ML20137L944

Comment Opposing GL, Loss of Reactor Coolant Inventory & Associated Potential for Loss of Emergency Mitigation Functions While in Shutdown Condition

ML20137L944
Person / Time
Site:	Calvert Cliffs
Issue date:	03/18/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-62FR07075, FRN-62FR7075, RULE-PR-7 62FR7075-00007, 62FR7075-7, 62FR707500007, NUDOCS 9704070349
Download: ML20137L944 (2)

Text

, -o Cninus H. CRUSE ~gye Baltimore Gas and Elearic Company Vice President ' ' ' Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway gj Mn, 2y pt ') 2 l Lusby, Maryland 20657 pff 410 495-4455 RULLSi g yg (_2 f4' 7 p75' Feb /9; m7 Q AbmMc March 18,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Rules Review and Directives Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on Proposed Generic Letter: " Loss of Reactor Coolant Inventory and Associated Potential for Loss of Emergency Mitigation Functions While in a Shutdown Condition" The Baltimore Gas and Electric Company is pleased to provide comments on the proposed Generic Letter. We have reviewed and endorse comments submitted by the Nuclear Energy Institute.

This proposed generic letter would: (1) assess the susceptibility of their Emergency Core Cooling System to common-cause failure as a result of Reactor Coolant System drain-down while in a shutdown condition; and (2) submit certain information concerning their findings regarding potential pathways for inadvertent Reactor Coolant System drain-down, and the suitability of configuration control and operating practices during reactor shutdown cooling.

We feel that the proposed generic letter should not be issued. We feel BGE's existing design provides an adequate basis for assuring that the Emergency Core Cooling System is not subject to common-cause failure as a result of Reactor Coolant System drain-down while in a shutdown condition. The event described by the proposed generic letter does not represent a possibility for common mode failure at Calvert Cliffs. Baltimore Gas and Electric Company's design does not allow one shutdown cooling loop aligned to the Reactor Coolant system, with a second loop aligned to the refueling water storage tank.

Baltimore Gas and Electric Company's design also includes separate suction headers from the refueling water tank to the Emergency Core Cooling System pumps. Calvert Cliffs and similarly designed plants should not be subject to the proposed generic letter. We recommend the Nuclear Regulatory Commission further research the appropriate applicability of this concern prior to issuing a generic letter applicable to all nuclear power plants.

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Rul:s Revirw and Directivcs Br:.nch March 18,1997  ;

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{ i Should you have questions regarding this matter, we will be pleased to discuss them with you. l e

! Very truly yours, I l

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fix V CHC/SJR/bjd i cc: Document Control Desk, NRC H. J. Miller, NRC  :

D. A. Brune, Esquire Resident Inspector, NRC t J. E. Silberg, Esquire R.1. McLean, DNR Director, Project Directorate I-1, NRC J. H. Walter, PSC A. W. Dromerick, NRC P

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