ML13030A133

License Amendment Request Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

ML13030A133
Person / Time
Site:	Calvert Cliffs
Issue date:	01/28/2013
From:	Flaherty M Constellation Energy Nuclear Group, Calvert Cliffs, EDF Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13030A133 (38)

Text

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 CENG.

a joint venture of Enegi o, DF CALVERT CUFFS NUCLEAR POWER PLANT January 28, 2013 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 License Amendment Request re: Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

REFERENCE:

(a) Technical Specification Task Force (TSTF)-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," June 20, 2005, ML051860296 The Calvert Cliffs Nuclear Power Plant, LLC hereby requests an Amendment to its Renewed Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos. 1 and 2, respectively, with the submittal of these proposed changes to the Technical Specifications.

This license amendment request proposes to revise several Calvert Cliffs Technical Specifications to eliminate the second completion time. The proposed changes are consistent with Reference (a).

Attachment (1) contains the evaluation of the proposed changes and Attachment (2) has the marked up Technical Specification pages. Attachment (3) contains the marked up Technical Specification Bases pages for your information.

Approval of the proposed amendment is requested by December 1, 2013 with the amendment being implemented within 90 days of issuance.

There are no regulatory commitments identified in this letter.

A~oKl N~ZA

Document Control Desk January 28, 2013 Page 2 Should you have questions regarding this matter, please contact Mr. Douglas E. Lauver at (410) 495-5219.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 28, 2013.

Very truly yours, Mark D. Flaherty Plant General Manager MDF/PSF/bjd Attachments: (1) Evaluation of the Proposed Change (2) Marked Up Technical Specification Pages (3) Marked Up Technical Specification Bases Pages cc: N. S. Morgan, NRC Resident Inspector, NRC W. M. Dean, NRC S. Gray, DNR

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusions

6.0 REFERENCES

Calvert Cliffs Nuclear Power Plant, LLC January 28, 2013

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION The proposed change would revise the Renewed Operating Licenses to remove second Completion Times from several Technical Specification (TS) Required Actions. The proposed changes are consistent with Reference 1, which was approved by the Nuclear Regulatory Commission (NRC) in Reference 2.

In Reference 1, the Technical Specification Task Force submitted Revision 2 of TSTF-439 proposing a new TS convention to limit the maximum time allowed for any combination of Limiting Condition for Operation (LCO) Conditions that could result in a single continuous failure to meet the LCO. The NRC approved TSTF-439, Revision 2 in Reference 2.

The NRC staff concluded that the TS controls, coupled with the licensee's configuration risk management program provides adequate assurance against inappropriate use of combinations of Conditions that result in a single continuous occurrence of failing to meet the LCO. Based on the discussion below, the concern regarding multiple continuous entries into Conditions without meeting the LCO is addressed by the system unavailability monitoring programs described below and the administrative controls required by Section 1.3 of the TS. Therefore, this potential concern is no longer an issue and the TSs can be simplified by eliminating the second Completion Times with no detriment to plant safety.

2.0 DETAILED DESCRIPTION Calvert Cliffs Nuclear Power Plant is proposing a revision to modify TS Example 1.3-3 to remove second Completion Times, and removes second Completion Times from several TS Required Actions. To that end, the following TS changes are proposed. The marked up TS pages are provided in Attachment (2).

TS 1.3, Completion Times - Revise Example 1.3-3 to eliminate the second Completion Time and add a discussion of administrative limits to combinations of Conditions.

TS 3.6.6 Required Actions A and C, Containment Spray and Cooling System - Removes the second Completion Time from Conditions A. 1 and C.l.

• TS 3.7.3 Required Actions A, B, and D, Auxiliary Feedwater (AFW) System - Removes the second Completion Time from Conditions A.2, B.2, and D. 1.

• TS 3.8.1 Required Actions A and B, AC Sources - Operating - Removes the second Completion Time from Conditions A.3 and B.5.

TS 3.8.9 Required Actions A, B and C, Distribution Systems - Operating - Removes the second Completion Time from Conditions A. 1, B. I and C. I The TS Bases are also revised to reflect these changes. The marked up TS Bases are provided in Attachment (3) for information only.

3.0 TECHNICAL EVALUATION

A second Completion Time was included in the Improved Standard Technical Specifications for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the Limiting Condition for Operation (LCO). The intent of the second Completion Time was to preclude entry into and out of the Required Actions for an indefinite period of time without meeting the LCO. The second Completion Time provides a limit on the amount of time an LCO would not be met for various combinations of Conditions.

The adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately I

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which could prevent this misuse of the TSs. However, that is no longer the case.

There are now two programs which provide a strong disincentive to continued operation with multiple inoperabilities of the type the second Completion Times were designed to prevent.

Title 10 CFR 50.65 (a)(1), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," requires each licensee to monitor the performance or condition of systems, structures, and components (SSCs) against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken. The NRC Resident Inspectors monitor our Corrective Action process and could take action if our maintenance program allowed the systems required by a single LCO to become inoperable multiple times. The performance and condition monitoring activities required by 10 CFR 50.65 (a)(1) and (a)(2) would identify if poor maintenance practices resulted in multiple entries into the Required Actions of the TSs and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions, is evaluated at least every refueling cycle, not to exceed 24 months, per 10 CFR 50.65 (a)(3).

Under the TSs, the Completion Time for one system is not affected by other inoperable equipment. The second Completion Times were an attempt to influence the Completion Time for one system based on the condition of another system, if the two systems were required by the same TS. However 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as this rule considers all inoperable risk-significant equipment, not just the one or two systems governed by the same TS.

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable. This comprehensive program provides much greater assurance of safe plant operation than the second Completion Times in the TSs.

Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline,"

describes the tracking and reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NEI document is endorsed by Regulatory Issue Summary 2001-11, "Voluntary Submission of Performance Indicator Data." Nuclear Energy Institute 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. Nuclear Energy Institute 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System TSs), and the AFW system.

Extended unavailability of these systems due to multiple entries into the Required Actions would affect the NRC's evaluation of the licensee's performance under the ROP.

Discussion of the specific changes is provided below.

• TS 1.3, Completion Times - Revise Example 1.3-3 to eliminate the second Completion Time and add a discussion of administrative limits to combinations of Conditions.

2

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE In addition to the programs described above, a requirement is added to Section 1.3 of the TSs that requires administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This TS requirement, when considered with the regulatory processes discussed above, provides an equivalent or superior level of plant safety without the unnecessary complication of the TSs by second Completion Times on some TSs. A revision to TS Example 1.3-3 is proposed to remove the second Completion Time for Required Actions A.1 and B.1 and replace the discussion in the example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis of the Completion Times and is inappropriate.

Therefore, administrative controls are appropriate to ensure that the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO is not inappropriately extended.

TS 3.6.6 Required Actions A and C, Containment Spray and Cooling System - Removes the second Completion Time from Conditions A. 1 and C. 1.

Technical Specification 3.6.6, has a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time for one containment spray train inoperable (Condition A) and a 7 day Completion Time for one containment cooling train inoperable (Condition C).

Conditions A and C have a second Completion Time of 10 days from discovery of failure to meet the LCO. Condition F also states that if two containment spray trains are inoperable or any combination of three or more trains is inoperable, LCO 3.0.3 must be entered immediately. The second Completion Time is not needed. Adverse combinations require entry into LCO 3.0.3. The second Completion Time restricts operation with only one train inoperable, but that is unnecessary because when one train is inoperable, there are still three operable trains and only two trains are needed to perform the safety function. Therefore, the second Completion Time is overly restrictive.

• TS 3.7.3 Required Actions A, B, and D, Auxiliary Feedwater (AFW) System - Removes the second Completion Time from Conditions A.2, B.2, and D. 1.

Technical Specification 3.7.3, AFW System, has a 7 day Completion Time for one inoperable steam driven AFW pump (Condition A), a 7 day Completion Time for one inoperable motor driven AFW pump (Condition B) and a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time for one AFW train inoperable (Condition D). Conditions A, B, and D have a second Completion Time of 10 days from discovery of failure to meet the LCO. In order for the second Completion Time to be limiting, entry into and out of Conditions A, B, and D must occur, which requires the turbine driven or motor driven AFW pumps to be inoperable concurrently with an AFW train. However, Condition E states that if the Required Actions and associated Completion Times of Condition A, B, and D are not met the plant must be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The second Completion Time is not needed. For the second Completion Time to be limiting, Conditions A, B, and D must be entered concurrently. However, Condition E requires an immediate shutdown when one train or one pump are inoperable for longer than the allowed time. Therefore, the second Completion Time is not limiting and can be removed. In addition, the Reactor Oversight Process monitors the availability of the AFW system. Such frequent, repeated failures of the AFW system would be reported to the NRC and this represents a strong disincentive to such operation.

3

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE

• TS 3.8.1 Required Actions A and B, AC Sources - Operating - Removes the second Completion Time from Conditions A.3 and B.5.

Specification 3.8.1, AC Sources - Operating, has a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time for one offsite circuit inoperable (Condition A) and a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time for one diesel generator inoperable (Condition B). Both Condition A and Condition B have a second Completion Time of "17 days from discovery of failure to meet LCO 3.8.1.a or LCO 3.8.l.b." The second Completion Time limits plant operation when Condition A or B is entered, and before the inoperable system is restored, the other Condition is entered, and then the first inoperable system is restored, and before the remaining inoperable system is restored, the other Condition is entered again. This highly improbable scenario is further limited by Condition H which applies when an offsite circuit and a diesel generator (DG) are inoperable.

It limits plant operation in this Condition to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As stated above, the Reactor Oversight Process monitors the availability of mitigating systems, including the emergency AC sources (DG unavailability).

Such frequent, repeated failures of the AC sources would be reported to the NRC and this represents a strong disincentive to such operation.

• TS 3.8.9 Required Actions A, B and C, Distribution Systems - Operating - Removes the second Completion Time from Conditions A. 1, B. I and C. 1 Specification 3.8.9, Distribution Systems - Operating, has an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time for one or more AC electrical power distribution subsystems inoperable (Condition A), and a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for one or more AC vital bus subsystems (Condition B) or one DC electrical power distribution subsystem (Condition C) inoperable. Conditions A, B, and C have a second Completion Time of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet the LCO. Condition E applies if two or more electrical power distribution subsystems are inoperable and, if it results in a loss of function, LCO 3.0.3 must be entered immediately.

The second Completion Time is not needed. First, it is unusual for an AC electrical power distribution subsystem or AC vital bus to be inoperable without causing a reactor trip. Secondly, Completion Times are very short (8 and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) providing little time to restore systems such that the Conditions overlap and multiple inoperabilities occur. Lastly, should any overlapping inoperabilities that result in a loss of function occur, a plant shutdown in accordance with LCO 3.0.3 is required.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements Section 182a of the Atomic Energy Act requires TSs to be included as part of the operating license.

These TSs are derived from the plant safety analyses. In 10 CFR 50.36, "Technical Specifications," the NRC established its regulatory requirements related to the content of the TSs. Title 10 CFR 50.36, states, "When a limiting condition for operation for a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted in the technical specifications until the condition can be met." The proposed change continues to meet the requirements of this regulation.

The objective of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," is to ensure that nuclear power plant structures, systems, and components will be maintained so that they will perform their intended finction when required.

The Calvert Cliffs design was reviewed for construction under the "General Design Criteria for Nuclear Power Plant Construction" issued for comment by the AEC in July 1967. This change does not impact compliance with any of the draft General Design Criteria.

4

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE 4.2 Significant Hazards Considerations This license amendment request proposes to revise several Calvert Cliffs Technical Specifications (TSs) to eliminate reference to the second Completion Time. Specifically, Completion Times Example 1.3-3 is revised to eliminate the second Completion Times and to replace the discussion regarding second Completion Times with a new discussion. The second Completion Time associated with TS 3.6.6 Required Actions A.1 and C.1, TS 3.7.3 Required Actions A.2, B.2 and D.1, TS 3.8.1 Required Actions A.3 and B.5, and TS 3.8.9 Required Actions A.1, B.1 and C.1 is proposed to be deleted. The TS Bases associated with these Required Actions are also being revised to delete the discussion of the second Completion Time. The proposed changes are consistent with TSTF-439-A, Revision 2.

Calvert Cliffs has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment" as discussed below:

1. Does the proposed amendment involve a significant increase in the probabilityor consequences of an accidentpreviously evaluated?

Response: No.

The change proposed by incorporating TSTF-439-A, Revision 2, eliminates certain Completion Times from the Technical Specifications. Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected.

The consequences of an accident during the revised Completion Times are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed change does not alter or prevent the ability of structures, systems, or components from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed change to modify certain Completion Times does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase the cumulative occupational/public radiation exposures. The proposed change is consistent with the safety analysis assumptions and resultant consequences.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated?

Response: No.

The proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed changes do not alter any assumptions made in the safety analyses.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

5

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE

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

Response: No.

The proposed change to delete the second Completions Times and the related example of second Completion Times does not alter the manner in which safety limits, limiting safety systems settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside of the design basis.

Therefore, the proposed amendment does not involve a significant reduction in the margin of safety.

Based on the above, Calvert Cliffs concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of"no significant hazards consideration" is justified.

4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Technical Specification Task Force (TSTF)-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," June 20, 2005, ML051860296

2. Letter from T. H. Boyce (NRC) to Technical Specification Task Force, dated January 11, 2006, Status of TSTF-439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" 6

ATTACHMENT (2)

MARKED UP TECHNICAL SPECIFICATION PAGES Calvert Cliffs Nuclear Power Plant, LLC January 28, 2013

Completion Times 1.3 1.3 Completion Times continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition), and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry)-ar aaa e*e dified b the phrase "from discovery . . .

CALVERT CLIFFS - UNIT 1 1.3-2 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

Completion Times 1.3 1.3 Completion Times one_ us -Gion

_ h .T .i..

The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> met.

Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

CALVERT CLIFFS - UNIT 1 1.3-3 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

Completion Times 1.3 1.3 Completion Times EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore 7 days Function X Function X train train to OPERABLE inoperable. status.

railure to meet B. One B.1 Restore 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y Function Y train train to OPERABLE (_

inoperable, status.

C. One C.1 Restore 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function X Function X train train to OPERABLE inoperable, status.

AND OR One C.2 Restore 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y Function Y train train to OPERABLE inoperable, status.

CALVERT CLIFFS - UNIT 1 1.3-6 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

Completion Times 1.3 1.3 Completion Times When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e.,

initial entry into Condition A).

eandin s1ch Ppea 1ator-manncr th.t could continu4

............. y Completiur Tea i-estoring

,,.t..ut eve;T ws-epaate sy..tems dif.-h.ed by the tometheC.

phras "from disovey o filue t elll~ tKLCQ u *,,

dei"e t......

i "ndefin-ite- conti*,nue prl,,ation-l' ,while notF meetling the1 ICO.

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CALVERT CLIFFS - UNIT 1 1.3-7 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

Insert It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those conditions are not inappropriately extended.

Containment Spray and Cooling Systems 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

MODE 3, except containment spray is not required to be OPERABLE when pressurizer pressure is < 1750 psia.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train inoperable, spray train to OPERABLE status. 4RD 1Odisys#to-fy failuwree tomeet Condi tion -for Operation B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A AND not met.

B.2 Be in MODE 3 with 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressurizer pressure

< 1750 psia.

CALVERT CLIFFS - UNIT 1 3.6.6-1 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One containment C.1 Restore containment 7 days cooling train cooling train to inoperable. OPERABLE status. ___D failure to mccte Coenditionm D. Two containment D.1 Restore one 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> cooling trains containment cooling inoperable. train to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition C AND or D not met.

E.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable.

CALVERT CLIFFS - UNIT 1 3.6.6-2 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

AFW System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Auxiliary Feedwater (AFW) System LCO 3.7.3 Two AFW trains shall be OPERABLE.

---

NOTE------------------------

AFW trains required for OPERABILITY may be taken out of service under administrative control for the performance of periodic testing.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

---

NOTE -------------------------------------

LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One steam-driven AFW A.1 Align remaining 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> pump inoperable. OPERABLE steam-driven pump to automatic initiating status.

AND A.2 Restore steam-driven 7 days pump to OPERABLE ( f status.

dseeL-viryo failure to mect Condition. for Qr,-4-,,I-CALVERT CLIFFS - UNIT 1 3.7.3-1 Amendment No. 276 CALVERT CLIFFS - UNIT 2 Amendment No. 253

AFW System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One motor-driven AFW B.1 Align standby steam- 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> pump inoperable. driven pump to automatic initiating status.

AND B.2 Restore motor-driven 7 days pump to OPERABLE status.

C. Two AFW pumps C.1 Align remaining 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. OPERABLE pump to automatic initiating status.

AND C.2 Verify the other 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> unit's motor-driven AFW pump is OPERABLE.

AND C.3 Verify, by 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> administrative means, the cross-tie valve to the opposite unit is OPERABLE.

AND CALVERT CLIFFS - UNIT 1 3.7.3-2 Amendment No. 276 CALVERT CLIFFS - UNIT 2 Amendment No. 253

AFW System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.4 Restore one AFW pump 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to OPERABLE status.

D. One AFW train D.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for OPERABLE status.

reasons other than -A*)

Condition A, B, or C.

failure- to c the LCO-E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, AND B, C, or D not met.

E.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. Two AFW trains F.1 ---------NOTE------

inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to Immediately restore one AFW train to OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.7.3-3 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

AC Sources-Operating 3.8.1 ACTIONS

---

NOTE -------------------------------

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION I COMPLETION TIME A. One required A.1 Perform SR 3.8.1.1 or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> LCO 3.8.1.a offsite SR 3.8.1.2 for circuit inoperable. required OPERABLE AND offsite circuits.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND A.2 Declare required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from feature(s) with no discovery of no offsite power offsite power to available inoperable one train when its redundant concurrent with required feature(s) inoperability of is inoperable. redundant required feature(s)

AND A.3 Restore required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> offsite circuit to OPERABLE status.

17 ayLs4fr-@;4 rikcq_-ý o

.1._____________________________________ A CALVERT CLIFFS - UNIT I 3.8.1-2 Amendment No. 276 CALVERT CLIFFS - UNIT 2 Amendment No. 253

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.4.2 Perform SR 3.8.1.3 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for OPERABLE DG(s).

AND B.5 Restore DG to 14 days OPERABLE status.

+/-7-dayxs4ý~

cH co very-,e-f-faure-tua-cý LCO 3-.8-.i-1.c r-C. Required Action and C.1.1 Restore both DGs on 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> associated Completion the other unit to Time of Required OPERABLE status and Action B.1 not met. OC DG to available status.

OR C.1.2 Restore DG to OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.8.1-4 Amendment No. 265 CALVERT CLIFFS - UNIT 2 Amendment No. 242

Distribution Systems-Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating LCO 3.8.9 The AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> electrical power power distribution distribution subsystems to ___

subsystems OPERABLE status.

inoperable. 16 hears from fimii ti lg Condition for B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> bus subsystem(s) subsystems to inoperable. OPERABLE status. AN9_

failure to- eft

,iffl.ion.g Conditien fer CALVERT CLIFFS - UNIT I 3.8.9-1 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

Distribution Systems-Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical C.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> power distribution power distribution subsystem inoperable, subsystem to OPERABLE MAQ.

status.

16 he rs-froem dis~eaveioy ef failurc to mee-t Cnitionfo D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. Two or more E.1 Enter LCO 3.0.3. Immediately electrical power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and 7 days voltage to AC, DC, and AC vital bus electrical power distribution subsystems.

CALVERT CLIFFS - UNIT 1 3.8.9-2 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201

ATTACHMENT (3)

MARKED UP TECHNICAL SPECIFICATION BASES PAGES Calvert Cliffs Nuclear Power Plant, LLC January 28, 2013

Containment Spray and Cooling Systems B 3.6.6 BASES The Containment Spray System is only required to be OPERABLE in MODE 3 with pressurizer pressure Ž 1750 psia.

In MODE 3 with pressurizer pressure < 1750 psia, and in MODEs 4, 5, and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODEs. Thus, the Containment Spray System is not required to be OPERABLE in MODE 3 with pressurizer pressure < 1750 psia, and the Containment Spray and Cooling Systems are not required to be OPERABLE in MODEs 4, 5, and 6.

ACTIONS A.1 With one containment spray train inoperable, the inoperable containment spray train must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the redundant heat removal capability afforded by the Containment Spray System, reasonable time for repairs, and the low probability of a DBA occurring during this period.

heO poda prtion ef the Completion Time.

B.1 and B.2 If the inoperable containment spray train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 3 with pressurizer pressure 1750 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Time of six hours is reasonable, based on operating experience, to reach MODE 3 from full power CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-5 Revision 2

Containment Spray and Cooling Systems B 3.6.6 BASES conditions in an orderly manner, and without challenging plant systems. The extended interval to reach MODE 3 with pressurizer pressure < 1750 psia allows additional time for the restoration of the containment spray train and is reasonable when considering that the driving force for a release of radioactive material from the RCS is reduced in MODE 3.

C.1 With one required containment cooling train inoperable, the inoperable containment cooling train must be restored to OPERABLE status within seven days. The remaining OPERABLE containment spray and cooling components provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The seven day Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray and Cooling Systems, and the low probability of a DBA occurring during this period.

LCh" poto1fteCmlto ie D.__.

With two required containment cooling trains inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The remaining OPERABLE containment spray components provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray and Cooling Systems, the iodine removal function of the Containment Spray System, and the low probability of a DBA occurring during this period.

CALVERT CLIFFS - UNITS 1 & 2 B 3.6.6-6 Revision 2

AFW System B 3.7.3 BASES standby or automatic initiating status, depending upon whether the other steam-driven AFW pump is in standby or automatic initiating status) within seven days. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and seven day Completion Times are reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA event occurring during this period. Two AFW pumps and flow aths faien to mli etthe otnb am-d rine the betoetn rtor iiitn ensus n dais Required At bAttion soyefldta tha lired eI the and team-rer utrcie propermt B.1 and B.2 With the motor-driven AFW pump inoperable, action must be taken to align the standby steam-driven pump to automatic initiating status. This Required Action ensures that another AFW pump is available to automatically start, if required. If the standby steam-driven pump is properly aligned, the inoperable motor-driven AFW pump must be restored to OPERABLE status within seven days. The 72-hour and seven day, Completion Times are reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA event occurring during this period. Two AFW pumps and one flow path remain to supply feedwater to the steam generators.

estabhli-shesa limfit on the maximum timcl allow'ied for an-y continini'sT~ LCO.

to mcct thisANDiir 2 B 3.7.3-5 Revision 26

- UNITS 1 CALVERT CLIFFS - UNITS 1 &

& 2 B 3.7.3-5 Revision 26

AFW System B 3.7.3 BASES C.1, C.2. C.3, and C.4 With two AFW pumps inoperable, action must be taken to align the remaining OPERABLE pump to automatic initiating status and to verify the other units motor-driven AFW pump is OPERABLE, along with an OPERABLE cross-tie valve, within one hour. If these Required Actions are completed within the Completion Time, one AFW pump must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Verifying the other unit's motor-driven AFW pump is OPERABLE provides an additional level of assurance that AFW will be available if needed, because the other unit's AFW can be cross-connected if necessary. The cross-tie valve to the opposite unit is administratively verified OPERABLE by confirming that SR 3.7.3.2 has been performed within the specified Frequency. These one hour Completion Times are reasonable based on the low probability of a DBA occurring during the first hour and the need for AFW during the first hour. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time to restore one AFW pump to OPERABLE status takes into account the cross-connected capability between units and the unlikelihood of an event occurring in the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period.

D.1 With one of the required AFW trains inoperable for reasons other than Condition A, B, or C (e.g., flowpath or steam supply valve), action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This Condition includes the loss of two steam supply lines to the turbine-driven AFW pumps. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA event occurring during this period. One AFW train remains to The--ten -day Comp~leet~in Tiffe prciea ritdimalod ille this LCsT i i i upd r d r a o a l o

-he~tun iLrl wITi 1 1uid LionsA wnd B drefetSfa)edf-CALVERT CLIFFS - UNITS 1 & 2 B 3.7.3-6 Revision 26

AFW System B 3.7.3 BASES eeerrnly The ANfl connecorbeen 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and ten day-s dictates that both Completiogn Timesz a pplyv se ,nd*more restritive mut -be-*et.+-

E.1 and E.2 When the Required Action and associated Completion Time of Condition A, B, C, or D cannot be met the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

F.1 Required Action F.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status.

With two AFW trains inoperable in MODEs 1, 2, and 3, the unit may be in a seriously degraded condition with only non-safety-related means forconducting a cooldown. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip.

However, a power change is not precluded if it is determined to be the most prudent action. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status. While other plant conditions may require entry into LCO 3.0.3, the ACTIONS required by LCO 3.0.3 do not have to be completed because they could force the unit into a less safe condition.

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS Verifying the correct alignment for manual, power-operated, and automatic valves in the AFW water and steam supply flow paths, provides assurance that the proper flow paths exist for AFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position CALVERT CLIFFS - UNITS 1 & 2 B 3.7.3-7 Revision 26

AC Sources-Operating B 3.8.1 BASES Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features (or both) that are associated with the other train that has offsite power. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature.

Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 Consistent with Reference 6, operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, andthe low probability of a DBA occurring during this period.

.hile, for instance', an LCO 3 DG is nzpr babl-, xnd that D ....ub returned OPERABLE, thc LC

• t .y may CALVERT CLIFFS - UNITS 1 & 2 B 3.8.1-7 Revision 26

AC Sources-Operating B 3.8.1 BASES LCO 3.8..O 3.3 , t o tte ci rcu*i At this time", a-G again become

,ould pe* on of LCs 3.8.1.a and 3.8.1.b. Th A 17day Completion Time provides a limit en the time specified condition after deisc-overyoftm LCO3..1a i CO 3..1.b. Thi limit is conrirdeied-

~&~on.&be f~ sita-tions in which Cond"itions n r e.tcrcd e a iiC eentlyI The "AMD" connlector between the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 17 day Completion Time meansrtAtiothB.5 isbased As B.__!~ frs in Required Action tn A.2, the CmpletivoenTime allow xrL f p allowed outage t4me "clou k. Th is wil resutoin on lplthe OPRBTime n of bo--simth opoite-us ni-tD esndte-tas Jsu-rnce thea bnostme-tiall t, insandthe time at elaceptonutor tlossmol-o"time zoer." fIr bseguinnin tho B.1 The 14 day Completion Time for Required Action B.5 is based on the OPERABILITY of both opposite-unit DGs and the availability of the OC DG. The OC DG is available to power the inoperable DG bus loads in the event of a station GeDisrbtionASystem.

blackout or loss-of-offsite power. It is required to administratively verify both opposite-unit DGs OPERABLE and the OC DG available within one hour and to continue this action once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter until restoration of the required DG is accomplished. This verification provides assurance that both opposite-unit DGs and the OC DG are capable of supplying the onsite Class lE AC Electrical Power Distribution System.

B.2 To ensure a highly reliable power source remains with an inoperable LCO 3.8.1.b DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform,"

a failure of SR 3.8.1.1 or SR 3.8.1.2 acceptance criteria does not result in a Required Action being not met.

CALVERT CLIFFS - UNITS 1 & 2 B 3.8. 1-8 Revision 26

AC Sources-Operating B 3.8.1 BASES

e. Elective maintenance will not be performed on the alternate AC power source (OC DG). Personnel will be made aware of the dedication of the alternate AC source to the affected Unit.

f. Planned maintenance will not be performed on the Auxiliary Feedwater System.

g. The system dispatcher (System Operations and Maintenance Department) will be contacted prior to removing the DG from service and after it has been returned to service.

h. The operations crews will be briefed concerning the Unit activities, including compensatory measures established and the importance of promptly starting and aligning the alternate AC source (OC DG).

i. The on-shift operations crew will discuss and review the appropriate normal and emergency operating procedures prior to or shortly after assuming the watch for the first. time after having scheduled days off while the extended DG Completion Time is in effect.

j. The condition of the grid will be evaluated prior to entering the extended DG 3.8.1 Condition B Completion Time for elective maintenance. An extended DG Completion Time will not be entered to perform elective maintenance when grid stress conditions are considered "High" per plant procedures. This will include conditions such as expected extreme summer temperatures and/or high demand.

~~t tL offsite circut an addiicnal 2 huur (f e- tutal of20 days) allofWed culdI r -L * * .bl t . OEBLa CALVERT CLIFFS - UNITS 1 & 2 B 3.8. 1-12 Revision 26

AC Sources-Operating B 3.8.1 BASES and B- ary cnt 17 TimeA ,e day Cuompletion. ns etha both n C.I.1 and C.1.2 In Condition C with an opposite-unit DG inoperable and/or the OC DG unavailable, the remaining OPERABLE unit-specific DG and required qualified circuits are adequate to supply electrical power to the onsite Class lE Distribution System.

Consistent with Reference 6, operation may continue in Condition C for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

D._1 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it, were inoperable resulting in de-energization. Therefore, the Required Actions of Condition D are modified by a Note to indicate that when Condition D is entered with no AC source to any train, the Conditions and Required Actions for LCO 3.8.9, must be immediately entered. This allows Condition D to provide requirements for the loss of the LCO 3.8.1.c offsite circuit and DG without regard to whether a train is de-energized. Limiting Condition for Operation 3.8.9 provides the appropriate restrictions for a de-energized train.

CALVERT CLIFFS - UNITS 1 & 2 B 3.8. 1-13 Revision 26

Distribution Systems-Operating B 3.8.9 BASES Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore, imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining train by stabilizing the unit, and on restoring power to the affected train. The eight hour time limit before requiring a unit shutdown in this condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit; and

b. The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

The storond-Gm~t OrERADL th RCeqay uiready hAe ben noA mt!o as-bince inta e lifalur An the to alG L orsr aC y becomc inoperablng andyA ditiui on rWa e GO[AL.

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Distribution Systems-Operating B 3.8.9 BASES The two hour Completion Time takes into account the importance to safety of restoring the AC vital bus to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low probability of a DBA occurring during this period.

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With one DC bus inoperable, the remaining DC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining DC electrical power distribution subsystem could result in the minimum required ESF functions not being supported.

Therefore, the DC bus must be restored to OPERABLE status within two hours by powering the bus from the associated battery or charger.

CALVERT CLIFFS - UNITS 1 & 2 B 3.8.9-6 Revision 2

Distribution Systems-Operating B 3.8.9 BASES Condition C represents one DC bus without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit,.

minimizing the potential for loss of power to the remaining trains and restoring power to the affected train.

This two hour limit is more conservative than Completion Times allowed for the vast majority of components which would be without power. Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue;

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c. The potential for an event in conjunction with a single failure of a redundant component.

The two hour Completion Time for DC buses is consistent with Reference 2.

fo*r*uition is ibutie dubsysuentlh Cflequnred returno ay alreadi--iv teLD MrRDE a1,not14been meQtfo0r_

-up to eight heurs. This eculd leud to a taoftnhrs s-i-nccinitial failure o1f the LCO, to etretcD distribution system. At th,"- ., C t-ainc ld bcm inoperable, and Be distributin etr,d O.PERABL CALVRT CIFFS- UNThs1& 2o~ B_~3.8- Revsin CALVERT CLIFFS - UNITS 1 & 2 B 3.8.9-7 Revision 2

Distribution Systems-Operating B 3.8.9 BASES D.I and 0.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within six hours and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner.

and without challenging unit systems.

E.I1 Condition E corresponds to a level of degradation in the electrical distribution system that causes a required safety function to be lost. When more than one inoperable electrical power distribution subsystem results in the loss of a required function, the plant is in a condition outside the accident analysis. Therefore, no additional time is justified for continued operation. Limiting Condition for Operation 3.0.3 must be entered immediately to commence a controlled shutdown.

SURVEILLANCE SR 3.8.9.1 REQUIREMENTS This SR verifies that the AC, DC, and AC vital bus Electrical Power Distribution Systems are functioning properly, with the correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus. The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system CALVERT CLIFFS - UNITS 1 & 2 B 3.8.9-8 Revision 2