ML16266A086

License Amendment Request - Control Room Emergency Ventilation System

ML16266A086
Person / Time
Site:	Calvert Cliffs
Issue date:	09/22/2016
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML16266A086 (19)

Text

200 Exelon Way Exelon Generation Kennett Square. PA 19348 September 22, 2016 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 www.exeloncorp.com Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318 10 CFR 50.90

Subject:

License Amendment Request - Control Room Emergency Ventilation System In accordance with 10 CFR 50. 90, Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is submitting a request for amendment to the Technical Specifications (TS). Specifically, TS 3.3.8 "Control Room Recirculation Signal (CARS)," and TS 3.7.8 "Control Room Emergency Ventilation System (GREV)" are being changed.

There are no regulatory commitments contained in this letter. Exelon requests approval of the proposed license amendment by September 22, 2017, with the amendment being implemented within 60 days.

These proposed changes have been reviewed by the Plant Operations Review Committee.

In accordance with 10 CFR 50.91, "Notice for public comment; state consultation," a copy of this application, with attachments, is being provided to the designated State Official.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22"d day of September 2016.

If you should have any questions regarding this submittal, please contact Enrique Villar at 610-765-5736.

Respectfully, rvf ~ LJ I,L Jy----

David T. Gudger Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

License Amendment Request Control Room Emergency Ventilation System Docket Nos. 50-317 and 50-318 September 22, 2016 Page2 Attachments: 1. Evaluation of Proposed Change cc:

2. Marked-up Technical Specifications Page NRC Regional Administrator, Region I NRC Senior Resident Inspector, CCNPP NRC Project Manager, NRA, CCNPP S. T. Gray, State of Maryland w/attachments

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGE CONTROL ROOM EMERGENCY VENTILATION SYSTEM

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGE

Subject:

License Amendment Request - Control Room Emergency Ventilation System 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 1 of 8 1.0

SUMMARY

DESCRIPTION Pursuant to 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes a change to the Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2, Technical Specifications (TS) Appendix A of Renewed Facility Operating License Nos. DPR-53 and DPR-69.

The proposed license amendment to revise the TS as stated below would allow for the elimination of certain Control Room Emergency Ventilation (GREV) system components that no longer serve the purpose of establishing and isolating the control room boundary.

Technical Specifications 3.3.8 Exelon proposes to modify the TS 3.3.8 REQUIRED ACTION A.1 and C.1 as shown below.

CONDITION REQUIRED ACTION COMPLETION TIME A. CRRS trip circuit or Al Place one GsR~fBi Rssm 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> measurement channel

~m@r~@R@'I li'@R~iht~i8A inoperable in MODE S,1s~efR ~FEMR tR 1, 2, 3, or4.

resiret!!le~isA msEIB wi01:

tAe post-loss-of-coolant incident filter fan in service.

CONDITION REQUIRED ACTION COMPLETION TIME

c. CRRS trip circuit or C.1 Place one Gei;iti:el ~88FA 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> measurement channel lemer!!)eRe~ ~,,eRtiletieR inoperable during

~ystem treiR iA re1Sire1o1letiet=1 movement of irradiated meee witR post-loss-of -

fuel assemblies.

coolant incident filter fan in service.

The requirement to place the GREV System in the recirculation mode in Conditions A and C above are eliminated since the GREV system is now operated in recirculation mode at all times.

Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 2 of 8 Technical Specifications 3.7.8 Exelon proposes to modify the TS 3.7.8 ACTIONS as briefly described below.

CONDITION REQUIRED ACTION COMPLETION TIME A. Gee Sf mefe eh:1ets A.1 Giese the GPeRABbe l:mmeeiately with eee eatsiee aif eatsiee aif ietake :iral:ire ie ietake iselatiee :i.*ah*e eaeh a:ffeetee eaet ieepefable ia MODe l, ~.~.Sf 4.

Condition A will be eliminated in its entirety. The outside intake isolation valves no longer serve the purpose of isolating the control room from outside air. This function is now performed by the normally closed hatches, and the CREV system is operated in recirculation mode at all times.

Condition B will be retained and renumbered Condition A.

CONDITION REQUIRED ACTION COMPLETION TIME

c. QAs iimA81iiB~ ts C.l Restefe *,i:al:ire te 7 says 8~1fi88f!R8F8 issla~iBR OPBRABbe status.

21i1alii1e tRBflli!F881e iR MQQ~ I,~. s, BF 4..

Condition C will be eliminated in its entirety. The exhaust isolation valve no longer serves the purpose of isolating the control room from outside air. This function is now performed by the normally closed hatch, and the CREV system is operated in recirculation mode all the time.

Conditions D, E, F, G, H, and I will be retained and renumbered B, C, D, E, F, and G and when appropriate the text is modified to match the new numbering.

CONDITION REQUIRED ACTION COMPLETION TIME H. Two CREVS trains H.1 Suspend movement of Immediately inoperable for reasons irradiated fuel assemblies.

other than Condition A, B, G or D during movement of irradiated fuel assemblies.

GR Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 3 of 8 CONDITION REQUIRED ACTION Qi;ie 8F mere Cilwsts witt;i w~s swtsiea air iRtal~e isslati8R 1ii1al111es iR81i18F611ille ilwril'IS ms1i1emeF1t si iFF8iliate8 fwel essemlilliss QR Tws 8Jlloliiwst ts iitFAlSJ!)lol8F8 i8lliiti8FI

¥81¥88 iR81i18Fiilill8 awriFl!iJ FA8!iil8FF18Flt ef irFiiSi8t88 fwel 81iilii8mlillielii COMPLETION TIME Condition H above will also be modified as shown to eliminate the reference to intake and exhaust isolation valves since they no longer serve the purpose of isolating the control room from outside air. This function is now performed by the normally closed hatches, and the CREV system is operated in its recirculation mode all the time.

2.0 DETAILED DESCRIPTION

Background

The CREV system consi.sts of two redundant subsystems, each capable of maintaining the habitability of the Control Room Envelope (CRE). Each CREV system train is considered operable when the individual components necessary to limit operator exposure are operable within the given train. A CREV system train is considered operable when the associated:

Control Room Heating, Ventilation, and Air Conditioning (CRHVAC) Supply and Return fans are operable; Post Loss-of-Coolant Incident (LOCI) fan is operable; Post LOCI filter train is operable.

High Efficiency Particulate Air (HEPA) filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions; Ductwork, valves, and dampers are operable, and air circulation can be maintained; and CRE boundary is operable (the single boundary supports both subsystems).

The CCNPP CREV system has its inlet fresh air supplies, one for each train, and the common air exhaust isolated by leak tight hatches; therefore, the CCNPP CREV system is operated in full recirculation mode during normal and accident conditions. With the CREV system operating in the recirculation mode at all time, if a chemical, radiological, or smoke event occurred, the ventilation system would not require damper actuation or system realignment to establish the boundary and protect the operators in the CR.

Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 4 of 8 Therefore, this proposed license amendment to revise the TS as described in Section 1.0, and shown in Attachment 2 would allow for the elimination of certain CREV system components that no longer serve the purpose of establishing and isolating the CR boundary. The testing related to those components would be eliminated as well. CCNPP has been testing the actuation signals and the re-alignment of the original designed isolation dampers every 24 months to satisfy the current TS wording requirements even though the damper re-alignment no longer functions to isolate the CR environment from the outside atmosphere.

=

Background===

The CRE provides a protected environment from which operators can control the unit, during airborne challenges from radioactivity, hazardous chemicals, and fire byproducts, such as fire suppression agents and smoke, during both normal and accident conditions.

The CREV system is designed to maintain a habitable environment in the control room envelope for 30 days of continuous occupancy after a design-basis accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body.

The original design of the CREV system included outside air inlet goosenecks, one for each train, and their associated ductwork with isolation dampers (two dampers per train). The common return air exhaust outlet also included a gooseneck and discharged to the outside atmosphere through two discharge isolation dampers. As originally designed, the CREV system operated drawing air from the outside atmosphere and discharging it to the outside atmosphere.

In this (original) configuration, if a chemical, radiological, or smoke event occurs, the ventilation system would be realigned to a full recirculation mode of operation by closing the air inlet isolation dampers, one for each train, and the exhaust air outlet isolation dampers. In the recirculation mode of operation, the CREV system isolated unfiltered ventilation air supply intakes; isolated unfiltered exhaust-to-atmosphere dampers, and aligned the system for emergency recirculation of a portion of the CRE air through the HEPA and charcoal filters. The Post-Loss-of-Coolant Incident (LOCI) filters process 10,000 CFM of CRE air continuously in this mode per train. Only one train is required to operate to satisfy the safety analyses.

In 1999, the CREV system was modified to add leak tight hatches that cover the outside intake and exhaust openings. The dampers were left in place, but no longer form the boundary of the CR HVAC. The installation of the hatches altered the CR HVAC system envelope, and resulted in the CREV system operating in a full recirculation mode during normal and accident conditions. With the CREV system operating in the recirculation mode at all time, if a chemical, radiological, or smoke event occurred, the ventilation system would not require damper actuation or system realignment to establish the boundary and protect the operators in the CR.

The Post LOCI filters are located within the CRE and do not affect system isolation. The Post LOCI filters continue to operate as they were originally designed.

The design of the leak tight hatches consists of steel plate, knife edge, elastomer seal, are bolted in place. These hatches are also subject to a Preventive Maintenance (PM) program in accordance with procedure EN-1-123 "Control Room Habitability Program."

Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 5 of 8 In-leakage testing has been successfully performed per TS Surveillance Requirement (SR) 3.7.8.4 every six (6) years in accordance with Regulatory Guide 1.197 as required by Technical Specification 5.5.17. c. Additionally, the hatches were last inspected in December 2012 with satisfactory results, thus providing assurance that the hatches are appropriately leak tight.

Furthermore, the leak tight hatches form part of the CR boundary and, as such, are controlled by TS 3.7.8; thus removal of these hatches requires that Condition 3.7.8.D be entered for an inoperable GREV system boundary. Condition 3.7.8.D will remain unchanged, but re-numbered 3.7.8.B upon approval of this license amendment request.

This proposed change to the TS 3.3.8 and 3.7.8, as mentioned above, to:

1. Delete Required Actions that require the CR HVAC system be placed into recirculation mode, and

2. Remove the Required Actions related to realigning the dampers will bring consistency between the TS and the actual configuration and operation of the GREV system because:

1. The GREV system is always operated in full recirculation mode, and

2. Damper realignment to isolate penetrations sealed by leak tight hatches is unnecessary.

Therefore, we are requesting approval of this amendment request.

Furthermore, the change in the CR boundary (present system configuration) was used when calculating the doses to the CR operators. This calculation was submitted to the NRG as part of the Alternate Source Term License Amendment Request (Reference 1 ). The NRG approved the Alternate Source Term License Amendment Request in Reference 2.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine compliance with applicable regulatory requirements.

General Design Criterion (GDC) 19 requires that holders of an operating license using alternate source term under 1 O CFR 50.67 shall meet the requirements of the criterion by ensuring the radiation exposures to CR occupants shall not exceed five (5) Rem TEDE dose. The analysis performed to determine CR operator dose following an accident assumed no ventilation flow through the inlet and exhaust dampers in the CREVS. The installed, locked closed, leak tight hatches provide this same level of protection from the outside environment. Therefore, the requirements of GDC 19 continue to be met.

Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 6 of 8 1 O CFR 50.36(c)(2)(ii) provides the criteria for establishing the limiting condition for operation of items in the TS. The TS Bases describe which of the four (4) criteria the GREV system meets for inclusion in the TS. The TS Bases identify Criterion 3 as the applicable criterion from 1 O CFR 50.36. Criterion 3 requires inclusion of equipment that is part of the primary success path and which functions to mitigate a design basis accident. The proposed change complies with Criterion 3 because removal of equipment that does not perform a post-accident function still meets the Criterion. The hatches are not required to be added as specific components to the TSs because they are already a part of the CR habitability boundary and are addressed as part of the existing TS.

4.2 Precedence None 4.3 No Significant Hazards Consideration The proposed license amendment to revise the Technical Specifications (TS) as stated below would allow for the elimination of certain Control Room Emergency Ventilation (GREV) system components that no longer serve the purpose of establishing and isolating the control room boundary. The testing related to those components would be eliminated as well. Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 1 O CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The proposed amendment eliminates certain GREV system components from the Technical Specifications that no longer serve the purpose of establishing and isolating the Control Room (CR) boundary. The testing related to those components would be eliminated as well.

The GREV system and its components are not an accident initiator. The GREV system and its components required to be operable and capable of performing any mitigation function assumed in the accident analysis continue to be operated and tested in accordance with the applicable TS requirements.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 7 of 8 The proposed amendment eliminates certain GREV system components that no longer serve the purpose of establishing and isolating the Control Room boundary.

The proposed amendment does not impose any new or different requirements. The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed amendment eliminates certain GREV system components that no longer serve the purpose of establishing and isolating the CR boundary. The testing related to those components would be eliminated as well.

The proposed amendment does not affect the design, operation, testing methods, and acceptance criteria for systems, structures, and components (SSCs), specified in applicable codes and standards (or alternatives approved for use by the NRG). The elimination of components that no longer serve the original purpose of establishing the CR envelope and isolating the control room from the outside atmosphere by placing the GREV system in full recirculation mode improves the overall mitigating capabilities of the system by eliminating the consequences of any potential failure of a component to re-align. The GREV system will continue to meet all of its requirements as described in the plant licensing basis (including the Final Safety Analysis Report and TS Bases).

Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 O CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve: (i) a significant Evaluation Of Proposed Change Control Room Emergency Ventilation System Page 8 of 8 hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 1 O CFR 51.22(c)(9). Therefore, pursuant to 1 O CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Letter from Bruce S. Montgomery (CCNPP) to Document Control Desk "Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request: Revision to Accident Source Term and Associated technical Specifications," dated November 3, 2005.

2. Letter from Douglas V. Pickett (NRC) to James A. Spina (CCNPP) "Calvert Cliffs Nuclear Power Plant, Units Nos. 1 and 2 - Amendment RE: Implementation of Alternative Radiological Source Term (TAC Nos. MC8845 and MC8846)," dated August 29, 2007

ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATIONS PAGES CONTROL ROOM EMERGENCY VENTILATION SYSTEM

. 3.3 INSTRUMENTATION 3.3.8 Control Room Recirculation Signal (CRRS)

CRRS 3.3.8 LCO 3.3.8 One CRRS ~rip circuit and measurement channel shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies.

ACTIONS CONDITION A.

CRRS trip circuit or measurement channel inoperable ~n MODE 1, 2, 3, or 4.

8.

Required Action and associated Completion Time of Condition A not met.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 A.l 8.1 AND 8.2 REQUIRED ACTION Place one Control Ropm Emergency Ventilation System train in recirculation mode with the post-loss-of-coolant incident filter fan in service.

Be in MODE 3.

Be in MODE 5.

3.3.8-1 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 6 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Amendment No. 227 Amendment No. 201

ACTIONS (continued)

CONDITION C.

CRRS trip circuit or C.l measurement channel inoperable during movement of irradiated fuel assemblies.

C.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIRED ACTION Place one Control Room Emergency Ventilation System train in recirculation mode with post-loss-of-coolant incident filter fan in service.

Suspend movement of irradiated fuel assemblies.

CRRS 3.3.8 COMP LET ION TIME Immediately Imrediately FREQUENCY SR 3.3.8.l Perform a CHANNEL CHECK on the control room In accordance SR 3.3.8.2 radiation monitor channel.

with the Surveillance Frequency Control Program Perform a CHANNEL FUNCTIONAL TEST on the CRRS radiation monitor trip circuit and measurement channel.

Verify CRRS high radiation setpoint is less than or equal to the Allowable Value of 6E4 cpm above normal background.

In accordance with the Surveillance Frequency Control Program CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.3.8-2 Amendment No. 314 Amendment No. 292

3.7 PLANT SYSTEMS

• 3.7.8 Control Room Emergency Ventilation System (CREVS)

LCO 3.7.8 Two CREVS trains shall be OPERABLE.

CREVS 3.7.8

• ----------~-------------------------NOTES------------------------------------

Only o_ne CREVS redundant component is required to be OPERABLE during movement of irradiated fuel assemblies when both Units are in MODE 5 or 6, or defuel ed.

2.

Only one CREVS train is required to be OPERABLE for the movement of irradiated fue 1 as_semb l i es.

3.

The control room envelope (CRE)* boundary may be opened intermittently under administrative control.

APPLICABILITY:*

MODES 1, 2, 3, 4; During movement of irradiated fuel assemblies.

ACTIONS CONDITION A.

One or more ducts with one outside air intake isolation valve inoperable in MODE 1, 2, 3, or 4.

B.

Toil et area exhaust isolation valve inoperable.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 REQUIRED ACTION A.1 Close the OPERABLE outside air intake valve in each affected duct.

B.1 Restore valve to OPERABLE status.

3.7.8-1 COMPLETION TIME Iinmediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Amendment No. 287 Amendment No. 264 A

A.1

ACTIONS (continued)

CONDITION C.

One exhaust to C.1 atmosphere isolation valve inoperable in MODE 1~ 2, 3, or 4.

D.

One or.more CREVS D.1 trains inoperab1e due to inoperable CRE boundary. in MODE 1, 2,.3, or 4.

. AND D.2 AND D.3 E.

.One.CREvs-train E.1

.i noperab 1 e for reasons other than c*ond.ition A, B, C, or D in MODE 1, 2, 3, or

4.

CALVERT *CLIFFS

~ UNIT 1 CALVERT CLIFFS - UNIT 2 REQUIRED ACTION Restore valve to OPERABLE.status.

Initiate action to tmplement mitigating actions.

Verify mitigating actions ensure CRE occupant exposures to radiological, che~ical, and smoke hazards will not exceed limits.

Restore CRE boundary to OPERABLE status.

Restore CREVS train to OPERABLE status.

3.7.8-2 CREVS 3.7.8 COMPLETION TIME 7 days Immediately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days 7 days Amendment No. 287 Amendment No. 264 B

B.1 B.2 B.3 C.

C.1 or

ACTIONS (continued)

CONDITION F.

---

NOTE --------

Not applicable when second CREVS train intentionally made inoperable.

Two CREVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition D.

G.

Required Action and associated Completion Time of Condition B not met during movement of irradiated fuel assemblies.

OR One or more CREVS trains inoperable due to an inoperable CRE boundary during movement of irradiated fuel assemblies.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 REQUIRED ACTION F.1 Initiate action to implement mitigating actions.

AND F.2 Verify LCO 3.4.15, 11RCS Specific

Activity, 11 is met.

AND F.3 Restore at least one CREVS train to OPERABLE status.

G.1 Suspend movement of irradiated fuel assemblies.

3.7.8-3 CREVS 3.7.8 COMPLETION TIME IITITlediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 24 hours Immediately Amendment No. 309 Amendment No. 287 D.

D.1 D.2 D.3 E.

E.1 B

A

ACTIONS (continued)

CONDITION H.

Two CREVS trains inoperable for reasons other than Condition A, B, C, or D during movement of irradiated fuel assemblies.

OR One or more ducts with two outside air intake isolation valves inoperable during movement of irradiated fuel assemblies.

OR Two exhaust to atmosphere isolation valves inoperable during movement of irradiated fuel assemblies.

I.

Required Action and associated Completion Time of Condition A, B, C, D, E, or F not met in MODE 1, 2, 3, or 4.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 REQUIRED ACTION H.1 Suspend movement of irradiated fuel assemblies.

1.1 Be in MODE 3.

AND 1.2 Be in MODE 5.

3.7.8-4 CREVS 3.7.8 COMPLETION TIME Immediately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Amendment No. 309 Amendment No. 287 F.1 F.

G.

G.1 G.2 or or