ML20042G614

Requests Regional Temporary Waiver of Compliance to Provide Relief from Provision of Limiting Condition for Operation of Tech Spec 3.4.10.1, Structural Integrity of ASME Code Class 1,2 & 3 Sys.

ML20042G614
Person / Time
Site:	Calvert Cliffs
Issue date:	05/05/1990
From:	Detter G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9005150160
Download: ML20042G614 (4)

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• A BALTIMORE OASAND ELECTRIC CHARLES CENTER . P.O. BOX 1475 BALTIMORE, MARYLAND 21203 May 5,1990 U. S. Nuclear 3eplatory Commission Washington, DC 10555 A'ITENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit No.1; Docket No.50 317 Request for Regional Temporary Waiver of Compliance from a Limiting Condition for Oncration Gentlemen:

Tile REOUIREMENT FROM WillCil A WAIVER IS REOUESTED The Baltimore Ons and Electric Company respectfully requests a regional temporary waiver of compliance to provide relief from a provision of the Limiting Condition for Operation of Technical Specification 3.4.10.1, " Structural Integrity of ASME Code Class 1,2, and 3 Systems." This request woukt specifically provide relief from the requirement of Action Statement 3.4.10.1.c to isolate a camponent not conforming to the structural integrity requirements for ASME Code Class 3 components, The purpose of this request is to allow one train of the Saltwater System containing a non-conforming component to be unisolated (contrary to Technical Specification 3.4.10.1) and placed into operation while the remaining train is tem 1orarily removed from service to xtform cleaning that is necessary to maintain its heat removal function. Relief from this Techn cal Specification provision is requested on a one-time only basis and for a duration of up to six hours.

DESCRIPTION OF CIRCUMSTANCES AND Tile NEEI) FOR Tile WAIVER During a plant walkdown on the morning of May 4,1990, an Operator observed a leak in the discharge piping of Saltwater Puinp #13. The leak is located in a pipe flange to pipe wcld just downstream of the outboard pump discharge isolation valve before the point where the discharge piping connects with Saltwater System Header #11. Because of the location of this leak,it is not isolable from Saltwater Header #11. Technical Specification 3.4.10.1.c states:

". . . With the structural integrity of any ASME Code Class 3 component (s) not conforming to the above requiremenis, restore the structuralintegrity of the affected component (s) to within its limit or isolate the affected component (s) from service." q .. f/dg

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The affected component is classified as ASME Code Class 3. The non-conforming condition is a leak ,

in the flange to pipe weld. Restoration of structural integrity involves inspection and reaalt of the wcld,which in turn requires isolation of the leak from the system. Since there is no insta. led means i of accomplishing this isolation locally, the entire Saltwater IIcader #11 must be isolated and removed from service pursuant to Action Statemen' 3.4.10.1.c until the leak is repaired.

Accordingly, Action Statement 3.4.10.1.c was entered at 1130 EST on May 4,1990, and the Saltwater Ileader #11 removed from service and isolated at 1330. Saltwater IIcader #12 provides redundancy to Saltwater IIcader #11 and is currently in senice and operable. Saltwater licader #12 provides cooling to plant components via Service Water IIcat Exchanger #12. To maintain #12 IIcat Exchanger's capacity, cleaning must presently be performed approximately every 48 houu to prevent ,

excessive flow degradation due to biofouling. Cicening of Service Water Heat Exchanger #12 is expected to be required again on the morning of May 6,1990.

While this cleaning is performed, SW licader # 12 will be inoperable for a period of between two and four hours. If Saltwater IIcader #11 was not placed back in senice when #12 Saltwater licader was taken out of service for cleaning, the plant would have no decay heat removal capability (shutdown cooling) until the cleaning was completed. If Saltwater Header #11 is unisolated and placed back into senice for the period required to clean Saltwater IIcat Exchanger #12, then decay heat removal capability will be retained. The nature of the leak in Saltwater licader #11 is such that it does not threaten its capability to perforin its safety function of decay heat removal (the leak is an elliptical ,

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hole approximately 0.25 cm2 in size). Iloweva, Saltwater licader #11 cannot be returned to service due to the aforementioned restriction cf Techmcal Specification 3.4.10.1.c.

COMPENSATORY ACTIONS (IF ANY)

During the period of time that Saltwater Header #11 is placed in senice, a dedicated Operator will be in the vicmity to observe any increase in leakage rate.

SAITlY CONSEQUENCES ASSOCIATED WITil GRANTING A TEMI'ORARY WAIVER OF '

COMPl. LANCE A tempo aiy waiver of compliance from Action Statement 3.4.10.1.c would allow Saltwater Header

1. 11 to b; placed into senice to provide a decay heat removal function for a short period of time

! while the redun ' ant train is taken out-of senice for required cleaning. Without a waiver, Saltwater licader #11 would not be returned to senice and Saltwater Header #12 would remain in senice until it was either removed from service for cleaning or until flow was degraded due to biofouling to the point where its heat removal function was jeopardized. In either case, therc would be a period of time when the decay heat removal runction was not being satisfied.

Approval of this waiver will provide for continuous, uninterrupted decay heat rc moval. One possible consequence associated with the granting of this waiver would be that the leak in Saltwater Header

1. 11 could enlarge while this header was in senice. In this case, the increasei leakage would be detected and,if necessary, the header would be removed from senice. This is not considered likely given the short period of time Saltwater IIcader #11 will be operated (up to six hours). In any case, ,

l an increase in leakage and subsequent removal cf Saltwater Header #11 from senice would place l l the plant in the same condition that would be prevailing if this waiver was not granted, j l

! In fact this waiver, if granted, would increase the level of plant safety and minimize risk to the public l because it would allow the full utilization of a safety system in order to perform an important rafety function irrespective of the fact that a component within the system is not in conformance with an 1 ASME Code requirement. Consequently, this waiver would not pose any undue risk to public health {

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. . , Document Control Desk May 5,1990 Page 3 and safety and would, in fact, prc W ' increased level of protection givet. the special circumstances that presently exist.

DURATION OF TEMPORARY WAIVER This waiver is requested for a duration of six hours to accommodate cleaning of Saltwater Header

1. 12. Cleaning is normally accomplished within two to four hours. During the 48-hour period of r operation Saltwater 11cader # 12 that will follow this cleaning, the leak in Saltwater IIcader #11 will  ;

be repaired.

IIASIS FOR CONCLUSION TilAT Tile WAIVER DOES NOT CONSTITUTE A SIGNIFICANT IIAZARDS CONSIDERATION -

This waiver would not involve a sigrificant increase in the prooability or consequences of an accident  :

previously evaluated. The accident of concern is a loss of deny beat removal capability. This waiver ,

would provide increased assurance that adequate decay heat removal capabihty will be available, considering the need to periodically remove one train of the Saltwater System from service for required cleaning.

This waiver would not create the possibility of a new or different kind of accident front any accident previously evaluated because no new equipment is being added nor is any existing equipment being modified. Operation of Saltwater IIcader #12 with a leak does not create the possibility of a new accident. Excessive leakage or rupt tre of a Saltwater System }{cader was previously evaluated in the Updated Final Safety Analysis Report regarding the capability of the system to support the decay heat removal function.

This waiver would not involve a significant reduction in a margin of safety. Given the special -

circumstances that presently exist, this waiver would provide for an increased margin of safety over that presently provided for in the Technical Specifications by allowing the use of Saltwater Header 411, irrespective of its non conformance wit) the structural integnty requirements of Technical Specification 3.4.10.1.c.

For the above reasons, this waiver would not involve a significant hazards consideration, llASIS FOR CONCLUSION TilAT Tills WAIVER WOULD NOT INVOLVE IRREVERSillLE ENV1RONMENTAL CONSEOUENCES This waiver, if granted, would invahc a change in a requirement with respect to the use of plant components within the restricted areas as defined in 10 CFR 20. Ilowever, this change vould not involve an incresac in the amounts or types of effluents that may be released off site, nor will there by any increase in indivMual or cumulative occupational radiation exposure, Therefore, this waiver would have no adverse emironmental impact, temporary or permanent.

SAFl?IY COMMI'ITEE MINIEW This sequest has been reviewed and approved by the Plant Operations and Safety Review Committee.

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I Should you have any further questions regarding this matter, we will be pleased to discuss them with

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Very truly yours,  :

, w F

O. L Detter

'"' r - uclear Regulatory Matters l OLD/BSM/gla  !

cc: D. A. Brune, Gs uire ,

ufre J.

R. E. Silberg, N A. Capra, D. G. Mcdonald, Jr., NRC

. T. T. Martin, NRC  ;

L E. Nicholson. NRC (

R. Mclean, DNR b

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