ML20082M475

Application for Amends to Licenses DPR-53 & DPR-69,changing Tech Spec Table 4.3-2 to Allow Safety Injection Sys Logic, That Starts Emergency Diesel Generators,To Be Moved to Different Subchannel of Safety Injection Sys

ML20082M475
Person / Time
Site:	Calvert Cliffs
Issue date:	08/30/1991
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082M477	List: ML20082M475 ML20082M481
References
NUDOCS 9109050222
Download: ML20082M475 (5)

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l B ALTIMORE GAS AND ELECTRIC/

CHARLES CENTER e P.O. BOX 1475

• BALTIMORE. MARYLAND 21203 1475 GroRoc C CRtcL C,7/UU[,

August 30,1991 o u,.e-m s U. S. Nuclear Regulatory Commission Washington, DC 20555 A*ITENTiON:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50 318 Request for Amendment

REFERENCES:

(a)

Letter from hir S. A. hicNeil (NRC) to hir. J. A. Tiernan (BG&E).

dated hiay 25,1988, Deletion of Containment Vent System Technical Specification Requirement 3/4.6.1.8 (b)

Letter from hir. G. C. Creel (BG&E) :o Document Control Desk (NRC), dated June 14,1991, Unit 2 Containment Vent System Operability, Technical Specification 3/4.6.1.8 (c)

Letter from hir. G. C. Creel (BG&E) to Document Control Desk (NRC), dated June 28,1991, Unit 1 Containment Vent System Operability; Technkal Specification 3/4.6.1.8 Gentlemen:

The Baltimore Gas and Electric t'ompany (BG&E) hereby requests an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos.1 and 2, respectively, with the submittal of the proposed changes to Technical Specifications Table 4.3-2. This request supercedes our request of August 27,1991 on this subject so as to include an additional, unrelated change that had instead been included with a letter revising the Technical Specification Bases. This change deletes Technical Specification 3/4.6.1.8, is strictly administrative in nature, and does not impact the conclusions of the no significant hazards determination contained in this request.

1)ESCitil"I'lON The 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 the actuation logic testing procedures. Baltimore Gas and Electric Company also requests reissuance of the appropriate pages of Amendment Nos.115 and 98 to its,Op' rating

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,q Document Control Desk August 30,1991

. Page 2 License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos. I and 2, respectively, to complete the implementation of changes to the Technical Specifications approved in those amendments.

IIACKGROUNI)

Technical Specification Surveillance Requirement 4.3.2.1,1 requires channel functional tests during the modes and at the freqvencies shown in Table 4.3 2. Item 1.d applies this testing requirement to the automatic actuation logie of 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 B) 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 Subchannel 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 simplification of the procedure could be accomplished by moving the EDG start signal to a subchannel which impacts less equipment.

1 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 EDG 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 requ,re 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.

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The present wording could be read to imply that additional approval or documentation is required to in.plement the stated exemptions. Finally, as requested in Reference (a), BG&E has notified the 1

Nuclear Regulatory Commission of completion of installation of a containment high radiation isolation signal on the containment vent line for both Units 1 and 2 (References c and b, respectively).

As indicated in Reference (a), deletion of Technical SpeciGcation 3/4.6.1.8,

" Containment Systems - Containment Vent System," was approved in Amendment Nos.115 and 98, and completion of implementation of the amendments was to include reissuance of the applicable Technical Specification page(s) following these notifications.

REOUESTEI) ClIANGES l

l Technical Specification 3/4.3.2.1, " Engineered Safety Feature Actuation System Instrumentation,"

l 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 test 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 SIAS 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 f

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Y Document Control Desk August 30,1991 Page 3 cxemptions are not conditional based on other circumstances or appiovals, as the words "may be" could be construed to imply.

Finally, Technical SpeciGcation 3/4.6.1.8,

• Containment Vent System," is requested to be deleted in its entirety.

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

SAFl?iY ANAINSIS!.1USTlFICATION 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 change is operationally transparent The EDG would continue to operate as described in the plant safety analyses (Chapter 14) of the Updated Final Safety Analysis Report, and would continue to receive the testing required to oemonstrate operability. Further, deletion of the containment vent system requirements was previnusly approved in Amendment Nos.115 and 98 as discussed above.

DETERMINATION OF SIGNIFICANT ll A ZARDS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would nat:

(i)

IVould not imolve a significant increase in the probability or consequences of an accident previously evaluated.

No change is being made to any accident initiators or mitigation features or assumptions. No relaxation of the testing is being sought. The Engineered Safety Features Actuation System (ESFAS) anci 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 logic to another. The change in the wording of Notes 3 - 6 is only administrative in nature, in that it simply clarifies the current, NRC-approved status of test exemptions for ESFAS logic circuits.

Deletion of the containment vent system requirements administratively fulfills a previously approved amendment.

(ii)

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

No significant change in plant equipment design is being implemented, and no new interactions of the affected equipment have been identified. The Engir. cered Safety Features Actuation System and the engineered safety features wiil 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 sat :ty injection actuation signal to another, and the deletion of the containment vent systeri requirements administratively fulfills a previously approved amendment.

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(iii)

IVould not irn'alve a significant reduction in a snargin of safety.

The proposed change is administrative in nature and serves only to assure continued compliance with the bases of the Technical Speci0 cations. Deletion of the containment vent sysicm requirements administratively fulfills a previously approved amendment. Therefore, this change does not lead to any reduction in the margin of safety.

SCllEDUI.E This design modification is currently scheduled to be implemented while performing maintenance on the EDGs beginning Jaruary 27,1992. The amendment is requested to be appioved by that date.

Ilowever, 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, j

- SAFF'lY COMMI'ITEE REVIEW These proposed changes to the Technical Speci0 cations and our determination of significant hazards have been reviewed by our Plant Operations Safety Review Committee and Off-Site Safety Review j

Committees, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.

Very truly yours

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STATE OF MARYLAND:

TO WIT:

COUNTYOFCAIXERT :

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I hereby certify that on the M day of O44ust

,191, before me, the subscriber, a Notary Public of the State of Maryland in and for Coluer* Coun+4 t

personally appeared George C. Creel, neing duly sworn, and states that he is-Vice' President of the i

Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the i

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 kehalf of said Corporation.

WITNESS my IIand and Notarial Scal:

Nu C/ I Notary Public i

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' My Commission Expires:

2tI4ucv2u M /NY bate l

GCC/ ERG /bjd

Attachment:

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Revised Technical Specification Pages

Document Control Desk August 30,1991 Page5 cc:

D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., N RC T. T. Martin, NRC L E. Nicholson, NRC R.1. McLean, DNR J. II. Walter, PSC

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