IR 05000317/1990012

Insp Repts 50-317/90-12 & 50-318/90-11 on 900604-08.No Violations Noted.Major Areas Inspected:Activities Re Engineering Mods,Including Replacement of LPSI Pump Mechanical Seals & Changes to Salt Water Inlet Piping

ML20056A410
Person / Time
Site:	Calvert Cliffs
Issue date:	07/10/1990
From:	Carrasco J, Chaudhary S, Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20056A409	List: IR 05000317/1990012 ML20056A408
References
50-317-90-12, 50-318-90-11, NUDOCS 9008070252
Download: ML20056A410 (12)

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V. S. NUCLEAR REGULATORY COMMISSION REGION'I'

Report No /90-12 30-318/90-11 l

' Docket No License Nos. DPR-53 DPR-69 Licensee: Baltimore Gas and Electric Company I RD Rts 2&4, P.O. Box 1536 -.

Lusby, Maryland 20657 j

'l Facility Name: Calvert Cliffs Inspection At: Lusby, Maryland I Inspection Conducted: ' June 4-8, 1990

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Inspectors: 7 //4 /90

1. ,V/ K. Chaudhary, Sr. Reatt. r Engineer, date 1ateri 4 Pro ss e on, EB, DRS  ;

( J?????JC4 J. ES faffasco, Reactor Engineer, Mater uls llN & r i

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and Processes Section, EB, DRS l

Approved by: A '

R. Strosnider, Chief, Materials and 7/d//4 date rocesses Section, Engineering Branch, DRS Inspection Summary: Routine Unannounced Inspection on June 4-8, 1990 (Inspection Report Nos. 50-317/90-12 and 50-318/90-11)

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-i Areas Inspected: An inspection was performed of licensee activities related

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to engineering modifications. The modifications included the replacement of

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the LPSI pump mechanical seals and the changes to- the salt water inlet piping !

to ECC Results: No violations or deviations were identifie .

9008070252 900724 "

PDR ADOCK 0500031'7 o PDC

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I DETAILS 1.0 Persons Contacted i

1.1 Baltimore Gas and Electric Company ,

L. Larragoite Compliance Engineer  :

D. Muth Compliance Engineer

• M. Milbradt Compliance Engineer P. Katz G.S. Design Engineering

• E. Zumwalt Project Management Unit'

• R. Gambrill Projecr~ Management Unit R. Fretz Project Management Unit i D. Kennedy Mechanical Modifications

• S. Wolf Design Engineering *

• T. Camilleri Maintenance Superintendent

• G. Detter Dirtector-NRM  !

• J. Thop Senior Engineer .L

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G. Pavu Plant Engineering U.S. Nuclear Regulatory Commission

• L. Nicholson Senior ResidentzInspector

• Denotes those present during the exit meeting held on June 8,1990 2.0 Engineering Modification 88-31 LPSI Pump Mechanical Seal 'and heat exchanger replacement

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2.1 Purpose The purpose of this modification was to replaced existing-Durametallic *

Seals on the LPSI pumps 11, 12, 21 and 22 with a Borg-Warner Cartridge type seal assembly, j 2.2 Background The LPSI pumps, as a subsystem of the safety injection system, inject borated water into'the reactor coolant system'to supply' emergency coolin . LPSI Pump Mechanical Seal The existing seal features a non-cartridge type design and has a history of installation problems, such as difficulty in establishing correct alignment of the seal faces with the shaft. As a result, an' excessive-amount of leakage was detecte The new cartridge seal assembly j is preset to attach onto the shaft and lock into place. This '

design assures proper alignment reducing leakage past the shaft, decreasing maintenance time and increasing seal lif :

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Another technical consideration _for this seal replacement is the L fact that the high radiation dosage postulated-in the ECCS pump rooms following a LOCA may be detriniental to the secondary teflon seals within the seal. Based on this postulation, the new seal has four nonmetallic parts, all of which are 0-ring gaskets functioning as secondary seals. - They are fabricated fromi ethylene propylene elastomer (EPR) which has a radiation i tolerance of'1.0X-10' rads, ensuring'its suitability for,the

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ECCS pump room (Maximum expected radiation level following_ J LOCA is 3.6 X 103 rads).

2.2.2- Heat Exchanger Replacement The new larger capacity, upgraded

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Borg-Warner heat exchanger will provide a greater effective ;

cooling surface area required by the new seal design. This heat ;

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exchanger is capable of cooling 2 gpm of the working fluid;(borated 1 water) from 350 degrees F to about 161 degrees F before it ist i injected onto the seal faces, j 2. Piping Modification In order to accomodate the present modifica-

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tion, the component coolant water (CCW) supply and return lines: !

will be increase from 3/4 inch to;l inch in diameter. This will !

also. involve rerouting the CCW. supply. piping-to; provide branched- i paths to the new seal heat exchanger and pump bearings / stuffin j bo !

2.3 Technical requirements, purchase' order and QA surveillance '{

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The inspector reviewed the technical requirements for the mechanical l seals and the heat exchangers. These technical requirements are  ;

specified in licensee document numbered TDR - M - 1056, Rev. 4 which 1 includes design, performance, service, engineering documentation and- !

shipping / handling requirements. -Based on the technical requirements,. !

the inspector reviewed purchase order number 25880MX.whi_ch states- !

that the vendor, Borg Warner (BW), is approved to supply the seals on ,

this purchase order. The licensee's 'procuroment quality unit performed a Quality Assuranse surveillance prior to shipment of the seal and  ;

the heat exchanger to verify that these compoments,were built to an j approved QA progra The inspector also reviewed the-licensee's Quality Assurance surveil- i lance of the BW mechanical seals division. The surveillance, number ,

QA0 6640, was conducted at the BW facility in Temecula, California j on May 2, 1989. The purpose of this surveillance was to inspec replacement mechanical seals and spare parts and to verify that the

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parts and documentation met the requirements of the' licensee's QA progra The inspector did not identity any deficiencies in the licensee's Technical requirements and~ procurement documentation for- )

the LPSI pump seals and heat exchangers, j l

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2.4 Anchor Supports Design _ for LPSI Pumps 11 and 12 Seal Coolant Lines -

s The inspector reviewed calculation numbered M - 90 - 31 (Bechtel

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number P1203). The purpose of this calculation was to design anchor l- supports for the one inch diameter line on LPSI pumps 11 and 12. The- ,

estimated anchor loads were based on Bechtel pipe support design 1 L- guide M-18. The seismic loads were normalized to an acceleration l of 1.0 g, as shown in the response spectra generated for elevation l

(-)15'-0" of the auxiliary building. Therefore, the . dead weight was -

This is a conservative

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applied as a force in all 3 direction approach. The inspector, found this design approach acceptable, since _ ,

the equipment, structures and components at elevation (-)15'-0" respond as rigid bodies to a postulated seismic excitation. The inspector L -did not identify any deficiencies in the calculation. Therefore, l:

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based on the review of various engineering and procurement documentation and discussions with the responsible engineers, the inspector did not identify any deficiencies in the packag .0 Modifications to Salt Water Inlet Piping to ECCS, (FCR 85-851 3.1 Background The ECCS pump room coolers. receive cooling water from the salt water'

(SW) system through an eight inch diameter pipe. There is a strainer i assembly installed before the heat exchanger inlet to prevent foreign l- materials and debris from reaching and. clogging the tube s'ide of the heat exchangers. If the heat exchanger becomes clogged and does not

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function properly, there is a potential to exceed _the design tempera-

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ture of the ECCS pump rooms; thus, degrading performance of all ECCS l

trains that are housed in that particular pump roo Historically, there has been a problem with the strainers becoming:

clogged after a short service; sometimes, after-only one hour of'

operation. These strainers have been manually cleaned.to assure-operability of the system. However, the manual cleaning will not be

, possible in case of a design bases accident (LOCA) when the pump room l

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becomes a high radiation area. The room-temperature, without properly functioni.no coolers, could rise to 174 degrees F; thereby, jeopardiz-l ing the function of vi.ner safety related equipment in tho _ room, The- maximum design temperature for the pmp room is 120 degree F.

Roccgnizing the above concern, the licensee initiated a Facility Change-e Request (FCR 85-85) to modify the system by changing the suction of I the 8 inch diameter pipe from the bottom of the 30 inch line header to the side of the header to prevent and/or mitigate the transport of debris to the strainer, .thus, prolonging the reliable operation of the affected heat exchanger )

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In July of 1989,, the NRC issued a Generic Letter (89-13)' alerting licensees regarding the biofouling and clogging problems of service water system In response to the above concern, the licensee initiated a comprehensive program, and the FCR 85-85 became a sub part of this new progra .2 Findings The inspector reviewed the modification package, held discussions with the cognizant engineer and management personnel, and performed a-visual examination of the completed work. The inspector assessed the technical adequacy of the modification design and the adequacy of procedural and management controls ~ implemented by'the licensee to ,

assure an acceptable system. operatio ]

Based on the above. reviews, discussions and personal-observatior.'the inspector determined that the modification as designed (side o' ..

from the line header) is based on the assumption that larger pat c tles and other debris currently enter the 8 inch line due to .their ..[

concentration on th.e bottom of the header; hence, a side outlet from j the header would either eliminate or substantially reduce the entry i'

of debris in the heat exchanger tubing. However,.this rationale is not based on any test data or observation, and does not take into account that the velocity of water entering the 8 inch branch line may be capable of initiating a turbulence of sufficient magnitude to carry those particulates into the branch line. Also, even if the particulate transport is subst'antially reduced, it is-uncertain'that j1 this reduction will substantially improve the performance of.the

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I strainer. Therefore, it is necessary to collect performance-and j l operational data to ascertain the effectiveness of-the modificatio '

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The modification has not been completely implemented. Only one train (MC-6-2002,SWH-22) in unit _2 has been modified, and the system has f i

not been operated in the high risk season (bay temperature at;or abov ;

50 degrees F.) to determine the -performance of the system, and its {

effectiveness. Therefore, the acceptability and effectiveness of the- a modification remains unresolved pending review of operational and 1 functional data when they became available (UNR 90-11-01).  !

Additional observations made by the inspector regarding this

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modification are as follows: The nodification was implemented by the licensee through maintenance- 1 order (MO)- MO # 209-310-633A which included the' control work procedure CWP-85-085-M-5-II. -The work package reviewed by the !

inspector was complete with all the required documentation, review and proper approval of the work steps and inspections. The package '

also included material identification tags, although CMTR and other material acceptability were not in the package. Such

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documentation is controlled and filed separately under "R & R '

Plan Design Reconciliation Traveler" package. The inspector's reviewed of this traveler did not disclose any discrepanc "

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2, The engineering 'and design portion of the package was adequate - i to describe and support the design output for the modification,

, The inspectors, however, observed that the package was retained l- in the engineering' department files without formal procedural l- control-on the contents, access, inclusion or deletion of information, and revision of the design inputs received and retai,ved.in the file, The licensee representativer informed'th ~

inspector that the package is kept.open in the engineerint department until the completion of the modification, and then l

transmitted to document control for permanent retention, 1 l f

=The inspector noted that the above controls as applied on the design !

packages did not appear to provide adequate control over the~ access, j l content, and authority:to revise the information contained in these 1 l

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f i l e s'. A design modification package may remain open for several- !

_ years before it is closed, and may be' assigned to different responsible ;

engineers during its development and. implementation phase. The planned j audit at the end of the job is not an adequate control; since, the ;

auditor may not have the information, technical expertise, and a l l reference to judge ,the adequacy of the required information necessary !

for closure. The auditor would be at a disadvantage to determine:the validity of design inputs or their evolution, from internal and/or l external responsible-organization, if these inputs were revised and i the previous document or the new information was not included in the l

file due to personnel error or some.other cause, The licensee

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acknowledged this inadequacy and informed the. inspector that an !

index/ log for every design package would be prepared and formally .

controlled to establish the contents of'the package, This index/ log I would be forwarded to the main document control for retention whenever i addition, deletion or revision of documents and/or information is 1 affected in the package. This systec also will provide adequate infor- q mation to an auditor to verify the completeness of the package at the

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j end of the jo l The inspector had no further question in this regard at this time, No violation or deviation was identifie .3 Followup on Generic Letter 89-13  !

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In July 1989, the NRC issued a Generic Letter alerting licensees regarding the problems in Service Water System (Salt Water System in this plant) due to biofouling. The licensee has initiated extensive 1 evaluation of this problem, and is considering several improvements ,

in the Salt Water System to eliminate or mitigate this. problem. The modification package reviewed'and described in the preceding paragraphs, y although initiated.before the issuance of the generic letter, is one of the modifications implemented by the licensee. This Generic Letter remains open until.the licensee's evaluation and improvement plans '

have been finalized, and the licensee has developed specific modifica-

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tion to address the concerns'. The licennsee's response to the' Generic *

Letter was trasmitted to the NRC on January 29, 1990 detailing the '

i licensee's plans. The inspector has'no further questions in this

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L regard at.this tim .0 Management Meeting >

Licensee management was informed of the-scope and purpose of the' inspection-at the begining of the inspection._The findings of the inspection were .

' discussed with the' licensee's represntatives during the course ofLthe '

inspection and presented to-the licensee management at the June 8, 1990 exit meeting.

t At no time during the inspection was written-material provided to the licensee by the inspector. The licensee did not indicate that proprietary

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information was involved within the scope of this inspectio ,

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