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| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC |
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| | t t t B ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE. MARYLAND 21203 JostpH A.flERNAN vie Pntsiotut NUCt tA8r Entmov |
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| | October 18, 1988 U. S. Nucl ear Regulatory Commission Washington, DC 20555 A'ITENTION: Document Control Desk |
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| | ==SUBJECT:== |
| | Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 AShiE Section XI Pumo and Valve Inservice Test (IST) Program |
| | |
| | ==REFERENCE:== |
| | (a) Letter from Mr. S. A. hicNeil (NRC) to Mr. J. A. Tiernan (BG&E), |
| | dated August 9, 1988, Request for Additional Information (TACS 64976 and 64977) |
| | Gentlemen: |
| | This letter constitutes our reply to Reference (a). As requested, a complete, revised IST program plan is enclosed. Our response to the Request for Additional Information (RAI) is discussed below. |
| | Enclosure (1) provides a detai'ed discussion in response to Valve Program item N;. I and Pump Program item No.1. We are not including the emergency diesel generator air start and fuel oil transfer Systems in our IST Program for the reasons provided therein. We do not believe that the testing of these systems in accordance with ASME Section XI is required or of any benefit. |
| | Valve Program item 2 identified txo relief requests that were both numbered A-3. In the revised IST program plan (Enclosure 2), Relief Request A-3 is that request identified as such in the March 30, 1988 submittal. Relief Request A-4 in Enclosure (2) is the previous A-3 in the July 5,1988 submittal. |
| | We have re-evaluated the relief request numbered AF-1 in the March 30, 1988 submittal, and decided to ivithdraw that request. We have included those ialves on the cold shutdown list in our revised program plan. |
| | In response to Valve Program item 4, additional technica! Justification is provided in the revised program plan for relief requests SI-6 and 51-7. We also have defined the abbreviation 'ITP." |
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| | 0010240156 G81010 ; |
| | PDR ADOCK0500g7 g P , |
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| | Doct ment Control Desk - |
| | Octolwr 18,' 1988 Pa58 2 t |
| | i As _ requested in Velve Program item 2, the basis and alternative testing of Relief Riquest No. 7 was clarified to require that all data would normally be' taken on a quarterly frequency. |
| | Should you have any further questions regarding this matter, we will be pleased to - |
| | discuss them with you. |
| | Very truly yours, b ' |
| | i JAT/SRC/BSM/dlm Enclosures cc: D. A. Brune. Esquire J. d. Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC D. C. Trimble/V. L. Pritchett, NRC T. Magette, DNR I |
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| | ENCLbSURE (1) |
| | RESPONSE TO NRC VALVFJOGRA M ITEM (1) AND PUMP PROGRAM ITEM (1) ON TIIE PROPOSED SECOND TEN-YEAR INTERVAL OF TIIE CALVERT CLIFFS ASME SECTION XI PUMP AND VALVE INSERVIGE IIST (ITT) PROGRAM INTRODUCTION AND OVERVl3 The NRC staff has requested thit the scope of the IST program be expanded during the next !0-year interval to include the valves and pumps in the emergency diesel generator (EDG) air start and fuel oil transfer "ystems. In response to this request, We have reviewed the requirements for establishing the scope of the IST program as set forth in 10 CFR 50.55h, NRC Regulatory Guide 1.26 and the Calvert Cliffs Operating License. As a result of this review, we have reaffirmed that testind of these components under our IST program is neither required nor necessary. The following summanizes our findings: |
| | Finding No. I: The EDG Air Start and Fuel Oil Transfer Systems Are Not Reauired to be Tested Under the Calvert Cliffs IST Program. |
| | Those systems and components that are regulfed to be included within the IST program are identified by 10 CFR 50.55a as those which are chssified as ASME Code Class 1, 2 or 3. The IST program scope (along with requirements relative to plant design features), is further defined in paragraph 50.55a(gX3)(iv), which states: |
| | "Pumps and valves which are classified as ASME Class 2 and Class 3 shall be designed and provided with access to enable the performance of inservice testing . . ." (emphasis added). |
| | Regulatory Guide 1.26 provides a method acceptable to the NRC for identifying the quality standard and ASME code classification applicable to components containing water, steam or radioactive waste. In addition, Regulatory Guide 1.26 states clearly that: |
| | "Other systems not covered by this guide, such as instrument end tervice air, diesel engine and its eenerators and autiliarv suncrt systems, diesel |
| | [ud, emergency and normal ventilation, fuel handling, and radioactive waste management systems, should be designed, fabiicated, erected, and tested to quality standards commensurate with the safety function to be perfortned." (emphasis added) |
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| | , ,o ENCLOSURE (t) |
| | In accordance with the above regulations and regulatory guidance all Code Class 1, 2, and 3 components werc identified during the plant design phase prior to the issuance of the plant operating license. This component classification formed the basis for 'he list of components included in the initial IST Program, as approved by the NRC on February 8, 1982. Since these systems are not classified as either Code Class 1, 2, or 3 testing under the IST Program is not required. |
| | Finding No. 2: The EDG Air Start and Fuel Oil Transfer Systems are Already Subiected to Testina Commensurate with the Safety Function Thev Pfrform. |
| | Both the air start and fuel oil transfer systems are subjected to testing which regularly verifies their operational readiness. This testing is conducted in accordance with the Calvert Cliffs Technical Specifications under the surveillance test program. Eight different Surveillance Test Procedures (STPs) exist in this program which require rasting of the diesel generators and their auxiliary systems in various combinations on a monthly, semiannual and refueling-outage basis. Testing under this program requires a sum total of at least 36 tests per diesel generator per year, each of which confirms the operational readiness of the diesel generator and its support systems. Furthermore, the STPs require that attention be focused on the performance of the air start and fuel oil transfer systems. This is done during each test by ensuring that air receiver pressure drops by a specified amount ar.d that fuel oil is automatically made up to maintain day tank level. |
| | Finding No. 3: The Valves and Pumos Within the EDG Air Start and Fue; Oil Transfer Systems are liinhly Reliable and are Well-Maintained. |
| | In response to NRC Generic Letter 84-15, a diesel generator reliability program was established following the guidelines of the generic letter and Regulatory Guide 1.108. |
| | The scope of the program encompasses the entire EDG unit, consistent with the Regulatory Guide 1.108 definition; i.e., |
| | "A ' diesel generator' unit consists of the engine, generator, cor.1bustion air system, cooling water system up to the supply, [gl sucolv system, lub-ricating oil system, Wrtine enerny system, autostart controls, 11anual con-trols, and diesel generator breaker." (emphasis added) |
| | Under this program, failures of the diesel generators have been trended since 1985. To date, no failure of a diesel generator unit has been attributed to the air start or fuel oil transfer systems. A separate review of all maintenance work perf ormed on she EDG air start and fuel oil transfer systems since initial plant operation revealed no component malfunctions or deleterious conditions that would have reduced system operational readiness. |
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| | , FJiCLOSURE (1) |
| | CONCLUSIDH The ASME Calvert Cliffs Section XI Inservice Testing Program for pumps and valves, as approved by the NRC in 1982, is in compliance with 10 CFR 50.55a. Expansion of the IST program to include the EDG air start and fuel oil transfer systems is not required and would provide no greater assurance of operational readiness. Therefore, we decline to add these systems to the IST Program. |
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MONTHYEARML20236Q5421987-11-13013 November 1987 Requests Addl Info Re Proposed Inservice Testing Program for safety-related Pumps & Valves,Described in Util . Discussion of Request for Addl Info at Proposed Dec 1987 or Jan 1988 Util/Nrc Inservice Testing Conference Recommended Project stage: RAI ML20151R5861988-04-19019 April 1988 Requests Response to Questions Provided in 871113 Request for Addl Info Re Proposed Inservice Test Program for safety- Related Pumps & Valves within 70 Days of Ltr Date,Per 880218 & 19 Meeting.Trip Rept for Pump & Valve Encl Project stage: RAI ML20207D3021988-08-0909 August 1988 Forwards Request for Addl Info Re Proposed Pump & Valve Inservice Testing Program.Response Requested within 70 Days of Ltr Date Project stage: RAI ML20204G5771988-10-18018 October 1988 Forwards Rev 1 to ASME Section XI Pump & Valve Test Programs-Units 1 & 2 Second 10-Yr Interval, Per NRC 880809 Request.Response to Valve Program Item 1 & Pump Program Item 1 Also Encl Project stage: Other 1988-10-18
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20138H3831999-10-25025 October 1999 Forwards Draft Model of Renewed License for Calvert Cliffs, Unit 2 to Illustrate How List of Minimum Requirements Could Be Incorporated Into License Condition ML20217M9991999-10-22022 October 1999 Forwards Response to NRC 990930 RAI Re Void Swelling Degradation Mechanism,Per License Renewal Application for Ccnpp,Units 1 & 2 ML20217M1721999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept Form Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates ML20212M2631999-10-0404 October 1999 Informs That Staff Concluded That Licensee Responses to GL 97-06 Provides Reasonable Assurance That Condition of Util SG Internals in Compliance with Current Licensing Bases for Calvert Cliffs Nuclear Power Plant ML20216J8671999-10-0101 October 1999 Forwards Rev 52 to QA Policy for Calvert Cliffs Nuclear Power Plant. Rev Accurately Presents Changes Made Since Previous Submittal,Necessary to Reflect Info & Analyses Submitted to NRC or Prepared,Per to NRC Requirements ML20212J7811999-09-30030 September 1999 Requests That Licensee Address Potential Aging Mgt Issue Re Effects of Void Swelling of Rv Internals by Making Plant Specific Commitment to Implement Focused age-related Degradation Insp for Evidence of Void Swelling in Future ML20212J5611999-09-29029 September 1999 Informs That on 990916,NRC Completed mid-cycle Plant Performance Review of Calvert Cliffs.No Areas in Which Util Performance Warranted Addl Insp Beyond Core Insp Program Identified.Historical Listing of Plant Issues,Encl ML20216H7831999-09-28028 September 1999 Forwards Addl Info Re NRC SER for Ccnpp,Units 1 & 2,per License Renewal Application ML20212D5361999-09-20020 September 1999 Forwards Rev 1 to Calculation CA04048, Fuel Handling Accident During Reconstitution, as Agreed During 990909 Telcon ML20212C1861999-09-15015 September 1999 Requests That NRC Complete Review of TR CED-387-P,Rev 00-P, Abb Critical Heat Flux Correlations for PWR Fuel, by 000201.Util Expects to Use ABB-NV Correlation for Current non-mixing Vane Fuel in Reload Analyses in 2000 for Ccnpp ML20212A2001999-09-0808 September 1999 Forwards Insp Repts 50-317/99-06 & 50-318/99-06.Two Violations Being Treated as Noncited Violations ML20211N8971999-09-0707 September 1999 Responds to Ltr to D Rathbun of NRC Dtd 990720,in Which Recipient Refers to Ltr from Wc Batton Expressing Support on Renewal Application of Baltimore Gas & Electric Co for Calvert Cliffs Plants ML20211H9841999-08-31031 August 1999 Provides Comments Re Data Entered in Rvid for Ccnpp,Units 1 2,per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211K3091999-08-27027 August 1999 Informs That During 990826 Telcon,L Briggs & B Bernie Made Arrangements for NRC to Inspect Licensed Operator Requalification Program at Calvert Cliffs Npp.Insp Planned for Wk of 991025 ML20211J1611999-08-17017 August 1999 Documents Bg&E Consultations with MD Dept of Natural Resources Re Potential Impacts to Chesapeake Bay Critical Area & Forest Interior Dwelling Bird Habitat,Per Ccnpp License Renewal.Telcons Ref Satisfy Consulting Requirement ML20210V1181999-08-17017 August 1999 Forwards Toxic Gases Calculations for Control Room Habitability,As Discussed During 990713 Telcon.Util Will Make Final Submittal for Toxic Gases After NRC Has Completed Review of ARCON96 ML20210T5061999-08-16016 August 1999 Forwards Rev 0 to Ccnpp COLR for Unit 2,Cycle 13, Per Plant TS 5.6.5 ML20210U2761999-08-13013 August 1999 Forwards Listed Info Re Guarantee of Payment of Deferred Premiums for Ccnpp,Units 1 & 2,IAW 10CFR140.21 Requirements ML20210S8101999-08-12012 August 1999 Forwards Application Requesting Renewal of License for Mv Seckens,License SOP-10369-2.Without Encl ML20210S8131999-08-12012 August 1999 Forwards Summary of Various Open Licensing Actions for Bg&E That Were Completed During Unit 2 Refueling Outage Ending 990506 ML20210S7901999-08-12012 August 1999 Forwards semi-annual Fitness for Duty Program Performance Data for Period of 990101-990630,IAW 10CFR36.71(d) ML20210Q1941999-08-11011 August 1999 Informs That Info Submitted in 981130 Application Re CEN-633-P,Rev 03-P,dtd Oct 1998,marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended ML20210N5881999-08-0606 August 1999 Forwards ISI Rept for Ccnpp,Unit 2,fulfilling Intentions & Requirements Stated in Program Plan & Commitment to Comply with ASME Code Section XI ISI Requirements ML20210N5471999-08-0505 August 1999 Requests That License SOP-10031-3,for DF Theders,Be Removed from Active Files for Ccnpp,Due to Individual Being Reassigned to Position No Longer Requiring License ML20210N5491999-08-0505 August 1999 Requests That License SOP-10371-2,for RW Scott,Be Renewed IAW 10CFR55.57.Individual Has Satisfactorily Discharged License Responsibilities Competently & Safely.Without Application ML20210N1291999-08-0505 August 1999 Forwards NRC Response to W Batton Ltr Expressing Support of Renewal Application for Calvert Cliffs Plants as Requested in Ltr ML20210N9291999-08-0404 August 1999 Forwards Clarification to Initial Response to Biennial Rept on Status of Decommissioning Funding,As Required by 10CFR50.75(f)(1) ML20211C0951999-07-30030 July 1999 Expresses Appreciation for Participation in Y2K Training & Tabletop Exercise Held on 990714 ML20211B5381999-07-30030 July 1999 Expresses Appreciation for Support in Y2K Training & Tabletop Exercise Held on 990714.Suggests Referral to NRC Y2K Web Site to View Issues & Lessons from Tabletop That Will Be Tracked by NRC ML20210J0741999-07-30030 July 1999 Expresses Appreciation for Participation in Y2K Training & Tabletop Exercise on 990714.Suggests Referral to NRC Y2K Web Site to View Issues & Lessons from Tabletop That Will Be Tracked by Nrc.Web Site Should Reflect Info within 2 Wks ML20211C3251999-07-30030 July 1999 Expresses Appreciation for Participation in Y2K Training & Tabletop Exercise Held on 990714 ML20210E4941999-07-23023 July 1999 Informs That 1999 Emergency Response Plan Exercise Objectives Is Scheduled for Wk of 991025.Exercise Scenario Will Test Integrated Capability & Major Portion of Elements Existing within Emergency Response Plan ML20210D0911999-07-22022 July 1999 Responds to to Chairman Jackson Referring to Ltr from New 7th Democratic Civic Club,Inc.Forwards Staff Response to W Batton,President of New 7th Democratic Civic Club,Inc ML20210C5011999-07-21021 July 1999 Informs That SL Walters,License OP-10096-3 & CC Zapp,License Number SOP-2188-9,have Been Reassigned within Organization & No Longer Require NRC License,Per 10CFR50.74(a).Removal of Subject Licenses from Active Files for Ccnpp,Requested ML20210A5021999-07-20020 July 1999 Responds to ,Expressing Support for Renewal of Operating Licenses for Calvert Cliffs Plant & to Concerns Re Lack of Specificity for License Renewal Regulations & Length of Time Set Aside for Public Comment ML20211N9101999-07-20020 July 1999 Forwards Correspondence Author Received from New 7th Democratic Club Civic,Inc Raising Some Serious Concerns About Renewal of Nuclear Reactor Licenses for Calvert Cliffs Power Plant ML20210C2681999-07-20020 July 1999 Forwards Certified Copy of Listed Nuclear Liability Policy Endorsement,Per 10CFR140.15(e) ML20210C8461999-07-19019 July 1999 Informs That CF Farrow,License OP-10648-1,will No Longer Be Employed with Bg&E,As of 990709,per 10CFR50.74(a).Removal of Subject License from Active Files for Ccnpp,Requested ML20209J5171999-07-16016 July 1999 Forwards Comments from Accuracy Review of License Renewal Application SER ML20210B7651999-07-15015 July 1999 Forwards SER Denying Licensee Proposed TS Amend Dtd 981120, to Delete TS Requirements for Tendon Surveillance & Reporting Because TS Requirements Duplication of Requirements in 10CFR50.55a.Notice of Denial Encl ML20209G2081999-07-13013 July 1999 Forwards Insp Repts 50-317/99-05 & 50-318/99-05 on 990509- 0626.No Violations Noted ML20210A6311999-07-0606 July 1999 Discusses Closure of TACs MA0532 & MA0533 Re Response to Requests for Addl Info to GL 92-01,rev1,suppl 1, Reactor Vessel Structural Integrity, for Plant,Units 1 & 2 ML20209C1391999-07-0202 July 1999 Forwards Responses to Open & Confirmatory Items Based on Review of SER for Bg&E Application for Renewal of Operating Licenses for Calvert Cliffs.Bg&E Intends to Forward Comments Based on Accuracy Verification in Near Future ML20210D1531999-06-30030 June 1999 Informs of Receipt of from New 7th Democratic Civic Club,Inc Expressing Support for License Renewal. Requests Consideration in Addressing Concerns & Recommendations ML20209B5781999-06-29029 June 1999 Submits Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML20210D1741999-06-24024 June 1999 Expresses Opinions on Renewal of Nuclear Reactor Licenses Re Plant & Support Renewal Application of Bg&E.Requests That NRC Revise Procedures to Allow Sufficient Time for Public to Review,Evaluate & Respond to Info ML20211H8431999-06-23023 June 1999 Ack Participation of Calvert Cliffs Nuclear Engineering Dept in NRC Cooperative Research Project with Univ of Virginia. Copy of Relevant Portion of NRC Cooperative Agreement with Univ of Virginia Encl ML20196C6831999-06-21021 June 1999 Discusses Proposed Alternative Submitted by Bg&E for Calvert Cliffs NPP to Requirements of 10CFR50.55a(g)(4) in Regard to Compliance with Latest Approved Edition of ASME Code,Section XI for Third Ten Year Insp Interval Beginning on 990701 ML20196C4291999-06-21021 June 1999 Forwards Rev to ERDS Data Point Library for Ccnpp,Unit 2,per 10CFR50,App E,Section VI.3.a.Table Provides Brief Summary of Changes ML20195J8271999-06-16016 June 1999 Ack Receipt of to Jackson,Chairman of NRC Re Environ Impacts of Increased Patuxtent River Complex Flight Operations on Ccnpp.Clarification & Correction of Listed Statement Found on Page Two,Provided 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217M9991999-10-22022 October 1999 Forwards Response to NRC 990930 RAI Re Void Swelling Degradation Mechanism,Per License Renewal Application for Ccnpp,Units 1 & 2 ML20216J8671999-10-0101 October 1999 Forwards Rev 52 to QA Policy for Calvert Cliffs Nuclear Power Plant. Rev Accurately Presents Changes Made Since Previous Submittal,Necessary to Reflect Info & Analyses Submitted to NRC or Prepared,Per to NRC Requirements ML20216H7831999-09-28028 September 1999 Forwards Addl Info Re NRC SER for Ccnpp,Units 1 & 2,per License Renewal Application ML20212D5361999-09-20020 September 1999 Forwards Rev 1 to Calculation CA04048, Fuel Handling Accident During Reconstitution, as Agreed During 990909 Telcon ML20212C1861999-09-15015 September 1999 Requests That NRC Complete Review of TR CED-387-P,Rev 00-P, Abb Critical Heat Flux Correlations for PWR Fuel, by 000201.Util Expects to Use ABB-NV Correlation for Current non-mixing Vane Fuel in Reload Analyses in 2000 for Ccnpp ML20211H9841999-08-31031 August 1999 Provides Comments Re Data Entered in Rvid for Ccnpp,Units 1 2,per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20210V1181999-08-17017 August 1999 Forwards Toxic Gases Calculations for Control Room Habitability,As Discussed During 990713 Telcon.Util Will Make Final Submittal for Toxic Gases After NRC Has Completed Review of ARCON96 ML20210T5061999-08-16016 August 1999 Forwards Rev 0 to Ccnpp COLR for Unit 2,Cycle 13, Per Plant TS 5.6.5 ML20210U2761999-08-13013 August 1999 Forwards Listed Info Re Guarantee of Payment of Deferred Premiums for Ccnpp,Units 1 & 2,IAW 10CFR140.21 Requirements ML20210S7901999-08-12012 August 1999 Forwards semi-annual Fitness for Duty Program Performance Data for Period of 990101-990630,IAW 10CFR36.71(d) ML20210S8131999-08-12012 August 1999 Forwards Summary of Various Open Licensing Actions for Bg&E That Were Completed During Unit 2 Refueling Outage Ending 990506 ML20210S8101999-08-12012 August 1999 Forwards Application Requesting Renewal of License for Mv Seckens,License SOP-10369-2.Without Encl ML20210N5881999-08-0606 August 1999 Forwards ISI Rept for Ccnpp,Unit 2,fulfilling Intentions & Requirements Stated in Program Plan & Commitment to Comply with ASME Code Section XI ISI Requirements ML20210N5491999-08-0505 August 1999 Requests That License SOP-10371-2,for RW Scott,Be Renewed IAW 10CFR55.57.Individual Has Satisfactorily Discharged License Responsibilities Competently & Safely.Without Application ML20210N5471999-08-0505 August 1999 Requests That License SOP-10031-3,for DF Theders,Be Removed from Active Files for Ccnpp,Due to Individual Being Reassigned to Position No Longer Requiring License ML20210N9291999-08-0404 August 1999 Forwards Clarification to Initial Response to Biennial Rept on Status of Decommissioning Funding,As Required by 10CFR50.75(f)(1) ML20210E4941999-07-23023 July 1999 Informs That 1999 Emergency Response Plan Exercise Objectives Is Scheduled for Wk of 991025.Exercise Scenario Will Test Integrated Capability & Major Portion of Elements Existing within Emergency Response Plan ML20210C5011999-07-21021 July 1999 Informs That SL Walters,License OP-10096-3 & CC Zapp,License Number SOP-2188-9,have Been Reassigned within Organization & No Longer Require NRC License,Per 10CFR50.74(a).Removal of Subject Licenses from Active Files for Ccnpp,Requested ML20211N9101999-07-20020 July 1999 Forwards Correspondence Author Received from New 7th Democratic Club Civic,Inc Raising Some Serious Concerns About Renewal of Nuclear Reactor Licenses for Calvert Cliffs Power Plant ML20210C2681999-07-20020 July 1999 Forwards Certified Copy of Listed Nuclear Liability Policy Endorsement,Per 10CFR140.15(e) ML20210C8461999-07-19019 July 1999 Informs That CF Farrow,License OP-10648-1,will No Longer Be Employed with Bg&E,As of 990709,per 10CFR50.74(a).Removal of Subject License from Active Files for Ccnpp,Requested ML20209J5171999-07-16016 July 1999 Forwards Comments from Accuracy Review of License Renewal Application SER ML20209C1391999-07-0202 July 1999 Forwards Responses to Open & Confirmatory Items Based on Review of SER for Bg&E Application for Renewal of Operating Licenses for Calvert Cliffs.Bg&E Intends to Forward Comments Based on Accuracy Verification in Near Future ML20210D1531999-06-30030 June 1999 Informs of Receipt of from New 7th Democratic Civic Club,Inc Expressing Support for License Renewal. Requests Consideration in Addressing Concerns & Recommendations ML20209B5781999-06-29029 June 1999 Submits Response to GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Disclosure Encl ML20210D1741999-06-24024 June 1999 Expresses Opinions on Renewal of Nuclear Reactor Licenses Re Plant & Support Renewal Application of Bg&E.Requests That NRC Revise Procedures to Allow Sufficient Time for Public to Review,Evaluate & Respond to Info ML20196C4291999-06-21021 June 1999 Forwards Rev to ERDS Data Point Library for Ccnpp,Unit 2,per 10CFR50,App E,Section VI.3.a.Table Provides Brief Summary of Changes ML20195J6591999-06-16016 June 1999 Submits Proposed Alternative to Requirements of 10CFR50.55a(g)(4) (Automatic Compliance with Latest Approved Edition of ASME Code Every 120 Months).Proposal Will Apply Third ten-year ISI Interval,Scheduled to Begin 990701 ML20207F0201999-06-0101 June 1999 Forwards Third Interval Inservice Insp Program Plan for Ccnpp,Units 1 & 2, for NRC Review.Plan Satisfies Commitment Contained in Licensee to NRC 05000317/LER-1999-002, Requests That Cover Page for LER 99-002,dtd 990525,be Corrected to Indicate Rept Is Submitted Per Requirements of 10CFR20.2201(b)1999-05-28028 May 1999 Requests That Cover Page for LER 99-002,dtd 990525,be Corrected to Indicate Rept Is Submitted Per Requirements of 10CFR20.2201(b) ML20195B3751999-05-25025 May 1999 Forwards ECCS Codes & Methods Rept, as Required by 10CFR50.46(a)(3)(ii) ML20195B2521999-05-25025 May 1999 Submits Response to RAI Re LAR for Tube Repair Using Leak Limiting Alloy 800 Sleeves for Ccnpp,Units 1 & 2.Test Repts Encl ML20195B2271999-05-24024 May 1999 Forwards Certified Copy of Nuclear Liability Policy NF-216, Endorsement 128 ML20206U3051999-05-19019 May 1999 Submits Written Rept as Required follow-up to Verbal Rept Given to NRC Regional Administrator on 990419 of SG Tube Insps Conducted,Cause of Tube Degradation & Corrective Measures Taken as Result of Insp Findings ML20206U8281999-05-18018 May 1999 Forwards Missing Pages C-30,C-31,C-114 & C-115 from 990319 Response to NRC RAI, Wind Tunnel Modeling of Calvert Cliffs NPP Cpp Project 94-1040. Complete Copy of 1985 Rept, Wind Flows & Dispersion Conditions of Calvert Cliffs, Encl ML20212G9751999-05-12012 May 1999 Forwards Draft write-up Re OI 16 for F Grubelich to Consider ML20206K6921999-05-10010 May 1999 Forwards Certified Copy of Listed Nuclear Liability Policy Endorsements,In Compliance with 10CFR140.15(e).Without Encl ML20206K1711999-05-0707 May 1999 Informs That on 990430 Util Filed Encl Articles of Share Exchange with Maryland Dept of Assessments & Taxation to Form Holding Company,Constellation Energy Group,Inc (Ceg). CEG Is Parent Company of Bg&E ML20206C7521999-04-29029 April 1999 Provides Rept of Number of Tubes Plugged in Calvert Cliffs Unit 2 SGs During Recently Completed Isi,As Required by Calvert Cliffs Unit 1,TS 5.6.9.a ML20212G9891999-04-28028 April 1999 Forwards Current Draft Response to Ci 3.3.2.2-1 to Be Used as Example for OI Vs License Condition Vs Commitment Situation ML20206C7271999-04-28028 April 1999 Forwards Occupational Radiation Exposure Repts for 1998, as Required by Units 1 & 2 Tech Specs 5.6.1 & 6.1 of Isfsi. Repts Contain Tabulation of Number of Station,Util & Other Personnel Receiving Exposures Greater than 100 Mrem ML20206C7211999-04-27027 April 1999 Forwards Addl Info Which Is Being Made Available in Encl Licensed Operators Fitness for Duty Questionnaire.Encl Specifics of Personal Info Are Withheld,Per 10CFR2.790 ML20212G9851999-04-26026 April 1999 Provides Proposed Response to OI 4.1.3-1 for B Elliott to Consider ML20206U6691999-04-26026 April 1999 Advises That Documents Re Operation of Calvert Cliffs Nuclear Power Plant Should Be Addressed to Listed Natl Marine Fisheries Svc Office ML20205F8851999-04-0202 April 1999 Provides First Annual Amend to Bg&E License Renewal Application for Ccnpp,Units 1 & 2,as Required by 10CFR54 ML20205J0691999-04-0202 April 1999 Forwards Response to NRC 990129 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20205G2971999-04-0101 April 1999 Requests That NRC Complete Review of Rev 0 to CENPD-396-P, Common Qualified Platform TR & Rev 0 to CE-CES-195-P, Software Program Manual for 'Common Q' Sys, by 990930 ML20205D7471999-03-30030 March 1999 Forwards Biennial Rept on Status of Decommissioning Funding, IAW 10CFR50.75(f)(1) ML20207G4391999-03-30030 March 1999 Responds to from Cl Miller,Requesting Assistance of FEMA in Addressing Concerns Received by NRC Involving Offsite Emergency Preparedness at Plant NPP ML20205C4091999-03-26026 March 1999 Submits Info Related to Scope,Risk Mgt & Summary of Risk for Performing Preventive Maintenance on P-13000-2 Unit Transformer Re License Amend 205 1999-09-28
[Table view] Category:UTILITY TO NRC
MONTHYEARML20064A7471990-09-18018 September 1990 Discusses Response to Generic Ltr 88-17, Loss of Dhr. Development of Appropriate Tech Spec Changes for Reducing Cooling Flow Rate in Process.Changes Will Provide Increased Margin to Vortexing Conditions ML20059K1951990-09-18018 September 1990 Clarifies Auxiliary Feedwater Sys Commitments Concerning Ability of Sys to Prevent Total Loss of Feedwater Following Various Pipe Breaks & Component Failures ML20059H2811990-09-0707 September 1990 Forwards Rev 4 to Calvert Cliffs Nuclear Power Plant Performance Improvement Plan Implementation Program. Rev Creates Std Format for Action Plans Which States Scope, Deliverables & Overall Objectives of Action Plan ML20059F4761990-09-0707 September 1990 Forwards Rev 5 to Security Training & Qualification Plan.Rev Withheld ML20059H4241990-09-0707 September 1990 Forwards Performance Improvement Plan Implementation Program Schedule Status as of 900905 05000317/LER-1989-023, Advises That Licensee Plans to Complete Detailed Design for Automatic Isolation Sys Upgrade by 910401,per NRC Request for Schedule for Enhancement Implementation as Discussed in LER 89-23 Re Postulated Pipe Rupture1990-08-24024 August 1990 Advises That Licensee Plans to Complete Detailed Design for Automatic Isolation Sys Upgrade by 910401,per NRC Request for Schedule for Enhancement Implementation as Discussed in LER 89-23 Re Postulated Pipe Rupture ML20059B7481990-08-21021 August 1990 Forwards fitness-for-duty Program Performance Data for Jan-June 1990 ML20058Q2211990-08-14014 August 1990 Forwards Performance Improvement Plan Implementation Program Schedule Status as of 900807.Synopsis of Activities Since Last Update & Updated List of Key Action Plan Info Also Encl ML20058L8811990-08-0101 August 1990 Withdraws License Amend Request Changing Tech Spec Pages 3/4 25a & 25b, RCS Pressure-Temp Limitations. Change Would Have Revised Min Reactor Vessel Flange bolt-up Temp from 70 F to 90 F ML20058L7271990-08-0101 August 1990 Forwards Plant Performance Improvement Plan Implementation Program Schedule Status as of 900724 ML20058L2151990-07-27027 July 1990 Responds to NRC Re Unresolved Item Noted in Insp Repts 50-317/90-80 & 50-318/90-80.Corrective Action: Evaluation of Battery Charger Determined That Provisions Adequately Verify Requirements of Tech Spec 4.8.2.3.2 ML20055H9241990-07-26026 July 1990 Forwards Decommissioning Plan for Calvert Cliffs Isfsi ML20055G9981990-07-20020 July 1990 Responds to NRC Re Generic Implications & Resolution of Control Element Assembly Failure at Plant on 900607.New Control Element Assemblies Ordered.Addl Response Will Be Submitted at Least 60 Days Prior to Restart ML20044B0401990-07-13013 July 1990 Forwards Rev 3 to Calvert Cliffs Nuclear Power Plant Performance Improvement Plan Implementation Program. Brief Summary of Changes Listed ML20055E0801990-07-0303 July 1990 Responds to NRC Re Violations Noted in Insp Repts 50-317/90-08 & 50-318/90-08.Corrective Actions:Instruction CCI-309B Re Control of Locked Valve Revised to Clarify Required Documentation and Verification of Locked Valves ML19298E2271990-06-29029 June 1990 Confirms That Work Intended to Resolve Unresolved Items & Incorporate Improvement Suggestions Completed,Per Insp Repts 50-317/90-04 & 50-318/90-04 ML20055D0311990-06-25025 June 1990 Submits Corrections to Commitments Re Hydrogen Analyzer Sys. Under Worst Case Condition,Hydrogen Recombiners Would Be Started Prior to Hydrogen Concentration Inside Containment Reaching 3.0% Hydrogen ML20043G1771990-06-12012 June 1990 Forwards Monthly Operating Repts for May 1990 for Calvert Cliffs Nuclear Power Plant Units 1 & 2 & Revised Operating Rept for Apr 1990 for Calvert Cliffs Unit 1 ML20043G5931990-06-0808 June 1990 Requests one-time Exemption from Requirement of 10CFR50.71(e) to Allow 3-month Extension to Schedule for Submitting 1990 Rev to Updated Fsar,Per NRC 1989 QA Audit & Insp Repts 50-317/89-27 & 50-318/89-28 Noting Weaknesses ML20043F7101990-06-0606 June 1990 Suppls 900330 Response to Station Blackout Rule (10CFR50.63).Two Addl Class 1E Diesel Generators Added to Reduce Required Coping Duration.Required Coping Duration Is 4 H for One Unit ML20043D7281990-06-0404 June 1990 Responds to NRC 900404 Ltr Re Weaknessess Noted in Maint Team Insp Repts 50-317/90-80 & 50-318/90-80.Efforts to Clean,Insulate & Paint Plant Areas to Improve Cleanliness Being Undertaken ML20043C9051990-05-31031 May 1990 Notifies of Relocation of Ofcs,Effective 900604.New Addresses & Telephone Numbers Listed ML20043C5971990-05-29029 May 1990 Forwards Startup Review Board Self-Assessment Rept:Apr 1990 Unit 1 Startup. Based on Assessment,Mgt Efforts Taken Through Performance Improvement Plan Appears Substantially on Track ML20043B9341990-05-25025 May 1990 Advises of Licensee Progress to Date Re Unresolved Item Noted in Inps Repts 50-317/90-04 & 50-318/90-04 & Identify Slippage Past 900601 Target Date.Completion Date Extended to 900701 ML20043B4691990-05-21021 May 1990 Reaffirms Licensee Intention to Submit Rept Re Deletion of Tech Spec 3/4.6.1.8, Containment Sys - Containment Vent Sys, Upon Receiving Notification That Vent Valves 1(2)-MOV-6900 & 1(2)-MOV-6901 Established ML20043A3381990-05-15015 May 1990 Responds to NRC 900409 Ltr Re Violations Noted in Insp Repts 50-317/90-01 & 50-318/90-01.Corrective Actions:Detailed & Specific Directions for Radiography Will Be Incorporated in Radiography Procedures within NDE Program ML20043A3321990-05-14014 May 1990 Responds to SALP Rept Dtd 900404 Covering Util Performance During 1989.Feedback Mechanisms Established to Improve Training & 10CFR50.59 Screening Procedure & Training Revised ML20042G3751990-05-10010 May 1990 Forwards Changes 1-3 to Rev 0 to Program Plan for Second Insp Interval for Calvert Cliffs Nuclear Plant,Units 1 & 2. Plan Revised to Include Volumetric & Surface Exams of Class 2 Piping Welds in Containment Spray & Shutdown Cooling Sys ML20042G6141990-05-0505 May 1990 Requests Regional Temporary Waiver of Compliance to Provide Relief from Provision of Limiting Condition for Operation of Tech Spec 3.4.10.1, Structural Integrity of ASME Code Class 1,2 & 3 Sys. ML20042G4581990-05-0404 May 1990 Responds to Request for Addl Info Concerning Tech Spec Amend Re Emergency Diesel Generators.Preventive Maint Procedures Prepared on 900411 & Final Approval Will Be Completed After Issuance of Amend ML20042F5771990-05-0404 May 1990 Responds to NRC 900404 Ltr Re Violations Noted in Insp Repts 50-317/90-80 & 50-318/90-80.Corrective Actions:Surveillance Test Procedure M-538-1 Revised to Include Verification of Alarm Function & Alarm Testing Reviewed ML20042F0101990-04-30030 April 1990 Forwards Update of Tables 1C,2A,2B,3A & Page 7 of Semiannual Effluent Release Rept for Second Half of 1989 & Table 3A for Second Half of 1988 & First Half of 1989.Update Includes Strontium Results for Fourth Quarter for Gaseous Releases ML20042E8271990-04-30030 April 1990 Forwards Rev 2 to Calvert Cliffs Performance Improvement Plan Implementation Program. Accountability Improvements, Engineering Planning & Sys Circles Action Plans Completed. New Sections to Rev Listed ML20042F0391990-04-19019 April 1990 Submits Initial Response to SALP Rept Dtd 900404.Licensee Devoted Substantial Senior Mgt Attention & Resources to Improving Facility Performance & Committed to Continue Efforts to Attain High Stds of Safety & Quality ML20012F5511990-04-0606 April 1990 Responds to NRC 900306 Ltr Re Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000.Corrective Actions:Operating Procedures Changed to Prohibit Testing of ECCS When in Solid Water Condition ML20012F2991990-04-0404 April 1990 Revises Scheduled Completion Date for Implementation of Computerized Trending of Surveillance Test Data,In Response to Special Team Insp Repts 50-317/89-200 & 50-318/89-200 from 900601 to 901228 ML20042D8101990-03-30030 March 1990 Forwards Supplemental Info,Clarifying Util 890414 Response to Station Blackout Rule Noting That Util Followed NUMAR-87-00 Methodology ML20012F0211990-03-29029 March 1990 Responds to NRC 900227 Ltr Re Violations Noted in Insp Rept 50-317/89-25.Corrective Actions:Plugging Error Identified & Correct Tube Plugged & Corrective Action Procedures Revised ML20012D3111990-03-19019 March 1990 Provides Followup Response to Violation Noted in Insp Repts 50-317/89-24 & 50-318/89-24.Corrective Actions:Radiation Safety Technicians Responsible for Safety Procedures Trained in Jan 1990 & Radwaste Scaling Factors Approved on 900201 ML20012D1871990-03-16016 March 1990 Discusses Readiness for Restart of Facility ML20012B9121990-03-0909 March 1990 Withdraws 891113 Request for Relief from ASME Code Section XI Requirements ML20012B9221990-03-0909 March 1990 Responds to NRC 900207 Ltr Re Violations Noted in Insp Repts 50-317/89-27 & 50-318/89-28.Corrective Actions:Demineralized Water & Chemicals Added to Steam Generators to Restore Chemical Concentrations to Required Specs ML20012B6111990-03-0707 March 1990 Responds to NRC 900229 Ltr Re Violations Noted in Readiness Assessment Team Insp Rept 50-317/89-81.Corrective Actions: Memo Issued re-emphasizing Importance of Mgt Controls & General Supervisor Counselled ML20012D7271990-03-0505 March 1990 Responds to Violations Noted in Insp Repts 50-317/90-03 & 50-318/90-03 on 900108-12.Corrective Actions:Medical Svcs Tested All Members of Nuclear Security Force for Glaucoma & field-of-vision Requirements ML20011F4251990-03-0101 March 1990 Forwards Page 4-9 of Rev 25 to Security Plan,Originally Submitted on 900228.Encl Withheld (Ref 10CFR73.21) ML20011F4491990-02-28028 February 1990 Forwards 1989 Steam Generator Insp Results Rept.Rept Includes Number & Extent of Tubes Examined,Imperfections Noted & Identity of Tubes Plugged.No Steam Generator Tube Exams Conducted on Unit 1 During 1989 ML20012A1481990-02-28028 February 1990 Forwards Rev 25 to Security Plan & Details of Changes Made by Rev.Encls Withheld (Ref 10CFR73.21) ML20012A1531990-02-28028 February 1990 Forwards Rev 11 to Safeguards Contingency Plan & Details of Changes Made by Rev.Encls Withheld (Ref 10CFR73.21) ML20011F4141990-02-27027 February 1990 Forwards Rev 2 to, Evacuation Time Estimates within Plume Exposure Pathway EPZ for Calvert Cliffs Nuclear Power Plant. Evacuation Time Estimates Updated to Reflect Population & Road Network Changes Since 1981 ML20012A2331990-02-26026 February 1990 Advises That Erosion/Corrosion Program Controlling Implementing Procedure 5.05, Secondary Sys Piping Erosion/ Corrosion Insp Program, Fully Implemented on 891229 1990-09-07
[Table view] |
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t t t B ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE. MARYLAND 21203 JostpH A.flERNAN vie Pntsiotut NUCt tA8r Entmov
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October 18, 1988 U. S. Nucl ear Regulatory Commission Washington, DC 20555 A'ITENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 AShiE Section XI Pumo and Valve Inservice Test (IST) Program
REFERENCE:
(a) Letter from Mr. S. A. hicNeil (NRC) to Mr. J. A. Tiernan (BG&E),
dated August 9, 1988, Request for Additional Information (TACS 64976 and 64977)
Gentlemen:
This letter constitutes our reply to Reference (a). As requested, a complete, revised IST program plan is enclosed. Our response to the Request for Additional Information (RAI) is discussed below.
Enclosure (1) provides a detai'ed discussion in response to Valve Program item N;. I and Pump Program item No.1. We are not including the emergency diesel generator air start and fuel oil transfer Systems in our IST Program for the reasons provided therein. We do not believe that the testing of these systems in accordance with ASME Section XI is required or of any benefit.
Valve Program item 2 identified txo relief requests that were both numbered A-3. In the revised IST program plan (Enclosure 2), Relief Request A-3 is that request identified as such in the March 30, 1988 submittal. Relief Request A-4 in Enclosure (2) is the previous A-3 in the July 5,1988 submittal.
We have re-evaluated the relief request numbered AF-1 in the March 30, 1988 submittal, and decided to ivithdraw that request. We have included those ialves on the cold shutdown list in our revised program plan.
In response to Valve Program item 4, additional technica! Justification is provided in the revised program plan for relief requests SI-6 and 51-7. We also have defined the abbreviation 'ITP."
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PDR ADOCK0500g7 g P ,
Doct ment Control Desk -
Octolwr 18,' 1988 Pa58 2 t
i As _ requested in Velve Program item 2, the basis and alternative testing of Relief Riquest No. 7 was clarified to require that all data would normally be' taken on a quarterly frequency.
Should you have any further questions regarding this matter, we will be pleased to -
discuss them with you.
Very truly yours, b '
i JAT/SRC/BSM/dlm Enclosures cc: D. A. Brune. Esquire J. d. Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC D. C. Trimble/V. L. Pritchett, NRC T. Magette, DNR I
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ENCLbSURE (1)
RESPONSE TO NRC VALVFJOGRA M ITEM (1) AND PUMP PROGRAM ITEM (1) ON TIIE PROPOSED SECOND TEN-YEAR INTERVAL OF TIIE CALVERT CLIFFS ASME SECTION XI PUMP AND VALVE INSERVIGE IIST (ITT) PROGRAM INTRODUCTION AND OVERVl3 The NRC staff has requested thit the scope of the IST program be expanded during the next !0-year interval to include the valves and pumps in the emergency diesel generator (EDG) air start and fuel oil transfer "ystems. In response to this request, We have reviewed the requirements for establishing the scope of the IST program as set forth in 10 CFR 50.55h, NRC Regulatory Guide 1.26 and the Calvert Cliffs Operating License. As a result of this review, we have reaffirmed that testind of these components under our IST program is neither required nor necessary. The following summanizes our findings:
Finding No. I: The EDG Air Start and Fuel Oil Transfer Systems Are Not Reauired to be Tested Under the Calvert Cliffs IST Program.
Those systems and components that are regulfed to be included within the IST program are identified by 10 CFR 50.55a as those which are chssified as ASME Code Class 1, 2 or 3. The IST program scope (along with requirements relative to plant design features), is further defined in paragraph 50.55a(gX3)(iv), which states:
"Pumps and valves which are classified as ASME Class 2 and Class 3 shall be designed and provided with access to enable the performance of inservice testing . . ." (emphasis added).
Regulatory Guide 1.26 provides a method acceptable to the NRC for identifying the quality standard and ASME code classification applicable to components containing water, steam or radioactive waste. In addition, Regulatory Guide 1.26 states clearly that:
"Other systems not covered by this guide, such as instrument end tervice air, diesel engine and its eenerators and autiliarv suncrt systems, diesel
[ud, emergency and normal ventilation, fuel handling, and radioactive waste management systems, should be designed, fabiicated, erected, and tested to quality standards commensurate with the safety function to be perfortned." (emphasis added)
i
, ,o ENCLOSURE (t)
In accordance with the above regulations and regulatory guidance all Code Class 1, 2, and 3 components werc identified during the plant design phase prior to the issuance of the plant operating license. This component classification formed the basis for 'he list of components included in the initial IST Program, as approved by the NRC on February 8, 1982. Since these systems are not classified as either Code Class 1, 2, or 3 testing under the IST Program is not required.
Finding No. 2: The EDG Air Start and Fuel Oil Transfer Systems are Already Subiected to Testina Commensurate with the Safety Function Thev Pfrform.
Both the air start and fuel oil transfer systems are subjected to testing which regularly verifies their operational readiness. This testing is conducted in accordance with the Calvert Cliffs Technical Specifications under the surveillance test program. Eight different Surveillance Test Procedures (STPs) exist in this program which require rasting of the diesel generators and their auxiliary systems in various combinations on a monthly, semiannual and refueling-outage basis. Testing under this program requires a sum total of at least 36 tests per diesel generator per year, each of which confirms the operational readiness of the diesel generator and its support systems. Furthermore, the STPs require that attention be focused on the performance of the air start and fuel oil transfer systems. This is done during each test by ensuring that air receiver pressure drops by a specified amount ar.d that fuel oil is automatically made up to maintain day tank level.
Finding No. 3: The Valves and Pumos Within the EDG Air Start and Fue; Oil Transfer Systems are liinhly Reliable and are Well-Maintained.
In response to NRC Generic Letter 84-15, a diesel generator reliability program was established following the guidelines of the generic letter and Regulatory Guide 1.108.
The scope of the program encompasses the entire EDG unit, consistent with the Regulatory Guide 1.108 definition; i.e.,
"A ' diesel generator' unit consists of the engine, generator, cor.1bustion air system, cooling water system up to the supply, [gl sucolv system, lub-ricating oil system, Wrtine enerny system, autostart controls, 11anual con-trols, and diesel generator breaker." (emphasis added)
Under this program, failures of the diesel generators have been trended since 1985. To date, no failure of a diesel generator unit has been attributed to the air start or fuel oil transfer systems. A separate review of all maintenance work perf ormed on she EDG air start and fuel oil transfer systems since initial plant operation revealed no component malfunctions or deleterious conditions that would have reduced system operational readiness.
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, FJiCLOSURE (1)
CONCLUSIDH The ASME Calvert CliffsSection XI Inservice Testing Program for pumps and valves, as approved by the NRC in 1982, is in compliance with 10 CFR 50.55a. Expansion of the IST program to include the EDG air start and fuel oil transfer systems is not required and would provide no greater assurance of operational readiness. Therefore, we decline to add these systems to the IST Program.
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