ML20195E353

Application for Amend to Licenses DPR-53 & DPR-69,changing Min Pressurization Temp in Tech Spec Figure 3.4-2c to 90 F. Fee Paid

ML20195E353
Person / Time
Site:	Calvert Cliffs
Issue date:	11/01/1988
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20195E358	List: ML20195E353 ML20195E364
References
GL-87-09, GL-87-9, NUDOCS 8811070355
Download: ML20195E353 (9)

Text

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S ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE. MARYLAND 21203 JostpH A.TIERNAN vict PatssotNT NUCLEAR eNEROf November I,1988 U. S. Nuclear Regulatory Commission

. Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Rig)fest for Amendment

REFERENCE:

(a) NRC Generic Letter 87-09, Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements Gentlemen:

The Baltimore Gas and Electric Company hereby requ?sts an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Calvert Ceiffs Unit Nos.1 & 2, respectively, with the submittal of the proposed changes to the Technier? Specifications.

CifANGE MQJ.

(BGAE FCR 88-147)

Delete pages 3/4 4 25a&b of the Unit 2 Techulcal Specifications and seplace with 3/4 4-25b attached to this transmittal.

DISCUSSION This proposed amendment would change Technical Specification 3.4.9.l.

Specifically, the Minimum Pressurization Temperature (MPTg between 530 and 20 psia on Technical Specification Figure 3.4-2c would shift to 90 F (20 F to the right). This amendment request resulted from a QA audit that identified part of the MPT on the Unit 2 Operator's Curves as being incorrect.

The Nil Ductility Transition Temperatures (NDTTs) for each reactor vessel are different and associated with different vessel components. For Unit 1, the maximum NDTT (based on drop weight tests) of +10 F is based on the nozzles, upper shell and closure head 0

peals. For Unit 2, the maximum NDTT cf +30 F is based on the vessel flange, p[

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- Document Control Desk November 1,1988 Page 2

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In accordance with the original design code, ASME Boiler and Pressure Vessel Code, Section !!!, 1965, through Winter 1967 Addenda, this portion of MPT is equal to 0

0 60 F. Therefore, the MPT between 530 and 20 psia for Unit I is 70 F and for NDTT Ns +90 F. This is identified in the reactor vessel technical manual.

Unit i.

Based on the vessel technical manual, the MPT in the Unit i Technical Specification 0

should be 70 F and is correctly listed as such, llowever, the Unit 2 Technical 0

Specification identifies the MPT in question to be 70 F. This is incorrect. The MPT of concern should be 90 F. This portion of tite Operator's Curves is off by 20 F in the non-conservative direction.

i As a result of the audit finding, corrective actions were immediately initiated. The I

operating curves in the Unit 2 Emergency Operating Procedures were changed to reflect l

correct requirements from the technical manual. All shift crews received training on the new limit. Plant operating history was reviewed and the results indicated that a 0

MPT limit of 90 F for the Unit 2 reactor vessel flange has always been implemented despite the less conservative Technical Specification limit.

The applicable maintenance procedures are based on the technical manual requirements. Our tensioning procedures ensure that flange temperature limits are not violated during stud tensioning.

A metallurgical review determined that going below the MPT limit, with or without j

stress, does not change the material properties. Since the failure mechanism at low temperature is catastrophic brittle fracture, the fact that failure has not occurred i

shows that the venel fracture toughness characteristics have not been affected.

l Additionally, this area is subject to volumetric inservice insention.

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Our h/4S vendu vtas consulted on this issue arvi they stated that part of the basis for 0

the 90 F limit is founded en the minimum allowable temperature at which the reactor I'

ven.1 head bolts can be bolted (teasioned) to the vessel flange and pre-stressed, i

without inducing local tensile stresses in the vessel material which might lead to brittle fracture. This limit is c?llej the Minimum Bolt-up Temperature and is identified in the sesset technie.d manual.

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The NSSS vendor verit'ied that the MPT ' operating curve' applies only when the reactor l

vessel studs are tensioned. Our bolt up procedures ensure that flange temperature l

limits are not violated during stud tensioning.

l does not have to be adjusted for l

For the Minimum Bolt-up Temperature, the RTNDT irradiation effects. This is because the limiting component, the vessel fit nge, is not subject to significant fluence throughout vessel life. This proposal would shift the MPT line on the ' Operator's Curve" to the right 20 F (in the conservative direction),

l No other portions of the curves would be changed. The rectangular indentation at l

530 psis between the Lowest Service Temperature and Minimum Holt-up Temperature would 0

stay.

The step reduction at 20 psia to 40 F would also remain.

0 The Lowest Service Temperature curve includes a 6 F instrument error correction factor.

We have verified vIth the NSSS vendor that no temperature instrument error was included in the original NRC-spproved MPT and was never required. The instrumentation used to measure Minimum Bolt-up Temperature is within an accuracy of I-2 F.

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Document Contr:t Desk November 1,1988 Page 3 DETERMINATION OF SIGNIFICANT IIAZARDS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant incrsase in the probability or consequences of an accident previously evaluated; or Justification:

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Shifting the MPT curve between 530 and 20 psia for Unit 2 from 70 F to 90 F is a conservative change.

Plant operations on Technical Specification Figure 3.4-2c must be to the right of the curve line. A 20 F shift to the right removes area to operate. This shift would be done in accordance with the reactor vessel technical manual and the applicable ASME Code. The probability of a previously evaluated accident would not be significantly increased. Nothing in the Technical Specifications would be changed that would increase that likelihood. In addition, the proposed change would not increase significantly the consequences of a previously evaluated accident.

Brittle fracture of the reactor vessel is not an analyzed accident.

Fracture mechanics are discussed in Chapter 4 of our UFSAR but vessel fracture is not considered to be 7.

credible accident.

(ii) create the pos:ibility of a new or different type of secident from any accident previously evaluated; on Justification:

This change does not create a new or different type of accident by shifting a pressure-temperature limit in the conservative direction. This oroposed based >n uur desl n code and other regulatory change would impose a limit 6

regiairements No new or different actior.s would take piace that could create an accident.

l (iii) involve a significant reduction in a margin of safety.

l The proposed amendment would shift a temperature limit in the conservatise l

direction and actually impose more stringent operating requirements. A l

margin of safety would not be reduced because the change is being made to ensure conformance with the applicable ASME Code and the reactor vessel technical manual.

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e Documsnt Control Desk November 1,19J8 Page 4 CHANGE MQ,_2 (BGAE FCR 88-148)

Change pages 0-1, 0-2, 3-30, 3-31, 3-34, 3-43, 3-48, 3-53, 11-1, 11-5, 11-6, 11-7, 11-11, 11-12, 11-13, 11-14, 11-15, 11-16, 11-17, 12-1, 12-2, 12-13 in Section ~ 3/4, plus pages B 3/4 0-1, B 3/4 0-3, and B 3/4 0-4 sali common to the Unit I and Unit 2 Tschnical Specifications. Also Unit I pages 7-63, 7-66, 7-69, 7-72, 7-73, 7-75, 7 77 and Unit 2 i

pages 7-55,.7-58, 7-61, ~ 64, 7-65, 7-67, and 7-69. Changes arc shown on the marked-up pages attached to this transmittal.

DISCUSSION Reference (a). NRC Generic Letter 87-09, discusses three concerns with the general requirements of Sections 3.0 and 4.0 of the Standard 4chnical Specifications (STS) on the applicability of Limiting Conditions for Operathn ILCO) and Surveillance Requirements. it gives guidance on alternatives to resolve these concerns. This change follows that guidance.

1 First Concern l

The first concern is with Specification 3.0.4 Specification 3.0.4 prevents entry into an OPERATIONAL MODE or other specified condition unless the conditions for LCOs are met without reliance on provisions in ACTION requirements. This i.npacts operation in l

two ways. First. It delays startup if conformance to the ACTION require.nents j

establishes an acceptable level of safety for unlimited continued operation. Second, i

it delays a return to power when the facility is required to be in a lower mode of

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operation as a consequence of other ACTION requirements. This is because the LCO must be met without reliance on the ACTION requirements 1efore returning to a medo for which unlimited continued operation was previously pc4mitted by the previous ACTION requirements, The NRC staff position on this in Generic Letter 87-09 h that Specification S.O.4 l

unduly restricts facility operation when conformance to the ACTION requirements I

provides an acceptable level of safety for continued operation, flowever, they point l

out that they are not endorsing or encournging a plant startup with inoperable equipment. Startup with inoperable equipment must be the exception rathee than the i

tule.

The change to Specification 3.0.4 clearly defines the conditions under which its i

requirements

apply, Consequently, those specifications that noted exce.otion to i

Specification 3.0.4 and had ACTION requirements permitting continued operation no longer need to indicate the exception. Those ACTION requirements have had the exception deleted.

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Document Control Desk November 1,1988 Page 5 Second Concern The second concere is with Specification 4.0.3.

Speci:1 cation 4.0.3 states that the failure to perfcim a surveillance within the specified time interval shall constitute a failure to meet the LCO's Operability Requirements. A missed surveillance, therefore, causes entry into ACTION requirements. Some ACTION requirements have allowable outage time limits of only one or two hours, which is normally not a prvtical amount ol' time for completing a missed Surveillance Requirement. This ein lead to.'nnecessary plant shutdown to comply with the ACTION requirements. Since completing the missed surveillar.ee is what is needed to return to power, it will probably be performed during the SII'JTDOWN. This increases the chance that the plant system bein8 tested may be needed and not available during the transient.

The NRC staff position on this in Generic Letter 87-09 is that Surveillance l

Requirements for the most part demonstrate operability and missed Surveillance Requirements are primarily a quest!an of operability that has not been verified.

Specification 4.0.3 should include a time limit that would allow a delay of the required actions to permit the performance of the missed surveillance. Based on considerations detailed in the generic letter, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> could be an acceptable time limit when the allowable outage times of the ACTION requirements are less than this time limit or when SIIUTDOWN ACTION requiiements apply, 1

The change to Specification 4.0.3 allows for ;he delay of ACTION requirements for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit completion of a missed surveillance. Thr. change clarifies the time that the ACTION requirements are applicable.

Also, the statement that exceptions to St>eeification 4.0.3 are stated in individual specifications is deleted l

because this specification is always applicable and no excemions exist.

Third Conqnn The third concern !nscives conflicts between Specifications 4.0.3 and 4.0.4 related to raode changes. Specification 4.0.4 prohibits entry into an operational moe or other specified condition when Surveillance Requirements have not been performed within the specified surveillance interval. There are two parts to this problem.

Part 1 A conflict exists when a mode change is required as a result of a SilUTDOWN ACTION requirement and the Surveillance Requirements that become applicable have not been done. The unit may even have to be placed in a lower mode than that required by the original SIIUTDOWN ACTION requirement.

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Page 6 i

l The NRC staff position on this in Generic Letter 87-09 is that the potential for a i

plant upset and challenge to safety systems is heightened if surveillances are performed during a SHUTDOWN to comply with ACTION requirements. The specification should be modified to note that its provisions shall not prevent passage through or to operational modes as required to comply with ACTION requirements.

The change to Specifier.tlon 4.0.4 notes that its provisions shall not prevent passage through or to operational modes as required to comply with ACTION requirements.

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Part 2 Allowance of an exception to Specification 4.0.4 can create a

conflict with f'

Specification 4.0.3.

An exception to Specification 4.0.4 is allowed when Surveillance Requirements can be completed only after entry into a mode or specified condition for 1

which they apply. However, upon entry into the mode, Specification 4.0.3 may not be met because the Surveillance Requirements may not have been performed within the o

i allowed interval. If the system has redundant trains, all trains are inoperable.

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Therefore, neither the LCO or the ACTION requirements can be met and Specification 3.0.3 applies and initially requires a SHUTDOWN to llOT STANDBY within six hours.

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The NRC staff position in Generic Letter 87-09 is that Specifiestion 4.0.3 is not intended to preclude the performance of surveillances when an exception to Specification 4.0.4 is allowed. The change to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the t

applicability of the ACTION reauirements of Specification 4.0.3 proudes an l

appropriate time limit for the complation of those Sut veilm.ce Requirements.

l Therefore, the conflict between (0.4 and 4.0.3 cannot occur.

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The BASES for Specifications 3.0.4, 4.0.3, and 4.0.4 have also been changed to reflect these changes. Much discussion was added to the BASES of 9pecifica-tion 4.0.3. The changes to these BASES recommended in Gereric 1,etter 87-09 otre used almost verbatim.

D ETE R M I N ATION OF Sl{ifilDCA NT liA Z A R DS This proposed change has been evaluated against the standardt. In 10 CFR 50.92 and has I

i been determined to involve no significant hazards considerations, in that operation of i

the facility in accordance with the proposed amendment would not:

i (i) involve a significant increase in the probability or consequences of I

an accident previously evaluated; l

The change to Specification 3.0.4, allowing mode changes w hile in ACTION STATEMENTS that allow continued, unlimited operation, does not affect the probability or consequences of any accident previously evaluated. Since continued, unlimited operation is allowed in either f

of the modes involved in the mode change, the only difference is that now the mode change is allowed to happen.

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Document Control Desk November 1,1988 Page 7 i

The change to Specification 4.0.3, allowing 24-hours to complete missed Surveillance Requiremenu, does not effect the consequences of previously evaluated accidents, but it may slightly increase the probability of an accident previously evaluated by increasing the time between surveillances, llowever, the frequency of missed Surveillance Requirements is very low and it is ovctly conservative to assume that systems or components are inoperable when a Surveillance Requirement has not been performed. Also, by not shutting down the plant, accidents that might occur as a result of the transient are avoided.

Therefore, overall, the change does not increase the probabilities significantly, if at all.

Clarification of Specification 4.0.4 for mode changes as a consequence of ACTION requirements does not affect the probability or consequences of previously evaluated accidents. It is not the intent of Specificatioa 4.0.4 to prevent passage through or to operational modes to comply with ACTION requirements. The change resolves potential conflicts between Specifications 4.0.3 and 4.0.4.

or (ii) create the possibility of a new or efferent type of accident from any accident previously evaluated; This change does not add or modify any plant equipment. Therefote, the aly pos?ible accidents are still those previously evaluated.

Or (iii) involve a significant reduction in a margin of safety.

The change to Specification 3.0.4 reduces the margin of safety in those specificat:ons that allow for continued, ur. limited operation nnd which did not hase an exception to 3.0.4 prior to the change.

Ilowever, as discussed in the NRC staff position in the generic letter, i

for an LCO that has ACTION require nents permitting continued operation for an unlimited period of time, entry into an operatiorti mode should in permitted in accordance with those ACTION requirements.

Therefore, these ACTION requirements provide an acceptable level of se '.y for cantinued operation, and there is not a significant reduction in the margin of safety.

Deleting the exception to Specification 3.0.4 in the specifications that allow for continued, unlimited operation does not affect any margin of safety. Prior to this change, Specification 3.0.4 did not spoly, as indicated by the exception, and mode changes could be made.

With this

change, Specification 3.04

applies, but, since these specifications allow for continued, unlimited operation, mode changes can still be made.

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Document Ccntrol Desk November 1,1988 Page 8 The proposed change to Specification 4.0.3 would allow time to complete a missed surveillance test and avoid a forced power reduction.

Since the majority of surveillances are completed successfully, this avoids potentially unnecessary transients and reduces the potential for plant upset and challenges to safety systcms. Therefore, no reduction in a margin of safety results.

Deletion of the statement that exceptions to Specification 4.0.3 are stated in the individual specifications does not effect margin of safety since no such statements exist.

Clarification of Specification 4.0.4 for mode changes as a consequence of ACTION requirements does not affect margin of safety. As pointed out in the NRC staff position on this area in Generic Letter 87-09, it is not the intent of Specification 4.0.4 to prevent ptssage through or to operational modes to comply with ACTION requirements. The change resolves potential conflicts between Specifications 4.0.3 and 4.0.4.

SAFETY CQMMITTEE RE.YUiE These proposed changes to the Technical Specifications and our determination of significant hazards have been reviewed by our Plant Operations and Off-Site Safety Review Committees, and they have concluded that implementation of these changes will nct result in an undue risk to the health and safety of the piblic.

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Document Ccntral Desk November 1,1988 Page 9 J

FEE DETERMINATION r

Pursuant to 10 CFR 170.21, we are including BGAE Check No. 1275210 in the amount of

$150.00 to the NRC to cover the application fee for this request.

Very truly yours,

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1 STATE OF MARYLAND TO WIT :

COUNTY OF CALVERT I hereby certify that on the 1st day of November,8eArrd1988, befo3e me, the subscriber, a Notary Public of the State of Maryland in and for Lt/t an personally appeared Joseph A. Tierntn, being duly sworn, and states 6that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, l

Information, and belief; and that he was authorized to provide the response on behalf of said Corporation.

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WITNESS my lland and Notarial Seal:

h M A)

Notary Public v

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F i

I My Commission Expirer dlf /, / Nd 0

U Date

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JAT/SRC/DLS/ dim l

A'tachments j

cc:

D. A. Brune, Esquire f

J. E.

Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell. NRC i

D. C. Trimb JV. L. Pritchett, NRC l

T. Magette, vNR

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