ML20081L731

Suppl to 910524 Application for Amends to Licenses DPR-53 & DPR-69,changing Tech Specs Per Guidance in Generic Ltr 90-09 Re Alternative Requirements for Snubber Visual Insp Intervals

ML20081L731
Person / Time
Site:	Calvert Cliffs
Issue date:	07/01/1991
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-90-09, GL-90-9, NUDOCS 9107080043
Download: ML20081L731 (3)

Text

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g D A LTIMORE GAS AND ELECTRIC CHARLES CENTER

• P.O. BOX 1475

• BALTIMORE, MARYLAND 21203-1475 GroRot C CRttt v e c F.t ot,r e "d u t t t a p [ 6.g a G y

%,,o..n July 1,1991 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATl'ENTION: Document Control Desk SUlUECT: Calvert Cliffs Nuclear Power Plant Un:t Nos.1 & 2: Docket Nos. 50-317 & 50-318 Supplement to Request for Amendment

REFERENCES:

(a) 1. citer from hit. G. C. Creel (BG&E) to Document Control Desk (NRC), dated hiay 24,1991, Request for Amendment Gentlemen:

On hiay 24,1991, Baltimore Gas and Electric Company requested an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Cahcrt Cliffs Unit Nos.1 & 2, respectively. This Request for Amendment was based on the guidance provided in Generic Letter 90-09, "Ahernative Requirements for Snubber Visual Inspection Intervals and Corrective Actions," but did not include all of the changes proposed by the Generic Letter. Tnis supplement provides additionalinformation regarding the bases for not including those items and supports a conclusion that the referenced request accomplishes the intent of the Generic I etter.

The referenced submittal provided the following paragraph to indicate that some items from the Generic Letter were not being requested:

The Generic Letter proposed three changes to Surveillance Requirement 4.7.8.1.b.

However, these items are not requested to be incorporated for the following reasons.

First, Cab ert Cliffs pcrsonnel prefer the cunent wonling with regard to action to be taken for a suspect snubber. The cunrnt wording is considered to precisely describe the impact on operability and the required actions to be taken. Second, the wonis of the Generic Letter regarding snubbers connected to common hydraulic fluid reservoirs are not included since the Cah ert Chfp design does not include safety-related snubbers l connected to a common hydnndicjhad reservoir. Final.'y, the cunent descriptian of the l required evaluation is maintained to retain the additional details regarding scope and purpose of the evaluation.

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Document C<mtrol Desk

• July 1,1991 Page 2 The following information is provided to supplement this statement. c The Generic letter proposed three additional changes to Surveillance Requirement 4.7.8.1.b.

Ilowever, these items are not requested to be incorporated for the reasons discussed below.

First, Calvert Cliffs has not adopted the classification of " unacceptable" for snubbers which do not satisfy the visual inspection acceptance criteria. Calvert Clifts will continue to conservatively consider these snubbers inoperable until determined otherwise. Considering the snubbers as inoperable precisely prescribes the required actions to be taken. Our staff does not feel comfortable with classifying a snubber as " unacceptable" and not identifying the immediate impact on operability of the snubber. His classification results in only'a minor, conservative difference in operation from the method using the classification " unacceptable.'

Second, the words of the Generic Letter regarding snubbers connected to common hydraulle fluid resenuits are not included since the Calvert Cliffs design does not include safetyw: lated snubbers connected to a common hydraulic fluid reservoir. (Refer to Calvert Cliffs Unit 1 and Unit 2 Operating License Amendment Nos.103, dated April 19,1984, and 73, dated May 16, 1985, respectively, for additional information.)

Finally, the current description of the required evaluation is maintained to retain the additional details regarding the scope and purpose of the evaluation. He wording pro >osed ir the Generic Ixtter requires only that "a review and evaluation shall be performed and (ocumented to justify continued operation . . . ." The current Calvert Cliffs requirement similarly requires an "enginecting evaluation," but also provides additional information regarding the scope and purpose of the ,

evaluation His item is also related to the use of the classification "unacceptabic." The evaluation pro >osed in the Generic letter is one which results in a determination of the operability of the snu 3ber, and it is not required to be completed within a specific time frame. Again, the Calvert Cliffs staff is not comfortable with identifying a snubber as unacceptable and not identifying an imrnediate impact on operability of the snubber. The current Calvert Cliffs specification declares the snubber  ;

inoperable and performs an evaluation on the supported component within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per the Action tatement of Technical Specification 3.7.8.1.

The changes which have been requested would fulfill the intent of the chai,ges proposed by the l Generic Letter. The Calvert Cliffs S3ccification, with the requested changes, would provide the alternative schedule for snubber visua; inspections bas:d on the number of unacceptable snubbers found during the presious inspection in proportion to the sizes of the various snubber po ,ulations or categories (as proposed by the Generic Letter), and wuuld provide for evaluation of snu ,bers which do not meet the visual inspection acceptance criteria. The only significant item from the Generic letter not requested is the use of an additional criteria of " unacceptable" for the snubbers which do not meet the visual inspection acceptance criteria.- Ilowever, Calvert Cliffs alternative would result .

in the conservative declaration of the snubber as inoperable and would proceed with the required l actions. These required actions for inoperable snubbers are not proposed for change in the Generic j letter or by our request.

There are other minor differences between the overall wording of the Model Specification and the Calvert Cliffs current Specification; however, these differences are not considered to impact the-intent of this change.

1

Document Control Desk

• July 1.1991 Page 3 l

The above information is provided to clar:fy the bases for not including portions of the complete change proposed by the Genetic Letter. This information does not affect the Significant llazards Consideration provided in the request since it does not revise the requested changes nor the supporting information for those changes, but discusses only the Generic Letter proposed changes which were nni requested.

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

Very truly yours, L

x BTATE OF MARYLAND t /

8 TO WIT COUNTY OF CALVERT I hereby certify that on the 2 day of _ ]Eu?d, ,191, before me, the subscriber, a Notary Public of the State of Maryland in and for da /ve r/ fouo/v ,

personally appeared George C, Creel, being duly sworn, and states that he is Vice' President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing information for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the information on behalf of said Corporation.

WITNESS my lland and Notarial Scal: '///4t*MI[t d.C/N, Notary Public My Commission Expires: wtcu-u 2. [9fk 17 ate GCC/ ERG!crg/ dim cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC L E. Nicholson, NRC R. I. McLean, DNR J. II. Walter, PSC