ML071270371

License Amendment Request Add LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process

ML071270371
Person / Time
Site:	Calvert Cliffs
Issue date:	05/02/2007
From:	Spina J Constellation Energy Group
To:	Document Control Desk, NRC/NRR/ADRO
References
Download: ML071270371 (8)

Text

James A. Spina Calvert Cliffs Nuclear Power Plant, Inc.

Vice President 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495.3500 Fax 0 Constellation Energy-Generation Group May 2, 2007 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: Add LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process

REFERENCE:

(a) Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding the Addition of LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process, 71 FR 58444, dated October 3, 2006 Pursuant to 10 CFR 50.90, Calvert Cliffs Nuclear Power Plant, Inc. hereby requests an amendment to Renewed Operating License Nos. DPR-53 and DPR-69 to modify Technical Specification requirements for unavailable barriers by adding Limiting Condition for Operation 3.0.9. This proposed amendment request is based on the Nuclear Regulatory Commission staff's model application described in Reference (a). Attachment (1) provides a description of the proposed change, the requested confirmation of applicability and plant specific regulatory commitments. Attachment (2) provides the marked up Technical Specification pages. The Technical Specification Bases will be changed as appropriate to support this information.

Safety Committee Review The Plant Operations Review Committee has reviewed the proposed change and concurs that operation with the proposed change will not result in an undue risk to the health and safety of the public.

Schedule Calvert Cliffs requests approval of the proposed License Amendment by April 1, 2008. We request an implementation period of 60 days to allow for operator training and the required procedure changes.

A/oo

Document Control Desk May 2, 2007 Page 2 Should you have questions regarding this matter, please contact Mr. Jay S. Gaines at (410) 495-5219.

you rs, STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT I, James A. Spina, 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 belitell Sub cribed and sworn before me a INotary Public in and for the State of Maryland and County of

'0' this day of WiTNESS my Hand and Notarial Seal:

Notary Pub~lic My Commission Expires: ýý K

/ 2&ý//

bDate JAS/PSF/bjd Attachments: (1) Technical Basis and No Significant Hazards Consideration (2) Marked up Technical Specification Pages cc: D. V. Pickett, NRC Resident Inspector, NRC S. J. Collins, NRC R. I. McLean, DNR

ATTACHMENT (1)

TECHNICAL BASIS AND NO SIGNIFICANT HAZARDS CONSIDERATION TABLE OF CONTENTS

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL EVALUATION Calvert Cliffs Nuclear Power Plant, Inc.

May 2, 2007

ATTACHMENT (1)

TECHNICAL BASIS AND NO SIGNIFICANT HAZARDS CONSIDERATION

1.0 DESCRIPTION

The proposed amendment would modify Technical Specification requirements for unavailable barriers by adding Limiting Condition for Operation 3.0.9.

The changes are consistent with the Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF)-427, Revision 2. The availability of this Technical Specification improvement was published in the Federal Register on October 3, 2006 (71 FR 58444) as part of the consolidated line item improvement process (CLITP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Calvert Cliffs Nuclear Power Plant (Calvert Cliffs) has reviewed the safety evaluation dated October 3, 2006 as part of the CLIIP. The review included a review of the NRC Staff's evaluation as well as the supporting information provided to support TSTF-427, Revision 2. Calvert Cliffs has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Calvert Cliffs Units 1 and 2 and justify this amendment request for incorporation of the proposed changes into the Calvert Cliffs Technical Specifications.

2.2 Optional Changes and Variations Calvert Cliffs is not proposing any variations or deviations from the Technical Specification changes described in TSTF-427, Revision 2 or the NRC staff's model safety evaluation dated October 3, 2006.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Calvert Cliffs has reviewed the proposed No Significant Hazards Determination published in the Federal Register as part of the CLIIP. Calvert Cliffs has concluded that the proposed No Significant Hazards Determination presented in the Federal Register notice is applicable to Calvert Cliffs and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on October 3, 2006 for this Technical Specification improvement, plant specific regulatory commitments are made as follows:

1. Calvert Cliffs commits to the guidance of NUMARC 93-01, Section 11, which provides guidance and details on the assessment and management of risk during maintenance.

2. Calvert Cliffs will revise procedures as appropriate to ensure that the risk assessment and management process described in Nuclear Energy Institute (NEI) 04-08 is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.9 are to be applied, in accordance with an overall Configuration Risk Management Program to ensure that potentially risk significant configurations resulting from maintenance and other operational activities are identified and avoided.

4.0 ENVIRONMENTAL EVALUATION Calvert Cliffs has reviewed the environmental evaluation included in the model safety evaluation dated October 3, 2006 as part of the CLIIP. We have concluded that the NRC Staff s findings presented in that evaluation are applicable to Calvert Cliffs and the evaluation is hereby incorporated by reference for this 1

ATTACHMENT (1)

TECHNICAL BASIS AND NO SIGNIFICANT HAZARDS CONSIDERATION application. A Technical Specification Bases Control Program already exists in the Calvert Cliffs Technical Specifications (Technical Specification 5.5.14).

2

ATTACHMENT (2)

MARKED UP TECHNICAL SPECIFICATION PAGES Calvert Cliffs Nuclear Power Plant, Inc.

May 2, 2007

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Special test exception (STE) LCOs in each applicable LCO section allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with STE LCOs is optional. When an STE LCO is desired to be met but is not met, the ACTIONS of the STE LCO shall be met. When an STE LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.

LCO-. jc9Lv~e4 CALVERT CLIFFS - UNIT 1 3.0-3 Amendment No. 276 CALVERT CLIFFS - UNIT 2 Amendment No. 253

Insert 1 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not requiredto be declarednot met solely for this reasonfor up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable ofproviding their related supportfunction (s), and risk is assessed and managed This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE ahd the barrierssupportingeach of these trains or subsystems provide their relatedsupport function(s)for different categories of initiatingevents.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their relatedsupport function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supportedsystem LCO(s) shall be declared not met.