ML20217G338

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Forwards Response to NRC 970529 RAI Re TS Change Request to Convert to Improved Sts.Responses for Section 3.6 Provided in Attachment 1.Rev 7 to Original License Amend Application Also Encl
ML20217G338
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 10/06/1997
From: Cruse C
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217G343 List:
References
TAC-M97363, TAC-M97364, NUDOCS 9710100028
Download: ML20217G338 (31)
v • d • e


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CH etis 11. Ctrst: llattimore Gas and Electric Company Vice Preadent Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkw ay 1.usby. Maryland 20657 410 495-4455 October 6,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk .

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Revis;ca 7 to the License Amendment Request to Convert to the Improved Technical Snecifications (TAC Nos. M97363 and M97364)

REFERENCE:

(a) Letter from A. W. Dromerick (NRC) to C.11. Cruse (BGE), dated May 29, 1997, Request for Additional information Regarding the Technical Specification Change Request to Convert to the improved Technical Specifications (TAC Nos. M97363 and M9736 %)

The referenced letter transmitted questions regarding Section 3.6 of Baltimore Gas and Electric Company's application to convert to the Improved Standard Technical Specifications.

The responses for Section 3.6 are provided in Attachment 1 of this letter. Also attached to this letter is Revision 7 to the original license amendment application. These changes result from the responses provided in Attachment 1, as well as other changes identified by plant per;onnel. Changes to the No Significant 11azards Considerations discussions are included where appropriate.

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To assist in reviewing this revision, a list describing each of the changes is provided (Attachment 2). All of the material for each change is grouped by change in Attachment (3). Attachment (4) provides the >

revision by Improved Technical Specification Section for ease of replacing pages in the original amendment request. Page replacement instructions are provided. All changes are marked with revision '

bars and are labeled Revision 7.

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Documsnt Control Desk October 6,1997 Page 2 The Plant Operations and Safety Review Committee and a subcommittee of the Offsite Safety Review Comm ttee have reviewed revisions resulting in changes to the No Significant llazards Considerations and concur that operation with the proposed revisions will not result in an undue risk to the health and safety of the public. Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, s,w STATE OF MARYLAND  : .

TO WIT:

COUNTY OF CALVERT  :

I, Charles 11. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this License Amendment Request on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practicumd I believe it to be reliable. / -

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ne, a Notary Public in and for the State of Maryland and County of Subscribed (dl_LdAd) and sworn , this before L . ;d Jdav of dC(&(4t),1997.

WITNESS my lland and Notarial Seal: /M f Af J 2 1LLL LU Notary Public My Commission Expires: b k Date CilC/ PSF /dlm Attachments: (1) Responses h. .iequest for Additional Information (2) Summary of Changes (3) Amendment Revision by Change (4) Amendment Revision by ITS Section ec: M. L. Reardon, NRC (With Attachment 2 only)

R. S. Fleishman, Esquire 11. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate I 1, NRC R. I. McLean, DNR A. W. Dromerick, NRC J.11. Walter, PSC

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IMPROVED TECIINICAL SPECIFICATIONS, REVISION 7 i
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION i

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l Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 6,1997

Il E E E ATTACHMENT _L1) ,

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECT!ON 3.6 I

DESCRIFflON OFISSUE DAE DAE COMMENTS NO. JFD LCO OPENED CLOSED 3.6.1-1 A4 CTS 4.6.1.1.c CTS 4.6.1.1.c, CTS 4.6.1.1.d, and CTS 4.6.1.2 5/16/97 Licensee to update submittal CTS 4.6.1.1.d require leak rate testing in accordance with the with regards to 11/2/95 CTS 4.6.1.2 Primary Containment Leakage Rate Testing letter and updat:d TSTF 52 STS SR 3.6.1.1 Program. STS SR 3.6.1.1 requires the visual rhen OG provides revision ITS SR 3.6.1.1 examination and leakage rate testing be performed or provides additional and in accordance with 10 CFR 50 Appendix J as justification fordeviations.

Associated Bases modified by approved exemptions. Ils SR 3.6.1.1 modifies STS SR 3.6.1.1 to conform to CTS 4.6.1.1.c, CTS 4.6.1.1.d and CTS 4.6.1.2 as modified by Amendment 219 for Unit I and Amendment 196 for Unit 2. The STS is based on Appendix J Option A while the CTS /ITS are based on Appendix J, Option B. Changes to the STS with regards to Option A versus Option B are covered by a letter from Mr. Christopher I.

Grimes to Mr. David J. Modeen NEI dated i 1/2/95 and TSTF 52. The ITS changee. are not in conformance with the letter or TS.r' 52 as modified by staficomments.

CCNPP Response:

Improved Technical Specification (ITS) 3.6 will be revised to reflect the current licensing basis as approved by License Amendment Nos. 219 and 196 for Facility Operating Licenses DPR-53 and DPR-69, respectively.

3.6.1-2 A.4 CTS 4.6.1.1.c CTS 4.6.1.1.c which requires serifying that each 5/16/97 Provide a discussion and containment air lock is in cc.npliance with the justification for this requirements of CTS 3.6.1.3 is deleted. No deletion.

justification is provided for this deletion. A.4 only discusses the Containment Leakage Rate Programs.

CCNPP Response:

DOC A.7 will be provided to justify the deletion. The requirement is deleted because it is a cross-referece to a requirement in another specification, so the requirement is not deleted,just the cross-reference.

DOC = Discussion of Change 1 JFD = Justifx:ation for Deviation l

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ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORARATION 1 REPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ID DAE DAR -

DESCRif910N OFISSUE COMMENTS

' NO. JFD LCO- OPENED CLOSED 3.6.1-3 A.5 CTS 3.6.! 6 Unit 1 CTS 3.6.1.6 ACTION b requires an 5/16/97 Peet additional Bases ACTION a and b. engineering evaluation that assures the structural discussion and justificatum i JFD 7 ITS B3.6.1 integrity prior to increasing RCS temperature > for this Administrative Bases 200*F when the containment is not in change. See item Number SR 3.6.1.2 conformance with CTS 4.6.1.6.2-End Anchorages 3.6.1-4 and 3.6.1-5.

and Adjacent Concrete Surfaces and 4.6.1.63-Containment Surfaces. A.5 equates this Action with CTS 3.6.1.6 ACT10N a which requires a shutdown to MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This comparison is incorrect. CTS 3.6.1.6 allows 90 days to restore integrity or perform the engineering evaluation, but it only applies if containment integrity does not meet the criteria of CTS 4.6.1.6.1-Containment -Tendons. If the criteria of CTS 4.6.1.6.2 and CTS 4.6.1.63 are not met when the RCS temperature is > 200*F, then an immediate entry into CTS 3.03 is required.

Thus the justification is wrong. A justification similar to A3 would be more appuriate. See  ;

Item Numbers 3.6.1-4 and 3.6.1-5. ,

CCNPP Response:

DOC A.5 will be revised to more accurately describe the change and provide additionaljustification.

DOC = Descussion of Change 2 JFD = Justrncation for Deviation

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AUACHINENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORIAATION

. ITEM DOC / Uis/ sis DESCRif910N OFISSUE DAE - . DAE 1  !

. NO. JFD- LCO~ OPENED CLOSED COMMENTS t

'3.6.1-4 LA.1 CIS 3.6.1.6 Unit 1 CTS 3.6.L6 ACTION a allows 90 days to 5/16/97 Either ' delete this j L.1 ACTION a. restore containment tendon integrity or perform requirement and . provide i Bases ITS B3.6.1 Bases-SR. an engineering evaluation that assures the discussion and justification [

JFD 7 3.6.1.2 structural integrity when the containment tendons for this deletion (More

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are not in conformance with CIS 4.6.1.6.1. This Restrictive (M)), or provide

  • requirement is being moved to ITS B3.6.1 BASES the moupii.te Conditions,

- SR 3.6.1.2. The relocation of this requirement to ras and Completion Thnes  !

ITS B3.6.1 BASES SR 3.6.1.2 is unacceptable. in ITS 3.6.1 as well as  !

113 3.6.1 AC110NS require containment be mnupt te discussion and 3

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restored to OPERABLE status within I hour or justification for this  ;

shutdown to MODE 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. It does not administrative change. . See l allow 90 days to restore or perform an Item Numbers 3.6.1-3 and [

engineering evaluation. Therefore, the 90 days is 3.6.1-5. l consklered as an A ' awed Outage Time (AOT)  !

specific to Unit 1 CCNPP and would require  !

mnvraiate Conditions, ras, 'and Completion [

l Times. See Item Numbers 3.6.1-3 and 3.6.1-5. j CCNPP Response:  !

The actions associated with the Containment Tendon Program will be moved to the Technical Requirements Manual, controlled under 10 CFR 50.59, and

appropriate justifications will be provided. j r

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l DOC = Discussion of Change 3  :

JFD = Justrfication for Deviauon  !

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ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRS# TION IREPROVED TECHNICAL SPECIFICATIONS SECTION J.6  !

1 ITEM DOC / Ut s/STS DAE DAR - '

DESCRIPTION OFISSUE COMMENTS

NO. .JFD LCO- OPENED CLOSED  :

3.6.1-5 LA.1 Unit i Unit 1 C13 3.6.1.6 ACTION a allows 90 days to 5/16/97 Either delete this L1 CTS 3.6.1.6 restore containment tendon integrity or perform requirement and provide  :

Bases ~ ACTIONS a and b an . engineering evaluat on that assures the discussion and justification [

JFD 7 Unit 2 stmetural integrity when the containment tendons '

for ' this deletion (More CTS 3.6.1.6 are not in conformance with CIS 4.6.1.6.1. This Restrictive (M)) or provide, ACTION requirement is being moved to ITS B3.6.1 Bases- only for Unit 1 containment [

ITS B3.6.1 SR 3.6.1.2. The unacceptability of the relocation tendons inoperable, 'the j BASES- is discussed in item Number 3.6.1-4. Ilowever, .yymp ete Conditions, j SR 3.6.1.2 retention of this requirement in the ITS 'in the ras, and Completion Times  ;

form it is now is unacceptable. Unit l's current as well as appropriate ,

licensing basis has this AOT requirement discussion' and ju."ification j applying only to containment tendons (CTS for this Administrative /Less ,

3.6.1.6 ACTION a/ CTS 4.6.1.6.1), not to end Restrictive change. See  ;

anchorages and adjacent concrete surfaces (CTS Item ' Numbers 3.6.1-3, and  !

3.6.1.6 ACTION b/ CTS 4.6.1.6.2) and 3.6.1-4. j containment surfaces (CTS 3.6.1.6 ACT10N ,

b/ CTS 4.6.1.63) and see Item Numbers 3.6.1-3.  ;

In addition, Unit 2 CTS 3.6.l.6 ACTION does not include this requirement. Unit 2 CfS '3.6.1.6 I ACTIONS allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore integrity, [

not 90 days. Further nore, Unit 2 changes the 24

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hours change. Therefore, to implement this  !

change as proposed would require a staff  !

evaluation with regards to CTS 3.6.1.6 ACTION b '

and Unit 2 CTS 3.6.1.6 ACTION. This is beyond the scope of review for this conversion.

CCNPP Response: f The actions associated with the Containment Tendon Program will be moved to the Technical Requirements Manual, controlled under 10 CFR 50.59, and j appropriatejustifications will be provided. }

k DOC = Discussion of Change 4 JFD = Just#ication for Deviation

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, r ATTACHMENT (1) f RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 t i

ITEM DOC / xis/STS DAE DAE.

DESCRIPTION OF ISSUE . -

COMMENTS NO. JFD ' If0 OPENED CLOSED j t

l 3.6.1-6 None CTS 4.6.1.1.d CTS 4.6.1.1.d was added by Unit 1 Amendment 5/16/97 Correct this discrepancy. [

, 'ITS 5.5.1.6 No. 221 and Unit 2 Amendment No.197 to allow l use of blind flanges for the Containment Purge l l System -instead of the two outboard. 48 inch isolation valves during MODES I to 4. Insert A  !

in the CTS markup differs from the staff approved i amendments (197 and 221) and the insert 5.5.16 i

, in ITS 5.5.1.6. l CCNPP Response: .I i

insert A will be marked to match the approved Amendments.

3.6.1-7 Bases ITS 5.5.6 ITS B3.6.1 Bases-REFERENCES lists Reference 5/16/97 Correct this diwy. cy. '

l None ITS B3.6.1 4 as Regulatory Guide 135 Revision 0, while ITS  !

, Bases 5.5.6 specifies Revision 2 of the same document. [

REFERENCES  !

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CCNPP Response
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!' The Bases will be corrected to reference Revision 2.

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ITEM . DOC / CTS /STS

- DESCRIPTION OF ISSUE..

DAE DAE .

NO. JFDL LCO COMMENTS OPENED ' CLOSED' i 3.6.2-1 A.5 CTS 4.6.1.3a See item Number 3.6.1-1 5/16/97 See Item Number 3.6.1-1. l ITS B3.6.2  ;

BASES CCNPP Response: I t

Improved Technical Specification 3.6 will be revised to reflect the current licensing basis as approved by License Amendment Nos. 219 and 1% for Facility Operating Licenses DPR-53 and DPR-69, respectively.

j coc = Descussion of change 5 i JFD = Just& sten for Deviation [

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ATTACHMENT (1) I RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 IN # NSD DAE DAE DESCRIPTION OFISSUE COMMENTS NO. JFD LCO OPENED CLOSED 3.6.2-1 A.5 CTS 4.6.1.3a See Item Number 3.6.1-1 5/16/97 See Item Number 3.6.1-L ITS B3.6.2 BASES 3.6.2-2 L.2 CTS 3.6.1.3 CTS 3.6.1.3 ACTION b require

  • that when an air 5/16/97 Provide additional ACTION 5 lock is inoperable as a result of an inoperable justifiuntion and discussion ITS 3.6.2 door gasket, that the OPERABLE door of the air for this More Restrictive ACTION A and C and lock be maintained locked closed and sealed, and change. See Item 3.6.2-3.

Associated Bases the air lock restored to OPERABLE status within 7 days. L.2 states that the appropriate ACTION to follow in this case is ITS 3.6.2 ACTION A. This is inco rect. He appropriate ACT10N to enter in this condition is ITS 3.6.2 ACTION C. The basis for this is faund in ITS B3.6.2 BASES RA C.I. Thus the change becomes a more restrictive change. See Item Number 3.6.2-3.

CCNPP Response:

If one air lock door is inoperable due to a failed seal, Condition A is the appropriate condition to enter. Ilowever, if one seal per door has failed (one of the two seals in each door has failed, such that both doors would be considered inoperable), then Condition C is the correct condition to enter. The L.2 DOC is correct in describing applicable conditions and change categorization.

DOC = Discussion of Change 6 f

JFD = Justrftcation for Deviation

ATTACHMENT..fil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM DOC / CTS /STS DAE DAE '

DESCRIPTION OFISSUE COMMENTS NO. . JFD LCO OPENED CLOSED 3.6.2-3 L4 CTS ITS 3.6.2 ACTION RA A contains a Note 2 5/16/97 Provide additional 3.6.1.3 which allows entry and exit into containment for justification and discussion ACTION D seven days under administrative controls if both for this less Restrictive ITS 3.6.2 air locks are inoperable. 'Ihe justification L4 change.

RA A uses CTS 3.6.1.3.b as part of the basis for adding Note 2 this Note. Bases on item Number 3.6.2-2, L4 is incorrect.

CCNPP Response:

If one air lock door is inoperable due to a failed seal, Condition A is the appropriate condition to enter. Ilowever, ifone seal per door has failed (one of the two seals in each door has failed, such that both doors would be considered inoperable), then Condition C is the correct condition to enter. The L2 DOC is correct in describing applicable conditions and change categorization. DOC L4 will be enhanced to provide additionaljustification.

3.6.2-4 None STS 3.6.2 Changes are made to STS B3.6.2 Bases SR 5/16/97 Licensee to update Bases 3.6.2.2 to bring it into conformance with TSTF- submittal with regards to SR 3.6.2.2 17. The changes made do not conform to the TSTF-17 or provide ITS B3.6.2 approved version ofTSTF0-17. additional discussions and Bases justifications for the SR 3.6.2.2 deviations.

CCNPP Response:

JFD-16 will be provided tojustify the deviations from TSTF-17 Revision 1.

DOC = Discussion of Change 7 JFD = Just:5 cation for Deviabon

i ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 IHM W C E /S U DESCRIPTION OFISSUE DAE DAR COMMENTS NO. JFD -LCO. OPENED CLOSED 3.63-1 A.5 CTS 3.6.4.1 ITS 3.63 wu contain an ACTIONS Note 2 which 5/16/97 Provide additional j ITS 3.63 allows separate condition entry for each discussion and justification penetration flow path. CTS 34.4.1 ACTIONS do for this Administrative not contain this requirement. He justification change.

states that the Note is consistent with the intent of the CTS ACTIONS for the containment air locks.

His is incorrect. He justification needs to be consistent with the CTS for containment isolation valves, since the same change was done for containment air lecks.

CCNPP Mesponse:

DOC A.5 will be modified to clarify that the actions are consistent with the intent of the existing actions for the containment isolation valves.

3.63-2 M.2 CIS 3.6.4 ITS 3.63 RA B.2 contains requirements to verify 5/16/97 Licensee to update submittal l BASES ACTIONS the affected penetration flow path is isolated once in accordance with TSTF-JFD 6 ITS 3.63 per 31 days for isolation devices outside 145 as modified by the staff RA B.2 and Associated Containment. ITS 3.63 RA B.2 contains an or provide additional BASES additional requirement for isolation devices inside discussion and justification Containment to verify the affected penetration for the deviations.

flow path is isolated prior to entering MODE 4 fmm MODE 5, if not performed within the previous 92 days. ITS 3.63 RA B.2 is modified by a Note allowing isolation devices in high radiation areas verified administratively. CTS 3.6.4.1 does not contain this allowance. The STS markup for ITS 3.63 RA B.2 references %

145 'as justification for adding RA B.2. He changes to ITS B3.63 Bases-RA B.1 and B.2 is not in accordance with TSTF 145 as modified by the staff.

CCNPP Response:

Chaages associated with TSTF-145 were removed as part ofITS supplemental Amendment Request Revision I dated June 9,1997. ,

DOC = Discussion of Change 8 JFD = Justification for Deviation

ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM DOC / CTS /STS - DAR . DAE COMMENTS DESCRIPTION OFISSUE :

NO. JFD 'LCO. OPENED CLOSED 3.63-3 M3 CTS 3.6.1.1 See Item Number 3.6.7-1 5/16/97 See item Number 3.6.7-1 LS

  • Footnote JFD5 BASES JFD 6 CCNPP Response:

DOC L1 for ITS 3.6.7 will be revised to bette explain that the allowance for the plant to operate with both hydrogen recombiners inoperable under the conditions specified is acceptable based on having an alternate hydrogen control system acceptable to the Nuclear Regulatory Commission technical stafT.

3.63-4 LA.2 CTS 4.6.4.1.1 He post-maintenance testing required by CTS 5/16/97 Provide a description of the 4.6.4.1.1 is not contained in IP3 3.63. Rather, plant procedures to which this requirement is moved into plant procedures. the post-maintenance testing His places requirements outside of the ITS into requirements are relocated Licensee controlled documents. There is not an and the change control adequate discussion and justification of how process for these specific post-maintenance testing requirements procedures.

are addressed and controlled by plant procedures.

CCNPP Response:

DOC L10 will be provided tojustify deletion of these requirements.

DCC = Discussion of Change 9 JFD = Justfication for Deviation

ATTACHRAENT fil RESPONSES TO REQUEST FOR ADDITIONAL INFORRRATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 IN U DESCRIPTION OFISSUE DAE DAE COMMENTS .-

14 0. JFD LCO OPENED CLOSED 3.63-5 L3 CTS 4.6.1.1.a and CTS 4.6.1.1.a requires verifying once per 31 days 5/16/97 Prov additional Associated ** Footnote that all penetrations not capable of being closed discussion and justifkation ITS SR 3.63.2 by OPERABLE containment automatic isolation for adding the phrase "and ITS SR 3.633 valves, but that are required to be closed during are not locked, scaled, or and Associated Bases accident conditions, are cloced by valves, blind otherwise secured" to CTS flanges, or deactivated automatic valves secured 4.6.1.1.a. See Item Number in their positions. Footnote ** to CTS 4.6.1.1 3.6 3-13.

excepts those valves, blind flanges, or deactivated automatic valves located inside containment from the 31 day verification frequency, but specifies that they must be verified during each MODE 5 if not performed in the previous 92 days. ITS SRs 3.63.2 and 3.633 require performing the same verification. IIowever, they are modified by a Note which allows verifying valves, blind flangw -

or equivalent in high radiation areas by administrative means. The CTS markup for CTS 4.6.1.1.a inserts the phrase "and are not locked, scaled, or otherwise ' secured." There is no discussion or justification provided for inside containment; not all valves or valves outside containment which is _~>t the focus of L3. See item Number 3.63-13.

CCNPP Response:

DOC L4 will be enhanced, and DOC L3 will be wi:hdrawn. _

DOC = Discussion of Change 10 JFD = Justification for Deviaton

ATTACdRAENT (1) 4 RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM DOC / CI3/STS DAR DAR DESCRII410N OFISSUE COMMENTS

. NO. JFD LCO OPENED CLOSED 3.63-6 L6 CTS 4.6.1.1.a CTS Surveillance Requirement 4.6.1.1.a requires 5/16/97 Delete this change.

L7 CTS 3.6.4.1 ACTION C all penetrations not capable of being closed by ITS 3.63 OPERABLE CIVs, and are required closed during RA A.1 accident conditions, are verified closed by valves, ITS 3.63 blind flanges, or deactivated automatic valves RA B.1 secured in their positions. ITS 3.63 RA A.1,ITS ITS 3.63 3.63 RA B.1, ITS 3.63 RA C.1, ITS SR 3.63.2 RA C.1 and ITS SR 3.633 allow penetrations to be

, ITS SR 3.63.2 isolated by an equivalent isolation device. she ITS SR 3.633 STS markup for this change references CEOG-and Associated Bases 112. CEOG-112 is TSTF 1% which has been rejected by the staff.

CCNPP Response:

Changes associated with TSTF-l% will be removed and appropriatejustifications provided.

3.63-7 Bases ITS B3.63 Bases- ITS B3.63 Bases- RA C.1 and C.2 last paragraph 5/16/97 Comet this discrepancy.

JFD3 RA C.1 and C.2 has no changes associated with 'it. Yet it is marked with Bases JFD 3.

CCNPP Res use:

The JFD-3 reference will be removed.

3.63-8 None CTS 3.6.4.1 ACTIONS CTS 3.6.4.1 ACTIONS adds a Note to bring the 5/16S7 Provide a discussion and ITS 3.63 Conditions A CTS into conformance with ITS 3.63 Conditions justification for this and B and Associated A and B. No justification is provided for this - administrative change.

Bases. administrative change.

CCNPP Response:

DOC A.9 addressed this change as part ofJTS supplemental Amendment Request Revision I dated June 9.1997.

coc = Dscussen of change 11

. FD = Justification for Deviation

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4 ATTACHRENT f1) -l RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM DOC / UIs/ sis DAE ' DAE DESCRIPTION OFISSUE . COMMENTS NO. JFD- 'LCO OPENED CLOSED 3.63.9 None CTS 3.6.4.1 AC110NS CTS 3.6.4.1 ACT10NS adds a Note to bring the 5/16/97 Provida a discussion and ITS 3.63 CTS into conforraance with ITS 3.63 Condition justification for' this i 4.

Condition C and C. No justification is provided for this administrative change. See  !

1 Associated Bases administrative change. See item Num'oer 3.63- Item Number 3.63-12.

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CCNPP Response:

DOC A.9 addressed this change as part ofITS supplemental Amendment Regaest Revision i dated June 9,1997.

3.73-10 None CTS 4.6.4.1.1 CIS 4.6.4.1.1 # Footnote is being moved from 5/16/97 Provide a discussion and I

  1. Footnote CTS 3.6 to ITS 33.7 Containment Radiation justification . for this i Signal." No justification is provided for this administrative change.  :

administratise change.  !

CCNPP Response:

Tliis change is addressed by DOC A.I.

3.6 3-11 None CTS 4.6.1.1.b,4.6.1.1.c, CTS 4.6.1.1.b, 4.6.1.1.c, and 4.6.1.1.d are being 5/16/97 Provide a discussion and and 4.6.1.1.d moved frn:n CTS 3.6 to ITS 5.5.16. No justification for this i justification is provided for this cdministrative administrative change. l

, change. j CCNPP Response 11:is change is addressed by DOC A.I. j 3.6 3-12 None STS 3.63 Condition C IIS 3.63 Condition C modifies STS 3.63 5/16/97 Provide a discussion and ITS 3.63 Condition C Condition C and associated Note to melude more justification based on and Associated Bases than one containment isolation valve in a closed current licensing basis,  :

system. The change is designated CEOG-106. It system design, or  :

is the staffs understarxiing that this change is not operational constiaints.

generic and has been withdrawn from the generic j re<iew process, but will be subm: tied as a plant specific change.

CCNPP Response: fi JFD 10 was added to address this change as part ofITS supplemental Amendment Request Revision I dated June 9,1997. l Doc = orscussen of change 12  ;

JFD = Justification for reviaton  !

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ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 IDI C DAR ' DAR COMMENTS DESCRIIrIlON OFISSUE

. NO. JFD LCO OPENED CLOSED 3.6 3-13 None STS STS SR 3.633, SR 3.63.4 and their associated 5/16/97 Licensee to update submittal SR 3.633 Bases have been modified by TSTF 45 Rev.1. in a d c with is1P 45 STS_ ITS SR 3.63.2 and SR 3.633 have mcorporated Rev 1 or provide additional SR 3.63.4 and TSTF 45. Ilowever, their asweiated bases are not discussion and justification Associated Bases in accordance with '5Tr'-45. for the bases deviation.

ITS SR 3.63.2 ITS SR 3.633 and Associated Bases CCNPP Response:

TSTF-145 Revision I will be incorporated into the ITS submittal.

IEI DAE DAE - COMMENTS DESCRIPIlON OFISSUE NO. JFD LCO OPENED CLOSED No comments for 3.6.4.

occ = Discussen of change 13 JFD = Justdeation for Deviaten

R ATTACManET til RESPONSEG TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTKJN 3.6

- \

IE DAE ' DAR COMMENTS )

DESCRIPTION OFISSUE NO. JFD LCO OPENED CLOSED 3.6.5-1 LA2 CTS 4.6.1.5 CTS 4.6.1.5 requires determining the containment 5/16/97 Specify the temperature ITS B3.6.2 average air temperature as the arithmetical indication locations in ITS BASES average of the temperature at the containment 33.6.5 BASES-SR 3.6.5.1.

SR 3.6.5.1 dome and the containment reae.or cavity. ITS SR 3.6.5.1 requires determining the primary Provide a description of the l containment average air temperature, but does not plant procedure to which the specify temperature indication locations. The temperature indicaticn temperature indication locations are moved into locations are relocated and the Bases and plant procedures. ITS B3.6.2 the change control process Bases-SR 3.6.5.1 does not specify the tempe2ture for these p;ocedures.

indication locations, nor is it specified elsewhere in ITS 63.6.5. 'Ihe specific plant procedures and associated controls are not indicated.

CCNPP Response:

The detail will be mcwed to the Bases and appropriatejustification changes will be made.

ITEM DOC / CTS /STS DAR DAE COMMENTS DESCRIPT10N OFISSUE NO. JFD LCO. OPI': ED CLOSED 3/4.6.5.1-1 None CTS 3/4.6.5.1 CTS 3/4.6.5.1 is being moved to fl3 33.10 " Post 5/16/97 Provide a discussion and Accident Monitoring Instrumentation." No justification for this justification has been provided for this Administrative change.

Administrative change.

CCNPP Response:

DOC A.1 was provided for thb change..

DOC = Drscussion of Change 14 JFD = Justrficaton for Deviation

P ATTACHAAENT (1)

RESPONSES TO REQUEST FOR' ADDITIONAL INFORRRATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 IN DAE DAR . COMMENTS DESCRIPTION OFISSUE .

MO.- JFD LCO OPENED CLOSED 3.6.7-1 Li CTS 3.6.5.2 CTS 3.6.5.2 does not specify an ACTION when 5/16/97 Provide additional Bases ITS 3.6.7 two hydrogen recombiners are inoperable. discussion and justification JFD 2 ACTION B and Therefore, if two hy& ogen recombiness are based on current licensing Associated Bases inoperable, a shutdown per LCO 3.03 :s required. basis, system design,. or ITS 3.6.7 Condition B adds Required Actions and operational constrains as Completion Times for two hydrogen recombiners well as . .pr vr i.Ac inoperable. However, instead of requiring entry documentation to show that into the LCO 3.03 shutdown track as in CTS ITS 3.6.7 ACllON B 3.5.6.2, ITS 3.6.7 ACTION B allows 7 days to applies to CCNPP and the restore one hydrogen recombiner to OPERABLE CTS is in error.

status when two are inoperable. ITS 3.6.7 ACTION B also requires administrative!y verifying the hydrogen control function within I hour after both hydrogen recombiners become inoperable, and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafler. ITS B3.6.7 Bases-RA B.1 a d 3.2 and justification Ll state that the hydrogen control function is provided by Containment Vent /Ilydrogen Purge System. Ilowever, CTS 3.6.1.1 ' Footnote (justification M3 in ITS 3.63) only allows the Containment Vent /llydrogen Purge System to be open in MODES 1 to 4 for cmtainment pressure conuol, airborne radioa.;tivity control, and surveillance testing purposes, not for hydrogen control functions. Thus it would seem that IIS 3.6.7 ACTION B does not apply to CCNPP.

CCNPP Response:

DOC L.1 for ITS 3.6.7 will be revised to better explain that the allowance for the plant to operate with both hydrogen recombiners inoperable under the conditions specified is acceptable based on having an alternate hydrogen control system acceptable to the Nuclear Regulatory Commission technical staff.

DOC = Discussion of Change 15 JFD = Justsfecation for Deviation

ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 ITEM DOC / CTS /STS DAR DAE :

DESCRIPTION OFISSUE COMMENTS

' NO. -JFD LCO ' OPENED CLOSED 3.6.7-2 L.2 CTS 4.6.5.2.a CTS 4.6.5.2.a requires verifying that during a 5/15/97 Provide ' additional STS functional test of the hydrogen recombiner, the discussion and justification SR 3.6.8.1 and minimum heater sheath temperature increases to > based on current licensing Associated Bases 700*F within 90 minutes, and is maintained for at basis, system design" or ITS least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> once per 6 months. ITS 3.6.7 does operational constraints to SR 3.6.7.1 and not contain this requirement. Rather, ITS SR justify the deviation from Associated Bases 3.6.7.1 (hydrogen recombiner functional test) is a the CfS and STS.

24-month functional test which requires the heater sheath temperature to be increased to > 1200*F within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, and maintained for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Nojustification is provided for changing the test parameters from a heater sheath temperature of >700 within 90 minutes and is maintained for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to > 1200*F to within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and maintained for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

STS B3.6.8 Bases-SR 3.6.8.1 has a testing requirement similar but less restrictive than CTS 4.6.5.2.a. It does not maintain the temperature for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, but increases it to maximum for approximately 2 minutes and verified to be >60 kw CCNPP Response:

DOC L.2 will be revised to provide additionaljustification foi deletion of Current Technical Specification Surveillance Requirement 4.6.5.2.a.

Doc = oiscussion of change 16 JFD = Just:feation for Deviation

[ ._. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _

1 ATTACHIENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRRATION 3RAPROVED TECHNICAL SPECIFICATIONS SECTION 3.6

' IEM DOC / CTS /STS DAE DAE . COMMENTS DESCRII410N OFISSUE -- 1 NO. '

JFD LCO- OPENED CLOSED 3.6.7-3 Bases STS B3.6.8 Bases- STS B3.6.7 Bases RA B.1 and B.2 ' has a 5/16/97 Provide - additional JFD 10 - RA B.1 and reviewer's Note in the text. ITS B3.6.7 Bases RA discussion and justification B.2 B.1 and B.2 deletes the Note using justification for the deletion of the ITS B3.6.7 Bases JFD 10. Bases JFD 10 deals with the Reviewer's Note.

Bases compriance of CCNPP to the General Design RA B.1 and B.2 Criteria (GDC). De deletion of the Reviewer's Note has nothing to do with the GDC.

CCNPP Response:

He JFD 10 notation will be revised to JFD 9.

{ Doc = Descussion of change 17-JFD = Justification for Deviaton

ATTACHMENT (il RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6 i CEE DAE - DAR COMMENTS DESCRIPTION OFISSUE f NO. JFD LCO OPENED CLOSED' 3.6.8-1 BASES STS B3.6.10 STS B3.6.10 Bases for SR 3.6.10.2 states Jiat 5/16/97 Rehsert the STS statement JFD 3 BASES "The ICS filter tests are in accordance with and Ref. 3 into the SR 3.6.10.2 Regulatory Guide (RG) 1.52 (Ref. 3). "ITS approprete place in ITS ITS B3.6.8 Bases- B3.6.8 Bases for SR 3.6.8.2 deletes this statement B3.6.8 Bases SR 3.6.8.2 SR 3.6.8.2 and Reference 3 from ITS B3.6.8 Bases and ITS B3.8 Bases ITS B3.6.8 REFERENCE Section. The basis for this deletion REFERENCES.

BASES is that it was perforried to ensure that the REFERENCES references are applicable to CCNPP. The testing requirements in CIS 4.63.1.b thru g reference RG 1.52 Rev. 2 and are relocated to ITS 5.5.11.

ITS 5.5.1I states that the VFTP test shall be done in accordance with RG 1.52 Rev. 2. Therefore, I

the justification JFD 3 is wrong, and the STS statement and Reference 3 should be reinserted f into ITS B3.6.8 Bases SR 3 6.8.2 and ITS B3.6.8  !

I Bases REFERENCES, respectively. Furthermore, the stafT would consider this change as a generic change.

CCNPP Response:

JFD 15 will be provided forjustification for deletmg the reference in ITS 3.6.8 Bases, because all the filter trains are not in full conformance with Regulatory Guide 1.52 Revision 2, and the change is not generic since it is made to be consistent with current licensing basis.

Doc = Discussion of change 16 JFD = Just:fration for Deviation I _______

ATTAC8EENT (1)

RESPONSES TO REQUEST FOR ADDmONAL INFORRIATION 1RIPROVED TECHNICAL SPECIFICATIONS SECTION 3.8' ITEM DOC / C TS/S E DATE. "DATE' '

p, OFISSUE :

NO. 1JFD LCO -- OPENED CLOSED 3.6.8-2 Bases SE B3.6.10 Bases- STS B3.6.10. Bases-LCO states the following: S/1667 Provide a - discussion and JFD 8 LCO "Two separate,' independent, and redundant justification  : for this JFD 11 ITS trains " ITS B3.6.8 Bases-LCO deletes the deletion.

B3.6.8 words " separate, E '-; ="- --: and. redundant."

BASES- ITS B3.

6.8 BACKGROUND

frst sentence, BACKGROUNDITS second paragraph . retains these words. The B3.6.8 justifications (Bases JFD 8 and JFD 11) deal with Bases consistency with CCNPP spei.ific number, system LCO name, terminology, safety analysis, plant system operation or design basis. This deletion does not fall under any of these cgs-ics.

CCNPP R- ; n.

The ISTS Bases markup for ITS 3.6.8 will be revised to state that the three trains of the iodine removal system ase seper e, independent (except for power), and redundant, in accordance with the current licensing basis, as s,ated in the Safety Evaluation dated August 28,1972.

3.6.8-3 Bases STS 3.6.10 Bases - SH 3.6.10 Bases-SR 3.6.10.1 states that the SR S/16S7 Provide a discussion and JFD 8 ' SR 3.6.10.1 requirement to OPERATE cach ICS train ensures justification L for this ITS 3.6.8 that all trains are OPERABLE. "It also ensures deletion.

Bases- that blockage, fan or motor failure or excessive

' BACKGROUND. vibration can be detected for corrective action.'

ITS B3.6.8 His last statement has been deleted from ITS I Bases- B3.5.8 - Itases for SR 3.6.8.1. The justification SR 3.6.8.1 (Bases #D 8) provided does not correlate :o this sentence, based on the system descriptum provided in ITS B3.6.8 Bases-BACKGROUND.

CCNPP Response:

The statement will be retained in the ITS Bases.

Doc = oiscussion at change 19 JFD = Justdeshon for Denstion

ATTACIIMENT (2) 4 i

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IMPROVED TECilNICAL SPECIFICATIONS, REVISION 7

SUMMARY

OF CIIANGES i

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1 Baltimore Gas and Electric Company l- Calvert Cliffs Nuclear Power Plant October 6,1997

ATTACIIMENT (2)

SUMMARY

OF CilANGES 1.

The Nuclear Regulatory Commission (NRC) requested additionaljustification for deviating from a yet to be i sued revision of TSTF 52, and a letter from Mr. Christopher 1. Grimes to Mr. David J. Modeen dated November 2,1995. To resolve these comments, the improved Technical Specification (ITS) was revised to reflect the current licensing basis as approved by the NRC in I icense Amendment Nos. 2*.9 and 196 for Facility Operating License Nos. DPR 53 and DPR-69, respectively. While resolving these comments the following were discovered: 1) the Current Technical Specification (CT3) Markup for CTS 4.6.1.2 a for ITS 3.6.1 was not consistent with the issued License Amendments; 2) the acceptance criteria for the leakage rate tests provided in the improved Standard Technical Specification (ISTS) Bases for ITS Surveillance Requirement (SR) 3.6.1.1 was incorrect; and 3) the Markups for CTS 4.6.1.3.a for ITS 3.6.2 were not consistent with the ISTS Markup for ITS 3.6.2 SR 3.6.2.1. To resolve these issues, the following changes were made: 1) the Markups for CTS 4.6.1.2 and CTS 4.6.1.3.a were revised; 2)

Discussion of Change (DOC) A.5 was revised tojustify the addition of Notes I and 2 ofITS SR 3.6.2.1; 3) the references to TSTF 52 were removed from the ISTS Markups for ITS 3.6.1,3.6.2,

and 3.6.3 and the deviations were justified by new Justification for Deviation (JFD) 11 for ITS l

' 3.6; 4) the references to TSTF 52 were removed from the ISTS Bases Markups for ITS 3.6.1, 3.6.2, and 3.6.3. These deviations were justified by exiting JFDs 6 and 8, and new JFD 17 for Bases Section 3.6; and 5) the ISTS Bases Markup for ITS SR 3.6.1.1 were revised to provide the correct acceptance criteria. (Comments 3.6.1 1 and 3.6.2-1)

2. The NRC requestedjustification for the deletion of CTS SR 4.6.1.1.b, Thejustification has been provided in DOC A.7 for ITS 3.6.1. (Comment 3.6.1-2)

! 3. The NRC questioned the validity of the justificction provided for the elimination of Action b of CTS 3.6.1.6. Discussion of Change A.5 for ITS 3.6.1 was revised to provide the appropriate justification. (Comment 3.6.1-3)

4. In the CTS Markup of Action a of Unit I CTS 3.6.1.6, we proposed to move to the Bases the requirement to perform an engineering evaluation to demonstrate the ability of the containment structure to perform its function, in the event the containment structure was exhibiting evidence of possible abnormal degradation. The NRC did not believe this was appropriate, To resolve the NRC Comments, the following changes were made: 1) DOC LA.1 was revised to state that the requirement would be moved to the Technical Requirements Manual (TRM) versus the Bases.

This is appropriate, because the requirement only applies when the operability of the containment is indeterminate, if the containment is determined to be inoperable, then prompt action should be taken to either restore the containment or to place the plant in a safe condition; and 2) the ISTS Bases Markup for ITS SR 3.6.12 were revised to eliminate the discussion regarding the engineering evaluation. (Comments 3.6.14 and 3.6.1-5)

5. The NRC identified that Insert A provided in the Markups of CTS SR 4.6.1.1.d for ITS 3.6.1 did not match Insert 5 5.16 piovided in the CTS Markups for ITS Section 5.0 and the revised surveillances issued in License Amendment Nos. 221 and 197. insert A provided in the Markups of CTS SR 4.6.1.1.d for ITS 3.6.1 has been revised to be consistent with Insen 5.5.16 and the revised surveillances issued in License Amendment Nos. 221 and 197. (Comment 3.6.1-6)
6. The NRC identified that the reference to the revision of Regulatory Guide 1.35 contained in the ISTS Bases Markup for ITS 3.6.1 was different than the revision of Regulatory Guide 1.35 I

ND'ACllMENT m

SUMMARY

OF CIIANGES referenced in ITS 5.5.6. The revision referenced in ITS 5.5.6 is correct, so the reference in the ISTS Bases hierkup for ITS 3.6.1 was revised to reference Revision 2, versus Revision 0, (Comment 3.6.1 7)

7. Discussion of Change L.4 for ITS 3.6.2 was c+ nced to provide additional clarification. This proposed change was required to respond to an NRC comment. (Comment 3.6.2 3)
8. The NRC identified that the ISTS Bases hiarkup for ITS SR 3.6.2.2 did not match the wording appro; 3d in TSTF 17, Revision 1. The NRC is correct, llowever, the TSTF-17 wording contained several technical errors. Justification for Deviation 16 for Baser Section 3.6 has been provided tojustify the deviations from the approved TSTF 17 wording. (Comment 3.6.2-4)

The NRC requested that DOC A.5 for ITS 3.6.3 be revised to address the containment isolation valves,instead of the containment air locks. Discussion of Change A.5 for ITS 3.63 was revised as requested. (Comment 3.6.31)

10. The NRC was concerned that adding Action B ofISTS 3.6.8 to CTS 3/4.6.5.2 conflicted with Footnote
  • to CTS Limiting Condition for Operation (LCO) 3.6,1,1. Discussion of Change L 1 for ITS 3.6.7 was revised to include additioaal discussion and justification for the change. The l associated no significant hazards considerations (NSilC) did not require revision.

(Comments 3.6.3-3 and 3.6.71)

11. Currem Technical Specification SR 4.6.4.1.1 provides requirements to demonstrate the operability of each containment isolation valve prior to returning the valve to service afler maintenance, repair, or replacement work is performed on the valve or its associated actuator, I

control, or power circuit. Originally, we proposed to relocate this SR to procedures. Now, we are proposing to delete the SR. Justification for deleting the SR is provi'ed as DOC L.10 (and its associated NSHC) for ITS 3.6.3. To support this change, DOC LA.2 was deleted, because it is no longer used. (Comment 3.6.3-4)

12. The NRC requested additionaljustification regarding a change to CTS SR 4.6.1.1.a identified in the CTS hiarkups for ITS 3.6.3. To resolve this question the following changes were made:

1)the Markups of CTS SR 4.6.1.1.a for ITS 3.6.3 were revised to reference DOC ts4 for ITS 3.6.3 as the justification for change and to delete the reference to DOC L 3 for ITS 3.6.3; ,

2) DOC L.4 and its associated NSHC for ITS 3.6.3 were revised to ensure that the change to CTS 4.6.1.1.a and Footnote " to CTS 4.6.1.1.a were clearly discussed and justified; and
3) DOC L.3 and its associated NSIIC were deleted. DOC L.3 for ITS 3.6.3 addressed a different change, that was also addressed by DOC L.5 for ITS 3.6. (Comment 3.6.3 5)

While resolving the aforementioned NRC Comment, it was discovered that the Markups of CTS 4.6.1.1.a and Footnote ** of CTS 4.6.1.1.a for ITS 3.6.3 did not properly cross-reference the ITS requirements. Thus, the Markups of CTS 4.6.1.1.a and Footnote " of CTS 4.6.1.1.a for ITS 3.6.3 were revised to properly cross-reference the ITS requirements. Also, the ISTS Markup for ITS 3.6.3 was revised to properly cross-reference the CTS requirements.

13 The NRC requested that the deviations proposed by CEOG-ll2 (TSTF-196) be withdrawn from the Calvert Cliffs' submittal. The deviations proposed by CEOG-ll2 were withdrawn from the 2

A'ITACIIMENT 0)

SUMMARY

OF CllANGES submittal as requested. The following changes were required: 1) the Markups for Action c of CTS LCO 3.6.4.1 for ITS 3.6.3 were revised: 2) the Markups for CTS 4.6.1.1.a for ITS 3.6.*3 were revised; 3) DOC L.6 and its associated NSilC for ITS 3.6.3 were deleted, because they are no longer used; 4) DOC L.7 and its associated NSilC for ITS 3.6.3 were revised; and 5) the ISTS Markups for ITS 3.6.3 and its Bases were revised. (Comment 3.6.3-6)

14. The NRC requested that the ISTS Bases Markup for ITS 3.6.3 be revised by deleting a reference to JFD 3 for Bases Section 3.6 that was placed next to the last paragraph of the Bases for

(

Required Actions C.l and C.2. The ISTS Bases Markup for Required Actions C.1 and C.2 of ITS 3.6.3 was revised as requested. (Comment 3.6.3 7)

15. The NRC requested that the ISTS Bases Markup for ITS SRs 3.6.3.2 and 3.6.3.3 be revised to accurately reflect Revision 1 of TSTF 45. The ISTS Bases Markup for ITS SRs 3.6.3.2 and 3.6.3.3 were rev; sed to reflect Revision 1 of TSTF-45. (Comment 3.6.3 13)
16. Discussion of Change LA.2 for ITS 3.6.5 was revised to state that the specific locations for mea:uring containment air temperature are being moved to the Bases. The ISTS Markup of the Bases for ITS 3.6.5 was revised to include the required information. These changes have been made to respond to an NRC Comment. (Comment 3.6.5-1).
17. The NRC had several questions regarding the justifications for changes to CTS 4.6.2.1.a.1, CTS 4.6.2,1.b.1, and 4.6.2.1.c l. Additionally, while resolving these NRC Comment, additional problems with the Markups of the SRs of CTS 4.6.2.1 and the DOCS for ITS 3.6.6 were identified. The following changes were required to resolve these comments: 1) the Markups of l the SRs for CTS 4.6.2.1 for ifs 3.6.6 were revised; 2) DOCS A.5, M.1, LA.4, LA.5, and L 5 for l ITS 3.6.6 were revised; 3) DOCS A.6, A.7, and L.7 (and its associated NSilC) for ITS 3.6.6 were added; 4) DOC L 4 for ITS 3.6.6 was deleted; 5) the ISTS Markups for ITS 3.6.6 were revised; and 6) the ISTS Bases Markups for SRs 3.6.6.5, 3.6.6.6, and 3.6.6.7 were revised.

- (Comments 3.6.6-1,3.6.6-2,3.6.6-3, and 3.6.6-7)

18. Discussion of Change LA.3 for ITS 3.6.6 was revised to state that the requirement for the service water outlet valves to be full open has been moved to the Bases. The ISTS Markup of the Bases for ITS 3.6.6 was revised to include the required information. These changes have been made to respond to an NRC Comment. (Comment 3.6.6-5)
19. The NRC requested: 1) the Completion Time provided for Required Action B.2 for ITS LCO 3.6.6 be revised to account for the fact that we are only requiring a shutdown to Mode 3 with pressurizer pressure < 1750 psia, while Required Action B 2 ofISTS LCO 3.6.6A requires a shutdown to Mode 5; and 2) requested the deletion of a reference to a Note 5 in ED 6 for Section 3.6. To resolve these comments, the following changes were made: 1) the Markups of the Action for CTS 3.6.2.1 were revised to require the plant to be placed ir.1% ode 3 with  :

pressurizer pressure < 1750 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in the event the Containment Spray System is f inoperable and cannot be restored within the specified Completion Time. The proposed chsnge was justified by DOC M.5 for ITS 3.6.6; 2) DOC L.1 for ITS 3.6.6 and its associated NSHC [

were deleted, because they were no longer used; 3) the ISTS Markup for ITS 3.6.6 was changed to require the plant to be placed in Mode 3 with pressurizer pressure < 1750 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in the event the Containment Spray System is inoperable and cannot be restod. within the -

3

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I A1 TAC 11MENLG)

SUMM ARY OF CilANGES specified Completion Time. JFD 6 was revised to provide justification for this proposed deviation; 4) the IJTS Bases Markup for Required Action B.2 for ITS 3.6.6 was revised to be consistent with the revised ITS; and 5) JFD 6 for ITS 3.6.6 was revised to delete the reference to Note 5. In addition, the use of the Note to modify the Mode 3 Applicability was changed to add the modification into the Applicability, consistent with the manner in which this issue is handled in ITS 3.5.2. Justification for Deviation 6 was modified to reflect this change.

(Comments 3.6.6 6 and 3.6.6 8)

Additionally, the Applicability for ITS 3.6.6 was revised to be more consistent with the writer's gulde. This required changes ta the ISTS Markup for ITS 3.6.6 and ISTS Bases Markup for ITS 3.6.6.

20. De NRC requested that a generic editorial change made in the IST S Bases Markup for ITS 3.6.6 ve removej, and they requested justification for deleting the references to the spray additive sysam in the ISTS Hases Markup for ITS 3.6.6. The g;cneric editorial had replaced the word

" reduce" with the word " minimize." The generic editorial change was removed from the ISTS liases Markup for ITS 3.6.6. He deletion of the references to the spray additive system were anr. hated with JFD 8 for Bases Section 3.6. (Comment 3.6.6 9 and 3.6.610)

21. He NRC requested additional justification for the deletion of CTS 4.6.5.2.a. Discussion of

. Change L.2 for ITS 3.6.7 hrs been clarifled to better state our justification. While resolving this issue, it was discovered that the ISTS Markup for ITS SR 3.6.7.1 did not refer to the correct CTS SR. Thus, the ISTS Markup for ITS SR 3.6.7.1 was revised to refer to the correct CTS SR. '

(comment 3.6.7 2) l 22. The NRC requested that justification be provided for deleting a Reviewer's Note in the ISTS 4

Dases Markup for ITS 3.6.7. The proposed deviation referenced JFD 10 to Bases Section 3.6. -

4 This JFD did not justify the proposed deviation. Justification for Deviation 9 to Dases 4

Section 3.6 provides the appropriate justification. The ISTS Bases Markup for ITS 3.6.7 was revised to annotate the change with the proper JFD. (Comment 3.6.7 3) i

23. The NRC requested additional justiGeation for the deletion of the reference to Regulatory
Guide 1.52 from the ISTS Dases Markup for ITS SR 3.6.8.2. This justification has been provided as JFD 15 to Bases Section 3.6. (Comment 3.6.81) The NRC also questioned the l deletion of a statement from the ISTS Bases Markup for ITS SR 3.6.8.1 regarding the purpose of l the surveillance. This statement should not have been deleted. Thus, the statement has been restored to the ISTS Dases Markup for ITS SR 3.6.8.1. (Comment 3.6.8 3)
24. The NRC requested additional justification for the deletion of the statement " separate, independent, and redundant" from the ISTS Dases Markup for ITS LCO 3.6.8. The deletion of this statement was inconsistent with information provided in the Background Section of the ISTS Dases Markup for ITS 3.6.8. The ISTS Bases Markup for ITS 3.6.8 was revi+ed to state that the three trains of the lodine removal system are separate, independent (except for power), and redundant. (Comment 3.6.8 2)
25. The NRC requested justification for moving CTS 3/4.6.5.1 to Section 3.3.10. Discussion of Change A.1 for CTS 3/4.6.5.1 was added to provide thejustification. (Comment 3/4.6.51) 4

AIIACllMENT (2)

SUMMARY

OF CliANGES While resolving the aforementioned NRC Comment, it was discovered that the move of CTS 3/4.6.6 to Section 3.7 was also lacking justification. 'lhus, DOC A.1 for CTS 3'4.6.6 was added to provide thejustification. .

26. An internal reviewer identified that the llases for ITS 3.6.2 contained an error regarding the remote position indication for the doors of the personnel air locks. The ISTS Bases for ITS 3.6.2 were corrected to relicci that the personnel air locks are provided with an alarm in the control room that actuates when either door or equalizing valve for a personnel air lock is opei,ed.
27. While resolving comments, it was identified that ACTIONS Note 1 of ISTS LCO 3.6.3 was added tc CTS LCO 3.6.4.1 without appropriate justification. To resolve this issue, the following changes were made: 1) the Markups of CTS LCO 3.6.4.1 for ITS 3.6.3 were revised;
2) DOC L ll for ITS 3.6.3 and its associated NSilC were added tojustify the change; and 3) the ISTS Markup for ITS 3.6.3 was revised to provide the appropriate cross references.

i 28. The requirements of Unit 1 CTS 4.6 l.2.b and 4.6.1.2.c should have been retained in the i Containment leakage Rate Testing program. To resolve this issue, the following changes were required: 1) the Markups of Unit I CTS 4.6.1.2.b and 4.6.1.2.c for ITS 3.6.1 were revised;

2) DOCS LA.2 and LA.3 for ITS 3.6.1 were climinated; 3) Markups of Unit 1 CTS 4.6.1.2.b and 4.6.1.2.c were added to the CTS Markups for ITS 5.0; 4) a change to Unit I CTS 4.6.1.2.b was justified by DOC A 31 for ITS 5.0; 6) the Markups for CTS 3.6.4.1 and 3.6.1.1 for ITS 3.6.3 were revised; 7) DOC A 7 for ITS 3.6.3 was climinated; 8) the ISTS Markup for ITS 3.6.3 was revised; 9) JFD 3 for ITS Section 3.6 was modified to reflect that requirements for the e

containment purge isolation valves would be maintained in the Containment Leakage Rate Testing Program; 10) the ISTS Markups for ITS 5.5.16 were revised; 11) JFD 35 for ITS 5.0 was revised; and 12) the ISTS Markup for ITS SR 3.6.1.1 was revised.

29. While reviewing the LA DOCS for ITS Section 3.6, several issues were identified (i.e., items were proposed to be relocated but should have been retained, items were proposed to be relocated to plant procedures and items proposed to be relocated to the Bases were not included in the Bases). The following changes were required to resolve the issues: 1) the ISTS Bases Markups for ITS 3.6.3 were revised to include information that was deleted from the CTS via LA.3 for ITS 3.6.3; 2) the ISTS Bases Markups for ITS 3.6.6 were revised to include information deleted from the CTS via 1 A.1 for ITS 3.6.6; and 3) the ISTS Bases Markups for ITS 3.6.7 were revised to included information deleted from the CTS via L i .1 for ITS 3.6.7.

The following issues relate to pending TSTF changes.

30. A plant specific justification was provided (Discussion of Deviation 5 to Bases Section 3.0) to justify addition of the words to Bases LCO 3.0.7. The Bases changes are consistent with pending TSTF 48,
31. A plant specific justification was provided (Discussion of Deviation 4 to Bases Section 3.0) to justify the modification to Bases SR 3.0.2. The Bases changes are consistent with pending TSTF 52.

5

l ATTACilMrNT- (2)

SUMMARY

OF CilANGES

32. The NUREO Markup was modified to delete the reference to TSTF 37 as the justification for deleting NUREO Specification 5.6.7, Emergency Diesel Generator Failures Report. In the original submittal, a plant specific justification for this deletion was provided (Discussion of Deviation 19 to Section 5.0).
33. A plant specific justification was provided (Discussion ol' Deviation 35 to Section 5.0) tojustify the changes to the Containment I cakage kate Testing Program. The changes had been previouslyjustified based on 141; .2
34. A plant specific justification was provided (Discussion of Deviation 34 to Section 5.0) to justify deletion of NUREO Specification 5.2.2.b. The change had been previously justified based on TSTF.121.
35. The title of the Quality Assurance Plan in ITS 5.2.1.a has been changed to Quality Assurance Policy, consistent with Calvert Cliffs nomenclature. Appropriate changes to the CTS Markup, Discussion of Change A.5 to Section 3.0, ISTS Markup, and Discussion of Deviation 26 to Section 5.0 have also been inade, 6

l l

ATTACilMENT (3) .

4

)

i 4

)

IMPROVED TECilNICAL SPECIFICATIONS, REVISION 7 AMENDMENT REVISION IW CilANGE i

4 J

l i

i i

e i

k Haltiniore Gas and Electric Company Calvert Cliffs Nuclear Po ver Plant October 6,1997

1. The Nuclear Regulatory Commission (NRC) requested additionaljustincation for deviating from a yet to be issued revision of TSTF 52, and a letter from hir. Christopher I. Grimes to hir. David J. hiodeen dated November 2,1995. To resolve these comments, the improved Technical Specification (ITS) was revised to reDect the currc it licensing basis as approved by the NRC in License Amendment Nos. 219 and 196 for Facility Operating License Nos. DPR 53 and DPR 69, respectisely. While resolving these comments, the following were discovered: 1)the Current Technical Speci0 cation (CTS) hfarkup for CTS 4.6.l.2 a for ITS 3.6.1 was not consistent with the issued License Amendments; 2) the acceptance criteria for the leakage rate tests provided in the Improved Standard Technical Speel0 cation (IS1S) llases for ITS Surveillance Requirement (SR) 3.6.l.1 was_ incorrect; and 3) the Markups for CTS 4.6.1.3.a for ITS 3.6.2 were not consistent with the ISTS hfarkup for ITS 3.6.2 SR 3.6.2.1. To resolve these issues, the following changes were made: 1) the hiarkups for CTS 4.6.1.2 and CTS 4.6.1.3.a were revised: 2)

Discussion of Change (DOC) A.5 was revised tojustify the addition of Notes 1 and 2 ofITS SR i 3.6.2.1; 3) the references to TSTF 52 were removed from the ISTS hiarkups for ITS 3.6.1,3.6.2,  !

and 3.6.3 and the deviations werejustlued by new Justl0 cation for Deviation (JFD) 11 for ITS 3.6; 4) the references to TSTF 52 were removed from the ISTS Ilases hiarkups for ITS 3.6.1, 3.6.2, and 3.6.3. These deviations were justined by exiting JFDs 6 and 8, and new JFD 17 for liases Section 3.6; and 5) the ISTS Bases hiarkup for ITS SR 3.6.1.1 were revised to provide the correct acceptance criteria. (Comments 3.6.1 1 and 3.6.21)

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