Text

Forwards Response to 970611 RAI Re License Amend Request to Convert to Improved Sts.Responses for Section 3.7,list Describing Each of Changes & Revs to Improved TS Section Also Encl
	ML20217G370
Person / Time
Site:	Calvert Cliffs
Issue date:	10/06/1997
From:	Cruse C; BALTIMORE GAS & ELECTRIC CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217G377	List: ML20217G370; ML20217G378;
References
	TAC-M97363, TAC-M97364, NUDOCS 9710100049
	Download: ML20217G370 (53)
	v • d • e

..-__ _________ _ ____ - __-__ -

CH Cl la ll. COtCl. llaltimate Oas und Llr4tric Comjtny Yke President Cah ert Chif s Nudrat Pow et Plant Nuckar linerpy 1650 Cahrn ChfIs Pa:Lw ay Lust y. Maryland 20657 410 493-44$$

October 6,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 A'ITENTION: Document Control Desk SUlijECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50-318 Itevislen 6 to the 1.icense Amendment itequest to Convert to the improved Icchnical SpedGCations (TAC Nos. M97363 and M97364)

REFERENCE:

(a) 1.etter from A. W. Dromerick (NitC) to C.11. Cruse (11Gl!), dated >

June 11, 1997, Request for Additional Inforrnation Regarding the Technical Speel0 cation Cnange Iwquest to Convert to the improved Technical Speci0 cations (TAC Nos. M97363 and M97364)

The referenced letter transmitted questions regarding Sections 3.7 of flaitimore Gas and Electric Company's application to convert to the Imnroved Standard Technical Specl0 cations.

The responses for Section 3.7 are provided in Attachment 1 of this letter Also attached to this letter is Revision 6 to the original license amendment application. These changes result from the responses provided in Attachment 1, as well as other changes identined by plant personnel. Changes to the No j Signincant llazards Considerations discussions are included where appropriate. /

To assist in reviewing this revision, a list describing each of the changes is provided (Attachment 2). All of the material for each change is grouped by change in Attachment (3) Attachment (4) provides the revision by improved Technical Specification Section for case of replacing pages in the original amendment request. Page replacement instructions are provided. All changes are marked with revision /

bars and are labeled Revision 6.

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9710100049 971006 * '

PDR ADOCK 05000317 p PDR

l

, Document Control Desk i October 6,1997

Pcge 2 j

'the Plant Operations and Safety Review Committee and a subcommittee of the Offsite Safety Review ,

Committee have reviewed revisions resulting in changes to the No Significant llazards Considerations I 1 and concur that operation with the proposed revisions will not result in an undue risk to the health and safety of the public. Should you have questions regarding this matter, we will be pleased to discuss them with you, i Very truly yours, e

'Y .

l STATE OF MARYLAND

y. ,,,e6 , es .+ ,

I TO WIT: f COUNTY OF cal. VERT l ;

I, Charles 11. Cruse, behg duly sworn, state that I am Vice l' resident, Nuclear Energy Division, l Italtimore Oas and Electric Company (110E), and (l.at I am duly authorized to execute and file this I

License Amendment Request on behalf of110E. To the best of my knowledge and belief, the statements j contained in this document are true and correct. To the extent that these statements are not based on my p personal knowledge, they are based upon information provided by other 110E employees and/or

! consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable. -

y y # &? y ,sv

/

Subscribed and sworn before me, a Notary Public 91 and for the State of Maryland and County of ,

l I'd h a n h , this[ppldayof Od&D(A/,1997.

WITNESS my lland and Notarial Scal: A4 AM > 'h1 &

! Notary Public My Commission Expires: b

, Date

CilC/ PSF / dim

Attachments: (1) Responses to Rcquest for Additionalinformation i

(2) Summary of Changes (3) Amendment Revision by Change 4 (4) Amendment Revision byITS Section 4

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

R. S. Fleishman, Esquire 11. J. Miller, NRC L J. E. Silberg, Esquire Resident lnspector, NRC i

Director, Project Directorate 1 1, NRC R.1. McLean, DNR A. W, Dromerick, NP.C J.11. Walter, PSC i

l

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NI'TACIIMENT (1)

IMPROVED TECilNICAL SPECIFICATIONS, REYlSION 6 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION llattimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 6,1997

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPEC 33 ICATIONS SECTION 37

DA COMMENTS 3.

7.1 DESCRIPTION

OFISSUE g 5/30S7 Correct tNs dw ew a.y.

3.7.1-1 A.3 ITS 3.7.1 ITS 3.7.1 ACTIONS wdouis a Note whch a!!ows ACTIONS sepcuole wdb> entry for each L1SSV. CTS 3.7.1.1 ACTIONS do not contain this requirement The Unit 1 CTS 3.7.1.1 markup dew.otes the change as A3. The Un:t 2 CTS 37.1.1 rnada.rp has no dew Wuun.

CCNPP Response The Unit 2 mark-up of trncng Conddion for Of= bi (LCO) 3.7.1.1 for Improved Techncal Sped Li (ITS) 3.7.1 wJI be rewsed to be w&d w.th the Unit 1 markup.

3.7.1-2 AS CTS 4.7.1.1 Uis 4.7.1.1 and assocated Uid Table 41-1 5/30G7 Delete this ce@. See I.A1 CTS Table 47-1 requres tesbng in E= wdora.e with CTS 4.0.5 and item Numbers 3 7.1-5. 3.7.1-STS LCO 3.7.1 lists the MSSVs. Idt setbngs and the onfice sce. 6. and 371-7.

STS SR 3.7.1.1 icWvely. ITS LCO 3.7.1 and ITS SR 37.1.1 STS Table 3.7.1-2 moddy STS LCO 31.1 and STS SR 31.1.1 to ITS delete STS Table 3.7.1-2. TNs change is LCO 3.7.1 %r.ated CEOG-84 It is the staf"s I TS SR 3.7.1.1 urd,>Iac4a g that this change is not genenc and and Anvuoted Bases has been rejected by the generc review prom See item Number 3.7.1-5. 3.7.1-6 and 3.7.1-7.

CCNPP Response Changes assocated with Combusbon Ergiacuus Owners Group (CEOG)-84 were removed as part of ITS s@co dos Ana Go 4 Request. Revison 1. dated June 9.1997. '

31.1-3 A6 CTS 3.7.1.1 CTS 3.7.1.1. Footnote allows entry into MODE 3 5/30G7 ,

to determine OPERAB!UTY cf the MSSVs. STS l Delete this de @.

Footnote STS SR 3.7.1.1 SR 3.7.1.1 has a Note whch allows entry into and NcDe upcituun in MODE 3 prior to guiumog the SR.

ITS SR3.7.1.1 ITS SR 31.1.1 moddies the STS Note to state that Note and Assocated the SR is not requred prior to entry into MODE 3.

Bases This change is desgnated CFOG-71. It is the staffs tard,eding that this change is not genenc and has been relected by the genenc review pr-CCNPP Response Char:ges ="rmied wrth CEOG-71 were removed as part of ITS e5--bio do Aru a = 4 Request. Revison 1. dated June 9.1997.

Doc = Discussen of change 1 JFD = .hastfica+vi for Deviaton

ATTACM (1)

RESPONSES TO REQUEST FOR ADDmOttAL WIFORRAATIOft N TECHNICAL SPECRCATaOgIS SECTIOf8 3.7

3.7.1 ;b DESCRIPTION OFISSUE U is 3.7.1.1 ACTION b prendes remedel actons W 5/3097

[ CORASINTS Rewee fue at====ws and 3.7.1-4 L3 CTS 3.4.12 CTS 3.7.1.1 less than the requred riurrter of MSSVs are )% for sie d=hensi of ACTION b OPERABLE in operatng steem generator in CTS 17.1.1 ACTION b.

ITS 3.4.5 MODE 3. L3 states that inoperable MSSVs are in ITS 3.7.1 the norH)perabng loop. It also stp%c thal

AHhough Secton 3.4 aAows only one Reactor Coolant System to be OPERE it is very unlikely that Calvert CliNs wiE operate in this configuraton." this statsment and the stater 9ents foRomng it are in emar. CTS 3.4.12 requres tdh RCS loops to be OPERABLE we one in oper.Aion. The CTS 3.4.1.1 ACTIONS wei one bop inoperable are the sarne as ITS 3.4.5- restore withr 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or shutdoum.

CCNPP Response DOC L3 wW be revoed to previde ad6tional)_% _

l 1

l i

Doc = Docuseen erchange 2 JFD = h for Devuton I

n ~

ATTACteENT f1)

RESPONSES TO REQUEST FOR ADDITIONAL 8MFORRfATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 37 3.

7.1 DESCRIPTION

OFISSUE , COlleAENTS l 3.7.1-5 JFD 14 STS 3.7.1 sis 3.7.1 Table 3.7.1.2 specifies the hft sci-9 of 5*3'067 1 Prtwede o dear oescrphon Bases Table 3.7.1-2 the MSSVs with a trhrance o it 3%. ITS 3.7.1 I' and luhvi for deletag JFD 3 ITS 3.7.1 dek4es this table per CEOG-84 (See item Number the13% tolerance from STS ITS 83.7.1 3.7.1-2). ITS 3.7.1 marks up STE '7.1 Table f 17.? Table 3.7.1-2.

3.7.1-2 to deAete the i 3% tolerance usmg ;

Bases SR 3.7.1.1 jto'Ja iini JFD 14. JFD 14 states that the i 3% l ImS CEOG44 has been does not apply to CCNPP but the aBowable value rejeded, what e4.c (s) is range is from i 3% to appi C, i 6% goog to be speedied in STS

&per As on the value. In addsbon, the CCNPP 3.7.1 Table 3.7.1-2 in ITS procedures regure this as found valve to be i 3%. 3.7.1. Provida a orummarvt Thisisconfusing See!!emNumber3.7.1-2. and justificatai for the

&Wa.e(s).

Sece ITS B3.7.1 Bases SR 3.7.1.1 rscrmmes i

the OPERABIUTY of the MSSVs. prcmde addConal dscussson and po4-~2--7 for d y..y the STS wording from ~13% setporit tolerance for OPNE to*13% setpomt tolerance for as found valves in the piant procedures.-

See item Number 3.7.1-2.

CCNPP Response Changes MK-wj with CEOG-84 were removed as part of ITS supplemental Amendment Request Revision 1, dated June 9.1997. The oppivpi i range of Idt setbngs has been prcmded for each main steam safety valve (MSSV). The Bases for ITS Surveillance Requrement (SR) 3.7.1.1 has Deen revised to state that Tcble 3.7.1-1 defines the range of hft wmngs pem* for valve op@ JFD 14 and 16 to Sechon 3.7 have been revised to clarfy thejiai.T- ^- - o.

Doc = oscussen of change 3

.FD = Justicaten for Des sten J

t ATTACHM (1) ;

4 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 DOCI CTS /STS DATE DATE 3.

7.1 DESCRIPTION

OFISSUE gg CORMENTS E LCO 3.7.1-6 JFD-17 STS SR 3.7.1.1 STS SR 3.7.1.1 states that follounng tesbng the 5/30/97 Delete tras change rt!TS SR ITS SR MSSVs lift setbngs shall be wenn i 1% to allow for 3.7.1.1. See item Number 3.7.1.1 and Aw_- W dnft. ITS SR 3.7.1.1 deletes this requrement from 3.7.1-2.

Bases ITS SR 3.7.1.1 but retans it in the Bases for SR i 3.7.1.1 If the requrement is to be retamed per ;

JFD 17 in the Bases, it must be speofied in the !

SR. See item Number 3.7.1-2. ;

CCNPP Response The requirement ws be placed in the ITS. and DOC M2 wnll be added to desenbe the change 3.7.1-7 Bases STS B3.7.1 Bases- STS B.3.7.1 Bases-BACKGI'OUND states the S/30f97 Delete thes change. See JFD 7 BACKGROUND ITS follounng *The MSSV design ocludes 4.yyeiad item Number 3.7.1-2.

i B3.7.1 Bases , setponds, inued.9 to Table 3.7.1-1, in the i BACKGROUND is,uiry iying LCO - ITS B3.7.1 Bases- i j BACKGROUND deletes the words "Enued.g to LCO,". The )4- M--i (Bases JFD 7) states !

tnat the delebon is made to conform with changes made to the spevfc,Ed ,i. Since both tables are *o l be retamed, the delebon is tia+jeA See i item Number 3.7.1.-2. !

, t CCNPP Response The statement has been retaned in the Bases, except for the phrase, "in the inu,wrying LCO.* This phrase is an unneeman reference (Bases inu,w,y 4

LCOs). ;

3.7.1-8 Bases STS B3.7.1 Bases LCO STS B3.7.1 Bases - LCO states the mrumum 5/30/97 ' Delete this criange or provide i JFD 7 ITS B3.7.1 requred MSSVs requaed in MODES 1,2, and 3. aditeional trac == ann and Bases LCO ITS B3.7.1 modifies the STS wnleup based on y='4e*wi based on cunent dw@ made to the spedT=,. ins. (Bases JFD 7). basis, iicensing system No di.@ made have been made to the desagn or upes.in,i.i i

=p--X-A--i which would necessitate, the iTS constramts. ,

peupused C W @ .

CCNPP Response t

JFD 3 will be used tojustify the dw.ye= ristead of JFD 7.

1 l

ooc. o- .s a c% 4 JFD = JustWicabon for Densbon i

~ _ _ _ _- - _.,

ATTACHRENT.(1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IIIPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

-3.

7.1 DESCRIPTION

OFISSUE q COMMENTS 3.7.1-9 None STS B3.7.1 Bases STS B3.7.1. Bases SR 3.7.1.1 states the folicunng- 5/30/97 Licensee to update the SR 3.7.1.1

a .nrismum of 20% of the va!ves tested evety 24 sutmttal with regards b ITS B3.7.1 Bases months" ITS B3.7.1 Bases SR 3.7.1.1 changes EDIT-18 when OG prowdes SR 3.7.1.1 this to: " .a rnmimum of 20% of the valves be revissort.

tested every 24 months" This change is

%re as a genenc editonal change. The staff has re.Rd this change under EDIT-18, and has modified the change.

CCNPP Response JFD 19 wiH provide a plant-speofic jiatif.coi.cni for the deviaton.

3.72 DESCRIPTION OFISSUE g CORA4ENTS 3.7.2-1 A.5 CTS 3.7.1.5 CTS 3.7.1.5 ACTION. allows an inoperable MSIV 5/30/97 Provide addibonal darme and jiaur.c.iui for this More ACTION- b be edher resmed to OPERABLE status or MODE 1 closed wittci fois i.ours when in MODE 1. ITS Restncbve change.

ITS 3.7.2 3_7.2 ACTION requires an inoperable MSIV to be RA A.1 .cs.cd to OPERABLE status withm eight hours.

The ITS is More Restnchve than the CTS in that the CTS would allow conbnued cw.km in MODE 1 with the MSIV closed. It should be noted that the old STS (NUREG-0212) only requred i=Amts the MSIV to OPERABLE status not closog it. Thus CCNPP CTS is a plant speofic TS.

CCNPP Response DOC M.4 win be provded to jusbfy ths change. and DOC A.5 wiB be withdrawn.

Doc = oiscussion of change 5

.fFD = )_em for Deviabon

-_-...-.----._..-__-=..--.a... = . - . . . . . .

ATTACE.1EENT fil RESPONSES TO REQUEST FOR ADDITIONAL INFORIAATION IRPROVED TECHNICAL SPECh-T.ATIONS SECTION 3.7 31.2 3.72-2 A6 CTS 3.7.

1.5 DESCRIPTION

OFISSUE CTS 3.7.1.5 ACTION MODES 2 and 3 infer to 5/30f97

[ CORAMENTS Pronde additonal neeru==ari l ACTION conhnued operabon in MODES 1.2 and 3 prended and justlicatori for tiis Less l MODES 2 and 3 certain mm are rnet A6 states that the Restnchve chsige. See referen to MODE 1 wiB be deleted because the item Number 3.72-1.

i. ACTIONS do not apply to MODE 1. This is wrong

~

based on item Number 3.72-1. The change is Less Restnctive, not Admrustrabwe. See Item

Number 3.72-1.

CCNPP Roeponse DOC A6 wiR be modified to state that the Modes 2 and 3 Acton does not apply to Mooe 1 operatons.

3.72-3 M.3 CTS 3.7.1.5 CTS 3.7.1.5 ACTION-MODES 2 and 3 requres the 5I30/97 Corrm:t this decrepancy.

ACTION MODES 2 and 3 plant to be in MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when requred ITS 3.7.2 RA D.1 and D2 achons and assocated Cm6^s. Tunes cannot be met ITS 3.7.2 RA D.1 and D2 requres 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 when the RA A1, RA B.1, RA C.1 and 4

RA C2 and ph C-6's. bmes cannot be rnet. The markup for Unit 1 CTS 31.1.5

, ACTION-MODES 2 and 3 shows this dunge.

However the markup for Unit 2 CTS 31.1.5

+ ACTION-MODES 2 and 3 deletes the requrement to be in MODE 4 (HOT SHUTDOWN) in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

CCNPP Roeponse i Unit 1 and 2 CTS markups were revised to be consastent with each cAher and with Acton D of the iTS 312.

i l

i Doc = oscus on or change 6

.FD = JusbRcahon for Devehon I

ATTACHMENTfil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.2 DESCR PTION OFISSUE COMMENTS LA1 CTS 4.7.1.5 Uis 4.7.1.5 regures each MSN be denu=^uoi.:d 5/30/97 De.ete this genenc change.

3.72-4 JFD 15 STS SR 3.72.1 OPERABLE by venfyrg fut closure in less than Bases ITS SR 3.72.1 5.2 seconds. STS SR 3.721 also requres each JFD 7 and Assocated Bases MSN be de.,. .oobated OPERABLE by venfying fuH closure in less than a plant % T.ed time. ITS SR 3.72.1 does not retaan this requirement but relocates it to the IST Prograrrt This is ur+x jLMAE, would be uao jered a genenc change and be beyond the scope of revew for this conversat CCNPP Response The cbsure time wi2 be restored to ITS SR 3.7.2.1 with our vpnaie MTaburs.

STS SR 3.72.1 Note STS SR 3.72.1 flote states that the SR is "On!y ' 5/30/97 Delete this change.

3.72-5 L4 ITS SR 3.7.2.1 requeed to be paiairied in MODES 1 and 2. ITS Note SR 3.72.1 ciups this Note to 'Not required to and Assoc ateu Bases be pm'aarred pnor to entry into MODE 3." This change is deiJgrsted CEOG-72 in the ITS markup.

It is the staffs urnb w..-Lrg that this change is not genenc and has been rejected trf the genenc revew &

CCNPP Response i

Chanoes assocated with CEOG-72 wiH be removed.

l DOC = Dscussion of Cha ge 7 JFD = Just6cabon for Deviabon

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~l ATTACHM 11)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRIATION i IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 i

DOC / CTS /STS DATE DATE 3.72 DESCRIPTION OFISSUE COMMENTS E LCO ROSED 3.72-6 JFD 1 STS 3.72 STS 3.72 APPUCABluTY is MODE 1. MODE 2 8 5/30/97 Esther delete ttus genene Bases APPUCABIUTY and and 3 except when as MSIVs are closed and de- change or provide acfditonal JFD 1 AsK--Aj Bases achvated. _ ITS 3.72 APPUCABIUTY deletes "and <*w,== ann and jusA oun ITS 3.72 de-achvated - The juMA.inni for both the ITS based on current licensing APPUCABIUTY change (JFD 1) and the assocated Bases basis, system dessgn or and AsE--Aj Bases -

cinis @ (Bases JFD 1) is the standard delebon of cyci.'iv. lcxmstraints.

bracket removalp 47 2:--i. *ic r c.r, the Bases i rnarkup also states this is an genene editonal

! change. The staff has not reoerved this EDIT-X j change forrevew CCNPP"1;- _ :

A piant-spec fic ps' T- 2:-N will be subsbtuted for the gerenc eddonal pW_shnn.

3.72-7 Bates STS B3.72 STS B.3.72 Bases - RA A1 contams a pin yopii 5/30/97 Provide additonal dmmmtanri JFD 11 Bases- justifying the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Cun@i Time rather than and justificahon to show that RA A1 the containment isolabon valve Cui%:.,.ni Tirne of the MSIVs are not ITS B3.72 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months The MSIV is considered a contamment contamment isolabon valves.

Bases-RA A1 isolabon valve. ITS B3.72 BASES RA A1 deletes Reference to UFSAR this pmayapii based on the juMA.inni that the sechons. Icensee current incusig basis does not u.=6.6 the MSN documentaban and as a we. unentisolabon valve. associated staff SERs or 1 letters wiB be sufficient to resolve this issue.

CCNPP Response Additional pnt T-M-y. .nli be provided in JFD-11.

1 i Doc = mscussen or change 8

'j JFD = Justicaten for Dematon l

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION lMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 DA 3.

7.3 DESCRIPTION

OF .SSUE g COMMENTS CO CTS 3.7.12 ACTION b2 requres the other unds Cuned tNs dwegiu y by 3.7.3-1 A3 CTS 3.7.12 5/30/97 L5 ACTION b2 motor-driven AFW pump be venSed OPERABLE. either addog a RA to JFD 10 CTS 4.7.12.a 3 and that valve 2-CV-4550 and 1G-4550 (for ACTION C whch ven5es Bases ITS 3.7.3 Units 1 and 2. icspecuvely) be ven5ed that the that valves 2-CV-4550 and JFD 7 RA C.2 valves were exere sed within the last 30 days. ITS 1-CV-4550 have been ITS SR 3.7.3 RA C2 requires the motor-dnven pump from exerosed wCun the last 30 3.7.3.2 the other und be ven5ed OPERABLE but does not days or change the SR and Assooated Bases require the ven5caton that the valves were frequency of ITS SR 3.7.32 exerosed wthm the last 30 days. The Mrduva trom 92 days to 31 days.

(A.3) states that th: exerosmg the va!ves Provide add.t onal discusson requirement is rnoved to ITS SR 3.7.32 and this is and jusTcAr.ni to support done every 31 days. The p_@T-X _-i (L5) .or the the gavevaed change. See Survei2ance Requirement states this Frequency is item Number 3.7.3-2.

92 days. In adddon, if a unit is shutdown, the SRs ;

would not need to be paiu u d on that unfs AFW curg ,erds. Thus. ITS SR 3.7.32 would not need to be ;.uivin.ed over a 92 day frequency as required by the ITS SR or 31 day frequency as required by CTS 4.7.12.a3. See item Number '

3.7.3-2.

CCNPP Response New Action C 3 wi!! be aoded to ITS 3.7.3 to venfy that these valves are Operable. The Bases wiU hiva that tNs ven5cabort of operabd:ty means that the vanes have been cycled pw SR 3.7.3. The Unit in cpedova cedrts the other Un(s valve and is respui6ble for the surveiRance on the va've. DOCS A3 and 1.5 have been modified to describe these ch.ges. ,

l 1

Doc = om:usson of che ge 9 SD = Juc'Ecaten for Deviaton

- _ _ . _ _ _ _ c7

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.

7.3 DESCRIPTION

OFISSUE

^ COMMENTS ED aOSED 3.7.3-2 A.3 CTS 3.7.12 CTS 3.7.12 ACTION b.2 requires venfying that the 5/3G97 Ecer clearty define LS ACTION b2 cross-be valves have been exerc sed wcun the Open h g pos: bon in the JFD 10 CTS 4.7.12.a3 last 30 days. CTS 4.7.12.a.3 and ITS SR 3.7.32 BASES or provde a Est of BASES CTS 4.7.12.a 4 require cycling each testable, remo%.:cd valves to be tested by ITS JFD 7 ITS 3.7.3 valve that is not in its cr a hg postbon. These SR 3.7.32 in the BASES RA C.2 SRs are confustg in that"Opci 69 pcsitof is not Provde .:= P N vtal ITS SR 3.7.3.1 clear 4y defined and may conf.ct wi'h the MA 4 -. and h m ITS SR requirenents of CTS 4.7.12.a4 and ITS SR forthe pW change.

3.7.3.2 3.7.3.1-venfcabon of valves in correct possbon. In and AsK Lied Bases the case of the AFW cross-te valves the normal Open.~o.g posrbon would be clostsd. Thus it is concervable that these valves would never be cycled except if CTS 3.7.12 ACTION b was entered.

CCNPP Response These va!ves are requireo u % t p sed, and are currently cycled by survei:!ance guiures. The "Open.h i possbon of these valves is to supply water, the 'normar possbon is closed The acbon added in response to NRC quesbon 3.7.3-1 provdes some d.6Teh,. cf this issue.

3.7.3-3 M2 ITS 3.7.3 See item Number 3.7.3-8 5/3GG7 See !!em Number 3.7.3-8 Cond: tion D CCNPP Response A plant-specirc justfcabon will be added to the improved Standard Techncal SmTwk,o markup.

3.7.3-4 M.3 CTS 4.7.12.b CTS 4.7.12.b requires the AFW flow path to be 5/3Gt97 Provde a dtscussen and ITS SR 3.7.3.7 and venfied from the CST to the SGs pnor to entenng MTwk,. for th:s t_ess Associated Bases MODE 3 after being in MODE 5 for a speofc Restnctve change penod of time. ITS SR 3.7.3.7 wiB requee the AFW flow Path to be venfied prior to erferirig MODE 2 after being in MODE 5 or 6 for a speofc penod of trne. No jto'Tehe. has been prwided for the Less Restncbve change of gorg from "pnor to entenng MODE " " in the CTS to "Pnor to entenng MODE 2"in L: tis.

CCNPP Respanse i DOC L3 wiL o_e nmsed to justfy this change.

DOC = Nm of Change 10 JFD = .bem for Deviatm

ATTACM (1)

RESPONSES TO REQUEST FOR ADOITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTON 3.7 3.73 DESCRIPTION OFISSUE Uis 3.7.12 ACTION al.b regures the inoperable 5/30/97

[ COMMFNTS Prtmde the procedue or 3.7.3-0 IA2 CTS 3.7.12 ACTION al.b steam-drwen pump restored to standby status or plant document to whch the automabc nbahng status if the other stearndrwen M,u Lun is moved and the ITS 3.73 RAA2 pump is place in standby ITS 3.73 RA A2 documentchange control requaes the stearn-dnven pump restored to OPERABLE status The requrement to place the pump, upon restorabon. in the standby or automabc nbahng status is moved to plant

,.rocedires. wicuv;;od aii.vidiis to the plant change:ontroiprocess CCNPP Response DOC IA2 will be revised to state that the Juin 4 -i will be moved to the Bases, and w upi& (I@ to the Bases wE be made.

3.7.3-6 LA.4 CTS 3.7.12 UIS 3.7.12 ACTION C allows AFW tratis to be ST30/97 Mvdify ITS LCO 3.73 Note JFD 9 ACTION C rernoved from sennce dunng periodic testng, as specded. Prtwide BASES ITS LCO 3.7.3 provided a dedcated cre.ia- is staboned at the addebonal jus A oi,si and FD7 Note and Assuu md local stabons with drect commtn ic,.Luis to the discusson for the change.

Bases control room. Upon u.nnp;aecai of the teseng, the See item Number 3.7.39 trains are restored to their proper status and verned by an n$ependent ci=.an check. ITS LCO 3.73 adds s Note whch only states that the AFW traris are allowed to be removed from servce dunng penodic teshng. This Note is wxomplete, in that CCNPP's cunent Wg basis requres that the removal be done under cer'w admnstrative controls. The details of the admastrabve control may be moved to the Bases but the Note must contasi the words "under admnstratwe controls." This change mmes ITS 3 6.3 ACTIONS Note 1. See item Number 3.7.3-6. l CCNPP Response ITS LCO 3.7.3 was revised to irdh reference to Nu- ::,L.Le contrds, and JFD 9 was modified cm.w diopy.

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1 Doc = Docussion or char x 11 JFD = Just:ficabon for DenaJm

ATTACHMENT _(1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

^ COMMENTS 3.7.3 - DESCRIPTION OF ISSUE . ENED SED 3.7.3-7 LA.5 CTS CTS 4.7.1.2.a.1 & a.2 contains specific values for 5/30/97 Provide the Plant Procedure 4.7.1.2.a.1 dynamic head and Reactor Coolant System to which the iniune'si is CTS temperature in the Surveillance Requirernents to rnoved and tne procedure 4.7.1.2.a.2 verify the AFW stearndriven and rnotor-driven change control pumps develop a certain dynamic head. ITS SR 3.7.3.3 does not contain the speerfic values for dynamic head testing The specific values are moved to plant precedures and/or Bases.

CCNPP Response:

DOC LAS wi!! be revised to state that the requirements are being rnoved to the TechniciJ Spedicatbn Bases, which is controlled by 10 CFR 50.d9.

DOC = Disoission of Change 12 JFD = Justication for Deviation

ATTACHREENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.3 ' DESCRIPTION OFISSUE 5/30/97

[ COMRENTS Delete this c6-@ and 3.7.3-8 JFD 1 STS LCO 3.7.5 Note STS 3.7.5 APPUCABluTY states that the AFW STS 3.7.5 system is OPERABLE in MODE 4 when steam update the sutmttai to JFD 2 l

JFD 10 APPUCABlUTY generator is relied upon for heat removal. STS ar.lude the MODE 4 Bases STS 3.7.5 Condition B LCO 3.7.5 Note, STS 3.7.5 Conditions B, D, and E requirements in the added and STS SR 3.7.5.3 Note 2 and SR 3.7.5.4 Note 2 ITS Cordbons and SRs, or JFD 1 STS 3.7.5 Condition D Bases STS 3.7.5 Condition E specify the requirements and conditions within STS provide addsbonaljuer.udui 3.7.5 to which the MODE 4 APPUCAB!UTY and discusrJen for any JFD 3 STS SR 3.7.5.3 Note 2 Bases STS SR 3.7.5.4 Note 2 applies and does not apply. The ITS counter parts deviabons based on current JFD 7 ITS LCO 3.7 5 to the STS items spedfied (ITS LCO 3.7.3, ITS hids basis, system ITS 3.7.5 3.7.3 APPUCABILITY, ITS 3.7.3 Cordbons D and design or - OpciakigJ F, and ITS SR 3.7.3.4 and ITS SR 3.7.3.5) delete u i mba;ats. See item APPUCABILITY ITS 3.7.5 Conditions A, B, these requirements and conditions and modifies Number 3.7.3-15.

C, D, and F the Bases accordingly. STS 3.7.5 Condition E is ITS SR 3.7.3.4 Note 2 also deleted These proposed dwiives were ITS SR 3.7.3.5 Note 2 reviewed and rejected by the staff in TSTF-29. In ITS SR 3.7.3.6 and short, the basis for the fer3uu' was that, at the Associated Bases OG's insistence; the switch from AFW to RHR/SDC did not occur exactly at the MODE 3 to MODE 4 interface but camed over into MODE 4 for a short durabon., Therefore, for these requirements and conditions are required. In addebon. ITS 3.7.3 Cudi;uns A, B, and C and ITS SR 3.7.3.6 may need to be revised to inWde these requiremunts and us4%is. See item Number 3.7.3-15.

CCNPP Response JFD-20 has been added to provide a plant-specific justifir* inn for the change JFD 2 ITS 3.7.3 and Associated The renumbenng of ITS 3.7.3 and succeeding 5/30/97 See item Numbers S3.7.3-1 3.7.3-9 Bases Bases spedTn.abens will depend on the resolubon of item and S3.7.4-1.

JFD 2 Numbers S 3.7.3-1 and S 3.7.4-1.

Bases JFD 3 ,

CCNPP Response See responses to S3.7.3-1 and S3.7.4-1.

Doc = Discussion of change 13 JFD = Justi5caten for Deviation

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ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITICML INFORMATION l

IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.3 ' DESCRIPTION OFISSUE ED C SED STS 3.7.5 STS 3.7.5 ACTION A desenbes the RA, and 5/30/97 include this Condibon, RA 3.7.3-10 JFD 10 Bases ACTION A Completion Time for when the steam supply to the and Completion Trne in ITS I

JFD 3 ITS 3.7.3 steam driven AFW pump (s) is inoperable. ITS 3.7.3. Revise iTS 3.7.3 Bases ACTIONS and 3.7.3 ldoes not contain this ACTION. No Condition E and A-ted Associated Bases justification is given for its deletion. Based on the Bases accordingly.

JFD 7 description of tne steam supply provided in ITS B3.7.3 Bases - BACKGROUND, which uses the STS wording, the staff believes this Condition, RA, and Cw n,AcL0n Time are necessary at CCNPP. ,

CCNPP Response JFD 10 has been revised to provide additional detail.

ITS 3.7.3 RA A2 and RA B.2 Completion Trne has 5/30/97 Provide discussion and 3.7.3-11 JFD 10 ITS 3.7.3 RA A.2 an additional requirement not addressed in the justification for this More ITS 3.7.3 CTS. The additional Completion Time is to restore Restrictive change RA B.2 and Associated an AFW pump to OPERABLE status 10 days from Bases discovery of failure to meet the LCO. There is no l justification for this addruwial More Restrictive Completion Time. j CCNPP Response:

j The CTS markups were modified and DOC M.4 has been added to justify the change.

STS B3.7.5 STS B3.7.5 Bases - RA D.1 states that with all 5/30/97 Provide additional discussion 3.7.3-12 Bases JFD 3 Bases AFW trains inoperable, there is "only a li: ' and justification for this RA D.1 means for conducting a cool down with nonsafen delebon ITS B3.7.3 grade equipment. ITS B3.7.5 Bases RA F.1 Bases deletes this statement. The justificabon provded <

RA F.1 states that it is deleted to make the statement more understandable or to conform to the CCNPP design or safety analysis. Based on the Bases description, the justification does not seem to apply to this deletion.

CCNPP Response:

The Bases were clarified to indicate the non-safety-related means for mr* town.

Doc = Dscussion of change 14 JFD = Justification for Deviation y

ATTACHMENT (1)

RESPONSFS TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7,3 S DESCRIPTION OFISSUE ED C OSED 3.7.3-13 Bases CTS 4.7.1.2.b STS B3.7.5 Bases - SR 3.7.5.5 states that the SR 5/30/97 Delete this change.

JFD 3 CTS 4.7.1.2.c.2 requires a venficaten of minimum flow capacity of STS B3.7.5 750 gpm at 1270 psi to ensure that the flow path Bases imm the CST to be SG is property aligned. ITS SR 3.7.5.5 B3.7.3 Bases SR 3.7.3.7 deletes this requirement.

ITS B3.7.3 No justification is provded. Yet CTS 4.7.1.2.b Bases which is the CTS counterpart to STS SR SR 3.7 3.7 ' 3.7.5.5/ITS SR 3.7.3.7 requires a flow test and CTS 4.7.1.2.c.2 specifies the minimum gpm as 300 gpm.

CCNPP Response CTS 4.7.i.2.b does not require a specific flow, and it corresponds to ITS SR 3.7.3.7. CTS 4.7.1.2.c.2 is not related to this SR, which venfies a flow path from the CST. This would be a more restnchve change, and is not necessary.

3.7.3-14 None STS B3.7.5 STS 83.7.5 Bases - RA D.1 d%ude the RA, and 5/30/97 Delete these changes Bases Ccirp;etiva Times for the condition of all AFW RA D.1 trains inoperable in MODES 1, 2, and 3. ITS ITS B3.7.3 B3.7.3 - Bases RA F.1 modifies the STS wording.

Bases The modifications are designated CEOG-76 and RA F.1 CEOG-77. It is the staffs understanding that these dwrgs are not genenc and have been rejected by the generic review process CCNPP Response:

A plant-specific jtohistivn will be provided for these changes Doc = Discussion of Change 15 JFD = Justincate for Deviate

ATTACHARENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.3 DESCRIPTION OFISSUE C6

.CL D 3.7.3-15 None CTS 4.7.1.2.c.1 CTS 4.7.12.c.1 requires venfication that the AFW 5/30/97 Provide discussion and patRM -i for the More ITS SR 3.7.3.5 and valves and pumps actuate to their correct possbon Associated Bases on a test signal. ITS SR 3.7.3.5 requires venfying Restnchve change See the AFW pumps start automabcally on a simulated item Number 3.7.3-8.

( signal or with an actual signal when in MODE 1,2, or 3. There is no discussion or pastificabon for adding the More Restnchve requirement of MODES 1,2, or 3. This change will be dependent on the resolution of item Number 3.7.3-8. The inclusion of MODE 4 APPUCABluTY/Nole would require the retenbon of"in MODES 1,2, or 3, while the delebon of MODE 4 APPLICABlUTY/Nole would require the delebon of "in MODES 1, 2, or 3.*

CCNPP Response ITS SR 3.7.3.5 was revised to delete Modes 1,2, or 3 consistent with the app;;c,atWidy. Also see the response to 3.7.3-8.

3.

7.4 DESCRIPTION

OFISSUE D CL LA1 CTS 3.7.1.3 CTS 3.7.1.3 lists the specrfic CST numbers and the 5/30/97 Providc>the plant procedure 3.7.4-1 to which the is/un=dui is ITS 3.7.4 specrfic backup water supply tank numbers in the LCO, ACTIONS, and SRs. ITS 3.7.4 does not list moved and the procedure the specific numbers The specific component change control numbers wiH be listed in the plant procedures.

CCNPP Response DOC LA1 will be revised to specify this detail in the Bases.

Doc = Descussion of change 16 JFD = Justification for Devrabon r___:---'--;.s - . ':'.

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ATTACHMENT (1)

. RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

'3.7.4 LO ONISSUE ED CLOSED 3.7.4-2 LA.2 CTS 4.7.1.3.2 CTS 4.7.1.3.2 requires the backup CST be 5/30/97 Provide the plant procedure ITS 3.7.4 demonstrated OPERABLE once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by to which the inLm.%i is RA A.1 verifying the tank contains a minimum of 150,000 moved and the procedure gallons of water, and the flow path for taking change control suchon from this tank is OPERABLE with the manualvalvesin this flow path open.

ITS RA A.1, second Cwi@b7 Time, requires the availability of the backup water supply be venfied once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Venfying the tank contains the minimum water and the flow path opembility details are moved to plant procedures.

CCNPP Response DOC LA.2 will be revised to specify this detail in the Bases.

3.7.4-3 JFD 2 ITS 3.7.4 an1 Associated See item Number 3.7.3-9 5/30/97 See item Number 3.7.3-9 BASES Bases JFD 2 CCNPP Response See response to S3.7.3-1 and S3.7.4-1.

3.7.4-4 JFD 3 ITS 3.7.4 Changes made to ITS 3.7.4 APPLICABILITY, ITS 5/30/97 See item Number 3.7.3-8.

BASES APPLICABILITYITS 3.7.4 RA B.2, and Associated Bases are made in JFD 1 3.7.4 accordance with TSTF-29. These changes are ,

BASES BASES-APPLICABILITY unacceptable. See item Number 3.7.3-8.

JFD 7 ITS B3.7.4 !

BASES RA B.1 and B.2 CCNPP Response See response to 3.7.3-8. ;

Doc = Discussion of Change 17 JFD = Justification for Deviation

A7ACHMENT. (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION

3.7 DESCRIPTION

OFISSUE

~

3.7.4 NED C 3.7.4-5 None STS SR 3.7.6.1 STS SR 3.7.6.1 requires venfying CST level is 5/30/97 Delete this change.

ITS SR 3.7.4.1 and 2 150,000 gal. ITS SR 3.7.4.1 and Associated Associated Bases Bases requires verifying CST level is 2 150,000 gal. per unit. The change is justified by TSTF-140.

This change is not in accordance with TSTF-140.

CCNPP Response:

ITS SR 3.7.4.1 requires vent ing condensate storage tank (CST)

volume." which was changed from " level" by Technical Speufcah Task Force (TSTF)-140. The verification of the volume on a "per unit" basis is justified by JFD 3 consistent with LCO 3.7.1.3. To avoid confuson, the term *per unit" will be deleted. and the SR will require the " usable" volume to be >=150,000 gal. The Bases for Condition A and SR 3.7.4.1 will be revised to clarify the applicaixtity to each unit.

3.7.4-6 None STS B3.7.6 STS B3.7.6 BASES-RA A1 and A2 desenbes the 5/30G7 Licensee to update , the Bases ras and Completion Times for when the CST is submittal in undece with RA A.1 and A2 inoperable. ITS B3.7.4 Bases RA A1 and A2 TSTF-174.

ITS B.3.7.4 modifies the STS wording based on CEOG-79 BASES (TSTF-174). The ircddicabs are not in RA A1 and A2 accordance with TSTF-174. !

CCNPP Response:

The Bases were modified to be consistent with TSTF-174.

3.

7.5 DESCRIPTION

OFISSUE .O ED C OSED 3.7.5-1 A1 CTS 3/4.7.5 CTS 3/4.7 5 is entitled " Component Cooling 5/30/97 Correci this dh,u eparEy.

JFD 2 ITS 3.7.5 Water System." The CTS markup changes this to

" Component Cooling Water (CCW) Systern." ITS 3.7.5 is entitled " Component Cooling (CC)

System."

CCNPP Response Discrepancies willbe corrected.

Doc = Discussion of change 18 JFD = Justifcation for Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

^ COMMENTS 3.7.5 . DESCRIPTION OF ISSUE' ED a CTS 4.7.3.1.b requires venfying each automabc 5/30/97 Provide the pirsnt pivcedures 3.7.5-2 LA2 CTS 4.7.3.1.b ITS 3.7.5.2 valve actuates to its correct posrbon on a Safety to which the kivnisabun is injechon Actuaton signal ITS SR 3.7.5.2 requires moved and the procedure venfying CCW OPERABIUTY on an actual or change control simulated xWinn signal The specific test signal requirement is moved to plant procedures. The plant procedures and associated controls are not identified.

CCNPP Response DOC LA2 will be modified to move the detail to the Bases 5/30/97 See item Nud,or 3.7.3-9 3.7.5-3 JFD 2 ITS 3.7.5 and Associated See item Number 3.7.3-9 Bases Bases JFD 2 CCNPP Response See response to S3.7.3-1 and S3.7.4-1.

ITC SR 3.7.5.1 Note states isolation of CCW flow 5/30/97 Provide anscusson and 3.7.5-4 None ITS SR 3.7.5.1 to individual components does not render the justification for this Less CCW System inoperable. This Note is not in the Restnchve change.

CTS. There is no discussion or jusTabcn for including this Note in ITS SR 3.7.5.1.

CCNPP Response DOC A5 was added with the Note to the CTS markup. This is an administrabve change that clarifies an industry acwyted pracbee-ITS B3.7.5 Bases-BACKGROUND states "In the 5/30/97 Provide adddonal 3.7.5-5 None iTS B3.7.5 Bases-BACKGROUND event of a CC passive failure during a LOCA, the discusson and jusbrabun Service Water System provides redundant decay to clanfy this CCW heat removat Based on the Bases desuipbuiw statement See item Number 3.7.6-1 and 3.7.7-3.

(see item Numbers 3.7.6.1 and 3.7.7-3)for the Service Water System and the Saltwater System, it seems that this statement may be in error.

CCNPP Response The Bases have been revised to clarify how decay heat is removed on a 5mse failure in the Component Cooling System.

Doc = Discussion of change 19 JFD = Justification for Deviation

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ATTACHMENT fil RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 L 3.

7.3 DESCRIPTION

OFISSUE ED CL SED 3.7.6-1 A4 STS 3.7.8 STS 3.7.8 RA A1 contains a Note 2 which states 5f30/97 See item Number 3.7.5-5.

JFD 11 RA A1 " Enter applicable Conditions and Required achons Bases ITS 3.7.6 of LCO 3.4.6 RCS loops MODE 4." for shutdown

'JFD 3 RA A1 and Associated cooling made inopmotAe by SWS. ITS 3.7.6 RA Bases A1 deletes this Note. As a result of item Number 3.7.5-5 the delebon of this Note may be in error.

CCNPP Response:

The Service Water System does not provide cooling to the shutdown cooling heat exchangers; therefore, this note is not anr*mNa at Calvert Cliffs. See response to 3.7.5-5 for Bases clarification.

3.7.6-2 LA1 CTS 4.7.4.1.b CTS 4.7.4.1.b lists the type of test signals (safety 5/30/97 LJcensee to update the ITS SR injechon actuabon signal and containment spray sutmttal to specify that the 3.7.6.2 actuabon signal) to ensure that the system valves SRW valves also actuate to actuate to their correct position. ITS SR 3.7.6.2 the correct posrbon on a does not specify the actual signals. LA.1 states containment spray actuabon that these details have been rebcated to the signal.

Bases ITS B3.7.6 does not spec:fy that the containment spray actuabon signal actuates the l valves to their correct posthon !

CCNPP Response DOC LA1 will be revised to state that the containment spray eatino signal is deleted. There are no valves in the Sennce Water System that respond to a containment spray actuabon signal Service water valves are actuated by a safety injechon e ntian signal. This is stated in the Bases Background 3.7.6-3 JFD 2 ITS 3.7.5 and See item Number 17.3-9 5/30/97 See item Number 3.7.3-9.

Bases Associated Bases r JFD 2 CCNPP Response See response to S3.7.3-1 and S3.7.4-1.

DOC = Dscussion of Change 20 JFD = Justifica4on for Dennabon

.. s ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 DA 17.3. ' DESCRIPTION OFISSUE g COMMENTS -

None ITS SR 3.7.6.1 ITS SR 3.7.6.1 Note states tsolabon of SRW flow 5/30/97 Provide Gscussion and 3.7.6-4 to indivdual csiWnts may not render the SHW jiA#- stk-i for this Less anoperable. This Note is not in the CTS. There is Restnchve change no discussion or justificabon for incruding this Note in ITS SR 3.7.6.1.

CCNPP Response DOC A.5 and the appropnate markups will be provided to justify this change, which irWr.nsies an industry-wide accepted pracbce.

'3.

7.7 DESCRIPTION

OFISSUE. ED CL CTS 4.7.5.1.b lists the type of test signal (safety 5/30/97 Licensee to update the 3.7.7-1 LA-1 CTS 4.7.5.1.b ITS SR 3.7.7.2 injechon #* inn signal) to ensure that the sutmttal to specify that the system valves actuate to their correct possbon ITS SW valves actuate to their SR 3.7.7.2 does not specify the actual signal LA.1 correct possbon on a safety states that this detail has been ic-im.ated to the injechon actuabon signal Bases ITS B3.7.7 does not specify this detail.

CCNPP Response ITS SR 3.7.7.2 and 3.7.7.3 identify the signal as safety injer*vi e winn signal (SIAS). This detail was missing from the NUREG markup and has been added 3.7.7-2 JFD 12 ITS 3.7.7 and Associated See item Nurnber 3.7.3-9. 5/30/97 See item Number 3.7.3-9.

Bases Bases JFD 7 CCNPP Response

~See response to S3.7.3-1 and S3.7.4-1.

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Doc = Discussion of change 21 JFD = Justification for Deviation

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ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION 1RAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3;7.7-

- DESCRIPTION OFISSUE ED CLO

.C N 3.7.7-3 JFD 12 STS 3.7.8 ITS 3.7.7 uses STS 3.7.8 as the basis for this G i s 5/30/97 Prowde additional decussion Bases RA A1 requirement STS 3.7.8 RA A1 has two Notes andju=LTic 000 based on the JFD 7 ITS 3.7.7 asscuaied with it. Note 1 deals with entering LCO system design or Opciatuu RA A.1 and Associated 3.8.1 when the DG is made inoperat4e by SWS constraints to show that the l

Bases inoperability and Note 2 does the same for LCO Notes should be deleled.

3.4.6 for shutdown coohng ITS 3.7.7 RA A.1 See item Numoers 3.7.5-5 deletes both these Notes. Based on the ITS and 3.7 6-1.

B3.7.7 Base-BACKGROUND system desuipiui as well as the Bases system desuspben for the CCW system and SRW system, these Notes may have to be retained. See item Numbers 3.7.5-5 and 3.7.6-1.

CCNPP Response These notes are restored and appropnate markups provided. DOC A.5 and appwpiiate markup 3 will be provided to justify this change This change clanfies an industry-wide accepted pr= fe ITS SR 3.7.7.1 ITS SR 3.7.7.1 Note states isolation of SW flow to 5/30/97 Provide discussion and 3.7.7-4 JFD 12 Bases and Associated Bases individual u.nopenents does not render the SW justificabon for this Less 8FD 7 inoperable. This Note is not in the CTS. There is Restnchve change no discussion or justification for including this Note in ITS SR 3.7.7.1.

CCNPP Response:

The NUREG Note pertaining to individual component isoldian will be added to the CTS markup with DOC A5 to justify the Note.

I DOC = Discussion of Change 22 JFD = Just:ficaten for Deviaton

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ATTACHMENT. (il f

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.8 ' DESCRIPTION OFISSUE COMMENTS ED C OSED CTS 3.7.6.1 Insert ACTION G states for RA G.1 5/30/97 Conectthese discrepances 3.7.8-1 M.1 CTS 3.7.6.1 JFD 2 Insert ACTION G the following " Place OPERABLE CREVS train in Bases ITS 3.7.8 Control Room Recirculation Mode" M.1 states JFD 2 RA G.1 that the CREVS in this condition is to be place in the "Ernergency Radiation Protection MODE._."

while ITS 3.7.8 RA G 1 requires placing the OPERABLE CREVS train in recirculation Mode with the POST-LOCA fans in service.

CCNPP Response DOC M.1 and Required Achon G.1 will be revised, and the markup will be made consistent.

CTS 3.7.6.1 ACTIONS c, d, and e speofy the 5/30/97 Provide the appivpiiais 3.7.8-2 M.1 CTS N.6.1 ACTIONS c, d, and e remedial acbons to be taken when cae air intake Condsbons, ras, and JFD 3 Bases ITS 3.7.8 isolation valve, one exhaust to atmosphere Complebon Tirnes for the ACTIONS isolation valve, and one toilet area exhaust spec,ified Conditions or JFD 3 A, B, C, and D and isolation valve are inoperable in MODES 1 through provide additional discussion ;

Bases '

Associated Bases 4, respecbvely. ITS 3.7.8 ACTION D provides the and jusric,at;cr to show why JFD 7 Required Acbons for 2 air intake isolabon valves,1 they are not needed based toilet area exhaust isolabon valve and 2 exhaust to on current licensing Basis, absphere isolabon valves incpoiable during system design or Ope at,06al movement of irradiated fuel assemblies. The CTS c,0- 6 aints.

and ITS do not provide Conditions ras and appivpiiate Complebon Times for the following conditions: a. One air intake isolabon valve inoperable during rnovement of irradiated fuel assemblies. b. One exhaust to abrive'.ere isolabon valve inoperable during m&ement of assemblies. c. Two air intake or two exhaust to absphere isolabon valves ino Table during MODES 1,2. 3, or 4.

CCNPP Response The AcR-is will be revised to resolve these issues.

IIDC = Discussion of Change 23 JFD = Justf. caten for Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3,7.8 -

' DESCRIPTION OF ISSUE . -

S-NED CL SED 3.7.8-3 M.1 ITS 3.7.8 ITS 3.7.8 ACTION D provides the ras and 5/30/97 ITS 3.7.8 ACTIONS to be JFD 2 ACTION D and conyieben Tirnes for inoperable isolabon valves rearrorged and/or rewntien Associated Bases during movement of irradiated fuel assemblies. upon resoluGon ofitem 3.7.8-JFD 3 Bases This ACTION is ira,vicectif place in the sequence 2.

JFD 3 of ACTIONS. It should probably be placed after Bases ITS 3.7.8 ACTION F or G. See item Number JFD 7 3.7.8-2.

CCNPP Response:

This issue will resolved as part of the rewrite of thew w*vis Currecithis disuwpim n y.

3.7.84 M.1 CTS 3.7.6.1.c ITS B.3.7.8 Bases - RA D.1 states the followirg: 5/30/97 Bases CTS 3.7.6.1.d CTS "When two control room outsde air intake isolatos JFD 3 3.7.6.1.e ITS B3.7.8 valves, the toilet exhaust isolation valve, or Bases- exhaust to atmosphere isolabon valves are RA D.1 anoperable. ". This sentence is confusing. It either states that there are two of each type of valve or two intake valves, one toilet area valve and an indeterminate number of exhaust to abovsphere valves. CTS 3.7.6.1 c, d, and e, and ITS 3.7.8 Condition D specify the appropriate number of valves as two, one and two respechvely.

CCNPP Response This issue will be resolved as part of the rewnte of these w*ns and the Bases Doc = Discussion of change 24 JFD = Just!ficate for Deviation

ATTACHilflENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 CT S I TE A 3.7.8 DESCRJPTION OFISSUE 3.7.8-5 LA.1 CTS 3.7.6.1.a CTS CTS 3.7.6.1.a. 3.7.6.1.c, 3.7.6.1.d. and 3.7.6.1.e S/30/97 Provide these detasis in 3.7.6.1.c CTS 3.7.6.1.d requires the CREVS te be OPERABLE with two either ITS B3.7.8 BASES-CTS 3.7.6.1.e filter trains, two isolation valves in each control BACKGROUND or ITS room outside air intake duct, two isolation valves in 83.7.8 BASES-LCO.

the r:omrnon exhaust to a'u .usphere duct, and one isolation valve in the toilet area exhaust duct.

These details are not spec $ed in ITS 3.7.8, but are to be relocated to the Bases. The details on the isola'Jon valves have not been moved to the Bases. ITS B3.7.8 Bases-BACKGROUND and ITS B3.7.8 Bases-LCO which describe the cor!.ponents of an OPERABLE CREVS system do not contain these details.

CCNPP Response: l DOC LA.1 will be rewntten, and the details will be located in the Bases 3.7.8-6 LA2 CTS 4.7.6.1.e.2 ITS CTS 4.7.6.1.e.2 requires that the CREVS 5/30/97 Defu e CRRS in ITS B3.7.8 automatcally switches into a recirculation mode of BASES-BACKGROUND, LA.3 B3.7.8 Bases-BACKGROUND operation and the iso 8ation valves close on a and provide additional Bases JFD 2 control room high radiation signal ITS SR 3.7.8.3 discussion and p MI-M-s to does not contain this detail These details will be show that this is the Control moved to the ITS B3.7.8 BASES. ITS B3.7.8 does Room high radiatiori signal I

not seem to have this inicirnatun. ITS B3.7.8 speuf,cd in CTS 4.7.6.1.e.2.

BASES-BACKGROUND states that "The CRRS (

initiates pressurization and filtered ventilation of the air supply to the control r3om. CRRS is an undefined term, which may be the radiation signal CCNPP Resporne:

"CRRS" will i+;s defined in the Bases as the Control Room Recirculation Signal. This is the signal specified in CTS 4.7.6.1.e2. ITS 3.3.8 provides the requirements for this *::gnal DOC = Descussion of Change 25 JFD = Justification for Deviaton

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

- . .- . ~ .. - -

c ATTACHRENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRRATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 DA DESCRIPTION OFISSUE . g CORA4ENTS 3.7.8 CTS 4.7.6.1.e2 requires the ventwiui that on a 5/30/97 Delete this G==nya.

3.7.8-7 JFD 1 CTS 4.7.6.1.e.2 ITS SR BASES 3.7.8.3 and Associated control room high radiation signal the system au'er==iony switches into a recirculation mode of

^

JFD 1 Bases Opciouan. This surveillance is done on an 18-

^

month frequency ITS SR 3.7.8.3 per'wiris the same vent = 'uc6 except that it is done on a 24-month frrquency The change from 18-months to 24-months is justified using a generalized jM'-:A T-i (JFD 1/ BASES JFD 1) that inceipciaies CCNPP-specific hfuu= iui into the bracketed ir/uir==^&ni. The js'-:4-i used is wrong The change in frequency is ui-@.

and is beyond the scope of review for this conversion.

CCNPP Response This change in surveillance frequency from 18 to 24 months is smiar to other dww apprtM as part of ITS sutmttals. This is one of four such dwp discussed with the Calvert Cliffs Project Manager and tumed over to the oppc - r iaio technical branch. DOC L1 for ITS 32.8 was revised to provide additional jushf- nei as part of Revision 1 to the ITS Amendment Request dated June 9.1997.

ITS 3.7.8 and Associated See item Number 3.7.3-9. S/30/97 See item Number 3.7.3-9.

3.7.8-8 JFD 2 B.*.SES Bases JFD 2 CCNPP Response See response to NRC wn=rients S3.7.3-1 and S3.7.4-1.

l DOC = Discussion of Change 26 JFD = Justrfication for Deviation

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

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.

7.8 DESCRIPTION

OFISSUE CNN O ENED CLOSED 3.7.8-9 BASES STS 83.7.11 STS B3.7.11 Bases-SR 3.7.11.2 states that S/30S7 Reinsert the STS statement JFD 13 Bases- "The... filter tests are in accordance with Regulatory and Reference to RG 1.52 in SR 3.7.11.2 Guide (RG) 1.52) (Ref.3)? ITS B3.7.8 Bases-SR the appvrse place in ITS ITS B3.7.8 3.7.8.2 deletes this statement and Ref. 3 frorn ITS B3.7.X Bases SR 3.7.X.2 Bases B3.7.8 Bases-REFERENCE Section The Bases and ITS B3.7.X Bases-SR 3.7.8.2 for this deletion is that it was performed to ensure REFERENCES.

ITS B3.7.8 that the REFERENCES are applicable to CCNPP, Bases-REFERENCES and that not all the filter testing is in accordance with RG.1.52. ITS 5.5.11 states that the VFTP test shall be done in accordance with R.G.1.52 Rev. 2. There* ore, the justificaton Bases JFD 13 is wrong, ano the STS statement and Reference 3 should be reinserted into ITS B3.7.8 Bases SR 3.7.8.2 and ITS B3.7.8 Bases-REFERENCES, j

respectively. Furthermore, the staff would consider this change as a generic change. l l CCNPP Response:

JFD 13 for Bases secbon 3.7 will be revised to clarify our justiwbun for the deviation 3.

7.9 DESCRIPTION

OFISSUE CMM OPENED CLOSED 3.7.9-1 M.1 CTS 3.7.6.1 CTS 3.7.6.1 Insert ACTION C states the following 5/30/97 Correct this diweponcy.

Insert for Condition C:

Required Acbon and associated ACTION C Completion Time of Condition A not met in MODE ITS 3.7.9 1, 2, 3 or 4." ITS 3.7.9 Condition C states the Condition C following " Required Achon and MWed Cumpiebun Time of Condition A not met during rnovement of irradiated fuel assembles." M.1 and ITS 3.7.9 Condition C use the same tenr%y.

The CTSinsertiswrong CCNPP Response:

The CTS Insert for AMinn C wili be revised to be consistent with Acton C of ITS 3.7.9.

Doc = orscussen of change 27 JFD = Just#caten for Deviaton

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SEC110N 3.7 3.

7.9 DESCRIPTION

OFISSUE CMM D O ENED CLOSED 3.7.9-2 LA.2 CTS 4.7.6.1.a ITS SR UnS 4.7.6.1.a requires the backup Control Room 5/30/97 Provde the plant piecedures air wrdhers de-energized prior to venfying that to which the iniuuwoc.n.- is 3.7.9.1 moved and the procedure the emergency Control Room air conditioners can ma:ntain Control Room temperature in the change control recirculation mode of operation. ITS SR 3.7.9.1 requires venfying each CRETS train has the capability to maintain control room temperature within limits every 24 months. The specifics on how to conduct the Surveillance Recuirement are moved to plant procedures. The piant procedures and associated controls are not identified.

CCNPP Response:

DOC LA.2 will be revised to state that the information will be relocated to the Bases, and the Bases wi!! be revised.

3.7.9-3 CTS 3 7.6.1 LA.3 addresses changes to ITS 3.7.8 and thus is 5/30/97 Delete LA.3 frvm ITS 3.7.9 !

l 1.A3 junn,tuuns l not applicable to ITS 3.7.9.

' CCNPP Response:

DOC LA.3 will be deleted.

3.7.9-4 L.2 CTS 4.7.6.1.a ITS CTS 4.7.6.1.a requires maintarning CRETS Control 5/30/97 Delete this derge.

JFD 1 Room temperature within Timits <.mce per 62 days SR 3 7.9.1 and Bases on a STAGGERED TEST BASIS.

Ashed Bases JFD 1 ITS SR 3.7.9.1 requires ver.fying each CRETS i train has the capabihty to maintain control room temperature within limits every 24 months. The change 62 days on a STAGGERED TEST BASIS to 24 months is justified using a generalizec' justi*ication (JFD 1/ Bases JFD 1) that in.,v.pciated CCNPP-specific infuneLun into the bradeted information. The justifications used are wrong and the charme in frequency is unac.ceptable, and is beyond the scope of review for this conversion CCNPP Response:

This change in surveillance frequency from 62 days b 24 months is similar to other changes approved as part of ITS submittals. This is one of four such dernfs discussed with the Calvert Cli'is Project Manager and tumed over to the appropnate technical branch. DOC L2 for ITS 3.7.9 was revised to provde add:tional 8

justJfication as part of Revision 1 to the ITS Amendment Request dated June 9,1997.

DOC = Discussion of Change 28 JFD = JustG:ation for Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.9 . DESCRIPTION OF ISSUE Em OPENED CLOS D.

See item Number 3.7.3-9. 5f30/97 See iter.1 Nc. Thy 3.7.3-9.

3.7.9-5 JFD 2 ITS 3.7.9 and Associated Bases Bases JFD 2 CCNPP Response:

See response to NRC que s S3.7.3-1 n and S3.7.4-1.

8 DESCRIPTION OFISSUE 3.7.10 O ENED CLOSED CTS 3.7.7.1 requires the ECCS Pump Room 5/30/97 Revise ITS 3.7.10 ACTIONS, 3.7.10-1 LA.1 CTS 3.7.7.1 CTS 3.7.7.1 Exhaust Ventilation System OPERABLE with one j ITS SR 3.7.10.1 and LA.2 HEPA filter and charcoal adsorber train, and two Associated Bases to requsre L1 ACTION a JFD 1 CTS 4.7.7.1.a exhaust fans. CTS 3.7.7.1 ACTION a, requires that both ECCS PREFS fans JFD 4 ITS LCO 3.7.10 with one ECCS pump room exhaust fan to be OPERABLE.

ITS 3.7.10 inoperable, restore the snoperable fan to ACTIONS OPERABLE within 7 days. CTS 4.7.7.1.a requires ITS SR 3.7.10.1 and at least once per 31 days, by initiating, from the Associated Bases control room flow through the HEPA filter and charcoal adsorber train and venfying that each exhaust fan operates for at least 15 minutes. ITS LCO 3.7.10 does not address how many exhaust fans make up an ECCS PREFS train, but ITS B3.7.10 Bases-BACKGROUND states that ECCS PREFS consists of one train with two independent and redundant fans. ITS B3.7.10 Bases-LCO states that one train shall be OPERABLE and onty one fan is required OPERABLE, instead of one train and two fans are required OPERABLE. ITS 3.7.10 does not retain the ACTION when one exhaust fan is inopeiable, and ITS SR 3.7.10.1 does not require operation of both fans. The proposed change would allow indefinite operation of the ECCS PREFS with one fan inoperable. This is not in accordance with current I~censing basis DOC = Descussion of Change 29 JFD = Justncation for Deviation

ATTACHMENT (11 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICAT10NS 3ECTION 3.7 3.7.10 DESCRIPTION OFISSUE ED C and is unacceptable to the staff. rhere is inadeouate justificabon for removing tne CTS requiement for two fans OPERABLE. This change is consdered a beyond scope of review for this conversion. l CCNPP Response The Operability requirements for the Emergency Core Cooling System Pump Room Exhaust Filtration System have been revised 'o be consistent with CTS LCO 3.7.7.1. They are stated in the Bases Also, the Acbons for ITS 3.7.10 have been revised to be consistent with the Achons for CTS 3.7.7.1. ]

3.7.10-2 JFD 1 STS SR 3.7.13.5 STS SR 3.7.13.5 venfies that each ECCS PREFS 5/33/97 Either include STS SR Bases ITS B3.7.10 Bases- filter bypass damper can be opened. ITS B3.7.10 3.7.13.5 in the ITS or provde JFD 7 BACKGROUND Bases-BACKGROUND states during emerpc a addibonal dicevann and .q opc, ducts the ECCS PREFS dampers ate jtoLfcz00ii based on current i j realigned to initiate filtrabon STS SR 3.7.13.5 is rice-sg basis, system ;

deleted from ITS 3.7.10 based on a general design . or Opwiducts4 justification on items not consistent with the constraints to jushfy the CCNPP design. The justfications in this case are delebon of STS SR 3.7.13.5.

the wrong justificabon since tne design does include bypass darrl>ers.

CCNFP Response j The Standard Technical Specification (STS) surveillance was wntten for designs that have a bypass line to provide coohng to a loaded filter train that has been shut down post-accdent. The Calvert C1:ffs design does not include this feature. Therefore, while De_mino of Deviabon 1 does not provide specific details, it is accurate. This system is operated manually and the ITS ver~fies system operabon on a monthly basis. No additional survesitances are necessary tv dewe s4= flow through the filter train.

3 7.10-3 JFD 2 ITS 3.7.10 and See item Number 3.7.3-9. 5/30/97 See item Number 3.7.3-9.

Bases Associated Bases JFD 2 CCNPP Response See response to NRC commerits S3.7.3-1 and S3.7.4-1.

Oct = Descussion of change 30 JFD = Just rcation for Deviation

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ATTACHRENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 -

.3.7.10 f DESCRIPTION OFISSUE ED COISEWTS 3.7.10-4 Bases STS B3.7.13 STS B3.7.13 Bases-REFERENCES lists 5/30/97 Prtmde addeonal efemann JFD 11 Bases-REFERENCES Reference 4 " Regulatory Guide 1.52 Rev. 2" and and MTwi for the ITS B3.7.10 Reference 6 "NUREG-0800 Seebon 6.5.1, Rev. 2 delebon of these references.

BasestIEFERENCES July 1981"." ITS B3.7.10 Bases-REFERENCES See item Nurnbers 3.7.8-9 deletes these two references. The MTicatini and 3.7.-10-5.

(Bases JFD 11) used to delete the w".. wa, applies only to MSIVs not to ECCS PREFS. See item Numbers 3.7.8-9 and 3.7.10-5.

CCNPP Response-Justificabon for delebon of the references was provided in a change in JFD 4 to sechon 3.7 as part of supplemental Amendment Reqvest. Revision 1. to the :Ts '

subr uttal, dated June 9,1997. JFD 11 will be changed to JFD 4 3.7.10-5 Bases STS B3.7.13 See item Number 3.7.8-9 5/30/97 See 11em Number 3.7.8-9.

JFD 13 Bases-Bases SP 3.7.13.2 JFD 11 ITS B3.7.10 Bases SR 3.7.10.2

, , ITS B3.7.10 1 I

Bases RE", ERENCES CCNPP Response:

JFD 13 for W secbon 3.10 wiR be revised to cfarify ourM' A_- for the devebon 1

i

~ 3 7.11 DESCRIPTION OFISSUE 1 COMMENTS ]

FD OPE 3.7.11-1 IA1 CTS 3.9.12. CTS 3.9.12 requres SFPEVS OPERABLE with 5/30/97 ReviseITS3.7.11 ACTIONS, IA3 CTS 3.9.12 one HEPA filler bank, two charcoal adsorbers, and ITS SR 3.7.11.1, ITS SR L1 ACTION a two exhaust fans. CTS 3.9.12 ACTION a, regurec 3.7.11.3 and Assocated i JFD 3 CTS 4.9.12.a with one charcoal adsorber bank or one exhaust Bases e evyuire boih l JFD 16 CTS 4.9.12.d.2 fan snoperable fuel rnovement may proceec SFPEVS fans and charcoal ]

Bases ITS LCO provided an OPERABLE exhaust fan is in adsorber banks to be JF0 3 3.7.1. operabon discharging through an OPERABLE OPERABLE.

ITS 3.7.11 SFPEVS train of HEPA filters and charcoal Doc = Discussion of change 31 50 = Justdication for Deviation

.m-.

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.11- DESCRIPTION OFISSUE [ . COhWENTS ACTIONS adsorbers, CTS 4.9.12.a requwes at least once f ITS SR per 31 days, by inibahng flow through the HEPA 3.7.11.1 filter bank and both de@ adsorber banks and ITS SR venfying that each dewal adsorber bank and

^

3.7.11.3 and Associated each exhaust fan Opsaa-s for at least 15 minuets.

Bases CTS 4.9.12.d.2 venfies that each exhaust fan nsintains the spent fuel storage pool area at a measurable negatrve. pressure relatwe to the outsde ein usphere during system vpeiai,un on an 18 month frequency ITS LCO 3.7.11 does not address how many exhaust fans or dscoal adsorber banks nake up an SFPEVS train, but ITS B3.7.11 Bases-BACKGROUND states that SFPEVS consists of one train with two independent and redundant fans, one dwccai adsorber sechon. ITS B3.7.11 Bases-LCO states that one train shat! be OPERABLE and only one fan and one deicual Endscioci sechon are requred OPERABLE instead of one trah with two fans and two dwccai adsorber banks are required OPERABLE. ITS 3 7.11 does not retain the ACTION af one exhaust fan or one Gewa; adscits bank is inoperable ITS SR 3.7.11.1 l does nut require OpciaGe of both fans and both dewal adsoroer banks. ITS SR 3.7.11.3 does not require operaton of t,oth fans. The proposed enange would allow indefinne Operation of the SFPEVS with one fan and/or one dewal adsci'oci bank snoperabia This is not 'ri acccidance with current licensing basis and is unacceptable to the staff. There is inadequale juc!#ication for remowng thess CTS requrements and the change is consdered a beyond scope of rewew for this conversson.

DOC = Discussion of Change 32 JFD o Justrfication for Deviat;3

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ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORABATION IRRPROVED TECHNICAL. SPECIFICATIONS SECTION 3.7 3.7.11 CT S ..

. DESCRIPTION OFISSUE [ COIMNTS CCNPP Response The LCO for ITS 3.7.11 will be rewntten to require the system to be in operabon. This is more restnchve than the cupent licenseg hmic and is described in new DOC M.1. This change makes the current Aebon a uniecessary, since it is covered by the LCO.

3.7.11-2 LA.2 CTS 3.9.12 CTS 3.9.12 ACTION b requaes suspending aR 5/30/97 Provide M plant procedures ACTION b. operabons mvolving movement of fuel or crane to winch the informahon is operabon with loads over the storage pool ITS moved and the procedure 3.7.11 does not retam the crane OpoiaEmi change control reouirement. The heavy load (crane) requrements are rmved to plant procedures The specific piant procedure is not idenbfied nor how clear @ to these procedures are controlled by the plant change ax*of process CCNPP Response DOC LA.2 will be revised to state that the in'uinwinai wiR be relocated to the Updated Final Safety Analysis Report i

3.7.11-3 LA.3 CTS 4.9.12.a CTS 4.9.12.a requres the SFPEVS to rubated 5/30/97 Correct the Bases to show ITS SR 3.7.11.1 with flow through the HEPA filter and both charcoal this requeement. See item adsorbers ITS SR 3.7.11.1 does not retam tNs Number 3.7.11-1.

requirement. : This requrement will be moved to the Bases Tne Rmm does not contam this requrement See item Number 3.7.11-1. l CCNPP Response DOC LA.3 will be deleted as a result of other Gmi njas made to the Specificabort Doc = Discussion of change 33 JFD = Justsficabon for Deviabort g_______ _ _ . . . _

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

^

DESCRIPTION OFISSUE 1 COMMENTS 3.7.11 ED CLO _

3.7.11-4 L3 CTS 4.9.12.d.2 CTS Surveillance 4.9.12.d2 requires maintaining 5/30/97 Delete this ciwirye.-

l JFD 1 ITS SR 3.7.11.3 the SFPEVS measurable negatwe pressure Bases and Associated Bases relatwe to the outside tunuspireie once per 18 JFD 1 months. ITS SR 3.7.11.3 requires 6 dai6ing the SFPEVS measurable negatue pressure relatwe to the outside atmosphere once per 24 months. The change from 18 months to 24 months is justified based on Opeiainig history (L3)and using a generalized justificabon (JFD 1/ Bases JFD 1) that irwpciates CCNPP-speofic informahon into the bracketed inivimatbi. The latter justificabon used is wrong The change en frequency is unaci,epiau;e and is beyond the scope of review for this conversion.

CCNPP Response This change in surveillance frequency from 18 to 24 rnonths is similar to other d=69es approved as part of ITS sutxtuttals. This is one of four such changes discussed with the Calvert Cliffs Project Manager and tumed over to the appicpdate technical branch. DOC L3 for ITS 3.7.11 ms revised to provide addibonal just% tion as part of Revision 1 to the ITS Amendment Request dated June 9.1997.

3.7.11-5 JFD 1 STS SR STS SR 3.7.14.5 venfies that each FBACS filter 5/30/97 Ediier include STS SR i Bases 3.7.14.5 bypass damper can be opened ITS B3.7.10 3.7.14.5 in the ITS or provide JFD 1 ITS B3.7.11 Bases- Bases-BACKGROUND states that during normal additional discussion and BACKGROUND cpertuc6 the deccal adscrucis are bypassed justificabon based on current ,

and it is implied that during emergency Opefat47 licensing basis, system l the SFPEVS dampers are reali* to initiate or Opciaimni i desegn, filtrabon STS SR 3.7.14.5 is dek - Nm ITS constraints to jushfy the '

j 3.7.11 based on a generaljustificabon on items not delebon of STS SR 3.7.14.5.

consistent with the CCNPP design. The 1 justificabon in this case are the wrong jusisk,duc6s since the design does include bypass derivers.

CCNPP Response The STS surveillance was wntten for designs that have a bypass line to provide cooling to a loaded filter train that has been shut down post-acodent. The CCNPP design does not include this feature. Therefore, while Discussion of Deviabon 1 does not provide specific details, it is accurate. This system is operated manually and the ITS verifies system Opcituc6 during fuel movement. No addibonal surveillances are rwm y.

DOC = Discussion of Change 34 JFD = Justfricabon for Devinhon

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ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.11

~

' DESCRIPTION OFISSUE C6 D. C 3.7.11-6 JFD 2 ITS 3.7.11 and See item Number 3.7.3-9 5/30/97 See ie. Number 3.7.3-9.

! Bases Associated Bases

! JFD 2 CCNPP Response See response to NRC comments S3.7.3-1 and 3.7.4-1.

Bases STS B3.7.14 See item Numbers 3.7.8-9. 3.7.104, and 3.7.11-8. 5/30/97 See item Numbers 3.7.8-9, 3.7.11-7 JFD 11 Bases 3.7.104 and 3.7.11-8.

REFERENCES ITS B3.7.10 Bases REFERENCES CCNPP Response Justifcskm for deletion of the refeein 4-5 was provided in a change to JFD 4 to sechon 3.7 as part of supplemental Amendment Request, ree.sion 1, to the ITS 1 submi%3. dved June 9.1997. JFD 11 will be c.1==-@ to JFD 4.

3.7.11-8 Bases STS B3.7.14 See item Number 3.7.8-9. 5/30/97 See item Ntn h 3.7.8-9.

JFD 13 Bases Bases SR 3.7.14.2 JFD 13 ITS B3.7.11 ;

l Bases l

SR 3.7.11.2 iTS B3.7.11 Bases REFERENCES CCNPP Response ,

JFD 13 for Bases sechari 3.7 was revised to clanfy ourju.J - sk-. for this deviabon.

DOC = Discussion of Change 35 JFD = Mhm for Deviation

ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRAATION IRAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.11 DESCRIPTION OFISSUE ED Ct. S D g

3.7.11-9 None CTS 3.9.12 CTS 3.9.12 ACTION b requires suspending a6 5/30/97 Provide a discussion and

,CTION b operations involving movement of fuel within the justificabon for the C.E ,ged ITS 3.7.11 storage pool when the HEPA filter bank is CTS requrement.

ACTION A inoperable, or with two charcoal adsorber banks inoperable, or with two exhaust fans inoperisble.

ITS. 3.7.11 ACTION A requires immediately suspending movement of irradiated fuel assemblies in the auxiliary building when SFPEVS is irioperable. Components of the SFPEVS could be inoperable in the CTS and the whole system is inoperable in the ITS. There is no discussion or justification for removing the CTS ACTION requirements.

CCNPP Response The LCO for ITS 3.7.11 will be revised in response to NRC comment 3.7.11-1.

3.7.12 DESCRIPTION OFISSUE NED C 3.7.12-1 LA1 CTS CTS 4.6.6.1.a describes the manner in which this 5/30/97 include this information in 4.6.6.1.a surveillance demonstrated the flow for the ITS B3.7.12 Bases ITS SR PREVS to be OPERABLE. The special manner 3.7.12.1 and Associated in which the test L, perforrred is not included ITS Bases SR 3.7.12.1 but is relocated to the Bases. This information is not included in ITS B3.7.12 Bases.

CCNPP Response The Bases will be modified to include this infu nWuca, justified by DOC LA1, and DOD 10.

D')C = Discussion of Change 36 JFO = Justircation for Deviation

~

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 3.7.12 DESCRIPTION OFISSUE OMMENTS O ENED C OSED 3.7.12-2 JFD 1 CTS 4.6.6.1.d.2 CTS 4.6.6.1.d.2 requires verifying at least once 5/30/97 Delete this chango.

Bases ITS SR 3.7.12.3 per 18 months that PREVS starts on a JFD 1 ITS Containment Isolation Test signal. ITS SR B3.7.12 3.7.12.3 requires verifying that each PREVS Bases trains actuates on an actual or simulated SR 3.7.12.3 actuation signal once per 24 months. The change from 18 months to 24 months is justified j in the ITS Based on a generalizect justification (JFD1/ Bases JFD 1) that incorporates CCNPP-specific information into the bracketed information. This justification is wrong. In addition, the CTS markup does not show this change or provide a justification for it. The change in frequency is unacceptable and is beyond the scope of review for this conversion.

CCNPP Response: '

DOC L1 was provided to justify the change from a frequency of 18 to 24 months. Frequency extensions from 18 to 24 months have been included as within the scope of the ITS conversbn. and this was a change discussed with the NRC Project Manager for Calvert Cliffs.

3.7.12-3 JFD 1 STS SR STS SR 3.7.15.5 verifies that each PREACS filter 5/30/97 Either include STS SR Bases 3.7.15.5 bypass damper can be opened. ITS B,?.7.12 3.7.15.5 in the ITS or JFD 1 ITS B3.7.12 Bases-BACKGROUND states that *During provide additional Bases- emergency operations, the PREVS dampers are discussion and just:fication BACKGROUND realigned.. " STS SR 3.7.14.5 is deleted frem ITS based on current licensing 3.7.12 based on a general justification on items basis, system design or not consistent with the CCNPP design The operationa! constraints to justifications in this case are the wrong justify the deletion of STS justifications, since the design does include SR 3.7.15.5.

bypass dampers.

CCNPP Response:

The STS survei!!ance was written for designs which have a bypass line to provide cooling to a loaded filter train that has been shutdown post-accident. The CCNPP design does not include this feature. Therefore, while DOD 1 does not provide specific details, it is accurate, this system is operated manually and the ITS venfies system operation during fuel movement. No additional surveillances are necessary Doc = oescussion of chang, 37 JFD = Justification for Deviation

- w AIIACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

^ COMMENTS 3.7.12 DESCRIPTION OFISSUE ED RO 3.7.12 4 JFD 2 ITS 3.7.12 See item Number S..'.3-9 5/30/97 See item Number 3.7.3-9 Bases- and Associated Bases JFD 2 CCNPP Response See response to RAI S3.7.3-1 and S3.7.4-1.

3.7.12-5 JFD 3 CTS 3.6.6.1 CTS 3.6.6.1 ACTION requires restoring PREVS 5/30/97 Provide discussion and Bases ACTION to OPERABLE status within 7 days or be in at justificate for changing the JFD 3 STS 3.7.15 least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD CTS required shutdown RA B.2 SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . from COLD SHUTDOWN ITS 3.7.12 Under the same condition ITS 3.7.12 RA B2 (MODE 5) to MODE 4.

RA B.2 and Associated requires being in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE Provwie justification for the 6ases 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . STS 3.7.15 RA B.2 requires being STS deviabon based on in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . current licensing basis.

There is no discussion or justifn Gen for system design, or operaanist constraints.

^ -

changing the CTS shutdown requirement from COLD SHUTDOWN to MODE 4 in ITS 3.7.12 RA B.2. The change results in a STS deviation which could be considered as a generic change. !

CCNPP Response The CTS will be revised DOC A.4 will be provided to justify the change, and DOD 19 will be provided to justify the deviabon from NUREG-1432.

3.7.12-6 Bases STS B3.7.15 See item Number 3.7.8-9 5/30/97 See Item Number 3.7.8-9 JFD 13 Bases 3.7.15.2 ITS B3.7.12 Bases SR 3.7.12.2 CCNPP Response JFD 13 for Be Sechon 3.7 will be revised 'o clanfy ourjustrficabon for the deviabon DOC = Drscussion of Change 38 JFD = Just:5 cation for Deviation

ATTACHRAENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORRRATION 1RAPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

' ^ ^

DESCRIPTION OFISSUE COMMENTS

_ 3.7.12 L O ENED COSED 3.7.12-7 None CTS 4.6.6.1.a CTS 4.6.6.1.a requires the PREVS be 5/30/97 Provide discussion and ITS SR demonstrated OPEPABLE at least once per 31 jusbra,ouon for this 3.7.12.1 days on a STAGGERED TEST BASIS. ITS SR Administratrve change which and Associated Bases 3.7.12.1 requires operating each PREVS train for changed . CTS Frequency 2 15 minutes every 31 days. There is no requirement.

discussion or justification for thir, Administrative change of removing the CTS requirement to demonstrate PREVS OPERABLE on a STAGGERED TEST BASIS.

CCNPP Response

_The CTS markup will be revised to delete the reference to *on STAGGERED TEST BASIS." ar 1 DOC L2 will be provxied to justify the change 3.7.13- DESCRIPTION OFISSUE CLOSED O ENED 3.7.13-1 LA.1 CTS 3.9.11 CTS 3.9.11 ACTIONS require crane cperations 5/30/97 Provide the plant Actions with loads in the fuel storage areas to be procedures to which the suspended when the spend fuel level is not within information is rrxmed and limits. ITS 3.7.13 does not contain this the procedure change requirement This requirement will be moved to control.

plant procedures. The plant procedures and associated controls are not identified.

CCNPP Response:

DOC LA.1 will be revised to indicate that controls for crane operations with loads over the fuel storage pool are to be relocated to the UFSAR under the control of 10 CFR 50.59.

3.7.13-2 JFD 2 ITS 3.7.13 and See item Number 3.7.3-9 5/30/97 See item Number 3.7.3-9 Bases Associated Bases JFD 2 CCNPP Response i See response to RAI S3.7.3-1 and S3.7.4-1. l l

DOC = Discussion of Change 39 JFD = Justdication for Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7

^ ^

3.7.13 DESCRIPTION OFISSUE COMMENTS OPENED aOSED 3.7.13-3 Bases ITS B3.7.13 ITS B3.7.13 Bases-APPLICABILITY. ITS B3.7.13 SGG97 Correct this dnevanc.f.

JFD 2 Bases Bases-ACTIONS, and ITS B3.7.13 Bases-SR APPLICABILITY 3.7.13.1 do not show any changes. However ITS B3.7.13 they have a Bases JFD 2 associated with them.

Bases- ACTIONS ITS B3.7.13 Bases SR 3.7.13.1 CCNPP Response:

A global change is anLGed on the first page of ITS 3.7.13 Bases wtuch Ciornges fuel storage pM to SFP. DOD 2 is shown in thesa par &g%iis to denote th:s change in the ISTS markup.

3.7.13-4 None CTS 3.9.11 CTG 3f.11 requires a minimum of 21 1/2 feet of SGG97 tacensee to delete this STS LCO *ater be maintained over the top of irradiated fuel change.

3.7.16 -rssembhes seated in the s% racks. STS ITS LCO LCO 3.7.16 requires SFP water level sh30 be 3.7.13 2{23] ft over the top of irradiated fuel assen-LM seated in the storage racks iTS I.CO 3 7.13 changes the STS requvement to "The SFP water level is within Inn:ts." T'lis change is dwignated CEOG-116 in the ITS inarkup. It is the stats understanding that this changa has been wdhdrawn fvn the generic revew process.

CCNPP Response:

i This was corrected in Revison 1 to the Calvert Cids ITS submd'al by letter dated June 9.1997.

Doc = Drscussa of Cha p 40 JFD = Justt6catm for Deviata

a ATTACM (1) l RESPONSES TO REQUEST FOR ADDmONAL 588 0558411088 IMHOWED TEQWACAL S*ECFICATIOf05 SECTION 3J 31.14 : LCO -

DE mmOFISSUE OPEBED CLOSED JFD-LA.1 CTS Tath CTS Table 4.7-2 contarts a requwement to do a Sf30t97 Provide the plant 3.7.14-1 4.7-2 gross actmty determmaton at least once per 72 prrw=*=es to whch h ITS 3.7.14 hours. ITS 31.14 does not contam this informebon is moved and requwement The requwement for tha gross the promdure change actmty is moved to plant procedures. The control specnic piant procedure is not idenedied nor how changes b these promdures are controlled by the piant change control promss.

CCNPP Response DOC L1 wiB be prtmded to M deleton of the re ' _.si and DOC LA.1 wiB not be used. '

3.7.14-2 JFD 2 ITS 3.7.14 See item Number 3.7.3-9 500f97 See leern Number 31.3-9.

Bases and AW Bases JFD 2 CCNPP Response.

See resportse to RAI S3.7.3-1 and S3.7.4-1.

'I JFD = Juseneshon for Dewsbon

ATTACHMENT M1 RESPONSES TO REQUEST .cOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPEuMTIONS SECTION 3.7

^ COMMENTS DESCRIPTION OFISSUE ED a CO __

Prmnde %.:uio 6mm l STS 3.7.3 is not included in the CCNPP 5/30S ITS. 7The S3.7.3-1 JFD 7 STS 3.7.3 Bases

)4wiu i (JFD 7) states that these va!ves are not and p ^ L_;-=> to show that JFD 7 containtrent isolaban valves and are not credsted the MFNs and MFW Bypass in the safety analysis. The staff w-h the valves are not wJouwea t

4

51V and MFIV bypass valves to have rnore than isolabon vatves and that the l one safety funcbon in addition to wJouww A add:bonal sa8ety funcbons isolabon. Thus a separate sp-50 atW, whch specr5ed in STS B3.7.3 addresses these other safety funcbons as Bases are nct WLu=1 by specfied in STS B3.7.3 - Bases APPUCABLE the CCNPP MFIVs and MFIV SAFETY ANALYSES and LCOis provded. bypass vahes If they do, include STS 3.7.3 in the CCNPP ITS. Reference to UFSAR secbons, bcensee doctui= Jdu.. and ,

++ + 44 staff SERs or l letters rnay be suf5oent to resolve this issue. 1 CCNPP Response NUREG LCO 3.7.3 wdl be added as ITS LCO 3.7.15. and DOD 7 w:1! be revised DOC = Discusson of Chang, 42 JFD = Jushfx: sten for Deviaton

AT1 ACIM (1)

RESPONSES TO REQUEST FOR ADDmONAL INFORERATION AFROVED TECHNICAL SPECFICATIONS SECTION

3.7 DESCRIPTION

OFISSUE [ CORAENTS S3.7.4-1 JFD 8 STS 3.7.4 STS 3.7.4 is not included in me CCNPP ITS. The 5/30/97 Pronde addeonel docuomon and passer =hari b shour met Bases Jusbliemhnn (JFD 8) states that me ADVs are not JFD 7 credeed in the Salety Analyses. The staK consders me addeonal seself the ADVs to have more than one salsty funchon, funchons W in STS and are considered the pnmary valves mat are B3.7.4 R=mma are not used dunng a SGTR event. Thus a separate performed by the' CCIWP speedcanon, whch addresses ow:,e emer sassey ADVs. w they do ndude funchons as specded in STS B.3.7.4. Ramat- STS 3.7.3 in CCNPP ITS. '

APPUCABLE SAFETY ANALYSES and LCO, is Reference to UFSAR prowded. Semons. limnsee documen-tenon and A-===aare star SERs or letters rney be -

sullioent to resolve his sensa.

CCNPP Response DOD 8 will be rc.Md to prende adddional plant sp*)e for not includwig the LCO on the ADVs_

I l

DOC = Docussion of Change 43 ED = JustAcahon for Devuhon

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

NITACllMENT (2)

IMPROVED TECilNICAL SPECIFICATIONS, REVISION 6

SUMMARY

OF CIIANGES llattimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 6,1997

1 ATTACllMi'NT (2)

SUMMARY

OF CilANGES

1. To rasolve NRC Comment 3.7.1 1, the Unit 2 CTS markup for Improved Technical Specification (ITS) 3.7.1 for the addition of an Action Note has been revised to be consistent with tL Unit I Current Technical Specification (CTS) markup. The change isjustified by Discussion of Change (DOC) DOC A.3 for ITS 3.7.1. Also, the LA.l writeup was removed because it was

inadvertently left in when the LA.1 annotation was deleted.

2. To resolve NRC Comment 3.7.14, DOC L.3 for ITS 3.7.1 and its associated No Slgnificant

llazards Considerations (NSilC) were revised to provide justification for the change.

3. To resolve NRC Comments 3.7.15 and 9, the following changes were made: 1) Discussion of

Deviation (DOD) 14 to Section 3.7 was revised to clarify that we are retaining our current

, licensing basis values for main steam safety valve lift settings; 2) the NUREO Bases markup for Surveillance Requirement (SR) 3.7.1.1 was revised to appropriately tellect our current licensing basis, and to state that we impose more restrictive requirements in the plant procedure; 3) DOD j 16 for Hases Section 3.7 was revised to clarify our justification; and 4) DOD 19 for Bases l

Section 3.7 was added tojustify an editorial change. l l 1

! 4. To resolve NRC Comment 3.7.16, the following changes were made: 1) the CTS markup for !

ITS 3.7.1 has been revised to include the requirement for the lift settings of the MSSVs to bc ,

! within *1% following testing. This change is justified by DOC M.2 for ITS 3.7.1; 2) the I

NUREG markup for ITS SR 3.7.1.1 has been revised to be consistent with the NUREO; and-

3) DOD 17 for ITS 3.7.1 has been deleted, because it is no longer used.

5. To resolve NRC Comments 3.7.17 and 8, the NUREO Bases markup for ITS 3.7.1 was revised to eliminate a deviation that was no longer required, and to change the justification for several :

deviations from DOD 7 to DOD 3 for Bases Section 3.7.

6. To resolve NRC Comments 3.7.21,2, ar the following changes were made: 1) the CTS markup for ITS 3.7.2 of the Mode 1, i was revised; 2) DOC A.5 for ITS 3.7.2 was climinated; 3) DOC M.4 for ITS 3.7.2 % added; 4) DOC A.6 for ITS 3.7.2 was revised; and

2) the CTS markup for ITS 3.7.2 of the Modes 2 and 3 Action was revised.

7. - To resolve NRC Comments 3.7.2 4 and 5, the following changes were made: 1) the CTS markup for ITS 3.7.2 was revised to restore the requirement regarding the main steam isolation valve closure time and to revise the SR Note to be consistent with NUREG 1432; 2) DOC LA.1 for ITS 3.7.2 was climinated; 3) DOC L.4 for ITS 3.7.2 was revised; 4) the NUREO markup for ITS SR 3.7.2.1 was revised to be consistent with NUREG 1432, except for the incorporation of j the plant cpecific va!ue; 5) DOD 15 for ITS 3.7 was climinated; and 6) the NUREO Bases markup for SR 3.7.2.1 was revised to be consistent with the revised ITS. Also, the Note for ITS SR 3.7.2.1 only requiring the SR in Modes 1 and 2 was removed, the related Bases writeup was also removed. These valves are tested in Mode 5. DOC L.4 and associated NS11C are not used, 1

and DOD 22 is added. The phrase "on an actual or simulated actuation signal" was removed to accommodate the stated l'requency and reflect how testing is conducted, and DOC 15 is added.

8. To resolve NRC Comment 3.7.2 6, the justification for a generic change to the Applicability Section ofITS 3.7.2 was changed from " generic editorial" to DOD 3 for Bases Section 3.7.

I s

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

ATTACllMENT (2)

SUMMARY

OF CilANGES

9. To resolve NRC Comment 3.7.2 7, DOD 11 for llases Section 3.7 was revised to provide additional justification for stating that the main steam isolation salves are not containment isolation valves.

10. To resolve NRC Comment 3.7.31, the CTS and NUREO markups were revised to reflect the addition of a new action to verify surveillance pe formaace, and DOC A.3 and L.5 were revised to provide additional justification in addition, typographical errors in the typed Calvert Cliffs Bases were corrected.

11. To resolve NRC Comment 3.7.3 4, DOC L.3 was revised to provide additionaljustification. The CTS markup was also revised to show DOC L.3 applying to the change in Mode.

12. To resolve NRC Comment 3.7.3 5, DOC LA.2 was revised to indicate that the relocated information is moved to the liases. The Bases for Condition A was revised to include the relocated information.

13. To resolve NRC Comment 3.7.3 6, the CTS and NUREO markups were revised to reflect the use of administrative controls during testing. In addition, DOD 9 to Section 3.7 was also revised to reflect the use of administrative controls.

14. To resolve NRC Comment 3.7.3 7, DOC LA.5 was revised to indicate that the relocated information is moved to the Inservice Testing Program under the control of 10 CFR 50.55(a).

15. To resolve NRC Comment 3.7.3 3,3.7.3 8,3.7.315, and 3.7.4 4, new DOD 20 for Section 3.7 was provided tojustify the deletion of the auxiliary feedwater (AFW) Mode 4 requirements, and SR 3.7.3.5 was revised to delete references to Modes 1,2, and 3 since they are the same as the Modes listed in the Applicability of the Limiting Condition for Operation (LCO) and are not necessary to be repeated.,

16. To resolve NRC Comment 3.7.310, DOD 10 for Section 3.7 was revised to provide additional justification related to not including the AFW steam supply valve Action.

17. To resolve NRC Comment 3.7.311, the CTS markup was revised to reflect the additional Completion Time for AFW pump inoperability, and new DOC M.4 was added to justify the change,

18. To resolve NRC Comment 3.7.41, DOC LA.1 has been revised to state that the specific component numbers are relocated to the Bases. The Bases have been revised to include the relocated material.

19. To resolve NRC Comment 3.7.4 2, DOC LA.2 has been revised to state that the details associated with the backup water supply are relocated to the Bases. The Dases have been revised to include the relocated material.

20. To resolve NRC Comment 3.7.4 5, ITS SR 3.7.4.1 was revised to delete the "per imit" requirement and require a " usable" volume. DOC A.3 was added to describe this change. In 2

NLTACilMI'NT (2)

SUMMARY

OF CilANGES addition, the Bases for Condition A and SR 3.7.4.1 were revised to clarify the applicability of an out oflimit condition to both units.

21. To resolve NRC Comment 3.7.4 6, the Bases were revised consistent with Technical Specification Task Force TS1T 174.

22. To resolve NRC Comment 3.7.51 and 3.7.5 4, the CTS markup and DOCS were corrected for system naming conventions. The CTS markup was also revised to add the NUREO Note pertaining to individual component isolation and DOC A.5 was added to justify the addition of the Note.

23. To resolve NRC Comment 3.7.5 2, DOC LA.2 has been revised to state that the actuation signals are relocated to the Bases. The Bases were revised to include the relocated material.

24. To resolve NRC Comment 3.7.5 5, the Bases Background section was revised to clarify the method of post loss-of coolant accident heat removal following a passive failure of the Component Cooling System, consistent with the method described in the Updated Final Safety Analysis Report.

25. To resolve NRC Comment 3.7.6-4, the CTS markup was revised to add the NUREO Note pertaining to individual component isolation and DOC A.5 was added to justify the addition of the Note.

26. To resolve NRC Comment 3.7.71, the NUREO markup was revised to add the missing detail for actuation signals consistent with the typed ITS.

27. To resolve NRC Comment 3.7.7 3, the ITS and the CTS markup were revised to add the NUREO Notes pertaining to cascading requirements for inoperable Saltwater System. DOC A.4 was also added tojustify the addition of the Notes.

28. To resolu NRC Comment 33.7 4, the CTS markup was revised to add the NUREO Note pertaining to %di: Uual component isolation and DOC A.5 was added to justify addition of the Note.

29. To resolve NRC Comments 3.7.8-1,3.7.8 2,3.7.8 3,3.7.8 4,3.7.8 5, and 3,7.8 6, the following changes were required: 1) the CTS markup for IT* 3.7.8 was revised; 2) DOCS A.5 and M.i for ITS 3.7.8 were revised; 3) the NUREO markup for ITS 3.7.8 was revised and the deviations were justined by DOD 1. DOD 2, or DOD 3 for Section 3.7; and 4) the NUREO Bases markup for ITS 3.7.8 was revised and the deviations were justined by DOD 2, DOD 3, or DOD 7 for Bases Section 3.7.

30. To resolve NRC Comments 3.7.8 9, 3.7.10 5, 3.7.118, and 3.7.12.6, DOD 13 for Bases Section 3.7 was revised to clarify ourjusti0 cation for the deletion of the reference to Regulatory Guide 1.52 from the Bases ofITS SRs 3.7.8.2,3.7.10.2,3.7.11.2, and 3.7.12.2.

31. To resolve NRC Comment 3.7.91, the Insert for Action C contained in the CTS markup for ITS 3.7.9 was revised to be consistent with Action C ofITS 3.7.9.

3

AffACllMENT12)

SUMMARY

OF CllANGES l

32. To resolve NRC Comments 3.7.9 2 and 3, the followings changes were made: 1) DOC LA.2 for

!TS 3.7.9 was revised to state thtt the information is being moved to the llases for ITS 3.7.9, not plant procedures; 2) the NUREG markup for ITS SR 3.7.9.1 was revised to include the information; and 3) DOC LA.3 for ITS 3.7.9 was eliminated, because it was not u:ed.

Additionally, the CTS markup for ITS 3.7.9 was revised to denote that the specific temperature requirements were also moved to the Bases, and an editorial correction was made to DOC LA.1 for ITS 3,7.9.

33. To resolve NRC Comment 3.7.101, the following changes were made: 1)the CTS markup for ITS 3.7.10 was revised to maintain the current operability requirements and actions; 2) DOC LA.2 for ITS 3.7.10 was revised; 3) DOC L 1 for ITS 3.7.10 and its associated NSilC were deleted because they were no longer used; 4) the NUREG markup for ITS 3.7.10 was revised to maintain the current operability requirements and actions and these deviations were justified by i DOD 4 for ITS 3,7; and 5) the NUREG Bases markup was revised to be consistent with the revised specification and these deviations were justified by DOD 3 and DOD 7 for liases Section 3,7. Additionally, while resolving this comment, inconsistencies and typographical i errors were identified in the NUREG liases markup for ITS 3.7.10 and the typed Dases. These i were corrected.

34. To resolve NRC Comments 3.7.10-4 and 3.7.117, the justification for deleting references in the

. NUREG 13ases markups for ITS 3,7.10 and 3,7,11 was changed from DOD 11 to DOD 4 for flases Section 3.7. While resolving this comment, it was discovered that a deleted reference in the NUREO Dases markup for ITS 3.7,12 should also have been justified by DOD 4 for Bases Section 3.7. The NUREO Dases markup for ITS 3,7.12 was revised to proylde the correct DOD for deleting the reference.

35. To resolve NRC Comments 3.7.11 1, 3.7.112, 3.7.113, and 3.7.119, the following changes

. were made: 1) the ITS LCO requires the Spent Fuel Pool Exhaust Ventilation System to be in operation; 2) the CTS markup for ITS 3,7.l! was revised; 3) DOC LA.2 for ITS 3,7.11 was revised to account for one of the changes; 4) DOC M,1 for ITS 3.7.11 was created tojustify most j of the additional changes; DOCS LA,3 and L.I (and its associated NSHC) were climinated, because they were no longer appropriate; 5) the NUREG markup for ITS 3,7.11 was revised; 6) the additional deviations to the NUREG Specification were justified via DOD 21 for ITS 3,7; 7) the NUREG Bases markup for ITS 3,7.11 was revised to be consistent with the revised markup i for ITS 3,7.11t and 8) the deviations from the NUREG Hases were justified by DOD 2 and DOD 7 for Bases Section 3.7,

36. To resolve NRC Comment 3.7.121, the NUREG Hases markup for ITS SR 3.7,12,1 was revised

to include information deleted from the CTS via DOC LA.1 for ITS 3.7.12. This deviation is justified by DOD 10 for Bases Section 3.7, i

37. To resolve NRC Comment 3,7.12 5, the following changes were made: 1) the CTS markup of the Action for ITS 3,7.12 was revised; 2) DOC A,4 for ITS 3.7.12 was provided to justify the -

change; and 3) DOD 19 for ITS 3.7.12 was provided to justify the deviation from the NUREG, in addition, the Applicable Safety Analyses and Applicability sections of the flases were j modified to accurately reflect the design basis for PREVS.

4

)

NiTACilbiFNT d)

, SUMM ARY OF CHANGES

38. To resolve NRC Comment 3.7.12 7, the following changes were made: 1) the CTS markup of ITS 3.7.12 was revised to delete the reference to "on STAGOERED 7 EST BASIS;" and 2) DOC L.2 for ITS 3.7.12 and its associated NSilC were provided tojustify the change.

39. To resolve NRC comment 3.7.131. DOC LA.! was revised to indicate that controls for crane operations with loads over the fuel storage pool are to be relocated to the Updated Final Safety Analysis Report under the control of 10 CFR $0.$9.

40. To resolve NRC Comment 3.7.141, DOC LA.! was deleted and replaced by new DOC L.I which justifies the deletion of gross radioactivity determinations.

41. To resolve NRC Comment S 3.7.31, NUREO 3.7.3 is marked up to show the addition of the 1 main feedwater isolation valves. DOD 7 is also revised to include the main feedwater isolation valves into the ITS 't he Specification is added to the end ofITS Section J 7 to minimire the documentation changes since it was not included in the orig!nal submittal.

42. To resolve NRC Comment S 3.7.41, DOD 8 to Section 3.7 has been revised to include the plant-specification justification for not including the atmospheric dump valve Specification (NUREO LCO 3.7.4).

43. During a review to ensure LA DOCS were properly addressed, several issues were discovered that required changes to be made. The changes were: 1) the NUREG Hases markup for ITS ,

SR 3.7.8.3 was revised to incorporate the information relocated by DOC LA.2 for ITS 3.7.8; 2) the NUREO Bases markup for ITS SR 3.7.12.3 were revised to tellect the information relocated by DOC LA.2 for ITS 3.7.12. 'lliese deviations werejustified by DOD 10 for Bases Section 3.7.

44. A change was made to the Bases of LCO 3.7.3 to provide additional clarification on the application of a CTS allowance. The CTS allows AFW trains required for operability to be taken out of service under administrative control for the perfonnance of periodic testing. This allowance is retained in ITS 3.7.3 as an LCO note.

45. A change was made to the Bases of LCO 3.7.4 to remove a statement that the condensate was returned te the condensate storage tank (CST). The condensate is returned to the backup CSTs, not the shared CST covered by the LCO.

46. To resolve NRC comment 3.7.313 new DOD 21 was added to NUREG Dases for SR 3.7.5.5 (ITS SR 3.7.3.7) tojustify deleting a flow requirement for CST flow path operability.

47, To resolve NRC comment 3.7.312, a clarification was added to the Bases of ITS 3.7.3 Condition F, which indicates that only non safety related equipment is available for cooldown following a loss of both trains of AFW. His meets the intent of the existing statement in the NUREG Bases tojustify why LCO 3.0.3 actions are suspended.

48. To resolve NRC comment 3.7.6 2, DOC LA.1 is revised to indicate that the service water valves do not get a signal from the containment spray actuation signal, and that the signal is not retained in the Bases for these valves.

5

ATIACilMENT Q) i

SUMMARY

OF CllANGI:S l

J

49. A change was made to the !!ases of LCO 3.7.3 to correct a statement that the AFW pumps are :

only required to supply water to either steam generator. 'llie pumps are required to be capable of j supplying water to both steam generators for operability.

4

50. A change was made to the liases of LCO 3.7.4 to correct a llases Condition D statement to

, match the LCO and to identify examples of train inoperabilities versus pump inoperabilities in Conditions A,Il and C.

I '

51. Changes were made to the Background section of the NUREO !!ases markup for ITS 3.7.8 to l match the typed Calvert Cliffs 11ases. In addition, a statement in the 11ackground section ,

i describing that the control room is pressurized has been deleted since the Control Room 3 Emergency Ventilation System does not and is not assumed to pressurize the control room Some nomenclature and liases statements were modined or removed to be consistent with plant j design and nomenclature.

i l

i I

l 4

Y I

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

v t e Letter Sequence Other
TAC:M97363, TSTF-19, TSTF-88, TSTF-64 (Approved, Closed) TAC:M97364, TSTF-19, TSTF-88, TSTF-64 (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance... Administration Meeting Questions 29 May 1997 6 June 1997 11 June 1997 16 May 1997 22 October 1997 Answers 27 March 1997 Results Approval Other: ML20140H545, ML20141B944, ML20198K326, ML20198R718, ML20210K953, ML20217G338, ML20217G370, ML20217K605
MONTHYEAR1997-05-07 [Table View]

ML20217G370

Text

REFERENCE:

7.1 DESCRIPTION

7.1 DESCRIPTION

7.1 DESCRIPTION

7.1 DESCRIPTION

1.5 DESCRIPTION

7.3 DESCRIPTION

7.3 DESCRIPTION

7.4 DESCRIPTION

3.7 DESCRIPTION

7.5 DESCRIPTION

7.3 DESCRIPTION

7.7 DESCRIPTION

7.8 DESCRIPTION

7.9 DESCRIPTION

7.9 DESCRIPTION

3.7 DESCRIPTION

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

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