Text

License Amendment Request - Change to Surveillance Requirement 3.5.3.1
	ML16035A227
Person / Time
Site:	Calvert Cliffs
Issue date:	02/04/2016
From:	David Gudger; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML16035A227 (10)
	v • d • e

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 February 4, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318

Subject:

License Amendment Request - Change to Surveillance Requirement 3.5.3.1 In accordance with 10 CFR 50. 90, Application for amendment of license, construction permit, 11 or early site permit, Exelon Generation Company, LLC (Exelon) is submitting a request for amendment to the Technical Specifications (TS). The proposed amendment corrects an administrative error in the License Amendment Request (LAA) submitted in accordance with Technical Specification Task Force Traveler 523, Generic Letter 2008-01, Managing Gas Accumulation. The propose~ change will include newly added Surveillance Requirement 11 (SR) 3.5.2.10 in the list of applicable Surveillances of SR 3.5.3.1.

Consistent with Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," dated December 29, 1998, Calvert Cliffs Nuclear Power Plant has implemented administrative controls to include SR 3.5.2.10 in SR 3.5.3.1, while processing this amendment request.

There are no regulatory commitments contained in this letter. Exelon requests approval of the proposed license amendment by February 4, 2017, with the amendment being implemented within 60 days.

These proposed changes have been reviewed by the Plant Operations Review Committee and approved in accordance with Nuclear Safety Review Board procedures.

In accordance with 10 CFR 50.91, "Notice for public comment; state consultation," a copy of this application, with attachments, is being provided to the designated State Official.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of February 2016.

License Amendment Request Change to Surveillance Requirement 3.5.3.1 Docket Nos. 50-317 and 50-318 February 4, 2016 Page2 If you should have any questions regarding this submittal, please contact Enrique Villar at 61 0-765-5736.

Respectfully, David T. Gudger Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Change

2. Marked-up Technical Specifications Page cc: NRG Regional Administrator, Region I w/attachments NRG Senior Resident Inspector, CCNPP "

NRG Project Manager, NRR, GCNPP "

S. T. Gray, State of Maryland "

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGE

ATIACHMENT1 EVALUATION OF PROPOSED CHANGE

Subject:

License Amendment Request to Relocate Surveillance Frequency Requirements 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedence 4.3 No Significant Hazards Consideration 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

License Amendment Request Attachment 1 Change to Surveillance Requirement 3.5.3.1 Page 1 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit, 11 Exelon Generation Company, LLC (Exelon), proposes a change to the Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2, Technical Specifications (TS) Appendix A of Renewed Facility Operating License Nos. DPR-53 and DPR-69.

Specifically Exelon proposes to add Surveillance Requirement (SR) 3.5.2.10 to the list of applicable Surveillances for SR 3.5.3.1.

SURVEILLANCE FREQUENCY SR 3.5.3.1 The HPSI train related portions of the In accordance with train following Surveillance Applicable Requirements are applicable: Surveillance Requirements SR 3.5.2.1 SR 3.5.2.5 SR 3.5.2.2 SR 3.5.2.6 SR 3.5.2.3 SR 3.5.2.8

[SR 3.5.2.1 O]

2.0 DETAILED DESCRIPTION On July 30, 2015, the U.S. Nuclear Regulatory Commission (NRG) issued Amendments 313 and 291 approving the implementation of Technical Specifications Task Force Traveler TSTF-523," Generic Letter 2008-01 , Managing Gas Accumulation" (TSTF-523) for CCNPP, Units 1 and 2 (Reference 1).

Specifically, TSTF-523 modified CCNPP, Units 1 and 2 TS Limiting Condition For Operation (LCO) 3.5.2, "ECCS - Operating," by adding a Surveillance Requirement (SR). The new SR requires that Emergency Core Cooling System (ECCS) locations susceptible to gas accumulations be verified sufficiently filled with water.

Prior to approval of Amendments 313 and 291, Calvert Cliffs TS did not contain a SR for determining if the pipes were filled with water. The Combustion Engineering Standard Technical Specifications (CE STS) contained an existing SR (SR 3.5.2.3) addressing the condition. The CE STS SR 3.5.3.1 already contained SR 3.5.2.3.

Therefore, since TSTF-523 was modeled on the CE STS, it did not need to contain a change to SR 3.5.3.1. Exelon failed to identify that the addition of a new SR should result in a change to SR 3.5.3.1 to capture the new SR.

Consistent with Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety," dated December 29, 1998; Calvert Cliffs Nuclear Power Plant has implemented administrative controls to include SR 3.5.2.1 O in SR 3.5.3.1, while processing this amendment request

License Amendment Request Attachment 1 Change to Surveillance Requirement 3.5.3.1 Page 2 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes

3.0 TECHNICAL EVALUATION

This License Amendment Request (LAR) is purely an administrative change to correct the oversight stated in Section 2.0 above.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change is: 1) consistent with TSTF-523, which has been approved by the NRC for CCNPP, Units 1 and 2; 2) meets the requirements under 10 CFR 50.36

(Technical specifications"); and 3) is consistent with the defense in depth philosophy of Regulatory Guide 1.174.

4.2 Precedence None 4.3 No Significant Hazards Consideration This License Amendment Request (LAR) will add Surveillance Requirement (SR) 3.5.2.1 O to the list of applicable Surveillances for SR 3.5.3.1. Prior to approval of Amendments 313 and 291, Calvert Cliffs TS did not contain a SR for determining if the pipes were filled with water. The Combustion Engineering Standard Technical Specifications (CE STS) contained an existing SR (SR 3.5.2.3) addressing the condition.

The CE STS SR 3.5.3.1 already contained SR 3.5.2.3. Therefore, since TSTF-523 was modeled on the CE STS, it did not need to contain a change to SR 3.5.3.1. Exelon failed to identify that the addition of a new SR should result in a change to SR 3.5.3.1 to capture the new SR.

Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment 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 any accident previously evaluated?

Response: No The proposed LAR is purely an administrative change; therefore, the probability of any accident previously evaluated is not significantly increased. The systems and components required by the TS for which SR 3.5.2.1 O is applicable, continue to be operable and capable of performing any mitigation function assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly increased.

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

License Amendment Request Attachment 1 Change to Surveillance Requirement 3.5.3.1 Page 3 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes

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

Response: No The proposed LAR is purely an administrative change. The proposed change to add SR 3.5.2.1 O to the list of applicable surveillances in SR 3.5.3.1 does not create a new or different kind of accident previously evaluated.

The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements.

The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.

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?

Response: No The proposed LAR is purely an administrative change to add SR 3.5.2.10 to the list of applicable surveillances in SR 3.5.3.1.

The design, operation, testing methods, and acceptance criteria for systems, structures, and components (SSCs), specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the Final Safety Analysis Report and Bases to TS). Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

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

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

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve: (i) a significant

License Amendment Request Attachment 1 Change to Surveillance Requirement 3.5.3.1 Page 4 of 4 Docket Nos. 50-317 and 50-318 Evaluation of Proposed Changes hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent 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. Letter from U.S. Nuclear Regulatory Commission to David T. Gudger (Exelon Generation Company, LLC), Issuance of Amendments Regarding Implementation of Technical Specification Task Force Traveler 523, Generic Letter 2008-01, Managing Gas Accumulation," dated July 30, 2015.

ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATIONS PAGES

ECCS - Shutdown 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 The HPSI train related portions of the train In accordance following Surveillance Requirements are with applicable applicable: Surveillance

~Requirements SR 3.5.2.1 SR 3.5.2.5 ~

SR 3.5.2.2 SR 3.5.2.6 SR 3.5.2.3 SR 3.5.2.8 CALVERT CLIFFS - UNIT 1 3.5.3-2 Amendment No.~

CALVERT CLIFFS - UNIT 2 Amendment No.~