ML20006F921

Provides Addl Clarification to 891220 Application for Amend to License DPR-53 Re HPSI Pump Operability in Mode 3 & Proposes Operating HPSI Pumps in Manner Consistent W/Low Temp Overpressure Protection Requirements

ML20006F921
Person / Time
Site:	Calvert Cliffs
Issue date:	02/14/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20006F922	List: ML20006F921 ML20006F923
References
GL-88-17, TAC-75562, NUDOCS 9003010357
Download: ML20006F921 (2)

Text

.s.

A BALTIMORE OAS AND ELECTRIC L

CHARLES CENTER + P. O. BOX 1476

• BALTIMORE, MARYLAND 21203 GeoRot C. CRtcL v.ec pac.,e ., February 14, 1990 Nutttam r taev uso uso-a es

. U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit No.1; Docket No. 50-317 Technical Specification Change - HPSI Pump Operability in MODE 3 (TAC No. 75562)

REFERENCES:

(a) Letter from Mr. G. C. Creel (BG&E) to Document Control Desk (NRC), dated December 20, 1989, same subject (b) Letter from Mr. G. C. Creel (BG&E) to Document Control Desk (NRC), dated February 7,1990, LTOP System Description Gentlemen:

As requested by our NRC Project Manager on February 2, 1990, Baltimore Gas and Electric Company (BG&E) is providing additional clarification to a license amendment request (Reference (a)).

Reference (a) addressed the operability of high pressure safety injection (HPSI) pumps in MODE 3 by adding a footnote to Technical Specification Table 3.3-3 "Encineered Safety Features Actuation System Instrumentation." The footnote

. stated:

"When Tava s350*F, the OPERABLE high pressure safety injection pump will be placed in pull-to-lock, and will not start automatically.'

k Because of LTOP concerns, HPSI pumps must be prevented from starting automatically when the RCS temperature is less than 319 0F (Reference (b)). Analyses have been b' performed which demonstrate that taking the pumps out of service at RCS temperatures 0

[ $gg .as high as 350 F has no adverse impact on safety. Therefore, upon approval of the ryo amendment requested in Reference (a), we will change our operating procedures to 88 require disabling two HPSI pumps during RCS cooldown (by removing their circuit So breakers) and glacing the third in pull-to-lock when the RCS temperature is between t 350 F and 319 F. This process would be performed in the reverse during plant heatup.

$w8 in this manner, inadvertent HPSI pump starts would be precluded, oo U llowever, when the RCS temperature is less than 319 F, there are situations when a

$g HPSI pump mu:t be used under manual control. Examples include use of the HPSI pump i

$@g as an alternate boration means (TS 3.1.2.1, 3.1.2.3), mitigation of loss of shutdown ]

f

t Doe:me t Cxtrol Desk February tal,1990 ,

Page 2 -

cooling (pursuant to Generic Letter 88-17), or mitigation of an excessive reactor ,

coolant system leak (Abnormal Operating Procedure 0 2-A). In all cases, the use of a IIPSI pump when the RCS temperature is less than 319 F would be governed by approved ,

procedures. These procedures will include operational restrictions described in Reference (b) to preclude RCS overpressure transients. A future license amendment request will incorporate these operational restrictions as part of Technical Specification 3.9.4.3.

t During discussions with the NRC Project Manager and the NRC Technical Reviewer, a concern was expressed that the strict wording of the above-mentioned proposed footnote could be interpreted to prevent the flexibility needed to take the remaining available llPSI pump out of pull-to-lock to support the required uses of the pump under manual control. Consequently, we agreed to propose a similar footnote for Technical Specification 3.5.3, ECCS Subsystems, which would clarify the operability definition of the llPSI pump in this regard. The footnote we propose to add is:

"When Tavs $3500 F,the OPERABLE high pressure safety injection pump will be placed in pull-to-lock and will not start automatically. Manual use of the high pressure safety injection pump will be conducted in accordance with approved procedures."

This proposed ' footnote does not affect the significant hazards discussion presented in Reference (a). This change provides clarification of the definition of liPSI pump operability in Technical Specification 3.5.3 consistent with that defined and evaluated ,

in Reference (a) for Technical Specification Table 3.3-3. We are proposing to operate  :

ilPSI pumps in a manner consistent with the LTOP requirements described in Reference '

(b). All llPSI pump operation will be in accordance with approved procedures which will contain controls to protect against overpressurization of the RCS. The margin of safety, presented in Reference (a), is preserved.

Should you have any further questions regarding this matter, we will be pleased to discuss them with you, i Very truly yours, l

GCC/ PSF /bjd a l

Attachments cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra, NRC D. G. Mcdonald, Jr., NRC l

W. T. Russell, NRC J. E. Deall, NRC T. Magette, DNR