Text

Issuance of Amendments Regarding Adoption of Technical Specification Task Force 439-A, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Limiting Condition...
	ML14009A320
Person / Time
Site:	Calvert Cliffs
Issue date:	01/29/2014
From:	Nadiyah Morgan; Plant Licensing Branch 1
To:	George Gellrich; Calvert Cliffs
	Morgan N
References
	TAC MF0617, TAC MF0618
	Download: ML14009A320 (28)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 29, 2014 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2-ISSUANCE OF AMENDMENTS REGARDING ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE 439-A, "ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO

[LIMITING CONDITION OF OPERATION]" (TAC NOS. MF0617 AND MF0618)

Dear Mr. Gellrich:

The Commission has issued the enclosed Amendment No. 304 to Renewed Facility Operating License No. DPR-53 and Amendment No. 282 to Renewed Facility Operating License No. DPR-69 for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated January 28, 2013, as supplemented by letter dated April 1, 2013.

The amendments revise TS 1.3, "Completion Times" Example 1.3-3, TS 3.6.6, "Containment Spray and Cooling Systems," TS 3. 7.3, "Auxiliary Feedwater (AFW) System," TS 3.8.1, "AC

[Alternating Current] Sources-Operating," and TS 3.8.9, "Distribution Systems-Operating" by eliminating the second completion time in accordance with TS Task Force 439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO

[limiting condition for operation]."

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

SJPeprely,

/, /l .. ----

/

./Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosures:

1. Amendment No. 304 to DPR-53

2. Amendment No. 282 to DPR-69

3. Safety Evaluation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CALVERT CLIFFS NUCLEAR POWER PLANT, LLC DOCKET NO. 50-317 CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NO.1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 304 Renewed License No. DPR-53

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Calvert Cliffs Nuclear Power Plant, LLC (the licensee) dated January 28, 2013, as supplemented by letter dated April 1, 2013, 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 the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated 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 Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 304, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: January 29, 2014

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CALVERT CLIFFS NUCLEAR POWER PLANT, LLC DOCKET NO. 50-318 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO.2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 282 Renewed License No. DPR-69

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Calvert Cliffs Nuclear Power Plant, LLC (the licensee) dated January 28, 2013, as supplemented by letter dated April 1, 2013, 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 the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated 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 Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 282, are hereby incorporated into this license.

The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION Benjamin G. Beasley, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: January 29, 2014

ATTACHMENT TO LICENSE AMENDMENTS AMENDMENT NO. 304 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AMENDMENT NO. 282 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 DOCKET NOS. 50-317 AND 50-318 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3 3 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 1.3-2 1.3-2 1.3-3 1.3-3 1.3-6 1.3-6 1.3-7 1.3-7 3.6.6-1 3.6.6-1 3.6.6-2 3.6.6-2 3.7.3-1 3.7.3-1 3.7.3-2 3.7.3-2 3.7.3-3 3.7.3-3 3.8.1-2 3.8.1-2 3.8.1-4 3.8.1-4 3.8.9-1 3.8.9-1 3.8.9-2 3.8.9-2

rules, regulations, and orders of the Commission, now or hereafter applicable; and is subject to the additional conditions specified and incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady-state reactor core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 304, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

(a) For Surveillance Requirements (SRs) that are new, in Amendment 227 to Facility Operating License No. DPR-53, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 227. For SRs that existed prior to Amendment 227, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 227.

(3) Additional Conditions The Additional Conditions contained in Appendix C as revised through Amendment No. 297 are hereby incorporated into this license. Calvert Cliffs Nuclear Power Plant, LLC shall operate the facility in accordance with the Additional Conditions.

(4) Secondary Water Chemistry Monitoring Program The Calvert Cliffs Nuclear Power Plant, LLC, shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:

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

b. Identification of the procedures used to quantify parameters that are critical to control points; Amendment No. 304

C. This license is deemed to contain and is subject to the conditions set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act, and the rules, regulations, and orders of the Commission, now and hereafter applicable; and is subject to the additional conditions specified and incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor steady-state core power levels not in excess of 2737 megawatts-thermal in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendices A and 8, as revised through Amendment No. 282 are hereby incorporated into this license.

The licensee shall operate the facility in accordance with the Technical Specifications.

(a) For Surveillance Requirements (SRs) that are new, in Amendment 201 to Facility Operating License No. DPR-69, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 201. For SRs that existed prior to Amendment 201, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 201.

(3) Less Than Four Pump Operation The licensee shall not operate the reactor at power levels in excess of five (5) percent of rated thermal power with less than four (4) reactor coolant pumps in operation. This condition shall remain in effect until the licensee has submitted safety analyses for less than four pump operation, and approval for such operation has been granted by the Commission by amendment of this license.

(4) Environmental Monitoring Program If harmful effects or evidence of irreversible damage are detected by the biological monitoring program, hydrological monitoring program, and the radiological monitoring program specified in the Appendix 8 Technical Specifications, the licensee will provide to the staff a detailed analysis of the problem and a program of remedial action to be taken to eliminate or significantly reduce the detrimental effects or damage.

Amendment No. 282

Completion Times 1.3 1.3 Completion Times continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition), and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified 11 time zero. 11 This modified 11 time zero 11 may be expressed as a repetitive time (i.e., 11 0nce per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , 11 where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase 11 from discovery . . . 11 CALVERT CLIFFS - UNIT 1 1.3-2 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

Completion Times 1.3 1.3 Completion Times The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1. 3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months met.

Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months ) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

CALVERT CLIFFS - UNIT 1 1.3-3 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

Completion Times 1.3 1.3 Completion Times EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore 7 days Function X Function X train train to OPERABLE inoperable. status.

B. One B.l Restore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function y Function Y train train to OPERABLE inoperable. status.

c. One C.l Restore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X Function X train train to OPERABLE inoperable. status.

AND OR One C.2 Restore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function y Function Y train train to OPERABLE inoperable. status.

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

CALVERT CLIFFS - UNIT 1 1. 3-6 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

Completion Times 1.3 1.3 Completion Times If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e.,

initial entry into Condition A).

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those conditions are not inappropriately extended.

CALVERT CLIFFS - UNIT 1 1.3-7 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

Containment Spray and Cooling Systems 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

MODE 3, except containment spray is not required to be OPERABLE when pressurizer pressure is < 1750 psia.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray A.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable. spray train to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A AND not met.

B.2 Be in MODE 3 with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months pressurizer pressure

< 1750 psia.

c. One containment C.1 Restore containment 7 days cooling train cooling train to inoperable. OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.6.6-1 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

Containment Spray and Cooling Systems 3.6.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two containment D.1 Restore one 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months cooling trains containment cooling inoperable. train to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C AND or D not met.

E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. Two containment spray F.1 Enter LCO 3.0.3. Immediately trains inoperable.

OR Any combination of three or more trains inoperable.

CALVERT CLIFFS - UNIT 1 3.6.6-2 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

AFW System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Auxiliary Feedwater (AFW) System LCO 3.7.3 Two AFW trains shall be OPERABLE.

NOTE----------------------------

AFW trains required for OPERABILITY may be taken out of service under administrative control for the performance of periodic testing.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

NOTE-------------------------------------

LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One steam-driven AFW A.1 Align remaining 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months pump inoperable. OPERABLE steam-driven pump to automatic initiating status.

AND A.2 Restore steam-driven 7 days pump to OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.7.3-1 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

AFW System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One motor-driven AFW B.1 Align standby steam- 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months pump inoperable. driven pump to automatic initiating status.

AND B.2 Restore motor-driven 7 days pump to OPERABLE status.

c. Two AFW pumps C.1 Align rema 1m ng 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. OPERABLE pump to automatic initiating status.

AND C.2 Verify the other 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months unit's motor-driven AFW pump is OPERABLE.

AND C.3 Verify, by 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months administrative means, the cross-tie valve to the opposite unit is OPERABLE.

AND C.4 Restore one AFW pump 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.7.3-2 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

AFW System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One AFW train D.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable for OPERABLE status.

reasons other than Condition A, B, or C.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A, AND B, C, or D not met.

E.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months F. Two AFW trains F.1 --------NOTE -------

inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to Immediately restore one AFW train to OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.7.3-3 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

AC Sources-Operating 3.8.1 ACTIONS

NOTE-------------------------------------

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required A.1 Perform SR 3.8.1.1 or 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months LCO 3.8.1.a offsite SR 3.8.1.2 for circuit inoperable. required OPERABLE AND offsite circuits.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no discovery of no offs ite power offsite power to available inoperable one train when its redundant concurrent with required feature(s) inoperability of is inoperable. redundant required feature(s)

AND A.3 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months offsite circuit to OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.8.1-2 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

AC Sources-Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.4.2 Perform SR 3.8.1.3 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPERABLE DG(s).

AND B.5 Restore DG to 14 days OPERABLE status.

c. Required Action and C.1.1 Restore both DGs on 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months associated Completion the other unit to Time of Required OPERABLE status and Action B.1 not met. OC DG to available status.

OR C.1.2 Restore DG to OPERABLE status.

CALVERT CLIFFS - UNIT 1 3.8.1-4 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

Distribution Systems-Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating LCO 3.8.9 The AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystems to subsystems OPERABLE status.

inoperable.

B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months bus subsystem(s) subsystems to inoperable. OPERABLE status.

c. One DC electrical C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power distribution power distribution subsystem inoperable. subsystem to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months CALVERT CLIFFS - UNIT 1 3.8.9-1 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

Distribution Systems-Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two or more E.1 Enter LCO 3.0.3. Immediately electrical power distribution subsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and 7 days voltage to AC, DC, and AC vital bus electrical power distribution subsystems.

CALVERT CLIFFS - UNIT 1 3.8.9-2 Amendment No. 304 CALVERT CLIFFS - UNIT 2 Amendment No. 282

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 304 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-53 AMENDMENT NO. 282 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-69 CALVERT CLIFFS NUCLEAR POWER PLANT. LLC CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318

1.0 INTRODUCTION

By application dated January 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13030A133), as supplemented by letter dated April 1, 2013 (ADAMS Accession No. ML13093A012), Calvert Cliffs Nuclear Power Plant, LLC, the licensee, submitted a request to the Nuclear Regulatory Commission (NRC) for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 (Calvert Cliffs), Technical Specifications (TSs).

The supplement dated April 1, 2013, provided additional information that clarified the application. The NRC staff published a no significant hazards consideration determination in the Federal Register(FR) on May 28, 2013 (78 FR 31981).

The proposed changes revise TS 1.3, "Completion Times" Example 1.3-3, TS 3.6.6, "Containment Spray and Cooling Systems," TS 3.7.3, "Auxiliary Feedwater (AFW) System," TS 3.8.1, "AC [Alternating Current] Sources-Operating," and TS 3.8.9, "Distribution Systems-Operating" by eliminating the second completion time in accordance with TS Task Force (TSTF)-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [limiting condition for operation]."

2.0 REGULATORY EVALUATION

2.1 Systems Description 2.1.1 Containment Spray and Cooling Systems The TS 3.6.6, "Containment Spray and Cooling Systems," has a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for one inoperable containment spray train (Condition A) and a 7 day Completion Time for one inoperable containment cooling train (Condition C). Conditions A and C have a second Completion Time of 10 days from discovery of failure to meet the LCO. Restoring either one of the two inoperable conditions, i.e. either the inoperable containment spray train for Condition A Enclosure

or the inoperable containment cooling train for Condition C would result in exiting that Condition.

The second Completion Time is limiting if multiple entries into and out of these Conditions results in an indefinite period of time without meeting the LCO.

2.1.2 Auxiliary Feedwater System The TS 3.7.3, "Auxiliary Feedwater System (AFW) System," has a 7-day Completion Time for one inoperable steam driven AFW pump (Condition A), a 7-day Completion Time for one inoperable motor driven AFW pump (Condition B), and a 72-hour Completion Time for one AFW train inoperable for reasons other than Condition A, B, or C (Condition D). Conditions A, Band D have a second Completion Time of 10 days from discovery of failure to meet the LCO.

Restoring any one of the three inoperable conditions, i.e. either the inoperable steam driven AFW pump for Condition A, the inoperable motor driven AFW pump for Condition B or the inoperable AFW train for Condition D, would result in exiting that Condition. The second Completion Time is limiting if multiple entries into and out of these Conditions results in an indefinite period of time without meeting the LCO.

2.1.3 AC Sources - Operating The TS 3.8.1, "AC Sources- Operating," has a 72-hour Completion Time for one required offsite circuit inoperable (Condition A) and a 14-day Completion Time for one diesel generator inoperable (Condition B). Conditions A and B have a second Completion Time of 17 days from discovery of failure to meet the LCO 3.8.1.a or LCO 3.8.1.b. If Condition A orB is entered, and before that inoperable system is restored, the other Condition is entered, then Condition H applies, which is both Condition A and B inoperable, and plant operation is limited to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Should either inoperable Condition be restored, that Condition and Condition H is exited. The second Completion Time is limiting if repetitive entry into the previously restored Conditions results in the LCO not being met for an extended period of time.

2. 1.4 Distribution Systems - Operating The TS 3.8.9, "Distribution Systems- Operating," has an 8-hour Completion Time for one or more inoperable AC electrical power distribution subsystems (Condition A), a 2-hour Completion Time for one or more inoperable AC vital bus subsystems (Condition B), and a 2-hour Completion Time for one or more inoperable direct current (DC) electrical power distribution subsystems (Condition C). Conditions A, B, and C have a second Completion Time of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO. The second Completion Time limits plant operations from any potential allowed outage time extensions if a Condition in this LCO is entered, but before the Completion Time for that Condition is passed, a second different Condition is entered; and again, before the Completion Time for the second Condition is passed, the first Condition is entered again.

2.2 Proposed TS Changes

TS Example 1.3 elimination of the second Completion Time for Required Actions A.1 and B.1 and the addition of a discussion that requires administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO.

TS 3.6.6 -deletion of the second Completion Times from Required Actions A.1 and C.1, which state, "AND 10 days from discovery of failure to meet the [LCO]."

TS 3.7.3- deletion of the second Completion Times from Required Actions A.2, 8.2, and D.1, which states, "AND 10 days from discovery of failure to meet the [LCO]."

TS 3.8.1 -deletion of the second Completion Time from Required Action A.3 and 8.5, which states, "AND 17 days from discovery of failure to meet LCO 3.8.1.a or LCO 3.8.1.b."

TS 3.8.9 -deletion of the second Completion Times from Required Actions A.1, 8.1, and C.1 which states, "AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet [LCO]."

2.3 Regulatory Requirements and Guidance Documents The NRC staff reviewed the proposed changes to eliminate TS second completion times against the criteria in Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.36 and the precedent established in NUREG-1432, "Standard Technical Specifications [STS], Combustion Engineering Plants," Revision 4. Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses. In 10 CFR 50.36, the NRC established its regulatory requirements related to the content of the TSs, which include ( 1) safety limits, limiting safety systems settings and control settings, (2) LCOs, (3) surveillance requirements, (4) design features, and (5) administrative controls.

In NUREG-1432, a second Completion Time was included in the STS for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that would result in a single continuous failure to meet the LCO. These Completion Times (henceforth referred to as "second Completion Times") are joined by an "AND" logical connector to the Condition-specific Completion Time and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second Completion Time was to preclude entry into and out of the Actions for an indefinite period of time without meeting the LCO. The second completion time provides a limit on the amount of time that the LCO would not be met for various combinations of Conditions. The TSTF-439, Revision 2, deletes these second Completion Times from the affected Required Actions from the STS.

The regulations at 10 CFR 50.65(a)(1 ), the Maintenance Rule, requires each licensee to monitor the performance or condition of structures, systems, and components (SSCs) against licensee-established goals in a manner sufficient to provide reasonable assurance that the SSCs are capable of fulfilling their intended functions. The goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken. The effectiveness of these performance and condition monitoring activities, and associated goals and preventive maintenance activities, are evaluated at least every refueling cycle, not to exceed 24 months, per 10 CFR 50.65(a)(3).

By letter dated June 20, 2005 (ADAMS Accession No. ML051860296), the TSTF submitted a proposed change, TSTF-439, Revision 2, to the improved STS. The proposed TSTF- 439, Revision 2, was approved by the NRC in a letter dated January 11, 2006 (ADAMS Accession No. ML060120272).

3.0 TECHNICAL EVALUATION

Additional secondary completion times, such as limits on the period of time from discovery of the failure to meet the LCOs discussed above, were specified to prevent repeated entry and exit from alternating TS Required Actions. In its supplement dated April 1, 2013, the licensee stated that it has an action written in its action item tracking program to revise operations procedure titled, N0-1-200, "Control of Shift Activities," to include a statement similar to the following, "Alternating between LCO Conditions, in order to allow indefinite continued operation while not meeting the LCO, is not allowed." The licensee also stated that the procedure will be revised prior to implementation of the proposed TS change.

The licensee's revised discussion addresses the NRC staff's concern that the deletion of the second Completion Times could result in indefinite operation without restoration of the systems.

The Maintenance Rule requires licensees to monitor the performance or conditions of SSCs in a manner sufficient to provide reasonable assurances that SSCs are capable of fulfilling their intended functions. The Maintenance Rule provides a strong disincentive for the licensee's continuing to operate without restoring systems. The licensee's application states the following regarding the Maintenance Rule:

Under 10 CFR 50.65(a)(4), the risk impact of all inoperable risk-significant equipment is assessed and managed when performing preventative or corrective maintenance. The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide (RG) 1.182, "Assessing and Managing Risk before Maintenance Activities at Nuclear Power Plants." The RG 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed maintenance is acceptable.

Prior to the promulgation of 10 CFR 50.65, TSs were the primary rules governing operations, including what equipment must normally be in service, how long equipment can be out of service, compensatory actions, and surveillance testing to demonstrate equipment readiness.

The goal of TSs is to provide adequate assurance of the availability and reliability of equipment needed to prevent, and if necessary mitigate, accidents and transients. The Maintenance Rule supports this same goal by requiring a comprehensive process for performance and condition monitoring activities.

Under 10 CFR 50.65, the licensee assesses and manages the inoperable equipment; however, the rule also considers all inoperable risk-significant equipment. Under the TSs, the Completion Time for one system within a LCO is not generally affected by inoperable equipment in another LCO. However, the second Completion Time influenced the Completion Time for one system based on the condition of another system, but only if the two systems were required by the same LCO.

Plant Maintenance Rule programs implement risk-based configuration management programs that augment the deterministic Completion Times in the TSs. The performance and condition monitoring activities required by 10 CFR 50.65 identify poor maintenance practices that would result from multiple entries into the Actions of the TSs which would contribute to unacceptable unavailability of these SSCs.

Based on the above, the NRC staff finds that multiple, continuous entries into TS Conditions, without meeting the LCO, will be adequately controlled by (1) the licensee's administrative controls (operation procedures, etc), (2) the configuration risk management programs as implemented to meet the requirements of the Maintenance Rule to assess and manage risk, and (3) the requirements of Section 1.3 of the TS, "Completion Times." In addition, the NRC staff finds the Maintenance Rule provides adequate assurance against inappropriate use of combinations of TS Conditions that result in a single contiguous occurrence of failing to meet the LCO. Accordingly, consistent with TSTF-439, the NRC staff finds the proposed changes to Calvert Cliffs TS to be acceptable.

4.0 STATE CONSULTATION

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

5.0 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. 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, published in the FR on May 28, 2013 (78 FR 31981 ), that the amendments involve no significant hazards consideration, and there has been no public comment on such finding. 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 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 is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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 Contributor: K. Bucholtz Date: January 29, 2014

ML14009A320 *Via email OFFICE LPLI-1/PM LPLI-1/LA DSS/STSB/BC OGC LPLI-1/BC LPLI-1/PM STurk NAME NMorgan KGoldstein REIIiott BBeasley NMorgan

. (w/chanJles}_

DATE 1/10/2014 1/10/2014* 11/26/2013 1/22/2014 1/29/14 1/29/14

v t e Letter Sequence Approval
TAC:MF0617, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Approved, Closed) TAC:MF0618, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Approved, Closed)
Initiation Request Acceptance, Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2013-03-04 [Table View]

ML14009A320

Text

SUBJECT:

Dear Mr. Gellrich:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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