ML20126F813
| ML20126F813 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/09/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8103200244 | |
| Download: ML20126F813 (4) | |
Text
1 e
BALTIMORE GAS AND ELECTRIC COMPANY P. O. B O X 1475 B A LTI M O R E, M A RYL A N D 21203 March 9, 1981 AntHun E.LuNovALL Jn.
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Of fice of Nuclear Reactor Regulation S,'
U. S. Nuclear Regulatory Commission po@F
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Washington, D. C.
20555 j
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Mr. Robert A. Clark, Chief S*
Operating Reactors Branch #3 g
/p Division of Licensing f.,
Q/"ner;
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Dubject:
Calvert Cliffs Nuclear Power Plant d N}'
Units Nos. 1 & 2; Dockets Nos. 50-317 & 50-318 MRC Requirementy for Auxiliary Feedvater System
Reference:
Draft Safety Evaluation Report (GER) CCNPP Implem-entation.of Recommendations for Aux Feedvater System Centlemen:
On b March 1981 the NRC and BG&E held a meeting to discuss the Draft SER referenced alove.
The TTRC requested that we verify, in writing, the following information.
A.
Short Term Recommendations 1.
GS-2 The only valves which could interrunt all AW T1ov to one unit are as follow:
0-AFW-166 Condensate Storage Tank (CST) #12 AFW Sunply to Unit 1 and 2 1-AFW-1/>l #12 CST Unit 1 AFW Pump Suction 2-AFW-161 #12 C3T Unit 2 AFW Pump Suction i
"'hese valves, per Operatinp' Instruction (OI)-32 are required to be locked open.
2.
GS h a.
Should the primary water supply not initially be availabic the operator would not start the AFW punp per 01-32.
One i
of the initial conditions for start-up of the AFW nump is, l
" Water in #12 Condensate Storage Tank (CGT) is available".
Chould the level in the #12 CST not be adequate, the operator THIS DOCUMENT CONTAINS POOR QUAUTY PAGES f
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f
Mr.. R. A. Clark' Pace:2 March'0, 1031 is directed how to shift to the: alternate water supply prior to -
starting the AFW pump.
In addition to the procedure, there is also a checklist available for this' evolution. Tech Spec 3.71 3 requires that #12 CST-always have 150,000 gallons F
available ner operating unit. This is verified at least once
.per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Therefore, the likelihood of #12 CST not having adequate level is remote. Based on the above information-there=is adecuate direction to prevent damage to.the APW pump.
should the primary water. supply initially not be available,
- b.. For the case in which th'e primary water source is being.
depleted, Abnormal Operating Procedure ( AOP)-15 directs the operator to transfer to an alternate water source. Thel procedures detail, for the onerator, how-to' perform this.
function.
3.
GS-5 a.
Communications: Should all AC power be lost, an operator vill be directed to proceed to the steam admission. valves for the AFW pumps and open them. The centrol room would know when the valves are being opened because the numn vill immediately start, therefore, it is not necessary for the operator to communicate this fact to them.
The operator vill be aware that the valves are onen because he perforned the function, he does-not need verification from the "~1 trol room.
There are walkie-talkies available in the control room but.they are not dedicated to use for the AFW system.
In addition, there is a sound povered phone at each 3evel in n'stairvell.readily accessible to the steam admission valves.
[
l b.
Lighting:
The corridors on the L5' Flevation are illuminated during a station blackout by energency lighting units with an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> rating. We plan to install additional lights in the vicinity of the steam admission valves to augment that which is i
already available. We extect this work to be completed in six
(
nonths.
h.
GS-6 1
a.
Any locked valve which is repositioned must be checked and then rechecked independently by a second operator to verify its nosition.
b.
We understand that t'a NFC finds the following to be satisfactory in regard to the flow test required after a greater than Ih day cold shutdovn period.
During a normal start-up we use the AFW l
system to feed the steam generators.
The use of the AFW system in this manner is suffielent to neet this test as long as it j
establishes f3ov to both nteam cenerators from the primary vnter source tank and reaches a minimum flow requirement. This minunum flov vill be determined orier to issuance of the revision to'the Tech Free.
I
Mr. P. A. Clark Pace 3.-
March 9,1031-5.
CS The existing AFW system meets, with the exception of the first item,-
all seven' criteria from Item 2.1.7.a of NUREG-0578. At present the NRC has not approved the CCNpp AFW system. for automatie initiation of-flow, we only automatically -start the AFW pumps.
Upon approval-by the NRC, we vill implement automatic. initiation of flow.
6.
Reconnendation It 'should be noted that the Tech Spec change (3.71.2) submitted on,22 January 1980 does not' state what is contained in this paragraph.
The SER states that manual valves that are normally closed or open should be tested for operability at least once a quarter.
The' tech spee change reads, "At least once per quarter verify the operability of remote operated valves."
Our position. is that testing the operability of normally open or shut' valves does not'in any way contribute.to the health and safety of the public. Valves critical to proper AFW system operability are locked in position.
To unlock a valve, shut it, and then reopen, demonstrates nothing and only contributes to systen unavailability.
We l agree that remote operated valves should be tested quarterly.
The above comments-are consistent with ASME Section III IWV 2000 and' IWV 3000 of the applicable codes at both units (Unit 1 - Th Edition Summer 1975 Addenda, Unit 2 77 Edition, Summer 1978 Addenda)..
In addition to this, the same' tech spee. requires that every 31 days the plant is required to verify that each valve in the flov '
rath is in its correct position.
B.
Additional Short Term Recomnendations 1.
The addition of redundant-level indication for #12 CST can not be completed by 1 July 1981 due to equipment ordering lead times.
We expect delivery of the required parts by April of 1982. Should these parts arrive in time for the 1982 outages, they vill be installed at that time, if not they vill be installed with the rest of the AFW modifications with an expected conpletion tine of late 1083.
2.
A h8 hour endurance test an deneribed in this reconmendation vill be perforned on AFW pumns 12, 21, and 22 by 1 May 1981.
Fndurance tests vill be conducted on the motor driven numps after they are installed.
C.
Ione Term Pecommendations P.
GL-2 n.
This recomnendation requires, "The licensec should pronoce Technical Specifications to incorporate appropriate periodic inspections to veri fy the valve nositions." The valven
)
"r. R. A. Clark Pare h
!treh 9, 1981 discussed are those valves installed which are redundant to those in the suction flow path. The requested Tech Spec change-forwarded on 22 January 1980 requires that every.31. days the plant must verify that each valve in the AFW flow path is in its correct position. We feel that this change meets the requirenent of this 'nortion of the recommendation.
b.
In letter dated 2 February 1981 from Ash to Conner ve discussed our modifications to the suction piping line up.
We are in'the trocess of-submitting a request to the NRC -to allow us to delete these bypass valves based on a small increase in avail-ability but a large cost to install them.
i h.
Recommendation All equipment installed, as' discussed in our 18 November 1980 a.
letter, vill be environmentally. qualified in accordance with the existing requirements.
Every specification forwarded to vendore for bids is reviewed by our environmental qualification group to encure' thst the 'enuipnent vill lte properly qualified.
b.
The existinc motor onerated steam inlet valves are presently installed in the main steam room on the 27 foot elevation.
Reach rods have been installed to allow manual. operation of the valves from the h5 foot elevation corridor. The estimated time to open thece valves, should a break occur in the main steam room that resulted in the valves not opening, is 15 minutes including time to. detect the need to manually open them. This is adequate to ensure that we vould not loose the steam generator as a heat sink.
5 Recommendation The design and trocedural changes required to implement the AFW system modifications have been reviewed to ensure that they vill raintain the carability to supply the required flov to the steam generator (s) assuming a pipe break anywhere in the AFW nump discharge lines concurrent with a single active failure. The design and procedural chances are sufficient to ensure the capability to detect and isolate the break, and direct the required feedvater flow to the steam generator (s) before they boil dry.
Should you have any questions, feel free to contact us.
Very truly yours
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.ce:
J. A. Biddison, Esquire G. F. Trowbridge, Esquire Messrs. P. W. F. ruse - CE J. C. Ventura - Pechtel h
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