ML19127A076

Application to Revise Technical Specifications to Adopt TSTF-490, Deletion of E-Bar Definition and Revision to RCS Specific Activity Tech Spec

ML19127A076
Person / Time
Site:	Calvert Cliffs
Issue date:	05/06/2019
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19127A076 (27)

Text

Exelon Generation May 6, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318

Subject:

Application to Revise Technical Specifications to Adopt TSTF-490, "Deletion of E-Bar Definition and Revision to RCS Specific Activity Tech Spec" In accordance with 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests changes to the Technical Specifications (TS) of the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (CCNPP).

The proposed amendment revises the current CCNPP's TS Limiting Condition for Operations (LCO) 3.4.15 "RCS Specific Activity," and associated Surveillance Requirements (SR). The proposed changes would replace the current TS limit on Reactor Coolant System (RCS) gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent XE-133 definition that would replace the current E-Bar average disintegration energy definition. The current definition of Dose Equivalent 1-131 is also revised.

The proposed changes are consistent with NRG-approved Technical Specification Task Force (TSTF) Standard Technical Specification Traveler, TSTF-490, Revision 1, "Deletion of E-Bar Definition and Revision to RCS Specific Activity Tech Spec."

The request is subdivided as follows:

• provides a description and evaluation of the proposed change.

• provides a markup of the affected TS and associated Inserts.

• provides revisions of the affected TS Bases pages. The TS Bases pages are provided for information only and do not require NRC approval.

The proposed change has been reviewed by the Plant Operations Review Committee.

Application to Revise TS to Adopt TSTF-490 May 6, 2019 Page2 EGC requests approval of the proposed license amendment by May 6, 2020. Once approved, the amendment shall be implemented within 90 days of receipt. There are no regulatory commitments contained within this letter.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), EGC is notifying the State of Maryland of this application for license amendment by transmitting a copy of this letter and its attachments to a designated State Official.

Should you have any questions concerning this letter, please contact Enrique Villar, at (610) 765-5736.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 61h Day of May 2019.

Res71ttully, f

4-1..____:J [. ~

Jyv-James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Change

2. Markup of Proposed Technical Specification Pages

3. Revised Technical Specification Bases Pages cc:

NRC Regional Administrator, Region I NRC Senior Resident Inspector, Calvert Cliffs NRC Project Manager, Calvert Cliffs D. A. Tancabel, State of Maryland Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

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

6.0 REFERENCES

Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION In accordance with 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests changes to the Technical Specifications (TS) of the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (CCNPP).

The proposed changes would replace the current limits for primary coolant gross specific activity with limits on primary coolant noble gas activity. The noble gas activity will be based on DOSE EQUIVALENT XE-133 (DEX) and will take into account only the noble gas activity in the primary coolant. These changes were approved in an NRC Safety Evaluation (SE) dated March 19, 2007 (Reference 1 ). Technical Specification Task Force (TSTF) change traveler TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec," was announced for availability in Reference 1 as part of the Consolidated Line Item Improvement Process (CLllP). By memorandum from the Chief, Licensing Processes Branch, to the Plant Licensing Branch Chiefs, dated March 14, 2012, the NRC staff indicated that License Amendment Requests (LARs) related to TSTF-490 can be accepted for review, but will be handled through the normal LAA review process, instead of the expedited six-month CLllP schedule.

2.0 DETAILED DESCRIPTION Consistent with NRG-approved TSTF-490, Revision 0, EGC proposes the following TS changes for CCNPP:

1. Revise the definition of DOSE EQUIVALENT 1-131.

2. Delete the definition oft-AVERAGE DISINTEGRATION ENERGY.

3. Add a new TS definition for DOSE EQUIVALENT XE-133.

4. Revise LCO 3.4.15, "RCS Specific Activity," to read as follows "RCS Dose equivalent 1-133 and Dose equivalent XE-133 Specific Activity."

5. Revise LCO 3.4.15 "AP PU CAB I LITY" to specify the LCO is applicable in MODES 1, 2, 3, and 4.

6. Modify ACTIONS Table as follows:

a. Condition A is modified to delete the reference to Figure 3.14.15-1 and define an upper limit.

b. NUREG-1432 ACTIONS are reordered, moving Condition C to Condition B to be consistent with the Writer's Guide.

c. Condition B (was Condition C in NUREG-1432) is modified to provide a Condition and Required Action for DOSE EQUIVALENT XE-133 instead of gross activity of the reactor coolant. The Completion Time is changed from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

A Note allowing the applicability of LCO 3.0.4.c is added, consistent with the Note to Required Action A.1.

Page 1 of 6 Evaluation of Proposed Changes

d. Condition C (was Condition Bin NUREG-1432) is modified based on changes to Conditions A and B to reflect the change in the LCO Applicability.

7. Revise SR 3.4.15.1 to verify the limit for DOSE EQUIVALENT XE-133.

8. Revise SR 3.4.15.2 to delete the surveillance Note, "Only required to be performed in MODE 1."

9. Delete SR 3.4.15.3.

For CCNPP, a few minor variations exist within the TS compared to the TSTF that does not change the technical intent of the changes proposed.

1. A minor variation is that SR 3.4.15.2 has been revised to delete the surveillance Note, "Only required to be performed in MODE 1." Deleting this Note provides continued assessment of RCS activity for the modes of applicability since DOSE EQUIVALENT 1-131 (DEi) will no longer be limited to MODE 1 operation. Deleting this Note is consistent with other licensees that have adopted TSTF-490.

2. CCNPP uses different numbering than the improved Standard Technical Specifications (STS) for RCS Specific Activity. This difference is administrative and does not affect the applicability of TSTF-490 to the CCNPP TS.

3. The current CCNPP TS have incorporated TSTF 425, Relocate Surveillance Frequencies to Licensee via amendment 314/292 dated August 17, 2015. Therefore, the proposed pages reflect the current use of the Surveillance Frequency Control Program instead of the frequency values reflected in the TSTF-490 markup pages.

4. Reference to the NRC staff SE, dated September 27, 2006 (ML062700612) is changed to refer to the NRC staff SE in Reference 1, because the SE dated September 27, 2006, that is referred to in the model application is not publicly available. The SE posted in the Federal Register on March 19, 2007 is publicly available and approved for use.

5. For TS 3.4.15 Conditions A and B, CCNPP will replace the words 'not within limits' with the numerical limit value stated in SR 3.4.15.2 and 3.4.15.1, respectively. This variation is done to eliminate a potential human error trap for personnel.

3.0 TECHNICAL EVALUATION

EGC has reviewed References 1 and 2. EGC has applied the methodology in Reference 1 to develop the proposed TS changes. EGC has also concluded that the justifications presented in TSTF-490, Revision 0 and the model SE prepared by the NRC staff are applicable to CCNPP and justify this amendment for the incorporation of the changes to CCNPP's TS.

To assist in the NRC staff, review of this amendment request, the inputs for determining DEX limits are summarized below.

The determination of DEX is performed using effective dose conversion factors for air submersion listed in Table 111.1 of EPA Federal Guidance Report No. 12 (FGR-12) (Reference 3), as shown in Table 1 below. To normalize each radioisotope, each FGR-12 effective dose Page 2 of 6 Evaluation of Proposed Changes Page 3 of 6 conversion factor is divided by the FGR-12 effective dose conversion factor for XE-133. The resultant number is each radioisotopes equivalence factor, as shown in column 4 in Table 1.

The equivalence factors are then multiplied by the concentrations of noble gases based on 1%

failed fuel, as provided in column 2, Table 1. The nuclide concentrations are assumed to be the total sum of the degassed gamma activities and the gaseous gamma activities for each appropriate nuclide. The products for each radionuclide are then summed to come up with the DEX Technical Specification limit. The Dose Equivalent XE-133 Technical Specification limit is calculated to be 636 µCi/g; however, the DEX limit will be implemented, conservatively, as 630

µCi/g.

Table 1 - Calculation of DEX Limit for Calvert Cliffs

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability dated March 19, 2007 (Reference 1), the NRC Notice for Comment published on November 20, 2006 (Reference 2), and TSTF-490, Revision 0.

4.2 Precedent EGC is not proposing significant variations or deviations from the TS changes described in TSTF-490, Revision 0, or in the content of the NRCs model SE published in Reference 1.

The NRC has previously approved similar amendment requests to the TS for Palo Verde Nuclear Generating Station Units 1, 2, and 3 (ML13294A576); Braidwood Station Units 1 and 2 and Byron Station Units 1 and 2 (ML100690386); and Three Mile Island Nuclear Station Unit 1 (ML100320493). Submittals by these plants to request implementation of TSTF-490 were reviewed, along with corresponding requests for additional information (RAIs). The letters for issuance of amendment were also reviewed to establish the final version of the approved amendment.

Evaluation of Proposed Changes 4.3 No Significant Hazards Consideration Exelon Generation Company, LLC (EGC) has reviewed the proposed no significant hazards consideration determination published in the Federal Register on March 19, 2007 (Reference 1 ).

EGC has concluded that the proposed determination presented in the notice is applicable to Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (CCNPP), and the full determination evaluation is provided below.

The traveler and model SE discuss the applicable regulatory requirements and guidance, including the 1 O CFR 50, Appendix A, General Design Criteria (GDC). CCNPP was not licensed to the 1 O CFR 50, Appendix A, GDC. The CCNPP equivalent of the referenced GDC is provided in Appendix 1 C of the Updated Final Safety Analysis Report (UFSAR). This Section of the CCNPP UFSAR provides an analysis of plant design criteria for CCNPP to the GDC criteria.

Based on the analysis performed, EGC believes that the plant-specific requirements for CCNPP are sufficiently similar to the Appendix A, GDC and represent an adequate technical basis for adopting the proposed change.

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

Response: No.

Reactor coolant specific activity is not an initiator for any accident previously evaluated.

The Completion Time when primary coolant gross activity is not within limit is not an initiator for any accident previously evaluated. The current variable limit on primary coolant iodine concentration is not an initiator to any accident previously evaluated. As a result, the proposed change does not significantly increase the probability of an accident. The proposed change will limit primary coolant noble gases to concentrations consistent with the accident analyses. The proposed change to the Completion Time has no impact on the consequences of any design basis accident since the consequences of an accident during the extended Completion Time are the same as the consequences of an accident during the Completion Time. As a result, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences 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?

Response: No.

The proposed change in specific activity limits does not alter any physical part of the plant nor does it affect any plant operating parameter. The change does not create the potential for a new or different kind of accident from any previously calculated.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 4 of 6 Evaluation of Proposed Changes

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

Response: No.

The proposed change revises the limits on noble gas radioactivity in the primary coolant.

The proposed change is consistent with the assumptions in the safety analyses and will ensure the monitored values protect the initial assumptions in the safety analyses.

Based upon the reasoning presented above and the previous discussion of the amendment request, the requested change does not involve a significant hazards consideration.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 1 O 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'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

EGC has reviewed the environmental consideration included in the model SE published in the Federal Register on March 19, 2007 (Reference 1 ). EGC has concluded that the NRC's findings presented therein are applicable to CCNPP and the full determination is provided below.

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 1 O CFR Part 20 or surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published March 19, 2007 (Reference 1 ). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 1 O CFR 51.22(c)(9).

Pursuant to 1 O CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Page 5 of 6

6.0 REFERENCES

Evaluation of Proposed Changes

1.

Federal Register Notice of Availability published on March 19, 2007, 72 FR 12838, "Notice of Availability of Model Application Concerning Technical Specification Improvement Regarding Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification Using the Consolidated Line Item Improvement Process."

2.

Federal Register Notice for Comment published on November 20, 2006, 71 FR 67170, "Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification; Babcock and Wilcox Pressurized Water Reactors, Westinghouse Pressurized Water Reactors, Combustion Engineering Pressurized Water Reactors Using the Consolidated Line Item Improvement Process."

3.

Federal Guidance Report No. 12, "External Exposure to Radionuclides in Air, Water, and Soil," 1993.

Page 6 of 6 Markup of Technical Specification Pages and Associated Inserts Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Facility Operating License Nos. DPR-53 and DPR-69 REVISED TECHNICAL SPECIFICATION PAGES 1.1-2 1.1-3 3.4.15-1 3.4.15-2 3.4.15-3 3.4.15-4

1.1 Definitions CHANNEL FUNCTIONAL TEST CORE OPERATING LIMITS REPORT (COLR}

DOSE EQUIVALENT I-131 Definitions 1.1 indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

A CHANNEL FUNCTIONAL TEST shall be:

Analog Channels - the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY.

Bistable Channels - the injection of a simulated signal into the channel sensor to verify OPERABILITY of all devices in the channel required for channel OPERABILITY.

The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping or total channel steps.

The COLR is the unit specific document that provides cycle specific parameter limits for the current reload cycle.

These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5.

Plant operation within these limits is addressed in individual Specifications.

goae eQYI'.lJ\\beNT I 131 shall be that concentration of I 131 (microcuries/gram) that alone would produce the same thyrgid dose as the ~uantity and

!INSERT 1

')-is9topic mixture of I 131, I 132, I 133, I 134, 1-------:7 and I 135 actually present, The Hg& (Total effective Cose li~uivalent) inhalatign dose cgnversion factors used fgr this calculatign shall be those listed in Table 2.1 in the column headed "effective" gf ~ederal Guidance Report 11, ORNb, 1988, "limiting Values of Radionuclide Intake and CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 1.1-2 Amendment No. 286 Amendment No. 263

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT XE-133 Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."

OISINTiGRATION

~ shall be the average (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per INSERT 2 disintegration (in MeV) for isotopes, other than iodines, with half lives > 15 minutes, making up at least 95% of the total non iodine activity in the coolant.

ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc. ). Times shall include diesel generator starting and sequence loading delays, where applicable.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

INSERVICE TESTING PROGRAM La CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.SSa(f).

The maximum allowable containment leakage rate, La, shall be 0.16% of containment air weight per day at the calculated peak containment pressure (Pa).

1.1-3 Amendment No. 320 Amendment No. 298

,--.....,....,,,....,,....,,...,,.~~..,,_...,....,.~~.,..,,...,_..........,...,,,....,,,...,,,..,,,~~~...,....,.~~~~~--:~..._~..._...... *fic Activity RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity.

3.4.15 3.4 REACTOR COOLANT SYST 3.4.15 RCS LCO 3.4.15 The specific activity of the reactor coolaRt shall be within limits.

MODES 1, 2, 3 and 4, APPLICABILITY:

MODI! 3 with RCS average temperat1:1re (T~ ~ W012-F-r ACTIONS CONDITION A.

DOSE EQUIVALENT I-131 >

0.5 µCi/gm.

js 30 µCi/gm.

I I

REQUIRED ACTION

---

NOTE -----------

LCO 3.0.4.c is applicable.

A.1 Verify DOSE EQUIVALENT I-131

~Jithin the acceptable regioR of Fig1:1re :L 4.15 1.

COMPLETION TIME Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> A. 2 Restore DOSE we hours EQUIVALENT I-131 to within limit.

CALVERT CLIFFS - UNIT 1 3.4.15-1 Amendment No. 281 CALVERT CLIFFS - UNIT 2 Amendment No. 258

ACTIONS (continued)

RCS Specific Activity 3.4.15 CONDITION REQUIRED ACTION COMPLETION B.

ReqYiPeGI Action an GI B.1 Qe in MOOe 3 associated

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Completion Time of

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EQYIVAbeNT I 131~"

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Pegion of i;;,igype 3.4.15 1.

c.

GPOSS acti>.iit~ of c.1 Qe in MODI! 3 the PeactoP coolant

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not within limit, SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.15.1 Verify reactor coolant

~~~~µCi/gm.

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with

'IJith TIME 6 hOYPS 6 hOYPS FREQUENCY In accordance with the Surveillance Frequency Control Program

'yoosE EQUIVALENT XE-133 specific CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.4.15-2 Amendment No. 314 Amendment No. 292

RCS Specific Activity 3.4.15 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.15.2 SURVEILLANCE FREQUENCY NOTE ORly PCqHired to be performed iA MODE 1.

Verify reactor coolant DOSE In accordance EQUIVALENT I-131 specific activity ~ 0.5 with the

µCi/gm.

Surveillance

---

NOTE----------------

Not required to be performed until ays after a minimum of 2 effective full er days and 20 days of MODE operation ve elapsed since t eactor was last subcr *cal for >

hours.

m a sample t n in r a minimum of 2 effe ve ower days and 20 days of MODE eration have elapsed since the reactor was last subcritical for ~ 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Frequency Control Program Between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after THERMAL POWER change of

~ 15% RTP within a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> period In accordance with the Surveillance requency Co ol CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.4.15-3 Amendment No. 314 Amendment No. 292

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30 40 50 60 70 BO 90 100 PERCENT OF RATED THERMAl. POWER Figure 3.4.15-1 (page 1 of 1) tor Coolant DOSE EQUIVALENT I-131 Specific Activity Limi ersus Percent of RATED THERMAL POWER With Reactor Coolant Specific Activity ~ 0.5 µCi/gm DOSE EQUIVALENT I-131 CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 3.4.15-4 Amendment No. 281 Amendment No. 258 I

INSERT 1:

DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries per gram) that alone would produce the same dose when inhaled as the combined activities of iodine isotopes of I-131, I-132, I-133, I-134, and I-135 actually present. The determination DOSE EQUIVALENT I-131 shall be performed using Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal Guidance Report No. 11.

INSERT2:

DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity.

The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, "External Exposure to Radionuclides in Air, Water, and Soil."

INSERT3 CONDITION REQUIRED ACTION COMPLETION TIME

---

Note ----------

B.

DOSE EQUIVALENT XE-LCO 3.0.4.c is applicable.

133 > 630 µCi/gm 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> B.1 Restore DOSE EQUIVALENT XE-133 to within limit.

c.

Required Action and C.1 Be in MODE 3 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated AND Completion Time of C.2 Be in MODE 5 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition A or B not met.

OR DOSE EQUIVALENT I-131 >

30 µCi/gm.

Markup of Technical Specification Bases Pages and Associated Notes Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Facility Operating License Nos. DPR-53 and DPR-69 REVISED TECHNICAL SPECIFICATION BASES PAGES B 3.4.15-1 B 3.4.15-2 B 3.4.15-3 B 3.4.15-4 B 3.4.15-5 B 3.4.15-6

RCS Specific Activity B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Specific Activity BASES BACKGROUND DOSE EQUIVALENT XE-133 APPLICABLE SAFETY ANALYSIS

, 0.5 µCi/gm DOSE EQUIVALENT 1-131.

Title 10 CFR 50.67 and Reference 2 specify the maximum TEDE an individual at the exclusion area boundary can receive for two hours and that individuals in the low population zone and the Control Room can receive over 30 days during an accident. The limits on specific activity ensure that the doses are held to within the acceptance criteria given in Reference 1, Chapter 14, during analyzed transients and accidents.

The RCS specific activity LCO limits th~ allowable concentration level of radionuclides in the reactor coolant.

The LCO limits are established to minimize the offsite and Control Room radioactivity dose consequences in the event of a SGTR accident.

The LCO limits also impact, to a much lesser extent, other transients such as the maximum hypothetical accident, the seized rotor event, the main steam line break, and the Control Element Assembly Ejection event.

specific activity limits for both DOSE EQUIVALENT I-131 a gross activity.

The allowable levels are intended to limit the dose at the exclusion area boundary and the Control Room to within the acceptance criteria given in Reference 1, Chapter 14.

The LCO limits on the specific activity of the reactor coolant ensure that the resulting doses at the exclusion area boundary or in the Control Room will not exceed the acceptance criteria given in Reference l, Chapter 14.

The GTR safety analysis (Reference 1, Section 14.15) assumes th

~pecific activity of the reactor coolant at the LCO limi~ including either a Preaccident Iodine Spike or a Concurrent Iodine Spike and assumes that all of t~ 200 gpd primary to secondary l~ kage is to the unaffected G, since primary to secondary fl w through the ruptured SG ube has already been maximized.

(by a factor of 335)

CALVERT CLIFFS - UNITS.1 & 2 B 3.4.15-1 Revision 58

BASES Insert NOTE 1 RCS Specific Activity B 3.4.15 the atmespheric dump valves aRd the maiR steam safety valves.

The safety aRalysis shews the radielegical ceRsequeRces of aR SGTR accideRt, are withiA the RefereRce 1, Chapter 1q acceptaRce criteria. OperatieA with iediRe specific activity levels greater thaR the LCO limit is permissible, if the activity levels de Ret exceed the limits shewA iR Figure 3,q.l§ 1 fer mere thaR 100 heurs.

The remaiRder ef the abeve limit permissible iodiRe levels shewR iR Figure 3.q,15 1, are acceptable because of the lew probability of aA SGTR accideRt occurriRg duriRg the established 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> time limit.

The occurreRce of aR SGTR accideAt at these permissible levels could iRcrease the fXclusioR area beuREiary dose levels beyeRd the acceptaRce

~riteria giveR iR RefereRce 1, Chapter 1q.

'V Other accidents or transients, such as a main steam line break, a seized rotor event, and a control element assembly ejection event, involve a partial release of the primary activity via Technical Specification primary-to-secondary leakage limits and subsequent steam release to the atmosphere via the atmospheric dump valves and main steam safety valves.

As a result of the blowdown during a loss of coolant accident, the maximum hypothetical accident also accounts for release of primary activity via the hydrogen purge pathway.

These releases contribute to the offsite and Control Room doses listed in Reference 1, Chapter 14.

These accident analyses show that the radiological consequences of a OBA do not exceed the acceptance criteria given in References 1, Chapter 14 and Reference 2.

Reactor Cool ant System specific activity sati s,..........__.,_ ___ -.,..,,,__.....,

10 CFR 50. 36 ( c) (2) (ii), Criterion 2.

noble gas specific LCO The specific activity is limi to 0.5 µCi/gm DOSE

.----------.EQUIVALENT I-131, and the~ activity in the primary 630 µCi/gm DOSE EQUIVALENT XE-133 cool an 1 s the Rumber ef i:tCi /gm equal to 100

...._ ______ ___. divided by I (average di si Ategrati OR eRergy of the sum of the average beta aRd ga!mla eRergies of the coolaRt nuclides).

The limits on DOSE EQUIVALENT I-131 and Q-FG-S-S-activity ensure the TEDE dose to an individual at he DOSE EQUIVALENT XE-133 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-2 Revision 58

BASES RCS Specific Activity B 3.4.15 exclusion area boundary during the OBA will be within the acceptance criteria given in Reference l, Chapter 14.

+Re limit on gross activity ens1:Jres the whole body dose to an i ndi vi d1:Jal at tl:ie excl 1:1si on area 801:Jndary d1:Jri ng the OBA will ee within the acceptance criteria given in Reference 1, Chapter 14.

The SGTR accident analysis (Reference 1, Section 14.15) shows that the exclusion area boundary and Control Room dose levels are within acceptable limits. Violation of the LCO may result in reactor coolant radioactivity levels that could, in the event of an SGTR, lead to exclusion area boundary and Control Room doses that exceed the Reference 1, Chapter 14 acceptance criteria.

APPLICABILITY

/1n MODEs 1 and 2, and in MODE 3 \\'8ith RCS average temperat1:Jre

!Insert NOTE 2 tJ ~ 500°F, operation within the LCO 1 imits for DOSE EQUIVJl,LENT I 131 and gross activity is necessary to contain the potential conseq1:Jences of an SGTR to within the acceptable excl1:Jsion area bo1:Jndary and Control Room dose values, ACTIONS For operation in MODE 3 witl:i RCS average temperature

~ 500°F, and in MODEs 4 and 5, tl:ie release of radioactivity in tl:ie event of an SGTR is 1:Jnlikely since the saturation press1:Jre of the reactor coolant is below the lift pressure settings of the atmospheric dump valves and main steam safety valves.

A.1 and A.2 that the specific activity is s 30 µCi/gm DOSE EQUIVALENT 1-131.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is acceptable With the DOSE QUIVALENT 1-131 greater than the LCO limit, since it is expected that samples at

• terval s of four hours must be taken to the normal coolant demonstrate the 1 imits of Figure 3. 4.15 1 are not exceeded.

iodine concentration The Completion Time of four hours is required to obtain and would be restored analyze a sample.

~8 within this time period.

Also. there is a low continue for trending. The DOSE UIVALENT probability of a SLB or stored to within limits, within lOO hours.

SGTR occurring during The Completion Time o 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> is required if tt:1e limit this time period.

violation resulted from normal iodine spiking, A Note permits the use of the provisions of LCO 3.0.4.c.

This allowance permits entry into the applicable MODE(s)

CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-3 Revision 58

BASES A.1 and A.2 while the DOSE EQUIVALENT 1-131 LCO limit is not met.

RCS Specific Activity B 3.4.15 while re y1ng on This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient DOSE EQUIVALENT I-131 specific activity excursions while the plant remains at, or proceeds to power operation.

B.1

!Insert NOTE 3 ~f a Reqt:Ji reel Action anel associ ateel Completion Time of CoRelitioR A is not met or if the QOSf fQUIVALENT I 131 is iR the YRacceptable region of Vigt:Jre 3.4.1§ 1, the reactor mYst be brot:Jght to MOQE 3 with RCS average temperatt:Jre ~ ~

withiR six hot:Jrs.

The alloweet Completion Time of six hot:Jrs is reqt:Jireel to reach MOQf 3 below §002F withot:Jt challeRgiRg plaRt systems.

jlnsert NOTE 4 SURVEILLANCE REQUIREMENTS This Llland C.2 I j-;rWith tl:ie gross activity iR excess of the allo11Jeel limit, tl:ie uRit mt:Jst be placeel iR a MOQf iR wl:iicl:i the reqt:JiremeRt eloes not apply.

The cl:iange withiR six hot:Jrs to MOQf 3 aREI RCS average temperatt:Jre <: §QQ2F lowers the satt:JratioR presst:Jre of the reactor coolant below the setpoiRts of the maiR steam safety valves aREI preveRts veRting the SG to the eRviroRmeRt iR aR SGTR eveRt.

The alloweel Completion Time of six hot:Jrs is reqt:Jireet to reach MOQE 3 below §Q02V from ft:Jll power conelitioRs aREI withot:Jt cl:ialleRQiRg plaRt systems.

SR 3.4.15.1 noble gas specific The SR require performing a gamma isotopic analysis, as a measure of the ~

activity of the reactor coolant.

WR4+e E

dffllitt--Hri:l-&6H-H~ measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken.

This SR provides an indication of any increase in the noble gas specific CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-4 Revision 58

BASES RCS Specific Activity B 3.4.15 Trending the results of this SR allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions.

The SR is applicable in MODEs 1 and 2, and in MODE 3 with RCS average temperat1::1re at least 500gF, The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

!Insert NOTE 5

~

SR 3.4.15.2 This SR is performed to ensure iodine remains within limits during normal operation and following fast power changes when fuel failure is more apt to occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The Frequency, between two hours and six hours after a power change of ~ 15% RTP within a one hour period, is established because the iodine levels peak during this time following fuel failure; samples at other times would provide inaccurate results.

The SR is modified by a Note which req1::1ires the s1::1rveillance test to only be performed in MODE 1, This is req1::1ired beca1::1se the level of fission prodYcts generated in other MODEs is m1::1ch less. Also, f1::1el fail1::1res associated with fast power changes is more apt to occ1::1r in MODE 1 than in MODEs 2 and 3.

SR 3,4,1§.3 A radiochemical analysis for E determination is req1::1ired with the plant operating in MODE 1 eqYilibri1::1m conditions.

+he E determination directly rel ates to the LCO and is req1::1ired to verify plant operation within the specified gross activity LCO limit. The analysis for i is a meas1::1rement of the average energies per disintegration for isotopes with half lives longer than 15 min1::1tes, excl1::1ding iodines.

The S1::1rveillance Freq1::1ency is controlled 1::1nder the S1::1rveillance Freq1::1ency Control Program.

This SR has been modified by a Note that indicates sampling is not req1::1ired to be performed 1::1ntil 31 days after 2 effective f1::1ll power days and 20 days of MODE 1 operation have elapsed since the reactor was last s1::1bcritical for

~ 48 ho1::1rs.

This ens1::1res the radioactive materials are at CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-5 Revision 58

BASES REFERENCES RCS Specific Activity B 3.4.15 equilibrium so that analysis for f is representative and not skewed ey a crud eurst or other similar asnormal event.

1.

UFSAR

2.

Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000 CALVERT CLIFFS - UNITS 1 & 2 B 3.4.15-6 Revision 58

NOTE 1:

The analyses for the MSLB and SGTR accidents establish the acceptance limits for RCS activity. Reference to these analyses is used to assess changes to the unit that could affect RCS activity, as they relate to the acceptance limits. The SGTR accident results in larger offsite consequences compared to MSLB.

The SGTR analysis assumes a limiting double-ended tube break in excess of charging pump capacities. The flow of primary coolant to secondary of the ruptured generator results in a reactor trip on TM/LP, followed by a turbine trip. Analyses performed demonstrate that the DNB SAFDL is not exceeded, and since there are no associated appreciable power increases, there is no fuel damage postulated to occur. The analysis further assumes the turbine bypass valves are not available resulting in a rise in pressure in the ruptured SG that causes radioactively contaminated steam to discharge to the atmosphere through the Atmospheric Dump Valves (ADVs) and the Main Steam Safety Valves (MSSVs) in order to maintain secondary pressure.

Once the operator identifies the event, the operator initiates cooldown of the RCS. The ADV of the intact SG is assumed to be isolated at the beginning of the event for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> due to single failure. Thus, the initial cooldown is carried out using the ADV of the ruptured SG only, which increases the release of radioactive steam. After 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the operator isolates the ADV of the ruptured SG ad continues cooling down using the ADV on the intact SG. The intact SG continues to remove core decay heat by venting steam until the cooldown ends and the Shutdown Cooling (SOC) system is placed in service.

The MSLB radiological analysis assumes that offsite power is lost with the turbine trip. The affected SG blows down completely and steam is vented directly to the atmosphere.

The MSLB radiological analysis further assumes that the transient results in 0.80% failed fuel.

Operation with iodine specific activity levels greater than the LCO limit is permissible for up 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, if the activity levels do not exceed 30.0 µCi/gm.

NOTE 2:

In MODEs 1, 2, 3 and 4, operation within the LCO limits for DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 is necessary to contain the potential consequences of an SGTR to within the acceptable exclusion area boundary and Control Room dose values.

In MODEs 5 and 6, the steam generators are not being used for decay heat removal, the RCS and steam generators are depressurized, and primary to secondary leakage is minimal.

Therefore, the monitoring of RCS specific activity is not required.

NOTE 3:

With the DOSE EQUIVALENT XE-133 greaterthan the LCO limit, DOSE EQUIVALENT XE-133 must be restored to within limit within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is acceptable since it is expected that, if there were a noble gas spike, the normal coolant noble gas concentration would be restored within this time period. Also, there is a low probability of a SLB or SGTR occurring during this time period.

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODES(s), relying on Required Action 8.1 while the DOSE EQUIVALENT XE-133 LCO limit is not met. This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient-specific activity excursions while the plant remains at, or proceeds to, power operation.

NOTE4:

If the Required Action and associated Completion Time of Condition A or B is not met, or if the DOSE EQUIVALENT 1-131 is> 30 µCi/gm, the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

NOTE 5:

Due to the inherent difficulty in detecting Kr-85 in a reactor coolant sample due to masking from radioisotopes with similar decay energies, such as F-18 and 1-134, it is acceptable to include the minimum detectable activity for Kr-85 in the SR 3.4.15.1 calculation. If a specific noble gas nuclide listed in the definition of DOSE EQUIVALENT XE-133 is not detected, it should be assumed to be present at the minimum detectable activity.