ML20023D139
| ML20023D139 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/10/1983 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| IEB-79-01B, IEB-79-1B, NUDOCS 8305190293 | |
| Download: ML20023D139 (4) | |
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER. P. O. BOX 147S a BALTIMORE, MARYLAND 21203
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May 10,1983 v
SUPPLY Director of Nuclear Reactor Regulation Attention: Mr. R. A. Clark, Chief Operating Reactors Branch #3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Calvert Cliffs Nuclear Power Plant Units Nos.1 & 2; Dockets Nos. 50-317 and 50-318 Environmental Oualification of Electrical Equipment
References:
(a) 10 CFR Part 50, paragraph 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," effective February 22,1983.
(b) Letter from R. A. Clark (NRC) to A. E. Lundvall, Jr.
(BG&E), dated March 25,1983.
(c) Letter from A. E. Lundvall (BG&E) to R. A. Clark (NRC) dated February 10,1983.
(d) Letter from A. E. Lundvall (BG&E) to R. A. Clark (NRC) dated March 18,1983.
Gentlemen:
In Reference (a) and (b) above, the NRC has requested information concerning the current qualification status and our plans for completing the environmental qualification of all electrical equipment important to safety.
This letter constitutes our response to both References (a) and (b).
Background
Reference (a) requires that by May 20, 1983, all operating reactor licensees identify the electrical equipment important to safety which has already been qualified and submit a schedule for either:
- oY8 8305190293 830510 PDR ADOCK 05000317 P
Mr. R. A. Cl rk
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MIy 10,1983 o Qualification of the remaining electrical equipment important to safety in accordance with the provisions of CFR 50.49; or o Replacement of this equipment.
, Reference (b) requires that we review our previous thirty (30) day response to the December 16, 1982 NRC Safety Evaluation with regard to equipment in Categories I.B, II.A, and IV, and notify the NRC within thirty days of any changes to that response.
Reference (b) additionally requested that the following information be provided to the NRC in the May 20 submittal required by 10 CFR 50.49:
o A statement as to whether our previous submittals provide complete compliance with 10 CFR 50.49, paragraphs (a) and (b); and o A description of the methods used to identify the equipment covered by paragraph 10 CFR 50.49 (b)(2).
Update of Response to NRC Safety Evaluation On December 16,1982 the NRC issued its safety evaluation for the environmental qualification of safety-related electrical equipment at Calvert Cliffs Units 1 and 2. This safety evaluation requested that we reaffirm the justification for continued operation and submit information for those items for which justification for continued operation was not previously submitted.
Reference (c) forwarded our preliminary response to your request. The response consisted of information supporting our justifications for continued operation for several Category I.B ltems. We stated in Reference (c) that we would submit information by March 1,1983 which would assist you in your review of our qualification efforts for equipment within Category II.A, " Equipment Qualification Not Established."
This information was provided to you by Reference (d) in the form of our latest compilation of environmental qualification data (IEB 79-OlB report).
No equipment has been listed in Category IV.
- The following discussion is intended to supplement the justifications for continued operation which have been submitted to you in previous correspondence, including Reference (c).
During our last refueling outage on Unit 2, we conducted a walkdown (from January 3 to January 7,1983) of the safety-related motor operated valves listed in our last IEB 79-01B submittal. We found ten (10) instances of inadequate identification of the motor class insulation system. These ten MOV's are listed on Table 1 by equipment number and qualification category. Table 1 also lists the page numbers from our last submittal and the item number which was referenced in the NRC Safety Evaluation (Franklin TER).
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Mr. R. A. Clark
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M:y 10,1983 TABLE 1 3/18/83 response TER COMPNO
_QUALNO Page No.
Item No.
2MOV656 MOV014 229 21 2MOV4145 MOV002 226 22 2MOV617 MOV0ll 207 23 2MOV615 MOV002 217 24 2MOV659 MOV013 227 28 2MOV660 MOV013 228 28 2MOV5462 MOV016 274 30 2MOV5463 MOV016 275 30 2MOV625 MOV002 218 31 2MOV4144 MOV002 225 32 We subsequently identified the motor manufacturer and serial numbers and have issued a query to the manufacturer requesting identification of the motor class insulation system. We expect to receive this information in eight weeks. We do not anticipate any problem in qualifying these motors, since the specific environmental parameter of concern is radiation and we are aware of similarly supplied motors which have been tested to higher radiation values. Therefore, we have concluded that continued safe operation can be maintained.
Response to 10 CFR 50.49 1.
Identification of Safety-Related Equipment Already Oualified The compilation of environmental qualification data provided by Reference (d) constitutes our May 20, 1983 response to the 10 CFR 50.49(g)) requirement for identification of equipment within the scope of 10 CFR 50.49(bXI that has already.
been quallfled. This compilation also identifies all items for which qualification
-review activities have not yet been completed.
We expect to complete these reviews for (b)(1) equipment and issue a final qualification report for these items by August 15,1983.
- 11. Identification of Nonsafety-Related Equipment Requiring Qualification Paragraph 50.49 (b)(2) requires identification of nonsafety-related electrical equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of specified safety functions.
Based on the original plant design and design review practices, equipment classification criteria, and supplemental analyses conducted in response to I&E Bulletin 79-01B, we are not aware of any nonsafety-related equipment whose failure would prevent satisfactory accomplishment of safety functions. Nevertheless, we are currently evaluating various systems-oriented review methods to determine whether either of them may be useful in reviewing the existing classification of electrical equipment for the purposes of validating the aforementioned design practices and supplemental analyses. At this time, however, we do not feel that an extensive re-evaluation of the plant design is required to satisfy the intent of the rule.
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. ' Mr. R.~A. Clark -
M2y 10,1983 111. Identification of Post-Accident Monitoring Equipment Requirinz Qualification Post-accident monitoring equipment requiring qualification pursuant to paragraph 30.49(b)(3) is being identified under our Regulatory Guide 1.97 review program. - This progra.n was required pursuant to NRC Generic Letter 82-33, dated December 28, 1983, and is being coordinated with the other emergency response capability initiatives of Supplement I to NUREG-0737. Our plans and schedules for identification of post-accident monitoring equipment were provided in our response to Generic Letter 82-33 (reference BG&E letter from A. E. Lundvall to R. A. Clark (NRC), dated April 15,1983). The R.G.1.97 review program will identify the qualification requirements for each Instrument to monitor a post-accident variable.
Instrumentation requiring further qualification will then be incorporated into our equipment qualification program.
iv.- Equipment Qualification Schedule and Extension Request We will complete our qualification efforts within the scope of 10 CFR 50.49 by the end of the second refueling outage after March 31,1982. This corresponds to the Unit 1 Cycle 8 refueling outage in Spring 1985 and the Unit 2 Cycle 6 outage in Spring 1984. Since our spring outages typically begin in April, we request an extension to April 31,1985 for the Unit 1 outage.
If you should have any questions concerning the information provided above, please do not hesitate to contact us.
Sincerely, ifD AEL/BSM/pdy cc: 3. A. Biddison, Jr., Esq.
G. F. Trowbridge, Esq.
Mr. D. H. Jaffe, NRC
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Mr. R. E. Architzel, NRC
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