ML20141H479

Forwards RAI Re TSs Change Request to Convert to Improved TSs for Plant,Units 1 & 2

ML20141H479
Person / Time
Site:	Calvert Cliffs
Issue date:	05/16/1997
From:	Dromerick A NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
TAC-M97363, TAC-M97364, NUDOCS 9705230315
Download: ML20141H479 (64)

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Mr. Charles H. Cruse M y 16,1997 Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway i

Lusby, MD 20657-4702

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL SPECIFICATIONS FOR THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.

i 1 AND 2 (TAC NO. M97363 AND M97364)

Dear Mr. Cruse-i On December 4,1996, Baltimore Gas and Electric Energy (BGE), submitted a license amendment request to convert the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Current Technical Specifications to the Improvad Technical Specifications (ITS). During the course of our review, we found that we require additional information to complete our evaluation.

Please respond to the enclosed request for information (RAI) that seeks to clarify the ITS Sections 2.0 Safety Limits, 3.1 Reactivity Control Systems, 3.2 Power Distribution Limits, 3.5 Emergency Core Cooling Systems, and 3.9 Refueling.

On May 15, 1997, in a telephone conference with Brian D. Mann, of BGE and NRC staff Mr. Mann said that the supplement to the Calvert Cliffs conversion amendment would be sent to the NRC on May 31, 1997. The staff anticipates that review of the supplement will assist in the Calvert Cliffs conversion to the Standard Technical Specifications. To support the NRC staff's review schedule, your written and electronic response in Wordperfect 5.1 to this RAI is requested within 15 days of the receipt of this letter. Should you have any questions, please do not hesitate to contact me at (301) 415-3473.

j Sincerely, OHginal Signed By Alexander W. Dromarick, Senior Project Manager i

Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

RAI

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May 16, 1997 Mr. Charles H. Cruse Vice President - Nuclear Energy i

Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway l

Lusby, le 20657-4702

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE TECHNICAL i

SPECIFICATIONS CHANGE REQUEST TO CONVERT TO THE IMPROVED TECHNICAL l

SPECIFICATIONS FOR THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.

1 AND 2 (TAC NO. M97363 AND M97364) h

Dear Mr. Cruse:

On December 4,1996, Baltimore Gas and Electric Energy (BGE), submitted a license amendment request to convert the Calvert Cliffs Nuclear Power Plant, i

Units 1 and 2 Current Technical Specifications to the Improved Technical j

Specifications (ITS). During the course of our review, we found that we require additional information to comp 1Ge our evaluation.

Please respond to the enclosed request for information (RAI) that seeks to clarify the iTS l

Sections 2.0 Safety Limits, 3.1 Reactivity Control Systems, 3.2 Power Distribution Limits, 3.5 Emergency Core Cooling Systems, and 3.9 Refueling..

On May 15, 1997, in a telephone conference with Brian D. Mann, of BGE and NRC staff, Mr. Mann said that the supplement to the Calvert Cliffs conversion amendment would be sent to the NRC on May 31, 1997.

The staff anticipates that review of the supplement will assist in the Calvert Cliffs conversion to the Standard Technical Specifications. ~To support the NRC staff's review i

schedule, your written and electronic response in Wordperfect 5.1 to this RAI i

is requested within 15 days of the receipt of this letter. Should you have i

any questions, please do not hesitate to contact me at (301) 415-3473.

e Sincerely,

/

Alexa er W. Dromerick, Senior Project Manager Project Directorate I-1 1

Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation j

l Docket Nos. 50-317 and: 50-318

Enclosure:

RAI cc w/ enc 1: See next page j

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Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas and Electric Company Units Nos. I and 2 cc:

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President-

-Mr. Joseph H. Walter, Chief Engineer.

Calvert County Board of Public Service Commission of Commissioners Maryland l

175 Main Street Engineering Division Prince Frederick, PE) 20678 6 St. Paul Centre i

Baltimore, PE) 21202-6806 James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore,10 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire 2300 N Street NW Co-Director Washis:gton, DC 20037 Maryland Safe Energy Coalition l

P.O. Box 33111 Mr. Thomas N. Prichett, Director Baltimore, MD. 21218 i

NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donate 11 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. Richard I. McLean Administrator - Radioecology Department of Natural Resources 580 Taylor Avenue Tawes State Office Building, B3 Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussian, PA 19406 3

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CCNPP ITS 2.0 SAFETY UMITS 2.0 DOC

'JFD CHANGE / DIFFERENCE COMMENT.

STATUS I

1 JFD 7 Applicability changed from " closure bolts not fully

• Not fully tensioned" is more accurate.

tensioned" to "is unbolted," to be consistent with Change section 1 not safety limits.

l MODES in section 1.

CC Response l

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CCNPP ITS 3.1.1 SHUTDOWM MARGIN t

t 3.1.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

LA.1 CTS 3.1.1.1 and 3.1.1.2 Actions require that boration Provide specific plant procedure where at greater than 40 GPM of 2300 ppm boric acid the requirement is located (i.e., relocate solution or equivalent until the Shutdown Margin is to TRM) and a discussion of the restored. ITS 3.1.1 does not contain this information regulatory controls provided.

as it is moved to plant procedures. However, the specific procedures are not identified. There is no discussion of how the Calvert Cliffs procedure control process meets the regulatory control requirements.

CC Response 2

L.2 CTS 3.1.1.2.b. Action requires that positive reactivity incorporate the limiting requirements of changes shall be suspended when the pressurizer is the boron dilution analysis into the ITS drained to < 90 inches and all sources of non-borated or provide justification for the deletion of water is > 88 gpm. ITS has deleted this requirement the requirements, based on a boron dilution analysis for three charging pumps. There is no justification provided for deleting the requirement rather than revising the limits to match the new boron dilution analysis.

CC Response

b CCNPP ITS 3.1.2 REACTIVITY BALANCE -

3.1.2 -

DOC

.JFD.

CHANGE / DIFFERENCE COMMENT ~

STATUS 1

L1 CTS 3.1.1.1 Action required immediate boration The ITS completion time is not initiation if the SHUTDOWN MARGIN was outside the consistent with either CTS or the STS limits provided in COLR. ITS 3.1.2 requires an Completion time. Justification required.

evaluation to determine it the reactor core is Submit TSTF request.

acceptable for continued operation, and to establish operating restrictions and SRs. The completion time for this Action is 7 days. STS 3.1.3 requires the same action but the time to complete was 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. There is no justification provided for increasing the completing time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.

CC Response 2

L3 CTS 3.1.1.1 is applicable in MODES 1,2,3, and 4.

Acceptance of this change is contingent ITS 3.1.2 for the reactivity balance is applicable in upon NRC approval of generic change MODE 1. The justification for the change in the MODE TSTF-141.

applicability between the ITS and the STS is based on TSTF-141.

CC Response

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CCNPP ITS 3.1.2 REACTIVITY BALANCE 3.1.2 DOC JFD CHANGE / DIFFERENCE

-COMMENT STATUS 3

M.1 CTS 3.1.1.1 does not contain any requirement when Acceptance of this charige is contingent l

Actions are not completed within the required time.

upon NRC approval of generic change Therefore ITS 3.0.3 is entered which requires entry TSTF-141. Change is less restrictive.

into MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. ITS 3.1.2 requires entry l

into MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. STS 3.1.3 requires entry into MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> whenever the required Action and associated completion time are not met.

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The justification for the change in final Definition of the j

final MODE 2 designation is cited in the ITS markup as being TSTF-141. Also, the final ITS requirement of entering MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> rather than MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> does not satisfy the definition of being More Restrictive, but rather Less Restrictive.

CC Response l

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CCNPP ITS 3.1.3 MODERATOR TEMPERATURE COEFRCIENT 3.1.3 DOC

.JFD

. CHANGE / DIFFERENCE.

COMMENT' STATUS l

1 1.A.1 CTS 4.1.1.4.1 requwes that the determination of the Provide specific plant procedure where MTC is within its limits with confirmatory the requirement is located and a measurements. These extrapolated confirmatory discussion of the regulatory controls measured values are to permit direct comparison with provided.

the MTC limits. These requirement are procedural in nature. The ITS does not include these procedural requirements. The procedural requirements are moved to plant procedures controlled under the Calvert Cliffs procedural control process. However, the specific f

procedure and associated controls are not identified.

CC Response i

2 None CTS 4.1.1.4.2.a requires a MTC determination prior to Provide the justification for adding the initial operations above 5% RTP, after each fuel NOTE to the SR.

loading. ITS SR 3.1.3.1 requires that the MTC is verified within the upper limits specified in Figure 3.1.3-1 prior to entering MODE 1 after each fuel i

loading. In addition ITS SR 3.1.3.1 has a Note that specifies the Surveillance is not required prior to entry into MODE 2, consistent with the STS. This NOTE is not identified in the marked-up CTS.

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b CCNPP ITS 3.1.3 MODERATOR TEMPERATURE COEFRCIENT l

3.1.3 DOC

.JFD CHANGE / DIFFERENCE

- COMMENT.

STATUS 3.

A.3 CTS 4.1.1.4.2.b and c requires the determination of Acceptance of this change is contingent the MTC: 1) when above 90% RTP within 7 EFPD of upon NRC approval of generic change reaching equilibrium at or above 90% RTP; and 2)

CEOG-82.

within 7 EFPD of reaching equilibrium boron concentration of 300 ppm. ITS SR 3.1.3.2 require the MTC determined at: 1) within 7 EFPD of. reaching 40 EFPD core burnup; and 2) within 7 EFPD of reaching 2/3 of expected core burnup. STS SR 3.1.3.2 requires a MTC determination within 7 EFPD of reaching 40 EFPD core burnup is changed with a generic change, t

CEOG-82, to require a MTC determination prior to i

reaching 47 EFPD.

CC Response 4

JFD 8 CTS 4.1.1.4.2.a requires the determination of the MTC Acceptance of this change is contingent l

prior to initial operation above 5% RTP after each fuel upon NRC approval of generic change loading. ITS SR 3.1.3.1 requires verification of the CEOG-75.

MTC is within the upper limits specified by Figure

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3.1.3-1. STS 3.1.4.1 requires the verification of the MTC is within the upper limits specified by COLR. The justification for the change from the STS to the ITS is

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with generic change CEOG-75.

CC Response i

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l CCNPP ITS 3.1.4 CONTROL ELEMENT ASSEMBLY AUGNMENT 3.1.4 DOC JFD CHANGE / DIFFERENCE COMMENT.

STATUS 1

CTS 3.1.3.1.e allows continued operation with one Acceptance of this change is contingent CEA misaligned less than 15 inches if the alignment is upon NRC approval of generic change restored in one hour. ITS 3.1.4 allows one or more CEOG-114.

CEAs trippable and misaligned less than 15 inches or one trippable CEA misaligned greater than 15 inches.

For either of these conditions, the power is to be reduced to less than or equal to 70% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and restore the CEA alignment within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The STS 3.1.5 Action A requires the power reduced to less than or equal to 70% RTP within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The justification for the completion time is generic change CEOG-114.

CC Response 2

L CTS 3.1.3.1.i requires that with one vi more CEAs Provide the justification for the less misaligned by 15 inches or more from the others in the stringent requirement of requiring two or group, be in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS 3.1.4 more of the CEAs misaligned greater Action D requires two or more CEAs misaligned by than 15 inches. The CTS 3.1.3.1.i greater than 15 inches to be in MODE 3 within 6 requires being in MODE 3 with two or hours. This is consistent with STS 3.1.5. The CTS more misaligned greater than 7.5 inches requirements are more restrictive than those cited in and one or more of the CEAs misaligned the ITS or STS. A discussion of the justification for greater than 15 inches.

the less stringent requirements is required.

CC Response

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t CCNPP ITS 3.1.4 CONTROL ELEMENT ASSEMBLY ALIGNMENT 3.1.4 DOC

. JFD CHANGE / DIFFERENCE-COMMENT STATUS 3

M.6 CTS 4.1.3.1.1 requires detamining the position to be Acceptance of this change is contingent within 7.5 inches of t% other CEAs in the group at upon NRC approval of generic change least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ETS SR 3.1.4.1 requires CEOG-107.

verifying the position of the CEAs are within 7.5 inches of the other CEAs in the group within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following any CEA movement of greater than 7.5 inches AND every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. The STS SR 3.1.5.1 requires the frequency of 12 for the same surveillance. The justification for the ITS SR 3.1.3.1 i

change is generic change CEOG-107.

CC Response i

4 L.6 CTS 4.1.3.1.3 requires the CEA Motion inhibit Acceptance of this change is contingent demonstrated OPERABLE at least once per 31 days.

upon NRC approval of generic change ITS SR 3.1.4.2 requires verification of the CEA motion TSTF-127.

inhibit is OPERABLE every 92 days. The STS SR 3.1.5.5 require the same every 31 days. The justification for the ITS SR 3.1.4.2 change in i

frequency is generic change TSTF-127.

CC Response

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5 M.4 New item - CTS None. ITS 3.1.4.3 requires Acceptance of this change is contingent verification of the CEA deviation circuit is OPERABLE upon NRC approval of genenc change

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every 92 days. STS 3.1.5.4 requires the same TSTF-127.

surveillance every 31 days. The justification for the I

frequency change is generic change TSTF-127.

CC Response

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CCNPP ITS 3.1.4 CONTROL ELEMENT ASSEMBLY ALIGNMENT 3.1.4 DOC EJFD --

CHANGE / DIFFERENCE _

. COMMENT STATUS 6

L3 CTS 3.1.3.1.f with one CEA misaligned in a group.

M Acceptance of this change is contiew

!l more than 15 inches, operations may contmue upon NRC approval of generic change U

provided the misahgned CEA is restored to within the CEOG-114.

S required shonment, immediately implement the reduced

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power requwements of Action g. Action g 'unplements a completion time of one hour ITS 3.1.4 Action A.2 i

requires a reduction in the RTP to less than or equal to 70% within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. STS 3.1.3 Action A.1 requires the reduction in power to less than or equal to 70% in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The justification for the change is CEOG-114.

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i CCNPP ITS 3.1.4 CONTROL ELEMENT ASSEMBLY ALIGNMENT 3.13 DOC

JFD CHANGE / DIFFERENCE COMMENT STATUS 7

Several items in the STS are deleted from the ITS due Acceptance of this change is contingent to generic changes. These items include:

upon NRC approval of genenc change STS 3.1.5 Action A.2.1 &.2 for one or more TSTF-67, TSTF-143, and CEOG-107.

regulating CEA misaligned between 7.5 and 15 inches or one CEA greater than 15 inches requiring verification the SDM is less than or equal to 4.5%

detta k/k in one hour OR initiate boration in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to restore SDM (TSTF-67);

STS 3.1.5 Action A.3.2 for one or more regulating CEA misaligned between 7.5 and 15 inches or one CEA greater than 15 inches requiring the alignment of the remainder of tne CEAs in the group to within 7 inches of the misaligned CEAs while maintaining insertion limit within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (TSTF-143);

STS 3.1.5 Action 8.1,.2, &.3 for one or more shutdown CEA misaligned between 7.5 and 15 inches or one CEA greater than 15 inches requiring reduce RTP to less than 70%, AND verify SDM greater than or equal to 4.5% delta k/k, OR initiate boration, all within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, AND restore misaligned CEAs to within 7 inches within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (TSTF-143);

i STS SR 3.1.5.2 to verify the for each of the CEAs the indication is within 5 inches every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (CEOG-107).

The CTS requirements associated with these deleted i

sections were either covered in other section of the ITS or were not required by the CTS.

CC Response I

CCNPP ITS 3.1.4 CONTROL ELEMENT ASSEMBLY ALIGNMENT l

l t

'3.1.4 DOC JFDl CHANGE / DIFFERENCE COMMENT STATUS

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8 L2 CTS 3.1.3.1 Action g requires Thermal Power to be What is a " reasonable assurance?"

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M.5 reduced to less than (50%) or (75% of the Thermal Provide the justification for the Power level prior to the misalignment if above 50%

conclusion that acceptable power RTP). ITS 3.1.4 requires the power to be reduced to distributions are maintained for a power less than 70% RTP. The justification provided for the limit of less than 70% RTP for all change is that there is reasonable assurance that misaligned CEA conditions that are acceptable power distributions are maintained for all allowed.

conditions when the power is less than 70% RTP.

I CC Response 9

L.3 CTS 3.1.3.1 Action f allows operation to continue in Update the Bases and procedures.

t MODE 1 and 2 with one CEA misaligned greater than 15 inches within the time determined by the full core power distribution monitoring system or if this system is unavailable from the allowable time provided in COLR. CTS 3.1.4 Action A allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore the CEA misalignment but does not define the restrictions that are imposed on the allowable operating time. The restrictions imposed in the CTS 3.1.3.1 need to be included in the Bases and in procedures.

CC Response l

10 L.4 CTS 4.1.3.1.2 requires each CEA that is not fully Acceptance of this change is contingent inserted is exercised at least once per 31 days. ITS SR upon NRC approval of the extension of 3.1.4.5 requires the exercising of the CEAs once per the surveillance interval.

92 days. The STS SR 3.1.5.4 require the every 92 days.

i CC Response i

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CCNPP ITS 3.1.4 CONTROL ELEMENT ASSEMBLY ALIGNMENT 3.1.4 DOC JFD-CHANGE / DIFFERENCE COMMENT STATUS L

11 JFD 6 SR 3.1.4.5 Frequency is being from 18 to 24 months Under NRC review.

to coincide with the change in refueling cycle, per

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GL 91-04.

l CC Response 12 L1 CTS 3.1.3.1 Action e. allows one CEA (regulating or The justifications for allowing more than shutdown) misaligned from the other CEA in its group one CEA to be misaligned is required and by less than 15 inches. Operation may continue in the CT change from 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

MODE 1 or 2 provided the misaligned CEA is restored in one hour. ITS 3.1.4 Action A allows one or more Note: The allowance of more than one CEAs misaligned from its group by greater than 7.5 misaligned CEA is consistent with the inches and less than or equal to 15 inches requires STS.

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restoration in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The bases for allowing more than one misaligned CEA and the CT change are not provided.

CC Response l

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I CCNPP ITS 3.1.5 SHUTDOWN CONTROL ELEMENT ASSEMBLY INSERTION LIMIT 3.1.5-DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

L2 CTS 3.1.3.1.1. requires that with more than one CEA Acceptance of this change is contingent

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misaligned more than 7.5 inches or any one CEA upon NRC approval of CEOG-114.

L3 misaligned more than 15 inches from any other CEA in the group, enter into HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Note: The ITS AOT is consistent with ITS 3.1.5 Action requires: verification of the t'wnes the the STS.

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CEAs are within 121.5 and 129.0 inches; restoration of the misaligned CEAs based on accumulated time out of specification, one misaligned CEA less than 121.5 l

inches; or two or more CEA not within limits; restore the CEAs to within limits in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, if this is not possible, enter into MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The ITS allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to correct the misalignment, this is an extension of the allowable outage time.

CC Response i

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l CCNPP ITS 3.1.5 SHUTDOWN CONTROL ELEMENT ASSEMBLY INSERTION UMIT

' 3.1.5 DOC JKO ?

- CHANGE / DIFFERENCE.

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. COMMENT STATUS i

2 CTS 3.1.3.5 Action requires with one or more Acceptance of this change to the STS is.

SHUTDOWN CEAs withdrawn to less than 129.0 contingent upon NRC approval of generic iriches consider the CEAs misaligned and immediately change TSTF-67.

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apoly specification 3.1.3.1 Actions e, f, h, or i as appropriate. ITS 3.1.5 Action has three Actions requmng: verification of the times the CEAs are within 121.5 and 129.0 inches; restoration of the misaligned CEAs based on accumulated time out of specification, one misaligned CEA less than 121.5 inches; or two or more CEA not within limits; restore the CEAs to within limits in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If this is not possible, enter into MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The STS 3.1.6 Action A requires with one or more SHUTDOWN CEAs not within limits, verify the SDM detta k/k, or initiate boration to restore the SDM, and restore SHUTDOWN CEAs to within limits. The STS 3.1.6 Action to verify the detta k/k SDM and initiate boration is deleted from i

the STS by Generic change TSTF-67.

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I CCNPP ITS 3.1.5 SHUTDOWN CONTROL ELEMENT ASSEMBLY INSERTION LIMIT i

i l

j 3.1.5 DOC iJFD CHANGE / DIFFERENCE

~ COMMENTJ STATUS 3

JFD 7 CTS 3.1.3.5 Action requires that with one or more There are several differences between a

CEA misaligned, follow the Actions identified in CTS the STS and ITS 3.1.5 that need to be JFD 9 3.1.3.1 Actions e, f, h, or i. Action g is referenced by discussed, and they are as follows:

the Action cited above. These Actions require for the

1) The change in MODE 2 definition; JFD respective Action items: h) more than one CEA

2) The inclusion of time limits in the v

10 misaligned and each misaligned CEA is within 15 CONDITION Statements; and, l

inches of any other CEA, restore within one hour or be

3) The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> restoration time for one.

in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; i) with more than or more severely misaligned CEAs.

one CEA misaligned and any one or more than one CEA misaligned CEAs is more than 15 inches from any CEA in the group, be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; l

g) allows continued POWER OPERATION for misaligned CEAs within 7.5 inches of the CEA group for 7 days per occurrence with a total accumulated time of greater than 14 days per calendar year. ITS l

3.1.5 Action has three Actions requiring: verification of the times the CEAs are within 121.5 and 129.0 1

i inches; restoration of the misaligned CEAs based on i

accumulated time out of specification, one misaligned

[

CEA lest than 121.5 inches; or two or more CEA not within limits; restore the CEAs tn within limits in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If this is not possible, enter into MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

CC Response I

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CCNPP ITS 3.1.6 REGULATING CEA INSERTION LIMITS-3.1.6 DOC

-JFD-CHANGE / DIFFERENCE COMMENT STATUS 1

LA.2 CTS 3.1.3.1 Action c. and g. allow the insertion of one

1) Provide the justification and rationale CEA beyond the long-term steady state insertion limit used to determine when the PDillimits for up to 7 days per occurrence and up to 14 days per are the most limiting. Also describe the 365 days. This is allowed only if the remainder of the other time limit requirements if the other group is inserted within 7.5 inches of the out-of-limits are more limiting.

alignment CEA. ITS does not limit the amount of time

2) Provide specific plant r,iocedures that a CEA is inserted beyond the long-term steady where the requirements are located and state limit, other than the alignment limits of ITS provide a discussbn of how the 3.1.6. However, the ITS and the CTS limit the time regulatory change controls on these the group is inserted within the steady-state insertion requirements are met, limits to 5 EFPD per 30 EFPD, and 14 EFPD per 365 EFPD. In most cases, the CTS limit is less restrictive, however, the PDlllimits are required to be adhered to.

The CTS long-term steady-state insertion limits are moved to plant procedures. This information is controlled under the Calvert Cliffs procedure control process.

CC Pesponse t

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l CCNPP ITS 3.1.7 SPECIAl. TEST EXCEfrTION (STE) - SHUTDOWN MARGIN (SDM) l t

3.1.7 DOC

'JFD CHANGE / DIFFERENCE COMMENT STATUS i

1 1.A.1 CTS 3.10.1.a. Action requires with the CEA not fully Acceptance of this change is contingent inserted and less than required reactivity equivalent upon NRC approval of generic change available for trip insertion, immediately initiate end CEOG-111 [TSTF-67).

continue boration until the Shutdown margin is restored. ITS 3.1.7 Action A requires the initiation of the Action to restore trippable CEA worth within 15 minutes. STS 3.1.8 required initiation of boration to restore Shutdown reactivity within 15 minutes. CTS 3.10.1.b. Action requires that with all CEAs inserted and the reactor subcritical by less than the above reactivity equivalent, immediately initiate boration until SHUTDOWN MARGIN in CTS 3.1.1.1.1 is restored.

ITS 3.1.7 Action A (option) requires that all CEAs inserted and reactor subcritical by less than the above SHUTDOWN reactivity equivalent, initiate Action to re' store trippable CEA worth within 15 minutes. The CTS Action b. has been completely marked for the markup for the ITS. The change is attributed to generic change CEOG-111.

CC Response e

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CCNPP ITS 3.1.7 SPECIAL TEST EXCEPTION (STE) - SHUTDOWN MARGIN (SDM) 3.1.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2

LA.1 CTS 3.10.1.b. Action requires that, with all full length Provide specific plant procedure where CEAs inserted and the reactor suberitical by less than the requirement is located and a

~

the required amount, initiate boration and continue at discussion of the regulatory controls greater than 40 gpm of 2300 ppm until SDM is provided.

restored. ITS 3.1.7 requires the initiation of action to restore the trippable CEA worth. These actions are adequately defined and controlled by plant procedures and as such are being deleted from the ITS. However, the specific procedures are not identified. There is no discussion of how the Calvert Cliffs procedure control process meets the regulatory control requirements.

CC Response I

3 LA.1 CTS 4.10.1.1 requires demonstrating each CEA not Acceptance of this change is contingent fully inserted is capable of full insertion from at least upon NRC approval of generic change 50% withdrawn 7 days prior to reducing the SDM TSTF-134.

below its limit. ITS 3.1.7.2 requires the same, however, it is modified by a note to waive the CEA drop time test requirement during initial power escalation if SR 3.1.4.6 has been performed. The bases for this added note is that of generic change TSTF-134.

CC Response i

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+

CCNPP ITS 3.1.8 SPECIAL TEST EXEMPTIONS - MODES 1 & 2 3.1.8 DOC

'JFD CHANGE / DIFFERENCE COMMENT STATUS 1

TSTF-67 removes SDM requirement from LCO.

Acceptance of this change is contmgent upon NRC approval of generic change TSTF-67; review this specific portion of TSTF-67 for acceptability. With insertion limit TS suspended, should a SDM (or similar) requirement remain?

CC Response I

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4 CCNPP ITS 3.1 RELOCATED SPECIFICATIONS

-3.1 DOC

'JFD CHANGE / DIFFERENCE

. COMMENT STATUS No Comments 6

1 1

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l CCNPP ITS 3.2.1 LINEAR HEAT RATE l

3.2.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS l

1 JFD 6 SR added to verify value of F',,. Addition to STS.

Evaluate for generic applicability, and l

submit TSTF change to revise STS if i;

found to be genenc.

CC Response

,1 2

A.5 CTS Surveillance Requirernent 4.2.1.3.a is deleted by Provide additional justification and this change. The discussion of change indicates that discussion on what CTS requirements this surveillance is "duplicative of ITS 3.1.6 and are contained outside the ITS and future revisions to this information will be controlled controlled by the Calvert Cliffs under the Calvert Cliffs procedure control process."

procedure control process, if any.

It is not clear that any portion of the CTS 4.2.2.1.2.d Surveillance Requirement is not maintained by ITS 3.1.6 SRs. Therefore, the discussion regarding requirements outside the ITS being controlled by Calvert Cliffs procedure control process is an error.

CC Response h

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l 1

CCNPP ITS 3.2.2 TOTAL PLANAR RADIAL PEAKING FACTOR 1

3.2.2 DOC JFD..

CHANGE / DIFFERENCE COMMENT STATUS 1

JFD 4 Addition to SR 3.2.2.1 Note allowing Total Planar Evaluate Note addition for genenc Radial Peaking Factor using incore detectors to obtain applicability, and submit a TSTF ti power distribution map limited to core planes between change to the STS if found generic.

15% and 85% of full core height.

i 2

LA.1 CTS 3.2.2.1 Action a requires the withdrawal of Provide discussion on which procedure CEAs at or beyond the long-term steady state will contain these details as well as the insertion limit, and a power reduction to bring the applicable procedure change control combination of Thermal Power and Total Planar Radial process.

Peaking Factor with the limits provided in the COLR or i

the reduction in Thermal Power to less than or equal Approval of this change is contingent i

to the limit established by the full core power on NRC approval of CEOG-110.

i di~ 'bution monitoring system as a function of Total aar Radial Peaking Factor when the Total Planar

.1adial Peaking Factor is outside the limits provided in the COLR. These specifics on how to restore the Total Planar Radial Peaking Factor provided by the CTS are moved to plant procedures. The discussion of change does not include what procedures these details are moved to or the procedure change control 3

process in place. This change is consistent with Generic Change CEOG-110 to the STS.

CC. Response

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f CCNPP ITS 3.2.3 TOTAL INTEGRATED RADIAL PEAKING FACTOR l'-

-3.2.3 DOC 2 JFD -:

CHANGE / DIFFERENCE

. COMMENT STATUS 1

LA.1 CTS 3.2.3 ACTION b requires the withdrawal of CEAs Provide discussion on which procedure at or beyond the long-term steady state inserten will contain these details as well as the e:

hmet, and a power reduction to bring the combinaten apphcable procedure change control of Thermal Power and Total Integrated Radial Peaking process.

l Factor withm the limits provided in the COLR and maintain the peripheral axial shape index with the Approval of this change is contingent DNB flux offset control limits provided in the COLR, or on NRC approval of CEOG-110.

the reducten in Thermal Power to less than or equal

t to the limit established by the full core power distnbution monitoring system,~as a function of Total i

Integrated Radial Peaking Factor when the Total l

Integrated Radial Peaking Factor is outside the limits j

provided in the COLR. These specifics on how to restore the Total Integrated Radia! Peaking Factor provided by the CTS are moved to plant procedures.

~

The discussion of change contains no details on which procedure contains these requirements or the change control process in place. This change is consistent with Genenc Change CEOG-110 to the STS.

CC Response I

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l CCNPP ITS 3.2.4 AZIMUTHAL POWER TILT i

i

.3.2.4 '-

DOC TJFD-CHANGE / DIFFERENCE

COMMENT '-

STATUS amyv-1 L1 JFD 7 CTS 3.2.4 Action b requires Tq wa be restored to Either adopt the STS Completion Tunes A.5 within limits in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or reduce power to s20%

of provide adequate justification for the RTP. The ITS requires restoring Tg to within limits in less restrictive ITS Completion Times.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or reducing power to s50%RTP within ths next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The STS allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore Tq and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to reduce power. Adequate justification is not provided for this *out-of-scope" change (the ITS is less restrictive than both the CTS and STS).

CC Response 2

LA.1 CTS Surveillance Requirement 4.2.4.2.b requires the Provide discussion on which procedure determination of Azimuthal Power Tilt using the incore contains this information c:d the detectors at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one excore applicable procedure control process.

channel is inoperable and Thermal Power is > 75%

RTP, This requirement is moved to plant procedures.

The discussica of change contains no information on which procedure contains this information or the details of the applicable procedure control process.

CC Response i

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CCNPP (TS 3.5.1, SAFETY INJECTION TANKS (SITS) 75.1' DOC LJFDy CHANGE / DIFFERENCE g ; COMMENTS,

' g,

STATUS;-

3

.m All I CCNPP relies upon CEOG-87 for many of the changes Provide changes deleting CEOG-87 included in this LCO. Please revise to delete changes based changes.

d resulting from CEOG-87.

1 CCNPP Response:

>N 1

LA.2 CTS Survedlance Requirement 4.5.1.f specifies the Provide specific plant procedure where sample location for verifying boron concentration as the requirement is located and a "HPSI pump discharge." ITS SR 3.5.1.4 requires discussion of the regulatory controls verifying boron concentration but does not specify the provided.

i sample location. This detail is moved to plant

[

procedures. However, the specific procedure and i

associated controls are not identified.

l i

CCNPP Response:

3 L.1 STS 3.5.1 Action A requires restoration of boron concentration to within limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the BEYOND SCOPE I

condition of one. inoperable SIT, due to boron Acceptance of this etwnee is ;-@

concentration outside limits. ITS 3.5.1 Action A upon NRC appre/al of genenc change requires restoration of the SIT to OPERABLE status and CEOG-87.

adds " inability to verify level or pressure" to this condition. The added inability to verify level or pressure to the Condition and the changed l

Requirement to restore the SIT to OPERABLE status results in a deviation from the STS based on generic s

change CEOG-87.

l CCNPP Response:

I a

i CCNPP ITS 3.5.1, SAFETY INJECTION TANKS (SITS) r3.5.1 -

DOC

//JFDL h

2 CHANGE /DIFFERENCEI x

LCOMMENT g

i

STATUS 4

L2 CTS 3.5.1 requires the restoration of the SIT to TSTF AWAITING COMMISSION ACTION operable status withm one hour with one tank Acceptance of this change is contingent e

inoperable. The STS requires the retum to operable upon NRC appoval of generic change status within one how if the one SIT is inoperable for TSTF-59.

reasons other than buon ccm:entration not within limits. The ITS 3.5.1 Actions has increased the completion time from one hour to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> based on generic change TSTF-$9.

m... _

CCNPP Responoo:

5 L3 CTS 3.5.1 requires that the isolation valve to be TSTF AWAITING COMMISSION ACTION i

opened immediately when one SIT is inocerable. The Acceptance of this change is contingent STS requires the retum to operable status within one upon NRC approval of generic change i

hour if the one SIT is inoperable for reasons other than TSTF-59.

boron concentration not within limits. The ITS 3.5.1 Actions has increased the completion time for i

retuming to operable status to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> based on generic change TSTF-59.

CCNPP Response:

6 LA.1 CTS Surveillance Requirement 4.5.1.c specifies power Provide specific plant procedure where is removed to the isolation valve operator by the requirement is located and a maintaining the feeder breaker open under discussion of the regulatory controls.

administrative control. ITS SR 3.5.1.5 requires provided.

verifying power is removed from each isolation valve operator but does not specify the feeder breaker being open by admiriistrative controls. This detailis mcad to plant procedures. However, the specific procedure and associated controls are not identified.

i t

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

CCNPP ITS 3.5.1, SAFETY INJECTION TANKS (SITal l

33.5.n DOC TJFD7

~

CHANGE / DIFFER!.NCE b W - X N ~

COMMENT MF W STAT.US l

CCNPP Response:

7 L6 CTS Survedlance Requirement 4.5.1.e requires a Provide the justification for the deletion verification of the opening of the SIT isolation valves of this test requirement or a reference to whenever the pressure is greater than 300 psia and another section that would satisfy the j

upor aceipt of a SIT signal. This requirement is testmg function.

.l deleted from the ITS 3.5.1 Surveillance Requirements.

There is no justification presented that these automatic

{

i functions are not required or are being tested in i

another section.

d i

V CCNPP Respor.se:

4

(

i 8

A.3 CTS 3.5.1 Actions a and b are based on the position IS THIS ALSO BASED,IN PART ON l

of the isolation valve. The ITS Actions are not based CEOG-877 on the isolation valve position. There is no justification i

or basis provided for not including the isolation valve Provide the justification and basis for not l

position.

basing the Actions on the position of the isolation valve.

l CCNPP Response:

i i

11 L.1 CTS 3.5.1 does not have an Action based on the Acceptance of this change is contingent inoperability due to boron concentration not being upon NRC approval of generic change within limits or the inability to verify the pressure and CEOG-87.

level in the SIT. ITS 3.5.1 Action A incorporates these condition requirements to require the restoration of the l

SIT 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 basis i

for these requirements is generic change CEOG-87.

CCNPP Response:

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e CCNPP ITS 3.5.2 ECCS - OPERATING 1

[3.5;2 ?

DOC

~!JFD}

~

^$

. dCOMMENT@i ' '

STATUS'

- CHANGE / DIFFERENCE l 8

• ~

1 L1 CTS 3.5.2 requires that with one or more ECCS COMMENT SAME AS 3.5.1 subsystems inopwable that the subsystems should be 4

retumed to operaDie status withm 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The Acceptance of this change is contingent proposed Action A extends this completion time to upon NRC approval of generic change retum the subsystem to operable status to within 7 TSTF-58.

days for the LPIS subsystem only. ITS 3.5.2 Action A proposes the same requirement for the LPIS to be returned to operable status be added to the STS. The STS does not have a specific action statement for the

-i LPIS subsystem. The basis for changing the STS is the generic change TSTF-58.

l CCNPP Response:

t 2

LA.4 CTS Surveillance Requirement 4.5.2 specifies in a Provide specific plant procedure wtere footnote, that whenever flow testing into the RCS is the requirement is located and a i

required at RCS temperatures of 365'F and less, the discussion of the regulatory contro!s high pressure safety injection pump shall recirculate provided.

RCS water. This requirement is used to demonstrate operability of the ECCS subsystems. ITS SRs do not contain this requirement. This detail is moved to plant procedures. However, the specific procedure and associated controls are not identified.

j CCNPP Response:

1 s

f

CCNPP iTS 3.5.2 ECCS - OPERATING

~

3.5.2 '

' DOC-fJFD -;

. LCHANGE/ DIFFERENCE

~ '

N TCOMMENT J

STATUS 3

LA.5 CTS Surveillance Requirement 4.5.2.e.1 specifies that Provide specific plant procedure where verification of the open-permissive prevents the the requirement is located and a U

Shutdown Cooling System suction isolation valves discussion of the regulatory controls i

from being opened at RCS pressure of greater than provided.

309 psie. ITS Srs do not contain this requirement.

This detail is moved to plant procedures. However, the specific procedure and associated controls are not i

identified.

i CCNPP Response:

4 LA.6 CTS Surveillance Requirement 4.5.2.h.1 specifies that Provide specific plant procedure where verification of HPSI flow rates shall be greater than the requirement is located and a 470 gpm for the sum of the three lowest flow legs discussion of the regulatory controls l

following completion of HPSI modifications. ITS Srs provided.

l do not contain this requirement. This detailis moved to plant procedures. However, the specific procedure and associated controls are not identified.

CCNPP Response:

{

5 None CTS Surveillance Requirement 4.5.2.b.1 provides a BEYOND SCOPE i

suru:",ce requirement for verifying the containment MAKE SURE THAT THIS IS COVERED IN isolation valve opens upon a Recirculation Actuation 3.3.4.

Test Signal every 31 days. This requirement is moved I

to ITS SR 3.3.4 with a surveillance interval of 92 days.

j No justification is provided for the change in frequency of the surveillance interval.

l CCNPP Response:

i I

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CCNPP ITS 3.5.2 ECCS - OPERA 131G

'I i3.5.2 :

DOC-JJFDJ W

' iCHANGE/ DIFFERENCE,

^

14Y wdCOMMEN$ Mffhj STATOS 8

A.5, CTS Surveillence RequhTwd 4.1.2.8 has been Prowde the justification for the quehfying

f A.7 revised to require that each of the chorging pumps note added to the surveillance ej develops a flow of greater than 37 g",e in accordance requirement hmeting the surveillance to with the Inservice Testmg Program. -ITS 3.5.2.4 now when the reactor power is grooter then l

contains the surveillance requirement. A quainfying 80%, based on system design, current il note is added to the STS to only require the hcensing basis or operational constraints.

l performance of the surveillance when greater then STS requwes this at all times.

[

80% reactor power. No justification is provided to support the added qualifying note. This change is a deviation from the STS requirements.

f i

i 1

CCNPP Response:

l

}

7 LA.3 CTS Surveillance Requirement 4.5.2.c requires that a Provide specific plant procedure where r

}

wwuoi inspection of the containment be performed to the requwement is located and a verify that no debris could be transported to the discussion of the regulatory controls containment sump resulting in plugging the pump provided.

suction during a LOCA. ITS Srs do not contain this requirement. This detail is moved to plant procedures, i

However, the specific procedure and associated controls are not identified.

i CCNPP Response:

1 8

LA.7 CTS Surveillance Requirement 4.5.2.h specifies that Provide specific plant procedure where verification of the head of the HPIS pumps be the requirenant is located and a 2

determined dunng the recirculation flow test to the discussion of the regulatory controls refuehng water tank. ITS Srs do not contain this prowded.

requirement. This detail is moved to plant procedures.

However, the specific procedure and associated i

controls are not identified.

i I

CCNPP ITS 3.5.2 ECCS - OPERATING

$3.'5.2.5

'l DOC) dM w

CHANGE /DIFFERENCEt

~ '4 COMMENT " ~ '

STATUS:

3' i

CCNPP Response:

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CCNPP ITS 3.5.3 EMERGENCY CORE COOUNG SYSTEM (ECCS) - SHUTDOWN.

'53'.5.34 DOC fJFDi

?

CHANGE / DIFFERENCE 1

'COMMENTi W

'aa STATUS

^

i 1

LA.2 The CTS 3.5.3 requirement to place the HPIS control Provide specific plant procedure where switch in the pull-to-lock position at or below 365"F is the requirement is located and a

l moved to plant procedures. The specific plant discussion of the regulatory controls procedures and associated regulatory controls are not provided.

edentified.

CCNPP Response:

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CCNPP ITS 3.5.4 REFUEUNG WATER TANKS (RWT)

'3.5.4 c DOC ifJFD).N/ % }M

.. CHANGE / DIFFERENCES A NY ' COMMENTd?"T% '

SThTUS

+ * -

No comments t:

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CCNPP ITS 3.5.5 TRISODluiWI PHOSPHATE

) 3.5.5!

DOC IJFO) 3 CHANGE / DIFFERENCE '

/"

• NOMMENT/ mp SE

STATUS 1 2

1 A.2 CTS 3.5.2 Surveillance Requirements contain testmg Change the designation of this change requirements for the Trisodium Phosphate (TSP). ITS from an Adnsiistrative to a More 3.5.5 is created to address TSP that elevates the Restrictive designation.

p requirements to an LCO rather then just a Surveillance Requirement. This is considered as a more restrictive change.

i CCNPP Response

,t

~'

2 L1 The CTS 3.5.2 and 3.5.3 Trisodium Phosphate (TSP)

Provide additional discussion and Surveillance Requirements are Applicable in MODES 3 justification for deleting the MODE 4 when plant pressure is equal to or greater than 1750 Applicabiiity based on Safety Analysis psia and in MODE 4. ITS 3.5.5 changes the assumptions.

l Applicability to MODES 1,2, and 3, deleting MODE 4 Applicability. It is not clear that the TSP inventory is not assumed in the plant accident analysis for MODE 4 Conditions.

CCNPP 9esponse:

i l

1 l

I 1

CCNPP ITS 3.9.1 REFUELING OPERATIONS - BORON CONCENTRATION Table 3.9.1 Rev.1 May 9,1997

-: 3.9.11

~ DOC

[JFD;

' iCHANGE/ DIFFERENCE -

b 'ir.[ COMMENT

• 1

~

ISTATUS x

s 1-JFD1 Terms in the ITS LCO for the volumes flooded with Evaluate the Bases for 'mconsistent borated water during refueling operations are not application of TS LCO terms and revise consistently applied in the Bases.

the submittal as necessary.

CCNPP Comment:

2 L2 L2 relates to deleting CTS SR 4.9.1.1 that specifies Provide the requested additional the boron concentration is required to be within the justification.

limits prior to special cases listed in the SR. The DOC discussion should be revised to state that the ITS Mode 6 requirements bound each case specified in SR 4.9.11. If it does not then additional justification l

needs to be provided.

CCNPP Comment:

i I

4 e

I I

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q CCNPP ITS 3.9.2 REFUELING OPERATIONS - NUCLEAR INSTRUMENTATION Table 3.9.2 Rev.1 May 9,1997 J3.9.2 :

' DOC: <JFD(

4

- CHANGE / DIFFERENCE ~

! COMMENTj s ' '

^7 STATUS 1

none none The CTS requirement for two " operating" SRMs is Prowde a DOC discussion for each changed to two " operable" SRMs without justification.

proposed change to the CTS.

CCNPP Response:

2 M.2 Prowde additional M.2 discussion to address changes Provide a DOC Mscussion for each to the applicabilities in the CTS to ITS translation and proposed change to the CTS.

use of Core Alterations vice Mode 6 for specified I

surveillance.

CCNPP Response:

3 L1 The DOC states that the CTS SR 4.9.2.a tests only Provide additional explanation.

the Rate of Change Pcwer-High RPS trip, yet the SR requries a CFT test of the SRM instrumentation.

j Explain how plant procedures meet the SRM CFT test requirements by testing the RPS Rate of Change Power-High instrumentation.

CCNPP Response:

i 5

i

?

i

~. _ -

t l

CCNPP ITS 3.9.3 REFUELING OPERATIONS - CONTAINMENT PENETRATIONS l

Table 3.9.3 Rv.1 May 9,1997 13.9.3 c

. DOC'

fJFDl

~

CHANGE /DIFFERENCEL GN; LCOMMENT C

. STATUS 1

A.7 CEOG-115 (TSTF-197) is incorporated in the ITS. CTS Wnhold acceptmg this change pendmg 3.9.4 is applicable for penetrations that provide direct staff review and approval of CEOG-115.

E access from the containment atmosphere to the "octsida atmosphere." ITS 3.9.3.c is applicable for penetrations that provide direct access from the containment atmosphere to 'the environment."

l CCNPP Response:

2 2

STS 3.9.3.c.2 requires the containment penetrations Provide justification for the STS

(

capable of being closed by an Operable Containment deviation based on current licensing i

Purge and Exhaust isolation System. ITS 3.9.3.c.2 bases, system design, or oporational requires closure capability from a Containment constraints.

l Radiation Signel (CRS). The equivalency of Operable Containment Purge and Exhaust isolation System and Containment Radiation Signal (CRS) is unclear.

CCNPP Response:

3 LA.1 CTS 3.9.4.c.1-4 stipulates actions taken when both Provide additional less restrictive change l

containment Personnel Airlock Doors are open. These discussion including specific safety basis requwements are moved to ITS 3.9.3 Bases and plant discussion for the CTS requirements and l

procedures. The prcposed change results in the explain why the deletion will not result in olimmation of CTS limiting conditions for operation, as a significant safety question in the such the use of a less restrictive relocation of TS detail operation of the plant.

justification is not acceptable. Each proposed change to CTS limits requires a safety basis discussion.

CCNPP Response:

I 1

s

t CCNPP ITS 3.9.3 REFUELING OPERATIONS - CONTAINMENT PENETRATIONS Table 3.9.3 Rv.1 May 9,1997 l

3.9.3 -

DOC.

4JFD-

. CHANGk/DIFFERENCEl

^

L. COMMENTS

n ^

STATUS.

4 L.2 CTS SR 4.9.4.b and 4.9.14 require verifying the These L justifications require additional

• i penetrations are in their required condition, or capable discussion of the safety basis for the L.5 of being closed by an Operable containment purge proposed extension in order to adopt the valve (4.9.4~.b only) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start ITS Surveillance Test Interval.

of and at least once per 7 days during Core Alterations i

and movement of irradiated fuelin containment. ITS SR 3.9.3.1 does not retain the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requirement.

This extends the CTS STI from <72 hours to <7 l

days.

l l

CCNPP Response:

5 L.3 10 CTS SR 4.9.9 requires verifying the containment purge This L justification requires additional isolation valves isolate to their correct position on an discussion of the safety basis for the actuation signal within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start of proposed extension in order to adopt the Core Alterations and at least every 7 days thereafter.

ITS Surveillance Test Interval.

t ITS SR 3.9.3.2 requires this verification each refueling outage prior to the start of Core Alterations or i

movement of irradiated fuel assemblies within the containment, but deletes the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CTS STI. This extends the CTS STI from <72 hours to once per refueling outage.

t CCNPP Response:

f I

. m 4

CCNPP ITS 3.9.3 REFUEUNG OPERATIONS - CONTAINMENT PENETRATIONS Tatde 3.9.3 Rv.1 May 9,1997 f 3.9.3 4

. DOC:

iJFDI

/-

~ CHANGE / DIFFERENCE.

^ -

f COMMENTM M

STATUS-

/

l 6

L.4 CTS SR 4.9.9 requires verifying the containment purge This L justification requires additional OOS supply and exhaust isolation system capable of discussion of the safety basis which I

isolating on an actuation signal once per 7 days during includes instrument loop and actuated refueling. ITS SR 3.9.3.2 requires performing the test device reliability in order to adopt the t

once each refueling outage prior to starting Core proposed extension from 7 days to once Alterations or movement of irradiated fuel assemblies por refueling interval.

within the containment, but deletes the 7 day STI.

This extends the CTS STI from every 7 days to once per refueling outage.

CCNPP Response:

7 A.3 2

CTS 3.9.9 includes Operability and Action Provide discussion and justification for requirements for the Containment Purge Valve Isolation deleting Containtnent Purge Valve system dunng refueling. With the Containment Purge isolation System Actions from CTS Valve isolation inoperable, the requirements specify 3.9.9.

closing each penetration providing access from the i

containment atmosphere to the outside atmosphere.

l The CTS 3.9.9 requirements are moved to ITS 3.9.3.

l ITS 3.9.3 replaces the CTS requirement for the Containment Purge Valve Isolation System with the Containment Radiation Signal.

CCNPP Response:

(

i 1

CCNPP ITS 3.9.3 REFUELING OPERATIONS - CONTAINMENT PENETRATIONS Table 3.9.3 Rv.1 May 9,1997 i3.9.3 DOC 4 IJFD,

V N'*

LCHANGE/ DIFFERENCE:

1

' [ COMMENT ['s L+3 < >

. STATUS' 8

A.3 CTS 3.9.14 requires that the Containment Vent Provide discussion and jb.Gi;c.ation for b

OOS isolation Valves are closed during Core Alterations or the disposition of CTS 3.9.14, movement of irradiated fusi assemblies in containnsent.

Containment Vent isolation Valves.

The CTS markup indicates the requirements are moved i

l to ITS 3.9.3. Discussion A.3 is provided for movmg l

CTS 3.9.4 and CTS 3.9.9 but the discussion does not i

include moving CTS 3.9.14.

l CCNPP Response:

i 9

L.5 CTS 3.9.14 provides requirements and actions for the Provide a revised discussion and l

Containment Vent isolation Valves dunng refueling justification for the desired CTS operations. CTS 4.9.14 requires verification that requirements changes.

Containment Vent isolation Valves are in the closed position 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the start of and at least every 7 days during Core Alterations. DOC L.5 discusses verifying that the valves actuate to their correct position on an actuation signal. DOC L.5 also discusses a Purge and Exhaust valve SR in ITS 3.9.3.2 which requires the Purge and Exhaust valves to actuate. It is unclear what changes to what systems L.5 is discussing.

CCNPP Response:

r t

L i

t

_ -.. ~.. =

_ ~.

~

CCNPP Ils 3.9.3 REFUEUNG OPERATIONS - CONTAINMENT PENETRATIONS Table 3.9.3 Rv.1 May 9,1P37 L 319.35 DOC fJFDj iCOMMENT gN'

. STATUS CHANGE / DIFFERENCE s

I 10 L5 CTS 3.9.14 requires the Containment Vent Isolation Provide discussion and just'fication for

=!

valves closed during Core Alterations or irradiated fuel deleting the Containment Vent isolation movement in containment. With one or more vent Actions from ITS 3.9.3.

isolation valves open, CTS 3.9.14 Action requires closing the valve within one hour or suspending all operations involving Core Alterations or movement of irradiated fuelin containment. CTS 3.9.14 requirements were moved to ITS 3.9.3. but the requirement to close an open valve within one hour is not part of ITS 3.9.3 Required Action.

CCNPP Response:

11 None CTS 3.9.4.c and ITS 3.9.3.b provide requirements for Acceptance of this change is contingent Containment Airlock Doors. ITS 3.9.3.b adds upon staff approval of TSTF-68 rev 1.

i requirements for the Emergency Airlock that tre not contained in CTS 3.9.4.c. This change is based on TSTF-68 rev.1.

CCNPP Response:

[

12 8

The JFD states that CTS requirements allow both Provide a revised JFD discussion.

Personnel Air Locks open if one door id capable of

}

being closed. This statement is one item in a list of 4 CTS conditions which must be met for both airlock doors to be open. Revise the JFD discussion to include att limiting conditions for operation.

CCNPP Response:

i I

i CCNPP ITS 3.9.3 REFUELING OPERATIONS - CONTAINMENT PENETRATIONS i

Table 3.9.3 Rv.1 May 9,1997 23.9.35 DOC

'fJFDj

,.m

',. CHANGE /DIFFERENCEf

< :# ICOMMENT c, i ? -

STATUS 13 LA.2 The DOC discussion justifies relocating details because Provide revised LA.2 discussion.

"this detail does not change the requerement that the l

Action be performed." Provide a safety basis discussion for the change. The discussion of change i

should relate that LCO limhs are not changed and that the relocated requirements establish a good practice i

for ensuring reactor operations do not pose a threat to l

public health and safety.

CCNPP Response:

f I

14 LA.3 Specific TS requirements, to verify that the Frovide COC discussion for each I

containment purge valve isolates on a manual initiation proposed change.

3 and high radiation test signal from the containment j

l radiaDm monitoring instrumentation channels, are j

delete '. Provide L DOC discussion for the deletions, i

CCNPP Response:

15 A.1 The A.1 DOC is used in CTS SR 4.9.9 to justify the Provide additional DOC discussion.

addition of test applicabilities for containment purge i

valves. The proposed justification is not detailed enough to make a finding that the applicability changes l

are administrative.

CCNPP Response:

i I

I i

~

CCNPP ITS 3.9.3 REFUELING OPERATIONS - CONTAINMENT PENETRATIONS Table 3.9.3 Rv.1 May 9,1997 3.9.3 DOC-OJFD-CHANGE / DIFFERENCE -

.7 i COMMENT::-

STATUS 16 A.6 The A.6 DOC is used to justify the deletion of Provide additional justification.

I surveillance test requirements specified in ITS SR 3.9.3.2 to verify valves close on test or actual signals if the valve is closed to comply with ITS LCO 3.9.3.c.1: i.e., the staff accepts that valves not included in the TS applicability because they are closed can be controlled under administrative controls. DOC A.6 does not present sufficient justification to make a finding that the SR changes are administrative.

CCNPP Response:

17 TSTF-68 Rev.1 is incorporated into the Bases.

Withhold approval pending staff review.

CCNPP Response:

I l

l

CCNP? ITS 3.9.4 REFUEUNG OPERATIONS - SHUTDOWN COOLING AND COOLANT CIRCULATION - HIGH WATER LEVEL Table 3.9.4 Rev.1 May 91997 1

-73.9.4 DOC 53FDJ

. CHANGE /DIFFERENCEl COMMENT) q:

STATUS 1

M.1 The logical connector'"AND* between ITS 3.9.4 Insert the logical connector in 4;

Required Action A.1 and A.2 is omitted from ITS 3.9.4 accordance with common usage o

Required Action.

described in ITS 1.2, Logical Connectors.

CCNPP Response:

2 L1 11 CTS 3.9.8.1 Action a requires with less than one SDC Acceptance of this change is contingent loop in operation that all containment penetrations upon NRC approval of CEOG-115.

providing direct access from the containment 4

atmosphere to the outside atmosphere are closed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

.i CTS 3.9.8.1 allows the SDC pumps to be deenergized I

for local leak rate testing of penetration 41 end maintenance of SDC smtion valves.

Both of these requirements are changed to

" Containment penetrations are in the status described in ITS 3.9.3." This change relaxes two fission product boundaries with only the cladding boundary intact.

This change is justified by CEOG-115.

CCNPP Response:

w

~

CCNPP ITS 3.9.4 REFUEUNG OPERATIONS - SHUTDOWN COOUNG AND COOLANT CIRCULATION - HIGH WATER LEVEL i

Table 3.9.4 Rev.1 May 91997 I

T3.9.4 :

.DOCt JFD5

CHANGE / DIFFERENCE -

.: COMMENT STATUS:

~

3 A.6 The statement that CTS 3.9.8.1 applicability includes Provide additional discussion that the d

" operable" is incorrect.

proposed changes are administrative.

Also, the discussion states that splitting CTS LCO 3.9.8.1 requirements (Mode 6, all water levels) into I

two Mode 6 ITS LCOs (one for > 23 feet and the other for s 23 feet of water)is administrative. When

'i compared to CTS 3.9.8.2 (Mode 6 < 23 feet of I

water) a datermination cannot be made that the change is administrative because the action for these two applicabilities are different and because CTS LCO 3.9.8.2 already exists for the condition of s 21 feet of water.

i CCNPP R

- inse:

4 L.3 Current TS requirements allow shutdown cooling to be Provide additional justification.

i periodically removed from service during the i

performance of core alterations in the vicinity of the reactor pressure vessel hot legs. The DOC states the importance of this evolution is to prevent reducing boron concentration. Further, the DOC states that operations such as core mapping, RCS to SDC isolation l

valve testing etc. will be permitted. Explain how " core alterations in the vicinity of the RPV hot legs" can I

affect these operations that will now be permitted.

CCNPP Response:

5 8

incorporation of CEOG-85 in Bases Withhold approval pending staff review.

i r

1 CCNPP ITS 3.9.4 REFUEUNG OPERATIONS - SHUTDOWN COOUNG AND COOLANT CIRCULATION - HIGH WATER LEVEL Tatde 3.9.4 Rev.1 May 91997

+ 3.9.41 DOC:

4JFD CHANGE / DIFFERENCE / ~ '

q; % %, iCOMMENT '.

' fin ^

[ STATUS CCNPP Response:

5 6

Bases CEOG-115 (TSTF-196) changes to Action A.4 Bases Revise the Bases to incorporate all of were partially incorporated.

CEOG-118. Acceptance of CEOG-118 is

'{

pending staff review.

CCNPP Response:

1 l

l 1

[

CCNPP ITS 3.9.5 REFUELING OPERATIONS - SHUTDOWN COOLING AND COOLANT CIRCULATION - LOW WATER LEVEL t

Table 3.9.5 Rev.1 May 9,1997 l

13.9.5 DOC-kJFD1 5

[ CHANGE / DIFFERENCE )

W (COMMENT STATUS y

l 1

A.6 5

!TS LCO 3.9.5 requires two SDC loop operable and These LCOs do not address the same j

M.3 one in operation in Mode 6 with reactor water level <

plant conditions. The changes proposed i

L.1 23 feet above irradiated fuel. ITS 3.9.5 has essentially by these DOCS are rejected. Provide a L.2 the same limits and applicability as CTS 3.9.8.2.

revised markup of CTS 3.9.8.2 and L.3 Certain limitations and a!!owances for operation in associated DOCS for adopting NUREG Mode 6 are proposed to be added to ITS 3.9.5 using 1432 LCO 3.9.5.

mquirements from CTS 3.9.8.1. CTS 3.9.8.1 requires one SDC loop to be in operation.

CCNPP Response:

i 2

L.1 CTS 3.9.8.1 Action a requires, with less than one SDC Acceptance of this change is contingent loop in operation, that all containment penetrations upon NRC approval of CEOG-115.

providing direct access from the containment atmosphere to the outside atmosphere are closed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.9.5 Action B.3 changes these requirements to " Containment penetrations are in the status described in ITS 3.9.3."

This change is

[

justified by CEOG-115.

CCNPP Response:

i 3

A.6 ITS 3.9.5 does not include any Required Actions that Delete DOC A.6 discussion and restrict altering the decay heat load of the reactor.

justification.

Water level and Core Alteration restrictions are established in ITS 3.9.6.

A.6 is not applicable to ITS 3.9.5.

CCNPP Response:

+

CCNPP ITS 3.9.5 REFUEUNG OPERATIONS - SHUTDOWN COOUNG AND COOLANT CIRCUULTION - LOW WATER LEVEL I

Table 3.9.5 Rev.1 May 9,1997 L 3.9.5 ;

DOC? QFD?

~

.? CHANGE / DIFFERENCE 1, L*"

,n M

jCOMMENT

'SX STATUS) 4 L.3 5

ITS 3.9.5 LCO Note 1 provides an allowance that the Provide discussion and justification for i

M.3 SDC loop is not required to be in operation for < 1 the less restrictive change includmg hour per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period provided no operations that securing SDC loop flow during low water would cause boron concentration to change are level conditions and applicability of L.3 permetted. This note is added for consistency with with respect to ITS 3.9.5.

CTS 3.9.8.1 which applies to applicability during all l

water levels and expands the allowance to operations beyond core alterations in the vicinity of the SDC hot leg descharge. Water level requirements provide a volumetnc heat sink in the event of loss of SDC (M.1).

Water level and Core Alteration restrictions are established in ITS 3.9.6.

CCNPP Respones:

5 L.2 Surveillance Requerement CTS 4.9.8.1 requires Explain the safety analysis basis for this verification that the SDC loop is operating and the flow change to the ISTS.

rate is > 1500 GPM every four hours. ITS SR 3.9.5.2 sets the frequency at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

CCNPP Response:

6 LA.1 6

CTS details for usmg the spent fuel pool to replace the Relocation of allowances which provide shutdown cooling loop are proposed to be relocated to limits to operation is not acceptable.

the Bases. This proposed change is rejected because Provide a revised submittal that includes these detail represent limiting conditions for operation.

the entire CTS # footnote in ITS Note 2.

l l

CCNPP Response:

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

s CCNPP ITS 3.9.5 REFUEUNG OPERATIONS - SHUTDOWN COOUNG AND COOLANT CIRCULATION - LOW WATER LEVEL I

Table 3.9.5 Rev.1 May 9,1997

3.9.5.

DOC lJFD.;

! CHANGE /DIFFEftENCE!!

Je,

fc. &

J: COMMENT C. ^ J RM

~ STATUS' 7

7 ITS SR 3.9.5.1 requirements to verify that one SDC This change is rejected until the staff loop is in operation are deleted.

approves a TSTF for this generic change.

CCNPP Response:

8 8

incorporation of CEOG-85 in Bases.

Withhold approval pending staff review of proposed changes.

CCNPP Response:

9 2

CEOG-115 (TSTF-197) insert #4 to Bases for Action Revise the Bases to incorporate all of B.3 was partially used.

CEOG-118. Acceptance of CEOG-118 is pending staff review.

CCNPP Response:

i

___.-__._m

CCNPP ITS 3.9.8 REFUEUNG OPERATIONS - REFUEUNG POOL WATER LEVEL l

Table 3.9.6 Rv.1 May 9,1997 l

?

l

? 3.9.6 :

DOC CJFD.6 1

. CHANGE / DIFFERENCE J.

x:c

. ' et i COMMENT? t

• y ' -~ ~

STATUS t

f 1

M.1 The M.1 DOC states that the proposed changes Based on the information provided the minimize the possibility of a fuel handling accident in staff could not confirm the basis of the containment that is beyond the asstanptions of the justification. Provide additional 1

safety analysis.

information to document the stated M.1 conclusion.

CCNPP Responoo:

2 M.2 The M.2 DOC concludes that the ITS changes expands Provide clarifying information to support the CTS required actions without specifying exactly statements that the proposed more how this conclusion is reached. In addition the DOC restrict change expend CTS states the change were made to ensure that a fuel requirements and ensures fusi handling handling accident cannot (emphasis added) occur.

accidents cannot occur.

CCNPP Response:

9 r

I

f s

l l

CCNPP ITS REFUEUNG OPERATIONS - RELOCATION TaSa for Relocated Requirements Rew.1 May 9,1997 RELOCATED :

DOC) JJFD' CHANGE / DIFFERENCE-.

!. COMMENT '

e t

STATUS Decay Time R1 Incomplete DOC disctession.

Revise R.1 to include evaluation of

[.

the 50.36 criteria for ITS.

i CCNPP Response:

r e

I L

4 4

i i

-..a-.

.- -.- - m u

-