ML20082K715

Application for Amends to Licenses DPR-53 & DPR-69,revising TS to Allow SIAS That Starts EDG to Be Moved to Different Subchannel of SIAS

ML20082K715
Person / Time
Site:	Calvert Cliffs
Issue date:	08/27/1991
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082K717	List: ML20082K715 ML20082K786
References
NUDOCS 9108300188
Download: ML20082K715 (4)

Text

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i t 13 ALTIMORE GAS AND ELECTRIC CHARLES CENTER

• P O. BOX 1475 e DALTIMORE. MARYLAND 21203 1475 G t c,4 c t C C n t t L Vic( Pmg g @g est NVCitah reet#GT onn,.o ....

August 27,1991 U. S. Nuclear Regulatory Commission Washington, DC 20$55 A1TENTION: Document Control Desk SU11 JECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50 317 & 50 318 Reauest for Amendment Gentlemen:

The 13altimore 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.

DESCRIPTION ne proposed amendment would revise the Technical Specifications for both Units 1 and 2 to allow the Safety injection Actuation Signal (SIAS) logic that starts the Emergency Diesel Generators (EDGs) to be moved to a different subchannel of the SIAS. This request is administrative in nature since no relaxation from the current requirements is being sought. The change would allow improvements in tne actuation logie testing procedures, il4CKGROUND Tc6niel Specification Surveillance Requirement 4.3.2.1.1 requires channel functional tests during the modes and at the frequencies shown in Table 4.3 2. Item 1.d applies this testing requirement to ti.e automatic actuation logic cf the SIAS. A SIAS actuates more than 90 pieces of equipment. To provide control of the actuation of this equipment and to facilitate testing, each of the two divisional logic channels (A and 13) is divided into ten subchannels (1 10) in the Calvert Cliffs design, which -

are independently tested on a monthly basis. The equipment assigned to each subchannel is identified in the Updated Final Safety Analysis Report, Section 7.3.2.2. The EDG start signal is assigned to Sutchannel No. 9 along with several isolation valves, vent valves, sample valves and the containment purge fans. Each of these pieces of equipment must be verified to actuate correctly each time the SIAS signal is used to verify operability of the EDGs. This significantly increases the complexity of the procedure and the resources required to monitor the test. Considerable 0

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Document Control Desk August 27,1991 Page 2 simplification of the procedure could be accomplished by moving the liDG start signal to a subchr nnel u hich impacts less equipment.

Subchannel No.10 currently contains only four Safety injection Tank (SIT) isolation valves and has been selected as an appropriate channel for assignment of the EDO start signal. Ilowever, this channel is currently exempted from channel functional testing on a 31-day frequency, and are required instead to be tested on an 18. month frequency during shutdown. Since this exemption does not apply to the EDGs, moving the EDGs to Subchannel No.10 will require a change to the techmcal specifications to assure appropriate channel functional testing is required.

Additionally, a potential for misinterpretation of Table 4.3 2, Notes (3) - (6), has been identified.

De present wording could be read to imply that additional approval or documentation is required to implement the stated exemptions.

HEOUliSTED Cll ANGE Technical Specification 3/4.3.2.1, Engineered Safety Feature Actuation System Instrumentation,"

Table 4.3-2, Note 3, is requested to be changed to delete its application to Subchannels A 10 and B.10. Also, a new Note 2 will be added to the table for the monthly channel functional tett of the SIAS automatic actuation logic. The new note will read:

(2) SIAS logic circuits A-10 and B 10 shall be tested monthly with the exception of the SIT isolation valves. The SI AS logic circuits for these valves are exempted from testing during operation; however, these logic circuits are tested at least once per 18 months during shutdown.

Additionally, a minor wording change is requested for Notes (3) . (6) which replaces "may be" with "are" on a consistent basis to clarify the approved status of these exemptions. That is, the test exemptions are not conditional based on other circumstances or approvals, as the words "may be" could be construed to imply.

Marked up pages of the current Technical Specifications are attached to show the requested revisions. No revisions to the associated Bases are necessary.

SAFiflY ANAINSIS!]tiSTil1 CATION

! The change is essentially administrative in nature. While a design change is being made to move the EDG safety injection actuation signal logic from one subchannel to another within each division, the L change is operationally transparent. The EDO would continue to operate as described in the plant

! safety analyses (Chapter 14) of the Updated Final Safety Analysis lleport, and would continue to receive the testing required to demonstrate operability.

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I Document Control Desk l August 27,1991 Page3 j t

t DINEltMINATION Ol' SIGNil'ICANT II A7Alti)!i This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been  !

determmed to involve no significant hazards considerations, in that operation of tbc facility in i accordance with the proposed amendment would not:

j (i) IVould not imohe a significant increase in the pmbability or consequusces of an accident i previously evaluated. '

No change is being made to any accident initiators or mitigation features or assumptions. No rehnation of the testing is being sought. The Engineered Safety Features Actuation System (ESFAS) and the engineered safety features will continue to operate as described in the safety analysis. This change is administrative in that it only moves a design feature frorn one acce, tab!c subchannel of the safety injection actuation logie to another. The change in the worc ing of Notes 3 - 6 is only administrative in nature, in that it simply clarifies the current, NRC approved status of test exemptions for ESFAS logie circuits.

(ii) li'ould not create the possibility of a new or different type of accident from any accident proiously evaluated.

No signincant change in plant equipment design is being implemented, and no new interactions of the affected equipment have been identified. The Engineered Safety Features Actuation System and the engineered safety features will continue to operate as described in the safety analysis. This change is administrative in that it only moves a design feature from one acceptable subchannel of the safety injection actuation signal to another.

(iii) IVould not involve a sipajicant reduction in a mart;in of safety.

The proposed change is administrative in nature and serves only to assure continued comp iance with the bases of the Technical Specifications. Therefore, this change does not lead to any reduction in the margin of safety, SCIIEI)UI.E This design modification is currently scheduled to be implemented while performing maintenance on the EDGs beginning October 28,1991. The amendment is requested to be approved by that date.

llowescr. the work could be performed during later maintenance or during the Unit I refueling outage scheduled for the spring of 1992. The amendment is therefore requested to become effective upon implementation of the design modification.

Document Control Desk August 27,1991 Page 4 SAFi?lYC051N111 TEE HIEJEW These proposed changes to the Technical Specifications and our determination of significant har.ards ,

have been reviewed by our Plant Operations Safety Resiew Committee and Off-Site Safety Review Committees, and they have concluded that implernenta'(on of these changes will not result in an undue risk to the health and safety of the public.

Very truly yours, ,

4f STATE Ol' MAlWIAND:

TO WIT:

COUN'lY Ol' CALVERT :

I hereby ecrtify that on the 2[ day of her<ff ,19 W a Notary Public of the State of Maryliind in dnd for . Ch /vc2, before Counkme, the subscriber, personally appeared George C. Cicel, being duly sworn, and states that he is Vicd Picsident of the 13altimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the 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 l'c was authorized to provide the response on behalf of said Corporation.

WITNESS mylland and NotarialScal: [2If<1(([ Notary Public My Commission Expires: b MM4/ Date c1/Nh GCC/ ERG /dtm/bjd Attachments: (1) Revised Technical Specification Page 3/4 3-22 (Units 1 and 2)

(2) Revised Technical Specification Page 3/4 3 24 (Units 1 and 2) cc: D. A.13 rune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC L E. Nicholson, NRC R.1. McLean, DNR J.11. Walter, PSC

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