ML20127D162
| ML20127D162 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/03/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20127D156 | List: |
| References | |
| NUDOCS 9209110229 | |
| Download: ML20127D162 (6) | |
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UNITED STATES n
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NUCLEAR REGULATORY COMMISSION
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WASHINoTON. D C. 20666 os...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.174 TO FAClllTY OPERATING LICENSE NO DPR-53 AND AMENDMENT NO.151 TO FACILITY OFERATING LICENSE NO. DPR-69 BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT N05. 1 AND 2 DOCKET NOS. 50-317 AND 50-318
1.0 INTRODUCTION
By letter dated February 13, 1992, Baltimore Cas and Electric Company (the licensee) submitted a request for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2, Technical Specifications (TS).
The requested changes would revise the TS relating to the reactivity control systems for both units to provide clarifications and simplifications to several specifications fce the control element assemblies (CEAs).
The changes also provide other minor administrative corrections and the TS Bases are revised to support the proposed changes.
The specific changes requested would:
(1) provide a clarification of the terminology for a CEA which is not available for reactivity insertion during a reactor trip; (2) clarify the applicability of a specification; (3) provide clarification of the apprcoriate actions to be applied for inoperable and misaligned CFAs; (4) remove an unnecessary portion of an action statement that implies that an unavailable, automatic mode of CEA operation is acceptable; and (5) provides other minor administrative corrections and clarifications.
The proposed TS amendments will revise TSs 3/4.1.1.1, 3/4.1.1.2, 3/4.1.2.3.1, and 3/4.1.3.5 and Bases 3/4.1.3 for both Units 1 and Unit 2.
2.0 EVALVA110N The licensee proposed changes for five categories of TS items.
The NRC staff's evaluation of each of the five categories is as follows:
Item 1 - Specifications 4.1.1.1.1.a, 4.1.1.2.a, 3.1.3.1 Action a and the Bases for Specification 3/4.1.3 do not use consistent terminology when referring to a CEA that is not available for reactivity insertion during a reactor trip.
This inconsistency has been a source of confusion regarding actions required for an inoperable CEA when inoperability was due to electrical malfunctions which did not affect the ability to trip the CEA.
The licensee has proposed that the terms " immoveable and untrippable" in the TSs be reduced to "untrippable" since the purpose of the specifications is to assure adequate shutdown margin.
The term " immoveable" is associated only with being
%fkN P
k inoperable as a result of excessive friction or mechanical interference.
This change clarifies that an increase in the shutdown margin is required only if the CEA is untrippable, i.e., unavailable for reactivity insertion.
The Bases section is also revised to reflect the proposed changes.
The staff finds this change to be acceptable in that it provides clarification as discussed above.
Item 2 - Specification 3/4.1.1.2 is identified as applicable during Mode 5 with either:
(1) pressurizer level above 90-inches or (2) pressurizer level below 90 inches while the flow rate from all sources of non-borated water are
'less than 88.gpm.
However, the specification is also intended to be applicable when the flow rate from non-borated sources of water is greater
-than 38 gpm as evidenced by Action b.
The licensee proposes to eli inate this m
inconsistency by making the specification applicable during all of Mode 5, and identifying the-intended limiting condition for operation To accomplish the intent, a portion of the current applicability statement is proposed to be relocated to the Limiting Condition fer Operation (LCO) section of the TS so that the LC0 and.the applicability statements will match.
The staff finds this proposed change to be acceptable in that it clarifies the intended requirements as discussed above.
Item 3 - Specifications 3.1.3.1 and 3.1.3.5 both provide action requirenieno to be met wFe, a shutdown CEA is found to be mispositioned.
The action statements or Specifications 3.1.3.1 and 3.1.3.5 contain several confusing elements.
Some of the action requirements apply when the CEA is withdrawn to less than 129.0 inches, and others apply when the CEA is misaligned in relation to the other CEAs in its group, some apply to both instances and some ao not ever apply to shetdown CEAs.
Based on prior analysis, the licensee has proposed tF' following changes, (a) to (f), to simplify and clarify the appropriat
.tions:
(a)- The action statements-for TS 3.1.3.1 do not all apply to both regulating and shutdown CEAs, some are applicable to only regulating CEAs and some are applicable to both.
This TS has been clarified by specifying that Action c is for regulating CEAs and tnat-the other actions are applicable for both regulating and shutdown CEAs.
~
(b) Action e of TS 3.1.3-1 currently provides requirements for more than one CEA being misaligned, but does not differentiate which portions of the action statement apply when only a single'CEA is inoperable. To prevent potential misinterpretation, Action e is proposed to be split into two-separate Actions (e and a new h), each with clear entry conditions.
The revised Action e which is for a single CEA, does not require restoration-of the CEA to "0PERABLE-status" since the CEA has not yet been declared inoperable.
Inoperable CEAs are covered under action statement g.
(c) Actions e, f, and y for TS 3.1.3.1 were developed separately and do not contain consistent requirements for power levels and timing.
The licensee proposed that the action requirements be combined into a new Action g which
. would include the current power' reduction requirements for CEAs misaligned at greater than 15 inches. Action g would also be revised to include an entry condition of "With one CEA (regulating or shutdown) not within its specified alignment requirements..." rather than "With one CEA m'saligned from_an other CEA in its group by 15 inches or more..." since it would be applicable to other misalignment conditions as well, i.e., resulting from new Actions e, f, and h.
Action g includes-the conditions for determining that a misaligned CEA is inoperable and also includes a tima requirement for realigning the remainder of the CEAs with the inoperable CEA such as currently exist in Action e.
(d)
The action statement of Specification 3.1.3.5 requires application of Specification 3.1.3.1, but is unclear on which of the action statements of Specification 3.1.3.1 are applicable to shutdown CEAs that are not fully withdrawn. An analysis performed to support Amendment Nos. 127 and 109 for-Units 1 and-2, respectively,- considered both the shutdown and regulating CEAs, independent of their type, to ensure that adequate shutdown margin would be available.
Therefore, the licensee proposes that a shutdown CEA not be treated any differently from a_ regulating CEA except that it be considered
" misaligned" when it is withdrawn to less that 129.0 inches as well as when it
'is greater-than 7.5 inches from any other CEA in its group. This revision requires ~other minor editorial changes to Action e, new Action h, and Action f.
The proposed changes continue to allow I hour for attempting to realign a misaligned CEA and provides clear application of an appropriate action statement if the realignment is not successful.
(e)
Action f of TS 3.1.3.1 requires an unnecessary referral to a figure to determine the next action.
The proposed wording will eliminate an assumed pre-misalignment value and reference to the figure and require an immediate
-implementation of Action g.
_(f)
Action i of TS 3.1.3.] provides information to be used when conducting a surveillance and is not really an action statement.
Therefore, the licensee Lproposes to incorporate the current Action i into Surveillance Requirement 4.1.3.1.2.
This revision does not result in any actual changes to the requirements, but only-provides clarification of when the requirements muct be i
l
-met.
l L
We find the proposed changes, as detailed above, to tKr acceptable in that they provide simplification and clarification for the specific conditions and required actions.to meet the LCO for CEAs based on their relative alignment within-their specified group.
l Item 4 - The CEA-drive system is designed to operate in any one of five modes; I
one of these is an automatic mode. However, for Calvert-Cliffs, the automatic E
-mode has been disabled and operation in this mode is not allowed.
The CEA drive system mode switch has an off position and three types of manual control positions.
Specification 3.1.3.1.b.2 begins with the requirement to " place and maintain the CEA drive system mode switch in either the 'Off' or any
' Manual Mode' position...," which implies that ar ather mode of the CEA drive system can be used. But the only other position is the disallowed " automatic
0
- mode" and this mode is not available for use at Calvert Cliffs.
We find it acceptable to-delete this statement in that it eliminates any confusion relating _to the CEA operating modes.
However, if the licensee decides to enable the automatic mode at some future time, this specification must be revised to reflect the change.
Item 5 - The licensee has also proposed several other administrative and editorial changes.
These include:
(a) incorporating a discussion in the Bases of the " greater than or equal to" symbol prior to the "40 gpm or 2300 ppm" to clarify that the symbol applie to the entire phrase and not just the 40 gpm.
This is necessary to the understanding of the "or equivalent" phrase; (b) incorporating the-missing title of Specification 3/4.1.3.1, "CEA POSITION" which was inadvertently omitted in a past amendment; (c) correcting the number of the identifier for the " MOVEABLE CONTROL ASSEMBLIES" Specification from 3.4.1.3-to 3/4.1.3; (d) adding periods to the end of notes for Specification 3/4.1.1.1-and 3/4.1.3.5; and (e) revising a time reference in Bases 3/4.1.3 to
. match the time actually allowed by the current action statements.
The staff finds these administrative and editorial changes to be acceptable.
3.0
SUMMARY
Based on the staff evaluation detailed in Section 2.0 above, the staf' concludes that-the licensee proposed revisions, which provide clarification and simplification to CEA Technical. Specifications 3/4.1.1.1, 3/4.1.1.2, 3/4.1.3.1, and 3/4.1.3.5 and Bases 3/4.1.3 for Unit I and 2, are acceptable.
4.0 STATE'CONSULTAT10N 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.
5.0 ENVIRONMENTAL CONSIDERATION
The. amendments change a requirement witn 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 E
significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative l
occupational radiation exposure.
The Commission has previously issued a p
proposed finding that the amendments involve no 'significant hazards L
consideration, and there has been no public comrent on such finding
_(57 FR 9439). Accordingly, the amendments meet the eligibility criteria for 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 reed be c
prepared in connection with the issuance of the amendments.
= - -
- ... -o -
- 6.0 f 0NC LU.SJ,0_N The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance.that the health-and safety of the
- public will not be endangered by ogation in the proposed manner, (?) 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.
Principal Contributors:
H. Balukjian L. Kopp
-Date:
Septa-ter 3,1992
Docket Nn. 50-317 and 50-318 Mr. R. E. Denton Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant MD Rts. 2 & 4 P. O. Box 1535 Lusby, Maryland 20657
Dear Mr. Denton:
SUBJECT:
UNIT NO. 1 (TAC NO. M82776) AND The Commission has issued the enclosed Amendment No 174 DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit cense No.
tively.
(TS) in response to your application transmitted by letter 1992.
ons ae ebruary 13, The amendments revise the Technical Specifications relating to control systems to provide clarification and simplification for the cont reactivity element assemblies and other minor administrative correction f
is revised to reflect the TS changes.
The TS Bases rol l
A copy of the related Safety Evaluation is enclosed.
will be included in the Commission's next regular biweekly Federal R notice.
A Notice of Issuance s er Sincerely, Original Signed By:
Daniel G. Mcdonald, Senior Project Manager Project Directorate I-l Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation
Enclosures:
1.
Amendment No.174 to DPR-53 2.
Amendment No.151 to DPR-69 3.
Safety Evaluation cc w/ enclosures:
See next page
- See previous concurrence OFFICE PDI-1:LA PDI-1tff%[,)
OTSB*
OGC*
NAME DMcDona N PD M :Q Cyogan c~
CIGrimes JHull khh[1 0 h 92 DATE
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Q /4 /92 8/28/92 9/1/92 Y/3/92 0FFICIAL RECORD COPY 3
FILENAME: A:\\CCM82776.AMD
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,o Docket Nos. 50-317 and 50-S13 Mr. R. E. Denton Vice President - Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant MD Rts. 2 & 4 P. O. Box 1535 Lusby, Maryland 20657
Dear Mr. Denton:
SUBJECT:
ISSUANCE OF AMENDMENTS FOR CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO 1 (TAC NO. M82776) AND UNIT NO. 2 (TAC NO. M82777)
The Commission has issued the enclosed Amendment No.174 to Facility Operating License No. DPR-53 and Amendment No.151 to Facility Operating License No.
DPR-69 for the Calvert Cliffs Nuclear Powe, Plant, Unit Nos. I and 2, respec-tively. The ameadments consist of changes to the Technical Specifications (TS) in response to your application transmitted by letter dated February 12, 1992.
The amendments revise the Technical Specifications relating to reactivity control systems to provide clarification and simplification for the control element assemblies and other minor administrative corrections.
The TS Bases is revised to reflect the TS changes.
A copy of the related Safety Evaluation is enclosed. A iMtice of Issuance will be included in the Commission's next regular biweekly Federal B_eaister notice.
Sincerely, Original Signed By:
Daniel G. Mcdonald, Senior Project Manager Project Directorate I-l Division of Rei.ctor Projects - 1/II Office of Nuclear Reactor Regulation
Enclosures:
1.
Amendment No.174 to DPR-53 2.
Amendment No.151 to DPR-69 3.
Safety Evaluation cc w/ enclosures:
See next page
- See previ_ous concurrence OFFICE pD{.1:LA PDI-1/@$3,, )
.)TSB*
OGC*
PQl-J:0 DMcDonN:N CIGrimes JHull NNkM m
CVogan W 0FFICIAL RECORD COPY 8/28/92 9/1/92 Y/3/92 O S/92 Q /% /92 OME
/
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FILENAME: A:\\CCM82776.AMD