ML20070A994
| ML20070A994 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/22/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9406290230 | |
| Download: ML20070A994 (5) | |
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f Romxs E. Duxsmi Italtimore Gas and Electric Compmy Cahnt Osjfs Nuclear l'ou a l'lant Vu e l'rcsident 1650 Calwn GJfs i'arlu ay Nuclear Energy Lusby. Maryland 2o657 410 586-2200 iht. 4155 local l
.sto 260.t.155 Italtimore N
June 22,1994 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk SUllJECT:
Calvert Clifts Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Supplement to License Amendment RcAucst: Emergency Diesci.Ssncrator Testina
REFERENCES:
(a) letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, dated November 2,1993, License Amendment Request; Emergency Diesel l
Generator Testmg i
(b)
Letter from Mr. D. G. Mcdonald, Jr. (NRC) to Mr. R. E. Denton (BGE),
dated February 24,1994, Request for Additional Infonnation Regarding Emergency Diesel Generator Technical Specification Surveillance Testing Requirements - Calvert Cliffs Nuclear Power Plant, Units Nos. I and 2 (TAC Nos. M88168 and M88169)
In Reference (a), the Baltimore Gas and Electric Company requested an Amendment to Operating License Nos. DPR-53 and DPR-69 regarding Emergency Diesel Generator surveillances. In Reference (b), the NRC requested additional infornution to support their review of our request. Attachment (1) contains our response.
This supplemental information does not change the Determination of Significant llazards section of Reference (a), nor our conclusion that the requested change does not represent an undue risk to the health and safety of the public.
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'l 9406290230 940622 1
PDR ADOCK 05000317 I\\
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Document Control Desk June 22,1994 Page 2 l
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
1 Very truly yours, STATE OF MARYLAND
- TO WIT:
COUNTY OF CALVERT I hereby certify that on the c27Al day of d/t,y e _.
,19.91, before me, the subscriber, a Notary Public of the State of Maryland in andlfor l'ilv2u f. /'htyL
, personally appeared Robert E. Denton, being duly sworn, and states that he is Viec President gf the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
WITNESS my lland and Notarial Scal:
l_> < - NA d>/Ir Notary Public
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My Commission Expires:
JAnato /, /998 i
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Ifte' RED /BDM/ dim l
Attachment ec:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC i
P. R. Wilson, NRC R.1. McLean, DNR J. II. Walter, PSC i
ATTACIIMENT (1)
RESPONSE TO TIIE REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST; EMERGENCY DIESEL GENERATOR TESTING Ouestion 1:
You indicate that the Emergency Diesel Generator (EDG) vendor, Fairbanks Morse (FM), was conferred with on extending the surveillance and testing requirementsfrom the current 18-month interval to a 24-month interval and that FM provided recommendations. We request that a summary ofthe FM recommendations be provided.
Response 1:
Baltimore Gas and Electric Company (BGE) requested that Fairbanks Morse evaluate a 24-month maintenance interval. Fairbanks Morse recommended that BGE extend the maintenance interval to 24-months and temporarily collect additional information on the efTect of the extended interval. Fairbanks Morse stated that the following information would be sufficient to detennine the health of the EDO:
A.
Baltimore Gas and Electric Company should submit the following operating data for review: engine parameters, lube oil analysis, corrective maintenance, and preventative maintenance. Fairbanks Morse would review the data and prepare an
" engine health report" indicating any abnormalities which may require special at'.ention.
B.
Baltimore Gas and Electric Company should perform a mid-cycle inspection under the supenision of a Fairbanks Morse technical representative. This inspection should:
1.
check the main and connecting rod bearings; 2.
check the side clearance measurement between the upper connecting rod floating bushing and the piston insert bushing; 3.
visually inspect the camshaft bearings and cams; 4.
check thejacket cooling water for treatment; 5.
check the fuel linkage for freedom of movement and the condition of the governor link and linkage pins; 6.
visually inspect the blower lobes and measure the lobe clearance with feeler gauges; 7.
check the vertical drive coupling and gears and measure the bearing end float; and 8.
operate the engine under the observation of an Fairbanks Morse technical representative and submit the collected data to Fairbanks Morse for review.
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ATTACIIMENT (1)
RESPONSE TO Tile REQUEST FOR ADDITIONAL INFORMATION j
LICENSE AMENDMENT REQUEST; EMERGENCY DIESEL GENERATOR TESTING J
Ouestion 2-Based on the FM recommendations, you have decided to temporarily implement a mid-cycle EDG maintenance inspection. Provide the basisforyour decision and the extent thatyour maintenance inspection is consistent with the FM recommendations.
Response 2:
As described in our L,icense Amendment Request, we have reviewed our EDG inspection and maintenance records and concluded that the EDG maintenance interval can be i
extended from 18 to 24 months without reducing the reliability of the EDG. In other words, we have identified no replacements or adjustments that are required on an 18 month frequency. Therefore, we believe that extension of the EDG maintenance interval from 18 to 24 months is justified without a mid cycle inspection. Ilowever, to give further confidence that operation on a 24-month maintenance interval will not adversely affect j
EDG performance, we have committed to temporarily perform a mid-cycle inspection in i
accordance with the vendor's recommendations.
Baltimore Gas and Electric Company is differing from the vendor's recommendations in two areas. First, BGE is not committing to use Fairbanks Morse for the routine analysis of EDG performance data or for observation of the mid-cycle inspections. Baltimore Gas and Electric Company has considerable experience with the Fairbanks Morse EDGs and has an established program for evaluating engine health. We may consult with Fairbanks Morse concerning specific EDG conditions, but we believe that their presence is not required to successfully perform the routine inspections and evaluations.
Secondly, during the mid-cycle inspection, BGE will perform all of the inspections recommended by Fairbanks Morse. Ilowever, the side clearance measurement between the upper connecting rod floating bushing and piston insert bushing will not be perfonned immediately. This inspection is not currently included in the recommended inspections for EDGs at nuclear power plants. As such, BGE has not performed this inspection in the past and does not have a baseline for future inspections. Baltimore Gas and Electric Company is currently upgrading the electrical capacity of each of the EDGs and we will perform a baseline measurement during this upgrade and perform follow-on inspections uf this parameter in future mid-cycle inspections as special tools and inspection techniques are developed.
Ouestion 3:
You indicate that the mid-cycle maintenance inspections may be discontinued in the future dependmg on the inspection results. Provide the criteria that will be used to analyze the inspection resuhs and make a determination that the mid-cycle inspection are no longer necessary. Further, indicate the expected number ofmid-cycle inspections necessary to determine they are no longer necessary.
Response 3:
Inspections which measure objective values (i.e., clearances, water chemistry) will be compared to recommendations in the vendor technical manuals or values obtained from the vendor. He subjective inspections (e g., visual inspection) are performed by engineers and 2
ATTACilMENT 0)
RESPONSE TO TIIE REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST; EMERGENCY DIESEL GENERATOR TESTING mechanics with extensive experience with the EDGs. All of BGE's EDG-qualified mechanics have attended training given by Fairbanks Morse. If questions are raised during the inspections, Fairbanks Morse would be contacted for recommendations. In addition to our in-house expertise, BGE has at its disposal EDG consultants and the other members of the Fairbanks Morse owners group. Therefore, BGE would rely on in-house expertise, manufacturer's manuals and recommendations, and on industry experience to evaluate abnonnal inspection results and determine an appropriate course of action.
Baltimore Gas and Electric Company anticipates that six mid-cycle EDG inspections (two per engine) will be sufficient to evaluate the extended maintenance interval. The first report on each engine will allow Fairbanks Morse to evaluate the condition of the engine and recommend any additional inspections. The second inspection will confirm the results of the first inspection and provide the results of any additional inspections warranted by the first inspection. If additional inspections are necessary to assure the 24-month maintenance interval is appropriate, BGE will continue the inspections. However, at this time, we do not anticipate that a third inspection will be necessary.
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