ML20076K756
| ML20076K756 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/21/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20076K749 | List: |
| References | |
| NUDOCS 9411020083 | |
| Download: ML20076K756 (3) | |
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. 20555-0001
,wj SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIOF, RELATED TO AMENDMENT NO. 199 TO FACILITY OPERATING LICENSE N0. DPR-53 AND AMENDMENT NO.176 TO FACILITY OPERATING LICENSE NO. DPR-69 BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-313
1.0 INTRODUCTION
By letter dated August 4,1994, the Baltimore Gas and Electric Company (the licensee) submitted a request for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2, Technical Specifications (TSs). The proposed changes would delete the requirements related to seismic monitoring instrumentation from the TSs and relocate them to the Updated Final Safety Analysis Report (USFSAR) and plant procedures. The requirements of these TSs, however, will still be maintained and controlled pursuant to the plant procedures and 10 CFR 50.59, " Changes, tests, and experiments."
2.0 EVALUATION Section 50.36 of Title 10 of the Code of Federal Regulations established the regulatory requirements related to the centent of TSs. The rule requires that TSs include items in specific categories, including safety limits, limiting conditions for operation, and surveillance requirements; however, the rule does not specify the particular requirements to be included in a plant's TSs.
The NRC developed criteria, as described in the " Final Policy Statement on Technical Specifications Improvementi for Nuclear Power Reactors" (58 FR 39132), to determine which of the design conditions and associated surveillances need to be located in the TSs "to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety." Briefly, those criteria are:
(1) detection of abnormal degradation of the reactor coolant pressure boundary, (2) boundary conditions for design-basis accidents and transients, (3) primary success paths to prevent or mitigate design-basis accidents and transients, and (4) functions determined to be important to risk or operating experience. The Commission's final policy statement acknowledged that its implementation may result in the relocation of existing technical specification requirements to licensee controlled documents and programs.
Appendix A to 10 CFR Part 100 requires that seismic monitoring instrumentation be provided to fromptly determine the magnitude of a seismic event and evaluate the response of those features important to safety. This capability 9411020083 941021 PDR ADOCK 05000317 P
., is required to allow fo a comparison of the measured response to that used in the design basis for the unit.
Comparison of such data is needed to:
(1) determine whether the plant can continue to be operated safely and (2) permit such timely action as may be appropriate. However, these components are not factored into accident analyses at Calvert Cliffs nor do they affect the margin of safety of the plant.
Seismic instrumentation does not actuate any protective equipment or play any direct role in the mitigation of an accident. The capability of the plant to withstand a seismic event or other design-basis accident is determined by the initial design and construction of systems, structures, and components. The instrumentation is used to alert operators to the seismic event and evaluate the plant response.
Therefore, requirements related to the seismic monitoring instrumentation do not satisfy any of the above final policy statement criteria and need not be included in the TSs.
In addition, the proposed amendment does not involve a change in the manner in which the plant will be operated, maintained, or tested.
The requirements described in the affected TSs will be maintained and any subsequent changes to the plant procedures or the VFSAR related to these instruments will be made in accordance with the requirements of 10 CFR 50.59.
On this basis, the staff concludes that TSs 3/4.3.3.3, 6.9.2.b, 6.9.2.d, and Bases 3/4.3.3.3, which are related to seismic monitoring instrumentation, do not need to be controlled by TS; future changes to these requirements are adequately controlled by 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either:
(1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, as defined in the basis for any TSs, NRC approval and a license amendment would be required prior to implementation of the change. NRC inspection and enforcement programs d so enable the staff to monitor facility changes and licensee adherence to updatec final safety analysis report commitments and to take any remedial action that may be appropriate.
The staff has concluded, therefore, that relocation of the requirements related to seismic monitoring instrumentation (TSs 3/4.3.3.3, 6.9.2.b, and 6.9.2.d and Bases 3/4.3.3.3) is acceptable because:
(1) their inclusion in TSs is not specifically required by 10 CFR 50.36 or other regulations, (2) these requirements are not required to avert an immediate threat to the public health and safety, and (3) changes that are deemed to involve an unreviewed safety question will require prior NRC approval in accordance with 10 CFR 50.59(c).
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendments.
The State official had no comments.
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4.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendments involve 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (59 FR 47165). Accordingly, the amendments meet the eligibility criteria for l
categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the consideraticns discussed above, that:
(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 amendments will not be inimical to the common defense and security or to the health and safety of the public.
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Principal Contributor:
J. Harold Date: October 21, 1994 l
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