ML19327B723

Application for Amend to License DPR-69,revising Tech Spec 4.6.1.2.a to Extend Testing Schedule to 900801 or Entry Into Mode 4,whichever Occurs First

ML19327B723
Person / Time
Site:	Calvert Cliffs
Issue date:	10/27/1989
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8911070300
Download: ML19327B723 (4)

Text

g- s B ALTIMO R E p  ;

OAS AND i f ELECTRIC I h

CHARLES CENTER. P. O. BOX 1476

• BALTIMORE, MARYLAND 21203 l

GLORGE C. CRrEL i j VtC4 Pat tibt.s1 NCatam rest 90T *

. (400 #60 eens f l

October 27, 1989  ;

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' O. S. Nuclear Regulatory Cornmissien '

Washington, DC 20$55

% ATTENTION: Document Control Desk

SUBJECT:

Ca'vc t Oiffs Nuclear Power P; ant Unit No. 2; DocLet Na, 50 318  ;

Brauest for Temoorary Technteni sneciriention Chance Gentlemen:

We request a temrorary Technical Specification change to Technical Specifica-tion 4.6.1.2.s for Unit 2, which defines the interval between containment integrated Leak Rate Tests (ILRT). We request an extension of the testing schedule to August I, 1990 or entry into MODE 4, whichever occurs first. l DISCUSSION As defined by Appendix J to 10 CFR 50, an ILRT is required to be performed three times in each ten-year operating cycle, with the last one done during the ten-year  !

inservice inspection nnd the others performed at approximately equal intervals. Our I current Technical SpeciGcation supports that schedule by requiring that an ILRT be i performed every 40 i 10 months. Our last Unit 2 ILRT was performed on l November 21, 1985. Our next Unit 2 ILRT must be performed before January 21, 1990 (50 months) liowever, because of the extended work on the pressurizer heater sleeves,  ;

the Reactor Coolant System (RCS) cannot be filled with water for the test.

Thereforc, we request an extension to the testing schedule for this outage only until August I,1990 or entry into MODE 4, whichever occurs first. j 0911070300 891027 PDR ADOCK 05000310 b  !

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I Document Control Desk October 27, 1989 Page 2 i

Normally, an ILRT is performed at the end of a refueling outage, after the Reactor Vessel has been scaled and the water level raised so that the level indication is on scale in the pressurizer. This allows us to determine if there are any changes in RCS inventory during the test, and account for them in the test results. This methodology is prescribed in STP-M-662, which we follow during the test. During the pressurizer heater repsirs, openings are made in the pressurizer when the heaters are removed.

This prevents filling of the pressurizer and impacts our ability to determine changes in RCS inventory during the test. The piessurizer heater repairs are not expected to be complete until Match 1990, To perform the test within the time kilowed by the Technical SpecificaCons, we would have to stop all presserizer repair work and close tht openings that exist la the pressurizer. After the test is cornplete, the RCS would have to be drained, ana ti.e pressurizer retvined to its pre-test state. Then work could proceed on the pressurizer heaters. This would case an unnecessary delay in the pressurizer repair work.

We beliese that the intent of the regulation would be met by granting this exter:sion.

Unit 2 htts b?cn shut down s!nce March 1989 for refueling and the pressurizer hentes repair. Since this time, plar>t components have aot been e.t pcsed to the normal operat!ng temperature, pnssure, and radiation conditions. The time intervals specified in Appendix J were based, in part, on the expected dcgradation of components exposed to the environment resulting from normal plant operation. We shut Unit 2 down within the testing window allowed by our Technical Specifications. We will perform the ILRT prior to starting up Unit 2 from this outage. Therefore, because component  !

degradation due to the operating environment has been minimized during this octage, and we will be testing the containment prior to start up, we believe that this schedule extension poses no significant hazard to the health and safety of the public. We will  !

be able to show that containment leakage will not exceed the acceptance criteria stated in Appendix J and our Technical Specifications prior to start up.

DETERMINATION OF SIGNIFICANT llAZARDS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hatards considerations, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant increase in the probability or consequences of an accident previously evaluated; or Our last ILRT determined that the containment was within the leakage rates allowed by 10 CFR 50 Appendix J and our Technical Specifications. We '

have not had any unusual operating transients during this interval which might have a significant effect on the pressure-retaining capability of the containment. We shut down Unit 2 during the testing window allowed by our Technical Specifications. Since then, containment components have not been exposed to a degrading environment. Consequently, we do not expect the integrity of the containment botmdary to differ significantly betweeen the

s Document Control Desk October 27, 1989 Page 3 L

L current test date of January 20, 1990, and the requested date of August 1, 1990. During this time until the ILRT is performed, we will remain shut down, in MODE $ & 6 the applicable accident analyses are the fuel handling event and the boron dilution event. Neither one of these events is anticipated to have a significant impact on containment pressure.

Neither one would make the containment leak at its design rating of 0.2 w/o per day. There fore, delaying the ILRT will not impact these accident analyses.

(ii) create the possibility of a new or different type of necident from a any sccident pteviously evalanted; or ,

i Delaying the ILRT by six months does not create the possibility of a new I or diffrent type of accident. During the delay, the Unit will bo shut j down and the ev(nts applicable to this MODE are the boron dilutic*n event and e fuel hand!!ng event. Neither one of these events is impacted by the

• delay in perforraing the ILRT. No additional degradation is anticipated to occur during the delay because of the non-operating condition of the Unit.

Therefore, no new or different condition is postulated to be present during the delay period.

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

The ILRT is performed to ensure that containment leakage has remained within the limits allowed by the Technical Specifications and the assumptions used in the accident analyses. The .tressurization needed to perform the ILRT approaches the design pressure of the containment. This pressure is postulated to exist during a Loss of Coolant Accident or Main Steam Line Break event. With the Unit shut down, these events are not >

postulated to occur. The margin of safety is not affected by delaying the '

performance of the ILRT by approximately six months while the Unit remains shut down, i

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?E Document Control Desk October 27, 1989 Page 4 SAFETY COMMrITEE REVIEW Ther.e 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 not result in an undue risk to the health and safety of the public.

Very truly yours, i-

/

L' l _

Q STATE OF MARYLAND  :

TO WIT :

b)!)lVffh lntinf  :

I b day of.

^

I hereby certify that on the Cub?T , 19 , before me, the ib /, /lbrv3 subscJ

/P//M er, M/a Notary, personally Public of the State ofGeorge appeared Maryland in andbeing C. Creel, for duly sworn,'and states that 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, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.

WITNESS my Hand and Notarial Seal:

/

d A Notary Pubyl My Commission Expires:vy commsien tiens My t.1990 ['/t[2 , /hf Date '

GCC/ PSF /dtm Attachment cc: D. A Brune Esquire J. E. Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC V. L. Pritchett, NRC T. Magette, DNR  ;

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