Text

Requests Addl Info Re DAEC Improved TSs in Order to Complete Review of Request Submitted 961030.Provide Response to Encl Questions within 30 Days to Meet Staff Review Schedule
	ML20217N930
Person / Time
Site:	Duane Arnold
Issue date:	08/18/1997
From:	Kelly G; NRC (Affiliation Not Assigned)
To:	Leslie Liu; IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
Shared Package
ML20217N937	List: ML20217N930; ML20217P012;
References
	TAC-M97197, NUDOCS 9708260390
	Download: ML20217N930 (116)
	v • d • e

Mr. Lee Liu August 18, 1997 Chairman of the Board and Chief Executive Officer IES Utilities Inc.

200 First Street, SE.

P.O. Box 351 Cedar Rapids, IA 52406-0351

SUBJECT:

DUANE ARNOLD ENEROY CENTER (DAEC)- REQUEST FOR ADDITIONAL INFORMATION (RAI) ON TiiE DAEC IMPROVED TECHNICAL SPECIFICATIONS (ITS) (TAC NO. M97197)

Dear Mr. Liu:

On October 30,1996, IES Utilities Inc., submitted a request for a license amendment to convert the UAEC Technical Specificmions to ITS. The staff requires additional information (RAI) in order to complete its review. The staff requests that you provide a response to the enclosed questions within 30 days to meet the staft's review schedule. Because of time constraints and stalT resource limitations, the staff is transmitting these RAls although they are not as precise as normally would be expected. We also enclosed a letter from Christopher Grimes to James Davis for your review, as indicated in the questions for DAEC ITS Section 5.0.

Sincerely, ORIGINAL SIGNED BY Glenn B. Kelly, Sr. Project Manager Project Directorate III-3 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Decket No. 50-331

Enclosures:

As stated cc w/encls: See next page DPotL, Distribution:

Docket File PUBLIC PDIll-3 R/F JRoe JCaldwell, Rill ACRS OGC, 015B18 GMarcus EAdensam (e-mail)

G:\DUANEARN\DUA97197.RAI OFFICE LA:PDill-3 l PM:PDilly u NAME CBoyle GKelly /fg T DATE / /97 fpff97 970826039' O '97085Ei ~'~

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Lee Liu Duane Arnold Energy Center IES Utilities Inc.

cc:

Jack Newman, Esquire Kathleen H. Shea, Esquire Morgan, Lewis, & Bockius 1800 M Street, NW.

Washington, DC 20036-58f9 Chairman, Linn County Board of Supervisors Cedar Rapids, IA 52406 IES Utilities Inc.

ATTN: Gary Van Middlesworth Plant Superintendent, Nuclear 3277 DAEC Road Palo, IA 52324 John F. Franz, Jr.

Vice President, Nuclear Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Ken Peveler Manager, Nuclear Licensing Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U.S. Nuclear Regulatory Comission Resident inspector's Office Rural Route #1 Palo, IA 52324 Regional Administrator, RIII U.S. Nuclear Regulatory Comission 801 Warrenville Road Lisle, IL 60532-4531 Parween Baig Utilities Division Iowa Department of Comerce Lucas Office Building, 5th floor Des Moines, IA 50319 4

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DAEC ITS 1.0 USE AND APPLICATION A4TASL10.DAS i

7/1s/97 r i 1.0 L DOC iJFD

, LCHANGE/DfFFERENCE F COMMENT -

STATUS 1.0-1 A.4 The ITS 1.1 definition of Operat40perstwhty changes Reclasssfy the change as more restrictive l' the CTS 1.0 definition by changing " cooling or seal and provide discussion and justification ,

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water" to " cooling and seal water." This is a more for the more restrictive change.

U , restrictive change. -

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! 1.0-2 L1 The CTS 1.0.9 definition of Hot Standby Candition Provide discussion and justification for i requ.h the coolant temperature be > 212 F for the- the less restrictive change to CTS ~ I l plant to be in Hot Standby. This defirwtion and requirements.

!i requirement is not maintained in ITS 1.1, Definitions, 6

or ITS Table 1.1-1, Modes. Allowing the plant to be in Hot Standby with temperature < 212 F is a less restrictive change that is not adequately justified. r 1.0-3 L1 The discussion and justification for this change states Provide discussion and justification

, that it encompasses both Adminisvative and Less separately for the Administrative and the Restrictive chenges. Changes to the CTS definitions of Less Restrictive changes.

Hot Standby Condstion, Reactor Power Operation, and Shutdown are stated to the Administrative. However, these changes are classified as Less Restrictive and ncne of the changes are classified as Administratrve.

1.0-5 M.1 The CTS 1.0.22 definition of Channel Calibration Provide disctasion and justification for includes a statement that the acceptable range and deletmg the CTS statement.

accuracy of an instrument and its setpoint are given in

, the system design control document and its setpoint is used in the CTS. This statement is not included in the -

ITS 1.1 Defmitions. No discussion or justification is provided for deleting this statement.

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j DSEC fTS 1.0 USE AND APPLICATION AdTASUS.DAS DOC *

! , d .O . LJFD . . CHANGE /DfFFERENCE '

COMMENT a '

STATUS r r d 1.0-6 M.1 . The CTS 1.022 defhstion of Channel Functional Test Provide discussion and justification for defines the test for both analog channels and bistable not imiuding both analog and bistable channels. The corresponding ITS 1.1 definition does channels in the ITS 1.1 defirwtions or

, not distinguish between analog and bistable channels. Channel Functional Test.

I No discussion or justification is provided for not l including both analog and bistable channels in the ITS 1.1 definition.

.1. 0-7 A.11 ITS 1.1, Definitions, revises the CTS 1.0.22 defm* ition Provide discussion and justification for -

of Logic System Function Test (LSFT) to remove the

.l

,. this less restrictive change to CTS '

I requirement to include the sensor and end device. requirernents.

I Since the CTS definition requires includeg both the l

, sensor and the end device in the LSFT and the ITS Reclassify the change as Less restrictive.

definition does not, this is a less restrictive change. ,

t 1.0-9 A.7 The CTS 1.0.49 definition of SDM requires using the Provide discussion and justification for i analytically determined strongest rod. The ITS allows the less restrictive change to CTS ;

either the analytically determined strongest rod or the requirement allowing the strongest rod 1

strongest rod determined by test. Allowing the to be determined by test.

i strongest rod to be determined by test is a less ,l restrictive change. Reclassify as Less Restrictive.

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1.0-10 P.1 The change to STS 1.1 definitions of Channel Acceptance of this change is contingent l Calibration and Channel Functional test clarifies what upon NRC approval of generic change l ,wrtions of a channel require testing to consider the TSTF-64. (

channel OPERABLE. The changes are based on generic :

change TSTF-64. . 7/17/97 TSTF-64 is still pending. ,

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l' l DAEC ITS 1.0 USE AND APPUCATION AdTAs u o.pno :

h 1.0L DOC l JFDl : . CHANGE / DIFFERENCE :s : COMMENT STATUS 1.0-11 P.2 The STS 1.1 definition of Dose Equivalent 1-131 uses Provide justification for this STS microcuries/ gram as units for concentration. This is deviation based on current licensing l

, ! changed to microcuries/mi in ITS 1.1. The units in the basis, system design, or operational O CTS are microcuries/ gram (ml). The justification does constraints.

not adequately show why the change to i micrograms /ml is needed or preferable. ;

1.0-12 P.13 The ITS 1.1 definition of Dose Equivalent I-131 dc.'etes Provide justification for this STS the STS 1.1 phrase "..or those listed in Table E-7 of deviation based on current licensing ;

Regulatory Guide 1.109, Rev.1, NRC,1977, or ICRP basis, system design, or operational i 30, Supplement to Part 1, page 192-212, Table titled, constraints. l

" Committed Dose Equivalent in target Organs or , l l- Tissues per Intake of Unit Activity". No justification is !l provided for deleting this ph ase from the STS ;

definitum. j

, 1.0-13 P.3 The STS 1.1 definitions of Emergency Core Coolmg Determination on hold until ECCS !

l System (ECCS) Response Twne and Isolation System response time requirements in TS Response Twne are deleted in ITS 1.1, Definitions. 3.3.5.1 are resolved. :

This change is based on EPRI study EPRI NP-7243, l Investigation of Response Twne Testing Requirements,"

May 1991. !

1.0-14 P.11 The STS 1.1 phrase used in the definition of End of Provide justification for this STS i P.13 Cycle Recirculation Pump Trip (EOC RPT) System deviation based nn current licensing Response Twne ".. complete suppression of the electric basis, system design, or operational ;

are between the fully open contacts of the constraints. i recirculation pump circuit breaker" is replaced 'm the same ITS 1.1 definition with " actuation of the breaker secondary (auxiliary) contact." No justification for this i change is provided.

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DAEC ITS 1.0 USE AND APPLICATION A.4TAaL10.DAO

, ; 11.0 ; DOC q#Dj _

$ ' _ f CHANGE / DIFFERENCE # v :r ~ COMMENT [ ? STATUS f; a, +

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1.0-15 P.4 The ITS 1.1, Definitions, deletes Pressure Boundary NRC is reviewing DAEC's lack of a !

ji: Leakage from the STS 1.1 definition of Leskage. This pressure bounderd TS in Section 3.4.

J'L change is based on DAEC TS amendment #203.

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jll 1.0-17 P.16 The bracketed term, for each class of fuel, in the STS Provide justification for this STS

' ;i 1.1 definition of Minimum Critical Power Ratio (MCPR) deviation based on cummt Ilconsing !

! veas not adoptet! in ITS 1.1. No justification is basis, system design, or operational j j provided. constraints. ;

, . I y 1.0-18 P.9 The term Transition Boiling is used in the ITS 1.1 Submit a TSTF generic change package i Li . definition of Minimum Critical Power Ratio (MCPR) to change boiling transition to transition i c rather than the STS 1.1 term of boshng transition. The boding. The term transition boiling is

. DAEC definition of Transstion Boiling is added to the more widely used by heat transfer ITS. The term transition bosling is more widely used by analysts.

heat transfer analysts.

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1.0-19 None The marked up STS 1.1 defirwtion of Minimum Critical Revise the ITS 1.1 definition of Mirnmum Power Ratio (MCPR) indicates that the term boiling Critical Power Ratio (MCPR) to .

transition is replaced in ITS 1.1 by the term transition consistently use the term transitior:

boiling. The ITS 1.1 definition of Minimum Critical boiling. -

Power Ratio (MCPR) mixes the terms boiling transetion i and transition boiling. The change to the term transition boiling should be accomplesbx! consistently in the ITS without any ambiguity. i

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DAEG ITS 2.0 SAFETY LIMITS A:\TABL2o.DAo 7/18/97 2.0 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2.0-1 L.1 CTS 1.1.A requires a Minimum Critical Power Ratio Retain MCPR 11.10 for single loop (MCPR) less than 1.10 for single loop operation. ITS operation in accordance with current 2.1.1.2 requires a MCPR 11.08 for single loop licensing basis and NRC SER to license operation. This is a deviation to the CTS requirement. amendment 119.

This deviation is based on an analysis supporting RTS 124C, NEDO-24272, UFSAR 15.45.

2.0-2 L.3 CTS 1.2.2 requires the reactor vessel dome pressure Provide additional discussion and shall not exceed 135 psig at any time when operating justification for changing the CTS the RHR pump in the shutdown cooling mode. This pressure requirement when operating the reouirement is incorporated into ITS 3.3.6.1, Table RHR pump in the shutdown cooling 3.3.6.1-1. The value listed in Table 3.3.6.1 is i 152 mode.

psig. There is inadequate justification for this difference of CTS requirements.

2.0-8 A.5 CTS 1.1.B requires the RTP shall not exceed 25% Provide additional discussion and when the reactor pressure is1785 psig or core flow justification for changing the CTS is less than or equal to 10% of rated core flow. ITS values, including the formulas for this 2.1.1.1 removed the " equal to" from the less than or change based on the DAEC Safety equal to symbol. Analysis.

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DAEC ITS 3.4.1 RECORCULATION LOOPS OPERATING .!

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L s 3.4.1 :: DOC .JFD- CHANGE / DIFFERENCE - COMMENT- ~

STATUS

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t I 3.4.1-1 A.3 CTS Survedlance Requirement 4.6.F.1 requaes daily Provide justdicahon for this less restnchve i

! venficahon of recaculahon pump speed rmsmatch. . CTS change in acceptance entena.

4.6.F Bases contains details on this testmg including the ;

htmts which are set at i 10% and i 15% of the average i speed for the above and below 80% power cases, respeCJ.di. ITS SR 3.4.1.1 replaces CTS 4.6.F.1.

3 However, the hmets of ITS SR 3.4.1.1 is that the faster ,

speed pump is 5122% of the slower pump speed with i' h,

reactor power >80 RATED THERMAL POWER and 5135% of the slower pump speed with reactor power -

<80% RATED THERMAL POWER. i 3.4.1 P.1 ITS SR 3.4.1.1 monitors Rectculatum Pump Speed The JFD does not provide sufficent mesmatch while STS SR 3.4.1.1 monitors Jet Pump Loop details indicahng how the LPCI Loop !

Flow mismatch. The JFD indicates that this change is - Select affects the SR. I due to LPCl Loop Select design at DAEC.

3.4.1-3 M.4 The discussion of change for M.4 states in part that identify CTS 3'.6.F.2 footnote. I single loop limits must be initially applied in Startup and !

Run (Modes 1 and 2) only in accordance with CTS I 3.6.F.2, footnote *. CTS 3.6.F.2 has no footnote. i; 3.4.1-4 R.2 CTS 3.3.F.5.b requires, after W of the idle The discussion does not indicate what recuculabon pump, the discharge valve of the lower plant procedure contains this requirement. i speed pump not be opened unless the speed of the faster pump is less than 50% of its rated speed. This requrement is moved to unidenhfied plant procedures. ,

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DAEC ITS 3.4.1' RECORCULATION LOOPS OPERATING 3.4.1 DOC ?JFD -- JCHANGE/ DIFFERENCE j s COMMENTL STATUS 3.4.1-5 R.3' .

CTS 3.3.F.4.c for Segle Loop Operaten (SLO) requires The docusson does not indcole what l isolatog the idle loop electncelly by deconnectog the plant procedure contans this requirement i breaker to the recrculaten pu ry ndor generator (M/G) set dnve motor prior to reuor startup, o.-if dmabled 1 dunng reactor operaten, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of entenng SLO. This infonnshon 'smoved to umdentdied plant procedure 2.

3.4.1-6 none Acton A.1 does not require the schon that is Justdy DAEC contmued procedure of .

recommended in the ITS 3.4.1 Bases for A.1 manually going to shutdown rather than manually scrammmg vs. gomg to Shutdown. scramming the reactor a' nmedelely.

3.4.1-7 none What in the current bcensmg bases supports the Docuss CLB and why a procedural statement in iTS Bases Applicable Safety Analyses, at Imtaten alone is acceptable for allowed the top of page B3.4-3, "For some limded low probability varimbons in recirculation pump speeds.

accidents..." and why is a procedural limitabon alone acceptable on allowed vanatens in recuculation pump speeds?

. -...j-I DAEC fTS 3.4.2 JET PUMPS

i 3.4.2 DOC JFD- CHANGE / DIFFERENCE- COMMENT- STATUS i i _3.4.2 R.1 -' . CTS Surveillance Requirement 4.6.E1 contains The discussion does not indicate which j j' desenpth matenal relative to the performance of CTS plant procedure wW contain these i

! . Survesitance Requrement 4.6.E1. This desenptive requrements.

material requires performance of CTS Survemance t 9

Requrement 4.6.E1 after any unexplaned changes in I either core flow. jet pump loop flow, recirculation loop l flow, or core plate differential pressure. This informaten is move to urudentified plant procedures. i q 3.4.2-2 R.2 . CTS Surveillance Requirements 4.3.F.4.a and 4.6.E4 [ No specificITS Bases sechon was i'~ require that basehne data be updated as soon as referenced and no ITS 3.4.2 Bases j pim,& I to evaluate jet pump Operabihty. The secten appears to explicstly contam the j discussion of change indicates that these regurements requrement to update beseline data as !

are moved to the Bases. Mc ;m, no 5pec;T,c ITS soon as p.,i i.

, Bases sechon was referenced and no ITS 3.4.2 Bases ;

sechon appears to exphcstly contain the requwement to update basehne data as soon as g.cu i.

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. .. .I DAEC ITS 3.4.3 SRVs and SVs -

3.4.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3.4.3-1 R.1 . The CTS 4.6.D.2 requwement to disassemble and The discussion of change contains no inspect one SRV once per Operating Cycle is moved ;inivir.ieticxi on what plant procedure into umdentified plant procedures. contams this requwement.

. 3.4.3-2 None in ITS SR 3.4.3.1, the roundog off of SRV setponts Provide just; Tic.et;uh I needs to be addressed to make the allowed values

!! reflect +1 and -35 i!

! 3.4.3-3 None ITS 3.4.3 Bases LCO. If six valves are what is Provide justificaten.

j required the statement "eight valves are requwed to be OPEPABLE so that the reactor will not be operated for an uniwnrted penod of time with any valve inoperable."

needs to be further explamed.

3.4.3-4 Ley.2 This discussion covers extension of surveillance test This is beyond the scope of the intervals from once per operatog cycle to once per 24 conversion.

months 3.4.3-5 M.1 CTS Surveillance Requwement 4.6.D.3 requwes Provide justificaten.

venfyng each SRV open when mar:ually actuated with reactx pressure a: 100 psig and turbme bypass flow to the mam condenser. ITS SR 3.4.3.2 replaces this requwement with a Note that states that ITS SR 3.4.3.2 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after reactor steam pressure and f% are adequate to perform the test. The ITS SR Bases states " adequate pressure at which the test is to performed is .

approximately 150 psig..." This is a change from the CTS which requwed performance of the test once pressure reached greater than 100 psig.

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a DAEC ITS 3.4.4 RCS OPERATIONAL LEAKAGE 3.4.4 DOC JFD CHANGE /DfFFERENCE . COMMENT STATUS i

f,- 3.4.4-1 P .11 Notwithstandmq that having a pressure boundary Adopt a pressure boundary leakage leakage specification is not part of the CTS, the licensee spedre hi.

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has failed to adequately explain what makes the p! ant -

design unique and unable to accommodate this important specification. It is true that the CTS l

. requirement was discussed in the licmsee's submittal in I: '

support of Amendment #203. However, the NRC review -

! did not make a finding on that specife issue.

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DAEC ITS 3.4.5 LEAKAGE DETECTION INSTRUMENTATION ,

i 3.4.5 DOC JFD CHANGE / DIFFERENCE - COMMENT STATUS

3.4.5-1 none . ITS 3.4.5 has only one REQUIRED ACTION yet is Correct REQUIRED ACTION numbenng

'I designated A.2.

3.4.5-2 none iTS Bases Background next to last paragraph reads Correct Bases.

"The Primary Contamment Air Samphng System is not ...

but agt ..."

i e 3.4.5-3 P.16 STS 3.4.8. ACTION B.1, requires analysis of grab Provide desenphonrJwtirsi;06.

' ]j samples once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when primary contamment air sampling is inoperable and restorabon of the monitor I to operable status within 30 days. P16 in part states that tha CTS does not contain such requirements. While CTS 3.6.C.4 contains no requwements for restoration of or compensatory schon for inoperable conts; nirmit air samphng. CTS 3.6.C.3 refers to Table 3.2.E which requaes Action 68 be taken in such a case. A3 elimmates that schon by stating it is solely a reference .to another speciretici without desenbeg what action is elimmated. Without descnption of the action required it cannot be venfied that the CTS do in fact not require any action when air samphng akme is inoperable.

3.4.5-4 none ITS Bases SR 3.4.5.2. Shouldnlit be the " tests ensure" Correct wordng.

rather than the " test ensure _s"?

DAEC ITS 3.4.6 RCS SPECIFIC ACTIVITY - l 3.4.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS i'

3.4.6-1 R.1 . Cie Table 4.6.B.1-1 contains requirements for reactor Provide discussion.

l coolant sampling and analysis while in the Run, Startup i and Hot Shutdown Modes. The specirc manner in which the isotopic analysis is pc,fvirried (by analyzing the filtrate from the 0.45u filter) is moved to unidentified J plant procedures. No information is given in the discussion concerning which plant procedures comain

,; these details.

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] 3.4.6-2 A.4 CTS Table 4.6.B.1-1, requires an analysis for gross Provide discussion.

iodine. A 4 only addresses how one analysis is duplicative of another but does not address the elimination of gross iodine analysis.

i 3.4.6-3 L4 CTS Table 4.6.B.1-1 requires RCS soi>plirig and Provide discussion.

analysis when in Run, Startup, or Hot Shutdown (Modes

i. 1,2, and 3). ITS SR 3.4.6.1 requires this RCS sampling

and analysis in Mode 1. L-4 addresses the issue of

, extending the interval but not the issue of changing the l conditions in which the sampling is requ' red to be done.

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DAEC ITS 3.4J RHR SHUTDOWN COOLING SYSTEM-HOT SHUTDOWN ;

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, 3.4.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS a

3.4.7- 1 P.27 STS 3.4.8 is appuc ble in MODE 3 with reactor steam Prowde discussion.

't j dome pressure < [the RHR cut in permissive pressure].

This is changed in the iTS 3.4.7 APPLICABILITY to be l in MODE 3 with reactor steam dome pressure < the l RCIC Steam Supply Line Pressure-Low isolation l pressure. ITS 3.4.7 Bases LCO states "Two shutdown l cooling subsystems are required to be OPERABLE, and when no reorculation pump is in operation one shutdown cooling subsystem must be in opc,#dG .

i. Given that recirculation pumps are required only to be operable in Modes 1 and 2 and the Applicability of ITS 3.4.7 is Mode 3 reactor steam dome pressure less than ,

RCIC Steam Supply Line Pressure-Low isolation pressure, what assures the Bases will be met?

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.j DAEC ITS 3.4.8 RHR SHUTDOWN COOUNG SYSTEM-COLD SHUTDOWN

t. I li i 3.4.8 DOC JFD I CHANGE / DIFFERENCE COMMENT STATUS i

il 3.4.8-1 P.29 ^ STS 3.4.9 requwes two RHR shutdown cooling Provide Jitstification.

I subsystems OPERABLE. With no recwculation pump in operaten. STS 3.4.9 requwes at least one RHR l

shutdown cooling subsystem in opeiet;0n. Th's is changed in ITS 3.4.8 to require two RHR shutdown

, cooling subsystems OPERABLE and at least one recirculabon pump or RHR shutdown cooling subsystem in operation when reactor coolant temperature is 2150 degrees F. This deviabon is in format and the addebonal restnchon on applicability of1150'F. The jusi;Tet;0n

,l for this deviabon from the STS only addresses the large i! margm to 212 degrees F when below 150 degrees F and does not justify the change based on current

> licensing basis, system design or operational constramts.

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. . .I DAEC ITS 3.4.9 RCS PRESSURE AND TEMPERATURE LIMITS 3.4.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS I

3.4.9-1 R.1 . CTS 3.6.A.2 cor:tains specific operator direction that the Provide discussion.

reactor vessel be vented and power operation not be conducted unless the reactor vessel temperature is equal to or greater than that shown in Curve C of CTS I

Figure 3.6-1, when RCS temperature I?m;ts are i exceeded. This operator direction to vent the reactor

. vesse! is moved to plant procedures. The discussion

- does not iuentify the procedures now containing this diraction.

3.4.9-2 R.2 CTS 4.6.A.1 contains details for when the RCS Provide discussion.

temperature Surveillance for heatups and cooldowns may be discontinued. These details are moved to unidentified plant procedures. The discussion does not identify the procedures now containing these details.

3.4.9-3 R.3 CTS 4.6.A.1 and 4.6.A.2 contain specific RCS locations Provide discussion.

for monitoring temperature during heatups and cooldowns and inssivice hydrostatic or leak testing.

These details are moved to unidentified plant procedures. The discussion does not identify the procedures now containing these details.

3.4.9-4 R.5 CTS Survei!!ance Requirements 4.6.A.2,4.6.A.3 and Provide discussion.

4.6.A.4 contain recording requirements. The ITS does not contain this level of detail in the ITS SRs. These details have been moved to unidentified plant procedures. The discussion does not identify the procedures now containing these details.

l DAEC ITS 3.4.9 RCS PRESSURE AND TEMPERATURE LIMITS i'

f 3.4.9 - DOC JFD CHANGE / DIFFERENCE COMMENT STATUS i i

3.4.9-5 None STS SR 3.4.10.3 has a note which states "Only required Provide justdication.

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to be met in MODES 1,2,3, and 4 [with reactor steam dome pressure > 25 psig]. This is changed in ITS SR I 3.4.9.3 % be "Only required to be met in MODES 1,2, 3, and 4 during recirculation pump startup." No justification is given 3.4.9-6 None STS 3.4.10.4 has a note which states "Only required to Provide justificahon be met in MODES 1,2,3, and 4." This is changed in ITS SR 3.4.9.4 to be "Only required to be met in MODES 1,2. 3, and 4 during rerirculation pump startup." No justification is given.

3.4.9-7 none Figure 3.4.9.1. Minimum vessel metal temperature as Provide discussion.

measured where? On the critical component for that portion of the curve?

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ITENj ' _ ;DUC/*% CTS /SN- "O

. DESCRIPTION 10F] ISSUE 3'il ^DATEM. DATENh LCOPMENTS k. &

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OPENED-- CLOSED-3.6.1.1-1 A.4 CTS 15.b CTS 25.b requires that at least 7/8/97 Provide one door in each airlock is . additional closed and sealed. No change is discussion and-associated with this requirement, justification

, 3 yet it is marked A.4. A.4 for the l changes "PRINARY CONTAINNENT administrative INTEGRITY shall be maintained" to change

" Primary conta!nment 1. hall be associated with

! OPERABLE." This has noth*ng to the airlock

, do with the airlock door. . See door. See Item

Ites Numbers 3.6.1.1-2 and Numbers 3.6.1.2-1. ,3.6.1.1-2 and l 3.6.1.2-1.

e 9

1

DhEC ITS 3.6.1.1 PRINARY CONTAlletEMT ITEM) M IDOC/[ CTS /STSi 'DESCRIPTICE'"0FilSSUE O - i f4 1 DATE N L DATEi CopslENTS pN),J Wh %F ^

~ '

fJFDP :LCO " ' -

~

OPENED - CLOSED? ~

3.6.1.1-2 A.4 CTS 15. CTS 15 " PRIMARY CONTAllelENT 7/8/97 Revise the.

A.8 ITS INTEGRITY" definition is divided markup to show R.1 83.6.1.1 into three parts in the CTS- that definition j . Bases- markup. The'first part is CTS 15 " PRIMARY L BACKGROUND associated with ITS 1.0 and the CONTAlfRIENT l2 change is designated A.8 which INTEGRITY" is-

! deletes the definition from TS. being relocated i i The second part is associated in its entirety with containment isolation valves to the Bases of (CTS 15.a) and the change is _ ITS 83.6.1.1.

i! designated R.1 which states that the majority of CTS 15.a is Provide-additional relocated to the Bases. Since discussion and this R.1 is in the justifications justification for ITS 3.6.1.3 ft is assumed it for this Less is relocated to ITS B3.6.1.3, Restrictive which it is not. The third part (LA) change.

is associated with airlock doors See Item and manways (CTS 15b and c) and Numbers the changes are designated A.4 3.6.1.2-1 and and R.I. For A.4 see Item Number 3.6.1.3-4.

3.6.1.1-1. R.1 relocated CTS 15.c to ITS B3.6.1.1 Bases-BACKGROUND.- The markup is --

incorrect. The entire definition for PRIMARY CONTAlfffENT INTEGRITY is moved to ITS B3.6.1.1 Bases-BACKGROUND.- In addition, the staff considers this a'Less Restrictive change (LA) rather than a Relocation (R), which is reserved for the movement of whole specifications. See Item Numbers 3.6.1.2-1 and 3.6.1.3-4.

2

r DAEC ITS 3e6.1.1 PRIMARY CONTAIMENT ITEM}?pt /

.D0C/ A CTS'STS? - DESCRIPTION'0F11SSUEi DATE4 _ DATE i Co mENTS 303 4 m JFD E ' ' LCO @ m -

OPENED? CLOSED-- '

3.6.1.1-3 LCT.2 CTS CTS 4.7.E.4 requires a leak test 7/8/97 Delete this j

Bases 4.7.E.4 of the drywell to suppression change.

P.8 ITS SR chamber structure every operating 1

. 3.6.1.1.2 cycle (18 months). ITS SR l ITS 3.6.1.1.2 requires a leak test j B3.6.1.1 every 24 months. This extension

Bases- of the surveillance frequency is i

, SR considered by the staff as a i 3.6.1.1.2 beyond scope of review item for

I this conversion.

I i l 3.6.1.1-4 P.54 ITS SR CTS 4.7.A.I.aa requires leak rate 7/6/97 Licensee to Bases 3.6.1.1.1 testing in accordance with the update i P.18 and Primary Containment Leakage Rate submittal with

! Associated Testing Program. STS SR regards to Bases 3.6.1.1.1 requires the visual 11/2/95 letter examination and leakage rate and updated testing be performed in TSTF 52 when OG accordance with 10 CFR 50 provides Appendix J as modified by revision or approved exemptions. ITS SR provide 3.6.1.1.1 modifies STS SR additional 3.6.1.1.1 to conform to CTS justification 4.7.A.I.A. The STS is based on for deviations.

Appendix J Option A while the CTS /ITS are based on Appendix J, Option B. Changes to the STS j with regards to Option A versus Option 8 are covered by a letter from Mr. Christopher I. Grimes to Mr. David J. Modeen, NE! dated 11/2/95 and TSTF 52. The ITS changes are not in confomance with the letter or TSTF 52 as modified by staff comments.

3

DAEC ITS 3.6.1.1-PRINARY CONTAIMENT

^

liEML 2 00C/85 CTS /STS o, DESdRIPT10ibtTIISSUEf* * ~kh

~

DATEi ,, lDATEC COMENTS /

N0k P

?JFD i # LCor te ' -"

1 -

OPENED 9 Closed -

- ~ m

. 3.6.1.1-5 Bases- STS STS B3.6.1.1 Bases-SR 3.6.1.1.2 7/8/97 Delete this P.1 B3.6.1.1 states the following: "This SR change.

Bases- measures drywell to suppression

-i . SR chamber differential 1! 3.6.1.1.2 pressure...to ensure that the i ITS leakage paths...are within 83.6.1.1- allowable limits." ITS B3.6.1.1 Bases- Bases SR 3.6.1.1.2 changes this SR statement as follows: "This SR 3.6.1.1.2 maintains drywell to suppression chamber differential pressnre...to measure and ensure that the-leakage paths... The .

il Justification used (Bases P.1) is for plant specific nomenclature, system description, etc. This justification does apply to the changes made. -In addition, this SR does not maintain a differential pressure but measures the increase in pressure

o detemine the leakage rate.

Therefore, the change is unacceptable.

. 3.6.1.1-6 Bases STS STS B3.6.1.1 Bases-SR 3.6.1.1.1- 7/8/97 See item Number P.8 B3.6.1.1 references a number of SRs in ITS 3.6.1.3-4.

Bases-SR 3.6.1.3. ITS B3.6.1.1 Bases SR 3.6.1.1.1 3.6.1.1.1 changes these numbers ITS to reflect the deletion of a B3.6.1.1 number of SRs in ITS 3.6.1.3.

Bases-SR These chnges are dependent on 3.6.1.1.1 resolution of Iten Number 3.6.1.3-4.

4

.DAEC ITS 5.6.1.2 PRIMARY CONTAINMENT AIRLOCK ITEM 4 DOC /t CTS /STS DESCRIPTION OF ISSUE: DATE- DATEi . ~CO M NTS- ~

< ' ~

NOD ~JFDE LCO1 - OPENED- CLOSED' 3.6.1.2-1 A.4 CTS 15.b CTS 15.b requires that 7/8/97 Revise the CTS

! at least one door in markup to i cach airlock is closed include CTS

! . snd sealed CTS 15.b is 15.b, and

'f: definitely part of the provide OPERABILITY requirements additional

' discussion and for airlocks and as such should be included in justification the CTS markup for ITS for the changes 3.6.1.2. See item made to CTS

, Numbers 3.6.1.1-1 and 15. b".

3.6.1.I-2.

l 3.6.1.2-2 Bases STS SR STS SR 3.6.1.2.2 7/8/97 Licensee to P.1 3.6.1.2.2 requires verifying only -

update submittal ~

Bases !TS SR one door in the airlock to be in P.8 3.6.1.2.2 and will open at a time at accordance with Associated six month intervals. TSTF 17 or Bases The interval is modified i provide in the ITS from 6 months additional to 24 months. This justification modification is in for the accordance with TSTF 17; deviations.

however, the Bases changes are not in accordance with TSTF 17.

1

DAEC ITS 3.6.1.2 PRIMARY CONTAIMENT AIRLEK CTS /STSW: DESCRIPTION '0F: ISSUE ' DATE!. DATE __ ComENTSj

' ITEM l DOC /) 5 M.- >

JFD ' LC0 + - OPENED. '

CLOSED:

', 3.6.1.2-3 Bases ITS B3.6.1.2 ITS B3.6.1.2 Bases RA 7/8/97 Delete this

P.2 Bases- A.1, A.2 and A.3 adds change.

RA A'.1, A.2 the following sentence

and A.3 "This 7 day allowance is tracked from initial entry into condition A and is not intended to place a limitation on the use of Note I to the ACTIONS." The j justification used (P.2) is for enhances clarity, .

typographical errors or 1 1

Bases consistency. This change does not enhance clarity, changes the intent of the Note, and could possibly be generic. Therefore it is ur: acceptable.

3.6.1.2-4 None ITS B3.6.1.2 See Ites Number 3.6.1.1- 7/8/97 See Item Number Bases 4. 3.6.1.1-4.

e 2

DAEC-ITS 3.6.1.3 PRIMARY CONTAllmENT ISOLATION VALVES (PCIVs)1 1 ilTEM$^

DOCIIM l CTS /STS:: DESCRIPTION,OF) ISSUE' 3RE ...

DATEc CopOENTS -

N0n *

'JFDV 4 LC0 W . 2 OPENF.9 CLOSED --

3.6.1.3-1' A.4- CTS 15 See Item Number 3.6.1.1-2 7/8/97 .See Ites Ncaber-A.8 ITS 3.6.1.1 3.6.1.1-2. l R.1 Bases

. BACKGROUND 3.6.1.3-2 A.4 STS 3.6.1.3 Three new Notes are added to 7/8/97 Delete'this P.3 ACTION ITS 3.6.1.3 ACTIONS. Note 2 change.

Bases Notes allows separate condition l P.2 ITS 3.6.1.3 entry for each penetration

! ACTION . flow path.- Note 3 requires s Notes and entering applicable Conditions Associated and Required Actions for

. Bases systems made inoperable by PCIVs.- Note 4 requires entering Conditions and ,

Required Actions of ITS 3.6.1.1 when NSIV or purge valve leakage rates exceed overall containment leakage rate acceptance criteria. 'STS 3.6.1.3 Action Note 4 applies to all PCIVs not to just MSIV and Purge Valves. Since.

leakage from any valve could result' in valve inoperability yet not result in overall containment leakage being exceeded, the' Note has to apply to all PCIVs. In addition, there is inadequate justification (P.3) to limiting Note'4.to just MSIVs and Purge Valves. The staff finds the change unacceptable, and potentially generic.

~

I ,

I DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

ITEM. ' DOC /) CTS /STS: . DESCRIPTION OF ISSUEL DATE- DATE COWlENTS l NO.' JFD:" - LCO ~ OPENED- CLOSED- I 3.6.1.3-3 M.4 STS 3.6.1.3 STS 3.6.1.3 Condition I 7/8/?< Delete this P.37 ACTION I defines the acronym OPDRVs in generic change.

ITS 3.6.1.3 Condition I. ITS 3.6.1.3

- ACTION G ACTION G removes the phrase

" Operation with a potential for draining the reactor vessel (OPDRVs) from Condition i G and places it in RA G.1 in piece of "0PDRVs." The justification (P.37) states that the only OPDRVs that need to be suspended are those asso:1ated with the RHR Shutdown Cooling System. The justification does not provide adequate justification as to why ITS 3.6.1.3 ACTION G should not apply to the other OPDRVs implied by the justification. Since the ras are connected by an "or" there is no guaranty that RA G.I will be used for when the RHR valves are inoperable rather than RA G.2. The STS considers this condition into Condition I as unacceptable.

In addition, the staff has determined that this is a generic change which is beyond the sc7pa of review for this

,conve.Sfon.

2

DAEC ITS 3.6.1.3 PRINARY CONTAIMIENT ISOLATION VALVES (PCIVs)-

{ITEN) fl; DOC t/I" '

CTS /STN DESCRIPTIONLOF$ilSSUEi >' DATEk 'DATE COMENTS@

J NO. >

'JFD 'LCO R OPENED - CLOUD

i 3.a:1.3-4 R.1 CTS 15.a STS SR 3.6.1.3.3 and SR. 7/8/97. . Revise the CTS I

P.7 STS SR- 3.6.1.3.4 verify that each markup and ITS i

Bases '3.6.1.3.3 manual PCIV and blind flange 3.6.1.3 to

, P.2 STS SR located outside and inside include STS SR Bases 3.6.1.3.4 containment respectively that 3.6.1.3.3 and SR-

(( P.8 and is required to be closed is 3.6.1.3.4 and T Associated' closed. ITS 3.6.1.3 does not its Associated Bases . include these STS SRs. The Bases. Also-ITS B3.6.1.3 justification used (P.7) is revise ITS.

. Bases- incorrect. The STS SRs are B3.6.1.3 Bases-SR 3.6.1.3.1- required, based on the CTS SR 3.6.1.3.1 to requirement specified in CTS reflect these 15.a.2). While it'is correct changes.

.that the majority of CTS 15.a Provide any is relocated (R.1) to the additional Bases as background natarial discussion as for ITS B3.6.1.1,'.the necessary. See requirement specified in CTS Item Number 15.a.2 needs to be specified 3.6.4.2-4.

as an SR just like the rest of the definition requirements.

CTS definitions are part of the TS requirements and can specify indirectly or directly SRs or OPERA 8ILITY requirements that must be met, such as in this case. See Item Number 3.6.4.2-4.

A 3

= --

, DAEC ITS 3.6.1.3 PRIMARY C0ffTAIW4ENT ISOLATION VALVES (PClifs)

ITEM DOC /: CTS /STS -

DESCRIPTION OF-ISSUE DATE DATE CrNIENTS NO. JFD' LCO- OPENED CLOSED 3.6.1.3-5 R.4 CTS 3.7.B.4 CTS 3.7.8.4.a requires that 7/8/97 Cor ect this Bases ITS 83.6.1.3 containment purge valves not 8 discrepancy or P.2 be opened so as to create a provide

.{Pases-O 3.6.1.3.4 flow path from the primary additional containment. The specific- discussion and valves listed in CTS 3.7.C.4.a ; justification are moved to the ITS 3.6.1.3 '

for not listing Bases SR 3.6.1.3.4. Two of ' CV-4309 and CV-the valves (CV-4309 and CV- 4310 in ITS 4310) listed in the CTS are 3.6.1.3 Bases-SR not identified in the ITS 3.6.1.3.4.

3.6.1.3 Bases - SR 3.6.1.3.4.

4 1

DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ASOLATION VALVES (PCIVs)

ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COP 9fENTS NO. - JFD- LCO. OFENED CLOSED 3.6.1.3-6 L.1 CTS 3.7.B.2 CTS 4.7.A.I.b specifies the 7/8/97 Delete this P.4 CTS MSIV leakage li:::its and generic change.

Bases 4.7.A.I.b remedial actions to take upon P.3 STS 3.6.1.3 discovery of leakage rates ACTION D and exceeding specified limits.

Associated CTS 3.7.8.2 provide additional 8ases operability requirements, .

l ITS 3.6.1.3 remedial actions and ACTION D and associated times in which to Associated complete the repairs and Bases retests associated with CTS 4.7.A.I.b. The repair time per CTS 3.7.B.2 is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

ITS 3.6.1.3 Condition D changes STS 3.6.1.3 Condition D from " Secondary containment bypass leakage rate not within limit to "One or more penetration flow paths with one or more MSIVs not within leakage limits." Based on STS B.3.6.1.3 Bases RA D.I discussion, STS 3.6.1.3 Condition D includes both secondary containment and MSIV leakage. Therefore, the proposed change to Condition D is acceptable. However, the change of the Completion Time associated with RA D.1 and CTS 3.7.B.2 from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to an ITS time of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months is not adequately justified. The justification used is consistency with the Completion Time of RA 5

1

DAEC ITS 3.6.1.3 PRIMARY CONTAIMENT ISOLATION VALVES (PCIV2)

ITEM . DOC / - . CTS /STS. DESCRIPTION OF ISSUE lDATE DATE COMENTS NO. JFD- LCO -

OPENED CLOS 9 ,

A.1 and that generic change BWR 15 C.4 was not fully I

implemented. The staff never

- approved BWR 15 C.4. The Completion Time associated with ITS 3.E.1.3 RA D.1 takes into account the safety significance of containment

' leakage versus valve inoperability. Thus the STS Completion Time for leakage is i j l t less than the Completion Time ; i i 1

for an inoperable MSIV. In 1

(

addition, the staff finds this j change to be generic and J beyond the scope of review for i l l l 1 ! a conversfon. ) i \ \

I i

1 6

DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (FCIVs)

ITEM DOC /. CTS /STS DESCRIPTION OF ISSUE DATE DATE COMENTS NO. JFD LCO CPENED CLOSED 3.6.1.3-7 L.2 CTS CTS 4.7.A.I.c requires purge 7/8/97 l Either modify P.25 4.7.A.I.c system isolation valve leakage i ITS SR 3.6.1.3.4 Bases ITS SR testing at least once every arrd its P.8 3.6.1.3.7 three months. STS SR Associated and 3.6.1.3.7 requires leakage Bases to conform Associated testing every 184 days and to the frequency

Bases once within 92 days after specified in CTS opening the valve. ITS SR ITS SR 4.7.A.I.c or to 3.6.1.3.4 3.6.1.3.4 relaxes the CTS both the and testing requirement to every frequencies Associated 184 days and deletes the STS specified in STS Bases testir.; requirement of once SR 3.6.1.3.7 and within 92 days after opening its Associated the valve. STS B3.6.1.3 Bases Bases. Provide SR 3.6.1.3.7 states the staff additional position that the 92 day discussion and frequency was chosen justification recognizing that cycling the for these valve could introduce changes.

additional seal degradation, beyond that which occurs to a valve that has not been opened. Thus, decreasing the STS interval of 184 days is a prudent measure after a valve has been opened. The justification used (L.2) to relay the 3 month testing requirement to 184 days states that the vent / purge valves are cycles at least once per week to maintain consistent stroke -

times of the valves with Bettis actuaturs. Based on this and a connitment made to leak test the valves on a l 7

DAE0 ITS 3.6.1.3 PRIMARY CONTAINMENT VSOLATION VALVES (PCIVs)

ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE CDPr.ENTS NO. JFD LCO OPENED' LLOSED 3 month frequency (stated in the SE for Amendsent 219 dated October 4, 1996), the staff

. finds that the frequency '

changes made in ITS SR 3.6.1.3.4 when converting from CTS 4.7.A.I.c and STS SR 3.6.1.3.7 are unacceptable.

3.6.1.3-8 L.8 ITS SR A Note is added to ITS SR 7/8/97 Delete this P.31 3.6.1.3-7 3.6.1.3.7 which allows not change.

Bases and entering the appropriate P.8 Associated system Required Actions when

, Bases performing a Surveillance Requirement on these systems.

This Note is not included in the CTS or STS. The i justification addresses previous communication to the NRC staff in letter DAEC GL 80-10 Motor-Operated Valve r DV) Program (J. Franz (IES) t; W. Russell (NRC), " Generic Letter 89-10 Program," NG 4017, November 30,1994). The staff's position is that if a surveillance test makes the system inoperable or puts the system into an alignment that is not a normal or emergency operational alignment, then the system is considered inoperable and the appropria',e ACTIONS shall be taken.

8

@Gwwv W

DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs) {

M ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COMMENTS .

NO. JFD LCO OPENED CLOSED 7<,

3.6.1.3-9 LCY.2 CTS CTS 4.7.B.I.a requires 7/8/97 Delete this f 4.7.B.I.a performing testing of the change. I?

CTS 4.7.C PCIVs at least once per ITS SR operating cycle. Under the 3.6.1.3.6 same circumstance ITS SR ITS SR 3.6.1.3.6 requires testing 3.6.1.3.7 every 24 months. CTS 4.7.C and requires verifying, once per Associated operating cycle, the Bases operability of the reactor I coolant system instrument line flow check valves. Under the same circumstances ITS SR 3.6.1.3.7 requires this verification every 24 months.

This extension of the Surveillance frequency is considered by the staff as a beyond scope of review item for this conversion.

3.6.1.3-10 P. 21 ITS 3.6.1.3 The renumbering of ITS 3.6.1.3 7/8/97 See Item Numbers Bases and SRs and references to 3.6.1.3-4 and P.8 Associated succeeding specifications will S3.6.1.4-1.

Bases depend on the resolution of Item Numbers 3.6.1.3-4 and S3.6.1.4-1.

3.6.1.3-11 P.52 STS SR STS SR 3.6.1.3.6 and 7/8/97 Licensee to Bases 3.6.1.3.6 Associated Bases has been update submittal P.8 and modified by TSTF 46 Rev 1. with regards to Associated ITS SR 3.6.1.3.3 and its TSTF 46, Rev 1.

Bases Associated Bases as stated in ITS SR P.52 has been modified to be 3.6.1.3.3 consistent with TSTF-46. The and changes to ITS SR 3.6.1.3.3 Associated and its Associated Bases are Bases not consistent with TSTF-46.

9 r

DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE C0ftfENTS NO. JFD LCO OPENED CLOSED 3.6.1.3-12 Bases STS B3.6.1.3 STS B3.6.1.3 Bases-LCO states 7/8/97 Provide P.1 Bases-LCO that the valves covered by additional ITS B3.6.1.3 this LCO are listed with their discussion and Bases-LCO associated stroke times in the justifications ITS B3.6.1.3 FSAR (Ref. 2). ITS B3.6.1.3 for listing Bases- Bases-LCO states that the list these PCIVs in REFERENCES is in plant administrative Administrative control procedures and Procedures implies, based on the changes rather than the made, that no stroke times are FSAR, include provided in those procedures. the procedures The specific procedures are or FSAR location -

not specified or listed in ITS in ITS B3.6.1.3 B3.6.1.3 Bases- REFERENCES Bases-REFERENCES Section nor is the procedure Section and the change control process procedure change defined. Also, the location control process.

of the PCIV stroke times is Also provide required for reference to the document that satisfactory perfonnance of lists the PCIV ITS SR 3.6.1.3.3. stroke times as well as the document change control process and reference it in ITS B3.6.1.3.

Provide additional discussion and justification as necessary.

10 i ._ _ _ _ - - _ _ _ -

DAEC ITS 3e6.1.3 PRIMARY CONTAIMIENT ISOLATION VALVES (PCIVs)

-ITEM .- DOC /. CTS /STS- DESCRIPTION OF ISSUE- DATE DATE . CONIENTS NO. JFD ~ LCO OPENED CtOSED' 3.6.1.3-13 Bases STS 83.6.1.3 STS B3.6.1.3 Bases--SR 7/8/97 Provide P.1 Bases- 3.6.1.3.10 states the additional SR following for excess flow discussion and 3.6.1.3.10 check valves: "The [18] month justification to ITS B3.6.1.3 Frequency is based on the need justify the i Bases to perfom this Surveillance sentence SR 3.6.1.3.7 under the conditions that deletion based apply during a plant outage on current

. and the potential for an licensing basis, unplanned transient if the system design or Surveillance were performed operational with the reactor at power." constraints.

ITS B3.6.1.3 Bases-SR '

3.6.1.3.7 deletes this statement. The justification used (Bases P.1) is the general plant specific nomenclature, system ;

description, etc.,

justification, which is inadequate to justify this deletion.

I d

11

DAEC ITS 3.6.le3 PRIMARY CONTAIMENT ISOLATION VALVES (PCIVs)

ITEM. DOC /~ CTS /STSL DESCRIPTION OF ISSUE DATE- DATE CDPMENTS-NO. JFD LCO OPENED CLOSED 3.6.1.3-14 Bases STS SR The Bases for STS SR 7/8/97 Add Note to ITS P.1 3.6.1.3.13 3.6.1.3.13 refers to a Note 1 SR 3.6.1.3.13 and while STS SR 3.6.1.3.13 does and retain Bases

. Associated not show a Note. Therefore, description of Bases the Bases discussion on the Note. Provide ITS SR Note was deleted from the ITS additional 3.6.1.3.9 SR 3.6.1.3.9. This is an justification and error. The Note should be and discussion Associated added to ITS SR 3.6.1.3.9 and to support this Bases the discussion retained in the change.

Bases. This Note deals with leakage limit applicability and is associated with ITS 3.6.1.3 ACTIONS Note 4. Also, BWR 16 C.5 corrected this error. This error has been corrected by TSB-13.

12

DAEC ITS 3.6.1.3 PRIlmRY CONTAIf91ENT ISOLATION VALVES (PCIVs) 1 ITDI L DOC /: CTS /ST$ DESCRIPTION OF ISSUE- 0 ATE - DATE CSBENTS NO. - - JFD ~ LCO' OPDED CLOSED 3.6.1.3-15' Bases STS B3.6.1.3 STS 83.6.1.3 Bases-LCD states 7/8/97 Provide P.2 Basts-LCO that the passive PCIVs or additional ITS B3.6.1.3 isolation devices covered by discussion and

. Bases-LCO STS LCO 3.6.1.3 are listed in justification ITS B3.6.1.3 the FSAR (Nef 2). ITS for listing Bases- 83.6.1.3 Bases-tCO modifies these isolation REFERENCES this statement by adding after devices in more

( " Reference 2* "or in than one applicable administrative document rather procedures." The than just the justification used (Bases P.2) FSAR, include is a general clarity the procedures justification. This in ITS B3.5.1.3 justification is incorrect for Bases-REFERENCES this change. The specific Section and

- procedures are not specified provide the or listed in ITS B3.6.1.3 procedure change Bases-REFERDICES Section nor control process.

is the procedure change control process defined.

3.6.1.3-16 Bases- ITS 33.6.1.3 ITS B3.6.1.3 Bases ACTIONS 7/8/97 Delete this P.2 Bases- adds additional statements to generic change.

ACTIONS the ACTI0lIS Note 1 description stating that IIote 1 expands upon the allowance of LCO 3.0.5. The justification used (P.2) is.the general clarity justification. The addition does not clarify Note.1 and the change would be considered by the staff as a generic change which is a beyond the scope of review item for this conversion.

13

DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

ITEM DOC / CTS /STS DESCRIPTION OF ISSUE DATE DATE COPMENTS NO. JFD LCO OPENED CLOSED 3.6.1.3-17 Bases STS B3.6.1.3 STS B3.6.1.3 Bases RA C.1 and 7/8/97 Delete this P.2 Bases- C.2 states the following: "In generic change.

RA C.1 and the event the affected

. C.2 penetration flow path is ITS 83.6.1.3 isolated in accordance with Bases- Required Action C.I, the RA C.1 and affected penetration must be C.2 verified to be isolated on a periodic basis. This is necessary to ensure that primary containment penetrations required to be isolated following an accident are isolated." ITS B3.6.1.3 Bases RA C.1 and C.2 revised the wording of these sentences for clarity (Bcses P.2) and requires a system walkdown to verify isolation. The modification does not clarify the STS wording and the addition of the system walkdown imposes an additional requirement that is not justified nor imposed on Conditions A, B, or E. . The staff considers this change to be a generic change which is a beycad scope of review item for this conversion.

14

DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION 'JALVES (PCIVs)

ITEM " DESCRIPTION OF ISSUE DATE DATES COMENTS DOC /- CTS /STS NO. JFD.' LCO OPENED CLOSED 3.6.1.3-18 ~4ases ITS B3.6.1.3 ITS B3.6.1.3 Bases-RA E.I, E.2 7/8/97 Delete this P.2 Bases- and E.3 adds the following: change.

RA E.1, E.2 "If the results of a combid -

. and E.3 leak rate or pressure __.,p test indicate exces",1ve leakage, credit c.n be taken for one of the purge valves to satisfy Required Action E.1, if it can be reasonable determined that only one of the purge valves is leaking excessively." This statement was added for clarity (Bases P.2); however, it does not clarity anything that is already written in the Bases and could be misinterpreted to allow the lecking valve to be used for the isolation requirement of RA E.1. The change is unacceptable.

3.6.1.3-19 None ITS B3.6.1.3 See Ites Number 3.6.1.1-4. 7/8/97 See Item Number Bases- 3.6.1.1-4.

SR 3.6.1.3.4 15

DAEC ITS 3.6.1.3 PRIMARY CONTAINMENT ISOLATION VALVES (PCIVs)

-ITEM DOC / CTS /STS- DESCRIPTION OF ISSUE. DATE DATE CDPMENTS NO.- JFD LCO OPENED CLOS!D 3.6.1.3-20 None CTS 3.7.B.1 CTS 3.7.8.1 requires all 7/8/97 Provide a ITS LCO primary containment isolation discussion and 3.6.1.3 valves (PCIV) and instrument justification and line flow check valves for this Less Associated OPEPABLE except when a PCIV is Restrictive Bases inoperable and the affected change of the flow path is isolated. ITS ITS exception 3.6.1.3 requires each PCIV, of the reactor except reactor building-to- building-to-suppression chamber vacuum suppression breakers, to be OPERABLE. chamber vacuum There is no discussion or breakers CTS justification for excepting requireseats.

reactor building-to-suppression chamber vacuum breakers from ITS LCO 3.6.1.3 when it is required by CTS 3.7.B.I.

16

DAEC STS 3.6.1.4 DRYWELL PRESSURE ITEM' LOC / ' CTS /STS. DESCRIPTION OF 1SSUE DATE- DATE- COMOETS .

ND. JFD LCO OPENED CLOSED S3.6.I.4-1 P.2 STS STS 3.6.1.4 Drywell 7/8/97 Provide 3.6.1.4 Pressure, is deleted from Bases justification for P.3 and the ITS. The ITS is the STS deviation

- Associated renumbered such that ITS based on current Bases 3.6.1.4 is Drywell Air licensing basis, Temperature. The discussion system design, or and justification for operation deleting the Drywell constraints, or Pressure STS requirement retain the STS does not address the current 3.6.1.4 and ,

i licensing basis, system Associated Bases.

design, or operational constraints. The justification is based on a recent GE evaluation on drywell pressure. The justification used virtually the same words as Brunswick and Browns Ferry for deleting this requirement from their respective amendments. The only difference between the DAEC justification and their justification is the reference to a GE Report-NEDC - 32466P Supplement 1.

This report has not been reviewed and approved by the staff. Therefore, the justification based on this report would constitute a generic change to the STS and would be beyond the scope of review for a conversion.

I

DAEC ITS 3.6.1.4 DRYWELL AIR TEMPERATURE I

ITEM; DOC /. CTS /STS DESCRIPTION OF ISSUE- DATE DATE COMENTS NO. JFD LCO E OPENEC ,2LOSED 3.6.1.4-1 P.21 ITS The renumbering of ITS 7/8/97 See Ites Number Bases 3.6.1.4 3.6.1.4 and succeeding 53.6.1.4-1.

P.8 and specifications will dep m!

. Associated on the resolution of Item Bases Number 53.6.1.4-1.

i I

l 2

DAEC ITS 3.6.1.5 LOW-LOW SET (LLS) VALVES ITDI DOC /; CTS /STS- DESCRIPTION OF ISSUE DATE DATEi ColetENTS L NO. JFD' LCO- ~ -

OPENED CLOSED - -

3.6.1.5-1 A.3 CTS 4.6.D.1 CTS 4.6.D.1, CTS 7/8/97 Provide the A.4 CTS 4.6.D.2 4.6.D.2 and CTS appropriate A.5 DTS 4.6.D.4 4.6.D.4 specify discussions and

R.1 various justifications for l surveillances, the disposition of inspections, and these CTS tests to be performed requirements in the on the safety relief CTS /ITS markups of valves. The CTS ITS 3.6.1.5.

markup shows that these surveillance requirements are associated with ITS 3.4.3. The staff's review concludes that -

they also apply to ITS 3.6.1.5 as well, but the '

justifications A.3, A.4, A.5 and R.1 are not provided in JTS 3.6.1.5. !

1

DAEC ITS 3.6.1.5 LOW-LOW SET (LLS) VALVES ITEM; DOC /. CTS /STS DESCRIPTION.OF ISSUE- DATE. DATEL COIMENTS NO. JFD .LCO OPENED CLOSED-

3.6.1.5-2 M.2 ITS LCO CTS 4.2.B.Z.g and CTS 7/8/97 Provide a rarkup for 3.6.1.5 4.6.D.3 contain SRs CTS 3.6.D.1 and CTS ITS 3.6.1.5 for the LLS valves. 3.6.D.2 and provide APPLICABILITY M.2 states that the the appropriate ITS 3.6.1.5 CTS does not contain Administrative (A),

ACTIONS specific LCO, More Restrictive (M)

APPLICABILITY or or Less Restrictive ACTIONS for the LLS (L) change

, valves. This is discussions and incorrect. No M.2 is justifications to shown in the markup convert these CTS of CTS 4.2.8.2.g or requirements to the CTS 4.6.D.3 which ITS requirements of corresponds to this ITS 3.6.1.5.

change. The only M.2

. shown applies to ITS SR 3.3.8.1.5.

However, CTS 3.6.D.1 and CTS 3.6.D.2 do contain the specific LCO, APPLICA8ILITY and ACTIONS for the LLS valves.

+

2 i ._. ._ _ - _ _ _ - _ - _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ .. _

DAEC ITS 3.6.1.5 LOW-LOW SET (LLS) VALVES i

ITEM . DDC/ CTS /STS. DESCRIPTION OF ISSUE: DATE DATE CopelENTS JFD 7 CLOSED NO.- LCO ' OPENED - ,

3.6.1.5-3 LCY.2 CTS 3.6.0.3 CTS 3.6.D.3 requires 7/8/97 Delete this change.

Bases CTS 4.2.8.2.g the manual opening of P.8 ITS SR each relief valve

. 3.6.1.5.1 once per operating ITS SR cycle. CTS 4.2.B.2.g l 3.6.1.5.2 and requires Logic System i i Associated Functional Tests

Bases (LSFT) once per 1 operating cycle for -

8 the Low-Low Set l Function. Under the same conditions the ITS SR 3.6.1.5.1 and ITS SR 3.6.I.5.2 have a Frequency of 24 months. This extecsion of the Surveillance Frequency is I considered by the staff as a beyond scope of review ites for this conversion.

3.6.1.5-4 P.21 ITS 3.6.1.5 See Ites Number 7/8/97 See Item Number Bases and Associated 3.6.1.4-1. 3.6.1.4-1.

P.8 Bases 3

DAEC ITS 3.6.1.5 LOW-LOW SET (LLS) YALVES ITEMi 4 DOC / CTS /STS- DESCRIPTIOR 9F ISSUE- DATE- DATE . ComENTS -

I NO.: ' JFD. -

LCO' ' OPENED CLOSED 3.6.1.5-5 ) Bases CTS 3.6.D.3 CTS 3.6.D.3 specifies 7/3/97 Provide a discussion P.1 ITS B3.6.1.5 that the LLS valves and justification for Bases- shall be manually this More Restrictive

, . SR 3.6.1.5.1 tested when reactor change in test pressure is 2 100 pressure.

psig. ITS B3.6.1.5

!! Bases-SR 3.6.1.5.1 ll states that this same l; test cannot be perforised until the

reactor pressure is 2 ':

150 psig. No justification is provided for this More Restrictive

, change from 100 psig to 150 psig.

4

GAEC ITS 3.6.1.6 REACTOR BUILDING-TD-SUPPRESSION CHAMBER VACUUM BREAirERS ITEM. x DOC /- CTS /STS- _ DESCRIPTION OF. ISSUE E DATE i DATE ;-lI 4TS '~

NJ.. . JFD! LCD: ' -

OPENE0 CDSED "- U 3.6.1.6-1 A.4 ITS SR Two Notes are added to ITS 7/8/97 Provide

! 3.6.1.6.1 SR 3.6.3.6.1 which state, additional that the SR is not discussion and

! required to be met for ,

justification 8

vacuum breaker assemblies for the i.ets

~! that are open for. ,

Restrictive i Surveil?ances and not change.

i nqu'. red to be nei 'or ;

i vacuum assembly valves l open for their intended

,' function. These Notes are not included in the CTS. l There is inadequate discussion and justification for these Less Restrictive exceptions to the CTS SR.

3.6.1.6-2 A.4 ITS SR Two Notes are added to ITS 7/8/97 Correct A.4 to 3.6.1.6.1 SR 3.6.1.6.1 which state delete the ITS SR that the SR is not reference to 3.6.1.6.3 required to be met for ITS SR certain conditions. A.4 3.6.1.6.3.

states that both of these -

. Notes apply to ITS SR -

3.6.1.6.1 and SR 3.6.1.6.3. This is incorrect. The Notes only apply to ITS SR 3.6.1.6.1.

I

DAEC ITS 3.6.1.6 REACTOR BUILDING-TO-SUPPRESSION CHAMBER VACUUM BREAKERS ITEM ' '

DOC /- '

CTS /STS;' DESCRIPTION OF: ISSUE DATE DATE . Cof9 TENTS s NO.' JFD- LCO OPENED CLOSED-3.6.1.6-3 M.1 CTS 3.7.D.3 CTS 3.7.D.3 requires, when 7/8/97 Provide a P.32 ITS 3.6.1.6 a vacuum breaker assembly discussion and Bases ACTION A valve is open, that the justification P.1 and Associated other valve in the for the s' Bases assembly be verified deletion of closed within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . the CTS

, M.1 reduces the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to requirement to I hour to be consistent verify the with the time provided for othe valve is when primary containment closed within is not maintained. ITS 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

3.6.1.6 ACTION A does not include this CTS requirement, in either form.

2

DAEC ITS 3.601.6 REACTOR SUILDING-TO-SUPPRESSION CHAMBER VACUUM 8REAKERS

~

ITEM h+M DOC / - CTS /STSI- DESCRIPTIONOFIISSUEI DATE:. DATE? . Cof9 TENTS 30 6 - r.g .JFDE LCO ' ' 1 ,2 OPDIED CLOSED 4

3.6.1.6-4 M.1 CTS 3.7.8.3 CTS 3.7.D does not contain 7/8/97 Prcvide P.32 CTS 3.7.D.3 ITS specific Required Action discussion and

- Bases 3.6.1.6 ACTION for when one or two justification j P.1 8 and reactor building-to- for the Less l Associated suppression chamber vacuum Restrictive

, Bases breaker assemblies have requirement

! both valves not closed. when both l- One can assume that an reactor

! limmediate shutdown would building-to-l be required either by CTS suppression 3.7.8.3 or CTS 3.7.D.3. chamber vacuum ITS 3.6.1.6 RA 8.1 breaker requires closing one open assemblies

vacuum breaker assembly valves are not valve within I hour when closed. See one or two reactor Ites Number building-to-suppression 3.6.1.6-3.

chamber vacuum breaker assemblies have both valves not closed. There ,

is no discussion or justification for the new requirement when both reactor building-to-suppression chamber vacuum breaker assemblies valves

~

are not closed. However, M.1 seems to apply here, but M.1 talks about when one valve is open. See Item Number 3.6.1.6-3.

3

DAEC ITS 3.6.I.6 REACTOR BUILDING-TG-SUPPRESSION CHAMBER VACUUN BREAKERS ITEN) $2bDCC/. u- CTS /STS': DESCRIPTION OF-ISSUE 1 ~

DATE' . DATE'- ColmENTSL LCO ' J

~

NO.m JFO' OPENED CLOSED I 3.6.1.6-5 L.3 CTS 3.7.D.4 CTS 3.7.D.4 and 4.7.D.2 7/8/97 Provide l ~

CTS 4.7.D.2 provide ACTIONS and -

additional j i Survelliance Requirement discussion and

.- for the Reactor Building- justification j to-Suppression Chamber for the Vacuum Breaker position procedure and j

, indication policy change i'

instrumentatio.1. Position control indication instrumentation process.

l 1s moved to plant i procedures and policies.

.' There is no discussion or

! Justification of the i specific procedure or

policy and how changes to these procedures and policies are controlled.

This change is considered

- by the staff as a less Restrictive (LA) change.

4

DAEC ITS 3.6.1.6 REACTOR BUILDIM-TO-SUPPRESSION OUWWER VACULM BREAKERS

^

LITEMIl 14; - DOC /i CTS /STS -

DESCRIPTION OF) ISSUE 9 DATEi - DRIE : CtNSENTS No. ' " "

M >> ^

~

l.C0 * -

^

OPDED CLOSED >

3.6.1.6-6 L.4 CTS 4.7.0.2 CTS 4.7.D.2 requires 7/8/97 Delete this P.42 STS SR quarterly demonstrations generic

Bases 3.6.1.7.2 and that the Reactor Building- change.

. P.8 Associated to-Suppression Chanber

! Bases Vacuum Breaker valve i ITS SR travels through one

3.6.1.6.2 and complete cycle of full

! Associated travel. STS SR 3.6.1.7.2

Bases requires performing a functional test of each vacuun breaker every [92]

days. ITS SR 3.5.1.6.2 extends this testing by j changing the frequency

- fres "once per quarter"/92 days to "In Accordance j with the Inservice Testing Program" which allows up to six months depending on previous testing performance. This extension of the CTS /STS Survelliance Frequency from once per quarter to once per 6 months is considered by the staff to be a generic change which is a beyond scope of review item for this conversion.

S

..v.__ _ . _ . _ _ _ _ _ _

DAEC ITS 3.6.1.6 REACTOR BUILDING-TO-SUPPRESSION CHAMBER VActPJN BREAKERS iITE'%^-

I'i DOC / ! - CTS /STSi DESCRIPTIONOff1SSUE?

DATE 1- DATE,J 'CometTS JFD.'# -w LCO:'

N04: - , e -

OPENED CLOSED- -

i 3.6.1.6-7 LIC.2 CTS 4.7.D.3 CTS 4.7.D.3 requires once 7/8/97 Delete this

.! Baus ITS SR per quarter demonstrating change.

> P.14 3.6.1.6.3 and that the setroint of each l: -

Associated vacuum breaker is

-l ! Bases equivalent of 59.5 psid.

j' j Umfer the same dI circumstances ITS SR lj 3.6.1.6.3 requires every ij! 12 months. This extension

'! of the CTS Surveillance q Frequency is based on 1 Generic Letter 91-04 which

.j only applies to increasing 4

the SR frequency from 18 months to 24 months. In addition, this change is considered by the staff to

! be a beyond scope of review item for this

. conversion.

3.6.1.6-8 P.21 ITS 3.6.1.6 and See Item Number 3.6.1.4-1 7/8/97 See Item Bases Associated Number P.8 Bases 3.6.I.4-1.

6 l _______ _ _

DAEC ITS 3.6.I.6 REACTOR BUILDING-TO-SUPPRESSION O W BER VACUUM BREAKERS ITEM- #

DOC /$ % CTS /STS0 J' DESCRIPTION OFJISSUE" DATE " DATE . Co mENTS-N01- w JFD : -* LCDi ~ ~

OPDED CLOSED- : -. <

3.6.I.6-9 Bases STS B3.6.I.7 STS B3.6.I.7 Bases- 7/8/97 See Ites f; P.2 Bases- APPLICABILITY states that Number APPLICABILITY the vacuum breakers are 53.6.2.4-I. .

l -

ITS B3.6.I.6 required DPERABLE in MODES

' Bases- I, 2,and 3 '

'l APPLICABILITY *

...when the Suppression Pool Spray System is

. required to be OPERABLE."

, ;i ITS B3.6.I.6 Bases-

! APPLICABILITY changes this ,

, to "...when Suppression Pool Spray System '

.j operation may be -

+; desirable." The acceptability of this

. change is dependent on the

' resolution of Item Number S3.6.2.4-1.

c l

i 7

DAEC ITS 3.6.I.6 RFJh' ORTBUILDING-TO-Sb7PRESSION CHAMBER VACUUN BREAKERS DESCRIPTIONOFLISSUE;2 DATE'. 1 00C/i# .

ITEM / CTS /STSi DATE 'ColWENTS N0;- ~'- JFD " LCO

. 1 OPENED CLOSED - -

3.6.I.6-10 None CTS 3.7.D.2 CTS 3.7.D.2 identifies the 7/8/97 Provide ITS 3.6.1.J required actions if one additional

ACTION C and valve of a reactor discussion and Associated building-to-suppre: sion justification i Bases chamber vacuum breaker for this

{; assembly is inoperable for Administrative 9

- opening but known to be change of

'! -closed. ITS 3.6.1.6 ACTION C requires removing the CTS j' 'I restoring the vacuum requirement

I breaker to OPERABLE status that the

! within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for ons vacuum breaker be known li ; reactor building-to-suppression chamber vacuum closed.

l; breaker assembly with one or two valves inoperable j for opening. ITS 3.6.1.6

ACTION C does not assrae knowing the inoperable vacuum breaker is closed not does the ITS 83.6.1.6 Bases RA C.I. There is no discussion or !

Justification for this Administrative change of .

removing the CTS requirement that the vacuum breaker be known closed.

8

DAEC ITS 3.6.1.7 SUPPRESSION CHAMBER-TO-DRYWELL VACULM BRENCUtS t

ITDF t N0;' % "2 DOC /*-e ; ' CTS /STSJ '

KD M ~ LCO ' ' ~

~

- DESCRIPTION OFjlSSUE ,'

~

'~ > v- ~

DATE Y

OPOED~

._ DATFs -

CLOSED' Cof91ENTS

'e

I '

3.6.1.7-1 A.2 ITS SR A Note is added to ITS SR 7/8/97 Provide 3.6.1.7.1 3.6.1.7.1 which states additiwal

i L and that the SR is not discussion and

.! . Associated required to be met for justification for

i Bases vacuan breakers that are the Less

!j open for Surveillances. Restrictive

This Note is not included t.hange.

'?; 4 la the CTS. There is i; inadequate discussion and l

Justification for this r Less Restrictive exception i

to the Surveillance ileautrement.

!lI

!! 3.6.1.7-2 A.2 ITS SR A Note is added to ITS SR 7/8/97 Correct A.2 to ,

3.6.1.7.1 3.6.1.7.1 which states, delete the t and that the SR is not reference to ITS Associated required to be met for SR 3.6.1.7.3.

Bases vacuan breakers that are 4 open for Surveillances.

A.2 states that the Note applies to ITS SR 3.6.1.7.1 and ITS SR 3.6.1.7.3. This is-incorrect. The Note only applies to ITS SR 3.6.1.7.1.

I

DAEC ITS~3.6.1.7 SUPPRESSION CHAMBER-TO-DRYWELL VACUUN BREAKERS

ITEM!W $ DOC /hp CTS /STS)s W ' DESCRIPTION OF; ISSUED > .

DATEh DATEh- COMENTS "

? -

N0hM9 0 "JFD* 4v $ ' LCOMG '

'* ~ '^

M 0*ENED CLOSED- 4 j 3.6.1.7-3 L.2 CTS 4.7.E.3 CTS 4.7.E.3 requires a 7/8/97 Provide

, visual inspection of.the discussion and drywell-to-suppressien justification on

. chambee vacuum breakers. how changes to j! Visual inspection of the the plant drywell-to-suppression procedures and i], chamber vacuum breakers is policies will be ji moved to plant procedures controlled.

ji_ and policies. There is no

~,

discussion or justification of the specific procedure or I' policy and how changes to these procedures and i

policies are controlled.

3.6.1.7-4 L.3 CTS 3.7.E.4 CTS 3.7.E.4 and 4.7.E.2 7/8/97 Provide

CTS 4.7.E.2 provide ACTIONS and a discussion and Surve111ance Requirement justification on for the suppression how changes to chamber-to-drywell vacuum the plant breaker position procedures and indication policies are instrumentation. Position controlled.

indication instrumentation -

is moved to plant procedures and policies.

There is no discussion or justification of the specific procedure or policy and how changes to these procedures and policies are controlled.

2

. - . . ~ - - . - . . - . . - . - . - . . . . - - . - . . - - - -. - - . - - = - - - - - - - . . - -

o

-i DAEC ITS 3.6.1.7' SUPPRESSION CHAMBER-TO-DRYWELL VACUUN BREAKERS-i' .

j, LITEM), 4 DOC /% . CTS /STSls DESCRIPTION DEISSUEP ^ w DATES J DATE/_ CONIENTSEa:-,

J; N0!v < "JFDi' - - LCO P '

. . ~

OPENED /^ CLOSED A +

i :

3.6.1.7-5 P.12 STS SR STS SR 3.6.1.8.1 requires 7/8/97 Delete this l, Bases 3.6.1.8.1 the vacuum breakers be generic change.

i P.9 ITS SR verified closed every 14

4- -

3.6.1.7.1 and days and after any ;

Associated discharge of steam or any ,

l Bases operation causing a vacuum j breaker to open. ITS SR i 3.6.1.7.1 deletes the !

,, ~

second frequency (steam or j i operational opening). The i

,I justification (P.12).

I

~; states that this frequency

'; is not needed since'ITS SR

.i 3.0.1 would not be met and

. appropriate actions taken. .!

The justification also states that if conditions i exist for the vacuum !

breakers to be potentially opened, control roon operators would be alerted t to the possibility and would ensure the vacuum breakers were closed at the completion of the evolution. The SR frest.;;y assures that this is done. The staff has determined based on i the justification that this is a generic change which is beyond the scope of review for this conversion. ;

i 3

I f

r

l

, DAEC ITS 3.6.1.7 SUPPRESSION CHAMBER-TO-DRYWELL VActTJi BREAKERS I

! ITEM; >

_ Doch - CTS /STS DESCRIPTION OP iSSUEi- DATE: . DATEL COPMENTS '

'^ # '

[ NO.- -

JFD LCO-OPEKED: CLOSED; 3.6.1.7-6 P.13 STS SR STS SR 3.6.1.8.2 requires 7/8/97 Delete this l Bases 3.6.1.6.2 a functional test of the generic change.

P.8 ITS SR vacuum breakers within 12 3.6.1.7.2 and hours of any discharge of Associated steam into the suppression

Bases chamber and following any

operation that causes the ,

!i vacuuc breaker to open.

i"1 ITS SR 3.6.1.7.2 deletes l !! .

these

i ,

) (

\

frequencies / conditions. l l l h

STS SR 3.6.1.8.2 covers all aspects of valve l l, opening including any ,

' other unexpected event i ' i I ' '

which would open the vacuum breakers. Thus, l the staff considers the proposed change as a t generic change and beyond ,

I-the scope of review for !

this conversion.

l 3.6.1.7-7 P.21 ITS 3.6.1.7 See Item Number 3.6.I.4-I 7/8/97 See Item Number t Bases 'and '

i 3.6.1.4-1.

P.8 Associated l Bases .

l l

l 4

4 I DAEC ITS 3.6.1.7 SUPPRESSION CHAMBER-TO-DRYWELL VACIRM BREAKERS

% CTS /STS L N:

^

LITEMl',4 00C/) - DESCRIPTION;0EllSSUEi DATEii DATE? COMENTS$ ,

NOS* W ?JFDf u LC0 5 > * ' ~ -

OPENED 3* CLOSED

- Aa 3.6.1.7-8 Bases STS 83.6.1.8 ITS B3.6.1.7 Bases- 7/8/97 See Ites Number P.1 Bases - APPLICABILITY makes a S3.6.2.4-1.

APPLICA8ILITY number of changes to the

- ITS B3.6.1.7 STS 83.6.1.8 Bases-

'r Bases' APPLICA8ILITY discussion.

APPLICABILITY The changes deal with the operation of the .

Containment / Suppression 1

'[ Pool Spray System. The acceptability of these changes will depend on the resolution of Item Number 53.6.2.4-1.

None ,STS SR STS SR 3.6.1.8.3 has a 7/8/97 Change the 3.f.1.7-9 Frequency of [18] months. Frequency for ITS 3.6.1.8.3 ITS SR ITS SR 3.6.1.7.3 changes SR 3.6.1.7.3 to 3.6.1.7.3 and the Frequency to 24 18 months.

t Associated months. Although this is Provide any Bases a bracketed item change, additional

the 24 month period is not discussion and in the current licensing justification as basis. The current necessary.

licensing buis Frequency for refueling outage frequencies is 18 months.

The change in SR Frequencies from 18 months to 24 months has already determined to be a beyond scope of review ites for this conversion.

5 l

_=

t DAEC ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE ITEM: ; DOC /! CThhTS! I DESCRIPTION OFi SSUE2 DATEI,. DATE? . COPWIENTS 4.

l NO.- JFD: LCOT ~

OPENED: CLOSED 1 -

a v

3.6.f.1-1 A.2 CTS CTS 3.7.G.2.b and 3.7.G.2.c requires 7/8/97 Provide P.27 3.7.G.2.b the plant brought to Hot Shutdown additional Bases CTS followed by Cold Shutdown if the discussion P.8 3.7.G.2.c suppression pool temperature is not and Justification

, ITS reduced to s 95"F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

3.6.2.1 ITS 3.6.2.1 RA B.1 requires THERMAL for this Less RA B.1 POWER be reduced to s 1% RTP within Restrictive 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The ITS ACTION of change. See reducing power to 5 1% is Less Item Numbers Restrictive than the CTS ACTION of 3.6.2.1-2 and bringing the plant to COLD SHUTDOWN. 3.6.2.1-3.

3.6.2.1-2 A.2 CTS CTS 3.7.G.2.a requires a maximum 7/8/97 Provide i P.27 3.7.G.2.a average suppression chamber additional i Base CTS temperature of 95"F during nomal discussion l

P.8 3.7.G.2.c power operation. CTS 7.G.2.c and ITS LCO requires a maximum average justification 3.6.2.1.a suppression chamber temperature of for this Less 3

i ITS LCO 105" during testing which adds heat Restrictive 3.6.2.1.b to the suppression chamber. ITS LCO change. See and 3.6.2.1.a requires ruppression poul Ites Numbers Associated average temperature is s 95'F with . 3.6.2.1-1, Bases THERMAL I'0WER > 1% RTP and 3.6.2.1-3, performing no testing that adds heat and 3.6.2.1-to the suppression pocl. ITS LCO 5.

3.6.2.1.b requires suppression pool average temperature s 105"F with THERMAL POWER > 1% RTP and testing that adds heat to the suppression pool. Add!ng a specific THERME POWER level limits to these CTS gds is a Less Restrictive change and was ;

inadequately discussed and i justified. See Item Numbers 3.6.2.1-1, 3.6.2.1-3, and 3.6.2.1-5.

1 l

l

________2_-

DAEC ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE i

DATE? +

!!TEMi DOC /f CTS /STS: DESCRIPTION 0FLISSUEh . DATE? CON 9ENTS'

, N0t~ - :JFD' LCO' ' > , OPENED- CtOSED

) 3.6.2.1-3 A.2 CTS CTS 3.7.G.R.a requires a maximum 7/8/97 Delete this P.27 3.7.G.2.a average suppression chamber generic l change. See i Bases CTS temperature of 95*F during nomal i P.8 3.7.G.2.b power operation. CTS 7.G.2.c Item Numbers CTS requires a maximum average 3.6.2.1-1, 3.7.G.2.c suppression chamber temperature of 3.6.2.1-2,

, STS LCO 105*F during testing which adds heat and 3.6.2.1-3.6.2.1 to the suppression chamber. STS LCO 5.

STS 3.6.2.1.a requires a suppression s !

3.6.2.1 pool average temperature be s 95'F ACTIONS when any OPERABLE intermediate range and monitor (IRM) channel is 2 25/40 Associated divisions of full scale on Range 7, Bases while STS LCOs 3.6.2.1.b and c ITS LCO require a suppression pool average i 3.6.2.1 temperature be s 105*F when any IRM ITS channel is 2 25/40 divisions on i 3.6.2.1 Range 7 and s 110*F when all IRM Condition channels are s 25/40 divisions on A Range 7. ITS 3.6.2.1 changes the ITS IRM criteria to 1% RTP. Both STS 3.6.1.1 B3.6.2.1 Bases-LCO and P.27 state RA B.1 that 1% RTP is not readily ITS quantified with much accuracy.

3.6.2.1 However, the Bases states that 25/40 Condition divisions of full scale on IRM Range C and 7 is a convenient measure of when Associated reactor is providing power Bases essentially equivalent to 1% RTP.

Since 1% RTP cannot be readily quantified with much accuracy the STS specifies an acceptable means to determine this. Therefore, the staff finds the ITS change unacceptable and generic. See Item Numbers 3.6.2.1-1, 3.6.2.1-2 and 3.6.2.1-5.

2 I

)e f g

DAEC ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TEMPERATURE 1 TEM S

'# 'bOC/g CTS)STSt"* ' DESCRIPTION'0F ISSUE? , _ 2[ DATE! - DATEM CofflENTS - -

"% ^ "- T ^

NO:n LC0 %

.JFD P - OPENED CLOSED t

3.6.2.1-4: L.1 CTS. . CTS 4.7.G.2.c requires an external 7/8/97 Provide

4.7.G.2.c visual inspection of the suppression additional chamber whenever there is indication discussion

- of relief valve operation with the and justifi-local suppression pool temperature cation to reaching 200*F or greater. L.2 shew that states that ITS 3.6.2.1 does not NEDO-30832 retain this CTS requirement in has been accordante with NEDD-30832, reviewed and

" Elimination of Limit on BWR approved by Suppression Pool Temperature for SRV the staff and Discharge with Quenchers," dated its December 1984. The discussion and applicability l Justification do not indicate if to DAEC.

! MEDD-30832 has been reviewed and approved by the staff. It also does not indicate its applicability to DAEC. This item may be considered a beyond scope of review item for this conversion.

3.6.2.1-5 None ITS LCO ITS 3.6.2.1.c requires suppression 7/8/97 Provide a 3.6.2.1.c pool average temperature s 110*F discussion and when THERMAL POWER 51% RTP. This and Associated More Restrictive requirement is not justification Bases addressed in the CTS. See Item for the More Numbers 3.6.2.1-2 and 3.6.2.1-3. Restrictive change. See item Numbers 3.6.2.1-2 and 3.6.2.1-3.

3

s. -.. .. .. .

DAEC ITS 3.6.2.1 SUPPRESSION POOL AVERAGE TENPERATURE j .

.. ITEM L - DOC /J- . CTS /STSJ DESCRIPTION OF ISSUE ,

.m DATE; DATEi- CormENTS-h'" 'JFD: 1.CO ' '

OPENED CLOSED--

g 3.6.2.1-6 None CTS CTS 3.7.G.2.e requires a 7/8/97 Provide a j 3.7.G.2.e depressurization of the reactor to discussion

ITS less than 200 psig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and

. 3.6.2.1 when the suppression pool average justification l

Condition temperature is > 120*F. ITS 3.G.2.1 for this Less E and Condition E requires the same Restrictive Associated required action when the suppression change.

Bases pool average temperature is > 120*F.

t. No justification is provided for the Less Restrictive change from "2-

, 120*F to > 120*F."

3.6.2.1-7 None STS STS B3.6.2.1 Bases-BACKGROUND lists 7/8/97 Correct this 83.6.2.1 four technical concerns that lead to discrepancy. .

Bases- development of the suppression pool BACKGROUND average temperature. ITS B3.6.2.1 ITS Bases-BACKGROUND only lists two B3.6.2.1 concerns. The "and" between the end Bases- of concern a. and the beginning of BACKGROUND concern b has inadvertently been deleted. _

^

4

DAEC ITS 3.6.2.2 SUPPRESSION POOL WATER LEVEL t

' ITEM l CTS /STS2 DESCRIPTION,0FilSSUE! DATE: DATE .. CONtENTSt^

l DOC /' '

N0;: '

JFD LC0t o. OPENED ~ CLOSED?

3.6.2.2-1 A.2 CTS CTS 3.7.G.I.a specifies 7/8/97 Correct ITS LCO P.43 3.7.G.I.a the volume of the 3.6.2.2 to specify Bases STS LCD suppression pool as level in terms of ft.

P.8 3.6.2.2 cubic feet and percent. Provide any additional ITS LCO ITS LCO 3.6.2.2 justification and 3.6.2.2 specifies the water discussion as and level as a volume in necessary for this Associated cubic feet, and the change.

Bases level is specified in the Bases as volume (ft 3) and level (ft).

STS LCO 3.6.2.2 only ,

specifies level in ft.

l The reason for this is a that the control room .

I indication of I- suppression pool water level is given in ft.

, not volume (ft'). The STS was written this way as a convenience for the operator and to avoid confusion.

Justification A.2 states that suppression pool water level indication in the control room is given in terms of level-ft, not volume. Therefore, the ITS change is unacceptable. The Bases can specify the level as well as the corresponding volume.

I

DAEC ITS 3.6.2.2 SUPPRESSION POOL WATER LEVEL

! : ITEM DOC /f CTS /8TS DESCRIPTION OF ISSUE: DATE DATE- N!_CotMENTS' Mo.q J -

.JFD :: LCO: -

OPENED CLOSED :

3.6.7. 2-2 P.43 STS LCO STS LCO 3.6.2.2 and its 7/8/97 Correct this deviation Bases 3.6.2.2 associated Bases from the writers 1 P.8 and specifies the guide. See Ites

! . Associated suppression pool water Number 3.6.2.2-I.

l Bases level as "1" or "s" i ITS LCO specified limits. ITS 3.6.2.2 LCO 3.6.2.2 and its

, and associated Bases

'! Associated changes "2" and "s" to l Bases " greater than or equal

! to" and "less than or l equal to",

! respectively. This

! change is not in accordance with the industry writer's guide l for TS conversions.

See Item Number 3.6.2.2-I.

2

DAEC ITS 3.6.2.3 RESIDUAL HEAT REMOVAL (RHR) SUPPRESSION POOL COOLING

ITEN -D06/if CTS /STSL~ 'DESCRIPTIdN DEISSUEi , DATEl f. DATEN. CormENTS' N0r- JFD' ' lCO E "s m - T . OPENED- CLOSED' 3.6.2.3-1 P.16 STS SR STS SR 3.6.2.3.1 requires verifying 7/8/97 Delete this Bases 3.6.2.3.1 each RHR Suppression Pool Cooling change.

.. P.8 ITS SR System manual, power operated, and l . 3.6.2.3.1 automatic valve in the flow path that

.; and is not locked, sealed, or otherwise i Associated secured in position is in the correct Bases position or can be aligned to the correct position every 31 days. Under the same conditions ITS SR 3.6.2.3.1 requires the same except the manual valves are deleted. The deletion is 1 unacceptable. The way the 3: specification and associated Bases is I

i written would allow verification of the valves position through use of a paper verification rather than a system walkdown as is required by the PWR STS*. Therefore, since this is a new s' _cification for DAEC and a paper verification is feasible based on the justification (P.16), the staff requires that the manual valves be verified in the correct position.

3.6.2.3.2 P.21 ITS The renumbering of ITS 3.6.2.3 ACTIONS 7/8/97 See item Bases 3.6.2.3 will depend on the resolution of Ites Number P.8 ACTIONS Number 3.6.2.3-3. 3.6.2.3-3 and Associated Bases 1

DAEC ITS 3.6.2.3 RESIDUAL HEAT REMOVAL (RHR) SUPPRESSION POOL COOLING jjTE i F fb N/Il~ UN/5iNED DESCRIPTION 'DATE M ~ DOE W C'0 mutts ? 1 Nok 44 fJFD W LCO N N ^E } OF}ISSUEE J'~Y EJ N W N*

*P OPDIED CLOSED ~ - a ~- -

! 3.6.2.3-3 P.34 STS STS 3.6.2.3 ACTION 8 requires a 7/8/97 Delete this

! Bases 3.6.2.3 shutdown if the ras and associated generic

.~ l* P.8 ACTION 8 Completion Times are not met and for change.

.. ITS two RHR Suppression Pool Cooling 3.6.2.8 subsystems inoperable (loss of i, ACTIONS D function). ITS 3.6.2.3 breaks STS and E 3.6.2.3 ACTION 8 up into two ACTIONS -

ACTION D - two subsystems inoperable 1

(loss of function) and ACTION E- ras J and Competion Times not. met. ACTION D l; instead of requiring a shutdown per

l the STS, requires the restoration of

!; one RHR subsystem to OPERABLE status ii within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The justification l' used (P.34) states that the time is consistent with time provided in NUREG-1433 when both RHR service water (RHRSW) subsystems are inoperable.

.' This is not totally correct. The Bases for the RHRSW states that the time is consistent with both the RHR Suppression Pool Cooling and RHR Suppression Spray. However, only the spray systen has the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months loss of function restoration based on the fact that there is alternate means of cooling containment. This is not true in this -

case. In this case, the staff finds that total loss of RHR Suppression Pool Cooling requires an immediate shutdown. Therefere, the change is unacceptable and is considered a generic chage that is beycnJ the scope of review for this conversion.

2

DAEC ITS 3.6.2.3 RESIDUAL HEAT REMOVAL (RHR) SUPPRESSION POOL COOLING liENk[

> DOC [OCTS /STS? DESCRIPTION 0F.lISSUEb _ , ~ < 'rJ

DATE5n DATEls. CON?ENTS-2 li NOL ";H .JFD & LCOi lJ1 ^

OPENED CLOSED

3.6.2.3-4 Bases STS STS B3.6.2.3 Bases - RA A.1 states the 7/8/97 Correct this

,;, P.1 B3.6.2.3 following: "In this Condition, the discrepancy.

j Bases- remaining RHR..." ITS B3.6.2.3 Bases-

i .. RA. A.1 RA C.I decapitalizes the letter "C" in

! ITS " Condition". This is incorrect. The ll B3.6.2.3 sentence is referring to Condition C;

! Bases- thereTore, the "C" in Condition" 4: RA C.1 should be capitalized.

'I. 3.6.2.3-5 Bases ITS ITS B3.6.2.3 Bases SR 3.6.2.3.1 is 7/8/97 Delete this i P.17 B3.6.2.3 clarified by a number of statements change.

Bases- (Insert 2) which allows the valves to SR be mispositioned for survelliance 3.6.2.3.1 testing and other approved operating system configurations. While the

~

wording of the STS/ITS allows for the

. various sy; tem operating l

configurations, it does not al"ow for

. realignments due to surveillance i tests. The staff's position is that if surveillance tests put the system into an alignment that is not a normal or emergency operational alignment then the system is considered inoperable and the appropriate ACTIONS shall be taken. 1

. 3

DAEC STS 3.6.2.4 RESIDUAL HEAT REMOVAL (RHR) SUPPRESSION POOL SPRAY .

ITd po; ~ f @W . DOC /[9 '

CTS /STS1~

a DESCRIPTION OF ISSUEC A

DATE!. DATEh CoretENTS :

sJFD E LCO

' s OPENED CLOSED: -

.f S3.6.2.4-1 P.17 STS CTS 3/4.5.8 " Containment 7/8/97 Include CTS lj Bases 3.6.2.4 Spray Cooling Capability" 3/4.5.8 in ITS

P.8 and specifies the suppression 3.6. Provide r .. Associat'ed pool and drywell spray additional i l1 Bases MODES of the RHR System discussions and OPERABILITY requirements. justifications for

- STS 3.6.2.4 specifies the any changes made OPERABILITY requirement to the CTS /STS.

for the RHR Suppression Pool Spray. ITS 3.6 does not include STS 3.6.2.4

,- based on the premise that it does not meet the

! Criterion specified in 10 CFR 50.36(c)(2)(11). The staff has determined and stated in the Bases of STS B3.6.2.4 that the RHR Suppression Pool Spray System does meet Criterion 3 of 10 CFR 50.36(c)(2)(11). Since this system was in the CTS and the staff determination is that it meets Criterion 3, this specification should be included in the ITS.

However, STS 3.6.2.4 of NUREG-1433 may not be the appropriate TS in DAEC case, STS 3.6.1.7 "RHR Containment Spray System" of NUREG-1434 (BWR-6) may be the more appropriate TS to use.

1

. DAEC STS 3.6.3.2 DRYWELL COOLING SYSTEM FANS l

ITEM-l!!A i DOC /P CTS /STSl* DESCRIPTION ~0EilSSUE DATEi DATEJ.. CofMENTS ( o~ s

g. ,ip; cyg c4

LC0;"

OPENED' ' CLOSED-

+

I S3.6.3.2-1 P.14 STS STS 3.6.3.2 specifies 7/8/97 Provide additional Bases 3.6.3.2 the requirements ar.d discussion and il n P.8 and surveillances for justification for this t

Associated Drywell Cooling System deletion based on

! Bases Fans. The ITS does current licensing not contain this bases, system design specification. The or operational constraints.

! Justification (P.19) used states DAEC does -

not assume Drywell j Cooling System Fans

,: are available to

! assure adequate mixing. STS B3.6.3.2

- Bases APPLICABLE -

i SAFETY ANALYSES states

' that even though no credit for mechanical

- mixing is assumed in the analysis, the system does meet criterion 3 of 10 CFR 50.36(c)(2)(11), for other reasons.

4 1

DAEC ITS 3.6.3.1 CONTAlleqENT ATMDSPHERE DILUTI0lt (CAD) SYSTDI

_DOCMD CTS /NS) DATEh- DATEb Cof91DITS ['-

'ITEMM' "W5% 'l DESchlPTI0liMISSUE O A U E:' -

Non J 'JFD i ' LCO O M' w OPENED CLOSED? ^ ' A 3.6.3.1-1 A.2 STS- STS 3.6.3.4 RA A.1 specifies 7/8/97 Delete this i P.33 3.6.3.4 the required action to take if generic change.

Bases RA A.I' sne CAD subsystem is i P,8 STS inoperable. STS 3.6.3.4 ACTION il 3.6.3.4 8 specifies the required

j ACTION B actions to take if two CAD i ITS subsystems are inoperable lj; 3.6.3.1 (i.e., total loss of function).

t RA A.1 ITS 3.6.3.1 deletes STS 3.6.3.4

-l and RA A.1 and modifies STS 3.6.3.4

2 Associated ACTI0lt B to apply to total Bases system inoperable (loss of function). This modification i adds a Note to ITS 3.6.3.1 RA

' A.1 to specify that LC0 3.0.4 4

is not applicable. While STS 3.6.3.4 RA A.I had this note, ACTI0lt B did not because Condition A only applied to one subsystem inoperable, thus there was a redundant subsystem capable of performing the safety function for the 30 days required to restore system operability. With total loss of function there is no backup, redundant CAD system to rely on, therefore the exception to LCO 3.0.4 was not included in STS 3.6.3.4 ACTIoll B. The same reasoning would also app!y to the ITS changes to RA B.I. In addition the staff would ~

consider this change as a generic change.

1

DAEC ITS 3.6.3.1 CONTAINMENT ATMDSPHERE DILUTION (CAD) SYSTEM ITEM M $ DATEI. DATEI 92 DOEM ~ C13/STS W 'DESCRiPTIONOF? ISSUE ~ ~4 CofflENTS N0; 'M M% ;LCO C * ' ' '

! OPENED M CLOSED' x 3.6.3.1-2 P.20 STS SR STS SR 3.6.3.4.2 requires 7/8/97 Delete this Bases 3.6.3.4.2 verifying each CAD subsystem change.

,. P.8 - ITS SR maeval, power operated, and

. 3.6.3.1.2 automatic valve in the flow

.. ; and . path that is not locked, .

! Associated sealed, or otherwise secured in Bases. position is in the correct position or can be aligned to the correct position every 31 days. Under the same conditions ITS SR 3.6.3.1.2 3

requires the same except the 1 manual valves are deleted. The i deletion'is unacceptable. The way the specif1 cation and .

associated Bases is written would allow verification of the valves position through use of a paper verification rather than a system walkdown as is-required by the PWR STSs.

Therefore since this is a new specification for DAEC and a paper verification is feasible based on the justification (P.20), the staff requires that ,

the manual valves be verified in the correct position.

3.6.3.1-3 P.21 ITS The renumbering of ITS 3.6.3.1 7/8/97 See Iten Number Base 3.6.3.1 and succeeding specification 53.6.3.2-1.

P.8 and will depend on the resolution Associated of Ites Number 53.6.3.2-1.

Bases e

2

i

?

DAEC ITS 3.6.3.1 CONTAllWIENT ATM0 SPHERE DILtTTION (CAD) SYSTEM l

~, . u. , . _ .

.. ~

. PI r DATEL i

1TEMfL M: DOC d CTS /STS) DESCRIPT10N 0F3ISSUEL ~ 1 _

DATEC C0f9ENTS ' ' - !

pop % & LCO Gw J M 1W N fJFD 4@ '

OPENED" CLOSED:

i 3.6.3.1-4 Bases ITS ITS 83.6.3.1 Bases SR 3.6.3.1.2 7/8/97 Delete this !

i' P.17 B3.6.3.1 is clarified by a number of change. ;

Bases statements (Insert 2) which !

4 . SR allows the valves to be

.l 3.6.3.1.2 mispositioned for surveillance

testing and other approved i operating system i jl_ configurations. While the ;

j wording of the STS/ITS allows !

I for the various system .

lJ operating configurations it r

,; does not allow for realignments !

due to surveillance testing. :

l The staff's position is that if surveillance tests put the !

l system into an alignment that !

is not a normal or emergency !

, operational alignment then the i i system is considered inoperable i and the appropriate ACTIONS $

shall be taken.

3.6.3.1-5 New STS SR STS SR 3.6.3.4.2 states that 7/8/97 Delete this !

3.6.3.4.2 each CAD valve in the flow path change, or i ITS SR is verified-in the correct provide' i 3.6.3.1.2 position. ITS SR 3.6.3.1.2 additional ;

and deletes the words "in the flow discussion and' !

Associated path." No justification is justification ;

Bases. provided for this deletion. for this l However, M.2 which adds this SR deletion. l to the DAEC ITS uses these l words and the Associated Bases uses similar wording. ., i

i i

l 3 ,

l

DAEC ITS 3.6.3.2 PRINARY CONTAINNENT OXYGEN CONCENTRATION l 2

NENin 1:e ;Dts$fbA CTS /STS[N DESCRIPTION 0E{ISSUEn:. DATE0 ,,

+ -

DATEN sw CofiEh _

, . nob -

2JFD FN#W LC0 U - <

OPENED' CLOSED 1-l' 3.6.3.2-1 P.21 !TS See Item Number 7/8/97 See Item Nunter

!: ~

Bases 3.6.3.2 3.6.3.1-3 3.6.3.1-3 i' P.8 and

i' . Associated lj.

Bases j 3.6.3.2-2 B'ases STS The changes made to 7/8/97 See Item Number.

i P.I B3.6.3.3 STS 83.6.3.3 Bases- 53.6.3.2-1.

! Bases- BACKGROUND to delete I. BACKGROUMD the references to STS lll ITS 3.6.3.2 in ITS

., 83.6.3.2 B3.6.3.2 will depend

'* Bases on resolution of Item

. BACKGF.0tJNO Number S3.6.3.2-1.

g #

i i

I l

l

DAEC ITS 3.6.4.1 SECONDARY CONTAINMENT ITENL N0;-

'. ~ DOC /

JFD CTS /STS0 LCO DESCRIPTION OF. ISSUE- DATE OPENED:

DATE" CLOSED-

. COMENTS 3.6.4.1-1 A.3 CTS 16 CTS 16 " SECONDARY CONTAINNENT 7/8/97 Revise the markup i A.8 ITS INTEGRITY" definition is to show that the N.4 B3.6.4.1 divided into three parts. definition CTS 16 R.2 Bases The first part is associated " SECONDARY with ITS 1.0 and the change CONTAINNENT

is designated A.8 which INTEGRITY" is

! deletes the definition from being relocated

~

TS. The second part is to the Bases of j associated with the access ITS B3.6.4.1.

f openings and Standby Gas Provide Treatment (SBGT) System (CTS additional l 16.a and 16.b respectively) discussion and

! and the changes are justfilcation for l

! designated N.4 and A.3 this less

[ respectively. N.4 modifies Restrictive (LA) definition 16.a as ITS SR change. See Item

3.6.4.1.1 and SR 3.6.4.1.2 Numbers 3.6.4.2-l while A.3 moves the 4, 3.6.4.3.-1, definition for SBGT to ITS and 3.6.4.3-2. [

3.6.4.3. The third part is '

associated with secondary containment isolation valves / dampers (SCIV/D) and the change is designated R.2 which states that the majority of CTS 16.c is i relocated to the Bases. The markup is incorrat. 't he entire definition for SECONDARY CONTAINNENT INTEGRITY is moved to ITS B3.6.4.1 Bases in total or sunnarized in some part of ITS B3.6.4.1 Bases. In 1

l . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

DAEC ITS 3.6.4.1 SECONDARY CONTAINMENT 4

ITEMJ ' DOC /2 CTS /STS - DESCRIPTION OF-ISSUE 1 DATE' DATE -

C0f9fENTS' l NO.- N ^~ 'JFD' ' LCO ' OPENED CLOSED 1

addition, the staff considers this relocation to be a Less Restrictive change (LA)

i rather than a Relocation (R) i which is reserved for the {

movement of whole specifications. See Ites

! ~

Numbers 3.6.4.2-4, 3.6.4.3-1, 1 and 3.6.4.3-2.

l

.j 3.6.4.1-2 M.4 CTS 16.a STS SR 3.6.4.1.3 verifles 7/8/97 Delete the TSTF

, P.53 STS SR that the secondary 18 changes or i Bases 3.6.4.1.3 containment access doors are provide P.2 ITS SR closed except when it is additional l Bases 3.6.4.1.2 being used for entry or exit, discussion and '

P.8 and then at least one door shall justification for Associated be opened. ITS SR 3.6.4.1.2 the deviations Bases and its Associated Bases from the STS.

modifles STS 3.6.4.1.3 and~

lts Associated Bases based on plant specific design and TSTF 18. TSTF 18 has been rejected by the staff.

3.6.4.1-3 LCY-2 CTS CTS 4.7.J.1.a requires 7/8/97 Delete this j 4.7.J.1.a performing testing of the change.

ITS SR secondary containment 3.6.4.1.3 capability at each refueling and outage (18 months). Under Associated the same circumstance ITS SR Bases 3.6.4.1.3 requires every 24 months. This extension of the Surveillance frequency is considered by the staff as a beyond scope of review item for this conversion.

2 l

DAEC ITS 3.6.4.1'SECOMP*~l CONTAllWEEMT

ITIMD%I

gogude- DOCM4 iCTS/STSi d JFDPe: LCO t* * '

DESCRIPTION OF ISSUE!.

o - > -

a DATEU *"

OPENEDi DATE$'$$

CLOSED"J NSk e sm**

f 4-3.6.4.1-4 Bases STS STS B3.6.4.1 Bases-BACKGROUND 7/8/97 Delete this P.ll' B3.6.4.1 states the following: "It is generic change.

Bases- possible for the pressure in

.. BACKGROUND the control volume to rise ITS relative to the environmental i B3.6.4.1 pressure (e.g., due_to pump l, Bases- . and motor heat load t' BACKGROUND additions)." ITS C3.6.4.1 Bases-BACKGROUND deletes this sentence. The justification (Bases P.11) state that the

, sentence is confusing and did not add value to the discussion. This is an j inadequate justification to determine why the sentence is I

, confusing. Furthermore, the

deletion based on the i justification would be considered a generic change which is beyond the scope of review for this conversion.

3

DAEC ITS 3.6.4.2 SECONDARY CONTAIMENT ISOLATION VALVES /DMPERS (SCIV/Ds) g :e ;a ' CTS /ST0m + R SCRIPTION OF[IS#d^~ ed DATEL 6 DdTESE"-C6MMENTS@as-@f gon ,

l,,gj?

JFD LCO M M - + /

OPENED: ' CLOSED s 34 ^

'J h 3.6.4.2-1 A.3 CTS 16 See Ites Number 3.6.4.1-1 7/8/97 See Item Number 4 A.8 ITS 3.6.4.1-1.

.; M.4 83.6.4.1 i R.2 Bases.

3, ITS 1 ,

B3.6.4.2

! Bases y

n 3.6.4.2-2 LCY.2 CTS CTS 4.7.K.1 requires 7/8/97 Delete this

4.7.K.1 testing OPERA 8LE change.

! ITS SR isolation dampers once

{ 3.6.4.2.2- per operating cycle (18)

( and months). ITS SR 4 Associated 3.6.4.2.2 requires j Bases verifying each SCIV/D

actuates every 24 months. j

^

Extending the Frequency from 18 months to 24 months is an extension of the surveillance frequency which is considered by the staff as a beyond scopo of review ites for this conversion.

3.6.4.2-3 P.21 ITS SR The renumbering of ITS SR 7/8/97 See Ites Number Bases 3.6.4.2.1 3.6.4.2.I and SR 3.6.4.2-4.

P.8 ITS SR 3.6.4.2.2 will depend on 3.6.4.2.2 the resolution of Item and Number 3.6.4.2-4.

Associated Bases I

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DAEC ITS 3.6.4.2 SECONDARY CONTAINMENT ISOLATION VALVES / DAMPERS (SCIV/Ds)

~

DATEc-

ITEML DOC /(F CTS /STMl; DESCRIPTION OFIISSUEh 'DATEi CofffENTS :

~

pop s,

n

.:JFDL ' ~

LC0 " OPENED-CLOSED:

i 3.6.4.2.4 P.22 CTS 16.c. STS SR 3.6.4.2.1 verifles 7/8/97 Revise the CTS Bases STS SR that each manual SCIV/D markup and ITS

, P.8 3.6.4.2.1 and blind flange that is 3.6.4.2 to include

. and required closed during STS SR 3.6.4.2.1

. Associated accident conditions is and its Associated Bases. Provide Bases closed. ITS 3.6.4.2 does i not include this STS SR. any additional 3 The justification used discussion and (P.22) is incorrect. The justification as

.l STS SR is required, based necessary. See j on the CTS requirement Item Numbers specified in CTS 16.c.2). 3.6.1.3-4 and CTS definitions are part 3.6.4.2-8.

of the TS requirements and can specify .

'l indirectly or directly i SRs or OPERABILITY requirements that must be met, such as in this case. See Item Number 3.6.1.3-4 and 3.6.4.2-8 l I l

4 2

DAEC ITS 3.6.4.2 SEC3NDARY CONTAINNENT ISOLATION VALVES / DAMPERS (SCIV/Ds)

! ITEM @)$ .[DOCf/ , cts /STSk DESCRIPTIONOF?I'ESUEi y DATEi - DAfE= CopWENTS1 NOD e W '

~ '

JFD '~ LCO.' - +

OPENED: CLOSED

~

- m -

3.6.4.2-5 Bases STS STS B3.6.4.2 Bases-LCO 7/8/97 Provide additional P.1 B3.6.4.2 states that the automatic discussion and Bases-LCO SCIV/Ds covered by STS justifications for

. ITS LCO 3.6.4.2 along with listing these i B3.6.4.2 their stroke times are SCIV/Ds in Bases-LCO listed in the FSAR (Ref. Administrative ITS 3). ITS B3.6.4.2 Bases- Procedures rather .

/ B3.6.4.2 LCO states this list is than the FSAR, Bases- in Plant Administrative include the REFERENCES Procedures. The specific Procedures or FSAR 1 procedures are not location in ITS t specified or listed in 83.6.4.2 Bases-

, ITS B3.6.4.2 Bases- REFERENCE Section, REFERENCES nor is the and provide the procedure change control procedure change -

process defined. control process.

i 3

DAEC ITS 3.6.4.2 SECONDARY CONTAINNENT ISOLATION VALVES / DAMPERS (SCIV/Ds) itTEM?

~

. DOC / 4 'a " CTS /5TS$'

DESCRIPTIONLOF[ISSUEi

'DATEU DATE 9 50NIENTS)

"JFD4 N0k LCO' -

OPENED CLOSED <~

3.6.4.2-6 Bases STS SR STS SR 3.6.4.2.2 requires 7/8/97 Provide a l P.2- 3.6.4.2.2 verifying the isolation discussion and ITS SR time of each power justification for 3.6.4.2.1 operated, automatic the STS deviation and SCIV/D is within limits based on current

,' Associated in acecrdance.with the licensing basis, Bases. Inservice Testing Program system design, or '

? (IST) or 32 days. Under operational i

1 the same conditions ITS constraints.

SR 3.6.4.2.1 requires every 92 days. However,

! ITS SR 3.6.1.3.5 which is l the same SR for PCIVs requires the test be performed in accordance ,l with the IST. There is i no discussion for choosing the STS :

requirement of 92 days r verses in accordance with !

the IST, particularly when ITS SR 3.6.1.3.5 uses the IST program.

E e

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DAEC ITS 3.6.4.2 SECONDARY CONTAINNENT ISOLATION VALVES / DAMPERS (SCIV/Ds)

^

w ' DOC /fY-

!! TEM / ' CTS /STSi' DESCRIPTIONOF11SSUEm" DATE ? DATE .' C0fMENTSf LCO, ' A

^ ' -

N0b - 'JFDT ; *

~

OPENED CLOSED? A - -

3.6.4.2-7 Bases STS STS B3.6.4.2 Bases-LCO 7/8/97 Prwvide the l P.15 B3.6.4.2 states that the passive location of this

! Bases-LCO SCIV/Ds or isolation list of normally ITS devices covered by STS closed isolation !

B3.6.4.2 LCO 3.6.4.2 are listed in devices, specify l Bases-LCO the FSAR (Ref.3 ) ITS it in ITS B3.6.4.2 ITS B3.6.4.2 Bases-LCO Bases, and

) B3.6.4.2 deletes this :tatement. describe the jj Bases-- The justification (Bases change control ij REFERENCES P.IS) deals with process for the b determining valve list. Provide any I OPFRABILITY and additional appropriate isolation discussion and ,

methods. The STS/ITS justification as '

paragraph deals with necessary.

l defining "normally"

closed isolation devices 1 and where a list of these y normally closed isolation devices can be found.

Thus, the justification is irrelevant to this cl.ange.

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DAEC ITS 3.6.4.2 SECONDARY CONTAIMENT ISOLATION VALVES /DMPERS (SCIV/Ds)

DOC /J ^ CTS /STSli : DESCRIPTION.DFUISSUE;) DATE? . DATEJ ComENTSL. .

:N0pd ITEM-6

.. JFD? -

LCO i OPENE01- CLOSED ~

^

! 3.6.4.2-8 None CTS CTS 3.7.K.2 addresses one 7/8/97 Provide a 3.7.K.2 or more of the secondary ditrussion and ITS containment " automatic" justificetion fo:-

3.6.4.2 1 solation valves / dampers removing the CTS ACTION A inoperable. ITS 3.6.4.2 requirement for Condition A addresses one automatic SCIV/Ds.

or more penetration flow

! paths with one SCIV/D

!l inoperable which does not i limit the ACTION to just automatic SCIV/Ds. There is no discussion or justification for removing the CTS i

requirement for automatic

! SCIV/Ds, particularly in j light of Item Number

, 3.6.4.2-4.

3.6.4.2-9 None STS SR STS SR 3.6.4.2.2 and its 7/8/97 Licensee to update 3.6.4.2.2 Associated Bases has been submittal with and modified by TSTF 46 Rev regards to TSTF Associated I. ITS SR 3.6.4.2.2 and 46, Rev 1.

Bases its Associated Bases has ITS SR not been modified by 3.6.4.2.2 TSTF-46 Rev 1. Since ITS and 3.6.I.3 has been modified Associated by TSTF-46, ITS SR Bases 3.6.4.2.2 and its Associated Bases needs to

,be modified accordingly.

6

DAEC ITS 3.6.4.3 STMOBY GAS TREATMENT (58GT) SYSTEN ITEM [ DOC /Je CTS /STS DESCRIPTION DE ISSUE DATE- DATED = C09 TENTS -^

' ~

t N0; '

'JFD - LOC L.i OPENED CLOSED l 3.6.4.3-1 A.3 CTS 16 See Item Numbers 3.6.4.1-1 and 7/8/97 See Item

A.8 ITS 3.6.4.2-2. Number l M.4 83.6.4.1 3.6.4.1-1 and R.2 Bases 3.6.4.3-2.

ITS B3.6.4.3 Bases

,! 3.6.4.3-2 A.3 CTS 16.b. CTS 16.b states that the 58GT is 7/8/97 Revise the CTS ITS LCD OPERABLE. The CTS markup for CTS 16 markup for ITS

gli j 3.6.4.3 is found in ITS 3.6.4.1 and 3.6.4.2 3.6.4.3 to but not in ITS 3.6.4.3. CTS 16.b include CTS definitaly applies to ITS 3.6.4.3 la 16.b. Provide

!l

!r that it is another CTS statement additional requiring SBGT be OPERABLE, which in discussion and l -

the ITS would correspond to ITS LCO justification 3.6.4.3 for this Administratia change.

1

DAEC ITS 3.6.4.3 STANDBY GAS TREATMENT (SSGT) SYSTEM i ITEM; _ DOC /1 CTS /STST~ DESCRIPTION OF ISSUE. _. DATE DATED. CONTENTS

! Nor -

JFD - LOC -

OPENED CLOSED 3.6.4.3-3 A.4 CTS CTS 3.7.L.3 requires restoring the 7/8/97 Provide 3.7.L.3 incperable SBGT to OPERABLE status additional ITS within 7 days when one SBET is discussion and i

. 3.6.4.3 inoperable, operation or fuel justification ACTION A handling may continue previde the to clarify why ITt remaining SBGT is verified to be this 3.6.4.3 OPERABLE. ITS 3.6.4.3 RA A.I Administrative !

ACTION C requires restoring the inoperable change is i ITS 586T subsystem to OPERABLE status -

being made, ,

I 3.6.4.3 within 7 days. There is no and its '

ACTION E requirement to verify the remaining relation to

! S8GT system is OPERABLE. ITS the various 3.6.4.3 RA C.I, and C.2 require ITS ACTIONS. .

j placing the OPERABLE 58GT in i 1 veration or suspending fuel .;

'! movement, CORE ALTERATIONS, or o OPDRVs when the Required Action and !

associated Coupletion Time of :

Condition A are not met (I SBGT subsystem inoperable). The Justification A.4 discusses 2 S8GT !

subsystems inoperable. There is inadequate discussion and Justification for changing the CTS allowance that operation or fuel handling may continue provided the :

remaining SBGT is verified to be i OPERABLE and how this related to 2 SB3T subsystems inoperable. '

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DAEC ITS 3.6.4.3 STANDBY GAS TREATMENT (58GT) SYSTEM

^

-ITtNJ DOC /' CTS /STSi. DESCRIPTION OF ISSUE . DATE DATED _ ColflENTS' -

Nor

JFD ~ LDC:'

~

OPENED CLOSED

.j 3.6.4.3-4 R.2 CTS CTS 4.7.L.1.f requires the SBGT 7/8/97 Provide i

4.7.L.l.f System drains be inspected quarterly discussion and for adequate water level in loop justification i

" seals. This requirement is not identifying -

i retained in ITS 3.6.4.3 and is moved how the to plant procedures. The specific specific plant ,

plant procedures are not identified, procedures are

. l!j

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nor is the procedure change control controlled. l process.

~

In addition, the staff ;

considers this relocation to be a Less Restrictive change (LA) rather l

' ;j -

than a Relocation (R) which is l

!, reserved for the movement of whole ;

j specificaticas.

3.6.4.3-5 L.2 ITS SR ITS SR 3.6.4.3.2 includes two Notes 7/8/97 Delete this !

P.35 3.6.4.3.2 that reflect DAEC current operating change. !

P.36 and practice which delays entering 8ases Associated Required Actions for Conditions P.8 8ases caused by performing Surveillance l Requirements. The CTS does not include these Notes. The change to CTS requirements is based on previous correspa A ..ce with the NRC staff regarding the DAEC GL 89-10 t Motor-Operated Valve (MOY) .*rogran ,

(J. Franz (IES) to W. Russell (NRC), l

' Generic letter 89-10 Program," NG- l 94-4017, November 30, 1894).. The staff's position is that if a surveillance test makes the system l Inoperable or puts the system into an alignment that is not a normal or emergency operational alignment then .

the system is considered inoperable and the appropriate ACTIONS shall be taken.

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DAEC ITS 3.6.4.3 STANDBY GAS TREATNENT (58GT) SYSTEM l .

l ITEM E DOC /; CTS /STSc:.1 DESCRIPTIONOFl ISSUE

DATE' DATED' ComENTS C

l

'JFD^ toc M: -

OPENEC CLOSEDi c

' 3.6.4.3-6 LCY.2 CTS 4.7.L.I.d requires demonstrating Delete this CTS 7/8/97 3

4.7.l.1.d once per operating cycle (18 months) change.

ITS SR automatic initiation of each branch

- 3.6.4.3.3 cf 58GT. Under the same conditions and ITS SR 3.6.4.3.3 requires this f' Associated surveillance every 24 months. This i Bases extension of the surveillance !

' i frequency from 18 months to 24 l l months is considered by the staff as >

j a beyond scope of review item for this conversion. l

. 3.6.4.3-7 LIC.2 CTS CTS 4.7.L.I.e requires demonstrating 7/8/97 Delete this j 4.7.L.l.e manual operability of the bypass change. l system for filter cooling annually.

ITS SER !

, 3.6.4.3.4 ITS SR 3.6.4.3.4 requires verifying l

and each 58GT filter cooler bypass <

Associated damper can be opened and the fan

, Bases. started every 24 months. This .

extension of the Surveillance I Frequency from annually to 24 months l 1s considered by the staff as a l beyond scope of review item for this !

conversion. ,

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, DAEC ITS 3.6o4.3 STANDBY GAS TREATMENT (SBGT) SYSTEM i

-ITEM DOC / CTS /STS. DESCRIPTION OF ISSUE ' DATE DATEC COFMENTS N0;> a JFDf LOC-OPENED CLOSED i

~

3.6.4.3-8 Bases STS STS B3.6.4.3 Bases-SR 3.6.4.3.1 7/8/97 Delete this g

,P.13 B3.6.4.3 state the following: "The 31 day generic .

Bases Freg.;..cy was developed in change.

. SR consideration cf the known t 3.6.4.3.1 reliability of fan motors and !

ITS controls and the redundancy '

B3.6.4.3 available in the system." ITS SR B3.6.4.3 Bases-SR 3.6.4.3.1 deletes ,

3.6.4.3.1 the words *was developed...in the system." And replaces them with the following: *is sufficient to ensure potential moisture buildup does not j' impact the adsorption and filtering function. As applicable, the 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months run is not required to prove .

OPERABILITT for post-maintenance l l

, testing." Based on the STS/ITS

writeup preceding the deleted STS words, the deleted STS words cannot i be deleted. In addition, while the first part of the replacement words about moisture buildup would be considered acceptable, the last sentence about post maintenance testing is unacceptable. The whole change is considered to be a generic change and beyond the scope of i review for this cor. version. <

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DAEC ITS 3.7.1 RESIDUAL HEAT REMOVAL SERVICE WATER (RHRSW) SYSTEM 3.7.1 DOC JFD CHANGE / DIFFERENCE COMMFNT STATUS 1 P.18 ITS 3.7.1 Achon A.1 adds a Note statog that LCO 3.0.4 Provide justdicahon for the STS is not app 6 cable. CTS 3.5.C.2 does not contain the deviabon.

provisions of ITS 3.0A. Addag this Note to ITS 3.7.1 Achon A.1 is a deviation from the STS. There is inW* h ==m and )athm for this STS deviabon.

DAEC RESPONSE 2 R.1 CTS Survedlance Requirements 4.5.C.1.a and 4.5.C.1.b Provide specife document references to specdy IST requirements for the RHRSW pumps and ensure that the CTS detads for motor-operated valves. ITS SR 3.7.1.1 does not achieving the requirements are contain these requarements. The <*=e,mem states that incorporated into the Licensee-the IST requirements are moved to plant procedures controlled documents controsed by 10 and to the IST Program. This change moves CFR 50.59.

ggquirements nrdaria the Technical -WW into 1.icensee controned documents. Specife documents are not referenced. There is not enough informahon to ensure that the CTS detads for achievmg the lI requirements are incorporated inb the trensee-controlled documents controlled by 10 CFR 50.59. ;

DAEC RESPONSE i

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l j DAEC ITS 3.7.2 RIVER WATER SUPPLY (RWS) SYSTEM AND ULTIERATE HEAT SINK (UHS) j 3.7.2 DOC JFD CHANGE /DNERENCE - COMMENT STATUS 1 R.1 CTS Survedlance Requirements 4.5.J.1.b,4.5.J.1.c Provide specdic document references to

(pump and valve quarterfy teshng and post- assure that these CTS details for

! mandonance testmg) and 4.5.J.1.d (daily operahng achieving the IST requwements are l pump flow rate demonstration) specdy inservice contained in the Licensee-controlled Toshng (IST) cntena for the RWS System pumps documents that are controlled by 10 i and motor-operated valves. ITS SRs do not contain CFR 50.59.

l these IST requirements. This change rh j'

these requirements to Licensee-controked documents or the IST Program in ITS 5.5.6, j " Inservice Teshng Program." This change moves j requirements outside the ITS into Licensee-l controsed documents. Specdic documents are not ,

) referenced. There is insufficent informahon to ,

ensure that the CTS Maan for achieving the i j, requirements are 'mcorporated into the Licensee- ,

2 controsed documents controlled by 10 CFR 50.59.

1

) DAEC RESPONSE F' t

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DAEC ITS 3.7.2 RIVER WATER SUPPLY (RWS) SYSTEM AND ULTlatATE HEAT SINK (UHS) 3.7.2 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 2 L1 CTS Surveillance Requirement 4.5.J 1.c requires Provide adermal Ae=<rwt and performing RWS pump flow rate testmg daily to just&atm relatwe to the atukty of a A.4 demonstrate OPERABILITY when the UHS level is river water level of 727 feet, required in

< 727 feet above mean sea level. Nedher the STS the CTS, to provide =&wyinta NPSH for 3.7.2 SRs nor the ITS 3.7.2 SRs contam such the RWS pumps. Include a de==~m requrements. Rather, they declare the UHS of the marge provided by this level, and inoperable whenever river level is too low to provide justdy deletog this requirement.

the requred flow to support RWS pump OPERABILITY (i.e.,725.2 feet above mean sea level). The river water level speedied in CTS 4.5.J.1.c of 727 feet is based on providag =&wyvata net posewo suchon head (NPSH) to the RWS pumps. There is ina&wyinta semcm and justdicahon related to the RWS pumps NPSH requirements and lowenng the allowed river level value to 725.2 feet. ;

DAEC RESPONSE f 3 L3 CTS Survedlance Requirement 4.8.E.1.c e a Provide adddsonal discussion and l A.3 condiconal Survedlance to perform ESW pump ju9hm for the 95'F upper }

testmg weeldy when the river water temperature is > temperature limit for the river water. ?

80*F. The ITS 3.7.2 SRs do not require such Justdy not utdizmg conddional SR of conddional survedlances. However, ITS 3.7.2 SRs CTS.

replace the CTS 4.8.E.1.c conddsonal Survedlance ,

with a SR to mondor river temperature daily to venfy ..

l it is < 95*F. There is inadequate s e asm and justdicabon for the 95*F upper limit for the river water temperature. j DAEC RESPONSE :

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DAEC ITS 3.7.2 RfVER WATER SUPPLY (RWS) SYSTEM AND ULTIMATE HEAT SINK (UHS) i l 3.7.2 DOC JFD . CHANGE / DIFFERENCE COMMENT STATUS-i

! 4 A.2 P.2 The cross-train operatmiity h mquired by Indude the pump inoperability condshon l the CTS is deleted nace this funchon is covered by with the 30 day compiehon time of the

the Safety Funchon Determinahon Program in the STS or prowde)% for the STS i STS. STS 3.7.2 Achons A and B (on pump devcahon. -

! ir -;+M~r) are deleted since these condsisons !

I are not a part of the CTS (the cummt licensang basas-CLB). Delehng the explicst cross train venEcation checks required by the CTS, on the one

} hand, and not induding the STS pump requirements j har- they are not in the CLB is not prudent. In j arWwwn, the ITSJCTS compiehon time for j subsystem inoperabiWy is greater than that provided '

by the STS (7 days vs 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ).

DAEC RESPONSE =

5 LCY.2 CTS 3.5.J.1.a spea6es a frequency of "once per This change has been withdrawn as Closed.

l' i

l

operahng cycle," which is currently 18 months. ITS part of the conversoon. l l SR 3.7.2.4 *parda* a Frequency of 24 months. I basing the change on Genenc Letter 91-04,

" Changes in Technical W Surveillance Intervais to Accommodate a 24-month Fuel Cycle." .

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DAEC ITS 3.7.3 EMERGENCY SERVICE WATER (EWS) SYSTEM 3.7.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1- R.1 CTS Survedance Requrements 4.8.E1.b and These praMral detads that were in 4.8.E1.c (quarterfy pump and valve testog and post- the CTS, and are now bemg raam arad mantenance testing) speofy insovice Teshng (IST) to other procedures, shall be raw cmena for the ESW System pumps and motor- to licensee controsed documents operated valves. The ITS 3.7.3 SRs do not contam contro8ed by 10 CFR 50.59. Provide these IST requirements. This change relocates these spae*- document references to assure requrements to bcensee contro8ed documents or to that these CTS detads for achieving IST the IST Program descnbed in ITS 5.5.6. *1nservice requremerts are contamed in the Teshng Progrant This change moves requrements bcensee-controlled documents that are me the Techncal Se% into Licensee controlled by 10 CFR 50 59.

controlied documents. Speofc documents are not referenced. There is innne*nt informahon to ensure that the CTS detads for actueving the requrements ,

are acorporated mio the Licensee-controlled documents that are controlled by 10 CFR 50.59. -

1 DAEC RESPONSE 2 L2 CTS Survedance Requrement 4.8.E1.c & a Provide discussion and jushfication for l condsonal Surveeltance to perform ESW pump testing Ine changed CTS requrement, includeg j weekly when the river water temperature exceeds 80* the basis for the 95* F limit. Provide F. Neither the STS 3.7.3 SRs nor the ITS 3.7.3 SRs addeonal justificahon for deleting the l require such condsonal survedance requirements. CTS 4.8.E.1.c condsonal survedance However, reference is made to the ITS 3.7.2 requrement for weekly ESW pump !

requrement to dedare the UHS inoperatae whenever testog.

river water temperature exceeds 95* F. There is no hm or jushfcation related to the basis for the 95* F imt.

DAEC RESPONSE

DAEC ITS 3.7.3 EMERGENCY SERVICE WATER (EWS) SYSTEM 3.7.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3 LCY-2 CTO Survedance Requirement 4.8.E.1.a Wies a This request for extenson of CTS Frequency of"once per operahng cycle. whch CTS Survemance Test interval has been 1.0.17 states is 18 months. ITS SR 3.7.32 spe'a* a removed from the conversion effort.

Frequency c424 months, basang the change on Genenc Lealer 91-04. T.hanges in Techncal cymP 34 Survemance Intervals to Accommodate a .

24-month Fuel Cyde."

DAEC RESPONSE 4 A2 P.2 The cross-train operab6ty vendication required by the include the pump inoperatdy condden CTS is deleted sance this funcbon is covered by the with the 30 day complebon time of the Safety Functon Determmabon Program in the STS. STS or provide jushficahon for the STS STS 3.7.3 Actons A and B (on pump moperabuses) deviaton.

are deleted since these condsons are not a past of the CTS (the current bcenseg basas-CLB). Delehng the explot cetrain ver* mem checks required by .l the CTS. on the one hand, and not indudog the STS pump requirements he they are not in the CLB .i is not prudent. In msm. the ITS/ CTS complebon -

time for subsystem moperatsy is greater than that -

provided by the STS (7 days vs 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ).

DAEC RESPONSE i

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DAEC ITS 3.7.4 STANDBY FILTER UNIT (SFU) SYSTEM 3.7.4 DOC JFD CHANGE / DIFFERENCE CORWENT STATUS 1 LCY h: CTS 4.10A3 requres this SR be performed once per This extensen of CTS Survemance Test Closed.

M.3 operatog cycle, John:h CTS 1.0 .17 defines as 18 Interval has been withdramun from tw months. ITS SR 3.7.4.4 proposes extendog the CTS conversson effort.

Survedance Test interval from 18.Tanitiis to 24 rnonths, on a staggered test bases.

DAEC RESPONSE 2 R.1 CTS Survedance Requrements 4.10A2.d and These pOcedural detads that were in 4.10A3 requre, in part, Gc,Tanoisai.6g each SFU the CTS, and are now being relocated subsystem Operable by initsatog flow through the to other procedures, shat be relocated HEPA Nters and charcoal adsorbers and venfymg that to bcensee contro5ed documents upon receipt of a high radsabon test segnal, the system contro5ed by 10 CFR 50.59. Provide auici6.ik ily switches to an isolaten mode. ITS 3.7.4 additional mformation on whch does not contam these detads. Rather, they are documents now contam these

" relocated to licensee controHed documents." requrements and which are contro5ed However, the discussion does not speofy whch by 10 CFR 50.59. .

hcensee controlled documents now contain these requrements. The discussion merely states that these relocated requeeinciiis are evaluated in accordance wdh the DAEC 10 CFR 50.59 pcWinn. I i'

DAEC RESPONSE ,

6

_ _ _ _ _ _ _ . _ _ _ _ _ _ . _ m

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

I DAEC ITS 3.7.5 CONTROL BUILDING CHK.LER (CBC) SYSTEM 3.7.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS No Comments on this Spec 6cabon. j f

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an. - m. .m e m -,a 4 4.%--i , ,, .,._.nyr...,..i aa-4 -A & Ed -->h-- 4 s+- *A A .-A & -- - ~ - - - -h--& -* --4 4- -bdS- .-----* I & = h m

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DAEC ITS 3.7.5 IWUN CONDENSER OFFGAS 3.7.6 DOC 'JFD' CHANGFJDIFFERENCE COMMENT STATUS i ,

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DAEC ITS 3.7.7 MAIN TURBINE BYPASS SYSTEM

3.7.7 DOC ED CHANGE / DIFFERENCE COMMENT STATUS'l -

1 P.13 A companoon of the new ITS 3.7.7 SRs and the STS The cyde related frequency extensions 3.7.7 SRs reveals changes to the Frequences. frorn 18 to 24 rnonths have been ,

Spec 4capy ITS SR 3.7.7.1 Frequency is 92 days and withdrawn (the frequences sha5 he 18 the STS SR 3.7.7.1 Frequency is 31 days. Smiady, months). Sutet a TSTF change the ITS SRs 3.7.7.2 and 3.7.7.3 Frequenoes are 24 request for the turbane bypass SR l rnonths and the STS SRs 3.7.7.2 and 3.7.7.3 frequency change to 92 days.

Frequencies are 18 months.

DAEC RESPONSE 2 P.5 A NOTE has been added to SR 3.7.7.1 delaying entry Remove the NOTE aBowing delayed into the Required Achons for up to an hour in order to er.try into the Requred Actons. R is i perform the SR, sece the turtune bypass valve is made unnecessary 1 inoperable by the performance of the SR. This note is i

! not in 2he STS. -

i DAEC RESPONSE l

I i

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1

~

. DAEC ITS 3.9.1 REFUELING EQUIPMENT INTERLOCKS -

I 3.9.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS

- 1 A.2 , y CTS 3/4.9 Applicability applies to fuel handling and Provide addihonal discussion and

',- core reactivity linutanons during refueling and Core just:fication for the changed CTS

. Anerabons. ITS 3.9.1 Apf t 4 *t isi dunng in-wessel AppliemhiEty. - -- E i ,

i fuel movemert with equipment associated with the '3 ,

irdedocks when the Reactor Mode Switch is in the r I

Refuel Posibon. There is no justification for the ~, -

l chan0ed CTS Applicability requnng the Reactor Mode ,

Sestch in the Refuel Position.

I 2 A.3 ITS 3.9.1 AcBon A requires immediately suspending in- Provide discussion and justi6cahon for the l vessel fuel movement with equipment associated with more restnctiver chinge of adding the ITS the inoperable interlock (s) when one or more required Action. -

refueling equipment interlocks are inoperable. This ,, ,-

requirement is not addressed in CTS 3.9. There is Reclassify as more '

restrictive. f ~

inadequate discussion and Justification for adding the . ,

l ITS AcBon requinng immediately suspending in-wessel J# ,

fuel movement.

3 R.1 CTS 4.9.A.1.a and 4.9A.1.b have the ach ud hoist load Provide addibonel Mash and !

xWA These requirements are moved to plant jushfication identfying tte specfic plant procedures. ,

gm and how the requirements are contro5ad. .

p ".

e

. s 43 .. * ,'

.-__.-____.a_ _ _ _ _ - _-_ . -

I I

DAEC iTS 3.9.1 REFUELING EQUIPfJENT INTERLOCKS 3.9.1 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS

' 4 ITS SR 3.9.1.1 requires performing a CHANNEL Provide discussion and justification for the NONE. . 9

' 3 i* FUNCTIONAL TEST on each of the fonowing required adding the specdic interfock inputs.

refueling equipmcni interiock inputs: all rods in, refuel ,

5 platform posdion, refuel platforrn fuel grapple fuel *

~ *

. loaded, refuel platform fuel grapple fury retracted .

posdion, refuel platform frame mounted hoist fuel ,

. loaded, and refuel platform monorail mounted hoist fuel loaded. CTS 3/4 9 does not address the specific '

Intedock inputs. Thr.re is no discussion or justification

for adding the specific intertock inputs.

5 P.4 STS SR 3.9.1.1.g requres performing a CHANNEL Provide justification for the ITS deviation FUNCTIONAL TEST on the service platfc:m hoist. fuel based on current Ecensing basis. system

~

ioaded. This requirement is not retained in ITS SR desgn. or operationd censi=G.

. 3.9.1.1 The justrication states the service platform has been A=iued and removed. There is inadequate 'd r5mwh and justification stating if the current J

.' licens.ng basis is amended to address this issue. - .

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DAEC ITS 3.9.2 REFUEL POSITION ONE. ROD-OUT INTERLOCKS 3.9.2 DOC JFD CHANGE / DIFFERENCE -

COMMENT STATUS 1 M.2 ,.

CTS 3.9.A.1 requres the reactor MODE swikin locked Prowde rknasion and Justi6 cation for

!': In the " Shutdown

or " Refuel" posebon dunng Core adding the more testricHve switch position "g 9 Aterabons. Under the same conddions, ITS SR venficahon Surveillance Requirement 3.9.2.1. also requres ven6cahon every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that ,,

the MODE switch remarts locked in the " Refuel

t- .

posibon while ITS 3.92 is Applicable. There is no .

; discussion or justificaban for adding the addibonal . ,-

requrement to verihr the MODE switch posabort. .

2 M.1 ITS 3.9.2 Action A is added requinng the suspension of Provide rknasion and justi6cahon for '

coniros rod wahdrawal and achons inmated to fusy - adding the additional requirement if the '

insert at Artsertable control rods in core ceus cmtaining one4od-out interlock is inoperable. -

one or more fuel assemblies when the refuel possbon . .

orwwod-out interlock is inoperable. CTS 3.9 does not p ' i ~ #

. contain any requirements if the one-rod-out interlock is . * *

, '," i .. f. i >

! Inoperable. There is no jushficabon for adding the additionei roquirement r the one4od-out intertock is .r ' 7. " .

inoperable. :

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4

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'. - DAEC ITS 3.9.3 CONTROL ROD POSITION .

3.9.3 DOC JFD CHANGE / DIFFERENCE COMMENT . STATUS

. 1 NONE. CTG 3.9.A.2 requires that fuel is not loaded into the Provide discussion and justification for

' . O. reactor core unless aR control rods are fully inserted. adding the Action of immediately ITS 3.9.3 Action A requires immediately suspending suspending loading fuel assemblies.

' <1 '

loading fuel assemblies into the core when one or r.1ere control rods are not fully inserted. There is no

l '

discussion or justification for adding the Action to >

~

immediately suspend loading fuel when a cordrol rod is ,

not fuey inserted. .

i 2 A.2 . CTS 3/4.9 Applicability applies to fuel handling and Pmvide additional discussion and I core reactivity timstations dunng refueling and Core justifcation for the changed CTS ARerations. ITS 3.9.3 Applicability is when loading fuel Applicabelity. ' -

ass &Ccs into the core. There is no justification for .

. the dwged CTS Applicability. ' .

A l --

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,. 4 .

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DAEC ITS 3.9.4 CONTROL ROD POSITION INDICATION . .

3.9.4 DOC JFD CHANGE /DIFFtHENCE COMMENT STATUS

No .. .. .. .

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. DAEC ITS 3.9.5 CONTROL ROD OPERABILITY-REFUEUNG 3.9.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS

,j 1 L1 . p CTS 4.9.A.2 requires a control rod recoupiing check for Provide additional discussion and .

j j' ." any dontrol rod drive .T,alw.rdsm that has been justification for m0ving the CTS l . Uncoupled and then recoupled. verifying that the requirement to ITS 3.j0.8. ' -

! Y control rod does not go to the overtravel position. This . , . * . .

ll regurement is moved to ITS SR 3.10.8.5. ITS 3.10.8 ,

? }, ,

Is a r*w shutdown margin testing requirement and

(

4 i CTS 4.9.A.2 is not indicated as part of the new . 3.,

~ -

requirement. There is no discussion and justification M

for moving this requirement to ITS 3.10.8. '5

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+ _

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l ,. DAEC ITS 3.9.8 REACTOR PRESSUREVESSEL(RPV) WATER LEVEL . .

I s

~

j 3.9.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1

l j 1 P.2 ' , STS 3 9.6 requwes reactor pressure vessel (RPV) Prtmide Jushfication for the STS deviabon y.' water level 2 23 ft above the top of the RPV flange. based a current licensing basis, system .

, 3 iTS 3.9.6 requwes reactor pressure vessel (RPV) design, or operational c6hstraints.

l water level 2 23 ft above the top of the m ' .C"-d

?

i fuel assemblies seated within the RPV. The

t .

~ * .

4

. h% for 23 ft above the irradiated fuel

- assemblies seated wthin the RPV instead of the . g .1 i RPV flange does not relate to the justificabon for the A * ' ,' *a.~. f

~

21 ft-1 inch value in ITS 3.9.7. 21 ft-1 inch . . . t .

~.

conesponds to a level of 36 feet in the spent fuel ,- : : ',. '.,e - .

pool which is the runinum required by the current ,

1 iscensing basis. 23 rt above the fuelis not. ': . * , , e aM W. , ,

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- - - . . - - - - , , - v - _ -- ,

DAEC iTS 3.9.7 RESIDUAL HEAT REMOVAL (RHR). HIGH WATER LEVEL. .

3.9.7 DOC JFD CMANGE/ DIFFERENCE COMMENT STATUS 1 ,

M.1 J A new requirement, not addressed in the CTS is added Provide discussion and justWication for

, ,, ' p .,

to the ITS. ITS 3.9.7, Residual Heat Removal (RHR) - adding the new requiremerA. .

.,,- High Water Level, and the associated Conditions. 5, 3 ! ,

6 l , .

- Required Achons, CuiTAL-- Times. Notes, and .

s i SurveRance Requirements, requres one RHR - '

i Shutdown Cooling (SDC) subsystem Operable and in ' ', ,

t operabon in Mode 5 when reactor coolant temperature Is 2150*F. There is no justification for adding this i : new requirement. - . .

2 . P.3 STS 3.9.8 requires one RHR shutdown cooling Provide justi6ca6er' fu. the STS deviaten subsystem OPERABLE and in operabon. ITS 3.9.7 based on current Ecensing basis, system -

requres one RHR shutdown cooling subsystem design, or operational censtraints. -

OPERABLE and in operabon when reactor coolant 3 & ,.

'. temperature is = 150*F. The justficahon states an . --

3 . .,

. evaluason was performed and procedures are in place .; ,#

t.

to mantain temperature t etween 80*F and 140*F.

l ; There is no Justecation stannc the evaluston was - .;.

~

, , . 2,

? conducted to ve:tfy compsance with the licensing basis, , ,-

.~.s, j .

system design, or operanonal constraints to justify '

adding the 150*F temperature to have RHR shutdown coonng operahng.

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DAEC ITS 3.9.8 RESIDUAL HEAT REMOVAL (RHR}- LOW WATEft LEVEL

~

3.9.8 DOC JFD CHAT.'GE/ DIFFERENCE - COMMENT STATUS

~

i 1 M.1 .

A new requirement nc* addressed in the CTS is added Provide discussion.and Justification for

. ~p,. O , lo the ITS. ITS 3.9.8, Residual Heat Removal (RHR) - adding the new reduireme.%

Lo* Water Level, and the associated Conditions. k' y # .$ " ..

Required Actions Completion Times. Notes, and .

3 ',' Y #ti .

Surveillance Requirements, requires two RHR *4 , i,*i i ,

i c{ Shutdown Cooling (SDC) subsystems Operable and . ' . .' I f .*- *

~ .' one RHR SDC subsystem ii operation in Mode 5 with -

,. +. q

, water level < 21 ft-1 inch above the top of the RPV ,

3~ ,

flange. Ther$ is DO justificat*31 for adding thing new i ~ '"

I. .

,4l ,

requiremefit. , -

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i l DAEC ffS 3.1S.1 SYSTEM LEAKAGE ADW HYDROSTATIC TESTING OPEr ATION l 3.10.1 - DOC JFD CHANGE / DIFFERENCE COlmENT ~ - STATUS '

1 A.1 .. ITS 3.10.1 adds aparde Conditions, Required Actions,- W as a more restrictive change. i and Completion Tenos related to system leakage and j hydrostanc metsig seouirements to the CTS Provide discussion and)% for ;

j seguimunents. The CTS does not eurdirey contain this more restrictwo change j4 these sequimments. Adding sequinwnents to the CTS is j- a mom sesencewe dienge. There is no h* or -i

JumelEcstion for Wiis sucre restnctive change. )

i4 >

l 2 P.1 in its entirety, ITS 3.10.1 is near W that is not Provide)% for the STS !

j contained in the CTS. Accordingly, there is no CTS deviation booed on cunent Econsing

! markup. A comparison of the STS 3.10.1 seguirements beeis, system design, or operational ;

j and tie ITS 3.10.1 seguirements irh that the Ituo constrants.

contain the same seguirements. Hoimever, STS 3.10.1

--l contains several soforences to reactor coolant maperatu of p00 rt These am as changed to j;

i 212* F. This is a deviation from the STS. There is j irW* discussion and)% for this STS l i devianon. t t

i

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DAEC ITS 4.0 DES 8GN FEATURES AATAsL40.DAo g 7n7.37 4.0 DOC JFD CHANGE / DIFFERENCE COMMENT.. STATUS

?

I '

, 1 A.3 The CTS 5.5 Bases describes the P4 designed new Provide discussion that identifies what fuel storage rocks and the: :siculations that were the three CTS 5.5 references are, where tl'

! performed to determine the bounding reactivity limits the i are referenced, where they are

+ for GE MF.e.d fuel bundles when stored in the spent kept, and how they are controlled.

l fuel storage rocks. ITS 4.3 and its Bases do not inciale a dascription of their change

.. je contain this information. The CTS 5.5 Bases are control process.

il deleted. However, the limits specified in the CTU 5.5 8 Bases are contained in ITS 4.3.1 and require prior NRC 3

!- approval for changes. The discussion states that this ,

information is contained in the three references specified in the CTS 5.5 Bases, and that change

, control for this Bases material is in accordance with

! the change control for the references. The discussion

! does not specify exactly what the CTS 5.5 references are, where they are referenced, nor where they can be found. There is not adequate discussion concoming the change control process for these references 2 A.4 CTS 5.1 includes a reference to UFSAR Figures 1.2-1 Provide descussion and justifestion for and 1.2-2 for a plan of the site. ITS 4.1 does not deleting the reference to the site plan in contain this cross reference. There is no dis.cussion or UFSAR Figures 1.2-1 and 1.2-2.

juusfication for deleting this cross reference.

3 M.1 General "M" Comment: None of the discussic.. Provide justifmation for each change M.2 associated with M.1 and M.2 justify their respective discussed, change. Each discussion presents a succinct rGers=*irm of the change, but does not justify it.

j ,

i '

i 4 DAEC ITS 5.0 ADNTIVE CONTROLS ;

1 i

) _ 5.0 DOC XD u. , CHANGE 9 DIFFERENCE ,

CORAE*87 2*' -

x STATUS ,

i l.

1 R.3 ,,

CTS 6.11.2 Irwendam the naquimments for the Core Accepeance of this change to CTS

=. Operating Unuts Rooort (COLR). In the CTS the COLR requirements is contingent upon the ~!

!: requims ame=hE=hing core Emits for Linear Heat appErahaisy of the letter frorn A.C.

'3 Thandani (MtC) to J.S. Camley (GE),

Generation Rate (LHGR). ITS 5.6.5 does not include

.l Wils i=;

1121.:. Jusencation for this change to CTS *Accaptarice for Refenmcing of .

l4 : requimments is based on a letter frorn A.C. Thandani Amendment 19 to Genend Electric

! (NRC) to J.S. Camley (GE), "Armpearice for Licensing Topical Report NEDE-24011-P-Referencing of Amendment 19 to General Electric

~

A (GESTAR-II), General Electric Standard Licensing Topical Report NEDE-24011-P-A (GESTAR-il), Application for Paar4ar Fuel," dated april General Electric Standard Application for Paar4ar Fuel," 7,1987, to the DAEC submittal. Provide a

!. dated aprE 7,1987. reacismaing or the app 5cabigty of this

! change to DAEC.

DAEC RESPONSE

~

2 P-26 STS 5.2.2.e requins Die amount of overtime worked by Review #m MtC letter from C.1. Grimes unk semit members perfonning safety reisted functions to J. Davis of PEl, of Apr5 9,1997, .

shes he ihnned and controsed !n accordance wik Jie addreening appropriate overdme control NRC PoEcy Statement on working hours (generic Letter requimments; and adopt.

82-12).

s DAEC RESPONSE '!

3 R.9 CTS 6.8.2 Irwend== See delats of tie rewiour and The dotaBs of tie reviour and appmval i appavat process and CTS 6.8.3 Irwendas datans for tio pecess and Sie detaEs for sie temporary i

temporary diengo pocoes fori-+:+f-n The ITS change pocoes sha3 he raine=aad to the

!. does not inctude tiees delats. The dotats are snowed QAP. The revised QAP sheE be outside Sie ITS fo upararmad plant prM=es. subm8ted to the 95tC for rewiour, prior b Die leeuence of Sie Ensi 95tC SE.

DAEC RESPONSE i

5 DAEC ITS 5.0 ADMINISTRATIVE CONTROLS i

i

.i i 5.0 - DOC JFD CHANGE / DIFFERENCE ' COMMENT' STATUS j;. 4 R.t1 ,,

CTS 6.4.1 lists the training program reouirements of the Provide a discussion including which

!; operating organization. This CTS requwement is moved specific Licensee Controlled Document (s)

' outside the iTS to unspecified Licensee Controlled include the CTS training requirements

} Documents. and that they meet 10 CFR 50.54 and 10 i

CFR 55 requirements. Also, review the NRC letter from C. I. Grimes to J. Davis of NEl, of April 9,1997, addressing a new l;;

paragraph on qualification requirements;

', and adopt.

l' DAEC RESPONSE 1

. 5 R.10 CTS 6.8.5 includes details on the preventive and Provide discussion including which conechve maintenance program. These details are specific procedures include the details of rnoved outside the ITS to unspecified plant conbctd the CTS requirements for the preventive documents. and conechve maintenance programs, including their control mechanism.

DAEC RESPONSE

6 A.12 P.21 STS 5.7.1 requires entry into high radiation areas Provide jushfication for the STS deviation, controlled by a Radiahon Work Permet (RWP). G 5.7.1 explaining why the added attemative requwes entry into high radiation areas controlird a means of c'haton is necessary.

RWP "or a work document which includes radioSq:re) requwements normally associated with a RWP." Se discussion does not show an equivalence titween the RWP and work document requirements fo6 entenng High Radishon Areas. There is inadequate Justification for the STS deviation.

DAEC RESPONSE i

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

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

DAEC ITS 5.0 ADMINISTRATWE CONTROLS i

5.0 . DOC :JFD CHANGE / DIFFERENCE - : COMMENTS STATUS

. 7 ,,

CTS 6.9.2.c and STS 5.7.1.c require an individual incorporate the deleted CTS and STS

< i qualified in radiation protechon procedures to perform requirements into the ITS.

i ;!

periodic radiation surveillances in a high radiation area i ; st the frequency speedied by the facility [ Health Physics]

supervisor in the RWP. ITS 5.7.1.c requwes the same

! ', surveillances but changes the frequency to, "as l ;' necessary," and it deletes the requirement for control by a [Radiabon Protection Manager]. There is no discussion orMia. tion for these deviates to the CTS and STS requwements.

DAEC RESPONSE 8 R.11 P.13 STS 5.7.2 reqaires an RWP prior to entering a high Review the NRC letter fmm C. I. Grimes radiahon area (>1000 mr). ITS 5.7.2 allows exemphng to J. Davis of NEl, of April 9,1997, Health Physics personnel or personnel continuously addressing a new High Radiation Area escorted by such individuals fro n the RWP requirement specdication, and the associated areas

if they are performing their assigned dubes and listed; and adopt.

otherwise following plant radiabon protechon procedures for entering a high radiation area. There is no justdication for this STS deviation. Also, CTS 6.9.2 includes footnotes " and "* that specify measurement distances from a radiation source to determine personnel dose rates. ITS does not include the i footnotes.

DAEC RESPONSE 1

_ - . , - -, __ . , , . , , _ _ . _.m_, _ . , . . , ,m. - _ - - . - _.- _ , -____ .--,______m_,,.__

- _ , -- + =-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

o .

! DAEC ITS 5.0 ADMINISTRATIVE CONTROLS 5.0 DOC JFDj CHANGE / DIFFERENCE . ,

COMMENT STATUS 9 R.14 .. CTS 6.10 includes the requirements for Record Record Retention requirements are to be

.' Retention. This CTS requirement is moved outside the moved to the QAP. The revised QAP

! shall be submitted to the NRC for review, ITS. There is no discussion on where these l requirements are moved or how they are controlled. prior to the issuance of the final NRC SE.

4 i DAEC RESPONSE

! i 10 R.17 CTS 6.15 includes change control requirements for the PCP implementation and change control Process Control Program. ITS 5.0 does not include requirements are to be incorporated into these requirements. The CTS requirements are moved the QAP. The revised QAP shall be outside the ITS to unspecified plant procedures. submitted to the NRC for review, prior to the issuance of the final NRC SE.

1 DAEC RESPONSE 11 M.3 ITS 5.2.2.b adds staffing requirements that were not in Review the NRC letter from C. :. Grimes L8 the CTS. CTS Table 6.2.1 on minimum staffing to J. Davis of NEl, of April 9,1997, requirements has been removed from the ITS. These addressing staffing requiren'ents, and the staffing requerements are redundant to associated areas; and adopt.

10 CFR 50.54(m).

DAEC RESPONSE

,,.-% e , , . ,,,-..,, v

. . . , - - . ._f . - - y - - . - - - , -- . , . . , .-%. -

DAEC fTS 5.0 ADMNISTRATIVE CONTROt.S

- 4

.5.0 :f DOC TJFDs ,

- . CHANGE /DIFFERENCEn

7, :

. ,p, j l,7 g ,COMMEN Q

- . STATUS

, u l 12 L7 ,,

CTS 4.10.A.2, main control room SFU system and CTS The requested extension of the CTS j; 4.7.L2.a. SBGT system, require testing and sample refueling Survemance Test interval from

! analysis annusBy or after every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of system 18 to 24 months has been withdrawn.

operation, IAW ASME-N510-1989; not to exceed 720 This SR frequency should revert to that in hours. The STS requires testeg IAW ASME-N510-1989. the CTS.

, ITS 5.5.7 requires the same testeg and analysis but i extends the CTS Survedance Test interval from p annuaBy to 24 months and from 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months to 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months .

, DAEC RESPONSE ii j 13 P.10 STS 5.5.8.d requires demonstratmg for each of the ESF Provide Jt.'J -a- for the STS deviation j systems that the pressure drop across the combined (only SBGT has preft%u?).

i HEPA tihers, the pre-filters, and the charcoal absorbers j

is less than the value speo6ed in a listed chart. ITS I 5.5.7.d requires the same testeg but adds (SBGT i system only) after the pre-fillers.

DAEC RESPONSE 14 A.2 CTS 6.2.1 plant management titles are changed Acceptance of this change is contingent throughout ITS 5.0 based on TSTF-65. on the NRC acceptance of TSTF-65.

l;, DAEC RESPONSE i>

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ML20217N930

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Dear Mr. Liu:

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ML20217N930

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Dear Mr. Liu:

Enclosures:

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