ML20203A094
| ML20203A094 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/04/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | BALTIMORE GAS & ELECTRIC CO. |
| Shared Package | |
| ML20203A100 | List: |
| References | |
| NUDOCS 9802230273 | |
| Download: ML20203A094 (5) | |
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l' UNITED STATES OF AMERICA 1
1 NUCLEAR REGut.ATORY COMMISSION j
in the Matter of
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Docket Nos. 50317 Baltimore Gas & Electric Company
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and 50 318
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(Calvert Cliffs Nuclear Power
)
Pferd, Units 1 and 2)
)
EXEMPTION I.
The Baltimore Gas & Electric Company (BGE or the licensee) is the holder of Facility 4
l Operating License Nos. DPR-53 ar d DPR 69, which authorize operation of the Calvert Cliffs l
Nuclear Power Plant, Units 1 and 2 (the facilities), respectively. The license provides, among 4
other things, that the facilities are subject to all rules, regulations, and orders of the U. 8. Nuclear l
Regulatory Commission (NRC or the Commission) now or hereafter in effect.
l The facilities are pressurized-water reactors located at the licensee's site in Calvert County, Maryland.
The licensee is implementing an upgrade to the existing Calvert Cliffs Unit i emergency 1
l l
diesel generator (EDG) 18 during the upcoming Unit i refueling outage (RFO 14). RFO 14 is l
scheduled to commence on April 3,1998, and is expected to be completed in earty June 1998.
l To support the upgrade, the licensee has identified one temporary exemption required at this t
l time. The exemption is specified below.
R.
The Code of Federal Reaulations at 10 CFR Part 50, Appendix A, General Criterion 2 (GDC-2) requires that structures, systems, and components important to safety be designed to withstand the effeds of natural phenomena, such as tomadoes, without the loss of capability to perform their safety funct'ons, i
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' The licensee has requested the temporary exemption from GDC 2 because of the planned upgrade of the Unit 1 EDG 1B. The effort will require temporary removal of two steel doors, which will expose the out-of serv!ce Unit 1 EDG 18 and the operating Unit 2 EDGs 2A and 28, as well as the support systems for the out-of-servica Unit 1 EDG 1B and the operating Unit 2 EDGs 2A and 28. Unit 2 EDGs 2A and 28 must be operable to support the operation of Unit 2.
These EDGs require protection from the effects of missiles, generated by natural phenomena.
The licensee indicates that the steel missile doors will be removed four times during RFO-14; only one door will be removed at a time. The licensee estimates that each of the missile door removals will take less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,-which will result in a total removal time of about 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> during the scheduled 60-day outage.
The licensee is providing compensatory action to ensure the safe operation of Unit 2, for the shor1 periods that the steel missile doors will be removed. To cover all severs weather conditions, as defined in the plant site Emergency Response Plan implementing Procedure 3 3.0, 7, a concerted effort will be made to reinstall the missile doors if a tomado or a hurricane watch is issued or if sustained winds are predicted to be greater than 50 miles an hour at the site. When the missile shield is removed, it is left connected to the crane used to remove it. A crane operator remains at the crane controls during the time the missile shield is removed.
In addition to the crane operator, three people are used to handle the movement of the shield and fasten it in place. These people are drawn from the crew working on the diesel upgrade since the shield is removed only wbsn they are working in the area. The time required to reinstall the missile shield is approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes. This time includes 30 minutes to 45 minutes to move and position tb s shield, and.9) minutes to completely torque a minimum of 13 bolts to hold it in place. The installation time is considered sufficient since plant procedures require that the missile shield be reinstalled on an adverse weather watch, rather than waiting until a waming is issued. The only factor that would impede the reinstallation of the missile doors
5 would be the safety of the individuals performing the reinstallation. The licensee has also stated that the missile doors between the EDG 1B room and the EDG 2A room is a fhe barrier but not a flood barrier. The fire barrier will be breached when the door is removed to pass EDG parts through. Plant procedures require a fire watch if any fire barrier is to remain open. The procedures will be followed from the time the door is removed until it is replaced.
Considering the existing design features and the compensatory measures proposed by the licensee, the likelihood of damage to the exposed EDGs and the support systems from postulated missiles generated by natural phenomena is minimal for the short periods that the protective doors will be removed. Also, on the basis of the compensatory measure provided, reasonable assurance exists that the ability to reinstall the missile doors will be maintained during any severe weather that could result in airbome missiles. Therefore, there is reasonabic assurance that the proposed GDC-2 exemption will present no undue risk to public health and i
safety.
III.
The Commission has determined, pursuant to 10 CFR 50.12(a), that special circumstances, as set forth in 10 CFR 50.12(a)(2)(v), exist. The exemption would provide only temporary relief from the applicable regulation (GDC-2). The exemption is requested for a specific period, after which the facility would again be in conformance with all the requirements of GDC 2. The licensee has made good faith efforts in considering attematives to the exemption request and has concluded that without the subject exemption, the EDG upgrade can only be l
conducted when both units are shut down.
On the basis of this information and review of the licensee's submittal, as summarized in the Safety Evaluation, the NRC staff concludes that the likelihood of unacceptable damage to the exposed portions of the operable EDGs and support systems as a result of weather-induced missiles during short-duration exposures in the exemption period is low.
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4-On the basis of the low probability of the occurrence of unacceptable events, coupled with the compensatory measure to which the licensee has committed, the NRC staff finds the proposeo exemption from GDC 2 to be acceptable.
W.
Accordingly, the Commission has determined that pursuant to 10 CFR 60.12, the subject exemption is authorized by law, will not present an undue risk to public health and safety, and is consistent with the common defense and security. The Commission further determines that special circumstances, as provided in 10 CFR 50.12(a)(2)(v), are present that justify the exemption; namely, that the exemption would provide only temporary relief from the applicable regulations and that the licensee has made good faith efforts to comply with the regulations.
Therefore, the Commission hereby approves the following exemption: Calvert Cliffs Nuclear Power Plant, Units 1 and 2, may operate without conforming to the requirements of GDO 2 as they apply to the exposed portions of the Unit 2 EDGs 2A and 28 and the support systems for the EDGs, providing that the compensatory measure, as described herein, is in place for the period of the exemption.
Pursuant to 10 CFR 51.32, the Commission has determined that granting the above exemption will have no significant impact on the quality of the human environment (62 FR 114).
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-s-The subject Unit No, i EDG 18 upgrade GDC 2 exemption is effective from the date of issuance through July 31 1998 FOR THE NUCLEAR REGULATORY COMMISSION l
r Office of Nuclear Reactor Regulation 4
Dated at Rockville, Maryland, 3
this 4th day of February 1998 d
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