ML20125A582

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Safety Evaluation Supporting Amends 103 & 85 to Licenses DPR-53 & DPR-69,respectively
ML20125A582
Person / Time
Site: Calvert Cliffs  
Issue date: 05/16/1985
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20125A568 List:
References
NUDOCS 8506110120
Download: ML20125A582 (4)


Text

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WASHINGTON, D. C. 20555 g.o..f SAFETY EVALUATIOP BY THE OFr!CE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.103 AND 85 TO FACILITY OPERATING LICENSE N05. DPR-53 AND DPR-69 BALTIM0RE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 1

DOCKET NOS. 50-317 AND 50-318 Introduction By applications for license amendments dated September 20, 1984 and January 31, 1985, Baltimore Gas and Electric Company (BG&E) requested changes to the Tech-nical Specifications for Calvert Cliffs Units 1 and 2.

The proposed amendments would change the. Unit 1 and Unit 2 Technical Specifications (TS) to reflect:

(1) changes to surveillance requirements for safety-related hydraulic sway arrestors (snubbers) for Unit 1 only, (2) clarification of the degree of independence associated with the emergency core cooling system (ECCS) and shutdown cooling system, (3) deletion of a reactor vessel pressurization curve that is no longer needed for Unit 2 only, (4) a change to the containment isolation valve identi-fication numbers, (5) incorporation of the containment water level monitor in-ciuding operability and surveillance requirements, and (6) installation of a new meteorological monitoring system.

Discussion and Evaluation The first TS change. topic relates to the safety related hydraulic sway arrestors

' (snubbers) addressed in TS 3/4.7.8.1, " Snubbers". On April 19, 1984, the NRC issued Amendments 92 and 73.for Calvert Cliffs Units 1 and 2 which included a change to TS 3/4.7.8.1.

This change allowed BG&E to replace snubbers with rigid supports (sway struts). During the Unit 1 Cycle 8 refueling outage, BG&E will replace a number of snubbers with sway struts as pernitted by TS 3/4.7.8.1 i

and has proposed deletion of these snubbers from the TS.

In addition, the licensee has requested a change to TS 3/4.7.8.1 to allow removal of three snubbers (1-1-12, 1-60-5, and 1-60-5A) without' installing sway struts.

In both cases where the licensee has proposed removal of snubbers (with and without installation of a sway strut) stress calculations have been performed to demonstrate'that no appreciable increase in seismic induced stress will occur in associated piping or equipment.

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Mb A second change associated with Unit 1 TS 3/4.7.8.1 involves the deletion of common-reservoirs notations from those designated snubbers in Unit 1 TS Table 3.7-4 These sixteen snubbers, associated with the Steam Generators, will be mcdified such that each snubber will have its own reservoir. The reservoirs, together with all associated fittings, will be designed, manufactured, mounted and maintained to the same scismic standards as the snubbers which they serve.

Removal of these common reservoirs and replacement with individual units improves the seismic design in that it eliminates the po::sibility that a single reservoir failure would result in eight snubbers being inor.erable. Since these 16 snubbers are the only' snubbers served by common reservoirs, the surveillance requirements for these common reservoirs specified in TS 4.7.8.lf have been pro-posed for deletion. This proposed TS change was previously approved for the Unit 2 TS in License Amendment No. 73 which was issued on April 19, 1984.

The proposed changes in the snubbers addressed above and their associated TS assure an equivalent degree of seismic resistance. Accordingly, the proposed changes to TS 3/4.7.8.1 are acceptable.

The licensee has proposed changes to TS Basis 3.5.?, "ECCS Subsystems - T more than or equal to 300*F" and TS 3.9.8.2, " Shutdown Cooling and Coolan&V8ir-culation." Each of these TS requires that two " independent" subsystems (loops) of the respective systems be operable. The licensee has proposed deletion of the term " independent" as it applies to shutdown ecoling and ECCS in TS-Basis 3.5.2 and TS 3.9.8.2, respectively.

The term " independent", when applied to systen design, means that components have been arranged in subsystems which can function without interdependence.

While both the ECCS and shutdown cooling systems contain major components which are arranged independently, both systems share common piping within the respective system and thus neither system is truly " independent." Deleting the word "in-dependent" from TS Basis 3.5.2 and TS 3.9.8.2 does not change the requirements of the TS. Both TS would still require that two subsystems (loops), at a minimum, be operable for each system. The term " independent" as used in TS Basis 3.5.2 and TS 3.9.8.2 was used descriptively and, in these cases, incorrectly.

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The two proposed changes are simply clarifications of Technical Specifications which more closely ref. lect actual plant design.

The TS are not being altered except to provide this clarification. Accordingly, the proposed changes to TS Basis 3.5.2 and TS 3.9.8.2 are acceptable.

The licensee has proposed deletion of TS Figure 3.4-2a, " Reactor Coolant System Prese,ure Temperature Limitations for 0 to 2 years of Full Power Operation." At 2

the present time, TS Figure 3.4-2b, " Reactor Coolant System Pressure Temperature Limitations for 2 to 10 Years" provides the applicable limitations. Since Unit 2 has been in commercial operation for approximately 7 years and has surpassed the two " effective full power years" point of reactor embrittlement, TS Figure 3.4-2a is no longer needed.

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.' Deletion of TS Figure 3.4-Za in no way changes the applicable TS, prevents an error by removing information which is no longer applicable, and is thus accep-table.

The licensee'has proposed a change to TS Table 3.6-1, " Containment Isolation Valves." This table lists all containment isolation valves which are subject to operability and surveillance requirements.

The licensee has proposed a change in the valve numbering system in TS Table 3.6-1 to achieve consistency with the operational piping and instrument diagrams (P&ID) and procedures used to perform the required surveillance on containment isolation valves.

The licensee has been involved in an effort to revise, upgrade, and standardize P& ids. Associated with this effort they have performed a walkdown of all affected systems to verify the accuracy of affected drawings. TS Table 3.6.1 as presently written lists the valve designations used on construction P& ids. The proposed change would modify this table to reflect the numbers used on operational P& ids.

This would result in less chance of error while performing critical valve line-ups by making Table 3.6.1 consistent with operational procedures and P& ids.

The requested change is an administrative change and in no way changes existing operability or surveillance requirements in the TS and this is acceptable.

The licensee has proposed the addition of containment water level monitor in-strumentation to the operability and surveillance-requirements of TS 3/4,3.3.6, "Postaccident Instrumentation."

On November 1, 1983, the NRC issued Generic Letter No. 83-37 (GL 83-37) to all pressurized water reactor licensees. This letter contained gJidance Concerning TS which the NRC believed to be appropriate as addressed in NUREG-0737, "Clari-fication of TMI Action Plan Requirements". The licensee responded, in part, to GL 83-37 via their applications for license amendments dated January 31, 1985.

The licensee has proposed that existing TS Table 3.3-6, " Radiation Monitoring Instrumentation," and TS Table 4.3-3, " Radiation Monitoring Instrumentation Surveillance Requirements" would be modified to include Limiting Conditions for Operation (LCOs) and Surveillance Requirements for the containment water level monitor.

The proposed TS would increase the likelihood that the associated equipment will undergo appropriate surveillance and be available to assist in postaccident assessment and is therefore acceptable.

The licensee has proposed a change to TS 3/4.3.3.4, " Meteorological. Instrumenta-tion" to reflect installation of a new meteorological monitoring system at Calvert Cliffs.

The new system corrects a number of problems associated with the old system and substantially conforms to NRC guidance for meteorological monitoring systems.

The proposed revised TS provide requirements for surveil-lance and operability that are at least equivalent to those required for the old system.

Postaccident monitoring of meteorological conditions can be, therefore, expected to improve as a result of operability of the new system.

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' In acdition, the licensee has proposed to delete the operability and surveil-larce requirements for the previously required meteorological monitoring system.

The new meteorological system does not impact plant safety systems and the new system is at least equivalent to the previously approved system, therefore, the proposed change to TS 3/4.3.3.4 is acceptable.

EWIRONMEf!TAL CONSIDERATI0f1 TFese amendments involve a change in the installation or use of a facility corponent located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements.

The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released off-site, and that there is no significant increase in individual or cumulative cccupational radiation exposure. The Commission has previously published a proposed finding that these amendments involve no significant hazards consid-eration and there has been no public comment on such finding. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 651.22(c)(9).

Pursuantto10CFR951.22(b),noenvironmental irpact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

i CO ;CLUSI0tl lle have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be er. dangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission'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 16, 1985 Principal Contributor:

D. H. Jaffe