ML080740227
| ML080740227 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/12/2008 |
| From: | Spina J Calvert Cliffs |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MD5928, TAC MD5929 | |
| Download: ML080740227 (7) | |
Text
James A. Spina Vice President Constellation Energy-Nuclear Generation Group Calvert Cliffs Nuclear Power Plant, Inc.
1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495-3500 Fax March 12, 2008 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
REFERENCES:
Document Control Desk Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information re: Control Room Habitability (TAC Nos. MD5928 and MD5929)
(a)
Letter from Mr. D. V. Pickett (NRC) to Mr. J. A. Spina (CCNPP), dated January 8, 2008, Request for Additional Information re: Control Room Habitability (TAC Nos. MD5928 and MD5929)
(b)
Letter from Mr. J. E. Pollock (CCNPP) to the Document Control Desk (NRC), dated June 29, 2007, License Amendment Request:
Revise Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448 Using the Consolidated Line Item Improvement Process As requested by Reference (a), we are providing additional information to support our request to modify Technical Specification requirements for Control Room emergency ventilation system in accordance with Technical Specification Task Force (TSTF)-448, Revision 3. We understand from Reference (a) that TSTF-448, Revision 3 was developed for plants with pressurized Control Room envelopes. Calvert Cliffs does not pressurize the Control Room envelope as part of the response to a plant transient. The programs and manuals section of the standard Technical Specifications, as modified by TSTF-448, Revision 3, specifies a differential pressure test to be conducted between performances of inleakage testing for the purpose of providing input to a periodic assessment of the Control Room envelope boundary. Because Calvert Cliffs has a non-pressurized Control Room envelope, we cannot conduct the differential pressure test. Therefore, in our initial submittal (Reference b), we removed the requirement provided in TSTF-448 for a differential pressure test. However, we recognize that there is a need to provide a method to collect data to serve as input to a periodic assessment of the Control Room envelope.
Therefore, we are proposing a method to collect this data as shown in the attached markup of new section 5.5.17 of our Technical Specifications.
Document Control Desk March 12, 2008 Page 2 The Control Room envelope boundary is static. The Control Room ventilation system operates in 100%
recirculation mode during normal and accident conditions. If a chemical, radiological, or smoke event occurs, the ventilation system does not require damper actuation or system realignment to establish the boundary and protect the operators in the Control Room. During a radiological event, dampers realign the ventilation system to use the post-loss-of-coolant incident filters, but these components are within the Control Room envelope and will not affect system isolation. Periodic inspection of the Control Room envelope boundary components that are opened occasionally (such as doors and access hatches) will provide sufficient assurance that the Control Room envelope boundary has not degraded between periodic inleakage testing. Therefore, we propose to add a requirement to perform inspections of the doors and access hatches on a periodicity that ensures the information is available to serve as an input to the periodic assessment of the Control Room envelope that is already contained in new Technical Specification 5.5.17.
Attachment (1) provides a revised markup of proposed Technical Specification 5.5.17 that includes a new section (d). Please replace the proposed Technical Specification 5.5.17 in Reference (b) with the revised mark-up provided in Attachment (1).
No Technical Specification Bases are provided for this section.
This additional information does not alter the No Significant Hazards Determination provided in Reference (b).
Document Control Desk March 12, 2008 Page 3 Should you have questions regarding this matter, please contact Mr. Jay S. Gaines at (410) 495-5219.
Very truly yours, STATE OF MARYLAND COUNTY OF CALVERT
- TO WIT:
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 me, a Notary Public in and for the State of Maryland and County of n "y this I day of ac-c,,/,
2008.
(ll ~I'/ /ja' WITNESS my Hand and Notarial Seal:
My Commission Expires:
Notary Publiqi/
Date JAS/PSF/bjd
Attachment:
(1)
Marked up Technical Specification Page cc:
D. V. Pickett, NRC S. J. Collins, NRC Resident Inspector, NRC R. I. McLean, DNR
ATTACHMENT (1)
MARKED UP TECHNICAL SPECIFICATION PAGE Calvert Cliffs Nuclear Power Plant, Inc.
March 12, 2008
Programs and Manuals 5.5 5.5 Prograrns and Manuals
- b.
Air lock testing acceptance criteria are:
- 1. Overall air lock leakage rate is 5 0.05 La when tested at Ž Pa.
- 2.
For each door, leakage rate is
- 0.0002 L. when pressurized to Ž 15 psig.
The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.
The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
-Lc~-
~A CALVERT CLIFFS -
UNIT 1 CALVERT CLIFFS -
UNIT 2 5.5-18 Amendment No.
278 Amendment No.
255
Insert 2 5.5.17 Control Room Envelope Habitability Program A Control Room Envelope (CRE)
Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS),
CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge.
The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem whole'body or its equivalent to any part of the body for the duration of the accident.
The program shall include the following elements:
- a.
The definition of CRE and the CRE boundary.
- b.
Requirements for maintaining CRE boundary in its design condition including configuration control and preventive maintenance.
- c.
Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the
- testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors,"
Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.
.d. Inspection of the following CRE boundary elements:
roof top access hatches, and personnel access doors, at a frequency of 18 months.
The results shall be used as part of the 36 month assessment of the CRE boundary.
- e.
The quantitative limits on unfiltered air inleakage into the CRE.
These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.
The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences.
Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these
hazards will be within the assumptions in the licensing basis.