ML20138Q168
| ML20138Q168 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/09/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20138Q143 | List: |
| References | |
| NUDOCS 8512270077 | |
| Download: ML20138Q168 (6) | |
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UNITED STATES i
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NUCLEAR REGULATORY COMMISSION n
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WASHINGTON. D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.109 AND 92 TO FACILITY OPERATING LICENSE NOS. DPR-53 AND DPR-69 BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318 I
Introduction s
By application for license amendment dated April 26, 1985 as supplemented by letter dated September 30, 1985, Baltimore Gas & Electric Company (BG&E/ licensee) requested changes to the Technical Specifications (TS) for Calvert Cliffs
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~ Units 1 and 2.
The proposed TS changes would:
(1) reflect a clarification of surveillance requirements of TS 4.6.1.6.2, " Containment Structural Integrity",
concerning containment tendon end anchorages and adjacent concrete surfaces and a change to TS 4.6.1.6.3, " Liner Plate"; (2) reflect an increase in the required diesel generator test load specified in TS 4.8.1.1.2.c.2, "A.C. Sources"; (3) delete TS 3/4 3.3.8, " Radioactive Gaseous Effluent Monitoring Instrumentation" and incorporate these requirements in TS Tables 3.3-6 and 4.3-3, " Radiation Monitoring Instrumentation"; (4) provide simplification, additions and clarifications concerning the fire protection I
instrumentation in TS Table 3.3-11. " Fire Detection Instruments"; (5) revise limiting conditions and surveillance requirements for the hydro TS 3/4.6.5, " Combustible Gas Control-Hydrogen Analyzers"; and (gen analyzers n
- 6) revise limiting conditions and surveillance requirements for the auxiliary feedwater system (TS3/4.7.1.2).
Additional TS changes requested in the April 26, 1985 application will be addressed as part of a future ifcense amendment.
Discussion and Evaluation The licensee has requested a change to TS 4.6.1.6.2 in order to provide clarification regarding inspection of containment tandon end anchorages and ii adjacent concrete surfaces. The wording of TS 4.6.1.6.2 would seem to indicate that all end anchorages and adjacent concrete surfaces should be visually inspected. The licensee's requested change would provide for a visual inspection of a random sample of end anchorages and adjacent concrete surfaces during tendon testing consistent with the sample of tendons selected
,3 for surveillance, and a sample of tendon-adjacent concrete surfaces during the containment integrated leak rate test (ILRT).
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As indicated in the TS Bases for TS 4.6.1.6.2, the inspection of the containment post-tensioning system (tendon, anchors, and related equipment and structures) is based upon Regulatory Guide (RG) 1.35, " Inservice Surveillance of Ungrouted Tendons in Prestressed Concrete Structures "
i January 1976 A review of Section C.3 of RG 1.35 clearly indicates, that a l
random sample of tendon end anchorages and adjacent concrete surfaces (corresponding to the random selection of tendons to be tested) should be selected for visual inspection during tendon testing. Thus, the proposed TS change for selection of tendon end anchorages and adjacent concrete surfaces, during tendon testing, is consistent with the provisions of RG 1.35 and is acceptable.
Finally, with regard to observation of concrete surfaces during the containment ILRT test. TS 4.6.1.6.2 requires observation of crack patterns in concrete adjacent to the end anchorages. The licensee proposes.to continue the use of a program developed in cooperation with the Architect / Engineer for Calvert Cliffs, Bechtel Power Corporation. as described in BG&E's letter dated June 19, 1985. The program involves the observation of 11 preselected
>4 areas for each containment during the ILRT test; each area is 50 to 100 square feet in size. A total of over 50, representative, end anchorages per containment are thus observed. This program has been used at Calvert Cliffs
- to.date. While the RG 1.35 program would incorporate a smaller, random, observation of concrete surfaces (approximately a 11 sample of all tendon-adjacent surfaces), the Calvert Cliffs program involves a larger, fixed, tendon sample (approximately 65 of all tendon-adjacent surfaces per i
j Calvert Cliffs containment). Although the random system of observation might tj eventually result in a greater range of observed concrete locations, the Calvert Cliffs program incorporates a sufficiently diverse sample to be representative of overall containment concrete conditions.
Based upon the above, the licensee's proposed changes to TS 4.6.1.6.2 and associated Ba:es, to establish the use of random inspection of tendon end.
anchorages and adjacent concrete surfaces and the observation of preselected
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areas durin the ILRT tests, is in accordance with RG 1.35, January 1976, and is acceptab e.
The licensee has proposed a change to TS 4.6.1.6.3, " Liner Plate". At the present time. TS 4.6.1.6.3 requir:s periodic visual inspection of the containment liner plate te detect any signs of abnormal degradation. The licensee has proposed to extend this visual inspection to also include
"... the exposed accessible interior and exterior surfaces of the j !
containment...."
This proposed change would improve the visual inspection of the containment and thus incmase the likelihood that possible degradation in containment components to other than the liner plate would be i
detected. In addition, the licensee has proposed a change in the. title of TS 4.6.1.6.3 to " Containment Surfaces" to more clearly reflect the nature of the I
proposed revised visual inspection. Based upon the above, we conclude that
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the proposed change to TS 4.6.1.6.3 is acceptable.
The licensee has requested a change to TS 4.8.1.1.2c.2 to increase the diesel 9enerator load rejection test load from 450 to 500 hp. The purpose of the
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' oad rejection test is to assure tnat the diesel generator will not trip, due to load rejection, in the event that the electrical load with the highest l
horsepower rating should trip.
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!.The existing test load specified in TS. 4.8.1.1.2c.2 is 450 hp. Since completion of modifications to the auxiliary feedwater system which added one motor operated pump per unit, the new maximum load is 500 hp. Accordingly, the test load specified in TS 4.8.1.1.2c.2 should be increased to 500 hp to assum that the load rejection test is conducted with the limiting-(largest) electrical load.
The proposed change would increase the size of the load that must be periodically rejected by the diesel generator by about 10%. This would provide greater assurance of the generator's capability to respond to the loss of the single largest load and is thus acceptable.
The licensee has proposed to delete TS 3/4.3.3.8 which contains limiting y
conditions for operation and surveillance requirements for radioactive gaseous effluent monitoring instrumentation. The licensee has further proposed that the requirements of TS 3/4.3.3.8 be incorporated in TS Tables 3.3-6 and 4.3-3 where requirements for similar instrumentation are located. The licensee's proposal to relocate the requirements of TS 3/4.3.3.8 is appropriate since locating requirements for similar instrumentation in comon areas within the.
TS will facilitate conpliance and is therefore acceptable.
The licensee has proposed charges to the fire detection instrumentation descriptions contained in TS Table 3.3-11.
These instruments are required to be operable and to undergo surveillance in accordance with TS 3/4 3.3.7
" Fire Detection Instrumentation". The proposed changes are of several types as follows:
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One heat detector was replaced with a smoke detector and three more smoke detectors were added as a result of structural modifications to the 69' level access centrol area. The area includes a laboratory where a smoke detector would be more suitable for fire detection.
Several dup 1'icate entries occur in TS Table 3.3-11.
Both the North South Corridor Room 410 and North South Corridor Room 308 were listed twice. The number of fire detectors in these areas has not been reduced, only the duplicate listings should be eliminated.
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Additional clarification has been proposed as follows: The room numbers and room names should be changed to reflect their proper names. The Intake Structure has been listed as a comon structure. Although the Intake Structure is a single room, the equipment in each side is dedicated to its respective unit. To provide clarification, the fire detection instrumentation serving the Unit I side of Intake Structure should be exclusively listed in the Unit 1 Technical Specification and similarly for Unit 2.
The last clarification concerns the Protecto Wire Instrumentation. The existing entries'in TS Table 3.3-11 list this instrument location as the Southwest and Northeast Containment Electrical Penetration Rooms.
Actually, the instrument meters are located in these rooms, but the j
Protecto Wires monitor cable trays rather than the rooms themselves.
,t The Protecto Wires are also not conventional heat detectors.
If a fire r
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becurs in the cable tray, the insulation between the wires melt and the wires short-circuit. The new electrical resistance corresponds to a wire length which can then be used to detemine the location of the fire. A footnote is proposed for TS Table 3.3-11 to clarify the special nature
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of these detectors.
As noted above, the modification to the fire detection instrument deployment strategy on the 69' level access control area provides a superior degree of fire detection capability. The remaining proposed changes to TS Table 3.3-11 do not in any way impact existing fire detection capability. Thus, we conclude that the overall ability to detect and suppress fires has not been t
decreased; therefore the proposed changes are acceptable.
The licensee has proposed changes to TS 3/4.6.5 in response to NRC's Generic Letter (GL) 83-37, "NUREG-0737 Technical Specifications", dated November 1, 1983 regarding hydrogen monitors. The hydrogen monitors are required to o
detemine post-LOCA, containment, hydrogen concentrations.
The purpose of GL 83-37 was to provide model TS associated with system / procedural improvements deemed necessary following the accident at Three Mile Island, Unit 2 (TMI-2). The proposed TS change clarifies the Limiting Condition for Operation (LCO) by providing an appropriate remedial
. action when two hydrogen monitors become inoperable. Although the LCO requires I-two~ hydrogen monitors to be operable, the required remedial action is only applicable when one hydrogen monitor is inoperable. The existing LCO allows a single hydrogen monitor to be inoperable for up to 30 days after which the reactor must be shut down within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The proposed LCO would require that, when both hydrogen monitors become inoperable, one monitor must be made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the reactor must be shut down within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Based upon our review, we conclude that the proposed remedial action, when two hydrogen monitors are inoperable, is consistent with the importance of the subject equipment and is thus, acceptable.
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i" The licensee has also proposed a change to the surveillance requirements for the hydrogen monitors. The proposed change would add a periodic test to the F
existing calibration requirements of TS 4.6.5.1.
The periodic test involves a biweekly demonstration of operability which is perfomed by drawing and analyzing gas from the waste decay tank. The additional proposed surveillance requirement provides a valid test of system operability at an appropriate frequency. Although the model TS also suggests a more frequent
" check" of instrument operability, this type of qualitative observation is meaningless since the hydrogen monitors are maintained in a de-powered state until required.
The proposed changes to TS 3/4.6.5.1 result in increased reliability of the hydrogen monitors in accordance with GL 83-37 and are acceptable..
t The licensee has proposed changes to the limiting conditions for operation i
and surveillance requirements for the Auxiliary Feedwater System (AFW) as l
specified in TS 3/4.7.1.2. At the present time, the Unit 1 TS 3.7.1.2a.i(b) would allow up to 14 days for a motor-driven AFW pump to be inoperable.
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'. addition, TS 3.7.1.2a.2.(b) allows up to 30 days for a steam-turbine-driven AFW pump to be inoperable. The licensee has proposed that tne maximum period of inoperability for either motor-driven or steam-turbine-driven AFW pumps be reduced to 7 days. This proposed change is consistent with the Unit 2 TS.
P The proposed change to Unit 1 TS 3.7.1.2 would improve the availability of the Unit 1 AFW pumps by substantially reducing the allowable out-of-service times and is acceptable.
i The licensee has also proposed a change to Unit 2 TS 3.7.1.2c which specifies remedial action to be taken when AFW components are inoperable for the purpose of testing. The wording of TS 3.7.1.2c would be changed to allow more than i
one AFW pump to be inoperable for the purpose of logic testing. For example, L
testing of the AFW automatic actuation system requires that two of three AFW pumps be momentarily made inoperable. This proposed change is consistent with the Unit 1 TS.
The proposed change to Unit 2 TS 3.7.1.2c would only insignificantly decrease.
the availability of the AFW system. Moreover, the axisting TS 3.7.1.2c requires a dedicated operator to be stationed at the AFW pumps (with direct comunication to the control room) to promptly restore full AFW capability in the event of an accident. The proposed change to TS 3.7.1.2c is therefore acceptable.
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.The licensee has proposed the following changes to the Unit I and Unit 2 TS 3/4.7.1.2:
Delete the note addressing Unit 1 Cycle 7. system inoperability. This t
note is no longer applicable.
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Correct the spelling of " standby" in a note in the Unit 2 TS. This change would correct a typographical error, t
Correct the spelling of " characteristics" in the Unit 1 TS. This change would correct a typographical error.
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Add the' word "and" to a Unit 1 surveillance requirement. This change would correct a clerical error.
f Add a close parenthesis to a Unit 2 surveillance requirement. This change would correct a clerical error.
These proposed changes are minor in nature and da not affect the AFW system or related analyses and are acceptable.
Environmental Consideration I
These amendments involve a change in the installation or use of a facility I,
component 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 i
change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational h
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. ' ' radiation exposure. The Commission has previously published a proposed finding that these amendments involve no significant hazards consideration and there i
has been no public comment on such finding. Accordingly, these amendments meet L
the eligibility criteria for categorical exclusion set forth in IQ_CFR 651.22(c)(9).
Pursuant to 10 CFR 951.22(b), no environmental impact statement or environmental
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assessment need be prepared in connecti.on with the issuance of thes.e amendments.
Conclusion F
l 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 9, 1985 Principal Contributor:
D. Jaffe I
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