ML20062D679

Application for Amends to Licenses DPR-53 & DPR-69,changing Tech Specs to Correct Inconsistencies & Incorporate Updated Bases Re Containment Integrity

ML20062D679
Person / Time
Site:	Calvert Cliffs
Issue date:	11/07/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20062D681	List: ML20062D679 ML20062D683
References
NUDOCS 9011150076
Download: ML20062D679 (5)

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BALTIMORE GASAND ELECTRIC CHARLES CENTER

• P.O. BOX 1475 e BALTIMORE. MARYLAND 21203 1475 Gtomor C. Catti VsCt Pat 61DtNT Nuctssa rwanov s (3 0s) #6 D-4 4 66 j November 7,1990 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk s

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket' Nos. 50-317 & 50-318 Reauest for Amendment to Operatinn Licenses Gentlemen:

The Baltimore Gas had Electric Company hereby requests an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos. I & 2, respectively, with the submittal of the . proposed changes to the Technical Specifications. This request _ will correct inconsistencies' between certain Calvert Cliff's Technical Specifications. provide clarifications and supplemental requirements, and incorporate updated bases for the affected specifications.

BACKGROUND The ' Calvert Cliffs Nuclear Power Plant (CCNPP) Technical Specifications were originally written based on an early version (Revision 2) of the Standard Technical Specifications lor Comhustion Engineering (CE) Pressurized Water Reactors (NUREG-0212). This version of the CE Standard Technical Specifications is the origin of the ACTION statements currently included in CCNPP Technical Specification Limiting Conditions for Operation (LCOs) 3.8.2.2 and 3.8.2.4, AC/DC Electrical Power Distribution Systems - Shutdewn.

These ACTION statements require that full CONTAINMENT INTEGRITY be established

- within eight hours of determining that the required complement of A.C. or D.C.

busses are not OPERABLE, CONTAINMENT INTEGRITY is defined, partially, in terms of Specifications 3.6.1.2, 3.6.l.3 and 3.6,4.1. These specifications are applicable only in MODES 1 through 4, and are not required to be met in MODES 5 and 6.

llowever, they are invoked

• through the ACTION statements of Specifications 3.8.2.2 and 3.8.2.4 for MODES 5 and 6 under certain conditions.

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i Document Ccntrol Desk November 7,1990 Page 2 This inconsistency in the manner with which the current Technical Specifications treat conditions regarding CONTAINMENT INTEGRITY has been the source of some confusion.

A later version of the Standard Technical Specifications (Revision 3) provided an ACTION that eliminated the requirement for CONTAINMENT INTEGRITY and replaced it with actions such as suspension of CORE ALTERATIONS, positive reactivity changes, and movement of irradiated fuel Revision 3 did not revise the BASES for the Technical Specifications in any way. This indicates a refined understanding of the actions necessary to ensure safe operation in the COLD SilUTDOWN and REFUELING MODES.

The requested change to the Technical Specifications and their Bases will provide for a more consistent interpretation of the requirements for containment isolation during COLD SilUTDOWN and REFUELING conditions, and will address some operating conditions identified subsequent to the adoption of the existing Technical Specifications.

The need for this change to the Technical Specifications is based on the impracticality of implementing full CONTAINMENT INTEGRITY during some conditions (such as during integrated leak rate testing or penetration modification) that occur during MODES 5 and 6.

BEOUESTED CilANGE In this proposed amendment, the ACTION statements for Technical Specifica-tions 3.8.1.2, 3.8.2.2 and 3.8.2.4 would be modified to replace the requirement to establish CONTAINMENT INTEGRITY with a containment penetration closure requirement.

These Technical Specifications would also be supplemented with requirements from the Standard Technical Specifications (Revision 3) and the latest draft of the forthcoming Restructured Standard Technical Specifications (

Reference:

J. Calvo to W. Itall, dated July 24, 1990) to require suspension of operations involving CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel and heavy loads over i irradiated fuel, and initiation of corrective actions to restore the power source or electrical distribution system within one hour. Technical Specification 3.9.4 would also be modified to be applicable during these operations.

DETERMINATION OF SIGNIFICANT IIAZARDS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant increase in the probabilby or consequences of an accident previously evaluated; or In MODES 1, 2, 3, and 4, a Design !! asis Accident could cause a release of radioactive material into the containment, in these MODES, prevention against the release of this material to the environment is accomplished by maintaining CONTAINMENT INTEGRITY, in MODES $ and 6; however, the

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Doe: ment Contr:1 Desk November 7,1990 Page 3 probability and consequences of these events are lower because of the reactor coolant system pressure and temperature limitations of these MODES.

A minimum complement of electrical power sources and distribution systems is established to assure adequate power for systems required to recover from a boron dilution event or fuel handling incident, as discussed in Updated Final Safety Analysis Report Sections 14.3 and 14.18, respectively.

A single power traln/ division is adequate in these lower MODES (5 and 6) because additional time is available to restore power before fuel damage occurs. Additionally, because of the lack of a containment pressurization potential, less stringent requirements . are needed to isolate the containment from the + tside atmosphere. These less stringent requirements are applied during CO? 1 ALTERATIONS, movement of irradiated fuel, and when the power distribution systems are degraded, as addressed in Technical Specification 3.9.4, ' Containment Penetrations". ,

With the number of energized A.C. or D.C. power distribution systems less than that required, sufficient power may not be available to recover from a fuel handling accident. Consequently, the ACTION statements require immediate suspension of CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel in the containment, and movement of loads over irradiated fuel within the containment. This precludes . the occurrence of I the postulated events and the need for CONTAINMENT INTEGRITY. Ilowever, ,

containment penetration closure is provided for additional mitigation of I unforet.een events. Therefore, there is no increase in the probability or consequences of any accident previously evalur6ted.

(11) create the possibility of a new or different type of accident from ,

any accident previously evaluated; or i

The proposed - changes will not represent a significant change in the configuration or operation of the plant. Specifically, no new hardware is being added to the plant as part of the proposed change, no existing equipment is being ' modified, nor are any significantly different types of operations . being introduced. The initiators of the accidents previously evaluated, boron dilution and fuel handling, have been reviewed with no -

impact identified. Other operations that are potential precursors to events L which are not currently addressed in the Technical Specifications would henceforth be precluded by the proposed amendment. Therefore, there is no possibility of the creation of a new or different type of accident.

(ill) involve a significant reduction in a margin of safety.

The Technical Specifications involved are based upon the need to prevent and/or control the consequences of a fuel handling incident or boron dilution event. The margin of safety is provided in the current Technical Specifications for these two events by requiring CONTAINMENT INTEGRITY to prevent the release of radioactive materials to the environment.

l- llowever, full CONTAINMENT INTEGRITY is not practical to achieve under

i I

l Doe:me;t Control Desk  ;

November 7,1990 Page 4 some conditions, e.g., during integrated leak rate testing or penetration modification. The revised Technical Specifications strengthen the controls l to prevent the design basis accidents while modifying the means specified for controlling the consequences of such accidents. A containment boundary -

will continue to be provided when there are operations being conducted '

which could lead to a fuel handling incident or boron dilution event.

Containment penetration closure is equivalent to CONTAINMENT INTEGRITY if electrical distribution under these circumstances. Additionally, systems' needed to mitigate the consequences of one of these events become '

inoperable, the proposed ; Technical Specifications would require suspension of such operations and the establishment of containment penetration closure, thereby removing the possibility of the event occurring, and mitigating any unforeseen events. Therefore, margin of safety against ,

release to environs is maintained because of sn equivalent barrier. Margin is then improved upon by new restrictions on activities that could lead to a challenge to the barrier, ,

SAFETY COMMITTEE REVIEW 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.

3 1-l ,

i

= Document Contrcl Desk November 7,1990 Page 5 Should you have any questions regarding this matter, we will be pleased to discuss them with you.

Very truly ur /

STATE OF MARYLAND  :

TO WIT :

COUNTY OF CALVERT  :

I hereby certify that on the day of fl

• L ,1 0, fore me, the subsgiber, a Notary Public of the State of Maryland in and for #

fMuda , 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:

Notary Public My Commission Expires:  !! '

Dat[ ,

GCC/ ERG / dim

' Attachments: (1) Unit 1 Revised Technical Specification; and BASES Pages (2) Unit 2 Revised Technical Specifications and BASES Pages '

cc: D. A. Brune Esquire ,

J. E. Silberg, Esquire l R. A.Capra, NRC  ;

D. G. Mcdonald, Jr., NRC 1 T. T. Martin, NRC L. E. Nicholson, NRC 1 R.1. McLean, DNR