ML20237J425
| ML20237J425 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/16/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8708260160 | |
| Download: ML20237J425 (9) | |
Text
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a' s
,g BALTIMORE v
^9 GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TIERNAN Vict Patssocut NucktAn ENERGY,
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June 16,1987
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U..S. Nuclear Regulatory Commission i
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63P Park Avenue 1
mKing of Prussia, PA 19406
^TTENTION:
Mr. William T. Russell Regional Administrator
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$UBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Environmental Qualification - Submittal of Additional Information
REFERENCES:
(a)
Enforcement Conference held in King of ' Prussia, ' PA ' on May 13,1987, between Mr. 3. M. Allan and Staff (NRC), and Mr. 3. A. Tiernan and Staff (BG&E), Environmental Qualification (b)
Letter from Mr. 3.- A. Tiernan (BG&E), to Mr. W. T. Russell (NRC),
dated May 22, 1987, Environmental. Qualification' of Unit One Electrical Equipment (c)
Letter from Mr. 3. A. Tiernan (BG&E), to Mr. W. T. Russell (NRC),
dated May 29, 1987, Environmental Qualification of Unit Two Electrical Equipment I
^
(d)
Combined Inspection Report Nos. 30-317/87-07; 50-318/87-08, dated April 28,1987 (e)
Combined Inspection Report Nos. 50-317/85-22; 50-318/85-20, dated March 4,1986 l
Gentlemen:
At the conclusion of the Enforcement Conference held on May 13,1987 (Reference a),
your staff requested that Baltimore Gas and Electric Company provide additional information on our Environmental Qualification (EQ) Program.
A summary of the information requested is provided in the Enclosure and associted attachments.
R ADOCK 050003.17 G
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,a Mr. William T. Ressell June 16,1987 Page 2 As discussed at the Enforcement Conference, we employed an extensive inspection program to reaffirm the qualification of 10 CFR 50.49 equipment. All discrepancies a
were resolved and a task force consisting of Design Engineers, personnel with licensed operator experience, and contracted consultants assessed the safety significance of all discrepancies. This. task force found that a!! Unit One 10 CFR 30.49 equipment was operable and would have remained operable for all postulated design basis events.
We have summarized in the Enclosure our interim and long-term corrective actions that we are taking to enhance our EQ program. These include interim methods to provide l.
cle ar communication of EQ maintenance requirements to field craft personnel and addtional reviews of planned maintenance by Design Engineering personnel or Qualified Equ:pment Qualification Reviewers.
Long term corrective actions will include the assi.gnment of an overall. EQ Program Manager, issuance of revised Qualification Malitenance Requirement Sheets which more clearly provide EQ maintenance req alrements, and an independent review of the EQ program.
Should you have any additional questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, 3AT/LSL) dim Enclosure cc:
D. A. Brune, Esquire
- 3. E. Silberg, Esquire R. A. Capra, NRC S. A. McNeil, NRC T. Foley/D. C. Trimble, NRC
ENCLOSURE I
MAY 13,1987 ENFORCEMENT CONFERENCE ON ENYlRONMENTAL QUALIFICATION - ADDITIONAL INFORMATION As discussed at the Enforcement Conference and in our letters dated May 22,1987 and May 29,1987, (References b and c), Baltimore Gas and Electric Company (BG&E) employed an extensive inspection program to reaffirm the qualification of both Units' 10 CFR 50.49 equipment. Unit One was shutdown on April 1,1987 (Unit 2 was already in a refueling outage) to inspect the installed configuration of 10 CFR 50.49 equipment.
These inspections included the use of comprehensive checksheets (examples of which were provided previously to the NRC) to document any identified discrepancies. These discrepancies were then reviewed by Equipment Qualification Design Engineers and all discrepancies were resolved.
All discrepancies were evaluated by a task force consisting of Design Engineers (Electrical, Mechanical, and Instrumentation and Control), personnel with licensed operator experience, and contracted consultants. This task force was formed to assess the qualification of equipment, given the identified discrepancies, and determine whether this equipment was qualified, qualifiable, or operable. In addition, should any equipment have been found to be inoperable, this task force would assess the safety significance by evaluating the ability to maintain reactor energy removal and containment energy removal functions.
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Af ter assessing the equipment for which there were identified discrepancies, the task force found that the large majority of these were determined to be qualified or quallflable. All Unit One 10 CFR 50.49 equipment was determined to be operable and would have remained operable for all postulated design basis events. Therefore, the assessment of the past potential impact on public health and safety concluded there was no safety concern as a result of these discrepancies.
A review of all EQ discrepancies showed that, in general, adequate qualification for 10 CFR 50.49 equipment and associated cable was present and that environmental qualification requirements were properly implemented in the field with respect to this I
equipment and cable. However, the connection details between the equipment and cable (i.e., termination sp!!ces, terminal blocks, jumper wire, junction boxes, etc.) were not clearly communicated to the maintenance organization, Interim upgraded EQ program controls have been established to prevent recurrence.
i These include methods to provide clear communication of EQ maintenance requirements j
to craftsmen to ensure work is completed as directed by the EQ maintenance requirements. This will be accomplished by use of an EQ Equipment Traveler with each maintenance work package. Each planned maintenance order associated with 10 CFR 50.49 equpment will be reviewed by an Equipment Qualification Design Engineer (EQDE) or a Qualified Equipment Qualification Reviewer (OEQR) prior to work commencing. A
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post-maintenance checklist will be filled out by the craftsman and quality control inspector. Finally, the checklist will be reviewed by either an EQDE or QEQR to ensure that the work performed complies with the applicable EQ requirements and that the qualification of the component is not compromised.
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ENCLOSURE MAY 13,1987 ENFORCEMENT CONFERENCE ON ENVIRONMENTAL QUALIFICATION - ADDITIONAL INFORMATION In addition to the above interim actions, the following corrective actions have been or will be taken (projected completion dates are provided in parentheses):
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o A Project Engineering Supervisor has been assigned as the Environmental l
Qualification Program Manager, o
Revised' Qualification Maintenance Requirement Sheets which more clearly provide electrical connection requirements will be issued (July 1987),
A revised electrical design and construction standard will be issued (July 1987),
o and o
A Quality Assurance evaluation, including expertise in EQ, will be performed on the overall EQ program (August 1987).
The below additional information was requested at the conclusion of the May 13, 1987 Enforcement Conference.
1.
Provide a copy of all overhead transparencies presented during the Enforcement Conference.
Response
These were provided at the Enforcement Conference.
2.
Provide a list of all items recently added to the Calvert Cliffs 10 CFR 50.49 list and the reasons they were added.
Additionally, discuss whether 10 CFR 50.49(b)(2) items were considered for the original 10 CFR 50.49 iist or in Calvert Cliffs' recent review of the list.
Response
In the course of our review of the Environmental Qualification Program, we chose to upgrade and maintain additional equipment in accordance with EQ requirements.
We will maintain and control that equipment by an Interim Program pending final engineering review for possible permanent addition to the ilst of 10 CFR 50.49 equipment. This equipment is listed in Attachment (1).
The Calvert Cliffs 10 CFR 50.49 list does not contain a separate section for items described by 10 CFR 50.49(b)(2), (i.e., non-safety related equipment whose failure under postulated environmental conditions could prevent the satisfactory i
accomplishment of the functions of safety related equipment). It has been our l
practice that any such equipment which falls under the description of 10 CFR 50.49(b)(2) be classified as safety related, and thus our 10 CFR 50.49 list does not distinguish between these items.
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ENCLOSURE MAY 13,1987 ENFORCEMENT CONFERENCE ON ENVIRONMENTAL QUALIFICATION - ADDITIONAL INFORMATION 3.
With regards to the closed Potential Enforcement Iterr. Nos. 50-317/85-22-10; 50-318/85-20-09 pertaining to the qualification of Hatfield Cable (discussed on page 11 of Reference d), discuss the documentation present in the Qualification File at the time of the March 1987 Inspection that supported similarity.
Response
The Combined Inspection Report for the September 1985 Inspection (Reference e) noted three deficiencies (related to submergence, 40-year lifa at 111.9 C, and similarity between the installed cable and the test cable) in the environmental qualification file CBL011 for a Hatfield cable. The inspection report noted that the licensee (BG&E) was able to resolve all the inspector's concerns regarding the file and that the licensee would revise the qualification file to resolve all the questions identified by the inspector.
The issue of similarity was that Wyle Report No. 46111-0 (Reference 4 below) was not physically included in the CBL0ll file. The report was subsequently added to the file as agreed upon during the inspection.
During the March 1987 Inspection, the inspector verified that the file CBLO11 had been revised to include supporting data to resolve the questions regarding submergence and the 40-year life at 111.9 C.
However, the inspection report for the March 1987 Inspection (Reference b) states that "... the EQ file still did not contain a similarity analysis" and that "during the course of this inspection, the licensee generated a similarity analysis and placed this analysis in the file."
i While we agree that we provided an additional document (Attachment 2) which j
summarized the information present in the CBL0ll file to the satisf action of the inspector, we believe the file already contained all information necessary to support qualification of the Hatfield Cable as discussed below.
Environmental Qualification File CBLO11 contained the following information (listed by reference) prior to the March 1987 inspection:
J o Reference ('4) - Wyle Report No. 46111-0, "A Nuclear Environmental Test i
Program on Two Electrical Control Cables," dated July 17,1982.
1 This test report identified one of the test specimens as a "three (3) conductor, l
No.12 AWG, rubber insulation of GE silicone compound No. 9025, asbestos l
braided, BG&E Qualification Code CBL0ll, manufactured by the Hatfield
{
Corporation."
l o Reference (9) - Letter from Mr. M. Daley (Continental Copper and Steel Industries, Inc., Hatfield Wire and Cable) to Mr. R. Morsberger (BG&E), dated j
July 2,1981.
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This letter stated that Hatfield's records confirmed "the use of CE silicone
, insulation No. 9025 and asbestos flame retardant braid jacket on the
- Saltimore Gas and Electric (Bechtel Corp) job. Our records show no other i
silicone insulation compound was used."
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ENCLOSURE MAY 13,1987 ENFORCEMENT CONFERENCE ON ENVIRONMENTAL QUALIFICATION - ADDITIONAL INFORMATION o-Reference (13) - Letter from Mr. 3. Eckert (Lewis Engineering Company -
subsequently bought 'out by Hatfield) to Mr. P. Bhatia (BG&E), dated April 30, 1970.
This letter forwarded Franklin Institute's Final Report F-C2781 (dated April 1970), Test of Electrical Cables Under Simulated Post Accident Reactor Containment Service, and states that " Cable Nos. A-1 and B-1 were processed with General Electric Company Silicone Rubber Cat. No. SE 9025."
o Reference (2) - Calvert Cliffs Nuclear Power Plant Qualification Evaluation Worksheet, dated March 26,1983.
This worksheet identified the cable of concern (Hatfield - GE Silicone No.
9025 Insulation) location, function, etc.
o Reference (3) - Calvert Cliffs Nuclear Power Plant Qualification Report Review Summary, dated March 26,1983.
This summary provided the equipment type (Hatfield Cable with GE Silicone Compound No. 9025), qualification method, data summary, etc.
In summary, the issue of similarity, which arose initially during the September 1985 Inspection, stemmed from the fact that the Wyle report (Reference 4 above) was not physically included in the CBLOli file. This issue was resolved during the September 1985 inspection and the report was subsequently added as agreed upon. The document (Attachment 2) generated for the inspector during the March 1987 Inspection only summarized the information avaliable in file CBLO11 at the time of the March 1987 Inspection.
The information in file CBLO11 adequately supported that the cable tested (GE silicone compound No. 9025) is the same cable documented in qualification file CBLO11 which is the same cable installed in the plant. Therefore, we maintain that qualification file CBLO11 did address and resolve the deficiencies noted during the September 1985 Inspection.
4.
Provide a schedule for qualification of Unit One and Two Equipment with Environmental Qualification justifications for continued operation (3CO).
Resoonse:
The only equipment which required 3COs are the equipment identified in Attachment (1) by Note (6). Qualification of this equipment will be completed by July 31, 1987.
This will include a review to ensure proper electrical separation, if cable rerouting is required, engineering for the rerouting will be issued to the field by August 31,1987, and the work will be completed at the I
next outage of sufficient duration.
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..co ATTACHMENT (1)
ADDITIONS TO CALVERTS CLIFFS 10 CFR 50.49 LIST In the course of our review of the Environmental Qualification Program, we chose to upgrade and maintain additional equipment in accordance with environmental qualifica-tion requirements. We will control that equipment by an Interim Program pending final engineering review for possible permanent addition to the list of 10 CFR 50.49 equipment. This equipment is listed below.
Component No.,
Description
~ 0-HS-2103A (Notd 1)
D/G 114kV Bus Feeder Bkr Control Transfer Handswitch 0-HS-2103B (Note 1)
D/G 114kV Bus Feeder Bkr Local Control Handswitch 0-HS-2106A (Note 1)
D/G 12 4kV Bus Feeder Bkr Control Transfer Handswitch-0-HS-2106B (Note 1)
D/G 12 4kV Bus Feeder Bkr Local Control Handswitch 1,2-NA-103 (Note 4)
Disconnect Switch from D/G 11 (21) to 4kV Bus 11 (21) 1,2-NA-106 (Note 4)
Disconnect Switch from D/G 12 to 4kV Bus 11 (21) 1,2-HS-3470 (Note 2)
- 11 (21) AFW Pp Rm Exhaust Fan Handswitch 1,2-HS-5471 (Note 2)
- 12 (22) AFW Pp Rm Exhaust Fan Handswitch 1,2-NB-102 (Note 5)
- 11 (21) Containment Cooler Controller 1,2-NB-ll4 (Note 5)
- 12 (22) Containment Cooler Controller 1,2-NB-402 (Note 5).
- 13 (23) Containment Cooler Controller 1,2-NB-414 (Note 5)
- 14 (24) Containment Cooler Controller 1,2-PS-5404 (Note 6)
- 11 (21) ECCS Pp Rm' Cooling Fan Pressure Switch 1,2-PS-3405 (Note 6)
- 12 (22) ECCS Pp Rm Cooling Fan Pressure Switch 1,2-PY-5405 (Note 6)
- 12 (22) ECCS Pp Rm Cooling Fan Relay-1,2-SV-1645 (Note 3)
SRW to #12 D/G - Unit One (2) Solenoid Valve 1,2-SV-1646 (Note 3)
SRW from #12 D/G - Unit One (2) Solenoid Valve 1,2-SV-5170 (Note 6)
ECCS Pp Rm Cooler 11 (21) SW Inlet Solenoid Valve 1,2-SV-5171 (Note 6)
ECCS Pp Rm Cooler 11 (21) SW Outlet Solenoid Valve 1,2-SV-5173 (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Inlet Solenoid Valve Ig2-SV-5174 (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Normal Outlet Solenoid Valve lo2-SV-5175 (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Normal B/U Outlet Solenold Valve 1,2-SV-5177 (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Aux Outlet Solenoid Valve 1,2-SV-5178 (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Aux B/U Outlet Solenold Valve 1,2-ZS-5170A(B) (Note 6)
ECCS Pp Rm Cooler 11 (21) SW Inlet Open (Close) Pos. Ind.
1,2-25-5171A(B) (Note 6)
ECCS Pp Rm Cooler 11 (21) SW Outlet Open (Close) Pos. Ind.
ATTACHMENT (1) 1 ADDITIONS TO CALVERT CLIFFS 10 CFR 50.49 LIST y
Comporvent No.
Description 1,2-ZS-5173A(B) (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Inlet Open (Close) Pos. Ind.
1,2-ZS-5174A(B) (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Normal Outlet Open (Close) Pos. Ind.
1,2-ZS-5175A(B) (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Normal B/U Outlet Open (Close) Pos. Ind.
1,2-ZS-5177A(B) (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Aux Outlet Open (Close) Pos. Ind.
1,2-ZS-5178A(B) (Note 6)
ECCS Pp Rm Cooler 12 (22) SW Aux B/U Outlet Open (Close) Pos. Ind.
l 2-HS-302XC (Note 1)
LPSI Pp 21 Local Control 2-HS-2085 (Note 1)
Instrument Air Header Containment-Iso Valve Handswitch 2-HS-320!D (Note 1)
Saltwater Pp 23 Local Control 2-ZS-1585A(B) (Note 1)
Containment Cooler 22 Outlet Open (Close) Pos. Ind.
2-ZS-1593A(B) (Note 1)
Containment Cooler 24 Outlet Open (Close) Pos. Ind.
~2-ZS-382SA(B) (Note 1)
Shutdown HX 21 Comp Cooling Outlet Open (Close) Pos. Ind.-
2-ZS-3830A(B) (Note 1)
Shutdown HX 22 Comp Cooling Outlet Open (Close) Pos. Ind.
Note (1h This equipment was added to the 10 CFR 50.49 list after comparison of the Unit One and Unit '2 lists yielded these discrepancies. While these items were omitted from the list due to an administrative error, this equipment type had qualification files established.
This equipment is located in a radiation only harsh environment.
Note (2h This equipment was added to the 10 CFR 50.49 list following a review of the recent additions to our list of safety-related items. These additions resulted from an ongoing Engineering Design review of safety related equipment. The items are located in a radiation only harsh environment and are included in our LOCA emergency operating procedure.
Note (3h This equipment was added to the 10 CFR 50.49 list after a review of the instrument index for potential additions to the 50.49 list. While these items were omitted from the list due to an administrative error, this equipment type had qualification files estab!!shed. This equipment is located in a radiation only harsh environment.
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Note (4h This equipment was added to the 10 CFR 50.49 list during recent inspections of equipment in harsh areas. They are located in a radiation only harsh environment and must function to assure that the diesel generators can feed 4kV Bus 11.
Nste (Sh This equipment was added to the 10 CFR 50.49 list during recent inspections of equipment in harsh areas. They are located in a radiation only harsh environment and are required during SIAS initiation to shif t the containment cooler fans into slow speed.
Note (6h This equipment was added to the 10 CFR 50.49 list following review of success paths by a task force consisting of Design Engineering (Electrical, Instrument and Control, and Mechanical), Operations, and Reliability and Risk Assessment personnel. This equipment is located in a radiation only harsh environment.,
ATTACHMENT (2)
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SUPPLEMENT TO QUALIFICATION
SUMMARY
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SUBJECT:
QUALNO CBLO11 l
Hatfleid Wire and Cable
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]
1 l$
The insulation system used in this cable \\ General Electric No. 9025 sillcone rubber. This g/
Is a methyl phenyl compound as attested by References 9 and 9a. The Wyle Test Report j
No. 46111-0 identifies Specimen 6.1 as the cable with the same insulation. The FIRL d
Test Report No. F-C2781 Identifies GE silicone rubber SE-9025. Both of these silicone compounds are methyl phenyl base. Reference 13 and 9a support this determination.
Therefore, it is concluded that the compound identified by QUALNO CBLO11 is similar to that which was tested.
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11Ma 3/2,Is, ;}k C
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