ML20059G374

Application for Amends to Licenses DPR-53 & DPR-69, Respectively,Revising Pages 3/4 0-2 & B 3/4 0-3 & B 3/4 0-3a of Tech Specs Re Surveillance Requirement 4.0.2,per Generic Ltr 89-14

ML20059G374
Person / Time
Site:	Calvert Cliffs
Issue date:	08/28/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059G379	List: ML20059G374 ML20059G381
References
GL-89-14, NUDOCS 9009120276
Download: ML20059G374 (4)

Text

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,1  !

e BALTIMOPtE .

5 OAS AND 1 ELECTRIC ,

CHARLES CENTER e P.O. BOX 1475

• BALTIMORE, MARYLAND 21203 1475 l

Gromot C. CRECL v.cc ence,prN, l

W CLlan rNtmet noo ,.o a **

r August 28, 1990  !

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

SUBJECT:

Calvert Cliffs Nuclear Power Plant  !

Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Reauest for License Amendment -

REFERENCE:

(a) Line-Item Improvements in Technical Specifications - Removal of the 3.25 Limit on Extending Surveillance Intervals (Generic Letter 89-14), dated August 21, 1989 ,

i Gentlemen:

The Baltimore Gas and Electric Company hereby requests an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos. 1 & 2, respectively, with the submittal of the proposed changes to the Technical Specifications.

}i CilANGE (BG&E FCR 90-103) l Change pages 3/4 0-2, B 3/4 0-3 and B 3/4' 0-3a of the Unit I and Unit 2 Technical Specifications as shown on the marked-up pages attached to this transmittal. ,

The proposed change would revise Technical Specification Surveillance Requirement 4.0.2  !

by deleting the requirement that the combined time interval for any three consecutive surveillance intervals is not to exceed 3.25 times the specified surveillance interval. '

The proposed change is based on the guidance of NRC Generic Letter 89-14, 'Line-Item improvements in Technical Specification -

Removal of the 3,25 Limit on Extending Surveillance Intervals," [ Reference (a)). i Baltimore Gas & Electric requests approval of the proposed amendment by-January 15, 1991. While the proposed change is not required to address an immediate ,

safety concern, we concur with Generic Letter 89-14 in that removal of the 3.25 limit  !

will result in a safety benefit by providing for flexibility that nauld allow surveillance activities to be scheduled at times when plant conditions are more +

conducive to the safe conduct of a surveillance. Additionally, removal of the limit reduces the potential for unnecessary forced shutdowns to perform surveillance activities. 1 0'

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' Document Ccntrol Desk 1

' August 28, 1990 1 Page 2 '

l 1 I

DISCUSSION l

On August 21, 1989, the NRC issued Generic Letter 89-14. "Line-Item Improvements in- '!

l Technical Specifications - Removal of the 3.25 Limit on Extending . Surveillance  ;

l Intervals? In this letter, the NRC staff noted _ that they have routinely _ granted requests for one-time exceptions to the 3.25 limit to accommodate variations . in ' the . ,

length of a fuel cycle. While the~ 25% allowance is usually - sufficient to accommodate l variations in cycle length; the more common occurrence has been to encounter the 3.25-  ;

limit on the combined ' time interval for. three consecutive surveillances. The basis for these exceptions: was that' the risk to safety due to the extension of these .. surveil-lances was low in contrast to the alternative of a forced shutdswn to perform the .-

surveillances.' Furthermore, the NRC staff concluded that the elimination: of- this -

i' limit for - surveillances that are performed on a routine basis during plant operation:

would also result. in = a significant safety benefit.

Calvert Cliffs currently operates on c 24-month fuel cycle. Some surveillances have a ,

frequency of once per 18 months and are - not associated with refueling ' outages.1 A (

statement will be added - to the appropriate administrative procedures; to ensure that L the ~  :

25% allowance is not abused for these surveillances.

We concur with the NRC's finding that approval of -this request will:

1. Facilitate scheduling of surveillance- activities and allow surveillances to be postrsned when plant conditions are less conducive to the safe conduct of a tu <eillance;

2. Rr + ct. the potential for unnecessary . forced shutdowns to perform surveillance activities; .!

3. Eliminate the administrative buiden associated with tricking-' the use of the 25% allowance to ensure compliance with the 3.25-limit; and .

4. Minimize the need for license amendments to . extend surveillance intervals.

l In summary, the flexibility to schedule surveillances . so ' that- conditions [less suitable for performing these surveillances can be avoided outweighs ~ any; benefit. : derived by limiting .three consecutive surveillance intervals to the 3.25' limit. We, therefore, conclude that removal of the 3,25 limit for surveillances is._ justified. In addition,;

we proposed a change to the - Bases for Technical Specification ' 4.0.2 ? to ^be consistent with the recommendations of Generic Letter 89-14.

I e - r-yw e

l Document Centr:I Denk i August 28,.1990 Page 3 1

DETERMkNATION OF SIGNIFICANT HAZARDS

~

This proposed change has been evaluated ogainst the standards. In 10 CFR' 50.92 and has d c been determined to involve no significant hazards considerations, in that operation of I- the facility in accordance with the proposed . amendment would not:

- (i) Involve a significant increase in the probability or consequences of an accident previously evaluated:

s The surveillance intervals will continue to be constrain'ed: by the 25% limit.  ;

of Technical Specification 4.0.2. The 3.25 surveillance interval- provision  !

was not considered in any safety' analyses. Any risk = associated with  ;

exceeding the 3.25 ' limit is outweighed by the' risk associated - with a forced shutdown to perform surveillances which 'would normally be: performed 'during a- refueling outage, in addition, 'for those surveillances which . are routinely performed during plant . operation, o the flexibility to schedule, surveillances to avoid . plant ' conditions which - are - less conducive . - to surveillances represents a positive safety- benefit. Therefore, the proposed change does ' not involve a significant increase in the probability "

or consequences of an accident previously evaluated. ,

! (ii) Create- the possibility of a new or different type off accident from any accident previously evaluated:

l l The proposed change would not result in any physical = alteration to any  ;

plant system, nor would there be a change . in the method in which any safety-related system performs its function. The ~ change - would not : result in any equipment being operated in a manner different than that in which it-was designed to be operated. Therefore, the# proposed . change . will not create the possibility of a new or different ' kind . of accident frem any.

previously evaluated.

(iii) Involve a: significant reduction in a . margin of safety:

Deletion of the 3,25 limit will . not significantly affect the performance of equipmer.t required to maintain the margin of safety as defined in t*,6 Technical Specification Bases and the safety analysis report. Rather, it  !

will reduce the potential for interrupting normal plant operation. due to surveillance scheduling. Surveillance int::rvals ' will ' continue to be .q l constrained by the 1.25 limit. The added . flexibility in scheduling i surveillances afforded by deletion of the 3.25 limit should hr.ve a positive safety benefit by allowing surveillances - to be performed under appropriate plant conditions. Therefore, the proposed change does not ~ involve a l significant reduction in a margin of safety, i

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, Document CCntrol Desk  ;

August 28, 1990-  !

Page 4 SAFETY COMMTITEE REVIEW [

i These proposed changes to the Technical- Specifications ' and' our , determination : of:  ;

significant hazards - have been reviewed by our Plant. Operations and Safety Review i Committee and Off-Site Safety Review Committee, and they - have concluded that  !

implementation of these changes will not result in an undue risk to the health and  ;

safety of the public.

Very truly . yours .

F STATE OF MARYLAND '

%s a 6uov.t l i I hereb c rtify that on the 2Nb day of- M IL , 19 0 re me, the sutypriber,1 Notary Public of the State of ' Marylai(d in' and for M, dll>c; l

( W1471s , personally appeared George C. Creel, being dtfli sworn,~ andf/ states that he is 1 the State of[Jee President Maryland; that he.of the Baltimore provides Gas response the foregoing and Electric for the Company, purposes atherein corporation of i

set forth; that the statements made are true - and correct to the best of . his knowledge, i information, and belief;- and that he was authorized to provide the response on behalf of said Corporation. l WITNESS my Hand-and Notarial Seal: L M.d _ /A' ary fublic l t

My Commission Expires: /_ "/M 8 h fd GCC/BSM/ dim

D .

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Attachments {

cc: D. A. Brune, Esquire J. E. Silberg, Esquire  :

l- R. A.Capra, NRC l D. G. Mcdonald, Jr., NRC T. T. Martin, NRC  ;

L. E. Nicholson, NRC R.1. McLean, DNR 4

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