ML20211J269
| ML20211J269 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/02/1997 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20211J274 | List: |
| References | |
| NUDOCS 9710080050 | |
| Download: ML20211J269 (10) | |
Text
Cut.tt.r. II. Cutu llahimore Gas and Liectric Company
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Vice President Cahett Chth Nuclear Power Pl.mt Nuclear Energy 1650 Cah en Chth Parkw ay Lusby. Maryland 20657 410 495-44$$
October 2,1997 U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION:
Document Control Desk SUlljECT:
Calvert Cliffs Nuclear Power Plant Unit No.1; Docket No. 50 317 License Amendment Request: Upgrade of No. In rmergenev Diesel Generator
REFERENCES:
(a)
Letter from hir. R. E. Denton (ilGE) to NRC Document Control Desk, dated November 1,1995, License Amendment Request; Enhar.:cment of the Engineered Safety Features Electrical System (b)
Letter from hir. D. G. hicDonald, Jr. (NRC) to hir R. E. Denton (BGE),
dated April 2,1996, issuance of Amendments for Calvert Cliffs Nuclear Power Plant, Unit No, I (TAC No. h194030) and Unit No.2 (TAC No. h194031)
Pursuant to 10 CFR 50.90, the Baltimore Gas and Electric Company (BGE) hereby requests an Amendment to Operating License No. DPR 53 by the incorporation of these changes to the Technical Speci0 cations for Calvert Cliffs Unit No.1.
In reference (a) above, BGE submitted a license amendment request whkh included upgrading the electrical capacity of the No. 2A and 2B Emergency Diesel Generators (EDG), and stated that the No. IB EDG would he upgraded in a future refueling outage. in reference (b), the NRC issued these amendments and provided a safety Evaluation Report. This submittal requests a license amendment as part of the modification to upgrade the electrical capacity of the No, IB EDO. The details of the modifications were evaluated by BGE in accordance with 10 CFR 50.59, and were determined not to involve an unreviewed safety question. This proposed change revises the Technical Specifications to reflect the new electrical capacity for No.1B EDG.
We have evaluated the significant hazards considerations associated with this change and have K determined that there are none. We have also dctermined that operation with the proposed amendment would not result in any significant change in the types, or significant increases in the amounts of any khtOd8O'O50971002 l
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liocum:nt Control Desk October 2,1997 Page 2 l
I efnuents that may be released offsite, nor would it result in any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion as set forth in 10 CFR S t.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed amendment.
The Plant Operations and Offsite Safety Review Committees have reviewed the proposed change to the Technical Specifications and concurred that operation with the proposed change will not result in an undue risk to the health and safety of the public.
These modificatior.c are to be performed during the next Unit i refueling outage, which is scheduled to begin in April 1998. This change is requested to be approved and issued in conjunction with the outage.
implementation of these Technical Specifications cannot occur until the electrical capacity of No. til EDO is upgraded and testing is complete. The testing will be completed prior to entry into Mode 4 near the end of the outage.
It should be noted that the requested approval date is after the proposed implementation date for our conversion to the improved Technical Specifications. Therefore, proposed changes to the improved Technical Specifications are also attached, if the improved Technical Specifications are approved prior to this proposed change, we request that this change be applied to the appropriate sections of the improved Technical Specifications.
D'ocument Control Desk October 2,1997 l' age 3 Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, pV - w,:a-
/
STATE OF MARYLAND
- TO WIT:
COUNTY OF CALVERT 1 Charles 11. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, llaltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this License Amendment Request on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowleduc, they are based upon information provided by other BGE employees and/or consultants. Such :nformation has been reviewed in accordance with company practice and I believe it to be reliable.
Af _ m e-
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Subsenbed and sworn before me, a Notary Public in and for the State of hiaryland and County of A/perf
, this A day of Ch h h c 1997.
WITNESS my lland and Notarial Seal:
Notary Public hiy Commission Expires:
44 Djde CllC/SJR/ dim Attachments: (1)
Description and Justification of Proposed Change (2)
Determination of Signliicant llazards (3)
Current Unit 1 Technical Specification hiarked Up Pages (4)
Improved Technical Specification hiarked Up Pages cc:
R. S. Fleishman, Esquire 11.J hillier,NRC J. E. Silberg Esquire Resident inspector, NRC A. W. Dramerick, NRC R.1. hiclean, DNR Director, Project Directorate 1 1. NRC J.11. Walter, PSC i
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ATTACilMENT (1) i
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DESCRIPTION AND JUSTIFICATION OF PROPOSED CilANGE I
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i Baltimore Gas & Electric Company Docket Nos. 50-317 and 50-318 October 2,1997 i
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AITACllMENT (1)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CilANGE i
Calvert Cliffs is a two unit site. The plant has four safety related emergency diesel generators (EDOs),
two dedicated to each unit. Three of the EDos are Fairbanks hiorse diesels, the remaining EDO was l
manufactured by SAChi [Societe Alsacienne De Constructions hiccaniques De hiulhouse). Unit I has the SACM EDO (l A) and one of the Fairbanks hiorse EDGs (1B). Unit 2 has two Fairbanks hiorse EDOs (2A and 211). !!oth of the Unit 2 EDGs had their electrical capacity upgraded in previous outages (References 1 and 2). The Unit 2 Technical Specifications re0cct this increase in electrical capacity.
During this upcoming outage, we plan to upgrade the electrical capacity of the No,IB EDO (the remaining Fairbanks hiorre EDG). The Technical Specifications for the No. III EDO upgrade are described below. The proposed Technical Speel0 cation changes are located in Attachment (3). To facilitate review, markups of the Improved Technical Speci0 cations (ITS) are provided in I
Attachment (4).
UPGRADE OF FAIRHANKS MORSE NOs 1H EDG llattimore Gas and Electric Company (DGE) is modifying No. IB EDO to increase its electrical capacity.
The modincation will increase the electrical ratings of No.1B EDO, thereby providing additional margin for the electrical loading of the 4.16 kV ESF bus (No.14) %e mechanical capacity of the engine was also upgraded to support the increased electrical capacity. The details of the modi 0 cation were evaluated by BGE in accordance with 10 CFR 50.59, and determined not to involve an unreviewed safety question.
The quali0 cation testing program for the EDO upgrade was submitted to the NRC in Reference (3), and approved by a Safety Evaluation Report in Reference (4) The No. IB EDO upgrade mod 10 cations will be performed during the 1998 refueling outage, and this EDO will be quallned to the upgraded ratings in accordance with the approved testing program. Since the fuel oil consumption rates forming the basis for the proposed Technical Specifications have previously been based upon the conservative assumption that all three EDGs have been upgraded, no change to this specl0 cation is required.
The EDO ratings following the 1998 Unit I refueling outage are indicated in Table 1 EDG Ratings and Surveillance Requirement Test Loads. The proposed changes revise the Technical Specl0 cations to reDect these new electrical ratings for No. IB EDG. Note that this proposed change will result in all three Fairbanks hiorse EDGs having the same electrical ratings and, therefore, the same surveillance requirements.
Table 1 - EDG Ratings and Surveillance Requirement Test Loads EDG Ratings Surveillance Test Loads EDGID#
Continuous 2000 hr.
200 hr.
hionthly 24 hionth Rating 1A 5400 kW N/A N/A 2 4000 kW 2 4000 kW lB 3000 kW 3300 kW 3500 kW 2 2700 kW 2 3000 kW 2A 3000 kW 3300 kW 3500 kW 2 2700 kW 2 3000 kW 2 11 3000 kW 3300 kW 3500 kW 2 2700 kW 2 3000 kW l
g[TACllMENT (1)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CilANGE Changetta EDG_SuricillanscEcquirementtResultingfronLEDGhgrades Survelliance Requirement J.8.1.1.2.a.5 verifies that the EDGs are capable of synchronizing with the offsite electrical system and operating, for a period of greater than or equal to 60 minutes, with loads which do not exceed the EDG's continuous rating. Currently, this surveillance requires No. IB EDG to be loaded to greater than or equal to 2250 kW (90% of the continuous rating of the EDG). The proposed change will maintain the existing surveillance reqtiremen:
(testing to 90% of the continuous rating). The surveillance requirement will be modified to require No. IB EDG be loaded to greater than or equal to 2700 kW (90% of 3000 kW). This change reflects the upgraded electrical capability of the EDO. This change in surveillance requirements is consistent with the changes previously approved for Unit 2.
Surveillance Requirement 4.8.1.1.2.d.4 currently requires that No. ID EDG be operated at least once per refueling interval at greater than or equal to 2700 kW (2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating) for at least 60 minutes. For the refueling interval surveillance, DGE proposes changing the acceptance criteria i
for the refueling interval surveillance requirement to at least 3000 kW (continuous rating) for No. til EDG. The change from the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating to the upgraded continuous rating is necessary to ensure that the testing performed is consistent with the intent of the surveillance.
This surveillance is intended to demonstrate the EDG's ability to carry an electrical load near or above the steady state accident loading for a period of time. Before the No.10 EDG wes upgraded, the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating was used because it more closely reflected the steady state accident loading. With the additional electrical capability of the upgraded No.10 EDG, the continuous rating of 3000 kW is sufficient to demonstrate the EDG's long term loading capability. In addition. this change makes the No.10 EDG surveillance compatible with surveillances previously approved for Unit 2's identical EDGs.
> Survel!!ance Requirement 4.8.1.1.2.d.5 requires verification that the auto-connected loads do not exceed 4000 kW for No. l A EDG or 2700 kW for No. IB EDG at least once per refueling interval. Baltimore Gas and Electric Company proposes changing the auto connected load verification for No. lD EDG to 3300 kW to reflect the change in the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of the No.10 EDG. This change mai'itains the intent of the surveillance, namely, to verify that the auto connected loads do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of the EDO. Before the upgrade, the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of the No IB EDG was 2700 kW, with the upgrade it will change to 3300 kW.
(Note: The No. I A EDG does not have a 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating; see Reference 1). This change in load verification will also make the No. ID EDG surveillance consistent with the identical sun eillences on Unit 2.
Table 1, EDG Ratings and Surveillance Requirement Test Loads, compares the design ratings of each EDG to the proposed Monthly (Surveillance Requirement 4.8.1.1.2.a.5) and 24 month (Surveillance Requirement 4.8.1.1.2.d.4) acceptance criteria.
IMPROVED TECIINICAL SPECIFICATIONS The conversion to the ITS (Reference 5) may be approved by the NRC prior to the approval of this proposed change. The changes described above apply to the ITS. Improved Technical Specification Surveillances 3.8.1.4, 3.8,1,11, and 3.8.1.12 are identical to the surveillances previously described.
Additionally, the Determinatica of No Significant flazards (Attachment 2) applies to these changes in the ITS. Markups o' affected ITS pages are provided in Attachment (4). If the conversion to ITS *s complete before % proposed change is approved, we request that this change be applied to the ITS.
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1 NITACIDIENT (1)
DESCRIPTION AND JUSTIFICATION OF PROPOSED CilANGE l
CONCLUSION We request that the NRC grant our proposed changes to the Calvert Clifts Technical Specifications.
These changes were prompted by the upgrade of the electrical capacity of the No. ID Fairbanks htorse EDO. The increased electrical capacity of the No. ID Fairbanks hiorse EDO will result in greater flexibility in the choice of discretionary loads for the mitigation of accidents. Based upon the ability of the Technical Specifications to adequately demonstrate the reliability of the EDGs in the past 20 years, i
and the understanding that the EDG upgrades will not significantly alter the method by which the EDGs operate, we believe that the proposed Technical Specifications will continue to provide an adequate 4
demonstration of ability of the No. ID EDG to perform its safety function: to provide a reliable source of electrical power to the safety related busses to operate the necessary accident mitigation equipment, should offsite power be lost. Furthermore, we have determined that these changes do not create an undue risk to the public health and safety.
REFERENCES (1) Letter from hir. R. E. Denton (BGE) to NRC Document Control Desk, dated November 1,1995, License Amendment Request; Enhancement of the Engineered Safety Features Electrical System (2) Letter from hir, D. G, hicDonald, Jr. (NRC) to hir. C.11. Cruse (BGE), dated April 2,1996, Issuance of Amendments for Calvert Cliffs Nuclear Power Plant, Unit No.1 (TAC No, h194030) and Unit No. 2 (TAC No. h194031)
(3) Letter from hir, R. E. Denton (BGE) to NRC Document Control Desk, dated August 17,1993 Emergency Diesel Generator Upgrade Padect (4) Letter from hir. D. G, hicDonald, Jr. (NRC) to hir. R. E. Denton (BGE), dated February 10,1994, Qualification Testing Program for Emergency Diesel Generator Upgrade Project. Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2 (TAC Nos, hi87249 and h187250)
(5) Letter to NRC Document Control Desk from hir. C. IL Cruse (BGE), dated December 4,1996, License Amendment Request; Conversion of the Calvert Cliffs Units 1 and 2 Technical Specifications to the improved Standard Technical Specifications, NUREG-1432 3
t ATTACllMENT (2) l$
DETERMINATION OF SIGNIFICANT IIAZARDS Baltimore Gas & Electric Company Docket Nos. 50-317 and 50-318 October 2,1997 l
NITACllMENT m DETERMINATION OF SIGNIFICANT liAZAMDS 1he proposed change has been evaluated agalnst the standards in 10 CFR 50.92 and has been determined to not involve a significant hazards consideration, in that operation of the facility in accordance with the proposed amendments:
1.
Would not involve a sign {ficant increase in the probability or consequentes of an accident previously evaluated.
The Engineered Safety Features (ESP) electrical system provides a reliable source of elecwical power to the 4.16 kV ESF busses to operate the necessary accident mitigation equipment, should offsite power be lost. *lhe proposed change to the Technical Specifications was prompted by the upgrade of the electrical and mechanical capacity of the No ID Fairbanks Morse Emergency Diesel Generator (EDG). The increased electrical capacity of the No.1H Fairbanks Morse EDG will give the operators greater flexibility in the choice of discretionary loads for the mitigation of accidents. This modification necessitates changes to the Technical Specifications.
The ESF electrical system, including the four EDGs, is used to mitigate the consequences of an accident. The modification to upgrade the capacity of No, IB EDG will increase the electrical output of the EDG, but will not change the configuration of the ESF electrical system or any support systems such that the EDGs would become an accident initiator. Therefore, the proposed change would not increase the probability of an accident previously evaluated.
The proposed Technical Specifications will continue to demonstrate the reliability and capability of the upgraded No. lH EDG to perform its accident mitigation function. The proposed changes to the surveillance requiremems do not alter the intent or performance of the surveillance. Only the electrical-loadings changed, reflecting the change in the EDG's electrical capacity.
Implementation of the proposed Technical Specifications will not reduce the ability of No. IB EDG to perform its safety functions. Any auxiliary systems that required modification or analysis to suppon the upgraded ratings of the ID Fairbanks Morse EDO have been determined not to adversely impact operation of any other plant systema necessary to mitigate the consequences of an accident.
Therefore, the prvposed change would not increase the consequences of an accident previously evaluated.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Would not create the possibility of a new or diferent type of accident from any accident previously evaluated.
The proposed change increases the electrical loading for surveillance requirements to reflect the upgrade to the electrical capacity of the No. ID Fairbanks Morse EDG. This change does not add any new equipment, modify any interfaces with any existing equipment, change the equipment's function, or the method of 0perating the equipment to be modified. The system wl!!
continue to operate in the same manner as before the capacity upgrades were implemented. The modified No. I B EDG will continue to function as an accident mitigatar, and will not become an initiator of any accident.
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AIIACilMENT (2)
DETERMINATION OF SIGNIFICANT liAZARDS
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%crefore, the proposed change does not create the possibility of a new or different type of accident from any accident previously evaluated.
3.
Wouhlnot lowolve a significant reduction in a rnargin ofsafety.
The safety function of the EDO is to provide a reliable source of electrical power to the ESF clectrical system suf0clent to power the necessary accident mitigation equipment, should offsite power be lost. This safety function is demonstrated by performing the required surveillance tests. The proposeci changes do not alter the intent or method of performance of any of the sun cillance tests.
The proposed change to the Technical Speci0 cations was prompted by the upgrade of the electrical and_ mechanical capacity of the No. ID Fairbanks Morse EIX). The higher electrical-capacity will result in an increase in the margin between No, in EDO's electrical capacities and the electrical power required to operate safety related equipment required for safe shutdown or accident mitigation. The increased electrical capacity results in the need to increase the electrical loadings used in the surveillance tests. The changes in the survell!ance tests will continue to ensure that the EDO is tested appropriately and will continue to perform its safety -
function. In addition, it should be noted that upgrades on identical Fairbanks Morse EDGs have already been perfonned on Unit 2 and have resulted in identical changes to the Unit 2 Technical Specl0 cations. Because of the increased electrical margin afforded by the upgraded EDG, these modl0 cations may be considered an increase in the margin of safety.
1 Therefore, the proposed change does not involve a signincant reduction in a margin of safety, 2_
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