ML20209E613

Application for Amend to Licenses DPR-53 & DPR-69,deleting Ref to Containment Purge Isolation Valve Mode 5 Applicability in Operability Table 3.3-3 of ESFAS Instrumentation Tech Specs.Fee Paid

ML20209E613
Person / Time
Site:	Calvert Cliffs
Issue date:	06/28/1985
From:	Poindexter C BALTIMORE GAS & ELECTRIC CO.
To:	Butcher E Office of Nuclear Reactor Regulation
Shared Package
ML20209E618	List: ML20209E613 ML20209E621
References
NUDOCS 8507120033
Download: ML20209E613 (9)

Text

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• i BALTIMORE GAS AND i ELECTRIC CHARLES CENTER

• P.O. BOX 1475 BALTIMORE, MARYLAND 21203 CHRis H. POINDEXTER VICE PRESIDENT ENGINEERING AND CO**STRUCTION June 28,1985 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C. 20555 ATTENTION: Mr. Edward 3. Butcher, Jr., Chief Operating Reactors Branch #3 Division of Licensing

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Request for Amendment

REFERENCES:

(a) BG&E letter from Mr. A. E. Lundvall, Jr., to Mr. R. A. Clark, dated December 7,1981 (b) BG&E letter from Mr. A. E. Lundvall, Jr., to Mr. R. A. Clark, dated September 22,1982 (c) I&E Inspection Report 50-317/85-09; 50-318/85-09 (d) Letter from Mr. R. A. Clck, NRC, to Mr. A. E. Lundvall, Jr, BG&E, dated October 24, 1930, Order for Modification of License, Environmental Qualification Gentlemen:

The Baltimore Gas and Electric Company hereby requests an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos.1 & 2, respectively, with the submittal of the proposed changes to the Technical Specifications.

CHANGE NO.1 (BG&E FCR 85-32)

Change pages 3/4 3-13 and 3/4 6-25 of the Unit Nos. I and 2 Technical Specifications as shown on the marked-up copies attached to this transmittal.

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• Mr. E. J. Butcher, Jr.

June 28,1985 Page 2 DISCUSSION This proposed change deletes reference to the Containment Purge Isolation Valves' MODE 5 applicability in OPERABILITY Table 3.3-3 of the Engineering Safety Feature Actuation System Instrumentation Technical Specification. Also, in order to provide consistency, we propose to similarly delete reference to the MODE 5 applicability of the Containment Purge Isolation Valve isolation times of OPERABILITY Table 3.6-1, Containment Isolation Valves.

By an earlier application for license amendment, reference (a), we requested and received approval to maintain the purge air inlet and exhaust isolation valves in the closed position during plant operation. Technical Specification 3.6.1.7 now requires that the purge supply and exhaust valves be maintained closed, with the air to the air operator isolated and the solenoid air supply valve deenergized in MODES 1-4. Coincident with this change, the " applicable modes" of the manual containment purge valves isolation (TS Table 3.3-3) were changed to provide operational requirement consistency. MODE 5 applicability was unnecessarily added to the table. This error was complicated by a later application for license amendment, reference (b), that instituted a containment purge isolation valve seal replacement program. This program necessitates " tagging-out" the purge valve control switches during MODE 5 seal replacement. Therefore, this proposed change corrects the current discrepancy by removing the inconsistent containment purge valve MODE 5 OPERABILITY requirement.

DETERMINATION OF SIGNIFICANT HAZARDS CONSIDERATIONS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve any increase in the probability or consequence of any accident previously evaluated in the Updated Final Safety Analysis Report.

Containment Integrity is only required in MODES 1-4. Additionally, during core alterations or movement of irradiated fuel within the containment, the status of the containment penetrations is closely maintained. A review of the accidents analyzed in the Updated Final Safety Analysis Report revealed no accidents which would require isolation of the containment purge valves in MODE 5.

(ii) Create the possibility of a new or different type of accident from any accident previously evaluated.

No new equipment, system alignments beyond those previously bounded by current Technical Specifications, or accident analyses are involved in the proposed change.

(iii) involve a significant reduction in the margin of safety.

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Mr. E. 3. Butcher, Jr.

June 28,1985 Page 3 The bases for the appropriate Technical Specifications are not being altered. This proposed change only corrects a current Technical Specification discrepancy.

CHANGE NO. 2 (BG&E FCR's 85-1008 & 85-1013)

Change page 3/4 8-10 of the Unit 1 and 2 Technical Specifications as shown on the marked-up copies attached to this transmittal.

DISCUSSION This proposal (FCR 85-1008) would change the Battery Service Test, surveillance 4.8.2.3.2.d.2, for 125-volt DC Batteries 12 and 22 to reflect their updated design load cycle. A review of the emergency loads supplied by 125-volt DC Batteries 12 and 22 for the design load cycle (two hour discharge caused by a LOCI on Unit I and simultaneous undervoltage on Units 1 and 2) has been conducted. The updated design load cycle is determined to be greater than the simulated or " dummy" loads currently used for 125-volt Batteries 12 and 22 during the Battery Service Test performed every 18 months. A safety analysis has been completed which verifies that 125-volt DC Batteries 12 and 22 have ample capacity to supply power for the updated design load cycle. A review of the design load cycle for 125-volt Batteries 11 and 21 is currently in progress, however,it is not anticipated that the result of this review will be larger than the dummy loads currently used during their Battery Service Tests.

This proposal (FCR 85-1013) would also increase the battery terminal voltage required to be maintained during the Battery Service Test for all of the 125-volt DC Batteries from 100 volts to 105 volts. 105 volts is required for OPERABILITY of the emergency loads supplied by the batteries. Battery terminal voltage has not decreased below 105 volts during any previous performance of this surveillance. A safety analysis has been conducted which verifies that all 125-volt DC Batteries have adequate capacity to supply the emergency loads for the design load cycle while maintaining battery terminal voltage at least 105 volts.

DETERMINATION OF SIGNIFICANT HAZARDS CONSIDERATIONS This proposal has been reviewed against the standards set forth in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant increase in the probability or consequences of an accident previously evaluated; or (11) create the possibility of a new or different kind of accident from any accident previously evaluated; or (iii) involve a significant reduction in a margin of safety.

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. ~:4 Mr. E. J. Butcher, Jr.

June 28,1985 Page 4 The proposed change would increase the amperes drawn by 125-volt DC Batteries 12 and 22 and increase the minimum terminal voltage to be maintained by all 125-volt DC Batteries during the performance of the Battery Service Test every 18 months. Thio change would make the surveillance more stringent and, therefore, the probability or consequences of an accident previously evaluated would not be increased and no margin of safety would be reduced.

This proposal would not modify equipment or change system alignments. The procedural change involved would not create the possibility of a new or different accident.

CHANGE NO. 3 (BG&E FCR 85-31)

Change page 3/4 9-4 of the Unit I and 2 Technical Specifications as shown on the marked-up copies attached to this transmittal.

DISCUSSION This proposed change to the Technical Specifications is being processed in response to Reference (c), Unresolved Item 317/85-09-03, concerning use of the temporary closure device as an acceptable replacement for the emergency escape hatch airlock door.

Facility Change Request (FCR)83-103 designed and analyzed a temporary closure device with penetrations to be installed on the emergency personnel escape hatch to facilitate work inside containment during core alterations or movement of irrradiated fuel within the containment. The supporting Safety Analyses determined that the temporary closure device penetrations will prevent direct access from the containment atmosphere to the outside atmosphere. The Technical Specification bases 3/4.9.4 states that there is a lack of containment pressurization potential while in the refueling mode. Thus, the most limiting case of release of radioactivity that could occur during refueling is through a fuel handling incident. This incident, analyzed in the Updated FSAR section 14.18, will not result in containment pressurization, and therefore would not challenge the integrity of the temporary closure device. Additionally, the closure and its penetrations meet the applicable design requirements of the permanent door and penetrations for MODES 5 and

6. Based on these safety analyses, FCR 83-103 was determined not to constitute an unreviewed safety question.

This change provides for a clarification of Technical Specification 3.9.4.b concerning the requirement to have one escape hatch door closed during core alterations or movement of irradiated fuel. This proposed change explicitly addresses the emergency escape hatch temporary closure device in the Technical Specifications.

DETERMINATION OF SIGNIFICANT HAZARDS CONSIDERATIONS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

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4 Mr. E. 3. Butcher, Jr.

June 28,1985 Page 5 (i) Involve any increase in the probability or consequence of any accident previously evaluated in the Updated Final Safety Analysis Report.

The temporary closure device is an acceptable replacement for the personnel emergency escape hatch door. This change only provides a clarification of the Technical Specifications by recognizing the temporary closure device.

(ii) Create the possibility of a new or different type of accident from any accident previously evaluated.

No modifications to the intent of the Technical Specifications are being made, therefore, no new accident previously unanalyzed will be created by this proposed change.

(iii) Involve a significant reduction in the margin of safety.

There will be no change in the operability and closure restrictions necessary to restrict radioactive material release from the containment. The proposed change only clarifles the current Technical Specification wording by recognizing the use of the temporary closure device in place of an emergency escape hatch airlock door.

CHANGE NO. 4 (BG&E FCR 85-30)

Change pages XVI,6-21 and 6-22 of the Unit I and 2 Technical Specifications as shown on the marked-up copies attached to this transmittal.

DISCUSSION This change is being proposed to delete the superseded Environmental Qualification (EQ) deadlines from the Technical Specifications. By reference (d) the NRC transmitted an Order for Modification of License which added the original EQ deadlines to the Technical Specifications. The two deadlines specify the date by which Class IE electrical equipment must be environmentally qualified and the date by which records describing EQ methods must be available. These deadlines have been superseded by the issuance of a final rule in 10 CFR 50.49. BG&E is committed to the revised EQ deadlines contained in the Code of Federal Regulations, as modllled by approved exemption requests.

Therefore, it is proposed to delete the EQ deadlines from the Technical Specifications,

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Mr. E. 3. Butcher, Jr.

June 28,1985 Page 6 DETERintNATION OF SIGNIFICANT HAZARDS This proposed change to the Technical Specifications has been evaluated against the standards in 10 CFR 50.92. It has been determined that this change involves no significant hazards considerations, in that operation of the facility in accordance with the proposed change would nots (i) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (ii) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (lii) Involve a significant reduction in a margin of safety.

The change is administrative in nature and would not alter the schedule for or type of modifications or documentation presently committed to by BG&E to meet 10 CFR 50.49. Therefore, this proposed change would not increase the probability or consequence of a previously analyzed accident, create the possibility of a new accident or decrease any margin of safety.

CHANGE NO. 5 (BG&E FCR 82-138)

Change pages 3/41-21,3/41-25,3/43-16,3/44-8,3/47-72,3/49-11,3/410-5, B 3/41-3, B 3/4 9-3 and 6-14 of the Unit No.1 Technical Specifications; pages 3/41-21, 3/41-25,3/4 3-16, 3/4 3-41, 3/4 4-8,3/4 7-1,3/4 7-64,3/4 9-11,3/410-5, B 3/4 9-3,6-6 and 6-14 of the Unit No. 2 Technical Specifications; and, pages 5.1-1, 5.3-1, 5.5-1 and Figure 5.2-1 of Appendix B to the Unit Nos.1 & 2 Technical Specifications as shown on the marked up copies attached to this transmittal.

DISCUSSION The proposed change would correct numerous syntax, spelling and typographical errors and update several organizational titles. All proposed corrections are administrative in nature and do not affect plant operation or safety.

The proposed changes are described below:

P_ age, Unit (s) Change VI 2 "exhause" to " exhaust" 3/4 1-21 1&2 "within" to "with" 3/41-25 1&2 "the above figure" to " Figure 3.1-2" 3/41-25 1 "3.12" to "3.1-2"

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Mr. E. 3. Butcher, Jr.

June 28,1985 Page 7

.P. gge,_ UnitW Chante i 3/4 3-16 1&2 " provide" to "provided" 3/4 3-41 2 "INSTURMENT" to " INSTRUMENT" 3/44-8 1&2 " tubes" to " tube"

3/47-1 2 " lime" to "line" 3/4 7-5a 2 "sybsystem" to " subsystem" 3/47-64 2 "460" to "4160" 3/4 7-72 1 "460" to "4160"

! 3/4 9-11 1&2 " fuel spent fuel pool" to " spent fuel pool" l

3/4 10-5 1&2 "shotdown" to " shutdown" l "de= energized" to "de-energized" "xeon" to " xenon" B3/41-3 1 "sxfficienta to " sufficient" l B 3/4 9-3 1&2 "is a critical array" to "in a critical array" 6-6 2 " General Foreman" to " General Supervisor" 6-14 1&2 "originial" to " original" App. B 1&2 " Chief Environmental Engineer" to 5.1-1 " Director, Environmental Programs" App. B 1&2 " DIRECTOR ENVIRONMENTAL STUDIES Fig. 5.2-1 AND MONITORING" to DIRECTOR ENVIRONMENTAL PROGRAMS" App. B 1&2 " Environmental Engineering Group" to 5.3-1 " Environmental Programs Unit" m .__. . . _ _ - _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ ..-

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Mr. E. 3. Butcher, Jr.

June 28,1985 Page8 P_ge, Unit (s) Change App. B 1&2 " Environmental Engineering Group" to 5.5-1 " Environmental Programs Unit" (two places)

" Chief Environmental Engineer" to

" Director, Environmental Programs" (two places)

DETERMINATION OF SIGNIFICANT HAZARDS CONSIDERATIONS This proposed change has been reviewed against the standards set forth in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve an increase in the probability of occurrence or consequences of an accident previously evaluated; or (11) create the possibility of a new or different kind of accident from any accident previously analyzed; or (iii) involve a significant reduction in the margin of safety.

The proposed change is administrative in nature and does not involve a change to equipment, procedures, or limits.

SAFETY COMMITTEE REVIEW These proposed changes to the Technical Specifications and our determination of significant 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 public.

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Mr. E. 3. Butcher, 3r.

June 28,1985 Page 9 FEE DETERMINATION Pursuant to 10 CFR 170.21, we are including BG&E Check No. (A334904) in the amount of $150.00 to the NRC to cover the application fee for this request.

Very truly yours, STATE OF MARYLAND :

TO WIT:

CITY OF BALTIMORE :

Chris H. Polndexter, being duly sworn states that he is 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 set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Ccrporation.

WITNESS my Hand and Notarial Scal: A <- ~ c M 2 4.~. -

Notary Public My Commission Expires: 73//I6 Date CHP/BEH/MTF/dtm cc: D. A. Brune, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC T. Foley, NRC T. Magette, DNR