ML20058K283
ML20058K283 | |
Person / Time | |
---|---|
Site: | Calvert Cliffs ![]() |
Issue date: | 12/08/1993 |
From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
Shared Package | |
ML20058K284 | List: |
References | |
NUDOCS 9312150087 | |
Download: ML20058K283 (10) | |
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BALTIMORE l
GAS AND ELECTRIC 1650 CALVERT CLIFFS PARKWAY. LUSBY. MARYLAND 20657-4702 l
.70BERT E. DENTON Vict PRESIDENT December 8,1993 i
NUCLEAR ENERGY (4io) aso-44ss U. S. Nuclear Regul. tory Commission j
Washington,DC 20555 A'ITENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant l
Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Reauest: Content of the Desien Features Section l
REFERENCES:
(a)
Nuclear Regulatory Commiss:on's Final Policy Statement on l
Technical Specifications Improvements for Nuclear Power Reactors, dated July 16,1993 (b)
Letter from W. T. Russell, Assoc. Director for Inspection and i
Technical Assessment, (NRC), to Ow er's Groups Technical Specifications Committee Chairmen, Content of Standard Technical i
Specifications, Section 5.0, Administrative Controls, dated October 25,1993 (c)
NUREG-1432, Standard Technical Specifications for Combustion i
Engineering Plants, September 1992 i
Pursuant to 10 CFR 50.90, the Baltimore Gas and Electric Company (BG&E hereby requests an Amendment to Operating License Nos. DPR-53 and DPR-69 by the incorpor)ati 4
described below into the Technical Specifications for Calvert Cliffs Unit Nos. I and 2.
DESCRIPTION I
References (a) and (b) provide criteria developed by the NRC Staff used to determine what regulatory requircrrients are appropriate for inclusion in licensee Technical Specifications.
Reference (a) describes the four criteria which are applicable to the Safety Limits, Limiting Conditions for Operation, and Surveillance Requirements.
Reference (b) describes two criteria which are applicable to the administrative controls contained in technical specifications. Rese two l
references provide criteria for four of the five technical specification categories required by 10 CFR 50.36(c). The remaining section without criteria is " Design Features."
As an active participant in the industry-NRC improved Standard Technical Specifications l
implementation effort, BG&E volunteered to develop criteria for determining what requirem j
are appropriate for inclusion in the Design Features section of the Technical Specifications, and to i
submit a lead plant license amendment applying those criteria. This proposed license amendment justifies the adoption of the " Design Features" section of the Combustion Engineering Stand ehhg7h
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4 Document Control Desk December 8,1993 Page 2 Technical Specifications (STS) (Reference c) for Calvert Cliffs, and then applies the developed criteria to the STS.
CRITERIA DEVELOPMENT i
A review of the authorizing legislation for nuclear power plants reveals only one legislative reference i
to technical specifications. The Atomic Energy Act of 1954, Section 182.a," License Applications,"
states in part:
"In connection with applications for licenses to operate production or utilization facilities, the applicant shall state such technical specifications, including information of the amount, kind, and source of special nuclear material required, the place of the use, the specific characteristics of the facility, and such other information as the Commission may, by rule or regulation, deem necessary in order to enable it to find that the utilization or production of special nuclear material will be in accord with the common defense and security of the public. Such technical specifications shall be a part of any license issued."
The amount, kind, and source of special nuclear material required, and the place of the use are only described in the Design Features section of licensee Technical Specifications. De specific characteristics of the facility are described in the Safety Limits, Limiting Conditions for Operation, and Surveillance Requirements sections. A review of the Commission's rules and regulations has found no requirement for specific information to be included in the Design Features section of the Technical Specifications, except for 10 CFR 50.36(c).
10 CFR 50.36(c), " Technical Specifications," states, in part:
(c)
Technical specifications will include items in the following categories:
(1)
Safety limits...
(2)
Limiting conditions for operation...
(3)
Surveillance requirements...
(4)
Design features. Design features to be included are those features of the i
facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in paragraphs (c) (1), (2), and (3) of this section.
(5)
Administrative controls...
10 CFR 50.36 was published in the Federal Register on December 17,1968 (33FR10923). The Statements of Consideration give no further definition or explanation of the purpose or content of the Design Features section. We believe that 10 CFR 50.36(c)(4) is not meant to supersede 10 CFR 50.59," Changes, Tests, and Experiments." Features of the facility which are described in the Updated Final Safety Analysis Report (UFSAR) must be reviewed under the criteria of 10 CFR 50.59 when changed. The 10 CFR 50.59 criteria for determining if a change is an unreviewed safety question are similar to the,"if altered or modified would have a significant impact on safety" criteria in 10 CFR 50.36(c). Changes which are determined to be an unreviewed safety question under 10 CFR 50.59 are required to be approved by the Commission under 10 CFR 50.92,
" License Amendments." Therefore, changes to features described in the UFSAR which have a significant impact on safety mult in a license amendment exactly as would be required if changes are
Document Control Desk December 8,1993 Page 3 made to features described in the Design Features section. Also note that 10 CFR 50.36(c)(4) applies to features that, if altered or modified, would have an impact on safety.10 CFR 50.59 applies to changes which may have an impact on safety. From this we infer that the Design Features section should only contain those requirements that are so critical in their design that any change would affect a safety function. Therefore, we propose to define the phrase "significant impact on safety" found in 10 CFR 50.36(c)(4) as meaning those features for which any change would have such an immediate and significant impact on safety that control under 10 CFR 50.59 is not appropriate.
t Therefore, we propose that the criteria for determining what requirements should be placed in the_
Design Features section of the Technical Specifications be:
1.
He amount, kind, and source of special nuclear material required; 2.
The place of the use of the special nuclear material; and f
3.
Those features of the facility such as materials of corstruction and geometric arrangements, i
which,if altered or modified, would have an immed ate and significant effect on safety and are not covered in the safety limits, limiting conditions for operation or surveillance requirements of the Technical Specifications.
JUSTIFICATION OF CIIANGES In its Final Policy Statement on Technical Specifications Improvements (Reference a), the Commission encouraged licensees to use the improved STS as a basis for plant-specific license amendments. The STS for Combustion Engineering plants is NUREG-1432 (Reference (c).
Following the Commission's policy, we propose to adopt the STS format and content of the Design Features section for Calvert Cliffs Units 1 and 2.
Individual changes are justified below.
Furthermore, we have applied the criteria described above to the STS Design Features section and have proposed changes to the STS based on that application. A section.by-section comparison of the Calvert Cliffs Technical Specifications, the STS, and the proposed Design Features criteria is given below.
Section 5.1 Site i
i Sections 5.1.1 and 5.1.2 contain maps of the site boundary and low population zones, respectively.
j These maps also show the major structures, effluent release points, meteorologicd tower location, i
and the minimum exclusion area radius. De STS requires inclusion of the site and exclusion area boundaries and the low population zone and allows descriptions instead of maps. These maps or descriptions do not meet any of the criteria. However, Criteria 2 requires that the place of use of the special nuclear material be described. We propose to delete the existing Sections 5.1.1 and 5.1.2 and to create Section 5.1 emitled " Site Ixcation," and to include a text description of the location of the site as shown in Attachments (1) and (2).
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The information contained in the existing Calvert Cliffs Section 5.1.1 and 5.1.2, and the associated maps, will be maintained in the UFSAR and controlled under 10 CFR 50.59. The Standard Review Plan (NUREG-0800) recommends that the s:te boundary, low population zone, and exclusion area boundary be specified in Chapter 2 of the UFSAR. We will place these maps in the appropriate sections of Chapter 2 of our UFSAR. The additionalinformation contained on the Calvert Cliffs site map is currently in the UFSAR: major structures (Figure 1.2, " Plant Property and Buildings"),
effluent release points (Section 11, " Waste Processing"), and the minimum exclusion area radius
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Document Control Desk December 8,1993 Page 4 i
(Sections 2.1, " General Description"). The meteorological tower location will be shown on the site boundary map which is being placed in the UFSAR. Changes to the maps and other information can be adequately controlled under 10CFR 50.59, and climination of this information from the Technical Specifications will not have an impact on plant safety.
Section 5.2 Containment l
The " Containment" section does not meet Criteria 1,2 or 3 in that modification of the containment l
would not create an immediate and significar.1 effect on safety. Furthermore, containment integrity is covered in the Limiting Conditions for Operation and Surveillance Requirements sections of the l
Technical Specifications and, therefore, does not meet the criteria for Design Features in 10 CFR 50.36(c)(4). Section 5.2 is not included in the STS. We propose to climinate it from the Calvert Cliffs Design Features.
The containment dimensions included in the Technical Specifications are also included in UFSAR Section 5.1.2.1, " Containment - General Design." The temperature and pressure limitations are included in UFSAR Section 5.L5.1,
- Design Bases." These items can be adequately controlled under 10 CFR 50.59 and climination of this information from the Technical Specifications will not have an impact on plant safety.
Section 53 Reactor Core Calvert Cliffs Technical Specification Section 53 and corresponding STS Specification 4.2.1 meet l
Criteria 1, e.g., state the amount, kind, and source of special nuclear material. For consistency with j
the STS, we propose to adopt the S'13 titles and wording.
I Comparing the Calvert Cliffs Technical Specifications to the STS:
A.
The Calvert Cliffs Technical Specifications state:
"The reactor core shall contain 217 fuel assemblies with each fuel assembly containing a 1
maximum of 176 fuel rods clad with Zircaloy-4. Each fuel rod shall have a nominal active fuel length of 136.7 inches and contain 2 maximum total weight of 3000 grams uranium. The initial core loading shall have a maximum enrichment of 2.99 weight percent U-235. Reload i
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fuel shall be similar in physical design to the initial core loading and shall have a maximum l
enrichment of 4.35 weight percent U-235."
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"Except for special test as authorized by the NRC, all fuel assemblies under control element assemblics shall be sleeved with a sleeve design previously approved by the NRC."
The STS state:
'The reactor shall contain 217 fuel assemblics. Each assembly shall consist of a matrix of zirconium alloy fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO ) as fuel material. Limited substitutions of zirconium alloy or stainless steel 2
filler rods for fuel rods,in accordance with approved applications of fuel rod configurations, l
may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number oflead test assemblies that have not completed representative testing may be placed in nonlimiting regions."
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I Document Control Desk December 8,1993 Page 5 i
Both the Calvert Cliffs Technical Specifications and the SE contain the following information:
Number of fuel assemblies in the core Fuel rod cladding material Fuel material (Iow enriched uranium) l l
'Ihe STS contains the following additional information, all of which is currently alinwed at Calvert Cliffs:
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Allowance for limited substitution of filler rods Limitations on fuel assembly design Allowance for lead test assemblies The following Calvert Cliffs Technical Specifications information is not included in the SE:
Maximum number of fuel rods, active height of the fuel rods, and maximum total weight of a fuel rod. Detailed information on fuel assembly design is contained in the UFSAR, Section 33.23, " Fuel Assembly Mechanical Design," and changes must be evaluated under 10 CFR 50.59. The proposed technical specifications will continue to require that fuel assemblics be designed using NRC staff-approved methods and comply with all fuel safety design bases. Therefore, it is not necessary to include this information in the Design Features Section.
Initial core maximum enrichment. This information has only historical significance and should not be included in the Technical Specifications.
Maximum enrichment. Placing a maximum enrichment on the fuel in the core is unnecessary as limits on the maximum enrichment for spent fuel and new fuel are contained in proposed Design Features Sections 53.1.1 and 53.1.2, respectively.
Requirements for sleeving. This requirement is incorporated in the STS requirement that fuel assembly designs must meet NRC staff approved codes and methods.
Therefore, we have concluded that adopting the STS wording for proposed Section 5.2, " Reactor Core" will meet the criteria and will continue to provide an adequate level of control of the safety significant information.
Section 533 Control Element Assemblies Calvert Cliffs Section 533," Control Element Assemblies" and the corresponding SE Section 4.2.2 does not meet Criteria 1,2 or 3. The safety significant aspects of control rods, e.g., the reactivity worth of control rods and their required insertion times, are included in other portions of the Technical Specifications. Therefore, control rods do not fall under the Criteria 3 as features not described in other sections of the Technical Specifications. We propose that this section be eliminated from the Calvert Cliffs Design Features and the SE.
The control element assemblics are described in UFSAR Section 33.2.4, " Control Element Assembly Mechanical Design." Changes to the control rods can be adequately controlled under 10 CFR 50.59 and climination of this information from the Technical Specifications will not have an impact on plant safety.
1 Document Control Desk December 8,1993 j
Page 6 1
Section 5.4 Reactor Coolant System i
His section does not meet any of the criteria and is not included in the SE. It does not meet Criteria 3 in that the requirements on degradation, pressure and temperature are contained in other portions of the Technical Specifications and changes in the total water and steam volume would not have an immediate and significant impact on safety. We propose that it be climinated from the Calvert Cliffs Technical Specifications.
The information contained in Design Features Section 5.4 is also contained in UFSAR Section 4.1.1,
" Reactor Coolant System Design Basis" and in UFSAR Table 4-1. Changes to the Reactor Coolant System can be adequately controlled under 10 CFR 50.59 and climination of this information from the Technical Specifications will not have an impact on plant safety.
Section 5.5 MeteorolocicalTowerlocation This section does not meet any of the criteria and is not included in the STS. We propose to climinate this section from the Calvert Cliffs Design Features section.
Baltimore Gas and Electric Company is committed to have a meteorological tower in accordance with Regulatory Guide 1.2 and NUREG-0654. The location of the meteorological tower will be shown on the site boundary map which is being added to the UFSAR.
Changes to the meteorological tower can be adequately controlled under 10 CFR 50.59 and climination of this information from the Technical Specifications will not have an impact on plant safety.
Section 5.6 Fuel Storace Calvert Cliffs Section 5.6.1, " Criticality - Spent Fuel," specifies the minimum center-to-center distance, a K g limit, and the maximum enrichment for fuel in the spent fuel storage racks. These e
requirements are also contained in SE Section 4.3.1.1, Items a, b, and c. Section 5.6.2, " Criticality -
New Fuel," specifies the minimum center-to-center distance, a k li eg mit, and a maximum enrichment for fuel in the new fuel racks. These requirements are contained m STS Section 4.3.1.2, Items a, b, c, and d. These sections meet Criteria 3, e.g., geometries which, if altered, would have an immediate and significant impact on safety. These requirements do not appear in other sections of the Technical Specifications. The STS language contains the same restrictions as the Calvert Cliffs Design Features while introducing no new requirements. We propose adopting the STS language and we will ac'd information on uncertainties to the referenced sections of the UFSAR.
Section 5.6.3 Drainace This section in the Calvert Cliffs Design Features section and the corresponding SE Section 4.3.2 does not meet any of the criteria. It does not meet Criteria 3 in that it does not describe geometry or materials of construction and because the requirements are contained in another portion of the Technical Specifications.. We propose that this section be climinated from the Calvert Cliffs Design Features section and from the STS.
Calvert Cliffs Technical Specification 3.9.1.1 requires that at least 21-1/2 feet of water be maintained over irradiated fuel assemblies in the spent fuel pool. The design of the Spent Fuel Pool is described in UFSAR Section 9.7.4,
- Design Evaluation and System Reliability." It states that the Spent Fuel Pool is designed to prevent accidental draining of the pool by gravity. These controls ensure that the design of the spent fuel storage pool can be adequately controlled under 10 CFR 50.59 and
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Page 7 j
elimination of this information from the Design Features Section will not h' ave an impact on plant-l L
safety.
l Section 5.6.4 Capacity i
Section 5.6.4, " Capacity," states the maximum spent fuel storage capacity. This meets Criteria 1 in l
that it limits the amount of special nuclear material that may be stored on site. He Calvert Cliffs i
Technical Specifications language varies slightly from the S13 language in that it makes clear that the l
storage capacity limit applies to the combined storage pool for Units 1 and 2. Therefore, we propose -
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to retain the Calvert Giffs Technical Specification language.
l Section 5.7 Component Cyclic or Transient Limits l
This section is not included in the STS and does not meet any of the criteria. We propose that it be l
eliminated from the Calvert Giffs Design Features section.
The component cyclic or transient limits for the Reactor Coolant System are included in UFSAR.
Section 4.1.1, and those for the Steam Generator are in UFSAR Section 4.13.2. These limits are 1
l monitored by procedure. Therefore, these requirements can be adequately controlled under
~l 10 CFR 50.59 and elimination of this information from the Technical Specifications will not have an.
impact on plant safety.
REOUESTED CIIANGE e
l Revise the Calvert Cliffs Units 1 and 2 Technical Specifications by inclusion of the revisions shown in Attachments (1) and (2).
DETERMINATION OF SIGNIFICANT IIAZARDS i
The proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to not involve a significant hazards consideration, in that operation of the facility m accordance with the proposed amendment:
1.
Would not involve a significant increase in the probability or consequences of an accident previously evaluated.
1 The proposed change to the Design Features section adopts language from the Design Features section of the Standard Technical Specifications (S'IS) for Combustion Engineering Plants (NUREG-1432, September,1992), based on the Commission's Final Policy Statement l
on Technical Specifications Improvements for Nuclear Power Reactors (July 16,1993).
l Some requirements in the current Technical Specifications have been eliminated or relocated to the UFSAR based on the STS as evidence that the NRC no longer considers those requirements to meet the criteria for Design Features in 10 CFR 50.36(c)(4). In some cases, we have proposed climination of some requirements in the STS and the Calvert Giffs -
Technical Specifications based on a determination that they have no legal or regulatory basis.
We propose climinating the " Site" sections, present in the Calvert Giffs and the STS Design Features sections, which contain maps or descriptions of the site boundary and low population zone.
There are no legal or regulatory requirements for including this information in the Technical Specifications and this information will be relocated to the UFSAR. We propose adding a " Site Location" section which contains a description of the l
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Document Control Desk i
December 8,1993 l
Page 8 Calvert Cliffs location as required by the Atomic Energy Act of 1954. The " Containment,"
" Reactor Coolant System," " Meteorological Tower Location," and " Component Cyclic or Transients Limits" sections do not meet the legal or regulatory requirements for inclusion in the Design Features section, are not included in the STS, and have been deleted. The information in these sections is or will be contained in the UFSAR and will be controlled under 10 CFR 50.59. The " Control Element Assemblies" and " Fuel Storage - Drainage" i
sections are included in the STS and Calvert Cliffs Technical Specifications but climinated in this change as theses sections do not meet any of the legal or regulatory requirements for the Design Features section. This information is contained in the UFSAR and will be controlled under 10 CFR 50.59. We propose adopting the STS wording for the " Reactor Core" and
" Fuel Storage" sections with no changes in the present limits or controls. Some information in the Cahert Cliffs Technical Specifications is not contained in the STS
- Reactor Core" section. This information is contained in the UFSAR and will be controlled under 10 CFR 50.59.
Allinformation eliminated from the Design Features section of the Technical Specifications is or will be located in the UFSAR and will be controlled under 10 CFR 50.59. The design and operation of the plant have not changed. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluat:d.
2.
Would not create the possibility of a new or different type of accident from any accident previously evaluated.
The proposed change does not represent a change in the configuration or operation of the l
plant. All information eliminated from the Technical Specifications will continue to be l
controlled under 10 CFR 50.59. All legal and regulatory requirements for the Design Features section continue to be met. Therefore, the proposed change does not create the possibility of a new or different type of accident from any accident previously evaluated.
3.
Would not involve a significant reduction in a margin ofsafety.
i The proposed change does not represent a change in the configuration or operation of the plant. All information climinated from the Technical Specifications will continue to be controlled under 10 CFR 50.59. All legal and regulatory requirements for the Design Features section continue to be met. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
ENVIRONMENTAL ASSESSMENT The proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, or changes to an inspection or surveillance requirement. We have determined that the proposed amendment involves no significant hazards consideration, and that operation with the proposed amendment would result in no significant change in the types or significant increases in the amounts of any effluents that may be released offsite, and in no significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion as set forth in 10 CFR Part 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no emironmental impact statement or emironmental assessment is needed in connection with the approval of the proposed amendment.
Document Control Desk December 8,1993 Page 9 l
SCIIEDULE This change is requested to be approved and issued by June 1994. However, issuance of this amendment is not currently identified as having an impact on outage completion or continued plant operation.
SAFETY COMMITTEE REVIEW These proposed changes to the Technical Specifications and our determination of significant hazards have been reviewed by our Plant Operations and Safety Review Committee and Offsite Safety Review Committee. They have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.
Should you have any questions regarding this matter, we will be pleased to discuss them with you.
truly yours, STATE OF MARYLAND :
i TO WIT :
(
COUNTY OF CALVERT I hereby certify that on the 8M day of
,19M, before me, the subscriber, a Notary Public of the State of Maryland in and for
('s h/ rat h_
personally appeared Robert E. Denton, being duly sworn, and states that he is Vice PresAlent of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
WITNESS my Hand and Notarial Seal:
IA_4_;
. M kr>I-Notary Public
/
My Commission Expires:
Aw /, /99M l
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@ ate RED /BDM/ dim Attachments: (1)
Unit 1 Technical Specification Revised Pages (2)
Unit 2 Technical Specification Revised Pages
l l-Document Control Desk
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December 8,1993 Page 10 -
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cc:
D. A. Brune, Esquire
- J. E. Silberg, Esquire 1
R. A. Capra, NRC j
- D. G. Mcdonald, Jr., NRC C. L Grimes, NRC -
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T. T. Martin, NRC P. R. Wilson, NRC i
R. I. McIzan, DNR -
-i J. H. Walter, PSC j
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