ML20012B922

Responds to NRC 900207 Ltr Re Violations Noted in Insp Repts 50-317/89-27 & 50-318/89-28.Corrective Actions:Demineralized Water & Chemicals Added to Steam Generators to Restore Chemical Concentrations to Required Specs

ML20012B922
Person / Time
Site:	Calvert Cliffs
Issue date:	03/09/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003190167
Download: ML20012B922 (4)

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A BALTIMORE j

!. GAS-AND ELECTRIC '

CHARLES CENTER P. O. BOX 1476 BALTIMORE, MARYLAND 21203 GEORGE C, CREEL i ,. vice pac.ioc=1 - March 9,1990 Nucitan Chenov -

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(sod teo 44ss ti y,  ;

,. - U. S. Nuclear Regulatory Commission P Washington, DC 20555 ATTENTION: Document Control Desk  ;)

SUBJECT:

' Calvert' Cliffs Nuclear -Power . Plant Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Reolv to NRC Insoection Report Nos. 50-317/89-27: 50-318/89-28

REFERENCES:

(a) Letter from Mr. J. C. Linville (NRC) to Mr. G. C.- Creel (BG&E),  :

dated February 7 1990, Inspection Report . Nos. 50-317/89-27; 50-318/89-28. >

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- Gentlemen:

Enclosed is our response to a Notice of Violation identified in Reference (a).

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

Very truly yours, ,

.i 1

- GCC/JMO/db

. Enclosure cc: D. A. Brune, Esquire i J. E. Silberg, Esquire R A.Capra,NRC

. D. G. Mcdonald, Jr., NRC 1 W. T. Russell, NRC 1 '

. L. E. Nicholson, NRC

- T. Magette, DNR pg ssog(psf <

9003190167 900309 /

~PDR ADOCK 05000317 n 'pl r, . . . O. . PDC .

c ENCLOSURE (1)

REPLY-TO INSPECllON REPORT NOS. 50-317/89-27; $0-318/89-28 I. NOTICE OF VIOLATION: STE AM GENERAMR CHEMISTRY CONTROL l'.I The Notice .of Violation, described in Appendix A of Reference (a) indicates that .

BG&E's Chemistry Procedure (CP)-217, " Specifications and Surveillance - Steam Generator" requires Steam Generator parameters to be maintained within specification. Between May 1,1989 and December 15, 1989, the required pH and hydrazine concentrations for Steam Generators #11, #12, and #22 were not always maintained within these specifications, i The root cause of the violation was inadequate coordination of maintenance activities such that proper preservation control could not be ensured. .,

Specifically, numerous maintenance activities (such as feed ring J-nozzle repairs, resolution of steam generator manway bolt elongation issues, feed ring thermal sleeve repair, snubber repair and auxiliary feedwater pump repair) were not scheduled and/or _ completed in a timely manner. Until these activities were completed, the Chemistry _ Section could not adjust or maintain the required chemical concentrations. Additionally, a nitrogen blanket could not be established, since due to maintenance activities neither an alternate nitrogen supply nor a purging flowpath were available. Contributing causes included the following:

o Steam generator recirculation equipment was unavailable to support an '

extended dual unit outage, o Adequate priority was not placed on coordinating the maintenance

. activities which affected reestablishing proper chemical concentrations.

A. Corrective Steos That Have Been Taken and Results Achieved

1. Demineralized water and chemicals (hydrazine, ammonia and morpholine) were added to the steam generators to restore chemical concentrations to the required specifications.

2. The Operations Section revised a procedure to provide nitrogen overpressure to steam generators that now includes a purging flowpath and an alternate nitrogen supply.

3. The Manager-Calvert Cliffs Nuclear Power Plant Department (CCNPPD) has personally emphasized to the responsible individuals that it is imperative to properly maintain plant layup control.

B. Corrective Steos That Will Be Taken To Avoid Further Violations

1. The Chemistry Section is-developing a new CCI-412, " Plant Lay-up and Equipment Preservation Program," which e .;. establish a program to coordinate preservation activities of magr plant components. This procedure is expected to be implemented by May 3,1990.

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ENCLOSURE (1)

REPLY TO INSPECI1ON REPORT NOS. 50-317/89-27; 50-318/89-28

, 2. The Chemistry Section is developing provisions for additional equipment - to support an extended dual unit outage. They will continue to investigate other methods to improve steam generator chemistry control.

C. Date When Full Comoliance Will Be Achigyfd Full compliance was achieved on February 12, 1990 when the final steam generator's chemical concentration was brought into specification.

II.' NOTICE OF VIOL ATION: CABLE SEPA R ATION The Notice of Violation described in Appendix A of Reference (a) indicates that l BG&E's electrical cable installation and separation requirements are implemented i in ' Design and Construction Standards for Cable and Race +vay" (E 406). Appendix A cites various examples where the barrier requirements of E 406 are not met.  ;

h The root cause of the failure to meet the requirements of C 406 was insufficient I programmatic controls of barriers installed for cable separation, j L A. Corrective Steos That Have Been Taken and Results Achieved i 1

1' l: We have developed and are implenienting the " Electrical Sepvation Issue Resolution Plan" which was previously forwarded to the NRC Resident '

Inspector. The plan is designed to provide assurances that acy cable i separation anomalies encountered during field walkdowns will be evaluated and corrected, Any programmatic - weaknesses with independence and i l ' protection of redundant safety-related raceways and cables wh! be i

resolved. The plan contains elements to ensure completion of the folinwing objectives: ,

o Establish a clear understanding of the licensing basis and criterio for electrical separation; ,

o Ensure that these bases are clearly delineated in installation guidelines and procedures;  !

o Ensure that personnel performing tasks which effect electrical ,

separation are trained and understand the safety relationships; i-o Ensure that the as-built configurations are in accordance with the criteria; o Ensure that the design documents reflect the as-built configurations; and, o Ensure that the as-built versus as-designed configurations continue to meet the criteria on a long-term basis.

_- w ENCLOSURE (1) -

. REPLY TO INSPECTION REPORT NOS. 50-317/89-27; 50-318/89-28 s

The curr6nt status of the plan follows:

o Walkuuwa inspections of Unit I are complete, o Review of: the walkdown inspection reports for Unit .1 is complete, o - All Unit I cable configurations not bounded by the report of IEEE Safety Committee - 6.5 " Cable Separation - What Do Industry Testing Programs Show?" of April 25, 1989 were repaired. This report summarizes 115 tests performed by electric power utilities to demonstrate adequate independence of electrical circuits. This report recommends reductions and clarifications to the separation requirements of IEEE Standard .384, in general, the report includes data showing that the separation distances of 3 feet, horizontal, and

.5 feet, vertical, are extremely conservative.

o Cable separation anomalies, inside the Unit-1 containment building,.

involving all safety related raceway transitions and crossovers have been repaired.

o All cable separation anomalies, outside the Unit-1 containment building, involving redundant 4160 vac and. 480 vac load center safety-related raceway transitions have been repaired.

o All Unit-1 cable separation barriers involving Appendix R safe shutdown cables have been verified as correct.

D. Corrective Steos that will be taken to avoid further Violations

1. The plan's schedule calls for resolution of Unit-2 cable separation anomalies similar to-that ~ described in ll.A above. Additionally, all remaining safety-related raceway transition and crossover walkdowns, evaluations and corrective actions will be completed prior to the end of each unit's respective next refueling outage.

2. The lessons learned from this plan implementation will be evaluated for inclusion in the following configuration control mechanisms to ensure integration of any programmatic deficiencies:

o New or revised separation criteria; o Personnel training will be updated for engineering, maintenance, construction, and quality control personnel.

C. Date When Full Comoliance Will Be Achieved Full Compliance will be achieved prior to the end of each unit's respective next refueling outage by completing the Corrective Steps listed above in II.B.

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