ML082760383

Attachment 1, Evaluation of the Proposed Change to License Amendment Request: Reporting of Reactor Vessel In-Service Inspection Information and Analyses in Support of Code Relief Request for Extension of Reactor Vessel..

ML082760383
Person / Time
Site:	Calvert Cliffs
Issue date:	10/01/2008
From:	Calvert Cliffs, Constellation Energy Group, Nuclear Generation Group
To:	Office of Nuclear Reactor Regulation
Shared Package
ML082760380	List: ML082760382 ML082760383 ML082760384
References
TAC MC9768
Download: ML082760383 (5)

Text

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Calvert Cliffs Nuclear Power Plant, Inc.

October 1, 2008

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION This letter requests an amendment to Renewed Operating Licenses DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant (Calvert Cliffs), Unit Nos. 1 and 2. The proposed change will insert into the respective operating licenses a requirement involving the reporting of specified Reactor Vessel (RV) In-Service Inspection (ISI) information and analyses as specified in Reference (1). This amendment request is a required element of a code relief request (Reference 2) to extend the RV ISI 10-year inspection interval. The code relief request is based on the analysis contained within Reference (3). The methodology in Reference (3) was evaluated by the Nuclear Regulatory Commission (NRC), in Reference (4), as being acceptable for referencing in license amendment requests. Reference (4) requires that licensees desiring to extend the frequency of the RV ISI interval, which do not implement 10 CFR 50.61a, must amend their licenses to require the submittal of information and analyses requested in paragraph (e) of the final 10 CFR 50.61a [or the proposed 10 CFR 50.61a, as listed in Reference (1) prior to the issuance of the final 10 CFR 50.61a]. Currently, Calvert Cliffs has not implemented 10 CFR 50.61a because the final rule has not yet been approved. Therefore, in accordance with Reference (4), we are requesting to amend our licenses as described below.

Acceptance of this amendment request would allow the RV ISI interval to be extended such that Unit 1's third interval ISI would be completed during the 2018 refueling outage and its fourth interval inspection would be completed during the 2038 refueling outage. Likewise Unit 2's third interval ISI interval would be completed during the 2019 refueling outage and its fourth interval inspection would be completed during its 2039 refueling outage. This is consistent with the proposed inspection schedule in Reference (5).

2.0 DETAILED DESCRIPTION Calvert Cliffs proposed change will add, as item (6) to Section 2.C of Unit 1's license and item (8) to Section 2.C of Unit 2's license the following requirement:

Reactor Vessel In-Service Inspection Interval Extension As part of Calvert Cliffs Nuclear Power Plants relief request to extend the reactor vessel In-Service Inspection interval (if approved), Calvert Cliffs shall submit to the NRC the information and analyses specified in paragraph (e) of the proposed 10 CFR 50.61a, given in 72 FR 56275 following completion of each American Society of Mechanical Engineers (ASME) Code,Section XI, Category B-A and B-D reactor vessel weld inspection. The information and analyses shall be submitted within one year of the completion of each inspection. Once the final 10 CFR 50.61a is effective, the required information and analyses specified in paragraph (e) of the final 10 CFR 50.61a shall be the information submitted to the NRC.

This proposed change implements the requirement to submit a license amendment request at the time of submitting a relief request as specified in Reference (4).

3.0 TECHNICAL EVALUATION

The proposed change is administrative in nature because it adds a reporting requirement to the operating licenses. The justification for the information requested, and the scope and frequency of the ISI examinations is given in Reference (2). This proposed amendment only addresses the reporting of results following the described ISI examination.

Submittal of the data required by 10 CFR 50.61a is necessary to demonstrate the RV maintains its ability to meet code fracture toughness requirements and is used to justify continued use of the approved code relief request for an extended RV ISI interval. Since the proposed change involves only a requirement for 1

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EVALUATION OF THE PROPOSED CHANGE the submittal of information, it clearly does not have any impact on the operation of the plant or any design basis accident, and is not related to a margin of safety.

The relief request to extend the RV ISI interval is separate from this license change and is reviewed separately.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria This amendment request is a required part of a code relief request submitted to extend Calvert Cliffs RV ISI 10-year inspection interval. Reference (4) provides the requirements a station must meet in order for the NRC to approve such an alternative to Section XI of the ASME code. This amendment request meets the requirement, listed in Section 3.4 of Reference (4), that the licensee will submit identified information and analyses to the NRC.

The proposed change, to report results from RV examinations required by Section XI of the ASME code, is being submitted in support of demonstrating Calvert Cliffs ability to justify extending its RV ISI interval frequency.

4.2 Precedent While there is no existing approved precedent for this proposed change, Indian Point Units 2 and 3 and Palisades Nuclear Plant, have recently submitted license amendment requests for this proposed change that are similar in content and approach. Submittal of this proposed change is consistent with the requirements stated in Reference (4).

4.3 Significant Hazards Consideration Calvert Cliffs is submitting a code relief request from American Society of Mechanical Engineers (ASME) code,Section XI that will allow Calvert Cliffs to extend the frequency of the reactor vessel In-Service Inspection (ISI) beyond the required 10-year interval. The code relief request is based on the analysis of Topical Report WCAP-16168-NP, Revision 2 which was found to be an acceptable approach by a Nuclear Regulatory Commission (NRC) Safety Evaluation. The Safety Evaluation required that utilities not implementing 10 CFR 50.61a (Calvert Cliffs is not implementing 10 CFR 50.61a at this time) must submit a license amendment request that requires the submittal of information and analyses specified in Section (e) of 10 CFR 50.61(a) (or the proposed 10 CFR 50.61a, given in 72 FR 56275, for the time period prior to the issuance of the final 10 CFR 50.61a). This proposed change adds a statement in Calvert Cliffs licenses to provide the required information and analyses.

Calvert Cliffs has evaluated whether or not a significant hazards consideration is involved with the proposed change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment" as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change, which adds a requirement within Calvert Cliffs licenses to provide required information and analyses as a supporting condition for extending the allowed reactor vessel ISI interval, only involves the commitment to provide data obtained from the reactor vessel ISI. This proposed change involves only the submittal of generated data that will be used to verify the reactor vessel has more than sufficient margin to prevent any pressurized thermal shock event from occurring. This proposed change does not involve any change to the design basis of the plant or of 2

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EVALUATION OF THE PROPOSED CHANGE any structure, system, or component. Therefore, the proposed change does not involve a significant increase in the probability or consequence of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change, which adds a requirement within Calvert Cliffs licenses to provide required information and analyses as a supporting condition for extending the reactor vessel ISI interval, only involves the commitment to provide data and analyses obtained from the reactor vessel ISI. As such this proposed change does not result in physical alteration to the plant configuration or make any change to plant operation. As a result no new accident scenarios, failure mechanisms, or single-failures are introduced. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

The proposed change, which adds a requirement within Calvert Cliffs licenses, to provide required information and analyses as a supporting condition for extending the allowed reactor vessel ISI interval, only involves the commitment to provide data and analyses obtained from the reactor vessel ISI. The submitted data may be used to verify the condition of the reactor vessel meets all required standards to ensure sufficient safety margin is maintained against the occurrence of a pressurized thermal shock event during the expanded time interval between reactor vessel ISIs. The proposed change is administrative in nature and is not related to any margin to safety. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above evaluation, Calvert Cliffs has concluded that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (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 Commission regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance and/or indemnity requirements, or (ii) changes to recordkeeping, reporting or administrative procedures, or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in conjunction with the proposed amendment.

6.0 REFERENCES

(1) Federal Register Notice (72 FR 56275), dated October 3, 2007, Alternative Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events (2) Letter from Mr. M. D. Flaherty (CCNPP) to Document Control Desk (NRC), dated October 1, 2008, Revised Request to Extend the Inservice Inspection Interval for Reactor Vessel Weld Examinations - Relief Requests (ISI-020 and ISI-021) 3

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE (3) WCAP-16168-NP, Revision 2, dated June 2008, Risk-Informed Extension of the Reactor Vessel In-Service Inspection Interval (4) Letter from H. K. Nieh (NRC) to G. Bischoff (PWROG), dated May 8, 2008, Final Safety Evaluation for Pressurized Water Reactor Owners Group (PWROG) Topical Report (TR)

WCAP-16168-NP, Revision 2, Risk-Informed Extension of the Reactor Vessel In-Service Inspection Interval (TAC No. MC9768)

(5) PWR Owners Group letter OG-06-356, "Plan for Plant Specific Implementation of Extended Inservice Inspection Interval per WCAP 16168-NP, Revision 1," Risk Informed Extension of the Reactor Vessel In-Service Inspection Interval" MUHP 5097-99, Task 2059," dated October 31, 2006 4