ML20195K371

Application for Amends to Licenses DPR-53 & DPR-69,removing TS Originally Developed from Reg Guide 1.35 & Implementing Requirements of 1992 Edition Through 1992 Addenda of ASME B&PV Code Section Xi,Subsections IWE & Iwl,Per 10CFR50.55a

ML20195K371
Person / Time
Site:	Calvert Cliffs
Issue date:	11/20/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195K378	List: ML20195K371 ML20195K383
References
RTR-REGGD-01.035, RTR-REGGD-1.035 NUDOCS 9811270003
Download: ML20195K371 (8)

Text

l' CHARI.ES II. CRUSE baltimore Gas and Electric Company Vice President Cahert Cliffs Nuclear Power Plant

. Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Ma.yland 20657 410 495-4455 November 20,1998 U. S. Nuclear Regulatory Commission Washington, DC 20$55 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request; Implementation of American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Subsections IWE and IWL Pursuant to 10 CFR 50.90, the Baltimore Gas and Electric Company hereby requests an Amendment to Operating License Nos. DPR-53 and DPR-69 by incorporation of the changes described below into the Technical Specifications for Calvert Cliffs Units 1 and 2.

On September 9,1996, a final rule amending 10 CFR 50.55a was issued requiring owners to implement, by September 9, .2001, the requirements of the 1992 Edition through the 1992 Addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Subsections IWE and 4 IWL, as modified and supplemented by 10 CFR 50.55a. We have developed a program plan to effect the implementation of Subsection IWE and IWL. This submittal requests a license amendment in support of the program plan. i One Technical Specification change requested is an administrative change that remov; a Technical 4 Specification oririnally developed from Regulatory Guide 1.35. Compliance with Regulatory Guide 1.35 is not sufficient to comply with 10 CFR 50.55a, as amerided. The other Technical Specification changes request the removal from the Technical Specifications requirements that are a duplication of 10 CFR 50.55a. The final Technical Specification pages may be renumbered to accommodate added/ deleted pages.

We have evaluated the significant hazards considerations associated with the changes, as required by 10 CFR 50.92, and determined that there are none (see Attachment 2 for a complete discussion).

Operation with the proposed amendment w"ild not result in any significant change in the types or significant increases in the amounts of any ufluents tha' may be released offsite, nor would it result in any significant increase in mdividual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion as et forth in 10 CFR Sl.232(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.

,. ,nrn 9811270003 981120 PDR ADOCK 05000317 p PDR a

_ _ _. _ ._ _. _ . _ . . _. - _m _ . ._.

l> i l

l j . DocumInt Control Desk l

l November 20,1998 l Page 2 l

l We have developed a program plan to implement the inspection requirements of Subsections IWE and i

IWL during the 2000 Unit I refueling outage, which is scheduled to begin in March 2000. To help us l prepare for the inspections in a timely fashion, we request that you review and approve our application by July 1,1999.

I Should you have questions regarding this matter, we will be pleased to discuss them with you. '

l Very truly yours,

, s //

, /C - t%L -

i STATE OF MARYLAND  :

l  : TO WIT:

COUNTY OF CALVERT  :

I I, Charles H. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this response 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 knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been review ( in accordance with company practice and I believe it to be reliable.

[ _. & 11 _

m1L-1 i

t Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of l 042mf .this 20 dayof 7/mlwt ,1998.

WITNESS my Hand and Notarial Seal:

j Notary Public

t. 1 l

My Commission Expires: M MSM '

date CHC/JKK/ dim Attachments: (1) Description and Justification of Proposed Change 4

(2) Determination of Significant Hazards j (3) Units 1 and 2 Marked-up Technical Specification Pages 1

cc: R. S. Fleishman, Esquire H. J. Miller, NRC

J. E. Silberg, Esquire - Resident Inspector, NRC l l S. S. Bajwa, NRC R.1. McLean, DNR I A. W. Dromerick, NRC J. H. Walter, PSC

ATTACHMENT (1) 1 5

i l

i 4

1 i

1 i DESCRIPTION AND JUSTIFICATION OF PROPOSED CHANGE l

1 4 .

j.,. 1 i

4 1

i i

i Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 20,1998

ATTACHMENT (1)

DESCRIPTION AND JUST1FICATION OF PROPOSED CHANGE BACKGROUND in the Federal Register, dated August 8,1996 (61 FR 41303), the Nuclear Regulatory Commission i

amended its regulations to incorporate, by reference, the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI,1992 Edition, through the 1992 I Addenda, Subsections IWE and IWL. Subsection IWE states the requirements for inservice inspection I of Class MC (Metallic Containment components) and the metallic liner of Class CC (Concrete Containment components). Subsection IWL states the requirements for the inservice inspection of the concrete containmrints. The Calvert Cliffs Nuclear Power Plant containment vessels are ungrouted, post-tensioned concrete structures with metallic liners and, therefore, Subsections IWE and IWL apply. )

Revising the inservice inspection program for the Containment Vessels to meet the requirements of 10 CFR 50.55a(f)(4) creates conflicts with the Technical Specifications that are applicable to the Calvert Cliffs containment vessels. Baltimore Gas and Electric Company is submitting the requested changes to the Technical Specifications to resolve the co.ifiicting issues in accordance with 10 CFR 50.55a(f)(5)(ii).

The requirements of 10 CFR 50.55a, with respect to the containment vessels, are incorporated in the program plan for containment inspection for the first, and subsequent inspection intervals, as required b' the ASME B&PV Code, Section .XI, Subsections IWA, IWE, and IWL.

REOUESTED CHANGES Change 1 - Delete Technical Specification 5.5.6. " Concrete C,atainment Tendon Surveillance Program." Technical Specification 5.5.6 is currently conducted in accordance with Regulatory Guide 1.35, Revision 2,1976. Compliance with Regulatory Guide 1.35 is not sufficient to ensure compliance with 10 CFR 50.55a, as amended. The Concrete Containment Tendon Surveillance Program will be conducted using the Containment Inspection Program Plan, developed in accordance with Subsection IWL of the ASME B&PV code, as required by 10 CFR 50.55a.

Change 2 - Delete Technical Specification 5.6.8 " Tendon Surveillance Report. The Tendon Surveillance Report will be reported to the NRC as required by 10 CFR 50.55a(b)(ix)(B), (C), (D), or (E). The Technical Specification is a duplication of the 10 CFR 50.55a requirement.

Change 3 - Delete Surveillance Requirement 3.6.1.2. Containment structural integrity will no longer be verified by the Containment Tendon Surveillance Program, but rather in accordance with Subsection IWL of Section XI of the ASME R&PV Code, incorporated by reference in 10 CFR 50.55a.

SAFETY ANALYSIS The revisions to the Technical Specifications will allow implementation of a Containment inspection program utilizing the more robust inspection techniques required by incorporating, by reference, the requirements of ASME B&PV Code,Section XI,1992 Edition, through the 1992 Addenda of Subsections IWE and IWL into 10 CFR 50.55a.

Adopting the requirements of 10 CFR 50.55a creates conflict with some Technical Specifications as they are currently written, and makes other Technical Specifications redundant to 10 CFR 50.55a.

The proposed changes do not involve modifications to any system, structure, or component. The changes are to ensure compliance with 10 CFR 50.55a by modifying the Technical Specifications to defer to the requirements of the ASME B&PV Code,Section XI,1992 Edition, through the 1992

. Addenda of Subsections IWE and IWL, as modified and supplemented by 10 CFR 50.55a. The Containment Buildings are passive safety structures designed to prevent the release of radioactive 1

. i l

ATTACHMENT (1) .

1 DESCRIPTION AND JUSTII'iCATION OF PROPOSED CllANGE materials to the environment. The Containment Buildings are not analyzed as causal factors in accidents involving the loss of radioactive material from th" Reactor Coolant System.

4 Containment Building imegrity is essential to the containment function. Periodic inspections and tests of Containment integrity ensure the maintenance of this integrity.

CONCLUSION We request that the Nuclear Regulatory Commission grant our proposed amendment to the Calvert Cliffs Technical Specifications. The proposed changes remove redundancies with regulations, and allow full compliance with 10 CFR 50.55a. The Plant Operations and Safety Review Committee and the Offsite Safety Review Committee have determined that the proposed changes do not result in undue risk to the public health and safety.

1 1

i l

l 2

.-'. . . . . - .- . . . . - . _ . . - . . . . ..~. ._ . _.. . . - . . . . . _ . . . - - - . . . . _ .

3 .

4 a

i ATTACHMENT (2) i 1

i i

i i

i e

1 9

DETERMINATION OF SIGNIFICANT IIAZARDS i-e iJ i

I i

i i

i 1

i l'

Baltimore is and Electric Company

' Calvert 'J.';;;. .'idclear Power Plant November 70,1998

4 ATTACIIMENT (2)

DETERMINATION OF SIGNIFICANT IIAZARDS DETERMINATION OF SIGNIFICANT HAZARDS The proposed changes have been evaluated against the standards in 10 CFR 50.92 and have been i

determined to not involve a significant hazards consideration, in that operation of the facility in J

accordance with the proposed amendments:

1. Would not involve a sigmficant increase in the probability or consequences of an accident previously evaluated.

The Containment Building is a passive safety structure that prevents the release of radioactive

, materials to the environment in post-accident conditions. The proposed Technical Specification

, changes delete requirements of the Technical Specifications that have been made obsolete by the improvements of the Containment Building inspections required by the changes in the

, regulations. The improved inspections required by the American Society of Mechanical

. Engineers Code serve to maintain Containment response to accident conditions, by causing the identification and repair of defects in the Containment Buildings.

Relocating existing requirements, eliminating requirements that duplicate regulations, and making administrative improvements provide Technical Specifications that are easier to use.

Because existing requirements are controlled by regulation, there is no reduction in commitment l and adequate control is still maintained. Likewise, the climination of requirements that duplicate  !

regulations enhances the usability of the Technical Specifications without reducing J commitments. Therefore, the proposed changes would 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 different type of accident from any accident previously evaluated.

The Containment Building in a passive safety structure designed to contain radioactive materials 3 released from the Reactor Coolant System. The performance of the Containment Building is not l evaluated as the causal factor in any accident at Calvert Cliffs Nuclear Power Plant. The i proposed Technical Specification changes delete requirements of the Technical Specifications that have been made obsolete by the improvements of the Contcinment Building inspections I I

required by the changes in the regulations. Revising the Technical Specifications, to comply with current regulations and to eliminate duplication of requirements, does not create the possibility of a new or different type of accident from any accident previously evaluated.

3. Would not involve a sigmficant reduction in a margin ofsafety.

The safety function of the Containment Building is to provide a boundary to the release of radioactive material to the environment during post-accident conditions. The changes to the Technical Specifications incorporate improved inspection techniques and criteria to ensure optimum Containment integrity and, therefore, optimum containment response in the event of an accident resulting in a release of radioactive material from the Reactor Coolant System.

Optimizing containment integrity will result in maintaining the margin of safety allowed by the Containment Buildings. Therefore, the proposed changes will not involve a significant reduction in a margin of safety.

I

l ATTACHMENT (3)

UNITS 1 & 2 MARKED-UP TECHNICAL SPECIFICATION PAGES

]

I i

l Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Novemher 20,1998