ML20138E132
| ML20138E132 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/04/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20138E129 | List: |
| References | |
| NUDOCS 8512130350 | |
| Download: ML20138E132 (4) | |
Text
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION 5
E WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED AMENDMENT NOS.108 AND 91 TO FACILITY OPERATING LICENSE NOS. DPR-53 AND DPR-69 BALTIM0RE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318 Introduction By application for license amendment dated June 28, 1985, Baltimore Gas and Electric Company (BG&E) requested changes to the Technical Specifications (TS) for Calvert Cliffs Units 1 and 2.
The proposed amendments would change the Unit 1 and Unit 2 TS to:
(1)reflecta clarification of requirements associated with the containment purge isolation valves in TS Table 3.3-3, " Engineered Safety Features Actuation System Instru-mentation," and TS Table 3.6-1, " Containment Isolation Valves," (2) modify TS 3.9.4, " Containment Penetration," to allow the use of an alternate closure for the emergency personnel escape lock, (3) delete TS 6.13, " Environmental Qualifi-cations," and (4) correct identified spelling errors and changes in terminology.
Additional changes to the TS that were requested in the June 28, 1985 applica-j-
tion will be addressed in subsequent correspondence.
Discussion and Evaluation 3
BG&E has requested a change to TS Tables 3.3-3 and 3.6-1 to correct an inconsis-tency between operability requirements for the containment purge isolation valves and related requirements.
The containment purge isolation valves allow outside air to enter the contain-ment and vent the containment atmosphere to the environment. At the present time, these valves are required to be isolated by the requirements of TS 3.6.1.7,
" Containment Purge System " to prevent these valves from being opened, during Modes 1 through 4 (power operation through hot shutdown). Furthermore, the purge isolation valves are required to be operable, meaning capable of auto-matic closure to a leak-tight condition, by the requirements of TS 3.9.9. " Con-tainment Purge Valve Isolation System," during core alterations or movement of irradiated fuel inside the containment (during Mode 6). A comparison of the requirements of TS 3.6.1.7 and TS 3.9.9 indicates that the containment purge isolation valves may be inoperable (open) in Modes 5 (cold shutdown) or in Mode 6 (refueling) when neither core alterations nor movement of irradiated i
e 851213o350 851204 ADOCK0500g7 DR
, fuel inside containment is underway or any time in Mode 6 when t $ contain-ment purge valves are closed. Conditions under which the containment isola-tion valves may be inoperable are consistent with conditions under which containment (leak-tight) integrity is not required per TS 3.6.1.1 and TS 3.9.4 BG&E has identified two inconsistencies regarding requirements associated with the containment purge isolation valves. The first instance of incon-sistency involves TS Table 3.6-1.
In this case, the TS requires that the valve isolation response time for the containment purge isolation valves be applicable "... for Mode 5 and 6 during which time these valves may be opened." Since isolation response times should not be applicable when the valves are not required to be operable, BG&E has proposed to reword the applicability of the response time to be "... in Mode 6 when the valves are required to be operable and they are open." This proposed applicability wording is consistent with operability requirements of the containment purge isolation valves.
The second instance of inconsistency involves TS Table 3.3-3 which specifies operability requirements for devices for manual and automatic closure of the containment purge isolation valves. At the present time, the purge valve control switches for manual closure must be operable in Modes 5 and 6 and containment radiation-high area monitor (for automatic closure) must be operable in Mode 6.
The licensee has proposed changing the operability requirements for these closure devices to "... in Mode 6 when the valves are required operable and they are open" which is consistent with the operability requirements for the containment purge isolation valves.
The proposed changes to TS Tables 3.6-1 and 3.3-3 would be consistent with analyses for which closure of the containment purge isolation valves is assumed. Operability of automatic and manual valve closure devices and closure response times would be applicable at all times when the containment purge isolation valves are required to be operable (these requirements only apply to the containment purge isolation valves). Accordingly, the proposed changes to TS Tables 3.3-3 and 3.6-1 are acceptable.
The licensee has proposed a change to TS 3.9.4b which would provide a footnote to allow use of a temporary closure for the containment emergency personnel escape lock during refueling activities. At the present time, TS 3.9.4 requires at least one door in each air lock to be closed during core alterations or movement of irradiated fuel inside the containment.
The personnel escape lock described in Section 5.1.2.1 of the Calvert Cliffs Final Safety Analysis Report (FSAR) is located at elevation 49'4" and is pro-vided with outer and inner doors. During refueling operations, the licensee proposes to replace the inner personnel escape lock door with a temporary closure; the outer door would remain open at this time. This temporary closure would contain several penetrations to facilitate work inside containment, during core alterations or movement of irradiated fuel, when containment integrity is required. The licensee has indicated that the temporary closure and its
. use during reactor Mode 6 (refueling)gn requirements of the pemenent door penetrations meet the applicable desi Installation and leak testing of the temporary closure would be controlled by a plant procedure.
The Bases for TS 3/4.9.4 states the following with regard to containment closures such as the personnel escape lock during refueling: "The OPERABILITY and closure restrictions are sufficient to restrict radioactive material release from a fuel element rupture based upon the lack of containment pressurization potential while in the REFUELING MODE." Since no containment pressurization results from the design basis (fuel handling) event during Mode 6, containment closures need only be vapor-tight rather than capable of withstanding excess pressure. Since the temporary closure is fabricated to standards equivalent to the personnel escape lock for Mode 6. utilization and installation and testing will be in accordance with plant procedures, the temporary closure can be expected to perfonn in a manner equivalent to that of the personnel escape lock door during the design basis event in Mode 6.
Moreover, since either a personnel escape lock door or the equivalent (temporary closure) will be in place during core alterations or movement of irradiated fuel inside contain-ment, current, approved, analysis concerning fuel handling accidents is still applicable. Accordingly, the proposed change to TS 3.9.4b., to allow use of a temporary closure device, is acceptable.
The licensee has proposed to delete TS 6.13, " Environmental Qualifications."
This TS provides schedule requirements for completion of activities relating to environmental qualification of electrical equipment important to safety that have already passed. Moreover, environmental qualification requirements, in-cluding schedules, are incorporated in 10 CFR 50.49, " Environmental qualifica-tion of electric equipment important to safety for nuclear power plants,"
and thus need not appear in the TS and, accordingly, TS 6.13 can be deleted.
Finally the licensee proposes to correct 14 spelling and one terminology error in the TS as detailed in the June 28, 1985 application. The correction of these spelling and terminology errors do not affect the associated TS requirements and is acceptable.
ENVIRONMENTAL CONSIDERATION These amendments involve a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
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 offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously published a proposed finding that these amendments involve no significant hazards consideration 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 951.22(c)(9).
These amendments also involve changes in recordkeeping, reporting, or administra-tive procedures or requirements. Accordingly, with respect to these items, the amendments meet the eligibility criteria for categorical exclusion set forth in10CFR51.22(c)(10).
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. Pursuant to 10 CFR 951.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.
CONCLUSION We 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 endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission'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:
December 4,1985 Principal Contributor:
D. H. Jaffe
.