ML20082K654

Application for Amend to Licenses DPR-53 & DPR-69 Consisting of Tech Spec Changes Revising Reactor Coolant Sys Overpressure Protection Surveillance Requirements to Delete Power Operated Relief Valves from Inservice Testing Program

ML20082K654
Person / Time
Site:	Calvert Cliffs
Issue date:	08/27/1991
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:
Shared Package
ML20082K656	List: ML20082K654 ML20082K663
References
NUDOCS 9108300163
Download: ML20082K654 (4)

Text

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B ALTIMORE GAS AND ELECTRIC CHARLES CENTER e P.O. BOX 1475

• BALTIMORE. MARYLAND 21203-1475 Gionot C CRtet v.cc P=c sme fiVC L t a m c ost m G v

( 400 a e> o-4 a e b August 27,1991 U. S. Nuclear Regulatory Commission Washington, DC 20555 NITENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50-318 License Amendment Rrquest: Inservice Testine Catecorv for PORVs

REFERENCES:

(a) Letter to hir. G. C. Creel (BG&E) from hir. R. A. Capra (NRC),

Second Ten Year Interval Insenice Testing Prograrn, dated September 20,1990 (b) Letter to NRC Document Control Desk from hir. G. C. Creel (BG&E), Requests for Relief from ash 1E Section XI Requirements, dated hiay 24,1991 Gentlemen:

The Baltimore Gas and Electric Company hereby requests an Amendment to its 0;. rating 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.

DESCRIPTION This request would revise the reactor coolant system overpressure protection surveillance requirements to delete the designation of the power operated relief valves as Category C for the ash!E Section XI Insenice Testing Program. Insenice testing of the valves will continue in accordance with the approved program, but the valves may not be tested under a Category C designation.

HACKGROUND The pressurizer power operated relief valves (PORVs) were designated as Category C in Surveillance Requirement 4.4.9.3.1.d and in the First Ten Year Interval Insenice Testing Program.

Ilowever, that program also included an approved relief request for the PORVs which delineated the '

specific testing to be done for the Category C designation since the PORVs are not of the ordi ry 9108300163 910827 d7 .d

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design for relief valves. A similar request was submitted for the Second Ten Year Intervalinsenice Testing Program, however, the request was denied in Reference (a). BG&E subsequently withdrew the relief request and committed to categorizing the PORVs as AShiE Section XI, Category B, cold shutdown exercised sah;cs and to performing the tests resulting from this categorization [see Reference (b)]. However, this re-categorization requires a revision to Surveillance Requirement 4.4.9.3.1.d.

JilLQ11ESTED CII ANGE Change Specification 4.4.9.3.1.d of the Unit 1 and Unit 2 Technical Specifications as shown on the marked-up pages attached to this transmittal. This change will delete the " Category C" designation of the power operated relief valves.

sal'INY ANAINSES!.IUSTil'1 CATION 10 CFR 50.55a (g), "Insenice Inspection-Requirements, contains the requirements for insenice testing of pumps and valves in accordance with ash 1E Boiler and Pressure Vessel Code Section XI.

It also requires that requests for relief from the Section XI testing requirements be approved by the NRC. Technical Specification 4.0.5 then requires that the Insenice Testing Program be implemented. Various other technical specifications also refer to Technical Specification 4.0.5, but only Specification 4.4.9.3.1 provides a specific valve category. Deletion of this valve categorization in Specification 4.4.9.3.1 does not revise any testing requirements since these valves must e(mtinue to be tested in accordance with AShtE Section XI or an NRC-approved relief request.

DETElt NilN ATION OF SIGNIFICANT ll A7AltI)S The proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determmed to not involve a significant hazards consideration, in that operation of the facility in accordance with the proposed amendment:

i (1) liould not imolve a significant increase in the probability or consequences of an accident previously evaluated.

Pressurizer power operated relief valves provide overpressure protection during low temperature operation. The change to the Technical S ? ccifications would delete the specific c . categorization for ash 1E Section XI testing listec in the surveillance requirements.

liowever, the valves would continue to be tested in accordance with an approved insenice testing program. Therefore, the change would not involve a significant increase in the probability or consequer

es of an accident previously evaluated.

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_ (2) .11'ould not create the possibility of ~ new or different type of accident from any accident 'I previously evaluated, ,

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t lhe- change would delete the ., '

Category C designation in the surveillance  !

requirements, but testing would con..aue to be conducted in accordance with previously i approved methods. The proposed will .not represent a change in the conf'guration or -  !

operation of the plant, Specifically, no new hardware is being added to the plant, no existing l equipment is being modified, nor are any significantly different 'ypes of operations being i' introduced. Therefore, the change would not create the possibility of a new or different type of accident from any accident previously evaluated. .

(3) il'ould not involve a significant reduction in a margin ofsafety. l The margin of safety is provided through the capability of the power operated relief valves to  :

provide overpressure protection during low temperature operation. This margin is maintained by continuing to test the valves in accordance with an approved program.

1herefore, the change would not involve a significant reduction in a margin of safety.

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-t SCllEDUIL _ j This change is requested to be approved and issued by November 20,1991. Ilowever, issuance of this amendment is not currently identified as having an impact on outage compl< rion or continued plant operation.

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Document Control Desk .

August 27,1991 i Page 4 -

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t SAFirlY COMMI'ITEE REVIEW  !

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 Off. Site Safety Review Committee, and they have concluded that implementation of these changes will not result in i an undue risk to the health and safety of the public.

Veg truly yours, ,

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STATE OF MARYLAND

TO WIT : l COUNTY OF CALVERT  : i I hereby certify that on the 27 day of / aqu SI ,193, before me, the subscriber, a Notary Public of the State of Maryland in "and for Chloerf Coun& ,  :

personally appeared George C. Crect, beine d iy sworn, rind states that he is Vice President of the i Baltimore Gas and Electric Company, e .orporation of the State of Magland; that he provides the foregoing information for the purpc es therein set forth; that the statements made are true and correct to the best of his knowledg.:, information, and belief; and that he was authorized to provide '

the information on behalf of said Corporation.

WITNESS my lland and Not::rialScal: Y)b 4Notary Public 7 I '

l I

2 a< Leu [ /

My Commission Expires:

Date'  ;

GCC/ ERG! erg /dlm t i

Attachment l

cc: D. A. Brune, Esquire J. E. Silberg, Esquire i R. A. Capra, NRC D. G. Mcdonald, Jr., NRC  !

T. T. Martin, NRC ,

L E. Nicholson, NRC "

R. I. McLean. DNR i J. H. Walter, PSC h e

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