ML20247B046
| ML20247B046 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/30/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20247B049 | List: |
| References | |
| NUDOCS 8909120329 | |
| Download: ML20247B046 (5) | |
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BALTIMORE l
GAS AND I
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. CHARLES CENTER P. O. BOX 1475 BALTlMORE, MARYLAND 21203
. GroRGE C. CREEL Vict PatsiotNT Nuctre.n Entnov.
'(300 aso-ma ss August 30, 1989 U. S. Nuclear Regulatory Commission
. Washington, DC 20555
' ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.'l & 2; Docket Nos. 50-317 & 50-318 Reauest for Amendment Gentlemen:
The' Baltimore Gas' and Eleefric 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 following prcposed changes to the Technical Specifications.
The proposal involves changes to the following pages of the Unit 1 and Unit 2 Technical
. Specifications as shown on the marked-up pages attached to this transmittal:
3/4 6-13 3/4 6-30 3/4 7-23 3/4'6-14 3/46-31 3/4 7-24 3/4 6-15 3/4 7-18 3/4 9-13 3/5 6-16 3/4 7-19 3/49-14 3/4 6-28 3/4 7-20 3/4 9-15 3/4 6-29 3/4 7-22 DISCUSSION This proposal would change the Technical Specifications covering the following systems:
Containment Iodine Removal System, Penetration Room Exhaust Air Filtration System, Control Room Emergency Ventilation System, Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Filtration System, and Spent Fuel Pool Ventilation System.
These.. changes mostly involve the Surveillance Requirements for the laboratory and in-place testing of the charcoal adsorbers and HEPA filters.
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- w Document Control Desk August 30, 1989 Page.2 There are four changes in all. Two changes are proposed for sampling and laboratory analysis of charcoal:
Change 1.
Change the temperature at which the laboratory analysis is done from 130 C to 30 C for the following systems:
Penetration Room Exhaust Air Filtration, Control Room Emergency Ventilation, ECCS Pump Room Exhaust Air Filtration, and Spent Fuel Pool Ventilation.
A temperature of 30 C is more indicative of the accident conditions to which these adsorbers will be sub.iected.
Change 2.
Change the requirement for obtaining charcoal samples so that only one sample is obtained for the laboratory analysis. The Technical Specifications now require that two charcoal samples be removed and tested. The intent was to remove two samples in case one became unusable, but only to test one. This change applies to all five systems.
Change 3.
One change is proposed for in-place testing of the llEPA filters and charcoal adsorbers. The procedure used for the in-place testing would be changed from ANSI N510-1975 to Regulatory Guide 1.52 Regulatory Positions C.5.a.
C.5.c, and C.5.d.
This change is administrative in nature, would not affect the performance of the test, and has been requested by the NRC. The same sections of ANSI N510-1975 will still be used, but the Technical Specifications will reference the Regulatory Positions. This change applies to t ll five systems.
Change 4.
One change is proposed for the surveillance which verifies I
isolation ' of the Control Room on a high radiation signal. The change would clarify that all appropriate isolation valves will be closed.
It spreifically causes verification that both isolation valves in each inlet duct and the common exhaust duct.
I and the isolation valve in the toilet area exhaust duct area, close. This change has been requested by the NRC.
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' Document Control Desk i
' August 30,1989 Page 3 l
d DETERMINATION OF SIGNIFICANT HAZARDS These proposed changes have been evaluated against the standards in 10 CFR 50.92 and have been determined to involve no significant hazards considerations, in l
that operation of the facility 'in accordance..with the proposed amendment would
-l not:
(i) involve a significant increase in the probability or consequences of an accident previously evaluated; The change to have laboratory testing of charcoal adsorber samples performed at 30 C from 130 C does not effect probabilities. Since this more realistic testing parameter will yield more realistic test results, the evaluated accident consequences will be more accurate.
Changing. our charcoal adsorber bed sample removal and testing requirement from two down to one will not effect accident l
probabilities or consequences.
Changing the reference for in-place testing of HEPA filters and charcoal adsorbers from ANSI N510-1975 to Regulatory. Guide 1.52 Positions C.5.a.
C.5.c.
and C.5.d L an administrative change.
'The three.. Regulatory Positions direct. us to the same ANSI N510-1975 sections that we were using all along. Therefore, this change does not effect accident probabilities or consequences.
Clarifying the. requirements to periodically verify that the Control Room has been isolated on a Control Room High Radiation alarm will not effect the probabilities of any accidents and could actually reduce the potential consequences of an accident if the verification finds valves not fully closed.
or(ii) create the possibility of a new or different type of accident from any accident previously evaluated; I
None of these changes modify equipment design or operation.
Therefore, none would create the possibility of a new or different accident.
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- 1Docum nt Co: trol Desk :
<.g..s August 30, 1989 Page 4
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involve a significant reduction in a margin of safety.
.The change to have-laboratory testing of. charcoal adso:ber samples '
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performed at 30 C ' from 130 C will ' cause ' results to be snore conservative. and, therefore, increases margin of safety.
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Regarding changing our charcoal adsorber bed sample removal and l
testing' requirement from two down to one, the two samples taken in l
-the past each wtre: a representative sample for determining the condition of the charcoal bed. Taking one sample will still give
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a representative ' sample. Current regulatory guidance and industry
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practice : do not indicate a need for more than one sample. Margin of safety is not effected by this change.'
Changing the reference for in-place testing of IIEPA filters and i
charcoal adsorbers from ANSI N510-1975 to Regulatory Guide 1.52 l
Positions. C.5.a.
C.S.c, and C.5.d is an administrative change.
The three Regulatory Positions direct us to the same ANSI
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N510-1975 sections - that 'we were using all along. Therefore, this change does not effect any margin of safety.
Clarifying the requirements to periodically verify that the l
Control Room has been isolated on a Control Room liigh Radiation alarm will actually. increase the margin. of safety in that there is
' more assurance that each valve will be checked closed and, therefore, the chances that. the Control Room would not be totally l
isolated have been reduced.-
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' Document Control Desk
- August 30, 1989 Page 5 SAFETY COMMITTEE REVIEW l
These proposed changes to the Technical Specifications and our determination of I'
significant hazards have been reviewed by our Plant Operations and Off-Site Safety l:
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.
Very truly yours l
STATE OF MARYLAND TO WIT :
COUNTY OF CALVERT
.3 hereby certify that-on the 30th day of August,81/n0+T'1989, before me,[1//a fmthe subscriber, a
. Notary Public of the State of Maryland in and for
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personally appeared George C. Creel, being duly sworn, and states that hofis 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 cf his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
WITNESS my Har.? and Nota-ial Seal:
b7AA)I d-4 I
Notary Public My Commission Expires:
't /. /Y9d v
(pate '
GCC/9tS/ dim Attachments l
cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire l
R. _A.Capra, NRC i
S. A.McNeil,NRC
]
W. T. Russell, NRC j
i V. L. Pritchett, NRC T. Magette, DNR L
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