calvert cliffs, unit 3, response to request for additional … · 2015. 6. 22. · at a public...

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Mark T. Finley 750 East Pratt Street, Suite 1400 Baltimore, Maryland 21202 Senior Vice President, Regulatory Affairs & Engineering UniStar NUCLEAR ENERGY 10 CFR 50.4 10 CFR 52.79 December 20, 2012 UN#12-156 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Subject: UniStar Nuclear Energy, NRC Docket No. 52-016 Response to Request for Additional Information for the Calvert Cliffs Nuclear Power Plant, Unit 3, RAI 336, Ultimate Heat Sink References: 1) Surinder Arora (NRC) to Paul Infanger (UniStar Nuclear Energy), "Final RAI 336 SBPA 6230," email dated January 20, 2012 2) UniStar Nuclear Energy Letter UN#12-044, from Mark T. Finley to Document Control Desk, U.S. NRC, Response to Requests for Additional Information for the Calvert Cliffs Nuclear Power Plant, Unit 3, RAI 325, Information Systems Important to Safety: RAI 325, Information Systems Important to Safety, RAI 328, Flooding Protection Requirements, RAls 287, 330, RAI 331, RAI 332, RAI 336, Ultimate Heat Sink, RAls 333, 339, Other Seismic Category I Structures, RAI 337, Initial Plant Test Program - Design Certification and New License Applicants, and RAI 340, Functional Design Qualification and Inservice Testing Programs for Pumps, Valves, and Dynamic Restraints, dated May 18, 2012 The purpose of this letter is to respond to the request for additional information (RAI) identified in the NRC e-mail correspondence to UniStar Nuclear Energy, dated January 20, 2012 (Reference 1). This RAI addresses the Ultimate Heat Sink, as discussed in Section 9.2.5 of the

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Page 1: Calvert Cliffs, Unit 3, Response to Request for Additional … · 2015. 6. 22. · At a public meeting on May 3, 2012, UniStar made a presentation to the NRC indicating its intent

Mark T. Finley 750 East Pratt Street, Suite 1400Baltimore, Maryland 21202

Senior Vice President, Regulatory Affairs & Engineering

UniStarNUCLEAR ENERGY

10 CFR 50.410 CFR 52.79

December 20, 2012

UN#12-156

ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

Subject: UniStar Nuclear Energy, NRC Docket No. 52-016Response to Request for Additional Information for theCalvert Cliffs Nuclear Power Plant, Unit 3,RAI 336, Ultimate Heat Sink

References: 1) Surinder Arora (NRC) to Paul Infanger (UniStar Nuclear Energy), "FinalRAI 336 SBPA 6230," email dated January 20, 2012

2) UniStar Nuclear Energy Letter UN#12-044, from Mark T. Finley toDocument Control Desk, U.S. NRC, Response to Requests for AdditionalInformation for the Calvert Cliffs Nuclear Power Plant, Unit 3, RAI 325,Information Systems Important to Safety: RAI 325, Information SystemsImportant to Safety, RAI 328, Flooding Protection Requirements, RAls 287,330, RAI 331, RAI 332, RAI 336, Ultimate Heat Sink, RAls 333, 339, OtherSeismic Category I Structures, RAI 337, Initial Plant Test Program - DesignCertification and New License Applicants, and RAI 340, Functional DesignQualification and Inservice Testing Programs for Pumps, Valves, andDynamic Restraints, dated May 18, 2012

The purpose of this letter is to respond to the request for additional information (RAI) identifiedin the NRC e-mail correspondence to UniStar Nuclear Energy, dated January 20, 2012(Reference 1). This RAI addresses the Ultimate Heat Sink, as discussed in Section 9.2.5 of the

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UN#1 2-156Page 2

Final Safety Analysis Report (FSAR), as submitted in Part 2 of the Calvert Cliffs Nuclear PowerPlant (CCNPP) Unit 3 Combined License Application (COLA), Revision 8.

Reference 2 indicated that responses to RAI 336, Questions 09.02.05-23, 24, 25, and 27 wouldbe provided to the NRC by December 20, 2012. Enclosure 1 provides our responses to RAI336, Questions 09.02.05-23, 24, 25, and 27, and includes revised COLA content. A LicensingBasis Document Change Request has been initiated to incorporate these changes into a futurerevision of the COLA. Enclosure 2 provides a table of changes to the CCNPP Unit 3 COLAassociated with the RAI 336 response. This submittal does not modify previously submitted RAIresponses.

Our response does not include any new regulatory commitments. This letter does not containany sensitive or proprietary information.

If there are any questions regarding this transmittal, please contact me at (410) 369-1907 orMr. Wayne A. Massie at (410) 369-1910.

I declare under penalty of perjury that the foregoing is true and correct.

W Executed on Decem 20, 2012

M 'T.Fin<ey

Enclosures: 1) Responses to NRC Request for Additional Information, RAI 336, Questions09.02.05-23, 24, 25, and 27, Ultimate Heat Sink, Calvert Cliffs NuclearPower Plant, Unit 3

2) Table of Changes to CCNPP Unit 3 COLA Associated with the Responsesto RAI 336, Questions 09.02.05-23, 24, 25, and 27, Calvert Cliffs NuclearPower Plant, Unit 3

cc: Surinder Arora, NRC Project Manager, U.S. EPR Projects BranchLaura Quinn-Willingham, NRC Environmental Project Manager, U.S. EPR COL ApplicationAmy Snyder, NRC Project Manager, U.S. EPR DC Application, (w/o enclosures)Patricia Holahan, Acting Deputy Regional Administrator, NRC Region II, (w/o enclosures)Silas Kennedy, U.S. NRC Resident Inspector, CCNPP, Units 1 and 2,David Lew, Deputy Regional Administrator, NRC Region I (w/o enclosures)

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UN#12-156

Enclosure 1

Responses to NRC Request for Additional Information,RAI 336, Questions 09.02.05-23, 24, 25, and 27,

Ultimate Heat Sink,Calvert Cliffs Nuclear Power Plant, Unit 3

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Enclosure 1UN#1 2-156Page 2 of 23

Response

At a public meeting on May 3, 2012, UniStar made a presentation to the NRC indicating itsintent to pursue the following approach for Calvert Cliffs Nuclear Power Plant Unit 3 (CCNPPUnit 3) Ultimate Heat Sink (UHS) Makeup Water System.

A. Changing the UHS Makeup Water screen wash system from Non Safety-Related (NSR)to Safety-Related.

B. Eliminate the UHS Makeup Water screen wash pumps and provide wash water to thescreens from the safety-related UHS Makeup Water pumps.

C. Changing the UHS Makeup Water System from a dry layup system to a wet layupsystem.

D. Performing the UHS Makeup Water System functional test and flushing the entire UHSMakeup Water System piping every three months (quarterly).

E. Adding a new Limiting Condition for Operation (LCO) for the required number ofoperable UHS Makeup Water System trains to site-specific Technical Specifications(TS).

F. Adding a new Surveillance Requirement (SR) to verify the proper operation of travelingscreens and screen wash system and forebay level to site-specific TS.

G. Providing UHS Makeup Water traveling screen motor and pump discharge strainermotor status and heat tracing alarm.

H. Verifying that the Instrumentation and Controls (I&C) signals that trip the UHS MakeupWater pumps are safety-related signals.

I. Adding an ITAAC to verify UHS Makeup Water System water temperature does notexceed 95°F.

J. Changing operation of the traveling screens and screen wash system to eliminate localmanual actions.

K. Clarifying that the UHS Makeup Water System operation is manually initiated by theoperator from the Main Control Room based on UHS cooling tower basin level

L. Changing the UHS Makeup Water traveling screens and screen wash system to SeismicCategory I to comply with General Design Criterion (GDC) 2

M. Including the UHS Makeup Water System traveling screens and screen wash system aspart of the Reliability Assurance Program and Maintenance Rule

N. Incorporating frequent rotation and cleaning of the UHS Makeup Water traveling screensinto the FSAR

0. Providing heating to the UHS Makeup Water Intake Structure (MWIS) Traveling Screenroom to maintain the temperature at or above 41 OF, to mitigate icing effects

Items A, B, J, L, M, N, and 0 are discussed in RAI 330 Question 09.02.05-20 responseUN#12-153.Items C and D are discussed in RAI 332 Question 09.02.05-22 response UN#12-154.Items E and F are discussed in RAI 336 Question 09.02.05-23 response UN#12-156.Items G and H are discussed in RAI 336 Question 09.02.05-24 response UN#12-156and RAI 325 Question 07.05-1 response UN#12-151.Item G is discussed in RAI 337 Question 14.02-58 response UN#12-157.Item I is discussed in RAI 336 Question 09.02.05-27 response UN#12-156.Item K is discussed in RAI 325 Question 07.05-1 response UN#12-151.

All of the above responses were submitted December 20, 2012.

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Enclosure 1UN#12-156Page 3 of 23

RAI No 336

Question 09.02.05-23

10 CFR 50.36, Technical Specifications (TS) states that each applicant for a license authorizingoperation of a production or utilization facility shall include in his application proposed technicalspecifications in accordance with the requirements of this section.

In addition, a TS limiting condition for operation (LCO) of a nuclear reactor must be establishedfor each item meeting one or more of the following criteria:

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the controlroom, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2. A process variable, design feature, or operating restriction that is aninitial condition of a design basis accident or transient analysis that either assumes thefailure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3. A structure, system, or component that is part of the primary successpath and which functions or actuates to mitigate a design basis accident or transient thateither assumes the failure of or presents a challenge to the integrity of a fission productbarrier.

(D) Criterion 4. A structure, system, or component which operating experience orprobabilistic risk assessment has shown to be significant to public health and safety.

Criterion 3 is applicable for the UHS makeup water system since the UHS makeup watersystem is necessary to supply water for the UHS cooling tower basin and supports long termheat removal post DBA. The important-to-safety system and component it supports are thecomponent cooling water system and emergency diesel generators.

The applicant should describe in the CCNPP Unit 3 application those TS LCO and surveillancerequirements (SR). Without the UHS makeup water system there is a potential that the essentialcooling water system pumps would fail due to the loss of net positive suction head (NPSH) andlong term cooling water would be lost for EDG and core cooling support.

Considerations for TS LCO, SR, and associated TS Bases should include:

1. UHS makeup water supply temperature2. UHS makeup water (forebay) level (required to support proper operations of the makeup

water pumps)3. UHS travelling screens and screen wash pumps (assured flow path)4. UHS makeup water system readiness to provide a required flow path in a required time

of, but no longer than 72 hours.

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Enclosure 1UN#12-156Page 4 of 23

Response

RAI 336 Q09.02.05-23 identifies four considerations for TS LCO, Surveillance Requirements(SR) and associated TS Bases.

1. UHS Makeup Water Supply Temperature:

The UHS Makeup Water system draws water from the Chesapeake Bay, starting 72hours post-DBA, to provide makeup water to the UHS cooling tower basin to ensureadequate basin volume for the required net positive suction head (NPSH) for theassociated Essential Service Water (ESW) pump. The UHS Makeup Water Systemprovides a minimum of 300 gpm to the basin to make-up for losses due to evaporation,drift, seepage, and boundary isolation valve seat leakage, starting 72 hours post-DBA.The UHS cooling tower basin has a U.S. EPR FSAR TS SR to verify the basin watertemperature of each UHS cooling tower to be less than or equal to 90°F (32.2°C).Based on CCNPP Unit 1 and 2 intake channel surface water temperature for the past 17years, the highest experienced inlet water temperature recorded was 88.13°F (31.2 0C).The CWS and UHS common forebay draws water from the Unit 3 inlet area at anelevation well below the extreme low water level of the bay, where the drawn watertemperature is lower than the measured surface water temperature of the ChesapeakeBay. Since the maximum UHS Makeup Water System flow of 750 GPM is a minorcontributor to the total UHS Cooling Tower post-DBA minimum basin volume ofapproximately two million gallons before starting 72 hours post-DBA, the temperatureimpacts from the UHS Makeup Water System to the total basin volume are considerednegligible. The UHS cooling tower basin U.S. EPR TS SR temperature limit of less thanor equal to 90°F (32.2'C), and the critical temperature of the ESW to CCWS heatexchanger of 950 F (350C), as described in the U.S. EPR Technical Specification, willensure the UHS cooling tower basin can perform its safety function to mitigate a designbasis accident. Therefore, a site-specific TS LCO or SR for the UHS Makeup Waterforebay temperature is not required, since the current SR or TS ensures the ability of theUHS Makeup Water system to support the long term heat removal post-DBA.

2. UHS Makeup Water (forebay) Level (required to support proper operations of themakeup water pumps):

The UHS Makeup Water forebay level is currently measured upstream and downstreamof UHS Makeup Water traveling screens, to determine the differential level across thescreens for operation of the screen wash system. The downstream level locationmeasures the water level at the UHS Makeup Water pump bay, which can be used toensure proper water level is available for NPSH of the UHS Makeup Water pump.Therefore, this downstream UHS Makeup Water pump bay water level will be added tothe CCNPP Unit 3 Technical Specification Surveillance Requirement, to ensureadequate NPSH is available to maintain proper operation of the UHS Makeup Waterpump and that the pump can perform its safety function of providing makeup water to theUHS cooling tower basin starting 72 hours post-DBA. CCNPP Unit 3 FSAR Subsection9.2.5.3.2, "UHS Makeup Water System Pumps" describe the excess margin (33.3 ft)between the NPSH-available and NPSH-required. CCNPP Unit 3 COLA Part 4Technical Specifications and Bases are being updated to include the new surveillancerequirement for UHS Makeup Water pump bay level.

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Enclosure 1UN#12-156Page 5 of 23

3. UHS Makeup Water Traveling Screens and Screen Wash Pumps (assured flow path):

The response to RAI 330 Q09.02.05-20 (separate submittal) describes the design ofUHS Makeup Water traveling screens as safety-related and the classification as SeismicCategory I. Also, the response to RAI 330 Q09.02.05-20 describes changes to the UHSMakeup Water screen wash system, removing the requirement for screen wash pumpsand updating the design and classification of the UHS Makeup Water screen washsystem components, piping, valves, fittings, instrumentation and spray nozzles to Safety-Related and Seismic Category I. Therefore, the UHS Makeup Water traveling screensare capable of automatic rotation and frequent screen wash to keep the screens clearfrom debris. No local manual operator actions are required for the traveling screens andthe screen wash system; thus operator error is minimized. Prior to the start of thepumps, operators ensure that there is adequate water level in the UHS Makeup Waterintake structure pump bay and traveling screens are not blocked, by rotating the screensone quarter turn to supply the necessary makeup water flow to the UHS cooling towerbasin. A new surveillance requirement SR 3.7.22.2 is added to the Plant SpecificTechnical Specification to verify the operation of the UHS Makeup Water travelingscreens and verify the operation of the screen wash systems quarterly. This will ensurea clear flow path is available for the UHS Makeup Water Pump to provide the minimumrequired makeup water flow of 300 gpm to the UHS cooling tower basin, coincident withthe design flow rate of the screen wash system. CCNPP Unit 3 COLA Part 4 TechnicalSpecifications and Bases are being updated to include the new surveillance requirementof the UHS Makeup Water traveling screens operation.

4. UHS Makeup Water System Readiness to Provide a Required Flow Path in the RequiredTime of no longer than 72 hours:

The response to RAI 332 Question 09.02.05-22 (separate submittal) describes the wetlayup UHS Makeup Water System that maintains the piping full of water during normal,shutdown/cooldown and Design Basis Accident (DBA) conditions. The UHS MakeupWater System will normally be maintained full, tested and ready for operation 72 hourspost-DBA. The UHS Makeup Water system will be flushed quarterly through the UHStest bypass isolation valve located in the ESW pump house, to ensure system availabilityto provide the greater than or equal to 300 gpm of makeup water to the UHS coolingtower basin post-DBA. The UHS Makeup Water pumps rated capacity and minimumflow requirements to the basin are addressed in FSAR Subsection 9.2.5.3.2 and Part 10(ITAAC) Table 2.4-22 Item 17, respectively. The CCNPP Unit 3 Plant Specific TechnicalSpecifications Surveillance Requirement 3.7.19.6 and Plant Specific TechnicalSpecification Bases 3.7.19 ensure the ability of the system to supply emergency makeupwater to each UHS cooling tower basin at > 300 gpm. In addition, the SurveillanceRequirement 3.7.22.2 verifies the operation of the safety-related traveling screens andverifies that the safety-related screen wash system can provide the necessary designedscreen wash flow, concurrent with the system's ability to provide the makeup water flowto the basin. Therefore, considering the wet layup of the UHS Makeup Water Systemand the quarterly flushing of the piping system to the UHS test bypass line, the system isconsidered ready and operable at all times. In addition, a new Limiting Condition forOperation (LCO) for the required number of operable UHS Makeup Water System trainsis added to the CCNPP Unit 3 Plant Specific Technical Specifications.

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Enclosure 1UN#12-156Page 6 of 23

Any postulated operators error, which may occur during a post-DBA from UHS MakeupWater System filling a dry layup configuration (such as improper valvesequencing/manipulation of the system), is minimized with the wet layup and the UHSMakeup keep-fill system as described in the Response to RAI 332 Q09.02.05-22(separate submittal). The UHS Makeup Water System is periodically inspected tomaintain the integrity and capability of the system, and complies with 10 CFR 50Appendix A, General Design Criterion (GDC) 45. CCNPP Unit 3 COLA Part 4 TechnicalSpecifications and Bases are being updated to include a new LCO for the requirednumber of operable UHS Makeup Water System trains.

COLA Impact

CCNPP Unit 3 COLA Part 4, Technical Specifications, has been supplemented as follows:

5 BASES 3.7.19 ULTIMATE HEAT SINK (UHS)

Justification:The site specific information provided is consistent with the CCNPP Unit 3 FSAR Section 9.2description of Seismic Category I UHS Makeup Water System and the bracketed text for themakeup water to the UHS cooling tower has been added to LCO section 3.7.19 as shownabove.}

6 LCO 3.7.22 ULTIMATE HEAT SINK (UHS) Makeup Water System

Generic Technical Specifications:

The Generic Technical Specification LCO 3.7.19 Ultimate Heat Sink (UHS) does notdescribe a Limitincq Condition for Operation (LCO) for the UHS Makeup Water System.The Generic Technical Specification 3.7.19 is supplemented by the Plant SpecificTechnical Specifications 3.7.22 for the UHS Makeup Water System as below.

Plant Specific Technical Specifications:

A new Limiting Condition of Operation (LCO) section is added to the CCNPP Unit 3 TSand Bases Site-Specific Changes for the Ultimate Heat Sink (UHS) Makeup WaterSystem. The following text is added to the CCNPP Unit 3 Technical Specification andBases:

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Enclosure 1UN#12-156Page 7 of 23

3.7.22 Ultimate Heat Sink (UHS) Makeup Water System

LCO 3.7.22 Four UHS MakeuD Water Svstem trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. One or more A.1 Restore UHS Makeup Water 72 hoursUHS Makeup System train(s) toWater System OPERABLE status.train(s) inoperable.

B. Required Action B.1 Declare the associated UHS Immediatelyand associated train(s) inoperable.Completion Timenot met.

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.7.22.1 24 hours

Verify the water level of the UHSMakeup Water Pump Forebay is> -11.7 feet NGVD 29.

SR 3.7.22.2 Quarterly

Verify each UHS Makeup Watertravelincq screen rotates and screenwash system provides the necessarydesign flow rate to wash the screens,coincident with the SR 3.7.19.6 UHSemergency makeup water flow rate tothe cooling tower basin, on an actualor simulated actuation signal to verifyproper operation to perform theirassociated safety function.

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Enclosure 1UN#12-156Page 8 of 23

Justification:

Adding the Site-Specific Limiting Conditions of Operation and surveillancerequirements assure that the UHS Makeup Water System can provide the postdesign basis event safety-related function of supplying makeup water to the UHScoolinq tower basin volume to maintain the required Net Positive Suction Headavailable for proper operation of the Essential Service Water (ESW) pump. Inaddition, it ensures the makeup water flow to the basin is achieved, coincident withthe necessary design screen wash flow rate. The site specific information providedis consistent with the CCNPP Unit 3 FSAR Section 9.2.5 description of the UHSMakeup Water System,

7 BASES 3.7.22 ULTIMATE HEAT SINK (UHS) MAKEUP WATER SYSTEM

Generic Technical Specifications:

The Generic Technical Specification Bases 3.7.19 Ultimate Heat Sink (UHS) doesnot describe the UHS Makeup Water System Bases to support the UHS coolinqtower basin makeup requirements. The Generic Technical Specification Bases3.7.19 is supplemented by the Plant Specific Technical Specifications Bases 3.7.22for the UHS Makeup Water System as below.

Plant Specific Technical Specifications:

The CCNPP Unit 3 Bases 3.7.22, Ultimate Heat Sink (UHS) Makeup Water Systemis added in the LCO section, to provide plant specific information for the UHSMakeup Water System. The following text is inserted:

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Enclosure 1UN#12-156Page 9 of 23

B 3.7 Plant Systems

B 3.7.22 Ultimate Heat Sink (UHS) Makeup Water System

BASES

BACKGROUND The safety-related UHS Makeup Water System providesemergency makeup water to the UHS cooling tower basinstarting 72 hours post design basis event, to replenish lossesdue to evaporation, blowdown, drift and leakage, to ensure thatthe level of the cooling tower basin is sufficient to maintain therequired net positive suction head (NPSH) of the essentialservice water (ESW) pumips. The UHS Makeup Water Systemdraws Chesapeake Bay water from the common circulatingwater system (CWS) and UHS common forebay. Two buried60" safety-related pipes provide a flow path for Chesapeake Baywater to enter the common forebay. During normal plantoperation the UHS Makeup Water System is maintained in awet layup configuration. Starting 72 hours post design basisevent, the UHS Makeup Water System is required to provide aminimum of 300 gpm of Chesapeake Bay makeup water to theUHS cooling tower basin. In addition to the makeup water tothe basin, the UHS Makeup Water pumps also provide thenecessary intermittent design flow rate to the safety-relatedscreen wash system. The safety related functions are coveredby this LCO.

The UHS Makeup Water system consists of four separatesafety-related emergency makeup water trains. Each trainconsists of a vertical turbine pump, discharge check valve, self-cleaning strainer, and pump discharge isolation MOV. The UHSMakeup Water Intake Structure houses four bar screens andfour dual-flow traveling screens that remove large debris andtrash that may be entrained in the flow. Each traveling screen isequipped with a screen wash system, which provides a highpressure spray to remove debris from the screens.Instrumentation and controls are provided in the main controlroom (MCR) and remote shutdown station (RSS). Safety-related components of each of the four UHS Makeup WaterSystem trains are powered by the Class 1 E electrical bus foreach division and their respective emergency diesel generator(EDG).

Additional information about the design and operation of theUHS Makeup Water System is presented in FSAR Subsection9.2.5 (Ref. 1). The principal safety-related function of the UHSMakeup Water system is to provide makeup water to the UHScooling tower basin, to maintain the NPSH for the ESW pumpstarting 72 hours post design basis event up to 30 days, tosupport the accident mitigation.

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Enclosure 1UN#12-156Page 10 of 23

APPLICABLE The design basis of the UHS Makeup Water System is for twoSAFETY UHS Makeup Water trains, in coniunction with the associatedANALYSES UHS cooling tower basins, to provide emergency makeup water

to the basin, to maintain the NPSH of the ESW pumps 72 hourspost design basis event to a minimum of 30 days post designbasis event, as discussed in FSAR Subsection 9.2.1 (Ref. 2)and 9.2.5 (Ref. 1).

Each UHS Makeup Water system train is sized to provide amaximum of 750 gpm and no less than 300 gpm to theassociated UHS cooling tower basin during the post-72 hourdesign basis event. The UHS Makeup Water pumps aredesigned to provide the makeup water to the basin, coincidentwith intermittent screen wash system providing spray water tothe traveling screens. The UHS Makeup Water forebay is sizedto ensure the UHS Makeup Water pumps NPSH required isavailable based on the predicted minimum low water level of theChesapeake Bay of (-7.7) feet NGVD 29, which results in acommon forebay minimum level of (-10.2) feet NGVD 29. Theminimum water level at the UHS Makeup Water pump bay at(-11.7) feet considers a head loss of 1.5 feet across thetraveling screens. The U.S. EPR UHS cooling tower and basinare designed in accordance with Regulatory Guide 1.27 (Ref. 3)to provide a 30 day supply of cooling water in the UHS coolingtower basin. The cooling tower basin is sized considering a 72hour water storage capacity, with safety-related makeup waterprovided post 72-hours, to safely shut down and cool down theplant and dissipate the residual heat from a design basis event.For the post 72 hour through the 30 day period, the UHScooling tower basin is replenished by UHS Makeup Watersystem, to assure the continuous capability of the UHS coolingtower basin to perform its safety-related function.

The UHS Makeup Water System satisfies Criterion 3 of 10 CFR50.36 (c) (2) (ii).

LCO The UHS Makeup Water System consists of four trains. FourUHS Makeup Water System trains are required to beOPERABLE, to provide the reguired redundancy to ensure thatthe system functions to transfer the reguired supply ofChesapeake Bay makeup water to its associated UHS coolingtower basin.

A UHS Makeup Water System train is OPERABLE when thetraveling screens, pump, associated piping, valves andinstrumentation and controls required to perform the safety-related function can provide the required Chesapeake Bay

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Enclosure 1UN#1 2-156Page 11 of 23

makeup water to its associated UHS cooling tower basin,coincident with the screen wash operating at the design flowrate necessary to ensure a clear flow path, and the UHSMakeup Water pump forebay level at greater than or equal to(-11.7) feet NGVD 29.

APPLICABILITY In MODES 1, 2, 3, and 4, the UHS Makeup Water System isnormally in standby mode and required to be OPERABLE tosupport the UHS system for mitigation of a Design BasisAccident after 72 hours.

ACTIONS A.1

If any UHS Makeup Water System train is inoperable, actionmust be taken to restore OPERABLE status within 72 hours.Each OPERABLE UHS train is adequate to perform thecooling function for 72 hours post design basis event. Theassociated UHS Makeup Water System train is required tomaintain that UHS train, OPERABLE starting 72 hours postdesign basis event through 30 days or greater.

The 72 hour Completion Time to restore a UHS MakeupWater System train to OPERABLE is reasonable, since itsoperation is not assumed in the safety analysis to mitigate theconsequences of postulated accident or anticipatedoperational occurrences (AOOs) until 72 hours after theinitiating event. This provides a reasonable time for repairs,and the low probability of a postulated accident or AOOoccurring during this period.

B. 1

If a UHS Makeup Water train cannot be restored toOPERABLE status within the Associated Completion Time,the associated UHS train must be declared inoperableimmediately. Without the associated UHS Makeup WaterSystem train, the UHS train can only perform its safetyfunction for 72 hours considering the worst case design basisconditions. If multiple UHS Makeup Water System trains areinoperable, the Required Actions for Specification 3.7.19ensure UHS cooling is restored in the time framecommensurate with safety.

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Enclosure 1UN#12-156Page 12 of 23

SURVEILLANCE SR 3.7.22.1REQUIREMENTS

This SR verifies that adequate Chesapeake Bay level isavailable for the UHS Makeup Water pumps to provideemergency makeup water to the UHS cooling tower basinstarting 72 hours post design basis event. The specified levelalso ensures that sufficient NPSH is available to operate theUHS Makeup Water pumps starting 72 hour post design basisevent to a minimum of 30 days. The 24 hour frequency isbased on operating experience related to trending of theparameter variations during the applicable MODES.

SR 3.7.22.2

This SR verifies proper operation of the UHS Makeup Watertraveling screens and screen wash system on an actual orsimulated actuation signal. The UHS Makeup Water systemis normally in standby mode. The screen wash system mustprovide the necessary design flow rate to properly wash thetraveling screens, coincident with the UHS Makeup Waterpumps providing greater than or equal to 300 qpm emergencymakeup flow rate to the basin. The guarterly Frequency isbased on the need to perform this surveillance under theconditions that may impact the flow path to the UHS MakeupWater pumps. The quarterly Frequency is based on operatingexperience, the redundancy available, and the low probabilityof significant. degradation of the components occurringbetween surveillances. Therefore, the Frequency isacceptable from a reliability standpoint.

References 1. FSAR Section 9.2.5

2. FSAR Section 9.2.1

3. Regulatory Guide 1.27, Rev. 2, January 1976

Justification

The site specific information provided is consistent with the CCNPP Unit 3 FSARSection 9.2.5 description of the UHS Makeup Water System. The SR 3.7.22.1addresses the minimum Chesapeake Bay water level requirement in each UHSMakeup Water System pump forebay, to ensure that emergency makeup water canbe provided to the associated UHS cooling tower basin starting 72 hours post designbasis event. The SR 3.7.22.2 ensures the UHS Makeup Water traveling screens andscreen wash system are functional to provide a clear flow path of Chesapeake Baywater to the UHS Makeup Water pumps.)

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Enclosure 1UN#12-156Page 13 of 23

RAI No 336

Question 09.02.05-24

Follow-up to RAI 279 (eRAI 2618). Question 09.02.05-7

Original question:

According to Standard Review Plan (SRP) 9.2.5, the overall arrangement of the ultimate heatsink (UHS) and, in this case, the UHS makeup which is outside the scope of the U.S. EPRdesign certification needs to comply with GDC 44. The description of the UHS in CCNPP Unit 3Final Safety Analysis Report (FSAR) Section 9.2.5 and the drawing in FSAR Figure 9.2-3 areincomplete or inaccurate. Revise the FSAR to address the following considerations:

Part 3: FSAR Figure 9.2-3 does not show the location of indications (e.g., local, remotepanel, control room, remote shutdown panel), and does not identify the instruments thatprovide input to a process computer and/or have alarm and automatic actuation functions.Part 14: FSAR Section 9.2.5 does not specifically describe the ESW basin level controller(automatically or manually) when in normal makeup or safety related UHS makeup. Describethe types of valves which are used for controls (gates, globes, butterfly, etc.).

Follow-up questions:

For Item 3, the applicant has not adequately addressed this item related to instrumentation andcontrols (I&C). Some of the information is missing from the CCNPP Unit 3 FSAR or needs to beclarified. Specifically, the applicant should address the following items:

1. FSAR 9.2.5.7.1, missing strainer motor status, traveling screen motor and screenwash pump/motor status

2. FSAR 9.2.5.7.2, missing loss of heat tracing alarm3. For Table 9.2-2, verify that all of the I&C signals that trip the UHS makeup pumps

are from safety related signals (traveling screen forebay water level, and motorbearing)

For Item 14, the applicant has not fully addressed this item related to the basin level controls inthe CCNPP Unit 3 FSAR. The applicant should address this following:

1. The U.S. EPR FSAR Revision 3, Section 9.2.1.3.5 states that the ESWS emergencymakeup water isolation valve, 30PED10/20/30/40 AA021, is shut during normaloperations. Upon receipt of an SI signal, the valve opens automatically to establishthe flow path from the ESWS emergency makeup system to the tower basin. After 72hours have elapsed under DBA conditions, the emergency makeup water -systemisolation valves (modulate) the flow of emergency makeup water to the cooling towerbasins to maintain tower basin water levels within the established operating limits.

The applicant stated in their RAI response that AA021 is completely open after thesystem is full and did not address that AA021 may be already opened due to the SIsignal.

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Enclosure 1UN#12-156Page 14 of 23

Since the emergency makeup water isolation valve, 30PED10/20/30/40 AA021 getsan open signal on a SI, the filling of the system should be re-evaluated and clearlydescribed in the CCNPP Unit 3 FSAR related to the description in the U.S. EPRDesign Certification.

2. Provide a discussion of using the screen wash pumps for filling the UHS makeupsystem, that is, the initial fill of the UHS makeup system is not adequately describedin the FSAR. Also the initial fill line shown in Figure 9.2-3 is confusing with the textprovided for the markup for 9.2.5.3.2. The CCNPP Unit 3 FSAR should be corrected.

3. The markup for Section 9.2.5.3.2 is confusing since various valves are opened andclosed and it is unclear if these valves are manually opened, opened from the MCR,open locally from a control panel, or automatically opened. The CCNPP Unit 3 FSARshould be corrected.

Response

RAI 336 Q09.02.05-24, Item 3, identifies three I&C items to be addressed as follows:

1. FSAR 9.2.5.7.1, Pump Discharge Strainer Motor and Traveling Screen Motor Status andSystem Monitoring

FSAR Subsection 9.2.5.7.1, "System Monitoring," is updated as part of this response toinclude UHS Makeup Water pump discharge strainer motor status and UHS MakeupWater traveling screen motor status as monitored system parameters. As described inthe response to RAI 330 Q09.02.05-20 (separate submittal), the UHS Makeup Waterscreen wash pumps are removed from the design of the UHS Makeup Water System.The response to RAI 330 Question 09.02.05-20 provides further description of thedetails of the safety-related UHS Makeup Water screen wash system. CCNPP Unit 3COLA FSAR Subsection 9.2.5.7.1 is being updated to add the UHS Makeup WaterSystem monitored parameters.

2. FSAR 9.2.5.7.2, Missing Loss of Heat Tracing Alarm

FSAR Subsection 9.2.5.7.2, "System Alarms" is updated as part of this response toinclude the heat tracing alarm of the UHS Makeup Water System to the list of includedsystem alarms. This heat tracing of the UHS Makeup Water System is described in theResponse to RAI 330 Q09.02.05-20 and RAI 337 Question 14.02-58 (separatesubmittals). Heat tracing is provided on the traveling screen frame and/or UHS makeupwater bar screens as defense-in-depth to prevent the build-up of ice in the flow path tothe UHS Makeup Water pumps. CCNPP Unit 3 COLA FSAR Subsection 9.2.5.7.2 isbeing updated to add the UHS Makeup Water System alarms. Also, COLA FSAR Table9.2-2 is updated to show the addition of the associated alarm summary for heat tracing.

3. FSAR Table 9.2-2, Verify all of the I&C Signals that trip the UHS makeup pumps arefrom safety-related signals (traveling screen forebay water level, and motor bearing)

FSAR Table 9.2-2 describes the Instrumentation and Controls (I&C) signals that can tripthe UHS Makeup Water pumps. Instrumentation and controls associated with thesafety-related UHS Makeup Water system are designed as safety-related. Theseinclude all transmitters and distributed control system interfaces associated with thedisplay parameters listed in FSAR Table 9.2-2 that can trip the UHS Makeup Water

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Enclosure 1UN#12-156Page 15 of 23

pumps. The response to RAI 325 Q07.05-1 (separate submittal) describes updates tothe CCNPP Unit 3 FSAR Subsection 9.2.5.7 in regard to safety-related instrumentationand controls functions.

RAI 336 Q09.02.05-24, Item 14, identifies three basin level control issues that are addressed asfollows:

1. Operation of the ESWS emergency makeup water isolation valve

The ESWS emergency makeup water isolation valve 30PED10/20/30/40 AA021 isdescribed in the U.S. EPR FSAR as a motor operated valve that is normally closed andremains closed during normal operation of the plant. Upon receipt of a Safety Injectionsignal, the valve will open to establish the emergency UHS makeup water flow path tothe UHS cooling tower basin. As described in RAI 332 Q09.02.05-22 response(separate submittal), the UHS Makeup Water system is maintained in wet layup. Theresponse to RAI 325 Q07.05-1 (separate submittal) updated CCNPP Unit 3 FSARSubsection 9.2.5.3.2 to correct the automatic operation (open and close) of the ESWSemergency makeup water isolation valves, to remain open until the UHS cooling towerbasin is within the established operating levels. The ESWS emergency makeup waterisolation valve will modulate flow to the UHS cooling tower basin. From 72 hours post-DBA to 30 days post-DBA, the UHS cooling tower basin is replenished by the UHSMakeup Water System, if normal ESWS Makeup Water system is unavailable. Theresponse to RAI 325 Q07.05-1 also updated the CCNPP Unit 3 FSAR Subsection9.2.5.7, such that the ESWS emergency makeup water operation is consistent with theoperation described above.

2. UHS makeup water system initial fill

The UHS Makeup Water System piping is designed to be initially filled manually withbrackish Chesapeake Bay water, via the UHS Makeup Water pumps, in conjunction withslowly opening the isolation valves to reduce the effects of water hammer and high pointvents to remove trapped air from the piping. The response to RAI 330 Q09.02.05-20(separate submittal) describes the elimination of the UHS Makeup Water screen washpumps and the removal of the initial fill line off of the screen wash pumps discharge.The response to RAI 332 Q09.02.05-22 (separate submittal) describes the change to awet layup status of the UHS Makeup Water system and includes markups to FSARFigure 9.2-3 and Figure 9.2-9, which remove the screen wash pump and screen washpump initial-fill line from the system design.

3. FSAR Section 9.2.5.3.2 related to open and closing of motor operated valves

The CCNPP Unit 3 FSAR Subsection 9.2.5.3.2, "Piping, Valves, and Fittings" is updatedin the responses to RAI 325 Q07.05-1, RAI 330 Q09.02.05-20 and RAI 332 Q09.02.05-22 (separate submittal). UHS Makeup Water System motor operated valves (MOVs) arecontrolled automatically from the main control room (MCR) based on operator action tostart the associated UHS Makeup Water pump. 72 hours post-DBA, when the operatorinitiates the start of the UHS Makeup Water pumps, the UHS Makeup water systemMOVs open and close automatically as described in the response to RAI 325 Q07.05-1,to maintain the UHS cooling tower basin level within the established operating levels.

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Enclosure 1UN#12-156Page 16 of 23

COLA Impact

CCNPP Unit 3 COLA Part 2, FSAR, Sections 9.2.5.7.1 and 9.2.5.7.2, and FSAR Table 9.2-2have been updated as follows:

9.2.5.7.1 System Monitoring

+ UHS Makeup Water pump operating status (energized/de-energized)

* UHS Makeup Water discharge strainer operating status (energized/de-energized)+ UHS Makeup Water traveling screen operating status (energized/de-energized)

9.2.5.7.2 System Alarms

+ High bearing temperature of UHS Makeup Water pump

* Loss of UHS Makeup Water System heat tracing

Table 9.2-2- {UHS Makeup Water System Alarm Summary)

MCR/RSS Display Division Setpoint Name Function

... ... ... ...

UHS Makeup Water 1/2/3/4 Max 2 Max 2: Alarm and Pumppump abnormal (bearing Max 1 Triptemperature Hi) Max 1: AlarmUHS Makeup Water 1/2/3/4 Max 1 Max 1: Alarm (AlertsSystem Heat Tracing operator of equipmentFailure failure)

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Enclosure 1UN#12-156Page 17 of 23

RAI No 336

Question 09.02.05-25

Follow-up to RAI 279 (eRAI 2618). Question 09.02.05-14

Original question:

General Design Criteria (GDC) 45 requires the ultimate heat sink (UHS) and UHS makeupwater system to be designed so that periodic inspections of piping and components can beperformed to assure that the integrity and capability of the system will be maintained overtime. CCNPP Unit 3 FSAR Section 9.2.5.6 indicates that periodic inspections will beperformed, but does not describe the extent and nature of these inspections and theprocedural controls that will be implemented to assure that the UHS is adequately maintainedover time. The accessibility and periodic inspection of safety related buried piping and yardMOVs is of particular interest. Provide additional information in FSAR Section 9.2.5 todescribe the extent and nature of inspections that will be performed and the proceduralcontrols that will be implemented commensurate with the GDC 45 requirement. Also, confirmin the FSAR that the UHS makeup water system complies with GDC 45.

Follow-up questions:

The applicant responded to this original RAI question with the following text:

Related to GDC 45, the UHS makeup water system is a safety-related ASME Code Class 3system. This system has relatively 'small diameter' underground carbon steel piping that iscoated with 2-layer fusion bonded epoxy both on the exterior and interior surfaces.Additionally, exterior surfaces exposed to the soil shall be cathodically protected. Normally,the system piping is in dry layup.

Clarify in the CCNPP Unit 3 FSAR the meaning of "relatively small diameter". Typically,

small diameter piping is referred to a 2" and smaller and 2" diameter piping may notallow the required system flows.

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Enclosure 1UN#12-156Page 18 of 23

Response

In the response to RAI 279, Q09.02.05-14 1, regarding periodic inspections of piping andcomponents of the UHS Makeup Water System, the UHS Makeup Water system piping wasreferred to as "relatively small diameter" in terms of availability to perform internal visualinspections of the 8" nominal diameter buried piping from the UHS Makeup Water pumpdischarge piping to the ESW (UHS) Cooling Tower Basin. The ASME Section Xl Code visualexamination requirement is not practical for the 8" nominal diameter UHS makeup water buriedpiping, due to the difficulty of accessing the buried piping external surface and inside diameter incomparison to the larger UHS/CWS 60" pipes, which are accessible by divers.

Therefore, the term "relatively small diameter" of the piping diameter is in relation to the ability toperform visual examination of the inner diameter of the 8" pipe in comparison to larger pipingsizes, which are accessible to inspect via remote controlled cameras or by divers. The 8"nominal diameter piping is designed for the associated system flow requirements and isunchanged. The UHS piping material is super austenitic stainless steel rather than carbon steelpiping, coated with 2-layer fusion bonded epoxy, as stated in the responses to RAI 279Questions 09.02.05-172 and 09.02.05-14.

The verbiage "relatively small diameter" in the response to RAI 279, Q09.02.05-14 was notintended to refer to small bore diameter piping in term of nominal diameter piping of two inchesor less. A clarification of the meaning of "relatively small diameter" piping is therefore notincluded in the CCNPP Unit 3 FSAR.

COLA Impact

Revision to the CCNPP COLA FSAR is not required as a result of this response.

'UniStar Nuclear Energy Letter UN#1 1-173, Response to Request for Additional Information for the Calvert Cliffs Nuclear Power

Plant, Unit 3, RAI 279, Ultimate Heat Sink, dated June 3, 2011

2 UniStar Nuclear Energy Letter UN#1 1-213, Response to Request for Additional Information for the Calvert Cliffs Nuclear Power

Plant, Unit 3, RAI 279, Ultimate Heat Sink, dated July 29, 2011

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Enclosure 1UN#12-156Page 19 of 23

RAI No 336

Question 09.02.05-27

Follow-up to RAI 279 (eRAI 2618). Question 09.02.05-17

Original question:

According to Standard Review Plan (SRP) 9.2.5, the overall arrangement of the ultimate heatsink (UHS) needs to comply with GDC 44. The staff reviewed the inspection, tests, analysis,and acceptance criteria (ITAAC) information provided in the CCNPP Unit 3 application, Part 10,Table 2.4-9 and Table 2.4-24, to confirm completeness and consistency with the plant designbasis as described in CCNPP Unit 3 FSAR Section 9.2.5. The staff found that the ITAACinformation is incomplete, inconsistent, inaccurate, or that clarification is needed.

Follow-up question:

Justify the following items in the CCNPP Unit 3 application, Part 10 - ITAAC.

1. EPR FSAR, Tier 1, Section 2.7.11, Item 8.2 states that the site-specific emergencymakeup water system provides water to each ESW cooling tower basin at atemperature below the maximum ESWS supply temperature of 95 'F (35 °C).

2. EPR FSAR, Tier 1, Section 2.7.11, Item 8.4 states that the site-specific emergencymakeup water system provides a means to limit corrosion, scaling, and biologicalcontaminants in order to minimize component fouling for a minimum of 30 days post-DBA.

3. The semi-automatic fill of the UHS makeup water system is not specifically addressedunder Part 10 - ITAAC. An ITAAC should exists for the placing of the four trains ofUHS makeup water system from dry-layup to filled and vented, without theintroduction of a water hammer.

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Enclosure 1UN#12-156Page 20 of 23

Response

RAI 336 Q09.02.05-27 identifies three items as follows:

1. Site-specific emergency (UHS) makeup water system to provide water to each ESWCooling Tower Basin Below 950F (350C)

The U.S EPR FSAR, Tier 1, Section 2.7.11, Essential Service Water System, InterfaceRequirement 8.2, for the UHS Makeup Water System to supply makeup water to eachcooling basin at a temperature below the maximum ESWS supply temperature of 950F(35 °C), is justified by the historical data of the Unit 1 and 2 inlet area. Data compiledover the last 17 years show that the maximum Chesapeake Bay water temperaturerecorded to be 88.13°F (31.2 0C) at the Unit 1 and 2 inlet area. The Circulating WaterSystem (CWS) and UHS common forebay draws water from the Unit 3 inlet area wellbelow the minimum operating water level of -7.7 ft (-2.34 m), where the water is colderthan that at the surface of the Chesapeake Bay. The UHS Makeup Water systemprovides brackish makeup water to the UHS cooling tower basin starting 72-hours post-DBA at a minimum flow rate of 300 gpm and a maximum of 750 gpm, to maintain thebasin level within the established level. The UHS cooling tower basin volume is severalmillion gallons. Therefore, the UHS Makeup Water flow to the basin does not have asignificant impact to the cooling tower basin temperature and the maximum ESWSsupply temperature of 950F (35°C) during a DBA. The operating limits of the ESW arebased on conservative heat transfer analysis in the ESW heat exchanger for the worstcase DBA. An ITAAC item is added to CCNPP Unit 3 COLA ITAAC Table 2.4-22 toinclude UHS Makeup Water temperature to be below 950 F (350C).

2. Site-specific UHS Makeup Water System to provide a means to limit corrosion, scalingand biological contamination to minimize fouling for a minimum of 30 days post-DBA.

The U.S EPR FSAR, Tier 1, Section 2.7.11, Essential Service Water System, InterfaceRequirement 8.4, for the UHS Makeup Water System to provide a means to limitcorrosion, scaling and biological contamination to minimize fouling for a minimum of 30days post-DBA, is justified by using material of construction as super austenitic stainlesssteel and by quarterly flushing the piping system. The piping, valves, fittings, andcomponent materials of the UHS Makeup Water system are super austenitic stainlesssteel, an anti-corrosion piping material capable of withstanding the effects of silting,erosion, corrosion, and the presence of organisms that subject the system tomicrobiological influenced corrosion as well as well as macro fouling. UHS MakeupWater System piping is compatible with the Chesapeake Bay water chemistry. Thesefeatures eliminate the need of a UHS Makeup Water chemical treatment system duringstandby conditions. During the quarterly functional pump testing for flow and pressure,the entire UHS Makeup Water System piping system will be flushed through the testbypass line located in the ESW pump room.

3. Semi-Automatic Fill ITAAC of the UHS Makeup Water System from Dry Layup

The response to RAI 332 Q09.02.05-22 (separate submittal) changes the layup designof UHS Makeup Water System to wet layup. The piping system is maintained full ofwater during plant normal operation, shutdown/cooldown and DBA conditions to assuresystem readiness. The semi-automatic fill function has been removed from the design.

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Enclosure 1UN#12-156Page 21 of 23

Therefore, Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) to verify thesemi-automatic fill associated with a dry layup UHS Makeup Water System are notrequired. Each division of the UHS Makeup Water System is being updated to haveUHS Makeup Keep-Fill lines, as described in the response to RAI 332 Q09.02.05-22(separate submittal). The UHS Makeup Water System is always filled with ChesapeakeBay water and maintained full in a standby mode. The normal makeup water systemprovides makeup water to UHS Makeup Water System during plant normal operationand shutdown/cooldown condition to assure system readiness. The ESW system returnline will provide keep-fill makeup water to the UHS Makeup Water System during a DBAcondition to assure system readiness, when the normal makeup water system is notavailable. Furthermore, the existing ITAAC Table 2.4-22 Item 13 verifies the material ofthe UHS Makeup Water System as super austenitic steel, and ITAAC Table 2.4-22 Item21 verifies that the surveillance test bypass line is available to perform system testingand flushing. Therefore, no additional CCNPP Unit 3 Part 10 ITAAC is necessary toensure a means to limit corrosion, scaling and biological fouling.

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Enclosure 1UN#1 2-156Page 22 of 23

COLA Impact

CCNPP Unit 3 COLA Part 10, ITAAC Table 2.4.-22, has been modified as follows:

NOTE: Table 2.4-22 Items 23 and 24 were added in the response to RAI 332 Question09.02.05-221.

Table 2.4-22- {Ultimate Heat Sink Makeup Water System Inspections, Tests, Analyses,and Acceptance Criteria)

(Page 8 of 8)

Commitment Wording Inspection, Test, or Acceptance CriteriaAnalysis

22 a. Each UHS Makeup Water a. Tests will be a. Test reports exist andIntake Structure dual flow performed on each UHS conclude that upon atraveling screen is designed Makeup Water Intake simulated loss of motiveto be manually rotated, if Structure dual flow power or failure of its electricneeded, following a loss of traveling screen to verify motor drive, each UHSmotive power or failure of its it can be manually Makeup Water Intakeelectric motor drive, rotated upon a loss of Structure dual flow traveling

motive power or failure screen can be manuallyof its electric motor rotated.drive.

b. Each UHS Makeup Water b. Tests will be b. Test reports exist andIntake Structure dual flow performed on each UHS conclude that upon atraveling screen is designed Makeup Water Intake simulated loss of its screento be manually cleaned using Structure dual flow wash system, each UHSan external water source traveling screen to verify Makeup Water Intakefollowing a loss of its screen it can be manually Structure dual flow travelingwash system. cleaned using an screen can be manually

external water source cleaned using an externalfollowing a loss of its water source.screen wash system.

23 Each division of the UHS Tests of the as-built The as-built UHS MakeupMakeup Water System has a system will be Keep-Fill line for eachUHS Makeup Keep-Fill line conducted. division of the UHS Makeupas shown in Figure 2.4-3, that Water System, as shown inallows makeup water flow Figure 2.4-3, allows makeupfrom the normal makeup water flow from normalwater system to the UHS makeup system to the UHSMakeup Water System during Makeup Water Systemnormal plant operation. during normal plant

operation.

1 UniStar Nuclear Energy Letter UN#1 2-154, from Mark T. Finley to Document Control Desk, U.S. NRC, Responseto Request for Additional Information for the Calvert Cliffs Nuclear Power Plant, Unit 3, RAI 332, Ultimate HeatSink, dated December 20, 2012

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Enclosure 1UN#1 2-156Page 23 of 23

24 Each division of the UHSMakeup Water System has aPost-DBA UHS MakeupKeep-Fill line as shown inFigure 2.4-3, that allowsmakeup water flow from theESW System return line tothe UHS Makeup WaterSystem during post DBAplant operation.

Tests of the as-builtsystem will beconducted.

a. The as-built PostDBA UHS MakeupKeep-Fill line for eachdivision of the UHSMakeup WaterSystem, as shown inFigure 2.4-3, allowsmakeup water flowfrom ESW Systemreturn line to the UHSMakeup WaterSystem during postDRA n•lant oneration

I________________________ I I____________________ - - - -I- - M

b. A report exists andconcludes that, theflow restricting orificelisted in Table 2.4-29, restricts makeupflow within thespecified designvalue/system limit.

I- I- 4

25 Each division of the UHSMakeup Water System iscapable of suDDlvina makeuDwater to the associated UHScooling tower basin starting72 hours post DBA at atemperature less than orequal to the maximum ESWSdesign water temperature of950 F (350C).

Tests and analyses, ora combination of' testsand analyses, will beperformed todemonstrate that eachdivision of the UHSMakeup Water Systemis capable of supplyingmakeup water to theassociated UHS coolingtower basin starting 72hours post DBA,assuming the mostlimiting environmentalconditions, at atemperature less than orequal to the maximumESWS design watertemperature of 95TF(350C).

System is capable ofsupplying makeup water tothe associated UHS cooling

A report exists andconcludes that each divisionof the UHS Makeurp Water

tower basin starting 72 hourspost DBA, assuming themost limiting environmentalconditions, at a temperatureless than or equal to themaximum ESWS desianwater temperature of 95 0F(350 C).

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UN#12-156

Enclosure 2

Table of Changes to CCNPP Unit 3 COLAAssociated with the Responses to RAI No. 336,

Questions 09.02.05-23, 24, 25, and 27Calvert Cliffs Nuclear Power Plant, Unit 3

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Enclosure 3UN#12-156Page 2 of 2

Table of Changes to CCNPP Unit 3 COLA

Associated with the Responses to RAI No. 336

Change Subsection Type of Change Description of ChangeID# IIIPart 2 - FSAR12-0243 9.2.5.7.1, Incorporate COLA The response to RAI 336 Question

9.2.5.7.2, markups associated 09.02.05-24 adds information concerningTable 9.2-2 with the response to UHS Makeup Water System.

RAI 336 Question09.02.05-24.

Part 4 - Technical Specifications12-0243 LCO 3.7.22 Incorporate COLA The response to RAI 336 Question

markups associated 09.02.05-23 adds a Technical Specificationwith the response to concerning UHS Makeup Water System.RAI 336 Question09.02.05-23

Part 10 - Inspections, Tests, Analyses, and Acce ptance Criteria (ITAAC) and ITAAC Closure12-0243 Appendix B Incorporate COLA The response to RAI 336 Question

Table 2.4-22 markups associated 09.02.05-27 adds ITAAC concerning theItem 24 with the response to UHS Makeup Water System.

RAI 336 Question09.02.05-27