ML20010A679

Application to Amend Licenses DPR-53 & DPR-69,deleting Tech Spec Sections 3/4.7.1.6 & B3/4.7.1.6 & Tables 3.7-3 & 4.7-3. Amend Inserts Condition in Paragraph 2.C Requiring Implementation of Secondary Chemistry Monitoring Program

ML20010A679
Person / Time
Site:	Calvert Cliffs
Issue date:	07/30/1981
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20010A680	List: ML20010A679 ML20010A682
References
NUDOCS 8108120021
Download: ML20010A679 (5)

Text

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A BALTIMORE GAS AND ELECTRIC CHARLES CENER. P. O. BOX 1475. BALTIMOR E, MARYLAND 21203 ARTHUR E. LUNOVALL. JR.

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Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation 2

AUG 111981 m 11 U. S. Nuclear Regulatory Commission F

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g Washington, D. C.

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Subject:

Calvert Cilffs Nuclear Power Plant

, \\j Units Nor 1 & 2, Dockets Nos. 50-317 & 50-318 g

Recuest for Amendments

References:

(a) NRC letter dated 7/23/79 from R. W. Reid to A. E. Lundvall, Jr., Secondary Water Chemistry.

(b) BGLE letter dated 10/5/79 from A. E. Lundvall, Jr.

to R. W. Reid, same subject.

(c) NRC letter dated 11/20/80 from D. G. Eisenhut to All Power Beactor Licensees, Technical Specification Revisions for Snubber Surveillance.

Dear ffr. Denton-Baltimore Gas and Electric Conpany (BG&E) hereby requests Amendnents for Operating Licenses DPR-53 and DPR-69 for Calvert Cliffs Units 1 and f, respectively, with the submittal of the enclosed proposed changes to the Technical Specifications. All changes pertain to both Units unless otherwise indicated. The FCR Number shown on each change is for BG&E internal use only.

TECHNICAL SPECIFICATION CHANGES Change No. 1 (FCR 81-lh):

l Delete Sections 3/h.7.1.6 and B3/h.71.6 and Tables 3.7-3 and l

h.7-3, and insert the following Condition in Paragraph 2.C of the Operating License:

The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:

1.

Identifiestion of a sampling schedule for the critical paeameters and control points for these parameters; 2.

Identification of the procedures used to quantify parameters that are critical to control points; sI

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Mr. H. R. Denton

'Paga 2 July 30,1981 3.

Identification of process sampling points; h.

Procedure for the recording and management of data; 5

Procedures defining corrective actions for off control point chemistry conditions; and 6.

A procedure identifying the authority responsible for the inter-pretation of the data, and the sequence and timing of administrative events required to initiate corrective action.

Discussion and Justification The NRC's letter of July 23, 1979, Reference (a), requested that we submit a request to delete the existing Technical Specifications on secondary water chemistry and to incorporate the requirements of the model license condition which NRC had provided. Feference (b) f nformed NRC that we vould submit a proposed change at a later date.

The above proposed license condition, which was written verbatim from the model, has been evaluated, and we have detennined that our present secondary chemistry program complies with the license condition in all respects.

Change No. 2 (FCR 81-19):

Change Paragraph 310 5.a as shown ou the attached marked-up page 3/h 10-5; Change Paragraph 3 9.8.1.a as shown on the attached marked-up page 3/h 9-8.

Discussion and Justification:

Surveillance Requirement h.10 5.1 states that the charging pumps shall be verified de-energized and the charging flovpaths shall be verified closed at least once per hour. 7his requirement implies that the associated Limiting Condition for operation (LCO) 3.10.5.a is meant to require that the pumps and flovpaths are so isolated. However, the present wording of the LCO does not specifically do so.

The proposed change vill direct the operator to place the charging pumps and flovpaths in the required condition, consistent with the Surveillance Requirement.

Similarly, Action Statement (a) for LCO 3 9.8.1, as presently worded, does not provide the operator with specific guidance as to how to suspend dilution operations. Inasmuch as Paragraph 3/h.10.5 specifically addresses the charging pumps and flovpaths, there should be consistency between 3/h.10.5 and 3/h.9.8.1.

In addition, an asterisk (*) has been added as shown to reiterate the existing footnote pertaining to when a shutdown cooling loop may be removed from operation.

2.

Mr. H. R. Denton

'Paga 3 July 30,'1981 Change No. 3 (FCR 81-28):

Change Limiting Condition for Operation (LCO) 3.7.6.1.d and Action Statements (b) and (d) as shown on the attached marked-up page 3/h 7-17 Discussion and Justification:

As presently worded, LCO 3.7.6.1.d and Action Statement (d) incorrectly identify which exhaust duct isolation valves must be OPERABLE in the Control Room ventilation system. The proposed change correctly identifies the duct in which the t alves must be OPERABLE.

Action Statement (b) is being changed to account for the fact that the Control Room air-conditioning units may be inoperable without jeopardizing the safety of the plant so long as the Control Room temperature remains within limits. It is unnecessarily restrictive to cause the plant to be shut down when an air-conditioning unit is inoperable if it can be demonstrated that the Control Room temperature can be maintained within ecceptable limits even without the air-conditioning unit (s). The conser-vative (reduced) temperature limit of 110 F has been selected as the Actien criterion in lieu of the existing criterion (one a/g unit inoperable). This temperature limit allows a substantial margin of 10 F before the design temperature linit of the Control Room would be reached.

Change No. h (FCR 81 b1) (Unit No. 2 Only):

Delete Eydraulic Snubber 2-38-1 from Table 3 7 h, page 3/h 7-31.

Discussion and Justification:

As part of a plant modification, the leak-off line for valve 2-CV-Sh66 was removed and plugged. Snubber 2-38-1 was attached to the removed leak-off line and, therefore, was removed. Accordingly, snubber l

2-38-1 should be deleted from Table 3.7-h.

Change No. 5 (FCR 81 h9):

Replace Technical Specification section 3/h.7.8 pages 3/h 7-25 and a.

3/4 7-26 with the attached revised pages and add attached new page 3/h 7-26a.

b.

Replace Bases section 3/h.7.8 page B 3/h 7-5 with the attached revised page.

Add a new subparagraph 6.10.2.m as shown on the attached page 6-20.

c.

d.

Modify / add to the footnotes at the end of Table 3 7-h (page 3/4 7-61a Unit 1; page 3/h 7-53 Unit 2) as shown on the attached composite marked-up page. Also change the heading of column h for every page in Table 3.7 h to read:

"HIGH EXPOSURE ZONE" as shown.

Delete Table h.7-4 (page 3/h 7-62 Unit 1; page 3/h 7-Sh Unit 2).

e.

Mr. H. R. Denton Page h July 30, 1981 f.

Add a triple asterisk (***) next to the existing brackets for the Steam Generator snubbers on pages 3/4 7-51 and 7-52 for Unit 1 and pages 3/4 7-h5 and 7-h6 for Unit 2.

Discussion and Justification:

The proposed changes are in response to an NRC request, Reference (c), as modified to be consistent with the Ce.lvert Cliffs design and operating practices and considering the latest ASME guidelines (draft ASME OM-h, " Examination at i Performance Testing of Nuclear Power Plant Dynamic Restraints (Snubbers ).")

Change No. 6 (FCR 81-1017):

Change the last sentence of the second paragrer' of Bases paragraph 3/h.71.2, on page B 5/h 7-2 to read as follows:

"A flow of h50 gpm has been determined to be sufficient to ensure that adequate ';edvater..."

Discussion and Justification:

As presently worded, the basis for Technical Specification 3/h.7.1.2 implies that the full rated flov (700 gpm) of an auxiliary feedvater pump is required to provide adequate decay heat removal. In fact, calculations performed by the NSSS Supplier have shown that a flow of about h50 gpm is adequate to perform this function. Therefore, this clarification should be made in the basis to preclude misinterpretation of design data and functional requirements by NRC inspectors end/or plant personnel.

SAFETY COMMITTEE REVIEW These proposed changes to the Technical Specifications have been reviewed by our Plant Operations and Safety Review Committee and Off-Site Safety and Review Committee, and they have concluded that implementation of these changes vill not result in an undue risk to the public health and safety.

A

Mr. 3. R. Denton

• Paga 5 July 30, 1981 FEE DHfERMINATION We have determined, pursuant to 10 CFR Part 170 Paragraph 170.22, that this Amendment request consists of Class IV and Class I amendments for Calvert Cliffs Units Nos. 1 and 2 respectively, and, accordingly, we are including BG&E Check No. A013084,n the amount of $12,700.00 i

to cover the fee for this request.

BALTIMORE GAS AND ELE IC COMPANY By:

4-w c:2 L -

" Vice ' Pre' side nt, Supply

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STATE OF MARYLAND:

TO WIT:

CITY OF BALTIMORE:

Mr. A. E. Lundvall, Jr. being duly sworn, states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he executed the foregoing Amendment for the purpose therein set forth; that the statements made in said Amendment are true and correct to the best of his knowledge, information and belief; and that he was authorized to execute the Amendment on behalf of said corporation.

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i WITNESS my hand and Notarial Seal (I-(id;

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My Commission Expires :

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cc:

J. A. Biddison, Esquire G. F. Trowbridge, Esquire Messrs. E. L. Conner, Jr. - NRC R. E. Architzel - NRC i

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