ML20236C440
| ML20236C440 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/15/1989 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | BALTIMORE GAS & ELECTRIC CO. |
| Shared Package | |
| ML20236C422 | List: |
| References | |
| NUDOCS 8903220150 | |
| Download: ML20236C440 (6) | |
Text
-
l
'7590-1 UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
.)
)
l BALTIMORE GAS AND ELECTRIC
)
l COMPANY
)
)
(Calvert Cliffs Nuclear
))
Power Plant Unit 2)
EXEMPTION I.
The Baltimore Gas and Electric Company (the licensee) is the holder of Facility Operating License No. DPR-69, which authorizes operation of the Calvert Cliffs Nuclear Power Plant Unit No. 2 (the facility). The-license provides, among other things, that the facility is subject to all rules, regulations and Orders of the Nuclear Regulatery Comission (the Commission) now or hereafter in effect.
I The facility is one of two pressurized water reactors located at the 1
licensee's site in Calvert County, Maryland.
II.
i Sections III.D.2(a) and III.D.3 of Appendix J to 10 CFR Part 50 l
respectively require that Types B and C containment local leak rate tests:
(LLRTs) be performed during each reactor shutdown for refueling but.in no case at intervals greater than two years.
During the previous Calvert Cliffs Unit 2 refueling outage, the LLRT testing program was conducted from March 9 to June 4. 1987 with the first Type B and C test completed on March 16, 1987. The current operating cycle (Cycle 81 was the first 24-month operating cycle at Calvert Cliffs Unit 2.
8903220150 090315 9
DR ADOCK 0500 QO m
a i '
I This Cycle is scheduled to end with a Unit 2 shutdown on March 25, 1989.
Consequently, the Unit 2 LLRTs would not all be performed within the required l
l 2-year test interval unless the licensee chose to shut down prematurely and 1)
I reload the core without having fully utilized the soon-to-be discharged spent l
fuel or 2) perform the Types B and C tests and subsequently operate for an-additional 9-10 days before refueling with the same Types B and C tests possibly repeated again during the upcoming refueling outage or during the following l
operating cycle. Therefore, the licensee'has requested a temporary exemption from these requirements to permit an extension of up to'28 days for the performance of each individual Type B or C LLRT. This temporary exemotion would expire upon reaching 199.9'F average reactor coolant system (RCS) temperature during initial RCS heatup following the Unit 2 Cycle 9 refueling l
outage.
In the transformation from an 18-month to a 24-month operating cycle, j
the licensee has shown good faith in attempting to perform and comply with all surveillance test that previously would have not needed to be performed until the next refueling outage. This good faith effort was exhibited by tho licensee when it conducted an extensive mid-Cycle 8 Unit 2 outage that was initiated to perform 18-month refueling interval suruillance tests to ensure that their associated test intervals did not exceed the allowed periods. Unfortunately, the licensee, in analyzing its testing _ program to determine which surveillance needed mini-outage retesting, failed to note that the Types B and 0 LLRT retest intervals for certain containment penetrations and isolation valves would exceed the maximum 2-year interval before the next refueling outage. This deficiency was not noted by the licensee until November 1988.
III.
Pursuant to 10 CFR 50.12. "The Commission may, upon application by any interested person or upon its own initiative, grant exemptions from.the requirements of the regulations of [10 CFR Part 501, which are ~... Authorized-by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security." Further, Section 50.12(a)(2) provides inter alia, "The Commission will not' consider granting an exemption unless special circumstances are present. Special circumstances are present whenever... (v) the exemption would provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation."
Despite a good faith effort to comply with the provisions of the rule, the licensee will not be able to comply with the maximum allowable retest interval for all Types B and C LLRTs without conducting an extensive,.
j premature outage at Unit 2.
This exemption provides only temporary relief i
from the applicable regulations, j
As discussed in our Safety Evaluation, dated March 15, 1989, there are several reasons for concluding that this extension to the maximum 2-year -
1 Types B and C LLRT retest interval will not adversely affect protection of the public health and safety. First, this extension is a one-time occurrence spanning, at a maximum, only 28 days during which containment integrity could be necessary.
It is more probable that containment integrity will be needed for only the first 10-14 days of this extension period. ' However, the full 28-day period represents an interval extension of less than 4% of the maximum allowable retest interval during which no significant further degradation of either the containment penetrations or of the containment
4 isolation valves is likely. Second, this retest extension will not increase the possibility of events that require containment integrity, primarily the loss of coolant accident (LC0A).
Finally, for this interval extension to j
significantly increase the consequences.or size of a radiological release to the outside environment, a significant degradation of the containment boundary must occur during the 28-day extension followed by an event requiring containment integrity. As neither is probable during the 28-day extension, their sequential l
l occurrence is quite unlikely.
IV.
Accordingly, the Commission has determined, pursuant to 10 CFR 50.12(a),
that (1) a temporary exemption as described in Section III. is authorized by' law, will not present an undue risk to the public health and safety, and is l
consistent with tne conmon defense and security and (2) in this case, special circumstances are present as described in Section III. Therefore, the l
Commission hereby grants the following exemption:
The Baltimore Gas and Electric Company is exempt from the requirements of Sections III.D.2(a) and III.D.3 of Appendix J to 10 CFR Part 50, for performing Types B and C local leak rate retests on the Calvert Cliffs Unit 2 containment penetrations and isolation valves, in that the allowable retest interval for each individual Type B or C test may be extended to 2 years and 1
28 days vice the maximum 2-year interval specified in these sections. This exemption expires upon reaching 199.9"F average reactor coolant system (RCS) l temperature during the initial RCS heatup following the Unit 2 Cycle 9 refueling outage. Upon expiration, the licensee shall comply with the provisions of these sections.
W
-5 Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not result in any significant environmental impact (53 FR 10757).
This exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION l
ORIGINAL SIGNED BY Gus C. Lainas, Acting Director l
Division of Reactor Projects I/II Office of Nuclear Reactor Regulation l
l Dated at Rockville, Maryland, l
this 15th day of March 1989.
1 l
l i
l l
- SEE PREVIOUS CONCURRENCE l
1 16 A
0FC I.1
- PDI.1
- 0GC
- PDI-
- AD:D
- Act D:DRP:
.....:...... _ _ _ :.. _ _ _.j NAME :CVoga
- SMcN F :v RCapra
- BBog<.r
- G ainas
_ _ _... :............ :.S.HL_e_wi.s.. _ _ _ :
.. _ _ _ _ _ _ _ _ _.....( 8 9 '____..J//M._________,______
DATE :
/89
- 3 //f/89
- 3 / 15/89 *
- 3 //S/89
- q /i g
OFFICIAL RECORD COPY'
--__________m.m_______u
5 Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not result in any significant environmental impact ( FR
).
This exemption is effective Lpon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Gus C. Lainas, Acting Director y
Division of Reactor Projects I/II e
l Office of Nuclear Reactor Regulation Dated at Rockville, Maryland, this day of March 1989.
1 J
l l
l OFC RDI-l f :PDI-I
- DGC
/
- PDI-l
- AD:DRP
- Acting D:DRP:
.....:. N..... /...:............:... A.
i l NAME :CVoga
- SMcNeM :ve :
- BBoger
- Glainas
- ...,4(#.22..: f NkBILZ:RCapra DATE : / /89
- 3 //#/89
- 7 /E/89
- 3 ////,89
/ /89'
/ /89 0FFICIAL RECORD COPY l
- -