ML053460269

Amendment Shutdown Margin and Operations Involving Positive Reactivity Additions (TAC Nos. MC7328 and MC7329)

ML053460269
Person / Time
Site:	Calvert Cliffs
Issue date:	01/19/2006
From:	Milano P NRC/NRR/ADRO/DORL/LPLA
To:	Vanderheyden G Calvert Cliffs
Milano P, NRR/DLPM 415-1457
References
TAC MC7329, TAC MC7328
Download: ML053460269 (14)

Text

January 19, 2006Mr. George Vanderheyden, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs ParkwayLusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 -AMENDMENT RE: SHUTDOWN MARGIN AND OPERATIONS INVOLVING POSITIVE REACTIVITY ADDITIONS (TAC NOS. MC7328 AND MC7329)

Dear Mr. Vanderheyden:

The Commission has issued the enclosed Amendment No. 277 to Renewed Facility OperatingLicense No. DPR-53 and Amendment No. 254 to Renewed Facility Operating LicenseNo. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated June 7, 2005, as supplemented on September 16, 2005.These amendments revise TS 3.1.1, "Shutdown Margin," to modify the restrictions in RequiredAction B.1 to allow positive reactivity additions as long as shutdown margin requirements in Limiting Condition for Operation 3.1.1 are maintained. The amendments also correct an administrative error regarding an incorrect TS reference in TS 3.4.17, "Special Test Exception RCS [reactor coolant system] Loops - Modes 4 and 5." A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in theCommission's next regular biweekly Federal Register notice.Sincerely,/RA/Patrick D. Milano, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-317 and 50-318

Enclosures:

1. Amendment No. 277 to DPR-53 2. Amendment No. 254 to DPR-69 3. Safety Evaluationcc w/encls: See next page January 19, 2006Mr. George Vanderheyden, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs ParkwayLusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 -AMENDMENT RE: SHUTDOWN MARGIN AND OPERATIONS INVOLVING POSITIVE REACTIVITY ADDITIONS (TAC NOS. MC7328 AND MC7329)

Dear Mr. Vanderheyden:

The Commission has issued the enclosed Amendment No. 277 to Renewed Facility OperatingLicense No. DPR-53 and Amendment No. 254 to Renewed Facility Operating LicenseNo. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated June 7, 2005, as supplemented on September 16, 2005.These amendments revise TS 3.1.1, "Shutdown Margin," to modify the restrictions in RequiredAction B.1 to allow positive reactivity additions as long as shutdown margin requirements in Limiting Condition for Operation 3.1.1 are maintained. The amendments also correct an administrative error regarding an incorrect TS reference in TS 3.4.17, "Special Test Exception RCS [reactor coolant system] Loops - Modes 4 and 5." A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in theCommission's next regular biweekly Federal Register notice.Sincerely,/RA/Patrick D. Milano, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-317 and 50-318

Enclosures:

1. Amendment No. 277 To DPR-53

2. Amendment No. 254 To DPR-69 3. Safety Evaluationcc w/encls: See next pageAccession Number: ML053460269OFFICELPLI-1/PMLPLI-1/LASPWB/BCOGCLPLI-1/BCNAMEPMilanoSLittleJNakoskiRLaufer DATE01/03/0601/03/0612/09/0501/13/0601/17/06OFFICIAL RECORD COPY DATED: January 19, 2006AMENDMENT NO. 277 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53CALVERT CLIFFS UNIT 1AMENDMENT NO. 254 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69CALVERT CLIFFS UNIT 2PUBLICLPLI-1 R/F R. LauferRidsNrrDorlLpla P. MilanoRidsNrrPMPMilano S. LittleRidsNrrLASLittle J. NakoskiRidsNrrDssSpwt Y. Hsii T. BoyceRidsNrrDirsItsb J. Trapp, RI G. Hill (2)

OGC RidsOgcMailCenter ACRSRidsAcrsAcnwMailCentercc: Plant Service list Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:

PresidentCalvert County Board of Commissioners 175 Main Street Prince Frederick, MD 20678Carey Fleming, EsquireSr. Counsel - Nuclear Generation Constellation Generation Group, LLC 750 East Pratt Street, 17 th floorBaltimore, MD 21202Lou LarragoiteCalvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs ParkwayLusby, MD 20657-4702Resident InspectorU.S. Nuclear Regulatory Commission

P.O. Box 287 St. Leonard, MD 20685Mr. R. I. McLean, AdministratorRadioecology Environ Impact Prog Department of Natural Resources Nuclear Evaluations 580 Taylor Avenue Tawes State Office Building Annapolis, MD 21401Regional Administrator, Region IU.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406Kristen A. Burger, EsquireMaryland People's Counsel 6 St. Paul Centre Suite 2102 Baltimore, MD 21202-1631Patricia T. Birnie, EsquireCo-Director Maryland Safe Energy Coalition P.O. Box 33111 Baltimore, MD 21218Mr. Roy HickokNRC Technical Training Center 5700 Brainerd Road Chattanooga, TN 37411-4017 CALVERT CLIFFS NUCLEAR POWER PLANT, INC.DOCKET NO. 50-317CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO. 1AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 277 Renewed License No. DPR-531.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Calvert Cliffs Nuclear Power Plant, Inc. (thelicensee) dated June 7, 2005, as supplemented on September 16, 2005,complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (I) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 2.C.2. of Renewed Facility Operating License No. DPR-53 is hereby amended to read as follows: 2.Technical SpecificationsThe Technical Specifications contained in Appendices A and B, as revisedthrough Amendment No. 277, are hereby incorporated into the license. The licensee shall operate the facility in accordance with the TechnicalSpecifications.3.This license amendment is effective as of the date of its issuance and shall beimplemented within 30 days.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Richard J. Laufer, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical SpecificationsDate of Issuance: January 19, 2006 CALVERT CLIFFS NUCLEAR POWER PLANT, INC.DOCKET NO. 50-318CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO. 2AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 254 Renewed License No. DPR-691.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Calvert Cliffs Nuclear Power Plant, Inc. (thelicensee) dated June 7, 2005, as supplemented on September 16, 2005,complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (I) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 2.C.2. of Renewed Facility Operating License No. DPR-69 is hereby amended to read as follows: 2.Technical SpecificationsThe Technical Specifications contained in Appendices A and B, as revisedthrough Amendment No. 254, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the TechnicalSpecifications.3.This license amendment is effective as of the date of its issuance and shall beimplemented within 30 days.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Richard J. Laufer, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical SpecificationsDate of Issuance: January 19, 2006 ATTACHMENT TO LICENSE AMENDMENTSAMENDMENT NO. 277 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53AMENDMENT NO. 254 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69DOCKET NOS. 50-317 AND 50-318Replace the following pages of the Appendix A Technical Specifications with the attachedrevised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.Remove PagesInsert Pages3.1.1-23.1.1-23.4.17-13.4.17-1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 277 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53AND AMENDMENT NO. 254 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69CALVERT CLIFFS NUCLEAR POWER PLANT, INC.CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2DOCKET NOS. 50-317 AND 50-31

81.0 INTRODUCTION

By letter dated June 7, 2005, as supplemented on September 16, 2005 (AgencywideDocuments Access and Management System (ADAMS) Accession Nos. ML051660195 and ML052650346, respectively), the Calvert Cliffs Nuclear Power Plant, Inc. (the licensee)submitted a request for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2(Calvert Cliffs 1 and 2) Technical Specifications (TSs). The requested changes would revise TS 3.1.1, "Shutdown Margin [SDM]," to modify Required Action B.1, which restricts a positive reactivity addition. The proposed amendments would also correct an administrative error regarding an incorrect TS reference in TS 3.4.17, "Special Test Exception RCS [reactor coolant system] Loops - Modes 4 and 5." The September 16, 2005, letter provided additionalinformation that clarified the application, did not expand the scope of the application asoriginally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register dated July 5, 2005(70 FR 38716).

2.0 REGULATORY EVALUATION

2.1 Proposed Changes to TS Sections 3.1.1 and 3.4.17The licensee proposed to revise Required Action B.1 in Limiting Condition for Operation (LCO)3.1.1 by replacing the existing required action statement stating "[s]uspend positive reactivitychanges" with the statement to "[s]uspend operations involving positive reactivity additions that could result in loss of Required SDM." This proposed change is similar to those proposed in the Technical Specification Task Force (TSTF) Change Traveler TSTF-286, Revision 2, "Operations Involving Positive Reactivity Insertion," approved by the Nuclear Regulatory Commission (NRC) on March 20, 2000 (Reference 3).The licensee also proposed to correct an administrative error associated with prior AmendmentNos. 266 and 243 to Renewed Facility Operating License Nos. DPR-53 and DPR-69, dated May 6, 2004 (References 4 and 5), for Calvert Cliffs 1 and 2, respectively. Specifically, thelicensee requested to revise LCO 3.4.17.b by replacing the reference to LCO 3.9.1 with areference to LCO 3.1.1.General Design Criterion (GDC) 26, "Reactivity control system redundancy and capability," inAppendix A to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50) requirestwo independent control systems of different design principles capable of: (1) reliablycontrolling reactivity changes with appropriate margin to assure that under conditions of normal operation, including anticipated operational occurrences (AOO), specified acceptable fueldesign limits (SAFDL) are not exceeded, and (2) holding the reactor core subcritical under cold conditions.2.2 Regulatory Requirements and GuidanceCompliance with GDC 26 is met by the use of movable control element assemblies (CEA) andsoluble boric acid in the RCS. The CEA system provides the SDM during power operation andis capable of making the core subcritical rapidly enough to prevent exceeding SAFDLs, assuming the CEA of highest reactivity worth remains fully withdrawn following a reactor scram.

The soluble boron system can compensate for fuel depletion during operation and all xenonburnout reactivity changes, and maintain the reactor subcritical under cold conditions.During power operation, SDM is assured by operating with the shutdown CEAs fully withdrawnand the regulating CEAs within the limits specified in LCO 3.1.6. When the unit is in theshutdown and refueling modes, the SDM requirements are met by means of adjustments to the RCS boron concentration. LCO 3.1.1 specifies the SDM requirement during Modes 3, 4, and 5operation, which provides sufficient subcritical reactivity margin to assure that the SAFDLs willnot be exceeded for normal shutdown and AOOs.The proposed change to LCO 3.1.1, Required Action B.1, adopts generic changes in industryTSTF-286, Revision 2. TSTF-286 revises Required Actions that suspend operations involving positive reactivity additions and LCO notes to prevent operations involving a reduction in RCS boron concentration by limiting the introduction into the RCS of reactivity more positive than that required to meet the required SDM. The NRC staff evaluation of the proposed changes will useTSTF-286, Revision 2, as a guide to ensure continued compliance with GDC 26.

3.0 TECHNICAL EVALUATION

3.1 LCO 3.1.1, Required Action B.1 - Restriction on Positive Reactivity Addition TS LCO 3.1.1 requires that the SDM be within the limits specified in the Core Operating LimitsReport (COLR) during operation in Modes 3, 4, and 5. TS LCO 3.1.1 also specifies that, when in Mode 5 with pressurizer level < 90 inches, the RCS level shall be above the bottom of the hot leg nozzles and all sources of non-borated water shall be 88 gallons per minute (gpm). WithRCS level at or below the bottom of the hot leg nozzle, Required Action B.1 requires the operators to suspend positive reactivity changes and Required Action B.2 requires the operators to initiate action to increase RCS level to above the bottom of the hot leg nozzles immediately. Because Required Action B.2 is generally accomplished by taking water from the refueling water tank (RWT) and adding it to the RCS, a potential conflict exists between Required Actions B.1 and B.2 when the RWT boron concentration is lower than the RCS boron concentration. This can happen if the RCS boron concentration is elevated above the requiredSDM and the RWT boron concentration is at the SDM; thus adding the RWT water into the RCS would result in positive reactivity addition. Therefore, the licensee proposed to revise Required Action B.1 to "[s]uspend operations involving positive reactivity additions that could result in loss of required SDM." With this proposed change, a positive reactivity addition is allowed as long as the required SDM is maintained, and therefore, resolves the potentialconflict.The required SDM specified in the COLR is an initial condition assumed in safety analyses. The safety analyses establish the minimum SDM that ensures the SAFDLs are not exceeded for normal operation and AOOs. The most limiting accident for the SDM requirements is a main steam line break (MSLB). The SDM requirements for Modes 3 and 4 also protect against an uncontrolled CEA withdrawal from a hot zero-power condition and a CEA ejection. For Mode 5 (which relates to Required Action B.1), the primary safety analysis that relies on the SDM limit is for boron dilution events. In the Mode 5 boron dilution event analysis, the required SDM defines the reactivity differencebetween an initial subcritical boron concentration and the corresponding critical boron concentration. These values, in conjunction with the RCS inventory and the assumed dilution flow rate, directly affect the results of the analysis. With the RCS level below the bottom of the hot leg nozzles, while in Mode 5 with the pressurizer level less than 90 inches, the consequences of a boron dilution event may exceed the results of the analysis that assumed the RCS level above the bottom of the hot leg nozzles. To reduce the potential for such anevent, Required Action B.1 requires immediate suspension of positive reactivity addition.

However, Required Action B.1 only reduces the potential for, but does not preclude, a borondilution event. An important immediate action is the addition of RCS inventory to increase the RCS level to above the bottom of the hot leg nozzles (i.e., Required Action B.2) to prevent uncovering the reactor core. Adding inventory from the RWT will not create a boron dilution event because the RWT boron concentration is at or above the concentration assumed in the calculated SDM. TSTF-286, Revision 2, allows licensees to revise their plant TS LCO Required Actions andnotes that require suspension of operations involving positive reactivity additions or preclude reduction in boron concentration by placing a limit on positive reactivity addition to within the TS-required SDM. TSTF-286 thus provides the flexibility necessary for continued safe reactoroperations, while also limiting any potential for excessive positive reactivity addition to the core.

During conditions in which these Required Actions may be required, various activities for unit operation must be continued to maintain RCS inventory and control RCS temperature. These activities that involve inventory makeup from sources with boron concentrations less than the current RCS concentration need not be precluded in the TSs so long as there still is assurancethat the required SDM is maintained for the worst-case overall effect on the core. The NRC hasapproved changes to various LCOs and Required Actions in a previous application dated July 29, 2003 (Reference 4), based on TSTF-286, Revision 2. The proposed change to LCO 3.1.1, Required Action B.1 is similar in nature to these changesapproved by NRC and TSTF-286, Revision 2. With the RCS level at or below the bottom of thehot leg nozzles in Mode 5 with the pressurizer < 90 inches, immediate action must be taken to increase the RCS inventory from the RWT. Without the change to Required Action B.1 thatrequires immediate suspension of a positive reactivity change, the RCS inventory makeup activity cannot be pursued if the RWT boron concentration is lower than the current RCS boronconcentration. The revised Required Action B.1 would allow for continued safe operation with the RCS inventory makeup to above the bottom of the hot leg nozzles as long as the required SDM is met. By limiting the positive reactivity addition to the required SDM, the initial boron concentration assumed for the safety analysis and the analysis results for boron dilution events would remain valid providing reasonable assurance that the SAFDLs will not be exceeded. Theproposed change to LCO 3.1.1 Required Action B.1 st ill requires suspension of operationsinvolving positive reactivity additions that could result in loss of required SDM. Therefore, the proposed change continues to meet the SDM requirement and GDC 26 and is acceptable.3.2LCO 3.4.17.b - Correction of Administrative Error The licensee proposed to correct an administrative error contained in its previous application,dated July 29, 2003 (Reference 4), that changed LCO 3.4.17.b. LCO 3.4.17.b specified that"[n]o operations are permitted which could cause introduction of coolant into the RCS with boron concentration less than that required to meet the minimum boron concentration ofLCO 3.9.1." In its amendment application of June 7, 2005, as supplemented by a letter datedSeptember 16, 2005 (Reference 2), the licensee proposed to change the last few words in LCO 3.4.17.b from "minimum boron concentration of LCO 3.9.1" to "SDM of LCO 3.1.1." Thelicensee indicated that LCO 3.4.17.b in its July 29, 2003, application should have referencedLCO 3.1.1 instead of LCO 3.9.1. However, it had improperly marked-up the proposed TSs change in Attachment 2, although it was properly identified on Page 7 of Attachment 1 to the July 29, 2003, application. Also, the NRC staff's safety evaluation (Reference 5) referencedLCO 3.1.1 in the discussion for accepting the proposed change. Whereas LCO 3.9.1 specifiesthe boron concentration requirement during Mode 6 operation, LCO 3.4.17 specifies conditionsfor special test exception for RCS loops during Modes 4 and 5. Thus, it is appropriate to reference LCO 3.1.1 since it specifies the SDM requirement during Modes 3, 4, and 5. TheNRC staff concludes that the proposed change is acceptable since it provides the applicable TSLCO reference.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Maryland State official was notified of theproposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20. The NRC staff hasdetermined that the amendments involve no significant increase in the amounts, and nosignificant change in the types, of any effluents that may be released offsite, and that there isno 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 (70 FR 38716). Accordingly, the amendments meet the eligibility criteria for categoricalexclusion set forth in 10 CFR 51.22©)(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.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above that (1) there isreasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of the amendments will not be inimical to thecommon defense and security or to the health and safety of the public.

7.0 REFERENCES

1.Letter from George Vanderheyden, Constellation Generation Group, LLC, to U.S.Nuclear Regulatory Commission, "Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2;Docket Nos. 50-317 & 50-318, License Amendment Request: Technical Specification Changes to Modify Requirements Related to Positive Reactivity Addition," June 7, 2005.2.Letter from Bruce S. Montgomery, Constellation Generation Group, LLC, to U.S.Nuclear Regulatory Commission, "Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2;Docket Nos. 50-317 & 50-318, Response to Request for Additional Information:

Technical Specification Changes to Modify Requirements Related to Positive Reactivity Addition (TAC Nos. MC7328 and MC7329)," September 16, 2005.3.Letter from W. D. Beckner, U.S. Nuclear Regulatory Commission, to J. Davis, NuclearEnergy Institute, July 6, 2000.4.Letter from George Vanderheyden, Constellation Generation Group, LLC, to U.S.Nuclear Regulatory Commission, "Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2;Docket Nos. 50-317 & 50-318, License Amendment Request: Improvement to the Definition of Operations Involving Positive Reactivity Changes," July 29, 2003.5.Letter from G. S. Vissing, U.S. Nuclear Regulatory Commission, to GeorgeVanderheyden, CCNPP, "Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 & 2Amendment Re: Technical Specification Changes to Modify Requirements Related to Positive Reactivity Additions (TAC Nos. MB8478 and MB8479)," May 6, 2004.

Principal Contributor: Y. Hsii Date: January 19, 2006