ML20198K959
| ML20198K959 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/12/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20198K961 | List: |
| References | |
| RTR-NUREG-1432 TAC-M97363, TAC-M97364, NUDOCS 9801150138 | |
| Download: ML20198K959 (18) | |
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1 Curates H. Unt;st Baltimore Gas and Electric Company -\
Vice President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby Maryland 20657
- 410 495-4455 January 12,1998 U. S. Nuclear Regulatory Commission -
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Washington, DC 20555 -
ATTENTION: Docunient Control Desk pl
SUBJECT:
Calvert Cliffs Nuclear Power Plaat Unit Nos.1 & 2; Docket Nos. 50 317 & 50-318 j
Revision 11 to the License Amendment Reauest to Convert to the Improved ..
Technical Soecifications (TAC Nos. M97363 and M97364) _ f REFEREI CE: (a) Letter frem C. H. Cruse (BGE) to A. W. Dromerick (NRC), dated '7 ' il December 4, !996, License Amendment Request to Convert to the l improved Technical Specifications (TAC Nos. M97363 and M97364) l
~y il
-y Reference (a) was the initial application to convert to the improved Standard Technical Specifications. 3- j Revisions to Reference (a) have been submitted in response to Nuclear Regulatory Commission .
j questions and comments. Additionally, dUcussions have been held between the Nuclear Regulatory 4 H Commission Staff and Baltimore Gas and Electric Company personnel to clarify the information -J .
jl contained in the application and revisions. As a result of these discussions, additional changes are being *
.l made to the initial application. Thir letter provides R: vision iI to Reference (a). .
i These changes come from four sources. The first source was comments from Nuclear Regulatory Commission reviewers. The second source was comments from Calven Clif's personnel. A comparison '=-t was done of the Improved Technical Sp ,ifications (ITS) and NUREG-1432 markup which resulted in i*
adFional changes. The last source of changes was a review done to identify any editorit.1 corrections needed to ensure consistency throughout the ITS and with Calvert Cliffs terminology.
Attachment (1) contains revised pages for the tables submitted previously in response to various . tuests for aaditional information. Attachment (2) provides a minor revision to the Summary of Changes provided for Revision 6. Attachment (3) contains Revision 1I by ITS section, for ease of replacing pages in the original amendment request. Page replacement instructions are provided. All changes are marked with revision bars and labeled Revision 11.
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9901150130 900112 PDR ADOCK 05000317 '
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f " DocEment Control Desk January 12,1998 Page 2 Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
/ ,g- yg STATE OF MARYLAND :
- TO WIT:
COUNTY OF CALVERT :
I, Charles 11. Cruse, being duly sworn, i.. ate that I am Vi e President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this License Amendment Request on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants Such information has been reviewed in accordance w'th company practice and I believe it to be reliable. ) /
//
_/ 1Ar/ 2%/ -
Supscribed and sworn before me, a Notary Public in and for the State of Maryland and County o' CdAldW , this /At/Aay of OuulukM 1998.
0 0 WITNESS my lland and Netarial Seal: M M) b. 4LU I
Notary Public My Commission Expires: S '
/ b bN I Date CilC/ PSF /bjd Attachments: (1) Revision to Responses to Request for Additiona Information (2) Revision to Summary of Changes (3) Revision by ITS Section ec: M. L. Reardon, NRC (With Attachment 2 only)
R. S. Fleishman, Esquire 11. J. Miller, NRC J. E. Silberg, Esquire Resident inspector, NRC Director, Project Directorata I-1, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. II. Walter, PSC d
ATTACHMENT (1) l i
IMPROVED TECHNICAL SPECIFICATIONS, REVISION 11 REVISION TO RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant January 00,1998 b.
f ATTACHTENT (1)
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.3.1 DOC 'JFD CHANGE / DIFFERENCE . COMMENT STATUS-BGE Response:
DOC M.7 will be provided to discuss this change. -
21c CTS 4.3.1.1.2, test of total bypass function during Channel Calibmtion, is ' Revise the submittal with 5/20/97 retained as ITS SR 3.3.1.7 Channel Functicnal Test (CFT) of the automatic an explanation. open bypass removal feature. The submittal contains no explanation of the equivalence of these two test requirements.
BGE Response:
CT' ' :.1.2 is retained as both ITS SR 3.3.1.7, Channel Functional Test, and ITS SR 3.3.1.8, Channel Calibration. The Char 4nel Functional Test ens - use operability of the logic, and the Channel Calibration confirms setpoints, as stated in CTS 4.3.1.1.2. These tests are defined in Section 1.0.
21d ITS 3.3.1, Table 3.3.1-1, Function 1, Power Level- High .
Revise the submittal with 5/20/97 CTS 3.3.1.1, Table 4.3-1, Functional Unit 2.b, DT Power Level - High an explanat,on. open The DT power level - high function is not discussed in the Bases for iTS 3.3.1.
BGE Response:
The delta T power level provides an input to Q power. This is described in the NUREG Bases markup. Delta T power is also described as primary calorimetric power in the Bases. The Pressurizer Pressure-High, Containment Pressure-High, and Steam Generator Water Level- Low functions do not have bypass notes, as shown in CTS Table 3.3-1.
22 ITS 3.3.1, Table 3.3.1-1, Revise the submittal with 5/20/97 Function 4, Pressurizer Pressure - High an explanation. open (Note:
Function 5, Containment Pressure - High This comment is repeated t Function 7, Steam Generator Level - Low for the power level - high Function 9.b, Asymmetric Steam Generator Transient functic nal unit in comment ITS SR 3.3.1.7 Channel Functional Test (CFT) - automatic bypass removal 28.a.)
feature CTS 3.3.1.1, Table 3.3-1, coc = oiscussion of change 10 JFD = Justification for Deviation
ATTACHMENT (1)
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3
- CHANGE / DIFFERENCE COMMENT STATUS JFD 3.3.2}fDOC BGE Response: ,
See response to Request for Additional information 3.3.1-4.
CTS Table 2.2-1 specifies an Allowable Value for the power Revise the submittal with a suitable maricJp 5/28/97 4
, rate of change - high channels of > 2.6 decades pec minute. of CTS Table 2.2-1 Functional Unit 11 in the open 8 A CTS markup of this requirement is not included in the CTS markup for ITS 3.3.2, and also with a submittal for ITS 3.3.2 in addition, ITS 3.3.2 differs from suitable DOC. Acceptance of specifying the STS 3.3.2 by stating the allowable value in ITS SR 3.3.2.4, allowable value in ITS SR 3.3.2.4 is not in LCO 3.3.2 as in the STS. This difference is based on contingent on NRC approval of TSTF-82.
TSTF-82, which has not yet been approved by the NRC.
BGE Response:
This was corrected in a previous Supplemental Amendment Request which incorporated TSTF-82 Revision 1, approved by the Nuclear Regulatory Commission (NRC).
CTS 4.3.1.1.2, test of total bypass function during Channel Revise the submittal with an explanation. 5/28/97 5 A.1 Calibration, is retained as ITS SR 3.3.2.3 Channel open Functional Test (CFT) of the automatic bypass removal See comment 3.3.1-21c feature for the power rate of change - high function. The submittal contains no explanation of the ec;uivalence of l
these two test requirements.
In addition, STS LCO 3.3.2 does not specifically include Acceptance of this difference contingent on automatic bypass removal feature for the power rate of NRC approval of CEOG-91.
change - high channels, but ITS LCO 3.3.2 does. This difference is based on TSTF-160 (CEOG-91) which has not yet been approved by the NRC.
BGE Response See the response to RAI 3.3.1-21.c for the response tc the first comment. The second comment will be justifed by DOD-34.
doc = Diaarssion of Change 13 JFD = Justrficaten for Deviaten L_.._______ -. -
ATTACHMENT (1)
RESPONSES TO REQUEST FOR ADDITIONAi. INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.3 3.5.5 ' DOC JFD CHANGE / DIFFERENCE COMMENT STATUS the requirements on a per AFAS basis or a per steam generator basis. Manual Start is liste *, and ITS 3.3.5 requires 2 channels, not the eight pushbuttons of CTS Table 3.3-3, Function 9.a.
BGE Response:
DOC L2 will be provided to justify the change. DOC A.9 w;ll not be used.
8 ITS Table 3.3.5-1, adds Function 6.c, Steam Generator 1 Frovide a description of ITS Table 3.3.5-1, 6/3/97 Isolation (Block) Logic, and Function 6.d Steam Generator Function 6.c, Steam Generator 1 Isolation open 2 Isolation (Block) Logic, to STS Table 3.3.5-1. TheITS (Block) Logic, and Function 6.d, Steam 3.3.5 BASES, LCO 6, does not include a description of ITS Generator 2 Isolation (Block) Logic in the Table 3.3.5-1, Function 6.c and 6.d. ITS 3.3.5 BASES, LCO.
BGE Response:
Function 6.c and 6.d were removed as part of Revision 8.
9 ITS 3.3.5, Condition B, adds a second Condition to STS Provide additional discussion and 6/3/97 3.3.5, Condition B. The Condition added is two AFAS justification for this change, showing how open Manual Actuation Logic channels inoperable. iTS 3.3.5, ITS 3.3.5 provides appropriate Actions for 2 Condition D, adds a second Condition to STS 3.3.5, inoperable, non-manual AFAS Actuation Condition D. The Condition added is one or more Functions Logic Channels.
with two non-AFAS Manual Trips or Actuation Logic channels inoperable. The additions are based on TSTF- Acceptance of this STS deviation is 187 (CEOG-99) which has not yet been approved by the contingent on NRC approval c' CEOG 99 NRC. However, with this STS deviation, there is no specific (TSTF-187).
Condition that provides Actions for 2 inoperable, non-manual AFAS Actuation Logic Channels.
BGE Response:
See response to RAI 3.3.5-2.
DOC = Discussion of Change 28 JFD = Justification for Deviation
ATTACHMENT (1)
RESP SES TO REQUEST FOR ADDITIONAL INFORMATION IMPh0VED TECHNICAL SPECIFICATIONS SECTION
3.6 DESCRIPTION
OFISSUE _
DAE DAE COMMENTS
- NO. JFD LCO OPENED CLOSED 3.6 3-13 None STS STS SR 3.633, SR 3.63.4 and their associated 5/16/9' Licensee to update submittal SR 3.633 Bases have been modified by TSTF 45 Rev.1. in accordance with TSTF 45 STS ITS SR 3.63.2 and SR 3.633 have incorporated Rev I or provide additional SR 3.63.4 and TS fF 45. However, their associated bases are not discussion and justification Aseiated Bases in accordance with TSTF-45. for the bases deviation.
'fS SR 3.63.2 ITS SR 3.633 and Associated Bases CCNPP Response:
TSTF-45 Revision I will be incorporated into the ITS submittal.
ITEM DOC / CTS /STS - DATE DATE NO. LCO JFD OPENED CLOSED No comments for 3.6.4.
DOC = Drscussion of Change 13 JFD = Justification for Deviation
ATTACHMENT (1)
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7
'3.
7.1 DESCRIPTION
OF ISSUE "
CO OPENED C SD 3.7.1-6 JFD-17 STS SR 3.7.1.1 STS SR 3.7.1.1 states that following testing the 5/30/97 Delete this change in ITS SR ITS SR MSSVs lift settings shall be within i 1% to allow for 3.7.1.1. See item Number 3.7.1.1 and Associated drift. ITS SR 3.7.1.1 deletes this requirement from 3.7.1-2.
Bases. ITS SR 3.7.1.1 but retains it in the Bases for SR 3.7.1.1. If the requirement is to be retained per JFD 17 in the Bases, it must be specified in the SR. See item Number 3.7.1-2.
CCNPP Response:
The requirement will be placed in the ITS, and DOC M.2 will be added to describe the change.
3.7.1-7 Bases STS B3.7.1 Bases- STS B.3.7.1 Bases-BACKGROUND states the 5/30/97 i Delete this change. See JFD 7 BACKGROUND ITS following: "The MSSV design indudes staggered item Number 3.7.1-2.
B3.7.1 Bases setpoints, according to Table 3.7.1-1, in the BACKGROUND accompanying LCO,.. " ITS B3.7.1 Bases-BACKGROUND deletes the words "according to...LCO," The justification (Bases JFD 7) states that the deletion is made to conform with changes made to the specification. Since both tables are to be retained, the deletion is unreptable. See item Number 3.7.1-2.
CCNPP Response:
The statement has been retained in the Bases. I 3.7.1-8 Bases STS B3.7.1 Bases LCO STS B3.7.1 Bases - LCO states the minimum 5/30/97 De!ete this change or provide JFD 7 ITS B3.7.1 required MSSVs required in MODES 1,2, and 3. additional discussion and Bases LCO ITS B3.7.1 modifies the STS writeup baseL on justification based on current changes made to the specification (Bases JFD 7). licensing basis, system No changes made have been made to the design or operationa' specification which would necessitate, the ITS constraints.
proposed changes.
CCNPP Response:
JFD 3 will be used to justify the changes instead of JFD 7.
DOC = Discussion of Change 4 JFD = Justirication for Deviation
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3 ATTACHM. (1)!
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. RESPONSES .TO REQUEST FOR ADOITIONAL INFORMATION >
P NrROVED TECHNICAL SPECIFICATIONS SECTION'3.7 -
p I
CTSISTS E ATE, DATER (3,7,7";
~- DOK r OFISSUE 'Y188hapedTS ij eJFD: LCO ' OPENED CLOSED 3.7.7 JFD 12 STS 3.7.8 ITS 3.7.7 uses STS 3.7.8 as the basis for this CTS 5/30/97- Provide additional docuetuon Ranma RA A.1 - requrement STS 3.7.8 RA A.1 has two Notes and) ^^~ 4-i booed on te JFD 7 - ITS 3.7.7 '- assocated with it. Note 1 deals with entenng LCO system design or operabonel . .
RA A.t and Assocated 3.8.1 when the DG is made _ inoperable by SWS constraints to'shour that me Bases inoperability and Note 2 does the same for LCO Notes should be' deleted, u
, 3.4.6 for shutdown cooling ITS 3.7.7 RA A.1 See . Item Numbers 3.7.5-5 6
- deletes both these Notes. Baesd on the ITS and 3.7&1.
l B3.7.7: oase-BACKGROUND system desenpbon as well as the h system desenphon for the CCW system and SRW system, these Notes may
, have to be retained See item Numbe.13.7.5-5
- and 3.7.6-1.
! CCNPP Response .
These notes are restored, and appropnete markups provided DOC A.4 and appiupii i markups will be provided to jushfy this change. This change cienfles an f industry-wide accepted practee
, -13.7.7 JFD 12 ITS SR 3.7.7.1 ITS SR 3.7.7.1 Note states isolabon of SW flow to 5/30/97 - l_ Provide docussion and Bases and Associated Bases individual uniip06 6is does not render the SW jusblicabon lforithis; Less JFD 7 inoperable This Note is not in the CTS. There is Restnchve change no discussion or ji_.W-M-i for including this Note ,
in ITS SR 3.7.7.1.
CCNPP Response The NUREG Note pertaining to individual ccivipunent isolabon will be added to the CTS markup with DOC A.5 to jushfy the Note. ,
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1 3-T j JFD = Justdcaten for Deviabon ,
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ATTACHMENT. (1)
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.7 -
3.7.10 DESCRIPTION OF ISSUE D C and is urW to the staff. There is inadequate justification for removing the CTS requirement for two fans OPERABLE. This change is considered a beyond scope of review for this conversion.
CCNPP Response The Operability requirements for the Emergency Core Cooling System Pump Room Exhaust Fihtion System have been revised to be consistent with CTS LCO 3.7.7.1. Tney are stated in the Bases. Also, the Actions for ITS 3.7.10 have been revised to be consistent with the Acho_ns for CTS 3.7.7.1.
3.7.10-2 JFD 1 STS SR 3.7.13.5 STS SR 3.7.13.5 venfies that each ECCS PREFS 5/30/97 Either include STS SR Bases ITS B3.7.10 Bases- filter byprss damper can be opened ITS B3.7.10 3.7.13.5 in the ITS or provide JFD 7 BACKGROUND Bases-BACKGROUND states during emergency additional discussion and operations the ECCS PREFS dampers are justificabon tesed 0:e current realigned to initiate filtration. STS SR 3.7.13.5 is licensing basis, system deleted from ITS 3.7.10 based on a general design or operatiorei justification on items not consistent with t.e constraints to justify the CCNPP design. The justifications in this case are deletion of STS SR 3.7.13.5.
the wrong justification since the design does -
include bypass dampers.
CCNPP Response:
The Standard Technical Specification (STS) surveillance was written for designs that have a bypass line to provide cooling to a loaded filter train that has been shut ,
down post-accident. The Calvert Cliffs design does not include this feature. This change is based on the surveillance not being in CTS and the STS surveillance -
being in brackets. Therefore, while Discussion of Deviation 1 does not provide specific details, it is accurate. This system is operated manually and the ITS venfies system operation on a monthly basis. No additional surveillances are necessary to demonstrate flow through the filter train.
3.7.10-3 JFD 2 ITS 3.7.10 and See item Number 3.7.3-9. G30/97 Eee item Number 3.7.3-9.
Bases Associated Bases.
JFD 2 CCNPP Response:
- See response to NRC comrnents S3.7.3-1 and S3.7.4-1.
DOC = Discussion of Change 30
- ~D = Justification for Deviation
ATTACIIMENT (1)
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8
~
3.8.1 L : DOC. JFD CIIANGE/ DIFFERENCE - COMMENT ' ~ STA'IUS L BGE Response:
See response to RAI 3.8.1-2.
8 LA.2 Unit 2: CTS SR 4.8.1.1.2.d.1 Relocation of the CTS requirement His is an import nt part of maintaining DG to inspect the DGs in accordance with vendor reccmmendations reliability and should be incoiporated into a at every refueling is acceptable. Ilowever, relocation of this document / program for which controls have been requirement to plant procedares is not acceptable. established. The TRM or Maintenance Rule Program are acceptable for relocition. He licensee should revise the submittal accordingly.
BGE Response:
See response to RAI 3.8.1-3.
9 M.I Unit 2: Insert 3.8.1.17 He staff does not understand why the The licensee should provide a detailed ,
DG from the other unit is only required to be subject to 4 SRs. discussion of what is intended by this SR. -
Why is tne affected DG not required to undergo all SR testing?
BGE Response:
See response to RAI 3.8.1-4.
10 JD.10 STS SR 3.8.1.10 requires verifying each DG, operating at a Providejustification for the STS deviation based power factors [0.9], does not trip, and voltage is maintained 5 on current licensing basis, system design, or l [5000] V during and following a load rejection of > [4500] kw operational constraints.
, and 5 [5000] kw, every 18 months. ITS 3.8.1 does not include this SE requirement. Here is inadequate justification of deleting this STS requirement.
l BGE Response:
DOD 10 will be modified to provide adequatejustification. k i1 JD.10 STS SR 3.8.1.11 requires verifying on an actual or simulated loss Providejustification for the STS deviation band DCC = Discussion of Change 3 JFD = Justificar'an for Ikviation IIDD = Discussion of Deviation
ATTAC11 MENT (1)
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8
_3.8.1 DOC' JFD CIIANGE/ DIFFERENCE COMMENT STATUS of offsite power signal: 1) De-energization or emergency buses. on current licensing basis, system design, or
- 2) Load shedding from emergency buses. 3) DG auto-starts from opmition constraints.
the standby condition, loads, and maintains voltage and frequency for 2 5 minutes. ITS 3.8.1 does not include this STS requirement.
There is inadequate justification for deleting this STS requirement.
BGE Response:
DOD 25 will pmvided tojestify this change.
12 JD.10 STS SR 3.8.1.14 requires verifying each DG, operating at a Pmvidejustification for the STS deviation based power factor s [0.9], ope ates for 2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ITS 3.8.1 does not on current licensing basis, system design, or include this STS requirement. There is inadequate justification operational constraints.
for deleting this STS requirement.
BGE Response:
Improved Standard Technical Specification SR 3.8.1.14 will be retained, and DODs 26,28, and 29 will be provided to describe the deviations from the ISTS. k 13 JD.10 STS SR 3.8.1.15 requires verifying each DG starts and achieses, Providejustification for the STS deviation lased in s [10] seconds, voltage 2 [3740] V and 5 [4580] V, and on current licensing basis, system design, or frequency 2 [58.8] liz and 5 [61.2] IIz. ITS 3.8.1 does not operational constraints.
include this STS requirement. There is inadequate justification for deleting this STS requirement.
BGE Response:
DOD 10 will be modified to provide adequatejustification.
BASES DOC' JFD CilANGE/ DIFFERENCE CONC..ENT STATUS 3.8.1 DCC = Discussion of Change 4 JFD = Justincation for Deviation DOD - Discussion of Deviation
ATTACHMENT (1)
L RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION ,
IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8
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l ENf3RE.Gi llDOCL fJFDM W iCHANGE/ DIFFERENCE { . COMMENT * .STATUSi -i
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M3.8.P i=- - L ENUREG SR 3.F M 1he term "from standby condition" has been deleted The licensee.should provide'an ,
, Comment from the SR, but nojustification is provided. z.pyivpriate justification, to retain the NUREG
- 2- wording.
BGE Response:
1
.t l Deletion of the term "from standby condition" is provided in LCO DOD 49.
.t NUREG SR 3.814 Proposed Note 1. to this SR does not make sense. The Nete serves no purpose and Comment The licensee has chosen to use the symbol for " equal to or should be deleted.
- 3- greater than " for the loading requirements of this.SR. By ,
definition, there is no " load range."
BGE Response: j a
The ISTS Note allows the DG load to be either greater than the upper limit or less than the lower limit during momentary transients. Calver* Cliffs has kept the
, lower limit, and the Note is still applicable (i.e., during momentary transient where the load falls below the limit).. However, there is no load range, so " load range" .j i will be changed to" load limit" and maintain the Note.
4 . -
NUREG Note 3 is proposed for deletion.
NUREG 18 SR 3.8.1.4 The licensee should revise the .
Comment Justification 18 states that CCNPP is not currently restrained submittal to retain NUREG Note 3 to.this SR '!
- 4 from testing more than one DG at a time, and proposes to retain since it reflects the CCNPP current licensing their "right to do so." The staff disagrees with the Heensee's basis. -
position. CTS SR 4.8.1.1.2.a prefaces all DG SRs by stating j '
they will be conducted on a staggered test basis. Requiring staggered . testing eliminates the possibility for simultoneous testing, andjustification 18 is wrong.
BGE Response:
The Ncte will be retained.
NUREG 1 SR 3.8.1.4 The licensee has opted to retain the CCNPP CLB 1he staff requests'that the licensee Comment. with regard to DG loading requirements. Specifically, the provide such~. insight to aid - thel staff lin
- 5 loading requirements are stated in terris of " equal to or greater understanding the licensee's choice.
DJC = Discussion ofChange 13- ->
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- JFD = Justification for Deviation ,
EDD = Discussion of Deviation -
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ATTACIIMENT Q}
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECIINICAL SPECIFICATIONS SECTION 3.8
~
NUREG DOC JFD - 1 CHANGE / DIFFERENCE -
COMMENT - STA'IUS -
3.8.1 ,
NUREG 9 SR 3.8.1.11 & SR 3.8.1.12 Should the inclusion of these SRs in Comment the ITS, to the exclusion of c,ther SRs be found acceptable for
- 10 any reason, the 24 mo. frequency is still beyond scope.
BGE Response:
He 24 month frequency is the current licensing basis. Improved Technical Specification (ITS) SR 3.8.1.12 will be removed. justified by DOC Li1.
NUREG 1, 2, SR 3.8.1.I3 Changes to the NUREG SR (3.8.1.9) are proposed Provide adequatejustifications.
Comment 6 as follows: 1) delete the Note which prohibits performing this
- 11 SR in Modes I and 2, 2) deletion of the Note directing the SR be conducted at a power factor of < [0.9], and deletion of the SR acceptance criteria for frequency and voltage. He licensee has not provided an adequatejustifica: ion for any of these changes. l Herefore, they will be considered not acceptable pending receipt of adequatejustifications. Also, the change from IS mo. 7 to 24 mo. is beyond scope.
BGE Response:
DOD 32 and DOD 50 will be provided tojustify the changes to the Notes. DOD 6 was provided tojustify deletion of the voltage and frequency acceptance criteria deletions, and the deletions, are consistent with CLB. The 24 month fnxtuency is CLB. i NUREG 1 SR 3.8.1.12 (NUREG) He NUREG markup shows this SR as Comment being deleted. However, the indicated justification (1) does not
- 12 address this change at all. Deletion of this SR will be considered not acceptable pending receipt of an adequate justification.
BGE Response:
DOD 25 will be provided tojustify the deviation.
NUREG 1,2 SR 3.8.1.14 The changes associated with this SR are as follows: 1 Comment 21 1) the Pote prohibiting performance of this SR in Modes 1 and DOC = Disetnsion of Change 16 JFD = Justification for Deviation DOD = Discussion of Devisson
ATTACHMENT _(1)
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.6
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ITEM DOC / CTS /STS . DESCRIPTION OF ISSUE DAlli DATE ' COMMEN15 NO. JFD ; LCO -- _
OPENED CLOSED which require end device actuation every 92 days.
Justification L.4 does not state where this test is located. Ifit is located in ITS 33 then this portion of the change is an administrative change. Ifit is located in plant procedures or other licensee controlled document then it is a less restrictive (LA) change.
CCNPP Response:
CTS 4.6.2.1.a.1 has been retained as ITS .'.6.6.1 (see response to NRC question 3.6.6-3). CTS 4.6.2.1.b.1 has been deleted. Justifiestion for the change is provided as - '
DOC A.7 for ITS 3.6.6. As a result of these two changes, DOC L4 for ITS 3.6.6 and its associated No Significant llazards Considerations will be deleted, because they will no longer be appropriate.
3.6.6-8 JFD 6 ITS 3.6.6 JFD 6 states that a Note 5 has been added to ITS 5/16/97 Correct this discrepancy.
ACTIONS 3.6.6 ACT10NS. ITS 3.6.6 ACTIONS show only Note one Note being added. Here is no Note 5.
CCNPP Response: '
JFD 6 will be : vised to resolve the discrepancy.
3.6.6-9 BASES ITS B3.6.6 ITS B3.6.6 Bases-BACKGROUND " Containment 5/16/97 Delete this change.
JFD 8 Bases- Spray System" section second paragraph, first BACKGROUND sentence changes the word " reduce" to " minimize."
His change was reviewed by the staff as part of EDIT-18 and rejected based on the fact that it was a technical change with ir.suflicientjustification.
CCNPP Response:
His change will be removed.
3.6.6-10 None ITS B3.6.6 ITS B.3.6.6 Bases-BACKGROUND " Containment 5/16/97 Provide a discussion and l Bases- Spray System" section second paragraph, first justification for these deletions.
- BACKGROUND sentence and third paragraph deletes all reference l to Spray Additive System. Nojustification is l
DOC = Discussion ofChange 20 T"D = Justification for Deviation DOD = Discussion of Deviation l
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ATTACHMENT (1) ^
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RESPONSES TO REQUEST FOR ADDITIONAL INF0F.MATION -
lMPROVED TECHNICAL SPECIFICATIONS SECTION-3.6 r
- W' a; y COMMENTS w, ITEM DOC / CTS /STS e DESCRIPTION '" OFISSUEs MDATE!: 1DATEL A '_i ,
FngNO2 1 $JFDL 215 0}'
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-3/4.6.6.1-1 . None CTS CIS 3/4.6.6.1 is being moved ~ 5/16/97 Provide a discussion andjustification for this Administratrve
. 3/4.6.6.1. to ITS 3.7.12 Penetration change. -
Room Exhaust Ventilation System. Nojustification has been provided for Als ,
Administrative change.-
CCNPP Response:
Movement of requirements from one specification to another only requires ajustification in the specification to which it is being moval. In this case, nojestification is -
provided in the 3.6 Section, but it is provided as part ofIg7.12. DOC A.1 will be used tojustify the changes.
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I DOC = Ducussion ofChange 22-
- wD-Justification for Deviation DOD = Discus
- ion of Deviation ,
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ATTACHMENT (2) 1 4
IMPROVED TECHNICAL SPECIFICATIONS, REVISION 11 REVISION TO
SUMMARY
OF CHANGES t
l Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Janunry 00,1998
I ATTACHMENT (2) -6 forSedran 3.] rt At,rons l
SUMMARY
OF CHANGES l
- 49. A change was made to the Bases of LCO 3,7.3 to corisct a statement that the AFW pumps are only required to supply water to either steam generator. The pumps are required to be capable of -
supplying water to both steam generators for operability.
- 50. A change was made to the Bases of LCO 3.7.3 to correct a Bases Condition D statement to lb match the LCO and to identify examples of train inoperabilities versus pump inoperabilities in Conditions A, B and C. !
t St. Changes were made to the Background section of the NUREG Bases markup for ITS 3.7.8 to match the typed Calvert Chffs Bases. In addition, a statement in the Background sectior.
describing that the control room is pressurized has been deleted since the Control Room Emergency Ventilation System does not and is not assumed to pressurize the control room.
Some nomenclature and Bases statements were modified or removed to be consistent with plant design and nomenclature.
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