ML23180A236

Correction of Errors on Technical Specification Pages

ML23180A236
Person / Time
Site:	Calvert Cliffs
Issue date:	06/29/2023
From:	David Helker Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EPID L-2019-LLA-0261
Download: ML23180A236 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com June 29, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318

Subject:

Correction of Errors on Technical Specification Pages

Reference:

1. Letter from Andrea G. Mayer (U.S. NRC) to David P. Rhoades (Exelon Generation Company), Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 336 and 314 Concerning Reactor Coolant Pump Flywheel Inspection Program (EPID L-2019-LLA-0261), dated August 13, 2020 (Accession No. ML20182A194)

2. Letter from Andrea G. Mayer (U.S. NRC) to David P. Rhoades (Exelon Generation Company), Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 340 and 318 to Add Containment Sump Technical Specifications (EPID L-2020-LLA-0256), dated December 14, 2021 (Accession No. ML21299A005)

3. SECY-96-238, Proposed Guidance for Correction of Technical Specification Typographical Errors, dated November 19, 1996 (Accession No. 9611250030)

4. NRC Staff Guidance Memorandum, License Amendment Corrections of Technical Specifications, dated January 16, 1997 (Accession No. ML103260096)

This letter requests Nuclear Regulatory Commission (NRC) approval of a correction of two errors in the Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2 Technical Specifications (TS).

A typographical error on TS page 5.5-10 was introduced during the processing of License Amendments 336 and 314 for Units 1 and 2 (Reference 1). The typographical error inadvertently listed the approved TS Amendment for CCNPP Unit 1 in the bottom right-hand corner of the page as 316 instead of 336.

A typographical error on TS page 5.5-16 was introduced during the processing of License Amendments 340 and 318 for Units 1 and 2 (Reference 2). The typographical error inadvertently omitted TS 5.5.15 Parts c and d, at the top of TS page 5.5-16.

The errors were neither addressed in the notice to the public nor reviewed by the NRC, and thus fall within the scope of the guidance provided by SECY-96-238 (Reference 3) and the associated NRC Staff Guidance Memorandum (Reference 4).

U.S. Nuclear Regulatory Commission Correction of Errors on Technical Specification Pages Docket Nos. 50-317 and 50-318 June 29, 2023 Page 2 describes the typographical errors and applicability of SECY-96-238. Attachment 2 provides the pages from Amendments 336/314 and 340/318 as issued, with the requested corrections noted. Attachment 3 contains the corrected, clean copy pages.

There are no regulatory commitments contained in this submittal.

If there are any questions or if additional information is needed, please contact Wendi Para at (267) 533-1105 or Wendi.Para@Constellation.com.

Respectfully, David P. Helker Sr. Manager, Licensing Constellation Energy Generation, LLC Attachments: 1. Description of Errors on Technical Specification Pages

2. Markup of Corrected Technical Specification Pages

3. Clean Copy of Corrected Technical Specification Pages cc: USNRC Regional Administrator, Region I USNRC Senior Resident Inspector, CCNPP USNRC Project Manager, CCNPP

ATTACHMENT 1 Description of Errors on Technical Specification Pages Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318

Correction of Errors on Technical Specification Pages Page 1 Technical Specification Error on TS Page 5.5-10 Description of Technical Specification Error A typographical error was introduced into the Calvert Cliffs Nuclear Power Plant (CCNPP)

Technical Specifications (TS) during the processing of License Amendments 336 and 314 for Units 1 and 2 (Reference 1). The following describes the specific error.

License Amendments 336 and 314 for CCNPP Units 1 and 2, respectively, revised certain inspection requirements in the Reactor Coolant Pump Flywheel Inspection Program documented in TS Chapter 5.5.15. License Amendments 336 and 314 for CCNPP Units 1 and 2, respectively, impacted TS pages 5.5-6 through 5.5-11. The typographical error inadvertently listed the approved TS Amendment for CCNPP Unit 1 in the bottom right-hand corner of TS page 5.5-10 as 316 instead of 336. This error was reflected in the NRC approved Safety Evaluation Report TS pages. All other impacted TS pages approved by License Amendments 336 and 314 for CCNPP Units 1 and 2, respectively, correctly reflected the Amendment Nos. in the bottom right-hand corner of the TS page.

Applicability of SECY 96-238 SECY 96-238 (SECY) (Reference 2) as documented in an NRC Staff Guidance Memorandum dated January 16, 1997 (Reference 3) provides guidance to correct inadvertent typographical errors in the TS pages. The SECY allows for the use of an administrative letter to correct a typographical error upon meeting two requirements: 1) the error must have occurred in a specific license amendment; and 2) the error was not reviewed as part of the license amendment.

Constellation Energy Generation, LLC (CEG) has determined that the error on TS page 5.5-10 was introduced during implementation of License Amendments 336 and 314 for CCNPP, Units 1 and 2, respectively. Therefore, the first SECY requirement is met.

The TS page Amendment Numbers are added to the bottom of the licensee-provided clean-copy TS pages at the end of the NRC approval process for a License Amendment Request.

The Amendment Numbers at the bottom of the TS pages are not the subject of NRC review during the safety evaluation of the License Amendment Request. Therefore, the second SECY requirement is met.

Based on meeting both requirements for SECY 96-238, the use of this administrative letter to correct the identified typographical error on the CCNPP, Units 1 and 2 TS page 5.5-10 is appropriate.

Correction of Errors on Technical Specification Pages Page 2 Technical Specification Error on TS Page 5.5-16 Description of Technical Specification Error A typographical error was introduced into the Calvert Cliffs Nuclear Power Plant (CCNPP)

Technical Specifications (TS) during the processing of License Amendments 340 and 318 for Units 1 and 2 (Reference 4). The following describes the specific error.

License Amendments 340 and 318 for CCNPP Units 1 and 2, respectively, made changes to the TS based on Technical Specifications Task Force Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI [Generic Safety Issue] -191 Issues. The licensee-provided clean copy TS pages inadvertently omitted the existing and unaffected TS 5.5.15 parts c and d, at the top of TS page 5.5-16. This error was reflected in the NRC approved Safety Evaluation Report TS pages.

Applicability of SECY 96-238 SECY 96-238 (SECY) (Reference 2) as documented in an NRC Staff Guidance Memorandum dated January 16, 1997 (Reference 3) provides guidance to correct inadvertent typographical errors in the TS pages. The SECY allows for the use of an administrative letter to correct a typographical error upon meeting two requirements: 1) the error must have occurred in a specific license amendment; and 2) the error was not reviewed as part of the license amendment.

CEG has determined that the error on TS page 5.5-16 was introduced during implementation of License Amendments 340 and 318 for CCNPP, Units 1 and 2, respectively. Therefore, the first SECY requirement is met.

When the associated license amendment request was submitted for approval, the changes identified for the adoption of TSTF-567 did not identify any required change to TS 5.5.15 Parts c and d, at the top of TS page 5.5-16. As such, the inadvertent omission was not the subject of NRC review during the safety evaluation of the associated License Amendment Request.

Therefore, the second SECY requirement is met.

Based on meeting both requirements for SECY 96-238, the use of this administrative letter to correct the identified typographical error on the CCNPP, Units 1 and 2 TS page 5.5-16 is appropriate.

Correction of Errors on Technical Specification Pages Page 3 References

1. Letter from Andrea G. Mayer (U.S. NRC) to David P. Rhoades (Exelon Generation Company), Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 336 and 314 Concerning Reactor Coolant Pump Flywheel Inspection Program (EPID L-2019-LLA-0261), dated August 13, 2020 (Accession No. ML20182A194)

2. SECY-96-238, Proposed Guidance for Correction of Technical Specification Typographical Errors, dated November 19, 1996, (Accession No. 9611250030)

3. NRC Staff Guidance Memorandum, License Amendment Corrections of Technical Specifications, dated January 16, 1997 (Accession No. ML103260096)

4. Letter from Andrea G. Mayer (U.S. NRC) to David P. Rhoades (Exelon Generation Company), Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 340 and 318 to Add Containment Sump Technical Specifications (EPID L-2020-LLA-0256), dated December 14, 2021 (Accession No. ML21299A005)

ATTACHMENT 2 Markup of Corrected Technical Specification Pages Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 TS Pages 5.5-10 5.5-16

Programs and Manuals 5.5 5.5 Programs and Manuals This constitutes the fourth and subsequent inspection periods.

3. If crack indications are found in any SG tube, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever results in more frequent inspection). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e. Provisions for monitoring operational primary to secondary LEAKAGE.

5.5.10 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit steam generator tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables;

b. Identification of the procedures used to measure the values of the critical variables;

c. Identification of process sampling points which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;

d. Procedures for the recording and management of data;

e. Procedures defining corrective actions for all off control point chemistry conditions; and 336 CALVERT CLIFFS - UNIT 1 5.5-10 Amendment No. 316 CALVERT CLIFFS - UNIT 2 Amendment No. 314

c. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and Programs and Manuals

d. Other appropriate limitations and remedial or compensatory 5.5 actions.

5.5 Programs and Manuals A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

5.5.16 Containment Leakage Rate Testing Program A program shall be established to implement the leakage testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B. This program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) 94-01, Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J, Revision 3-A, dated July 2012, and the conditions and limitations specified in NEI 94-01, Revision 2-A dated October 2008.

The peak calculated containment internal pressure for the design basis loss-of-coolant accident, P a , is 49.7 psig. The containment design pressure is 50 psig.

CALVERT CLIFFS - UNIT 1 5.5-16 Amendment No. 340 CALVERT CLIFFS - UNIT 2 Amendment No. 318

ATTACHMENT 3 Clean Copy of Corrected Technical Specification Pages Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 TS Pages 5.5-10 5.5-16

Programs and Manuals 5.5 5.5 Programs and Manuals This constitutes the fourth and subsequent inspection periods.

3. If crack indications are found in any SG tube, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever results in more frequent inspection). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e. Provisions for monitoring operational primary to secondary LEAKAGE.

5.5.10 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit steam generator tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a. Identification of a sampling schedule for the critical variables and control points for these variables;

b. Identification of the procedures used to measure the values of the critical variables;

c. Identification of process sampling points which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage;

d. Procedures for the recording and management of data;

e. Procedures defining corrective actions for all off control point chemistry conditions; and CALVERT CLIFFS - UNIT 1 5.5-10 Amendment No. 336 CALVERT CLIFFS - UNIT 2 Amendment No. 314

Programs and Manuals 5.5 5.5 Programs and Manuals

c. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and

d. Other appropriate limitations and remedial or compensatory actions.

A loss of safety function exists when, assuming no concurrent single failure, a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a. A required system redundant to system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

5.5.16 Containment Leakage Rate Testing Program A program shall be established to implement the leakage testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B. This program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) 94-01, Industry Guideline for Implementing Performance Based Option of 10 CFR Part 50, Appendix J, Revision 3-A, dated July 2012, and the conditions and limitations specified in NEI 94-01, Revision 2-A dated October 2008.

The peak calculated containment internal pressure for the design basis loss-of-coolant accident, Pa, is 49.7 psig. The containment design pressure is 50 psig.

CALVERT CLIFFS - UNIT 1 5.5-16 Amendment No. 340 CALVERT CLIFFS - UNIT 2 Amendment No. 318