ML091380325

License Amendment Request: Administrative Revision of Inservice Test Program Technical Specification

ML091380325
Person / Time
Site:	Calvert Cliffs
Issue date:	05/13/2009
From:	Trepanier T Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML091380325 (10)

Text

i. ............. .i Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 Constellation Energy Nuclear Generation Group May 13, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 License Amendment Request: Administrative Revision of Inservice Test Program Technical Specification

REFERENCES:

(a) TSTF-479-A, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a, dated December 19, 2005 (b) TSTF-497-A, Revision 0, Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less, dated July 12, 2006 (c) Letter from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, Status of TSTF 343, 479, 482, 485, dated December 6, 2005 (d) Letter from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, dated October 4, 2006 Pursuant to 10 CFR 50.90, Calvert Cliffs Nuclear Power Plant, Inc. (Calvert Cliffs) hereby requests an amendment to Calvert Cliffs Unit 1 and 2 Technical Specifications that is based on incorporating Technical Specification Task Force 479-A (Reference a) and Technical Specification Task Force 497-A (Reference b). References (a) and (b) revise the Improved Standard Technical Specification administrative controls of the Inservice Testing Program for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3. References (a) and (b) were subsequently approved by the Nuclear Regulatory Commission by References (c) and (d), respectively.

Specifically, the proposed change will replace, within Technical Specification 5.5.8, references to ASME Section XI of the Boiler and Pressure Vessel Code with references to the ASME Code for Operation and Maintenance of Nuclear Power Plants. In addition the proposed change also applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in Technical Specification 5.5.8.a.

The technical basis and the significant hazards discussion for the proposed changes are provided in Attachment (1). A marked up page of the affected Technical Specification is provided in Attachment (2).

-AOJ -

Document Control Desk May 13, 2009 Page 2 Approval of the proposed amendment is requested by October 1, 2009 with a 60 day implementation period. Continued plant operation does not depend on approval of this proposed change.

Should you have questions regarding this matter, please contact Mr. Jay S. Gaines at (410) 495-5219.

Very t ly yours, Thomas E. Trepanier Plant General Manager STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT I, Thomas E. Trepanier, being duly sworn, state that I am Plant General Manager - 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 emplooe and/or consultants.

Such information has been reviewed in accordance with company e eve it to be reliable.

I)

Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of Cc¢A,uo0

.PT ,this iS dayof (Yio.m ,2009.

-WITNESS my Hand and Notarial Seal:

Notary Public WOW L N~~W NOTARY£wI.

imI*I!f PUBLIC 01/010 My Commission Expires: C~vasffy.

Dateln U -A TET/KLG/bjd Attachments: (1) Evaluation of the Proposed Change (2) Marked up Technical Specification Page

Document Control Desk May 13, 2009 Page 3 cc: D. V. Pickett, NRC Resident Inspector, NRC S. J. Collins, NRC S. Gray, DNR

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.

May 13, 2009

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Calvert Cliffs Unit 1 and 2 Technical Specifications based on incorporating Technical Specification Task Force (TSTF) 479-A (Reference 1) and TSTF 497-A (Reference 2). Technical Specification Task Force-479-A and TSTF-497-A revise the Improved Standard Technical Specification administrative controls of the Inservice Testing (IST) Program. The proposed change will revise the applicable Technical Specification (TS) to align it with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3. Technical Specification Task Force-479-A and TSTF-497-A were subsequently approved by the Nuclear Regulatory Commission by References 3 and 4, respectively.

2.0 DETAILED DESCRIPTION The proposed change incorporates TSTF-479-A and TSTF-497-A and is comprised of two portions. The first portion replaces references to ASME Section XI of the Boiler and Pressure Vessel Code with references to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) within TS 5.5.8.

The second portion of the change applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.8.a. Specifically TS 5.5.8.b is changed to read:

"The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities."

These proposed changes serve to align Calvert Cliffs TS with the TSTFs of References 1 and 2 and revises Calvert Cliffs TS to correctly reflect the ASME code of record that is currently being used in Calvert Cliffs current Ten Year IST Program (Reference 5).

3.0 TECHNICAL EVALUATION

Title 10 CFR 50.55a was amended by Reference 6 to incorporate by reference more recent editions and addenda of the ASME Boiler and Pressure Vessel Code and the ASME OM Code for construction, inservice inspection, and inservice testing. These provisions provide updated rules for the construction of components of nuclear power plants and for the inservice inspection and inservice testing of those components.

Pursuant to 10 CFR 50.55a(f)(4), Calvert Cliffs adopted, in Reference 5, ASME OM Code, 2004 Edition as the code of record for Calvert Cliffs Fourth Ten Year IST program period which began on July 1, 2008. The proposed change to incorporate TSTF-479-A will serve to align Calvert Cliffs TS with the ASME code of record currently being used in Calvert Cliffs IST Program.

Incorporation of TSTF-497-A applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in Calvert Cliffs TS 5.5.8.a. This extension facilitates surveillance scheduling and considers plant operating conditions that may not be suitable for conducting the surveillance while not resulting in a significant degradation of the reliability that results from performing the surveillance at its specified time.

I

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE The proposed change is considered to be administrative in that the incorporation of TSTF-479-A and TSTF-497-A incorporates the evolution of policy and guidance as to the required content and preferred format of TS over time. Incorporating TSTF-479-A and TSTF-497-A also aligns Calvert Cliffs TS with the code of record currently in place with our IST Program.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Title 10 CFR 50.55a(f)(4) requires that ASME Boiler and Pressure Vessel Code Class 1, 2, and 3 components must meet the IST requirements of the ASME OM Code. Section 50.55a(f)(5)(ii) requires that, if a revised IST program for a facility conflicts with Technical Specifications for that facility, the licensee shall apply to the Nuclear Regulatory Commission for amendment of the Technical Specifications to conform the Technical Specification to the revised program. Therefore, in accordance with the requirements of 10 CFR 50.55a(f)(5)(ii), Calvert Cliffs is submitting this license amendment request.

Calvert Cliffs TS 5.5.8 currently references Section XI of the ASME Boiler and Pressure vessel Code, as the standard for testing frequencies and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves. The current ASME Code of Record for Calvert Cliffs. fourth ten-year IST program is the 2004 Edition of the ASME OM Code. The current fourth ten-year IST program period began July 1, 2008.

The proposed change to TS 5.5.8 will replace references to Section XI of the ASME Boiler and Pressure Vessel Code with references to the ASME OM Code to conform the TS to the current IST Program.

4.2 Precedent Below are several other facilities that have been granted approval for incorporating TSTF-479-A and TSTF-497-A into their TSs.

Facilitjy Amendment#(s) Approval Date Braidwood Station, Units 1 & 2 153 August 28, 2008 Brunswick Steam Electric Plant, Units 1 & 2 247/275 April 23, 2008 4.3 Significant Hazards Consideration Calvert Cliffs Nuclear Power Plant, Inc. is requesting an amendment to Calvert Cliffs Unit 1 and 2 Technical Specifications (TSs) that is based on incorporating Technical Specification Task Force (TSTF) 479-A and TSTF 497-A. Technical Specification Task Force-479-A and TSTF-497-A revise the Improved Standard Technical Specification administrative controls of the Inservice Testing Program for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3.

The proposed change has been evaluated against the standards of 10 CFR 50.92(c) and has been determined to not involve a significant hazards consideration in the operation of the facility in accordance with the proposed amendment as indicated below:

1. Operationof the facility in accordance with the proposed amendment would not involve a significant increase in the probabilityor consequences of an accidentpreviously evaluated.

The proposed change will replace, within TS 5.5.8, references to Section XI of ASME Boiler and Pressure Vessel Code with references to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code). In addition the proposed change adds words to TS 5.5.8.b which applies 2

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.8.a.

The proposed change is administrative, does not affect any accident initiators, does not affect the ability to successfully respond to previously evaluated accidents and does not affect radiological assumptions used in the evaluations. Thus, operation of the facility in accordance with the proposed change will not involve an increase in the probability or the consequences of an accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated.

The proposed change will replace, within TS 5.5.8 references to Section XI of ASME Boiler and Pressure Vessel Code with references to the ASME OM Code. In addition the proposed change also adds words to TS 5.5.8.b which applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.8.a.

The proposed change does not involve a modification to the physical configuration of the plant (i.e., no new equipment will be installed) or involve a change in the methods governing normal plant operation. The proposed change will not impose any new or different requirements or introduce a new accident initiator, accident precursor, or malfunction mechanism. Additionally there is no change in the types or increase in the amounts of any effluent that may be released offsite and there is no increase in individual or cumulative occupational exposure.

Therefore the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. I

3. Operation of the facility in accordancewith the proposedamendment would not involve a significant reduction in a margin of safety.

The proposed change will replace, within TS 5.5.8 references to Section XI of ASME Boiler and Pressure Vessel Code with references to the ASME OM Code. In addition the proposed change also adds words to TS 5.5.8.b which applies the extension allowance of Surveillance Requirement 3.0.2 to other normal and accelerated inservice testing frequencies of two years or less that were not included in the frequencies of the table listed in TS 5.5.8.a.

The proposed change does not involve a modification to the physical configuration of the operating units or change the methods governing normal plant operation. The proposed change incorporates revisions to the ASME Code that results in a net improvement in the measures for testing pumps and valves. The safety functions of the applicable pumps and valves will be maintained.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, Calvert Cliffs concludes that the proposed amendment 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.

3

ATTACHMENT (1)

EVALUATION OF THE PROPOSED CHANGE 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's 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

Calvert Cliffs review has determined that the proposed amendment would change an inspection requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. TSTF-479-A, Revision 0, dated December 19, 2005, Changes to Reflect Revision of 10 CFR 50.55a

2. TSTF-497-A, Revision 0, dated July 12, 2006, Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less

3. Letter. from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, dated December 6, 2005, Status of TSTF 343, 479, 482, 485

4. Letter from T.H. Boyce (NRC) to Members of the Technical Specification Task Force, dated October 4, 2006

5. Letter from Mr. J.A. Spina (CCNPP) to Document Control Desk (NRC), dated July 2, 2007, Fourth Ten-Year Inservice Test Program for Safety-Related Pumps and Valves

6. Federal Register, Volume 64, Number 183, dated September 22, 1999, 10 CFR Part 50 - Industry Codes and Standards; Amended Requirements 4

ATTACHMENT (2)

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

May 13, 2009

Programs and Manuals.

5.5 5.5 Programs and Manuals' C --Pa, r a. Testing frequencies-. 1 , Sc,,ini H elf the ASME Operdl+I DINa4tlý p t.e I, Pi,-ssu-e Yes. l and applicable .Addenda as

. follows:

". .1 "0' M- . " .

PN-l,)rS As Po.tn ASME. Bei~ler aiMd PI-331 -

PL.4A 'C'O(t--') .Vessel Code and

( )appl i ca ble Addenda termi no logy for Required Frequencies i nservi ce testing for. performing inservice acti~vit ies testing activities Weekly At least once per 7 days Monthly At least once per 31 days Quarterly or every 3 mongths At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annually .At least once per 366 days Biennially or every

2. years At least once per 731 days ctn + Fe- b. The provisions of SR 3.0.2 are applicable to the above norinAJ CIfl required FrequenciesAfor performing inservice testing activities;

. 4~c-4ea.c52et ZAefVC T&sr5 The provisions of SR 3.0.3 are applicable to inservice testing activities; and o e .,, t.c rA~iervd.

Nothing in the ASMEn-'ile -andPressure V .... l Code shall be construed.to supersede the requirements of any Technical Speci fi~cation.

5.5.9 Steam Generator (SG) Proqram A Steam:Generator Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the Steam Generator Program shall include the following provisions:

CALVERT CLIFFS - UNIT I 5.5-7 Amendment. No. 278 CALVERT CLIFFS - UNIT 2 Amendment No. 255