ML20207M144
| ML20207M144 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/07/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR GL-87-02, GL-87-2, NUDOCS 8810180125 | |
| Download: ML20207M144 (4) | |
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f B At.TI M O f E CASAND ELECTRIC l
CHARLES CENTER
- R O, BOX 1475
- bat.TIMORE. MARYLAND 21203 JostpH A.TitmHAN Vict Passioto Nvcteam Esiteer i
9 October 7,1988 a
9 U S. Nuclear Regulatory Commission
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Washington, DC 20555 ATTENTION:
Document Control Desk l
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SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. ! & 2; Docket Nos. 50-317 & 50 318 l
Response to Generic SER on SQUG Resolution of Unresolved Safety Issue A-46
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1 Gentlemen:
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l On July 29, 1988, the NRC Staff issued a Safety Evaluation Report (SER) on Revision 0 of the Generic implementation Procedure (GlP) for Seismic Verification of Nuclear Plant j
Equipment developed by the Seismic Qualification Utility Group (SQUG). The letter to SQUG enclosing the SER requests that SQUG member utilities provide to the NRC, within l
60 days, a schedule for implementing the GIP, Dy letter, dated August 19, 1988, to l
Mr. Shao, SQUG clarified that the 60 days would expire on October 7.1988. This letter responds to the NRC request for our plant-specific seismic ve'ification plans for l
.l Calvert Cliffs consistent with the requirements of Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, i
j Unresobed Safety issue (USI) A-46.*
I As members of SQUG (and the Electric Power Research Institute), we have supported the j
many efforts on which the GIP is I;ased. The SER endorses the methodology and criteria l
embodied in Revision 0 of the GIP, subject to satisfactory resolution of a number. of open issues and ?'RC comments. Action by SQUG and its contractors is underway to resohe the identified open issues and comments in accordance with the SQUG schedule presented at the Augu.t 10-11, 1988 meeting with the NRC staff, and included with the SQUG letter to Mr. L Shao, dated August 19, 1988. This schedule projects completion j
of Revision 2 of the GIP in spring 1989, contingent upon SQUG and NRC agreement on the resolution of the sarious open issues. Revision 2 of the GIP is the version which is 1
scheduled to contain all of the information needed to implement the USI A-46 generic l
letter at SQUG member plants. The final NRC SER Supplement on Revision 2 of the GlP is anticipated by mid-1989.
I Our plart for implementation of tha GlP at Calvert Cliffs are preliminary gisen the
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current status of and schedule for completion of Revision 2 of the GIP and NRC's SER Supplement on that revision, llowever, it is our current plan to resohe USl A-46 for
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Calvert Cliffs by implementation of the generle criteria and triethodology included in i
I f M 8810180125 GS1007 4
PDR ADOCK CU000317 1 g\\
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...________,_\\____,_,__.___
Dosument Control Desk October 7,1988 Page 2 l
I Revision 0 of the GIP, as clarified by the SQUG responses to the NRC SER in SQUG letter to Mi. L. Shao, dated September 22, 1988. Assuming no major changes in the work scope currently envisioned, as described in Revision 0 of the GIP, including the criteria to be added for cable raceways, tanks, heat exchangers, and relays, we plan to perform the seismic verification plant walkdown reqaired by the GIP by the conclusion of the second refueling outage after receipt of the final SER Supplement and resolution of all open issues, if the final NRC SER Supplement with no open items is issued by the second quarter of 1989, then the plant walkdown for both Units at Calvert C'iffs is expected to be completed by spring 1992. Identifleation of safe shutdown equipment, gathering of necessary plant specific data and training of our walkdown team members will be initiated prior to the plant walkdown for each Unit.
Our current implementation plan and schedule, as described abose, are based on the
'SQUG Commitments" identified in each section of the GIP (Revision 0), with the exception of those specified commitments delineated in Attachment (1) to this letter.
The specific commitments described in Attachment (1) are not considered applicable or appropriate for our facility for the reasons given therein. As we enntinue to deselop our program in more detail, we may identify additional 'SQUG Commitments
- that are impractical for Cals ert Cliffs.
In
- addition, our implementation and schedule commitment is contingent upon our current understanding of the GIP. If the scope of the final revision of the GIP or the cost and effort required to implement it at our plant facility change significantly from the current scope and cost estimates, we will re-evaluate our commitments. In view of the uncertainties in the requirements and schedule for resolution of related issues, we reserse the right to revise the imple-mentation schedule for USl A-46 at Calvert Cliffs to integrate poten'ist future requirements into a single, cost-effective program. This possibility has been the subject of on-going discussions with your stalf, and further discussions are planned.
We will advise you in writing of any changes in our implementation plans and schedules.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
'W J AT/Gl.11/dtm Attachment ec:
D. A, llrune Esquire J.
E.
Silberg, Esquire R. A. Carra, NaC S.
A. McNeil NRC W. T. Russell, NRC D. C. TrimNe/V. L. Pritchett, NRC
~I. Magette, DNR
A'ITACHMENT (1) i EXCEPTIONS TAKEN TO GENERIC IMPLEMENTATION PLAN (GIP) i 1.
The GIP identifies four essential functions which must be accomplished for safe shutdown as follows:
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o Reactor reactivity control o
Reacto; coolent pressure control l
o Reactor coolant inventory control f
We will use four critical safety functions which meet the intent of the above functions, but conform with the safety functions in the Emergency Operating i
Procedures Safety Parameter Display System and Q List. These functions are as follows:
Meactivity Control i
Same as GIP.
i Pressure and Inventory Control l
This safety function combines the pressure and inventory functioa of the GlP since these functions have significant overlap.
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i llent Removal j
Same as GIP.
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Vital Auxillah l
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The maintenance of vital auxiliaries safety function supports all systems which j
are used to satisfy the other safety functions. These support systems provide such services as instrument air needed for vahe operation, electrical power required for valve, pump, motor, parameter indication and cooling air and water to prevent damage to equipment required to operate in a harsh atmosphere.
2.
The GIP identifies a two-stage approach for the identification of safe shutdown I
i equipment.
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We will base our identification of safe shutdown equipment upon a previous
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eva'uation performed to identify equipment for the List of Safety-Related items j
(Q List). This evaluation is based on the safety analyses in Chapter 14 of the l
FSAR and identifies systems, equipment and components which are credited for the l
capability to shutdown the reactor and maintain it in a safe condition. A series I
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6fTACllMENT (1)
EXCElrrlONS TAKEN TO GENERIC IMPLEMENTATION PLAN (GIP) of drawings and Shutdown Flow Sheets document the bases for the equipment included on this list. The Loss of Non-Emergency Power event will be used to identify the seismic safe shutdown equipment. The list will be amended to reflect the 72-hour requirement for the seismic safe shutdown. The list may slso be amended to include additional or alternate safe shutdown equipment based upon the guidanc) provided ty Appendix A of the GlP.
3.
Safe shutdown is defined in Section 3.3.3 of the GIP as bringing the plant to a llOT SilUTDOWN condition and maintaining it there for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an earthquake. IlOT SilUTDOWN is defined as having the reactor sub-critical and average reactor coolant temperature above 200 F.
We define this safe shutdown condition as bringing the plant to a llOT STANDBY condition and maintaining it there for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an earthquake, llOT STANDDY is defined in our Technical Specifications as having the reactor sub-critical and the aseroge temperature equal to or greater than 300 F.
IlOT SilUTDOWN is defined as sub-critical with temperature less than 0
0 300 F, but greater than 200 F The llOT SilUTDOWN definition in the UIP is therefore in conflict with that of our Technical Specifications. Calvert Cliffs is licensed as a llOT STANDBY plant, and therefore, safe shutdown for Calvert Cliffs is llOT STANDDY.
4.
Section 3.0 states that Appendix A gives a detailed descriptior of the raethod to identify individual items of safe shutdown equipment including a step-by-step procedure, flow diagram, and documentation forms which can be used to develop the safe shutdown equipment list (SSEL) for seismic evaluation and the SSEL for relay evaluation.
Wr will use the previous evaluation as stated abose; and therefore, will deviate from the step by-step procedure provided in Appendix A. Iloweser, we will use an 1
equivalent document system for configuration control.
5.
Section 2.1.1 Systems Engineers, states that the licensee will provide
- Systems Engineers" to develop the SSEL described in Section 3.
The SSEL will be developed by ' Design Engineers' at Cahert Cliffs. They are best qualified to make this determination.
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