ML20070T353

Submits Update & Implementation Schedule for Emergency Classification & Action Level Scheme,Per NUREG-0654 & Forwards Response to NRC Review Questions on Change 2 to Rev 14 to Emergency Classification & Action Level Scheme

ML20070T353
Person / Time
Site:	Calvert Cliffs
Issue date:	03/29/1991
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 9104040122
Download: ML20070T353 (4)

Text

• .

13 ALTIMORt!

, OASAND

,, ELECTRIC CHARLES CENTER

• P.O BOX 1475

• DALTIMORE, MARYLAND 21203 1475 GroRot a Cettk v ca h c s+t a March 29,1991 w'ni..t t...

-, , . n . u U. S. Nuclear Regulatory Commission Wa:.hington, DC 20555 NITENTION: Document Control Desk SUIUECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50 318 Emergency Classi0 cation and Action Level Scheme Update and trnplementation Schedule

REFERENCE:

(a) Letter from Mr. James 11. Joyner (NRC) to Mr. George C. Creel (BG&E). Review of Calvert Cliffs Nuclear Power Plant Emergency Action levels (EALs), dated February 12,1991 (b) NRC Combined Inspection Report Nos. 50 317N004 and 50 318S0 04 Gentlemem Reference (a) discusses the results of Nuclear Regulatory Commission sttif review of Revision 14, Change 3 to the Emergency Classification and Action Level Scheme for Calvert Cliffs Nuclear Power Plant. This review concluded that the Emergency Action Level (EAL) scheme has been % proved, but that additional changes are needed to meet the guidance of NUREG 0654. The letter requested a response to staff review comments and a schedule for implementing further changes to the EAL scheme.

it has been BG&Es consistent intent to use the guidance of NUREG 0654 in defining those conditions which should initiate EAL declarations. We have been equally attentive in attempting to insert that guidance into our EALs in the form of dennitions that are clear-cut and straightfonvard for application by our operat;ng staif. To this end, we have tied EAI. declarations to our Emergency or Abnormal Operating Procedures (EOP/AOP) wherever possible. Since these do not fit identically with the wording of NUREG4)654, we have attempted to identify equivalent conditions as nearly as possible while still complying with the intent and spirit of NUREG 0651, We have carefully considered your previous comments from Reference (b) in evaluating these interpretations, and have

! resolved most of your noted concerns. Your most recent letter addresses some remaining items. We l have reviewed these and our comments are provided in Attachment (1). Additionally, our implementation schedule is included in Attachment (2). ,

1 As discussed earlier this month with Mr. Jim Wiggins of the Region 1 office, BG&E Emergency i l

Planning personnel will discuss the specifics of the EAL revision with you at your convenience in l King of Prussia.

&$ A'IUY f lh? Ei&? mms  %. ool M W WO ' I

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i Docuinent Control Desk l hintch 29,1991 1

Page 2 Should you have any further questions regarding this inutter, we will be pleased to discuss thern with you.

Very truly yours, i

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, (, / '1 GCC/TEF/REIWjd i .j '

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Attachinents ec: D. A.13 rune, Esquire J. E. Silberg, Esquhe R. A. Capra, NRC D. G. hicDonald, Jr., NRC j T. T, biartin, N RC L E. Nicholson, NRC R. I, hicLean, DN R J. II, Walter, PSC i

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NITACllMENT (1)

. ILESPONNjtTO NltC lllNIEW COMMENTS

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0654 guidance but that revision to incorporate , it is our your co intent to include these items in our next modification to the EALs.

1. BGkE considers that NOUE 6. which discusses Safety / Relief valves, is curr under ' Equipment described in Technical Specification" and Temperature malfunction. / Pressure outside of Technical Specification" which woald resultthrough " A condition. We will, however, incorporate an additional EAL to from clarify such a the inclusion of this EALs. For totalloss of onsite power an alert level emerg -

Station Blackout implemented." For partialloss of onsite power a NOUE would ,

the general safety category EAL: " Equipment described in that ... ."

a eTechnical such Specifica 0654 to the extent that unambiguous guidance could e degree of subjectivity into our classification. Since it is c latitude ofinterpretation better meets the needs of the public, ewe will agree to t .

BG&E views SAE 10 as an instance where the existing EAL complies with N Adopting your comments willimprove the conservative level for implementing the intention to include this implementing levelin our next change to the EAL .

discussed NRCs concern. in SAE 18 as equivalent. We agree, however e BG&E has reviewed GE #5 and agrees to add specific core rnelt sequences as listed.

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ATrACJIMENT(2) 1:4L HlWISION SCl]JillElf e

SCilEI)ULEI)

COMl'L1!!'lON ACI'IYl'Il jg Develop EAL revision responsive to NRC concerns April,1991 Technical review of proposed EAL revision (includes comment May,1991 resolution)

Plant Operations and Safety Review Committee review of proposed EAL revision (includes comment resolution) June,1991 NRC review of proposed EAL revision (Region I and NRR;

-includes comment resolution)' July August,1991 State / County review of proposed EAL revision September,1991 Conduct training on EAL revision - September October, 1991 EAL final approval and implementation November,1991 L

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