ML20149H578

Forwards Rev 2 to Bge'S Original Application to Convert to Improved Sts,Per NUREG-1432.Changes Result from Responses Provided in to NRC 970507 Rai.Tables in Attachment 1 Describes Each of Changes Encl

ML20149H578
Person / Time
Site:	Calvert Cliffs
Issue date:	07/21/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20149H580	List: ML20149H578 ML20149H582
References
RTR-NUREG-1432 TAC-M97363, TAC-M97364, NUDOCS 9707250052
Download: ML20149H578 (6)

Text

_

l CHARES H. CROSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 July 21,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 A'ITENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50-318 Revision 2 to the License Amendment Request to Convert to the Improved Technical Snecifications (TAC Nos. M97363 and M97364)

REFERENCES:

(a) Letter from A. W. Dromerick (NRC) to C. H. Cruse (DGE), dated May 7,1997, Request for Additional Information Regarding the License Amendment Request to Convert to the Improved Technical Specifications (TAC Nos. M97363 and M97364)

(b) Letter from C. H. Cruse (BGE) to Document Control Desk (NRC), dated June 18, 1997, Response to Request for Additional Information Regarding the License Amendment Request to Convett to the Improved Technical Specifications (TAC Nos. M97363 and M97364)

Reference (a) transmitted questions regarding Sections 4.0 and 5.0 of Baltimore Gas and Electric

/

Company's application to convert to the Improved Standard Technical Specifications. The responses I were provided in Reference (b).

Attached to this letter is Revision 2 to the original license amendment application. These changes result 6/

from the responses provided in Reference (b), as well as other changes identified by plant personnel.

Changes to the No Significant Hazards Considerations discussions are included where appropriate.

To assist in reviewing this revision, a table describing each of the changes is attached (Attachment 1).

All of the material for each change is grouped by change in Attachment (2). Attachment (3) provides the revision by Improved Technical Specification Section for ease of replacing pages in the original amendment request. Page replacement instructions are provided. All changes are marked with revision bars and are labeled Revision 2.

j 9707250052 970721 PDR ADOCK 05000317 b

P PDR DdO900 . . . . .

l Document Control Desk July 21,1997 Page 2 l

The Plant Operations and Safety Review Committee and the Offsite Safety Review Committee have reviewed revisions resulting in changes to the No Significant Hazards Considerations and concur that operation with the proposed revisions will not result in an undue risk to the health and safety of the public. Should you have questions regarding this matter, we will be pleased to discuss them with you.

l Very truly yours, l .

d]// sf k#

STATE OF MARYLAND  :

TO WIT:

COUNTY OF CALVERT  :

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

/

S se ibed and sworn before me, a Notary Public in and for the State of Maryland and County of

, this fl4Eday of Omfu idn1J ,1997.

WITNESS my Hand and Notarial Seal: bfM1AiJb MILb ;

Notary Public My Commission Expires: b h Date CHC/ PSF / dim Attachments: (1) Summary of Changes (2) Amendment Revision by Change (3) Amendment Revision by ITS Section cc: (With Attachment 1 only)

R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC A. W. Dromerick, NRC R.1. McLean, DNR Director, Project Directorate 1-1, NRC J. H. Walter, PSC 1

i ATTACHMENT (1) 1 1

l

]

4 4 IMPROVED TECHNICAL SPECIFICATIONS, REVISION 2 )

i i

SUMMARY

OF CHANGES

\

l l

l 1

Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant July 21,1997

ATTACHMENT (1) l IMPROVED TECIINICAL SPECIFICATIONS, REVISION 2

SUMMARY

OF CHANGES

1. A new Discussion of Deviation has been provided (Discussion of Deviation 27 to Section 5.0) to describe the ' current Calvert Cliffs requirement that the operations manager hold or have held a senior reactor operator license. This Discussion of Deviation justifies the change to NUREG-1432 Specification 5.2.2.f [ Improved Technical Specification (ITS) 5.2.2.f] as -

requested by the Nuclear Regulatory Commission (NRC) in their comments to Section 5.0 (comment 3).

2. Discussion of Deviation 5 to Section 5.0 has been revised to provide the Current Technical Specification (CTS) Amendment number that added the Shift Technical Advisor requirements to the Calvert Cliffs CTS. This revised Discussion of Deviation justifies the change to NUREG-1432 Specification 5.2.2.g (ITS 5.2.2.g) based on current licensing basis. This was requested by the NRC in their comments to Section 5.0 (comment 4).

3. Discussion of Change LA.3 to Section 5.0 has been revised to state that the relocated details will be moved to the Quality Assurance Policy, which is controlled by the provisions of 10 CFR 50.54(a). The change control process was requested to be provided by the NRC in their comments to Section 5.0 (comment 5).

4. A new Discussion of Change has been provided (Discussion of Change M.6 to Section 5.0) to discuss the addition of the prefilters to the pressure drop tests of CTS 4.6.3.1.d.1,4.6.6.1.d.1, 4.7.6.1.e.1,4.7.7.1.d, and 4.9.1.2.d.1 (ITS 5.5.11.d). This change was requested by the NRC in their comments to Section 5.0 (comment 13).

5. A new Discussion of Deviation has been provided (Discussion of Deviation 28 to Section 5.0) to describe the current Calvert Cliffs requirement for the testing of the Iodine Removal System  ;

filter trains. This Discussion of Deviation justifies the change to NUREG-1432 l Specification 5.5.11.c (ITS 5.5.11.c) as requested b / the NRC in their comments to Section 5.0 (comment 14).

6. Discussion of Deviation 11 to Section 5.0 has been revised to clearly state that the outdoor liquid storage tank requirements of Section 5.5.12 are being deleted. The NUREG markup of this l Section has also been annotated with this Discussion of Deviation number. This change was requested by the NRC in their comments to Section 5.0 (comment 15) in order to more clearly justify the change to NUREG-1432.

]

7. A new Discussion of Deviation has been provided (Discussion of Deviation 29 to Section 5.0) to .

describe the current Calvert Cliffs gas storage tank radioactivity limit. The Discussion of I Deviation justifies the change to NUREG-1432 Specification 5.5.12.b (ITS 5.5.12.b) as requested by the NRC in their comments to Section 5.0 (comment 16).

8. Discussion of Changes M.4 and M.5 to Section 5.0 have been combined into Discussion of Change M.4, and Discussion of Change A.26 to Section 5.0 has been replaced with Discussion of l Change L.3. These Discussions relate to the changes to the current Calvert Cliffs diesel i

generator stored fuel oil testing requirements. Discussion of Change M.4 now describes the addition of the new fuel oil testing requirements and Discussion of Change L.3 describes the i change in the stored fuel oil testing requirements. An associated No Significant Hazards 1

l ATTACHMENT (1)

IMPROVED TECHNICAL SPECIFICATIONS, REVISION 2

SUMMARY

OF CHANGES Consideration has also been provided. These changes were requested by the NRC in their comments to Section 5.0 (comments 17.a,17.b, and 17.c).

9. Discussion of Deviation 25 to Section 5.0 has been revised to clearly state the reason for substituting a gravimetric analysis requirement for total particulates in ITS 5.5.13.c instead of the  ;

u ASTM D-2276-89, Method A-2 or A-3 requirements provided in NUREG-1432 Specification 5.5.13.c. This change was requested by the NRC in their comments to Section 5.0 I (comment 18).

10. Discussion of Deviation 12 to Section 5.0 has been revised to clearly state the reason for changing the total particulate test frequency from 31 days in NUREG-1432 to 92 days in the ITS. j This was requested by the NRC in their comment to Section 5.0 (comment 19). l

)

11. Discussion of Change LA.6 to Section 5.0, which discusses the relocation of details on ,

components that require Type B testing, has been replaced with Discussion of Change L.4. The l

new Discussion of Change justifies the deletion of the specific testing requirements, since they l are duplicative of requirements that are maintained in the ITS. An associated No Significant Hazards Consideration has also been provided. This change responds to the NRC comments to Section 5.0 (comments 20 and 30).

1

12. The Battery Inspection Program has been deleted from the Cah crt Cliffs ITS submittal. This i change only affects the portion of the program in Section 5.0. The portions of the submittal I affected by the Rattery Inspection Program deletion that are described in Section 3.8 will be deleted from the Calvert Cliffs ITS in a later revision to the subm .ttal. This was requested by the NRC in a phone conversation with BGE while discussing NRC comment 21 to Section 5.0.

13. A statement precluding the inclusion of the occupational radiation exposure due to the Independent Spent Fuel Storage Installation in the Units 1 and 2 Occupational Radiation Exposure Report required by ITS 5.6.1 has been added to the Note ofITS 5.6.1. This restriction is consistent with CTS 6.6.1 footnote *. A new Discussion of Deviation has also been provided (Discussion of Deviation 30 to Section 5.0) to describe the addition of this statement to NUREG-1432 Specification 5.6.1 Note, as requested by the NRC in their comments to l Section 5.0 (comment 22). l

14. A bracketed sentence in the NUREG markup of NUREG-1432 Specification 5.6.2 has been i retained. The sentence was inadvertently deleted in the original submittal; however, the sentence I was correctly included in the typed Calvert Cliffs ITS and the CTS markup. The Discussion of i Deviation thatjustified deletion of this sentence (Discussion of Deviation 16 to Section 5.0) has i been modified to reflect this change, as requested by the NRC in their comments to Section 5.0 (comment 24).

l 15. Discussion of Change LA.8 to Section 5.0 has been revised to state that the Offsite Dose Calculation Manual (ODCM) will be the location of the relocated details. (One of the details is duplicative of 10 CFR 50.36a and will not be included in the ODCM). This change was requested by the NRC in their comments to Section 5.0 (comments 25 and 30). In addition, the phrase ", as modified by approved exemptions" has been added to the Calvert Cliffs ITS for l

l 2 l

l l

l ATTACHMENT (1)

IMPROVED TECHNICAL SPECIFICATIONS, REVISION 2

SUMMARY

OF CHANGES clarity, since one of the relocated details is an exemption to 10 CFR 50.36a. A new Discussion of Deviation has also been provided (Discussion of Deviation 31 to Section 5.0) to describe the addition of this phrase.

16. Discussion of Change A.17 to Section 5.0 has been revised to clearly state why the addition of the Post Accident Monitoring (PAM) Instrumentation Report to Section 5.0 is administrative. In addition, new Discussion of Changes M.7 and L.5 to Section 5.0 have been provided to justify changes to the PAM Instrumentation Report required by CTS 3/4.3.3.1 Action 30, 3/4.3.3.6 Actions 34 and 35, and 3/4.6.5.1 Action a.l. An associated No Significant Hazards Consideration has also been provided. These changes respond to the NRC comments to Section 5.0 (comment 28).

17. Discussion of Change A.22 to Section 5.0 has been revised to clarify why the associated change (the addition of a Safety Function Determination Program) is administrative and to cross-reference the less restrictive Discussion of Change in Section 3.0. This change responds to the NRC comments to Section 5.0 (comment 29).

18. Discussion of Change LA.5 to Section 5.0 has been revised to state that the Technical Requirements Manual will be the location of the relocated requirements. This change was requested by the NRC in their comments to Section 5.0 (comment 30).

19. Discussion of Change LA.7 to Section 5.0 has been deleted. Most of the CTS details relocated by LA.7 have been incorporated into the ITS. These details affect the frequencies of the tests required by the Ventilation Filter Test Program. In addition, due to maintaining the CTS frequencies, new Discussion of Deviation 32 to Section 5.0 has been provided justifying these changes to NUREG-1432. The remainder of the details are either deleted with new Discussion of Change L.6, or with modified Discussion of Change A.23. An associated No Significant Hazards Consideration has also been provided. This change responds to the NRC comments to Section 5.0 (comment 30). Also, new Discussion of Deviation 33 to Section 5.0 has been provided justifying deleting the phase "at the system flowrate specification below [i 10%]" in NUREG-1432 Specification 5.5.11 since it is redundant to each of the subsequent requirements that require a specific flowrate.

20. Discussion of Change LA.4 to Section 5.0 has been revised to state that the Technical Requirements Manual will be the location of the relocated requirements. This change was requested by the NRC in their comments to Section 5.0 (comment 34).

21. Discussion of Change A.7 to Section 5.0 has been revised to spell out the acronym "NRC."

3