ML022210229
| ML022210229 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/06/2002 |
| From: | Katz P Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML022210229 (13) | |
Text
Peter E. Katz 1650 Calvert Cliffs Parkway Vice President Lusby, Maryland 20657 Calvert Cliffs Nuclear Power Plant 410 495-4455 Constellation Generation Group, LLC 410 495-3500 Fax 0 Constellation Energy Group August 6, 2002 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request: Revisions to the Refueling Operations Section of the Technical Specifications
REFERENCES:
(a) NUREG-1432, Revision 2, Combustion Engineering Improved Standard Technical Specifications, April 2001 (b) Industry/TSTF Standard Technical Specification Change Traveler TSTF-312, Administratively Control Containment Penetrations, Revision 1 (c) Industry/TSTF Standard Technical Specification Change Traveler TSTF-197, Require Containment Closure when Shutdown Cooling Requirements are not met, Revision 2 Pursuant to 10 CFR 50.90, Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP) hereby requests an amendment to Renewed Operating License Nos. DPR-53 and DPR-69 to incorporate the changes described below into the Technical Specifications for Calvert Cliffs Unit Nos. 1 and 2.
DESCRIPTION The proposed amendment revises Technical Specification 3.9, Refueling Operations to incorporate two changes previously approved for the Improved Standard Technical Specifications (ISTS). These changes are reflected in Revision 2 of NUREG-1432 (Reference a). Each proposed change is described below.
Marked up Technical Specification pages are contained in Attachment (1). Changes to the Technical Specification Bases consistent with the Technical Specification Task Force (TSTF)-312 and TSTF-197 (References b and c) will be made once this request is approved.
Change 1 - Refueling Operations 3.9.3 Containment Penetrations Technical Specification 3.9.3, Containment Penetrations, specifies the status of each type of containment penetration during core alterations and fuel handling within Containment. Technical Specification 3.9.3.d requires penetrations providing direct access from the containment atmosphere to the outside atmosphere
'9
Document Control Desk August 6, 2002 Page 2 to be closed by a manual or automatic isolation valve, blind flange, or equivalent capable of being closed by an operable containment purge valve isolation system. In accordance with TSTF-312 (Reference b),
CCNPP is proposing to add a note under Limiting Condition for Operation (LCO) 3.9.3 allowing penetration flow path(s) that have direct access from the containment atmosphere to the outside atmosphere to be unisolated under administrative control. Limiting Condition for Operation 3.6.3, Containment Isolation Valves, ACTION Note 1 allows containment isolation valves to be opened in Modes 1 through 4 under administrative control. In this condition, the accident analyses credit the Containment as a barrier. In the lower energy conditions of LCO 3.9.3, opening containment isolation valves under administrative control is less risk significant. Therefore, this change is proposed to provide a consistent approach to containment boundary issues that utilizes previously approved acceptable compensatory measures.
The current analysis for the fuel handling incident presented to the Calvert Cliffs Updated Final Safety Analysis Report Section 14.18, "Fuel Handling Incident," assumes that the personnel air lock is open for the duration of the incident and one volume of containment atmosphere containing activity is released from Containment unfiltered. The analysis results are maximum offsite doses of 14.06 rem to the thyroid, and 0.457 rem to the whole body, which are within the Standard Review Plan 15.7.4, Revision 1, guidelines of 75 rem to the thyroid and 6 rem to the whole body (25% of the 10 CFR Part 100 limits).
Since the analysis assumes the radioactive release is unfiltered, the analysis will also apply to the containment penetration flow paths that are opened under administrative control. Actual offsite doses in the event of a fuel handling incident will be less because containment closure will be established. In a similar manner, allowing containment penetration flow paths to be opened under administrative control does not negatively impact the dose exposure of the Control Room operators following a fuel handling incident.
Change 2 - Change to Technical Specifications 3.9.4 and 3.9.5 Technical Specifications 3.9.4, Shutdown Cooling (SDC) and Coolant Circulation - High Water Level and 3.9.5, Shutdown Cooling (SDC) and Coolant Circulation - Low Water Level requires when the LCO requirements are not met to "Close all containment penetrations providing direct access from the containment atmosphere to outside atmosphere." This requirement is vague and, in some cases, overly restrictive.
In accordance with TSTF-197 (Reference c), CCNPP is proposing to replace the SDC requirement "Close all containment penetrations providing direct access from containment atmosphere to outside atmosphere" with a requirement to:
a) either close the equipment hatch and secure with a minimum of four bolts or close the containment outage door, and; b) close one door in each air lock; and c) either close each penetration providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent, or verify the penetration is capable of being closed by an operable containment purge valve isolation system.
The safety function of containment closure in the case of a loss of SDC is twofold: 1) the time required to close the Containment to prevent a radioactive release to the atmosphere outside Containment if SDC is
Document Control Desk August 6, 2002 Page 3 lost; and 2) the ability to retain the pressure generated by boiling of reactor coolant as result of a loss of SDC.
Currently, the Technical Specifications are vague and overly restrictive concerning the requirement for containment closure when SDC is lost. The proposed change eliminates unclear requirements and provides a clear way to establish containment closure that meets the Bases description for the Action, which is to prevent fission products from being released from the Containment during a loss of SDC incident. The containment purge isolation valves close rapidly on a high radiation signal or are closed by remote manual control. All required penetration closure devices can withstand the maximum calculated pressure that can develop in the Containment for the limiting loss for SDC.
Establishing containment closure meets the Bases description for the Action, which is to prevent fission products from being released from the Containment during a loss of SDC incident. Containment closure is a well understood and controlled condition that is used routinely during a refueling outage. Utilizing containment closure instead of the current special actions gives a greater confidence that the Containment will be in the appropriate state.
Therefore, the analysis assumptions and Bases assumptions for the Actions are preserved while eliminating an unclear requirement, lessening the administrative burden on the plant, and increasing confidence that the Containment will be in the proper status should an event occur.
DETERMINATION OF SIGNIFICANT HAZARDS The proposed amendment revises the Unit Nos. I and 2 Technical Specification Refueling Operations Section to incorporate two changes previously approved for the Improved Standard Technical Specifications. These changes are reflected in NUREG-1432, Revision 2. Specifically, the proposed changes will allow penetration flow paths that have direct access from the containment atmosphere to the outside atmosphere to be unisolated under administrative control. Also, the proposed changes clarify containment closure requirements and allow containment purge valves to remain open provided the containment purge isolation system is operable when shutdown cooling (SDC) requirements are not met.
These proposed changes have been evaluated against the standards in 10 CFR 50.92 and have been determined to not involve a significant hazards consideration, in that operation of the facility in accordance with the proposed amendments:
- 1. Would not involve a significant increase in the probability or consequences of an accidentpreviously evaluated.
Closing the containment penetrations is considered to be a mitigator of the radiological consequences of a fuel handling incident and a loss of SDC, not an initiator. Therefore, allowing containment penetration flow paths to be unisolated and the containment purge valves to be opened during these outage activities does not involve a significant increase in the probability of an accident previously evaluated.
The consequence of a fuel handling incident is the release of radioactivity from Containment. The impact of the proposed change to the calculated offsite dose resulting from a fuel handling incident has been evaluated and determined to be acceptable. The fuel handling incident analysis assumes no containment closure. The amount of radioactivity that could be released as a result of the proposed change is bounded by the current analysis of record. Therefore, having containment penetration flow
Document Control Desk August 6, 2002 Page 4 paths unisolated during core alterations and fuel handling does not involve an increase in the consequences of an accident previously evaluated.
The consequence of a loss of SDC is the potential for release of radioactivity to the atmosphere outside Containment. Closing containment penetrations is a mitigator of that consequence.
Administrative controls will be put in place to ensure that in an emergency containment closure can be quickly achieved. The containment purge system isolation valves are closed automatically on a containment high radiation signal and can be shut by remote manual operation. Therefore, the proposed changes do not involve a significant increase in the consequences of a loss of SDC.
Therefore, the proposed Technical Specification changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Would not create the possibility of a new or different type of accidentfrom any accidentpreviously evaluated This requested change does not involve a significant change in the operation of the plant and no new accident initiation mechanism is created by the proposed changes. Closing containment penetrations is considered to be a mitigator of the radiological consequences of any accident in the Containment, not an initiator. The containment penetration flow paths are currently opened and closed during the course of an outage. The proposed changes allow them to remain open during a period when they are currently required to be closed.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Would not involve a significantreduction in a margin of safety.
The margin of safety for containment closure during core alternation/fuel handling is based on the amount of offsite dose resulting from a fuel handling incident. An offsite dose calculation previously approved by the Nuclear Regulatory Commission for a fuel handling incident assumes no containment closure, and any activity released from the Containment is unfiltered. The analysis will apply to the containment penetration flow paths that could be opened under administrative controls and therefore, does not involve a significant reduction in the margin of safety.
The margin of safety for containment closure in the case of loss of SDC is twofold: 1) the time required to close the Containment to prevent a radioactive release to the atmosphere outside Containment if SDC is lost; and 2) the ability to retain the pressure generated by boiling of reactor coolant as a result of a loss of SDC.
Currently the Technical Specifications are vague and overly restrictive concerning the requirement for containment closure when SDC is lost. The proposed change eliminates unclear requirements and provides a clear way to establish containment closure that meets the Bases description for the Action, which is to prevent fission products from being released from the Containment during a loss of SDC incident. The containment purge isolation valves close rapidly on a high radiation signal or are closed by remote manual operation. The proposed changes do not increase the possibility of a release of radiation following a loss of SDC incident
Document Control Desk August 6, 2002 Page 5 Therefore, the ability to provide containment closure is maintained and the margin of safety is not significantly reduces by this proposed activity.
ENVIRONMENTAL ASSESSMENT We have determined that operation with the proposed amendments will not result in any significant change in the types or significant increases in the amounts of any effluents that may be released offsite, and no significant increases in individual or cumulative occupational radiation exposure. Therefore, the proposed amendments are eligible for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact assessment is needed in connection with the approval of the proposed amendments.
SAFETY COMMITTEE REVIEW The Plant Operations and Safety Review Committee and the Offsite Safety Review Committee have reviewed these proposed amendments and concur that operation with the proposed amendments will not result in an undue risk to the health and safety of the public.
SCHEDULE The proposed changes make the requirements for containment penetrations during refueling operations consistent throughout Technical Specifications. The 2003 Unit 2 Refueling Outage is currently scheduled to begin mid February 2003. Therefore, we request approval of the proposed changes by February 1, 2003.
PRECEDENT The changes have been approved by the Nuclear Regulatory Commission for incorporation in the ISTS and are incorporated in NUREG-1432, Revision 2. Plants converting to the ISTS under Revision 2 of the NUREG could adopt these changes. In addition, a number of plants have submitted and/or received approval for these changes as individual items.
TSTF-312 Ft. Calhoun - Approved March 26, 2002 DC Cook - Approved November 21, 2001 Shearon Harris - Approved July 30, 2001 Callaway - Approved September 26, 2000 Wolf Creek - Approved September 12, 2000 Comanche Peak - Approved September 5, 2000 Watts Bar - Approved August 24, 2000
Document Control Desk August 6, 2002 Page 6 Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yot
-72 ztý-- /V STATE OF MARYLAND
- TO WIT:
COUNTY OF CALVERT I, Peter E. Katz, being duly sworn, state that I am Vice President - Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP), and that I am duly authorized to execute and file this License Amendment Request on behalf of CCNPP. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other CCNPP employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it t be reliable.
Su d and sworn before me, a Notary Public in and for the State of Maryland and County of jAUay of /zthis 2002.
WITNESS my Hand and Notarial Seal: Ia&WtAL Notary Public My Commission Expires: OX /01 /06t Date PEK/DJM/bj d
Attachment:
(1) Marked up Technical Specification Pages cc: R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate I-1, NRC R. I. McLean, DNR D. M. Skay, NRC
ATTACHMENT (1)
MARKED UP TECHNICAL SPECIFICATION PAGES 3.9.3-1 3.9.4-2 3.9.5-2 Calvert Cliffs Nuclear Power Plant, Inc.
August 6, 2002
Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:
- a. 1. The equipment hatch closed and held in place by a minimum of four bolts, or
- 2. The containment outage door is capable of being closed under administrative control;
- b. One door in the emergency air lock is closed;
NOTE -- ------------------
The emergency air lock temporary closure device can be used in place of an emergency air lock door.
- c. The personnel air lock shall be either:
- 1. closed by one personnel air lock door, or
- 2. capable of being closed by an OPERABLE personnel air lock door under administrative control.
- d. Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:
- 1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or
- 2. capable of being closed by an OPERABLE Containment Purge Valve Isolation System.
APPLICABILITY: During CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.
CALVERT CLIFFS UN I1U2I
~1 3.9.3-1 Amendment No. 242 Amendment No. 216 CALVERT CLIFFS - UN II
Insert 1
-------- NO T E -------------------------------------
Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.
SDC and Coolant Circulation-High Water Level 3.9.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required SDC loop A.1 Initiate action to Immediately inoperable or not in restore SDC loop to operation. OPERABLE status and operation.
AND A.2 Suspend operations Immediately involving a reduction in reactor coolant boron concentration.
AND A.3 Suspend loading of Immedi ately irradiated fuel assemblies in the core.
AND prnvidig dirt access from atmosehere to outside 1
CALVERT CLIFFS - UNIT 1 3.9.4-2 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201
Insert 2 A.4.1 Close equipment hatch and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> secure with a minimum of four bolts, OR A.4.2 Close the containment outage door.
AND A.5 Close one door in each air 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> lock.
AND A.6.1 Close each penetration 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.
OR A.6.2 Verify each penetration is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> capable of being closed by an OPERABLE Containment Purge Valve Isolation System.
SDC and Coolant Circulation-Low Water Level 3.9.5 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. No SDC loop OPERABLE B.1 Suspend operations Immediately or in operation. involving a reduction in reactor coolant boron concentration.
AND B.2 Initiate action to Immediately restore one SDC loop to OPERABLE status and to operation.
AND ra 'C4 ýrIý". .1 *I contai nment pe~etr, a. ,
provIidig direet cant'a i meart
(
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify required SDC loops are OPERABLE and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> one SDC loop is in operation.
SR 3.9.5.2 Verify SDC loop in operation is circulating 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> reactor coolant at a flow rate of
> 1500 gpm.
CALVERT CLIFFS - UNIT 1 3.9.5-2 Amendment No. 227 CALVERT CLIFFS - UNIT 2 Amendment No. 201
Insert 3 B.3.1 Close equipment hatch and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> secure with a minimum of four bolts, OR B.3.2 Close the containment outage door.
AND B.4 Close one door in each air 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> lock.
AND B.5.1 Close each penetration 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.
OR B.5.2 Verify each penetration is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> capable of being closed by an OPERABLE Containment Purge Valve Isolation System.