Text

Forwards Request for Addl Info Re License Amend Request to Convert Plant Current TS to Its.Request Seeks to Clarify ITS Sections 3.3.3 Through 3.3.12
	ML20140G436
Person / Time
Site:	Calvert Cliffs
Issue date:	06/06/1997
From:	Dromerick A; NRC (Affiliation Not Assigned)
To:	Cruse C; BALTIMORE GAS & ELECTRIC CO.
References
	TAC-M97363, NUDOCS 9706160237
	Download: ML20140G436 (48)
	v • d • e

. . _ . . . __ _. . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _

Mr. Charles H. Cruse _ June 6,1997 Vice President - Nuclear Energy-Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 ,

SUBJECT:

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

1 AND 2 (TAC NO. M97363 AND M97364)

Dear Mr. Cruse:

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

Units 1 and 2 Current Technical Specifications to the Improved Technical Specifications (ITS). During the course of our review, we found that we require additional information to complete our evaluation. Please respond to the enclosed request for information (RAI) that seeks to clarify the ITS Sections 3.3.3 through 3.3.12. We anticipate sending staff comments on Sections 3.7 and 3.8 to you next week.

In a telephone discussion with BGE on June 2. 1997, the staff said they would not'sup) ort the Technical S3ecifications Task Force (TSTF) changes 198 through 203 on ]attery testing. BGE said that the supplement would include use of NUREG-1432 in instances previously indicated for those TSTF changes. The staff anticipates receipt of the supplement the first week of June. Review of the supplement should assist in the' conversion to the Standard Technical Specifications and preparation of the draft Safety Evaluation report. To support the NRC staff's review schedule, your written and electronic response ;

in Wordperfect 5.1 to this RAI is requested within 15 days of the receipt of l this letter. Should you have any questions, please do not hesitate to contact me at (301) 415-3473. J l

Sincerely.

Guy Vissing for Alexander W. Dromerick, Senior Project Manager I Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 1

Enclosure:

RAI cc w/ encl: See next page m M M B COPY

! Distribution:

l Docket File SLittle MLReardon D[ol PUBLIC ADromerick OGC I

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DOCUMENT NAME: G:\CC-JUNE 6.RAI M Ot 0FFICE ISB/ADPR PM:PDI-1 LA:PDI-1 [RP$1)d7 ul NAME MLReardon 4/g A' ADromerick 4 # SLittle /) " s #/L.

DATE 6/f,/97 6/ f /97 6/ /97 6//0 /97 7 DR DO K 05 0 317 P PDR ._

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UNITED STATES NUCLEAR REGULATORY COMMISSION i

A" WASHINGTON, D.C. 20666 0001 6

1

- - - +4 June 6, 1997 l

Mr. Charles H. Cruse Vice President - Nuclear Energy

, Baltimore Gas and Electric Company )

l Calvert Cliffs Nuclear Power Plant l l 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 l l

SUBJECT:

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

1 AND 2 (TAC NO. M97363 AND M97364)

Dear Mr. Cruse:

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

Units 1 and 2 Current Technical Specifications to the Improved Technical Specifications (ITS). During the course of our review we found that we require additional information to complete our evaluation. Please respond to the enclosed request for information (RAI) that seeks to clarify the ITS Sections 3.3.3 through 3.3.12. We anticipate sending staff comments on Sections 3.7 and 3.8 to you next week.

In a telephone discussion with BGE on June 2. 1997, the staff said they would not sup) ort the Technical S)ecifications Task Force (TSTF) changes 198 through 203 on aattery testing. BGE said that the supplement would include use of i

NUREG-1432 in instances previously indicated for those TSTF changes. The j staff anticipates receipt of the supplement the first week of June. Review of l the supplement should assist in the conversion to the Standard Technical i Specifications and preparation of the draft Safety Evaluation report. To support the NRC staff s review schedule, your written and electronic response ,

in Wordperfect 5.1 to this RAI is requested within 15 days of the receipt of l this letter. Should you have any questions, please do not hesitate to contact '

me at (301) 415-3473.

Sincerely,

) ) $ ==

Al xander W. Dro'ierick. Senior Project Manager Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 l

l

Enclosure:

RAI l

cc w/ encl: See next page J

l

June 6, 1997 Mr. Charles H. Cruse Calvert Cliffs uclear Power Plant Baltimore Gas and Electric Company, Units Nos. 1 and 2 cc:

President Mr. Joseph H. Walter. Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland 175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore. MD 21202-6806 James P. Bennett. Esquire Counsel Kristen A. Burger. Esquire Baltimore Gas and Electric Company Maryland People's Counsel D.0. Box 1475 6 St. Paul Centre Baltimore. MD 21203 Suite 2102 Baltimore, MD '21202-1631 Jay E. Silberg. Esquire Shaw. Pittman. Potts, and Trowbridge Patricia T 91rnie. Esquire 2300 N Street NW Co-Director Washington. DC 20037 Maryland Safe Energy Coalition P.O. Box 33111

'ir. Thomas N. Prichett. Director Baltimore MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby. HD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard. MD 20685 Mr. Richard I. McLean Administrator - Radioecology Department of Natural Resources 580 Taylor Avenue Tawes State Office Building. B3 Annapolis, MD 21401 Regional A6ministrator. Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia. PA 19406

- .. - - . . - ---- --=

CCNPP ITS 3.3.3 REACTOR PROTECTIVE SYSTEM (RPS) LOGIC AND TRIP INITIATION tabs 333.cci 3.3.3 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS l 1 A.3 CTS 4.3.1.1.1 requires a Channel Functional Test (CFT) for Matrix Clarify that this double 6/2/97 Logic, Trip Path Logic, and RTCBs as shown in CTS Table 4.3-1. ITS testing is intended in the open ;

3.3.3 moves the CFT requirements to iTS SR 3.'3.3.1, RTCB channels ITS.

every 31 days, and ITS 3.3.3.2,.RPS Logic channels (Functions 12 and 13 of CTS Table 4.3-1) and RTCB channels every 92 days. This requires the CFT for the RTCBs at two frequencies; ITS SR 3.3.3.1, every 31 days, and ITS SR 3.3.3.2, every 92 days.

EGE Response:

2 M.1 The CTS 3.3.1.1 Applicability for the Manual Trip is MODES 1 and 2, Address this change to the 6/2/97 and with any RTCBs closed and the CEA system capable of CEA Manual Trip open ,

withdrawal. ITS 3.3.3 changes the Applicability for these functions APPLICABILITY and to MODES 1 and 2, and MODES 3,4, and 5, with any RTCBs closed provide justification for it and any CEA capable of being withdrawn. Adding MODES 3,4, and as an administrative 5 to the APPLICABILITY "with any RTCBs closed and the CEA change. !

system capable of CEA withdrawal" is an administrative change.

CGE Response:

3 M.6 CTS 4.3.1.1.1 does not require a CHANNEL FUNCTIONAL TEST Provide additional 6/2/97 (CFT) for the Manual Reactor Trip Function in any specific MODE. discussion and justification open The CFT is, however, required by CTS Table 4.3-1 within 7 days for this change, describing prior to startup. ITS SR 3.3.3.3 requires the test once within 7 days how it is more restrictive, l prior to startup for Modes 1 and 2, and Modes 3,4, and 5 with any or reclassifying as RTCBs closed and any CEAs capable of being withdrawn. The administrative.

surveillance in both the CTS and the ITS is required for all operating MODES, within 7 days prior to startup (before exiting MODE 6). The i change and justification support this change as an administrative change.

. t CCNPP ITS 3.3.3 REACTOM PROTECTIVE SYSTEM (RPS) LOGIC AND TRIP INITIATION tabi333.cc1 3.3.3 DOC JFD- CHANGE / DIFFERENCE ' COMMENT STATUS t

CGE Response: '

4 The STS 3.3.3 NOTE in Conditions B and C are adopted as notes in Acceptance of thi change 6/2/97 !

Required Actions B.1 and C.1, respectively, in ITS 3.3.3. This is contingent on NRC open deviation from the STS s based on TSTF-181 (CEOG-93), which has approval of TSTF-181 !

not yet been approved by the NRC. (CEOG-93).

CGE Response:

5 The wording of STS 3.3.3 Required Action C.1 to "Open all RTCBs" Acceptance of this change 6/2/97 is not adopted; rather ITS 3.3.3 Required Action C.1 states "Open is contingent on NRC open the affected RTCBs." This deviation from the STS is based on TSTF- approval of TSTF-170 170 (CEOG-73), which has not yet been approved by the NRC. (CEOG-73).

BGE Response:

6 ITS 3.3.3 Condition D lists two inoperable manual trip channels in Acceptance of this change 6/2/97 addition to two inoperable channels of RTCBs or initiation logic is contingent on NRC open ,

affecting the same trip leg as specified in STS 3.3.3 Condition D. approval of TSTF-182 !

This deviation from the STS is based on TSTF-182 (CEOG-94), which (CEOG-94). !

has not yet been approved by the NRC. l CGE Response: :

7 The wording of STS 3.3.3 Condition E, "One or more Functions Acceptance of this change 6/2/97 ;

with," is omitted from corresponding ITS 3.3.3 Condition E. This is contingent on NRC open

deviation from the STS is based on TSTF-183 (CEOG-95), which has approval of CEOG-95.

not yet been approved by the NRC.

CGE Response:

[

t t

CCNPP ITS 3.3.3 REACTOR PHOTECTIVE SYSTEM (RPS) LOGIC AND TRIP INITIATION tabt333.cci 3.3.3 DOC JFD CHANGE / DIFFERENCE i COMMENT STATUS 8 ITS SR 3.3.3.1, a 31-day CHANNEL FUNCTIONAL TEST on each Acceptance of this change 6/2/97 -

RTCB channel, is not specified in STS 3.3.3. This deviation from the is contingent on NRC open l STS is based on TSTF-79, which was nydified, but not yet approval of TSTF-79. ;

approved, by the NRC on 3/17/97. '

CGE Response:

b

CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabt334.cci 3.3.4 DOC JFD CHANGE / DIFFERENCE ' COMMENT STATUS 1 LA.6 CTS 4.3.2.1.2 requires demonstrating the total bypass logic during Provide additional 6/2/97 i the at-power Channel Functional Test. ITS 3.3.4 moves this bypass discussion and justification, open testing reqcirement to unidentified plant procedures. The identifying the plant justification does not identify the plant procedure that maintains this procedures that contain the requirement nor the specific controls that maintain the requirement in requirement to demonstrate plant procedures. the bypass logic during the i at-power Channel Functional Test, and controls over changes to that requirement.

BGE Response:

2 LA.5 CTS Table 3.3-4 contains " Trip Setpoint" and " Allowable Values" Provide additional 6/3/97 columns. ITS Table 3.3.4-1 contains only the " Allowable Values" discussion and justification, open column. Specific trip setpoints are maintained in plant procedures. identifying the plant The justification for deleting the " Trip Setpoint" column from ITS procedures that contain the Table 3.3.4-1 does not identify the plant procedures that maintain trip setpoints, and controls the trip setpoints nor the specific controls that maintain the over changes to the trip requirement in plant procedures. setpoints in those plant procedures.

BGE Response: ,

CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabs 334.cc1 3.3.4 DOC JFD CHANGE / DIFFERENCE

COMMENT STATUS 3 LA.3 CTS Table 3.3-3 Action 7.b requires, within one hour, placing all Revise the submittal to 6/2/97 functional units receiving a parameter input from the inoperable fully explain how Action open !

ch'annel in the same tripped or bypassed condition as the inoperable 7.b of CTS Table 3.3-3 will trip channel. DOC LA.3 states this requirement is moved to the be accomplished under the i Safety Function Determination Program (SFDP) of ITS 5.5.15. ITS. In addition, this is an Although the SFDP is activated under ITS LCO 3.0.6 and ITS LCO L-type, not an LA-type .

3.0.6 would apply when ITS LCO 3.3.4 is not met, it is not certain change.

that the SFDP would require taking the same action as Action 7.b of CTS Table 3.3-3 or an equivalent action. See comment 3.3.1-04 See comment 3.3.4-12 CGE Response:

4 M.3 The justification for this change states that CTS Table 3.3.3 Action Provide discussion and 6/2/97 7.c does not specify a time for placing the additional inoperable justification for this less open channel in bypass and ITS 3.3.4, Action B, requires placing one restrictive change that channel in trip and one channel in bypass in one hour. The provides a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months justification does not address the reason for placing the additional extension of the AOT for inoperable channel in bypass - the reason being testing and testing and maintenance.

maintenance, with a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months limit (both CTS and ITS) from the :

beginning of testing. Therefore, the one hour limit of ITS 3.3.1, See comment 3.3.1-05 I Action B, to place the channel under test in bypass is a less restrictive change providing a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months extension of the allowed outage time (AOT) for testing and maintenance that is not justified. l BGE Response:

CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabi334.cct 3.3.4 DOC JFD - CHANGE / DIFFERENCE i COMMENT STATUS 5 L.1 CTS Tabte 3.3-3, Action 11, Containment Spray Actuation System Provide justification for this 6/2/97 (CSAS), Containment Pressure - High, when one or two sensor (trip) less restrictive change open channels are inoperable, allows continued operation with one removing the requirement inoperable channel provided the inoperable channal is bypassed and to verify the remaining the other channels are demonstrated OPERABLE within one hour. Containment Pressure - ,

ITS 3.3.4, Action A, allows one hour to place the affected sensor High channels OPERABLE (trip) module in bypass or trip. There is no ITS requirement to within one hour. ,

demonstrate the remaining sensor (trip) channels OPERABLE within one hour. This less restrictive change from the CTS is not justified. ,

BGE Response: ;

6 L.1 CTS Table 3.3-3, Action 11 Containment Spray Actuation System Provide justification for this 6/2/97 (CSAS), Containment Pressure - High, when one or two channels are more restrictive change open :

inoperable, allows continued operation with one inoperable channel requiring bypassing one provided the inoperable channel is bypassed. One additional channel sensor (trip) module of the may be bypassed for surveillance testing for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS Containment Pressure -

3.3.4, Action B, allows one hour to place one affected sensor ttrip) High instrumentation and module in bypass and the other affected sensor (trip) module in trip. bypassing the other rather This more restrictive change to the ITS requires bypassing one that the CTS requirement sensor (trip) module and bypassing the other rather that the CTS to bypass both.

requirement to bypass both. This more restrictive change is not justified. '

EGE Response: !

, . -. . . - . .- - _ . ~ _ .. . . . . - - - . ._ =. - ..

l CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabt334.cci 3.3.4 DOC JFD CHANGE / DIFFERENCE t COMMENT STATUS 7 L. 2 ITS Table 3.3.4-1 adds Footnote c to the CTS Table 3.3-3 footnotes. Provide additional 6/2/97 '

This footnote allows the Steam Generator Isolation Signal (SGIS) discussion for this less open function and the Steam Generator Pressure - Low signal and the restrictive change, i Containment Pressure - High signal to be inoperable when all addressing the inclusion of '

associated valves isolated by the SGIS function are closed and the Containment Pressure - ,

deactivated. DOC L.2 does not discuss the Containment Pressure - High function in the '

High signal nor why it is included in the footnote. Further, Footnote footnote.

c is not applied in ITS Table 3.3-3 for any function associated with Containment Pressure - High.

BGE Response:

8 A.1 CTS 4.3.2.1.2 requires demonstrating the logic for the automatic Provide justification for this 6/2/97 LA.6 block removal function Operable during the at-power Channel less restrictive change open Functional Tests of channels affected by blocks. These CFTs are extending the CFT required quarterly by Frequency for the logic for CTS Table 4.3-2 for Functions - the automatic b;ock >

1.c (Pressurizer Pressure - Low) and removal features for the 4.b (Steam Generator Pressure - Low). two functions listed from 3 ITS Table 3.3.4-1, for Functions -- months to 24 months.

1.b (Pressurizer Pressure - Low) and )

4.a (Steam Generator Pressure - Low),

requires a CFT on each automatic block removal feature (total ;

bypass function)) at a 24-month Frequency (ITS SR 3.3.4.3) rather than quarterly. This leas restrictive change in the Frequency for ;

testing the logic for the bypasses is not justified.

BGE Response:

l 1

l'

CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabi334.cci

[

t 3.3.4 DOC JFD CHANGE / DIFFERENCE ' COMMENT STATUS 9 STS 3.3.4 Actions Note allows separate Condition entry for each Acceptance of this STS 6/2/97 "ESFAS trip or bypass removal Function." Corresponding ITS 3.3.4 deviation is based on NRC open Actions Note allows separate Condition entry for each "ESFAS approval of TSTF-178 Function." This diffeerence in wording from the STS is based on (CEOG-89). ;

TSTF-178 (CEOG-89), which has not yet been approved by the NRC. l EGE Response:

10 26 In the event of one or more Functions with the automatic block Revise the submittal to 6/2/97 removal fi .ture of one sensor block inoperable, ITS 3.3.4 Action C, adopt the STS action open i does not require restoring the bypass removal channel and affected requirements.

trip units to Operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or placing the affected unit in trip within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months as required by STS 3.3.4 Required Action :

D.2.2.1 or Required Action D.2.2.2.

JFD-26's justification for not adopting these STS requirements [

appears to be consistency with ITS 3.3.1 Required Actions A.2.1 l and A.2.2, which allows within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months either restoring the !

affected bistable trip unit and associated measurement channel to '

Operable status or placing the affected unit in trip, which places the -

unit in a one-out-of-three coincidence logic. Thus, indefinite operation is allowed once the function is in a one-out-of-three coincidence logic. ;

Since the STS action requirements are logically the same as the i action requirements of ITS 3.3.1, they should be adopted. JFD-26 j does not explain how ITS 3.3.4 Required Actions C.1 and C.2 result ;

in placing the unit in a one-out-of-three coincidence logic.

Therefore, the justification for this STS deviation is inadequate.

BGE Response:

h CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabt334.cci 3.3.4 DOC JFD CHANGE / DIFFERENCE i COMMENT STATUS 11 LA.1 Portions of CTS 3.3.2.1, SIAS Endnote @, which discusses when to Provide additional 6/2/97 '

i place the high pressure safety injection pumps in pull-to-lock, are discussion and open .

moved to unidentified plant procedures. The justification does not justification, identifying the '

identify the plant procedure that maintains this requirement nor the plant procedures that specific controls that maintain the requirement in plant procedures. contain the requirement for placing the high pressure ,

safety injection pumps in pull-to-lock, and controls over changes to that i

, requirement.

BGE Response:

12 LA.3 CTS Table 3.3-3, Action 7.b, requires piacing all functional units Revise the submittal to 6/2/97 l receiving a parameter input from the inoperable channel in the same describe the regulatory open tripped or bypassed condition as the inoperable trip channel within basis for the plant change one hour. ITS 3.3.4 does not require this action. This requirement control process and how '

is moved to the Safety Function Determination Program (SFDP) of changes to the SFDP i ITS 5.5.15. implementing procedures !

DOC LA.3 states that changes to the SFDP are in accordance with will be approved. . t the plant change control process. The plant change control process l is not identified.

l t

BGE Response:

T l m_-__ _ _ . __ _ _ _ _ _ _ . . _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____-__._ _ _ _ _ _ - _ _ _ . . _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ __ _ _ _ _ _ _ _ _ . _ _ -_ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ -

CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabt334.cc1 3.3.4 DOC JFD CHANGE / DIFFERENCE i COMMENT STATUS 13 ITS Table 3.3.4-1, Function 1.b, SIAS - Pressurizer Confirm that the iTS is 6/2/97 Pressure - Low correct and correct the open CTS Table 3.3-3, Functional Unit 1.c, SlAS - Pressurizer CTS markup.

Pressure - Low CTS markup indicates CTS Table 3.3-3 Notation (a) corresponds to ITS Table 3.3.4-1 Note (b), but the ITS clearly indicate it i corresponds to ITS Table 3.3.4-1 Note (a). i CGE Response: !

14 A.8 ITS 3.3.4, Table 3.3.4-1, Function 2.a, CSAS - Confirm that the ITS is 6/2/97 Containment Pressure - High correct, and correct the open Note (b) to ITS Table 3.3.4-1 CTS markup and DOC A.8.

CTS Table 3.3-3, Functional Unit 2.b, CSAS -

Containment Pressure - High DOC A.3 and the CTS Table 3.3-3 markup indicate that Note (c) of i ITS Table 3.3.4-1 is being added, but the ITS designates this note as Note (b) to ITS Table 3.3.4-1.

i CGE Response:

l 15 L.2 ITS Table 3.3.4-1 Note (c) Why does the note also 6/2/97 STS Table 3.3.4-1 Note (d) include the conteinment open pressure - high function?

ITS Note (c) is a new note that relaxes the CTS operability (Note that the STS i requirements'on the steam generator isolation signal function (steam includes it too.) !

generator pressure -low) when all valves closed by SGIS are closed i and deactivated.

[

5 t

CCNPP ITS 3.3.4 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION tabt334.cct 3.3.4 DOC JFD CHANGE / DIFFERENCE i COMMENT STATUS

~

BGE Response:

16 CTS Table 3.3-3 Markup (page 3 of 16) Revise the submittal with a 6/2/97 corrected markup. open l Action 7 is marked as being replaced by ITS ACTION 5 is and C for Functional Units 4.B Steam Generator Pressure - Low, 5.B Refueling Water Tank - Low, and 9. Auxiliary Feedwater Actuation System.

The markup should indicate ITS ACTIONS A and B. Verify that this is correct and correct the markup.

BGE Response:

17 ITS 3.3.4 ACTION B Note The submittal contains no 6/2/97 ITS Table 3.3.4-1 Function 9. AFAS justification for adding the open CTS Table 3.3-3 Action 7 LCO 3.0.4 exception to the CTS Table 3.3-3 Notation

AFAS functions. Revise the submittal with this

CTS Action 7 applies to the AFAS functional units but CTS Notation justification.

(LCO 3.O.4 does not apply) does not apply to the AFAS functions.

ITS 3.3.4 ACTION B Note, corresponding to CTS Notation *, applies to the AFAS functions.

11GE Response:

m ~

r ~. . 7 CCNPP ITS 3.3.5 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) LOGIC AND MANUAL ACTUATION tatd335.cc1 j 3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ;

1 A.8 CTS Table 3.3-3 Action 6 requires restoring an Provide justification for this less restrictive 6/3/97 inoperable ESFAS Actuation Logic channel to change and discussion justifying the open OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or being in MODE 3 shutdown to MODE 4 rather than within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . ITS MODE 5 for ITS 3.3.5, Actions B and E. i 3.3.5 Actions, when one channel in one or more functions is inoperable, allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the inoperable ESFAS Actuation Logic channel to OPERABLE status. l' not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , i MODE 3 is required within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . MODE 5 is not required for ITS 3.3.5 Actions B and E for not meeting l the Required Actions and Completion Times of Actions A and C (one actuation logic channel), respectively. ITS 3.3.5 Actions B and E require shutdown to MODE 4. i There is no justification for requiring MODE 4 rather than !

MODE 5 for this less restrictive change. t BGE Response:

i i

e ---

p .

CCNPP ITS 3.3.5 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) LOGIC AND MANUAL ACTUATION tabt33s a:1 L

3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS !

2 A.8 CTS Table 3.3-3 Action 6 does not address multiple Provide additional justification including 6/3/97 inoperable redundant channels. If two or more channels when ITS LCO 3.0.3 is required for two or open -

in one or more function are inoperable, entry into CTS more channels in one or more functions 3.0.3 is required. ITS 3.3.5 Action B when two Manual are inoperable and when ITS 3.3.5, Auxiliary Feedwater Actuation System (AFAS) Logic Actions B and D, are required.

channels are inoperable, requires MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.3.5 Action D, -

for two Manual non-AFAS Manual Trip or Actuation Logic channels are inoperable, requires MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The justification states that in this situation both the CTS and the ITS require entering (CTS or ITS LCO) 3.0.3. The i justification does not include discussion of ITS 3.3.5, Actions B and D, which are entered for multiple inoperable channels. ,

BGE Response:

3 A.8 CTS Table 3.3-3, Action 6, does not address multiple Provide additional discussion for ITS 6/3/97 inoperable channels within a Function. If two or more 3.3.5, Actions B and D, when two AFAS open !

channels in one or more functions are inoperable, entry Actuation Logic channels are inoperable.

into CTS 3.0.3 is required. ITS 3.3.5, Actions B and D. ;

do not address when two AFAS Actuation Logic '

channels are inoperable, yet address other multiple redundant channels. It is not clear that this entry into ITS LCO 3.0.3 for the two AFAS Actuation Logic !

channels is intentional.

BGE Response:

i t

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t CCNPP ITS 3.3.5 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) LOGIC AND MANUAL ACTUATION tabc35.cci ,

3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS i i

4 LA.2 ~ CTS Table 4.3-2, Endnotes (2) through (6), discuss the Provide additional justification and 6/3/97 logic circuits that cannot be tested during power discussion, identifying the plant open !

operation. They are identified as only tested at least procedures that contain the CTS Table l once per REFUELING INTERVAL during shutdown. 4.3-2, Endnotes (2) through (6), .

These endnotes are moved to unidentified plant requirements, and how those procedures. Change control of these requirements requirements are controlled. .

moved to procedures is not specifically identified.

BGE Response:

i 5 A.4 CTS Table 4.3-2 and Endnote (1) require performing the Provide justification for extending the 6/3/97 CHANNEL FUNCTIONAL TEST of the ESFAS automatic Surveillance Test Interval from 31 days to open actuation logic manually every 31 days. ITS SR 3.3.5.1 92 days.

requires performing a CHANNEL FUNCTIONAL TEST of each ESFAS actuation logic channel every 92 days. Note: Consistent with the STS. .

This less restrictive change extending the CTS Table !

4.3-2 Surveillance Test Interval from 31 days to 92 days is not justified. j BGE Response:

i r

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

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CCNPP ITS 3.3.5 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) LOGIC AND MANUAL ACTUATION tatd335.cci 3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS i

6 A.9 CTS Table 3.3-3, Function 9.a. requires two sets of two Provide additional discussion and 6/3/97 '

manual trip buttons per steam generator (a total of eight justification for changing the CTS Table open pushbuttons). ITS 3.3.5 requires two channels for 3.3-3, Function 9.a. two sets of two manual start of the Auxiliary Feedwater Actuation manual trip buttons per steam generator System (AFAS) A and AFAS B, ITS Table 3.3.5-1, (a total of eight pushbuttons), to the ITS Function 9.a. The justification discusses the ITS Table Table 3.3.5-1, Function 9.a two channels. :

3.3.5-1, Function 9.a. requirement for two manual start channels, one for AFAS A and one for AFAS B. The justification does not discuss the acceptability of '

changing the CTS Table 3.3-3, Function 9.a. two sets of ,

two manual trip buttons per steam generator, to the ITS i Table 3.3.5-1, Function 9.a. two channels for manual start, one for AFAS A and one for AFAS B.

BGE Response:

7 A.9 CTS Table 3.3-3, Function 9.a. requires two sets of two Provide additional discussion and 6/3/97 manual trip buttons per steam generator (a total of night justification for this administrative change, open i pushbuttons). ITS Table 3.3.5, Function 9.a. requires showing how ITS 3.3.5 implements the ;

two channels for manual start of the Auxiliary Feedwater CTS Table 3.3-3 requirements.

Actuation System (AFAS) Signal. The justification for this change states that ITS Table 3.3.5-1, Function 9, requires two channels for manual start, one for AFAS A i and one for AFAS B (Function 9.a). ITS Table 3.3.5 does not separate the requirements on a per AFAS basis or a per steam generator basis. Manual Starl is listed, and ITS 3.3.5 requires 2 channels, not the eight l pushbuttons of CTS Table 3.3-3, Function 9.a. j BGE Response:

l

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

" ~

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p CCNPP ITS 3.3.5 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) LOGIC AND MANUAL ACTUATION totd335oci l

4 3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 8 ITS Table 3.3.5-1, adds Function 6.c, Steam Generator Provide a desenphon of ITS Table 6/3/97 l 1 Isolation (Block) Logic, and Function 6.d Steam 3.3.5-1, Funchon 6.c, Steam Generator 1 open ;

Generator 2 Isolation (Block) Logic, to STS Table 3.3.5- isolation (Block) Logic, and Funchon 6.d, !

1. The ITS 3.3.5 BASES, LCO 6, does not include a Steam Generator 2 Isolation (Block) Logic [

desenption of ITS Table 3.3.5-1, Function 6.c and 6.d. in the ITS 3.3.5 BASES, LCO.

BGE Response:

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 appropnate Actions for !

Condition D, adds a second Condition to STS 3.3.5, 2 inoperable, non-manual AFAS Actuation i Condition D. The Condition added is one or more Logic Channels. j Functions with two non-AFAS Manual Trips or Actuation !

Logic channels inoperable. The additions are based on Acceptance of this STS deviabon is !

TSTF-187 (CEOG-99) which has not yet been approved contingent on NRC approval of CEOG-99 !

by the NRC. However, with this STS deviation, there is (TSTF-187). !

no specdic Condition that provides Actions for 2 l inoperable, non-manual AFAS Actuation Logic Channels. j BGE Response: f 10 CEOG-99 (TSTF-187) Verify Condition B is worded correctly and 6/3/97 ITS 3.3.5 Action B i revise the STS markup and ITS ACTIONS open !

s Condition B acordingly.

The Condition "Two AFAS Manual Actuation Logic ,

channels inoperable" is added to Condition B. It Acceptance of this difference is j appears that this wording means "Two AFAS Manual dependent upon NRC approval of TSTF- i Start channels or two Actuation Logic channels 187 or a plant-specific justification which :

inoperable." This difference is based on TSTF-187 would have to be added to the subrnettal. I which has not yet been approved. i

_ _ _ . _ _ _ _ . . _ _ _ _ . _ . _ _ . . _ _ _ . _ . _ __ _ __ _.m . ._ _ .

CCNPP ITS 3.3.5 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) LOGIC AND MANUAL ACTUATION tatd335cc1 3.3.5 DOC JFD CHANGE / DIFFERENCE COMMENT- STATUS BGE Response:

11 ITS 3.3.5 Revise the submittal to clarify the intent of 6/3/97 the CTS, the STS, and the proposed ITS. open i As presented, ITS Table 3.3.5-1 indicates that the operability of the manual actuation and the operability of the actuation logic for each function are independent; thus manual actuation and actuation logic may be treated as separate " functions." Even if the operability is independent, this does not appear consistent with the CTS and the STS.

BGE Response: i 12 4 ITS Table 3.3.5-1 6/3/97 12 open The titles of the functions in Table 3.3.5-1 use the word Revise the table to omit the word channel

" channel." This is misleading given the wording of LCO in the function titles.

3.3.5, which requires two channels of each function to j be operable.

BGE Response: i r

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n CCNPP ITS 3.3.6 DOESEL GENERATOR (DG) - LOSS OF VOLTAGE START (LOVS) totdsas.cci 3.3.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 L.3 CTS Surveillance Requirement 4.3.2.1.3 requires Provide additional discussion and 6/3/97 response time testing for the DG-LOVS instrumentation justification showng the response time open on a staggered test basis every 24 months. ITS 3.3.6 testing for the DG start is inclusive of the does not require response time testing for the DG-LOVS DG-LOVS instrumentation response time instrumentation because the DG-LOVS instrumentation for both LOVS Funchons.

response time is negligible compared to the ten second DG start time required, and does not contribute significantly to determining operability of the DGs. The DG start time testing of ITS SR 3.8.1.16 verifies the DG starts within 10 seconds of a actual of simulated loss of power in conjunction with a actual or simulated ESFAS.

ITS SR 3.8.1.16 is satisfied with a less than 10 second start, regardless of whether the start signal from the

! LOVS instrument Functions is timely. For instance, the ITS SR 3.8.1.16 testing could show satisfactory results based on the ESFAS initiation with the LOVS initiations being inadequate to meet the 10 second requirement.

The justification does not show that both LOVS

Functions (Loss of Voltage and Degraded Voltage) meet the response time requirements.

BGE Response:

e

_ - _ _ . - _ _ .m_-._ ..___-.-.____ _ - - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _____._ __- _ _ _ _ - _ __w

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

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i CCNPP ITS 3.3.6 DIESEL GENERATOR (DG) - LOSS OF VOLTAGE START (LOVS) tatsass a:1 1 3.3.6 DOC JFD CHANGE /D!FFERENCE COMMENT STATUS 2 l_A.2 CTS Table 3.3-3, Action 7.b. requires, within one hour, Provide additional discussion and 6/3/97 i placing all functional units receiving a parameter input justification, identifying how CTS Table open from the inoperable channel in the same tripped or 3.3-3 Action 7.b is accomplished under I bypassed condition as the inoperable trip channel. ITS the ITS.

3.3.6 does not require this Action. This requirement is moved to the Safety Function Determination Program See comment 3.3.4-03 (SFDP) of ITS 5.5.15. However, the SFDP is activated under ITS 3.0.6, which is not required by any ITS 3.3.6 ACTION, and does not accomplish CTS Table 3.3-3, Action 7.b, or an equivalent action.

BGE Response:

3 LA.2 CTS Table 3.3-3. Action 7.b, requires placing ali Provide additional discussion and 6/3/97 functional units receiving a parameter input from the justification, identifying the plant open inoperable channel in the same tripped or bypassed procedures that maintain control over the condition as the inoperable trip channel within one hour. plant change control process and controls ITS 3.3.6 does not require this action. This requirement over changes to the SFDP.

is moved to the Safety Function Determination Program (SFDP) of ITS 5.5.15. The justification states that See comment 3.3.4-12 changes to the SFDP are in accordance with the plant change control process. The plant change control process is not identified.

BGE Response:

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

e e n I

CCNPP ITS 3.3.6 DIESEL GENERATOR (DG) - LOSS OF VOLTAGE START (LOVS) tatd33 sat i

3,3.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 4 A.4 With one inoperable LOVS channel in trip, CTS Table Provide discussion and justification for 6/3/97 M.1 3.3-3, Achon 7.c, allows bypassing an additional channel this less restrictive change that provides open.

for test or maintenance for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS 3.3.6, for bypassing a second inoperable }'

Action B, allows placing either of two inoperable channel for reasons other than testing channels in trip and bypassing the remaining inoperable and maintenance.

channel, without restnchon on the second channel, that is, the second channel can be inoperable for testing, See comment 3.3.1-05 and 3.3.4-04 maintenance, or for any other reason. This is a less restnctive change because the second LOVS channel can be inoperable for reasons other than the CTS Table 3.3-3, Action 7.c, allowed testing and maintenance.

Adding the allowance for the second inoperable channel !

to the CTS Table 3.3-3, Action 7.c, allowance for reasons other than testing and maintenance is not justified.

BGE Response:

5 L.1 CTS 3.3.2.1 and Table 3.3-3 do not require Actions if Provide additional discussion and 6/3/97 more than two channels are inoperable; immediate entry justification for this less restrictive change open into CTS 3.0.3 (shutdown) is required.' ITS 3.3.6 Action that changes the Completion Time from C allows one hour to restore all but two DG - Loss of immediately initiating a shutdown to 1 Voltage channels per DG to OPERABLE status if more hour to restore all but two DG - Loss of than two (three or four) channels are inoperable. This Voltage channels per DG to OPERABLE increases the Completion Time for the action from status.

immediately to one hour.

BGE Response:

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CCNPP ITS 3.3.8 DIESEL GENERATOR (DG) - LOSS OF VOLTAGE START (LOVS) tatd336.cci 3.3.6 DOC JFD CHANGE / DIFFERENCE - COMMENT STATUS 6 L.1 Because CTS 3.3.2.1 and Table 3.3-3 contain no Provide additional d'scussion and 6/3/97 L2 Actions for more than two channels inoperable, entry justification for this less restrictive change open .

into CTS 3.0.3 is required. ITS 3.3.6 Action C allows to the required achon from initiating a I

one hour to restore all but two DG - Loss of Voltage shutdown to entering the actions for the channels per DG to OPERABLE status if more than two associated DG made inoperable by this (three or four) channels are inoperable per DG. If condition, allowing operation to continue.

restoration is not completed within one hour, ITS 3.3.6 Action D is required. This changes the required action from initiating a shutdown to entering the actions for the !

associated DG made inoperable by this condition.

allowing operation to continue. While the justification

. notes that this change prevents a shutdcwn, the Justification does not show that a shutdown :s not l necessary under these circumstances. As separate condition entry is allowed for each Function, the overall

, total of inoperable equipment may warrant a shutdown rather than continued operation. ;

BGE Response.

I i 7 LA.3 CTS Table 3.3-4 contains " Trip Setpoint" and " Allowable Provide additional discussion and 6/3/97 Values" columns. ITS 3.3.6 does not maintain the Trip justification, identifying the plant open ;

Setpoint requirements. Specific trip setpoints are procedures that contain the trip setpoints, maintained in plant procedures. The justification for and cuisiivis over changes to the trip :

deleting the " Trip Setpoint" column from CTS Table 3.3- setpoints in those plant procedures. !

4 does not identify the plant procedures that maintain !

the trip setpoints nor the specific controls that maintain ;

the requirement in plant procedures. l BGE Response: [

t

__________-.__m._______-_.______._..._____:-_____m._m..__m____m___.. _ _ _ _ _ _ _ - _ _ _ _ _ _ - - _ _ ____ _ C _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . - _ _ _ _ _ - _ - _ _ _ _ - - _ _ _

I

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CCNPP iTS 3.3.6 DIESEL GENERATOR (DG) - LOSS OF VOLTAGE START (LOVS) tatw338.ect 3.3.6 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 8 CTS Table 3.3-4 contains " Trip Setpoint" and " Allowable Revise the submittal to include Allowable 6/3/97 Values" columns. ITS 3.3.6 does not maintain the Values in ITS SR 3.3.6.2, consistent with open Allowable Value requirements. There is no justification STS SR 3.3.6.3 and CTS Table 3.3.4 i for deleting the " Allowable Values" column from CTS Functional Units 7.a and 7.b.

Table 3.3-4. This is not in conformance with the STS, which includes the allowable values in STS SR 3.3.6.2. '

This difference from the STS is based on TSTF-91 which was rejected by the NRC on 3/14/97. (See TSTF meeting summary dated April 8,1997).

BGE Response: ,

9 19 STS 3.3.S applies in MODES 1,2,3, and 4, and when Revise the submittal to conform to the 6/3/97 the associated DG is required OPERABLE by STS 3.8.2. Applicability of STS 3.3.6. open ITS 3.3.6 applies only in MODES 1,2, and 3. Not '

requiring the DG - LOVS instrumentation OPERABLE in MODE 4 and when the associated DG is required OPERABLE by ITS 3.8.2 is because ESFAS APPLICABILITY is MODES 1,2, and 3. The justification does not address the requirements for DG OPERABILITY which includes SHUTDOWN conditions.

BGE Response: ,

i 10 L.2 ITS 3.3.6 Required Action D.1 - Bases discussion 6/3/97 .

open DOC L2 and the Bases refer to LCO 3.8.2 for Revise the Bases and DOC L.2 to correct .

appropriate action requirements in response to Required this error.

Action D.1. Since the Applicability of ITS 3.3.6 is Modes 1,2, and 3, only entering the action requirements of ITS 3.3.1, not ITS 3.3.2, would be appropriate.

i

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m .

CCNPP ITS 3.3.6 DIESEL GENERATOR (DG) - LOSS OF VOLTAGE START (LOVS) tabo3acc1 3.3.6 DOC JFD CHANGE /DlFFERENCE COMMENT STATUS BGE Response:

i I

11 A.13 ITS SR 3.3.6.1 Notes 1 and 2 6/3/97 ;

STS SR 3.3.6.2 open

a. The allowances of Notes 1 and 2 in ITS SR 3.3.6.1, Revise the submittal with an appropriate i Channel Functional Test of the DG Ioss of voltage justification of this less restrictive change. ;

instrumentation, are not explicitly specified in corresponding CTS 4.3.2.1.1 (Functional Unit 7 of CTS Table 3.3-3). Thus including them in SR 3.3.6.1 is a ,

less restnctive change. *

b. DOC A.13 states the inclusion of Notes 1 and 2 in . Revise the submittal with an appropriate justification of this apparently plant-ITS SR 3.3.6.1 is consistent with the NUREG-1432 (the STS). However, the STS does not include them in specific difference from the STS.

corresponding STS SR 3.3.6.2, and the STS markup offers no specific justification for this difference.

BGE Response:

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CCNPP ITS 3.3.7 CONTAINMENT RADIATION SIGNAL (CRS) tabi337.cci 3.3.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 L1 CTS 3.3.2.1 and CTS Table 3.3-3, Function 6.a. require Provide additional discussion and 6/3/97 ,

two Containment Purge Valve Isolation Manual Trip justification for this less restnctive change, open !

channals per penetration OPERABLE. ITS 3.3.7 addressing the adequacy of ITS 3.3.7, !

reduces this requirement to one Manual Actuation Required Action B.2, for an inoperable channel. The required actions in the event a channel is Containment Purge Valve l solation ;

inoperable are either ITS 3.3.7 Required Action B.1 Manual Trip channel. .

(based on CTS Table 3.3-3 Action 8) or ITS 3.3.7 !

Required Action B.2, to enter the applicable Conditions ;

and Required Actions of ITS 3.9.3. The justification !

does not explain why ITS 3.3.7 Required Action B.2 is j an acceptable option to Required Action 0.1. ,

BGE Response:

2 M.2 In the event less than the required number of Provide additional discussion and 6/3/97 !

containment radiation monitors are OPERABLE, CTS justification for this less restrictive change, open .

l Table 3.3-3 Action 8 allows continued operation if the addressing the adequacy of ITS 3.3.7, f containment purge isolation valves are kept closed ITS Action A, for fewer than the required !

3.3.7 Action A requires, if one radiation monitor sensor number of containment radiation monitors module or associated measurement channel is OPERABLE. ;

inoperable with the containment purge valves or l containment vent valves open, placing the affected i sensor module in trip, or suspending Core Alterations I and all movement of irradiated fuel assemblies within j containment. This less restrictive change adds options :

of trippmg the affected sensor module or suspending Core Alteratums and movement ofirradiated fuel !

- assembhes within containment. The justification does not address this less restrictive change. -

i BGE Response:

i l

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i

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i CCNPP ITS 3.3.7 CONTAINMENT RADIATION SIGNAL (CRS) tabt337.cci 3.3.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 4 M.3 in the event less than the required number of '

Provide additional discussion and 6/3/97 I M.4 containment radiation monitors are OPERABLE, CTS justification for this less restrictive change. open A.8 Table 3.3-3 Action 8 allows continued operation provided the containment purge isolation valves are kept closed.

ITS 3.3.7 Action B requires, if one required manual Actuation channel or Actuation Logic channel is inoperable, or more than one instrument channel is inoperable, or the Completion Time of ITS 3.3.7, Action A, is not met, either closing the containment purge and i

exhaust valves and maintaining them in a closed position, or entering the applicable Conditions and Required Actions of ITS 3.9.3, which requires j suspending Core Alterations and all movement of irradiated fuel assemblies within containment. By I

providing attemative Actions, this is a less restrictive change. The justification does not address orjustify this as a less restrictive change.

BGE Response:

5 1.A.1 CTS Table 3.3-4 contains a " Trip Setpoint" column and Provide additional discussion ana 6/3/97 an " Allowed Values" column. ITS 3.3.7 contains only the justification, identifying the plant open allowable values for the trip setpoints. These specific procedures that contain the trip setpoints, trip setpoints are moved in plant procedures. The and controls over changes to the trip justification does not identify the plant procedures setpoints in those plant procedures. i receiving these trip setpoints nor the specific controls that maintain the requirement in plant procedures.

l BGE Response:

1

g .

4 CCNPP ITS 3.3.7 CONTAINMENT RADIATION SIGNAL (CRS) tatg337.cci 3.3.7 DOC JFD CHANGE / DIFFERENCE ~ COMMENT STATUS 6 LA.3 CTS Table 4.3-2, Functional Unit 6.a. requires a Provide justification for this as an 6/3/97 CHANNEL FUNCTIONAL TEST (CFT) for the manual administrative change or provide details open purge valve control switches every refueling interval. clearfy showing the details removed from ITS SR 3.3.7.5 requires a CFT of the Containment the CTS requirements.

Radiation Signal Manual Actuation Channels every 24 months. This is justified as a Less Restrictive Removal of Requirements rather than as an administrative change.

BGE Response:

7 STS 3.3.7 Required Actions B.1 and B.2 are connected Provide justification for this STS deviation 6/3/97 by an 'AND* logical connector. Corresponding ITS 3.3.7 based on cunent licensing basis, system open Required Actions B.1 and B.2 are connected by an 'OR* design, and operational constraints.

logical connector. Changing the logical connector from Acceptance of this STS deviation is based

'AND' to 'OR' is based on TSTF-185 (CEOG-97) which on NRC approval of TSTF-185 has not yet been approved by the NRC. (CEOG-97).

BGE Response:

1 f

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CCNPP ITS 3.3.8 CONTROL ROOM RECIRCULATION SIGNAL (CRRS) taus3emi ,

t 3.3.8 DOC JFD CHANGE / DIFFERENCE CONIMENT STATUS r 1 15 STS/ITS 3.3.8 Applicability Revise the submitta! to justify this STS 6/3/97 i STS/ITS 3.3.8 Actions A, C difference in Applicability and achon open ,

requirements by discussing the system !

The Appik tAHiy of STS 3.3.8 is MODES 1,2,3,4,5, design and the adequacy of current and 6, during CORE ALTERATIONS, and during testing practices. t movement ofirradiated fuel. The Applicability of corresponding ITS 3.3.8 is only MODES 1,2,3, and 4. > !

This difference in Applicability is also reflected in certain STS action requirements that are not being adopted in j the ITS. JFD-15 does not expirin why this specification !

need not be applicable during CORE ALTERATIONS !

and during movement of irradiated fuel, except to say ;

the proposed Applicability is based on consistency with j the plant design and current testing methods. The submittal should discuss the system design and testing ;

methods to make clear why the entire Applicability of STS 3.3.8, and related action requirements, need not be ;

adopted. .

BGE Response:

2 4 STS SR 3.3.8.1, CHANNEL CHECK, is not adopted in Provide justification for this STS deviation 6/3/97 ITS 3.3.8. JFD-4 does not directly justify this STS based on system design and the open deviation nor explain why a Channel Check is not adequacy of current testing practices.

needed based on system design and testing practices.

BGE Response: f i

i i

CCNPP ITS 3.3.8 CONTROL ROOM RECIRCULATION SIGNAL (CRRS) totd338.cc1 I 3.3.8 DOC -JFD CHANGE / DIFFERENCE COMMENT STATUS l 3 15 STS SR 3.3.8.3, CHANNEL FUNCTIONAL TEST of the Provide justificaten for this STS deviahon 6/3/97 '

Actuaten Logic, and SR 3.3.8.5, CHANNEL based on system design and the iopen FUNCTIONAL TEST of the Manual Trip, are not dopted adequacy of cunent testing preactices. :

in ITS 3.3.8. JFD-15 does not explain how the system t design and testing prachces just4y omission of these surveillances.

BGE Response:

4 3 Why does STS SR 3.3.8.6, response timo testing, not Revise the submittal to explain why 6/3/97 t need to be adopted in ITS 3.3.87 The just:Feason for response time testing is unnecessary for open this STS deviation is based on incorporating piant the control room recirculation signal. !

specific information into brackets not sufficient basis. ,

BGE Response:

l 1

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CCNPP ITS 3.3.9 CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS) ISOLATION SIGNAL tatd33s.cci 3.3.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS w .

1 LA.4 The CTS Table 3.3-3 requirements for the CVCS Provide additional discussion and 6/3/97 Isolation Manual Initiation, Function 8.a. are moved to justification, idenbfying the plant .

open unidentified plant procedures. ITS 3.3.9 does not procedures that contain the CVCS mancal :

contain requirements for manual initiation of the CVCS initiation requirements, and controls over i

isolation system. The justification does not identify the changes to the requirement in plant !

plant procedures receiving these CVCS manual initiation procedures. ;

requirements nor the specific controls ttiat maintain the requirement in plant procedures. ;

=_

BGE Response:

2 LA.2 CTS Table 3.3.3 Action 7.'o requires placing all Provide additional discussion and 6/3/97 functional units receiving a parameter input from the justification, identifying how CTS Table open i inoperable channel in the same tripped or bypassed 3.3-3, Action 7.b, is accomplished under condition as the inopemble trip channel within cne hour. ITS 3.3.9. .

ITS 3.3.9 does not require this action. This requirement is moved to the Safety Function Determination Program See comment 3.3.4-3 ,

(SFDP) of ITS 5.5.15. However, the SFDP is activated [

under ITS 3.0.6, which is not required by any ITS 3.3.9 i ACTION, and does not accomplish CTS Table 3.3-3, !

Action 7.b, or an eqdvalent action. !

BGE Response- j O

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I CCNPP ITS 3.3.9 CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS) ISOLATION SIGNAL tabosomt 3.3.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 3 LA.2 CTS Table 3.3-3, Action 7.b, requires placing all Provide additional discussion and 6/3/97 funchonal units receiving a parameter istput from the justification, identifying the plant open ;

inoperable channel in the same tripped or bypassed procedures that mair tain control over the [

condition as the inoperable trip channel within one hour. plant change control process and controls ITS 3.3.9 does not require this action. This requirement over changes to the SFDP that affect the 6 is moved to the Safety Function Determination Program CTS Table 3.3-3, Action 7.b requirement ;

(SFDP) of ITS 5.5.15. The justification states that for placing all funchonal units receiving a l changes to the SFDP are in accordance with the plant parameter input from the inoperable ,

change control process. The plant change control channel in the same tripped or bypassed ;

process is not identified. condition as the inoperable trip channel !

within one hour.

1 See comment 3.3.4-12 I

BGE Response:

4 M.2 CTS 3/4.3.2.1 does not include specific requirements if Provide discussion and justification for 6/3/97 l an Action cannot be completed within the required this change from the CTS 3.0.3 - 13 hour1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months open ;

Completion Time, or if two Actuation Logic channels are requirement to reach MODE 4 to the ITS !

inoperable. Thus, entering CTS 3.0.3 is required if the 3.3.9, Action D,36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months requirement to <

Action is not compieied within the Completion Time or if reach MODE 5. I two Actuation Logic channels are inoperable. CTS 3.0.3 :

allows 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 20 reach MODE 3, and 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months to reach MODE 4. ITS 3.3.9 Action D is added for when two Actuation Logic channels are inoperable, or the .

Required Action and Associated Completion Times cannot be met. It requires MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . No justification is provided for l changing the CTS 3.0.3 - 13 hour1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months requirement to reach MODE 4 to the ITS 3.3.9, Action D,36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months requirement i to reach MODE 5. !

i

- ^

m ,

r CCNPP ITS 3.3.9 CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS) 8 SOLATION SIGNAL tatd339.cci i 3.3.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS BGE Response: '

5 LA.3 CTS Table 3.3-4 contains Trip Setpoint" and " Allowable Provide additional discussion and 6/3/97 Values" columns. ITS SR 3.3.0.2 contains only the justification, identifying the plant 'open ;

" Allowable Values" column. Specific trip setpoints are procedures that contain the trip setpoents, maintained in plant procedures. The justification for and controls over changes to the trip '

i deletng the CTS Table 3.3-4 " Trip Setpoint" column setpoints in those plant procedures.

does not identify the plant procedures that maintain the trip setpoints nor the specific controls that maintain the <

requirement in plant procedures.

I BGE Response: !

6 ITS 3.3.9 adds the note "LCO 3.0.4 is not applicable" to Verify that the changes assoc 6ated with 6/3/97 ITS 3.3.9, Action C. The note "LCO 3.0.4 is not TSTF-84 have been withdrawn. open :

apphcable" is not contained in STS 3.3.9, Action C. This !

STS deviation is based on TSTF-84. On 4/22/97 BGE indicated by e-mail that TSTF-84 was being withdrwan .

from the submittal. i CGE Response:

i 7 ITS 3.3.9 adds the condition "two Actuation Logic Acceptance of this STS deviation is based 6/3/97 Channels inoperable" to Action D, that is not contained on NRC approval of TSTF-187 open in STS 3.3.9, Action D. This STS deviation is based on (CEOG-99). !

TSTF-187 (CEOG-99) which has not yet been approved by the NRC. ;

i R". _" _~_4sponse:

l l

t

n CCNPP ITS 3.3.9 CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS) ISOLATION SIGNAL tatd339.ect 3.3.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 8 4 ITS SR 3.3.9.2 limits CHANNEL FUNCTIONAL Provide a plant-speafic justificaten for 6/3/97

- TESTING of relays associated with plant equipment that this STS deviation based on cunent open cannot be operated during plant operaten to once per- licensing basis or system design.

24 months, instead of the STS SR 3.3.9.2 "during each MODE 5 entry exceeding 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless tesied within the previous 6 months." This STS deviation is not justified by JFD-4.

BGE Response:

9 A.11 4 ITS SR 3.3.9.2 Notes 1 and 2 6/3/97 CTS 4.3.2.1.1 for Table 4.3-2 Functional Unit 8 "CVCS open isolation"

a. Notes 1 and 2 for ITS SR 3.3.9.2 have been a. Revise the submittal with appropriate adopted as an administrative change. However, justifications.

because Note 1 speedies a requirement not explicitly given in CTS 4.3.2.1.1, adopting it is a more restnctive change. In addition, because Note 2 specifies an allowance not given in CTS 4.3.2.1.1, adopting it is a less restrictive change.

b. ITS SR 3.3.9.2 Note 2 is less restrictive than the b. Revise the submittal with a JFD to corresponding Note 2 of ST3 SR 3.3.9.2. The STS address this difference.

markup indicates that JFD 4 explains the basis for the difference. However, JFD 4 does not explain why it is acceptable to only test the relays "once per 24 months" instead of"during each Mode 5 entry exceeding 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unless tested within the previous 6 months."

BGE Response:

~

I I

4.-- . g CCNPP ITS 3.3.9 CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS) ISOLATION SIGNAL tatW339.cx:1 3.3.9 DOC -JFD CHANGE / DIFFERENCE COMMENT STATUS 10 M.3 ITS SR 3.3.9.1 Revise the submittal to correct this error. 6/3/97 CTS 4.3.2.1.1 . open CTS Table 4.3-2 Functional Unit 8 "CVCS Isolation" A Channel Check for the CVCS isolation functional unit is adopted as ITS SR 3.3.9.1 and justified by DOC M.3, as indicated on the markup of CTS Table 4.3-2.

However, the snarkup of CTS 4.3.2.1.1 mistakenly lists this DOC as M.4, which doesn't exist.

BGE Response:

m ^

c .

CCNPP ITS 3.3.9 CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS) ISOLATION SIGNAL tabl339.cci 3.3.9 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 11 A.1 ITS 3.3.9 ACTIONS A and D 6/3/97 LA.4 CTS 3/4.3.2.1 Action b and Table 3.3-3 Action 6 for open Functional Unit 8.a " Manual (CVCS isolation Valve Control Switches)

CTS 3/4.3.2.1 Action b and Table 3.3-3 Functional Unit 8.b "CVCS isolation"

a. CTS Table 3.3-3 Action 6 co:Tesponds to both a. Revise the CTS markup accordingly.

ACTION A and ACTION D of ITS 3.3.9. The markup of CTS Table 3.3-3 (page 3/4 3-15) does not show the correspondence to ACTION D.

b. CTS Table 3.3-3 Action 6 is listed with Functional Unit b. Revise the submittal with an 8.a. not with 8.b. All requirements for Functional Unit appropriate justification for applying the 8.a are moved from the CTS to plant procedures requirements of Action 6 to Functional according to DOC LA.4. Yet Action 6 is treated as being Unit 8.b.

retained for Functional Unit 8.b. "CVCS isolation." Only CTS Action 7 is listed with Functional Unit 8.b. Thus, applying the requirements of Action 6 to Functicini Unit 8.b in ITS 3.3.9 is a more restrictive change.

BGE Response:

f t

l CCNPP ITS 3.3.10 POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION tatd3310.cci 3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 1 LA.2 CTS Table 3.3-10 Note

stctes that a channel of the Provide additional discussion and. 6/4/97 ;

Reactor Vessel Water Level instrumentation consists justification for moving these details, open I of eight sensors per probe, and that a channel is documenting the recipient ,

OPERABLE if four or more sensors (one or more documentation for these design details among the upper three and three or more in the lower and controls over changes to the details five) are OPERABLE. The justification for deleting located in that documentation.

these details from ITS 3.3.10 states these details are relocated to the BASES and moved to plant procedures. LA.2 is not clear as to the disposition of '

these design details and the controls that maintain these details once they are removed from the ITS.

i BGE Response:

2 CTS Table 3.3-10 instrument 3, Reactor Coolant Revise the submittal to justify the 6/4/97 Outlet Temperature, requires a minimum of 2 change from a minimum of 2 channels to open channels Operable. Corresponding ITS Table 3.3.10- 2 indication channels per loop. ;

1, Function 2, Reactor Coolant Outlet Temperature, '

requires 2 indication channels per loop Operable. The i change from a minimum of 2 channels to 2 indication channels per loop appears to be a more restrictive -

change.

BGE Response:

I

f

.s g .

i CCNPP ITS 3.3.10 POST-ACCfDENT MONITORING (PAM) INSTRUMENTATION tabs 3310.cc1 j 3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS t

3 CTS Table 3.3-10 instrument 9 and ITS Table 3.3.10- Justify having the same action for both 6/4/97 1, Function 4, RCS Subcooled Margin Monitor, the inoperability of the only required RCS open require a single instrument channel for this Regulatory Subcooled Margin Monitor channel and Guide 1.97, Type A, variable. The ITS 3.3.10 the inoperability of one channel of a A tions for that inoperable channel are the same as redundant pair of instrument channels. i the iTS 3.3.10 Actions for the loss of a single channel of a Function with redundant channels. It is Provide justification for this STS not clear how the loss of the single RCS Subcooled deviation based on current licensing Margin Monitor channel is compensated for as it is basis and system design. .

the only indicator of RCS Subcooled Margin. This !

deviates from STS 3.3.11, as redundant instrument ;

channels are required for all variables in STS Table '

3.3.11-1. t BGE Response: ,

4 LA.8 CTS Table 3.3-6 reqdres two channels of Provide additional discussion and 6/4/97 LA.10 Containment Area High Range monitors OPERABLE in justification for moving this detail, open MODES 1,2,3, and 4. In addition, CTS Table 4.3-3 documenting the plant procedure !

specifies surveillances to be met in these Modes. containing this requirement and controls Corresponding ITS Table 3.3.10-1 does not specify over changes to this requirement located these requirements in Mode 4, which is a less in that procedure. !

restrictive change. The Mode 4 requirements are i moved to unidentified plant procedures.

BGE Response:

I

. ~ .-

m CCNPP ITS 3.3.10 POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION tabs 3310.cci 3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS 5 LA.8 CTS Table 3.3-6 requires two Containment Area High Revise the submittal to discuss and 6/4/97 LA.10 Range monitors in MODES 1,2,3, and 4. Similarly, justify this less restrictive change, open

, CTS Table 4.3-6 requires surveillances for this PAM documenting why CTS Table 3.3-6 and instrumentation to be met in Modes 1, 2,3, and 4. 4.3-3 requires two channels of Corresponding ITS 3.3.10 and Table 3.3.10-1 require Containment Area High Range monitors two PAM channels of Containment Area Radiation OPERABLE in MODE 4 and detailing the (high range) and corresponding testing requirements acceptability of deleting that (SR 3.3.10.1 and SR 3.3.10.3) in MODES 1, 2, and 3 requirement.

only. The deletion of the MODE 4 from the

Applicability is a less restriptive change. LA.8 does not explain why this PAM instrumentation is not needed in Mode 4.

. BGE Response:

6 CTS Table 3.3-6 lists for Instrument 1.b, Containment Revise the submittal to identify and 6/4/97 Area High Range monitors, a range of 1 to 10* R/hr justify the removal of the required range open and a alarm / trip setpoint of :s; 10 R/hr. The and the alarm / trip setpoint for the disposition of the required range and the alarm / trip Containment Area High Range monitors. i setpoint is not identified in the markup of CTS Table ,

[

3.3-6. These requirements are not contained in !

coresponding ITS 3.3.10 for Function 9. j BGE Response:

1 r

I f

1

' i

-. __ .-..m_____--_m .. . . ~ . _ . _ . _ _ _ _ _ . .. -

p CCNPP ITS 3.3.10 POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION totd3310.cc1 3.3.10 DOC ~ JFD CHANGE / DIFFERENCE COMMENT STATUS 7 ITS Table 3.3.10-1 Function 4, RCS Subcooled Provide additional discussion, clarifying 6/5/97 Margin Monitor, requires a single instrument chanr:el there are 2 required channels for this open

, for this Regulatory Guide 1.97, Type A, variable. The Type A variable in ITS Table 3.3-10, as ITS 3.3.10 Bases states the "two SMMs consist of required by Regulatory Guide 1.97.

redundant microprocessor based instruments,"

indicating one analog indicator for the two microprocessor based channels.

BGE Response:

8 LA.7 l The requirements for CTS Table 3.3-10, PAM Provide additional discussion and 6/5/97 Instrumentation, include requirements for the non- justification for moving these PAM open Category 1 variables Auxiliary Feedwater (AFW) Flow instrumentation requirements, Rate, Power-0perated Relief Valve (PORV)/ Safety documenting the plant procedures Valve Acoustic Flow Monitoring, PORV Solenoid containing these requirements and Power Indication, and Feedwater Flow. These controls over changes to these requirements are moved to unidentified plant requirements located in those procedures. procedures.

CGE Response:

9 LA.6 CTS Table 4.3-10, Footnote *, requires calibrating Provide additional discussion and 6/5/97 the core exit thetmocouple prior to installation into - justification for moving the requirement open the reactor core. This requirement is moved to to calibrate the core exit thermocouple unidentified plant procedures. prior to installation into the reactor core, documenting the plant procedures containing these requirements and controls over changes to these requirements located in those procedures.

EGE Response:

m CCNPP ITS 3.3.10 POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION tabl3310.cc1 3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT . STATUS 10 LA.12 CTS Table 4.3-3, requires a CHANNEL CHECK of the Revise the submittat documenting the 6/5/97 Ccntainment Area High Range radiation monitors plant procedures containing the shiftly open each shift. ITS SR 3.3.10.1 requires a monthly Channel Check requirement and controls CHANNEL CHECK for these PAM instrument over changes to these procedures.

channels. The requirement for the CHANNEL CHECK every shift is moved to unidentified plant procedures.

BGE Response:

11 LA.12 CTS Table 4.3-3, requires a CHANNEL CHECK of the Revise the submittal to justify the 6/6/97 Containment Area High Range radiation monitors Channel Check Frequency relaxation as a open each shift. ITS SR 3.3.10.1 requires a monthly L-type change.

CHANNEL CHECK for these PAM instrument "

channels. Decreasing the Channel Check Frequency from shiftly to monbtly is a less restrictive change.

BGE Response:

12 ' LA.4 CTS Surveillance Requirement 4.6.5.1.1 requires Provide additional discussion and 6/6/97

. demonstrating each hydrogen analyzer is OPERABLE justification for moving the requirement open at least biweekly, on a Staggered Test Basis, by for demonstrating each hydrogen ;

I drawing a sample from the Waste Gas System analyzer is OPERABLE, documenting the through the hydrogen analyzer. This requirement is plant procedures containing these i moved to unidentified plant procedures. In addition, requirements and controls over changes no justification is given for removing this surveillance to these requirements located in those -

l from CTS. procedures. !

l BGE Response:

j .

f r

._._m - _ _ _ _ . _ _ . . . . . . . _ . . . _ _ _ _ _ _ . . . _ . - _ . _ _ _ _ _ _ _ . . . . . . . _ . -

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CCNPP ITS 3.3.10 POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION tabi3310.cc1 3.3.10 DOC JFD CHANGE / DIFFERENCE COIL 4 MENT STATUS 13 LA.9 CTS Table 3.3-6, Action 30, requires, with the Provide additional discussion and 6/6/97 number of channels of Containment Area High Range justification for moving the requirement open radiation monitors less than that required, initiating an for implementing the pre-planned alternate pre-planned method of monitoring within 72 attemative method of monitoring this hours. The 72-hour requirement to implement the variable, documenting the plant pre-planned alternative method of monitoring this procedures containing these variable is moved to an unidentified procedure, requirements and controls over changes to these requirements located in those procedures.

BGE Response:

14 LA.11 CTS Table 4.3-3, requires a monthly CHANNEL Revise DOC LA.11 to contain additional 6/6/97 FUNCTIONAL TEST (CFT) of the Containment Area discussion and justification for moving open High Range Radiation Monitor. This CTS Table 4.3-3 the requirement for a monthly CHANNEL CFT requirement is not required by ITS 3.3.10, and is FUNCTIONAL TEST of the Containment moved to unidentified plant procedures. Area High Range Radiation Monitor, documenting the p! ant procedures containing these requirements and controls over changes to these requirements located in those I procedures.

BGE Response:

t

l CCNPP ITS 3.3.10 POST-ACCIDENT MONITORING (PAM) INSTRUMENTATION tabs 3310.cci 3.3.10 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,

15 ITS Table 3.3.10-1 Function 4 requires a single RCS Provide discussion on how the loss of 6/6/97 Subcooled Margin Monitor channel. For this the RCS Subcooled Margin Monitor open Function, ITS Table 3.3.10-1 requires Condition F channel requires the forced shutdown of when referenced from ITS 3.3.10, Action E. ITS 3.3.10-1, Condition F, as required However, for Action E to apply, and hence, Action F, by ITS Table 3.3.10-1, Function 4.

the Action C is not completed. Action C is required when two required indication channels are inoperable, a condition that can not occur for Function 4, RCS i Subcooled Margin Monitor, because only one channel is required by ITS Table 3.3.10-1. Thus, the ITS Table 3.3.10-1, Function 4, entry for Condition F (a forced shutdown), is not possible with the single RCS Subcooled Margin Monitor channel.

BGE Response: '

t i

7 A CCNPP ITS 3.3.11 REMOTE SHUTDOWN INSTRUMENTATION tatw3311.cci 3.3.11 DOC JFD CHANGE / DIFFERENCE COh4 MENT STATUS 1 LA.1 The CTS 3.3.3.5 and CTS Table 3.3-9 details of the Provide additional discussion and 6/6/97 readout location and measurement range of the justification for moving the details of the open individual instruments for the Remote Shutdown readout location and measurement range ;

instrumentation are moved to unidesitified plant of the individual instruments, pvocedures and the Updated Final Safety Analysis documenting the plant procedures Report. containing these requirements and controls over changes to these requirements located in those procedures.

BGE Response:

2 LA.1 The CTS 3.3.3.5 and CTS Table 3.3-9 details of the Provide additional discussion and l

6/6/97 !

readout location and measurement range of the justification for moving the details of the open !

individual instruments for the Remote Shutdown readout location and measurement range Instrumentation are moved to unidentified plant of the individual instruments, discussing !

procedures and the Updated Final Safety Analysis the acceptability and the safety impact '

Report. The justification for moving these of moving these requirements, requirements does not discuss the acceptability nor the safety impact of moving these requirements.

BGE Response:

3 CTS Table 4.3-6 specifically requires the wide-range Provide justification and discussion on 6/6/97 steam generator level channels for the remote moving of the specific requirement for open shutdown instrumentation. Corresponding ITS Table wide-range channels to monitor the 3.3.11-1, while requiring steam generator level steam generator level for the remote instrumentation, does not specifically require the shutdown instrumentation.

wide-range channels. Not controlling the requirement for the wide-range channels in ITS 3.3.11 could result ,

in their replacement with the narrow-range channels.

.s .-

m

[

l, i

CCNPP ITS 3.3.7 CONTAINMENT RADIATION SIGNAL (CRS) totd337.cci i

3.3.7 DOC JFD CHANGE / DIFFERENCE COMMENT STATUS

-e 3 M.1 in the event fewer than the required number of Provide additional discussion and - 6/3/97 -[

containment radiation monitors are OPERABLE, CTS justification for this more restrictive open !

Table 3.3-3 Action 8 allows continued operation provided change, addressing the adequacy of ITS the containment purge isolation valves are maintained 3.3.7, Action A, Completion Times.

closed. This allowance has no time limit. ITS 3.3.7, Action A, requires, if one instrument channel is Note: The ITS 3.3.7 Completion Tunes inoperable, either placing the affected sensor module in are consistent with the STS.

trip within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or immediately suspending Core Alterations and all movement of irradiated fuel assemblies within containment. The justification does not explain why the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time of ITS 3.3.7 Required Action A.1 (similar to the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months limit in ITS 3.3.2, Required Action A.1) is acceptable.

BGE Response: ,

I

m i

CCNPP ITS 3.3.11 REMOTE SHUTDOWN INSTRUMENTATION tabt3311.cci I

3.3.11 DOC JFD CHANGE / DIFFERENCE COlWMENT STATUS BGE Response: ,

4 JFD 17 STS SR 3.3.12.2 verifies each required control circuit Revisse the submittal to adopt this STS 6/6/97 i and transfer switch is operational. ITS 3.3.11 does surveilance requirement or provide open >

not adopt STS SR 3.3.12.2 because it is not required justification for this STS deviation based in the CTS. The justification does not discuss system on current licensing basis, system !

, design and operational constraints that preclude design, and operational constraints.

i adding this requirement to ITS 3.3.11.

BGE Response: .,

5 The Bases discussion of ITS 3.3.11 Required Action Resolve this discrepancy between ITS 6/6/97 [

A.1 states that the control and transfer switches are 3.3.11 and the ITS 3.3.11 Bases. open included in the Functions required OPERABLE.

However, the control and transfer switches are not included in ITS Table 3.3.11-1, and have no !

requirements in ITS 3.3.11. -

l

BGE Response: ;

t i

-- - ' - " - - - - ~ - ~ ' ' - ' ~ ~ - " - - - - - - - ~ - - - - - - - - - - - - - - - ' - ~ - - - - ' - - - " - - - - - - ~ --- --- '- -- -- ~ - - ' " - - - - - - ' - - - - - - ' ' - - - - " " - - - - - - - - ~ - - - - - " - - ' " " - ' " - ' - ' ' ' - ~

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CCNPP ITS 3.3.12 WIDE-RANGE LOGARITHMIC NEUTRON FLUX MONITOR CHANNELS tabs 3312.cci 3.3.12 OOC JFD CHANGE / DIFFERENCE COMMENT STATUS ,

1 A.3 CTS Table 3.3-1 contains a " Total No. of Channels" Provide justification and discussion 6/6/97 LA.1 column, a " Minimum Channels Operable" column, and showing the acceptability of the change open a " Channels to Trip" column, requiring 4 wide-range from the CTS Table 3.3-1 minimum of 3 logarithmic neutron flux monitor channels, at least 3 OPERABLE wide-range logarithmic OPERABLE, and 2 channels to trip. Corresponding ITS neutron flux monitor channels to 2 3.3.12 requires 2 OPERABLE channels of wide-range OPERABLE channels in ITS 3.3.12. ;

logarithmic neutron flux monitor channels. The change from the CTS Table 3.3-1 minimum of 3 OPERABLE wide-range logarithmic neutron flux monitor channels to 2 OPERABLE channels in ITS 3.3.12 is a less restrictive change that is not justified.

BGE Respones:

1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

v t e Letter Sequence RAI
TAC:M97363, TSTF-19, TSTF-88, TSTF-64 (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance... Administration Meeting Questions 29 May 1997 6 June 1997 11 June 1997 16 May 1997 22 October 1997 Answers 27 March 1997 Results Approval Other: ML20140H545, ML20141B944, ML20198K326, ML20198R718, ML20210K953, ML20217G338, ML20217G370, ML20217K605
MONTHYEAR1997-05-07 [Table View]

ML20140G436

Text

SUBJECT:

Dear Mr. Cruse:

Enclosure:

SUBJECT:

Dear Mr. Cruse:

Enclosure:

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