ML20149E441

Provides Clarification on 870120 Request for Amends to Licenses DPR-53 & DPR-69 Re Change to Tech Specs Re Containment Purge Valves & Forwards Proposed Tech Specs

ML20149E441
Person / Time
Site:	Calvert Cliffs
Issue date:	01/12/1988
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20149E446	List: ML20149E441 ML20149E451
References
TAC-64603, TAC-64604, NUDOCS 8801130349
Download: ML20149E441 (3)

Text

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AD ALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475

• BALTIMORE. MARYLAND 21203 JOSEPH A.TIERN AN VICE PatSIDtNT January 12, 1988 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50-317 & $0-318 Modification to Amendment Request for Containment Purge Valves (TACs 64603 and 64604)

R EFERENCE: (a) Letter from Mr. J. A. T:n: :, (BGAE), to NRC Document Control Desk, dated January 20, 1987, Request f or Ar.1endment Gentlemen:

In Reference (a), we requested a change to the Unit I & 2 Technical Specifications for the containment purge isolation valves. This change will relocate the containment purge isolation valve requirements from Technical Specification 3/4 6.4 (Containment isolation Valves) to Technical Specification 3/4 9.4 (Containment Penetrations).

Technical Specification 3/4 9.9 (Containment Purge Valve isolation System) will be deleted and its associated requirements incorporated into Technical Specification 3/4 9.4. By rearranging the above Technical Specifications that address the containment purge system, inconsistencies and duplication will be eliminated.

In recent discussions, your staff expressed two concerns regarding the above change, llaving reviewed the requested change in light of these concerns, we feel that they can be addressed through clarification of Technical Specification 3/4 9.4. A discussion of the concerns and the agreed upon clarification is provided in Encicsure (1). Final copies of all pages associated with the requested change are provided in Enclosure (2).

Should you have any further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

($/ [AdlA-- - -

JAT/LSL/ dim Enclosures hP P

. bocument Control Desk January 12, 1988 Page 2 l

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cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A Capra, NRC S. A, McNeil. NRC W. A. Miller, NRC T. Foley/D. C. Trimble T. Magette i

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! . ENCLOSURE (1) -

A MENDM ENT REQUEST FOR CONTAINMENT PURGE VAI,VES l

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t In our letter dated January 20, 1987, Mr. J. A. Tiernan (BG&E) to NRC Document Control i Desk, we requested a change to the Unit ! & 2 Technical Specifications for the ,

containment purge isolation valves. This change will relocate the containment purge l isolation valve requirements from Technical Specification 3/4 6.4 (Containment i Isolation Valves) to Technical Specification 3/4 9.4 (Containment Penetrations).  !

Technical Specification 3/4 9.9 (Containment Purge Valve Isolation System) will be deleted and its associated requirements incorporated into Technical Specification 3/4 9.4. By rearranging the above Technical Specifications that addrest the ,

i containment purge system, inconsistencies and duplication will be eliminated. i In recent discussions, your staff expressed two concerns regarding the above changes.

These concerns and our response to each are provided below.

1 CONCERN: Surveillance Requirement 4.6.4.1.1 provides specific post-maintenance test requirements for isolation valves listed in Table 3.6- 1. By deleting penetration Nos. 13 and 14 and the associated containment purge valves from Table 3.6- 1, the  !

j specific post-maintehance test requirements for these valves would not be called out in d a Surveillance Requirement. ,

R ESPONSE: Article IWV-3200 (Vahe Replacement, Repair and Maintenance) of Se: tion XI ,

of the ASME Doller and Pressure Vessel Code provides retest requirements when a valve i or its control system has been replaced, repaired, or has undergone maintenance, j

> Surveillance Requirement 4.0.5 specifically requires testing of ASME Code Class 1, 2, '

and 3 components in accordance with Section XI of the ASME Boiler and Pressure Vessel

Code and applicable Addenda as required by 10 CFR 50.55a(g). Although requirements for retesting of the containment purge valves would still be in place through Surveillance ,

Requirement 4.0.5, we have added Surveillance Requirement 4.9.4.3 (see Enclosure 2) "

which is identical to 4.6.4.1.1.

1 CONCERN: Proposed Technical Specification 3.9.4 could make it possible to open a l containment purge valve during CORE ALTERATIONS or movement of irradiated fuel within i l the containment without having tested the valves for closure upon a containment radiation high Channel A or Channel B test signal.

l R ESPONSE: When Technical Specification 3.9.4 is applicable, Limiting Condition for ,

) Operation (LCO) 3.9.4.c requires that each penetration providing direct access from the a containment atmosphere to the outside atmosphere must be either: (1) closed by an i l isolation valve, blind flange, or manual valve, or (2) be capable of being closed by an l l OPERABLE automatic containment purge valve. In order to open a containment purge ,

i isolation valve when the Technical Specification is applicable, the valve must have .

been demonstrated OPERABLE or the LCO would be violated. Surveillance requirement  !

, 4.9.4.1.b has been clarified to show that testing with Containment Radiation liigh test i' I

signals is included in the determination of an OPERABLE automatic containment purge

valve (see Enclosure 2). ,

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