ML073470640

Supplement to Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process

ML073470640
Person / Time
Site:	Calvert Cliffs
Issue date:	12/13/2007
From:	Spina J Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD5437, TAC MD5438
Download: ML073470640 (10)

Text

Jam es A. Spina Calvert Cliffs Nuclear Power Plant, Inc.

Vice Presid ent 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.49 5-3500 Fax 0 *: >* Constellation Energy'

../ Nuclear eneration Group December 13,2007 U. S. Nuclear Regu latory Commission Was hington, D.C. 20555 ATTENTION: Document Control Desk SUBJ ECT: Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos . 50-31 7 & 50-318 Supplement to Application for Technical Specification Change to Add LCO 3.0 .8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process

REFERENCES:

(a) Letter from J. M. Heffley (CNGG) to Document Con trol Desk (NRC),

dated October 17, 2007 , "Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process" (b) Letter from J. A. Spina (CCNPP) to Document Control Desk (NRC), dated May 2, 200 7, "License Amendment Request: Add LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process" (c) Letter from D. V. Pickett (NRC) to J . A. Spina (CCNPP), dated September 27,2007, "Calvert Cliffs Nuclear Power Plant, Unit Nos . 1 and 2 - Amendment Re: Implementation of LCO 3.0 .9 on the Unavailabi lity of Barriers Using the Consolidated Line Item Improvement Process (TAC Nos. MD543 7 and MD5438)"

This letter is to correct similar omi ssions in the submittal of References (a) and (b).

Limiting Condition for Operation 3.0.8 Reference (a) submitted a request to change the Technical Specifications for Calvert Cliffs Nuclear Power Plant and R.E. Ginna Nuclear Power Plant to add Limiting Condition for Operation (LCO) 3.0.8 . In that submittal we inadvertently omitted a markup for a related change to LCO 3.0.1. This supplement provides a Calvert C liffs Nuclear Power Plant markup for that change. The markup for R.E. Ginna Nuclear Power Plant will be submitted separately.

Document Control Desk December 13,2007 Page 2 We are also providing a markup for the Technical Specification Bases for LCOs and LCO 3.0.8

[Attachment (2)]. These markups are related to Reference (a) and are provided for information only.

Analysis Limiting Condition for Operation 3.0.8 will provide an allowance of time to repair or replace an inoperable seismic snubber without declaring the supported system inoperable. Limiting Condition for Operation 3.0.1 requires LCOs to be complied with, except as provided in certain LCOs. Since LCO 3.0.8 will provide an exception to LCO 3.0 .1, it should be listed among the exceptions. This supplement adds LCO 3.0.8 to the exceptions. A Technical Specification page markup is provided in Attachment (1) .

Adding the reference to LCO 3.0 .8 in LCO 3.0.1 does not change the Significant Hazards Discussion in Reference (a) .

Limiting Condition for Operation 3.0.9 Reference (b) submitted a request to change the Technical Specifications for Calvert Cliffs Nuclear Power Plant to add Limiting Condition for Operation (LCO) 3.0.9. In that submittal we inadvertently omitted a markup for a related change to LCO 3.0.1 . This letter provides a markup for that change. The license amendment request posed in Reference (b) was approved by Reference (c).

Analysis Limiting Condition for Operation 3.0.9 provides an allowance of time to remove a barrier without declaring the supported system inoperable. Limiting Condition for Operation 3.0.1 requires LCOs to be complied with, except as provided in certain LCOs . Since LCO 3.0.9 will provide an exception to LCO 3.0.1, it should be listed among the exceptions. This supplement adds LCO 3.0.9 to the exceptions.

A Technical Specification page markup is provided in Attachment (1).

Adding the reference to LCO 3.0.9 in LCO 3.0.1 does not change the Significant Hazards Discussion in Reference (b).

Document Control Desk December 13, 2007 Page 3 Should you have questions regarding this matter, please contact Mr. Jay S. Gaines at (410) 495-5219.

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 believe i e reliable.

./ /

Subscribed and sworn before ~ a Notary Public ip and for the State of Maryland and County of

~-f. MaLe.(:O , this _u_* . day of PeC;8¥l~ ,2007.

/

WITNESS my Hand and Notarial Seal:

Notary Pu My Commission Expires:

JAS/EMT/bjd Attachments: (1) Technical Specification Markup - LCO 3.0.1 (2) Technical Specification Bases Markup - For Information Only cc: D. V. Pickett, NRC Resident Inspector, NRC S. J. Collins, NRC R. I. McLean, DNR

ATTACHMENT ill TECHNICAL SPECIFICATION MARKUP -

LCO 3.0.1 Calvert Cliffs Nuclear Power Plant December 13, 2007

LCO Applicabil ity 3.0 3.0 LIMIT ING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shal l be met during the MODES or other specified conditi ons in the App1i cabil ity, exgp.Las._p.LQ..'Lid.e- iJD-LCO 3.0.2 Q LCO 3.0.7~__:L ~ . O ' 8 G~ J ux.o *3 . 0~

(~

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Requ ired Actions of the associated Cond itions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO i s not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the un it shall be placed in a MODE or other specified condit ion in which the LCO is not applicable. Action shal l be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a. MODE 3 withi n 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

b. MODE 4 withi n 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and

c. MODE 5 withi n 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

CALVERT CLIFFS - UNIT 1 3.0-1 Amendment No. 227 CALV ERT CLI FFS - UNIT 2 Amendment No. 201

ATTACHMENT (11 TECHNICAL SPECIFICATION BASES MARKUP -

FOR INFORMATION ONLY Calvert Cliffs Nuclear Power Plant December 13, 2007

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs Limiting C~ition for Operation (LCO) 3.0.1 through LCO 3.0.~establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated.

LCO 3.0.1 Limiting Condition for Operation 3.0.1 establishes the Applicability statement within each individual Specification for when the LCO is required to be met (i .e., when the unit i s in the MODEs or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 Limiting Condition for Operation 3.0.2 establishes that, upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable when an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit for meeting the LCO. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures, permiting continued operation of the unit, that are not further restricted by the Completion Time. In this case, CALVERT CLIFFS - UNITS 1 &2 B 3.0-1 Revision 2

LCO Appl icability B 3.0 BASES LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit.

These special tests and operations are necessary to demonstrate select unit performance characteristics, to per form special maintenance activities, and to perform special evolutions. Special Test Exception (STE)

LCOs 3.1.7, 3.1 .8, and 3.4.17 allow specific Tec hnical Speci f i cat i on requirements to be changed to permit perf ormances of these special tests and operations, which otherwise could not be performed if required to comply with these Technical Specifications. Unless otherwise specified, all the other Technical Specification requirements remain unchanged. This wil l ensure all appropriate requirements of the MODE, or other specified condition not directly associated with or required to be changed to perform the special test or operation, will remain in effect.

The App licability of a STE LCO represents a condition not necessari ly in compliance with the normal requirements of the Technical Specificat ion. Compliance with STE LCOs is optiona l. A special operation may be performed either under the provisions of the appropriate STE LCO or under the other applicable Technical Specification requirements. If it is desired to perform the special operation under the provi si ons of the STE LCO, the requirements of the STE LCO shall be followed.

CALVERT CLIFFS - UNITS 1 &2 B 3.0 -12 Revision 26

INSERT LCO 3.0.8 Limiting Condition for Operation (LCO) 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s) . This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function( s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications in the Technical Requirements Manual (TRM) . The snubber requirements do not meet the criteria in 10 CFR 50.36(d)(2)(ii), and, as such, are appropriate for control by the TRM .

If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

Limiting Condition for Operation 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system . Limiting Condition for Operation 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.

Limiting Condition for Operation 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function( s) to more than one train or subsystem of a multiple train or subsystem supported system . Limiting Condition for Operation 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.

Limiting Condition for Operation 3.0.8 requires that risk be assessed and managed . Industry and Nuclear Regulatory Commission guidance on the

implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use ofLCO 3.0.8 must be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness ofthe vulnerability of systems and components when one or more snubbers are not able to perform their associated support function .