ML20079A577
| ML20079A577 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/24/1995 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20079A581 | List: |
| References | |
| NUDOCS 9503010264 | |
| Download: ML20079A577 (11) | |
Text
t RO~ EIT E. DENTON -
Baltimore oas and Electric Company Calvert Cliffs Nuclear Power Plant Vice President 1650 Calvert Cliffs Parkway Nuclear Energy Lusby, Maryland 20657 410 586-2200 Ext.4455 local 410 260-4455 Baltimore February 24,1995 U. S. Nuclear Regulatory Commission Washington, DC 20555 i
ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit No. 2; Docket No. 50-318 Application for Temporary Exemption from 10 CFR Part 50, Appendix J and License Amendment Request; Administrative Change to Technical Specifications to Reflect Exemption from Tvoc A Testina Frequency Reauirement
REFERENCES:
(a)
Letter from Mr. D. H. Jaffe (NRC) to Mr. A. E. Lundvall, Jr. (BGE),
dated January 8,1986, Exemption from 10 CFR Part 50, Appendix J, and License Amendment No. I12 and 95 (b)
NUREG-1432, " Standard Technical Specifications - Combustion Engineering Plants," dated September 1992 (c)
Draft NUREG-1493, " Performance-Based Containment Leak-Test Program," dated December 1994 Baltimore Gas and Electric Company hereby requests temporary relief from the schedular requirements for performing a Type A test during the upcoming Unit 2 refueling outage. Accordingly, we request a one-time temporary exemption from 10 CFR Part 50 Appendix J, paragraph III.D.I.(a), Periodic Retest Schedule, pursuant to the provisions of 10 CFR 50.12. In conjunction with this temporary exemption, and pursuant to 10 CFR 50.90, we request an amendment to Operating License No. DPR-69 by incorporating the changes described below into the Technical Specifications for Calvert Cliffs Unit No. 2.
DESCRIPTION Baltimore Gas and Electric Company requests two exemptions from 10 CFR Part 50, Appendix J, paragraph lli.D.I.(a), " Type A Periodic Retest Schedule." The first exemption would allow a one-time 010027 Ob 9503010264 950224 PDR ADOCK 05000318
FT Document Control Desk February 24,1995 Page 2 extension of the interval between the first and second Type A test during the second ten-year service period, and the second exemption would extend the second service period to twelve years to coincide with our 1999 plant inservice inspection. The temporary exemption would result in a six-year interval between the first and second Type A tests, with the second Type A test to be performed et the 1997 refueling outage instead of the 1995 refueling outage as currently scheduled. The third Type A test can be performed during the 1999 refueling outage, coincident with the end of the ten-year inservice inspection interval. The net effect of these exemptions is that the three tests during the current service period will be separated by intervals which are not "approximately equal."
The proposed change to the Calvert Cliffs Unit 2 Technical Specifications would revise Specification 4.6.1.2.a such that it would reference 10 CFR Part 50, Appendix J directly, and any approved exemptions to the Type A testing frequency requirements, rather than paraphrase the regulation.
The proposed wording is consistent with that used in NUREG-1432, Reference (b).
IIACKGROUND The purpose of Appendix J leak test requirements, as stated in the Introduction to 10 CFR Part 50 Appendix J, is to " assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment." This exemption request concerns part (a) of the stated purpose of Appendix J. Part (b) of the stated purpose of Appendix J applies to pc'ictrations and isolation valves, which are tested by Type B and C Local Leak Rate Tests (LLRTs) and are not affected by this licensing action.
The Type A testing frequency is addressed in the following portion of Appendix J, paragraph lil.D.I.(a):
"Three Type A tests shall be performed, at approximately equal intervals during each 10 year senice period. The third test of each set shall be conducted when the plant is shutdown for the 10-year plant insenice inspections."
At Calvert Cliffs, the Type A test is performed by pressurizing the containment structure to the postulated peak accident pressure of 50 psig. The containment is maintained at this pressure while measuring the leakage rate out of the containment. The test is concluded when it is determined, within a 95% upper confidence limit, that containment leakage is less than 75% of the containment allowable leakage limit.
J)escription of Containment The Calvert Cliffs Unit 2 containment structure consists of a 130-foot diameter reinforced concrete cylinder and a shallow domed roof. The inside height of the structure, including the dome, is 181 feet - 8 inches.
The containment free volume is 2x10' cubic feet. The thickness of the reinforced concrete base is 10 feet and the minimum thicknesses of the cylindrical side wall and dome are 3 feet - 9 inches and 3 feet - 3 inches, respectively. The inside of the structural concrete is lined with 1/4-inch minimum
Document Control Desk February 24,1995 Page 3 j
i thickness steel plate attached to the concrete by means of an angle grid system stitch-welded to the hner plate and embedded in the concrete. The frequent anchoring is designed to prevent significant distortion of the liner plate during accident conditions, and to insure that the liner maintains its leak-tight integrity. The bottom horizontal liner plate is covered with approximately I foot - 6 inches of concrete, the top of which forms the Door of the containment. All penetrations made in the structure have been considered as potential leak sources and as such are designed to withstand full containment accident pressure. Further information on the containment design can be found in Section 5.1 of the Calvert Cliffs Updated Final Safety Analysis Report.
IIistorical Type A Testine Results i
Five Type A tests have been perfonned to date and considerable margin exists between the Type A test results and the Technical Specification 4.6.1.2.b limit of 75% L,,m where L,is equal to 0.20% by weight of the containment atmosphere in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at a peak accident pressure of 50 psig. The results of these tests demonstrate that Calvert ClilTs Unit 2 is a low leakage containment, and that there is reasonable assurance that contamment leakage would not approach the leakage assumed in the accident analyses.
The data from each of these tests was analyzed using the total time leakage rate method. All Type A tests were performed at a minimum test pressure of 50 psig. The results of the individual Type A tests for Calvert Cliffs Unit 2 follow:
Pre-Operational Type A Test The pre-operational Type A test was successfully completed on April 14, 1976, resulting in a calculated total time leakage rate of 0.019 weight percent per day, with a 95% upper confidence limit (UCL) of 0.057 weight percent per day.
First Periodic Type A Test The first periodic Type A test initially failed because of excessive leakage through three sources:
(1)the containment recirculation sump isolation valve, MOV-4145; (2) the temporary level indicators on the steam generators; and (3) the packing gland of a main steam line inboard vent valve. The corrective actions and subsequent leak test history of these components is described below.
The first leakage source was icbnti6cd as a problem with the limit switch settings on MOV-4145 that prevented full closure. Resetting the switches and closing the valve electrically corrected that source of leakage. This valve is now tested periodically to ensure the limit switch settings allow full closure, and this valve has not demonstrated excessive leakage in any subsequent Type A tests.
10 CFR Part 50, Appendix J, Section II.K defines the acceptable leakage limit L, as, "
the maximum allowable leakage rate at piessure P,, [ calculated design basis accident peak containment pressure] as specified for preoperational tests in the technical specifications or associated bases, and as specified for periodic tests in the operating license."
Document Control Desk February 24,1995 Page 4 b
l The second source of leakage, the temporary level indicators, are components which are only in l
place while the plant is shutdown. Upon identification of this leakage path, the temporary configuration was isolated and has not resulted in further leakage. The third component condition which led to an excessive leakage rate during this test was attributed to a packing failure in the main steam inboard vent valve. This condition was corrected by backseating the valve to eliminate leakage. In a subsequent refueling outage, the vent valves were removed and the connection was scaled with a blind flange.
Following the actions listed above, the Type A test was successfully completed on November 15,1979. The calculated total time leakage rate was 0.028 weight percent per day with a 95% UCL of 0.128 weight percent per day.
4 Second Periodic Type A Test The second periodic Type A test was successfully completed on December 23, 1982. The calculated total time leakage rate was 0.016 weight percent per day with a 95% UCL of 0.071 weight percent per day.
Third Periodic Type A Test l
The third periodic Type A test was successfully completed on November 24,1985. The calculated total time leakage rate was 0.050 weight percent per day with a 95% UCL of 0.104 weight percent per day.
Fourth Periodic Type A Test The fourth periodic Type A test was successfully completed on January 16, 1991. The calculated total time leakage rate was 0.036 weight percent per day with a 95% UCL of 0.118 weight percent per day. This was the first Type A test in our second ten-year service period, which began in 1987.
I Baltimore Gas and Electric Company is scheduled to perform the fifth periodic Type A test on the Calvert l
Cliffs Nuclear Power Plant Unit 2 containment during the upcoming refueling outage, which is scheduled to begin on March 17,1995. This test will constitute the second of three Type A tests to be performed in the second ten-year service period. We are requesting an exemption to allow us to perform this second Type A test during the subsequent Unit 2 refueling outage in 1997. Postponement of this test will result in significant cost savings, while past test results provide conf:dence that the underlying purpose of the rule is achieved.
REOUESTED CilANGE Change Technical Specification 4.6.1.2.a, Primary Containment / Containment Leakage, as shown on the marked-up pages in Attachment (1). The change revises the surveillance frequency requirement from "Three Type A tests.
.at approximately equal intervals..during each ten-year service period" The l
Document Control Desk February 24,1995 Page5 revised specification refers to "10 CFR Part 50, Appendix J, as modified by approved exemptions" for the frequency of Type A testing.
SAFETY ANAINSIS 4
The function of the containment structure is to minimize release of radioactive material to the environment should a serious failure of the RCS occur. The structure provides adequate radiation shielding for both l
normal operation and accident situations. The principal design basis for the containment is that it be capable of withstanding the intemal pressure resulting from a loss-of-coolant accident with no loss of integrity. To support the assumptions made in the maximum hypothetical accident analysis in the Calvert Cliffs Updated Final Safety Analysis Report, Chapter 14.24, the containment is designed for a maximum of 0.20% per day leakage by weight of the original content of air at a design pressure of 50 psig. The Type A, B and C tests verify that this assumption remains valid throughout the life of the plant.
Factors affecting leak-tightness of containment may be categorized as: 1) active components which are leak rate tested by Type B and C tests; and 2) passive components which constitute the containment structure and are tested during the Type A test. Industry experience indicates that 97% of the failures associated with Type A tests are found to be due to Type B and C tested penetrations [ Reference (c)]. The existing Type B and C testing programs are not being modified by this request and will continue to effectively detect containment leakage caused by the degradation of active containment isolation components (e.g., valves) as well as scaling material within containment penetrations. Therefore, continued overall leak tightness of the active containment components can be assured by the existiag Type B and C testmg program.
Two mechanisms could adversely affect the passive structural capability of containment. The first is deterioration of the structure due to pressure, temperature, radiation, chemical, or other such effects.
Secondly, modi 6 cations can be made to the structure which, if not carefully controlled, could leave the structure with reduced capability.
Absent actual accident conditions, stmetural deterioration is a gradual phenomenon requiring periods of time well in excess of the proposed interval extension. Other than accident conditions, the only pressure challenge to containment is the Type A test, itself. 10 CFR Part 50, Appendix J, Section V.A requires a general inspection of accessible interior and exterior surfaces of the containment structures and components to be performed prior to any Type A test to uncover any evidence of structural deterioration which may affect either the containment structural integrity or leak tightness. At Cahcrt Cliffs no evidence of structural deterioration that would affect containment structural integrity or leak tightness has been observed, and the scheduled containment visual inspection will still be performed during the upcoming refueling outage.
Modifications that would alter the passive containment structure are infrequent and receive extensive review to ensure containment capabilities are not diminished. The Calvert Cliffs design change program is effective in providing a high quality oversight of such safety-significant modifications. In addition, 10 CFR Part 50, Appendix J, Section IV.A, requires a Type A, Type B, or Type C test, as applicable, to be performed following any major modification to the primary containment boundary. This requirement will be maintained.
Document Control Desk February 24,1995 Page 6 Risk Assessment The risk of contaimnent structural degradation is that a pathway for radionuclides could be created if the containment is challenged, such as in a loss-of-coolant accident or severe accident. Such leakage does not create any new accident scenarios, nor does it contribute to the initiation of any accident.
From a risk standpoint, the purpose of Appendix J leak testing is to detect any containment leakage resulting from failures in the containment isolation boundary before an accident occurs. Such leakage could be the result ofleakage through containment penetrations, through airlocks, or through containment structural faults. The Appendix J Type B and C tests, which are unafrected by this proposed change, will continue to detect leakage through containment valves, penetrations, and airlocks. The only potential failures that would not be detected by Type B and C testing are mechanical failures of the containment (i.e., degradations or modifications to the containment). Thus, the only potential effect of the proposed one-time change to the Type A test frequency is the possibility that contaimnent structural leakage would go undetected between tests.
As described in the preceding section, passive failures resulting in containment structural leakage in excess of that assumed in the accident analyses are extremely unlikely to develop between Type A tests.
Postulated containment failure under severe accidem conditions is primarily due to phenomenological effects associated with severe accidents. Such efTects were considered as part of the Calvert Cliffs Unit 2 Individual Plant Examination (IPE). Increasing the testing interval is unlikely to affect the containment failure probabilities calculated for the IPE.
Draft NUREG-1493, Reference (c), includes the results of a sensitivity study performed to explore the risk affect of several alternate leak rate testing schedules. Based on information provided in Reference (c), the increased risk to the general population due to radiation dose attributable to extending the test interval from three to five years would be extremely small. Another alternative addressed in this study is extending the Type A testing frequency from three in ten years, to one in ten years. Using best estimate data, Reference (c) concludes that the increase in risk to those in the vicinity of the five representative plants ranged from 0.02 to 0.14%. This very low effect on risk is attributable to: 1) the efTectiveness of Type B and C tests in identifying potential leak paths (about 97%); 2) a low likelihood of Type A test-identified leakages in excess of two times allowable; and 3) the insensitivity of risk to containment leak rate (e.g., no discernible increase in population dose risk with containment leak rates 100 times greater than currently allowed). This led the authors of Reference (c) to conclude that even decreasing the Type A testing frequency to once per twenty years would " lead to an imperceptible increase in risk."
The exemption requested for Calvert Cliffs Unit 2 is concluded to be bounded by the analyses of Reference (c) because the requested exemption would result in a one-time test interval of six years; not twenty or even ten years. Furthermore, the proposed one-time increase in the Type A testing interval will not affect the containment failure probability calculated in the Calvert Cliffs IPE. As such, Baltimore Gas and Electric Company believes that there is sufficient information in the Reference (c) and the Calvert Cliffs IPE to conclude that the risk increase from the requested exemption is low and that the value, in terms of i
enhancing public safety, of performing the Type A test in 1995 is extremely low.
The testing history, structural capability of the containment, and the risk assessment previously established that Calvert Cliffs Unit 2 has had low containment leakage rates, that the structural integrity of the
Document Control Desk February 24,1995 Page 7 containment is assured, and that there is negligible risk associated with changing the Type A test schedule on a one-time basis. Therefore, it is concluded that the requested exemption will not present an undue risk to the public health and safety.
Tile REOUIREMENTS OF 10 CFR 50.12 ARE MET The standards set forth in 10 CFR 50.12 provide that specific exemptions may be granted which:
+
are authorized by law;
+
are consistent with the common defense and security;
+
will not present an undue risk to the public health and safety; and
+
are accompanied by special circumstances.
Baltimore Gas and Electric Company believes that the activities to be conducted under the temporary exemption are clearly authorized by law and are consistent with the common defense and security. The remaining standards for the temporary exemption are also satis 6cd, as described below.
No Undue Risk As discussed in the Safety Analysis section, this temporary exemption will not present an undue risk to the public health and safety.
Special Circumstances This request involves special circumstances as set forth in 10 CFR 50.12 (a)(ii). The underlying purpose of 10 CFR Part 50, Appendix J is still achieved. Appendix J states that the leakage test requirements set forth in this appendix provide for periodic verification by tests of the leak-tight integrity of the primary reactor containment. The appendix further states that the purpose of the tests is to assure that leakage through the primary reactor containment shall not exceed the allowable leakage rate values as specified in the Technical Specifications or associated Bases.
10 CFR Part 50, Appendix J, paragraph Hl.D.I.(a) states that a set of three periodic tests shall be performed at approximately equal intervals during each ten-year period, and that the third test shall be conducted when the plant is shutdown for the ten-year plant insenice inspections. The second ten-year period for Calvert Cliffs Unit 2 will end with the 1997 Unit 2 outage; however, the ten-year plant inservice inspection period is not concluded until the 1999 Unit 2 outage. (In accordance with the ASME Boiler and Pressure Vessel Code,Section XI, IWA-2400, units that are out-of-senice continuously for six months or more may extend an insenice interval for a period equivalent to the outage. Therefore, for Calvert Clifts Unit 2, our second insenice interval will be extended for approximately two years to account for our 1989-199l outage.) Therefore, the intent of the regulation, for the ten-year Type A testing period to coincide with the ten-year inservice inspection period, will not be met without this exemption.
l l
Document Control Desk February 24,1995 Page 8 l
This exemption request does not affect the periodic schedule for Type B and C tests, which will continue to l
be perfonned in accordance with Appendix J, and approved exemptions. Demonstrated operability of the associated components and penetrations through Type B and C tests adds assurance that the overall Type A leakage rates remain satisfactory. No leakage trends have been identified to indicate that l
containment leakage would exceed that assumed in the accident analyses prior to the 1999 Type A test.
l There is no signincant change in the types or increase in the amounts of any effluents that may be released offsite due to the extension of the interval between the first and second Type A tests during the second ten-year interval. This one-time change does not affect the design basis of the plant and would not affect the response of containment during a design basis accident.
i Based on the above, there is significant assurance that the extended interval between Type A tests will l
continue to provide periodic verification of the leak-tight integrity of the containment. Therefo-e, the underlying purpose of 10 CFR Part 50, Appendix J is still achieved.
DETERMINATION OF SIGNIFICANT IIAZARDS The proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to not involve a significant hazards consideration, in that operation of the facility in accordance with the proposed amendments:
I.
Wotdd not involve a significant increase in the pro.5 ability or consequences of an accklent previously evahiated.
The proposed change revises Technical Specification 4.6.1.2.a to reference the testing frequency requirements of 10 CFR Part 50, Appendix J, and to state that NRC-approved exemptions to the applicable regulatory requirements are permitted. The current Technical Specificatien 4.6.1.2.a paraphrases the requirements of Appendix J, paragraph III.D.I.(a) and necessitates a change to the Technical Specifications should the Appendix J language change or an exemption be granted. The proposed administrative revision simply deletes the paraphrased language and directly references Appendix J and any approved exemptions. No new requirements are added, nor are any existing requirements deleted.
Any specific exemptions from the requirements of Appendix J, paragraph lli.D.I.(a) will continue to require a submittal from Baltimore Gas and Electric Company under 10 CFR 50.12 and subsequent review and approval by the NRC prior to implementation.
The proposed change will provide a one-time exemption from the 10 Cl R Part 50, Appendix J, paragraph Ill.D.I.(a) leak rate test schedule requirement. This change will allow for a one-time interval between subsequent Type A tests of approximately 72 months. It will also extend the second ten-year Type A testing service period to 12 years to coincide with the inservice inspection interval.
l No physical or operational changes to the structure, plant systems or components would be made l
as a result of the proposed change. Furthermore, leak rate testing is not an initiating event in any accident, therefore this proposed change does not involve a significant increase in the probability of any accident previously evaluated.
l
Document Control Desk February 24,1995 Page 9 Type A tests are capable of detecting containment leaks through containment penetrations and j
through the containment liner. The history at Calvert Cliffs Unit 2 demonstrates that Type B and i
C Local Leak Rate Tests (LLRTs) have consistently detected leakage through penetrations. With the exception of the first periodic Unit 2 Type A test in 1979, which failed and was promptly corrected, Type A tests have not detected excessive leakage from the containment.
Administrative controls govern the maintenance, modification and testing of containment penetrations such that the probability of excessive penetration leakage due to improper maintenance or valve misalignment is very low. Following maintenance or modifications to any containment penetration, a leak rate test is performed to ensure acceptable leakage levels.
Following any LLRT on a containment isolation valve, an independent valve alignment check is performed. Therefore, Type A testing is not necessary to ensure acceptable leakage rates through containment penetrations.
While Type A testing is not necessary to ensure acceptable leakage rates through containment penetrations, Type A testing is necessary to demonstrate that leakage through the containment liner is within limits assumed in the accident analyses. Structural failure of the containment is considered to be a very unlikely event; and in fact, since Calvert Cliffs Unit 2 has been in operation, the Type A tests have demonstrated no evidence that containment leakage will exceed that assumed in th: cccident analyses prior to the 1999 Type A test. Therefore, a one-time exemption increasing the interval between subsequent Type A tests will not result in a signi6 cant degradation in our ability to determine the leak-tightness of the containment structure.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
1 2.
Waidd not create the possibility of a new or different type cf accident frotn any accident previously evaluated The proposed Technical Specification amendment is administrative and will not create the possibility of a new or different type of accident from any accident previously evaluated.
(
The proposed exemption request does not affect normal plant operations or con 6guration, nor does l
it affect leak rate test methods. The proposed change allows a one-time test interval of l
approximately 72 months for the Type A tests. As the test histoiy of Calvert Cliffs Unit 2 has demonstrated no evidence that containment leakage will exceed that assumed in the accident analyses prior to the 1999 Type A test, the relaxation in schedule should not signi6cantly decrease the con 6dence in the leak-tightness of the containment.
The proposed change would not change the design, con 6guration or method of operation of the plant. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
s Document Control Dcsk February 24,1995 Page 10 3.
Would not involve a significant reduction in a margin ofsafety.
The purpose of the existing schedule for Type A tests is to ensure that the release of radioactive materials will be restricted to those leak paths and leak rates assumed in accident analyses. A one-time extended interval between successive Type A tests does not change any frequency or methodology requirements for Type B and C LLRTs. Therefore, methods for detecting local containment leak paths and leak rates are unaffected by this proposed change. Given that the problems identified by the first periodic Type A test were promptly and effectively resolved, and the subsequent Type A test history for Urit 2 shows no containment degradation-related failures, a one-time increase of the test interval doce not lead to a significant probability of creating a new leakage path or increased leakage rates.
The proposed Technical Specification change is administrative and eliminates the redundancy between the requirements of Technical Specification 4.6.1.2.a, and 10 CFR Part 50 Appendix J, including any approved exemptions to Appendix J. It does not, in itself, change a safety limit, a Limiting Condition for Operation, or a surveillance requirement on equipment required to operate the plant.
The NRC must approve any proposed change or exemption to Appendix J, paragraph Ill.D.I.(a) prior to implementation. As the proposed change does not affect the Type A test acceptance criteria, the margin of safety inherent in existing accident analyses is maintained.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
ENVIRONMENTAL ASSESSMENT The proposed exemption and license amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR Pan 20, or changes to an inspection or surveillance requirement. We have determined that the proposed license amendment involves no significant hazards considerations, and that operation with the proposed surveillance frequency would result in no significant change in the types or significant increases in the amounts of any effluents that may be released offsite and in no significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed licensing action is eligible for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental affect statement or erwironmental assessment is needed in connectim with the approval of the proposed exemption and license amendment.
SCilEDULE The Unit 2 Type A test is ccrrently scheduled to be performed during the next refueling outage, which is currently scheduled to begin on March 17,1995. The Type A test is scheduled to begin on April 26,1995.
Staging for the test is scheduled to begin on April 11, 1995. Therefore, we request approval of this
(
temporary exemption and license amendment by April 11,1995.
Document Control Desk February 24,1995 Page1I 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 Offsite Safety Review Committee. They have concluded that implementing these changes will not result in an undue risk to the health and safety of the public.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
[r 2&
STATE OF MARYLAND
- TO WIT:
COUNTY OF CALVERT I hereby certify that on the O day of b bru a ru
,196 before me J /b/w< J- /b, n L, the subscriber, a Notary Public of the State of Maryland in and for
~~
. personally appeared Robert E. Denton, being duly sworn, and states that he is Vice President of tWe 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 of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
WITNESS my lland and Notarial Scal:
80 o 2 dim eo !(AU/L)
) Notary Public ' F
~~
(
i c2 i 4 <T My Commission Expires:
' ' bate RED /EMT/ dim
Attachment:
(1)
Unit 2 Technical Specification Marked-Up Page l
cc:
D. A. Dnme, Esquire
~
J. E. Silberg, Esquire L. B. Marsh, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC 4
R. I. McLean, DNR J. II. Walter, PSC
.