ML19343B932

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Submits Revised Schedule for Response to NUREG-0737. Emergency Procedures Will Be Revised After 811201.Revisions Will Be Implemented at First Refueling Outage After 820601
ML19343B932
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 02/11/1981
From: Lundvall A
BALTIMORE GAS & ELECTRIC CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-3.A.2.2, TASK-TM NUDOCS 8102180304
Download: ML19343B932 (3)


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BALTIMORE GAS AND ELECTRIC COMPANY.

f; P. O. B OX 14: i BALTIMORE, M ARYLAN D 21203 ARTHUR E. LUN OVALL. JR.

February (1, 1981 v:cc Pats.oce sv..s Fr. D. G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cc:::11ssion Washington, D.C.

20555

Subject:

Calvert Cliffs Nuclear Power Plant Units 1 & 2, Docket Nos. 50-317 & 50-318 Response to NUREG-0737

References:

(a) Letter from A. E. Lundvall, Jr. to D. G. Eisenhut dated Dece=ber 15, 1980 (b) Report C m -117, " Inadequate Core Cooling-A response to NRC IE Bulletin 79-06C, Item 6 for Ca:1bustion Engineering Nuclear Steam Supply Systems.

(c) Report CEN-128, " Response of Ccmbustion Engineering Nuclear Steam Supply System to Transients and Accidents."

(d) Letter from D. G. Eisenhut to All Licensees dated October 31,1980; NURm-0737

Dear Mr. Eisenhut:

In reference (a), Baltimore Gas and Electric Company (BG&E) presented I

a schedule for submitting reanalyses of transient, accident and inadequate core cooling conditiens. We must now revise that schedule. Activity related to this Action Plan item is su =arized below.

BG&E has participated in Combustion Engineering Owners Group (CEOG) activities conducted since the accident at Three Mile Island to develop improved l

emergency procedure guidelines and associated supporting analysis. The CEOG has submitted numerous documents to the NRC for review, and is sponsoring activities which vill be completed and documented in the first half of 1981.

The initial CEOG analysis of Inadequate Core Cooling (ICC) is documented I

in reference (b). This report was submitted to the NRC staff by the owners group on Octcber 31, 1979

" Operational Guidance for Inadequate Core Cooling" was pre-pared by the CEOG based on the analysis described in CEN-ll7, and a ecpy was submitted to the NRC on December 10, 1980.

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Tha CECG has also sponsclad an extensive study of instrumentation respenc" chancterictice under ICC ccnditiens. This study was begun in early 1980 ar decc -iw tc tne tiEC staff at a =ceting on Mrf 28, 1980. BG&E is currently evaluating a draft report of this study for use in possible revisions to plant e=ergency procedures.

The initial CEOG analysis of transient and accident (non-LOCA) conditiens is doctr.ented in reference (c). Thic report was submitted to the

!mC staff by the CEOG cn April 1,1980. This report shows how a typical C-E designed plant would respond to various event initiators, and which systems would be actuated in the course of an incident.

This analysis considered only a single active failure for each system called upon to functicn for a particular event. Passive failures and multiple system failures were not considered. The CEOG is new conducting a program to develop analyses of transients and accidents involving multiple failures. This program was cutlined to the IGC staff at a meeting on January 31, 1980, and is scheduled to be completed in the first half of 1981.

The CEOG has developed guidelines for emergency procedures based upon review of existing procedures, previous safety redesign analysis, plant simulation, sequence of events analysis, and interviews with operations personnel at plants with C-E reactors. These procedure guidelines were documented in reference (c).

The IGC sent questions to the CEOG concerning these guidelines in a letter dated July 17, 1980. These questions were discussed at a meeting between the CEOG and the IEC staff on September 11, 1980, and a preliminary response was submitted to the staff on December lo, 1980.

TV CECG has' initiated an effort to define the process by which plant e=ergency prccedures cheuld be developed or modified using guidelines and support-ing analyces.

EG&E is participating in this effort and feels that it must be cc=pleted before plant emergency procedures are further revised. A meeting was held wius the 3C staff en January 30, to discuss this process. This activity is new ccheduled to be ccepleted by May 1, 1981, and revised e=crgency procedure guidelines are to be submitted by June 1, 1981.

Following coa:pletion of the IEC review of the revised emergency procedure guidelines and completion of the C-E Owners Group activities to define the process -

for development or revision of plant emergency procedures, BG&E will evaluate the need for revision of its plant emergency procedures. Reference (d) indicates that six months will be required for Imc staff review and approval and that another six months or more are to be allowed for revision and implementation of emergency j

i procedures. Therefore, the Calvert Cliffs Nuclear Power Plant emergency procedures will be revised, if necessary, after December 1,1981, and the revisions imple-mented at the first refueling outage after June 1, 1982. Any additional training for mitigating core damage required per item II.B.4 will be conducted prior to impletentation of these changes to emergencf procedures.

If any additional information is required, we would be pleased to provide it to you.

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J. A. Biddison, Esquire

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i G. F. Trowbridge, Esquire Mr. E. L. Conner, Jr. - IGC

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