ML20210T870
| ML20210T870 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/10/1997 |
| From: | BALTIMORE GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20210T868 | List: |
| References | |
| NUDOCS 9709160166 | |
| Download: ML20210T870 (774) | |
Text
{{#Wiki_filter:. . . . _ . _ _. _ _ _ _ _ . _ _ . _ _ _ _ _ . _ . _ . _ _ _ _ . _ . - -_ __ _ _ . . _ _ _ . _ . . _ _ . . . _ - . _ _ _ _ _ . ___ ._ l A'ITACilMENT (2) { 4 i IMPROVED TECIINICAL SPECIFICATIONS, REVISION 5
SUMMARY
OF CilANGES i 1 I I 9709160166 970910 PDR ADOCK 05000317 P PDR J Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant ' September 10,1997
NITACllMENT (2)
SUMMARY
OF CHANGES
- 1. He Actions of Improved Technical Specification (ITS) 3.4.1 have been revised to require the pit.nt to be placed in Mode 2 in the event any of the Reactor Coolant System (RCS) Departure <
from Nucleate Boiling parameters do not meet the limits and are not restored within two hours. This change is consistent with the current licensing basis provided in Current Technical J Specification (CTS) Limiting Condition for Operation (LCO) 3.2.5. To suppon this change, the Markups of CTS LCO 3.2.5 for ITS 3.4.1 were revised, Discussion of Change (DOC) L.1 for ITS 3.4.1 and its associated No Significant flazards Considerations (NSilC) eliminated, Justification for Deviation (JFD) 31 to Section 3.4 added, and JFD 26 to Dases Section 3.4 added. These changes were required to respond to an NRC Comment (ITS 3.4.1 Comment 1).
- 2. The Markups of CTS LCO 3.2.5.d for ITS 3.4.1 have been revised to indicate that the requirements regarding Axial Shape index are discussed in tha DOC for Specl0 cations 3.2.5. As a result of this change, DOC A.2 for ITS 3.4.1 was eliminated. This change was requested by the NRC (ITS 3.4.1 Comment 4),
- 3. The NRC requested additionaljustification regarding the retention of our current licensing basis values for pressurizer pressure, and RCS cold leg temperature. This justification is provided as 1
JFD 32 to Section 3.4. (ITS 3.4.1 Comments 5 and 6).
- 4. The Markups of CTS 3.4.9.1 for ITS 3.4.3 have been revised to establish that the LCO limits are being retained in ITS Figures 3.4.31 and 3.4.3 2, versus being stated in the LCO. Improved Technical Specifications Surveillance Requirement (SR) SR 3.4.3.1 will invoke these figures and ensure the LCO requirements are met. Discussion of Change A.2 for ITS 3.4.1 has been added tojustify these changes, nese changes were required to respond to an NRC comment (ITS 3.4.3 Comment 2).
- 5. The improved Standard Technical Specifications (ISTS) Bases markup for ITS 3.4.3 has been revised by deleting the following plant specific statement: "llowever, as a practical matter, it is not possible to violate the LCO when the reactor vessel head is removed or all reactor vessel head studs are removed." Additionally, JFD 5 to Bases Section 3.4 has been eliminated nis change was made to respond to an internal question.
- 6. The wording provided in the ISTS markup of the Bases for ITS LCO 3.4.5 was changed to match the wording in ITS LCO 3.4.5. Additionally, a plant speciuc justification (JFD 27 to Bases Section 3.4) was provided, rather than relying upon Technical Specification Task Force (TSTF)-177 (CEOG 83) as thejustification for changes to the Bases for ISTS LCO 3.4.5 Bases.
These changes have been made to respond to an NRC comment (ITS 3.4.5 Bases comment).
- 7. DOC LA.1 for ITS 3.4.5 was revised to state that the specific loop numbers and number of required RCPs per loop are being moved to the Bases. The ISTS markup of the Bases for ITS 3.4.5 was revised to include the required information. These changes have been made to respond to an NRC comment (ITS 3.4.5 Comment 1).
- 8. Note " of CTS 3.4.1.2 has been revised in the CTS markups for ITS 3.4.5 to denote that "a reactor coolant pump shall not be started with any RCS cold leg temperature less than or equal to
[the LTOP enable temperature) unless . . . " Currently, this Note simply refers to "the RCS temperature." This change provides consistency with a change made in the markups of Footnote 1
1 AUAGIMFNT (2)
SUMMARY
OF CilANGES
'" of CTS 3.4.1.3 for ITS 3.4.6. Tojustify the change, DOC A.3 for ITS 3.4.5 was added. This change was made to respond to an NRC comment (ITS 3.4.5 Comment 2).
- 9. The ISTS markups for Note 1.b for ITS LCOs 3.4.5,3.4.6, and 3.4.7 were revised to climinate a generic editorial change. The phrase ";t 10'F below saturation temperature" was changed to "at ,
least 10'F below saturation temperature " Additionally, the ISTS markup for Note 1.b of ITS LCO 3.4.8 and its corresponding Dases were revised to be consistent with similar notes for ITS ! LCOs 3.4.5, 3.4.6, and 3.4.7. This phrase is consistent with the current footnotes in CTS ' LCOs 3.4.1.2 and 3.4.1.3. These changes were made to respond to several NRC comments (ITS 3.4.5 Comment 3, ITS 3.4.6 Comment 2, and ITS 3.4.7 Comment 5). 2
- 10. Discussion of Change LA.1 for ITS 3 A.6 was revised to state that the specific loop numbers are being moved to the Bases. The ISTS markup of the Bases for ITS 3.4.6 was revised to include the required information. These changes have been made to respond to an NRC comment (ITS 3.4.6 Comment 1)
- 11. The markups of CTS LCO 3.4.1.3 for ITS 3 A.6 have been revised to denote that the climination of Footnote
- isjustified by DOC A.6 for ITS 3.4.6, not DOC A.5 for ITS 3.4.6. This change has
! been made to respond to an NRC comment (ITS 3.4.6 Comment 3).
- 12. The markups of CTS LCO 3.4.1.3 for ITS 3.4.6 have been revised to denote that the climination of Footnote # isjustified by DOC A.5 for ITS 3.4.6. This change has been made to respond to an NRC comment (ITS 3.4.6 Comment 4).
- 13. The NRC requested additionaljustification regarding the changes to Action b of CTS 3.4.1.3 for ITS 3.4.6. To resolve this comment the following changes were required: 1) the markups of the Actions of CTS 3.4.1.3 for ITS 3.4.6 were revised to reflect the changes to Action b of, CTS 3.4.1.3; 2) DOC M.5 for ITS 3.4.6 was added to provide additionaljustification for a number of i
changes to Actions a and b of CTS 3.4.1.3; 3) DOCS A.2 and L.1 (and its associated NSilC) for ITS 3.4.6 were deleted, because they were no longer used. (ITS 3.4.6 Comment 5) 1
- 14. The NRC requested additionaljustification regarding the addition of Note 4 ofITS LCO 3.4.7.
5 Discussion of Change L. 2 for ITS 3.4,7 and its associated NSilC were revised to include additionaljustification. Additionally,ISTS Dases markup for ITS 3.4.7 were revised to make the discussion of Note 4 consistent with the actual Note; this involved the deletion of a plant specific change. (ITS 3.4.7 Comment 2)
.While resolving the aforementioned NRC comment, it was discovered that the justification provided in DOC L.i for ITS 3.4.8 and its associated NSilC was similar to the justification provide; 6 DOC L.2 for ITS 3.4.7. Discussion of Change L.) for ITS 3.4.8 and its associated NSilC were revised to include additionaljustification.
- 15. The ISTS markups for ITS 3.4.7 and 3.4.8 and their Dases were revised by changing the references to "SDC train" or "SDC trains" to "SDC loop" or shutdown cooling (SDC) " loops,"
respectively. These changes ensure consistency regarding the references to the SDC loops. These changes were made to respond to an NRC comment (ITS 3.4.7 Comment 3). 2
i AHACllMENT f2) i
SUMMARY
OF CllANGES i l
\
- 16. Improved Technical Specification SRs 3.4.7.3 and 3.4.8.2 and their liases have been changed from "the required SDC pump that is not in operation" to "the required SDC loop components that are not in operation." ne markups for CTS SR 4.4.1.3.1 for ITS LCOs 3.4.7 and 3,4.8 have ,
been revised from " pumps and [SDC] loop valves" to " loop components," and DOCS LA.2 for ITS 3.4.7 and ITS 3.4.8 have been changed to reflect these revisions and their associated applications to theliases. The same changes have been made to the ISTS markup for ITS SRs 3.4.7.3 and 3.4.8.2. To justify these deviations, JFD 33 to Section 3.4 has been provided. Additionally, the markup of the ISTS Ilases for ITS SRs 3.4.7.3 and 3.4.8.2 have been revised to reflect the changes made to the ITS SRs. nese deviations were justified using existing JFDs 2 and 13 to Section 3.4. These changes were made te respond to NRC comments (ITS 3.4.7 Comment 4 and ITS 3.4.8 Comment 2). Additionally, while responding to the aforementioned NRC comments, it was discovered that the same issue existed in the markups andjustifications for ITS 3.4.6. Thus, the same changes were made to the markups of CTS SR 4.4.1.3.1 for ITS 3.4.6, DOC LA.2 for ITS 3.4.6, the ISTS markup for ITS SR 3.4.6.3, and the ISTS Ilases markup for ITS SR 3.4.6.3.
- 17. Discussion of Changes LA.1 for ITS 3.4.7 and 3.4.8 were revised to state that the specific loop numbers are being moved to the lla es. The ISTS markup of the Bases for ITS 3.4.7 and 3.4.8 were revised to include the required information. These changes have been made to respond to an NRC comment (ITS 3.4.7 Comment 6 and ITS 3.4.8 Comment 1).
- 18. He NRC requested additionaljustification for the deletion of the requirement for the pressurizer heaters to be capable of being powered by an emergency power supply, Justification for Deviation 26 to Section 3.4 was revised to provide the additionaljustification. Additionally, the ISTS markup of the Bases for ITS 3.4.9 was revised to state, in the llackground section, that the pressurizer heaters are permanently powered by Class IE power supplies, and to revise the llases for the LCO section to be consistent with the ISTS markup for ITS 3.4.9. The changes to the 11ases were justified with existing JFDs to Bases Section 3.4. (ITS 3.4.9 Comment 2).
- 19. The NRC requested additionaljustification for the deletion ofISTS SR 3.4.9.3 from ITS 3.4.9.
Justification for Deviation 21 for Section 3.4 was revised to include additional justification. (ITS 3.4.9 Comment 4)
- 20. Discussion of Change L.1 for ITS 3.4.10 and its associated NSilC were revised to include justification for: a) changing the shutdown requirements of the Action for ITS LCO 3.4.2.1 from llot Shutdown to Mode 3 with all RCS cold leg temperatures less than or equal to the low temperature overpressure protection (LTOP) enable temperature; and b) the deletion of Footnote
- of CTS LCO 3.4.2.1. As a result, DOC M,1 for ITS 3.4.10 was eliminated.
Additionally, JFD 9 to Section 3.4 was revised to include additional justification for deviating from the applicability ofISTS 3.4.10 in ITS 3,4.10. nese changes were required to iespond to NRC comments (ITS 3.4.10 Comments 1,3, and 4). Additionally, while resolving the comments, several errors were noted on the markups of the Appliubility of CTS LCO 3.4.2.1 for ITS 3.4.10. These errors included the incorrect LTOP enable temperature being identified in the Unit No. 2 markup, and the lack of units for the LTOP enable temperature in the Unit No, I markup. These errors were corrected. 3
AITACllMFNT 12) l
SUMMARY
OF CllANGES ! 21. The NRC questioned the addition of a note to Action A.1 in the ISTS markup ofITS 3.4.11. De note was removed because it was not consistent with the current licensing basis, in support of l this change, JFD 25 to Section 3.4 was deleted and the ISTS Ilases markup for ITS 3.4 !! were revised (ITS 3.4.11 Comment 1). While resolving the aforementioned NRC comment, issues were discovered in the markups of CTS 3.4.3 for ITS 3.4.11, and the ISTS markurs for ITS 3.4.11. These issues include: a) the failure to properly identify changes to the CTS actions; b) the unjustified deletion of a note that pennits separate condition entry for each power-operated relief valve (PORV); and c) an apparent generic error in the ISTS regarding the note that pennits separate condition entry for the PORVs; the note should also apply to the PORY block valves. The markups of the CTS actions were revised to be consistent with the ISTS markup of the ITS aalons, While not identified in the original CTS markup, the changes had been justified in DOCS M.1 and M.2 for ITS 3.4.11. A note that permits separate condition entry for each PORV and each block valvt; was added to the markups of CTS 3.4.3 for ITS 3.4.10. This change wasjustified by DOC A.6 for ITS 3.4.11. The ISTS markup for ITS 3.4.11 wts revised to include the PORV block valves. It wasjustified by JFD 36 to Section 3.4. The ISTS !!ases markup for ITS 3.4.11 was revised to be consistent with the revised ITS.
- 22. The markups of CTS SR 4.4.3.1.a for ITS 3.4.11 were revised to state that the deletion of the phrase "in accordance with Table 4.31, item 4" is actually an administrative change, versus a movement ofinfonnation. Thus, DOC A 5 for ITS 3.4.11 has been added to justify the change,
' and IX)C LA.1 for ITS 3.4.11 has been eliminated. These changes were made to respond to an NRC comment (ITS 3.4.11 Comment 2).
- 23. The NRC requested additional justification for incorporating CTS SRs 4.4.3.1.a and 4.4.3.1.b into ITS 3.4.11 as SRs 3.4.11.1 and 3.4.11,4. Justification for Deviation 12 to Section 3.4 has been revised to include the additional justification. Additionally, the ISTS llases markup for ITS 3.4.11 has been changed to better describe the current system design. (ITS 3.4.11 Comments 3 and 6)
While resolving the aforementioned NRC comment, several inconsistencies regarding the rationale for the PORV setpoint in the ISTS Ilases markup for ITS 3.4.11 were discovered. He 11ases have been revised to be consistent regarding the rationale for the PORV setpoint. The use of the term "only" in the Applicability regarding RCS cold leg temperature was changed to "all" to properly complement a related change in ITS 3.4.12 applicability. These tenns now accurately reflect NUREG 1432 and the current licensing basis. 24 The NRC requested additionaljustification for the changes to Actions a, b, and c ofidentified in the markups of CTS 3.4.3 for ITS 3.4.11. Discussion of Change L.1 for ITS 3,4.11 and its associated NSilC have been revised to include additional justification for the changes to Actions a, b, and c of CTS 3.4.3 (ITS 3.4.11 Comment 4), 4
I KETACubL'G 12)
SUMMARY
OF CilANGES
- 25. The NRC requested additionaljustification for the deviations from the Actions ident:Ged in the
, markups ofISTS 3.4.11 in ITS 3.4.11. Justincation for Deviation 11 to Section 3.4 has been , r: vised to simply address changes to completion times. Justification for Deviation 35 to Section 3.4 has been added to provide justification for the deviations frorn Actions D, E, F, and O of the ISTS in ITS 3.4.11 (ITS 3.4.11 Comments 7 and 8), i 26 The NRC requested additionaljustlucation for the deletion ofISTS SR 3.4.11.4 from ITS 3.4.11. Justification for Deviation 34 to Section 3.4 has been added to provide the justificatiot for deletion of this SR. Additionally, the ISTS Bases markup for ISTS SR 3.4.11.4 has been revised to show that the justification for this deviation is JFD 2 to Ilases Section 3.4, not JFD 1 to llases Section 3.4 (ITS 3.4.11 Comment 9). ' o
- 27. 'lhe NRC requested DOC A.2 for ITS 3,4.13 to be revised to specify the ITS the addresses CTS
, SRs 4.4.6.2.a.2 and 4.4.6.2.c. Discussion of Change A.2 for ITS 3.4.13 has been revised to justify the deletion of CTS SRs 4.4.6.2.a.2 and 4.4.6.2.c from 11S 3.4.13; it includes a reference
- to the Actions of ITS LCO 3.4.14, which preserve the _ context of the CTS SRs (ITS 3.4.13 Comment 2).
4
- 28. The NRC requested that the deviations proposed by TSTF 138 be removed from the submittal.
This TSTF was rejected by the NRC. The following have been revised to exclude the changes proposed by TSTF.138: 1) the markups of Action a of CTS LCO 3.4.6.2 for ITS 3.4.13; 2) the j markups of the Action of CTS LCO 3.4.5 for ITS 3.4.13; 3) the ISTS markup for ITS LCO 3.4.13; and 4) the ISTS Bases markup for ITS 3.4.13. The ISTS Bases markup for ITS
- SR 3.4.13.2 was changed to indicate that compliance with LCO 3.0.3 is required when one or
- inore steam generators do not meet the requirements of the Steam Generator Tube Surveillance j Program. This deviation isjustined by JFD 13 to Bases Section 3.4. Additionally, DOC A.3 and DOC A.5 for ITS 3.4.13 were revised to ensure consistency with the revised CTS markup and to improve thejustifications. Also, DOC M 1 for ITS 3,4.13 was deleted, because it was no longer used (ITS 3.4.13 Comments 4,5, and 6).
i
- 29. The NRC requested additionaljustification for the deletion of CTS SRs 4.4.6.2.a.1,4.4.6.2.b, and
, 4.4.6.2.d from ITS 3.4.13. Discussion of Change L.I for ITS 3.4.13 and its associated NSilC have been revised to provide additionaljustification for the changes (ITS 3.4.13 Comment 7).
- 30. The deviations proposed by TSTF-ll6 have been removed from the submittal. To accomplish this, the following changes were made: 1) the markups of CTS SR 4.4.6.2.c for ITS 3.4.13 were revised to eliminate the proposed note, and to denote that part of the SR would be addressed in ITS 3.4.14; 2) DOCS A.2 and L.2 (and its associated NSilC) for ITS 3.4.13 were climinated; 3)the markups of Action b.2 of ITS LCO 3.4.6.1 for ITS 3.4.1/ .ere revised to climinate the i proposed note; 4) markups of CTS SR 4.4.6.2.c were added to ITS 3.4.14. As a result, the CTS markup pages for ITS 3.4.14 were repaginated; 5) DOC L.6 for ITS 3.4.14 and its associated NSilC were eliminated; 6) DOC M.1 for ITS 3.4.14 was added to justify a change to CTS SR 4.4.6.2.c; 7) the ISTS markup for ITS SR 3.4.13.1 was revised; 8) the deviation from ISTS SR 3.4.13.1 was justified by JFD 38 to Section 3.4; 9) the ISTS markup for ITS 3.4.14 was revised; and 10) the ISTS markups for the Bases of ITS 3,4.13 and 3.4.14 were revised (ITS 3.4.14 Comment 1).
4 L 5
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AIIACilMENT A
SUMMARY
OF Cil ANGES
- 31. lhe NRC requested additionaljustf acation for the changes to CTS Tables 3.3 6 and 4.3 3 for ITS 3.4.14. The following changes were made to resolve the commnts: 1) the references to the ITS SRs in the markup of CTS SR 4.4.6.1 for ITS 3.4.14 had to be revised to be consistent with the actual 11S SR numbers; 2) the markups for CTS Table 3.3 6 had u be remarked; 3) the references to the applicable ITS requirements on the matkup for CTS Table 4.3 3 had to be changed or added to be consistent with ITS 3,4.14; 4) DOC LA.I for ITS 3.4.14 had to be added tojustify a change to CTS Table 3.3 6; 5) DOC Ll for ITS 3.4.14 and its associated NSilC had to be revisco to reDect changes to CTS Table 3.3 6, and to improve the justification; 6) the !STS markup for ITS 3.4.14 had to be revised to properly rencet the CTS SRs and Tables; and 7) the ISTS Unses markup for ITS 3.4.14 had to be revised to include the range of operation for the containment atmosphere radioactivity monitors (ITS 3.4.14 Comments 2 and 3). j
- 32. The NRC requested additional justification for a change included in the markups of CTS SR 4.10.5.2 for ITS 3.4.17. They also reauested that the markups of CTS LCO 3.10.5.c for ITS 3.4.17 be modified to accurately reDect the requirements of ITS 3.4.17. While resolving these comments, numerous deficiencies with the original submittal regarding ITS 3.4.17 were ;
identified. To resolve these comments and issues, the following changes were required: 1) the markups of CTS 3/4.10.5 for ITS 3.4.17 were revised to rencet the current licensing bases;
- 2) DOCS LA.1, LA.2, and A.2 were climinated; 3)IX)C A.3 was created tojustify changes to the CTS; and 4) ITS 3.4.17 had to be revised to be consistent with the current licensing bases (ITS 3.4.17 Comments I and 2). -
- 33. The NRC requested additional justification for Relocated Specifications based on not meeting the four criteria in 10 CFR 50.36(2)(11) for retention in the Calvert Cliffs Technical Speci0 cations. Discussion of Changes R.1, R.2, R.3, R.4, R.5, and R.6 were revised to provide additionaljustification (ITS 3.4 Relocated Specifications Comment).
- 34. The NRC requested additionaljustification for excluding a specification regarding RCS primary isolation valve leakage from the ITS. JFD 16 to Section 3.4 was revised to provide additional justification (ITS 3.4 Primary isolation Valve Comment).
- 35. Technical Specification Task Force TSTF 153 modified the Note ofISTS LCO 3.4.5, Note 1 of ISTS LCO 3.4.6, Notes I and 4 ofISTS LCO 3.4.7, and Note 1 ofISTS LCO 3.4.8. This TSTF has been approved. Thus, it was incorporated into the ITS. Unfortunately, the TSTF creates the potential for an incorrect interpretation, it replaced various phrases in the notes with the phrase "may not be in operation." This phrase could be misintcrpreted to mean that the pumps cannot be in operation. This was not the intent of the TS1 F The phrase may not be iri operation" was replaced with the phrase "may be not in operation." The ISTS mr. kups of Note 1 to ITS LCO 3.4.5, Note 1 of ITS LCO 3.4.6, Notes 1 and 4 of ITS LCO 3.4.7, and Note 1 of ITS LCO 3,4.8 were revised. These deviations are justified by JFD 37 to Section 3.4. Additionally, the ISTS markup for the Bases ofITS 3.4.5 had to be revised to reDect the revised note; this deviation isjustified by JFD 2 to Dases Seelon 3.4.
- 36. Combustion Engineering Owners Group (CEOO) .109 has not received NRC approval. Thus, the deviations proposed by the CEOO-were provided with a plant specinc justification.
Justification for Deviations 28 and 29 to Bases Section 3.4 were added to provide the niaat-specific justlGeation for the deviations to the ISTS Bases. Additionally, while resolving this 6
ATIACILirNT 01 , SUMM ARY OF CilANGES
.i.2ue, it was discovered that a deviation was made to the ISTS Bases in the llases for ITS 3.4.6 without a jostincation being identined. 'this issue was conected; the proposed deviation is justified by JFD 6 to Bases Section 3.4. l 3?. While resolving NRC anestions regarding ITS 3.4.14, it was discovered that the markups of f Actlan b of CTS !LO 3.4.6.1 for ITS 3.4.14 did not accurately reDect the changes made to l convert to ITS 3.4.14.11w CTS markups were revised to denote the changes, and DOC L.3 for ITS 3 4.14 w.d l:s m.sisted NSilC were revised to justify the changes.
- 38. The deviation peuposwi by TSTF.3 was removed from ISTS INes markup for ITS 3.4.15. This generic change was rejected by tbc NRC.
l l
- 39. Improved Technical Speclucation 3.4.12, Low Temperature Overpressure Protection (LTOP)
System," and associated 11ases have been revised to be consistent with the Calvert Cliffs LTOP analysis redected in CTS 3/4.9.3. As a result of this change and subsequent review of supporting information, the following changes were also made: 1) DOCS A.2, A.3, A.4, LA.1, LA.2, and L.2 (and associated NSilC) for ITS 3.4.12 were revised; 2) DOCS A.5, M.1, and L.1 (and associated NSilC) for ITS 3.4.12 are deleted, because they are no longer used; 3) new DOCS A.8, M.2, am L.5 (and associated NSilC) were provided for ITS 3.4.12; 4) JFD 14 for Section 3.4 was revised; 5) JFD 20 for Section 3.4 was deleted; 6) JFD 24 for Section 3.4 was deleted; and 7) JFD 39 for Section 3.4 was added, A typographical / grammatical error in JFD for ITS Ilases Section 3.4 was corrected. These changes were made in the response to NRC Comments (l'IS 3.4.12 Comments 1,2,3,4, $ 6,8,9,10,11,12, and 13).
- 40. 'The proposed devinions of TSTF.27 were removed. This TSTF has not been approved by the NRC. The following changes were required to remove this TSTF: 1) the markups for CTS 4.1.1.5.a and 4.1.1.5.b were revised to renect that the current SRs were being maintained, except the frequency for CTS 4.1.1.5.a is being extended to 30 minutes; 2) DOC L.1 for ITS 3.4.2 and its associated NSilC were revised to reDect the change to CTS 4.1.1.5.a;
- 3) DOCS A.3 and I 2 (and its associated NSilC) for ITS 3.4.2 were climinated, because they are no longer used; 4)ISTS markup for ITS SR 3,4.2.1 was revised to reDect CTS SRs 4.1.1.5.a and 4.1.1.5.b, except for the frequency of CTS SR 4.1.1.5.a; 5) the deviation to the ISTS wasjustined by JFD 28 to Section 3.4; and 6) the ISTS Bases markup for 11S SR 3.4.2.1 was revised to be consistent v;!th the revised ITS SR.
Additionally, an internal review identified that the nominal T , for making the reactor critical was not correct in the ISTS Bases markup for ITS 3.4.12. The value is $32'F, not $25'F. This issue has been corrected in the ISTS Bases markup for ll a 3.4.2.
- 41. The NRC requested additional justi0 cation for changing the Frequency of CTS 4.2.5.2 from 18 months to 24 months (ITS 3.4.1 Comment 2). Additionaljustification has been provided in DOC L.3 for ITS 3.4.1. This change is not beyond the scope of the ITS process. Extending surveillance frequencies from 18 to 24 months has been conducted as part of the ITS process.
- 42. Discussion of Change L.1 was revised to provide additional justification for allowing a steam generator at a level of 2 50 inches as a second method for removing decay heat. This change has been made to respond to an NRC comment (ITS 3.4.7 Comment 1).
7
i I NrrACilMENT f2)
SUMMARY
OF CilANGr.S 43, Discussion of Deviation 27 for Section 3.4 was revised to provide additional justification for extending ITS SR 3.4.9.2 from 92 days to 24 months. This change has been made to respond to an NRC comment (11S 3 4.9 Comment 3).
- 44. 'the NRC requested additionaljustification for changing the Frequency of CTS 4.4.3.1.a from l 31 days to 92 days (ITS 3.4.11 Comment $). DOC L.2 has been revised to provide the requested
! Infonnation. 8
I l l ATTACllMENT G) IMPROVED TECIINICAL SPECIFICATIONS, REVISION 4 AMENDMENT REVISION BY CilANGE Haltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant September 10,1997
- l. The Actions of improved Technical Specl0 cation (ITS) 3.4.1 have been revised to require the pla it to be placed in Mode 2 in the event any of the Reactor Coolant System (RCS) Departure from Nuclette lloiling parameters do not meet the limits and are not restored within two hours.
This change is consistent with the current licensing basis provided in Current Technical Speel0 cation (CTS) 1.imiting Condition for Operation (l CO) 3.2.5. To support this change, the Markups of CTS LCO 3.2.5 for ITS 3.4.1 were revised, Discussion of Change (DOC) L.I for ITS 3.4.1 and its associated No bignl0 cant liarards Considerations (NSilC) eliminated, Justl0 cation for Deviation (JFD) 31 to Section 3.4 added, and JFD 26 to Ilases Section 3.4 added. Thpse changes were required to respond to an NRC Comment (ITS 3.4.1 Comment 1). l
]
OVERYlEW OF CHANGES i SECTION 3.4 - REACTOR COOLANT SYSTEM
'lhe significant differences between the current Technicsl Specifications and the proposed Improved Technical SpeelGeations are:
- Delay is allowed in the performance of some surveillances to allow plant conditions to stabillte or time to ast,ess the situition, e
lhe specification which requires coolant loops to be Operable in Modes 4 and $ is spilt into three specifications.
. .Some allowed outage times are reduced.
- Some Limiting Condition for Operations are being relocated out of the specifications.
The significant differences between the proposed improved Technical Specifications and NUREG 1432, Revision 1, as modified by generic changes, are: An improved Technical Specification allowance to de energlie the reactor coolant pumps for up to two hours per eight hour period for low flow testing, as contained in the current Technical ' Specifications, was added to Specification 3.4.5. The Calvert Cliffs low flow test requirement requires more than one hour, e Plant specific power operated relief valve and low temperature overpressure protection specifications are incorporated.
* 'lhe Reactor Coolant System pressurizer isolation valve leakage specification was not incorporated. Calvert Cliffs does not currently have this specification, and the Calvert Cliffs design for the applicable accident does not warrant this specification.
L CALVERT CLIFFS-UNITS I & 2 3.41 Revision 5
RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.1 RCS Pressure. Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits LC0 3.4.1 RCS ONB parameters for pressurizer pressure, cold leg temperature, and RCS total flow rate shall be within the ! limits specified below 1
- a. Pressurizer pressure 2 2200 psia
- b. RCS cold leg temperature (Tc) s 548'F; and
- c. RCS total flow rate 2 370,000 gpm. l APPLICABILITY: MODE 1.
............................N0TE..-.-.-..-....--.-..-..--..-
Pressurizer pressure limit does not apply during:
- a. THERMAL POWER ramp > 5% RTP per minutet or
- b. THERMAL POWER step
- 10% RTP.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
-A. RCS DNB parameter (s) A.1 Restoreparameter(s) 2 hours
-not within limits. to within limit.
B. Required Action and B.1 Be in MODE 2. 6 hours associated Completion Time not met. g
-- . S' CALVERT CLIFFS - UNITS 1 & 2' 3.4.1 1 Revisiongg
RCS Pressure. Temperature, and flow DNB Limits B 3.4.1 B_ASES
> 5% RTP pSr minute or a THERMAL POWER step increase of
> 10% RTP. These conditions represent short term perturbations where actions to control pressure variations might be counterproductive. Also, since they represent transients initiated from power levels < 100% RTP, an increased DNBR margin exists to offset the temporary pressure variations.
~
Another set of limits on DNB related parameters is provided inSafetyLimit(SL)2.1.1,"ReactorCoreSafetyLimits." Those limits are less restrictive than the limits of this LCO, but violation of SLs merits a stricter, more severe Required Action. Should a violation of this LCO occur, the operator should check whether or not an SL may have been exceeded. ACTIONS M Pressurizer pressure and RCS cold leg temperature are l g-controllable and measurable parameters. RCS flow rate is l not a controllable parameter and is not expected to vary during steady state operation. With any parameter not 5' within its LCO limit, action must be taken to restore the parameter. f The 2 hour Completion Time for restoration of the parameters provides sufficient time to adjust plant parameters, to determine the cause of the off normal condition, and to restore the readings within limits. The Completion Time is based on plant operating experience that shows the parameter can be restored in this time period. M If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the CALVERT CLIFFS - UNITS 1 & 2 8 3.4.1-3 Revision 65'
RCS Pressure Temperature, and Floc DNB Limits B 3.4.1 l I BASES plant must be brought to at least MODE 2 within 6 hours. In NODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. Six hours is a reasonable time that permits the plant power to be reduced at an orderly rate in conjunction with even controlofsteamgenerator(SG)heatremoval. G SURVE1LLANCE -SR 3.4.1.1 ! REQUIREMENTS Since Required Action A.1 allows a Completion Time of 2 hours to restore parameters that are not within limits, the 12 hour Surveillance Frequency for pressurizer pressure ' is sufficient to ensure that the pressure can be restored to a normal operation, steady state condition following load changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and verify operation is within safety analysis assumptions.
-SR 3.4.1.2 Since Required Action A.1 allows a Completion Time of
] 2 hours to restore parameters that are not within limits, the 12 hour Surveillance Frequency for cold leg temperature is sufficient to ensure that the RCS coolant temperature can be restored to a normal operation. steady state condition following load changes and other expected transient operations. . The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety analysis assumptions. 4 4
- CALVERT CLIFFS - UNITS 1 & 2- B 3.4.1-4 Revisiong5' , __ _ . _ _ _ ___ _ . _ , - 2_~ - _ _ . - - - _ _. . ~ _ _ _ _ _ _ - _ . _
spaAdm 34,1 RrAch[Y) 34 W FWhiTRiis~~~ _ _ m_ - _ _ _ _ _ _ _ _ _ _
" g,g 3,4,1 3/4.2.6 6 ft,,5 ftu M E, N e b't-, A N a A r d m F,a
- Asledt _b.) t i c.649 Liqd' 'h-
- ~-
LIMITING EON 0!T!0N FOR OPERATION ~ . ; WO 3 4+I following DNB related parameters shall be maintained within the
- 4. Cold Ltg Temperature S 648*f 6(( % V'd %, ob C #. Pressurizer Pressure a 2200 psia' 'd ' " ' Sp .
'e 's.2 4
- c. Reactor Coolant System total flow Rate 2 370.000 im
- d. AXIAL $ NAPE INDEX. THERMAL POWER as specified in e COLR. l APPLICABILITY: MODE 1. .
h e.t u ss % 4p'0" g e ACTION: With any of the above parsme+ers exceerling its limit, restore the k gessthanMofRATEDTHERMALPOWL?withinthenextarameter ours. to within its limit witrin 2 hours o SURVE!LLANCE pt0UIREMENTS
- 24' I arame
" 3lj, ,, 4dr6d at least once Each perof 12 the kours.ters shall be verified to be within their Itmits l M 3dM A.2.5.2-The Reactor Coolant System total flow rate shal be determined to be within its limit by measurement at least once per months. 4 2+
b 1 1 1 Limit not a licable durin either a THERMAL POWER ramp increase in
](excess
. increase of greater ofthan5% of RATED THER L POWER per minute or a THERMAL POWER step 10% of RATED THERMAL POWER.
CALVERT Cliffs - UNIT 1 3/4 2-8 Amendment No.186 payI *f l
-<,r p --- h'+W- W 'w - - - ' ' w 7 +-
F--"w'-T-*'-T-- - - - gag P ry-mWia-'T-e-+
$pec8eg4.m 3. k. l 1
hSW k _ k I I: A,l g,4
~
4/4+ POWER DISTRIBUTION LIMITS _m
'5. 4. I 3/4.2.s .ma,aARmans Rc5 A as s -, <, T~ r< W w t e , ~J Fl. ~
O.P r4 w, e F'co - thi m G o . t. . LIMITING CONDITION FOR OPERATION NC)_Liy.4 _
+rer5- The following bN8 related parameters shall be maintained within the limits shoin:
l b ff. Cold' Leg Temperature s; 548'f _-- ,
'N O. X. Pressurizer Pressure 2 2200 psia \ S of EC O4U M{fw' Ckco g,g . %% 3,2 6'
- c. Reactor Coolant System Total Flow Rate 2 370,000 ppm *M NT
- d. AXIAL SNAP 2 INDEX, TNEllMAL POUER as specified in the COLR l
APPLICABILITY: MODE 1. A c '1 m ta Q ACTION: With an of the above parameters exceedin (ts Itmit, restore the A c b'on A arameter to wit in its limit within 2 hours or re uce THERMAL POWER to ess than 5% of RATED THERMAL POWER within the next ours. SURVEILLANCE REQUIREMENTS g, 4.44ri. at least Each of the arameters shall be verified to be within their limits l g 3 4, ,, once per 12 ours.
% 3 4 i,4 4.2.5.2 The Reactor Coolant System total flow rate shall be detemined tw .
bc within its limit by meaurement at least once per.Mrmonths.f A fieedh $4e -
.i Limit not applicable' during ett er THERMAL POWER ramp increase in excess of 5% of RATED THERMAL POWER per minute or a THERMAL POWER step increase of grea'er than 1% of RATED THERMAL POWER.
CALVERT CLIFFS - tlNIT 2 3/4 2-8 Amendment No. 163
DISCUSSION OF CilANGES SECTION 3.4.1 - RCS PRESSURE, TEMPERATURE, AND FLOW (DNB) LIMITS ADMINISTRATIVE CIIANGES A.1 'Ihe proposed change will zeformat, renumber, and reword the existing Technical Specifications, with no change ofintent, to be consistent with NUREG 1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs improved Technical Specification (ITS) development, certain wording preferences or conventions were adopted which resulted in no technical changes to
, the Technical Specihtions. Additional information may also have been added ta more fully describe cact. titing Condition for Operation (LCO) 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 Specifications.
A.2 Not used. l t , TECIINICAL CIIANGES - MORE RESTRICTIVE None TECIINICAL- CIIANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS None TECIINICAL CIIANGES - LESS RESTRICTIVE L.1 Not used. l L.2 Current Technical Specification 3.2.5 Action requires the unit to reduce power within four hours when the Action cannot be met. Improved Technical Specification Actions B and D will allow six hours to reduce power when Actions A and C, respectively, cannot be met. The two additional hours to reduce power, from four hours to six hours, will allow for a more controlled power reduction (which is a transient in itself), in conjunction with even control of steam generator (SG) heat removal. This change is consistent with NUREG-1432. L.3 Current Technical Specification 3.2.5 Surveillance Requirement (SR) 4.2.5.2 requires the RCS total flow rate to be determined within its limit by measurement once per 18 months. Improved Technical Specification 3.4.1 SR 3.4.1.4 decreases the Surveillance Frequency to 24 months (consistent with the Calvert Cliffs refueling interval). The RCS flow rate does not normally change much during the fuel cycle; however, changes will be detected by ITS SR 3.4.1.3 which requires the flow to be verified every 12 bours. Reactor Coolant System flow will be most likely to change after refueling outages when the core has been altered, which may cause a change in flow resistance. Thus, it is important that this detailed test be CALVERT CLIFFS - UNITS 1 & 2 3.4.1 1 Revision 5
NO SIGNIFICANT liAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM
- 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed changes move details from the Technical Specifications to a licensee-controlled document. He changes will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed changes. T 3roposed changes will not introduce any new accident initiators. 'Ihe changes will ra .mpose different requirements, and adequate contro' ofinformation will be maintained. The changes will not alter assumptions made in the safety analysis and licensing basis. Herefore, the changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction tu the margin of safety?
The proposed changes move details from the Technical Specifications to a licensee-controlled document. The changes do not reduce the margin of safety since they have no impact on any safety analysis assumptions. In addition, the details to be moved from the Technical Specifications to a licensee-controlled document are the same as the existing Technical Specificatlans. Since any future changes to this licensee-controlled document will be evaluated per the requirements of the Calvert Cliffs change control process, no reduction (significant or insignificant) in a margin of safety will be allowed without prior NRC approval. The NRC review provides a certain margin of safety, and although this review will no longer be performed prior to submi'tal, the NRC can audit the Calvert Cliffs change control process. Therefore, the margin of safety lost by not requiring NRC prior approval is not significant. Also, since the proposed changes are consistent with the Combustion Engineering Plants Standard Technical Specification, NUREG 1432, approved by the NRC Staff, revising the Technical Specifications to reflect the approved level of detail reinforces the conclusion that there is no significant reduction in the margin of safety. Therefore, the changes do not involve a significant reduction in the margin of safety. TECIINICAL CIIANGES - LESS RESTRICTIVE Baltimore Gas and Electric Company, Calvert Cliffs Units I and 2, is converting to the ITS as outlined in NUREG-1432, " Standard Technical Specifications, Combustion Engineering Plants." The proposed change involves making the Current Technical Specifications (CTS) less restrictive. Below are the No Significant Hazards Considerations for conversion to NUREG-1432, in accordance with the criteria set forth in 10 CFR 50.92, BGE has evaluated these proposed Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion. 3.4.1 Change L.1 Not used. l CALVERT C1.lFFS - UNITS 1 & 2 3-4 5 Revision 5
RCS Pressure, Temperature, and FlowhNBfLimits 3.4.1 (erb 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 RCS Pressure, Temperature, and Flow'{ Departure from Nucleate Boiling (DNB)}4 Limits (3,2.ShLCO 3.4.1 RCS ONB parameters for pressurizer pressure, cold leg temperature limitsspecIfledbelowsand RCS total flow rate shall be within the ( 3.2. C b )a. Pressurizer pressure 2 psia aM : (???!' - i$ [ 3 2.C D b. RCS cold -leg temperature
;r ; ::-{T[Ili!!:'."
=e .: :: re h
- e. : ::"4:.RT
'5"r " ' and
. -- r= *F gpq g "b
[3.7. r.e.) c. al flow rate h te 15; ::;xris : "." ' !!B g g APPLICABILITY: MODE 1. l
-----------------------------NOTE----------------------------
Pressurizer pressure limit does not apply during: (y,g,f a. THERMAL POWER ramp > 5% RTP per minute; or
- b. THERMAL POWER step > 10% RTP.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
^
4,4 ft Ib N*w$$1ri 1
- wit
- cs - m ,,u {ta au 1j.1 1ts.
B. Required Action and B.1 Be in MODE 2. 6 hours b ' (continued) CEOG STS-3.4-1 Rev1,04/07/95
RCS Pressure. Temperature, and Flow [DNB) Limits 3 4.1 ACTIONS (continued) CONDITION REQUIRED ACTION CONPLETION TINC C. RCScolh\og C. N 2 hourt
\e temperatu not within Restore cold temperature to wileg't(in limits, liatts.
N ' a D. utred Action and 0.1 Redu ass lated Completion THERMAL POWER 6 urs Time f Condition C to 5 [ % RTP. j SURVE!lLANCE REQUIREMENTS SURVEILLANCE FREQUENCY [42A8)SR 3.4.1.1 Verify pressurizer pressure 2 psia 12 hours O
=4:[ms: .
(4.3,s a)SR 3.4.1.2 "*F 12 hours M Verify end s RCS
- cold F 'er leg temperature
' '70': ".?? r i 5 t-(("M- v ar.d ; 55Sl '" f;7 ;. '70l%"'".
)
(1.75/)SR 3.4.1.3 ------
-----------NOT---------------
Requ ed to be met i MODE 1 with all cps ru ng, 30 ig t- -_ 3 70, oaoMg--.--.------ -------V V f fy RCS total riow rate 12 hours t.3AS EE! n!heu- @ (c !" ' 55] It/ W @ g kh (continued) CEOG STS 3.4-2 Rev 1, 04/07/95
DISCUSSION OF TECHNICAlo SPECIFICATION DEVIATIONS FROM NUREC~1432 SECTION 3.4 - REACTOR COOLANT SYSTEM
- 31. The Actions for NUREG 1432 LCO 3.4.1 were modified to reflect the Action requirements of CTS 3.1.5 for RCS cold leg temperature not being within limits. He Action for CTS 3.1.5 requires the restoration of RCS cold leg temperature to within limits, or Thermal Power be reduced to less than 5% of Rated Thermal Power (i.e., Mode 2), ne Action for CTS 3.1.5 is the same regardless of which parameter (i.e., pressurizer pressure, RCS flow rate, or RCS cold leg temperature) is out of limits. Hus, Action A of ITS 3.4.1 provides the requirements for restoration of the parameter, and Action B oflTS 3.4.1 provides the requirements for exiting the mode of applicability in the event the parameter cannot be restored to within limits within two hours.
- 32. In NUREG-1432 LCOs 3.4.1.a and 3.4.1.b, the limits for pressurizer pressure and RCS cold leg
, temperature are expressed in ranges, in ITS LCO 3.4.1.a,vonly a minimum limit is established ._,
for pressurizer pressure. This limit is consistent with the initial assumption regarding pressurizer pressure in the Calvert Clifts accident analysis. This limit was approved by the NRC in License Amendment No. 88 to Facility Operating License No.DPR 53 for Unit No.1, and License Amendment No. 61 to Facility Operating License No. DPR 69 for Unit No. 2. In ITS LCO 3.4.1.b, only a maximum limit is established for RCS cold leg temperature. This limit is consistent with the initial assumptions regarding RCS cold leg temperature in the Calvert Cliffs accident analysis. This limit was approved by the NRC in License Amendment No. 39 to Facility Operating License No. DPR-53 for Unit No.1. and License Amendment No. 9 to Facility Operating License No. DPR-69 for Unit No. 2. Thus, these deviations are consistent with the current licensing basis for Calvert Cliffs.
- 33. NUREG-1432 SRs 3.4.6.3,3.4.7.3, and 3.4.8.2 require the verification of the correct breaker ,
alignment and indicated power available to the required pump that is not in operation. NUREG-1432 SR 3.4.6.3 applies to the RCS and SDC pumps, while NUREG 1432 SRs 3.4.7.3 and 3.4.8.2 only apply to the SDC pumps. Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignments and indicated power availability for the required shutdown cooling pumps and valves that are not in operation. NUREG 1432 SRs 3.4.6.3, 3.4.7.3, and 3.4.8.2 have been modified to reflect the additional requirement to verify the correct breaker alignments and indicated power availability for the required shutdown cooling valves, which is consistent with the Calvert Cliffs current licensing basis. These SRs were modified by replacing the word " pump" with the words " loop components." The components required to be checked by the SRs will be denoted in the Bases. For the RCS loop, the required component is the RCS pump. For the SDC loop, the required components are the pump and the valves. -
- 34. NUREG-1432 SR 3.4.11.4 requires the verification that the PORVs and block valves are capable of being powered by an emergency power supply. This surveillance does not exist in CTS 3/4.4.3. Improved Technical Specification 3.4.11 will not contain a surveillance to verify that the PORVs and block valves are capable of being powered by an emergency power supply.
This is appropriate, because the PORVs and block valves are permanently powered by Class IE power supplies. Class IE power sources are backed-up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under-voltage condition. The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied by a Class IE power source (e.g., the safety injection systems) do not contain SRs to verify the CALVERT CLIFFS-UNITS 1 & 2 3.4-8 Revision 5 . e
RCS Pressure Temperature, and flow OND} tts B 3.4.1 BASE 3 APPLICABILITY (continued) counterproductive. Also since they represent transients initiated from power leve,ls < 1005 RTP an increased DNBR margin exists to offset the temporary p,ressure variations. Another in Safetyset of limits Limit SL on DNS related parameters is provided 2.1.1, ' Reactor Core Safety L'imits.' Those LCO, Required limitsof SLs butAction. violation are(les)s merits a stricter,restrictive more severethan the limits of this operator should check whether or not an SL may have beenShould a violatio exceeded. ACTIONS A,J Md N3 C#' ( harnp )assurizerhressure-aramete w ith + controllable and measurable ( action st be taken to,arameter not within restore the: parameter. L ,0 limits. . T;,, ; ;._ - m :... :: i. .. - ..m _ . ,_ -
- x. period.1 qime ". . .;$t snows the parameter can be restored in this d'
3 A MM 4 RCS flow rate is not a controllable parameter and xpected to vary r nob n,_2 .;___.au durina su ~-- steady-state - operation.1 .-
' ' ' = ' ' -
e_ 2- c ';' ' "" ' w"'" r ru ' = JZ Z.' iif r.'
- i PT
' ' Tf Z, C'C ..Ij'_ '""I
' ~'i' T".
" Ii' '_'i I? _ ' ?M I #
' ' " ' " ' ' ~ ' '
The 2 hour Completion Time for restoration of the parameters provides sufficient time to adjust plant parameters, to deter 1nine the cause of the off normal condition, and to restore the readings within limits. based on plant operating experience The Completion Time is 1 g ] ILl If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a M00E in which the LCO does not apply. To achieve this status the plant must be brought to at least MODE 2 within 6 hour,s. In MODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. (continued) CEOG STS B 3.4-3 Rev 1, 04/07/95 ___ J
. - - ~ ~ _ _ . . ~ - -. . _ . . . - - . - . - _ - _ . . _ - . . ---. . --
4 4 1 RCSPressure, Temperature,andFlowkDNB mits B 3.4.1 BASES ACTIONS' A d (coatinued) Six hours is a reasonable time that pomits the plant power to be reduced at an orderly rate in conjunction with even . control of steam generator (SG) beat removal. ' ! ( G.1: , ' Id leg t rature is a ontrollable and asurable pa ter. this parame is not within LC0 iteits,
)
- act n must be kan to rest the parameter. ,
The 2 ur Complet Time is ba on plant opera ng perlen that show that the par ter can be rest in t time riod. ! na - If Requir Acti C.1 is not within the i Completion sociated
, RMAL POWER be reduced
[305) RTP. lant peration may } 4 pe od of time th condition. A tinue for an ndefinite I-i' ' leve the potent 1f violation of a DN8 limits sr he reduced great reduced. The 6 hou ompletion se a reasonable that pers r reduct n at an o A ( trol of SG t removal rly ateinconjunc on with even s SURVEILLANCE rR 3.4.1.1 REQUIREMENTS i' Since Required Action A.1 allows a Completion Time of 2 hours to restore parameters that are not within limits, !' the 12 hour Surveillance frequency for pressurizer pressure is sufficient to ensure that the pressure can be restored to-
- a nomal operation, steady state condition following load D . changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and ~
- verify operation is within safety analysis assumptions. _
i (continued) i CEOG STS B 3.4-4 { Rev 1. 04/07/95 p 9 4 p l 4 2
- ~ . . . - - . . . - - -. - , . . . -
DISCUSSION OF BASES DEVIATIONS FROM NUREG-1432 SECTION 3A - REACTOR COOLANT SYSTEM 23. Calvert Cliffs is not committed to the General Design Criteria in 10 CFR Part 50, Appendix A; Calvert Cliffs is committed to the draft General Design Criteria. Therefore, the Criteria in the draft General Design Criteria, where applicable, were referenced in the Technical Specification Bases. 24. Bases statements which refer to the CFR 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 Clifts are I approved by the Nuclear Regulatory Commission and stated in the Updated Final Safety Analysis Report. He CFR contains the maximum allowable limits, not plant specific 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. 25. NUREG 1432 B 3.4.12 SR 3.4.12.1 Section allows an alternate method of LTOP control to be employed using at least two independent means to prevent injection into the RCS such that a single failure or single action will not result in an injection into the RCS. It allows this to be accomplished through the pump control switch being placed in pull to lock and at least one valve in the discharge flow path being closed. Improved Technical Specification SR 3.4.12.1 Bases will allow verification that the llPSI pumps will not inject into the RCS by verifying their discharge valves are locked shut. This change is consistent with the Calvert Cliffs design and current licensing basis.
- 26. The Actions for NUREG 1432 LCO 3.4.1 were modified to reflect the Action requirements of CTS 3.1.5 for RCS cold leg temperature not being within limits. The Action for CTS 3.1.5 requires the restoration of RCS cold leg temperature to within limits, or Thermal Power be reduced to less than 5% of Rated Thermal Power (i.e., Mode 2). The Action for CTS 3.1.5 is the -
same regardless of which parameter (i.e., pressurizer pressure, RCS flow rate, or RCS cold leg temperature) is out of limits. Thus, Action A of ITS 3.4.1 provides the requirements for restoration of the parameter, and Action B ofITS 3.4.1 provides the requirements for exiting the mode of applicability in the event the parameter cannot be restored to within limits within two hours.
- 27. The Bases for NUREG-1432 LCO 3.4.5 state, "An OPERABLE toop consists of at least one RCP providing forced flow for heat transfer and . . . ." This statement is not consistent with the requirements of NUREG-1432 LCO 3.4.5. NUREG-1432 LCO 3.4.5 requires [two] RCS loops to be OPERABLE and one RCS loop to be in operation. The LCO only requires one loop to be providing forced circulation; the second loop only needs to be capable of providing forced circulation. Improved Technical Specification LCO 3.4.5 requires two RCS loops to be Operable and one RCS leop to be in operation. This is consistent with CTS LCO 3.4.1.2. Thus, the Bases for ITS LCO 3.4.5 have been revised to state, "An OPERABLE RCS loop consists of at least one OPERABLE RCP and . . . ." In addition to this plant-specific justification, this deviation is being addressed as TSTF-177.
- 28. Condition A of NUREG-1432 LCO 3.4.6 applies when one required RCS loop is inoperable and two SDC trains are inoperable. He Bases for Action A.1 of NUREG-1432 LCO 3.4.6 state: "If only one required RCS loop or SDC train is OPERABLE and in operation, redundancy for heat removal is lost." The discussion in the NUREG 1432 Bases is inconsistent with the Condition.
Action A.1 of NUREG-1432 LCO 3.4.6 only applies when one RCS loop and two SDC trains are CALVERT CLIFFS- UNITS 1 & 2 3.4-3 Revision 5
- 2. The Markups of CTS LCO 3.2.5.d for ITS 3.4.1 have beer, revised to indicate that the requirements regarding Axial Shape Index are discussed in the DOC for Specifications 3.2.5. As a result of this change, DOC A.2 for ITS 3.4.1 was climinated. This change was requested by the NRC (ITS 3.4.1 Comment 4).
Spu4c/rsa 3 4./ 1 RFAcme cmuur us reg (Ac.y 3.4 ! u0 t in _ _ -r gg 3,4,1 3/4.2.5 Dua D*omrrree g,c g P, usa, LM.<c3 e*A And N " j
"b Sl 'hjN_ ^ ^^
LINITING CONDITION FOR OPERATION ' Lco 3 4.1 4ro,4 The following DNB related parameters shall be maintained within the limits shown: i b 4. Cold Leg Temperature s $48'F s (g %c.v u., m ok
- 9. Jr. Pressurizer Pressure 2 2200 psia' g gl . d c.
,' gee Reactor Coolant System Total Flow Rate 2 370.000 g m l
- d. AXIAL SHAPE INDEX, THERMAL POWER as specified in the COLR.
l l APPLICABILITY: MODE 1. A r.9 u o th d 4 g' 4 '.0" g ACTION: With any of the above parameters exceeding its limit. restore the k-arameter to within its limit within 2 hours or reduce THERMAL POWER to ess than 5% of RATED THERMAL POWER-within the next ours. t SURVEILLANCE REQUIREMENTS
*A 2 4 i t j " %, 4rer671 at least once Eachper of 12 thehours.
parameters shall be verified to be within their limits l j in L4d 4 A.2.5.2- The Reactor Coolant System total flow rate shal be detemined to be within its limit by measurement at least once per ' months. 24 I J b 4 Aerb'l'h petr % j Limit not applicable during either a THERMAL POWER ramp increase in excess of 5% of RATED THERMAL POWER per minute or a THERMAL POWER step nerease of greater than 10% of OTED THERMAL POWER. , CALVERT CLIFFS - UNIT 1 -3/4 2 8 Amendment No. 186 i
)
+ [dp ! 0
- 3. S. l pre .C. cg 4. o q g m=-w_ _ -
@h
$$@ _h COLA _ TEM 4,g g,4
~
4/4re POWER DISTRIBUTION LIMITS 34 j 3/4.2.5 - M S.P m RCS A <u e,<, T~ p., .so i e , . 4 Fl. v O. p. (-4 , e R- Nw einu e G o. tm LIMITING CONDITION FOR OPERA 11ex DN G) L . ~ .4 fner5- The following DNB related parameters shall be maintained within the limits shown: l b "p. Cold Leg Temperature s 548'F JEC DhcWt $ c>. f. PressurizerPressure22200psta\
, Q % 3.1 #
- c. Reactor Coolant System Total Flow Rate 2 370,000 p9m "AdojS Q R h
- d. AXIAL $ NAPE INDEX, TWERNAL 900ER as specified in the COLR l
APPLICABILITY: MODE 1. A c l awi Q ACTION: With an of the above parameters exceedin (ts limit, restore the Ac.he'onA paramete- to it in its iimit within 2 hours or re uce THEiiMAt P0wER to i.'ss thar 5% of RATED THERMAL POWER within the next ours. SURVEILLANCE REQUIREMENTS M' ,'h,i,( p 3 4, g, 4,4r6rk at least Each of the once per arameters shall be verified to be within their limits l 12 ours. 4.2.5.2 The Reactor Coolant System total flow rate shall be determined tg
% 54g4 .
be within its limit by measurement at least once per.14' , months. f ~
'_ ,'\
Limit not applicable d: ring eit er THERMAL POWER ramp increase in excess of 5% of RATED TNEP#AL POWER per minute or a THERMAL POWER step increase of greater than 10% of RATED THERMAL POWER. CALVERT CLIFFS - UNIT 2 3/4 2-8 Amendment No. 163
. m __ _ _ _ _ -
DISCUSSION OF CHANGES SECTION 3c4.1 - RCS PRESSURE, TEMPERATURE, AND FLOW (DNB) LIMITS ADMINISTRATIVE CIIANGES A.1 The proposed change will reformat, renumber, and reword the existing"rechnical Specifications, with no change ofintent, to be consistent with NUREG-1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs Improved Technical Specification (ITS) development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each Limiting Condition for Operation (LCO) and to be consistent with NUREG-1432. However, the additional information does not change the intent of the current Technical Specifications. He reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Not used. l TECIINICAL CIIANGES - MORE REST *'ICTIVE
- None
.TECIINICAL CIIANGES - RELOCATIONS None f
4 TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS None TEC11NICAL CIIANGES - LESS RESTRICTIVE L.1 Not used. l L.2 Current Technical Specification 3.2.5 Action requires the unit to reduce power within four hours when the Action cannot be met. Improved Technical Specification Actions B and
- D will allow six hours to reduce power when Actions A and C, respectively, cannot be met.
He two additional hours to reduce power, from four hours to six hours, will allow for a more controlled power redaction (which is a transient in itself), in conjunction with even control of steam generator (SG) heat removal. This change is consistent with NUREG-1432.
- L.3 Current Technical Specification 3.2.5 Surveillance Requirement (SR) 4.2.5.2 requires the RCS total flow rate to be determined within its limit by measurement once per 18 months.
Improved Technical Specification 3.4.1 SR 3.4.1.4 decreases the Surveillance Frequency to
-24 months (consistent with the Calvert Cliffs refueling interval). The RCS flow rate does not normally change much during the fuel cycle; however, changes will be detected by ITS SR 3.4.1.3 which requires the flow to be verified every 12 hours. Reactor Coolant System a outages when the core has been altered, flow will be most likely to change after refu ing which may cause a change in flow resistance. Thus, it is important that this detailed test be CALVERT CLIFFS - UNITS 1 & 2 3.4.1-1 Revision 5
- 3. The NRC requested additionaljustificethn regarding the retention of our current licensing basis values for pressurizer pressure, and RCS cold leg temperature. This justification is provided as JFD 32 to Section 3.4 (ITS 3.4.1 Comments 5 and 6).
u a 4 1 i M
RCS Pressure, Temperature, and FlowhB}* Limits dre 3.4.1 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 RCS Pressure, Temperature, and Flow'{ Departure from Nucleate Bolling (DNB)}4 Limits (3.24hLCO3.4.'1 RCS DNB parnaeters for pressurizer pressure, cold leg temperature limits spec lfied belowsand RCS total flow rate shall be within the
- a. Pressurizer pressure 2 psiaaM:[2??$'~'%
(3.2.C b) ( 'J 2.C D
- b. RCS cold leg temperature ru:;:gp;RTP,u;::n(T)I[ig .
'T :d g-
- e e :5ru
'r h L[70) P and -
[3,7.r,c.)c. I flow rate t Se dj n;=r@ ; !" s !sB APPLICABILITY: MODE 1.
.........................-NOTE---.--------....-.-.......
Pret:urlI:e pressure limit does not apply during: a. 12.Ih b. THERMAL M)WER ramp > 5% RTP per minute; or THERMAL r0WER step > 10% RTP. ACTIONS CONDITION REQUIRED ACTION COMPLETION T!ME A. b A.1 Restore parameter (s) 2 hours g,g Pr/ssfizhwr RC fl eh to within limit. Ithirt.U mi t s. b }C 5 hNE oa o m.tA ___e (:J) B. Required Action and 8.1 Be in MODE 2. 6 hours A associa , h/ Time @l.ed Completion Cindlty , not met. (continued) CEOG STS 3.4-1 Rev 1, 04/07/95
. - . .~ - ._. - - . - - - --
DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM
- 31. De Actions for NUREG 1432 LCO 3.4.1 were modified to reflect the Action requirements of CTS 3.1.5 for RCS cold leg temperature not being within limits. He Action for CTS 3.1.5
- requires the restoration of RCS cold leg temperature to within limits, or Hermal Power be reduced to less than 5% of Rated Thermal Power (i.e., Mode 2). The Action for CTS 3.1.5 is the same regardless of which parameter (i.e., pressurizer p9ssure, RCS flow tate, or RCS cold leg temperature) is out of limits. Thus, Action A of W 3.4.1 provides the requirements for restoration of the parameter, and Action B oflTS 3.4.1 provides the requirements for exiting the mode of applicability in the everit the parameter cannot be restored to within limits within two hours.
- 32. In NUREG-1432 LCOs 3.4.1.a and 3.4.1.b, the limits for pressurizer pressure and RCS cold leg
,- temperature are expressed in ranges. In ITS LCO 3.4.1.aronly a~ minimum limit is estabushed for pressurizer pressure. This limit is consistent with the initial assumption regarding pressurizer pressure in the Calvert Cliffs accident analysis. This limit was approved by the NRC in License Amendment No. 88 to Facility Operating License No.DPR 53 for Unit No.1, and License Amendment No. 61 to Facility Operating License No. DPR-69 for Unit No. 2. In ITS LCO 3.4.1.b, only a maximum limit is established for RCS cold leg temperature. This limit is consistent with the initial assumptions regarding RCS cold leg temperature in the Calvert Cliffs accident analysis. This limit was approved by the NRC in License Amendment No. 39 to Facility Operating License No. DPR 53 for Unit No.1, and License Amendment No. 9 to Facility Operating License No. DPR-69 for Unit No. 2. Thus, these deviations are consistent with the current licensing basis for Calvert Cliffs.
- 33. NUREG-1432 SRs 3.4.6.3,3.4.7.3, and 3.4.8.2 require the verification of the correct breaker alignment and indicated power available to the required pump that is not in operation.
NUREG 1432 SR 3.4.6.3 applies to the RCS and SDC pumps, while NUREG 1432 SRs 3.4.7.3 and 3.4.8.2 only apply to the SDC pumps. Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignments and indicated power availability for the required shutdown cooling pumps and valves that are not in operation. NUREG 1432 SRs 3.4.6.3, 3.4.7.3, and 3.4.8.2 have been modified to reflect the additional requirement to verify the correct breaker alignments and indicated power availability for the required shutdown cooling valves, which is consistent with the Calvert Cliffs current licensing basis. These SRs I were modified by replacing the word " pump" with the words " loop components." The components required to be checked by the SRs will be denoted in the Bases. For the RCS loop, the required component is the RCS pump. For the SDC loop, the re . ired components are the pump and the valves.
- 34. NUREG 1432 SR 3,4.11.4 requires the verification that the PORVs and block valves are capable of being powered by an emergency power supply. This surveillance does not exist in CTS 3/4.4.3. Improved Technical Specification 3.4.11 will not contain a surveillance to verify that the PORVs and block valves are capable of being powered by an emergency power supply.
This is appropriate, because the PORVs and block valves are permanently powered by Class 1E power supplies. Class IE power sources are backed-up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under-voltage condition. The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied by a Class IE power source (e.g., the safety injection systems) do not contain SRs to verify the CALVERT CLIFFS- UNITS 1 & 2 3.4-8 Revision 5
- 4. The Markups of CTS 3.4.9.1 for ITS 3.4.3 have been revised to establish that the LCO limits are being retained in ITS Figures 3.4.3-1 and 3.4.3 2, versus being stated in the LCO. Improved Technical Specifications Surveillance Requirement (SR) SR 3.4.3.1 will invoke these figures and ensure the LCO requirements are met. Discussien of Change A.2 for ITS 3.4.1 has been added tojustify these changes. These changes were required to respond to an NRC comment (ITS 3.4.3 Comment 2).
f I I
SP<dicab 3.4 3 2 O 54 3/4,4 REACTOR CCOLANT SYST W 4,+r4 h RES$URE/ TEMPERATURE LIMITS
.. . t,k aban LIMITING CON 0!TI M FOR OPERATIM UO L41
?.' ? 1 The Reactor Cnolant Systes f:f:H V: :::::r:x " t=nnature
.T.4.3 isurevshili heriimi in acco nee,w n tne imit lines shown7tp g p.' idown crittfality/W
,s i
s -3r4ry-)r. and ). 4.9-vice le6t and Rydros tic test
.during ft .
i N [ ( [a. A maximum heatup f: NA llml}h J Qj% tiaximum Allow e Heatuo Rate RCS Temocrature j , 30 F in any e hoi,r period 70' to 164*F i W 40'F in an one hour period
- 64'F to 256'F 60*F in y one hour period 256'F q,g
- b. A max um cooldown of:
i fia mum Allowable Cooldown Ratt RCS Temperature "F in any one hour period > 270*F O'F in any one hour period Lc o ( 10'F in any one hour period 270*F to 184'F
< 184'F 3 A.1 % A maximum temperature change of 5'F in any one hour period.
pgtg during hydrostatic testing operations above system design pressure. APPLICABILITY: At all times. ACT(ON: With any of the above limits exceeded, restore the temperature
/lcg' (reng/or and pressure to within 1_he limit within 30 minutest perform an ineering evaluation toJdetemine tne errects of tne out-of-11mit7 4Cg' ' f.anamon on tne Tracture touahness properties of the Reactor CoolantF q System: metemine tnat the Reactor Coolant System remains acceptable for continued operations or be in at least NOT STANDBY within the next 6 hours AC O86' , and reduce t M "f? T and pressure to less than F*r
- 300 psia, O ret;;dinly,wlthin,Iefollowing30 hours. '
p-- wW.a 12, LD \ A . _ _ _ _ _ . L.\ dooJeb A Alors: g
$>p' rec) Ac-ly., A.2 s k,l\
b ump /clec)<4voum 4k*1 Yh it earfered. p - l CALVERT CLIFFS - UNIT 1 3/4 4-28 Amendment No. 188 l
Sps.Ec h os 3,4,-3 4 /' ' "' ' **^* !^^' ^2" !Y:7-"
'v " ' W SURVEILLMCE REQUIREMENTS Fiqur.> 3M,3-1 3, 5/, y_- S N ' ' ?.:.1 The Reactor Coolant Sy em temperature and pressure shall be 3.4,g,\ determined to be within the limits at least once per 30 minutes during system heatu operations, p, cooldown, and inservice leak and hydrostatic testing f4.4.9.1.2 he reactor vessel materls Irradianon surveillance speci shall b emoved and examined, to d ruine changes in material prop- tes.
L _; - as re red by 10 CFR Part 50 Ap di': H. The results of these L.h S -ry Jek. exa nations shall be used to u ate figures 3.4.9 1 and 3.4.9 . g CALVERT Cliffs - UNIT 1 3/4 4 29 Amendment No.188 l
. . . - - . . --- - . . - - . - -- _-. . - - . - . ~ . - . . - . .-
3p
- t P. c E 4 .o m 7. 4. 3 A.
14 -9/4rt EACTOR C00LAlff.$Y${E
'3. 4 '5 s/4.,.ibentssuntiTruprannint tiniTs M_
LIMITING CONDITION FOR OptRATION f 3.* 3 ,MhThe Reactor .han he blent Syst%m- na - m' " m--- - n'ne "Q(* o e hand to t t (hI . 2.
"d . A maximum heatup of yM.h l'm,'
c.e.d. coollcw m6 j Maximus Allevable Heatuo Rate R*$ Temocratutt 30'F in any one hour period 70'F to 156'F a 40'F in any one hcur period 60'F in any one hour period
> 156'F to 246*F
> 246'T
' h/
- b. A maximum cooldown oft pianimum Allowable Cooldown Rate RCS Temperature 100'F in any one hour period > 200'F 40'F in any one hour period 200'T to 176'F 4
~
15'F in any one hour. Deriod < tser L C. C , p.' A maximum temperature change of 5'F in any one hour period. ! 3.4.3 during hydrostatic testing operations above system design NO7 E pressure. APPLICABILITY: At all times. cwad With any of the above limits exceeded. restore the temperature A.I nd or pressure to within the limit within 30 minutest perform an (engineering evaluat_1on to ninne une siirm owne un-m-omuA
/lenid -
ndflon on Ine Tract ouchness oronerties afthe Reactor Cooldtf g'g 44 p_;fdetermine that tne Reactor Coolant Systein remains acceptable for tun ' nued operations or be in at least NOT STAN08Y within the next 6 hours fgcow - and reduce the and pressure to less than 20 F M 300 psia. A res m i t h , w thin e foll n 30 hours em3 O k o x c
,..i..., A w m e.
69 r ..J Ac4.o* A.2 s%: ___
*g
%C r >~ pt 4-d w L, ~ ~ e R4 erahr C o 4 , 4 . ., .' 4 Qp: _ POT ACUou c CALVERT CLIFFS - UNI 4-28 Amendment No,'178 Co (* Cb 1
Ipecif'.eno,m 3. 4 . 3 3/4:t--t2ACTet-t00 TANT-SYSTDt f -s C SURVEILLANCE REQUIREMENTS $9v(*4_ 3 'IO~f 6 3'* SR - A.1
-41479 tid The Reactor Coolant Sys temperature and pressure shall be 3.4.3. I detemined to be within the limits t least once per 30 minutes during system heatu operations. p. cooldown, and inservice leak and hydrostatic testing I .4.9.1.2 4 he reactor vessel erial irradiation e111ance specimen l shall ved and examine to detemine chang in mater 1P1 proper es. '
as ired by 10 CFR Part . Appendix H. The suits of these b' e nations shall be us to update Figures .4.91 and 3.4.9 2 7 j i a 1 i CALVERT CLIFFS - UNIT 2 3/4 4-29 Amendment No. 165 l j e pose 3 oF 5
DISCUSSION OF CIIANGES SECTION 3.4.3 - RCS PRESSURE AND TEMPERATURE LIMITS ADMINISTRATIVE CilANGES 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 Clifts ITS development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional information does not change the intent of the CTS. 'Ihe reformatting, renumbering, and rewording process involves no technical changes
- to existing Specifications. '
A.2 Current Technical Specification LCO 3.4.9.1 requires the RCS temperature and pressure to be within the limits shown on Figures 3.4.9-1 and 3.4.9-2 during heatup, cooldown, criticality, and inservice leak and hydrostatic testing, and the Figures list the maximum heatup and cooldown rates. Current Technical Specification SR 4.4.9.1.1 requires the RCS temperature and pressure to be determined to be within limits during system heatup, cooldown, and inservice leak and hydrostatic testing operations. Improved Technical Specification LCO 3.4.3 requires RCS pressure, RCS temperature, and RCS heatup and cooldown rates to be maintained within limits, and ITS SR 3.4.3.1 requires the verification that the RCS pressure, RCS temperature, and RCS heatup and cooldown rates are within the limits specified in Figures 3.4.31 and 3.4.3 2. Current Technical Specification LCO 3.4.9.1 is being revised to simply require the RCS pressure, RCS Temperature, and RCS heatup and cooldown rates to be within limits. Thelimits will be defined in two figures. Current Technical Specification Figures 3.4.91 and 3.4.9-2 contain the RCS pressure, RCS temperature, and RCS heatup and cooldown rates. These Figures are being incorporated into the ITS as Figures 3.4.3 1 and 3.4.3 2. Current Technical Specification SR 4.4.9.1.1 is being revised to invoke these figures. These proposed changes are presentation changes only. They do not involve any technical changes to the RCS press'.tre, RCS temperature, or RCS heatup and cooldown rates. This method of presentation is consistent with the NUMARC Writer's Guide for the Restructured Technical Specifications, NUMARC 93 03. Section 4.1.4.b of the Writer's Guide states: " Typically, LCOs which require more than one parameter limit be met will only refer to the parameters as required to be within limits . . .." Section 4.1.7.b states: "Surveillances on parameter limits will specify, to the extent practical, the limit. This applies whether or not the LCO also requires the precise limit. Reference to where the limit (s) may be located is an acceptable alternative . . .." -IECIINICAL CHANGES - MORE RESTRICTIVE M.I Current Technical Specification 3.4.9.1 Actions are not required to be completed if the LCO is restored prior to expiration of the required time intervals (CTS 3.0.2 and ITS 3.0.2). Improved Technical Specification 3.4.3 adds a Note which requires completion of the evaluation to determine if the RCS remains acceptable for continued operation (which is an exception to ITS 3.0.2). This change is acceptable because it is reasonable to ensure that the RCS remains acceptable for continued operation following an excursion outside the allowable P/r limits. Restoration alone it insufficient because higher than analyzed stresses may have occurred and may have affected the reactor coolant pressure boundary integrity. CALVERT CLIFFS - UNITS 1 & 2 3.4.3- 1 Revision 5
- 5. He improved Standard Technical Specifications (ISTS) Bases markup for ITS 3.4.3 has been revised by deleting the following plant specific statement: "llowever, as a practical matter, it is not possible to violate the LCO when the reactor vessel head is removed or all reactor vessel head studs are removed." Additionally, JFD 5 to Bases Section 3.4 has been eliminated. This change was made to respond to an internal question.
4 ) 1 4 4
RCSP/TLimits B 3.4.3 BASES
- c. The existences, sizes, and orientations of flaws in the vessel material.
APPLICABILITY The RCS P/T limits Specification provides a definition of acceptable operation for prevention of nonductile failure in accordance with 10 CFR Part 50, Appendix G (Ref. 1). Although the P/T limits were developed to provide guidance for operation during heatup or cooldown (MODES 3, 4, and 5} or ISLH testing, their Applicability is at all times in l keeping with the concern for nonductile failure. The limits f do not apply to the pressurizer, i l During MODES 1 and 2, other Technical Specifications provide l limits for operation that can be more restrictive than or can supplement these_ P/T limits. LC0 3.4.1, "RCS Pressure. Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits;" LC0 3.4.2, "RCS Minimum Temperature for Criticality;" and Safety Limit 2.1, " Safety Limits," also provide operational restrictions for pressure and temperature and maximum pressure. Furthermore, MODES 1 and 2_are above the temperature range of concern for nonductile failure, and stress analyses have been performed for normal maneuvering profiles, such as power ascension or descent. The actions of this LCO consider the premise that a violation of the limits occurred during normal plant maneuvering. Severe violations caused by abnormal transients, at times accompanied by equipment failures, may also require additional actions from emergency operating _procedurt1. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.3-5 Revision /ig
i
\
RCS P/T Limits B 3.4.3 ! BASES LCO
- c. The existences, sizes (continued) the veesel material. , and crientations of flaws in APPL.!CABILITY The RCS P/T limits Specification provides a definition of acceptable operation for prevention of nonductile failure in m the P/T limits were developed to provide guidance M) foraccordance 4
operation during heatup or cooldown (MODES 3, 4, and 5) or j g with the concern for nonductile failure.ISLH testing, their Appitcability s l is apply to the pressurizer. The limits do not During H0 DES 1 and 2, other Technical Specifications provide limits for operation that can be more restrictive than or can supplement these P/T limits. LC0 3.4.1, 'RCS Pressure, . Temperature, and Flow Departure from Hucleate Boiling (DNB) ' Limits' LC0 3.4.2, 'RCS Minimum Temperature for Critical'ity' - and Safety Limit 2.1,
- Safety I provide opera;tional restrictions for pressureinitsand
" also temperature and maximum pressure. Furthermore MODES 1 and 2 are above the temperature range of concer,n for nonductile failure, and stress analyses have been performed for normal maneuvering profiles, such as power ascension or descent.
The actions of this LCO consider the premise that a violation of the limits occurred during normal plant maneuvering. Severe violations caused by abnonnal also require additional actions from emergency operatingtran procedures. ACTIONS A.1 and A.2 Operation outside the P/T limits must be corrected so that thestress by RCPB is returned to a condition that has been verified analyses. The 30 minute Completion Time reflects the urgency of restoring the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a controlled manner. (continued) CEOG STS B 3.4-12 Rev 1, 04/07/95
4 DISCUSSION OF BASES DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM PLANT-SPECIFIC CHANGES
! 1. This change incorporates Calvert Cliffs specific numbers into brackets. Bracketed information located throughout NUREG 1432 will be replaced with the specific Calvert Clifts numbers,
- 2. his change to the Improved Technical Specification (ITS) Bases incorporates changes made to the ITS. Als change ensures consistency between the ITS and ITS Bases.
- 3. Calvert Cliffs has an Updated Final Safety Analysis Report, therefore, "FSAR" will be changed to "UFSAR"throughout the ITS Bases.
- 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.
4
- 5. Not used.
l
- 6. 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.
- 7. The Limiting Condition for Operation phrase, in the Limiting Condition for Operation section of Specification 3.4.6 Bases, which states that natural circulation is established using the steam generators during the time that no forced flow exists for the s I hour per 8 hours, is being deleted. Natural circulation can not be assured because the pressurized heaters are not required to be Operable in Mode 4. This change is consistent with Calvert Cliffs' design.
i
- 8. Bases for new Specification 3.4.17 ["Special Test Exception (STE) RCS Loops - MODE 4"]
were added to Section 3.4 Bases consistent with the Technical Specifications.
- 9. This statement in the Section 3.4.9 Bases, Applicable Safety Analyses Section, is not true for Calvert Cliffs. There are safety analyses at Calvert Cliffs that are initiated in Mode 3 and below.
Therefore, this statement is being deleted since it not consistent with the Calvert Cliffs licensing basis.
- 10. The safety analyses described or listed are inconsistent with Calvert Cliffs analyses, therefore,
- they were modified as required to be consistent with Calvert Cliffs.
- 11. This wording was deleted from the Bases or changed to be consistent with the Calvert Cliffs design, analyses, procedures, or operations.
- 12. Specification 3.4.12 Bases, Applicable Safety Analyses Section, list of mass input transients were modified to be consistent with Calvert Cliffs analyses.
- 13. Additional wording was added to this Bases Section for clarification. These additional words are consistent with Calvert Cliffs analyses, procedures, or Operations.
- 14. The Calvert Cliffs steam generator tube rupture analysis does not assume the reactor trip at the same time as the steam generator tube rupture. Thus, if the reactor is not tripped it can be i CALVERT CLIFFS- UNITS 1 & 2 3.4-1 Revision 5 3
. . - .- . ...... - - - -- ~ _-. - . .. - .-. .. . . .- . - .- ~-_...~. - . - . - - .-,- - .... -.--. - -
IE 6.- The wording provided in the ISTS markup of the Bases for ITS LCO 3.4.5 was changed to match the wording in ITS LCO 3.4.5. Additionally, a plant specific justification (JFD 27 to Bases-Section 3.4) was provHed, rather than relying upon Technical Specification Task Force (TSTF) 177 (CEOG 83) as thejustification for changes to the Bases for ISTS LCO 3.4.5 Bases.. These changes have been made to respond to an NRC comment (ITS 3.4.5 Bases comment). t i 1 4 i i .n 4 i i i il ' l i :. I 3 L 4
_ ~. - - . . - - _ .. -
. - - - - . . - ~ ~ . .
4 0 J RCS Loops-MODES 3 8 3.4.5 BASES (continued) LC0 h The purpose of this LC0 is to require twof lacps to be available for heat removal thus provi ing undancy. The LCO requircs thebttwc}^1oop,s to be OPERAB of requirt both SGs to be capable with the intent transferrin k nd rate. Fore heat from the reactor o co(>lant at a controlledwater l op e, tab. en ',' transport heat reactor coolant flow is the requimd way to adequate remova,l.although natural circulation flow provides Mb A A alntmum of one runnin LCO requirement for one loop in operat1on.g RCP seets the S D Th Not
,j, ec .
permits a limited period of operation without RCPs. All RCPs mahBFWr.-Wnm_!Mb for s 1 hour per 8 hour part h When in natural circulation, a reduction in boronIhn < ej d 2means b.n that natura pn t 6 ,, concentration distribution throughout is prohibited because tts RCS cannot an even concentration ? praat b te ensured. Core outlet temperature is to be maintained at least 10'F below e'l kg g pu l the saturattun temperature so that no vapor bubble may foru wT '
, and possibly cause a nattral circulation flow obstruction.
In MODES 3, 4, and 5, it is sometimes necessary to stop all RCPs or shutdown cooling (500) pump forced circulation (e.g., to change operation from one SDC train to the other, to perform surveillance or startup testing to perform the transition to and from SDC System cooling,,or to avoid operation below the RCP minimum net positive suction head limit). The time period is acceptable because natural and circulation is adequate for heat removaleer. the retctor Il coolant temperature can be maintained subcooled M i...
,, . ' ~ ; ... " -'!*p-eeact hi b a.^.. . : . . . . . ,,a . patr" um88 , @
An_ OPERABLE gasenc sists of at least one @ RTJPm now for heat transtsorb and an SG t at t OPERABLE in
'th 4
i accorcance with tne Steam Generator Tube Survei Program. ance An RCP is OPERABLE if it is capable of being powered and is able to provide forced flow if required. ofE M GCE ' i 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. Operatic 1 in other MODES is covered by: (continued) CEOG STS B 3.4-22 Rev 1, 04/07/95 4
plSCUSSION OF BASES DEVIATIONS FROM NUREG 1432 SEC110N 3.4 - REACTOR COOLANT SYSTEM 23. Calvert Cliffs is not committed to the General Design Criteria in 10 CFR Part 50 Appendix At Calvert Cliffs is committed to the draft General Design Criteria. Herefore, the Criteria in the draft General Design Criteria, where applicable, were referenced in the Technical Spwification Bases. 24. Bases statements which refer to the CFR 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 Saruy Analysis Report. Plant specific acceptance criteria for Calvert Cliffs are approved by the Nuclear Regulatory Commission and stated in the Updated Final Safety i Analysis Report. %e CFR contains the maximum allowable limits, not plant specific limits which are typleally 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. l 25. NUREO 1432 B 3.4.12 SR 3.4.12.1 Section allows an alternate method of LTOP control to be employed using at least two independent means to prevent injection into the RCS such that a single failure or single action will not result in an injection into the RCS. It allows this to be accomplished through the pump control switch being placed in pull to lock and at least one valve ' in the discharge flow path being closed improved Technical Specification SR 3.4.12.1 Hases will allow verification that the llPSI pumps will not inject into the RCS by verifying their - discharge valves are locked shut. This change is consistent with the Calvert Cliffs design and current licensing basis. 26, The Actions for NUREG 1432 LCO 3.4.1 were modified to reflect the Action requirements of CTS 3.1.5 for RCS cold leg temperature not being within limits %e Action for CTS 3.1.5 requires the restoration of RCS cold leg temperature to within limitt, or Thennal Power be reduced to less than 5% of Rated %ennal Power (i.e., Mok 2). He Action for CTS 3.1.5 is the i.ame regardless of which parameter (l.c., pressurize; pressure, RCS flow rate, or RCS cold leg temperature) is out of limits. %us, Action A of ITS 3.4.1 provides the requirements for j restoration of the parameter, and Action D ofITS 3.4.1 provides thu requ;rements for exiting the mode of applicability in the event the parameter cannot be restored to witLh limits within two { ' hours. 27 The Bases for NUREG 1432 LCO 3.4.5 state, "An OPERABLE loop consists of at least one RCP providing forced flow for heat transfer and . . , ." This statement is not consistent with the requirements of NUREO 1432 LCO 3.4.5. NUREG 1432 LCO 3.4.5 requires (two; RCS loops to be OPERABLE and one RCS loop to be in operation. The LCO only requires one loop to bc { providing forced circulation; the second loop or..y needs to be capable of providing forced circulation. Improved Technical Specification LCO 3.4.5 requires two RCS loops to be Operable and one RCS loop to be in operation.- This is consistent with CTS LCO 3,4.1.2, Thus, the Bases for ITS LCO 3.4.5 have been revised to state, "An OPERABLE RCS loop consists of at least one OPERABLE RCP and ...." In addition to this plant specific justification, this deviation is being addressed as TSTF 177, 28. Condition A of NUREG 1432 LCO 3.4.6 applies when one required RCS loop is inoperable and two SDC trains are inoperable. The Bases for Action A.1 of NUREG 1432 LCO 3.4.6 state: "If only one required RCS loop or SDC train is OPERABLE and in operation, redundancy for heat aemoval is lost." The discussion in the NUREG 1432 Dases is inconsistent with the Condition. Action A.1 of NUREG 1432 LCO 3.4.6 only applies when one RCS loop and two SDC trains are CALVERT CLIFFS-UNITS I & 2 3.4 3 Revision 5
i l l
- 7. DOC LA.1 for ITS 3.4.5 was revised to State that the specific loop numbers and number of
; required RCPs per loop are being moved to the liases. The ISTS markup of the liases for !!S 3.4.5 was revised to include the required information. These changes have beel made to respond to en NRC comment (ITS 3.4.5 Comment 1).
4 i J d i 1 4 4 l i d ? e 1 a 4 1 4
RCS Loops - H0DE 3 8 3.4.5 8 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.5 RCS Loops - H0DE 3 BASES BACKGROUND The primary function of the reactor coolant in MODE 3 is removal of decay heat and transfer of this heat, via the
~
steamgenerators-(SGs),tothesecondaryplantfluid. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. In MODE 3 reactor coolant pumps (RCPs) are used to provide forced circulation heat removal during heatup and cooldown. The MODE 3 decay heat removal requirements are low enough that a single RCS loop with one RCP is sufficient to remove core decay heat. However, two RCS loops (i.e., RCS loop Nos. I and 12 for Unit No. I and RCS loop Nos. 21 and 22 for 5 Unit No. 2) are required to be OPERABLE to provide redundant paths for decay heat removal. Only one RCP needs to be OPERABLE to declare the associated RCS loop OPERABLE. Reactor coolant natural circulation is not normally used but is sufficient for core cooling. However, natural l circulation does not provide turbulent flow conditions.
-Therefore, boron reduction in natural circulation is prohibited because mixing to obtain a homogeneous concentration in all portions of the RCS cannot be ensured.
APPLICABl.E Fuilure to provide heat removal may result in challenges to SAFETY ANALVSES a fission product barrier. The RCS loops are part of the primary success path that functions or actuates to prevent or mitigate a Design Basis Accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. I CALVERT CLIFFS - UNITS 1 & 2 B 3.4.5-1 Revision Es
DISCUSSION OF CHANGES SECTION 3.4.5 - HCS LOOPS . MODE 3 M.2 Current Technical Specification LCO 3.4.1.2.b footnote
- allows all RCP: to be de energized for up to one hour improved Technical Specification 3.4.5 LCO Note 1 allows all the RCPs to be de-energized for up to one hour per eight hour period. Herefore, the amount of time all RCPs may be de energized has been restricted from less than or equal to one hour, to less than or equal to one hour per eight period. Current Technical Specifications permit repeated application of the one hour exemption, indefinitely. His additional restriction on plant operations restricts immediate, repeated application of the one hour allowance, which would circumvent the intent of the Note. Placing a limitation on the de-emgization of all the RCPs will not adversely affect plant safety. Placing additional restrictions on plant operation constitutes a more restrictive change. His change is consistent with NUREO.1432.
.2 -4m.
M.3 Improved Technical Specification SR 3.4.5.2 is an added Surveillance which requires the verification of secondary side water level in each SO once per 12 hours. His Surveillance is required to verify adequate SO water level in order to have a heat sink for removal of the core decay heat from the reactor coolant. He Frequency has been shown by operating practice to be sufHcient to regularly assess degradation and verify operation within the safety analyses assumptions. This change will not adversely affect plant safety because it ensures an adequate heat sink is available for the removal of decay heat. %e addition of this SR constitutes a more restrictive change. This change is consistent with NUREO 1432. TECilNICAL CilANGES - RELOCATIONS None TECIINICAL CilANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.I Current Technical Specification 3.4.1.2 LCO lists the loop numbers required to be Operable and requires that at least one RCP be Operable, improved Technical Specification 3.4.5 LCO will require two reactor coolant loops to be Operable. The specific loop numbers and number of required RCPs per loop is being moved to the Bases of Section 3.4.5. This is acceptable because moving this requirement to the Bases will not affect the requirement for the loop consisting of at least one RCP per loop to be Operable. Throughout the ITS, the Bases usually describes the contents of the system and the specific requirements of the system contents. This information 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 efTective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement for two reactor coolant loops. This l change is a less restrictive movement ofinformation change with no impact on safety. This change is consistent with NUREO.1432. LA.2 Current Technical Specification SR 4.4,l.2.2 requires the reactor coolant loops to be verified in operation and circulating reactor coolant. Improved Technical Specification SR 3.4.5.1 will require the reactor coolant loops to be verified in operation, The requirement that the reactor coolant loops be verified to be circulating reactor coolant is being moved to the Bases of Section 3.4.5 His is acceptable because moving this requirement to the Bases will CALVERT CLIFFS - UNITS 1 & 2 3.4.5 2 Revision 5
4 i RCS Loops-M00C 3
,,B,3.4.5 B 3.4 Rt. ACTOR C00LAN1 SYST[M (RCS)
B 3.4.5 RCS Loops -MODE 3 BA$t$ ' BACKGROUND The primary function of the reactor coolant in MODE 3 is removal of decay heat and transfer of this heat via the steam generators to the secondary plant fluid. The secondary function of (SGs)Ihe reactor coolant is to act as 4
" carrier for soluble neutron poison, borte acid. w i
in MODE 3. reactor coolant pumps are used to provide
. forced circulation heat removal ringdu(RCPs)heatup and cooldown.
( 6 A. N !00f' The MODE 3 decay heat removal requirements are low enough d5 ll *^f 4 for- that a single RCS loop with one RCP is sufficient to remove i i V'"1 )lo, I o^j core decay heat. HoweverMtwot4RC$docchare required to be OPERABLE to provide reduncant paths for decay heat h, 8C.5 loop g8 removal. Only one RCP needs to be OPERABLE to declare the ' associated RCS loop OPCRABLE. i l S^ Reactor coolant natural circulation is not normally used but g^l4 No.7 D is sufficient for cora coolin However natural t circulation does not provide fu.rbulent flow conditions. u Therefore, boron reduction in natural circulation is prohibited because mixing to obtain a homogeneous concentration in all portions of the RCS cannot be ensured. ~ APPLICABLE rAnal s have shown the
$AFETY ANALYSES MO e rod withdraya'l event from /'
with one RCS 1 in operation g bounded by thy tod y drawal intilate rom MODE f. - Failure to provide heat removal may result in challenges to a fission product barrier. The RCS loops are part of the , primary success path that functions or actuates to prevent or mitigate a Design Basis Accident or transtent that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. RCS Loops-MODE 3 satisfy Criterion 3 of the NRC Policy Statement. (continued) CEOG SIR B 3.4 21 Rev 1, 04/07/95 1
- 8. Ncie of CTS 3.4.1.2 has been revised in the CTS markups for ITS 3.4.5 to denote that "a reactor coolant pump shall not be started with any itCS cold leg temperature less than or equal to
[the LTOP enable temperature) unless . . . " Currently, this Note simply refers to "the itCS temperature." This change provides consistency with a change made in the maikups ofl'ootnote
* *
- of CTS 3.4.1.3 for ITS 3.4.6. Tojustify the change, DOC A 3 for ITS 3.4.5 was added. This change was inade to respond to an NitC comment (ITS 3.4.5 Comment 2).
Sf<s' icd a 3.4. 7 i l 34 444-AEACf04.C00LANT_lYSTEh , g og- 3 3,4,g 4/4d t ' !^^L'M '.^^M = ^ooi.mitiefudmn' -~-~ N LIMITING CONetTION FOR OPERATION 3 5 3 1 1.3 07 setor coolant loops 4444+d-below shall be OPERABL
. + wmrest r coolant On m ,e pump. 1...m.....ma w . _ m:
- 2. actor Coolar.t Loop sociated; nclor coolanLou.n_$ nd at least once t ob ::: 7;; der ;;;te;A 1;;p; shall APPLICABillJlt MODE 3 .
0 l Acil0N:
^$d % / With less than the above required reactor coolant loops OPERABLE, N restore the required loops to OPERABLE status within 72 hours or uE,4 Hbe in NOT $11UT00WN within the next 12 hours. :
l' Am o % With no reactor coolant loop in operation suspend all operations g involving a reduction in boron concentration of the Reactor Coolant System and initiate corrective action to return the required loop to operation "t" r- h=.
. '\,)
g p;s p, a. e.<>.s n All reactor coolant umps may be de energized for up to I hour up to UO 2 hours for low flow test) provided (1) no operations are permitted NOTE t that would c#e a di ten of the Reactor Coolant System boron concentration, and (2) core outlet-temperature is maintained at least l.
~
10'F below saturation temperature. g gg b A reactor coolant pump shall not be started with @ RCS temperature
'" less than or equal to 365'F unless (1) the pressurizer water level is l s
l' }W L less than or equal to 170 inches, and (2) the secondary water l temperature of each steam generator is less than or equal to 30*F above the RCS temperature, and (3) the pressurizer pressure is less than or equal to 300 psia, , CALVERT CLIFFS . llNIT 1 3/4 4 2 Amendment No. 185 ; I pa y hf ?- l
$ pas.I.e m be 3 i. 5
~3. +
3,4, S 4/44 REACTOR C00LAlff.SYSTEN 3/4.4.1 .t00mf Ian*s an m m eiacu trae!_ { w
]g'g-409-STAN00V, LIMITING CONDITION FOR OPERAT!0N N[5 " ** ***'r * " '*"t actor Coola 1 "
- t " * *h*ll 6' '"^* F N 00p #21 a t least.one ociated ' "
b
/ reactor c nt p g ,- Ea bb*
k A,, y 0" M b , 22 and at le or.e associ (.5 1 gne ef * : .".:::t;r C;;1=t L::;: shall be i APPLICABILITY: MODE f*' EU.958 k ,A . . Ith less s OPERABLE, Ac^ti o N store thethan theloops required above required reactor to OPERABLE coolant status within 100h2 hours or g {beinNOTSHUTDOWNwithinthenext12 hours. ACNt4 % With no reactor coolant loop in operation, suspend all operations C, involving a reduction in boron concentration of the Reactor Coolant System and initiate corrective action to return the required loop to operation withi our. l A$e - i
- t. . _
LC O # All reactor coolant umps may be de.ener (JOTE I 2 hours for low flow test) provided (1) gized for no operations areup to 1 hourdup permitted to that would cause ti;i41m of the Reactor Coolant System boron concentration, and (2) core outlet temperature is maintained at least 10'F below saturation temperature. A reactor coolant pump shall not be started with
% e, ,
g t,c, o RCS emperature mE 2 less less than thanoror equal equal to inches, to 170 301'T unless (1)(the $ressurizec water level is l and 2)tesecondarywater temperature of each steam generator is less than or equal to 30'F above the RCS temperature, and (3) the pressurizer pressure is less than or equal to 320 psia. CALVERT CLIFFS . UNIT 2 3/4 4 2 Amendment No. 178 O
DISCUSSION OF CIIANGES SECTION 3.4.5 RCS LOOPS . MODE 3 ADMINISTRATIVE CilANGES A.1 ne proposed change will refonnat, renumber, and reword the existing Technical Specifications, with no change ofintent, to be consistent with NUREO 14*>2. 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, cedain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREO 1432. Ilowever, the additional information does not change the intent of the l current Technical Specifications, ne reformatting, renumbering, and rewording process l involv6s no technical changes to existing Specifications. A.2 Current Technical Specification LCO 3.4.1.2.b footnote
- discusses the requirements which allow all RCPs to be de energized for a period of time. One requirement is that no operations be permitted that would cause dilution of the boron concentration. Improved Technical Specification LCO 3.4.5 LCO Note 1 changes the word "dllution" to " reduction."
Both words are used in the same context; reducing boron concentration is ~ unacceptable. . His wording change is solely for consistency with NUREG 1432. Word changes made to be consistent with NUREG 1432 constitute an administrative change. A.3 The Applicabilities for CTS LCOs 3.4.1.2 are modified by Footnotes ". For Unit No.1, Footnote " states,"A reactor coolant pump shall not be started with the RCS temperature less than or equal to 365'F unless . . .." For Unit No. 2, Footnote " states, "A reactor coolant pump shall not be staded with the RCS temperature less than or equal to 301*F unless . . .." Note 2 ofITS LCO 3.4.5 states "No RCP shall be started with any RCS cold leg temperature s 365'F (Unit 1) s 30l'F (Unit 2) unless. . .." Footnotes " for CTS , LCOs 3.4.1.2 have been modified to state,"A reactor coolant pump shall not be started with any RCS cold leg temperature less than or equal to. . .." These proposed changes are consistent with Calvert Clif1's current interpretation of the CTS Footnotes; RCS cold leg temperatures are monitored to ensure compliance with the requirements of the Footnotes, These proposed changes are administrative comments; they are consistent with the current interpretations of Footnotes " of CTS LCOs 3.4.1.2. no ITS limit will ensure a reactor coolant pump is not started when overpressure protection is being provided by the low temperature overpressure protection system and the established prerequisites regarding pressurizcr water level, secondary water temperature, and pressurizer pressure are not met. This ensures the plants will be operated in accordance with the existing design bases. TEC11NICAL CilANGES - MORE RESTRICTIVE M.1 Current Technical Specification 3.4.1,2 Action b requires the initiation of corrective action within one hour to return a loop to operation when no loop is in operation. Improved Technical Specification 3.4.5 Action C will require immediate initiation of corrective action. This change, which requires immediate initiation of corrective action, reficcts the importance of maintaining an RCS loop in operation for decay heat removal. This change will not adversely affect plant safety because it requires immediate action to restore decay heat
- removal capability. The addition of this more stringent requirement constitutes a more restrictive change. This change is consistent with NUREO 1432, CALVERT CLIFFS - UNITS 1 & 2 3.4.5-1 Revision 5 i . - , - . , - _ . - _ . . _ - - . . , . _ - . . . - - - - - , . . - , . _ - . , _ , _ - . - . , , , , _ __..,_.m, -..m _ - - , , . . - - . , .
- 9. The ISTS markups for Note 1.b for ITS LCOs 3.4.5,3.4.6, and 3.4.7 were revised to climinate a generic editorial change. 'Ihe phrase "210'F below saturation temperature" was changed to "at least 10*F below saturation temperature." Additionally, the ISTS markup for Note 1.b of ITS LCO 3.4.8 and its corresponding Ilases were revised to be consistent with similar notes for ITS LCOs 3.4.5, 3.4.6, and 3.4.7. 'this phrase is consistent with the current footnotes in CTS LCOs 3.4.1.2 and 3.4.1.3. These changes were made to respond to several NitC comments (ITS 3.4.5 Comment 3, ITS 3.4.6 Comment 2, and ITS 3.4.7 Comment 5).
RCS Leops . H0DE 3 l 3.4.5 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.5 RCS Loops - N0DE 3 LCO 3.4.5 Two RCS loops shall be OPERABLE and one RCS loop shall be in operation. 1
..........................- N0TES............................
- 1. All reactor coolant pumps (RCPs) may be not in operation 6
.for s 1 hour per 8 hour period and s 2 hours per 8 hour period for low flow testing, provided:
- a. No operations are permitted that would cause reduction of the RCS boron concentrations and
- b. Core outlet temperature is maintained at least 10*F 5 3 below saturation temperature.
- 2. No RCP shall be started with any RCS cold leg temperature s 365'F (Unit 1), s 301'F (Unit 2) unless:
- a. The pressurizer water level is s 170 inches
- b. The pressuriter pressure is s 300 psia (Unit 1),
s 320 psia (Unit 2); and
- c. The secondary water temperature of each steam ,
generator is s 30'F above the RCS temperature. ' APPLICABILITY: MODE 3. CALVERT CLIFFS . UNITS 1 & 2 3.4.5-1 Revisiongf
i-RCS Loops - MODE 4 3.4.6 ~ 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.6 RCS Loops . MODE 4 F LCO 3.4.6 Two loops consisting of any combination of RCS loops and } shutdown cooling (SDC) loops shall be OPERABLE and at least 1 i one loop shall be in operation. ]
- 1
- ...........................N0TES.-..-......--...............
4 e .
- 1. All reactor coolant pumps (RCPs) and SDC pumps may be 6 :
I not in operation for s 1 hour per 8 hour period, ;
- provided
- '
, a. No operations are permitted that would cause ; reduction of the RCS boron concentration; and 1 i
- b. Core outlet temperature is maintained at least 10'F 6 l ,
below saturation temperature. t , i 2. No RCP shall be started with any RCS cold leg , l temperature s 365'F (Unit 1), s 301'F (Unit 2) unless: I c ! a. Pressurizer water level is s 170 inches a- }
- b. Pressurizer pressure is s 300 psia (Unit 1),
s 320 psia ~(Unit 2); and . c. Secondary side water temperature in each steam j ). generator (SG) is s 30'F above each of the RCS cold ~ j- leg temperatures. ; h i i J
- -APPLICABILITY
- MODE 4.
l- ! l i
- 1. t i
i CALVERT CLIFFS - UNITS 1 & 2- 3.4.6 1 Revisionp'5' - i
,----_..a...._..,..__.- -
..-__...;,,_,..._,__.1,.--,._,,,,,,_._.,_ _u, ., , ,._. -. -. ...a.
RCS Loops . MODE 5. Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4,7 RCS Loops . MODE 5 , Loops Filled LCO 3.4.7 One shutdown cooling (SDC) loop shall be OPERABLE and in
- operation, and either
1
- a. One additional 500 loop shall be OPERABLE; or
- b. The secondary side water level of each steam generator (SG)shallbeh-50 inches.
.........................-. N0TES.-......-...............-...
- 1. The SDC pump of the loop in operation may be not in T operation for s 1 hour per 8 hour period prolided:
- a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is inaintained at least 10'F F below saturation temperature.
- 2. One required SDC loop may be inoperable for up to 2 hours for surveillance testing provided that the other SDC loop is OPERABLE and in operation.
- 3. No reactor _ coolant pump (RCP) shall be started with any RCS cold leg temperature s 365'F (Unit 1), s 301'F (Unit 2)unless:
- a. The pressurizer water level is s 170 inches;
- b. Pressurizer pressure is s 300 psia (Unit 1),
s320 psia (Unit 2);and
- c. The secondary side water temperature in each SG is s 30'F above each of the RCS cold leg temperatures.
- 4. All SDC loops may be not in operation during planned heatup to M0bE 4-when at least-one RCS loop is in operation.
CALVERT CLIFFS .' UNITS 1 & 2 '3.4.7 1 Revision g y
_ . _. _ _~ . _ . _ . _ _ _ _ . _ . - _ . . _ . . _ . _ _ _ _ _ _ _ . _ _ _ i RCS Loops . MODE 5 Loops Not Filled 3.4.8 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.8 RCS Loops - MODE 5, Loops Not filled i LC0 3.4.8 Two shutdown cooling (SDC) loops shall be OPERABLE and one , SDC loop shall be in operation.
...........................NOT65.-......-...................
- 1. All SDC pumps may be not in operation for s 15 minutes fi when switching from one loop to another provided:
- a. The core outlet temperature is maintained at least SF 10'F below saturation temperature;
- b. No operations are permitted that would cause a ,
reduction of the RCS boron concentration;.and 2
- c. No draining operations to further reduce the RCS
, water volume are permitted.
- 2. One SJC loop may be inoperable for s 2 hours for surveillance testing provided the other SDC loop is OPERABLE and in operation,
- APPLICABILITY
- MODE 5 with RCS loops not filled.
s ACTIONS I CONDITION REQUIRED ACTION COMPLETION TIME A. One SDC loop A.1 Initiate action to Immediately-inoperable, restore SDC loop to OPERABLE status. CALVERT CLIFFS . UNITS 1 & 2 3.4.8-1 Revision Adr
RCS Loops - H0DE 5 Loops Not filled D 3.4 8 0 BASES minimum of one running SDC pump meets the LCO requirement for one loop in operation. An additional SDC loop is required to be OPERABLE to meet the single failure criterion. Note 1 permits the SDC pumps to not be in operation for s 15 minutes when switching from one loop to another. The circumstances for stopping both SDC pumps are to be limited to situations when the outage time is short and the core outlet temperature is maintained at least 10'F below f saturation temperature. The Note prohibits boron dilution or draining operations when SDC forced flow is stopped. Note 2 allows one SDC loop to be inoperable for a period of f 2 hours provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are safe and possible. An OPERABLE SDC loop is composed of an OPERABLE SDC pump capable of providing forced flow to an OPERABLE SDC heat exchanger, along with the appropriate flow and temperature instrumentation for control, protection, and indication. Shutdown cooling pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the SDC System. Operation in other MODES is covered by: LCO 3.4.4, "RCS Loops - MODES 1 and 2;" LC0 3.4.5, "RCS Loops - MODE 3;" LC0 3.4.6, "RCS Loops - MODE 4;" LC0 3.4.7, "RCS Loops - MODE 5. Loops filled;" LCO 3.9.4, " Shutdown Cooling (SDC) and Coolant Circulation - High Water Level" (MODE 6); and CALVERT CLIFFS - UNITS 1 & 2 B 3.4.8-2 Revision #5
RC$ uops-MDC 3 3.4.$ 3.4 REACTORCOOLANTsystLN(RCS) 3.4.6 RCS loops-MODE 3 .4,t.hC0 3.4.5 Two)(RCS loo n operation.ps shall be OP[pABLEf;and one RCS loop shall be
-=
.................... . .,0a..4. d< .LLMmJJf/*),", @
pumps sa hallperreactor coolan - for s I hour gj,,, 8 hour period provided:y
#rI
- a. No o trations are peret ed that would cause reddction C of t e RCS boron concen rationi and b.
Core butlet temperatu is saintained at least 10'r
.r* d below saturation. temp
......................... . . . .rature.1.....
. = .
zwett
.................... te,a.ra e, APPLICABILITY: MODE 3. N'" '
ACTIONS
. CONDITION RtQUIRED ACTION COMPLETION TIME A. One required RCS loop A.) Restora reoutred RCS
. inoperable. 72 hours loop to OPERABLE 3A .) .*L, An.. n status.
1 B. Required Action and 8.1 Be in MODE 4. associated Completion It hours A ^*
^"**' Time of Condttion A not met.
(continued) CEOG ST$ 3.4-8 Rev 1. C4/07/95'
) RCS Loops-M000 4 3.4.6 '
3.4 ktACTOR COOLANT SYSTEM (RC$) 3.4.6 RC$ Loops-M00C 4 les J (3. 4.1.h tCO 3.4.6 twoloops::t. c loops and shutdown:coo consistino of an coattratten of RCS and at least one loop gSOCghall shall bebe in operation BLE OPERA h L nof re ... ...... ..
.~...h0 TE $ .-.= g Qf"' 1. All reactor coolant pumps RCPs and 2aa.aneer TNp for g I haur p(er 8) hour erted,pr p$0C pumps 7.5F#* /33 bd@ed:
i a. (33 Nooperationsarep$boronconcentrattoniand redu tion of the R ruitted that would cause a b. Core saturatt outlet to temperature. trature is maintained at least 10'F g ' below 2.
} -g'[
No RCP shall be started with any RC$ cold leg tot Gad O temperature s {44g{'F unless:
,' <W
, D 4, 4.
Pressurtser water level is 4-fy)st.ef hja _g
@W. Secondary side water t generator _ ($G) is *-{ erature in each steam
'F a och of the RCS cold leg temperature
.............................s........ _ G)
Q - .- - - - m e,,,64o g APPLICADILITY: MODE 4. Mrs". b"N U
~~~~~ ~~
ACT10NS CONDITION - . _ - REQUIRIO ACTION COMPLETION TIME 3,9,g 3 A. One required RCS loop
<Ag' ' ' " inoperable, A.1 Initiate action to Innediately restore a second loop E e inir,to OPERABLE g status.
Two $DC inoperable. (continued) CEOG $15 3.4 10 Rev1,04/07/95 1
i RCS Loops-MODt 6. Loops filled (ers) 3.4.7 3.4 RIAC10R C00LANT.SY$1CM (ACS) i 3.4.7 RCS Loops-MODE 8, Leops' Filled i (3.4.1.'3) LCO 3.4.7 One shutdown cooling operation, and either($00) shall be OPCRA8LE and in N.4d'h a. One additional $0C (43rva b. shall be OP[blt or g te 1.4.') The secondary side wateNai'al at _- aach steam generator On L \ ' ($4) thel 6 berusnar e-FORM _- G
... . .. -N0TES------[-Q-- Leleftjunh& fS*W'* /53
- y. s~
- 1. The $0C puest.e(.
qit
.ayerveS for.th(Are4e in amarattan ma/9 f s I hour per 8 hour perloa providets (3.4.13.l'h 6 erations ofarethe ermitted that would cause No o!tton redu Rbh boron concentration; and 1
- b. Core outlet temperature is setntained,at least 10'T below saturati emperature. !
N Ev./ 2. One required $DC m p/1 2h may be (hoperable for up to t,o c. s.. t. or survettlance testing provided that the other 3.
$DC R{ LC and in operation, g g %., , ,
o No reactor co fant pump JRCP) shall be started with M 14M -' '" RCS cold ' eg temp if unlesst Apf"u..%.4 b
- a. The pressuriser water level ~ t.4&(WE er, lhe secondary side water te erature in etc ~
-' ""*"" above each of the CS cold le spe tures.
Q #~#U h St d 4. A C may4. W t A."1 operation during 0't 6. planned In operation.heatup to NODE 4 when at least one RCS loop is b
***'y fpssa's is !
APPLICABILITY: MODE 6 with RCS loops filled. a g CEOG $15 3.4-13 Rev 1, 04/07/95 s
-r -
i RCS Loops-M00t 5. Loops Not filled 3.4.3 3.4 REACTOR C00LMT SYSTEN (RCS) ) 3.4.8 RCS Loops-MODE 5. Lo : Not filled (3.4.i to 3.4.8 Two shutdown coolin f;X 500 han shall be a(oper)ation. te.e shall be opt Lt one (b 1 3* ^0p m, etsukon ysgr )C3
- . . . - - - . ..-.hoTE$ 7 . =:a ht;-
- 1. All 500 umps may -mangna for s l.5 etnutes when 1
" switchin free one to another prov'ded: Ail 3h a. The core out e emperature is maintained
! 6 low saturat on temperaturei b '
- b. No operations are pemitted that would cause a
. reduction of the RC$ boron concentrationi and
- c. No draining operations to further reduce the RCS 1
water volume are peraltted. . NEv/ t. One 500 ma suruemance tes{in,beinoperableforfe rovided the ot 2 hour @
'N .... 5"^'$.'"d !".!!"i.h............r s0C #s f s
APPLICABILITY: HODE 5 with RCS loops not filled. ACTIONS CONDITION REQUIREDACTION COMPLETION TIME 3A b Ad t ** *
. One SDC inoperable, A.) Initiate actior to imediately restore $DC OP(RABLE status (continued)
CC0G STS 3.4 16 Rev1,04/07/95
RC$ loops-M00C $ Loops Not filled 7 8 3.4.8 gggg _ sh & lA CPU ** 1575 /53 LC0 Note 1 peretts the SDC pumps toup-~.J (continued) n.m for ,
$ 15 minutes when switching free one teele se another.
circumstances for stopping both $0C pumps are toThe Ala' be Italted N 06 g4 la o.st to situatians when the outage ties is short/tand the core outlet temperature is maintainww10'F below saturation @ $- operations when SDC forced flow 18 stopped.temperaturete-1he N Note t 41 ows one 10C tres, to be inoperable for a ner , ! hours provided that the other trM is OPIMBLE and 'nad of operat
]
r 1: ' perform. ton. This peretts period:e surveillance tests to be ' 3 these tests are safednon the Inoperable t 2 during the only time When ossible.- An OPERABLE SDC 4 capable of Tcomposed of an OPERABLE SDC pump g exchanger, providing forced flow to an OPCPeBLE SDC leatalong instrumentation for control, protection, and indication
$DC pumps are OPERA 8LE if they are capable of being red powe."
and are able to provide flow if required. APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the 500 System. OperationinotherMODEiiscoveredby LC0 3.4.4 'RC$ Loops-MODES 1 and 2' LCO 3.4.5,, 'RCS Loops-MODE 3' LC0 3.4.6, 'RCS Loops-MODE 4'; LC0 3.4.7 'RCS Loops-MODE 5. Loo LCO 3.9.4, *$hutdown Cooling ($0C)ps Filled's and Coolant Circulation-High Water Level' LC0 3.9.5, ' Shutdown Cooling ($0C) and Coola(MODE nt 6); and Circulation-Low Water Level' (MODE 6). . ACTIONS L1 oo If the required $0C is inoperable redundane for heat CD l removal is lost. Action must be initta{ed imeditfely to restore a seconaeek to OPERABLE status. The Completion Time of two teflects paths forthe importance heat removal. of maintaining the availablitty
@ [
(continued) CEOG ST$ B 3.4-36 Rev1,04/07/95
- 10. Discussion of Change LA.I for ITS 3.4.6 was revised to state that the specific loop numbers are being moved to the Dases. The IS1S markup of the 11ases for ITS 3.4.6 was revised to include the required information. These changes have been made to respond to an NRC comment (ITS 3.4.6 Comment 1).
RCS Loops - MODE 4 B 3.4.6 8 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.6 RCS Loops - MODE 4 BASES BACKGROUND In MODE 4, the primary function of the reactor coolant is - the removal of decay heat and transfer of this heat to the : steamgenerators(SGs)orshutdowncooling(SDC) heat exchangers. The secondary function of the reactor coolant , is to act as a carrier for soluble neutron poison, boric . acid. . In MODE 4 either reactor coolant pumps (RCPs) or SDC loops can be used for coolant circulation. The intent of this LCO , is to provide forced flow from at least one RCP or one SDC . loop for decay heat removal and transport. The flow provided by one RCP or SDC loop is adequate for heat removal.- The other intent of this LCO is to require that two paths be available to provide redundancy for heat - removal. For Unit No. 1, the two paths can be any combination of RCS Icop No. 11. RCS loop No. 12. SDC loop No. 11, or SDC loop No. 12. For Unit No. 2, the two paths f can be any combination of RCS loop No. 21. RCS loop No. 22, SDC loop No. 21, or SDC loop No. 22. APPLICABLE In MODE 4. RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the accidental boron dilution event. The RCS and SDC loops provide this circulation. RCS Loops'- MODE 4 have been identified in 10 CFR 50.36(c)(2)(11) as important contributors to risk , reduction. LC0 The. purpose of this LCO is to require that at least two loops, RCS.or SDC, be OPERABLE in MODE 4 and one of these CALVERT CLIFFS - UNITS 1 & 2 B 3.4.6-1 Revisiong5
DISCUSSION OF CilANGES SECTION 3.4.6 - HCS LOOPS . MODE 4 contain the option to bring the plant to Mode 5, corrective action to restore the required e.oolant loops to an OPERABLE status can always be initiated within the Completion Time; thus, the option to cooldown to Mode 5 is never required to be invoked. While Action C of ITS 3.4.6 does not contain a requirement to place the unit in Mode 5, it is equivalent to Action a of CTS 3.4.1.3 because its shutdown requirement is never required to be invoked. Action C of ITS 3.4.6 provides a more restrictive course of action than Action a of CTS 3.4.13, because, in addition to requiring the initiation of corrective action to restore the loops to an OPERABLE status, it requires the suspension of all operations involving a reduction in boron concentration of the RCS. The more restrictive action to suspend all l operations involving a reduction in boron concentration of the RCS is appropriate, in most scenarios with no coolant loops OPERABLE, there will also be no forced flow. Without forced flow, proper mixing would not occur. Thus, if boron dilution was occurring, slugs of water with a significantly reduced boron concentration could develop. These slugs could lead to reactivity excursions. This requirement will ensure that this does not occur. To incorporate Action C ofITS 3.4.6, Action b of CTS 3.4.1.3 was modified to apply to the condalon of no coolant loops OPERABLE. Currently, Action b of CTS 3.4.1.3 only applies when no coolant loopi are in operation. It essentially contains the same actions as Action C ofITS 3.4.6. TECIINICAL CIIANGES - ItELOCATIDES None TECIINICAL CilANGES MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DDC11MENTS LA.1 Cmrent Technical Specification LCO 3.4.1.3.a lists the loop numbers (reactor coolant and SDC) required to be Operable and defines the components which comprise an Operable RCS loop. Improved Technical Specification 3.4.6 LCO will require two reactor coolant or SDC loops to be Operable. He speelfic RCS and SDC loop numbers and the definition of an Operable RCS loop will be moved to the Bases. This is acceptable, because ITS 3.4.6 will continue to require two cooling loops to be Operable, Throughout the ITS, the Bases usually describe the contents of the system and the specific icquirements of the syste n contents. This information can be adequately controlled in the Bases. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement for two coolant loops to be Operable. This change is a l less restrictive movement ofinformation change with no impact on safety. This change is consistent with NUREO.1432. LA.2 Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specifiestion SR 3.4.6.3 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.1.3.1 has been modified by replacing the phrase "SDC pump and valves" with the phrase " loop components." The Bases ofITS SR 3.4.6.3 will be revised to identify the loop components CALVERT CLIFFS - UNITS 1 & 2 3.4.6-4 Revision 5
RCs Loops-MODE 4 8 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.6 RCS Loops-MODE 4 BASES - SACKGROUND in MODE 4 the primary function of the reactor coolant is the remova,l of decay neat and transfer of this heat to the or shutdown cooling $0C) heat P,o' galj go, j l k steam generators enhangers. The secon ($Gs)dary function of the r(eactor coolant - twopc t t e k acid.is to act as n: carrier for soluble neutron poison, boric "3 (p(alncMoo in MODE 4 either react 0r coolant pum can be used for coolant circulation. ps (RCPs) or $DC M RC.$ locf g gg J The intent of this LC0 in RC $ IOofg0 g DC, is to provide forced flow from at least one RCp or one $0C bes4* Ior cecay neat removal and transport. tThe f' ow 8 provided by one RCP Teep or $DC 6pesa.is saequate For heat - l0 @ ff ll Or S DC. ik, removal. The other intent of this LCO is to require that For un!4 gA 4 wo pd S 0"^ b two paths be available to provide redundancy for heat
'**I't
,3 h
a q tom (s sha.Wer o P APPLICABLE SAFETY ANALYSES n MODE 4. RCS circulation is considered in the determination of the time available for mitigation of the St S lcac3 p *f <1,1, Rc3 accidental boron dilution event. The RCS teops and $0C g g te4(M provide this circulation, gnp3 g BOP y 1i Oe SD(. I Statement as important contributors to risk reduction.RCS Loops-M Icoe m. y .
, ./..:
LCO The eurpose of this LCO is to require that at least two loops er tr 9 5 of these loops re.t~" RCSbeor $DC,in operation.be OPERABLE in MODE 4 and one The LC0 allows the two loops that are required to be OPERABLE to consist of any combination of RCS and $DC System loops. . Any one loop
-r t-9 in operation provides enough flow to remove the decay heat from the core with forced circulation. An
/kg b /4 additional loop ^- tr6 is required to be OPERABLE to f,gyg fr3 4 provide redundancy for heat removal.
Note 1 permits all RCPs and $DC oumps t)i>e.me-a wers) L 1 hour per 8 hour period. yhispens snat n ~ (ctrgMhtt n nas geen estacilshed/bsing-the SGf[y ir,LpTie Note (continued) CEOG STS B 3.4 2$ ) Rev1.04/07/9$
f
?
l 11. De markups of CTS LCO 3.4.1.3 for ITS 3.4.6 have been revised to denote that the climination 4 of17ootnote
- isjustined by DOC A.6 for ITS 3.4.6, not DOC A.$ for ITS 3.4.6. This change has been made to respond to an NRC comment (ITS 3.4.6 Comment 3).
4 1 4 4 N e i 4 o E e - , , . , , .- . y-,---n...-,-, , -,.. ...nc.,w .. .w,, ,, - - - - -. ,,n.,,-,,: ~.
'n aa.Ot A 3,(f, 4 !
3.4 9/474 REACTOR COOLANT $YST[ h ] 3,Q 4 4 4,4 COuai ivva "" 200;",',7 0"N0dG - - Shiddeein
- LIMITING CON 0! TION FOR OPERATION 4 '* a A.)
k0 I'M b4riva b ^.t h.n tw ' 'M = hrt loop t h t:d h b : shall be OPERABL j,.f i - , . _ [i.Reactorcoola Loop r44 ano us as ciatea steam generator an at least one associ ed reactor coola . pump, ! L Ae l
- 2. Reactor oolant Loop #12 and ts associated st gener or and at least one stociated reactor oolant' pum , "
- 3. utdown Cooling Loop . k[ d
[ thutanwn ranH an ina J18b
%, , At least 3,ne e' tS d= ce-!=t loon 6sha11 be th" A'
' operation .i sn kn.nia,.or* c).. p &
% APptlCABilills MODE $f(and 5".- Gr...r.< , g, y,4,7, , ,n g,,g a.c. , , AC110N: tI.N '),f
; f ik ' *#' ~^ mTire n
e corrective m e 2action == to a = = = w ---. .... J - t e ne recui ma cooiant ioo e A 0LRABLEstatuswithinen,feturn_!h n t,We.inAC0 $HUTDOWN with% \gy l
/kh.o ours.]
(_ 1 B oreerj.def i< Q e J \
" a s /.~,i .b.,.y.de)
__f& Vf
\ -- 'S n=1 ;r n.;;,;r.;y ;=;r :=ce 5ey M ' !?reh ' "^M 0. _ _ _ -
~
All reactor coolant umps and shutdown cooling pumps may be de.
- M l' O energized for up to hour provided (1) no operations are pemitted WI - of the Reactor Coolant System boron
- concentration, that would cause and (2)d'ht'h outlet temperature is maintained at least '
10'f below saturation temperatur e
~
A reactor coolant pump shall not be started withhRCS t e re kt0 Mt t. less thanororequal less than equaltoto170 365'r unless inches, and(1)(the pressurizer water level is l 2)thesecondarywater g temperature of each steam generator is less than or equal to 30'f above the RCS temperature, and (3) the pressurizer pressure is less than or equal to 300 psia. L- c._ ,___u. ....____m . . .g , CALVERT CllffS - UNIT 1 3/4 4 4 Amendment No.185 h
& [.esA s s 3.A..( .
3,4 9/4t4 hACTOR C00LAKT .*JlIB 3.+.6 m met =- - - -r -
= -
(( --
'n h (
w_._-_._-- . 4 m +. a g
- P ,. a y r* 4 a ad i %
Lill!TIIIG C0010!T!0ll F04 OPtnATItil ' *A, sac.$ l..c 3 .r _ S OC l..py LC.O
- s. 4. 6 - u .:.:
% .;j , g t g g " : = 1**Pi j
{== shall to i .l A battor ant Loop frl its associated eam 7
/ Denera and at least associated to r coolant
- 2. eactor Coolen op #22 and its ociated ste
__f_ A .) generator a t least one also sted reactor clant Pump,
- 3. Shut Cooling loop # . [
4 . __ down Cooling #2 5 % t least ,ge M th- -in: retet loopyshall be 13 M.S eratio #n .- r.. d... s,... F e.b.-
,3
[
~
APPLEAllLITY: El . and M , c p . ( . . .a . . . 'f . ' . ~/ , E3 C C , [ ,g gc,gg,,, M5 L a c* t4 0 W C, '** W r.tod" nd 4o 50cle a -d D'O
$ a -f lh % .".? M e-w
=-
e-e b.. .. m. m ... _L* - . __ Y.*
. U. +,5, +"
r** B'_ 5,_'..'-R'
. ;'E.'.fa s - * *0 E %
'w .a ,/ Tuste corrective action to returnlhe recuUnd coolant Joonsh - . . _ . _
Act toQ ($ - I o DP_ERABLE status within ent-hou5ttype in COLD $ lit 171Rui withiB 4 f 4' hours.
. a , m. .a = s. , . ..
- n. ,
N bu QC. _
l e.p t ,i n p . ., y Nh: :=t e- -- :- . r
^
- =ra =, $: '- ::r:St: ' - :: : . I6 LC C nd shutdown cooling pumps may be de. N et Y **'
All reactor coolant to I hourpumps fprovided (1) no operations M WMEI energized that would cause for up ton of the Reactor Coolant System boron ?are "*4permitted concentration, and (2) outlet temperature 1 intained at least 10'F below saturation tempe stu m
" ,. e { q Q tco A reactor coolant pump shall not be s wit RCS* temperature N0Y2 less less than thanoror equal equal to 301'F to 170 inches,unlessand 2) t(1)(the e secondary $ressuriner water water level 4 is temperature of each steam generator is less then or equal to 30'F .
above the RCS temperature, and (3) the pressurizer pressure is less than or equal to 320 psia. Y h. Qui:t ' et E::;tta 0.;0.ii. CALVERT CLIFFS . UNIT 2 3/4 4 4 Amendment No. 178 pe.S e i oP Q
12 The markups of CTS 1.CO 3.4.1.3 for ITS 3.4.6 have been revised to denote tha: the climination ofl'ootnote # isjustified by DOC A.5 for ITS 3.4.6. This change has been made to respond to an NI(C comment (ITS 3.4.6 Comment 4). I
%Y *A'L h** 3* 'f. G 3.4 4/tt REACTOR COOLANT SYSTEMh (JR 'c's't..v4. Moos 4 3 4.(, '8V4t4rl 000 E i ivsi^, ".; 000 = 7 0;;i0 f 7 4
lhiddleL4 ' _y,,-'m-LINITING CONDITION FOR OPERATION h,'. seN
^
* ' 'h :ni;at_ looph!!:t:d 5:hw shall be I'N ,Br+rh+ Et0PERABL
".t h;n t gjgt .
, . . . . .. . g . a
[ 7 xeactor cooia i.oop r44 ana us as ciated ste generator an at least one associ ed reactor coola pump, t '
- 2. L A. I Reactor oolant Loop #12 and ts associated st I
_gener or and at least one ssociated reactor colant i pum , 7
- 3. utdown Cooling Loop k -
[ h tdown enn1<nn Ia n A10 ef th: dr: echet loo @shall be inf A.) 7
% . operation At least g,ne .i 4 ste be.we o r* c),..y IC ,7 APPLICABILITY: N0 DES 4*ytnd _
5"*'. Sonob J..s.7, * ,c s t na.oe s, g ACTION: [I fc *
,f,/,'g, 55 I' '*""*
AC%'4 a, 0 Wit [ h n 't 5 th: : h ;; c; ;!r g rn ;t r : n h .* 'aar* N m tE, F.'tlate corrective action to gp 4 loo m
/kh.4 g to_0PERABLE status within c=,feturn tne recuirea coolanth:r..kHbbe_ in COLD SHUTDO B-ggv? e
H -__ , ,, {
l++ eh Jf, t on ny,a.I sos
% tc.s /.up anyw h i
__ -- s I \ A.4
'he, =1 x u,ug;;.g pw;r :=re -ty be '-e- rebh < "ar: :.
~
(C " nd shutdown cooling pumps may be de-
"'A I All z'eactor era gtzed for upcoolant to I hour pumps}provided (1) no operations are permitted' I"h,3 that would cause d! h t' r concentration, and (2)h of the Reactorperature CoolantisSystem boronat least maintained 10Y below sate ation tempera .
u.0 A reactor coolant pump shall not be started with RCS t , e re OM L less thanoror less than equal equal to 170to 365'F inches, unless (1)(the pressurizer water level and 2)thesecondarywater g is l temperature of each steam generator is less than or equal to 30*F above the RCS temperature, and (3) the pressurizer pre ure is less , than or equal to 300 psia.
'- in 0Fc:el !st E:n,,t:. 0.;0.5. _
g,g CALVERT CLIFFS - UNIT 1 3/4 a-4 Amendment No.185 s- . pop \ ash
{p f,M , % 3, 4. , ( b ._-_ _
._ A,i 3.4 5/4:4 REACTOR COOLANT SYSTEN C,3 ~' -
- 3. 4 . b 4/4T471-CS Loops - MODE 4-20nL*MT La^P! ^"O C^^L*F C!Pf"L*?._
$m LIMITING CONDITION FOR OPERATION
. e. . . , . , . < . ~ .
m -- h . , gg - -^ Q Re.S 1..c3
.c
_ S Oc l..pg__ 5,4,6 -5A.1.3 \. At k.;t t ' 'M m int loops 'etd kh.; shall be OPERABLI/ % t)
.e , n er v .....-.~.
- 1. Joactor i
ant Loop #Z1- d its associated eam _3
/ genera and at least associated re r coolant
- 2. eactor Coolant op f22 and its L A.1 generator an ociated ste pump, t least one asso" sted reactor olant 3.' Shut n Cooling Loop i . [
- 4. _
utdown Cooling #2 1 kA % t least ge. ;f the 20't: ce:h .t loopf shall be ige - peration f s-< 4 . .. ,,, , - u F c.k. n . s ('M.$ APPLICABILITY: MODES and N c p . . c. . .A .
, m,- saw . ,,
= e m ,,, m ..c. -s, 'T. 4 . *? r , a-sum. .--
Nd N N 'd h. ~ yui..; :: (:$,.Ea.s m y$ , ~.. - s a.
@M N- itiate corrective action to return the reg.uired, coolant 0! ' l ACTio'J L% -
o CPERABLE status within en; he"_mtype in COLD SHU p^ /kb d lours. wthIn) M n=- __
.) g,[ eJ b f
. .e Oc b. p . .a ,- N . 3-
__ _ Wu _ Q,},*a p s y a p
- m Y e Nh :- ! Or - tr =ary a~~ ::r:: ;; i
- n p rabi; '- "0"! .-
l- 9 W u'T = I All reactor energized that would cause df49ti coolant for up to 1 hourpumps {provided (1) no operations9'"*4 are t4 pennittedn concentration and (2)t%reoutlettemperatureismaintainedatleast en of the Retetor Coolant System boron 10'F below saturation tempeh N tc o A reactor coolant pump shall not be st with RCSMemperature N oTE 2 less thanoror equal to 301'F less than equal to 170 inches,unless and 2) t (1)(the e secondary $ressurizer water water**level M ' *is-temperature of each steam generator is less than or equal to 30'F above the RCS temperature, and (3) the pressurizer pressure is less than or equal to 320 psia. b 1.s Spe:f:1 Ted Ex :pt!;r. 3.10.5.
- CALVERT CLIFFS - UNIT 2 3/4 4 4 Amendment No. 178-pc 3 e 1 o P '2
- 13. The NRC requested additionaljustification regarding the changes to Action b of CTS 3.4.1.3 for ITS 3.4.6. To resolve this comment the following changes were required: 1) the markups of the Actions of CTS 3.4.1.3 for ITS 3 A.6 were revised to reflect the changes to Action b of CTS 3.4.1.3; 2) DOC M.5 for ITS 3.4.6 was added to provide additionaljustification for a number of changes to Actions a and b of CTS 3.4.1.3; 3) DOCS A.2 and L1 (and its associated NSilC) for ITS 3.4.6 were deleted, because they were no longer used (ITS 3.4.6 Comment 5).
i i i l 1 J Y l I d
- ~ . _ . . . ,- - ..
Seat OLMe 3, 4, (,, t 3.4 W4M JLEACTOR 500LANT SYSTh { { 3,g U4,4,4 ^e^ LnWi wvi ^. ":: 0^^L,"!7 0 MC C G LIMITING CONDITION FOR OPERATION s M
"" -h4 tid E !.t u;J tw
'ib , OPERABL
^f 'h: :: leet loops thi:d hh; shall be rf,'f ., .
. , . ..a 7%
[ E Keactor coola Loop r44 ano its as clatea ste generator an at least one associ ed reactor coola f, j; a pump, i t I
- 2. Reactor colant Loop f12 and ts associated st I L A. I gener pum ,
or and at least one ssociated reactor oolant 7 -
- 3. utdown Cooling loop k -
d __ N tdnwn ran14aa la a 81 M
% At least p.,ne ef th: t r: : chat loo;ufsshall be i operation .i s u b m u m or* th.a p /C 5".
4 APPLICABIL]J1: N0 DES 4"(and St adt A. J.4,7, us t ,s . we s,
' g ACTION:
[ fhe .
#8),y,//y,
; e N '#8' ' W" # #
Ap4 ' a, With::NNM:M;;7:wirgr;;;;;r:: 9 -t 'e M m ajeir,' M (Unitiate corrective action tofeturn Ine reauirea coolant loom Lto_0PERABLE status within en:, h:.7,ji6be_ in C0t0 SHUTDOWN withfih gy
/kha -
f24 hours.) I 6 L ,- _ _, i ore reg.sr<J .tos Im eh y,(
-tm 42 g f,up y, _ _ - pan)$).e I i \
'hc no ai er ;r,;r;ca;y p;.;;r ::tre = be '- cre'- ' "^0: :.
All reactor coolant pumps tC ,
"'" I energized for up to I hour {and shutdown coo!ing pumps may be de.
provided (1) no operations are permitted
%,3,[
that would cause d"ut' : ef the Reactor Coolant System boron concentration,and(2) mperature is maintained at least 10*F below saturation tempera . i Lto A reactor coolant pump shall not be started with RCS t e re MeL less than or equal'to 170 inches, and (2) the secondarygwaterless than temperature of each steam generator is less than or equal to 30*F above the RCS temperature, and (3) t% pressurizer pressure is less than or equal to 300 psia.
' "^^ '- '" 't:t 5::st ';a 0.10 ';.
g,g CALVERf CLIFFS - UNIT 1 3/4 4-4 Amendment No.185 O
Spe.4Ae 3 4,b 5/t.t !!'"^ *^^L" N!?"
^
M LIMITING CONDITION FOR OPERATION (Continued) _ b in(erath suspend all operations C- %. involving With noa reducti coolant loo!n in $oron con, centration of the Reactor Coolant System and initiate corrective action to return the required coolant loop to operation w1*a_;^ '-"- e, -- . - - jA
$URVEILLANCE REQUIREMENTS D PERh S LC
$ s e ld\
d;h-+- - i, ,1 +:+r+r&d The requiredCW c. ::er shall be cetermined OPERA 8LE loop (s), if not in operation, days by ect breaker
=innments
= , and indicated power availability forhvesafifying chu cor ea*] g C"
3A,g i.t.1.3 a The required ste'am generator c.av"rthm (s). " d't '- -- "'" g . g Sv'.l. ;, shall be determined CPERA8LE by verifying the secondary ' ^ -"B side A .9-ia water level to be above -50 inches at least once per 12 hours. sA 4.4.1.3.3 At least one coolant loop shall be verified to be in operation gna-circutating-reactor-coetenbat least once per 12 hours. d, CALVERT CLIFFS - UNIT 1 3/4 4-5 Amendment No. 169 p.y a .F 4
Ipas C.d is. 3.4,{
.m c - k.I 3.4 W474 AEACTOR C00 TANT $YSTEM *i) ' * ^ ^ "
- 3. 4. 6 #4r4rl- COOLANT LMPS ^"" CM' ^" t!"" ^2__ C.L _
_ L'ofs- MODE 4
'5M** -
c . g w . 3 . P '. = y ev m % ..A 3 LIMITING CONDITION FOR OPERATION 'eP _ Re. $ l..c g . r- _ S OC 1..ps 9 -
- 5. 4, 6 1.'.1.0 \. f.; heet t ^' "; ;n het loops ht;d h h; shall be
., g OPERA 8LI/ c= w g , n n. n. .n ,~. , 4
- 1. actor ant Loop #21 d its associated eaa N --
genera and at least 4l O e associated re r coolant
- 2. eactor Coolant o #22 and its ociated ste generator an t le st one asso sted reactor olant pump.
- 3. Shut Cooling Loop i '
- 4. utdown Cooling #2 5 % t least 3,ne Of tM er: crehM loopf shall be iP-
- peration /. y-e 4 . .. u . . . u F cN s ,3 M.S
~
~ APPLICABILITY: MODES nd . c y. . r . . 4 . . J.'.7, ,
ACTION: CL, ,,p.,,2 pc.fi,,p R'S L a+ c. M o o r 5, I no w r, h.d *
"4 Y *.a* S
%.d.p+4 g wo 50c 1.
r Sie _ t +. pg. g4- " RC C. I' N oa*,'m - M * % a. D' M % hMfwHtWE M.- . wi. J C:hnt '00r: ^*!"?? .' I . ACTiok) B Itiate corrective action to return ..he reauired coolant looof . '
. o OPERABLE status within ent-houyG!) einCOLDSHUfDOWNwithi@
4 hours, y-
= - - -
G ,Q toc 6,p.4 #
'*ff-45 w o qc\iop.,.mog..q,
~ _- _ - - _-
iMn0m!er era ~yn~~ :=rn ny h '"?perath "a : :. . A.6
^
L.C O nd shutdown cooling pumps may be de. pu ?..' All reactor energized coolant for up to I hourpumps {provided (1) no operations are 9'"*4permitted M~ WMEI that would cause e of the Reactor Coolant System boron i concentration,and(2 outlet temperature is maintained at least 10'F below saturation temp *
< .h f,. v i__J gQ - -
go A reactor coolant pump shall not be st with RCS* temperature NOTE 2 less than or equal to 301'F unless (1) the essurizer water level is less than or equal to 170 inches, and (2) t e secondarv water "* M temperature of each steam generator is less than or egal to 30'F , above the RCS temperature, and (3) the pressurizer pressure is less than or equal to 320 psia. Y .c Opnb1 S:t Ex: ptb;. 0.10.3.
- CALVERT CLIFFS - UNIT 2 3/4 4 4 Amendment No. 178-
~
i i 1
. . . _ . __ ~ . _ _ . _ . _ . _ _ _ . _ _ - _ _ . _ . . . . . . _ _ . _ _ _ . ~ _ _
$pec.Oeed.., 3, 4, 6 1
1
-!!^ ^ t? ~" _'_"* m LIMITIM ComITION FOR OPERATIt (Continued) h ACT tchJ Wn o ration suspend all o ations C % With involvingno coolant a reducti loo!n in $ron con, centration of fhe Reactor Coolant System and initiate corrective action to return the required coolant loop to operation '.;.;n .. ;-.
' l M.3 it 3,,u, * '
SURVEILUWICE REQUIRDIDITS parb jhfubl D s 3403 i...i.;." -The utred it;. r:!91oop(s) if not in operation. M'N shall be detem ned OPERA 8LE once per 7 days by verifying correct breaker alignments and indicated power availability forCoumadece r_~_C. :=
==- g 4.4.i.3.i The required steam generator (s), bL f: CCE M g 4 , c * 2
" t.:.0.;. shall be detemined OPERABLE by verl"ying the secondary side water level to be above -50 inches at least once per 12 hours.
5:fr r:: t: - 7 Q ' SR 3*4*4*g 4 At least one coolant loop shall be verified to be in operation
- .J.~.1.3.3 L,w..rr- - rr tru-t at least once per 12 hours. [A*]
1' i i l CALVERT CLIFFS - UNIT 2 3/4 4-5 Amendment No. 149 e
DISCUSSION OF CHANGES SECTION 3.4.6 - RCS LOOPS - MODE 4 ADMilijSTRATIVE CIIANGES A.1 The proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change ofintent, to be consistent with NUREG-1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs ITS development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREG 1432, 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 Specifications. A.2 Not used. l A.3 Current Technical Specification LCO 3.4.1.3.b footnote " discusses the requirements which allow all RCPs to be de-energized for a period of time. One requirement is that no operations be permitted that would cause dilution of the boron concentration. improved Technical Specification LCO 3,4.6 LCO Note I changed the word " dilution" to " reduction." Both words are used in the same context; reducing boron concentration is unacceptable. This wording change is solely for consistency with NUREG-1432. Word changes made to be consistent with NUREG-1432 constitute an administrative change. A4 Current Technical Specification 4.4.1.3.2 requires the SG(s), if used to meet the LCO, to be determined Operable by verifying the secondary side water level to be above -50 inches at least once per 12 hours. Improved Technical Specification SR 3.4.6.2 will delete the phrase, "if it is used to meet the LCO." 'Itc statement is redundant with " required" SG(s), if the SGs are not associated with a reactor coolant loop, which is required to meet the LCO, then the Surveillance will not be performed on that SG The deletion of redundant information constitutes an administrative change. This change is consistent with NUREG-1432, A.5 Current Technical Specification 3.4.1.3 Applicability footnote (#) references STE 3.10.5. Improved Technical Specification 3.4,6 will delete the reference to the STE. This change is consistent with the ITS format which does not typically include cross references. .In addition, LCO 3.0.7 has been provided to clarify theeApplicability of STEs. The deletion of cross references, consistent with the ITS format, constitutes an administrative change. This change is consistent with NUREG-1432. A.6 Current Technical Specification LCOs 3.4.1.3.a.3 and 4 footnote
- allow the normal or emergency power source to be inoperable for the SDC loops. Improved Technical Specification 3.4.6 will not include this allowance. The ITS definition of Operability only requires a normal or an emergency source be available for the system, subsystem, component, etc. (see Section 1.0 less restrictive discussion of changes). Therefore, the footnote is no longer required. This change is considered administrative since the justification for the Operability definition change has already been made. This change is consistent with NUREG-1432.
CALVERT CLIFFS - UNITS I & 2 3.4.6-1 Revision 5
DISCUSSION OF CHANGES SECTION 3A6 - RCS LOOPS - MODE 4 M.5 - Action a of CTS 3.4.1.3 requires, when less than the required coolant loops are OPERABLE, action be initiated to return the required coolant loops to an OPERABLE status, or the plant be placed in COLD SHUTDOWN. Action b of CTS 3 A.1.3 requires, when no coolant loop is in operation, the suspension of all operations involving a reduction in boron concentration of the RCS and the initiation of corrective action to return the required coolant loop to operation. As discussed below, the CTS actions are being revised to match the Actions of ITS 3.4.6. In Action A of ITS 3.4.6, if only one RCS loop is OPERABLE (i.e., one RCS loop inoperable and both SDC loops inoperable) the plant will be required to initiate action to restore a second loop to OPERABLE status. Currently, in the event only one RCS loop is
,t~ OPERABLE, Action a of CTS 3.4.1.3 requires the initiation of corrective action to restore the required coolant loops to an OPERABLE status, or the plant placed in Cold Shutdown (i.e., Mode 5). While Action a of CTS 3.4.1.3 does contain the option to bring the plant to Mode 5, corrective action to restore the required coolant loops to an OPERABLE status can always be initiated within the Completion Time; thus, the option to cooldown to Mode 5 is never required to be invoked. Based on this, Action A ofITS 3.4.6 essentially requires the same course of action as Action a of CTS 3.4.1.3 for the given condition, even though it does not contain a requirement to place the. unit in Mode 5, Changing Action a of CTS 3.4.1.3 to i
match Action A ofITS 3.4.6 is a presentation change only, in Action B of ITS 3,4.6, if only one SDC loop is OPERABLE (i.e., one SDC loop inoperable and both RCS loops inoperable), the plant will be required to be placed in Mode 5. If a second loop can be restored to an OPERABLE status prior to the end of the stated completion time, the action may be exited, Currently, in the event only one SDC loop is OPERABLE, Action a of CTS 3.4.1.3 requires the initiation of corrective action to restore the required coolant loops to an OPERABLE status or the plant placed in Cold Shutdown (i.e., Mode 5). Action B of ITS 3.4.6 is more restrictive than Action a of CTS 3.4.1.3, because it requires the plant to be placed in Mode 5 and Action a of CTS 3.4.1.3 permits the plant to operate indennitely with only one SDC loop OPEP ABLE, if corrective action has ; been initiated. Changing Action a of CTS 3.4.1.3 to match Action B of ITS 3.4.6 is ' acceptable, because redundancy is lost when only one SDC loop is OPERABLE in Mode 4. ; Thus, if another coolant loop cannot be restored within a reasonable time, the plant should be ! placed in a Mode for which the LCO does not apply to reduce the risk of operating with a single coolant loop OPERABLE. Cooling the plant down to Mode 5 exits the Mode of Applicability for ITS LCO 3.4.6. The 24-hour Completion Time for placing the plant in Mode 5 is reasonable (i.e., will permit a controlled cooldown), and is consistent with other actions which require the plant to be placed in Mode 5. Additionall; a SDC loop remains OPERABLE. Thus, the plant would be brought to Mode 5 utilizing the safest method. The operators would not have to rely on infrequently perfonned operations, such as feed and bleed, to achieve Mode 5. In Action C for ITS 3.4.6, if no coolant loops are OPERABLE, the plant is required to suspend all operations involving a reduction in boron concentration of the RCS, and initiate corrective action to return one required coolant loop to OPERABLE status and operation. Currently, in the event no coolant loop is OPERABLE, Action a of CTS 3.4.1.3 requires the initiation of corrective action to restore the required coolant loops to an OPERABLE status or the plant placed in Cold Shutdown (i.e., Mode 5). While Action a of CTS 3.4.1,3 does CALVERT CLIFFS - UNITS 1 & 2 3.4.6-3 Revision 5
DISCUSSION OF CHANGES SECTION 3A6 - HCS LOOPS - MODE 4 contain the option to bring the plant to Mode 5, corrective action to restore the required coolant loops to an OPERABLE status can always be initiated within the Completion Time; thus, the option to cooldown to Mode 5 is never required to be invoked. While Action C of ITS 3.4.6 does not contain a requirement to place the unit in Mode 5, it is equivalent to Action a of CTS 3A 1.3 because its shutc'own requirement is never required to be invoked. Action C of ITS 3x.6 provides a more restrictive course of action than Action a of CTS 3 A.13, because, h. uddition '.o requiring the initiation of corrective action to restore the loops to an OPERABLE status, it requires the suspension of all operations involving a reduction in boron concentration of the RCS. He more restrictive action to suspend all operations involving a reduction in boron concentration of the RCS is appropriate. In most scenarios with no coolant loops OPERABLE, there will also be no forced flow. Without forced flow, proper mixing would not occur. Thus, if boron dilution was occurring, slugs of water with a significantly reduced boron concentration could develop. Rese slugs could - - lead to reactivity excursions. His requirement will ensure that this does not occur. To incorporate Action C ofITS 3.4.6, Action b of CTS 3.4.1.3 was modified to apply to the condition of no coolant loops OPERABLE. Currently, Action b of CTS 3.4.1.3 only applies when no coolant loops are in operation. It essentially contains the same actions as Action C - ofITS 3.4.6. TECIINICAL CHANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification LCO 3.4.1.3.a lists the loop numbers (reactor coolant and SDC) required to be Operable and defines the components which comprise an Operable RCS loop. Improved Technical Specification 3.4.6 LCO will require two reactor coo' ant or SDC loops to be Operable. The specific RCS and SDC loop numbers and the definition of an Operable RCS loop will be moved to the Bases. This is acceptable, because ITS 3.4.6 will continue to require two cooling loops to be Operable. Throughout the ITS, the Bases usually describe the contents of the system and the specific requirements of the system contents. This information can be adequately controlled in the Bases. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement for two coolant loops to be Operable. This change is a l less restrictive movement ofinformation change with no impact on safety. This change is consistent with NUREG-1432. LA.2 Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specification SR 3.4.6.3 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.1.3.1 has been modified by replacing the phrase "SDC pump and valves" with the phrase " loop components." The Bases ofITS SR 3.4.6.3 will be revised to identify the loop components CALVERT CLIFFS - UNITS 1 & 2 3.4.6-4 Revision 5
DISCUSSION OF CHANGES SECTION 3.4.6 - RCS LOOPS - MODE 4 that will be required to be tested. Relocation of this information to the Bases is acceptable, because ITS SR 3.4.6.3 will continue to require th, required SDC pump and valves that are not in operation to be tested. Throughout the ITS, the Bases usually describe the contents of the system _ and the specific requirements of the system contents. The Bases will be maintained in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change, because the SR will continue to require the verification of the correct breaker alignment and indicated power available to the required SDC pump and valves that are not in operation. LA.3 Current Technical Specification SR 4.4.1.3.3 requires the coolant loops to be verified in 3
. .. operation and circulating reactor coolant. The requirement to circulate reactor coolant is l
~ 3..
"being moved to the ITS 3.4.6 Bases. 3 Specific requirements for verify!ng that a reactor coolant or SDC loop is in operation will be located in the Bases or plant procedures, as appropriate. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert Cliffs change control process, 'Ihe Bases Control Program and the Calycit Cliffs i change control process will ensure that any changes to this requirement will receive an appropriate review. This change is consistent with NUREG 1432.
TECIINICAL CIIANGES - LESS RESTRICTIVE L.I Not used. l 3 CALVERT CLIFFS - UNITS 1 & 2 3.4.0-5 Revision 5
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. l 3. Does this change involve a significant reduction la margin of safety? The proposed change increases the time to reach Mode 3 from one hour to six hours when two reactor coolant loops are not Operable and in operation. The change will still require the plant to be placed in a condition where two reactor coolant loops with both RCPs are Operable and in operation (Mode 3). However, the plant will be brought to this condition in a more controlled manner, which places less stress on safety system components and with less risk of a plant upset. Therefore, the change does not involve a significant reduction in a margin of safety. 3.4.6 Chanoe L.I' _ Not used. l
,L4.7 Change L.1
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change eliminates the requirement to have the reactor coolant loop Operable 4 (i.e., the RCPs, SGs, required support systems, etc.) in Mode 5 with the loops filled when the reactor coolant loops are used to satisfy the Limiting Condition for Operation (LCO). The 4 change will require the SGs, used to satisfy the LCO, to have secondary side level 2 50 inches, The specific means by which cooling is provided to the reactor in Mode 5 with the loops filled is not an initiator of any analyzed event. Shutdown cooln.;' is the desired cooling method and one train is required to be Operable and in operation, per the LCC. The reactor coolant loops can only be used as the backup means, as also required by the LCO. The SGs with their large contained volume of secondary side water is a natural heat sink, and is capable of dissipating the required heat load while onc SDC train is being restored. The heat load is capable of being dissipated by the SG through natural circulation. Thus, the change will not alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. l 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? The proposed change diminates the requirement to have the reactor coolant loop Operable , (i.e., the RCPs, SGs, required support systems, etc.) in Mode 5 with the loops filled when the reactor coolant loops are used to satisfy the LCO. The change will require the SGs used to satisfy the LCO to have secondary side level 2 -50 inches. The change will not involve a
- significant change in design or operation of the plant. No hardware is being added to the plant as
,. part of the proposed change. He proposed change will not introduce any new accident i initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. i CALVERT CLIFFS - UNITS 1 & 2 3-4-11 Revision 5
- .._ . . . _ .-_.m.-.___.
- 14. De NRC requested additionaljustification regarding the addition of Note 4 of ITS LCO 3.4.7.
Discussion of Change L.2 for ITS 3.4.7 and its associated NSilC were revised to include _additionaljustification. Additionally,ISTS Bases markup for ITS 3.4.7 were revised to make the discussion of Note 4 consistent with the actual Note; this involved the deletion of a plant-specific change (ITS 3.4.7 Commerit 2).- While resolving the aforementioned NRC comment, it was discovered that the justification provided in DOC L.1 for ITS 3.4.8 and its associated NSilC was similar to the justification
- provided in DOC L.2 for ITS 3.4.7. Discussion of Change L.1 for ITS 3.4.8 and its associated >
NSilC were revised to include additionaljustification.
. . . . ~ _ t _. . .,, . . , . ~ . . . . . . . _ . _ ,r.
_ _ . _ _ __ . _ . _ _ ~ - - . . . _ - . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ RCS Loops - MODE 5, Loops Filled B 3.4.7 BASES } Satisfying the above conditions will preclude opening a PORV
- - during a pressure transient-when the RCP is started.
Note 4 provides _for a) orderly transition from MODE 5 to
- MODE 4 during a planned heatup by permitting SDC loops to not be in operation when at least one RCP is in operation. 6 This Note provides for the transition to MODE 4 where an RCP '
-is permitted to be_in operation and replaces the RCS -
! circulation function provided by the SDC loops. d An OPERABLE SDC loop is composed of an OPERABLE SDC pump and 5 an OPERABLE SDC heat exchanger. 1 SDC pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG l can perform as a heat sink when it has an adequate water level and is OPERABLE in accordance with the Steam Generator Tube Surveillance Program.
/PPLICABILITY In MODE 5 with RCS loops filled, this LC0 requires forced circulation to remove decay heat from the core and to provide proper boron mixing.. One SDC loop provides sufficient circulation for these purposes.
Operation in other MODES is covered by: LC0 3.4.4, "RCS Loops - MODES I and 2;" LC0 3.4.5, "RCS Loops - MODE 3;"
.LC0 3.4.6, "RCS Loops - MODE 4;"
LCO 3.4.8, "RCS Loops - MODE 5. Loops Not Filled;" LC0 3.9.4, " Shutdown Cooling (SDC) and Coolant Circulation - High-Water Level" (MODE 6); and LC0 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation'- Low Water Level" (MODE 6). CALVERT CLIFFS - UNITS 1 & 2 B 3.4.7-4 Revision p'r
RCS Loops-MODE 5, Loops Filled B 3.4.7 BASES LCO (continued) the reactor coolant temperature can be maintained subcooled, and beron expected. stratification affecting reactivity control is et los __ - Note 2 allows one SDC o be up to 2 hours provided that the et noperabl for a period of er SDC n is OPERABLE and in operation. This permits per' odic surveillance tests to be performed on the inoperable M during thw only time when sue.h testing is safe and possible.
,e Note 3 requires that dth: M the following4we conditions be satisfied before an RCP may_be started with any RCS cold leg temperature s q)*F: f_hDjg @
a. Pressurizer water level s e ; (60 5 1-ee h _ _ _ Secondary side water temperature in each SG must be
-U^^"~ ch of the RCS cold leg temperatures.
'F .
Satisfying M ..... .. abov ir t:;mt= rc;; pressure e conditions - ' ' " - " will preclude l a 'N3* transien@ the RCP is started. Note' P"V JAQ h 4 pr v es for an orderly transitio from MODE 5 to M00E14 during a planned heatup by permitt n
. Spees.@ operation when at least one R >g is-in
~This Note provides for the transition to M)DE 4 where an RCP dWVIT 2 SDC operation.
6 lg is permitted to be in operation and replacos the RCS circulation function provided by the 50C tiths.
-fo no Le, in An OPERABLE SDC g
and an OPERABLE SDC heat exchanger.s composed of anru-r. OPERABLE p53 SDC pump SDC pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG can perform as a heat sink when it has an adequate water ' level and isProgram. Surveillance OPERABLE 'n accordance with the SG Tube APPLICABILITY In M00E S with RCS loops filled, this LCO requires forced circulation to remove decay heat from the core and to provide proper boron mixing. One SDC sufficient circulation for these purposes. provides h
\ cot (continued)
CEOG STS B 3.4-32 Rev 1, 04/07/95 b b u siw pt e rt. 2 (, ,[ isd h
DISCUSSION OF CHANGES SECTION 3A7 - RCS LOOPS - MODE $, LOOPS FILLED alignment and indicated power available to the required SDC pump and valves that are not in operation. LA.3 Current Technical Specification SR 4.4.1.3.3 requires the coolant loops to be verified in-operation and circulating reactor coolant. De requirement to circulate reactor coolant is being moved to the ITS 3.4,7 Bases. Specific requirements for verifying that the reactor coolant loop is in operation will be located in the Bases or plant procedures, as appropriate. Any changes to the Bases will be in accordance with the Bases Control Program la ITS Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert Cliffs change control process. no Bases Control Program and the Calvert Cliffs change control process' will ensure that changes te this requirement will receive an appropriate
.y c review. His change is consistent with NUREG 1432, awe Ta TECIINICAL CIIANGES - LESS RMTRICTIVE 4
L.1 Current Technical Specification LCOs 3.4.13.a.1 and 2 require the reactor coolant loops, their associated SGs, and at least one associated RCP to be Operable if used to satisfy the LCO. Improved Technical Specification 3.4.7 will only require that the secondary side water level of each SG be h -50 inches if used as the backup system to the required SDC train. This is acceptable in Mode 5 with the loops filled because even though the SGs cannot produce steam, they are capable of being a heat sink due to the large contained volume of secondary side water. Forced cooling using the RCPs is not required because natural circulation occurs, which is sufficient to remove the small heat load in the reactor core until a SDC train can be made available. A plant specific calculation was developed to verify that the SGs could be used for decay heat removal. The calculation was performed in response to NUMARC Guidance Document 91-06, Guidelines for Industry Action to Assess Shutdown Management. De calculation considers or detennines the maximum core decay heat generation rate, total primary to secondary heat transfer area, heat transfer coefficients, relative primary and secondary temperatures, total natural circulation flow rate, and combined SG ambient heat loss rate, as well as other considerations. The calculation determines that a SG level of 2 50 inches with the associated RCS loop filled is sufficient to remove the generated decay heat load. This change is consistent with NUREG-1432. L.2 Two notes are being added to CTS LCO 3.4.1.3. These notes permit: a) one required SDC , loop to be inoperable for up to two hours for Surveillance testing, provided the other SDC loop is Operable and in operation; and b) all SDC loops to be removed from operation during planned heatup to Mode 4 when at least one RCS loop is in operation. Note 2 to ITS LCO 3.4.7 permits periodic Surveillance tests to be performed on one of the SDC loops when both SDC loops are credited for meeting the LCO. This not provides operational flexibility by allowing two hours before entering the Action statement. The note is acceptable, because: a) the note requires one SDC loop to be Operable and in operation. The forced coolant circulation provided by one SDC loop is sufficient to remove decay heat in Mode 5 with the loops filled; and b) the Operators will be focused on the status of SDC while operating under the provisions of this note. Thus, in the event the required SDC loop becomes inoperable or ceases to be in operation, the Operators would take action in a short period of time to restore a SDC loop to an Operable status and place it in operation, 4 CALVERT CLIFFS - UNITS 1 & 2 3.4.7-4 Revision 5
DISCUSSION OF CHANGES SECTION 3.4.7 - RCS LOOPS o MODE 5 LOOPS FILLED Note 4 to ITS LCO 3.4.7 provides for the transition to Mode 4 and permits an RCP to be in operation to replace the reactor coolant circulation function provided by the SDC loop. This proposed change is acceptable, because: a) the note does not permit the required SDC loop to be inoperable; it only pennits it to not be in operation, Thus, if required, the SDC loop could be returned to service in a short period of time; b) the note requires an RCS loop to be in operation to provide forced circulation in place of the SDC loop; c) the Steam Generators are required to be Operab!c in accordance with LCO 3.4.7, thus, decay hest removal via natural circulation would be available; and d) ITS SR 3.0.4 requires the surveillances for LCOs to be met prior to entry into a Mode or other speciGed condition in the Applicability of the LCO. Improved Technical SpeciGcation LCO 3.4.6 provides the Mode 4 requirements regarding the RCS loops. This LCO requires two loops consisting of any combination of RCS and SDC loops to be Operable and at least one loop to be in operation. ITS SRs 3.4.6.1, i 3.4.6.2, and 3.4.6.3 provide the surveillaricci which establish operability. Rese SRs are required to be met within their frequency prior to entering the Mode of Applicability for ITS LCO 3.4.6 (i.e., Mode 4). Thus, when a transition to Mode 4 is planned, two loops capable of providing forced circulation of the RCS would be required to be Operable. In addition to the justifications provided above, these proposed changes are consistent with NUREG 1432. t i CALVERT CLIFFS - UNITS 1 & 2 3.4.7-5 Revision 5
DISCUSSION OF CHANGES SECTION 3.4.8 - RCS LOOPS - MODE 5, LOOPS NOT FILLED TECHNICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED ! DOCUMENTS ' LA.1 Cu~ent Technical Specification LCOs 3.4.1.3.a.3 & 4 list the SDC loop numbers required to ' be Opcoble, improved Technical Specification 3.4.8 LCO will require two SDC loops , Operable, but the ITS will not list specific loop numbers, ne specific loop numbers am ' being moved to the Bases. This is acceptable because moving this requirement to the Bases l will not affect the requirement for the specific loops to be Operable. Throughout the ITS, the Bases usually describe the contents of the system. This information can be adequately controlled in the Bases. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0 His approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of 4 S.cility operation is unaffected by the change because there is no change in the requirement for two coolant loops to be Operable, nis change is a less restrictive movement of l mformation change with no impact on safety. This change is consistent with NUREG 1432. LA.2 Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specification SR 3.4.8.2 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.1.3.1 has been modified by replacing the phrase "SDC pump and valves" with the phrase " loop components." The Bases ofITS SR 3.4.8.2 will be revised to identify the loop components that will be required to be tested. Relocation of this information to the Bases is acceptable, a because ITS SR 3.4.8.2 will continue to require the required SDC pump and valves that are not in operation to be tested. Throughout the ITS, the Bases usually describe the contents of the system and the specific requirements of the system contents. The Bases will be maintained in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change, because i the SR will continue to require the verification of the correct breaker alignment and indicated power available to the required SDC pump and valves that are not in operation. J LA 3 Current Technical S2ccification SR 4.4.1.3.3 requires the coolant loops to be verified in operation and circulating reactor coolant, ne requirement to circulate reactor coolant is being moved to the ITS 3.4.8 Bases. Specific requirements for verifying that the reactor coolant loop is in operation will be located in the Bases or plant procedures, as appropriate. Any changes to the bases will be in accordance with the Bases Control Program in ITS Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert Cliffs change control process. The Bases Control Program and the Calvert Cliffs change control process will ensure that changes to this requirement will receive an appropriate review. This ch:mge is consistent with NUREG-1432. TECIINICAL CIIANGES - LESS RESTRICTIVE L1 Improved Technical Specification 3.4.8 will add a note to CTS LCO 3.4.1.3 which permits one required SDC loop to be inoperable for up to two hours for Surveillance testing, CALVERT CLIFFS - UNITS 1 & 2 3.4.8-3 Revision 5
DISCUSSION OF CHANGES SECTION 3.4.8 - RCS LOOPS - MODE 5 LOOPS NOT FILLED provided the other SDC loop is Operable and in operation. This note provides operational flexibility by allowing two hours before entering the Action statement. _The note is acceptable, because: a) the note requires one SDC loop to be Operable and in operation. The forced coolant circulation provided by one SDC loop is suflicient to remove decay heat in Mode 5 wis the loops not filled; and b) the Operators will be focused on the status of SDC whlie operating under the provisions of this note, Thus, in the event the required SDC loop becomes inoperable or ceases to be in operation, the Opentors would take action in a short period of time to restore a SDC loop to an Operable status and place it in operation. In addition to the justification provided above, this proposed change is consistent with NUREG 1432. I l i CALVERT CLIFFS - UNITS 1 & 2 3.4.8-4 Revision 5
NO SIGNIFICANT liAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM
- 3. Does this change involve a signincant reduction in margin of safety?
The proposed change eliminates the requirement to have the reactor coolant loop Ope able (i.e.,the RCPs, sos, required support systems, etc.) in Mode 5 with the loops filled when the reactor coolant loops are used to satisfy the LCO. De change will require the sos used to satisfy the LCO to have secondary side level 2 50 inches. The SGs are used only as a backup for the SDC loops. The LCO requires one SDC loop to be Operable and in operation. However, if the SG is required to be used, the large volume of secondary side water will ensure the SGs capability as a heat sink to re nove the heat load generated by the reactor. Herefore, the change does not involve a significant reduction in a margin of safety. 3.4.7 Changr12 m
- l. Does the change involve a significant increase in the probabilltfor consequences of an accident previously evaluated?
Note 2 to ITS LCO 3.4.7 permits periodic Surveillance tests to be performed on one of the SDC loops when both SDC loops are credited for meeting the LCC. This Note provides operational flexibility by allowing two hours before entering the Action statement. The note is acceptable, because: a) the note requires one SDC loop to be Operable and in operation. The forced coolant circulation provided by one SDC loop is sufficient to remove decay heat in Mode 5 with the loops filled; and b) the Operators will be focused on the status of SDC while operating under the provisions of this note. Thus, in the event the required SDC loop becomes inoperable or ceases to be in operation, the Operators would take action in a short period of time to restore a SDC loop to an Operable status and place it in operation. Note 4 to ITS LCO 3.4.7 provides for the transition to Mode 4 and permits an RCP to be in operation to replace the reactor coolant circulation function provided by the SDC loop. This proposed change is acceptable, because: a) the note does not permit the required SDC loop to be inoperable; it only permits it to not be in operation. Thus, if required, the SDC loop could be returned to service in a short period of time; b) the note requires an RCS loop to be in operation to provide forced circulation in place of the SDC loop; c) the Steam Generators are required to be Operable in accordance with LCO 3.4.7, thus, decay heat removal via natural circulation vould be available; and d) ITS SR 3.0.4 requires the surveillances for LCOs to be met prior to entry into a Mode or other specified condition in the Applicability of the LCO. ITS LCO 3.4.6 provides the Mode 4 requirements regarding the RCS loops. This LCO requires two loops i consisting of any combination of RCS and SDC loops to be Operable and at least one loop to be
- in operation. ITS SRs 3.4.6.1, 3.4.6.2, and 3,4.6.3 provide the surveillances which establish operability. These SRs are required to be met within their frequency prior to entering the Mode 4
of Applicability for ITS LCO 3.4.6 (i.e., Mode 4). Thus, when a traasition to Mode 4 is planned, two loops capable of providing forced circulation of the RCS would be Operable. These proposed changes will not alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. l
~
CALVERT CLIFFS - UNITS 1 & 2 3-4-12 Revision 5 l I
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM 2. Does the change create the possibiht! of a new or different Idad of accident from any previously evaluated? These proposed changes will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed changes will not introduce any new accident initiators. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
He margin of safety is establ!shed through the design of the plant structmes, systems and 3 componentr, the parameters within which the plant is operated, and the establishment of the setpoints for the actuation of equipmenticlied upon to respond to a event. He proposed changes do not significantly impact the condition or performance of structures,~ systems or con'ponents relied upon for accident mitigation. The proposed changes do not impact any safety enalysis assumptions. Therefore, they do not involve a significent reduction in a margin of safety. 3A.8 Change 11
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
Improved Technical Specification 3.4.8 will add a note to CTS LCO 3.4.1.3 which permits one required SDC loop to be inoperable for up to two hours for Surveillance ter.ing, provided the other SDC loop is Operable and in operation. This note provides operational flexibility by aliowing two hours before entering the Action statement. The note is acceptable, because: a) the nota requires one SDC loop to be Operable and in operation, ne forced coolant circulation provided by one SDC loop is sufficient to remove decay heat in Mode 5 with the loops not filled; and b) the Operators will be focused on the status of SDC while operating under the provisions of this note. Thus, in the event the required SDC loop becomes inoperable or ceases to be in oneration, the Operators would take action in a short period of time to restore a SDC loop to an Operable status and place it in operation. This proposed change will not alter assumptions relative to the mitigation of an accident or transient. The proposed change does not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
This proposed change will not involve a significant change in de' sign or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The margin of safety is established through the design of the plant structures, systems and components, the parameters within which the plant is operated, and the establishment of the setpoints for the actuation of equipment relied upon to respond to a event, The proposed change does not significantly impact the condition or performance of structures, systems or components CALVERT CLIFFS - UNITS 1 & 2 3-4-13 Revision 5
NO SIGNIFICANT llAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM relied upon for accident mitigation. The proposed change does not impact any safety analysis assumptions. Therefore, it does not involve a significant reduction in a margin of safety. 3A.9 Chance L.1
- 1. Does the change involve a significant increase in the probsbility or consequences of an accident previously evaluated?
He proposed change increases the allowed outage time, when one bank of pressurizer heaters are inoperable for reasons other than an inoperable power source, from no time to 72 hours. The loss of one bank of pressurizer heaters is not an initiator of any analyzed event. The pressurizer pressure is still capable of being maintained with the non-emergency power-supplied heaters and one remaining bank of emergency powered heaters. Also, the likelihood of an event occurring in 72 hours which would require the heaters powered from an emergency pmer source is unlikely. ' ' The change will not alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
The proposed change increases the allowed outage time, when the pressurizer heaters are inoperable for reasons other than an inoperable power source, from a shutdown track to 72 hours. The change will not involve a significant change in design or operation of the plant. No-hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators, Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The proposed change increases the allowed outage time, when the pressurizer heaters are inoperable for reasons other than an inoperable power source, from a shutdown track to 72 hours. Pressure control is still available using the normal plant power supplied pressurizer heaters and the one remaining bank of emergency-supplied heaters. It is unlikely that an event will occur during the 72-hour period which would require the pressurizer heaters, it is also possible that this change would prevent a plant shutdown, which is a transient that places thermal stress on safety components and could cause plant upset. Therefore, the change does not involve a - significant reduction in a margin of safety. 3A.9 Chance T.3
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change deletes the requirement to limit pressurizer level to less than 210 inches when three charging pumps are running with less than 25 gpm letdown flow. The change deletes a condition that places the plant in an analyzed accident scenario. This change will not significantly increase the probability of an accident. Pressurizer level is not an initiator of any analvmd event. The deletion of this requirement will not significantly increase the consequences of an accident. If the three charg:ng pumps are running with less than 25 gpm letdown flow, the CALVERT CLIFFS - UNITS 1 & 2 3-4-14 Revision 5
- 15. The ISTS markups for ITS 3.4.7 and 3.4.8 and their Bases were revised by changing the references to "SDC train" or "SDC trains" to "SDC loop" or shutdown cooling (SDC) " loops,"
respectively. These changes ensure consistency regarding the references to the SDC loops. These changes were made to respond to an NRC comment (ITS 3.4.7 Comment 3). l _----.-----,-------m- -- - - -
RCS Loops - MODE 5. Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops - MODE 5 Loops Filled LC0 3.4.7 One shutdown cooling (SDC) loop shall be OPERABLE and in operation, and either:
- a. One additional SDC loop shall be OPERABLE; or
- b. The secondary side water level of each steam generator
,, (SG) shall be 2: 50 inches. -+r -
....................-._-._. NOTES.-------..........-__...s._
- 1. The SDC pump of the loop in operation may be not in 5-operation for s 1 hour per 8 hour period provided:
- a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is maintained at least 10 F f below saturation temperature.
- 2. One required SDC loop may be inoperable for up to 2 hours for surveillance testing provided that the other SDC loop is OPERABLE and in operation.
- 3. No reactor coolant pump (RCP) shall be started with any RCS cold leg temperature s 365'E (Unit 1), s 301*F (Unit 2)unless:
- a. The pressurizer water level is s 170 inches;
- b. Pressurizer pressure is s 300 psia (Unit 1),
s 320 psia (Unit 2); and
- c. The secondary side water temperature in each SG is s 30 F above each of the RCS cold leg temperatures.
- 4. All SDC loops may be not in operation during planned heatup to MODE 4 when at least one RCS loop is in operation.
CALVERT CLIFFS . UNITS 1 & 2 3.4.7-1 Revision g g
RCS Loops - H0DE 5. Loops Filled B 3.4.7 8 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.7 RCS Loops - MODE 5, Loops Filled BASES BACKGROUND In MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and the
-transferofthisheateithertothesteamgenerator(SG) secondary side coolant or the component cooling water via the shutdown cooling (SDC) heat exchangers. While the principal means for decay heat removal is via the SDC System, the SGs are specified as a backup means for redundancy. Even though the SGs cannot produce ~ steam in this MODE, they are capable of being a heat sink due to their large contained volume of secondary side water. As long as the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will occur. The rate of heat transfer is directly proportional to the temperature difference. Due to the non-condensible gasses that come out of solution and restrict flow through the SG tubes, the SGs can only be ciedited when the RCS is capable of being pressurized. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid.
In MODE 5 with RCS loops filled, the SDC loops are the principal means for decay heat removal. The number of loops 5 in operation can vary to suit the operational needs. The intent of this LC0 is to provide forced flow from at least one SDC loop for decay heat removal and transport. The flow provided by one SDC loop is adequate for decay heat removal. The other intent of this LC0 is to require that a second path be available to provide redundancy for decay heat removal. The LC0 provides for redundant paths of decay heat removal capability. The first path can be an SDC loop (i.e., SDC loop No.11 or No.12 for Unit No.1, and SDC loop No. 21 or S No. 22 for Unit No. 2) that must be OPERABLE and in CALVERT CLIFFS - UNITS 1 & 2 8 3.4.7-1 Revision 9'y
I RCS Leops - MODE 5, Loops Filled l B 3.4.7 BASES This LC0 is modified by a Note that prohibits boron dilution when SDC forced flow is stopped because an even concentration distribution cannot be ensured. Core outlet temperature is to be maintained at least 10*F below saturation temperature, so that no vapor bubble would form and possibly cause a natural circulation flow obstruction. In this MODE, the SG(s) can be used as the backup for SDC heat removal. To ensure their availebility, the RCS loop flow path is to be maintained with subcooled liquid. In MODE 5, it is.sometimes necessary to stop all RCP or SDC forced circulation. This is permitted to change operation from one SDC loop to the other, perform surveillance or startup testing, perform the transition to and from the SDC, or to avoid operation below the RCP minimum net positive suction head limit. The time period is acceptable because natural circulation is acceptable for decay heat removal, the reactor coolant temperature can be maintained subcooled, and boron stratification affecting reactivity control is not expected. Note 2 allows one SDC loop to be inoperable for a period of up to 2 hours provided that the other SDC loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop auring the only time 5' when such testing is safe and possible. Note 3 requires that the following conditions be satisfied before an RCP may be started with any RCS cold leg temperature s 365*F (Unit 1), s 301*F (Unit 2):
- a. Pressurizer water level must be s 170 inches;
- b. Pressurizer pressure s 300 psia (Unit 1), s 320 psia (Unit 2); and
- c. Secondary side water temperature in each SG must be s 30 F above each of the RCS cold leg temperatures.
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.7-3 Revision #5
? RCS Loops - MODE 5. Loops Filled-B 3.4.7-e BASES Satisfying the above conditions will preclude opening a PORV during a pressure transient when the RCP is started. Note 4 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting SDC loops to not be in operation when at least one RCP is in operation. 6 This Note provides for the transition to MODE 4 where an RCP is permitted to.be in operatior, and replaces the RCS > circulation function provided by the SDC loops. An OPERABLE SDC loop is composed of an OPERABLE SDC pump and 5 an OPERABLE-SDC heat exchanger. SDC pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG can perform as a heat sink'when it has an adequate water level and is OPERABLE in accordance with the_ Steam Generator Tube Surveillance Program. APPLICABILITY In MODE 5 with RCS loops filled, this LC0 requires forced circulation to remove decay heat from the core and to provide proper boron mixing. One SDC loop provides sufficient circulation for these purposes. Operation in other MODES is covered by: LC0 3.4.4, -"RCS Loops - MODES 1 and 2;" LC0 3.4.5, "RCS Loops - MODE 3;" LCO 3.4.6, "RCS Loops - MODE 4;" LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled;" LC0 3.9.4, " Shutdown Cooling (SDC) and Coolant Circulation - High Water Level" (MODE 6); and LC0 3.9.5, "ShutdownCooling(SDC)andCoolant ISrculation - Low Water Level" (MODE 6). CALVERT-CLIFFS - UNITS 1 & 2 B 3.4.7-4 Revisionfff
RCS Loops - MODE 5, LCops Filled l B 3.4.7 BASES ACTIONS A.1 and A.2 If the required SDC loop is inoperable and any SGs have secondary side water levels < -50 inches, redundancy for heat removal is lost. Action must be initiated imediately to restore a second SDC loop to OPERABLE status or to restore the water level in the required SGs. Either Required Action A.1 or Required Action A.2 will restore redundant decay heat removal paths. The imediate Completion Times reflect the importance of maintaining the availability of two paths for decay heat removal. 4 B.1 and 8.2 If no SDC loop is in operation, except as permitted in Note 1, all operations involving the reduction of RCS boron concentration must be suspended. Action to restore one SDC loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing and the margin to criticality must not be reduced in this type of operation. The immediate Completion Times reflect the importance of maintaining o,neration for decay heat removal. I SURVEILLANCE SR 3.4.7.1 REQUIREMENTS This SR requires verification every 12 hours that one SDC loop is in operatior,. Verification includes flow rate. l6 temperature, or pump status monitoring, which help ensure that forced flow is providing decay heat removal. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation is within safety analyses assumptions. In addition, control room indication and alarms will normally indicate loop status. CALVERT CLIFFS - UNITS 1.& 2 B 3.4.7-5 Revision 45
RCS Loops - MODE 5. Loops Not filled B 3.408 BASES minimum of one running SDC pump meets the LCO requirement for one loop in operation. An additional SDC loop is required to be OPERABLE to meet the single failure criterion. Note 1 permits the SDC pumps to not be in operation for s 15 minutes when switching from one loop to another. The circumstances for stopping both SDC pumps are to be limited to situations when the outage time is short and the core outlet temperature is maintained at least 10"F below r saturation temperature. The Note prohibits boron dilution or draining operations when SDC forced flow is stopped. Note 2 allows one SDC loop to be inoperable for a period of f 2 hours provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be perfonned on the inoperable loop during the only time when these tests are safe and possible. An OPERABLE SDC loop is composed of an OPERABLE SDC pump capable of providing forced flow to an OPERABLE SDC heat exchanger, along with the appropriate flow and temperature instrumentation for control, protection, and inoication. Shutdown cooling pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the SDC System. Operation in other MODES is covered by: LC0 3.4.4, "RCS Loops - MODES 1 and 2;" LC0 3.4.5, "RCS Loops - MODE 3;" LCO 3.4.6, "RCS Loops - MODE 4;" LCO 3.4.7, "RCS Loops - HODE 5, Loops Filled;" LCO 3.9.4, "ShutdownCooling(SDC)andCoolant Circulation - liigh Water level" (MODE 6); and CALVERT CLIFFS - UNITS 1 & 2 B 3.4.8-2 Revision 55 l
RCS Loops - MODE 5. Loops Not Filled B 3.4.8 BASES LCO 3.9.5, Shutdown Cooling (SDC) and Coolant Circulation - Low Water Level" (MODE 6). ACTIONS &d If the required SDC loop is inoperable, redundancy for heat r: - removal is lost. Action must be initiated imediately to restore a second loop to OPERABLE status. The Completion l 5' Time reflects the importance of maintaining the availability of two paths for heat removal. B.1 and B.2 If no SDC loop is OPERABLE or in operation, except as provided in FMe 1, all operations involving the reduction of RCS boron concentration must be suspended. Action to restore one SDC loop to OPERABLE status and operation must be initiated imediately. Boron dilution requires forced circulation for proper mixing and the margin to criticality must not N reduced in this type of operation. The immediate Completion Time reflects the importance of maintaining operation for decay heat removal. SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours that one SDC loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing decay heat removal. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation is within safety analyses assumptions.
-CALVERT CLIFFS - UNITS 1 & 2 ~ B 3.4.8-3 Revision gf
RCS Loops - MODE 5. Loops Not Filled 8 3.4.8 BASES SR 3.4.8.2 i Verification that the required number of loops are OPERABLE I L ensures that redundant paths for heat removal are available and that additional loops can be placed in operatinn, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and indicated power available to the required pumps and valves that are not in operation. The T l Frequency of 7 days is considered reasonable in view of ! other administrative controls available and has been shown i to be acceptable by operating experience. REFERENCES None. CALVERT CLIFFS - UNITS 1-& 2- B 3.4.8-4 Revision O f
RCS Loops-MODE 5. Loops filled drs> 3.4.7 3.4 REACTOR C00LMT SYST[M (RC$) 3.4.7 RCS Loops-M00C 5. Loops' FI)1ed (3,4,t3)LC03.4.7 Oneshutdowncoo'ing($0C) operstlen, and o'ther shall be CPCRABLE and in
<>.4 m ) 4. one tuinonsi see O shan 6e Optssui .r nstw b.
The se:9ndary side watentawal af anch steam generator e se . t41 oes t.,t
' (5G) :t.sil bepsnar e.fropua ~~
-N0T[$.--[w[Ls iVedom . ..
f$1T./53
#""' 1. The $DC pumoJt theJeeft in anaration mar 4 "'
o . ElbewerDIS for i 1 hour per 8 hour perloc provi e t l (3.4.4 3- a. ermitted that would cause No o!erations redo tion of the R are b5 boron concentration: and
- b. Core outlet temperature is maintained.at least 10'F below saturat aperature.
NEv/
- m. s y)
- t. One required $DC I hou may be inoperable for up to g
for surveillance testing provided that the other b o t. t.. t. 500 Pig.BLEandinoperation. , g .g %;,
- 3. No reactor to 1Wt D shall be started with 3W
- t. 4 t.1 A g*u.MA
$th geh.w @
a. The pressurizer water level sQtt er lhe secondary side water tem erature in att -
" l:C""i above each of the kCS cold le Mf*M3 ape tures. " -
[
- 4. A C 6f" t,4 "A styhuurra trom operation during D't L. t planned heatup to MODE 4 when at least one RCS loop is in operation. -
h, Irf 68**itte fitf84.g i6 f APPLICABILITY: MODE 5 with RCS loops filled. ' CtoG STS 3.4 13 Rev 1, 04/07/95
c RCS toops-MODE l, Loops Filled B 3.4.7 8 3.4 REACTOR COOLANT $YSTEN (RCS) B 3.4.7 RC$ loops-M000 5, Loops Filled 8A$[$ BACKGROUND in MODE 5 the $ loops filled the primary function of the react coolant is the removal of decay heat and M'# transfer this heat either to the steam generator secondary side coolant or the component cooling terwa(56) via the shutdown cooling heat exchangers. While the vv principal means forcay de($DC) heat removal is via the $0C T
- het, h 444 system, the $Gs are specified as a backup means for i
redundancy, tven though the $Gs cannot produce steam in rom .ndena.Lle, Iettes e M c m *.A eC ! their lar$e contained volume of secondary 1 long as t e SG secondary side water is at a lower As side water.this MODE, they Mb n .4, 44 [ temperature than the reactor coolant, heat transfer will i g g,g g,,,)O (4 occur._ The rate of heat transfer is directly proportional g4 Oh e to the temperature cirrerence.F The secondary function of ' f*S un enQ L. 4 f the reactor neutron coolant poison, boricisacid to act as a carrier for soluble O D' 'M *Ma O inh 0DE5withRCfloopsfi e, khe$DC XC$ h pI,1,Q,p principal means i or decay heat r<noval. are the The number of k pref urhcl in operat' on can vary to . . ult the operational needs.
.he intent of th s LCO is to pra
'e_ e least one $0C W 4n for decay ha tide forced flow from at h,,c, # @ IC'i O
/**g The flow provided by one SDC +ee6e is adequate for dreayst # et ,, g, b
. heat removal. The other intent of this LCO is to require d ll 0 removal n and transport.
4*+)3pc,,loop that a second path be available to provide redundancy for - dg( t{o l W #. p . decay heat removal. C,DC.go ti ;,l o r 4 M ' g V au' k O' l g g ( The LCO provides for redundant paths of decay het removal
,, o c. loof capablitty. The first path can be an 500 Ignat must be N', ')
OPERABLE and in operation.
't
; .F pp k gp OPERABLE $0C adequate water vel, The second or through the SGs,each cabe pathha another ing an c K. Io b edf APPLICABLE SAFETY ANALYSES In MODE 5 RCS circulation is considered in the detennination of the time available for mitigation of the accidental this boron dilution event. The SDC circulation, provide g
(continued) Cl0G $15 8 3.4 30 Rev1,04/07/95 1
RC$ toops-MODE 6 Loops Filled 0 3.4.7 BA$ts APPLICABLE SAFE 1V ARAI,V$t$ (continued) NRC reduction Policy Statement as important contributors to riskRCS Loops-M g LCO ( E s* %<) The out pose f thi SDC W ees OPE LCO 1s'to require at least one of the G) 50C LE and in operetton with an additional p e- lcscq be t EPWt' or secondaryMda water level af and 1A ID*P _ (m)_\ i - circulatten u}@pn lM the SOC safet We41n provides surrlctent forced coolant undet U UAttions. y functions of the reactor normallt maintat The second SOC 4ee9e is
$0C kann to prov-; 'S*'RABLE o a backup t> theeera"ina However, if the s- ce recunaans ains vor c< < ay n, andby SDC ""g--Tis not vi napti,,at4rieeval.
sufficient altern 1 decay heat remova its method to provide redundant paths for ! l is two $4s with their secondary side water levels 4415). _2_ Should the operating SDC Ween rail, the SGs could d to remove the decay heat. MfV 1-Not 1 permits f .. ed I g gg DC pumps toiwdaAnam 8 h ur period. The circumstances for stopp ng ooth1 SDC 23gs hour per temperature allowable pressure increases can be maintained well within theare to be lietted to temperature overpres(pressure and temperature and low sure protection and 10'F subcooling 11stts, or an alternate heat remova)l path through the SG(s) is in operation. This LC0 is modified by a Note that prohibits boron dilution when SDC forced flow is stopped because an even concentration distribution cannot be ensured. temperature is to be maintained at least 10'F belowCore outlet saturatton temperature, so that no vapor bubble would form and possibly cause a natural circulation flow obstruction. In this heat MODE, the $G(s) can be used as the backup for $0C removal. ' flow path is to be aTo ensure their availability, the RCS loop ined with subcooled itquid. In MODE 5, it ti some forced circulat on. s necessary to stop all RCP or 50C from one SOC tm4n to the other, perform surveillance orThis is permitted to chan startup testing or to avoid oper,ation below the RCP minimum net positiveperfore the transitio suction head limit, lhe time period is acceptable because h natural circulation is acceptable for decay heat removal, (continued) CEOG STS B 3.4-31 Rev1,04/07/96
RCS toops-MODE 5. Loops f t11ed B 3.4.7 BASES LC0 the reactor coolant temperature can be maintained subcooled (continued) and boron stratification affecting reactivity control is nol expected, b , Note t allows one $0C be noperab1 > for a period of up to 2 hours provided that the et er SDC 4% is OPERABLE and in operation. This permits per odic surveillance tests to be performed on the inoperable W4e during the only time when such testing is safe and possible. Note S Nguires that ctth: :f the fo11owing4weconditions be satisfied before an RCP may be tiaria wIth any RCS cold leg temperature s.(y}'f a f5d UJn a. w u.s y @ Pressurizer water level aunwe(M)N ee 6 Moi . l Secondary side water temperature in each SG must be hava h of the RCS cold leg temperatures.
-;;'{
Satisfying et t. m THe above conittions will preclude a l i n :r r: ...; pressure :;::t i: t. . ::- I 4
'N "k h transienLdy the RCP is started. P6W d"'
Note! 4p es for an orderly transitio from MODE 5 to I MODE i4 during a planned heatup by ermitt ng talEYITTB SDC M operation when at less one R ) is in operation. lMRCP This~N@ote provides for the transition to PODE 4 where an is permitted to be in operation and replacos the RCS circulation function rovided by the SDC k W s. 4* ^
- An OPERABLE SDC d . composed of an OPERABLE SDC pump g
La. in and an OPERABLE SDC heat exchanger. 74.rr,/g3 SDC pumps .re OPERABLE if they are capable of being powered and are able to provide flow if required. An OPERABLE SG can perform as a heat sink when it has an adequate water ' level and is OPERABLE in accordance with the SG Tube Surveillance Program. APPLICABIL11Y In MODE 5 with RCS loops filled, this LC0 requires forced circulation to remove decay heat from the core and to provide proper boron atting. One SDC sufficient circulation for these purposes. provides h
, i pof (continued)
CEOG $15 0 3.4 32 Rev 1. 04/07/95 t,. u.* ,~,- e ;;; ','lgpa @
~
RCS Loops-MODE 5. Loops filled B 3.4.7 BASES APPLICABILITY Operation in other M0005 is covered by (continued) LC0 3.4.4 LCO 3.4.5,, 'RCS Loops-MODE 3't'RCS Loops-MODES 1 and I't . LCO 3.4.6 'RCS Loops-MODE 4* LCO 3.4.8,, 'RCS Loops-MODE 5 ;too LC0 3.9.4, ?5hutdown Cooling ,$0C)ps Not Ft11ed's and Coolant Circulation-High(Water Level' (MODC 6); and and coolant
, LC0 3.9.5, ,
' shutdown Circulation-Low Wate Cooling ($00) Level' (MODE C, 6)
,N, ACTIONS A.1 and A.f If the required 50C 6pa m i ina>erable~andanySGshave redundancy for heat secondary removal is lost.side Actionwaterst belevel in < (M}lttated tenedtately ,
to rutore a second SDC . the water level in the required SGs.to 0PERABLE Either Requiredstatus or to restore Action A.) or Required Action A.2 will restore redundant decay heat removal paths. The immediate Completion Times reflect the importance of maintaining the availability of two paths for decay heat removal. B.1 and B.2 \cef If no 5 is in operation, except as permitted in Note conc
. all operations involving the reduction of RCS boron tration must be suspended.
Action to restore one SDC to OPERABLE status and operation must be initiated. Baron dilution requires forced circulation for proper mixing and the type margin to criticality must not be reduced in this of operation. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. ' SURVEILLANCE $R 3.4.7.1 REQUIREMENTS This $R requires verification every 12 hours that one 500
- Acela is in operation. Vertf tcation includes flow rate A
/oop temperature, or pump status monitoring, which help ensur,e g that forced flow is providing decay heat removal. The (continued)
CEOG STS B 3.4-33 Rev 1. 04/07/95 c
RCS Loops-M00C 5, Loops Not filled p re B 3.4.8
- y,g, h & in Opathkos '
- xx + 1575 153 LC0 (continued) Note 1 pemits the 500 pumps toud-e- %.a for ,
s 15 minutes when switching from one tes4m se another. a4 la o-circumstances foroustoppinka out1H temperatu7re: TaTI both SDC to situations when the is e itp%:rtftand The are to be 11mited the core @ temperature operationsben o}f-SDC Theforced Noteflow 10'F below saturation prohibits boren dilution or draining
@ d I
]
is stopped.
, 2 hoursThis operation. provided perutts period that the other it;i.1is OPERABLE j and ' nNote 2 4
' performed on the inoperable the during survet11ance tests to be the only time when j ~
these tests are saf n ossible.' 1 An OPERABLE SDC 4 capable of composed of an OPERABLE SDC pump ' exchanger providing forced flow to an OPERABLE SDC heat
- instrumentation for controlalong with the appropriate flow and temperature protection, and indicatten SDC pumps are OPERABLE if t$ey are capablered and are able to provide flow if required.
of being powe. APPLICABILITY In MODE 5 with loops not filled this LCO requires core heat removal and coolant circulation,by the SDC System. Operation in other M00E5 is covered by: LC0 3.4.4, 'RCS Loops-MODES 1 and 2't LCO 3.4.5, 'RCS Loops-MODE 3't LCO 3.4.6, 'Rt3 Loops-MODE 4't LCO 3.4.7, 'RCS Loops-MODE 5 LCO 3.9.4, ' Shutdown Cooling . Loops filled't i I Circulation-High(Water Level' SOC)andCoolant LC0 3.9.5, ' Shutdown Cooling (SOC) and Coola(ntMODE6) and Circulation-Low Water level' (H00C 6). . ACTIONS L.1 koop If the required SDC m og removal is lost. is inoperable redundancy for heat @ restore a seconaeein to OPERABLE status. Action must Q[, 1he Completion of two paths for heat removal. Time reflects the importance of maintaining the ava g be initialed tunedtately to (continued) CEOG STS B 3,4 36 Rev1,04/07/95
1 RC$ Loops-MODE 5 Loops Not filled B 3.4.8 BASES ACTIONS B.1 and B.f 6ep (continued) if no $DC provided in Note 1, a is OP LE or in operation, except as Oc operations involving tht reduction of RCS boren concen tion must be suspended. Action to resten one 50C to OPERABLE status and operation must be initiated tamediately. Boron dilution requires forced circulation for proper mixing and the margin to criticality must not be reduced in this type of operation. The immediate Completion Time renects the importance of .3,. , maintaining operation .'or decay heat removal. SURVE!LLANCE $R 3.4.8.1 . cop REQUIREMENTS . This requires verification every !! hours that one SOC 1 6 is in operation. Vertftcation includes flow rate. - temperature or pump status monitoring, which hel that forced, flow is providing decay heat removal.p ensure The 12 hour Frequency has been shown by operating practice ti be sufficient to regularly assess degradation and verify operation is within safety analyses assumptions.
$R 3.4.8.2 \g p3 g Verification that the equired number of 4 4*s are OPERABLE @
ensures that redundant paths for heat removal are available and that additional 4edes can be placed in operation, if needed to maintain decay heat removal and reactor coolant circulation. breaker alignment and indleated cower availableo.nd required pumps? The frequency of 7 days is consicerca to theVerification vc h isgiperform S jM e 40p O reasonable in view of other administrative controls available and has been shown to be acceptable by operating g oI .r u. W, , expertence. REFERENCES None.
?
CC00 STS- 0 3.4-37 Rev1,04/07/95 F
-.. , - - - y m , , , - _ . . ~ . , -__y,_,--.,m.--- ...- ._,, -----..-e,_..-,.r-- .m- r . . .cm- e_,..',,_---#,
- 16. Improved Technical Specification SRs 3.4.7.3 and 3A.8.2 and their llases have been changed from "the required SDC pump that is not in operation" to "the required SDC loop components that are not in operation." The markups for CTS SR 4A.l.3.1 for ITS LCOs 3.4.7 and 3 A.8 have been revised from " pumps and [SDCJ loop valves" to " loop components," and DOCS LA.2 for ITS 3.4.7 and ITS 3A.8 have been changed to reflect these revisions and their associated applications to the Ilases. The same changes have been made to the ISTS markup for ITS SRs 3A.7.3 and 3.4.8.2. To justify these deviations, JFD 33 to Section 3.4 has been provided.
Additionally, the markup of the ISTS liases for ITS SRs 3.4.7.3 and 3 A.8.2 have been revised to redect the changes made to the ITS SRs. These deviations were justified using existing JI'Ds 2 and 13 to Section 3A. 'lhese changes were made to respond to NRC comments (ITS 3.4.7 Comment 4 and ITS 3 A.8 Comment 2). Additionally, while responding to the aforementioned NRC comments, it was discovered that the same issue existed in the markups and justifications for ITS 3.4.6. Thus, the same changes were made to the markups of C1S SR 4.4.1.3.1 for ITS 3.4.6, DOC LA.2 for ITS 3A.6, the ISTS markup for rfS SR 3 A.6.3, and the ISTS 11ases markup for ITS SR 3.4.6.3,
RCS Loops - MODE 5 Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS (continued) SURVE1LLANCE FREQUENCY SR 3.4.7.2 Verify required SG secondary side water 12 hours level is > -50 inches. SR 3.4.7.3 Verify correct breaker alignment and 7 days j indicated power available to the required SDC loop components that are not in operation. 5 ,, CALVERT CLIFFS - UNITS 1 & 2 3.4.7-3 RevisiongS
RCS Loops - H0DE 5 Loops Not Filled 3.4.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required SDC loops B.1 Suspend all Imediately inoperable, operations involving reduction of RCS QB boron concentration. No SDC loop in 6EQ operation. J B.2 Initiate action to Imediately i restore one SDC loop to OPERABLE status , and operation. ' SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one SDC loop is in operation. 12 hours SR 3.4.8.2 Verify correct breaker alignment and 7 days indicated power available to the required SDC loop components that are not in 5 operation. L CALVERT CLIFFS - UNITS 1 & 2 3.4.8-2 Revision #S-
RCS Loops - MODE 5. Loops Filled B 3.4.7 BASES The SDC flow is established to ensure that core outlet temperature is maintained sufficiently below saturation to allow time for swapover to the standby SDC loop should the operating loop be lost. SR 3.4.7.2 Verifying the SGs are OPERABLE by ensuring their secondary side water levels are h -50 inches ensures that redundant heat removal paths are available if the second SDC loop is-inoperable. The Surveillance is required to be performed when the LC0 requirement is being met by use of the SGs. If
-both SDC loops are OPERABLE, this SR is not needed. The-12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within safety analyses assumptions.
SR 3.4.7.3 Verification that the second SDC loop is OPERABLE ensures thac redundant paths for decay heat removal are available. The requirement also ensures that the additional 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 available to the required pumps and valves that are not in-operation. The Surveillance is required to be performed g when the LC0 requirement is being met by one of two SDC loops, e. . both SGs have < -50 inches water level. 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, t CALVERT CLIFFS - UNITS 1 & 2 B 3.4.7-6 Revisiong5
RCS Loopa - HODE 5 Loops Not Filled B 304.8 BASES SR 3.4.8.2 Verification that tw: required number of loops are OPERABLE I l ensures that redundant paths for heat removal are available and that additional loops can be placed in operation, if l- needed, to maintain decay heat removal and reactor coolant i circulation. Verification is perfonned by verifying proper l ' breaker alignment and indicated power available to the required pumps and valves that are not in operation. The f Frequency of 7 days is considered reasonable in view of other admini t'ative controls available and has been shown to be acceptable by operating experience. REFERENCES None I
\
l CALVERT CLIFFS - UNITS 1 & 2 B 3.4.8-4 Revision O f
RCS Loops - H0DE 4 3.4.6
$URVEILLANCE REQUIREMENTS ,
SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RCS or SDC loop is in operation. 12 hours SR 3.4.6.2 Verify secondary side water level in 12 hours l requiredSG(s)is>-50 inches. SR 3.4.6.3 Verify correct breaker alignment and 7 days indicated power available to the required loop components that are not in operation. g CALVERT CLIFFS - UNITS 1 & 2 3.4.6-3 Revisiongg i
. - - - -.~.- -- - - .- - - - -
r l RCS Loops - MODE 4 ! B 3.4.6 t BASES initiated. Boron dilution requires farced circulation for proper mixing, and the margin to criLcalMy must not be reduced in this type of operation. The insnediate Completion l Times reflect the importance of decay heat removal. The ! action to restore must continue until one loop is restored , to operation. SVRVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours that one , required loop is in operation. This ensures forced flo'l 1s providing heat removal. Verification includes flow rate, temperature, or pump status monitoring. The 12 hour Frequency has been shown by operating practice to be ; sufficient to regularly assess RCS loop status. In i addition, control room indication and alarms will normally indicate loop status. ' s SR 3.4.6.2 - l This SR requires verification every 12 hours of secondary i side water level in the required SG(s) > -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 hour interval has been shown by operating practice to be sufficient to regularly assess degradation _ and verify operation within safety analyses assumptions. ' SR 3.4.6.3 4 Verification that the required pump is OPERABLE ensures that i an additional RCS or SDC 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 available to the required loop g components that are not in operation. For an RCS loop, the CALVERT CLIFFS - UNITS 1 & 2 8 3.4.6-5 Revisionpr
?
i
. ,, _ ,___ - .._ -,.._.. ._...,_._ _ . ..._ ... L. _ __, _ _., , . _ _:_.,-,._..._._._..__._._-_.~./
RCS Loops - H0DE 4 8 3.4.6 BASES required component is a pump. For an SDC loop, the required g components are the pump and valves. The Frequency of 7 days is considered reasonable in view of other administrative I controls available and has been shown to be acceptable by operating experience. REFERENCES None . l CALVERT CLIFFS - UNITS 1 & 2 8 3.4.6-6 Revisiongy
S e4 < ifst ib 3, g 3/M _^r^ a
***' i!Yi?" -
~~
M LIMITING CONDITION FOR OPERAT! M (Continued) b %. involving With noa reduction coolantinloop boron in4 eratton,of suspend concentration erations all ofhe Reactor C-Coolant Systus and initiate corrective action to return the required coolant loop to operation M*Ma e2'-"- i'[kb O PE R A 61.0 $Da
,. SURVEILLANCE H QUIREMENTS e -
- C~~ '
h j;bd ryg "Y' 3, g,1 W loop s fr'.1be shall "A 11"onments The detemin re!d utredJPL " sJ Q 51days y)v,eif not in operation, LEoncY 0=; cand indicated power availability f rQrb;ifying r- a corvet ~ tet breaker M 4,44,4t6 The reqr tred steamqgenerator q" -
2'Is (s). F " " '-'-- j d\. " g,9g" 3 A 4,'a 3.4.1.3.- A.
water le7e1 to be above 50 inches at least once per 12 hours,shall te detemine s n. 4.4.1.3.3 At least one coolant too shall be vertited to be in operation gna -ci rcu s a u nt-react o r-cooient] a t east once per 12 hours, k CALVERT CLIFFS UNIT 1 3/4 4 5 Amendment No. 169 t
Spu.C ou .. 3. 4. 6 2l^.^ "'~m'"'""~- LIMITING COSITION FOR OPERATIt (Continued) ACTich) C % With no coolant involving a reduction in oNrat'on. auspend rations loopHn all o ron concentration of he Reactor Coolant System and inttlate corrective action to return the required coolant loop to operation .'U,ih ,-i~y. _
'?T '* f d N.3 A
. SURVE!LLANCt_ REQUtttMtwTs pee $.Ut I b 6d h ' '
N ., . . . . . ;
- 4. 4. . . ; . "r 3 4 +$*3 The required #^: c _::: Sloop s), if wt in operation. I 'N thallbedeterminedOPERA78 once per 7 days vertfying correct breaker alignments and indicated power availability f - -e.tr M_~_1 ; 2::
- g i g f,gc,
- 2 4d.i.i.s The required steam generator '- s).-""C "" "P$$2*b l
5.'J.S.;,- shall be determined OPERABL!(by vert'ytng the secondary ~ side, water level to be above .50 inches at least once per 12 hours. Q
%R l 3* 4.6. I 4 4.1.3.3
.A. 4 mw . - - m; - :ner er:AtMdat leastleast one once coolanu perloop LA'1-shall be vertfled to be in operation 12 hours.
CALVERT CLIFFS . UNIT 2 3/4 4 5 Amradment No. 149 Q @ i
DISCUSSION OF CilANGES SECTION 3.4;6 - HCS LOOPS MODE 4 contain the optic, , bring the plant to Mode 5, corrective action to restore the required coolant loops to an UPERABLE status can always be initiated within the Completion Time; thus, the option to cooldown to Mode 5 is never required to be invoked. While Action C of ITS 3.4.6 does not contain a requirement to place the unit in Mode 5, it is equivalent to Action a of CTS 3.4.1.3 because its shutdown requirement is never required to be invoked. Action C of ITS 3.4.6 provides a more restrictive course of action than Action a of CTS 3.4.13, because, in addition to requiring the initiation of corrective action to restore the loops to an OPERABLE status, it requires the suspension of all operations involving a reduction in boron concentration of the RCS, ne more restrictive action to suspend all I operations involving a reduction in boron concentration of the RCS is appropriate. In most scenarios with no coolant loops OPERADLE, there will also be no forced flow. Without forced flow, proper mixing would not occur. Run, if boron dilution was occurring, slug of water with a significantly reduced boron concentration could develop. Rese slugs could lead to reactivity excursions. This requirement will ensure that this does not occur. To incorporate Action C ofITS 3.4.6, Action b of CTS 3.4.1.3 was modified to apply to the condition of no coolant loops OPERABLE, Currently, Action b of CTS 3.4.1.3 only applies when no coolant loops are in operation. It essentially contains the same actions as Action C ofITS 3.4.6. TEC11NICAL CilANGES - RELOCATIONS None TECIINICAL CilANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.I Current Technical Specification LCO 3.4.1.3.a lists the loop numbers (reactor coolant and / SDC) required to be Operable and defines the components which comprise an Operable RCS loop. Improved Technical Specification 3.4.6 LCO will require two reactor coolant or SDC loops to be Operable, ne specific RCS and SDC loop numbers and the definition of an Operable RCS loop will be moved to the Bases. This is acceptable, because ITS 3.4.6 will continue to require two cooling loops to be Operable, nroughout the ITS, the Bases usually describe the contents of the system and the specific requirements of the system contents. His infonnation can be adequately controlled in the Bases. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement for two coolant loops to be Operable. This change is a l less restrictive movement of information change with no impact on safety. This change is consistent with NUREG 1432. LA.2 Current Technical Specification SR 4.4.1.3,1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specification SR 3.4.6.3 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.1.3.1 has been modified by replacing the phrase "SDC pump and valves" with the phrase loop I components." The Bases ofITS SR 3.4.6.3 will be revised to identify the loop components CALVERT CLIFFS - UNITS 1 & 2 3.4.6-4 Revision 5
DISCUSSION OF CHANGES SECTION 3.4.6 - RCS LOOPS . MODE 4 that will be required to be tested. Relocation of this information to the Bases is acceptable, because ITS SR 3.4.6.3 will continue to require the required SDC pump and valves that are not in operation to be tested. Throughout the ITS, the Bases usually describe the contents of the system and the specific requirements of the systern contents. The Bases will be maintained in accordance with the Bases Control Program in ITS Chapter 5.0. This approach. l provides an etTective level of regulatory control and provides for a more appropriate change I control process. The le <cl of safety of facility operation is unaffected by the change, because i the SR will continue to require the verification of the correct breaker alignment and indicated power available to the required SDC pump and valves that are not in operation. LA.3 Current Technical Specification SR 4.4.1.3.3 requires the coolant loops to be verified in l operation and circulating reactor coolant. The requirement to circulate reactor coolant is
.y
~
being moved to the ITS 3.4.6 Bases. Specific requirements for verifying that a reactor coolant or SDC loop is in operation will be located in the Bases or plant procedures, as appropriate. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert Cliffs change control process. The Bases Control Program and the Calvert Cliffs change control process will ensure that any changes to this requirement will receive an appropriate review. This change is consistent with NUREG 1432. TECIINICAL CIIANGES - LESS_HFSTRICTIVE Li Not used. l CALVERT CLIFFS - UNITS 1 & 2 3.4.6-5 Revision 5
~ RCS LoQs-M00C 4 3.4.6 hTh $URytillANCE RIOUIREMENTS (continued)
$URVtlLLANCE FREQUDici (4 4,p,g,j/MR 3.4.6.3 Verify correct breaker alignment and indicated ower available to the required 7 days I ' that not in operation.
- r. -
, w .. 'a y loop corrf onuY
-_ s l
4 , t . i. */.1. 1 1 l CEOG STS 3,4-12 Rev1,04/07/95
RC5 Loop 8-- { BA$t$
$URVElllMCE SR 1.4.6.3~
REQUIREMENTS (continued) Vertf tcation that the required p 6 an additional RCS 4eep or $0C is OPERABLE can ensures that be placed in operation, reactor coo lant etetuistion.1f needed to eatntain decay heat removal and verifying the requi breaker alignment and power available toVerification is perfoned by l reasonable i The Frequency of 7 days is considered ew of other administrative controls. available and
. expertence. its been shown to be acceptable by operating REFERENCES None.
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- W v mp> o.ab Uo~ U*3' e~
CE0G STS B 3.4 29 Rev 1. 04/07/95
.5(ac[it. hon 3.4.'7 3/4.4 REACTOR COOLANT $YSTEM LINITINGCONDITIONFORAPERATION(Continued)
R b. With no op in o involvingareductioninberation,suspendalloperations g oron concentration of the Resctor foolant System and initiate corrective action to return the
, aquired coolant loop to operation 't'.' : : 'r.
J 7 , SURVEILLANCE REQUIREMENTS . O i.i.:.%1 The required shutdown cooling loop (s), if not in operation,
),43.1 shall be detennined OPERABLE once per 7 days by verif t ing correct breaker ' O GO MM oitonments
^
and indicated power Ld6pf:es5p availability fordiuRM @ IN8'METdiUP@ $
' "12 h _ __. . .. steam oenerator(s) d t ': i:':: _::d i: =eO 1 4'71 M MAINS tall be determinea ortusi.L oy ver1Fylng the secondary side water level to be above -50 inches at least once per 12 hours.
{*1 5A 1,4,1, I
- e. .;.0.0 At leas
@ " rr" un ne - t:::- one=::..c.)st loo shall be verified to be in operation east once per 12 hours. h D
CALVERT CLIFFS . UNIT 1 3/4 4-5 Amendment No. 169 pay 3 sF3
$ p*c'.( .c A .'.,a 3.4 . 7 3/4.4 kEACTOR C00Uuff $YSTDI LIMITIM Com! TIM FOR OPERATIM (Coettaued) w a+d.
With M"oo ent1 A C* tie M b. o retton, suspend all o rations involvino a reducti n in Nron coheentration of fhe Reactor 6 Coo 1W tvstem and inttiste corrective action to return the required cwi6.it loop to operation -MM g.: h:; _. _ __
- - - ~ -
M. '$ SURVE!LLAllCE kt0UtttMENTS SR e.f.:.:.; The required shutdown cooling loop s), if not in operation 4 . 9 . 7.3 shall be determined OPERA 8LE once per 7 days verifyinn co (g o and indicated power availability Wapd @rrect breakerstHQJfspL A, _ M669 EvfNp%M SR . Th: . 61.-) steam generator (sb iLii i. ,,,;, ..;; '- -A A.I b 3.4.7."2 A- wr ievel to be above -5naii ne *7 side esasturmines at least onceortansLE per 12 hours.by verTiying sne secondary SR A_A *** At least one = '.... oop shall be Verified to be in operetton
- 3. 4. "?. I fd 9"ac -': :::d: at least once per 12 hours.
1 I CALVERT CLIFFS - UNIT 2 3/4 4-5 Amendment No. 149 P'* ry* 3oF 3
DISCUSSION OF CilANGES SECTION 3.4,7 -- RCS LOOPS . MODE 5 LOOPS FILLED l additional testrictions on plant operation constitutes a more restrictive change. This camnge is consistent with NUREO 1432. M.3 Current Technical Specification 3.4.1.3 Action b requires the initiation of corrective actions within one hour to return the required coolant loop to Operable status when no coolant loop is in operation, improved Technical Specification 3.4.7 Action B will require immediate initiation of corrective action. This change, which requires immediate initiation of corrective action, reflects the importance of decay heat removal. This change will not adversely affect plant safety because it ensures the immediate initiation of action to restore decay heat removal. The addition of this more stringent requirement constitutes a more restrictive change. This change is consistent with NUREO 1432. TICIINICAL CIIANGES - RFI OCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification LCOs 3.4.1.3.a.3 & 4 list the SDC loop numbers required to be Operable improved Technical Specification 3.4.7 LCO will require two SDC loops or one SDC loop and both SGS to be Operable, but the ITS will not list specific loop numbers. The speellic loop numbers are being moved to the Bases. This is acceptable because moving this requirement to the Bases will not affect the requirement for the specific loops to be Operable.1hroughout the ITS, the Bases usually describe the contents of the system. The loop numbers can be adequately controlled in the Basesswhich require change control in accordance with the Bases Control Program provided in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unalTected by the change because there is no change in the requirement for two coolant loops to be Operable. This change is a l less restrictive movement of information change with no impact on safety. This change is consistent with NUREG 1432. LA.2 Current Technical SpeciF. cation SR 4.4.1.3.1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specification SR 3.4.7.3 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.1.3.1 has been modified by replacing the phrase "SDC pump and valves" with the phrase " loop components." The Bases ofITS SR 3.4.7.3 will be revised to identify the loop components that will be required to be tested. Relocation of this information to the Bases is acceptable, because ITS SR 3.4.7.3 will continue to require the required SDC pump and valves that are not in operation to be tested. Throughout the ITS, the Bases usually describe the contents of the system and the specific requirements of the system contents. The Bases will be maintained in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change, because the SR will continue to require the verification of the correct breaker CALVERT CLIFFS - UNITS 1 & 2 3.4.7 3 Revision 5
DISCUSSION OF CHANGES SECrlON 3.4.7 - RCS LOOPS o MODE 5 LOOPS FILLED alignment and indicated power available to the required SDC pump and valves that are not in operation. l LA.3 Current Technical Specification SR 4.4.1.3.3 requires the coolant loops to be verifled in operation and circulating reactor coolant. The requirement to circulate reactor coolant is being moved to the ITS 3.4.7 Bases. Specific requirements for verifying that the reactor coolant loop is in operation will be located in the Bases or plant procedures, as appropriate. l Any changes to the Bases will be in accordance with the Bases Control Program in ITS l Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert l ClllTs change control process. The Bases Control Program and the Calvert Cliffs change control process will ensure that changes to this requirement will receive an appropriate 4 _& review, nls change is consistent with NUREG 1432. O TECllNICAL CIIANGES - IIRS H5'ETRICTIVE L.) Current Technical Specification LCOs 3.4.1.3.a.1 and 2 require the reactor coohnt loops, their associated SGs, and at least one associated RCP to be Operable if used to satisfy the LCO. Improved Technical Specification 3.4.7 will only require that the secondary side water level of each SO be h .50 inches if used as the backup system to the required SDC train. This is acceptable in Mode $ with the loops filled because even though the SGs cannot produce steam, they are capable of being a heat sink due to the large contained volume of secondary side water. Forced cooling using the RCPs is not required because natural circulation occurs, which is sumclent to remove the small heat load in the reactor core until a SDC train can be made available. A plant specific calculation was developed to verify that the SGs could be used for decay heat removal. The calculation was performed in response to NUMARC Guidance Document 9106, Guidelines for Industry Action to Assess Shutdown Management, ne calculation considers or determines the maximum core decay heat generation rate, total primary to secondary heat transfer area, heat transfer coeflicients, relative primary and secondary temperatures, total natural circulation flow rate, and combined SG ambient heat loss rate, as wc!! as other considerations. The calculation determines that a SO level of 2 $0 inches with the associated RCS loop filled is sufficient to remove the generated decay heat load. %is change is consistent with NUREG 1432. L.2 Two notes are being added to CTS LCO 3.4.1.3. These notes permit: a) one required SDC loop to be inoperable for up to two hours for Surveillance testing, provided the other SDC loop is Operable and in operation; and b) all SDC loops to be removed from operation during planned heatup to Mode 4 when at least one RCS loop is in operation. Note 2 to ITS LCO 3.4.7 permits periodic Surveillance tests to be perfonned on one of the SDC loops when both SDC loops are credited for meeting the LCO. His note provides operational flexibility by allowing two hours before entering the Action statement. The note is acceptable, because: a) the note requires one SDC loop to be Operable and in operation. The forced coolant circulation provided by one SDC loop is sufficient to remove decay heat in Mode 5 with the loops filled; and b) the Operators will be focused on the status of SDC while operating under the provisions of this note. Rus, in the event the required SDC loop becomes inoperable or ceases to be in operation, the Operators would take action in a short period of time to restore a SDC loop to an Operable status and place it in operation. CALVERT CLIFFS UNITS 1 & 2 3.4.7 4 Revision 5
, n
S p.. .fu. ch e4 3.4.9 3/474--IttAff9R-400MNT-5V5 FEM LIMITING CONDITION FOR OPERATION t (Continued) fk_ A Wtth ho 1 in o tratton suspend all operations Ac 6 involving a redu ton in boron con, centration of the Reactor g Coolant system nd initiate corrective action to return the required loop to operation Mt" ::: bn-cwnut .sh s l )\ks\
$URVEILLANCE REQUIREMENTS 3A L2. -414drid-The required shutdown cooling loopid, if not in operation.
shall be dettnetned OPERABLE once per 7 days Fy verifying correct breaker
- allonments and Indicated power availability for@mnsAna str :::P -- A GP#M /.S 4 .~4 .1. 3. The required st t (jf'{p g , g 4 fp
' generator (s) it is being used meet -
['3. 4.1. . shall be det ned CPERABLE erifying the seco side hate evel to be abo _. 50 inchet at 1 tt once Dec 12 rytys u
~4.4.i.3.3* At least one MS,) &a ei :ut' ; re :ter ::::r.Ota.t$loo east once per 12 Kurs,shallbevertfled4Eeinoperation t
CALVERT CLIFFS - UNIT 1 3/4 4-5 Amendment No. 169
Spec. h w , 3.4.g 3/4d-AEAETet "L'_"" :YETE LIMITING CONDITION FOR OPERATIM (Coatiased) _ QC
% With 4 loop in operation suspendalloperations Ar'~'U o ti a reduction in boren con, centration of the Reactor p, Sg% 000 ant ystem and initiate corrective action to return the required# ~wt loop tq'operetton witua - Wr.
.1 Q47pi[y}
SURVEILLANCE REQUIREMENTS - - - -
--s
,---- p N
4.4.1.3.1 The required shutdown cooling 100 if not in operation. T. 4 3.7. shall be detenmined OPERA 8LE once per 7 days y verifying correct breaker l nts and indicated power availability orc =: "- - t' ~ nna kb-cop-v 14es. Q QQ g
'I 4.4.1.3<f' The required st generator (s),i t is being used 3.4#.3.a. shall be date ined OPERABLE by meef ~
ifying the secon ry side fer level to be abov -50 (nches at le once per 12 hou j 4.a.1.1.1 At least "one _k_ 3hloo 3 4.St ) (M ei wi.uim ..ecie, eee'M at feast once per 12 hours.shall be verified to be in operation L ___ g I , CALVERT CLIFFS - UNIT 2 3/4 4-5 Amendment No. 149
DISCUSSION OF CIIANGES SECTION 3A;8 - RCS LOOPS - MODE 5. LOOPS NOT FILLED TECIINICAL DOCUMENTS CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED I LA.1 Current Technical Specification LCOs 3.4.1.3.a.3 & 4 list the SDC loop numbers required to be Operable. Improved Technical Specification 3A.8 LCO will require two SDC loops Operabic, but the ITS will not list specific loop numbers. He specific loop numbers are being moved to the Bases. This is acceptable because moving this requirement to the Bases l will not affect the requirement for the specific loops to be Operable. Throughout the ITS, the Bases usually describe the contents of the system. His information can be adequately controlled in the Bases. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0. Als approach provides an effective level of regulatory a control and provides for a more appropriate change control process. He level.of safety of facility operation is unaffected by the change because there is no change in the requirement for two coolant loops to be Operable. This change is a less restrictive movement of l information change with no impact on safety. His change is consistent with NUREG-1432. LA.2 Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specification SR 3.4.8.2 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.1.3.1 has been l modified by replacing the phrase "SDC pump and valves" with the phrase " loop components." The Bases ofITS SR 3.4.8.2 will be revised to identify the loop components that will be required to be tested. Relocation of this information to the Bases is acceptable, because ITS SR 3.4.8.2 will continue to require the required SDC pump and valves that are not in operation to be tested. Throughout the ITS, the Bases usually describe the contents of the system and the specific requirements of the system contents. The Bases will be maintained in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change, because the SR will continue to require the verification of the correct breaker alignment and indicated power available to the required SDC pump and valves that are not in operation. LA.3 Cmient Technical Specification SR 4.4.1.3.3 requires the coolant loops to be verified in operation and circulating reactor coolant. The requirement to circulate reactor coolant is being moved to the ITS 3,4.8 Bases. Specific requirements for verifying that the reactor coolant loop is in operation will be located in the Bases or plant procedures, as appropriate. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert Cliffs change control process. The Bases Control Program and the Calvert Cliffs change control process will ensure that changes to this requirement will receive an appropriate review. This change is consistent with NUREG 1432. TECHNICAL CIIANGES - LESS RESTRICTIVE L.1 Improved Technical Specification 3.4.8 will add a note to CTS LCO 3.4.1.3 which permits one required SDC loop to be inoperable for up to two hours for Surveillance testing, CALVERT CLIFFS - UNITS I & 2 3.4.8-3 Revision 5
RCS Loops-MODE 5, Loops Filled 4,s> , 3.4.7 SURVEILLMCE REQUIREMENTS SURVEILLMCE FREQUENCY g SR 3.4.7.1 Verify one 500 is in operation . 12 hours A. I .12. R 3.4.7.2 Verify required SG secondary side water 1 , vel is 4 ;- 12 hours n SR 3.4.7.3 Verify correct breaker alignment and (4'4')'g, 7 days indl .atedt gower at available to the required SDC peration, e ea I i CEOG STS 3.4-15 Rev1,04/07/95
~
\ _ _ _
RCS Loops-MODE S Loops Filled B 3.4.7 BASES-
. SURVEILLANCE-REQUIREMENTS SR 3.4.7.1L(continued) 12 hour Frequency has been shown by operating practice to be sufficient to mgularly assess degradation and verify operetten is within safety analyses assumptions. In additten, loop status. control room indication and alarms will nomally indicate 'c/ co The SOC flow is estabitsbed to ensure .that core outlet ....,y'.
temperature is maintained sufficiently below saturation o t'*' '- l allow time for swapover to the standby SOC should the operating Q be lost. - SR 3.a.7.2 5tJhh Verifying tl e SGs are ope @ side water ' evels are t LE by ensuring their secondary )p removal pati ensures that Mdundant heat inoperable. s are avalla le f the second 50C 4cesa is The Survalliance is mquired to be performed when the LCD requirement is being met by use of the SGs. If both SDC 44es are OPERABLE, this SR is not needed.( The 12 hour Fregiiency has been shown by operating practice to be
-sufficient to regularly assess degradation and verify-operation within safety analyses assumptions.
SR -3.a.7.3 - 80l* Verification that the set ond SDC is OPERABLE nsures-that redundant paths for The requirement also enst decay heat removal are av lable. res that the additional .can- ' be placed in operation.-if needed to maintain decay heat removal and reactor coolantcirculation. Verification is performed by require available to the verifying
< proper breaker aliennent and power "J[Nunob pumpsC The survettlance is required to be performed when the LCO requirement is bei k' peti met by one of two SDC tes4ae, e.g., both SGs have <
water level. The Frequency of 7 days is considered 50ia reasonable in view of other administrative controls @ available and has been shown to be acceptable by operating - experience. REFERENCES- None. CEOG STS B 3.4-34 Rev 1,-04/07/95 4
RCS Loops-MODE 5. Loops Not Filled 3.4.8 f(fs) ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
- 8. Required SDC B.1 Suspend all inoperable, !amediately operations involving OO reduction of RCS DB Atb s boron concentration. l
' No SDC in 8HQ operation. 8.2 Initiate action to lunedtately
- .J restore one SDC .
to OPERABLE status and operation. g p S ' i SURVEILLANCERE0dlREMENTS SURVEILLANCE FREQUENCY (4.4.1.13 SR 3.4.8.1 Verify one SDC is in operation. 12 hours h SR 3.4.8.2 Verify correct breaker alignment and 7 days indicated power available to the required (ki'lill) SDC that @ not in operation.
- M-
\ an a b CEOG STS 3.4-17 Rev 1, 04/07/95 1
' -~--
RCS Loops-MODE 5. Loops Not Filled B 3.4.8 BASES ACTIONS B.1 and B.2 (continued) If no SDC provided in Note is of RCS boron conce, 1 OPERABLE or in operatton, except as 1 operations involving the reduction h i tion must be suspended. Action to restore one SDC to OPERABLE status and operation must be initiated immedtately. Boron dilution requires forced circulation for proper mixing and the margin to criticality must not be reduced in this type of operation. The immediate Completion Time reflects the importance of A, maintaining operation for decay heat removal. SURVEILLANCE SR 3.4.8.1 oop REQUIREMENTS This requires vertftcation every 12 hours that one SDC 6 is in operation. Verification includes flow rate - temperature, or pump status monitoring, which help ensur.e that forced flow is providing decay heat removal. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation is within safety analyses assumptions. SR 3.4.8.2 \q3 g Verification that the equired number of @ ensures that redundant paths for heat removalasare are OPERABLE available and that additional 4edes 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 indicated nower available to the required pumpM The Frequency of 7 days is constaereo cud A W ' h / f.i}g reasonable in view of other administrative controls tQ omarwh i n Go[e h available and has been shown to be acceptable by operating expertence. REFERENCES None.
=
CEOG STS B 3.4-37 Rev 1, 04/07/95
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM 31. The Actions for NUREG-1432 LCO 3.4.1 were modified to reflect the action requirements of CTS 3,1.5 for RCS cold leg temperature not being within limits. He Action for CTS 3,1.5 requires the restoration of RCS cold leg temperature to within limits, or Thermal Power be reduced to less than 5% of Rated Hermal Power (i.e., Mode 2). The Action for CTS 3.1.5 is the same regardless of which parameter (i.e., pressurizer pressure, RCS flow rate, or RCS cold leg temperature) is out of limits. Thus, Action A of ITS 3.4.1 provides the requirements for restoration of the parameter, and Action D ofITS 3.4.1 provides the requirements for exiting the mode of applicability in the event the parameter cannot be restored to within limits within-- two hours. 32. In NUREG-1432 LCOs 3.4.1.a and 3.4.1.b, the limits for pressurizer pressure and RCS cold leg temperatw are expressed in ranges. In ITS LCO 3.4.1.a,mnly a minimum limit is established for pressurizer pressure. This Ilinit is consistent with the initial assumption regarding pressurizer pressure in the Calvert Clifts accident analysis. This limit was approved by the NRC in License Amendment No. 88 to Facility Operating License No. DPR-53 for Unit No,1, and License Amendment No. 61 to Facility Operating License No. DPR-69 for Unit No. 2. In ITS LCO 3.4.1.b, only a maximum limit is established for RCS cold leg temperature. This limit is consistent with the initial assumptions regarding RCS cold leg temperatu c in the Calvert Cliffs accident analysis. This limit was approved by the NRC in License Amendment No. 39 to ' Facility Operating License No. DPR-53 for Unit No.1, and License Amendment No. 9 to Facility Operating License No. DPR 69 for Unit No. 2. Thus, these deviations are consistent with the current licensing basis for Calvert Cliffs.
- 33. NUREG-1432 SRs 3.4.6.3,3.4.7.3, and 3.4.8.2 require the verification of the correct breaker alignment and indicated power available to the required pump that is not in operation.
NUREG 1432 SR 3.4.6.3 applies to the RCS and SDC pumps, while NUREG 1432 SRs 3.4.7.3 and 3.4,8.2 only apply to the SDC pumps. Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignments and indicated power availability for the required shutdown cooling pumps and valves that are not in operation. NUREG-1432 SRs 3.4.6.3, 3.4.7.3, and 3.4.8.2 have been modified to reflect the additional requirement to verify the correct breaker alignments and indicated power availability for the required shutdown cooling valves, which is consistent with the Calvert Cliffs current licensing basis. These SRs were modified by replacing the word " pump" with the words " loop components." The components required to be checked by the SRs will be denoted in the Bases. For the RCS loop, the required component is the RCS pump. For the SDC loop, the required components are the pump and the valves. -- 34. NUREG-1432 5R 3.4.11 A requires the veritication that the PORVs and block valves are capable of being powered by an emergency power supply. This surveillance does not exist in CTS 3/4.4.3. Improved Technical Specification 3.4.1I will not contain a surveillance to verify that the PORVs and block valves are capable of being powered by an emergency power supply. This is appropriate, because the PORVs and block valves are permanently powered by Class lE power supplies. Class IE power sources are backed-up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under-voltage condition. The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied - by a Class IE power source (e.g., the safety injection systems) do not contain SRs to verify the CALVERT CLIFFS-UNITS 1 & 2 3.4-8 Revision 5
- 17. Discussion of Changes LA.1 for ITS 3.4.7 and 3.4.8 were revised to state that the speciGe loop numbers are being moved to the Bases. The ISTS markup of the Bases for ITS 3.4.7 and 3.4.8 were revised to include the required information. These changes have been made to respond to an NRC comment (ITS 3.4.7 Comment 6 and ITS 3.4.8 Comment 1).
RCS Loops - MODE 5, Loops Filled B 3.4.7 B 3,4 REACTORCOOLANTSYSTEM(RCS) ' B 3.4.7 -RCS Loops - MODE 5, Loops Filled BASES BACKGROUND In MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and the transfer of this heat either to the steam generator (SG) secondary side coolant or the component cooling water via L the shutdown cooling (EDC) heat exchangers. While the
- principal means for decay heat removal is via the SDC l System, the SGs ark specified as a backup means for l
redundancy. Even though the SGs cannot produce' steam in t this MODE, they are capable of being a heat sink due to their large contained volute of secondary side water. As long as the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will occur. The rate of heat transfer is directly proportional to the temperature difference. Due to the non-condensible gasses that come out of solution and restrict flow through the SG tubes, the SGs can only be credited when the RCS is capable of being prasurized. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. In MODE 5 with RCS loops. filied, the SDC loops are'the principal means for decay heat removal.. The number of icops 5 in operation can vary to suit the operational needs. _The
, intent of this LCO is to provide forced flow frok ht least one SDC loop for decay heat removal and transport. The flow provided by one SDC loop is adequate for decay heat removal.
The other intent of this LC0 is to require that a second path be available to provide redundancy for decay heat removal. The LC0 provides for redundant paths of decay heat removal capability. The first path can be 'an SDC loop (i.e., SDC
-loop No. 11 or No. 12 for Unit No. 1, and-SDC loop No. 21 or g No. 22 for Unit No. 2) that must be OPERABLE and in CALVERT CLIFFS - UNITS 1 & 2 8 3.4.7-1 Revision g 5
WCS Loops - MODE 5 Loops Filled B 3.4.7 BASES operation. The second path can be another OPERABLE SDC loop (i.e., SDC loop No.11 or No.12 for Unit No.1, and SDC y loop No. 21 or No. ?2 for Unit No. 2), or through the SGs, each having en adequate water level. APPLICABLE In MODE 5 RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the - accidental boron dilution event. The SDC loops provide this circulation. RCS Loops - MODE 5 (Loops Filled) have been identified in 10 CFR 50.36(c)(2)(ii) as important contributors to risk reduction. l LC0 The purpose of this LCO is to require at least one of the SDC loops be OPERABLE and in operation with an additional SDC loop OPERABLE or secondary side water level of each SG l shall be 2 -50 inches. One SDC loop provides sufficient forced circul? tion to perform the safety functions of the reactor coolant under these conditions. The second SDC loop is normally maintained OPERABLE as a backup to the operating SDC loop to provide redundant paths for decay heat removat. However, if the standby SDC loop is not OPERABLE, a sufficient alternate method to provide redundant paths for decay heat removal is two SGs with their secondary side water levels 2 -50 inches. Should the operating SDC loop fail, the SGs could be used to remove the decay heat. Note 1 permits all SDC pumps to not be in operation s I hour per a hour period. The circumstances for stopping both SDC loops are to be limited to situations where pressure and temperature increases can be maintained well within the allowable pressure (pressure and temperature and low temperature overpressure protection) and 10*F subcooling limits, or an alternate heat removal path through the SG(s) is in operation. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.7-2 Revision #S I
DISCUSSION OF CHANGES SECTION 3.4,7 - RC1 LOOPS MODE 5 LOOPS FILLED i additional restrictions on plant operation constitutes a more restrictive chrnge. This change is consistent with NUREG 1432. MJ Current Technical Specification 3.4.13 Action b requires the initiation of corrective actions within one hour to return the required coolant loop to Operable status when no coolant loop is in operation. Improved Technical Specification 3,4.7 Action B will require immediate initiation of corrective action. His change, which requires immediate initiation of , corrective action, reflects the importance of decay heat removal. This change will not adversely affect plant safety because it ensures the immediate initiation of action to restore decay heat removal, ne addition of this more stringent requirement constitutes a more restrictive change. His change is consistent with NUREG 1432. TECIINICAL CIIANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Current Technical Specification LCOs 3.4.13.a3 & 4 list the SDC loop numbers requhrd to be Operable. Improved Technical Specification 3.4.7 LCO will require two SDC loops or i one SDC loop and both SGs to be Operable, but the ITS will not list specific loop numbers. The specitic loop numbers are being moved to the Bases. This is acceptable because moving ' this requirement to the Bases will not affect the requirement for the specific loops to be Operable. Throughout the ITS, the Bases usually describe the contents of the system. *lhe locp numbers can be adequately controlled in the Basess which require change control in accordance with the Bases Control Prcgram provided in ITS Chapter 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement for two coolant loops to be Operable. This change is a l less restrictive movement ofinformation change with no impact on safety. This change is consistent widi NUREG-1432. LA.2 Current Technical Specification SR 4.4.13.1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specification SR 3.4.73 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.13.1 has been modified by replacing the phrase "SDC pump and valves" with the phrase " loop components." The Bases ofITS SR 3.4.73 will be revised to identify the loop components that will be required to be tested. Relocation of this information to the Bas:s is acceptable, because ITS SR 3.4.73 will continue to require the required SDC pump and valves that are not in operation to be tested. Throughout the ITS, the Bases usually describe the contents of the system and the specific requirements of the system contents. The Bases will be maintained in accordance with the Bases Control Program in ITS Chapter 5.0. This approach provides an effective level of regulatory control and providu for a more appropriate change control process. The level of safety of facility operation is unaffected by the change, because the SR will continue to require the verification of th: correct breaker CALVERT CLIFFS - UNITS 1 & 2 3.4.7-3 Revision 5
RCS Loops-MODE 5, Loops Filled B 3.4.7 8 3.4. REACTOR COOLANT SYSTEM (RCS) B 3.4.7 RCS Loops-MODE 5. Loops Filled BASES BACKGROUND in MODE 5 h the loops filled, the primary function of f Y the react coolant is the removal of decay heat and transfer this heat either to the steam generator (SG) secondary side coolant or the component cooling water via heat exchangers. While the the shutdown principal cooling means for decay(SDC) heat removal is via the SDC ve System, the SGs are specified as a backup means for he,h4b- redundancy. Even though the SGs cannot produce steam in me a.ndensMe Igues this MODE, they are capable of being a heat sink due to i their large contained volume of secondary side water. As
-c44C- ) long as the SG secondary side water is at a lower bk.bn .=A m4d l temperature than the reactor coolant, heat transfer will (4
I occur._ The rate of heat transfer is directly proportional pg N N, g,,,)O e- to the temperature cirrerence.~e The secondtry function of
- i the reactor coolant is to act as a carrier for soluble I3 S$ scan ,,lq L I neutron poison, boric acid
'N *Ma A InMODE5withRCkloopsfilTed, kheSDC are the KCs j,, PIA Q ,p principal means 1 or decay heat ri moval. The number of in operat' on can vary to .uit the operational needs.
- k. prtH vehel he intent of th s LCO is to prc ride forced flow from at O least one SDC tm+n for decay heat removal and transport. (r,,c, # SDC l0OP
/o## The flow provided by one SDC 4eek is adequate for decay heat removal. The other intent of this LCO is to require 4 ll O f yIg Q d^;( do l
( 'iJ g pc, hop that a second path be available to provide redundancy for decay heat removal. 6 DC k ti gl o r g 4 V nib M The LCO provides for redundant paths of decay hea removal Q
' l # 2.1 ,
capability. The first path can be an SDC at must be N s DC- lON Of pp N OAi OPERABLE and in operation. The second path ca be another OPERABLE SDC
. adequate water or through the SGs, each ha ing an vel.
6 r ho APPLICABLE in MODE 5 RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the ! accidental boron dilution event. The SDC provide this circulation. (continued) CEOG STS B 3.4-30 Rev 1, 04/07/95 i
RCS Loops - MODE 5. Loops Not Filled B 3.4.8 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.8- RCS Loops - MODE 5 Loops Not Filled BASES BACKGROUNC In MODE 5 with'the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat and transfer of-this heat'to' the shutdown cooling (SDC) heat exchangers. Thesteamgenerators(SGs)arenotavailableas a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid. l In MODE 5 with loops not filled, only the SDC System can be j used for coolant circulation. The number of loops in 1
- operation can vary to suit the operational needs. The intent of this LCO is to provide forced flow from at least one SDC loop for decay heat removal and transport and to require that two paths (i.e., SDC loop No.11 or No.12 for p Unit No. 1, and SDC loop No. 21 or No. 22 for Unit No. 2) be available to provide redundancy for heat removal.
APPLICABLE In MODE 5. RCS circulation is considered in determining SAFETY ANALYSES the time available for mitigation of the accidental boron dilution event. The SDC loops provide this circulation. The flow provided by one SDC loop is adequate for decay heat removal and for boron mixing. Reactor Coolant System loops - MODE 5 (loops not filled) satisfy 10 CFR 50.36(c)(2)(11), Criterion 4. LC0 The purpose of this LC0 is to require a minimum of two SDC loops be OPERABLE and one of these loops be in operation. An OPERABLE loop is one'that is capable of. transferring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the SDC System unless forced flow is used. A CALVERT CLIFFS - UNITS 1 & 2. B 3.4.8-1 RevisionMy
DISCUSSION OF CHANGES SECTION 3A.8 - RCS LOOPS - MODE 5, LOOPS NOT FILLED TECIINICAL DOCUMENTSCHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED LA.1 Current Technical Specification LCOs 3.4.1.3.a.3 & 4 list the SDC loop numbers required to be Operable. Improved Technical Specification 3.4.8 LCO will require two SDC loops Operable, but the ITS will not list specific ioop numbers, ne specific loop numbers are being moved to the Bases, his is acceptable because moving this requirement to the Bases l will not affect the requirement for the specific loops to be Operable, nroughout the ITS, the Bases usually describe the contents of the system. This information can be adequately controlled in the Bases, Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0 His approach provides an effective level of regulatory ua. control and provides for a more appropriate change control process. He level.of safety of facility operation is unaffected by the change because there is no change in the requirement for two coolant loops to be Operable. His change is a less restrictive movement of l information change with no impact on safety. His change is consistent with NUREG 1432. LA.2 Current Technical Specification SR 4.4.1.3.1 requires the verification of the correct breaker alignment and indicated power availability for the required SDC pump and valves that are not in operation. Improved Technical Specification SR 3.4.8.2 contains the same verification requirements except it requires them to be performed for the required loop components that are not in operation. Current Technical Specification SR 4.4.1.3.1 has been modified by replacing the phrase "SDC pump and valves" with the phrase " loop components." The Bases ofITS SR 3.4.8.2 will be revised to identify the loop components that will be required to be tested. Relocation of this information to the Bases is acceptable, because ITS SR 3.4.8.2 will continue to require the required SDC pump and valves that are not-in oper stion to be tested. Throughout the ITS, the Bases usually describe the contents of the systeri and the specific requirements of the system contents. The Bases will be maintaim d in accordance with the Bases Control Program in ITS Chapter 5.0. His approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change, because the SR will continue to require the verification of the correct breaker alignment and indicated power available to the required SDC pump and valves that are not in operation. LA 3 Current Technical Specification SR 4.4.1.3.3 requires the coolant loops to be verified in operation and circulating reactor coolant. The requirement to circulate reactor coolant is being moved to the ITS 3.4.8 Bases. Specific requirements for verifying that the reactor coolant loop is in operation will be located in the Bases or plant procedures, as appropriate. Any changes to the Bases will be in accordance with the Bases Control Program in ITS Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert Cliffs change control process. The Bases Control Program and the Calvert Cliffs change control govess will ensure that changes to this requirement will receive an appropriate review. His change is consistent with NUREG-1432. TECIINICAL CIIANGES - LESS RESTRICTIVE L.1 Improved Technical Specification 3.4.8 will add a note to CTS LCO 3.4.1.3 which permits one required SDC loop to be inoperable for up to two hours for Surveillance testing, CALVERT CLIFFS - UNITS 1 & 2 3.4.8-3 Revision 5
RCS Loops-H00E 5. Loops Not Filled B,3,4 8 B 3.4- REACTOR COOLANT SYSTEM (RCS) B 3.4.8 RCS Loops-HODE 5, Loops Not filled BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary function of the reactor coolant is the removal of decay heat and transfer of th'. heat exchangers.4 The steas ?st to the shutdown cooling (SDC)le pnerators' as a heat sink when the 100,s are not(SGs) are not availab filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid. 5 f)c (oop In MODE 5 with loops not filled, only the SDC System can be top 3 ( n. . e. . ) d@ilY#c( ti nM M used for coolant circulation. The number of 4eeds in operation can vary to suit the operational needs. The intent of thit LCO is to provide forced flow from at least { NA g g 3.1 , "n lgp S c \ oof god one SDC forheat decay heat removal ano transport anu wrequire h two path [s that
& gtO/ V for removal. ,
13 tb APPLICABLE In MODE 5. RCS circulation is considered in detemining SAFETY ANALYSES the time available for mitigation of the accidental boron Ie8PJ dilution event. The 50C tro; provice snis ctreuiation. The flow provided by one SDC t-i u acequate for cecay heat removal and for boron mixing.
,lbf @
RCS loops-HODE 5 (loops not filled) have been identified in the NRC Policy Statement as important contributors to risk reduction. - LCO Io P - Th purpose this LCO is to require a minimum of two SDC be OPERABLE and one of'these be in operation. An OPERABLE tri, is one snat is capable or transferring heat from the reactor coolant at a controlled rate. Heat IC6P cannot be removed via the SDC System unless forced flow is used. A minimum of one_ running SDC pumo meets the LC0 requirement for one 4ee4e 11 o>eratton, An addit' onal SDC h t-9 is required to be OPE MB.E to meet the single failure criterion. (continued) CEOG STS B 3.4-35 Rev 1. 04/07/95
- 18. The NRC requested additionaljusti0 cation for the deletion of the requirement for the pressurizer heaters to be capable of being powered by an emergency power supply, Justification for Deviation 26 to Section 3,4 was revised to provide the additionaljustl0 cation. Additionally, the ISTS markup of the Bases for ITS 3.4.9 was revised to state, in the Background section, that the pressurizer heaters are permanently powered by Class lE power supplies, and to revise the Bases for the LCO section to be consistent with the ISTS markup for ITS 3.4.9. The changes to the Bases were justined with existing JFDs to Bases Section 3.4 (ITS 3.4.9 Comment 2),
i
Pressurizer B 3.4.9 BASES The maximum water level limit permits pressure control equipment to function as designed. The limit preserves the steam space during normal operation, thus, both sprays and heaters can operate to maintain the design operating , pressure. The level limit also prevents filling the pressurizer (water solid) for anticipated design basis l transients, thus ensuring that pressure relief devices 4 (PORVs or pressurizer safety valves) can control pressure by - l steam relief rather than water relief. If the level limits l were exceeded prior to a transient that creates a large pressurizer insurge volume leading to water relief, the maximum RCS pressure might exceed the Safety Limit of 2750 psia. The requirement to have two banks of pressurizer heaters, which are permanently powered by Class IE power supplies, 6 ensures that RCS pressure can be maintained. The-pressurizer heaters maintain RCS pressure to keep the reactor coolant subcooled. Inability to control RCS pressure during natural circulation flow could result in loss of single phase flow and decreased capability to remove core decay heat. APPLICABLE In MODES 1, 2, and 3, the LC0 requirement for a steam Dubble SAFETY ANALYSES- is reflected implicitly in the accident analyses. All analyses perfonned from a critical reactor condition assuine the existence of a steam bubble and saturated conditions in the pressurizer. In making this-assumption, the analyses neglect the small fraction of noncondensable gases-normally present. Safety analyses presented in the UFSAR_do not take credit' for pressurizer heater operation; however, an implicit initial condition assumption of the safety analyses is that-the RCS-is operating at normal pressure. Although the heaters are not specifically used in accident analysis, the need to maintain subcooling in the long term , CALVERT CLIFFS - UNITS 1 & 2 B 3.4.9-2 Revision #S-
Pressurizer B 3.4.9 BASES ( during loss of offsite power, as indicated in NUREG-0737_ (Ref.1), is the reason for their inclusion. The requirement for emergency power supplies is based on NUREG-0737(Ref.1). The intent is to keep the reactor coolant in a subcooled condition with natural circulation at hot, high pressure conditions for an undefined, but i extended, time period after a loss of offsite power. While loss of offsite. power is a coincident occurrence assumed in the accident analyses, maintaining hot, high pressure conditions over an extended time period is not evaluated in the accident analyses. The pressurizer satisfies 10 CFR 50.36(c)(2)(ii), Criteria 2 and 3. LCO The LC0 requirement for the pressurizer to be OPERABLE with water level 2133 inches and s 225 inches ensures that a steam bubble exists. Limiting the maximum eperating water level preserves the steam space for pressure control. The LC0 has been established to n.inimize the consequences of potential overpressure transients. Requiring the presence of a steam bubble is also consistent with analytical assumptions. The LCO requires two banks of OPERABLE pressurizer heaters, each with a capacity 2 150 kW. TheminimumheatercapacitylS' required is sufficient to maintain the RCS near normal operating pressure. By_ maintaining _the pressure near the operating conditions, a wide subcooling margin to saturation can be obtained in the loops. The generic value of 150 kW is derived from the use of 12 heaters rated at 12.5 kW each. The amount needed to maintain pressure is dependent on the ambient heat losses'. APPLICABILITY The need-for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature CALVERT CLIFFS - UNITS 1 & 2 B 3.4.9-3 Revisiongr
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM improved Technical Specification 3,4.9 will not contain a surveillance to verify that the pressurizer heaters are capable of being powered by an emergency power supply. Hisis appropriate, because the pressurizer heaters are permanen:ly powered by Class IE power supplies, Class IB power sources are backed up by the emergency diesel generators. He transfer from the normal power supply to the emergency power supply for these buses occurs on
- an under-voltage condition, ne transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied by a Class 1E power source (e.g., the safety iq}ection systems) do not contain SRs to verify the systems are capable of being supplied by emergency power Thus, the climination of SR 3,4.9.3 from the ITS is consistent with other specifications, Furthermore, the elimination of this SR is consistent with the 13ases of NUREG 1432 SR 3.4.9.3 which states: "This SR [SR 3.4.9.3]
applicable if the heaters are permanently powered by 1E power supplies." 22. Reference to "specified in the COLR" in SR 3.4.1.4 was deleted because the limit in the LCO is the limit tested for in the SR. Therefore, placing the value in the Core Operating Limits Report is not necessary, This change is consistent with Calvert Cliffs current licensing basis. 23. The containment sump monitor in Specification 3.4.15 was changed to containment sump level alarm. Calvert Cliffs has a containment sump level alarm system, This change is consistent with ! the current Calvert Cliffs licensing basis. l 1 24. Not used. l
- 25. Not used.
l 26, NUREG 1432 LCO 3.4.9.b requires the pressurizer to be Operable with two groups of pressurizer heaters Operable with the capacity of each group 2 [150 kW] [and capable of being powered from an emergency power supply]. Current Technical Specification LCO 3.4.4 requires the pressurizer to be Operable with a steam bubble and with at least 150 kW of pressurizer heater capacity capable of being supplied by emergency power, improved Technical Specification LCO 3.4.9 will not contain a requirement to ensure that the pressurizer heaters are capable of being cupplied by emergency power, This is appropriate, because the pressurizer heaters are permanently powered by Class 1E power supplies. Class IE power sources are backed up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under-voltage condition. He transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied by a Class IE power source (e.g., the safety injection systems) do not contain requirements in the LCOs to verify the systems are capable of being supplied by emergency power Thus, the climination of the LCO requirement from the ITS is consistent with other specifications. Furthermore, the Bases of NUREG-1432 SR 3.4.9.3 (the NUREG SR which confirms the pressurizer heaters are capable of being supplied by an emergency power) states that it is not applicable if the heaters are permanently powered by lE power supplies. This implies that the LCO requirement is also not applicable if the heaters are permanently powered by Class 1E power supplies. CALVERT CLIFFS- UNITS 1 & 2 3.4-6 Revision 5 t -
Pressurizer 8 3.4.9 BASES BACKEROUND (PORVs or pressurizer safety valves (continued) steam relief rather than water relie)f.can con' trol pressure by - If the level limits were exceeded prior to a transient that creates a large pressurizer tasurge volume leading to water relief, the saxtaus RCS pressure sight exceed the Safety Lisit of 27 0 i ' The requirenset to have t 3 ensures that RCS pressure can of pressurizer heaters maintained. The d,' t ,o pressurizer heaters maintain RCS pressure to keep the reactor coolant subcooled. Inability to control RCS ge eA 3 / pressure duri pudb A loss of sin 1 natural circulation flow could result in ig U ~ core decay le t. phase flow and decreased capability to remov g g ppjliu 3 1 APPLICABLE / In MODES 1,'t and 3, the LCO requirement for a steam bubble I SAFETY ANALYSES isgreflected
... . Implicitly
.ra in the accident analyses, t nr.,
a a- M =^9::. All analyses h performed free a critical reactor condition assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses neglect present. the small fraction of noncondensable gases nomally Safety analyses presented in theVSAR do not take credit for pressurizer heater operation; however an implicit initial h condition assuption of the safety ana, lyses is that the RCS is operating at normal pressure. Although the heaters are not specifically used in accident analysis, the need to maintain subcooling in the long ters during loss of offsite power, as indicated in NUREG-0737 (Ref.1), is the reason for their inclusion. The
- requirement for emergency power supplies is based on NUREG-0737 (Ref. 1). The intent is to keep the reactor coolant in a subcooled condition with natural circulation at hot, high pressure conditions for an undefined, but extended, time period after a loss of offsite power. While loss of offsite power is a coincident occurrence asstmed in the accident analyses, maintaining hot, high pressure conditions over an extended time period is not evaluated in
,the accident analyses.
(continued) CEOG STS 8 3.4-39 Rev 1, 04/07/95
Dressurizer 8 3.4.g SASES APPLICABLE SAFETY ANALYSES The pressurizer NRC satisfies Criterion 2 and Criterion 3 of the Policy Statement. (continued) w:= :c-LC0 M lI* k eak 1 2AS W h m ., , o .. , The water LCO requir level ' h'"nt for snr pressurizer to be OPERA 8LE with u ensures that aoperating steam bubblewater exists. level a mm Limiting the ma,xim;;um preserves the d C~ steas space for pressure control. The LC0 has been established to minimize the consequences of potentini overpressure transients. Requirino the presence of a steam bubble is also consis ith analytical assumptions. The LC0 requires two each with phtemprgeWr a caoac h k H150}*kWi[aof OPERABLE eressurizer heaters.- capac
. d from tu c4 Ae e mi.,l@aus n
. woh wu ,s sufficient to sa i in the RCS near heaterh noriaal operating pressurefwnen sccoununa "arment iosus) gnrow _the oressunzer iniul.afiori. By ma ntaining the~ a U.!)
pressure near the operating ' conditions, a wide subcooling na i Met de aturation can be obtained in the loops. The value ofM150}4W is derived from the use of 12 heaters rated at 12.5 kW each. The amount needed to @ maintain pressure is dependent on the ambient heat losses. APPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature resulting in the greatest effect on pressuriter level and RCS pressure control. Thus, Appitcability has been designated for MODES I and 2. Tho 14pitecbility is also. provided for MODE 3. the purpose is to prevent solid water RCS operation'during hentup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup. The LCO does .iot apply to MODE 5 (Loops filled) because LCO 3.4.12, ' Low Temperature Overpressure Protection (LTOP) Systea," applies. The LCD does not apply to MODES 5 and 6 with partial loop operation. In MODES 1,'t, and~S . availability of press.' there is the need to maintain the from an emergency power supply.urizer heaters capable of being powered In the event of a loss of offsite power, the initial conditions of these MODES gives i (continued) CEOG STS B 3.4-40 Rev 1. 04/07/95
19.- he NRC requested additionaljustification for the deletion ofISTS SR 3.4.9.3 from ITS 3.4.9. Justification for Deviation 21 for Section 3.4 was revised to include additional justification (ITS 3.4.9 Comment 4). c ..,.
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3A - REACTOR COOLANT SYSTEM 15. Specification 3.4.12 (LTOP System) Applicability was changed from Mode 4 when any RCS cold leg temperature is s 285'F, Mode 5, and Mode 6 when the reactor vessel head is on, to Mode 3 with any RCS cold leg temperature is s 365'F (s 301*F for Unit 2) and Modes 4,5, and 6. His change is consistent with the Calvert Cliffs requirement to have the Pressurizer Safety Valves and PORVs Operable in Modes 1 and 2, and Mode 3 with any RCS cold leg l temperatures > 365'F (> 30l*F for Unit 2), ne addition of the Note which exempts the LCO when the RCS is vented to 2 8 square inches allows the equipment for the LCO to not be applicabic when the reactor vessel head is off. Also, changes were made to the Actions consistent with the changes made to the Applicability.
- 16. NUREG-1432 Specification 3.4.14 provides requirements for RCS pressure isolation valves.
De Calvert Cliffs' ITS do not contain the requirements of thisiSpecification, except for the SR which tests the interlock that prevents the shutdown cooling system suction isolation valves from opening at a specific pressure. His SR is currently addressed as CTS SR 4.5.2.e.1, and it has been retained as ITS SR 3.5.2.9. Calvert Cliffs Unit Nos. I and 2 were licensed prior to 1979 Neither unit has any specific requirements to individually leak test any pressure isolation valve. Additionally, Calvert Cliffs was not identified by the NRC Event V order, dated April 20,1981, as an older plant that was required to add a requirement for 1 ak testing pressure isolation vuves. As described in the Calvert Clifts' response to Generic Letter 87-06, " Periodic Verification of Leak Tight Integrity of Pressure Isolation Valves," dated July 7,1987, the pressure isolation valves are either: a) periodically tested in accordance with the requirements of ASME Section XI; b) periodically tested in accordance with 10 CFR Part 50, Appendix J; or c) the pressure upstream of the valves (i.e., SI 217,227,237, and 247) is continuously monitored by i remote indication in the control room. These activities ensure the valves are meeting their pressure isolation function. Therefore, Calvert Cliffs does not need to add additional requirements to the ITS to ensure these valves are leak tested. 17. Specification 3.4.15 (RCS Leakage Detection Instrumentation) SR 3.4.15.2 Frequency is being changed from 92 to 31 days. This change is consistent with the current Calvert Cliffs Surveillance Frequency for the containment atmosphere radioactivity monitor Channel Functional Test. 18. Specification 3.4.16 (RCS Specific /setivity) Required Action A.2 Completion Time to restore the Dose Equivalent 1 131 to within limits is being increased from 48 hours to 100 hours. This change is consistent with the Calvert Cliffs current licensing basis. 89. A new Specification [ Specification 3.4.17, "Special Test Exception (STE) RCS Loops - Modes 4 and 5"] was added to Section 3.4. This new Specification is a Special Test Exception which allows LCOs 3.4.6, 3.4.7, and 3.4.8 to be suspended while performing special tests or maintenance (i.e., local leak rate testing on containment penetration 41, maintenance on valves located in the common shutdown cooling line, or maintenance on the shutdown cooling flow control valve). This Specification is consistent with the Calvert Cliffs current licensing basis. This change also resulted in changing the title of Specification 3.4.16 to include Mode 2.
- 20. Not used.
l 21. NUREG-1432 SR 3.4.9.3 requires the verification that the pressurizer heaters are capable of j being powered by an emergency power supply. His surveillance does not exist in CTS 3/4.4.4.
}
)
l CALVERT CLIFFS - UNITS 1 & 2 3.45 Revision 5
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 _ SECTION 3.4 - REACTOR COOLANT SYSTEM Improved Technical Specification 3.4.9 will not contain a surveillance to verify that the pressurizer heaters are capable of being powered by an emergency power supply. This is appropriate, because the pressurizer heaters are permanently powered by Class IE power ' supplies. Class lE power sources are backed-up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under voltage condition. The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has= been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied by a Class 1E p.)wer source (e.g., the safety injection systems) do not contain SRs to verify the systems are capable of being supplied by emergency power. Thus, the climination of SR 3.4.9.3 from the ITS is consistent with other specifications. Furthermore, the climination of this SR is w, consistent with the Bases of NUREG .1432 SR 3.4.9.3 which states: "This SR [SR 3 A applicable if the heaters are permanently powered by 1 E power supplies." '
- 22. Reference to "specified in the COLR" in SR 3.4.1.4 was deleted because the limit in the LCO is the limit tested for in the SR. Therefore, placing the value in the Core Operating Limits Report is not necessary. This change is consistent with Calvert Cliffs current licensing basis.
23. The containment sump monitor in Specification 3.4.15 was changed to containment sump level alarm. Calvert Cliffs has a containment sump level alarm system. This change is consistent with the current Calvert Cliffs licensing basis,
- 24. Not used.
l
- 25. Not used.
l 26. NUREG 1432 LCO 3.4.9.b requires the pressurizer to be Operable with two groups of pressurizer heaters Operable with the capacity of each group 2 [150 kW) (and capable of being i powered from an emergency power supply). Current Technical Specification LCO 3.4.4 requires the Pressurizer to be Operable with a steam bubble and with at least 150 kW of pressurizer heater capacity capable of being supplied by emergency power. Improved Technical Specification LCO 3.4.9 will not contain a requirement to ensure that the pressurizer heaters are capable of being supplied by emergency power. This is appropriate, because the pressurizer heaters are permanently powered by Class IE power supplies. Class IE power sources are backed-up by the emergency diesel generators. The transfer from the nomial power supply to the emergency power supply for them buses occurs on an under voltage condition. The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3,8.1. Additionally, the specifications for other systems that are supplied by a Class IE power source (e.g., the safety injection systems) do not contain requirements in the LCOs to verify the systems are capable of being supplied by emergency power. Thus, the elimination of the LCO requirement from the ITS is consistent with other specifications. Furthermore, the Bases of NUREG 1432 SR 3.4.9.3 (the NUREG SR which confirms the pressurizer heaters are capable of being supplied by an emergency power) states that it is not applicable if the heaters are permanently powered by lE power supplies. This implies that the LCO requirement is also not applicable if the heaters are permanently powered by Class 1E power supplies. 1 CALVERT CLIFFS- UNITS 1 & 2 3.4-6 Revision 5 1
- 20. Discussion of Change L.1 for ITS 3.4.10 and its associated NSilC 'were revised to include justification for: a) changing the shutdown requirements of the Action for ITS LCO 3.4.2.1 from -
llot Shutdown to Mode 3 with all RCS cold leg temperatures less than or equal to the low temperature overpressure protection (LTOP) enable temperature; and b) the deletion of Footnote
- of CTS LCO 3.4.2.1. As a result, DOC M.1 for ITS 3.4.10 was eliminated.
Additionally, JFD 9 to Section 3.4 was revised to include additional justification for deviating from the applicability ofISTS 3.4.10 in ITS 3.4.10. These changes were required to respond to NRC comments (ITS 3.4.10 Comments 1,3, and 4). Additionally, while resolving the comments, several errors were noted on the markups of the Applicability _ of CTS LCO 3.4.2.1 for ITS 3.4.10.- These errors included the incorrect LTOP enable temperature being identified in the Unit No,2 markup, and the lack of units for the LTOP enable temperature in the Unit No.1 markup. These errors were corrected. h h o f-4 k i' t Y
, __y - a .r . - , , . - . , _c . - . _ , , ,-
S e c 8'c.k e s 3. 4.1 o 3'. 4 -$/tt- AEACTOR C00LAlfT SYSTEM T. 4 . I O S/4,4rf (ETYVALVES LIMITIM CONDITIN FOR OPERATIM
~
+
isst Ai 4.,4.i. , 14.f e-L. C O 3 A 1 0 3 ' ." . ; S. Nh pressuriger code saf shall be OPERABLE: r^*Je Lift .found As Left yglyg Settina Jolerance Toleranc]e
'~
i - hg) sp i RC-200 00 p'sta' ' +2%/-1%
~ ~~
RC.201 - 1 1% Ad- A 2565 ps1a i 24 11%j) APPLICABILITY: MODE $ & hdton %
- With one pres and ]. E n 4,, g ,,4 ,,,,^^
~
9 2 yyj f C .a . h L,l O [ the rer code safety valve inoperable, either restore noperable valve to OPERABLE status within 15 minutes or be in W9f ~ ( g,b) ' within 12 hours. 7 g m e. ac . . . . .. , _ . ... .,es. .m..
. . . . . . _ _ ..__.... m .. .3. . . , _...... .u...
S hs*F _ '(jP RICABILIIVT MODE 5 4 5.T q 3 CTION: With no pre rizer code suspe all operatJ6ns involvin ety valve OPERM innedtat CPE sitive reactivjty changes and ~ LE shutdow vcooling loop)g to operation, f f acean) SURVEILLANCE REQUIREMENTS
- _ n, _- - -
- 3. 4A-? . h :dditin.;'. b vcilitaseJaa"te---t! a+har than thnea
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CALVERT CLIFFS - UNIT 1 3/4 4-6 Amendment No. 206 py 1oF 2
Sp,b.b 2. 4.t 0 3,9 -3/h+ REACTOR C00LAlfT SYSTEM TA . t O S/4.4.2 QETYVAtVES g?]YING C01tDITI0ll FOR OPERATI001 i l.(.O 3.4,IO I NSERT AppQ<.t..M Y 4; thd;; pressurizer code) Ives shall be OPERABLE: L . 7-ovt Lif As-Found As.L 1 ,M,g 11111 Sett s Tolerance
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CALVERT CLIFFS - llNIT 2 3/4 4-6 Amendment No. 184 p3e lJ2
.1)lSCUSSION OF CilANGES
- SECTION 3.4.10. PRESSURIZER SAFETV VALVES ADMINISTRATIVE CilANGES A,1 r
%e proposed change will re ormat, renumber, and reword the existing Technical Specifications, with no chnge of in:ent, to be consistent with NUREG 1432. As a result, the Technical Specifications should be more casily readable and, therefore, understandable by plant operators, as well as other users.
During the Calvert Cliffs ITS development, certain wording prderences or conventions were adopted which resulted in no techn! cal changes to the Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional information does not change the intent of the cu. Tent Technical Specifications. He reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Current Technical Specification LCO 3.4.2.1 contains the valve listing and the "As Found" and "As LefP tolerances. Improved Technical Specification 3.4.10 moves the valve listing and tolerances to SR 3.4.10.1. %c ITS also specifically lists the upper and lower lift settings for "As Found" and "As Left," based on the tolerances provided in the CTS. %c movement of requirements from the LCO to the SRs and changing the presentation of the information is considered an administrative change. A.3 Current Technical Specification 3.4.2.1 Action for Modes 1,2, and 3 requires the plant to proceed to Mode 4 in 12 hours if the Actions cannot be met. Improved Technical Specification 3A.10 Action D for Modes I and 2, and Mode 3 with all RCS cold leg tenperatures > 365'F (> 301'F for Unit 2) requires the plant to be in Mode 3 in six hours (see a more restrictive discussion of change for a description of the addition of this intermediate action), and to reduce all cold leg temperatures to s 365'F (s 30l'F for Unit 2) in 12 hours. This reflects the change in the Modes of Applicability for the Specification (see a less restrictive discussion of change fbr the description of the Mode change). His change is consistent with CTS 3.0.1 and ITS 3.0.1, which stipulate that once outside the Applicability, the 1.CO no longer applies. Therefore, this change is considered administrative. His che,ge is consistent with NUREG 1432. TECilNICAL CIIANGES - MORE RESTRICTIVE M.I Not used. j M.2 Current Technical Specification 3.4.2.1 requires an LCO 3.0.3 entry when two pressurizer safety valves are inoperable, improved Technical Specification 3.4.10 requires the plant to be in Mode 3 in 6 hours, and to reduce all RCS cold leF temperatures to s 365'F (s 301'F for Unit 2)in 12 hours. This change is considered more restrictive since an LCO 3.0.3 entry allows an additional hour to be in Mode 3 (Mode 3 in seven hours). Decreasing the time to shut down is considered a more restrictim change, however, this change will not adversely affect plant safety. His change is consistent with NUREG 1432. TECilNICAL CllANGES - RELOCATIONS None CALVERT CLIFFS - UNITS I & 2 3.4.10 1 Revision 5
E l DISCUSSION OR CilANGES l SECTION 3.4.10 PRESSURIZER SAFETY VALVES TECIINICAL CHANGES . MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCLIMAXfS None TECIINICAL CilANGES . IISS_lWNTRICTIVE L.1 Current Technical Specification LCO 3.4.2.1 and 3.4.2.2 provide the minimun, operability requirements for the pressurizer code safety valves. 1,Miting Condition for Operation 1 3.4.2.1 is applicable in Modes I,2, wt 3, and LCO .h.'. 4 is applicable in Modes 4 and 5, improved Technical Specification LCO 3.4.10 provides the minimum operability requirements for the pressurizer code safety valves. Improved "echnical Specification L 3.4.10 is applicable in: a) Modes I and 2 for Units 1 and 2, b) Mode 3 with all RCS cold leg temperatures > 365'F for Unit it and c) Mode 3 with all RCS cold leg temperatures > 301'F for Unit 2. The Applicability for CTS LCO 3.4.2.1 was revised to be consistent with the Applicability for CTS LCO 3.4.10. Current Technical Cpecification LCO 3.4.2.2, its associated footnote (i.e., footnote *), Applicability statement, and Action requirement have j been eliminated. These proposed changes are acceptable, because the pressurizer safety valves are only needed to provide overpressure protection of the RCS in: a) Modes I and 2 for Units I and 2, b) Mode 3 with all RCS cold leg temperatures > 365'F for Unit it and c) Mode 3 with all RCS cold leg temperatures > 30l'F for Unit 2. In Mode 3 with the RCS cold leg temperatures s 365'F for Unit 1 nd s 301*F for Unit 2, and Modes 4 and 5 for both Units, overpressure protection of the RCS is provided by the low temperature overpressure protection (LTOP) system. The requirements for the LTOP system are contained in ITS 3.4.12. In addition, the llases for the Applicability of NUREG 1432 LCO 3.4.10 states that the LCO is not applicable when overpressure protection is provided by the LTOP system. To support this change, the Action of CTS LCO 3.4.2.1 was revised. In the event one pressurirer code safety valve is inoperable, the Action of CTS LCO 3.4.2.1 requires the inoperable valve be restored to an Operable status or the plant be placed in llot Shutdown (i.e., Mode 4). Action 11 ofITS LCO 3.4.10 requires the plant to be placed in Mode 3 with all RCS cold leg temperatures less than or equal to 365'F for Unit i or 301'F for Unit 2t this is a condition where the ITS LCO for the pressurizer safety valves will not be applicable, and the ITS LCO for the LTOP system will be applicable to ensure overpressure protection of the RCS is available. The Action of CTS LCO 3.4 2.1 was revised to require the unit to be placed in a condition for which the LCO does not apply in the event the pressurizer safety valve could not be restored to an Operable status in 15 minutes. This proposed change is consistent with the llases of NUREO 1432 LCO 3.0.2 which states if a Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a Mode or condition in which the speelfication is not applicable. L.2 Improved Technical Specification 3.4.10 adds a Note to CTS 3.4.2.1 which allows the pressurizer safety valve lin settings to be outside the limits of the LCO for 36 hours, follo;ving entry into Mede 3 > 365'F (Mode 3 > 30l'F for Unit 2). for the purpose of setting the pressurizer safety valva lin settings under ambient conditions, provided a preliminary cold setting was made prior to heatup. *lhe Note permits testing and examination of the safety valves at high pressure and temperature near their normal operating range, but only aner the valves have had a preliminary cold setting. The cold setting gives assurance that CALVERT CLIFFS . UNITS I & 2 - 3.4.10-2 Revision 5
=
NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM plant is in en excessive charging event, which is analyzed in the Updated Final Safety Analysis Report Chapter 14 accident analyses. His change will not significantly affect the assumptions relative to the mitigation of accidents or transients, because the plant is already in the accident if in this condition. Since the deleted condition places the plant in an analyzed accident scenarlo, deleting the condition does not involve a significant increase in the probability or consequence of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any accident previously evalveted? He proposed change deletes the requirement to limit pressurizer level to less than 210 inches when three charging pumps are running with less than 25 gpm letdown flow. This change does e3 !rvolve a significant change in the design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any I new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the change involve a significant reduction in a margin of safety?
The proposed change deletes the requirement to limit pressurizer lev'el to less than 210 inches when three charging pumps are running with less than 25 gpm letdown flow. He change deletes a condition that places the plant in an accident. If the plant was in this condition, it would already be in a Updated Final Safety Analysis Report Chapter 14 analyzed accident. This condition should not be in the LCO because the LCO should not contain a condition that places the plant in an accident. %crefore, deleting an accident condition from the LCO does not involve a significant reduction in a margin of safety. MJ0_ChanacL1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The Applicability for CTS LCO 3.4.2.1 was revised to be consistent with the Applicability for CTS LCO 3.4.10, at,u the Action of CTS 3.4.2.1 was revised to be consistent with the revised Applicability. Current Technica' Specification LCO 3.4.2.2, its associated footnote (l.c., footnote '), Applicability statement, and Action requirement have been climinated. Rese p oposed changes are acceptable, because the pressurizer safety valves are only needed to provide overpressure protection of the RCS in: a) hiodes 1 and 2 for Units I and 2, b) hiode 3 with all RCS cold leg temperatures > 365'F for Unit it and c) hiode 3 with all RCS cold leg temperatures > 301*F for Unit 2. In hiode 3 with the RCS cold leg temperatures 5; 365'F for Unit I and s; 301'F for Unit 2, and hiodes 4 and 5 for both Units, overpressure protection of the RCS is provided by the low temperature overpressure protection (LTOP) system. The requirements for the LTOP system are contained in ITS 3.4.12. Additionally, in the event a pressurizer safety valve is inoperable and can not be restored within the associated Completion Time, the revised Action will ensure that the plant is placed in a condition for which the LCO for pressuriier safety valves does not apply in the event a pressurizer safety valve is inoperable and can not be restored within the Completion Time of the Action. The proposed changes do not alter assumptions relative to the mitigation of an accident or transient, nor do they significantly affect initiators or mitigatien of analyzed events. Herefore, CALVERT CLIFFS - UNITS 1 & 2 3415 Revision 5
- w _
NO SKiNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR pOOLANT SYSTEM the prepose,I chu3es do not involve a signincant increase in the probability or consequences of an acodent pmiously evaluated. 1 2. Does the change create the possibility of a new or different kind of acendent from any previously evaluated? ne proposed changes do not introduce a new mode of plant operation and do not involve physical modi 0 cation to the plant. He proposed changes do not introduce any new accident initiators. Herefore, they do not create the possibility of a new or difTerent kind of accident
' from any accident previously evaluated.
- 3. Does thh hange lavolve a signifleant reduction la margin of safety?
ne Applicability for CTS LCO 3.4.2.1 was revised to be consistent with the Applicability for CTS LCO 3.4.10, and the Action of CTS 3.4.2.1 was revised to be consistent with the revised Applicability. CTS LCO 3.4.2.2, its associated footnote (i.e., footnote ') Applicability sta'. ment, and Action requirement have been climinated. These profed changes are i acceptable, because the pressurlier safety valves are only needed to provide overpressure ! protection of the RCS in: a) Modes 1 and 2 for Units 1 and 2, b) Mode 3 with all RCS cold leg temperatures > 365'F for Unit 1; and c) Mode 3 with all RCS cold leg temperatures > 301'F for Unit 2. In Mode 3 with the RCS cold leg temperatures s 365'F for Unit I and s 301'F for Unit 2, and Modes 4 and 5 for both Units, overpressure protection of the RCS is provided by the low temperature overpressure protection (LTOp) system, nus, overpressure protection of the RCS will be assured. The margin of safety is established through the design of the plant , structures, systems and components, the parameters within which the plant is operated, and the establishment of the setpoints for the actuation of equipment telled upon to respond to a event. He proposed changes do not signi0cantly impact the condition or performance of structures, systems or components relled upon for accident mitigation. He proposed changes do not impact any safety analysis assumptions. Therefore, they do not involve a signincant reduction in a margin of safety. MJ0fhange L2
- 1. Does the change involve a algnifleant increase in the probability or consequences of an aceldent previously evaluated?
The proposed change adds a Note to the Applicability, which allows the pressurizer safety valve lift settings to be outside the limits of the LCO for 36 hours aher entry into the Modes of Applicability, for the purposes of setting the pressurizer safety valve lih settings under ambient conditions provided a preliminary cold sett!ng was made. De pressurizer safety valves are not an initiator of any analyzed event. The pressurizer safety valve lin settings are required to have had a preliminary cold setting prior to heatup, ne cold setting provides assurance that the valves are operabic near their design condition. Establishing pressurizer safety lin setting at
- ambient conditions gives assurance that they will be able to perform their design function. Also, one valve remains available for relief, along with the power-operated relief valves (PORVs), to mitigate overpressure eventsc ne change will not alter assumptions relative to the mitigation of an accident or transient. He proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a signl0 cant increase in the probability or consequences of an accident previously evaluated.
CALVERT CLIFFS UNITS 1 & 2 3416 Revision 5
plSCUSSION OF TECitNICAL SPECIFICATION 1)EVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM itself better to be in the SRs where the as found values and as left values are specifically listed. Placing these values in the LCO would have split the required tolerances in two different places! within the Specification (the as founds in the LCO and the as lefts in the SR). His change is ! plant spectue because Calvert Cliffs has different setpoints for each Pressurizer Safety Valve, and two different as found tolerances for one of the Safety Valves. His change was found to-make the Specification less confusing to the Operations staff. 9. NUREG 1432 LCO 3.4.10 is applicable in Modes I through 3, and Mode 4 with all RCS cold leg temperatures > [285)'F. Improved Technical Speelucation 3.4.10 will be applicable in Modes I through 2, and Mode 3 with all RCS cold leg temperatures > 36$'F for Unit No.1, and > 301'F for Unit No. 2. His deviation is acceptable, because the pressurizer safety valves are only . m,,e needed to provide overpressure protection of the RCS in: a) Modes I and 2 for Units I and 2, b) l Mode 3 with all RCS cold leg temperatures > 36$'F for Unit 1; and c) Mode 3 with all RCS cold i leg temperatures > 301'F for Unit 2. In Mode 3 with the RCS cold leg temperatures s 365'F for Unit I and s 301*F for Unit 2, and Modes 4 and 5 for both Units, overpressure protection of the RCS is provided by the low temperature overpressure protection (LTOP) system, ne , requirements for the LTOP system are contained in ITS 3.4.12. Additionally, this deviation is I consistent with the intent of NUREG 1432. He Bases for the Applicability of NUREG 1432 LCO 3.4.10 states that the LCO is not applicable when overpressure protection is provided by the LTOP system. To support this deviation, Required Action B.2 was revised to reflect the Applicability of ITS 3.4.10. He revised Required Action will require the plant to be placed in Mode 3 with all RCS cold leg temperatures less than or equal to 365'F for Unit 1 or 301'F for Unit 2; this is a condition where the ITS LCO will not be applicable. This proposed change is consistent with the Bases of NUREG 1432 LCO 3.0.2 which states if a Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit h a Mode or condition in which the specification is not applicable. 10. Specification 3.4.11 (power-operated relief valves (PORVs)) Applicability was changed from Modes I,2, and 3, to Modes I and 2, and Mode 3 with any RCS cold leg temperatures > 365'F l (301'F for Unit 2). This change is specific to Calvert Cliffs and was made because the LTOP System Specification provides requirements for the PORVs in Mode 3 with any RCS cold leg temperature s 365'F (30l'F for Unit 2), and in Modes 4 and 5, and Mode 6 with the head on. Appropriate Actions were adjusted to account for this Mode of Applicability change. His change is consistent with Amendment Nos.188 and 165 (for Units I and 2, respectively) and the accompanying Safety Evaluation Report, dated April 20,1994, 11, Specification 3.4.11 Completion Times were changed to be consistent with Calvert Cliffs Amendment Nos.188 and 165 (for Units 1 and 2, respectively) and the accompanying Safety Evaluation Report, dated April 20,1994. l
- 12. NUREG 1432 3.4.11 was developed assuming the pressurizer PORVs are air operated valves.
Hus, it contains a surveillance to perform a complete cycle of each solenoid air control valve and check valve on the air accumulators in the PORV control systems. At Calvert Cliffs, the pressurizer PORVs are electric solenoid operated valves; they are not air operated valves. Thus, ITS 3.4.11 does not include the NUREG 1432 surveillance to perform a complete cycle of each solenoid air control valve and check valve on the air accumulators in the PORV control systems. CALVERT CLIFFS-UNITS 1 & 2 3.4 2 Revision 5
- 21. The NRC questioned the addition of a note to Action A.) in the ISTS markup ofITS 3.4.11. The note was removed because it was not consistent with the current licensing basis. In support of this change, JrD 25 to Section 3.4 was deleted and the ISTS 11ases markup for ITS 3.4.11 were revised (ITS 3.4.11 Comment 1).
While resolving the aforementioned NRC comment, issues were discovered in the markups of CTS 3.4.3 for ITS 3.4.11, and 11- ISTS markups for ITS 3.4.11. These issues include: a) the l failure to properly identify changes to the CTS actions; b) the unjustined deletion of a note that permits separate condition entry for each power operated relief valve (PORV); and c) an apparent generic error in the ISTS regarding the note that permits separate condition entry for the PORVs; the note should also apply to the PORY block valves. The markups of the CTS actions were revised to be consistent with the ISTS rnarkup of the ITS actions, While not identified in the original CTS markup, the changes had been justified in DOCS M.) and M.2 for ITS 3.4.11. A note that permits separate condition entry for each PORV and each block valve was added to the markups of CTS 3.4.3 for ITS 3.4.10. This change wasjustified by DOC A.6 for ITS 3.4.11. The ISTS markup for ITS 3.4.11 was revised to include the PORV block valves, it was justified by JFD 36 to Section 3.4. The ISTS liases markup for ITS 3.4.11 was revised to be consistent with the revised ITS.
Pressurizer PORVs 3.4.11 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) LCO 3.4.11 Two PORVs and associated block valves shall be OPERABLE. APPLICABILITY: MODES 1 and 2 MODE 3withallRCScoldlegtemperatures>365'f(Unit 1).
> 301'F (Unit 2).
ACTIONS
.................................... NOTES-.----------------------...--...---
- 1. Separate Condition entry is allowed for each PORV and each block valve.
5"
- 2. LC0 3.0.4 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or two PORVs A.1 Close and maintain 1 hour inoperable and power to associated capable of being block valve. manually cycled. CALVERT CLIFFS - UNITS 1 & 2 3.4.11-1 Revision J/ 5'
Pressurizer PORVs 3.4.11 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. One PORV inoperable B.1 Close associated I hour and not capable of block valve. being manually cycled. 6ffD J B.2 Remove power from associated block 1 hour valve. AND l B.3 Restore PORV to l OPERABLE status. 5 days 6 C. One block valve C.1 Place associated PORV 1 hour inoperable, in override closed. AND C.2 Restore block valve 5 days F to OPERABLE status. D. Two PORVs inoperable D.1 Close associated 1 hour and not capable of block valves, being manually cycled. AND D.2 Remove power from I hour associated block valves. AND D.3 Restore one PORV to 72 hours OPERABLE status. CALVERT CLIFFS - UNITS 1 & 2 3.4.11-2 Revisiong5
l Pressurizer PORVs B 3.4.11 BASES 1 Therefore, this LCO is applicable in MODES 1 and 2, and MODE 3 with all RCS cold leg temperatures > 365'F (Unit 1), l6
> 301'F (Unit 2). The LCO is not applicable in MODE 3 with all RCS cold leg temperatures s 365'F (Unit 1), s 301'F (Unit 2), when both pressure and core energy are decreased and the pressure surges become much less significant. The l
~
PORY setpoint is reduced for LTOP in MODE 3 with T.y 5 365'F l (Unit 1), s 301'F (Unit 2) and in MODES 4, 5, and 6 with the~ ' "C 1 reactor vessel head in place. LCO 3.4.12 addresses the PORY requirements in these MODES. l ACTIONS The ACTIONS are modified by two Notes. Note 1 clarifies that the pressurizer PORVs and block valves are treated as 5 separate entities, each with separate Completion Times (i.e., the Completion Time is on a component basis). Note 2 ( is an exception to LCO 3.0.4. The exception to LCO 3.0.4 permits entry into MODES 1, 2, and 3 to perform cycling of the PORV or block valve to verify their OPERABLE status. Testing is typically not performed in lower MODES. Ad With one or two PORVs inoperable and capable of being manually cycled, either the inoperable PORV(s) must be restored or the flow path isolated within 1 hour. The block valve should be closed but power must be maintained to the
- associated block valve, since renoval of power would render the block valve inoperable. Although the PORV may be designated inoperable, it may be able to be manually opened and closed and in this manner can be used to perform its function. Power operated relief valve inoperability may be due to seat leakage, instrumentation problems, automatic control problems, or other causes that do not prevent manual use and do not create a possibility for a smt11 break LOCA.
For these reasons, the block valve may be closed but the Action requires power be maintained to the valve. This Condition is only intended to permit operation of the plant CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-4 Revision 5
l l l Pressurizer PORVs l B 3.4.11 BASES for a limited period of time not to exceed the next refuelingoutage(HODE6)sothatmaintenancecanbe performed on the PORVs to eliminate the problem condition. The PORM should nonnally be available for autoinatic mitigation of overpressure events and should be returned to OPERABLE status prior to entering startup (MODE 2), ( Quick access to the PORV for pressure control can be made when power remains on the closed block valve. The - Completion Time of I hour is based on plant operating experience that minor problems can be corrected or closure can be accomplished in this time period. 5 B.1. B.2. and B.3 If- one PORV is inoperable and riot capable of being manually cycled, it must either be isolated, by closing the associated block valve and removing the power from the block valve, or restored to OPERABLE status. The Completion Time : of 1 hour is reasonable, based on challenges to the PORVs during this time period, and provides the operator adequate time to correct the situation. If the inoperable valve cannot be restored to OPCRABLE status, it must be isolated within the specified time. Because there is at least one PORY that remains OPERABLE, 5 days are provided to restore 6 the inoperable PORV to OPERABLE status. C.1 and C.2 If one block valve is inoperable, then it must be restored to OPERABLE status, or the associated PORV placed in override closed. The prime importance for the capability to close the block valve is to isolate a stuck open PORV. Therefore, if the block valve cannot-be restored to OPERABLE status within-1 hour, the Required Action is to place the PORV in override closed to preclude-its automatic opening for an overpressure event and to avoid the potential for a CALVERT CLIFFS - UNils 1 & 2 B 3.4.11-5 Revision Ey
Pressurizer PORVs l B 3.4.11 BASES stuck open PORY at a time that the block valve is inoperable. The Completion Times of 1 hour are reasonable based on the small potential for challenges to the system during this time period and provide the operator time to correct the situation. Because at least one PORV remains OPERABLE, the operator is permitted a Completion Time of 5 days to restore the inoperable block valve to OPERABLE 5 status. The time allowed to restore the block valve is based upon the Completion Time for restoring an inoperable PORV in Condition 8 since the PORVs are not capable of automatically ultigating an overpressure event when placed in override closed. If the block valve is restored within the Completion Time of 5 days, the power wil) be restored y and the PORY restored to OPERABLE status. IL L_.,0.2. and 0.3 If both PCRVs are inoperable and not capable of being manually cycled, it is necessary to either restore at least one valve within the Completion Time of 1 hour or isolate the flow path by closing and removing the power to the associated block valves. The Completion Time of 1 hour is reasunable based on the small potential for challenges to the system during this tine and provides the operator time ' to correct the situation. If Required Actions 0.1 and D.2 have been completed, Required Action D.3 allows 72 hours to restore a PORV to OPERABLE status. This time is reasonable to perform required repairs. This time also accounts for the overpressure protection provided by the pressurizer safety vahes in LC0 3.4.10. LLand E.? If both block valves are inoperable. it is necessary to ' either restore the block valves within the Completion Time of 1 hour or place the associated PORVs in override closed and restore at least one block valve to OPERABLE status CALVERT CLIFFS - UNIls 1 & 2 B 3.4.11 6 Revisionpt
Pressurizer PORVs B 3.4.11 BASES I within 72 hours and the remaining block valve in 5 days, per g l Required Action C.2. The Completion Time of 1 hour to either restore the block valves or place the associated i PORVs in override closed is reasonable based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. F.1 and F.2 If the Required Actions and associated Completion Times are not met, then the plant must be brought to a MODE in which the LCO does not apply. The plant must be brought to at
-least MODE 3 within 6 hours and reduce any RCS cold leg 5 temperature s 365'F (Unit 1), s 301'F (Unit 2) within 12 hours. The Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging safety systems. Similarly, the Completion Time of 12 hours to
;y reduce any RCS cold leg temperature s 365'F (Unit 1), I s 301*F (Unit 2) is reasonable considering that a plant can cool down within that time frame. In MODE 3 with any RCS y cold leg temperature s 365'F (Unit 1), s 301'F (Unit 2) and in MODES 4, 5, and 6. maintaining PORY OPERABILITY is required per LCO 3.4.12.
SURVEILLANCE SR 3.4.11.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each PORV instrument channel every 92 days to ensure the entire channel will perform its intended function when needed. SR 3.4.11.2 Block valve cycling verifies.that it can be closed if necessary. The basis for the Frequency of 92 days _is AmericanSocietyofMechanicalEngineers(ASME)SectionXI CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-7 Revision Ay
Sp c.kA,ca 3.4.tL b 34 W AIEltt.300LAEL1Y111M (Aes
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A y Q LIMITING COSITION FOR OPERATIM M rated rettef valves 3M 4.4.3. valves sha1Two 5OPr.ofaAstE. a POdRs. M a d their stocidi'"hb e goc APPLICABILITY: IIget$ 1.*2, and 3# k [ h[7,I.- w" 1.' ( _
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_C_s/ed of $sI6g WN3 fit
~ .
t; ,i Dd A .lf'Ethe clo orbothPORV(s)fhas excessive s::t h :h . within 1 hour associated block valvejs) nand maintai;; power to the block valve (s). g,j 4 g,gg g,q ,,;;qKg@
% With one PORY inoperable b^
~
-7" - " '-- ^^^"
Asr um B ^ l :::t h . or status h ;lo. c sewithin 1 ho:rd block valve and remove power " rom the associa ther restore the PORV to OPERABLE
<the block valves restore t hthi; 5 days or be in OTPORY to OPERABLE status within()
Mau F - STANDBY within the next . hours . M and at or below 365'F withl n the following hours. . E lith both PORVs inoperab1hi: M ....e. 0,7'Mr.:aa:h: A " *8 D - .?" :::t h:h;;. within 1 hour either restore one PORV to OPERABLE status or close the associated block valve and remove power from the block valvel restore one PORY to OPERABLE status Awlthin@Efi%D 72 hours or be in NOT STAND 8Y within the 4 ,., , y g . ext ours and at or below 365'F wtthin the following M
- d. fWith one or both block valve (s) inoperable, within 1 hour restore theblockvalve(s)toCPERABLEstatusorplaceitsassociated A ' "*" 8 . PORV(s)inoverrideclo QN.D y'
dd a OPERABLE status within v Restore at least one block valve to i inoperable restore any rem ' 2D72 hours if both block valves are njin inoperable b1cck valve to OPERABLE status within e d ian M 5 days otherwise, be in at
%,.a p least NOT STANOGY within ours. the next $ hours and at or below 365'F within the following Q
% The provisions of Specification 3.0.4 are not appitcable.
MfMJ /hre L l
-.o Noth I h
[M43pecAancr1 Above 365'F) At-+r ;, ele. 00~,T. O g n ;;^ h !!' ',0,0 : pi k e. l CALVERT CLIFF $ . UNIT 1 3/4 4-7 Amendment No. 188
Tp cc 6,u ..,- t.4.tl 3.4 S/4:4 REACTOR C00LAlfT SY$ TEM Q y,q,ej - /4.4.0 RELIEF YALVES _ . _
~
Geiie { P.i . OpJ. 44~_nUf'y.Ge~(.PoA% LIMITING C00to!T!0ll TOR OPinATI0ll - LC D ~] ~QJ
)* 4* g 4;t:t Two faver.ogerated be OP RABLE. relief valves (PORVs)_gndjheir.as}e fatap41 k
valves shel M 5. aw.s d e
%.~Lpow!46 m$lkad .H j l APPLICABILITY: N00LS (
j i AUIMI ~
*\
l b C" Q A. ri. 7 de d I c. M k i N M ilIy h el h A K.'J(pne citFle theor both PORV(s) associated b lock valve (s') and maintain power to thehae-Ma block valve (s). Acwd 1 ith one PORY inoperable ..; t: 20: et': 0.n at;nts44 "0"'!- ~ - Q T setf l ulta0e. within 1 hour eith ! restore the PORV to OPERABLE status or close the associated ock valve and remove power trom l AcWM h the block valves restore the PO V to OPERABLE status wit in(We 5 days or be in 110T ANDtY within the next F ours A' and at or below 301'T within he following hours. l J Ach.og h tth both PORVs inoperable,..e te av.s. v5nwr 6.n me..;,,- W *eet !?9t;:. within 1 hour either restore the PORVs to OPERAlti status or close its associated block valve ...d remove
/\r,iora over ithi from the block valves restore one PORV to CPERABLE status
~.4 fella'TRin?2 hours or be in if0T STAN0lY within the t A' p n at ur our)Qand at or below 301'T within '.he following l ^4 t
74 Ad 'o M5
- d. It one or both block valve (s) inoperable within 2 hour restore M the block valve (s) to OPERAltt status or place its aswisted C4g PORV(s)inoverrideclosed. Restore at least one block valve to .
OPEU?tt status within@8g:BtitD 72 hours if both block valves are (A inoperable restore anylemaining inoperable block valve to gg PtkABLE status within t H H Eli 5 days otherwise, be in at
- p least HOT STANDIY within the next hours and at or below 301T within the following l .
urs. (Q AcuaN5 % The provisions of Spectffcation 3.0.4 are not applicable. N oTE 'L m/d Ul RC S co ld im 4< p m e-ice. A ed 6
/ Mot)F
- n -_
Q d\-
~3 A pt> l.e 4. i. 4 y
! bove 301*F) %; ;r h!= 3017. 4;;i'!::t' - ?/d 8.0 ' W !:s.
[ CALVERT CL1FFS LINIT 2 3/447 Amendment No. 178 9
DISCUSSION OF CHANGES SECTION 3.4.11. PRESSURIZER PORVs ADMINISTRATIVI' CilANGES A.1 ne proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change cfintent, 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 and to be consistent with NUREG 1432, llowever, the additional information does not change the intent of the current Technical Specifications, %c reformatting, renumbering, and rewording process involves no technical changes to existing Specifleations.
' ~
' " ~ '
l A.2 Current Technical Specification 3.4.3 Applicability footnote ' contains a reference that below 365'P (301'F for Unit 2) the LTOP Technical Specification applies. Improved l Technical Specification 3.4.11 deletes this reference, in general, the ITS does not reference other Specifications, in this case, the Applicability for this Specification and the LTOP Speellication are precise enough so that no confusion should exist as to which Technical Specification applies. Deletion of this unwarranted reference constitutes an administrative change. His change is consistent with NUREG 1432. A.3 Not used. l A.4 Current Technical Specification 3.4.3 requires the Specification to be applicable in Modes I and 2, and Mode 3 above 365'F (above 301'F for Unit 2). Improved Technical Specification 3.4.11 specifies that in Mode 3 the Specification be applicable with all RCS cold leg temperatures > 365'F (> 301'F for Unit 2). This change is administrative because this is consistent with current Calvert Cliffs practice. His change is consistent with NUREG 1432. A5 Current Technical Specification SR 4.4.3.1.a requires each PORV to be demonstrated Operable by performance of a Channel Functional Test in accordance with Table 4.31, item 4. Table 4.31, item 4 provides the Surveillance Requirements for Pressurizer Pressure
- liigh reactor trip. Improved Technical Specification SR 3.4.11.1 requires a Channel Functional Test of each PORV. Current Technical Specification SR 4.4.3.1.a has been revised to be consistent with ITS SR 3.4.11.1; the reference to Table 4.31, Item 4 has been deleted. This proposed change is an administrative change, because a Channel Functional Tcat of cach PORY will be required to be perfe med ir. accordance with ITS SR 3.4.11.1, and the Channel Functional Test for the pressurler pressure high reactor trip will be required to be performed in accordance with ITS SR 3.3.1.4 for item 4 of Table 3.3.1-1. In addition to the justification provided above, this proposed change is consistent with NUREG 1432.
A.6 Current Technical Specification LCO 3.4.3 does not specify a method for tracking allowable out of service times. Note i for the Actions ofITS LCO 3.4.11 states that separate condition entry is allowed for each PORV and each block valve. This note provides a methodology for tracking Completion Times. It allows the Conditions and Completion Times to be entered and tracked separately for each inoperable PORV or block valve. In the ITS, once a CALVERT CLIFFS UNITS 1 & 2 3.4.11 1 Revision 5 d
DISCUSSION OF CHANGES SEC110N 3A.ll . PRESSURIZER PORVs Condition has been entered, the subsequent discovery of another inoperable component expressed in the Condition does not result in separate entry into the Condition, unless specifically stated, ne Required Actions would continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, in the case of an inoperable PORY or block valve, the initial actions for ITS 3.4.11 Actions A,11, and C are required to be completed within one hour if during this time, the second PORV or block valve becomes inoperable, very little time (less than one hour) would be permitted to take the initial action for the second inoperable PORV or block valve, in the event separate condition entry was not explicitly allowed. Also, this time would be more limiting than: a) the initial Completion Time pennitted by ITS Action A (i.e., one hour) in the event both PORVs were concurrently discovered to be inoperable, but capable of being manually cycled; and b) the initial Completion Times permitted by ITS Actions D and E (i.e., one hour)in the event both PORVs or block valves are discovered to be inoperable, %us, a note permitting separate condition entry for each PORV and each block valve has been added to CTS LCO 3 A.3 nis clarification is necessary due to the reformatting of the requirements contained in the ITS, nis change is perceived as the intent of the Actions of CTS 3A.3. Dus, this proposed change is considered be an administrative change, because it does not involve a technical change to the CTS. TECilNICAL CilANGES - MORE HMTRICTIVE M.1 Current Technical Specification 3.43 Actions b and d require the one inoperable PORV and block valve, respectively, to be restored to Operable status within 121 hours; and Actions c and d require one of two inoperable PORVs and block valves, respectively, to be restored to Operable status within 73 hours, improved Technical Specification 3,4.ll Actions 13, C, D, and E will reduce the time allowed to restore the PORVs and block valves to Operable status by one hour. Reducing the allowed outage time constitutes a more restrictive change, ne change does not adversely affect plant safety, ne change is consistent with NUREG 1432. M.2 Current Technical Specification 3A.3 Actions b, c, and d shutdown requirements require the unit to be in Mode 3 within 12 hours and temperature to be below 365'F (Unit 1), and 30l'F (Unit 2) within 36 hours. Improved Technical Specification 3.4.11 Action F requires the unit to be in Mode 3 within 6 hours and temperature to be below 365'F (Unit 1), and 301'F (Unit 2) within 12 hours. This change reduces the time allowed to be in Mode 3, and Mode 3 with temperature below 365'F (Unit 1) and 301'F (Unit 2) Reducing the shutdown times constitutes a more restrictive change. The change does not adversely aficct plant safety because the plant is still capable of shutting down in a safe and orderly manner. This change is consistent with NUREG 1432. M.3 Improved Technical Specification SR 3.4.11.3 was added to CTS 3.4.3. The added SR will require the PORVs to be cycled once per 24 months. His SR is required to demonstrate that the PORVs function, ne addition of new requirements to Technical Specifications constitutes a more restrictive change. This change will not detrimentally affect safety-because it proves the PORV can perform its function. This change is consistent with NUREG 1432. CALVERT CLIFFS - UNITS 1 & 2 3.4.11 2 Revision 5 I i
Pressurtzer PORVs
- 4r# 3.4 REAC10R COOLANT $Y$iLM (RC$)
3.4.!! 3.4.11 Pressurtzer Power Operated Reitef Valves (PORVs) LC0 3.4.11 1 POR$nd associated block valvghall be OP(RAttt. APPLICA81LITY: Moots if {_ _ _
, 34,,794i)
W All tc.5 ..# /. y h /wre/~' ? h ACTION $ N- ^3el*fG"U
- ~~
q w u . o .. ... .......... ... .........N0Tc$.--- - . .. . i.- $. .r.ie cuition entry is anowed for each POR .
*o 3.
e o om wk @ & '
!:.. d .! i !.!!.".i d ! d !!:........................ m . h i <.= r:.r ...
CONDITION REQUIREDACil0N CONPLETION'TINC 3A 3 - A. One or A< ru a PORVs A.! Close and maintain 1 hour inoperable and capable power to associated of bein cycled.g manually block volve. I .. I B. 24'I B.! Close associated Ahmb One and notPORY inoberable capa le of block valve. I hour being manually cycled. M B.2 Remove power from I hour associated block valve. m G~ 8.3 Restore PORY to g l 46 OPERABLE status. (continued) CEOG STS 3.4 22 Rev 1. 04/07/95 ,
Pressurtger PORVs ' (cr4 3.4.11 ACTIONS (continued) CON 0lil0N REQUIREDACTION i COMPLETION TINC 3.d. 3 C. One block valve C.1 Place associated PORY
<444.. ) inoperable. ^ 1 hour g
n -^- -
=
p C.! Restore block valve 9y to OPERABLE status. Q O. Reilu ed Action and D.1 in MODE 3. 6 ho as lated Completion l T of Condition A. e or C not met. M .
.2 Be in-M00C 4.
[ [12)hoursj Two and notPORVs capab etable ino$e of being manually cycled. 1 Close associated block valves. I hour @ 3A.3 caen C. f .I Remove power from associated block I hour h. valves. Sabe ou PMV h ( OPCunc 6kW .3 rwut 3 1 hours l'. 4 Be in MODE j [lt) Nr[ 14'3 i - ^-- block valvasinoperable. 1 Place associated I hour A<bn d PORVs in bec As clo14 (continued) CEOG STS 3.4-23 Rev 1. 04/07/95
1)lSCUSSION OF TECilNICAL SPECIFICATION DEVIATIONS FROM NUMEG.1432 SECTION 3,4 - REACTOR COOLANT SYSTEM 1mproved Technical Speellication 3.4.9 will not contain s surveillance to verify that the pressurlier heaters are capable of being powered by an emergency power supply. This la appropriate, because the pressurizer heaters are pennanently powered by Class IE power supplies. Class 1B power sources are backed-up by the emergency diesel generators. 1he transfer from the normal power supply to the emergency power supply for these buses occurs on an under voltage condition. The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has I been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied
- by a Class 1E power source (e.g., the safety irdection systems) do not contain SRs to verify the systems are capable of being supplied by emergency power. Thus, the elimination of SR 3.4.9.3 i
from the ITS is consistent with other specifications. Furthermore, the climination of this SR is consister.t with the Bases of NUREG 1432 SR 3.4.9.3 which states: "This SR (SR 3.4.9.3] i applicabic if the heaters are permanently powered by iE power supplies." 22. Reference to "specified in the COLR" in SR 3.4.1.4 was deleted because the lim!t in the LCO is the limit tested for in the SR. Therefore, placing the value in the Core Operating Limits Report is not necessary, lhls change is consistent with Calvert Clifts current licensing basis. 23.- The containment sump monitor in Specification 3.4.15 was changed to containment sump level alarm. Calvert Cliffs has a containment sump level alarm system. This change is consistent with the current Calvert Cliffs licensing basis.
- 24. Not used.
l
- 25. Not used.
l 26. NUREG 1432 LCO 3.4.9.b requires the pressurizer to be Operable with two groups of pressurizer heaters Operable with the capacity of each group 2 (150 kW) (and capable of being powered from an emergency power supply]. Current Technical Specification LCO 3.4.4 requires the pressurizer to be Operable with a steam bubble and with at least 150 kW of pressurlier heater capacity capable of being supplied by emergency power. Improved Technical Specification LCO 3.4.9 will not contain a requirement to ensure that the pressurirer heaters are capable of being supplied by emergency power. This is appropriate, because the pressurizer heaters are permanently powered by Class 1E power supplies. Class lE power sources are backed-up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under voltage condition. The transfer from the nonnal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3.8.1. Additionally, the speelfutions for other systems that are supplied by a Class IE power source (e.g., the safety injection systems) do not contain requirements in the LCOs to verify the systeras are capable of being supplied by emergency power. Thus, the climination of the LCO requirement from the ITS is consistent with other specifications. Furthermore, the Bases of NUREO 1432 SR 3.4.9.3 (the NUREG SR _which confirms the pressurizer heaters are capable of being supplied by an emergency power) states that it is not applicable if the Seaters are permanently powered by lE power supplies.1his implies that the LCO requirement is also not applicable if the heaters are permanently powered by Class 1E power supplies. CALVERT CLIFFS - UNITS _1 & 2 3.46 Revision 5
l DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM I
- into Action O in ITS 3.4.1 t Actions E, F, and O of NUREG 1432 LCO 3.4.11 were labeled as Actions D, E, and F in the ITS.
'these proposed deviations from NUREO 1432 were necessary to incorporate the current lleensing basis provided in CTS 3.4.3, as approved by the NRC in License Amendments Nos.188 and 165 (for Units 1 and 2, respectively) with a Safety Evaluation Report dated April 20,1994. In License Amendment Nos.188 and 165, the NRC accepted the 72 hour allowed outage time for restoring a PORV to an Operable status in the event both PORVs were Inoperable due to causes other than excessive seat leakage. *lhis allowed outage time provides a more realistic opportunity to rnake repairs to the inoperable PORV. Thus, the plant would avoid unnecessary shutdowns, and would avoid entering the region when the PORVs are required to bc
,..m m. operable for low temperature overpressure purposes. It is safer to attempt repairs of the PORVs -
in Modes 1,2, and 3 with the temperature above the LTOP enable temperature, because the PORVs are not credited in the accident analyses in Modes 1,2, and 3 with temperatures above the LTOP cnable temperature. During operations in Modes 1,2, and 3 with the temperature above the LTOP enable temperature, the pressurizer safety valves are the credited means for overpressure protection in the accident analyses. Thus, the proposed addition of the */2 hour allowed outage time to restore a PORV to an operable status to Action D ofITS 3.4.11 and the deletion of the shutdown requirements (Actions E.1 and E.2 of NUREO 1432 LCO 3.4.11) from Action D ofITS 3.4.11 are acceptable. To support this change, Actions D and O of NUREO 1432 LCO 3.4.11 had to be revised in
. ITS 3.4.11. These requirements ensure that the plant is placed in a Mode and condition for which the LCO does not apply in the event a Required Action and associated Completion Time are not met. Action D of NUREG 1432 LCO 3.4.11 was incorporated into Action F ofITS 3.4.11, and Action F of ITS 3.4.11 was revised to apply to Condition D of ITS 3.4.11. 'the proposed deviations regarding Actions D and O of 1,LTl'O 1432 LCO 3.4.11 are considered to be acceptable, because the ITS continue to require the plant be placed in a Mode and Condition for which the LCO does not apply in the event a Required Action and its associated Completion Time are not met.
36. Note 1 of the Actions for ITS 3.4.11 was revised to pennit separate condition entry for the PORV block valves. This Note has been modified to also pennit separate condition entry for each PORY block valve. in the ITS, once a Condition has been entered, the subsequent discovery of another inoperable component expressed in the Condition does not result in separate entry into the Condition, unless specifically stated, The Required Actions would continue to apply to each additional failure, with Completion Times based on initial entry into the Condition in the case of an inoperable block valve, the initial action for ITS 3.4.11 Action C is required to be completed within one hour, if during this time, the second block valve becomes inoperable, ITS 3.4.11 Action C would permit very little time (less than an hour) to take the initial action for the second inoperabic block valve, in the event separate condition entry was not explicitly stated. Also, this time would be more limiting than the initial Completion Time permitted by ITS Action E (i.e., one hour) which addresses the condition when both block valves are discovered to be inoperable. 'lhus, Note 1 ofITS 3.4.11 was revised to permit separate condition entry for the PORV block valves. CALVERT CLIFFS- UNITS I & 2 3.4 10 Revision 5
. i i
Pressuriter PORVs 8 3.4.!! gsoc 3 pt n s. '3L5' W O BA$[5 j "3
- 4 APPLICABILITY 5 1 and 6 with the reactor vessel head in place.
(continued) MODt3 LCO 3.4. 4,1, addresses the PORV requirements . in these M0I ACTIONS L1
- The ACTIONS are modified bj
_thd all naturteer PORVyare 4retreated Notes. as Mete-sepa) -clerifise rate entities A 1*-#. ' each'w nh soplH W COIlpl H 1 ni llanes /?il @ f C M~w_
=-
bd O VC' #' i Time is on a component basi i). ' Notei.e. (A the Completion is,an exception to ed h d )*** * { LC0 3.0.4. M00ts 1, t, and 3 to perfors cycling of the PORY or blockThe excep valve to verify their vacLperformed OPERABLp141Wida1 in lawa' INU Ling _it.lygin pu e:%>b is4&D , With no POR41nop 1 cycled, either the ano capaore of being manually isolated within I hour. pust be restored or the flow path The block valve should be closed but power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. Although the PORV say be designated inoperable it may be able to be manually opened and closed and in this, manner can be used to perfors its function. PORV inoperability may be due to seat leakage instrumentation problees, automatic control problems, or,other causes that do not prevent manual use and do not create a possibility for a small break LOCA. For these reasons the block valve may be closed but the Action requires power, be maintained to the valve. This Condition is only intended to perett
- operation of the plant for a Itaited period of time not to exceed the next refueling outage (MODE 6) to that maintenance can be performed on the PORVs to ellainate the probles condition. The PORVs should normally be available for automatic mitigation of overpressure events and should be returned to OPERABLE status prior to entering startup (MOOC2).
Quick access to the PORY for pressure control can be made when power remains on the closed block valve. Tne Completion Time of I hour is based on plant operating experience that minor probless can be corrected or closure can be accomplished in this time period. (continued) CEOG STS B 3.4 51 Rev 1, 04/07/g5
INSERT A.I IIASES Required Action .1 is modifi by a note which lows the Action to, delayed to s 7 120 houaifo block valv s inoperable and 7 ours if two block ves are ino able. - 1 time to r the block valve latent with Requ , Action C. ' E.2
/ ))ds will al ordert mplywith equired Action A. This is bastA on a ant shutdo being s unr le when t RV la capable o roviding its funct! the safety v vos being ava , and the r te possibility of ent occurring d ' this period ' time.-
aPORY is inoperable due t excessiveleakage, Note may o be applied if tiw associst lock valve (s) can ntained in the c sed position. s ensures that : the possibility of a small break L A via the PORV( la minimized. u
~
Pressurtzer PORVs 8 3.4.!!
)
SA$15 ACTIONS 9.1. B.f. and B.3 - (continued) . If one PORY cycled, it must is inoperable either be isolatedand not ca able of being manually y closing the associated block valve and removi he power from the block vahe, or restored to OPERABLE sta s. The Caspletion flee . m. of I bour is reasonable, based on challenges to the PORVs . ., during this time period, and provides the ope,rator adequate ,*. time to correct the situation. If the inoperable valve within the specified time. Because t it must be isolated cannot PORY that remains beOPERA restored to OPERABLt 8Lt 1 iff'.t'.n..; '..... 4 status $ere is at least provided to restore the ino,perable PORV to PERABLE status, C,1 and f.2 $cw W h , t l If one block valve is inoperable then it must be restored onr4
- to OP(RABLE status or the assoc ated PORY placed in sen4ee4. The prime toportance for the capablitt c *u t i the block valve is to isolate a stuck open PORV.y to close if the block valve cannot be restored to OPERABLE statusTherefore, ova r"h within
;n;1 I:::
hour::g,the Required Action is to place the PORV in c,bs. &- to preclude its automatic opening for an
% overpressure event and to avoid the potential for a stuck
! open PORY at a ttee that the block valve is inoperable. The l Completion ilmes of I hour are reasonable based on the small ! potential period andfor challenges to the systea during this time i situation. provide the operator time to correct the Because at operator is permitted aCleast one PORY remains OPERABLE, the restore the inoperable blot letton Time of M 'Iiiius, valvetoOPERABLT to < j%' '3-
- ine' time allowed to restore the block valve is based upon the Completion Time for restoring an inoperatele PORV in Condition overpressure 8 since event whenthe PORVs placed in anas41
/4 are not capable onsitt3sting an%.. Npr y3
- trd. f the
?blockL.o. valve is restored within the Comp 11:ttm itse of the power will be restored and th. PORY restored t RABLE stat
^D.1andDf(
lf he Required Act n cannot be met w 4 letion ilme, t plant must be br htintothe associa d lGhichtherequtr a MODE nt does not apply, o achieve th 2, j t (continued) CEOG STS 8 3.4 52 Rev 1. 04/07/95
Pressurtrer PORVs B 3.4.11 BA$[$ AC110N$ D.1and[f (continued) 1
- status the plant must be b ught to at least MOOL 3 thin 6 hou and to MODE 4 witn 12 hours. The alleved
/d Campi t!.m flees are reas able, based on operatt U/
espe ence to reach the quired plant conditten free full I cond\ttensinan rly manner and withou
. X.F to ytek O *^t 1 ch longing plant syst s., J t).1 an f>4 W w ep.1, SPD 1. f.
4_ E A A 5 4*12O' *' bd 8 4 If a
- E- r: PORVs 4 Miaos
/ tt:4ut g, (t.a V I inoperable and not capable of being manually cycled, it to necessary to either restore at least one valve within the Completion Time of I hour or isolate
- 4. bet N O *q' the flow path by closing and removino the power to the *
% K=, a associated block valves. The Completion itse of I hour is I
te . 3 4 4, p,, r., a reasonable based on the small potential for cha11enges to the systen during this time and orovides the ootrator ttee reg p,3 f,g;,y, g I to correct the situation.
, whn I ene thePORY plant uwillhe res30Tecin anc onh
- h. -"'*
- Id 4 c. <is 4 @nditionBwiththv remains inopers 2.
& . '.,re si.e e., declaration of hav too clock started at se orietnal two ponVs inocerabi If no rokys art p,,% 6 p,.. b .D restored within Completion Time, th e plant must be b O brought to a M0 in which the LCO doe not apply. To t rS*1" achieve this tus, '^* plant must brought to at least 5,G LI v. lea M MODE 3 withi 6 hour; a 1 to M00C 4 tthin 12 hours. The
"* L4'g' toepletion expertenc , to mereachof MODE 6 ewrs3isfrom reas able based on operating 11 pow,er in an orderly manner d without challenging ant systems. 51stlarl the C
>1stion line of 12 hour to reach MODE 4 is reas a>1e, considering that plant can cool down w th time frame on one saf in y system train. In 4 O L,a.17. 2$ maintat_ning PORV OffLABIL11Y may be .
Seereautr
)
and if - - e block valv -e to either resto e the block valves within the Completinoperable it is necessary ilme of I hour r place the associated PORVs in E.'rdis== dah seawel and re ore at least one block valve to OPERABLE status within y hours and the remaining block valve in Ehoes. The Cocthston ilme of I hour to either restore the block valves or pla e the associated PORVs in g R9 ,% ( A . 6 0.. A
.r everod8 continued) h he-CEOG $15
' 8 3.4 53 Rev1,04/01/g5 w
l L
- 22. The markups of CTS Sit 4.4.3.1.a for ITS 3,4.11 were revised to state that the deletion of the phrase "in accordance with Table 4.31, item 4" is actually an administrative change, versus a movement ofinformation. Thus, DOC A.$ for ITS 3.4.11 has been added tojustify the change, and DOC LA.1 for ITS 3.4.11 has been climinated. These changes were made to respond to an NitC comment (ITS 3.4.11 Comment 2).
se s . 4.. . 1, S . i i
-3/M l !0: :::."J.;;; 27:!!"
$URYt!LLANCE kt0UIRENtNTS l g 4.4.3.1 tech PORY shall be demonstrated DPERABLE:
- 4. 4. t 4.1 4.
At least(*once perd[s et t b{?
. L. performance
. '_ FL !!r '. of a CNANNEL FWCTIMAL m TEST. ?"'^+!e 8.b d
. 1ro -.i.,~. e,, 4, i i ,4 b. At least once per ktFUELING INTERVAL by performance of"a'ta4NNEL ~ -l CAltlRAT1M.
d 4.4.5.E tach block valve :%11 be demonstrated DPERABLE at least once per
- 14. WD 92 days by operating the valve through one complete cycle of full trav funless the_b ock valve is closed to meet the requirements ofqrson-r,el E 44 ( ME 6 newec' ficeuser s.4 3
,.,, j j ,,, , g y
% 4. t \ . *l. 4,n tu -
to . 4 c *>
~%,s SR 3,4,t t .] PeeF.m = .. put e v. l e .F
*=ek 9 0 CAU .
24%. %, ! _-) CALVERT CLIFF $ . UNIT 1 3/4 4 8 Amendment No. 208 po. ge 2 *I1
I P"* 8' on i % 3.4.tl SM -* n; tr' ~ mm SURVE!LtANCE REQUIRDttNTS
,h
- 4.4.3.1 tech PORY shall be danonstrated DPIRA8LE:
3411.I 't. utsi, (At least once per t :::::t , sb ?.y performance of a CNAlBitt FUNCT!0llAL. Q-L. .n 4.:.2, ii ,. l 3, A (At least once per ktfVEL!llG INTttVAL by perft,rmance of a CIIANNEL
/3
- 1. t M IBRATION. l am . < i t .1
~
A t 3I4 ilt 4 g N 92 ech days byblock valve oprating shall the valve be demonstrated through one complete cycle$PtnAsttof full trar at least once 3 . 4.1 l . s
- pcmEmmanow.4.2s ock valve isthe b to meet the requirements oft!Jennirn closed a,8
_g_ 737,, g,g 1 L = _ ,- Pc,S em w m e' A L 1 A sf, 3,4,ll3 A of ca J f t>M g.) CALVERT CLIFTS - UNIT 2 3/4 4.B Amendment No. 186 c, o d
DISCUSSION OF CHANGES SECTION 3.4.11. PRESSURIZER PORVs ADMINISTRATIVE CllANCaES - A.1
%e proposed change will reformat, renumber, and rewrd the existing Technical Specifications, with no change ofintent, to be consistent with NUREG 1432. As a result, the Tecimical Specifications should be more easily readable end, 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 infonnation may also have been added to more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional information does not change the intent of the l current Technical Specifications. He reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. " ' ' " " ' " A.2 Current Technical Specification 3.4.3 Applicability footnote
- contains a reference that below 365'F (301*F for Unit 2) the LTOP Technical Specification applies, improved Technical Specification 3.4.11 deletes this reference. In general, the ITS does not reference other Specifications. In this case, the Applicability for this Specification and the LTOP Specification are precise enough so that no confusion should exist as to which Technical Specification applies. Deletion of this unwarraated reference constitutes an administrative change. This change is consistent with NUREO 1432.
A.3 Not used. l A.4 Current Technical Specification 3.4.3 requires the Specification to be applicable in Modes 1 and 2, and Mode 3 above 365'F (above 301'F for Unit 2), improved Technical Specification 3.4.11 specifies that in Mode 3 the Specification be applicable with all RCS cold leg temperatures > 365'F (> 301'F for Unit 2). This change is administrative because this is consistent with current Calvert Cliffs practice, his change is consistent with NUREO 1432. A.5 Current Technical Specification SR 4.4.3.1.a requires each PORV to be demonstrated Operable by performance of a Channel Functional Test in accordance with Table 4.31, item 4. Table 4.3 1, item 4 provides the Surveillance Requirements for Pressurizer Pressure liigh reactor trip. Improved Technical Specification SR 3.4.11.1 requires a Channel Functional Test of each PORV. Current Technical Specification SR 4.4.3.1.a has been revised to be consistent with ITS SR 3.4.11.l; the reference to Table 4.31, item 4 has been deleted. His proposed change is an administrative change, because a Channel Functional Test of each PORV will be required to be performed in accordance with ITS SR 3.4.11.1, and the Channel Functional Test for the pressurizer pressure high reactor trip will be required to be performed in accordance with ITS SR 3.3.1.4 for item 4 of Table 3.3.1-1. In addition to the justification provided above, this proposed change is consistent with - NUREG 1432. A.6 Current Technical Specification LCO 3.4.3 does not specify a method for tracking allowable out of service times. Note 1 for the Actions ofITS LCO 3.4.11 states that separate condition entry is allowed for each PORV and each block valve. His note provides a methodology for tracking Completion Times. It allows the Conditions and Completion Times to be entered and tracked separately for each inoperable PORY or block valve. In the ITS, once a CALVERT CLIFFS - UNITS 1 & 2 3.4.11 1 Revision 5
^
v
DISCUSSION OF CIIANGES SECTION 3.4.11 - PRESSURIZER PORVs TECIINICAL CIIANGES - RELOCATIONS None TECliNICAL DOCUMENTSCIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED LA.I Not used. l TECIINICAL CIIANGES - LESS RESTRICTIVE L.1 Actions a, b, and c of CTS 3.4.3 provide the required actions in the event one or two PORVs
-r ' ' '
t
. are inoperable. Action a provides the actions for one or two inoperable PORVs due to
excessive seat leakage, and Actions b and c address one or two inoperable PORVs for causes other than excessive seat leakage, respectively. Actions A, D, and D ofITS 3.4.11 provide the required actions in the event one or two PORVs are i,ioperable. Action A provides the actions for one or two inoperable PORVs that are capable of being manually cycled. Actions 13 and D provide the actions for one or two inoperable PORVs that are incapable of being manually cycled, respectively. The CTS have been revised to reflect the ITS methodology for addressing PORV inoperability. These proposed changes are considered to be a less restrictive change, because they appear to broaden the applicability for Action a of CTS 3.4.3 and narrow the range of applicability for Actions b and c of CTS 3.4.3. Actually, excessive seat leakage is an example of an inoprable PORV which does not prevent the PORV from b:ing manually cycled. Thus, this change could be interpreted as meeting the intent of the CTS. Action a of CTS 3.4.3 has been revised to be applicable when one or both PORVs are inoperable and the applicable PORVs are capable of being manually cycled. In the event this occurs, :he inoperable PORV can be manually opened and closed to perform its function. Thus, the PORV should remain available so that the operators could manually utilize the relief pathway, For this condition the prudent course of action is to close the block valve and maintain power to the bbek valve. This methodology permits the operators to have relatively_ quick access to the PORV for pressure control, if the power were removed from the block valve, additional operatot actions would be reqPred to manually utilize the pathway. Therefore, the proposed change to Action a of CTS 3.4.3 is acceptable. Actions b and c of CTS 3.4.3 have been revised to be applicable when the PORVs are ' inoperable and the valve is not capable of being manually cycled. In this case, the PORV cannot be used manually for pressure control, and the condition a the PORV may be uncertain. Thus, the prudent course of action is to secure the PORV by closing the block valve, and provide additional assurance that the PORV is isolated by removing power from the valves. Actions b ard c of CTS 3.4.3 require these actions, and they also require the PORVs to be restored to an Operchte status. Thus, the proposed changes to Actions b and c of CTS 3.4.3 are acceptable. 1 in addit on, at Calvert Cliffs, the PORVs are not credited in the accident analyses for overpressure protection during Modes I,2, and 3 with the RCS cold leg temperature greater than the enable temperature for the L~u Temperature Overpressure Protection System. In these Modes and specified conditions, the i,assurizer safety valves are the mechanism CALVERT CLIFFS - UNITS 1 & 2 3.4.11-3 Revision 5
- 23. The NRC requested additional justification for incorporating CTS SRs 4.4.3.1.a and 4.4.3.1.h
-into ITS 3.4.11 as SRs 3.4.11.1 and 3.4.11.4. JustiHeation for Deviation 12 to Section 3.4 has been revised to include the additionaljustification. Additionally, the ISTS Bases markup for ITS 3.4.ll- has been changed to better describe the current system design. (ITS 3.4.11 Comments 3 an( i)
While resolving the aforementioned NRC comment, several inconsistencies regarding the rationale for the pORV setpoint in the ISTS Bases markup for ITS 3.4.11 were discovered. The Bases have been revised to be consistent regarding the rationale for the pORV setpoint. The use of the term "only" in the Applicability regarding RCS cold leg temperature was changed to "all" to properly complement a related change in ITS 3.4.12 applicability. These terms now accurately reDect NUREG 1432 and the current licensing basis. l l }
Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs). LCO 3.4.11 Two PORVs and associated block valves shall be OPERABLE. APPLICABILITY: MODES 1 and 2 MODE 3 with all RCS cold leg temperatures > 365'F (Unit 1),
> 301*F (Unit 2).
ACTIONS
..................................--NOTES-------------------............-....
- 1. Separate Condition entry is allowed for each PORV and each block valve.
S ! 2. LC0 3.0.4 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME , A. One or two PORVs A.1 Close and maintaia 1 hour inoperable and power to associated capable of being block valve. manually cycled.- ; 1
.CALVERT CLIFFS - UNITS 1 & 2 3.4.11-1 Revisionp/'5
Pressurizer PORVs 3.4.11. ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME E. Two block valves- E.1 Place associated I hour inoperable. PORVs in override closed. AND E.2 Restore one block 72 hours valve to OPERABLE status. F. Required Action and F.1 Be in MODE 3. 6 hours associated Completion Time not met. AND F.2 Reduce any RCS cold 12 hours leg temperature g L
$ 365'F (Unit 1).
s 301*F (Unit 2).
-SURVEILLANCE REQUIREMENTS-SURVEILLANCE FREQUENCY.
SR 3.4.11.1 Perform a CHANNEL FUNCTIONAL TEST of each 92 days PORV. CALVERT CLIFFS - UNITS 1 & 2 3.4.11-3 Revisiong5'
Pressurizer PORVs B 3.4.11 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) BASES BACKGROUND The pressurizer is equipped with two types of devices for pressure relief: pressurizer safety valves and PORVs. The
= . m PORV is an electric, solenoid operated valve that is - l 5 .e automatically opened at a specific set pressure when the pressurizer pressure increases and is automatically closed on decreasing pressure. The PORV may also be manually operated using controls installed in the control room.
An electric, motor operated, normally open, block valve is installed between the pressurizer and the PORV. The function of the block valve is to isolate the PORV. Block valve closure is accomplished manually using controls in the control room and may be used to isolate a leaking PORV to permit continued power operation. Most importantly, the block valve is used to isolate a stuck open PORV to isolate l the resulting small break loss of coolant accident (LOCA), Closure terminates the RCS depressurization and coolant inventory loss. The PORV and its block valve controls are powered from normal power supplies. Their controls are also capable of being powered from emergency supplies. Power supplies for the PORV are separate from those for the block valve. Power supply requirements are defined in NUREG-0737, Paragraph II,
" G.1 (Ref. 1). ---
The PORV setpoint is equal to the high pressure reactor trip setpoint and below the opening setpoint for the pressurizer safety valves as required by Reference 2. The purpose of the relationship of these setpoints is to reduce the frequency of challenges to the safety valves, which, unlike the PORV, cannot be isolated if they were to fail open. l5 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-1 Revisiong5
Pressurizer PORVs - B 3.4.11 BASES The possibility of a small break LOCA through the PORY is reduced when the PORV flow path is OPERABLE. The possibility is minimized if the flow path is isolated. Overpressure protection is provided by safety valves, and analyses do not take credit for the PORV opening for accident mitigation. Pressurizer PORVs satisfy 10 CFR 50.36(c)(2)(ii), Criterion 3. LCO The LCO requires the two PORVs and their associated block-l valves to be OPERABLE. The block valve is required to be l OPERABLE so it may be used to isolate the flow path if the ! PORV is not OPERABLE. Valve OPERABILITY also means the PORV setpoint is correct. Ensuring the PORV opening setpoint is correct reduces the frequency of challenges to the safety valves, which, unlike the PORVs, cannot be isolated _if they were to fail open. g APPLICABILITY In MODES 1 and 2, and MODE 3 with all RCS cold leg !5 temperatures > 365'F (Unit 1), > 301*F (Unit 2), the PORV and its block valve are required to be OPERABLE to limit the potential for a small break LOCA through tha flow path. A likely cause for PORV small break LOCA is a result of pressure increase transients that cause the PORV to open. Imbalances in the energy output of the core and heat removal by the secondary system can cause the RCS pressure to increase to the PORV opening setpoint. Pressure increase transients can occur any time the steam generators are used for heat removal. The most rapid increases will occur at higher operating power and pressure conditions of MODES 1 and 2. Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-3 Revision Efr
Pressurizer PORVs B 3c4.11 BASES Therefore, this LCO is applicable in MODES 1 and 2, and MODE 3withallRCScoldlegtemperatures>365'F(Unit 1), l6
> 301'F (Unit 2). The LCO is not applicable in MODE 3 with all RCS cold leg temperatures s 365'F (Unit 1), s 301*F (Unit 2), when both pressure and core energy are decreased and the pressure surges become much less significant. The PORV setpoint is reduced for LTOP in MODE 3 with T.y 5 365'F (Unit 1), s 301*F (Unit 2)_ and in MODES 4, 5, and 6 with the: F ;"CC -
reactor vessel head in place. 'LCO 3.4.12 addresses the PORV ' requirements in these MODES. ACTIONS The ACTIONS are modified by two Notes. ! Note 1 clarifies that the pressurizer PORVs and block valves are treated as f separate entities, each with separate Completion Times (i.e., the Completion Time is on a component basis). Note 2 is an exception to LCO 3.0.4. The exception to LC0 3.0.4 permits entry into MODES 1, 2, and 3 to perform cycling of the PORV or block valve to verify their OPERABLE status. Testing is typically not performed in lower MODES. A.1 With one or two PORVs inoperable and capable of being manually cycled, either the inoperable PORV(s) must be restored or the flow path isolated within 1 hour. The block valve should be closed but power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. Although the PORV may be designated inoperable, it may be able to be manually opened and closed and in this manner can be used to perform its function. Power operated relief valve inoperability may be due to seat leakage, instrumentation problems, automatic control problems, or other causes that do not prevent manual use and do not create a possibility for a small break LOCA. For these reasons, the block valve may be closed but the Action requires power be maintained to the valve. This Condition is only intended to permit operation of the plant CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-4 Revision 5
Pressurizer PORVs B 3.4.11 BASES within 72 hours and the remaining block valve in 5 days, per g Required Action C.2. The Completion Time of 1 hour to either restore the block valves or place the associated PORVs in override closed is reasonable based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. F.1 and F.2 ' If the Required Actions and associated Completion Times are not met, then the plant must be brought to a MODE in which the LC0 does not apply. The plant must be brought to at least MODE 3 within 6 hours and reduce any RCS cold leg 5 temperature s 365*F (Unit 1), s 301*F (Unit 2) within 12 hours. The Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging safety systems. Similarly, the Completion Time of 12 hours to iy reduce any RCS cold leg temperature s 365*F (Unit 1), I s 301*F (Unit 2) is reasonable considering that a plant can cool down within that time frame. In MODE 3 with any RCS cold leg temperature s 365'F (Unit 1), s 301*F (Unit 2) and 5' in MODES 4, 5, and 6. maintaining PORV OPERABILITY is required per LC0 3.4.12. SURVEILLANCE SR 3.4.11.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each PORV instrument channel every 92 days to ensure the entire channel will perform its intended function when needed. SR 3.4.11.2 Block valve cycling verifies that it can be closed if necessary. The basis for the Frequency of 92 days is American Society of Mechanical Engineers (ASME) Section XI CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-7 Revision #5' j
S p <,khn c+ E. A.1\ , b 34 W EMIGL.1991ML1Y112 ges g 3/' .0.; - - -- , ~~_ ven RELIEF VALVES __ .fp,'sdoteI'__fedte opaded 9.U% V*Iv's (I'OM Q v::::: LIMITING CO MITION FOR OPERATION W 34.0 PORVs i tsecit 3 L3.sha1 valves Two 5r-obrated OP tE. relief valves ye g APPLICABILITY: MODES 1. 2. and 3 .
# d; g
, k'd y.
ACTION: [ [c k'j;.[J- II) ic A rr.s A 's .lf o. a th PORY s Ikas excessive int i ni;;;. within 1 hour c1 the associate lock valvejs) and maintain power to the block valve (s).
@ .rb;{h286Mh
- t. ilth one P0RY ino rable L ; ^ n_n. :ttn tix x:_xM =;
Atr um B r :t i n k ;;. wit in 1 hour ther restore the PORV to OPERABLE status or close the associa d block valve and remove power " rom sthe block valves restore t s Asuo F ?!!;.t 5 days or be in OT STANDBY within hours the nextPORYhto OPERABLE land at or below 365'T withl n the following hours. w lith both PORVs inoperableOhe t: ;..... 3;r thn nanM gview D - 51.' :nt tri:;;. within 1 hour either restore one PORV to OPERABLE status or close the associated block valve and remove power from_the block valves restore one PORY to OPERABLE status Awithinaw/fpHoving 72 hours or be in NOT STAND 8Y within the Acre.n f ex
, ours and at or below 365'r within the following Al
- d. filith one or both block valve (s) inoperable, within I hour restore A " ' .
the block valve (s) to OPERABLE status or place its associated PORV(s)inoverridecl {^.. d44 OPERABLE status within Restore at least one block valve to inoperables restore anyJe 72 hours if both block valves are inoperable block valve to OPERABLE status within 0Ke_ma'n Ln# E o= M a 5 dayst otherwise, be in at A r,,a least NOT STAND 8Y within the next g within the following ours and at or below 365'F urs. i
% The provisions of Spec ation 3.0.4 are not appitcable. l I
-.o Je h
{m.samAenerl Above 365'F) At ., L;h., ;"/,7. ;W at'= 2/' '.0. ;;,;,l'a l CALVERT CLIFFS - UNIT 1 3/4 4-7 Amendment No. 188 1 e l _a
Sp er .%a .n 's A . t l 3.i lf/414 REACTOR C00LANTJYSTDI Q 3,q,el 4/?.?. EUEF 'fALVES _ _ _ _ _ _]_.y. OK4 4 Q, W V. I_cv (,PQRV
~
LC D LIMITING CON 01110N FOR 6PERATION " g
)*. 4 gg - 1.h t Two valves shal be r-o ersted DP RABLE. relief valves (P3Vs).And)1 ehetc.auociatept 6 115 m d.h y sj%HC APPLICABILITY: M00FS .
blos k vc- v %. .w-ACTION: [ ,y a/,, d,} _ hi}
~~
L- . \ A K.' pne or both PORV( has-evessive-4 sat 4eeketo vithin 1 hour c c%e the associated lock valve (s) and maintain power t_o the blockvalve(s)* "v- -~ Q' onag g"lE s Ac.voM r e n I* ith one PORY No rable m' _e
== the tha annhi =r -
Q N W , sit in 1 hour eith restore the PORY to OPEBABLE status or close the associated ock valve and remove power Ac7WM @ the block valves restore the P0 to OPERABLE status within
'5"e.h.,- 5 days or be in NOT ANDBY within the next F hours and at or below 301'F within he following ours. J g -1 Ac6og h ith both PORVs inoperable m.e te cevin vinwr den mmi..
O F "et '- 9 ;t, within 1 hour either restore the PORVs to OPERA 8LE statut or close its associated block valve and remove ower from the block valves restore one FCRV to OPERAILE status
/\r7 'oM ithi "r.; fe ;2iiin?2 hours or be in N01 STAND 8Y within the , ~,G' p xt our n
" g y band at or below 301'F within the following l
d. 6t> g A #MS itb one or both block valve (s) inoperable, within 1 hour restore the block valve (s) to OPERABLE status or place its associated
- c.
- E PORV(s) in override closed. Restore at least one block valve to e OPERABLE status withint%M:MID 72 hours if both block valves are 14 I inoperable restore anylemaining inoperable block valve to gg PERABLE status within t M "._..- @ 5 days; otherwise, be in at g' ,
p least NOT STAND 8Y within the next hours and at or below 301'F A within the following urs. (g l
- Ac.1.aN$ % The provisions of Specif cation 3.0.4 are not applicable.
NoTEL
- =n= m -_
f,sL - a.\ l 98SreId %AMY $ Ard to
/ MoDB ~3 A pp l.c b t. 4 y ove 301tF) -At r hhr 3017.-Spalfint5 ? d 0 ' epm hs. -
l CALVERT CLIFFS - UNIT 2 3/4 4-7 Amendment No. 178 po$c I of 2
DISCUSSION OF CIIANGES SECTION 3.4.11 - PRESSURIZER PORVs ADMINISTRATIVE CllANGES A.1 The proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change ofintent, to be consistent with NUREG 1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs ITS development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical SpeciGcations. Additional information may also have been added to mora fully describe cach LCO and to be consistent with NUREG-1432 l{owever, the additional information does not change the intent of the current Technical Specifications. The reformatting, renumberint. and rewording process involves no technical changes to existing Specificailons. A.2 Current Technical Specification 3.4.3 Applicability footnote ' contains a reference that below 365'F (301'F for Unit 2) the LTOP Technical Specification applies. Improved Technical Specification 3.4.11 deletes this reference. In general, the iTS does not reference 4 l ' other Specifications, in this case, the Applicability for this Specification and the LTOP Specification are precise enough so that no confusion should exist as to which Technical Specification applies. Deletion of this unwarranted reference constitutes an administrative change. This change is consistent with NUREG 1432. A.3 Not used. l A.4 Current Technical Specification 3.4.3 requires the Specification to be applicable in Modes I and 2, and Mode 3 above 365'F (above 301'F for Unit 2). Improved Technical Specification 3.4.11 specifies that in Mode 3 the Specification be app'icable with all RCS cold leg temperatures > 365'F (> 301'F for Unit 2). This change is administrative because this is consistent with current Calvert Cliffs practice. This change is consistent with NUREG-1432. A,5 Current Technical Specification SR 4.4.3.1.a requires each PORV to be demonstrated Operable by performance of a Channel Functional Test in accordance with Table 4.3-1, item 4. Table 4.3-1, item 4 provides the Surveillance Requirements for Pressurizer Pressure
- liigh teactor trip. Improved Technical Specification SR 3.4.11.1 requires a Channel Functional Test of each PORV. Current Technical Specification SR 4.4.3.1.a has been revised to be consistent with ITS SR 3.4.11.1; the reference to Table 4.3-1, item 4 has been deleted. This proposed change is an administrative change, becau.e a Channel Functional Test of each PORV will be required to be performed in accordance with ITS SR 3.4.11.1, -
and the Channel Functional Test for the pressurizer presrure - high reactor trip will be required to be performed in accordance with ITS SR 3.3.1.4 for item 4 of Table 3.3.1-1. In addition to the justification provided above, this proposed change is consistent with NUREG-1432. A.6 Current Technical Specification LCO 3.4.3 does not specify a method for tracking allowable out of service times. Note I for the Actions ofITS LCO 3.4.11 states that separate condition entry is allowed for each PORV and each block valve. This note provides a methodology for tracking Completion Times, it allows the Conditions and Completion Times to be entered and tracked separately for each inoperable PORV or block valve. In the ITS, once a CALVERT CLIFFS - UNITS 1 & 2 3.4.11-1 Revision 5
Pressurizer PORVs
- 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (Mys) '
LCO 3.4.11 POR$nd associated block valv@ hall be OPERA 8tt. APPLICABILITY: MODES 1 _2, X g .g(., v) I l ACTIONS M**G 3 w.R cd l /cS e ld J.ry h~runl= > Sol T6 $
' - ~ * ^ ' ^ ^ ~
^
~
( Qc)(. A . 6 .... . _ .... 1.- . - . - . - ..N0TES- - - .- - J,4 ? Separate Condition entry is allowed for each POR - - - - Ae6 e 2. LC0 3.0.4 is not applicable. Mron c bdoc g_\ _ CONDITION REQVIRED ACTION COMPLETION' TIME 34.3 A. One or PORVs Aerys A.1 Close and maintain inoperable and capable I hour of being manually power to associated cycled block valve. B. D *3 One PORY ino etable B.1 Close associated and not capa le of I hour Ahea b being manually cycled. block valve. 8bD B.2 Remove power from I hour associated block valve. B.3 Restore PORY to A @ l OPERABLE status. (continued) CEOG STS 3.4 22 Rev1,04/07/95 , {_ ..
. . . . _ . ~
4 Pressurizer PORVs . 3.4.11 ACTIONS CONDITION REQUIRED ACTION , COMPLETION TINE x
- Ig (continued) .2 Restore ;t ';;;; one rs il block valve to OPERA 8LE status.
Required Action and 1 Be in N00E 3. 6 hours 3.4.3 5% '55'Ct'dCT____'Li'" Ti . _ . _ .. f,}g 2 f. G C k!![ hours SURVEILLANCE REQUIREMENTS M P S L W d !~IQ @ le SURVEILLANCE FREQUENCY l- i & { A,1, SR 3.4.1 -------------------NOTE------------------ m Not required to be performed with block W valve closed in accordance with the Required Actions of this LCO. Perfonn a complete cycle of each block A(92 days} *- valve.
"M 5R 3.4.1 Perform a complete cycle of each PORY.
months rSR 3.11.3 Perform a e ete cycle of each solenoid
.3) months
_+ l air control alve and check valve on the air acc tors in PORV control systems. / M ntinued)
' U 'i AGm s (,9%etu o cauta.*w*J A.1.l.L of esk3mg 24% A sr. 3 O. ) ~ C G[g htA44EE [*dW""'
- w-[" & -
C T gp 3~4-74 Rev 1, /07/95 4.4 3.l . ct,
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3A - REACTOR COOLANT SYSTEM itself better to be in the SRs where the as-found values and as-!cft values are specifically listed. Placing tnese values in the LCO would have split the required tolerances in two different places within the Specification (the as founds in the LCO and the as lefts in the SR). This change is plant specific because Calvert Cliffs has different setpoints for each Pressurizer Safety Valve, and two different as-found tolerances for one of the Safety Valves. His change was found to make the Specification less confusing to the Operations staff. 9 NUREG-1432 LCO 3.4.10 is applicable in Modes 1 through 3, and Mode 4 with all RCS cold leg
- temperatures > [285]'F. Improved Technical Specification 3.4.10 will be applicable in Modes I through 2, and Mode 3 with all RCS cold leg temperatures > 365'F for Unit No.1, and > 301'F y.
for Unit No. 2. This deviation is acceptable, because the pressurizer safety valves are only needed to provide overpressure protection of the RCS in: a) hbdes 1 and 2 for Units 1 and 2, b) -- Mode 3 with all RCS cold leg temperatures > 365'F for Unit 1; and c) Mode 3 with all RCS cold ' leg temperatures > 301'F for Unit 2. In Mode 3 with the RCS cold leg temperatures s 365'F for Unit I and s 30l*F for Unit 2, and Modes 4 and 5 for both Units, overpressure protection of the RCS is provided by the low temperature overpressure protect:ce (LTOP) system. ne i requirements for the LTOP system are contained in ITS 3.4.12. Additionally, this deviation is consistent with the intent of NUREG 1432. The Bases for the Applicability of NUREG 1432 LCO 3.4.10 states that the LCO is not applicable when overpressure protection is provided by the LTOP system. To support this deviation, Required Action B.2 was revised to reflect the Applicability of ITS 3.4.10. The revised Required Action will require the plant to be placed in Mode 3 with all RCS cold leg temperatures less than or equal to 365'F for Unit 1 or 301'F for Unit 2; this is a ! condition where the ITS LCO will not be applicable. This proposed change is consistent with the Bases of NUREG-1432 LCO 3.0.2 which states if a Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a Mode or condition in which the specification is not applicable. 10. Specification 3.4.ll (power-operated relief valves [PORVs]) Applicability was changed from Modes 1,2, and 3, to Modes I and 2, and Mode 3 with any RCS cold leg temperatures > 365'F l (301*F for Unit 2). This change is specific to Calvert Cliffs and was made because the LTOP System Specification provides requirements for the PORVs in Mode 3 with any RCS cold leg temperature s 365'F (30l*F for Unit 2), and in Modes 4 and 5, and Mode 6 with the head on. Appropriate-Actions were adjusted to account for this Mode of Applicability change. This change is consistent with Amendment Nos.188 and 165 (for Units I and 2, respectively) and the accompanying Safety Evaluation Report, dated April 20,1994. 11. Specification 3.4.11 Completion Times were changed to be consistent with Calvert Cliffs Amendment Nos.188 and 165 (for Units 1 and 2, respectively) and the accompanying Safety Evaluation Report, dated April 20,1994. l 12. NUREG-1432 3.4.11 was developed assuming the pressurizer PORVs are air operated valves. Thus, it contains a surveillance to perform a complete cycle of each solenoid air control valve and check valve on the air accumulators in the PORV control systems. At Calvert Cliffs, the -
' pressurizer PORVs are electric solenoid operated valves; they are not air operated valves. Thus, ITS 3.4.11 does not include the NUREG-1432 surveillance to perform a complete cycle of each solenoid air control valve and check valve on the air accumulators in the PORV control systems.
CALVERT CLIFFS-UNITS 1 & 2 3.4-2 Revision 5
DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM Additionally, two plant specific surveillances have been added to ITS 3.4.11. CTS SRs 4.4.3.1.a and 4.4.3.1.b require the performance of a Channel Functional Test and Channel Calibration for each PORV. These requirements have been maintained, because they provide assurance that the PORVs' actuation channels will perform their intended function, and the PORVs will open at the appropriate setpoint.
- 13. He Note in NUREG 1432 SR 3.4.1.4, which allows the measured RCS total flow rate to not be performed until 24 hours after 2 90% Rated ucrmal Power, is being deleted. Calvert Cliffs uses a pump differential pressure method that can be performed neurately in Mode 3. This change is consistent with Calvert Cliffs' current operating practices.
14. The requirements of NUREG 1432 Specification 3.4.12, Low Temperature Overpressure Protection (LTOP) System, are modified to reflect the Calvert Cliffs specific LTOP analysis requirements as reflected in the CTS 3.4.9.3. The requirements of CTS 3.4.9.3.d and 3.4.9.3.e are reflected in the ITS LCO 3.4.12.a.1; a maximum of one IIPSI pump only capabic of manually injecting into the RCS, with the CTS details of how to accomplish these requirements moved to the associated ITS Bases. The requirements of CTS 3.4.9.3.d are reflected in ITS LCO 3.4.12.a.2; when llPSI suction is aligned to the Refueling Water Tank, the IIPSI pump shall be in manual control and either HPSI How is limited to s 210 gpm or an RCS vent of 2 2.6 square inches established. The requirements of CTS 3.4.9.3.c and the associated # note are reflected in ITS LCO 3.4.12.b and Note; HPSI loop i motor operated valves (MOVs) only capable of manually aligning IIPSI flow to the RCS and llPSI loop MOVs may be capable of automatically aligning HPSI flow to the RCS for the purposes of testing, with details of how to accomplish the requirements moved to the ITS Bases. l l The requirements of CTS 3.4.9.3.a.1, a.2, and a.3 and the
- note are reflected in ITS LCO 3.4.12.c.1, c.2, and c.3; which provide requirements for PORVs (and lift settings), block valves, vents, and PORV lift settings when on shutdown cooling. The corresponding CTS requirements were provided in Amendment 145 (Unit 1) and Amendment 131 (Unit 2) except for the LTOP enable temperature and PORV lift settings which were revised to their current values in Amendment 188 (Unit 1) and Amendment 178 (Unit 2).
The requirements in NUREG-1432 Specification 3.4.12 regarding Safety injection Tanks (SIT) are not included in ITS 3.4.12 since an inadvertent or spurious opening of the SIT outlet motor operated valves at Calvert Cliffs has no effect on the limiting LTOP analysis. The Calvert Cliffs SlT pressure is less than 400 psia; the Calvert Cliffs LTOP allowed pressure is over 400 psia. Herefore, the SITS will not cause t. mass addition when the RCS is at or near the LTOP allowable pressure. In addition, the limiting mass addition transient (inadvertent HPSI pump start) is initiated at over 400 psia in the analysis. Therefore, even a simultaneous opening of the SIT motor operated valve and start of the HPSI pump will not affect the analysis. Not including these requirements in the Calvert Cliffs ITS is consistent with the current licensing basis reflected in CTS 3.4.9.3. The requirements in NUREG-1432 Specification 3.4.12 regarding charging pumps are not included in the Calvert Cliffs ITS. Not including these requirements in the Calvert Cliffs ITS is consistent with the current licensing basis reflected in CTS 3.4.9.3. The amendment requests (submitted in letters dated May 14, 1990 for Unit I and October 22, 1990 for Unit 2) that. supported the issuance of CTS 3.4.9.3 requirements in their current form identified charging CALVERT CLIFFS-UNITS 1 & 2 3.4-3 Revision 5 l o
l i: I Pressurizer PORVs 8 3.4.11 8 3.4 REAC10R COOLANT SYSTEM (RCS) I B 3.4.11 Pressurizer Power Operate PORVs) BASES
~
'I # O 6
BACKGROUND
)
The pressurf pressure er is equipped re eft pressurizer s of devices safety v with two tbes for and FORVs PORV is . The -"-# operated valve that is automatically opened ! at a specific set pressure when the pressuriter pressure increases and is automatically closett on decreasing pressure. The P3RV may also be manuall controls installed in the control room.y operated using An electric, motor operated, normally open, block valve is installed between the pressurizer and the PORV. The function of the block valve is to isolate the P0RV. Block valve closure is accompitshed manually using controls in the control roce and may be used to isolate a leaking PORV to permit continued power operation. Most importantly, the block valve is used to isolate a stuck open p0RV to isolate the resulting small break loss of coolant accident (LDCA Closure terminates the RCS depressurization and coolant ). leventory loss. The PORY and its block valve controls are powered from normal power supplies. being powered free emergency supplies.-Their Power supplies controls for are also capable of the PORV are separate from those for the block valve, Power supply requirements are defined in NUREG-0737, Paragraph {,G.1(Ref.1). g,,,j ,A The PORY setpoi_nt is;above. the high pressure reactor trip egud 4= setpoint and below the opening setpoint for the pressurizer safety valves as required by Reference 2. the relationship of these setpoints is toJTiin sne nThe purpose _of BY"TFens 'nt y m sure insrs. e Wa i i ... the , which, if opened, uld f"all ..inthat might n The V setpoint thus lie the open ition. f transients and limi the possibility of a L from a _failed
. . _...... .., ope RV. the frequency Pla 11ofbrencha enges }k a+ halaw
.. .. ....,cing the set _
frequency of challenges to the safety valves, whic_unlike ..mniny , educe, t,,e k_ the PORV, cannot be isolated if they were to fall open. The rimar
.s purpose of this LC0 is to ensure that the PORV/
and the block valve are operating correctly so "g ,gg, (continued) CEOG STS B 3.4-4B Rev 1, 04/07/95 [ . ____ _. .
Pressurizer PORVs B 3.4.11 8ASES APPLICABLE kn ..... i. SA ES . %% ... ;., .L;,r...
;,. 0 ; f ' ---"-- *
- M " = ". N" - : ' '
mi h ivi h i,,.... = i.J _ Overprissure protection is provided by safety valves, and analyses attigation. accident do not take credit for the PORV opening for
.. ,_ ,a Pressurizer PORVs satisfy Criterion 3 of the NRC Policy Statement.
s
^ LC0 + The LC0 requires th and pc]u,, j k be OPERABLE.
it sa sociated block valv The block valve is required to be OPERA 8L o o OPE be LE. used to isolate the flow path if the PORY is not ' O{
$r a$ v'~)
cb 6 . s J OPERABILITY also means the PORY setpoint is corres surin t( y uLa,gyunliL %j veu 64 h ab the PORv is nr,/subfi~t p ssure icreas transi to fr onenin, setooint is correen1the uent
, an c Henges ros pos ible herefo the d
tied o en PORV sibil no It y o a cMnof ho break LOCA th ugh a equen even g k : ppg( t/4,,bf N 9 ,_m _ ~ ~ - g g.jp.,n)
' *1 & c4 b Ave'M N/'r G.d O
" TT in MODES ve are
{ requiredtfbeOPERABLEtolimitthepotentialforasmall break LOCA through the flow path. A likely cause for PORV that cause the PORY to open.small break LOCA is a result of pressure increas Imbalances in the energy output of the core and heat removal by the secondary system can cause the RCS pressure to increase to the PORY opening setpoint. Pressure increase transients can occur any time the steam generators are used for heat removal. rapid increases will occur at higher o The most pressure conditions of NODES 1 and 2. perating power and
- Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is h1 Therefore, this LCO is applicable in MODES 1 The LCO is not applicable in,M00E-4 when both pre, 2, and 3. pc6 energy are decreased and the pressure surges sure a less significant. The come auch RV setpoint is red .ed for LTOP in 2
we i in,Je 3 J m3 M5 c a p f*-ssn M
@,'[f.N, ^
'g
% _-w (continued)
CEOG STS B 3.4-50 Rev1,04/07/95 l (
Pressurizer PORVs B 3.4.11
-BASES ACTIC;45 1 and '
(continued) eeMeet is reasonable based on the small potential for h challenges to the systen during this time and provides the operator time to correct the situation, Qf, a0f y,c;rta= z h
~v w w., w . s, &.m a"O~
m If the Required Ac ons and associated Completion Times e txf"-- E -- f a e not met, then the lant must be brought; to a MODE in whic the LCO does not app y. The plant must be brought to at att MODE 3 within 6 ours and ** r . ,g within 12 hours. The Completion Time of 6 hours is reasonable, base on operating experience, to r?ach MODE 3 from full safety power n an orderly manner and without challenging system Similarly, the Completion itse of 12 hours y Saa b to :;0, Z4 is reasonable considering that a plant can cool down within that time frame -- - '-" -^- ^-- E InfM5Db saae+, intaining
~ requ1redr RABIL11Y -
LCO 3 A.12. . - ses Wu +0 A*S_IW!9fW***** f 3fI *b'")),,,,e /,, g~ SURVEILLANCE SR 3.4.11 - REQUIREMENTS Block valve cycling veriffes that it can be closed if necessary. The basis for the Frequency ofM92 dayst'Is ASME II (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance beca'use opening the block valve is necessary__to permit the PO to be used for manual control of tetet6r pressure, if the g#3 @ block valve is closed to isolate an otherwise inoperable PORY, the maximus Completion Time to restore the PORV and open the block valve is ?Z hours, which is well within the~ allowable limits (25%) to extend the block valve surveillance interval of8 requirements would be comp leted(92 days}f by the Furthermore, reopening of a these test recently closed block valve upon restoration of the PORY to OPERABLE status (i.e., completion of the Required Action fulfills the SR}. The Note modifies this SR by stating that this SR is not reautred to be performed with the block valve closed in accordance with the Required Actions of this LCO. (continued) CEOG STS B 3.4-54 Rev1,04/07/95
- 24. The NRC requested additionaljustification for the changes to Actions a, b, and c of identified in the markups of CTS 3.4.3 ior ITS 3.4.11. Discussion of Change L1 for ITS 3.4.11 and its associated NSilC have been revised to include additional justification for the changes to Actions a, b, and c of CTS 3.4.3 (ITS 3.4.11 Comment 4).
DISCUSSION OF CliANGES SECTION 3.4.11 - PRESSURIZER PORVs TECIINICAL CIIANGES - RELOCATIONS None TECilNICAL CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED - DDCUMENTS LA.1 Not used. l TECIINICAL CIIANGES - LESS RESTRICTIVE L.1 Actions a, b, and c of CTS 3.43 provide the required actions in the event one or two PORVs are inoperable. Action a provides the actions for one or two inoperable PORVs due to excessive seat leakage, and Actions b and c address one or two inoperable PORVs for causes other than excessive seat leakage, respectively. Actions A, B, and D ofITS 3.4.11 provide the required actions in the event one or two PORVs are inoperable. Action A provides the actions for one or two inoperable PORVs that are capable of being manually cycled. Actions B and D provide the actions for one or two inoperable PORVs that are incapable of being manually cycled, respectively. The CTS have been revised to reflect the ITS methodology for addressing PORV inoperability. These proposed changes are considered to be a less restrictive change, because they appear to broaden the applicability for Action a of CTS 3.43 and narrow the range of applicability for Actions b and c of CTS 3.43. Actually, excessive seat leakage is an example of an inoperable PORV which does not prevent the PORV from being manually cycled. Thus, this change could be interpreted as meeting the intent of the CTS. Action a of CTS 3.43 has been revised to be applicable when one or both PORVs are inoperable and the applicable PORVs are capable of being manually cycled, in the event this occurs, the inoperable PORV can be manually opened and closed to perform its function. Thus, the PORV should remain available so that the operators could manually utilize the relief pathway. For this condition, the prudent course of action is to close the block valve and maintain power to the block valve. This methodology permits the operators to have relatively quick access to the PORY for pressure control. If the power were removed from the block valve, additional operator actions would be required to manually utilize the pathway, Therefore, the proposed change to Action a of CTS 3.43 is acceptable. Actions b and c of CTS 3.43 have been revised to be applicable when the PORVs are inoperable and the valve is not capable of being manually cycled. In this case, the PORV cannot be used manually for pressure control, and the condition of the PORV may be uncertain. Thus, the prudent course of action is to secure the PORV by closing the block valve, and provide additional assurance that the PORV is isolated by removing power from the valves. Actions b and c of CTS 3.43 require these actions, and they also require the PORVs to be restored to an Operable status. Thus, the proposed changes to Actions b and c of CTS 3.43 are acceptable. In addition, at Calvert Cliffs, the PORVs are not credited in the accident analyses for overpressure protection during Modes 1,2, and 3 with the RCS cold leg temperature greater than the enable temperature for the Low Temperature Overpressure Protection System. In these Modes and specified conditions, the pressurizer safety valves are the mechanism CALVERT CLIFFS - UNITS 1 & 2 3.4.11-3 Revision 5 l
DISCUSSION OF CilANGES SECTION 3.L11 - PRESSURIZER PORVs
. credited for overpressure mitigation. Dese proposed changes are consistent with NUREO 1432.
L.2 Current Techniew Specifications require the PORV CllANNEL FUNCTIONAL TEST (CFT) to be performed every 31 days, in accordance with CTS Table 4.31, item 4. Improved Technical Specifications will decrease the Surveillance Frequency to 92 days. ne PORV actuation instrumentation is the same as that used for the RPS High Pressurizer Pressure Function, described in CTS Table 4.31, item 4. The RPS High Pressurizer Pressure Function CFT 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 Evaluation Report for Amendments 193 and 170 for Units 1 and 2, respectively, dated August 24,1994). In this report, the NRC stated that Calvert Cliffs had to satisfy three requirements necessary to extend the CIT Frequency. These requirements were: a) the licensee must confirm that they have reviewed instrument driflinformation for each channel involved; b) have to determine that drift occurring in that channel over the period of extended surveillance test interval would not cause the setpoint value to exceed the Allowable Value as calculated for that channel by the licensee's methodology; and c) should have onsite records of the as-found and as left values showing actual calculations and supporting data for planned future NRC audits. The NRC further stated that Calvert Cliffs met these three requirements and could extend the CFR Frcquency from 31 days to 92 days for certain instruments, including the liigh Pressurizer Pressure Function. Calvert Cliffs has l ' cvaluated this instrumentation as it relates to the PORV opening setpoint ensured that it meets the three requirements listed above. Since the PORV actuation and the High
. Pressurizer Pressure liigh Trip Setpoint share the same instrumentation and the signal that actuates the PORV is generated from the same portion of the instrument that actuates the RPS, this change is acceptable.
4 1 CALVERT CLIFFS - UNITS 1 & 2 3.4.11-4 Revision 5
NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM 2. Does the change create the possibility of a new or different Idad of meeldent from any previously evaluated? The proposed change adds a Note to the Applicability, which allows the pressurizer safety valve lin settings to be outside the limits of the 140 for 36 hours after entry into the Modes of Applicability, for the purposes of setting the pressurizer safety valve lift settings under ambient conditions. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction la margin of safety?
The proposed change adds a Note to the Applicability, which allows the pressurizer safety valve lift settings to be outside the limits of the LCO for 36 hours after entry into the Modes of Applicability, for the purposes of setting the pressurizer safety valve lift settings under ambient conditions. Allowing the pressurizer safety valves to be set at ambient conditions ensures a more accurate lift setting, which provides confidence that the pressurizer safety valves will lift when required to mitigate design basis accidents. Also, only one safety valve is allowed to be tested at a time; therefore, one pressurizer safety valve and both PORVs remain available to mitigate any l ' overpressure events that may occur. Therefore the change does not involve a significant reduction in a margin of safety, 3A11 Chanine L.1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? Action a of CTS 3.4.3 has been revised to be applicable when one or both PORVs are inoperable and the applicable PORVs are capable of being manually cycled. In the event this xcurs, the inoperable PORV can be manually opened and closed to perform its function. Thus, the PORV should remain available so that the operators could manually utilize the relief pathway, For this condition, the prudent course of action is to close the block valve and maintain power to the block valve. His methodology permits the operators to have relatively quick access to the PORV for pressure control, if the power were removed from the block valve, additional operator actions would be required to manually utilize the pathway. Actions b and c of CTS 3.4.3 have been revised to be applicable when the PORVs are inoperable and the valve is not capable of being manually cycled. In this case, the PORV cannot be used manually for pressure control, and the condition of the PORV may be uncertain. Thus, the prudent course of action is to secure the PORV by closing the block valve, and provide additional assurance that the PORV is isolated by removing power from the valves. Actions b and c of CTS 3.4.3 require these actions, and they also require the PORVs to be restored to an Operable status. The PORVs are not credited in the accident analyses for overpressure protection during Modes 1, 2, and 3 with the RCS cold leg temperature greater than the enable temperature for the Low Temperature Overpressure Protection System. In these Modes and specified condition, the pressurizer safety valves are the mechanism credited for overpressure mitigation. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do l CALVERT CLIFFS - UNITS 1 & 2 3-4-17 Revision 5
NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
The change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The PORVs are not credited in the accident analyses for overpressure protection during Modes 1, 2, and 3 with the RCS cold leg temperature greater than the enable temperature for the Low Temperature Overpressure Protection System, in these Modes and specified conditions, the pressurizer safety valves are the mechanism credited for ove pressure mitigation. Ilowever, the PORVs are the preferred method of relieving an overpressure event and will still be available to perform this function. Therefore, the change does not involve a significant reduction in a margin of safety. 14.11 Change L2 l 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? He proposed change decreases the Surveillance Frequency for the PORY Special Test Exception from 31 days to 92 days. Decreasing the PORV Special Test Exception Frequency to 92 days is not an initiator of any analyzed event. The FORV shares the same instrumentation as the Reactor Protective System Pressurizer Pressure liigh Function, which was approved for quarterly Channel Functional Testing in an NRC Safety Evaluation Report, dated August 24,1994, A plant specific setpoint drift analysis demonstrated that the observed changes in instrument uncertainties for extended Surveillance test intervals do not exceed the current 30-day setpoint assumptions. This provides confidence the 90-day test interval will not impact the ability of the PORV to perform its safety function. The change will not significantly alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? , The proposed change decreases the Surveillance Frequency for the PORV Channel Functional Test from 31 days to 92 days. The change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change, The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 3-4-18 Revision 5 _ . _ . _ _ _ _ _ . ' ' ' -. _ . . . . . _ . . . . _ _ _....,..-.-m ii..--.-,......--.i... .- -- ' '
- 25. He NRC requested additionaljustification for the deviations from the Actions identified in the markups of ISTS 3.4.11 in ITS 3.4.11. Justification for Deviation 11 to Section 3.4 has been revised to simply address changes to completion times. Justification for Deviation 35 to Section 3.4 has been added to provide justification for the deviations from Actions D, E, F, and G of the ISTS in ITS 3.4.11 (ITS 3.4.11 Comments 7 and 8).
Pressuriser PORY:
- 3.4.11
- ACTIONS (continued)
- CONDITION REQUIRED ACTION -
COMPLET!0N TIME 3A'3 C. One block valve C.1 Piece associated PORY (4cd.* ) 180Perable. ]- -_ I hour g
-. m ~
l$ C.2 Restore block valve (c.EQiD 72 b6g(B to OPERABLE status.
- 0. Requ ed Action and D.! in MODE 3. 6 ho
~as lated Completion .
T of Condition A, E .
, or C not met.
j
.2 Be in4100E 4.
f (12] hours] 1 Close associated I hour I TwoPORVsino$erable ard not capab e of block valves, being sanually cycled. cam C.
'2 Remove power from I hour '34 h,
. associated block valves, bsb<e ou PoAV M (
OPEuME s4b: .3 A nuut J. 1
'll hours g -
[.4 Be in MODE j il2] hrs) 34'3 "r . h = block valvesinoperable. 1 Place associated^ I hcur
' Ac4.6 cl PORVs in oere cb close h
(continued) CEOG STS 3.4-23 Rev1,04/07/95
i Pressurtzer PORVs gis> 3.4.11 ACTIONS CONDITION REQUIRED ACTION . COMPLETION TINE (continued)
.. c Restore ;; h ; one lb rs iL block valve to OPERABLE status.
. _ . . . . , . --e.-> -
quired Action and g,43
,yg associated Completion Time *(>^M!ttr "
1 Se in M00C 3. 6 hours h ---
,]ff .2 ii.- M C k!![ hours SURVEILLANCE REQUIREMENTS M25SLWMk @l&
SURVEILLANCE ~; - FREQUENCY 4,4,1, SR 3.4.1 ..---...-.-......--N0TE......--.-.---...... Hot. required to be performed with block valve closed in accordance with the Required Actions of this LCO. Perform a complete cycle of each block 2{92 days}" valve. 5 5[3.4.1 Perfone a complete cycle of each PORV. months fSR3 .11.3 Perform a e ete cycle of each solenold
~3
'z
.3] months air control alve and check valve on the -C air acc ators in PORV control systems. /
# 3' i' U *i Mms (kswes t. entinued) t w t u m *J 24 4 C(4MM m3 u. i
{e.i epy e,wa s .. n- er 32- ,o h . C T gr .-4 Rev 1,
~ ~ ~ ~
4/07/95 (4.4 3.1.n
DISCUSSION OF TECilNICAlo SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM itself better to be in the SRs where the as-found values and as-len values are specifically listed. Placing these values in the LCO would have split the required tolerances in two different places within the Specification (the as founds in the LCO and the as-lefts in the SR). His change is plant specific because Calvert Cliffs has different setpoints for each Pressurizer Safety Valve, and two different as-found tolerances for one of the Safety Valves. This change was found to make the Specification less confusing to the Operations staff. 9. NUREG-1432 LCO 3.4.10 is applicable in Modes 1 through 3, and Mode 4 with all RCS cold leg-temperatures > [285)'F. Improved Technical Specification 3.4.10 will be applicable in Modes 1 through 2, and Mode 3 with all RCS cold leg temperatures > 365'F for Unit No.1, and > 301'F for Unit No. 2. This deviation is acceptable, because the pressurizer safety valves are only w needed to provide overpressure protection of the RCS in: a) Modes 1 and-2 for Units I and 2, b) Mode 3 with all RCS cold leg temperatures > 365'F for Unit 1; and c) Mode 3 with all RCS cold leg temperatures > 301'F for Unit 2. In Mode 3 with the RCS cold leg temperatures s 365'F for Unit I and s 301*F for Unit 2, and Modes 4 and 5 for both Units, overpressure protection of the RCS is provided by the low temperature overpressure protection (LTOP) system. He requirements for the LTOP system are contained in ITS 3.4.12. Additionally, this deviation is consistent with the intent of NUREG-1432. De Bases for the Applicability of NUREG 1432 LCO 3.4.10 states that the LCO is not applicable when overpressure protection is provided by the LTOP system. To support this deviation, Required Action B.2 was revised to reflect the Applicability of ITS 3.4.10. The revised Required Action will require the plant to be placed in Mode 3 with all RCS cold leg temperatures less than or equal to 365'F for Unit 1 or 301'F for Unit 2; this is a condition where the ITS LCO will not be applicable. This proposed change is consistent with the Bases of NUREG-1432 LCO 3.0.2 which states if a Required Action is not completed within the specified Completion Time, a shutdown may be required ta place the unit in a Mode or condition in which the specification is not applicable. 10. Specification 3.4.11 (power-operated relief valves (PORVs]) Applicability was changed fror: Modes 1,2, and 3, to Modes 1 and 2, and Mode 3 with any RCS cold leg temperatures > 365'F l (30l*F for Unit 2). This change is specific to Calvert Cl;ffs and was made because the LTOP System Specification provides requirements for the PORVs in Mode 3 with any RCS cold leg temperature s 365'F (301*F for Unit 2), and in Modes 4 and 5, and Mode 6 with the head on. 4 , Appropriate Actions were adjusted to account for this Mode of Applicability change. This change is consistent with Amendment Nos.188 and 165 (for Units I and 2, respectively) and the accompanying Safety Evaluation Report, dated April 20,1994. 11. Specification 3.4.ll Completion Times were changed to be consistent with Calvert Cliffs Amendment Nos.188 and 165 (for Units I and 2, respectively) and the accompanying Safety Evaluation Report, dated April 20,1994. l 12. NUREG 1432 3.4.11 was developed assuming the pressurizer PORVs are air operated valves. Thus, it contains a surveillance to perform a complete cycle of each solenoid air control valve and check valve on the air accumulators in the PORV control systems. At Calvert Cliffs, the pressurizer PORVs are electric solenoid operated valves; they are not air operated valves. Thus, ITS 3.4.11 does not include the NUREG 1432 surveillance to perform a complete cycle of each solenoid air control valve and check valve on the air accumulators in the PORV control systems. CALVERT CLIFFS - UNITS 1 & 2 3.4-2 Revision 5
1)1SCUSSION OF TECilNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM systems are capable of being supplied by emergency power. Rus, the elimination of NUREG 1432 SR 3.4.11.4 from the ITS is consistent with other specifications. Fu thermore, the elimination of this SR is consistent with the liases of NUREG 1432 SR 3.4.11.4 which states:
"This Surveillance [SR 3.4.11.4] is not required for plants with permanent IE power supplies to the valves."
35. In the event two PORVs are inoperable and not capable of being manually cycled, Action E of NUREG 1432 LCO 3.4.11 requires the closure of and removal of power from the associated block valves within one hour, and it requires the plant to be placed in Mode 3 within six hours and Mode 4 within 12 hours . Mode 4 is a Mode for which the NUREG 1432 LCO 3.4.11 does not apply. Action c of CTS 3.4.3 provides actions to take when two PORVs are inoperable due j to causes other than exctssive PORV seat leakage. It requires: a) closure of the associated 1, lock valves; b) removal 6f power from the associated block valves; and c) restoration of one PORV to an operabh status within the following 72 hours. If any of these actions are not met, the CTS requires the plant to be placed in a Mode and condition for which the LCO does not apply. Actions D, E, F, and G for NUREG-1432 LCO 3.4.11 have been modified in ITS 3.4.11 to incorporate the current licensing basis provided in Action c of CTS 3.4.3. De proposed deviations include: a) adding an action to Action E of NUREG-1432 LCO 3.4.11 (i.e., Action D ' ofITS 3.4.11) that would permit restoration of one PORV to an Operable status in the event two PORVs are inoperable and are not capable of being manually cycled; b) eliminating Actions E.3 l and E.4 of NUREG-1432 LCO 3.4.11 from Action D ofITS 3.4.11; c) eliminating Action D of NUREG 1432 LCO 3.4.1i from ITS 3.4.11; d) revising Action G of NUREG-1432 LCO 3.4.11 (i.e., Action F of ITS 3.4.11) to apply to all the previous actions; and e) labeling Actions E, F, and G of NUREG-1432 LCO 3.4.11 as Actions D, E, and F ofITS 3.4.11. Action E of NUREG 1432 LCO 3.4.11 provides the actions for two inoperable PORVs that are not capable of being manually cycled. This Action is being revised to include a Required Action that would provide 72 hours to restore one of the PORVs to an Operable status. This new action provides a series of actions which lead to exiting the action. Thus, the shutdown requirements provided in Required Actions E.3 and E.4 of NUREG-1432 LCO 3.4.11 have been eliminated from ITS 3.4.11. In the event the Required Actions and the associated Completion Times of the revised Action E are not met, an action is needed that requires the plant to be placed in a Mode and condition for which the LCO does not apply. "This type of action is consistent with the philosophy of NUREG-1432. Also, Action c of CTS 3.4.3 contains an action which requires the plant to be placed in a Mode and condition for which the LCO is nu applicable in the event one of its required actions are not met within the specified completion time. Actions A, B, C and E of NUREG-1432 LCO 3.4.11 also require this type of Action. Actions D and G of NUREG-1432 LCO 3.4.11 contain actions to place the plant in a Mode and Condition for which the LCO does not apply. Action D of NUREG 1432 LCO 3.4.11 addresses the event where a Re luired Action and associated Completion Time cf Condition A, B, or C was not met, while Action G of NUREG -1432 LCO 3.4.11 addresses the event where a Required Action and associated Completion Time of Condition E is not met. In ITS 3.4.11, Action D of NUREG-1432 LCO 3.4.11 was consolidated into Action G of NUREG-1432 LCO 3.4.11, and Action G of NUREG-1432 LCO 3.4.11 was also revised to address the event where a Required Action and associated Completion Time of the revised Action E was not met. Due to the consolidation of Action D CALVERT CLIFFS- UNITS 1 & 2 3.4-9 Revision 5
DISCUSSION OF TECitNICAL NPECIFICATION DEVIATIONS FROM NUREG.1431 SECTION 3.1 - REACTOR COOLANT SYSTEM into Action O in ITS 3.4.11. Actions E, F, and O of NUREO.1432 LCO 3.4.11 were labeled as Actions D, E, and F in the ITS, nese proposed deviations from NUREG 1432 were necessary to incorporate the current licensing basis provided in CTS 3.4.3, as approved by the NRC in License Amendments Nos.188 and 165 (for Units 1 and 2, respectively) with a Safety Evaluation Report dated April 20,1994. In License Amendment Nos.188 and 165, the NRC accepted the 72 hour allowed outage time for restoring a PORV to an Operable status in the event both PORVs were Inoperable due to causes other than excessive seat leakage, nis allowed outage time provides a i ' more realistic opportunity to make repairs to the inoperable POR\ Thus, the plant would avoid unnecessary shutdowns, and would avoid entering the region when the PORVs are required to be o , , yg m.m operable for low temperature overpressure purposes, it is safer to attempt repairs ofthe PORVs - in Modes 1,2, and 3 with the temperature above the LTOP enable temperature, because the PORVs are not credited in the accident analyses in Modes I,2, and 3 with ternperatures above the LTOP enable temperature. During operations in Modes I,2, and 3 with the temperature above the LTOP enable temperature, the pressurizer safety valves are the credited means for overpressure protection in the accident analyses. %us, the proposed addition of the 72 hour allowed outage time to restore a PORV to an operable status to Action D ofITS 3.4.11 and the deletion of the shutdown requirements (Acti:.ns E.1 and E.2 of NUREO 1432 LCO 3.4.11) from Action D ofITS 3.4.11 are acceptable. To support this change, Actions D and O of NUREG 1432 LCO 3.4.11 had to be revised in ITS 3.4.11. These requirements ensure that the plant is placed in a Mode and condition for which the LCO does not apply in the event a Required Action and associated Completion Time are not met. Action D of NUIEG 1432 LCO 3.4.ll was incorporated into Action F oflTS 3.4.11, and Action F of ITS 3.4.11 was revised to apply to Condition D of ITS 3,4.11. The proposed deviations regarding Actions D and O of NUREG 1432 LCO 3.4.11 are considered to be acceptable, because the ITS continue to require the plant be placed in a Mode and Condition for which the LCO does not apply in the event a Required Action and its associated Completion Time are not met. 36. Note 1 of the Actions for ITS 3.4.11 was revised to pennit separate condition entry for the PORV block valves, his Note has been modifled to also permit separate condition entry for each PORV block valve, in the ITS, once a Condition has been entered, the subsequent discovery of another inoperable component expressed in the Condition does not result in soprate entry into the Condition, unless specifically stated. The Required Actions would continue to cpply to each~ additional failure, with Completion Times based on initial entry into the Condition, in the case of an inoperabic block valve, the initial action for ITS 3.4.11 Action C is required to be completed within one hour, if during this time, the second block valve becomes inoperable, ITS 3.4.11 Action C would permit very little time (less than an hour) to take the initial action for the second inoperable block valve, in the event separate condition entry was not explicitly stated, Also, this time would be more limiting than the initial Completion Time permitted by ITS Action E (l.c., one hour) which addresses the condition when both block valves are discovered to be inoperable. Rus, Note 1 ofITS 3.4.11 was revised to pennit separate condition entry for the PORY block valycs. CALVERT CLIFFS UNITS 1 & 2 3.4-10 ' Revision 5
- 26. 'the NRC requested additionaljustification for the deletion ofISTS SR 3.4.11.4 from ITS 3.4,11.
Justification for Deviation 34 to 3estion 3.4 has been added to provide the justification for deletion of this SR. Additionally, the ISTS Ilases markup for ISTS SR 3.4.11.4 has been revised to show that the justification for this deviation is JFD 2 to liascs Section 3.4, not JFD I to llases Section 3.4 (ITS 3.4.11 Comrnent 9). 1 l
Pressurtter PORVs . 3.4.!! j SURVffilANCE Rf0VIRIMfMTS (continued) SURVEILLANCE . FREQUENCY r M 3.9. .4 Verify PORVs and lock valve (s) are able (16] months of being power free an emergency supply. r A G.\ L-1 CEOG STS 3.4 25 Rey 1,04/07/95 4
DISCUSSION OF TECitNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM
- 31. The Actions for NUREG 1432 LCO 3.4.1 were modified to renect the Action requirements of CTS 3.1.5 for RCS cold leg temperature not being within limits. ne Action for CTS 3.1.5 1
requires the restoration of RCS cold leg temperature to within limits, or Thermal Power be reduced to less than 5% of Rated Thermal Power (l.c., Mode 2), ne Action for CTS 3.1.5 is the same regardless of which parameter (l.c., pressurizer pressure, RCS How rate, or RCS cold leg temperature) is out of limits. Hus, Action A of ITS 3.4.1 provides the requirements for restoration of the parameter, and Action D ofITS 3.4.1 provides the requirements for exiting the mode of applicability in the event the parameter cannot be restored to within limits within Iwo hours. 1 32, in NUREO 1432 LCOs 3.4.1.a and 3.4.1.b, the limits for pressurizer pressure and RCS cold leg temperature are expressed in ranges. In ITS LCO 3.4.1.a, only a minimum limit is established for pressurizer pressure. This limit is consistent with the initial assumption regarding pressurizer pressure in the Calvert Cliffs accident analysis. His limit was approved by the NRC in License Amendment No. 88 to Facility Operating License No. DPR 53 for Unit No.1, and License Amendment No. 61 to Facility Operating License No. DPR 69 for Unit No. 2. In ITS LCO 3.4.1.b, only a maximum limit is established for RCS cold leg temperature. His limit is consir*ent with the initial assumptions regarding RCS cold leg temperature in the Calvert Cliffa accident analysis. This limit was approved by the NRC in License Amendment No. 39 to Facility Operating License No. DPR 53 for Unit No.1 and License Amendment No. 9 to Facility Operating License No. DPR 69 for Unit No. 2. Thus, these deviations are consistent with the current licensing basis for Calvert Cliffs.
- 33. NUREG 1432 SRs 3.4.63,3.4.7.3, and 3.4.8.2 require the verification of the correct breaker alignment and indicated power available to the required pump that is not in operation.
NUREO 1432 SR 3.4.6.3 applies to the RCS and SDC pumps, while NUREG 1432 SRs 3.4.7.3 and 3.4.8.2 only apply to the SDC pumps. Current Technical Specification SR 4.4.1.3.1 requires the verincation of the correct breaker alignments and indicated power availability for the required shutdown cooling pumps and valves that are not in operation. NUREG 1432 SRs 3.4.63, 3.4.7.3, and 3.4.8.2 have been modlSed to renect the additional requirement to verify the correct breaker alignments and indicated power availability for the required shutdown cooling valves, which is consistent with the Calvert Cliffs current licensing basis. These SRs were modified by replacing the word " pump" with the words " loop components." The components required to be checked by the SRs will be denoted in the Bases. For the RCS loop, the required component is the RCS pump. For the SDC loop, the required components are the pump and the valves. 34. NUREG 1432 SR 3.4.11.4 requires the verification that the PORVs and block valves are capable of being powered by an emergency power supply. This surveillance does not exist in CTS 3/4.4.3. Improved Technical Speci0 cation 3.4.11 will not contain a surveillance to verify that the PORVs and block valves are capable of being powered by an emergency power supply. This is appropriate, because the PORVs and block valves are permanently powered by Class lE power supplies. Class IE power sources are backed up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under voltage condition, The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3t this SR has been maintained in ITS 3.8.1. Additional!y, the specifications for other systems that are supplied by a Class 1E power source (e.g., the safety injection systems) do not contain SRs to verify the CALVERT CLIFFS. UNITS I & 2 3.48 Revision S
DISCUSSION OF TECHNICAL SPECIFICATION I EVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM systems are capable of being supplied by emergency power. Thus, the climination of NUREG 1432 SR 3.4.11.4 from the ITS is consistent with other speel0 cations. Furthermore, the elimination of this SR is consistent with the Dases of NUREG 1432 SR 3.4.11.4 which states:
"This Surveillance [SR 3.4.11.4) is not required for plants with pennanent 18 power supplies to the valves."
- 35. In the event two PORVs are inoperable and not capable of being manually cycled, Action E of NUREG 1432 LCO 3.4.11 requires the closure of and remeval of power from the associated block valves within one hour, and it requires the plant to be placed in Mode 3 within six hours and Mode 4 within 12 hours . Mode 4 is a Mode for which the NUREG 1432 LCO 3.4.11 does not apply. Action c of CTS 3.4.3 provides actions to take when two PORVs are inoperable due to causes other than excessive PORV seat leakage, it requires: a) closure of the associated block valves; b) removal of power from the associated block valves; and c) restoration of one PORV to an operable status within the following 72 hours, if any of these actions are not met, the CTS requires the plant to be placed in a Mode and condition for which the LCO does not apply.
Actions D, E, F, and O for NUREG 1432 LCO 3.4.11 have been modlSed in IT9 3.4.1I to incorporate the current licensing basis provided in Action c of CTS 3.4.3. The proposed
- deviations include: a) adding an action to Action E of NUREG 1432 LCO 3.4.ll (l.c., Action D ofITS 3.4.11) that would permit restoration of one PORV to an Operable status in the event two PORVs are inoperable and are not capable of being manually cycled; b) eliminating Actions E.3 and E.4 of NUREG 1432 LCO 3.4.11 from Action D ofITS 3,4.11; c) el8minating Action D of NUREG 1432 LCO 3.4.11 from ITS 3.4.11; d) revising Action G of NUREG 1432 LCO 3.4.11 (l.c., Action F ofITS 3.4.11) to apply to all the previouJ actions; and c) labeling Actions E F, and G of NUREG 1432 LCO 3.4.11 as Actions D, E, and F ofITS 3.4.11.
Action E of NUREG 1432 LCO 3.4.11 provides the actions for two inoperable PORVs that are not capable of being manually cycled. This Action is being revised to include a Required Action that would provide 72 hours to restore one of the PORVs to an Operable status. This new action provides a series of actions which lead to exiting the action. Tims, the shutdown requirements provided in Required Actions E.3 and E.4 of NUREG 1432 LCO 3.4.11 have been climinated from ITS 3.4.11. In the event the Required Actions and the associated Completion Times of the revised Action E are not met, an action is needed that requires the plant to be placed in a Mode and condition for which the LCO does not apply."This type of action is consistent with the philosophy of NUREG 1432. Also, Action c of CTS 3.4.3 contains an action which requires the plant to be placed in a Mode and condition for which the LCO is not applicable in the event one of its required actions are not met within the specided completion time. Actions A, D, C and E of NUREG 1432 LCO 3.4.11 also require this type of Action. Actions D and G of NUREG-1432 LCO 3.4.11 contain actions to place the plant in a Mode and Condition for which the LCO does not apply. Action D of NUREG 1432 LCO 3.4.1I addresses the event where a Required Action and associated Completion Time of Condition A, B, or C was not met, while Action G of NUREO .1432 LCO 3.4.11 addresses the event where a Required Action and associated Completion Time of Condition E is not met. In ITS 3.4.11. Action D of NUREG 1432 LCO 3.4,11 was consolidated into Action G of NUREG-14321 CO 3.4.11, and Action G of NUREG. 1432 LCO 3,4,11 was also revised to address the event where a Required Action and associated Completion Time of the revised Action E was not met. Due to the consolidation of Action D CALVERT CLIFFS-UNITS I & 2 3.49 Revision 5
Pressortaer PORVs B 3.4.11 BA$t$
$URVt!LLANCE st 3.4.11 j Rt0VIREMENT5 (continued) 5R 3.4.11. . reoutres complete cycling of each PORV. PORY cilng 6 strates its function. The frequenc 2.
senths is based en a t 1 stry accepted practice.ypical refueling e and cyc)y of 4R-t-4-11-1 , ask[ [st (4
/ Operating the sol old air control val es and check valets
' on the air acc aters ensures the V control systee ! actuates proper y when called upon. he frequency of i (18]sonthsi based on a typical fueling cycle and th i Fro vene _ POR opt f se
! TY. other survatilan s used to demonstrat .
y 1R 3.4.11.4/ N This Su It pow see 111ance is not required for lants with parsanen supplies to the valves. 1 ncy power can be provided a test demonstrates t t b is perfonned by tr sferring power from the no supply to the see cy s~ ply and cycling the valves, heFrequencyof(1 s based on a typical refuel months practice, cycle and industry ccepted
% j 5
REFERENCES 1. NURIG-0737. Paragraph , C.I. November 1980. eA*d y**
- 2. Ins 21,pection 1979. and Enforcement (IE) Bulletin 79 058, Aprt)
(
- 3. A5MI, Boller and Pressure Yessel Code, Section XI.
CEOG STS 8 3.4 55 Rev1.04/07/95 _m . O
Y 27, 't he NitC requested DOC A.2 for 11S 3.4.13 to be revised to specify the ITS that addresses CTS SRs 4.4.6.2.a.2 and 4.4.6.2.c. Discussion of Change A.2 for ITS 3.4.13 has been revised to justify the deletion of CIS SRs 4.4.6.2.a.2 and 4.4.6.2.c from ITS 3.4.13; it includes a reference
- to the Actions of ITS LCO 3,4.14. which preserve the context of the CTS SRs (ITS 3.4.13 Cominent 2).
A 4 4
DISCUSSION OF CIIANGES SECTION 3.4.13 . MCS OPERATIONAL LEAKAGE AllMIMSIRATIVE CllAMjES i A.] He 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, i 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, censin wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional-Information may also have been added to more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional information does not change the intent of the current Technical Specifications. He refonnatting, renumbering, and rewording process involves no technical changes to existing Specl0 cations. A.2 Current Technical Sp;cification SRs 4.4.6.2.a.2 and 4.4.6.2.c contain requirernents that are associated with Actions from CTS LCO 3.4.6.1. These requirements have not been retained as surveillance requirements in ITS 3.4.13; they have been retained in the Required Actions of ITS 3.4.14. With the gaseous and particulate monitors inoperable, CTS SR 4.4.6.2.a.2 requires grab samples of the containment atmosphere be taken in accordance with the action requirements of CTS 3.4.6.1. This requirement is maintained as Required Action B.l.1 of ITS 3.4.14; this action requires grab samples of the containment atmosphere be analyzed when the required containment atmosphere radioactivity monitor is inoperable. The second part of CTS SR 4.4.6.2.c requires the RCS leakage be determined at least once per 24 hours when required by CTS Action 3.4.6.1.b, except when operating in the shutdown cooling mode. This requirement is maintained as Required Actions A.1 and B.I.2 of ITS 3.4.14; these ITS Actions provide requirements for determining RCS leakage at an increased frequency when RCS leakage detection instrumentation is inoperable. Deleting CTS SRs 4.4.6.2.a.2 and 4,4.6.2.c is an administrative change, because the requirements are redundant ' to Action requirements in ITS 3.4.14. In addition to the justification provided above, the proposed change is consistent with NtlREG 1432. A.3 Improved Techn! cal Specification 3.4.13 will add SR 3.4.13.2 to CTS 3.4.6.2. It rquires the - ver10 cation of Steam Generator (SG) tube integrity in accordance with the Steam Generator
- Tube Surveillance Program, Current Technical Specification 3/4.4.5 contains surveillances which ensure SO tube integrity is maintained. The SG tube integrity surveillances were moved to a program in ITS Chapter 5.0 (see the discussion of changes in ITS Chapter 5.0).
This proposed change is an administrative change, because it does not modify the operability requirements for the SGs contained in this specification (i.e., SO tube inspection requirements). hnproved Technical Specification SR 3.4.13.2 has si.nply been added to invoke performance of the SG Tube Surveillance Program, in addition to the justi0 cation provided above, this change is consistent with NUREG 1432. l A.4 Current Technical Specification 3.4.6.2.c requires a limit of I gpm primary-to secondary leakage through all SGs, and 100 gpd through any one SG. Improved Technical Specification 3.4.13 will only require a limit of 100 gpd through any one SG. He I gpm limit was deleted because the combined leakage from both SGs of 200 gpd is only a frrction of the gpm limit (the 1 gpm rate can never be reached). Deleting a limit that can no longer be reached is considered an administrative change. CAlWERT CLIFFS UNITS 1 & 2 3.4.13 1 Revision 5
- 28. The NRC requested that the deviations proposed by TSTF.138 be removed from the submittal.
This TSTF was rejected by the NRC. The fol'owing have been revised to exclude the changes proposed by TSTF 138: 1) the markups of Action a of CTS LCO 3.4.6.2 for ITS 3.4.13; 2) the markups of the Action of CTS LCO 3.4.5 for ITS 3.4.13; 3) the ISTS markup for ITS 1,CO 3.4.13; and 4) the ISTS Ilases markup for ITS 3.4.13. The ISTS 11ases markup for ITS SR 3,4.13.2 was changed to indicate that compliance with LCO 3.0.3 is required when one or more steam generators do not meet the requirernents of the Steam Generator Tube Surveillance Program. This deviation isjustined by JFD 13 to llases Section 3.4. Additionally, DOC A.3 and
- DOC A.5 for ITS 3.4.13 were revised to ensure consistency with the revised CTS markup and to l improve the justl0 cations. Also, DOC M.1 for ITS 3.4,13 was deleted, because it was no longer used (ITS 3.4.13 Comments 4,5, and 6).
Y
I RCS Operational LEAKAGE 3.4.13 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B .' Required Action and B.1 Be in H0DE 3. 6 hours associated Completion Time of Condition A N 6.NJ not net. B.2 Be in MODE 5. 36 hours l QB Pressure boundary LEAKAGE exists.- S SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 Verify RCS Operational LEAKAGE is within -.... NOTE .--. limits by performance of RCS water inventory Only required balance, to be performed e-during steady state operation 72 hours SR 3.4.13.2 Verify SG tube integrity is in accordance In accordance with the Steam Generator-Tube Surveillance with the Steam Program. Generator Tube Surveillance Program CALVERT CLIFFS - UNITS 1 & 2 3.4.13-2 Revision /iS'
RCS Operational LEAKAGE B 3.4.13 BASES The allowed Completion Times are reasonable, based on operating experience, to reach the required conditions from full power conditions in an orderly manner and without challenging plant systems. In H0DE 5, the pressure . tresses acting on the RCPB are much lower, and further deterioration is much less likely. SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance. Primary to secondary LEAKAGE is also measured by performance of an RCS water inventory balance in conjunction with effluent monitoring within the secondary steam and feedwater systems. The RCS water inventory balance must be performed with the reactor at steady state operating conditions and near operating pressure, y 5teady state operation is required to perform a proper water inventory balance; calculations during maneuvering are not I . useful. For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS y I pressure, temperature, power level, pressurizer and makeup. tank levels, makeup and letdown, and RCP seal leakoff flows. An early warning of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment sump level. These leakage detection systems are specified in LCO 3.4.14 "RCS Leakage Detection Instrumentation." I CALVERT CLIFFS - UNITS 1 & 2 B 3.4.13-5 Revision g 5
RCS Operational LEAKAGE B 3.4.13 BASES The 72 hour Frequency is a reasonable interval to trend LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. A Note under the Frequency column states that this SR is only required to be f performed during steady state operations. I SR 3.4.13.2 u,c ' This SR provides the means necessary to determine SG OPERABILITY in an operational MODE. The requirement to demonstrate SG tube integrity in accordance with the Steam Generator Tube Surveillance Program emphasizes the 1 importance of SG tube integrity, even though this Surveillance cannot be performed at nonnal operating conditions. In the event one or more steam generators are determined to not meet the requirements of the SG Tube Surveillance Program at anytime in MODES 1 through 4, action to comply f with LCO 3.0.3 must be taken. REFERENCES 1. - UFSAR, Appendix 10. Criterion 16 I
- 2. Regulatory Guide 1.45, May 1973
- 3. UFSAR Section 14.15
- 4. UFSAR, Section 14.14 g
CALVERT CLIFFS - UNITS 1 & 2- B 3.4.13-6 Revisionpg
5p . A.h w 3,4,t3
~3. d}. W REACTOR COOLANT SYSTEM h ](,Q
^
2/'.",0- I -- 3.4 0 REACTOR COOLANT SYSTEN LEAKAGE Mxte, MLt L.tv .'.;tlegg LINITING CONDIT!M F0P. OPERATION J{ , 3 3 hh4,4 Reactor Coolant System leakage shall be limited to:
- 1. a . No PRES $URE BOUNDARY. LEAKAGE. -
- b. 1 GPM UNIDENTIFIED LEAKAGE.
- h. [o ,
tal primary MGtmeandarv teature throuah all Efeaml ratara__AytF1 & gallons per-day through any one steam
' generator, and A.
=,
10 GPH IDENTIFIED LEAKAGE from the Reactor Coolant System. APPLICABILITY: MODES 1. 2. 3 and 4. ACTION: l g* % With any PRES $URE SOUNDARY LEAKAGE. be in at least NOT STANDBY l g within 6 hours and in COLD $NUTDOWN within the following 30 hours. l
% ilth any Reactor Coolant System leakage greater than any one of
[ 4A - the above limits, excluding PRE $$URE B0UNDARY LEAKAGE. reduce the ileakage rate to within limits within 4 hours or be in at least ALS - NOT STANDBY within the next 6 hours und in COLD SHUTDOWN within l-the following 30 hours. SURVEILLANCE REQUIRENENTS 4.4.6.2 Reactor Coolant Sys',em leakages shall be demonstrated to be within each of the above limits bys
- a. Ei thu.
t,Nfva e kIr U. g ae r gaseM 1 With the g scous and particul e monnors inoperacie, conducti the containment a sphere grab sample a accord a with the ACTION equirements of Techni ysis in A. 2, L Soect ention 3.4.6.1. CALVERT CLIFFS - UNIT 1 3/4 4-19 Amendment No. 188 l y Id3
J"t*o(I* ~b'^ 3 4.13 3,4 T4.4 tt&ff0RCOOLANT1r$ TEM} 3 . 4 .13
** 5't^" 'd" >
LIMITING CONDITION FOR OPERATION j h4ffach steam gepe~rator shall be OPEWLE.f APPLICABILITY: N00t$ 1. 2, 3 and 4. Ith one 0T1po-in. generator ( OPERA erable, restore 5....dtors r1to increati LE statu sN T.,,aboy) , M y tns casa..., .r c.hu,p.' rv, Cp..Z dm 110 A g .a.A ,.4.- c. 4,h .i
/5URVE!LtANCE REQUIREMENTS 4.4.5.0 tech steam generator shall be demonstrated OPERABLE by perforsance of the following augmented inservice inspection program and the requirements of specification 4.0.5.
4.4.5.1 Steam Generator Samole Selection and Inspection . Each steam generator shall be determined OPERABLE during shutdown by selecting and inspecting at least the minimum number of steam generators specified in Table 4.4 1. 4.4.5.2 Steam Generator Tube Samole Selection and Inspection . The steam generator tube minimum sample size. inspection result classification, and the corresponding action required shall be as specified in Table 4.4 2. The inservice inspection of steam generator tubes shall be performed at the frequencies specified in Specification 4.4.5.3 and the inspected tubes shall be verified acceptable per the acceptance criteria of Specification 4.4.5.4. When applying the exceptions of 4.4.5.2.a through 4.4.5.2.c. previous defects or imperfections in the area repsired by sleeving are not considered an area requi.*ing reinspection. The tubes selected for each inservice inf.pection shall include at least 3% of the total number of tubes in all steam generators; the tubes stlected for these inspections shall be selected on a random basis except:
- a. Where experience in sistlar plants with siellar water chemistry indicates critical areas to be inspected, then at least 60% of the tubes inspected shall be from these critical areas.
- b. The first inservice inspection (subsequent to the preservice inspection) of each steam generator.shall include:
- 1. All nonplugged tubrs that previously had detectable wall penetrations (> 20%). and CALVERT CLIFF 5 - UNii 1 3/4 4 10 Amendment No. 213
(,T3 3 A5 pi pa 3/4 4*ll O[ 3N 4*N ( u -r.& s.au. n~ fe *y ~ ~') w mu <A k u . c. m .. n c.. w pay 3$ 3
h pr*tif. en d e0 m 3 .kt O
- 3. 4 3, 4 , q 4/4Tt REACTOR C00 TANT..lYSTE((Rc.59 1/4T4T6 REACTOR COOLANT $YSTDI CEAKAGE 7-- _ _ _
E*Y " "- Q
.RaArtarf anlant tratan laakana L cu LIMITING CONDITIN FOR OPERATIM - [Qp***fiaath
- 3. 4. l3 3.~.e.2 Reactor Coolant Systandakage shall be limited tos
- s. No PRES $URE B0UNDARY LEAKAGE,
- b. I GPM W IDEKTIFIED LEAKAGE.
@g. I gen E tal prey 'a-marIdarv lankana thro (sh all stgeb rn and 100 gallons.per-day through any one steam A'
l'enerator,and b/. 10 GPH IDENTIFIED LEAKAGE from the Reactor Coolant $ystem. APPLICABILITY: MODES 1. 2. 3 and 4. Act10N: A c7totJ /l With any PRES $URE DOUNDARY LEAKAGE. be in at least liOT STANDBY g within 6 hours and in COLD $NUTDOWN within the following 30 hours, j C.' Og f. ith any Reactor Coolant $ stem leakage greater than any one of the above limits, excludin PRES $URE $00NDARY LEAKAGE reduce the A leakage rate to within lim ts within 4 hours or be in at least Ac raos) $NOT STANDBY within the next 6 hours and in COLD $NUTDOWN within r3 (thefollowing30 hours.
$URVEILLANCE REQUIRENENTS 4.4.6.2 Reactor Coolant System leakages shall be demonstrated to be within each of the above limits by:
.4,---f4%en.
!. Hogoring the containmen teos here particul or gase s' l.t 4Mdioactivity at less oer$2hournor
- 2. With th aseous and par iculate monitors in rable, cond ing the contal nt atmosphere grab ample analysis i a rdance with t ION requirements Technical '
u_ pecification 3. . .!. , CALVERT CLIFFS - UNIT 2 3/44.!g Amendment No. 16$ l po$e Io 3
Sp.cC.e.hw 3.4.13 3,y 6/4.4 M af6 eaaLaf triftN) 3, 4 ,1*3 t3/4 SitAN RATOR$ , LINITInt CONDITION Fet optRATION f
/
p.4.yEach steam gydtater shall baptRABLt.1 APPL 1tABILITY: MODES 1, 2, 3 and 4. Ih one or generator (3 steam oSPERA!eneratorsi LE statu perable,vettore-or to increasin - k h p bist.ss sp.c,A.4e + *F5.0,P S W^ * # ' ' TSURVEILtANCE REQUlttMENT} i
.4.4.5.0 Each steam generator shall be demonstrated GPERABLE by4perfomance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.
4.4.5.1 Steam Generator Samole te) ion and Inspection . Each steam generator shall be detemined OPE E during shutdown by selecting and inspecting at least the minimum number of steam generators specified in Table 4.4 1. 4.4.$.2 liens Generator Tube Sample Selection and Inspection . The steam generator tube minimum sample size. Inspection result classification, and the corresponding action required sh411 be as specified in Table 4.4.t. The intervice inspection of steam generator tubes shall be perfomed at the } frequencies specified in Specification 4.4.6.3 and the inspected tubes shall be verified acceptable per the acceptance criteria of Specification 4.4.5.4. When applying the exceptions of 4.4.$.t.a through 4.4.5.2.c. Previous defects or imperfections in the area reptired by sleeving are not considered an area requiring reinspection. The tubes selected for each inservice inspection shall include at least 3% of the total number of tubes in all steam generatorst the tubes selected for these i inspections shall be selected on a random basis except:
}
- a. Where experience in stellar plants with similar water chemistry indicates critical areas to be inspected, then at least 50% of the tubes inspected shall be from these critical areas.
- b. The first inservice inspection (subsequent to the preservice inspection) of each steam generator shall include:
- 1. All nonplugged tubes that previously had detectable wall penetrations ($20%).and w
CALVERT CLIFFS WIT 2 3/4 4 10 Amendment No. 190 Ct 5 3 4,f pmjn 3/4 4*ll /A'7 't 3!4 4'iL s % s.,u,wu er.pm) wu ~@ r u s.o,..w.e-ems P*P 3 2 3
DISCUSSION OF CIIANGES i SECTION 3413 o RCS OPERATIONAlo LEAKAGE ADMINISTRATIVF EllANGES A.1 He proposed change will refonnat, renumber, and reword the existing Tecimical Specifications, with no change ofIntent, to be consistent with NURIB1432. As a result, se 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 infonnation may also have been added to more fully describe each LCO and to be consistent with NUREG 1432,110 wever, the additional information does not change the intent of the current Technical Specifications. He refonnatting, renumbering, and rewording process involves no tech,nical changes to existing Specincatiota. , A.2 Current Technical Specification SRs 4.4.6.2.a.2 and 4.4.6.2.c contain requirements that are associated with Actions from CTS LCO 3.4.6.1. These requirements have not been retained as surveillance requirements in ITS 3.4.13; they have been retained in the Required Actions of ITS 3.4.14. With the gaseous and particulate monitors inoperable, CTS SR 4.4.6.2.a.2 requires grab samples of the ccetainment atmosphere be taken in accordance with the action , requirements of CTS 3.4.6.1. This requirement is maintained as Required Action D.1.1 of ITS 3.4.14; this action reodes grab samples of the containment atmosphere be analyzed when the required containment atmosphere radioactivity monitor is inoperable. He second part of CTS SR 4.4.6.2.c requires the RCS leakage be detennined at least once per 24 hours when required by CTS Action 3.4.6.1.b, except whers operating in the shutdown cooling mode. This requirement is maintained as Required Actions A.1 and D.1.2 ofITS 3.4.14; ' these ITS Actions provide requirements for detennh, lng RCS leakage at an increased l frequency when RCS leakage detection instrumentation is inoperable. Deleting CTS SRs 4.4.6.2.a.2 and 4.4.6.2.c is an administrative change, because the requirements are redundant to Action requirements in ITS 3.4.14. In addition to the justification provided above,',he proposed change is consistent with NUREO 1432. A.3 Improved Technical Specification 3.4.13 will add SR 3.4.13.2 to CTS 3.4.6.2. It requires the verification of Steam Generator (SO) tube integrity in accordance with the Steam Generator Tube Surveillance Program Current Technical Specification 3/4.4.5 contains surveillances which casure SO tube integrity is maintained. The SO tube integrity surveillances were moved to a program in ITS Chapter 5.0 (see the discussion of changes in ITS Chapter 5.0). This proposed change is an administrative change, because it does not modify the operability requirements for the sos contained in this speelfication (i.e., SO tube inspection requirements), improved Technical Specification SR 3.4.13.2 has simply been added to - invoke perfonnance of the SO Tube Surveillance Program, in addition to the justification provided above, this change is consistent with NUREG 1432. A,4 Current Technical Specification 3.4.6.2.c requires a limit of I gpm primary to-secondary leakage through all sos, and 100 gpd through any one SO. Improved Technical Specification 3.4.13 will only require a limit of 100 gpd through any one SG. The 1 gpm limit was deleted because the combined leakage from both sos of 200 gpd is only a fraction ' of the gpm limit (the I gpm rate can never be reached). Deleting a limit that can no longer be reached is considered an administrative change. CALVERT CLIFFS . UNITS 1 & 2 3.4.13 1 Revision 5
1 DISCUSSION OF CilANGES SECTION 3.4213 RCS OPERATIONAL LEAKAGE A.5 Current Technical Specification 3/4A.5 provides requirements regarding the Steam Generators. Current Tecimical Specification LCO 3.4.5 requires each Steam Generator to be Operable. he Surveillances in this specification which ensure operability of the Steam Generators deal speciGeally with the SO tubes, improved Technical SpeclGcation LCO 3.4.13 does not speellically require the SGs to be Operable, however, it does place a limit on primary to secondary leakage through the steam generators. His limit Indirectly requires the sos to be Operable. Additionally, ITS SR 3.4.13.2 invokes the SG Tube Surveillance Program. Current Technical Specification LCO 3.4.5 has been indirectly incorporated into the requirements ofITS 3.4.13. His proposed change is an administrative change, which does not change the requirements of the CTS. He CTS Surveillances which established SO operability have been incorporated into the SO Tube Surveillance Program contained in Chapter 5.0 of the ITS. He SO Tube Surveillance Program is invoked by ITS SR 3.4.13.2. In accordance with ITS SR 3.0.4, ITS SR 3.4.13.2 will have to be met within its } speelned frequency prior to entry into a Mode of Arg" ability of ITS LCO 3.4.13. l Herefore, the explicit LCO and Action of CTS 3/4.4.5 a . act required to be included in ITS 3.4.13. In addition to the justification provided above, this change is consistent with NUREG 1432. TEC11NICAL C11ANGES - MORE RENTRICTIVE M.1 Not used. l
'lICIINICAL CllANGES - RELOCATIONS None TECllNICAL DHCUh1ENTS CllANGES - h10VEh1ENT OF INFORhtATION TO LICENSEE-CONTROL None IEC11bi1 CAL CllANGES - LESS RESTRICTIVE L.1 Current Technical Speclucation SRs 4.4.6.2.a.1,4.4.6.2.b, and 4A.6.2.d require the periodic monitoring of various RCS leakage detection instrumentation (i.e., containment atmosphere gaseous or particulate monitor, the containment sump discharge, and the reactor vessel head closure seal leakage detection system). Improved Technical Specification 3A.13 does not contain because:
these Surveillances. Hese Surveillances are being climinated. This is acceptable a) CTS SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d only provide gross indloation of leakage; they do not provide a method for quantifying the leakage. Current Technical Specification SR 4.4.6.2.c provides the method for quantifying RCS leakage; it has been retained as ITS SR 3.4.13.1; b) ITS 3.4.14 will contain operability requirements for the containment atmosphere gaseous and particulate monitors. Improved Technical Speel0 cation SR 3.4.14.1 requires a channel check of the required containment atmosphere radioactivity monitor to be performed every 12 hours. Improved Technical Specification SR 3.4.14.1 is essentially equivalent to CTS SR 4.4.6.2.a.it c) ITS 3.4.14 will contain operability requirements for the containment sump level alarm system. An operable containment sump level alarm system will provide continuous monitoring of the sump level. CALVERT CLIFFS - UNITS 1 & 2 3.4.13-2 Revision 5
1)lSCUSSION OF CIIANGES SEC1'lON 3.4a13. RCS OPERATIONAL LEAKAGE 1hus, CTS SR 4.4.6.2.2.b is superfluous; d) the rea tor vessel head closure sea leakage detection system does not necessarily relate directly to the leakage requirements. Neither NUREG 1432 nor the CTS require this indication to be operable in the leakage detection instrumentation specifications (NUREO 1432 LCO 3.4.15 and CTS LCO 3.4.6.1); thus, it is not needed to support this specification; and c) prompt indication of RCS leakage will be provided to the operators via various alanns (e.g., containment sump level alarm and high - radiation alann from the containment atmosphere radiation monitoring system). In addition to the justification provided above, the removal of these Surveillances is consistent with NUREG 1432. L.2 Not used. l
. s i
1 CALVERT CLIFFS UNITS 1 & 2 3.4.13 3 Revision 5
RCS Operational LEAKACE (CT5) 3.4 13 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.13 RCS Operational LEAKACE ' (3,4,y,g LC0 3.4.13 RCS operational LEAKACC shall be lleited tot, (3.4.0.t. @ a. No pressure boundary LEAKAstl (7.4(.2.6)b. I gpa unidentified LEAKWI 6.(f,.1.d)c. 10 gpa identified LEAKAsti (d-h ! 5 y M l d O '*!L .'! S "'' ^*^ d @ (3.4 6.7.Qh' allons per day primary to secondary LEAKAGE ug any one SG. @
/40 APPLICA81LITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUllED ACTION COMPLETION TIME A. RCS LEAKAGE not within A.1
<3' Adw +.Lb '2 11alts for reasons ether than pressure Reduce LEAKAGE to within limits. 4 hours boundary LEAKAGE.
3.4 c,.Z. B. Required Action and 8.1 Be in MODE 3. Ac h' associated Completion 6 hours 4 *p*" 4 Time of Condittot. A A51 not met. 8.2 Be in M30E 5. QR 36 hours Pressure boundar LEAKAGE exists. y b CEOG STS 3.4-30 Rev 1, 04/07/95
RC$ Operational LEAKAGE B 3.4.13 BA$ES ACT10NS B.I and R 2 (continued) acting on the RCPS are much lower, and further deterioration is much less likely. A M At
$URVElllANCE 1R 1.4.11.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LC0 Ilmits ensures the integrity of the RCPS is maintained.
LEAKAGE would at first appear as unidenttfted LEAKAGE andPressure boundary can only be positively identified by inspection. l ' Unidentified LEAKAGE and identified LEAKAGE are deterstned by performance of an RCS water inventory balance. Primary l to secondary LEAKAGE is also measured by performance of an RCS water inventory balance in conjunction with effluent monitorin6 within the secondary steam and feedwater systems.
.The RCS water inventory balance must be performed with the reactor at steady s operatina pressure,rhere tat operatino conditions mad ==
rfo a is WEp J a ee
,u th! $R is fot ree red st e rattihsnehrepe ina 12 A rs of en 1.
nureax sed. Steady invent statelancer operation is required to perform a proper water calculations during saneuvering are not useful te rewirus we i- i o- n = mat whew f tate g estabitshgA / For RCS operational LLAKAGE' determinatTon my veier inventor defined as stable RCS pressure,y tem balance, steady state is pressurtter and makeup tank levels,perature, power level, makeup and letdown, and RCP seal $njecth ;-4 ntr- flows. d t /N An early warning of pressure boundary LEAKAGE or /,. k, U unidentified LEAKAGE is provided by the automatic systems thu monitor the containment atmosphere radioactivity and the containment sump level are specified in LCO 3.4. These leakage detection systems
'RCS Leakage Detection instrumentation.'
The 72 hour Frequency is y asonable interval to trend LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. A Note under the Frequency column states that this SR is equired be perfonned during steady state operation. (continued) CE00 STS B 3.4-72 Rev 1, 04/07/g5
INSEltT ACTION B j t f Ab MO rostri n SOsare 3 within 6 and MO ble due lure to meet S 5 within 36 hou . Subsequent ent
. 4.13.2, the react iust be brought to MODE 4 is d
by LCO 3,0.4 until the generator tu .. mtegrity can be e blished. r9 - 4
+9 5
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_____-- ~ RCS Operattenal LEAKAGE 8 3.4 13 BASES
$URy[lLLANCE 1R 1.4.11.2 R[0UIREMENTS (continued) This SR provides the oesns necessar OP(MBILITV in an operettenal M00C.yThe to determine requirement SGto demonstrate $4 tube integrity in accordance with the Stean Generator Tube survet11ance Program emphastres the tapertence of SG tube integrity, even though this *-
condttiens. cannet be performed at normal operating -~ Survalliance I M u n M ., A Fie M y T G G La % REF[RENC[$
- 1. mb_ rIR 50. AseeK1x A. WG W.
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@ i Regulatory Guide 1.45, May 1973.
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CEOG STS . B 3.4-73 Rev1,04/07/95
- 29. The NRC requested additional justification for the deletion of CTS SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d frorn ITS 3.4.13. Discussion of Change L.1 for ITS 3.4.13 and its associated NSilC have been revised to provide additionaljustification for the changes tlTS 3.4.13 Comment 7).
l
DISCUSSION OF CllANGES SECTION 3.4.13 o MCS OPERATIONAL LEAKAGE A.5 Current Technical Specification 3/4.4.5 provides requirements regarding the Steam Generators. Current Technical Specification LCO 3.4.5 requires each Steam Generator to be Operable, ne Surveillances in this specification which ensure operability of the Steam Generators deal specifically with the 50 tubes, improved Technical Specification LCO 3.4.13 does not specifically require the sos to be Operable, however, it does place a limit on primary to secondary leakage through the steam generators. His limit indirectly requires the sos to be Operable. Additionally, ITS SR 3.4.13.2 invokes the SO Tube Surveillance Program. Current Technical Specification LCO 3.4.5 has been indirectly incorporated into the requirements ofITS 3.4.13. This proposed change is an administrative change, which does not change the requirements of the CTS. De CTS Surveillances which established SO operability have been incorporated into the SO Tube Surveillance Program l contained in Chapter 5.0 of the ITS. %e SO Tube Surveillance Program is invoked by ITS SR 3.4.13.2. In accordance with ITS SR 3.0.4,ITS SR 3.4.13.2 will have to be met within its specified frequency prior to entry into a Mode of Applicability of ITS LCO 3.4.13. Derefore, the explicit LCO and Action of CTS 3/4.4.5 are not require *d to be included in ITS 3.4.13. In addition to the justification provided above, this change is consistent with NUREO 1432. TECilNICAL C[IANGES - MORE RESTRICTIVE M.1 Not used. l TECliNICAL CIIANGES - RELOCATIONS None TECIINICAL CilANGES MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED DOCUMENTS None TECIINICAL CIIANGES - IISS RESTRICTIVE L.! Current Technical Specification SRs 4.4.6.2.a.1,4,4.6.2.b, and 4.4.6.2.d require the periodic monitoring of various RCS leakage detection instrumentation (i.e., containment atmosphere gaseous or particulate monitor, the containment sump discharge, and the reactor vessel head closure seal leakage detection system). Improved Technical Specification 3.4.13 does not contain these Surveillances. These Surveillances are being eliminated. This is acceptable because: a) CTS SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d only provide gross indication of leakage; they do not provide a method for quantifying the leakage. Current Technical Specification SR 4.4.6.2.e provides the method for quantifying RCS leakage; it has been retained as ITS SR 3.4.13 lt b) ITS 3.4.14 will contain operability requirements for the containment atmosphere gaseous and particulate monitors. Improved Technical Specification SR 3.4.14.1 requires a channel check of the required containment atmosphere radioactivity monitor to be performed every 12 hours. Improved Technical Specification SR 3.4.14.1 is essentially equivalent to CTS SR 4.4.6.2.a.1; c) ITS 3.4.14 will contain operability requirements for the containment sump level alarm system. An operable containment sump level alarm system will provide continuous monitoring of the sump level. CALVERT CLIFFS - UNITS I & 2 3.4.13 2 Revision 5
- . _ - - - . - - - - - . _ _ . - _ - - - =
DISCUSSION OF CHANGES SECTION 3.4.13 - RCS OPERATIONAL LEAKAGE "thus, CTS SR 4.4.6.2.2.b is superfluous; d) the reactor vessel head closure seal leakage detection system does not necessarily relate directly to the leakage requirements. Neither NUREG 1432 nor the CTS require this indication to be operable in the leakage detection instrumentation specifications (NUREG 1432 LCO 3.4.15 and CTS LCO 3.4.6.1); thus, it is not needed to support this specification; and c) prompt indication of RCS leakage will be provided to the operators via various alanns (e.g., containment sump level alarm and high radiation alarm from the containment atmosphere radiation monitoring system), in addition to the justification provided above, the removal of these Suncillances is consistent with NUREG 1432. L.2 Not used. l CALVERT CLIFFS UNITS I & 2- 3.4.13 3 Revision 5 , I
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM change does not create the possibility of a new or different kind of accident from any previously analyzed accident.
- 3. Does this change involve a signincent reduction in margin of safety?
%is change remoses the explicit requirement, in the event lipSi How exceeds 210 gpm, to verify that the flow condition did not result in the violation of RCS pressure / temperature limits.
%c verification of the status of compilance with Technical Specifications is an implicit part of using Technical Specifications and detennining the appropriate Conditions to enter and Actions to take in the event of a failure to meet a Surveillance Requirement. In addition, plant status is continuously monitored by control room personnel. %e results of this monitoring process are documented in records / logs maintained by control room personnel. He continuous monitoring process includes re evaluating the status of compliance with Technical Specification requirements when the plant conditions change. Therefore, the explicit requirement, in the event lipSI now exceeds 210 gpm, to verify that the flow condition did not result in the violation of RCS pressure / temperature limits is considered to be unnecessary for ensuring compliance with the applicable Technical Specification requirements. The status of compliance with Technical Speel!1 cation requirements will continue to be monitored to assure the appropriate previously j
' approved actions are taken in the event of a failure to meet Technical Specl0 cation requhements.
%crefore, this change does not involve a significant reduction in the margin of safety.
3.4.13 Cimnae L1
- 1. Does the change involve a signifleant leervase in the probability or consequences of an aceldent previously evaluated?
Current Technical Specification SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d are being eliminated.
%ls is acceptable because: a) CTS SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d only provide gross indication of leakage; they do not provide a method for quantifying the leakage. Current Technical Specification SR 4.4.6.2.c provides the method for quantifying RCS leakage; it has been retained as ITS SR 3.4.13.l; b) ITS 3.4.14 will contain operability requirements for the containment atmosphere gaseous and particulate monitors. Improved Technical Specification SR 3.4.14.1 requires a channel check of the required containment atmosphere radioactivity monitor to be performed every 12 hours. improved Technical Specification SR 3.4.14.1 is essentially equivalent to CTS SR 4.4.6.' 2 .a.1; c) ITS 3.4.14 will contain operability requirements for the containment sump level alarm system. An operable containment sump level alann system will provide continuous monitoring of the sump level. Dus, CTS SR 4.4.6.2.2.b is super 0uous; d) the reactor vessel head closure seal leakage detection system does not necessa,rily relate directly to the leakage requirements. Neither NUREG 1432 nor the CTS require this ind8 cation to be operable in the leakage detection instrumentation speci0 cations (NUREG 1432 LCO 3.4.15 and CTS LCO 3.4.6.1); thus, it is not needed to support this speci0cationt and c) pro.upt indication of RCS leakage will be provided to the operators via various alanns (e.g., containment sump level alann and high radiation alarm from the containment atmosphere radiation monitoring system).
The proposed changes do not alter assumptions relative to the mitigation of an accident or transient, nor do they significantly affect initiators or mitigation of analyzed events. Failure of an RCS leakage detection system is not an initiator of any analyzed event. Also, the elimination of these SRs do not affect the ability to quantify RCS leakage. Therefore, the proposed changes CALVERT CLIFFS - UNITS I & 2 3424 Revision 5
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3A ~ REACTOR COOLANT SYSTEM do not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any 1 previously evaluated? Current Technical Specification SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d are being el8minated. l The elimination of these SRs do net affect the ability to quantify RCS leakage, improved l Technical Specification LCO 3.4.13 will continue to provide leakage limits, and ITS SR 3.4.13.1 provides the method for quantifying leaks to ensure these limits are maintained. Additionally, ITS 3.4.14 will contain operability requirements regarding the RCS leakage detection systems; these requirements ensure that RCS leaks that could potentially challenge the limits are promptly
. Identified. The proposed changes do not introduce a new mode of plant opert An and do not -
Involve physical modification to the plant. The proposed changes do not introduce any new accident initiators. Therefore, they do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Doo this change involve a signifleant reduction la margin of safety?
'The margin of safety is established through the design of the plant structures, systems and components, the parameters within which the plant is operated, and the establishment of the setpoints for the actuation of equipment relied upon to respond to a event. The proposed changes do not significantly impact the condition or perfonnance of structures, systems or components relled upon for accident mitigation. The proposed changes do not impact any safety analysis assumptions. Therefore, they do not involve a significant reduction in a margin of safety.
LLQChange L1 Not used. l 14.14 Change L1 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? Current Technical Specification LCO 3.4.6.1 has been revised to only require two RCS leakage detection systems to be Operable (l.c., the containment sump level alarm system and either the
'ntainment atmosphere - particulate radioactivity monitor or the containment atmosphere ..,
ecus radioactivity monitor). Current Technical Specification Table 3.3-6, item 2.a. has been ised to require a minimum of one channel b operable for tl.c gaseous or paniculate activity monitor, These prorased changes are acceptable, because the LCO continues to require instruments of diverse monitoring principles to be Operable to provide a high degree of assurance that extremely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS leakage indicates possible reactor coolant pressure boundary degradation. Additionally, ITS 3.4.13 contains a Surveillance which requires a periodic determination of RCS leakage; this Surveillance provides additional assurance that the integrity of the reactor coolant pressure boundary is being maintained. Failure of containment atmosphere radioactivity monitors is not an initiator of any analyzed event. Reactor Coolant System leakage will still be adequately detected by the remaining instrumentation, the RCS inventory balance, and other instrumentation not required by this CALVERT CLIFFS - UNITS 1 & 2 3425 Revision 5
30; The deviations preposed by TSTF-ll6 have teen removed from the submittal, To accomplish this, the following changes were made: 1) the markups of CTS SR 4.4.6.2.c for ITS 3.4.13 were revised to eliminate the proposed note, and to denote that part of the SR would be addressed in ITS 3.4.14; 2) DOCS A.2 and L.2 (and its associated NSitC) for ITS 3.4.13 were eliminated; 3)the markups of Action b.2 of ITS LCO 3.4.6.1 for ITS 3.4.14 were revised to eliminate the proposed note; 4) markups of CTS SR 4.4.6.2.c were added to ITS 3.4.14. As a result, the CTS markup pages for ITS 3.4.14 were repaginate 5 5) DOC L.6 for ITS 3.4.14 and its associated NSilC were climinated; 6) DOC M.1 for ITS 3.4.14 was added to justify a change to CTS SR 4.4.6.2.c; 7) the ISTS markup for ITS SR 3.4.13.1 was revised; 8) the deviation from ISTS SR 3.4.13.1 was justified by JFD 38 to Section 3.4; 9) the ISTS markup for ITS ? 4.14 was revised; and 10) the ISTS markups for the Bases of ITS 3.4.13 and 3.4.14 were revised GTS 3.4.14 Comment 1). 1 l
~
RCS Operational LEAKAGE 304e13 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A AND not met. B.2 Be in MODE 5. 36 hours QB P'ressure boundary ~ ' LEAKAGE exists.
.W S
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 Verify RCS Operational LEAKAGE is within -----NOTE ---- limits by perfonnance of RCS water inventory Only required balance, to be performed 3-during steady state operation i 72 hours SR 3.4.13.2 Verify SG tube integrity is in accordance In accordance with the Steam Generator Tube Surveillance with the Steam Program. Generator Tube Surveillance Program CALVERT CLIFFS - UNITS 1 & 2 3.4.13-2 Revision /15'
RCS Leakage Detection Instrumentation 3.4.14 3.4--REACTORCOOLANTSYSTEM(RCS) 3.4.14 RCS Leakage Detection Instrumentation LCO 3.4.14 The following RCS leakage detection instrumentation shall be OPERABLE:
- a. One containment sump level alarm; and 1
- b. One containment atmosphere radioactivity monitor (gaseousorparticulate).
l APPLICABILITY:- MODES 1, 2, 3, and 4. ACTIONS
-------------------------------------NOTE-----------------------------------_-
LC0 3.0.4 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME
~
A. Required containment s A.1 -Perform SR 3.4.13.1. Once per sump level alarm 24 hours inoperable. AND A.2 Restore containment 30 days y sump level alarm to OPERABLE status. CALVERT CLIFFS - UNITS 1 & 2 3.4.14-1 Revisiong5'
RCS Leakage Detection-Instrumentation 3.4.14 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment B.1.1 Analyze grab samples Once per i atmosphere of the containment 24 hours radioactivity monitor atmosphere. inoperable.
- E B.1.2 Perform SR 3.4.13.1. Once per 24 hours AND B.2 Restore required 30 days containment atmosphere I --
radioactivity monitor to OPERABLE status. C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours D. All required alarms D.1 Enter LCO 3.0.3. Immediately and monitors inoperable. CALVERT CLIFFS - UNITS 1 & 2 3.4.14-2 Revision # 5
RCS Operational LEAKAGE B 3c4.13 BASES The allowed Completion Times are reasonable, based on operating experience. to reach the required conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 5 the pressure stresses acting on the RCPB are much lower, and-further deterioration is much less likely. 5 SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure botadary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. Unidentified LEAKAGE and identified LEAKAGE are determined i by performance of an RCS waNr inventory balance. Primary to secondary LEAKAGE is also measured by performance of an RCS water inventory balance in conjunction with effluent monitoring within the secondary steam and feedwater systems. The RCS water inventory balance must be performed with the reactor 1.t steady state operating conditions and near operating pressure, y Steady state operation is required to perform a proper water inventory balance; calculations during maneuvering are_not I useful. For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS y I pressure, temperature, power level, pressurizer and makeup. tank levels, makeup and letdown, and RCP seal _ leakoff flows. An early warning of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment sump level. These leakage detection systems are specified in LC0 3.4.14 "RCS Leakage Detection-Instrumentation." CALVERT CLIFFS - UNITS 1 & 2 B 3.4.13-5 Revision JTS R Ft~~%1
RCS Operational LEAKAGE B 3.4a13 BASES The 72 hour Frequency is a reasonable interval to trend LEAKAGE cnd recognizes the importance of early leakage detection in the prevention of accidents. A Note under the Frequency column states that this SR is only required to be- f performed during steady state operations. SR 3.4.13.2 : ~%e e. = This SR provides the means necessary to determine SG OPERABILITY in an operational MODE. The requirement to demonstrate SG tube integrity in accordance with the Steam Generator Tube Surveillance Program emphasizes the importance of SG tube integrity, even though this Surveillance cannot be performed at normal operating conditions. In the event one or more steam generators are determined to t not meet the requirements of the SG Tube Surveillance Program at anytime in MODES 1 through 4, action to comply f with LC0 3.0.3 must be taken. REFERENCES 1. UFSAR, Appendix-10, Criterion 16 I
- 2. Regulatory Guide 1.45, May 1973
~3. UFSAR Section 14.15
- 4. UFSAR, Section 14.14-g CALVERT CLIFFS - UNITS 1 & 2 B 3.4.13-6 ,
Revisionpg
)
RCS Lcakage Detection Instrumentation B 3.4.14 BASES I propagation is much smaller. Therefore, the requirements of this LC0 are not applicable in MODES 5 and 6. ACTIONS The actions are modified by a Note that indicates the provisions of LC0 3.0.4 are not applicable. As a result, a MODE change is allowed when the containment sump and required radiation monitor channels are inoperable. This ~" allowance is provided because other means are available to monitor for RCS LEAKAGE. A.1 and A.2 If the containment sump level alarm is inoperable, no other form of sampling can provide the equivalent information. However, the containment atmosphere radioactivity monitor will provide indications of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours to provide information that is adequate to detect leakage. 5-Restoration of the sump level alarm to OPERABLE status is required to regain the function in a Completion Time of 30 days after the monitor's failure. This time is acceptable considering the frequency and adequacy of the RCS water inventory balance required by Required Action A.1. B.1.1. 8.1.2. and B.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed, or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic CALVERT CLIFFS - UNITS 1 & 2 B 3.4.14-4 Revision g 5
RCS Leakage Detection Instrumentation B 3.4.14 BASES-information. With a sample obtained and analyzed or an inventory balance performed every 24 hours, the reactor may be operated for up to 30 days to_ allow restoration of at least one of the radioactivity monitors. 1 The 24 hour interval provides periodic information that is adequate to detect-leakage. The 30 day Completion Time f recognizes at least one other form of leakage detection is available. C.1 and C.2 l If any required Action of Condition A or 8 cannot be met within the required Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to ,at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. M If all required alarms and monitors are inoperable, no automatic means of monitoring leakage are available and immediate plant shutdown in accordance with LCO 3.0.3 is required. SURVEILLANCE SR 3.4.14.1 REQUIREMENTS SR 3.4.14.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere. radioactivity monitors. The check gives reasonable confidence the chennel is operating properly. The Frequency of 12 hours is based on CALVERT CLIFFS - UNITS 1 & 2 B 3.4.14-5' Revision 45-
3(ks.bc bb 3.de13
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3'4 ,4' " dc:, leu ku p 3/4.4 REACTOR COOLANT SYSTEM $ h & s s,y s ('",
$URVEILIJUICE REQUIREMENTS (Continued)
)
. nonitor tne containment sump;nscnarse Trequency at ie t once' per 1 ours, when the Contalpfent Sump Level Alam Sys is b'g apr nr.
59- M. Detemining Re' actor Coolant System leakage at least once per S*4'4,l 2 hoursW urina stuacy stath operation and at least once per A
'24 hows when requ' red by ACTION 3.4.6.1.b. except when, operating _ 64 u_-
* :i{ ~ .
Jn.the shutdown cooling mode, and ~' Ey tl to per r?
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(bg ea m CALVERT CLIFFS - UNIT 1 3/4 4-20 Amendment No. 188 l p y 2. 3 3
5 7, .r. , s io , 3. 4. 3 See(L.wule c,4C 6 QSPicJFJCATJot/T.'[.8% [ 3/4.4 REACTOR C00LAlfi_5YSTEM fr *, L udo.y 0*I*d'ON g ,s 3 SURVEILLANCE REWIREMENTS (Continued) kb. Moni oring the co ruwnt sump ci l 2 hours, w he Containop(pharge Sump Levelfrequency atleast Alors)(stem is j once L.\ l _ ES ' ALE, <
$R g. not.-inina the Reactor Coolant Enten water leakage at least
$4.G.I
,J ,3,'.y __once per 72 hours turing steady stat'n operation'and at least once-per ze nours wnen required by ACTION 3.4.6.1.b. except when~ operating in the sWtdown cooling mode, and h SR , [g*Y tI t o) Nhou sa 3.4.t3.i m v . . r ,A .sc.s4 u- _,. , w3. . y w . -, --- 4. -~ tg <x?g m , ,s c _ . , 4 . ,. T.se o , _. .
$vpwe llpN . . .ru b> og. c. + ( bev*.lle.ge4 't
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l 3 CALVERT CLIFFS - ljN!T 2 3/4 4-20 knend:nent No.165 l p o. y 1 o P 3
. o
DISCUSSION OF CHANGES SECTION 3A 13 - RCS OPERATIONAL 1.EAKAGE Thus, CTS SR 4.4.6.2.2.b is superfluous; d) the reactor vessel head closure seal leakage detection system does not necessarily relate directly to the leakage requirements. Neither
-NUREG 1432 por the CTS require this indication to be operable in the leakage detection instrumentation specificaticos (NUREG 1432 LCO 3A.15 and CTS LCO 3.4.6.1); thus, it is not needed to support this specification; and c) prompt ind! cation of RCS leakage will be provided to the operators via various alarms (e.g., containment sump level alarm and high radiation alarm from the containment atmosphere radiation monitoring system). In cddition to the justification provided above, the removal of these Surveillances is consistent with NUREG-1432.
L.2 Not used.
]
i: 4 CALVERT CLIFFS - UNITS 1 & 2 3.4.13-3 Revision 5 J
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM do not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? Current Technical Specification SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d are being eliminated. The climination of these SRs do not affect the ability to quantify RCS kakage. Improved Technical Specification LCO 3.4.13 will continue to provide leakage limits, and ITS SR 3.4.13.1 provides the method for quantifying leaks to ensure these limits are maintained. Additionally, ITS 3.4.14 will contain operability requirements regarding the RCS leakage detection systems; these requirements ensure that RCS Icaks that could potentially challenge the limits are promptly ,
. identified. He proposed changes do.not introduce a new mode of plant operation and do not '
involve physical modificativn to the plant. The proposed changes do not introduce any new accident initiators. Therefore, they do not create the possii,ility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
ne margin of safety is established through the design of the plant structures, systems and components, the parameters within which the plant is operated, and the establishment of the l setpoints for the actuation ofequipment relied upon to respond to a event. The proposed changes do not significantly impact the condition or performance of structures, systems or components relied upon for accident mitigation. He proposed changes do not impact any safety analys:s assumptions. Retefore, they do not involve a significant reduction in a margin of safety. 3AJ3 Chantic L2 Not used. l 3.4.14 ChanEc L.I 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? Current Technical Specification LCO 3.4.6.1 has been revised to only require two RCS leakage detection systems to be Operable (i.e., the containment sump level alarm system and either the containment atmosphere particulate radioactivity monitor or the containment atmosphere
~
gaseous radioactivity monitor). Current Tecimical Specification Table 3.3-6, Jtem 2.a. has been revised to require a minimum of one channel be operable for the gaseous or particulate activity monitor. These proposed changes are acceptable, because the LCO continues to reqaire instruments of diverse monitoring principles to be Operable to provide a high degree of nssurance that extremely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS leakage indicates possible reactor coolant pressure boundary degradation. Additionally, ITS 3.4.13 contains a Surveillance which requires a periodic determination of RCS leakage; this Surveillance provides additional assurance that the integrity of the reactor coolant pressure boundary is being maintained. Failure of containment atmosphere radioactivity monitors is not an initiator of any analyzed event. Reactor Coolant System leakage will still be adequately detected by the remaining instrumentation, the RCS inventory balance, and other instrumentativ.i not required by this CALVERT CLIFFS - UNITS I & 2 3-4-25 Revision 5
sp.Lb 3.4. M
-Q -4/4,4 REACTOR COOLANT SYST l
4/4.4 ? REACTOR COOLANT SYSTERL "'!.0: 3 A it 1
.QeakaaeDetectionSystem._Q LIMITING CONDITION FOR OPERATION tc.o 34,q. 3
- 6;t The following Reactor Coolant System Leakage Detection Systems shall be OP LE:
L /. ntainment Atmosphere Particulate Radioactivity Monitor 4*t-- System,g L.I o, W. ThEkontainment Sump Level Alarm Systcn, and
/. 5 ontainment Atmosphere Gaseous Radioactivity MonitorM; Sy:t-Q APPLICABILITY: MODES 1, 2, 3 and 4. 1 P- - A *@- ---
[*g ACTION: LCu - 3.o.4 e.s n,-\ e.,e lk.M.4 - g '^ 4 a. With only two of the above requireu Leenage vetemon sysi; ems 7 i CPERABLE, operati may continue for up to 30 samples of the ntainment atmosphere are obt .nedsand provided grab
@2 S y red analyzed l pg,, g at least one er 24 hours when either the quired Gaseous or - A.3 Particulat adioactivity Monitoring Syst is inoperable; Nat. R.{
9
% LP() othenvi be in at least HOT STANDBY wi n the next 6 hours and j Ma C SHUTDOWN within the following 0 hours.j
~
^ % FWith only one of the above required Leakage Detection Systems d'. n sp~.t ,0, A.PERABLE, operation may continue ford up provided to that:
% Grab samples of the containment atmospher
-e.-- N Lanalyzed at least once per our e obtained and L.
Cr @\.\ s
< 'A The Reactor Coolant System r inventory balance of. L.4 h ,~ /
f 0.4.0.2. is performed at least once g, g 7 Surveillance per 24 hours. Requirement (5K ~3 pr3 I) II.l* 2 2
~[ Otherdse be in at least ll0T STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours, jN4 w
/
1( C ge s,, b. ht! rep ll<A b'l G^#' W I'* O Y - o n.,,.s , n., I
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CALVER 3/4 4-17 Amendment No. 188 ,.. .lm
\w.TCLIFFS-UNIT __.-s 1p t a
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" RC.S Ope rah.l 1.ttkay."
3*N
-4/+r+ REACTOR C00LAlfT SYSTDI (RCS)
{ SURVEILLANCE REQUltEM[lfil (Contissed)
- b. Monitoring the containment sump discharge frequency at least once ger 12 hours, when the Containment Sump Level Alatu system is
'E * 't' 5 Ail and .; . . e ,i.: .s t
gk h, g'g
- c. Detenr.ining Reactor Coolant System leaka e at least once per 72 hours durino steady state ITS 3Ali 24 hours when recuired by ACT (31 e no at immut once =r l ~ . >,
^ K; kc4. % ,1.7 Qhyt shqown cylingyce, ah(
u= m s m;
\
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'd. Monitoring the reactor vessel head closure seal Leakage Detection - .fj., System at least once per 24 hours. , < See k( Sp*'d DiscunIon Co-hon 3 9, \3of Chan$tS j h
RCS Opeyhoro\ Legkop" 4 e i (' . [ a CALVERt CttrFS - tM11 1 3/4 4 20 knendtnent he.188 s i Page b of b W " 9. N l
b peci 9.< c.-{ o w ~5, 4 , l s}- CD
'"f, 4 -)/4N REACTOR COOLANT SYSTD t]C ~
y 4,g 4 9/'_' ! REACTOR COOLANT SYSTDLd^4^.CU hoe Detston System]s LIMITIIIG CONDITION FOR OPERATI0ll L.C O gg4 $rMr.+ The following Reactor Coolant System Leakage Detection Systems shall be LE: PN b/ Lonta Syst tmosphere Particulate Radioactivity Monitoring (, , { cJ. nment Sump Level Alam System, and
- g. ( inment Atmosphere Gaseous Radioactivity Monitoring S M APPLICABILITY: MODES 1. 2, 3 and 4. ~~
"m'
- C_ _ _ _%
ACTION: - LC.O 3.04 4 ~l a pF '<<-bte I A@gy '3 a. W caly two of tfie above requi d Leakage Detectio Sy g q.'"" g'P ERABLE, oper n may conti for up to 30 day rovided ab i la 9 samples of containment sphere are obtai d and ana zed W'I b at least e per 24 hour hen either the re tred Gase I Particu e Radioactivi Monitoring Syst s inopera!R or A. i Q at f% othemse be in at le,a t il0T STANDBY wit / l (C.g,0..y i+9, ( in $8LD SNUTD0l#1 within the following the nextfl' hours /d) hours. f - T Q,.
,% ] %.[With only one of the above required Leakage etection Systems
/ OPE *ABLE. operation may continue for up to be 1 da q vided that
( A. 2 , rab samples of the containment atmosphe t1ibtained and
- nalyzed at least once per rs #
w [* I J i The Reactor Coolant System inventory balance of
/ Surveillance Requirement-4.' 0.2.c is perfomed at least once g Per 24 hours. n5; q y , 4 ,t3. I
^A,<t b4 .n Othemise be in at least 110T STAllDBY within the next 6 hours and in COLD n ENUTD0441 wi h y Q } lowing 3.0 hours.
t g -mv
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s 4 M c'h t (A % 3,4,tg See Discussion o{ Ch6%es 4 Spec 4ca-hon 3.4il5;
't 9.G opere-how.l l.Ma3e" 3'N -W4T+ AEACTOR C00! ANT SYSTEM (RC5')
, (, SURVEILtANCE REQUIREMENTS (Continued) il b.
Monitoring the contatrument sump discharge frequency at least once per 12 hours, when the Containment Sump Level Alaru System is GPERABLE.
'. . l .
- c. the Reactor Coolant System water leakane at least [$il oek I!l
- b'I I Determinin!
once oer 7 hours durino steady s'; ate opera"!ortland O'I'g it4 least
' onced per Z4 hours when recuired by ACT"UNLAA-Asnu , m, HTS I'N'IN i
, y g,g,g loMratfW in'the shtMdown C9011ng quous.yana s -
J ~
- d. Monitoring the reactor vessel head closure seal Leakage Detection
, , System at least once per 24 hours.
hg bcuston c( b7A
, b S gt dca b 3 SI3)
,' 'RG Openbat l.akay."
/
CALVERT CLIFFS - UNIT 2 3/4 4 20 Amendment hs. 165 l Ap b d
DISCUSSION OF CHANGES SECTION 3AI4 - RCS LEAKAGE DETECTION INSTRUMENTATION A.1 De- proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change ofintent, to be consistent with NUREG 1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs ITS development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREG-1432, liowever, the additional information does not change the intent of the current Technical Specifications. The reformatting, renumbering, and rewording process invoives no technical changes to existing Specifications. A.2 Current Technical Specification 3.4.6.1 does not contain an Action when all the RCS laakage detection instrumentation are inoperable. Therefore, the CTS would require a Specification 3.0.3 entry if no leak detection instrumentation were Operable. Improved Technical Specification 3.4.15 adds Action D which requires an LCO 3.0.3 entry when all the required leakage detection monitors are inoperable. Therefore, since the addition of the ITS Action did not change or add any requirements to the CTS, this is considered an administrative change. This change is consistent with NUREG-1432. A.3 Current Technical Specification 3.4.6.1 Action a contains requirements when two of the three required leakage detection systems are inoperable. Improved Technical Specifications will delete this Action. The ITS presents the leakage detection instrumentation by requiring i one containment sump monitor and one radiation monitor (either the particulate or the gaseous containment atmosphere radiation monitors). Therefore, only two monitors are required to be Operable, which allows the deletion of CTS 3.4.6.1 Action a. The deletion of an Action that no longer applies constitutes an administrative change. This change is consistent with NUREG-1432. Changes to the LCO presentation and instrumentation requirements are discussed in a less restrictive discussion of change in this section. TECIINICAL CIIANGES - MORE RESTRICTIVE M.1 The second part of CTS SR 4.4.6.2.c requires RCS leakage to be determined "at least once per 24 hours when required by Action 3.4.6.1.b, except when operating in the shutdown cooling mode." Required Actions A.l and B.I.2 ofITS 3.4.14 require RCS leakage to be determined in accordance with ITS SR 3.4.13.1 at least once per 24 hours, when the required containment sump level alarm or the required containment atmosphere radioactivity monitor is inoperable, respectively. The exception contained in the CTS regarding the shutdown cooling mode is not included in the ITS. In the event the containment sump level alarm or the containment atmosphere radioactivity monitor is inoperable, redundancy for RCS. leakage detection is lost. Thus, compensatory actions should be taken to ensure that the RCS leakage is within limits. The proposed change is acceptable, because it will provide additional assurance that the RCS leakage is being maintained within limits. TECIINICAL CIIANGES - RELOCATIONS None CALVERT CLIFFS - UNITS 1 & 2 3.4.14-1 Revision 5
DISCUSSION OF CIIANGES SECTION 3,4,14 o RCS LEAKAGE DETECTION INSTRUMENTATION changes were not r.llowed constitutes a less restrictive change. This change is consistent with NUREG 1432. L.6 Not used. . l
. . _ . 7, . ;
CALVERT CLIFFS - UNITS I & 2 3.4.14-4 Revision S l
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM instruments are inoperable, Actions require that remedial measures be taken (i.e., grab samples of containment or RCS inventory balance at an increased Frequency). Also, other methods are available to detect RCS leaks (such as monitoring containment pressure, containment humidity, volume control tank level, etc.). These alternate methods ensure that RCS leakage will be adequately detected if a leak were to occur. The change will not alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a sigmficant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? The proposed change adds a requirement that allows Mode changes (LCO 3.0.4 exemption) when in the Actions for RCS leakage detection instruments inoperable. The change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The proposed change will net introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different j kind of accident from any accident previously evaluated. l
- 3. Does this change involve a significant reduction in margin of safety?
l The proposed change adds a requirement that allows Mode changes (LCO 3.0.4 exemption) when in the Actions for RCS leakage detection instruments inoperable. Mode changes do not affect the ability to detect leaks; however, they can affect leakage. His change affects only leakage detection by allowing Mode changes when leakage detection instrumentation is inoperable. However, adequate methods of leakage detection remain available. Another Technical Specification will ensure that the leakage detection requirements are not exceeded. This change will not affect the ability for the remaining leakage detection instrumentation to adequately detect RCS leakage. Therefore, the change does not involve a significant reduction in a margin of safety. 3.4.14 Chance L6 Not used. l 3.4.15 Chance L.1 1. Does the change involve a significant increase in the probability or consequences of an
. accident previously evaluated?
He proposed change revises the Modes of Applicability for the RCS Specific Activity Specification from Modes 1,2,3,4, and 5, to Modes 1,2, and 3 with RCS average temperature 2 500'F. The RCS specific activity is not an initiator of any analyzed event. nere are not any events for offsite release of RCS activity initiated from below 500'F. Also, below 500'F in Mode 3 and in Modes 4 and 5, the release of radioactivity during a SG tube rupture is unlikely since the saturation pressure of the reactor coolant is below the lift pressure settings of the main steam afety valves. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 3-4-29 Revision 5
--RCS Operational LEAKAGE 3.4.13 6 70 SURVEILLANCE REOUIREMENTS SURVEILLANCE '
FREQUENCY
*4S'T
- C\/SR 3.4.13.1 (---
P:, reg
--NO -
-- ^
C---- E-b ofue/in ('u til/12bired tfbe I3/r Oni qui
- hours of st state o ratp. to perfo 6 1- Sn _ _ _ _ .- dur ng ste y wA1 ket,'dpWM fr4K4de- ~- -
st te ope tion 9 gp, 4 ( Q g ?RCS water inventory balance.^ 72 hours
'D M k I 1 M N " ?- 4 SR 3.4.13.2
#M
~
Verify SG tube integrity is in accordance In accordance-59c 3 Ay! with Program. the Steam Generator Tube Surveillance with the Steam og A,3 Generator Tube Surveillance Prograa I i CE00 STS 3.4-31 Rev 1, 04/07/95
(cro RCS Leakage Detection Instrumentation 2 *-l g O 3.4 CTORCOOLANTSYSTEM(RCS) 3.4.lT RCS Leakage Detection Instrumentation
-h 3.46.1)LCO3.4. (T=
shall be 110 wing RCS 1;.akage detection instrumentation E LE: --^ ~ (3'4.L'l h a. - f One containment sump.ae*44+r;'{andFa-
._u.
[3,4 4.t.e 4 (,,) 6. One containment atmosphere radioactivity monitor " ~ (gaseous or particulate); -[end
. n. . ...... _--,,w, .,_ .._,__ .. >.....-
we . .-. w-w... .
......__ww n,,,.w .. .
g a gg APPLICABILITY: MODES 1, 2, 3, and 4. AtTION [ CONDITION REQUIRED ACTION COMPLET!ON TIME 3 . 4.b, j A. Required containment g sump.ac ---------- NOT E----------- inoperable. g LCO 3.0.4 is not applicable. p 7F-GC 4,,
/% 4.4.(, 1. U -f B A.1 Perform SR 3.4.13.1. Once per N o.......
.....3..
,2-...
g 24 hours 8 we aiu i eiG-4--r,ti$ A.2 Resto e conta naent 30 days 23 sump % n44*r to h OPERABLE status. (continued) CEOG STS 3.4-36 Rev1,04/07/95
RCS Leakage Detection Instrumen to -.. ACTIONS (continued) CONDITION REQUIRE'D ACTION COMPLET!0N TIME o-3,4 ' g ' { B. Required containment f --- STE f' atmosphere Ad*a radioactivity monitor LC0 3. appl s not y,5 yp- @ e. Inoperable. -- -~~ b64'N'b'I* 3 Anal ze grab s M Once per of the containment 24 hours atmosphere. a g l B.1.2 Perform SR 3.4.13.1. Once per 24 hours 1 Y . B.2/ Restore required 30 days containment atmosphere radioactivity monitor
~
to OPERABLE status. - g < B.2.2 Ify containment 30' d'ays I ir cooler condens e flow rate monitor s h OPERABLE. C. Require containment C.1 Perform SR 3.4.15.1. Once per air c ler condensate flow ate monitor ino rable. E 8 hours -
\l Perform SR 3.4. .1. Once p 24 h s (continued)
CEOG STS 3.4-37 Rev1,04/07/95
- DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM
- 37. TSTF 153 revised the Notes for the RCS loops, which provide exceptions to the requirements for required pumps to be in operation in revising the Notes, TSTF-153 created the possibility for misinterpretation. As a result of TSTF-153, the Notes were revised as follows:
Note to NUREG-1432 LCO 3.4.5 "All reactor coolant pumps may not be in operation for s I hour per 8 hour period, provided . . .". Note 1 of NUREG 1432 LCO 3.4.6 "All reactor coolant pumps (RCPs) and SDC pump;niaymot be in operation for s I hour per 8 hour period, provided. . . ". Note 1 of NUREG-1432 LCO 3.4.7 "The SDC pump of the train in operation may not be in operation s I hour per 8 hour period, provided . . .". l-Note 4 of NUREG-1432 LCO 3.4.7 "All SDC trains may not be in operation during planned heatup to MODE 4 when at least one RCS loop is in operation." Note 1 of NUREG 1432 LCO 3.4.8 "All SDC pumps may not be in operation for s 15 minutes when switching from one train to another provided . . .". The justification for TSTF-153 describes that this change is necessary to eliminate ambiguity that culd lead to errors or improper enforcement, llowever, this change can now lead to a misinterpretation of the allowance of the Notes. Specifically, the Notes can now be interpreted as requiring the required loop or train to not be in operation for the specified periods; i.e., it must be taken out of operation. The intent of the Notes (as described in the associated Bases) is to allow (but not require) the required loop to not be in operation for the specified periods. Therefore, for consistency with the original intent and to avoid improper enforcement, the Notes have been revised by replacing the phrase "not be in operation" with the phrase "be not in operation." These revisions make the Notes consistent with the ACTIONS, which use the phrase "not in operation" to describe when the loop is not operating. A generic change has been proposed with this correction to TSTF-153.
- 38. NUREG-1432 SR 3.4.13.1 provides the requirements for verifying RCS operational leakage is within limits. It contains the following note in the surveillance column: "Not required to be performed in Mode 3 or 4 until 12 hours of steady state operation." This Note was deleted from -
ITS SR 3.4.13.1 in order to maintain consistency with the current licensing basis, Current Technical Specification SR 4.4.6.2.e requires RCS leakage to be determined at least once per 72 hours during steady state operation . . ." This proposed deviation will require the-initial CALVERT CLIFFS- UNITS 1 & 2 3.4-11 Revision 5
DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM performance of the surveillance to be performed 72 hours prior to achieving steady state operation in order to comply with ITS SR 3.0.4. This is more restrictive than NUREG-1432, which permits the initbl SR to be performed 12 hours after establishment of steady state operation in Mode 3 or'4 This additional restriction is consistent with the current licensing
= bases, it is acceptable, because it ont; affects the initial performance of the SR. Subsequent performances of the surveillance will be required to be performed at the same frequency (i.e.,72 hours during steady state operation).
- 39. Calvert Cliffs ITS LCO 3.0.4 is not applicable during shutdowns and during MODES 5 and 6.
Therefore, entry into LTOP conditions would be allowed without LTOP requirements being met. Ilowever, it is inapprcpriate to entry conditions most susceptible to an LTOP event when the necessary overpressure protection is not available. Therefore, the ACTIONS of NUREG-1432 Specification 3.4.12, " Low Temperature Overpressure Protection (LTOP) System," (ITS 3.4.12) are modified by a Note which states that while the requirements of the LCO are not met, entry into a MODE or other specified condition is the Applicability is not permitted. l CALVERT CLIFFS- UNITS 1 & 2 3.4 12 Revision 5
l RCS Operational LEAKAGE B 3.4.13 BASES ACTIONS B.1 and B 2 (continued) acting on the RCPB are much lower, and further deterioration is much less likely, A fU SURVEILLANCE SR 3.4.13.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LC0 timits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first ap, war as unidentified LEAKAGE and can only be positively identified by inspection. Unidentified LEAKAGE and identified LEAKAGE are detemined by performance of an RCS water inventory balance. Primary - to secondary LEAKAGE is also measured by performance of an RCS water inventory balance in conjunction with efflueri monitoring within the secondary steam and feedwnter systems. The RCS water inventory balance must be performed with the reactor at steady state operatina conditions and ==ne operatino pressure. here e,4thi SR is fot req red rfo d 1p iw0E Ja ,u I st e ratiphsne cpe ing ssurg2rs_.ar of sed. ea 2 Stsady state operation is required to perfom a proper water inventor balance; calculations during maneuvering are not useful n a ote requires sne 2 in h a m ha mpt whelO state (Vestablishe(fFor RCS operational LEAKAGE ~ determinatWn oy water inventory balance, steady state is defined as stable RCS pressure, temperature, power level, M pressurizer and makeup tank levels, makeup and letdown, and RCP seal Jafeeth, . - . .... .. flows. An early warning of pressure boundary LEAKAGE or g unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment sump level These leakage detection systems are specified in LCO 3.4.1 , 'RCS Leakage Detection Instrumentation." The 72 hour Frequency is a easonable interval to trend g LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. A Note under the Frequency column states that this SR is equired be perfonned during steady state operation, g (continued) CEOG STS B 3.4-72 Rev 1, 04/07/95
. _ _ . _ . m._ _ _ . ._. _ _. _ _. _. _ . . _
4 w e RCS Leakage Detection Instrumentat BASEE 8 3.4. Q ACTIONS A.1 and A.2 (continued) at an increased frequency of 24 hours ' that is adequate to detect leakage.- v de information Restoration of the sump mea 44w to OPERABLE status is g ~ g required to regain the function in a 30 days after the monitor's failure. Completion Time of acceptable considering the fre This time is gater inventory balance requirgency byand adequac of the RCS red Act on A.1. e Re a Sote JiredthatActua AJ the indicates rd "2;&;f provistoi A.t- Mkre modified by fggr47 A '"~ applicable. As a result s of LC0 3.0.4 are not " Wg, p
/.r- containment sumpu h .,channea MODE angecis allowed when the ..
allowance is pro oided because o e r ^ino p' 3'gg available to mon' ter for RCS LEAKAGE. f- *" ^ 1: __m W)
'perable. m ui This (M r'epir.J r4W 2.1.1.s.1.2.b.2 "' ,
With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable alternative action is required. samples of,the containment atmo;phere must be taken andEither grab analyzed, or water inventory balances in accordance with SR 3.4.13.1, must be performed to prov,ide alternate periodic infonnation. - With a sample obtained and analyzed or an inventory balance performed every 24 hours be operated for up to 30 days to allow restoration of at, the reactor may least one of the radioactivity sonitors. Itern vely, ce nued operation is en ool condens low rate monitoring u the atr n ro ed crab les are taken every om is OPERABL , hours. W The 24 hour interval provides periodic information that is adequate to detect leakage. The 30 day Completion Time a recognizes at least one other form of leakage detection is available.
/L\
S equired Ac ons 8.1.1, B.1.2, .2.1 by a Note at indicates th the pro, visions and u.g.zof er 0muu n inul are not plicable. As a sult, a MODE chan 3.0.4 when gaseous and pa is allo
. adt etivity monitor culate containmen tecspher 'fMp p annel is inoperab . This al wance; (continued)
CE0G STS B 3.4-84 Rev1,04/07/95
INSERT 3.4.14 ACTION A
/
- i = A Note ad3M allow' that SR 3.4.13. is not required to performed until 1 ours aner estabi'
- steady : e operation (sta e temperature, r level, pressurize leve , makeup an etdown, and R sealinjection makeup tank return flows). The hour allowance Ih pr ides suffici t time to collect d process all n sary data after sta plant conditions are establisted. ; I
_.~ b INSERT 3.4.14 ACTION B AN is added allowing t SR 3.4.13.1 i ot required to performed until I rs after es ishing steady stat peration (stabla emperature, po level, pressurize 1 1s, makeup and I own, and RCp 1 injection an turn flows). Th makeup hour allo ce lh provides sufficien ime to collect process all nec sary data after sp e plant con ' ions are
' established.
DISCUSSION OF BASES DEVIATIONS FROM.NUREGol432 SECTION 3.4 - REACTOR COOLANT SYSTEM inoperable (i.e., only an RCS loop is operable). The NUREG 1432 Bases for Action A.1 of LCO 3.4.6 state that the action.is required to be met whenever an RCS loop is Inoperable or an SDC train is inoperable. The NUREG-1432 Bases for Action A.1 ofI.CO 3.4.6 is incorrect. Thus, in the ITS, the Bases for Action A.1 of LCO 3.4.6 has been rev! sed to be consistent with Condition A ofITS LCO 3.4.6. The Bases for Action A.1 ofITS 3.4.6 state: "If only one required RCS loop is OPERABLE and in operation and no SDC loops are OPERABLE, redundancy for heat removal is lost." 29, Condition B of NUREG 1432 LCO 3.4.6 applies when one required SDC train is inoperable and two RCS loops are inoperable. The Bases for Action B.1 of NUREG-1432 LCO 3.4.6 state. "If only one required SDC train is Operable and in operation, redundancy for heat removal is lost." The NUREG 1432 Bases discussion is inconsistent with the applicable Condition. Action B.1 of NUREG 1432 LCO 3.4.6 only applies when one SDC train and two RCS loops are inoperable (i.e., only an SDC train is operable). The NUREG 1432 Bases for Action B.1 of LCO 3.4.6 state that the action h required to be met whenever one required SDC loop is inoperable. The NUREG 1432 Bases for Action A.1 of LCO 3.4.6 is incorrect. Thus, in the ITS, the Bases for Action B.! of LCO 3.4.6 has been revised to be consistent with Condition B ofITS LCO 3.4.6. I The Bases for Action B.I ofITS 3.4.6 state: "If one required SDC loop is OPERABLE and in j operation and no RCS loops are OPERABLE, redundancy for heat removal is lost!'
- 30. The Bases for NUREG 1432 SR 3.4.13.1 states: "A note under the frequency column states that .
this SR is required to be performed during steady state operation." This discussion is not i consistent with the Note contained in the frequency column for SR 3.4.13.1. The Note states:
"Only required to be performed during steady state operation." Thus, in the Bases for ITS SR 3.4.13.1, the discussion of the Note has been revised to be consistent with the Note contained in the frequency column for ITS SR 3.4.13.1.
~
CALVERT CLIFFS-UNITS 1 & 2 3.4-4 Revision 5 j _A
- 31. The NRC requested additionaljustification for the changes to CTS Tables 3.3 6 and 4.3 3 for ITS 3.4.14. The following changes were made to resolve the comments: 1) the references to the ITS SRs in the markup of CTS SR 4.4.6.1 for ITS 3.4.14 had to be revised to be consistent with the actual ITS SR rtumbers; 2) the markups for CTS Table 3.3 6 had to be remarked; 3) the references to the applicable ils requirements on the markup for CTS Table 4.3 3 had to be changod or added to be consistent with ITS 3.4.14; 4) DOC LA.1 for ITS 3.4 I4 had to be added tojustify a change to CTS Table 3.3 6; 5) DOC L.1 for ITS 3.4.14 and its associated NSilC had to be revised to reflect changes to CTS Table 3.3 6, and to improve the justification; 6) the ISTS markup for ITS 3.4.14 had to be revised to properly reflect the CTS SRs and Tables; and 7) the ISTS Ilases markup for ITS 3.4.14 had to be revised to include the range of operation for the containment atmosphere radioactivity monitors (ITS 3.4.14 Comments 2 and 3).
i I
RCS Leakage Detection Instrumentation B 3.4.14 BASES both particulate and gaseous activities, bar:ause of their sensitivities and responses to RCS LEAKAGE. These radioactivity monitors have a range of 10'.10' counts per 5 minute (cpm). An increase in humidity of the containment atmosphere would indicate r(lease of water vapor to the containment which p '
. would be an indicator of potential RCS LEAKAbs Since the .
humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow into or from the containment sump. Humidity level monitoring is considered most useful as an L indication to alert the cperator to a potential problem. Humidity monitors are not required by this LCO. Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise abi,ve the normally indicated range of values may indicate RCS LEAKAGE into the containment. The relevance of temperature and pressure measurements are affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to_the containment. Temperature and pressure ' monitors are notJequired by this LCO. APPLICABLE. The need to evaluate the severity of an alaan-or an SAFETY ANALYSES. indication is important te the operators, and the ability to compare and verify with indicatior.s from other systems is necessar/. The RCS Leak Detection Instrumentation is describedintheUFSAR(Ref.3). Multiple instrument locations are utilized, if needed, to help identify the location of the LEAKAGE and its source. The safety significance of RCS LEAKAGE varies widely dependir.g on its source, rate, and duration. Therefore, CALVERT CLIFFS - UNITS'1 & P. B 3.4.14-2 Revision $f
~ .$
$pood'.c.o'% ~3, 4 , l 4 3/4.4 AgAff01COOLANTSYSTEN SURVE!LLANet ht0UlttNENTS g ,. 7.e.&dr-lhe Leaksge Detection Systems shall be demonstrated OPthABLC by 7 4. Ia. 4 \. Containment Atmosphere Gaseous and Particulate Monitorine 3, 4, i 4, 2 3,4, 3 4, y Systems. performance of CNANNEL CNECK, CRAINitL CALIl4ATI0il and CllAlllitt FilllCTI0llAL TEST at the frequencies specified ta ,
Table 4.3 3, and 3* 9 ' M ' 1 T. Containment S Level Alarm $ stem. f g i i CAL 184AT10ll abeast once per htFUEL E ormance of CilA101EL INTERVAL. ' l i i CALVERT CLIFF 5 . UNIT 1 3/4418 Amendment No. 208 9 $, 7 of 6 d.h msun
~
g taste _3.3-6 L,Q % g ,4eLp, S g
\ RADIATION PONITORING IW5Tm*ENT4 TION S pe d u % W ,'<K S I* i l
b MINIMUM
;; CHANNELS APPLICABLE ALARM / TRIP MEASUREMDIT INSTPUMENT OPERABLE MODES __ SETPOINT_ RANGE ACTIO4 k
". O x
e 1. AREA MONITORS inDwa-J E 5 m 2 2.re l %)pi.A d
- a. Containment mA;, ALL E
[ ,
- f. Fm ce & Evhaust Isolaticat 3 K
< M mrY 10 10' er/hr ID =
'g N /
(b. Containment Area High Range 2 \ 1, 2. 3. & 4 <Wr 1 - 10" R/hr 3p
- 2. PROCESS MONITORS ,-
mr & 2
- a. Containscnt
- f. Gaseous Activity ,
/
a) RCS leattge Detection 1. 2. 3 &4 Not 10'.- cpm 14 Appitcab
- 11. Particulate Activity ,
i 8 a) RCS Leatage Dat . on ' 1 2. 3. & 4 Not 10 - cpm 14 g Applicabi N
- b. Noble Gas Ef fluen ~~ flors
- f. Main V Ide Cange 1 1. 2. 3. & 4 10 to 10' pCf/cc
# 30 l
ce
- l M
z 11. Piat Steam Header 2 1. 2. 3. & 4 104 to 10' R/hr 3 b % ~ . I
- d. .'
s 3 _ _ _ - _ . . _ _ _ ._. p
+
.5-c x . . -
N, ,- i ; ,- ~ ~
# e b
/SatU.scusi..n of CnonstS .
\b @c4 cab 3.3.~4, '(t$"/
Q 4BLE 3.3- 'T RM iun w iniaan b NINDWE a DuMIELS SPERAsLE APPLICAsLE M AUWE/ TRIP
-SETPOINT -
prN M MT3M k 7 JNSTRLNENT , e 5
- 1. AREA PENIITORS f
; a. Containment E
[ 4
- 1. Purge & Exhaust Isolation 3- 6 5 220 ar/hr 10 - If ar/hr 16
- b. Containment Area High Range 2 1. 2. 3. & 4 5 10 R/hr 1 - If R/hr 30 h PROCESS MORITORS D3N.IT g 3,3, 3
@ RCS Leakage Detection 1 l 1. 2. 3. & 4 l k- If M
- 11. Part late Activity' a) RCS katA Detectf 1 1 . 3. & 4 t - If cpm I
;t.
g b. Noble Gas Effisent Monitors N icable p g k 1. Main Vent vide Range 1 1. 2. 3. & 4 20# to if pCf/cc 30 3 a . g p g it. nata Steam needer 2 1. 2. 3. & 4 lod to Io' R/hr 30 e = w .
@ .L-g See Oiscuss.on of Cha$tsk -C
^
e cn 3.u.t, " R aa & j r % do.-3 Txsb. ode e i _ b
.SpetMs 44 L 4.l4 3/4.3 IN$TRUMENTATION
. sphi. 2. YAttt3.5-6(Continued)
,
- R ) A. AM9 A4r " TABLE NOTATION Alam setpoint to be specified in a controlled documen (e.g., setpoint control manual).
Le Damf% e4 Ckeys ACTION.$TATEMENTS
$g,&wir,n 3.'y -), "c A 5" /
/9 d'on a g
- q, pl
@- With the msnber of channels OPERABLE less than required b the Minisun Channels OPERABLE requi n comp s wit 4 ACTION requirements of Specification .. . . ._
. v. s v the]'
/.fI QCTION 16 -- With the msnber of channels OPERABLE less than required by' the Mintsun Channels OPERABLE requirement, comply with thej -
MCTION requirements of $pecification 3.9.9 7 ACTION 30 - With the manner of channels OPERABLE less than required by the Mintsus Channels OPERABLE requirement initiate the preplamed alternate method of monitoring the appropriate parameter (s),within72 hours,and:
- 1) either restore the inoperablJ channel (s) to OPERABLE status within 7 days of the~ event, or
/ See Di l'
- S 5 ' * #(' I
- 2) prepare pursuantand to submit 10 CFRa50.4 Special Re$
within ort stofollowing 0 da the Conrnission the l Cm lhl s u b,as event, outlining the action taken, t e cause of the Ol'#^ S*
- f.7 I ino g\
th'perabtitty,
'Y5t** and the plans and schedule for restoring i c T '. . 3. % s , " R nd. E""E $t't"5' j -- - \
H\o n l kts r s'r IM hun
- N g, ,, , g Spefw k 3 3.so,**tsmt*
CALVERT CLIFFS - UNIT-1 - 3/4 3-25 -Amendment No. 216 f*P &
g g fea 0ac.w..,t U. Q b Sg fGtJ w 3.'DO,74 5 taste 4.3-3 RABIATIM MONITMING INSTIMIMDITATIM SMTEfttANCE RE95DIDIUff5 (h 7 po, k
'x &
y jc , 8 b b O T z Sgu%b l.3.7, v s' CaupIEL CIWelEL MBES 25 IAIIG I"C j
'a IstSTiteMurr Causett
..CNECK CALIBRATIM FUNCTIONAL TEST SURTEILUNCE REggDIEB
[i-g g T1. AREA MONITOR 5
- jfg
- a. Containment es s
.y g
(_ 1. Purge & Exhaust Isolation 5- _ RETWCLING owetuvat _f M 6 ] \* 1_ h_ Containment Area Minh Range S wtretLIuli M I.2.3.&4] tImwAL f t' 2. PROCESS MONITORS
=
t* a. Containment
- 1. Gaseous Activity. 3. 8'l I 3 ,, y, y y q , ;. OPI f 3 'l'I' a) RCS Leakage Detection S R M 1. 2. 3. 1 4
- 11. Particulate Activity g a) RCS Leakage Detection 5 R M I, 2. 3 & 4
. Noble Gas Effluent Monito 3
- 1. Main Vent Wide Range 5 R M I. 2. 3. & 4 '
2 I
? C it. Main Steam Header S M R
I. 2. 3 & 4 )i k MA 3 b M ~~ cn w h . b 4 i PC p Q . 3
5 p c. r J .% .'. . 34.i4, A.\ 3/4.4 ktACTOR C00LAlti SYSTDI SURYtILLAllCE kt0V!tDltWTS SM -4M*1-The Leakage Detection Systems shall be demonstrated OPERABLE by: 3*i '
- I %. Containment Atmosphere Gaseous and Particulate Monitort
,4.44.2 Systems. performance of CIIAlmtL CutCK. CRAlsitL CALIBRAT!h and
*g,4,t4.q CilAlllitL F1111CT10llAL TEST at the frequencies spectfled in Table 4.3 3, and
. *p 3* 4 ' 8 +' I
~
._7tbntainment$ Level Alarm $ rformance of CR41eltL k : , ~;p
~
l CALIBRATI0li abeast once per btem- FUEL IIG INTERVAL. l l l CALVERT CLIFFS - UNIT 2 3/4 41B Amndment No.186 p, 2 . c c. A
l l
~
p C e 0.u . w... A a - s 3 Taste 2.s-s e S dd* 3.30 3 RADIATION MONITORIK INSTR PENTATION - C r m rMon CHANNELS APPLICABLE ALARM / TRIP MEASURIMENT U INSTRUMENT OPERABLE MODES _SETPOINT RAKE ACTION "
] E
, 1. AREA MONITORS w h .. En -
g g a. Contairmt w ers 1. %),. A, N g 7A, ,. N, g
- 1. Purge a Oraust Isolation h 6 5 220Mr 10 - 10' rr/hr d
16 1 l e N / - Q. Contairrtent Area High Range 2 % 2. 3. & 4 _y10 R/hr 1 - 10' R/hr 30)
- 2. PROCESS MOMITORS g gm,,
R a. Containment ke< C A 1 3.f* ,F N "
- 1. Gase:ms Activity a) RCS Leakage Detection 1. 2. &4 Not 10' - 10' cp]m 14 Appitcable '
- 11. Particulate Activity a) RCS Leakage ection 1 2. 3. & 4 Not 10' - I cpm 14 App 11 cab g b. Noble Gas Eff ent tiont to n
y 1. Mai ' Tent Wide Range 1 1. 2. 3. & 4 .' 10# to 10'.pCf /cc 30) ta A 4 3 ] f Maln Steam Header 2 1, 2. 3. & 4 10 to 10' R/hr c N . [ g to M I,
% /- 9
+
A y g; . x py ,. w hbr
.:4. x
_- .. .- l
\
,. m.
S Seds.ussoa d Ch2$c5
.k(e.c.'D*2<ttssiovi Sp.ukehen 33.7, *ces* of Chan3ts <Q$peu6c,w 33.to,N a 3.3 E
b ATI .# f
;; WWIATftlW MONI MINDEM g
- C CWMMELS APPLICABLE- AtJust/ TRIP MEASWEEMENT 5 SPERABLE MODES . SETMINT . RANGE ACTISR Pg 3 INSTRUMDri
. 1. AREA MONITORS E c C y a. Containment
- f. Purte & Exhaust Isolatfen 3 6 5 220 mr/hr 104 - 10' w/hr 16
- b. "Centainment Area High Range 2 I. 2. 3. S 4 S 10 R/hr 1 - 10' R/hr 30 ,
h FRDCEss PDlliORS Q Containment cy - %Act2d pet 33 4,g Y g Gsseous Actfvity l '
@ RCS Lt-3kage Detection 1 ,II.2.3.&4l l10' - 10' cysl 4 '
\ - 11. Particulate Act ty
\
. a) RCS Leatage Det tion .: 2 1. 2, 3 4 Ilot 10'- Mf nei Applicable \
- b. Moble Gas Effluent Ponitors
- 1. Main vent wide b oe 1 1. 2. 3. a 4 10# to 20' pct /cc 30 g/)
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Alarm (e.g., sesetkoint point controto manual). be s$ecified in a controlled documentj ACTION $1MDM11 A r b o^. b ACTION 14 - With the number of channels OPERABLE less than required by 3*q'fy the Minimum Channels CPERABLE requirement the A A,T ACTION tequirements of Specificationq;Lhc i 4 .s . kwit (ACTION 16 - With the number of channels OPERABLE le';s than required by the Minirum Channels OPERABLE requirement comply with the l kACTION reouirements of speci'iication 3.9,9e (ACTION 30 - With the number of channels OPEPAtV. Its: than requirttit
,] the preplanned Minimumalternate Channels CPERABLE ed. hod requirement, of monitoring tr.e sp;Mpriate initiate the parameter (s),within72 hours,and:
- 1) either restere the inoperable channel (s) ttJ CPT.RABLE status r. thin 7 days of the event, or
"" ()' ' " u *f ri ,,,du 2) ort to the Cccuission prepare pursuant toand submit 10 CFR 50.4a within Special Re$0 days following the l - #r , , ' ,*e c l (, c . , b e C7 L event, cutlining the action taken, the cause of the [,\i inoptrability, and the plans and schedule for restoringJ 3,3,3,I,dnd,i m m, the system to OPERABLE status.p -_
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DISCUSSION OF CilANGES SECTION 3.f.14 - RCS LEAKAGE DETECTION INSTRUMENTATION TEUilNICAL CilANGES - h!OVEMENT OF INFORMATION TO LICENSEE CONTROLLED HDCUMENII: _ - LA.1 Current Technicel Specl0 cation Tsble 3.3 6, item 2.a contains requirements regarding the containment atmosphere gaseous and particulate radioactivity monitors. The tab!c provides the range for these instruments. Improved Technical Specification 3.4.14 will provide the ' requirements for the containment atmosphere gaseous and particulate radioactivity monitors; however, it will not require the instrurnents pesess a specific range. 'the instrument ranges will be relocated to the Bases of ITS 3.4.14. This is acceptable, because ITS 3.4,14 will continue to provide the requirements for operability of the containment atmosphere radioactivity monitors Additionally, the instrument ranges can be adequately controlled in f the Bases, because the Bases will be controlled via the Bases Control Program provided in ITS Chapter 5.0. This approach provideY an cirective level of iegulatory control and provides for a more appropriate change ccStrol piocess, in addition to the justification provided above, the relocation of this inferrantion to a lleensee controlled document is consistent with NUREG 1432. TECHNICALCMGES - IMiS IESIldC[lXE L.1 Current Technical Specification LCO 3.4.6.1 requires the cont.ainment atmosphere particulate radioactivity monitoring system, the containment sump level alarm system, and l the containment atmosphere 13aseous radioactivity monitoring system to be operable. Additionally, CTS Table 3.3 6, item 2.a requires a minimum of one channel of the conteinment atmosphere gaseous radioactivity monitoring system to be operable, and a minimum of one channel of the containment atmosphere particulate indicactivity monitoring i system. ITS 3.4.14 requires the containment sump level alarm system and one containment I ' atmosphere radiation monitor (either the particolate or the gaseous) to be operable. The requirements regarding the containment ritmosphere particulate and gaseous radioactivity monitors in CTS LCO 3.4.6.1 and Table 3.3 6, item 2.a htye been modified to reflect the I requirementi for the containment atmosphere radioactivity monitor in ITS 3.4.14. Currem Technical Specification LCO 3.4.6.1 has been revised to only require two RCS leakage detection systems to be operable (i.e., the containment sump level alarm systern and either the containment atmosphur particulate radioactivity monitor or the containment atmosphere gaseous ndloactivity monitor). Cunent Technical Specification Tatle 3.3-6, item 2.a has been revised to require a minimum of one char.nel be operable for the gaseous or particulate activity monitor. Hese proposed chauges are acceptable, because the LCO continues to require instruments of diverse monitoring principles to be Operable to provide a high degree of assurance that extrernely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS leakage indicatea possible reactor coolant pressure boundary degradation. Reactor Coolant System leakage can be detected by other means including: a) ITS SR 3.4.13.1 requires an RCS water balance to be performed periodically; and b) other instrumentation not required by this Technical Specification (i.e., volume contml tank level, pressurizer level, containment pressure, containment temperature, and containment humidity). In addition to thejustification provided above, the proposal changes are consistent with NUREG-1432. 1.2 Current Technical Specification 3.4.6.1 Action b requires the inoperable RCS leakage detection instrument to be restored to Operable status whhin seven days when only one RCS leakage detection instrument temains Operable. Improved Technical Specification 3.4.14 CALVERT CLIFFS - UNITS I & 2 ' '.4.14-2 3 Revision 5
NO SIGNIFICANT 11NIARDS CONSIDTRATIONS
,SECTION 3.4 - REAcr0R COOLANT SYSTD1 do not involve a signlucant increase in the probability or consequences of an accident previously evaluated.
2. Does the change ercate the possibility of a new or different kind of aceldent from any previously evaluated? Cunent Technical Specification SRs 4.4.6.2.a.1, 4.4.6.2.b, and 4.4.6.2.d are being eliminated. The climination of these SRs do not affect the ability to quantify RCS leakage. Improved Technical Specincation LCO 3.4.13 will continue to provide leakage limits, and ITS SR 3.4.13.1 provides the method for quantifying leaks to ensure these limits are maintained. Additionally, ITS 14.14 will contain operability requirements regarding the RCS leakage detection systems; these requirements ensure that RCS leaks that could potentially challenge the limits are pmmptly
. identified. The proposed changes do not introduce a new mode of plant operation and do not -
involve physical modiGention to the plant. The proposed changes do not introduce any new accident initiators. 'lherefore, they do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
'I'he margin of safety is established through the design of the plant structures, systems and components, the parameters within which the plant is operated, and the estabihhment of the setpoints for the actuation of equipment relied upon to respond to a event. 'lhe proposed changes
! do not signlucantly impact the condition or perfonnance of structures, systems or components I relied upon for accident mitigation. 'Ihe proposed changes do not impact any safety analysis assumptions. Therefore, they do not involve a signinennt reduction in a margin of safety. 3al3IhangcL2 l Not used. j JAL4fhangcL1 1. Does the change involve a significant lnercase in the probability or consequences of an accident prerlausly evaluated? Current Technical Specincation LCO 3.4.6.1 has been revised to only require two RCS leakage detection systems to be Operable (i.e., the containment sump level alann system and either the containment atmosphere particulate radioactivity monitor or the containment atmosphere _ gaseous radioactivity monitor). Current Technical Specification Table 33-6, Item 2.a. has been revised to require a minimum of one channel be operable for the gaseous or particulate activity monitor. These proposed changes are acceptable, because the LCO continues to require instruments of diverse monitoring principles to be Operable to provide a high degree of nssurance that extremely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS leakage indicates possible reactor coolant pressure boundary degradation. Additionally, ITS 3.4.13 contains a Surveillance which requires a periodic determination of RCS leakage; this Surveillance provides additional assurance that the integrity of the reactor coolant pressure boundary is being maintained. Failure of containment atmosphere radioactivity monitors is not an initiator of any analyzed event. Reactor Coolant System leakage will still be adequately detected by the remaining instrumentation, the RCS inventory balance, and other instmmentation not required by this CALVERT CLIFFS ImlTS 1 & 2 3 4-25 Revision $ w__ .
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM Technical Specification (i.e., volume control tank level, pressurlier level; containment pressure, containment temperature, and containment humidity). The change will not alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not signincantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? ne change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. De proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or difkrent kind of accident from any accident prevloissly evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
Cunent Technical Specification LCO 3.4.6.1 has been revised to only require two RCS leakage detection systems to be operab.te (l.c., the containment sump level alarm system and either the containment atmosphere particulate radioactivity monitor or the containment atmosphere gaseous radioactivity monitor). Current Technical Specification Table 3.3 6, item 2.a. has been revised to require a minimum of one channel be operable for the gaseous or particulate activity monitors. Diverse methods of leck detectiw continue to be required by the Technical Specification (onc containment sump monitor, one containment atmosphere radiation monitor, and a periodic RCS inventory balance) which will assist in early detection of RCS leakage. In nddition, other instrumentation which are part of'he plant design provide additional means for j detecting RCS leakage. Therefore, the change does not involve a significant reduction in a
- margin of safety.
l l 3.4.14 Chanec L.2
- 1. Does the change involve a significant lucrease in the probability or cor. sequences of an accident previously evaluated?
The proposed change increases the allowed outage time from seven days to 30 days when only one RCS leakage detection instrument remains Operable. Failure of RCS leakage detection is not an initiator of any analyzed event. One RCS leakage detection instrument remains operable
. during this period. Also, the Actions require that an RCS inventory balance or grab sample of the containment atmosphere be performed once per 24 hours. These mechanisms, along with other methods (i.e., monitoring changes in volume control tank level and pressurizer level; monitoring containment pressure, temperature and humidity; etc.) that are not part of the RCS leak detection instrumentation Technical Specification, ensure that RCS leakage will be detected while only one monitor remains Operable. The change will not alter assumptions relative to the mitigation of an accident or transient, ne proposed change does not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated.
2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? . The proposed change increases the allowed outage time from seven days to 30 days when only one RCS leakage detection instrument remains Operable. The change will not involve a CALVERT CLIFFS - UNITS 1 & 2 3-4-26 Revision S [.ml
e RC$ Leakage Detection Instrumen (m>
$URVtillANCE RIQUIR[MENTS (continued)
$URVEILLANCE
, FREQUENCY
(,4 (,l', R 3.4. 2 Perfore CHANNCL FUNCTIONAL TEST of the days re
.V. A b raguiredcontainmentstaosphere toactivity monitor.
l 3 Perfore CHANNEL CALIBRATION of the required q,g,g'$R3.4. containment sump months
$R 3.4. 4 Perform CHANNEL CA T!0N o the required months containment atmosphere radioactivity - /
T d t.,, 4.3 2
- s 2'A SR 3. 15.5 Perfore CHANNE LIBRATION of the requi d con nt cooler condensate f1 ate (18]sonths [
CE0G STS 3.4-39 Rev1,04/07/95
I RC$ teskage Detection 8Instrumentatiodn 3.4. b 83.4 CTOR COOLANT SYSTDt (RCS) , 8 3.4. RC$ Leakage Detection Instrumentation BASIS BACKGROUND 0 of Aa6Mdix A trio cFR 50)(Ref. '1)' requires means l 8e k' M.).slb e ur e ENth[3Mkit [tegul - Guide 1.45 Uter. 2) describes acceptable methods for ' j selecting leakage detection systems. I Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary degradation as soon after occurrence as practic(RCPB) al to . - minimize the potential for propagation to a cross fatture. Thuslt pers proper evaluation of all unidentified LEAKAGE.an early indication or warning Industry practice has shown that water flow changes of W W le # 'aks % ok iw 0.5 ppe to 1.0 gpa can readily be detected in contained i i 4 d.. 44 c4 c.id. 4 J volumes by monitoring changes in water level. In flow rate, ump.
'har - M or sumpin the usedoperating frequencyL of a kAKAGE'Thehontainment to collect unidentified N m m - -t e u m --- r n u = .;.[is_n e --
a,.,.t u s %
/*jyl - 2*/ M fE N'2 N' hh hhct
# e r 31,e m 3,4 ,;, detectir.gincreasesinunidentifiedLtkAGE.
O h .: Io,y, J The reactor coolant contains radioactivity that, when e,,)
- f'due Ajt, released to the containment can be detected by radiation
+
monitoring instrumentation., Reactor coolant radioactivity U c c/c /. fc 4, levels will be low during initial reactor startup and for a r_ _ _ _~'_ few weeks thereafter untti activated corros a=
'.. - s nave Mt
- 1'3 3 been formed and fission products appe Q claddina e sensitivittee o n or claddin pct /ccGS a fuel element '
acts. Instrument arsevM monitoring and #C1/ccm W-"="kfor " Tor oarticulate gaseo 3g morntering are tical for these leakage detection systems. Radioactivity detection systems are included fo #~ # .5/ monitoring both particulate and gaseous activities. because-of-their sensitivitles.and map 44 responses to RCS LEAKABE.
/ MbtAW W. q-l 1
An increase in humidity of the containment atmosphe _tadicate alanse of water vapor to the containment uld av f hofftaikab s [s n
, (continued)
CE00 $TS 8 3.4-81 Rev1,04/07/g5
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- 32. The NRC requested additional justification for a change included in the markups of CTS SR 4.10.5.2 for ITS 14.17. They also requested that the markups of CTS LCO 3.10.5.c for ITS 3.4.17 be modined to accurately reDect the requirements of ITS 3.4.17. While resolving these comments, numerous denciencies with the original submittal reguimg ITS 3.4.17 were identined. To asolve these comments and issues, the following changes were required: 1)the markups of CTS 3/4.10.5 for ITS 3.4.17 were revised to renect the current licensing bases;
- 2) DOCS LA.),IA.2, and A.2 were eliminated; 3) DOC A.3 was created tojustify changes to the CTS; and 4) ITS 3.4.17 had to be revised to be consistent with the current licensing bases (ITS 3.4.17 Comments 1 and 2).
l l
STE RCS Loops - MODES 4 and 5 3.4.17 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.17 SpecialTestException(S1E)RCSLoops-MODES 4and5 LCO 3.4.17 The reactor coolant circulation requirements of LCO 3.4.6, "RCS Loops-MODE 4 " !C0 3.4.7, "RCS Loops-MODE 5 Loops Filled " and LCO 3.4.8, "RCS Loops-MODE 5. Loops Not Filled" l may be suspended during the time intervals required: 1) for g local leak rate testing of containment penetration number 41
.m n m, pursuant to the requirements of the Containment Leakage Rate Testing Programt and 2) to pennit maintenance on valves l
located in the comon shutdown cooling suction line or on the
- shutdown cooling flow control valve provided l
l a. Xenon reactivity-is 5 0.1% Ak/k and is approaching stability g
- b. No operations are permitted which could cause reduction of the RCS boron concentrationt
- c. The charging pumps are deenergized and the charging flow paths are closed; and
- d. The SHUTDOWN MARGIN requirement of LCO 3.1.1 is verified every 8 hours.
APPLICABILITY: MODES 4 and 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.. One or more- A.1 Suspend activities Inunediately requirements of the being performed,under y LCO not met, this STE. CALVERT-CLIFFS.- UNITS.1 & 2 3.4.17 1 Revision Afr
STE RCS Loops - H0 DES 4 and 5 3.4.17 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify xenon reactivity is tithin limits. Once within I hour prior to suspending the l reactor coolant y l circulation requirements of
.,_ LCO 3.4.6, LCO 3.4.7, and ly LCO 3.4.8 SR 3.4.17.2 Verify charging pumps de-energized. 1 hour SR 3.4.17.3 Verify charging flow paths isolated. 1 hour SR 3.4.17.4 Perform SR 3.1.1.1. 8 hours CALVERT CLIFFS - UNITS 1 & 2 3.4.17-2 Revision /r
STERCSLoops-H0 DES 4and5lf 3.4.17 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.17 bpecial Test Exception (S1E) RCS Loops - H0 DES 4 and 5 BASES BACKGROUND This special test exception to LCO 3.4.6, "RCS Loops - H0DE 4 " LCO 3.4.7, "RCS Loops - MODE 5. Loops Filled," and S' LC0 3.4.8, "RCS Loops - MODE 5. Loops Not Filled" allows no RCS or shutdown cooling (SDC) loops to be in operation during the time intervals required: 1) for local leak rate y testingofcontainmentpenetrationnumber41(shutdown cooling); and 2) for maintenance on the comon shutdown S cooling suction line or on the shutdown cooling-flow control valve (CV-306). APPLICABLE As described in LC0 3.0.7 coc11ance with Special Test SAFETY ANALYSIS Exception LCOs is optional, and therefore no criteria of 10 CFR 50.36(c)(2)(ii) applies. Special Test Exception LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is
.provided in their respective Bases.
LC0 This LCO is provided to allow for the performance of testing and maintenance in MODES 4 and 5 (normally after a refueling),wherethecorecoolingrequirementsare significantly different than after the core has been operating. Without this LCO, plant operations would be held bound to the normal operation LCOs for reactor coolant loops and circulation (MODES 4 and 5), and the appropriate tests or maintenance could not be performed in these MODES. In MODES 4 and 5, operation is allowed under no flow conditions provided the xenon reactivity is s 0.1%- Ak/k and approaching stability, no operations are permitted which could cause reduction of boron concentration, the charging g CALVERT-CLIFFS - UNITS 1 & 2 B 3.4.17-1 Revision $f
STE RCS Loops - MODES 4 and 5 f 3.4.17 BASES pumps are de-energized, the charging flow paths are isolated, and the SHUTDOWN MARGIN requirement of LCO 3.1.1 I is verified at least once per 8 hours. These limits along with the Surveillances ensure no safety limits or fuel design limits will be violated. l The exception is allowed even though there are no bounding safety analyses. These tests or maintenance are allowed - l since they are performed under close supervision during the l test program and must stay within the requirements of the LCO. l l i
-APPLICABILITY The LCO ensures that while within this LCO the plant will not be operated in any other MODE besides MODES 4 and 5 without forced circulation. This is because the MODES of Applicability for this Specification are MODES 4 and 5.
This Specification allows testing and maintenance to be performed on the SDC system while SDC is required to be OPERABLE. ACTIONS 6d If one or more requirements of the LC0 are not met, all ' activities being performed under this STE must be immediately suspended. These activities are local leak rate g testing of the shutdown cooling penetration and maintenance on valves in the shutdown cooling system. The Completion Time to suspend these activities immediately ensures the plant is not placed in an unanalyzed condition and prevents exceeding the specified-acceptable fuel design limits. SURVEILLANCE SR 3.4.17.1 REQUIREMENTS Xenon reactivity must be verified to be within limits once within one hour prior to suspending the reactor coolant circulation requirements of LC0 3.4.6, LCO 3.4.7, and g CALVERT CLIFFS - UNITS 1 & 2 8 3.4.17-2 Revisiongf
STERCSLoops-MODES 4and5lI 3.4.17 BASES LC0 3.4.8. The frequency of once within one hour prior to suspending the applicable RCS Loops LCO will ensure that the xenon reactivity is within linilts and trending toward stability prior to suspending forced flow cooling. This will ensure no safety limits or fuel design limits will be violated while testing or maintenance are being conducted. SR 3.4.17.2 and SR 3.4.17.3 Verifying the charging pumps are de-energized and the c //ging flow paths are isolated ensures that the major source of a boron reduction is not available. These two Surveillances support the requirement that no source be available that could cause an RCS boron concentration reduction. These SRs are required to be verified at a frequency of one hour. The one hour frequency is sufficient to ensure that these sources will not be available to cause a reduction of the RCS boron concentration. Subsequent perfonnance of these Surve111ances after the initial verification that the charging pumps are de-energized and the charging flow paths are isolated, may be performed administratively. LR, _L 4.17. 4 This SR requires that a SDM verification be performed in accordance with SR 3.1.1.1 once per 8 hours. The nonnal Frequency for these Surveillances is once per 24 hours. The S~ 8 hour frequency reflects that no forced flow cooling t i available and that the SDM should be verified more frequently. The 8 hour frequency is sufficient to ensure that the SDM remains within limits while under this STE. 5" CALVERT CLIFFS - UNITS 1 & 2 B 3.4.17-3 Revision 45-
c3g aQ. b e 3.4.l7 3.+ 4<: . = = = = == === =ts.;w 4 T ,1 E% h 3.4 n
.n m, ,m,,,.,,,o.,,
th M % d Es<<c b a 6 0 RC5 tws- mecs 4..A r h LIMITIM C0WITION FOR OPERAi!0N 4 4,6, 3.4.7, ,J L.cc ~~ 3. 4. 5 3'4'p 440d The react _ coolant circulation requirements of Specificattorr 3. . , g all 'iaHBr woient pu,. ant stIUttsutt TUOTThDQq be e. l ett testing o'%cen/UUFTNF thTTimenumber ts' nmenu nanatrattaa Intervals41 worea altoTor pursuant theinter 1Mt* i requirements of tsnect"1 cat' on 4.n.1.2 Dand 2). to pemit maintenance on A ; valves located in common shutdown cooling suction line or on the l shutdown cooling low trolwelpe- g 0 l.m v,4,dedo e,st' n{CYA06)<p m.7~e41-r - - .
- 1.co ?..ot.n bcs, No operation aMh.sk,*ne emitted-wflich-foui b.k.
% th use-diiO1'1Dn-17tliE'gg Reactor Coolant System boron concentrationf and specifically, the charging pumps shall be de. energized and'the charging flow paths
, gco 3, y, s)g shall be closed.
.a o s ..t. ) 44. The xenon reactivity is 10.1% ok/k and is approaching stability, and uo '+ 8 74I pg
- c. The SWrDOWN MARGIN requirement of $ stification X.1.r]his A b 4,17 'I v3rifjad at least nnre ner a heurs/w$on Creactof _cpelant puWre in operatifn.;p- shutgowfRoo #g% '
A'3 b effilIA11LIII: N00t$ 4 and 5. ACTION: With the requir.ements of the above soecification not tat < efied. suspend all operationsrinvolvi local leak rate testing of cent 'nment Gunwir Vaaithon numoer 4Ti maint
,Han una. and nce on valves located in the c
_ntenance on valve CV.306. n shutdown / A. gg SURVE!LLANCE REQUIREMENTS
'34,0 1 m 4, ir,. ,
M rhe charoina mumss_sha'1 be verified de.enerairedland the
.-(cherg ng f' ow paths sha ll )e ver' fled closed _jat least once per hour.
Ml1.3 grt
- .10.3.2 The xenon reactivity shall be detemined to be 10.1% ok/k and approaching stability within 1 hour prior to suspending reactor coolant 3 A,r?.I circulatio g
vs (Yio e m.,a l: o5 *
% 'I* "> b' 'l' ) %0 L l _. . . -
CALVERT CLIFFS - UNIT 1 3/4 10 5 Amendment No.16g pay \ *l \
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- 3. 4 . t 7 3/4710;8 000LM-CMLAYW b" ' T'u F- * ~ r -
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'3 . 4, l 7 4.44,4. The reac O r coo'ino c'rtulation reauf.
may be sus I aqE
- + = af taaef ficatiot6 . " . (~ "_3' # 'I Mfdur' fac'.or~ coolevitMLanfshut40Fn ng Welliniiliifervals ee6TingM_
reguliTI) for local ~Isa li inment penetr_gLion number 41 pursuant to the requirements of JH119Lhtd.g@and 2) to pemit maintenance on valves located common shutdown cooling suction line or on the shutdown cooling f1 co ,1 valv (CV406) y1 eds - sg~'t ., h w g, gj7 b/. No operatins s' e Nte N i N oul'd cause utk M d D Reactor Coolant System boron concentration, and specifically, the chareing pw.ps shall be de energized and the charging flow paths LC.c1 3. */, / 7. C- shallbeclosed, g7 ,l> a F. The menon reactivity is a 0.1% Ak/k and is approaching stability and (to 3,4/. ' 7, d c. The SMTDonal ad_at least once NARGIN per 8 hourf requirement wh n of Speciff eation 3.1.1.2
*J is2.\/A
)
5 & 1. 4. I 7,'/ or/coglant paga arean operetty_,yshupown pooli)g or APPLICABILITY: MODES 4 and 5. ACTION: With the requirements of the above specification not satisfied.
^
suspendalloperationsiinvomng
.. ir.Ovn .. ,srA 1 i leat rate ItThTTiconte.-..i A on valves 1 ed in the cooli g suctionA fne.. mainte and ma nance on val CV 306. _ pc n shut -
n i SURYtILLANCE REQUIREMENTS SR % . _ _ _ . I' 'N2 4.lo.oriM charging ;" ps snaii os veriffYa ce-energriED and the SQ .-@ing flow patns snan ne verifica closed)at least once per hour.
~5. 4. D " . ;; . ", . The menon reactivity shall be detemined to be 5 0.1% Ak/k and approaching stability within 1 hour prior to suspending reactor coolant M circulatic 3,4.1 % \ , . ,. s - -
sj %- m;_s"sa m../wa s %_
~~
k c.~0 L co 3. /. s -
~
ms._.t_- CALVERT CLIFFS - UNIT 2 3/4 10 5 Amendment No. 149 p $a Io l
l DISCUSSION OF CHANGES SECTION 3.4.17 SPECIAL TEST EXCEPTION RCS LOOPS o MODES 4 AND 5 ADMINISTRATIVE CIIANGES A.1 ne proposed change will reformat, renumber, and reword the existing Technical l Specifications, with no change of intent, to be consistent with NUREO 1432. As a result, ' the Techn! cal 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 infonnation may also have been added to more fully describe each LCO and to be consistent with NUREO 1432. Ilowever, the additional information does not change the intent of the i current Technical Specifications. The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Not used. l A.3 Current Technical Specification LCO 3.10.5 states: "The reactor coolant circulation - ; requirements of Specification 3.4.1 may be suspended and all reactor coolant pumps and ' shutdown cooling pumps may be de energized. . ." Improved Technical Specification LCO 3.4.17 simply states that the reactor coolant circulation requirements may be suspended. This statement is equivalent to CTS LCO 3.10.5, because, whenever the reactor coolant circulation requirements of the specified ITS LCOs are suspended, there are no reactor coolant pumps or shutdown cooling pumps in operation. The method for removing the pumps from service does not need to be addressed. This proposed change is administrative; it does not change the intent of the CTS. Additionally, CTS LCO 3.10 $.c states: "The SilUTDOWN MARGIN requirement of Specification 3.1.1.2 is verified at least once per 8 hours when no shutdown cooling or reactor coolant pumps are in operation." Section d ofITS LCO 3.4.17 simply states that the SilUTDOWN MARGIN requirement must be verified every 8 hours. This statement is equivalent to the statement in CTS LCO 3.10,5.c. The SilUTDOWN MARGIN is only required to be verified at the increased frequency when the reactor coolant circulation requirements of the specified LCOs are suspended (i.e., no shutdown cooling or reactor coolant pumps are in operation). This proposed change is administrative; it does not change the intent of the CTS. TECllNICAL CIIANGES - MORE RESTRICTIVE None TECllNICAL,CilANGES - RELOCATIONS None TECilNICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.) Not used. l CALVERT CLIFFS - UNITS 1 & 2 3.4.17-1 Revision 5
- - - - = . _ - - . - _ . - - . - - - - - _ _ - . - . - _ - - _ - - - . . - _ -
DISCUSSION OF CHANGES SECTION 3.4.17 . SPECIAL TEST EXCEPTION RCS LOOPS . MODES 4 AND 5 LA.2 Not used. l i IA.3 Current Technical Specification 3.10.5 Action specifically lists the Actions (based on the LCO) to be suspended if the LCO is not met. *lhese specific Actions ' vill be moved to the ^ Bases, consistent with the movement of specific applications of the STE (see another movement of details discussion of change in this section). 'this is consistent with NUREG 1432 philosophy to move specific details into the Bases. Any changes to the Bases will be consistent with Bases Control Program in ITS Chapter 5.0. 'the Bases Control Program will ensure that changes to this requirement receives an appropriate review. TECliNLCAL CilANG}:S . ITRS RESTRICTIVE None 1 1 I l 4 b i
\
i I b CALVERT CLIFFS UNITS I & 2 3.4.17 2 Revision 5
- 3. 4 STE RCS Loops. MODES 4 an 5 6,4 3.4 -
REACTOR COOLANT SYSTEM (RCS) 3.4.17 Special Test Exception (STE) RCS Qw - p(S 4 and 5 Ebh,' F? Q tM) LCO 3.4.17 %e equirements of LCO 3.4.6, "RCS Loops MODE 4, LCO 3.4.7, "RCS loops MODE 5, loops Filled"and LCO 3.4.8, "RCS loops-MODE 5, loops Not Filled." may be sump:grovided: Xenon reactivity
-- yb .
6.t'iS .Q. a. approaching stability;
-(3105.*)b. No operations are perniitsd which could cause reduction of the RCS 4,to. c.4 c. . % g concentration' ev e[s e.n s' J g4 3.'~
c_% ,y hlow& s s va c- t =}} * .Au ~ 6.Ic. S. c.) c( , APPLICABILITY: Th. s OY 40 wI\/q u MM6Y N ib,cujs" m u d o! MODES 4 and 5 Ltc 3.1.1 I w v3 6 hout' ACTIONS b CONDITION REQUIRED ACTION COMPLim0N TIME A. kenon reactivity not withind A.1 Suspend activities being Immediately limits - performed under this STE. J ', OR rations .urring w 'ch could ca redu tion of RC 'toron (e tion. 4 Y" ~
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INSERT 3,4.171 during the time latervals required: 1) for local leak rate testing of containment penetration number 41 pursuant to the requirements of the Containment Imkage Rate Testing Program; and 2) to permit maintenance on valves located in the common shutdown cooling suction line or on the shutdown cooling flow control valve (CV-306) I
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'2WJfrJ 3.4.17 e secv (d w i
r .- (TS) SURVEILLANCE REQUIREMENTSreqvirenod _ 7 M SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify xenon reactivity is within limits, once within I hour priortosuspendmg 4
/
LCO 3.4.6, LCO 3.4.7,
.l0.5. 2) ,g, SR 3.4.17.2 Verify charging pumps de energized.' Ibour M.10 5.1)
SR 3.4.17.3 Verify charging flow paths isolated. Ibour
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SR 3.4.17.4 OTE On[requir to be ormed s no So/
,g, (shbtdow coolin x
p is in ration.
) h Perform SR 3.1.1.1. 8 hours 4 k
TdS5d7 ' L 'l.II OC'M) STE RCS Loops - MODES 4 and 5 B 3.4.17 1 D 3.4 REACTOR COOLANT SYSTEM (RCS) ^ B 3.4.17 Special Test Exception (STE) RCS Loops - MODES 4 and 5 Bases i BACKGROUND This epocial test exception to LCO 3.4.6,"RCS 1. oops MODE 4;" LCO 3 A.7, "RCS loops-MODE 5, Imops Filled;" and 140 3 A.8, "RCS Loops-MODE 5, leo s (Jot Filled" allows p_oACS N~vi M b b q *- SDQoops.to be 'n vhile nin spesaltegC i ,MN.b r y""' ')-o@orctatiqns, ohqain sce.Mesektiyit2 'nclu giocalleak d for b rate testing of contairunent penetration nT,nber 41 (shutdown f* coolingand,Qmaintenance on the common sliutdown Q[ coohng suTtIon line or on the shutdmvn cooling flow control valyc (CV-306). l APPLICABLE As described in LCO 3.0.7, compliance with Special Test i SAFETY ANALYSIS Exception LCOs is optional, and therefore no criteria of 10 CFR l 50.36 (c)(2)(ii) apply. Special Test Exception LCOs provide I flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion or the criteria satisfied for the other LCOs is provided in their re*pective
' Bases.
LCO This LCO is provided to allow for the performance of testing and maintenance in MODES 4 and 5 (normally during a refuehng outagc), where the core cooling requirements are significantly different thau after the core has been operating. Without this . 1 CO, plant operations would be held bound to the normal ') operating LCOs for reactor coolant loops and circulation (MODES 4 and 5), and the appropriate tests or maintenance 1 could not be performed in these MODES. In MODES 4 and 5, operation is allowwi under no flow t conditions provided the xenon reactivity is s 0.1% Ak/k and i approaching stability /$no operations are permitted which ID could cause reduction of boron concentration, These limits along , with the Surveillances ensure . Jafety limits r fuel design limits will be violated.
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tJJEAT w, 3.4.M Gquj STE-RCS Loops - MODES 4 and 5 B 3.4.17 BASES l The exception is allowed evon though thue are no bounding saf.:ty analyses. %ese tests or maintenance are allowed since i they are performed under clooe supenision during the test l program and must stay within the requirements of the LCO. l .+ .. I ~ f l APPLICABILITY The LCO cast.res that while within this LCO the plant will not be operated in any other MODE besides MODES 4 and $ without forced circulation. This is because the MODES ofApplicability for this Specification are MODES 4 and 5.1Fs Specification allows testing and maicenance to be performed on tim SDC system while SDC is required to be OPERADLR ACT10NS M
}m.m.<~mJ)oneoernordif engnrc9ctivityis nojt vith imitjs tifope7ationsp j (e v i, e e h curfinMh* cdd caG . .tetton m RCSmron c6ncentdition, 4 Lr o e all a'etivities being pe'rfonn
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s O under this STE must t:oimmediat$lyg suspended. nese activities @tavuidyd31ocalleak rate testing of y OO4 **}. the shutdown cooling penetration Gpmaintenance on val.ns in the shutdown coaling system. The Completion Time to suspend these activities immediately msures the plant is not placed in an unanalyzed condition and prevents execeding the specified - t acceptable fuel design limits.
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SURVEILll.NCE SR 3 4.17.1 k h d < coo k b A 1 REQUIREMENTS o L {.l 3 , FT n We-eb ot Xenon reactivity must be vc ficd to m 'n units once witidn one hour prior to suspendin CO 3.4.6, LCO 3.4.7, and LCO 3,4.8. The frequency of once within one hour prior to suspending
- th; appsmble RCS Loops LCO will ensure that the xenon -
rer. M is within limits and trending toward stability prior to suspendmg forced flow cooling. This will ensure no safety limits or fuel design linuts will be violated while testing or mamtenance are being conducted. Fy Y l
ItM E <T 3.4.17 6A54.5 - STE-RCS I4 ops -MODES 4 and 5 B 3.4.17 i
- BASES SR 3.4.17.2 and SR 3.4.17.3 Verifying the charging pumps are de mergized and the charging flow paths are isolated ensures that the mahr source of a boron y reduction is not available - %cse two Surveillandes support the requirement that no source be available that could cause an RCS boron concentration reduction. Dese SRs are required to be wrified at a frequency ofone hour, ne one hour frequency is ,
sufficient to ensure that these sources will not be available to l l cause a reduction of the RCS boron concentration. - Subsequent performance of these Surveillances after the initial verification that the charging pumps are de-energized and the charging flow paths are isolated, may be performed administratively. ( ' SR 3.4.17.4 his SR requires that a SDM verification be performed in accordance with SR 3.1.1.1 once per 8 hours. The normal
}5 _
Frequency for these Surveillanc2@bonce per 24 hours. The 8 hour frequency reflects that no forced flow cooling is available and that the SDM should be verified more frequently. The 8 hou frequency is sufficient to ensure that the SDM remains within limits while under this STE. The SRis modified y requ to be per by,fa note. The note specifies that the S is-when no hutdown ling or S 1 is in tion. His res that th R frequ is not . inct from i rmalinte untilall fon flow is - opped. 6 REFERENCES Nonc pay 39 3
- 33. The NRC requested additionaljustification for Relocated Specifications based on not meeting the four criteria in 10 CFR 50.36(2)(ii) for retention in the Calvert Cliffs Technical
- Specifkations. Discussion of Changes R.1, R.2, R.3, R.4, R.5, and R.6 were revised to provide additionaljustification (ITS 3.4 Relocated Specific,tions Comment).
__.___._...._...:.m_ - 4 -
DISCUSSION OF CHANGES CTS 3/4.4,7 - CHEMISTRY ADMINISTRATIVE CHANGES None TECIINICAL CHANGES - MORE RNTRICTIVE None TECIINICAL CIIANGES - RELOCATIONS R.1 Cur' rent Technical Specification 3/4.4.7 places limits on the oxygen, chloride and fluoride content of the RCS to minimize corrosion. Minimizing corrosion of tne RCS reduces the potential for RCS leakage or failure due to stress corrosion, and it ultimately ensures the-structural integrity of the RCS. He chemistry monitoring activity serves a long term preventive rather than a mitigative purpose, a) Current Technical Specification 3/4.4.7 does not address installed instrumentation that is used to detect and indicate in the control room a significant degradation of the reactor coolant pressure boundary. Current Technical Specification 3/4.4.7 does not satisfy Criterion 1. b) Current Technical Specification 3/4.4.7 does address operating restrictions regarding RCS water chemistry, llowever, these operating restrictions are not an initial condition I of a design basis accident or transient analysis that either assumes the failure of or presents a challenp to the integrity of a fission product barrier. Current Technical f Specification 3/4.4./ does not satisfy Criterion 2. c) While the water chemistry limits do protect the reactor coolant pressure boundary from corrosion, this requirement is a long term preventive measure rather than a mitigative function. He RCS water chemistry limits do not support a primary success path which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challerm to the integrity of a fission product barrier. Current Technical Specification 3/4.4.7 does not satisfy Criterion 3. d) The operating restrictions covered by CTS 3/4.4.7 have not been shown to be risk significant to public health and safety by either operating experience or probabilistic safety assessment. This was established in the Combustion Engineering Owner's Group Criteria Application Report, CEN-355, issued in December 1987; which concluded the RCS water chemistry limits were not a significant contributor to core damage frequency and offsite releases. BGE has reviewed this evaluation, considers it applicable to Calvert Cliffs, and concurs with the assessment. Current Technical Specification 3/4.4.7 does not satisfy Criterion 4. Current Technical Specification 3/4.4.7 does not satisfy any of the criteria of 10 CFR 50.36(c)(2)(ii). Thus, it will be relocated to the Technical Requirements Manual (TRM), a licensee-controlled document. The TRM will be included in the Calvert Cliffs' UFSAR by reference. Thus, any changes to this requirement, once it is relocated to the TRM, will be made in accordance with 10 CFR 50.59. CALVERT CLIFFS - UNITS 1 & 2 CTS 3/4.4.7-1 Revision 5
DISCUSSION OF CHANGES CTS 3/4A 9.2 - PRESSURIZER PRESSURE / TEMPERATURE LIMITS ADMINISTRATIVE CIIANGES None IECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANGES - RFLOCATIONS R.1 Current Technical Specification 3/4.4.9.2 places heatup and cooldown limits on pressurizer temperature, as well as providing a limit regarding the maximum spray water temperature difTerential. These limits are placed on the pressurizer to prevent non-ductile (i.e., brittle) failure and ensure compatibility of operation with the fatigue analysis. Tne requirements are consistent with those provided in ASME Boiler and Pressure Vessel Code, Section III, Appendix 0. While the limits provided in CTS 3/4.4.9.2 do protect the pressurizer, the passive functiom.1 integrity of the pressurizer is not maintained by activities of the operators during plant operation. Pressurizer integrity is a design feature maintained by ASME Code
. design and component cyclic / transient limits imposed outside of the Technical Specifications, a) Current Technical Specification 3/4.4.9.2 does not address installed instrumentation that is used to detect and indicate in the control room a significant degradation of the reactor coolant pressure boundary. Current Technical Specification 3/4.4.9.2 does not satisfy Criterion 1.
b) Current Technical Specification 3/4.4.9.'2does address operating restrictions regarding pressurizer heatup and cooldown limits, and spray differential temperature. Ilowever, these operating restrictions are not an initial condition of a design basis accident or transient analysis that either assumet the failee of or presents a challenge to the 4 integrity of a fission product barrier. Current Technical Specification 3/4.4.9.2 does not I satisfy Criterion 2. c) The operating restrictions imposed by CTS 3/4.4.9.2 do not support a primary success path which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Current Technical Specification 3/4.4.9.2 does not satisfy Criterion 3. d) The operating restrictions covered by CTS 3/4.4.9.2 have not been shown to be risk significant to public health and safety by either operating experience or probabilistic safety assessment. This was established in the Combustion Engineering Owner's Group Criteria Application Report, CEN-355, issued in December 1987; which concluded the pressurizer pressure /temperattire limits were not a significant contributor to core damage frequency and offsite releases. BGE has reviewed this evaluation, considers it applicable to Calvert Cliffs,' and concurs with the assessment. Current- Technical Specification 3/4.4.9.2 does not satisfy criterion 4. Current Technical Specification 3/4.4.9.2 does not satisfy any of the criteria of 10 CFR 50.36(c)(2)(ii). Thus, it will be relocated to the TRM, a licensee-controlled document. 'Ihe
'CALVERT CLIFFS - UNITS 1 & 2 CTS 3/4.4.9.2-1 Revision 5 u
DISCUSSION OF CIIANGES CTS 3/4.4.9.2 -- PRESSURIZER PRESSURF/ TEMPERATURE LIMITS TRM will be included in the Calvert Cliffs' UFSAR by reference. Thus, any changes to this rquirement, once it is relocated to the TRM, will be made in accordance with 10 CFR 50.59. TECHNICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS None TECIINICAL CIIANGES - LESS RESTRIL7 LYE None
- .. .+ . 5 s.-,
l CALVERT CLIFFS - UNITS 1 & 2 CTS 3/4.4.9.2 2 Revision 5
DISCUSSION OF CHANGES CTS 3/4.4.10.1 - STRUCTURAL INTEGRITWASME CODE CLASS 1. 2, & 3 COMPONENTS ADMINISTRATIVE CIIAMGEM None TECIINICAL CHANGES _J10RE RESIBICTIVE None TECIINICAL CHANGES - RELOCSUDES R.1 Current Technical Specification 3/4.4.10.1 provides the inspection requirementa for the ASME Code Class 1,2, and 3 componerts to ensure their structural integrity, ne inspection prograrns for the ASME Code Class 1,2,:and 3, components ensure that the structural integrity of these components will be maintained at an accepinble level throughout the life of the plant. This Technical Specilication is directed toward prevention of component degradation and continued long-term maintenance of acceptabic stmetural conditions, nese requirements serve a long term preventive mther than a mitigative purpose. a) Current Technical Specification 3/4.4.10.1 does not address installed instrumentation that is used to detect and indicate in the control room a significant degradation of the reactor coolant pressure boundary. Current Technical Specification 3/4.4.10.1 does not satisfy Criterion 1. b) Current Technical Specification 3/4.4.10.1 does not address a pr%.s vari.'..ble, design feature, or operating restriction that is an initial condition of a design basis accident or transient nnalysis that either aasumes the failure of or presents a challenge to the integrity of a fission product barrier. Current Technical Specification 3/4.4.10.1 does not satisfy Criterion 2. I , c) The requiremects of CTS 3/4.4.10.1 do not support a primary success path which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Current Technical Specification 3/4.4.10.1 does not satisfy Criterion 3. d) The requirements of CTS 3/4.4.10.1 have not been shown to be risk significam to public health and safety by either operating experience or probabilistic safety assessment. This was established in the Combustion Engineering Owner's Group Criteria Application ,
. Report, CEN-355, issued :in December 1987; which concluded the pressurizer pressure / temperature limits were not a significant contributor to core damage frequency
[ ! and offsite releases. 'BGE has reviewed this evaluation, considers it applicable to Calvert
; Cliffs, and concurs with the assessment. Current Technical Specification 3/4.4.101does not satisfy Criterion 4.
Current Technical Specification 3/4.4.101 does not satisfy any of the criteria of 10 CFR 50.36(c)(2)(ii). Rus, it veill be relocated to the TRM, a licensee-controlled document. The TRM will be included in the Calvert Cliffs' UFSAR by reference. Thus, any changes to this requirement, once it is relocated to the TRM, will be made in accordance with 10 CFR 50.59. CALVERT CLIFFS - UNITS 1 h 2 CTS 3/4.4.10.1-1 R-vision 5 1
DISCilSSION OF CHANGES
- CTS 3/4.4.1.1 - CORE BARREL MOVEMENT
- ADMIN 15TRAT1Y.I CIIANGES None TECHNICAL CilANGES - hiQRE RERTRICTIVE None IECHNICAL CIIANGES - RELOCATIONS IL1 - Current Technical Specification 3/4.4.11 provides requirements to ensure early detection of excessive com barrel movement ifit should occur. This Technical Specification is directed i u d:s,, toward prevention of component degradation and continued long tmun_ maintenance.of l acceptab!c structural conditions. These requirements serve a long term preventive rather than a mitigative purpose, a) Current Technical Specification 3/4.4.11 does not address instelled instrumentation that is used to detect and indicate in the control room a significant degradation of the reactor
[ coolant pressure boundary. Current Technical Specification 3/4.4.11 does not satisfy Criterion 1. b) Current Technical Specifiation 3/4.4.11 does not address a process variable, design j feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or prescuts a :halicnge to the , integrity of a fitsion product barrier. Current Tecimical Specification 3/4.4.11 does not l satisfy Criterion 2. , c) The requirements of CTS 3/4.4.11 do not support a primary success path which functions ! or actuates to mitigate a design basis accident or transient that either assumc . the failure ofor presents a challenge to the integrity of a fission product barrier Current Technical Specification 3/4.4.11 does not satisfy Criterion 3. d) Core Barrel Movement is not considered to be a risk significant factor at Calvert Cliffs to public health and safety by either operating experience or probabilistic safety assessment. Current Technical Specification 3/4.4.11 does not satisfy any of the criteria of 10 CFR 50.36(c)(2)(ii). Thus, it will be relocated to the TRM, a licensee. controlled document. The TRM will be included in the Calvert Cliffs' UFSAR by reference. 'Ihus, any changes to this requirement, once it is relocated to the TRM, will be made in accordance with 10 CFR 50.59. TECHNICAL CHANGES - MGVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS None o TECilNICAL CHANGES - LESS RESTRICTIVE None h CALVERT CLIFFS - UNITS -1 & 2 CTS 3/4.4.11-1 Revision 5
DISCUSSION OF CHANGES CTS 3/4.4.13 - REACTOR COOLANT SYSTEM VENTS ADMINISTRATIVE _QLMiGES None TECIINICaL_.CUANGES ,_MORE RESIBICTIYE - None IECHNICAL CUANGES -3ELOCATFOE.S R.1 Curre it Technical Specifwation T4.4.13 places Smits on the RCS vents. The RCS vents are used to exhaust, from the scactor vessel, non-condensable gases arrd/or steam which could inhibit naturai circeir6n core cooling flow fol;owing any event involving a loss of offsite power and requhing long term cooling, such as a Loss of Coolant Accident, llowever, the , vents are not required to cperate to mihgate any design b'. sis accident or transient.
- l Opention of the vents is not assumed in the safety analysis. Operation of the vents is not part of any primmy success path. It is au cperator action after the event has occurred, and it is required only if there is indice. tion natural circulation is not occurring.
a) Current Technical Specification 3/4.4.13 does not address installed instrumentation that is used to detect and indicate in the control room a signi0 cant degradation of the reactor coolant pressure boundary. Current Technical Specification 3/4A.13 does not satir#y Criterion 1, b) Current Technical Specificatica 3/4A.13 does not address a process variable, design j feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either asscmes the failure of or presents a challenge to the integrity of a fission product barrier. Current Technical Specification 3/4A.13 does not satisfy Criterion 2. c) The RCS vents do not support a primary success path which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Current Technical Specification 3/4.4.13 does not satisfy Criterion 3. d) The RCS vents have not been shown to be risk significant to public health and safety by either operating experience or probabilistic safety assessment. This was established in the Combustion Engineering Owner's Group Criteria Applicatic Report, CEN-355, issued'in December 1987; which concluded the RCS vents wen: not a significant contributor to core damage frequency and offsite releases. Baltimore Gas and Electric Company has reviewed this evaluation, considers it applicable to Cahart Cliffs, and concurs with the assessment. Current Technical Specification 3/4.4.13 doe. not satisfy Criterion 4. Current Technical Specification 3/4.4.13 does not satisfy any of the criteria of 10 CFR 50.36(c)(2)(ii). Thus, it will be relocated to the TRM, a licensee-controlled document. The TRM will be included in the Calvert Cliffs' UFSAR by reference. Thus, any chanEes to this requhement, once it is relocated to the TRM, will be made in accordance with 10 CFR 50.59.'
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CALVERT CLIFFS - UNITS 1'& 2 CTS 3/4.4.13-1 Revision 5
l l
- 34. The NRC requested additionaljustificatien for excluding a specification regarding RCS primary isolation valve leakage from the ITS. JFD 16 to Section 3.4 was revised to provide additional justification (ITS 3 A Primpey isolation Valve Comment).
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DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM 15. Specification 3.4.12 (LTOP System) Applicability was changed from Mode 4 when any RCS cold leg temperature is s 285'F, Mode 5, and Mode 6 when the reactor vessel head is on, to Mode 3 with any RCS cold leg temperature is s 365'F (s 301*F for Unit 2) and Modes 4,5, and 6. His change is consistent with the Calvert Cliffs requirement to have the Pressurizer Safety Valves and PORVs Operable in Modes 1 and 2, and Mode 3 with any RCS cold leg l temperatures > 365'F (> 30l*F for Unit 2).- ne addition of the Note which exempts the LCO when the RCS is vented to ;t 8 square inches allows the equipment for the LCO to not be applicable when the reactce vessel head is off. Also, changes were made to the Actions consistent with the changes made to the Applicability. 16. NUREG-1432 Specification 3.4.14 provides requirements for RCS pressure isolation valves. ne Calvert Cliffs' ITS do not contain the requirements of this Specification, excent for the SR which tests the interlock that prevents the shutdown cooling system suction isolatiot. valves from opening at a specific pressure. His SR is currently addressed as CTS SR 4.5.2.e.1, and it has been retained as ITS SR 3.5.2.9. Calvert Cliffs Unit Nos. I and 2 were licensed prior to 1979. Neither unit has any specific requirements to individually leak test any pressure isolation valve. Additionally, Calvert Cliffs was not identified by the NRC Event V order, dated April 20,1981, as an older plant that was required to add a requirement for leak testing pressure isolation valves. As described in the Calvert Cliffs' response to Generic Letter 87-06, " Periodic Verification of j Leak Tight Integrity of Pressure Isolation Valves," dated July 7,1987, the pressure isolation L valves are either; a) periodically tested in accordance with the requirements of ASME f Section XI; b) periodically tested in acudance with 10 CFR Part 50, Appendix J; or c) the L pressure upstream of the valves (i.e., Sl 217,227, 237, and 247) is continuously monitored by remote hdication in the control room. These activities ensure the valves are meeting their pressure isolation function. Therefore, Calvert Cliffs does not need to add additional requirements to the ITS to ensure these valves are leak tested. 17. Specification 3.4.15 (RCS Leakage Detection Instrumentation) SR 3.4.15.2 Frequency is being changed from 92 to 31 days. This change is consistent with the current Calvert Cliffs Surveillance Frequency for the containment atmosphere radioactivity monitor Channel Functional Test. 18. Specification 3.4.16 (RCS Specific Activity) Required Action A.2 Completion Time to restore i the Dose Equivalent I-131 to within limits is being increased from 48 hours to 100 hours. This change is consistent with the Calvert Cliffs current licensing basis. 19. A new Specification [ Specification 3.4.17, "Special Test Exception (STS) RCS Loops - Modes 4 and 5"] was added to Section 3.4. His new Specification is a Special Test Exception which allows LCOs 3.4.6, 3.4.7, and 3.4.8 to be suspended while performing special tests or maintenance (i.e., local leak rate testing on containment penetration 41, maintenance on valves located in the common shutdown cooling line, or maintenance on the shutdown cooling flow control valve). This Specification is consistent with the Calvert Cliffs current licensing basis. This i:hange also resulted in changing the title of Specification 3.4.16 to include Mode 2.
- 20. Not used.
l 21. NUREG-1432 SR 3.4.9.3 requires the verification that the pressurizer heaters are capable of-being powered by an emergency power supply. This surveillance does not exist in CTS 3/4.4.4. CALV'ERT CLIFFS- UNITS 1 & 2 3.4-5 Revision 5
)
l o
I 35. Technical Specincation Task Force TSTF 153 modined the Note ofISTS LCO 3.4.5, Note 1 of I ISTS LCO 3.4.6 Notes I and 4 ofISTS LCO 3.4.7, and Note i ofISTS LCO 3.4.8. This TSTF has been approved. Thus, :t was incorporated into the ITS. Unfortunately, the TSTF creates the potential for an incorrect interpretation. It replaced various phrases in the notes with the phrase "may not be in operation." This phrase could be misinterpreted to mean that the pumps cannot be in operation. This was not the intent of the TSTF. The phrase "may not be in operation" was replaced with the phrase "may be not in operation." The ISTS markups of Note I to ITS LCO 3.4.5, Note 1 of ITS LCO 3.4.6, Notes I and 4 of ITS LCO 3.4.7, and Note 1 of ITS LCO 3.4.8 were revised. These deviations are justined by JFD 37 to Section 3.4. Additionally, the ISTS markup for the Bases of ITS 3.4.5 had to be revised to reDect the revised note; this deviation isjustined by JFD 2 to Bases Section 3.4. 1 k
RCS Loops - MODE 3 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Loops - MODE 3 LC0'3.4.5 Two RCS loops shall be OPERABLE and one RCS loop shall be in operation.
..................--------- NOTES----------------------------
- 1. All reactor coolant pumps (RCPs) may be not in operation 6
.for s 1 hour per 8 hour period and 5 2 houts per 8 hour period for low flow testing, provided:
- a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature in maintained at least 10"F 5 below saturation temperature.
- 2. No RCP shall be started with any RCS cold leg temperature s 365*F (Unit 1), s 301*F (Unit 2) unless:
1
- a. The pressurizer water level is s 170 inches;
- b. The pressurizer pressure is s 300 psia (Unit 1),
s 320 psia (Unit 2); and f
- c. The secondary water temperature of each steam
[ i generator is s 30*F above the RCS temperature. APPLICABILITY: MODE 3. t CALVERT CLIFFS - UNT.TS 1 & 2 3.4.5-1 Revisiongf < l l _i
RCS Loops - MODE 4 3.4.6 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.6 RCS Loops - HODE 4 LC0 3.4.6 Two loops consisting of any combination of RCC loops and shutdown cooling (SDC) loops shall be OPERABLE and at least one loop shall be in operation. ____....................-. NOTES----.....--.__----..__-___
- 1. All reactor coolant pumps (RCPs) and SDC pumps may be l$I not in operation for s I hour per 8 hour period, i
provided: l a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core _ outlet temperature is maintained at least- 10*F SI-below saturation temperature.
- 2. No RCP shall be started with any RCS cold leg
-temperature s 365'F (Unit 1), s 301*F (Unit 2) unless:
- a. Pressurizer water level is s 170 inches;
- b. Pressurizer pressure is s 300 psia (Unit 1),
L .s 320 psia (Unit 2); and
- c. -Secondary side water temperature in each steam generator (SG) is s 30*F above each of the RCS cold leg temperatures.
APPLICABILITY: MODE 4. L i
\e
.CALVERT CLIFFS - UNITS 1 & 2 3.4.6-1 Revision J/ 6 ci:.
a 1
- i . . ..s - - - -
......_...._.i . ._4 .. .
RCS Loops - MODE 5, Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops - MODE 5 Loops Filled LC0 3.4.7 One shutdown cooling (SDC) loop shall be OPERABLE and in operation, and either:
- a. One additional SDC loop siall be OPERABLE; or
- b. The secondary side water level of each steam generator (SG) shall be 2 -50 inches.
--------------------------- NOTES----------------------------
- 1. The SDC pump of the loop in operation may be not in T operation for s 1 hour per 8 hour period provided:
, a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is maintained at least 10 F 5-below saturation temperature.
- 2. One required SDC loop may be inoperable for up to 2 hours for surveillance testing provided that the other SDC loop is OPERABLE and in operation.
- 3. No reactor coolant pump (RCP) shall be started with any RCS cold leg temperature s 365*F (Unit 1), s 301*F (Unit 2)unless:
- a. The pressurizer water level is s 170 inches;
- b. Pressurizer pressure is s 300 psia (Unit 1),
s 320 psia (Unit 2); and
- c. The secondary side water temperature in each SG is s 30*F above each of the RCS cold leg temperatures.
- 4. All SDC loops may be not in operation during planned heatup to MODE 4 when at least one RCS loop is in operation.
CALVERT CLIFFS - UNITS 1 & 2 3.4.7-1 Revision g y
RCS Loops - MODE 5. Loops Not Filled 3.4.8 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.8 RCS Loops - MODE 5, Loops Not Filled LCO 3.4.8 Two shutdown cooling (SDC) loops shall be OPERABLE and one SDC loop shall be in operation.
..........................-NOTES----.-----..------.-.-.----.
- 1. All SDC pumps may be not in operation for s 15 minutes 6
- r when switching from one loop to another provided:
- a. The core outlet temperature is maintained at least 5 10*F below saturation temperature;
- b. No operations are permitted that would cause a reduction of the RCS boron concentration; and
- c. No draining operations to further reduce the RCS water volume are permitted.
- 2. Ona SDC loop may be inoperable for s 2 hours for surveillance testing provided the other SDC leap is OPERABLE and in operation.
APPLICABILITY: MODE 5 with RCS loops not filled. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SDC loop A.1 Initiate action to Immediately inoperable, restore SDC loop to OPERABLE status. CALVERT CLIFFS - UNITS 1 & 2 3.4.8-1 Revisiongg l
RCS Loops - MODE 3 B 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 LC0 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 51 hour per 8 hour 5 period and s 2 hours per 8 hour 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 saturation temperature so that no vapor bubble may form and possibly cause a natural circulation flow obstruction. In MODES 3, 4, and 5, it is sometimes necessary to stop all RCPs or shutdown cooling (SDC) pump forced circulation (e.g., to change operation from one SDC train to the other, to perform surveillance or startup testing, to perform the transition to and from SDC System cooling, or to avoid operation below the RCP minimum net positive suction head limit). The time period is acceptable because natural circulation is adequate for heat removal and the reactor coolant temperature can be maintained subcooled. CALVERT-CLIFFS - UNITS.1 & 2 B 3.4.5-2 Revision #5 i
RCS Loops-HODE 3 3.4.5 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 - RCS Loops-MODE 3
.4.t.hC0 - 3.4.5 Two)(RCS loops shall be OPERABLE and one RCS loop shall be n operation. f+- . . .. .
NOTE---- pumps may seen-aaadited for s 1 hour I b hAllreactorcoolan per 8 hour period provided gg 4.(;.s .
/
- a. No operations are pomi ed that would cause reduction of the RCS boron concen ration; and
, - . , u, _ ,
- b. Core outlet temperatu is maintained at least 10*F below saturation temp rature._ mmeer
-----~~ ---~~~----- --~~- - - ~ ~ - " - - - ~ ~ ~ ~ - - ~ ~ - - - - - - - - - - - - - Leo AWG E-APPLICABILITY: MODE 3. *~
e .
^ W* ~
l ACTIONS CONDITION REQUIRED ACTION- COMPLETION TIME A. Oct required RCS loop A.1 Restore required RCS noperable. 72 hours loop to OPERABLE 3A .t. 4. status. (Acre. a B. Required Action and B.1 Be in MODE 4. associated Completion 12 hours 3AL
^**" Time of Condition A not ret.
(continued) CEOG STS 3.4-8 Rev.1,04/07/95 l l 1 l
RCS Loops-MODE 4 3.4.6 3.4 REACTOR COOLANT SYSTEM (RCS) j 3.4.6 RCS Loops-MODE 4 leo 4 (3. 4.la) LC0 3.4.6- Two loeps r t:N consisting of an combination of RCS c loops and shutdown cooling ( and at least one loop e in._ hall be in shall be OPERABLE operation. h k n d sq ..._ _ _ _ . - - - NOTES------ --- g '
- 1. -
O/2*'4 M All reactorfor coolant 'TSf8* /S 3 descersizee 51 hour pumps per 8 (RCPs) hour periodandSDCpumpsmay(S
, provided:
- a. No operations are permitted that would cause 3 4.1.3 ~ :~
Agiwq @ reduction of the RCS boron concentration; and A
- b. 5 L1 Core outlet temperature is maintained at least 10'F below saturation temperature.
- 2. No RCP shall be started with any RCSiioi cold GAleg 8: 365 # )
temperature s ta4[}'F unless: , O 9 .'b' a. Pressurizer water level is q:.ar @ hW. Secondary side water temperature in each steam generator (SG) is +tt90}'F abo e each of the RCS cold leg temperatures-t 63o O
- , . : . = _ v , .
pfr<m,:. b. u pre m ,,. u a * " " I"
- O u JL @
APPLICABILITY: MODE 4. %3EY93 L g ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 34,l.3 A. One required RCS loop A.' A*4 " " inoperable. Initiate action to immediately restore a second loop e t; .6 to OPERABLE Ni2 status. Two SDC inoperable. (continued) CEOG STS 3.4-10 Rev1,04/07/95
~
RCS Loops-MODE 5, Loops fillW 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops-MODE 5, Loops' Filled A13) LC0 3.4.7 One shutdown cooling (SDC)Siiiit shall be OPERABLE operation, and either: @ and in N Alh a. One additional SDC shall be OPElhWLE; or usw b. The secondary side wate_rJaval of =Jch g se tA."1 o*e a \
'(SC) shall beamnar e-foPN _ steam generator C
" " 1. _ . - N0TES - -. The SDC pumptof_theAceit in operation ma/S
- La if+&.
~ , '
7*t-ft'-/53 gewersees for s I hour per 8 hour pertoa provt : (3A.13- a. No operations are persitted that would cause reduction of the RCS baron concentration; and b. Core outlet temperature is maintained at least 10'F below saturat erature. NEv/ 2. One required SDC may be inoperable for up to 5 , p g1 b o c. 1,. t, 2 hours for surveillance testing provided that the other 3. SDC No reactor co BLE and in operation. g .g %
- - - - - t pump (RCP) shall be started with M 1AM unless:
' '" RCS cold leg temper ures y k n U"'*O 366.a t)
N a. W ~
- D)
The pressurizer water level is~.e 46$3%; er The secondary side water temperature in eac ~ JUM3
#N 4. A
" "0^'"T empe tures.
C above each of the RCS cold le g ,w h Soc M,"1 may b --- o fan operation during 0" L. t planned in operattor.. heatup to MODE 4 when at least or.e RCS loop is _~ k, Nu i"' r'u S*'E b d-- APPLICABILITY: MODE 5 with RCS loops filled. a g CEOG STS 3.4-13 Rev 1. 04/07/95 J
RCS Loops-MODE 5. Loops Not Filled 3.4.8 4m> 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5, Loo s Not Filled (SA.thc0
'7 3.4.8 loop (h
Two shutdown coolino (SDC) DE9fs shall be OPERABLE and one h a SDC uda shall be In operation. Q2/ g ' ^Op *en efanfron I/d MTES -- - - - 7117.)$'3 P
- 1. All SDC puC BayChe4e-enarnim for g l$ minutes when-switching f.ve one to another provided:
<3A.Ii3.b*\/ a. he core outle emperature is maintained low saturation temperature; M '
O' 4 ,u @ d
/d
- b. No operations are permitted that would cause a reduction of the RCS boron concentration; and
! c. No draining operations to further reduce the RCS i water volume are permitted. NEW
- 2. One SDC may be inoperable for s 2 hours fe surveillance testing provided the other SDC is leo b M'4'I b*:. L. OPERABLE and in operation.
APPLICABILITY: MODE 5 with RCS loops not filled. ACTIONS CONDITION REQUIREDACTION COMPLETION TIME 3A I1 A. One SDC A! Adoa
- inoperable, Initiate action to Innedtately restore SDC to OPERABLE status, g (continued)
CEOG STS 3.4-16 Rev 1. 04/07/95
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3A - REACTOR COOLANT SYSTEM I l 1 37. TSTF-153 revised the Notes for the RCS loops, which provide exceptions to the requirem , requinA pumps to be in operation, in revising the Notes, TSTF-153 created the possibility for misinterpretation. As a result of TSTF-153, the Notes were revised as follows. { Note to NUREG-1432 LCO 3.4.5 l 1
"All reactor coolant pumps may not be in operation ot' r s I hour per 8 hour period, provided . . .".
Note 1 of NUREG-1432 LCO 3.4.6 "All reactor coolant pumps (RCPs) and SDC pumppaymot_ be in operation for s I hour per 8 hour period, provided. . . ". ' ' Note 1 of NUREG-1432 LCO 3.4.7 "The SDC pump of the train in operation may not be in operation s I hour per 8 hour period, provided . . .". Note 4 of NUREG-1432 LCO 3.4.7 "All SDC trains may not be in operation during planned heatup to MODE 4 when at least one RCS loop is in operation." Note 1 of NUREG-1432 LCO 3.4.8 "All SDC pump; may not be in operation for s 15 minutc when switching from one train to another provided . . .". The justification for TSTF-153 describes that this change is necessary to climinate ambiguity that could lead to errors or improper enforcement, llowever, this change can now lead to a misinterpietation of the allowance of the Notes. Specifically, the Notes can now be interpreted as requiring the requirci loop or train to not be in operation for the specified periods; i.e., it must be taken out of operation. The intent of the Notes (as described in the associated Bases) is to allow (but not require) the required loop to not be in operation for the specified periods. Therefore, for consistency with the original intent and to avoid imprope enforcement, the Notes have been revised by replacing the phrase "not be in operation" with the phrase "be not in operation." These revisions make the Notes consistent with the ACTIONS, which use the phrase "not in operation" to describe when the loop is not operating. A generic change has been proposed with this correction to TSTF-153.
- 38. NUREG-1432 SR 3.4.13.1 provides the requirements for verifying RCS operational leakage is within limits, it contains the following note in the surveillance column: "Not required to be pei ormed in Mode 3 or 4 until 12 hours of steady state operation." This Note was deleted from ITS SR 3.4.13.1 in order to maintain consistency with the current licensing basis. Current Technical Specification SR 4.4.6.2.c requires RCS leakage to be detennined at least once per 72 .
hours during steady state operation . . ." This proposed deviation will require the initial 1 CALVERT CLIFFS-UNITS 1 & 2 3.4-11 Revision 5
RCS Loops-MODES 3 l 8 3.4.5 BASES (continued) LCO h The purpose of this LCO is to requirebtwo loops to be arallable for heat removal, thus providing[ The dundancy. LCO of requiresboth requiring theattwo 1 oops SGs}^to betocapable be OPERAB (d with the intent transferring heat from the reactor co4%nt at a controlledwater level) of k n at rate. transport Forced heat reactor coolant flow is the required way to 08 8 '*M'" adequate remova,l.althou$ntmum Am NY~ of one runninh natural circulattan flow prfvides LCO requirement for one loop in operation.g RCP meets the -
,,,,,,_g,,, .
The Hot permits a limited period of operation wi hout RCPs. All RCPs mawt woe .u. ee..P for s 1 hour per 8 hour peri h This means When that in natural natural circulation circulation, a reduction has been established. in boron ,nj f 2 6 pu t b., concentration is prohibited because an even concentration distribution throughout the RCS cannot he ensured. Core p,#ot C, d outlet temperature is to be maintained at' 4g e least a p,s 10*F belowthe
.yT
. and possibly cause a natural circulation flow obstruction.
In MODES 3, 4, and 5 RCPsorshutdowncooling(SDC)pumpforcedcirculationit is sometimes nec (e.g., to change operation from one SDC train to the other, to perform surveillance or startup testing, to perform the transition to and from SDC System cooling or to avoid operationbelowtheRCPminimum~netpositlvesuctionhead nJ limit). The time period is acceptable because natural I circulation is adequate for heat removal,-or- the reactor coolant temperature can be maintained subcooled M i;..,, s+rti'h;;;;,
-"
- r; - act M t, n..L .'. ; . ...; .w,4. gusf # Sco BMd @
An_ OPERABLE (foret sists of at least one R grpeunnb '
. sccorc flow Is heat transeorb and an SG t at ance with the Steam Generator Tube Survet lance Program. An RCP is OPERABLE if it is capable of being fEMGf,E OPERABLE in
'3h 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 OPERA 8tE but not in operation for redundant heat removal capability. Operation in other MODES is covered 6y: (continued) CEOG STS-B 3.4-22 Rev1,04/07/95 P
. _. _~ .
l 36.- Combustion Engineering Owners Group (CEOG) .109 has not received NRC apprcM. Thus, the deviations proposed by the CEOG were provided with a plant specific justification. Justification for Deviations 28 and 29 to Bases Section 3.4 were added to provide the plant-specific justification for the deviations to the ISTS Bases. Additionally, while resolving this
-issue, it was discovered that a deviation was made to the ISTS Bases in the Bases for lTS 3.4.6
-without a justification being identified. This issue was corrected; the proposed deviation is justifiert by JFD 6 to 13ases Section 3.4.
4 4 I
RCS Loops-MODE 4 B,3.4,.6 BASES LCO forced flow to' the SDC heat exchanger (contiaued) pumps are OPERABLE if they are capable (s). RCPs and SDC are able to provide flow if required. of being p9wered and APPLICABILkTY In MODE 4,'this LC0 applies because it is possible to remove core decay heat and to provide proper boron sixing with either the RCS loops and SGs or the SDC System. r j
' ^
"'*r' & ti,- .
Operation in other MODES is covered by: LCO 3.4.4, 'RCS Loops-MODES I and 2'; LCO 3.4.5, 'RCS Loops-MODE 3'; LCO 3.4.7, 'RCS Loops-MODE 5, Loops Filled"; LCO 3.4.8, 'RCS Loops-MODE 5, Loops Not Filled'; LCO 3.9.4, ' Shutdown Coo 11 SOC)andCoolant Circulation-Hi h(Water Level" (MODE 6); and ' LCO 3.9.5.* ' Shutdown Coolin SOC) and Coolant Circulation-L 1(14ter Level" (M00E 6). ACTIONS Ad e
- od e* 8K If only. one required RCS loopw3DCJeaub islPEPMLE and, io.p are in operatiog,. redundancy for heat removal is lost. Action must De initiated tamediately to restore a second loop ee i
gg 4*e4a to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of h two paths for decay heat removal.
. y ))
Ad #" lo w one required 500 If red @undancyforheatremovalislost. is OPE LE nd in operatt he ant must be Y placed in MODE 5 within the next 24 ours. Placing the plant in MODE 5 is a conservative a ton ith regard to decay heat removal. With only one DC OPERABLE, redundancy for decay heat removal s lost and, in the event of a loss of the remaining 50C it would be safer to initiate that loss from MODE 5 ($ 200'F) rather than MODE 4 1 ( 00'F to<300'F). The Completion Time of 24 hours is r asonab11 , based on operating experience, to reach MODE 5 gw.J wa s
~
(continued) CEOG STS B 3.4-27 Rev 1, 04/07/95
' DISCUSSION OF BASES DEVIATIONS FROM NUREG-1432 SECTION 3.4 - REACTOR COOLANT SYSTEM 23.
Calvert Cliffs is not committed to the General Design Criteria in 10 CFR Part 50, Appendix At i Calvert Cliffs is committed to the draft General Design Criteria. Therefore, the Criteria in the draft General Design Criteria, where applicable, were referenced in the Technical Specification Bases. 24. Bases statements which refer to the CFR or the Standard Review Plan as the source of offsite dose or other accident analysh 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 Nuclear Regulatory Commission and stated in the Updated Final Safety Analysis Report. De CFR contains the maximum allowable limits, not plant-specific limits s which are typically more conservative. Calvert Clifts is not committed to the Standard Review Plan and, therefore, the current licensing basis may not be the Standard Review Plan values. 25. NUREG 1432 B 3.4.12 SR 3.4.12.1 Section allows an alternate method of LTOP control to be employed using at least two independent means to prevent in.lection into the RCS such that a i single failure or single action will not result in an injection into the RCS it allows this to be accomplished through the pump control switch being placed in pull to lock and at least one valve in the discharge flow path being closed. Improved Technical Specification SR 3.4.12.1 Bases will allow verification that the IIPSI pumps will not inject into the RCS by verifying their discharge valves are locked shut. This change is consistent with the Calvert Cliffs design and current licensing basis. I
- 26. The Actions for NUREG-1432 LCO 3.4.1 were modified to reflect the Action requirements of CTS 3.1.5 for RCS cold leg ter..perature not being within limits. The Action for CTS 3.1.5 l requires the restoration of RCS coM leg temperature to within limits, or Thermal Power be i reduced to less than 5% of Rated Thennal Power (i.e., Mode 2). The Action for CTS 3.1.5 is the j
' same regardless of which parameter (i.e., pressurizer pressure, RCS flow rate, or RCS cold leg temperature) is out of limits, Thus, Action A of ITS 3.4.1 provides the requirements for restoration of the parameter, and Action B ofITS 3.4.1 provides the requirements for exiting the mode of applicability in the event the parameter cannot be restored to within limits within two hours.
- 27. The Bases for NUREG-1432 LCO 3,4.5 state, "An OPERABLE loop consists of at least one RCP providing forced flow for heat' transfer and . . . ." This statement is not consistent with the requirements of NUREG-1432 LCO 3.4.5. NUREG 1432 LCO 3.4.5 requires (twol RCS loops to be OPERABLE and one RCS loop to be in operation. The LCO only requires one loop to be providing forced circulation; the second loop only needs to bo capable of providing forced circulation. Improved Technical Specification LCO 3.4.5 requires two RCS loops to be Operable and one RCS loop to be in operation. This is consistent with CTS LCO 3.4.1.2. Thus, the Bases for ITS LCO 3.4.5 have been revised to state, "An OPERABLE RCS loop consists of at least one OPERABLE RCP and . . . ." In addition to this plant-specific justification, this deviation is being addressed as TSTF-177.
- 28. Condition A of NUREG-1432 LCO 3.4.6 applies when one required RCS loop is inoperable and two SDC trains are inoperable. The Bases for Action A.1 of NUREG-1432 LCO 3.4.6 state: "If only one required RCS loop or SDC train is OPERABLE and in operation, redundancy for heat
; removal is lost." The discussion in the NUREG-1432 Bases is inconsistent with the Condition.
Action A.1 of NUREG-1432 LCO 3.4.6 only applies when one RCS loop and two SDC trains are CALVERT CLIFFS-UNITS 1 & 2 3.4-3 Revision 5 4 1
i DISCUSSION OF OASES DEVIAT?.ONS FROM NUREG 1432 i SECTION 3.4 - REACTOR COOLANT SYSTEM l inoperable (i.e., only an RCS loop is operable). The NUREG 1432 Bases for Action A.I of LCO 3.4.6 state that the action is required to be met whenever an RCS loop is inoperable or an SDC train is inoperable. The NUREG 1432 Bases for Action A.1 of LCO 3.4.6 is incorrect. Thus, in the ITS, the Bases for Action A.I of LCO 3.4.6 has been revised to be consistent with Condition A ofITS LCO 3.4.6. The Bases for Action A.1 ofITS 3.4.6 state: "If only one required RCS loop is OPERABLE and in operation and no SDC loops are OPERABLE, redundancy for heat removal is lost."
- 29. Condition B of NUREG-1432 LCO 3.4.6 applies when one required SDC train is inoperable and two RCS loops are inoperable. The Bases for Action B.1 of NUREG 1432 LCO 3.4.6 state: "If only one required SDC train is Operable and in operation, reti undancy for heat removal is lost."
The NUREG 1432 Bases discussion is inconsistent with the applicable Condition. Action B.1 of NUREG 1432 LCO 3.4.6 only applies when one SDC train and two RCS loops are inoperable (i.e., only an SDC train is operable). The NUREG 1d32 Bases for Action B.1 of LCO 3.4.6 state j that the action is required to be met whenever ,ne required SDC loop is inoperable. The NUREG-1432 Bases for Action A.1 of LCO 3.4.6 is incorrect. Thus, in the ITS, the Bases for Action B.) of LCO 3.4.6 has been revised to be consistent with Condition B ofITS LCO 3.4.6. , The Bases for Action B.I ofITS 3.4.6 state: "If one required SDC loop is OPERABLE and in operation and no RCS loops are OPERABLE, redundancy for heat removal is lost." 1
- 30. The Bases for NUREG 1432 SR 3.4.13.1 states: "A note under the frequency column states that this SR is required to be performed during steady state operation." This discussion is not consistent with the Note contained in the frequency column fo- SR 3.4.13.1. The Note states:
"Only required to be performed during steady state operation." Thus, in the Bases for ITS SR 3.4.13.1, the discussion of the Note has been revised to be consistent with the Note contained in the frequ:ncy column for ITS SR 3.4.13.1.
t y i i d 1 5 CALVERT CLIFFS- UNITS 1 & 2 3.4-4 Revision 5
- 37. While tcsolving NRC questions regarding ITS 3.4.14, it was discovered that the markups of Action b of CTS LCO 3.4.6.1 for ITS 3.4.14 did not accurately reflect the changes made to convert to ITS 3.4.14. The CTS markups were revised to denote the changes, and DOC L.3 for ITS 3.4.14 and its associated NSilC were revised tojustify the changes,
sp.6b 3.4.14 _1,4 -4/4,4 REACTOR COOLANT SYSTE
-B/4,4,4 REACTOR COOLANT SYSTDLLC'."4:
3 A li i haceDetectionSysTems]. LINITING CONDITION FOR OPERATION lao - - 34'g4 h4tet The following Reactor Coolant System Leakage Detection Systems shall be OP BLE:- b /. ntainment Atmosphere Particulate Radioactivity Monitork t -
~' '
System, or L.I
- 4. W. TNI'ontainmentSump'LevelAlatzSystem,and l
ou
- f. A'Containmer.t Atmosphere Gaseous Radioactivity MonitorE; SM APPLICABILITY: MODES 1, 2, 3 and 4. T NM- - - [ {'p ACTION: LCo 3.o.4 ang.) g i k,W g '^ 4 a. With only two of th above requirco Leskave uctemon aysi; ems 7 OPERABLE, operatt may continue for up to 30 s provided grab
-(I" S y Lyh samples of the ntainment atmosphere are obt ned and analyzed -.
g, s g_ at least one er 24 hours when either the quired Gaseous or A. 3 Particulat adioactivity Monitoring Syst is inoperable: ' Nep. M % LP() othervi be in at least HOT STAND 8Y wi n the next 6 hours and j
%_C SHUTDOWN within the following 0 hours.j
~ '
, - %J With oniy one of the above required Leakage Detection Systems A .n 0PERABLE, operation may continue for up to da providedthatif
- x. m .t
.r~ ' %l 4 Grab samples of the containment atmospher zo O'd'% re obtained and L..3 l., analyzed at least once per our k.1d s) iE /
% The Reactor Coolant System L,4 fh / r inventory balance of.
, f 3- -
'.4.0.2.c is performed at least once g, g 7 /. Surveillance per 24 hours. Requirement (AK 'L4.r3 D
@l' 2 ; " 6therw[se be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.
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CALVERT CLIFFS - UNIT 1 3/4 4 17
-- x _ . - ~x. . . . --. Amendment No.188
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,.s - N-. C.0- ,,,,oq 3,4, g 4 1/' ' M REACTOR C0OLANT SYSTgiUS."
hoeDetectionSystem]s LIMITING cow ! TION FOR OPERATION LCO y,g $r4r0-t shall be The following Reactor Coolantg, Leakage
, Detection Systems LE: J 'T er
- b. onta sphere Particulate Radioactivity Monitoring Sys L.(
c4. neent Sump Level Alaru System, and , /. t inment Atmosphere Gaseous Radicactivity Monitoring $ M APPLICABILITY: MODES 1, 2, 3 and 4. - hoPr
^
-%l ACTION:
LC.O 3.09 4 ~1 a pP .cc.hte
. _- _y A@g a7WiWonly two of t e above requi d Leakage Detectio SyM
,AIPERABLE,oper g p*' g'P la*P n may conti for up to 30 day rovided grab samples of containnent sphere are obtal dandan4Wzed at least e per 24 hcur hen either the re tred Gase
' N'I b Da Particu e Radioactivi Monitoring Syst s inopera- : or / A'3
( iC. n.,p , g, s..ly f% otherpse be in at 1 (infdLD5NUTDOWNwi in the following t NOT STANDBY wit the next hours / d) hours. f
+
f v,, 'h ] %.[With only one of the above required Leakage etection Systems L,2
, ,< t.r.3 / OPERABLE,operationmaycontinueforupto da t.Lrovided that:
sot ( A.7 4(y.]
' s ,,,1'.(Grab samples of the containment atmospher
-Tar.alyzed at least once per e%tainedand j b.3 p urs --
k[l1 J
# he Reactor Coolant System ' inventory balance of-~
Survelliance Requirement '.".?.0.c is performed at least once per 24 hours. S pg 5.4.13 I A[A m (Otherwise be in at least NOT STANDBY within the next 6 hours and A. l 8 ng 3,0
- Q - Q in(Q COLD $NUTDOWN re vlceh coh p Q th @ N nr w k hnoh k\
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%u oe ma lc.cra, g - W~de,si~p [gg3 6 d' ag Y LVERT CLIFFS - UNIT 2 3/4 4 17 An,endment No.165 l
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DISCUSSION OF CHANGES
- SECTION 3A.14 - RCS LEAKAGE DETECTION INSTRUMENTATION increases the allowed outage time from 7 days to 30 days. This change is acceptable because one other leakage detection system remains available along with_ required contingency actions. These Actions include performing an RCS inventory belance or taking grab samples of the containment atmosphere once per 24 hours. These methods, along with other instrumentation (i.e., containment temperature, pressure, and humidity; and pressurizer and volume control tank level) ensure that RCS leakage is adequately detected. His change is consistent with NUREG-1432.
L.3 - In the event only one of the required RCS leakage detection % stems is operable, Action b of CTS 3.4.6.1 permits the plant to continue to operate provided grab samples of the containment atmosphere are obtained and analyzed periodically, and an RCS water inventory balance is performed in accordance with CTS SR 4.4.6.2.c at an increased frequency, in the event the Containment Sump Level Alann System is inoperable (i.e., only the Containment Atmosphere Radioactivity Monitoring System is operable), Action A ofITS 3.4.14 permits continued operation of the plant provided an RCS water inventory balance is performed in accordance with ITS SR 3.4.13.1 at an increased frequency, in the event the Containment Atmosphere Radioactivity Monitoring System is inoperable (i.e., only the Containment Sump Level Alarm System is operable), Action B ofITS 3.4.14 permits continued operation of the plant provided a grab sample of the containment atmosphere is performed periodically, or an RCS water inventory balance is performed at an increased frequency. Action b of CTS 3.4.6.1 has been revised to reflect Actions A and B ofITS 3.4.14. Action b of CTS 3.4.6.1 has been revised to require: a) only one contingency action to be performed (either periodic grab samples or RCS inventory balance) when the Containment Atmosphere Radioactivity Monitoring System is inoperable; and b) only an RCS inventory balance to be conducted at an increased frequency in the event the Containment Sump Level Alarm System is inope.able. These proposed changes are acceptablt because: a) one of the RCS leakage detection systems remains Operable; b) other instrumentation not required to be operable by the specification will be available to detect F,CS leakage (e.g., volume control tank icvel, pressurizer level, containment pressure, contaimnent temperature, containment humidity); and c) the required compensatory measure provides added confidence that RCS leakage will be identified in a timely manner. In addition to thejustification provided above, the proposed change is consistent with NUREG 1432. L.4 Current Technical Specification 3.4.6.1 Action b requires grab samples of the containment atmosphere to be analyzed once per 12 hours when used as contingency actions when only one RCS leakage detection system remains Operable, improved Technical Specification 3.4.14 decreases the Frequency for the performance of this action to once every 24 hours. This change is acceptable because the 24-hour interval provides results that are adequate to detect leakage. Also, the 24-hour interval is adequate because one remaining RCS leakage detection instrument remains Operable along with other methods (i.e., containment temperature, pressure, and humidity; and pressurizer and volume control tank level) to adequately detect RCS leakage. This change is consistent with NUREG-1432. L.5 Improved Technical Specification 3.4.14 adds an LCO 3.0.4 exemption to CTS 3.4.6.1 which allows the changing of Modes within the Modes of Applicability while RCS leakage
- detection instrumentation is inoperable. This change is acceptable because Mode changes do not affect the ability to detect RCS leakage, and other methods remain available to detect
- RCS leakage. Adding a requirement that allows Mode changes when previous Mode CALVERT CLIFFS - UNITS 1 & 2 3.4.14-3 Revision 5
NO SIGNIFICANT HAZARDS CONSIDERATIONt SECTION 3.4 - REACTOR COOLANT SYSTEM significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. He proposed change will not introduce any new accident initiators. Herefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
' He proposed change increases the allowed outage time from seven days to 30 days when only one RCS leakage detection instrument remains Operable, ne remaining Operable RCS leakage detection instrument, the leak detection mechanisms required by the Actions, and other methods for detecting RCS leakage, will ensure that the RCS leakage will continue to be detected. 3 Therefore, the change does not involve a significant reduction in a margin of safety. m,;-
\
, 3.4.14 Chance L3
- 1. Does the change involve a significant increase in the probability or consequences of an ,
accident previously evaluated? ! Action b of CTS 3.4.6.1 has been revised to reflect Actions A and B ofITS 3.4.14.- Action b of CTS 3.4.6.1 has been revised to require: a) only one contingency action to be performed (either periodic grab samples or RCS inventory balance) when the Containment Atmosphere Radioactivity Monitoring System is inoperable; and b) only an RCS inventory balance to be conducted at an increased frequency in the event the Containment Sump Level Alarm System is inoperable. These proposed changes are acceptable, because: a) one of the RCS Inkage detection systems remains Operable; b) other instrumentation not required to be operable by the specification will be available to detect RCS leakage (e.g., volume control tank level, pressurizer level, containment pressure, containment temperature, containment humidity); and c) the . required compensatory measure provides added confidence that RCS leakage will be identified in a timely manner. Failure of RCS leakage detection instrumentation is not an initiator of cny analyzed events. The change will not alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly afTect initiators or mitigation of analyzed
, events, and therefore do not involve a significant increase in the probability or consequences of l an accident previously evaluated.
4
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
He proposed change requires either analyzing grab samples or performing RCS inventory , balances as contingency actions, when only one RCS leakage detection instrument remains Opernble, instead of performing both actions. The change will not involve a significant change in design or operation. No hardware is being added to the plant as part of the proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The proposed change requires the performance of either analyzing grab samples or perfonning RCS inventory balances as contingency actions, when only one RCS leakage detection instrument remains Operable, instead of performing both actions. One contingency action, along with the one remaining Operable RCS leakage detection instrument and other methods available CALVERT CLIFFS - UNITS 1 & 2 3-4-27 Revision 5
NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM for detecting RCS leakage, ensures that the RCS leakage will continue to be detected. Therefore, ! the change does not involve a significant reduction in a margin of safety. 3.4.14 Change L4
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change decreases the Frequency from 12 hours to 24 hours for obtaining and analyzing containment atmosphere grab samples when used as the contingency action when only , one RCS leakage detection instrument remains Operable The Frequency for obtaining and analyzing grab samples is not an initiator of any analyzed event. He 24-hour Frequency provides results frequently enough to detect leakage. Also, one RCS leakage detecti.on instrumentation is operable and other methods ofleak detection are available (i.e., monito' ring " ' changes in volume control tank level and pressurizer level; monitoring containment pressure, temperature and humidity; etc.) to ensure detection of RCS leaks. The change will not alter assumptions relative to the mitigation of an accident or transient. He required system will be capable of quantifying the RCS leakage following an accident so that mitigative action can be taken. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
The proposed change decreases the Frequency from 12 hours to 24 hours for obtaining and analyzing containment atmosphere grab samples, when used as the contingency action, when only one RCS leakage detection instrument remains Operable. The change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of 6 e proposed change. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The proposed change decreases the Frequency from 12 hours to 24 hours for obtaining and analyzing containment atmosphere grab samples, when used as the contingency action, when only one RCS leakage detection instrument remains Operable. The 24-hour Frequency is adequate to detect RCS leakage, Also, one remaining RCS leakage detection instrument remains Operable along with other methods available for detecting RCS leakage. Therefore, the change does not involve a significant reduction in a margin of safety. 3.4.14 Change L.5
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
He proposed change adds a requirement that allows Mode changes (LCO 3.0.4 exemption) while in the Actions for RCS leakage detection instruments inoperable. Failure of RCS leakage detection is not an initiator of any analyzed events. While Mode changes may affect RCS leakage, they do not affect the ability to detect RCS leakage. When leakage detection CALVERT CLIFFS - UNITS 1 & 2 3-4-28 Revision 5
- 38. The deviation proposed by TSTF 3 was removed from ISTS Bases markup for ITS 3.4.15. This generic change was rejected by the NRC.
l
RCS Specific Activity B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.15 RCS Specific Activity BASES BACKGROUND The Code of Federal Regulations,10 CFR Part 100 specifies ' the maximum dose to the whole body and the thyroid an e indivictual at the site boundary can receive for 2 hours-during an accident. The limits on specific activity ensure that the doses are held to within the acceptance criteria given in the UFSAR (Ref.1) during analyzed transients and I accidents. The RCS specific activity LCO limits the allowable concentration level of radionuclides in the reactor coolant. , The LC0 liaits are established to minimize the offsite , radioactivity dose consequences in the event of a steam l generator tube rupture (SGTR) accident. The LC0 contains specific activity limits for both DOSE EQUIVALENT I-131 and gross specific activity. The allowable 6 levels are intended to limit the dose at the site boundary to within the acceptance criteria given in the VFSAR g (Ref. 1). APPLICABLE The LC0 limits on the specific activity of the reactor SAFETY ANALYSIS coolant ensure that the resulting doses at the site boundary will not exceed the acceptance criteria given in the UFSAR I (Ref. 1). The SGTR safety analysis (Ref. 2) assumes the specific activity of the reactor coolant at the LC0 limits and an existing reactor coolant steam generator (SG) tube leakage rate of 1 gpm. The rise in pressure in the ruptured SG causes radioactively contaminated steam to discharge to the atmosphere through the atmospheric dump valves and the main steam safety valves. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-1 Revisiondi
e.. .m . - .. _, . . . _ _ . ~ . _ . . - _ . _ - ~ . _. _ _ _ _ _ _ . _ . _ _ _ _ . _ _ . . _
]
r i [- RCS Specific yy g p B 3.4 TOR COOLANT SYSTEM (RCS), s B 3.4 RCSSpecificActivity1 i [ i
;8ASES r
kwana"n The Code of Feoeral lations le CFR 100 dIEr4h {}
. . .,Ag;a g specifies the maximum setot$ewholebodyandtliethyreld g lg *
- i .. pe s/Ll, an individual at the site boundary can receive for I hours 1 during an accident. The limits en specific activity ensure '
i: *Ata la n k u R Nt. Wt the do_ses are held to- -u rramien er ue) i Uter, gp :) 6rnaw r .uwsuring analyzed transtants enraccidents. g ! :: The RCS specific activity LC0 limits the allowable > ! concentration level of radionuclides in the reacter toelant, The LCO limits are established to stataire the offsite U radioactivity dose consequences in the event of a steam i. l generator tube rupture (SGTR) accident, [
- - The LC0 contains specific activity 11atts for both 00$E i EQU1 VALENT I-131 and gross specifftactivity. - The allowable
{ levels are intended to Itait theSamhdose at the si te boa-'--w tm misaall.rrac ion ei
^i, i;is w cose A ased on p line I ts. The imits in the LC0 standardized
(.d C . N ,** 4f**** tric ev untions of offst raltoactiv?t 21 se consa nces for typical: site loca ons v a na gew.,is n N urpe.(0.t.6 Ihe .
- rasetric ev uations showes t potential off ite dose .
[ leve s for an SGT accident were a appropriately 11 fra ion of the 0 CFR 100 dose g deline limits. fach eva cation ass j I a s a broad range f site appitcab e 1: eric dit rsion factors i a marametric a lustian /- 5-
' APPLICABLE
~
i ~, SAFETY ANALYSES The LCO limits on the specific actt it of the reactor m--7
- coolant ensure that the resulting doses at the site boundary wi' 1 not =~a-d '. {
a:
- - NmtMt s - -ii a sien ei we Ju un 100 se li6its fAlowing an ETR accidentA f "'M s* W N Uravttpd. th se e y analysis The SGTR
- the reactor coola(nt at the LC0 lietts and an existingRef. 2) assumes I th reactor coolant steam generator (SG) tube leakage rate of I gpa. ~ Th =:h^$ it: "~~: 2 r'_r ^ '.
t-i". .. ;7 _. _i_ : ; " r r ti. u n ... ^. ...~ . .
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i- I_I Iw WD b U .. TU s e 6t 'r: " . ';; ,_ _ ; ; W 5. 4.T. .. . . . ; ., . -." '-- - - to 1: 4 (continued) . a t CE0G STS 4~ B 3.4-88 Rev 1, 04/07/95 1 n 1 4 . . . -- . . - _ , ..._.-
.._L-_ . _ . .-. , ,__.i. . . - - - . _ , . . - , , . - .
- 39. Improved Technical Specification 3.4.12, " Low Temperature Overpressure Protection (LTOP) - System," and associated Bases have been revised to be consistent with the Calvert Cliffs LTOP analysis reflected in CTS 3/4,9.3, As a result of this change and subsequent review of supporting information, the' following changes were also made: 1) DOCS A.2, A.3, A.4, LA.1, LA.2, and L.2_(and _ associated NSHC) for ITS 3.4.12 were revised; 2) DOCS A.5, M.1, and L.1 (and associated. NSilC) for ITS 3.4.12 are deleted, because they' are 2 0 longer used; 3) new DOCS A 8, M 2, and L.5 (and associated NSilC) were provided for ITS 3.4.12; 4) JFD 14 for l Section 3,4 was revised; 5) JFD 20 for Section 3.4 was deleted; 6) JFD 24 for Section 3,4 was l deleted; and 7) JFD 39 for Section 3.4 was added. A typographical / grammatical error in JFD for .! ITS Bases Section 3.4 was corrected. These changes were made in the response to NRC Comments (ITS 3.4.12 Comments 1,2,3,4,5,6,8,9,10,11,12, and 13). < 1
LTOP System 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP) System LCO 3.4.12 An LTOP System shall be OPERABLE with:
- a. 1. A maximum of one high pressure safety injection (HPSI)pumpcapableof.injectingintotheRCS,and:
- 2. When HPSI suctiongs_ aligned _to the Refueling Water Tank (RWT), the HPSI pump shall be in manual control and either:
I a) HPSI flow limited to s 210 gpm, or l b) An RCS vent of 2 2.6 square inches established; blQ
-b. - HPSI loop motor operated valves (MOVs) only capable of manually aligning HPSI pump flow to the RCS; g
-------------------------NOTE.--------------.----------
HPSI loop MOVs may be capable of automaticully aligning HPSI pump flow to-the RCS for the purposes of testing. AND
- c. 1. Two OPERABLE power operated relief valves (PORVs),
and associated block valves open, with PORY lift-settings on or-below the curve _in Figure 3.4.12-1 whentheShutdownCooling(SDC)Systemisnotin operaticn and PORV lift settings s 492 psia (Unit 1), s 443 psia (Unit 2), when the SDC is in operation, or
- 2. One OPEPABLE PORV, and associated. block valve open, with PORV lift setting on or below the curve in Figure 3.4.12-1 when the SDC System is not in CALVERT CLIFFS - UNITS 1 & 2 3.4.12-1 Revisicaff$
l-
- LTOP System 3.4.12 operation and PORY lift setting s 429 psia (Unit 1). s 443 psia (Unit 2), when the SDC is in
-operation; and an RCS vent of 2 1.3 square inches 5' established; or
- 3. An RCS vent of a 2.6 square inches established.
APPLICABILITY: MODE 3 with any RCS cold leg temperature s 365'f (unit 1), 5' s301*),(U. nit _2).. < MODES 4, 5, and 6.
............................N0TE..-------.--------.---.-....
This Specification is not applicable O:n the RCS is vented to 2 8 square inches. ALTIONS l
....................................-N0TE--.--.....-.-..-..-...-......-...-...
While the requirements of this LCO are not met, entry into a MODE or other specified condition in the Applicability is not permitted.
' CONDITION REQUIRED ACTION COMPLETION TIME A. One or more HPSI A.1 Initiate action to Intnediately pumps capable of verify a maximum of automatically one HPSI pump only injecting into the ,,
capable of manually RCS. injecting into the RCS and no HPSI pumps 6 98 capabla of - automatically Two or more HPSI injecting into the pumps capable of RCS. manually injecting into the RCS.
-CALVERT CLIFFS . UNITS 1 & 2 3.4.12-2 Revision g 5
LTOP System 3.4.12 ACTIONS (continued) CONDITION = REQUIRE 0 ACTION- _ COMPLETIbkTIME B. HPSI flow > 210 gpm B.1- Initiate action to Immediately and suction aligned reduce flow to to RWT. s 210 gpm. 8.!iQ RCS vent < 2.6 square inches established.
-C. One or more HPSI loop C.1 Initiate action to Immediately MOVs capable of verify HPSI loop MOVs automatically- are only capable of aligning HPSI pump S-manually aligning flow to the RCS, HPSI pump flow to the RCS.
D. One of two required D.1 Restora required PORV- 5 days PORVs inoperable in to OPERABLE status.
-MODE 3 with any RCS 5
cold leg temperature s 365'F (Unit 1), s 301*F (Unit 2), or NDE 4,
- 8. lie RCS vent < 1.3 square 6 inches established.
CALVERT CLIFFS - UNITS 1 & 2 3.4.12-3 Revisionp'y
. . _ _ . _ . . . _. _ _ _ _ . _ . . . - . _ _ _ . _ _ _ _ _ _ - . _ _ _ _ _ _ . ~ . - _ . - _ . .__
LTOP System 3.4.12 ~ ACTIONS (continued) CONDITION REQUIREDACTION COMPLETION TIME E.- One of two required E.1 Restore required PORV 24 hours 3r PORVs inoperable in to OPERABLE status. MODE 5 or 6. AND RCS vent < 1.3 square , SI inches established. F. Requirea Action and F.1 Depressurize RCS and 48 hours j e associated Completion establish RCS vent - Time of Condition D 2 1.3 square inches, or E not met. F G. All required PORVs G.1 Depressurize RCS and 48 hours 5' inoperable, establish RCS vent of 2 2.6 square inches. . , S' SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify a maximum of one HPSI pump is only
- 12 hours capable of manually injecting into the RCS. 3r SR 3.4.12.2 Verify HPSI loop MOVs are only capable of 12 hours 5-manually aligning HPSI pump flow to the RCS.
i j
-CALVERT CLIFFS - UNITS 1 & 2 3.4.12-4 RevisionSf3r i
LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE
.tREQUENCY SR 3.4.12.3 Verify required RCS vent is open. i 12 hours for unlocked open ventvalve(s) 5 31 days for locked open ventvalve(s)
SR 3.4.12.4 Verify PORY block valve is open for each 72 hours required PORV. SR 3.4.12.5 ----------.-.----.-NOTE----------------.-. 5 , Not required to be performed until 12 hours j after decreasing any RCS cold leg g temperature to s 365'F (Unit 1), s 301*F (Unit 2). Perform CHANNEL FUNCTIONAL TEST on each 31 days required PORV, excluding actuation. SR 3.4.12.6 Perform CHANNEL CALIBRATION on each required 24 months f PORV actuation channel. 1 l I I i CALVERT CLIFFS - UNITS 1 & 2 3.4.12-5 l Revision 75
. _ _ _ _ _ . _ . _ - . - .~ - _ _ . _ _ _ _ _ _ __ _ _ _ _ _ , LTOP System B 3.4.12 4
i B 3.4 REACTORCOOLANTSYS1EM(RCS) B 3.4.12 LowTemperatureOverpressureProtection(LTOP) System , BASES BACKGROUND The LTOP System controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary
- p .- .-
(RCPB) is not compromised by violating the pressure and temperature (P/T)limitsof10CFRPart50,AppendixG (Ref.1). The reactor-vessel is the limiting RCPB component for demonstrating such protection. LCO 3.4.3, "RCS Pressure andTemperature(P/T) Limits,"providestheallowable ; combinations for operational pressure and temperature during cooldown, shutdown, and heatup to keep from violating the Reference 1 requirements during the LTOP MODES. The reactor vessel material is less tough at low temperatures than at normal operating temperatures. As the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at E low temperatures (Ref. 2). Reactor Coolant System pressure.
- therefore, is maintained low at low temperatures and is increased only as temperature is increased.
The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only while shutdown; a pressure flectuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle , cracking of the reactor vessel. LCO 3.4.3-requires administrative control of RCS pressure and temperature duringheatupandcooldowntopreventexceedingtheP/T limits, This LC0 provides RCS overpressure protection by having a minimum coolant input capability and having adequate
-pressure relief capacity. Limiting coolant input capability requires all but one high pressure safety injection (HPSI) pump incapable of injection into the RCS and this HPSI pump 5 1
j CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-1 Revision #5'
LTOP System B 3.4.12 BASES will only be capable of manually injecting into the RCS. When suction of this HPSI pump is aligned to the Refueling Water Storage Tank (RWT), the HPSI pump will be throttled unless an adequate vent path exists. The HPSI motor g operator valves must be in pull-to-override so that valves do not automatically actuate. In addition, administrative controls are placed on charging pump operation. The pressure relief capacity requires either two OPERABLE redundantpoweroperatedreliefvalves(PORVs),onePORVand an RCS vent of 1.3 square inches, or the RCS depressurized g and an RCS vent of 2.6 square inches. One PORV or the 1.3 square inch RCS vent is the overpressure protection device that acts to terminate an increasing pressure event. The extra PORV or extra 1.3 square inch vent is for single failure criteria. With minimum coolant input capability, the ability to provide core coolant addition is restricted. The safety { injection (SI) actuation circuits are blocked to HPSI. If , conditions require the use of more than one HPSI for makeup in the event of loss of inventory, then pumps can be made availab'le through manual actions. The LTOP System for pressure relief consists of two PORVs with reduced lift settings, one PORV with reduced lift setting and an RCS vent of 1.3 square inches, or an RCS vent g of 2.6 square inches. Two relief valves are required for redundancy. One PORV has adequate relieving capability to prevent overpressurization for the required coolant input capability. PORV Reauirements As designed for the LTOP System, each PORV is signaled to open if the RCS pressure approaches a limit determined by the LTOP actuation logic. The actuation logic monitors RCS temperature and pressure and determines when the LTOP overpressure setting is approached. If the indicated CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-2 Revision 0 5
LTOP System B 3.4.12
-BASES
_ pressure meets or exceeds the calculated value, a PORV is signaled to open. The LCO presents the PORV setpoints for LTOP. Having the setpoints of both valves within the limits of the LCO ensures the P/T limits will not be exceeded in any analyzed event. we When a PORV is opened in an increasing pressure transient, the release of coolant causes the pressure increase to slow and reverse. As the PORV releases coolant, the system pressure decreases until a reset pressure is reached. At this point the event is terminated and the operator manually closes the PORV. RCS Vent Recuirements Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient,-if the relieving requirements of the transient do not exceed the capabilities of the vent. Thus, the vent path must be I capable of relieving the flow resulting from the limiting LTOP mass or heat input transient and maintaining pressure belowtheP/Tlimits.-Therequiredventcapacitymay:be provided by one or more vent paths. If.the vent path is :t 8 square inches (e.g., removing the pressurizer manway) the RCS can not be pressurized above the P/T limits, and the LTOP System is not required. 6 APPLICABLE Safety analyses (Ref. 3) demonstrate that the reactor vessel SAFETY ANALYSES is adequately protected against exceeding the Reference 1 P/T limits during shutdown. In MODES 1 and 2, and MODE 3 with all RCS cold leg temperatures > 365'F (Unit 1), > 301'F s- ' (Unit 2), the RCPB is sufficiently above the nil-ductility temperature that the pressurizer safety valves prevent CALVERT CLIFFS - U!!ITS 1 & 2 B 3.4.12-3 Revi sion- fr5'
LTOP System B 3.4.12 BASES brittle fracture. At-365'F (Unit 1), 301*F (Unit 2) and lI below, overpressure prevention falls to the OPERABLE PORVs and administrative controls or to a depressurized RCS and a 5 sufficient sized RCS vent. Each of these means has a limited overpressure relief capability. Each time the P/T limit curves are revise <J, the LTOP System e- - will be re-evaluated to ensure its functional requirements can still be satisfied using the PORY method or the depressurized and vented RCS condition. Reference 3 contains the acceptance limits that satisfy the LTOP requirements. Any change to the RCS must be evaluated against these analyses to determine the impact of the change on the LTOP acceptance limits. Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients, examples-of which follow: Mass Inout Tvoe Transients
- a. Inadvertent high pressure safety injection pump start;
- b. Inadvertent HPSI and charging pump start; or
- c. Charging / letdown flow mismatch.
Heat Inout Tvoe Transients
- a. Inadvertent actuation of pressurizer heaters;
- b. Loss of shutdown cooling (SDC); or
- c. Reactor coolant pump (RCP) startup with temperature asymmetry within-the RCS or between the RCS and steam
-generators.
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-4 Revisiong5
LTOP System B 3.4.12 BASES The following are requi*ed during the LTOP MODES to ensure that mass and heat input transients do not occur, which either of the LTOP overpressure protection means cannot handle:
- a. Rendering all but one HPSI pump incapable of injection and blocking automatic initiation from the remaining HPSI. pump;
- b. When HPSI suction is aligned to the RWT, the HPSI pump shall be in manual control and either:
- 1) HPSI flow is limited to s 210 gpm, or-
- 2) an RCS vent > 2.6 square inches is established;
- c. Reading HPSI motor operator valves (MOVs) only capable l of manually aligning HPSI pump flow to the RCS;
- d. Running only one charging pump when injecting via HPSI
' (chargingpumprequirementsarecontrolled f administrativcly);and
- e. Maintaining a pressure bubble with level s 170 inches, y The Reference 3 analyses demonstrate that either one PORV or the RCS vent and pressurizer steam volume can maintain RCS f pressure below limits when only one HPSI pump is actuated provided two of the three HPSI pumps are disabled and the remaining HPSI pump's flow is throttled. If HPSI pump flow is not throttled during addition of mass to the RCS through on HPSI loop MOV, then two PORVs or an RCS vent 2 2.6 y square inches are capable of maintaining RCS pressure below limits. Thus, the LCO allows only one HPSI pump OPERABLE with flow throttled, or with an RCS vent 2 2.6 square inches during the LTOP MODES.
Also to limit pressure overshoot over the PORV setpoint, the remaining HPSI and two charging pumps are rendered incapable CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-5 Revision g g
~
LTOP System B 3.4.12 BASES of injection, and the RCPs are disabled during water solid operation. Heatup and cooldown analyses established the temperature of LTOP Applicability at 365'F (Unit 1), and 301'F (Unit 2) and below based on SRP criteria. Above this temperature, the RCPB is sufficiently above the nil-ductility temperature and
'~'-
the pressurizer safety valves provide the reactor vessel ~ chi pressure protection against brittle fracture. The vessel matericls were assumed to have a fluence level equal to 2.61 x 10" n/cm* (Unit 1), 4.0 x 10" n/cm (Unit 2). The consequences of a loss of coolant accident (LOCA) in LTOP conform to 10 CFR 50.46 and 10 CFR Part 50, Appendix K (Refs.4and5),requirementsbyhavingSITsoperablein MODE 3 and one HPSI pump available for manual actuation. l PORV Perfonnance The fracture mechanics analyses'show that the vessel is protected when the PORVs are set to open at or below the , curves in Figure 3.4.12-1 and are applicable when the I g Shutdown Couling (SDC) System is not in operation. The setpoint is derived by modeling the performance of the LTOP System, assuming the limiting case of loss of SDC and one charging pump injecting into the RCS during water solid operation. These analyses consider pressure overshoot beyond the PORV opening setpoints, resulting from signal processing and valve stroke times. The PORV setpoints below the derived limit ensure the Reference 1 limits will be met. ' When the SDC System is in operation, the PORV lift setting must be s 429 psia (Unit 1), s 443 psia (Unit 2). This ensures that the PORV lift setting is low enough to mitigate s' overpressure transients when SDC is in-operation, since RCS temperature measurement is not cccurate in this condition. ThePORVsetpointswillbere-evaluatedforcompliancewhen the revised P/T limits conflict with the LTOP analysis CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-6 Revision g r
LTOP System B 3.4.12 -BASES limits. The P/T limits are periodically modified as the reactor vessel material toughness decreases due to embrittlement caused by neutron irradiation. RevisedP/T limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. However, the Calvert Cliffs' P/T limita are not projected to change through the end of Calvert Cliffs current operating license. The Bases for LC0 3.4.3, "RCS Pressure and Temperature (P/T) Limits," discuss these examinations. The PORVs are considered active components. Thus, the failure of one PORV represents the worst case, single active failure. RCS Vent Performance With the RCS depressurized, analyses show a vent size of 1.3 square inches is capable of mitigating the limiting allowed LTOP overpressure transient provided a pressurizer steam volume exists, two of the three HPSI pumps are g disabled and the remaining HPSI pump's flow is throttled. In that event, this size vent maintains RCS pressure less than the maximum RCS pressure on the P/T limit curve. A 2.6 square inch vent is required to allow for single failures of other equipment, such as HPSI throttle valves. An 8 square inch vent is sufficient to preclude RCS overpressure events. Therefore, when an 8 square inch vent g is established LT0e System requirements are not necessary to maintain RCS pressure within litits. The RCS vent size will also be re-evaluated for compliance each time the P/T limit curves are revised based on the results of the vessel material surveillance. The RCS vent is pastive and is not subject to active failure. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-7 Revision #5
9 LTOP System B 3.4.12 B/.SCS LTOP System sitisfies 10 CfR 50.36(c)(2)(ti) Criterion 2. LCO This LCO is required to ensure that the LTOP System is OPERABLE. The LTOP System is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient. To limit the conlant input capability, the LCO requires a maximumofo.<tiPSIpumponlycapableofmanuallyinjecting into the Rv , This is accomplished by disabling two.HPSI pumps by eitner removing (racking out) their motor circuit breakers from the electrical power supply circuit or by locking shut their discharge valves. During required testing, other means of preventing two HPSI pumps from injecting into the RCS may be used. In addition, when not in use the remaining HPSI pump shall have its handsnitch in ' pull-to-lock. When HPSI suction is aligned to the RWT for 5 injection into the RCS, the HPSI pump must be in manual control and either HPSI flow shall be limited to s 210 gpm or an RCS vent of 2 2.6 square inches is established. To provide single failure protection against a HPSI pump mass addition transient, the HPSI loop H0V handswitches must be placed in pull-to. override so the valves do not automatically actuate upon receipt of a safety injection signal. During required testing this requirement may be suspended. The elements of the LCO that provide overpressure mitigation thre;M pressure relief are:
- a. Twc OPERABLE PORVs and associated block valves opent
- b. One OPERABLE PORV and associated block valve open and an RCS vent open with an area 2 1.3 square inches; or T CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-8 Revisionp'S'
I 4 LTOP System B 3.4.12 l t BASES s ;
- c. The depressurized RCS and an RCS vent open with an area
){ 2 2.6 square inches. f 4 i ! ' A PORY is OPERABLE for LTOP when its block valve is open. ! its lift setpoint is set in accordance with the LCO and ! testing has proven its ability to open at that setpoint, and motive power is available to the two valves and their
- control circuits. "
i The combination of these methods of overpressure prevention I (as specified in LCO 3.4.12) are capable of mitigating the limiting LTOP transient. l5 i APPLICABILITY This LCO is applicable in MODE 3 when the temperature of any g RCS cold leg is s 365'T (Unit 1), s 301'F (Unit 2), in i MODES 4, 5, and 6. LCO 3.4.3 provides the operational P/T limits for all MODES. LCO 3.4.10. " Pressurizer Safety Valves," requires the OPERABILITY of the pressurizer safety valves that provide overpressure protection during MODES I and 2, and MODE 3 ] above 365'F (Unit 1), 301'F (Unit 2). Low temperature overpressure prevention is most critical 4 during shutdown when the RCS is water solid, and a mass or
- heat input transient can cause a very rapid increase in RCS t pressure when little or no time allows operator action to ;
mitigate the event. i The Applicability is modified by a Nato stating that this
'pecification is not applicable when the RCS is vented 2 8 square inches. An RCS vent of this size precludes RCS overpressure events.
ACTIONS A Note to the ACTIONS restricts entry into MODES or other specified conditions in the Applicability of this LCO while 6 4 d . CALVERT CLIFFS-- UNITS 1 & 2 B 3.4.12-9 Revisiongy
L10P System B 3.4.12 BASES complying with the ACTIONS (i.e., while the LCO is not met). LCO 3.0.4 typically allows entry into MODES or other specified conditions in the Applicability as part of any y unit shutdown, however, the restriction of this Note is necessary to assure low temperature overpressure protection is available prior to operating within the Applicability of this LCO. U With one or more HPSI pumps capable of automatically injecting into the_RCS or with two or more HPSI pumps g capable of manually injecting into the RCS, overpressurization is possible. The imediate Completion Time to initiate actions to restore restricted coolant input capability to the RCS reflects the importance of maintaining overpressure protection of the RCS. M With HPSI flow > 210 gpm and suction aligned to the RWT and an RCS vent < 2.6 square inches established, sufficient overpressure protection may not exist and overpressurization may be possible. The inanediate Completion Time to initiate actions to reduce HPSI flow to 5 210 gpm reflects the importance of maintaining overpressure protection of the RCS. f M With one or more HPSI loop MOVs capable to automatically aligning HPSI pump flow to the RCS, single failure protection against a HPSI pump mass addition transient is CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-10 RevisionJff
LTOP System B 3.4.12 BASES lost. Therefore, action is required to be immediately initiated to restore single failure protection by placing the affected HPSI loop MOV handswitch to pull-to-override, or shutting and disabling the affected HPSI loop MOV, or isolating the affected HPSI header flow path, f The immediate Completion Time to initiate action to restore single failure protection for the HPSI pump mass addition transient reflects the importance of restoring single failure protection for low temperature overpressurization mitigation. 0.1 5 In MODE 3 when any RCS cold leg temperature is s 365'F (Unit 1), s 301*F (Unit 2) or in MODE 4, with one of the two g required PORVs inoperable and an RCS vent 41.3 srluare inches established, the inoperable PORV must be restored to OPERABLE status within a Completion Time of 5 days. The inoperable PORY is required to meet the LCO requirement and to provide low temperature overpressure mitigation while withstanding a single failure of an active component. The Completion Time is based on the fact that only one PORV is required to mitigate an overpressure transient. f.d lY The consequences of operational events that will overpressure the RCS are more severe at lower temperature (Ref.6). Thus, with one of the two required PORVs inoperable and an RCS vent < 1.3 square inches established I in MODE 5 or in MODE 6, the Completion Time to restore two valves to OPERABLE status is 24 hours. The 24 hour Completion Time to restore the inoperable PORY to OPERABLE status in MODE 5 or in MODE 6 is a reasonable CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-11 Revision #f
i LTOP System B 3.4.12 i BASES amount of time to investigate and repair several types of PORV failures without exposure to a lengthy period with only one PORV OPERABLE to protect against overpressure events, f_d l6 If the required Actions and associated Completion Times of- ' ~ Condition D or E cannot be met the RCS is required to be f
- depressurized and vented through a vent h 1.3 square inches. This action must be completed within 48 hours. y This action along with the OPERABLE PORY restores single i failure protection and ensures the flow capacity is greater '
than that required for the worst case mass input transient reasonable during the applicable MODES. This action protects the RCPB from an overpressure event and a possible brittle failure of the reactor vessel. The Completion Time of 48 hours to depressurize and vent the. RCS is based on the time required to place the plant in this condition and in a controlled manner. The probability of an overpressure event occurring along with a single failure of the remaining OPERABLE PORV is unlikely. [LJ 5 If all required PORVs (i.e., when one PORV is required and it is inoperable or when two PORVs are required and both are f inoperable) are inoperable, the RCS must be depressurized and a vent established within 48 hours. The vent must be sized at_least 2.6 square inches to ensure the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES.- This action protects the RCPB from a low temperature overpressure. event and a possible brittle failure of the reactor vessel. The Completion Time of 48 hours to depressurize and vent the RCS is based on the time required to place the plant in this CALVERT CLIFFS UNITS 1-& 2 B 3.4.12-12 Revisionfy
76sh2iFAh88h%V* k LTOP System 'X ! B 3.4.12 p_ - BASES condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements. SURVEILLANCE SR 3.4.12.1 and SR 3.4.12.2 g REQUIREMENTS To minimize the potential for a low temperature overpressure event by limiting the mass input capability, verification that a maximum of one HPSI pump is only capable of manually injecting into the RCS and automatic alignment of the HPSI g loop H0Vs, is prevented (by disabling the automatic opening featuresoftheHPSIloopH0Vs)isrequired. The HPSI pumps are rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative control or by verifying their discharge valves are locked shut. The 12 hour interval considers operating practice to regularly assess potential degradation and to verify operation within the safety analysis. SR 3.4.12.3 f SR 3.4.12.3 requires verifying that the required RCS vent is lf open once every 12 hours for a valve that is unlocked open and once every 31 days for a valve that is locked open. lf The passive vent arrangement must only be open to be OPERABLE. This Surveillance need only be performed if the vent is being used to satisfy the requirements of this LCO. The Frequencies consider operating experience with mispositioning of unlocked and locked vent valves, respectively. SR 3.4.12.4 T CALVERT CLIFFS - UNITS 1 & 2 8 3.4.12-13 Revision A 5~
LTOP System B 3.4.12 4 BASES The PORV block valve must be verified open every 72 hours to provide the finw path for each required PORV to perform its function when actuated. The valve can be remotely verified open in the main control room. The block valve is a remotely controlled, motor operated valve. The power to the valve motor operator is not required to be removed, and the manual actuator is not '- 1 required locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure event. The 72 hour Frequency considers operating experience with
- accidental movement of valves having remote control and position indication capabilities available where easily monitored. These considerations include the administrative controls over main t.ontrol room access and equipment control.
SR 3.4.12.5 l5 Performance of a CHANNEL FUNCTIONAL TLST is required every 31 days to verify and, as necessary, adjust the PORV open setpoints. The CHANNEL FUNCTIONAL TEST will verify on a monthly basis that the PORV lift setpoints are within the LCO limit, Power operated relief valve actuation could depressurize the RCS and is not required. The 31 day Frequency considers experience with equipment reliability. A Note has been added indicating this SR is required to be performed 12 hours after decreasing RCS cold leg temperature to s 365'F (Unit 1), .s 301'F (Unit 2). The test cannot be performed until the RCS is-in the LTOP MODES when the PORY lift setpoint can be reduced to the LTOP setting. The test must be performed within 12 hours after entering the LTOP MODES. CALVERT CLIFFS - UNITS 1 & 2 8 3.4.12-14 Revisionpf
LTOP System B 3.4.12 BASES SR 3.4.12.6 ( Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 24 months to adjust the whole channel so that it responds and the valve opens within the required LTOP range and with accuracy to known input, m: The 24 month Frequency considers operating-experience with ! equipment reliability and matches the typical refueling outage schedule. REFERENCES 1. 10 CFR Part 50, Appendix G
- 2. Generic letter 88-11
- 3. UFSAR, Section 4.2.2
- 4. 10 CFR 50.46
- 5. 10 CFR Part 50, Appendix K
- 6. Generic Letter 90 4 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-15 Revision 4.5-1
L10P Systee . 3.4.12 Gr4 . 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 LowTemperatureOverpressureProtection(LTOP)Systes LC0 3.4.12 An pre LT,0P system sh 11 be OPERA 8LE with a maximus of one high y cap bleureofsafety i jection inje ing into t '(HP41)S RC. fety cnd the44npump and_one, charging pump inject
- M '" !.
l_c o ~). '/. I'l ." t is($lis)i lated, and' h
. . Two OP Lt power perated reller alves
. poc, g.Q lift stingsg4 )psigter . Vs)with
' ' '-# N b. Th RCS depres . a f0T C
,S, \ tY* **'lA ' * lt 1.3)squa 5 vent o inches.f.(.?rtred an .tri h k y"
- go w re[,h{, f=e- =
id a i,=w PPLI LITY: "M00 any;RCS cold leg temperature $M s i Q, w1.ir b (s
' p D t; of C 4 Q .feu , ' ' ,
r s "- - -- _ _
- vasta1Xas im ni t,.*
W . o
,.,4{lI;p.s. io b I ~ ~ ;- r---~------------NO T E------ _-------------~. -_-
,g rso {. , uv uun a uniy 4,g ..A @
h, t Ag* ll L] than equal to the quirve unen u prsssure is g xtrum RCS
.4O3 re for the ext og !
s r ", ' pt,d
.- RC old leg tempe ure allowed he P/T Ilmit yet j vidad tn t u x .=" :: .- q, g gz 3 y ,,, , a .m m e or n or' ACTIONS V I _ /J ge aled MS D t5 3 1uMh
.ps1 tNmp 3 l, ,, f CONDITICt! REQUIRCD ACTION COMPLETION TIME i A, 'Two or more HPSI pumps A.1 Inttiate action to I ately t i, of . capable of cting verify a maximum of into the R one HPSI pumpvcapable gj of njecting into the
- 3. O.3 g
M a^ uA RC rY\pA V A
%. hL . Y$ .- _ - . --
c1J o H'ini eLme s " (continued) eugw e o c no ko nheu
;4. A9 a+w Ct0G STS 3.4-26 Rev1,04/07/95
I ndM 3. 4.11. An LTOP System shall be OPERADLE witle 1.4.94. . 1. M **l'I'* A maximum of one high pressure safety injection (11 PSI) pump only capable of manualinjecting into the RCS, and
;4'q' q'3' p 2. When llPSI suction is aligned to the Refueling Water Tank (RWT), the llPSI pump shall be in manual control and either:
a) IIPSI flowlimited to s 210 gpm, or b) An RCS vent of 2 2.6 square inches established; MD
. . /,*i.1.c) b.
IIPSI loop motor operated valves (hiOVs) only capable of manually aligning IIPSI pump flow to the RCS;
................... NOTE.-..-.........---....--....-.-............
4.9. 3.c) IIPSI loop hiOVs may be capable of automatically aligning IIPSI pump flow to the RCS M i il A for the purposes of testing. l I MD c 1. Two OPERABLE power operated relief valves (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 (Unit 1), s 443 psia (Unit 2), when the SDC is in operation, or 'i../.9.3.a 2.
One OPERABLE PORV, and associated block valve open, with PORV lift setting on s Add or below the curve in Figure 3.4.12 1 when the SDC System is not in operation and PORV lift setting s 429 psia (Unit 1), s 443 psia (Unit 2), when the SDC is in operation; and an RCS vent of h 1.3 square inches established; or f,q,9,3.u.h3. An RCS vent of h 2.6 square inches established.
. I& (0 % 6i l' c,. r
.'/. 9. 3 Tb R W T, I t]T[&YI;ILT c . On or om llMT I C.I Tol {,%.h ab% 40 V t f
'y z m m .J.il b C C 3 d f~d @mg~ f"idMOTSt # >i;rre.
GS>y re (asyyAcTtDNfRMnued%skbC9;sen 4 , j Mr en P~ %
.<. n CONDITION REQUIRED ACTION COMPLETION TINE r
i B Two or more charging / -NOTE = pumps capable of T charging pumps may be injecting into the able of injecting into the i RCS. CS during pump swap
, ,, operation for g Il sinutes. -
B.! Initiate action to ! lamediately verify a maximum one charging p capable of inj ting into the RCS l C. A Si not isolated C.1 Isolat affected Sli. I hour the SIT pressure is r ster than or equal the maximus RCS pressure for existing cold leg temperature allowed in the PTLR. D. Required Action and 0.1 associated Completion Increase RCS cold leg 12 ho s temperature to Time of Condition C >(175)'F. not pet. D.2 Depressurire affect 12 hours Sli to less than t maximus RCS press e for existing col leg temperature al - in the PTLR. ( o,. ., ,) b r. one Mreou %. Restore redreguireda v poRv ,r da,s e e inoperabie inj nDot 4. to CerRAsto status. g
$t IS}u.
l . (continued) I v.4 s) Ol' 3.4 27 (;JJtSTS Rev1,o4forfgs
\y A ts v . d < l. 1 c v,
e ine I + A Na v_.e 3._e 4
- - - ._~. .__---- _ -- . i i I LTOP $ystem . 3.4.12 I ACTIONS (continued) CON 0lil0N REQUIRED ACTION -
)
COMPLETION TIME i (M*'" " 'T'ar'r4roav inoperable in MODE $ R a*r to OPERABL r eaa< k s'tatus.
<< s -
(gr ge s vmf < 4sw g 1,3 q w.a
,bl44 .
- M I .'
- 9. Iw6 required PORVs inoperable.
G.! Depressurfre RCS and establish RCS vent of (hours b) nc 8 "' E'* ' quir Acti'nand)
/ ssoc sted C let on '
Time f Cond tion
> 48,' 0, E, e F no r
' LTOP Sy tem ino r le i for an reason th e
.than onditto A,' 8.)
g D, E, or F _ SURVEllLANCE REQUIREMENTS SURVE!LLANCE FREQUENCY SR 3.4.12.1 Verify a maximum of one HPSI pump is *
.i. 3.3 12 hours capable o c,t ip.111t the RCS. @
? P_'*-kb SR 3.4.12.2 Vert aximum of one che i ump is 12 hours (apa_ _
of injecting into th $. ""* g%*lC6d23 01%) aoo srs 3. 2. Re, i o m.,
- r. %.u. n a,,,..o 4.a.,,,,,,,w u s .. >
Ac.edd wb u < c.u.., o , WeA fu ud u.3 s a.a . M k'"3 h 4
- ~ - - . - , , ,
l l LTOP Systee '* 3.4.!!
$URVI!LLANCE REQUIRIMENTS (continued)
SURVIILLANCE - FR(QUENCY SR 3.4.1 .3 - - - - - - - - TE- - - - - - - h eutrod to be omed when complying with LCO 3.4.1 . Vr IT is isolated !! hour: _ SR 3.4.!!. Verify 4RCS vent t!! *: ::::7 '- 4 ! is open !! hours for h unlocked open ,
*L"'" ventvalve(s)'
(4.4.93.z) 31 days for locked open ventvalve(s) l$ b (41.93,) SR 3.4.12.) Verif PORV block valve is open for each requi ed PORV. T2 hours h
$R 3.4.!! ---------
---------NOTE---- --------------
Not required to be perfomed untti Hit}< hours after decreasing RCs cold leg 4^'3l@ sts tudi 3H ?O g 2"*':"":'. 5 f$'------------------- Perfom CHANNEL FUNCTIONAL TEST on each 31 days required PORV, excluding actuation, f R 3.4.1 Perfom CHANNEL CALIBRATION on each pf months (MDS.) required PORY actuation channel. gg CEOG STS 3.4 29 Rev 1. 04/07/95
DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NURFA SECTION 3.4 - REACTOR COOLANT SYSTEM Additionally, two plant specific surveillances have been added to ITS 3.4.11. CTS SRs 4.4.3.1 and 4.4.3.1.b require the perfonnance of a Channel Functional Test and Channel Calibration f each PORV. Rese requirements have been maintained, because they provide assurance that PORVs' actuation channels will perform their intended function, and the PORVs will open appropriate setpoint. 13. He Note in NUREG 1432 SR 3.4.1.4, which allows the measured RCS total flow rate to not be perfonned until 24 hours after 2 90% Rated Thermal Power, is being deleted. Calven ClitTs uses a pump differential pressure method that can be performed accurately in Mode 3. %1s chan consistent with Calvert Cliffs' current operating practices. 14. The requirements of NUREG 1432 Specification 3.4.12, Low Tempeinture Overpressure Protection (LTOP) System, are modified to reflect the Calvert Cliffs specific LTOP analys requirements as reflected in the CTS 3.4.9.3. i , The requirements of CTS 3.4.9.3.d and 3.4.9.3.c are reflected in the ITS 1 CO 3.4.12.a.1; maximum of one llPSI pump only capable of manually injecting into the RCS, with the CTS details of how to accomplish these requirements moved to the associated ITS Bases. The requirements of CTS 3.4.9.3.d are reflected in ITS LCO 3.4.12.a.2; when llPSI suction is a to the Refueling Water Tank, the lipsi pump shall be in manual control and either llPSI flow is limited to s 210 gpm or an RCS vent of 2 2.6 square inches established. The requirements o CTS 3.4.9.3.c and the associated # note are reflected in ITS LCO 3.4.12.b and Note; llPS motor operated valves (MOVs) only capable of manually aligning IIPSI flow to the RCS and ilPSI loop MOVs may be capable of automatically alignhig ilPSI flow to the RCS for the purposes of testing, with details of how to accomplish the requirements moved to the ITS Bases. The requirements of CTS 3.4.9.3.a.1, a.2, and a.3 and thc
- note are reflected in ITS
) LCO 3,4.12.c.1, c.2, and c.3; which provide requirements for PORVs (and lift settings), bloc valves, vents, and PORV lift settings when on shutdown cooling. He corresponding CTS requirements were provided in Amendment 145 (Unit 1) and Amendment 131 (Unit 2) exce the LTOP cnable temperature and PORV lift settings which were revised to their current values in Amendment 188(Unit 1)and Amendment 178(Unit 2). The requirements in NUREG 1432 Specification 3.4.12 regarding Safety injection Tanks ( are not included in ITS 3.4.12 since an inadvertent or spurious opening of tin SIT outlet motor operated valves at Calvert Cliffs has no effect on the limiting LTOP analysis. The Calvert Cliffs SlT pressure is less than 400 psia; the Calvert Cliffs LTOP allowed pressure is over 400 p Herefore, the SITS will not cause a mass addition when the RCS is at or near the LTOP allowable pressure, in addition, the limiting mass addition transient (inadvertent ilPSI pu start) is initiated at over 400 psia in the analysis. Therefore, even a simultaneous opening o SIT motor operated valve and start of the llPSI pump will not affect the analysis. Not inclu these requirements in the Calvert Cliffs ITS is consistent with the current licensing basis reflected in CTS 3.4.9.3. The requirements in NUREG 1432 Specification 3.4.12 regarding charging pumps are not included in the Calvert Cliffs ITS. Not including these requirements in the Calvert Cliffs ITS is consistent with the current licensing basis reflected in CTS 3.4.9.3. The amendment reques (submitted in letters dated May 14, 1990 for Unit I and October 22, 1990 for Unit 2) that supported the issuance of CTS 3.4.9.3 requirements in their current form identified chargin CALVERT CLIFFS UNITS I & 2 3.4-3 Revision 5 I
DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG.1432 i SECTION 3.4 - REACTOR COOLANT SYSTEM i pump requirements as being administratively controlled, nis was accepted in the issuance of , the amendments (145 for Unit I and 131 for Unit 2) for CTS 3.4.9.3, which did not include l charging pump requirements. ne Applicability requirements of CTS 3.4.9.3, which excludes the condition with the RCS vented to a 8 square inches, are reflected in the Note to the Applicability ofITS 3.4.12. This exclusion was provided in Amendment 145 (Unit 1) and Amendment 131 (Unit 2). j ACTION A of NUREG 1432 Specification 3.4,12 is modified to reficct the Calvert Cliffs specific !!!OP analyses which are reflected in the CTS. Specifically, the LTOP analysis requires allllPSI pumps to be incapable of automatic injection into the RCS and only allows one pump to be capable of manual injection into the RCS.. NUREG 1432 ACTIONS II, C and D of SpeH% tion 3 A12 are not included in ITS 3.4.12 since charging pump and SIT requirements : are i,. meluded in ITS 3.4.12. NUREO.1432 ACTIONS E and F of Specification 3.4.12 are revised in ITS 3.4.12 ACTIONS D and E to reflect the Calvert Clifb current licensing basis which allows various combinations of PORVs and vents to be used to provide overpressure protection. In addition, the completion time for restoration of the required PORV in MODE 3 with all cold leg temperatures < 365'F (Unit 1), < 301'F (Unit 2), or MODE 4 is revised to r
, reflect the current licensing basis reflected in CTS 3.4.9.3 Action a (5 days). If the required PORVs are not restored within the required completion time, CTS 3.4.9.3 Actions s and b require the RCS to be depressurized and an RCS vent 21.3 square inches established within 48 hours. This requirement is reflected in ITS 3.4.12 ACTION F. NUREO.1432 ACTION O of Specification 3.4.12 is revised in ITS 3.4.12 ACTION O to the reflect the Calvert Cliffs current Ilcensing basis. CTS 3.4.9.3 Action c requires, with both PORVs inoperable, the RCS to be depressurized and an RCS vent 2 2.6 square inches established within 48 hours. ITS 3.4.12 ACTION O will require, when all required PORVs are inoperable, the MCS to be depressurized and an RCS vent 2 2.6 square inches established within 48 hours. He remaining conditions addressed in NUREG 1432 ACTION G of Speci0 cation 3.4.12 are not included consistent with Calvert . Cliffs LTOP requirements in CTS 3.4.9.3. The corresponding CTS requirements were provided in Amendment 145 (Unit 1) and Amendment 131 (Unit 2) except for the LTOP enable temperature which was revised to the current value in Amendment 188 (Unit 1) and Amendment 178 (Unit 2).
NUREO 1432 Surveillance Requirements for Specification 3,4.12 are revised to be consistent with changes made to NUREG 1432 LCO 3.4.12 described above. These changes reDect the SurycF. lance Requirements provided in CTS 4.4.9.3.1,4.4.9.3.2, and 4.4.9.3.3 and the
- footnote, with details of how to accomplish the surveillances moved to the ITS Bases. He corresponding CTS requirements were provided in Amendment 145 (Unit 1) and Amendment 131 (Unit 2) except for the Frequency of CTS 4.4.9.3.1 (ITS SR 3.4.12.6) which was revised in Amendment 208 (Unit 1) and Amendment 186 (Unit 2).
NUREG 1432 SpeciGcation 3.4.12 is revsed to include ITS Figure 3.4.121 and associated references to the Figure, which includes LTOP PORV setpoints. This change is consistent with the Calvert Cliffs current licensing basis reflected in CTS 3.4.9.3. This change was issued in Amendments 185 (Unit 1) and 178 (Unit 2). Amendments 146 (Unit 1) and 165 (Unit 2) are not used for thisjustlGeation. CALVERT CLIFFS UNITS 1 & 2 3.4 4 Revision 5 j
.. .- - , -..-- - - . ,. .- , _ .--- -- - -u.
i DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECrlON 3.4 - REACTOR COOLANT SYSTEM 15. Specifiention3.4.12 (L'IVp System) Applicability was changed from Mode 4 when any RCS cold leg temperature is s 285'F, Mode 5, and Mode 6 when the reactor vessel head is on, to Mode 3 with any RCS cold leg temperature is s 365'F (s 301*F for Unit 2) and Modes 4,5, and 6. His change is consistent with the Calvert Cliffs requirement to have the Pressurizer Safety Valves and PORVs Operable in Modes I and 2, and Mode 3 with any RCS cold leg l temperatures > 365'F (> 301'F for Unit 2). The addition of the Note which exempts the LCO when the RCS is vented to 2 8 square inches allows the equipment for the LCO to not be applicable when the reactor vessel head is off. Also, changes were made to the Actions consistent with the changes made to the Applicability.
- 16. NUREG 1432 Specification 3.4.14 provides requirements for RCS pressure isolation valves.
He Calvert Cliffs' ITS do not contain the requirements of this Specification, except for the SR which tests the interlock that prevents the shutdown cooling system suction isolation valves from opening at a specific pressure. His SR is currently addressed as CTS SR 4.5.2.e.l. and it has been retained as ITS SR 3.5.2.9. Calvert Cliffs Unit Nos. I and 2 were licensed prior to 1979. Neither unit has any speci0c requirements to individually leak test any pressure isolation valve. Additionally, Calvert Cliffs was not identified by the NRC Event V order, dated April 20,1981, as an older plant that was required to add a requirement for leak testing pressure isolation valves. As described in the Calvert Cliffs' response to Generic Letter 87 06," Periodic Verification of 4 ' Leak Tight Integrity of Pressure isolation Valves," dated July 7,1987, the pressure isolation valves are either: a) periodically tested b accordsnee with the requirements of ASMB Section XI; b) periodically tested in accordance with 10 CFR Part 50, Appendix J; or c) the pressure upstream of the valves (i.e., SI 217,227,237, and 247) is continuously monitored by remote indication in the control room, nese activities ensure the valves are meeting their pressure isolation function. Herefore, Calvert Cliffs does not need to add additional requirements to the ITS to ensure these valves are leak tested.
- 17. Specification 3.4.15 (RCS Leakage Detection Instrumentation) SR 3.4.15.2 Frequency is being changed from 92 to 31 days. This change is consistent with the current Calvert Cliffs Surveillance Frequency for the containment atmosphere radioactivity monitor Channel Functional Test.
- 18. Specification 3.4.16 (RCS Specific Activity) Required Action A.2 Completion Time to restore the Dose Equivalent 1 131 to within limits is being increased from 48 hours to 100 hours, nis change is consistent with the Calvert Cliffs current licensing basis.
19 A new Specification [ Specification 3.4.17. "Special Test Exception (STE) RCS bops - Modes 4 and 5") was added to Section 3.4. This new Specification is a Special Test Exception which allows LCOs 3.4.6, 3.4.7, and 3.4.8 to be suspended while performing special tests or maintenance (l.c.,ic .a leak rate testing on containment penetration 41, maintenance on valves located in the common shutdown cooling line, or maintenance on the shutdown cooling flow control valve). His Specification is consistent with the Calvert Cliffs current licensing basis. This change also resulted in changing the title of Specification 3.4.16 to include Mode 2,
- 20. Not use".
l
- 21. NUREG 1432 SR 3.4.9.3 requires the verincation that the pressurizer heaters are capable of being powered by an emergency power supply. This surveillance does not exist in CTS 3/4.4.4.
CALVERT CLIFFS-UNITS 1 & 2 3.4 5 Revision 5
IllSCUSSION OF TFCHNICAL SPECIFICATION I)EVIATIONS FROM NUMEG.1432 SECTION 3.4 - REACTOR COO 1 ANT SYSTEM improved Technical Specification 3.4.9 will not contain a surveillance to verify that the pressurlier heaters are capable of being powered by an emergency power supply. This is appropriate, because the pressurizer heaters are permanently powered by Class IE power supplies. Class lE power sources are backed up by the emergency diesel generators. The transfer from the normal power supply to the emergency power supply for these buses occurs on an under voltage condition. The transfer from the normal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has I been maintained in ITS 3.8.1. Additionally, the specifications for other systems that are supplied by a Class lE power source (e.g., the safety injection systems) do not contam SRs to verify the l systems are capable of being supplied by emergency power. Thus, the climination of SR 3.4.9.3 from the ITS is consistent with other specifications. Furthermore, the climination of this SR is consistent with the Bases of NUREG 1432 SR 3.4.9.3 which states: "This SR [SR 3.4.9.3] is not applicabic if the heaters are permanently powered by lE powcr supplies."
- 22. Reference to "specified in the COLR"in SR 3.4.1.4 was deleted because the limit in the LCO is the hmit tested for in the SR. Therefore, placing the value in the Core Operating Limits Report is not necessary. This change is consistent with Calvert Cliffs current licensing basis.
- 23. The containment sump monitor in Specification 3.4.15 was changed to containment sump level alarm. Calvert Cliffs has a contcInment sump level alarm system. This change is consistent with the current Calvert Cliffs licensing basis.
- 24. Not used.
l
. 25. Not used.
l
- 26. NUREG 1432 LCO 3.4.9.h requires the pressurizer to tw Operable with two groups of pressurizer heaters Operable with the capacity of each group 2 [150 kW) (and capable of being powered from an emergency power supply). Current Technical Specification LCO 3.4.4 requires the pressurizer to be Operable with a steam bubblo and with at least 150 kW of pressurizer heater capacity capable of being supplied by emergency power. Improved Technical Specification LCO 3.4.9 will not contain a requirement to ensure that the pressurlier heaters are capable of being supplied by emergency power. This is appropriate, because the pressurizer heaters are permanently powered by Class 1B power supplies. Class IE power sources are backed up by the emergency diesel generators. The transfer from the nonnal power supply to the emergency power supply for these buses occurs on~an under voltage condition. The transfer from the nonnal power supply to the emergency diesel generators is currently ensured by testing in accordance with CTS SR 4.8.1.1.2.d.3; this SR has been maintained in ITS 3.8.l. Additionally, the specifications for other systems that are supplied by a Class IE power source (e.g., the safety injection systeins) do not contain requirements in the LCOs to verify the systems are capable of being supplied by emergency power. Thus, the elimination of the LCO requirement from the ITS is consistent with other specifications. Furthermore, the Bases of NUREO 1432 SR 3.4.9.3 (the NUREG SR which confirms the pressurizer heaters are capable of being supplied by an emergency power) states that it is not applicable if the heaters are permanently powered by lE power supplies, This implies that the LCO requirement is also not applicable if the heaters are permanently powered by Class lE power supplies.
CALVERT CLIFFS. UNITS 1 & 2 3.46 Revision 5
l DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NURE61432 SEC110N 3.4 - REACTOR COOLANT SYSTEM perfonnance of the surveillance to be performed 72 hours prior to achieving steady state j operation in order to comply with ITS SR 3.0.4. This is more restrictive than NUREO.1412, which permits the initial SR to be performed 12 hours aller establishment of steady state ! operation in Mode 3 or 4. This additional restriction is consistent with the current licensing l bases.1; is acceptable, because it only affects the initial performance of the SR. Subsequent performances of the surveillance will be required to be performed at the same frequency (i.e.,72 hours during steady state operation).
- 39. Calvert Cliffs ITS LCO 3.0.4 is not applicable during shutdowns and during MODES $ and 6.
1herefore, entry into LTOP conditions would be allowed without LTOP requirements being met. liowever, it is inappropriate to entry conditions most susceptible to an LTOP event when the necessary overpressure protection is not available. Therefore, the ACTIONS of NUREO.1432 4 Specification 3.4.12, " Low Temperature Overpressure Protection (LTOP) System," (ITS 3.4.12) are modified by a Note which states that while the requirements of the LCO are not met, entry into a MODE or other specified condition is the Applicability is not permitted, i i J l t j 4 4 9
+
CALVERT CLIFFS UNITS I & 2 3A.12 Revision 5
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c.1. Two power operated relief valves (PORY .i a trip. A.A A I setpoint below the curve in rigureGi D(with their @ associat valves open, or 3y , ( 2. A single P th a trip setpoint below the curve in . Figure d.agr2 with its associated block valve open and a .l Reactor Coo ant System vent of 11.3 square inches, or
- 0. 3. A Reactr. Coolant System (RCS) vent 12.6 square inches.
fli-~ two nigh disabled byrn ure ither asTety removinginaecuon g out nnif pumps; snali cetheir motor circuit [] t
/_. [ .1 om the electrical (rack f breakers supply circuit, or by logfing ,
shut t r discharge valves. pow j_ w
} g _
- c. The HPSI loop motor operated valves (HOVs)' shall be prevented _
, A f,C 3.'/./l,k from automat,in),1yJJ,gnipa HPSL Dygp_ flow to the RCSMITclng j tag dMeir hand switcheso n pull-to override. ,.
% .No more than one OPERABLE nigh pressure safety injection pump M L 4.il A with suction aligned to the Refueling Water Tank may be used to e inject f N *- M *'- nee W -'-a 'M it must be under manual control and one of the following restdctions shall apply:
- 1. The total high pressure safety injection flow shall be
- L '/M *- ' '
limited to a 210 gpm. or g
- 2. A Reactor Coolant System vent of g 2.6 square inches shall y exist.
' co 7../. lk Al fe. RABLEhighpressuresafetyl A. L When injectionnot pump in shall use,haveQM. the above_pt[TE3MicKinyu1140;ttrcy APPLICABillTY: Whe- +k- are t g :- -*: 300" d (the RC$ is vented)
.g-{CT1F eT(. < 8 sauare incheg gggggg .
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h-- ' W L 'i. l k C. I . lf u, D. C.). 3 When on shutdown cooling, the PORf trip setpoint shall be 1429 ps',a. O EXCEPT when required for testing} ico 3,.f. n.. L cAtycRt CtirrS - UNIT 1 3/4 4 33 Amendment No. 168 fve Ad* W gpg gow fl PM P"4 p.y Iofd
$fa4 iOtMon 3. 4, i L O
j 3/4.4 MAClytJ991Agl,1YHlH LINIY!NGCON0!TIONFOROPERAIXON(Continued) !
~
AC110!(t
/vm. 4 D ""g*<w W vith one PORV in'. erable in P6DE 3 with the RC$ temperature T or ie 4. either restore the inoperable PORV to
' MMG g>tus within 6 days or depresstr ite and vent the RCS 3 tita,nhry 1 htye Mejp (,M i >*
A , ed;1Nf;.$"'*4 E 24T t19 v.e k gym,.thiven46) withW- ma$j.40_houthRVg in a ventedicondj4%p/until tytt,'- , Lees @forea/to OP Ltystupf ,- "
% (9tth one PORY inoperabin in 1400t$ $ or 6. either restore the i
i ACM I jinoperable PORY to 0PERABLE status within 24 hours, or i depressurtre end vent the RCS through e > 1.3 square inch vent (s) within the next 48 hours and maintain tee RCS in this vented A C.W I. (condition until both PORVs have been restored to OPERABLE status. , A %ith both PORVs inoperable depressurite and vent the RC' thro h
,a g 2.6 square inch vent (s) within 48 hourst p.m.in 6
. Acreed G- remrnte m m on unu i s u ne ne vrauswr0RV and ent of -
g,y
!t :ere inches has b tablished or both have beenj in Apraans t etat j .
q ! Id. In the av e nner mv rv u s or tn C5 vent (s) are usea to l - K mitigate RCS pressure transient. Special Report shall be -
/ prepar and submitted to the C sston pursuant to 10 CFR .4 l . withi 10 days. The report sha describe the circumstanc ,
intVating the transient, the ffect of the PORVs or ven s) on t transient and any_ corre tve action necessary to p vent curren_ce.j F than two HP$1 pumps' dabled.6The at lentr'two HP117
% With I naswna 6 vuii-u-isap within Tif teen migtes png
( ~
+ (UTspine two HP51 pumgs withirfthe next four hoursf,
- f. With one or more hP$1'100 ^MOVs' not prevent automatically (q'(E "" c a.]jsningJ~Hlil pump to t e RC5. tavnedima 1 The mv / A.
andsw tch ln pul tFMerriller r~ shot ano e the a fected HOV isolate e affected HP header fl h within our gg Og'( ho and i ement the ACT requir of- . E trrificati s.3.t,1.1. 3. . 3. . and 3.5. . es..spp i bl e. i
- g. With HPSI flow exceeding 210 ppm while suct on is aligned to the -
RWT and an RCS vent of < 2.6 square inches oxists. h iv'o d toinediately take action to reduce flow 10 less than or e3 1
- 1. A to 210 gp:n. J srs../ 9 O
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l . j .. - ( _ - , t ,, ,,, .- 3/4.4 ktACT0k COOLANT SY1 TEN LIMITING CONDIT!M FOR OPERATION (Continued)
- 2. Verify the excessive flow condition did not raise pressure above the maximum allowable pressure for the given RC$ L. D temperature on Figure 3.4.9-1 or figure 3.4.9 2. A r4
- 3. If a pressure limit was exceeded. take action in accordance with 5pecification 3.4.9.1;~,'7.' '* '
i- p 4 ..--h e-pre 4 *!^-" "' W. _ i NJ.t . .g . . ,J 4 ., be g.../..~ ,( v 4.i l '2. 6., s
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- f-SURyt!LLAuct At0UIREMtWTS be. . .% k .52 -T. 3 4.
u- 1 1 mm-4.4.9.3.1 tech PORY shall be demonstrated OPERABLE by: M L.3 SR - a. t 4. 87 * ' Perfomance of a CNANNet twCTIOuAL test.on the PORv actuation channet but axeludina valve 09erstjenJwithin (Enterj ('n conditioAAfFwhich w rvnv is dcaDhs t?**prime f t ho l- . 3 et iv.n vnse per 31 cays thereaf ter unen ins runt is requ' red ep OPERABLE. M.4 4 b. Perfomance of a CNANNtl CALIBRATION on the PORY actuation channel at least once per REFUtLING INTERVAL. l W c. Verify g the PORV block valve is open at least once per 72 hours
~f A . G . d when t e PORV is being used for overpressure protection.
- d. TestiMn accerdance pursfant to Specif h the intervice/fft requireme ion 4.0.5y -, -
A,4 eR
'S 4.12 . 2, 4.4.9.3.)
12 hours w hen the vent (s) is being used for overpressure protection.The RCS vent (s) sha 4.4.9.3.3 All high pressure safety injectign pumps except the above OP(RASLE pump. shall be demonstrated inoperable at Isaslonce _per 12 hours. (; ' 1' by v ying . 5 6ns u.us 6mm v vi . nm eir el rical it 3.gga r verifyino td* r. .-imso Tram discharge 1 vesare) A 5d L'le I t' k t/lheautoma open esture of the h1gn pressin usiriy ' ~' ection loo MOVs shall be verif ed disabled at least once oer 12 hours. (L .
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Except when the vent pathway is locked, sealed, or otherwiselecured
'5( 4. l~2 3 in the open position, then verify these vent pathways open at least once per 31 days.
7,a f.<g r~#y,p CALVERT CLIFFS . LINii 1 3/4 4-35 5idndment No 208 w (I [h e; tu)Ihoo? MMS M'\ A ccthri.6tj
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- 19. G 4W M w e.,een. e-.
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# '.M% h [II-Iii^-b';;;JZ2-~F;^Z^I^^"- .
ChII .C 1 C.3. Two power lief valves ( h a trip r setpoint ow the curve in Figure with their assocta valves open, or c., t. A sing Figure th a trip setpoint below the
+ e e in
)
with its associated block valve open and. a Reactor nt Systen vent of a 1.3 square inches, or C .3. A Reactor Coolant System (ACS) vent t 2.6 square inches.
- b. Two high pressure safety ection (HpS!? pumps'sh411 be disabled by either n uovi rocking outs their motor circuit breakers from the electric 1(power supply circuit, or by locking LA.
shut their discharge valves.
- c. The NPSI loop motor operated valves (MOVs)' shall be prev Att
! UU N'"'b op3 Oe g.Jp 3 fl9w.191bt L c o 3 gl,14 c. % b 9 3.han gng y g g M 3_su n safety W ec q on q w N IUhilI52".55'5E 55'Ef3.E'Eh it must be unNr~inainuti L I fcontrol and one of the following restrictions shall apply g go 1. The total high petssure safety injection flow shall be
- Ilmited to 5 !!O gpa OR , t4.4 c l-
- 2. A Reactor Coolant System vent of 12.6 square inches shall Lw S */A A ' E e. When in m the above OPERABLE HP$! o m hall _
uo'tN.IL,wI @FsM) pyllst fl Q . f j A9P . APPLir.Attt1Tvi m _g N ot E % Ro a 5 square incheh h, RC ";;; .".,; i; ; =", ;;,[he RCs jg venQ l
.gog 4J f.
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- p.. 4.,,.., a Q/
thkfoL'$' @ M~
! '3*-) M*0FS- ~
4,5. -d 4. g,vgi .8 " When on shutdown cooling, the P0fV trip setpoint shan 0e 14 . l A'd lo [ Escept when required for testing - Leo 3.yn.6 gL.4 . bIW # CALVERT CLIFFS . UNIT 2 3/4433 Amendment No. 178 g J.M Whr Pv4 l gy \ r 4
Spe e. .Ge do e. 3. 9, n z,, l 3/4.4 REACTOR C001, ANT..$Y$ FEM LIMITINGCON0!TIONFOROPERATION(Continued) bCMt 1 301'F N * */ D A.6fith gr in M00t one 4, etiPORY er restore inokerable the inoperable in P NODE to OPER 3 with RCS therature $5LE ' status within ti days or depressurtre and vent the RCS
> guare inch vntI1) WithiL.tf a t g 48 M,? N'# I hhbentpnditioD,.unty u y o A ith one PORV inoperable in M00E'A l'or 6 either restore the A egy g inoperable PORY to OPERABLE status within 24 hours, or depressurtre and vent the RCS through a > 1.3 square inch vent (s) A within the next 48 hourst and mintain tee RC$ in this vented Cd.\
4crfw F condition untt) both PORVs have been restored to OPERAllt status.
% (A E 2.6 square inch vent (s) within 48 hnurtifisin sin InWith both POR)'s inoptrables.
MWb , o sunu g u i i e s f n , r ter [0Pthat s tatt{g , f
. In the eye eitner the runus or the R vent mitigste RCS pressure transtant pecial(s) are used Report shall bto
' prepare and submitted to the com ston pursuant to 10 CF 50.4- l withi 0 days. The report shal' describe the circumsta es -
.7 int ting the iransient, the 'ect of the PORys or v (s) on i th transient and any corret we action _necessary to even3 ;
. ' currence. ,
e. LA
% With lest/han two HPSI pumps' _ditablad.mM at leasttwoMrd urumo namwm - in nui n -to.10tD wi t fleen minutes disagtEtwoHP51pumpswithinthenex our hours. )
jg ' 4 #^ C f. With one or more HPSI loop HOVs' not prevented from autompJ' icall al ning a HPSI pum)p to__the REL inmedtatel late the MOv ' iiwrltpt 1NpTdl.tili verride, or shui,4n 1 sable the aff ted L Ail solate the facted HP$1 he flowp th within f r rL h (MOV (v hou Sp and imp 1 ications o. t the action r 2.1. 3.1.2.3, rements d 3.5.3. as pplic e M i g '4W^ Q +
- g. With HPSI flow exceeding 210 gpm while suction 1 aligned to the RWT and an RCS vent of < 2.6 square inches exists
- 1. Imediately take action to reduce flow to less than or equal h
fk uf,y a eu; l4P$r l% t.M h. yolA f nwwWsca." *^ j c v ' '. -r ee p m_. , . . . ,y W Os4 or #Nu flPSI r ' siryA 49
*9Apsic. ,1.Pvme ,y e.: e @ ca p 6le of;g ,r s
% vo,udtr.J y J CALVERT CLIFFS llNIT 2 3/4 4-34 Amendment No. 193
'l ln N m,
;,4 3 r h,A faa ~
,e m e. pur p..o no e,4;. 4 ,, L, 4 ,,s.ty
( I s_,,wa, l ny* l ende fd,Ay a a. e .,:,... , at .~ es l
&g m ( ~,g> vv wah/W,A
, % g1 u a w a n. s t <. 7 y pu e ne , e<+O 64 a n) M akqb- 4 aes ,%sOl.a RL1 pys t) 4
IloTE - - i{, a LC 0 5 p . f .,c4i , 7,, g ,i q tv U I c. 4.4 rg. p )/ s.n d ' l c> o , e. b4n u .i , bd< c id
- o. % v o PC -
o on M i 9 g A 4r t. d. .n:n n.s d.'& o AJ\ 3 _ N.. .. 4. _,,,. -%. / # 3/4.4 g rTea COOLANT $YSTEM LIMITING CONDITION Fet OPERATION (Continued)
- 2. Verify the excessive flow condition did niet raise pressure L . .,
above the maximum allowable temperature on Figure 3.4.9 gressure or f tpur6for the elven 3.4.9 2. RCS g 3. w'thgpecifIcation3.4.9.1.IP a ressure Itait was exceeded, take action in accor
.hr- The Provlstens - M:!!!'*3t4= 3.0.' = =t ;;'4+ emes _
%4 -,.*e u,u . : .n
**g 4 (. p, . r . . d o.t i t L.,. . g .
e r 4 ,, 4 ,, , . . m $ q c,,g SURYt!LtANCE tt0UlktM -----'u-'- - _----r., g_ ., - (a--_ se sp e - --p) @ , 4.4.9.3.1 M 1 be demonstrated OPEAABLE by: ,
- a. reance of a CNAllNEL FUNCTIONAL TEST h 3' 4 + (7. 6- chann.L hut mueludina valva entration/whn)e.Jt0R)LacLgal n f dlys prior (fnTet#(a conditierrin which tMRV is rgginred OPERA 8L l . ~3 g vow yer n uso somener unen sne rvu , -
qu red
, g7 ' 4 b. Performance of a CHANNEL CALIBRATION on the PORY actuation channel at least once per RtrVELING INTERVAL. /*M' SR l 3,4, g
- tj c. Verifying the PORY block valve is open at least once per 72 hours when the PORY is being used for overpressure protection.
- d. ing in accordar. with the ins 1
ursuant to Spe cation 4.0.51 jsmaffe -- test reqdesmeng -- %0 a, 4 , ,7
- 3 The RC$ venth) shall be verified to be open at least once 4.4.9.3.l 12 hours w hen the vent (s) is being used for overpressure protection. per 4.479."3.'3 All high pressure safety injection Pum except the above OPERAllt pump, shall be deannstrated inoperable a$sIsast once per 12 hours by verifying that the motor circuit breakers have been removed free their electrical powe p LeitettiLar_
losted_ s ut]omaHe opentpe'by feature of'tKe strifying high pressu their dischabe valvesu are A, a gju eta _hyt n Ino tfe s g 3, f,; g , g Vs sha11 he war'rfiad disableWeast nara dr 12 hoy N, 1he above OrtilABLE pump shall be verified to have its handswitch in'ps1 - SM. 4 / L . I to. lock at least once per 12 hours. W r . I' *y =
. ,, . ~ m . I o i, W pg g Pw~ p h e p.bl<. .F
.g,4g g %e DC L * .%. 4 f,,4.12 ' 2 Excekt when the vent pathway is locked, seSled, or otherwise seciireda
.c e q t, ,,, , , J
/
7# I, , in t e open position, then verify these vent pathways open at least once per 31 days. N'*qh
^'~^
CALVERT CLIFFS . UNIT 2 3/4.4-)$ s y h tn p ntJ!o .38 y A Veri H PSI luot tr04 to cm ChN of
,-d(7+s 4+ Ru a ta ps we #
(%f low A _.. d " # B. y 3 e 4-
DISCUSSION OF CilANGES SECTION 3.4.12 LTOP SYSTEM ADMINISTitADVE CilANGES A.1 ne proposed change will ref9rmat, renumber, and reword thw existing Technical Specifications, with no change ofintent, to be consistent with NUREO.1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs ITS development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREG 1432, llowever, 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 Specifications. A.2 Current Technical Specification LCO 3.4.9.3 requires the trip setpoints to be "below" the l curve, improved Technical Specifications requires the setpoints to be "on or below" the curve. This change is administrative because "on or" only clarifies the CTS. The term below the curve also includes points on the curve, which is consistent with Calvert Cliffs current analyses. I A.3 Current Technical Specification 3.4.9.3 Actions a, b, and c require the RCS to be depressurir.ed and vented through a vent. It goes on to require the unit to be maintained in this condition until it is satisfied or the LCO is satisfied, improved Technical Specification 3.4.12 will delete the requirement that the result of the Actions be maintained. His requirement is redundant to LCO 3.0.2, which requires the associated Action to be taken when an LCO is not met. The deletion of redundant requirements constitutes an administrative change. This change is consistent with NUREO.1432.
, A.4 Current Technical Specification 3.4.9.3 Action g requires specific actions to be taken when the high pressure safety injection (IIPSI) flow exceeds 210 gpm with an RCS vent
< 2.6 square inches. De Actions require that flow be reduced to below 210 gpm, the verification that the excessive flow did not raise pressure in violation of the P/r Limits Technical Specification, and if the P/r limits were violated, action should be taken in accordance with that Specification. Improved Technical Specification 3.4.12 will not include the explicit requirements to take action in accordance with P/r limits specification if a pressure limit was exceeded (CTS 3.4.9.3 Action g.3). Current Technical Specification 3.4.9.3 Action g.3 will automatically be followed because whenever the P/r litnits are violated, the Actions of ITS 3.4.3 must be followed, his requirement is only a cross reference. Repeating the requirement to enter an ACTION when an LCO is not met is unnecessary. Herefore, cross references are not included in ITS 3.4.12. Since this change is only a difference in presentation preference, this change is considered administrative.
A.5 Not used. l A.6 Current Technical Specification 3.4.9.3 SR 4.4.9.3.1.d requires testing in accordance with the Inservice Testing Program, pursuant to Specification 4.0.5. Improved Technical Specification 3.4.12 -will delete this Surveillance, inservice testing is required per Chapter 5.0 and regulations. Therefore, requiring it specifically in this Technical l Specification is duplicative of other Technical Specification requirements and other CALVERT CLIFFS . UNITS I & 2 3.4.12-1 Revision 5
DISCUSSION OF CilANGES SECTION 3.4.12 LTOP SYSTEM l ' regulations. De deletion of duplicative requirements is considered an administrative change. his change is consistent with NUREO 1432, 1 A.7 Current Technical Specification 3.4.9.3 Action d requires a special report be provided to the l NRC if either PORVs or the RCS ,ents Are used to mitigate sm RCS pressure transient. l Improved Tecimical Specification 3.4.12 deleted this requirement. His requirement is redundant to the Chapter 5.0 requirement, which requires a report to be written if the PORVs or RCS vents are used to relieve overpressure events. The deletion of redundant ' requirements in Technical Specifications constitutes an administrative chanEe. This change is consistent with NUREG 1432. 4 A.8 Current Technical SpeclAcation 3.4.9.3 provides a requirement, in the. event one or more ilPSI loop motor operated valves are disabled, to implement the ACTION requirements of CTS 3.1.2.1,3.1.2.3, and 3.5.3, as applicable. These requirements are only cross references. He referenced Specifications are aheady required by CTS 3.0.1 (ITS LCO 3.0.1 and i LCO 3.0.2). Repeating the requirement to rneet an LCO and its Required Actions is unnecessary. Herefore, the cross references are not included in ITS 3.4.12. Since this l change is only a difference of presentation preference, this change is considered administrative. t IECilNICAL CilANGES - h10RE RMTRICTIVE M.1 Not used. l M.2 Current Technical Specification 3.4.9.3.h states that the provisions of Specification 3.0.4 are not applicable. Herefore, CTS 3.4.9.3.h allows entry into LTOP conditions when the requirements of the LTOP LCO are not satisfled. The ITS 3.4.12, " Low Temperature Overpressure Protection (LTOP) System," ACTIONS are modified by a Note which states that while the requirements of this LCO are not met, entry into a MODE or other specified condition in the Applicability is not permitted. Therefore, this change will no longer allow entry into LTOP conditions unless the requirements of the LTOP LCO are satisfied. This change represents an additional restriction on plant operation necessary to ensure that overpressure protection is provided during the conditions most susceptible to an LTOP event. IECIINICAL CIIANGES - IW10 CATIONS None TECIINICAL CIIANGES MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Details associated with the methods used to disable llPSI pumps (CTS 3.4.9.3.b, the associated # Note, and 3.4.9.3.c), prevent ilPSI loop motor operated valves from automatically aligning IIPSI pump flow to the RCS (in CTS 3.4.9.3.c and 3.4.9,3.f), and prevent the one llPSI pump allowed to be capable of injecting into the RCS from automatically actuating are to be moved to the Bases for ITS 3.4.12. These details are not necessary for ensuring the Calvert Cliffs LTOP analyses assumptions are maintained during CALVERT Cl.lFFS - UNITS I & 2 3.4.12 2 Revision 5
DISCUSSION OF CilANGES SECTION 3A.12 o LTOP SYSTEM LIOP conditions, ne requirements of ITS LCO 3.4.12 a.1 and b. ACTIONS and Surveillance Requirements are adequate to ensure that a maximum of one llPSI pump is only capable of injecting into the RCS (manual injection only) and llPSI loop motor operated valves are only capable of manually aligning IIPSI pump flow to the RCS. Dese requirements are considered to be adequate for maintaining Calvert Cliffs LTOP assumptions, nerefore, the details to be moved are not required to be included in the ITS to provide adequate low tempercture overpressure protection. Changes to the Bases will be controlled in accordance with the Bases Control Program in ITS Chapter 5.0. His approach provides an effective level of regulatory control and provides for a more appropriate change control process, ne level of safety of facility operation is unaffected by the change, because there is no change in the requirements for maintaining LTOP analysis assumptions when the LTOP System is required. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This change is a less restrictive movement ofinformation change with no impact on safety, nis change is consistent with NUREO.1432. l LA.2 Current Technical Specification SR 4.4.9.3.3 contains details of methods for verifying a maximum of one llPSI pump is capable of manually injecting into the RCS and for verifying the llPSI loop htOVs are only capable of manually aligning IIPSI pump flow to the RCS. Improved Technical Specification 3.4.12 will not contain these details. These details are being moved to the Bases of Specification 3.4.12. This la acceptable because moving these details to the Bases does not impact the requirement to verify only one llPSI pump is capable manually of injecting into the RCS and for verifying the llPSI loop hiOVs are only capable of manually aligning IIPSI pump flow to the RCS, nese verification requirements are maintained in ITS SR 3.4.12.1 and SR 3.4.12.2. The details of the verifications can be l adequately controlled in the Bases which require change control in accordance with the Bases Control Program in ITS Section 5.0. His approach provides an effective level of regulatory control and provides for a more appropriate change control process. He level of safety of facility operation is unaffected by the change, because there is no change in the requirement to verify only one llPSI pump is capable of injecting into the RCS. Furthermore, NRC and Calvert Cliffs resources associated with processing lleense amendments to these requirements will be reduced. This change is a less restrictive movement of information change with no impact on safety. This change is consistent with NUREG 1432. IFCIINICAL CIIANGES - LESS RMTRICTIVE L.1 Not used. l L.2 Current Technical Specification 3.4.9.3 Action e requires placing at least two llPSI pumps handswitches in pull to lock within 15 minutes and disabling two llPSI pumps within the next 4 hours when less than two 11 PSI pumps are disabled. Current Technical Specification 3.4.9.3.e requires the one !! PSI pump capable of injection into the RCS to be incapable of automatic actuation, the CTS do not provide actions for the conditions where the CTS 3.4.9.3.e requirement is not met. Current Technical Specification 3.4.9.3 Action f requires with one or more llPSI loop hiOVs not prevented from automatically aligning a llPSI pump to the RCS, the htOV handswitch to be placed in pull to override immediately or CALVERT CLIFFS UNITS I & 2 3.4.12 3- Revision 5
DISCUSSION OF CHANGES SECTION 3A.12 LTOP SYSTEM shut and disable the affected MOV or isolate the affected !! PSI header flow path within 4 hours, improved Technical Specification 3.4.12 ACTION A requires, with one or more l llPSI pumps capable of automatically irdecting into the RCS or with two or more !! PSI. pumps capable of manually injecting into the RCS, that action be immediately initiated to i verify a maximum of one llPSI only capable of manually injecting into the RCS and no lipSI pumps capable of automatically injecting into the RCS. Improved Technical Specification 3.4.12 ACTION C requires, with one or more llPSI loop MOVs capable of automatically aligning IIPSI pump flow to the RCS, action to be immediately initiated to - verify llPSI loop MOVs are only capable of manually aligning IIPSI pump flow to the RCS, Restoration of restricted coolant input capability to the RCS within a specified time period may not alwr.ys be porsible. In this situation, the CTS do n# pmvide direction as to the l j 1,, - action to take. As a result, the ITS provide Required Actio9s to immediately commence and' ' continue attempts to restrict coolant input capability to the RCS consistent with assumptions of the LTOP analysis. This change ensures that actions are taken to restrict coolant input capability to the RCS in a timely marmer while continuing to provide directior, if attempts fall to restore the required coolant input capability restrictions within a specific time period. This change is considered to be acceptable since ITS 3.4.12 ACTIONS A and C do not preclude, but continue, to require action to restore restricted coolant input capability which will decrease the possibility of overprr ssrization further as additional coolant input source restrictions are restored, in addition,!TS 3.4.12 ACTIONS A and C require actions to be taken immediately, which is defined in ITS Section 1.4 as without delay in a controlled manner. As a result, this change ensures that actions to be taken to restore required coolant input restrictions are immediately initiated rather than allowing up to the CTS Completion Time for satisfying the action and also ensures that direction is provided for restoring all l conditions where coolant input restrictions are not satisfied.
- L.3 Current Technical Specification 4.4.9 3.1.a requires a STE to be performed on the PORV actuation channel within 31 days prior to decreasing RCS cold leg temperature below 365'F (s 301'F for Unit 2), improved Technical Specification 3,4.12 does not contain this requirement, and allows the SR to not be performed until 12 hours after decreasir g any RCS l cold leg temperature below 365'F. This eliminates declaring the PORV inoperable and changing the PORV lift setting in L Mode [ Mode 3 with RCS cold leg temperature > 365'F
(> 30l'F for Unit 2)) when the PORV is required to be Operable. A STE is also required in Mode 3 > 365'F (> 301'F for Unit 2). The change is reasonable because it allows 12 hours to stabilize plant conditions, change the PORV lift setting fcr the present temperature requirements, and prepare for the STE. It climinates plant personnel from changing the PORV lift settings unnecessarily in a Mode where the PORVs are required, which involves manipulation ofinstrumentation that can lead to human error. This change is consistent with NUREG-1432. L.4 Current Technical Specification 3.4.9.3 Applicability requires the LTOP System LCO to be met when RCS temperature is s 365'F (s 301'F for Unit 2), and the RCS vented
< 8 square inches, improved Technical Specification 3.4.12 requires the LTOP System LCO to be met in Mode 3, with any RCS cold leg temperature s 365*F (s 301*F for Unit 2), and l Modes 4,5, and 6. The CTS requirement that exempts the Specification when the RCS is vented > 8 inches was made into an Applicability Note. This change essentially eliminates the CTS requirement which requires the Specification to be applicable when the unit is CALVdRT CLIFFS - UNITS I & 2 3.4.12-4 Revision 5
. ~. .. --. .. . .- . ._. . . . -_ _ . -.
DISCUSSION OF CHANGES SECTION 3A.12 LTOP SYSTEM defueled. This change is less restrictive only since it deletas the defueled Mode of Applicability. This change is consistent with NUREG 1432. L.5 in the event liPSI flow exceeds 210 gpm, CTS 3.4.9.3 Action g.2 requires verification that the flow condition did not raise the RCS pressure above the maximum allowable pressure for a given RCS temperature on Figure 3.4.9-1 or Figure 3.4.9 2 (i.e., verity the RCS pressure / temperature limits are not vio):ted). This requirement is to be removed from Technical Specifications. This requirement is not necessary to be included in the Calvert , Cliffs ITS because the requirements ofITS 3.4.3 require RCS pressure / temperature limits to be met at all times, in ITS, LCOs must be continually met during the Applicability (per ITS 4 LCO 3.0.1). Thus if IIPSI flow exceeds 210 gpm and this results in the RCS pressure / temperature limits not being met, LCO 3.4.3 would not be met and appropriate ITS 3.4.3 ACTIONS must be taken. In general, this type of requirement is addressed by plant specific processes which continuously monitor plant conditions to ensure that changes in the status of the plant that require entry into ACTIONS (as a result of failure to satisfy an LCO) are identified in a timely manner. This verification is an implicit part of using , Technical Specifications and determining the appropriate Conditions to enter and Required Actions to take in the event of a failure to meet an LCO . In addition, plant status is continuously monitored by control room personnel. The results of this monitoring process are documented in records / logs maintained by control room personnel. The continuous monitoring process includes re-evaluating the status of compliance with Technical Specification requirements when the plant conditions change. Therefore, the explicit requirement, in the event HPSI flow exceeds 210 gpm, to verify that the flow condition did not result in the violation of RCS pressure / temperature limits is considered to be unnecessary for ensuring compliance with the applicable Technical Specification requirements. 4 s 1 CALVERT CLIFFS - UNITS I 4.2 - 3.4.12 5 Revision 5
tTOP Systen 8 3.4.12 8 3.4 REACTORCOOLANTSYSTEM(RCS). t 3.4.12 Low Temperature Overpressure Protection (LTOP) Systen BASES - K4ROUND The LTop System centrols RCS pressurJ at low t retures so Q 's (4PSr pump g mthe integrity of the reacter coolant pressure (RCP8 ary .. a 4
'~ .#M ( o n b o temper)ature (P/T lietts of 10 CFR 50, Appendix Gis not comproatsed by v The reactor vesse)l is the RCPBcoepnent limitt Ref. 1).
Cu'^( or rnc,nuoJt :na,' ^3 demonstrati such tection. L 3.4.3 RCS Pressure and T rature w /T t eiti.- revides the a iowabie RCA . W e inations or)operationa pressure and temperature during ooldown
- 4. , Q p51 (N mf Reference, shutdown, and heatup to kee from violating the .<
O I requirements during the L OP MODES. h o- s 7 *j k The teactor vessel material is less tough at low
..-s 8^
g hf Tem temperatures than at normal operating temperatures. As the vessel neutron exposure accumulates, the material toughness i ecreases and becomes less resistant to pressure ftress at ! - pN 3 4*' $ 951 ow temperatures (Ref. 2). RCS pressure, therefore, is i rdg[] temperature is increased.intained low at low temperatures and is increased only as i s i { b( f v t he potential for vessel overpressurization is most acute V ^ h. s 1 M ""( uhen the RCS is water solid, occurring on1 Y M fcLg g's , i pressure fluctuation can occur more quic lwhile shutdown;, operat>r can react to relieve the condition.y than an Exceedin the RCS P/T limits by a significant amount could cause bri t1e qkN@ lONg pmMr - x v . ,,
*mv tj cracking of the reactor vessel. LCO 3.4 3
.x d' 'T adelnistrative control of RCS pressure an.3 requires d temperature ll k-o V'Irlh during heatup limits. and cooldown to prevent exceeding the P/T 9
I
' kV *
.This LCO provides RCS ove ressure protection by having a
'g hyw cA einieue coolant input cap 111ty and having adequate n pressure relief capacity. . Limiting coolant input capabilit L d: 4N rA_ - - requires all but one high pressure safety injection (HPSI d .'n l$ bA mp EEUshNeMt af.!aM!?uatag-) y pressure relieflahcit[Nitut5ielih'er two $NRINE o yn ob M9 *
~g redundant power operated relief valves PORVs s depressurized and an RCS vent of s=f*J:.:'.;}.I&.the RCS-One PORV-g n k ]. @Y n ' or the RCS vent is the overpressure p tection de ce that acts to terminate an increast re event.
. c. w i~~
%k'% - @.-
(continued) CE00 STS
, 8 3.4-56 Rev 1. 04/07/95 or- eh - ).3 f f ee. (URY anD a n CC,S d of-t ved k crob;< .
f
l l i LTOP System i B 3.4d2 ' BA$t$
#f0 m
BACKGROUND With minimum coolant input capability, the ability
& HMg (continued) providecorecoolantadditionisrestricyed.
not 7'
" - ^
The". ? fr: safetyinjection(SI);r;../..-d actuation4.;;; h:t-d .. ... t etblock circuitsf tb 1-r p*eir r : . tL '.T =; J the-en-.9ee-w- *rf ere l1 K- -
^ '
v + 6 h Iboki srdih- ~
' 't the use of more than one {MR! ?-b pump for makeup '
in the event of loss of inventory the;'p;mps nu can be made available through manual actions., h The LTOP System for pressure reitef consists of two PORVs with reduced lift settings.apr an RCS vent of ="ffMM;t A a4ee. Two relief valves arg required for redundancy. One .laa g e PORY has adequate relieving capability to prevent [ overpressurization for the equired coolant input capability, g g,/4 PORY Recuirements re}uub /WfulhN "d As designed for the LTOP System, each PORY is signaled to u ggy,,+ ,f j,T5 par.ia k
,_ = : h open if the RCS pressure approaches a limit deterwined by the LTOP actuation logic. The actuation logic monitors RCS heukt
~~
0d pressure and determines then the LTOP overpressure setting is approached. If the indicated pressure meets or exceeds the calculated value, a PORY is signaled to open. The LCO presents the PORY setpoints for LTOP. The-set h
-......y . .;,+; -7 ...,e y y - ; f . ,.e.., e. 9; points it --s
;g i;;
. . ... . . tM ' rt . Having the setpoints of both valves limits will not be within exceeded the limits of the LC0 in any analyzed ensures the P/T event.
When a PORY is opened in an increasing pressure transient, < the release of coolant causes the pressure incrcue to slow
- and reverse.
As the PORY releases coolant the s stes ressuredecreasesuntila,resetpressureIsreacNedynot ; v ivy ,s signaiea to ciop . depresse below the reset nressure as the valve m oses.me ymsmJ6enunfs so 5 kb pad M emt i.s tem:mMaul
& y<<de m.will ekS37@,k is adequately protected against exceeding the Ref rence 1 \! *> 5 m- P/Tl.imitsdurinL, shutdown.
me _
._u ,__ .In ,, ,.. n /. ..,..o__
MODE,S 1 d, and , am..H. .n. .
' % s W 6 is sA F.ut % 'tEphebfl'e'r s'ifdy vanes pre' vent "C" ;r:d$3 C
( 4d 4 n.(- hel.lij ext;;d'.rG 'M Pa'"r T e I b'ts. At 3NU#l 'A below, overpressure; prevention falls t@o theE *F and 1 4 Ph p- fior to a depressurtzed RCS and a sufficient sized RCS ven LE PORVs 30/&4 2) Each of these means has a limited overpressure relief c capablitty.
"'b ' Q j,,,, y /l The act 1t erature at ch the pressure in t
-- (;h M7/
tait urve is below t pressurizer safety e
/1 e int increases as t reactor vessel matar +anahnessi l8 rentes due to neutr limit curves are revised, the LTOP System will ben-Mt+1 aman + f Each time the P/T~
re-evaluated to ensure its functional requirements can still be satisfled using the PORY method or the depressurized and vented RCS condition. Reference 3 contains the acceptance limits that satisfy the LTOP requirements. Any change to the RCS must be evaluated against on theseacceptance the LTOP analyses tolimits. determine the impact of the change (continued) , 1 CEOG STS B 3.4-58 Rev 1, 04/07/g5
,p.a_,.. + w -*- 4-- - - - - --+e--ed'-+-Hr-- 4 e J' mew +-&e-- d i4dap- -s 4 .,el*
*w.+4e +bd- +M4ed- 4m-An - *44-es*J -)amLH .S 4-e. + - -
e LTOP Systee B 3.4.12 1. BASES APPLICABLE SAFETY ANALYSES Transients that are capable of overpressuriting the RCS are categorized as either mass or heat input transients. (continued) examples of which follows Matt fnnut Tyne Transients- 8["
- a. Inadvertent (safety; injection; Af h 8. Charging / letdown flow mismatch. L L. hem HPC* and g -
Heat Innut Tyne Trantients %,..,,.-,4,9.c
- a. Inadvertent actuation of pressurizer heaters:
- b. Loss of shutdown cooling (SDC): or
- c. Reactor coolant pump (RCP) startup with temperature j i Tn 5.ar r D asymmetry within the RCS or between the RCS and steam l
C- generators. A I.f,\ The following arm required during the LTOP N00ES to ensure Il that mass and heat input transients do not occur which either of the LTOP overpressure protection means,cannot handlet-an0 \,b Ma} 8MES-4
,mAab (mm 4Ac l
- a. . Rendering all but one HPS! pump, ::d " i.;
r u t--4 ; -. sincapable of injectioy *nd b* %^Hl'C
=
p-4 * %mm .. ..- .. . . g; p '; p"3 Tjdt' "'""*' " ,~_,j .. , __ ,,, . ,_ _ , _
' f f lphnue a 1. o~
- i1 @ g
. i hn,a h u\ U o n,,, (dhe Reference /J analfits1 n ra e that eit er ne PORY or E i the RCS vent 8' tan maintain RCS pressure below imits when c.hseg toy pq i,ak only one HPSI pump =ad - th:- '- i I
. g *) d'* gg
. .**d' .
Thus, the LC0 allows only one HN5g p., = actuated. d pump :-d = 0...y.9-
= --'
En s.c SA h i c nh -pump.0PERABL(ar.uringtheLTOPMODES.n ae th: "00 't 0: Vthe ;=;.. . ^ . ..,. :th;r t..;
#--- ::. r:' r d
==h t. r ' ,i e en .i . . ... . 6. ec.t.'.t "-- *** t: ; =,t = ' 7; ;h., th;-
. a . . i . . -- a - - . -- --
d # 4 a t e am na
^L, =*w '"
. n r. e. h. .., < . . , y , --- - - -
/* s'de a4c b(,(a 3. 6. av g QQ, 73Q(,s'Q';7p;..g, m" M I4vQ $ no W T ,.,g. . C5 V* .2 4 qese
_ - _ _... ..... ,,,.. ..,,r. o.. .u u . -. . n x ,, . % ,
, .. ,.. ,..g....y. ..q.
6.v..u , [q' , 3 gg. T^'"'2^^
" < - ; i
,,.......,,..,...._.o...
*"' ' ' ' '" " ' ' ' ' 8 8 *'n e m i s
.r. .. .
g ro p it** *^ b C N cWro lI*A -, (continued) c,4 ; m ln h > c d v<^ ) S B 3.4-59 Rev1,04/07/95 M p f 6/)lw h
.. rems;nt} HnZ 1:3 rewrs..,)
eau.ikoef w N W h*$
-ho cAsy % & PJ n 't te d"* d 0 ise.p Ue . t njeck, a a vi. xc6 ,,, ja.s><d h~j
i l INSERT b & c
- b. -- When HPSI suction is aligned to the RWT, the HPSI pump shall be in manual control and either: 1) HPSI flow is limited to s 210 gpm or 2) an RCS vent 2 2.6 square inches is established;
- c. Rendering HPSI motor operator valves (MOVs) only capable of manually aligning HPSI pump flow to the RCS; .
og , . , q. . r-
- r. m r t _ .u- .. ..
INSERT ASA provided two of the three HPSI pumps are disabled and the remaining HPSI pump's flow is throttled. If HPSI pump flow is not throttled during addition of mass to the RCS through one HPSI loop MOV, then two PORVs or an RCS vent 2 2.6 gpm are capable of maintaining RCS pressure below limits. 1 4 4 4
=
.- -- .- . - .. . - - . - ~ - - . - . - . - - - - - - . _
l l l
- i. 1 i
9haa^u le.J epd O l 24I k 3CO nlcm3 Gr 64 I LTOP Systes (9,o u r n/c-s Sesi. & 2.) , t) 8 3'4 32 BASES APPLICABLE Heat Innut Twoe Trantients (continued
, gigi..4\
SAFETY ANALYSES ,g.g f. ,, ,c,4 2. t-- : ti... tMt ;f 't; ' 00. (i^;-]"in c:. ., - ; ; n ;:~.'"-- ]?;;"T 1,,,,,
-- (,,,,,,,,
M4 hA.b.# Tr;;t.. . .:....h; analys
# LTOP Apolicability at- established the temperature of 1
hu j sKf en%-6-qAC ghris i pressuruer'Fsafety tem"wrature,4the and belou.O Above this I i valves provide the Md u i.,Me<< rg.neter vessel pressure protectiork.. The vessel materials re assumed to ha 1 a f.n 4 ,,7j j,4 f
--":t ' e " -"-c' ve
- e *rP a --"- ;:n:---
f " 8 -
;nn :? ;:r9,cc m ht;. L
)
^Ed"'?*f' N " A ~ The consequences ofla O g b*.m.p,g -- -
,g g0CA)ixKin pend
;11 i:.3 loss of coolant accident LTOP R/Jnform to 10 CFR 50.46 and 10 CFR 50 Refs. 4 and 5 g
ef one HPS!(pump and-enec), ;' ;requirements
;q ; ;,= _-jby::having 6eam4 /t>, eve....
$ s oy L in
- tnth:,22h}!=* ;r Q
se,m c, ua PORY Performance (bJl siaC C+DTY
^#
i cMMen The fracture mechanics analyses show t t e vesse : C- - O ' # 'n ~'7 D protected when the PORVs are set to open at or below 3 i -f ]2M] M. The setpoint is derived by modeling the E1d 2d9' perfomance eP r:f '.T^^ of the LTOP System, assuming the limiting g
~~
tr=&-t efn'*- : ""!! ;"- rd :n 3;is ;,,, go
.a.-
i
.These analyses co. sider -g ,4 Ng 7re'ssur.4. ... au'_ overshoottfrqPUnd(rsh5o3 beyond 6 O the PORY
,p lj openin
' e n C *(*
- cloMinh setpoints resulting from signal processing and c ^' d **/ D valve s me times.' The PORV setpoints h belcit the Hm ' 4, C,ter,t derived limit ensure the Reference 1 limits will be met. p ~p,g,, '^ $ I
(@RCS, g 1 0 ,.#8, f/T M8
- 4
" " 'd* ** 4 The the PORY sethT limits conflict with the LTOP revised el danalysisints
. a3 @ k .ss\ A will b f
limits. op44^ i-b d.. '*.,.,'p 4 The P/T limits are periodically modified at the reactor vessel material toughness decreases due to - w .o f .c Q embrittlement caused by neutron irradiation.. Revised P/T h ch,4 cyn. e,,,,, w ,p J: g, 11alts are determined using neutron fluence pro,1ections and i py gj* U the resultssurvelliance rradiation of examinations specimens.Jof the The reactor vessel Bases for material Lc0 3.4.3, 'RCS Pressure ano issperature (P/T) Lietts " discuss these examinations. The PORVs are considered active components. Thus, the failure of one PORY represents the worst case, single active failure.
- l. \
(continued) CEOG STS B 3.4-Jer_.lg7pSy i-g.w~w +L y .J;os+LpovUH a#N;$ g j/ mud L. 3 N:L9 P ' -(Un;ya e quap; duo.w. IL*,, w un
,Q uM n.fhy j l~e3
(; S "+. 't p *
- s
- J w k soc. h '^ of ?4, ^' ga o s =c g r* (; h ,
Q< mea..su & p '* % p g gemk_in q (%g j <~A _ A A _ - G / ~ ~ ~- ~ n N f
.y . ~ ~ y g
o ro v i < e. A: f t(45v r ij or 8 u vovena.,yeJk
%o of k c o e, }[ PSI p u mp s e c$i4od r N [
o~0. A mc kl,3 H PSI p u m p 'a b la
, .$ ro {. ,- -
.(Q %v LTOP systen 8 3.4.12 i
BASES F APPLICABLE SAFETY ANALYSES Rcs Vent performance h (continued) W1 the RCS depresLurized, analyses show a vent site -f square inches is capable of a ti fyp y/ms,n l ,,,,' a eued LTOP everpressure transion .Inenting that event,the lietting thi site vent maintains RCS pressure less than the. i<di ved , - pressure.gn _tJ)e.P/T 11eit curve. ,_'s>.,',,.."
- i. f?A.sp&4.d64 I* - repiet
~
The RCS vent size will also evaluated for compliance
- 6. 3,,,/q . p.,,t ,, ,p each ties the P/T 11 es are revised based on the ob pE, s.aA results of t e material surveillance.
! at W.52: .K,,Mu Aae. S vent is passige and is not subject to active _, failure. . 3
~
LTOP Systes satisfies Critorion 2 of the NRC Policy ' Statement. 4' LCO This LC0 is required to ensure that the LTOF System is
- OPERABLE.
- The LTOP System is OPERABLE when the einfan
, coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low l temperature overpressure attigation and violation of the Reference 1 limits as a result of an operational transie t A o eno.,4en am o
. Q To limit the coolant input capability, the LCO requires y G.\
l ~ j 'f.C'edibii7f"E" ** .gectW n __ .._ u.c _ m . l 3__ . 3 g - ,..-,-.
' '" I "' " ".!!.v-"."y .". n"' ... y,"'.* '.'E
-..,........,.ymnm. n..... .m ..
a
- - /g The elements of the LCO that provide ovefpressure e iga ton through pressure relief are
- y - = - - = - - --
" A5#00- _
Two OPERABLE PORVsk g g,* one cemed toMeA "x\ a. b v loc.k VeJue.s o - #
/ %Res n .i e r.
i
@/. The depressurized RCS and an RCS ventg e
;h y 9 i\-
@ A "' 2 I' >* 9 c A PORY is OPERABLE for LTOP when its block va ve is open, b 8 C0 i.
' { n c3-t.6 - its lift setpoint is set a6-fm] r=9 - .- : nd testing has proven its ability to open at that setpt, int, ad motive power is available to the two valves and their co rol
- circuits. >
-? o p w e.2.C "^sq M .g T
(con n (- CEOG STS-8 1.4-61 Rev g g yg U hn 9 syvw4 .h t / .' a svh 'e.'m h -k u 4. (0 ru w .,p J .. rk Li, & pac. e- e n u-l ;d ud b a s U lh Y LToP spL req ui<emab b ( J n ee. J s q io ru.lN,\ R c s g a n s a t.v , k'n hen,'h. j a ~ H ,
i n INSERT LCO i This is accomplished by disabling two HPSI pumps by _either removing (racking
-out) their motor circuit breakers from the electrical power supply circuit or by.
locking shut their discharge valves. During required testing, other means of preventing the two HPSI pumps from injecting into the RCS may be used. In
- addition, when not in usej the remaining HPSI pump shall have its handswitch in pull-to-lock. When HPSI suction is aligned to the RWT for injection into the
/[
1 RCS, the HPSI pump must be in manual control and either HPSI flow shall be j : limited to s 210 gpm or an RCS vent of 2: 2.6 square inches-is established. -Tom .. s - D provide single failure protection against a HPSI pump me.ss addition transient, the ' HPSI loop MOV handswitches must be placed in pull-to-override so the valves do L '
. not automatically actuate upon receipt of a safety injection signal. During
- j. required testing this requirement may be suspended ' .
1 i; 4 w -- a m-- ,- m-,y- - o -- w- y a ., - ,. --r- - ,w-p.e
L10P Systee B 3.4.12 ggggg aa # /. .m suv s?a sfu.<e. onnees. Aelu -M cua. @ LCO An RC vent is OPERABL when open with an area (continued) 2 . square inches Each of these methods of overpressure prevention is capable of mitigating the limiting LTOP transient. -=- R.c - E P' M R Lc9 W 9 2 APPLICABILITY QsstussQ This LCO is applica 2of(a .t & G ~- e in MODE K n the emperature of any RCS cold leg ts s yean or vs , in MODES -
; and[. y 6/wS4hthe I head is on. ine pre vr 4 i .. .ir valves h
provide orpressure protectic,n t P ts above je/T 1 is off, 24ti'F and meets the Reference Qi over(eretturinti . When the reactor cannot neeuw. el LC^ 3.4.3 provides the operational P LCc 3.4.10, ' Pressurizer Safety Valve /T limitsthe s,' requires for all MODES. . OPERABILITY of the pressurizer safety y overpressure prot,Rttion duri MODES 1 4 2, esnthat provide above 'F. 3ML*NO /, and MODE Qt So u-r +
- Low temperature ov ressare prevention is most critical h during shutdown when the RCS is water solid, and a mass or
*" heat input transient can cause a very rapid increase in RCS b e ev Kc.tr /, y,4 > The Applicability is modified by a Note stating that'#At-4.at.+u-g 87 .a ,h h > :73 7:; -4 a--
fcg y g *g g", 4 thu e q. 3 1 +a
+A: n.c ;7:::rethe r--
MT ;r;;;;r; '; v.ater tL- -- q t i tai-
+ba "?':tr;, ;; .1h ;d ij tl.; "/T J . Tht: Met: ; --it:-th: C:! d';c;...
l'.;. ;.; ; ; ;grnid;d in
- 'iPrech b .
AC1 hamn sua eph. seeilh=: ;rnr teapustec ~4';h,.;. d er.ij .-Jer-the;; pr..; .ae
.......J-
==
ACTIONS A.1 4ad44 With two or more HPSI pumps capable of injecting into the RCS, overpressurization is possible. The immediate Completion Time to initiate actions to restore restricted coolant input capability to the RCS reflects the importance of maintaining overpressure protection of the RCS. (continued) CEOG STS B 3.4-62 Rev 1, 04/07/95
l l 4 N INSERT LCO BASES '
/ l
/ /
The LCQ is modified by t o Notes. Npt6I requires the following restri ions wher using b the HP I pump. a; the pump must in manual l ntrol, and A b./ - an RCS ve ;t 2.6 square i ches must exist r HPSI > 21 gpm. j These restricti s placed on HP I pump operati ensure that overpr e transient - 4 does not oc by either auto tic HPSI actua on or by oper ing a HPSI mp greater ,- than 210 . Note 2 requi the PORVli tting to be 429 psia (U 1), s 443 psia (Unit 2) n on shutdo cooling. This sures that the RVlift se ngis low
- enough mitigate overp ssure transient hen operati on shutdo cooling, since the RCSt perature meas ement is not ac rate in this dition.
J J s f i w . c --
. - ~ . . - ~- - - - - - . _ - .. - - - - .
I a l i LTOP Systen 8 3.4.12 BASES ACTION $ -O id0*. '
';n".t.;J) b ;.t . .J ^ . '... ;. ; .. f !!' :f S; i '- ' M' cyjg,
;. J t: ^.;;
i , -ih ;f ?." SJ- ^ I ... S. $ . . ...^... " o h OM' ET o. i . and 022 An unisola $1T requires i lation within I hour. Thisil only req when the $1T to the ximum RCS pressu ssure is greater than or equal temp sture allowed in for the existing cold leg PTLR. 3 isolation s need i and cannot be accomplished within twtH .ar, Requi ed A on D.1 and Required Action 0.2 pro e of which must be performed within 2 12 ho." tons, urs.
- sit i
Sli pressure, i reasing the RCS te. perature to > J'F a [600)psigcannotexceedtheLTOP mitsIf the tanks ar fully injected. C; pressurizing t SIT below
- the LTOP 1 it stated in the PTLR also protec againstsucN an event The C {
letion Times are based on opera g experience that the activities can be accomplished i these time periods ' a on engineering evaluations indi ing that an event quirino LTOP is not likelv in t allowed times. (hEI[oiuN , o f-N-ts ' e t o GSbadd GArf e) b
,. y e In' MODE he
% any RCS coldleg temperature,is $ {384'F,
[M[',g 11L5 M { R inoperab of4wo POR
< g ,1 m) W A
'Mkg h-withone s
OPERABLE status wit veher.n M re aCompletio$mustberestoredto n Time of to meet the LCO require a s. - or g M provide in erature overpressure mitigation while g- (Q withstanding a single failure of an active component. The Completion Time is based on the fact / that only one PORY % W' is required to mitigate an overgressure transtant s.J ^.:..".
+" p un 6-4 ' R9 'M;d ;f :.:. ;d';; S' .r: :f " r rtning-veke il 7 t' '. . L r. . %d u . . . , S.:.
(continued) CEOG STS B 3.4-63 Rev 1, 04/07/95 t 4
~
Insert Actions B and C 4 '
- With IIPSI flow > 210 gpm and suction aligned to the RWT and a RCS vent < 2.6 square inches established, sufficient overpressure protection may not exist and overpressurization may be possible. ,
' The immediate Completion Time to initiate actions to reduce IIPSI flow to 5: 210 gpm reflects the importance of maintaining overpressure protection of the RCS.- g h ~ With one or more HPSI loop MOVs capable of automatically _ aligning HPSI pump flow to the RCS, single failure protection against a HPSI_ pump mass addition transient is lost.' Therefore, action is required to be immediately initiated to restore single failure protection by placing the
- affected HPSI loop MOV handswitch in pull-to-override, or shutting and disabling the affected HPSI loop MOV, or isolating the affected HPSI header flow path.
The inunediate Completion Time to initiate action to restore single failure protection for the
- HPSI pump mass addition transient reflects the importance of restoring single failure protection for low temperature overpressurization mitiga ion.
i-i i 1
,y , <
l10 $
.m.
aAsts c: n , - u w + @ ,
< 8 @gf M g
/f ACTIONS (continued)
The consequences e operat overpressure the Sa 1 events that will (Ref. 6). 4 re severe at lower trature in MODE 6 th
' utred PORY inoperable n M00E 5 or o the Completion two valves o ER/ ALE s atus is 24 hours, Time to restore @
e p.g The 24 hour Completion 31me in restore-4de PORV 4,3 ', MODE 5 or in MODE 6maAG wan*r_heTC$rm is a / - reasonable amount of time to investiga'.e and repair s al L types of PORY failures without exposure to a lengthy period with only one PORY OPERABLE to protect against overpressure
~e 33 i
(i.e.) Vl^ O^ PoAy g g ., fu If
\g _
utred PORVdare ingerabi on a The or if Requi ed g ,{f (gr. cgvlc*M Ml^CP # J k er W l p E. -er/.'. are, at mesociaor ar any reason ther han ond on thr e edT TR on me o Condi ion . 3, f th L Sys em is nope able uch C 114 a r h /A ie"lltreun ce otTf , (,,,,,,1 { go 90M Scd l s h hours. The vent must be sized at least ( T square 64 ...aQa vtnt estabushed withi inches to ensure the flow capacity is greaterlhan that rg4, cr{(U g LiMf#f(A s j required for the worst case mass input transient reasonable during the applicable MODES. I This action protects the RCPB 13 from a low temperature overpressure event and a possible brittle failure of the tor vessel. The Completion Time of hours to depressurtre and vent the RCS is based on the ti @ condition and the relatively low probability of anrequired to place the plant in this overpressure event during this time period due to increased operator awaraness of administrative control requirements.
-~ -- ,,
g m SURVEILLANCE SR 3.4.12.1r3; * : .101. =d "" 2.0.: o W
- REQUIREMENTS To minimite the potential for a low temperature overpressure Q
event by limiting the mass input capability. lony one NP50 m ::. - n m __.,:. , , _ . verified the other p slockedoutwt power LE fl remo and the
=-'=q= ennable of inier
'""" pumpisf-d P-g intn the J Jhg C....., M;} are rendered incapable i HP33 (continued)
.. "N s. *$ ^%
MCL 41 CN_
' mmuttt inj ul,'n~ nw .L w2 me u m al. '
,, 04/J J
J A _ d e a to op hwo,n n ke-LA wLRa u e dJcJn c w k ,niA cJ,j n d @g cu b meS c o pcs ,'n3 b.h o f N N Psr loop Mo n) i s - NGyr v. ~ J . y d ' %', . % .g . >. - >- i
INSERT ACTION 1
-F A /A If the required Actions and associated Completion Times of&- n b (Deannot be met the RCS is required to be depressurized and vented through a vent 21.3 square inches. Thisp(ction must be completed within 48 hours. Thipction along with the OPERABLE PORV restores single failure protection and ensures the flow capacity is -
greater than that required for the worst case mass input transient reasonable during the applicable MODES. This action protects the RCPB from an overpressure event and a possible brittle failure of the reactor vessel, r 1 The Completion Time of 48 hours to depressurize and vent the RCS is based on the time required to place the plant in this condition and in a controlled manner. The probability of
- an overpressure event occurring along with a single failure of the remaining OPERABLE PORV is unlikely. ~
4 Y I i i 1
5 LTOP System B 3.4.12 BASES f,)RVEILLANCE SR 3.4.12. li :: I ' !! 2. Z kEQUIREMENTS
-..? .".:El (continued) of injecting into the RCS through removing the power from h
the b racking the b,reakers out under administrative on to rue 6e es6:ivu UT Lsvr sensrol }, ust t least two independent means prevent a {f o,-(Yg,.,ff)d M ).g.ka Y
/
n pump art s h that a single failure or si e action will i nocompli ruult nedant irdection into the RCS. s may be ugh the pump control : h ktlothJd.4 >4pu11 ch bei lock nd at least one valve ,_ the dis arge placed in f1 (path ing closed. f The 12 hour interval considers operating practice to regularly assess potential degradation and to verify + operation within the safety analysis. SR 3.4.12
.f SR3.h12# quire verifyingtg R S vent,is open 7;Ef.'I$d?5ihi555Edi.'""~ ~~"~~'
s C/nce every 12 hours for a valve that is unlocked open(I el M a
- g. (pnce every 31 days for a valve that is locked open.
The passive vent arrangement must on1 be open to be OPERABLE.-This Surveillance need on1 be perfomed if the vent is being used to satisfy the requirements of this LCO. The Frequencies consider operating experience with 4 alspositioning of unlocked and locked vent valves, respectively, i SR 3.4.12 The PORY block valve must be verified open every 72 hours ') provide the flow path for each required PORV to perform it. function when actuated. The valve can be remotely verified open in the main control roce. The block valve is a remotely controlled, entor operated valve. The power to the valve actor operator is not required to be removed, and the manual actuator is not required - (continued) CEOG STS B 3.4-65 Rev1,04/07/95
LTOP Systes B 3.4.12 BASES i ED - SURVE]LLANCE SR 3.4.12.t (continued) /A'
~
REQUIREMENTS locked in the inactive position. Thus the block valve can Q4 be closed or does notin the event the PORY develop,s excessive leakage closs overpressure event.(sticks open) after relieving an The 72 hour Frequency considers operating experience with accidental movement of valves having remote control and position indication capabilities available where easily monitored. These considerations include the adstatstrative cwtrols over main control room access and equipment control. SR 3.4.12 CD < 31 days to verify and. at necessary, adjust the PORV openPerfo setpoints. The CHANNEL FUNCTIONAL TEST will verify on a monthly LCO limit. basis that the PORV lift setpoints are within the
- not required.PORY actuation could depressurite the RCS and is The 31 day Frequeruq.sp l with equipment reliability, scS cq,.u) experience A Note has been adde performed *fl?}4our after ndicating 3or w.sz decreasing RCS cold leg s required to be &
temperaturetosi *
- F. The test cannot be perfonned untti the RCS is in t e LTOP MODES when the PORY lift setpoint can be reduced to tha LTOP setting. The test must be performed within 12 hours after entering the LTOP MODES.
SR 3 3.12 _ Performance cf a CHANNEL CAL]BRATION o required PORV h each actuation channel is required every months to adjust @ the whole channel so that it responds and the valve opens within input. the required LTOP range and with accuracy to known The no h Frtauency considers operatin equipmentreliabilityandmatchesthetypic!1 e ertence outage schedule. fueling with b (continued) CEOG STS B 3.4-66 Rev 1, 04/07/95
DISCUSSION OF HASES DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM assumed that the turbine has not tripped. Therefore, this statemerrt was deleted from the Specification 3.4.16 Bases, Applicable Safety Analyses Section. 15 ne Calvert Cliffs Specification 3.4.15 Action, when the Dose Equivalent lodine is out oflimit but within limits of the Figure 3.4.15-1, was changed from 48 hours to 100 hours. Based on this change and consistent with the Current Technical Specification requirements, a statement was added to the Bases which requires the cumulative operating time in this condition to not exceed 10% of the unit's total yearly operating time. 16. Specification 3.4.11 Bases (Background Section) states the power-operated relief valve setpoint is above the high pressure reactor trip setpoint, This change will incorporate changes that specify the power-operated relief valve setpoim is equal to the high pressure reactor trip setpoint. his change is consistent with Calvert Cliffs current trip settings.
- 17. The word analog is deleted from places in the Bases where it is used to modify Specifications.
Calvert Cliffs is an analog plant and it is unnecessary to specify this for Specifications.
- 18. His portion of the Applicable Safety Analyses Section of Specification 3.4.12 Bases is being deleted because the pressurizer safety valves do not protect the PN limits at all temperatures above minimum pressurization temperature. This change is consistent with Calvert Cliffs' design.
- 19. NUREG 1432,3.4.2 Bases, Applicable Safety Analyses Section was changed to accommodate that Calvert Cliffs is not standard in its analysis of the minimum temperature for criticality. He analyses assume a minimum temperature consistent with normal hot zero power operation instead of the Technical Specifications limit. This discrepancy was justified by Combustion Engineering Owners Group Task 889, as documented in CENPSD-1026, " Evaluation of NRC Notice 94-75."
- 20. NUREG 1432,3.4.14 Bases, Background Section was changed to delete reference to measuring dew point temperatures and to delete that humidity level is useful as an indirect alarm. Calvert Cliffs does not measure dew point temperature, nor does it use humidity level as an alarm. This change is consistent with Calvert Cliffs' design.
- 21. A requirement was added to NUREG-1432 Bases Section 3.4.3 (Calvert Cliffs ITS Bases Section 3.4.3) Actions A.1 and A.2, which requires the engineering evaluation when P/r limits are exceeded to include a determination of the effects of the out-oflimit condition on the fracture toughness properties of the RCS. This change is a result of moving a requirement out of the Current Technical Specifications into the ITS Bases.
- 22. These changes to NUREG-1432 incorporate Calvert Cliffs specific requirements, allowances, or exemptions currently located in the Calvert Cliffs Current Technical Specification. These items were relocated out of the Current Technical Specification to the ITS Bases. These changes are l consistent with the Calvert Cliffs current licensing basis.
CALVERT CLIFFS- UNITS 1 & 2 3.4-2 Revision 5
NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3;4 -- REACTOR COOLANT SYSTEM 3.4.12 Change L.2 l 1.- Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change replaces specific times for Actions when more than one high pressure l safety injection (liPSI) pump is capable ofinjecting water into the RCS with a requirement to - immediately initiate action to verify a maximum of one llPSI pump only capable of manually injecting into the RCS The proposed change also replaces specific times for Actions when one or more liPSI loop MOVs are capable of automatically aligning HPSI pump flow to the RCS with a requirement to immediately initiate action to verify HPSI loop MOVs are only capable of manually aligning HPSI flow to the RCS, In addition, the change adds requirements, when one
^
or more llPSI pumps are capable of automatically injecting into the RCS, to immediately verify no HPSI pumps are capable of automatically injecting into the RCS. The aidount of time required to take actions, and to restore required coolant injection capability restrictions, is not an initiator of any analyzed event. Restoration of restricted coolant input capability to the RCS within a specified time period may not always be possible, in this situation, the CTS do not provide direction as to the action to take. A . result, the ITS provide Required Actions to immediately commence and continue attempts to restrict coolant input capability to the RCS consistent with assumptions of the LTOP analysis. This change ensures that actions are taken to restrict coolant input capability to the RCS in a timely manner while continuing to provide direction if attempts fall to restore the required coolant input capability restrictions within a specific time period. This change is considered to be acceptable since ITS 3.4.12 ACTIONS A and C do not preclude, but continue to require action to restore restricted coolant input capability
, which will decrease the possibility of overpressurization further as additional coolant input source restrictions are restored. In addition,ITS 3.4.12 ACTIONS A and C require actions to be i
taken immediately, which is defined in ITS Section 1.4 as without delay in a controlled manner. As a result, this change ensures that actions to be taken to restore required coolant input restrictions are immediately initiated rather than allowing up to the CTS Completion Time for satisfying the action and also ensures that direction is provided for restoring all conditions where coolant input restrictions are not satisfied. In addition, the consequences of an event occurring under the proposed action are the same as the consequences of an event occurring under the current action. The change will not alter assumptions relative to the mitigation of an accident or transient. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change ercate the possibility of a new or different kind of accident from any previously evaluated?
The proposed change replaces specific times for Actions when more than one high pressure safety injection (HPSI) pump is capable of injecting water into the RCS with a requirement to immediately initiate action to verify a maximum of one HPSI pump only capable of manually injecting into the RCS. The proposed change also replaces specific times for Actions when one or more HPSI loop MOVs are capable of automatically aligning HPSI pump flow to the RCS with a requirement to immediately initiate action to verify HPSI loop MOVs are only capable of manually aligning HPSI flow to the RCS In addition, the change adds requirements, when one or more HPSI pumps are capable of automatically injecting into the RCS, to immediately action to verify no HPSI pumps are capable of automatically injecting into the RCS. The change will not involve a significant change in design or operation of the plant. No hardware is being added CALVERT CLIFFS - UNITS 1 & 2 3-4-20 Revision 5
NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM to the plant as fart of the proposed change. The proposed che, will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new cr different kind of accident from any accident previously esaluated. j i
- 3. Does this change IFYolve a significant FMlWC11oh ln margin of safety? J De proposed change replaces specific times for Actions when more than one high pressure safety injection (liPSI) pump is capable of injecting water into the RCS with a requirement to immediately initiate action to verify a maximum of one llPSI pump only capable of manually injecting into the RCS. He proposed change also replaces specific times for Actions when one or more IIPSI loop MOVs are capable of automatically aligning HPSI pump flow to the RCS with a requirement to immediately initiate action to verify liPSI loop MOVs are only capable of manually aligning IIPSI flow to the RCS. In addition, the change adds requirements, when one or more llPSI pumps are capable of automatically injecting into the RCS, to immediately action to verify no liPSI pumps are capable of automatically injecting into the RCS. Restoration of restricted coolant input capability to the RCS within a specified time period may not always be possible. In this situation, the CTS do not provide direction as to the action to take. As a result, the ITS provide Required Actions to immediately commence and continue attempts to restrict l
coolant input capability to the RCS consistent with assumptions of the LTOP analysis. This change ensures that actions are taken to restrict coolant input capability to the RCS in a timely manner while continuing to provide direction if attempts fail to restore the required coolant input capability restrictions within a specific time period. This change is considered to be acceptable since ITS 3.4.12 ACTIONS A and C do not preclude, but continue, to require action to restore restricted coolant input capability which will decrease the possibility of overpressurization further as additional coolant input source restrictions are restored. In addition, ITS 3.4.12 ACTIONS A and C require actions to be taken immediately, which is defined in ITS Section L4 as without delay in a controlled manner. As a result, this change ensures that actions to be taken to restore required coolant input restrictions are immediately initiated rather than allowing up to the CTS Completion Time for satisfying the action and also ensures that direction is provided for restoring all conditions where coolant input restrictions are not satisfied. Therefore, the change does not involve a significant reduction in a margin of safety. 3.4.12 Change L.3
- 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change deletes the requirement to perform a Channel Functional Test on the PORVs actuation channel at least 31 days prior the entering the LTOP System Modes of Applicability. This is being replaced with a requirement that allows a 12-hour delay once in the LTOP Modes of Applicabi!ity before the Channel Functional Test is required to be performed. A delay in performing a Surveillance test on the LTOP System is not an initiator of any analyzed event. Allowing 12 hours aller entering the LTOP Mode of Applicability for plant conditions to stabilize ensures more accurate test results. The change will not alter assumptions relative to the mitigation of an accident or transient. Therefore, the change will not involve a significant increase in the probability or consequence of an accident previously evaluated. CALVERT CLIFFS - UNITS I & 2 3-4-21 Revision 5
NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM
-ieg temperature s 365'F for Unit I and s 301'F for Unit 2, and Modes 4,5, and 6. nis change essentially deletes the requirement for the Specification to be applicable when the reactor is defueled. The LTOP System is not needed to mitigate any analyzed event when the reactor is defueled. Adequate remedial action is still required to be taken if any pressure / temperature limits are exceeded per the RCS Pressureffemperature Limits Technical Specification.
Herefore, the change does not involve a significant reduction in a margin of safety. 3.4.12 Chnnce LS
- 1. Does the change involve a signilleant inercase in the probability or consequences of an i accident previously evaluated?
)
This change removes the explicit requirement, in the event IIPSI flow exceeds 210 gpm, to verify that the flow condition did not result in the violation of RCS pressure /smperature limits. This verification is not considered in the initiation of any previously analyzed accident. Therefore, this change does not significantly increase the frequency of such accidents. The explicit requirement, in the event IIPSI flow exceeds 210 gpm, to verify that the flow condition did not result in the violatica of RCS pressure / temperature limits, is not necessary to be included in the Calvert Cliffs ITS because the requirements of ITS 3.4.3 require RCS pressure / temperature limits to be met at all times, in ITS, LCOs must be continually met during i the Applicability (per ITS LCO 3.0.1) Rus ifIIPSI flow exceeds 210 gpm and this results in the RCS pressure / temperature limits not being met, LCO 3.4.3 would not be met and appropriate ITS 3.4.3 ACTIONS must be taken. In general, this type of requirement is addressed by plant specific processes which continuously monitor plant conditions to ensure that changes in the status of the plant that require entry into ACTIONS (as a result of failure to satisfy an LCO) are identified in a timely manner. This verification is an implicit part of using Technical Specifications and determining the appropriate Conditions to enter and Required Actions to take in the event of a failure to meet an LCO . In addition, plant status is continuously monitored by control room personnel. The results of this monitoring process are documented in records / logs maintained by control room personnel. The continuous monitoring process includes re-evaluating the status of compliance with Technical Specification requirements when the plant conditions change. Therefore, the explicit requirement, in the event HPSI flow exceeds 210 gpm, to verify that the flow condition did not result in the violation of RCS pressure / temperature limits is considered to be unnecessary for ensuring compliance with the applicable Technical ; Specification requirements. The status of compliance with Technical Specification requirements will continue to be monitored to assure the potential consequences are not significantly increased. Therefore, this change does not significantly increase the probability or consequences of any previously analyzed accident.
- 2. Does the change ercate the possibility of a new or different kind of accident from any previously evaluated?
This change removes the explicit requirement, in the event IIPSI flow exceeds 210 gpm, to verify that the flow condition did not result in the violation of RCS pressure / temperature limits, The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. In addition, the change does not introduce any new accident initiators. The status of the plant and compliance with Technical Specification requirements will continue to be monitored to assure the possibility for a new or different kind of accident is not created. Therefore, this CALVERT CLIFFS - UNITS 1 & 2 3-4-23 Revision 5 J
NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3A - REACTOR COOLANT SYSTEM change does not create the possibility of a new or different kind of accident from any previously analyzed accident.
- 3. Does this change involve a significant reduction in margin of safety?
This change removes the explicit requirement, in the event HPSI flow exceeds 210 gpm, to verify that the flow condition did not result in the violation of RCS pressure / temperature limits, ne verification of the status of compliance with Technical Specifications is an implicit part of using Technical Specifications and determining the appropriate Conditions to enter and Actions to take in the event of a failure to meet a Surveillance Requirement. In addition, plant status is continuously monitored by control room personnel. He results of this monitoring process are documented in records / logs maintained by control room personnel. The continuous monitoring process includes re-evaluatingJtho~ status of compliance with Technical Specification requirements when the plant conditions change. Herefore, the explicit requirement, in the event HPSI flow exceeds 210 gpm, to verify that the flow condition did not result in the violttion of RCS pressure / temperature limits is considered to be unnecessary for ensuring compliance with the applicable Technical Specification requirements. The status of compliance with Technical Specification requirements will continue to be monitored to assure the appropriate previously approved actions are taken in the event of a failure to meet Technical Specification requirements. Therefore, this change does not involve a significant reduction in the margin of safety. MJ3 Chance L.1
- 1. Does.the change involve a signifleant increase in the probability or consequences of an accident previously evaluated?
Current Technical Specification SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d are being eliminated. This is acceptable because: a) CTS SRs 4.4.6.2.a.1,4.4.6.2.b, and 4.4.6.2.d only provide gross indication of leakage; they do not provide a method for quantifyinF the leakage. Current Technical Specification SR 4.4.6.2.c provides the method for quantifying RCS leakage; it has been retained as ITS SR 3.4.13.1; b)ITS 3.4.14 will contain operability requirements for the containment atmosphere gaseous and particulate monitors, improved Technical Specification SR 3.4.14.1 requires a channel check of the required containment atmosphere radioactivity monitor to be performed every 12 hours, improved Technical Specification SR 3,4.14.1 is essentially equivalent to CTS SR 4.4.6.2.a.1; c)ITS 3.4.14 will contain operability requirements for the containment sump level alarm system. An operable containment sump level alarm system will provide continuous monitoring of the sump level. Hus, CTS SR 4.4.6.2.2.b is superfluous; d) the reactor vessel head closure seal leakage detection system does not necessarily relate directly to the leakage requirements. Neither NUREG-1432 nor the CTS require this indication to be operable in the leakage detection instrumentation specifications (NUREG-1432 LCO 3.4.15 and CTS LCO 3.4,6.1); thus, it is not ceded to support this specification; and e) prompt indication of RCS leakage v,01 be provided w the operators via various alarms (e.g., containment sump level alarm and high radiation alarm trum the containment atmosphere radiation monitoring system). The proposed changes do not alter assumptions relative to the mitigation of an accident or transient, nor do they significantly affect initiators or mitigation of analyzed events. Failure of an RCS leakage detection system is not an initiator of any analyzed event. Also, the elimination of these SRs do not affect the ability to quantify RCS leakage. Therefore, the proposed changes CALVERT CLIFFS - UNITS I & 2 3-4 24 Revision 5
- 40. The proposed deviations of TSIT-27 were removed. This TSTF has not been approved by the NRC. The following changes were required to remove this TSTF: 1) the markups for CTS 4.1.1.5.a and 4.1.1.5.b were revised to reDect that the current SRs were being maintained, except the frequency for CTS 4.1.1.5.a is being extended to 30 minutes; 2) DOC L.1 for ITS 3.4.2 and its associated NSilC were revised to reDect the change to CTS 4.1.1.5.a;
- 3) DOCS A.3 and L.2 (and its associated NSliC) for ITS 3.4.2 were eliminated, because they are no longer used; 4)ISTS markup for ITS SR 3.4.2.1 was revised to reDect CTS SRs 4.1.1.5.a and 4.1.1.5.b, except for the frequency of CTS SR 4.1.1.5.a; 5) the deviation to the ISTS wasjustined by JFD 28 to Section 3.4; and 6) the ISTS Bases markup for ITS SR 3.4.2.1 was revised to be consistent with the revised ITS SR.
Additionally, an internal review identified that the nominal T.v, for making the reactor critical , was not correct in the ISTS Bases markup for ITS 3.4.12. The value is 532*F, not 525'F. This i issue has been corrected in the ISTS Bases markup for ITS 3.4.2.
RCS Minimum Temperature for Criticality 3.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I SR 3.4.2.1 Verify RCS T.,, in each loop 2 515'F. Once within 30 minutes prior to reaching criticality AND
..... NOTE - -- E Only required to be performed when RCS T.,,is
< 525'F 30 minutes thereafter i
[ CALVERT CLIFFS - UNITS 1 & 2 3.4.2-2 Revision 5 5
l l RCS Minimum Temperature for Criticality. B 3.4.2 h B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.2 RCS Minimum Temperature for Criticality BASES BACKGROUND Establishing the value for the minimum-temperature for reactor criticality is based upon considerations for: -
- a. Operation within the existing instrumentation ranges and accuracies;
- b. Operation within the bounds of the existing accident analyses; and
- c. Operation with the reactor vessel above its minimum nil ductility reference temperature when the reactor is critical.
The reactor coolant moderator temperature coefficient used in core operating and accident analysis is defined for the l normal operating temperature range as specified in the operating procedures. The Reactor Protective System receives inputs from the narrow range hot and cold leg temperature detectors,-which have a range of 515'F to 665'F and 465"F to 615'F, respectively. The RCS temperature is controlled using inputs of the same range. Nominal T.y for making the reactor critical is 532'F. Safety and operating. 5-analyses for lower temperature have not been made. J
-APPLICABLE There are no accident analyses that dictate the minimum SAFETY ANALYSES temperature for criticality, but all low power safety analyses can accommodate initial temperatures near the 515'F limit (Refs. I and 2).
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.2-1 Revision #5-1 o
RCS Minimum Temperature for Criticality B 3.4.2 BASES The RCS minimum temperature for criticality satisfies 10 CFR 50.36(c)(2)(ii) Criterion 2. -LC0 The purpose of the LCO is to prevent criticality outside the normal operating regime and to prevent operation in an unanalyzed condition.
~
p i-APPLICABILITY The reactor has been designed and analyzed to be critical in MODES 1 and 2 only and in accordance with this specification. Criticality is not permitted in any other MODE. Therefore, this LCO is applicable in MODE 1 and MODE 2 when K gr 2 1.0. ACTIONS b_d If T.,, is below 515'F, the plant must be brought to a MODE in which-the LCO does not apply. To achieve this status, the plant must be brought to MODE 2 with K gr < 1.0 within 30 minutes. Rapid reactor shutdown can be readily and practically achieved-within a 30 minute period.- The allowed time reflects the ability to perform this action and to maintain the plant within the analyzed range. SURVEILLANCE. SR 3.4.2.1 REQUIREMENTS-T.,, is initially required to be verified 2 515'F within 30 minutes prior to reaching reactor criticality, then T.,, is required to be verified 2 515 F every 30 minutes. The 30 minute time period .is frequent enough to prevent 6 inadvertent violation of the LCO. The second frequency is modified by a Note which states that the Surveillance is only required to be performed when RCS T.,, is less than 525'F.. This provides a reasonable distance to the limit of 515'F . Adequate time will be available to trend RCS T.,, as CALVERT CLIFFS - UNITS 1 & 2 B 3.4.2-2 Revisiong6
RCS Minimum Temperature for Criticality
- - B 3.4.2 t
1- - BASES . ' it approaches 515'F, and take corrective action (s) prior-to exceeding the limit. T
- REFERENCES 1. UFSAR, Section 14.
- 2. CENPSD-1026. Evaluations of NRC Information -
, Notice 94-75 x * - s i. J i e 4 J i 1
)
4 I 4 1 i CALVERT CLIFFS-- UNITS 1 & 2 B 3.4.2-3 Revisiong5-4 4 __ _ _ _ _ ___ . ____ _ _ _ _ . . _ _ _ . ._- - . _ _ . _ _ . , _ . _. _ , _., . = _ . . _ _
speif*A*^ 3 4' 2-M^? ,
??Y -
3,4 -W474 RE r . m - ........ SYSTEMS A'
-?/'.1.1 , _20^.?!0.N 00?a.^L g nimum Temeerature For Criticality LIMITING CONDITION FOR OPERATION LC' 3,4,2. 3.1.10 The Reactor Coolant System lowest operating loop temperature (T.,,)
shall be t $15'F when
.z- the reactor is critical. :-.~..
APPLICABillTY: MODES 1,and 2 with K,n 11.0. l A CT'8 M N: With e Jteactor Coolant System operatina loop temperature
.4 T h, < 515'F. ff = = '
_ _ _ _ 3 within the neXt M ""- " ' im;; . "."- ;; d ...;,.. G be in minutes. h 0 MAehEA)A k.cf 41.o h SURVEILLANCE REQUIREMENTS 5.A 3'42'I . 4drbfr The Reactor Coolant System temperature (T,,,) shall be determined to be 1515'Fs
- a. -Within minutes prior to achievin; reactor criticality, and
- b. At least once per,30 Ininutes when the reactor is critical and the Reactor. Coolant System T.,, is less than $25-f c ' ' b
' dh I
CALVERT CLIFFS - UNIT 1 3/4 1-9 Amendment No. 186 pa y I of I 4
$ p oe .N . c ,4.on 3A 7 h'\ --
gg _c.coLhRV A.I
- 3. I 4/4rt HAff!Y!fY t5ft0L SY$fDi$
4/2 11 rfaiim G,um intenan Tennerature For triticality 3.92 LIMIY1116 Cele!T!aN Fet 9PttAY!all LCO \ v ,v. T 4. 7 'O.;.1.G The when thall be t $15'r Reactor Coolant ${or is critica{.stes lowest the rest -+ o rating loop temperatutt}f,,,) - APPL 1 tab 1L11Y: IIDDES 1 and 2 with k,n k 1.0. l 1 A('llotQ Eh2!!:
- 515'F'With " t = ai Reactor Coolant System
;; ; toperating loop temperature (O, )
T A ithin the% 0
; dt'tnutes
.'!:it #O'u -* b' in '
l l tA06E '2 Ji% V ccc 4 \ . Q s a rittanet7 r pitwis h. SR
.I. 4 . 2. I
' 4drh4 The Reactor Coolant System temperature (f.,,) shall be determined to be t 516'rt g I
- a. Within 4@ minutes prior to achieving reactor criticality, u,d
'b. At least once per 70 minutes when the reactor is tritical anc the Reacter Coolant Syltem T,,, is less than $1F. g i
l ( CALVERT CLIFrs
- WIT 2 3/4 1 9 Amen k nt No. 16)
I)lSCUSSION OF CHANGES SECTION 3.4.2 - HCS MINIMUM TEMPERATURE FOR CRITICALITY A1)A11NISTRATIVE CIRNGES A.1 The proposed change will reformat, renumber, and reword the existing Teshnical Specifications, with no change ofintent, to be consistent with NUREG 1432. As a .esult, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs ITS development, certain wording preferences or conventions were adopted which resulted in no technical changes to the Technical Specifications. Additional information may also have been added to more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional information does not change the intent of the current Technical Specifications. The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. '# A.2 Current Technical Specification 3.1.1.5 Actions require RCS Tr, to be restored in 15 minutes, and the unit to be in hiode 3 in the following 15 minutes. Improved Technical Specification 3.4.2 Action A will require the unit to be in biode 3 within 30 minutes. The CTS statement to restore . . ." is being deleted because the option to restore always exists. The deletion of a requirement that is always implied in the ITS constitutes an adrainistrative change. 'ihls change is consistent with NUREG 1432. A.3 Not used. l A.4 Current Technical Specification 3.1.1.5 requires the plant to be in hiode 3 If the RCS average Temperature is not 2 515'F in hiode 1 or biode 2 with Na 21.0. Ilowever, per LCO 3.0.1, the plant is only required to be taken outside the blode of Applicability, which would be biode 2 with Ng < l.0. Improved Technical Specifications require the plant to be taken to hiode 2 with Ng < l.0 in this situation. Therefore, changing the requirement for the plant to be in hiode 2 with Ng < l.0 is consistent with CTS requirements and is considered an administrative change. This change is consistent with NUREG 1432, Generic Change TSTF 26, TECilNICAL CilANGES MORE RENIRICTIV.E None. TECllNICAL CIIANGES - Rl: LOCATIONS None TECllNICAL CilANGES . MOVEMENT OF INFORMATION TO LICENSEE CONTROLLEE DOCUMENTS None TECIINICAL CIIANGES - LFSS RESTRICTIVE L.1 Current Technical Specification SR 4.1.1.5.a requires RCS T.,, to be verified within 15 minutes prior to achieving reactor criticality. This requirement will be relaxed to CALVERT CLIFFS - UNITS 1 & 2 3.4.21 Revision 5
IllSCUSSION OF CilANGES SECTION 3.4.2 - RCS MINIMUM TEMPERATURE FOR CRITICALITY 30 minutes in ITS SR 3.4.2.1. It will require RCS T.,, to be verified within 30 minutes of
- achieving reactor criticality. Allowing the Surveillance to be performed 15 minutes earlier la reasonable because it is within the same Frequency the Surveillance is perfonned during operation. Reactor Coolant System tempcrature will still be verified to be within limits prior to achieving reactor criticality. The frequency of ITS SR 3.4.2.1 is adequate to detect a significant temperature change considering the volume of the RCS, the severity of a cooldown transient necessary to effect a significant temperature change and the likelihood that such a transient will be immediately self revealing. Thus, the proposed change is acceptable.
L.2 Not used. l
.,....;1 ...
t CALVERT CLIFFS . UNITS 1 & 2 33.2 2 Revision 5
-NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM 2.
Does the change create the possibility of a new or different klad of accident from any previously evaluated? He proposed change decreases the Surveillance Frequency from 18 months to 24 months for the total flow rate measurement. nis change does not affect the probability of an accident. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. ne proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction la margin of safety?
ne proposed change decreases the Surveillance Frequency from 18 months to 24 months for the total flow rate measurement. Decreasing the Frequency from 18 months to 24 months ensures that the Surveillance is performed when a change in RCS flow rate is most likely to have occurred (following a refueling outage when the core has been altered). Any significant RCS flow rate change throughout the fuel cycle is unlikely to go undetected because of the shiftly l RCS flow rate verification. Therefore, the change does not involve a significant reduction in a margin of safety. l M2_ Change 11 l 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change increases the maximum time prior to criticality that the average RCS temperature must be verified from 15 minutes to 30 minutes. He Frequency of measurement of RCS minimum temperature for criticality is not an initiator of any analyzed event. Allowing the Surveillance to be performed 15 minutes earlier is reasonable, because it is within the same , Frequency the Surveillance is performed during operation. Reactor Coolant System temperature will still be verified to be within limits prior to achieving reactor criticality. He frequency of ITS SR 3.4.2.1 is adequate to detect a significant temperature change considering the volume of the RCS, the severity of a cooldown transient necessary to effect a significant temperature change and the likelihood that such a transient will be immediately self revealing. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated? The proposed change increases the maximum time prior to criticality that the SR must be met from 15 minutes to 30 minutes. He change will not involve a significant change in design or operation of the plant. No hardware is being added to the plant as part of the proposed change. The preposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 347 Revision 5
NO SIGNIFICANT llAZARDS CONSIDERATIONS SECTION 3.4 - REACTOR COOLANT SYSTEM
- 3. Does this change involve a significant reduction in margin of safety?
The proposed change increases the maximum time prior to criticality that the SR must be met from 15 minutes to 30 minutes. Als change will make the time to verify average temperature prior to criticality and after criticality consistent. The increased time will continue to provide assurance that average temperature is within limits prior to achieving reactor criticality. Herefore, the change does not involve a signincant reduction in a margin of safety. ,LL2 Chamme Ia Not used. l 3.4.3 Channe L.1 - 1, Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? He proposed change increases the amount of time specifically allowed to perform an evaluation to determine if the RCS is acceptable for continued operation, following a violation of the pressure / temperature (P r) limits, from no specified time allowed (which is assumed to require an immediate evaluation) to 72 hours. The P/r limits are not derived from design basis accident analyses. Hey are prescribed during normal operation to avoid encountering pressure, temperature, and temperature rate of change conditions that might cause undetected flaws to propagate and cause nonductile failure of the reactor coolant pressure boundary, which is an unanalyzed condition. He time required to evaluate RCS when the pressure or temperature limits have been exceeded is not an initiator of any analyzed event %e out of limit condition is required to be restored in 30 minutes or a shutdown must commence. Also, the time allowed for the evaluation is long enough only to evaluate mild violations, which most likely will prove the RCS to be acceptable for continued operation. He change does not alter assumptions relative to the mitigation of an analyzed event. The proposed changes do not significantly affect initiators or mitigation of analyzed events, and therefore do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the change create the possibility of a new or different kind of accident from any previously evaluated?
The proposed change increases the amount of time specifically allowed to perform an evaluation
*o determine if the RCS is acceptable for continued operation, following a violation of the P/f limits, from no specified time allowed to 72 hours. While a nonductile failure in the RCS is an unanalyzed condition, the unit is required to restore the P/r limits within 30 minutes. The 72 hour evaluation prior to shutting down is only enough time to evaluate mild violations. As a result, this change will not allow continued operation following a significant violation of the P/T limits. The change will not involve a significant change in design or operation of the plant.
No hardware is being added to the plant as part of the proposed change, The proposed change will not introduce any new accident initiators. Therefore, the change does not create the . possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does this change involve a significant reduction in margin of safety?
The proposed change increases the amount of time specifically allowed to perform an evaluation to determine if the RCS is acceptable for continued operation, following a violation of the P/r 4 CALVERT CLIFFS UNITS 1 & 2 348 Revision 5
4rs> RCS Mintmun Temperature for Criticg1] 3.4 REACTOR COOLANT SYST[M (RCS) ' 3.4.2 RCS Minimus Toeperature for Criticality 313 5) LCO 3.4.t toch RCs loop average.tomperature (Tm ) shall be,k .
^"""""'
=g 2:: 2:g;m: z h g )
ACTIONS CON 01110N REQUIRED ACTION COMPLETION TIME hMhA. T I in one or more RCs A.! Be in M00[ s not within . 30 minutes z, Q:w A H.g --- yset LG
$_URVE1ltANCE REOU!REMENTS
$URi[lLLANCE FREQUENCY (4.t.l.5)5R 3.4 21 Vertry Rcs im _in each loop 3 , O y3 .
O ne_ J,kslg 30 m nuk(4 prior $c : udi r /
/ t.rl W cc I, L) ~J [
s .___senc__.... .
) nlyre b (op ., &q v , r u0 % w L., Ra k s'
%5 l r <fLC *F _
w ,w. A -~ g
\, .- . ._ /
4
DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.4 - REACTOR COOLANT SYSTEM
- 27. NUREG 1432 Sli 3.4.9.2 requires the verification of the pressurizer heater capacity once pe 92 days. Calvert Cliffs ITS will require verificat!an of the pressurizer heater capacity once per l 24 months. Calvert Cliffs Current Technical Specification does not contain this SR, thus this is a new SR for Calvert Cliffs, llowever, the test the SR will require is currently being performed every refuele interval (i.e., every 24 months). An historical review of maintenance history has determined that no failures of the test have occurred in the past 5 years. Herefore, the Calvert Cliffs ITS will continue to require the test every 24 months consistent with current practice. In addition, the 24 month interval is consistent with NUREG 1432, Generic Change TSTF 93.
- 28. He Mode of Applicability for NUREG 1432 LCO 3.4.2 is Mode 1 with T.,,in one or more RCS loops < [535'F] and Mode 2 with T.,, in one or more RCS loops < [535'F] and Nrr 21.0.
. e .NUREG SR 3.4.2.1 requires verifying RCS T.,,in each loop to be 2 [520'F) every 30 minutes m a thereafler. NUREG 1432 SR 3.0.4 requires surveillances to be met prior to entering the Mode of ,
Applicability for an LCO. He requirements regarding RCS minimum temperature for criticality should be applicable whenever the reactor is critical and not just below a certain temperature. ne following changes were made to NUREG 1432 Specification 3.4.2: a) the Applicability of , ITS 3.4.2 was revised to be Mode I and Mode 2 with Nrr h 1.0; b) an additional frequency was added to ITS SR 3.4.2.1 to require the verification of T,9 prior to reaching criticality; and c) the current frequency was modified by a note which addresses the temperature requirements provided in the Applicability of NUREG 1432 LCO 3.4.2; thus, aller achieving criticality, the SR will only be required to be perfonned when RCS T.,, is less than $25'F. The revised l ' Applicability of ITS LCO 3.4.2 is the same as the Applicability of CTS LCO 3.1.1.5. It is broader than the Applicability provided in NUREG 1432 LCO 3.4.2. With the revised j Applicability, ITS 3.4.2 will require cach RCS loop average temperature to be 2 515'F in Modes I and 2 with Ntr 21.0. The revised frequency ofITS SR 3.4.2.1 requires verification of RCS 1 T.,, to be performed: a) once within 30 minutes prior to reaching criticality; and b) at once per 30 minutes thereafter whenever RCS T.,,is less than 525'F. These frequencies are consistent with the intent of NUREG 1432 SR 3.4.2.1 and CTS 4.1.1.5.a and 4.1.1.5.b.
- 29. NUREG 1432 SR 3.4.1.4 requires the RCS total flow rate to be verified within limits by precision heat balance. Calvert Cliffs ITS will require the RC.', total flow rate to be determined by measurement. The Calvert Cliffs ITS will not specify the method by which to verify the RCS total flow rate. Calvert Cliffs does not use the precision heat balance method of verifying RCS total flow rate. Calvert Cliffs current Technical Specification requires the measurement of the total flow rate. Thus, this deviation from NUREG 1432 is also consistent with the Calvert Clift:
current licensing basis.
- 30. Improved Technical Specification SR 3.4.1.3, which verifies RCS total flow rate, contains a Note which states, " Required to be met in MODE 1 with all RCPs running" TSTF 62 revised the
. Note to read "Only required to be met in MODE 1" with the justification that all RCPs are required to be running in MODE 1. However, the Applicability of LCO 3.4.1 is Mode 1. Therefore, a Note which states, "Only required to be met in MODE 1" is superfluous. He NOTE has been deleted, TSTF 62 was approved by the NRC on September 18, 1996. A new generic change will bc
,. proposed to delete the Note from NUREG 1432.
CALVERT CLIFFS - UNITS 1 & 2 3.4 7 Revision 5
RCS Ninimum Temperature for Criticality B 3.4.2 5 3.4 REACTOR COOLANT $VSitM (RCS) S 3.4.2 RC$ Minimum temperature for Criticality Basts SACKGROUND Estabitshing the value for the minimum toeperature for reactor criticality is based upon considerations fort
- a. Operation within the existing instrumentation ranges and accuracles:
~
bi" Operation within the bounds of the existing accident analysest and
- c. Operation with the reactor vessel above its minimum nil duett 11ty reference temperature when the reactor is critical. o h + h l'In i
4 p p,,, The reactor coolant moderator temperature coefficient used fema in core operating and accident analysis is ^ - E ^- J'a ruk for the normal o>erating temperature range 9 "':!b b defin9d T ^7,. (adc) une neactor Pro 0pction System receives inputh from the narrowrangehotologtemperaturedetectors,whichhavea
~
f.h rance of- ^^^ lhe RCS S:- ggg'r 44, 46 6 % Nom (T 7n)alforTlicontrolled using inputs ame r4nof
- e. the:sr ; temperature@ (,
* ** d 4G M 5 making the reactor critical is .
83 3, *F d j Safety anEoperating analyses for lower temperature have 4/cT, regch*ll been made. o
-=
APPLICABLE . There are no accident analyses that dictate the minimum
$AFETY ANALY$t$ temperature for criticality, but all low power safair analyses ginttial_tesiperatsres near the (436FF limit h Q (Ref.}}. g.24,QQ --
The RCS minimum temperature for criticality satisfies ' Criterton 2 of the NRC Policy Statement. . LCO The purpose of the LC0 is to prevent criticality outside the normal operating regimep5N2FMTQ-~ and to prevent / operation in an unanalyzed conditio% c-(continued) CEOG STS B 3.4-7 Rev 1, 04/07/95
RCS Minimus Temperature for Criticality B 3.4.2 8ASES LC0 (TheLCO only applicable (continued) reason e distance to limit o[ftw $30
- rovidesaD
'F anallows adog e time to tre 1his tact ns prior to en ts approach and ake corrective Ing the 11 alt. .
APPLICABILITY MODES specification. 1 and 2 only and in accordance with thisThe reacto MODE. Therefore, this Lgis applicablet in MODE lCriticality and '. . . s #, 4u- ris not perm n oIc $ Itt t e turi 11 t Nnitor g is required .
)* . The)'
no 1 temperature of below a T of i r= .n1 tvein ., is maintaNed by[51 t 5 team Dump ACTIONS L1 ' If T MODETnwhichtheLCOdoesnotapply.is status, the To achieve this b belov4440FF, the plant must be . 30 minutes. plant must be brought to MODE X withu n I Rapid reactor shutdown can be readliy and practically achieved within a 30 minute period. The allowed a ga4 % time reflects the ability to perform this acti 8,& # /' pF F.fo , maintain the plant within the analyzed range. on and to
+x x
SR 3.4.2.1 Q ls isskwI SURVEILLANCE b e- V trl o'< 2 %$ 'yE lI j erkviecs s.s0 & i REQUIREMENT 5 in- rior 4T isrequhed$o~bedified1Oe 1$7 30 minute time period is frequ(ent]enoughII+utes. 520et*Pevery'30 INtc. no nrevent ~Q ' h inadvertent violation of the LC0 frequired whenever the reactor 'elhelurveillanceisl n l below 535)*F,tinpracticet critical and temperature is appr ritte dur,ing the pert surveillance is most /J\. gr ical. when the reactor is ght
)
REFERENCES 14 1. h"@SAR,sectionJag[. g CEOG STS B 3.4 8 Rev1,04/07/95 s , dh
- 41. . ihe NRC requested additional justification for changing the 17t equency of CTS 4.2.5.2 from 18 months to 24 months (ITS 3.4.1 Comment 2). Additional justification has been provided in DOC 1,.3 for ITS 3.4.1. This change is not beyond the scope of the 11S process. Ihtending surveillance frequencies from 18 to 24 months has been conducted as part of the ITS process.
RCS Pressure. Temperature, and Floa DNB Limits B 3.4.1 BASES SR 3.4.1.3 The 12 hour Surveillance frequency for RCS total flow rate is performed using the installed flow instrumentation. The 12 hour Frequency has been shown by operating experience to be sufficient to assess for potential degradation and to verify operation is within safety analysis assumptions. l l SR 3.4.1.4 i Measurement of RCS total flow rate is performed once every 24 months. This verifies that the actual RCS flow rate is f within the bounds of the analyses. The Frequency of 24 months reflects the importance of verifying flow after a refueling outage where the core has been altered, which may have caused an alteration of flow resistance. REFERENCES 1. UFSAR. Section 14.1.2 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.1-5 Revision ES-
Spee<{nsben J. 4./ M MIT$~ ~ .- _n,,- -
" g',
3.4.1 3/4.2.6 .g gg g g g g R u P,a ,.ce, % p A .<<.,c 4 Flu Ser a bre F*
- A**'*h }}"5,L}@ L; &"
~'-
LIMITING CONDITION FOR OPERAT10N Lc0 3 4.1 h%4 The following DNB related parameters shall be maintained within the limits shown: b 4. 5 t r trs el.u ss, e o f Cold Leg Temperature s $48'r i st. /. Pressurizer Pressure 2 2200 psis' ' q l . d c.
, yy(q et' Reactor Coolant System total Flow Rate 2 370.000 gim l
- d. AXIAL $NAPt !NDEX, THERNAL POWER as specified in the COLR.
l APPLICABillll: MODE !. ta9..o th 44 4".'" g ACllMa With any of the above parameters exceeding its limit, restore the k trameter to within its limit within 2 hours or reduce THERMAL POWER to est than 5% of RATED THERMAL POWER within the next ours. SURYt!LLANCE REQUIREMENTS
*MtI 4rer!b4 tach of the erame
{ Q ,,y at least once per 12 bours.ters shall be verified to be within their limits l 5" 3. 4 I 4 .4,W The Reactor Coolant System total flow rate shal be determined to be within its limit by measurement at least once per months. 24 b
- b I
~6 Limit not applicable during either a THERMAL POWER ramp increase in
'* excess of 5% of RAT [0 THERMAL POWER per minute or a THERMAL POWER step nerease of greater than 10% of RAT [0 THERMAL POWER.
CALYtRT CLIFFS - UNIT 1 3/4 2 8 Amendment No. 186 py l&I
PFC 8 es 4.an ~3. $. l l
~ - - : _
O' (9J6Cl?%N-AM g,4 4/4rt- 70WIR distr!auf!Du Ltitifsi' ~ S YSTEM (RCSi) A,g ~ 3,4. l 3/4.2.6 .!ma.htstuu. Rc.s A ,u . , <, T~ r =6 s e , .m.1 Fl. ~ O.p. < 4 , e i% ~ th e 5 , = < < G o. Im LIMITING CONDITION FOR OPERATION NG)L.y.j Grftt- The following DN8 related parameters shall be maintained within the limits shown: l b p. Cold Leg Temperature s $48'F 4 et 0.'auq W CA t. Pressurizer Pressure k 2200 psia \ .. Q 3.1.f
- c. Atoctor Coolant System Total Flow Rate 2 370.000 ppe " M Wd }* b *
- d. AX1AL SRAPC INDEX. THERNAL D0VER as specified in the COLR l
APPtlCABILITY: MODE 1. A c 'l in t.1 B Ache,o,A ACIl.pff: With an of the above parameters exceedin ts limit &- gess than 5% of RATED intRNAL POWER ours. 0 Wit within to the nextar me f0RVEILLANCE REQUIRthENTS l
,' 4 , 't , 4,4rGr4 g 3 4,i, at least once per 12 pours.Each of the arameters shall be verified to be within their limits l 4.2.5.2 The Reactor Coolant System total flow rate shall be detemined tg
@ 3 4 g,4 be within its limit by measurement at least once per.Hr months.f
-h-A f^Let 1Pc Limit not applicable during elg. \ er THERNAL POWER ramp increase in excess of 5% of RATED THERNAL POWEP per minute or a TNERNAL POWER step increase of greater than 1M of RATED THERNAL POWER.
CALVtRT CLIFFS - UNIT 2 3/4 2 8 Amendment No. 163
DISCUSSION OF CIIANGES SECTION 3.4.1 - RCS PRESSUk4E, TEMPERATURE, AND FLOW (DNZ) LIMITS performed aner a refueling outage v'nen the RCS flow is most likely to have changed. A review of 5 years of maintenance nistory found no failures of this surveillance test. The Current Technical Specifications (CTS) Frequency of 18 months will not coincide with the test to be perfonned aner each refueling outage. 1herefore, this change reflects the importance of performing this test aner a reft.eling outage. This change is consistent with NUREG 1432. b^4 .c au . CALVERT CLIFFS - UNITS 1 & 2 3 A.1-2 Revision 5
- 42. Discussion of Change L.1 was revised to provide additional justincation for allowing a steam generator at a leve' of t 50 inches as a second method for removing decay heat. This change has been made to respond to an NRC comment (ITS 3.4.7 Comment 1).
l I
DISCUSSION OF CHANGES SECTION 3A,7 - RCS LOOPS . MODE 5, LOOPS FILLED alignment and indicated power available to the required SDC pump and valves that are not in operation. LA.3 Current Technical Specification SR 4.4.1.3.3 requires the coolant loops to be verifled in operation and circulating reactor coolant. The requirement to circulate reactor coolant is being rnoved to the ITS 3.4.7 Dases. Specific requirements for verifying that the reactor coolant loop is in operation will be located in the Bases or plant procedures, as appropriate. Any changes to the Bases w811 be in accordance with the Bases Control Program in ITS Chapter 5.0, and any changes to plant procedures will be in accordance with the Calvert Cliffs change control process. De Bases Control Program and the Calvert Cliffs change control process will ensure that changes to this requirement will receive an appropriate
,y . review. His change la consistent with NUREG 1432. - gp . ea TECilNICAL CIIANGES . I rER prRTRICTIVE L.1 Current Technical Specification LCOs 3.4.1.3.a.1 and 2 require the reactor coolant loops, thelt associated sos, and at least one associated RCP to be Operable if used to satisfy the LCO. Improved Technical Specification 3.4.7 will only require that the secondary side water level of each SO be a .50 inches if used as the backup system to the required.SDC train.
This is acceptable in Mode 5 with the loops filled because even though the sos cannot produce steam, they are capable of being a heat sink due to the large contained volume of secondary side water. Forced cooling using the RCPs is not required because natural circulation occurs, which is sufficient to remove the small heat load in the reactor core until a SDC train can be made available. A plant specific calculation was developed to verify that the sos could be used for decay heat removal. The calculation was performed in response to I NUMARC Ouldance Document 9106, Ouldelines for Industry Action to Assess Shutdown Management. The calculation considers or detennines the maximum core decay heat generation rate, total primary to secondary heat transfer area, heat transfer coef0clents, relative prl mary and secondary temperatures, total natural circulation Ocw rate, and combined SO ambient heat loss rate, as well as other considerations. The calculation determines that a SO level of a 50 inches with the associated RCS loop Olled is suf0cient to remove the generated decay heat load. His change is consistent with NUREO.1432, L2 Two notes are being added to CTS LCO 3.4.1.3. nese notes permit: a) one required SDC loop to be inoperable for up to two hours for Surveillance testing, provided the other SDC loop is Operable and in operation; and b) all SDC loops to be removed from operation during planned he,itup to Mode 4 when at least one RCS loop is in operation. Note 2 to ITS LCO 3.4.7 pennits periodic Surveillance tests to be performed on one of the SDC loops when both SDC loops are credited for meeting the LCO. His note p ovides operational flexibility by allowing two hours before entering the Action statement. The note is acceptable, because: a) the note requires one SDC loop to be Operable and in operation. The forced coolant circulation provided by one SDC loop is suflicient to remove decay heat in Mode 5 with the loops filled; and b) the Operators will be focused on the status of SDC while operating under the provisions of this note, nus, in the event the required SDC loop becomes inoperable or ceases to be in operation, the Operators would take action in a short period of time to restore a SDC toop to an Operable status and place it in operation. CALVERT CLIFFS . UNITS 1 & 2 3a.7-4 Revision 5
- 43. Discussion of Deviation 27 for Section 3.4 was revised to provide additionalJustification for extending ITS SR 3.4.9.2 from 92 days to 24 months. This change has been made to respond to an NRC comtnent (ITS 3.4.9 Cornment 3).
b Pressurizer ' _ _ _ __ _ 3.4.9 (CT5) Qig_,,,J ,,J f gi
$URytitt act at00!RtMrwis =
r-
' ^
e-v - - b SURytILLMCt
/. FREQUENCY
,4,$h$R3.4.9.1 Verify pressurizer water level is : ;L :. It kurs NEW sg 3.4 9 SR 3.4.9.2 Verifycapacity'ereach n trod of c@ru.29 pressuriter heaters 21160 .
cet u. 553.4.9. Verif re rtner heaters are nthe ~) j capab5eofutrodpre betrig red from an energency (16 Power supply. ( b
- f 4
Ct0G STS 3.4-19 Rev1,04/07/95
l DISCUSSION OF TECllNICAL SPECirlCATION DEVIATIONS FROM NUREG 1432
,.e SECTION 3.4 - REACTOR COOI. ANT SYSTEM
- 27. NUREO 1432 SR 3.4.9.2 tequires the verification of the pressurizer heater capacity once per 92 days. Calvert Cliffs ITS will require verincation of the pressuriter heater capacity once per l 24 months. Calvert Cliffs Cunent Technical Specification does not contain this SR, thus this is a new SR for Calvert Clifts. Ilowever, the test the SR will require is currently being performed l every refueling interval (i.e., every 24 months). An historical review of maintenance history has determined that no failures of the test have occurred in the past $ years. Therefore, the Calvert Cliffs ITS will continue to require the test every 24 months consistent with current practice, in addition, the 24 rnonth interval is consistent with NUREG 1432, Ocneric Change TSTF 93.
- 28. %e Mode of Applicability for NUREG 1432 LCO 3.4.2 is Mde I with T.,,in one or more RCS loops < [$35'F] and Mode 2 with T.,, in one or more RCS loops < [$35'F) and Nn h 1.0.
NUREO SR 3.4.2.1 requires verifying RCS T., in each loop to be a [520'F] every 30 minutes thercefter. NUREO 1432 SR 3.0.4 requires surv,eillances to be met prior to entering the Mode of Applicability for an LCO. The requirements regarding RCS minimum temperature for criticality should be applicable whenever the reactor is critical and not just below a certain temperature. The following changes were made to NUREG 1432 Specification 3.4.2: a) the Applicability of ITS 3.4.2 was revised to be Mode 1 and Mode 2 with Nn 21.0; b) an additional frequency was added to ITS SR 3.4.2.1 to require the verification of T,9 prior to reaching criticality; and c) the current frequency was modified by a note which addresses the temperature requirements provided in the Applicability of NUREG 1432 LCO 3.4.2; thus, after achieving criticality, the SR will only be required to be performed when RCS T.,, is less than 525'F. The revised Applicability of ITS LCO 3.4.2 is the same as the Applicability of CTS LCO 3.1.1.5. It is broader than the Applicability provided in NUREG 1432 LCO 3.4.2. With the revised Applicability, ITS 3.4.2 will require each RCS loop average ten.perature to be h $15'F in Modes I and 2 with Nrr d 1.0. The revised frequency ofITS SR 3.4.2.1 requires verifkation of RCS T.,, to be performed: a) once within 30 minutes prior to reaching criticality; and b) at once per 30 minute thereafler whenever RCS T,v,is less than $25'F. These frequencies are consistent with the intent of NUREG 1432 SR 3.4.2.1 and CTS 4.1.1.5.a and 4.1.1.5.b. 29 NUREG 1432 SR 3.4.1.4 requires the RCS total flow rate to be verified within limits by precision heat balance. Calvert Clifts ITS will require the RCS total flow rate to be Atermined by measurement. The Calvert Cliffs ITS will not specify the method by which to verify the RCS total Dow rate. Calvert Cliffs does not use the precision heat balance method of verifying RCS total flow rate. Calvert Cliffs current Tahnical Specification requires the measurement of the total flow rate. Thus, this deviation from NUREG 1432 is also consistent with the Calvert Cliffs current licensing basis.
- 30. Improved Technical Specification SR 3.4.1.3, w hich verifies RCS total flew rate, contains a Note which states, " Required to be met in MODE 1 with all RCps running." TSTF 62 revised the Note to read "Only required to be met in MODE I" with the justification that all RCPs are required to be running in MODE 1, llowever, the Applicability of LCO 3.4.1 is Mode 1.
Therefore, a Note which states, "Only required to be met in MODE 1" is superfluous. The NOTE has been deleted. TSTF 62 was approved by the NRC on September 18, 1996. A new generic change will be proposed to delete the Note from NUREG 1432. CALVERT CLIFFS UNITS I & 2 3.47 Revision 5
- 44. " ' " fCTS4. 3 a from The 31 daysNRC requested to 92 days additional justificati[). Ibis (ITS 3,4.11 Comment "t ,fg[,'s m ber W
_ _ _ .. . - - - - - _ - . -- __ -- - - _ ---- -_~ .. J Pressortrer 8 3.4.g bA$[$ ACT10N3 f.1 and f f (continued) ' within' fit)' hours. The Completion flee of reasonable based on operating experience, 6 hours is te reach 100E 3 . free full safety p,ower systems. Stellarl in an orderly manner and without challenging ' the completton Ties of [1t) hours is reasonable,ybased on opersting expertence, %a> to rtach MODE 4 from ful) power in an orderly manner ~and without challenging plant systems.
$URVI!LLANCE SR 1.4.9.1 R[QUIR[MENTS This Surveillance ensures that during steady state '
nominal bubble. up,per italt to provide a sintsue space for a steneope indicatedThe surveillance is performed by observing the level. The it hour interval has been shown by operating practice to be sufficient to regularly assess the level for any deviation and verify that operation is within safety analyses assumptions. Alarus are also available for early detection of abnormal level indications. 1R 1.4.9.2 M meg 4J The Survet11 ce is satisfied when the power suppites are demonstrat and the to be capable of producing the minious power their d ign sociated rating.pressurizer heaters are verffted to be at supp1 output and by pe(This rformingmay be done check an electrical by testing on tte power heat element continuity and resistanta.) 1he Fmquency of is considered adequate to detect heater d: gradation and has been shown by operating expertence to be acceptable. This SR is not appi c the heater powered by it power supplies. ersanently This Surveillance demons manually transferr : in:t the can be and ener L supplies. T uency of [16)gized by eneroen r months is based cr. a (continued) CEOG STS B 3.4 42 Rev 1. 04/07/95 e
DISCUSSION OF CilANGES SECTION 3.4.!! PRESSURIZER PORVs credited for overpressure mitigation. 1hese proposed changer are consistent with NUREG 1432. ' L.2 Current Technical Specifications require the PORY CllANNEL FUNCTIONAL TEST (CIT) to be performed every 31 days, in accordance with CTS Table 4.31, item 4. Improved Technical Specificaticas will decrease the Surveillance Frequency to 92 days. The PORY actuation instrumentation is the same as that used for the RPS liigh Pressurizer Pressure Function, described in CTS Table 4.31, item 4. The RPS liigh Pressuriter Pressure Function CIT Surveillance Frequency was decreased from 31 days to 92 days in the RPS and ESFAS " monthly to cuarterly" Technical Specification change (approved in an i NRC Safety Evaluation Report for Amendments 193 and 170 for Units I and 2, respectively, dated August 24,1994). In this report, the NRC stated that Calvert Cliffs had _to satisfy three requirements necessary to extend the CFT Frcquency. These requirements were: a) the licensee must confirm thet they have reviewed instrument drifl infonnation for each channel involved; b) have to determine that drift occurring in that channel over the period of extended surveillance test interval would not cause the setpoint value to exceed the Allowable Value as calculated for that channel by the lleensee's methodologyt and c) should have onsite records of the as found and as-left values showing actual calculations and supporting data for planned future NRC audits. The NRC further stated that Calvert Cliffs I met these three requirements and could extend the CFR Frequency from 31 days to 92 days fbr certain instruments, including the liigh Pressurizer Pressure Function. Calvert Cliffs has evaluated this instrumentation as it relates to the PORV opening setpoint ensured that it meets the three requirements listed above. Since the PORY actuation and the liigh Pressurizer Pressure liigh Trip Setpoint share the same instrumentation and the signal that actuates the PORV is generated from the same portion of the instrument that actuates the RPS, this change is acceptable, CALVERT CLIFFS UNITS 1 & 2 3.4.11-4 Revision 5
ATTACllMENT (4) l l IMPROVED TECilNICAL SPECIFICATIONS, REVISION 5 AMENDMENT REVISION llY ITS SECTION llattimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant September 10,1997
l 1 Pcge Itept:ccment Instructions ! VOLUMI;H l Section 3. l l Note: Undcrlined titles mdscate tabs in volumes Regardmg CIS markups: Pages are rderem ed by citing the umt number as wilas the spec @ cation number locatedin the upper r;ght handcorner ofIhe CIGpage. Key: l)DC = Discussion OfChanges D00 m Discusslon Qf 11chnicalSpec@ cation Deviation or Discussion Qfliases Deviation RI MOVI: INSI:RT CTS Marliup_6_D.broulon of Chnngu Spec $ cation 3 4.1, Unit i Page1of1 PageiofI Spec @ cation 3 41. Unit 2 Page1of1 PageIofI DOC 3.4.1 1 and 3.4.12 DOC 3.4.1 1 and 3.4.12 Spec @ cation 3.41. Unit i Pageiof1 PageiofI Spec @ cation 3 4 2. Unit 2 Page1ofl Page1ofI DOC 3.4.21 and 3.4.2 2 DOC 3,4.2.I and 3.4.2 2 Spec @ cation 3 4 3. Unit I Pageiof5 Page1of5 Page 3 of 5 Page 3 of 5 Spec @ cation 3 43, Unit 2 Page i of 5 Page 1 of 5 Page 3 of 5 Page 3 of 5 DOC 3.4.31 through 3.4.3 3 DOC 3.4.3 1 through 3.4.3-3 Spec $ cation 3.4,5, Unit i Page 1 of 2 Page 1 of 2 Spec $ cation 313, Unit 2 Page I of 2 Page1of2 DOC 3.4.51 and 3.4.5 2 DOC 3.4.5 I through 3.4.5 3 Spec @ cation 346. Unit i Page I of 2 Page i of 2 Page 2 of 2 Page 2 of 2 Spec @ cation 316, Unit 2 Page 1 of 2 Page I of 2 Page 2 of 2 Page~ u 2 DOC 3.4.61 through 3.4,6 4 DOC a.4.6 I through 3.4.6 5 Spec @ cation 3 47, Unit i Page 3 of 3 Page 3 of 3 Specification 3A 7, Unit 2 Page 3 of 3 Page 3 of 3 DOC 3.4.7 2 through 3.4.7-4 DOC 3.4.7 2 through 3.4.7 5
.i
I Pcue 14epl: cement instructions VOLUME N Secilon 3 4 Note: Underimed titles indscate labs in udumes. Regardmg CIS markups: Pages are referenced by citing the unit numir r as utilas the spec {fication number locatedin the upper right-handcorner <fthe C15page, j Kn: - i DOC = Discusston ofClumges DOD = Discussion Gf TechnicalSpecylcarton Deviation or Discussion {}(Bases ucriation REMOVE INSERT Ogenicw of Channes 3.41 3A 1 113 3.4.1 1 and 3 A.l.2 3 A.1 1 and 3 A.l.2 3.4.21 3.4 S 1 and 3A.2 2
-3.4.51 3A.S.1 -
_ _ 3 A.6 1 - 3 A.6 1 3A.63 3.4.63 ' 3.4.71 3A.71 . 3,4.73 3A.73 ! 3.4.81 and 3A.8 2 3 4.81 and 3A.8 2 ! 3A ll 1 through 3.4.11+5 3 A.ll l through 3.4.11-1 : 3 A.121 through 3.4.12 6 3A.121 through 3A.12 7 3.4.13 2 3A,13 2 , 3A.141 and 3.4.14 2 3.4.141 and 3A.14 2 3A.171 and 3.4.17 2 3A.171 and 3.4.17 2 115#1111
-Il 3 A.1 1 through Il 3 A.16 13 A.1 1 through fl 3 A.1 5 B 3A.21 through B 3A.2 3 113 A.21 through 113.4.2 3 B3A.35 113.4.3 5 ll 3 A.5 1 through 113.4.51 Il 3 A.5 1 through Il 3A.5 3 - B 3 A.61 through 113 A.6 Il 3.4.61 through B 3 A.6-6 113.4.7 l through Il 3.4.7 6 113A.71 through B 3A.7 6 ;
il 3 A.81 through !! 3A.8 4 B 3A.81 through B 3A.8 4 B 3 A.9 2 through B 3.4.9 B 3 A.9-2 through B 3.4.9-6 B 3 A.10-2 and i! 3A.10 3 Il 3 A.10 2 and B 3 A.10 3 Il 3.4.1i l il 3 A.I1 1 -< B 3A.ll 3 through B 3 A.ll 9 !! 3.4.113 through B 3 A.ll 9 Il 3 A.121 through Il 3 A.1213 83.4,121 through B 3 A.1215 il 3.4.13 5 and il 3 A.13 6 113.4.13 5 and il 3 A.13 6 113,4.14 2 through B 3.4.14-6 113.4.14 2 through B 3A.14 6 B 3.4.151 through B 3A.15 6 ' B 3A.151 through 113 A.15 6 [ 113.4.171 through B 3.4.17 4 !! 3 A.171 through 113 A.17 4 i
Pcge Rept:ccment Instrucilns VOLUME 8 Secilon 3.4 Note: UnderlincJ tulcs indicate labs in volumes. RegarJing CIS markups: pages are referenccJ by citing the unit number as nell as the sfwc@ cation number located in the ujper right hand corner of the UTSpage. Key: DOC = Discussion O[ Changes DOD = Di.scunion Uf TechnicalSpectfication Deviation or [listuuion Gf flases Lk. viation REMOVE INsEitT Specylcation 3.4 5, Unit i Page 2 of 2 Page 2 of 2 Spec @ cation 3.4 5, Unit 2 Page 2 of 2 Page 2 of 2 DOC 3.4.8 3 and 3.4.8-4 DOC 3.4.8 3 and 3.4.8 4 Specification 3 4.10. Unit i Page i of 2 PageIof2 Specykation 3.410. Unit 2 PageIof2 PageIof2 DOC 3.4.101and 3.4.10 2 DOC 3.4.101 through 3.4.10 3 Spec @cution 3.411. Unit i Page I of 2 Page1of2 Page 2 of 2 Page 2 of 2 Specylcation 3.411. Unit 2 Page i of 2 Page 1 of 2 Page 2 of 2 Page 2 of 2 DOC 3.4.11 1 through 3.4.113 DOC 3.4.11 1 through 3.4.114 Specylcation 3.412. Unit i Page I of 4 through Page 3 of 4 Page I of 4 through Page 3 of 4 Specylcation 3 4.12. Unit 2 Page I of 4 through Page 3 of 4 Page I of 4 through Page 3 of 4 DOC 3.4.121 through 3.4.12 4 IX)C 3.4.121 through 3.4.12-5 Specylcation 3.413. Unit i Page I of 3 through Page 3 of 3 Page I of 3 through Page 3 of 3 Specylcation 3.4.13. Unit 2 Page 1 of 3 through Page 3 of 3 Page i of 3 through Page 3 of 3 DOC 3.4.131 through 3.4.13 3 DOC 3.4.131 through 3.4.13 3 Specification 3.414. Unit i Page 1 of 5 through Page 5 of 5 Page I of 6 through Page 6 of 6 Specylcation 3.414. Unit 2 Page 1 of 5 through Page 5 of 5 Page I of 6 through Page 6 of 6 DOC 3.4.141 through 3.4.14 3 DOC 3.4.14 1 through 3.4.14-4 iii
l'ct:c iteplacement lustrucilons VOLUM10N Section 3,4 Nose: UnderlincJ tales indicate labs in wdumes. RegarJing CIS marLups: l' ages are referenced by citmg the unit number as ucil as the spec @ cation nunsber locatcJ In the u;Y'er rigbl handcorner of the CISpage. Key: DOC = Discusswn Of Changes DOD = Qitrussion GfTechnicalSpee@ cation Deviation or Discussion Qfflaws Qeviation lii'.M O VI'. INhl:llT Spec @ cation J 4.17, Unit I l' age I of I l' age 1 of I Spec @ cation 3 417, Una 2 l' age 1 of I l' age I of I DOC 3.4.171 and 3.4.17 2 DOC 3.4.17.i and 3.4.17 2 DOC C1 S 3/4.4.7 1 DOC C'lS 3/4.4.71 and CTS 3/4.4.7 2 DOC CT S 3/4.4.9.21 DOC C1S 3/4.4.9.21 and C1S 3/4.4.9.2 2 DOC CTS 3/4.4.10.1.I DOC CTS 3/4.4.10.1 1 and C1 S 3/4.4.10.1 2 DOC C1 S 3/4.4.11 1 DOC CIS 3/4.4.11 1 DOC C1 S 3/4.4.12 1 DOC C1S 3/4.4.12 1 and CTS 3/4.4.12 2 NSilC l'indines I 3 4 5 through 3-4 21 3-4 5 through 3 4 21 3 4 23 through 3 4 32 3-4 23 through 3 4 32 111S Markup A Justincalist 3.4.I and 3.4 2 2.41 and 3.4 2 3.44 3.4-4 3.48 3.48 3.4 10 3.4 10 3.412 and 3.413 3.4 12 and 3.4 13 3.4 15 ti.mugh 3.4 17 3.4 15 through 3.4 17 3.4 19 3.4 19 3,4 22 through 3.4 26 3.4 22 through 3.4 26 including
" Insert 3.4 12" 3.4 27 through 3.4-29 3.4 27 through 3.4 29 3.4 30 and 3.4 31 3.4 30 and 3.4 31 3.4 36 through 3.4 39 3.4 36 through 3.4 39 3.4-41 3.4-4 i After page J 4-44..
" Insert 3.4.17" " Insert 3.4.17" and
- Insert 3.4.17 1" DOD 3.4 2 through 3.4 5 DOD 3.4-2 through 3,4 12 ISTS Itases Markup & .lustification B 3.4.I B 3.4 1 Il 3.4 3 through 3.4 5 B 3.4 3 through 3.4 5 113.4 7 and B 3.4 8 113.4 7 and il 3.4 3 B 3.4 12 B 3.412 iv
Pcge Repl:ccment instructions Vol.UME H Section 3,4 Note: Underlined tales indicate tabs in volumes. RegarJing CIS markups.5 ages arq referenced by citing the una number as utli as the specification number located in the utper right hand corner of the CISpage. Ksy: DOC - Dncussion ofChanges D0D = Dncussion Gf TechnicalSpecVication Deviation or Discussion GfBases Deviation l HEMOVE INSERT 113.4 21 133.4 21 113.4 22 !! 3.4 22 113.4 24 and 113.4 25 113.4 24 and 3.4 25 113.4 27 113.4 27 113.4 29 through 113.4 37 113.4 29 through 113.4 37 113 A 39 and il 3.4-40 113.4 39 and !! 3.4-40 113.4 42 !!3.4 42 113.4-48 Il 3.4-48 113.4 50 113.4 50 113,4 51, including" Insert A.; liases" 113 4 51, including" Insert A,1 Ilases" 113.4 52 through 113.4 54 113 4 52 thwugh Il 3.4 54 !!3.4 55 113.4 55 113 A 56 through 113.4 58 113.4 56 through 113A 58 113.4 59 113.4 59 and " INSERT b & c" 113.4 60 113.4-60 113.4 61 113.4 61 and "lNSERT LCO" Il 3 A 62, including " INSERT LCO IIASES" !! 3 A 62 and " INSERT LCO f1ASES" 113A 63 H 3.4 63 and "In$ert Actions 11 and C" 113.4 64, including " INSERT ACTION D.l" 113 A-64 and " INSERT ACllON l',l" 113.4 65 and il 3.4 66 113.4 65 and 113.4 66 113A 72, including"lNSERT ACTION 11" 113.4 72, including" INSERT ACTION 11" 113.4 73 113.4 73 113,4 81 Il 3.4 81 Il 3,4 84, including" INSERT 3.4.14 Actions A & !!" 113.4-84, including " INSERT 3.4.14 Action A 211" 113.4 88 113.4 88 Afterpage B 34-96.
" INSERT 3.4.14 Ilases," pages I of 3 through 3 of 3 " INSERT 3.4.17 !!ases," pages I of 3 through 3 of 3 DOD 3.41 through 3A 3 DOD 3.4 1 through 3.4-4
OVERVIEW OF CIIANGES SECTION 3.4 - REACTOR COOLANT SYSTEM The significant differences between the current Technical Speci0 cations and the proposed improved Technical Specifications are: e e Delay is allowed in the performeace of some surveillances to allow plant conditions to stabilize or time to assess the situation. The specification which requires coolant loops to be Operable in Modes 4 and 5 is split into three specifications.
- Sorne allowed outage times are reduced, e Some Limiting Condition for Operations are being relocated out of the speci0 cations.
The significant differences between the proposed improved Technical Specifications and NUREG-1432, Revision 1, as modified by generic changes, are: t e An improved Technical Specification allowance to de-energize the reactor coolant pumps for up to two hours per eight hour period for low flow testing, as contained in the current Technical Specifications, was added to Specification 3.4.5. The Calvert Cliffs low flow test requirement requires more than one hour, e plant specific power-operetest relief valve and low temperature overpressure protection specifications are incorporated. e The Reactor Cocht System pressurizer isolation valve leakage specification was not t incorporated. Calvert Cliffs does not currently have this specification, and the Calvert Cliffs - design for the applicable 5 %:.* does not warrant this specification. CALVERT CLIFFS- UNITS 1 & 2 3.4-1 Revision 5
RCS Pressure, Temperature. and Flow DNB Limits 3.4.1 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.1 RCS Pressure. Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits LC0 3.4.1 RCS DNB parameters for pressurizer pressure, cold leg temperature, and RCS total flow rate shall be within the limits specified below:
- a. Pressurizer pressure 2 2200 psia;
- b. RCS cold leg temperature (Tc) $ 548'F; and
- c. RCS total flow rate 2 370,000 gpm.
APPLICABILITY: MODE 1.
----------------------------NOTE---------------------------.
Pressurizer pressure limit does not apply during:
- a. THERMAL POWER ramp > 5% RTP per minute; or
- b. THERMAL POWER step > 10% RTP.
ACTIONS-CONDITION REQUIRED ACTION COMPLETION TIME A. RCS DNB parameter (s) A.1 Restoreparameter(s) 2 hours not within limits. to within limit. B. Required Action and B.1 Be in MODE 2. 6 hours associated Completion g Time not met. S' i CALVERT CLIFFS - UNITS 1 & 2 3.4.1-1 Revision Jfg
RCS Pressure, Temperature, and Floa DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure 2 2200 psia. 12 hours SR 3.4.1.2 Verify RCS cold leg temperature s 548'F. 12 hours SR 3.4.1.3 Verify RCS total flow rate 2 370,000 gpm. 12 hours i SR 3.4.1.5 Verify measured RCS total flow rate is 24 months within limits, l l CALVERT CLIFFS - UNITS 1 & 2 3.4.1-2 Revision #f
RCS Minimum Temperature for Criticality 3.4.2 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.2 RCS Minimum Temperature for Criticality LCO 3.4.2 Each RCS loop average temperature (T.,,) shall be 2 515'F. APPLICABILITY: MODE 1, 4 MODE 2 with K,,, 2 1.0. ACTIONS CONDITION REQUIREDr?. TION COMPLETION TIME A. T.,,in one or more A.1 Be in MODE 2 with K,rr 30 minutes RCS loops not within < 1.0. limit. I i CALVERT CLIFFS - UNITS 1 & 2 3.4.2-1 Revision 0
RCS Minimum Temperature for Criticality 3.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 Verify RCS T.,, in each loop 2 515'F. Once within 30 minutes prior to reaching criticality AND
-----NOTE .-.- 6 Only required to be performed when RCS T.,,is
< 525'F 30 minutes thereafter CALVERT CLIFFS . UNITS 1 & 2 3.4.2-2 Revision /fg
J RCS Loops - MODE 3 l 3.4.5 3.4 REACTOR COOLANT. SYSTEM (RCS) 3.4.5 RCS Loops - N0DE 3
- LLCO 3.4.5 Two RCS loops shall be OPERABLE and one RCS loop shall be in operation.-
---------------------_----- NOTES-------------------------.--
- 1. All reactor coolant pumps (RCPs) may be not in operation 6 for s 1 hour per 8 hour period and s 2 hours per 8 hour period for low flow-testing, provided:
- a. No operations are permitted that would cause i
reduction of the RCS boron concentration; and
- b. Core outlet temperature is maintained at least-10'F 5 below saturation temperature.
- 2. No RCP shall be started with rny RCS cold leg temperature s 365'F (Unit 1), s 301*F (Unit 2) unless:
- a. The pressurizer water level is s 170 inches;
- b. The pressurizer pressure is s 300 psia (Unit 1),
s 320 psia (Unit 2); and
- c. The secondary water temperature of each steam generator is s'30'F above the RCS temperature.
APPLICABILITY: MODE 3. CALVERT CLIFFS - UNITS l'& 2 3.4.5-1 RevisionAf
RCS Loops - MODE 4 3.4.6 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.6 RCS Loops _- MODE 4 LC0 3.4.6
. Two loops consisting of any combination of RCS loops and shutdown cooling (SDC) loops shall be OPERABLE and at least one loop-shall be in operation.
.-------------------------- NOTES---------------------------.
- 1. All reactor coolant pumps (RCPs) and SDC pumps may be E ;
not in operation for s 1 hour per 8 hour period, ; provided:
- a. No operations are permitted that would cause reduction of the-RCS boron concentration; and
- b. Core outlet temperature is maintained at least 10*F f below saturation temperature.
- 2. No~RCP shall be started with any RCS cold leg temperature s 365'F (Unit 1), s 301*F (Unit-2) unless:
- a. Pressurizer water level is s 170 inches;
- b. Pressurizer pressure is s 300 psia (Unit 1),
s320 psia (Unit 2);and
- c. Secondary side water temperature-in each steam .
generator (SG) is s 30 F above each of the RCS cold I leg temperatures. APPLICABILITY: MODE 4. i i CALVERT CLIFFS - UNITS 1 & 2 3.4.6-1 Revision /5
RCS Loops - MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RCS or SDC loop is in operation. 12 hours i SR 3.4.6.2 Verify secondary side water level in 12 hours required SG(s) is > -50 inches. SR 3.4.6.3 Verify correct breaker alignment and 7 days indicated power available to the required loop components that are not in operation, g i l l CALVERT CLIFFS - UNITS 1 & 2 3.4.6-3 Revisiongg
RCS Loops - MODE 5. Loops Filled 3.4.7 3.4 : REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops - MODE 5, Loops Filled LC0 3.4.7 One shutdown cooling (SDC) loop shall be OPERABLE and in operation, and either:
- a. One additional SDC loop shall be OPERABLE; or
- b. The secondary side water level of each steam generator (SG) shall be 2 -50 inches.
......___......__ .......-- NOTES------------------__---.----
- 1. The SDC pump of the loop in operation may be not in S' operation for s I hour per 8 hour period provided:
- a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is maintained at.least 10'F 5' below saturation temperature.
- 2. One required SDC loop may be inoperable for up to 2 hours for surveillance testing provided that-the other SDC loop is OPERABLE and in operation.
- 3. No reactor coolant pump (RCP) shall be started with any RCS cold leg temperature s 365*F (Unit 1), s 301*F (Unit 2)unless:
- a. The pressurizer water level' is s 170 inches;
- b. Pressurizer pressure is s 300 psia.(Unit 1),
s 320 psia (Unit 2); and
- c. The secondary side water temperature in each SG is s 30*F above each of the RCS cold leg temperatures.
- 4. - All SDC loops may be not in operation during planned heatup to MODE 4 when at least one RCS loop is in operation.
CALVERT CLIFFS - UNITS 1 & 2 3.4.7-1 Revision g y
l RCS Loops - MODE 5. Loops Filled 3.4.7 , i SURVEILLANCE-REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.4.7.2 Verify requited SG secondary side water 12 hours level is > -50 inches. SR 3.4.7.3 Verify correct breaker alignment and 7 days indicated power available to the required SDC loop components that are not in operation. 5 CALVERT CLIFFS - UNITS 1 & 2 3.4.7-3 Revisiongg
RCS Loops - MODE 5. Loops Not Filled 3.4.8 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.8 RCS Loops - MODE 5. Loops'Not Filled LC0 3.4.8 Two shutdown cooling (SDC) loops shall be OPERABLE and one SDC loop shall be in operation.
........................... N0TES-.....-.-...-..-....-....-..
- 1. All SDC pumps may be not in operation for s 15 minutes 6 when switching from one loop to another provided:
- a. The core outlet temperature is maintained at least S-10*F below saturation temperature;
- b. No operations are permitted that would cause a reduction of the RCS boron concentration; and
- c. No draining operations to further reduce the RCS vater volume are permitted.
- 2. One SDC loop may be inoperable for s 2 hours for surveillance testing provided the other SDC loop is OPERABLE and in operation.
APPLICABILITY: MODE 5 with RCS loops not filled. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SDC loop A.1 Initiate action to Immediately inoperable, restore SDC loop to OPERABLE status. CALVERT CLIFFS . UNITS 1 & 2 3.4.8 1 Revision #5-
RCS Loops - MODE 5, Loops Not filled 3.4.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required SDC loops B.1 Suspend all Immeoiately inoperable, operations involving reduction of RCS QB boron concentration. No SDC loop in AND operation. B.2 Initiate action to Immediately restore one SDC loop to OPERABLE status and operation. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one SDC loop is in operattu. I? hoi:rs SR 3.4.8.2 Verify correct breaker alignment and 7 days indicated power available to the required SDC loop components that are not in 5 operation. CALVERT CLIFFS - UNITS 1 & 2 3.4.8-2 Revision # 5
. .~
l l l Pressurizer PORVs 3.4.11 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.11 PressurizerPowerOperatedReliefValves(PORVs) LC0 3.4.11 Two PORVs and associated block valves shall be OPERABLE. l APPLICABILITY: MODES 1 and 2 MODE- 3 with all RCS cold leg temperatures > 365'F (Unit 1),
> 301*F (Unit 2) .
1 ACTIONS
.....__........................---..N0TES..---..---...---..--...-...--.......
- 1. Separate Condition entry is allowed for each PORV and each block valve.
5
- 2. LC0 3.0.4 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or two PORVs A.1 Close and maintain 1 hour inoperable and power to associcted capable of being block valve.
- manually cycled.
t CALVERT CLIFFS - UNITS 1 & 2 3.4.11-1 Revision 9/ 5'
. ~ - - . _ . . . . - . . _ - - , _ - .
E c Pressurizer PORVs 3.4.11 ACTIONS (continued)
. CONDITION REQUIRED ACTION COMPLETION. TIME B. One.PORV inoperable B.1 Close associated I hour and not capable of block valve.
being manually cycled. AND
- B.2 Remove power from l associated block I hour valve.
i AND i B.3 Restore PORV to [ OPERABLE status. 5 days 6 4 C. One block valve C.1 Place associated PORY 1 hour . inoperable. in override closed. AND C.2 Restore block valve 5 days 5' } to OPERABLE status, i D. Two PORVs inoperable 0.1 C'ose associated 1 hour and not capable of block valves. being manually cycled. AND D.2 Remove power from 1 hour associated block valves. AND 0.3' Restore one PORV to 72 hours OPERABLE status. CALVERT CLIFFS - UNITS 1 & 2 .3.4.11-2 Revisiong5'
Pressurizer PORVs 3.4.11. ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME E. Two block valves E.1 Place associated 1 hour inoperable. PORVs in override closed. AND E.2 Restore one block 72 hours valve to OPERABLE status. F. Required Action and F.1 Be in MODE 3. 6 hours associated Completion Time not met. AND F.2 Reduce any RCS cold 12 hours g-leg temperature s 365'F (Unit 1), s 301*F (Unit 2). SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 Perform a CHANNEL FUNCTIONAL TEST of each 92 days PORV. CALVERT CLIFFS - UNITS 1 & 2 3.4.11-3 Revision)75' l
Pressurizer PORVs 3.4.11 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.4.11.2 -------------------NOTE------------------- Not required to be performed with block valve closed in accordance with the Required Actions of this LCO. Perform a complete cycle of each block 92 days valve. SR 3.4.11.3 Perform a complete cycle of each PORV. 24 months SR 3.4.11.4 Perform a CHANNEL CALIBRATION of each PORV. 24 months CALVERT CLIFFS - UNITS 1 & 2 3.4.11-4 Revision 0
LTOP System
-3.4.12 3.4 REACTOR COOLANT SYSTEM (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 capable of injecting into the RCS, and:
- 2. When HPSI suction is aligned to the Refueling Water :
Tank (RWT), the HPSI pump shall be in manual. I control and either: a) HPSI flow limited to s 210 gpm, or b) An RCS vent of 2: 2.6 square inches 4 establhhed; 6!iQ
- b. HPSI loop motor operated valves (MOVs) only capable of manually aligning HPSI pump flow to the RCS; g
......................... NOTE--------------------------
HPSI loop MOVs may be capable of automatically aligning HPSI pump flow to the RCS for the purposes of testing. AND
- c. 1. TwoOPERABLEpoweroperatedreliefvalves(PORVs). j 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 492 psia
-(Unit 1), s 443 psia (Unit 2), when the SDC is in operation, or l
- 2. One OPERABLE PORV, and associated block valve-open.
-with PORV lift setting on or below the curve in Figure 3.4,12-1 when the SDC System'is not in CALVERT CLIFFS - UNITS 1 & 2 3.4.12-1 Revision ( $
LTOP System 3.4.12 operation and PORV lift setting s 429 psia (Unit . 1), s 443 psia (Unit 2), when the SDC is in operation; and an RCS vent of 2 1.3 square inches f established; or
- 3. An RCS vent of 2 2.6 square inches established.
APPLICABILITY: MODE 3 with any RCS cold leg temperature s 365'F (Unit 1), 6 s 301*F (Unit 2), MODES 4, 5, and 6.
...........................-NOTE---------------------------
This Specification is not applicable when the RCS is vented to 2 8 square inches. ACTIONS
..................................... NOTE-----------------------------------..
While the requirements of this LC0 are not met, entry into a MODE or other specified condition in the Applicability is not permitted.
~
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more HPSI A.1 Initiate action to Immediately pumps capable of verify a maximum of automatically one HPSI pump only injecting into the capable of manually RCS. injecting into the RCS and no HPSI pumps I
- 03. capable of automatically Two or more HPSI injecting into the pumps capable of RCS.
manually injecting into the RCS. CALVERT CLIFFS - UNITS 1 & 2 3.4.12-2 Revisiong5
LTOP System 3.4.12 ACTIONS (continued) i CONDITION REQUIRED ACTION . COMPLETION TIME . B. HPSI flow > 210 gpm B.1 Initiate action to Immediately and suction aligned reduce flow to to RWT. s 210 gpm. i SF AND i RCS vent < 2.6 square , inches established. C. One or more HPSI loop C.1 Initiate action to Immediately MOVs capable of verify HPSI loop MOVs l automatically are only capable of c7 aligning HPSI pump manually aligning
- flow to the RCS. HPSI pump flow to the i a
RCS. D. One of two required D.1 Restore required PORV 5 days PORVs inoperable :n to OPERABLE status. SF MODE 3 with any RCS '
; . cold leg temperature ;
I s 365'F (Unit 1), s 301*F. (Unit 2), or MODE 4. ; ' 4 AND s RCS vent < 1.3 square SF inches established. l l CALVERT CLIFFS - UNITS 1 & 2 3.4.12-3 Revisionjfsr
LTOP System 3.4.12 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
; E. One of two required E.1 Restore required PORV 24 hours 5 PORVs inoperable in to OPERABLE status.
MODE 5 or 6. 4 b.@ RCS vent < 1.3 square 5' inches established. F. Required Action and F.1 Depressurize RCS and 48 hours
-associated Completion establish RCS vent Time of Condition D 2 1.3 square inches.
or E not met. 5 G. All required PORVs G.1 Depressurize RCS and 48 hours 5' inoperable, establish RCS vent of 2 2.6 square inches. S* SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify a maximum of one HPSI pump is only 12 hours capable of manually injecting into the RCS, y SR 3.4.12.2 Verify HPSI loop MOVs are only capable of 12 hours y manually aligning HPSI pump flow to the RCS. 4 4 CALVERT CLIFFS - UNITS 1 & 2 3.4.12-4 Revisiongg
_ _ _ ~ LTOP System 3.4.12 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.4.12.3 Verify required RCS vent is open. 12 hours for i unlocked open ventvalve(s) 5 31 days for locked open ventvalve(s) SR 3.4.12.4 Verify PORV block valve is open for each 72 hours reoiired PORV. 5 SR 3.4.12.5 -------------------NOTE------------------- Not required to be performed until 12 hours y after decreasing any RCS cold leg temperature to s 365'F (Unit 1), s 301*F (Unit 2). Perform CHANNEL FUNCTIONAL TEST on each 31 days required PORV, excluding actuation. SR 3.4.12.6 Perform CHANNEL CALIBRATION on each required 24 months f PORV actuation channel. CALVERT CLIFFS - UNITS 1 & 2 3.4.12-5 Revisiongy
l LTOP System 3.4.12 aseo . y iF!../.Q'IfI .J i !C1 :I iD :lh' '!"
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0 100 200 300 400 500 600 ACTUAL REACTOR COOL.AVT TEMPERATURE TC ' FIGURE 3.4-12-1 Calvert Cliffs Unit 1, for Fluence s 2.61x10" n/cm* Maximum PORV Openino Pressure vs Temperature CALVERT CLIFFS - UNITS 1 & 2 3.4.12-6 Revision 0
LTOP System 3.4.12 aso0 m_. . _ .. . . ,,___ - _ 4.;
- =
~'
MW 9' %.
. . _ _ , .p- ._ _
1500 7_ . .._ w...a
. .. -- ,..__ =
, ((i_ RCS TEMP, PZR PRESS.
h
- s. ==,- .__ . . ._ i 44*F 443 PSIA' 5 g ---- - --- ---
= :/.- = -
90'F 443 PSIA [
/ 170'F $15 PSIA 5 f =
l_ ._ . _g. ; _ . 194'F 543 PSIA j _ 240F 740 PSIA 5: 500 - 260.*h 835 PSIA E_ 304'F 1250 PSIA _ o- + , _ i::= _m.-,i.._ .. _ - . - . - - - o too 200 soo 400 soo s00 ACTUAL REACTOR COOLANT TEMPERATURE T ,'F FIGURE 3.4-12-1 Calvert Cliffs Unit 2, for Fluence s 2.61x10" n/cm' Maximum PORY Openino Pressure vs Temperature CALVERT CLIFFS - UNITS 1 & 2 3.4.12-7 Revision 0
a , RCS Operational LEAKAGE 3.4.13 4 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME . B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Conditica A AND not met. B.2 Be in MODE 5. 36 hours QB ! Pressure boundary LEAKAGE exists. 5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 Verify RCS Operational LEAKAGE is within -----NOTE ---- limits by performance of RCS water inventory Only required l balance. to be performed cp
- during steady state operation 72 hours SR 3.4.13.2 Verify SG tube integrity is in accordance- In accordance with the Steam Generator Tube Surveillance with the Steam Program. Generator Tube Surveillance Program Y
i CALVERT CLIFFS - UNITS 1 & 2 3.4.13-2 RevisionJ15'
_ _ _ . _ ~ . _ . . _ -. _.._. - _ . .. _ .._ _ _ _ . . _ _ . - . _ - RCS Leakage Detection Instrumentation 3.4.14 3.4 REACTORCOOLANTSYSTEM(RCS) 3.4.14- RCS Leakage Detection Instrumentation i LC0 3.4.14 The following RCS leakage detection instrumentation shall be OPERABLE:
- a. One containment sump level alarm; and
- b. One containment atmosphere radioactivity monitor (gaseousorparticulate).
e i APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS
.................................----N0TE---.-.-----..----.....-.-..-....----.
LC0 3.0.4 is not applicable. CONDITION REQUIRED ACTION COMPLETION TIME
~
5 A. Required containment A.1 Perform SR 3.4.13.1. Once per sump level alarm 24 hours inoperable. AND A.2 Restore containment- 30 days y sump level alarm to OPERABLE status, i CALVERT CLIFFS - UNITS 1 & 2 3.4.14-1 RevisionAS'
\
RCS Leakage Detection Instrumentation 3.4.14 ACTIONS-(continued) CONDIIION REQUIRED ACTION COMPLETION TIME B. Required containment- B.1.1 Analyze grab samples Once per atmosphere of the containment 24 hours radioactivity monitor atmosphere. inoperable, 93 B.1.2 Perform SR 3.4.13.1.. Once per 24 hours AND B.2 Restore required 30 days-containment atmosphere radioactivity monitor to OPERABLE status.- i C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours D. All required alarms D1 Enter LC0 3.0.3. Inunediately and monitors inoperable. CALVERT CLIFFS UNITS 1 & 2 3.4.14-2 Revision #5 ! v
I' STE RCS Loops - MODES 4 and 5 3.4.17 c 3.4 REACTORCOOLANTSYSTEM(RCS) ; 3.4.17- Special Test Exception (STE) RCS Loops - MODES 4 and 5 LCO 3.4. The reactor coolant circulation requirements of LCO 3.4.6, "RCS Loops-MODE 4 " LC0 3.4.7, "RCS Loops-MODE 5 Loops Filled," and LCO 3.4.8, "RCS Loops-MODE 5 Loops Not Filled" may be suspended during the time intervals required: - 1) for g local leak rate testing of containment penetration number 41 pursuant to tSe requirements of the Containment Leakage Rate TestingProgram;and2)topermitmaintenanceonvalves located in the common shutdown cooling suction line or on the shutdown cooling flow control valve provided: , a. Xenonreactivityiss0.1%Ak/kandisapproaching stability; I
- b. No operations are permitted which could cause reduction of the RCS boron concentration; E
- c. The charging pumps are deenergized and the charging flow paths are closed; and i
5'
- d. The SHUTDOWN MARGIN requirement of LC0 3.1.1 is verified every 8 hours.
APPLICABILITY: MODES 4 and 5. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend activities Immediately requirements of the being performed under g LCO not met. this STE. CALVERT CLIFFS - UNITS 1 & 2 3.4.17-1 Revision # 5
STE RCS Loops - MODES 4 and 5 3.4.17
- SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify xenon reactivity is within limits. Once within 1 hour prior to suspending the reactor coolant y circulation requirements of LC0 3.4.6, LCO 3.4.7, and lf LC0 3.4.8 SR 3.4.17.2 Verify charging pumps de-energized. I hour SR 3.4.17.3 Verify. charging flow paths isolated. I hour SR 3.4.11.4 Perform SR 3.1.1.1. 8 hours CALVERT CLIFFS - UNITS 1 & 2 3.4.17-2 Revisiongy
RCS Pressure, Temperature, and floa DNB Limits B 3.4.1 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.1 RCS Pressure Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits BASES BACKGROUND These Bases address requirements for maintaining RCS pressure, temperature, and flow rate within limits assumed in the safety analyses. The safety analyses (Ref. 1) of normal operating conditions and anticipated operational occurrences assume initial conditions within the normal steady state envelope. The limits placed on DNB related parameters ensure that these parameters will not be less conservative than were assumed in the analyses and thereby provide assurance that the minimum departure from nucleate boiling ratio (DNBR) will meet the required criteria for each of the transients analyzed. The LCO limit for minimum RCS pressure as measured at the pressurizer is consistent with operation within the nominal operating envelope and is bounded by the initial pressure in the analyses. The LCO limit for maximum RCS cold leg temperature is consistent with operation at the indicated power level and is bounded by the initial temperature in the analyses. The LC0 limit for minimum RCS flow rate is bounded by the initial flow rate in the analyses. The RCS flow rate is not expected to vary during plant operation with all pumps running. APPLICABLE The requirements of LC0 3.4.1 represent the initial SAFETY ANALYSES conditions for DNB limited transients analyzed in the safety analyses (Ref.1). The safety analyses have shown that transients initiated from the limits of this LCO will meet the DNBR criterion. Changes to the facility that could impact these parameters must be assessed for their impact on the DNBR criterion. The transients analyzed for include CALVERT CLIFFS - UNITS 1 & 2 B 3.4.1 1 Revision 0
RCS Pressure, Temperature, and Flow DNB Limits B 3.4.1 BASES loss of coolant flow events and dropped or stuck control elementassembly(CEA) events. A key assumption for the analysis of these events is that the core power distribution is within the limits of LCO 3.1.6, " Regulating Rod Insertion Limits " LCO 3.2.4 " AZIMUTHAL POWER TILT (T,)I" and LCO 3.2.5, " AXIAL SHAPE INDEX." The safety analyses are I performed over the following range of initial values RCS oressure 2154 2300 psia, core inlet temperature s 548"F, and reactor vessel inlet coolant flow rate 2 370,000 gpm. The RCS DNB limits satisfy 10 CFR 50.36(c)(2)(ii), Criterion 2.
- LCO This LC0 specifies limits on the monitored process variables 3
- RCS pressurizer-pressure, RCS cold leg temperature, and RCS total flow rate - to en.are that the core operates i within the limits assumed for the plant safety analyses.
) Operating within these limits will result in meeting the j DNBR criterion in the event of a DNB limited transient. The LCO numerical values /or pressure and temperature are given for the measurement location and have been adjusted i for instrument error. RCS Flow Rate is given as an f j analytical value. APPLICABILITY In MODE 1, the limits on RCS pressurizer pressure, RCS cold leg temperature, and RCS flow rate must be maintained during steady state operation in order to ensure that DNBR criteria will be met in the event of an unplanned loss of forced coolant flow or other DNB limited transient. In all other MODES, the power level is low enough so that DNBR is not a Concern. A Note has been added to indicate the limit on pressurizer pressure may be exceeded during short . term operational transients such as a THERMAL POWER ramp increase of CALVERT CLIFFS _ UNITS 1 & 2 B 3.4.1 2 Revision 9'S
I RCS Pressure. Temperature, and Flow DNB Limits ; 8 3.4.1 l BASES
> 5% RTP per minute or a THERMAL POWER step increase of
> 10% RTP. These conditions represent short term
[ i perturbations where actions to control pressure variations : might be counterproductive. Also, since they represent transients initiated from power levels < 100% RTP, an increased DNBR margin exists to offset the temporary ; pressure variations. Another set of limits on DNB related parameters is provided I inSafetyLimit(SL)2.1.1,"ReactorCoreSafetyLimits."
-Those limits are less restrictive than the limits of this LCO, but violation of SLs merits a stricter, more severe Required Action. Should a violation of this LCO occur, the operator should check whether or not an SL may have been exceeded.
ACTIONS M Pressurizer pressure and RCS cold leg temperature are y controllable -and measurable carameters. RCS flow rate is not a controllable parameter and is not expected to vary during steady state operation. With any parameter not F within its LCO limit, action must be taken to restore _the parameter, f The 2 hour Completion Time for restoration of the parameters provides sufficient time to adjust plant parameters, to . determine the cause of the off normal condition,-and to restore the readings within limits. The Completion Time is based _on plant operating experience tnat shows the parameter can be restored in this tiF4 period. M if Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this_ status, the CALVERT CLIFFS - UNITS 1 & 2 B 3.4.1-3 Revision 6 f
RCS Pressure Temperature, and Flow DNB Limits D 3.4.1 BASES plant must be brought to at least MODE 2 within 6 hours. In H0DE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. Six hours is a reason ele time that permits the plant power to be reduced at an oederly rate in conjunction with even control of steam generator (SG) heat removal. G SURVEILLANCE SR 3.4.1.1 REQUIREMENTS Since Required Action A.1 allows a Completion Time of 4 2 hours to restore parameters that are not within limits, the 12 hour Surveillance Frequency for pressurizer pressure ! is sufficient to ensure that the pressure can be restored to a r:ormal operation, steady state condition following load changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be i sufficient to regularly assess for potential degradation and verify operation is within safety analysis assumptions. SR 3.4.1.2 Since Required Action A.1 allows a Completion Time of 2 hours to restore parameters that are not within limits, the 12 hour Surveillance Frequency for cold leg temperature is sufficient to ensure that the RCS coolant temperature can be restored to a normal operation, steady state condition following load changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within safety analysis assumptions. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.1-4 Revisiongf
RCS Pressure. Temperature, and Flow DNB Limits B 3.4.1 BASES SR 3.4.1.3 The 12 hour Surveillance Frequency for RCS total flow rate
-is performed using the installed flow instrumentation. The 12 hour frequency has been shown by operating experience to be sufficient to assess for potential degradation and to verify operation is within safety analysis assumptions.
1 SR 3.4.1.4 i Heasurenent of RCS total flow rate is performed once every i 24 months. This verifies that the actual RCS flow rate is 5F within the bounds of the analyses. The Frequency of 24 months reflects the importance of verifying flow after a refueling outage where the co.e has been altered, which may have caused an alteration of flow resistance. REFERENCES 1. UFSAR, Section 14.1.2 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.1 Revision JTS-
RCS Minimum Temperature for Criticality B 3.4.2 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.2 RCS Minimum Temperature for Criticality BASES BACKGROUND Establishing the value for the minimum temperature for reactor critiolity is based upon considerations fort
- a. Operative Hi% n the existing instrumentation ranges and accuracing
- b. Operation within the bounds of the existing accident analysest and
- c. Operation with the reactor vessel above its minimum nil ductility reference temperature when the reactor is critical.
The reactor coolant moderator temperature coefficient used in core operating and accident analysis is defined for the normal operating temperature range as specified in the operating procedures. The Reactor Protective System receives inputs from the narrow range hot and cold leg temperature detectors, which have a range of 515'F to 665'F and 465'F to 615'F, respectively. The RCS temperature is controlled using inputs of the same range.. Nominal T,n for caking the reactor c_ritical is 532'F. Safety and operating g analyses for lower temperature have not been made. APPLICABLE There are no accident analyses that dictate the minimum SAFETY ANALYSES temperature for criticality, but all low power safety
- analyses can accommodate initial temperatures near the 515'F limit (Refs.1and2).
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.2-1 Revisiongf
RCS Minimum Temperature for Criticality B 3.4.2 BASES The RCS minimum temperature for criticality satisfies 10 CFR 50.36(c)(2)(11), Criterion 2. LCO The purpose of the LCO is to prevent criticality outside the normal operating regime and to prevent operation in an unanalyzed condition. APPLICABILITY The reactor has been designed and analyzed to be critical in MODES 1 and 2 only and in accordance with this specification. Criticality is not permitted in any other MODE. Therefore, this LC0 is applicable in MODE 1 and l MODE 2 when K.,, 2 1.0, ACTIONS Ad If T.,, is below 515'F, the plant must be brought to a MODE l in which the LC0 does not apply. To achieve this status, the plant must be brought to MODE 2 with K,,, < 1.0 within 30 minutes. Rapid reactor shutdown can be readily and practically achieved within a 30 minute period. The allowed time reflects the_ ability to perform this action and to maintain the plant within the analyzed range. SURVEILLANCE SR 3.4.2.1 REQUIREMENTS T.,, is initially required to be verified 2 515'F within. 30 minutes prior to reaching reactor criticality, then T.,, is required to be verified 2 515'F every 30 minutes. The 30 minute time period is frequent enough to prevent _ 6 inadvertent violation of the LCO. The second frequency is modified by a Note which states that-the Surveillance is only required to be performed when RCS T.,, is less than 525'F. This provides a reasonable distance to the limit of 515'F . Adequate time will be available to trend RCS T.,, as CALVERT CLIFFS - UNITS 1 & 2 B 3.4.2-2 Revisiongs
RCS Hinimum Temperature for Criticality B 3.4.2 BASES it approaches 515'F. and take corrective action (s) prior to exceeding the limit. 7 REFERENCES 1. UFSAR, Section 14
- 2. CENPSD-1026. Evaluations of NRC Information Notice 94-75 l
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.2-3 Revisiongr
l RCSP/TLimits B 3.4.3 BASES
- c. The existences, sizes, and orientations of flaws in the vessel material.
APPLICABILITY TheRCSP/TlimitsSpecificationprovidesadefinitionof acceptable operation for prevention of nonductile failure in accordancewith10CFRPart50,AppendixG(Ref.1). AlthoughtheP/Tlimitsweredevelopedtoprovideguidance foroperationduringheatupor_cooldown(H0 DES 3,4,and5) or ISLH testing, their Applicability is at all times in keeping with the concern for nonductile failure. The limits f do not apply to the pressurizer. During MODES 1 and 2, other Technical Specifications provide limits for operation that can be more restrictive than or cansupplementtheseP/Tlimits. LCO 3.4.1, "RCS Pressure, Temperature,andFlowDeparturefromNucleateBoiling(DNB) Limits;" LCO 3.4.2, "RCS Minimum Temperature for Criticality " and Safety Limit 2.1, " Safety Limits," also provide operational restrictions for pressure and temperature and maximum pressure. Furthermore, MODES 1 and 2 are above the temperature range of concern for nonductile failure, and stress analyses have been performed for normal maneuvering profiles, such as power ascension or descent. The actions of this LC0 consider the premise that a violation of the limits occurred during normal plant maneuvering. Severe violations caused by abnormal transients, at times accompanied by equipment failures, may also require additional actions from emergency operating procedures. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.3-5 Revision,65
RCS Loops - MODE 3 8 3.4.5 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.5 RCS Loops - MODE 3 BASES BACKGROUND The primary function of the reactor coolant in MODE 3 is removal of decay heat and transfer of this heat, via the steam generators (SGs), to the secondary plant fluid. The
- secondary function of the reactor coolant is to act as a L
carrier for soluble neutron poison, boric acid. In MODE 3, reactor coolant pumps (RCPs) are used to provide forced circulation heat removal during heatup and cooldown. ! The MODE 3 decay heat removal requirements are low enough that a single RCS loop with one RCP is sufficient to remove core decay heat. Horever, two RCS loops (i.e., RCS loop Nos. 1 and 12 for Unit No. 1 and RCS loop Nos. 21 and 22 for F UnitNo.2)arerequiredtobeOPERABLEtoprovideredundant paths for decay heat removal. Only one RCP needs to be OPERABLE to declare the associated RCS loop OPERABLE. Reactor coolant natural circulation is not normally used but is sufficient for core cooling. However, natural circulation does not provide turbulent flow conditions. Therefore, boron reduction in natural circulation is prohibited because mixing to obtain a homogeneous concentration in all portions of the RCS cannot be ensured. APPLICABLE Failure to provide heat removal may result in challenges to SAFETY ANALYSES a fission product barrier. The RCS loops are part of the primary success. path that functions or actuates to prevent or mitigate a Design Basis Accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.5-1 Revision #s
1 RCS Loops - H0DE 3 8 3.4.5 BASES RCS Loops - MODE 3 satisfy 10 CFR 50.36(c)(2)(ii), Criterion 3. LCO The purpose of this LCO is to require two RCS loops to be available for heat removal, thus providing redundancy. The LCO requires the two loops to be OPERABLE rith 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 hour per 8 hour 5 period and s 2 hours per 8 hour 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 saturatiun temperature so that no vapor bubble may form and possibly cause a natural circulation flow obs;ruction. In MODES 3, 4, and 5, it is sometimes necessary to stop all RCPsorshutdowncooling(SDC)pumpforcedcirculation (e.g.,tochangeoperationfromoneSDC-traintotheother, to perform surveillance or startup testing, to perform the transition to and from SDC System cooling, or to avoid operation below the RCP minimum net positive suction head limit). The time period is acceptable because natural circulation is adequate for heat removal and the reactor coolant temperature can be maintained subcooled. CALVERT~ CLIFFS - UNITS 1 & 2. B 3.4.5-2 Revision JL5'
RCS Loops - MODE 3 8 3.4.5 l BASES Note 2 requires that all of the following three conditions 1 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): 3
- a. the pressurizer water level is s 170 inches,
- 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 g.
Ensuring the above conditions are satisfied will preclude a PORV from opening as a result 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. - g_ APPLICABILITV' 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 4 not in operation for redundant heat removal capability. Operation in other M0uES is covered by: l LCO 3.4.4, "RCS Loops - MODES 1 and 2;"
- LCO 3.4.6, "RCS Loops - MODE 4;"
i LCO 3.4.7, "RCS Loops - MODE 5 Loops Filled;"
- LC0 3.4.8, "RCS Loops - MODE 5 Loops Not Filled;"
i LCO-3.9.4, " Shutdown Cooling (SDC) and Coolant
- Circulation-HighWaterLevel"(MODE 6);-and-I t
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.5-3 Revision #1
.ye- . < - ~- -47,m-, ,,w,- , .,,--c.~- , ,,,#--,- m.- v,y. - . , --,--.----,,,,w----. --~.,ve--.., --c,--- =
RCS Loops - MODE 4 B 3.4.6 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.6 RCS Loops - MODE 4 BASES BACKGROUND In MODE 4, the primary function of the reactor coolant is l the removal of decay heat and transfer of this heat to the steamgenerators(SGs)orshutdowncooling(SDC) heat exchaigers. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. In MODE 4, either reactor _ coolant pumps (RCPs) or SDC loops car, be used for coolant circulation. The intent of this LCO is to provide forced flow from at least one kCP or one SDC loop for decay heat removal and transport. The flow provided by one RCP or SDC loop is adequate for heat removal. The other intent of this LCO is to require that two paths be available to provide redundancy for heat removal. For Unit No. 1, the two paths can be any combination of RCS loop No. 11, RCS loop No. 12. SDC loop No. 11 or 500 loop No. 12. For Unit No. 2, the two paths f can be any combination of RCS loop No. 21. RCS loop No. 22, SDC loop No. 21, or SDC loop No. 22. APPLICABLE In MODE 4. RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the accidental boron dilution event. The RCS and SDC loops provide this circulation. RCS Loops - MODE 4 have been identified in 10 CFR 50.36(c)(2)(ii) as important contributors to risk reduction. LCO The purpose of this LCO is to require that at least two loops, RCS or SDC, be OPERABLE in MODE 4 and one of these CALVERT CLIFFS - UNITS 1 & 2 B 3.4.6-1 Revision gS n
RCS Loops - MODE 4 0 3.4.6 BASES loops be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS and SDC System loops. Any one loop in operation J provides enough flow to remove the decay heat from the core with forced circulation. An additional loop is required to be OPERABLE to provide redundancy for heat removal. Note 1 permits all RCPs and SDC pumps to not be in operation 5; 1 hour per 8 hour period. The Note prohibits boron dilution when forced flow is stopped because an even concentration distribution cannot be ensured. Core outlet temperature is to be maintained at least 10*F below saturation temperature so that no vapor bubble may form and possibly cause a natural circulation flow obstruction. The l response of the RCS without the RCPs or SDC pumps depends on the core decay heat load and the length of time that the pumps are stopped. As decay heat diminishes, the effects on RCS temperature and pressure diminish. Without cooling by forced flow, higher heat loads will cause the reactor coolant temperature and pressure to increase at a rate proportional to the decay heat load. Because pressure can increase, the applicable system pressure limits (pressure andtemperature(P/T)limitsorlowtemperatureoverpressure protection (LTOP) limits) must be observed and forced SDC flow or heat removal via the SGs must be re-established prior to reaching the pressure limit. The circumstances for stopping both RCPs or SDC pumps are to be limited to situations where:
- a. Pressure and temperature increases can be maintained well within the allowable pressure (P/T limits and LTOP) and 10*F subcooling limits; or
- b. An alternate heat removal path through the SGs is in operation.
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.6-2 Revision 0
i
)
RCS Loops - MODE 4 8 3.4.6 !
)
l BASES j Note 2 requires O tt the following conditions be satisfied before an RCP may be started with any RCS cold leg < temperature s 365'T (Unit 1), s 301'F (Unit 2): l l a. Pressurizer water level is s 170 inches;
- b. Pressurizer pressure is s 300 psia (Unit 1), s 320 psia ,
(Unit 2);and ' 1 i
- c. Secontry side water temperature in each SG is s 30'F !
l above each of the RCS cold leg temperatures. 4 4
- Satisfying the above conditions will preclude a PORV from i opening due to a pressure surge in the RCS when the RCP is l started.
An OPERABLE RCS loop consists of at least one OPERABLE RCP [ and an SG that is OPERABLE in accordance with the Steam Generator Tube Surveillance Program and has the minimum water level specified in SR 3.4.6.2. Similarly, for the SDC System, an OPERABLE SDC loop is composedoftheOPERABLESDCpump(s)capableofproviding j forcedflowtotheSDCheatexchanger(s). Reactor coolant , pumps and SDC pumps are OPERABLE if they are capable of j being powered and are able to provide flow if required. d d i APPLICABILITY In MODE 4, this LCO applies because it is possible to remove i core decay he6t and to provide proper boron mixing with n either the RCS loops and SGs or the SDC System, i ; j Operation in other MODES is covered by: 1 LCO 3.4.4, "RCS Loops - MODES 1 and 2;"
. LCO 3.4.5, "RCS Loops - MODE 3;"
LCO 3.4.7, "RCS Loops - MODE 5. Loops Filled;" LCO 3.4.8, "RCS Loops - N0DE 5. Loops Not Filled;" CALVERT CLIFFS - UNITS 1 & 2 8 3.4.6-3 Rnision 0
RCS Loops - MODE 4 8 3.4.6 BASES LCO 3.9.4, "ShutdownCooling(SDC)andCoolant Circulation - High Water Level" (MODE 6); and LCO 3.9.5, "ShutdownCooling(SDC)andCoolant Circulation - Low Water Level" (MODE 6). I 1 ACTIONS M If only one required RCS loop is OPERABLE and in operation, and no SDC loops are OPERABLE, redundancy for heat removal is lost. Action must be initiated innediately to restore a second loop to OPERABLE status. The innediate Completion Time reflects the importance of maintaining the availability of two paths for decay heat removal. M If one required SDC loop is OPERABLE and in operation and no RCS loops are OPERABLE, redundancy for heat removal is lost. The plant must be placed in MODE 5 within the next 24 hours. Placing the plant in MODE 5 is a conservative action with regard to decay heat removal. With only one SDC loop OPERABLE, redundancy-for decay heat: removal is lost and, in the event of a loss of the remaining SDC loop, it would be safer to initiate that loss from MODE 5 (s 200*F) rather than MODE 4 (> 200'F to < 300*F). The Completion Time of 24 hours is reasonable, based on operating experience, to reach MODE 5 from MODE 4, with only one SDC loop operating, in an orderly manner and without challenging plant systems. C.1 and C.2 If no RCS or SDC loops are OPERABLE or in _ operation, except during conditions permitted by Note 1 in the LCO section, all operationt, involving reduction of RCS boron concentration must be suspended and action to restore one RCS or SDC loop to OPERABLE status and operation must be CALVERT CLIFFS - UNITS 1 & 2 B 3.4.6-4 Revision 0
RCS Loops - MODE 4 8 3.4.6 BASES initiated. Boron dilution requires forced circulation for proper mixing, and the margin to critical u y must not be reduced in this type of operation. The imediate Completion Times reflect the importance of decay heat removal. The l action to restore must continue until one loop is restored l to operation. ( _ SURVEILLANCE SR 3.4.6.1 REQUIREMENTS This SR requires verification every 12 hours that one required loop is in operation. This ensures forced flow is providing heat removal. Verification includes flow rate, temperature, or pump status monitoring. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess RCS loop status. In addition, control room indication and alarms will normally indicate loop status. SR 3.4.6.2 This SR requires verification every 12 hours of secondary side water level in the required SG(s) > -50 inches. An adequate SG water level is required in order to have a heat sink for reinoval of the core decay heat from the reactor coolant. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within safety analyses assumptions. SR 3.4.6.3 Verification that the required pump is OPERABLE ensures that an additional RCS or SDC 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 available to the required loop g components that are not in operation. For an RCS loop, the CALVERT CLIFFS - UNITS 1 & 2 B 3.4.6-5 Rewision 9Y
i' ! i i RCS Loops - MODE 4- 1 B 3.4.6 i I i BASES 4 , i ' required component is a pump. For an SDC loop, the required y i components are the pump and valves. The frequency of 7 dayt is considered reasonable in view of other administrative ; i- controls available and has been shown to be acceptable by ! { operating experience. ! j -! ! REFERENCES None t 4 ; i- ; l-i 1 1 I e 1
?
I t -- i l t-CALVERT CLIFFS - UNITS 1 & 2 B 3.4.6-6. Revision h . t
, , _ , - . , _ . . _ , _ . . - , , . . _ . _ _ _ , _ - , _ , _ _ _ . _ . . . _ _ , . . . , . . . _ _ _ _ . . _ . . . , . , . . . . . . , . . , _ , . . . . , _ _ _ _ -,..-_....__.__...-.,_.a,...
RCS Loops - MODE 5. Leops filled B 3.4.7 8 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.7 RCS Loops - MODE S. Loops filled BASES BACKGROUND in MODE S with the RCS loops filled, the primary function of the reactor coolant is the removal of decay heat and the i transferofthisheateithertothesteamgenerator(SG) l se:condary side coolant or the component cooling water via taeshutdowncooling(SDC)heatexchangers. While the p>incipal means for decay heat-removal is via the SDC 1 System, the SGs are specified as a backup means for redundancy. Even though the SGs cannot produce steam in this MODE they are capable of being a heat sink due to their large contained volume of secondary side water. As long as the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will occur. The rate of heat transfer is directly proportional to the temperature difference. Due to the non condensible gasses that come out of solution and restrict flow through the SG tubes, the SGs can only be credited when the RCS is capable of being pressurized. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. In MODE S with RCS loops filled, the SDC loops are the principal means for decay heat _ removal. The number of loops 5 in operation can vary to suit the' operational needs. The intent of this LCO is to provide forced flow from at least one SDC loop for decay heat removal and transport. The - flow provided by one SDC loop is adequate for decay heat removal. The other intent of this LCO is to require that a second path be available to provide redundancy for decay heat removal. The LC0 provides for redundant paths of decay heat removal capability. The first path can be an SDC loop (i.e., SDC
' loop No.11' or_ No.12 for Unit No.1, and SDC loop No. 21 or S No.22forUnitNo.2)thatmustbeOPERABLEandin CAliERT CLIFFS - UNITS 1 & 2 B 3.4.7-1 Revision D'S
RCS Loops - MODE 5. Loops Filled B 3.4.7-BASES operation. The second path can be another OPERABLE SDC loop (i.e., SDC loop No. 11 or No. 12 for Unit No. 1 and SDC y loopNo.21orNo.22forUnitNo.2),orthroughtheSGs, each having an adequate water level, i APPLICABLE In MODE 5. RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the_ , accidental boron dilution event. The SDC svops provide this l , circulation. l RCSLoops-MODE 5(LoopsFilled)havebeenidentifiedin 10 CFR 50.36(c)(2)(ii) as important contributors to risk l reduction. l LCO- The purpose of this LCO is to require at least one of the SDC loops be OPERABLE and in operation with an additional SDC loop OPERABLE or secondary side water level of each SG shall be 2 -50 inches. One SDC loop provides sufficient
' forced circulation to perform the safety functions of the reactor coolant under these conditions. The second SDC loop is normally maintained OPERABLE as a backup to the operating SDC loop to provide redundant paths for_ decay heat removal.
However, if the standby SDC loop is not OPERABLE, a sufficient alternate method to provide redundant paths for decay heat removal is two SGs with their secondary side water levels 2 -50 inches. Should the operating SDC loop fail, the SGs could be used to remove the decay heat. Note 1 permits'all SDC pumps to not be in operation s 1 hour per 8 hour period.- The circumstances for stopping both SDC loops are to be limited to situations where pressure and temperature increases can be maintained well withinthe'allowablepressure(pressure'andtemperatureand-low temperature overpressure protection) and 10'F subcooling limits,oranalternateheatremovalpaththroughtheSG(s) is in operation. CALVERT CLIFFS - UNITS 1 & 2 8 3.4.7-2 Revision 6S
RCS Loops - MODE 5 Loops Filled B 3.4.7 BASES This LCO is modified by a Note that prohibits boron dilution when SDC forced flow is stopped because an even concentration distribution cannot be ensured. Core outlet temperature is to be maintained at least 10'F below saturation temperature, so that no vapor bubble would form and possibly cause a natural circulation flow obstruction. ! InthisH0DE,theSG(s)canbeusedasthebackupfor500 heat removal. To ensure their availability, the RCS loop I flow path is to be maintained with subcooled liquid. In MODE 5 it is sometimes necessary to stop all RCP or SDC forced circulation. This is permitted tu change operation from one SDC loop to the other, perform surveillance or startup testing, perform the transition to and from the SDC, or to avoid operation below the RCP minimum net positive suction head limit. The time period is acceptable because natural circulation is acceptable for decay heat removal, the reactor coolant temperature can be maintained subcooled, and boron stratification aff6cting reactivity control is not expected. Note 2 allows one SDC loop to be inoperable for a period of up to 2 hours provided that the other SDC loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time 5 when such testing is safe and possible. Note 3 requires that the following conditions be satisfied before an RCP may be started with any RCS cold leg temperature s 365'F (Unit 1), s 301*F (Unit 2):
- a. Pressurizer water level must be s 170 inchest
- b. Pressurizer pressure s 300 psia (Unit 1), s 320 psia (Unit 2);and
- c. Secondary side water temperature in each SG must be s 30*F above each of the RCS cold leg temperatures, CALVERT CLIFFS - UNITS 1 & 2 B 3.4.7-3 Revision D'S
RCS Loops - MODE 5. Loops Filled B 3.4.7 i BASES ^ Satisfying the above conditions will preclude opening a PORY during a pressure transient when the RCP is started. Note 4 provides for an orderly transition from MODE 5 to 1 MODE 4 during a planned heatup by permitting SDC loops to not be in operation when at least one RCP is in operation. 6 This Note provides for the transition to MODE 4 where an RCP is permitted to be in operation and replaces the RCS circulation function provided by the SDC loops. An OPERABLE SDC loop is composed of an OPERABLE SDC pump and 5 an OPERABLE SDC heat exchanger.
- SDC pumps are OPERABLE if they are capable of being powered
- and are able to provide flow if required. An OPERABLE SG i can perform as a heat sink when it has an adequate water
- level and is OPERABLE in accordance with the Steam Generator
[ Tube Surveillance Program. APPLICABILITY In MODE 5 with RCS loops filled, this LCO requires forced circulation to remove decay heat from the core and to provide proper boron mixing. -One SDC loop provides
; sufficient circulation for these purposes.
i
- Operation in other MODES is covered by:
- LCO 3.4.4 "RCS Loops - MODES 1 and 2;"
LCO_3.4.5, "RCS Loops - MODE 3;" LC0 3.4.6 "RCS Loops - MODE 4;"
, LCO 3.4.8 "RCS Loops - MODE 5, loops Not Filled;"
LCO 3.9.4 " Shutdown Cooling (SDC) and Coolant Circulation - High Water Level". (MODE 6); and LCO 3.9.5, "ShutdownCooling(SDC)andCoolant Circulation - Low Water Level" (MODE 6). 3 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.7-4 Revisiong5'
. - -_ _ _ = . . . . _ . . _ _ _ . . _ . _ . . _ _ . . . - _ __ .._ _ _ .
RCS Loops - MODE 5, Loops filled B 3.4,7
. BASES i
AC110NS A.1 and A.2 If the required SDC loop is inoperable and any SGs have secondary side water levels < -50 inches, redundancy for heat removal is lost. Action must be initiated immediately to restore a second SDC loop to OPERABLE status or to restore the water level in the required SGs. Either l Required Action A.1 or Required Action A.2 will restore redundant decay heat removal paths. The immediate Completion Times reflect the importance of maintaining the I availability of two paths for decay heat removal. B.1 and B.2 If no SDC loop is in operation, except as permitted in Note 1, all operations involving the reduction of RCS boron concentration must be suspended. Action to restore one SDC loop to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation .for proper mixing and the margin to criticality must not be reduced in this type of operation. The inmed19*.e Completion Times reflect the importance of maintaining operation for decay heat removal. SURVEILLANCE SR 3.4.7.1 REQUIREMENTS , This SR requires verification every 12 hours that one SDC loop is in operation. Verification includes flow rate. l6 temperature, or pump status monitoring, which help ensure that forced flow is providing decay heat removal. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess- degradation and verify operation is within safety analyses assumptions. In addition control room indication and alarms will normally indicate loop status. CALVERT CLIFFS.- UNITS 1 & 2 B 3.4.7-5 Revision 45
1 I RCS Loops - MODE 5. Loops filled ) B 3.4.7 BASES I The SDC flow is established to ensure that core outlet temperature is maintained sufficiently below saturation to allow time for swapover to the standby SDC loop should the operating loop be lost. SR 3.4.7.2 Verifying the SGs are OPERABLE by ensuring their :;econdary side water levels are 2: -50 inches ensures that redundant heat removal paths are available if the second SDC loop is inoperable. The Surveillance is required to be performed when the LCO requirement is being met by use of the SGs. If both 500 loops are OPERABLE, this SR is not needed. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within safety analyses assumptions. SR 3.4.7.3 Verification that the second SDC loop is OPERABLE ensures that redundant paths for decay heat removal are available. The requirement also ensures that the additional 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 available to the required pumps and valves that are not in operation. The Surveillance is required to be performed g when the LCO requirement is being met by one of two SDC loops, e.g., both SGs have < -50 inches water level. 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. CALVERT CLIFFS - UNITS 1 & 2 8 3.4.7-6 Revisiong5
RCS Loops - MODE 5. Loops Not Filled B 3.4.8 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.8 RCS Loops - MODE 5, Loops Not Filled i BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary 1 function of the reactor coolant is the removal of decay heat ' and transfer of this heat to the shutdown cooling (SDC) heat exchangers. Thesteamgenerators(SGs)arenotavailableas a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid.- l 1 In MODE 5 with loops not filled, only the SDC System can be l , used for coolant circulation. The number of loops in operation can vary to suit the operational needs. The intent of this LCO is to provide forced flow from at least j one SDC loop for decay heat removal and transport and to i require that two paths (i.e., SDC loop No.11 or No.12 for g-Unit No.1, and SDC loop No. 21 or No. 22 for Unit No. 2) be available to provide redundancy for heat removal. > l APPLICABLE In MODE 5, RCS circulation is considered in determining SAFETY ANALYSES the time available for mitigation of the accidental boron dilution event. The SDC loops provide this circulation. The flow provided by one SDC loop is adequate for decay heat removal and for boron mixing. Reactor Coolant System loops - MODE 5 (loops not filled) satisfy 10 CFR 50.36(c)(2)(ii), Criterion 4. LC0 The purpose of this-LC0 is to require a minimum of-two SDC loops be OPERABLE and one of these loops be in operation. An OPERABLE loop is one that is capable of transferring heat from the reactor coolant at a controlled rate. Heat.cannot be removed via the SDC System unless forced flow is used. A , CALVERT CLIFFS - UNITS 1 & 2 B 3.4.8-1 Revision Ar
RCS Loops - MODE 5. Loops Not Filled B 3.4.8 BASES minimum of one running SDC pump meets the LCO requirement for one loop in operation. An additional SDC loop is required to be OPERABLE to meet the single failure criterion. Note 1 permits the $bC pumps to not be in operation for s 15 minutes when switching from one loop to another. The circumstances for stopping both SDC pumps are to be limited to situations when the outage time is short and the core outlet temperature is maintained at least 10'F below S' saturation temperature. The Note prohibits boron dilution or draining operations when SDC forced flow is stopped. l Note 2 allows one SDC loop to be inoperable for a period of f l 2 hours provided that the other loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time when these tests are saft and possible. An OPERABLE SDC loop is composed of an OPERABLE SDC pump capable of providing forced flow to an OPERABLE SDC heat exchanger, along with the appropriate flow and temperature instrumentation for control, protection, and indication. Shutdown cooling pumps are OPERABLE if they are capable of being powered and are able to provide flow if required. APPLICABILITY In MODE 5 with loops not tilled, this LC0 requires core heat 4 removal and coolant circulation by the SDC System. Operation in other MODES.is covered by: LCO 3.4.4. "RCS Loops - MODES 1 and 2;" LCO 3.4.5, "RCS Loops - MODE 3;" LC0 3.4.6, "RCS Loops - MODE 4;" LC0 3.4.7, "RCS Loops - MODE 5. Loops Filled;" LC0 3.9.4, " Shutdown Cooling (SDC) and Coolant Circulation - High Water Level" (MODE 6); and CALVERT CLIFFS - UNITS 1 & 2 8 3.4.8-2 Revision 65
RCS Loops - H0DE 5. Loops Not filled B 3./. 8 4 BASES LCO 3.9.5 "ShutdownCooling(SDC)andCoolant Circulation-LowWaterLevel"(H0DE6). ACTIONS 6.d If the required SDC loop is inoperable, redundancy for heat removal-is lost. Action must be initiated immediately to-i restore a second loop to OPERABLE status. The Completion lf I Time reflects the importance of maintaining the availability of two paths for heat removal. B.1 and B.2 If no SDC loop is OPERABLE or in operation, except as provided in Note 1, all operations involving the reduction
- of RCS boron concentration must be suspended. Action to restore one SDC loop to OPERABLE status and operation must be initiated immediately. Boron dilution requires forced circulation for proper mixing and the margin to criticality must not be reduced in this type of operation. The immediate Completion Time reflects the importance of maintaining operation for decay heat removal.
SURVEILLANCE SR 3.4.8.1 REQUIREMENTS This SR requires verification every 12 hours that one SDC loop is in operation. - Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing decay heat removal. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation is within safety analyses assumptions.
-CALVERT CLIFFS - UNITS 1 & 2- B 3.4.8-3 Revision gf
RCS Loops - MODE 5. Loops Not Filled : B 3.4.8 [ BASES i SR 3.4.8.2 : Verification that the required number of loops are OPERABLE I I ensures that redundant paths for heat removal are available . and that additional loops 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 indicated power available to the required pumps and valves that are not in operation. The f 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 1 i e t i CALVERT CLIFFS . UNITS 1 & 2- B 3.4.8-4 Revision 0 5
Pressurizer B 3.4.9 BASES- ~ The maximum water level limit permits pressure control equipment to function as designed. The limit preserves the steam space during normal operation, thus, both sprays and heatars can operate to maintain the design operating pressure. The level limit also prevents filling the pressurizer (water solid) for anticipated design basis transients, thus ensuring that pressure relief devices (PORVs or pressurizer safety valves) can control pressure by steam relief rather than water relief. If the level limits were exceeded prior to a transient that creates a large , pressurizer insurge volume leading to water relief, the , maximum RCS pressure might exceed the Safety Limit of 4 2750 psia, The requirrment to have two banks of pressur'zer heaters, , which are permanently powered by Class 1E power. supplies. 6 4 ensures that RCS pressure can be maintai.ed. The pressurizer heaters maintain RCS pressure to keen the
- reactor coolant subcooled. Inability to control RCS
. pressure during natural circulation flow could result in loss of single phase-flow and decreased capability to remove core decay heat. APPLICABLE In MODES 1, 2, and 3, the LCO requirement for a steam bubble-SAFETY ANALYSES is reflected implicitly in the at.cident analyses. All analyses performen from a critical reactor condition assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses l neglect the small fraction of noncondensable gases normally present. Safety analyses presented in the UFSAR do not take credit for pressurizer heater operation; however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure. Although the heaters are not specifically used in accident analysis, the need to maintai:. subcooling in the long term 4
'CALVERT CLIFFS - UNITS 1 & 2 B 3.4.9-2 Revision KS-
Pressurizer
, B 3.4.9 BASES-during loss of offsite power, as indicated in 6cnEG-0737 (Ref.1), is the reason for their inclusion. The requirement for emergency power supplies is based on NUREG-0737 (Ref.1). The intent is to keep the reactor coolant in a subcooled condition with natural circulation at hot, high pressure conditions for an undefined, but
- extended, time period after a loss of offsite power. While loss of offsite power is a coincident occurrence assumed in
- the accident analyses, maintaining hot, high pressure conditions over an extended time period is not evaluated in the accident analyses.
The pressurizer satisfies 10 CFR 50.36(c)(2)(ii), Criteria 2 and 3. 4 LC0 The LC0 requirement for the pressurizer to be OPERABLE with water level 2133 inches and s 225 inches ensures that a steam bubble exists. Limiting the maximum operating water
- level preserves the steam space for pressure centrol. The
! LC0 has been established to minimize the consequences of potential overpressure transients. Requiring the presence of a steam bubble is also consistent with analytical assumptions. The LC0 each with requires a capacity 2 150two kW.banks of OPERABLE The minimum heater capacitypressuriz required is sufficient to maintain the RCS near normal operating pressure. By maintaining the pressure near the operating conditions, a wide subcooling margin to saturation can be obtained in the loops. The generic value of 150 kW is derived from the use of 12 heaters rated at 12.5 kW each. The amount needed to maintain pressure is dependent on the ambient heat losses. APPLICABILITY. The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature J CALVERT CLIFFS - UNITS 1 & 2 B 3.4.9-3 Revision,65- _v4 _
Pressurizer B 3.4.9 , BASES resulting in the greatest effect on pressurizer level and , ~ RCS pressure control. Thus, Applicability has been designated for MODES 1 and 2. The Applicability is also provided for MODE 3. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid ] pressure rises caused by normal operational perturbation, such as reactor coolant pump startup. The LC0 does not i apply to MODE 5 (Loops Filled) because LCO 3.4.12, " Low Temperature Overpressure Protection (LTOP) System," applies. The LCO does not apply to MODES 5 and 6 with partial loop
- operation.
In MODES 1, 2, and 3, there is the need to maintain the availability of pressurizer heaters capable of being powered from an emergency power supply. In the event of a loss of offsite power, the initial conditions of these MODES gives the greatest demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. For MODE 4, 5, or 6, it is not necessary to control pressure (by heaters) to ensure loop subcooling for heat transfer. When the Shutdown Cooling System is in service, l this LC0 is not applicable.
-ACTIONS 6 1 and A.2 With pressurizer water level not within-the limit, action must be taken to restore the plant to operation within the bounds of the safety analyses. To achieve this status -the unit must be brought to MODE 3, with the reactor trip breakers open, within 6 hours and to MODE 4 within 12 hours.
This takes the-plant out of the applicable MODES and restores the plant to operation within the bounds of the safety analyses. Six hours is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plant systems. Further pressure and temperature reduction to MODE 4 brings the plant to a MODE where the LCO is not applicable. The CALVERT CLIFFS - UNITS 1 & 2 B 3.4.9-4 Revision 0
Pressurizer B 3.4.9 i BASES 12 hour time to reach the nonapplicable MODE is reasonable based on operating experience for that evolution. Ild If one required bank of pressurizer heaters is inoperable, restoration is required within 72 hours. The Completion ' Time of 72 hours is reasonable considering that a demand caused by loss of offsite power would be unlikely in this period. Pressure control may be maintained during this time using normal station powered heaters. C.1 and C.2 If one required bank of pressurizer heaters is inoperable and cannot be restored within the allowed Completion Time of Required Action B.1, the plant must be brought to a MODE in f which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours and to MODE 4 within 12 hours. The Completion Time of 6 hours is reasonable, based on operating experience, to reach !!0DE 3 from full power in an orderly manner and without challenging safety systems. Similarly, the Completion Time of 12 hours is reasonable, based on operating experience to reach MODE 4 from full power to an orderly manner and withcut challenging plant systems. SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This Surveillance ensures that during steady state operation, pressurizer water level is maintained below the nominal- upper limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess the level for any deviation and verify that operation is within CALVERT CLIFFS - UNITS 1 & 2 8 3.4.9-5 Revision 0
Pressurizer B 3.4.9 BASES safety analyses assumptions. Alarms are also available for early detection of abnormal level indications. SR 3.4.9.2 The Surveillance is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at l their design rating. (This may be done by testing the power supply output and by performing an electrical check on heater element continuity and resistance.) The Frequency of 24 months is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable. REFERENCES 1. NUREG-0737. II.E.3.1, November 1980 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.9-6 Revision 0
Pressurizer Safety Valves B 3.4.10 BASES (Ref. 1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress i analyses prior to resumption of reactor operation. , APPLICABLE All accident analyses in the UFSAR that require safety valve ! SAFETY ANALYSES actuation assume operation of both pressurizer safety valves to limit increasing reactor coolant pressure. The overpressure protection analysis is also based on operation of both safety valves and assumes that the valves open at the high range of the as found setting. These valves must accommodate pressurizer insurges that could occur during a loss of load, loss of main feedwater, or main feedwater line 1 break accident. The startup accident establishes the minimum safety valve capacity. Single failure of a safety i valve is neither assumed in the accident analysis nor required to be addressed by the ASME Code. Compliance with l this specification is required to ensure that the accident analysis and design basis calculations remain valid. The pressurizer safety valves satisfy 10 CFR 50.36(c)(2)(ii), Criterion 3. LCO One pressurizer safety valve is set to open at 2500 psia and one is set to open at 2565 psia. These setpoints are within the. ASME specified tolerance to avoid exceeding the maximum RCS design pressure SL, to maintain accident analysis- , assumptions, and to comply with ASME Code requirements. The upper and lower pressure tolerance limits are based on the 1% tolerance requirements (Ref.1) for lifting pressures above 1000 psig. The limit protected by this specification is the reactor coolant. pressure boundary (RCPB) SL of 110% of design pressure. Inoperability of one or both valves could result in exceeding the SL if a transient were to occur. The consequences of exceeding the ASME pressure
-limit could include' damage to one or more RCS components, 4
CALVERT CLIFFS - UNITS 1 & 2 8 3.4.10-2 Revision 0
._ - .. . _ . - ~ . _ __ _ _ _ _ _ . . . __ .
Pressurizer Safety Valves , B 3.4.10 BASES increased leakage, or additional stress analysis being
- required prior to resumption of reactor operation.
APPLICABILITY In MODES 1 and 2, and portions of MODE 3 above the low , temperature overpressure protection (LTOP) temperature, OPERABILITY of two valves is required because the combined capacity is required to keep reactor coolant pressure below 110% of its design value during certain accidents. MODE 3 is conservatively included, although the listed accidents may not require both safety valves for protection. The LCO is not applicable in MODE 3 when all RCS cold leg temperatures are s 365'F (Unit 1), s 301'F (Unit 2), and 4 MODES 4 and 5, and MODE 6 with the reactor vessel head on, because LTOP protection is provided. Overpressure i protection is not required in MODE 6 with the reactor vessel q head off. The Note allows entry into MODE 3 > 365'F (Unit 1), > 301*F (Unit 2) with the lift settings outside the LCO limits. This permits testing and examination of the safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. The cold setting gives assurance that the-valves 4 are OPERABLE near their design condition. Only one valve at
, a time will be removed from service for testing. The 36 hour exception is based on 18 hour outage time for each of the two valves. The 18 hour period is derived from operating experience that hot testing can be performed within this time frame.
ACTIONS A.1 With one pressurizer safety valve inoperable, restoration must take place within 15 minutes. The Completion Time of 15 minutes reflects the importance of maintaining the RCS CALVERT CLIFFS - UNITS 1 & 2 B 3.4.10-3 Revision 0 1 ,
l Pressurizer PORVs B 3.4.11 B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) BASES BACKGROUND The pressurizer is equipped with two types of devices for pressure relief: pressurizer safety valves and PORVs. The PORV is an electric, solenoid operated valve that is l5 automatically opened at a specific set pressure when the pressurizer pressure increases and is automatically closed on decreasing pressure. The PORY may also be manually operated using controls installed in the control room. An electric, motor operated, normally open, block valve is installed between the pressurizer and the PORV. The function of the block valve is to isolate the PORV. Block valve _ closure is accomplished manually using controls in the control room and may be used to isolate a leaking PORV to permit continued power operation. Most importantly, the block valve is used to isolate a stuck open PORV to isolate the resulting small break loss of coolant accident (LOCA). Closure terminates the RCS depressurization and coolant inventory loss. The PORV and its block valve controls are powered from normal power supplies. Their controls are also capable of being powered from emergency-supplies. Power supplies for the PORV are separate from those for the block valve, Power supply requirements are defined in NUREG-0737, Paragraph II, G.1 (Ref.1) . The PORV setpoint is equal to the high pressure reactor trip setpoint and below the opening setpoint for the pressurizer safety valves as required by Reference 2. The purpose of the relationship of these setpoints is to reduce the-frequency of challenges to the safety valves, which, unlike-the PORV, cannot be isolated if they were to fail open. l5 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-1 Revisiong5
~ Pressurizer PORVs B 3.4.11 BASES The possibility of a small break LOCA through the PORV is reduced when the PORY flow path is OPERABLE. The possibility is minimized if the flow path is isolated. Overpressure protection is provided by safety valves, and analyses do not take credit for the PORV opening for accident mitigation. Pressurizer PORVs satisfy 10 CFR 50.36(c)(2)(ii), Criterion 3. LC0 The LCO requires the two PORVs and their associated block valves to be OPERABLE. The block valve is required to be OPERABLE so it may be used to isolate the flow path if the PORV is not OPERABLE. Valve OPERABILITY also means the PORV.setpoint is correct. Ensuring the PORV opening setpoint is correct reduces the frequency of challenges to the safety valves, which, unlike y the PORVs, cannot be isolated if they were to fail open.. APPLICABILITY In MODES I and 2, and MODE 3 with all RCS cold leg lF temperatures > 365'F (Unit 1), > 301'F (Unit 2), the PORV and its block valve are required to be OPERABLE to limit the potential for a small break LOCA through the flow path. A likely causo for PORV small break LOCA is a result of pressure increase transients that cause the PORV to open.- Imbalances in the energy output of the core and heat removal by the secondary system can cause the RCS pressure to increase to the PORV opening setpoint. Pressure increase transients can occur any time the steam generators are used for heat removal. The most rapid increases will occur at higher operating power and pressure conditions of MODES 1 and 2. Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-3 Revision O'r
Pressurizer PORVs B 3.4.11 BASES Therefore, this LCO is applicable in MODES 1 and 2, and MODE 3 with all RCS cold leg temperatures > 365'F (Unit 1), l6
> 301*F (Unit 2). The LC0 is not applicable in MODE 3 with all RCS cold leg temperatures s 3G5'F (Unit 1), s 301*F i (Unit 2),whenbothpressureandcoreenergyaredecreased and the pressure surges become much less significant. The PORV setpoint is reduced for LTOP in MODE 3 with T,n s 365'F I (Unit 1), s 301'F (Unit 2) and in MODES 4, 5, and 6 with the reactor vessel head in place. LCO 3.4.12 addresses the PORV requirements in these MODES.
ACTIONS 1he ACTIONS are modified by two Notes. Note 1 clarifies that the pressurizer PORVs and block valves are treated as 5 separate entities, each with separate Completion Times (i.e., the Completion Time is on a component basis). Note 2 is an exception to LC0 3.0.4. The exception to LC0 3.0.4 permits entry into MODES 1, 2, and 3 to perform cycling of the PORV or block valve to verify their OPERABLE status. Testing is typically not performed in lower MODES. A.1 With one or two PORVs inoperable and capt. ole of being manuallycycled,eithertheinoperablePORV(s)mustbe restored or the flow path isolated within 1 hour. The block valve should be closed but power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. Although the PORV may be designated inoperable, it may be able to be manually opened and closed and in this manner can be used to perform its function. Power operated relief valve-inoperability may-be due to seat leakage, instrumentation problems, automatic control problems, or other causes that do not prevent manual use and do not create a possibility for a small break LOCA. For these reasons,'the block valve may be closed but the , Action requires power be maintained to the valve. This l
- Condition is only intended to permit operation of the plant ;
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-4 Revision A5 l 4
Pressurizer PORVs B 3.4.11 BASES for a limited period of time not to exceed the next refuelingoutage(MODE 6)sothatmaintenancecanbe performed on the PORVs to eliminate the problem condition. > The PORVs should normally be available for automatic mitigation of overpressure events and should be returned to OPERABLE status prior to entering startup (MODE 2). Quick access to the PORV for pressure control can be made ; when power remains on the closed block valve. The 1 Completion Time of 1 hour is based on plant operating experience that minor problems can be corrected or closure can be accomplished in this time period. S B.I. B.2. and B.3 If one PORV is inoperable and not capable of being manually cycled, it must either be isolated, by closing the associated block valve and removing the power from the block l valve, or restored to OPERABLE status. The Completion Time of 1 hour is reasonable, based on challenges to the PORVs i during this time period, and provides the operator adequate time to correct the situation. If the inoperable valve cannot be restored to OPERABLE status, it must be isolated I within the specified time. Because there is at least one PORY.that remains OPERABLE, 5 days are provided to restore 6 the inoperable PORV to OPERABLE status. C.1 and C.2 If one block valve is inoperable, then.it must be restored to OPERABLE status, or the associated PORY placed in override closed. The prime importance for the capability to close the block valve is to isolate a stuck open PORV. Therefore, if the block valve cannot be restored to OPERABLE status within.1 hour, the Required Action is to place the PORV in override closed to preclude its automatic opening for an overpressure event and to avoid the potential for a CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-5 Revision #y
Pressurizer PORVs B 3.4.11 BASES-stuck open PORV at a time that the block valve is inoperable. The Completion Times of I hour are reasonable based on the small potential for challenges to the system during this time period and provide the operator time to { correct the situation. Because at least one PORY remains OPERABLE, the operator is permitted a Completion Time of l 5 days to restore the inoperable block valve to OPERABLE 5 states. The time allowed to restore the block valve is based upon the Completion Time for restoring an inoperable PORV in Condition B since the PORVs are not capable of automatically mitigating an overpressure event when placed l in override closed. If the block valve is restored within the Completion Time of 5 days, the power will be restored and the PORV restored to OPERABLE status. l5 D.I. D.2. and D.3 If both PORVs are inoperable and not capable of being manually cycled, it is necessary to either restore at least t-one valve within the Completion Time of 1 hour or isolate-the flow path by closing and removing the power to the-associated block valves. The Completion Time of 1 hour is reasonable based on the small potential for challenges to the system <iuring this time and provides the operator time to correct the situation. .If Required Actions D.1 and D.2 have been completed, Required Action D.3 allows 72 hours -to restore a PORV to OPERABLE status. This time is reasonable to perform required repairs. This time also accounts for the overpressure protection provided by the pressurizer safety valves in LCO 3.4.10. E.1 and E.2 If both block valves are inoperable, it is necessary to either restore the block valves within the Completion Time of 1 hour or place the associated PORVs in override closed and restore at least one block valve to OPERABLE status CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-6 Revision E t
Pressurizer PORVs B 3.4.11 BASES' within 72 hours and the remaining block valve in 5 days, per g Required Action C.2. The Completion Time of 1 hour to either restore the block valves or place the associated PORVs in override closed is reasonable based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. F.1 and F.2 If the Required Actions and associated Completion Times are not met, then the plant must be brought to a MODE in which the LC0 does not apply. The plant must be brought to at least MODE 3 within 6 hours and reduce any RCS cold leg 5 temperature s 365'F (Unit 1), s 301'F (Unit 2) within 12 hours. The Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging safety systems. Similarly, the Completion Time of 12 hours to iy reduce any RCS cold leg temperature s 365'F (Unit 1), I s 301'F (Unit 2) is reasonable considering that a plant can cool down within that time frame. In MODE 3 with any RCS g-cold 1eg temperature's 365'F (Unit 1), s 301*F (Unit 2) and i_n MODES 4, 5, and 6. maintaining PORV OPERABILITY is required per LC0 3.4.12. ' SURVEILLANCE SR 3.4.11.1 REQUIREMENTS A CHANNEL FUNCTIONAL TEST is performed on each PORV instrument channel every 92 days to ensure the entire channel will perform its intended function when needed, i SR 3.4.11.2 Block valve cycling verifies that it can be closed if necessary. The basis for the Frequency of 92 days is American Society of Mechanical Engineers (ASME) Section XI CALVERT CLIFFS'- UNITS 1 & 2 B 3.4.11-7 Revision gy
Pressurizer PORVs B 3.4.11 BASES (Ref. 3). If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance because opening the block valve is necessary to permit the PORV to be used for manual control of RCS pressure. If the block valve is closed to isolete an otherwise inoperable PORV, the maximum Completion Time to restore the PORV and open the block valve is 120 hours, which is well within the allowable limits (25%) to extend the block valve surveillance interval of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e., completion of the Required Action fulfills the SR). The Note modifies this SR by stating that this SR is not required to be performed with the block valve closed in accordance with the Required Actions of this LCO. SR 3.4.11.3 SR 3.4.11.3 requires complete cycling of each PORV. Power operated relieve valve cycling demonstrates its function. The Frequency of 24 months is based on a typical refueling cycle and indus,try accepted practice. SR 3.4.11.4 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 24 months to adjust the whole channel so that it responds and the valve opens within the required range and with accuracy to known input. The 24 month Frequency considers operating experience with equipment reliability and matches the refueling outage Frequency. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.11-8 Revision 0
Pressurizer PORVs 1-B 3.4.11 BASES
- - -REFERENCES 1. NUREG-0737. Paragraph II, G.I. November 1980
- 2. Inspection and Enforcement (IE) Bulletin 79-058,
!- April 21, 1979
- 3. ASME, Boiler and Pressure Vessel Code, Section XI 1
.i
--l CALVERT CLIFFS - UNITS 1 & 2 8 3.4.11-9 Revision 0
LTOP System B 3.4.12 -l l B 3.4 REACTOR COOLANT SYSTEM (RCS) l
- B 3.4.12 Low Temperature Overpressure Protection (LTOP) System BASES BACKGROUND The LTOP System controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not com pomised by violating the pressure and temperature (P/T)limitsof10CFRPart50.AppendixG (Ref.1). The reactor vessel is the limiting RCPB component for demonstrating such protection. LC0 3.4.3, "RCS Pressure
- andTemperature(P/T) Limits,"providestheallowable combinations for operational pressure and temperature during cooldown, shutdown, and heatup to keep from violating the Reference 1 requirements during the LTOP MODES.
The reactor vessel material is less tough at low 1 temperatures than at normal operating temperatures. As the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at lowtemperatures(Ref.2). Reactor Coolant System pressure, 1 therefore, is maintained low at low temperatures and is increased only as temperature is increased. The potential for vessel overpressurization is most acute 4 when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can occur more quickly than an
- operator can react to relieve the condition. Exceeding the-RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LC0 3.4.3 requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the.P/T limits.
This LC0 provides RCS overpressure protection by having a minimum coolant input capability and having adequate pressure relief capacity. Limiting coolant input capability requires all but one high pressure safety injection (HPSI) pump incapable of injection into the RCS and this HPSI pump 5
' CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-1 Revisionfff 6
LTOP System B 3.4.12 BASES will only be capable of manually injecting into the RCS. When suction of this HPSI pump is aligned to the Refueling Water Storage Tank (RWT), the HPSI pump will be throttled unless an adequate vent path exists. The HPSI motor 5 operator valves must be in pull-to-override so that valves do not automatically actuate. In addition, administrative controls are placed on charging pump operation. The pressure relief capacity requires either two OPERABLE , redundant power operated relief valves (PORVs), one PORV and an RCS vent of 1.3 square inches, or the RCS depressurized g ! and an RCS vent of 2.6 square inches. One PORV or the 1.3 ) square inch RCS vent is the overpressure protection device that acts to terminate an incrasing pressure event. The extra PORV or extra 1.3 square inch vent is for single failure criteria. With minimum coolant input capability, the ability to provide core coolant addition is restricted. The safety injection (SI)actuationcircuitsareblockedtoHPSI. If I conditions require the use of more than one HPSI for makeup in the event of loss of inventory, then pumps can be made available through manual actions. The LTOP System for pressure relief consists of two PORVs with reduced lift settings, one PORV with reduced lift setting and an RCS vent of 1.3 square inches, or an RCS vent of 2.6 square inches. Two relief valves are required for y redundancy. One PORV has adequate relieving capability to prevent overpressurization for the required coolant input capability. PORV- Reoui rements As designed for the LTOP System, each PORV is signaled to open if the RCS pressure approaches a limit determined by the LTOP actuation logic. The actuation logic monitors RCS temperature and pressure and determines when the LTOP i overpressure setting is approached. If the indicated CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-2 Revision 9 5
LTOP System !
; B 3.4.12 BASES pressure meets or exceeds the calculated value, a PORV is signaled to open.
The LCO presents the PORV setpoints for LTOP. Having the setpoints of both valves within the limits of the LCO , ensures the P/T limits will not be exceeded in any analyzed event. When a PORV is opened in an increasing pressure transient, , the release of coolant causes the pressure increase to slow and-reverse. As the PORY releases coolant, the system pressure decreases until a reset pressure is reached. At this point the event is terminated and the operator manually closes the PORV. RCS Vent Reauirements Once the RCS is depressurized, a vent exposed to the
. containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the capabilities of the vent. Thus, the vent path must be capable of relieving the flow resulting from the limiting LTOP mass or heat input transient and maintaining pressure below the P/T limits. The required vent capacity may be provided by one or more vent paths.
If the vent path is 2 8 square inches (e.g., removing the pressurizer manway) the RCS can not be pressurized above the P/Tlimits,andtheLTOPSystemisnotrequired. 6 APPLICABLE Safety analyses-(Ref. 3) demonstrate that the reactor vessel SAFETY ANALYSES is adequately protected against exceeding the Reference 1 P/Tlimitsduringshutdown. In MODES 1 and 2, and MODE 3 with all RCS cold leg temperatures > 365'F (Unit 1), > 301*F s-(Unit 2), the RCPB is sufficiently above the nil-ductility-temperature that the pressurizer safety valves prevent CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-3 Revision fry
LTOP System B 3.4.12 BASES brittle fracture. At 365'F (Unit 1), 301*F (Unit 2) and- lI below, overpressure prevention falls to the OPERABLE PORVs and administrative controls or to a depressurized RCS and a 5 sufficient sized RCS vent. Each of these means has a limited overpressure relief capability. Each time the P/T limit curves are revised, the LTOP System will- be re-evaluated to ensure its functional requirements can still_be satisfied using the PORY method or the depressurized'and vented RCS condition. Reference 3 contains the acceptance limits that satisfy the LTOP requirements. -Any change to the RCS must be evaluated against these analyses to determine the impact of the change on the LTOP acceptance limits. Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients, examples of which follow: Mass Inout Tvoe Transients
- a. Inadvertent high pressure safety injection pump start;
- b. Inadvertent HPSI and charging pump start; or c.--Charging /letdownflowmismatch.
Heat Inout Tvoe Transients
- a. Inadvertent actuation of pressurizer heaters;
- b. Loss of shutdown cooling (SDC); or
- c. Reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.
CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-4 Revisiongy
LTOP System B 3.4.12 BASES The following are required during the LTOP MODES to ensure that mass and heat input transients do not occur, which either of the LTOP overpressure protection means cannot handle:
- a. Rendering all but one HPSI pump incapable of injection and blocking automatic initiation from the remaining HPSI pump;
- b. When HPSI suction is aligned to the RWT, the HPSI pump shall be in manual control and either:
- 1) HPSI flow is limited to s 210 gpm, or l
- 2) an RCS vent > 2.6 square inches is established;
- c. Reading HPSI motor operator valves (MOVs) only capable of manually aligning HPSI pump flow to the RCS;
- d. Running only one charging pump when injecting via HPSI (chargingnumprequirementsarecontrolled f administratively);and
- e. Maintaining a pressure' bubble with level s 170 inches, y The Reference 3 analy:es demonstrate that either one PORV or the RCS vent and pressurizer steam volume can maintain RCS I pressure below limits when only one HPSI pump is actuateri provided two of the three HPSI pumps are disabled and the remaining HPSI pump's flow is throttled. If HPSI pump flow is not throttled during addition of mass to the RCS through on HPSI loop M0V, then two PORVs or an RCS vent 2 2.6 g-square inches are capable of maintaining RCS pressure below limits. Thus, the LC0 allows only one HPSI pump OPERABLE with flow throttled, or with an RCS vent 2 2.6 square inches during the LTOP MODES.
Also to limit pressure overshoot over the PORV setpoint, the remaining HPSI and two charging pumps are rendered _ incapable CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-5 Revision /IS-
LTOP System B 3.4.12 BASES of injection, and the RCPs are disabled during water solid operation. Heatup and cooldown analyses established the temperature of LTOP Applicability at 365'F (Unit 1), and 301'F (Unit 2) and below based on SRP criteria. Above this temperature, the RCPB is sufficiently above the nil-ductility temperature and the pressurizer safety valves provide the reactor vessel pressure protection against brittle fracture. The vessel materials were assumed to have a fluence level equal to 2 2.61 x 10" n/cm (Unit 1), 4.0 x 10" n/cm' (Unit 2). The consequences of a loss of coolant accident (LOCA) in LTOP conform to 10 CFR 50.46 and 10 CFR Part 50, Appendix K (Refs. 4 and 5), requirements by having SITS operable in , MODE 3 and one HPSI pump available for manual actuation. PORV Performance The fracture mechanics analyses show that the vessel is protected when the PORVs are set to open at or below the curves in Figure 3.4.12-1 and are applicable when the g Shutdown Cooling (SDC) System is not in operation. The setpoint is derived by modeling the performance of the LTOP System, assuming the limiting case of loss of SDC and one charging pump injecting into the RCS during water solid operation. Thase analyses consider pressure overshoot beyond the PORV opening setpoints, resulting from signal
-processing and valve stroke times. The PORV setpoints below the derived limit ensure the Reference 1 limits will be met.
When the SDC System is in operation, the PORV lift setting must be s 429 psia (Unit 1), s 443 psia (Unit 2). This ensures that the PORV lift setting is low enough to mitigate 5' overpressure transients when SDC is in operation, since RCS temperature measurement is not accurate in this condition. The PORV setpoints will be re-evaluated for compliance when the revised P/T limits conflict with the LTOP analysis CALVERT CLIFFS - UNITS 1 & 2 B-3.4.12-6 Revision g y ~. - - -
LTOP System B 3.4.12 y BASES limits. The P/T limits are periodically modified as the reactor vessel material toughness decreases due to embrittlement caused by neutron irradiation. RevisedP/T limits are determined using neutron fluence projections and the' results of examinations of the reactor vessel material irradiation surveillance specimens. However, the Calvert Cliffs' P/T limits are not projected to t.hange through the . end of Calvert Cliffs current operating license. The Bases forLC03.4.3,"RCSPressureandTemperature(P/T) Limits," discuss these examinations. The PORVs are considered active components. Thus, the failure of one PORV represents the worst case, single active failure. RCS Vent Performance With the RCS depressurized, analyses show a vent size of 1.3 square inches is capable of mitigating the limiting allowed LTOP overpressure transient provided a pressurizer steam volume exists, two of the three HPSI pumps are g disabled and the remaining HPSI pump's flow is throttled. In that event, this size vent maintains RCS pressure less thanthemaximumRCSpressureontheP/Tlimitcurve.-A 2.6 square inch vent is required to allow for single failures of other equipment, such as HPSI throttle valves. An 8 square inch vent is sufficient to preclude RCS overpressure events. Therefore, when an 8 square inch vent g is established, LTOP System requirements are not necessary to maintain RCS pressure within limits. The RCS vent size will also be re-evaluated for compliance eachtimetheP/Tlimitcurvesarerevisedbasedonthe results of the vessel material surveillance. The RCS vent is passive and is not subject to active , failure. ' CALVERT CLIFFS - UNITS 1 & 2 8 3.4.12-7 Revision #5
LTOP System B 3.4.12 BASES LTOP System satisfies 10 CFR 50.36(c)(2)(ii) Criterion 2. LC0 This LC0 is required to ensure that the LTOP System is OPERABLE. The LTOP System is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient. To limit the coolant input capability, the LC0 requires a maximum of one HPSI pump only capable of manually injecting into the RCS. This is accomplished by disabling two HPSI pumps by either removing (racking out) their motor circuit breakers from the electrical power supply circuit or by locking shut their discharge valves. During required testing, other means of preventing two HPSI pumps from injecting into the RCS may be used. In addition, when not in use the remaining HPSI pump shall have its handswitch in pull-to-lock. When HPSI suction is aligned to the RWT for 5 injection into the RCS, the HPSI pump must be in manual control and either HPSI flow shall be limited to s 210 gpm or an RCS vent of 2 2.6 square inches is established. To provide single failure protection against a HPSI pump mass addition transient, the HPSI loop HOV handswitches must be placed in pull-to-override so the valves do not automatically actuate upon receipt of a safety injection signal. During required testing this requirement may be suspended. The elements of the LC0 that provide overpressure mitigation through pressure relief are:
- a. Two OPERABLE PORVs and associated block valves open;
- b. One OPERABLE PORV and associated block valve open and an RCS vent open with an area 21.3 square inches; or Y CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-8 RevisionpT
LTOP System B'3.4.12 BASES
- c. The depressurized RCS and an RCS vent open with an area g 2 2.6 square inches.
A PORY_is OPERABLE for LTOP when its block valve is open, its lift setpoint is set in accordance with the LCO and testing has proven its ability to open at that setpoint, and motive power is avaibble to the two valves and their control circuits. The combination of these methods of overpressure prevention 5 (as specified in LCO 3.4.12) are capable of mitigating the limiting LTOP transient. l6 APPLICABILITY This LC0 is applicable in MODE 3 when the temperature of any g RCS cold leg is s 365'F (Unit 1), s 301'F (Unit 2), in-MODES 4, 5.-and 6. LC03.4.3providestheoperationalP/TlimitsforallMODES. LC0 3.4.10. " Pressurizer Safety Valves," requires the OPERABILITY of the pressurizer safety valves that provide overpressure protection during MODES 1 and 2, and MODE 3 i above 365'F (Unit 1), 301'F (Unit 2). Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event. The Applicability is modified by a _ Note stating- that this Specification is not applicable when the RCS is vented 2 8 square inches. An RCS vent of this size precludes RCS overpressure events. ACTIONS A Note-to the ACTIONS restricts entry into MODES or other specified conditions in the Applicability of this LC0 while
~
6 i CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-9 Revisiongf
LTOP System B 3.4.12 4 . BASES complying with'the ACTIONS (i.e., while the LC0 is not met). LC0 3.0.4 typically allows entry into MODES or other specified conditions in the Applicability as part of any y unit stutdown, however, the restriction of this Note is necessary to assure low temperature overpressure protection is available prior to operating within the Applicability of this LCO. A.1 With one or more HPSI pumps capable of automatically g injecting into the RCS or with two or more HPSI pumps capable of manually injecting into the RCS, overpressurization is possible. The immediate Completion Time to initiate actions to restore restricted coolant input capability to the RCS reflects the importance of maintaining overpressure protection of the RCS, bl With HPSI flow > 210 gpm and suction aligned to the RWT and an RCS vent <-2.6 square inches established, sufficient overpressure protection may not exist and overpressurization may be possible. The immediate Completion Time to initiate actions to reduce HPSI flow to s; 210 gpm reflects the importance of maintaining overpressure protection of the RCS. f C.1 With one or more HPSI loop MOVs capable to automatically aligning HPSI pump flow to the RCS, single failure protection against a HPSI pump mass addition transient is CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-10 Revision 75
LTOP System B 3.4.12 BASES lost. Therefore, action is required to be immediately initiated to restore single failure protection by placing the affected HPSI loop MOV handswitch to pull-to-override, or shutting and disabling the affected HPSI loop MOV, or isolating the affected HPSI header flow path, f The immediate Completion Time to initiate action to restore single failure protection for the HPSI pump mass addition transient reflects the importance of restoring single failure protection for low temperature overpressurization
- mitigation.
1 9l 5 In MODE 3 when any RCS cold leg temperature is s 365'F (Unit 1), s 301'F (Unit 2) or in MODE 4, with one of the two g i required PORVs inoperable and an RCS vent < 1.3 square
- inches established, the inoperable PORY must be restored to
-OPERABLE status within a Completion Time of 5 days. _ The i inoperable PORV is required to meet the LCO requirement and to provide low temperature overpressure mitigation while withstanding a single failure of an active component.
The Completion Time is based on the fact that 'only one PORV is required to mitigate an overpressure transient. E.d lY The consequences of operational events that will overpressure the RCS are more severe at lower temperature (Ref. 6). Thus, with one of the two required PORVs inoperable and an RCS vent < 1.3 square inches established I in MODE 5 or in MODE 6,.the Completion Time to restore two ' valves to OPERABLE status is 24 hours. The 24 hour Completion Time to restore the inoperable PORV to OPERABLE status in MODE 5 or in MODE 6 is a reasonable CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-11 Revision #5'
LTOP System B 3.4.12 BASES amount of time to investigate and repair several types of PORV failures without exposure to a lengthy period with only one PORV OPERABLE to protect against overpressure events. F.1 l5 If the required Actions and associated Completion Times of Condition D or E cannot be met the RCS is requi/Jd to be- f depressurized and vented through a vent 21.3 :"w inches. This action must be completed within 48 qours, y This action along with the OPERABLE PORY restores single failure protection and ensures the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. This action protects the RCPB from an overpressure event and a possible brittle failure of the reactor vessel. The Completion Time of 48 hours to depressurize and vent the RCS is based on the time required to place the plant in this condition and in a controlled manner. The probability of an overpressure event occurring along with a single failure of the remaining OPERABLE PORV is unlikely. b.1 5 If all required PORVs -(i.e., when one PORV is required and it is _ inoperable or when two PORVs are required and t,oth are f inoperable) are inoperable, the RCS must be depressurized and a vent established within 48 hours. The vent must be sized at least 2.6 square inches to ensure the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. This action protects the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel. The Completion Time of 48 hours to depressurize and vent the RCS is based on the time required to place the plant in this CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-12 Revision p'y
LTOP System B 3.4.12 BASES condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements. SURVEILLANCE SR 3.4.12.1 and SR 3.4.12.2 REQUIREMENTS h To minimize the potential for a low temperature overpressure event by limiting the mass input capability, verification that a maximum of one HPSI pump is only capable of manually injecting into the RCS and automatic alignment of the HPSI g loop MOVs, is prevented (by disabling the automatic opening featuresoftheHPSIloopMOVs)isrequired. The HPSI pumps are rendered incapable of injecting into the RCS through
-removing the power from the pumps by racking the breakers out under administrative control or by verifying their discharge valves are locked shut.
The 12 hour interval considers operating practice to regularly assess potential degradation and to verify operation within the safety analysis. SR 3.4.12.3 f SR 3.4.12.3 requires verifying that the required RCS vent is l5
-open once every 12 hours for a valve that is unlocked open and once every 31 days for a valve that is locked open. lf The passive vent arrangement must only be open to be OPERABLE. This Surveillance need only be performed if the vent is being used to satisfy the requirements of this LCO.
The Frequencies consi6'r operating experience with mispositioning of unlocked and locked vent valves, respectively. SR 3.4.12.4 5 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-13 Revision A f
i l LTOP System B 3.4.12 BASES ' The PORV block valve must be verified open every 72 hours to provide the flow path for each required PORV to perform its l function when actuated. The valve can be remotely verified I open in the main control room, i The block valve is a remotely controlled, motor operated valve. The power to the valve motor operator is not required to be removed, and the manual actuator is not i required locked in the inactive position. Thus, the block l valve can be closed in the event the PORV develops excessive leakageordoesnotclose(sticksopen)afterrelievingan overpressure event. I The 72 hour Frequency considers operating experience with accidental movement of valves having remote control and position indication capabilities available where easily initored. These considerations include the administrative ntrols over main control room access and equipment introl. SR 3.4.12.5 l6 Performance of a CilANNEL FUNCTIONAL TEST is required every 31 days to verify and, as necessary, adjust the PORV open setpoints. The CHANNE1. FUNCTIONAL TEST will verify on a monthly basis that the PORY lift setpoints are within the LCU limit, Power operated relief valve actuation could depressurize the RCS and is not required. The 31 day Frequency considers ey.perience with equipment reliability. A Note has been added indicating this SR is required to be performed 12 hours after decreasing RCS cold leg temperature to s 365'F (Unit 1), s 301'F (Unit 2). The test cannot be performed until the RCS is in the LTOP MODES when the PORV lift setpoint can be reduced to the : TOP setting. The test must be performed within 12 hours after entering the LTOP MODES. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.12-14 .Revisionp5
LTOP System B 3.4.12 B_ASES SR 3.4.12.6 lf Performance of a CHANNEL CAllBRATION on each required PORV actuation channel is required every 24 months to adjust the whole channel so that it responds and <he valve opens within the required LTOP range . ,d with accuracy to known input. The 24 month Frequency considers operating experience with equipment reliability and matches the typical refueling outage schedule. REFERENCES 1. 10 CFR Part 50, Appendix G
- 2. Generic Letter 8811
- 3. UFSAR, Section 4.2.2
- 4. 10 CFR 50.46 5.- 10 CFR Part 50, Appendix K
- 6. Generic Letter 90-06 e
i CALVERT. CLIFFS - UNITS 1 & 2 .B 3.4.12-15 Revision 55-l . , - , . , ~ , . . ~ , = , _ , . . , . . . _ _ _ - . , _ . _ . . _ ~ , , _ . - _ . _ - , _ . , . . - . , _ . . , _ . _ - . . . - . _ _ . , _ - _ _ , . _ . _ , _ - _ _ - _ - _ . _ , ,
1 i RCS Operational LEAKAGE j B 3.4.13 BASES i i The allowed Completion Times are reasonable, based on l operating experience, to reach the required conditions from full power conditions in an orderly manner and without , challenging plant systems. In MODE 5, the pressure stresses acting on the RCPB are much lower, and further deterioration ' is much less likely. SURVEILLANCE SR 3.4.13.1 REQUIREMENTS . i Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection. Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance. Primary to secondary LEAKAGE is also measured by performance of an RCS water inventory balance in conjunction with effluent monitoring within the secondary steam aad feedwater systems. The RCS water inventory balance must be performed with the -j reactor at steady state operating conditions and near i operating pressure. y
- Steady state operation is required to_ perform a proper water inventory ba13nce, calculations during maneuvering are not f '
useful. For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS y I pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal leakoff flows - l An early warning of pressure boundary LEAKAGE or unidentified LEAKAGE is provided by the automatic systems that monitor the containment atmosphere radioactivity and the containment sump level. These_ leakage detection systems are specified in LCO 3.4.14. "RCS Leakage Detection & Instrumentation." CALVERT CLIFFS - UNITS 1 & 2 B.3.4.13 . Revision g g i i: _nw ,
l RCS Operational LEAKAGE B 3.4.13 BASES The 72 hour Frequency is a reasonable interval to trend LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. A Note under the Frequency column states that this SR is only required to be i performed during steady state operations. SR 3.4.13.2 This SR provides the means necessary to determine SG OPERABILITY in an operational MODE. The requirement to de:nonstrate SG tube integrity in accord 6nce with the Steam Generator Tube Surveillance Program emphasizes the ; importance of SG tube integrity, even thcugh this ' Surveillance cannot be performed at normal operating i conditions. In the event one or more steam generators are determined to not meet the requirements of the SG Tube Surveillance Program at anytime in MODES 1 through 4, action to comply f with LCO 3.0.3 must be taken. REFERENCES 1. UFSAR, Appendix 10, Criterion 16 I
- 2. Regulatory Guide 1.45, May 1973.
- 3. UFSAR, Section 14.15
- 4. UFSAR, Section 14.14 g CALVERT CLIFFS - UNITS 1 & 2 B 3.4.13-6 Revisiongg
RCS Leakage Detection Instrumentation B 3.4.14 BASES both particulate and gaseous activities, because of their sensitivities and responses to RCS LEAKAGE. These radioactivity monitors have a range of 10 -10' counts per 3 5' minute (cpm). An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment which would be an indicator of potential RCS LEAKAGE. Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow into or from the containment sump. Humidity level monitoring is considered most useful as an indication to alert the operator to a potential problem. Humidity monitors are not required by this LCO. Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values-may indicate RCS LEAKAGE into the containment. The relevance of temperature and pressure measurements are affected by containment free volume and, for temperature,_ detector location. Alarm signals.from these instruments can be valuable in recognizing rapid and sizable leakage to the containment. Temperature and pressure monitors are not required by this LCO. APPLICABLE The need to evaluate the severity of an alarm or an SAFETY ANALYSES indication is important to the operators, and the ability to compare and verify with indications from other systems is necessary. The RCS Leak Detection Instrumentation is described in the UFSAR (Ref. 3). Multiple instrument locations are utilized, if needed, to help identify the location of the LEAKAGE and its source. The safety significance of RCS LEAKAGE varies widely depending on its source, rate,-and duration. Therefore, CALVERT CLIFFS - UNITS 1 & 2 B 3.4.14-2 Revision #5-
RCS Leakage Detection Instrumentation B 3.4.14 BASES detecting and monitoring RCS LEAKAGE into the containment area are necessary, Quickly separating the identified , LEAKAGE from the Ridentified LEAKAGE provides quantitative , information to the operators, allowing them to take l corrective action should leakage occur detrimental to the I safety of the facility and the public. Reactor Coolant System leakage detection instrumentation satisfies 10 CFR 50.36(c)(2)(ii) Criterion 1. ' LCO One method of protecting against large RCS LEAKAGE derives from the ability of instruments to rapidly detect extremely. small leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected in time to allow actions to place the plant in a safe condition when RCS LEAKAGE indicates possible RCPB degradation. The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment sump monitor, in combination with a particulate or gaseous radioactivity monitor provides an acceptable minimum. APPLICABILITY Because of elevated RCS temperature and pressure in H0 DES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE. In H0DE 5 or 6, the temperature is s 200'F and pressure is :' maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for H0 DES 1, 2, 3, and 4 the likelihood of leakage and crack CALVERT CLIFFS - UNITS 1 & 2 B 3.4.14-3 Revision 0
RCS Leakage Detection Instrumentation l B 3.4.14 t l BASES l propagation is much smaller. Therefore, the requirements of j this LCO are not applicable in MODES 5 and 6. ACTIONS The actions are modified by a Note that indicates the l provisions of LCO 3.0.4 are not applicable. As a result, a ) H0DE change is allowed when the containment sump and l required radiation monitor channels are inoperable. This allowance is provided because other means are available to monitor for RCS LEAKAGE. A.1 and A.2 If the containment sump level alarm is inoperable, no other form of sampling can provide the equivalent information. However, the containment atmosphere radioactivity monitor will provide indications of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance SR 3.4.13.1, must be performed at an increased frequency of 24 hours to provide information that is adequate to detect leakage. 5 Restoration of the sump level alarm to OPERABLE status is required to regain the function in a Completion Time of 30 days after the monitor's failure. This time is acceptable considering the frequency and adequacy of the RCS water inventory balance required by Required Action A.1. B.1.1. B.1.2. and B.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is- required. Either grab samples of the containment atmosphere must be taken and ' analyzed, or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic CALVERT_ CLIFFS - UNITS 1 & 2 B 3.4.14-4 Revision g f
RCS Leakage Detection Instrumentation B 3.4.14 BASES information. With a sample obtained and analyzed or an inventory balance performed every 24 hours, the reactor may be operated for up to 30 days to allow restoration of at least one of the radioactivity monitors. The 24 hour interval provides periodic information that is adequate to detect leakage. The 30 day Completion Time f recognizes at least one other form of leakage detection is available. C.1 and C.2 If any required Action of Condition A or B cannot be met within the required Completion Time, the plant must be 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 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. Ad If all required alarms and monitors are inoperable, no automatic means of monitoring leakage are available and intnediate plant shutdown in accordance with LCO 3.0.3 is required. SURVEILLANCE SR 3.4.14.1 REQUIREMENTS SR 3.4.14.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitors. The check gives reasonable confidence the channel is operating properly. The frequency of 12 hours is based on CALVERT CLIFFS - UNITS l'& 2 B 3.4.14-5 Revision 45-
l RCS Leakage Detection Instrumentation B 3.4.14 BASES l instrument reliability and is reasonable for detecting off normal conditions. SR 3.4.14.? SR 3.4.14.2 requires the performance of a CHANNEL FUNCTIONAL TEST of the required containment atmosphere radioactivity monitors. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper-for detecting __ degradation. SR 3.4.14.3 and SR 3.4.14.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 24 months is a typical refueling cycle and considers channel reliability. Operating experience has shown this Frequency is acceptable. REFERENCES 1. UFSAR, Appendix IC, Criterion 16
- 2. Regulatory Guide 1.45
- 3. UFSAR, Section 4.3 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.14-6 Revision 0
RCS Specific Activity B 3.4.15 i B 3.4 REACTORCOOLANTSYSTEM(RCS) B 3.4.15 RCS Specific Activity , BASES I l BACKGROUND- The Code of Federal Regulations, 10 CFR Part 100 specifies ' the maximum dose to the whole body and the thyroid an individual at the site boundary can receive for 2 hours during an accident. The limits on specific activity ensure that the doses are held to within the acceptance criteria I given in the UFSAR (Ref.1) during analyzed transients and accidents. The RCS specific activity LCO limits the allowable concentration level of radionuclides in the reactor coolant. The LCO limits are established to minimize the offsite radioactivity dose consequences in the event of a steam generatortuberupture(SGTR) accident. The LCO contains specific activity limits for both DOSE EQUIVALENT I-131 and gross specific activity. The allowable 6 levels are intended to limit the dose at the site boundary to within the acceptance criteria given in the UFSAR g (Ref.1). APPLICABLE The LCO limits on che specific activity of the reactor SAFETY ANALYSIS coolant ensure that the resulting doses at the site boundary will not exceed the acceptance criteria given in the UFSM i-(Ref.1). The SGTR safety analysis (Ref. 2) assumes the specific activity of the reactor coolant at the LCO limits and an existing reactor coolant steam generator (SG) tube leakage rate of 1 gpm. The rise in pressure in the ruptured SG causes radioactively contaminated steam to discharge to the atmosphere through the atmospheric dump valves and the main steam safety valves. CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-1 Revision 56
l l RCS Specific Activity B 3.4.15 l BASES The safety analysis shows the radiological consequences of an SGTR accident are within the Reference 1 acceptance criteria. Operation with iodine specific activity levels greater than the LCO limit is permissible, if the activity levels do not exceed the limits shown in Figure 3.4.15-1 for more than 100 hours. The remainder of the above limit permissible iodine levels shown in Figure 3.4.15-1 are acceptable because of the low probability of an SGTR accident occurring during the established 100 hour time limit. The occurrence of an SGTR accident at these permissible levels could increase the site boundary dose levels beyond the acceptance criteria given in theUFSAR(Ref.1). Reactor Coolant System specific activity satisfies 10 CFR 50.36(c)(2)(ii), Criterion 2. LCO Thespecificactivityislimitedto1.0pCi/gmDOSE EQUIVALENT I-131, and the gross specific activity in the primary coolant is limited to the number of pCi/gm equal to 100 divided by ? (average disintegration energy of the sum of the average beta and gama energies of the coolant nuclides). The limit on DOSE EQUIVALENT I-131 ensures the thyroid dose to an individual at the site boundary during the Design Basis Accident (DBA) will be within the acceptance criteria given in the UFSAR (Ref.1). The limit on gross specific activity ensures the whole body dose to an individual at the site boundary during the DBA will be within the acceptance criteria given in the UFSAR (Ref.1). TheSGTRaccidentanalysis(Ref.2)showsthatthesite boundary dose levels are within acceptable limits. Violation of the LCO may result in reactor coolant radioactivity levels that could, in the event of an SGTR, lead to site boundary doses that exceed the Reference 1 acceptance criteria. CALVERT CLIFFS - UNITS 1 & 2 0 3.4.15-2 Revision 0
RCS Specific Activity i}}