ML15097A009

Response to Request for Additional Information Permanent Extension of Type a and C Leak Rate Test Frequencies License Amendment Request

ML15097A009
Person / Time
Site:	Calvert Cliffs
Issue date:	04/02/2015
From:	George Gellrich Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15097A009 (4)

Text

Adomw AAMMMW George Gellrich Anow-Exelon Generation, Site Vice President Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 410 495 5200 Office 717 497 3463 Mobile www.exeloncorp.com george.gellrich@exeloncorp.com 10 CFR 50.90 April 2, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318

Subject:

Response to Request for Additional Information re: Permanent Extension of Type A and C Leak Rate Test Frequencies License Amendment Request

References:

1. Letter from G. H. Gellrich (Exelon Generation) to Document Control Desk (NRC), dated September 18, 2014, License Amendment Request: Revise Technical Specification Section 5.5.16 for Permanent Extension of Type A and C Leak Rate Test Frequencies

2. Letter from N. S. Morgan (NRR) to G. H. Gellrich (Exelon Generation), dated January 22, 2015, Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 -

Request for Additional Information Regarding Permanent Extension of Type A and C Leak Rate Test Frequencies License Amendment (TAC Nos.

MF4898 and MF4899)

3. Letter from G. H. Gellrich (Exelon Generation) to Document Control Desk (NRC), dated February 17, 2015, Request for Additional Information Regarding Permanent Extension of Type A and C Leak Rate Test Frequencies License Amendment Request In Reference 1, Exelon Generation submitted a license amendment request for the Calvert Cliffs Nuclear Power Plant (Calvert Cliffs) to permanently extend the Type A and C leak rate test frequencies. In Reference 2 the Nuclear Regulatory Commission issued a request for additional information (RAI). Reference 3 contained Calvert Cliffs' response.

On March 26, 2015 a phone call with the Nuclear Regulatory Commission was held to discuss the RAI response to EMCB RAI-1 of Reference 3. Calvert Cliffs indicated we would provide additional clarifying information to our response to this RAI. Attachment (1) contains our revised response to EMCB RAI 1. Attachment (1) supercedes the response originally provided in Reference 3 to this RAI.

Document Control Desk April 2, 2015 Page 2 During the March 26, 2015 phone call two other items were discussed:

• A typo was identified in Reference 1, page 8 of Attachment (1). In the second paragraph under the date 'May 1, 2002' the words '(ILRT was conducted on May 3, 2003 )' should have read '(ILRT was conducted on May 3, 2006)'.

" The two commitments made in Attachment (4) of Reference 1 to complete concrete repairs to areas of the containment structure have been completed. The repairs have addressed all issues previously identified with containment dome weathering and the effects of freeze-thaw cycles. In addition, repairs associated with the concrete delamination around the sloped surface above the equipment hatch have been completed. All corrective actions associated with these issues, including removal of loosened concrete, cleaning of grease leaks, and sealant application, were completed in December 2014.

This additional information does not change the No Significant Hazards Determination provided in Reference 1. No regulatory commitments are contained in this letter.

Should you have questions regarding this matter, please contact Mr. Michael J. Fick at (410) 495-6714.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 2, 2015.

Respectfully, Geor ie HGellrich Site Vice President GHG/KLG/bjm

Attachment:

(1) Revised Request for Additional Information Response cc: NRC Project Manager, Calvert Cliffs NRC Regional Administrator, Region I NRC Resident Inspector, Calvert Cliffs S. Gray, MD-DNR

ATTACHMENT (1)

REVISED REQUEST FOR ADDITIONAL INFORMATION RESPONSE Calvert Cliffs Nuclear Power Plant April 2, 2015

ATTACHMENT (1)

REVISED REQUEST FOR ADDITIONAL INFORMATION RESPONSE The below response revises the previously supplied response to EMCB RAI 1:

Mechanical and Civil Enqgineering (EMCB) RAI 1:

Section 3.8 of the LAR states that, (1) "at Calvert Cliffs, a test pipe was provided for each continuous segment of the bottom liner plate weld chase test channels;" and (2) an analysis of the NRC Information Notice 2014-07, "Degradationof Leak-Chase Channel Systems for Floor Welds of Metal Containment Shell and Concrete Containment Metallic Liner" "is in progress to determine if this issue is applicable to Calvert Cliffs."

Discuss (1) the results of the Calvert Cliffs evaluation relative to the NRC Information Notice 2014-07 and (2) the operating experience, inspection results, and any corrective actions relative to the bottom floor liner plate weld leak chase test channels, including the existing test pipe.

CCNPP Response EMCB RAI 1:

The Calvert Cliffs design configuration is different from the one considered as "typical" in Information Notice 2014-07. At Calvert Cliffs, the pipe protruding from the leak chase channel is either "flush" to the floor or exposed to the surface with no access box and cover plate. This configuration eliminates the chances of moisture accumulation thus avoiding degradation of this area.

The Containment Inservice Inspection Program includes the American Society of Mechanical Engineers (ASME) Code, Section Xl, Subsection IWE inspection requirements for containment liner as mandated by 10 CFR 50.55a, "Codes and Standards." The inspection frequency required by ASME Section Xl Subsection IWE is to perform a general visual inspection of all accessible areas in Containment, including the moisture barrier, each inspection period, which may consist of more than one refueling outage (RFO). At Calvert Cliffs the inspection is performed every RFO, which meets and exceeds the ASME Code inspection frequency requirements in the instances where the period contains more than one RFO. The examination includes the inspection of the leak chase channels caps/plug and exposed portions of pipes during the General Visual inspection of 10' containment liner and 10' moisture barrier.

In addition the Containment Leakage Rate Testing Program requires removal of the leak-chase channel pipe cap/plug for functional testing of containment during the local leak rate test/

integrated leakage rate test (LLRT)/(ILRT) per procedures STP-M-471-1/2 and STP-M-662-1/2, respectively. A satisfactory LLRT/ILRT exam indicates containment leak tightness and leak-chase channel system integrity. The procedures include steps for pipe caps/plugs removal and installation.

At Calvert Cliffs there have been no failed ILRT exams. All ILRT examinations results have been satisfactory which reflects that the structural integrity of the leak chase channel system and components remains intact. In addition, all visual inspections performed on the accessible surfaces of the leak chase channel system have been satisfactory with no degradation identified.

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