ML20074A993
| ML20074A993 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/05/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20074A991 | List: |
| References | |
| NUDOCS 8305170266 | |
| Download: ML20074A993 (7) | |
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g UNITED STATES 85' -
o NUCLEAR REGULATORY COMMISSION 4
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..; f WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE '0FFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NOS. 83 AND 66 TO FACILITY OPERATING LICENSES NOS. DPR-53 AND DPR-69 BALTIM0RE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT UNIT NOS.1 & 2 I
DOCKET NOS. ' 50-317 AND 50-318 Introduction l
By application for License Amenaments dated February 24, 1983, as st.pple-i mented by letter dated March 22, 1983, Baltimore 3as and Electric Company (3G&E) requested changes to the Technical Specifications (TS) for Calvert Cliffs Units 1 and 2.
The proposed changes to the TS would (1) revise Surveillance Requirements for the equipment hatch, (2) revise Surve111ame Requirements fpr safety-related air filter systems, (3) revise Surveillance Requirements and provide for a single period of inoperability for the hydrogen analyzers, and (4) delete the Limiting Safety System Settings and an administrative change associsted with the " Loss of Load' functicn of the Reactor Protection System, in partial response to the February 24, 1983 application.
s In the course of reviewing the proposed TS,we.have found it necessary to t
make certain changes.
These changes were discussed with and approved by BG&E.
4 Discussion and Evaluation i
1.
Surveillance Requirements for the Equipment Hatch Calvert Cliffs TS 4.6.1.1.a.2 requires verification at least once per 31 days that the equipment hatch is closed and sealed.
BG&E has proposed that this requirement be deleted and replaced with new TS 4.6.1.1.c.
This TS would require verification "...that the equipment hatch is closed and sealed, prior to entering Mode 4 following a shutdown where the equipment hatch was open, by conducting a Type B test per Appendix J to 10 CFR Part 50.".
In their February 24, 1983 application, BG&E noted that the existing requirement for visual inspection of the hatch is unnecessary in that seal degradation has not been a problem at Calvert Cliffs.
In addition, radiation exposure for inspection personnel averages 15-30 millirem per person for each inspection.
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i The Calvert Cliffs Units 1 and 2 equipment hatches are described in Calvert Cliffs FSAR Section 5.1.2.1.
Each Calvert Cliffs containment has -
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= a single equipment ' hatch.
The hatch is 19 feet in diameter and is securely bolted to a ring which extends inward from the. containment liner such that the domed surface of the hatch is oriented inward to the containment.
The 4
hatch is -sealed via two machined surfaces on the hatch which mate with resilient i
seals on the face of the ring. Due to the massive nature of the hatch, and the extensive amount of planning and effort required to remove it, it is highly unlikely that the equipment hatch wouTd be inadvertently opened..
Upon opening, however, it ~is important that the equipment hatch -be properly sealed prior to returning the facility to power operation to maintain contain-ment integrity.
The proposed TS would require that the equipment hatch be leak-tested in accordance with the requirements of a " Type B". test as specified in Appendix J to 10 CFR Part 50, prior to returning the facility to power operation, following an outage where the equipment hatch is removed.
Ti.is test would be undertaken by pressurizing the space between the two seals and monitoring the leakage.
Existing TS 4.6.1.2.d, and Appendix ~J to 10 CFR Part 50, require that " Type B" tests be conducted at least every two yeers.
Based upon t.his information, we concluded that.the proposed TS change would~
provide for detection of equipment hatch leakage while keeping radiation expoture to inspection personnel to levels that are as low as is reasonably achf evable.
Since integrity of the eculpr:ent hatch seal is assured there will be no significant endnge in the corsequences analyzed for those accidents for which -
containment integrity is required. Therefore, the proposed change to TS 4.6.1.1 is acceptable.
2.
Surveillance Requirements for Safety-Related Air Filters
-The second issue addressed herein relates to Surveillance Requirements for safety-related air filter systems. These systems are the topic of TS 3/4.6.3
" Containment Systems - Iodine Removal System"; 3/4.6.6, " Penetration Room Exhaust Air Filtration System"; 3/4.7.6.1, " Control Room Emergency ^ Ventilation System"; 3/4.7.7.1, "ECCS Pump Room Exhaust Air Filtrat4 System"; and 3/4.9.12, " Spent Fuel Pool Ventilation System".
The application for license amendment dated February 24, 1983 requested the following changes to the l
Surveillance Requirements for safety-related air filter systems (1) provide a surveillance requirement for the recently installed j
NUCON Test Tray assemblies, l
(2) deletion of the requirement to perform D0P testing of High Efficiency Particulate Air (HEPA) filters upon reinstalling absorber trays, and l
(3) changing the word " system" to the words " filter train" in TS 4.6.6.1.
l By letter dated April 8,1983, BG&E submitted additional information concerning l
these proposed TS changes.
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. BG&E has installed new filter train test assemblies, manufactured by NUCON, in place of standard adsorber' trays in all charcoal filter banks of safety-r' elated air filters at Calvert Cliffs Units 1 and 2.
The purpose of the test assemblies is to allow the withdrawal of a charcoal sample for periodic: penetration testing with methyl iodine to assure continued capacity for. iodine adsorption.
The existing TS for safety-related air filters provide 4
for removal of a longitudinal sample from an.adsorber bed,' or emptying the entire bed, to provide a sample of the charcoal for testing. The NUCON test trays are divided into eight cells one of which is used for obtaining a sample for each charcoal test; subsequent samples are taken from different cells. Thus, the existing TS do not apply to the NUCON test assemblies since neither a longitudinal sample nor an entire bed.is removed to obtain the charcoal sample for testing. SGt.E has proposed the following TS to be added to the Surveillance Requirements for safety-related filter systems:
"Emotying a representative sample from an adsorber test tray section, mixing the adscrbert thoroughly, and obtaining samples at least two inches in diametet and with s lengtn equal to'the thickness of the bed. Succeuive samples will be removed from different test tray sectionn' The preparation of the charcoal swple, "...m-ixing the adsorbent thoroughly and obtaining samples at least two incSes in dimieter with a length equal to tr.e thickness of the bedJ..", is an approved industrial standard methodology t
( ANSI-N509-1980, Appendix A) that is currently within the guidelines of Regulatory Guide 1.52 incorporated in the Calvert Cliffs TS. The remainder of the proposed TS, the emptying of a representative sample and the use of 1
successive campl.es from different test tray sections, apply specifically to the NUCON test trays. The XUCON dsorber test tray is divided into eight sections. When a section is emptied for laboratory analysis it will not be refilled with charcoal adsorbant, but be covered with a seal plate to identify its location. When the specified flow rate, due to tray sections being sealed off, cannot be met, the complete charcoal adsorber bank will be replaced including the test tray sections that have been emptied.
This procedure meets the recommendations of ANSI-N509-1980 and is an acceptable alternative to Regulatory Guide 1.52 (Rev. 2). Our review of the February 24, l,
1983 application indicates that the use of the NUCON test trays at Calvert l-Cliffs -is acceptable.
The proposed TS will assure proper selection and i
preparation of a representative charcoal sample for analysis to assure that the charcoal continues to be an effective agent for post-accident iodine removal, as assumed in the safety analysis. Accordingly, we find the revised Surveillance ReqQirements for the NUCON test trays to be acceptable.
In addition, the existing TS for the previous types of test trays which involve emptying the whole tray or a longitudinal section should be deleted in that these trays are no longer used at Calvert Cliffs.
The second issue associated with safety-related filters involves deletion of a requirement, contained in the Surveillance Requirements for testing of the HEPA filters following reinstallation of the charcoal test trays.
This requirement had been contained in the TS of a number of facilities -as a result of a generic concern that, in the process of removal and reinstallation of charcoal test trays, the HEPA filters might be damaged. We have reviewed
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the design of the safety-related air filters at Calvert Cliffs and conclude that the access to the charcoal test trays is not adjacent to the HEPA filters; therefore, removal and reinstallation of the charcoal test trays could not result in damage to the HEPA filters. Moreover, Generic i
Letter No. 83-13, issued by'the NRC on March 2,1983 concerning air filters system used in engineered safety feature atmospheric clean-up systems, no longer requires testing the HEPA filters due to reinsta11ation of charcoal test trays only. We conclude that the deletion of the requirement to test the HEPA filters following reinsta11ation of the charcoal test trays is consistent with the NRC position in this area and will not endanger the safety function of HEPA filters regarding post-accident removal of particulates.
The remaining tests for the HEPA filters, conducted at least every 18 months, are adequate to-assure proper filter efficiency.
Accordingly, the deletion of the requirement for HEPA filter. testing following reinstallation of the charcoal ~ test trays is acceptable.
The final issue addressed herein involves the changing of the word " system" to the words " filter train" in TS 4.6.6.1.c.2.a.
The phrase " filter train" is used to describe the specific assembly of roughing, HEPA and enr.rccal
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filters used in the penetration room exhaust air filtratina system which is the subject' of TS 4.6.6.1.
The Lse of the phrase " filter train" is more accurate than the'wcrd " system" when addressing these types of filters.
Therefcre, we conclude that the propcsed TS change, to substitute the phrase " filter train" for the word " system" in TS 4.6.6.lc.2.a. is an administrativa change in that it does r.ot impact the sm vaillance Or safety function of any equipment and is, therefore, acceptable i
l 3.
Revise Surveillance Requirements and Provision for Extended Outage of tfie Hydrogen Analyzers The Application for License Amendment dated February 24, 1983, as supple-mented by letter dated March 22, 1983 requested changes to TS 3/4.6.5.
" Hydrogen Analyzers".
The proposed changes would (1) change the surveillance requirements to reflect recent modifications to the system, and (2) provide for a single period of inoperability, from May 15 to July 15, 1983, during which time one hydrogen analyzer may be made inoperable for making modifi-cations.
The purpose of these modifications relates to the environmental-qualifications of the hydrogen analyzer solenoid valves.
BG&E has completed modifications to the Calvert Cliffs hydrogen analyzers to meet the requirements of TMI Acticn Item II.F.1.6, " Containment Hydrogen Monitor." One such modification resulted in the calibration sample gases, specified in TS 4.6.5.1 becoming inappropriate for this application. The calibration sample gases are currently required to be (1) zero volume percent hydrogen, the balance nitrogen, and (2) three volume percent hydrogen, the balance nitrogen, i
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BG&E has proposed that TS 4.6.5.1 be modified to delete the composition of the calibration sample gases and 'i.ndicate that the sample gas to be used will be "... in accordance with manufacturers' recommendations." The redesigned hydrogen analyzers can detect hydrogen within the containments in concentra-tions from 0 to 10 percent, by volume, in accordance with the requirements of NUREG-0737. Although the instrumentation is capable of selecting a range of 0 to 20 percent, this scale is not used.
BG&E has provided a written
" caution" in the operating procedure and at the panel against using the O to 20 percent scale.
The calibration sample gases used to calibrate the instrumentation in the 0 to 10 percent range are recommended by the equip-ment manufacturer as follows:
(1) gas' of 10 percent hydrogen (H ), and 2
(2) reagent gase of 59.97% pure oxygen (02) concentration.
The specift-cation of these calibration sample gases has been incorporated in the surveillance procedure for the hdyrogen analyzers, STP-M-3808-0.
Since the l
tank couplings used to connect the calibration sample gases to the hydrogen anclyzer are of a unique design not utilized elsewhere at Calvert Cliffs, only calit' ration gases recommended by the manufacturer can be utlized i
to calibrate the hydrogen analyzer. We conclude,- therefore, that the composition of hydrogen analyzer calibration sample gases can be deleten from TS 4.6.5.1 and the requirement that Lthe gases used be "...in accordance with aanufacturers' recomendations'"be inserted in TS 4.6.5.1.
This TS,
.as modifled, provides a high degree of assurance that the hydrogen analyzer-can be reliably calibrcted in the ra.nge of 0 to 10 percent in that the canfiguration.of tha sample gas tank couplings prevents the use of gases other than those recorerended by the manufacturer.
The other issue associated with the hydrogen analyzers involves a proposed TS change which would allow a single hydrogen analyzer to be inoperable for two months from May 15, 1983 to July 15, 1983 for the purpose of replacing the solenoid valves with environmentally qualified valves. On July 30, 1982 the NRC issued Amendment Nos. 74 and 55 to the Operating Licenses for Calvert Cliffs Units 1 and 2, respectively. These license amendments provided for a change to TS 3.6.5.1 to allow a single hydrogen analyzer to be inoperable for a period of two months in order to complete the modifications required by TMI Action Item II.F.1.6.
As indicated in our Safety Evaluation Report (SER) issued on July 30,1982, a single Hydrogen Analyzer is sufficient to perform post-LOCA hydrogen sampling for Calvert Cliffs Units 1 and 2.
The use of hydrogen " grab samples" provides a back-up capability for the hydrogen analyzer system. These and other safety issues associated with reactor operation for an extended period with a single Hydrogen Analyzer were previously addressed in our July 30, 1982 SER.
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Accordingly, since the issues associated with reactor operation with a single Hydrogen Analyzer have been previously addressed, and since there is reason-able assurance that the modifications can be completed by July 15,1983, the proposed change to TS 3.6.5.1 is appropriate and acceptable.
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4.
Deletion of the Limiting Safety System Setting (LSSS) and An Adminis-trative Change Associated with the Loss of Load Function of the-Reactor 1
Protection System l
By letter dated March 22, 1983, BG&E amended their February 24, 1983 applica-tion to request changes to the TS associated with the Loss of Load function of the RPS.
The first change to these TS is administrative in nature and involves a change in terminology. At the present time TS Tables 2.2-1, 3.3-1, 3.3-2, and 4.3-1 and associated Bases contain information on a " Loss of Turbine" function of the RPS. BG&E has requested that the term " Loss of Turbine" be replaced by the term " Loss of Load" in the above referenced TS.
The Calvert Cliffs RPSs are equipped with a trip function that senses a main turbine trip and causes a reactor trip via the RPS.
This device is described in the Calvert Cliffs FSAR Section 7.2.3.8 and is identified as the " loss of load trip".
The TS referenced above describe this trip function as a " Loss of Turbine" trip.
Changing the term " Loss of Turbine" to " Loss of Load" as it appears in the TS, would make the TS consistent with the terminology in the FSAR and the equipment "name plates" utilized at Calvert Cliffs.
Moreover, since the terminology has no effect on any safety function associated with the RPS, the change has no effect on plant safety. Accord-ingly, the change to the TS to replace the term " Loss of Turbine" with " Loss of Locd" is adeeptable.
-The March 22, 1983 amendment to the February 24, 1983 application also requested that the LSSS for the Loss of Load RPS trip be deleted from TS Table 2.2-1, " Reactor Protective Instrumentation Trip Setpoint Limits".
litle 10, CFR Part 50, Section 50.36(c)(1)(i)(A) provides the following definition for LSSS:
" Limiting safety system settings for nuclear reactors are settings for automatic protective devices related to those variables having significant safety functions."
The Bases for the LSSS states that, "No credit was taken in the accident I
analyses for operation of the Loss of Load trip." Moreover, unlike other RPS trip functions, the Loss of Load trip is generated in a non-safety grade system; in this case, the turbine control system.
Although the setpoints*
l for the Loss of Load trip function should be deleted from -TS Table 2.2-1, both limiting Conditions for Operation and Surveillance Requirements in the TS will continue to ~ assure that the Loss of Load RPS function will continue to The Unit 1 Loss of Load trip function actually lacks a true "setpoint" in that the trip is generated by the " master trip solenoid" and does not l
involve comparison of a measured process variable against a preset value.
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Accordingly, since the Loss of Load RPS function was not credited in.the accident analyses, deletion of the Loss
.of Load LSSS from Table 2.2-1 will not affect the consequence of any.
i-accident considered in the Safety Analyses; therefore, deletion of this-
- TS is acceptable.
Environmental Consideration We have determined that the, amendments do-not authorize a ch'ange in effluent types or total amounts nor an increase in power level" and will not result in any significant environmental' impact.
Having made this determination, we have further concluded that the amendments involve an action which is insignificarit from the standpoint of envir6nmental impact and, pursuant to /
declaration and environmental impact appraisal (t. statement or negative 10 (JR 851.5(d)(4), that an environmental impa need not_be prepared in connection with the issuance of these amendments.
Conclusion We have concluded. based on the considerations discussed above, that: (1) because the amendments do not involve a significant increase. in the e probability or consequrnces of an accident.previously evaluated, do not create the possibility of an accident of a type different from any -
evaluated previously, and do not involve a significant. reduction in a margin of safdty, the amendments do not involve a significant hazards consideration, (2) there is a reasonable assurance that the health and safety of the.public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the.
Commission's regulations and the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Date: May 5,1983 Principal Contributor:
D. H. Jaffe i
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