ML20032D432
| ML20032D432 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/04/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20032D427 | List: |
| References | |
| NUDOCS 8111160360 | |
| Download: ML20032D432 (4) | |
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UNITED STATES E
h NUCLEAR REGULATORY COMMISSION l
j WASHINGT ON, D. C. 20555 5
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%*...*l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NOS. 59 AND 41 TO FACILITY OPERATING LICENSE NOS. DPR-53 AND,DPR-69 l
BALTIMORE GAS AND ELECTRIC COMPANi CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318
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Introduction:==
By application for license amendment dated January 29, 1981, the Baltimore Gas and Electric Company (BG&E) requested changes to the Technical Specifi-cations (TS) for Calvert Cliffs Units 1 and 2.
This application addresses four unrelated issues, three of which were subsequently resolved.
The final issue, deletion of two snubbers from the applicable TS requirements, is addressed herein.
In addition, by application for license amendment dated July 30, 1981 BGLE requested changes to the TS for Cah ert Cliffs Units 1 and 2.
The' July 30, 1981 application addresses several unrelated issues; we herein provide our evaluation of the TS changes relating.to (1) secondary water chemistry, (2) measures to prevent inadvertent reactor coolant system boron dilution, (3) clarification concerning the operability of valves associated with the control room ventilation system, (4) deletion of a snubber froin the applicable Technical Specifications, and (5) changes to the basis for the auxiliary feedwater flow requirements.
Discussion and Evaluation:
We herein provide our evahetion of tha TS change request contained in the applications for license amendments dated January 29, 1981 and July 30, 1981.
Secondary Water Chemistry - Aoplicatien of. July 30, 1981 By letter dated July 23, 1979, the NRC informed BG&E that a change in NRC policy had been implemented concerning the requirements for secondary system water, chemistry control.. The previous NRC position had been that secondary
.c system water chemistry limits, Limiting Conditions for Operation, and Surveillance Requirements should be incorporated in the TS. ' These requirements were incorporated into the TS as Sections 3.7.1.6 and 4.7.1.6 via License Amendments 34 and 16 for Calvert Cliffs Units 1 and 2, respectively.
License Amendments 34 and 16 were issued on August 7,1978. The intent of the provisions was to provide added assurance that the licensee would properly monitor arid control secondary water chemistry to 1. nit corrosion of steam generator tubes.
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N In a number of instances, at other facilitjes, the TS have.significantly restricted the operational flexibility of some plants with little or no benefit with regard to limiting corrosion of steam generator tuber. Based on these experiences and the knowledge gained in recent years, we have concluded that TS limits are not the most effectivc way of assuring that steam generator tube corrosion.will be minimized.-
Due to the complexity of the corrosion pnenomena involved, and the state-of-the-art as it exists today, we believe that, in lieu of TS, a more effective approach would be to institute a license condition that requires the implementation of a secondary water chemistry monitoring and cantrol program containing appropriate procedures and administrative controls'.*
The license concition developed by the NRC is as follows:
"The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:
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Identification of a sampling schedule for the critical parameters and control points for these parameters; 4
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Identification of the procedures used to quantify parameters that are critical to control points; Identificationofprocesssamp(ingpoints; 3.
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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 interpretatirn of the data, and the secuence and timing of administrative events required to initiate corrective action."
The required program and procedures would be developed by the licensees, with any needed input from their reactor vendors or other-consultants, and thus could more readily account for site and plant specific factors that affect chemistry conditions in the steam generators.
In our view, such a license condition would provide assurance that licensees would devote proper attention to controlling secondary water chemistry, while also providing the qeeded flexibility.to allow.them to more effectively deal with any off-normal conditions that might arise. Moreover, we have concluded that such a license condition, in conjunction with' existing TS on steam generator tube leakage and inservice inspection, would provide the most practical and comprehensive means of assuring that steam generator tube integrity would be maintained.
In the BG&E application of July 30, g
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1981, license cmditions for secondary system water chemistry control were proposed which are identical to the license conditions developed by the NRC. Accordingly, it is appropriate that these conditions be _ incorporated into the Facility Operating License for Calvert Cliffs Unit 1 as Paragraph 2.C.(S) and into the Facility Operating License for Calvert Cliffs Unit 2 as Paragraph 2.C.(7).
Measures to prevent Inedvertent Primary System Baron Dilution - Application of July 30, 1981 Calvert Cliffs Units 1 and 2 TS 3.9.8.1 and 3.10.5 address measures to be taken when the shutdown cooling loops are not operable. Under TS 3.978.1 an.d 3.10.5, these p=asures include the suspension of all operations which could result in primary r.ystem boron dilution; however, no specific measures are presently specified to prevent prirary sy; tem boron dilution. TS 4.10.5.1 presently provides a Surveillance Requirement associated with TS 3.10.5 in that, when reactor coolant circulation and shutdown cooling are suspended,
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surveillance includes assuring that "... charging pumps shall be verified de-energized and charging flow paths shall be verified closed at least once 9
per hour." The de-energizing of the charging pumps and closing the associated flow paths isolates the only significant source of boron dilution capability via the chemical and volume control system. BG&E has proposed that the Surveillance Requirements of TS 4.10.5.1 be added to the Limiting Conditions for Operation (LC0's) of TS 3.9.8.1 and 3.10.5..Me find this c.hange to be accept'able in that it clarifies the minimum actions needed to prevent primary system boron dilution when shutdcwn cooling is not available. Moreover, the proposed chcnge in no way affects the reliability of safety related ecuiprent nor does it preclude the licensee from taking additional reasures to preclude inadvertent dilution of the reactor coolant system boron concentration.
Clarification Concernina the Operability of Valves Associated with the C,ontrol Room Ventilation System - Application of July 30, 1931
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Calvert Cliffs Units 1 and 2 TS 3.7.6.1 provides the minimum operability requirements for equipment *ssociated with the control room emergency ventilation system.
Item d of TS 3.7.6.1 requires that "Two isolat:on valves in the control room exhaust duct..." be operable; however, this requiredent does not specify which two valves are being addressed.
By application dated July 30, 1981, BGLE requested that the phrase " control room exhaust duct" be replaced in TS 3.7.6.1d by the phrase " common exhaust to atmosphere" in order to specifically identify the valves for which the operability requirement is applicable.
A review of Calvert Cliffs Units 1 and 2 Piping and instrumentation Diagram M-65 (sheet 1 of 3) indicates that the control room ventilation system exhausts to the atmosphere via a common air duct. The common air duct is isolated by two valves which are automatically closed, upon high radiation, by actuator 0-P0-5370.
In this way,.the c.ontrol room exhaust to atmosphere is isolated, as is the control room air intake, upon high radiation. We concur that the proposed change to TS 3.7.6.ld provides clarification by identifying which control room exhaust duct isolation valves are required to be operabio. The proposed change in no way affects the reliability of the subject equipment and is therefore accaptable.
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Deletion of Snubbers from Applicable TS - Applications of January 29, 1991 and July 30, 1981 By application dated January 29, 1981 BG&E requested that Snubbers 1-38-1 and 1-38-2 be deleted from the list of safety related snubbers, contained in TS Table 3.7-4, that are subject to operability and surveillance require-ments.
Snubbers 1-38-1 and 1-38-2 provided -support for the Unit 1 pressurizer sample control valves' packing leak-off lines; these lines have been removed since they are no longer needed.
In addition, by application dated July 30, 1981, BG&E requested that Snubber 2-38-1 be deleted from TS Table 3.7-4.
Snubber 2-38-1 had been attached to a Unit 2 valve packing leak-off line which had also been removed.
For Snubbers 1-38-1, 1-38-2 and 2-38-1, removal of corresponding lines made it appropriate tc remove the snubbers since they were no longer needed. We concur with removal of Snubbers 1-38-1, 1-38-2 and 2-38-1 since the support of other safety related piping is not affected.
Accordingly., deletion of Snubbers 1-33-1, 1-38-2 and P-38-1 from TS Table 3.7-4 is appropriate.
Change to the Basis for the Auxiliary Feedwater Flow Reauirement - Application of July 30, 1981 By application dated July 30, 1981, BGLE requested a change to the basis for the auxiliary feedwater TS 3/4.J.l.2, for Calvert Cliffs Unit l'and 2.
At the present time, the basis for the Calvert Cliffs Units 1 and 2 auxiliary feedwater system, contained in Bases 3/4.7.1.2, indicates that.each auxiliary fesdwater pump is capable of delivering 700 gpm, at a total dynamic head cf 2490 ft, to the entrance of the steam generators.
This Bases is as stated in the Calvert Cliffs FSAR, Section 10.2.3.
Calculations, however, indicate that a total flow of 450 gpm is sufficient to ceal the reactor primary system to 3000F, at which point shutdown cooling can be utilized.
We concur with BG&E that 450 gpm is the minimum level of operability for t'ie auxiliary feedwater system, with regard to total, deliverable, flow to the steam generators.
Accordingly, we find it appropriate to amend Bases 3/4.7.1.2 by providing the following:
"A capacity of 450 gpm, however, is sufficient to ensure adequate feedwater flow is available to remove decay heat and reduce the Reactor Coolant System temperature to less than 3000F when the shutdown cooling system may be olaced intu ooeration."
Environmental Consideration We have determined that the amendments do not authorize a change in effluent types or total amounts nor an increase in pcwer level and will not result in any significant envircamental impact. Having made this determination, we have further cor.cluded that the amendments involve an action which is insignificant from the standpoint of
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environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement or ne,gative declaration and environ-mental impact appraisal need not be prepared in tonnection with the issuance of'these amendments.
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conclusion i
We have concluded, based on the considerations discussed above, that:
(1) because the amendments do not involve a significant increase in the probability or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Corxnission's regulations'and the issuance of these amendments will not be inimicak to the common defense and security or to the health and safety of
. the public.
Date:. November 4, 1981 J
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