ML20244B196
| ML20244B196 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/01/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20244B199 | List: |
| References | |
| NUDOCS 8906130019 | |
| Download: ML20244B196 (2) | |
Text
4 r o BALTIM O R E GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 GEORGE C. CREEL vier pas siormt NucLtan Entnov aoo n o-u..
June 1, 1989 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Enn. ort of Chances. Tests and Experiments (Supplemental)
REFERENCE:
(a) 10 CFR 50, Paragraph 50.59 (b)
(b)
Letter from Mr.
G.
C. Creel (BG&E) to the USNRC dated March 14, 1989, Report of Changes, Tests and Experiments On March 14, 1989, Baltimore Gas and Electric Company (BG&E) provided you an annual report of changes, tests and experiments that covered the period from January 1, 1988 to December 31, 1988.
As a result of a review of the process that controls temporary modifications, including lifted leads and jumpers, we identified six additional modifications that should have been within the scope of 10CFR 50.59.
These safety evaluations are summarized in Enclosure (1).
These modifications did not receive formal, documented safety evaluations because of our interpretation of Technical Specification (TS) 6.5.1.6.d which states, "The Plant Operations and Safety Review Committee (POSRC) shall be responsible for review of all proposed changes or modifications to plant system or equipment that affect nuclear safety."
We had concluded that equipment that "affects nuclear safety" was the same as " safety related" equipment.
This interpretation led us to develop a temporary modification procedure that required a formal, documented safety analysis and POSRC review only when those modifications involve "any system, subsystem or component designated by the Q-List or Equipment Database as safety related".
Recent NRC Inspections prompted us to reevaluate our interpretation of TS 6.5.1.6.d.
Our new interpretation currently installed (approximately 65) against a newly developed discussion criteria.
This review involved 18 engineers and required 320
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6906130019 890601 ADOCK0500gg{7 PDR R
Document Control Desk June 1, 1989 Page 2 manhours.
The new discussion criteria explores how any temporary modification might affect nuclear uafety.
Through a strict interpretation of determining an increase in the probability of an accident, one of the six modifications was determined to constitute an unreviewed safety question (USQ).
This modification involved defeating a limit switch on the Unit 2 fuel assembly upender machine.
While the modification marginally increased the probability of occurrence of a fuel handling accident, the Updated Final Safety Analysis Report (UFSAR)
Chapter 14.8 analysis clearly bounds any consequence of jumpering the limit switch.
The USQ is discussed in Enclosure (1).
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very~truly 4Gr
/
')[
-,, /
Ge rge C.
Cr el GCC/ENM/jc Enclosure cc:
D. A.
Brune, Esq.
R. A. Capra, NRC H. Eichenholz/V. L. Pritchett, NRC I
T. Magette, DNR S. A. McNeil, NRC W. T. Russell, NRC J. E. Silberg, Esq.
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