ML20204E799
| ML20204E799 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/14/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20204E804 | List: |
| References | |
| NUDOCS 8810210453 | |
| Download: ML20204E799 (6) | |
Text
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475
- BALTIMORE, MARYLAND 21203 JostpH A.TIERNAN vece patsiormt NuC6 tam Esotmot October 14, 1988 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit No. 2: Docket No. 50-318 Reauest for Amendment Gentlemen:
The Baltimore Gas and Electric Company hereby requests an Amendment to its Operating License No. DPR-69 for Calvert Cliffs Unit No. 2 with the submittal of the following proposed changes to the Technical Specifications.
CilANGE NO.1 (BG& E FCR 88-132)
Change pages 3/4 7-26 of the Unit 2 Technical Specifications as shown on the marked-up psges attached to this transmittal.
JilSCUSSION in the spring of 1987 Calvert Cliffs Unit 2 changed the duration of its refueling cycle from 18 to 24 months. Technic.I Specification 4.7,8.1.c requires that at least once per 18 months during shutdown, a representati e sample of 10% of each type of snubber in use in the plant shall be functionally tested.
Additional snubber function.11 tests are required if any of the tested snubbers do not meet the functional test acceptance criteria of technical Specification 4.7.8.1.d.
Performance of the functional testing requires Unit shutdown. The purpose of this pioposed one time Technical Specification change is to allow Calvert Cliffs Unit 2 to complete its current 24 month refueling cycle without havios to shutdown to satisf y the required 18-month snubber functional testing requirement. Calvert Cliffs Unit 2 is scheduled to be shutdown for refueling on March 31,1989. The 18 month + 25% maximum snubbet surveillance interval expires on March 22, 1989. This one time change will allow us to perform the snubber functional tests during the refueling outage. The one-time Technical Specification change propoles th
- the '18 month' snubber functional testing requirement be changed to 'l8 months + 's 4' in Technical Specification 4.7.8.1.c.
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Documera Control Desk October 14, 1988 Page 2 This is a one-time change which proposes that the maximum allowable extension of the safety-related snubber functional tests be increased from 25% to 35E The 10% increase in the maximum allowable time extension of the functional tests is equivalent to an increase of 54 days. The 54 days are being requested to provide an adequate time margin if refoeling outage re-scheduling becomes necessary, and to assure that adequate time is available after shutdown for the functional testing of snubbers required to be operable in MODES $ and 6.
We recognize the punitive nature of the Snubber Technical Specification and view it as self-correcting. A snubber program with a history of so very fev> inoperable snubbers per inspection period should not be unduly penalized. Therefore, we request the one-tin.e Technical Specification changes noted above due to the following:
1.
Calvert Cliffs Units I and 2 have a very successful snubber program. Sir..e 1978, we have functionally tested 413 snubbers between both Units. There base been only three failures in this time period. This equates to a functional test failure rate of 0.7%
Since
- 1970, we hase visually inspected 5387 snubbers between both Units. There have been only 18 failures in this time period. This equates to a visual inspection failure rate of 0.3 %
2.
Calvert Ciiffs Unit 2 has extended its refueling interval from 18 to 24 months. The proposed Technical Specification changes would allow Calvert Cliffs Unit 2 to complete its current scheduled operating cycle without being required to shutdown to perform snubber functional tests. The change would also allow a reasonabic amount of extra time if refueling outage re-scheduling besomes necessary.
3.
The changes lower the probability of esents which are more likely to occur during transient operation (heatup and cooldown) than at full power steady state operation. Increasing the functional testing interval eliminates one cooldown/heatup cycle for Unit 2 that would otherwise be required before the unit is shutdown for refueling in March of 1989.
4.
Extension of the functional testing intersal effectively increases the maximum allowable surveillance interval by 8% The increase in the probabi'ity ol' a snubber failure during the 8% ($4-day) extension period is insignificant. This is due to the successful snubber program at Cals ert Cliffs and the relatively short length of the surseillance period extension ss compared to th, total surveillance interval.
3.
The cost of performing the functional tests during an unscheduled maintenance outage is considered to be excessise in comparison to the benefits realized by performing the tests.
Due to the surseillance interval expiration date of March 22, 1989, it is requested that a response be furnished to the 13altimore Gas and 1:lectric Company by March 15, 1989. This will allow fise working da>s for receipt and internal processing of the changes.
o Document Control Desk October 14, 1988 Page 3 DETE R MIN ATION OF SIG NI F1 CANT i f AZ A R DS The proposed one-time changes have been evaluated against the standards in 10 CFR 50.92 and have been determined to involve no significant hnards considerations, in that operation of the facility in accordance with the proposed Technical Specification change would not:
(i) involve a significant increase in the probability or consequences of an accident previously evaluated.
Since 1978 we have functionally tested 413 snubbers and visually inspected 5,387 snubbers between Unit I and Unit 2. There has been only 3 functional and 18 visual failures in this time period, corresponding to failure rates of 0.7% and 0.3%, respectively. Dased upcn this surseillance history, we have no reason to believe that the proposed one-tirne Tachnical Sp *cifica-tion change will result in a significant increase in the probabiiity or consequences of any accident previously evaluated. The punitive riature of Technical Specification 4.7.8.1 will force a
larger representatise functional test sample if cny functional failures are noted. Extending the snubber functional testing maximum allowable time extension from 25% to 35%
will not significantly increase the probability o t' any accident previously evaluated. No plai' changes are being made, thus no increase in the consequences of any accident previously eval ated will occur.
(ii) create the possibility of a new or different type of accident from any accident previously evaluated.
The proposed Technical Specifications change does not change the number, type, design, function or remaining service life of snubbers in the Unit.
The ability of snubbers to provide dynamic load support during a design basis seismic event does not change. This conclusion is based on our successful snubber program.
- Thus, the change does not create tFe possibility of a new accident, nor does ;t create the possibility of a different type of accident from any accident previously evaluated.
(iii) involve a significant reduction in a margin of safety.
Extending the snubber functional testing interval does not significantiy reduce any margin of safety. Past operating experience indicates that our current snubber program is more than adequate in minimizing snubber failures. The thance of a snubber failure occurring during the increased functional testing surveillance time interval is small.
l o
DoEument Control Desk r
October 14, 1988 Page 4 l
CilANGE NO. 2 (BG&E FCR 88-132)
Change pages 3/4 7-25 and 7-26 as shown on the marked up pages attached to this l
transmittal. Changes on page 7-26 which are detailed in CIIANGE NO. I to this t
f proposed amendment are not included in this change, plSCUSSION The proposed changes are permanent administrative Technical Specification changes designed to provide consistency and reme.e confusion from Technical Specifica-t tion 3.7.8. The proposed changes are as follows:
1.
The note at the bottom of Technical Specification page 3/4 7-26 which states; *
- The Steam Generator snubbers 2 63-11 through 2-63-26 need not be functionally tested until the refueling outage following June 30, 1985."; will be deleted.
I 2.
Three typographical errors, located on pages 3/4 7-25 and 7-26 will be t
corrected. The first, located in the ACTION STATEMENT on page 3/4 7-25, will chrnge "4.7.8.b" to 4.7.8.1.b."
The other two, located on page 7
3/4 7-26, will change
'4.7.8.d*
to
'4.7.8.1.d."
This change includes a permanent administrative change which proposes deleting the note at the bottom of Technical Specification page 3/4 7-26, and correcting several i
typographical errors on pages 3/4 7-26 and 7-27. The note reads, *
snubt ers 2-63-11 through 2-63-26 need not be functionally tested until the refueling outage following June 30, 1985." The referenced refueling outage has passed and the note no longer has any applicability. Removing the note will prevent confusion in the 9
future. Correction of the typographical errors shall provide consistency in Technical l
Specification 3.7.8. This will preclude any unforeseen confusion which might arise in the future.
I l
DETERMINATION OF SIGNIFICANT llAZARDS t
The proposed permanent changes have been evaluated against the standards in 10 CFR 50.92 and have been determined to involve no significant safety hazards l
considerations, in that operation of the facility in accordance with the propased amendment would not:
}
(h involve a significant increase in the probability or consequences
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of an accident previously evaluated.
4 The changes are administratise in..ature and do not affect
..n y accident evaluated in the Updated Final S & ty Analysis Report (FSA R). Thus, neither the probability nor the cons quences of any accident previously evaluated is increased.
I t
o Do6ument Control Desk October 14, 1988 Page 5 (ii) create the possibility of a new or different type of accident from any accident previously evaluated.
No new or different types of accidents from those previously evaluated in the Updated FSAR are created by this change. No equipment changes or changes in operating procedure or philosophy are involved.
(iii) involve a significant reduction in a margin of safety.
These administrative changes do not increase the potential for snubber failure in any way and, thus, do not increase any margin of safety associated with snubbers.
SAFETY COMMrITEE REVIEW These proposed changes to the Technical Specifications and our determination of sigr.ificant hazards have been reviewed by our Plant Operations and Off-Site Safety Review Committees, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the rublic.
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Ddcument Control Desk October 14, 1988 Page 6 l
i FES DETERMINATION Pursuant to 10 CFR 170.21, we are including BG&E Check No. 1267037 in the amount of
$150.00 to the NRC to cover the application fee for this request.
l Very truly yours, 1
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l STATE OF MARYLAND :
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I hereb certify that on the
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day of hdDAld
_, I IN, before me, the
/ u rf, suljseriber, a Notary Public of the State of Maryland in and for 1
rant 6e
, personally appeared Joseph A. Tiernan, being duly sworn, and states i
that he il Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein l
l set forth: that the statements made are true and correct to the best of his knowledge, i
I Information, and belief; and that he was authorized to provide the response on behalf of said Corporation, f
W WITNESS my lland and Notarial Scal:
Notary Public
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Date j
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JAT/CD*) dim Attachments l
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cc:
D. A. Brune, Esquire i
J. E.
Silberg, Esquire
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R. A.Capra, NRC
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i S. A.McNeil,NRC l
W. T. Russell, NRC
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5 D. C Trimole/V. L. Pritchett, NRC i
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T. Magette, DNR
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