ML040760287

License Amendment, Change Technical Specification to Modify Requirements Applicable When Action Requires No Positive Reactivity Additions

ML040760287
Person / Time
Site:	Calvert Cliffs
Issue date:	05/06/2004
From:	Vissing G NRC/NRR/DLPM/LPD1
To:	Vanderheyden G Calvert Cliffs
Vissing G, NRR/DLPM, 415-1441
References
TAC MC8478, TAC MC8479
Download: ML040760287 (19)

Text

May 6, 2004 Mr. George Vanderheyden, Vice President Calvert Cliffs Nuclear Power Plant, Inc.

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

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 AMENDMENT RE: TECHNICAL SPECIFICATION CHANGES TO MODIFY REQUIREMENTS RELATED TO POSITIVE REACTIVITY ADDITIONS (TAC NOS. MB8478 AND MB8479)

Dear Mr. Vanderheyden:

The Commission has issued the enclosed Amendment No. 266 to Renewed Facility Operating License No. DPR-53 and Amendment No. 243 to Renewed Facility Operating License No. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated April 17, 2003, as supplemented July 29, 2003.

These amendments revise the Required Actions requiring suspension of operations involving positive reactivity additions and various notes that preclude reduction in boron concentration.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commissions next regular biweekly Federal Register notice.

Sincerely,

/RA/

Guy S. Vissing, Senior Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosures:

1. Amendment No. 266 to DPR-53

2. Amendment No. 243 to DPR-69

3. Safety Evaluation cc w/encls: See next page

May 6, 2004 Mr. George Vanderheyden, Vice President Calvert Cliffs Nuclear Power Plant, Inc.

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

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 AMENDMENT RE: TECHNICAL SPECIFICATION CHANGES TO MODIFY REQUIREMENTS RELATED TO POSITIVE REACTIVITY ADDITIONS (TAC NOS. MB8478 AND MB8479)

Dear Mr. Vanderheyden:

The Commission has issued the enclosed Amendment No. 266 to Renewed Facility Operating License No. DPR-53 and Amendment No. 243 to Renewed Facility Operating License No. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated April 17, 2003, as supplemented July 29, 2003.

These amendments revise the Required Actions requiring suspension of operations involving positive reactivity additions and various notes that preclude reduction in boron concentration.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commissions next regular biweekly Federal Register notice.

Sincerely,

/RA/

Guy S. Vissing, Senior Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosures:

1. Amendment No. 266 To DPR-53

2. Amendment No. 243 To DPR-69

3. Safety Evaluation cc w/encls: See next page ADAMS Accession Numbers: Letter - ML040760287; TSs - ML  ;

Package - ML040760306

• Safety evaluation provided - no significant changes made

• • See previous concurrence OFFICE PDI-1/PM PDI-1/LA IROB* OGC** PDI-1/SC NAME GVissing SLittle TBoyce SLewis RLaufer DATE 5/3/04 5/3/04 2/27/2004 4/21/04 5/4/04 OFFICIAL RECORD COPY

DATED: May 6, 2004 AMENDMENT NO. 266 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 CALVERT CLIFFS UNIT 1 AMENDMENT NO. 243 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 CALVERT CLIFFS UNIT 2 PUBLIC PDI-1 R/F RLaufer SLittle GVissing OGC GHill (2)

TBoyce WBeckner ACRS KKavanagh CBixler, RI cc: Plant Service list

Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:

President Patricia T. Birnie, Esquire Calvert County Board of Co-Director Commissioners Maryland Safe Energy Coalition 175 Main Street P.O. Box 33111 Prince Frederick, MD 20678 Baltimore, MD 21218 James M. Petro, Esquire Mr. Loren F. Donatell Counsel NRC Technical Training Center Constellation Energy Group, Inc. 5700 Brainerd Road 750 East Pratt Street, 5th floor Chattanooga, TN 37411-4017 Baltimore, MD 21202 Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge 2300 N Street, NW Washington, DC 20037 Mark Geckle Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. Richard I. McLean, Manager Nuclear Programs Power Plant Research Program Maryland Dept. of Natural Resources Tawes State Office Building, B3 Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Kristen A. Burger, Esquire Maryland Peoples Counsel 6 St. Paul Centre Suite 2102 Baltimore, MD 21202-1631

CALVERT CLIFFS NUCLEAR POWER PLANT, INC.

DOCKET NO. 50-317 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 266 Renewed License No. DPR-53

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Calvert Cliffs Nuclear Power Plant, Inc. (the licensee) dated April 17, 2003, as supplemented July 29, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2. of Renewed Facility Operating License No. DPR-53 is hereby amended to read as follows:

2. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 266, are hereby incorporated into the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 6, 2004

CALVERT CLIFFS NUCLEAR POWER PLANT, INC.

DOCKET NO. 50-318 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 243 Renewed License No. DPR-69

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Calvert Cliffs Nuclear Power Plant, Inc. (the licensee) dated April 17, 2003, as supplemented July 29, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2. of Renewed Facility Operating License No. DPR-69 is hereby amended to read as follows:

2. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 243, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 6, 2004

ATTACHMENT TO LICENSE AMENDMENTS AMENDMENT NO. 266 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AMENDMENT NO. 243 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 DOCKET NOS. 50-317 AND 50-318 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 3.3.12-1 3.3.12-1 3.3.12-2 3.3.12-2 3.4.5-1 3.4.5-1 3.4.5-2 3.4.5-2 3.4.5-3 3.4.5-3 3.4.6-1 3.4.6-1 3.4.6-2 3.4.6-2 3.4.7-1 3.4.7-1 3.4.7-2 3.4.7-2 3.4.7-3 3.4.7-3 3.4.8-1 3.4.8-1 3.4.8-2 3.4.8-2 3.4.17-1 3.4.17-1 3.4.17-2 3.4.17-2 3.8.2-3 3.8.2-3 3.8.2-4 3.8.2-4 3.8.5-2 3.8.5-2 3.8.8-2 3.8.8-2 3.8.10-2 3.8.10-2 3.9.2-1 3.9.2-1 3.9.4-1 3.9.4-1 3.9.4-2 3.9.4-2 3.9.5-1 3.9.5-1 3.9.5-2 3.9.5-2 3.9.5-3 3.9.5-3

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 266 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AND AMENDMENT NO. 243 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 CALVERT CLIFFS NUCLEAR POWER PLANT, INC.

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318

1.0 INTRODUCTION

By letter dated April 17, 2003 (ADAMS Accession No. ML031130176), as supplemented July 29, 2003 (ADAMS Accession No. ML03210153), the Calvert Cliffs Nuclear Power Plant, Inc. (the licensee) submitted a request for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 Technical Specifications (TSs). The proposed changes would revise the Required Actions requiring suspension of operations involving positive reactivity additions and various notes that preclude reduction in boron concentration. The proposed changes would limit the introduction of positive reactivity such that the required margin to the Shutdown Margin (SDM) and refueling boron concentration limits will be maintained. These proposed changes are similar to those proposed in the Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) change traveler TSTF-286, Revision 2. The July 29, 2003, letter clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on May 27, 2003 (68 FR 28841).

2.0 REGULATORY EVALUATION

Calvert Cliffs adopted the Improved Technical Specifications in License Amendment Numbers 227 and 201 (Reference 3) based on NUREG-1432, "Standard Technical Specifications [STS],

Combustion Engineering Plants," Revision 1, dated April 1995. Since then, industry and the NRC staff have been working to improve the STS, in NUREG-1430 through NUREG-1434 for the different plant vendors, and as a result, generic changes have been developed for the STS in NUREG-1432.

The proposed changes adopt NRC-approved generic changes in industry TSTF-286, Revision 2, which was approved by the staff in a letter dated July 6, 2000 (Reference 4). This TSTF revises Required Actions to suspend operations involving positive reactivity additions and limiting conditions for operation (LCOs) notes to prevent operations involving a reduction in reactor coolant system (RCS) boron concentration. The revisions limit the introduction into the

RCS of reactivity more positive than that required to meet the required SDM or refueling boron concentration, as applicable. TSTF-286 allows applicable licensees to revise their plant TSs and clarify limits on the introduction of reactivity such that the required SDM or refueling boron concentration will be satisfied.

The Calvert Cliffs SDM limit provides sufficient subcritical reactivity margin to ensure that the specified acceptable fuel design limits (SAFDLs) will not be exceeded for normal operation and anticipated operational occurrences (AOOs). The SDM definition assumes that the single Control Element Assembly (CEA) with the highest reactivity worth remains fully withdrawn following a reactor scram. In Modes 1 and 2, TSs 3.1.5, Shutdown Control Element Assembly (CEA) Insertion Limits, and 3.1.6, Regulating Control Element Assembly (CEA) Insertion Limits, satisfy the required SDM by limiting the insertion of the control and shutdown CEAs.

Small reactivity changes due to RCS coolant inventory management and temperature control are also considered in specifying SDM, including moderator temperature coefficient (MTC) effects. At the beginning of core life, a positive MTC coefficient must be considered as allowed by TS 3.1.3, Moderator Temperature Coefficient (MTC). In Mode 2 with keff < 1.0, and Modes 3, 4, and 5, the SDM requirements provide enough negative reactivity to meet the assumptions of the safety analyses in the Updated Final Safety Analysis Report. In Mode 6, the reactor subcriticality margin is ensured by the limit on the boron concentration of all filled portions of the RCS and the refueling pool that have direct access to the reactor vessel.

The TSs will be modified by this amendment to permit the addition of positive reactivity and changes to the RCS boron concentration as long as the change preserves the margin to core criticality as defined by the SDM and refueling boron concentration limit specifications. The limit specifications for the SDM and refueling boron concentration are given in TSs 3.1.1, Shutdown Margin (SDM), and 3.9.1, Boron Concentration, respectively.

The NRC has previously approved the subject change on a plant-specific basis. These previous approvals include but are not limited to H.B. Robinson, Unit 2, dated March 14, 2001 (ADAMS Accession Number ML010810282), Callaway, Unit 1, dated May 1, 2002 (ADAMS Accession Number ML020220051), Wolf Creek, dated July 29, 2002 (ADAMS Accession Number ML021290254), Catawba, Units 1 and 2, dated July 29, 2003 (ADAMS Accession Number ML032110122), and McGuire, Units 1 and 2, dated July 29, 2003 (ADAMS Accession Number ML032110073).

3.0 EVALUATION 3.1 Summary and Licensees Justification of Proposed Changes The licensee requested a change to the TSs for Calvert Cliffs to revise TS Required Actions that currently require suspending all operations involving any positive reactivity additions, and to revise TS LCO notes that preclude any reduction in boron concentration. The proposed changes would allow the introduction of reactivity as long as the TS required SDM or refueling boron concentration is properly maintained. The licensee stated that these necessary operations may involve additions to the RCS of cooler borated water or required makeup from

borated sources that have lower boron concentration than the existing RCS boron concentration. The licensee indicated that these changes would be allowed if the overall effect on core reactivity still assures that the required SDM or the refueling boron concentration is maintained.

The proposed changes conform closely with TSTF-286 except where noted in Section 3.2 below. The licensee provided plant-specific differences between the proposed changes and TSTF-286 as part of its application.

3.2 Staff Evaluation TSTF-286, Revision 2, revises the following in the STS: (1) various Required Actions that require suspension of operations involving positive reactivity additions; and (2) various TS notes precluding reduction in boron concentration. The revised TSs will limit the introduction of positive reactivity into the RCS to that which would maintain the TS-required SDM or refueling boron concentrations, as applicable. Additionally, the Required Actions, that require the suspension of positive reactivity changes, will have Bases additions that clarify the intent to preclude a loss of required SDM.

The justification given in the TSTF is that the change provides the flexibility necessary to provide for continued safe reactor operations, while also limiting any potential for excess positive reactivity addition to the core. The Required Actions and LCO Notes that preclude positive reactivity changes and/or reduction in boron concentration ensure either no power increases, or continued margin to core criticality operations. During conditions in which these Required Actions may be required, the following various activities for unit operation must be continued: RCS inventory must be maintained, and RCS temperature must be controlled.

These activities involve addition to the RCS of cooler water and may involve inventory makeup from sources that are at boron concentrations less than the current RCS concentration, but limit the introduction of reactivity more positive than that required to meet the required SDM or refueling boron concentration, as applicable. These activities do not need to be precluded in the TSs to ensure that, for the worst-case overall effect on the core, there would still be assurance that the required SDM is maintained.

The licensee employs two independent reactivity control systems: one uses the movable control and shutdown CEAs, and the other uses the chemical and volume control system (CVCS) to adjust the soluble boron concentration in the RCS. In Modes 1 and 2, both systems are used to compensate for the reactivity effects from the fuel and coolant temperature changes in the RCS during power operation from full load to no load condition. In Modes 3, 4, and 5, soluble boron is used to compensate for the reactivity effects from core temperature and xenon changes. In Mode 6, the CVCS is used to maintain the boron concentration within the required limits.

In Modes 1 through 4, the minimum required SDM is assumed as an initial condition for the reload safety analyses to ensure that the SAFDLs will not be exceeded for normal operation and AOOs, assuming that the highest worth CEA remains stuck out following a reactor scram.

The main steam-line break (MSLB) and boron dilution accidents are the most limiting events to establish the minimum SDM value for LCO 3.1.1 and the minimum boron concentration requirement of LCO 3.9.1, respectively. For the boron dilution accident, if LCO 3.1.1 or LCO 3.9.1 are not met, the minimum required time assumed for operator action to terminate dilution

may no longer be sufficient, and the required actions of LCO 3.1.1 or LCO 3.9.1 are necessary to restore compliance with the LCO.

As stated in the Bases for LCO 3.1.1, a sufficient shutdown margin ensures that: (1) the reactor can be made subcritical from all operating conditions, transients, and design basis events; (2) the reactivity transients associated with postulated accident conditions are controllable within acceptable limits; and (3) the reactor will be maintained sufficiently subcritical to preclude inadvertent criticality in the shutdown condition. The Bases for LCO 3.9.1 on refueling boron concentration in the RCS and the refueling pool similarly indicate that the limitations on boron concentration during refueling ensure that the reactor will remain subcritical during Mode 6. Since the proposed changes will not alter the limits established in these specifications, the staff concludes that the proposed changes will have no effect on the licensees ability to shut down and maintain the reactor in a subcritical condition.

The changes specified in TSTF-286, Revision 2, ensure that, under the specified plant conditions for each operating mode, unplanned power increases or reductions in the margin to core criticality are precluded. The proposed revision to existing TS Notes and the addition of wording to the TS ACTIONS allow the small reactivity variations that result from the temperature or boron concentration fluctuations associated with normal RCS inventory management or temperature control. These normal activities are permitted to be performed while maintaining the minimum SDM requirement of LCO 3.1.1 and the minimum boron concentration requirement of LCO 3.9.1.

The Calvert Cliffs plant specific clarifications provide the staff the assurance that the initial assumptions of the most limiting accident safety analyses are still maintained, while acknowledging that necessary compensatory activities may still be taken by adding cooler water to the RCS to lower the current temperature; and makeup sources are of borated water at boron concentrations less than the current RCS boron concentration. Compensatory activities are part of plant procedures, and this would assure that the overall effect on core reactivity is properly monitored, and the TS-required SDM or the required refueling boron concentration is maintained.

In its application, the licensee provided justification for changes that are consistent with TSTF-286, Revision 2. Where plant-specific design would dictate differences, the licensee provided plant-specific justification for any differences or exceptions, as discussed below. The proposed TS changes are applicable to Calvert Cliffs.

(a) The proposed changes include revising Required Action A.1 to TS 3.3.12, "Wide Range Logarithmic Neutron Flux Monitor Channels."

The current Required Action A.1 states the following: "Suspend all operations involving positive reactivity additions." TSTF-286, Revision 2, adds a note to STS 3.3.13 Required Action A.1 that allows limited insertions of positive reactivity associated with routine plant operations, and states that: "Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM." The licensee, however, proposed that the Required Action be changed without the addition of a note to the Required Action. Required Action A.1 would state: "Suspend all operations that involve positive reactivity additions that are not accounted for in the calculated SDM."

The licensee stated that the proposed change is preferred over the addition of the note to Required Action A.1. When one or more channels are inoperable, the wide range neutron flux monitoring function cannot be reliably performed which makes it difficult to ensure SDM is maintained. Therefore, positive reactivity additions that are not accounted for in the calculated SDM will not be allowed while the instrumentation is inoperable. Limited temperature changes or boron concentration fluctuations associated with RCS temperature control or inventory management will be allowed as long as the change is accounted for in the calculated SDM. The licensee stated that the revised Required Action 3.3.12.A.1 will fulfill the same purpose as the note by requiring suspension of operations involving positive reactivity addition if the calculated SDM is adversely affected.

The licensees proposed changes maintain SDM and reactor coolant boron concentration consistent with the current TSs for Calvert Cliffs. The proposed changes are consistent with TSTF-286, Revision 2, but are clarified to more accurately define the plant-specific application of the TSTF at Calvert Cliffs. Therefore, the staff finds that the proposed changes, with the plant-specific differences, are acceptable.

(a) The proposed changes include changes to Notes for the following LCOs:

 LCO 3.4.5, "RCS Loops - MODE 3," Note 1.a

 LCO 3.4.6, "RCS Loops - MODE 4," Note 1.a

 LCO 3.4.7, RCS Loops - MODE 5, Loops Filled, Note 1.a

 LCO 3.4.8, RCS Loops - MODE 5, Loops Not Filled, Note 1.b The LCO Notes would be changed to state that "No operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1." These Notes currently state: "No operations are permitted that would cause reduction of the RCS boron concentration." These Notes are intended to preclude dilution of the RCS when no forced mixing (i.e., coolant circulation by shutdown cooling (SDC) pumps or reactor coolant pumps) is taking place.

The proposed changes allow dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the SDM requirement of LCO 3.1.1. These proposed changes are identical to the changes in TSTF-286, as modified by the staff, for the same LCO notes.

The licensee provided the same justification for these changes as that provided by the staff for the TSTF. These changes are identical to the modified wording of TSTF-286, Revision 2, and are applicable to Calvert Cliffs; therefore, the staff finds that the proposed changes are acceptable.

(c) The proposed changes include changes to Required Actions for the following TSs:

 TS 3.4.5, "RCS Loops - MODE 3," Required Action C.1

 TS 3.4.6, RCS Loops - MODE 4, Required Action C.1

 TS 3.4.7, "RCS Loops - MODE 5, Loops Filled," Required Action B.1

 TS 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," Required Action B.1

The proposed changes would revise the Required Actions to state the following:

"Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1." The current Required Actions states: "Suspend all operations involving a reduction of RCS boron concentration." These Required Actions are intended to preclude dilution of the RCS when no forced mixing is taking place. The proposed changes allow dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the SDM requirement of LCO 3.1.1. These proposed changes are identical to the changes in TSTF-286, as modified by the staff, for the same Required Actions.

The licensee provided the same justification for these changes as that provided by the staff for the TSTF. These changes are identical to the modified wording of TSTF-286 and are applicable to Calvert Cliffs; therefore, the staff finds that the proposed changes are acceptable.

(d) The proposed changes include revision LCO 3.4.17, Note b, Special Test Exception (STE) RCS Loops - MODES 4 and 5.

LCO 3.4.17 Note b. would be changed to state that, "No operations are permitted which could cause introduction of coolant into the RCS with boron concentration less than that required to meet the minimum boron concentration of LCO 3.9.1. The Note currently states: "No operations are permitted which could cause reduction of the RCS boron concentration." This LCO is a special test exception that is allowed even though there is no bounding safety analysis. The tests or maintenance are allowed since they are performed under close supervision during the test program and must stay within the requirements of the LCO. Boron concentrations that are not accounted for in the SDM of LCO 3.1.1 will not be allowed so that, when circulation is re-established, SDM is the system that will not be adversely affected. The proposed note will allow boron concentration fluctuations associated with inventory management.

The licensee's proposed change maintains SDM consistent with the current TSs for Calvert Cliffs. LCO 3.4.17 Note b. will continue to restrict the conditions under which the shutdown cooling pumps may not be in operation. The proposed change clarifies that the intent of the Required Action is to limit the changes in boron concentration. This is a plant-specific change which is consistent with the intent of TSTF-286, Revision 2.

Therefore, the staff finds that the proposed change, with the plant-specific differences, is acceptable.

(e) The proposed changes include changes to Required Actions for the following TSs:

 TS 3.8.2, "AC Sources - Shutdown," Required Actions A.2.3 and B.3

 TS 3.8.5, "DC Sources - Shutdown," Required Action A.2.3

 TS 3.8.8, "Inverters - Shutdown," Required Action A.2.3

 TS 3.8.10, "Distribution Systems - Shutdown," Required Action A.2.3 The proposed Required Actions would state the following: "Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration." These Required Actions currently state: "Initiate action to suspend

operations involving positive reactivity additions." These Required Actions are intended to initiate suspension of operations involving positive reactivity additions based on the loss of required electrical sources and distribution equipment. The proposed changes allow dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the SDM requirement of LCO 3.1.1 or the refueling boron concentration of LCO 3.9.1. The proposed changes will also allow temperature changes that could increase reactivity provided the reactivity insertions do not result in a loss of required SDM. These proposed changes are identical to the changes in TSTF-286, as modified by the staff, for the same Required Actions.

The licensee provided the same justification for these changes as that provided by the staff for the TSTF. These changes are identical to the modified wording of TSTF-286 and are applicable to Calvert Cliffs; therefore, the staff finds that the proposed changes are acceptable.

(f) The proposed changes include changes to Required Action for TS 3.9.2, Nuclear Instrumentation, Required Action A.2.

The proposed Required Action states the following: "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1." The Required Action currently states:

"Suspend positive reactivity additions." This Required Action is intended to initiate suspension of operations during refueling operations involving positive reactivity additions when there is a loss of one source range monitor. The proposed change allows dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the minimum refueling boron concentration requirement of LCO 3.9.1, which ensures that inadvertent criticality will not occur. The proposed change is identical to the change in TSTF-286, as modified by the staff, for this Required Action.

The licensee provided the same justification for this change as that provided by the staff for the TSTF. The change is identical to the modified wording of TSTF-286 and is applicable to Calvert Cliffs; therefore, the staff finds that the proposed change is acceptable.

(g) The license proposed the following change to LCO 3.9.4 Note 1:

The proposed LCO 3.9.4 Note 1 would state the following: "The required SDC loop may be not in operation for # 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period, provided no operations are permitted that would cause introduction of coolant into the Reactor Coolant System with boron concentration less than that required to meet the minimum boron concentration of LCO 3.9.1." LCO 3.9.4 Note 1 currently states that: "The required SDC loop may be not in operation for < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period, provided no operations are permitted that would cause reduction of the Reactor Coolant System boron concentration." The allowance of removing the required SDC loop for < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period is not being changed by the proposed amendment. This note is intended to preclude dilution of the RCS when no forced mixing is taking place during refueling. The proposed change allows dilution of the RCS, but the source of boric acid is required to contain a soluble

boron concentration greater than that required to meet the minimum refueling boron concentration requirement of LCO 3.9.1, which ensures that inadvertent criticality will not occur. This proposed change is identical to the change in TSTF-286, as modified by the staff, for the same LCO Note.

The licensee provided the same justification for this change as that provided by the staff for the TSTF. This proposed change is identical to the modified wording of TSTF-286 and is applicable to Calvert Cliffs. Therefore, the staff finds that the proposed change is acceptable.

(h) The proposed changes include changes to Notes for the following LCOs:

 TS 3.9.4, "Shutdown Cooling (SDC) and Coolant Circulation-High Water Level,"

Note 2.a

 TS 3.9.5, "Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level,"

Note 3.b The proposed Notes would state the following: "No operations are permitted that would cause introduction of coolant into the Reactor Coolant System with boron concentration less than that required to meet the minimum boron concentration of LCO 3.9.1." The LCO Notes currently states that: "No operations are permitted that would cause a reduction of the Reactor Coolant System boron concentration." The allowance of removing the shutdown cooling pumps from operation during the time required for local leak rate testing of containment penetration number 41 for LCO 3.9.4 and de-energizing all SDC pumps for # 15 minutes when switching from one train to another for LCO 3.9.5 are not being changed by the proposed amendment. These notes are intended to preclude dilution of the RCS when no forced mixing is taking place during refueling. The proposed change allows dilution of the RCS, but the source of boric acid is required to contain a soluble boron concentration greater than that required to meet the minimum refueling boron concentration requirement of LCO 3.9.1, which ensures that inadvertent criticality will not occur.

The licensees proposed change maintains SDM consistent with the current TSs for Calvert Cliffs. LCO 3.9.4 Note 2.a. and LCO 3.9.5 Note 3.b. will continue to restrict the conditions under which the shutdown cooling pumps may not be in operation. The proposed changes clarify that the intent of the required action is to limit the changes in boron concentration. These are plant-specific changes which are consistent with the intent of TSTF-286, Revision 2. Therefore, the staff finds that the proposed changes, with the plant-specific differences, are acceptable.

(i) The proposed changes include changes to Required Actions for the following TSs:

 TS 3.9.4, "Shutdown Cooling (SDC) and Coolant Circulation - High Water Level,"

Required Action A.2

 TS 3.9.5, "Shutdown Cooling (SDC) and Coolant Circulation - Low Water Level,"

Required Action B.1

The proposed Required Actions would state the following: "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1." These Required Actions currently state: "Suspend operations involving a reduction in reactor coolant boron concentration." These Required Actions are intended to preclude dilution of the RCS when no forced mixing is taking place during refueling. The proposed changes allow dilution of the RCS, but the source of the boric acid is required to contain a soluble boron concentration greater than that required to meet the minimum refueling boron concentration requirement of LCO 3.9.1, which ensures that inadvertent criticality will not occur. These proposed changes are identical to the changes in TSTF-286, as modified by the staff, for the same Required Actions.

The licensee provided the same justification for these changes as that provided by the staff for the TSTF. These changes are identical to the modified wording of TSTF-286 and are applicable to Calvert Cliffs; therefore, the staff finds that the proposed changes are acceptable.

3.3 Conclusion of the NRC Staff Evaluation The NRC staff has reviewed the licensees application with the supporting documentation.

Based on its review, the NRC staff concludes that the proposed changes to the TSs are acceptable because proposed notes and Required Actions limit the introduction of coolant into the RCS with boron concentration less than that required to meet the required SDM or refueling boron concentration. In addition, these changes are consistent with the approved TSTF-286, Revision 2, which is applicable to Calvert Cliffs and takes into account plant-specific design differences discussed above. The justification for TSTF-286, Revision 2, is applicable to Calvert Cliffs, and continues to ensure that the required minimum SDM of LCOs 3.1.1, 3.1.5, and 3.1.6, and boron concentration of LCO 3.9.1 to preclude inadvertent criticality are met.

Since the licensee's proposed amendment will still require the minimum SDM and boron concentration to be maintained, the NRC staff concludes that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (68 FR 28847). Accordingly, the amendments meet the eligibility criteria for categorical

exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above that (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 Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Katz, P. E., Constellation Energy Group, to USNRC, Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request:

Improvement to the Definition of Operations Involving Positive Reactivity Changes, April 17, 2003.

2. Vanderheyden, G., Constellation Energy Group, to USNRC, Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request: Improvement to the Definition of Operations Involving Positive Reactivity Changes, July 29, 2003.

3. Domerick, A. W., USNRC, to C. H. Cruse, Baltimore Gas and Electric Company, Issuance of Amendments for Calvert Cliffs Nuclear Power Plant Unit No. 1 (TAC No.

M97363) and Unit No. 2 (TAC No. M97364), May 4, 1998.

4. Beckner, W. D., USNRC to J. Davis, Nuclear Energy Institute, July 6, 2000.

Principal Contributor: K. Kavanagh Date: May 6, 2004