ML20059G374
| 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: |
| References | |
| GL-89-14, NUDOCS 9009120276 | |
| Download: ML20059G374 (4) | |
Text
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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.
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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
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conducive to the safe conduct of a surveillance. Additionally, removal of the limit reduces the potential for unnecessary forced shutdowns to perform surveillance activities.
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' Document Ccntrol Desk 1
' August 28, 1990 1
Page 2 l
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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
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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.
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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.
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Document Centr:I Denk i
August 28,.1990 Page 3 DETERMkNATION OF SIGNIFICANT HAZARDS This proposed change has been evaluated ogainst the standards. In 10 CFR' 50.92 and has d
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been determined to involve no significant hazards considerations, in that operation of c
the facility in accordance with the proposed. amendment would not:
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- (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:
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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
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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
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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,
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, personally appeared George C. Creel, being dtfli sworn,~ andf/ states the State of[Jee President.of the Baltimore Gas and Electric Company, a corporation of that he is 1 Maryland; that he provides the foregoing response for the purposes therein 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:
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/A' ary fublic l
t My Commission Expires:
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Attachments
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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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