ML20237J569
| ML20237J569 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/29/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| GL-86-15, NUDOCS 8708260223 | |
| Download: ML20237J569 (11) | |
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B ALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203
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JostpH A.TigRNAN vice Pacsiocar NucLcAn ENcROY May 29,1987 U. S. Nuclear Regulatory Commission l
Region I 631 Park Avenue l
King of Prussia, PA 19406 ATTENTION:
Mr. William T. Russell l
Regional Administrator
SUBJECT:
Calvert Cliffs Nuclear Power Plant l
Unit No. 2; Docket No. 50-318 l
Environmental Qualification of Unit Two Electrical Equipment
REFERENCE:
(a) Letter from Mr. J. A. Tiernan (BG&E), to Mr. W. T. Russell (NRC),
dated May 22, 1987, Environmental Qualification of Unit One Electrical Equipment (b) Generic Letter 86-15, Information Relating to Compliance with 10 CFR 50.49, " Environmental Qualification of Electric Equipment important to Safety for Nuclear Power Plants," September 22,1986 Gentlemen:
During an NRC inspection of our Environmental Qualification (EQ) Program the week of March 23,1987, it was noted that Calvert Cliffs Units 1 and 2 each had two solenoid valves under the scope of 10 CFR 50.49 with undocumented taped splices. Subsequent to the NRC inspection, a sampling of Unit 2 10 CFR 50.49 solenoid valves revealed additional undocumented taped splices. Based on this, the Baltimore Gas and Electric Company decided to shutdown Unit 1 on April 1,1987, (Unit 2 was already in a refueling outage), and perform a review of the installed configuration of both Units' 10 CFR 50.49 equipment.
As discussed in Reference (a), a comprehensive program was developed to inspect in detail all splices on 10 CFR 50.49 equipment, to inspect 10 CFR 50.49 equipment to check the installed configurations against the EQ files, and to resolve or repair discrepancies when identified.
Our Quality Assurance organization has provided independent review to ensure complete and proper documentation of inspections and subsequent reinspection following corrective maintenance in response to discrepancies.
We have also contracted an EQ consultant to provide additional expertise.
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' Mr. William T. Russell May 29,1987 Page 2 A summary of corrective measures, as well as interim EQ program modifications, is provided in Enclosure (1).
Additionally, a summary of all 10 CFR 50.49 equipment Inspected is provided in Enciosure (2).
I 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 control that equipment by an Interim Program, pending engineering review, for possible permanent addition to the list of 10 CFR 50.49 equipment. This equipment is listed in Enclosure (3). The summary of equipment inspected provided in Enclosure (2) reflects these additions.
Based on our inspections, verification of installed equipment and/or review of documentation, and corrective measures, all Unit 2 equipment within the scope of 10 CFR 50.49 is qualified with the exception of equipment for which a justification for continued operation has been written in accordance with Reference (b). To prevent recurrence in the future, additional long-term measures will be taken including upgraded program controls and an independent evaluation of our EQ program. These measures are summarized in Enclosure (4).
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, in f(.// N W 3AT/LSL/ dim Enclosures cc: D. A. Brune, Esquire
- 3. E. Silberg, Esquire R. A. Capra, NRC S. A. McNeil, NRC T. Foley/D. C. Trimble, NRC l
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L ENCLOSURE (1)
ACTIONS THE BALTIMORE GAS & ELECTRIC COMPANY HAS TAKEN PRIOR TO START-UP OF UNIT 2 TO ENSURE QUALIFICATION OF UNIT 2 EQUIPMENT WITHIN THE SCOPE OF 10 CFR 50.49 It was demonstrated to the Manager-Nuclear Operations that all 10 CFR 50.49 equipment (with the exception of that equipment for which a justification for continued operation has been written) complies with Environmental Qualification (EQ) requirements and is qualified without exception. This demonstration consisted of the below items.
1.
For inspected equipment:
an - Equipment Qualification Design Engineer (EQDE) or Qualified Equipment Qualification Reviewer (QEQR) reviewed ' all inspection checksheets for 10 CFR 50.49 equipment to ensure this equipment complies with EQ requirements, l
an engineer performed the post-maintenance inspection of all reworked splices and the rework of other selected components, a post-maintenance checksheet for equipment that was reworked was reviewed by an EQDE or QEQR to ensure the equipment complies with EQ requirements, and a written notification was provided to the Shift Supervisor, and a
normal post-maintenance operational
- test, as described in j
Enclosure (2), was or will be performed on all reworked equipment.
l 2.
We have performed inspections and/or review of the documentation of all i
10 CFR 50.49 equipment listed in Enclosure (2). These inspections included use of comprehensive checksheets (which include commodities, when appropriate, such as termination hardware, wire, lubricants, gaskets) developed by engineering personnel. Examples of these were recently provided to the NRC. Our Quality l
Assurance organization has reviewed documentation to ensure that:
modifications were completed on items with identified deficiencies, and all documentation (inspections and modifications) was reviewed and determined to be adequate by either an EQDE or a QEQR.
3.
Variations in Raychem shrink' tubing applications, not specifically approved by the manufacturer, have been incorporated into the EQ files. These are supported by qualification test reports.
4.
We have performed a detailed evaluation of one lead of a 10 CFR 50.49 4 Kv motor from Unit 1. This included the complete dissection and analysis of the entire splice to determine the method of application of the tape as well as the tape material. A 1
sample of tape from each 10 CFR 50.49 4 Kv motor lead in Unit 2 was also i
analyzed.
The termination splice procedures for both units are identical. The insulation for 4 Ky motor lead cable terminations was verified to be adequate based on the above dissection and tape analyses and specific qualification data has been added to the 4 Kv motor qualification file. !
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ENCLOSURE (1)
. ACTIONS THE BALTIMORE GAS & ELECTRIC COMPANY HAS TAKEN PRIOR TO START-UP OF UNIT 2 TO ENSURE QUALIFICATION OF UNIT 2 EQUIPMENT
- WITHIN THE SCOPE OF 10 CFR 50.49
- 5. f We pulled random (26) cable scheme numbers for Unit I and performed complete documentation' checks of these cables through. our cable routing, tagging, and procurement receipt inspection records. The purpose was to verify these processes
.which are identical for both Unit I and 2.
- 6.. All junction boxes' falling within the scope of 10 CFR 50.49 have been inspected and verified to meet EQ requirements.
blocks for motor operated valves in containment and spliced them to the field circuit using qualified Raychem shrink tubing.
- 8. 'The issue regarding overstress o.f Raychem as documented in Non-Conformance Report No. 3890 and subsequent memos was resolved.
i 9.
With regard to IE Notice 86-104 (Unqualified Butt Splice Connectors identified in Qualified Penetrations), no General Electric nylon insulated butt splice connectors are used in EQ penetration assemblies.
- 10. All 10 CFR 50.49 components associated with the below equipment, which could be visually inspected without disassembling or de-energizing the equipment have been i
inspected using checksheets. The purpose of the inspection was to confirm the j
installed configuration with what is detailed in the EQ files. The equipment is located within radiation-only harsh environments.
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Disconnect Switches These are 480 volt and 4 Kv disconnect switches with electrical connections of field cables directly bolted to NEMA bolt pads or terminated on quallfled terminal blocks.
Switchgear These are 4 Ky and 480 9olt switchgear assemblies with electrical connections of field cables directly bolted to NEMA bolt pads or terminated on qualified terminal blocks.
- Motor Control Centers 4
The 480 volt motor control centers have electrical connections of field cables directly bolted to NEMA bolt pads or terminated on qualified terminal blocks.
- 11. ' RTD cap splice terminations are reworked each refueling outage as part of a Surveillance Test Procedure (STP) which incorporates the EQ requirements for the 4
terminations. This STP was performed in May 1987.
ENCLOSURE (1)
' ACTIONS THE BALTIMORE GAS & ELECTRIC COMPANY
-HAS TAKEN PRIOR TO START-UP OF UNIT 2 TO ENSURE QUALIFICATION OF UNIT 2 EQUIPMENT WITHIN THE SCOPE OF 10 CFR 50.49 Interim upgraded program controls have been established to ensure clear communication of EQ maintenance requirements to the craftsman and to ensure work is completed as directed in those maintenance requirements. A current 10 CFR 50.49 list has been issued to planners. The major portions of this interim program are summarized below.
To clearly communicate EQ maintenance instructions, we will:
prepare a checklist (EQ Equipment Traveler) 'to ensure all EQ requirements are incorporated in the maintenance work package, include connection, SIS wire, and terminal block requirements in qualification maintenance requirement sheets (QMRS),
attach pertinent QMRS and excerpts from E-406 (BG&E Electrical Design and Construction Standard) to the Maintenance Order (MO),
attach a post-maintenance checklist to the MO, and have each planned MO reviewed by an EQDE or QEQR prior to working the job. He will also ensure that all requirements from the EQ files including lubricants, gaskets, cable,_ cable splices, terminal lugs and tape (for 4 Kv motors), related to the specific application are included in the work package.
To ensure work is done in accordance with maintenance instructions prior to declaring equipment OPERABLE:
craf t supervision will do an in-field review of the job to determine and indicate which items of the Equipment Inspection Checklist are applicable (see Note 1 below),
a quality control inspector (see Note 1 below) and craftsman will complete the post-maintenance checklist, 1
craf t supervision will review the post-maintenance checklist, and j
a EQDE or QEQR will review the post-maintenance checklist and the work packages to ensure that the work performed complies with E-406, the applicable QMRS section, and the EQ files.
i NOTE (1): These requirements may be waived if in the judgment of the General Supervisor-Operations or Manager-Nuclear Operations, ALARA considerations outweigh the benefit of these additional checks.
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ENCLOSURE (2)
EQUIPMENT INSPECTED DURING BALTIMORE GAS & ELECTRIC COMPANY'S REVIEW OF UNIT 2 1'
The below 10 CFR 50.49 equipment received a comprehensive inspection.
These Inspections included use of checksheets developed by engineering personnel. An engineer performed the post-maintenance inspection of all reworked splices and the rework of other selected components. Typical post-maintenance and operational testing for this' equipment is Indicated in the below Notes.- If maintenance was associated with the Engineered Safety Features Actuation System, proper response wlil be tested prior to entering the Mode of Operation for which the equipment is required to be operable in accordance.with the Technical Specificatbns. CCI-104 (Surveillance Test Program) and Operational Administration Procedures provide guidance for operational retests. ~
TOTAL NUMBER TOTAL NUMBER EQUIPMENT INSTALLED INSPECTED 1
Soleno'd Valves and Position Switches (Note 2) 106 106 i
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- Motor-Operated Valves (Note 2) 42 42 480V Motors (Note 3) 24 24 i
Penetrations (inside/outside containment) (Note 4) 74 74 Instrumentation (Note 5) 110 110 Motor-Operated Dampers (Note 6) 3 3
In-Line Junction Boxes (Note 7) 19 19 I
4 KV Motors (Notes 1 and 4) 7 7
Handswitches (Note 8) 15 15 Indicating-Type Relay (Note 8) 1 I
Hydrogen Recombiners and Controllers (Note 9) 2 2
Disconnect Switches (Notes 8 and 10) 8 8
Switchgear (Notes 8 and 10) 3 3
i Motor Control Centers (Notes 8 and 10) 5 5
RTD Cap Spilce Terminations (Notes 11 and 12) 16 0
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ENCLOSURE (2)
EQUIPMENT INSPECTED DURING BALTIMORE GAS & ELECTRIC COMPANY'S REVIEW OF UNIT 2 NOTE (lh See Item 4 of Enclosure (1).
l NOTE (2h The valve is stroked (including timing and flow verification as necessary) and proper position indication is verified.
j NOTE (3h The motor is meggered, phase rotation checked, and run tested.
NOTE (4h The applicable post-maintenance and operational testing for the specific equipment is performed after a visual inspection of work completed.
NOTE (5h Loop currents are measured.
Channel checks are performed when parameters reach normal ranges.
NOTE (6h The damper is stroked to verify proper operatien.
NOTE (7h Visual Inspection NOTE (8h No maintenance was performed.
NOTE (9h Af ter meggering, a test run is performed.
NOTE (10h See Item 10 of Enclosure (1).
NOTE (llh See item 11 of Enclosure (1).
NOTE (12h Reference resistance measurements were taken.
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ENCLOSURE (3)
ADDITIONS TO THE UNIT TWO 10 CFR 50.49 LIST Component No.
Description 2-N A-103 Disconnect Switch from D/G 11 to 4kV Bus 21 2-N A-106 Disconnect Switch from D/G 12 to 4kV Bus 21 2-HS-302XC LPSI Pp 21 Local Control Handswitch 2-HS-2085 Instrument Air Header in Containment-Iso Viv Hand 3 witch 2-HS-5201D SW Pp 23 Local Control Handswitch 2-HS-5470 AFW Pp Rm Exhaust Fan #21 Handswitch 2-HS-5471 AFW Pp Rm Exhaust Fan #22 Handswitch I
2-NB-102 (Note 1)
- 21 Containment Cooler Controller 2-NB-114 (Note 1)
- 22 Containment Cooler Controller 2-NB-402 (Note 1)
- 23 Containment Cooler Controller 2-NB-414 (Note 1)
- 24 Containment Cooler Controller 2-PS-5404 (Note 2)
- 21 ECCS Pp Rm Cooling Fan Pressure Switch 2-PS-5405 (Note 2)
- 22 ECCS Pp Rm Cooling Fan Pressure Switch 2-PY-5405 (Note 2)
- 22 ECCS Pp Rm Cooling Fan Relay 2-SV-1645 SRW to #12 D/G - Unit 2 Solenoid Valve 2-SV-1646 SRW from #12 D/G - Unit 2 Solenoid Valve 2-SV-5170 (Note 2)
ECCS Pp Rm Cooler 21 SW Inlet Solenoid Valve j
I 2-SV-5171 (Note 2)
ECCS Pp Rm Cooler 21 SW Outlet Solenoid Valve 1
2-SV-3173 (Note 2)
ECCS Pp Rm Cooler 22 SW Inlet Solenoid Valve l
2-SV-5174 (Note 2)
ECCS Pp Rm Cooler 22 SW Normal Outlet Solenoid Valve 2-SV-5175 (Note 2)
ECCS Pp Rm Cooler 22 SW Normal B/U Outlet Solenoid Valve 2-SV-5177 (Note 2)
ECCS Pp Rm Cooler 22 SW Aux Outlet Solenoid Valve j
2-SV-5178 (Note 2)
ECCS Pp Room Cooler 22 SW Aux. B/U Outlet Solencio Valve 2-Z5-1585A Containment Cooler 22 Outlet Viv Control-Open Position Indication 2-ZS-1585B Containment Cooler 22 Outlet Viv Control-Close Position Indication 2-ZS-1593A Containment Cooler 24 Outlet Viv Control-Open Position Indication )
2-ZS-1593B Containment Cooler 24 Outlet Viv Control-Close Position Indication 2-ZS-3828A CC Outlet SDCHX 21 Control-Open Position Indication 2-ZS-3828B CC Outlet SDCHX 21 Control-Close Position Indication 2-ZS-3830A CC Outlet SDCHX 22 Control-Open Position Indication l
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ENCLOSURE (3)
ADDITIONS TO THE UNIT TWO 10 CFR 50.49 LIST Component No.
Description j
2-ZS-3830B CC Outlet SDCHX 22 Control-Close Position Indication i
2-ZS-5170A (Note 2)
ECCS Pp Rm Cooler 21 SW Inlet Open Position Indication j
2-ZS-5170B (Note 2)
ECCS Pp Rm Cooler 21 SW Inlet Close Position Indication j
2-ZS-5171 A (Note 2)
ECCS Pp Rm Cooler 21 SW Outlet Open Position Indication 2-ZS-5171B (Note 2)
ECCS Pp Rm Cooler 21 SW Outlet Close Position Indication 2-ZS-5173A (Note 2)
ECCS Pp Rm Cooler 22 SW Inlet Open Position Indication 2-ZS-5173B (Note 2)
ECCS Pp Rm Cooler 22 SW Inlet Close Position Indication 2-ZS-5174A (Note 2)
ECCS Pp Rm Cooler 22 SW Normal Outlet Open 2-ZS-5174B (Note 2)
ECCS Pp Rrn Cooler 22 SW Normal Outlet Close 2-ZS-5175A (Note 2)
ECCS Pp 9m Cooler 22 SW Normal B/U Outlet Open 2-ZS-5175B (Note 2)
ECCS Pp Em Cooler 22 SW Normal B/U Outlet Close 2-ZS-5177A (Note 2)
ECCS Pp Rm Cooler 22 SW Aux Outlet Open 2-ZS-5177B (Note 2)
ECCS Pp Rm Cooler 22 SW Aux Outlet Close 2-ZS-5178A (Note 2)
ECCS Pp Rm Cooler 22 SW Aux B/U Outlet Open 2-ZS-5178B (Note 2)
ECCS Pp Rm Cooler 22 SW Aux B/U Outlet Close Note (th This equipment is incJ.uded under the heading Motor Control Centers in Enclosure (2).
Note (2h This equipment hn a justification for continued operation written in accordance with Generic Letter 86-15, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," September 22,1986
' ENCLOSURE (4)
ADDITIONAL ACTIONS THE BALTIMORE GAS & ELECTRIC COMPANY WILL TAKE SUBSEQUENT TO START-UP OF UNIT 2
.l.. Selected EQ files will be reviewed by an EQ consultant. (July 1987) 2.
An independent evaluation will be performed on the EQ program by a team which includes expertise in EQ. (August 1987) 3.
The issue regarding inconsistencies in E-406 documented in Non-Conformance Report No. 3890 and subsequent memos will be resolved. (July 1987) e, l-1
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May 29,1987
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SUMMARY
OF CALVERT CLIFFS UNIT TWO'S i
3 JUSTIFICATION FOR CONTINUED OPERATION 1
I A review' of the present configuration of the ECCS Pump Room Cooler solenold valves, position switches, pressure switches and relay (Table 1 below) has been performed. A preliminary assessment has shown the agove equipment is quallflable for this radiation only harsh environment (maximum 3.8x10 rads).
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' A step has been included early in the LOCA Emergency Operating Procedure to have the l
operator remotely open (de-energize) the solenoid valves using existing.handswitches in the control room. The operators will be instructed on this change-to EOP-5 prior to entering MODE 4. This will open the ECCS pump room cooler control valves, turn on the cooler motors, and remove the temperature control loop (comprised partially of the pressure switches and relays) from the electrical circuit. Therefore, a subsequent failure of the temperature control loop cannot affect the operability of the coolers or mislead '
the operator.
The step provides assurance that flow will be established and valve -
position verified.' This equipment will be' operated before it is exposed to the harsh
.J radiation environment.
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Qualification of all equipment involved will be completed by July 31, 1987.- This will include-a review to ensure proper electrical separation.
If rerouting is required, engineering for the rerouting will be issued to the field by August 31,1987, and the work completed at the next outage of sufficient duration.
TABLE 1 i
IDENTIFICATION #
MANUFACTURER MODEL #
LOCATION 2-SV-5170 ASCO HPX 8320A26 A201 2-SV-5171 ASCO HPX 8320A26 A201 2-SV-5173 ASCO HPX 8320A26 A201 2-SV-5174 ASCO HPX 8320A26 A201 S-SV-5175 ASCO NP 8320A185E A201 r
2-SV-5177 ASCO HPX 8320A26 A201 1
2-SV-5178 ASCO HPX 8320A26 A201 All Position Switches
,Magnetrol 496-2 A201 All Pressure Switches Johnson F7221 A101/A102 j
2-PY-5405 Square D 8501 A414 i
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