Text

Forwards Response to 970611 RAI Re License Amend Request to Convert to Improved Std Tss.Response to Section 3.8 Provided in Attachment 1.Rev 8 to Original License Amend,Encl
	ML20217K605
Person / Time
Site:	Calvert Cliffs
Issue date:	10/23/1997
From:	Cruse C; BALTIMORE GAS & ELECTRIC CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217K612	List: ML20217K605; ML20217K616;
References
	TAC-M97363, TAC-M97364, NUDOCS 9710280336
	Download: ML20217K605 (52)
	v • d • e

.

C4nt.i;s 11. CDtn Bcitimore Oas and Electric Company t

i Vice President Cahert Cliffn Nuclear Pow er Plant Nuclear Energy 1650 Cahert Chtfs Parkw ay Lusby, Maryland 20657 410 495 4455 October 23,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 A1TENTION:

Document Control Desk

SUBJECT:

Calven Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Revision 9 to the License Amendment Request to Convert to the improved A;)!ulcal Snecifications (TAC Nos. M97363 and M97364)

REFERENCE:

(a) 1.ctter from A. W. Dromerick (NRC) to C. II. Cruse (BGE), dated June 11, 1997 Request for Additional Information Regarding the Technical Specification Change Request to Convert to the improved Technical Specl0 cations (TAC Nos M97163 and M97364)

Reference (a) transmitted questions regarding Section 3.8 of Baltimore Gas and Electric Company's application to convert to the improved Standard Technical Specifications.

The responses for Section 3.8 are provided in Attachment i of this letter. Also attached to this letter is Revision 9 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

Significant llazards Considerations discussions are included where appropriate.

j 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 'v improved Technical Specification Section for case of replacing pages in the original amendrce request. Page replacement instructions are provided. All changes are marked with revision f dd \\

bars and are labeled Revision 9.

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 and concur that operation with the preposed revisions will not result in an undue risk to the health and 9710290336 971023

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October 23,1997 Page 2 safety of the public. Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT t

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

g4G.nA M-

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i SuMcrip' Uffd)d cnd sworn befvre me, a Notary Public in and for the State of Maryland and Coun L(LL

, this 23 day of 6d hffn J.1997.

WITNESS my lland and Notarial Scal:

blat (ALJ b- _

llLL Ltd Notary Public My Commission Expires:

9 Date CilC/ PSF /bjd Attachments: (1) Responses to Request for Additional Information (2) SummaryofChanges (3). Amendment Revision by Change (4) Amendment Revision by ITS Section

.___= -_-.

NITACilMENT f1)

IMPROVED TECilNICAL SPECIFICATIONS, REVISION 9 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION Haltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 23,1997

ATTACHMENT fU RESPONSES TO REQUEST FOR ADDITIONA INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECT'ON 3.8 3.8.1

' DOC.

JFD CHANGE / DIFFERENCE COMMENT STATUS' 1

LS Unit 1: SR 3.8.1.10 The proposed deleten of the CIS constraint The licensee should prmide an

=L q=<e to conduct this SR during shutdown does not appear to be ju=tification, or retain the CIS constraint.

acceptable. The liensee has not provided a convincing argument to da1.onstrate this SR can be conducted at rwer in a totally safe manner.

BGE Response:

DOC L.5 will be revised to betterjustify why performance of this surveillance (manual transfer from r.ormal to alternrte ofTsite power source) will not cause retuib.tions in electrical distribution system that could challenge steady state operation. The improved Standard Technical Specifications (ISTS) Bases provided this as the reason for the Note. DOD 30 will be added tojustify the deviation from NUREG-1432.

2 L2 Unit 1:

SR 3.8.1.5 The proposed deletion of the CIS The justification should be revised to include requirement to test DGs on a W test basis is w.ble.

information regarding the impact on plant safety r

However, thejustification is som-what less than adequate.

of this change and reference to any generic studies that may have been --- i- ^ " on the issue ofstaggered testing.

BGE Response:

DOC L4 will be revised to include the requested information.

3 IA2 Unit I: CTS SR 4.8.1.12d Relocation of the CTS requirement The TRM or Maintenance Rule Program are to inspect the DGs in a doru with vox!or recommend =tians ace ptale for relocation. The licensee s!muld at every refueling is acceptable. However, relocation of this revise the submittal accordingly.

reyuirement to plant procedures is not acceptable. This is an important part of maintaining EDG reliability and should be ir,u-rn.ted into a d-.crdprogram for which controls have been established.

BGE Response:

DOC LA.2 will be revised to document moving this requirement to a puy o to a process in the Maintenance Rule Program.

DOC = Discussion of Change I

JFD = JusFfication for Dewanon DOD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 3.8.1 -

' DOC JFD CHANGE / DIFFERENCE COMMENT i STATUS 4

M.1 Unit 1: Insert SR 3.8.1.1.7 The staff does not understand why The licensee should prmide a detambi the DG from the other Unit is only required to be subject to 4 discussion ofwhat is intended by this SR.

SRs. Why is the affected DG not required to undergo all SR testing?

BGE Response:

Only the four Surveillance Requirements (SRs) are reqired because more time is allowed for the opposite unit diesel su.u.hx (DG) to be ready to accept loads and automatic starting and unloading is not required.

5 Unit 2: Action A.' - Unit 2 requires performance of SR 3.8.I.1.

%1y is there a difference betwren Units I and For Unit 1, Action A requires performance of SR 3.8.1.1 g SR 27 3.8.I.2.

g BGE Response:

The dimpo wy between Unit Nos. I and 2 will be corrected.

6 L5 Unit 2: SR 3.8.1.10 The proposed deletion of the CTS constraint The licensee should prmide an adequate to conduct this SR during shutdown does not appear to be justification, or retain the CTS constraint.

acceptable. The licensee has not prmide a convincing argument to demonstrate this SR can be conducted at power in a totally safe manner.

BGE Response:

See response to RAI 3.8.1-1.

7 L4 Unit 2:

SR 3.8.1.5 The proposed deletion of the CTS The justification should be revised to include requirement to test DGs on a stassuu! test basis is acceptable.

information wpdLig the impact on plant safety llowrver, thejustification is somewhat less than =Pa of this change and reference to any generic studies that may have been cr=4eted on the issue ofstaggered testing.

Epc-Disemsnm orchange 2

Jro -Jusnrx:mmm for Devinx.

EDD = Discussion orDevision

ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION

,. IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 3.8.1 DOC

.JFD CHANGE /D&TERENCE COMMENT STATUS BGE R-g _ __.

See response to RAI 3.8.1-2.

8 LA.2 Unit 2: CTS SR 4.8.1.1.2.d.1 Relocation of the CTS requirement This is an unportant part of maintaining DG to inspect the DGs 'n accordance with vender recommendations reliabilitf and should be Lcupw&M into a at every refueling is amyt.R. However, relocation of this document / program for which controls have been requirement to plant procedures is not w i.W.

established. The TRM or Maintenam Rule e

Pic5r ii are.myi.Nc for relocata. The licensee should revise the submittal accordingly.

BGE Response:

See response to RAI 3.3.1-3.

9 M.1 Unit 2-Insert 3.8.1.17 The statTdoes not understand why the The licensee should prmide a detashi DG from the other unit is only required to be subject to 4 SRs.

discussion ofwhat is intended by this SR.

g Why is the afTected DG not requ;J to undergo all SR testing?

BGE Response:

See response to RAI 3.8.1-4.

10 JD.10 STS SR 3.8.1.10 requires verifying each DG, operating at a Prmidejustifx:stion for the STS dedation based power factors [0.9], does not trip, and vohage is maintained 5 on current licensing basis, syvem design, or

[5000] V during and following a load rejection of > [4500] kw c u.iier Iconstraints.

r and 5 [5000] kw, every 18 months. ITS 3.8.1 does not include this STS requirement. There is inadequate justifx:ation of deleting this STS requirement.

BGE P-- ;:_.

DOD 27 will be provided in place of DOD 10 tojustify this change.

1I JD.10 STS SR 3.8.i.1I requires verifying on an actual or simulated loss Providejustification for the STS deviation based DCI= Discussion orChange 3

nn-Justircmion for oeviewn 900- oncussion orDevision

ATTACHMENT (D RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3J 3.8.1 -

DOC JFD CHANGE / DIFFERENCE J)MMENT STATUS of offsite power signal: 1) De-enosuouon or mou3u y buses.

on current licensing bests, sprem design, or

2) load shedding from emergency buses. 3) DG auto-starts from epu.dios constraints.

the standby condition, loads, and maintains voltage and frequency for25 minutes. ITS 3.8.1 does not include this STS requirement.

'Ihere is inadequate justification for deleting this STS requirement.

BGE Response:

DOD 25 will provided tojustify this change.

12 JD.10 STS SR 3.8.1.14 requires verifying each DG, operating at a Providejustifx:stion for the STS devianon based power factor 5 [0.9], operates for 224 hours0.00259 days 0.0622 hours 3.703704e-4 weeks 8.5232e-5 months . ITS 3.8.1 does not on current licensing basis, system design, or include this STS requirement. There is inadequatejustification opuAM constraints.

for deleting this STS requirement.

BGE Response-Improved Standard Technical Specification SR 3.8.1.14 w' tained, and DODs 26,28, and 29 will be provided to describe the deviations from the ISTS.

13 JD.10 STS SR 3.8.1.15 requir-s 6ing each DG starts and achieves, Providejustification for the STS deviauon based in,s [10] seconds, vor.go a [3740] V and 5 [4580] V, and on current recensing basis, system design, or fiency 2 [58.8] Hz and 5 [61.2] Hz. ITS 3.8.1 does not operational constraints.

include this STS requiremerr There is inadequate justification for deleting this STS requirement.

BGE Response:

DOD 27 will be provided tojustify the deviation from the ISTS.

BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 -

Doc-Discussion ofchese 4

JFD = Justifxation for Deviation DOD = Discussum of Devistion t._._..

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION LMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 DASES DOC JFD CR8kNGE/ DIFFERENCE COMMENT STATUS 3.8.1 Bases 5

Insert B. 3.8.1 Backrround The last paragraph of the insert The licensee should provide an Comment includes RG !.9 as a reference. In the list ofreferences, this RG q v v r iote justification, or include the

1 0 9) is listed as Reference 3, but the list is so.vt. icd to indicate gpor ;.te description.

that the reference is the Draft version of RG 1.9, Rev. 3, published in April 1992. A draft of a RG is not an official NRC document and should not be used as a reference or for any other purpose. Is it the licensee's intent to reference Rev. 3 to RG 1.9 dated July 1993. Also since the licensee proposes to retain Safety Guide 9 as a reference, the licensee should prwide details of what parts of RG 1.9, Rev. 3 are applicable, what parts of Safety Guide 9 are applicable, and any conflicts between the two documents.

The deleted NUREG narrative includes a discussion of what an offsite circuit is. The proposed Background material does not include a similar discussion, but nojustification for the omission has been prm-ided.

BGE Response:

The Bases will be modified to clarify what an offsite circuit is. The Bases state that the ratings for one DG are based on Regulatory Guide 1.9 Revision 3,which will be adopted, and the others SG 9. This is correct and additional explanatxm is not r-y to explain the difference.

Bases I

Anolicable Safety Annivsis The justifk:ation provided (I) for The licensee should provide an l

Comment deletion of"or all onsite AC power" is iimy up a qvvri.te justifk:ation for this change N

2 reflects the design basis for the plant (i.e., it is not designed to be capable of safe shutdown if the DGs become inoperable).

BGE Response:

The words will be restored to the Bases.

Doc-oscussion ofchange 5

KD = JustiDcation for Deviation 900- oscussion of penanon

=. -,... -.

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 Bases 3

LCO (two niaces) In the event of a LOCA, are safety loads lhe licensee should provide a detailed Comment block loaded to offsite power? The CCNPP biyikni of the hipison of the three qualified offsite circuits

3 offsite circuits lacks the details included in the NUREG model and how they relate to each other, or provide a detailed justification on why inclusion of such In the third poi.5..yh of the LCO Bases, the term "Fi@>cy" material is in%.y.upi.te at CCNPP.

appears to be partially lined out. Is it the licensee's intention to Justification 3 does not address the issue.

delete this term? Ifso, why?

BGE Response:

A better description will be provided in the Bases, explaining that the loads are block loaded, except when the 69 kV SMECO line is used. The term Frequency was not intended to be lined out.

Bases LCO The Bases markup appears to indicate that automatic start Comment of the DGs is not required in Modes 4-6. Is this correct? If the

4 licensee is of the opinion that this is the licensing basis for the plant, the licensee shouki provide specific references and documentation, as avrupi te, that the staff has, and continues to accept this as the CCNPP design / licensing basis.

BGE Response-Automatic start is not required in Modes 5 and 6, and.pror i.te changes andjustification will be presided.

Bases 6

LCO The Bases section dealing with DGs in test mode reverting The licensee should provide an adequate Comment to running standby in the event ofa LOCA is deleted. However, justification, or retain the Bases material

5 justification (6), which is annotated adjacent to the deleted material does not address the issue.

BGE Response:

Modified NUREG words will be retained, and DOD 32 will be provided tojustify the change.

Bases 9

Insert B 3.8.1 How is the DG in LCO 3.8.1.c made available This deletion is wyi.ble on the basis 2

that this is not the CCNPP design. However, Comment when required to provide power to the CREVS, CRETS, and H Doc - D.scuss.on orchange 6

np-Josnrcanon for oe,ianon ooo-oncussion on* vias.

ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

. BASES.

DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 '

6 Analyzer 7 nothing has been provided to describe how the transfer fan one offsite circuit to another is

'Ihe licensee has opted to delete the Bases material which accomplished. The licensee should pro ide this addresses fast transfer capability in the last p r.y.ph of the information.

LCO Bases.

BGE R4x The Bases will be modified to reflect that the 3.8.1.e DG is capable of supplying the power for the opposite unit Control Room Emergency Ventilation System (CREVS), Control Room Emergency Tempo.ture System (CRETS), and H Analyzer.

2 Bases 1

Anolicability What is unique to the CCNPP design such that Comment deletion of the term " abnormal transients" is w iable?

r

7 BGE Response:

The words wil; be restored.

Bases 8

Action A.2 Does the CChTP design include any single train Comment systems that are not covered by cr are exempt fan this

8 Required Action?

BGE Response:

Yes, an example is Control Room Recirculation Signal (CRRS).

Bases 10 SurveHI=ce Ra.. ~..- x Justification 10 states that the Bases The licensee should provide a detailed Comment information cannot be verified against the CCNPP design. Does response to the staffs concern.

9 this mean that the licensee has no idea what, if any voltage drop was considered in the design of the CCNPP AC di>UTuuiive system and cannot prmide any assurance that the minimum required AC voltage to all plant equipment is available at all tunes? How does thisjustification affect the loss of voltage and degraded voltage setpoint and allowable values established in Doc = Discuss== orchange 7

JFD = Justifcation for Deviation EDD = Discussion of Deviation

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ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INTORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3J BASES DOC

.JFD LCHANGE/ DIFFERENCE COMMENT STATUS 3.8.1 -

Section 33 of the ITS?

BGE R- _ ; x.

Most of the Bases information will be retained, but the voltages will be for transient vice steady state voltages, and the.m,.i.kJ reference is removed. Reference to allowances for voltage drops to go;pocat through the 120 V level is also removed because the Calvert Cliffs voltages reference transient voltage limits. A modification installing new relays during the 19998 Calvert Cliffs outage will provide steady state voltages for inclusion in the ITS Bases DOD 10 will be modified, and this change will be included in the next resision to the Cahrrt Clifts ITS.

Bases 9

SR 3.8.13 and SR 3.8.1.9 The Bases change is not acceptable Comment because the related ITS change is not acceptable.

10 BGE R+ a See response to RAI NUREG 3.8.1-2.

Bases 20 SR 3.8.1.4 The load values stated for SR 3.8.1.4 and SR The licensee should provide an adequate Comment 3.8.1.11 are identical In the case of SR 3.3.11, the stated load justifx:ation for this proposed change.

11 values are adequate to verify DG capability of acceptmg loads equal to or rather than expected accident loads. However, these same load values, when used in SR 3.8.1.4 are not adequate to verify the exact same DG capability. The staff does not understand this proposed Bases change, andjustifx:a: ion 20 does not help.

BGE Response:

The values are only the same for No. IA DG. For the other DGs, the SR 3.8.1.1I values are greater. SR 3.8.1.4 values ensure a) for No. IA DG, the DG is capable of accepting a load girater than or equal to the predicted accident load, and b) for the remaining DGs, each DG is capable of accepting a load greater than or equal to 90% of the predicted accMmt loads for each DG. The Bases ofSR 3.8.1.4 will be modified to reflect this information and DOD 20 will be clarifwd.

Bases 9

SR 3.8.1.4 Deletion of NUREG Note 3 is not acceptable Comment because the wima!ing ITS c'sange is not Qle.

12 DOC = Discussion ofChm 8

sto-Jusur==rion for Dam:mu EDD = Discussen orDeviadom L___ _ _

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ATTACILMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

. BASES.

DOC JFD CHANGE / DIFFERENCE COMMENT STATUS

~3.8.1 BGE R :; _ _ _.

See response to RAI NUREG 3.8.1-4.

Bases 11 SR 3.8.1.4 Is the purpose of this justifx:mlkn to state that Comment CCNPP does not attempt to include a lagging power factor as

13 part of the monthly DG surveillance? Ifso, what is the rationale for not doing so?

BGER4-_

The information will be retained.

Bases 1

SR 3.8.1.4 Deletion of NUREG Note 3 is not @

Comment because the corresponding ITS change is not a@

14 BGE R--_, a See response to RAI NUREG 3.8.1-4.

Bases 9

Irgrt SR 3.8.1.8 De part of the change dealing with deleting Comment Mode restrictions is not acceptable.

IS BGE Resposse:

See response to RAI NUREG 3.8.1-7.

Bases 9,3 SR 3.8.1.10 De proposed changes to the Bases are not Comment acceptable because the wue-niing ITS changes are not

16 W de.

d BGE Response:

See response to RAI NUREG 3.8.1-9.

cac-oiscussum erchange 9

no-Joseir== ion for Devise 6c=

o00-Inscussen eroevission

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL II%TORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 BASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 Bases 9

Insert SR 3.8.1.11 and SR 3.8.1.12 The proposed Bases is not Comment septable because the ITS changes are not acceptable.

17 BGE Response:

See response to RAI NUREG 3.8.1.10.

Bases 1,9,3 SR 3.8.13 The proposed changes to the Bases are not acceptable Comment because the ITS changes are not augvic.

18 BGE Response:

See response to RAI NUREG 3.8.1-11.

Bases 9

NUREG SR 3.8.1.10 See comments re: deletion of this SR in Comment comments to LCO 3.8.1.

19 DGE Response:

See response to RAI NUREG 3.8.1-10.

Bases 9

NUREG SR 3.8.i_11 See comments re-deletion of this SR in Comment comments to LCO 3.8.1.

20 BGE Response:

See response to RAI NUREG 3.8.1-11.

NUREG Sb[12 See comments re-deletion of this SR in Bases 9

Comment comments to LCO 31:1.

21 Doc-oscussion orchange 10 no o sostirm ror oevision rmo-oocussion oroevinion

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFOILMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3J iBASES' DOC.

JFD CHANGE / DIFFERENCE COMMENT STATUS-3.8.1 BGE Response:

See response to RAI NUREG 3.8.1-12.

Bases 9

SR 3 R 1.14 See comments re changes to SR 3.8.1.14 (ITS) in Comment comments to LCO 3.8.1.

22 DGE Response:

See response to RAI NUREG 3.8.1-13.

Bases 9

NUREG SR 3_S.I.14 =d NUREG SR 3.8.1.15 See comments Comment re-deletion of these SRs in comments to LCO 3.8.I.

23 BGE Response:

See response to RAI NUREG 3.8.1-12 and -13.

Bases 9

SR 3.8.1_15 See comments re: changes to this SR in staff Comment comments to LCO 3.8.1.

24 BGE R-4 _ _ _.

See response to RAI NUREG 3.8.1-14.

Bases 9,1, NUREG SR 3.3.1.17 See comments re: deletion of this SR in Comment 3

staffcomments to ILO 3.8.1.

- <.5 BGE Response:

See response to RAI NUREG 3.8.1-15.

Bases 4.1, SR 3_8.1.16 See comment re changes to this SR in staff EDc-oscussxe of ch-ge 11 fro-sustirx:mion roe Devinke con-oscussion oroe,imion

ATTACIIMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 BASES DOC

.JFD CHANGE / DIFFERENCE

' COMMENT STATUS 3.5.1 Comment 3

comments to LCO 3.8.1.

26 BGE R-, n.

See response to RAI NUREG 3.8.1-16.

Bases 9

Insert SR 3.8.1.17 See comments re-this SR in staff o enments Cunment to If0 3.8.1.

27 B G E P -,__-__

See response to RAI 3.8.1-4.

Bases 9

NUREG SR 3.8.1.20 See comments re-deletion of this SR in Comment comments to LCO 3.8.1

28 BGE Response:

See response to RAI NUREG 3.8.1-17.

NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 NUREG 1

SR 3.8.13 Thejustification does not make an Au.-A case for The sentence should be retained as Comment deleting the second sentence ofNote 3 in this SR.

part of the Note.

1 BGE Response:

A sentence regarding modified start procedures in ISTS SR 3.8.1.2 Note 3 will be restored with the exception of the reference to " time" which is not part ofCurrent Licensing Basis (CLB).

Doc - Dscussson of Change 12 no-Justinesion for Devision DOD = Discussion of Deviation

v ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 o

.NUREG

= DOC

' JFD.-

CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 NUREG SR 3.8.1.3 "Ihe term "from standby condition" has been deleted The licensee should provide an Comment from the SR, but nojustification is provided.

appropriate justification, to retain the NUREG

2 wording.

BGE P-, _ _ _:

DOD 50 will be provided. Current Licensing Basis does not require the monthly test from ambient conditions, but it is performed every six months.

NUREG SR 3.8.1.4 Proposed Note 1. to this SR does not make sense.

The Note serves no purpose and Comment The licensee has chosen to use the symbol for " equal to or should be delewd. '

3 greater than " for the loading requirements of this SR. By definition,there is no " load range

BGF 2-- ; - _ _.

The ISTS Note allows the DG load to be either greater than the upper limit or less than the lower limit during momentary transients. Calvert Cliffs has kept the lower limit, and the Note is still applicable (i.e., durmg momentary transient where the load falls below the limit). However, there is no Iced range, so "loed range" will be changed to " load limit'* and maintain the Note.

NUREG 18 SR 3.8.1.4 NUREG Note 3 is proposed for deletion.

The licensee should revise the Comment Justification 18 states that CCNPP is not currently 6.:.-d submittal to retain NUREG Note 3 to this SR

4 from testing more than one DG at a time, and proposes to retain since it reflects the CCNPP current licensing their "right to do so." The staff disagrees with the licensee's basis.

position CTS SR 4.8.1.1.2.a prefaces all DG SRs by stating they will be conducted on a staggered test basis. Requiring staggered testing eliminates the possibility for simultaneous testing andjustification 18 is wTong.

BGE Nesponse:

The Note will be retained.

NUREG 1

SR 3.8.1.4 The licensee has opted to retain the CCNPP CLB 1he staff requests that the licensee Comment with regard to DG loading requiren.ents. Specifically, the prmide such insight to aid the staff in

5 bading requirements are stated in terms of" equal to or greater understanding the licensee's choice.

occ-Discussion orchange 13 nn-susur. canon for om &.

DOD - Discussson of Dmahon

ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITION.*". INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8 I

NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STA1US 3.8.1 than" a specified value. The staff does not understand why the licensee has not adopted the NUREG language utiich includes a load range, i.e., > (kw) but < (kw), and to which NUPIG Note 2 is applicable. Justification I provides no insight into why this choice was made.

BGE Response:

Enhancedjustification will be provided.

I NUREG 2

SR 3.8.1.7 De bracketed term

automatically" in t!m NUREG The licensee should revise this Comment is proposed to be deleted from the CCNPP ITS. Does this m:2n justification to address the stafTs concerns.

6 that the DGs at CCNPP does not have automatic trae:sfic A niel oil from the storage tank to the day tanks? If so, hsw is this accommodated in the accident analysis? If this is not the CCNPP design, why is the term " automatically" proposed to be deleted from the ITY' BGE Response:

The term " automatically' will be restored.

NUREG 1

Insert SR 3.8.1.8 The licensee proposes to move NUREG SR The staffwill n dierthis change Comment 3.8.1.18 to after ITS SR 3.8.1.7, and change the SR no. to following submittal of an adequate justification

7 3.8.1.8. This is acceptable. The licensee has also proposed to by the licensee.

change the frequency from 18 months to 31 days.

No justification for this change is presided but the staff has no objection and this change is also acceptable. The licensee also proposes to delete :he Note which precludes performing this SR in Modes 1-4. This latter change does not have a justification

a.4 is, therefore, not acceptable. NOTTc-TSTF-8 is acceptable.

BGE Response:

DOD 31 will be presided tojustify the change.

ryx - Docussion of change 14 fro -Jesufic=6an for ocvia6on con - Discussion orDeviation 9

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ATTACHMENT m RESPONSES TO REQUEST FOR ADDITIONAL L%TORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3J NUREG DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 NUREG 6

SR 3.8.1.9 His licensee proposes to delete the voltage Thelicensee should umi u adding Comment requirement of this SR but maintain the frequency nquirement voltage as an @w criteria to Mully

8 (60 Hz). The rationale in justification 6 essentially states that wmi thig this SR.

vohage is not part of CCNI" CTS requirements. The staff acknowledges that the CIS only addresses reaching 60 Hz in less than or equal to 10 sec, but an acceptable voltage to allow loading in the same time frame is an id. mud part of DG OPERABill1Y. Since the 184 day fast start and the allowwx:e for a modified start was added by amendment to the CChTP license, it is highly probable that the omission of voltage requirements from this SR was an mersight.

BGE Response:

He voltage requirement wiF be retained, and DOCS M.10 and L12 and DODs 33 and 34 will berv,kled tojustifythe changes.

NUREG 1,2 SR 3.8.1.10 He SR is modified to delete the terms " automatic" The licensee should prmide Comment and " manual" from the requirement to transfer from the normal adequatejustifications for the changes.

9 to the ahernate offsite circuit. However, the justifications annotated as being associated with this change do not address the change.

The licensee also proposes to change the frequency of this SR from 18 mo. to 24 mo. This proposed change is beyond the scope of the ITS.

De licensee also proposes to delete the Note which prohibits performance of this SR in Modes I and 2. However, neither justification I nor 2 provide any rationale for the proposed deletion. Therefore, this change will be considered.

BGE Response:

The term "manuar' will be retamed, per design. De CLB is 24 months for the fiojouwy. DOD 30 will be prmided for deletion of the Note.

DOC = Discussion orChange 15 fro-Juscirm for oninsion 900 -Discuss =n oroniation

ATTACILMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 NUREG DOC JFD.

CHANGE / DIFFERENCE COMMENT.

STATUS 3.8.1 NUREG 9

SR 3.8.1.11 & SR 3.8.L12 Shouki the inclusion of these SRs in Comment the ITS, to the exclusion of other SRs be found @ for

10 any reason, the 24 mo. frequency is still beyond scope.

BG E Rc.

The 24 month frequency is the current licensing basis. Improved Technical Specification (ITS) SR 3.8.1.12 will be removed. justified by DOC Li 1.

NUREG 1,2, SR 3.8.1.13 Changes to the NUREG SR (3.3.1.9) are proposed Provide =%

justifications.

Comment 6

as follows: 1) delete the Note which prohibits performing this

11 SR in Modes I and 2, 2) deletion of the Note directing the SR be conducted at a power factor of< [0.9], and deletion of the SR aur-w criteria for frequency and s% The licensee has not provided an W

justification for any of these changes.

Therefore, they will be considered not @ pending receipt of adequatejustifications. Also, the change from 18 mo.

to 24 mo. is beyond scope.

BG E R, - - - -;

DOD 32 and DOD 50 will be provided tojustify the changes. The 24 month frequency is CLB.

NUREG 1

SR 3.8.L12 (NUREG) The NUREG markup shows this SR as Comment being deleted. However, the indicated justification (I) does not

12 address this change at all Deletion of this SR will be considered not acceptable pending receipt of an adequate justification.

BGE Response:

DOD 25 will be provided tojustify the deviation.

NUREG I,2 SR 3.8.1.14 The changes associated with this SR are as follows-Comment 21 I) the Note prohibiting perfonnance of this SR in Modes I and

13 2 is deleted,2) the NUREG language in the Body of the TS is ooc-Discussaon ofChange I6 ND = Justification ror Deviation ooo - Discussion or oe,ia: ion

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 NUREG

' DOC JFD' CHANGE / DIFFERENCE COMMENT STATUS 3.8.1 o

deleted in favor of licensee proposed verbiage, and 3) the frequency is propcsed to be changed from I8 mo.to 24 mo.

De first change is not acceptable because the justifications provided (1, 2, and 21) do not address dekting the Note.

The licensee should provide an adequate Specifically, thejustifications do not esteb!ish why pe. forming justification, or retain the NUREG language.

this SR at power does not constitute a risk to plam safety.

De proposed verbiage for the actual SR is not desirable because it does n A edequately address the two parts of the NUREG SR; De NUREG language should &

i.e., verifying that automatic trips that are desired to be bypassed retained because it more accurately expresses the are in fact bypassed, AND automatic trips that are at desired to purpose of the SR.

be bypassed are iii fact not invassed.

De frequency change from 18 months to 24 months is beyond the scope of this ITS conversion.

BGE Response:

DOD 45 will be provided to justify the first change. A modified version of the NUREG words will be re%ed in response to comments on the second change.

DOD 21 will be revised and DOC M.i1 will be provided. De :hird change is not a change,24 months is CLis.

r De stafTrecommends the licensee NUREG 20 SR 3.8.1.15 De licensee has proposed to revise the language o Comment this SR. De proposed revision deletes the three part structure review the proposed changes in light of stafT

14 of the NUREG in favor of a single, continuous, multipart comments with a view towards retaining the requirement narrative. He revision also deletes part c of the NUREG format and language, as ayggni te.

NUREG SR in its entirety. Dejustification for this (11) is that the DGs at CCNPP do not return to scady to load status. The staffis concerned that the proposed revision may be misleading.

He NUREG organization for this SR is intended to convey the thought that there are 3 separate but sequential parts to this SR.

The proposed single narrative defeats that purpose. In addition, justification 1I is not clearly understood. Oace the safety bus noc-Discussion ofchange 17 JFD = Justification for Deviation EDD = Discussion of Deviation

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ATTACHMENT fl)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED tex?3NICAL SPECIFICATIONS SECTION 3.8 '

NUREGa

DOC:

JJFD CHANGE / DIFFERENCE COMMENT -

STA'IUS'

^

"=

3.8.1 -

loads are transferred to offsite power by opening the DG outpu+

breaker, what statu,is the DG in. Is it inoperable? Is the status indeterminate? Is the DG in running standby ready to accept loads?

The frequency change from 18 to 24 months is beyond scope of the ITS conversion process.

BGI Response:.

DOD 11 and DOC M.5 will be modzied to better explain the Calvert Cliffs specific sspects of the specification. The surveillance will be modified to adopt a modified NUREG format, and DOD 35 will be added to explain why it is acceptable to perform the surveillance at power. The CLB surveillance frequency is ciready 24 months.

NUREG 1

N'UREG SR 3.8.117 This SR is proposed to be deleted from Comment the CCNPP ITS. Thejustifk On pravided is 1. Does the staff a

15 understand correctly that the DGs at CCNPP do not have a test override capability and will continue to operate in Test Mode in the cuent of a DBA/ LOOP while the DG is undergoing testing?

If this is the CCNPP design, the DGs are inoperable during testing. How is this handled at CCNPP7 BGE Response:

When No. IB,2A, and 2B DGs are tested,1) if they are in local, it will not work,2) if they are at rated speed being controlled by the Control Room, it will work,

3) if they are loaded and there is a safety injection actuation signal (SIAS), loads will be started and the DG will not trip off, and 4) if the DGs are loaded, arv' +cre is a loss-of-offsite power (LOOP) ar6 a SIAS, the DG breaker will open, then close, and ' eds will be +.ad on.

The No.1 A DG has the test override feature, but *Jw test was not added when the DG was installed.

NUREG-20, SR 3.8.1.16 The licensee proposes to delete frequency and The staff recommends that the Comment 6

voltage from ' the W-cri'eria of this SR.

The licensee reconsider the proposed deletion of

16 justification (6) is that voltage and fregasy are Len.wd these +xy-c4 criteria..

every 31 days, and need not be -@ bere. 'Ihe staffdoes not agree with the licensee's justification.

The voltage and noc-Discmsion ofchange 18 JFD = Justification for Devistion EDD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

'NUREG

. DOC-

JFD, CHANGE / DIFFERENCE COMMENT STA~IUS

. 3.8.1 -

frequency acceptance criteria in this SR are not demonstrated dming the monthly test, and should be included as part of this SR.

De proposed change from 18 months to 24 months is beyond the scope of the ITS conversion process.

BGE Response:

Voltage and frequen:y will be restored to the SR, see response to NUREG RAI 8. A 24 month interval is part of the CLB.

NUREG 20 NUREG SR 3.8.1.20 De licensee proposes to delete this SR De licensee should provide a Comment from the CCNPP ITS. However, the justification (10) is not revisedjustification for the proposed deletion, or understood. He purpose of this SR is not a common mode retain the SRin the CCNPPITS.

y;7 failure or reliability issue as discussed in thejustification.

BGE Response:

DOD 27 will be provided tojustify the deviation.

NUREG 3

SR 3.8.1.17 His SR is added to address the DG required by De licensee should revise this SR Comment LCO 3.3.1.c, and requires performance of SRs 3.8.13,3.8.1.5, and justification (3) as necessary to address the

18 3.8.1.6, and 3.8.1.7. He staffdoes not understand this SR. If a staffs concerns.

DG from another unit is required to support operation of the subject unit, why should the OPERABILITY of the other unit DG not be tied to successful performance of all the applicable SRs for the DG in that unit? Why is it only required to perfonn the 4 SRs identified above?

BGE Response:

Same answer as 3.8.1 comment 4.

noc-Ducussion orchange 19 JFD = Justification for Deviation DoD = Discussion of Deviation

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ATTACHMENT m RESPONSES TO REQUEST FOR ADDITIONAL INFOILMATION IMPROVED -TECHNICAL SPECIFICATIONS SECTION 3.8 :

,CHANGF1 DIFFERENCE -

COMMENT _

L STATUS 33.8.23 L DOC '.

JK;s

1 LA.1 Unit 1:

CTS ' Action a.1 (Also. Applies to LCO 3.83)

Justifcation LA.1 should be revised accordingly.

Relocation of the CI3 requirements regarding movement of heavy loads fmm TS is acceptable. However, the justification requires ' additional work.

Specifically, endorsement of NUREG-1432 means' that movement of heavy loads will be co-A-*d in a manner that will preclude dropping of the load on irradiated fuel. The statement in justifmation LA.2 that heavy loads are not initiators of any event is not entirely true - the fuel handling accident assumes an. irradiated fuel assembly is dropped.

BGE Response:

DOC LA.1 will be revised, and move the details to the Updated'F' al Safety Analysis Report (UFSAR).

m

'2 LA.2 Unit 1:. CTS Footnote * (Also applies to LCO 3.83) The The lzensee should provide more details re-this proposal to move this footnote to the Bases is not M.

annotation.

The footnote modifies the 'IS required action and, as such, is not appropriate Bases material. "Ihe purpose of the Bases is to explain why something is in the 13,: not to - establish requirements. In this case, the Bases should explain what constitutes a safe, conservative position, but the permissive to establish a safe, conservative position prior to implementing the Required Actions must remain in TS.-

The CTS markup includes another LA.2 annotation. However, it is not clear what if any change this annotation is associated with.-

I BGE Response:

The purpose of the footnote is to ensure that the phrase "Immediately' Suspend" is not taken literally, so an operator would not stop fuel movement with a bundle hanging on the refueling machine. The footnote allows the movement to out the bundle in a storage location. This information is applicable to the Bases, since the Bases describe what "Immediately Suspend" means. The NUREG Bases already contams these words under ITS 3.8.2 Actions A.2.1 through A.4.

Der-oscussion orchange

'20 sm-sustification for oevianon DOD = Ducession orDeviation

ATTACIIMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8 3.8.2 DOC JFD CIIANGE/ DIFFERENCE COMMENT STATUS DOC LA.2 is related to the asterisk in CTS Action A.I.

3 L.3 Unit 1: CTS Action a.3 Moving this CTS requirement from the ne licensee should verify that these CTS AC sources TS to refueling TS (3.9) is acceptable, and is an requirements are reflected in Section 3.9 of the Administrative change. Ilowever, deleting the requirement in its ITS, and change thisjustification accordSgly.

entirety is not acceptable.

BGE Response:

He Action is not needed. If a power source is inoperable, and does not result in a loss of shutdown cooling. Only Core Alterations, positive reactivity changes, and movement ofirradiated fuel must stop. With these evolutions suspended, Containment operabilitv is not required. If shutdown cooling is also lost due to the loss of the AC source, ITS LCOs 3.9.4 and 3.9.5 (CTS 3.9.8.1 and CTS 3.9.8.2) will require these Actions to ensure a potential radioactivity release due to the insuflicient cooling does not occur. Herefore, the change is a less restrictive change because the requirement is being deleted.

4 L.2 Unit 1: SR 3.8.2.1 He staff does not agree with the licensee *s His item requires discussion between the stafT concept of which SRs from LCO 3.8.1 are applicable in Modes 5 and the licensee

& 6 (Shutdown). See attached chart which provides the staff position regarding SRs that are 1) applicable and must be performed,2) applicable but are not required to be performed, and 3) are not applicable.

BGE Response:

DOD 46 will be provided tojustify differences from NUREG-1432. DOD 21 will not be used. SR 3.8.2.1 will be modified to except SR 3.8.1.8, SR 3.8.1.10, SR 3.8.1.13, and SR 3.8.1.15. This is consistent with the Nuclear Regulatory Commission (NRC) position, except

a. SR 3.8.1.12 is not applicable because it has been deleted by a difTerent change.

b. He NRC position was that SR 3.8.1.14 (changed to SR 3.8.1.13 due to the deletion of SR 3.8.1.12) should be applicable. He DGs are affected by either a safety injection signal or a LOOP signal. Neither of these two signals are required to start the DGs in Modes 5 and 6 or during movement ofirradiated fuel assemblies. Therefore, it is not necessary to include this test in SR 3.8.2.1.

New DOD 46 to Section 3.8 has also been provided tojustify differences from NUREG-1432 SR 3.8.2.1.

In addition, the Note to SR 3.8.2.1 has also been modified to be consistent with the NRC position shown in the chart attached to the comment, with the following exceptions:

a. The NRC position was that SR 3.8.1.7 should not be performed. Ilowever, perfonnance of this test does not impact safety and the current NUREG requirements do not exempt this test from being performed. Herefore, this test will be performed; and D(X' = Discussion of Change 21 JFD = justification for Deviation DoD = Discussion ofIkviation

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3 ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAI, INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8--

3.8.2E I-DOC-I JFDI

' CHANGFlDIFFERENCE COMMENT iSTARJS b.- De NRC position was that SR 3.8.1.12 should be performed. - His SR has been deleted as described above and will not be performed.

5-LA.1 Unit 2: CTS Action a.l. Relocation of the CTS requirements Justificahon LA.1 should be revised accu 4..gly.

regarding movement of heavy loads from 13 is mye.,le.

Ilowever, the justification requires _ ' additional work.

Specifically,1 endorsement of NUREG-1432 means that movement of heavy loads will be conducted in a manner that will preclude dropping of the load on irradiated fuel. De

~

statement in justification LA.2 that heavy loads are not initiators of any event is not entirely true - the fuel handling accident assumes an irradiated fuel assembly is dropped.

BCE Response:

See response to 3.8.2 RAI 1.

6 LA.2 Unit 2: CTS Footnote

uc. proposal to move this footnote to De licensee should provide more details re: this the Bases is not acceptable. He footnote modife the TS annotabon.

required action and, as such, is not appropriate Bases material.

He propose of the Bases is to explain why something is in the TS, not to establish requirements. In this case, the Bases should explain what constitutes a safe, conservative position, but the permissive. to establish a safe, conservative position prior to implementing the Required Actions must remain in TS.

De CTS markup includes another LA.2 annotation. However, it is not clear what if any change this annotation is associated with.

BGE R :;1 See response to 3.8.2 RAI 2.

7 L3 Unit 2: Moving this CTS requirement from the AC sources TS He licensee should verify that these CfS to refueling TS (3.9) is ace =*= hie, and is an Administrative requirements are reflected in Section 3.9 of the DOC = D:scussion of Choge 22 JFD = Justification for Deviation DOD = Discussion of Deviation

ATIACHMENT (1)

RESPONSES TO REQUEST FOR-ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 3.8.2

DOC:

JFD '

- CHANGFlDIFFERENCEL COMMENT STATUS-

~

change However, deleting the requirement in its entirety is not ITS, and change thisjustification md Jy.

acceptable.

BGE Response:

See response to 3.8.2 RAI 3.

8 L,.2 Unit 2:. 'Ihe staff does not agree with the licensee's concept of Justification LA.1 should be revised wn=r,Iy-which SRs from LCO 3.8.1 are applicable in Modes 5 & 6 (Shutdown). See attached chart which provides the staffposition regarding SRs that are 1) applicable and must be performed,

2) applicable but are not required to be performed, and 3) are not applicable.

BGE Response:

See response to 3.8.2 RAI 4.

L OMMENT STATUS-BASES-

' DOC.

LJFD L CHANGE / DIFFERENCE ~:

C 3.8.2 Bases 1, 3, LCQ See comments re: changes to the LCO in staff Comment 4,12 comnects to LCO 3.8.1.

1 BGE Response:

A better description of the ofTsite circuits will be provided, and see responses to RAls for 3.8.1.

5 A

h PP cabihty See staff comments re: changes to r

Bases 12 Comment Applicability in comments to LCO 3.8.2.

2 BGE Response:

Imr = Discussion ofChange 23 JFD = Justification for Deviation DOD = Discussion of Deviation

ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 iBASES-

, DOC; fJFD!

/ CHANGE /DIFFERENCEi

~

COMMENT

-STATUS i3.8.2i See response to NUREG RAI 1.

Bases 12 Actions The propo.,ed change to the Bases is not Comment -

consistent with the proposed ITS.

' #3 BGE R- ;:x::

The term "in Containment" will be removed, and the Bases made consistent with the NUREG.

Bass 9,21 SR 3.8.2.1 '.See staff comments re: SR 3.8.2.1 in Comment comments to LCO 3.8.2.

4 With respect to justification 21, why is it necessary to parallel the EDGs with offsite power whenever the EDGs'are run7 BGE Response:

i.

See response to 3.8.2 RAI 4. When DG is run, vendor requires DG to be loaded for approximately one hour.

COMMENT (STATUS SNUREG-DOCT LJFD?

c CHANGE /a process in the Maintenance Rule Program

+

13.8.2.

DIFFERENCE -

NUREG 17 LCO 3.8.2 The staff does not understand justification a 7. The The licensee ~ should reconsider. deleton of L

Comment reason for stopping movement of irradiated fuel wBen there is "During movement ofirradiate fuel assemblies"

~

1 inadequate AC power sources is to preclude the occurrence of a from; the LCO Applicability as well. a fuel handling accident. It has nothing to do with equipment in justification 17.

the fuel' handling building-having erncrgency power. The concern is that the safety equipment necessary to mitigate the consequences of.a fuel 1 andling accident could be without AC power, regardless oflocatiort Doc-Discussion orChange 24 JFD = Justification for Deviation DOD = Discussion of Deviation

ATTACHMENT m RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVEB TECHNICAL SPECIFICATIONS SECTION 3.8

'NUREG DOC JFD CIIANGFla process in the Maintenance Rule Program COMMENT STATUS

.~3.8.2 DIFFERENCE BGE Response:

During movement ofirradiated fuel assemblies will be added back in. In addition, a Note will be added, needed as a result of the additional applicability. DOD 48 and DOC M.1 will be provided tojustify the changes regarding the Note.

NUREG 2

SR 3.8.2.1 The SR should be revised to reflect the Table Comment prepared by the stafT.

2 BGE Response:

See response to 3.8.2 RAI 4.

3.8.7 -

DOC JFD

' CIIANGE/ DIFFERENCE COMMENT STATUS 1

A3 Units 1 & 2. CTS action b.2 As proposed, the ITS for it.crs He licensee should revise the submidal to retain could be interpreted as follows: at time zero, an inverter fails, the CTS requirements.

and efrorts begin immediately to power the AC vital bus from the backup bus; afler 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the affected AD vital bus cannot The addition of the Note is acceptable because it be powered from the backup bus, and the applicable Condition does not alter any requirements. He Note of LCO 3.8.9 is entered; afler an additional 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the afTected serves as a reminder that loss of any inverter AC vital bus is still not energized, and a plaat shutdown is could very well mean that multiple conditions started.

are entered.

He above interpretation is not correct. For the same scenario, at the moment the inverter fails, the AC vital bus is deenerghed.

At this point in time, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months clock for the inverter is started, and entry into the applicable Condition of If0 3.8.9 commences. If the afTected AC vital bus is not energized within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (from the backup bus or the inverter) a shutdown is started.

DOC = Discussion of Change 25 JFD = Justification for Deviation EDD = Discussion of Deviation

ATTACHMENT (I)

' RESPONSES'TO REQUEST FOI! ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

.3.8.7

DOC'

JFD

- CHANGE / DIFFERENCE 1 COMMENT

. STATUS ne above possible confusion could be eliminated by retaining the CTS requirement to power the vital bus from the backup bus connected to the equipment to restore the inverter by an AND This will alert all interested parties that these Required Actions have concurrent time clocks. - It also establishes beyond question what power sources are acceptable for powering the AC vital bus.

BGE Response:

De ITS can not be misinterpreted as described in the first paragraph,'since the Note to Action A does not allow two hours prior to cascading to ITS 3.8.9.- ITS 3.8.7 Action A is entered upon failure of the inverter. The Note to Action A.1 requires the Unit to cascade to ITS 3.8.9 at the same time. Dus,ITS 3.8.7 Action A is entered, requiring the inverter to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and ITS 3.8.9 Action B is entered, requiring the AC vital bus to be restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . De FIS 3.8.7 Action A.1, Bases supports this. He Bases state that the Fote to the Action ensures that the AC vital bus is rea.3;i.at within two hours.

BASES DOC.

JJFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.7 Bases 15 Rackeroemd De proposed chance is not acceptable. To Comment be OPERABLE (and not in an Action) an inverter must be

1 connected to its respective station battery. any other inverter alignment (i.e., constant voltage transformer or battery changer) is only allowed for a limited time and only in response to the LCO condition of an inverter inoperable. De discussion regarding battery chargers belongs in the Bases section for Action A.I.

BGE Response:

Updated Final Safety Analysis Report Section 8.3.5.2 states that an inverter is normally powered from the respective JC bus. The DC bus is powered from its respective battery and/or battery charger. This is the meaning of the statement in the Bases. If the DC bus is only powered from its battery charger (i.e. the battery is inoperable), then the DC source would be inoperable and the Actions ofITS 3.8.4 would apply (restore the DC source in two hours or shutdown the unit). In Doc-Ducussion orchange 26 JrD - Justificarion for Deviation DOD = Discussion of Deviation

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ATTACHMENT (1)

, RESPONSES TO REQUEST FOR ' ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 4

COMMINT T

1STA1US tBASES3

DOC 1 11FD CHANGE / DIFFERENCE

'3.8.7 y:

s.

addition, under normal conditions, the battery charger is supplying all the loads on the DC bus, since the charger is set up to be on float charge. Therefore, the inverter is technically powered by the battery charger even when aligned to the battery. Herefore, this change to the Bases is acceptable. ' He LCO Bases will be revised to indicate this alignment as a condition ofinverter Operability.

Bases

'16 LCQ De proposed new paragraph is confusing. _ What is Comment a " twin inverter"? How many of them are there? Can one

2 inverter power two AC vital busses? De licensee should revise the submittal to more clearly describe the inverter arrangement at CCNPP.

BGE Response:

De Bases LCO and Background portions will be revised to more' clearly describe the inverter arrangement.

Bases 1

LCQ Note that the 3rd paragraph on this page ( B 3.8-71)

Comment is not consistent with proposed changes to the Background

3 section.

BGE Response:

De LCO Bases will be revised to be consistent with the Background secten.

Bases 16 Acton A.1 ' His proposed change and the associated De licensee should identify which of the Comment justification (16) are not consistent with the proposed change changes reflects the CCNPP iicensing basis and

4 and associatedjustification (15) to the Background section.

make appropriate corrections to the submittal.

BGE Response:

He proposed change to Action A.1 is describing how to re-energize the AC vital bus if the inverter is inoperable. He AC vital bus normally receives power from the inverter. With the inverter inoperable, the AC vital bus mu. be remsgized from the 120 VAC bus. De change associated with the Background change is discussing how the inverter is powered.' Both are correct, and do 4 conflict. Derefore, no changes to the submittal is required.

Bases 9

SR 3.8.7.1 See comments regarding' deletion of the Comment frequency requirement from this' SR in comments to the

5-NUREG markup for LCO 3.8.7.-

DOC = Discussion ofChange

~ ~ 27- -

JFD = Justification ror Deviation DOD = Discussion of Devistion !

v rm ATT4f:HMENT (1)

RESPONSES TO' REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 BASES'-

DOC-JFD.

CHANGF1 DIFFERENCE.

COMMENT STATUS

3.8.7 lKiE Response:

See response to 3.8.7 NUREG RAI 1.

NUREG DOC.'

.JFD

. CHANGE / DIFFERENCE -

COMMENT-STATUS

'3.8.7 NUREG 1

SR 3.5.7.1 The justification does not adequately address

'Ihe licensee should revise the justification to Comment deleting the requirement to verify correct inverter frequency.

specifically address why this deletion is

1 acceptable.

BGE Response:

DOD 47 will be provided tojustify why the inverter frequency is not verified.

3.8.8 DOC.

JFD

CHANGE / DIFFERENCE.

COMMENT STATUS.

No comments on 3.8.8.

a B'ASES DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.8.8 -

Bases 9

Aeolicability The proposed Bases change is not Comment acceptable because the associated ITS change is not acceptable.

1 BGE Response:

DCC = Discussion of Change 28 JFD = Justification for Deviation EDD = Discussion of Deviation

l ATTACIIMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.3 BASES DOC JFD CIIANGE/ DIFFERENCE COMMENT STATUS 3.8.8 See respc,ase to NUIEG 3.8.8 RAI 1.

Bases 12 Actions the proposed change may or many not be Comment acceptable. Ilowever, addressing the issue only in the Bases

2 (and not in the LCO) does not make the change acceptable. The Bases are for the purpose of explaining the TS, not for establishing requirements or limitations. If the limitation on fuel handling is indeed limited to the containment, this must be stated in the appropriate LCO Action (s). He Bases should explain why this limitation is acceptable (e.g., language from SE for Amendment 155 and 135).

BGE Response:

He term "in containment" will be retained and DOD 12 provided forjustification.

Bases 9

SR 3.8.8.1 See comment regarding deletion of the Comment frequency requirement from this SR in comments to the NUREG

3 markup for LCO 3.8.8.

BGE Response:

See response to NUREG 3.8.7 RAI 1.

NUREG DOC JFD CIIANGE/ DIFFERENCE COhmiENT STATUS 3.8.8 NUREG 17 LCO Anolicability De licensee's proposal to delete "During Comment movement of irradiated fuel assemblies" from the LCO

1 Applicability does not app ar to be acceptable. His issue is discussed at length in the staff comment regarding the Applicability of LCO 3.8.2.

DOC = Discussion ofChange 29 JFD = Justification for Deviadon DOD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 hUREG DOC JFD CIIANGE/ DIFFERENCE COMMENF STATUS 3.8.8 BGE Response:

See response to NUREG 3.8.2 RAi 1. During movement ofirradiated fuel assemblies, will be added back in. In addition, a Note will be added, needed as a result of the additional applicability. DOD 48 and DOC M.1 will be provided tojustify the changes regarding the Note.

NUREG 1,2 SR 3.8.8.1 Hejustifications do not adequately address deleting The licensee should revise the justifications to Comment the requirement to verify correct inverter frequency.

specifically address why this deletion is

2 acceptable.

BGE Response:

See response to NUREG 3.8.7 RAI 1.

3.8.9.

DOC JFD CHANGE / DIFFERENCE :

CONSfENT

' STATUS 1

A3 This addition to the TS is acceptable. Ilowever, it should be The staff has rejected ETF-16 which was noted that the concerns regarding LCO 3.03 when 2 or more intended to compliment proposed Action E.

electrical power distribution subsystems are inoperable are not Consequently, two or more inoperable electrical resolved by this change.

power distribution subsystems that do not result in a loss of function will still invoke LCO 3.03.

BGE Response:

The ITS 3.8.9 markup will be revised to remove references to ETF-16. The conditions and required actions will also he revised to be consistent with the existing conditions and required actions in CTS 3.8.2.1 and 3.8.23. Ilowever, proposed Action E, which is not in the CTS, will be retained, and DOC M.2 and DOD 37 will be added, and DOC A3 will not be used.

2 The changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution ofTSTF-115.

BGE Response:

EDC = Discussion of Change 30 JFD = Justification for IWaatkm DOD = Discussion of Devintion

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 3.8.9

. DOC' JFD CHANGE / DIFFERENCE COMMENT -

STATUS TSTF does not apply to this section, and has been removed from the submittal.

3 H e changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution ofTSTF-115.

BGE Response:

See response to 3.F " *?Al 2.

4 De changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution ofTSTF-115.

BGE Response:

See response to 3.8.9 RAI 2.

5 De changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution ofTSTF-II5.

BGE Response:

See response to 3.8.0 RAI 2.

BASES-DOC JFD-CHANGE / DIFFERENCE -

' COMMENT

. STATUS 3.8.9 -

Bases 17 Background De proposed deletion of Bases material De submittal should be revised to irelude an Comment regarding transfer from the preferred offsite source to the syrvriate discussion.

1 alternate source is understandable. Ilowever, the licensee has not proposed a substitute for Se deleted ma ~ l which addresses the CCNPP design.

EDC = Discussion ofChange 31 JFD = Justifecation for Deviation DOD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION

'l IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 1 BASES DOC.

JFD

. CIIANGE/DIITERENCE

~ COMMENT STA~IUS

'.3.8.9 BGE Response:

When the preferred offsite power source is lost to a 4.16 kV engineered safety feature (ESP) bus, the associated DG starts and supplies power to the Lus. The Bases will be revised to provide this information.

Bases 17 Backernund De proposal to delete Table 3.8.9-1 is not Comment acceptable. He licensee should provide the Table, or retain the

2 CTS listing of AC, DC, and AC vital bus subsystems in the body of LCO 3.8.9.

BGE Response:

he Table was added back to the Bases as part of Revision I to the ITS submittal.

Bases 18 Background Justification 18 is presented as a reason for ne licensee should provide a detailed Comment deleting Table B 3.8.9-!. The discussion includes a statement discussion of the CCNPP shared sptems and DC

3 regarding shared systems and shared DC sources. LCO 3.8.1 in sources along with the proper justification for the ITS is the only place that " shared systems" are identified, why this is not inchxled in the ITS.

and is limited to DG support from the other unit for Control Room Ventilation and H monitoring. Nothing is said about 2

opposite unit support for AC vital bus and DC electrical power subsyste'-o. If the shared systems and shared DC sources are so complex as to make creating Table B 3.8.9-1 complicated to tim point of being impractical, why is none of this system and DC source interdependency not included in the ITS7 BGE Response:

De Table was added back to the Bases as part of Revision I to the ITS submittal.

Bases 17 LCQ The substitution of FSAR Fig. 8-9 for Table B He licensee should explain why this lack of Comment 3.8.9-1 is not acceptable as discussed above. Also, the proposed consistency in language is acceptable, or revise

4 language in the LCO is not consistent. In the Background the submittal to have consistent language.

section, the licensee uses systems, subsystems, and channels. In

, the LCO section of the Bases, the terminology ' load groups" is EDC = Discussion of Change 32 JFD = Justification for Deviaria BDD = Discussion of Deviation

~

. ~ -.... - -

.=.,

4_

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION

- IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 BASESJ DOC;

JFD -

CHANGE / DIFFERENCE "

COMMENT

~

STATUS m

3.8.9 ~

used.

BGE Response:.

The Table was a&ied back to the B---- ~ nart of Revision I to the ITS submittal. De reference to the UFSAR figure will 6 r. moved and consistent terminology added to the Bases.

Bases 1,3 LCQ - His portion of the LCO Bases reverts to Comment subsystems and channels as opposed to load groups.- This is the

5 same consistency question as addres ed above.

g BGE Response:

See response to 3.8.9 Bases RAI 4.

Bases Action A 1 He changes associated with TSTF-16 are not Comment acceptable because TSTF-16 has been rejected.

6 BGE Response:

See response to 3.8.9 RAI 1.

Bases Action B.1 De changes associated with TSTF-16 are not Comment acceptable because TSTF-16 has been rejected.

7 The Bases markup for this Action is confusing and appears to be inconsistent with LCO 3.8.7. LCO 3.8.7 allows an AC vital bus to be powered from a constant voltage AC source for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , whereas this Bases section requires the bus to be powered from an inverter within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Which LCO is correct?

BGE Response:

See response to 3.8.9 RAI 1. Also, the Bases of 3.8.9 Action B.1 will be revised to state that the vital bus must be rewfixd from the inverter or the 120 VAC ooc-Discussion ofChange 33 JrD-Justincmion for oevision EDD = Discussion of Devimion

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFIC /

JNS SECTION 3.8 BASES <

DOC:

JFD -

CHANGE / DIFFERENCE COMMENT STATUS 3.8.9 bus powered by an ESF Motor Control Center (MCC) through a regulating transfonner. This is consistent with LCO 3.8.7 Bases.

Bases Action C 1 The changes associated with TSTF-16 are not Comment acceptable because TSTT-16 has been rejected.

8 BGE Response:

Sec response to 3.8.9 RAI 1.

Bases The changes associated with TSTT-16 are not acceptable Comment because TSTT-16 has been rejected.

9 BGE Response:

See response to 3.8.9 RAI 1.

Bases 18 Table 3.8.9-1 See previous comments regarding deletion Comment ofTable B 3.8.9-1 andjustification 18.

10 BGE Response:

See response to 3.8.9 RAI 1.

NUREG

' DOC;

'JFD CHANGE / DIFFERENCE

. COMMENT STATUS _

3.8.9 NUREG Insert Action E A3 This addition to the TS is acceptable.

Comment However, it should be noted that the concerns regarding LCO 3.03 when 2 or more electrical power distribution subsystems are inoperable are not resolved by this change. The staff has rejected TSTF-16 which was intended to compliment proposed EDC = Discussion of Change 34 JFD = Justifs for Devintion EDD = Discussion of Deviation

ATTACHMENT (1)

, RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

' NUREG DOC

JFD CHANGE / DIFFERENCE COMMENT STA'IUS 43.8.91 Action E. Consequently,2 or more inoperable electncal power distribution subsystems that do not result in a loss of function will still invoke LCO 3.03.'

BGE Response:

See response to 3.8.9 RAI 1.

NUREG Pg 3/4 8-13 'lhe changes associated with the DC electrical Comment power distribution subsystems have not been reviewed pending

2 resolution ofTSTF-115.

BGE Response:

TSTF-115 does not apply to this section and TSTF-115 has been removed from the submittal.

NUREG Pg 3/4 8-14 ' 'lhe changes associated with the DC ciectrical Comment power distribution subsystems have not been reviewed pending

3 resolution ofTSTF-115.

BGE Response:

See response to 3.8.9 NUREG RAI 2.

NUREG Pg 3/4 8-15 'lhe changes associated with the DC electrical Comment power distribution subsystems have not been reviewed pending

4 resolution ofTSTF-115.

BGE Response:

1 See response to 3.8.9 NUREG RAI 2.

NUREG Pg 3/4 8-16 The changes associated with the DC electncal Comment power distribution subsyms have not been reviewed pending

5 resolution ofTSTF-115.

DOC = Discussion ofChange 35 JFD = Justnication for Devistion DOD = Discussion of Deviation

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECT. ION 3.8

-NUREG LDOCL JFD-

, CHANGE / DIFFERENCE -

COMME!ff

' STATUS;

.3.8.9 BGE Response:

See response to 3.8.9 NUREG RAI 2.

NUREG Canditinn A Canditinn B. and Cnaditinn C The changes Comment associated with TSTF-16 are not acceptable because TSTF-16

6 l

has been rejected.

BGE Response:

See response to 8.9 RAI 1.

NUREG 2

Condition B The stafTdoes not understand the proposed change.

Comment What is the difference between an "AC vital bus" and an "AC

7 vital bus subsystem"? Justification (2) does not provide any details that are directly apMicable to this change and does not address the stafTs question.

BGE Response:

Condition B was revised to be consistent with terminology in Required Action B.I. There is no intent to change any technical requirements.

73.8.10 -

DOC TJFD.

' CHANGE / DIFFERENCE COMMENT STA~IUS I

IA.1 Units 1 & 2: LCO 3.8.10 DOC LA.I is not ar-va.k The The DOC is not correct, is not M and CTS requirements for offsite power and DG backup are not the changes asWae-I with DOC IA.1 are not reflected in the Bases as stated in this DOC.

acceptable.. A substantial revision of the submittalin this area is required.

BGE Response:

DOC LA.1 will not be used, and DOC A.5 will providejustification for deleting the requirement that the bus be m.6,xd from an offsite per source, but aligned to an Operable DG. The restriction is not needed since CTS 3.8.1.2 (ITS 3.8.2) references that the offsite power source provide power to the AC buses. Ifit is not EDC = Discussion of Change 36 JFD = Justification for Deviation EDD = Discussion of Deviation l

l l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.. = _. _ _ _ _ _ _ _ _ _

ATTACdMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

. m w,.

' ".19

} J 'E j 6 CHANGF1 DIFFERENCE COMMENT STATUS' ite source is inoperable and the CTS 3.8.1.2 actions are basically the same as the actions of CI:s 3.8.2.2. Also, the requirement that mpplyby,m ar th.w dn r

s (4 has me vn ;;vxi te a < erable DG is also covered by ITS 3.8.2, which requires a DC bus to be capable of supplying one train of the AC electrical power d %d+ r enthiw listed in CIS 3.8.2.2 comprise one train). Therefore, the duplicative requirements in CIS 3.8.2.2 are not rwy and have been W.i.

.. - -g. -.

a e2 Units 1 & 2: LCO 3.8.10 DOC LA.2 is not acceptable. The De DOC is not correct, is therefore not 3

{

CIS requirements regarding 4160 VAC and 480 VAC busses, acceptable, and the changes associated with l

)

wi 120 VAC vital busses are not included in the Bases as DOC LA.2 are not acceptable. A revision to the j

f indicated by this LCO.

submittalis required.

BGL'emn e aack to the Bases ofITS 3.8.9 as part of Revision I to the ITS submittal. The revision also added a reference to the Table in Bases 3.8.9 The Taw ni w Backgrouna.

c omi Technical Specification 3.8.10 Bases Background references the ITS Bases 3.8.9 Background as the location to find a description of the eixtrical pover disvitution subsystems. Therefore, no further revision is necessary.

3 LA.3 l Units 1 & 2:

CTS Action a.1 Footnote

to this CIS ne Footnote is a modification (a permissive) to requirement should be retained in the TS. The Bases is not the the CIS completion time of"Immediately" and appropriate place for this material. The Bases are intended to should be retained in the TS.

explain what is in TS, not to establish or modify requirements.

BGE Response:

See response to ITS 3.8.2 RAI 2.

4 LA.4 Units 1 & 2: CTS Action a.1 Relocation of the CIS DOC LA.4 should be revised accordingly (see requirements regarding movement of heavy loads from TS is Section 5 ofNUREG-1432).

acceptable. However, thejustification requires additional work.

Specifically, endorsement of NUREG-1432 means that movement of heavy loads will be conducted in a manner that will preclude dropping of the load on irradiated fuel The statement injustification LA 4 that heavy loads are not initiators of an event is not entirely true - the fuel handling accident l

assumes an irradiated fuel assembly is dropped.

DOC = Discussion of Change 37 ND = fustification for Deviation DOD = Discussion of Deviation

ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

! 3'.8.16 DOC

~ JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response:

DOC LA.4 will be modified to move the details to the UFSAR.

5 L2 Units 1 - & 2: CTS Action a3 De proposed change is These CTS requirements are included in ITS acceptable. Ilowever, thejustification appears to be needlessly Section 3.9 and need not be repeated in Sectum complicated.

3.8.

This could also be an Administrative change.

BGE Response:

See response to ITS 3.8.2 RAI 3.

6 LA.1 Units I & 2: SR 3.8.10.1 Units I & 2: LCO 3.8.10 DOC LA.1 The DOC is not correct, is not acceptable, and is not acceptable. The CIS requirements for offsite power and the changes associated with DOC LA.I are not DG backup are not reflected in the Bases as stated in this DOC.

acceptable.

A substantial revision 'of the submittal in this area is required.

BGE Response:

See response to 3.8.10 RAI 1.

7 Units 1 & 2: The changes associated with the DC electrical power distribution subsystems have not been reviewed pending resolution ofTSIT-il5.

. _ ~

BGE Response:

TSTT-Il5 does not apply to this section and has been removed from the submittal.

BASES

' DOC.

5JFD.

CHANGE / DIFFERENCE COMMENT STATUSf

3.8.10 -

Bases 9

Applicabihty The proposal to delete "during

, Comment movement of irradiated fuel assemblies" from the LCO

' Doc-Discussion of change 38 JFD = Justifh for Deviation DOD = Nscussion of Deviation

[_

ATTACHMENT (I)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8

. BASES:

7 DOC 1 JFD -

CHANGE / DIFFERENCE ?

, COMMENT

. STARIS L

= 3.8.10 r= -

1 Applicability does not appear to be @ This issue is discussed at length in - the staff-' comment regarding the Applicability of LCO 3.8.2.

BGE Response:

See response to NUREG 3.8.10 R/_I 1.

Bases 12 Actions See' comment re: justification 12 and its Comment associated change in staff comment on Actions for LCO 3.8.8

2 Bases.

BGE Response:

See response to NUREG Bases 3.8.8 RAI 2. The change to the Action Bases regarding fuel movement has been removed and DOD 12 will not be used.

NUREG1 DOC.

JFDL CHANGE / DIFFERENCE. "

COMMENT STATUS-

~

3.8.10 -

NUREG 17 LCO 3.8.10 Anolicability The licensee's proposal to delete Comment "During movement of irradiated fuel assembiks" from the LCO

1 Applicability does not appear.to be acceptable. This issue is discussed at length in the.;taff comment regarding the Applicability of LCO 3.8.2.

BGE Response:

f The phrase will be added back to the Applicability consistent with the response to 3.8.2 NUREG RAI 1.

NUREG R~= dred Action A 75 The proposed change is not acceptable Comment because CEOG-86 has not been + --; -:-i

2 i

i DOC = Discussion of Change 39 JFD o Justification for Deviation DOD = Discussion of Detintion

ATTACHMENT (1)

RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION.

IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8 NUREG DOC JFD.

CHANGE / DIFFERENCE '

COMMENT STATUS 3.8.10' BGE Response:

Proposed change associated with CEOG 86 was removed as part of Revision I to the submittal.

DGE = Discussion of Change 40 JFD = Justification for Deviation EDD = Discussion of Deviation

ATTACHMENT _{1) l IMPROVED TECHNICAL SPECIFICATIONS, REVISION 9

SUMMARY

OF CIIANGES Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant October 23,1997 l

NITAClIMENT (2)

SUMMARY

OF CIIANGES 1,

Discussion of Change L.4 to Section 3.8.1 has been revised to include a more detailed justification of why the deletion of diesel generator (DG) staggered testing is acceptable. This change was requested to be provided by the Nuclear Regulatory Commission (NRC) in their comments to Section 3.8.1 (comments 2 and 7).

2.

Discussion of Change LA.2 to Section 3.8.1 has been revised to relocate the requirement to a process in the Maintenance Rule Progn.m and include a more detailed justification of why the relocation is acceptable. This change was requested to be provided by the NRC in their comments to Section 3.8.1 (comments 3 and 8).

3.

The Unit 2 markup for Current Technical Specification (CTS) 3.8.1.1 Action A (page 1 of 12) has been revised to match the corresponding Unit 1 CTS cnarkup and improved Technical Specification (ITS) 3.8.1 ACTION A. This change was requested to be provided by the NRC in their comments to Section 3.8.1 (comment 5).

4.

Discussion of Deviation 10 to Section 3.8 has been revised and new Discussion of Deviations 25 l

and 27 have been added to include a more detailed justification of why the deletion of the

(

Surveillance Requirements (SRs) is acceptable. This change was requested to be provided by the

(

NRC in their comments to Section 3.8.1 (comments 10,11,12, and 13, NUREG comments 12 and 17, and Bases comments 20,21,23, and 28), in addition, the power factor requirement and the Note that allows momentary transients outside the load and power factor limits are added to ITS SR 3.8.1.11 from NUREG 1432 SR 3.8.1.14 to ensure the rower factor requirement is periodically verified. As such, Discussion of Change M.6 and L.8 (and associated No

)-

Significant Hazards Considerations (NSilC)) have been added and Discussion of Deviation 9 has been deleted and new Discussion of Deviations 26,28, and 29 have been added. The Bases for ITS SR 3,8.1.11 is also modified to reflect this change. Also, the Bases of ITS SR 3.8.1.11 is modified to include a discussion associated with plant commitments to monitor and trend No. l A DG performance degradation since No. l A DG is not tested at the continuous load rating. The detailed discussion on DG monitoring was added consistent with the Baltimore Gn and Electric Company commitment made to the NRC as stated in the NRC Safety Evaluation that accepted CTS Amendments 214 (Unit 1) and 191 (Unit 2).

5.

The requirement to meet the voltage and frequency requirements ofITS SR 3.8.1.9 when the modified start procedures are not used was added to Note 3 of ITS SR 3.8.1.3 and associatd Bases were modified to reflect the cha,e In addition, the Note to allow gradual loading of the DG and the Note that only one DG could be tested at a time was included in ITS SR 3.8.1.4 and the associated Bases were modified to reflect the chnge. liowever, a plant specific reason for precluding the test from being performed on more than one DG at a time was provided. These changes were made since there is no plant specific justification for not including these requirements in addition, Note 2 to ITS SR 3.8.1.4 was also revised to be consistent with the requirements of the SR. As a recult of these changes,ITS 3.8.1 Discussion of Changes A 7, M.3, and L.6 (and associated NSHC) were modified, ITS 3.8.1 Discussion of Changes M.7 and L.10 (and associated NSHC) were added, ITS 3.8.1 Discussion of Deviations 5 and 18 were deleted, ITS 3.8.1 Discussion of Deviation 36 was added, and ITS 3.8.1 Bases Discussbn of Deviation 25 was added. These changes were requested to be provided by the NRC in their comments to Section 3.8.1 (NUREG comments 1,2,3, and 4 and Bases comments 10,12,13, and 14).

t I

l

ATI'AC11 MENT m

(

SUMMARY

OF CHANGES 6.

Revised ITS SR 3.8.1.7 to include the word " automatically" when referring to testing of the DG fuel oil transfer system. The ITS SR 3.8.1.7 Bases are clari0ed to state that one, fuel oil transfer pump is tested because No. I A DG has two transfer pumps, No.1B,2A and 2B DGs have one transfer pemp each, but only one is required. Also, new Discussion of Change M.8 for ITS 3.8.1 was provided to justify this addition to CTS 4.8.1.1.2.a.3. This change was requested by the NRC in their comments to Section 3.8.1 (NUREG comment 6).

7.

In response to NRC comments on Section 3.8.1 (NUREG comment 10 and Bases comments 17 and 19), ITS SR 3.8.1.12, which requires verification that the auto-connected loads of the DGs do not exceed specific load values is removed from the Technical Specifications. As a result of the removal ofITS SR 3.8.1.12, all subsequent ITS SRs, and associated references to these SRs in the ITS, Bases, Discussion of Changes, NSHCs, and Discussion of Deviations are renumbered.

In addition, new Discussion of Change L.11 (and associated NSHC) for ITS 3.8.1 is provide to support removal ofITS SR 3.8.1.12 (CTS 4.8.11.2.d.5).

8.

In response to NRC comments on Section 3.8.1 (comments I and 6, NUREG comment 9, and Bases comment 16), the justification for removing the requirement to perform the manual transfer from the normal offsite power source to the alternate offsite power source during shutdown was revised (Discussion of Change L 5 and associated NSHC) and Discussion of Deviation 30 was added to justify the deviation from NUREG-1432. The change incorporates more details on how the test is performed and the relative risk associated with performing the test at power versus shutdown, in addition, the word " manual" was included in ITS SR 3.8.1.10 consistent with the wording in CTS 4.8.1.1.1.b.

9.

In response to NRC comments on Section 3.8.1 (NUREG comment 7 and Bases comments 15),

Discussion of Deviation 31 was added to provide more detail to justify the deletion of the Note from ITS SR 3.8.1.8 that precludes testing during operation in MODE 1,2,3, or 4.-

10.

Discussion of Deviation 32 was added in response to NRC comments on Section 3.8.1 (NUREG comment 11 and Bases comment 18) to provide more detail by which to justify the deletion of the Note from ITS SR 3.8.1.12 that precludes testing during operatien in Mode 1 or 2 and Discussion of Deviation 6 was revised to provide more detail by which to justify the deletion of the voltage and frequency acceptance criteria from ITS SR 3.8.1.12.

I 1.

In response to NRC comments or. Section 3.8.1 (NUREG comments 8 and 16 and Bases comment 26), voltage and frequency requirements are added to the ITS SR 3.8.1.9 which verifies the DG start within 10 seconds and to ITS SR 3.8.1.15 (engineered safety feature / loss-of-offsite power DG test). As a result of this change the Bases for ITS SR 3.8.1,9 is modified to include requirements to monitor DG voltage and frequency during this test to ensure DG voltage regulator and governor degradations have not occurred. This additional information in the Bases is required by the NRC to allow deviation from NUREG-1432 SR 3.8.1.7.

Discussion of Deviation 33 was added tojustify the deviation from NUREG-1432 SR 3.8.1.7. In addition, two new Discussion of Changes (M.10 and L.12) were provided to justify the addition of the DG voltage and frequency requirements in both ITS SR 3.8.1.9 and ITS SR 3.8.1.15. No Significant Hazards Considerations L.12 was added to support the addition of 3.8.1 Discussion of Change L.12. Discussion of Deviation 34 was added to provide more detail by which to 2

l

ATTACIIMFXT (2)

SUMMARY

OF CIIANGES justify the deletion of the Note from ITS SR 3.8.1.15 (engineered safety feature / loss-of offsite power test) that pre;ludes testing during operation in MODE 1,2,3, or 4. This Discussion of Deviation, as well as Discussion of Deviation 35 (described in item. 12 below), supersede Discussion of Deviation 20. Therefore, Discussion of Deviation 20 has been deleted.

12.

In response to NRC comments on Section 3.8.1 (NUREG Bases comment 11), a description of the load values to which the DGs are tested has been added to the Bases ofITS SR 3.8.1.4. In addition,ITS 3.8.1 Bases Discussion of Deviation 20 has been modified to clearly discuss why the Bases description of the load values has been changed.

13.

The Bases was revised to update the reference to Regulatory Guide 1.9 draft Revision 3 to the actual Revision 3 version. In addition, the requested information concerning the offsite circuit description was added to the Background section of the Bases. These changes were requested to be provided by the NRC in their comments to Section 3.8.1 (NUREG Bases comment 1). During the development of these requested changes, typographical errors and consistency issues in the Bases were discovered and corrected. Also, in conjunction with our response to NUREG Bases comment 6 (as described in Item 14 below), the Background section of the Bases wa* also revised to clearly state that automatic transfer capability between o;Tsite circuits does not exist; only manual transfer capability exists.

14.

In response to NRC comments on Section 3.8.1 (NUREG Bases comment 3), the Bases was revised to provide the requested information regarding the design and loading of the offsite circuits. In addition, the NUREG Bases 3.8.1 markup inadvertently lined out the first part of the word " frequency" in the fourth paragraph of the Limiting Condition for Operation (LCO) section. This has been corrected. The NRC also requested that information be provided describing how the transfer from one offsite to another offsite occurs (NUREG Bases comment 6). The LCO section of the Bases has been revised to clearly state that only manual transfer capability between offsite circuits exists, in addition, during the resolution of these questions, typographical error and consistency issues in the LCO section of the Bases was discovered and corrected.

15.

In response me to NRC comments on Section 3.8.1 (NUREG Bases comment 5), the Bases was revised to provide the requested information, related to the additional DG capabilities required to be demonstrated. However, an example different than that provided in the NUREG-1432 Bases was used, since Calvert Cliffs did not retain the Surveillance used as the example.

16.

In response to NRC comments on Section 3.8.1 (NUREG Bases comment 7), the Bases was revised to add back in the phrase "or abnormal transients," consistent with the NUREG Bases.

17.

In response to NRC comments on Section 3.8.1 (NUREG Bases comment 4), the LCO Section of the Bases that described the DG undervoltage start capability was revised to delete the phrase

"(only in MODES 1,2, and 3)."

18.

In response to NRC comments on Section 3.8.2 (comments I and 5), Discussion of Change LA.1 has been revised to provide additionaljustification regarding the relocation of the movement of heavy loads requirements.

3

NITACIiM1:NT (3)

SUMMARY

OF CIIANGES 19.

In response to NRC comments on Section 3.8.2 (NUREG comment 1, liases comment 2), the LCO Applicability and associated liases have been revised, consisten; with NUREG 1432, to include "during movement of irradiated fuel assemblies." As a result of this change, a new Discussion of Change A.4 was added to Section 3.8.2 and appropriate CTS markup changes were m de, in addition, the Note and associated llases proposed by TSTF 36 was added since it is now necesary with the additbn of the new Applicability. Discussion of Deviation 48 was added to justify the addition of this Note. Also, new Discussion of Change M 1 was added to Section 3.8.2 and appropriate CTS' markup changes were made due to the addition of the Note.

20.

In response to NRC comments on Section 3.8.2 (llases ccmment 3), the change to the LCO and ACTIONS liases regarding fuel movement (the addition of the phrase "in containment") has been remove (.

21.

In response to NRC comments on Section 3.8.7 (NUREG comment I and flases comment $) and Section 3.8.8 (NUREG comment 2 and llases comment 3), a new Discussion of Deviation 47 for

'lon 3.8 has 'xen provided to justify the deletion of the bracketed word " frequency" in 4

S.7.1 and SR 3.8.8.1.

22.

In spon;e to NRC comments on Section 3.8.7 (llases comments 1, 2, and 3), the llases llackground and LCO sections have been revised to be consistent with one another with respact to power supplies to the inverters, to better describe the design of the inverters, and to clarify the alignment of the inverters to the AC bus with respect to Operability. In addition, Discussion of Deviations 15 and 16 for liases Section 3.8 were revised to better describe the changes and to reference the applicable Updated Final Safety Analysis Report (UFSAR) sections, in additior., a typographical ciror in the typed ITS Ilases (LCO section) has also been corrected.

23.

In response to NRC comments on Section 3.8.8 (NUR2G comment I and llases comment 1), the LCO Applicability and associated !!ases have been revised, consistent with NUREG 1432, to include "during movement ofirradiated fuel assemblies." As a result of this change, Discussion of Change M 1 for ITS 3.8.8 was revised and appropriate CTS Mnup changes were made, in addition, the Note and associnted lims proposed by TSTF40 was added since it is now necessary with the addition of the new Applicability. Discussion of Deviation 46, added as part ofitem 26 above, was used tojustify the addition of this Note.

24.

In response to NRC comments on Section 3.8.9 (comment 1, NUREG comments I,6, and 7, and llases Comment 6,7,8,9), references to TSTF 16 have been removed. The ACTIONS have been revised to be consistent with current licensie basis, which allows one or more AC buses to be inoperable for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , one or more vital buses to be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and one DC bus to be inoperable for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Condition Il has also been revised to be consistent with the associated Required Action, in addition, while ACTION E is not currently required by the Calvert Cliffs Technical Speelnentions, and TSTF 16 was attempting to correct problems with the addition of ACTION E to the NUREG (which was added as part of Rev!sion 1), ACTION E will be retained in the Calvert Clifts ITS. This will ensure proper actions are taken if a loss of safety function occurs. Discussion of Deviation 37 for Section 3.8 has been added to describe these changes. Discussion of Change A.3 for ITS 3.8.9, which justified the addition of ACTION E to the CTS, has been deleted and replaced with Discussion. ei Change M.3.

4

ATIACIlhfrNT (2)

SUMh1ARY OF CilANGL3 Appropriate llases changes have also been made, including ensuring the Bases description in ACTION 11.1 of how to power AC vital buses is consistent with LCO 3.8.7 Bases.

25.

In response to NRC comments on Section 3.R.9 (NUREO 11asts Comme't 1), the Bases Background section has been revised to diwuss the loss of preferred power ar.d subsequent transfus.

26.

In response to NRC comments on Section 3.8.9 (NUREO liases Comment 4 and 5), the Bases LCO section has been revised to delete references to the UFSAk.lgure added in Revision I to the submittal. The flases have also been revised to use consistent Mrminology across Bases sections regarding electrical power distribution subsystems.

27.

In response to NRC comments on Section 3.8.10 (comments 1 and 6), Discussion of Change LA.1 for ITS 3.8.10 has been deleted and replaced with new Discussion of Change A.5 tojustify the changes to the AC source alignment requirements.

28.

In response to NRC comments on Section 3.8.10 (comment 4), Discussion of Change LA.4 for ITS 3.8.10 has been revised to provide additional justification regarding movement of hes.vy loads.

29.

In response to NAC comments on Section 3.8.10 (NUREG comment I and Bases comment 1),

the LCO Applicability and associated Bases have been revised, consistent with NUREG 1432, to include "during movement of irradiated fuel assemblies." As a result of this changc, new Discussion of Change A.6 for ITS 3.8.10 was added and Discussion of Deviation 17 for Section 3.8 was deleted. Appropriate CTS Markup changes were also made, in addition, the Note and associated Bases proposed by TSTF-36 was added since it is now necessary with the addition of the new Applicability. Discussion of Deviation 48, added as p17t ofitem 26 above, was used tojustify the addition of this Note. Also, new Discussion of Change M.1 was added to Section 3.8.10 and appropriate CTS Markup changes were :nade.

30.

In response to NRC comments on Section 3.8.10 (Bases comment 2), the change to the actions Dases regarding fuel movement has been removed and Discussion of Deviation 12 for Bases Section 3.8 was debd.

31.

While reviewing LA DOCS to ensure they were properly incorporated in the Bases, it was discovered that while Discussion of Changes LA.1, LA.3, and LA. 5 for ITS 3.8.1 described that certain information was relocated to the Bases, it was not properly incorpornld into the Bases.

Therefore, the Bases have been revised to include the relocated information.

32.

Discussion of Change LA.4 for ITS 3.8.1 states that CTS 4.8.1.1.2.a.6 will be relocated to the Bases. Upon further review, this requirement will not be relocated to the Bases but will be deleted from the ITS. New Discussion of Change L 9 for ITS 3.8.1 has been provided to justify the deletion and Discussion of Change LA.4 has been deleted.

33.

While reviewing the Discussion of Changes to ensure they were properly incorporated in the Bases, it was discovered that while Discussion of Change LA.1 for ITS 3.8.9 described that certain infonnation was relocated to the Bases, a portion of the relocated information was not 5

MTACHMENT (2) -

SUMMARY

OF CHANGES properly incorporated into the Bases. In lieu of incorporating this infomiation into the flases. a new less restrictive Discussion of Change (DOC L.1 for ITS 3.8.9) and associated NSilC has been provided tojustify deleting the requirement that the AC buses be energized from sources of power other than the dos (i.e, the offsite circuits). His requirement has been deleted since it la not required by NUREO 1432 (Standard Technical Specification 3.8.9 allows the AC buses to be energized from the offsite sources or the dos). In addition, the Unit 2 CTS markup related to this change did not identify that Discussion of Change LA.1 was the reason for the change. This has also been corrected.

34.

The justification for adding the Note to the Actions ofITS 3.8.5 w:is changed from TSTF 36 to Discussion of Deviation 48. Discussion of Deviation 48 was added as part ofitem 26 above.

Also, thejustification for adding the Bases for the Note ofITS 3.8.5 was changed from TSTF.36 to 11ases Discussion of Deviation 9.

35.

When resolving NRC comments concerning the AC sources LCO, it was noted that ITS 3.8.1 did not include requirements for the other unit's offsite circuit, nor did the Actions for the other unit's DO (the requirements for the other unit's DO was included in the original submittal) include all the necessary requirements. Therefore, changes have been made to ITS 3.8.1 and associated CTS and NUREO Markups to resolve these discrepancies. To support these changes, riew Discussion of Changes A.9 and L.13 and associated NSilC for ITS 3.8.1 have been added.

Discussion of Change M.I for ITS 3.8.1 and Discussion of Deviation 3 for Section 3.8 has also been revised. In addition, ITS 3.8.2 and associated CTS and NUREO Mr.kups have also been revised to include the necessary AC sources requirements. To support thes: changes, new Discussion of Change A.5 and M.2 for ITS 3.8.2 have been added. Discussion of Deviation 3 for Section 3.8 has also been revised to discuss these additions.

6

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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 5 December 2003 27 March 1997 Results Approval Other: ML20140H545, ML20141B944, ML20198K326, ML20198R718, ML20210K953, ML20210M679, ML20217G338, ML20217G370, ML20217K605
MONTHYEAR1997-06-11 [Table View]

ML20217K605

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