ML20043A243
| ML20043A243 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/09/1990 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9005210073 | |
| Download: ML20043A243 (3) | |
Text
{{#Wiki_filter:- a P MAY 0 9' 1990 - 4 1 Docket Nos. 50-317/50-318: Baltimore Gas.and Electric' Company ATTN:. Mr.-George C. Creel .Vice President -Nuclear Energy Calvert Cliffs Nuclear Power Plant 1 - M0 Rts 2 and 4 Post Office Box 1535 Lusby, Maryland. 20657 Gentlemen:
Subject:
Temporary' Waiver of Compliance Related to the Use of a StructurallyJ r Degraded Train of the Salt Water. System This responds to your May 5,1990 letter-requesting a Regional Temporary Waiver 1 of_ ' Compliancefor operation - of the #11 -salt water.- system while not meeting applicable ASME Class III, code and _ Technical ~ Specification ~ requirements to facilitate' cleaning of the L #12 service water heat exchanger. . letter-is attached for reference.. ALcopy'of!your 4 This request was discussed in:a conference call between youristaff and Messrs. James Wiggins, Wayne Hodges and Curtis Cowgill? off this office, Mr.: Jack Roe _of-toe Office of Nuclear Reactor Reg'ulation and Mr. Larry Nicholson, the' Senior O sident Inspector at Calvert Cliffs, on-May 5, 1990. Af ter careful consideration of your request, I concluded that:...(1) theLintent of the proposed use of #11' salt water header. was to maintain the ca.pability of decay heat removal; (2) the probability-of a -significant increase in leakage -i from #11 salt water header was slight; and, (3) the relief generated.would not 1 4 - put the plant in an unsafe condition based on decay heat: considerations. A Regional Temporary Waiver of Compliance was thereby-grantedborally o' May 5, n 1990 for unisolating and using the ~#11 salt water header = with a piping con-- dition that did not conform with ASME Code Class III requirements. .This i Temporary Waiver was a-six-hour relaxation of the. requirements of Technical 1 Specification 3.4.10.1.c. l 9005210073 900509 n {DR ADOCK 05000317 \\\\ PDC f8
Baltimore. Gas.and Electric Company '2' I ',,i (5[" Subsequent. to.the granting of-the' Waiver, we have noted that.the plant staff 4 successfully completed the work necessary -to. isolate the' degraded section of' salt M.vr riping within the duration of the Waiver. Sincerely, ORIGINAL SIGNED BY: - JAMES T. WIGGINS j c William F. Kane, Director Division of Reactor-Projects
Attachment:
As stated cc w/
Attachment:
T. Magette, Administrator, Nuclear Evaluations. J. Walter, Engineering Division, Public: Service Commission of. Maryland G.-Adams, Licensing:(CCNPP) K.. Burger, Esquire, Maryland People's~ Counsel P. Birnie, Maryland; Safe Energy: Coalition Public' Document Room (PDR) . Local Public Document ~ Room'(LPDR) Nuclear Safety Information Center. (NSIC). NRC Resident Inspector State of Maryland (2) 0FFICIAL RECORD COPY LATHROP 656 5/7/90 - 0002.0.0 05/07/90
l, a baltimore Gas and Electric Company 3 i bec w/A'ttachment:-- 1 Region I Docket Room (with concurreness) W. Hodges, DRS W._Kane, DRP
- J; Wiggins, DRP J. Linville, DRP C. Cowgill, DRP'
( D. Limroth, DRP i D.'Vito, DRP 'K; Lathrop,.DRP-K. Abraham, PA0- 'M. Taylor, SLO l M. Callahan, OCA D.-Mcdonald, NRR' J.'Caldwell, NRR- .i i l L) 1'l .j. i a RI:DRPy 9 RI:DRP RIADRP I:DRP R 4 Klathnop/mjd CCowgill JLinv111e Wiggins TM tin-5/9/90 5/i/90 5 /90 \\ '5d /90 / 0 0FFICIAL RECORD COPY LATHROP-656 5/7/90 - 0003.0.0 05/09/90 J l l 1
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- OAS AND ' '.
ELECTR80 f ^ g = P CHARLES CMTER i P.O. BOX 1476. ; BALTIMORE. MAMLAND 2120s
- May 5,1990
- U. S. Nuclear Regulatory Commission -
, Washington, DC 20555 .NITENTION: Document ControlDesk SURIECT: Calvert Cliffs Nuclear Power Plant - i Unit No.1; Docket No.50317 Request for Regional Temporar:y Waiver of Compliance from a Limitin for Oneration i 1 Gentlemen: i E 1 i HIE REOUIRF3fENT FROM WHICH A WAIVERls REOUISITD. 2 i compliance to provide relief from a provision of the LimiThe Ba i a ver of Specification 3.4.10.1, ' Structural Integrity of ASME Code Condition for Operation of Technical would specifically provide relief from the requirement of Action Statement 3A 10 i component not conforming to the structural integrity requirements fo ~ ASME C ..c to isolate a cornponents. . r ode Class 3: a, The purpose of this request is to allow one train of the Siltwater' System c conforrmng component to be unisolated (contrary to Technical Specificat q g a non* j into operation while the remaining train is teroprar0y remowd from service n placed 1 that is necessary to maintain its heat removal Noction ' Relief from' thi T h er orm ' leaning c provision is requested on a one time only basis and for a duration of up to six s ec nical Specification l D_ES,91]EllON OF CIRCUMSTANCES AND THE NEED FOR_THE WA1VER 1 discharge piping of Saltwater Pump #13. The leak is ] a leak in the l downstream of the outboard pump discharge isolation valve before the ange to-pipe weld ' just piping connects with Saltwater System Header #11. Because of th ere the d' ischarge isolable from Saltwatei Header #11. Technical Specification 3A.10.1.c stau s: i .1 component (s) not confonning to the above requiremen structuralintegrity of the affected component (s) to within its limit or isolate the affected component (s) from service. i f 1 e
m,# lc1 oOf e:29 F RQtf CCl4FP.'HE SD l E F.- 1 r t.P W E"000 ^ Document Control Desk 1 ~. May5,1990 i L Page 2 L The aficcted component is clanified as ASME Code Class 3. The non-conformi L l in the Gange tr> pipe weld. Restoration of structuralintegrity involves inspection K weld, which in turn requires holation of the leak from the spiem. Since there is no insta; led means h' of accomplhhing this isolation locally, the entire Saltwater Header #11' must be isolai removed frem service pursuant to Action Statement 3A.10.1.c until the leak is repaired.E i Accordingly, Action Statement 3A.10.1.c was catered at 1130 ESTon May 4,1990, and 1 . to Saltwater Header #11 and is cunently in service an 1 1 cooling to plant components via Senice Water Heat Exchanger #12. To maintain #12 Heat t ' Exchanger's capacity, cleaning must presently be perform expected to be required again on the morning of May 6,1990. j i: J While thh cicaning is performed, SW Header #12 will be inoperable for a period of betwxn tw y four hours. If Saltwater Header #11 was'not placed back in senice when #12 Saltwater Head[ talen out-of service foi cleaning, the plant nutd have no decay heat removal capability i cooling) until the cleaning was completed. If Saltwater Header #11 is unisolated and placed b into service for the period requhed to cican Saltwater Heat Exchanger #_12, then decay; capability will be retained. 'Ihe nature of the leak in Saltwater Header #11 is such that it does not I . threaten its capability to perforrn its safety function of decay beat' removal (the lea hole approximately 0.25 cmEin size). Honver, Saltwater Header #11 cannot be returned to s i due to the aforementioned restriction of Technical Specification 3A.10.1.c. 1 COMPENSATOR.Y_ ACTIONS (IF.A&l During the period of time that Saltwater Header #11 is placed in service, a dedicated - t te in the vicinity to observe any increase in leakage rate. SAFETY CONSEQUENCES ASSOCIATED MTTH GRANTING A. TEMPOR COM!lLIANCE 1, A temporary walver of cornpliance from Action Statement 3A10.1.c would allow Saltwater H
- 11 to be placed into senice to provide a decay beat rernoval function for a short period o v,hile the redundaut train is taken out of senice for required cleaning. Without a waiver, Saltwate Header #11 would not be returned to service and Saltwater Hesder #12 w until it was either removed from senice for cleaning or until Dow us degraded due to the point where its beat removal functica was jeopardized. In citber case, there wou time when the decay heat removal function was not being satisfied.
l' Approval of this waiver will provide for continuous, uninterrupted decay heat removal. On comcquence asmciated with (bc granting of this waiver vmuld be that the leak in Saltwater IIcader
- 11'could enlarge while this header was in senice. In this case, the increased leakage detected and, if necessary, the header would be removed from senice. 'Ihis is not c given the short period of time Saltwater Header #11 will be owrated (up to six bours).
an increase in leakage and subsequent removal of Saltwater hicader #11 from service _C the plant in the same condition that would be prevailing if this waiver was not granted. In fact this waiver, if granted, would increase the level of plant safety and minimize because it would allow the full utilization of a safety sptem in order to perform a function irrespective of the fact that a component within the system is not in conformancj ASM13 Code requirement. Consequently, this waiver would not pose any unouc risk to pub m .. _. ~ m. .m.,
.w.~.., m. " nsW Si?90 1 Eu 3o f FROMiCCHPP/NEED;NEF-IFLR_ k " P A G E !.' o 0 4 ' N Document Contron Desk- - c l. May 5,1990 l i L . Page 3 'l ij and safety and would, in fact, provide an increawd level of protection given the special circumstances, j that presently exist, l DURATION OlLTpfPORARY WAIVER 7 nis waiver is requested for a duration of six bouts to accommodate cleaning of Saltwater Header ' j
- 12. Cleaning is normaUy accomplished within two to four hours. During the 48-hour period of-
- operation Saltwater Mcader #12 that will follow this cleaning, the leak in Saltwater Header #11 wiu j be repaired. s i BASIS FOR CONCLUSION THAT THE WAIVER DOES NOT CONSTITUTE A SIGNIFICANTl HAZARDS CONSIDERADON r This waiver would not involw a significant increase in the probability or consequences of an accident .[ previously evaluated. The accident of concern is a loss of decay beat removal capability. This waiver i would prmide lacreased assurance that adequate decay beat removal capability,will be avauable,' considering the need to periodically remove one train-of the Saltwater System from service for j mquired cleaning. This waiver would not create the possibility of a new or different kind of accident from'any accident. 1 previously evaluated because no new c5 ulpment is being added not is any existing uipment being-1- inodified. Operation of Saltwater Header #12 with a leak does not create tbc posu ility of a new accident. Excessive leakage or rupture of a Saltwater System Headcr was previously evaluated in'the 1 Updated Final Safety Analysis Report regarding the capabuity of the. system to support the_ decay heat removal function. nis waiver would not imolve a significant reduction in a margin of safety. Given the special' circumstances that presently existi this waiver would provide for an increased margin of safety over that presently provided for in the Technical Spifications by allowing the use of Saltwater Header
- 11,.iricapective of its non.conformance wit 2 the structural integrity requirements of Technical Specification 3.4.10.1.c.
.i For the above reasons, this waiver would not involve a significant hazards consideration. BASIS FOR CONCLUSION THAT THIS WAIVER WOULD NOT INVOINE IRRf'VERSIBLE ENVIRONMENTAL CONSEQUENCES - l t This wahur, if panted,_would involve a change in a requirement with sespect to the use of plant-l companents within the restricted areas as detned in 10 CFR 20. However, this change 'would not i 1 inmive an incresae in the amounts or types of effluents that may be released off site, not win there 1 by any increase in individual or cumulative occupational radiation exposure. Therefore, this waiver would have no adverse emironmental impact, temporary or perrnanent. y SAFYO'COMMFCTEE REUEW This request has been reviewed and approved by the Plant Operations and Safety Review Committee. i
iM
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- Page 4 1
r - buld you have any further questicii regarding in matter, we will be pleased to'discu ' Very'trulyyours.. I J l.- i. G. L Detter .s i h Director. Nuc1 car Regulatory Matters . GLD/BSM/gla i 1 ~ f cc D.' A. Brune, utre k J. E Silberg, R. A.Capra C . D. G. McDo,nald, Jr. , T. T. Martin, NRC, NRC l L E.Nicholson,NRC. 1 R.~ McLean, DNR'- i l l'- I k i s l 1 ?. l: 4 l: 3 t -{ .t 5 1 i f.' .) l' l, e 4 .}}