ML20118B524

Application for Amends to Licenses DPR-53 & DPR-69,revising TS 4.7.1.2.a.4 to Remove Requirements to Verify Valve Position Every 31 Days for Valves Locked,Sealed or Otherwise Secured in AFW Sys,Per NUREG-0212 (C-E STS)

ML20118B524
Person / Time
Site:	Calvert Cliffs
Issue date:	09/25/1992
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20118B525	List: ML20118B524 ML20118B526
References
RTR-NUREG-0212, RTR-NUREG-212 TAC-M69238, TAC-M69239, TAC-M69246, TAC-M69247, NUDOCS 9210050030
Download: ML20118B524 (4)

Text

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i B ALT IMORE GAS AND I

ELECTRIC l 1650 CALVERT CLIFFS PARKWAY e LUSBY, MARYLAND 20657-4702 GE OHGE C, CHE E L sevm vet emsum (410 200 3690 September 25,1992 U. S. Nuclear Regulatory Commission Washington, DC 20555 a ATiliNTION: Document Control Desk

SUBJECT:

Calvert Cliffs Neclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 License Amer.Jment Request

REFERENCES:

(a) Letter from Mr. J. A. Tiernan (BG&E) to NRC Document Control Desk, dated June 16,1988, Request for Amendment (b) Letter from Mr. D. G. Mcdonald, Jr. (NRC) to Mr. G. C. Creel (BG&E), dated June 10,1991, Issuance of Amendments for Calvert s Cliffs Nuclear Power Plant, Unit No.1 (TAC Nos. M69238 and M69246) and Unit No. 2 (TAC Nos. M69239 and M69247)

Gentlemen:

The ILdtimore Gas and Eicctric 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 proposed changes to the Technical Specifications.

DESCit tirl'lON The proposed amendment would revise the Technical Specifications for botn Units 1 and 2 to remove the requirement to verify valve position every 31 days for valves that are locked, scaled or otherwise secured in position in the Auxiliarv Feedwater System. This change is consistent with the requirements cf the Combustion Engineering Standard Technical Specifications (NUREG-0212, Revision 2).

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9210050030 920925 I 0#0QCf

)O PDR ADOCK 05000317 PDR k.

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h l I >ocurnent Control Desk September 25, IW2 l' age 2 ItAWGitOliNI)

('unently, Technical Specification 4.7.1.2 a 1 requires cath valve in the auxiliary Icedwater flow path be serified to be in its correct posi* ion every 31 days. The proposed change would exclude those vahes which are loc ke,1, scaled or otherwise secured in position. 'lhese valvcs are included in our progr.un that provides administratise control requirernents for locked valves. A copy of this procn huc w as prosided for your review of a similar Technical Specification change to the tontainment spray Surveillance itequircinents l Amendmerit requested in lle!crence (a) and approsed in Itclerence (b)) Valves which re locked, scaled or otherwise secured in position are currently escluded f rom the verification requirement ior the innergency Core Cooling System,

('ompon,:nt Cooling Water System, Service Water System. Sahwater Systern, and Containtnent Spray Systern Thk change makes the consideration of such vahes in the Technical Specilications -

mnshtent.

Iti;Qt 'l;S] l.lLEll ANGl; 5k k k . . . kk 4 -

k kI 8 m.u ked up pages att-hed to this uansmittal.

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} bC Ldet) lurictl(In (if tbc bu%klkary l' CdW'ner b{sICrn ks u) ICnMisC dCeay heat fr(un the lloachir Coolant ',guem f olloimp accitlents whic h msolve a loss of main Icedwater. In support of this tum tion, Technical Specificatim 4 7.1.2.aA requires each sake in the auxiliary feedwater llow path to be serilied to be in its correct position eve y 31 dap. The pioposed change would exclude those sakes which .uc locked, scaled or otherwise set uted in position. These valves are included in our piok edure that provides ad.ninistratise conual n , xments for locked valves. Valves which are locked, scaled or otherwise secu ed in position are aheady excluded from the verification -

requireme- lor the inneigency Core Cooling Sptem, Component Cooling Water System, Service Water Systc m. Saltwater Systein, amt Containment ' spray System. A locked, scaled or otherwise secmed valve gives equicalent assurance that the vahe vill remain in the correct position as the 31 day sonedlance doc- This change makes the consideration of such vahes in Technical 5perdications consistent. This change wdl abo make the Technical Specification consistent with the Standard "echnical Specilications for Combustion !!ngineering Pressurized Water lleactors (NUltH LO212, llevision 2). The pm,ition of these valves is administratively conuolled to minimize the probability of raispositioning. If they are delibeta9:ly taken out of their totLed, scaled or secu:ed posinon. the valves would tic checked on the surveillance requirement interval of Tl days.

1)l;l1.It%11NAflilOEQl' SIGNil 1(Mi llV.Altl)S The proposed change has been esaluated against the standards in m CI lt Wu and has been determineil to not involve a significant hazards consideration, in ' hat operation of the f acility in acondame with the proposed arnendment:

s, Document Control Desk Septernber 25,1W2 Tage 3

{1) .Would not imvive a significant increaw in the probability or turnequentes of an accident previously evaluated.

The safety function of the Ausiliary Feedwater System is to remove decay heat from the Reactor Coolant Setem following accidenu which involve a loss of main feedwater. In support of this function, Technical Specification 4.7.1.2.a.4 seguires each valve .o the auxiliary feedwater flow path be periodically verified to be in its correct position. The proposed change would exclude those valves which are locked, sealed or otherwise secured in position. These valves are included in our procedure that provides administrative control-requuerr:nta for kicked valves. A locked, scaled or otherwise secured valve gives equivalens assurance that the valve will remain in the wrrect position as the 31. day surveillance does.

This proposed change does no' affect accidents evaluated in lhe Updated Final Safety analysis Report (Ul%AR). No change b being made to any accident initiators, mitigation features or assumptions. 'lherefore, this proposed change does not involve a significant increase in the probability or cons quences of an accident previously evaluated.

(2) Inndd not create the pouibility of a new or different type of accident frans any accident '

previously evaluated, The proposed change does not represent a change in the configuration or operation of the plant. The valves affected by this change will remain in their current position. Therefore, j

this proposed change does not r:rcate the possibility of a new or different type of accid;nt from any accident presiomly evaluated.

(3) Would not imvive a significant reducion in a margin ofsafety, 4

Valves affected by this change are kicked, scaled, or otherwise secured in position prior to i entering the applicable operating conditions. Although this proposed change will remove the

, requirement that they be periodically verified, the adtninistrative co:.trols to bck, seal, or p otherwise secure them in position make this periodic verification requirement unnecessary. ,

A locked, scaled or otherwise secured valve gives equivalent assurance that the valve will-remain in the correct position as the periodie verificat on requirement does. The probability of inadvertent operation of these valves is very low, and adtriinist alive controls exist in procedures if any of these valves me removed f om their kicked, acated or otherwise secured condition. Therefore, this proposed change would not involve a significant reduction in a margin of safety.

ElIEDll6

'. This change is requested to be approved and issued by May 1, IW3. Ilowever, issuance of_ this j amendment is not currently identified as having an impact on outage completion or continued plant operation.

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, Document Control Desk Sc;.:cmher 25,1992

. Page 4 sal'IrlY COh1511'ITEE RINIEW These proposed changes to the Technical Specifications and our determination of significant hazards have been reviewed by our Plant Operations and Safety Review Committee and Off-Site Safety Review Committee, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.

Vet,j truly you , j STATE OF NARYLAND :

O( y TO WIT :

COUNTY OF CALVERT :

i hereb) :rtify that on the dM day of v 4214x/uJ ,1992, befo me, the subscriber, i

a Notary Public of the State of h1aryland'in and for /'afnja t [rhttIL ~

personally appeared George C Creel, being duly sworn, and sGites that he is Senior Vice' President of the Haltimore Gas and Electric Company, a corporation of the State of hiaryland; that he provides c the foregoing information for the purposes therein set forth; that the statements made are true and I

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: 'Ld <-

Notary Public

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l h!y Commission Expires: QAALLA% /, /h'7Y u Datd GCC/DJht/djm! dim 1

Attachments: (1) Unit 1 Technical Specification P.evised Page (2) Unit 2 Technical Specification Revised Page ec: D. A. Brune, Esquire J. E Silberg, Esquire R A. Capra, NRC D. G. AlcDonald, Jr., NRC l T. T. hf artin, NRC i L E. Nicholson, NRC R.1. hiclean, DNR i

J. II. Walter, PSC 1

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