ML20059L405

Application for Amends to Licenses DPR-53 & DPR-69,revising TSs by Relocating Tables of Response Time Limits for Reactor Protection Sys & ESFAS Instruments from TSs to Updated FSAR

ML20059L405
Person / Time
Site:	Calvert Cliffs
Issue date:	11/11/1993
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059L409	List: ML20059L405 ML20059L412
References
NUDOCS 9311170057
Download: ML20059L405 (5)

Text

l A B ALTIMORE GAS AND l l

ELECTRIC l 1650 CALVERT CLIFFS PARKWAY . LUSBY, MARYLAND 20657-4702 ROBERT E. DENTON VICE PRE SIDENT NUCLEAR ENERGY i4 0)260-4655 November 11,1993  !

U. S. Nuclear Regulatory Commission l Washington, DC 20555 i ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request; The Relocation of the Technical Specification Tables on Instrument Response Time Limits i

REFERENCE- (a) Federal Register Notice, Proposed Generic Communication,

" Relocation of Technical Speification Tables on Instrument  !

Response Time Limits," dated April 7,1993 (5SFR18118) l l

l Pursuant to 10 CFR 50.90, the Baltimore Gas and Electric Company hereby requests an Amendment '

to Operating License Nos. DPR-53 and DPR-69 by incorporating the changes described below into the Technical Specifications for Calvert Cliffs Unit Nos.1 and 2.

DESCRIPTION The proposed amendment would revise the Technical Specifications for both Units 1 and 2 by relocating the tables of response time limits for the Reactor Protection System (RPS) and the Engineered Safety Features Actuation System (ESFAS) instruments from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR). This proposed amendment is a "line-item" technical specification improvement and follows the guidance of the draft generic communication that was published in Reference (a). We are basing this proposed amendment on the draft generic communication because of modifications that are scheduled for the spring 1994 Unit I refueling outage.

HACKGROUND The proposed amendment would resise the Technical Specifications by relocating the tables of response time limits for the RPS and the ESFAS from the Technical Specifications to the UFSAR.

This change will allow changes to the response time limits for the RPS and ESFAS instruments to be processed (mder administrative controls in accordance with the provisions of 10 CFR 5059 without the need to process a license amendment request. Changes to these limits would then be submitted as an update to the UFSAR as required by 10 CFR 50.7 (c). R Jated changes to plant procedures 9311170057 931111 PDR ADOCK 05000317 6g/I P PDR ,

fltI

Documertt Control Desk November 11,1993 Page 2 would be subject to the provisions that control changes to plant procedures as stated in the Administrative Controls Section of the Technical Specifications. The response time limits will be included in the next update to the UFSAR.

COST-IIENEFICIAL LICENSE AMENDMENT NRC approval of this license amendment request will reduce future plant operating costs by eliminating the need for NRC review and approval of changes to ESFAS response time limits.

Without this change, at least one amendment would be required to support the upcoming spring 1994 Unit I refueling outage, and it is anticipated that many additional amendmunts would be requested in the future to support changes to the ESFAS response times list if it were to remain in the technical specifications. Many of these changes are the result of motor-operated valve testing being conducted under the NRC Generic Letter 89-10 program, and others are expected as future design basis resiews are completed for plant safety systems. Such changes are more cost effectively evaluated under 10 CFR 50.59. Elimination of the ESFAS response times table from the technical specifications allows for greater flexibility, reduced impact on licensee and regulatory resources, and more timely evaluation and resolution of non-conforming conditions. For test results which exceed the allowed response time but do not constitute an unreviewed safety question, the approach proposed under this license amendment request would allow changes to t' : response time to be reviewed under 50.59, avoiding the need for exigent licensing action, and possibly avoiding unnecessary plant shutdowns or delays in plant su -:p.

REOUESTED CllANGE l Change Specifications 3.3.1.1,4.3.1.1.3 and 3.3.2.1 of the Unit I and 2 Technical Specifications as l shown on the marked-up pages attached to this transmittal.

l SAFETY ANALYSIS

' The RPS and ESFAS instruments provide the actuation signals necessary to actuate the safety equipment needed to mitigate accidents and transients. The relocation of the response time tables from the Technical Specifications to the UFSAR will not affect this safety function in that this change does ne change the operability or surveillance requirements for these instruments from the estir.f4 echnical Specification requirements. Changes to the response time limits will be processed under the administrative controls of 10 CFR 50.59. The 50.59 process requires any change to these instrument response times that results in a plant response more severe than the current accident analysis to be submitted to the NRC for review and approval. Changes to the response times that do rot adversely impact the accident analysis would be implemented and submitted as an update to the i UFSAR as required by 10 CFR 50.71(c).  !

DETERMINATION OF SIGNIFICANT IIAZARDS The proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to not involve a significant hazards consideration, in that operation of the facility in accordance with the proposed amendments:

Document Control Desk  ;

N6vember 11,1993 Page 3

1. Would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The Reactor Protective System (RPS) and the Engineered Safety ?catures Actuation System (ESFAS) provide the signals needed to actuate the safety equipment necessary to mitigate accidents and transients. The proposed change relocates the RPS and the ESFAS instrument response times from the Technical Specifications to the Updated Final Safety Analysis Report (UFSAR) but will not change the operability or surveillance requirements for these instruments. With this proposed change, revisions to the response times for these instruments can be made pursuant to 10 CFR 50.59 without Nuclear Regulatory Commission (NRC) approval unless the revision involves an unreviewed safety question. The proposed change will not change any accident initiators or the consequences of any analyzed accident.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Would not create the possibility of a new or different type of accident from any accident previously evaluated.

The proposed change relocates the RPS and the ESFAS response time limits from the Technical Specifications to the UFSAR but does not change the function of these instruments. The proposed change does not represent a change in the configuration or operation of the plant. No new hardware is being added to the plant as part of the proposed change. The Technical Specifications will continue to require the same operability and surveillance requirements to be met for these instruments. Therefore, the proposed change does not create the possibility of a new or different type of accident from any accident previously evaluated.

3. Would not involve a significant reduction in a margin ofsafety.

The proposed change will not affect the functions of the RPS or the ESFAS instruments.

Relocating the response time limits will not alter the operability or the surveillance requirements on these instruments. The administrative change control provisions for the UFSAR and the plant procedures written pursuant to 10 CFR 50.59 are adequate to control revisions to the response time limits. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

ENVIRONMENTAL ASSESSMENT The proposed amendment would not change requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes to an inspection or surveillance requirement. We have determined that the proposed amendment involves ,

no significant hazards considerations, and that operation with the proposed amendment would result in no significant change in the types or significant increases in the amounts of any effluents that may be released offsite, and in no significant increase in indhidual or cumulative occupational radiation exposure. Therefore, no emironmental impact statement or emironmental assessment is needed in connection with the approval of the proposed amendment. j l

1

_ _ - _ _ _ -_ . . . . __ m- . . _ . . _ _

l 1

Document Control Desk i November 11,1993 i Page 4  ;

SCIIEDULE I s

This change is requested to be approved and issued by February 1,1994. This schedule will support  !

modifications to the low pressure safety injection loop motor-operated valves and the Emergency l Containment Sump motor-operated valves that are scheduled for the 1994 Unit I refueling outage, j which would otherwise require additional license amendments. l r

i SAFETY COMMrITEE REVIEW l

l These proposed changes to the Technical Specifications and our determination of significant hazards ,

have been reviewed by our Plant Operations and Safety Review Committee and Offsite Safety '

Review Committee. They have concluded that implementing these changes will not result in an undue risk to the health and safety of the public. j Should you have any questions regarding this matter, we will be pleased to discuss them with you. j Very truly yours, j n (

r  ;

STATE OF MARYLAND :

TO WIT :

COUNTY OF CALVERT  :

4 I hereby certify that on the /[ day of /Vove/nb# ,1993, before me, the subscriber, a Notary Public of the State of Maryland in and for dt/ vert dbok/ ,  !

personally appeared Robert E. Denton, being duly sworn, and states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the l foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the ,

response on behalf of said Corporation.  ;

WITNESS my Hand and Notarial Seal: (

Notary Public l My Commission Expires: cpty k

Date j' RED /DJM/ dim Attachments (1) Unit 1 Technical Specification Revised Pages (2) Unit 2 Technical Specification Revised Pages

~

Document Control Desk November 11,1993 Page 5 i

cc: D. A. Brune, Esquire ,

J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC ,

R. I. McIran, DNR J. H. Walter, PSC i

l l

l l

I i

i l

l l

l l

)

l