ML20118B527

Application for Amends to Licenses DPR-53 & DPR-60,revising TS to Expand Acceptable Methods for Obtaining Samples from Charcoal Filters by Incorporating Method Described in C-E STS (NUREG-0212) & Reg Guide 1.52

ML20118B527
Person / Time
Site:	Calvert Cliffs
Issue date:	09/25/1992
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20118B528	List: ML20118B527 ML20118B529
References
RTR-NUREG-0212, RTR-NUREG-212, RTR-REGGD-01.052, RTR-REGGD-1.052 NUDOCS 9210050032
Download: ML20118B527 (4)

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BAtTIMORE GAS AND ELECTRIC 1650 CALVERT CLIFFS PARKWAY

• LUSBY, MARYLAND 20657-4702 Geonor C. CncrL St w oe, Vitt PRE 51DE NT tdi06 260-3690 September 25,1992 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk SUBJ EC1': Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 Request for Amendment: Charcoal Filter Testine Reouirements REFERENCE 5: (a) Letter from Mr. A. E. Lundvall, Jr. (BG&E) to Mr. R. A. Clark (NRC), dated February 24,1983, Request for Amendment (b) Regulatory Guide 1.52, Design, Testing, and Msintenance Criteria for Post Accident Engineered Safety Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, Revision 2, March 1978 -

(c) NUREG-0212, Standard Technical Specifications for Combustion Engiacering Pressurized Water Reactors, Revision 2, December 1981 (d) Letter from Mr. G. C. Creel (BG&E) to NRC Document Control Desk, dated August 30,1989, Request for Amendment (c) Letter from Mr. D. G. Mcdonald, Jr. (NRC) to Mr. G. C. Creel (BG&E), dated Aprii 27,1990, Issuance of Amendments m

Gentlemen:

1 i Baltimore Gas and Electric Company (BG&E) hereby requests an Amei. ament to its Operating l

License Nos. DPR-53 and DPR-60 for Calvert Cliffs Unit Nos. I and 2, respectively, with the submittal of the proposed changes to the Technical Specifications. The proposed amendment would expand the acceptable methods for sampling charcoal filter units.

l L DESCRIlrl'lON The proposed amendments would expand the acceptab!c methods for obtaining samples from charcoal filter units by incorporating the sampling method described in Standard Technical Specifications. This test methN was formerly in the Calvert Cliffs Technical Specifications, but was removed in 1983, 9210050032 920925 6h DR ADOCK 0500 7 ,[ qE 9 f

Document Control Desk September 25,1992 Page 2 11\CKGIU) UNI)

In 1983,13G&E requested a license amendment which would allow the use of sectioned test trays for charcoal filter testing (Reference a). The proposed change added the option of taking charcoal samples from sectioned test trays in addition to the existir.g method of taking charcoal samples from stendard adsorber trays. Taking charcoal samples from standard adsorber trays is the industry accepted method described in Regulatory Guide 1.52 (Reference b) and N UREG-0212 (Reference c). No changes were made in the chemical testing or test acceptance criteria for the charcoal samples. This change was approved as Amendments 83 (Unit 1) and 66 (Unit 2)

(Reference c). During discussions between the NRC and BG&E regarding this change, a decision was made to elimmate the option to obtain charcoal filter samples from standard adsorber trays as it was nelieved that method of testing would not be used. Therefore, the current Calvert Cliffs -

Technical Specilications allow charcoal samples to be taken from sectioned adsorber test trays only.

ILdtimore Gas and Electric Compny has had some difliculty obtaining sectioned test trays in recent years and proposes to restore the option to take charcoal samples from standard adsorber trays in accordance with NRC Reguiatory Positions.

l FOUES'l EI) CllANGli j

Revise the following Technical Specifications as shown in Attachments (1) and (2):

4.6.3.1.b.3 Iodine Removal System 4.63.1.c.1 lodine Remova! System 4 6 6 1.F.3 Penetration Room Exhaust Air Filtration System e 4.6.6.1.c.1 Penetration Room Exhaust Air Filtration System 4.7.6.1.t.i Control Room Emergency Ventilation System 4.7.6.1.d Contiol Room Emergency Ventilation System ,

4.7.7.1.b.3 ECCS Pump Room Exhauct Air Filtration System -

4.7.7.1.c ECCS Pump Room Exhaust Air Filtration System 4.9.12.b 3 Spent Fuel Pool Ventilation Systems 4.9.12.c Spent Fuel Pool Ventilat;on Systems S AFETY AN AIXSIS; JUSTIFICATION The proposed amendment does not change the testing method or test acceptance criteria for charcoal filter sample testing. The current test method was requested in Reference (d) in response to concerns raised in Information Notice 86-76, " Problems Noted in Control iloom Emergency Ventilation Systems." It was approved in Reference (e). This test method is the same as that wcommended in Regulatory Guide 1.52, Regulatory Position C.6.a.

The proposed sample collection method is described in NRC Regulatory Guide 1.52, Regulatory Position C.6.b. and in the Standard Technical Specifications, Reference (c). The format and content used in Standard Technical Specifications have been used as much as possible. Deviations frora the standard were necessary to accommodate the approved use of sectioned test trays and the use of the test methods approved in Reference (c).

Tir ,roposed rechnical specifications require that samples taken from adsorber trays or adsorber test trays be taken in accordance with Regulatory Guide 1.52, Reguir. tory Position C.6.b. This ReguL < 'y Position specifies the same collection methods as the current technical specifications, including sample mixing. sample size, and taking of successive samples.

. Docun.cnt Control Desk September 25,1992

- Page 3 L)f].EIGilNATION OF SIGNil>lCANT ILAZAlti)S The proposed change has been evaluated against the standard in 10 CFR 50.92 and has been i determined to not involve a significant hazards consideration, in that operation of the facility in j accordance with the proposed amendment:

1. Il'ould not involve a significant increase in the probability or consequences of an accident previously evaluated.

Charcoal filter units are used to remove radioactive iodine from air systems following an-acc . lent and are not a precursor to any accident previously evaluated. Changes to the test sample collection method would not affect any accident precursors and would not change the probability of any accident.

The proposed change would allow charcoal filter samples to be collected from standard adsorber trays. The testing performed on the charcoal samples to verify their effectiveness is tachanged. Charcoal filter sample collection from standard adsorber trays is an approved method of samp:e collection which will have no adverse effect on the accuracy of the charcoa'l filter testing. Therefore, the proposed change will have no adverse effect on charcoal filter performance following an accideat and their ability to mitigate the consequences of an accident.

Therefore, the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Would not create the posibility of a new or difference type of accident from any accidem

previously evaluated.

This proposed change to the charcoal sample collection method does not invo!ve a change in the design or operation of the plant. Therefore, this change would not create the possibility of a new or different ope of accident frm any accident previously evaluated.

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3. Would not involve a significant reduction in a margin ofsafety.

t The margin of safety provided by the charcoal filter units is the rated removal efficiency for L radioative iodine following an accident. The proposed changes do not alter the removal efficicney test acceptance criteria for charcoal filter samples. The proposed charcoal filter sample collection option is an approved method. The margin of safety provided by the charcoal filter units is unaffected. Therefore, this change would not involve a sign:ficant .

reduction in a margin of safety.

SCliEI)UI.E This change is requested to be approved by March 1,1993. Apnroval will allow use of the proposed sample collection method during the spring 1993 Unit 2 refueling outage. This change is not associated with any outage limiting activity.

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' Document Control Desk S'eptember 25,1992 Page 4 sal'lflY CONIN11'IT.* M_ljlTilSV The proposed change to the Technical Specifications and our determination of signiEcant hazards j 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 an undue risk to tbc health and safety of the public.

Should you have any questions on this request, we would be pleased to discuss them with you.

Very trul 'o rs, .

s STATE OF MARYLAND :

TO WIT :

COUNTY OF CALVERT  :

I hereby certify that on the A5" day of legt4ticd ,1992,>cfc me a Notary Public of the State of Maryland ih and for //>Att M, the subscriber, 4 ,

personally appeared George C. Creel, being duly sworn, and states that he is Senior Vied President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purpos:s 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 behalf of said Corporation.

MITNESS my lland and Notarial Seah A~1' d 27C y Notary Public U M v Comtnission Expires: *1% /> /97Y

(/ (JDaic

. GCC/BDM/bdm! dim Attachments cc: D. A. Brune, Esquire J. E. Silbergi Esquire R. A. Capra, NRC D. G. Mcdonald, J r., NRC T. T. Martin, NRC L E. Nicholson, NRC R. I. McLean, DNR J. It Walter, PSC

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