Text

Proposed Tech Specs Section 3.6 to Reflect Conversion to Improved STS
	ML20217G357
Person / Time
Site:	Calvert Cliffs
Issue date:	10/06/1997
From:	; BALTIMORE GAS & ELECTRIC CO.
To:	;
Shared Package
ML20217G343	List: ML20217G338; ML20217G357;
References
	NUDOCS 9710100038
	Download: ML20217G357 (519)
	v • d • e

q om o ,

b u

h M

Containment B 3.6.1 BASES l

ACTIONS Ad In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time provides a period of time to correct the problem comensurate with the importance of maintaining containment during H0 DES 1, 2, 3, and 4. This time period alsoensuresthattheprobabilityofanaccident(requiring containmentOPERABILITY)occurringduringperiodswhen L containment is inoperable is minimal.

B.1 and B.2 If containment cannot be restored to OPERABLE status 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 H0DE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to H0DE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

SURVEILLANCE SR 3.6.1 1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test l ~?

requirements of the Containment Leakage Rate Testing Program. Failure to meet leakage limits specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program, leakage test is required to be s 0.6 L. (207,600 SCCH) for combined Type B and C leakage y following an outage or shutdown that included Type B and C CALVERT CLIFFS - UNITS 1 & 2 8 3.6.1-4 Revisiong7 9710100030 971006 DR ADOCKOS00g7 1

5(w #ad on 3. 6. l 34 @ CONTAINMENT $Y$IQil

@ (RIMMCONTAINDNI containmlele ce v .

LIMITING CONDITION FOR OPERATION

- J g

/co 3,(,,/ (T4.J.f) Containment LenMpe#teashall be'Ofpfte#'tik .

@ Imaxieum allowable containment leakage rate L, as spectited in Specification 6.6.6, ' nment Leakage Rale festing Program ' l 4' A combined leakage rate b C """N f 1 O valves su ect~to ypeg an

~

sts L lA p M Q"' ' GO" ,as s'peelhed in Spa <IhesflN 4.6.6, D APPLICABILITY: NODES 1, 2, 3 and 4 C+afain enf IedI*pe[a,L'kT8Nas Mpam dc7r,sf rACTION: the measured overall integratta containmens With leakage rate eithert (a)he exceedin acceptance criteria specified in the Containment)

A g rogram, or

}LeakageRateTesting netrations and valv(b) with thetoinessured combined rate fo es subject Types B and C tests leakage

< Texceedi L , restore the overall inte 06 to withi < acceptence criteria speciftegrated containnent leakage rate 4'3 in the efn elke ate Testino Pro gond the combined leakaotrate for al penetrati an Q [keut W,alves s_ubiett to_ Types B 1nd C_ testg+-4est-4 Aar r 2DO*fN a.it; IO , prior increasing the Reactor coolant System temperature above A a smi f 1,l 4 I biscusce ,o O Mg O Spacfsthe f.O

$URVEILLANCE REQUIRLHENTS 'Nd'*dM'** CMa/J l

-._ _ s (g.

@i . r- m , _ ,m kage rates M%M d:tUGt-M 8/I" ,. -

l criteria, metho p ions specified in QUTJfCTitwsppe.imi/

shall be detemined in confomance ne,C,=441mpeiif Leaige l'a+c with the

[ . {Pertom required visual examinatti,ns and%R+tt~ ~ in esug- hey 1 accordance with the Containment Leakage RMIesting' rogram. ^

Q e talc lesNng,eucept' $>r contairement air t s e w .\ -

l l

l CALVERT Cliff 5 - UNIT 1 '3/4 6-2 Amendment No. 216 l

y 3 J /0 uasA -

0

S pac A . b 3 ,f..l M (Bipsammt.smos

.7.6.[ h @igcoNTAlleeEWT)

Contat i ===

LDetfllit t0IIBIfttu POR OPERAfttu dMMAS@ '

d ; E 2 contatansat a E i s a n sha11 h -

@ A maximum allowable Specification 6.5.6,

containment leaksee L ratele Program.'

., as specified in1 t Laakage Ra Testing $

% A combined leakage rate ae"k L M s,ts for S all g I u we i

jW snetrations and valves s T

, A 4.e4

' #% h

~ g{** Spen'F=4 la %e%h g,5

=+ % .u m J APPLICAtlLITY: M00t$ 1, 2, 3 and 4.

M n : With either (a) the measured everall integrated containment

~

AfI e rate exceeding the acceptance criteria specified in the Containne

Leakage Rate Testing Program, er (b) with the measured combined leakage rate fo netrations and valves subject to Types 8 and C tests i

the L

ac . restorecriteria the overall integrated A' I

, to withi ceptance spec' fios in thecontainment Centainmentleakage Leakagerate Rate

) Testing Progr_Agrana the cm.inea le**"aa rata Y he nii ^^- trarians . - -- ice se ntalvez munimu ta Tiina R and c tantaEn JEne Ahm E n/ asidl t4 0.5FUprior A w'A'a'i t to increasing'the Reactor Coolant System temperature above 200'F. ~ l I Qb Saa hscusse.a er deeps.

A,e Ms.f.< <h.n f.o suavttLLAntt algogneetNTs ' W ,.,t.u M ,,e d 4. ls ',

f~4 W .1.l! The containment leakage ratestmai ram "-- : m ras ate.nej #

6.5DKER 18EDSchedula @shall be de efs ned in con"ormance w th the Qriter' a. methodgpad provtsions specified in 30 wu rurt m.Aonsnau ,

~

g Perform required visual examinations and ama/a 1[in g, g g ,(,,g,g ,

accordance with the Containment Leakage Rate Test ng Program.) -

IittwfC

" A eiJ ,4 d

~

'*"r lda ba..e " ''+ A /.v

. "A,'g j

/le. OmMasent' /.ed43 C Rate TestIg irogr e .

CALVERT CLIFFS . UNIT 2 3/4 6 2 Amendment No. Ig3

!.ietase hued,sent jg(p

'f f 6 &

I

\

A pt i b b "$.C;, *2

@ CONTAINMENT SYSTH 1 h NRIMMY COMIAINHENp fontainment Air Loeks LIMITING CORDITION FOR OPERATION (3AJ.$

Leo y,(,,t Q) Both c ntainment air loci $shall be OPERABLE withs s closea except wnen the r lock is being u for 1 h

norma ansit entry and exit t h the containmen h'en at)

_as ne air lock door thall sed. and;

@ An overallair lock leakage rate of !?, N :,CG- Q f feelfeA i $ p peita dlo d . d & ,,,e,,[ } Q y g APPLICABILITY: N0 DES 1, 2, 3, and 4. g rggj~g g ,"

3 tn M1LQtis id n ikt.e4 A L'I

,off @ "* *'

n$'E.$5ItErE e N N $$5EIa'$0EIIb+Sb' f or be in at least liOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and

/kr/v/ b --

sin COLD $HUTDOWN within th. following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

With an air ocK inopera~ ole due to n inoperable door gask LD AcrM A ll. Maint n the remaining door the affected air loc closed heyd,,,g,g and ealed, and '

l L2. 8[sto_re the mir 1 ~ ERAELE ttatus within avt nr hr in at least HOT $

l g g ($HUTDOWN g within the ic110 wing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ,within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD fA'Jf/7 Ac.rwv N0Tf6.* /,

2, SURVEILLANCE REQUIREMENTS J.

SR.3.62,) 4.6.1.3 Each containment air lock shall be demonstrated CPIRABLE:

a Mter en h ed if e ce t he t a r oc is be ng u d or l :

mu tt le nt te , he a i st on e r 2 ou r i th t t e en 1. La e s 0 00 ' L .2 $C ) $ et . ne b f;ue re s r is on lo e as re en v. n he vol e be et te oc s al g,g

ur te t a on ta t re ur o 1 ps ,

'm MN w perferes:n3 can lSnment .de )d !ea$' ape rAlk ksfing in acunluce wi/b N s la.4 1 Q fMSC it 3.y.

U '

DELETS

CALVERT CLIFFS - UNIT 1 3/4 6-4 Amendment No. 212 I

!.steMc kwMcd 219 g

_ _ __ _ ~

. fpaAdsn 3.G f i <

! I 1

1 INSERT SR 3.6.2.[

i i 1

l' SR 3.6.2.1 .............. . . . . NOT E S . . - . . . . . . . . . . . . . . .

1. An inoperable air lock door does not -

invalidate the previous successful

performance of the overall air lock i leakage test.

j 2. Results shall be evaluated against i

acceptance criteria applicable to SR 3.6.1.1. l

j

........................................... 1 f _ _ _

Perfo required ai lock leaka rate tes ng in accor nce with th ontainmen dnaccordan with the

)f i

akage Rate T ting Progra . Contain nt Leaka) Rate h

( Tept'ing Program I

4 i

E l

i 9

i 4

. . . - - . . , . ..-m ,.--...,,.,.-,=,e e, w..%..,w..,, , - - ., . , _ _ . , . , - , ..w_.- r ,-,,...,.,--,..,=r;---.., ..

__ . _ .__. ___._____._______._._..____m -

m .- __ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _

Sp c. f.u .}g g g, g l

3( @ CONTAINNtNT SYSTEMS l J.L 2 M ([RF\RY CQlMAIMifNTJ A./ -

Containment Air Locks )

LIMITING CONDITION FOR OPERATION L,co 3,4,2, M v h 4-containment air loch @ hall be OPERABLE withe

$ 'Both no a closed ransit entry except and extwhen fhe air lock is being undd.for T one air lock door shat fthrough the containny6 then at] '

Jes be closed and/__

h "

o ir lock leakage rate ohj.06 QQ:?)00_;g;@

~

A_

_g

-- L A 2.

s APPLICABILITI: MODES 1. 2 . an siled In(SQiedtA.lyContainit ' $h h

,g,g gf, y,f;,,, g,,,

8 bGl@ ~

/ c a.a aiidAc'rY &&

AS.e i cas! E Ne $N IMbea *!a M e!,o!NY}

_j$1n COLD $NUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .or be in at least NOT Aco u D -

_D.~ With an air lock inoperable due t an inoperable door gas t '

4 1.

Atr1*,e /) Mai sin theand an setled, remaining door f the affected Lir loc closed 4,1 L.4 u_ 9 ettore the air 1nek ta eraantf status within davt er t>e AcneAtM ($NUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .in at least HOT STAND 8Y w

$URVEILLANCE REQUIREMENTS 7 A,4 4.6.1.3

.5R 3. 6.7. I Each

= containment air lock shall be--demonstrated OPERABLE:

A te e ch p n1 0, ex ep -we th aros a.

fo it pl et I e 'h t e f n t it hi es s I le a ien at I.s s o e e 7 h ur b 0 00 2 9.

I t i e bA p ec 1n lo as r n en t 1 ee s

t oc ss%i es u 12e t c s n p s ro 1 p {g th A A.,'a'*,,A A By pe $rnin}An f ale loc k jin acced& W'

~;aaecni,i,,.-gg % st@ M 6,5,s,

' ~

~

.7ptger 26 3, e ?. I -

taemp44en-4+-M-fC for; 50. Aq ==

Dsterz CALVERT CLIFFS - UNIT 2 3/4 6 4 Amendment No. 189 l 1

P'A Ih I Licexu. be4et 196 O

.6pw $e/run 3.6. L 1NSERT SR 3.6.2.1 SR 3.6.2.1 - . - . . . . . . . . - . - . - - . N O T E S . . . . . . - . . . . .' . . . . . .

1. An inoperable air lock door does not -

invalidate the previous successful perfonnance of.the overall air lock i

leakage test. !

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform . quired air loc / eakage l rate In accordan testi in accordance th the Contai ent withthe/geO Le age Rate Testi Program. Contajnfiient lef kige Rate h

t

, IestingProgram)

F 9

I D

e _ - __ _ _ _ _ . - . _ , _ . . . . ~ . _ _ _ . _ _ . . _ _ - . _ _ . _ _ . . __.-.,_ _ _ _ . _ . - . _ _

DISCUSSION OF CHANGES j

SECTION 3 6J . CONTAINMENT AIR LOCKS

. ADA11NISTRATIVE CllANGES A.1 ne 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.

Durlog the Calvert Cliffs ITS development, certain wording preferences or conventions were i

adopted which resulted !n 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 3.6.1.3 (Containment Air Locks) requires each containment air lock to be Operable, improved Tcchnical Specification 3.6.2 (Containment Air Locks) will require two containment air locks to be Operable. His chnge specifies the number of air locks by changing "cach" to "two " Calvert Cliffs has two air locks, therefore, specifying the number of containment air locks in the LCO con.=titutes an administrative change. This change is consistent with NUREG 1432.

A.3 Improved Technical Specification 3.6.2 will add an Actions Note (Note 2) which allows separate Condition entry for each air lock. Current Technical Specification 3.6.1.3 Actions do not contain this requirement. His Note provides explicit instructions for proper

application of the Actions for Technical Specification compliance, in conjunction with proposed Specification 1.3. " Completion Times," this Note provides direction consistent with the intent of the existing Actions for the containment air locks. This change is 4

consistent with NUREG 1432.

A.4 Improved Technical Specification 3.6.2 will add an Actions Note (Note 3) which requires q entry into the applicable Conditions and Required Actions of LCO 3.6.1 when the containment is inoperable due to exceeding the overall containment leakage rate acceptance

, criteria Current Technical Specification 3.6.1.3 does not contain this Note. This Note is j essentially a reminder that noncompliance with the overall leakage limits requires entry into 4 the ITS Containment Specification (the CTS Containment Leakage Specification). Ilowever, i ITS, as well as CTS, requires entry into Actions for any Specification in which the LCO is not met. The addition of informational Notes constitutes an administrative change. His change is cons stent with NUREG 1432.

A.5 Current Technical Specification SR 4.6.1.3.a requires each containment air lock io be demonstrated OPERABLE by performance of containment air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program. Improved Technical Specification SR 3.6.2.1 contains the same requirement; however, it is modified by two notes. Rese Notes state: 1) An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test; and 2) Results shall be evaluated against acceptance criteria applicable to SR 3.6.l.1. These Notes have been added to the CTS. Notes 1 and 2 to ITS SR 3.6.2.1 are consistent with current practices. One air lock door is capable of providing a fission prodact barrier in the event; thus, Calvert Cliffs would J

not invalidate the previous successful performance of the overall air lock leakage test in the CALVERT CLIFFS - UNITS I & 2 3.6.21 Revision 7

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

DISCUSSION OF CilANGES SECTION 3 6.2 . CONTAINMENT AIR LOCKS event a single air lock door was inoperable. Additionally, the results of the air lock leakage test are accounted for in determining the combined Type B and C containment leakage rate, ne addition of these Notes is administrative, because it does not change the intent of the CTS.

l TECilNICAL CilANGES - MOltr urETitiCTIVE M.1 Current Technical Specification 3.6.1.3 Action a requires the air lock to be restored to Operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when an air lock la inoperable, except when the air lock is inoperable as a result of an inoperable door gasket. Improved Technical Specification 3.6.2 Action C is for air lock inoperabilities other than an inoperable air lock door and the interlock mechanism. His Action requires action so be immediately initiated to evaluate i

overall containment leakage rate, verification a door is closed in the affected alr lock within l 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and restoration of the air lock to Operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . His change adds two additional requirements when the air lock is inoperable for reasons other than for an inoperable door and interlock mechanism. He Action to evaluate the overall containment leakage will determine if the containment la Operable, if it il determined de overall containment leakage exceeds the required limits, then the Actions of LCO 3.6.1 are entered (one hour to restore). The requirement to maintain at least one door closed is consistent with the Actions of LCO 3.6.1, which requires the containment to be restored to Operable status within one hour. Adding additional requirements to the Technical Specifications constitutes a more restrictive change. His change will not impact plant safety because the additional Actions were added to ensure that the containment is Operable, his change is consistent with NUREG 1432.

IICilNICAL CilANGES . ItEl OCATIONS None TECIINICAL CIIANGES . MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA,1 Current Technical Specification LCO 3.6.1.3.a requires both doors to be closed except when the air lock is being used for normal transit entry and exit through the containment, then at least one air lock door shall be closed. Als requirement is being moved out of Technical Specifications and into ITS Bases 3.6.2. His requirement is consistent with the containment air lock interlock mechanism which prevents both doors from being open at one time, ne containment air lock interlock is required to be Open.ble consistent with this requirement in the CTS. The requirement that only one door be opened at a time in the containment air lovk will still be ensured, although this information is being moved to the Bases. Informational details such as this are consistently being moved to the Bases as part of the conversion to NUREG.1432. Any changes to this information in the Bases will be consistent with the requirements of the Bases Control Program of Section 5.0. Ac Bases Control Program will ensure that changes to these requirements will be appropriately reviewed, ne level of safety of facility operation is unaffected by the change because there is no change in the requirement to maintain the containment air lock interlock Operable, which will prevent both air lock doors from being open. Furthermore, NRC and Calvert Cliffs resouxes associated with processing license amendments to these requirements will be reduced. This change is a CALVERT CLIFFS UNITS I & 2 3.6.22 Revision 7

i 1

Containeent((Atnosph6tc an G)

(CT5)

$URVilllANCE RIQUIR(MfNTS

$URVEILLANCE FREQU[NCY

\N.(,.1, U/

3R 3.6.1.1 Perfore required visual exantnations and ---

TE---

lukage rate testing except for containment $R .0.t not

_atr inr1 tantino, in accordance witi Itca 110 CFR 60, pendix J. as If ted >y approved d ----------J tions.

The les go rate acce ance criteri n is in accord w e s 1.0 . However, ring the fir unit CFR 7

start following sting perfo d in ?'

acco ence with I CfR 50 tx J. s dix J led mod led by appr ed exemp. tio App , the . as ap ve 1 age rate ac plance cri ria are 0.6 i j fl 1 e fer the Typ 8 and Type tests, and empti yns i q t,0.75 L, for he Type A t st.

F (4,b,l. 6) $R 3.6.1.2 Verify containment structural integrit in accordance in accordance with tl.a Containment Tendon with the Surveillance Program.

r Containment

!"r%ence M Program f -n__ -

06 mIngh bes kEtp keYC f CEOG $15 3.6i Rev 1. 04/07/g5

1 Contathment Air Lock [(Atactph6ric,and Duad J.s.n h

ACTIONS fcontinued)

CON 01110N REQUIRCO ACTION COMPLEil0N 11ME I I. 6,1.3 . D. Required Action and D.! Be in NODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Com

! Ad;ee*4b line not met. pletion AliQ 0.2 Se in N0DE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 4

suRyt1LtANCE t.!OUIREMEWT$

-$URVElLLANCE FREQUENCY 5R 3.6.t.1 NOTEt...................

g g*g 1. An inoperable air lock door does not Invalidate the previous successful performance of the overall air lock leakage test.

)

2. Results shall be eval te agains i

acceptance critert g SR 3.6.1, (auvri w un 49 cup 10. Appen ,

i as fled by appr# ed enamoti .

Perform required air lock leakage rate esting in accordance withng Ltu w.=

C t.. ..

4 l,3, Appena1x 0, exempttons.

mocules o approvs 3

SR .2 lica not h

The acce ance criter for air ock in accordanco testing re

.u11hJ1 CFR 4 4pe tx J is l a. verall air ek leak e rate is nod led s[0.C5L.) en tes at t P,.

a rove empt ns b For each or, les ge rate is -

.01 L when t eted at 5l10.0$sig].

t

(

e --_ --

l (continued) re d Ita ke y kA k Tt sb'3 rog k ra CEOG $15 3.6-6 Rev 1, 04/07/95

h contatnnertisolationValves((

$URVittlMCt 4t00lRIMtitTS (continued)

$URVEILLMCE fat 0UtleCY

$R 3.6.3 Verify each valve is bloc [ke]dt

.ontainment purge restrict the valve from (18)non 3 opening >[50

~~~"-

$R 3.4.3.9 .Verif the combined leakage rate fo L11 '

sec dary containment bypass leak ---N01E-.

paths SR 3.0.t i g[ L ) when pressJrtred to psig). is r.ot appitcable g

in accorda ce with

'10 CFR l

lAppend )

as Ifled by preved e options CEOG $15 3.6-14 Rav1,04/07/95

DISCUSSION OF TECilNICAL SPECIFICATION DEVIATIONS FROh! NUllEG01432 SECTION 3.6 - CONTAINh1ENT SYSTEhtS apply. It is consistent with the philosophy provided throughout NUREG 1432. He Bases for NUREO.1432 LCO 3.0.2 states: "he first type of Required Action specifies a time limit in which the LCO must be met . . . If this type of 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." Additionally, the Completion Time for Required Action U.2 was changed from "84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months " to "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ", his time is consistent with the Completion ilme of Required Action D.2 ofITS LCO 3.5.2, which also requires the plant to be placed in hiode 3 with pressurizer pressure < 1750 psia.

7. He r.hutdown track in Required Action E.2 was changed from a requirement to be in Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , to Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , nis change was made lecause the Calvert Cliffs Containment Spray and Cooling Specincation is only applicable in Modes I,2, and 3. His change is consistent with other Technical Specifications (when not modified and justified in the Bases) when shutting down to Mode 4.

8. A Surveillance (ITS 3.7.6.2) was added to NUREO.1432 Specification 3.6.8 (Calven Cliffs ITS 3.6.7) which requires the performance of a Channel Calibration of all hydrogen recombiner instrumentation and control circuits every 24 months. His test is consistent with Calvert Cliffs' current licensing basis.

9. %e change adds an Action to NUREG 1432 Specification 3.6.10 (ITS 3.6.8) which incorporates an Action when two lodine Removal System trains are inoperable. Calvert Clifts deviates from the standard Combustion Engineering plant in that it has three trains of lodine Removal System. Two trains are required during a design basis accident. One of the three trains is a swing train and has to be powered from the correct bus to maintain separate and independent trains, in order to perform this alignment without entering Limiting Condition for Operation 3.0.3 (there is no Action for two trains), Action H was added.

Action B allows one hour to restore one lodine Removal System train to Operable status.

This change will not increase the total time allowed to be in Mode 5 (Limiting Condition for Operation 3.0.3 allows 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months , and Actions B and C combined would also allow 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months ).

10. NUREO 1432 Cond!!!on C is for one or more penetration How paths with one containment isolation valve inoperable and is only applicable to penetration How paths with one containment isolation valve and a closed system. Calvert Cliffs ITS 3.6.3 will retain the same requirement as the NUREO except the Calven Cliffs Nuclear Power Plant ITS will also apply to those closed systems with more than one containment isolation valve. Calvert ClitTs is a non-General Design Criteria plant with closed systems that contain one or more containment isolation valves, in conjunction with this change, a phrase was added to Conditions A and D Conditions Notes which specify that these Cenditions only apply to penetration flow paths not in a closed system. Th!s aange is consistent with Calvert Cliffs design.

11.

In ITS 3.6, changes have been made to reDect the implementation of 10 CFR 50, Appendix J, Option D. This is consistent with Calvert Cliffs' current licensing basis as approved in License Amendment Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively, nese License Amendments were issued on February 11,1997.

12.

Action Note 4 for NUREG 1432 LCO 3.6.3 requires the applicable Conditions and Required Actions of LCO 3.6.1 to be entered, whenever leakage results exceed the overall containment CALVERT CLIFFS . UNITS 1 & 2 3.6-2 Revision 7

+

_ _ _ _ . _ . _ - . . _ ~ - -"-- - - - ~ ' ~--~ ^ ~ ~ ^

~~~ i gent.: 4 ORC. Micy S- 'dcM + MCM O'MN(2)(!C

, __ ~= Q Containment ff .e ;,.c ) @

B3% ;

8 3.6 CONTAINMENT SYSTEMS 8 3.6.1 Containment M r ; M..e 3 g

RAlt$

SACKGROUNO 1he containment consists of the concrete reactor building (RS),itsstoelliner and the penetrations through this structure. ThestruclureisdesigneJtocontainradioactive material that may be rolessed free the reactor core following a . Additionally,this structure ovides pr,Cesign

' shielding s' asis > Accident from the f (f.tA)ission products that may be present in the containment atmosphere followl accident conditions. /

hns re &c, The containment is a reinforce concrete structui with's -

cylindri roof. al wall a flat fou atton mat, and a 4 110w dome 'l containment 'ngrouted tendons be cylinder walt s postressed with a post tensioning syt en in the vertical and horizontal directions, and the done roof is prestressed utilizing a three way post tensioning system.

The inside surface of the containment 1: Itned with a carbon steel linerand operating to ensure accident a high degree of leak tightness during conditions.

1he concrete R8 is required for structural integrity of the containment unde nDBAMonditions. The steel Itner and its penetrattens establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE Ideits .

the leakage of fission product radioactivity from the containment to the environment. SR 3.6.1.1 lenlage rate requirements comply with 10 CFR 50, Appendix h(Ref.1), as Ih modified by approved exemptions. ]

The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barriers

a. All penetrations required to be closed during accident cond'tions are either:

1. capable of being closed by an OPERABLE automatic containment isolation system, or (continued)

CEOG STS B 3.61 Rev1,04/07/95

Containment ("

{ Q 8th$

nACKset0lM. 2.

(continued) closed by manual valves blind flanges or ee-activated automatic v,alves secured In their except as provided in LC0 3.6.3,positions,inment ribsed 'Conta Isolation Valves':

b.

Each air 'Containeen lock is OPERA t excegs'as provided in 8LE, 0 3.6.2, 6. Loc s

,{ jg j

c.

~

d. T equipment hate __'

pressurized sealing closehjnd I h netration, except as anism associated with a l OPERABLE.

vided in LC0 3.6.[ ), is l

_)

i APPLICABLE

$METY ANA'Y$ts The safety design batts for the containment is that the containment must withstand the pressures and temperatures of the Itaiting DBA without exceeding the design leakage rate.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident, a main stet.= line break (MSLB ejectionaccident(Ref),2).and

. In a thecontrol element analysis of eachassembly of these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is eva controlled by the rate of containment leakage. The containment was designed with an allowable leakage rate of 2 A461% of containment air weight per day Ref. 3 . This

'eska as t. getherate is defined in 10 CFR 50 Appen(dix Ref. 1 , J Q

@ g. 'juggp' allowable containmentgleakagj[f='

maximas Ile a g m

- g Satisfactory leakage rate test results are a requirement for the estabitshment of containment OPERABILITY.

The containment satisfies Criterion 3 of the NRC Policy Statement.

LCO

~-

= / s _1.0 Containment Q, e OPERABILITY is maintained by limiting leakage to Q%ya 1(jch a required t orter to the first startup after performing 0AJR 69f Appen#x J, leakage test. At this c +p + L.J.p RA %W7 4 ,.- continued) 4_

CEOG STS B 3.6 2 Rev1,04/07/g5

Containment (^.' .

BASES 4

(C0 ti he c ned Ty 8 an oakago be\

(continued) _

< _L,. theompigJt]}T A Innknagat CA.E L)

Compliance with this LCu will ensure a containment

/ fag ,#);g3l' including equipment hatches that

/A /. /.b 3;f configurationlysoundandthatwilllimitleakagetothose is structural leakage rates assumed in the safety analysis.

N bd Individual leaka inck (LCO 3.6.t)hp(tas a

name131ed for the mcontair w air

. purse vfves wl"Fres utra 2EITMan not spectrically par', of the acceptance ant 4aaT h

exceeding these ladtvIdual limits iniy resun m thecriteria of 10 CTR 60 containment being inoperable when the leaLane n sult in exceeding t ptance criteria of ;,

APPLICABILITY In MODES 1. 2. 3. and 4 a DBA could cause a release of radioactive saterial into containment, in MODES 5 and 6 the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage of radioactive material from containment. The requirements for containment during MODE 6 are addressed in LCO 3.g.3. ' Containment Penetrations.'

ACTIONS L1 In the event containment is inoperable, containment must be restored to OPERABLE status within I hour. The I hour Completion Time provides a period of time to correct the problem commensurete with the importance of maintaining containment during MODES 1..t 3. and 4 This time period also ensurts that the probability of an accident containne;;tOPEKABILITY)occurringduringperiods(whenrequiring containment is inoperable is minimal.

B.1 and 9.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to 4 (continued)

CEOG STS B 3.6 3 Rev 1. 04/07/95

Containment (Atmos BASES ACTIONS B.1 and 3.2 (continued)

MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months . The allowed Completion Times are reasonable, based on operating experience power cond \tions in an orderly manner and withoutto reach the required plant cond challenging plant systems.

1 SURVE!LLANCE 1R 3.5.1.1 REQUIREMENTS Maintaining the colinineent

&O OPERABLE requires compliance 4 eakage rate test with the visual'f,axaminations reautrements of l0 Cry 50. a and

= a r:me lu. an - n eas C e d,*,w, g}. y,p'7 by AborousserumptfpAK Fallure to meet Gir.:sfk edi l

tvalys41 LCO 3.6.;!.h en 111an1A Je lenke and LCO 3.6.3 does noke l{gits spec' fled -g b %rhad ft.8rm invalidate the acceptability of these overall leakage determinations unless their contribution to overall Type A 8 and C leakage l

/ hil*W causes that to exceed limits. As left Isaktee prior to the *'L a' first startup after perforcing a required upw 8" d

g**g es ,3,de " me n leakage test is re ype 8 and C leakagg. quired.to be QLO.Qm/or 44dr M.Q c ne andbetween,do_r 50.n L

.g 8 T3M & 64 uub Iype_A leaka . M all otnef times oversii requirec leatag rfate t acceptance criteria is based on an overall

('M Type A lea age llett of s 1.0 L*. At s 1.0 L the offstte Ass,sw '

dose consequences are bounded by the assumptt'ons of the sec f,g.,,

safety analysis. SR Frequencies are as required by LLA J. . i Lp b$ch F a ev t %s a 1 y4wg Tiese periodic testing containment n Luned in the se e rate reLutrements verify that the ieska9ety

~

analysts.es not exceed the isaka,e rate 4eCoMJ MWesa Ae. etywemas rqnWiq 4e tha 1 ce+dwed ge Qk.y lakp s, 3,, h e nte aa* % + i motbe_mer. P

-- l 1& r D' J2-For ungrouted the structural integrity post tensioned this SR ensures tendonslneen of the conta maintainedinaccordancewiththeprovision$softhe av111thatbe

. S-.

Containment Tendon Surveillance Progran. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (kef. 4).

(continued)

CEOG ST$ 8 3.6-4 Rev 1. 04/07/95

I

-id '

Containment i" ::i 3.6.1-Q '

8A$t$ (continued)

REFEREEt$ 1. 10CFR$0, Appendix ((dhi.3)

t. hSAR. be Vl([hif, Jg h ,

g@

3hSAR.Ge(MDnf [

4. Regulatory Guide 1.38. Revision g,l,, '] h l

CCM STS 8 3.6-5 Rev1,04/07/95

Containment Air Locks (^tny.,,is wi B 3.5..r}

Q SA$ts (continued) h g

~

APPLICABLE pha M centaladen9,1be OsAs that result in a

^ =

SAFETY ANALY$t$ ens or restonct' ve masortTI within containment are a less e coolant accident (LOCA), a main steam line break

~

h (TMs le.k.p c.Ja. 4 (M$LS andacontre)elementassembly(CEA) ejection acci nt (Ref. 2). In the analysis of each of these el,/.,,J ,x f, g g g ' acci nts, it is assumed that containment ta OPCRABLE such that release of fission products to the environment is N5/*A 4 -A m.' ,1,-. Te opl,m 8' 1 con elled by the rate of containment leakage. The al)A @g con ainment was designed with an allowable leakage ta l

l h I of containment air weicht per day (Ref. 3)._

t,,L

4' ' 4 4 ; ftsts is serined in 19 6r I 4gc.{et f,.k . as L.:te er maximum allowable ,

tainme,n{....a e se e at1),

leakage j,g L c A m d (nieraaf the ca ulated maulmum peak ontainment pressu P of

<[55. stie i ile a kaala, which result ra= *ka Hait aa d)ich it a

\ rea m.<c # Idh.fIsiD )' mit h (Ref. ).f This allowab'e leakage rate P

G Ah * ,tep ,A- - SRs foms the basis for tne acceptance criteria teposed on the - A associated with the air lock.

b'N L0th '

For dual containment, t radioactive material DBAs that result in a releas }

hin containment are a LOCA, a MSLB andaCEAejJctiona ident (Ref. 2). In the analy s of each of these acci nts it is assumed that contal nt is OPERABLE such the relea,se of fission products t the environment is ntrolled by the rate of conta at leakage. The ontainment was designed with a allowable leakage rate f10.50)%ofcontainmentair icht per day (Ref.3). is leaka t i 10 ctR 10 Rppendia contai nt(Ref.1),asge L.: ra the e s defined maximum 1 lowable contai leakage rate at the calcul ed maximum petk nt pressure P.) of 42.3 g w o '

the siting DBA MSLh (hich Ref. results fro 2 . This

%.2das' whic(h is a (75% R"!L'u='2' !'!' ! Men)! '

The containment air locks satisfy Criterion 3 of the NRC Policy statement.

LC0 2 ""% @A fach containment air lock form part of th containment pressure bount!ary. As part of/ containment the air lock safety function is related to control of the containment leakage rate resulting from a DBA. Thus, each air lock's structural inte rity and leak tightness are essential to the successful siti atton of such an event.

(continued)

CEOG STS 8 3.6-12 Rev1,04/07/95

Containment Air Locks WWrt .4 L.;)

B 3.6.2 @

BAl[5 LCO Each air lock is required to be OPERAILE. For the air lock (continued) to be must considered be OPERABLE OPEAABLE, the air lock must be in compilance witht the Type 8 air ink leakage must tie OPERABLE. The interlock a test, and both llows air lock doorsonly one air lock

' door of an air lock to be opened at one time. This previsten ensures that a gross breach of containment does not exist when containment is required to be OPERABLE.

Closure of a single door in each air lock ta suffletent to provide a leak tight barrier follwing postulated events.

Nevertheless both doors are kept closed when the air lock is not being,used for normal entry Jnte it free lA containment. /d APPLICABill1V radioactive es,terial to containment.In MODES 1, 2 3 and 4, a dea coul In MODES I and 6 the probablitty and consequences of these events are reduce,d due to the pressure and temperature liettations of these MODES.

Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material free containment. 1he requirements for the containment air locks during MODE 6 are addressed in LC0 3.g.3, ' Containment Penetrations.'

ACT10NS 1he ACTIONS are modified by a Note that allows entry and exit to perform repairs on the affected air lock conoonent.

If the outer door is inoperable, then it may be easily accessed for most repairs. It is preferred that the air lock be accessed from inside primary containment by entering through the other OPERA 8LE air lock. However if this is not practicable, or if repairs on either door,must be perfomed from the barrel side of the door then it is permissible to enter the air lock through the OPERABLE door, which means there is a short time during which the containment boundary is not intact (during access through the OPERABLE door). The abt11ty to open the OPERABLE door, even if it means the containment boundary is temporarily not intact, is acceptable because of the low probability of an event that could pressurize the containment during the short time in which the OPERABLE door is expected to be open.

After each entry and exit, the OPERA 8LE door must be (continued)

CE0G STS 8 3.6-13 Rev 1. 04/07/95

Containment Air Locks ("r-f r'^ ' 'N 83.6.I @

BA$Es ACTIONS c.1. c.f. and t.3 (continued)

Additionallykus within she 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time. Thethe effected air lock (s) m OPERABLE sta specified time period is considered reasonable for restoring ass alag that at an leastinoperable air lock toclosed one door is maintained OPERABLEin eac status,h effected air lock.

D.1 and 0.2 If the inoperable containment air lock caract be restored to l

i OPERABLE status within the reoutrod Ceapletten Time, the plant must be brought to a M00C in which the LC0 does not l

apply. To achieve this status the plant must be brought to

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

The allowed Completion Times to reach the are reasonablelant roovired p based conditionsonfrom operating full powerexperience,ditions con in an er&rly manner

{ and without challenging plant systems.

SURVEILLANCE 1R 3.8.f.1 REQUIREMENTS Maintaining containment air locks OPERADLE requires N e, h e, '^ compliance with the leakane rute test requirements of ou . ?----'t#J (Re r. , K uoai v i na av d ,,,a j

=

ANC inner This SR reflec b the stakage rate testl '

L e da#v. requirements with regard to air lock teskage (Type Bleakage p

7es haE (/*J"m tests)l initia air lock and containment OPERABILITY The testing.The acceptance criteria periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall antainmortt leakage rate. The Frequen:y is required by hh F Ww i s$'anM The SR has been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful perfomance of the overall air lock leakage test.

This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note I has been added to this SR requiring the results to be evaluated against the acceptance criteria of (continued)

CEOG STS B 3.6-17 Rev1.04/07/95

f Containment Air Locks (A"--"-" "' ' '

8 3.6.n C

BAS [$

$URVEllLANCE SR 3.s.f.1 (continued)

REQUIREMENTS SR 3.6.1.1. This ensures it.at air k leakage is properly accounted for in determining the I n d'

rate. entainment leakage b $

a lisell, h e.D c.

SR 3.s.t.2 The air lock interlock is dest ned to prevent simultaneous opening of both doors in a sin Ie' air lock. Since both the inner and outer doors of an at lock are designed to withstand the maximum expected post accident containment g Q,3 closure of either door will support containment gressurePERABIL TY. Thus the door interlock feature supports

% containment OPERABILITY while the air lock is being used for O h**]**ll personnel transit into and out of containment. Periodic

- w =>i testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of

- % the inner and outer doort will not inadvertently occur. Due s<d /pe rfde[. ,, / u;f\ to the purely mechanica', naturt of this interlock, and given

's than' ,he igerlock mecnanism Ishn4y challenged when

@ *'#jd'tt r,p;,e g/,.d V _.. O .:

EDenteced, this test is or.ly required to be alA*<< ace .,(,

cr<nin ,,7j, j," performed q::r,:e;t:r

p Centa"-^-* '"' '- - ' ---~'- ' ---- Ib WF O F) fr:;2:nt'.y Je ;ri .M 4;ye. The 444-4 ty Frequency is based on engineering judgment and is const'lered adequate en v4ew.-' ther *:d!:.t! = ; er deer eid ir.;e Li -cL;.i;; '

{JNserr 2. sf 3pt.t L:te: :=ti-bh te -rm .uons-pereennel, f RENCES 1. 10 CFR 50, Appendix J f* Mb / " 2.@$AR,SectionM (j ,j 7 3.@SAR,Section bh CEOG $1$ B 3.6-18 Rev 1, 04/07/95

Containment isolation Valves m-++ M en g 83.6.1 sA$ts SURVEILLAi4CE st 1.8.1 RESl1RENDris (continued) administrative means is considered acceptable since access h '

to andthese areas 3 for ALARA is typically reasons. Therefcrerestricted the probabtittydurtne,IWDES o

t 1f, misalignment thegave been vertfled of these to be in containment their proper post ts,eletion once

, is valvesgten st 1.a.19 g e ,. , cfeJ @

i I

i fre d's hats Verifying ,

,g,,

j ,j Y [,*,.(f automati at t e seletiontimeofeachgedy r I aniD ysrA4 containment tse14 tion valve is with n F Gr (teg,' ret Q; .,t required to demon trate OptRABILITY. The isolation time o test ensures the valve will tselate in a time period less ,n D than or equal to that assumed in the safety analysis.p{The W p ,yg c &(,Logf isolation tir.a and Frequent of this SA are in accordance g with the Inservice Testing regram &p e pti gs). b 7

\ bryle they ave. ' # '

Nm3 b b. Igg 3,g,3,g clopg , 4 _

For containment purge alves wit r 11 tent seals, additional leakage r e testin of 10 CFR $0, Appe 1x O(Ref.g eyond the test quirements is required ensure OptRASIL11Y. Oper ting experience, has demonst #~30 this type of seal as the potential to degra inted a that shorter time Mrted than do other seal types. Base on this observation penetration i and he importance of maintain i,this tight ces.stament the env(due to athe ironment), Fredirect ency ofath 164between days

-was establi ed as part of the NRC res issue -to ' Containment Leakage Due ution of Generic IN'I'

Seal Deterioration' Additis ally, this SR must be per reed within 92 days after opent b -r.srr.so the valve. The 92 day F quency was chosen roc ring that cycling the y e could introduce add ional seal degradation ( yond that occurring to a va e that has not been o ). Thus, decreasing the as been o(pened.terval- from 1 a prudent 184 after measure days) pen a valva J

(continued)

CEOG ST$

B 3.6-31 Rev 1, 04/07/95

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

l containment Isolation Valves 4 B 3.6. @

BASES s.

SURVEILLANCE REQUIREMENT ~~ SR 3.8.5 J (conti ed) """

equal to the sp fled leakage rate. This provid assurance that e assumptions in the safety an met. The lea ge rate of each bypass leakage t sis is are assumed to the maximum pathway leakage (f the worse age through penetrati isthe two isolation isolated by use ofvalves unl one;clo the and de-activ ted automatic valve, closed ma 1 valve, or blind l flange in this case, the leakage rat of the isolated bypas leakage path is assumed to be e actual pathway les go through the isolation devic . If both isolation va r eesisinthethelesser penetration leakageare clo de the actual leakage rate thod of quantifying maximum the two valves. This - /

hway leakage is oniy to be r used for this SR

'limittare to be q(uantifiedi.e., Appen x J maximum pathway leakage i

y The Frequency is required n accordance with Appendix J) modified by approved ex 10 CFR 50, Appendix J, as

/ icas (and therefore, the Frequency extensions of 3.0.2 may not be applied) ince the testing is an App dix J. Type C test. "This S imply imposes additional eptance criteria.

k (Bypass leakage considered part of L,. [Re ewer's Note:

\ Unless specift lyexempted).) }

/

REFERENCES 1. hSAR, CSeeMon y R N

k.

SAff Section [ ). ]

3. neric Issue B-20 4 Generic issue 24. _

h ft 'P

5. 10 CFR 50, pendik J.

. L .

~ ,

~

(b o

CEOG STS B 3.6-33 Rev 1, 04/07/95

DISCUSSION OF HASES DEVIATIONS FROM NUREG-1432 SECTION 3c6 - CONTAINMENT SYSTEMS is entered . . ." The Bases for ~~ SR 3.6.2.2 have been revised to incorporate the changes discussed above, as well as sevei :dtorial enhancements.

17. Typographical / grammatical error corrected.

CALVERT CLIFFS - UNITS 1 & 2 3.6-3 Revision 7

2, The NRC requested just:0 cation 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 3.6.12)

spc.$uhn 3,( .l 3hU

44 .Cll011NMENT SYSTEMS

3. . . , m.:.s m- co,1mn CMTAIME INTE

~)

4 LIMITIllG CMDITIM FOR OPERATIM CAD 2 4co 3.6.1 M.*4 ' Primary CONTA!WENT INTEGRITY shall be maintained.' '

4 Acru 4 ["

APPLICABILITY: N00ES 1. 2. 3 and 4.

WLe r1 ~

gg ggg gf ITYk . no CONTAIIMENT4

/k n.a S r or be in at eas restore CMTAllelENT/

~~

_.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in C0'.D SWIDonal T STANDlf within the wit following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .hin the next SURVEILLANCE REQUIREMENTS t

(.6#!! =

Primary CQRAINNENT INTEHJM shall be dgm6nstratedO N, YleTst~ once per a cays by vertryIngosthat all penetrati'li

~ isolation valves and required to be t closed during ac

" conditions are closed by valves, blind flan automatic valves secured in their positions,ges, or deactivated

$pecification 3.6.4.1./that are open under administrative -

"- control a u n e e ibt 3$1

c. ~

,,) By verifying that the equipmerit hatch is closed and segled to entering w ne MODE a4Type by conducting followingB test a shutdown gatch

, rior ejuipment L$

5 y .g=50g L.icose,

8. h

( t>f

' accenlance

=

udA 8e CodakmeN)fh*Wb

-h- -

l l 4 3$ 4q Hydrogen purge containment vent 1 solation valves : hall be o containment surveillance testing pressure purposescontrol, only. airborne radioactivity controfeneo for' 65h i

, and er &N i j4 j 4yg jib " temperaiure is below 300'F to establish w. hh5shutdown ,

c

g $c Exce t valves blind flanges, and deactivatedc automatic are

g. } valves whi

$ ocated otherwise inside secured theclosed in the containment position. and are locked, sealed, or h & 5 p3 be verified closed during each COLD SHUTDOWN except pp that suchTh verification need not be performed more often then #,once net 92 days

. i CALVERT CLIFFS - UNIT 1 3/4 6-1 Amendment No.187 6R 3J*Id hrGm reyred gani eta, awhns enA esm+ a, a.-e e, ,,a wy\<.kage- ,, .<<k e -u <+

kuk9 < , '[ '}

Lv ^ p. u,,, i,,, ,. -

k '

ucme h c.4,A uq n i s io

'a

-l se<ku u..I , ,

i h

3, g, @ ComIISIENT sysTDis 36.l- @ (muaEYCOKWWEENT 1

CONT 41101ENT *

! LDl! TING CONDITION FOR SPERATION i L c o 3.(o.1 M Primary CONTA!IglENT INTE8t!TY shall be maintained.*4 j

l.

APPLICABILITY: MODES ! 2. 3 and 4. g g g- QJjg 3 Acnos A .h : WiShet ortamf9CONTAtletEllT restore CONTAfl01DIT8f

% w' thin one hour or be in at as 4

Acn+48 9 I T stall 0BY within the next

- rs and in COLD $NiffD0181 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

1 i

SURVEILLAllCE REQUIREMENTS (4.6.M primary CONTAliswp/fitTEGRITY 3 sh #be demonstrptid:} ~

$IAt least once per n days by vertrying that all penetrationd $

not capable of being closed by OPERAB.E containment automatic isolation valves and required to be closed during accident conditions are closed by valves blind flanges automatic valves secured in theIr positions, ex cept or deactivated for valves f '

that are open under administrative control as cerettted by J tSpecification 3.6.4.1. 1 e n of e 3 1 h

c. By ver1 Tying snat sne equii;;r.er.t hatch-is closed and sealed, prior

[% to entering MODE 4 following a shutdown where the endiament hatch ym =-3ened, _O by conducting a Type B test p " ". m r g g b,,,.

\ 14b Ig

&g.2$ .

5** f $ W %

k (dD f "

\

s. , y,f fog i. r y' N j l41 s 7=g

c. g4 h Hyarogen purge consainment vent isolation valves shall be opened for3 d containment pressure control, airborne radioactivity control, and g surveillance testing purposes only. K <5 j-GQ 5M The shutdown cooling isolation valves may be opened when the RCS temperature is below 300'F to establish shutdown cooling flow.

e d "c, I d 'g **

6 a. j

-9 Except valves, bitnd flanges, and deactivated automatic valves which

' are located inside the containment and are locked, sealed, or- &du*2 otherwise secured in the closed position. These penetrations shall be vertfled closed during each COLD SHUTD0 lot except that such vertf tcation need not be nerformed more often then once per 92 days.]

CALVERT CLIFFS - UNIT 2 3/4 6-1 Amendment No. 164 ggs j,h 'p, .

bd4pobdo ^g' # "

n ->.a c4 ar. cA,n w.n~kd eL..by a A.ng%skr, a,a WL.4 bh. Po rim. L..L p M ifcAq f%""

_ - ==

l.lteMt basedeereh 1% 4 ID /"7 Y '

DISCUSSION OF CHANGES SECTION 3c6.1 - CONTAINMENT A.5 With the structural integrity of the Unit I containment not conforming to a level consistent with the acceptance criteria of CTS 4.6.1.6.2 or 4.6.1.6.3, Action b of Unit 1 CTS 3.6.1.6 requires structural integrity restored or an engineering evaluation that assures structural integrity be completed prior to increasing the RCS temperature above 200*F. His requirement is not explicitly contained in ITS 3.6.1. liowever, it is addressed via ITS SR 3.0.4. In accordance with ITS SR 3.0.4, the applicable Surveillances for an LCO are required to be met within their specified frequency prior to entry into a Mode of Applicability, ne CTS Surveillances which established the structural integrity of the containment have been incorporated into the Contalament Tendon Surveillance Program contained in ITS Section 5.0. Improved Technical Specification SR 3.6.1.2 invokes the Containment Tendon Surveillance Program. Thus, ITS SR 3.0.4 will require the structural integrity of the containment to be established (i.e., containment to be OPERABLE) prior to entering Mode 4 (i.e., prior to increasing average reactor coolant temperature to greater than 200'F). His requirement si equivalent to Action b of Unit 1 CTS 3.6.1.6. Aus, deleting Action b of Unit 1 CTS 3.6.1.6 is an administrative change, which does not change the intent of the CTS.

A,6 Current Technical Specification 3.6.1.6 SRs are being moved to the Containment Tendon Surveillance Program in ITS Section 5.0. Improved Technical Specification 3.6.1 will contain an SR (SR 3.6.1.2) which requires the containment structural integrity to be verified in accordance with the Containment Tendon Surveillance Program. Adding a SR which references a program in Section 5.0 constitutes an administrative change. This change is consistent with NUREGJ.432.

A.7 Current Technical Specifica* ion SR 4.6.1.1.b requires the verification that the containment air locks are in compliance with the requirements of Specification 3.6.1.3. His SR has not been retained in ITS 3.6,1, Current Technical Specification SR 4.6.1.1.b invokes Specification 3.6.1.3, which provides requirements to ensure the operability of the containment air locks. In the ITS, the operability requirements for the containment air locks will be contained in ITS 3.6.2. This proposed change eliminates an SR which simply invokes another TS; i.e., it is simply a cross-reference to another Specification. The elimination of CTS SR 4.6.1.1.b is administrative, because this proposed change does not change the intent of the CTS, the containment air locks requirements are still required by CTS 3.6.1.3 and ITS 3.6.2.

TECHNICAL CHANGES - MORE RESTRICTIVE M.1 Unit 1 CTS 3.6.1.6 Action a requires the plant to be in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , if the Required Actions and associated Completion Times cannot be met, when the containment structure exhibits evidence of possible abnormal degradation, per Specification 5.5.6,

" Concrete Containment Tendon Surveillance Program." Improved Technical Specification 3.6.1 requires the plant to be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This change adds an intermediate step to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to the shutdown track. This change is acceptable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner, and without challenging plant systems. Adding an intermediate step will not adversely affect plant safety because it ensures a shutdown that minimizes stress on safety systems. His change is consistent with NUREG-1432.

CALVERT CLIFFS - UNITS 1 & 2 3.6.1-2 Revision 7

3. The NRC questioned the validity of the justification provided for the elimination of Action b of CTS 3.6.1.6. Discussion of Change A.S for ITS 3.6.1 was revised to provide the appropriate justification. (Comment 3.6.13)

DISCUSSION OF CHANGES SECTION 3.6.1 - CONTAINMENT A.5 With the structural integrity of the Unit I containment not conforming to a level consistent with the acceptance criteria of CTS 4.6.1.6.2 or 4.6.1.6.3, Action b of Unit I CTS 3.6.1.6 requires structural integrity restored or an engineering evaluation that assures structural integrity be completed prior to increasing the RCS temperature above 200'F. This requirement is not explicitly contained in ITS 3.6.1. liowever, it is addressed via ITS SR 3.0.4. In accordance with ITS SR 3.0.4, the applicable Surveillances for an LCO are required to be met within their specified frequency prior to entry into a Mode of Applicability, he CTS Surveillances which established the structural integrity of the containment have been incorporated into the Containment Tendon Surveillance Program contained in ITS Section 5.0. Improved Technical Specification SR 3.6.1.2 invokes the Containment Tendon Surveillance Program. Thus, ITS SR 3.0.4 will require the structural integrity of the containment to be established (i.e., containment to be OPERABLE) prior to entering Mode 4 (i.e., prior to increasing average reactor coolant temperature to greater than 200'F). This requirement is equivalent to Action b of Unit 1 CTS 3.6.1.6. Thus, deleting Action b of Unit i CTS 3.6.l.6 is an administrative change, which does not change the intent of the CTS.

A.6 Current Technical Specification 3.6.1.6 SRs are being moved to the Containment Tendon 4

Surveillance Program in ITS Section 5.0, improved Technical Specification 3.6.1 will

contain an SR (SR 3.6.1.2) which requires the containment structural integrity to be verified in accordance with the Containment Tendon Surveillance Program. Adding an SR which references a program in Sectian 5.0 constitutes an administrative change. This change is consistent with NUREG 1432.

A.7 Current Technical Specification SR 4.6.l.l.b requires the verification that the containment air locks are in compliance with the requirements of Specification 3.6.1.3. This SR has not been retained in ITS 3.6.1. Current Technical Specification SR 4.6.1.1.b invokes Specification 3.6.1.3, which provides requirements to ensure the operability of the containment air locks. In the ITS, the operability requirements for the containment air locks will be contained in ITS 3.6.2. This proposed change eliminates an SR which simply invokes another TS; i.e., it is simply a cross-reference to another Specification. The elimination of CTS SR 4.6.1.1.b is administrative, because this proposed change does not change the intent of the CTS, the containment air locks requirements are still required by

CTS 3.6.1.3 and ITS 3.6.2.

J

, TECIINICAL CIIANGES - MORE RESTRICTIVE M.I Unit 1 CTS 3.6.1.6 Action a requires the plant to be in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , if the Required Actions and associated Completion Times cannot be met, when the containment structure exhibits evidence of possible abnormal degradation, per Specification 5.5.6,

" Concrete Containment Tendon Surveillance Program." Improved Technical Specification 3.6.1 requires the plant to be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This change adds an intermediate step to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to the shutdown track. This change is acceptable, based on operating experience, to reach the required Sant conditions from full power conditions in an orderly manner, and without challenging plant systems. Adding an intermediate step will not adversely affect plant safety because it ensures a shutdown that minimizes stress on safety systems. This change is consistent with NUREG-1432.

CALVERT CLIFFS - UNITS 1 & 2 3.6.1-2 Revision 7 4

4, in the CTS Markup of Action a of Unit 1 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 perfonn 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 Commer.ts, the following changes were made: 1) DOC LA.! was revised to state that the i

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 3.6.1.2 were revised to eliminate the discussion regarding the engineering evaluation. (Comments 3.6.1-4 and 3.6.15)

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

Containment i B 3.6.1 i r '

BASES testing only, and s 0.75 L. (259.500 SCCM)foroverall Type A leakage following an outage or shutdown that included i

Type A testing. At all other times between required leakage 3

rate tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 L., At s 1.0 L the offsite

dose consequences are bounded by the assumptions of the safety analysis. Surveillance Requirement Frequencies are as required by s'ontainment Leakage Rate Testing Program.

These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

Additionally, the requirements regarding the Unit 1

containment purge isolation valves must be met. 7 SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Concrete Containment Tendon Surveillance Program. Testing and 4 Frequency are consistent with the reconinendations of

, RegulatoryGuide1.35(Ref.4).

7 REFERENCES 1. 10 CFR Part 50 Appendix J. Option B

2. Updated Final Safety Analysis Report, Chapter 14

3. Updated Final Safety Analysis Report, Chapter 5

4. Regulatory Guide 1.35, Revision 2, January 1976 7 CALVERT CLIFFS - UNITS 1 & 2 8 3.6.1-5 Revisionp'?

DISCUSSION OF CliANGES SECTION 3.6.1 CONTAINMENT M.2 Unit 2 CTS 3.6.1.6 Action requires the structural integrity to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when it is not conforming to the requirements of the LCO. Improved Technical Specifications will require the containment to be restored to Operable status within one hour.

He ITS will require the containment to be declared inoperable if its stmetural integrity is not maintained and the containment cannot meet its design function. His change is considered more restrictive because it is assumed that the containment is inoperable when the Actions are entered. Herefore, the AOT is decreased from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to I hour.

Decreasing the AOT constitutes a more restrictive change. This change will not adversely affect pant safety because the containment is one of the three barriers against a release of 1

radiation, nis change is consistent with NUREG-1432.

TECIINICAL CIIANGES - RELOCATIONS None TECllNICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Unit 1 CTS 3.6.1.6 Action a allows 90 days to perform an engineering evaluation when the containment structure exhibits evidence of possible abnormal degradation, per the tendon Surveillances. This requirement is being relocated to the Technical Requirements Manual (TRM), a licensee-controlled document. This is acceptable, because moving the requirement does not affect the requirement to maintain the containment OPERABLE. He requirement only applies when the operability of the containment is indeterminate, if there is evidence that the containment may be inoperable, prompt action should be taken to evaluate the condition to determine its impact on the capability of the containment to fulfill its safety function. Questions regarding the operability of systems, structures, and components are addressed routinely during the operation of the units. The ITS t, not provide requirements for conducting operability determinations, in the event the containment is determined to be inoperable by an engineering evaluation performed in accordance with this requirement, the plant will be required to immediately enter Action A ofITS 3.6.1. The Actions ofITS 3.6.1 provide adequate protection of the health and safety of the public. Additionally, the level of safety of facility operation is unaffected by the change because there is no change in the requirement to perform an engineecing evaluation to determine if the containment is inoperable. Thus, the requirement of Unit i CTS 3.6.1.6 Action a to perform an engineering evaluation to demonstrate containment operability can be adequately controlled in the TRM.

The TRM will be included in the Calvert Clifts' UFSAR by reference. Rus, any changes to this requirement, once it is relocated to the TRM, will be made in accordance with 10 CFR 50.59.

LA.2 Not used. l LA.3 Not used. l TECHNICAL CIIANGES - LESS RESTRICTIVE L1 Unit 1 CTS 3.6.1.6 requires a plant shutdown if the containment tendons or structure exhibit evidence of abnormal degradation, and continued operation cannot be justified by an engineering evaluation within 90 days. Improved Technical Specification 3.6.1 Action A CALVERT CLIFFS - UNITS 1 & 2 3.6.1-3 Revision 7

3 Containment (Atmospheric) 83.6.1 BASES ACTIONS B.1 and R.2 (continued)

MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at lean MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience to reach the required plant conditions from full powercondItionsinanorderlymannerandwithout challenging plant systems.

SURVE!LLANCE SR 3.6.1.1

' REQUIRENENTS bW Maintaining the cowninner.t OPERABLE requires compliance me with the visual'examina.; ions and : eskage rate test Aaa== x J r_ me lqu mmnneca Dyreouirements Abprovec A of O CFrio.

Cod 6,n.}. L,p,? tipnf f allure to meet (pirin k e6d c Lvalv*41th en111mnL4M leakage limits spec' ffed'Ili,pjt'g Mt 'Te d ad vfr.er m LEO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of these overall leakage determinations unless

[e their contributton to overall Type A. B and C leakage i

E

lMay a s ,f.dg '"

causes that to exceed limits. As left Isakage erior to the M%

first startup after performing a required vogw -- 8" d

g% 4kh MQ ependir J3 leakage test is requiredlo be QLO.6 L. dor combined Type B and C leakagg. and 50.75 L.ato, or oyerali 8 T " % 'd G3b 3 iype A leakas . At all other times between requireo iestageN rfate te e acceptance criteria is based on an averall L h e,soo 8

4 Type A leakage limit of 51.0 L*. At s 1.0 L dose consequences are bounded bv the assumpti. ons of the the offsite see f,g.,) '" *d*y or safety analysis. SR Frequencies are as required by K3penpa a, n ;iipo py approvec exejiptions. Inus, j m 4

ddb. 4.L 6Li,Q 114.2 twhich alleGs Frecuenev extensions) does notApply.)

.' y -

14ese periodic testing raterehutrements verify that therate

(

4 +"3] containment leakage assumed _in the safety analysis.

oes not exceed the leakage b

M M*N'"8 "SO*AN M1C*****b 4

Medo, g dmo.w3.,Lj"k,/' 3.6.1.2 SR

?"T D*kh OSS "" DIE ** -

l S. , r,

For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be A J2- maintained in accordance with the provisions of the 1 Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4).

(continued)

CEOG STS B 3.6-4 Rev1,04/07/95 4

f

~

INSERh B 34[SR 3.6.1.2

/ f

. If the con at structure exhibits evi cc ofpossible abnormal de dation per Specification j 5.5.6, " oncrete Containment T - urveillance Program," an e neerlag evaluation is

. perf to demonstrate the abili of the containment structure continue to perform its design tion. The engineering eval ion is required to be complet within 90 days of the test.

(

i I'

i e

I 3

s

(

)

i i

f I

b l

I 4- -

1 1

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 provided in the CTS Markups for ITS Section 5.0 and the revised

..surveillances issued in 1.icense 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 Insert 5.5.16 and the revised surveillances issued in License Amendment Nos. 221 and 197. (Comment 3.6.1-6)

sp,,.St hts 3.c.,1 i

'Assse Ae< d""N

[By verifying that the containmenttblind flanges are installed and seale[ prior to entering h, f following a shutdown where the blind flanges were removed, by conducting a Type B test per 10 CFR Part 50, Appendix J. If only one blind flange was remoy only that blind flange mu ky n' \

agsgg.w2.; y s ,, ,.

o g g. a , p c. M 5 i

i Lie m a A A n d 211

6 p4. E d w ~ 3.C..I INSERT A kemt kwh? FEN I

[By verifying that the containment blind flan 8es are installed and scaledhrior to entering MODE 4 f following a shutdown where the blind fiknges were :emoved, by conducting a Type B test per.10 CFR Part 50, Appendix J. If only one blind flang; was removp only that blind flange must be g

uaess 4n%13 recic,n3 IethwIcA\ Speci b b 4,6 l.1, .%,4 Discci&a 8. c.b ug .

' ^ ^ ^

y s y k k S.o i

Mm,mkW W' 1

i 4

1 4

1 i

4 k

i k

- ~

n j- >

6. 'Ihe NRC identified that the reference to the revision of Regulatory Guide 1.35 contained in the 1- ISTS Bases Markup for ITS 3.6.1 was different than the revision of Regulatory Guide 1.35

- referenced in ITS 5.5.6. The revision referenced in ITS 5.5.6 is correct, so the reference in the i

ISTS Bases Markup for ITS 3.6.1 was revised to reference Revision 2, versus Revision 0.

(Comment 3.6.1 7) 4 I .~

r i

l-1-

1 i

b 1

i

} --

I 6

I t

i i

)

4 i

1-I-

a i

1

.?

i-i-

a i

- -,--e~ - - , , , ,,,m., , , - _. . , , ,. . - , .- ,,, , , , . - ... . - . ,

Containment B 3.6.1 BASES testing only, and s 0.75 L. (259,500 SCCM) for overall Type A leakage following an outage or shutdown that included Type A testing. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of s 1.0 L., At s 1.0 L. the offsite dose consequences are bounded by the assumptions of the safety analysis. Surveillance Requirement Frequencies are as required by Containment Leakage Rate Testing Program.

These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis.

Additionally, the requirements regarding the Unit 1 1 containment purge isolation valves must be met. 7 SR 3.6.1.2 i

For ungrouted, post tensioned tendons,_this SR ensures that the structural integrity of the containment will be maintained in accordance with the provisions of the Concrete Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4).

7 REFERENCES 1. 10 CFR Part 50, Appendix J. Option B s

2. Updated Final Safety Analysis Report, Chapter 14

3. Updated Final Safety Analysis Report, Chapter 5

4. Regulatory Guide 1.35. Revision 2. January 1970 7 CALVERT CLIFFS - UNITS 1 & 2 B 3.6.1-5 Revisionp'7

1 Containment 122=: i g SASES (continued)

REFERENCES 1. 10 CFR 50 Appendix

c. 9 =.s -.. vn (y rsw(d$.[J) f h

3gSAR,GecHbn1 w

h

4. Regulatory Guide 1.35, Revision

~J; ~ g b l

I l

4 CE0G STS- S 3.6-5 Rev 1, 04/07/95 4

7. Discussion of Change L.4 for ITS 3.6.2 was en' enced to provide additional clarifi:ation. !his proposed change was required to respond to an NRC comment. (Cotament 3.6.2-3) 0

DISCUSSION OF CHANGES i e

SECTION 3.62 - CONTAINMENT AIR LOCKS L.2 Current Technical Specification 3.6.1.3 Action b, when an air lock is inoperable as a result of an inoperable door gasket, requires the Operable door to be maintained locked closed and sealed, and the air lock restored to Operable status within 7 days. Improved Technical Specification Action A will require the following Actions:

1. Within I hout verify an Operable door is closed in die affected air lock;

2. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months lock the Operable dcor closed in the affected air lock; and

3. Once per 31 days verify the Operable door is locked closed in the affected air lock (this Action is modified by a Note which allows the air lock doors in high radiation aren to be verified locked closed by administrative means).

This change increases the time to restore an inoperable air lock door to Operable status (when due to a gasket being inoperable) from seven days to no time limit as long as the Operable door is locked closed and verified closed periodically. This change is acceptable because when an Operable air lock door is maintained closed, a 1:ak tight barrier separates containment with the cutside atmosphere. This ensures that no radioactive material will be released through the air locks. Relaxing the Completion Time to restore the air lock to Operable status constitutes a less restrictive change. This change is consistent with NUREG-1432.

L.3 Improved Technical Specification 3.6.2 contains an Actions Note (Note 1) which allows entry and exit to perferm repairs on the affected air lock components. Current Technical Specification 3.6.1.3 Action b does not contain this allowance, although Action b (air lock inoperable due to an inoperable gasket) does contain a requirement to maintain the Operable air lock door in a closed position. This change will allow an exception to the Actions to maintain the Operable door in a closed position by allowing it to be cpened to perform repairs on the inoperable gasket. If the outer door is inoperable, then it may be easily accessed for most repairs (the inner door is providing the leak tight barrier). If the inner door is inoperable, it is preferred (as stated in the Bases) that the air lock be accessed from inside containment by entering through the other air lock. If this is not practicable, or if repairs on

~

either door must be performed from the barrel side of the door, then it is permissible to enter the air lock through the Operable door. After each entry and exit, the Operable door must be immediately closed. This is acceptable because of the short time period during which the containment boundary is not intact and the low probability of an event occuring that would pressurize containment during this period. The addition of an allowance which allows entry and exit through an inoperable air lock constitutes a less restrictive change. This change is consistent with NUREG-1432.

L4 Improved Technical Specification 3.6.2 contains a Note (Note 2) in Action A which allows

, entry and exit into containment for seven days under administrative controls if both air locks are inoperable due to each having an inoperable door. Current Technical Specification l 3.6.1.3 Action b does not contain this allowance. The seven-day allowance begins when the second air lock is discovered inoperable. Containment entry may be required to perform Technical Specification SRs and Required Actions, as well as other activities on equipment inside containment that support Technical Specification required equipment. This allowance is acceptable due to the low probability of an event that could pressurize the containment CALVERT CLIFFS - UNITS 1 & 2 3.6.2-4 Revision 7

DISCUSSION OF CHANGES SECTION 3.6c2 - CONTAINMENT AIR LOCKS during the short time that the Operable door is expected to be open. His change is l consistr-t with NUREG 1432.

L.S Current Technical Specification 4.6.1.3.c requires verification that only one door in each air lock can be opened at a time (interlock mechanism), once per six months. Improved Technical Specification SR 3.6.2.2 will require this Surveillance to be performed once per 24 months, nis change decreases the Frequency for verification of the interlock mechanism from 6 months to 24 months. This test ensures that the interlock, which prevents both air lock doors from being opened at the same time, is Operable. Since closure of either door will support containment Operability, normal personnel entry and exit will maintain containment integrity. The 24 month Frequency is based on the potential for loss of containment Operability if the SR were to fail when being performed with the reactor at power, it also is based on engineering judgment and is considered adequate given that the interlock is not typically challenged during use of the air locks. Decreasing SR Frequencies constitutes a less restrictive change, nis change is consistent with NUREG-1432.

4 B

+

d CALVERT CLIFFS - UNITS 1 & 2 3.6.2-5 Revision 7

i 7

8. - The NRC identified that the ISTS Bases Markup for ITS SR 3.6.2.2 did not match the wording--

, approved in -TSTF-17, Revision 1. The NRC is correct, llowever, the TSTF 17. wording 3

contained several technical errors Justification for Deviation 16 for Bases Section 3.6 has been -

provided tojustify the deviations from the approved TSTF 17 wording. (Comment 3.6.2-4)

I 4

} -

i 4

i I

2 t

s 4

i i.

l.

i i

I

t Containment Air Locks ptx:fde '-f ^=1' 83.6.I C

aAsEs SURVEILLANCE SR 3.8.2.1 (continued)

REQUIREMENTS SR 3.6.1.1.

, This ensures that airgleakage is properly ! n 8Jb

accounted for in determining the s ontainment leakage a plis,Un h rate. f4 c

SR 3.6.2.2

-The air lock interlock is dest ned to prevent simultaneous opening of both doors in a sin le air lock. Since both the inner and outer doors of an at lock are designed to withstand the maximum expected post accident containment

Q.h pressure closure of either door will support containment OPERA 81L TY. Thus the door interlock feature supports

~~

~ containment CPERABILITY while the air lock is being used for personnel transit into and out of containment. Periodic l

h*"^]* 3lh

- - = - testing of this interlock demonstrates that the interlock m mm will function as designed and that simultaneous opening of the inner and outer doors will not inadvertently occur. Due used hef,d7 ,,) o to the ourely mechanical nature of this interlock, and given (F"jdat rep;,e g/,.d '; r_Ethat the. ;interlockis+enteced, secnanism this test is1sfoaly challenged only required to be when alSe<<nce f ,4< g,,

cPe. ) performed

'-- =-ti,, ti,;..r;:.....,

.t: r':;M

. =t =r-- S deye.un' * !-- nt Mt i:;p',7;;

The 484-de Frequency is nrf - 0 aased

, ,,n oe.ngine,ering

_u _..,,judgmen,t and is conti L\

. t.. _ - m- 4 m.- fered

- - adequat,e 4e m ,LG 5t3L7j ihi Siit;ti; ^..

y.. .Ge..; greennel.

EFERENCES 1. 10 CFR 50, Appendix J f

N M / 'r/eh 2. Q SAR, Section W u Ad ed//rg<d e""?

"St af '/A' 9 Qlocha 3. @ $AR, Section k-- - DThW" bh '

CEOG STS B 3.4-18 Rev 1, 04/07/95 l

l 9

, INSERT B 3.6.2 SR 3.6.2.2 every 24 months, 'Ihe 24 month Frequency is based upon the need to perform this Surveillance /

under the conditions that apply during a plant outage and the potential for loss of containnut i

OPERABILITY if t'.:e Surveillance were performed with the reactor at power. *lhe 24 month Tsfr l? -

Frequcacy for the interlock is justifux! based on generic operating experience.

DISCUSSION OF BASES DEVIATIONS FROM NUREG-1432 SECTION 3.6 - CONTAINMENT SYSTEMS

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

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

These Specifications are B 3.6.1, " Containment (Dual)," B 3.6.4B, " Containment Pressure (Dual)," B 3.6.6B, " Containment Spray and Cooling Systems (Atmospheric and Dual)," B 3.6.7,

" Spray Additive System (Atmospheric and Dual)," B 3.6.9, " Hydrogen Mixing System (HMS)

(Atmospheric and Dual)," B 3.6.11, " Shield Building (Dual)," and B 3.6.13, " Shield Building Exhaust Air Cleanup System (SBEACS)(Dual)." Dese Specifications were not included in the Calvert Cliffs ITS. His change is consistent with Calvert Cliffs' current licensing basis.

13. NUREG-lO2 B 3.6.4 Applicable Safety Analyses Section contains information concerning the containment design. Calvert Cliffs' ITS will not contain this information because it is not applicable, ne Calvert Cliffs containment was designed for the event described in B 3.6.4 Background. This change is consistent with the Calvert Cl?ffs current licensing basis.

14. Specification 3.6.3, Containment isolation Valves, Condition C applies to Containment Isolation Valves on a closed sy:; tem. At the request of the licensed operators, we have included a list of containment penetrations which are in a closed system in the Bases, nis list is taken from the Calvert Cliffs Updated Final Safety Analysis Report, Figure 510 and Table 5.3 and will assist the operators in accurately following the Technical Specifications. In addition, a reference to the Standard Review Plan description of closed systems was eliminated. Calvert Cliffs is not licensed to the Standard Review Plan for containment isolation valves and the referenced description does not match the Calvert Cliffs licensing 1 asis.

15.

The Bases for NUREG 1432 SR 3.6.10.2 state: "The filter tests are in accordance with Regulatory Guide (RG) 1.52 (Ref. 3)." His statement has been deleted from the Bases ofITS SR 3.6.8.2. Additionally, the reference to RG 1.52 has been deleted. Currently, the filter testing requirements for the lodine Removal System are contained in CTS 4.6.3.1.b. This SR denotes that Calvert Cliffs complies only with portions of RG 1.52, Revision 2; Calvert Cliffs does not comply with all the positions established in RG 1.52, Revision 2. Thus, the statement contained in NUREG-1432 SR 3.6.10.2 does not apply to Calvert Cliffs. The provisions of RG 1.52, Revision 2 to which Calvert Cliffs complies are defined in the Ventilation Filter Testing Program provided in ITS 5.0. The Bases for ITS SR 3.6.8.2 refer to the Ventilation Filter Testing Program; thus, the Bases do not need to define the provisions of RG 1.52, Revision 2 to which we comply.

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

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

It should state: "given that the interlock mechanism is not normally challenged when the air lock CALVERT CLIFFS - UNITS I & 2 3.6-2 Revision 7

- = - - ._. - .

DISCUSSION OF BASES DEVIATIONS FROM NUREG-1432 1 SECTION 3.6 - CONTAINMF.NT SYSTEMS is entered . . ." The 9ases for ITS SR 3.6.2.2 have been revised to incorporate the :hanges discussed above, as well as several editorial enhancements.

17. Typographical / grammatical error corrected.

J t

4

}

i CALVERT CLIFFS - UNITS 1 & 2 3.6-3 Revision 7

9, he 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 3.6.3 was revised as requested. (Comment 3.6.31) l

DISCUSSION OF CHANGES SECTION 3.6.3 CONTAINMENT ISOLATION VALVES direction consistent with the intent of the existing Actions for the containment isolation valves, nis change is consistent with NUREO 1432.

A.6 Improved Techrjcal Specification 3.6.3 will contain an Actions Note (Note 3) which requires entry into applicable Conditions and Required A:tions for system (s) made inoperable by CIVs. Current Technical Specification 3.4.3.1 does not contain this requirement. His change adds a requirement to declare system (s) inoperable that are made inoperable by inoperable CIVs. His Action was added because, per ITS LCO 3.0.6, only the Actions of the CIVs would have to be entered, llowever, since inoperable CIVs require isolation of ;

penetrations to the affected system (s) with continued operation, cascading to the affected system la prudent. His requirement is necessary because unlimited continued operation with a system inoperable could teverely affect the mitigation of accidents and violate the ,

safety analyses. The CTS does not contain a Specificetion similar to LCO 3.0.6 and, therefore, already requires cascading, no addition of a requirement which is already required in the CTS is an administrative change. His change is consistent with NUREO.14.12.

A.7 Not used.

l A.8 Current Technical Specification 4.6.4.1.3 requires the isolation time of each power-operated or automatic CIV to be determined to be within its limit when tested pursuant to Technical Specification 4.0.5. Improved Technical Specification will require the SR to be performed in accordance with the Inservice Testing piogram, nis change is administrative because ITS moved CTS 4.0.5 and incorporated it into the inservice Testing program, which is required per ITS Section 5.0. The requirement to perform the SR has not changed. His change is consistent with NUREG lP2, A.9 Current Technical Specification 3.6.4.1 does net specifically have different Actions for different types of penetrations. Improved Technical Specific <tian 3.6.3 contains Actions for different type penetrations with different numbers of valves inoperable, improved Technical Specification 3.6.3 Actions A and B will contain a Conciltions Note which specifies that these Conditions only apply to penetration flow paths with two CIVs and not a closed system. Improved Technical Specification 3.6.3 Action C will contain a Conditions Note which specifies that this Condition only ar. plies to penetration flow paths with one or more CIVs and a closed system. A&lleg Notes which specify which Actions are applicable is an administrative change because thmquirement h not affected technically.

A.10 Unit I CTS 3.6.1,7 Action a requires an open containment puige supply and exharst isolation valve to be closed, improved Technical Specification 3.63 will require an inoperable containment purge supply arl exhaust isolation valve to be closed. He ITS combines all containment isolation valves into one specification and does not specifically contain Actions for the containment purge system valves. Therefore, the ITS Actions require the valves to be closed when the valve is inoperable, ne bases will require the containment purge supply and exhaust isolation valves to be closed as a part of their Operability requirements, nerefore, changing closed to inoperable in the Actions is an administrative change. This change is specific to Unit 1 because the Unit 2 containment purge and exhaust isolation valves located outside containment are beirq replaced with blind fianges for operation in Mooes 1 through 4. De Unit I containment purge and exhaust penetrations will also be modified to have blind fianges installed during the 1998 Unit I refueling outage.

~

CALVERT CLIFFS - UNITS 1 & 2 3.6.32 Revision 7

10 1he NRC was concerned that adding Action 11 ofISTS 3.6.8 to C1S 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 additional discussion and just!fication for the change. The a:sociated no significant huards considerations (NSilC) did not require revision.

(Comments 3.6.3 3 and 3.6.71) l I

i l

n l

R

_ _ m - = , - - - - - ' - ' - -'

" ' " " " " ~ ~ ~ ~ ' ' ' '

3 DISCUS $lON OF CHANGES SECTION 3 6.7 . HYDROGEN RECOMBINERS I

unaffected by the change because there is no change in the requirement to perform a i resistance.to ground test. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. His is a less j

testrictive movement of information change with no impact on safety. His chany is j consistent with NUREO.1432.

LA.3 Current Technical-Specification LCO 3.6.5.2 contains the regelroment for the hydrogen 1

recombiners to be indepenJent. Improved Technical Specification 3.6.7 will not contain this l l requirement. He ITS will move this detail to the Background Section of the :

Specification 3.6.7 Bases. His is acceptable because this requirement does not impact the

! requirement for the hydrogen recombiners to be Operable. De trigh of the. ;

hydrogen recombiners is a design detail that does not belong in the Technical Specifications.

His detail can be adequately controlled in the Bases which are controlled via Section 5.0.

j Dis approach provides an effective level of regulatory control and provides fora' more

) l appropriate change control process. De level of safety of facility operation is unaffected by

[ the change because there is no change in the design requirement that the hydrogen l recombiners be independent, and also, no change in the LCO requirement for the hydrogen 1

recombiners to be Operable. Furthermore, NRC and Calvert Cliffs resources associated with

processing license amendments to these requirements will be reduced. His change is a less i restrictive movement of information change with no impact on safety, his change is consistent with NUREG 1432.-

l LA.4 Current Technical Specifications 4.6.5.2.b.3 and 4.6.5.2.b.4 list specific test acceptance criteria for the hydrogen recombiner functional test and resistance to ground test. Improved

{ Technical Specification 3.6.7 will not contain the specific acceptance criteria. He ITS only J

requires that a functional test (SR 3.6.7.1) and a resistance to ground test (SR 3.6,7.4) be i performed, ne specific acceptance criteria will be moved to the specific SR sections in the

{ Specification 3.6.7 Bases. This is acceptable because this specific acceptance criteria does t

not impact the requirement for the hydrogen reconbiners to be proven Operable by

}= performance of the functional test and resistance to ground test. He acceptance criteria can

[ -

be adequately controlled in the Bases which are controlled via Section 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 '

there is no change in the requirement to perform the SRs. Furthermore, NRC and Calvert

! Cliffs resources associated with processing license amendments to these requirements will j be reduced. His change is a less restrictive movement of information change with no impact on rafety. This change is conalstent with NUREG 1432, i

{ TECHNICAL Cl[ ANGER ,,,,LESS RESTRICTIVE 3 L.1 in the event both hydrogen recombiners are inoperable, the CTS would require compliance with Specification 3.0.3, because CTS LCO 3.6.5.2 does not contain an action to address

both hydrogen recombiners inoperable. Current Technical Specification 3.0.3 requires the

plurat to be pbecd in a Mode for which the LCO does not apply within a specified time i period. Action B for ITS 3.6.7 permits the plant to continue to operate, as long as the

hydrogen control ftmetion is periodically verified to be mainte 'ned by administrative means, 3 and one hydrogen recombiner is restored to an operable status within 7 days. Action B of

ITS 3.6.7 is being incoiporated into the Actions of CTS LCO 3.6.5.2. He Bases for

- Action B of NUREO.1432 LCO 3.6.8 (i.e., Action B of ITS 3.4.7) contains a Reviewer's i

~

CALVERT CLIFFS . UNITS I & 2 3.6.72 Revision 7 1-

,-mw em g, y m w m-. -

- -,em,.m.-,-,,r3 v vew.,,,,,,,y--rpr.-w wv., e w %,----m,- .,.,-_._.n-,m y r m -- n.7,,we.m.- ,-<r *y-,ye..r &-+ e-+-+verrr--e-+e*

DISCUSSION OF CIIANGES SECTION 3_6.7. HYDROGEN RECOMBINERS Note which states: "nis Condition is only allowed for units with an alternate hydrogen control system acceptable to the technical staff." incorporation of the Action into CTS 3/4.6.5.2 is appropriate, because Calvert Cliffs possesses an alternate means of hydrogen control that has been found acceptable by the technical staff, in Section 3.2.2.3 of the original Safety Evaluation for Calvert Cliffs Unit Nos. I and 2, dated August 28,1972, the Atomic Energy Commission stated: "The hydrogen purge system provides a backup means of hydrogen control should both of the recombiners fall to function properly...We have concluded that the provisions for mixing, measuring, and controlling the quantity of hydrogen in the containment following a LOC /. are adequaa." ne proposed change is acceptable, because:

1. the containment vent / hydrogen purge system is an acceptable alternative to the hydrogen recombiners. He containment vent / hydrogen purge system is capable of maintaining hydrogen concentrations inside containment below the required lirait of 4.0v/o;

2. the action includes a requirement to periodically verify by administrative means that the hydrogen control function is maintained;

3. the containment vent / hydrogen purge system is utilized during normal operations for purposes other than hydrogen control. Thus, the operators are familiar with the system and its operation. Following an accident, there will be adequate time to place the containment vent / hydrogen purge system into operation if the need arises, because the hydrogen concentration builds up slowly; and

4. the revised action will permit the plant to avoid unnecessary transients (i.e., unplanned shutdown) and the potential challenges (e.g., cyclic stress) inherent to these operations, L.2 Current Technical Specification 4.6.5.2.a requires a six month functional test of the hydrogen recombiner to verify the minimum heater sheath temperature increases to 2 700*F within 90 minutes, and is maintained for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , improved Technical Speellication 3.6.7 will not contain this requirement. Generic Letter 93 05 recommended extending the frequency of the six month hydrogen recombiner functional test to the refueling interval. For Calvert Cliffs, extending the frequency of CTS 4.6.5.2.a to 24 months would result in requiring two functional tests of the hydrogen recombiners to be performed at the same frequency, but with different acceptance criteria. His is inappropriate. CTS ,

SR 4.6.5.2.b.3 requires a system functional test for each hydrogen recombiner 'o be performed every refueling interval. His SR requires the heater sheath temperature to be increased to 21200*F within 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , and maintained for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Current Technical Specification SR 4.6.5.2.b.3 has been maintained as ITS SR 3.6.7.1. His SR is the correct test to perform every 24 months; it ensures the hydrogen recombiners can perform their function (i.e., heat a hydrogen air mixture to above ll50'F). Current Technical l Specification 4.6.5.2.b.3 provides the appropriate acceptance criteria for ensuring the hydrogen recombiners can perform their function. He acceptance criteria of CTS 4.6.5.2.b.3 encompass the acceptance criteria of CTS 4.6.5.2.a. Deleting CTS 4.6.5.2.a will not affect the ability to demonstrate the operability of the hydrogen recombiners.

Additionally, no problems were identified while performing CTS 4.6.5.2.a (during a search of the SRs back to 1985); and the six month functional test is not recommended by the CALVERT CLIFFS UNITS 1 & 2 3.6.7-3 Revision 7

11. Cunent 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 aller maintenance, repair, or replacement work is performed on the valve or its associated actuator, 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 provided as DOC L10 (and its associated NSilC) 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) l l

l

c.p e.0,ub *s t , g 3 t. 3/4,4 CONTAllb WIT SY$T ms y, g,3 -3/4.4,4 CONTAINMENT ISO MTION VALVES LIN! TING CONDITION FOR OPttATION ,

LCo 'sta 4,6,4,6 Each containment isolation valve shall be 6PERABLt.' '

APPL 1tARILITY: N0Dts 3, 2, 3, and 4.

AGI12: With one or more of the isolation valve (s) inoperable, either: -

{ swss "sne inoperp vaivets; pruuuu status, sun []- h c

4 " Isolate each aff w mwneso w ed penetratTon siithinehours er use of at g.r g ,,,3 f* A ,9 4 c.

least one dee Position, orp voted automatic valve secQd in the isolation g,.., Qe i.V..Q y - 6.,g, 4, Isolate the affected penetration within( hours by use of at/e,.M8 FC' least one closed manual valve or blind f.anges or A "Se in at least M0T STANDtY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD j 'yg- U} g Acm.; D . SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b LI tt N Nrak$n a!N. 46 k

.Th'JtW A c n is: Aw.:

~~ ,--9

$URVE!LLANCE REQUIR[NtNTS ^"

4. 6.4. J1 Each contalhment iso tion valve shall be demonstrated UPERA) '

the valve service after maintenanc prior,oreturnin!sperfo repair,or gA rep cement work c

on the valve or its also ted actuator roi or power circuit y performance i L'O of a cycling est and vertf] ation)

.N _ __ isola, tion t h

,, - -n

~ i

-. . . - ~- v v

'C.Ah., fu t etc.. ; n.. g v, .

..1 1, .. :

W.

(

,f ,,qt + g js ..,t ,4 . .t o

'"

g u.u .. < ,> ,, , : 3.s ,,A x. a. e.,u . r s. ,L . ., ~. 'm,c . 2 <.

%,m &w~

.SR 3.l.1.'L S E 14.1,3 Valves that are nonnally closed may be opened on an intemittent A basis under administrettve control. CA Containment W?! K "an. purge isolation valves isolation times will only apply %

he';ti;r M=: the valves are recuired to be OPmmLE and they are geen.)

f rte!-'F p!:mtD- +-***dh

=iU..}.L..!.'.,f ... . .

l."."F2.m. I!!. % ' E M S M M [04 q wL *.1..P".. . . - .

l h CALVERT CLIFFS UNIT 1 3/4622 Amendment No. 212 M

$,, b su a rs.~ s f O'T (v f, pre ( c N't 2.5 + (U py l of G o

l sr . r . . .+ . ., 2. c . 3

'3, g Sftt t0NTAllDENT SYSTEN$

'g. 3 4/4,414 -

CONTAINMENT 150LAtl0NVALVQ l i

LIMITING C0WITION FOR OPERATION .

*3 4,4,4,4 Each containment isolation valve shall be 9PERAttt.' 8 APPLICAIILITY: N00tl 1, 2, 3, and 4.

EI1911: With one or more of the isolation valve (s) inoperable, either 4,1

q. y kurs.or,..e ,oeram ,a - ... -._ m...n

.. A ,, ,yg ,,, c kom 4 A,g 4 c, - N !'position, n 'Na or e$ 'f d lN*"aIN" e k Y L 'NoI!ti i D 5~ D i 8 fcO*"c 7d

% llolate the affected penetration withind ours by use of at - *

.'2)

,least one closed manual valve or blind f'anges or 't Acw es O - --

% A (SWT00WN Within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .e in at least NOT STAND 8Y withi j

. in at the ovirim or apasification 3.0.4 Dre not applicjMe provideQ affectedAetration is ip6ted.f Q

~~~~

- (s N-,. 5o& }o] & &

.8 h

\, $URVE!LLANCE REQUIREMENTS $ ~ ~, )Q,6

\ f4.6.4.1 prior Each containment returnin the val to service after olation valve shall e comonstrated OP BLE O

rep cementworkfsperf ntenance, repair. '

IA c tr01, or power etrc- by perforw.ance et ytl.ing d on the valve or s associated act or, il $

tett _and ariiftationJ l f isolation time. /

--- = -

G , 4 .4 . . , /U Cf. WoTt: cey pg ,.w e g

~ ~ -

4 p , 4 . . .. , re.. p t, .c u q_ 4 c.d. a 4. c ). ie,0 i,9 % --

h '

- <: te r: : o3 yM,s,e.v c 4

= - - -

-qe c.v a

[s .. + _ r i . p. . c. .. . R.

e .. 4 ,,u._

~

C #. 3.1, . 3. Z. \

Valves that are noryally closed may be opened on an intermittent d S R 3J,,J.3 basis under administrative control.

h~tUnment purge isolation valves isolation times will only apply in MODE 6 when the valves are reautred to be OPERAaLE and they are ope

('@tj=_tir= M m ., p,... msa,w L..

, .no . p er i.cnnic. r~ -' n = Q^}t . ((cj;] "". q m..m_

_ _ .. ....n,

'"j 7

y Q v..i m usun remain 6 s v.... -

CALVERTCLIFFS. UNIT 2 3/4 6 18 Amendment No. 189 See J.s.s., aC c% A's g, < y-,c.f,u4.- 3. 3. 7 3

% ( gc, ##

l.hw kQj ny l

DISCUS $10N OF CHANGES SECTION 3.6J o CONTAINMENT ISOLATION VALVES

+

considerations as described in a less restrictive Discussion of Changes) once per 31 days.

His SR ensures that the containment vent valves are closed as required or, if open, open for an allowable reason, ne 31. day Fraguency is consistent with other CIV requirements.

Adding an SR to verify an allowance constitutes a more restrictive change. He addition of thh SR is not adverse to plant safety because it ensures that this CIV la only opened for approved purposes. His change is consistent with NUREO.1432.

TECEINICAL CHANCEg . ns'tITATIONE None TECHNICAL CHANGES . MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED DOCUMENTS LA.I Current Technical Specification SRs 4.6.4.1.2.a and c specifically list the types of test signals (CIS Channel A or B, and Safety injection Actuation Signal Channel A or B) required for testing that the CIVs actuate to their isolation poiltion, improved Technical Specification SR 3.6.3.5 will require that the CIVs be verifled to isolate on an actual or simulated test signal. The test signal will no longer be speciflod in the SR. He test signal will be moved to Section B 3.6.3 of the ITS Bases. His is acceptable because these details do not impact the requirement to verify that the CIVs will isolate when required. Dese details can be edequately 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 ;nore appropriau change control process.

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

LA.2 Not used.

l LA.3 Unit 1 CTS LCO 3.6.l.7 requires the containment purge supply and exhaust isolation valves shall be closed by isolating air to the air operator and maintaining the solenoid air supply valve de-energized and SR 4.6.1,7 requires verification thnt power to the solenoid is removed, nese requirements are being moved to the Basea of Section 3.6.3. His is acceptable because moving these requirements to the Bases will not affect the requirement to maintain the valves closed and how to maintain the valve closed. The valves are required to

- be maintained Operable per Section 3.6.3 be that section does not specifically require them to be maintained closed. The Bases will require the containment parge and isolation valves to be closed in order to be Operable. De SR that requires the valves to be maintained closed will remain in the Technical Specifications; only the requirement on how to maintain the valve closed is being removed, nese requirements can be 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, ne level of safety of facility operation is unaffected by the change because the requirements are still in place to ensure the valves are closed and maintained closed. Furthermore, NRC and Calvert Cliffs Nuclear Power Plant (CCNPP) resources associated with processing license aruendments to these requirements CALVERT CLIFFS - UNITS I & 2 3.6.3 4 Revision 7

DISCUSSION CF CIIANGES SECTION 3.63 - CONTAINMENT ISOLATION VALVES 2

penetration to be verifled closed; however, the ITS will contain a Note which allows valves and blind flanges in high radiation areas to be verified by administrative means, His Note is acceptable since access to these areas is typically restricted for as low as reasonably

achievable radiation exposure reasons. Also, since these areas are restricted, the chances of these isolation devices being misaligned once they have been verified to be in the proper position is small, nis change is consistent with NUREG 1432, 1

L.8 Unit 1 CTS 3.6.1,7 Action a requires the containment purge supply and exhaust isolation valves to be closed within one hour if any of the valves are open. Improved Technical Specification 3.6.3 requires the containment purge supply and exhaust isolation valves to be closed within four hours if any of the valves are open. This change will increase the Completion Time to close the valves from one hour to four hours. This change is acceptable because the chances are remote that the valves will be left in the open position or opened in Modes I through 4. The valves are required to be maintained closed with power to the solenoid valve removed prior to Mode 4 per ITS SR 3.6.3.2 and the associated Bases, ne valves also receive automatic closure signals during accidents (containment isolation, safety irdection, and high radiation signals). Also, this change la specific to Unit I because the Unit 2 containment purge and exhaust isolation valves located outside containment have been replaced with blind flanges for operation in Modes 1 through 4, The Unit I containment purge and exhaust penetrations will also be modified to have blind flanges installed during the 1998 Unit I refueling outage. Therefore, this Action will no longer be applicable after installation of the blind flanges because the containment purge system specification will no longer be applicable in Modes I through 4. Increasing Completion T!mes to perform an Action constitutes a less restrictive change, nis change is consistent with NUREG 1432.

4 L.9 Unit i CTS 3.6.1.7 Action b requires containment purge supply and exhaust isolation valves to be repaired within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when inoperable due to high leakage, improved Technical i

Specification 3.6.3 will require the valve to be maintained closed, in both cases the containment leakage requirements are required to be maintained. The ITS will allow containment purge supply and exhaust valve leakage to exist indefinitely as long as the containment leakage requirements are within limits whereas the CTS requires the valve to be

, repaired within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as long as the containment leakage requirements are within limits.

This change is acceptable, because other Technical Specifications exist that control Containment Leakage, if the containment leakage is not within limits, Actions of the appropriate Technical Specification LCO is required to be entered (LCO 3.6.1 which requires an allowed outage time of one hour before requiring a plant shutdown), llowever, good operating practices and engineering judgment dictate performing repairs to correct leaks before they become excessive, nis change is specific to Unit I because the Unit 2 containment purge and exhaust isolation valves located outside containment have been replaced with blind flanges for operation in Modes I through 4, The Unit I containment I

purge and exhaust penetrations will also be modified to have blind flanges installed during the 1998 Unit I refueling outage, Therefore, these changes will no longer be applicable after installation of the blind flanges because the containment purge system specification will no

. longer be applicable in Modes I through 4. Deleting a requirement to perform Actions within a certain amount of time constitutes a less restrictive change. This change is consistent with NUREG 1432.

L.10 Current Technical Specification SR 4.6.4.Ll requires each containment isolation valve to be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair, 1

CALVERT CLIFFS - UNITS I & 2 3.6.3-7 Revision 7

DISCUSalON OF CHANGES SECTION 3.6.3 - CONTAINMENT ISO'MION VALVES or replacement work is performed on the valve or :ts associated actuator, control, or power circuit. Improved Technical Specification 3.6.3 will not contain this SR. Current Technical Specification 4.6.4.1.1 is being detted. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrate OPERABILITY of the system or component.

ARer restoration of a component that caused a required SR to be failed, ITS SR 3.0.1 requires the appropriate SR (i.e., ITS SR 3.6.3.4) to be performed to demonstrate OPERABILITY of the affected components. Derefore, explicit post maintenance Surveillance Requirements (i.e., CH SR 4.6,4.1.1) are not required and are not included in the Calvert Cliffs ITS.

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

which states:

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

Footnote

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

Intermittently opening CIVs which are isolated in accordance with an action requirement is acceptable due to the low probability of an event that could pre. cire the containment during the short time in which the penetration flow path is oper. and the administrative controls established to ensure the affected penetration can be isolated when a need for containment isolation is indicated.

CALVERT CLIFFS - UNITS 1 & 2 3.6.38 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6. CONTAINMENT SYSTEMS i

2.

Does the change create the possibility of a new or different kind of aceldent from any i previously evaluated?

' The proposed change will increase the allowed outage time to repair a containment purge supply and exhaust isolat!on valve from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to only requiring the valve to be maintained closed, llowever, the containment leakage requirements are still required to be within limits. This change does not involve 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. The proposed change will not intron any new eccident initiators. Therefore, the change does not create the possibility of e new or different kind of accident from any accident previously evaluated.

t

3. Does this change involve a significant reduction in maryln of safety?

j The proposed change will increase the allowed outage time to repair a containment purge supply j and exhaust isolation valve from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to only requiring the valve to be maintained closed.

Ilowever, the containment leakage requirements are still required to be within limits. This will ensure that the initial conditlore of the accident analyses are maintained. if the containment

~

leakage requirements are not within Smits the plant is required to shutdown if the limits are not restored within one hour. Also good operating practice and engineering judgment will ensure 4 -

that excessive leakage from any valve will be repaired as soon as practicable. *lherefore, the proposed changes does not involve a significant reduction in a margin of safety.

M.3 Chamme LIQ

1. Does the change involve a signifleant increase in the probability or consequences of an neeldent previously evaluated?

The requirement to demonstrate each containment isolation valve Operable by performance of a cycling test and verification of isolation time prior to retuming the valve to service after maintenance or repair has been deleted. This proposed change does not result in any hardware or l operating procedure changes. The current requirement to confirm containment isolation valve OPERADlLITY prior to retuming the valve to service after maintenance, repair, or replacement j

work is not assumed in the initiation of any analyzed event. This requirement was specified in the current Technical Specifications to ensure the OPERABILITY of a primary containment isolation valve was positively verified following repair, maintenance, or replacement. The

deletion of this explicit requirement from the Calvert Clift: ITS is considered administrative.

Improved Technical Specification SR 3.0.1 requires the appropriate SR to be performed to demonstrate OPERABILITY after restoration of a component that causes the SR to be failed, in i

this case, ITS SR 3.0.1 would require ITS SR 3.6.3.4 to be performed. This SR ensures the isolation times of the affected primary containment isolation valves are within limits. As a result, the accident consequences are unaffected by this change. Therefore, this change will 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 aceldent from any j aceldent previously evaluated?

The requirement to demonstrate each containment isolation valve Operable by performance of a cycling test and verification of isolation time prior to returning the valve to service after '

maintenance or repair has been deleted. The possibility of a new or different kind of accident CALVERT CLIFFS UNITS I & 2 3.6 14 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS i SECTION 3.6 CONTAINMENT SYSTEMS from any accident previously evaluated is not created because the change does not introduce a new node of plant operation r.ad does not involve physical modification to the plant.

3. Does the change involve a significant reduction in a margin of safety?

He requirement to demonstrate each ccainment isolation valve Operable by performance of a cycling test and verification of isolation time prior to returning the valve to service aner maintenance or repair has been deleted, ne deletion of the explicit requirement to verify primary containment isolation valve OPERADILITY prior to returning the valve to service aner maintenance, repair or replacement work is considered administrative. ITS SR 3.0.1 requires the appropriate SR to be performed to demonstrate OPERABILITY after restoration of a component that causes the SR to be failed. in this case, ITS SR 3.0.1 would require SR 3.6.3.4 to be performed, nis SR requires verification that the isolation times of the affected primary containment isolation valves are within limits. As a result, the existing requirement to verify primary containment isolation valve isolation times are within limits following repair, maintenance, or replacement is maintained. Herefore, this deletion does not involve a significant reduction in a margin of safety.

343. Change L11

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

This change allows a containment penetration flow path that has been isolated in accordance with an Action to be opened under administrative controls. Containment isolation is not considered an initiator of any previously analyzed accident. Therefore, this change does not significantly increase the probability of such accidents. Although containment isolation is considered in the mitigation of the consequences of an accident, the administrative controls provide acceptable compensatory actions to assure the penetration is isolated in the event of an accident. Herefore, the consequences of a previously analyzed event that may occur during the opening of the isolated line are not cignificantly increased.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

This change provides acceptable compensatory actions following failure of other equipment.

The current requirements are based on providing a single active failure proof boundary to compensate for the loss of one of the two active isolating boundaries. This change provides an alternative which meets the original criterin of a single active failure proof boundary and is capable of returning the system to its original configuration (i.e., configuration which can provide a single active failure proof boundary.) Herefore, this change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

3. Does the change involve a significan An in a margin of safety?

The margin of safety considered in determining the required compensatory action is also based on providing the single active failure proof boundary. Opening of containment penetrations on an intennittent basis is required for perfonning surveillances, repairs, routine evolutions, etc.

which mininizes the possibility of a transient due to a required plant shutdown. The administrative controls, consisting of stationing a dedicated operator (who is in continuous communication with the control room), provides a compensatory boundary in this condition.

CALVERT CLIFFS . UNITS 1 & 2 3.6-15 Revision 7

12. 'the NRC requested additionaljustincation regarding a change to CTS Sit 4.6.1.1.a identined in the CTS hiarkups for ITS 3.6.3. To resolve this question the following changes were made:

1)the hiarkups of CTS SR 4.6.1.1.a for ITS 3.6.3 were revised to reference DOC L.4 for ITS 3.6.3 as the just!0 cation for change and to delete the reference to DOC L.3 for ITS 3.6.3:

2) DOC L.4 and its associated NSilC 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 justined; and

3) DOC L.3 and its associated NSilC 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 hiarkups of CTS 4.6 Lt.a and Footnote " of CTS 4A.I.l.a for ITS 3.6.3 did not properly cross reference the ITS requirements. Thus, the hiarkups 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 hiarkup for ITS 3.6 3 was revised to properly cross-reference the CTS requirements.

S pit A M 3.f 3 3/4.6 t0KTAINHENT $YST [

]

3/4.6.1 M INARY CONTAINMENT e g D uc g in J c,,ha y b iMTA!ItitKT INTEGRfTY IP 8E** I'b'l /

'C.J'im M [

LIMIT!NG CONDITION FOR OPERA 110N 3.6.1.1 ' Primary CONTAIMENT INTEGR!fY shall be maintained.' '

S R,14.3. t'l l APPLICABillTY: N0 DES 1. 2. 3 and 4.

I E' AcM ens s Without primary CONTAINMENT INTEGRITY. restore CONTAINNENT 1

A.t 4 M 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SWTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .TY within one h areb

~

3 f.ekJ

$URVE!LLMtt REQUIREMENTS I,'c 8 """ '

l h.6.1.1 Primary CON 1AINNENT INTEGRITY shall be dersonst:sted (ilt16.3.5)

r. .t. % 'At least once pe sys by vertf not canable o that all penDra on ** l A st 3.6.13J eing closed by OPE E containment automatic

/ '

\

isolat'on y ves and required to be closed during accident J:endit' ont te closed by valves, blind "finoe!,ror cesctivated)

{.0 tomatic valves securea in their poth 4 Acept Yor valven 1 are open unaer administrative con s fG 4, ~i n g . es taed b2 -

%d

fb. pfe t requirements of Specification ....

3 613 verifying that tech containment air lock 16 j { ; . c. By a sa j to verify enteri g that the equ pment hatch is closed and segled. rior g g N0DE 4 follow byconducting a Typeng a shutdownggge t atch B test u o nst u..nt..w)g . g,g,a g Y

i j yg,oQi ace ~endsNcYwlf8e bNfaIwd)*AN E' b

h *1'l

g en purge containment vent isolation valves

@liydro!nment conta pressure control, airborne radioactivity & for " "contro{fano a

surveillance testing purposes only j;

et '/ The shutdown cooling isolation valves may be opened W en the RCS 1

temperature is below 300'T to establish shutdown cooling flow Q' M'M t valves. blind flang tactivated auYr ti

/ Re dred Excefocated inside the conhn@ ment are othentite secured in the closed position. These penetrat pn) shall or and l are locked. sea Act r* A.7. be verifted closed during each COLD SH except that such verification need not be performed more o te hen once per 92 days.

CnLYERT Cliff $ - UNIT 1 3/4 6 1 Amendment No. 187

- om - -. . ,

D ea Cad W ad h A g es in C h tg h t.'m atetts

%w

+- ~~

ed.. a w or ,1 4 ,d.a ,~.ns. [,

. . , , ,,, ~ .

0 lM N . Ae4 N44

_ __ _ ~_.____ _ _ _ _ _ - _ . _ , _ _ _ _ _ _._ _ _ _ _ _ . _ _ _ _ _ __. _ ____. _ _

$pacifw.abea 36'3 r/4.6 3

10KTAllettMT SYSTDtl 3/4.6.1 g

PRIMARY CONTAlletENT

& g gf, M g,q,(

C6iffAtlettNT INTittffY " d'**4 # '

LIMITIII6 CONDIT!0N FOR OPttATI0li u

3.6.1.1 a .=::

Primary CONTA!IDitNT INTrett1Y shall be maintained.'

t APfL1tABILIII: N00tl 1. 2. 3 and 4.

M'd 4 f.epleect illthout prleary CONTAllettNT INTEG4 TTY, rettore CONTAlletCNT Ama TV within one hour or be in at least N0" STAllDBY with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD $NiffD%81 within the follow'np 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . in the next A,t. 4 C.I. 5 ~

J n ,,.s Agtw SURVE!LIAllCE REQtl1REMENTS e., ev -- - - -

t 4.6.1.1 S R L bit t.

' Primary CONTAllettMT INTEGRITY shall be demonstrated)J 54MJJ fUE3'Us3 1

$ rgg je gg one, not capabl

- says ing close by OPE ver T that a 1 penetratto

4 4 isolation ves and required to be closed E conta durnment automatic AADittien are closed by valves blind 1 attid

' amatic valves securec ' n the- or deact vated

_are open under adeln'strat< ons rexcept for valves]

Q( 3 ,

opea Twmuen a. tim.m. ve conuroUnrnurmeumr, nostr - - - -

'b.

tBfe requkrements of Specification 3.6.13verif ing that each contelnme

{4

4 j

c. By verif to enter pment hatch is closed and sealed rior g$n gMODE bythat theaeIw 4 foll conducting Type Bng testa shutdownpggjn, katch c._.s ,

.s g h{

" }

<d. wcar A.y L,JM,nQ/.yQ) N b

=

dro en purge containment vent isolationg_bAe,u, LP~:!.4.Ll ""

. L conta nment pressure control valves u = f =9 for l

g tirborne radioactivity _ controi %

4 survet11ance testing purposes, on1Q4 gjg , and W rf el The shutdown cooling isolation valves may be openeMthe RCS temperatu*e is below 300'f to estabitsh shutdown cooling flow, w h M'13 ~

Exce t valves, bitnd flanges ind deactivated autnaatic vaiveowh{ch f.

A Rydeed are ocated inside the conta nment and are heted, sealed or

b. b1 Otherwise secured in the closed osition. These penetrat ons shall be vertfled closed during each C (D $N vertf tcation need not be perfonned more o' except that such ten then once per g2 days, i

% .. M I_RT CLIFFS . UNI _TJ _

3/4 6 1 ndent No.164

~ . -

-gart-~~~~~ s ~~

NVt$,nwd M d MomgfI'IR hIh ntMa,% w was~fu a,usym,c, e --

_ , _ ~ . - - -

'g Llnna ILur )qt, O

DISCUSSION OF CilANGi:S SECTION 3.6.3 . CONTAINMl:NT ISOLATION VALVI:S penetration to be isolated within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the CAV is inoperable in a penetration with a closed system. The penetration is required to be isolated with a closed and deactivated automatic valve, a closed manual valve, or a blind Dange 1hls change will increase the Completlos Time for this Action from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . 'lhis time is reasonable, considering the reliability of the closed system to act as a penetration isolatlon boundary.

'lhe closed system will perform the safety function ofIsolating th penetration until the valve is isolated, increasing the Completion Time to complete the Actions constitutes a less testrictive change. This change is consistent with NUREO.1432, TSTF.30.

L3 Not used.

l L.4 Curren Technical Speclucation 4.6.1,l.a and Footnote " to CTS 4.6.1.1.a require all penetrations required to be closed during accident conditions, which are not capable of being closed by OPERA 11LE containment automatic isolation valves, be verided closed by valves, blind Danges, or deactivated automatic valves. Improved Technical Specification SRs 3.6.3.2 and 3.6.3.3 also require verification that the containment Isolation manual valves and blind Danges that are required to be closed during accident conditions are closed; however, the ITS SRs do not require containment isolation manual valves and blind Danges that are locked, sealed, or otherwise secured to be verified closed. Current Technical Speelfication 4.6.1.1.a and Footnote " to CTS 4.6.1.1.a have been changed to include the exception regarding manual valves and blind Danges that are locked, sealed, or otherwise secured.1hls proposed change is acceptable, because containment isolation manual valves and blind Danges that are locked, scaled, or otherwise secured in position are verified to be isolated prior to locking, scaling, or securing. After locking, sealir.g. or securing, it would take an intentional act to remove the lock, seal, or securing device prior to opening the valve or blind Dange. Administrative controls are provided to assure that manual valves and blind Danges which are locked, sealed, or secured closed are not inadvertently opened.

Additionally, this proposed change is consistent with the requirements of a number of CTS SRs (e.g., 4.5.2.b.1, 4.'/.l.2.a.4, 4 7.3.1.a, 4.7.4.1.a, and 4.7.5.1.a) which do not require the position of valves that are locked, scaled, or otherwise secured in position to be verified.

L.5 Current Technical Specification 3.6.1.1 foctnote ' requires the containment vent to be opened only for containment pressure control, airborne radioactivity control, and Surveillance testing purposes, improved Technical Specification SR 3.6.3.1 requires the verification once per 31 days that the containment vent is closed, except for containment pressure control, airborne radioactivity control, air quality control, and Surveillance testing purposes. This change essentially adds an allowance for the containment vent to be opened for air quality mtrol purpostss. This is recsonable becaut, containmer.t air quality in containment is critical for persor nel entry. Also, the containn' nt vent is capable of closing in the environment following a loss-of coolant accident. Add ,; an additional allowance for the containment vent to be opened constitutes a less restrictive change. This change is consistent with NUREG '432.

L.6 Not used.

l L7 Current Technical Specification SR 4.6.1.1.a requires all penetrations (Inside and outside of containment) not capable of being closed by Operable CIVs, and are required to be closed during accident conditions, to be verified closed, improved Technical Specification SR 3.6.3.2 (outside containttent) and SR 3.6.3.3 (inside containment) will require the CALVERT CLIFFS . UNITS 1 & 2 3.6.36 Revision 7

NO #1GNIFICANT HAEARDS CONSIDERATIONS SECTION 3.6. CONTAINMENT SYSTEMS not signlucantly anected because the check valve with now through the valve secured, along with the one Operable CIV for the penetration, will eNectively isolate the penetration. Dus, the safety function of Iwlating the penetration will be accomplished, nerefore, the proposed change does not involve a signincant reduction in a margin of safety, 1str W sa I, Dow the ebange levolve a algaineast leeresse la the probability or eensequemees of as aceldest previously evelanted?

De propowd change will increase the Completion Time to isolate the penetration with a closed and deactivated automatic valve, a closed manual valve, or a blind Cany for a penetration in a clowd system when the one rguired isolation valve is inoperable, from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

uls chany will not signincant'y increase the probability of an accident previously evaluated, no CIVs are not initletors of any analysed event. His chany will not signlAcantly increase the consequences of an accident becauw of the tellability of the closed system to act as a penetration isolation boundary, nis change will not signincantly anect the anumptions relative to the mitigation of accidents or transients. Derefore, the change does not involve a signincant increau in the probability or consequence of an accident previously evaluated.

2. Does the ebange create the possibility of a new or dlNerent kled of aceldent from any accideat previously evalastedt ne proposed change will increase the Completion Time to isolate the penetration with a closed and deactivated automatic valve, a closed manual valve, or a blind Dange for a penetration in a closed syclem when the one required isolation valve is inoperable, from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

His change does not involve a algnificant change in the 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, nerefore, the change does not create the possibility of a new or dinerent kind of accident from any accident previously evaluated.

3. Does the change involve a algaincent redaction in a maryla of safety?

ne proposed change will increase the Completion Time to isolate the penetration with a closed and deactivated automatic valve, a closed manual valve, or a blind Hange for a penetration in a closed system when the one required isolation valve is inoperable, from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , ne margin of safety is not significantly affected because the closed system is enective as a penetration isolation barrier. De stability of the closed system, and hence its reliability, contntiute to it being an efficient isolation barrier. Herefore, the propowd change does not involve a significant reduction in a margin of safety.

3_L3Ch===e L3 Not used.

l 311ck-==.L4

1. Does the change lavolve a algelneset lacrease la the probability or consequences of an accident previously evalanted?

He proposed change will add an allowance that containment isolation manual valves and blind flanges that are locked, scaled, or otherwise secured in position do not have to be verified closed.

CALVERT CLIFFS UNITS I & 2 3.6 10 Revision 7

NO SIGNIFICANT liAZARI)S CONSIDERATIONS Sr.cTION 3.6. CONTAINMENT SYSTEMS l i

nis change will not signincantly increase the probability of an accident previously evaluated, ne CIVs are not initiators of any analyzed event. His change will not significantly increase the consequences of an accident. plant administrative controls are in place to provide assurance that the valves and blind Danges that are verilled locked, scaled, or otherwise secured in position will 3

not be inadveriently opened. Hus, the likelihood of a valve or blind Dange that was previously '

verined to be locked, scaled, or otherwise secured in the closed position being inadvertently opened is small. %1: change will not significantly affect the assumptions relative to the mitigation of accidents et translents. Derefore, the change does not involve a signlucant increase in the probability or consequence of an accident previously evaluated.

2.

Does the change create the possibility of a new or different kled of accident from any accident previously evaluated?

The proposed change will add an allowance that containment isolation manual valves and blind Danges that are locked, scaled, or otherwl.e secured in position do not have to be verified closed.

This change does not involve a signincant 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 new accident initiators. Herefore, the change does not crea;c the posalblilty of a new or different kind of accident from any accident previously evaluated.

3. Does the change involve a significant reduction la a margin of safety?

He proposed change will add an allowance that containment isolation manual valves and blind Danges that are locked, scaled, or otherwise secured in position do not have to be verified closed, ne margin of safety is not signincantly affected because plant administrative controls provide assurance that these valves and blind Hanges will not be Inadvertently opened, ne administrative controls provide reasonable assurance that the valves and blind Danges will not be inadvertently opened. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Auchance Ls

1. Does the change lh.olve a significant increase in the probability or consequences of an accident previously evaluated?

%e proposed change will allow the containment vent to be opened for air quality considerations.

His change will not significantly increase the probability of an accident previously evaluated, ne containment vents are not initiators of any analyzed event. This change will not signifirantly increase the consequences of an accident. Opening the containment vent for air quality control considerations is acceptable because the containment vent is capable of closing in the environment during a loss of-coolant accident (LOCA). This change will not significantly effect the assumptions relative to the mitigat!on of accidents or transients. Therrfore, the change does not involve a signlHeant 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 evaluated?

The proposed change will allow the containment vent to be opened for air quality considerations.

His change does not involve 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. R proposeo change will CALVERT' CLIFFS - UNiu 1 & 2 3.6 11 Revision 7

(cu) containment Isolation Valves (AtwPMc ;g ;;,W

>55 h A

ACil0N$

CON 0lT10N REQUIRED AC110N COMPLETION T!NC A. (continued) A! - - -

- NOTE---

!selation devices in ht9h radiation areas may be vertfled by use of administrative means.

(q4't, t,h Verify the affacted once per 31 days penetration flow path A forisolation g V6. lil. A is isolated. devices outside

%6,e se V$ containment ABQ Prior to enterino N00( 4 from Mobt 5 if not performed within the previous 92 days for isolation dcvices inside '

containment

g. .........N01E----.---- B.! Iso) ate the affected I hour only applicable to penetration flow path penetration flow paths by use of at least with two containment one closed and isointion valve M de-activated automatic valve @ uh

- *A 26+l One or more fM* closed manual va,lve,

.or blind flange.

AA..sa4( penetration flow paths with two containrent k

isolationvalves inoperableJIexcep olr reury alve lea e f a Ield bu ing b ss leaky Ans

%yhin limit' .f 1

(continued)

Cf0C 515 3.6-9 Rev 1, 04/07/95 J

t

j \ Containment Iselation Valves 4A4--- "-" ^" ^d) 3.6.3 @

Q TS }

ACTION $ (continued) [h CONDIT10N REQUIRt0 ACTION COMPLETION TINE C. ---NOTE------ C.1 Isolate the affected < hows 1 able to notration flow path wr. p

! pen ow paths y use of at least or soort, withW conta-on t isolation one closed and de-activated i h valv@and a closed automatic valve system.

.. ....... . ~. closed manual valve.

.or)bilnd f1ange. A M'

s.c. 4.1 One or more penetration flow paths E

Aen.4 Aid with one containment C.2 ..~..-NO T [------

1solatto valv Q Isolation devices in '

inoptrable high radiation areas may be vertfled by (h) or we use of administrative V means. j Verify the affected Once per 31 days (u.i.i.n) t;ati,t!!a;."**

, h &

5secondarkontainment 0.1 Restor g skage 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months b ast leakage not with m Itatt, hin limit. ',/ h

~ - ~_~

[. One or mort E.1 Isolate the affected penetration flow aths ' 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months penetration flow pa with one or mor by use of at lets containment pu e one valves not wl n deac(closedand tivated purge valve eskage

{

limits, automatte va e with restilent s is closed ma al valve h

with res tent seals,

( or bli flange).

\ " )

(continued)

. CEOG STS 3.6 10 Rev1.04/07/95

4 l-l Containment Isolation Valves d e " <c~and 19n113 i.e.U

$URVEILLAleCE RE0llIREMDifs .

$URVilLLANCE FREQUDICY bh3.6.3.1 Verifyeach[42)inchpure alve is 31 days asaled cleaed except for purge valve in a penetration flow pet ile in 6

( - Condition t of this .

$4 3.6.3 Verif each h Y excepfwhenLhe alueisclo2\-31 days y valves an _

.t. L,ld V open fo* p mssure contre , IA er air Weaa4- '

1(. 3 poc. A4.t.- quality considerations for personnel entry, or for $deveillances that require the valves to be open.

$R 3.6.3 - .----- .-----.--- 64T C.----

(A/,0,l.l.b

.41ves and blind flanges in high radiation a nos may be verified by use of h

/ ada

....'ntstrative

........ .means.

.......................... A Verify each containment isolatten manual g

31 days valve and bilnd dange th.t is located outside containmentjand is required to be M es cur my ac6icent conditions is

/c,*ios d. except for containment isolation ,TM/* 6

( t o 3.4 /5 vahes that are open ender adelnistrative ra in 4 p controls. A Q

(centinued)

A N N l*ck*d, Jeolo},,,.

6/Suusst . secured

_% %M

]

CEOG STS 3.6-12 Rev 1. 04/07/95 I

)

O Containment Iseletion Valves ?" ::f:t .4 ;;..W 3.6.I h

, $URVtlLLANCE REQUIREMENTS (continued)

$URVE!LLANCE FR[QU(NCY

%.tl. A \

SR 3.6.3 -

- --NOTE Valves and blind flanges in high radiation b

F..h.te *A/ areas may be verified b i administrative means. y use of x

[4.I.. l. l.

g I pg 4. l,4,p' Verify each containment isolation annual Prior to

/, 888/*

valve and blind flange that is located i in i g$ y 6' M*" ci. se.side..n.

contain as % dont conditions is6nd required closed exce,pt for containment isolation enterbM00C4 free not erfor.ed with,in the 5toifbe rsrr-e

'j

/ Leo J.4. 3 \ valves,that are open under administrative previous A 1

\P,..h.4e 4/ controls. 92 days /U 5

SP 3.6.3 7 C4 Verify the isolation time ofGai5Laavat> In h

] 4.lo.4,/,3\ each automatic ontainment accordance p 9 Ts ff** 4 /*

. / so at on valve is within mits. ",with the ~

l

! Inservice s

. ,s,, ,, .. . /, Testing

_ CD J

SR 3.6.3. Perform leakage rate tes ng for 184 days containment purge valve with resilient seals. AND With 92 days @

4 af r opening t valve SR 3.6.3 Verify each automatic containment isolation months valve that is not locked, sealed, or

,gA,j,g,g otherwise secured in position, actuates to the isolation position on an actual or s

simulated actuation signal.

(continued)

CEOG STS 3.6-13 Rev 1. 04/07/95 f

d

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

13 llie NRC requested that the deviations proposed by CEOG il2 (TSTI'.196) be withdrawn from the Calvert Cliffs' submittal. The deviations proposed by CEOO ll2 were withdrawn from the submittal as requested. The following changes were required: 1) the Markups for Action e 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 L6 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 llases were revised. (Comment 3.6.3 6) j-J 4

I A - -

, - - - - - m -- p--, , , , -r -w.v - w ~ --

r-- ---- -m--- ---- ~

Containment Isolation Valves i

3.6.3 ACTIONS (continued)

CONDITION Rt. QUIRED ACTION COMPLETION TIME l A. - - - - - - - - NOT E - - -- - - - . A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Only applicable to penetration flow path penetration flow by use of at least paths with two one closed and containment isolation de-activated valves and not a automatic valve, closed syt. tem. closed manual valve. I

..................... blind flange, or 7 check valve with flow One or more through the valve penetration flow secured. '

paths with one containment isolation _ 6!iQ valve inoperable.

A.2 -.----.-NOTE -----.-

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path for isolation is isolated, devices outside containment A!iD Prior to entering MODE 4 from MODE 1 if not performed within the previous 92 days for isolation devices inside containment CALVERT CLIFFS - UNITS 1 & 2 3.6.3-2 Revision p'7 m

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIREDACTION COMPLETION TIME B. ..-.... NOTE........ B.1 Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Only applicable to penetration flow path penetration flow by use of at least-paths with two one closed and containment isolation de. activated l valves and not a automatic valve, closed system, closed manual valve.

..................... or blind flange. 7 One or more penetration flow paths with two containment isolation I valves inoperable.

CALVERT CLIFFS . UNITS 1 & 2 3.6.3-3 Revision g 7

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIML C. ----.--. NOTE.------- C.1 Isolate the affected 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Only applicable to penetration flow path penetration flow by use of at least paths with one or one closed and more containment de. activated isolation valves and automatic valve, a closed system. closed manual valve,

..................... or blind f1ange. 7 One or more AND penetration flow paths with one or C.2 -------. NOTE -------

more containment Isolation devices in isolation valves high radiation areas inoperable, may oe verified by ust. of administrative means.

Verify the affected penetration flow path Once per 31 days is isolated.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months CALVERT CLIFFS - UNITS 1 & 2 3.6.3-4 Revision /~7

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 4 inch antainment vent valve is 31 days closed except when the 4 ine:h containment vent valves are o,;3n for pressure control.

ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.2 - -------- -.----kOTE----.--- ---------.

Valves and blind flanges in high radiation ~l areas may be verified by use of administrative means.

Verify each containment isolation manual 31 days valve and blind flange that is located 7 outside containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

CALVERT CLIFFS - L' NITS 1 & 2 3.6.3-5 Revisionp'y

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.3 -..-..........-....N0TE......-..--..-+...- <

7 Valves and blind flanges in high radiation areas may be verified by use of administrative means.

Verify each containment isolation manual Prior to valve and blind flange that is located entering MODE 4 7 inside containment and not locked, sealed, from MODE 5 if l or otherwise secured and required to be not performed closed during a:cident conditions is closed, within the except for containment isolation valves that previous I are open under administrative controls. 92 days SR 3.6.3.4 Verify the isolation time of each automatic In accordance power operated containment isolation valve with the is within limits. Inservice Testing Program SR 3.6.3.5 Verify each a *.orntic containment isolation 24 months valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

CALVERT CLIFFS . UNITS 1 & 2 3.6.3 6 Revision 77

Containment Isolation Valves B 3.6.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment Isolation Valves BASES BACKGROUND The containment isolation valves form part of the containment pressure boundary and provide a means for f u d

penetrations not serving accident consequence limiting i systems to be provided with two isolation barriers that are i

closed on an automatic isolation signal. These isolation devices are either passive or active (automatic). Manual i

valves, de activated automatic valves secured in their closed position (including check valves with flow through the valve secured), blind flanges, and closed systems are l7 4

considered passive devices. Check valves, or other automatic valves designed to close without operator action following an accident, are considered active devices. Two i

barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of. isolation or leakage that

, exceeds limits assumed in the safety analysis. One of these

] barriers may be a closed system.

3 A blind flange is installed and sealed on the Containment 1 Purge and Exhaust System in Modes 1, 2, 3, and 4 on Unit 2.

, Similar equipment will be uscJ on Unit 1 after a modification is installed. Until the modification to Unit 1 g is completed, the Containment Purge and Exhaust Isolation

Valves will be required for Containment Penetration Operability. Containment Purge and Exhaust Isolation Valves are not required for Containment Penetration Operability when the blind flanges are installed, j Containment isolation occurs upon receipt of a high containment pressure signal. The containment isolation signal (CIS) closes automatic containment isolation valves in fluid penetrations not required for operation of Engineered Safety Feature systems in order to prevent leakage of radioactive material. Upon actuation of safety CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-1 Revision p' ?

Containment Isolation Yalves B 3.6.3 BASES 4

injection, automatic containment isolation va'.ves also isolate systems not required for containment or Reactor CoolantSystem(RCS)heatremoval. Other penetrations are isolated by the use of valves in the closed position or blind flanges. As t. result, the containment isolation 7 4

valves (and blind flanges) help ensure that the containment atmosphere will be isolated in the event of a release of radioactive material to containment atmosphere from the RCS followingaDesignBasisAccident(DBA).

The OPERABILITY requirements for containment isolation valves help ensure that containment is isolated within the time limits assumed in the safety analysis. Therefore, the OPERABILITY requirements provide assurance that the containment function assumeri in the accident analysis will be maintained.

. 7

( APPLICABLE The containment isolation valve LC0 was derived from the SAFETY ANALYSES assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary i during major accidents. As part of the containment boundary, containment isolation valve OPERABILITY supports leak tightness of the containment. Thereiore, the safety rnalysis of any event requiring isolation of containment is applicable to this LCO.

The DBAs that result in a release of radioactive material

within containment are a loss of coolant accident (LOCA), a i main steam line break, and a control element assembly ejection accident. In the analysis for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through containment

. 1 solation valves (including containment purge valves) are minimized. The safety analysis assumes that the purge

, valves are closed at event initiation.

CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-2 Revision 6 7

Y Containment Isolation Valves B 3.6.3 BASES The DBA analysis assumes that, within 60 seconds after the accident, isolation of the containment is complete and 1eakage terminated except for the design leakage rate, La.

The containment isolation total response time of 60 seconds includes signal delay, diesel generator startup (for loss of

offsite power), and containment isolation valve stroke times.

I The containment isolation valves satisfy 10 CFR 50.36(c)(2)(ii), Criterion 3.

i l LCO Containment isolation valves form a part of the containment boundary. The containment isolation valve safety function is related to minimizing the loss of reactor coolant

inventory and establishing the containment boundary during a

, DBA.

The automatic power operated isolation valves are required to have isolation times within limits and to actuate on an automatic isolation signal. The valves covered by this LCO are listed with their associated stroke times in the Updated Final Safety Analysis Report (UFSAR) (Ref. 1).

. The normally closed isolation valves are considered OPERABLE when manual valves are closed. automatic valves are i de-activated and secured in their closed position, blind 7 4

flanges are in place, and closed systems are intact.

Containment purge supply and exhaust isolation valves being l

credited for Containment Penetration Operability shall be closed. They shall be maintained closed by isolating air to I

the air-operator and maintaining the solenoid air supply valve de-energized. These passive isolation valves or devices are those listed in Reference 1.

This LC0 provides assurance that the containment isolation

, valves will perform their designed safety functions to CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-3 Revisiong7

Containment Isolation Valves B 3.6.3 BASES The fourth Note allows the shutdown cooling (SDC). isolation 7 valves to be opened when RCS temperature is < 300*F to establish SDC flow. This Note is required for Operation in MODE 4 to allow SDC to be established.

A.1'and A.2 In the event one containment isolation valve in one or more-penetration flow paths is inoperable, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet thit; criterion are a closed and de-activated-autoinatic containment isolation valve, a closed manual valve, a blind flante, and a check valve with flow through the valve secured. For penetrations 7

isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be i completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1 Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of -

supporting containment OPERABILITY during MODES 1, 2, 3, and 4.

For affected penetration flow paths that cannot be restored 4 to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time and that have been isolated in accordance with Required Action A.1, the affected penetration flew paths must be verified to be isolated on a periodic basis. This is' necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of_being automatically isolated will be in the isolation position s h ld an event occur. This Required Action does not require any testing or device manipulation. Rather. - i t involves verification, through a system walkdown, that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-5 Revision p 7

Containment Isolation Valves B 3.6.3 BASES Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the i probability of their misalignment is low. For the isolation devices inside containment, the time period specified as

" prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is based on engineering

judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation

, device misalignment is an unlikely possibility.

Condition A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two containment isolation valves and not a closed

, system. For penetration flow paths with one or more i

containment isolation valves and a closed system, I Condition C provides appropriate actions.

Required Action A.2 is modified by a Note that applies to isolation devices located in high radiation areas and allows 4

these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these devices, once they have been verified to be in the proper position, is small.

I B.1 4

With two containment isolation valves in one or more penetration flow paths inoperable, the affected penetration

, flow path must be isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a

, closed and de-activated automatic valve, a closed . n.tal

valve, and a blind flange. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is 7

d CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-6 Revision p 7

Containment Isolation Valves B 3.6.3 BASES consistent with the ACTIONS of LCO 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative controls and the probability of their misalignment is low. I Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two containment isolation valves. Condition A of this LC0 addresses the condition of one containment isolation valve inoperable in this type of penetration flow path.

, f.1 and C.2 With one or more penetration flow paths with one or more containment isolation valves inoperable, the inoperable valves must be restored to OPERABLE status or the affected penetration flow patn must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. A check valve may not be used to 7 itolate the affected penetration. Required Action C.1 must be completed within the 72 hou- Completion Time. The specified time period is reasonable, considering the relativestabilityoftheclosedsystem(hence, reliability) to act as a penetration isolation boundary and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, ar.d 4. In the event the affected penetration is isolated in accordance with Required Action C.1, the CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-7 Revisiong7

Containment Isolation Valves !

B 3.6.3 i i i

! BASES

SR 3.6.3.2 This SR requires verification that each containment y j isolation manual valve and blind flange located outside '

l containment and not locked, sealed, or otherwise secured and- -

required to be closed during accident conditions is closed.

l The Containment Purge and. Exhaust Isolation Valves required j for Containment Penetration Operability shall be determined j

closed by verifying that power-to the solenoid valve is

removed. The SR helps to ensure that' post accident leakage i of radioactive fluids or gases outside the containment j boundary is within design limits. -This SR does not require

any testing or valve manipulation.- Rather, it involves o verification, through a.systan walkdown, that those -

containment isolation valves outside containment and capable >

l of being mispositioned are in the correct position. Since

[ verification of valve position for containment isolation

valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to

- provide added assurance of the correct positions.

! Conhinment isolation valves that are open under

!- administrative controls are not required to meet the SR

} during the time the valves are cpen. This SR does not apply -

to valves that-are locked, sealed, or otherwise secured in 7

l. the closed position, since these were verified to be in the

)- correct position upon locking, sealing, or securing.

The Note applies to valves and blind flanges located in high 7-

! radiation areas and allows these devices to be verified i- closed by use-of administrative means. Allowing

[ verification by administrative means is considered

- acceptable, since access to these areas is typically

[

restricted during MODES 1, 2, 3, 4 and for ALARA reasons.

Therefore.-the probability of misalignment of these containment isolation valves, once they have been verified

[ ' to be in the proper position, is small.

t i-t CALVERT_ CLIFFS - UNITS'1 & 2 B 3.6.3-10 Revision F 7 t

,e y 4 -

t- +-g, - -

- , , , - , , - - - - - - -w-,--- , , - , ~

Containment Isolation Valves B 3.6.3 BASES I SR 3.6.3.3 i This SR requires verification that each containment isolation manual valve and blind flange located inside 7 containment and not locked, sealed, or otherwise secured and

, required to be closed during accident conditions is closed.

The SR helps to ensure that post accident leakage of i

radioactive fluids or gases outside the conthinment boundary is within design limits. For containment isoktion valves inside containment, the Frequency of " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate, since these containment isolation valves are operated under administrative controls and the

, probability of their misalignment is low. Containment isolation valves that are open under administrative controls are not required to meet the SR during the time that they are open. This SR does not apply to valves that are locked, sealed, or othenfise secured in the closed position, since 7 these were verified to be in the correct position upon locking, sealing, or securing.

7 The Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.

SR 3.6.3.4 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-11 Revision 0 4

Se cS uk 3 f ,'t

3. L 4/4.4 CONTAtle4ENT SYsTots t c,,3 -3/4.6.4 CONTAllelENT ISOLAT10N VALVES LIMITIll8 COMITION FOR OPERATION t Co 34 3 _^1 Each containment isolation valve shall be OPERABLE.* '

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

AGIIB: With one or more of the isolation valve (s) inoperable, either O ne sne n:;:rpw valvetsJ W..-M?N statui,arrsnr.[7

" "y.y A., Isolate each aff ed petietrWTon within n.a.wynadu + s.3~

hours by use of at f ,..,_~s3 A k..Q Aev.ar least one des voted automatic valve sec in the isolation 7gg position, or g e,, w,,a ~

L -

c, Isolate the affected penetration within hours by use of at MerT'T ..

least one closed manual valve or blind f enge; or

[

to

'gMj '

g l Actsw b f8e in at least NOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in (SitUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

COLD

e. ';ne provisions of4pecification 3. ./ b' N \

hat the affectat penetration i are not applicablegfovide 4* g '

olated.

A i ~ ~ ~ ~ ~ ~ ~

I A

SURVEILLANCE REQUIREMENTS 4.6.4.y1 prior 'o returnin the valve Each containment iso tion valve shall be demonstrated UPERAB '

service after maintenanc repair. or rep cement work s perfo on the valve or its asso ted actuator.

c be -

rol, or power isolation timeJcircuit y performance of a ca c11ng est and verif atton) l

.<- v n , ,-.

C..keb.sfugo.,,; 4. g ..u,>.g,4,.: ..-.( - w e w '

i

jy1 & aw ,,g ,,4 . .to w.e.w.w~ e

, .,,r.. a. +h e..u... ,'p

~v, -,

- .~. cwc .a c.

SR 3,0,3 'l

S P.14.3,3 Valves that are. normally closed may be opened on an intermittent basis under administrative control. A

- . En c Containment purge isolation valves isolation times will only apply 1

-hK: h9:n.thetier, 0 valves 5 :: '^rare recuired to be OPraanLE and they are open, cr-Mi--"' a"7= i::ht':- 9= h n 'a-

=;^ 1. 2. 5 ano 4 per lecnnu..i 5pu;ik.u;.. /; ' '. ', er%;;

dhh ti;; th=-n',;; ;..t s; ' ;h::f _ g,4 li CALVERT Ct.!FFS - tmli 1 3/4 6 22 Amendment No. 212 M e ,, b s u m w sI

,7, \ /f

& $ f,pr - (, c a -% b e5 * (kb p47l46 i

S e Zake. % .3 4

/4.6 iPNTAI M ENT SYST

]

3/4.6.1 PAINARY CONTAI MENT -

gMcoag 86ery A I i

CONTA! MENT INTEGRITY SP ' # ' '

/ .

c h *m W f LIMITING CONDITION FOR OPERATION 3.6.1.1 ' Primary CONTA!WENT INTEGRITY shall be maintained.' '

S R.M.3. 2, l APPLICABILITY: N0 DES 1, 2, 3 and 4.

A W"'

. Ac w s Without primary CONTA!WENT INTEGRITY. restore CONTA!WENT A.t. 4 l'.2 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SNUTDONN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .TY within on i _

ysub M 0 *r* a d /.e k J SURVEILLANCE REQUIREMENTS "

Nc t 4.6.1.1 Primary CONTA!WENT INTEGRITY shall be demonstrated i @lL34.3.M

<..t.t? % "At least once pe g sg 3,t, ,3,$ ys by verifying that all penetration not ca able o ing closed l 1

isolat on y ves and requi OPERABLE conttinment automatic 2

[ b _ condition re closed by valves.

to be closed during accident blind linnyeor ceacuvated) j

g.

Lautomatic valves securea in their posh ons/except Tor valvfD

$} .

gopen uncer - o y. administrative conurpoermu wd og

4. d g f' o. sfe t requirements of Specification 3.6.1.3. verifying that each constinment air iocK

+

3 c. By verifying that the e j m{ j; to entering MODE 4 foll ng poent hatch is closed and sepled, rior a shutdown whe ened by conducting a Type B test t atch umst

$h r.... - . -

m. .. . .. .a g

. g,,u .t 2.19 l 1 g d TM.wr-A ' ace, dance ~willlJa Cait.,t ~J laakao* Rak %n by ~-

N '1 L

Hyd 3 & >.

, en purge containment vent isolation valvesNb for

' hconhnment pressure control, airborne radioactivity controffana surveillance testing purposes only j

prre ej ~

4 The shutdown cooling isolation valves may be opeed Men the RCS d temperature is below 300'F to establish shutdown cooling flow,d 1

P 13

1. 34 de.ptred Exce t valves, blind flanges. land deactivated au' are ocated inside the containment and are locked, se9 or which l othentise secured in the closed position. These penetratIpns shall Aiur. A.1 be verified closed during each Cola $N verification need not be performed more t except that such per 92 days.

CALVERT CLIFFS - UNIT 1 3/4 6 1 Amendment No. 187

- n- -.

WWes ad W4 flages in ldd trdkh creca m ~

c.a %- ~

c .t o s ,a.a ,~.e. g, t

'$ WYs % .Wa A

I c; p c . m.+ >., 7. 6. 3 3,g -$ft'.t $0NTAINMENT SYSTEMS

'g. 6. '3 3/4d*- CONTAINMENT ISOLATION VALVES LIMITING CONDITION FOR OPERATION .

" 3*3 4,4,44 Each cor.tainment isolation valve shall be OPEfABLE.*

APPLICABILITY: MODE $ 1, 2, 3. and 4.

EllM With one or more of the isolation valve (s) inoperable, either:

/ .f sacre une poperable volum to er>--mtatun within/3 hours, qmr- vi.%

Q,f sw7 4__

-~ ~

M 'OM %f_isolateeachaffectedpene atton within@ttpuYebuse Ct tic valve secureQt isolation @~*-b 1 east one deactivate w"'

A .g 4 c -

position, or d

2pa+ic

ws

% !solate the affected penetration within urs by use of at

= .2 x'

least one closed manual valve or blind ange: or NW *n) A

, [ Acwy % [Be in at least NOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD'd En C.

O - -

d5HUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . -

4. In rov 1TTons of sp fication 3.0.4 not applic)Wie provi@

the affected tration is is .f bQ

. ' & -~ ___ _ _ - . - L,1I 4Nstm Acriou* yo,g.3 @ ,g A

-- ~_-

g .8 $

~ N.

\ SURVEILLANCE REQUIREMENTS 3

\ f4.6.4.1

{prio Each containment olation valve shall e demonstrated OP BLE' '

returning the val to service after m ntenance, repair. 1

.A rep)J: 1cement or power is perf d on the valve or s associated act or, workcirc' l iI $

ii.

by performance of cytling. test _ erificationd l

_isniation time. y

~ _-- -- = _

6, o. 4.o., h_ E WoTC : c ay opp ,.w e 4 . p , . 4 . . .. ., fi .. g t, , s e

Q c.i v's a Q y clue.Q s.pty Q,. -*y 4 uot n : o , ,.p p . , . y e p 7.,, r . . %

g r i . p . t.. - e. t.

- m c~

~ o .. . .

C R 3.I, . 3. Z. Valves that are nonna11y closed may be opened on an intermittent 3

- ( s p, 3,g,, ,3,3 basis under administrative control.

TITnment purge isolation valves isolation times will only apply Tn MODE 6 when the valves are required to be OPERABLE and they are open y ;tj: l 8j p.jsnoe,persecnnicaiavuu...jett=1;r;;..^..Pr'?":jp*jz:ge{.g]fg

- . . m ing 7o. .. . .. muas vaives must remain ci m o. _

g i

CALVERTCLIFFS-UNIT 2 3/4 6-18 Amendment No. 189 See .l . m s . ., d c% m * >

{. ,, , $ p , ,. . fm , 4..- 3. '5.

s(y or Liemu. G.JJ ;9y n hh

$p.c,M- h 3

(

3/4.6 10NTAl m tNr SYST $

3/4.6.1 g,, h,g,,,% of &,

PRIMA'RY CONTAINMENT A $+ec4e,M e 1.4.h CONTAI M ENT INTtttITY d ,

LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAIMENT INTEGRITY shall be s intained.'

APPLICABILITY: N00ES 2, 2. 3 and 4.

t N 3' L :

d tepleec) NT Without primary CONTA!WENT INTEGRI1Y. restore CONTAINMENT Aga RITY within one hour or be in at least NOT STANDBY with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD $NUTDOW within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . in the next Ar 4 C 7. '

aa '

Regarsb s.Areeeed- /..hel Ag a..a. LA ;

$URYEILLANCE REQUIREMENTS tweed .

= - - ~

i J.6.1.1 Primary CONIAImtNT INTEGRITY shall be demonstratej SR f C 3 3 i

il 34.3.L -

g rat least once p sys by vertrying that all penetration

N 34'3'3 3 not capable isolation eing closed by 0PERABLE containment autocratic 4

gnadition ves and required to be closed durino accident n the'are closed by ,valves blind "lanoeg or deactivated)

' tautomatic valves secured '

Ghat are open under admin'strat< ve controllaryswonewnr onsJexcept for valves) oosit' *

(* =

GPecif watirn 3.6M.L

'b.

,. B tfeverifying requirements that eachofcontainment Specification air lock 3.6.1.3. is in compliance w1

h t 8

c. By verifying that the e j to entering MODE 4 foll ng a shutdown rior c o{ gam j e by conducting a Type B test g_. ygdpment hatc rr---.' -

.. g

. ._w l 4

e aceaealas,ca vid $e Corsfah.** erst

<d, wcw A. ( _

~ -

m _e hitA.TEsfly ra

{ h,a, a

\ S h j

g ~-- -

=w SA h .'1.l UZ.0 tet3e dro en purge containment vent isolation valves L:'WT for' C# m$

conta nment pressure control, airborne radioactivity contro{, and % (#

n*re 4 4 survetilance testing purposes onlygggg jg The shutdown cooling isolation valves may be openeMthe RCS .,;

temperature is below 300*F to establish shutdown cooling flow. u.A hd b%38 Jeed

~

Except valves, blind flanges, gind deactivated automatic valve 0which l

i t-M," O otherwise secured in the closed position.are located inside the containment an be verified closed during each COLD SH These penetrations shall verification need not be performed more o' except that such ten then once per 92 days. t i CALVERT CLIFFS _ UNIT 2_ 3/4 6-1 ndment No. 164

~~ -NarE

~~_ $s - ~ -

Whe s,ad ha -bges 'mhi@ raSat.'on s \

w ers <

~ m p urha q a ,e awd1<+~

<~ s t.

h L,%a Asa Rh b

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

1 DISCUSSION OF CIIANGES -

SECTION 3;6.3 - CONTAINMENT ISOLATION VALVES j

penetration to be isolated within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the CIV is inoperable in a penetration with a closed system, he penetration is required to be isolated with a closed and deactivated

- - automatic valve, a closed manual valve, or a blind flange. His change _ will increase the

,. Completion Time for this Action from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . .nis time is reasonable,-

t considering the reliability of the closed system to act as a penetration isolation boundary.

The closed system will perform the safety function ofisolating the penetration until the valve is isolated. Increasing the Completion Time to complete the Actions constitutes a less restrictive change. His change is consistent with NUREG-1432, TSTF 30.

LJ Not used.

l

! Li Current Technical Specification 4.6.1.1.a and Footnote ". to CTS 4.6.1.1.a require all s I

penetrations required to be closed during accident conditions, which are not capable of being i closed by OPERABLE containment automatic isolation valves, be verified closed by valves, blind flanges, or deactivated automatic valves. Improved Technical Specification SRs

[ 3.63.2 and 3.633 also require verification that the containment isolation manual valves and j blind flanges that are required to be closed during accident conditions are closed; however,

the ITS SRs do not require containment isolation manual valves and blind flanges that are

! locked, scaled, or otherwise secured to be verified closed. Current Technical

) Specification 4.6.1.1.a and Footnote " to CTS 4.6.1.1.a have been changed to include the j' exception regarding manual valves and blind flanges that are locked, sealed, or otherwise

, secured. This proposed change is acceptable, because containment isolation manual valves i

and blind flanges that are locked, sealed, or otherwise secured in position are verified to be

, isolated prior to locking, sealing, or securing. After locking, sealing, or securing, it would take an intentional act to remove the lock, seal, or securing device prior to opening the valve i or blind fiange. Administrative controls are provided to assure that manual valves and blind '

. flanges which are locked, sealed, or secured closed are not inadvertently opened.

! Additionally, this proposed change is consistent with the requirements of a number of CTS

} SRs (e.g., 4.5.2.b.1, 4.7.1.2.a.4, 4.73.1.a, 4.7,4.1.a, and 4.7.5.1.a) whkh do not require the

position of valves that are locked, sealed, or otherwise secured in position to be verified.

l

{ L5 Current Technical Specification 3.6.1.1 footnote

requires the containment vent to be 7

opened only for containment pressure control, airborne radioactivity control, and Surveillance testing purposes, improved Technical Specification SR 3.63.1 requires the j verification once per 31 days that the containment vent is closed, except for containment pressure control, airbome radioactivity control, air quality control, and Surveillance testing j purposes. This change essentially adds an allowance for the containment vent to be opened for air quality control purpeses. His is reasonable ~ because containment air quality in l containment is critical for personnel entry. Also, the containment vent is capable of closing i

in the environment following a loss-of-coolant accidert. Adding an additional allowance for the containment vent to be opened constitutes a less restrictive change. This change is L consistent with NUREG-1432.

L.6 Not used. l

'[ L.7 Current Technical Specification SR 4.6.1.1.a requires all penetrations (inside and outside of containment) not capable of being closed by Operable CIVs, and are required to be closed during accident conditions, to be verified closed. Improved Technical Specification l- SR 3.63.2 (outside containment) and SR 3.633 (inside containment) will require the CALVERT CLIFFS - UNITS 1 & 2 3.6J-6 Revision 7

,,-, 3.-,.w , -4 . . . - . . - , _

.,.c_ . , , .. . ,,- - - - - , , -

DISCUSSION OF CHANGES SECTION 3.6.3 - CONTAINMENT ISOLATION VALVES penetration to be verified closed; however, the ITS will contain a No'e which allows valves and blind flanges in high radiation areas to be verified by administrative means. This Note is acceptable since access to these areas is typically restri:ted for as low as reasonably achievable radiation exposure reasons. Also, since these areas are restricted, the chances of these isolation devices being misaligned once they have been verified to be in the proper position is small. This change is consistent with NUREG-1412.

L.8 Unit 1 CTS 3.6.1.7 Action a requires the containment purge supply and exhaust isolation valves to be closed within one hout if any of the valves are open. Improved Technical Specification 3.6.3 requires the containment purge supply and exhaust isolation valves to be closed within four hours if any of the valves are open. His change will increase the Completion Time to close the valves fron, one hour to four hours, nis change is acceptable because the chances ere remote that the valves will be left in the open position or opened in 1 Modes 1 through 4. The valves are required to be maintained closed with power to the solenoid valve removed prior to Mode 4 per ITS SR 3.6.3.2 and the associated Bases, ne valves also receive automatic closure signals during accidents (containment isolation, safety injection, and high radiation signals). Also, this change is specific to Unit I because the Unit 2 containment purge and exhaust isolation valves located outside containment have been replaced with blind flanges for operation in Modes 1 through 4. He Unit I containment purge and exhaust penetrations will also be modified to have blind flanges installed during the 1998 Unit I refueling outage. Therefore, this Acticn will no longer be applicable after installation of the blind flanges because the containment purge system specification will no longer be applicable la Modes 1 through 4. Increasing Completion Times to perform an Action constitutes a less restrictive change. This change is consistent with NUREG-1432.

L.9 Unit 1 CTS 3.6.1.7 Action b requires containment purge supply and exhaust isolation valves to be repaired within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when inoperable due to high leakage. Improved Technical Specification 3.6.3 will require the valve to be maintained ciosed. In both cases the contamment leakage requirements are required to be maintained. The ITS will allow containment purge supply and exhaust valve leakage to exist indefinitely as long as the containment leakage requirements are within limits whereas the CTS requires the valve to be repaired within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as long as the centainment leakage requirements are within limits.

This change is acceptable, because other Technical Specifications exist that control Containment Leakage, if the containment leakage is not within limits. Actions of the appropriate Technical Specification LCO is required to be emered (LCO 3.6.1 which requires an allowed outage time of one hour before requiring a plant shutdown). However, good operating practices and engineering judgment dbtate performing repairs to correct leaks before they become excessive. This change is specific to Unit i because the Unit 2 containment purge and exhaust isolation valves located outside containment have been replaced with blind flanges for operation in Modes I through 4. The Unit I containment purge and exhaust penetrations will also be modified to have blind flanges installed during the 1998 Unit I refueling outage. Therefore, these changes will no longer be applicable after installation of the blind flanges because the containment purge system specificaticn will no longer be applicable in Modes 1 ihrough 4. Deleting a requirement to perform Actions within a certain amount of time constitutes a less restrictive change. This change is consistent with NUREG-1432.

L.10 Current Technical Specification SR 4.6.4.1.1 requires each containment isolation valve to be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair, CALVERT CLIFFS - UNITS 1 & 2 3.6.3-7 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6. CONTAINMENT SYSTEMS - i 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 the change involve a significant reductior in a margin of safety?

He proposed change will allow the containment vent to be opened for air quality considerations.

He targin of safety is not significantly affected because a!!owing the containment vent to be !

opened for air quality control will not prevent the vents from being closed during a LOCA. '

Also, proper air quality in containment is critical for safe personnel entry. Herefore, the proposed change does not involve a significant reduction in a margin of safety.

3.63 Chanee L6 Not used.

l 3.63 Change L7 j 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

Tbc proposed change adds a Note which allows the closure devices (valves and blind flanges) in l high radiation areas to be verified closed by administrative means. His change will not affect the probability of an accident. He CIVs are not initiators of any analyzed event. The change will not significantly affect the consequences of an accident. He chances of isolation devices being out of position in high radiation areas is small once the isolation device is verified closed, because access is limited to these areas. He change will not alter assumptions relative to the mitigation of r.n accident or transient. Therefore, the change will not involve a significant i

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 previously evaluated?

The proposed change adds a Note which allows the closure devices (valves and blind flanges) in l high radiation areas to be verified closed by administrative means. This change will not afTect the probability of an accident. This change will not physically alter the plant (no new or different type of equipment will be installed). He change does not require any new or unusual operator actions. 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?

He proposed change adds a Note which allows the closure devices (valves and blind flanges) in l high radiation areas to be verified closed by administrative means. This change will not affect the probability of an accident. He margin of safety is not significantly affected by this change.

Access to high radiation areas is restricted, therefore, the likelihood of these valves being remotely mispositioned is small. Also, by allowing these valves to be verified closed by i administrative means will keep radiation exposure as low as reasonably achievable. Therefore, the change does not involve a significant reduction in a margin of safety.

i CALVERT CLIFFS - UNITS 1 & 2 3.6 12 Revision 7

Cnntainment Isolation Valves 4";;;;h:M rd S=S 75} 3.6.5 @

3.6 CONTAllMENT SYSTEMS 3.6.3 Containment Isolation Valves i't:;i:2 ::d 5:1)--

34 4 l) LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

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

ACTIONS gp .- _- -_

_ = ... .nmrs _ ..........

n,mc t, 1. .. _ .

ation flow paths Qexsefffer I421 inch pffge valvMnetraSton_Mmo s

may be unisolated interwittently under aaministrative con'rols. Th 3 6.YoU nth. Separate Condition entry is allowed for each penetration flow path.

<2 W h . Enter a licable Conditions and Required Actions for system (s) made inopera e by containment isolation valves.

34,l. ) 4. 'En applic e Condi ns and ~

Nho e # i

ontainee " when kage re u1 red A ons of Lid 3.6.1, / '

ts in e eeding t V overall

...b$.$$$I ..$$. .$ S . ...

..... ...... ..>.6ntain

.CONDf110N REQUIRED ACTION COMPLETION TIME A. ----- --NOT E - .-- A.1 Only applicable to Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetration flow path penetration flow paths by use of at least one closed and withtwocontainmerD' isolation valves e $.

,,n 4 G-activated g g'u.i One or more Mj ,g,. automatic valve, closed manual valve.

!i h k"s b

c. ; blind flange, or penetration flow paths check valve with flow A with one containment isolation valve through the valve -

/7\

secured.'

inoperable][e ept f 7 (Furg valve akage ANQ and shield u11d1 by ass le age n Lw< thin 1 it). @

(continued)

CEOG STS

, 3.6-8 Rev 1, 04/07/95 ,

%M dWnboo in3 (S D C.) i tah h=% Veb %W-( be orm k M RC.S .{ 9ph.vt.

's < w r -s - r us sue rua.

r i

(C7S Containment isolation Valves (Atefrh u ' O..P 3.6.$

h g ACTIONS CONDITION RE511 RED ACTION COMPLEil0N TIME A. (continued) A.2 ," 0TE-~~----

Isolation devices in

high radiation areas may be vertfled by

use of administrative means.

l

{q,4'g,h Verify the affected Once per 31 days

penetration flow path for isolation

44. l.l. A is isoletml. devices outside 46.4v W/r containment Prior to entering MODE 4 from MODE 5 if

.i not perfomed within the previous 92 days for isolation -

devices inside containment B. ------- h0T E------ B.1 Caly applicable to Isolate the affected I hour enetration flow path penetration flow paths use of at least with two containment one closed and

isolation valve 7nA g de-activated automatic valve @

S'Mg Q M" . closedormanual valve, One or more blind flange.

AAasm4g penetration flow paths with two containment isolation es inoperable excep olr

,purie alve les e f and told but ing by ss leak snot thin lia 1. T i

(continued)

CEOG STS 3.6-9 Rev 1, 04/07/95

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

Containment Isolation Valves f.-.%... % :d 5:1

(/ N 3.6. @

ACTIONS (continued) h CONDITION REQUIRED ACTION COMPLETION TINE C. -NOTE-C.1 Isolate the affected hours I icable to netration flow path myr. 3.

pen ow paths y use of at least h

or incre, with on one closed and 3

conta t isolation de-activated valv@and a closed automatic valve system. closed manual valve,

,00 blind flange.

i 5.M. l One or more AliQ

penetration flow paths 4en.45AiB with one containment C.2 -------NOTE - - ---

isoittio valve!D Isolation devices in '

inoperable high radiation areas may be verified by administrative ,

Verify the affected Once per 31 days .

flow path (4 lc.I,I n i

$"ll , h 5Secondadontainment 0.1 Restor kage 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months by f leakage not wi imit. j in limit, j @

~_

E. One or more E.1 penetration flow aths Isolate the affected '24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months penetration flow pa with one or mor by use of at leas containment pu e one valves not wi n de-ac(closedand tivated a valve eakage 4

{

ts, automatic va e with resilient s 1s, h closed ma al valve with res isnt seals, or bli flange].

(continued)

CE00 STS 3.6-10 Rev1,04/07/95

Containment isolation Valves dit='Thha(c aruefuelD 3.6.3 SURvFILLANCE Rf0b!REMENTS '

SUP.VEILLANCE FRCQUENCY r_SR 3.6.3.1 Verify each 42] inch purg alve is 31 days sealed clos except for e purge valve in

,' i a enetration flow pat 11e in

\

to ition E of this .

2- _;

SR 3.6.3 Verify esch irch except when t alve_is clob\-1 days

^'M .

open for pressure [4] 1contro1Mvalves an m

.s. t. l./ f

n. 3 coc. 44.r--

or air qualtt considerations for personnel entry, or fo Surveillances that require the kab- h valves to be open.

SR 3.6.3

,0,l.),(

.. NOT E------- - - - - - -

Valves and blind flanges-in hl h radiation areas say be verified by use o h

administrative means.

Verify each containment isolation marual 31 days valve and blind flange that is located cutside containmentjand is required to be losed d6FTiig accident conditions is

closed, exctpt Tor containment isolation .

- M* 6 4 to s.(,3\ valves that are open under administrative Toef a.h g controls.

f (continued) a^d d /x kad, . seal,J ,,

of$udse . secured CEOG STS 3.6-12 Rev 1. 04/07/95

Containment Isolation Valves ?"r:p:-u d ;,.i' 3.6.I h

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3 -

NOTE

%.tl.a Valvas and blind flanges in high radiation F.,* u o areas may be verified by use of administrative means.

[4,(,, l. l . -

~~ ~~

ad nef f.ekJ# Verify each containment isolation manual Prior to

'N^"- valve and blind flange that is located enteri N00E 4 inside containmentsand required to be

[ feare.18 8'I' S curing accident conditions is

- closed from not perfomed 5 ff 73F-4f closed, except for containment isolation within the Lco J.6.3 valves that are open under administrative previous (P,,h.+e. A) controls. 12 days SR 3.6.3. Verify the isolation time ofcamch noWeB in

, G 4,g ,4 f, madratavane each automaticgontainment

-p accordance O 74 C'"- 4ld isolation valve is within imits. ",with the Inservice Testing

. p ,se- o n . ./<

SR 3.6.3. Perform leakage rate tes ng for 184 days containment purge valve with resilient seals. E With 92 days i

b af r opening t valve

! ^

SR 3.6.3 Verify each automatic containment isolation months valve that is not locked, sealed, or

,q A,), g , othemise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

(continued)

CEOG STS 3.6-13 Rev 1. 04/07/95 s

i j

Containment Isolation Valves '" - " " i:1)__ g 8 3.6.3 8 3.6 CONTAINMENT SYSTEMS b J..' ?

Containment Isolation Valves ?"' ::; b,t = d N ;1 p

RASES JwdJ) '

A a

b.d,ROUND The containment isolation valves fem part of the i

containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting l-i

} htolid %e ;5 isskie 3 systems to be provided with two isolation barriers that are )

og*g closed on an automatic isolation signal. These isolation.

'di d'jK l devices are either passive or active (automatic). Mancal a~a %=51 kp b 1., valves, de-activated automatic valves secured in thet Fg g g y 3 " d *" e closed position (including check valves with flow throvgh '

A the valve secured), blind fla es and closed systems are N .eS/4(.c e considered passive devices. C cE valves, or other U /4 dl11 g N *" Y;p,ed- UI4 I automatic valves designed to close without operator actica 4

following an accident, are considered active devices. Two barriers in series are provided for each penetration so that i

f **arfd<.L I . QuKl 4N

A84bb is no single creJible failure or malfunction of an active 4

l gl('*4"toO"'qI".

' '* f component can result in a loss of isolation or leakage that

/ " b % b k;., e4 barriers may be a closed system. exceeds limits assumed in the safety analys P6 e m,k c,A. vi y 9 qoc bt td. h Containment isolation occurs upon receipt of a high containment pressure signa 1Ers ow Rextor con 2snt av.xes I' ' t ." A Nr M*WM i sm m on - ur= = = . The conta' nment isolation si nel @v

~

M",a.tw ope:t.hatuT't. closes automatic containment isolation valves in flu!d

-N T%ry I* W o 6)m a) 6 63t f

rtud penetrationsFeaturenot s required for operation of Engineered Safety 4cr 4 W ~ e g h t w w 3 ,,;,a material.ystems in order to prevent leakage of radioactive Upon actuation of safety injection, automatic OP(-MrufY A W %1 containment isolation valves also isolate systems not t

S W ar* C ' required for containment or RCS heat removal. Other Wr tt.4,/ : penetrations are isolated b position or blind flanges. y the As ause of valves in the closed result the containment h.,

isolation valves (and blind flanges) help ensure that the containment atmosphere will be isolated in the event of a release of radioactive material to containment atmospFare from the RCS following a Design Basis Accident (D8A).

The OPERABILITY requirements for containment isolation

valves help ensure that containment is isolated within the time 11mits assumed in the safety analysis. Therefore, the 4

OPERABILITY requirements provide assurance that the containment function assumed in the accident analysis will

, be maintained.

(continued)

CEOG STS B 3.6-19 Rev 1, 04/07/95 6

7 I

l

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

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

E Containment Isolation Valves 8 3.6. ("- "- '- M g h"I BASES (continued)

LC0 Containment isolation valves form a part of the containment Th boundary.

is related %e containment isolation valve functionsafetminimizing the loss of inventory and establishing the containment boundary during a DBA.

The automatic power operated isolation valves are required to have isolation automatic times isolation with 2 limits and to actuate on an sigul.j The p valves must -

sealed ci unntai ;or hav eks installed prev ull open JLl_oc urae valves al gtuttg, on auta= tte/ 1[1 Ine valves covered this LCO b are listed ~withtheirassocIlitedstroketimesintfeFSAR (Ref. 1). @

The normally closed isolation valves are considered OPERABLE when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind I

D # _

flanges'are in place and closed systems are intact. ,These sive 1solan on va ,lves or devices are snose (isted i'.i j c,u.,_w,%e mes fererencey 3

O 87 b fI h* O *d urge valves Ith resilient sea and secondary centai US fe h beh velik bA bk a g.) Pem lypass val s] must meet addl ona leakage rate nt \

require s. Tne other con inment isolation valve eakage D P R M rt:T g gg g , Q , s addressed by LC .6.1, ' Containment,"

Ilq skal\ b W ,b.e6 ~

ype C _ g cy ,4 7L i n W 3 ;# This LCO providfs assurance that the containment isolation b % droger Q e4 valves 63 purte va340 will perform their designed safety 6 functions to minimize the loss of reactor coolant inventory p*M4g .g. 4,g j and establish the containment boundary during accidents.

8'I 56(ThVM d ee 64 I

W-APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to contati. ment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES.

Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LCO 3.9.:,

' Containment Penetrations."

(continued)

CE0G STS B 3.6-22 Rev1,04/07/95

- - . - -- - .. . - . - - ~ .

, Containment isolation Valves ".7:-S sd LW 83.6.5 h

BASES (continued)

ACTIONS The ACTIONS are modified by a Note allowino penevat4en flow laths _excast for 'eL M ncn ource > s we senetMt' on "Ist l to De uniso ated interwittensy under Ma nis',ratuve M W

co s, These administrative controls consist of stationing a dedicated operator at the valve. controls, who

- is in continuous communication with the control room. In this way, the penetration can be rapidly isolated when a g Q g ,jj,g need for containment isolation is indicated.1D94 to e a

', g anze of ne containment puqe ine per.esranon and fact f*/c Atb.G.lt,3(Q W S that ose penetrations exh st directly from the o f,# 8 0 M #fdded con inment staqsphere to e environment th alves may 6

a he opened under ads istrativecontrekes 4

}M < 300'F

$U feYh4 A second Note has been added to provide clarification that.

s i

-/o for this LCO, sept ate Condition entry is allowed for each a s-/ j/U /i # b < [ /.'J' penetration flow path, This is acceptable, since the Required Actions for each Condition provide appropriate b, 14/e 4, p I ;re.p compensatory actions for each inoperable containment

. f C/ *, dw , isolation valve, Complyin m allow for continued operat$onwith the Required Actions may containment isolation valves a,reandoverned subsequent inoperable I, ##M I^ -fo a //W by subsequent Condition entry and application o associated Required g.c .j,, g Actions, c.ff..!Ar k d - The ACTIONS are further modified by a third Note, which ensures that appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve.

JA foyrth Note is been ded that equires ntry int he' appricable nditions d Requi d Actio of LC0 hiakage r ults in .1 when /_\

]imit.F ceedina e overa contain tleakace)l Q

.xv Q A.1 and A.2 In the event one containment isolation valve in one or more constration flow oaths is inoperable pxcept Jar purge vajpe, leak and sh' e W bu M nv bxssss H akaae Mt within / s the affected penetration flow path must be isolated.'

The me hod of isolation must include the use of at least one iso *ation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind

- (continued)

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

d f

Containment Isolation Valves *-- " -'- "' '"

B 3.6.5 - Q BASES ACTIONS

! A.1 and A.2 (continued) flange. and a check valve with flow through the valve A

I secure). For penetrations isolated in accordance with Required Action A.1, the device used to isolate the ; lJd penetration should be the closest available one to containment. Required Action A.1 must be completed within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is

reasonable, considering the time required to isolate the

! penetration and the relative taportance of supportin containment OPERABILITY during MODES 1, 2, 3, and 4.g For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time and

' that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic bests. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the lsolation

, position should an event cccur. This Required Action does not require any testing or device manipulation. Rather, it involves verification, through a system walkdown, that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of "once per 31 days for isolation devices outside containment' is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as

" prior to entering N00E 4 from MODE 5 if not performed within the previous 92 days' is based on engineering judgment and is considered reasonable in view of the inaccessiblitty of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

Condition A has been modified by a Note indicating that this

Condition is only applicable to those I;

ord nch"g with two containment isolation valves. penetration flow paths For penetration flow paths with only one containment isolation valve and a closed gg g, system,ConditionCprovidesappropriateaction3 Required Action A.2 is modified by a Note that applies tc g

! isolation devices located in high radiation areas and allows these devices to be verified closed by use of administrative (continued)

CEOG STS B 3.6-24 Rev1,04/07/95 4

/

Containment isolation Valves m-#,n n.d LP B3.6.6 Q BASES ACTIONS A.1 and A.2 (continued) means. Allowing verification by administrative means is consioered acceptable, since access to thtse areas is typically restricted. Therefore, the probability of misalignment to be in the proper of these devices,is small.once they have been verified position, L1 ig With two containment isolation valves in one or more Lenetration flow paths 1,noperable K ept for purge v et leag ano snielFL;L-, orna aakaae not wi \

1MJ, the affected penetration flow path must be isolated withnn I hour. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single activa failure. Isolation barriers that meet this criterion are a closed and de-activated 2_N automatic valve, a closed manual valve. and a blind flange. -

[_!.\

' The I hour Completion Time is consistent with the ACTIONS of '

LC0 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the iffected penetration must be verified to be isolated on a seriodic basis per Required Action A.I. which remains in effect. This periodic vertftcation is necessary to assure leak tightness of containment and that penetrations requiring isolatier, following an accident are isolated. The Cowpletion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated ur. der administrative controls and the probability of their misalignment is low. 1([\W 1

Condition B is modified by a Note indicating this Condition is only applicable to penetration flow paths with two containment isolation valves Condition A of this LCO j

f Ug *

CI*" accresses the condition of one containment isolation valve TA e,m inoperable in this type of penetration flow path.

C.1 and C.2 g fn ert With one valv isolation or aobpenetration flow paths with one containment noperable, the inoperable valve must be

@I h restored to OPERABLE status or the affected penetration flow (continued)

CEOG STS B 3.6-25 Rev 1, 04/07/95 a

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

4 i

i Containment Isolation Valves (Atmospheric and Dual) 83.6.3 BASES a

j ACTIONS R and 1 2 (continued)

{ path must be isolated.

The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active fallitw. Isolation 4

barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual valve sand'a blind flange. A check valve may not be used to isolate the 'A j

@ affected penttration. Required Action C.) must be completed 'W 4 wi6hinane @ hour Completion Time. The specified time rJTF4o period is reasonable, considering the relative stability of the closed system (hence, reliability) to act as a

penetration isolation boundary and the relative importance of supporting containment OPERA 8ILITY during MODES 1 2, 3 and 4. In the event the affected penetration is isoInted In i accordance with Required Action C.I. the affected penetration perio11c flow path must be verified to be isolated on a basis.

i This is necessary to assure leak tightness

3. of containment and that containment penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying that each affected penetration flow path is isolated is appropriate considering the valves are operated under administrative controls and the preability of their misalignment is low.

Condition is modified by a Note indicati g hat this '

Condition is nly applicable to those pen tration flow paths I with diD one containment isolation valv and a closed

system.4 This Note is necessary since this Condition is written to specifically address those penetration flow paths inaclosedsystenf 'EN%

JuMf I MNS C'I Required Action C.2 is modified by a Note that applies to valves and blind flanges located in high radiation areas and

/ M C.t allows these devices to be vertfled closed by use of 1Aj 14k administrative means. Allowing verification by 3 1

administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the

, probability of misalignment of these valves, once they have

! been verified to be in the proper position, is small.

u -^

W h the secondary c0ntainment l thin limit, the assumption pass leakage rate not f the safety analysis ar ot b

(continued)

CE0G STS B 3.6-26 Rev1,04/07/95 4

Containment Isolation Valves (*'-P:-h x MF B 3.6.f, C BASES SURVEILLANCE SR 3.6.3.1 (con nved) ~7 REQUIREMENTS epening of a co ainment purge valve. talled analysis of the purge valv abilit failed to conclusivel demonstrate their doses.yTher to c1ore, e during theseavalves LOCAare in ti to limit offsite ,

quired to be in the sealed clo d position during MODES , 2, 3 and 4. A containee purge valve that is se ed close,d must have motive p er to the valve operato removed. This can be accomp1 or by moving hed by de-energizing th source of electric p the air suppl this p11 cation, the tem 'y t the valve operator. I se ed' has no connotatto of leak i htness. The Frequene is a result of an NRC ini lat ve, Generic issue 8- (Ref. _p \ -

77,p co tainment purge valve use during un(D. related to it cperations i not required to be met This SR his is reasonable since e11e in Condition E of his LCO.

penetration flow p h would be isolated.

-w SR 3.6.3 ,l ./-

This SR ensures that the valves re closed as required or if open,' epe allowab 6 valve,is open 1 violation of this R,reason. If a the valve is codi'^"e+ VC4 considertd inoperable. If the inopera e valve is not

^-

otherwise known to hav excessive lea ge when closed, it is not considered to have eakage outsi t,f limits. The SR is not required to be met uhen the valves are opin for pressure control, ALARA or air q y consideratio s for personnel entry, or fer.Surveillances that require the valves to be open.

closingintheenvironmelntfollowingaLOCA.The Therefore,fpmnrrmh valves are capabl these valves are allowed to be open for limited periods of time. The 31 day frequency is consistent with other containment isolation valve requiruments discussed in SR 3.6.3Q SR 3.6.3.

%d MW

"* >" M *a This SR requires verification that each containment a

isolation manual valve and blind flange located outside Cfd containmentaand required to be closed during accident Ig 45 fd canoittonOs closeda The SR helps to ensure that post 7cioent leakage of raaloactive fluids or gases outside the (continued)

CEOG STS -_ -

B 3.6-29 Rev 1, 04/07/95

% Co-.hkatM P,rge ad flowsf dite k & C&~*^

%f P~t hkW w cece($noruTY stil6 leksed k@

'b % N'SI*)fM t L p~er4, n* %4 vA 6 re %n .

~

Containment Isolation Valves *-P-" d MP 83.6.5 O

sAsEs t

-SURVEILLANCE SR 3.6.3 REQUIREMENTS (continued) b containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather it involves verification, through a system walkdown, that,those of being mispositioned are in the correct position. containment isolation v Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to f( L'OSEET provide added assurance of the correct positions.

Containment isolation valves that are open under b '3 administrative controls are not required to meet the SR

,s fts 34,3.7-- -

during the time the valves are open.e3 11 6 -4/S' l g 3.l.'3) The Note applies to valves and blind flanges located in high l

i radiation closed areas by use and allows means.

of administrative these devices to be verified Allowing verification by administrative means is considered h

acceptable, since access to these areas is typically restricted during D OES 1, 2, 3 4 and for ALARA reasons.

Therefore, the probability of alsalignment of these containment isolation valves, once they have been verified to be in the proper position, is small.

SR 3.6.3 ad a4 g"h'j> This SR requires verification tnat each containment soI4 oc tsolation manual valve and blind flange located inside centainment4 and required to be closed during accident i chere pneed 5 conattionsl s closed. The SR helps to ensure that post

---~~____J accident leakage of radioactive fluids or gast1 outside the 7.'IfM4[

containment boundary is within design limits. for containment isolation valves inside containmed , the Frequency of " prior to entering MODE 4 from MODE 5 if not perfonned within the previous 92 days' is appropriate, since these containment isolation valves are operated under administrative misalignment is ccntrols low. and the probability of their

-fA)sEf.7) Containment isolation valves that are open under idnintstrattve controis are not required to meet gg the SR during the time that they are open.q JRs 3 4.3.L y,g The Note allows valves and blind flanges located in high N '3' 3 radiation areas to be vertfled closed by use of administrative means. Allowing verification by h ,

I (continued)

CEOG STS B 3.6-30 Rev 1, 04/07/95

14. 'Ihe NRC requested that the ISTS 11ases Markup for ITS 3.6.3 be revised by deleting a reference 1 to JFD 3 for liases Section 3.6 that was placed next to the last paragraph of the liases for llequired Actions C.l and C.2. He ISTS Ilases Marl. y for llequired Actions C.1 and C.2 of ITS 3.6.3 was revised as requested. (Comment 3.6.3 7) p i

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

Containment isolation Yalves (Atmospheric and Dual 8 3.6.

8A$[$

ACTION $

t 1 and c.2 (continued) path must be tselsted. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active fatture. Isolation barriers that meet this criterton are a closed and

/ de. activated blind flange. A check

_ n'fected p automatic valve, valve may not a to be used closed iso 1andmanual a valvelate

'A the 7 ;ratirn. Required Action C.! must be completed ;!n w thin ane period is ) hour Completion Time. The specttted time f:r7F-N asonable, considerine the relative stab (11ty of the closed systen (hence, reltabIlity) to att as a penetration Is01stlen boundary and the relative importance containment OPERASILITY during M00t$ 1 2, 3 of supportinhe event the affected penetration is isolated ln and 4. In t accordance with R "utred Actiten C.I. the affected penetration flow path must be vertfled to be isolated on a periodic basis. This is necessary to assure leak tightness of containment and that containment penetrations requiring isolat% following an accident are isolated. The Completion Time of once per 31 days for vertfying that each affected penetration flow path is isolated is appropriate considering the valves are operated under administrative controls and the probability of their misalignment is low.

Condition is modified by a Note indicati g at this Condition is nly applicable to those een tration flow paths with 45 one containment isolatioT valv . and a closed system.4 This Note is necessary since this Condition is written to specifically address those penetration flow paths inaclosedsystesf W Oa h

AtAross C'I Required Action C.2 is modified b a Note that appites to valvesandbitndflanieslocatedinhighradiationareasand

/ M c.t. allowsthesedevicestobevertfledclosedbyuseof 1A 1 adelnistrative means. Allowing verification b f4k administrative means is considered acceptable,ysince access to these areas is typically restricted. the probability of misalignacit of these valvesTherefore,he once t been verified to be in the proper position,,is small.y have

~

g ~h W h the secondary containment j thin limit, the assumption pass leakage rate not f the safety analysis er et b

(continued)

CEOG $1$

8 3.6-26 Rev1,04/07/g5

15, 'Ihe NRC requested that the ISTS Ilases Markup for ITS SRs 3.6.3.2 and 3.6.3.3 be revised to i accurately reflect Revision 1 of TSTI'.45. 'the ISTS Ilases Markup for 11S SRs 3.6.3.2 and 3.6.3.3 were revised to reflect Revision 1 of TSTi'.45. (Comment 3.6.313)

Containment Isolation Valves B 3.6.3 BASES SR 3.6.3.2 This SR requires verification that each containment 7

isolation manual valve and blind flange located outside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed.

The Containment Purge and Exhaust Isolation Valves required for Containment Penetration Operability shall be detennined j

closed by verifying that power to the solenoid valve is removed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions.

Containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the 7 correct position upon locking, sealing, or securing.

The Note applies to valves and blind flanges located in high 7 radiation areas and allows these devices to be verified ,

closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, 4 and for ALARA reasons.

Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in the proper position, is small.

CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-10 Revision 9' 7

Containment Isolation Yalves ;

B 3.6.3 j l

BASES SR 3.6.3.] '

This SR requires verification that each containment isolation manual valve and blind flange located inside 7 containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. For containment isolation valves inside containment, the Frequency of ' prior to entering MODE 4 from H0DE 5 if not perfonned within the previous l 92 days" is appropriate, since these containment isolation '

valves a.e operated under administrative controls and the probability of their misalignment is low. Containment isolation valves that are open under administrative controls are not required to meet the SR during the time that they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since y these were verified to be in the correct position upon locking, sealing, or securing.

The Note allows valves and blind fianges located in high 7 radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small.

SR 3.6.3.4 Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analysis. The CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-11 Revision 0

Containment Isolation Yalves U'W:t at M B3.6.5 C

aAsts

$URVIILLANCC At0VIR[MENTS

$R 3.6.3.1 (con nued) m~ ~

l opening of a co alnment purge valve. tatted analysis of the purge valv i

failed to conclusivel t)i P r to el e during a LOCA in ti demonstrate their l

I Gual Nr ore, these valves are to 1tstt offstte quired to be in the m iN n vi d position during MODES .23 and 4. A un et y. purge valve that is se edclose,dmusthave motive p er to the valve operate removed. This can be accompi or hed by de energiring th source of electric by movts.g this p11 cation the air supply t the valve operator. pI the ters se ed' has no connotatto of leak ichtness. ,The Frequene is a result of an NRC ini lattve, Generic !ssue 8-ce tainment purge valve use p -

\ related Fyg,p i dur(ng unTt operationsRef.GD, to i not required to be met This SR his is reasonable since elie in Condition E of his LCO.

penetration flow p h would be isolated.

@ w ._

$R 3.6.3 I 4 g This SR ensures that he m~

required or if open Lope GB, valve,is open I violation ofallowab valves te closed as reason, if a ded*M" " VC4 this R. the valve is W" considered inoperable, if the inopera e valve is not otherwise known to hay excessive lea ge when closed, it is not considered to have 'eakage outst not required to be met uhen the of Ilmits. The SR is pressure control, ALARA or air q valves are open for personnel entry y considerations for valves to be ope,n.or forJurveillances that require the The pyn-- valves are capable of closing in the environment rollowing a LOCA. Therefore these valves are allowed to be open for limited periods,of time. The 31 day frequency is consistent with other containment isolation valve requirements discusted in SR3.6.3 Q SR 3.6.3 and nai- ).g* This SR requires verification that each containment f"a;d;*e eh* tsolation manual valve and bitnd flange located outside a 7g,.45 [d

f *l containmentaand required to be closed during accident concitton 1s s closeda The 3R hel s to ensure that post acciaent itakage of radioactive f utds or gases outside the (continued) ct0c $1s -

B 3*6*29 Rev 1, 04/07/95 w to 4.i.,-.A PegeeA M ad p;4WG f oitel & CMtM*d p,,tgu om.non :T1 stif t,e Me~~,d \g CIntA h M f% N+ & p urr 4 4 W

fo\e 4 k w % h fe w e r .

~

Containment Isolation Val +ies 1" T r " d 5 1 8 3.6.3 b

BASES

$URV[lLLANCE $R 1.6.3 REQVIREMENTS (continued) b containment boundary is within design 1tatts. This $R does not require any testing or valve manipulatt9n. Rather, it involves verification through a system walkdown, that those containment isolation, valves outside containment and capable of being sispositioned are in the correct position. Since verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day

( Frequency is based on engineering judgment and was chosen to f Tsj$EP.T provide added assurance of the correct positions.

Containment isolation valves that are open under g3'g'"e administrativr controls are not requir S R.s 3.6.%'l -

during the it(e the valves are open.e)ed to meet the SR Tift-4Si - l p 3. 6.3. 3 ) The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be vertfled closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas it. typically restricted during MODES 1, t 3 Therefore the probability of u\salignment of these4 and for ALARA reasons.

containmen,t isolation valves, once they have been verified to be in the proper position, is small.

$R 1.E.1 ad M l"g'a J This $R requires verification that each containment se* h h s e isolation manual valve and blind flange located inside centainment and required to be closed during accident )

d i conanton o lk.mse pews.J s closed. The SR helps to ensure that post

~-

accident leakage of radioactive fluids or gases outside the 7JfMI containment boundary is within design limits. For containment isolation valves inside containment eth Frequency of ' prior to entering MODE 4 from MODk performed within the previous 92 days' is appropr$ iateif not these containment isolation valves are operated under, since administrative aistlignment is controls low. and the probability of their I

($A)S(f.T] Containment isolation valves that are open under adelnistrative controls are not required to meet g 3,g the SR during the time that they are open q y,qr

,5fh 3 h.3.'t.

M O'M' 3 The Note allows valves and bitnd flanges located in high radiation areas to be vertfled closed by use of administrative means. Allowing verification by h

(continued)

CE00 $15 8 3.6-30 Rev 1. 04/07/95

l .

Y(TFkRk INSERT B 3.6.3 sits 3.G.3. 2. cad 3.63.3 This SR does not apply to valves that are locked, sealed, or otherwise secured in th-closed position, since these were veri 6ed to be in the correct position upon locking, sealing, or securing.

e

. .w D

?

16. Discussion of Change 1,A.2 for ITS 3.6.5 was revised to state that the specific locations for -

measuring containment air temperature are being moved to the Dases. The ISTS Markup of the 11ases for ITS 3.6.5 was revised to include the required information. These changes have been made to respond to an NRC Comment. (Comment 3.6.51).

l l

1

Containment Air Temperature B 3.6.5 BASES Therefore, maintaining containment average air temperature i

within the limit is not required in MODE 5 or 6.

ACTIONS Ad l

When containment average air temperature is not within the limit of the LCO, it must be restored to within limit within l 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This Required Action is necessary to return

! operation to within the bounds of the containment analysis.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.

B.1 and B.2 If the containment average air temperature cannot be restored to within its limit 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 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The 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.

SURVEILLANCE SR 3.6.5.1 REQUIREMENTS Verifying that containment average air temperature is within the LC0 limit ensures that containment operation remains within the limit assumed for the containment analyses. In order to determine the containment average air temperature, an arithmetic average is calculated using measurements taken from the Containment Dome and the Containment Reactor Cavity temperature indicators selected to provide a representative 7 sample of the overall containment atmosphere. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this SR is considered acceptable based on the CALVERT CLIFFS - UNITS 1 & 2 8 3.6.5-3 Revisionp7

i DISCUSSION OF CilANGES SECTION 3.6.5 CONTAINMENT AIR TEMPERATURE ADMINISTRATIVE CliANGES A.1 ne 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 prtferences or conventions were adopted which resulted in no technical changes to the Technical Speci0 cations. 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.

IECllNICAL CllANGES - MORE RESTRIC11YE None.

TECIINICAL CilANGES RELOCATIONS None TECIINICAL CilANGES - MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED HQCUMENTS ;

i LA.1 Current Technical Specification 4.6.1.5 requires the containment average air temperature to be the arithmetical average of the temperature at the containment dome and the containment reactor cavity. Improved Technical Specification SR 3.6.5.1 will only include the requirements for the primary containment average air temperature to be determined. The ITS will not include the specifics on how to perfonn the SR (the arithmetical average of the temperatures). This information will be moved to Section B 3.6.5 of the ITS Pases. This is acceptable because these details do not impact the requirement to verify the containment average air temperature. Ecse details can be adequately controlled in the Bases which l require change control in accordance with Dases Control Program in ITS Section 5.0 His approach provides an effective level of regulatory control and provider for a more 4

appropriate change control process. He level of safety of facilhy operation is unaffected by the change because there is no change in the requirement to verify the containment average air temperature. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced, nis le s less rr strictive movement ofinformation change with no impact on safety, nis change is consistent with NUREG 1432.

LA.2 Current Technical Specification SR 4.6.1.5 requires the containment average air temperature to be the arithmetical average of the temperature at the containment dome and the

containment reactor cavity. Improved Technical Specification SR 3.6.5.1 will only include the requirements for the primary containment average air temperature to be determl i .: J The ITS will not include the specific location of temperature indication (containment dome and containment reactor cavity). This information will be moved to the Bases for ITS SR 3.6.5.1. This is acceptable because these details do not impact the requirement to verify

~

CALVERT CLIFFS UNITS 1 & 2 3.6.5 1 Revision 7

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

DISCUSSION OF CHANGES SECTION 3.6.5 CONTAINMENT AIR TEMPERATURE the containment average air temperature, nese details can be 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 control and provides for a more appropriate change control process. He level of safety of facility operation is unalrected by <

the change because there is no change in the requirement to verify the containment average l air temperature. Furthermore, NRC and Calvert Cliffs resources associated with processing i license amendments to these requirements will be reduced, nis is a less restrictive movement of information change with no impact on sefety. His change is consistent with NUREO 1432.

IEClih[lCAL CilANGES 1.s'RS Hs'ETRIC11VE None CALVERT CLIFFS - UNITS I & 2 3.6.52 Revision 7

1 1

Containment Air Teaperaturo (^t;,i;;;; ;rd 0.;P 83.6.I Q BASE 5 (continued)

ACTIONS Ad When containment average air temperature is not within ths-11stt of the LCO, it must be restored to within Itait within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This Required Action is necessary to return ooeration to within the bounds of the containment analysis.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is acceptable considering the sonsttivity of the analysis to variations in this oarameter and provides sufficient time to correct etnor problems.

L1 and B.2 If the containment average air temperat'are cannot be restereo to within its Itatt within the required Completion Time, the plant must be brought to a MODE tr whta.h the LCO does not app 1l/. To achieve this status, the plant must be brought to at 1sast M00t 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to h00E 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions free full power conditions in an orderly manner and without challenging plant systems.

$URVt!LLANCE SR 3.6.5.1 REQUIREMENTS Verifying that containment average air temperature is within the LCO 11:11 ensures that containment operation reenins within the Ilmit assumed for the containment analyses. In order to detemine the containment average air temperature, an arJthmetic ey b & Cen6,*ed gwgithr)Se is_ calculated using measurements taken n theto A g

bg Q Q representative sample of he {omnmonsciected to provide a t overall containment atmosphere.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of this $R is considered acceptable '

d emW een4 REAcler based on the observed slow rates of temperature increase Cwh bgree within containment as a result of environmental heat sources Idue to the iar e voiume of containment),

inficAfor3 f4 hour Frequen,cy is considered adequate in view of otherrurthe more, the

. Indications available in the control room, including alarms, to alert the operator to an abnomal containment temperature condition.

(continued)

Ct0G STS 6 3.6-42 Rev 1. 04/07/95

1 i

17. 'Ihe 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 the SRs for CTS 4.6.2.1 for ITS 3.6.6 were revised; 2) DOCS A.5, M.1, LA.4, LA.5, and L5 for 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)

_ , . - , . -e

Containment Spray and Cooling Systems B 3.6.6 BASES SR 3.6.6.4 l

Verifying that each containment spray pump's developed head at the fiaw test point is greater than or equal to the

, required developed head ensures that spray pump perfonnance l has not degraded during the cycle. Flow and differential l pressure are normal tests of centrifugal pump performance required by the American Society of Mechanical Engineers (ASME) Code,SectionXI(Ref.6). Since the containment spNy pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program.

SR 3.6.6.5 and SR 3.6.6.d These SRs verify that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation signal (i.e., the appropriate Engineered Safety FeatureActuationSystem(ESFAS) signal). This Surveillance I is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that

.hese components usually pass the Surveillances when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability stedpoint.

CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-10 Revision 5 7

Containment Spray and Cooling Systems B 3.6.6 BASES The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements.

SR 3.6.6.7 This SR verifies that each containment cooling train actuates upon receipt of an actual or simulated actuation signal (i.e., the appropriate ESFAS signal). The 24 month 7 Frequency is based on engineering judgment and has been shown to be acceptable through operating experience. See SR 3.6.6.5 and SR 3.6.6.6, above, for further discussion of the basis for the 24 month Frequency.

SR 3.6.6.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke can be blown through check valve bonnets. Performance of this SR demonstrates that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded. Due to the passive design of the nozzle, a test at 10 year intervals is considered adequate tn detect obstruction of the spray nozzles.

REFERENCES 1. UFSAR, Appendix 1C

2. UFSAR, Chapter 7

3. UFSAR, Chapter 6

4. ASME, Boiler and Pressure Vessel Code Section XI CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-11 Revisiong7

S pes u b 3,4,4

% # 4 4 teNTAllBitNT SYST Dtl

r. f,, ,4 4/LLI (RearetumwnTIONHND C00 LINO sysitws Q antainment larI{ M , h,

.______ _ - _ v A cu 3 (.,6 LItt!T188 CO S ITION 9ptAAT!4W 8 " 1b' ca a ella /r.w h tiest;1 fue independen', Containment Spra

.nv en IREDsh 11 h ettnAtttI wlte

,- = . . num ce, I $ prey stienSignt'seeeTsen n= uns nu enawn mment

) and 8tfe nject'on Actuotton $!ent) en tutent cally transfprring sue on to the containment sump on _

Rect 44.

de tvlation Actuation lien

--i e shall he w . Each s an BPraangeg4*-e taalinestem flow path me the mat anchanner ApptttAlftffY MODES 3, t, and 3'.

e. A i dev e aa AmW A s t blith one Containment Spray System inoperabit dc.eie, if r.% A nstere ~ A-4 Letch I, est NOT STperable a re system to OPERABLE status Y within the next 6 hours and in cethe withi Jer -in t;h.h==-

Ac W 8 lummnriness hours, 410 BID within @

Q ggg4g,g .

-h g siv n c SURVtlLLAllct u vva u s n u -"

g 3 0:4 ch Containeen pray System s 11 be demo ted OPERAILE: '

At les o r 31 t'sys **u ' a4,94 ..

/, g /,4 e ' >

% Ver ying that uponi Eac1rcuian-act

/ t con rinmens a agle) Test $ nti, O noist 4 v4Mesu mn . pr ina

.,$,',0y'.*A*u$ # "" "E 'h*' "" ....D /

- /

. Verifyin t r*G ralve \ s ,un,,,*

nual power ope ted or *'a sutomati in the f1 )w pa> tha i vred g natr a-i em /

/

r, --

s Iss ,

@stion

'o n e s tv w7'---"- Aj:o byh Trv TM annin7

! u"

- -n la

.nh. sue m ,bs1and

- no".

W_.

's Itsed. sealed ng shutdQy/ g*N ,, ,

Verifying that ch automatic va

_ to its correc positioncon um l in the

-artava flow pat-)(uactuates stone),f7 p. 4 d i

[ _,

f L, k tVerifying / \ J,/hat%each

<. _ ... 3 test s i. __

spref p starts automlati '11y on e'

_ M u % j, O y & _

With pressurlaer pressure 11750 psia, CALVERT CL!rf5 f [*j5M Lt2 g

UNIT 1 3/4 6 15 Amendment No. 212 l Lite

A.u d 218

// $ g

fftCit*4% 3.4. (

IN$ER13 $R g.6.6.4 Surveillance frequeg SR 3. ~ 1 Vw6fy tainmen y man wu ope ed, and a ~utic 31)tys val the flow tion is a not tion.

sealed, twise ed /

correct /

SR 3.6.6.4 Verify containment sprey pumps denloped head at the flow test point in accordance with is greater than or equal to the required developed head, theInsenice Testing Program l

9 py 2 r4 A

_o

S ofsu % 3*G*b i

3/4.6 CONTAllpDT SY$ftMS l SURVf!LLANCE REQUIREMENTS (Continued) et laatF

' /c" or. .fince. , pe.rN.e.3t e

na..cn

./4ti.Jersers

. n v o, ariirme -= nariant!

pr.,....i. .

F a omirve.es.f

/ t

/ / /

l Latene.

w.a h in8 CALVERT CLIFFS . UNIT 1 3/4 6 16 Amendment No. 212 l Licewtv Mwd 2.18 [#/#

Tpet,6 c:b 3. n..s.

3 b D M s 4.(a.Z.l.a jhicufs SC tt..t.t.d ,

as approveJ 4 Odd I in Liene OmeJetd do. 21B

4. 6.2.1 Each Containment Spray System shall be demonstrated OPERABLF:

(~a . At least once per 31 days by:

9t1.bibel Qn % %uN*M

1. Verifyl that each valve (manual power o erated or \

automat 1

( otherwise) secured

)osition in isJpgsi';10hed ';Cinse,aled or_.

theuct4flow path that I 0

Lfrom the INT oAa covairment Vretske Hibh te\take sT sian IF.

. At least once per'9' days by:

' . Verify b'l b the cont nment that upo sump a Recircu13 isolation tion Actua ion Test S nal, Ives open nd that a recircula on mode fl path via n OPERABL shutdown roling t M t exchan r is esta ished, '

)

s g c.

At least once per REFUELING INTERVAL. durina shutdown, byt s

' CA 3.4.t. 4 -

1. w .. n.+ iu.a.saie,.r. % .o wo.a .ne... w Q

- Verifying that each automatic valve in the flow pathtactuates to its correct position on LN)e vpropriatAE535 ttsy signal. *

{ gg 3 ,g,9 4 ( 2. Verifying that each saray pump starts automatically on the

((N)raprMte ESM5 tem ignal .

" Q an acks) or d a t e M l0 L.5 W 3,s. 6 8 [d. At least once per 1 trnrouchvacn xpray teadei\andiver1 Tying eacn spray nozz _

unobstructea.

4 i

)

) +

4 e

4 Lice.oe bed-ea E12

S p.8u A* - 3.4. 4

3. (. 4/4,4- CONTAlletENT SYSTDil 3 m.: W PM E$URIZA E LING H$ 2 5 tainment coo 11

! Svatam LINITING C01 BIT 10N Fet OPERATION L c.o 3, c,, g 4N Tweb " -min oIontainernt mir ==rirruinuan a60 coolingWhall h trinAB.E sr unme un' ts _

Jreach spetHQ ~~

APPLICABILITY: . MODES 1, I and 3 O' fr* **J 'LA._.r h A LCL)

Cittth one roup of required containment str_.racirculifenandb -

A""d O 7 coo 11 stei.is A .7.

. OPE , restore the inoperable ginoperable of air recircu and both Containment spray @ation a 4**" E j. cooling units to OPERABLE status w n 7 daysfor be ' n at least /

V T SN 13 rs. g [

A * *d t) .

K itth throe'requitec conTathme mini acuwuonans cooling units inoperable and both Co ainment $ pray Systems OPERABLE, A restore at least one raamr= ='- -m=mn una coolin Un A A cti. 4 E to OPERAstr status within@ hours or be in at leasts lt0V CN 0001 .

a irithin 12 i, burs. pre both above reeutred nrove n $ a T]s f'gcontainment at rec rculation and cooltna unito to ar WLE Anu C f D - I ,J status within days or be in at liast90T Env swielN w ",h n IZ]

Q A t_mo c- -i (hours. g' j j- 4,-

A With one group of required contat~nment air redirculation and 7 A ne .. i, cooling units inoperable and one Containment $p ay System I inoperable, restore the inoperable Contajnment pray System to A e w ti opgnAgLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least $NUTe0W r within !?. hours. Restore the inoperable roup of Inment air

^"'"'C-- precirculation and cooling units to OPERA E status within 7 days Atm s G mof initial loss or be in at least NOT 4

$NUTDOW1 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .;

i 4

$URVEILLANCE REQUIREMENTS 4.6.2.2 Each containment air recirculation and cooling unit shall be

demonstrated OPERA 8LE

A At least once per 31 deys@n,F5TAGGERED JMT SAE11b by:

% [$tytlng eachynit from the coptfoi roomd i

CALVERT CLIFFS . UNil 1 3/4617 Amendment No. 212 l m

R 6 e, & ~ 0 e r*t c.d a ua .s.o.3 h.m u,e..L .c.,JA) nA p,g& .,. a{r. . b'U.

. <..~.

y ns s

.C Pdad n 3. (.. (

l 3/4.6 $$dTAllgitiff $YSTDi$

SURVEILLAllCE ktqu!RDIDIT$ (Coatineed) l l

1R %.6 41. 'h Verifying that each unit operates for at least il minutes.

AL 1.G.6,3 h Verifying a cieling water f1_ow rete of12000 sps to each teeli w unitanen the ruis Tims n=mme wr wsiet valvem (Bre Tf 1# 0;;iJ . '

b. At least once Mr ntFUELill8 IWittVAL by vir fring that each unit A A 2.6 G. *i starts evtomatically on the q; ;j Q (test signal. F

%h% g ll CALVERT CLIFFS - t*li 1 3/4 6 18 Amendment No. 212 l f*y b b -

Sp4cifi4M*6 ,1(n.fo 1fe @ ColfTAlleitNT $YSTEMS

'3, f., y @ R=sanuunT10m.AND. COOLING SYSTEMS (containment Sora g ,

LIMITING CON 0! TION FOR OPERATION J[6;C[6 d'dE.h tc p 2.1, (, O Two independent Containment Spra/P shall be OPERABLtfTr E g m n spre sysisin capspis oT semi 65ivn i . sne nwi en e 59 .ir n1

$ pray Ac ation $lgnal and Safety ection Act.nton $lgnal a p outoma cally transferring sucti to the containment sump on

( A.

Recir lation Actuation $lenal. Each spray system flow pat ros the 1 to inment sumo shall ha via n nerniair ahutdown coolina aat amehaname.1

--- ~ eA APPLICABillTY: N00t$ 1, 2 and 3*. 0 ek ~ -

ja r/

4.rsu 4 -($110!!: 4#

Mnoperab le spray system to OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sPbr be inEWith one C 4 7,,, g Jetst NOT $TANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in gpp wuavvvityrithin@

Wo W owint 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months .

g-- g g _

.3

b s 6 C at J.Gir,. D

$URVEILLANCE REQ IR MLn n ~ -- ]pg, I A dr/ [ tach Containme~

Spray System sh emonstratsdOPtfLE:

a. At least ce per 31 days by: J

1. Ver ing that uppp aGameuratidn ActuMe_n)Iest $lgelT, L t

c i airuncus s snar et ec lation mo w rt vir vahes aprDPIRA y,,en[sh40wn copyn3 A, j he - exchancer i heds - -- -

---bl s. y b ch v ve(manual po r operated, or w ..,,. d Verifying)that automatic in e f1 paththatIs t locked, sea d,or A .pi + -

o herwise s red position _( SAfD51tiorwa to :ste mucu orn e ,-7 4

. _y ne _ m on afnhiai nmaff t Premmere.NIch/Tes (signal ./ d A*E

%.. 'H % u _ ,s/s. W. DHW '

u on ses

@ At least o per stru..ING INTER , during shutdown, b p uh l er

'i N i streid J r 1. Ver ying that each automa e valve in the flow actuates to ts correct position ambe apprsprbte mrumsignal.

%) erifying that e y pump starts automa 11y ong t/3,4 NM " k'I"'I' 8 I.6 Kfbffc,g4.

= --

A=

.7 tJ$ C P.T I f 4 6 I.l b i h

M*l'I'h With pressurizer pressure 1 1750 psia. freqkSQ4l.lk 195 h CALVERT CLIFFS . LINIT 2 3/4 6 11 Amendment No. 189 d litest hthQ IW ?

% p,. e i Pi c. 4 e v . 7. b. b INSERTS SMS,6,diaerd)3.6.6,4 Surveillance

~ . 1 6.6.1 rify each conta F.huency .

nt spray n 1, power o . sted, and au fftatic 31 i valve in the w path is no Led, seal r otherwise red L_ in posi is in the co position. ,

J SR 3.6.6.4 Verify containment spray pumps developed head at the flow test point J in accordance with is greater than or equal to the required developed head. the Inservice Testing Program I

l

$ c.f.o 4.e , 3 0+b 3/4.6 CONTA1MNT SYSTDi$

$URVIILLANCE tt0VittNENTS (Continued)

Atleast ce per $yeart_ivMorning ener v. _:.=A - s ,

in _ _ #n n rvs . o ane veriTyi acn spray not- ts -

-unoo. i,t es .

m

?/ / f Liceww.

w .>

M?

CALVERT CLIFr$ . UNIT 2 3/4 6 12 Amendment No. 189 l b u s M t. b e d u d \4 Y g n, e 3E6 h

$pe,4eamen 3 6.(.

IWST/cr % 4.u.i.a. he sa. 4.4.u. A M oppremd -Q,e W & 2 in Lo nt0ne M d 6 (4r 4.6.2.1 Each Containment Spray System shall be demonstrated 0PERABLE:

1i. At least once per 31 days by:

i Qnk tum4 NE) qg3,(,4,l/ 1. Verifying that each valve (manual power operated o \r automatic) in the flow path that Is ne locked se,aled or J otherwise secured in 1olition is Iposh;'one ';o tate s ction Ur9m int RWAon KCon;a ymen(PrhsurLQigh ests%na l . At leas once per days by: .- ~

1. Verify g that upo a Recircu tion Act tion Te Signal, the cont inment sump solation alves op and tha a M recircula on mode fl path via n OPERA shutdo coolin heat exchan er is estab shed. -

c. At least once per REFUELIE INIERVAl_ dudma thutdown bit Gk+ is tw& bekeit , sea tea. o ohr.,.1o w unJ ia Pub.

S.R 3.4.6 5 1. Verifying that each automatic valve in the flow path + actuates to itt, correct position on RHe aphropitatA ESMS\te(t Ignal. M sc 3.u.i. 2.

Verifying that each spray pump starts automatically on@

@pbTf4Ke QFAkta,$Qsignal .

N gotnock)or6mul44cJ

4,g qq 3,t ,g . At least once per yea LS) *

@ rouw etcn wprag netderM n pemorvnw in air gr smdte fJow\tc t unobs',ructea. erifying each spray nozzm Liceau Ibe*ba 195' q ,p g I g

Q a, #i oo o .o 'To 6 . b 3 . fa 4/ht- EMTAINMENT.lY$TEMS C' *'"*"*

3PQ b L 6. 6 4/;.e.;- 11tPRESTURIZATJO AND COOLING SYSTD4s tain tool _

System LIMITING CONDIT! M FOR OPEUTIM k'**[k' # "' # _

i' V 9

t t.o T. 4 6 ntai -

cooiing 4.0. . 4Tw mmtfihE[mnment 6% . . __

cu nierano APPLitABILITY: N0 DES 1, 2 and 3.

Q 42.

ACTION:

4, .5Q Q@~,; g, ,g ,gg A IWith on prouMf required containment 8hp-ifttremon ane d h W54 3' " * ,J C coolino OPERABLE, restore the inoperableofgsairinoperable andends ',}'7f'".,i both Containment m 'u'

, h 3fstems spray cooling units to OPEutLE status w socircu stion n 7 days (6'r oe sti at least A c t i e sa t %

NOT $ _within 12 hourt.

< vi e C< u . .s . . i.,.

f*7%^

I N

h3

\l1 tith hrn hequirt5 cen L . '2 A C "$2 0

-r -

cooling units inoperable and both Cont # neent soray 3-. PEMBLE.

kestore at least one,h r r=ncuuMdtb and cooling l

Ar 3 ..m g ~ o OPERABLE status within@ hours or be in at least$tgi $ NUT .

ithin 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Restore both above required groups of b ^ *O*.' ' '" ' @

u%,u% 4 g, _

/ containment a

~

ation and cooling unus to crLRABLE ; 4'

\ status within sys or be in at leastg0T $NUTDOWN within 12 J An 'ou F --

( hou rs .

~

K With one group of required containment air recirculation and cooling units inoperable and one Containment $ pray $ystem

! e.o ^ Anoperable, restore the tioperable Containment $ pray System to

(

f "" " C %(OPERABLE within status 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . within Restore72 hours or be in at the inoperable crouplesso co $NUTDOWN

^ ( w" <-

recirculation and cooling units to CPERABLE status within 7 days 5isin r

^< '

b8 L' -

3 0f initial loss or be in at least(OT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

T

$URVEILLANCF REQUIREMENTS 4.6.2.2 Each containment air recirculation and cooling unit shall be demonstrated OPERABLE:

\ At least once per 31 days (n.a 5TAsstuto TL5I MT!53{

\ $ppetlig each upe"trom the conyroom3 m m 1 CLy r$ ,us

t. 1. u..-

m" _

r"t"e" '

4...,...e..-~

3. , e .., u,e 3 . c,. 3 i - .a.. D, gg' O

a , c .n. . . . . . . ~ u. . c

.,, . . t. i e

.- - j rys.

p ec 8t r a 4 . ..s 3.6 6 3/4.6 CONTAllMENT$YSTEM$

$URVtlLLANCE REQUIREMENTS (Continued) j 8" 3'M y Verifying that each unit operates for at least 15 minutes.,

! '" 3 '(* ""A h Verifying a cooline water flow rate of 12000 ges_to each_

coolina unitteen the full flow serTice wr evust valves 3 4re fully open.f t.6.3 s s. W 5 b. At least once per ttFU(LING IKittVAL by that each unit starts automat cally on the o t signal. '

s_

Q

e 4]* ' k 4 'yd

d 'h..

CALVERT CLIFF $ . UNIT 2 3/4 6 14 Amendment No. 189 l lf

DISCUSSION OF CHANGES SECTION 3.6.6 - CONTAINMENT SPRAY AND COOLING SYSTEMS ADMINISTRATIVE CHANGES A1 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 1;lant 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 descrite each 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 Specitications.

A.2 Current Technical Specifications 3.6.2.1 (Containment Spray System) and 3.t,.2.2 (Containment Cooling System) are being combined into a Containment Spray and Cooling Systems Specification (ITS 3.6.6). These Specifications were combined because both the l Containment Cooling and Containment Spray Systems' function is to relieve pressure and temperature in containment. Combining Technical Specifications constitutes an administrative change. This change is consi,unt with NUREG-1432.

A3 Current Technical Specification 3.6.2.1 Actions require the plant to shut down to Mode 5 when the Containment Spray train cannot be restored to Operable status, improved Technical Specification 3.6.6 Action B requires the plant to shut down to Mode 3 with pressurizer pressure < 1750 psia, nis change will relax the shutdown requirement from Mode 5 to Mode 3 with pressurizer pressure < 1750 psia, when a Containment Spray train cannot be restored to Operable status. This is an administrative change because, per LCO 3.0.1 and LCO 3.0.2, the LCO is required to be met during the Modes of Applicability, and if the LCO is no longer applicable, the Required Actions do not have to be completed.

The current Applicability for the Containment Spray System is Modes 1 and 2, and Mode 3 with pressurizer pressure 21750 psia. Therefore, the plant is only required to shut down to Mode 3 with piessurizer pressure < 1750 psia, although the Required Action requires the plant to shtr. down to Mode 5.

A.4 Current Technical Specifications 3.6.2.1 and 3.6.2.2 do not contain any requirements when two containment spray trains are inoperable, or when any combination of three trains of containrrrnt spray or containment cooling is inoperable. Herefore, the CTS would require that LCO 3.0.3 be entered. Improved Technical Specification 3.6.6 will contain an Action (Action F) to enter LCO 3.0.3 immediately. The addition of the Action is an administrative change because CTS requires the same Actions. This change is consistent with NUREG-1432.

A.5 Current Technical Specifications 4.6.2.1.c.1,4.6.2.1.c.2 and 4.6.2.2.b require verifying the containment spray valves actuate to their correct position and the containment spray ptimps and contaluraent cooling units start on an ESFAS test signal. Improved Technical Specification SRs 3.6.6.5,3.6.6.6, and 3.6.6.7 also require the containment spray valves and pumps, and containment cooling units, respectively, to perform as required, but it permits the verification to be conducted with an actual or simulated signal. Current Technical Specification 4.6.2.1.c.1,4.6.2.1.c.2, and 4.6.2.2.b have been revised to permit the test to be CALVERT CLIFFS - UNITS I & 2 3.6.6-1 Revision 7 I

DISCUSSION OF CIIANGES SECTION 3.6 6 - CONTAINf.IENT SPRAY AND COOLING SYSTEMS credited with an actual signal. Olym the ability to verify the components perform as required, an actual signal is equivalent to a simulated signal. This allowance is consistent with current plant practice, in the event an actual signa! xna and all the functions can be verified. This proposed change is consistent with NURL L W A6 Current Technical Specification 4.6.2.1.a.1 requires the verification that each valve (manual, power-operated, or automatic) in the flow path that is not locked, scaled, or otherwise secured in position is positioned to take suction from the RWT on a Containment Pressure -

lilgh test signal, improved Technical Specification SR 3.6.6.1 requires the verification that each containment spray manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position. Current Technical Specification 4.6.2.i.a.1 has been revised to reflect the wording ofITS SR 3.6.6.1.

The phrase "is positioned to take suction from the RWT on a Containment Pressure - High test signal" has been replaced wia the phrase "is in the correct position." These phrases are equivalent; each requires the applicable containment spray valves to be verified to be properly positioned to ensure that the containment spray system can accomplish its safety function, if required. This proposed change is an administrative change, which does not change the intent of the SR. This proposed change is consistent with NUREG 1432.

A.7 Current Technical Specification 4.6.2.1.b.1 requires verifying, at least once per 92 days, the containment sump isolation valves open and that a recirculation mode flow path via an i OPERABLE shutdown cooling heat exchanger is established, upon receipt of a Recirculation Actuation Test Signal improved Technical Specification 3.6.6 does not include an SR to verify, every 92 days, the containment sump isolation valves open and that a recirculation mode flow path via an OPERABLE shutdown cooling heat exchanger is established, upon receipt of a Recirculation Actuation Test Signal. This SR being deleted from CTS 3/4.6.2.

This proposed change is acceptable, because it is redundant to the requirement in CTS j SR 4.3.2.1.1 to perform a CHANNEL FUNCTIONAL TEST, at least once per 92 days, on each ESFAS instrumentation channel. This requirement has been retained as ITS SR 3.3.5.1.

As part of the CHANNEL FUNCTIONAL TEST of the actuation logic for the Recirculation Actuation Signal, the individual components will also be actuated. Thus, C~S 4.6.2.1.b.1 is encompassed by the CHANNEL FUNCTIONAL TEST for CTS SR 4.3.2,1,1. Deleting CTS 4.6.2.1.b.1 is an administrative change, because the testing will continued to be performed at the same freqvvey in accordance with ITS SR 3.3.5.1.

TECHNICAL CHANGES - MORE RNTRICTIVE M.1 Improved Technical Specifications SR 3.6.6.4 is not contained in CTS 3.6.2.1. Surveillance l Requirement 3.6.6.4 verifies that each containment spray pump developed head at the flow test point is greater than or equal to the required developed head in accordance with the Inservice Testing Program. Surveillam,e Requirement 3.6.6.4 is performed to provide l assurance that the containment spray pumps' overall performance is satisfactory by confirming onc point on the pump design curve. Adding an additional Sk to Technical l Specilications constitutes a more restrictive change. This change will not adversely affect plant safety because the added SR provides assurance that the Containment Spray System l will perform as required. This change is consistent with NUREG-1432.

M.2 Current Technical Specification 3.6.2.2 Actions require the plant to be in Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the Required Actions and associated Completion Times cannot be met, improved YAl, VERT CLIFFS - UNITS I & 2 3.6.6-2 Revision 7 i

DISCUSSION OF CHANGES SECTION 316 6 - CONTAINMENT SPRAY AND COOLING SYSTEMS restrictive movement of information change with no impact on safety. His change is consistent with NUREG 1432.

LA.4 Current Technical Specifications 4.6.2.1.c.1,4.6.2.1.c.2 and 4.6.2.2.b specifically list the test signal (Engineered Safety Features Actuation System (ESFAS)) that must be used to verify that the containment spray valves actuate to their correct position and the containment spray pumps and containment cooling units start. Improved Technical Specification SRs 3.6.6.5, 3.6.6.6, and 3.6.6.7 require the containment spray valves, containment spray pumps, and containment cooling units, respectively, to perform as required on an actual or simulated signal. The specific test signals will no longer be specified in the SRs. He test signals will be identified in the Bases for ITS SRs 3.6.6.5, 3.6.6.6, and 3.6.6.7. His is acceptable because these details do not impact the requirement to verify that the containment spray valves and pumps and the containment cooling units will perform as required. Rese details =

can be adequately controlled in the Bases which requires change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement for the containment spray valves and pumps and the containment cooling units to perform as required.

LA.5 Current Technical Specification 4.6.2.1.c requires verification that the containment spray nozzles are unobstructed by performing an air or smoke flow test through each spray header.

Improved Technical Specification SR 3.6.6.8 will not contain this specific information, ne requirement to use an air or smoke flow test through the spray header is being moved to Section B 3.6.6 of the ITS Bases. This is acceptable because these details do not impact the requirement to verify that the containment spray nozzles are unobstructed. These details can be adequately controlled in the Bases which require change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operations is unaffected by the change because there is no change in the requirement to verify that the containment spray nozzles are unobstructed. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This is a less restrictive movement of information change with no impact on safety, his change is consistent with NUREG-1432.

TECIINICAL CIIANGES . LESS RESTRICTIVE L.1 Not used.

l L2 Current Technical Specification 3.6.2.2 contains an Action which allows eight hours to restore one containment cooling unit to Operable status when three containment cooling units are inoperable. See discussion of Change M.3 for the case when one containment cooling unit in each train is inoperable. Improved Technical Specification 3.6.6 Action D allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore one containment cooling train to Operable status when both trains are inoperable (three containment cooling units inoperable in CTS is equivalent to two treins being inoperable in ITS). In both cases, two trains of containment spray must be Operable.

This change increases the Completion Time to restore I train to Operable status from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Increasing the Completion Time is reasonable because the 2 Operable trains of containment spray provide 100% of the heat removal capability. The remaining Operable CALVERT CLIFFS - UNITS 1 & 2 3.6.6-5 Revision 7

DISCUSSION OF CIIANGES SECTIAN 3 6.6 . CONTAINMENT SPRAY AND COOLING SYSTEMS containment cooling unit will also provide approximately 31% heat removal capability, nerefore, although single failure pmtection of the Containment Cooling System is not provided, the Containment Spray System is available, and the likelihood of an event occurring dur'mg the short period of time one train of containment cooling is allowed to be inoperable is small, increasing the Completion Times constitutes a less restrictive change.

Als change is consistent with NUREG 1432.

L.3 Current Technical Specification 3.6.2.2 does not contain Actions for the situation when all the containment cooling units are inoperable, nerefore, LCO 3.0.3 would have to entered.

improved Technical Specification 3.6.6 Action D allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore one containment cooling train (two containment cooling units in one train) to Operable status if both containment spray trains are Operable. His change will increase the Completion Time when both trains of containment cooling are inoperable from a shutdown track via LCO 3.0.3 to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months increasing the Completion Time is reasonable because the two Operable trains of containment spray provides 100% of the heat removal capability. Herefore, although a redundant Containment Cooling System is not available, the likelihood of an event occurring in the short period of time one train of containment cooling is inoperable is small, l

increasing the Completion Times constitutes a less restrictive change. His change is consistent with NUREG-1432 L.4 Not used.

l L.5 Current Technical Specification 4.6.2.1.d requires verification that the containment spray l nozzles are unobstructed once per five years, improved Technical Specification SR 3.6.6.8 requires the test to be performed every 10 years. This change will decrease the Frequency for verifying the containment spray nozzles are unobstructed from 5 years to 10 years. He decrease in the SR Frequency was recommended by the NRC in N'UREG-1366,

" Improvements to Technical Specliication Surveillance Requirements." An NRC scarch for problems involving the Containment Spray System while performing this test resulted in three problems being found. In all three cases the problem involved a construction error.

Also, the test gives no quantitative data on flow rates exiting the nozzles, it only verifies that there is flow. The NRC did not uncover any problems involving this flow verification.

Based on the above data, the NRC recommended that the SR Frequency be decreased from 5 years to 10 years. Also, analysis of specific Calvert Cliffs data did not reveal any past problems. This Frequency is also reasonable to detect obstruction because of the passive design of the nozzles. Decreasing Surveillance Frequency icquirements in the Technical Specifications constitutes a less restrictive change. This chenp- is consistent with NUREG-1432.

L.6 Current Technical Specification SR 4.6.2.2.a requires that testing be performed every 31 days on a Staggered Test Basis, improved Technical Specification 3.6.6 SRs will not require testing on a Staggered Test Basis. The Containment Cooling System consists of two trains. His change deletes the requirement to perform testing on a Staggered Test Basis.

This is acceptable because the tests on a non-staggered frequency will continue to prove the system performs as required. Just as other systems with two trains (low pressure safety injection, containment spray, etc.), the Containment Cooling System is tested by train with

- other components on the same train. Normally, different compone.nts on different trains are not tested on the same day. This is a good operating practice becaus it prevents components from opposite trains from becoming inoperab'e at the same time. This change makes the CALVERT CLIFFS - UNITS 1 & 2 3.6.6-6 Revision 7

DISCUSSION OF CILANGES SECTION 3.6 6 - CONTAINMENT SPRAY AND COOLING SYSTEMS containment cooling trains consister't with other engineered safety features trains in that Staggered Testing is not required, ne del 6 tion of requirements on SRs constitutes a less restrictive change. This change is consistent with NUREG 1432.

L.7 Current Technical Specification 4.6.2.1.c.1 requires the verification that each containment spray automatic valve in the flow path actuates to its correct position on the appropriate signal. Improved Technical Specification SR 3.6.6.5 also requires the verification that each containment spray automatic valve in the flow path actuates to its correct position on the appropriate signal; however, the ITS SR does not require containment spray automatic valves that are locked, sealed, or otherwise secured to be verified to actuate to their required position. Current Technical Specification 4.6.2.1.c.1 has been changed to include the exception regarding valves that are locked, scaled, or othenvise secured. His proposed change is acceptable, because the containment spray valves that are locked, scaled, or l otherwise secured in position are verified to be in their proper position prior to locking, i sealing, or securing. After locking, scaling, or securing, it v.ould take an intentional act to remove the lock, seal, or securing device prior to realigning the valve. Administrative controls are provided to assure that valves which are locked, scaled, or secured in position are not inadvertently realigned. Additionally, this proposed change is consistent with the requirements of a number of CTS SRs (e.g., 4.5.2.b.1,4.7.1.2.a.4,4.7.3.1.a,4.7.4.1.a, and 4.7.5.1.a) which do not require the position of valves that are locked, sealed, or otherwise secured in position to be verified.

CALVERT CLIFFS - UNITS I & 2 3.6.6-7 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 - CONTAINMENT SYSTEMS 3.6.6 Change L.3 1.

Does the change involve a sigr.lficant increase in the probability or consequences of an accident previously evaluated ?

He proposed change will add a t Action for the case when all the containment cooling trains are inoperable. He added Action will increase the Completion Time from immediately initiating a shutdown, to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the train to Operable status. This change will not significantly increase the probability of an accident previou>ly evaluated. He Containment Cooling System is not an initiator of any analyzed event, nis change will not significantly increase the consequences of an accident. He containment cooling capability is still 100% because two containment spray trains are Operable. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time limits the time the plant is in a condition in which it does not have a redundant Containment Cooling System. This change will not significantly afTect the assumptions relative to the mitigation of accidents or transients.

Herefore, the change does not involve a significant increase in the probability or conseqeence of an accident previously evaluated.

2.

Does the change create the psibility of a new or different kind of accident from any l accident previously evaluated 1 l

The proposed change will add an Action for the case when all the containment cooling trains are l

inoperable. He added Action will increase the Completion Time from immediately initiating a l

shutdown, to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the train to Operable status. His change does not involve 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. 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 the change involve a significant reduction in a margin of safety?

The proposed change will add an Action for the case when all the containment cooling trains are inoperable. The added Action will increase the Completion Time from immediately initiating a shutdown to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the train to Operable status. The margin of safety is not significantly affected because enough containment cooling capability exists to mitigate any accident heat load inside containment. The Completion Time will ensure that the time the plant is in a degraded Condition (without a redundant Containment Cooling System) is limited, while allowing enough time to restore one train of containment cooling to Operable status, in order to avoid the transient of a plant shutdawn. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

3.6.6 Change L4 Not used.

l 3.6.6 Change L5 1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change will decrease the Surveillance Frequency, to verify that the containment spray nozzles are unobstructed, from 5 years to 10 years. This change will not significantly increase the probability of an accident previously evaluated. The Containment Spray System is CALVERT CLIFFS - UNITS 1 & 2 3.6-17 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 - CONTAINMENT SYSTEMS 2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change will delete the requirement to perform Containment Cooling System SRs on a Staggered Test Basis. This change does not involve 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.

The proposed change will not introace any new accident initiators. nerefore, 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?

I The proposed change will delete the requirement to perform Containment Cooling System SRs on a Staggered Test Basis. The margin of safety is not significantly affected because the Sun'eiliance will still be performed on the same periodicity. Deleting the requirement to stagger the testing of the components provides more flexibility to perform the Surveillances with the same train engineered safety features equipment. Allowing the same train engineered safety features components to be tested during the same period prevents the opposite train components from becoming inoperable due to a failed Surveillance. Derefore, the proposed change does not involve a significant reduction in a margin of safety.

3ALl'hante L7 1.

Does the change involve a significant increase in the probability or consequences of an accident preu, uly evaluated?

The proposed change will add an allowance that containment spray automatic valves, which are locked, sealed, or othenvise secured in position do not have to be verified to actuate to their required position. This change will not significantly increase the probability of an accident previously evaluated. The containment spray automatic valves are not initiators of any analyzed event, nis change will not significantly increase the consequences of an accident. Plant administrative controls are in place to provide assurance that containment spray automatic valves which are verified locked, sealed, or otherwise secured in position will not be inadvertently realigned. Thus, the likelihood of a valve that was previously verified to be locked, sealed, or otherwise secured in position being inadvertently realigned is small. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients.

Therefore, the change 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 evaluated?

He proposed change will add an allowance that containment spray automatic valves, that are locked, sealed, or otherwise secured in position do not have to be verified to actuate to their required position. This change does not involve 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. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possibility of a new er different kind of accident from any accident previously evaluated.

CALVERT CLIFFS - UNITS I & 2 3.6-19 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS .

SECTION 3.6 - CONTAINMENT SYSTEMS

3. Does the change lavolve a significant redsetion la a amargin of safety?

De proposed change will add an allowance that containment spray automatic valves, that are locked, sealed, or otherwise secured in position do not have to be verified to actuate to their required position. The margin of safety is not significantly affected because plant administrative controls provide assurance that these valves will not be inadvertently realigned. Derefore, the proposed change does not involve a significant reduction in a margin of safety.

M.7 Ch===e L.1 1.

Does the change lavolve a significant increase la the probability or consequences of an accident previously evaluated?

De proposed change will increase the allowed outage time (AOT), when two hydrogen recombiners are inoperable from a required shutdown per LCO 3.0.3, to seven days, nis change will not significantly affect the probability of an accident previously evaluated. He hydrogen l recombiners are not initiators of any analyzed events. His change will not significantly increase -

l l

the consequences of an accident. He containment vent / hydrogen purge system is capable of maintaining hydrogen in containment to within limits. Also during the seven-day AOT, within one hour after both hydrogen recombiners are declared inoperable and seven days thereafter, the containment vent / hydrogen purge system murt be verified (by administrative means) to be capable of controlling hydrogen. Also, the seven days is reasonable because of the low i probability of the occurrence of a LOCA that_would generate hydrogen in amounts cap.sble of exceeding the flammability limits such that the system would be needed, nis change will not significantly affect the assumptions relative to the miti 3at:on of accidents or transients.

Herefore, the change 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 evaluated?

The proposed change will increase the AOT, when two hydrogen recombiners are inoperable from a required shutdown per LCO 3.0.3, to seven days. His change does not involve 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. 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 the change lavolve a significant redsetion la a margin of safety?

He proposed change will increase the AOT, when two hydrogen recombines are inoperable from a required shutdown per LCO 3.0.3, to seven days. The margin of safety is not significantly affected because the containment vent / hydrogen purge system is capable of controlling hydrogen below the required limit. This change may also prevent a shutdown which .

is a transient that causes stress on safety system components and can cause a plant upset.

Herefore, the proposed change does not involve a significant reduction in a margin of safety.

CALVERT CLIFFS - UNITS 1 & 2- 3.6-20 Revision 7

1 Containment Spray and Cooling Systems (t'n _p...;s

.viLve[~

3.6.

AgIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment D.1 Restore one 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

.f,.2.7 \ cooling trains containment cooling g y inoperable, train to OPERABLE status.

E. Required Action and E.1 3 6 ' ** t associated Completion Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A*f* *

, 'e l Time of Condition C 8151 or D not met.

E.2 Be in MODE . hours F. Two containment spray F.1 trains inoperable. Enter LC0 3.0.3. Inmediately II.4 6 4 4,4 E Any combination of three or more trains inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.[1 Verify each containment sp ay manual, ower 31 days operated, and automatic valve in the f ow (q 4,g, )'a,) path that is not locked, sealed, or h otherwise secured in position is in the correct position. fk (continued)

CEOG STS 3.6-18 Rev 1, 04/07/95

Containment Spray and Cooling Systems " :;b t u g

SURVEllLANCE REQUIREMENTS (continued)

SURVEILLANCE FRit)UENCY SR 3.6.dt .merate each containment cooling-train fan 31 days h (4.f,. 2.. t. g,g unit for 2 15 minutes.

SR 3.6.d3 31 days b Verify each containment coolig' train 6.u.2... p :::17an"g tel'." " *d ").La" **

r SR 3. 6A.4 Verify the con inment spray piping is 31 days _f full of wate to the (100] ft level i containeen spray header.

he V -

ox A SR 3.6.6% Merify each containment spray otaM in accordance gy p. 7e r ur o - r ce Testing Program SR 3.6. Verify each automatic containment s ray months valve in the flow path that is not ocked.

/ sealed, or othentise secured in position,

$ 4 M.I, c. I>

actuates to the correct position on an actual or simulated actuatten signal, SR 3.6. Verify each containment spray pump starts months cTEKD automatically on an actual or simulated (4. f., 2. l. b. t actuattca signal.

A SR 3.6.Sf Verify each containment cooling train axnD months starts automatically on an actual or

2. 2 . simulated actuation signal.

(continued)

CEOG STS 3.6-19 Rev1,04/07/95

$8"I*Fsd h.el d 4fJ Pha deTi p4d 'ti ge< der A . c , p d -b & r' b'"* J A , u he. 9 k,. cl

Containment Spray and Cooling Systems (AladispherYand SURVilllMCE REOUIREMENTS (continued)

SOAVElltMCE FREQUENCY t

SR 3.6. -

-7 Verify each spray nozzle is unobstructed.

Db l At ff t / .

refu ing k4.lo.t.I.0} \

! 10 years k

CEOG STS 3.6-20 Rev 1, 04/07/95 l

1 Containment Spray and Cooling Systems n ' h - " " h"ali O

83.6 7

, BASES SURVE!LLANCE SR 3.6. 3 (continued)

REQUIREMENTS l redundancy, and the low probability of a significant degradation of flow occurring between surveillances.

SR 3!6.6A.4 Ver fying that the contal t spr ft1velminh12esthetimeheader trod piping is full toffillwater to the [100)This ensures that spray the header. 11 be flow 4

itted to the contal nt atmosphere within th tee frame ssumed in the contal nt analysis. The 31 da frequency is based on the static ature of the fill head and the low probability of a sign 'tcant degradation of ter level in

_ the piping occurrin tween surveillances.

J SR 3.6.

em g.n.J .+

O Gu Mit/p.id Jr Verifyingthateachcontainmentspraygumpdeve s (t UHFD} os16 difWrentiaFpressps on recirc tion ensures o

$ r,../cf /b ,, ,6 . /Mo that s 'F"STI' 78 cycle. pray pump performance nas not vegraded during theFlow and diffe 4 e U,;,,! ,Jr'.,)/,, ] centrifugal pump perfomance required by Section XI of the me I ASME Code (Ref. 6). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the performance. pump design curve and is indicative of overall Such inservice ins OPERABILITY, trend performance, andpections confim component detect incipient failures by indicating abnormal performance. The frequency of this SR is in accordance with the Inservice Testing Program.

SR 3.6. I and SR 3.6.

g hi. e*2 b ~nWrinfc] These SRs verify that each automatic containment spray valve 6gteeeedL%Fhres< j actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated Ackb f 5he1 (E5FAs}>N actuation stonala This Surveillance is not required for A

'

PN 3

~

valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The

@ JJ-\

nth Frequency is based on the need to perfom these 4

urveillances under the conditions that apply during a plant g (continued)

CEOG STS B 3.6-52 Rev1,04/07/g5 1

t Containment Spray and Cooling Systems {^' @

"-t =dBOn@"3.6.

BASES SURVEILLANCE SR 3.6. ad SR 3.8.

REQUIREMENTS (continued) .

1 outage and the potential for an unplanned transient if the Survelliances were perfomed with the reactor at power.

Operating experience has shown that these com nts usually

pass the Surveillances when performed at the< inonth Frequenc . Therefore the frequency was conc accept afromarolgabilitystandpoint. i to be g The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements.

SR 3.6.s (is.., M optytk h.

gg gg g3 0 A This SR verifies that . u: containment cooling train actuatas upo igr.J The pt oi un actual or staulated actuation g

judgment and nth Frequency is based on engineering been shown to be acceptable through#

operating experience. See SR 3.6.66F.6 and SR 3.6.46i7, h i

, for further discussion of the basis for the month Fr quency.

SR 3.6.sh.@

With the containment spray inlet valves closed and the spray gj,1' p[f' header drained of any solution. low pressure air or smoke can be t, lown tnrough n=a-~ ann. Performance of this p

,/,u, d.5 - SR demonstrates that eitch spray nozzle is unobstructed and provides assurance that spray covera during an accident is not degraded. ge of to Due thethe containment nassive design of the nozzle, a test at (the f' es' refueling andAtD 10 year intervals is considered ace 1 obstruction of the spray nozzles. quai.e ".o detect REFERENCES 1. 5 Ap x A. GDC 3)(GDC 39, GDCgGDC 41,

,, gg,,, gg urue% .#.> f c @

3.@SAR, asemy. *W7 @@

ekk f,.

(continued)

CEOG STS B 3.6-53 Rev 1,'04/07/95

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 hlarkup 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)

I

Containment Spray and Cooling Systems B 3.6.6 BASES position prior to being secured. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR does not require any testire or valve manipulation. Rather, it involves verifying, through a system walkdown, that those valves outside containment and capable of potentially being mispositioned are in the correct position.

SR 3.6.6.2 Starting each containment cooling train fan unit from the Control Room and operating it for 215 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected and corrective action taken. The 31 day Frequency of this SR was developed considering the known reliability of the fan units and controls, the two train redund acy available, and the low probability of a significant deu adation of the containment cooling train occurring between surveillances and has been shown to be acceptable through operating experience.

SR 3.6.6.3 Verifying a service water flow rate of 2 2000 gpm to each cooling unit when the full flow service water outlet valves are fully open provides assurance that the design flow rate 7 assumedinthesafetyanalyseswillbeachieved(Ref.2).

Also considered in selecting this Frequency were the known reliability of the Cooling Water System, the two train redundancy, and the low probability of a significant degradation of flow occurring between surveillances.

CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-9 Revision #7

DISCUSSION OF CIIANGES SECTION 3.6.6 - CONTAINMENT SPRAY AND COOLING SYSTEMS TECHNICAL CilANGES - MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED DOCUMENTS LA.1 Current Technical Specification 3.6.2.1 LCO states that the Containment Spray System shall be Operable with each spray system cyable of taking suction from the refueling water tank on a Containment Spray Actuation Signal and Safety injection Actuation Signal, and automatically transferring suction to the containment sump on a Recirculation Actuation Signal (RAS), and that the flow path from the containment sump shall be via an Operable shutdown cooling heat exchanger, improved Technical Specification 3.6.6 requires the Containment Spray System to be Operable, but does not contain the details that are in the CTS. These details are being moved to Section D 3.6.6 of the ITS Bases. This is acceptable because these details do not impact the requirement to verify that the Containment Spray System is Operable. These details can be adequately controlled in the Bases which require change control in accordance with 1, .:s Control Program in ITS Section 5.0. His approach provides an efTective level of regulatory ,ontrol and provides for a more appropriate change control process.

The level of safety of facility operations is unaffected by the change because there is no change in the requirement for the Containment Spray System to be Operable. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. His is a less restrictive movement of information chaage with no impact on safety. This change is consistent with NUREG-1432.

l LA.2 Current Technical Specification 4.6.2.2.a.1 requires that the containment air recirculation and cooling units be started from the Control Room. Improved Technical Specification SR 3.6.6.2 will not contain this requirement. This requirement will be moved to Bases Section SR 3.6.6.2 of the ITS Bases. This is acceptable because this requirement does not impact the requirement to verify that the containment air recirculation and cooling units will remove heat from containment. This detail can be adequately controlled in the Bases which require change control in ac,:ordance with Bases Control Program in ITS Sec. ion 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 to verify the containment air recirculation and cooling units are Operable. Furthermore, NRC and Calvert Cliffs resources associated wi*h processing license amendments to these requirements will be reduced. This is a less restrictive movement ofinformation change with no impact on safety, his change is consistent with NUREG-1432.

LA.3 Current Technical Specification 4.6.2.2.b requires verifying cooling water flow when the flow service water outlet valves are fully open. Improved Technical Specification SR 3.6.6.3 will not contain this requirement. This reautrement will be moved to the Bases. This is l acceptable because Technical Specificate should only contain specific requirements (i.e., to verify flow is a certain gpm). As long as the flow requirements are met, Technical Specifications should not specify valve position. The Bases ofITS SR 3.6.6.3 will include the requirement to conduct the SR when the full flow service water outlet valves are fully open. The Bases will be maintained in accordance with the Bases Control Program in ITS Section 5.0. This approach provides an effective level of control and a more appropriate change control process. He level of safety of facility operations is unaffected by the change tacause there is no change in the requirement to verify that the flow to each coohng unit meets the acceptance criteria. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This is a less l

CALVERT CLIFFS - UNITS 1 & 2 3.6.6-4 Revision 7

Containmot Spray and Cooling @

B 3.6.Systems (=:; Lib .., 0.

BASES ACTIONS L1 (coStinued) outside immediately.

entered the accident analysis. Therefore, LC0 3.0.3 must be SURVEILLANCE SR 3.6. 1 REQUIREMENTS Q

Verifying the correct alignment for sanval, power operated, and automatic valves in the containment spray flow path Containment Spray System operation.provides assurance that the proper flo to valves that are locked This SR does not apply position since these were, verified to be in the correctsealed, or otherwise sec position prior to being secured.

This SR also daes not apply to valves that cannot be inadvertently misaligned, such as check valves.

or valve manipulation.. Thth SR does not require any testing through a system walkdown, that those valves outsideRather, it involves verify containment are and capable in the correct of potentially being mispositioned position.

SR 3.6 2 g,,4; edrAt' G@

)each Containment Cooling train fan Unit for h

all15 m:nutes associated ensures controls that all trains are functioning are OPERABLE and that properly, ensures that blockage, fan or motor failure, or excessive it also r

! vibration can be detected and corrective action The taken.

31 day frequency _of this SR was developed considering the i

l known reliability of the fan units and controls the two train redundancy available, and the low probab1Itty of a significant degradation of the containment cooling train occurring between surveillances and has been shown to be acceptable through operating experience.

SR 3.6.6 dek *Q*b I Verifying a service water flow rate of 2 200 coolina uni provides assurance that the esignfpmtoeach seNief wedet owflet !

g\qes are Q assumed n 1 ej, peg Als'o considered in selecting this Frequenche low rate were the known h h '1 will be achieved safety analyses reliability of the Cooling Water System, t e two train (continued)

CEOG STS B 3.6-51 Rev 1, 04/07/g5

19, The NRC requested: 1) the Completion Time provided for Required Action D.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 D.2 ofISTS LCO 3,6.6A requires a shutdown to hiode 5; and 2) requested the deletion of a reference to a Note 5 in JFD 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 in Mode 3 with pressurizer pressure < 1750 psia within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in the event the Containment Spray System is inoperable and cannot be restored within the specined Completion Time. The proposed change was justined by DOC M.5 for ITS 3.6.6; 2) DOC L 1 for ITS 3.6.6 and its associated NSilC 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in the event the Containment Spray System is inoperable and cannot be restored within the specined Completion Time. JFD 6 was revised to provide justi0 cation for this proposed deviation; 4) the ISTS Bases Markup for Required Action B.2 for ITS 3.6.6 was revised to be l consistent with the revised ITS; and 5) JFD 6 for ITS 3.6.6 was revised to delete the reference to Note S. In addition, the use of the Note to modify the Mode 3 Applicability was changed to add i the modi 0 cation into the Applicability, consistent with the manner in which this issue is handled

! in ITS 3.5.2. Justi0 cation for Deviation 6 was modified to reDect 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 guide. This required changes to the ISTS Markup for ITS 3.6.6 and ISTS Bases Markup for ITS 3.6.6.

Containment Spray and Cooling Systems 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems LC0 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

MODE 3, except Containment Spray is not required to be 7 OPERABLE when pressurizer pressure is < 1750 psia.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable. spray train to OPERABLE status. 68D 10 days from discovery of failure to meet the LC0 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A AND not met.

B.2 Be in MODE 3 with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7 pressurizer pressure

< 1750 psia.

CALVERT CLIFFS - UNITS 1 & 2 3.6.6-1 Revisiong7

Containment Spray and Cooling Systems B 3.6.6 BASES LCO During a DBA, a minimum of one containment cooling train (3 of the 4 coolers) and one containment spray train is 7 required to maintain the containment peak pressure and temperaturebelowthedesignlimits(Ref.3). Additionally, one containment spray train is also required to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analysis.

To ensure that these requirements are met, two containment spray trains and two containment cooling trains (all four

! coolers) must be OPERABLE. Therefore, in the event of an accident, the minimum requirements are met, assuming that the worst case single active failure occurs.

Each Containment Spray System includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWT upon an ESF actuation signal and automatically transferring suction to the containment sump. Each spray system flow path from the containment sump will be via an 7 OPERABLE shutdown cooling heat exchanger. I Each Containment Cooling System includes cooling coils, dampers, fans, instruments, and controls to ensure an OPERABLE flow path.

APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment spray trains and containment cooling trains.

The containment spray system is only required to be OPERABLE 7 in MODE 3 with pressurizer pressure 21750 psia.

In MODE 3 with pressurizer pressure < 1750 psia, and MODES 4, 5, and 6 the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Thus, the Containment Spray CALVERT CLIFFS - UNITS l'& 2 B 3.6.6-5 Revision # 7 m - -

Containment Spray and Cooling Systems B 3.6.6 BASES' System is not required to be OPERABLE in MODE 3 with pressurizer pressure < 1760 psia, and the Containment Spray and Cooling Systems are not required to be OPERABLE in MODES 4, 5, and 6.

ACTIONS A.1 With one containment spray train inoperable, the inoperable containment spray train must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months '

Completion Time takes into account the redundant heat removal capability afforded by the Containment Spray System, reasonable time for repairs, and the low probability of a DBA occurring during this period, n.

The 10 day portion of the Completion Time for Required Action A.1 is based upon engineering judgment. It takes into account the low probability of coincident entry into two Conditions in this Specification coupled with the low probability of an accident occurring during this time.

Refer to Section 1.3, " Completion Times," for a more detailed discussion of the purpose of the "from discovery of failure to meet the LC0" portion of the Completion Time.

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status 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 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE-3 with pressurizer pressure < 1750 psia within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . .The 7 allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-6 Revisiong'?

S pc.G. b 3.4.G

3. G 4/44 f0NTAIMMENT $YSTEMS

3. G .G 4/ * @!wssupml0N)AND COOLING SYSTEMS QontainmentS @ _

LIMITING CONDI N FOR OPERATI M 5

[ ce __

tco g 4 0.6.2.1i.Two independent Containment Spra[GTUEis)shall be OPERABLEpithT

. m em capable of tan lmu6n Spray aumon Trve Ine Kwi on a con mment ation Signal and Safet njection Actuation Signal an automa cally transferrin ._.

Rect ulation Actuation $g1gn suc on to the containment sump on / 4.

to inment sumo shall be v Each spray system flow path rom the an ortnAntt thutdawn enelino eatexchancery APPLIEABILITY: MODES 1, 2. and 3*.

4A i dets N Agw A :

With one Containment Spray System inoperable, restore the Ass uese, .F W M.4 noperable spray system to CPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sFo'r De In+. a= m- -A> ^& - tc0 AwB Gkovinom hours,least NOT STAND 8Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in(Egk. SupuowM)within @)

gug, -

@ g SURVEILIM pI;m.go N.M utnumMuus ch Containmen

~

_e pray System s 11 be_ demo ted OPERABLE:

At less o r 31 days : M**

/

~_ e ed-/o 3 N /dec '

% Ver ying that upon .

/ t to nment'stp rculannv Actua.rior)

VWveswpm a Test S nal . -

~ ea ationafoef reb ana- er ;ab shed#

ow p n vu'an UPE tna shut wn n.

.T]b J/

. Verifyin t each ralve hrlanual, power-ope ted, or

/ \ m4.A,4 ur<. e automati ""'^

in the f1 otherwis secured in )w pap that is not lo ed, sealed or i g

potftfo )/

nn ww ntb* y n as natitionst!In +

o- g. aam onnake_ syt o .

/ + lts e ~o nt c tkr .Lnya b s . / Jsignal. M]a; [,/N @ b 1

e' e annuiTA , diT ng shutdo Verifying that y[ g to its correc ch automatic valyt in the flow pat / actuates gh. Ad ositioncon im aanecroriate mmpmsignal,

[3L., Verifying t at each spray p f

( /

est sig 1. starts automati 11y on @

/ t yrvarete / tag \ on an ,

N / \

[ \ er 5,;,,Jh.D M t

< c A,4 A7 .old,)

i e

With pressurizer pressure t 1750 psia. d5MSGT St it. . 2.l,cD DM- p CALVERT CLIFFS - UNIT 1 Lt2 3/4 6 15 Amendment No. 212 l lie <*u. dd 218

/f b

6,94tnE O ch 3.4.fo

3. fe @ CONTAINMENT SYSTEMS 3,f ,y @ hrmmun.wM10MpNDCOOLING$Y$ TEM 1 (Containment SoraMiirniiri LIMITING CONDITIM FOR OPERATIM /[r'.; [U .ak bajib t.c c) 2.1,.6 O Two independent Containment Spray GtT"azh I shall be OPERABLE %ih

m. m spra system capsoie or sau n cu vn u .=> 6 us nw i un a w sTnment Spray Ac ation Signal and Safety ection Actuation Signal a nutoma cally transferring sucti to the containment sump on .

( A Recir lation Actuation Signal. Each spray system flow pat rom the to inment sumo shall be via n DPreamer shutdon coolino eat errhanner A

= 7_=k APPLICABILITY: MODES 1, 2 and 3*.

'Oe yj g gy,, A _($1d' !is With one Containment Spray System it. operable, restore the t

efs #

Mnoperable spray cystem to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 7br be in at gy,, g east NOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and ingDe snurouwn1within @

oWowint 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months . --

j

($^Is 45D[_.3.fo.(,.& -~-

$URVEILLANCE REQUIRfMLnIn -

I . Each W ainme Spray System sh nstrated OPE LE:

a. At least / '

ce per 31 days by://- ' "'l J

! 1.

/_

l Ver ying that upon acre #tculati6n ActuaMon)fest Signa . L t co s uinen 6 s osa qvalves open va Enst at ect lation mo

/

he . exchanger i w

bl v1r arDP_ERABW shv(down copsrn eds -

g g' b cbdu do Verifying)that ch v ve(manual,po r. operated, or % s.<r.d automatic in e f1 path tha_t is t locked, sea d,or 3. gin e o herwise s red position OsAD51tionec to take aucuort b ',j, y , g

_ _l ne run on a/ontai nmMt 4'E N _ 'W %W.a/w W Kh kr1W Preim0re.HicVles(signa) '

a /

on an

@ At least or)fe per RLtu!,UNG INTER , during shutdown, b u.bl *e N s;nJA A

/ 1. Veri ying that each automa c valve in the flow p actuates to ts correct position mee apprmriste sarnesignal.

k erifying that each s y pump starts automa 11y on @

gpppoprisse urioAtttJ gsignal. g,4

= -

5t)$CE,T If Mihl M d* h With pressurizer pressure t 1750 psia.

[tod % 4faZIk f (1.5 h CALVERT CLIFFS - UNIT 2 3/4 6-11 Amendment ho. 189 d Lt't ku. NVQ IY f l s

DISCUSSION OF CHANGES SECTION 3.6.6 e CONTAINMENT SPRAY AND COOLING SYSTEMS Technical Specification 3.6.6 will require the plant to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , his change will add a requirement to be in Mode 3 at a certain period of time during the shutdown to Mode 4. He addition of this step is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner, and without challenging plant systems placing a time requirement to be in Mode 3 during a shutdown is a more restrictive change. His change will not adversely affect plant safety because the intermediate step requires the plant to cooldown in an orderly manner.

His change is consistent with NUREG 1432.

M.3 Current Technical Specification 3.6.2.2 Actions allow seven days to restore one containment cooling train to Operabb status when one cooling unit in each train is inoperable. See discussion of Change L2 for the case when three containment cooling units are inoperable, and the train with one unit inoperable is being restored. Improved Technical Specification 3.6.6 will allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore one containment cooling train to Operable status. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months take into account the degraded condition of the heat removal capability.

Although greater than 100% of the heat removal capability exists, protection against a single failure is not available, therefore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is reasonable. His is consister with Emergency Core Cooling System requirements which allow one train to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months as long as there is 100% flow available. Decreasing the Completion Time for a Required Action constitutes a more restrictive change. This change will have no adverse impact on safety because the 72 hotts limits the time the heat removal capability is in a degraded condition. This change is consistent with NUREG-1432, M.4 Improved Technical Specification 3.6.6 Actions A and C contain a limit on the total combined duration of operation for one containment spray train inoperable (Action A), and j one containment cooling train inoperable (Action C), of 10 days. This will prevent continuous operation in a degraded condition by entering the two Actions repeatedly.

Current Technical Specifications 3.6.2.1 and 3.6.2.2 Actions (Containment Spray and Containment Cooling Technical Specifications, respectively) do not contain this limitation.

Also, each of these requirements are contained in separate LCOs The combination of these two Specifications warranted this limitation, nerefore, the addition of this limitation is a more restrictive change. This change does not affect plant safety because it prevents operation in a degraded electrical condition for an inappropriately long period. This change is consistent with NUREG-1432, M.5 in the event the Containment Spray System is inoperable and cannot be restored within the specified time, the Action for CTS 3.6.2.1 requires the plant to be placed in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and outside the Mode of Applicability within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Action B ofITS 3.6.6 will require the plant to be placed in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and outside the Mode of Applicability (i.e., Mode 3 with pressurizer pressure < 1750 psia) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , This proposed change is a mort. restrictive change, because only 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is permitted to place the plant outside the Mode of Applicability, ne proposed change is acceptable, because the 12-hour period permits the plant to be placed in Mode 3 with pressurizer pressure < 1750 psia in a controlled manner.

TECHNICAL CHANGES - RELOCATIONS None CALVERT CLIFFS - UNITS 1 & 2 3.6.6-3 Revision 7 J

DISCUSSION OF CHANGES SECTION 3 6.6 - CONTAINMENT SPRAY AND COOLING SYSTEMS restrictive movement of information change with no impact on safety. His change is consistent with NUREG 1432.

LA.4 Current Technical Specifications 4.6.2.1.c.1,4.6.2.1.c.2 and 4.6.2.2.b specifically list the test signal (Engineered Safety Features Actuation System (ESFAS)) that must be used to verify that the containment spray valves actuate to their correct position and the containment spray pumps and containment cooling units start. Improved Technical Specification SRs 3.6.6.5,

.'8.6.6.6, and 3.6.6.7 require the containment spray valves, containment spray pumps, and centainment cooling units, respectively, to perform as required on an actual or simulated signal. The specific test signals will no longer be specified in the SRs. He test signals will be identified in the Bases for ITS SRs 3.6.6.5, 3.6.6.6, and 3.6.6.7. His is acceptable because these details do not impact the requirement to verify that the containment spray valves and pumps and the containment cooling units will perform as required. These details can be adequately controlled in the Bases which requires change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the l

requirement for the containment spray valves and pumps and the containment cooling units to perform as required.

LA.5 Current Technical Specification 4.6.2.1.c requires verification that the containment spray noules are unobstructed by performing an air or smoke flow test through each spray header, improved Technical Specification SR 3.6.6.8 will not contain this specific information. The requirement to use an air or smoke flow test through the spray header is being moved to Section B 3.6.6 of the ITS Bases. This is acceptable because these details do not impact the requirement to verify that the containment spray nozzles are unobstructed. These details can be adequately controlled in the Bases which require change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operations is unaffected by the change because there is no change in the requirement to verify that the containment spray nozzles are unobstructed. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these !

requirements will be reduced, his is a less restrictive movement of information change with no impact on safety. This change is consistent with NUREG 1432.

TECHNICAL CHANGES - LFSS RESTRICTIVE L.1 Not used.

l L.2 Current Technical Specification 3.6.2.2 contains an Action which allows eight hours to restore one containment cooling unit to Operable status when three containment cooling units are inoperable. See discussion of Change M.3 for the case when one containment cooling unit in each train is inoperable. Improved Technical Specification 3.6.6 Action D allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore one containment cooling train to Operable status when both trains are inoperable (three containment cooling units inoperable in CTS is equivalent to two trains being inoperable in ITS). In both cases, two trains of containment spray must be Operable.

This change increases the Completion Time to restore I train to Operable status from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Increasing the Completion Time is reasonable because the 2 Operable trains of containment spr y provide 100% of the heat removal capability, ne remaining Operable CALVERT CLIFFS - UNITS 1 & 2 3.6.6-5 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECI' ION 3.6 - CONTAINMENT SYSTEMS Since the compensatory boundary is capable of essentially meeting the same criteria of a single active failure proof boundary, the change does not involve a significant reduction in the margin of safety.

M.6 Chanee L1 Not used.

l M.6 Chanoe L2 1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

He proposed change increases the Completion Time to restore one containment cooling train to Operable status from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when three containment cooling units are inoperable.

This change wi'l not significantly increase the probability of an accident previously evaluated.

The Containment Cooling System is not an initiator of any analyzed event. This change will not significantly increase the consequences of an accident. The containment cooling capability is still over 100% because :wo containment spray trains and one containment cooling unit are Operable. The 72-hour Completion Time limits the time the plant is in a condition in which it does not have a redundant Containment Cooling System, nis change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change does not involve a significant increase in the probability or consequence of an accident previously evaluated.

l 2.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change increases the Completion Time to restore one containment cooling train to Operable status from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 Murs when three containment cooling units are inoperable. '

This change does not involve a significant change in the design or operation of the plant. No hardware is being a aded to the plant as part of the proposed chr.nge. He 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 the change involve a significant reduction in a margin of safety?

The proposed change increases the Completion Time to restore one containment cooling train to Operable status from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when three containment cooling u its are inoperable.

De margin of safety is nt significantly affected because enough containment cooling capability exists to mitigate any ceident heat load inside containment. The Completion Time will ensure that the time the plant is in a degraded Condition (without a redundant Containment Cooling System) is limited while allowing enough time to restore one train of containment cooling to Operable status in order to avoid the transient of a plant shutdown. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

CALVERT CLIFFS - UNITS 1 & 2 3.6-16 Revision 7

Containment Spray and Cooling Systems OchosphMe and thr(1) .

3 6.@

3.6 C0dTAllMENT SYSTEMS 3.6.E$) Containment Spray and Cooling Systems [(MhospVic and AGa19 -

Ucpean taxen for soaine removaypy the conwruent spray 5Aten)) _

b M'I 1 b'2' LCO 3.6.6%

Twocontainmentsbtrainsandtwocontainmentcooling trains sha11 be O lE.

od APPLICABILITY: MODES h 2,[yti)(A.d)Q - - -

ACTIONS ructi5, exce + CahevA Secq is d repiced % he.

ogB f_ Au pasmeker pmung, s. ; tw p s ia, k

m v. - _

CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable, spray train to 3.6. 2. l OPERABLE status.

Acres 682 10 days from discovery of failure to meet the LCO i

B. Required Action and B.1 Be in MODE 3.

associated Ccmpletion 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3'4 2 3 -

lar~s Time of Condition A not met.

MQ 3 A ru'eur t'md U

B.2 d l? 2 t*L / [

Be in MCOE /s hours") k l

C. One containment C.1 cooling train Restore containment 7 days inoperable.

cooling train to g,g OPERABLE status. MQ A"

10 days from discovery of failure to meet the LCO (continued)

CEOG STS 3.6-17 Rev 1, 04/07/95 l

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.6 - CONTAINMENT SYSTEMS PLANT-SPECIFIC CHANGES

1. This change deletes the terms Atmospheric and Dual in parentheses. These terms were placed in the NUREG-1432 titles to inform the users that the Specification is for atmospheric and dual containment plants. These informational terms are not required for the Calvert Cliffs improved Technical Specifications (ITS). Calvert Cliffs has an Atmospheric containment and will adopt the applicable Specifications. This change also applies to the deletion of NUREG-1432 Specifications that do not apply to Calvert Cliffs, and any designations in the titles that relate (e.g.,3.6.6B Containment Spray and Cooling (credit not taken for lodine removal) was deleted).

2. De change to the non-bracketed system name, nurAer of systems / components, terminology, or value was changed to be consistent with Calvert Cliffs-specific system name, number of systems / components, terminology, or values. His change also includes any numbering changes due to the addition or deletion of Specifications, Actions, or Surveillance Requirements (SRs).

3. His change deletes all of SRs and Actions related to the containment purge isolation valves.

Requirements for the containment purge isolation valves will be located in Section 5.5.16,

" Containment Leakage Rate Testing Program" for Unit I and bection 3.9, " Refueling Operations," for Units I and 2. The requirements for the Unit 2 containment purge isolation valves in Modes 1,2,3, and 4 will be deleted. Calvert Cliffs submitted a license amendment which deleted all requirements for the purge valves because the valves are being blind flanged in Modes 1,2,3, and 4, which eliminates the need for a containment isolation valve for this penetration. His change is consistent with the proposed Technical Specification change submitted from Mr. C. II. Cruse (Baltimore Gas and Electric Company) to NRC Document Control Desk, dated August 1,1996, License Amendment Request, Use of Blind Flange in Place of Containment Purge Valves During Operations. This request was approved in License Amendment No.197 for Facility Operating License No. DPR 69.

4. A Note was added to Specification 3.6.3 Limiting Condition for Operation Notes which allow the shutdown cooling (SDC) isolation valves to be opened when Reactor Coolant System temperature is < 300'F to establish SDC flow. The Note was added to allow SDC to be established in Mode 4 when Reactor Coolant System temperature is < 300'F, which is contradictory to Note I which only requires penetrations to be opened intermittently. His change is required to enable Calvert Cliffs to establish SDC and is consistent with the Calvert Cliffs current licensing basis.

5. These changes incorporate Calvert Cliffs-specific information into brackets. Bracketed information located throug.uut NUREG-1432 will be replaced with the specific Calvert '

Cliffs requirements. This change also includes deleting bracketed items when it is not consistent with the Calvert Cliffs design.

6. The Applicability Section ofITS LCO 3.6.6 was modified to require the Containment Spray System to only be operable in Mode 3 when the pressurizer pressure is 21750 psia. This proposed deviation is consistent w;th Footnote

to the Applicability Section for CTS LCO 3.6.2.1. In conjunction with this change, the requirement in Required Action B.2 was changed from "Be in MODE 5" to "Be in MODE 3 with pressurizer pressure < 1750 psia."

This proposed change would place the unit in a condition for which ITS LCO 3.6.6 does not CALVERT CLIFFS UNITS 1 & 2 3.6-1 Revision 7

Centainneet Spray and Cooling Systems Cz:f:t M M" g3.6.$ 1 Salt $ (continued)

(!+f v 4 4 o.ler.t) 8 (C0 -

GDN oering a a A. a minimum .f@contati ent steung tint@'

containment spray trat 2e@

08 A a is required to heh5 [allbe ceolets)J en stain the containment seaa == c ans r == W the design limits (Aef. sp. Ass stonsuy. one consainmentau m

^

spray train is aise regdired to remove iodine from the.

\,d/

Crisprog536tenM- containment staesphere and meintain concentrattens below p A 4em et enbfd these assumed in the safety analysis. To ensure that these requirements are met Sq WW be vk. nw OP61LMLEishiddoton y

y a noen g i a nd t per,t an s ,,thenintamregulrementsaremet ~eOJ '

cootlghead enkget*, assains that the worst case sir.ile active failure occurs.. I tech Containment Spra pump, spray headers, y System nogales valves adsricansincludes l iples instruments, a spray and controls to ouvre an OpkAABLE flev patli,tapable of taking suction from the Rift upon an (SF actuetten si nal and h( .5p reAotC 3

g,uJ fr"1 4 hin4 ad [.

automatically transferring suction to the containmen! sumpg) ch Ci .ainment Coeling lystemGWIenFh) includes

@ g coeltos coils d rs, ran instruments, and

' ([- '4 ( ,,g

, 4 nstram s.,Nr c eensureenOpkRAtt flowpetg. g

%?s. == ~ m AppLICAalLITY In M00t$ 1 d a/DBA ould cause a release of radioactive 2riamate to contal nt and an increase in '

g C* *g"I'"^*

C containment pressure and tempera ure, requiring the operation of the containment spr trains and containment SPt*$ sydee is ewig cooling trains, regMeed to be oppnad -ar g mg 3 gg i M00tsbnd6 he probablitty md consequences of these Pressacher pressure nts arrreduced due to the eres fure and temperature 31770 psio . limitations of these Moots. Thus Containa nt Cooling systems are no.vthe t requiredContainment to be OPERA spray 8LE and in=Egnd4. ,3 .

ACTIONS L.1

' MOM 1 "'M With one containment spray train inoperable, the inoperable containment spra p<tswriur preu,e within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .y train must In this be restored Cendition, to OPERABLE the remaintne status OptAABLE spray and cooling trains are adeouste to perfers the iodine (l'l$0pgDQ removal and containment cooling functions. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into accour.t the redundant heat (continued)

Ct0G $15 t 3.5-48 Rev 1. 04/07/95 s-

i 1

fontainment spray and Cooling Systems ( "--" " "i B3.6.68 @

BA![$

ACTION $

&J (continued) reasonabletemoval u

capablitty afforded by the Contairnent Soray Systee, DBA occurring during this p;,rlod.ne for repairs and tb low Wobability of a The 10 day portion of the Completion Time for Required Action A.1 is based upon engineering judgment. It takes into account the low probablitty of coincident entry into two Conditions in this Jpecit station coupled titth the low probability of an accident occurrtoe during this time.

Refer i to section 1.3 ' Completion limes.' for a more

tt 116d discussion o.f the purpose of the ' free discovery of u ilure to meet the LC0' portion of the Completion Time.

B.1 and B.2 I

If the inoperable containment spray train cannot be restored to OPERABLE statJs within the required Completion Time Motas 3 .J M Em r e, plant acol v.must be brought to a MODE in which the LCO does n,otthe s

a To achieve this status, the 11 st be brought to leatt MODE 3 witnin o nours una tF i within P' m ore 4 /750 , hours. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating expertence, to reach MODE 3

(; h '4G A from full th power conditions in an orderly manner and without nging plant systems.

/2. The extended interval to reach allows additional time for the restoration of the containment spray train and is reastrable when conside ing that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in M00[ 3.

4 v 4. .;J p Je With one required containment cocitng train inoperable, the inonarabia

/DPERABl[ enntairmant status coolina train must be re within 7 days tore to

/mca* . Inefcomponentsl N / 4enrt1!EO L'EfET1PflE rrovioe iodine removal capab}es and c..Jc. y,!pW'RT are capable of providing at least 100% of the heat removal "jjg y ..

needs after an accident. The 7 day Completion Time was

c. A %*/ *

I j developed taking into account the redundant heat removal capsb111 ties afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period.

(continued)

CLOG STS B 3.6 49 Rev 1, 04/07/95 ht

{

20. ihe NRC requested that a generic editorial change made in the ISTS Ilases hia:Lup for ITS 3.6.6 be removed, and they requested justification for deleting the references to the spray additive system in the ISTS liases hiarkup for ITS 3.6.6. The generic editorial had replaced the word

" reduce" with the word "minimlie." 1he generic editorial change was removed from the ISTS liases hiarkup for ITS 3.6.6.1he deletion of the references to the spray additive system were annotated with JI D 8 for llases Section 3.6. (Comment 3.6.6 9 and 3.6.610) l m em.

Containment Spray and Cooling Systems B 3.6.6 BASES tothecontainmentsump(s). Each spray system flow path from the containment sump will be via an OPERABLE shutdown 7 cooling heat exchanger.

The Containment Spray System provides a spray of cold borated water into the upper regions of containment to reduce containment pressure and temperature and to reduce 7 the concentration of fission products in the containment atmosphere during a DBA. The RWT solution temperature is an important factor in determining the leat removal capability of the Containment Spray System durfog the mjection phase.

In the recirculation mode of operation, heat is removed from the containment sump water by the shutdown cooling heat exchangers. Each train of the Containment Spray System provides adequate spray coverage to meet 50% of the system design requirements for containment heat removal and 100% of 4

the iodine remosal design bases.

The Containment Spray System is actuated either automatically by a containment spray actuation signal (CSAS) signal coincident with a safety injection actuation signal (SIAS)ormanually. An automatic actuation starts the two Containment Spray System pumps, and begins the injection phase. The containment spray header isolation valves open upon a CSAS. A manual actuation of the Containment Spray System is available on the main control board to begin the same sequence. The injection phase continues until an RWT level Low signal is received. The Low level for the RWT generatesarecirculationactuationsignal(RAS)thataligns valves from the containment spray pump suction to the containment sump. The Containment Spray System in recirculation mode maintains an equilibrium temperature between the containment atmosphere and the recirculated sump water. Operation of the Containment Spray System in the recirculation mode is controlled by the operator in accordance with the emergency operating procedures.

f CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-2 Revision 4 7

Containment Spray and Cooling Systens WW:t M ';F 8 3.6.00 @

)

BASES SACKGROUND cantainmaat tarav intas (continued)

The Containmen1 Sorar $1stes provijos a spray of cold

= " n va m an 640 t waam m -- m i nen a- uw . prim boraled water haea w u)per regions of conlainment to reduce conuainment pressure and tosperature and to teduce A IC the concentration of fission products in the containment atsoaphere during a DBA. The RWT solution temperature is an important factor in determining the heat removal capability oftheContainmentspraySystemduringtheinjectionphase.

In the' recirculation mode of operation, heat is removed from the cintainment sump water by the shutdown coo 11 heat enchangers. Each train of the Containment Spray ystes provides adequate spray coverage to meet 605 of i e system design requirements for containment heat removal and 100% of l the lodine removal design bases.

PThe Spray Additi ^ system injects a n razine solution into e spray. The result g alkalin (N,NJe'pli of the M M spray enhanc its ability to scave e fission products ( W l_l3 the contal nt atmosphere. The , added to the spray ,

also ensu s an alkaline pH for e solution recirculat d in the cent neont surp. The alka' ne pH of the contai t sump w or minimites the evolig on of iodine and mini tres {

the currence of chloride apd caustic stress corro on on w nical nut * = and e - -te avaaand in the f1 M d I The Containment spray Sy. tem is ac_ttated either f b* d automatically by n ortainsent man-inen or -mw signal

'F7 or manually.with a sarety injection actuation signal (514$? u b 4 ten coincident h

An automatic actuation - in- u-n spray puum cistnaroa_ valwa1. starts the two Containment ~u 2 5 prs 7 systen pumps, and begins the injection phase. The containment spray header isolation valves open upon a containment spray actuation signal. A manual actuation of the Containment 5 ray Systes is available on the main control board to in the same sequence. The injection phase continues unt I an RWT level Low signal is received.

The Low level for the RWT generates a recirculation actuation signal that aligns valves from the containment spray pump suction to the containment sump. The Containment Spray System in recirculation mode maintains an equilibrium temperature between the containment atmosphere and the recirculated sump water. Operation of the Containment Spray System in the recirculation mode is controlled by the (continued)

CEOG STS 8 3.6-45 Rev1,04/07/95

21. The NRC requested additional justincation for the deletion of CTS 4.6.5.2.a. Discussion of '

Change L.2 for ITS 3.6.7 has been (!arified to better state our justi0 cation. 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

DISCUSSION OF Cl!ANGES SECTION 3 6.7. IIYDROGEN RECOMTINERS l

Note which states: "his Condition is only allowed for units with an alternate hydrogen l

control system acceptable to the technical staff." incorporation of the Action into CTS 3/4.6.5.2 is appropriate, because Calvert Cliffs possesses an alternate means of hydrogen control that has been found acceptable by the technical staff, in Section 3.2.2.3 of the original Safety Evaluation for Calvert Cliffs Unit Nos. I and 2, dated August 28,1972, the Atomic Energy Commission stated: "ne hydrogen purge system provides a backup means of hydrogen control should both of the recombiners fall to function properly...We have concluded that the provisions for mixing, measuring, and contruiling the quantity of hydrogen in the containment following a LOCA are adequate." He proposed change is acceptable, because:

1. the containment vent / hydrogen purge system is an acceptable alternative to the hydrogen recombiners. He containment vent / hydrogen purge system is capable of maintaining hydrogen concentrations inside containment below the required limit of 4.0v/o;

2. the action includes a requirement to periodically verify by administrative means that the hydrogen control function is maintained;

, 3. the containment vent / hydrogen purge system is utilized during normal operations for j purposes other than hydrogen control. Hus, the operators are familiar with the

! system and its operation. Following a accident, there will be adequate time to place the containment vent / hydrogen purge s) stem into operation if the need arises, because the hydrogen concentration builds up slowly; and

4. the revised action will permit the niant to evold unnecessary transients (i.e., unplanned shutdown) and the potential challenges (e.g., cyclic stress) inherent to these operations.

L.2 Current Technical Specification 4.6.5.2.a requires a six month functional test of the hydrogen recombiner to verify the minimum heater sheath temperature increases to 2 700'F within 90 minutes, arid is maintained for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Improved Technical Specification 3.6.7 will not contain this requirement. Generic Letter 93 05 recommended extending the frequency of the six month hydrogen recombiner functional test to the refueling interval. For Calvert Cliffs, extending the frequency of CTS 4.6.5.2.a to 24 months would result in requiring two functional tests of the hydrogen recombiners to be performed at the same frequency, but with different acceptance criteria. This is inappropriate. CTS SR 4.6.5.2.b.3 requires a system functional test for euch hydrogen recombiner to be perfanned every refueling interval. This SR requires the heater sheath ti;mperature to be increased to 21200'F within 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , and maintained for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Current Technical Specification SR 4.6.5.2.b.3 has been maintained as ITS SR 3.6.7.1. This SR is the correct test to perform every 24 months; it ensures the hydrogen recombiners can perform their function (i.e., heat a hydrogen air mixture to above l l 50'F). Current Technical Specification 4.6.5.2.b.3 provides the appropriate acceptance criteria for ensuring the hydrogen recombiners can perform their function. The acceptance criteria of CTS 4.6.5.2.b.3 encompass the acceptance criteria of CTS 4.6.5.2.a. Deleting CTS 4.6.5.2.a will not affect the ability to demonstrate the operability of the hydrogen recombiners.

Additionally, no problems were identified while performing CTS 4.6.5.2.a (during a search of the SRs back to 1985); end the six month functional test is not recommended by the CALVERT CLIFFS UNITS 1 & 2 3.6.7 3 Revision 7

l DISCUSSION OF CilANGES SECI'lON 3.6.7. HYDROGEN RECOMBINERS manufacturer. Deleting the requirement to perform a functional test of the hydrogen recombiners on a six month basis will reduce wear and tear on the hydrogen recombiners (i.e., reduce the potential of testing the hydrogen recombiners to failure). Rus, CTS 4.6.5.2.a has been deleted.

L.3 Current Technical Specification 3.6.5.2 Actiori allows 30 days to restore the inoperable hydrogen recombiner train to Operable status when one train is inoperable. Improved Technical Specification 3.6.7 will also allow 30 days to restore the inoperable hydrogen !

recombiner train to Operable status, however, it is modified by a Note which exempts LCO 3.0.4. Als allows the plant to change Modes when one hydrogen recombiner is inoperable. This is acceptable because either hydrogen: recombiner can control the hydrogen concentration to below the flammability limit. Also, the containment vent is available to maintain the hydrogen concentration to within limits. Allowing the plant to change Modes while in an Action statement by exempting LCO 3.0.4 constitittes a less restrictive change.

This change is consistent with NUREG 1432.

CALVERT CLIFFS - UNITS i ? 2 3.6.7-4 Revision 7

. . . = . _ .

1 i

l Hydrogen Recombiners (i}adfspher)( 3.6.U h

and W@

i l

(c.T5)

SURVIILLANCE REQUIREMtwis II I FREQUENCY months 6.S.2.63 hdr nr n $ tional test for each

( \

3R 3.6 Visually examine each hy i enclosureandverifythere1enrecombiner months X s no evidence

\ % 5.2.L.2. of abnormal conditions.

SR 3.6 Perform a resistance to ground test for months en h heater phase.

[4,4 5.2.bh (4. (, E f .b./)

so.m.,. x e,, r.,, . c~e c - - r- .e I u~^ @

an ky trogen re c.mbo'*w inshewkh s~ uc} codr>l circs ,'l; )

C W. STS 3.6-28 Rev1,04/07/95

l l 22. The NRC requested that justi0 cation be provided for deleting a Reviewer's Note in the ISTS Ilases Markup for ITS 3.6.7. The proposed deviation referenced JFD 10 to llases Section 3.6.

This JFD did not justify the proposed deviation. Justi0 cation for Deviation 9 to llases Section 3.6 provides the appropriate justification. The ISTS Ilases Markup for ITS 3.6.7 was revised to annotate the change with the proper JFD. (Comment 3.6.7 3) l I

i Hydro 9en neceabiners PM:;':t d $2" l

8 3.6 @

8Alts l

ACil0N$

R.1 and B f (continued)

With two hydrogen recombiners inoperable, the ability to perfere the hyerogen control function via alternate capabilities must be verified by adotaistrative means within

4 g,,,,,,.+ .Ir.hou.r. The_ alternate hydrogen control capabilities are vt 4 b, ws si w d,.e... "**dt9. M , ,.d.

! _3L"dl$*!"t

... .. ,,d.m , ne. D k 3 The i hour Co.p ev en u .u.ws a r.asoone o r 5 f time se v.rify t ut a iest .f h,dr e. c.nsee- ,

r-H= daea mit esist. J1Wvi r s mwi i.e reiA ng N' U DS lu"SITM...aDb!!N!!Nhan d

rn edition, the siternateTydrogen ciairerdite.

capability must be verified every urs the. eafter to enstre .its continued availab111ty, s othPthey initialf Verification 4and all subsequent vert (cations be e

U>'

performed as an administrative check, by enant togs or other information to determine the avellability e the '

alternate hydrogen control system. It does not mean to perfore the survelliances needed to demonstrate OPERABILITY of the alternate hydrogen control system. If the abtitty to perform the hydrogen control function is maintained, continued operation is permitted with two hydrogen receabiners .noperable for up to 7 days. Seven days is a reasonable time to allow two hydrogen recombiners to be

- inoperable because the hydrogen control function is maintathed and because of the low probability of the occurrence of a LOCA that would eenerate hydrogen in amounts capable of exceeding the flammabllity limit.

Ed iftheinoperablehydrogenrecombiner(s)cannotberestored to OptRAbLt status within the required Completion itse, the plant must be brought to a M00t in which the LC0 does not apply. To achieve this status the plant must be brought to at least M000 3 within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ,. The allowed ceapletion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach M00t 3 free full power conditions in an orderly manner and without challenging plant systems.

(continued)

CE0G STS 8 3.6-74 Rev 1. W / P /95

I

23. lhe NRC requested additional justification for the deletlon of the reference to Regulatory Guide 1.52 from the ISTS Ilases Markup for ITS SR 3.6.8.2. 'lhls justification has been l

provided as JI:D 15 to liases Section 3.6. (Comment 3.6.81) The NRC also questioned the I

deletion of a statement from the ISTS liases Markup for ITS SR 3.6.8.1 regarding the purpose of the surveillance.1his statement should not have been deleted. 'thus, the statement has been restored to the ISTS liases Markup for ITS SR 3.6.8.1, (Comment 3.6.8 3) i

IRS B 3.6.8 BASES brought to a MODE in which the LCO does not :pply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The 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.

SVRVEILLANCE SR 3.6.8.1 REQUIREMENTS Initiating each IRS train from the Control Room and operating it for 2 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for 7 corrective action. The 31 day Frequency was developed considering the known reliability of fan motors and controls, the two train redundancy available, and the iodine removal capability of the Containment Spray System independent of the IRS.

SR 3.6.8.2 This SR verifies that the required IRS filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

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

SR 3.6.8.3 The automatic startup test verifies that both trains of equipment start upon receipt of an actual or simulated test CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-4 Revision g7

. ,. .. . . . 7, g

\

BA$t$ (continued)

$URVEItt.ANCE At0VIREMENTS 1R 3.5.

esostyheTeach hb trains aYe OPE rain'for k 15 minutes ensures that all LE and that all associated controls are functioning properly, it also ensures'that blockage, fan or motor failure, or extessive vibration can be detected for torrettive action. fTor systems wAh heaters, operatio withl he neaters GIUromatic heater ycling to maintain emperatur for k 10 continuo hours eltsinates no ture } $

n the a orbers and HEPA fil' rs. Experience f filter esti at operating units I icates that the ur period

ad uste far maisture at indiaa = m "10- --- ao EP IItersJ The 31 day frequenc consleering the known reliability / was developedof fan motors and controls,thetwo.rainredundancyavailable$ystem and the iodine removal capability of the Containment Spray independent of the .

sR 3.6. 2 This $R verifies that t e required performed in acco (11ter testing is @

Program (VFTP).J with the VentEntton Filter Testing ?

.5nnyt t - m arraraance uguj seguiperysu ce 2 (Ref. E).) The VFTP includes testing ~ l ntra tuter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific op6 cations). Spectftc test frequencies and additional inforsation are discussed in detail in the VFTP.

SR 3.6. 1 W' The automatic st rtup est verifles that both trains of

\ equipment start upon receipt of an actual or simulated test f[J/D/ stenal. The month Frequency is 1,ased on the need to perr5is this urveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these c .

ts usually pass the Surveillance when performed at month Frequency. Therefore conc dtobeacceptablefromarel.theFrequencywas iebtlity standpoint. @

Furthermore, the Frequency was developed considering that (continued)

CEOG STS B 3.6-84 Rev1,04/07/95

I g a

(.u__m

..-.r.....

_ u, -

g Basis .

l

$URVilLLANCE 1R 3.s. 3 (continued) i REQUIREMENi$

the system frequsney byequipment

$R 3.6. .l.OPERABILITY is demonstrated on a 31 day tR 3.s.10[4 ~

The ICS liter bypass dampers are test to verify OPERAB 11Y. The despers are in the b att pestilen during /

l norma operation and must reposition or accident operation /

l to d w air through the fliters. T (18] month frequency 1s nsidered to be acce te ability and design, ptable the bas on the damper alld i vironmental conditions n vicinityhas perience of the dampers, shown that theand he fact that operating ers usually pass the urvalliance when performed a the (18] month frequen .

_g REFERENCl3 1.

joJ#R 50. Appptfdix A. GDC 41./(DC 42, and GDCM 3

( !. h SAR, Section g

- 2,

3. a..u . . .., m. , < ... . . ..x,g

@.(9)$ARSection g g

-'oG sis 8 3.6-85 Rev1.04/07/95

DISCUSSION OF BASES DEVIATIONS FROM NUREG.1432 SECTION 3.6 CONTAINMENT SYSTEMS 11.

His change to the Bases reflects the Calvert Cliffs specific safety analysis, plant system or operation, or design basis.

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

Rese Specifications are B 3.6.1, " Containment (Dual)," B 3.6.4B, " Containment Pressure (Dual)," B 3.6.6B, " Containment Spray and Cooling Systems (Atmospheric and Dual)," B 3.6.7, '

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

(Atmospheric and Dual)," B 3.6.11. " Shield Building (Dual)," and B 3.6.13 " Shield Building Exhaust Air Cleanup System (SBEACS)(Dual)." nese Specifications were not included in the Calvert Cliffs ITS. His change is consistent with Calvert Cliffs' current licensing basis.

13.

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

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

15.

The Bases for NUREO 1432 SR 3.6.10.2 state: "The filter tests are in accordance with Regulatory Guide (RO) 1.52 (Ref 3)." His statement has been deleted from the Bases ofITS SR 3.6.8.2. Additionally, the reference to RG 1.52 has been deleted. Currently, the filter testing requirements for the lodine Removal System are contained in CTS 4.6.3.1.b. This SR denotes that Calvert Cliffs complies only with portions of RO l.52, Revision 2; Calvert Cliffs does not comply with all the positions established in RO l.52, Revision 2. Thus, the statement contained in NUREG 1432 SR 3.6.10.2 does not apply to Calvert Cliffs, ne provisions of RO 1.52, Revision 2 to which Calvert Cliffs complies are defined in the Ventilation Filter Testing Program provided in ITS 5.0. He Bases for ITS SR 3.6.8.2 refer to the Ventilation Filter Testing Program; thus, the Bases do not need to define the provisions of RO 1.52, Revision 2 to which we comply,

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

"He 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage, and the potential for containment OPERABILITY if the Surveillance were performed with the reactor at power." ne last half of the statement is incorrect. During power operations, containment OPERABILITY is required. Performing the test during an outage, avoids the potential for a loss of containment OPERABILITY, Rus, the Bases should state: "...and the potential for loss of containment OPERABILITY if the Surveillance were performed with the reactor at power." Additionally, TSTF 17 Revision 1, revised the NUREO 1432 Bases for SR 3.6.2.2 to state: . . .given that the interlock mechanism is not normally challenged when containment is entered . . ." His statement is also inaccurate, it should state: "given that the interlock mechanism is not normally challenged when the alt lock CALVERT CLIFFS UNITS I & 2 3.6-2 Revision 7

24. lhe NRC requested additional justification for the deletien of the statement " separate, independent, and redundant" from the ISTS liases hiarkup for ITS 1.CO 3.6.8. The deletion of thl Statement was inconsistent with information provided in the llackground Section of the ISTS Ilases hiarkup for ITS 3.6.8, 'ihe ISTS liases hiarkup for ITS 3.6.8 was revised to state that the three trains of the lodine removal system are separate, independent (except for power), and redundant. (Comment 3.6.8 2)

I 1

IRS B 3.6.8 8 3.6 CONTAINMENT SYSTEMS B 3.6.8 IodineRemovalSystta(IRS)

BASES BACKGROUND The IRS is provided per Updated Final Safety Analysis Report (UFSAR), Appendix 10, Criteria 62, 63, and 64 (Ref.1), to reduce the concentration of fission Jroducts released to the containment atmosphere following a postulated accident. The IRS would function together with the Containment Spray and CoolingsystemsfollowingaDesignBasisAccident(DBA)to reduce the potential release of radioactive material, principally iodine, from the containment to the environment.

The IRS consists of three 50% capacity separate, independent (except for power), and redundant trains. Each train- 'l includes a moisture separator, a_ high efficiency particulate air (HEPA) filter,: an activated charcoal adsorber section for removal of radiciodines, a fan, and instrumentation.

The moisture separators function to reduce the moisture content of the airstream. The system initiates filtered recirculation of the containment atmosphere following receipt of a safety injection actuation signal. The system design is described in Reference 2.--

The moisture separator is included for moisture (free water) removal from the gas stream. The moisture separator is.

important to the effectiveness of the charcoal adsorbers.

Three IRS trains are provided to meet-the requirement for separation, independence (except for power), and redundancy.

Two trains of the IRS are powered by separate Engineered Safety Features buses. The third IRS train is a swing train that can be aligned to take power from either Engineered 7 Safety Features bus.

i CALVERT CLIFFS - UNITS 1 & 2 b 3.6.'8 Revision 97 m

IRS B 3.6.8 BASES APPLICABLE The DBAs that result in a release of radioactive iodine SAFETY ANALYSES withincontainmentarealossofcoolantaccident(LOCA),a main steam line break (MSLB), or a control element assembly (CEA)ejectionaccident. In the analysis for each of these accidents, it is assumed that adequate containment leak tightness is intact at event initiation to limit potential leakage to the environment. Additionally, it is assumed that the amount of radioactive iodine release is limited by reducing the iodine concentration in the containment atmosphere.

The IRS design basis is established by the consequences of the limiting DBA. Theaccidentanalysis(Ref.3) assumes that only two trains of the IRS are functional due to a i single failure that disables the other train. The accident analysis accounts for the reduction in airborne radioactive l iodine provided by the remaining two trains of this filtration system.

The IRS satisfies 10 CFR 50.36(c)(2)(ii), Criterion 3.

LCO Three separate, independent (except for power), and 7 redundant trains of the IRS are required to ensure that at least two are available, assuming a single failure coincident with a loss of offsite power.

APPLICABILITY In H0 DES 1, 2, 3, and 4, iodine is a fission product that can be released from the fuel to the reactor coolant as a rssult of a DBA. The DBAs that can cause a failure of the fuel cladding are a LOCA, MSLB, and CEA ejection accident.

Because these accidents are considered credible accidents in MODES 1, 2, 3, and 4, the IRS must be operable in these MODES to ensure the reduction in iodine concentration

assumed in the accident analysis.

In MODES 5 and 6, the probability and consequences of a LOCA are low due to the pressure and temperature limitations of CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-2 Revisionff7 M

(em;;bk .

B 3.6 CONTAINNINT $YSTEMS 8 3.6 lodine g

stes( ) l"r:f --b m' M) @ l 4 ASIS SACKGROUND Jhe is brevided per 41, 'Gentalr .it n ,,,,

'G1 p,' EDG gr Int C1 up Systees.I a 'nd ton JDCof Containment

43. 'fattina A p of Con (ks,,here insent J #0 W J 4 Ap pe d ., i c,, chere Cleanup $# taas , to reduce sne-C'b % (E,6 3pJt. concentrauen er Tiss on Ref.1) ucts re leased to the c ntainment atmosphere fo lowing a postulated accident. The y S would function together with the Containment spra and Cooling systems following a Design Basis Accident ( M Og reduce the potential release of radioactive materia , ) to W print ally todin. '= 'ka eaatainment to the environment.

the VMEL 9 YD \

consists and redundant of [ach tratets. aanr2vva>

train includes rc m o na m m . seren too a moisture separator, a high capacity e aratara separateWependentf m /d ('$,

. - = = or 'tclency part< culate a' r (HEPA) filter, en activated t * ') kad

) **g_ .go,,4,b

~

_ _ .~ ~ ~

coal adsorber section for removal of radiolodines,6 a Ductwar'k, val %ps anc/ pre =mru ann mir- - mune

(_ . e m 4 -' af tda nyttanE .The motsture separators function to reduce the moisture content of the airstream.

'second b k of HEPA nitura ollows Ine susort m Uvn to co11ec carbon fines and p vide backup in c e of f ailure of th main HEPA filter nk. Only the ups ena HEPA fil ei and e charcoal adsor taction are crad ad in 'ka i Un viis.f The systes initiates filtered recirculation of

~

j ge/(-ry /g/,,, t of a the containment anri 1 un u u ne atmosphere actuation signal.following T recelhe system design is described in Reference 2. @

'~prmer vreves vi snu neaters y to ensure that the relative aldity of the airstream rntering the charcoal adsorbr is maintained below 70s which is consistent th the signed todine and iodide r val efficiencies a per IJtaa mee y e id. Lif tRaf. n The motsture separator is included for moisture (free water) removal from the gas stress. Petersareused;14 aline.

l gas sir , n nn ivi , . m '

operat n of each train f elative humidity, ntinuous least 10 hourg p month with lthe aters on reducat tura buildun en th W PA filters

~

Landadtarhare- anthlpe moisture separatorfant sa<erAraN taportant to the effectiveness of the charcoal adsorbers.

(continued)

CEOG $15 8 3.6-81 Rev1,04/07/95

Ipo tiu e be, 'f.k3. nic (c'Wf ted JrprAle[egeitert)

SM Tecaurrs 3 buses. The MtA IRS MM !s a. swing %M

%d con be o\tyd h, h peer (tm (T)

^

@)

fiket fyletered Edc4y Feedatc: bos .

- IN" T3[ W CC)

BASI $

_ .-m lACKGROUND K@5trainsareprovido meet the reAu cutti fee t+ wee ELfar $

(continued) tion independen J gndt yd . IC rain s' 9pWit is oc 5 ety stor bus d jre ed a ,

e nei d co .ci t e m_ .< -p ei. J

,,g.gguyuireoiosuppy 7-) g A m iCAltc the otAs that resuit in a reitase of r.dioactive iodine

$AffiV ANALY5tl within containment are a less of coolant accident LOCA a aatn steam line break (N$LB), or a control element (assem)bly (CIA)ejectionaccident. In the analysts for each of these it is essumed that adequate containment leak accidents,is intact at event initiation to 11stt potential tightness leakage to the environment. Additionally, it is assumed that the amount of radioactive lodine release is limited by reducing the todine concentration in the containment atmos here.

p g g The Tn design basis is nstabitshed ~ the con e ces of the limiting DBAf%htlh ' he accid t alys A

( uo attuatlJhat of trat of the I $ s rw us Rth unctiona 4.) l~due to a sinii lure that disable e train. The accident analysis accounts for the reduction in airborne radioactive todine provided by the remaining h_ tratryof this filtration system.

The II$ satisfies Criterton 3 of the NRC Policy Statement.

ca - '

g p Quo t he towerD to LC0 'separatt, ependentf al.<l rerlun are requirei to ensure that at least assuming a single failure coincident i@nsofthe(K5b h power.

availableffsite loss of o

. ~ , ,~a .

ApFLICABILivy In MODES 1

4. ed 4.141N $ 4 fission product that can be rei. d fraa tre (E**, to 1 i reactor coolant as a result ' .A. Ine 0*k. that un cause a failure of the fuel cit +13 eN a U/A mil 6, ed CEA ejection accident.

Becaun M w1.'nt, e cow. red credible accidents in MODE' ~

3. o 1 O te i sd be operable in these O @

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

(continued) CE0G STS 9 3.1 @ Rev 1, 04/07/g5

l

25. The NitC requested justincation for rnoving CTS 3/4.6.5.1 to Section 3.3.10. Discussion of Change A.I for CTS 3/4.6.5.1 was added to provide thejustl0 cation. (Conunent 3/4.6.51)

While resolving the aforementioned NRC Cornment, it was discosered that the move of C'lS 3/4.6.6 to Section 3.7 was also lackingjust!0 cation. Thus, DOC A.) for CTS 3/4.6.6 was added to provide thejustlucation. i

M 3. C. 5*./ tnov6b 10 .it'cr7sg g,5 3o 1. /C t% d ,, I3/4 .6 CONTAIMENT $YSTDtl 3/4.6.6 COMBU$fittf GA$ CONikDL krdrenen Anainers LIMITING C0WITION POR OPERAT30N 3.6.6.1 Two independent .ontainment hydro 0en analyrers shall'be OPERA 4Lt. APPLICABILITY: N00r.J 1 and 2. KIIDEI restore the inoperable

a. With analyzer one to hydrogen analyrer OrtAAtLE status within 30 inoperable, days ors 4

'                                                                   1. Verify containment atmesphere grab namp1tng                                         bility and prepare and subelt a special report to the Case saton j

pursuant to 10 CFR l outilntn the ACTION taken60.4 within the cause forthe t e inopera followin 30 days bility, and the lens and schedule,for restoring the systeA !s SPERABLE status, or

2. Se in at least NOT STA#tY within the next 6 hours,

b. With both hydrogen analyrers inoperable, restore at least one inoperable analyzer to OPitABLE status within 72 hours or be in at least NOT STANDIY within the next 6 hours,

c. Specification 3.0.4 is not applicable to this reqitroment.

EURVEILLANCE REQUIREMENTS 4.6.6.1.1 Each hydrogen analyzer shall be demonstr.ied SPERAtLE at least bl. weekly on a 5fAGGERtc illi BA$!$ by dr4..ng a lample free the Waste Gas System through the hydrogen analyser. 4.6.6.1.2 Each hydrogen analyzer shall be demonstrated OPttAtLE at least once per 92 days on a STAGettic TEST sal!$ by performing a CHANNEL CAL!thATION using sample gases in accordance with inanufacturers' omendattons. CALV(RT-tL1FFS,4' NIT-1 3/4-6-24 A.ndment-No -416

d 75 .7, c. g, / d40s170 7o c. F r , io u *C. 3 (~$,*r.to PAHl)

                 .r-3/4.6 $0NTAllgElli.SYliEMS hl I
           /

3/4.6.6 [ COMBUSTIRLt CA$ CONTROL Hydronen Analvrers i i _ LIMITING Com!T1011 Fet SPEMilell 3.6.l.1 Two independent containment hydrogen analyzers shall be OPERAttt. APPLicAllLITY: Nt0t$ 1 and 2. j MI.lENI

a. With analyzerone hydrogen to OPERA analyzer 8LE status inoperable, within 30 days or restore the inoperable

1. Verify containment star > sphere grab samp1tng capability and prepare and submit a special report to the Coantssion pur$Uant to Specification f.g.2 within the following 30 days, and the plansthe outlining and action schedule taken,for restoring the system tothe cause for the ino OPERABLE status, or.

2. Se in at least NOT STANDtY within the next 6 hours.

b. With both hydrogen analyrers inoperable, restore at least one inoperable analyzer to OPERABLE status within 72 hours or be in at least NOT STANDtY within the next 6 hours.

c. Specificat*iw 3.0.4 is not appitcable to this requirement.

               $URVt!LLANCE kt0UIREMENTS 4.6.5.1.1 Each hydrocen analyzer shall be demonstrated OPERABLE at least bi-teetkly on a $ TAG 4tht0 TEST LAl1$ by drawing a sample from the Watte Gas System through the hydrogen analyzer.

4.6.5.1.2 tach hydrogen analyzer shall be demonstrated OPERABLE at least once per 92 days on a $1AGGERED itST SA515 by performing a CHANNEL CALIBRATION using sample gases in accordance with manufacturers' r reconnendations. CALVERT CLIFr$ UNIT 2 3/4 6 20 Amendment No. 189 l

9. y I or i

I)lSCUSSION OF CHANGES SECTION 3/4.6.5.1. IIYl)ROGEN ANALYZERS A1)hi1NISTRATIVE CIIANGES A.1 The proposed change will reformat, renumber, and rewold the existing Technical Specifications, with no change of intent, to be consistent with NUREG 1432. As a result, the Techplcal Specifications should be more casily readable and, therefore, understandable by plant operators, as well as other users. During the relvert Cliffs ITS development, certain wording preferences or conventions were adopted whir h resulted in no technical changes to the Technical Specifications. Additional information rcsy 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 current Technical Specifications. The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. CALVERT CLIFFS UNITS I & 2 3/4.6.5.1 1 Revision 7

C7f 3,g.6./ 4 MAMO TU M cTu.4 37 f .6 3/4 CONTAllstDff $YSTDis h.$ l 3/4.6.6 PENETRATION k00N EXHAUST AIR FILTRATION SYSTDI LIMITING CONDIT!0N Fet OPitATION y 3.6.6.1 Two independent containment penetration room exhaust air filter trains shall be ertRABLE. APPLicA81LJTI: 1100t3 1, t, and 3. Witn one containrest penetratton room exhaust air filter train EllH Inopera blel restom the taoretable train to OPERABLE status with or be in within ti.eafollowing least 00T30STANDeY hours. within the next 6 hours and in COLD $NUfecial SURVE!LLAllCE tt0UltDtDITS 4.6.6.1 Each contathment penetration room exhaust air filter train shall be demonstrated OPERABLE:

3.

At fromleast once the control perflow room, 31through days theonHEPA STA44tRtp filter tr.d charcoa TE$T BA$!$ by init14tin adsorber train and verifying that the train operates for at least 15 minutes.

b. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone etenunicating with the system by: I

1. Verifying that the charcoal adsorbers remove t 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in. lace in accordance with Re ulatory Positions C.S.a and C.S.d f Regulatory Guide 1.52. R vision 2. March 1978 While operating the filter train at a flow rate of 2000 cfm i 10%.

CALVERT CLIFF $ . UNii 1 3/4 6 26 Amendment No. 212 l p \J3

cn 3 6. L. I Mwc0 % scenia 3 7 r l 3/4.6 $0NTAllBENT SYSTDtl A.I l h SURYt1LLAllCE RttutRDIElrTS (Centtsved) 2. Verifying that the NEPA filter banks remove 2 9M of the DOP when they are tested in place in accordance with Regulatory positions C.5.s and C.5.d of Regulatory Guide 1.62, hevtsten t. March 1978, while operating the filter train at a flow rate of 2000 cfs i IM. . 3. Verif anal Ing within 31 days after removal that a laboratory i ads 0 is of a representative carbon sample obtained from an r tray or from an adsorber test tray in accordance with Regulatory Position C.6.b of Regulatory Guide 1.62 Reviston t. March 1978, demonstrates a removat effletency of k 9M for radioactive methyl todine when the sample is tested in accordance wtth AN$! N5101975 (30*C, gh R.H.). 4. Vertfying a system flow rate of 2000 cfm i 1M durtne system operation when tested in accordance with AN$1 N5101975.

c. After every 720 hours of charcoal adsorber operation by:

of a representative carbon sample obtained from an adsorbe or free an adsorb 6r test tray in accordance with Regulatory demonstrates a removal efficiency of 19M for radioactivePosition methyl todine when the sample is tested in accordance with - ANSI N5101975 (30'C. 95% R.H.). Subsequent to reinstalling the adsorber tray used for obtaining the carbon sample, the filter train shall be demonstrated OPERA 8LE by verifying that the charcoal adsorbers remove 2 99% of the halogenated hydrocarbon refrigerant test pas when they are tested in. place in accordance with Regulatory Positions C.S.a and C.S.d of Regulatory Guide 1.52. Revision 2 operating the ventilation system at a flow. March 19*8. while 11M. rate of .000 cfm

                    ~
                                                                       ~.

CALVERT CLIFFS . LINIT 1 3/4 6 27 Amendment No. 212 l wy 2a3

f ( 73 .7.G..C../ mv&o m .sec.w 2Q 3/4.6 CellTAINMtiff SY$f Dts b'l ( SURYt!LLAllCE kt0UIRDetifil (Coettneed) f4. At least once per 18 acnths bys h 1. Verifying that the Iressure drop acmst the combined HEPA filters oand charcoa adsorber bant - while 110%. perating the filter train S a flow rate,cf 2000 cfs.s < 6 inches Water Gau 2. Verifying that the filter it in starts on Containment Isolation Test Stenal.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove > 99% of the 00P when they are tested in. place in accordance witE Regulatory Positions C.6.a and C.8.c of Regulatory Guide 1.52 Revision 2 March 1978, while operating the filter train at a flow rate of.

2000 cfm i 10%.

f. After each c bank by verif ng that the charcoal adsorbers remove t 99% of alete o halonenated in. place in accordance with Regulatorrocarbon refrigerant test gas when the of Regulatory Guide 1.52, Revision 2.y Positions a and C C.5.y are tested the filter trai'i at a flow rate of 2000 cfm 110%. ting March 1978, whlie opera.

g. After maintenance affecting the air flow distribution by testing in place and vertfying that the air flow distribution is unifom within i 20% of the average flow per unit when tested in accordance with the provisions of Section 9 of ' Industrial entilation' and Sec ton 8 of AN$1 N5101975. CALVERT Cliff 5 . UNIT 1 3/4 6-28 Amendment No. 212 l page

C 75 3 L f../ MNFD lo SFrTioy 3, 7 p-3/4.6 D NTAINMENT SYSTEMS Al A 3/4.6.6 PENETRATION ROOM EKHAUST AIR FILTRATION SYSTEM LINITING CON 0!T!0N FOR OPERATION 3.6.6.1 Two independent containment penetration room exhaust air filter trains shall be OPERABLE. APPLICABILill: MODES 1. 2 and 3. ACI1Qfit With one containment penetration roce exhaust air filter train Inoperable, restore the inoperable train to OPDABLE status within 7 days or dethe within in at least 30 following NOT STANDBY within the next 6 hours and in hours. COLD SNUTD0WN EURVEILLANCE REQUIREMENTS 4.6.6.1 be demonstrated OPERABLE:Each containment penetration room exhaust air filter train shall a. At least once per 31 days en STAGGERED TEST BASIS by initiating, frot the control room, flow through the HEPA filter and charcoal adsorber 15 minutes. train and verifying that the train operates for at least b. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting fire or cheelcal release in any ventilation zone comun,icating with the system by: 1. Verifying that the charcoal adsorbers remove t 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with Regulatory Positions C.S.a and C.S.d of Regulatory Guide 1.52. Revision 2. March 1978 while operating the filter train at a flow rate of 2000 cfm i 10%. l CALVERT CLIFFS ' WIT 2 3/4 6-22 Amendment No. 189 l p.$ e i oF 3

C. T.6 3 f. . L l t}-104 5 O To SGet t o bJ 3, */ 3/4.6 CONTAINMENT SYSTEM b.l J. JVRVEILLANCEREQUIREMENT5(Continued) 2. Verifying that the HEPA filter banks remove 199% of the D6P_ when they are tested in place in accordance with Regulatory Positions C.5.a and C.5.d of Regulatory Guide 1.52 Revision 2. March 1978. while operating the filter train at a flow rate of 2000 cfm i 10%. - 3. Verifying within 31 days af ter removal that a laboratory analysis of a representative carbon sample obtained from an adsorber tray or frun an adsorber test tray in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52 Revision 2. March 1978, demonstrates a removal efficiency of 2 90% for radioactive methyl iodine when the sample is tested in accordance with ANSI NS101975 (30*C, 954 R.H.). 4. Verifying a system flow rate of 2000 cfm i 10% durina system operation when tested in accordance with ANSI N5101975. c. After every 720 hours of charcoal adsorber operation by: Verifying within 31 days after removal that a laboratory analysis l of a representative carbon sample obtained from an adsorber tray or from an adsorber test tray in accordance with Regulatory

Position C.6.b of Regul: ; tory Guide 1.52. Revision 2. March 1978, demonstrates a removal efficiency of 2 90% for radioactive l methyl iodine when the sample is tested in accordance with ANSI N510-1975 (30*C. 95% R.H.).

k-CALVERT CLIFFS - UNIT 2 3/4 6-23 Amendment No. 189 l po e 7I3 s

c f3 3.4,6,) $ m u g o ,c3 wer ou 7. , 7 [3/4.6 .C0ltTAINNDIT 5YSTEMS A. I A f,JRVEILLANCE REQUIREMElfil (Continued) Subsequent to rainstalling the adsorber tray used for obtaining the carbon sample, the filter train shall be demonstrated OPERABLE by verifying that the charcoal adsorbers remove 199% of the halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with Regulator C.5.d of Regulatory Guide 1.52. Revision 2, yMarch Positions 1978,C.S.a while and operating the ventilation system at a flow rate of 2000 cfm i 10%.

d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and cht,' coal adsorber banks is < 6 inches Water Gauge while operating the filter train at a flow rate of 2000 cfm i 10%.

l 2. Verifying that the filter train starts on Containment

                                         ! solation Test Signal.

l e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove > 99% of the DOP wnen they are tested in place in accordance witE Regulatory Positions C.5.a and C.S.c of Regulatory Guide 1.52 Revicion 2, March 1978, while operating the filter train at a flow rate of 2000 cfm 1 i %.

f. After each w eplete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove > 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with Regulatory Positions C.S.a and C.S.d of Regulatory Guide 1.52 Revision 2, March 1978, while operating the filter train at a flow rate of 2000 cfm 110%.

g. After maintenance affecting the air flow distribution by testing ( in-place and verifying that the air flow distribution is uniform within 120% of the averagc flow per Unit when tested in

                   \              accordance with the provisions of Section 9 of " Industrial Ventilation" and Section 8 of ANSI N510 1975.

CALVERT CL1FFS - UNIT 2 3/4 6-24 Amendment No. 189 l

                                                                                               .y        3 oI 3

DISCUSSION OF CIIANGES SECTION 3/4 6.6. PENETRATION ROOM EXIIAUST AIR FILTRATION SYSTEM ADMINISTRATIVE CIIANGES A.1 The proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change of intent, 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 Calven 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 mo.c fully describe each LCO and to be consistent with NUREO.1432. Ilowever, the additional information does not change the intent of the

urrent Technical Specifications, The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications.

CALVERT CLIFFS - UNITS 1 & 2 3/4.6.6-1 Revision 7

_ 26. An internal reviewer identified that the Bases 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 reflect 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 opened. l

Containment Air Locks B 3.6.2 B 3.6 CONTAINMENT SYSTEMS

          -B 3.6.2 Containment Air Locks 4

BASES BACKGROUND-. Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODF$ pf operation. Each air lock is nominally a right circular cylinder, 9 feet-9 inches in diameter for the personnel ' air lock and 5 feet-9 inches in diameter for the emergency air lock, with a door at each end. The doors are interlocked to prevent simultaneous opening. During periods when containment'is not required to be OPERABLE, the door interlock mechanism - may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. Each air lock door has been designed and tested to certify its ability to withstand.a pressure in excess of the maximum expected pressure following a Design BasisAccident(DBA)incontainment. As such, closure of a single door supports containment OPERABILITY, Each of the doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity. To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door). Each personnel air lock is provided with an alarm in the control room that actuates when either door or equalizing valve for a personnel air lock is opened. The alarm senses 7 door position from a limit switch located on each door and equalizing valve. The' containment air locks form part of the containment

                                       ' pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA. Not maintaining air -lock integrity or leak tightness may result CALVERT CLIFFS - UNITS 1 & 2        B'3.6.2-1                         ' Revision g7

Containment Air Locks "--'- " ' " 83.6.f Q B 3.6 CONTAINMfMT SYSTEMS 5 3.6.2 Containment Air Locks P***h =d M; b SASES BACKGROUND Cor.tainment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation, Each air lock is nominally a right circular cylinder.p g g,. S pud *** - in diameter, with a door at each end. The doors are m erlocR65 to prevent simultaneous opening. During periods cr- lac k g when containment is not required to be OPERABLE, the door 5 /4-9/a Ain interlock mechanism may be disabled, allowing both doors of g;4,,, e.i e r- an air lock to ree in open for extended periods when frequent containment entry is necessary. Each air lock door 1 b# 4W T has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected 4 ;, /, c k pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports - containment OPERABILITY. Each of the doors contains double gasketed seals ar.d local leakage rate testing capability to ensure pressure integrity. To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door). Each personnel air lock is provided withilimit p(Itches o

                                                ~M bopr coors 3gnt orovim contpel room >fdlcatio(of door                          A

[p<fsitionAAdditto ly, IA trol pr todt ton is viceci i

                                                 $cNo [ated                                                           3 The containment air locks form part of the containment j

pressure boundary. As such, air lock integrity and leak 1 tightness is essential for maintaining the containment leakage rate within limit in the event of a 08A. Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the unit safety analysis. og darm On Ne, c crntrol roo,A bd ukudes den eder door or epaMt'i% VdVc. kor c. j>etsonel th \och. is opened. Ne ab.rM seMe5 door poiWienh krm A b0t C ANck locMed oA @ckdoor d Ov.he kahCi gVdve, y -

                                                                                                        ~           ~

(continued) CEOG STS B 3.6-11 Rev1,04/07/95

27. While resolving comments, it was identified that ACTIONS Note 1 of ISTS LCO 3.6.3 was-added to CTS LCO 3.6.4.1 without appropriatejustification. 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 to justify the change; and 3) the ISTS Markup for ITS 3.6.3 was revised to provide the appropriate cross-references.

4

Lt cS.u-b 3 f. 3 e Ib S/44 CONTADBGENT SYSTDi$ 3 . 4, ,3 -3/L04 CONTAINMENT ISOLAff0N VALVES LIMITING C081T10N FOR OPERATION

LCo 343

                                         ?!A.1- Each containment isolation valve shall be OPERABLE.* '

iPPLICABILITY: MODES 1. 1, 3. and 4. AGIl2ti: With one or more of the isointion valve (s) inoperable, either:

M b.deMs 4 sne inopergpw valvets) fpvrasABLE statui,Arrs q, A

ok y dre f /b o # M & l~~ sew "*:,$/

                                                                      . or2g;,                                                             /---

gg Visolateeachaff ed penetratTori withtn hours by use of at

least one des f # A ,G 4 C. - Position, or vated automatic valve sec@Qd in the isolation @rgi c,, m..nr,. y ----^'L

                                                     -c, ' Isolate the affected penetration within                                           m least one closed manual valve or blind flanges orhours by use of atl'NFC.'s                                  .
                                                          "Be in at least h0T STANDBY within the next 6 hours and ingCOLD,( g A O                                                                                               '

Act o.s D 5NUTDOWN within the following 30 hours. 3 I t e ne rat o a! . U p k w '

                                                -~                                         ,

D V W Acrmi: stre: 3'

                                        $URVEILLANCE REQUIREMENTS                        "                                  ^

[ 4.6.4. prior o returnin1 Each containment the valve 150 tion valve shall be demon trated~DE10(t - rep cement work s perio service after maintenanc repair, or on the valve or its asso ted actuator. A c rol, or power circuit /- 'IO _ isolation th y perfonnance of a cycling' est and veriff ationI i@

                                                                           -~,,~.<~,m                                          v,_.

C ,keh.s tu y o. .. : N , ,y : fJ, , g ; .. ; . ( '

                               .W1h.~:

t.w A. s4 ge & a js ,,,g

~W*

\ . .to, g

c.ime: M ,,#, J . 4 r..A 4 ('e'ia~ +u er mw be , & ^ " "ecwr...bc, JR3.L.3.'L s t 14,3,3 Valves that are. nonnally closed may be opened on an intennittent basis under administrative control. A

                                     '                ~

LA

                                               ;- ' Containment purge isolation valves isolation times will r:ity apply i "E_K h htk 9m , t'the :-valves fer : are     recuired to be OPERAaLE and thev are open.,
                                                                                   -t9--" a"9e Meh t '-a
                                                                                                                   @= e h *in os.
                                                     ;^^,;;^

wu .' u _i. -2, u-- 5 ana 4 per lecnnuai-s.--a 5W Lik,, 2/t 5.1 ' t-9;

                                                                            ...s----  - ' - ->-                                                          [44$ g        g

( CALVERT CLIFFS - UNIT 1 3/4 6-22 A:nentment No. 212 M e ,, b,ua rio, s I d *p* L

h. f (pr f e , & be0* {kb

                                                                                                                 +        \         /#

peg. I 4 6

Srue.Gu4u. 3.t. ,3 1NSERT 3.6.3 ACTION NOTES 2. 3. & 4 5 NOTES

2. Separate Condition entry is allowtd for each penetration flow path.

3 Enter applicable Conditions and Required Actions for s>*em(s) made inoperable by containment isolation valves. .

                                                                                           ~                                                                                               '

4. En ' cable Requir etions of 3.6.1, "Confidt,"

q c res m ex , _ the o contai cakage ratejoctfptance c * . 7 l, Peubu O pals n.3 be. %ua.wa aersbAu (AOQt CLO M1s iS krAN IV G. Cent ro \ S . P* Y Y , 1

i

                                                                                                                 $ p ea. . F . c.+.,%          ~F, 6 , 3 3,g       -37t;t CONTAINMENT SYSTEM 1 g, 6, 3       B/41674-                                   CONTAINMENT ISOLATION YAtVES LIMITING CONDITION FOR OPERATION                                                                                               -

3*3 4,4,44 Each containment isolation valve shall be OPERA 8LE.* ' APPL 1tABILITY: MODES 1, 2, 3. and 4. ' EI1Dfit With one or more of the isolation valve (s) inoperable, either 4.) oft' Ine poperable valven) to vrie= Witatus witnirs]e__ hours. %,..y A L, _

                                                                                .i                           g ,W u.J. A., X *b                                           g, s.. 4 fisolste each affec d pen                              attonwittiin t,, ,

M *4 least one deactivat tic valve secure - m1i st-- u,,, A,g 4 c - - position, or 4 e[e t isolationuse _ - . - cv **C M S. s

                            % !solate the affected penetration within                                                ours by use of at =-
                                              *least one closed manual valve >r blind                             ange; or                    H '4 M'T h.k Accow                                                                                                                         q         nion A.?

O -

                                                    $HUTDOWN e in at least   withinNOT        STANDBY the following    30 hours.within    the next 6 hours and in COLD"d C.2.-
                               . I                                   rovisions or a         fication 3.0.

at the affected etration is i notappitcybieprovideQ

                             -                                                                                 ted. _ f                                                       '4    ,
                                                                   -~ _,                        -
                                                                                                                                                       - L,Il
          '%~     - _

INum . Action % N oi r,.5 @ ,(

                                                                                                                                                                    .5
                     $URVEILLANCE REQUIREMENTS                                                                                               ^~                  /46 g              T.6.4.1                                  Each cc'ntainment            olation valve shall e cemonstrated 0F              BLE'"

prior o returnin the val to service after m ntenance, repair. l rep cement work s perf ed on the valve or s associated act or.

                                                                                                                                                                   'I c trol, or power circ                                       by perfomance of cyr.1. tag tait and erificationJ                                             l f isolation time.                                    f b.., hdbioTE: Gey on. .we                                                      4. p ,. 4.,...
                                                                                                                                , f i ... g,.h t , t %                  49
                        ~- e 4 b O 4 a d n.:*r a c h a @ s v b
                                                                                                                                                        -~
                                                               ' < nm n : 03y a                         e         $c . . 8 ct.

51343. L m c.g,(,G

w

                                                                                                   - ~ o....             _ . _

Valves that are nomally closed may be opened on an intemittent 3' (s q 3,g,,3,3 basis under administrative control. UTriment purge isolation valves isolation times will only apply in MODE 6 when the valves are required to be OPERABLE and they are open y tjer. tt :: S m..a ca../.- :" p g gehtf er. ;;h;;] " y

4. 4 a una e per secnnicas agmrfeette^-? A { , , m, ang lg. j*

                             .Akh-thjhus vaives must remain cisuJ.                                                                        -

CALVERT CLIFFS . UNIT 2 ! 3/4 6 18 Amendment No. 189 See d.s. s ..> - d <%. 9 ) g ,, , gp,c.G.,m4.- 3. '5. K m ,, l.its.a c k .J J 19y n l

S pec M d :s 3. t. 3 INSERT 3.6.3 ACTION NOTES 2. 3. & 4 NOTES-

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

3. Enter applicable Conditions and Required Actions for :)m(s) made inoperable by containnat isolation valms. '

t appli 4pleakageuits in ex le Cond: and A LCO 3.d"C- lak I the o Icon

t l=kardte acWM cri .j ;

1

1. bdrAb b pdhs mq b udsolade) Wermidedl3 uider-oJ7y s t r a N ue em +rJ.: . 7 h

I

DISCUSSION OF CIIANGES SECTION 3.6.3 o CONTAINMENT ISOLATION VALVES or replacement work is performed on the valve or its associated actuator, control, or power circuit, improved Technical Specification 3.6.3 will not contain this SR. Current Technical Spedfication 4.6.4.1.1 is being deleted. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, or replacement of a component, post maintenance testing is required to demonstrate O?ERABILITY of the system or component. After restoration of a component that caused a required SR to be failed, ITS SR 3.0.1 requires the appropriate SR (i.e., ITS SR 3.6.3.4) to be performed to demonstrate OPERABILITY of the affected compone.its. Therefore, explicit post maintenance Surveillance Requirements (i.e., CTS SR 4 o.4.1.1) are not required and are not included in the Calvert Cliffs ITS. L.ll Current Technical Specification LCO 3.6.4.1 is modified by Footnote

which states:

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

Footnote

of CTS LCO 3.6.4.1 only applies to valves that are normally closed (i.e., manual >

valves), while ACTIONS Note I for ITS LCO 3.6.3 applies to any penetration flow path that has been closed to comply with an action. The CTS have been modified to include ACTIONS Note 1 of ITS LCO 3.6.3. Opening of containment penetrations on an l intermittent basis is required for performing surveillances, repairs, routine evolutions, etc. Intermittently opening CIVs which are isolated in accordance with an action requirement is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the penetration flow path is open and the administrative controls established to ensure the affected penetration can be isolated when a need for containment isolation is indicated. CALVERT CLIFFS - UNITS 1 & 2 3.6.3-8 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3 6 - CONTAINMENT SYSTEMS from any accident previously evaluated is not created because the change does not introduce a new mode of plant operation and does not involve physical modification to the plant.

3. Does the change involve a significant reduction in a margin of safety?

He requirement to demonstrate each containment isolation valve Operable t>y performance of a cycling test and verification of isolation time prior to retuming the valve to service after maintenance or repair has been deleted. He deletion of the explicit requirement to verify primary containment isolation valve OPERABILITY prior to retuming the valve to service after maintenance, repair or replacement work is considered administrative. ITS SR 3.0.1 requires the appropriate SR to be perfonned to demonstrate OPERABILITY after restoration of a component that causes the SR to be failed. In this case, ITS SR 3.0.1 would require SR 3.6.3.4 to be performed, nis SR requires verification that the isolation times of the affected primary containment isolation valves are within limits. As a result, the existing requirement to verify primary containment isolation valve isolation times are within limits following repair, maintenance, or replacement is maintained, nerefore, this deletion does not involve a significant reduction in a margin of safety. 3.6.3 Chance L,n

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

This change allows a containment penetration flow path that has been isolated in accordance with an Action to be opened under administrative controls. Containment isolation is not considered an initiator of any previously analyzed accident, nerefore, this change does not significantly increase the probability of such accidents. Although containment isolation is considered in the mitigation of the consequences of an accident, the administrative controls provide acceptable compensatory actions to assure the penetration is isolated in the event of an accident. Therefore, the consequences of a previously analyzed event that may occur during the opening of the isolated line are not significantly increased. 2. Does the chance create the possibility of a new or different kind of accident from any accident previously evaluated? This change provides acceptable compensatory actions following failure of other equipment. The current requiremems are based on providing a single active failure proof boundary to compensate for the loss of one of the two active isolating boundaries. This change provides an attemative which meets the original criteria of a single active failure proof boundary and is capable of retuming the system to its original configuration (i.e., configuration which can provide a single active failure proof boundary.) Therefore, this change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

3. Does the change involve a significant reduction in a margin of safety?

The margin cf safety considered in determining the required compensatory action is also based on providing the single active failure proof boundary. Opening of containment penetrations on an intermittent basis is required for performing surveillances, repairs, routine evolutions, etc. which minimizes the possibility of a transient due to a required plant shutdown. The administrative controls, consisting of stationing a dedicated operator (who is in continuous communication with the control room), provides a compensatory boundary in this condition. CALVERT CLIFFS - UNITS 1 & 2 3.6-15 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 - CONTAINMENT SYSTEMS Since the compensatory boundary is capable of essentially meeting the same criteria of a single active failure proof boundary, the change does not involve a significant reduction in the margin ofsafety. 16.6 Chanee L1 Not used. l 3,ft,6 Channe 1M

1. Does the change involve a significant lacrease la the probability or consequences of an accident previously evaluated?

The proposed change increases the Completion Time to restore one containment cooling train to Operable status from R hours to 72 hours when three containment cooling units are inoperable. This change will not significantly increase the probability of an accident previously evaluated. The Containment Cooling System is not an initiator of any analyzed event. This change will not significantly increase the consequences of an accident. He containment cooling capability is still over 100% because two containment spray trains and one containment cooling unit arc Operable. He 72 hour Completion Time limits the time the plant is in a condition in which it does not have a redundant Containment Cooling System. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The proposed change increases the Completion Time to restore one containment cooling train to Operable status from 8 hours to 72 hours when three containment cooling units are inoperable. This change does not involve 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. 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 the change involve a significant reduction in a margin of safety?

The proposed change increases the Completion Time to restore one containment cooling train to Operable status from 8 hours to 72 hours when three containment cooling units are inoperable. The margin of safety is not significantly affected because enough containment cooling capability exists to mitigate any accident heat load inside containment. The Completion Time will ensure that the time the plant is in a degraded Condition (without a redundant Containment Cooling System) is limited while allowing enough time to restore one train of containment cooling to Operable status in order to avoid the transient of a plant shutdown. Therefore, the proposed change does not involve a significant reduction in a margin of safety. CALVERT CLIFFS - UNITS 1 & 2 3.6-16 Revision 7

Containmot isolation Valves -pt ::n:M d h;P 7g} 3.6.5 @ 3.6 CONTAllMENT SYSTEMS 3.6.3 tontainment Isolation Valves i":::An ; and Owey-- Q (3.6.4.1) LC0 3.6.3 Each containment isolation valve shall be OPERABLE. 4 APPLICABILITY: MODES 1, 2, 3 and 4. ACTIONS y . _ .. . _ .........uaTrs.-... ---__ _ _ . . . . . . ~ . - II,.1 tu t. 1. - .. ation flow paths Qexsanf for f 421 1Me valvwnetration;cro may be unisolated Intermitte.itly under noministrative .ontrols. @

     .6.E ath. Separate Condition entry is allowed for each penetration flow path.
 /N2""gh.

Enter applicable Conditions and Required Actions for system (s) sAde inoperable by containment isolation valves. 3.G.I.1 \4. En applic e Condi ns and .uired A Fv Wir W/

ontainee
when kage res ons of (183.6.1 A in ding tVoverall , ntains N

                 ...Wd'...!'***'!"**!'!!'h...a                                                                          ..
                             . CONDITION i                                                                                                               REQUIRED ACTION                        COMPLETION TIME A.    --------NOT E------                                                         A.1         Isolate the affected                4 hours Only applicable to                                                                     penetration flow path penetration flow paths                                                                 by use of at least withtwocontainmenp isolation valves one closed and 2' g 4.1         ------------%. .%. gjJ g,e automatic
                                                                                                    ,, . 4      de-activated valve closed manual va,lve.

gh! A""* p c, One or more ; blind flange, or penetration flow paths check valve with flow with one containment through the valve isolation valve secured. inoperable][e ept f l (purg valve akage Algl and shield utldi b age n L_ythin ass le 1 it]. @ (continued) CE00 STS 3.6-8 Rev 1, 04/07/95 ,

                    %%.o (Sbc.). 'i s.bb.s v.lo                                                           m..g Le orm4 a6 Ac.S -b p.sk.<t.

4 3* ' F -b a :L U.d t b c. Th a .

g I

Containment isolation Valves (EitarW=fe nWtfuAID

        <CTJ                                                                                                                 3.6.3

_SURVEllLMCE REQUIREMENTS SURVEILLMCE

FREQUENCY SR 3.6.3.1 Verifyeach(42)inchpurg alve is m' . 31 days sealed closed except for e purge valve in a penetration flow pat (_ - Condition E of this . 11e in g. SR 3,6.3.1 - Verify each except when t 441 in irch@ Ive is c1 b 1 days e open for pressure control, alves are J. L. lJ 9 or air I. d vu 34 3 poc. M r- quality considerations for personnel entry, or for Surveillances that require the valves to be open. SR 3,6.3 NOT E------~ ~-----

 <t/,(o.l.).h
              /

Valves and blind flanges in high radiation areas may be verified by use of h administrative means.

                                                                                       ................. ....                             A Verify each containment isolation manual g

( velve aiid blind flange that is located 31 days outside containmentpand is required to be losea curt T ITtrdent conditions is (co 14 1 closed, except for containment isolation Fe e ta. 4 g valves that are open under administrative ,TM-6 controls. s A Q (continued) AN nk kcked, ,$caloj, ,, 6]$4redse .secu rek CEOG STS 3.6-12 Rev 1. 04/07/95

Containment Isolation Valves y dr= ; h t . 4 ;m. W 3.6.k h

             $URVEILLANCE REQUIREMENTS (continued)

SURVEILLMCE FREQUENCY SR 3.6.3 - - . - - - . -

                                                                                   -- -NOTE.-
%,).l. A                    Valves and blind flanges in high radiation F,.     .. u                  areas may be verified by use of administrative means.
     .h,4,,}.l,4)'          V<.rlfy each containment isolation manual                                             Prior to
                            * &lve and blind flange that is located                                               enteri J 8"I'S 8' M""            'aside containment and required to be                                              from MODE 4 E5if fee-re d            'e.Tosed curing accident conditions is                                                 not performed            737F.4f Msed, except for containment isolation                                                within the Lco .3.6.3                  v.h a that are open under administrative                                                                            !

previous P .t..+ c 4 re Jols. 92 days 4'g' 4 /* SR 3.6.3. Ve,**fy ine isolation time ofutxh noWeB

in h ciilL<edfg@ each automaticgontainment ' T5 r5 4/o isolattoa valve is within imits. ", accordance ~ with the Inservice p ara o 'n,J,8 Testing SR 3.6.3. Perform leakage rate tes ng for 184 days containment purge valve with resilient seals. AND With 92 days @ af r opening i valve

                                                                                                           ~    f SR 3.6.3      Verify each automatic containment isolation                                                   months valve that is not locked, sealed, or
 ,g A,), g ,               otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

(continued) CEOG STS 3.6-13 Rev 1. 04/07/95 l J u

28. The requirements of Unit 1 CTS 4.6.1.2.b and 4.6.1.2.c should have been retained in the Containment Leakage Rate Testing Program. To resolve this issue, the following changes were required: 1) the Markups of Unit 1 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 eliminated; 3) Markups of Unit 1 CTS 4.6.1.2.b and 4.6.l.2.c were added to the CTS Markups for ITS 5.0; 4) a change to Unit 1 CTS 4.6.l.2.b was justified by DOC A.31 for ITS 5.0; 6) the Markups for CTS 3.6.4.1 and 3/...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 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.

Containment B 3.6.1 BASES I testing only,-and s 0.75 L. (259.500 SCCM) for overall Type A leakage following an outage or shutdown that included Type A testing. At all other times between required leakage rate tests, the acceptance criteria is based on an overall Type A leakage limit of 5 1.0 L.. .At s 1.0 L the offsite dose consequences are bounded by the assumptions of the safety analysis. Surveillance Requirement Frequencies are as required by Containment Leakage Rate Testing Program. These periodic testing requirements verify that the containment leakage rate does not exceed the leakage rate assumed in the safety analysis. Additionally, the requirements regarding the Unit 1 containment purge isolation valves must be met. 7 L l SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be. maintained in accordance with the provisions of the Concrete Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4). 7 REFERENCES 1. 10 CFR Part 50, Appendix J. Option B

2. Updated Final tafety Analysis Report, Chapter 14

3. Updated Final Safety Analysis Report, Chapter 5

4. Regulatory Guide 1.35. Revision 2 January 1976 ?

CALVERT CLIFFS - UNITS 1 & 2 8 3.6.1-5 Revisionp7

i Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE. 1 APPLICABILITY: MODES 1, 2, 3, and 4. ACTIONS

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

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

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

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

7

4. ShutdownCooling(SDC)isolationvalvesmaybeopenedwhenReactor Coolant System temperature is < 300'F to establish SDC flow.

CALVERT CLIFFS - UNITS 1 & 2 3.6.3-1 RevisionEI7

Containment Isolation Valves B 3.6.3 BASES minimize the loss of reactor coolant inventory and establish the containment boundary during accidents. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES S and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of thess MODES. Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LC0 3.9.3,

                               " Containment Penetrations."

ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths to be unisolated intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In I this way, the penetration can be rapidly isolated when a need for containment isolation is indicated. A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each penetration flow path. This is acceptable, since the Required Actions for each Condition provida appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable

                              -containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions.

The ACTIONS are further modified by a third Note, which ensures that appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve. 7 CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-4 Revision /7

Containment Isolation Valves B 3.6.3 BASES The fourth Note allows the shutdown cooling (SDC) isolation 7 valves to be opened when RCS temperature is < 300*F to establish SDC flow. This Note is required for Operation in MODE 4 to allow SDC to be established. A.1 and A.2 In the event one containment isolation valve in one or more penetration flow paths is inoperable, the affected penetration flow path must be isolated. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a i closed and de-activated automatic containment isolation valve, a closed manual valve, a blind flange, and a check valve with flow through the valve secured. For penetrations 7 isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest available one to containment. Required Action A.1 must be completed within the 4 hour Completion Time. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification, through a system walkdown, that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-5 Revision A 7

Programs and Manuals 5.5 5.5 Programs and Manuals criterion are s 0.60 L. for Types B and C tests and s 0.75 L. for Type A tests,

b. Air lock testing acceptance criteria tre:

1. Overall air lock leakage rate is s 0.05 L. when tested at 2 P..

2. For each door, leakage rate is s 0.0002 L when pressurized to 2 15 psig.

In additi?n, the following requirements apply to the Unit 1 containment purge isolation valves:

a. The Unit 1 containment purge isolation valves shall be demonstrated OPERABLE any time after being opened and prior to entering MODE 4 from shutdown modes by verifying that when the measured leakage rate is added to the leakage rates determined pursuant to the Containment Leakage Rate Testing Program for all other Type B or C penetrations, the combined

                            -leakage rate is less than or equal to 0.60 L.. The leakage             '7 rate for the containment purge isolation valves shall also be compared to the previously measured leakage rate to detect excessive valve degradation,

b. The Unit I containment purge isolation valve seals shall be replaced with new seals at a frequency to ensure no individual seal remains in service greater than 2 consecutive fuel reload cycles.

The provisions of SR 3.0.2 do not apply to tha test frequencies specified in the Containment Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

?.

CALVERT CLIFFS - UNITS 1 & 2 5.0-29 Revision kT7

TC 0h kh f 3/4.6 $9KTAtlflENT SYSTDIS SURVE!LtANCE REQUIRDelTS (Continued) , I !

b. ,

Containment purge isolation vaD1 be demonstrated OPERABLE ' s ' . the arty,last surveillance test has been performed within the pasttim ' ' MODE 4 from shutdown modes by verifying that when the measu i Techalcal Specification 4.6.1.1.a for all other Type 8 or Clenkene penetrations, O.60 L the combined leakage rate is less than or equal to ' s l , valves.. The leakage rate for the containment purge isolation ~ l rate to detect excessive valve degradation.shall also be compared to the prev c. The containment purge isolation valve seals shall be replaced with new seals at a freq incy to ensure no individual seal remains in service greater than 2 consecutive futi reload cycles. See, hrse.sasin & %ees kor ETS f,6,16, Cinth0ntmth L.eo.Q %4 'Ir&3 Prope I CALVERT CLIFFS - UNIT 1 3/46-3 Amenhent No. 219 py Of 10

DISCUSSION OF CllANGES SECTION 3.6.1 - CONTAINMENT M2 Unit 2 CTS 3.6.1.6 Action requires the structural integrity to be restored within 24 hours when it is not conforming to the requirements of the LCO. Improved Technical Specifications will require the containment to be restored to Operable status within one hour. The ITS will require the containment to be declared inoperable if its structural integrity is not maintained and the containment cannot meet its design fimetion. His change is conside .ed more restrictive because it is assumed that the containment is inoperable when the Actions are entered. Herefore, the AOT is decreased from 24 hours to I hour. Decreasing the AOT constitutes a more restrictive change. His change will not adversely affect pant safety because the containment is one of the threa barriers against a release of radiation. His change is consistent with NUREG-1432. TECIINICAL CIIANGES - RELOCATIONS None TECIINICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.I Unit i CTS 3.6.l.6 Action a allows 90 days to perform an engineering evaluation when the containment structure exhibits evidence of possible abnormal degradation, per the tendon Surveillances. This requirement is being relocated to the Technical Requirements Manual (TRM), a licensee-controlled document. This is acceptable, because moving the requirement does not affect the requirement to maintain the containment OPERABLE. The requirecer! only applies when the operability of the containment is indeterminate, if there is evidence that the containment may be inoperable, prompt action should be taken to evaluate the condition to determine its impact on the capability of the containment to fulfill its safety

                                                                   - function. Questions regarding the operability of systems, structures, and components are addressed routinely during the operation of the unia. The ITS do not provide requirements for conducting operability determinations. In the event the containment is determined to be inoperable by an engineering evaluation performed in accordance with this requirement, the plant will be required to immediately enter Action A ofITS 3.6.1. The Actions ofITS 3.6.1 provide adequate protection of the health and safety of the public. Additionally, the level of safety of facility operation is unaffected by the change because there is no change in the requirement to perform an engineering evaluation to determine if the containment is inoperable. Thus, the requirement of Unit 1 CTS 3.6.1.6 Action a to perform an engineering evaluation to demonstrate containment operability can be adequately controlled in the TRM.

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. LA.2 Not used. l LA.3 Not used. l TECIINICAL CHANGES - LESS HFSTRICTIVE L.I Unit 1 CTS 3.6.1.6 requires a plant shutdown if the containment tendons or structure exhibit evidence of abnormal dea,radation, and continued operation cannot be justified by an l engineering evaluation within 90 days, improved Technical Specification 3.6.1 Action A I CALVERT CLIFFS - UNITS 1 & 2 3.6.1-3 Revision 7

r S t c.f'u.Mc 3 4.1 f 3 t,. 3/44 IONTAlletENT SYM 34,3 4/44.4 $0NTAINMENTISOLATIONVALVES l LIMITING CONDITION FOR OPERATION Leo 34 3 = 44Ad Each containment isolation valve shall be OPERABLE.* # IPPLICABILITY: MODES 1, 2. 3. and 4. AC110N: With one or more of the isolation valve (s) inoperable. either: 4'D

                                              ""      inoperpHr valvels) therR'F_t statui arrt hjy^ S M /r,,s[7AN4fg43 374skh/7--

h b.#solate each aff 1 ed penetra onwithin hours tiy use of at

        % ,3                            least one det 7gg                                 peattion,orytvatedautomaticvalvesec ed in the isolation.g,.u_) ik.M@
                                 -c.
                                                                                                                           & g m..g     ---     -

Isolate the affected penetration within hours by use of at le

                                       " ast one closed manual valve or blind flanges or                                   m,~%

10Je'r r 8t% < A - M

t. w .. ' 4 c. t. "

Actsw D 'Be in at least

                                      ,$HUTDOWN       within the140T followingSTANDBY 30 hours.              within the next 6 hours and in COLD                  t

e. M provisions pecification hat the affee are not applica ovide b' N cenetration i solated. 4.6 y

m= , . .- - - - - - - - - p h

~ 3 SUkVEILLANCE REQUIREMENTS ^

4.6.4. 1 Each containment 1s0 prior o returning the valve tion valve shall be demonstrated OPERKB rep cement work is perfo service after maintenanc repair, or on the valve or its asso ted actuator. or power circuit y perfomance of a cycling est and verif) ation) /MO c trol, isolationhi t

                                                      , w . , . ,,, ~ <- ~. n - ~ ~

C.AA% (ut ww : % y g,_ . r ,, : t^ g,.g 4. , m gg ,,4 . . L.v m ~ se +.m Q. < .m. w ., ,# , s . o. + r.a. . ~c1

                                                                                     -w~~

4- .~. ~.

   .SR 34.3."L s ua,3,3 basis under administrative control. Valves that are nonnally closedAmay be opened o LA Containment purge isolation valves isolation times will only apply mar s when 1, a . m -       _the valves are reouired to be OPERABLE and thev are opan.
                                             .._..<........,,m,,,,,.
                                                                                 ..a....,m,w.,,,h.

I53i5'i['2[ iitnal per'iecnnmfr 3k;IIEAU A. 5/ wM:h t'n "h::: v:.h;; Net a.# :h::L.- 0.1 ' . t-' g lJpf ,g CALVERT CLIFFS - UNIT 1 3/4 6-22 Amendment No. 212 M 9, Dio are.s sI 7 (, c s u (, .4 3 . L . 9, "c LS

m. 9 J

Spe.f c.bs* 2,(. 3 INSERTS 3.6.3 ACTIONS A.2 and C.2 M A.2 Note Isolation devices in high radiation areas may bc T _Eby useof ) (veMIedy administrative means i Verify the affected Once per 31 days forisolatica penetration flow path is devices outside containment isolated. M Prior to entering MODE 4 from MODE $ if not performed within the previous 92 days forisolation devices inside containment.

                                                                                        ,b m

C.2 ------Note -- Isolation devices in high radiation areas may be 7 Mby use of administrative means.- lk Verify the affected Once per 31 days penetration flow path is isolated. Pa 7 1gG u

s t u c. R u 4 . 2.f 3 I jfGERT 3.6.3 ACTION NOTES 2. 3. & 4 NOTES- --

                                                                                                        'A F   "2. Separate Condition entry is allowed for each penetration flow path, g

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

i [Entyeppp11 cable Requi ctions of . 3.6.1, 'Tw '#, era qJaakageres ex the o contal eskade mie =d ~* c '/' . 7 uwAci ad mi istrdiv e. cautrols. t'

Sp.s.Gk 3.f. 3

(3/4.6 11:U M a tWr sysitN1

      -                                                              ]                                                                         )

3/4.6.1 BlMRY CONTAtWENT

                                                                             @ Mtunity J (MyA ItwTAliettur INtratfry           S e"T*

b 3 ' b 'I /

                                                                             'C.A*.m M                    [

LIN! TING CONDITION FOR OPCAATION

                                                                                                  -- 7t -        _--

3.61.1 ' Primary CONTAl*ENT INTEGRITY shall be maintained.' 8 stat,.3,t ) APPLtfABILITY: N00t$ 1, 2. 3 and 4. A'I".s}1 An to A.t. 4 C.1 t TY within one hour or be in at least Not $TANDBY withlitthout primary CO 6 hours and in COLD $NVfDOWN within the following 30 hours. in the next h sub

        ,'7                                                                                            $ Y /.e L el
                          $URVIILLANCC REQUttr.NENTS I,#<[               "

h.6.1.1 Primary CONTAtWENT INTEGt!TY shall be demonstrated _ (i1L34.3 9

f. .t.. % 'At least once pe ggg 34 a, not capable o ys by verifying that all penhTal on **

eing closed by OPfkAbLE containment automatic l isolat ,on v [ 3 icondlt' ons ves and required to be closed durtnp accident 0 4 " automatic valves secdrea in their on postire closed by valves bitnd ' lances /or gencuv xcept7er valvfl3 fG 4, t are open unaer admimstranve cot imit onsg. ermtava te

           % .I.

gq fo. s5et requirements of spectf tcation 3.6.1.3.verif ing that each containment air ioct I .c. By verif Ing that the e j w{ g; to ente ng MODE 4 foll ng pment hatch is closed and septed, rior a shutdown l g ,by> conducting a Type B test g t tch umsf.

                   .O jy

m. _, , ny. , t .y g , p, .a 1 g QYee'er[daNtN ]k Se}*S"lyb l*Ah' *E'h H

WMl

bf*

contafnment pressure control, airborne radinactivity surveillance testing purposes only -

                                                                                                               ~
                                                                                                                       ' -"         h     controi.vanc wrr, 9                                                                           ,3      7 1

The shutdown cooling isolation valves may be opened Wen the RCS Q# 4 '3 O k temperature is below 300'r to establish shutdown cooling flo Exce t valves, bitnd flanges (and geactivatedTdt ---ti which

  # Reptred                                                                                                          l A un A.t                     otherwise secured in the closed position.are or                    ocated inside                the conta nmen_t and ar be vertfled closed during each COLD $H            These penetrat pn shall vertitcation need not be performed more o t except that suc er 92 days.

CALVERT Cliffs - UNIT 1 3/4 6-1 Amendment No.187

                                      -e.                          .
              .. , w,gWives ad W4
              ~                                     _ _ja flq U 4.n3w;m
                                                                   - - ..-. ae u                                                       \
                                                     . !~ ,s.
                                                       =
                                                                                                                                      ,h d sY$mLJ. ha.stk sv.a k

i

                                                                                                              $ pre..F.,a+.,%             *3', 6 , 3
               '54 3, c, *3 ste:t seraratur systems 8/4 M -             c0NTAIMENT 110LAtl0N VALVE 1 b

LIMITIM teelf!0N FOR OPERAT!0N t

     "       3*3 M,44 tech containment toelation valve shall be OPEAABLE.' '

APPLitAtlLifY: Mppt$ 1, t, 3, and 4. l AC119lis With one or nore of the isolation valve (s) inoperable, eithers ! L.. l yhours.m u e y,m re ie vai w u o .--- - , m - m e _ 1.. A g,,s A-g4 . hn Y,osition,oraII l'Inl*$4l N N, MI N aIO"I k tTie'l!.iatNn 4 d .s 4 c.

                                        % !solate the affected penetration within                               ours by use of at        O e-<

8 5 3.9g

=-

Acr ot,;

                                             *least one closed manual valve or blind                          angel or q
                                                                                                                                           ** I' 50 4 3. as A-. .
                                                                                                                                                                    '* b1 O      -   -
                                        % te      in 90WN
                                              $ NUT       at least within the   NOT following   $7AN08Y 30 hours.           within the next 6 hours and in COLOM  ~-

i 1

f5th

                                                       - w -- _

tr Ibsi d.

             ~~~                        N                c s l.o ll

[w st m .a tion *. N -_oi r.$ @ (

                                                                                                                                                                 .g
  \,                           SURVIILLANCE REQUlttMENTS
                                    ~
                                                                                                                                            ' - h,6 fi.6.4.1            Each containment prior                                           olation valve shall e comonstrated OP BHP rep cement work sthe returnin         perfval - to service after m ntenance repair.

d on the valve or s associa ed act or.

                                                                                                                                                    '                         i L c,p trol, or power circ                                                                                                            'I MLJsolation t,i'ne.                        by    perfonnantt.nf. . cycling.te1Lan atifjr.ation)                                                  ,
                                                              /-

C. s. .., f\.( T3 doTr. ! cay pg,

                                 ~.~                  _

L ,. c, / , a s

                                                                                              ,wi, s , p ,, ,4 ... ,, ,, f e _ [i       e, , ['Q A 9
                                                                                                    ~n et. ..o 9 3 4 ad '                                  #-~ _
                                                 < u en n                              _

oi y ,.p po , ., s. i c p = p,- _

                                      "                                                                     y, s . . %              g. . t .,              ....

Qe Civ . 4 e t .. 4 .,,.,.. E #. 3 J, .1. L ( s p, 3,4, ,3,3 Valves that are nonna11y closed may be opened on an intermittent basis under administrative control. htT1nment purge isolation valves isolation times will only apply inl MODE 6 when the valves are reavired to be OPERAttr and they are aopen / ( pg];tj= t'= 'n n c._m M Q , h.. .'. j ena g per

                                                                                             .,rvy ,. g r :: i g g g._ g      ig , q                           g*,*j8 ivrase6nn         us 6i m ..-
                                                                                                                         . . .. . i n                               ,

y n ,v must remain g, CALVERT CLIFFS . UNIT 2 3/4 6 18 Amendment No. 189 'I 5,, .4, s . . . - # ch. 3 (. ,, , c yp.r.0 ..,4-e- 3.3. w c y ** bChit, he ) 37 M

_ _ . _ . ._. -. . . . . _ _- ~ _ _ . _ . _ _ . _ _ . _ _ _ _ _ . Spe(sehert.iee3 1 i e INSERTS 3.6.3 ACTIONS A.2 and c.2 i 1 A.2 Note 1 solation dwicesla high ! i radiation areas may be - o Vetfieb Mbyuse of adminierative ===. d i j Verify the affooted Onos per 31 days forisolation !

penetration flow pattils dwloss outside containment l leolated. ,

h8Q

Palor to caterlag140DE 4 from MODE $ if not performed whhin i

the prwlous 92 days forisolation

dwloos inside containment.

i

'                                                                                                 _                                                                                                                b 4

AND

!-                                                                                       C.2 --.-                     -Note             -
,                                                           . . .                             Isolation devices inhlgh i

radiation areas may bc l SififEi)by use of administrative means. ? Verify the affected Once per 31 days

. penetration flow path is 4

isolated. J i i b d 4 i l t a f i i i ' Ed y 1 h

_ ___._...-m.__ _ _ . _ . . _ _ _ . _ _ _ _ _ _ _ _ . _ _ ___ - - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ S pc.Fu4.s 3. t. 3 lNSERT 3.6.3 ACTION NOTES 2.3. A 4 NOTES

2. Separate Condition entry is allowed for each penetration flow isth, h l

3. Enter applicable Conditions and Required Actions for systends) made inoperable by l

e '- =2 isolation valves. l 4p%%pi' i .x ap leConds and A b03 m= [.-4.,i 'T - ' # ^" i

                                                                               .e       u-#                                                                        ;

3

                           '         l.      %                   b &le,o pAkt maj b udsekh) Mori4caly u.dec                                                                         :

agedr4%e<m4r,Is. -_f I d P ' y 3 p to

S pac fsca b 3 4 3 l 3/4.6 it![IAJmtWT $YSTEH1 3/4.6.1 g, ,p 4 titMA'RYCONTAINMENT A @cta.b 3, g,,( CMTAl*E!!I 1EIGRITY " d '* C LIMITINs I antitM FOR OPERATIM 3.6.1.1 Primary COUA!WEM IMEGR11Y shall be maintained.*~ t APPL 1tABILM MODES 1. 2. 3 and 4. NI+Uih 4 te vleect Without primary CONTAlletENT INTEGRITY restore CMTAtletENT As iew a ITY within one hour or be in at least NOT STANDIY wit 6 hours and in COLD SHUTDWN within the following 30 hours.hin the next A,1 4 C t ~ J p j jg,,f I wIsb,e,r ok.aae. U f SURYE!LLANCE REE*!RENENTS - - - J.6.1.1_ Primary CONTA!stNT INTEGRtTY shall be demonstrate JR J4 JJ ll 3.fe.S 2. J

                             @    tat least once p not capable sys y vertrytn N 3'0'3'3      1                 isolation            eing closed by OPERAlfE containment automaticthat                 4       all penetratto ves and required u be closed durinn (gon11 tion are closed by val _ves
                                      }omatic valves secured 'n thT ll_ind 'lancesFo.Etidtn   r deactivated u    at_ are open under admin'strat<              ons/except for valves]

open T mun .L BA.I. ve (o@hriuraanr Posit , I. B -

          ,                        tfe requirements of Specification 3.6.1.3.verif ing that each containmen
       *h4 t                     c. By vert to ente that the e    pment hatch is closed and sealed, rior j::4{                                      MODE 4 foll     ng a shutdown by conducting a Type B test                   gopnt atch
                                                                                    . . _ . ._ . w . ty                              l 4

se___ dno.es - - wid le Cu,fi~ed lu)sge %k Tnhm heam.

~_

l k.TallW h* f A _. m j dro en purge containment vent isolation valves a W m. LR 34.3. I ..& **j k WhTW for C conta nment surveillance pressure testing control, purposes only airborne radioactivity _ control.gend % t*# Nart' 4 A ~jg The shutdown cooling isolation valves may be openeYthe RCS y temperature is below 300'T to establish shutdown cooling flow ua 3 %'38 1 [d Re,ptred Exce t valves, bitnd flanges (and deactivated automatic valviDwhich 6 are ocated inside the conta nment and are locked, scaled or Ac h, m A 'L othenrite secured in the closed osition. These penetrat ons be verifted closed during eacn C Lo SH shall verification need not be perfomed more c except that such ten then once per 92 days. CALVERT CLIFFS . UNif_t 3/4 6- [N.7 .ieT A - ~1 ~ Amendment No. 164

          %e,a up% am wea ~ _my _ _ke ars,<& Q w ,e MarTy";

g& gj ^" _-- - Uce.a Ases nb b

DISCUSSION OF CHANGES SECTION 3.6J CONTAINMENT ISOIATION VALVE 8 direction consistent with the intent of the existing Actions for the containment isolation valves. His change is consiskat with NUREO 1432. A.6 ' improved Technical Specification 3.6.3 will contain an Actions Note (Note 3) which requires i entry into applicable Conditions and Required Actions for system (s) made inoperable by l CIVs. Current Technical Specification 3.4.3.1 does not contain this requirement. nl l change adds a requirement to declare system (s) inoperable that are made inoperable by inoperable CIVs. Als Action was 6dded because, per ITS LCO 3.0.6, only the Actions of the CIVs would have to be entered. However, since Inoperable CIV: require isolation of penetrations to the abeted system (s) with continued operation, cascading to the abeted system is prudent. This requirement is necessary because unlimited continued operation with a system inoperabic could severely a%ct the mitigation of accidents and violate the safety analyses. De CTS does not contain a Specification similar to LCO 3.0.6 and, therefore, already requires cascading. De addition of a requirement which is already required in the CTS is an administrative change. His change is consistent with NUREG 1432. A.7 Not used. l A.8 Current Technical Specification 4.6.4.1.3 requires the isolation time of each power-operated or automatic CIV to be determined to be within its limit when tested pursuant to Technical Specification 4.0.5. Improved Technical Specification will require the SR to be performed in accordance with the Inservice Testing Program, nis change is administrative because ITS moved CTS 4.0.5 and incorporated it into the Inservice Testing Program, which is required per ITS Section 5.0. De requirement to perfonn the SR has not changed. His change is consistent with NUREO 1432. A.9 Current Technical Specification 3.6.4.1 does not specifically have different Actions for dl% rent types of penetrations, improved Technical Specification 3.6.3 contains Actions for dl% rent type penetrations with di% rent numbers of valves inoperable, improved Technical Specification 3.6.3 Actions A and B will contain a Conditions Note which specifies that these Conditior.s only apply to penetration flow paths with two CIVs and not a closed system. Improved Technical Specification 3.6.3 Action C vill contain a Conditions Note which specifies that this Condition only applies to penetration flow paths with one or more CIVs and a closed system. Adding Notes which specify which Actions are applicable is an administrative change because the requirement is not affected technically. A.10 Unit 1 CTS 3.6.1.7 Action a requires an open containment purge supply and exhaust isolation valve to be closed, improved Technical Specifiestion 3.6.3 will require an inoperable containment purge supply and exhaust isolation valve to be closed. The ITS combines all containment isolation valves into one specification and does not specifically contain Actions for the containment purge system valves. Herefore, tie ITS Actions require the valves to be closed when the valve is inopemble, ne bases will re tuire the containment purge supply and exhaust isolation valves to be closed as a part of their Operability requirements. Herefore, changing closed to inoperable in the Actions is an administrative change, nis change is specific to Unit 1 because the Unit 2 containment purge and exhaust isolation valves located outside containment are being replaced with blind flanges for operation in Modes I through 4. He Unit I containment purge and exhaust penetrations will also be modified to have blind fianges installed during the 1998 Unit I refueling outage. CALVERT CLIFFS UNITS 1 & 2 i 't 2 Revision 7

                                                                                                       $f -cobahoa %O INSERT _6,5,6 (Pge i a z.D Leakage rate acceptance criteria are:

he,cebdmt 219) h i a. Containment leakage rate acceptance criterion is s 1.0 La. During the first unit startup, following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 Lafor Types B and C tests and s 0.75 La for Type A tests.

b. Air lock testing acceptance criteria are:

1. Overall air lock leakage rate is s 0.05 La when tested at a P,. 2. For each door, leakage rate is s 0.0002 a L when pressurized to d 15 psig. l f9pc 10d O

l

   ,          #45 FAT (o,C 6 dhsG Z of 7-)

f 406NCONTMMENNYSTERF P** '" ,o Jun ILber abREN $ n 0%4, ML %n Obwig taknetwt ragwamtds wqt. tsdah velas U WWEluS4Pel f io h)

4. $ Containment purge Isolation valves shall be demonstrated OPERAB M d::" ti= uper er.teria; ::^;; ; fra, pser cp;r:tica ::es, s,,1w

              %             iest surveillen:2 test he; b :a F;rf;md within ti,e past      A3I 6.5.16       0 44    +h :=ti; x any time after being opened and prior to entering N00E 4 from shutdown modes by verifying that when the measured      AI Jenkape rate is added to the leakage rates detemined pursuant to
         ,NWnwt    m .een     4 3rwif teetica t 0.:.".a for all other T B or c penetrations, the combined leakage rate is less tfpe                 i (v   L44%s%k 0.60 L Tastg by.
                .J an or equal to The leakage rate for the containment purge isolation valves..shall also be compared to the previously measured rate to detect excessive valve degradation.

l lea L. i E8A $ containment purge isolation valve seals shall be replaced new seals at a frequency to ensure no individual seal remains in service greater than 2 cons Un.4 I gt ibc1 sf G \ h CALVERT CLIFFS - UNIT 1 3/4 6-3 Amendment No. 219

DISCUSSION OF CHANGES SECTION S.0 - ADMINISTRATIVE CONTROLS A.29 Unit 2 CTS 4.4.10.1.1 contains a footnote that allows the reactor coolant pump flywheel inspections for the first inservice inspection interval to be completed during Unit 2, refueling outage number 9. His footnote is being deleted. Unit 2, refueling outage number 9 has been completed and this note is not longer needed. A.30 Current Technical Specification 4.4.5.5 requires that steam generator inspection reports be submitted pursuant to 10 CFR 50.4. Improved Technical Specification 5.6.9, " Steam Oenerator Tube inspection Report, "will not reference 10 CFR 50,4. Title 10 ofite Code of l Federal Regulation 50.4 contains general requirements on correspondence and applies I whether or not it is referenced. Eliminating a reference to a regulation is considered ! administrative. A.31 Unit 1 CTS 4.6.1.2.b requires the containment purge isolation valves to be demonstrated OPERABLE any time upon entering MODE 5 from power operation modes, unless the last l surveillance test has been performed within the past six months. De ITS will not contain this requirement. This proposed change is acceptable, because the MODES of Applicability for Unit 1 CTS 3/4.6.1.2 are MODES 1,2,3, and 4. The SR requires the containment purge isolation valves to be tested Iri MODE 5; a MODE for which the specification is not applicable. Current Technical Specification LCO 3.0.1 requires compliance with an LCO during the OPERATIONAL MODES or specified conditions stated within the LCO. Additionally, CTS 4.0.1 states that the SRs shall be applicable during the OPERAULE MODES or other conditions specified for individual LCOs unless otherwise stated in an individual SR. Unsed on CTS LCO 3.0.1 and SP. 4.0,1, the aforementioned requirement of CTS 4.6.1.2.h is not required to be met, since it is required in a MODE for which the LCO does not apply. Thus, its deletion is an administrative change. TECitNICAL CIIANGES . MORE MFRTRICTIVE M.1 Not used. M.2 The proposed change incorporates the following new programs into the Technical Specifications. Component Cyclic or Transient Limit (ITS 5.5.5) . This program is set up to provide controls to track the UFSAR. identified cyclic and transient occurrences to ensure that components are maintained within the design limits. His program currently exists at Calvert Cliffs. Secondary Water Chemistry Program (ITS 5.5.10) . This program provides controls for monitoring secondary water chemistry to inhibit steam generator tube degradation and low pressure turbine disc stress corrosion cracking. This type of monitoring currently exists at Calven Cliffs. The addition of these new requirements to Technical Specifications is considered a more restrictive change with no adverse impact on plant safety. This change is consistent with NUREG 1432, 1 CALVERT CLIFFS . UNITS 1 & 2 S.0 6 Revision 7

Containment (Ataes BAlts Atil0NS R.1 and R.f (fontinued) N00E in which the LC0 does not apply. To achieve this status, the plant must be broueht to at least MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed based on operating Completten experience to reachTimes theare reasonable,d require plant conditions from full Powercondlttonsinanortlerlymannerandwithout .' challenging plant systems, l SURVI!LLANCE 1R 3.8.1.1 l REQUIREM(Ni$ Maintaining the e nment OPERABLE requires compliance i with the visua examint,1on and : eakage rate test eC,-[,- Nr n:.h o 10 CFY ED. - - - - - m a rum v r . an .new t1# f allure to meet (girimfk,edl Mt

p'y w ilvM N u n m m A ja leaka L40 L.1,.;! and LCO 3.6.3 does noke 1{ mill spec fled T J \g "T"< rl+d trv.,rm invalidate the l acceptability of these overall leakage deteminattens unless 1

[ E*by . ,A 5g their contribution to overall Type A 8 and C leakage causes that to exceed limits. As left !eaktse fir .t startup after performing a required von erlor to the d'U% *

                                                                                                                                   //3 W      h app  inan in leakage test is required lo be hi , L. or            tm 4' *% 4k/r ' .,6.Q        coti>ined   Troe 8 and C leakagg. and 50.75 L,g oversis g%                                 8 3                        TyH A le rre;e tesY M  all cinW    times    bMween      requiree      leasagi\

T(1 B ** A C 48

        "                                          e acceptance eriteria is based on an overall Type A les age limit of s 1.0 L . At s 1.0 L the offstte L & n cou                      see dose consequences are bounded bit the assumpti,ons of the

) safety analysts. $R Frequencies are as reeutred by r,N,,)'*'*-*/or dd leina 44,d mil. L.Q R:t o, si. ii pi~ py approvea ex lions. Inus, l .2 tukich allets Freauenev extepions) does not 1. T *- sese periodic testing re that the A +"3\] containmentleakaerate$utrementsverif(heleakagerate oes not exceed assumed in the sa sty analysis. _

                                                                   * * "M'M* A N'S O 'M 1              "**E 4tdoM % ,W / J ,/*               g,

N "Y pung """.\amw

                                                             'ss             p utniaqbemet. ( d'                                           \
      $$r R4,n.                        3,g,3,,                                                  __

h

   'f't.,f    , 8 the  structural integrity of the conta this SR ensures that Forungroute1.Postter.sionedtendonslementwillbe                                       9.-

p maintained in accordance with the provisions of the Containment Tendon Surveillance Program. Testing and frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4). (continued) CEOG ST$ 8 3.6-4 Rev1,04/07/95

Containment Isolation Valves O t:::;t: ys) d S:"f 3.6. @ 3.6 CONTAINMENT $YSTEMS 3.6.3 Containment Isolation Valves P'r:;h;d: n.d 5:1)-- Q M4l)LC03.6.3 Each containment isolation valve shall be OPERABLE. APPLICABillTY: MODES 1, 2, 3, and 4. ACTION $ ag . ~ n i tec t., l.-

                                         ... ....... ...            ... .nm uc....................        _ .. _ ...

g s].atton flow paths)may benLI421 unisolateIMe valvwnetrasionJetno termittently under aaministrative controis, @ a.g.$ nth. Separate Condition entry is allowed for each penetration flow path.

         /      ***,M.         Enter applicable Conditions and Required Actions for system (s) made
         \M                    inoperable by containment isolation valves.

I 3.f,,1. ) 4. ' Ente ( applic e Condi ns and F..Wie d

when kage re isutred A in ev$tions eeding of t VLIAI3.6.1,/

overall en S A ['ontainee

                           ..L
                                        $....!.$$$!$..."$!.I .I S ................................tnin       .........
                                      . CONDITION                        REQUIRED ACTION            COMPLETION TIME A.   ------- NOT E------- A1                  Isolate the affected    4 hours only applicable to                      penetration flow path penetration flow paths                  by use of at least with two containeen                     one closed and isolation valve          ,4
                                                              ,i . 4      de-activated                                    g 3' f. 4. t L- nj94          automatic valve, closed manual valve,                              11 hl A"d ' b

c. One or more , blind flange, or penetration flow paths check valve with flow A with one containment through the valve /h isolation valve secured.

inoperablel[ cept f r rFu " valve akage Alg) an hield 11di (continued) CEOG STS 3.6-8 Rev 1, 04/07/95 , Sh y esn 4 ,a.w. , ,, h u% n eawr +. esua a u ri,s.

                                                          ._ v , ,, ..a                  m . 4 . ,, ..a., <

s g g

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SEC'IION 3.6 - CONTAINMENT SYSTEMS PLANT SPECIFIC CilAhifaES

1. This change deletes the terms Atmospheric and Dual in parentheses. Dese terms were placed in the NLIRUn 1432 titles to inform the users that the Specification is for atmospheric and dual containment plants. Dese informational terms are not required for the Calvert Cliffs improved Technical Specifications (ITS). Calvert Cliffs has an Atmospheric containment and will adopt the applicable Specifications. His change also applies to the deletion of NUREG 1432 Specifications that do not apply to Calvert Cliffs, and any ,

designations in the titles that relate (e.g.,3.6.6B Containment Spray and Cooling [ credit not l J taken for iodine removal) was deleted). j P

2. He change to the non bracketed system name, number of tstems/ components, terminology, or value was changed to be consistent with Calvert Cliffs specific system name, number of systems / components, terminology, or values. n s change also includes any numbering changes due to the addition or deletion of Specifications, Actions, or Surveillance j Requirements (SRs).; 3. His change deletes all of SRs and Actions related to the containment purge isolation valves. ,
Requirements for the containment purge isolation valves will be located in Section 5.5.16, i " Containment Leakoge Rate Testing Program" for Unit I and Section 3.9, " Refueling operations," for Units I and 2. He requirements for the Unit 2 containment purge isolation j valves in Mode 1,2,3, and 4 will be deleted. Calvert Cliffs submitted a license amendment which deleted all requirements for the purge valves because the valves are being blind fianged in Modes 1,2,3, and 4, which climinates the need for a containment isolation valve for this penetration. His change is consistent with the proposed Technical Specification change submitted from Mr, C.11. Cruse (Baltimore Gas and Electric Company) to NRC Document Control Desk, dated August 1,1996, License Amendment Request, Use of Blind Flange in Place of Containn ent Purge Valves During Operations. This request was approved in License Amendment No.197 for Facility Operating License No. DPR 69.: 4. A Note was added to Specification 3.6.3 Limiting Condition for Operation Notes which allow the shutdown cooling (SDC) isolation valves to be opened when Reactor Coolant System temperature is < 300'F to establish SDC flow. He Note was added to allow SDC to i be established in Mode 4 when Reactor Coolant System temperature is < 300'F, which is i contradictory to Note I which only requires penetrations to be opened intermittently. This change is required to enable Calvert Cliffs to establish SDC and is consistent with the ,

j Calvert Cliffs current licensing basis.

5. These changes incorporate Calvert Cliffs specific information into brackets. Bracketed information located throughout NUREG 1432 will be replaced with the specific Calvert Clifts requirements. This change also includes deleting bracketed items when it is not consistent with the Calvert Cliffs des!gn, i

a 6. He Applicability Section ofITS LCO 3.6.6 was modified to require the Containment Spray System to only be operable in Mode 3 when the pressurizer pressure is it 1750 psia. His 4 proposed deviation is consistent with Footnote

to the Applicability Section for CTS LCO 3.6.2.1. In conjunction with this change, the requirement in Required Action B.2 was changed from "Be in MODE 5" to "Be in MODE 3 with pressurizer pressure < 1750 psia."

This proposed change would place the unit in a condition for which ITS LCO 3.6.6 does not i CALVERT CLIFFS UNITS 1 & 2 3.6-1 Revision 7 I 1_ .

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 ; SECTION 3_6. CONTAINMENT SYSTEMS ' apply, it is consistent with the philosophy provided throughout NUREG 1432. He Bases ! for NUREO 1432 LCO 3.0.2 states: "ne first type of Required Action specifies a time limit in which the LCO must be met . . . If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the imit in a MODE or condition in which the specification is not applicable." Additionally, the Completion Time for Required Action B.2 was changed from "84 hours" to "12 hours". nl time la consistent with the Completion Time of Required Action B.2 ofITS LCO 3.5.2, which also requires the plant to be placed in Mode 3 with pressurizer pressure < 1750 psia.

7. He shutdown track in Required Action B.2 was changed from a requirement to be in Mode 5 in 36 hours, to Mode 4 in 12 hours, nis change was made because the Calvert Cliffs Containment Spray and Cooling Specification is only applicable in Modes 1,2, and 3. nl change is consistent with other Technical Specifications (when not modified and justifled in the Bases) when shutting down to Mode 4,

8. A Surveillance (ITS 3.7.6.2) was added to NUREG 1432 Specification 3.6.8 (Calvert Cliffs ITS 3.6.7) which requires the performance of a Channel Calibration of all hydrogen recombiner instrumentation and control circults every 24 nonths. nl test is consistent with Calvert Clift ' current licensing basis.

9. The change adds an Action to NUREG 1432 Specification 3.6.10 (ITS 3.6.8) which incorporates an Action when two lodine Removal System trains are inoperable. Calvert Cliffs deviates from the standard Combustion Engineering plant in that it has three trains of lodine Removal System. Two trains are required during a design basis accident. One of the three trains is a swing train and has to be powered from the correct bus to maintain separate ;

and independent trains, in order to perform this alignment without entering Limiting Condition for Operation 3.0.3 (there is no Action for two trains), Action B was added. Action B allows one hour to restore one lodine Removal System train to Operable status. This change will not increase the total time allowed to be in Mode 5 (Limiting Condition for Operation 3.0.3 allows 37 hours, and Actions B and C combined would also allow 37 hours).

10. NUREG 1432 Condition C is for one or more penetration flow paths with one containment isolation valve inoperable and is only applicable to penetration flow paths with one containment isolation valve and a closed system. Calvert Cliffs ITS 3.6.3 will retain the same requirement as the NUREG except the Calvert Cliffs Nuclear Power Plant ITS will also

 ,                               apply to those closed systems with more than one containment isolation valve. Calvert Clifts is a r.x General Design Criteria plant with closed systems that contain one or more containment isolation valves, in conjunction with this change, a phrase was added.to Conditions A and B Conditions Notes which specify that thse Conditions only apply to penetration flow paths not in a closed system. This change is consistent with Calvert Cliffs design.

11. In ITS 3.6, changes have been made *.o reflect the implementation of 10 CFR 50, Appendix J, Option B. His is cansistent with Calvert Cliffs' current licens'ng basis as approved in License Amendment Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively. Rese License Amendments were issued on February 11,1997, 12, Action Note 4 for NUREG 1432 LCO 3.6.3 requires the applicable Conditions and Required Actions of LCO 3.6.1 to be entered, whenever leakage results exceed the overall containment CALVERT CLIFFS UNITS 1 & 2 3.6 2 Revision 7

DISCUSSION OF TECilNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 3.6. CONTAINMENT SYSTEMS _. l leakage rate acceptance criteria. His Action Note has been deleted from ITS 3.6.3, because i ITS 3.6.3 contains no requirements regarding leakage rates. As discussed in additional JFDs for ITS Section 3.6, the SRs (i.e., SRs 3.6.3.6 and 3.6.3.9) and Actions (Actions D and E) associated with leakage rate testing of the containment purge valves with resilient seals and secondary containment bypass leakage paths have been eliminated from ITS 3.6.3. Due to the elimination of the requirements regarding leakage rates from ITS 3.6.3. Action Note 4 for NUREO 1432 LCO 3.6.3 is not appropriate to include in ITS 3.6.3. Dus, the note has not been included in ITS 3.6.3. I CALVERT CLIFFS - UNITS I & 2 3.6-3 Revision 7

Containment isolation Valves '"---- " " ^ " @ B3.6.5 BAlt$ (c.ntinued) ACTIONS The Act ONS are e.L died by a Nous a11mina nanaurat y, i - , rur w nen ur; m va senstst en flow ur rF Mi,e se on se tes Intere10ent'y unser ase ateurH

s. These administrative controls consist of tve W) stationins a dWicatW is in con this way,tinuous commun.perater ication with the control rose.

the penetration can be rapidly isolated when 4 at the In v41ve.centrols, who 7% (buth NL ell*WZ ' ' " ' w e er ne wei.a u ... r.. ws .r usn and fact W4 Aib.C 11 that se pentreuens exh,.itdiric_tlycree the f %*I'c s ./, 4[, qw,c/ 6 %WAt .I'* ["7I *I"N,m to tstra 5 a L u<w4 Y'" # " % < a n A sec.w not. has seen udW te provide cialiticatt.n that, for tus tco se

   , e s, m, e,c /,u-              le'.notreu.o vired Acu ow h.n     ,,s ate ath. This    is .ccecondinas tabie, sinceent,ry the        i. aue.ed for each TL. a a e. ,,                                       f.,e.sh condition revide a,r a< o.ns f- o ,r. h., ,. , 5. ,a        c".

is au tens.ator,ive. n va iyic ,for each in. r,a6ie ent contain ,riate an,w f., conunued peralwith o athe no.uired Actions .ay contain.ent is.ian.n vaives a,r.u sese y s as..uent ew ( 4 //.s condiu.n entry and a,,ucau.n of.vernehvent in.,eraie associat u no.uired Mc de . &#. ACII'"8' u Md'd' The ACTION $ are further modified by 4 third Note which ensures that appr*priate remedial actions are talen if necessary, if the effected systems are rendered inop,erable by an inoperable containment isolation valve. { A f eth hote been ed e.uires atry in h a cable nditio coedine,t d Re Act of tC0 .I who kage ults in e over coatal t leakene

/\

limit. g Q A.1 and A.t in the event flow senetration one saths containment isolation valve in one or more is inoperable les [ancept tar purgs vatre A and shtaWHTTiinn -us~ in akane M t within / < W The as h.the affected pinetration flow path must be isolated. d of isolation must include the use of at least one isolatt.n barrier that cannot be adversely affected by a single active failure. Isolation barriers that aset this criterion are a closed and de-activated automatic containment isolation valve, a closed manual valve, a blind i h 4. (continued) cE00 $T5 8 3.6-23 Rev1,04/07/95

INSERT 5.5 (Containment Leakage Rate Testing Program as approved in License Amendment Hos. 219 and 196 to Facility Operating Lisense Hos. DPR-53 and DPR-69) 5.5.16 Containment Leakage Rate Testing Program /hi A program shall be established to implement the i leakage testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR Part 50, Appendix J, option B._ This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, SPerformance-Dased Containment Leak-Test Program," dated September 1995, including errata. i The peak calculated containment internal pressure for the design basis loss-of-coolant accident, P., is 49.4 psig. The containment design pressure is 50 Tsig.

The vaximum allowable containment leakage rate, L., . shall be 0.20 parcent of containment air I weight per day at P..

Leakage rate acceptance criteria are

a. Containment l'aakage rate acceptance criterion is s 1.0 La. During the first unit startup, following testing in accordance with this program, the leakage rate acceptance oriteria aro. s 0.60 L. for Types B and C tests- and 5

0. 75 L. for Type A tes ts ,

b. Air lock testing acceptance criteria are:

1. Overall air lock leakage rate is s 0.05 L.

when tested-at 2 P., r , 2. For each door, leakage rate is s 0.0002 L.

   #Id5b when pressurized to 2 15 psig, f.C.Ib-l H The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

4.6 A SUR in t .%s bin pep issleMan veWant;g espyd a#v%% u.a i teAmme.d a,

                                          . Containment r"               purge isolation

Z 5 valves

                                                                                        ' -     shall be demonstrated OPERABLE   A
                                             >t i;     tt;r.;  upi, .:.t:75;t het .....t!!!-                         x:
                                                                          ?- st hee h^.;;;;rfed;;setien               Et;. rless (4 2-'-
                                                                                                        "'thiri i/nw pirt i

Tha 04+1 NODE 4 from shutdown modespriorbyto *verifying entering that Wien th leaka v--' e rate is added to the leaka g-"'!;::tfi;et;er 0.0.1.0.: ge rates determined pursuant to ' for all other Type B or C penetrations, O.60 L,. The leakage. rate for the contairment on i purge iso valves shall also rate to detect be compared excessive to the-previously measured leakage valve r%;radation. b, T

                                      @wt containment purge isolation valve seals shall be replaced                            }

new seals at a frequency to ensure no individual seal remains in service greater than 2 consecutive fuel reload cycles. t)< .'4 I i

                                       @ @ t.mkop. % kT*tM Y "

[CAWdIT cl.IF UNI Ajndhnt[1) I

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 SECTION 5.0 - ADMINISTRATIVE CONTROlE 10 CFR are required to be met. Rus, these requirements do not need to be reiterated in the ITS. ; Additionally, a generic change (TSTF.121) has been proposed to resolve this issue. l l

35. Cunent Technical Specification 6.5.6 provides the requirements for the Containment Leakage Rate Testing Program. His program was recently revised in License Amendment Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively. These License Amendments were issued on February 11, 1997. Bey adopted Option B of 10 CFR 50, Appendix J. This program has been incorporated as ITS 5.5.16. He cunent licensing basis has

      -been incorporated, because TSTF.52 has not been approved by the NRC, Additionally, requirements from Unit I CTS 4.6.1.2.b and 4.6.1.2.c have been added to the Containment              '

Leakage Rate Testing Program. Rey require: a) the Unit I containment purge isolation valves to be demonstrated OPERABLE any time aller being opened and prior to entering MODE 4 from shutdown modes by verifying that when the measured leakage rate is added to the leakage rates determined pursuant to the Containment Leakage Rate Testing Program for all other Type D or C penetrations, the combined leakage rate is less than or equal to 0.60 L,t b) leakage rate for the containment purge isolation valves are compared to the previously measured leakage rate to detect excessive valve degradation; and c) the containment purge isolation valve r,cals to be replaced with new seals at a frequency to ensure no individual seal remains in service greater than 2 consecutive fuel reload cycles. These requirements provide assurance that the Unit I containment purge isolation valves are OPERAllLE; they are being provided in lieu of NUREG.1432 SR 3.6.3.6. While the proposed containment Leakage Rate Testing Program is not identical to the program proposed in TSTF 52 for incorporation into NUREG 1432, it is technically equivalent (except for the additional more restrictive requirements for the Unit I containment purge isolation valves). CALVERT CLIFFS UNITS 1 & 2 5.0 5 Revision 7

29. While reviewing the LA IXX's for ITS Section 3.6, several issues were identified (l.c., 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 flases were not included in the liases). The following changes were required to resolve the issues: 1) the ISTS liases Markups for ITS 3.6.3 were revised to include information that was deleted from the CTS via LA.3 fot ITS 3.6.3; 2) the ISTS liases Markups for ITS 3.6.6 were revised to include information deleted from the CTS via LA.I for ITS 3.6.6; and 3) the ISTS Ilases Markups for ITS 3.6.7 were revised to included information deleted from the CTS via LA.1 for ITS 3.6.7.

l l

Containment Spray and Cocling Systems B 3.6.6 BASES to the containment imp (s). Each spray system flow path from the containment ump will be via an OPERABLE shutdown 7 cooling heat exchanger. The Containment Spray System provides a spray of cold borated water into the upper regions of containment to reduce containment pressure and temperature and to reduce 7 the concentration of fission products in the containment atmosphere during a DBA. The RWT solution temperature is an important factor in determining the heat removal capability l of the Containment Spray System during the injection phase. In the recirculation mode of operation, heat is removed from l the containment sump water by the shutdown cooling heat exchangers. Each train of the Containment Spray System provides adequate spray coverage to meet 50% of the system design requirements for containment heat removal and 100% of the iodine removal design bases. The Containment Spray System is actuated either automatically by a containment spray actuation signal (CSAS) signal coincident with a safety injection actuation signal (SIAS)ormanually. An automatic actuation starts the two Containment Spray System pumps, and begins the injection phase. The containment spray header isolation valves open upon a CSAS. A manual actuation of the Containment Spray System is available on the main control board to begin the same sequence. The injection phase continues until an RWT level Low signal is received. The Low level for the RWT generates a recirculation actuation signal (RAS) that aligns valves from the containment spray pump suction to the containment sump. The Containment Spray System in recirculation mode maintains an equilibrium temperature between the containment atmosphere and the recirculated sump water. Operation of the Containment Spray System in the recirculation mode is controlled by the operator in accordance with the emergency operating procedures. CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-2 Revishn f 7 I J

Containment Spray and Cooling Systems B 3.6.6 BASES LCO During a DBA, a minimum of one containment cooling train (3 of the 4 coolers) and one containment spray train is 7 required to maintain the containment peak pressure and temperaturebelowthedesignlimits(Ref.3). Additionally, one containment spray train is also required to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analysis. To ensure that these requirements are met, two containment spray trains and two containment cooling trains (all four coolers)mustbeOPERABLE. Therefore, in the event of an accident, the minimum requirements are met, assuming that the worst case single active failure occurs. Each Containment Spray System includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWT upon an ESF actuation signal and automatically l transferring suction to the containment sump. Each spray system flow path from the containment sump will be via an '? OPERABLE shutdown cooling heat exchanger. Each Containment ruling System includes cooling coils, dampers, fans, instruments, and controls to ensure an OPERABLE flow path. APPLICABILITY In MODES 1, 2, and 3, a DBA could caust a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment spray trains and containment cooling trains. The conteinment spray system is only required to be OPERABLE 7 in MODE 3 with pressurizer pressure d.1750 psia. In MODE 3 with pressurizer pressure < 1750 psia, and MODES 4, 5, and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Thus, the Containment Spray CALVERT CLIFFS UNITS 1 & 2 B 3.6.6-5 Revisiong7

Hydrogen Recombiners B 3.6.7 BASES reasonable to ensure the instrumentation and control circuits are calibrated at an interval to accomplish the above requirements. SR 3.6.7.3 This SR ensures that there are no physical problems that could affect recombiner operation. Since the recombiners are mechanically passive, they are not subject to mechanical failure. The only credible failures involve loss of power, blockage of the internal flow path, missile impact, etc. A vicual inspection is sufficient to determine abnormal conditions (i.e., loose wiring or structural connections, deposits of foreign materials, etc.) that could cause such 7 failures. The 24 month Frequency for this SR was developed considering that the incidence of hydrogen recombiners failing the SR in the past is low, t SR 3.6.7.4 This SR requires performance of a resistance to ground test for each heater phase to ensure that there are no detectable l grounds in any heater phase. This is accomplished by verifying that the resistance to ground for any heater phase is 2 10,000 ohms. This test is usually performed after SR 3.6.7.1 to verify the integrity of the heater electrical circuits. The 24 month Frequency for this SR was developed considering that the incidence of hydrogen recombiners failing the S" in the past is low. REFERENCES- 1. 10 CFR 50.44

2. UFSAR, Appendix 1C CALVERT CLIFFS - UNITS 1 & 2 B 3.6.7-6 Revisiony7

Containment spray and Coell..j systems t'.^ n ;'_ % g 8 3.6 CONTAllMENT SY$TDIS 8 3.6.$ gntainment m.__.. Spray and, Cooling Systems, ?'G-;;G;d;,qjyni' 8 BA$ts BACK6ROUle The Containment Spray and Containment Cooling systems provide containment atmosphere cooling to Ilmit post accident pressure and t reture in containment te less than the desten values. tien of containment pressure and the tedine removal capability of the spray reduce the fO MM Appen/.a .1C release of fissten product redtesetivity from containment to

             .                   / the environment, to within limits.in    the event of a Design Basis Accident The Containment spray and g448- TS, 59j 6oj ) {06A);amontonta                 Cooling systems are_ designed,te the requirements i

O, 61., 63, 44 ,,j gg- Q ,[,5 " '3 { .j$ pect $ ' system ,- CoE5IIment $est'Remo c,,, c 2 ) , so, Tuting er ontainment not R en ise et 42, Contat t Atm - sdnsp. . ion of Containment inti of Cent at tau re Ci.anu nti that appr m.r.ph.re a $ od GP Cf.5,steosIh.u,h.reC Re b er 0 3er doe eafsts-the or he.uin tid. ici.a - a - a w.Pr,i_9% / The Containment tooling System and Containment spray system

                                 - are tngin.or.d Sar.t r.atur.

dui n.d to enure dat the hea(tsr) syst.as. t r.o.vai They are capa6ttity reguired durt the post accident period can be attained. The Conta neent $ pray system and the Containment Cooline system provide redundant methods to 11stt and maintain post accident conditions to less than the containment design values. Containment inrav tvitam o f ,,pf,g The Containment spray System consists of two separate trains C P a c'r4) 4, Swr b T or naual enacity eachfan=== or -a== u.- oun .

     *prniwAl I go y,              Iach train incluces a containment spray pump, spray hea6ers.

neules, valves, and piping. Each train is powered from a separate EsF bus. The refueling water tank

    'f 4 'f"P c o l*,*).           borated water to the containment spray during(RWT)                   supplies V4W                                                                                   theinjection phase of operation. In the recirculation mode of operation containment spray pump suction is transferred from the RWT ,

to the containment sump ( . OmM ceoheat set, win kt, vk e OMAAB Lf dwyen coo \@esd cytkoget .f(continued) CEOG $1$ 8 3.6-44 Rev1,04/07/95

Containment Spray and Coeling Systems Wx:f: " W W S:% 8 3.6. 8

-=

BA$ES (continued) 8 (3 ef v4 4 c ler.t) @ ye LC0 During a 08A, a etnimum of containment spray train _- cont ainment tooling at mmena is required to M hah 5 [glifour ceekersh

                      --         -        an attin the containment Seat treasure and teamerature ha' ow the design limits (Ref,gr) . AdditionaHy, one containment 08  A spray train is also regg red to remove todine free the E.A4 O pra353      d eg 604        containment atmosphere and maintain concentrations below ps.4 b Ot cedsved                  those assumed in the safety analysis. To ensure that these requirements are set two containment spray trales and two                           per/c m usuam 3*"hM       h' "*- CM        i (containment coolina S, 9ta aust be OPERABLE. Therefore t               >

coobghed enkget.} wassuming e,ent thater en accuent, ti,e acti .ini.us regire.ents are,.in k+I l the worst case single failure occurs.,

fach Containment spra pump, spray headers, y System nozzles, wicsur) va' ves includes liping, a apray instruments, and controls to ouvre an Op(RABLE flew path capable of taking suction from the RWT upon an ESF actuation signal and gypel fr"1

     .5 a le n u ad "[

3 automatically transferring suction to the containment sumpg lac _h Containment Cooling Systes(spently) includes t 4 L b(.sco,0LC '" d

 ~ (l . y g gesst+r   #1sar<m ses1MerA        coolingancotisIRABL contren to ensure           OP           ers,path, flow       rans, instruments, and          g m

Lt""d, ,,, 4 _ -v APPLICABILITY in MODES 1, 2 daDBA ould cause a release of g { radioactive mate ria to /contal nt and an increase in f Tg C* b.'"*d containment pressure and tempera ure, requiring the operation of the containment spr trains and containment spt g s p b ,ss e d3 coo 11pg trains. resere A % 14 oppAsd -e

         ; %g 3 g                       in MODE f  $ $na nd 6, he probability and consequences of these pressstri7 er presst.ce.       events arrreduced due to the pres lure and temperature t 11r0 psio.,                   limitations of these MODES. Thus vthe Containment $ pray and Containment Cooling systems are not required to be OPERABLE
        ,                               in MODES          nd 6.

ACTIONS L1

         ' N 3 "'*                      With one containment spray train inoperable, the inoperable containment spray train must be restored to OPERABLE status p<tNeiur pregg c             within 72 hours. In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perfom the todine (l?50pstSQ                    removal and containment cooling functions. The 72 hour Completion Time takes into account the redundant heat (continued)

CEOG STS 8 3.6-48 Rev1,04/07/95

Hydrogen Recombiners (At:6S r4 MP O I 3.6.h BA$[$ (continued) s A..cs a,1 is

                 $URVEllt.ANCE       $R  1. 6 @,r.1                          m* * ^ d #*

t REQUIREMEN15 A 4 A"'S @ Performance of a ystes function Test for each hydrogen recombiner ensurt s that the roc fvst'n' / f,f,,,7 iners are operational and can attain and si stain the t reture necessary for hydrogen recombination. In pa ticular, this $R roovires M f.6t7.'e- verification thi the mini heater sheath temperature @ increases to k E D'Fing m#. prier rv my twya InefoWer is ins vaseg/so maxilium yy amarawl 2 minutna and varif ts in be > A0 MJ has shown that these components usuali Operating v /1 pass the expgrjence h surveillance when performed at the month 7*equency. uency was conc 1 to be acceptable from Therefore.theFregpoint. a relia stan This $R ensures that there are no M could affect recombiner operation. physical problems that U.e. 3 lcose wirig or N Since the recombiners sftweb rA\ cMWie% h are mechanically passive, they are not subject to mechanical failure. The only credible failures involve loss of power blockage of the internal flow path, missile tapact, etc. 1

                                                                                                            .h de pessHs o( doteign             visual inspection is sufficient to deterstne abnormal condition modet k\1. etc.)                 Frequenc~y,ythat could cause suchThefailures.for        :    month this $R was developed conside
                               ~

incidence of hydrogen recombiners failing the $R n the past

is low. sR 1.6 2' This $R requires performan of a resistanct '.o ground test 7% ,9gnow/ for each heater phase to e sure that there are no detectable P" 7'"'" j d M ' 1 grounds in any heater pha . Yhts is accomplished by s43.r.a.t 4u cr% verifying that the resist nce to ground for any heater phase is a 10.000 ches. . The month Frequency for this $R was

 .m vA,j/,4 g ,( .N               coveloped cons 10 erin that the incidence of hydrogen
  },.te, p,,A , of c.:<q4 j.      recombiners failing he $R in the past 16 low.

REFERENCES 1. 10 CFR 50.44.

2. (i~0yR 50,Apend1x AAj U f*J^l Ag*]'r 1 C

3. RegulatoryGuide1.7,Revisionllf.

h CEOG $T$ B 3.6-75 Rev1,04/07/95

 'Ihe following issues relate to pending TSTF changes.

30. A plant specille justification was provided (Discussion of Deviation 4 to llases Section 3.0) to justify addition of the words to liases LCO 3.0.7. 'the Ilases changes are .onsistent with pending TSTF 48.

l

LC0 Applicability B 3.0 , SAsEs q Mh7/,nf eg - LC0 3.0 6 - (continued) safety function existsretained. "If this evaluation determines that a l _ the appropriate Conditions and in which the less of fsafety TF *7[ L)I ! Required Actions of the, LCO A*/ function exists are required to be entered. ' I LC0 3.0.7 fspecialtestsandoper l characteristics over the unit's tItfe o demonstrate perfomanceas are required at various times rfom m perfom special,e lustions. aintenance activities, and to these tests and Because 15 nomally prrelude allow specifle under contro edrequiremen(s conditions. STEs are incl to be changed or suspendedperations s applicable A specified ettons of the specifications. uded in effect lg 4 requir appitcable. This will ensure that all appropriateal dire nts of the MODE or other specified condition not IdM sus y associated with or required to be changed or r innded to perform the special test or operation wil in effect. 8303 he Applicablitty of an STE LC0 represents a con in compilance with the nomal requ ton not necessarily the TS. i Compilance with $7E LCOs is option ements of A special test may be performed under e of the appropriate $TE LC0 or the oth er the provisions requirements, appilcable TS if it is desired to rform the special test under the provisions of the STE L STE LCO shall be followed. Thtincludesrequirements , the the $Rs specified of the in the STE LCO.

Some of the STE LCOs req for nomal operation b et e i.e.

that one or more of the LCOs requires meeting the ecifie(d nom, meeting the STE LCO . Applicability al LCOs . The LCOs, however,. a ACTS and SRs of the spec)ified normal the $TE LCO wh it is in effect.not required to be met in order to meet failure to t a soectfled normal LCOThis means that, upon k

ACTIONS of the associated

                                   . nomal l             . e STE LCO apply, in lieu o,f the ACTIONS Exceptions to the above do exist.                                        the insta must          s when the Applicabtitty of the specifiedTher are met where its ACTIONS must be taien,                                     mal LCO

{tsSurve,lliancesmustbeperformed,orwh re certain j all of a (continued) CEOG STS B 3.0 9 Rev 1, 04/07/95 4

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

I Vlferf U 3.do 1 LCO - 3.0.7 l There are certain special testa and or erations required to be performed at various t1/nes over the lif 3 of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance i activities, and to aerform special evolutions. Special Test t Landa.9.17311ow specified TechnicalExcestion (53<T 3'I' 3 LCOs(TWfa i Specificatiort(TS) 11.6, requirements to be chsged to permit performances of these special tests and operations, which otherwise could not be cc 4 3, y,/7 performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requiremen',s remain ' unchanged. This will ensure all appropriate requirements of the l MODE or other specified conditbn not directly associated with'or required to be changed to perform the special test or operation will remain in effect.- The Applicability of a Special Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the'TS. Compliance with Special Test Exception LCOs is optional. _ A special operation may be performed either under the provisions of the appropriate Special Test Exception - LCO or under the other applicable TS requirements. ;lfit is desired to perform the special operation under the provisions of the Special Test Exception LCO, the requirements of the Special Test Exception LCO shall be followed.

LCO Applicability 8 3.0 BASES 3.0.7 (continued) finese requirements must be met concurrently with t m requirements of the ST Lvo, '

                                                                                                                 )   -

Unless the SRs of th specified normal LCOs are su nded or phanged by the spec al test, those SRs that are n essary to seet the specift A performing normal LCOs must be met prior o Q test the s cial test. During the condu of the I special unless specik ose Surveillances need not be rformed by the ACTIONS or SRs of th TE LCo. Acil0NS for TE LCOs provide appro upon fall e to meet the STE LCO. priate dial measures Upon 11ure to meet these AC ONS, suspend the performance and en the ACTIONS for all LCOs th fthespecialtest{ are then not met. Entry nto LCO 3.0.3 may possibly required, but this date ination should not be made b considering only the j fat re to meet the ACTIONS of t STE LCO. CEOG STS g 3,010 Rev 1, 04/07/95

DibCUSSION OF BASES DEVIATIONS FROM NUREG-1432 SECTION 3.0 - LIMITING CONDITION FOR OPERATION AND SURVEILLANCE REQUIREMENT APPLICABILITY PLANT SPECIFIC CIIANGES

1. His change reflects the Calvert Cliffs plant specific terminology.

2. The bracketed statement in the Bases Section for Limiting Condition for Operation 3.0.3 is an information only statement for those plants that cannot cool down to Mode 4 in 13 hours.

Calvert Cliffs is capable of cooling down to Mode 4 in 13 hours, therefore, this information does not apply.

3. His change eliminates or modifies bracketed material so that it applies to Calvert Cliffs.

4. He Bases for NUREG 1432 SR 3.0.2 state: "An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of 'in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions.' The requirements of regulations have precedence...Herefore, there is a Note in the Frequency stating 'SR 3.0.2 is not applicable.'" The ITS do not contsin any Surveillances that refer to 10 CFR Part 50, Appendix J. The CTS were revised in License Amendments Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR-69, respectively. These License Amendments adopted 10 CFR Part 50 Appendix J, Option D, and included revised Surveillances which refer to the Containment Leakage Rate Testing Program, instead of 10 CFR Part 50, Appendix J. Thus, the Bases for ITS SR 3.0.2 have been revised to state: "An example of where SR 3.0.2 does not apply is the Containment Leakage Rate Testing Program." This is an appropriate example for the Calvert Clifts ITS. Improved Technical Specification 5.5.16 states that the provisions of SR 3.0.2 do not apply to the test frequencies in the Containment Leakage Rate Program. 5. The Bases for NUREG-1432 LCO 3.0.7 is different than the Bases for LCO 3.0.7 provided in NUREG-1430 and NUREG-1431. LCO 3.0.7 is the same for each of these NUREGs, except for some insignificant editorial differ nces. Thus, the Bases for LCO 3.0.7 in these NUREGs should be the same, regardless of the vendor who designed the nuclear steam supply system. The Bases of ITS LCO 3.0.7 have been revised to be consistent with the Bases for NUREG-1430 and NUREG-1431. The only difference is that the references to " Test Exceptions" have been changed to "Special Test Exceptions;" this is an editorial change which does not change the intent of the Bases. In addition to this justification, the proposed deviation is being addressed generically as TSTF-48. CALVERT CLIFFS - UNITS 1 & 2 3.0-1 Revision i . 1

31. . A plant specific justification was provided (Discussion of Deviation 4 to Bases Section 3,0) to justify the modification to Dases SR 3.0.2 The Bases changes are consistent with pending TSTF-52, l

l

SR Applicability B 3.0 BASES SR 3.0.2 not be suitable for conducting the Surveillance e.g (continued) transient conditions or other ongoing Surveillanc(e or., - maintenance activities). The 25% extension does not significantly degrade the reliabi)ity that results from perfoming the Surveillance at its specified Frequency. This is based on the recognition that the most probable result of any particular Surveillance being SRs. perfomed is the verification of conformance with the The exceptions to SR 3.0.2 are those Survet11ances for

                         &                                                      which the 25% extension of the interval specified in the t

[N Frequency does not apply. These exceptions are stated in the individual Specif teat' ans. An l g g jg,f,/1 does not apply in A Surve11ance witexamole of dra to 10.2 Frequen of 'in taccorcanc tth a CFR 5 , Appendix , as modif, leMagd fapprove exempt ns.' by A, e requir ats of ation Ipg g9 prec ce ove the TS L44 a test nterva specifi innot in a of th The TS l fr ra a' ' exte The fore, t re is the r ations ake elves j

                                                                                                                                                             )l   i Note in e Frecuene onH ..

3.0.2 it at an irahle_' As stated to the in SR initial 3.0.2, portion ofthe 25% extension also does not apply a periodic requires performance on a 'once per.. "Completion basis. The Time255 that extension performance. applies to each performance after the initial The initial performance of the Required Action, whether it is a particular Surveillance or some , other remedial action, is considered a single action with a single Completion Time. One reason for not 6110 wing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the fun alternative manner. ction of the inoper:ble equipment in an The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance refueling intervals intervals) other thanCompletion or(periodic those consistent Timewith intervals beyond those specified. SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not (continued) CEOG STS g 3,0 13 Rev 1, 04/07/95 a s- - " l

DISCUSSION OF BASES DEVIATIONS FROM NUREG-1432 SECTION 3.0 - LIMITING CONDITION FOR OPERATION AND SURVEILLANCE REQUIREMENT APPLICABILITY PLANT SPECIFIC CIIANGES

1. His change reflects the Calvert Cliffs plant specific terminology.

2. The bracketed statement in the Bases Section for Limiting Condition for Operation 3.0.3 is an information only statement for those plants that cannot cool down to Mode 4 in 13 hours.

Calvert Cliffs is capable of cooling down to Mode 4 in 13 hours, therefore, this information does not apply.

3. This change eliminates or modifies bracketed material so that it applies to Calvert Cliffs.

4. The Bases for NUREG 1432 SR 3.0.2 state: "An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of 'in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions ' The requirements of regulations have precedence...Therefore, there is a Note in the Frequency stating 'SR 3.0.2 is not applicable '" He ITS do not contain any Surveillances that refer to 10 CFR Part 50, Appendix J. The CTS were revised in License Amendments Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively. These License Amendments adopted 10 CFR Part 50 Appendix J, Option B, and included revised Sun'elllances which refer to the Containment Leakage Rate Testing Program, instead of 10 CFR Part 50, Appendix J. Thus, tiie Bases for ITS SR 3.0.2 have been revised to state: "An example of where SR 3.0.2 does not apply is the Containment Leekage Rate Testing Program." This is an appropriate example for the Calvert Cliffs ITS. Improved Technical Specification 5.5.16 states that the provisions of SR 3.0.2 do not apply to the test frequencies in the Containment Leakage Rate Program. 5. The Bases for NUREG-1432 LCO 3.0.7 is different than the Bases for LCO 3.0.7 provided in NUREG-1430 and NUREG-1431. LCO 3.0.7 is the same for each of these NUREGs, except for some insignificant editorial differences. Thus, the Bases for LCO 3.0.7 in these NUREGs should be the same, regardless of the vendor who designed the nuclear steam supply system, The Bases of ITS LCO 3.0.7 have been revised to be consistent with the Bases for NUREG-1430 and NUREG-1431. The only difference is that the references to " Test Exceptions" have been changed to "Special Test Exceptions;" this is an editorial change which does not change the intent of the Bases. In addition to this justification, the proposed deviation is being addressed generically as TSTF-48. CALVERT CLIFFS - UNITS 1 & 2 3.0-1 Revision i

32. The NUREG Markup was modified to delete the reference to TSTF 37 as the justification for deleting NOREG 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),

L

Reporting Requirements 5.6 (C T h 5.6 Reporting Requiresients 5.6.6 teactor coolant syst/m (RCS) PRESSURF AND TEMPERATURE LIMIT / tLPORT f

                                                >TLR) (co inued)
                                 ~

6. The mini ~

Part 50 temperati.re requirements of Appendix G o 10 CFR all be incorporated into the pressure temper ure Itait curves.

7. Lic sees who have removed two or more capsul c should are for each surveillance material the asured increase i reference temperature (RT.,) to the pr eted increase in T.,; where the predicted increase in RT is based on the mean shift in RT., plus the two standa eviation value (2a,) specified in Regulatory Guide 1. . Revision 2. If measured value exceeds the predicted alue (increase in RT.,

                                          + 2a.), the licensee should. provide supplement to the PTLR to demonstrate how the results aff ct the approved
                               ]          methodology.
                                                                                                              .=

f5.6.7 EDGFaidresReoort if individual emerge cy diesel nerator(EDG experiences four or re valid failures n the las 25 demands, t ese failures a y non valid failures experten d by that EDG in that time e od hall be reported within 30 da . Reports on EDG failures s A include the information reco nded in Regulatory Guide 1. , 1 3

                            /       Revision 3 Regulatory Posi on C.5, or existing Regulat y Guide 1.108 reporting req rement.

5.6 FAM Reoort When a report is required by Condition 8 or G of LCO 3.3. Q [A/EW) ( ' Post Accident Monitoring (PAM) Instrumentation," a repor all l be submitted within the following 14 days. The report shall j g 'f,

p. outline the preplanned alternate method of monitoring, the cause of the inoperability, <.nd tre plans and schedule for restoring the instrumentation channels of the function to OPERABLE status, 5.6. Tendon surveillance Reoort b Any abnormal degradation of the containment structure detected

 . f'g'g,h _                       during the tests required by the Pre-Stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within (continued)

CEOG STS 5.0-23 Rev 1, 04/07/95 i '

33. A piant specific justification was provided (Discussion of Deviation 35 to Section 5.0) to justify the changes to the Containment Leakage Rate Testing Program. The changes had been previously justified based on TSTF 52.

l l l l

Programs and Manuals . 5.5 5.5 Programs and Manuals safety function may exist when a support system is inoperable, and:

a. A required system redundant to system (s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to system (s) in turn supported by the inoperable supported system is also inoperable; or t

c. A required system redundant to support system (s) for the supportedsystems(a)and(b)aboveisalsoinoperable.

The Safety Function Determination Program identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. 5.5.16 Containment Leakaoe Rate Testino Prooram A program shall be established to implement the leakage testing of thecontainmentasrequiredby10CFR50.54(o)and10CFRPart50, Appendix J Option B. This program shall be in accordance with I the guidelines contained in Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program," dated September 1995, 2 including errata. y The peak calculated containment internal pressure for the design basis loss-of-coolant accident, P., is 49.4 psig. The containment design pressure is 50 psig. The maximum allowable containment leakage rate, L., shall be 0.20 7 percent of containment air weight per day at P.. Leakage rate acceptance criteria are: 7

a. Containment leakage rate acceptance criterion is s 1.0 L.,

During the first unit startup, following testing in 7 accordance with this program, the leakage rate acceptance CALVERT CLIFFS - UNITS 1 & 2 5.0-28 Revision F 7

                                                                                                                                                                   $ p'.Cs. k Sab J

66 4/ g,q,4 k. Limitations on the annual and quarterly doses to a MEM8ER OF THE PUBLIC from Iodine-131, and all radionuclides in particulate form e,d/. with half-lives greater than 8 days, in caseous effluents released to areas beyond the $!TE BOUNDARY, to be limited:

1. During any calendar quarter: Less than or equal to 15 mrems to any organ:

7NLtcr*

2. During any calendar years Less than or equal to 30 mrems to

                                                        'h,h,]                         ,

any organg and

3. Less than 0.1% of the limits ofW.S.F.k(1) and (2) as a result of burning contaminated oils and A f, g, 4 7 1. limitations on the annual dose or dose comitment to any MEMBER OF THE PUBLIC due to releases of radioactivity, and to radiation

                                                    %                                                    from uranium fuel cycle sources to be limited to less than or festcf g                                             equal to 25 mrems to the total body or any organ, except the

f. r.fr . thyroid, which shall be limited to less than or equal to p.so 75 mrems.

LC f. Il-

                                                                                           \.        Containment Leakace, Rate Testina Procram f.fo lf,. A                      A program shall be established to implement the leakage testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J,             ususe Option BFebdopfteMy a proda efempeTopt. This program shall be in                       M. ,{

accordance with the guidelines contained in Regulatory Guide 1.163,

                                                                                             ' Performance-Based Containment Leak-Test Program." dated September _199Cg)             d A

0'umTTea Dy ay,,wed ucegthenW 3_inckU% erredrQ p g' g ' g The peak cale91sted containment internal pressure for the design basis loss-of-coolant accident, P., is 49.4 psig. The containment design pressure is 50 psig. The maximum allowable containment leakage rate, L., shall be 0.20 percent O'I' N of containment air weight per day at P,. tontal nt leakage rate accepta riterton is 51. During the firs it startup following ng in accordance his program, e' I Je ae rate acceptance crit is 5 0.75 L for T e A tests. .__

                                                                                                                                                                             .- a nie r+ d.S b) f,'r, p d                           The provisions ofAperfication40.2)do not apply to the test frequencies specified in the Conta' nment Leakage Rate Testing Program.

The provisions of cpecwicatinnA.O.3)are applicable to the Containment g__['[ad'C Leakage Rate Testing Program. IN1rn r* 1~. LI L p $$3N 3R 3.o. 2-b CALVERT CLIFFS - UNIT 1 6-8 Amendment No. 217 I paga 0f 0

                                                                                                     $pci[k hou LO "N "4 (%e t t U                                                            @,, A,.a,a zig) i g

Leakage rate acceptance criteria are:

a. C~**8 :

ent leakage rate acceptance criterion is s 1.0 Ly During the first unit startup, following testing in accch with this program, the leakage rate acceptance criteria - are s 0.60 Lafor Types B and C tests and 5 0.75 La for Type A tests,

b. Air lock testing acceptrace criteria are:

1. Overall air lock leakage rate is s 0.05 La when tested at 2 P.. 2. For each door, leakage rate is s 0.0002 a L when pressurized to 215 psig. I t

                                                                   . - = __

fept 10oE O

ff t'e e' 'CAbu'tA) $.O 6,0- "'"!!!"'?M b"'l y, y, k. j$. . I I Limitations on the annual and quarterly doses to a MEMBER OF THE PUBLIC from lodine 131. and all radionuclides in particulate fonn with half-lives greater than 8 days. In gaseous effluents released to areas beyond the SITE BOUNDARY, to be Itmited: 1. Luol . . During any calendar quarter: Less than or equal to 15 mrems to any organ

           ~
      'p g'3                              2. During any calendar years Less than or equal to 30 mrems to any organg and w

g rid 56 h 3. Less than 0.1% of the limits of result of burning contaminated 5 k la ano(1) and (2) as a

7. T,14 4 I pp9 e gp" 1.

Limitations on the annual dose or dose commitment to any MEM8ER OF THE PUBLIC due to releases of radioactivity, and to radiation J.osee from uranium fuel cycle sources to be limited to less than or 55 e pg e. 46 thyroidto 25 mrems to the total body or any organ, except the equal 75 mrems,.which shall be limited to less than or equgl,tg h Containment Leakace Rate Testina Procram f* C id ^ A program shall be established to implement the leakage testing of the containment Option D. as required by 10 CFR 50.54(o) and 10 CFR Part 50. Appendix J. Ucose This program shall be in accordance with the guidelines A* dant contained in' Regulatory Guide 1.163. 'Perfonnance-Based Containment Leak- 1% Test Program." dated September 199

                                                                             ;,1cidig enoAo].                                             j S.T.II. b            peak calculated containment internal pressure for the design basis lus-of-coolant accident, P , is 49.4 psig. The containment design pre sure is 50 psig.

y,g S.C. The maximum allowable containment leakage t3te, L., shall be 0.20 percent of containment air weight per day at P., Contai 7 leakage rat cceptance cri rionis51

first . During e t startup fo ing testing accordance this pro tak rate acceotan criter1a is , _. 0.75 L. for

                                                                                                                , th e A tests. _ f             Eg, L 7, /!,cl The provisions of(ppffigtiorp4.04do r.ot apply to the test frequencies                                  d

Te d specified in the C tainment Leakage Rate Testing Progral'i.

C f./Ad The provisions ofGndcif teattoy4 9.J)are applicable to the Containment Leakage Rate Testilg Program. %',r i CALVERT CLIFFS - UNIT 2 6-8 Amendment No. 194 w.m

                                                                                             $fCC/hed'cr CO h
                 ^^

(f*f l*Ilb L.'ussekinskM0 Leakage rate acceptance criteria are: a. Containment leakage rate acceptance criterion is s 1.0 La. During the first unit startup, following testing in accordance w'th thl: program, the leakage rate acceptance criteria are s 0.60 Lafor Types B and C tests and s 0.75 La for Type A tests,

b. Air lock testing acceptance criteria are:

1. Over . air lock leakage rate is s 0.05 La when tested at 2 P., 2. For each door, leakage raa is s 0.0002 Lawhen pressurized to 215 psig. 4 4 e pge lo of 57

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Safety FmtetiondDetermination Procram __ b. (continued) A requN system redundant to systes(s) in turn supported h by tht 1ioperable supported system is also inoperablet or c. A required system redundant to support systes(s) for the supported systems (a) and (b) above is also inoperable. The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this progras the appropriate Conditions and Required Actions of the LC0 in , which the loss of safety function exists are required tc be entered. 2 f

                % A) SEAT :

m (- 5.S 16 C ,4nN m+ Le.kay Ge Tesim3 roy.m (.A1j) N P g W_ _ A CEOG STS 5.0-18 Rev 1, 04/07/95 I ~ .

INSERT 5.5 (Containment Leakage Rate Testing Program as approved in License Amendment Nos. 219 and 196 to Facility Operating License Nos. DPR-53 and DPR-69) 5.5.16 Containment Leakage Rate Testing Program [k( A program shall be established to implement the leakage testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR Part 50, Appendix J, Option B. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Perfornance-Based Containment Leak-Test Program," dated September 1995, including errata. The peak calculated containment internal pressure for the design basis loss-of-coolant accident, P., i is 49.4 psig. The containment design pressure is 50 psig.

The maximum allowable co' tainment leakage rate, L., shall be 0.20 percent of containment air weight per day at P..

Leakage rate acceptance criteria are:

a. Containment leakage rate acceptance criterion is s 1.0 La. During the first unit startup, following testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L. for Types B and C tects and s 0.75 L. for Type A tests.

b. Air lock testing acceptance criteria are:

1. Overall air lock leakage rate is s 0.05 L.

when tested at h P., r UI"bb

                                                                          ,               2. For each door, leakage rate is s 0.0002 L.

when pressurized to 2 15 psig. C.C.lb-\ Q The provisions of SR 3.0.2 do not apply to the test frequencies specified in the 'ontainmen t Leakage Rate Testing Program. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

      ',                               2nSER.'f C.Clb-1 6 WADMENT SYhDtS SUR    L      E RE                       ontin

{

                                                           ,%s              M pest tssiah*e                ValvesI;g ftgwren>AS Wv *tt% 04 I (dei

q. .

Containment purge isolation valves sha q^ t.. tis.& 1;;t ;;. pen e .t:rinii L: 5 f== pc'.:;ll be demonstrated r ;pretien A d;; ;.less OPERABLE ID 2:1 ;r.th; inri;i!!!nce te t he; b;;; ;;rfeni "' thin i.he,pIrt I Wa MODE 4 from shutdown modes by verifany time

                                                                                                              >rior      after being opened and to' entering og+; ' leakage rate is added to the leakag'ying that wien the measured T&.::!'S ::ifteeties " 0.1.".- for all other Type B or Ce rates detemined p penetration;s,lekkage rate for theon containment 0.60 L . The

{ valves shall also rate to detect be compared excessive to the previously measured leakage valve degradation. h gT wt containment purge isolation valve seals shall be replaced l new seals at a frequency to ensure no individual seal remains in service greater than 2 consecutive fuel reload cycles. Od4I gh t.g%kTesM hysm S l [CAhrfiiTCLIF UNI A3 eadIent[1JV)

DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION Sm0 - ADMINISTRATIVE CONTROLS 10 CFR are rquired to be met. Thus, these requirements do not need to be reiterated in the ITS. Additionally, a generic change (1STF 121) has been proposed to resolve this issue.

35. Current Technical Specification 6.5.6 provides the requirements for the Containment Leakage Rate Testing Program. This program was recently revised in License Amendment Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively. Rese License Amendments were issued on February 11,1997 They adopted Option B of 10 CFR 50, Appendix J. His program has been incorporated as ITS 5.5.16. The current licensing basis has been incorporated, because TSTF 52 has not been approved by the NRC. Additionally, requirements from Unit 1 CTS 4.6.1.2.b and 4.6.1.2.c have been added to the Containment Leakage Rate Testing Program. They require: a) the Unit I containment purge isolation valves to be demonstrated OPERABLE any time after being opened and prior to entering MODE 4 from shutdown modes by verifying that when the measured leakage rate is added to the leakage rates determined pursuant to the Containment Leakage Rate Testing Program for all other Type B or C penetrations, the combined leakage rate is less than or equal to 0.60 Lc, b) leakage rate for the l

containment purge isolation valves are compared to the previously measured leakage rate to detect excessive valve degradation; and c) the containment purge isolation valve seals to be I replaced with new seals at a frequency to ensure no individual seal remains in service greater than 2 consecutive fuel reload cycles. These requirements provide assurance that the Unit I containment purge isolation valves are OPERABLE; they are being provided in lieu of NUREG-1432 SR 3.6.3.6. While the proposed Containment Leakage Rate Testing Program is not identical to the program proposed in TSTF-52 for incorporation into NUREG 1432, it is technically equivalent (except for the additional more restrictive requirements for the Unit 1 , containment purge isolation valves). CALVERT CLIFFS - UNITS 1 & 2 5.0-5 Revision 7

34. A plant specinc justification was provided (Discussion of Deviation 34 to Section 5.0) to )ustify deletion of NUREO Speci0 cation 5.2.2.b. The change had been previously justified Sased on TSTF-121.

DISCUSSION OF CHANGES SECTION 5.0 - ADMINISTRATIVE CONTROLS

Determination Program, required by ITS LCO 3.0.6 is described in the Discussion of Changes for ITS LCO 3.0.6. This change is consistent with NUREG 1432.

A.23 He CTS 3.6.3,3.6.3.1,3.6.7,3.7.7, and 3.9.12 requirements for charcoal absorber and high efliciency particulate air filter bank testing requires each bank to remove 99% of the test gas or particulates, respectively. Improved Technical Specifications 5.5.ll.a and 5.5.ll.b require cach bank to show a penetration and system bypass of < l.0%. He CTS requires the measurement of the amount removed, while the ITS requires the measurement of the amount that is not removed. Both these requirements can be directly correlated to one another. Therefore, this change is administrative because both requirements are essentially equivalent. In addition, CTS 31.3, 3.6.3.1, 3.6.7, 3.7.7, and 3.9.12 requirements for laboratory analysis requires the sample to be obtained from an adsorber tray or an adsorber test tray. Since these are the only two locations to obtain samples, it is not necessary to state this in the ITS. Therefore, the ITS does not include this detail and this change is considered administrative. These chan;;es are consistent with NUREO-1432. A.24 The requirement in CTS 4.4.10.1.1 requires the reactor coolant pump flywheel to be inspected per the recommendations of Regulatory Guide 1.14. The proposed change moves this requirement to the Administrative Controls section of the ITS (ITS 5.5.7). This change is considered administrative because the requirements in the CTS will remain intact. This change is consistent with NUREG 1432. 1 A.25 A requirement which states that the provisions ofITS SRs 3.0.2 and 3.0.3 are a9plie sie to the VFTP Test Frequencies was added. These requirements are currently rpplic. ole to CTS 3.6.3.1, 3.6.6, 3.7.6, 3.7.7, and 3.9.12 Surveillances. Therefore, since these requirements are currently applicable to the CTS, the change is administrative in nature. This change is consistent with NUREG-1432. A.26 Not used. A.27 Current Technical Specifications 6.2.2.b and 6.2.2.c require at least a certain number of non-licensed Operators to be assigned to shift crews and licensed Operators to be present in the Control Room during specific plant operation. Improved Technical Specification 5.2.2 will not contain this requirement. These requirements sre being deleted because they are duplicative of regulations. Title 10 of the Code of Federal Regulations 50.54(mX2Xiii) and 10 CFR 50.54(k) provide the same requirements. The existing requirements will be met through compliance with these regulations and are not required to be reiterated in the ITS. This change is administrative because no requirements are being changed. l A.28 Unit i Specification 6.2.2.i states,"Those licensed operators counted toward minimum shift crew composition required by 10 CFR 50.54(mX2Xi) shall be licensed on both units." Unit 2 Specification 6.2.2.i, " Unit Staff," states, " Licensed operators shall be licented for both units." In the ITS, the Unit I wording shall be used. Both the Unit I and Unit 2 requirements are the same, as the section of the Administrative Controls containing the requirements describes minimum crew composition. Also, all of the Calvert Cliffs licensed operators are licensed for both units. A change which is consistent with the current application of a requirement is considered administrative. CALVERT CLIFFS - UNITS I & 2 5.0-5 Revision 7

Organization 5.2 h 5.2 Organization

2. h 5.2.2 Unit staff (continued)

Cmtzm an ax*ma-'a arra"an P m _ .. ..... ...m.. _... ._._... - L *~c.g*a 1 pequ4=f, te "- 8 L total'oI'th5A n5MiicensefoperatoWM "" '#

                                                                                                                                                             '!*"if  __ m At/ east oneJicensed Reactor Opera                              RO
          <6.2 2 A>                                         M the conty61 room when fuel is a(ditio the(rea)ctor.shall In be prese un 11 ile the  unit  is  in                      1, 2,  3 or 4            ast, in           sed   Senior control roam   Reactor    p rator               (SRO).s,   hall ,     resent
                                                            .,g -

i .e 422,h)'c. Shift crew composition may be less than the minimum " requirement for a period of timeof not10 CFRZ50.54(m)(2)(1) to exceed and 5.2.2.a and 5.2.2.4 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew compositton y lthin _the minimum requirements,

d. A *

((. 2,2, /\ in the reactor. The position ician).shall be on site when fuel is

                   /                                                                            may be vacant for not more                                                   lb than 2 hours, in order to provide for unexpected absence, provided tannediate action is taken to fill the required position.

[ e. < Administrative to limit the working procedure h shall be developed and implemented safety related functi s ,5e.g. of unit staff who perform I health physicists, xilia(ry op,erators, and key maintenalicensed @ licensed R0 , SR0s,

                      !                                  personnel),                                                                             e f                                   Adequate heavy       use shift of overage shall be maintal'ned without outine ertime. The objective shall be to                         ave operating 40     hour w p sonnel work an (8 or 12) hour day, ominal event th           while the unit is operating. How er in the unforeseen problems require subst tial, amounts of ove ime to be used, or duri~n g extended eriods of shutd n for refueling, major maintenance or major plant mod s         ication, on a temporary basis the f lowing guidelines i be followed:

1. An individual should not be pe itted to work more 16 hours straight, excludin ift turnover time; an (continued) CEOG STS 5-0-3 Rev 1, 04/6 /95 __ s pg [p ged ogr'abl (o u a b -[p d a I

rn, n wmm g,n wu csn,,xk a7a!" b8 lO Cff? GC 5'l D ( (-) h // N 'Cf W *i # 0 Vr -

DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 5.0 - ADMINISTRATIVE CONTROLS nis change has been proposed as a change to the ITS NUIEG as TSTF-65, but has not yet been approxd by the NRC.

27. The Calvert Cliffs current licensing basis requires the General Supervisor Nuclear Plant Operations to hold a license, and also requires the operations manager (the individual the General Supervisor Nuclear Plant Operations reports to) to hold or have held a Senior Reactor Operator license at Calvert Cliffs. This requirement is being retained in the ITS.

28. His change incorporates the current Calvert Cliffs requirements for the lodine Removal System into the Ventilation Filter Testing Program. His requirement is consistent with the Calvert Cliffs current licensing basis.

29. The gas storage tank radioactivity limit in NUREG-1432 Specification 5.5.12.b has been changed to be consistent with the Calvert Cliffs current licensing basis. The Calvert Cliffs ITS radioactivity limit will be that in the event of an uncontrolled release of the tank's contents, the resulting total body exposure to a member of the public at the site boundary will not exceed accident guidelines, t

30. The CTS state that the Occupational Radiation Exposure Report for the Independent Spent Fuel Storage Installation is reported separately from the Units I and 2 Occupational Radiation Exposure Report. Herefore, for clarity, the Note to ITS 5.6.1 has been modified to preclude combining the reports into a single submittal.

31. The phrase ", as modified by approved exemptions" has been added to the ITS 5.6.3 requirement that the Radioactive Effluent Release Report be submitted in accordance with 10 CFR 50.36a.

Current Technical Specification 6.6.3 footnote """ allows an exemption to 10 CFR 50.36a that allows the Sr" and Sr* analysis results to be submitted at a later date. The addition of the phrase ", a., modified by approved exemptions" is consistent with its use in other ITS that allow exemptions (e.g., ITS 3.6.1).

32. The current Calvert Cliffs licensing basis surveillance frequencies have been provided in ITS 5.5.11. In addition, for clarity the NUREG 1432 discussion concerning the provisions of SR 3.0.2 and SR 3.0.3 have been moved to the end of this specification after the discussion of frequencies, since it applies only to the frequencies.

33. The statement in NUREG-1432 Specification 5.5.11, "at the system flowrate specified below [+- 10%]" has been deleted since it is redundant. Each of the requirements in NUREG-1432 Specification 5.5.11 that require a specific flowrate have the same statement.

34. The requirement of NUREG-1432 Section 5.2.2.b has been climinated from ITS 5.0. The requirements for shill manning are provided in 10 CFR 50.54(m)(2)(iii) and 50.54(k). Title 10 CFR 50.54(m)(2)(iii) requires: "when a nuclear power unit is in an operational mode other than cold shutdown or refueling, as defined by the unit's technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at all times. In addition to the senior operator, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times." Further 10 CFR 50.54(k) requires: "An operator or senior operator license pursuant to part 55 of this chapter shall be present at the controls at all times during the operation of the facility." The requirements of CALVERT CLIFFS - UNITS 1 & 2 5.0-4 Revision 7

DISCUSSION OF TECIINICAL SPECIFICAYlON DEVIATIONS FROM NUREG 1432 SECTION 5.0 - ADMINIS"RATIVE CONTROlE 10 CFR are required to be met. Thus, these requirements do not need to be reiterated in the ITS. Additionally, a generic change (TST/ 121) has been proposed to resolve this issue.

35. Current Technical Specification 6.5.6 provides the requirements for the Containment Leakage Rate Testing Program. 'Ihis program was recently revised in License Amendment Nos. 219 and 196 to Facility Operating License Nos. DPR-53 and DPR 69, respectively, nese License Amendments were issued on February 11,1997. Dey adopted Option B of 10 CFR 50, Appendix J. This program has been incorporated as ITS 5.5.16. The current licensing basis has been incorporated, because TSTF 52 has not been approved by the NRC. Additionally, requirements from Unit 1 CTS 4.6.1.2.b and 4.6.1.2.c have been added to the Containment Leakage Rate Testing Program. They require: a) the Unit I containment purge isolation valves to be demonstrated OPERABLE any time after being opened and prior to entering MODE 4 from l shutdown modes by verifying that when the measured leakage rate is added to the leakage rates determined pursuant to the Containment Leakage Rate Testing Program for all other Type B or C l

penetrations, the combined leakage rate is less than or equal to 0.60 L.; b) leakage rate for the containment purge isolation valves are compared to the previously measured leakage rate to detect excessive valve degradation; and c) the containment purge isolation valve seals to be replaced with new seals at a frequency to ensure no individual seal remains in service greater than 2 consecutive fuel reload cycles. These requirements provide assurance that the Unit I containment purge isolation valves are OPERABLE; they are being provided in lieu of NUREG-1432 SR 3.6.3.6. While the proposed Containment Leakage Rate Testing Program is not identical to the program proposed in TSTF 52 for incorporation into NUREG-1432, it is ( technically equivalent (except for the additional more restrictive requirements for the Unit I containment purge isolation valves). CALVERT CLIFFS - UNITS I & 2 5.0-5 Revision 7

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 5.0, ISTS Markup, and Discussion of Deviation 26 to Section 5.0 I4 ave also been made.

Organization 5.2 5.2 Organization 5.2.1 Onsite and Offsite Oraanizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant,

a. Lines of authority, responsibility, and comunication shall be defined and established througnout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmentti responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements including the plant-specifit, cities of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be l documented in the Updated Final Safety Analysis Report or l Quality Assurance Policy; 7 l

b. The plant manager shall be responsible for overall safe >

operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant;

c. The Vice President-Nuclear Energy shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety; and

d. The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.

CALVERT CLIFFS - UNITS 1 & 2 5.0-2 Revision g 7

5ecec.gb g,o I

     **      h
             -f.0 ADMINISTRATIVE CONTROLS                                          .

r RESPONSIBILITV '

g 1.1 operation and shall delegate in writing the succession responsibility during his absence. I to thisThe plan C ORGANIZATION *

               .2.1 Onsite 8 offsite Oraantrations_

Onsite and offsite organizations shall be established'for unit operation and corporate management, respectively. The onsite and offsite organizations shallpower safety of the nuclear include the positions for activities affecting the plant. a. Lines of authority, responsibility and conmunication shall be established and defined for the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated l as appropriate. In the form of organization charts, functional , I and job descriptions for key personnel positions, or indescriptions o equivalent forms of documentation. the plant specific titles of personnel fulfilling theThese requirements. including responsibilities of the positions delineated in these Technical Analysis Report (UFSAR) Specifications, shall be documented in the Updated Fin

                  - b.

pddy Assurdue Po\i The plant manager shall be responsible for overall unit safe operation and shall have control over those onsite activities l necessary for safe operation and maintenance of the plant, c. The Vice President . Nuclear Energy shall have corporate responsibility for overall plant nuclear safety and shall take any measuresmaintaining in operating, needed to ensure acceptable performance of the staff plant to ensure nuclear sa,fety.and providing technical support to the d. The individuals who train the operating staff and those who carry - out health physics and quality assurance functions may report to , the appropriate onsite manager; however, they shall have sufficient organizational from operating pressures. freedom to ensure their independence

            .2.2 Unit Staff                                                                                   .

The unit staff organization shall include the following: a. A total of dPTerrt three non-licensed operators shall be assigned to the Units 1 and 2 shift crews. Q CALVERT CLIFFS - UNIT 1 6-1 Amendment No. 216 i' paplJ U l

                                                                                                             $fenIhicAfha.C.O
                                    'h. 6tt' ADMINISTRATIVE CONTROLS del 1 RESHmilBILITY
                                          .1.1 The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this                   l responsibility during his absence.                                                   ni, "I'muh      V.I
                                                                                    ^ ^ '

I

                                          .2 ORGANIZATION 2.1 Onsite & offsite Graanizations Onsite and offsite organizations shall be estabitshed for unit operation and corporate management, respectively. The onsite and offsite organitations     shall include the positions for activities affecting the safety of the nuclear power plant.

a. Lines of authority, responsibility and communication shall be established and defined for the highest management lev'els through -

intermediate levels to and including a') operating organisation positions. These relationships shall be documented and updated,* as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements, including the plant specific titles of personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Updated Final Safety AnalysisReport(UFSAR) b.

                                                                                   , g g g g % ,p,g; g ,]

The plant manager shall be responsible for o'verall unit safe operation and shall have control over those onsite activities l necessary for safe operation and maintenance of the plant.

c. The Vice President - Nuclear Energy shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining plant to ensure nuclear sa,fety. .and providing technical support to the d.

The individuals who train the operating staff cnd th$se who carry, out health physics and quality assurance functions may report to the appropriate onsite managers however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.

                                         .2.2 Unit Staff
                                     . The unit staff organization shall include the following:

a. A total of $7iHibthree non-licensed operators shall be assigned to tne Units 1 and 2 shift crews. . A .1 CALVERT CLIFFS - UNIT 2 6-1 Amendment No. 193 Pfge 144 57 l

u

DISCUSSION OF CIIANGES SECTION 5.0 - ADMINISTRATIVE CONTROLS ADMINISTRATIVE CHANGES A.1 ne proposed changes reformat, renumber, and reword the Current Technical Specification (CTS) definitions, with no change of intent, in accordance with NUREG-1432. As a result, the Technical Specifica.tions should be more readily readable and, therefore, understandable by plant operators, as well as other users. During the Calvert Cliffs Improved Technical Specifications (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 section and to be consistent with NUREG 1432. Ilowever, this additional information does not change the intent of the CTS. The reformatting, renumbering, and rewording process involves no technical changes to existing Definitions. A.2 Current Technical Specification 6.2.2.a requires at least three non licensed Operators to be assigned to shift crews and licensed Operators to be present in the Conuol Room during specific plant operation. Improved Technical Specifications 5.2.2.a and 5.2.2.b will delete the words, "at least," from the requirement. The convention of the ITS is to list the minimum requirement which is always allowed to be exceeded (the plant is always nilowed to be more conservative, i.e., having more than three non-licensed operators). Since this change does not revise the minimum requirement, this change is considered administrative in nature. This change is consistent with NUREG 1432. A.3 Current Technical Specification 6.2.2.d requires an individual qualified in radiation protection procedures to be onsite when fuel is in the reactor. Improved Technical Specification 3.2.2.e changes the title of the individual to a radiation protection technician. This change reflects the generic title of the individual specified in the American National Standards Institute standards. This change is consistent with NUREG 1432, Generic Change TSTF-65. A.4 Carrent Technical Specification 6.3.1, which requires the Shift Technical Advisor to have specific education requirements, is being incorporated into the Shift Technical Advisor requirements of CTS 6.2.2.g.2. His change is considered administrative because the requirements have not changed. Current Technical Specification 6.2.2.g.2 references CTS 6.3.1, This change will delete the reference to another Specification and incorporate the actual words. The ITS number for this requirement is ITS 5.2.2.h. A.5 Current Technical Specification 6.2.1.a requires lines of authority, responsibility, and communication to be established and defined for the highest management levels through intermediate levels to and including all operating organization positions, it further requires that these relationships be documented in organizational charts, functional descriptions . . . and the Updated Final Safety Analysis Report (UFSAR). Improved Technical Specification 5.2.1.a is consistent with the CTS except it also allows the plant specific titles of personnel fulfilling the responsibilities of the position delineated in the Technical Specifications to be placed in the Quality Assurance (QA) Policy, instead of or along with l the UFSAR. This change is administrative in nature because these requirements will be adequately controlled in either the UFSAR or QA Policy. This change is consistent with l NUREG-1432, Generic Change TSTF 65.

CALVERT CLIFFS - UNITS I & 2 5.0-1 Revision 7

s Organization 5.2 mv % %_ 5.0 # WINI$iRATIVE CON 1ROLS iricMD O P N 5e" # 4 75)

I O* F6* awl 5.2 Organizatton

('af nl.ap 4b v,vm.blA6< ef 4L pu.%: J J,.. 4.J. x g% y, A q ,f 3 ,p /;,,,t,, y , 4,9,i) 5.2.1 v# f w - Desite and offsite ornantratione eparatloa and corporate management, respectively.Onsite and offsite o offsite organizations shall include the positions for activitiesThe onstte and affecting safety of the nuclear power plant. a. be defined and established throughout highest management 1tnes t levels, intermediate levels and all operating organization (6'I I'4) positions. These relations $tps shall be documan164 and updatea, as appropriate, in organization charts desU :ptions of departmental responsibilities an,dfunctional relationships positions, o , and . fob desertotions for key personne requirement equivalent fores or cocumentauon. ese 11 be documented in the Q t b. TheHglant _$N...M-t'shall be responsible 74, for overall(ggg A*""# g gfg_ h.1.).h safe operation of the plant and shall have control over those onsite activities necessary for safe operation and Poh(B M v A 4A main J13.ntt _ ._ c. c e, The r :;::,, y. r,

                                                                                                   . AW thu hd m at: um].J: p t!! 9 sha11 have corporate responsiblitty for overall plant nuclear sifety                            @

h,;,1c) and shall take any settures needed to ensure acceptable performance of the staff in operating maintaining and providing safetyt andtechnical support to the pla,nt to ensure, nuclear d. The individuals who train the operating staff. carry out 4,*tLE> health physics, or perfors quality assurance functions may report to the appropriate onsite manager; however. these individuals shall have sufficient organizational fr ensure their independence from operating pressures eedom to h22)5.2.2 Unit staff The unit staff organization shall include the followingt 1,2'*) a. o icensed operato all be assigned each react n ning fuel and an ditional non lic sed operator (continued) CEOG STS 5.0 2 Rev1,04/07/95

_ - _ ~ __ .. . _ ___ , _ _ _ _ _ _. _ _ .. _ _ ___ . . _ _ DISCUSSION OF TECHNICAL SPECIFICATION DEVIATIONS FROM NUREG 1432 hr:CTION 5.0 - ADMINISTRATIVE CONTROLS 4

20. The Calvert Cliffs CTS 4.4.5.5 requirements for steam generator tube inspection reports were inserted into NUREO.1432 Section 5.t.9, Steam Generator Tube Inspector Report.1his change is consistent with the Reviewer's Note for this section, which requires the licensee to incorporate their current licensing basis regarding steam generator tube inspection reports. -

1

21. Calvert Cliffs will not include a section on liigh Radiation Area (as depicted in NUREO.1432 Section 5.7.1 as a bracketed specification) consister.t with the current licensing basis.

22. He proposed change to NUREO.1432 adds a requirement tlat licensed operators counted towards the minimum shift crew composition shall be licensed for both units. His is a specific requirement for Calvert Cliffs and is consistent with the current licensing basis. '

23. The proposed change to Specifict. tion 5.5.ll.c changes the penetration requirements of methyl j iodide from less than 10%, to less than or equal to 10%. %Is change is consistent with the i

Calvert Cliffs current licensing basis, which requires a 2 90% removed efficiency of methyl . iodide.

24. He proposed changes to Specifications 5.5.11.a and 5.5.11.b change the penetration system bypass requirements of the high efficiency particulate air filters and charcoal absorbers from

                 < l.0% to s 1.0%. Thl change is consistent with the current Calvert Cliffs licensing basis which requires a 2 99% removal efliciency.

25. NUREG 1432 requires the particulate concentration to be tested in accordance with American Society of Testing Material D-2276 89, Method A 2 or A 3. Calvert Cliffs ITS will include the requirement to test for particulates, but not in accordance with ASTM D 2276 89, Method A.2 or A 3. Total particulate concentration will be determined by gravimetric analysis.

ASTM D 2276 89, Method A 2 is the test method for fuel systems under pressure. The Calvert Cliffs diesel fuel oil tanks are not under pressure, so this is not an appropriate test method. ASTM D 2276 89, Method A 3, is primarily a gravimetric analysis, but the test methods used at Calvert Cliffs to determine total particulate concentration do not match all detail catalried in Method A 3. Among the di'Terences between Calvert Cliffs test methods and ASTM D 2276 89, Method A.3, are:

a. The reagents used are different,

b. A filter reagent is not used,

c. The preparation of apparatus is different, and

d. He volumes of the sample are different.

26. The Calvert Cliffs CTS Administrative Controls uses generic titles provided in American National Standards Institute /American Nuclear Society 3.1 instead of plant specific titles. The plant specific titles that correspond to the generic titles are given in the Updated Final Safety Analysis Report. The use of generic titles in the Administrative Controls war encouraged in a letter from C.1. Grimes (NRC) to Lee Bush (WOG), Brian Mann (CEOG), Clinton Szabo (B&WOG), and Andrew Maron (BWROG), dated November 10,1994. 'Ihese generic titles are carried over into the Calvert Cliffs ITS. Also, some additional titles appear in NUREG 1432.

For consisteacy, generic titles have been used in those locations. In addition, a change was made to allow the corresponding plant specific titles to be placed in the Quality Assurance Policy or l the Updated Final Safety Analysis Report. This is consistent with the November 10,1994 letter. CALVERT CLIFFS . UNITS I & 2 5.0-3 Revision 7

ATTACilMENT (4) l IMPROVED TECIINICAL SPECIFICATIONS, REVISION 7 AMENDMENT REVISION BY ITS SECTION Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 6,1997 l

P ge Replacement Instructions VOLUME 4 Section 3.0 Note: Underlined titles indicate tabs in volumes. Regarding CIS markups: Pages are referenced by citing the unit i number as wellas the tc{fication number loccledin the upper right hand corner of the CTSpage. Key: DOC = QIscussion ofChanges DOD = Discussion DJ TechnicalSpecification Deviation or Discussion OfBases Deviation REMOVE INSERT Osenten of Channes Nonc IIS None ITS Baars None CTS Madun & Dinussion of Chanacs None NSHC Findians None l$ fS Madun & Justincation -' None ISTS Bases Markun & Justincation B 3.0 9 B 3.0 9 Insert B 3.0,7 Insert B 3.0.7 B 3.010 B 3.010 B 3.013 B 3.013 DOD 3.01 DOD 3.01 i

LCO Applicabi)Ity B 3.0 5kSl5 fTST'71,Inled LC0 3.0.6 retained,4 (continued) safety function exists, the appropriate Conditions f&f TA' n this ev andif L,5 Required function exists Actions of the are required LCO to be in which the loss of safety entered. LC0 3.0.7 fspecialtestsandoper {' characteristics. over the untt'st life e demonstrate performanceons are required at various times perform special e rform maintenance activities luations these tests allow specif t and perations,. Because TS normally p and to reclude requirementsspecial test exceptions ($TEs) under contro ed condttions. to be changed or suspended applicable STEs are incl M specified ections of the $pectitcations. uded in effect all other TS requirements remain unchanged applicable. and inUnless$otherwise I requir dire nts of the MODE or other specified condition #38# notThis will ensu sus y associated with or required to be changed or r innded to perform the special test or operation wil in effect. 8 3 0/1

                            .he Applicability of an STC LC0 represents a con necessarily the   T$.            in costpliance with the nomal reau ton not Compitance with STE LCOs is option               ements of A special test may be performed under e of  the appropriate STE LCO or the oth er the provisions requirements,                                           appilcable TS if it is desired to under the provisions of the $TE L                   form the special test
                          $TE LCD shall be followed.Thl                   , the requirements of the in the $TE LCO.                               includes the $Rs specified 3

Some of the STE LCOs req for normal operation t e i.e. that one or more of the LCOs requires meeting the ecifie(dnor,malLCOs. meeting the $TE LCO Appitcability. ACT The LCOs however, a 3. and $Rs of the spec)tfled normal the $TE LCO wh it is in effect.not required to be met in order to meet failure to t a spectfled normal LCOThis means that, upon 1 ACTIONS of norwa) L e $TE LCO apply, in lieu o. the associated I Exceptions to the above do f the ACT10NS er'It. the instan t must s when the Apritenbility of the specifiedTher are met where its ACTIONS must be taken, rwal LCO is Surve,illances must be performed, re certain or whp e all of (continued) CEOG $T$ B 3.0-9 Rev 1. 04/07/95

1 rlfer/ 8 3.C, 7 LCO 3.0.7 There are certain special tests and operations required to be puformed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance ' activities, and to perform special evolutions. Special Test (33dO#dy4M]) Mrfalog7 allows.1K3.1.9fbnd specified 3417MDigita(13.1A) TechnicalException ; 7'I' 3 LCOs( i Spec!ficatiort(TS) l'I 8, i requirements to be changed to permit performances of these ' cc d special tests and operations, which otherwise could not be I 3, y,/7 performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect. The Applicability of a Special Test Exception LCO represents a condition not necessarily in compilance with the normal requirements of the TS. Compliance with Special Test Exception LCOs is optional. A special operation may be performed e!!her under the provisions of the appropilate Special Test Exception LCO or under the other applicable TS requirements. lf it is desired . to perform the special operation under the provisions of the Special Test Exception LCO, the requirements of the Special Test Exception LCO shall be followed. t e.

_ - ----=---- LC0 Appitcability B 3.0 BA$LS [Il3.0.7 Inese requirements must be met concurrently with7 h (ce'it tnued) requirements of the 51 LCO.

                                                                                               )   .

Onless the SRs of th spectfled normal LCOs are su ended or changed by the spec al test A those SRs that are n estary to. neet the specift normalLb0smustbemetprior performing the s ciel test. During the condu of the o I Q special tent anless specif ose Survelliances need not be erformed by the ACTIONS or SRs of th TE LCO. ETIONS for TE LCOs provide appropriate dial measures upon fail to meet the STE LCO. Upon 11ure to meet these AC ON$. suspend the performance and en the ACTIONS for all LCOs th fthespecialtest{ ere then not met. Entry nto LCO 3.0.3 may possibly required, but this dote ination should not be made b considering only the fat re to meet the ACTIONS of t $1E LCo. j/ CEOG STS B 3.010 Rev 1. 04/01/95

                                                                      $R Applicability B 3.0 BA$ts
   $R 3.0.2 (continted)    not be suitable for conducting the Survettlance (e.g.,

transient conditions or other ongoing surveillance or - maintenanceactivities). l 1he 25% extension does not significantly degrade the reliability that results from perfoming the survettlance at f its specified Frequency. This is based on the recognitten that bein the most probable result of any particular Surveillance SRs.g perfomed is the verification of confomance with the The exceptions to SR 3.0.1 are those Survalliances for which the 25% extension of the interval specified in the j O Frequency does not apply. f the the individual Specificat' ann.These exceptions are stated in Qui,nted 1 doel not apply in A Surve C inceAn example af eare in 10.t l wit frequency of 'in I /accoraanc Ith 3 CFR 5 . Appendix , as modif d by les.Ia9C fapprove exempt ns.' a requir nts of r A.

     $dc Td*)      preced ce eve the TS ' The 15           not in a of the elves                LL%

exte a test nterva specifte in the re Ther4 fore,t re is Note in e Frecuenc <attons

                                                                       ' attons'   y ake )l t fr D W

SY 3.0.2 it at an tenh1a ' t h. ,

f As stated in SR 3.0.2, the t$1 extension also does not apply j to the inttini portion of a periodic I requires performance on a 'once per..' Completion basis. The 25%Time that extension ap perfomance.pites to each performance af ter the initial The initial performance of the Required Act, ton, whether it is a particular Surveillance or some ottor remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accompitshes the function of the inoperable equipment in an alternative manner. The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surve111ance refueling intervalsintervals (other than those consistent with beyondthosespecif)ied.or periodic Completion Time intervals

 $R 3.0.3
                  $R 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a survetilance has not (continued)

CEOG STS B 3.0-13 Rev 1. 04/07/95

                                                                                                        'l m

DISCUSSION OF HASES DEVIATIONS FROM NUREG.1432 SECTION 3.0 - LIMITING CONDITION FOR OPERATION AND SURVEILLANCE REQUIREMENT APPLICAHILITV PLANT SPECIFIC CliANGES l 1. His change reflects the Calvert Cliffs plant. specific terminology, i l 2. The bracketed statement in the Bases Section for Limiting Condition for Operation 3.0.3 is an l-information only statement for those plants that cannot cool down to Mode 4 in 13 hours. Calvert Cliffs is capable of cooling down to Mode 4 in 13 hours, therefore, this information does not apply.

3. Tliis change climinates or modifies bracketed material so that it applies to Calvert Cliffs.

4. The liases for NUREG 1432 SR 3.0.2 state: "An example of where SR 3.0.2 does not apply is a Surveillance with a Frequency of'in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions.' The requirements of regulations have precedence...Therefore, there is a Note in the Frequency stating 'SR 3.0.2 is not applicable.'" The ITS do not contain any Surveillances that refer to 10 CFR Part 50, Appendix J. The CTS were revised in License Amendments Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively. These License Amendments adopted 10 CFR Part 50 Appendix J, Option B, and included revised Surveillances which refer to the Containment Leakage Rate Testing Program, instead of 10 CFR Part 50, Appendix J. Rus, the Bases for ITS SR 3.0.2 have been revised to state: "An example of where SR 3.0.2 does not apply is the Containment Leakage Rate Testing Program." This is an appropriate example for the Calvert Cliffs ITS. Improved Technical Specification 5.5.16 states that the provisions of SR 3.0.2 do not apply to the test frequencies in the Containment Leakage Rate Program.

5. The Bases for NUREG.1432 LCO 3.0.7 is different than the Bases for LCO 3.0.7 provided in NUREG 1430 and NUREG 1431. LCO 3.0.7 is the same for each of these NUREGs, except fo; some insignificant editorial dilTerences. Thus, the Bases for LCO 3.0.7 in these NUREGs should be the same, regardless of the vendor who designed the nuclear steam supply system. The Bases of ITS LCO 3.0.7 have been revised to be consistent with the Bases for NUREG 1430 and NUREG-1431. He only difference is that the references to " Test Exceptions" have been changed to "Special Tect Exceptions;" this is an editorial change which does not change the intent of the Bases, in addition to this justification, the proposed deviation is being addressed generically as TSTF-48.

CALVERT CLIFFS UNITS 1- & 2 3.0-1 Revision i

Page Replac: ment 1:str:cti::s YOLUME 10 Section 3.6 Note: Underlined titles indicate tabs in volumes. Regarding CIS markups: Pages are referenced by citing the unit number as well as the spec @ cation number located in the upper right-hand corner of the CISpagJ. l xey: DOC = Qlscussion OfChanges DOD = Discussion Of TechnicalSpec$ cation Deviation or Discussion QfBases Deviation REMOVE INSERT Ovennew of Chammes None g i 3.6.31 inrough 3.6.3 6 3.6.31 through 3.6.3 6 ' l 3.6.61 3.6.6 1 filli Bases B 3.6.14 and B 3.6.15 B .1.6.14 and B 3.6.15 B 3.6.2 1 B 3.6.2 1 B 3.6.31 through B 3.6.3 13 D 3.6.3 1 through B 3.6.3 12 B 3.6.5 3 and B 3.6.5 4 B 3.6.5 3 and B 3.6.N B 3.6.61 and B 3.6.6 2 B 3.6.61 and B 3.6.6 2 B 3.6.6 5 through B 3.6.611 B 3.6.6 5 and B 3,6.611 B3.6.76 B 3.6.7-6 B 3.6.81 and B 3.6.8 2 B 3.6.81 and B 3.6.8 2 B 3.6.8 4 and B 3.6.8 5 B 3.6.8 4 and B 3.6.8 5 CTS Madun & Discussion of Chammes Spec @ cation 3.6.1, Unit i Page 1 of 10 through Page 4 of 10 Page 1 of 10 through Page 4 of 10 Spec @ cation 3.6.1, Unit 2 Page 1 of 6 through Page 4 of 6 Page 1 of 6 through Page 4 of 6 DOC 3.6.1 1 through 3.6.14 DOC 3.6.1. I through 3.6.14 Spec $ cation 3.6.2, Unit i Page 1 of 7 Page I of 7 Page 6 of 7 Page 6 of 7 Page 7 of 7 Page 7 of 7 Spec @ cation 3.6.2, Unit 2 Page1of7 Page I of 7 Page 6 of 7 Page 6 of 7 Page 7 of 7 Page 7 of 7 DOC 3.6.21 through 3.6.2 5 DOC 3.6.21 through 3.6.2 5 Spec @ cation 3.6.3, Unit i Page 1 of 6 through Page 3 of 6 Page 1 of 6 through Page 3 of 6 Page 5 of 6 Page 5 of 6 i

P:ge Replaceme:t I:structi:ns VOLUME 10 Section 3,6 Note: Underlined titles indicate labs in volumes. Regardsng GS markups: Pages are referenced by citing the unit number as wellas the specipcation nurnber locatedin the upper right hand corner of the CISpage. Key: DOC - Discussion OfChanges { l DOD - Olscussion Of 7th,nicalSpecipcation Deviation or Discussion OLBases Deviation REMOVE INSERT Specipcation 3.6.3, Unit 2 Page 1 of 6 through Page 6 of 6 Page 1 of 6 through Page 6 of 6 DOC 3.6.31 through 3.6.3 8 DOC 3.6.31 through 3.6.3 H DOC 3.6.51 and 3.6.5 2 DOC 3.6.51 and 3.6.5 2 i Specipcation 3.6.6 Unit 1 ' Page 1 of 5 through Page 5 of 5 Page 1 of 6 through Page 6 of 6 Specipcation 3.6.6, Unit 2 Page 1 of 5 through Page 5 of 5 Page I of 6 through Page 6 of 6 DOC 3.6.6-1 through 3.6.6-6 DOC 3.6.61 through 3.6.6 7 DOC 3.6.71 through 3.6.7 3 DOC 3.6.71 through 3.6.7-4 l 1 CIS 3.6.3.1, Unit i Page1ofI Page1ofI CIS3.6.3.1, Unit 2 Page1of1 PageIofI DOC Page 3/4.6.5.1 1 CIS 3.6.6.1, Unit i Page 1 of 3 through Page 3 of 3 Page 1 of 3 through Page 3 of 3 CIS3.6.6.1, Unit 2 Page 1 of 3 through Page 3 of 3 Page 1 of 3 through Page 3 of 3 DOC Page 3/4.6.61 fiSilC Findines 3.61 through 3.6 24 3,61 through 3.6 24 ISTS Markup & Justification 3.6-2 362 3.6-6 3.6-6 3.6-8 through 3.610 3.6 8 through 3.610 3.612 through 3.614 3.612 through 3.614 3.617 through 3.6 20 3.617 through 3.6 20 3.6 28 3.6 28 DOD 3.61 and 3.6 2 DOD 3.61 through 3.6 3 il

Page Rept: cement lustructi:ns VOLUME 10 Section 3.6 Note: Underlined titles indicate labs in volumes. Regardong CIS markups: pages are referenced by citing the unit number as well as the specification number located in the upper right-hand corner ofthe CISpage. Key: > DOC = Qiscussion OfChanges DOD = Qiscussion Qf Technicel Specification Deviation or Olscussion OfBases Deviation { REMOVE INSERT ISTS Banea Mart == & Justifkation B 3.61 through " Insert B 3.6.1 SR 3.6.1.2" B 3.61 through " Insert B 3.6.1 SR 3.6.1.2" B 3.6 5 B 3.6 5 B 3.611 through B 3.613 B 3.611 through B 3.613 B 3.617 through " Insert B 3.6.2 SR 3.6.2.2" B 3.617 through " Insert B a' 6.2 SR 3.6.2.2" B 3.619 B 3.619 B 3.6 22 through B 3.6 26 B 3.6 22 through B 3.6 26 B 3.6 29 B 3.6 29 B 3.6 30 B 3.6 30 and " INSERT B 3.6.3 SRs 3.6.3.2 and 3.6.3.3" B3.631 B 3.6 31 B 3.6 33 B 3.6 33 B 3.6-42 B 3.6-42 B 3.6-44 and B 3.6-45 B 3.6-44 and B 3.6-45 3 3,6-48 and B 3.6-49 B 3.6-48 and B 3.6-49 B 3.6 51 through D 3.6-53 B 3.6 51 through B 3.6 53 B 3.6-74 and B 3.6 75 B 3.6 74 and B 3.6 75 B 3.6-81 and B 3.6-82 B 3.6 81 and B 3.6 82 B 3.6-84 and B 3.6-85 B 3.6 84 and B 3.6-85 1 DOD 3.61 and 3.6 2 DOD 3.61 through 3.6 3 iil

 =.                   _   =                                                                    =

W

Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE. APPLICABILITY: H0 DES 1, 2, 3, and 4. 1 ACTIONS

                                                                       ..................................-.N0TES.......-...............-............

l

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

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

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

7

4. Shutdown Cooling (SDC) isolation valves may be opened when Reactor Coolent System temperature is < 300'F to establish SDC flow.

CALVERT CLIFFS - UNITS 1 & 2 3.6.3 1 Revision 67

                                                                                     ~                                                                           _

Containment Isolation Valves 3.6.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME A. - - - - - . - - N OT E - - - - - - - - A.1 Isolate the affected 4 hours Only applicable to penetration flow path penetration flow by use of at least paths with two one closed and containment isolation de-activated velves and not a automatic valve, l l closed system. closed manual valve. I '

                                                    .................----                        blind flange, or                                7 check valve with flow One or more                                  through the valve penetration flow                             secured.                                        '

paths with one containment isolation E valve inoperable. A.2 --------NOTE ------- Isolation devices in high radiation areas may be verified by use of admir.istrative means. Verify the affected Once per 31 days penetration flow path for isolation is isolated. devices outside containment M Prior to entering MODE 4 from MODE 5 if not performed within the previous C2 days for isolation devices inside containment CALVERT CLIFFS - UNITS 1 & 2 3.6.3-2 Revisionff 7

Containment Isolation Valves 3.6.3 ! ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME , B. ......--NOTE-------- B.I Isolate the affected 1 hour Only applicable to penetration flow path penetration flow by use of at least paths with two one closed and containment isolation de-activated I valver, and not'a automatic valve, closed system, closed manual valve.

            ....................-         or blind f1inge.

l7 One or more penetration flow paths with two containment isolation I valves inoperable. I i CALVERT CLIFFS - UNITS 1 & 2 3.6.3-3 Revision p 7

I Containment Isolation Valves ! 3.6.3 , i r J ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME

C. --------NOTE------- C.1 Isolate the affected 72 hours l- Only epp11 cable to penetration flow path penetration flow by use of at least
- paths with one or one closed and more containment de-activated l isolation valves and automatic valve, i a closed system, closed manual valve, j ..................... or blind flange. j i

One or more M penetration flow paths with one or C.2 --------NOTE ----.-- more containment Isolation devices in isolation valves high radiation areas inoperable, may be verified b; use of adminit,trative means. Verify the affected penetration flow path Once per 31 days is isolated. D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time not met. E D.2 Be in MODE 5. 36 hours CALVERT CLIFFS - UNITS 1 & 2 3.6.3-4 Revision /7

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS l SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 4 inch containment vent valve is 31 days closed except when the 4 inch containment vent valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. SR 3.6.3.2 -------------------NOTE------------------- Valves and blind flanges in high radiation 7 areas may be verified by use of administrative means. Verify each containment isolation manual 31 days valve and blind flange that is located 7 outside containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls. CALVERT CLIFFS - UNITS 1 & 2 3.6.3-5 Revisionp'7

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.6.3.3 -------------------NOTE------------------- < 7 Valves and blind flanges in high radiation areas may be verified by use of administrative means. Verify each containment isolation manual Prior to valve and blind flange that is located entering MODE 4 7 inside containment and not locked, sealed, from MODE 5 if or otherwise secured and required to be not performed closed during accident conditions is closed, within the except for containment isolation valves that previous are open under administrative controls. 92 days SR 3.6.3.4 Verify the isolation time of each automatic In accordance power operated containment isolation valve with the is within limits. Inservice Testing Program SR 3.6.3.5 Verify each automatic containment isolation 24 months valve that is not locked, sealed, or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal. CALVERT CLIFFS - UNITS 1 & 2 3.6.3-6 Revisionp'7

Containment Spray and Cooling Systems 3.6.6 i 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems l LC0 3.6.6 Two containment spray trains and two containment cooling I trains shall be OPERABLE. l l l APPLICABILITY: MODES 1 and 2. MODE 3 except Containment Spray is not required to be 7 OPERABLE when pressurizer pressure is < 1750 psia. l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours train inoperable. spray train to OPERABLE status. M 10 days from discovery of failure to meet the LCO B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time of Condition A M not met. B.2 Be in MODE 3 with 12 hours 7 pressurizer pressure

                                               < 1750 psia.

CALVERT CLIFFS - UNITS 1 & 2 3.6.6-1 Revision A 7

Containment B 3.6.1 BASES ACTIONS Ad In the event containment is inoperable, containment must be restored to OPERABLE status within 1 hour. The 1 hour Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining containment during MODES 1, 2, 3, and 4. This time period l- alsoensuresthattheprobabilityofanaccident(requiring containment OPERABILITY) occurring during periods when containment is inoperable is minimal. B.1 and B.2 If containment cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a i 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. SURVEILLANCE SR 3.6.1.1 REQUIREMENTS Maintaining the containment OPERABLE requires compliance with the visual examinations and leakage rate test l ~/ requirements of the Containment Leakage Rate Testing Program. Failure to meet leakage limits specified in LCO 3.6.2 and LCO 3.6.3 does not invalidate the acceptability of-these overall leakage determinations unless their contribution to overall Type A, B, and C leakage causes that to exceed limits. As left leakage prior to the first startup after performing a required Containment Leakage Rate Testing Program, leakage test is required to be s0.6L.(207,600 SCCM) for combined Type B and C leakage 7 following an outage or shutdown that included Type B and C CALVERT CLIFFS - UNITS 1 & 2 B 3.6.1-4 Revisiong7

Containment 8 3.6.1 BASES testing only, and s 0.75 L. (259.500 SCCH) for overall Type A leekage following an outage or shutdown that included Type A testing. At all other times between required leakage rate tests, the acceptance criterla is based on an overall Type A leakage limit of s 1.0 L.. At c 1.0 L. the offsite l dose consequences are bounded by the assumptions of the i safety analysis. Surveillance Requirement Frequencies are as required by Containment Leakage Rate Testing Program. These periodic testing requirements verify that the

                   ;ontainment leakage rate does not exceed the leakage rate assumed in the safety analysis.

Additionally, the requirements regarding the Unit I containment purge isolation valves must be met. 7 SR 3.6.1.2 For ungrouted, post tensioned tendons, this SR ensures that the structural integrity of the containment will be 1 maintained in accordance with the provisions of the Concrete Containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of RegulatoryGuide1.35(Ref.4). 7 REFERENCES 1. 10 CFR Part 50, Appendix J Option B

2. Updated Final Safety Analysis Report, Chapter 14

3. Updated Final Safety Analysis Report, Chapter 5

4. Regulatory Guide 1.35. Revision 2. January 1976 7 CALVERT Cl.IFFS - UNITS 1 & 2 B 3.6.1-5 Revisiong7 1

L

Containment Air Locks B 3.6.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.2 Containment Air Locks BASES BACKGROUND Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all l HODES of operation. Each air lock is nominally a right circular cylinder, 9 feet-9 inches in diameter for the personnel air lock and 5 feet-9 inches in diameter for the emergency air lock, with l a dcor at each end. The doors are interlocked to prevent ) simultaneous opening. During periods when containment is l not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. Each air lock door has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected pressure following a Design BasisAccident(DBA)incontainment. As such, closure of a single door supports containment OPERABILITY. Each of the doors contains double gasketed seals and local leakage rate , testing capability tce ensure pressure integrity. To effect ' a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door). Each personnel air lock is provided with an alarm in the control room that actuates when either doar or equalizing valve for a personnel air lock is opened. The alarm senses 7 door position from a limit switch located on each door and equalizing valve. The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak-tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA. Not . maintaining air lock integrity or leak tightness may result l i CALVERT CLIFFS - UNITS 1 & 2 B 3.6.2-1 Revisiong7

                     =                              __

Containment ~ Isolation Valves B 3.6.3 B 3.6 CONTAINMENT SYSTEMS B 3.6.3 Containment Isolation Valves BASES BACKGROUND The containment isolation valves form part of the containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on an automatic isolation signal. These isolation devicesareeitherpassiveoractive(automatic). Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through thevalvesecurea),blindflanges,andclosedsystemsare l7 considered passive devices. Check valves, or other automatic valves designed to close without operator action following an accident, are considered active devices. Two barriers in series are provided for each penetration so that no single credible failure or malfunction of an active component can result in a loss of isolation or leakage that exceeds limits assumed in the safety analysis. One of these barriers may be a closed system. A blind flange is installed and sealed on the Containment E Purge and Exhaust System in Modes 1, 2, 3, and 4 on Unit 2. Similar equipment will be used on Unit 1 after a modification is installed. Until the modification to Unit 1 g is completed, the Containment Purge and Exhaust Isolation falves will be required for Containment Penetration Operability. Containment Purge and Exhaust Isolation Valves are not required for Containment Pene' ration Operability when the blind flanges are installed. Containment isolation occurs upon receipt of a high containment pressure signal. The containment isolation signal (CIS) closes automatic containment isolation valves in fluid penetratiors not required for operation of Engineered Safety Feature systems in order to prevent leakage of' radioactive material. Upon actuation of safety CALVERT' CLIFFS - UNITS 1 & 2 B 3.6.3-1 Revisionp'7 l

Containment Isolation Valves B 3.6.3 BASES injection, automatic containmsat isolation valves also isolate systems not required for containment or Reactor CoolantSystem(RCS)heatremoval. Other penetrations are isolated by the use of valves in the closed position or blind flanges. As a result, the containment isolation 7 valves (and blind flanges) help ensure that the containment atmosphere will be isolated in the event of a release of radioactive material to containment atmosphere from the RCS followingaDesignBasisAccident(DBA). The OPERABILITY requirements for containment isolation valves help ensure that containment is isolated within the time limits assumed in the safety analysis. Therefore, the OPERABILITY requirements provide assurance that the containment function assumed in the accident analysis will be maintained. 7 APPLICABLE The containment isolation valve LC0 was derived from the SAFETY ANALYSES assumptions related to minimizing the loss of reactor coolant inventory and establishing the containment boundary during major accidents. As part of the containment boundary, containment isolation valve OPERABILITY supports leak tightness of the containment. Therefore, the safety analysis of any event requiring isolation of containment is applicable to this LCO. The DBAs that result in a release of radioactive material withincontainmentarealossofcoolantaccident(LOCA),a main steam line break, and a control element assembly ejection accident. In the analysis for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through containment isolation valves (including containment purge valves) are minimized. The safety analysis assumes t'iat the purge valves are closed at event initiation. l CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-2 Revision E 7

Containment Isolation Valves B 3.6.3 BASES The DBA analysis assumes that, within 60 seconds after the accident, isolation of the containment is complete and leakage terminated except for the design leakage rate. La. The containment isolation total response time of 60 seconds includes signal delay, diesel generator startup (for loss of

.                                                       offsite power), and containment isolation valve stroke                                                 '

t times. 2 The containment isolation valves satisfy 10 CFR 50.36(c)(2)(ii), Criterion 3. LCO Containment isolation valves form a part of the containment i boundary. The containment isolation valve safety function is related to minimizing the loss of reactor coolant inventory and establishing the containment bouniary during a DBA. I The automatic power operated isolation valves are required to have isolation times within limits and to actuate on an automatic isolation signal. The valves covered by this LCO are listed with their associated stroke times in the Updated { FinalSafetyAnalysisReport(UFSAR)(Ref.1). { The normally closed isolation valves are considered OPERABLE ' when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind f j flanges are in place, and closed systems are intact. Containment purge supply and exhaust isolation valves being credited for Containment Penetration Operability shall be closed. They shall be maintained closed by isolating air to I the air-operator and maintaining the solenoid air supply valve de-energized. These passive isolation valves or devices are those listed in Reference 1. i This LC0 provides assurance that the containment isolation l valves will perform their designed safety functions to i l , CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-3 Revision,0'7

Containment Isolation Valves B 3.6.3 BASES minimize the loss of reactor coolant inventory and establish the containment boundary during accidents. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In H0 DES 5 and 6 the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. l Therefore, the containment isolation valves are not required I to be OPERABLE in MODE 5. The requirements for containment l isolation valves during MODE 6 are addressed in LCO 3.9.3,

                   " Containment Penetrations."

ACTIONS The ACTIONS are modified by a Note allowing penetration flow paths to be unisolated intermittently under administrative controls. These administrative controls consist of stationing a dedicated operator at the valve controls, who is in continuous communication with the control room. In this way, the penetration can bc rapidly isolated when a l need for containment isolation is indicated. A second Note has been added to provide clarification that, for this LCO, separate Condition entry is allowed for each ' penetration flow path. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable containment isolation valve. Complying with the Required Actions may allow for continued operation, and subsequent inoperable containment isolation valves are governed by subsequent Condition entry and application of associated Required Actions. The ACTIONS are further modified by a third Note, which ensures that appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve. 7 CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-4 Revision 97

_____._.__________m_. _ . _ _ _ _ _ _ Containment Isolation Valves B 3.6.3 ;

BASES ThefourthNoteallowstheshutdowncooling(SDC) isolation 7 valves to be opened when RCS temperature is < 300'F to establish SDC flow. This Note is reauired for Operation in MODE 4 to allow SDC to be established.

A.1 and A.2 i In the event one containment isolation valve in one or more )- penetration ' low paths is inoperable, the affected i penetration flow path must be isolated.- The method of F 1 solation must. include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic containment isolation

valve, a closed manual valve, a blind flange, and a check: valve with flow through the valve secured. For penetrations 7
isolated in accordance with Required Action A.1, the device used to isolate the penetration should be the closest

,                                         available one to containment. Required Action A.1 must be completed within the 4 hour Completion Time. The 4 hour Completion Time is reasonable, considering the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4.

For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and that have been isolated in accordance with Required Action A.1, the affected penetration flow paths must be verified to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no longer capable of being automatically isolated will be in the isolation position should an event occur. This Required Action does not require any testing or device manipulation. Rather, it involves verification, through a system walkdown, that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-5 Revision,0 7

Containment Isolation Valves B 3.6.3 BASES Time of "once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside containment, the time period specified as

                      ' prior to entering MODE 4 from H0DE 5 if not performed within the previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the isolation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

Condition A has been modified by a Note indicating that this Condition is only applicable to those penetration flow paths with two containment isolation valves and not a closed system. For penetration flow paths with one or more containment isolation valves and a closed system, 1 Condition C provides appropriate actions. Required Action A.2 is modified by a Note that applies to isolation devices located in high radiation areas and allows these devices to be verified closed by use of administrative

                     -means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these desices, once they have been verified to be in the proper position, is small.

i L.1 With two containment isolation valves in one or more penetration flow paths inoperable, the affected penetration flow path must be isolated within 1 hour. The method of isolation must include the use of at least one isolation barrier that cann0t be adversely affected by a single active n failure. Isolation barriers that meet this criterion are a l closed and de-activated automatic valve, a closed manual ! valve, and a blind flange. The 1 hour Completion Time is 7 CALVERT-CLIFFS - UNITS 1 & 2 B 3.6.3-6 Revisionp7 l

Containment Isolation Valves I, BASES q B 3.6.3 consistent with the ACTIONS of LCO 3.6.1. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be isolated on a periodic basis per Required Action A.2, which remains in ef tet. This periodic verification 1.1 necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolr~ - appropriate considering the fact that the valves are operated under administrative controls and the probi of their misalignment is low, l Condition B is nodified by a Note indicating this Condition is only applicable to penetration flow paths with two containment isolation valves. Condition A of this LCO addresses the condition of one containment isolation valve inoperable in this type of penetration flow path. C.1 and C.2 With one or more penetration flow paths with one or more containment isolation valves inoperable, the inoperable valves must be restored to OPERABLE status or the affected penetration flow path must be isolated. The method of isolation must include the use of at least or.e isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet thir criterion are a closed and de-activated automatic valve, a closed manual valve, and a blind flange. A check valve may not be used to 7 isolate the affected penetration. Required Action C.1 must be completed within the 72 hour Completion Time. The specified time period is reasonable, considering the relative stability af the closed system (hence, reliability) to act as a penetration isolation boundary and the relative importance of supporting containment OPERABILITY during H0 DES 1, 2, 3, and 4. In the event the affected ;,enetration is isolated in accoroance with Recuired Action C.1, the CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-7 Revision # 7 W1

Containment Isolation Valves B 3.6.3 BASES. affected penetration flow path must be verified to be i isolated on a periodic basis. This is necessary to assure leak tightness of containment and that containment penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for L verifying that each sffected penetration flow path is I isolated is appropriate considering the valves are operated under administrative controls and the probability of their misalignment is low. Condition C is modified by a Note indicating that this Condition is only applicable to those penetration flow paths with one or more containment isolation valves and a closs-system. This Note is necessary since this Condition is lI written to specifically address those penetration flow paths. in a closed system. Containment Isolation Valves and their associated penetration numbers are given in Table 5.3 of the UFSAR (Ref. 1). The penctrations on closed systems are ( listed below. Penetration h Function IB Containment Vent Header to Waste Gas 16 Component Cooling Water Inlet 18 Component Cooling Water Outlet 19A Instrument Air g 20A Nitrogen Supply 20B Nitrogen Supply 20C Nitrogen Supply

                                                                      '23           Reactor Coolant Orain Tank Drains

) '24 0xygen Sample Line 38 Demineralized Water 44 Fi-e Protection Required Action C.2 is modified by a Note that applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-8 Revision G,t

Containment Isolation Valves B 3.6.3 BASES to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small. D.1 and 0.2 If the Required Actions and associated Completion Times are not met, 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 challenrag plant systems. SURVEILLANCE SR 3.6.3.1 REQUIREMENTS This SR ensures thtt the containment vent valves are closed as required or, if open, open for en alls.iable reason. If a containment vent valve is open in vielation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessf w leakage when closed, it _is not considered to have leakage outside of limits. The SR is not required to be met when the containment vent valves are open for pressure control, as low as reasonably achievable (ALARA) or air quality considerations for personnel eatry, or for Surveillances that require the valves to be open. The containment vent velves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment isolation valve requirements discussed in SR 3.6.3.2. CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-9 Revision 0

Containment Isolation Valves B 3.6.3 l t BASES SR 3.6.3.2 This SR requires verification that each containment 7 isolation manual valve and blind flange located outside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The Containment Purge and Exhaust Isolation Valves required l for Contcinment Penetration Operability shall be determined closed by verifying that power to the solenoid valve is ; removed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since ! verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day j Frequency is based on engineering judgment and was chosen to ! provide added assurance of the correct positions. I Containment isolation valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the 7 correct position upon locking, sealing, or securing. The Note applies to valves and blind flanges located in high 7 radiation areas and allows these devices to be verified closed by use of administrative mecns. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, 4 and for ALARA reasons. Therefore, the probability of misalignment of these containent isolation valves, once they have been verified to be in : m proper position, is small. CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-10 Revision y 7

Containment fsolation Valves B 3.6.3

 , BASES SR 3.6.3.3 This SR requires-verification that each containment                          l isolation manual valve and blind flange located inside                 7     '

containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary l 1s within design limits. For containment isolation valves inside containment, the Frequency of " prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate, since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. Containment isolation valves that are open under administ ative controls are not required to meet the SR during the time that they are open. This SR does not apply to valves that are locked, sealed, or otherwise secured in the closed position, since y thase were verified to be in the correct position upon

                                  ~ ocking, sealing, or securing.

l i The Note allows valves and blind flanges located in high 7 radiation areas to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these containment isolation valves, once they have been verified to be in their proper position, is small. SR 3.6.3.4

                                 - Verifying that the isolation time of each automatic power operated containment isolation valve is within limits is required to demonstrate OPERABILITY. The isolation time test ensures-the valve will isolate in a time period less-than or equal to-that assumed in the safety analysis.            The CALVERT CLIFFS - UNITS 1 & 2                     8 3.6.3-11                          Revision 0

Containment Isolation Valves B 3.6.3 BASES isolation time and Frequency of this SR are in acct .nce with the Inservice Testing Program. Isolation times are not applicable for Containment Purge and Exhaust Isolation I valves because they are required to be closed. SR 3 qdd Automatic containment isolation valvas close on an isolation signal (C:S Channels A or B, or safety injection actuation signal Channels A or B) to prevent leakage of radioactive material from containment following a DBA. This SR ensures each automatic containment isolation valve will actuate to its isolation position on a containment isolation actuation signal. This Surveillance is not required for valves that are locked, sealed. or otherwise secured in the required position under administrative controls. The 24 month Frequency was developed considering it is prudent that this SR be performed only during a unit outage, since isolation l of penetrations would eliminate cooling water flow and disrupt normal operation of many critical components. ! Operating experience has shown that these components usually ! pass this SR when performed on the 24 month Frequency. Tirefore, the Frequency was concluded to be acceptable from a reliability standpoint. REFERENCES 1. UFSAR, Chapter 5 1 CALVERT CLIFFS - UNITS 1 & 2 B 3.6.3-12 Revision 9'l a

Containment Air Temperature B 3.6.5 BASES

Therefore, maintaining containment average air temperature within de limit is not required in MODE 5 or 6. ACTIONS Ad i When containment average air temperature is not within the limit of the LCO, it must be restored to within limit within 8 hours. This Required Action is necessary to return operation to within the bounds of the containment analysis. The 8 hour Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter l and provides sufficient' time to correct minor problems. l B.1 and B.2 If the containment average air temperature cannot be restored to within its limit 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. SURVEILLANCE SR 23 6.5.1 REQUIREMENTS Verifying that containment average air temperature is within the LC0 limit ensures that containment operation remains within the limit assumed for the containment analyses. In order to determine the containment average air temperature, an arithmetic average is calculated using measurements taken from the Containment Dome and the Containment Reactor Cavity temperature indicators selected to provide a representative 7 sample of the overall containment atmosphere. The 24 hour Frequency of this SR is considered acceptable based on the CALVERT CLIFFS - UNITS 1 & 2 B 3.6.5-3 Revisionp7

Containment Air Temperature B 3.6.5 BASES observed slow rates of temperature increase within containment as a result of. environmental heat sources (due tothelargevelumeofcontainment). Furthermore, the 24 hour Frequency is considered _ adequate in view of other l indications available in the control room, including alarms, to alert the operator to an abnormal containment temperature condition. REFERENCES 1. Updated Final Safety Analysis Report, Section 14.20 i CALVERT CLIFFS - UNITS 1 & 2- B 3.6.5-4 Revision 0

Containment Spray and Cooling Systems E 3.5.6 8 3.6 CONTAINMENT SYSTEMS B 3.6.6 Containment Spray and Cooling. Systems BASES-BACKGROUND The Containment Spray and Containment Cooling systems provide containment atmosphere cooling.to limit' post f j i accident pressure and temperature in containment to less j than.the design vaittas. Reduction of containment pressure { l and the iodine removal-capability of_ the spray reduce the-release of fission product radioactivity from containment to the environment, in the event of a Design Basis Accident , (DBA) .to within limits. The Containment Spray and_ 1

                                   - Containment Cooling systems are designad to the requirements in Updated Final Safety Analysis Report (UFSAR),

Appendix 10, Criteria 58, 59.-60, 61, 62,-63, 64, and.65

(Ref.1). l The Containment Cooling System and Containment Spray System ' are Engineered Safety Feature (ESF) . systems. They are designed to ensure-that the heat removal capability required j during the post accident period can be attained. The Containment Spray System and the Containment Cooling System provide redundant methods-to limit and maintain-post accident conditions to less than the containment design values. Containment Sorav System The Containment Spray System consists of two separate trains of equal capacity, each of sufficient capacity to. supply approximately 50% of the design cooling requirement. Each

                                   - train includes a containment spray pump, spray headers, nozzles, valves, and piping. Each train is powered from a-separate ESF bus. The refueling water tank.(RWT). supplies.

borated water to the containment spray during the injection phase of operation. In- the recirculation mode of operation, containment spray pump suction is transferred from the RWT' CALVERT-CLIFFS - UNITS 1 & 2 B 3.6.6-1 Revision 0

Containment Spray and Cooling Systems B 3.6.6 BASES tothecontainmentsump(s). Each spray system flow path from the containment sump will be via an OPERABLE shutdown 7 cooling heat exchanger. The Containment Spray System provides a spray of cold borated water into the upper regions of containment-to i reduce containment pressure and temperature and to reduce 'l the concentration of fission products in the containment atmosphere duri19 a DBA. The RWT solution temperature is an important factor in determining the heat removal capability of the Containment Spray System during the injection phase. In the recirculation mode of operation, heat is removed from the containment sump water by the shutdc.m coling heat exchangers. Each train of the Containment Spray System provides adequate spray coverage to meet 50% of the system design requirements for containment heat removal and 100% of the iodine removal design bases. The Containment Spray System is actuated either automatically by a containment spray actuation signal (CSAS) signal coincident with a safety injection actuation signal (SIAS)ormanually. An automatic actuation starts the two i Containmerit Spray System pumps, and begins the-injection

phase. The containment spray header isolation valves open upon a CSAS. A manual actuation of the Containment Spray System is available on the main control board to begin the same sequence. The -injection phase continues until an RWT

, level Low signal is received. The Low level for the RWT generates a recirculation actuation signal (RAS) that aligns valves from the containment spray pump suction to the l' containment sump. The Containment Spray System in 4 recirculation mode maintains an equilibrium temperature between the containment _ atmosphere-and the recirculated sump water. Operation of the Containment Spray System in the , recirculation mode is controlled by the operator in

accordance with the emergency operating procedures.

i er J CALVERT CLIFFS - UNITS 1 & 2 8 3.6.6-2 Revision 4 7

Containment Spray and Cooling Systems B 3.6.6 BASES LC0 During a DBA, a minimum of one containmu.t cooling train (3 of the 4 coolers) and one containment spray train is required to maintain the containment peak pressure and temperature below the design limits (Ref. 3). Additionally, one containment spray train is also required to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analysis. To ensure that these requirements are met, two containment spray trains and two containment cooling trains (all four coolers) must be OPERABLE. Therefore, in the event of an accident, the minimum requirements are met, assuming that the worst case single active failure occurs. Each Containment Spray System includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ansure an OPERABLE flow path capable of taking suction from the RWT upon an ESF actuation signal and automatically transferring suction to the containment sump. Each spray system flow path from the containment sump will be via an '7 OPERABLE shutdown cooling heat exchanger. Each Containment Cooling System includes cooling coils, dampers, fans, instruments, and controls to ensure an OPERABLE flow path. APPLICABILITY In MODES 1, 2, and 3, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature, requiring the operation of the containment spray trains and containment cooling trains. The containment spray system is only required to be OPERABLE 7 in MODE 3 with pressurizer pressure 21750 psia. In MODE 3 with pressurizer pressure < 1750 psia, a,d MODES 4, 5, and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Thus, the Containment Spray CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-5 Revision 9 7

Containment Spray and Cooling-Systems B 3.6.6 BASES System is not required to be OPERABLE in MODE 3 with pressurizer pressure < 1750 psia, and the Containment Spray and Cooling Systems-are not required to be OPERABLE in

                                                         -MODES 4, 5, and 6.

ACTIONS- A.1 With one containment spray train inoperable, the inoperable l containment spray train must be restored to OPERABLE status within 72 hours. Ir this Condition, the remaining.0PERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions. The 72 hour Completion Time takes into account the redundant heat removal capability afforded by the_ Containment Spray System, reasonable time for repairs, and the low probability of a DBA occurring during this pericd. The 10 day portion of the Completion Time for Required L Action A.1 is based upon engineering judgment. It takes into account the low probability of coincident entry into two Conditions in this Specification coupled with the low probaoility of an accident occurring during this time. Refer to Section 1.3, " Completion Times," for a more detailed discussion of the purpose of the "from discovery of failure to meet the LC0" portion of the Completion Time. B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status 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 3 with pressurizer pressure < 1750 psia within 12 hours. The '? al' awed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-6 RevisionJT'?

n , ,

Containment Spray and Cooling Systems B 3.6.0 BASES plant systems. The extended interval to reach MODE 3 with pressurizer pressure < 1750 psia allows additional time for the restoration of the containment spray train and is reasonable when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3. C.1 With one required containment cooling train inoperable, the inoperable containment cooling train must be restored to ! OPERABLE status within 7 days. The remaining OPERABLE !- containment rpray and cooling components provide iodine removal capabilities and are-capable of providing at least 100% of the heat removal needs after an accident. The 7 day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System and the low probability of a DBA occurring during this period. The 10 day portior of the Completion Time for Required Action C.1 is based upon engineering judgment. It takes into account the low probability of coincident entry into two Conditions in this Specification coupled with the low probability of an accident occurring during this time. Refer to Section 1.3 for a more detailed discussion of the purpose of the "from discovery of failure to meet the LC0" portion of the Completion Time. D.1 With two required containment cooling trains inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours. The remaining OPERABLE containment spray components provide iodine removal capabilities and are capable of providing at least 100% of CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-7 Revision 0

Containment Spray and Cooling Systems B 3.6.6

 -BASES t

the heat removal needs after an accident. The 72 hour Completion Ti..e was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and thu low probability of a-DBA occurring during this period. ' L E.1 and E.2 l If the Required Actions and associated Completion Times of Condition C or D of this LC0 are not met, 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 withfe 6 hours and to MODE 4 within 12 hours. The allowed Comphtion 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. F,1 With two containment spray trains or any combination of three or more Containment Spray System and Containment Cooling System trains inoperable, the unit is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately. SURVEILLANCE SR 3.6.6.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation. This SR does not apply to valves that- are locked, sealed, or otherwise secured in position since these were verified to be in the correct i CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-8 Revision 0

Containment Spray and~ Cooling Systems B 3.6.6 BASES position prior to being secured. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This SR does not require any testing or valve manipuiation. 'Rather, it involves verifying, through a system walkdown, that those valves outside containment and capable of potentially being mispositioned are in the correct position. SR 3.6.6.2 Starting each containment cocling train fan unit from the Control Room and operating it for 2 15 minutes ensures that all trains are OPERABLE and th0t all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected and corrective action taken. The 31 day Frequency of this SR was developed consitering the known reliability of the fan units and contro h , the two train redundancy available, and the low probability of a significant degradation of the containment cooling train occurring between surveillances and has been shown to be acceptable through operating experience. SR 3.6.6.3 Verifying a service water flow rate of 2 2000 gpm to each cooling un'.t when the full flow service water outlet valves are fully open provides assurance that the design flow rate 7 assumed in the safety analyses will be achieved (Ref. 2). Also considered in selecting this Frequency were the known reliability of the Cooling Water System, the two train. redundancy, and the low probability of a significant degradation of flow occurring between surveillances. CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-9 Revision D') w n . a

Containment Spray and Cooling Systems B 3.6.6 BASES SR 3.6.6.4 Verifying that each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head ensures that spray pump performance has not degraded during the cycle. Flow and differential pressure are normal tests of centrifugal pump performance required by the American Society of Mechanical Engineers (ASME) Code, Section XI (Ref. 6). Since the containment spray pumps cannot be tested with flow through the spray headers, they are tested on recirculation flow. This test confirms one point on the pump design curve and is indicative of nyerall performance. Such inservice inspections confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. The Frequency of this SR is in accordance with the Inservice Testing Program. SR 3.6.6.5 and SR 3.6.6.6 These SRs verify that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation signal (i.e., the appropriate Engineered Safety Feature Actuation System (ESFAS) signal). This Surveillance I is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for an en.nlanned transient if the Surveillances were performed with the reactor at power. Operating experience has shown that these components usually pass the Surveillances when performed at the 24 month Frequency. Therefore, the Frequency was concludeo to be acceptable from a reliability standpoint. CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-10 Revision # 7

Containment Spray and Cooling S, stems B 3.6.6 BASES The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements. SR 3.6.6.7 This SR verifies that each containment cooling train actuates upon receipt of an actual or simulated actuation signal (i.e., the appropriate ESFAS signal). The 24 month 7 Frequency is based on engineering judgment and has been shown to be acceptable through operating experience. See SR 3.6.6.5 and SR 3.6.6.6, above, for further discussion of the basis for the 24 month Frequency. SR 3.6.6.8 With the containment spray inlet valves closed and the spray header drained of any solution, low pressure air or smoke t can be blown through check valve bonnets. Performance of this SR demonstrates that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded. Due to the passive design of the nozzle, a test at 10 year intervals is considered adequate to detect obstruction of the spray nozzles. REFERENCES 1. UFSAR, Appendix 1C

2. UFSAR, Chapter 7

3. UFSAR, Chapter 6

4. ASME, Boiler and Pressure Vessel Code, Section XI CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-11 Revision 9')

i

Hydrogen Recombiners B 3.6.7 BASES l reasonable to ensure the instrumentation and control circuits are calibrated at an interval to accomplish the above requirements. i SR 3.6.7.3-This SR ensures that there are no physical problems that could affect recombiner operation. Since the recombiners are mechanically passive, they are not subject to mechanical failure. The only credible failures involve loss of power, blockage of the internal flow path, missile impact, etc. A visual inspection is sufficient to determine abnormal conditions (i.e., loose wiring or structural connections, deposits of foreign materials, etc.) that could cause such 7 failures. The 24 month Frequency for this SR was developed considering that the incidence of hydrogen recombiners failing the SR in the past is low. SR 3.6.7.4 This SR requires performance of a resistance to ground test for each heater phase to ensure that there are no detectable grounds in any heater phase. This is accomplished-by verifying that the resistance to ground for any heater phase is 2 10,000 ohms. This test is usually performed after SR 3.6.7.1 to verify the integrity of the heater electrical circuits. The 24 month Frequency for this SR was developed considering that the incidence of hydrogen recombiners failing the SR in the past is low. REFERENCES 1. 10 CFR 50.44

2. UFSAR, Appendix IC CALVERT CLIFFS - UNITS 1 & 2 B 3.6.7-6 Revisionp7

IRS B 3.6.8 6 3.6 CONTAINMENT SYSTEMS B-3.6.8 IodineRemoval' System-(IRS) BASES-

                            ~ BACKGROUND-                     The IRS is provided per Updated Final Safety Analysis Report (UFSAR), Appendix 10 Criteria 62, 63, and 64 (Ref.1), to reduce the concentration of fission products. released to the containment atmosphere following a postulated accident. The-
                                                             . IRS would function together with the Containment Spray and-Coo 11ng' systems following a Design Basis Accident (DBA) to--

L redWe the potential release _of radioactive material, L principally-iodine, from the containment to the environment. The IRS consists of three 50% capacity separate, independent (except for power), and redundant trains. Each train '? includes-a: moisture separator, a high efficiency particulate _ air (HEPA)-filter, an-activated charcoal /adsorber section for removal of radioiodines, a fan, and instrumentation. 3 The moisture separators function to reduce the moisture content of the airstream. The system initiates filtered recirculation of the containment atmosphere following receipt-of a safety' injection ' actuation signal. The system design is _ described in Reference 2. The moisture separator is _ included for moisture (free water) removal from.the. gas stream. The moisture separator is important to the effectiveness of the charcoal adsorbers.

                                                             -Three-IRS' trains are.provided to meet the requirement for separation, independence -(except for power), and redundancy.
                                                             'Two trains of_the~ IRS are powered by separate Engineered

Safety-Features buses. The third IRS train is a' swing train that can-be aligned to take power from either Engineered 7

Safety Features bus. CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-1 RevisionJ/ 7

IR1 B 3.6.8 BASES APPLICABLE The DBAs that result in a release of radioactive iodine SAFETY ANALYSES within containment are a loss of coolant accident (LOCA), a main steam line break (MSLB), or a control element assembly (CEA)ejectionaccident. In the analysis for each of these accidents, it is assumed that adequate containment leak tightness is intact at event initiation to limit potential leakage to the environment. Additionally, it is assumed that the amount of radioactive iodii.e release is limited by , reducing the iodine concentration in the containment i atmosphere. The IRS design basis is established by the consequences of the limiting DBA. The accident analysis (Ref. 3) assumes that only two trains of the IRS are functional due to a single failure that disables the other train. The accident analysis accounts for the reduction in airborne radioactive iodine provided by the remaining two trains of this filtration system. The IRS satisfies 10 CFR 50.36(c)(2)(ii), Criterion 3. LC0 Three separate, independent (except for power), and redundant trains of the IRS are required to ensure that at-least two are available, assuming a single-failure coincident with a loss of offsite power. APPLICABILITY In MODES 1, 2, 3, and 4, iodine is a fission product that can be released from the fuel to the reactor coolant as a result of a DBA. The DBAs that can cause a failure of the fuel cladding are a LOCA, MSLB, and CEA ejection accident. Because these accidants are considered credible accidents in MODES 1, 2, 3, and 4, the IRS must be operable in these MODES to ensure the reduction in iodine concentration assumed in the accident analysis. In MODES 5 and 6, the probability and consequences of a LOCA are low due to the pressure and temperature limitations of CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-2 Revisiong7

IRS B 3.6.8 BASES 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. SURVEILLANCE SR 3.6.8.1 REQUIREMENTS Initiating each IRS train from the Control Room and operating it for 2 15 minutes ensures that all trains are ; OPERABLE and that all associated controls are functioning ! properly. It also ensbres that blockage, fan or motor failure, or excessive vibration can be detected for 7 corrective action. The 31 day Frequency was developed j l considering the known reliability of fan motors and i l controls, the two train redundancy available, and the iodine i removal capability of the Containment Spray System independent of the IRS. SR 3.6.8.2 ! This SR verifies that the required IRS filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated ! charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP. SR 3.6.8.3 The automatic startup test verifies that both trains of equipment start upon receipt of an actual or simulated test 1 CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-4 Revisiong7

.g

IRS B 3.6.8 BASES signal (ESFAS). The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the-reactor at power. Operating experience has shown that these components usually pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was-concluded to be acceptable from a reliability standpoint. Furthermore, the Frequency was developed considering that the system equipment OPERABILITY is demonstrated on a 31 day Frequency by SR 3.6.8.1. REFERENCES 1. UFSAR, Appendix 1C

2. UFSAR, Section 6.7

3. ~UFSAR, Section 14.21 CALVERT CLIFFS - UNITS 1 & 2 B 3.6.8-5 Revision 0

 ~     ,                        ._        -                                                                       ,

s pa.,.$ tch e ^ 3 . G. . I 3.6 ' 4/64 .CONTA!MDff SYSTENS _

36. 1 2nJJ (htMARf CONTAIMENT_

10NTAINNE INTE 3 LIMITING CONDITION FOR OPERATION 4co 3,6. 0 4. '. J

                                           ' Primary CONTA!WENT INTEGRITY                                                      a        sh ll b elaatntaine.

4 APPLICABILITY: MODES 1. 2. 3 and 4. gg Aeru 4 {[ t WLm ITY Tw' ri n on Acr'ad S (\ CONTAIMENT &IFfth'fM restore CONTAIIMENT/ ~ 6 hours and in COLD SNUTDOWil within the east 11M STANDIY . following within the next30 hoursr or be in at ' SURVEILLANCE REQUIREMENTS Q.6M Primary C91RAINNENT INTEGRpf shall be=dja6nstratedO

                                    's TITeiiss not capableonce                                                   of being  per       a cays closed     by CPERABLEby verifying               f that all containment                  penetratio automatic f
                                       ~
                                       "  isolation valves and required to be closed during accident coMitions are closed by valves, blind flanges or deactivated I

that are3.6.4.I.e

                                         $pecification                                                  open under administrative                            y ves) control as permitted b Y
                                   %. yv                        fying thas eacn co utrente of snecidnt-tfon                              m as air Iccm is 1 3.6.1.                     11ancewM

c. -

{h j s . 140, to entering MODE 4 following by conducting a Type B test e, a shutdownguipmBy rior entbatch gt h b ,,......,m IJ&t hic-u $ f o7..(se g Ane

                                       ~                                        ' accordanen fY r)e C.Ja;y F 1skape 7Pf&
                                                                                                                  ~       -

l

     % 4q
        .S $                       conta nment pressure controlliydro en purge containment vent 1 solation valv surveillance testing purposes.                                                      airborne radioactivity contro , ande ocened for' only.

45h # ?. 9 ( 1

{ j 4. p o

                   **             temperature is belew 300'F to                                                                                          estabitsh5h5 e RCS g flow.              '
                                                                                                                                                                          .-          shutdown coolin          i
       =g5<:                                                                                                                                                                      (e}

y are ocated otherwise secured in the closed position. inside the containment a ves which and

                                                                                                                                                      , or              t are locked. seale
                                                                                                                                                                                                               }

1 be verified closed during each COLD SHUTDOWN such except 3 p{ thatThese penetrat verification need not be performed more often then once otr92 d ,

                                                                                                                                                                                 #,   I CALVERT CLIFFS - UNIT 1                                                                       3/4 6-1                                                                                      i Amendment No. 187                                A4 SR 3.G l l    %Cm re m el 1..u e ,u d c ,y. rad an al es,,,p                                                                              w e k ou.pr_f^,e, u u .y u                                                                                                       <                    <*A< hsNum # j.'[     -

con e h e,A.a r , n%m ' a - - _ _

sp OtAs 3. c. , I

                                                                                     * *+

(/. ice nse E*

h INSERT A By verifying that the containmenoblind flanges are installed and seale[ prior to entering MODE 4 following a shutdown where the blind flanges were removed, by conducting a Type B test per 10 h

CFR Part 50, Appendix J. Ifonly one blind flange was removp only that blind flange mu g L 3' i aam +es% is repd Q 3,, 3,,,,,,, ,c s y, Tehats 5yM;e yt,a,2, , g,ug g, o

                                                   %.s,w c M'
                                                  \

pa y A. c ' Li - a L A d 2.tl

6pdctMo^ 36.1

          '3.f.       @ ColfTAlletENT SYSTDt3 3,4,g                                              CONTAlletEIN Containm3e Le                ne L3MITIll4 Col 10!TI0ll FOR OPERATION f o 3,(,,f         M Containment {cesseyttetshall behdT&                                                                      .
                             @ fi maximum allowable containment leakage rate. L,. as spt7,tfied t@
                                   ' Specification 6.5.6 'C@m                       nment Leakage Rate Testing Program.'

(j) ' A combined leakage rate o'

                                                                                                 ' 9 0 I"" ~^h' ll                Lk= *s e.

{ yp estsf h11s Jpenetrationsa4valvessub 5 ?Y" an

                                                                                                                    ~
                                                                                      ,As spec lWed in Speci$seafl5 4.SA, Aa'daat h

APPLICABILITY: MODES 1, 2, 3 and 4

                                                                                       'C*afaim ient ledI'dPe Tale V8th Np Ic7t,4J          FACTION: Witis either (a) the measured overall integrated containmens A g               leakage rate exceeding the acceptance criteria specified in the Containmend jrateforLeakage Rate Testing Program, or (b) with the measured combined leakage
             - TexceediM netrations and valves subject to Types 8 and C tests L,, restore the overall integrated containment leakage rate OQ60 to within e acceptance criteria specified in the contat_Weakace Rate                                                                              g Testing ProorMnd the combined Teakane rate'or all penetrations an
                    .\talves tubject to_TypesB and C_ test-A: 1:;uh:; ::;;.;U; 0.;0 L' prior Qo increasing the Reactor Coolant System temperature above 200*F liumst A.ed a.t

1. M

                                                                                                                                                                            }h I

i f be scufceeno E dwn A to SURVEILLANCE REQUIREMENTS (\N"Se.cf-u%n "d"MM d'aMa/l f s

                                       $;                                 $1       e                       o                  cw     the icritera,methodyvand oWsions specified in lic r#R Eart eusp'oeM ne. CewM=en c                        A

[. Leu qs h +e

               '                      erform required visual examinations and9',:;h in                                                           stig',*y*W                     !

Q accordance with the Containment Leakage R D Testing Frogram. - -- ( fing,except See containonent air

                                                                                                       ^                    ~
                                                                                                                                                                ,$t
                                                                                                                                                               &R SV 24.\.\      -

CALVERT CLIFFS - UNIT 1 3/4 6-2 Amendment No. 216 y 3 .of /0

u. a w -

b I

TC fahkh,l 3/4.6 CONTAINMENT SYSTDt3 SERVEILtMCE REQUttDENTS (Contiaved) I 1 b. Containment purge ibolation valves shan be demonstrated OPERABLE ' . any"last the surveillance test has been perfonned within the,p six mont.*s or any time after being opened and prior to entering N00E 4 from shutdown modes by vertfying that when the measured letkage rate is added to the leakage rates detemined pursuant to Technical Spectftcation 4.6.1.2.a for all other Type B or C . penetrations, 0.60 L The leakage rate for the containment purge j isolationt valvess , hall also be compared to the previously measured leakage ,' rate to detect excessive valve degradation, c. The containment purge isolation valve seals shall be replaced with new seals at a frequency to ensure no individual sen1 remains in service greater than 2 consecutive fuel reload cycles. Ses htswa & C%ges or ITS f,6 Jh 3 hemk/inKCitk Lechttg kk Te&S Prostw I CALVERT CLIFFS - 1) NIT 1 3/4 6-3 Amendnent No. 219

1 l l fage 4o0 \D 1

l ! 6pecific. he u,l l l

          '3, (.       @ CONTAIP0fT SYSTDt3 3.6 l        QfffM                 [PRIMMY CONTAIMENT CONTAIMENT      EGRIH LIMITING CONDITION FOR OPERATION Lco 3,g,l        (TAJ.D Primary CONTA! MENT INTEGRITY shall be maintained.*1                                     g APPLICABILITY: MODES 1. 2. 3 and 4.

Acnw/ A ((KMit WIthet orinsMCONTAIMENT Q g QQJjg ~ restoreCONTAIIGIENT/ AllF'ElkITYJwithin one hour or be in at eas T STANDIY within the next Actr 18 I6 hours and in COLD SNUTDOW within the following 30 hours. SURVEILLANCE REQUIREMENTS

(4.6.M Primary C0NifAIMENyfNTEGRITY sh3W be demonstr M f Q 'At least once per 31 days by vertrying that all penetrationd not capable of being closed by OPERABLE containment automatic $ isolation valves and required to be closed during accident

conditions are closed by valves, blind flanges or deactivated automatic valves secured in their positions ex, cept for valves f-that are open under administrative control as seraitted by J e' M fication 3.6.4.1.1 e n of ec n3 1.: c. By verifying snat Ine equipment hatch is closed and sealed, prior to entering N00E 4 following a shutdown where the e di nt hatch

[A; _- y ned, by conducting a Type B test t s_ Q C; r 2ro O .

                                                                                                              .gr g

1 * ~ u!

                                                                $e C., tat ~enf & e*Rek^7Esh y                                       a;u.w I j         y:       Ax4
       %g4 ,i        =       L' 4**. p,d g

c. 44 4h Hydrogen purge containment vent isolation valves shall be opened for7 containment pressure control, airborne radioactivity control, and ><<5

        %g            '

surveillance testing purposes only. M g, [2 The shutdown cooling isolatica velves may be opeaed when the RCS temperature is below 300*F to establish shutdown cooling flow.

                                                                                                                    *e f c, I Q '0        **                                                                                                 o a.   +- J Except valves blind flanges, and r tivated automatic valves which are located inside the containmen                   are locked, sealed. or             & MG[
                 -9                                                             s otherwise secured in the closed po s .on. These penetrations shall be verified closed during each COLD SHUTDOWN except that such verification need not be oerformed more often then once oer 92 days.)

4, CALVERT CLIFFS - UNIT 2 3/4 6-1 Amendment No. 164 g '3,b,d [ b pe es ce,4 fir c,MaE*M M ej

                                                                                                                         ^g df[" A d4 4 c.AnJ L,.Ly R 4e.g                                   in ud"*

feshn Pt. f m. L. L .y M

                                                                      -_w -                                           iTeAq R E ""

litmt. &rterAs l9(o 4 \U f"Y Y '

6 p e &,b 3. (. . I INSERT A 0'n55 v$' '"" By verifying that the containment i blind flanges are installed and sealedhrior to entering MODE 4 following a shutdown where the blind flanges were removed, by conducting a Type B test per 10 CFR Part 50, Appendix J Ifonly one blind flange was removp only that blind flange ~ must be u.a,ss 4ngis e,c u ,n3 IethwicA\ SP Ge d o b 4,6d,1, Su bgce.h of, chp

                                 ~-               "

pn sgc,0,..bn 5,o

                                                            " M e a % h s Cock k "

l l l UCLmithsNttst\Q~j Y

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

5p 0 .b 3.4.l l 8' b @ CMTAINMENT SYSTEMS

8. (.. / h @ i h CONTAINM M Containme La ane LIMITING CMDITIM FOR OPERATI M h/ 46(.6

                 /EZ"Eh Containment 6 shall batllefterth:

0

                          @ Tmaximum allowable containment leakage rate, L , as specified in' Specification G.5.6. ' Con            LeakageRatetestingProgram."                $
                          $        A combined leakage rate of

einy L RR 050 su.m. for all i uga penetrations and valves subTect to IvnesI and C tests @ ( A aced pipnivruva ec h spw0 4 la sp.AW -

I /%

                                                               %       -.a w e. %g, @,g APPLICABILITY: MODES 1, 2, 3 and 4 bW            6       : With either (a) the measured overall integrated containment A[8                   e rate exceeding the acceptance criteria specified in the Jintainme k,,,,LeakageRatoTestingProgram,or(b)withthemeasuredcombineo)eakage rate for_t11_ penetrations and valves subject to Types B and C tests

, h3)exceectngw L,, restore the overall integrated containment leakage rate i j , to within the acceptance criteria specified in the Containment teakage Rat

               ) Testing Prograpnd the cottoined leakane rate for all nonetrations ana                                     Licmc        A naIvet   muniect to Tyne B and c tatttE1611Ahafi n/ ewil td 0.5(L,) prior j to increasing 'the Reactor Coolant System temperature above 200*F. ~                        /       l
                                                                                                                          /w< daa d 1 46 g
                                                                                .Sao D4cewee ,C & esp f,e Sp e .f* < <h.n .$.o SURVEILLANCE REQUIREMENTS                                  "/14, l,.u4r.h d.dr.ls

f4.6.1.2 The containmcot leakage ratesGAalVbeAlmstrates at/tbo UoWow1Ap tadtKschedul8 (g;shall be detennined in confonnance with the [h46 Qriteria, methodg9nd provisions specified in 40 yFR Patt AU./ApD(nd1K J.A ,

g Perform required visual examinations and uben tIstH81n 1 Litf"fC

S R % ).1 -

accordance with the Containment Leahge Rate Testing Program.) hes4 <d flesk y a h k d/p ace / 4 ) g, (dood,w,,-/ g, ,J ./;. ,f, Ne. Canbdmeat f.eak4g C. h te Its S32rogr e . CALVERT CLIFFS - UNIT 2 3/4 6-2 Amendment No. 193 N$ $&

Spes h b 3.6.l t 3/4.6 iQ!EU4 MENT SYSTEMS SURVEILLANCE REth'IREMENTS (Continued)

b. T e) a d te ts ha 1 nd et

in t, is of 4 n s xc t or te ts n lv ng I th ga a P (5

                                                                                                 *,o kp ig         4 g,

N g \ c. A c : al be te e an d tr te 0 LE e f 44, nu i Su ve la ce Re i t 6. 3 .

,qg

d. A1 p B n C es, le ka e te s al b ca cu te e 4 1 -

ob er d a ny rt t a 50 te va ue . a N l Contal nt purge olation val es shall be any ti upon ent ing N0DE 5 rom POWER OP nstratedfrERABLElt TION N00E54 unless the I st survell nce test ha been perfo d within t ~ past 6

                 @-            mon s or any t        after bei g opened an prior to en ring                            g ,g 4 from sh down modes y verifying het when th measured 1p kage rate       added to t e leakage r es determin pursuant to                       pg, j

.4.f,2.a J e hnical So ificatioAC4.:.2.9 for 11 other T B or C & M/

tra p the.__coqbin leakage r e is less t or equal to 4 040 ge t isY" ",00GGriy. he leakage ate for the ontainment p on vaWes hall also b compared to he previous) measured akage rate o detect ex stive valve egradation. The con inment pu ' isolation Ive seals s 11 be replac with n seals at frequency t ensure no 1 ividual seal (

                    ,          remai s in service greater tha 2 consecutiv fuel reload yeles.

4 Deters) Q e=#f W h 8 CALVERT CLIFFS - UNIT 2 3/4 6 3 Amendment No. 189

                                                                                                                   @ 'g a ,sa~ uv w m                                                                                           P9 * 'Y IA.

DISCUSSION OF CHANGES SECTION 3.6.1 - CONTAINMENT ADMINISTRATIVE CIIANGES A.1 The proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change of intent, to be consistent with NUREG-1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable by plant operators, as well as other users, During the Calvert Cliffs Improved Technical Specifications (ITS) development, certain l wording preferences or conventions were adopted which resulted in no technical changes to l 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 l l NUREG 1432, flowever, the additional information does not change the intent of the l current Technical Specifications. The reformatting, renumbering, and rewording process involves no technical changes to existing Speci0 cations. A.2 Current Technical Specifications 3.6.1.1 (Containment integrity), 3.6.1.2 (Containment Leakage), and 3.6.1.6 (Containment Structural Integrity) will be combined into one Technical Specification in the ITS. Improved Technical Specification 3.6.1 (Containment) will incorporate these three Speci0 cations. Any technical changes as a result of combining these Specifications will be discussed in other Discussion of Changes. This change only describes combining the Specifications and other related administrative changes. Combining Technical Specifications without technical changes constitutes an administrative change. This change is consistent with NUREG-1432. A.3 Current Technical Speci0 cation 3.6.1.2 Action requires that all the containment leakage requirements be within limits prior to increasing the Reactor Coolant System (RCS) temperature above 200 F. The Action does not specificall/ contain requirements for the condition when the leakage is out-oflimits in Modes I throua,h 4, therefore, LCO 3.0.3 would have to be entered. Limiting Condition for Operation 3.0.3 requires the plant to prepare to shut down in 1 hour, and to be in Mooe 3 in 7 hours, and in Mode 5 in 36 hours. Improved Technical Specification 3.6.1 Actions will be more general because of the combination of Current Technical Specifications (CTS), as described in another discussion of change. However, for the case when leakage is not within limits, the Actions require I hour to restore the out-of limit condition to within limits, or to be in Mode 3 in 6 hours, and in Mode 5 in 36 hours. The total Completion Time allowed is the same for the ITS as for the CTS (37 hours to be in Mode 3). Since the Completion Times are consistent between the ITS and CTS, this change is administrative. This change is consistent with NUREG-1432. A.4 Improved Technical Specification Surveillance Requirement (SR) 3.6.1.1 requires the performance of a visual examination and leakage rate testing, except for containment air lock testing, in accordance with the Containment Leakage Rate Testing Program. This Surveillance ties the requirements of the Containment Leakage Rate Testing Program to containment Operability. The addition of a Surveillance, which requires a program that will consist of CTS SRs and CTS requirements (i.e., CTS 4.6.1.1.c,4.6.1.1.d,3.6.1.2.a,3.6.1.2.b, and 4.6.1.2.b) to be followed, constitutes an administrative change. This change is consistent with NUREG 1432, TSTF-52. CALVERT CLIFFS - UNITS 1 & 2 3.6.1-1 Revision 7

DISCUSSION OF CHANGES SECTION 3.6.1 - CONTAINMENT A.5 With the structural integrity of the Unit I containment not conforming to a level consistent l with the acceptance criteria of CTS 4.6.1.6.2 or 4.6.1.6.3, Action b of Unit 1 CTS 3.6.1.6 1 requires structural integrity restored or an engineering evaluation that assures structural integrity be completed prior to increasing the RCS temperature above 200*F. This requirement is not explicitly contained in ITS 3.6.1. However, it is addressed via ITS SR 3.0.4. In accordance with ITS SR 3.0.4, the applicable Surveillances for an LCO are required to be met within their specified frequency prior to entry into a Mode of Applicability. The CTS Surveillances which established the structural integrity of the containment have been incorporated into the Containment Tendon Surve:: lance Program contained in ITS Section 5.0. Improved Technical Specification SR 3.6.1.2 invokes the Containment Tendon Surveillance Program. Thus, ITS SR 3.0.4 will require the structural integrity of the containment to be established (i.e., containment to be OPERABLE) prior to entering Mode 4 (i.e., prior to increasing average reactor coolant temperature to greater than 200'F). This requirement is equivalent to Action b of Unit 1 CTS 3.6.1.6. Thus, deleting Action b of Unit I CTS 3.6.1.6 is an administrative change, which does not change the intent l of the CTb. A.6 Current Technical Specification 3.6.1.6 SRs are being moved to the Containment Tendon Surveillance Program in ITS Section 5.0. Improved Technical Specification 3.6.1 will contain an SR (SR 3.6.1.2) which requires the containment structural integrity to be verified in accordance with the Containment Tendon Surveillance Program. Adding an SR which references a program in Section 5.0 constitutes an administrative change. This change is consistent with NUREG 1432. A.7 Current Technical Specification SR 4.6.1.1.b requires the verification that the containment air locks are in compliance with the requirements of Specification 3.6.1.3, This SR has not been retained in ITS 3.6.1. Current Technical Specification SR 4.6.1.1.b invokes Specification 3.6.1.3, which provides requirements to ensure the operability of the containment air locks, In the ITS, the operability requirements for the containment air locks will be contained in ITS 3.6.2. This proposed change climina*c2 an SR which simply invokes another TS; i.e., it is simply a cross-reference to another Specification. The elimination of CTS SR 4.6.1.1.b is administrative, because this proposed change does not change the intent of the CTS, the co.itainment air locks requirements are still required by CTS 3.6.1.3 and ITS 3.6.2. TECIINICAL CIIANGES - MORE RESTRICTIVE M.1 Unit 1 CTS 3.6.1.6 Action a requires the plant to be in Mode 5 within 36 hours, if the Required Actions and associated Completion Times cannot be met, when the containment , structure exhibits evidence of possible abnormal degradation, per Specification 5.5.6,

            " Concrete Containment Tendon Surveillance Program."                   Improved Technical Specification 3.6.1 requires the plant to be in Mode 3 within 6 hours and in Mode 5 within 36 hours. This change adds an intermediate step to be in Mode 3 in 6 hours to the shutdown track. This change is acceptable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner, and without challenging plant systems. Adding an intermediate step will not adversely affect plant safety because it ensures a shutdown that minimizes stress on safety systems. This change is consistent with NUREG-1432.

CALVERT CLIFFS - UNITS I & 2 3.6.1-2 Revision 7

DISCUSSION OF CIIANGES SECTION 3.6.1 - CONTAINMENT M.2 Unit 2 CTS 3.6.1.6 Action requires the structural integrity to be restored within 24 hours when it is not conforming to the requirements of the LCO. Improved Technical Specifications will require the contslament to be restored to Operable status within one hour, The ITS will require the containment to be declared inoperable if its structural integrity is not maintained and the contaioment cannot meet its design fimetion. His change is considered more restrictive because it is assumed that the containment is inoperable when the Actions are e itered. Therefore, the AOT is decreased from _24 hours to I hour, Decreasing the AOT constitutes a more restrictive change. His change will not adversely affect pant safety because the containment is one of the three barriers against a release of radiation. This change is consistent with NUREG-1432. TECHNICAL CHANGES - RELOCATIONS None TECIINICAL CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS LA.1 Unit 1 CTS 3.6.1.6 Action a allows 90 days to perform an engineering evaluation when the containment structure exhibits evidence of possible abnormal degradation, per the tendon Surveillances. This requirement is being relocated to the Technical Requirements Manual (TRM), a licensee-controlled document. This is acceptable, because moving the requirement does ut affect the requirement to maintain the containment OPERABLE The requirement only applies when the operability of the containment is indeterminate, if there is evidence that the containment may be inoperable, prompt action should be taken to evaluate the condition to determine its impact on the capability of the containment to fulfill its safety function. Questiona regarding the operability of systems, structures, and components are 4 addressed routinely during the operation of the units. The ITS do not provide requirements for conducting operability determinations. In the event the containment is determined to be inoperable by an engineering evaluation performed in accordance with this requirement, the plant will be required to immediately enter Action A ofITS 3.6.1. The Actions ofITS 3.6.1 provide adequate protection of the health and safety of the public. Additionally, the level of safety of facility operation is unaffected by the change because there is no change in the requirement to perform an engineering evaluation to determine if the containment is inoperable. Thus, the requirement of Unit 1 CTS 3.6.1.6 Action a to perform an engineering evaluation to demonstrate containment operability can be adequately controlled in the TRM. 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. LA.2 Not used. l LA3 Not used. l A TECHNICAL CHANGES - LESS RESTRICTIVE L.1 Unit 1 CTS 3.6.1.6 requires a plant shutdown if the containment tendons or structure exhibit evidence of abnormal degradation, and continued operation cannot be justified by an engineering evaluation within 90 days. Improved Technical Specification 3.6.1 Action A CALVERT CLIFFS - UNITS I & 2 3.6.1-3 Revision 7

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

DISCUSSION OF CHANGES SECTION 3.6.1 - CONTAINMENT will allow I hour for the containment to be deemed Operable following the engineering evaluation performed within 90 days. This change increases the Completion Time from immediately beginning a shutdown, to one hour. This added Completion Time will allow a period of time to prepare for a possible impending shutdown This time period also ensures that the probability of an accident (requiring containment Operability) occurring during periods when containment is inoperable is minimal. Allowing an additional one hour to complete a Required Action constitutes a less restrictive change. This change is consistent with NUREG 1432. l

 - CALVERT CLIFFS - UNITS 1 & 2                 3.6.1 4                                    Revision 7

Apa Me.M ~54,2

                                                                             @ CONTAINMENT SYSTEMS QM5J               iE4BE03PEiE@                                                                                           '

Containment Air Locks LINITING CONDITION FOR OPERATION L c o 7. 6 2.

                                                                                    $ poth a tainment air loc @ hall be OPERABLE withs s closec exceps wnen the     r lock is being ustf for I h

normal ansit entry and exit t gh the containment /th'en at) 0g'f less ne air lock door shall osed. and;

                                                                                    @ An overallair lock leakage rate of                                 !? M 3 b M                     ^'

MDLidQQo; Tid QbaekdieA.dyc% T, APPL!CABILITY: MODES 1, 2, 3 and 4. 8' laAme g af., g [f g ta FCT10Nt zwsrAf A.noy - A l'$ ACT'I l i Aj d, f C - (ii) f ith air lock inoperap sket. restore the Ni1ock except to apremas a result r emn,of anIinerablh or be in at least it0T STANDBY within the next 6 hours and 94 C h Aenv/ b -- N ni COLD SHUTDOWN within the following 30 hours. With an air ocK inoperaDie due to n inoperable door gask : AcfM A ll. Maint n the remaining door the affected air loc closed and ealed, and hny d... .Q [2. store the air lock to ERAntr status within 1 davt ne he ' fin at least HOT STANDBY within the next 6 hours and in COLD gg NSHUTDOWN within the fellowing 30 hours.

4.3

                                                                                                                                                   .7NJfM Acr*A' Marfs: /.

SURVEILLANCE REQUIREMENTS A .4 4.6.1.3 Each containment air lock shall be demonstrated OPERAilLE: S R 1 6 7..I A a.khtereah e n e ce t he t a r oc is be ng us d or\ { R mu ti le nt te , he a 1 ast on e r 2 ou r 1 - th t t e ea 1 ka e s 0 00 ' L .2 SC ) s et ne b L;n g J re is on lo a as r en w n he vol be et te oo s al p"'g ' A s r ur ze t a on ta t te ur o 1 ps . 11 -(A perfere:ng con lAlnmenf air lock le2520e PAlb hsfin wi/b Qc.J,;,,-,J ic,haga u a,,, a ,, g ,,a in acrattlance 0 (l\)ofos luh 2, & A

                                                                                      -.,. . , _ _ . , n. r. e eN. . . . .

g $, fg 3,y, a.. l

                                                                                               ...- .. .            .~

DELETf CALVERT CLIFFS - UNIT l' 3/4 6-4 Amendment No. 212 l pay /$ 7 utweA A azm g

ApoeoA,bw 3.6. L INSERT SR 3.6.21 SR 3.6.2.1 --------------.--NOTES-.-.---------..---

1. An inoperable air lock door does not

invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perfo equired ai lock leakage ate /nI accordanc tepsng in accor nce with th ontainmen with the f akage Rate T ting Progra . 7 Contain nt Leakaj Rate h ( Tejring Program J J

Spi 6cd n 3 , (..L

                                                                                                    -3/4.6 CONTAIlttENT SYSTDtS_

SURVE!LtAllCE REQUIRDtENTS (Continued)

                                                                                                             . A le st o               th b c nd et g an o ra 1 le ka                    si                                      c        Li""t d y e f n t at t 1 10 k e 1 wt ht             s la t, an we a       A*A*"t Ad        h d, 3*%'2'E               b*       At least each  air once  per(Doonths by vertfyiag that only one door in lock can  4 opened at a time.

l I CALVERT CLIFFS - UNIT 1 3/4 6-5 AmendWnt No. 212 l paje 7. f 7 Liceu 64 ..a t19-l3

_. .- .-- -~ - Qcafted,% 3-(o,*2. SA GHiD CONTAINMENT SYSTEMS

2. u 2.

M (kHSRY CQWTAUGENT) Containment Air Locks '

                    -LIMITING CONDITION FOR OPERATION Leo 3,g,,2         M . : .0-containment air locl@shall be OPERABLE with:

8'Bothd s closed except when e air lock is being ujdd, for T no Qea ransit entry and ext through one air lock door shat be closed, andr the containmeJK. then at) Q D - (Q

                                                                                               /                                   -- f A 2.

1r lock leakage rat _e .ciQ.p.05 QQ:Q00 ",;;^Q-K - in. v-- e ei Nd In(Spy 1f1esIt.A.LV C*ntainNst A;hi Af - ([].\ APPLICABILITY: MODES 1, 2, 3. and 4. gg, pgt, 7,,f;,,9 g,

FCTION:

    ,o. .                    a. yi                 ai y,ja y                            &

d ou.,r lock.. r.. inoperable,fi-

                                                                .. ,s. ,       cept.-as a..re.s.u,l.t.o.f r         . .. an.i.rfbper,a,blel s,.              i              c.

fyg,c. , or be in at least NOT STANDBY within the next 6 hours and _/$1n COLD SHUTDOWN within the following 30 hours. Acw D -- __D. With an air lock inoperable due t an inoperable door gas t: '

1. Mal ain the remaining soor f the affected air loc closed Acrt** /1 an sealed, and 4, ?, 4,4

 '"     I                    u       9 petnr. the mir inek en praantr status within days er be Acno^s b                              ~(SHUTDOWN within the following 30 hours.in at least HOT STANDBY W 2*AfCAT krM Ahrf.C I ~

2 Kb SURVEILLANCE REQUIREMENTS 3 A4 4.6.1.3 Sf 16.7. l Each containment air lock shall be demonstrated OPERAILE:

a. Ite echopnig,exeplidenth aro i e 'h fo m It'pl et e

                                 ; e f n t t h s I le                 enaat Is s o e e 7 h r b 0 00 2        9.            s t         e b p ec si n lo            as r          en t t        00 s al i p es u ize t n                I     ee

_ c 5 np s r o 1 p19

+{

8y perfoer,,ing containment all' lacN ltANo94 tAft $*3lin In '***N $ with the C* nisin wnf Leskate 11*fa Tis?&& fa, ,,@

r_.._ ,... 7 . . . , .- _. 7 . a . nm - - _ . ... .,. ,n. _N_ DEJ7% CALVERT CLIFFS - UNIT 2 3/4 6-4 Amendment No. 189 l P'? IN ' L;cwu. be h t196 O

                                                                  .fp c o kdm 3.6. L 1NSERT SR 3.6.2.1
     -SR 3.6.2.1     ------------------NOTES------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.5.1.1. ,

Perform quired air loc /l eakage rate / In accordang testi in accordance th the Contai nient with thef'[

Lej age Rate Testi. Program. Containment L kIgeRate h t j stingProgram) f>acf Cof7

Se t.Gu Ms n 3. f.. L 3/4.6 CONTAI E NT $YSTEMS SURVE!LLANCE REQUIREMNTS (Continued) r o t I t a l '1 6R 3.(,1't. @ At least once per$ months by verifying that only one door in each air lock can be opened at a time. l CALVERT CLIFFS - UNIT 2 3/4 6-5 Amendment No. 189 l

                             / its e tt [ g d d / 9 6

\

1 DISCUSSION OF CIIANGES SECTION 3.6.2 o CONTAINMENT AIR LOCKS ADMINISTRATIVE CilANGES I 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, cedain wording preferences or conventions vere adopted which resulted in no techrdcal changes to the Technical Specifications. Additional ' information may also have be.en t.dded to more fully describe each LCO and to be consistent with NUREG 1432. Ilowever, the additional informatior, does not change the intent of the current Technical Specifications. The reformatting, renumbering, and rewording process invo'. es no technical changes to existing Specifications. A.2 Current Technical Specification 3.6.1.3 (Containment Air Locks) requires each containment air lock to be Operable. Improveo Technical Specification 3.6.2 (Containnunt Air Locks) will require two containment air locks to be Operable. This cl. . age specifies the number of air locks by changing "cach" to "two." Calvert Cliffs has two air locks, therefore, specifying the number of containment air locks in the LCO constitutes an administrative change. This change is consistent with NUREG 1432. A.3 Improved Technical Specification 3.6.2 will add an Actions Note (Note 2) which llows separate Condition entry for each air lock Current Techn! cal Specification 3.6.1.3 Actions do not contain th's requirement. This Note provides explicit instructions for proper application of the Actions for Technical Specification compliance, in conjunction with proposed Specification 1.3 " Completion Times," this Note provides direction consistent with the intent of the i;xisting Actions for the containment air locks. This change is consistent with NUREG 1432. A.4 Improved Technical Specification 3.6.2 will add an Actions Note (Note 3) which requires entry into the applicable Conditions and Required Actions of LCO 3.6.1 when the containment is inoperable due to exceeding the overall containment leakage rate acceptance criteria Current Technical Specification 3.6.1.3 does not contain this Note. This Note is essentially a reminder that noncompliance with the overall leakage limits requires entry into the ITS Containment Specification (the CTS Containment Leakage Specification), llow wer, ITS, as well as CTS, requires entry into Actions for any Specification in which the LCO is not met. Tlie addition of informational Notes constitutes an administrative change. ~!his change is consistent with NUREG 1432. A.5 Current Technical Specification SR 4.6.1.3.a requires each containment air lock to is i demonstrated OPERABLE by performance of containment air lock leakage rate testing in accordance with the Containment Leakage Rate Testing Program. Improved Technical Specification SR 3.6.2.1 contains the same requirement; however, it is modified by two notes. These Notes state: 1) An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test; and 2) Rcaults shall be evaluated against acceptance criteria applicable to SR 3.6.1.1. These Notes have been added to the CTS. Notes I and 2 to ITS SR 3.6.2.1 are consistent with current practices. One air lock door is capable of providing a fission product barrier in the event; thus, Calvert Cliffs would not invalidate the previous successful performance of the overall air lock leakage test in the CALVERT CLIFFS - UNITS 1 & 2 3.6.2- 1 Revision 7

DISCUSSION OF CilANGES SECTION 3.62 - CONTAINMENT AIR LOCKS event a single air lock door was inoperable. Additionally, the results of the air lock leakage test are accounted for in determining the combined Type B and C containment leakage rate. The addition of these Notes is administrative, because it does not change the intent of the CTS. TECIINICAL CIIANGES - MORE HERTRICTlYE

M.1 turrent Technical Speci0 cation 3.6.13 Action a requires the air lock to be restored to Operable status within 24 hours when an air lock is inoperable, except when the air lock is inoperable as a result of an inoperable door gasket. Improved Technical Specification 3.6.2 Action C is for air lock inoperabilities other than an inoperable air Jock door and the interlock .nechanism. This Action requires action to be immediately initiated to evaluate ' overall containment leakage rate, verification a door is closed in the affected air lock within I hour, and restoration of the air lock to Operable status within 24 hours. This c}'~u;e adds two additional requirements when the air lock is incperable for reasons other than for an inoperable door and interlock mechanisn . The Action to evaluate the overall containment leakage will determine if the containme:.t is Operable. If it is determined the overall containment leakage exceeds the required limits, then the Actions of LCO 3.6.1 are entered (one hour to restore). The requirement to maintain t.t least one door closed is consistent with the Actions of LCO 3.6.1, which requires the containment to be restored to Operable status within one hour. Adding additional requirements to the Technical Specifications constitutes a more restrictive change. This change will not impact plant safety because the additional Actions were added to ensure that the containment is Operable. This change is consistent with NUREG-1432. TECIINICAL CllANGES - RELOCATIONS None TECIINICAL CllANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENT!!_ LA.1 Current Technical Specification LCO 3.6.1.3.a requires both doors to be closed except when the air lock is being used for normal transit entry and exit through the containment, then at least one air lock door shall be closed. This requirement is being moved out of Technical Specifications avJ into ITS Bases 3.6.2. This requirement is consistent with the containment air lock interlock mechanism which prevents both doors from being open at one time. The containment air lock interlock is required to be Operable consistent with this requirement in the CTS. The requirement that only one door be opened at a time in the containment air lock will still be ensured, although this information is being moved to the Bases. Informational details such as this are consistently being moved to the Bases as part of the conversion to NUREG-1432. Any changes to this information in the Bases will be consistent with the requirements of the Bases Control Program of Section 5.0. The Bases Control Program will ensure that changes to these requirements will be appropriately reviewed. The level of safety of facility operation is unaffected by the change because there is no change in the requirement to maintain the containment air lock interlock Operable, v.hich will prevent both air lock doors from being open. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This change is a CALVERT CLIFFS - UNITS 1 & 2 3.6.2-2 Revision 7 { 1 U

DISCUSSION OF CHANGES SECTION 3.6 2 - CONTAINMENT AIR LOCKS i less restrictive movement of information change with no impact on safety. This change is consistent with NUREG 1432. LA.2 Current Technical Specification LCO 3.6.1.3.a requires an overall air lock leakage rate of s0.05 L., as specified in the Containment Leakage Rate Testing Program, improved Technical Specification 3.6.2 will only require the overall air lock leakage to be in accordance with the Containment Leakage Rate Testing Program. The specific values of s 0.05 L, will not be contained in the ITS. This requirement will be moved to the Containment Leakage Rate Tnting Program. This is acceptable xcause these specific values do not impact the requirement to test the overall air lock leakage to within the requirements in the Containment Leakage Rate Testing Program, which must be in compliance with 10 CFR Part 50, Appendix J, Option B. This detail can be adequately controlled in the Containment Leakage Rate Testing Program, which is controlled via Section 5.0, which contains the requirements for the Containment Leakage Rate Testing Program. 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 to verify that the overall containment air lock leakage is within required limits. Furthermore, NRC and Calvert Cliffs resources associated with processing license 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. TECHNICAL CIIANGES . LESS RESTRICTIVE L.I current Technical Specification 3.6.1.3 Action a requires the air !ock to be restored to Operable status within 24 hours when an air lock is inoperable, except when the air lock is inoperable as a result of an inoperable door gasket. Improved Technical Specification Actions A (one or more air locks with one containment air lock door inoperable) and B (one or more containment air locks with containment air lock interlock mechanism inoperable) will requirt the following Actions:

1. Within I hour verify an Operable door is closed in the affected air lock;

2. Within 24 hours lock the Operable door closed in the affected air lock; and

3. Once per 31 days verify the Operable door is locked closed in the affected air lock (this Action is modified by a Note which allows the air lock doors in high radiation areas to be verified locked closed by administrative means).

This change increases the time to restore an inoperable air lock door to Operable status (when not due to a gasket being inoperable), or return the interlock mechanism to Operable status from 24 hours to no time limit as long as the Operable door is locked closed and vaified closed ~riodically. This change is acceptable because when an Operable air lock door is maintained closed, a leak tight barrier separates containment from the outside atmosphere. This ensures that no radioactive material will be released through the air locks. Relaxing the Completion Time to restore the air lock to Operable status constitutes a less restrictive change. This change is consistent with NUREG-1432. CALVERT CLIFFS - UNITS 1 & 2 3.6.2-3 Revision 7

DISCUSSION OF CIIANGES SECTION 3.6J - CONTAINMENT AIR LOCKS L.2 Currect Technical Specification 3.6.1.3 Action b, when an air lock is inoperable as a result of an inoperable door gasket, requires the Operable door to be maintained locked closed and sealed, and the air lock restored to Operable status within 7 days. Improved Technical Specification Action A will require the following Actions:

1. Within I hour verify an Operable door is closed in the affected air lock:

2. J." thin 24 hours lock the Operable door closed in the affected air lock; and

3. Once per 31 days verify the Operable door is locked closed in the affected air lock (this Action is modified by a Note which allows the air lock doors in high radiation areas to be verified locked closed by administrative means).

This change increases the time to restore an inoperable air lock door to Operable status l (when due to a gasket being inoperable) from seven days to no time limit as long as the l Operable door is locked closed and verified closed periodically. This change is acceptable because when an Operable air lock door is maintained closed, a leak tight barrier separates containment with the outside atmosphere. This ensures that no radioactive material will be released through the air locks. Relaxing the Completion Time to restore the air lock to Operable status constitutes a less restrictive change. This chsnge is consistent with NUREG-1432. L3 Improved Technical Specification 3.6.2 contains an Actions Note (Note 1) which allows entry and exit to perform repairs on the affected air lock components. Current Technical Specification 3.6.1.3 Actbn b does not contain this allowance, although Action b (air lock inoperable due to an inoperable gasket) does contain a requirement to maintain the Operable air lock door in a closed position. This change will allow an exception to the Actions to maintain the Operable door in a closed position by allowing it to be opened to perform repairs or the inoperable gasket, if the outer door is inoperable, then it may be easily necessed for most repairs (the inner door is providing the leak tight barrier). If the inner door is inoperable, it is preferred (as stated in the Bases) that the air lock be accessed from inside containment by entering through the other air lock, if this is not practicable, or if repairs on either door must be performed from the barrel side of the door, then it is permissible to enter the air lock through the Operable door. After each entry and exit, the Operable door must be immediately closed. This is acceptable because of the short time period during which the containment boundary is not intact and the low probability of an event occuring that would pressurize containment during this period. The addition of an allowance which allows entry and exit through an inoperable air lock constitutes a less restrictive change. This change is consistent with NUREG-1432. L.4 Improved Technical Specification 3.6.2 contains a Note (Note 2) in Action A which allows entry and exit into containment for seven days under administrative controls if both air locks are inoperable due to each having r.n inoperable door. Current Technical Specification l 3.6.1.3 Action b does not contain this allowance. The seven day allowance begins when the second air lock is discovered inop-rable. Containment entry may be required to perform Technical Specification SRs and Required Actions, as well as other activities on equipment inside containment that support Technical Specification required equipment. This allowance is acceptable due to the low probability of an event that could pressurize the containment CALVERT CLIFFS - UNITS 1 & 2 3.6.2-4 Revision 7

DISCUSSION OF CllANGES SECTION 3.6.2 - CONTAINMENT AIR LOCKS during the short time that the Operable door is expected to be open. %is change is l consistent with NUREG-1432. L5 Current Technical Specification 4.6.1.3.c requires verification that only one door in each air lock can be opened at a time (interlock mechanism), one; per six months. Improved Technical Specification SR 3.6.2.2 will require this Surveillance to be performed once per 24 months. This change decreases the Frequency for verification of the interlock mechanism from 6 months to 24 months. This test ensures that the interlock, which prevents both air lock doors from being opened at the same time, is Operable. Since closure of either door will suppon containment Operability, normal personnel entry and exit will maintain containment integrity. The 24 month Frequeicy is based on the potential for loss of containment Operability if the SR were to fail when being perfonned with the reactor at power, it also is based on engineering Judgment and is considered adequate given that the interlock is not typically challenged during use of the air locks. Decreasing SR Frequencies constitutes a less restrictive change. This change is consistent with NUREG 1432. l CALVERT CLIFFS - UNITS 1 & 2 3.6.2-5 Revision 7

tp.ch A., s 4.1 3A 4/4,4 CNTAIIDWif SYSTDt1

                                        '3/A.S.4 M .2                              c0NTAllSENT ll0Lafl0N VALVES LIMITIM C0WITIN FOR OPERATION LCo 343           mad Each containment isolation valve shall be SPtaABLE.*

APPLI* ABILITY: M00t$ 1, 2, 3, and 4.

agile niith one or'more of the isolation valve (s) inoperable, either: O eto sne inoperpMr vaivets) EpgrsuABLE statuprrsn "g"" *R%^ LHva[{&^75SLQk$ 5 s$:$/7-i IIsolate each aff ed penetr'stTon wifhin houn by use of at f Ac i. %,'** $8Jt voted automatic valve sec@up in the isolationk(Aey,,ofs3 6 2r@

                      /         .
                                                   -c,

(. Isolate the affected penetration within@ hours by use of at/<merT % w.

                                                          "l east one closed manuel valve or blind flanges or                                                                             ^
                                                                                                                                              #.'4, ' t'4

c, "a M - U $~ G

                                                                                                                                                                ~/
                                                                                                                                                                                ~

t. ("Be in at least NOT STA28Y within the ner,t 6 hours and in COLD '

AcT t 2n D (SWTDOW within the following 30 hours. ~ A

                                                   /.')ie provisions o              pecification 3.            are not applicabl                   vided
                                                                                                                                                         ~

b'

                                                            . hat the affec         enetration i                                                                            d' 8
                                                /~mw ated, h

93n'T" 14c v m 1: /AWJ , SURVEILLANCE REQUIREMENTS - j 4.5.4.y1 Cach containment iso tion valve shall be demonstrated OPERAB prior .o returning the valve service after maintenanc repair, or rep cement work is perfo on the valve or its asso ted actuator, A c rol, or power circuit y performance of a cycling est and verif ation)r i isolation times - ' ' l

                                     ,                                    .< v ,, ,          .,. m n                  -- w                ,

C A A (M o n. : r. . . y a :. p e! ( O

                                                                                                                             ,,e e ,; m ,,a 3 . etc.

s j g c...u.,c w.c u ~ N ~.n. 9_

                                                                      , ,s u. -;. c. o                    em+                .~.~.cio.2 4 m *" "
                                                                                                                                         %N .,---

SR3.631 Valves that are normally closed may be opened on an intemittent s t u,3,3 basis under administrative control. A LA Containment purge isolation valves isolation times will only apply 1

                                                    "^^~ K "- . the valves are reouired to be Opraantr and they are open.
                                                    'jglgtj;r._ti-: '^ r :-- t: 4 ---" ?" 3" 'q^' ';',--                           i

d 'h-

                                                    . ... a 6, a sna 4 per lecnnusi apm . .m..c, C.,, .'.!                                                                   1 wM:5 tin th::: ;;' .a ; .:t iv.,'- :' ::d--                                     '. trig

{J).4} ( CALVERT CLIFFS . UNIT 1 3/4 6 22 Amendment No. 212 N' e ,, bitra tin s I. (, e. ip, ( < . % : . '. ~"f f 4 M /f

                                                                                                                       ==I,CKS p e.r , l46

Spe.ficMoa1.G,3 INSERTS 3.6.3 ACTIONS A.2 and C.2 AND A.2 Note Isolation devices in high radiation areas may be Mby use of gg I u_\ ('derN'ied administrative means. Verify the affected Once per 31 days for isolation penetration flow path is devices outside containment isolated. AND Prior to entering MODE 4 frora MODE 5 if not performed within the previous 92 days for isolation devices inside containment. b hED C.2 Note - Isolation devices in high radiation areas may be icrtGetby use of j administrative means. l{ Verify the affected Once per 31 days penetration flow path is isolated. Pd 7 194

                                                                                                       .SpacSuks.*3.%.3 INSERT 3.6.3 ACTION NOTES 2. 3. & 4 NOTES                                         A

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

g

3. Enter applicable Conditions and Required Actions fer system (s) made inoperable by I containment isolation valves.

                   ~                                                                                               '

res o tal l 1, l Penetru4tni 4}eco pa4Ls n.3 be. unisolated intern'eea&Q s l under o.cl m in is tra.4 s'v e. end rokS .

                                                 ._-     ~

I i P'7 3hb

Spe 4A ~2.f..S I i 3/4.6 CONTAI M ENT SYST W 3/4.6.1

1RIMARY CONTAINMENT g Ducasa y J c.ber, y fh CONTAI MENT INTEGRITY SP d ' b' *' ' b '\ /

                                                                                                                                  *C.M m W                         f LIMITING CONDITION FM OPERATION 3.6.1.1 ' Primary CONTA! MENT INTEGRITY shall be maintained.' '

l S R 3.1,.3. L APPLICABILITY: MOCES 1, 2, 3 and 4. 4 '8" A 6 tens 1 Without primary CONTA! MENT INTEGRITY. restore CONTA!WENT A.t. 4 M 6 hours and in COLD $NUTDOM within the following 30 hours.TV within one hour y, gref e d o n d /.e L .) { SURVEILLANCE REQUIRENENTS 8 "

l h.6.1.1 Primary CONTA!WENT INTEGRITY shall be demonstrated: r. .t..

                                                                          %. "At least once (iiin3h

! ast 3 6.3. not ca able ys by verifying that all pen'etration **, ing clo;ed by OPERABLE containment automatic l [{ : b isolat on _ conditions es and required to be closed during accident Laututic valves closed re securec by in valves, blind "hnnest or ce_setivated) their pos_it ons/except70r valvfi) dministrative contr poermitMd DM

                                    %1
                                      ;j j                               f' D.5fe t       requirements of Specification 3 613 verifying that each containment air lock is in co jI .[n                              ' c.

g g By verifying that the e utpment hatch is atch to entering N00E 4 following a shutdown whe w n closed and sepled. krior i byeconducting a Type B test Uue w. g

                                                                                                                                                     . n t. , t - g                  . 4,.9,a D                                                                   ,.

2A jg4 ' accorrltnea up He C2ated 2 age Aa@fg*p^^- g WMd

Hydro en purge containment vent isolation valves $ k hcontakneent pressure control, tirborne radioactivity for controi.eanc surveillance testing purposes only --

g;g_ Y wnt 9 The shutdown cooling isolation valves may be opened Men the RCS G8AD'M temperature is below 300'F to establish shutdown cooling Exce t valves, blind flanges.(acLgeactivated auG r /1' flow' G are which l i Rt.ptred ocated insideinthe Acm A.7. otherwise secured thecontainment closed position. and are locked. set or be verified closed during each COLD SH These penetratipns shall verification need not be performed more o te axceptthatsuch hen once per 92 days. CALVERT CLIFFS - UNIT 1 3/4 6-1 Amendme t No. 187

                                                                               - nm _ _ ~                    ~        ~        __         _s YaNc3 F*i w vnt. & Huui.1aJed.w        od   bMM          4lA%2f         in    M       tdk%        areu         _

g

                                                                                          ~ _.              _

_~ . n :, . 1

                        / eYt%W. ha tk mr.4 k

Q e e. . F ' 's % es 'E G , g*l 3g -3tt t C M TAllMENT SYSTEMS g, ( , '3 3/4r6T4- CONTAINMENT ISOLATION VALVES LINITING CONDITION F0N OPERATION

                 *3 3.5d.! Each containment isolation valve shall be OPERABLE.* '

APPLICABILITY: MODES 1, 2, 3, and 4. ACTION: With one or more of the isolation valve (s) inoperable, either:

                                                                                                                                                                    ..I
                                      /s. R Q,eMore            Ine poperable hours.__g     r         .. A valyMU to or=== Mtatus W1thif/'] _                                _

m,4 a ,,

        *g M 4                        h fisolate          each affected pen least one deactivatej ation within tic valve secure Mn theTf7t    isolation                pta,g l

A position, or e . t d ,g 4 c - 7 (A C*' C fd

                                                                                                                                                ~
                                      % Isolatetheaffectedpenetrationwithin(dhoursbyuseofa                                                                              .k least one closed manual valve or blind flange or                                             N *N                         A Acyoy                                                                                                              %

O % [Be in at least NOT STANDBY within the next 6 hours and in COLDQ C ASHUTDOWNwithinthefollowing30 hours. ~ rc7111tms of ap

                                         . In

_ at the affected T1 cation 3.0.4 etration is is ted. f not appliefde proviNO Qv

                                                                                                                                                     - LiiI mN'ttu        Acrious o.01r,$ @ ,(

A

                              $URVEILLANCE REQUIREMENTS
                                                                                                                                                                .5          g
      \
                                                                                                                                                'N          [, g.,
        \                    T.6.4.1            Each containment               olation valve shall e demonstrated 0?

prior o returning the val to service after a ntenance, repair. BLE' ' rep cement work 1s perf d on the valve or s associated act or. A 1 control, or power circ Iib [L by performance of cyc11agJ.est_an . efiffrationJ l T isola; ion time, f

                                   .~.                 _         _

C o, 4.. .. ., /V E DOTE. : Oey ocge ..w e 4 . p . 4 , ,.. .. ., f e . . ,. g + t, , @u ~~ w ~~ - - Qm,~ c. w ', a n d . cl. a.o i A p

                                        - ~ -                -

(q-.-.-- a-u-- _- c ucn r : o i ., j . r ., . c p p,, 6 . . ft.- g. . t- .. t . ee c~

                                                                                                ~   e....        . ,         . -

t 5's?. 3.t 3.Z. Valves that tre normally closed may be opened on an intermittent _ (s;t 3,g,,3,3 basis under administrative control. (IDtEfiNnt purge 1 solation valves isolation times will only apply in] V MODE 6 when the valves are required to be OPERABLE and they are open /

1. o . . ~ . a _ . u- - -

                                                                                      -....    -<.a..u-      -'----u-                                       L . ,asa h i5 [ _ h anE [ pe [Iecnnics5~ Q UI-5U EA U E d .l.nIii
                                      -- m o . u.m        m u s vaives must remain 6 m m .-                   _

j' J 7 CALVERT CLIFFS - UNIT 2 3/4 6-18 Amendment No. 189 Sae k . s ..> - aC c%. m

s p ,, , g 7.c.6s .4 o

3. 3. \

                                                                                * ( M

y' q. \ .> l (p l

        / icM be.JM M7                                          7                                                                    "

l LO

Sp f.ed,o* 2.6,3 INSERTS 3.6.3 ACTIONS A.2 and C.2 M A.2 Note l Isolation devices in high radiation areas may be

                 @by use of                                                       fgh administrauve means.

Verify the affected Once per 31 days forisolation penetration flow path is devices outside containment isolated. M Prior to entering MODE 4 from MODE 5 if not performed within the presious 92 days forisolation devices inside containment. b M C.2 - Note .-

   . . .         Isolation devices in.high radiation areas may be jetihedj        @by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated. l

Spec Sd s 3.t. 3 l 1NSERT 3.6.3 ACTION NOTES 2. 3. & 4 { NOTES---

2. Separate Condition entry is allowed for each pmetratbn flow path.

3. Enar applicable Conditions and Required Actions for systends) made inoperable by containment isolation valves.

1 4fter appli ~le Conds and R Act LCO 3 " Con "w leakase uits in ex ira the o I contai t 1+c[. ate v% crite

g k a n; d ea +ive cmMls . 7-P'y 39 %

((. - r 8 . . 4 . . n'% 6 . ~$ 3/4.6 CONTAllMENT $YSTEMS

                 $URVE!LLANCE kt0UIREMENTS (Continued)
                 @durthp'the COLS SNUT00WN or REFUEL 1H MODE at least once per REFU INTERVAL by k,3,q                         9eJJfyina that otLpach' h t'll51 E                                    3ngLA or~

45 test signal each requirp.isala u '

                               'solationposItton.
                               ..__,,_,_.u._._v,_..,___...u.u_m_<

feat g r o-2 9,a0 017. y --- h ,2 l i -- 2; - . 1 ;_:r - w c;c- :_: cx; :: ; ' ; n_ ;;;;q

                                                                                                       . .. < ___              ,,,,,e      '

A

                               "___'__"T""'.I
                                                * 'Y
                                                         "   rzr;I_           ;    " ' " ' " " ' " '
                                                           . . . . . . .. C_ '_ , U. 2.". f-
                                                                                                       ---'-'-'n
                                                                                                                    ,,         A ,. . 4, -

80 {g es 41 sigbh,GirtO**86iTE'RGERII

                                                               . each required tseletion tim-actuates to
                                                                                                                               's LD tion position.

C\ 'r,,(. 1,4 @JQ The isolation time of each power-operated or automatic contal (Jtolation valve shall be detemined to be within its limit when teste T3r_T~eTMisptypee!!JteHon 4.0A m fy3) (T.

                                      ,. e ,
                                                                                                . (( 8 . ,.-- - , P. [. _,

_.~~_ _ _ 4-CALVERT CLIFF $ . UN112 3/4 6 19 Amendment No. 189 l Litcett AM%b 197 b [Y Y8 g

Sg,m.b 3 6 3 r/4.6 3 IDNTAIMENT $YSTEN$

                                                                                                                                 ,p 4 3/4.6.1               PRIMA' RY CONTAIMtNT                         4 (4,g4,h a                 g , g,, , l, 10NTA1 MENT IW1EG11H                         " d**d #

LIMITIIGG CONDZTION FOR OPERATION

                                                                                                        =              _

3.6.1.1 Primary CONTAlmtWT INTt4RITf shall be cafntained.' ' t APPLltABILITY: N0 DES 1. 2, 3 and 4. N I' L t d typ.ieeri Without' primary CONTA! MENT INTEGt!TY. restore CONTA! MENT Aym s 6 hours and in COLD $NIITDOWN within the following 30 hours.ITY w h.t & Csl ' a

                                                                                                                       ,              y jg,.]                                         I s< A,e,e                                     L.4 on . .w.

s $URVE!LLANCE REQUIREMENTS =- - 4.6.1.1 h M S. A. ' Primary CONTAINMENT _INTEG811Y shall_ be SAll demonstrate)J 33 g3L 34'3 3

                                             $       tat least once p not capable sys' y verir          that all penetration **

1 isolation eing close by 0PEk NE containment automatic4 i ves and required to be closed duri tion are closed by valves. blind " lance maid aT c valves securea 'n thm r deact voted Q( % ii. En are open under admin'stram opecuwanan Ann.L B

ve controllargewmeaeroosit'ons'exceptforvalv- - - tfe requirements of Specification 3.6.1.3.verif ing that each containmen g c. odd Byentering to verifying that the MODE 4 felle ipment hatch is closed and sealed, rior j c ., ,[ g ing a shutdown by conducting a Type B test ptQe egnt batch ' vr - - et . _ .Q.y } ky, a .,, a Smenife h by n % LR?.4,Ll e-^7 g :' W q e @'

                                          , Hydro en purge containment vent isolation valves l                                             conta nment pressure control                                                               M 1 for g                                 surveillance testing purposes, on1airborneradioactivittcontrol.gand                                              %

N 7f el M g The shutdown cooling isolation valves may be opened when the RCS temperature is below 300'F to establish shutdown cooling flow, u m he.1,b.3J d Exce t valves blind flanges

A R,4, utre d $, I Afb" O are ocated inside the cont 4In(ment otherwise secured in the *losed position. These penetrat ons shall and or are locked. sealedknd be verified closed during each COLD SH verification need not be performed more o except that such ten then once per g2 days. t i CALVERT# CL!rr$ . UNIT 2_ 3/4 6 1 ndment No. 164

                                      ~ C M rrA -                                                     ,

Wive.5M ha Agn id@ rd;d:m

                  -           m urs..w ec us,~                                                  -
                                                                                                                                                                     ,g. b
                                                         ^#-
                                                           -       - 4^     ^-   e          "~

0 6% M M6%k

                                                                                                                                   $ye. c # ..,. T.G. 3 3/4.6 CMTAllR4 TNT SY$fDis 3/4.6.1                               PRIMARY CONTAINMENT Containment Puree tv11 g MT!ll6C00 SIT 1011F046ptRAT10ll 3.6.1.7                               containment purge supply and exhaust isolation val                              shall be closed by 1                                ting air to the air operator and maintaining air supply valv                                                                                                    solenoid energized.

g APPLICABILITY: 1400t 2. 3 and 4. AM h

ACTION: a. pply and/ one exhaust isolation valve With open. one closesontainmentthe open valvepurg ithi (s ne hour or be in at least NOT STAllDIY within the next 6 hours in COLD $ NUT 90WW within the following 30 hours.; b. With one containment purg upply and/o '

inoperable due to high haust isolation valve kage, repair the Ive(s)within24 hours - or be in COLD $ NUT ithin the following 3 ours.

                              $URVE!LLANCE R                                     REMENTS 4.6.1.7                        e 48 inch containment purge supply and exhaust isolation v                                   es shall                    detemined closed at least once per 31 days. by verifying that powe               o the solenoid valve is removed.

3

f. fha p a , fot A *e J rl*N* A A

                                                                                                                                     )f 1

y ~+ p , Lu. . & l CALVERT CLIFFS . UNIT 2 3/4 6 10 Amendment No. 189 i p h A

l DISCUSSION OF CilANGES ; SECTION 3.6J . CONTAINMENT ISOLATION VAINES l ADMINISTRATIVE CllANGES A.1 The proposed change will refonnat, renumber, and reword the existing Technical Specifications, with no change of intent, to be consistent with NUREG 1432. As a result, the Technical Specifications should be more easily readable and, therefore, understandable

;                                                                       by plant operators, as well as other users.

During the Calvert Cliffs ITS development, certain wording preferences or conventions were l 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 l current Technical Specifications. The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Current Technical Specification 4.6.4.1.2 requires the verification that the containment isolation valves (CIVs) actuate to the isolation position on a Containment isolation Signal (CIS) Channel A or B test signal, and on a Safety injection Actuation Signal Channel A or D test signal. Improved Technical Specifications allow the SR to be performed with a simulated signal or credit to be taken with an actual signal. This change allows credit to be i taken for an actual signal if the CIVs can be verified as having been isolated. The actual signal is as valid as a simulated signal because it places a demand on the valves to isolate.

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

A.3 Current Technical Specification 3.6.4.1 Action a contains a requirement to restore the inoperable valve (s) to Operable status within four hours, or to isolate the affected penetration or to shut down. Improved Technical Specification 3.6.3 will not contain the requirement to restore the valve to Operable status. The op"on to restore the CIV(s) to Operable status, l however, still exists. Once the valve (s) is returned to Operable status, the Actions do not have to be completed, and the LCO can be exited. Therefore, requiring the valve (s) to bc restored is not required in the ITS. Deleting an unnecessary requirement is an administrative change. This change is consistent with NUREG 1432. A.4 Current Technical Speci0 cation 3.6.4.3.e states that the provisions of Specification 3.0.4 are not applicable, provided that the affected penetration is isolated, improved Technical 4 Speci0 cation 3.6.3 will not contain this requirement, improved Technical Specification LCO 3.0.4 states that entry into a Mode or other specified condition in the Applicability shall not be made, except when the associated Actions to be entered pennit continued operation in the Mode or other speci0ed condition in the Applicability for an unlimited period of (!me. Since the ITS 3.6.3 Actions allow continued operation, Mode changes are allowed. Deleting a requirement that exists through the LCO 3.0 requirements constitutes an administrative change. This change is consistent with NUREG 1432. A.5 Improved Technical Specification 3.6.3 will contain an Actions Note (Note 2) which allows separate condition entry for each penetration Dow path. Current Technical Speci0 cation 3.6.4.1 Actions do not contain this requirement. This Note provides explicit instructions for proper application of the actions for Technical Specification compliance, in conjunction with the proposed Speci0 cation 1.3 " Completion Times," this note provides CALVERT CLIFFS UNITS 1 & 2 3.6.31 Revision 7

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

DISCUSSION OF CilANGES

                      ,        ,            SECTION 3.63 . CONTAINMENT ISOLATION VAINES s.

direction consistent with the intent of the existing Actions for the containment isolation valves. His change Is consistent with NUREG 1432. l A.6 Imptoved Technical Specification 3.63 will contain an Actions Note (Note 3) which requires entry into applicable Conditions and Required Actions for system (s) made inoperable by CIVs. Current Technical Specification 3.43.1 does not contain this requirement. This change adds a requirement to declare system (s) inoperable that are made inoperable by , i inoperable CIVs. uls Action was added because, per ITS LCO 3.0.6, only the Actions of l the CIV: would have to be entered, llowever, since inoperable CIVs require isolation of I l penetrations to the affected system (s) with continued operation, cascading to the affected J system is prudent. His requirement is necessary because unlimited continued operation with a system inoperable could severely affect the mitigation of accidents and violate the safety analyses, ne CTS does not contain a Speel0 cation similar to LCO 3.0.6 and, therefore, already requires cascading. The addition of a requirement which is already required in the CTS is an administrative change. This change is consistent with NUREO 1432. A.7 Not used. l A.8 Current Technical Specification 4.6.4.1.3 requires the isolation time of each power. operated or automatic CIV to se determined to be within its limit when tested pursuant to Technical 4 Specification 4.0.5. Improved Technical Specification will require the SR to be performed in accordance with the Inservice Testing Program. His change is administrative because ITS moved CTS 4.0.5 and incorporated it into the Inservice Testing Program, which is required per ITS Section 5.0. He requirement to perform the SR has not changed. This change is consistent with NUREG 1432. A.9 Current Technical Specification 3.6.4.1 does not specifically have different Actions for different types of penetrations, improved Technical Specificat ion 3.6.3 contains Actions for difTerent type penetrations with different numbers of valves inoperable. Improved Technical Specification 3.63 Actions A and B will contain a Conditions Note which specifies that these Conditions only apply to penetration flow paths with two CIVs and not e closed system, improved Technical Specification 3.63 Action C will contain a Conditions Note which specifies that this Condition only applies to penetration flow paths with one or more CIVs and a closed system. Adding Notes which specify which Actions are applicable is an administrative change because the requirement is not affected technically, i A.10 Unit 1 CTS 3.6.l.7 Action a requires an open containment purge supply and exhaust isolation valve to be closed, improved Technical Specification 3.6J will require an j inoperable containment purge supply and exhaust isolation valve to be closed. The ITS l combines all containment isolation valves into one specification and does not specifically , contain Actions for the containment purge system valves. Herefore, the ITS Actions require the valves to be closed when the valve is inoperable. The bases will require the containment purge r.ipply and exhaust isolation valves to be closed as a part of their Operability

   ;                                requirements. Therefore, changing closed to inoperable in the Actions is an administrative change. This change is specific to Unit I because the Unit 2 containment purge and exhaust isolation valves located outside containment are being replaced with blind fianges for operation in Modes I through 4. The Unit I containment purge and exhaust penetrations will also be modified to have blind fianges installed during the 1998 Unit I refueling outage.

CALVERT CLIFFS UNITS 1 & 2 3.63 2 Revision 7

DISCUSSION OF CHANGES SECTION 3.6.3 . CONTAINMENT ISOLATION VALVES Herefore, this change will become moot after install lon of the blind flange because the containment purge system speelucation in Modes I through 4 will not longer be applicable. His change is consistent with NUREG.1432. A.ll Unit I CTS SR 4.6.4.1.2.b requires verifying that on each Containment Radiation. liigh Test Channel A or Channel D test signal, both required contahment purge valves actuate to their isolation position. improved Technical Specification 3.6.3 SRs will not contain this Surveillance. Current Technical Specification SR 4.9.9 and ITS SR 3.9.3.2 also require verifying the containment purge valves actuate on a Containment Radiation liigh Test signal. Therefore, deleting an SR which is duplicated in another Specification constitutes an administrative change. This change is consistent with NUREG 1432. TECHNICAL CilANGES MORE M5NTRICTIVE M.1 Current Technical Speel0 cation 3.6.4.1 Actions require the penetretions to be isolated within four hours if two CIVs are inoperable improved Technical Specification 3.6.3 Action D will require the p; nctration to be isolated within one hour. This change decreases the Completion Time to isolate a penetration, when two CIVs in the penetration are inoperable, from four hours to one hour, With both CIVs in one penetration inoperable, the means to isolate containment is hindered. He one hour Completion Time is consistent with the urgency to isolate containment, and is also consistent with the Actions of LCO 3.6.1, in addition, the alTected penetration flow path must be isolated with an isolation barrier that cannot be adversely affected by a single acGve failure (closed and deactivated automatic valve, a closed manual valve, or a blind Dange). Decreasing the Completion Time to complete an Action constitutes a More Restrictive change. His change will not adversely alTect safety because when two CIVs are inoperable, the ability to isolate the penetration is hindered, and rapid isolation is warranted. This change is consistent with NUREG 1432. M.2 Improved Technical Specification 3.6.3 Required Actions A.2 and C.2 contain requirements to verify that the affected penetration now path is isolated once per 31 days for isolation devices outside containment, and Action A.2 contains an additional Completion Time to verify the affected penetration flow path is isolated prior to entering Mode 4 from Mode 5, if not performed within the previous 92 days for isolation devices inside containment. The added Required Actions are modified oy a Note which allows the isolation devices in high radiation areas to be veri 0ed by use of administl.4tive means. Current Technical Specification 3.6.4.1 does not contain these requirements. His change will add requirements to Technical Specifications to periodically verify that the afTected penetration flow path is isolated. This verification is necessary to ensure that containment penetrations required to be isolated following an accident, and no longer capable of being automatically isolated, will be in the isolation position should an event occur. The addition of requirements to the Technical Specifications constitutes a more restrictive change. This change will not adversely affect safety because it ensures that the isolated penetrations remain isolated. His change is consistent with NUREG 1432. M.3 Current Technical Speci0 cation 3.6.1.1 Footnote ' allows the hydrogen purge containment vent isolation valves to be opened for containment pressure control, airborne radioactivity control and Surveillance testing purposes only, improved Technical Specification 3.6.3 creates an SR (SR 3.6.3.1) from this allowance. The ITS SR will require the veri 0 cation that the containment vent is only opened for the above listed purposes (and air quality CALVERT CLIFFS UNITS I & 2 3.6.33 Revision 7

DISCUSSION OF CilANGES SECTION 3.6.3 . CONTAINMENT ISOLATION VALVES considerations as described in a less restrictive Discussion of Changes) once per 31 days. His SR ensures that the containment vent valves are closed as required or, if open, open for an allowable reason. He 31 day Frequency is consistent with other CIV requirements. Adding an SR to verify an allowance constitutes a more restrictive change. The addition of this SR is not adverse to plant safety because it ensures that this CIV is only opened for approved purposes. His change is consistent with NUREG 1432. TECilNICAL CilANGES - ILELOCATIONS None TECilNICAL CilANGES . MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED DOCUMENTS LA.! Current Technical Specification SRs 4.6.4.1.2.a and c specifically list the types of test signals (CIS Channel A or 8, and Safety injection Actuation Signal Channel A or D) required for testing that the CIVs actuate to their isolation position, improved Technical Specification SR 3.6.3.5 will require that the CIVs be verified to isolate on an actual or simulated test signal. The test signal will no longer be specified in the SR. The test signal will be moved to Section B ?.6.3 of the ITS Bases. This is acceptable because these details do not impact the requirement to verify that the CIVs will isolate when required %ese details can be adequately controlled in the Bases which require change control in accordance with the Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. 1 Safety is unaffected by the change because there is no change in the requirement for the CIVs to isolate. Furthermore, NRC and Calvert Cliffs resources associated with processmg license amendments to these requirements will be reduced. This is a less restrictive movem.nt ofinformation change with no impact on safety. His change is consistent with NUREG 1432. l i LA.2 Not used. l LA.3 Unit 1 CTS LCO 3.6.1.7 requires the containment purge supply and exhaust isolation valves shall be closed by isolating air to the air operator and maintaining the solenoid air supply j valve de-energized and SR 4.6.1,7 requires verification that power to the solenoid is removed, nese requirements are being moved to the Bases of Section 3.6.3, This is acceptable because moving these requirements to the Bases will not afTect the requirement to maintain the valves closed and how to maintain the valve closed. He valves are required to be maintained Operable per Section 3.6.3 but that section does not specifically require them to be maintained closed. The Bases will require the containment purge and isolation valves to be closed in order to be Operable. The SR that requires the valves to be maintained closed will remain in the Technical Specifications; only the requirement on how tu maintain the valve closed is being removed, nese requirements can be 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. The level of safety of facility operation is unaffected by the change because the requirements are still in place to ensure the valves are closed and maintained closed. Furthermore, NRC and Calvert Cliffs Nuclear Power Plant (CCNPP) resources associated with processing license amendments to these requirements CALVERT CLIFFS - UNITS I & 2 3.6.3-4 Revision 7

       -           __               - . _ . _ - ,         . . . . . . . . . , . , , ,           .-.         . . . _ _ _ ,-. ,.mm.             _ . _ . _ .

DISCUSSION OF CHANGES SECTION 3;6.3 CONTAINMENT ISOLATION VALVES will be reduced. This change is specific to Unit i because the Unit 2 containment purge and exhaust isolation valves located outside containment are being replaced with blind flanges for operation in Modes 1 through 4. He Unit I containment purge and exhaust penetrations l will also be modified to have blind Danges installed during the 1998 Unit I refueling outage, nerefore, these requirements in the Bases will no longer be applicable afler installation of the blind Dange because the containment purge system specification will no longer be applicable. This change is a lest restrictive movement ofinformation change with no impact l on safety. This change is consistent with NUREG 1432. l LA.4 Unit i CTS SR 4.6.4.1.1 footnote # allows isolation times for containment purge isolation j valves to not be applicable for Modes 1,2,3, and 4 per the containment isolation valve Technical Specification, during which time these valves must remain closed. This requirement is being moved to the 11ases of Section 3.6.3. This is acceptable because moving this requirement to the Bases will not affect this allowance. His requirement can be adequately controlled in the Bases which require change control in accordance with the l Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because this allowance will be unchanged. Furthermore, NRC and CCNPP resources associated with processing license amendments to these requirements will be reduced. This change is specific to Unit i because the Unit 2 containment purge and exhaust isolation valves located outside containment are being replaced with blind 11anges for operation in Modes 1 through 4. The Unit I containment purge and exhaust penetrations will 2!so be modified to have blind fianges installed during the 1998 Unit I refueling outage. Therefore, this portion of the footnote will no longer be applicable aller installation of the blind Dange because the containment purge system specification will no longer be applicable, nis change is a less restrictive movement of information change with no impact on safety. This change is consistent with NUREG 1432. TECilNICAL CIIANGES . LESS RESTRICTlyE L.I Current Technical Specification 3.6.4.1 Actions b and c require that a penetration with one or more inoperable CIVs be isolated with one deactivated automatic valve secured in the isolation position, or by use of at least one closed manual valve or blind Dange. Improved Technical Specifications 3.6.3 Action A (when only one CIV is inoperable) will additionally allow the penetration to be isolated by a check valve with flow through the valve secured. This change adds an additional method for isolating a penetration when one CIV is inoperable. One CIV for the affected penetration is still Operable. This valve, combined with the check valve with now through the valve secured, is as effective in isolating the penetration as a secured automatic valve, a closed manual valve, or a blind flange. Therefore, the check valve with Cow through the valve secured will perform the intended safety function ofisolating the penetration. Adding methods to the Technical Specifications on how to isolate a penetrations constitutes a less restrictive change. His change is consistent with NUREG 1432. L.2 Current Technical Specification 3.6.4.1 Actions b and c require the penetration now path to be isolated within four hours when the CIV is inoperable. These Actions can be applied to penetration How paths in a closed system. Penetration flow paths in closed systems are only required to have one CIV improved Technical Specification 3.6.3 Action C will require the CALVERT CLIFFS . UNITS 1 & 2 3.6.35 Revision 7

DISCUSSION OF CHANGES SECTION 3.6.3 . CONTAINMENT ISOLATION VALVES penetration to be isolated within 72 hours when the CIV is inoperable in a penetration with a closed system. The penetration is seguired to be isolated with a closed and deactivated automatic valve, a closed manual valve, or a blind fiange. His change will increase the Completion Time for this Action from 4 hours to 72 hours. This time is reasonable, considering the reliability of the closed system to act as a penetration isolation boundary. He closed system will perform the safety function nfisolating the penetration until the valve is isolated. Increasing the Completion Time to complete the Actions constitutes a less restrictive change. His change is consistent with NUREG 1432, TSTF.30. L.3 Not used. l L.4 Current Technical Speel0 cation 4.6.1.1.a and Footnote " to CTS 4.6.l.l.a require all penetrations required to be closed during accident conditions, which are not capable of being closed by OPERABLE containment automatic isolation valves, be verified closed by valves, blind fianges, or deactivated automatic valves. Improved Technical Specincation SRs 3.6.3.2 and 3.6.3.3 also require verification that the containment isolation manual valves and blind flanges that are required to be closed during accident conditions are closed; however, the ITS SRs do not require containment isolation msnual valves and blind flanges that are locked, sealed, or otherwise secured to be verified closed. Current Technical Specification 4.6.1.1.a and Footnote " to CTS 4.6.1.1.a have been changed to include the exception regarding manual valves and blind fianges that are locked, scaled, or otherwise secured. This proposed change is acceptable, because containment isolation manual valves and blind Danges that are locked, scaled, or otherwise secured in position are verified to be isolated prior to locking, scaling, or securing. After locking, scaling, or securing, it would take an intentional act to remove the lock, seal, or securing device prior to opening the valve or blind fiange. Administrative controls are provided to assure that manual valves and blind fianges which are locked, sealed, or secured closed are not inadvertently opened. Additionally, this proposed change is consistent with the requirements of a number of CTS SRs (e.g., 4.5.2.b.1, 4.7.1.2.a.4, 4.7.3.1.a, 4.7.4.1.a. and 4.7.5.1.a) which do not require the position of valves that are locked, scaled, or otherwise secured in position to be verified. L.5 Current Technical Specification 3.6.1.1 footnote

requires the containment vent to be opened only for containment pressure control, airborne radioactivity control, and Surveillance testing purposes, improved Technical Specification SR 3.6.3.1 requires the verification once per 31 days that the containment vent is closed, except for containment pressure control, airborne radioactivity control, air quality control, and Surveillance testing purposes. This change essentially adds an allowance for the containment vent to be opened for air quality control purposes. His is reasonable because containment air quality in containment is critical for personnel entry. Also, the containment vent is capable of closing in the environment following a loss of coolant accident. Adding an additional allowance for the containment vent to be opened constitutes a less restrictive change. This change is consistent with NUREG 1432.

L.6 Not used. l L.7 Current Technical Specification SR 4.6.1.1.a requires all penetrations (inside and outside of containment) not capable of being closed by Operable CIVs, and are required to be closed during accident conditions, to be verified closed. Improved Technical Specification SR 3.6.3.2 (outside containment) and SR 3.6.3.3 (inside containment) will require the CALVERT CLIFFS UNITS 1 & 2 3.6.36 Revision 7

1)lSCUSSION OF CilANGES SECTION 3.6J o CONTAINMENT ISOLATION VALVES _ penetration to be verified closed; however, the ITS will contain a Note which allows valves and blind Danges in high radia:lon areas to be verified by administrative means. This Note is i acceptable since access to these areas is typically restricted for as low as reasonably achievable radiation exposure reasons. Also, since these areas are restricted, the chances of these isolation devices being misaligned once they have been verilled to be in the proper l position is small. This change is consistent with NUREO.1432. L.8 Unit I CTS 3.6.1.7 Action a requires the containment purge supply and exhaust isolation valves to be closed within one hour if any of the valves are open. Improved Technical Specification 3.63 requires the containment purge supply and exhaust isolation valves to be closed within four hours if any of the valves are open. %Is change will increase the Completion Time to close the valves from one hour to four hours. His change is acceptable because the chcnces are remote that the valves will be leR in the open position or opened in Modes 1 through 4. The valves are required to be maintained closed with power to the solenoid valve removed prior to Mode 4 per ITS SR 3.6.3.2 and the associated Bases. The valves also receive automatic closure signals during accidents (containment isolation, safety injection, and high radiation signals). Also, this change is specific to Unit i because the Unit 2 containment purge and exhaust isolation valves located outside containment have been replaced with blind flanges for operation in Modes I through 4. The Unit I containment purge and exhaust penetrations will also be modilled to have blind flanges installed during the 1998 Unit I refueling outage. Therefore, this Action will no longer be applicable aRer installation of the blind flanges because the containment purge system specification will no longer be applicable in Modes 1 through 4. Increasing Completion Times to perfonn an Action constitutes a less restrictive change. This change is consistent with NUREG 1432. L.9 Unit I CTS 3.6.1.7 Action b requires containment purge supply and exhaust isolation valves to be repaired within 24 hours when inoperable due to high leakage, improved Technical Specification 3.6.3 will require the valve to be maintained closed. In both cases the containment leakage requirements are required to be maintained. He ITS w!Il allow containment purge supply and exhaust valve leakage to exist indefinitely as long as the containment leakage requirements are within limits whereas the CTS requires the valve to be repaired within 24 hours as long as the containment leakage requirements are within limits. This change is acceptable, because other Technical Specifications exist that control Containment Leakage. If the containment leakage is not within limits Actions of the appropriate Technical Specification LCO is required to be entered (LCO 3.6.1 which requires an allowed outage time of one hour before requiring a plant shutdown), liowever, good operating practices and engineering judgment dictate performing repairs to conect leal's before they become excessive; This change is specific to Unit i because the Unit 2 containment purge and exhaust isolation valves located outside containment have been replaced with blind flanges for operation in Modes 1 through 4. The Unit I containment purge and exhaust penetrations will also be modified to have blind flanges installed during the 1998 Unit I refueling outage. Therefore, these changes will no longer be applicable aRer , installation of the blind flanges because the containment purge system specificatior, uill no I longer be applicable in Modes I through 4. Deleting a requirement to perform Actions l within a certain amount of time constitutes a less restrictive change. This change is , consistent with NUREG 1432. ' L.10 Current Technical Specification SR 4.6.4.1.1 requires each containment isolation valve to be demonstrated OPERABLE prior to returning the valve to service aRer maintenance, repair, CALVERT CLIFFS UNITS 1 & 2 3.6.37 Revision 7

DISCUSSION OF CHANGES SICCTION 3.6.3 . CONTAINMENT ISOLATION VALVES or replacement work is perfonned on the valve or its associated actuator, control, or power circuit, improved Technical Speci0 cation 3.6.3 will not contain this SR Current Technical i Specification 4.6.4.1.1 is being deleted. Any time the OPERAlllLITY of a system or ! component has been affected by repair, maintenance, or replacement of a component, post l maintenance testing is required to demonstrate OPERABILITY of the system or component. i After restoration of a component that caused a required SR to be failed, ITS SR 3.0.1 requires the appropriate SR (i.e., ITS SR 3.6.3.4) to be performed to demonstrate OPERABILITY of the afTected components. Therefore, explicit post maintenance Surveillance Requirements (i.e., CTS SR 4.6.4.1.1) are not required and are not included in the Calvert Cliffs ITS. L.l l Current Technical Specification LCO 3.6.4.1 is modified by Footnote

which states:

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

Footnote

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

Intermittently opening CIVs which are isolated in accordance with an action requirement is acceptable due to the low probability of an event that could pressurize the containment during the short time in which the penetration flow path is open and the administrative controls established to ensure the affected pen:tration can be isolated when a need for containment isolation is indicated. CALVERT CLIFFS UNITS 1 & 2 3,6.38 Revision 7

DISCUSSION OF CilANGES SECTION 3.6.5 CONTAINh1ENT AIR TEh1PERATURE AILi1[MISTRATIVE CilANGES A.I 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 i by plant oprators, as well as other users. During the Cahat 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. llowever, the additional infonnation does not change the intent of the current Technical Specifications, ne reformatting, renumbering, and rewording process involves no technical changes to existing 3pecifications. TECllNICAL CilANGES - MORE RESTRICTIVE None. TECliNICAL CllANGES - RELOCATIONS None TECilNICAL CilANGES - hiOVEh1ENT OF INFORh1ATION TO LICENSEE CONTROLLED DOCUMENTS LA.1 Current Technical Specification 4.6.1.5 requires the containment average air temperature to be the arithmetical average of the temperature at the containment dome and the containment reactor cavity. Improved Technical Specification SR 3.6.5.1 will only include the requirements for the primary containment average air temperature to be determined. %e ITS will not include the specifics on how to perfonn the SR (the arithmetical average of the temperatures). This information will be moved to Section B 3.6.5 of the ITS Bases. This is acceptable because these details do not impact the requirement to verify the containment average air temperature. Rese details can be adequately controlled in the Bases which require change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requiremeni to verify the containment average air temperature. Furthermore, NRC and Calvert Cliffs resources associeted with processing license amendments to these requirements will be reduced. His is a less restrictive movement ofinformation change with no impact on safety. This change is consistent with NUREG 1432. LA.2 Current Technical Specification SR 4.6.1.5 requires the containment average air temperature to be the arithmetical average of the temperature at the containment dome and the containment reactor cavity, improved Technical Specification SR 3.6.5.1 will only include the requirements for the primary containment average air temperature to be determined. He ITS will not include the specifi: location of temperature indication (containment dome and containment reactor cavity). This information will be moved to the Bases for ITS SR 3.6.5.1. His is acceptable because these details do not impact the requirement to verify CALVERT CLIFFS - UNITS 1 & 2 3.6.5 1 Revision 7

I)lSCUSSION OF CilANGES SECTION 3 6,5. CONTAINMENT AIR TEMPERATURE a the containment average air temperature. 'these details can be adequately controlled in the 11ases which require change control in accordance with the liases Control program in ITS i Section 5.0. This approach provides an effecthe level of 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 to verify the containment average air temperaturc Furthennore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This is a less restrictive movement of infonnation change with no impact on safety. This change is consistent with NUREG 1432. TECllNICAL CilANGES . I.ESS RFMTRICTIVE None CALVERT CLIFFS UNITS 1 & 2 3.6.52 Revision 7

S p .Ct. L 3.C.,f. 34 4/4:4 CONTAllpitNT SYSTDi$ 4/442 [DEPM11URIEATIONIANDCOOLINGSYSTEMS thinnent int LIMITINGCONDIT10NFhDPERATION 'd 5 * * " Acu g,g f S f;til Two inderenitenL Containment hprarptwa ]shall be OPtulLEprHh3 . erstem capso~ e er un i mon.Ar,dationStenalandsafet njection l $ pray

                                                                                                             .vmon irve         uns nilignal Actuation       en aan @l inment autF*etally transferring suc on to the coettinment sump on                                                               44.

Rec.1:stion Actuation Sign . Each s u pd innent suma shall he v an_epraan g hay sy h n elinostem flow path rom the antexchanner.) APPL 1tAllLITY: N00t$ 1, 2. and 3*. p.A i dev i N Am A - With one Contat.nent Spray System inoperable, restitre the 4.n .. .,3 .# r. u M.4

                                                          , noperable spray system to OrtnAllt status within 7                                             h =wAy          Sen h rarer ne in s Ae w 8                   NOT STANDlY within the next 6 hours and in within @

inusa hours. g y; ,, y f g p -

                                                                                                                                                                                               'g wwxsn.c SURYt!LLANTugvsununa                 ~~

g

                                                              ' Od ch Containmen       ptsy $ystem s b) be demo                                                                   '

ted OPERABLE: At les o r 31 days

                                                                                                                                          . og(~ /o 4                                      >
                                                                       % Ver ying that upon Bac']rculan                            ct m ot Test $ nal, L f                     t con 41nment i

_rp ation mo f low 150151 M vaMres- sna Q M.:/ vir an Urt ta[n -shut vn n

                                                       -                      eaV.=rka
                                                                                     - /

r- = .t ;ab had J' fr,,+

                                                                                                                   /^
                                                                        . Verifyin        t each ralve sianual power ops ted, or 1t r' ' .o.,, "*"
                                                                                                                                                                                   . et automati       n the f1 )w pa that Is not lo' ed, sealed or ether ris secured in post ton es na= t unam mi.                                          g                       k /,

N.muiE mr' ; - --" =__ o,1 4 dsigna . t ,

                                                                  %     G i s sp; b-
                                                       /                            ~e n s e the                                    /           --

[a4/4t'N'*O q' ; n. e 4. , ng shutdowh, by [ Verifying that ch automatic v i to its correc positionen us alw nriare in the flow pat actuates . m. 4d i - u o1 ,m _)(o gigna) , j r

                                                                  / k V_erifying i at each spray p

[ <- test sig starts automatio(11y on @ ' f - L( t..r, / ww.se nmg\ j 1. %_ _ M + A V @ g g _ L a., b'*b'I' / * -- With pressurizer pressure t 1750 psta. cal, VERT CLIFr$ . UNIT 1 f D5M 2 I2 3/4 6 15 Amendment No. 212 l Lit <<u. An.LA 218 If b k

                                                                                        "g t Cit 4*o 'J ,4, 4 INSER115N@,6,6,4 l

[ i i ' Swve611ance Freauency SR 3. , W Wj " : ' --

                                           --T.y nuu tope     and a     tic 31Ais val        the flow                    , sealed, tion is a not tion.

ruise red / correct _

SR 3.6.6.4 WJ containment i spray pwnps developed head at the flow test goint in accordance with is greater than or equal to the required developed head. the Innervios TeMing Program 4 p y 2.c 4 g

c p.f .Me 3.4.6 l l 3/4.6 teNfatteeff systDtl SURVf!Limctaggp3RENENT8(Continued) let !aad(ince perMearsl6mEfb na wbrm, - nMg' D W Wrut,es. $l LEV 5 Pry / httw4h6 r fy hp teC rey hettle 'S . u M I

                                                                                               /                                                                 \
                                                                                           /                /                     /

I Lla nc. u.aa h st8 I l l l ! CAlytRT Cllffs . UNIT 1 3/4616 Amendment No. 212 l Licsw A+) d 2.18 /uje J / lo l

l

                                                                                     $m.6 cch 3. 6. i.

NS h b.l . I.O ihfoujh SC 9.4.t.l.d , as aPProveJ O UEsi I 'h L2%c OmtMi*d No. 216 4.6.2.1 Lach Containment Spray System shall be demonstrated OPERABLE: r.a At least once per 31 days by: g 1.Mel Gn h <*en* ra@ 1. Verifying that each valve (manual, power operated, or automatic (

                 ;               otherwise)  ohtdsecured t(in theinflow10sition path isJpgsi';'

that is n%uct locket, sealed or ( (from The INT oAa coyatnmentVresshre HiBh te\take sT sian , Vn

                        . Aileas once per'92 days by:                                                  b'I
                             . Verify that upo   a Recircul isolation ' tion Actua ion Test S nal, the cont nment   sump recirculat on mode f1                    Ives o>en nd that a path via n OPF(ABL shutdown ooling )

eat exchan r is esta ished. ~

                                                                                                    )            '

c. At least once per REFUELING INTERVAL. durina shutdown. by:

SA3.t.w.T s o .. r,.+ ieo.4.se.iu ,.c.wi...u m e.a in co w g 4 1.

                      -         Verifying that each automatic valve in the flow pathtactuates to its correct position on @e vpropriatKE5FAS tqsy signal.                '

gg 3 , u .g 2 Verifying thit each saray pump starts automatically on the (rppemorhete :5Ms tem ignal. Q to an ar wal of 56 a l a

M it 3.i..i.8 [d. At least once per L.5

( unrouan yearsAFy per(6ihng anIir orboke vacn wpray readeNandfverifying eF.h spray noHl,e owy'esg unobstructea. r License Me&cu r 2'$

SpoCM 5.4.6

3. (, 4/4,4- CelffAlleGT SY11Di$

3 4M M *"" ^* "" 5"$ l _ tninoe Cooli Srstam L741T1104 CONDIT!011 fet OPERAT!0ll Lc.o 3,y,y Sr6 text _Twou '--'%wn oIontainment air ereursueK~EED coolingautru. fha 11 be prERABJ F InRO un' tsYeach app 0pl ABILITY: MODES 1, 2 and 3

quired containment Er_ A"*30 %w31th cooli inoperable and both Containment pray ens

                                                                                                                                                                              /t.2.

OPE E, restore the inoperable group of air racirru ation and J g**" / 6 --@ cooling units towijhi T $Nartefam OPERABLE IQurs, g- status ( n at least within 7 daysfor be ' Qt_).n c < . ,. n .t. I 4 ***# g K, With three're W F46't B noe aime rcum en cooling units inoperable and both Co ate: ment $ pray Systees OPERABLE. ,a A c r ma E restore at least one renuir _~ -en-9"amQ?Q coolin un to OPERA 8LE status within@ hours or be in at least, W CN TD06M - T]s-- I(within 12 hours. containment si rec Oth above required group T on and 1001 units to OP :llABLt Ac,u c { p _.T ._L status within days or be in at least TsnumMNwthinIqj g A tr% g - (hours. g,- - A With one group of required containment alFrectreulation and

                                                          /%,       g                      cooling units inoperable and one Containment 5p ay System inoperable, restore the inoperable Contajnsent
                                                          %" E            - Q OPERABLE status within 72 hours or be in at leastpraySystemto[,           SNUTMMM f' "'"' C-within 17. hours. Restore the inoperable group of              inment air I recirculation and cooling units to orERABLE status within 7 days lu m > G                      wof initial loss or be in at least NOT      SNUTD0V:3 within 12 hours.;

4 SURVE!LLANCE REQUIREMillis 4.6.2.2 Each containment air recirculation ti.d cooling unit shall be demonstrated OPERABLE: A At least once per 31 days @nMTAGGERED JHT SAnt by: K [$tgrtlng eachynit from the cptfoi roomd CALVERT CLIFFS . UNIT 1 3/4 6 17 Amendment No. 212 l m F', G coda ^~N 4t*f f. der t eo h.., twun . .r. o..s f +.,J.,4 } 6A A

                                                                     ,,%,Ji, +k .*f.c~'?fc
                                                                                  ~ .-           -

pys Q lo i

                                                                                                                            .C(ne de des 3. (.. b 3/4.6 20EIAIBILiff itSIDG
                                                            $418YtILtANCE Etel'%EMEtril (fontinued) 1R %.6 4,'4 l                \ Verifying f 4*t each unit operates for at least 15 minutes.
                                                    'b'b'3            x verif,is e         un:1.aie, n _   ,aie or i = ,,11each he TWII TIM BEmEg wasyr svTif'.' Valv5D-
                                                                            . _.       LLV                                -                       *

b. At itet crc par RENELING INTERVAL by i f ing that each unit 5 A 24 c,. *l starts autreatically on the 2;;rgriet test sibe;1. F

                                                                                             %&&3                                              g 3/4 6 18 CALVERT CLIFFS . US.!T 1                               Ame Meent No. 212     l P"P b      b

OpciOthon "i!..f..fo ,

3. fe Q CONTAINMENT $75TEMS

                                    '3, r., g           @                       iitamiwuwl0 LAND COOLING SYSTEMS (Containment sora}g                                                                                                                                 ,

LIMITING CONDITION FOR OPERATION f[rS/2 d he dibb.iel (c p y,g,6 @ Twf,' independent Containment fun spra system C6papis UT Isti ra)/stma shallbeOPERABLEJGTS v65ivu o vm snu Kul vn s i,9 ETnment Spray At stion $lgnal and Safety action Actuation $tgnal a p automa cally transferring sucti to the contat'iment sump cn ( t.A Recir lation Actuttion $lgnal. to inment sumo iria11 he via n DPraakPr thutdown coolinaEach rom the I s ray system flow pat eat errkannar.J

                                                                                                                                                                                                                          '4 APPLICABILITY: MODE $ 1, 2, and 3*.                                                                                         _ _ _ _ __[6M d'E I0 ck)f f.k elos ese Ac.r,, A              ($1103:ble                      spray system to OPERABLE status within 72 hours %r be i
                                                       \inopera g, g            ._.[least NOT STANDBY within the next 6 hours and in y_o yowint 33 hours.                                                                                                  within @

Q gg j .3 ('TNs5Det .3._Co.(..h]

                                                         $URVEILLANCE REQUIRIM m 3
                                                                                                                  -~
                                                                                                                                                                                                                },g.

I Each Containme Spray System shall e demonstrated CPE LE: 4

a. At least ce per 31 days by: 3 "'"' N /

__/ - -

                                                                                                                                                                      >_       ~

1. Ver ing that upon a(Ra/AcuntL6n AetdariodIest $1gns . L t c siimos s ist rtvalves spen yru t a

                                            /"                                       ec         lation mod                w         via aprDFill4I M s                     down                    2                  A'1 he         exchanger i                                               -
                                                                                                                                                                                  - T
                                                                                            '     ~                     _ _ b1 _ _ eds

e. 4,i 4o b Verifying that ch v ve(manual,po reoperated, or 4w .u.d automatic)in e f1 path that is t locked, sea d or i p i s .+ -

' o herwise $ red positionJ ittocra no tan mJ m orL tpg A'E a ne _ run on a#ontainmMt I rea *e HicV;es(signal./ ' h _ At _ *W q /[)n en 4.,,3;t leastWs_,s/peo per nuu W.D. LIMWW INT [a',d during shutdown, b .e)..l+c J s; l.4 J r 1. Veri ying that each automa c valve in the flow pt actuates t_o ts correct position ane apprmrisiY rsnegsignal. [(ib erifying that each y pu'np starts automa cally on g g,4 ppp N p1"ts p g signal.

                                                                                                                                           .f tJ1 C R.T R U                                                     h brI*l'I'h                          With pressurizer pressure .>,1750 psia.

f r owsk S R 'l.4 2 1-(( 19.5 .b CALVERT CLIFFS . UNIT 2 3/4 6-11 Amendment No. 189 d U t k u. h t h s. d . I W Y

,..______. ~ __ _ _____ _ ___- _ _. __ - . . _ _ _ _ _ . - _ . _ _ - . _ . . _ _ . _ _ _ _ _ _ _ _ -- _ _._._

                                                                                                                             % p ,. e . I. e b . 7 , b . lo

! INSERTS SRMmr$3.6.6.4 l Suntillance Frequency

              '~                                                                                                                                                    '
                     .6.6.1         ~ fy each con             at spray                 J, power          ted, and au             tic       31 valw in the         path is                 ked, scal            r otherwiec 1              L                   in posi      is in the               position.                                                      ,                              J                I SR 3.6.6.4 Verify containment spray pumps denloped head at the flow test po;nt                                            in accordance with                         I i                                 is greater than or equal to the required developed head.                                                 the Inservice Testing Program                           i e

I

,                                                                                                                                                                                    i i

U l l J 4 4 9 l 1 1 ] e

Qe e . C. .,y 4 . .

                                                                                      '5 ' (* ' S 3/4.6 CONTAllBElff SYSTDt$

Sukyt!LLANCE REQUlktMENTS (Continued) At l_east/ce os

                            ..s per n n $ye clea.

res orsing en e r ., __, oghg.teer an verifyin och spray not is T]

Ocemw. 1 F4.oo l95' t l l l CALVERT Cliffs - UNIT 2 3/4 6 12 Amendment No. 189 l

%hk

he dieenen 3 6 6 DMIaT SRs te.1.i.a. 4 4 a q,e.t,g, A M oppeure) (v M ?, i n Lion,tGwJmM de IW 4.6.2.1 Each Containment Spray System shall be demonstrated OPERABLE: 11i. At least once per 31 days by: Qnk tv.u4 WsWQ GR 3.4.41 / 1. Verifying)that automatic in the each flowvalve path (manual, that is notpower locked,operated, sealed or.or otherwise secured in ponition it FpostClone to t e suction l (Trtm thy RWKon NConta ymen(PrbgsurLQigh est s nal

                              .         At leas once per             days by:     .

1. Verify g that upo a Recirc tion Act tion Te Signal, d the cont inment sump isolation alves op and tha a recircula on mode f1 path via n OPERA shutdo. coolin heat exchan er is estab shed.

c. durina shutdown, by: hG . sea tea , or At least once per RE(FUE11H INIERV#_G isotar, ret w.t toc -

eewi u< J ia Peth. SR 3.L.6 5 1. Verifying that each automatic valve in the flow path + actuates to its correct position on (ttfe aphropMatA ESS5\te( Ignal. j'q UR 3.1,6,6, 2. Verifying that each spray pump starts automatically on@ p ocun or s'imula4 e4 gg qq 3ng . At least once per yeara 10 L.5)

                         )       qwrouw) etcn wpraE needer 4 n penannin                   in air er imote f40w\te%t) erifying each spray nozzlrT3 L         unobstructea.

9 Licmu A&4 19 s' N.y 4 of 6 &

Q n . r . , 4 . <, , T.6.b g 3 . () -4/+tt- CONTAINMENT SYSTEM $ C d ! " Y 5 K ' 7) L 6. 6 4/4, s.;- ttpaHfURIZATJC AND C29tlhL5YSTDb Q~ , ntai, Cool _ Svtig ) l LIMITING CONDIT10N FOR OPERAT!0N h ' ** * ** *

P ' * / ' * ' **5 * ** d 'ad L.t.o % 6 6 ntainment O cuian w an o oon n, AT(W.,de$fR.

4444 e .uhsa a - - .. _p e _o ., APPLICABILITY: MODES 1, 2 and 3. %%g 42 Euw h IWith "QX Got Q on group of required containment Qifttreu4etion tad '

c. <.-c. a.A ^

d

5

cooling $'T,$ T M inoperable and both Containment 3 pray 3ystems 3o io n C OPERABLE, restore the inoperable group of air rietreulation ends am u'2 cooling units to OPERABLE status within 7 daysfor be in at least

-~

y 3 An,.y g % NOT SN ytthin 12 hours r uF (< i. .n..; /7 Ty- . __ _- f L. Act oo O \(%ith hree heqalred rent 1It A J - m > cooling . units inoperable and both Contt noen Spray 3FitMTOPERABLE, b .m ( hestore at least one .= a'

                                         /to OPERABLE status within@ hours or be in a r=mu                  ~

and cooling ~ east D ' s

                                                                                                                                                                "'L/
                                         \within 12 hours. Restore both above required groups 9$9" $ NUT                    "

w ,,y, t. ., _ / containment air rectT5Tatton and cooling units to prinABLE

                                                                                                                                     >                ,_ Q _ *_

Status within@ays or be in at lealty07 $NUTDOWN within 12 J A m * ." i E - hours. K With one group of required containment air retirculation and cooling units inoperable and one Containment Spray System

  , " ' ' * ^                           / inoperable, restore the inoperable Containment $ pray System to
   ""-C                               (OPERABLE status within 72 hours or be in at leastf0T SNUTDOWN A c , o. ,'         ' N -(within 12 hours. Restore the inoperable group of containment a r

c. -

                                       - recirculation and cooling units to OPERABLE status within 7 days                                              1 6 u08 L*                                                                                                                                           j
                                      -z of initial loss or be in at least @0T $NUTDOWN within 12 hours.

T

                           $URVEILLANCE REQUIREMENT 5 _

4.6.2.2 Each containment air recirculation and cooling unit shall be demonstrated OPERABLE:

                                   \ At least once per 31 days (n~I3fRUUtttD m3Jt31Q                                                                   g
                                        \($}ptThg each upe"from the conVroo89                                                                            'Q kb CALVERT CLIFF 5 . UNIT 2                         3/4 6 13                           Amendment No. 189               l
                              ,_ _                  .s              -

p "T , ,, e. 4 e. . - .

l c.p *
Y N4., Leo

                                      ....,..w.~

v. s

4
4rl y h -

b

                                     %         .     . . . .       . oa. . ,                                                               I
                     )m                                                                                                                   3
                                                  .....,,..w,

_ _ _ _ - - -- J py 3 g

p . c . O r a 4 . .. 3 ~S . 6 6 3/4.6 CONTAlifttitT_lYlfDi$

           $URVIILLANCE REQUIRENENTS (Continued) 8" 3#

y Verifying that each unit operates for at least 15 minutes. .

'" I' " 4
                     % Yerifying cooline unita5When coolina  thewater  _ flow rate of g vos   2000 ppa       to eac6, fuWf1FiiWirrweterWitMy                  LA,3 tre fully coen.f s k M.5           b.                                                   that  each unit At least starts    once pcally on the ;; ar automat                     "'atFULLING     INittVAL st signal.       by h a e4] a [ *i      4'- F =4' 9 ..__...

CALVERT Cliffs . UNIT 2 3/4 6 14 Amendment No. 189 l P7 b *I b b

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

DISCUSSION OF CIIANGES SECTION 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS l ADMINISTRATIVE CilANGES A.1 The proposed change will reformat, renumber, and reword the existing Technical Specifications, with no change ofintent, to b6 consistent with NUREO 1432. As a result, the Technical Specl0 cations 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 NUREO.1432. Ilowever, the additional informction does not change the intent of the current Technical Specl0 cations. The reformatting, renumbering, and rewording process involves no technical changes to existing Specifications. A.2 Current Technical Specifications 3.6.2.1 (Containment Spray System) and 3.6.2.2 (Containment Cooling System) are being combined into a Containment Spray and Cooling i Systems Specification (ITS 3.6.6). These Specifications were combined because both the ] Containment Cooling and Containment Spray Systems' function is to relieve pressure and , temperature in containment. Combining Technical Specifications constitutes an

administrative change, nis change is consistent with NUREG 1432.

1 , A.3 Current Technical Specification 3.6.2.1 Actions require the plant to shut down to Mode 5 wher the Containment Spray train cannot be restored to Operable status, improved Technical Specification 3.6.6 Action D requires the plant to shut down to Mode 3 with pressurizer pressure < 1750 psia. This change will relax the shutdown requirement from Mode 5 to Mode 3 with pressurizer pressure < 1750 psia, when a Containment Spray train

.                        cannot be restored to Operable status. This is an administrative change because, per

LCO 3.0.1 and LCO 3.0.2, the LCO is required to be met during the Modes of Applicability, and if the LCO is no longer appl.:cabic, the Required Actions do not have to be completed.

The current App 5icability for the Containment Spray System is Modes 1 and 2, and Mode 3 with pressurizer pressure 21750 psia. Therefore, the plant is only required to shut down to Mode 3 with pressurizer pressure < 1750 psia, although the Required Action requires the plant to shut down to Mode 5. I A.4 Current Technical Speci0 cations 3.6.2.1 and 3.6.2.2 do not contain any requirements when two containmen' spray trains are inoperable, or when any combination of three trains of containment spray or containment cooling is inoperable. Therefore, the CTS would require that LCO 3.0.3 be entered. Improved Technical Specificat an 3.6.6 will contain an Action (Action F) to enter LCO 3.0.3 immediately. The addition of Oc Action is an administrative change because CTS requires the same Actions. TK change is consistent with > NUREG 1432. A.5 Current Technical Specincations 4.6.2.1.c.1,4.6 2.1.c.2 and 4.6.2.2.b require verifying the containment spray valves actuate to their correct position and the containment spray pumps

,                        and containment cooling units start on an ESFAS test signal, improved Technical Specificatica SRs 3.6.6.5,3.6.6.6, and 3.6.6.7 also require the containment spray valves and pumps, a'id containment cooling units, respectively, to perform as required, but it permits the verificatim to be conducted with an actual r,r simulated signal, Current Technical Specification 4.6.2.1.c.1,4.6.2.1.c.2, and 4.6.2.2.b have been revised to permit the test to be CALVERT CLIFFS                UNITS 1 & 2                        3.6.6-1                                                 Revision 7

DISCUSSION OF ClfANGES SECTION 3.6.6 CONTAINMENT SPRAY AND COOLING SYSTEMS credited with an actual signal. Given t!'e ability to verify the components perform as required, an actual signal is equivalent to a simulated signal, nis allowance is consistent with current plant practice, in the event t.n actual signal occurs and all the functions can be verined. His proposed change is continent with NUREG 1432. A.6 Current Technical Speci0 cation 4.6.2.1.a.1 requires the veri 0 canon that each valve (manual, power-operated, or automatic) in 'he Dow path that is not locked, scaled, or othenvise secured in position is positioned to take suction from the RWT on a Containment Pressure . liigh test signal, improved Technical Specincation SR 3.6.6.1 requires the verification that each con'ainment spray manual, power operated, and automatic valve in the Dow path that is not locked, scaled, or otherwise secured in position is in the conect position. Current Technical Specincation 4.6.2.1.a.1 has been revised to renect the wording ofITS SR 3.6.6.1. ne phrase "is positioned to take suction from the RWT on a Containment Pressure liigh test signal" has been replaced with the phrase "is in the correct position." These phrases are equivalent; each requires the applicable containment spray valves to be verined to be properly positioned to ensure that the containment spray system can recomplish its safety function, if required. This proposed change is an administrative change, which does not change the intent of the SR. This proposed change is consistent with NUREO 1432. A.7 Current Technical Specl0 cation 4.6.2.1.b.1 requires verifying, at least once per 92 days, the containment sump isolation valves open and that a recirculation mode now path via an OPERABLE shutdown cooling heat exchanger is established, upon receipt of a Recirculation Actuation Test Signal, improved Technical Specification 3.6.6 does not include an SR to verify, every 92 days, the containment sump isolation valves open and that a recirculation mode now path via an OPERABLE shutdown cooling heat exchanger is established, upon receipt of a Recirculation Actuation Test Signal, This SR is being deleted from CTS 3/4.6.2. This proposed change is acceptable, because it is redundant to the requirement in CTS SR 4.3.2.1.1 to perform a CIMNNEL FUNCTIONAL TEST, at least once per 92 days, on each ESFAS instrumentation channel. This requirement has been retained as ITS SR 3.3.5.1. As part of the CilANNEL FUNCTIONAL TEST of the actuation logic for the Recirculation Actuation Signal, the individual components will also be actuated. Hus, CTS 4.6.2.1.b.I is encompassed by the CilANNEL FUNCTIONAL TEST for CTS SR 4.3.11.1. Deleting CTS 4.6.2.1.b.1 is an administrative change, because the testing wdl continued to be performed at the same frequency in accordance with ITS SR 3.3.5.1. IECilNICAL CIIANGES - MORE RESTRICTIVE M.1 Improved Technical Specifications SR 3.6.6.4 is not contained in CTS 3.6.2.1 Surveillance l Requirement 3.6.6.4 verifies that each containment spray pump developed head at the flow test point is greater than or equal to the required developed head in accordance with the Inservice Testing Program. Surveillance Requirement 3.6.6.4 is performed to provide l assurance that the containment spray pumps' overall performance is satisfactory by confirming one point on the pump design curve. Adding an additional SR to Technical l Specifications constitutes a more restrictive change. This change will not adversely affect plant safety because the added SR provides assurance that the Containment Spray System l will perform as reqwed. This change is consistent with NUREG 1432. M.2 Current Technical Speci0 cation 3.6.2.2 Actions require the plant to be in Mode 4 in 12 hours when the Required Actions and associated Completion Times cannot be met. improved CALVERT CLIFFS UNITS 1 & 2 3.6.6 2 Revision 7

DISCUSSION OF CHANGES l SECTION 3.6.6 - CONTAINMENT SPRAY AND COOLING SYSTEMS Technical Specification 3.6.6 will require the plant to be in Mode 3 in 6 hours, and Mode 4 in 12 hours. This change will add a requirement to be in Mode 3 at a certain period of time during the shutdown to Mode 4. The addition of th!s step is reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner, and without challenging plant systems. Placing a time requirement to be in Mode 3 during a shutdown is a more restrictive change, nis change will not adversely affect plant safety because the intermediate step requires the plant to cooldown in an orderly manner. His change is consistent with NUREG 1432. M.3 Current Technical Speci0 cati on 3.6.2.2 Actions allow seven days to restore one containment cooling train to Operable status when one cooling unit in each train is inoperable. See d discussion of Change L.2 for the case when three containment cooling units are inoperable, and the train with one unit inoperable is being restored. Improved Technical Specification 3.6.6 will allow 72 hours to restore one containment cooling bain to Operable status. The 72 hours take into account the degraded condition of the heat removal capability. Although greater than 100% of the heat removal capability exists, protection against a single failure is not available, therefore 72 hours is reasonable. This is consistent with Emergency Core Cooling System requirements which allow one train to be inoperable for 72 hours as , long as there is 100% Cow available, Decreasing the Completion Time for a Required Action constitutes a more restrictive change, nis change will have no adverse impact on safety because the 72 hours limits the time the heat removal capability is in a degraded condition. This change is consistent with NUREG-1432, M.4 Improved Technical Specification 3.6.6 Actions A and C contain a limit on the total combined duration of operation for one containment spray train inoperable (Action A), and one containment cooling train inoperable (Action C), of 10 days. This will prevent continuous operation in a degraded condition by entering the two Actions repeatedly. Current Technical Specifications 3.6.2.1 and 3.6.2.2 Actions (Containment Spray and Containment Cooling Technical Specifications, respectively) do not contain this limitation. Also, each of these requirements are contained in separate LCOs. The combination of these two Specifications warranted this limitation. Therefore, the addition of this limitation is a more restrictive change. This change does not affect plant safety because it prevents operation in a degraded electrical condition for an inappropriately long period. This change is consistent with NUREG-1432. M.5 In the event the Containment Spray System is inoperable and cannot be restored within the specified time, the Action for CTS 3 6.2.1 requires the plant to be placed in Mode 3 within 6 hours and outside the Mode of Applicability within 36 hours. Action B ofITS 3.6.6 will requite the plant to be placed in Mode 3 in 6 hours and outside the Mode of Applicability (i.e., Mode 3 with pressurizer pressure < 1750 psia) within 12 hours. This proposed change is a more restrictive change, because only 12 hours is permitted to place the plant outside the Mode of Applicability. He proposed change is acceptable, because the 12 hour period permits the plant to be placed in Mode 3 with pressurizer pressure < 1750 psia in a controlled manner. 1 TECIINICAL CHANGES - RELOCATIONS None CALVERT CLIFFS - UNITS ; & 2 3.6.6-3 Revision 7

  ._   _. _ ___ _ _ _ _                        _    _   _ _ _ _          ..m      _       _     _ _         __    _ _ _ .

DISCUSSION OF CHANGES SECTION 3.6.6 - CONTAINMENT SPRAY AND COOLING SYSTEMS TECilNICAL CilANGES - MOVEMENT OF INFORMA"9N TO LICENSEE CONTROLLED DOCUMENTS LA.I Current Technical Specification 3.6.2.1 LCO states that the Containment Spray System shall be Operable with each spray system capable of taking suction from the refueling water tank on a Containment Spray Actuation Signal and Safety Iglection Actuation Signal, and automatically transferring suction to the containment sump on a Recirculation Actuation Signal (RAS), and that the flow path from the containment sump shall be via an Operable shutdown cooling heat exchanger. Improsed Technical Specification 3.6.6 requires the Containment Spray System to be Operable, but does not contain the details that are in the CTS. These details are being moved to Section B 3.6.6 of the ITS Bases. Ti is is acceptable because these details do not impact the requirement to verify that the Containment Spray System is Operable. These details can be adequately controlled in the Bases which require i change control in accordance with Bases Control Program in ITS Section 5.0. This approach 4 provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operations is unaffected by the change because there is no change in the requirement for the Containment Spray System to be Operable. Furthermore, NRC and Calvert Cliffs resources associated with processing license

amendments to these requirements will be reduced. This is a less restrictive movement of information change with no impact on safety. This change is consistent whh NUREG 1432.

LA.2 Current Technical Specification 4.6.2.2.a.1 requires that the containment air recirculation and cooling units be started from the Control Room. Improved Technical Specification SR 3.6.6.2 will not contain this requirement. This requirement will be moved to Bases Section SR 3.6.6.2 of the ITS Bases. This is acceptable because this requirement does not impact the requirement to verify that the containment air recirculation and cooling units will remove heat from containment. This detail can be adequately controlled in the Bases which . require change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provis:s 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 to verify the containment air recirculation and cooling units are Operable. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This is a less restrictive movement ofinformation change with no impact on safety. This change is consistent with NUREG 1432. LA 3 Current Technical Specification 4.6.2.2.b requires verifying cooling water flow when the flow service water outlet valves are fully oper. Improved Technical Specification SR 3.6.6.3 ! will not contain this requirement. This requirement will be moved to the Bases, This is l acceptable because Technical Specifications should only contain specific requirements (i.e., to verify flow is a certain gpm). As long as the flow requirements are met, Technical Specifications should not specify valve position. The Bases ofITS SR 3.6.6.3 will include the requirement to conduct the SR when the full flow service water outlet valves are fully open. The Bases will be maintained in accordance with the Bases Control Program in ITS Section 5.0. This approach provides an effective level of control and a more appropriate change control process. The level of safety of facility operations is unaffected by the change because there is no change in the requirement to verify that the flow to each cooling unit meets the acceptance criteria. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This is a less CALVERT CLIFFS - UNITS 1 & 2 3.6.6-4 Revision 7

DISCUSSION OF CalANGES SECTION 3.6.6 o CONTAINMENT SPRAY AND COOLING SYSTEMS restrictive movement of information change with no impact on safety, nis change is consistent with NUREG 1432. LA.4 Current Technical Specifications 4.6.2.1.c.1,4.6.2.1.c.2 and 4.6.2.2.b specifically list the test signal (Engineered Safety Features Actuation System (ESFAS)) that must be used to verify that the containment spray valves actuate to their correct position and the containment spray pumps and containment cooling units start. Improved Technical Specification SRs 3.6.6.5, 3.6.6.6, and 3.6.6.7 require the containmeat spray valves, containment spray pumps, and containment cooling units, respectively, to perform as required on an actual or simulated signal. The specific test signals will no longer be specified in the SRs. The test signals will be identified in the Bases for ITS SRs 3.6.6.5, 3.6.6.6, and 3.6.6.7. His is acceptable because these details do not impact the requirement to verify that the containment spray valves and pumps and the containment cooling units will perform as required. These details can be adequately controlled in the Bases which requires change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement for the containtnent spray valves and pumps and the containment cooling units to perform as required. LA.S Current Technical Specification 4.6.2.1.c requires verification that the c .ainment spray nonles are unobstructed by performing an air or smoke flow test through each spray header, improved Tuhnical Specification SR 3.6.6.8 will not contain this specific information. The requirement to use an air or smoke flow test through the spray header is being moved to Section B 3.6.6 of the ITS Bases. This is acceptable because these details do not impact the requirement to verify that the containment spray nozzles are unobstructed. These details can be adequately controlled in the Bases which require change control in accordance with Bases

Control Program in ITS Section 5,0, This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operations is unaffected by the change because there is no change in the requirement to verify that the containment spray nozzles are unobstructed. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. His is a less restrictive movement of information change with no impact on safety. This change is consistent with NUREG-1432.

TECHNICAL CIIANGES - i ESS RESTRICTIVE L.1 Not used. l L.2 Current Techr.ical Specification 3.6.2.2 contains an Action which allows eight hours to restore one containment cooling unit to Operable status when three containment cooling units are inoperable. See discussion of Change M.3 for the case when one containment cooling unit in each train is inoperable. Improved Technical Specification 3.6.6 Action D allows 72 hours to restore one containment cooling train to Operable status when both trains are inoperable (three containment cooling units inoperable in CTS is equivalent to two trains being inoperable in ITS). In both cases, two trains of containment spray must be Operable. This change increases the Completion Time to restore 1 train to Operable status from 8 hours to 72 hours. Increasing the Completion Time is reasonable because the 2 Operable trains of containment spray provide 100% of the heat removal capability. The remaining Operable CALVERT CLIFFS - UNITS 1 & 2 3.6.6-5 Revision 7

DISCUSSION OF CHANGES SECTION 3.6.6 - CONTAINMENT SPRAY AND COOLING SYSTEMS containment cooling unit will also provide approximately 33% heat removal capability. l Therefore, although single failure protection of the Containment Cooling System is not l provided, the Containment Spray System is available, and the likelihood of an event occurring during the short period of time one train of containment cooling is allowed to be inoperable is small. Increasing the Completion Times constitutes a less restrictive change. This change is consistent with NUREG-1432 L.3 Current Technical Specification 3.6.2.2 does not contain Actions for the situation when all the containment cooling units are inoperable. Therefore, LCO 3.0.3 would have to entered. Improved Technical Specification 3.6.6 Action D allows 72 hours to restore one containment cooling train (two containment cooling units in one train) to Operable status if both containment spray trains are Operable. This change will increase the Completion Time when both trains of containment cooling are inoperable from a shutdown track via LCO 3.0.3 to 72 hours increasing the Completion Time is reasonable because the two Operable trains of containment spray provides 100% of the heat removal capability. Therefore, although a redundant Containment Cooling System is not available, the likelihood of an event occurring in the short period of time one train of containment cooling is inoperable is small, increasing the Completion Times constitutes a less restrictive change. This change is consistent with NUREG 1432 L.4 Not used. l L.5 Current Technical Specification 4.6.2.1.d requires verification that the containment spray l 4 nozzles are unobstructed once per five years. Improved Technical Specification SR 3.6.6.8 requires the test to be performed every 10 years. This change will decrease the Frequency for verifying the containment spray nozzles are unobstructed from 5 years to 10 years. The decrease in the SR Frequency was recommended by the NRC in NUREG-1366,

            " Improvements to Technical Specification Surveillance Requirements." An NRC search for problems involving the Containment Spray System while performing this test resulted in three problems being found in all three cases the problem involved a construction error.

Also, the test gives no quantitative data on flow rates exiting the nozzles, it only verifies that there is flow. The NRC did not uncover any problems involving this flow verification. Based on the above data, the NRC recommended that the SR Frequency be decreased from 5 years to 10 years. Also, analysis of specific Calvert Cliffs data did not reveal any past problems. This Frequency is also reasonable to detect obstruction because of the passive design of the nozzles. Decreasing Surveillance Frequency requirements in the Technical Specifications constitutes a less restrictive change. This change is consistent with NUREG-1432. L.6 Current Technical Specification SR 4.6.2.2.a requires that testing be performed every 31 days on a Staggered Test Basis, improved Technical Specification 3.6.6 SRs will not require testing on a Staggered Test Basis. The Containment Cooling System consists of two trains. This change deletes the requirement to perform testing on a Staggered Test Basis. This is acceptable because the tests on a non-staggered frequency will continue to prove the system performs as required. Just as other systems with two trains (low pressure safety injection, containment spray, etc.), the Containment Cooling System is tested by train with other components on the same train. Normally, different components on different trains are not tested on the same day. This is a good operating practice because it prevents components from opposite trains from becoming inoperable at the same time. This change makes the CALVERT CLIFFS - UNITS 1 & 2 3.6.6-6 Revision 7

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

DISCUSSION OF CHANGES SECTION 3.6.6 - CONTAINMENT SPRAY AND COOLING SYSTEMS containment cooling trains consistent with other engineered safety features trains in that Staggered Testing is not required. The deletion of requirements on SRs const;tutes a less restrictive change. This change is consistent with NUREG 1432.

, L.7    Current Technical Specification 4.6.2.1.c.1 requires the verification that each containment spray automatic valve in the flow path actuates to its correct position on the appropriate signal. Improved Technical Speci0 cation SR 3.6.6.5 also requires the veriGcation that each containment spray automatic valve in the flow path actuates to its correct position on the appropriate signal; however, the ITS SR does not require containment spray automatic valves that are locked, sealed, or otherwise secured to be verified to actuate to their required position. Current Technical Specification 4.6.2.1.c.1 has been changed to include the exception regarding valves that are locked, scaled, or otherwise secured. This proposed change is acceptable, because the containment spray valves that are locked, scaled, or otherwise secured in position are verified to be in their proper position prior to locking, sealing, or securing. After locking, sealing, or securing, it would take an intentional act to remove the lock, seal, or securing device prior to realigning the valve. Administrative controls are provided to assure that valves which are locked, scaled, or secured in position are not inadvertently realigned. Additionally, this proposed change is consistent wit' he requirements of a number of CTS SRs (e.g., 4.5.2.b.1, 4.7.1.2.a.4, 4.7.3.1.a, 4.7.4.1.a, and 4.7.5.1.a) which do not require the position of valves that are locked, sealed, or other vise secured in position to be verified.

l l l 1 CALVERT CLIFFS - UNITS 1 & 2 3.6.6-7 Revision 7

DISCUSSION OF CIIANGES SECTION 3.6.7 - liYDROGEN RECOM INERS l ADMINISTRATIVE 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.

TECIINICAL CIIANGES - MORE RESTRICTIVE None 8 TECEINICAL CIIANGES - RELOCATIONS None TECHNICAL CIIANGES - MOVEMENT OF INFORMATION TO LICENSEE CONTROLLED DOCUMENTS

  - LA.1    Current Technical Specification 4.6.5.2.b.2 provides examples (i.e., loose wiring or structural connections, deposits of foreign materials, etc.) of what to look for when performing a visual examination of the hydrogen recombiners, improved Technical Specification SR 3.6.7.3 requires a visual examination, but will not contain any examples.

These examples are being moved to Bases Section B 3.6.7, SR 3.6.7.3 of the ITS Bases. This is acceptable because the examples do not impact the requirement to visually examine the hydrogen recombiners. These details can be adequately controlled in the Bases which require change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operations is unaffected by the change because there is no change in the requirement to perform a visual e : amination of the hydrogen recombiners. Furthermore, NRC and Calvert Cliffs resources associated a with processing license amendments to these requirements will be reduced. This is a less restrictive movement of information change with no impact on safety. This change is consistent wiL NUREG-1432. LA.2 Current Technical Specification 4.6.5.2.b.4 requires the resistance-to-ground test be performed following the functional test. Improved Technical Specification SR 3.6.7.4 will not contain this requirement. This requirement will be moved to Bases Section SR 3.6.7.4 of the ITS Bases. This is acceptable because this requirement does not impact the requirement to verify the resistance to ground. This requirement can be adequately controlled in the Bases which require change control in accordance with Bases Control Program in ITS Section 5.0. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operations is CALVERT CLIFFS - UNITS I & 2 3.6.7-1 Revision 7

DISCUSSION OF CIIANGES SECTION 3.6.7 - HYDROGEN RECOMBINERS unaffected by the change because there is no change in the requirement to perform a resistance-to-ground test. Furthermore, NRC and Calvert Cliffs resources associated with processing license amendments to these requirements will be reduced. This is a less restrictive movement of information change with no impact on safety. This change is consistent with NUREG 1432. LA.3 Current Technical Specification LCO 3.6.5.2 contains the ,equirement for the hydrogen recombiners to be independent. Improved Technical Specification 3.6.7 will not contain this requirement. The ITS will move this detail to the Background Section of the Specification 3.6.7 Bases. This is acceptable because this requirement does not impact the requirement for the hydrogen recombiners to be Operable. The independence of the hydrogen recombiners is a design detail that does not belong in the Technical Specifications. This detail can be adequately controlled in the Bases which are controlled via Section 5.0. This approach pro / ides 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 design requirement that the hydrogen recombiners be independent, and also, no change in the LCO requirement for the hydrogen i recombiners to be Operable. Furthermore, NRC and Calvert Cliffs resources associated with processing license 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. LA 4 Current Technical Specifications 4.6.5.2.b.3 and 4.6.5.2.b.4 list specific test acceptance , criteria for the hydrogen recombiner functional test and resistance-to-ground test. Improved Technical Specification 3.6.7 will not contain the specific acceptance criteria. The ITS only requires that a functional test (SR 3.6.7.1) and a resistance-to-ground test (SR 3.6.7.4) be performed. The specific acceptance criteria will be moved to the specific SR sections in the Specification 3.6.7 Bases. This is acceptable because this specific acceptance criteria does not impact the requirement for the hydrogen recombiners to be proven Operable by performance of the functional test and resistance to-ground test. The acceptance criteria can be adequately controlled in the Bases which are controlled via Section 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 to perform the SRs. Furthermore, NRC and Calvert Cliffs resources associated with processing license araendments 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. TECHNICAL CHANGIS - LESS RESTRICTIVE L.1 In the event both hydrogen recombiners are inoperable, the CTS would require compliance with Specification 3.0.3, because CTS LCO 3.6.5.2 does not contain an action to address both hydrogen recombiners inoperable. Current Technical Specification 3.0.3 requires the plant to be placed in a Mode fu cN:h the LCO does not apply within a specified time period. Action B for ITS 3.6.7 permits the plant to continue to operate, as long as the hydrogen control function is periodically verified to be maintained by administrative means, and one hydrogen recombiner is restored to an operable status within 7 days. Action B of ITS 3.6.7 is being incorporated into the Actions of CTS LCO 3.6.5.2. The Bases for Action B of NUREG 1432 LCO 3.6.8 (i.e., Action B of ITS 3.4.7) contains a Reviewer's CALVERT CLIFFS - UNITS I & 2 3.6.7-2 Revision 7

DISCUSSION OF CHANGES SECTION 3c6.7 o IIYDROGEN RECOMBINERS Note which states: "This Condition is only allowed for units with an alternate hydrogen control system acceptable to the technical staff." incorporation of the Action into CTS 3/4.6.5.2 is appropriate, because Calvert Cliffs possesses an alternate means of hydrogen control that has been found acceptable by the technical staff, in Section 3.2.2.3 of the original Safety Evaluation for Calven Cliffs Unit Nos. I and 2, dated August 28,1972, the Atomic Energy Commission stated: "The hydrogen purge system provides a backup means of hydrogen control should both of the recombiners fail to function properly...We have concluded that the provisions for mixing, measuring, and controlling the quantity of hydrogen in the containment following a LOCA are adequate." The proposed change is acceptable, because:

1. the containment vent / hydrogen purge system is an acceptable alternative to the hydrogen recombiners. The containment vent / hydrogen purge system is capable of maintaining hydrogen concentrations inside containment below the required limit of 4.0v/o;

2. the action includes a requirement to periodically verify by administrative means that the hydrogen control function is maintained;

3. the containment vent / hydrogen purge system is utilized during normal operations for purposes other than hydrogen control. Thus, the operators are familiar with the system and its operation. Following an accident, there will be adequate time to place the containment vent / hydrogen purge system into operation if the need arises, because the hydrogen concentration builds up slowly; and

4. the revised action will permit the plant to avoid unnecessary transients (i.e., unplanned shutdown) and the potential challenges (e.g., cyclic stress) inherent to these operations.

L.2 Current Technical Specification 4.6.5.2.a requires a six month functional test of the hydrogen recombiner to verify the minimum heater sheath temperature increases to 2 700 F within 90 minutes, and is maintained for at least 2 hours. improved Technical Specification 3.6.7 will not contain this requirement. Generic Letter 93-05 recommended extending the frequency of the six-month hydrogen recombiner functional test to the refueling interval. For Calvert Cliffs, extending the frequency of CTS 4.6.5.2.a to 24 months would result in requiring two functional tests of the hydrogen recombiners to be performed at the same frequency, but with different acceptance criteria. This is inappropriate. CTS SR 4.6.5.2.b.3 requires a system functional test for each hydrogen recombiner to be performed every refueling interval. This SR requires the heater sheath temperature to be . increased to 21200 F within 5 hours, and maintained for at least 4 hours. Current Technical Specification SR 4.6.5.2.b.3 has been maintained as ITS SR 3.6.7.1. This SR is the correct test to perform every 24 months; it ensures the hydrogen recombiners can perform their function (i.e., heat a hydrogen air mixture to above 1150 F). Current Technical Specification 4.6.5.2.b.3 provides the appropriate acceptance criteria for ensuring the hydrogen recombiners can perform their function. The acceptance criteria of rTS 4.6.5.2.b.3 encompass the acceptance criteria of CTS 4.6.5.2.a. Deleting CTS 4.6.5.2.a will not affect the ability to demonstrate the operability of the hydrogen recombiners. Additionally, no problems were identified while performing CTS 4.6.5.2.a (during a search of the SRs back to 1985); and the six month functional test is not recommended by the CALVERT CLIFFS - UNITS 1 & 2 3.6.7-3 Revision 7

DISCUSSION OF CHANGES SECTION 3.6.7 - HYDROGEN RECOMBINERS manufacturer. Deleting the requirement to perform a functional test of the hydrogen recombiners on a six month basis will reduce wear and tear on the hydrogen recombiners (i.e., reduce the potential of testing the hydrogen recombiners to failure). Thus, CTS 4.6.5.2.a has been deleted. L.3 Current Technical Specification 3.6.5.2 Actica allows 30 days to restore the inoperable hydrogen recombiner train to Operable status when one train is inoperable. Improved Technical Specification 3.6.7 will also allow 30 days to restore the inoperable hydrogen recombiner train to Operable status, however, it is modified by a Note which exempts LCO 3.0.4. This allows the plant to change Modes when one hydrogen recombiner is inoperable. This is acceptable because either hydrogen recombiner can control the hydrogen i concentration to below the flammability limit. Also, the containment vent is available to maintain the hydrogen concentration to within limits. Allowing the plant to change Modes while in an Action statement by exempting LCO 3.0.4 constitutes a less restrictive change, This change is consistent with NUREG 1432. 1 i J l J CALVERT CLIFFS - UNITS 1 & 2 3.6.7-4 Revision 7

3. (. 5. I n1 web 10 Arcr7ag g,5 3a3./U f14oef 3/4.6 CONTAINMENT SYSTEMS 3/4 .6.5 COMBUSTIBLE GAS CONTROL f Hydronen Analvrers LIMITING CONDITION FOR OPERATION l 3.6.5.1 Two independent containment hydrogen analyzers shall'be OPERABLE.

APPLICABILITY: M00E5 1 and 2. 311[Et

a. With one hydrogen analyzer inoperable, restore the inoperable analyzer to OPERABLE status within 30 days or:

1. Verify containment atmosphere grab sampling capability and prepare and submit a special report to the Comission pp auant to 10 CFR 50.4 within the following 30 days. l outlining the ACTION taken, the cause for the inoperability.

' and the plans and schedule for restoring the system to OPERABLE status, or

2. Be in at least NOT STANDBY within the next 6 hours.

b. With both hydrogen analyzers inoperable, restore at least one inoperable analyzer to OPERABLE status within 72 hours or be in at least NOT STANOBY within the next 6 hours,

c. Specification 3.0.4 is not applicable to this requirement.

EURVEILLANCE REQUIRENENTS 4.6.5.1.1 Each hydrogen analyzer shall be demonstrated OPERABLE at least bi-weekly on a 5TAGGERED TEST BASIS b System through the hydrogen analyzer.y drawing a sample from the Waste Gas 4.6.5.1.2 Each hydrogen analyzer shall be demonstrated OPERABLE at least once per 92 days on a STAGGERED TEST SASIS by perfonning a CRANNEL CALIBRATION using sample gases in accordance with manufacturers' ommendations.

 -CALYERT-CtfFFS ,-ilNIT-1                     3/4-6-24        -Anendment-Nb-216

((

i 6 TS 3.c. c./ l WFO 10 s P e n .oks 33 ( 3 ,*r..I O P A M I) , g e

                                                                                                             %           h.l  _

j 3/4.6 CONTAINMENT SYSTEMS 3/4.6.5 00pBUSTIBLE GAS CONTROL Kvdronen Analvrers LIMITING CONDITION FOR OPERATION 3.6.5.1 Two independent containment hydrogen analyzers shall be OPERABLE. APPLICABILITY: MODES 1 and 2. ACII.Qlit

a. With one hydronen analyzer inoperable, restore the inoperable analyzer to OPtRABLE status within 30 days or:

1. Verify containment atmosphere grab sampling capability and prepare and submit a special report to the Comission pursuant to Specification 6.9.2 within the following 30 days, outlining the action taken, the cause for the inoperability, and the plans and schedule for restoring the system to OPERABLE status, or

2. Se in at least NOT STAND 8Y within the next 6 hours.

b. With both hydrogen analyzers inoperable, restore at least one inoperable analyzer to OPERABLE status within 72 hours or be in at least NOT STANDBY within the next 6 hours,

c. Specification 3.0.4 is not applicable to this ree.uirement.

                              $URVEILLANCE 3EQUIREMENTS 4.6.5.1.1 Each hydrogen analyzer shall be demonstrated OPERABLE at least bi-weekly on a STAGGERED TEST BASIS by drawing a sample from the Weste Gas System through the hydrogen analyzer.

4.6.5.1.2 Each hydrogen analyzer shall be demonstrated OPERABLE at least once per 92 days on a $TAGGERED TEST BA$!$ by performing a CHANNEL CALIBRATION using sample gases in accordance with manufacturers' recomendations. CALVERT CLIFFS - UNIT 2 3/4 6 20 Amendment No. 189 l 9.), I or 1

DISCUSSION OF CIIANGES SECTION 3/4.6.5.1 - IIYDROGEN ANALYZERS ADMINISTRATIVE 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 1432.11owever, the additional information does not change the intent of the current Technical Specifications. The reformatting, renumbering, and icwording process involves no technical changes to existing Specifications. I I CALVERT CLIFFS - UNITS I & 2 3/4.6.5.1-1 Revision 7

C7 f 2.4 6. /

h M O *TI) S E Cri t ed 27 f .6 3/4 h,I CONTAIISIENT SYSTEMS 3/4.6.6 PENrTRATION ROOM EXHAUST AIR FILTRATION SYSTEM LIMITI M CONDITION FOR OPERATION - 3.6.6.1 Two independent containmant penetration room exhaust air filter trains shall be OPERABLE. APPLICABILITY: MODE $ 1, 2, and 3. g112(: With one containment penetration room exhaust air filter train inoperable, restore the inoperable train to OPERABLE status within 7 days or be inthe within at least MT STnNDtY following 30 hours. within the next 6 hours and in COLD SHTD06Al SURVEILLANCE REQUIREMENTS 4.6.6.1 Each containment penetration room exhaust air filter train shall be demonstrated OPERABLE:

a. At least once per 31 days on STAGGERED TEST SA315 by initiating, from the control room, flow through the HEPA filter and charcoal adsorber train and verifying that the train operates for at least 15 minutes.

i

b. At least once per 18 months or (1) after any structural '

i maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ; ventilation zone comunicating with the system by:

1. Verifying that the charcoal adsorbers remove 199% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with Regulatory Positions C.S.a and C.S d of Regulatory Guide 1.52. Revision 2. March 1978, while operating the filter train at a flow rate of 2000 cfm

                       + 10%.

CALVERT CLIFFS - UNIT 1 3/4 6-26 Amendment No. 212 l e- \*

Cn 3. G. (.. I MHGO % .cgem 4 37 f '

b. $

3/4.6 CONTAllstENT SY$1Dt3

                                       $URVEILLANCE REQUIRDIENTS (Continued)

2. Vertfying that the NEPA filter banks remove 2 9% of the D0P when they are tested in-place in accordance with Regulatory Positions C.S.a and C.S.d of Regulatory Guide 1.52 Revision 2. March 1978, while operating the filter train at a flow rate of 2000 cfm i 1M. .

3. I Verifying within 31 days after removal that a laboratory analysts of a representative carbon sample obtained from an adsorber tray or fram an adsorber test tray in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2. March 1978, demonstrates a removal efftetency of 2 90% for radioactive methyl todine when the sample is tested in accordance with ANSI N510-1975 (30*C. 95% R.H.). 4. t Ver!fying a system flow rate of 2000 cfm i 10% during system t operation when tested in accordance with ANSI N510-1975.

c. After every 720 hours of charecal adsorber operation by:

Verifying within 31 nys after removal that a laboratory analysis of a representative carbon sample obtained from an adsorber tray or from an adsorber test tray in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2. March 1978, demonstrates a removal efficiency of 2 90% for radioactive methyl lodine when the sample is tested in accordance with ANSI H510-1975 (30*C, 95% R.H.). Subsequer. to reinstalling the adsorber tray used for obtaining the carbon sample, the filter train shall be demonstrated OPERABLE by verifying that the charcoal adsorbers remove 199% of the halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with Regulatory Positions C.S.a and C.S.d of Regulatory Guide 1.52. Revision 2. March 1978, while operating the ventilation system at a flow rate of 2000 cfm i 10%. CALVERT CLIFFS - UNIT I 3/4 6-27 Amendment No. 212 l py 2 J '3 h

7 . - - 673 .7. le (= l M4Y60 % .tGe m 1 37 3/4.6 CONTAllffENT SYSTDIS bd g SURVE!LLAllCE REQUltDIENTS (Centineed) fd. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters oand charcoal adsorber banks is < 6 inches Water Gauge while 11M. perating the filter train at a flow rate,of 2000 cfm

2. Verifying that the filter train starts on Containment Isolation Test Stenal.

e. After each couplete or partial replacement of a HEPA filter bank vertfying that the HEPA filter banks remove > 99% of the DOP n they are tested in place in accordance witi Regulatory Positions C.S.a and C.5.c of Regulatory Guide 1.52. Revision 2 March 1978, while operating the filter train at a flow rate of 2000 cfm i 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verif ing that the charcoal adsorbers remove t 99% of a halogenated drocarbon refrigerant test gas when they are tested in-place in accordance with Regulator of Re ulatory Guide 1.52 Revision 2.y Positions C.S.a and C.S.d -

the f iter train at a flow rate of 2000 cfa i 10%. March 1978, while operating g. After maintenance affecting the air flow distribution by testing in- lace and verifying that the air flow distribution is uniform wit in i 20% of the average flow per unit when tested in accordance with the provisions of Section S of ' Industrial Ventilation

and Section 8 of ANSI N5101975.

t CALVERT CLIFFS - UNIT 1 3/4 6-28 Amendment No. 212 l 1 h

C Y.5 340/ % MNFD 'to sFr1 iou 3, 7

                                                                                       \  A.I        &

b/4.6 CONTAINMENT SYSTEM $ 3/4.6.6 PENETRAffpN ROOM EXHAUST A]W FILTRATION g3 LIMITING CON 0! TION FOR OPERATION 3.6.6.1 Two independent containment penetration room exhaust air filter trains shall be OPERABLE. APPLICABILITY: MODES 1, 2, and 3. AC119 tit With ont containment penetration room exhaust air filter train inoperable, restore the inoperable train to OPERABLE status within 7 days or be in within atfollowing the least NOT 30STANDsY hours. within the next 6 hours and in COLS $NiffDOWN 1 SURVEILLANCE REQUIREMENTS 4.6.6.1 Each containment penetration room exhaust air filter train shall be demonstrated OPERABLE:

a. At least once per 31 days on STAGGERED TEST BA5!$ by initiating, from the control room, flow through the HEPA filter and charcoal adsorber 15 minutes, train and verifying that the train operates for at least

b. At least once per 18 months or (1) after any structural maii.tenance on the HEPA filter or charcoal adsorber housings, or (2) following painting fire or chemical release in any ventilation zone consnun,icating w.*.h the system by:

1. Vertfying that the charcoal adsorbers remove 199% of a j

halogenated hydrocarbon refrigerant test gas when they are

tested in place in accordance with Regulatory Pcsttions C.5.a and C.S.d of Regulatory Guide 1.52 Revision 2. March 1978, while operating the filter train at a flow rate of 2000 cfm i 10%. w l CALVERT CLIFFS - UNIT 2 3/4 6 22 Amendment No. 189 l pc.g \of Z 1 1

CD 1. k L l Mo4 E O 'f o Wet t o bJ gy

h. [ 3/4.6 CONTAIMENT SY1 tdt $ l

     $URYt1LLANCE REQUIREMENTS (Continued)

2. Verifying that the HEPA filter banks remove t 99% of the DOP when they are tested in. place in accordance with Re Positions C.S.a and C.S.d of Regulatory Guide 1.52.gulatory Revision 2. March 1978, while operating the filter train at a flow rate of 2000 cfm i 10%.

               .t .

Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained from an adsorber tray or from an adsorber test tray in accordatect with Regulatory Position C.6.b of Regulatory Guide 1.52 Revision 2. March 1978, demonstrates a removal efficiency of 2 90% for radioactive methyl iodine when the sample is tested in accordance with AN$1 N5101975 (30*C, 95% R.H.). 4. Verifying a system flow rate of 2000 cfm i 10% during system operation when tested in accordance with ANSI N5101975.

c. After every 720 hours of charcoal adsorber operation by:

Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained from an adwrber tray or from an adsorber test tray in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2. March 1978, demonstrates a removal efficiency of 2 90% for radioactive methyl iodine when the sample is tested in accordance with ANSI N5101975 (30'C. 95% R.H.). k-l CALVERT CLIFFS - UNIT 2 3/4 6 23 Amendment No. 189 l py '2 J 3 i i

CT3 3.6.6.) l mt:0 7o SFeriou 3, 7 3/4.6 CONTAllMENT SYSTEns AJ & I SURVEILLANCE REQUIREMENTS (Continued) Subsequent to reinstalling the adsorber tray used for obtaining the carbon sample, the filter train shall be demonstrated OPERABLE by verif ing that the charcoal adsorbers remove 1 99% of the halogenated h drocarbon refrigerant test gas when they are tested in-place in accordance with Re ulatory Positions C.S.a and C.5.d of Regulatory Guide 1.52. Revis on 2. March 1978, while operating the ventilation system at a flow rate of 2000 cfm 11M.

d. At least once per 18 months by: 1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is < 6 inches Water Gauge while operating the filter train at a flow rate of 2000 cfm i 10%.; 2. Verifying that the filter train starts on Containment Isolation Test Signal.; e. Af ter each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove > 99% of the 00P when they are tested in-place in accordance witE Regulatory Positions C.5.a and C.S.c of Regulatory Guide 1.52. Revision 2 March 1978, while operating the filter train at a flow rate of 2000 cfm i 10%.; f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove 199% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with Regulatory Positions C.S.a and C.S.d of Reculatory Guide 1.52. Revision 2. March 1978, while operating the filter train at a flow rate of 2000 cfm i 10%.; g. After maintenance affecting the air flow distribution by testing in-place and verifying that the air flow distribution is unifom within i 20% of the average flow per unit when tested in accordance with the provisions of Section 9 of " Industrial Ventilation

and Section 8 of ANSI N5101975.

CALVERT CLIFFS - UNIT 2 3/4 6-24 Amendment No. 189 l

                                                                    .y            o 3

DISCUSSION OF CHANGES SECTION 3/4.6.6 - PENETRATION ROOM EXHAUST AIR FILTRATICN SYSTEM ADMINISTRATIVE CHANGES 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. However, the additional information does not change the intent of the , current Technical Specifications. The reformatting, renumbering, and rewording process j involves no technical changes to existing Specifications. e 1 CALVERT CLIFFS - UNITS ! & 2 3/4.6.6-1 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 - CONTAINMENT SYSTEMS _ _ AD311NISTRATIVE CHANGES Baltimore Gas and Electric Company (BGE), Calvert Cliffs Units I and 2, is converting to the improved Technical Specifications (ITS) as outlined in NUREG 1432, " Standard Technical Specifications, Combustion Engineering Plants." The proposed chuges involve reformatting, renumbering, and rewording of Technical Specifications, with no change in intent, and are the incorporation of current plant practices consistent with NUREG 1432. These changes, since they do not involve technical changes to the Technical Specifications or current plant practices, are administrative. Below is the No Significant Hazards Consideration for the conversion of this Sectior. 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. 1, Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the existing Technical Specifications, along with the incorporation or current plant practices and other changes, as discussed above, in order to be consistent with NUREG-1432. These changes involve no technical changes to the existing Technical Specifications. Specifically, there will be no change in the requirements imposed on Calvert Cliffs due to these changes. Thus, the changes are administrative in nature and do not impact initiators of analyzed cuents. 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 consequen..es of an accident previously evaluated. 2, Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the existing Technical Specifications, along with the incorporation of current plant practices and other changes, as discussed above, in order to be consistent with NUREG 1432. The 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. The proposed changes will not introduce any new accident initiators. Therefore, the changes do not create the possibility of c new or different kind of accident from any accident paviously evaluated.

3. Does this change involve a significant reduction in margin of safety?

f The proposed changes involve re'ormatting, renumbering, and rewording of the existing Technical Specifications, along with the incorporation of current riant practices and other changes, as discussed above, in order to be consistent with WUREG 1432. The changes are administrative in nature and will not involve any technical changes. The changes will not reduce a margin of safety because it has no impact on any safety analysis assumptions. Therefore, the changes do not involve a significant reduction in a margin of safety. TECHNICAL CHANGES - MORE RESTRICTIVE Baltimore Gas and Electric Company, Calvert Cliffs Units 1 and 2. is converting to the ITS as outlined in NUREG 1432, " Standard Technical Specifications, Combustion Engineering Plants." The proposed CALVERT CLIFFS - UNITS 1 & 2 3.6-1 Revision 7

NO SIGNIFICANT IIAZARDS CONSIDERATIONS

                               - SECTION 3.6; CONTAINMENT SYSTEMS change:, involve adding more restrictive requirements to the exisCng Technical Specifications t y either making current requirements more stringent or by adding new requirements which currently do not exist.

Below is the No Significant llazards Consideration for the conversion of this Section 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.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes provide more stringent requirements than previously existed in the Technical Specifications. Each change was evaluated and it was determined that these more stringent requirements do not result in operation that will increase the probability ofinitiating an analyzed event if anything, the new requirements may decrease the probability or consequences ! of an analyzed event by incorporating the more restrictive changes discussed above. The , proposed changes do not alter assumptions relative so mitigation of an accident or transient. The more restrictive requirements continue to ersure process variables, structures, systems, and components are maintained consistent with the safety analyses and licensing basis. 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 accident previously evaluated?

The proposed changes provide more stringent requirements than previously existed in the Technical Specifications. The 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. The proposed changes will not introduce any new accident initiators. The changes do impose e different requirements. However, these changes are consistent with the assumptions in the safety analyses and licensing basis. Therefore, the 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?

The proposed changes provide more stringent requirements than previously existed in the Technical Specifications. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on the margin of safety, The changes provide additional restrictions which may enhance plant safety. The changes maintain requirements within the safety analyses and licensing basis. As such, no question of safety is involved. Tlierefore, the changes do not involve a significant reduction in a margin of safety. TECHNICAL CHANGES - MOVEMENT OF INFORMATION TO LICENSEE-CONTROLLED DOCUMENTS 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 changes involve moving details (engineering, procedural, etc.) out of the Technical Specifications and into a licensee-controlled document. These changes, since detail is being removed, are less restrictive. CALVERT CLIFFS - UNITS 1 & 2 3.6-2 Revision 7

4 NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 - CONTAINMENT SYSTEMS Below is~ the No Significant llazards Consideration for the conversion from this section 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.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

, The proposed changes move details from the Technical Specifications to a licensee-controlled i document, ne changes do not result in any hardware chLnges or changes to plant operating

,                   practices. The details being removed from the Technical Specifications are not assumed to be an initiator of any analyzed event. The licensee-controlled document containing the removed Technical Specification details will be maintained using the provisions of the plant document

' change control process, and is subject to the change control process in the Administrative Controls section of the Technical Specifications. Since any changes to the relocated details will be evaluated per the plant documem change control process,. no increase (significant or insignificant) in the probability of an accident previously evaluated will be allowed. The details which are being moved from the Technical Specifications are not assumed to mitigate accidents 1 or transients. Since any changes to the relocated details will be evaluated per the plant document change control process, no increase (significant or insignificant) in the consequences of an accident previously evaluated will be allowed. Therefore, there will be no significant increase in the consequences of accidents previously evaluated. Therefore, the changes 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 accident previously evaluated?

The proposed changes move detail from the Technical Specifications to a licensee-controlled document. The change will not involve a signifi ant 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. The changes will not impose different requirements, and adequate control ofinformation will be maintained. The changes will not alter i assumptions made in the safety analysis and licensing basis. Therefore, the changes will not

)'

cr: ate the possibility of a new or different kind of accident fre c. any acciderd previously evaluated.

3. Does this change involve a significant reduction in the margin of safety?

The proposed changes move detail 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 detail to be moved from the Technical Specifications to a licensee-controlled document is the same as the existing Technical i Specifications. Since any future changes to this licensee-controlled document will be evaluated per the requirements of the plant document 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 submittal, the NRC can audit the plant document change control process. CALVERT CLIFFS - UNITS 1 & 2 3.6-3 Revision 7

l

                        'NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 - CONTAINMENT SYSTEMS Therefore, the margin of safety lost by not requiring NRC prior approval is not significant, Also, since the proposed change is 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 invalves 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 Specifications changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion. 3.6.1 Chanee L.1

1. Does the change involve a significant increase in the probability or con equences u! an accident previously evaluated?

The proposed change increases the Completion Time to restore the containment to Operable status from immediately to one hour when the containment is inoperable due to its structural integrity (containment tendons and structure). This change will not significantly increase the probability of an accident previously evaluated. The containment is not an initiator of any analyzed event. The consequences of an accident are not significantly increased. Inoperability of the containment could lead to an increase in the amount of radioactive material released following a severe accident, which is an increase in consequences. However, the type of degradation which would be identified by the surveillances while the reactor is operating, such as tendon failures, would not lead to a significant increase in the consequences of an accident, in addition, the consequences of these types of containment inoperabilities would not lead to consequences more significant than other safety function losses, such as an inoperable Emergency Core Cooling System, and those inoperabilities allow one hour to prepare for a unit shutdown. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The proposed change increases the Completion Time to restore the containment to Operable status from immediately to one ho .c when the containment is inoperable due to its structural integrity (containment tendons and structure). This change does not involve 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. 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 I & 2 3.6-4 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 _ CONTAINMENT SYSTEMS

3. Does the change involve a sir,nificant reduction in a margin of safety?

The proposed change increwes the Completion Time to restore the containment to Operable status from immediately te one hour when the containment is inoperable due to its structural integrity (containment tendons and structure). The margin of safety is not significantly affected because the one-hour Completion Time could poss;bly prevent a plant shutdown if the failure l was identified as one that would not significantly increase the chance of an event occurring I which could increase the consequences of an event. Also, the one hour would provide an opportunity for operations to prepare for a possible impending shutdown. The one hour allowed to restore containment prior to initiating a shutdown is similar to the requirements allowed by Limiting Condition for Operation (LCO) 3.0.3. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.6.2 Change L.1 1.~ Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change increases the time to restore an inoperable air lock door to Operable status (when not due to a gasket being inoperable), and to restore an inoperable interlock mechanism to Operable status from 24 hours to no time limit, as long as the Operable air lock door is maintained closed and locked. This change will not significantly increase the probability of an accident previously evaluated. He containment air lock is not an initiator of any analyzed event. The consequences of an accident are not significantly increased. Allowing one air lock to be inoperable for an extended period of time is appropriate because one Operable air lock door maintained closed provides a leak tight barrier from the containment to the outside atmosphere. This will ensure that in case of an event which pressurizes containment, radioactive material will not be released via the containment air lock. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The proposed change increases the time to restore an inoperable air lock door to Operable status (when not due to a gasket being inoperable), and to testore an inoperable interlock mechanism to Operable status from 24 hours to no time limit, as long as the Operable air lock door is maintained closed and locked. This change does not involve 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. 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 the change involve a significant reduction in a margin of safety?

The proposed change increases the time to restore an inoperable .tir lock door to Operable status (when not due to a gasket being inoperable), and to restore an inoperable interlock mechanism to Operable status from 24 hours to no time limit, as long as the Operable air lock door is maintained closed and locked. The margin of safety is not significantly affected by this change because the Operable air lock door is required to be maintained closed. By maintaining the CALVERT CLIFFS - UNITS 1 & 2 3.6-5 Revision 7

l NO SIGNIFICANT HAZARDS CONSIDERATIONS i SECTION 3.6 - CONTAINMENT SYSTEMS Operable air lock door closed, a leak tight barrier separates the containment from the outside atmosphere. This will prevent release of radioactive material through the air lock in case of an , event which pressurizes the containment. Herefore, the proposed change does not involve a l significant reduction in a margin of safety. 3.6.2 Change L.2

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change increases the time to restore an inopenble air lock door to Operable status

(when due to a gasket being inoperable) from seven days to no time limit, as long as the Operable air lock door is maintained closed and locked. His change will not significantly increase the probability of an accident previously evaluated, he containment air lock is not an initiator of any analyzed event. The consequences of an accider.t are not significantly increased.

Allcwing one air lock to be inoperable for an extended period of time is appropriate because one Operable air lock door maintained closed provides a leak tight barrier from the containment to the outside atmosphere. His will ensure that in case of an event which pressurizes containment, radioacti"e tnaterial will not be released via the containment air lock. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change does not involve a significant increase in the probsbility 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 evaluated?

The proposed change increases the time to restore an inoperable air lock door to Operab.e status (when due to a gasket being inoperable) from seven days to no time limit, as long as the Operable air lock door is maintained closed and locked. This change does not involve 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. The proposed change viill 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 the change involve a significant reduction in a margin of safety?

The proposed change increases the time to restore an inoperable air lock door to Operable status (when due to a gasket being inoperable) from seven days to no time limit, as long as the Operable air lock door is maintained closed and locked. The margin of safety is not significantly affected by this change because the Operable air lock door is required to be maintained closed. By maintaining the Operable air lock door closed, a leak tight barrier separates the containment from the outside atmosphere. This will prevent release of radioactive material through the air lock in case of an event which pressurizes the containment. Therefore, the proposed change does not involve a significant reducthn in a margin of safety. 4 3.6.2 Channe L3

!    1.      Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change allows an exemption to the requirement to maintain the Operable air lock dcor closed by allowing it to be opened for entry and exit to perform repairs to the inoperable air CALVERT CLIFFS - UNITS 1 & 2 3.6-6 Revision 7

NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.6 - CONTAINMENT SYSTEMS lock. This change will not significantly increase the probability of an accident previously evaluated. The containment air lock is not an initiator of any analyzed event. This change is acceptable because of the short time period during which the containment boundaiy is not intact and the low probability of an event that would pressurize containment during this period, ne consequences of an accident are not significantly increased. The Operable air lock door will be ooened for only a short period of time to allow entry and exit into the air lock. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The proposed change allows an exemption to the requirement to maintain the Operable air lock door closed by allowing it to bc opened for entry and exit to perform repairs to the inoperable air lock. This change does not involve 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 ;hange 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 the change involve a significant reduction in a margin of safety?

The proposed change allows an exemption to the requirement to maintain the Operable air lock door closed by allowing it to be opened for entry and exit to perform repairs to the inoperable air lock. The margin of safety is not significantly affected by this change because the Operable air lock door is only allowed to be opened for entry and exit into the air lock when it is not practicable to access the air lock by entering containment via the other air lock. Requiring the air lock to be opened only for entry and exit ensures that the air lock door is opened for only a short period of time, and the likelihood of an event occurring during this short priod is remote.

Also, the air lock is only being opened to perform repairs on the inoperable door, which when repaired provides an additional barrier separating containment from the outside atmosphere. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.6.2 Chanoe id I. Does the change involve a significant increase in the probability or_ consequences of an accident previously evaluated? The proposed change allows an exemption to the requirement to maintain the Operable air lock door closed (except for repairing the air lock) by allowing it to be opened for entry and exit for seven days, when both air locks are inoperable, to perform Technical Specification Surveillance Requirements (SRs), Required Actions, a< well e, other activities (Technical Specification or non-Technical Specification related). This change will allow enough time to perform activities to support continued plant operation prior to having to maintain the air lock closed. This change will not significantly increase the probability of an accident previously evaluated. The containment air lock is not an initiator of any analyzed event. The consequences of an accident are not significantly increased. The Operable air lock door will be opened for entry and exit and only for a period of seven days after the second air lock is determined inoperable. The air lock ; will be opened for only a short period of time to allow entry and exit into the air lock Should an accident occur while the air lock is open, the amount of radioactive material that would be I released through the inoperable door until the door is closed would not be significant. This CALVERT CLIFFS - UNITS 1 & 2 3.6-7 Revision 7 l

NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3c6 - CONTAINMENT SYSTEMS change will not significantly affect the ass,mptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The proposed change allows an exemption to the requirement to maintain the Operable air lock c'oor closed (except for repairing the air lock) by allowing it to be opened for entry and exit for seven days, when both air locks are inoperable, to perform Technical Specification SRs, Required Actions, as well as other activities (Technical Specification or non-Technical Specification related). This change will allow enough time to perform activities to support continued plant operation prior to having to maintain the air lock closed. This change does not involve 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. 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 the change involve a significant reduction in a margin of safety?

The proposed change allows an exemption to the requirement to maintain the Operable air lock door closed (except for repairing the air lock) by allowing it to be opened for entry and exit for seven days, _ when both air locks are inoperable, to perform Technical Specification SRs, Required Actions, as well as other activities (Technical Specification or non Technical Specification related). This change will allow enough time to perform activities to support continued plant operation prior to having to maintain the air lock closed. The margin of safety is i not sign:ficantly affected by this change because the air locks are only allowed to be opened for entry and exit for seven days. The seven days is a short period of time and the likelihood of an event occurring during the period the door is open is remote. This change also allows activities to be performed to support continued plant operation instead of not being able to perform

        - Technical Specification SRs or Actions, or other activities which may require a plant shutdown, which is a transient. Therefore, the proposed change does not involve a significant reduction in a margin of.aiety.

3.6.2 Chance L3

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change decreases the Frequency for verifying the air lock interlock mechanism from 6 months to 24 months. This change will not significantly increase 1% probability of an accident previously eveluated. The containment air lock is not an initiator of any antlyzed event. The consequences of an accident are not significantly increased. The test is still performed at a , Frequency that will provide reasonable assurance that the interlock mechanism, which prevents both air lock doors from being opened at the same time, is Operable. This change will allow the test to be performed under conditions that apply during a plant outage, and decreases the potential for a loss of containment operability while the reactor is at power, due to faili,g the test. This change is appropriate given that the interlock is not chellenged during use of t.ie air locks. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change does not involve a significant increase in the probability or comequence of an accident previously evaluated. CALVERT CLIFFS - UNITS 1 & 2 3.6-8 Revision 7

NO SIGNIFICANT !IAZARDS CONSIDERATIONS SECTION 3.6 o CONTAINMENT SYSTEMS

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

ne proposed change decreases the Frequency for verifying the air lock interlock mechanism from 6 months to 24 months. This changc does not involve 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. 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 the change involve a significant reduction in a margin of safety?

The proposed change decreases the Frequency for verifying the air lock interlock mechanism from 6 months to 24 months. The margin of safety is not significantly affected because the Surveillance is still performed at a Frequency that proves the containment air lock interlock mechanism is Operable. Also, the SR will be performed under conditions that apply during a plant outage and reduces the potential fer loss of containment Operability duri.ig power operation. Therefore, the proposed change does not insolve a significant reduction in a margin of safety. Afi.3 Chanoe L.1

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change adds an additional method (use of a check valve veith flow through the 4 valve secured) for isolating a penetration when one containment isolation valve (CIV) is inoperable. This change will not significantly increase the probability of ar. accident previously evaluated. The CIVs are not initiators of any analyzed event. The consequences of an accident are not significantly increased. One CIV for the affected penetration is still Operable. This valve, along with the check valve with flow through the valve secured, is as effective in isolating the penetration as a secured automatic valve, a closed manual valve, or a blind flange. The check valve with flow through the valve secured will perform the intended safety function ofisolating the penetration. This change will not significantly affect the assumpti< ns relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The proposed change adds an additional method (use of a check valve with flow through the valve secured) for isolating a penetration when one CIV is inoperable. This change does not involve 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. The proposed change will not introduce any new accident initiatois. Therefore, 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 adds an additional method (use of 3 check valve with flow through the valve secured) for isolating a penetration when one CIV is inoperable. The margin of safety is I l CALVERT CLIFFS - UNITS I & 2 3.6-9 Revision 7

NO SICNIFICANT HAZARI)S CONSil)ERATIONS SECTION 3.6 . CONTAINMENT SYSTFMS not significantly affected because the check valve with flow through the valve secured, along with the one Operable CIV for the penetration, will effectively isolate the penetration. Thus, the safety function of isolating the penetration will be accomplished. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.63 Chamme 1J 1, 1)oes the change involve a significant increase in the probability or consequences of an accident previously evaluated? l The proposed change v ill increase the Completion Time to isolate the penetration with a closed and deactivated automatic valve, a closed manual valve, or a blind flange for a penetraticn in a i closed system when the one required isolation valve is inopcrable, from 4 hours to 72 hours. His change will not significantly increase the probability of an accident previously evaluated. 1hc CIVs are not initiators of any analyzed event. This change will not significantly ircrease the consequences of an accident because of the reliability of the closed system to act as a penetration isolation boundary. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. 1herefore, the change does not invoke a significant increase in the probability or consequence of an accident previously evaluated.

2. I)oes the change create the possibility of a nev/ or different kind of accident from any accident previously evaluated?

The proposed change will increase the Completion Time to isolate the penetration with a closed and deactivated automatic valve, a closed mar,ual valve, or a blind flange fo a penetration in a closed system when the one required isolation valve is inoperabic, from 4 hours to 72 hours. This change does not involve a significant change in the design or operation of t!.e plant. No hardware is being added to the plant as part of the proposed change, rhe proposed change will not introduce any new accident initlators. Therefore, the chang,; does not create the possibility of a new or difTerent kind of accident from any accident previously evaluated.

3. 1)oes the chante involve a significant reduction in a margin of anfety?

The proposed change will increase the Completion Time to isolate the penetration witn a close<l and deactivated automatic valve, a closed manual valve, or a blind flange for a penetration in a closed system when the one required isolation valve is inoperable, from 4 hours to 72 hours. The margin of safety is not significantly affected because the closed system is effective as a penetration isolation barrier. The stability of the cloud system, and hence its reliability, contribute to it being an efficient isolation barrier. Thercibo, the propesed change does not involve a significant reduction in a margin of safety. 3.63 Channe L3 Not used. l

    ,tfn,1Channe L.4 1.

Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The propoel change will add an allowance that containment isolation manual valves and blind flanges that are locked, sealed, or otherwise secured in position do not have to be verilled closed. CALVERT CLIFFS UNITS I & 2 3.6 10 Revision 7

NO SICNIFICANT HAZARDS CONSIDERATIONS SECTION 34. CONTAINMENT SYSTEMS nis change will not signl0cantly increase the probability of an accident previously evaluated, ne CIVs are not initiators of any analyzed event. His change will not signincantly increase the consequences of an accident plant administrative controls are in place to provide assurance that the valves and blind fianges that are verified locked, sealed, or otherwise secured in position will not be inadvedently opened. Rus, the likelihood of a valve or blind fiange that was previously verified to be locked, scaled, or otherwise secured in the closed position being inadvertently opened is small. 313 change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The proposed change will add an allowance that contalament isolation manual valves and blind fianges that are locked, scaled, or othenvise secured in position do not have to be verified closed. This change does not involve 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. The proposed change will not introduce any new accident initiators. Therefore, the change does not create the possib!:ity l nia 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 will add an allowance that containment isolation manual valves and blind Danges that are locked, scaled, or othenvise secured in position do not have to be verifled closed. ne margin of safety is not significantly affected because plant administrative controls provide assurance that these valves and blind fianges will not be inadvenently opened. He administrative controls provide reasonable assurance that the valves and blind fianges will not be inadvertently opened. Derefore, the proposed change does not involve a significant reduction in a margin of safety. 163 Ch==ce L,5

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated 7 De proposed change will allow the containmert vent to be opened for air quality considerations, nis change will not signincantly increase the probability of an accident previously evaluated.

The containment vents are not initiators of any analyzed event. His change will not significantly increase the consequences of an accident. Opening the containment vent for air quality control considerations is acceptable because the containment vent is capable of closing in the environment during a loss-of coolant accident (LOCA). This change will not significantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated?

The propond change will allow the containment vent to be opened for air quality considerations.

'                         This change does not involve 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. The proposed change will        ,

c CALVERT CLIFFS UNITS I & 2 3.6 11 Revision i

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 o CONTAINMENT SYSTEMS not introduce any new accident initiators. Therefore, the change hs not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the change involve a sissificant reduction in a martin of safety?

ne proposed change will allow the containmut vent to be opened for air quality considerations. The margin of safety is not significantly affected because allowing the containment vent to be opened for air quality control will not prevent the vents from being closed during a LOCA. l Also, proper air quality in containment is critical for safe personnel entry. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

 ,M1Clianse L6 Not used.

l 16.3 Ch===e L7

1. Does the change involve a significant lneresse in the probability or consequences of an accident previously evaluated? l The proposed change adds a Note which allows the closure devices (valves and blind Danges)in l high radiation areas to be verified closed by administrative means. This change will not affect the probability of an accident. The CIVs are not initistors of any analyzed event. The change will not significantly alTect the consequences of an accident. The chances of isolation devices being out of position in high radiation areas is small once the isolation device is verified closed, because access is limited to these areas. 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.

2. Does the change create the possibility of a new or different kind of accident from any previously erslunted?

The proposed change adds a Note which allows the closure devices (valves and blind Danges)in l high radiation areas to be verified closed by administrative means. This change will not affect the probability of an accident. This change will not physically alter the plant (no new or different type of equipment will be installed). The change does not require any new or unusual operator actions. 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 sigalileant reduction in margin of safety?

He proposed change adds a Note which allon the closure devices (valves and blind flanges)in l high radiation a*cas to be verified closed by administrative means. This change will not affect the probability of an accident. The margin of safety is not significantly affected by this change. Access to high radiation areas is restricted, therefore, the likelihood of these valves being remotely mispositioned is small. Also, by allowing these valves to be verified closed by administrative means will keep radiatirm exposure as low as reasonably achievable. Therefore, the change does not involve a significant utiuction in a margin of safety. CALVERT CLIFFS . UNITS 1 & 2 3.6 12 Revision 7 t

NO SIGNIFICANT IIAZARDS CONSIDERATIONS SECTION 3.6 CONTAINMENT SYSTEMS

                  ,L63 Change LB

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

He proposed change will increase the allowed outage time to close an open containment purge

supply and exhaust isolation valve from one hour to four hours. This change will not signincantly affect the probability of an accident. The containment purge system is not an initiator of any analyzed event. This change will not significantly affect the consequences of an accident. The valves will continue to receive an automatic closure signal (containment blation, safety injection, and high radiation) during an accident. Also the valves are verined closed and power to the solenoid removed prior to entering the Modes of Applicability and performed i

monthly thereafler. His change will not affect the assumptions relative to the mitigation of accidents or transients. Herefore, this change does not involve a signincant increase in the probability or consequence of an accident previously evaluated. d

2. Does the change create the possibility of a new or different kind of accident from any j previously evaluated?

, The proposed change will increase the allowed outage time to close an open containment purge supply and exhaust isolation valve from one hour to four hours. This change does not involve 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. ne proposed change will not introduce any new accident l initiators. Therefore, the change does not create the possibility of a new or different kind of accident from any accident previously evaluated. 4

3. Does this change involve a significant reduction in margin of safety?

The proposed change will increase the allowed outage time to close an open containment purge i supply and exhaust isolation valve from one hour to four hours. His change will not affect the function of the containment purge supply and exhaust isolation valves during an accident which , is to close on a containment isolation, safety injection, or high radiation signal. Hese valves are also verined closed with power removed prior to entering the Modes of Applicability, j Herefore, the proposed change does not involve a signincant reduction in a margin of safety. 163 Change L9

1. Does the change involve a significant increase in the probability or consequences of an i accident previously evaluated?

! The proposed change will change the allowed outage time to repair a containment purge supply and exhaust isolation valve from 24 hours to only requiring the salve to be maintained closed. ilowever, the containment leakage requirements are still required to be within limits. This change will not significantly affect the probability of an accident. He containment purge system is not an initiator of any analyzed event. His change will not significantly affect the consequences of an accident. ne initial accident conditions with respect to containment leakage will be preserved because the containment leakage requirement is required to be within limits. This change will not affect the assumptions relative to the mitigation of accidents or transients. Therefore, this change does not involve a significant increase in the probability or consequence of an accident previously evaluated. 1 't CALVERT CLIFFS UNITS 1 & 2 3.6-13 Revision 7

NO SIGNIFICANT llAZARDS CONSIDERATIONS SECTION 3.6. CONTAINMENT SYSTEMS

2. Does the change create the possibility of a new or different klad of accident from any previously evaluated?

De proposed change will increase the allowed outage time to repair a containment purge supply and exhaust isolation valve from 24 hours to only requiring the valve to be maintained closed, llowever, the containment leakage requirements are still required to be within limits. This change does not involve 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 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?

                               %e proposed change will increase the allowed outage time to repair a containment purge supply and exhaust isolation valve from 24 hours to only requiring the valve to be maintained closed, llowever, the containment leakage requirements are still required to be within limits. This will ensure that the initial conditions of the accident analyses are maintained. If the containment leakage requirements are not within limits the plant is required to shutdown if the limits are not restored within one hour. Also good operating practice and engineering judgment will ensure that excessive leakage from any valve will be renaired as soon as practicable. Therefore, the proposed changes does not involve a significant reducti0n in a margin of safety.

3.6.3 Change LIO

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The requirement to demonstrate each containment isolation valve Operable by performance of a cycling test and verification of isolation time prior to returning the valve to service aRet maintenance or repair has been deleted. This proposed change does not result in any hardware or operating procedure changes. The current requirement to confirm containment isolation valve OPERAlllLITY prior to returning the valve to service aRer maintenance, repair, or replacement work is not assumed in the initiation of any analyzed event. This requirement was specified in the current Technical Specifications to ensure the OPERAlllLITY of a primary containment isolation valve was positively verified following repair, maintenance, or replacement. The deletion of this explicit requirement from the Calvert Cliffs ITS is considered administrative, improved Technical Specification SR 3.0.1 requires the appropriate SR to be performed to demonstrate OPERAlllLITY after restoration of a component that causes the SR to be failed, lu this case, ITS SR 3.0.1 would require ITS SR 3.6.3.4 to be performed. This SR ensures the isolation times of the affected primary containment isolation valves are within limits. As a result, the accident consequences are unaffected by this change. Therefore, this change will 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 accident previously evaluated?

The requirement to demonstrate cach containment isolation valve Operable by performance of a cycling test and verification of isolation time prior to returning the valve to service after maintenance or repair has been deleted. The possibility of a new or different kind of accident CALVERT CLIFFS - UNITS 1 & 2 3.6-14 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6. CONTAINMENT SYSTEMS from any accident previously evaluated is not created because the change does not introduce a new mode of plant operation and does not involve physical modification to the plant.

3. Does the change involve a significant reduction in a margin of safety?

The requirement to demonstrate each containment isolation valve Operable by performance of a cycling test and verification of isolation time prior to returning the valve to service after maintenance or repair has been deleted. The deletion of the explicit requirement to verify primary containment isolation valve OPERABILITY prior to returning the valve to service aner maintenance, repair or replacement work is considered administrative. ITS SR 3.0.1 requires the appropriate SR to be performed to demonstrate OPERABIL11Y after restoration of a component l that causes the SR to be failed. in this case, ITS SR 3.0.1 would require SR 3.6.3.4 to be performed. This SR requires verification that the isolation times of the alTected primary l containment isolation valves are within limits. As a result, the existing requirement to verify primary containment isolation valve isolation times are within limits following repair, maintenance, or replacement is maintained. Herefore, this deletion does not involve a significant reduction in a margin of safety. Afi3 ChamaeLil

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

Th!s change allows a centainment penetration flow path that has been isalated in accordance with an Action to be opened under administrative controls. Containment isolation is not considered an initiator of any previously analyzed accident. Therefore, this change does not significantly increase the probability of such accidents. Although containment isolation is considered in the mitigation of the consequences of an accident, the administrative controls provide acceptable compensatory actions to assure the penetration is isolated in the event of an accident. Therefore, the consequences of a previously analyzed event that may occur during the opening of the isolated line are not significantly increased. 2. Does the change create the possibility of a new or different Idad of accident from any accident previously evaluated? This change provides acceptable compensatory actions follo .g failure of other equipment. The current requirements are based on providing a single active failure proof boundary to compensate for the loss of one of the two active isolating boundaries, nis change provides an alternative which meets the original criteria of a single active failure proof boundary and is capable of returning the system to its original configuration (i.e., configuration which can provide a single active failure proof boundary.) Therefore, this change does not create the possibility of a new or different kind of accident from any previously analyzed accident.

3. Does the change involve a significant reduction in a margin of safety?

The margin of safety considered in determining the required compensatory action is also based i . on providing the single active failure proof boundary. Opening of containment penetrations on an intermittent basis is required for performing surveillances, repairs, routine evolutions, etc. which minimizes the possibility of a transient due to a required plam shutdown. The administrative controls, consisting of stationing a dedicated operator (who is in continuous communication with the control room), provides a compensatory boundary in this condition. CALVERT CLIFFS - UNITS 1 & 2 3.6 15 Revision 7

NO SIGNIFICANT liAZARDS CONSIDERATIONS SECTION 3.6 o CONTAINMENT SYSTEMS Since the compensatory boundary is capable of essentially meeting the same criteria of a single active failure proof boundary, the change does not involve a signl0 cant reduction in the margin of safJty. 3.6.6 Channe Li Not used. l Afi.6 Change IJ 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change increases the Completion Time to restore one containment cooling train to Operable status from 8 hours to 72 hours when three containment cooling units are inoperable. l This change will tiot signlucantly increase the probability of an accident previously evaluated. The Containment Cooling System is not an initiator of any analyzed event. This change will not signiGenntly increase the consequences of an accident. The containment cooling capability is still over 100% because two containment spray trains and one containment cooling unit are Operable. The 72. hour Completion Time limits the time the plant is in a condition in which it does not have a redundant Containment Cooling System. This change will not signincantly alTect the assumptions relative to the mitigation of accidents or transients. Therefore, the change 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 evaluated? The proposed change increases the Completion Time to restore one containment cooling train to Operable status from 8 hours to 72 hours when three containment cooling units are inoperable. This change does not involve 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. 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 the change involve a significant reduction in a margin of safety?

The proposed dange increases the Completion Time to restore one containment cooling train to Operable status from 8 hours to 72 hours when three containment cooling units are inoperable. The margin of safety is not significantly affected because enough containment cooling capability exists to mitigate any accident heat load inside containment. The Completion Time will ensure that the time the plant is in a degraded Condition (without a redundant Containment Cooling System) is limited while allowing enough time to restore one train of containment cooling to Operable status in order to avoid the transient of a plant shutdown. Therefore, the proposed change does not involve a significant reduction in a margin of safety. CALVERT CLIFFS UNITS I & 2 3.6-16 Revision 7 _U

NO SIGNIFICANT llAZARDS CONSil)ERATIONS SI:CTION 3.6 . CONTAINMENT SYSTEMS LL6 Change L3

1. Does the change Ingolve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change will add an Action for the case when all the containment cooling trains are inoperable. The added Action will increase the Completion Time from immediately initiating a shutdown, to 72 hours to restore the train to Operable status.1his change will not significantly increase the probability of an accident previously evaluated.1he Containment Cooling System is not an initiator of any analyzed event. This change will not significantly increase the consequences of an accident. The containment cooling capability is still 100% because two containment spray trains are Operable. The 72 hour Completion Time limits the time the plant is in a condition in which it does not have a redundant Containment Cooling System. This change , will not significantly afTect the assumptions relative to the mitigation of accidents or transients. ' Therefore, the change 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 evaluated?

The proposed change will add an Action for the case when all the containment cooling trains are inoperable. The added Action will increase the Completion time from immediately initiating a shutdown, to 72 hours to restore the train to Operable status. This change does not involve a significant change in the design or operetion 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 kit.J of accident from any accident previously evaluated.

3. Does the change involve a algnificant reduction in a margin of safety?

The proposed change will add an Action for the case when all the containment cooling trains are inoperable. The added Action will increase the Completion Time from immediately initiating a shutdown to 72 hours to restore tne train to Operable status, The margin of safety is not significantly affected because enough containment cooling capability exists to mitigate any accident heat load inside containment. The Completion Time will ensure that the time the plant is in a degraded Condition (without a redundant Containment Cooling System) is limited, while allowing enough time to restore one train of containment cooling to Operable status, in order to avoid the transient of a plant shutdown. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 166 Change L4 Not used. l LL6 Change L5

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change will decrease the Surveillance Frequency, to verify that the containment spray nozzles are unobstructed, from 5 years to 10 years. This change will not significantly increase the probability of an accident previously evaluated. The Containment Spray System is CALVERT CLIFFS - UNITS I & 2 3.6 17 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 . CONTAINMENT SYSTEMS not an initiator of any analyzed event. His change will not significantly increase the consequences of an accident. The Surveillance, when performed every 10 years, is sufficient to prove that the containment spray noules are unobstructed. He NRC recommended that the Frequency for this Surveillance be decreased from $ years to 10 years in NUREG 1366, ;

                                                " Improvements to Technical Specifications Surveillance Requirem nts."                            NUREG 1366 discussed the NRC findings in their scarch for failuirs during performance of this Surveillance.

The results of the search identified that only three problems were identified and those were related to construction errors. No problems were identified involving flow verification. Surveillance history at Calvert Cliffs substantiates the NRC findings. This change will not significantly afTect the assumptions relative to the mitigation of accidents or translents. Herefore, the change 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 evaluated?

He proposed change will decrease the Surveillance Frequency, to verify that the containment spray nonles are unobstructed, from 5 years to 10 years. This change does not involve 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. The proposed change will not introduce any new accident initiators. %erefore, the change does not create the possibility of a new or different kind of accider.t from any accident previously evaluated.

3. Does the change involve a significant reduction in a margin of safety?

He proposed change will decrease the Surveillance Frequency, to verify that the containment spray nonics are unobstructed, from $ years to 10 years. The margin of safety is not significantly affected because the Surveillance Frequency is still adequate to ensure that the containment spray nonles are unobstructed. Also, the NRC recommended that the Surveillance Frequency be increased from 5 years to 10 years. His was a result of their investigation into failures found during the performance of this Surveillance, which is outlined in NUREG 1366. Therefore, the proposed change does not involve a significant reduction in a margin of safety, 16.6 Chanse L6

1. Does the change invohe a significant increase in the probability or consequences of an !

accident previously evaluated? l The pioposed change will delete the requirement to perform Containment Cooling System SRs l on a Staggered Test Basis. This change will not signl0cantly increase the probability of an accident previously evaluated. The Containment Cooling System is not an initiator of any l analyzed event. This change will not signincantly increase the consequences of an accident. The Surveillance for each train will still be performed on the same Frequency. The ability of the Surveillance to verify Operability has not changed, This change will not signincantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change does not involve a signi0 cant increase in the probability or consequence of an accident previously evaluated. l CALVERT CLIFFS . UNITS I & 2 3.6 18 Revision 7

No SIGNIFICANT llAZARDS CONSIDCRATIONS SECTION 3c6 . CONTAINMENT "v8TEhtS

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change will delete the requirement to perform Cratainment Cooling System SRs on a Staggered Test Dasis. %Is change does not involve 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. 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 the change involve a significant reduction in a margin of safety? I The proposed change will delete the requirement to perform Containment Cooling System SRs ;

on a Staggered Test Basis. The margin of safety is not significantly affected because the Surveillance will still be performed on the same periodicity. Deleting the requirement to stagger the testing of the components provides more flexibility to perform the Surveillances with the same train engineered safety features equipment. Allowing the same train engineered safety features components to be tested during the same period prevents the opposite train components from becoming inoperable due to a failed Surveillance. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.6.6 Chanec L.7

1. Does the change lusolve a significant increase in the probability or consequences of an accident previously evaluated? l The proposed change will add an allowance that containment spray cutomatic valves, which are locked, scaled, or otherwise secured in position do not have to be verilled to actuate to their required position. This change will not significantly increase the probability of an accident previously evaluated. The containment spray automatic valves are not initiators of any analyzed event. This change will not significantly increase the consequences of an accident. plant administrative controls are in place to provide assurance that containment spray automatic valves which are verified locked, sealed, or otherwise secured in position will not be inadvertently realigned. Thus, the likelihood of a valve tht was previously verified to be locked, scaled, or otherwise secured in position being inadvertently realigned is small. This change will not significantly affect the assumptions relative to the mitigation of accidents or transients.

Therefore, the change 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 evaluated?

The proposed change will add an allowance that containment spray automatic valves, that are locked, scaled, or otherwise secured in position do not have to be verified to actuate to their required position. This change does not involve 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. 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 3.6 19 Revision 7

NO SIGNIFICANT liAZARDS CONSIDERATIONS SECTION 3.6. CONTAINMENT SYSTEMS i j 3. Does the change involve a significant reduction in a margin of safety?

                     'the proposed change will add an allowance that containment spray automatic valves, that are i                   locked, scaled, or otherwit.e secured in position do not have to be verified to actuate to their          !

required position. The margin of safety is not significantly afTected becaut.e plant administrative : controls provide assurance that these valves will not be inadvertently realigned. Therefore, the l proposed change does not involve a significant reduction in a margin of safety. 3.6.7 Channe L1

1. Does the change involve k significant increase In the probability or consequences of an accident previously evaluated?

~ The proposed change will increase the allowed outage time (AOT), when two hydrogen recombiners are inoperable from a required shutdown per LCO 3.0.3, to seven days. This change will not signif1cantly affect the probability of an accident previously evaluated. The hydrogen recombiners are not initiators of any analyzed events. This cha. ge will not significantly increase the consequences of an accident. The containment vent / hydrogen ourge system is capable of i maintaining hydrogen in containment to within limits. Also, during the seven day AOT, within one hour aller both hydrogen recombiners are declared inoperabic and seven days thereafter, the i containment vent / hydrogen purge system must be verified (by administrative means) to bc

capable of controlling hydrogen. Also, the seven days is reasonable because of the low probability of the occurrence of a LOCA that would generate hydrogen in amounts capable of exceeding the flammability limits such that the system would be needed. This change will not significantly affect the assumptions relative to the mitigation of accidents or translents.

Therefore, the change 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 evaluated?

                    'the proposed change will increase the AOT, when two hydrogen recombiners are inoperable from a required shutdown per LCO 3.0.3, to seven days. This change does not involve 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. 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 3

accident from any accident previously evaluated.

3. Does the change involve a signifleant reduction in a margin of safety?

!                   The proposed change will increase the AOT, when two hydrogen recombines are inoperable from a required shutdown per LCO 3.0.3, to seven days. The margin of safety is not significantly affected because the containment vent / hydrogen purge system is capable of controlling hydrogen below the required limit. This change may also prevent a shutdown which is a transient that causes stress on safety system components and can cause a plant upset.

Therefore, the proposed change does not involve a significant reduction in a margin of safety, i CALVERT CLIFFS UNITS 1 & 2 3.6 20 Revision 7

NO SIGNIFICANT H2ARDS CONSIDERATIONS SECTION 3.6 . CONTAINMENT SYSTEMS 3.6.7 Chance IJ

1. Does the change involve a significant increase in the probability or consequences of at accident previously evaluated?

The proposed change deletes the six month hydrogen recombiner functional test. This change will not signincantly affect the probability of an accident prevL ; sly evaluated. The hydrogen recombiners are not initiators of any analyzed events. This change will not sign 10cantly increase the consequences of an accident. The 24 month SR is adequate to identify hydrogen recombiner failures. The 6 month hydrogen recombiner funedonal test is encompassed by the 24 month functional test. The 24 month functional test is brought to a higher temperature for a longer duration. A search of the SRs back to approximately 1985 did not result in any failures being identined by the six month functional test. Also, this test is not a manufacturer recommended test. This change will not signincantly affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change does not involve a signl0 cant 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 evaluated?

The proposed change deletes the six month hydrogen recombiner functional test. This change does not involve a signincant change in the 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 the change involve a significant reduction in a margin of safety?

The proposed change deletes the six month hydrogen recombiner functional test. The margin of safety is not signl0cantly affected because the 24 month hydrogen recombiner functional test is adequate to ensure the hydrogen recombiner is Operable. Deleting a requirement which does not identify failures and is not recommended by the manufacturer will prevent wear and tear (which increases the chances of a premature failure) on the hydrogen recombiner by eliminating unnecessary operation. Therefore, the proposed change does not involve a sign 10 cant reduction in a margin of safety. 31 ' ChangcM

l. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change allows the plant to change Modes when one hydrogen recombiner is inoperable by exempting LCO 3.0.4. This change will not signi0cantly affect the probability of an accident previously evaluated. The hydrogen recombiners are not idators of any analyzed events. This change will not signi0cantly increase the consequenc, accident. One hydrogen recombiner is capable of maintaining the containment atmosphm, .,elow the hydrogen Dammability limit during post LOCA conditions. Also, the containment vent is available, which is also capable of maintaining the hydrogen concentration below the Hammability limit during post LOCA cond;tions. This change will not signl0cantly atTect the assumptions relative to the ! mitigation of accidents or transients. Therefore, the change does not involve a signincant increase in the probability or consequence of an accident previously evaluated, CALVERT CLIFFS - UNITS 1 & 2 3.6-21 Revision 7

NO SIGNIFICANT HAZANDS CONSIDERATIONS SECTION 3.6 o CONTAINMENT SYSTEMS I 2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? ne proposed change allovs the plant to change Modes when one hydrogen recombiner is inoperable by exempting LCO 3.0.4. His change does not involve a significant change in the i design or operation of the plant. No hardware is being added to the plant as pad of the proposed change, ne proposed change will not introduce any new accident initiators, nerefore, 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 signifk nt reduction in a margin of safety?

He proposed change allows the plant to change Modes when one hydrogen recombiner is inoperable by exemp*ing LCO 3.0A. The margin of safety is not significantly affected because the remaining Operable hydrogen recombiner or the containment vent is capable of maintaining the containment atmosphere below tne post LOCA hydrogen fiammability limit. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 3.6.8 Ch==ye L1

1. Does the change involve a significant increase in the probability or consequerces of an accident previously evaluated?

l The proposed change will delete the Staggered Test Basis requirement when operating the lodine Removal System (IRS) for 15 minutes once per 31 days. His change will not significantly increase the probability of an accident previously evaluated. The IRS is not an initiator of any analyztd event. This change will not significantly increase the consequences of an accident. Each train will still be performed on the same Frequency. The ability of the Surveillance to verify Operability has not changed, nis change will not significantly affect the assumptions relative to the mitigation of accidents or tratulents. Therefore, the change 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 evaluated? The proposed change will delete the Staggered Test Basis requirement when operating the IRS for 15 minutes once per 31 days. This change does not involve a significant change in the design or operation of the plant. No hardware is being added to the plant as pan 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 the change involve a significant reduction in a margin of safety?

The proposed change will delete the S:aggered Test Basis requirement when operating the IRS for 15 minutes once per 31 days. The margin of safety is not significantly affected because the Surveillance will still be performed on the same periodicity. Deleting the requirement to stagger the testing of the components provides more flexibility to perform the Surveillances with the same train components of other systems. Allowing the same train components to be tested during the same period prevents opposite train components from becoming inoperable due to the failure of a Surveillance. Therefore, the proposed change does not involve a significant reduction in a margin of safety. CALVERT CLIFFS - UNITS I & 2 3.6 22 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS SECTION 3.6 o CONTAINMENT SYSTEMS i hs Chnee L2

1. Does the change involve a sigulficant increase in the probability or consequences of su accident pre.inusly evaluated?

1he proposed change adds an Action to allow an AOT cf one hour to restore one IRS train to Operable status when two IRS trains are inoperable. This change will not significantly affect the probability of an accident previously evaluated. The IRS is not an initiator of any analyzed events. This change will not significantly increase the c3nsequences of sn accident because the time required to be in Mode 3 (7 hours) and Mode 5 (37 hours) has not changed. This change ' allows one hour to restore one IRS train to Operable status. In most cases, the one hour will specifically allow the swing IRS train to be aligned to the correct bus to ensure two separate and indepenant trains ofIRS. The one hour will allow time to restore one train without having to l concentrate on an immediate shutdown due to LCO 3.0.3 being entered. This change will not l i significantly affect the assumptions relative to the mitigation of accidents or transients, Therefore, the change dus not involve a significant incicase in the probability or consequence of an accident previous'y evaluated.

2. Does the change create the poss!bility of a new or dinerent kind of accident from any accident previously evaluated?

1he proposed change adds an Action to allow an AOT of one hour to restore one IRS train to Operable status when two IRS trains are inoperable. This change does not involve 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. 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, f l 3. Does the change invrIve e significant reduction in a margin of safety? 1he proposed change adds an Action to allow an AOT of one hour to restore one IRS train to Operable status when two IRS trains are inoperable. The margin of safety is not significantly affected because the time to be in Mode 3 and MWe 5 has not been extended. Ilowever, one hour is allowed to restore one IRS train to Operable status without having to divert attention to preparing the plant for a shutdown (which is a transient). Therefore, the proposed change does not involve a significant reduction in a margin of safety. ENVIRONMENTAL ASSESSMENT This proposed Technical Specification changes has been evaluated against the criteria for and identification oflicensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed changes meet the criteria for categorical exclusion as provided for under 10 CFR S t.22(c)(9). The following is a discusslor. of how the proposed Technical Specification change meets the criteria for categorical exclusion. 10 CFR 51.22(c)(9): Although the proposed changes involves changes to requirements with respect to inspection or SRs, (i) proposed changes involves No Significant llazards Consideration (refer to the No Significant llazards Consideration section of this Technical Specification Change Request); CALVERT CLIFFS - UNITS I & 2 3.6 23 Revision 7

NO SIGNIFICANT HAZARDS CONSIDERATIONS i SECTION 3,6 . CONTAINMENT SYSTEMS i (ii) there is no significant change in the types or significant increase in the amounts of any emuents that may be released offsite since the prooored changes do not affect the generation of any radioactive emuents nor do they affect any of the permitted release paths; and (iii) there is no signliicant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed chanses meet the eligibility criteria for categorical exclusion set forth in 10 CFR $1.22(c)(9). Based on the aforementioned and pursuant to 10 CFR $1.22 (b), no envirorimental assessment or environmental impact statement need be prepared in connection with issuance of an amendment to the Technical Specifications incorporating the proposed changes of this request. J s 2 j i l. t 4 g ,,,,

                 .CALVERT CLfFFS                           UNITS I & 2            3.6 24                                                        7

                 .-         - - _ - -          = -            .       __ __               -            .      .-          .        . - - . - - ..___                                     _.. - . -         .-

i (CTS) Containwnt/fAIwssMric and4 fun @ 3.5.3

                                          $URyttttANCE Rt0VIRINfWi$

SURVillLANCE FRtQUtNCY (9.6.l.5 / 3R 3.4.1.1 Perfore reoutred visual examinations and C- Ott.-- 1eakage rate testing except for containment SR .0.2 not ock tantir!..in accordance with li R $0, pind1x J, as dified by ' l approved e tions. L -- ca -

                                                                                                                                                                   ---- --J The lea ge rate acte ance criteri n is                                          In accorhare
                                                                   $ 1.0          . However,            ring the fir        unit start following sting                                                                          CFR      ?

d in x J. s acco ence with I CFR 50,perfo App dix J as led

'i                                                                 mod led by appr ed exemptio                                                              ove            j 1        age rate at plance cri ria, the              are = 0.6             I i

y L', for the lyp B and T pe apti yr.' ( tests, en

                                                         /p.75 L, for he Type                                 i st.            .

4, k ), S

                                            $R 3.6.1.2            Verify containment structural integrity                                          in accordance in accordance with the Containment Tendon                                      with the q

4drveillance Program. C>ntainment

                                        /                                                                                                          Irr%ance                  M
                                           ~                                                                                                       Program

( y~ i -. - _ _ Q Coq p .A ty k. M e Tid y i CEOG STS 3.6 2 Rev 1. 04/07/95

   , . , . . . .n. . ,                             , - . , , . . .           .          . . . , . _          ., ,-               ,                                ,      -     .....,n-e.,           , . -

i 4 l I Containment Air LocksdAtmoph61c,and DuM a.e.l h i (CTS) ACTION $ (continued) CON 01110N Al00lkt0 AC110N COMPiti!0N TIME

1. 6.1,3 D. Required Action and 0.1 to in M00C 3. 6 hours associated Com Adlee*Jb 11ae not met. pletion 4110 -

0.t le in MODE l. 36 hours i SURVfILl ANCI RtQUIREMENTS

                                                                   $URVilLLANCE                                             FRt00tNCY D                 $R 3.6.2.1             ...................N0Tt$...................

g g'c, 1. An inoperable air lock door does not invalidate the previous successful geska,etest.erforwance of the overall air lock g i; g -

2. Results shall be eval te esitnst acceptance criterin ' SR 3.6.li

                                                                            , wun av cr&40, appe fossm as       fled by apprged exameti                  .a
                                                                                                                  ,i Perform required air lock leakage rate                                          E..

esting in accordance with/16 crn 39, Appens1x J, moeities o approve-

                                                                                                                        $RF.J[.! t               h apflica gg                                  eaesptions.                                                          t......p.....-J    j The arte ance criter                   for air ock                     In accordance testing re:                                                          .g11h)1 CFR      Q hppe tx J

a. vera11 air ck leak e rate is no led I s[0.05L.) en tes at t P,. a rove

                                                                                                                     /     eyt ns b           For each         or. les go rate is
                                                                 .01 L s;10.0hsig].      when t ted at t

( (continued) er4d Itahey 94 Tgsk kram / CEOG $1$ a 3.6-6 Rev 1. 04/07/95

(og Containment Iselat16n Valves ("2:;t:t d ai...:t . g ' 3.6 CONTAllettNT SY3 FENS [ 3...: eontainment istiation vaives w=:;um e :;o g ; (44hLC03.4.3 tech containment teclation valve shall be OPERAttt. APPLICAllLITY: M00t$ 1, t, 3, and 4. ACTIONS gg nwc u

1. ation flow paths (

r x = anna..................... ...... ... 1

                            )may be unisolate< M'earJ4M1             iMe valvMWnhr Monm FTnterntttent' y unser seministrat                              h ye otrois.
 ,$.7d arh. Separate Condition entry is allowed for each penetration flow path.

<5*@. Enter applicable Conditions and Required Actions for system (s) made inoperable by containment isolation valves. 3.(,.l. ) \ 4 e Condt ns r..w, Q . applic. . When ons of lf4I3.61 A ntainee use.reytiine and Redutred A edin.tvoversit./

              ...L&_8!...!!.!!!!!.."!!.!$.41.......... ................entas                     .............

a CON 0lil0N Rt00lRED A: TION COMPLETION TIME A. .-.......N0T[...... . A.1 Isolate the affected 4 tours Only applicable to penetration flow path penetration flow paths by use of at least with two containment one closed and p 4,i isolation valves

                     ................ k.d"jg
                                            ..-GN.

de activated automatic yalye closed manual.yalve, gh I W' p c, Ow or more ,bitnd flange, or penetration flow paths check valve with flow with one containment throug?. the valve isolation vLive secured. inoperable] 'e opt f 7 ryrurg valve akage Alg) I and shield utidt by ass le aen ) Lw(thin llelt . J @ (cintinued) CLOG STS 3.6-4 Rev 1. 04/07/95 ,

      ~ E is (soq u.\.w., <.t~

a <. a w r +. u w a m a a . u , o e .a a c.cs +.v.a m g 'g h%

(cu) Containment isolation Valves 4*--"-'- - '

                                                                                                                                                              >5 "3              h A

AC710N$ CON 01110N REQUIRED ACTION COMPLEil0N TIME 4 A. (continued) ! A.2 - ~ ~ -NOT[ - - --- Isolation devices in high radiation areas may be verified by use of administrative beans. [qt*l,1,a\ ' Verify the affected penetration flow path onceIolationer 31 days 81 L l li A i

                         %%ser V$

is isolated, for I devices outside centainment h AE Prior to i entering N00( 4

free MODE 5 If not perfonned within the previous 92 days for isolation devices inside' containment B. ---------NOTE--------- 8.1 Isolate the affected I hour Only applicable to penetration flow path penetration flow paths by use of at least

, with two containment one closed and isolation valve . ' . -%Ag de-activated automatic valve @ u[j\ l *'I Q*# J M*" closed aianual valve, M.'oadg One or more or blind flange. h penetration flow paths with two containment isolation valves inoperahlej,excep. olr rynv. alve les e f

;                                              and           told bu    ing by ss leak.3 4 thin liatt:           .f rn u                                                                                                          g.

I l (continued) CEOG $15 3.6-9 Rev 1. 04/07/95

l Containment Iselation Valves (.".- ..#. :: d 5:1) @ ! 3.6.3 l ACil0N$ (continued) ' CONDITION RtWIRED ACTION COMPLETION Tlhi C. ~ --NOT E-~~-.. C.1 Isolate the effected hours ly and 1 cable to p.p ty'netration use of ai flow ieas tath or inor6

              ,.nei with W conta' Sonow ,aths I)nt 1scistion            one closed and de activated I,         4 valv@and a closed                  automatic valve system.
              .. ........ ........               closed manual valve.
                                               .orj b1ind f1ange.

A P 3 '*4'! One er more AM penetration flow paths Aerwn Alf with one containment C.! ~ ~ -.N0TE ~ ~ ~ isolatio valve @ Isolation devices in ' inoperable high radiation areas (h] may be verified by V rmore use of administrative j means. Verify the affected once per 31 days > (4,kl.l.a {'"Noh, flow path h 5Secondardontainment 0.1 Restor d akage 4 hours ' by set leakage not hin limit.

,/

with W 11mit. h E. One or more E.1 Isolate the affected '24 hours Penetration flow aths oenetration flow pa with one or mor by use of at less containment pu e one valves not w n de ac[ closed and tivated purse valve enkage limits, automatic va e with restliant s is h closed'ma al valve with res isnt seals, or bli flange]. x an (continued)

CEOG STS 3.6-10 Rev 1. 04/07/95 i

1 d

Containment Isolation Valves sm-rc ard1Fue13 - 3.c.3 SURVillt.ANCE Al0VIRlM(NTS SURVllLLANCE FREQUENCY f ~$R 3.6.3.1 # Verifyeach[42 asaledclosedex)ceptforinch alve e purge pure is valve in 31 days l a p m tration flow pet (- Conditici f of this . 11e in

                                           !R 3.6.3         Verif

me, beach. hen she i h I alve_Js clos dh+31 open for pressure c;ontroiMs.aives or air ar.

days @ J , C. ld V 3.6. 3 poc. p.r- quality considerations for personnel entry. or for Surveillance; that require the

                                                                                                                                           & =7 4                  -

cyp valves to be open.

$R 3.6.3 6/,0.i.l. b

                                                           ..................-N0if.........--.--..-..

Valves and blind flances in high radiation areas may be verified 'y use of h N i

                                   /                       adethiatrative means.
)                                                          ........................ ..................

A gh, 4 Verify each containment isblation manual 31 days i valve and blind flange that is lo$ated 4 outside c Mtainmentaand is required to be lossa coa 41TC111en' aonditions is except for con.41r. tnt isolation ,TM*6 t to i t,li closed,that valves are open under administrative rg4n.4 W contro?s. (continued) a d d b e k d, . a t,1 ,,., 6llemise .vcsa ed N CEOG $1$ 3.6 12 Rev 1. 04/07/95

  , . , n... -       -.e     - , .                  .,a      e,. m..   -,,       _    . -. _,               ,..__-wn,e4           . .               ,   ._w-             ,--y,r     , . . . , - - , . , -

a Containment isolation Valves ?"r::f:t ;.;4 ;,.B b) 3.J.I j $URVilllMCE REQUIR[MfNTS (continued) , l SURVEILLMC[ FR[0UENCY 1 SR 3.6.3 ------------- NO T [--------~ ~ 4.6.1.1.a \ Valves and blind flanges in high radiation F..w.*e M/ areas may be verified by use of x [4.6,l. l . administrative means. g o g ,,p l,,y j/ Verify each containment isolation manual Prior to 3 8"I' # 6' Md* valve and blind flange that is located i 6, i ( i Inside containment 4and required to be enterMnMODE4 frne t 5 if Jac re.1 closes curmg accident conditions is

closed, except for containment isolation not performed TW- 4f Leo J 4,.3 \ within the valves that a o open under administrative previous A r,.,4.4e4/ controls. 92 days la

                                    $R 3.6.3@.7                                Verify the_ isolation time of(~aacT"EoeT0 In
                   ,g,4/ 3\
                                                                              $seratarane each automaticfcontainment                                accordance         ~# ' TA F O
                           /                                                   isolation valve is within inits.                                 ^,'with the 1

Inservice ] i 'p.ar. a u* * /c Testing

                                    $R 3.6.3.                                  Perform leakage rate tes ng for                                     184 days containment purge valve with resilient seals.                                                             &HQ I

With i 9f. days af r cpenin-l

                                                                                                                       /                          t     valve
                                    $p

6.3 Verify each automatic containment isolation months

                                      '                                       valve that is not locked, sealed, or (4g ,4 ), q , ,'>                                                 otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

(continued) Ct0G STS 3.6-13 Rev 1. 04/07/95 1 A

                                         %                                            m.           ,,                        _                       .            .,,._-y
                                                                                                                                                                                  -r   _ , , _ , . . . .

Conta1noent Iselatton Vsives((Ainopg4nad. (b

  $URVilllMCE Rf0VIRlh(NTS (continued) l
                          $URVIILLANCE FR(QW(NCY Sk3.6.3 Verityeachfkbin valve is blo opening >[60    .

ontainment pu e restrictthevahefrom (18] son h Q . - -

     $R 3.6.3.9 ,Verif the combined leaksge rate fo all sec
                                                                   .-NOTE--.--

paths $R 3.0.2 1 $[dary )contathment L, when bypass pressurtzed to leak psig]. is r.ot applicable g-In accon.a ce with 10 LFR

                                                              ,' Append),.

l as ifted by proved e tions

j CEOG STS 3.6 14 Rev1,04/07/95

_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ __ _ _ _ .- . _ _ - _ _ _ _ . ~ _ _ _ _ _ . _ _ _ . l l l ' Containment spray and Cooling Systems dAnnospheric and ndip 3.5.55 ) 3.6 CONTAINMENT $Y$1 EMS ! 3.( G (pnteinment serar and Cooling systems (IAttospVic andAW1) -

gtpsen tenen rpr_ issine .-,.ysy sne unw .a veras lMtem)): 6. 6.1.1 M ,2. LC0 3.6.8%

Two containment trains shall be btrains LE. r,d two containment cooling od APPLICA81LITY: M00t$J.p,t.Ngdfffy4i.d/p) @. ACTIONS (risbf.1, etcept Catemen.5pq is td etp4ked b lt, ( OPCEABICyben p*mutlter piuarc is < Mro psia. k COWITION REQUIRt0 ACTION COMPLETION TIME A. Die containment spray A.) Restore centainment 72 hours train inoperable. spray train to 5.6. 2.1 OPERABLE status. Ag

                               /cne.s 10 days from discovery of failure to meet the LCO l

B. Required Action and 8.1 to in MODE 3. 6 hours associated Crmpletion -- -- w 3 4 3.1 A r.ws Time of Condition A Algl [3 A rm'eur t "d.- not met. B.2 N leMin2.E M)E b" 1 F[ 12

                                                                                                                                '8 hours                                      hk C. One containment                C.1           Restore containment                   7 days cooling train                                cooling train to 34              inoperable.                                 OPERA 8LE status.                     AE A"'    "

10 days from discovery of failure to meet the LCO (continued) CEOG 51$ 3.6-17 Rev1,04/07/95

t l Containment Spray and Coeling Systems @ 3.6.(" :ab.-k 4%6[ l ACTIONS (continued) CON 01110N REQUIRED ACTIM COMPLti!0N TIME

                          . Twc containment           D.1         Restore one         72 hours
               ,t,,2,        cooling trains                        containment cooling                                   i
               , ,.s         inoperable.                           train to OPtRABLE                                     j status.                                               1 l

l E. Required Action and E.1 te in MODE 3. 3' 6'i'l associated Completion 4iours A

f' ** Time of Condition C Algt 8, '< I or D not met.

E.2 le in MODE . hours F. Two containment spray F.1 Enter LC0 3.0.3. Ismediately trains inoperable. LL4 cic 4,4 11 8 Any combination of three or more trains inoperable.

                       $URVEILLANCE REQUIREMENTS SURVEILLANCE                             FREQUENCY
                         $R 3.6.dl       Verif each containment sp ay manual, ower operafed, and automatic valve it. the f$ow 31 days (g-,2. I' o '                   path that is not locked, sealed, or                                    h    1 A

otherwise secured in position is in the correct rosition. f/4\ (continued) CE06 STS 3.6-18 Rev 1, 04/07/95

Containment $ pray and Cooling Systems m :;b;; :. ,

           $URVIILLANCE Rf0VIRIMfNTS (continued)
                                                $URVE!LLANCE                              FREQUENCY
            $R3.6.dt           Operate each containment cooling train f6n unit for t Il minutes.

31 days h (4.f,.2.. t , g ,p

            $R 3.6.[3          Verify each containment cooling train cooling water flow rate is 1A2000kspa to 31 days          b 4 4 7 7 *-                     each fan cooler.                     >     #

r_

              $R 3 .6A.4       Verify the con inment spray piping is                31 days full of wate tothe[100                           he containeen spray header.) ft level i L                                                                          ,-              -
            $R 3.6.            yerifyeachcontainmentcoraycui[s')                     In accordance     S            ggg p. 7s fdevmopst[p0)psidd ,fferent                            with the jpr hure / onAcirculattA flowY"@                -

Inservice Testing frogram

            $R 3.6.                                                                         months Verifyeachautosaticcontainmentsbed, valve in the f'ow path that is not
  /
 $'I.G. R. I, c. l>

sealed, or otherwise secured in position, actuates to the ccrrect position on an actual or simulated actuation signal. d SR 3.6.8 Verify each containment spray pump starts months S& automatically on an actual or simulated (4,f.. ?, l. b. t). actuation signal.

            $R 3.6.

s Verify each containment cooling trais cc ergg) months starts automatically on an actual or 7, g , simulated actuation signal. (continued) CEOG $15 3.6-1g Rev1,04/07/05 Si"Ived bel at 4h f ka ded yd 'it gr< der 6, s e a a% % reyored A , ,, he, o k>. cl M

Containment Spray and tooling Systems KAladispherWand V 3.6.1

   $URVillLANCf_REQUIR[NINTS_(continued)
                           $URVEILLANCE                     l     TREQUENCY SR 3.6.       Verify each spray nortle is unobstructed. At ff t refu ing nob k4.(,, t. l.d )                                                t 10 years f

CEOG $15 3.6-20 Rev1,04/07/95

1 1 J HydrogenRecostainers(1sciphets(andDudM@ ' 3.6.1 h

                                   $URVilllANCE RIOUIREMENTS
                                                                           $URV[IllANCE                                   FRl0VEN;Y
                                     $R 3.6    i         Perform a system functional test for each                          months 4.6.$.2.(. 3                     hydrogen recombiner.
                                     $R 3.6              Visually examine each hydr en recombiner                           months enclosure and verify there s no evidence (46.$.2.{.                      of abnormal conditions.

7d 2 SR 3.6 Parform a resistance to ground test for mnths each heater phass. (4.45,f.b./) SC 3.sn.% Ferinn s C WrJnEL C At it> A Tioni of 24 n h & s\\ kn progen re c.mhine r thshe w 4<4 m onel codr>l c,irsa 4 ; CEOG STS 3.6-28 Rev 1, 04/07/95

DISCUSSION OF TECilNICAL SPECIFICATION DEVIATIONS FROM NUREGol432

  ,                                  SECTION 3.6 CONTAINMENT SYSTEMS ELhM-SPECIFIC CIIANGES

1. His change deletes the terms Atmospheric and Dual in parentheses. These t 'ns were placed in the NUREG 1432 titles to inform the users that the Specification is for o sspheric and dual containment plants. Dese informational terms are not required for the Calve:1 Clifts improved Technical Specifications (ITS). Calvert Cliffs has an Atmospheric containment and will adop' Go applicable Specifics: ions. This change also applies to the deletion of NUREG 1432 specifications that do not apply to Calvert Cliffs, and any designations in the titles that relate (e.g.,3.6.6B Containment Spray and Coolmg (credit not taken for iodine removal] was deleted).

2. He change to the non-bracketed system name, number of systems / components, terminology, or value was changed to be consistent with Calvert Chffs specific system name, number of systems / components, terminology, or values. His change also includes any numbering changes due to the addition or deletion of Specifications, Actions, or Surveillance i Requirements (SRs).

3. This change deletes all of SRs and Actions related w the containment purge isolation valves.

Requirements for the containment purge isolation valves will be located in Section 5.5.16,

                     " Containment Leakage Rate Testing Program" for Unit 1 and Section 3.9, " Refueling 4

Operations," for Units 1 and 2. The requirements for the Unii 2 containment purge isolation valves in Modes 1,2,3, and 4 will be deleted. Calvert Cliffs submitted a license amendment which deleted all requirements for the purge valves because the valves are being blind flanged in Modes 1,2,3, and 4, which eliminates the need for a containment isolation valve for this penetration. This change is consistent with the proposed Technical Specification

,                    change submitted from Mr. C. !I. Cruse (Baltimore Gas and Electric Company) to NRC Document Control Desk, dnted Argust 1,1996, License Amendment Request, Use of Blind Flange in Place of Containment Purge Valves During Operations, This request was approved m License Amendment No.197 for Facility Operating License No. DPR-69.

4. A Note was added a .kgNation 3.6.3 Limiting Condition for Operation Notes which allow the shutdown co&g (SuC) isolation valves to be opened when Reactor Coolant System temperature is < 300*F to establish SDC flow. The Note was added a allow SDC to be estab!ished in Mode 4 when Reactor Coolant System temperature is < 300*F which is contradictory to Note I which only requires penetrations to be opened intermittently. This c.hange is rcs uired to enable Calvert Cliffs to establish SDC and is consistent with the Cab'ert Cliffs current licensing basis.

6

5. These changes incorporr. , Calvert Cliffs-specific information into brackets. Bracketed information located throughout NUREG 1432 will be replaced with the specific Calvert Cliffs requirements. This change also includes deleting bracketed items when it is not consistent with the Calvert Cliffs design.

6. The Applicability Section ofITS LCO 3.6.6 was modified to require the Containment Spraf System to only be operable in Mode 3 when the pressurizer pressure is 21750 psia. This proposed deviation is consistent with Footnote

to the Applicability Section for CTS LCO 3.6.2.1. In conjunction with this change, the requirement in Required Action B.2 was changed from "Be in MODE 5" to "Be in MODE 3 with pressurizer pressure < 1750 psia."

This proposed change would place the unit in a condition for which ITS LCO 3.6.6 does not CALVERT CLIFFS - UNITS I & 2 3.6-1 Revision 7

DISCUSSION OF TECIINICAL SPECIFICATION DEVIATIONS FROM NUREG-1432 SECTION 3.6 - CONTAINMENT SYSTEMS apply, it is consistent with the philosophy provided throughout WUREG-1432. The Bases for NUREG 1432 LCO 3.0.2 states: "The Orst type of Required Adon sp< eifies 3 time limit in which the LCO must be met . . . If this type of Required Action h not completed within the specified Completion Time, a shutdown may be required to place he unit in a MODE or condition in which the specification is not applicable." Additionalh, the Completion Time for Required Action B.2 was changed from "84 hours" to "12 hours" This time is consistent with the Completion Time of Required Action B.2 ofITS LCO 3.5.2, which also requires the plant to be placed in Mode 3 with pressurizer pressure < 1750 psia.

7. The shutdown track in Required Action E.2 was changed from a requirement to be in Mode 5 in 36 hours, to Mode 4 in 12 hours. This change was made because the Calvert Cliffs Containment Spray and Cooling Specification is only applicable in Modes I,2, and 3. This change is consistent with other Technical Specifications (when not modified and justified in the Bases) when shutting down to Mode 4.

8. A Surveillance (ITS 3.7.6.2) was added to NUREG-1432 Specification 3.6.8 (Calvert Cliffs ITS 3.6.7) which requires the performance of a Channel Calibration of all hydrogen recombiner instrumentation and control circuits every 24 months, This test is consistent with Calvert Cliffs' current licensing basis.

9. The change adds an Action to NUREG-1432 Specification 3.6.10 (ITS 3.6.8) which incorporates an Action when two lodine Removal System trains are inoperable. Calvert Cliffs deviates from the standard Combustion Engineering plant in that it has three trains of 1, dine Removal System. Two trains are required during a design basis accident. One of the e ree trains is a swing train and has to be powered from the correct bus to maintain separate

              .md independent trains. In order to perform this alignment without entering Limiting Condition for Operation 3.0.3 (there is no Action for two trains), Action B was added.

Action B allows one hour to restore one lodine Removal System train to Operable status. This change will not increase the total time allowed to be in Mode 5 (Limiting Condition for Operation 3.0.3 allows 37 hours, and Actions B and C combined would also allow 37 hours). 10, NUREG 1432 Condition C is for one or more penetration flow paths with one containment isolation valve ir 9erable and is only applicable to penetration flow paths with one containment isolation valve and a closed system. Calvert Cliffs ITS 3.6.3 will retain the same requirement as the NUREG except the Calvert Cliffs Nuclear Power Plant ITS will also apply to those clossd systems with more than one containment isolation valve. Calvert Cliffs is a non-General Design Criteria plant with closed systems that contain one or more containment isolation valves. In conjunction with this change, a phrase was added to Conditions A and B Conditions Notes which specify that these Conditions only apply to penetration flow paths not in a closed system. This change is consistent with Calvert Cliffs design. I1. In ITS 3.6, changes have been made to reflect the implementation of 10 CFR 50, Appendix J, Option B. This is consistent with Calvert Cliffs' current licensing basis as approved in License Amendment Nos. 219 and 196 to Facility Operating License Nos. DPR 53 and DPR 69, respectively. These License Amendments were issued on February 11,1997.

12. Action Note 4 for NUREG-1432 LCO 3.6.3 requires the applicable Conditions and Required Actions of LCO 3.6.1 to be entered, whencver leakage results exceed the overall containment CALVERT CLIFFS - UNITS 1 & 2 3.6 2 Revision 7

DISCUSGION OF TECilNICAL SPECIFICATION DEVIATIONS FROM NUREGol432 SECTION 3.6 - CONTAINMENT SYSTEMS leakage rate acceptance criteria. This Action Note has been deleted from ITS 3.6.3, because ITS 3.6.3 contains no requirements regarding leakage rates. As discussed in additional JFDs for ITS Section 3.6, the SRs (i.e., SRs 3.6.3.6 and 3.6.3.9) and Actions (Actions D and E) associated with leakage rate testing of the containment purge valves with resilient seals and secondary containraent bypass leakage paths have been eliminated from ITS 3.6.3. Due to the elimination of the requirements regarding leakage rates from ITS 3.6.3, Action Note 4 for NUREG 1432 LCO 3.6.3 is not appropriate to include in ITS 3.6.3. Hus, the note has not been included in ITS 3.6.3. j i i d CALVERT CLIFFS - UNITS 1 & 2 3.6-3 Revision 7

r

b Containment ([*:=4 un, B 3.5.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.1 Containment %* :p. % ))

g BASES BACKGROUND The containment consists of the concrete reactor building (RB), its steel liner, and the penetrations through this structure. The structure 14 designrJ to contain radioactive material that may be releised froe the reactor core following a Cesign Casisi Accident (DPA). Additionally,this [f structure provides shielding from the fission products that W) may be present in the containment atmosphere following accident conditions. / ms

    %               The containment cylindrical  wall
                                                                              < << $r4 is a reinforce concrete structu; with'a    ~~

h roof. a flat foun ation mat and contaInmem1@4Rifd'ngrouted tendons a o llow dome be cylinder wall i@s prestressed with a post tensioning system in ths h

vertical and horizontal directions, and the dome roof is prestressed uttitzing a three way post tensioning system. The insi6e surface of the containment is lined with a carbon steel liner to ensure a high degree of leak tightness during operating and accident conditions. The concrete RB is required for structural integrity of the i containment undersDBAltonditions. The steel liner and its penetrations establish the leakage limiting boundary of the containment. Maintaining the containment OPERABLE limits the leakage c? fission product radioactivity from the containment to the environment. SR 3.6.1.1 leakage rate i requirementscomplywith10CFR50,AppendixJ)(Ref.1),as modified by approved exemptions. I The isolation devices for the penetrations in the containment boundary are a part of the containment leak tight barrier. To maintain this leak tight barrier:

a. All penetrations required to be closed during accident conditions are either

1. capable of being closed by an OPERABLE automatic containment isolation system, or (continued)

CEOG STS B 3.6-1 Rev 1. 04/07/95

Containment (" m e r W B3.6.1 Q 8ASES BACKGROUND 2. closed by manual valves blind flanges, or (continued) de+4ctivated automatic v,alves secured in their closed positions, except as provided in LC0 3.6.3, ' Containment Isolation Valves'; 4

b. En h air lock is OPERAtt exce t as provided in 3.6.2, 'Containee rLocgs'; {,j lg j

I

c. equipment hate close f h

d. T pressurized sealing 1 anism associated with a i netration, except as videdinLCO3.6.[],is l

                                         ,         OPERABLE.

__ ) APPLICABLE The safety design basis for the containment is that the SAFETY ANALYSES containment must withstand the pressures and temperatures of the limiting DBA without exceeding the design leakage rate. L The 08As that result in a release of radioactive material ! within containment are a loss of coolant accident, a main 4 e.iection accident (Ref). In 2).the steam lineofbreak analysis each of(MSLB , and a control eleme these accidents, it is assumed that containment is OPERABLE such that release of fission products to the environment is controlled by the rate of containment leakage. The l containment was designed with an allowable leakage rate of 2 [DAtq% of containment air weight per day (Ref. 3). This i leakage rate is defined in 10 CFR 50, .*.ppendix J (Ref.1), as 8 : the maximum allowable containment leakage ea Q the calculated maxiws peak containment press 4 63- i a 1 from the limiting d'" g Satisfactory leakage rate test result; are a requirement for the establishment of containeera OPERA 81LITY, The containment satisfies Criterien 3 of the NRC Policy Statement. LC0

               ~=        c-Containment OPERABILITY is maintained by limiting leakage to g 1.0 L), exceot orior to the first startup after performing

((344trA s(CA a required 10XTR SK Appen#fx J. leakage test. At this

d ..+^ %d L.,bp rat Tin 4lg by.e continued) 06 A CEOG STS B 3.6 2 Rev 1. 04/07/95 i e

1 I Containment -(A' :H -!ct 53.6.I @ BASES continued) L the 1 Yea a ihee1.75LQ Compliance with this LC0 will ensure a containment tag ,*), g dl' that configuration,includingequipmenthatchesIsakagetothose is structurally sound and that will limit /A /u /beh leakage rates assumed in the safety analysis. N bd Individual leaka s snecified for the containmenu air lock (LC03.6.2) p urge v; rives witlrrest11enixea1D Ulm 3xn nare not specifically part of the acceptance

criteria of'10 CFR 50, Appendix 4. Therefore, leat_ age rates exceeding these individual limits only resuis in sne containment being inoperable when the leakage results in exceeding t ghe aoptance criteria of enpehm A pg;y a Lo twn/D

                                      ~                          (781D APPLICABILITY   In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material into containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, containment is not required to be OPERABLE in MODE 5 to prevent leakage c,f radioactive material from containment. The requirements for containment during MODE 6 are addressed in LC0 3.g,3, " Containment Penetrations."

ACTIONS &d In the event containment is inoperable, containment must be restored to OPERABLE status within I hour. The I hour Completion Time provides a period of time to correct the problem comensurate with the importance of maintaining containment during MODES 1. 2, 3, and 4. This time period also ensures that the protability of an accident (requiring containmentOPERABILITY)occurringduringperiodswhen containment is inoperable is minimal. B.1 and B.2 If containment cannot be restcred to OPERABLE status within the required Completion Time, the plant must be brought to , (continued) CEOG STS L ?.6 3 Rev 1, 04/07/95 i i

l l 1 J Containment (Atmospheric I B 3.6. BASES ACTIONS 1 B.1 and B.2 (continued) 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.

SURVEILLANCE SR 3.6.1.1 REQUIREMENTS A. Maintaining the co inment OPERABLE requires compliance with the visua examinations and : eakage rate test r recut-ements o O CFy 50. _Aaa==a v a rum v 1o. as momnew l Aby AborovedA j ppege -g C e d ela .. {- ( ,,p ,l/ Lal_va41th tur1H1antAg fled inptipn1C Failure leakage limits to meet fairMr,edd spec' O %b d fre rm [E0 3.6.2 and LCO 3.6.3 does not invalidate the v acceptability of these overall-leakage determinations unless their contribution to overall Type A, B and C leakage causes that to exceed limits. As left Isakage prior to the O t "h M d, l [ bbia; .g first startup after performing a required (4D ML,ED # (' /

                         . A.dt     '"

gynn g'* -Rh 1 44,.Q co_ii51n leakage test is required _to be A0.0 L. or ype B and C leakagg, and 50.75 L,do,r overais G W 6 I T9 , e, O M3 Iroe A leakage 6 at nii etner times between requirea ieamageT ffate tests, une acceptance criteria is based on an overall L. 459. 5ou

            *g\                   -

Type A leakage it ilt of 51.0 L*. At s 1.0 L the offsite see dose consequences are bounded by the assumpti,ons of the f,%,,) " M *y of safety analysis. SR Frequencies are as required by_ Mpen o, as vuiiifu py approvec exepptions. Inus, sl.4h 4 LiuLt.Q t . 2 (which allo 6s Frecuenev extensions) does not only, yV' 4 +" Tiese periodic testing requirements verify that the - g containment leakage rate does not exceed the leakage rate assumed in the safety analysis. g 4 " j M *)* - (i5 tid ,We. r9wenes rep @q 6e. tiet 1 conhimewt] SR 3.6 h_ * '"*W"O"5 8'"$3 b e mt , f-Nde Q &. i l& I For ungrouted, post tensioned tendons, this SR ensures that ( E b'* the structural integrity of the containment will be 9-J2-

-~

maintained in accordance with the provisions of the containment Tendon Surveillance Program. Testing and Frequency are consistent with the recommendations of Regulatory Guide 1.35 (Ref. 4). (continued) CEOG STS B 3.6-4 Rev1,04/07/95 2 1 4 l l i i

-_..-. . _ . _ . . ._..._...___.____._.._-.._._._.___.._._-.m. . _ . _ _ _ _ . - . - . . _ . . . _

                  -F                                                     : INSERT B 34bR 3.6.1.2 f

if the con ' nt structure exhibits evi nee of possible abnonnal de dation per Specification 5.5.6, " oncrete Containment Tendo urveillance Program," an e nering evaluation is - perf wd to demonstrate the abili of the containment structure continue to perform its design

                     - fu tion. He engineering eval                      ion is required to be complet within 90 days of the test.

j

Containment ?"r:;': B3.6.1 Q BASES'(continued) REFERENCES 1. 10 CFR 50 Appendix L h i _ 8) h

2. hsAR, Gochron VB {f (;

3gSAR, QecWbn#

@[

4. Regulatory Guide 1.35, Revision g b CEOG STS B 3.6-5 Rev 1. 04/07/95

ContainmentAirLocks(f'.;;;;t:-!: W NW - B3.6.f Qt 83.6 CONTAINMENT SYSTEMS i 8 3.6.2 Containment Air Locks (At=^< P -i: r4 L ;l} b BASES BACKGROUND ! Containment air locks form part of the containment pressure boundary and provide a means for personnel access during all MODES of operation. g Each air lock is nominally a rikht circular cylinder.pe> in diameter with a door at eac end. The doors are 4,. Jh puJ** intersockeY:topreventsimultaneousopening. During periods

      @r lac k *"g when containment is not required to be OPERABLE, the door interlock mechanism may be disabled, allowing both doors of 5 A-9A in                  $n air lock to renin open for extended i     gia,,,e /e r-            frequent containment entry is necessary. periods Each airwhen lock door b ' ~g C

7 has been designed and tested to certify its ability to withstand a pressure in excess of the maximum expected 4, j, , )c pressure following a Design Basis Accident (DBA) in containment. As such, closure of a single door supports
containment OPERABILITY. Each of the doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity. To effect a leak tight seal, the air lock design uses pressure seated doors (i.e., an increase in containment internal pressure results in increased sealing force on each door).

Each personnel air lock _1: provided with limit Witches o g, "bo coorsJght prov1m contsta room >fRficatiW of door A la sition A Additto ly, trol r indt (ton is vloeO 1 t pe r ever rlock air loc) oor i 8 The containment air locks form part of the containment pressure boundary. As such, air lock integrity and leak tightness is essential for maintaining the containment leakage rate within limit in the event of a DBA, Not maintaining air lock integrity or leak tightness may result in a leakage rate in excess of that assumed in the unit safety analysis.

                                              .s_              -

p Arm m Ae. ca+rel tooe bl cubles cden eiher door or epding vdve_. (or c persone\ ch WE h opeced. The cJare reu es deot PosWem hm A bW' s Akck leceded c6~ eddoor d 4 o d e anlit?4 ve M , f (continued) CEOG STS B 3.6-11 Rev 1, 04/07/g5 4

ContainmentAirLocks(2.t:siJmi6 and sv.P 83.6.k O BASES (continued) g APPLICABLE T .phytfcontakdenQ Abe D8As that result in a

&^

SAFETY ANALYSES re ease loss o of radioactive metertT1 within containment are a coolant accident (LOCA), a main steam line break

h TM4 l.. key r.4 h (MSLB)andacontrolelementassembly(CEA) ejection accid nt (Ref. 2). In the analysis of each of these c/,/;,,id ,x g g ' acci nts, it is assumed that containment is OPERABLE such M # " 7. Op b 8' that release of fission products to the environment is con olled by the rate of containment leakage. The 45 A m.,;, ) con ainrent was designed with an allowable leakage ra oll%W c. Agg h [ of containment air weight per day (Ref. 3). t,,6 *4* '4 4 ftstige r u defined in 10 u p, appenvix v gue 1), as L.: O'.(%f d(*e

         'I'      M                                           e maximum allowable            ntainment leakage       e at
                       ,h  ed c.A.                             Ethe ca ulated maximum peak ontainment prassu_ rp P.) of j                                        .

35.' si , which result J d[e an gatg* MSLB (Ref. ram na limitino DEA. which 11 a~ reus at , Id4 9.{I s.h')' ).f This allowable leakage rate forms the basis for the acceptance criteria imposed on the , 6%

kg A SRs associated with the air lock.

                                                                                                                                 -A, LotA/                        For dual containment, t DBAs that result in a releas h radioactive material                    thin containment are a LOCA, a MSLB.

and a CEA ejection a ident (Ref. 2 . each of these acci nts, it is assum)ed that contalIn nt theisanaly 5 of OPERABLE such tha release of fission products t the 3nvironment is ntrolled by the rate of conta nt hakage. The ontainment was designed with a allowable leekage rate f [0,50]% of containment air icht per day

l (Rei. 3),

Appen11x is leakage rate is defined i 1U LtR 50, (Ref.1), as L.: the maximum lowable

                                      ,conta) nt leakage rate at the calcul ed maxir.3m peak contaip,wnt pressure (P.) of [42.3                         g, which results fron                          '

the 4mising DBA, which is a 75% R al MSLB (Ref. 2). This able bakage rate forms the asis for the acceptance i teria imaa - -t+ha th att i>+=A u" te 9 Inck ) The containment air locks satisfy Criterion 3 of the NRC Policy Statement. jw3sse l>.-)=r 4 -_- ~ l. LCO Each containment air lock form part of th containment pressure boundary. As part of containment the air lock safety function is related to control of the containment leakage rate resulting from e DBA. Thus, each air lock's structural integrity and leak tightness are essential to the successful mitigation of such an event. (continued) CEOG STS B 3.6-12 Rev 1, 04/07/g5

Containment Air Locks P ' W r k W 0. 1) B 3.6.2 @ BASES LC0 Each air lock is required to be OPERABLE. For the air lock (continued) to be considered OPERABLE the air lock interlock mechanism must be OPERABLE, the air, lock must be in compliance with the Type B air lock leakage test, and both air lock doors must be OPERABLE. The interlock allows only one air lock door of an air lock to be opened at one time. This provision ensures that a gross breach of containment does not exist when containment is required to be OPERABLE. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following pcstulated events. Nevertheless, octh doors are kept closed when the air lock I

 ,s is not being used for nomal entry into containment.

xit from o r-

                                                                                             /7    b' i

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these N00ES. Therefore, the containment air locks are not required in MODE 5 to prevent leakage of radioactive material from containment. The requirements for the containment air locks during MODE 6 are addressed in LCO 3.9.3, ' Containment Penetrations." ACTIONS The ACTIONS are modified by a Note that allows entry and exit to perform repairs on the affected air lock component, if the outer door is inoperable, then it may be easily accessed for most repairs. It is preferred that the air lock be accessed frem inside primary containment by entering through the other #ERABLE air lock. However, if this is not practicable, or if repairs on either door must be performed frc.i the barrel side of the door then it is pemissible to enter the air lock through the OPERABLE door, which means there is a short time during which the containment boundary is not intact (during access through the OPERABLE door). The ability to open the OPERABLE door even if it means the containment boundary is temporarily no,t intact, is acceptable because of the low probability of an event that could pressurize the containment during the short ' time in which the OPERABLE door is expected to be open. After eNt entry and exit, the OPERABLE door must be (continued) l CEOG STS B 3.6-13 Rev 1, 04/07/95 l

t Containment Air Locks 12"x;h:& rd B 3.6. i;,P[ @ BASES ACTIONS C.1. C.f. and C.3 (continued) Additionally, the affected air lock (s) must be restored to OPERABLE status within the 24 hour Completion Time. The ' specified time period is considered reasonable for restoring an inoperable air lock to OPERABLE status, rssuming that at least one door is maintained closed in each affected air lock. D.1 and D.2 If the inoperable containment air lock cannot be restored to OPERABLE status within the required Completion Time, the plant smst 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 basedonoperatingexperience,toreachtherequiredplant conditions from full power conditions in an orderly manner and without challenging plant systems. SURVEILLANCE SR 3.6.2.1 REQUIREMENTS Maintaining containment air locks OPERABLE requires (papliance with the leakace rate test requirements of I'$ c f M * '.*4 O 0F , Annandi/J (Ref.1), w ooamea Dv accroqrec) 6 j I are tion C This SR reflects the leakage rate ",esting - Lokw~p#A # requirements with regard to air lock leakage (Type B 1eakage tests). The acceptance criteria were established during . 7e's h 7 I /*7' # initial air lock and containment OPERABILITY testing. The periodic testing requirements verify that the air lock leakage does not exceed the allowed fraction of the overall o_ntaineertt_ leakage rate. Th_e Frequency is required by ppendly J as moa m ea py inua, - A to M r2_(which allows Fos /pprovea exemppens. a=new artans M ns) does not a y. j 41 The SR h:s been modified by two Notes. Note 1 states that an inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test. This is considered reasonable since either air lock door is capable of providing a fission product barrier in the event of a DBA. Note 2 has been added to this SR requiring the results to be evaluated against the acceptance criteria of (continued) CEOG STS B 3.6-17 Rev 1, 04/07/95

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

t ContainmentAirLocks(A;n:;h:-it :M N:1;- B 3.6.2 C SASES SURVEILLANCE SR 3.6.2.1 (continued) REQUIREMENTS SR 3.6.1.1. This ensures that si leakage is properly I j ounted for in determinin neent oakage , e pli<,lle h SR 3.6.2.2 The air lock interlock is dest ned to prevent simultaneous opening of both doors in a sin le air lock. Since both the inner and outer doors of an at lock are designed to withstand the maximum expected post accident containment g, kg h pressure, closure of either door will support containment OPERABILITY. Thus, the door interlock feature supports

              -    -                        containment OPERABILITY while the air lock is being used for N4 4"*]hi-                        personnel transit into and out of containment. Periodic
                --       -=->                 testing of this interlock demonstrates that the interlock will function as designed and that simultaneous opening of v            < - -                         the inner and outer doors will not inadvertently occur. Cue used fu erd 7 ,,,) n;f                   to the curely mechanical nature of this interlock, and given (F * # dre I re                           that the interlock secnanism is h a4y challenged when M4eenc., ,(,
                                      /d      2           _ ; M onteced, this test is only required to be
                            ,p;re g ,. / ' ; pe.1;irformsd r;:n :nt: ring cent:i- : t St i: ::t 7:wir:d :::: M yeo ~ )                   '74 "e"V                                                             The 144-.d Tsvr       p
                                              'rased a :-il, o ::.ei. m   .,j;00           Jeye.

4 u__..udgmen,t and is !e, ngineering co._nsi'ty Frequency is e\

                                              .,i _ 3 ,n3e.3                    _ _ _      > - - -    > -    _   -.

red adequate Je { S

   ~""ggjrg7~ 6' ,f./. 2, $f 3 t42 $!:1:0 T! il dl; ie -y..ei'e.74 per ;nT.^).         i

_ _ = - f Q4 ***l . ,

     ,,_,, % J EFERENCES                      1. 10 CFR 50, Appendix J i

p'V'A / 'r/**h 2. @ SAR, Section (,4 Q uu c,r & .,":,scn,?

                           '/                 3. $ $AR, Section M .

u 7^, <c,< < r bh f a 1 CEOG STS B 3.6-18 Rev 1, 04/07/95 4 l l l

1 i i INSERT B 3.6,2 SR 3.6.2.2 every 24 months, ~lhe 24 month Fmquency is based upon the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for loss of containment M W OPERABILITY if the Surveillance were performed with the reactor at power. The 24 month fsff l? Frequency for the interlock is justif.ed based on generic operating experience. .x i-i J 4 4 4 1 5

l Containtsnt isolation Valves (--"--" " " Qi B 3.6.5-1 8 3.6 CONTAINMENT SYSTEMS B 3.6.3 Containment isolation Valves -(^.'t=;brk- =d Mlb Basts

i BACKGROUND The containment isolation valves form part of the

 / ..                                   1 containment pressure boundary and provide a means for fluid 3 h tolid Q ei ;3 j,3 1/,        4      i penetrations not serving accident consequence Itaittag
        "" g* e**UM d'9t                      ekosedonanautomaticisolationsignal.s            Thesestems isolationto be provided with two is i
         *"a 6b { 396 ;.,

3 devices are either passive or active (automatic). Manual valves, de-activated automatic valvas secured in their pggO h O *M *" closed position (including check valves with flow through /1 the valve secured), blind flanges, and closed systems are IU uuih . C/ it,.c ,b ed considered passive devices. Check valves, or other U J,)g g "3d *# UM I automatic valves designed to close without operator action following an accident, are considered active devices. Two

         NT d Nc.bs is                     barriers in series are provided for each penetration so that isf & L . Uu4;) p                   no single credible failure or malfunction of an active i

y ;g*4**' U "'q g". component can result in a loss of isolation or leakage that 1

         *Py% % bk;., A                      exceeds limits assumed in the safety analysts. One of these barriers may be a closed system.

PW3 e ..,h EA.4 >

          ; % g*0 N S 'd' D g* .

Containment isolation occurs upon receipt of a high containment pressure si p'"* one i ry coa,;,,,aA nrm on,uurn umi. gnalformow Remor L.ouen ahees The containment isolation signal C#d* "*. r.%

               *4 000hrye.otuT4.

Q &6.t closes automatic containment isolation valves in fluid fsetc,A,W \!a\m art u penetrations not required for operation of Engineered Safety 4cr Co V,-W hoev o;,a Feature systems in order to prevent leakage of radioactive ChuaoryAW bWh. dai material. Upon actuation of safety injection, automatic jib we "^ containment isolation valves also isolate systems not d.n.g y , required for containment or RCS heat removal. Other penetrations ars isolated b position 0;* blind flanges. yAs thea use of valves result, in the -losed the containment 1 solation valves (and blind flanges) help ensure that the containment atmosphere will be isJiated in the event of a ! h release of radioactive material to containment atmosphere from the RCS following a Design Basis Accident (DBA). The CPERABILITY requirements for containment isolation-valves help ensure that containment is isolated within the time limits assumed in the safety analysis. Therefore, the OPERABILITY requirements provide assurance that the containment function assumed in the accident analysis will be maintained. (continued) CEOG STS B 3.6-19 Rev 1, 04/07/95

N Containment Isolation Valves (?*- "

d M g 83.6.5 BASES (continued)

LC0 Containment isolation valves form a part of the containment boundary. , The containment isolation valve safety function is related'to minimizing the loss of reactor coolant inventory and establishing the containment boundary during a DBA. The automatic power operated isolation valves are required to have isolation times with'.n limits and to actuate on an automatic isolation sinul.a The p valves must - maintal sealed cl ;or hay cks installe prev ull ope [31ocks urce valves a<1 actualg, on automatice 11 The valves covered by this LCO are listed ~with their assocliited stroke times in the ry2 (Ref.1), b-$ @ The notwally closed isolation valves are considerer 5;'4BLE when manual valves are closed, automatic valves are de-activated and secured in their closed position, blind f1 es' are in place, and closed systems are intact.f These )n b_~ ve IsolatT5W7&lves or devices are Encsc tisted in j C A ;.> - A p se.sypt,

                                                                                                                 @'/A 1

4 or b sf 4*ld es eterence Q O 7 urge valves Ith resilient sea hypass val s) must meet addl ona and secondary contal nt 5 behere Weak laakage rate 4 % g4 (be%ho-> eequire s. The other co inment isolation valve eskage Di'RMrLIT'j 3(g g,,,63, a s addressed by LC h Sl+E b wi.M < 6 ~

                                                                      .6.1, ' Containment,' y ype C _          g l

l cM L 1i. tole % 3n;,- This LCO providfs assurance that the containment isolation { b % Creger k c.4 valvetY fuenctio urge va36) will perform their designed safety sinimfre the loss of reactor coolant inventory 6 t-o w b.,,, g, ut,g) I and estabitsh the containment boundary during accidents. Od56(f W ) dee c g ,J. APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, the containment isolation valves are not required to be OPERABLE in MODE 5. The requirements for containment isolation valves during MODE 6 are addressed in LCO 3.9.3,

                               ' Containment Penetrations.'

(continued) CEOG STS B 3.6-22 Rev1,04/07/95

Containment Isolation Valves p; r " % d ..P - $ p3.6.5 . i IASES (continued) ACTIONS The ACTIONS are motified by a Note allowine menatrat' on flow ! ath excan ror u nen ;.r. m we senetst- an um so se un so asee~ 1nters10ent'y unser aan' nts .rettve

                                                                                                                                                                         ,C c

i s. W These administrative controls consist of stationing a dedicated coerator at the valve. controls, who is in continuous communication with the control room.- In -, this way, the penetration can be rapidly isciated when a r A L A . M .//,s s d e % t b . Co.it,a( $ s M ?

                                            ""d    '" *"*..*
                                            'sise er ne that
                                                                            .ei t-a"'"

_ . .

i.e.

se penetrations uh st directly from the d l

                                                                                                      '.'r'i ne.'t. _i. -" i ' i "d i '_ '.r**e fact u en'a"nd               3        :

con inment atmosphere to 5 g,,ja 8 O .d4 #fdatef environment thes alves may - he onened under intrativecantemIn Yn KCf-te'7"j"'" j 'I .< 300'r -/o A second Note has been added to provide clarification that, for this 1.00, sepa ate Condition entry is allowed for each af;f,j/;g-#3C [j'd* netration flow path. This is acceptable, since the NguiredActionsforeachConditionprovideappropriate M th/e 4. p I. ire.p compensatory actions for each inoperable containment f Om M/% e,n isolatiot valve. Complyi allowforcontinuedoperaNorwithand thesubsecuent Required Actions inoperable may i , MM f Mo * //W containment isolation valves a,re Condition entry and application ofoverned associatedby subsequent Required Jte p g Actions. uh4hr A d. - The ACTIONS are further modified by a third Note, which ensures that appropriate remedial actions are taken, if necessary, if the affected systems are rendered inoperable by an inoperable containment isolation valve. jAf rth Note s been ed the quires ntry int he a cable iti d Reg Actio of LC0 .Iw] hen-kage ults in ceedine e over contai tleakage) limit.F Q A.1 and A.2 In the event one containment isolation valve in one or more menstration flow paths is inoperable Foxcep purge va leakgand shtaWbutiome u-..s 11aEJ, the affected penetration flow path must be isolated. is akane ithin g The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic contairaent isolation valve, a closed manual valve, a blind l

\<

(continued) CE0G STS B 3.6 23 Rev 1, 04/07/95-e'me.u - e- 4 -e >%g.m-rg.+-e- -a,e%--t ---r. _ e w. w -s - - -

                                                                                                                                                                              -s   -

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

Containment Isolation Valves (A6mes $ t d S A B3.6.5 C sAsES ACTIONS A.1 and A.2 (continued) flange, and a check valve with flow through the valve secured. For penetrations isolated in accordance with A Required Action A.), the device used to isolate the I.M penetration should be the closest available one to 4 containment. Required Action A.] must be completed within 4 the 4 hour Completion Time. The 4 hour Completion Time is reasonable, considerfr*g the time required to isolate the penetration and the relative importance of supporting containment OPERABILITY during MODES 1, 2, 3, and 4. For affected penetration flow paths that cannot be restored to OPERABLE status within the 4 hour Completion Time and that have been isolated in accordance with Required Action A.1, the affected renetration flow paths must be vertfled to be isolated on a periodic basis. This is necessary to ensure that containment penetrations required to be isolated following an accident and no lancer capable ! of being automatically isolated will be in the Isolation position should an event occur. This Required Action does not requirs any testing or device manipulation. Rather, it involves verification, through a system walkdown, that those isolation devices outside containment and capable of being mispositioned are in the correct position. The Completion Time of 'once per 31 days for isolation devices outside containment" is appropriate considering the fact that the devices are operated under administrative controls and the probability of their misalignment is low. For the isolation devices inside contst'mrit, the time period specified as

                                ' prior to erterir.g M005 4 from h00f 5 if not performd within the prsviout 92 days' is based on engineering judgment and is :onsidered reasonnole in view of the inaccessibility of *ke isolation devices and other administrative controls that will ensure that isolation device misaligament is an unlikely possibility.

Cor.dition A has been modified by a Note indicating that this Condition is only applicable to those with teto containment isolation valves. pen Fctration flow paths

                                                                                                  ' penetration  flow qwi %4 a               paths with only or.e containment isolation valve and a closed gg         .}, m system.ConditionCprovidesappropriateaction3 Rcquired Action A.2 is modified by a Note that applies to g

isolatic, devices located in high radiation areas and allows . these devices to be verified closed by use of administrative (continued) CEOG STS B 3.6-24 Rev1,04/07/g5 4

Containment isolation Valves P' :$nk .d LW (D 83.6.$ BASES ACTIONS A.1 and A 2 (continued) means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Therefore, the probability of misalignment of these devices, once they have been verified to be in the proper position, is small. RJ With two containment isolation valves in one or more i@ penetration flow paths inoperable K ept for purge v leaty anc spielirE Mou oroa ankane not wi et

lia[f with<y,I hour.the affected penetration flow path must be isolated n The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a sir.gle active failure. Isolation barriers that meet this criterion are a closed and de-activated A automatic valve a closed manual valve, and a blind flange. - TheIhourCompletionTimeisconsistentwiththeACTIONSof f.ZA LC0 3.6.1. In the event the affected penetration is isolated in accordance with Required Action 8.1 the affectedpenetrationmustbeverifiedtobeisoittedona periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolatter. following an accident are isolated. The completion Time of once per 31 days for verifying each [ affected penetration flow path is isolated is appropriate I considering the fact that the valves are operated under administrative controls and the probability of their misalignment is low. ! u(g\ Condition 8 is modified by a Note indicating this Condition is only applicable to penetration flow paths with two Dg. " ' * ' _ containment isolation valvet. Condition A of this LCO . ns accresses the concition of cine containesnt isoletion valve /M Sph inoperable in this type of penetration flow path. C.1 and C.2 ' {,7 m or t With one or more penetration flow paths with one containment isolation valveTAnoperable, the inoperable valve must be

                                                                                                                                 @I       h restored to OPERABLE status or the affected penetration flow (continued)

CEOG STS 8 3.6-25 Rev 1. 04/07/95

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

Containment Isolation Valves (Atmospheric and Dual B 3.6. BASES ACTIONS U and 0.2 (continued) pati. erst be isolated. The method of isolation aust include the ese of at least one isolation barrier that cannot be advern. affected by a single active failure. Isolation ! barriors,that meet this criteritin are a closed and de-activated automatic valve, a closed manual valve, and a 4\

                                                                              ^        blind flange. A check valve may not be used to isolate the                                                  la affected pe                             Required Action C.! must be completed within the hn tration. hour Completion Time. The specified                                          time r:T7F" period is reasonable, considering the relative stability of the closed system penetrationisolat(hence,                     reliability)toactasa ion boundary and the relative importance containment OPERABILITY during MODES 1                 2, 3 of andsupportinhe

4. In t event the affected penetration is isolated In accordance with Required Action C.), the affected penetration flow path must be verified to be isolated on a

! periodic basis. This is necessary to assure leak tightness of containment and that centainment penetrations requiring i isolation following an accident are isolated. The Completion Time of once per 31 days for verifying that each i affected penetration flow path is isolated is appropriate e considering the valves are operated under administrative controls and the probability of their misalignment is low. Condit ion is modified by a Note indicati g at this

l Condition is nly applicable to those pen tration flow paths with di@ one containment isolation valv and a closed system,4 This Note is necessary since this Condition is written to specifically address those penetration flow paths N '3a inaclosedsystemf h MNS O'I Required Action C.2 is modified by a Note that applies to valves and blind flanges located in high radiation areas and 64 C.t. allows these devices to be verified closed by use of

                                                                                                                                                                                                  /h i administrative means. Allowing verification b                                                              3
                                                                                                                                                                                                 %4 administrative means is considered acceptable,ysince access to these areas is typically restricted. Therefore, the probability of misalignment of these valves, once they have been vertfled to be in the proper position, is small.
                                                                                                                                                                               ~^

u W h the secondary containment thin limit, the assumption pass leakage rate not f the safety analysis ar ot b (continued) CEOG STS B 3.6-26 Rev 1. 04/07/95 W-- --- - . - . -- - - _. - - - - - - _ - - - - - - - - - -_-. s -- r _ - - - -

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

Containment Isolation Yalves (" - T : t x S' }- B 3.6.3 C BASES SURVEILLANCE SR 3.6.3.1 , REQUIREMENTS (con nued) j opening of a co ainment purge valve, tailed analysis of the purge valv abilit failed to conclusivel demonstrate their doser.y to c1 e during a LOCA in ti to limit offsite Ther ore, these valves are equired to be in the i ' sealed clo d position during MODES 2 3 A containee purge valve that is se edcloseand4. d must have motive p er to the valve operato removed. This can be accompi hed by de-energizing th source of electric p or by moving the air supply t the valve operator. I this plication, the tenn 'se ed' has no connotatio of leak ightness. The Frequene is a result of an NRC ini istive, Generic Issue B- (Ref. . related to _pm ' Nfye.p cotainmentpurgevalveuseduringun@itoperations This Sk i not required to be met his is reasonable since eile in Condition E of his LCO. penetration flow p h would be isolated. j

                                                                                                      ~         _ J SR 3.6.3
                                                                             ,l        g This SR ensures that         he                valves re closed as required or, if open,1 ope                    allot.ab reason, if a valve is open i cod **tVM                cons dered inoperable violation of this .R. the valve is If the inopera e valve is not otherwise known to ha              excessive lea ge when closed, it is not considered to haveieakage outsi of limits. The SR is not required to be met uhen the                     valves are open for pressure control, ALARA or air q                  y considerations for personnel entry, or forJurveillancesthatrequirethe valves to be open. The pyri-m valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment isolation valve requirements discussed in SR 3.6.3 Q SR     3.6.3.

og g g*g> This SR requires verification that each containment isolation manual valve and blind flange located outside A f*I'd>8E'**

      -4 w'ed                      containmentaand required to be closed during accident                                            fa

_conattionsls closeda The SR helps to ensdre that post 7gp Af accicent seakage of radioactive fluids or gases outside the (continued) CEOG STS

                               - _ _ - - -- - _ .5 3.6-29                                      Rev 1, 04/07/95
             % Co.d s==A Prge.A Edosi
              %(sbAfss          (Roitek % (41&

ma ceceae,oTv sta m.-a k& Y*b % N 'St i*j f M & p - e r 4,

              % * % \e d w % p., ce , w ,z ,

m

Containment Isolation Valves *-t-i t d MP B3.6.$ O sAsES SURVEILLANCE SR 3.6.3 REQUIREMENTS continued) b containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those containment isolation valves outside containment and capable of being mispositioned are in the correct position. Since 1 verification of valve position for containment isolation valves outside containment is relatively easy, the 31 day [ Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. { .TOSEU] Containment isolation valves that are open under g3'g*3 administrative controls are not requir 5 R.s 34,3.7- - during the time tie valves are open.*)ed to meet the SR27F #5' - ) gA 3.le.3. % ) The Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing h verification by administrative means is considered acceptable,'since access to these areas is typically restricted during MODES 1, 2, 3 4 and for ALARA reasons. Therefore, the probability of m,isalignment of these containment isolation Salves, once they have been verified to be in the proper position, is small. SR 3.6.3

   /                   M ej>        This SR requires verification that each containment
 ,4 "se=d I.D, s e ^d'                1 solation manual valve and blind flange located inside centainment4 and required to be closed during accident                     !
                             ,,g F Qohen m,,J 4

concittons7s closed. The SR helps to ensure that post

           ~~~~~

accident leakage of radioactive fluids or gases outside the 7J$4[ containment boundary is within design limits. For containment isolation valves inside containment, the-Frequency of

prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days' is appropriate, since these containment isolation valves are operated under administrative controls and the probability of their misalignment is low. Containment isolation valves that are

       $dSfRT                      open under administrative controls are not re gg                         the SR dt. ring the time that they are open.e] quired           ..gtog meet
      & 3 (p.3.t N N '3' 3 The Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by h

(continued) CEOG STS B 3.6-30 Rev 1, 04/07/95

(KTFkRkb - INSERT _ B 3.6.5 sRs 3.4.3. 2. c ..d 3. 6 . 3. 3 This SR does not apply to valves that are locked, sealed, or otherwise secured in theb closed position, since these were verified to be in the correct position upon locking, sealing, or securing.

                  + w e

4

Containment 1 solation Valves mmp-y M %p 83.6.5. g 8ASES SURVEILLANCE JL.,'.6.3 REQUIREMENTS (continued) administrative means is considered acceptable, since access h to these areas is typically restricted during MODES 1, 2 and 3 for ALARA reasons. Therefore, the probabilit misalignment of these containment isolatior. oncevalves,y of . they have been verified to be in their proper position, is small. SR 3.6.3. ,,. ,put/e t) I j Tse d 'd 5 Verifying at t e isolation time of eachquee operAWd anj m mg ,Mficcff, automati ysr#-4 containment isolation valve is within limits is~ Cr o (fasel bWest required to demnn.trate OPERABILITY. The isolation time

O test ensures the valve will isolate in a time period less than or equal to that assusied in the safety analysis.s*{The A

   'Pvty < ,4 f Lm f                     isolation time and frequency of this SR are in accordance VJ~

g with the Inservice Testing Program (iiqps] , k NN5e re the3 ore r 3.6.3.6 ~ y,,,4 g g , [ SR clagg , 4 1 For containment purge alves wit r 111ent seals, i additional leakage r e testing e quirements of 10 CFR 50 Appe ix J Ref. is required OPERA 8ILITY. Opertingex(perie$.yondthetest ensure nce has demonst ted that #~3U this type of seal as the potential to degra in a shorter t'.pe period than do other seal types. Base on this observation and he importance of maintain g this 4 ' penetration 1 tight ath between containment d the env(due ironment), to athe Fradirect ency of 184 days was establi ed as part of the NRC res ution of Generic Issue -20 *Conteineent Leakage Due Seal Deterioration" (Ref. . Additi openi ally, this SR aust be per need within 92 days after the valve. The 92 day F quency was chosen rec zing

hat cycling the va've could introduce add ional seal degradation va e that has not been open( ) yond that occurring to a

                                                                                   . Thus, decreasing the terval (from 184 days) 1 a prudent measure after a valve as been opened,                                                              j (continued)

CEOG STS B 3.6-31 Rev1,04/07/95

l I l Containment isolation Valves 4 - 8 3.6. BASES

4 SURVEILLANCE ~ SR 3.6.3.9 T REQUIREMENTS (conti ed) ~l equal to the sp fled leakage rate. This provid assurance that he assumptions in the safety an sis are met. The lea pe rate of each bypass leakage t is assumed to tne maximum pathway leakage (1 the worse age through the two isolation valves un1 the penetrati is isolated by use of one)clo and de-activ ted automatic valve closed ma 1 valve or blind flange in this case, the leakage rat of the isolated 4 bypas leakage path is assumed to be e actual pathway lea ge through the isolation devic . If both isulation

va es in the penetration are clo d, the actual leaksge r e is the lesser leakagr rate the two valves. This thod of quantifying maximum !

hway lcakage is only to be Appen x J maximum pathway leakage j usedforthisSR(i.e.lfied limits _are to be quant n accordance with Appendix J) The Frequency is required 10 CFR 50, Appendix J. as [ modified by approved ex lons and therefore, the Frequency extensions of - the testing is an App dix.J.3.0.2(may Type C test. not be,This applied) since imply S imposes additional eptance criteria. k (Bypass leakage , considered part of L, (Re ewer's Note:

                       \ _ Unless specift                  lyexempted).]

REFERENCES 1. hSAR, CSickfon / D. j2. 7 S?pf Section [ ). ] g I

3. neric Issue B-20 4 Generic Issue 24. F

5. 10 CFR 50, pendix J.

                                                                                                                                 @ !b CEOG STS B 3.6-33                                        Rev 1, 04/07/95

4 4 t-i Containment Air Teeperature *- ' '- ' - " g-BASES (conM'ved) i i L ! .. ACTIONS L1 1 When containment average air temperature is not within the-limit of the LCO, it must be restereo to within limit within

8 hours. This Required Action is necessary to return

[ 1 operation to within the bounds of the containment analysis. . I

                                                         -The 8 hour Completion Time is acceptable considering the                            '

i sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems. ; i: .. B.1 and B.2 ). If the containment average air temperature cannot be ' restored to within its limit within the required Completion 4 Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, tha plant must be brought to at least MODE 3 within 6 hours and to MODE 5 1 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. ' 1: , SURVEILLANCE SR 3.8.E.1 ' 4 REQUIREMENTS I Verifying that containment average air temperature is within i the LC0 limit ensures that containment operation remains ! within the limit assumed for the containment analyses. In

i. -

order to detemine the containment average air temperature, A b k Cm6,*ehan ar1*h= tic averaos ae iocat$onysittw istomhe3,s.na 3 thy calculated using seiected measurements to provide a taken g -@~ Qg g g: representative sample of the overall containment atmosphere. The 24 hour Frequency of this SR is considered acceptable C,cmWem4 Reader based on the observed slow rates of temperature increase within containment as a result of environmental heat sources C a4 tweree i g;gfo rg

                                                          <due to the iar e voiume of containment). rurthe more, the 24 hour Frequen ,cy is considered adequate in view of other indications available in the control room, including alarms, to alert the operator to an abnormal containment temperature condition.

(continued) CE06 STS B 3.6-42 Rev 1, 04/07/95

i. 4 L I i-i 4 Containment Spray and Cooling Systems "^ " ' - " ^ " j @ 83.6 8 g B 3.6 CONTA1101ENT SYSTEMS ?- 0 3.6. $ Containment Spray and Cooling Systems (^.'-::f :M : r d 5 4 i (C--ft ' N ... ', 4 . . - . -, J., % = :--- ^ --- ^ - ' @ , t BASES i

                                              -SACKGROUND                         The Containment Spray and Containment Cooling systems

< provide containment staosphere cooling to limit post A accident pressure and t reture in contsineent to less than the design values. uction of contaiement pressure i and the todine removal capability of the spray reduce the i M release of fission product radioactivity from containment to MM Appeerl,x K> the environment, in the event of 6 Design Basis Accident DBA) to within limits. The Containment Spray and 4'4'/a- F8, 59j s,oj { onta neent Coolin, systems are designed,to the requirements.

                               .p                                                 UT IU P 4 DU . m ..m ix ne sus
                                   , f. t, t. 3, c4    #
                                                             ,,j gg-              Remova'. ,'         39, " Inspection wie w , _

Containment Heat Remo a rwas Systems,' (q* h , 3ystems 40, " Testing of ontainment Heat Remova GDC 41, 'Contal t Atmosphere Cleanup," 42,

                                                                                  'Inspe ton of Containment teosphere Cleanup Syst s," and
                                                                                             , ' Testing of Conta              at Atmosphern Clean                 Systems' or other doc            nts that were ap Re.1)licensino(ide

__ of ified an m ==i* -propri et '._ M i e at the The Containment Cooling System and Containment spray System

are Engineered Safety Feature (ESF) systems. They are designed to ensure that the heat removal capability required during the post accident period can be attained. The Containment Spray System and the Containment Cooling Cystes provide redundant methods to limit and maintain post accident conditions to less than the containment design values.

Containment Sorav System of gpg,g The Containment Spray System consists of two separate trains C*#* of eaual canacity, eaciganam or una t----nan annua A SurMi T Each train incluces a containment spray pump, spray headers, ap/v- h, del'I p g Jnozzles, valves, and piping. Each train is powered from a-

                                ,( 4 *f                                          separate ESF bus. The refueling water tank (RWT) supplies UP c a d',aj.                     borated water to the containment spray during the in,jection
                                f de W                                         phase of operation. In the recirculation mode of operation, containment spray pump suction is transferred from the RWT to the containment sump (s).                    -

fr.A sprq 1 3$+ee 'Sua PA y Ow.%, c.enWeedt sW Mn be, VI* p 0?6A A% LE -

                                                                                   ,sMaos coo \ipoed eytisaget ,                                               (continued)

CE06 STS B 3.6-44 Rev 1, 04/07/95

Containment $ pray and Cooling Systems WW:M: n. @ r:B 3.6.8 a% MSIS SACKCROUND Containment inriv tv1133 (continued) The Containment Soray intes prov1Jes a spray of cold boraled waterUg.ngsonna me, nourrroir7trigsp @

                              ="armC5mlMo the upper regions of containmErto                                                 W reduce containmer.t pressure and temperature and to teduce                                               i the concentration of fission products in the containment atmosphere during a D6A. The RWT solution tesperature is an importent factor in eeteretning the heat removal capahtitty of the Containment Spray $ystem during the injection phase.

In the rectrculation mode of operation heat is removed from the centainment sump water by the shutdown coolin heat exchangers. Each train of the Containment $ pray ystem provides adequate spray coverage to meet 50% of i e system design requirements for containment hest removal and 100% of the lodine removal design bases. 7he Spray Additi ^ system injects a n razine (N,H ) solution into e spray. The result g alkaline pH of the jsprayenhanc L/

its ability to scave e fission products f the contal nt atmosphere. Tha 4 added to the spray also ensur s an alkattne pH for e solution rectreulat d in l the cent nment sump. The alka' ne pH of the contal t sump w er ministres the evolu,tton of todine and mini tres { the corrence of chloride apd caustic stress corro6 on on -I Wq nicQ.systemt and enanonents arnread in the n6u d The Containment $ pray System is ac_tgated either g *Ia fd automatically by a @ftainment nwn viervra..vro signa, 8(far coincident with a safety injection actuation signal ($145? u b Aren h or manually. An automatic actuation nam numa n-ro 1pra use agingtge.yalysit, starts the two Containment gh

                              $pra     ystem pumps and begins the injection phase. The W.>

containmentspraybeaderisolationvalvesopenupona containment spray actuation signal. A manual actuation of the Containment $ pray System is available on the main control board to begin the same sequence. The injection phase continues until an RWT level low signal is received. The Low level for the RWT generaten a recirculation actuation signal that aligns valves from the containment spray pump suction to t.ie containment sump. The Containment Spray $ystem in recirculation mode maintains an equilibrium temperature between the containment atmosphere and the recirculated sus.p water. Operation of the Containment spray

                             $ystem in the recirculation mode is controlled by the (continued)

CEOG STS 8 3.6-45 Rev1,04/07/g5

t Containment $ pray and Cooling Systems (ir:;5': W Sn O3.6.% 1 BA$t$ (continued)

                                      "8      During a DBA a minimum of 3
                         -_ _lC0                                                   con                  41 l

containment spray trate_--r tainment w enacooling h'_A% [a6 gcar cae(ett) is required to maintain the containment Mat tressure and taargrature ba9 0 the design lietts (Ref.U P). AdditionaHy, eng tontainmen", .m w h h spray tra.a is also regiT red to remove todine from the \1/ 6.A4(sprA353slen Mcw containment atmosphere and maintain concentrations below p A b h en W etal those assumed in the safety analysis. To ensure that these

 . Swy wW b.a view c.^                       requirements are met, two containment s ray trains and two t untainment coolina att must be OPE Lt. Therefore in                     deceri
                                                                                                                     /

OPER. AME s heddet % M,e event or en accident, the minimum requirements are, met. *~ t @ J coe\lghtd eskagte,

assuming that the worst case single acthe failure occurs. I

[ach Containment Spra pump, spray headers, y Systemnozzles, p va ves, g)ipinoincludes a spray instruments, and controls to et.4ure an OP(RABLE flow pat 6, capable of , taking suction from the RWT upon an [$f actuation si nel and 4.A, gg,,aJ fr"1 5 s h 4 *d "[ 3 dutomatically transferring suction to the containmen! sump.y tach Containment Cooling Systen @gnc6tly] includes h g (' gtpfnC

dam y ,,4 es.iw mammeco coolingancoils contron to ensure OP [RABLpers, rans, instruments, and

                                                                              . flow path,                         g t'2('l ' TT                                                          ^

APPLICABILITY In M00t$ 1. 2 radioactive mate daDBA ould cause a release of ria to /contal nt and an increase in f N containment pressure and tempera ure, requiring the C'"I^.'" "f "i operation of the containment spr trains and containment IP% regu\re sys+em A ro k.e 55 twh [-wcooling trains. enknet 6 6 mg j @k in3M00t$4pnd6. he probability and consequences of these Pen 5eder pressucc events arrreduced due to the pres sure and temperature t l 7S'O psh. limitations of these M00ts. Thus.vthe Containment spray and Containment Cooling systems are not required to be OPERABLE

      ,                                     in MODE       nd 6.

ACTIONS Al

       ' MOM 14                             Pith one containment spray train inoperable, the inoperable containment spray train must l,e restored to OPERABLE status pet swrii n g regg,e               within 72 hours, in this Condition, the remaining OPERABLE spray and cooling trains are adequate to perfore the iodine (l'l$0ppS.4                         removal and containment cooling functions. The 72 hour Completion Time takes into account the redundant heat (continued)

CEOG $15 B 3.6-48 Rev1.04/07/95

Containment $ pray and Cooling systems ("- " -*- ' "- " t $.6.d Q BA$ts AC110NS M (continued) removal capability afforded b reasonable time for repairs,and y the Containment the low probability $ fray of aSystem, DBA occurring during this period. The 10 da Action A.y portion of the Completion Time for Required 1 is based upon enetneering judgment. It takes into account the low probability of coincident entry into two Conditions in this Specification couple'J with the low probability of an accident occurrino during this time. Refer to Section 1.3 ' Completion ilmes ' detailed discussion o,f the purpose of t$e. for a more

                                                                                       'from discover failure to meet the tCO' portion of the Completion Time,y of b.1 and R.f If the inoperable containment spray train cannot be restored to OptRA8LE status within the required Completion Time the Mobt 3 M 8u wes ,         plantv must be brought to a M00C in which the LC0 does n,ot aan;ea. To achieve this status, the_stl                           st be brought to f* W r e 4 np st swvi. 3 witnin a nevrs una IF                           within 3 hours. 1he allowed Completion Time of 6. hours is tinsonable, based on operating experience, to reach M00t 3                                      6 h!/   /

from full pcner conditions in an orderly manner and without c

                /2.             nging plant systems. The extended interval to reach allows additional time for the restoration of the containment spray train and is reasonale when considering that the driving force for a release of radioactive material from the Reactor Coolant System is reduced in C DE 3.
                      ?

e s,,:J p-e With one required containment cooling train inoperable the inanarabia raatainment coolina train must be re o f UPERABLE status within 7 days. TheYcomponentsl fg,g",'l N"kTN / aFe capable of providing at least 100% of the heat"*jjg

                          ._ 2 " -m=nm provide todine removal capab'g T, es and removal      y...

c.J.:. M W needs after an accident. The 7 day Completion Time was cuk / s.I developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment h $ pray System and Containment Cooling System and the low probability of a DBA occurring during this period. (continued) CEOG $15 8 3.6-49 Rev 1, 04/07/95

i Containment $ pray and tooling @ l 3.6.Systems ff= ;' A BA$t$ AC110N$ [ d (continued) l outside the accident analysts. Therefore, LC0 3.0.3 must be entered tamediately.

                       $URyt!LLANCE        1R     3.6. 1 REQUIREMENTS Q

Verifying the correct alionment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will entst for Containment spray System operett>n. This $R does not apply to valves that are locked sealed, or otherwise secured in position since these were,vertfled to be in the correct position prior to being secured. This $R also daes not appasycheck suc to valves valves. This or valve mant ulation. that

                                                                            $R cannot         be inadvertently does not require     any tes           misaligned (ing through a sys te walkdownRather, it involves verifying, that those valves outside j                                          containment and capable of potentially being mispositioned are in the correct position.

1R 3.6 QFi'

                                                                                  ,y      ;

G@ 2 ach containment coolino train fan unit for s'nutes ensures that all trains are OPERABLE and that 411 associated controls are functioning properly It also ensures that blockage, fan or motor fatture or e.xcessive i vibration can be detected and corrective action taken. The 31 day frequency of this $R was developed considering the

,                                      known reliability of the fan units and controls, the two 2

train redundancy available, and the low probabtItty of a significant degradation of the containment cooling train occurrin acceptab ebetween survetilances through operating and has been shown to be experience. D SR 3.6.ab h du b k*b be") i Verify 1 rig a service water flow rate of 1 2000 to each coolina unit provides assurance that the desig Swrate serWct vedet tsu41et assumed ~Tii~the safety analyses will be achieved (Ref. 2). l'h 4tges are M1ope)n _ reliability of the Cooling Water System. t were the known Alsoconsideredinselectingthisfrequencgetwotrain (continued) CEOG $1$ B 3.6-51 Rev 1, 04/07/95 i

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

i Containment spray and Cooltog Systems **--"-'t " 'n O 53.6 7 M$t$ suRyt!LLANCE 1R 2.8. RtQUIREMENTS 1 (continued) redundancy, and the low probability of a sientitcant degradation of flow occurring between survalliances. in1/s.sa.4 Ver fying that the contai t spray header piping is all ft I vel minimites the time r trod tofwatertothe[100)Thisensuresthatsprayflow fill the header. 11 be itted to the contal at atsesphere within t les frame ssumed in the centet fprobabilityofasign nt analysis. The 31 da Frequency is based on the static ature of the fill het and the low icant tNJradation of ter level in g the piping occurri tween surveillances. J in 1.E.a ) L% s e n.d s 1erifying that nach containment spraygump deve s O OW /b Mir/ p.id J r (t IJs01 Dsic c1 wrential pressups on rectre 9<<,4, /A. ,. 3,

                              ,6 . /-/o        that s                                                   tion ensures            Y.s# 78 cycle. prey pump performance nos nos owgraced curing theFlow and differe h    // , f.i ,;,,/ <! w '/ , f             centrifugal pump erformance required by Section XI of the l   eu.. I                                  ASME Code (Ref 6 . Since the containment spray pumps cannot be tested ith flow through the spray headers, they are tested point     on theon recirculation flow This test confires one performance. pump design curve an.d is indicative of overall Such inservice ins trend performance pections     confirm component OPERAllLITY, failures by               indicating and       detect abnormal    incipient performance The frequency of    this SR is in accordance with the Inservice Testing Program, in3.6.pIandSR 3.E.dp               r 6.e,* Ne aIperEria4c]

g These $Rs verify that each automatic containment spray valve i actuates to its correct position and that and containment (%Weted LIvh bhus Atha 45 slee(C5FAs) 5 Asetuation sinnaspray 1his pump starts uponisreceipt Survelliance of an for not required actual or simulated g '. Pp) I _ _

                                    ~/        valves      that at  locked,  sealed,    or othetvise  secured    in the    @         A 4/A y required           position under administrative controls. The p nth Frequency is based on the need to perform these ourvelliances under the conditions that apply during a plant                 g (continued)

CE0G STS 8 3.6-52 Rev1,04/07/95

Containment $ pray and Cooling Systems (** : @ AW rd S"8[ B 3.6.6 BASES

                                                                                     $URyt!LLANCE   1R  1.8.        nd st 1.8.

REQUIREMENTS (continued) i outage and the potential for an unplanned transient if the l Survel11ances were perfomed with the reactor at power. Operating experience has shown that these comp nts usually pass the surveillanm when perfomed at the month Frequenc . Thor'*i/t, .kr Frequency was conc acceptab e from a et'f 6 h n standpoint. to be g g The surveillance of evnu p a nt sump Isolation valves is ' also required by $R 3.4.0.5. A sin used to satisfy both requirements. gle surveillance may be i C - sk 1.8.a UA, M oppreptk% gggg g33A This $R verifles that each containment cooling train e 19 tes upo ipt of an actual or simulated actuation anaW The "q judgment and month Frequency is based on engineering been shown to be acceptable throughy @ l o>erating experience. See $R 3.6.6F6 and $R 3.6.667, e for further discussion of the basis for the month Fr quency. SR 1.s.sh.@ With the containment spray inlet valves closed and the spray 4 j j,.fj', header drained of any solution. Iow pressure air or smoke can be blown tnrough wa-~nna. Perfomance of this p

                                                                               ~L nc,4             $R demonstrates that each spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degradid u Due to the massive design of the nozzle, a test at @4 fir # refueling andAtD 10 year intervals is considered scequate so detect obstruction of the spray nozzles.

g REFERENCE $ 1. 5 > A._GDC 3[GDC 39 GDCgGDC 41, g uf'.5K N h<A).5

                                                                                                                                                       /         AC" 3.h$AR, ML'lbg.                             [

e4s @@ (continued) CEOG $1$ B 3.6-53 Rev 1, 04/07/95

Hydrogen Recombiners (Atmospher.ic and-On b B 3.6 @ BASES 1 ACTIONS B.1 and BJ (continued) With two hydrogen recombiners inoperable the 4bility to perform the hydrogen control function via alternate l capabilities must be vertfled by administrative means within I hour. TheJ1 ternate hydrogen control capabilities are ! .//u Q g,,m g providedbygtneconssi ,, i 6, y. ,, i.,, ,, 'im giym - Venl5 [$" raab ut / al in a.

                        . The I hour Comp'etion Time allows a reasonable per       f time to verify      La loss of hydrogen control fuartian doesg ot exist.        ev    r's notes ine r       ing lis tc b, u fa ir a non-src n         Specification alt    att hydr M rni runetta- 13 .uA + a he !h ete       e          ad
                                                                                          /A lin addition, the alternate hydrogen control system                         (,A capability must be verified every         hours the.eafter to ensure its continued evallability.         Both}'the performed as {an administrative                      m y be logscheck, or    by examininv other information to determine the availability o the                ,

alternate hydrogen control system. It does not mean to perform the Surveillances needed to demonstrate OPERABILITY of the alternate hydrogen control system. If the ability to perform the hydrogen control function is maintained, continued operation is permitted with two hydrogen recombiners inoperable for up to 7 days. Seven days is a reasonable time to allow two hydrogen recombiners to be inoperable because the hydrogen control function is maintained and because of the low probability of the occurrence of a LOCA that would generate hydrogen in amounts capable of exceeding the flammability limit. Ed Iftheinoperablehydrogenrecombiner(s)cannotberestored to OPERABLE status 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. The allowed Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. (continued) CEOG STS B 3.6-74 Rev1,04/07/95

Hydrogen Recombiners (**- O

                                                                                                                                       "--" -"B 3.6." "6    g 6A5E$ (continued)

(r c wrs sa ss

                                                                  $URyt!LLANC[

REQUIREMENT $ SR 1.6. 1 h m* M

A 4 A'* 8 A '* #

                                                                                                                                    "'S b  I l                                                                                    Performance of a {ystes function        est for each hydrogen          @  )

' recombiner ensurt .: that the rec iners are operational and fvf#f / f,(,,7 can attain and si stain the t reture necessary for hydrogen recoabli atton. In pa titular, this $R requires M f.6t?.'h verification thi the mini teator sheath temperature @ increases to 1 E D' Fins M T. grser Tne Dewer is m vaseano mammum gy manrant Ervmy v ivm,I

l 'I minuten and verif t4 ta ha > ao M3 @ erating expertence @ has shown that these components usual pass the survet11ance when performed at the month Frequency.}}

ML20217G357

Text

Navigation menu

Search