ML20079L958

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Forwards Response to Re Safety Evaluation for Environ Qualification of safety-related Electrical Equipment.Adequate Mechanism Exists to Call Attention to New Data Affecting Qualification Status of Equipment
ML20079L958
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 02/10/1983
From: Lundvall A
BALTIMORE GAS & ELECTRIC CO.
To: Clark R
Office of Nuclear Reactor Regulation
References
NUDOCS 8302230507
Download: ML20079L958 (3)


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A BALTIMORE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. L.UNDVALL. JR.

VICC PRESIDENT February 10,1983 su m Director of Nuclear Reactor Regulation Attention: Mr. R. A. Clark, Chief Operating Reactors Branch #3 Division of Licensing U.S. Nuclear Regt.4 tory Commission Washington, D.C. 20555

Subject:

Calvert Clifis Nuclear Powcr Plant Units Nos.1 & 2; Dockets Nos. 50-317 and 50-318 Environmental Qualification of Electrical Equipment Gentlemen:

This letter and its attachment constitute our preliminary response to your letter of December 16,1982, re Safety Evaluation for the Environmental Qualification of Safety-Related Electrical Equipment at Calvert Cliffs Units 1 and 2. We were asked to

. reaffirm the justification for coatinued operation and... submit information for items in... (designated) categories... for which justification for continued operation was not previously submitted...." We were also asked to provide plans for the qualification or replacement of the items in each of these categories along with schedules for the proposed corrective action. After a careful review we have determined that we cannot accomplish this within the specified time frame.

We wish to advise you that we do not concur with the Technical Evaluation Report (TER), specifically the assignment of equipment in category II.A, Equipment Qualification Not Established. As stated in our letter to D. G. Eisenhut of July 27,1982, we do not think it appropriate to submit copies of test reports or other documents which support the qualification of our IE equipment to a particular application. Unfortunately, the manner in which such information was used in the Franklin Research Center TER substantiates the concerns which led us to this conclusion.

We can provide, and would be happy to discuss, the technical basis for our determination of qualification for each piece of Class IE equipment in our plant. We are not privy to test reports and documents referenced in the TER which may supplement our documentation supporting qualification of equipment, and we see no reason to purchase end review every subsequent test report on equipment which we have already qualified for a particular application. We believe that an adequate mechanism exists to call attention to any new data which may affect the qualification status of equipment.

8302230507 830210 PDR ADOCK 05000317 P

PDR

Mr. R. A. Clark Febru:ry 10,1983 a

We would be pleased to meet with the staff to discuss and resolve these issues.

Very truly ours,

/

e AEL/MDP/gvg Attachment cc:

J. A. Biddison, Jr., Esq.

G. F. Trowbridge, Esq.

Mr. D. H. Jaffe, NRC Mr. R. E. Architzel, NRC

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I.B Equipment Pending Modification Item 10

- - We have determined that this equipment is acceptable for (Both Units) continued use as reported in our letter of February 26,1982.

Items 36,39,41 Transmitters inside of the containment on Unit I have been (Both Units) replaced with Barton transmitters, and those outside containment on Unit 2 have been replaced with Rosemount transmitters. We have experienced drift in the output signals on the Barton devices (See LER No. 50-317/82-40) and are presently evaluating the problem. We expect a ' final report d

from Barton_ by the end of February, and we plan to run a performance test to determine the acceptability of modified Barton transmitters. Justification for continued operation was submitted in our letter of February 26,1982.

i Item 40 We have completed our assessment / evaluation of the (Both Units)

Rosemount RTD's and have determined that they are qualified with the exception of the connection head. The head is made of a low copper ' aluminum alloy which may corrode under conditions which could occur during. containment spray.

However, the corrosion rate over the seventeen-day post-LOCA interval at postulated temperatures is not so severe as to consume the available material. Nevertheless, we plan to protect the connection head by application of _ an epoxy coating to preclude significant corrosive effects.

This is scheduled for the next refueling outage of each unit (Unit 1 l

cycle 7 and Unit 2 cycle.6). -

Items 95,96

- In our letter of February 26, 1982, we provided justification 3

(Unit 1) for continued operation and both interim and long term Items 94,95 corrective action for the Dragon Solenoid valves. We have (Unit 2) installed qualified Valcor valves inside the containments for both units. Valves outside containment will be replaced by the fall of this year.

The assessment / evaluation of the manufacturer's test report will not be completed until March 1983.

II.A Equipment Qualification Not Established The. majority - of equipment identified in this category has been determined to be acceptable as the result of independent assessr ent/ evaluation by Wyle Laboratories. We conduct a review of this activity and provide the final commentary addressing the qualification of our equipment. This review is on-going and is scheduled for completion j

in early August for the identified equipment. At that time we will be in a position to i

formally satisfy your information request. In the interim we would be pleased to submit information as it becomes available. We can also provide a submittal by March 1,1983, l

which will address equipment reviewed by that date.

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