ML20092E748
| ML20092E748 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/06/1992 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20092E754 | List: |
| References | |
| NUDOCS 9202180235 | |
| Download: ML20092E748 (11) | |
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0 DALTIMOft C GAS AND ELECTRI 1650 CALVERT CLIFFS PARKWAY
- LUSDY, MARYLAND 20657-4702 Otomot C. Cntro i Vict Pat $1 DENT Nvettam f setney i... . ....
February 6,1992 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Ccmtrol Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit No.1; Docket No. 50-317 License Amendment Request; low Temperature Overpressure Protection ;
U. TOP)
REFERENCES:
(a) 1. citer from Mr. O. C. Creel (BO&E) to NRC Document Control Desk, dated August 13,1990, License Amendment Request (b) 1.etter from Mr. D. O. Mcdonald, Jr. (NRC) to Mr. O. C. Creel (BO&E), dated September 18,1990, Issuance of Amendment No.146 (TAC No. M77292)
Gentlemen:
The Baltimore Oas al.d Electric Company hereby requests an Amendment to its Operating 1.icense No. DPR 53 for Calvert C'iffs Unit No. I with the submittal of the proposed changes to the Technical Specifications.
DESCRIPTION The proposed amendment would revise the Technical Specifications for Unit 1 to provide new heatup and couldown curves to allow operation beyond 12 effective full power years (EFPY). The Power Operated Relief Valve (PORV) setpoint has also been revised, and the Minimum Pressure and Temperature (MPT) Enable temperature has been increased to 3550F to provide low temperature overpressure protection (LTOP) for an allowable 11uence corresponding to approximately 22 EFPY based on the current core loading pattern %c temperature at which the high pressure safety injection (IIPSI) pumps are placed under manual control during a reactor cooldown has been increased to 3750F due to the higher MPT temperature. To accommodate the lower Appendix 0 pressure limits associated with the new curves, the maximum allowed IIPSI pump i flowrate has been reduced from 210 rpm to 200 gpm when used to add mass to the Reactor Coolant System (RCS) . The criterion for the reactor to be shutdown for eight hours or longer before a Reactor Coolant Pump (RCP)is started has been removed from the bases, as it is no longer required.
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l The initial indicated RCS pressure for starting an RCP has been increased to 300 psia. The Adjusted Reference Temperature (ART) for the 1/4 T and 3/4 T positions in the bases changed to 253.70F and .
193.8oF, respectively, ;
The technical specifications requested herein, while not constituting a safety concern, do not i represent the desired approach for operating Calvert Cliffs in the long term. The enclosed heatup and cooldown curves in conjui.etion with RCP operating requirements, will allow for only a 50 psia !
window of operation at low temperatures. Long term use of this restrictive operating window increases the possibility of RCP damage due to low pressure or an inadvertent PORY lift.
Until November 1991, it had beer our intention to submit a new set of curves based on the new LTOP methodology described in AH!!/C E Topical Report CEN 381 P.
- Low Temperature Overpressuritation Transient Pressure Ternperature Limit for Determination of Low Temperature Overproute Protection Setpoint" (and Attachment 1P. hw Temperature Overpressure Protection Pressure Temperature Limit Methodology Response to USNRC Inquiry," thereto). In fact, engineering had been complete and a license amendment application was under development.
Submittal to the NRC was scheduled for December 1991. Adoption of this new methodology would have greatly increased operational flexibility at low temperatures while affording an equivalent degree of safety relative to current methods. CEN 381 P has been under review at NRC for at least two years and it was our understanding that approval could be expected in the fall of 1991. Ilowever, when we became aware that approval was not forthcoming and that no firm schedule existed for completion of the reviews, we halted our effort and shifted back to a licensing submittal that was based on existing Appendix 0 methods.
We prefer not to operate Calvert Cliffs under the constraints imposed by the current methods unless there is no other technically viable alternative. We believe the new methodology proposed by CEN 381 P to be technically viable, and intend to make a follow on licensing submittal at mid. year.
We request that the NRC complete its review of CEN 381 P consistent with this schedule.
IIACKGROUND in our License Amendment Request letter dated August 13,1990 (Refeience a), proposed resisions to LTOP Technical Specifications and a new LTOP system description were submitted for your review. By letter dated September 18,1990 (Reference b), the Nuclear Regulatory Commission issued Amendment No.146, which approved our request. This system description provided information on our approach to LTOP which is based primarily on reducing the potential for overpressurization of the RCS through a combination of additional controls, administrative procedures and operator action. In general, this protection includes the following:
- Procedural precautions and controls;
. Disabling of non-essential components whenever LTOP is required (below the MPT Enable temperature and the RCS not vented);
. Avoidance of a water solid RCS whenever practical; and,
- Use of a low relief setpoint in the PORV controllogie.
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Attachment (1) provides the proyosed markup of the technical specifications. A description of the changes that have been made to t ac LTOP system follows, i-
}{EOUlWTEI) CIIANGE Change Unit 1 Technical Specifications as shown on the marked up pages attached to this transmittal and as described below.
- 1. llentup us).d Cooldow n Conts and Hutu
- a. Change Technical Specification Limiting Condition for Operation (LCO) 3.4.9.1.a.
maximum allowable heatup rates, as follows:
i Maximum Allowable lleatun Rates RCS Temocrature (FROM) 400 Fin any hour period 70"F to 3130F 1(PFin any hour period 3140F to 3270F '
W' Fin any hour period > 3270F (TO) 300 Fin any hour period 7(FF to 1640F 4(FFin :ny hour period > 164oF to 328"F 1(FFin any hour period > 3280F to 3550F W) Fin any hour period > 3550F
- b. Change Technical Specification LCO 3.4.9.1.b, maximum allowahle cooldown rates, as follows:
Maximum Allowable Cooldown Rates RCS Temperature (FROM) 10(FFin any one hour period > 2500F 20oFin any one hour period 250"F to 170oF 1(PFin any one hour period < 17(FF (TO)
' 1000 Fin any one hour period > 2540F 200 Fin any one hour period 2540F to 184oF 100 Fin any one hour period < 1840F
.- Document Control Desk l'ebruary 6,1992 Page 4
- c. Replace Technical Speci0 cation Figures 3.4 2a and 3.4 2b, RCS Pressure.
Temperature on a lluence of 3.25 (P.T) x 10 Lim ft/cm*(tg. li> l withp(ew mev), which Ogures. The corresponds revised curves to approximately 22 and rate EFPY based on the current core loading pattern. The revisions to tbe curves also made it necessary to revise the Adjusted Reference Temperatures (ART) for 1/4 T position and 3/4 T position in the bases. 'Ihe ART for 1/4 T iosition has been changed from 2220F to 253.70F and the ART .'or 3/4 T position las been changed from 162.SoF to 193.80F.
- 2. LTOP Conitub
- a. Change Technical Specification 3.4.9.3.a.1 and 2 from
- lift setting 5 430 psia" to " trip setpomt_ of 1429 psia.* 11ases 3/4.4.9 has been changed to explain the new terminology used to descritr the PORV setpoint.
- b. The MPT enable temperature has been changed from 3270F to 3550F. The Technical Specifications that are affected by this change are 3.1.2.1, 3.1.2.3, Table 3.3 3, 3.4.1.2, 3.4.1.3, 3.4.9.3, 4.5.2, 3.5.3, !!ases 3/4.4.1,11ases 3/4.4.9, and Bases 3/4.5.2.
- c. Due to the higher MPT enable temperature, the transition region at which the high prusure safety injection (llPSI) pumps are placed under manual control on cooldown and restored to automatic status on heatup has been changed from 3270F -
350"F to 3550F. 375oF. This affects Technical Specification 3.5.3 and Table 3.3 3.
- d. The allowable llPSI pump flowrate has been changed from "icss than or equal to 210 gpm" to "less than or equal to 200 ppm' when used to add mass to the RCS. 'Ihis affects Technical Specification 3.4.9.3,113/4.4.9 and B3/4.5.2.
- 3. RCP Start Criteria
- a. Change the RCP start controls for pressurizer pressure in footnote (*") to the APPLICABILITY section of Technical Speci0 cation 3.4.1.3 and in footnote (") to the APPLICABILITY section of Technical Speci0 cation 3.4.1.2 from s 290 psia to
& 300 psia.
b, Remove the criteria for acactor shutdown of eight hours or longer prior to RCP start from the Bases.
- 4. Techn[gt.Hpecif1 l cation llnws Revise Technical SpeciGcation Bases 3/4.4.1, Coolant loops and Coolant Circulation, and Bases 3/4.4.9, Pressure / Temperature Limits, and Bases 3/4.5.2, ECCS Subsystem, to be consistent with tne above changes.
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- 5. DeJ{kallan Add Technical Specification LCO 3.4.9.3.e to say,'When not in use, the above OPERADI.E high pressure safety injection pump shall have its handswitch in pull.to-kick.' To Technical Speci0 cation 4.4.9.3.3 add the surveillance requirement,"the above OPERADI.E pump shall be veriDed to have its handswitch in pull.to-hick at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.*
Change Bases B3/4.9 to remove the discussion of temperature instrument uncertainty for the minimum boltup temperature. The margin between the calculated minimum boltup temperature of 1(FF and the conservative administrative limit of 7(PF ensures that plant operation is consistent with the safety analysis for minimum boltup temperature. It has also been clarified that the administrative limit of 7(FF for minimum boltup temperature is the minimum allowable reactor vessel temperature at which the reactor vessel head can be attached in order to comply with the 10 Cllt Part 50, Appendix 0 limits.
Change Bases B3/4.4.9 to replace the discussion of a figure that was developed to show the calculated RCS pressure versus time with a more descriptive discussion. 'lhat discussion addresses the mass addition transient, which is the basis for the PORV setpoint.
EAF171Y ANAINSES!.itlSTil'ICATION
- 1. llentup nnd Cooldow n Cu.ves ami Hates
- The proposed change to the Technical Specifications will revise the existing 0-12 EFPY heatup and cooldown curves and rates. 'the existing 0-12 EFPY heatup and cooldown curves and rates are based on the calculation of P.T limit curves that comprise the basis of Reference (a), as app gved by NRC in Reference (b). The new P Tlimit curves are based on a Duence of 3.25 x 10 n/cm at the inner rurface of the reactor vessel, which corresponds to approximately 22 EFPY of operation based on the current core loading pattern. This Duenec is higher than the existing fluence (for 12 EFPY) and results in a lower Appendix G limit and a higher MPT enable temperature. Since the vessel embrittlement is actually based on Buence, and not EFPY, we find it more appropriate to base the curves on Quence. We have elected to propose heatup and cooldown curves based on a higher fluence, which corresponds to approximately 22 EITY. *lhe pro;msed cunes correspond to different heatup rates. 'Ihe cooldown rates remain the same, but the RCS temperature range changed for each of the rates. The proposed heatup and cooldown curves and rates are based on new P T limits that were conservatively developed using the same methods as the existing curves in accordance with the fracture toughness requirements of 10 CFR 50, Appendix G, as supplemented by the ASME Code Section lit, Appendix 0.
Due to increased reactor vessel embrittlement caused by the higher Duence, the above changes require the low temperature PORV pressure trip setpoint to be lowered. The low temperature PORV pressure trip setpoint is based on preventing RCS pressure from exceeding the most limiting pressure of the applicable heatup and cooldown Appendix G curves. This occurs during a cooldown at a temperature of 7(FF. Speci0cally, the maximum analytical pressurizer pressure (not including pressure instrument loop uncertainty and overshoot) when in MPT enable has decreased from 464.1 psia to 444.5 asia. The MPT enable temperature has been increased from 3270F to 355oF (incluces temperamre
- instrument loop uncertainty).
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Document Control Desk Februusy 6,1992 Page 6 he maximum allowable heatup rate for RCS temperature has been changed to be applicable for temperatures as follows:
3(PF/hr 7(PF to 1MoF 4(FF/hr > 1640F to 3280F 1(FIWr > 3280F to 3550F 6(PlWr > 3550F !
%c maximum allowable cooldown rates have been changed to be applicable for temperatures as follows:
10(FIWr > 2540F 20cIWr 2540F to 1840F 1(FIWr < 1840F Revised Technical Specification Figures 3-4.2a and 3-4.2b (heatup and cooldown curves) have been conservatively developed in accordance with the requuements of 10 CFR 50 Appendix 0, as su iplemented by Appendix 0 to Section 111 of the ASME Boiler and i Pressure Vessel Cm e,1986 Edition. ne adjusted RTNDTvalues used in their development !
have been conservatively calculated using the methodology provided in Re;;ulatory Guide 1.99, Revision 2, and are based upon the peak neutron fluence experieneet by the reactor beltline region through a period of approximately 22 EFPY based on the current core loading pattern.
- 2. J! ROP Controls The low temperature PORV pressure setpoint is based on protecting against exceeding the most restrictive pressure of both the heatup and cooldown curves. He most restrictive 1ressure limitation is for the too1%r cooldown at 7(FF in the RCS. With the proposed P T
.imits the maximum analytical pressurizer pressure (not including pressure instrument uncertainty and response time) when in MFT enable has been decreased from 464.1 psia to 444.5 psia. The existing PORV lift setting in the Technical Specification 3.4.9.3 is .54301sia.
This value represents the "as left" trip setpoint, which includes all instrument oop uncertainties and response time.
3 In order to better define the PORV setpoint, the term ' lift setting" has been replaced with
" trip setpoint". The new technical specification trip setpoint value is less than or equal to 429 psia. The actual trip setpoint is controlled by plant procedures and is calculated considering response time and total loop uncertainties. Total kop uncertainties include allowances for loop drift, calibration uncertainties and instrument device uncertaintics. %c
- loop drift was considered in developing the technical specification trip setpoint, which is an allowable value calculated per Instrument Society of America Standard ISA-S67.04.
He LTOP MPT enable temperature was developed using the guidance found in NRC Standard Review Plan 5.2.2, Revision 2. %e enable temperature was calculated using specific heatup transients with changing thermal rates to reduce the temperature gradients.
He selection of the proposed more restrictive heatup rates and the resulting allowable pressure limits as described above were required to minirnize the increase in the MPT enable
.- Document C(mtrol Desk February 6,1992 Page 7 temperature caused by the higher fluence, ne LTOP MPT enable temperature was increased from 3270F to 3550F. l As a result of the higher MPT enable temperature, the transition range at which the llPSI lumps are placed under manual control on cooldown and restored to automatic status on icatup has Seen changed from 3270F 35(PF to 3550F 3750F in the technical s >ccifications l and bases. Calculations performed indicate that adequate LOCA protection be ow 3750F is provided by the Safety injection Tanks. His is sufficient to allow operator action to manually start a llPSI pmnp, if requircd.
- 3. RCP Sta.tj Crlictia De new PORY setpoint provides margin to accommodate possible pressurization transients after starting two RCPs at the same time. The thermal. hydraulic analysis of RCP start ;
transients simulate thermodynamic conditions within the pressurizer. Calculations have also statistically combined instrumentation uncertaintics, providing additional margin in assurned .
I initial conditions for transient analysis. Dese provide a set of operating conditions which permit normal RCP start without challenging the PORV.
Reference (a) discusses the RCP start transient analysis that was used in developing RCP start criteria (two RCPs started at the same time). Additional analytical margin was available t to specify a higher maximum pressurizer pressure and a shorter allowable time after i shutdown for the RCP start transient analysis, but was not used. We are now taking credit for this additional margin and have increased the maximum initial indicated pressurizer '
pressure from 290 psia to 300 psia and have deleted the eight. hour criteria in the bases for the RCP start transient.
The plant conditions which must be satisfied for RCP starts are as follows:
indicated initial pressurizer pressure less than or equal to 300 psia. This is an increase of 10 psi from the current limit of 290 psia.
indicated initial pressuriter level less than or equal to 170 inches. This is not a change from the current limit.
indicated steam generator secondary temperature no more than 3(FF higher than indicated RCS temperature. This is not a change from the current limit.
- 4. Mass Addition Transients .
The changes in PORV setpoints end P.T limits affect the existing mass addition transient controls. Lowering the maximum analytical pressurizer pressure from 464.1 psia to 444.5 psia requires lowering the total ilow limit into the pressurizer during a mass addition event. De existing throttled IIPSI pump Dow limit of 210 gpm has been changed to 200 gpm to preclude exceeding the Appendix G limit when adding mass to the RCS.
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- 5. IJPSI Purtuu The OPERABLE high pressure safety injection pump required in Technical ,
Specification 3/4.4.9.3 must be undet manual control when the RCS temperature is less than or equal to 3550F and the RCS is vented to less than 8 square inches. This is currently controlled in plant procedures.1hc revision to this technical specification ensures that when !
the llPSI pump is not in use,its handswitch is in pull to k>ck. lhis revision does not change the intent of technical speci0 cation and is added for clarification only.
- 6. Technical Specirlention linses The margin of 8(FF between the calculated minimum boltup temperature ( 1(PF) and the conservative administrative limit (7(PF) ensures that actual bollup temperature is consistent with the assumptions of the safety analysis. 'lhe conservative administrative limit of 7(PF for minimum boltup temperature provides saf0cient trargin to ensure that instrument uncettainty is not a concern. It has also been clariGed that the administrative limit of 70"F for minimum boltup temperature is the minimum allowable reactor vessel ternperature at which the reactor vessel head can be attached in order to comply with the 10 CFR Part 50, ;
Appendix 0 limits. Therefore the discussion of instrument uncertainty in the Bases is not ;
necessary.
The current Bases references a figure that was developed to show the calculated RCS pressure versus time. Since this Ogure is not included in the Technical Specifications or the Bases, the neferences to this figure has been removed. A more descriptive discussion has been added that addresses the mass addition transient, which is the basis for the PORV setpoint, and therefore, is more appropriate for the Bases.
P JEFERMINATION OF SIGNIFICANT liAZARDS 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 in accordance with the proposed amendment:
- 1. li'ould not imvhe a significant increase in the probability or consequences of an accident previously evaluated.
The existing Unit 1 12 Effective Full Power Years (EITY) Pressure-Temperature (P T) :
limits were conservatively developed in accordance with the fracture toughncss requirements of 10 CFR 50, Appendix 0, as supplemented by the American Society of Mechanical Engineers (ASME) Dailer and Pressure Vessel Code Section 111, Appendix 0. 'lhe reactor vessel material Adjusted RTNDT values are based on the conservative methodology provided in Regulatory Guide 1.99, Revision 2. Because ofincreased Quence from 12 EFPY to approximately 22 EFPY based on the current core loading pattern, this amendment changes the P T limit calculations that are the basis for the existing heatup and cooldown curves. The proposed heatup and cooldown curves and associated limits continue to provide conservative administrative restrictions on reactor coolant system pressure to minimize rnaterial stresses in the Reactor Coolant System (RCS) due to normal operating transients, i
thus minimizing the likelihood of a rapidly propagating fracture due to pressure transients at l
low temperature. Because these proposed heatup and cooldown curves and rates are based i
,- Document Control Desk February 6,1992 Page 9 ;
l on new P T limits that were conservatively developed using the same methods as the existing i curves, this proposed amendment does not involve an increase in the probability or consequences of accidents previously evaluated.
Consistent with the selection of proposed heatup and cooldown curves and rates, the low temperature overpressure protection (LTOP) controls are being changed by decreasing the :
Power Operated Relief VaIvc (PORV) trip setpoint, ne increase in vessel fluence requires that the Minimum Pressure and Temperature (MPT) enable temperature be increased. He l new PORV trip setpoint is based on protecting against execeding the most restrictive nressure of both the heatup and cooldown curves; i.e., a 1(FF per hour cooldown at 7(PF RCS temperature. Since the basis for the selection of the PORV setpoint has not changed, the PORV will provide the sarne degree of protection in mitigating postulated LTOP ,
transients with the new setting as that provided by the present LTOP system. nerefore, this change does not increase the probability or consequences of accidents previously evaluated. ,
As a result of the higher MPT enable temperature, the transition region at which the high pter,sure safety injection (llPSI) pumps are placed under manual control on cooldown and restored to automatic status on heatup has been changed to 3550F 3750F. Analysis performed indicates that adequate Loss of Coolant Accident (LOCA) protection below 375oF is provided by the Safety Injection Tanks to allow operator action to manually start a !
IIPSI pump, if required. Therefore, this change does not increase the probability or '
consequences of accidents previously evaluated. ;
ne proposed heatup and cooldown rates, the decreased PORV trip setpoint, and increased MP1 enable temperature continue to provide margin to accommodate postulated pressurization from mass and energy addition transients. Calculations have been performed i that predict the response to such transients. From these calculations, the Reactor Coolant Pump (RCP) start criteria has been revised. The revised criteria will permit a slightly hi her '
initial pressure for RCP starts (two RCPs starting simultaneously) and will remove the e ht-hour reactor shutdown criteria for RCP restart. Also, a lower llPSI pump throttle flow I mit has been selected that will continue to protect the Appendix 0 pressure limit during a mass addition transient. Adding the requirement to ensure the operable llPSI pump's handswitch will be placed in pull to. lock when not in use is only a clari0 cation and does not change the intent of the specification. Because the results of the analyses remain well withm the conservative acceptance limits of 10 CFR 50 Appendix 0, these changes do not inerene the probability or consequences of accidents previously evaluated.
- 2. II'ould not create the possibility of a new or different type of accident from any accident previously evaluated.
The proposed changes to LTOP controls do not represent a significant change in the configuration or operation of the plant. Specifically, no new hardware is being added to the plant as part of the proposed change, no existing ecJuipment is being modified, nor are any signi0cantly different types of operations being' mtroduced. Therefore, the proposed amendment would not create the possibility of a new or different kind of accident from those previously evaluated.
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.L IVould not invohr a significant reduction in a margin ofsafety.
This change will ensure that the margin of safety is maintained with tespect to energy addition or mass addition events in that there are no postulated events that could challenge the Appenc.*x 0 limit. Utilizing the analytical margins for a planned RCP start does not signiDeantly reduce the margin of safety. The proposed increase in the allowable Duence at ;
the reactor vessel wall necessitated the changes to the heatup and cooldown curves and rates, the PORY trip setpoint, MPT enable temperature, llPSI pump flow limit, and llPSI pump manual control temperature. These changes ensure that t ic margin of safety is maintained by protecting the Appendix 0 limits for all postulated transients. Therefore, the proposed changes would not involve a significant reductio.: m a margin of safety, llased on the above, we have concluded that these changes do not constitute a significant hazard.
SCllEI)UI.E This change is requested to be approved and is<ued by May 15,1992 to allow implementation auring the upcoming Unit 1 spring 1992 refueling outage. This date will support the scheduled date for instal;ing the pressurizer manway, after which 1, TOP controls must be in place. Approval of this request after May 15,1992, may require the POllV setpoint to be changed at power, w hich we would prefer to avoid. The current curves are expected to expire in December 1992.
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. Document Control Desk February 6,1992 Page 11 SAFl*IY COMMrlTEE HEVil3V These proposed changes to the Technical Specifications and our determination of signliicant hazards have been reviewed by our Plant Operations and Safety Review Committee and Off. Site Safety Review Committee, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.
Very truly yours, STATE OF MAlWIAND:
- TO WIT:
COUN'iY OF CALVERT :
I hereby certify that on the 6th day of Februgy,1992, b , Sfore np_, the subscriber, a Notary Public of Calhlth /s.Tu _
the State of Maryland in and for , personally appeared George C. Creel, being duly sworn, and states that he is Vice Pr4sident of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing information 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 w s authorized to provide the information on behalf of said Corporation.
WITNESS mylland and Notarial Scal: , wp>0 Notarypblic My Commission Expires: /1*uoAv O[ /N6 GCC/DJM/djm/ dim Attachments cc: D. A. Brune, Esquire J. E. Silberg, Esquire e R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Mar tin, NRC L E. Nicholson, NRC R. I. McLean, DNR J. II. Walter, PSC