ML20095G747
| ML20095G747 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/15/1995 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20095G750 | List: |
| References | |
| TAC-M93326, TAC-M93327, NUDOCS 9512210261 | |
| Download: ML20095G747 (38) | |
Text
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Ro:ERT E. DENTON Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 586-2200 Ext.4455 Local 410 260-4455 Baltimore December 15,1995 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information (RAI) Concerning the Baltimore Gas and Electric Company Report Entitled, " Integrated Plant Assessment Methodoloav." dated.6ueust 18.1995. (TAC Nos. M93326 & M93327)
REFERENCE:
(a)
Letter from Mr. J. P. Moulton (NRC) to Mr. R. E. Denton (BGE), dated November 16, 1995, " Request for Additional Information (RAI)
Concerning the Baltimore Gas & Electric Company Report Entitled
' Integrated Plant Assessment Methodology,' dated August 18,1995" (b)
Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, dated August 18,1995," Integrated Plant Assessment Methodology" (c)
Public Meeting between NRC and BGE License Renewal Staffs, dated December 6,1995, Discussions on Responses to a Request for Additional Information (RAI) Concerning the Baltimore Gas and Electric Company Report Entitled, " Integrated Plant Assessment Methodology" (d)
Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, dated November 8,1995, " Schedule for Submitting License Renewal Documentation" By letter dated November 16,1995 (Reference a), the Nuclear Regulatory Commission (NRC) requested additional information on the Bairimore Gas and Electric Company (BGE) " Integrated Plant Assessment (IPA) Methodology" (Reference b). De IPA Methodology describes the specific method used by BGE to comply with 10 CFR Part 54.
Our response to questions on the methodology is contained in Attachment (1). It only addresses the 40 questions on the issues resulting from the NRC review of the IPA Methodology. Included in Attachment (1) are six administrative procedures that support some of the responses. These procedures are provided as examples that describe six of our current programs, and clanfy why we rely on these programs to support specific aspects of aging management. These types of 9 C." i P O 9512210261 951215 A
PDR ADOCK 05000317
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P PDR
Document Control Desk December 15,1995 Page 2 programs are representative of our extensive total program that has been developed to implement and maintain the requirements and commitments of our current licensing basis. We will proside a marked-up revision of the IPA methodology that incorporates the responses described m Attachment (1) by December 22,1995. We will forward a fmal version of the methodology incorporating these responses by January 12,1996 We appreciate the level of detail and technical comments you had on the "10 CFR Part 54 Sample Results" (Attachment 2 of Reference b) Our response, contained in Attachment (1), does not address any of these comments. We have concluded that responses to your comments on the "10 CFR Part 54 Sample Results" will be evaluated during development of IPA System and Commodity Reports. We anticipate further discussions with the NRC as we evaluate and resolve these comments.
During BGE's review of Reference (a) and development of responses to it, BGE participatid in two telephone conversations and a public meeting (Reference c) to discuss our responses. Thw d :cussions were helpful and resulted in a common understanding of concerns and issues that arose during the NRC review of the IPA Methodology. Contingent on your approval of the methodology in a Safety Evaluation Report by January 1996, the IPA System and Commodity Reports will be submitted for review and approval during 1996, as described in Reference (d).
Should you have further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
]
l Nth
$f4ZW for R. E. Denton
(
Vice President - Nuclear Energy RED /JMO/ dim
Attachment:
(1) BGE Resnonse to NRC Request for Additional Information; Integrated Plant Assessment Methodology Tab I NS-1-300, Revision 0, Industry Operating Experience Information Processing Tab 2 NO-l-106, Revision 2, Functional EvaluatioWOperability Determination Tab 3 QL-2-100, Revision 3, Issue Reporting and Assessment Tab 4 RM-1-103, Revision 0, Commitment Afanagement Tab 5 MN-3-l l1, Revision 0, ErostoWCorrosion Afonitoring ofSecondary Piping i
Tab 6 CP-217, Revision 4, Specification and Surveillance: Secondary Chemistry cc:
(Without Tabbed Documents)
D. A. Brune, Esquire Resident Inspector, NRC J. E. Silberg, Esquire S. A. Reynolds, NRC L. B. Marsh, NRC R. I. McLean, DNR D. G. Mcdonald, Jr., NRC J. H. Walter, PSC S. F. Newberry, NRC T. Tipton, NEI T. T. Martin, NRC
ATTACHMENT m
- BGE ' RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY.
1 i
i Baltimore Gas and Electric Company Docket Nos. 50-317 & 50-318 December 15,1995
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l ATTACHMENT U) j s
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION i
INTEGRATED PLANT ASSESSMENT METHODOLOGY METHODOLOGY
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CHANGE.
iBGE RESPONSE NRC COMMENT 1.
General: CLARIFY WHAT PARTS OF THE PREVIOUS IPA None Table (1) indicates where the resolution is to each of the 1993 SUBMITTAL are relied on in this Integrated Plant Requests for Additional Information (RAIs) in the
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Assessment (IPA) methodology or are the same in this August 1995 version of the methodology, and how the section
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methodology? ALSO, CLARIFY HOW and where in this numbering of the 1993 submittal is related to the sections in I
methodology Baltimore Gas and Electric Company (BGE) the 1995 submittal.
i addresses the open and confirmatory items from the I
previous Draft Safety Evaluation Report ifit is relied on.
2.
General:
Documentation:
The methodology makes Yes The Rule does not require that the results of scoping be f
reference to the need to document the results of the analysis submitted to the NRC. The first submittal product of the IPA or screening steps. However, the degree of documentation is the list of SCs subject to aging management review (AMR) or elements of documentation that will be prepared are not per {54.2!(a)(1). Therefore, BGE does not believe'it is j
discussed in any substantive form. PROVIDE ADDITIONAL appropriate to describe in this methodology the format of the j
DETAIL ON HOW THE RESULTS WILL BE DOCUMENTED.
scoping results. These results will be maintained onsite in an auditable and retnevable format.
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1he documentation of the results of the Pre-Evaluation, j
AMR, and Commodity Evaluation steps are lacateri in Sections 5.5,6.4 and 7.3 respectively. The dommentatian of j
Time-Limited Aging Analysis (TLAA) results are discussed
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in Section 8.4, which is entitled " Summary " "Ihe title of this j
section will be revised to be consistent with the titles to other j
sectens of the methodology which describe dommentatinn i
I 3.
General: Operating Experience / Generic Communication /
None We utilize operating experience throughout the scoping and j
Industry Topical Reports: The methodology mentions the IPA process. The method of using this expenence is a j
importance of operating experience yet it does not reliance on the site process which incorporates operatmg demonstrate how and where consideration of such experience into all aspects of plant documentatian, operating experience is to occur.
Such operating maintenance and operation, currently proceduralized in j
experience may be relevant in the identification of aging NS-1-300 (see Tab 1). No special verification of such effects that should be managed and the identification of experience is needed for scoping or the IPA.
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ATTACHMENT (1) l BCE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION l
INTEGRATED PLANT ASSESSMENT METHODOLOGY i
i 6
METHODOLOGY
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- NRC COMMENT iCHANGE -
' BGE. RESPONSE l
non-safety systems that can impact a safety system.
PROVIDE ADDITIONAL INFORMATION as to when and
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how operating experience is considered in the IPA.
i Further, EXPLAIN HOW EXISTING PROGRAMS resulting i
from responses to NRC generic commumcatens would be j
factored into the IPA.
l Additionally, the report indicates that industry documents In the actual LRA submittals, more effort will be taken to l
are reviewed for potential age-related degradation ensure consistent use ofidwmces from section to sectiott mechanisms (ARDMs).
Sampling information in Appendix A found that BGE has referenced the Nuclear Management and Resources Council (NUMARC) industry report on the pressurized water reactor vessel internals for renewal in the second example, " Reactor Coolant System."
i However, BGE did not reference the NUMARC industry l
report on the pressurized water reactor containment in the
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first example, " Containment."
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'Ihe information on page 4-2 (Section 4.3 of Appendix A)
We use the industry reports as a source ofinformation much is referenad from the NUMARC industry report on the the same as Electne Power Research Institute reports and internals.
However, sampling the potential ARDMs Nuclear Plant Aging Research reports In some cure. one or j
discussed, the staff found several unresolved items from the more of the generic conclusions of ebse reports do not apply staff review of the subject industry report that are identified to specific Calvert Cliffs SCs. In these cases, the non-
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as not significant in the BGE cxample, such as stress applicable report would rug be referenced for ' the j
corrosion cracking and creep (core shroud assembly).
corresponding conclusion in the detailed AMR Report and other more pertinent information sources would be used to L
The information on page 3-1 through 3-5 (Section 3.1 of make the required demnaceration. Because of this, BGE does Appendix A) is not referenced from the NUMARC not believe that it is appropriate to describe how industry industry report on the containment. However, sampling the reports will be used in the methodology. It is not necessary to potential ARDMs discussed, the staff found differences in describe in the methodology, the aging manamnent reports or information between the BGE report and the NUMARC the license renewal application (LRA) each instance where a 2
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ATTACIIMENT 0)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY i
METHODOLOGY I
NRC COMMENT b.
CHANGE report, such as aggressive chemical attack on concrete and conclusion in an industry reference, such as an industry inaccessible areas. These differences should be discussed.
report, does not apply to Cahert Cliffs equipment.
DISCUSS THE USE OF INDUSTRY DOCUMENTS such as the NUMARC industry reports for renewal. Also, discuss how BGE assesses whether it is within the bounds of these reports.
4.
General: The phrase " maintain the pressure boundary" is None Criteria for maintaining a system pressure boundary vary l
used repeatedly. WHAT IS THE CRITERIA USED TO from system to system and will be presented and documented DETERMINE when the pressure boundary is not on a system-by-system basis. We intended no difference maintained. Is there a difference between maintaining between the term " pressure boundary" and " pressure
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pressure boundary integrity and maintaining pressure boundary integrity"in this metivvialogy. The terms are used boundary?
interchangeably.
5.
Page 7. For the definition of" passive" REPLACE "does not Yes Baltimore Gas and Electric Company will make the requested require motion" with "is performed without moving parts."
change to the methodology.
6.
Page 12. Section 2.3.4 states that, " techniques provide an Yes All techniques presented in the metivvialogy provide the equivalent level of assurance." WHAT IS THE PURPOSE demonstration necessary to support the fmdmg of {54.29.
IN ASSURING THAT ALL TECHNIQUES PROVIDE
'Be wording in Section 2.3.4 and in Section 7 will be revised EQUIVALENT ASSURANCE. HOW DOES THIS ASSURE accordingly.
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THAT THE EVALUATION TECHNIQUES ARE TO PROVIDE the necessary evidence that the fmdings of {54.29 can be supported?
7.
Page 19, Section 3.3.1.1 states, "By relying on the Q-List None As stated in the merivvialogy, the BGE Q-List controls all Accident Shutdown Flow Sheets and Vital Auxiliaries SSCs which meet (54.4(a)(1) and (2) as " safety-related" at Flow Sheets, SR SSs are identified, as well as all SSs that Calvert Cliffs. It makes no distmetion between the SSC f
could fail and prevent the functioning of SR structures and which satisfy criterion {54.4(a)(1) versus (2). Therefore, any
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components (SCs). This identification is not limited to first example prosided is controlled as SR at Cahert Cliffs.
level, second level or any specific level of support We do not beliese that including an example in the I
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l ATTACHMENT (1)
BGE RESPONSE TO I
NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOthGY f
4 METHODOLOGY NRC COMMENT BCE RESPONSE j
CHANGE:
equipment. Rather, the scoping is performed consistent methodology that fits the situatum described in this RAI with the Calvert Cliffs Nuclear Power Plant (CCNPP) would provxie any additional clarificatum of how the scopmg Q-List Design Standard which was developed with the is enaAced.
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intent of identifying and controlling a similar scope of Th f Ilowm8 example is provided for your informatum.
systems, SSCs to that defined by the first two criteria of Note that all four levels of cascadmg are controlled as SR at 54.4." This statement indicates that the Vital Auxih. anes Calvert Cliffs' t
i Flow Sheets in the Q-List have identified all non-safety-related (NSR) systems, structures and components (SSCs)
A certain heatmg, ventilatum and air conditiomng i
whose failure could prevent satisfactory accomplishment of (HVAC) unit is a SR vital auxiliary because it i
any of the functions identified in {54.4(a)(1).
maintams the environment in the mntrol room and
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cable spreadmg room so that the Reactor Protective The Open Item in the Draft Safety Evaluation Report System and R6=ed Safety Features Aetian i
questioned how the previous metWalagy would identify a Signal System can perform their required safety NSR SSC that provides supportmg functions to another functions lhe electrical cables and panels which l
NSR SSC that is required for a SR SSC to perform its supply power to these units are also included in the t
function. PROVIDE A DISCUSSION OR AN EXAMPLE scope of LR because their failure would prevent the FROM THE VITAL AUXILIARIES FLOW SHEETS IN ' lite operation of the HVAC units which in tum could j
Q-LIST to show that a NSR SSC that provides supportmg Prevent the operatum of the Reactor Protective System i
functions to another NSR SSC that is required for a SR and Ep=.M Safety Features Actuation Signal
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SSC to perform its function would be identified as within System.
the scope of LR.
i 8.
Page 20, Section 3.3.2 states, "These evaluatums are None We do not believe that inel= ling an example in the
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reviewed to identify SSs that are relied on to mitigate the methodology that fits the situatum described in this RAI f
subject plant ennt as well as any systems or structures would provide any additional clarifie=tian of how the scoping whose failure would result in failure of other equipment to is enaAwred i
mitigate the particular event." PROVIDE A DISCUSSION OR AN EXAMPLE to show that a NSR system or structure The following example is provided for your information.
(SS) that provides supportmg functions to another NSR SS Note that both lewis of cascading are NSR.
that is relied on to meet the regulated events in {54.4(a)(3) would be identified as within the scope of LR.
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1 ATTACHMENT U)
BCE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLDGY
., ~ _.
METHODOLOGY NRC COMMar CHANGE
- BGE. RESPONSE.
The diesel-driven fire pump is required under 10 CFR 50.48. The description of how this pump must function to comply with this regulation includes the requirement to provide diesel fuel for the pump.
Tlerefore, the diesel fuel oil system piping which provides the fuel oil to this pump is included within the scope of LR.
9.
Page 31, Section 4.1.1 discusses system intended functions.
None The definition of intended function in f54.4(b) does not However, it does not contain details of the current licensing include any reference to design conditions under which a basis (CLB) design loading conditions under which the system must perform its intended function. Herefore, BGE system is required to function. A system may be required believes that this RAI requests information not identified to have structural integrity under normal, upset, during the scoping step. As discussed further in subsequent emergency, and faulted conditions in accordance with the RAI responses, we beliew that the appropriate place to factor CLB. For example, a system may be required to withstand in the design conditions is during the assessment / analysis a seismic event while another system, such as the fire phase of the aging management strategy. During this phase, i
protection shutdown system installed to ensure post-fire the effects of aging are assessed to deternune whether they shutdown capability (Paragraph II.L.6 of Appendix R),
impact the ability of the structure or component to fulfill its may not be required to withstand a seismic event. The intaxled function during all of the required conditions.
7 difference in the intended function based on the design conditions between these two systems could affect the aging management program for renewal. Hus, Tile CLB DESIGN LOADtNG CONDITIONS SHOULD BE IDENTIFIED AND SUBSEQUENTLY TRANSFERRED TO THE SC INTENDED FUNCTIONS FOR CONSIDERATION in developing aging management programs. as appropriate.
r
- 10. Page 31, Section 4.1.1 discusses system intended functions.
Nonc ne BGE methodology for scoping SSs does not recogmze IT SHOULD INCLUDE A DISCUSSION RELATING TO redundancy, diversity or defense in depth as functions. In REDUNDANCY, DIVERSITY, AND DEFENSE-IN-DEPTH.
addition, the BGE process does not allow exclusion of any i
Where the plant's licensing basis includes requirements for SSCs based on redundancy, diversity or defense in depth i
5 ATTACilMENT (I)
BGE RESPONSE TO NRC !!EQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METIIODOLOGY METIIODOLOGY NRC COMMENT CHANGE SE redundancy, diversity, and defense-in-depth, the system arguments. Herefore, the suggested discussion is not needed intended functions include providing for the same in the methodology.
redundancy, diversity, and defense-in-depth during the period of extended operation. For example, a system with two independent trains, according to the plant's CLB, has to perform the intended functions by each independent train.
I1. Page 31, Section 4.1.1 pressure boundary function Yes The current definition of pressure boundary is quoted directly SIIOULD INCLUDE:
from the Calvert Cliffs Q-List Design Standard and BGE does not see the need to modify this defmition for license (1) Sructural integrity under CLB design loading renewal.
Safety-related equipment must perform their conditions, and intended functions as described in the CL3. A statement to this effect will be added to the first paragraph in (2) General Design Criterion 19, " Control Room," in Section 4.1.1.
addition to Part 100 when discussing adequate radiation protection.
- 12. Page 39, Section 4.3 shows the commodity groups. ARE None Cable trays are in the component supports wumuilty CABLE TRAYS CONSIDERED PART OF A SPECIFIED evaluation.
COMMODITY CROUP?
- 13. Page 42, Sections 5.1.1 and 5.1.2, REPLACE the word Yes We will make the requested change to the methodology.
" motion" with "yving paits"
- 14. Page 43, Section 5.2, Determination of Long-lived:
Yes The replacement on condition steps of Section 5.2 resulted Replacement on performance or condition.
from a BGE misinterpretation of the SOC (60FR22478). We will move the discussion of replacement on condition to a new The rule does not allow SCs to be determined to be short-Section 6.1.4 (including Table 5-1) and charactenze these lived (not long-lived) based on a condition monitoring steps as another approach to performing an AMR without program. He portion of the Statement of Consideration specifically addressing ARDMs.
(SOC) that is referenc4d on page 43 is intended to clarify 6
ATTACHMENT (1)
BGE RESPONSE TO l
NRC REQUEST FOR ADDITIONAL INFORMATION I
INTEGRATED PLANT ASSESSMENT METHODOLOGY METHODOLOGY
-NRC COMMENT.-
CHANGE the agency's position that SCs are considered long-lived if they are subject to a condition monitoring program (and not subject to a replacement based on a qualified life or specified time period) and that these SCs are subject to an AMR. Additionally, the SOC indicates that an applicant can use replacement programs based on performance or condition that provides reasonable assurance that the functionality of that SC will be maintained.
THIS SECTION NEEDS TO BE REVISED TO BE IN COMPLIANCE WITH THE RULE OR A DISCUSSION NEEDS TO BE PROVIDED AS TO HOW THIS WOULD SATISFY THE REQUIREMENTS OF THE RULE.
Additionally, it is not clear what site Mmentation will be Based on the above change, the documentation to support this available that justifies that the three criteria of Table 5-1 step will be changed to be consistent with the AMR process are met.
PROVIDE ADDITIONAL INFORMATION documentation.
EXPLAINING THE SITE DOCUMENTATION that will exist for these determmatons and the lew! of detad in this documentation.
- 15. Page 50, Section 6.1.1 indicates that the pressure-retaining Yes The ability of SCs to perform their intended functions under components in the diesel generator supporting equipment all design conditions should be addressed during the would be managed by the diesel generator performance and assessment / analysis phase of the agmg management program condition monitoring program. 'Ihe staff does not believe after the effects of agmg are discovered that the performance and condition monitoring program i
ensures the structural integrity of these pressure-retauung We agree that the discovery techmques avadable through components under CLB design loadmg conditions durmg performance and condition monitormg may require additional the period of extended operation. PROVIDE ADDITIONAL supporting evaluations or inspection to ensure that DISCUSSION TO DEMONSTRATE HOW STRUCTURAL degradation of pressure-retammg components is discowred in INTEGRITY UNDER DESIGN LOADS IS ADDRESSED BY a timely manner such that there is a reasonable assurance that THE PERFORMANCE AND CONDITION MONITORING the CLB is maintained. In the=e cases, BGE would develop a 7
l ATTACHMENT (t)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION 5
INTEGRATED PLANT ASSESSMENT METHODOLOGY METHODOLOGY l
NRC COMMENT BGE RESPONSE l
CHANGE PROGRAM.
sampling inspection of selected pressure-retanung l
components. The inspection would be conducted prior to the period of extended operation to discover agmg effects that might impact the intended functons under design conditions.
The extent of follow-on inspectens and/or other activities will be determined based on the results of the sampling inspections.
Section 6.1.1 will be modified to include this discussion.
Additionally, Section 6.3.3.4 will be expanded to include i
guidelines for establishing sampling inspections for LR consistent with the executive committee discussions on December 7,1995.
- 16. Page 50, Section 6.1.1. In addition to the diesel generator None This process was also applied to the refrigerant loops of the supporting equipment, WHAT OTHER COMPLEX Control Room IWAC System and the Auxiliary Buildir g and ASSEMBLIES whose only passive function is closely linked Radiation Waste HVAC System.
to active performance have been identified?
- 17. Page 51, Section 6.1.1, Criteria for use of performance and Yes The BGE methodology does not rely on the Mamtenance Rule condition monitoring of complex assemblies as adequate alone to manage the effects of aging. The methodology aging management for passive function.
includes the Maintenance Rule as one factor among many in providing the requir xi demonstration. The contribution of the One of the criteria is that the " complex assembly" be Maintenance Rule to the IPA demaneration is primarily that covered by the Maintenance Rule. PROVIDE SPECIFIC the existing performance and condition monitormg programs EXAMPLES THAT DEMONSTRATE THE USE OF THIS would have a process which would require periodic CRITERION. INCLUDE THE TECHNICAL BASIS for how assessment of their effectiveness and would lead to the passive functions of that " complex assembly" would be improvements in the programs, if needed The methodology preserved by existing Maintenance Rule programs.
will be changed to clarify that the bullets on page 51 describe the circumoance= when this approach should be applied, not the steps of the apprnach itself.
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ATTACHMENT 0)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY t
METHODOLOGY
- BGE.. RESPONSE.
NRC COMMENT..
CHANGE.
18.1 age 51, Section 6.1.2 discusses component assemblics Yes We will add " including pressure boundary" as re =e-M to subject to refurbislunent. It is not clear how the proposed the cited section of the methodology approach addresses the pressure boundary functon For t
example, page 52 states, "The assembly components and The refurbishment activity specifically includes a direct i
subcomponents are inspected for signs of aging and other visual observation of the effects of aging and includes a post-degraded conditions." WORDS LIKE " INCLUDING THE refurbishment test consistent with current industry practices I
PRESSURE-RETAINING BOUNDARY" SHOULD BE and the CLB. The last bullet in Section 6.1.2 will be l
INSERTED AITER THE WORD "SUBCOMPONENTS" in this modified to reflect the above wordmg in place of"w..g.a.:
l statement to indicate that the inspection includes looking assembly's intended functions are tested..."
i for degradation in the pressure-retammg boundary In addition, page 52 states, "The component assembly's intended functions are tested after the refurbishment."
CLARIFY THIS STATEMENT because the intended h
functions are to be performed under CLB design loadmg conditions which may be difficult to simulate in a test.
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- 19. Page 52, Section 6.1.3, Long-Lived Environmental Yes
'Ihe portions of the long-lived EQ components svhich are f
Qualification (EQ) components covered by the EQ program (organic materials) will be identified as a TLAA and evaluated as a TLAA. (See This section states that components having an EQ life of response to RAI 36.) The opuans for addressing this TLAA greater than 40 years are adequately managed by the EQ are discussed further in the BGE response to RAI 40.
program This is not an acceptable argument. PROVIDE l
THE RATIONALE TO BE USED TO DEMONSTRATE
'Ihe portions of the long-lived EQ program which are not l
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FURTHER QUALIFICATION OF THESE COMPONENTS for covered by the EQ program (e.g., valve bodies of solenoid the extended period of operation. For example, how will valves) will be a&LM in a separate IPA report which
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the qualification of cables for the additional peryxl of addresses the effects of aging using the process described m j
senice life be demonstrated?
Section 6.2 of the methodology.
j Additionally, this section states that the EQ program Secten 6.1.3 will be changed consistent with the above requires that the component be reanalyzed to extend the discussion.
j qualified life. THE NRC WILL GENERALLY NOT ACCEPT 9
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ATTACIIMENT (1)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION L
INTEGRATED PLANT ASSESSMENT METHODOLOGY METHODOLOGY L
NRC COMENT' BGE RESPONSE CHANGE ANALYSIS IN LIEU OF TESTING to determine the qualified life of components. Any one of the four methods in
{50.49(f) is acceptable to extend the qualified life of a component.
- 20. Page 55, Sedion 6.23 indicates that the rationale for Yes Baltimore Gas and Electric Company believes that the level designating whether each ARDM is applicable or not is of detail requested in this RAI is not required to be inci uted t
maintained onsite. This assessment is part of the aging in the LRA by the Rule and accompanying SOC. The SOC review and SHOULD BE DISCUSSED AS PART OF THE (60FR22479) states only that, "the demanetration must RENEWAL APPLICATION to demonstrate how the include a description of activities, as well as any changes to requirements of {54.21(1)(3) are being met.
the CLB and plant modifications that are relied on to demonstrate that the intended functions will be adequately maintained despite the effects of agmg in the period of extended operations."
The requested rationale will be i
available onsite for detailed review by NRC Staff and for the use of plant personnel.
However, we will modify Section 6.23 to state that a listing of all potential ARDMs evaluated during the AMR will be included in the LRA section for each system, structure or t
commodity group.
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- 21. Page 55, Section 63.1 states, "The first phase of a Yes We believe that the ability of SCs to perform their intended maintenance strategy is identification that detrunental functions under all design conditions should be addressed effects of aging are or could be occurring." TIE THE during the assessment / analysis phase of the agmg DISCUSSION ON " DISCOVERY" TO THE SC INTENDED management program after the effects of aging are FUNCTIONS UNDER CLB DESIGN LOADING discovered. This approach is consistent with the current CONTsITIONS. For example, a phrase like "affecting the functional evaluation and operability determmation structure and component intended functions under CLB procedures (NO-1-106, see Tab 2) used at BGE for design loading conditions" could be inserted after the word maintauung equipment fimetinanlity. Once the effects are t
" aging" in the above statement. The remainder of the text discovered, a determmation will be made of their impact on 10
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ATTACHMENT (1)
BCE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOIAGY I
METHODOLOGY BGE RESPONSE NRC. COMMENT CHANGE" should also be revised acced-gly, such as Sections 6.3.2 the ability of the affected - ---- :- to perform their and 6.3.3. 'Ihis would avoid relying on inspections that intended functions under CLB conditions.
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would not discover aging effects before a loss ofintended function under a CLB design load.
In order to clarify this pomt, we will add a statement to the introduction of Secten 6.3 to state that one of the goals of j
aging management is to manage the effects of aging such that the intended functions are maintained consistent with the CLB. The paragraph will also clarify that each of the four
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phases of the maintenance strategy takes this goal into l
consideration when detemunmg the ada=m of an existmg
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or proposed program or activity. Additionally,6.3.l(1) will l
be modified to state that discovery methods may require l
augmentation for LR to ensure that the effects of agmg are j
discovered in a timely manner such that there is rcaso.wd,le assurance that the CLB will b: mamtamed
- 22. Page 55, Section 6.3.1 discusses " Discovery." DOES THE None The methodology does not require inclusion of this level of METHODOLOGY CALL' FOR THE SPECIFIC FREQUENCY detail in the LRA. Such information is available, where of the associated activities, such as inspections, to be appropriate, in controlled 4x==?< mamtained onsite.
t described in the renewal application?
- 23. Page 55, Section 6.3.1 states, " Monitoring and evaluating Yes As stated in the methodology, this is a techmque used for industry experience also serves as a discovery activity for
" unknown, emerging and hypothetical ARDMs..." It is managing aging since other plants may discover aging not appropriate to take any other actions to manage such effects before CCNPP " Page 60 (Section 6.3.3.5) states, aging mechanisms unless and until the need for other actions i
" Monitoring plant and industry expenence therefore is demonstaated and what actions would be effective are 5
provides reasonable assurance that these ARDMs will be determmed We believe that this technique for managmg such discovered before they severely affect intended functions at aging mechanisms does meet the requirements of the Rule and i
CCNPP."
THIS IS NOT CONSISTENT WITH THE is the only reasonable tehnhr under these circumstances l
REQUIREMENTS OF THE RENEWAL RULE.
We will not clinunate this option from the methodology.
[
f 1I f
1
i ATTACHMENT (1) j BCE RESPONSE TO i
NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOIACY METHODOLOGY
{
NRC COMMENT '
CHANGE BGE. RESPONSE l
t
'Ihe SOCs accompanying the renewal rule explicitly However, to clarify the use of this forward-looking and i
addresses how aging-related Generic Safety Issues (GSis) proactive practice, we will modify Sectum 6.3.l(1) to state f
and Unresolved Safety Issues (USIs), that is, those being that this form of aging s.esee.sa is used as the sole means L
tracked in NUREG-0933, will be treatal in renewal for unknown and theonzed aging = d==. ;.
The f
(60FR22484). However, for other applicable aging effects, discussion in Section 6.3.3.5 will be amplified to describe the the applicant is expected to provide a inwonation that manner in which monitonng industry expenence contributes the effects of aging will be adequately managed to ensure to a more complex aging. - ---- =e program.
I I
the intended function for renewal. Monitonng industry l
e.xp:rience to manage aging for renewal is similar to l
relying on the regulatory process to manage aging for renewal _ witich was a proposal considered during
(
mie :aking to revise the rule but was not adopted in the L._, rule.
6 Industry operating expenence is important in identifying potential aging effects for evaluation in a renewal application. However, a renewal applicant cannot rely l
solely on monitonng future industry development in lieu of l
i proposing adequate aging manageenent programs in the renewal application. As permitted by the renewal rule, a licensee can modify the aging management programs for I
renewal to take advantage of future industry development l
j following the requirements of {50.59 or {50.92 if the l
program is addressed by a technical specification or license j
condition.
l DELETE THIS OPTION AS AGING MANAGEMENT FROM l
THE METHODOLOGY.
i
- 24. Page 55, Section 6.3.1 discusses " Assessment / Analysis."
Yes During the assessment / analysis phase of the mamtenance j
DISCUSS HOW THE SC INTENDED FUNCTION UNDER strategy, the need for and the nature of required corrective l
12 1
i
I ATTACHMENT 0) t BCE RESPONSE TO l
NRC REQUEST FOR ADDITIONAL INFORMATION f
INTEGRATED PLANT ASSESSMENT METHODOIAGY METHODOLOGY
- NRCl COMMENT CHANGEE CLB DESIGN IAADING CONDITIONS would be factored actions are based on the effects of aging that are />iscre,4 into the assessment / analysis. Also, VERIFY THAT THE and their impact on the ability of the w.-yccs.t to peiform l l
ACCEPTANCE CRITERIA would be included in the renewal its intended function under all design r-lhiaru_
(ThiJ a
{
application currently a requirement of site procedures [NO-1-106, see Tab 2]).
The followmg statement will be added to i
Section 6.3.l(2) "A safety or safety support system shall be capable of perfornung its specified safety function for accident prevention and/or mkig=tian as described in the l
CLB. Likewise, a system providing a function for a regulated
[
event must be capable of performing that function under the t
conditions described in the CLB evaluation of the regulated event.
The assessment / analysis phase irwiporstes such requirements in detuum.I.g the need for and nature of I
corrective actions after abnormal or degraded conditions are discovered. One possible result of such =i---- r/ analysis
(
would be to repeat the discovery phase using an evn=aded j
i sample size or using an =ngn=^=i or improved t~4=ia - for discovermg and quantifying the extent of a particular aging j
effect."
With respect to whether the am cc criteria are included in the LRA, the methodology does not require inclusion of this level of detail in the LRA. Such information is available, l
where appropriate, in controlled h- =- <==: 2 =-i onsite.
- 25. Page 56, Section 6.3.1 discusses " Corrective Action." IT Yes We will revise the n-thadalagy to clarify that such activities l
SHOULD ALSO INCLUDE ROOT CAUSE DETERMINATION are already required, when appropriate, under site procedures AND CORRECTIVE ACTIONS to preclude recurrence.
(QL-2-100, see Tab 3) in accordance with 10 CFR Part 50 Appendix B.
i j
13 i
ATTACHMENT 0)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTECRATED PLANT ASSESSMENT METHODOLOGY a
i METHODOLOGY NRC COMMENT BGE RESPONSE l
CHANGE-
- 26. Page 58, Section 6.3.3.1 discusses plant programs relied on Yes We will revise the methadalagy to require the specific edition i
for renewal. It indicates that the inservice inspection to an industry code to be included in the LRA where the code l
program is one of the programs. Sampling the examples in is credited as part or all of the aging management program Appendix A of the report found that the specific edition of i
the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code Section XI mservice inspection program proposed for renewal is not identified.
Because the ASME Section XI program can vary with code editions, REVISE THE METHODOLOGY TO HAVE SPECIFIC CODE EDITIONS IDENTIFIED FOR RENEWAL PROGRAMS BEING EVALUATED.
Also DISCUSS HOW THE METHODOLOGY WOULD It is not appropriate to address the reliability of any specific ENSURE the reliability of ultrasonic examinations as program in the methodology. As stated in Section 6.4, BGE described in Appendix VIII of the ASME Section XI code.
will demonstrate the adequacy of any credited agmg management program in the specific system, structure or commodity aging management report, not in the methodology.
- 27. Page 58, second paragraph. DEFINE THE CONTENT OF A None We believe the phrase is already well understood in the
" CONDITION MONITORING" PROGRAM as discussed in industry and needs no further def'mition in our methodology.
i i
this paragraph.
Several examples of condition monitoring programs are included in Table 6-1 (e.g., eddy current testmg, vibration monitoring, thermography.
.).
- 28. Page 58, fifth paragraph. The report states that the LRA Yes The methodology will be modified to clarify that justification could include a commitment to implement a program or must be provided for actions which will not be taken until modification at an appropriate future date before or during after the beginnmg of the period of extended operations.
the extended period of operation. THE REPORT SHOULD REFLECT THAT FOR PROGRAMS or modifications delayed With respect to implementation dates of future activities, until sometime during the evtended period of operation and the methodology does not require inclusion of this level after the initial licensed term, a justification must be ofdetailin the LRA. Such information is available, where appropriate, in controlled documents inmintained onsite.
14
i ATTACilMENT (1) l BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION l
INTEGRATED PLANT ASSESSMENT METHODOLOGY METHODOLOGY NRC COMMM BGE RESPONSE CHANGE-provided that the aging effects will be managed (or does not require management) until such implementation.
Additionally, THE REPORT SHOUIE BE REVISED TO STATE THAT THE IMPLEMENTATION DATE OF FUTURE PROGRAMS OR MODIFICATIONS WILL BE SPECIFIED IN THE LRA.
I
- 29. Page 59, Section 6.3.3.2 indicates that aging management Yes The methodology will be resised to clarify that such could rely on less formal activities, such as plant tours by techniques are intended to be complementary to other managers.
PROVIDE EXAMPLES ON HOW SUCH activities such as one-time inspections and represent a defense INCIDENTAL ACTIVITIES can be relied on to manage aging in depth approach to aging management. These less formal to ensure intended functions.
activities are recogmzed in Generic Ixtter 91-18 for observing utant operation and identifying degraded conditions.
- 30. Page 60, Section 6.3.3.4, One-time inspections a) THE REPORT NEEDS TO BE MODIFIED TO Yes The methodology will be modified to clarify this pomt.
INCORPORATE THE FOLLOWINC Where applicable, the staff will require that any proposed one-time inspections be performed before the end of the initial 40-year license. In this way the staff can assure itself that there are no significant aging concerns prior to operation beyond the initial licensed term. The staff may accept one-time inspections after the end of the initial licensed term if the licensee provides adequate evidence that the specific issue of concern will not be a problem up to that time.
b) The report states that the one-time mspection can be Yes The methodology will be modified as suggested.
used to argue that the degradation is adequately i
i 15 e
i ATTACIIMENT (1)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY l
l METHODOLOGY NRC COMMENT BGE' RESPONSE CHANGE.
l managed. 'Ihe staff believes that THE CORRECT ARGUMENT SHOULD BE THAT THE DEGRADATION THAT IS OCCURRING WILL NOT RESULT IN LOSS OF THE COMPONENT FUNCTION during the period of extended operation and, therefore, no additional aging management activities or programs are necessary.
c) The report also concludes that ifindustry experience in Yes The methodology will be modified to clarify that if a the interim resolves an aging issue, a one-time commitment which has been previously made needs to be inspection would be canceled. 'Ihe staff agrees that adjusted or canceled, the site commitment management industry resolution of important aging issues will be process would be used to govern this activity.
valuable, however, A DETERMINATION THAT THE INDUSTRY HAS RESOLVED AN ISSUE WOULD NOT RELIEVE AN APPLICANT OF A REQUIREMENT OR COMMITMENT to perform an inspection.
(See Comment No. 23 for options to modify aging i
management programs.)
d) Page 60 (Section 6.3.3.4) indicates that a one-time inspection may be completed before the submittal of The need to extrapolate the results of one-ttme inspections the renewal application. It also indicates that if no will depend on the results of the inspection. If the effects of i
significant degradation is found in the inspection aging are expected to be muumal and no effects are found, no
[
sample, no program is needed other than documenting extrapolation would be m:eded In such cases, actisities such the inspection. DISCUSS HOW THE RESULTS OF THIS as those described in Section 6.3.3.2 will sen'e to subet=ntiate EARLY ONE-TIME INSPECTION WOUID BE the results of the one-time inspections. Other "one-time" EXTRAPOLATED TO DEMONSTRATE THAT THE inspections could result in the development of a periodic f
EFFECTS OF AGING WILL BE ADEQUATELY inspection program if results warrant such activities.
MANAGED FOR THE PERIOD OF EXTENDED l
OPERATION.
A discussion consistent with the above paragraph will be added to this section of the methodology.
r 16 r
ATTACHMENT (1)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY l
METHODOLOGY NRC COMMENT CHANGE
- 31. Page 60, Section 6.3.3.4 gives specific examples of one-Yes We believe that the examples prosided clarify the steps of the time inspection of certain SCs for renewal. Although the IPA and, therefore, should not be deleted. We are not one-time inspection is a useful tool for renewal, the staff requesting specific approval of the technical details of the has not determined whether the cited SCs would be examples as part of the review of this methodology.
adequately managed for renewal by one-time inspections.
However, to ensure that examples are not misinterpreted, the s
For example, freeze-thaw of external concrete is weather specific example pertaining to stress corrosion cracking of condition related, and Alloy 600 materials have cracked in Alloy 600 will be deleted.
service. Because the review at this time is a methodology review, BGE SHOULD REMOVE THE SPECIFIC EXAMPLES.
Similarly, on the same page, the report discusses how the l'
one-time inspection sample may be selected. Again, the concept is useful, but THE REPORT SHOULD NOT MENTION SPECIFIC COMPONENTS such as " valses" and
" Alloy 600"in the methodology.
- 32. Page 62, Section 6.3.4 indicates that " Assessment,"
None None of the SSCs within the scope of LR are any more
" Corrective Action," and " Confirmation" phases of the important because of LR. They are within the scope of LR aging management are performed through the existing " site because they perform important fhnetinne independent of LR.
issue reporting" and " corrective action program." Describe Consequently, controls are already in place for such how the existing site issue reporting and corrective action components which ensure issues related to their ability to program would be sensitive to LR issues. For example, perform their intended functions are adequately addressed.
l
" Assessment" would contain acceptance criteria for evaluation to ensure LR intended functions. DESCRIBE HOW THE SITE ISSUE REPORTING AND CORRECTIVE ACTION PROGRAM WOULD BE ALERTED TO THOSE
}
criteria, including NSR equipment that may not have 1
attracted much attention before renewal.
17 l
ATTACHMENT 0)
BGE RESPONSE TO t
NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOlhGY METHODOLOGY NRC COMMmT
. BGE RESPONSE CHANGE
- 33. Page 62, Section 6.4 indicates that the renewal application Yes Sections 6.4 and 7.3 will be modified to clarify that the LRA would contain a description of the programs and activities will contain a demonstration that the effects of aging are 1
that are relied upon to manage the effects of aging.
adequately managed, as well as a description of programs and i
Detailed justification of the adequacy of the programs will activities which manage the aging effects. The detailed be maintained onsite. THIS PROPOSAL COULD RESULT IN justification of the adequacy of each program or activity will A RENEWAL APPLICATION WITHOUT SUFFICIENT continue to be maintamed onsite in an audhable format. The DETAIL FOR AN NRC REVIEW. The renewal application discussion in Section 8.4 will also be adjusted as necessary to l
must describe the aging management programs and justify incorporate this concept.
why the proposed programs, either existing or additional, i
are adequate for renewal. Detailed program procedures l
need not be included in the application. The place for a l
summary description of programs and actisities for managing the effects of aging is the Final Safety Analysis Report supplement and not the renewal application. The documentation description needs to be resised accordingly.
- 34. Page 63, Section 7.0 addresses " Commodity Groups."
Yes Section 7 will be modified to include only a description of the Although the use of commodity groups is generally attemate process steps. The technical conclusions, which in acceptable, Section 7.0 actually contains the specific aging some cases dictate the nature of the alternate process, will be management programs for these commodity groups.
presented in the individual LRA section on each commodity Because the report addresses the IPA methodology and the group.
review at this time is on the methodology, the staff has not reviewed the aging management programs BALTIMORE GAS AND ELECTRIC COMPANY SHOULD RELOCATE j
SPECIFIC AGING MANAGEMENT PROGRAMS FOR COMMODITY GROUPS TO APPENDIX A AS EXAMPLES.
Aging management of commodities could follow the
+
methodology in Section 6 of the report.
l Further, the need for Section 7 of the report is unclear.
[
I Page 63 (Section 7.0) creates potential confusion by calling i
18
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+
t ATTACHMENT (1)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY METHODOLOGY NRC COMMENT BGE RESPONSE.
CHANGE some commodity evaluations " equivalent to entire IPA" and some evaluations " equivalent tojust AMR." It seems that all of the commodity groups could be pre-evaluated in Section 5.3, including a discussion of any special steps which caused the " equivalent to entire IPA" and " equivalent
[
to just AMR" distmction.
Then, based on the above t
comment, SECTION 7.0 MAY BE DELETED WITil THE SPECIFIC AGING MANAGEMENT PROGRAMS RELOCATED TO APPENDIX A.
- 35. Page 68, Section 7.2.1.2.
For all non-EQ cables, in Yes No radiation hot spots exist outside of contamment and, addition to thermal aging, potential RADIATION HOT therefore, radiat on hot spots do not need to be considered for SPOTS SHOULD BE ACCOUNTED FOR in the AMR for the non-EQ cable. However, based on the BGE response to i
cable commodity.
RAI34, this technical detail will be included in the LRA section for this commodity rather than in the methadalogy
- 36. Page 82, Figure 8-1 indicates that, for an evaluation that Yes We will revise the methodology to move the cited TLAA step.
otherwise meets the defmition of TLAA, a "yes" response Potential TLAAs which satisfy this criterion will be identified to "Is SSC covered by CLB program which updates as TLAAs and listed in the LRA. This step will be used in potential TLAA?" would make the evaluation not a TLAA.
the TLAA evaluation process as an aid in resohing the This is not consistent with 654.3. The CLB program could TLAA issue.
be a basis for re-evaluating the TLAA for renewal in
{54.21(c), but not a basis for disposing of the issue as not a TLAA in 54.3. THE REPORT NEEDS TO BE REVISED f
TO PROPERLY LABELTLAAS.
- 37. Page 83 Section 8.1 - What was the RANGE OF SEARCHES None
'Ihe range of TLAA searches will be provided in the TLAA f
USED TO IDENTIFY TLAAS?
submittal, not in the methodology. For your information, the l
searches which were used are prosided in Tables (3), (4) and (5).
19
r ATTACHMENT (1)
[
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION i
INTEGRATED PLANT ASSESSMENT METHODOLOGY METHODOLOGY
- NRC COMMENT CHANGE -
BGE RESPONSE
- 38. Page 84, Section 8.2 indicates that EQ is not a TLAA Yes With respect to the Secten 8.2 statement i# g EQ, this d
because of a CLB program called EQ. Similarly, the statement will be deleted consistent with the BGE rwac to methodology does not call out the containment pdussed RAI 36.
tendons as a TLAA requiring a re-evaluation in the renewal f
application (see page 3-5 of Appendix A).
i Issues such as EQ, metal fatigue, and prestressed tendons None With respect to the items not identified as TLAAs in are TLAAs in accord r :e with (54.3. He renewal rule in Appendix A, TLAAs are addressed in a separate agmg
{54.21(c) specifically requires such issues to be re-
==g=re report, Additionally, the listing and evaluaten j
evaluated to cover the period of extended operaton.
results of TLAAs are provided in a separate section of the i
RELIANCE ON A FUTURE PROCESS IN LIEU OF A RE-LRA.
EVALUATION IN THE RENEWAL APPLICATION WILL j
NOT SATISFY THE REQUIREMENTS OF THE RULE.
l ne METHODOthGY NEEDS TO BE REVISED SO THAT None With respect to reliance on future actens, {54.21(c) and
[
ISSUES SUCH AS EQ, METAL FATIGUE, AND (54.29 do not require re-analysis of all TLAAs prior to l
CONTAINMENT PRESTRESSED TENDONS WILL ALSO BE submittal of the LRA.
Paragraph 54.21(c) requires IDENTIFIED AS TLAAS.
evaluaten of the TLAAs and lists three equally weeptable l
actions for addressing TLAAs. He (54.29 findmg states i
that TLAAs are identified and actions identified and have I
been taken or will be taken with respect to TLAAs
- 39. Page 84, Section 8.3 indicates that all TLAAs subject to Yes We will remove the methodology wordmg in Secten 8.3 that renewal review are necessarily affecting SSCs within the causes the r4---w,. tion that TLAAs a=aci=*ed with long-scope of renewal and, therefore, the IPA process would lived passive Systems, structures and
- ;----== are
(
have managed aging of the long-lived passive SCs. Hus, categoncally excluded from TLAA evaluation because of the
[
the only TLAA issue to be reviewed is for active and short-IPA process. Instead, the section will include a discussion l
lived SCs. Although the report correctly pointed out that (similar to that presented in the following para iophs) to s
TLAAs, by definition, affect the same SSCs within the explain in more detail the relat anchip bet,,w the IPA and i
scope of renewal, it is an over-simplification to say that the the TLAA for these SSCs.
j IPA will necessarily address the TLAAs j
20
{
i
[
i i
f ATTACHMENT f1) -
BCE RESPONSE TO i
i NRC REQUEST FOR ADDITIONAL INFORMATION l'
INTEGRATED PLANT ASSESSMENT METHODOLOGY I
METHODOLOGY i
NRC' COMMENT
. BGE RESPONSE CHANGE-i Time-Limited Aging Analyses generally address agmg De IPA requires a i..emb.iion that the effects of agmg are effects that are difficult to be directly monitored. For adequately managed for all SCs within the scope of LR that j
example, there are currently no acceptable non-destructive are passive and long-lived. Paragraph 54.21(c) allows threc methods to measure the extent of embrittlement of a reactor options for addressing TLAAs, one bemg a iww.h tion vessel.
Also, there are currently no acceptable non-that the effects of agmg are adequately managed for the SCs j
i destructive methods to measure the integrity of cables.
affected by the TLAA. He definitum of TLAA provules that Thus, in general, it may be unrealistic to re:y on the IPA to only analyses affectmg SCs withm the scope of LR are completely address TLAAs defined as TLAAs Derefore, if the IPA was able to
[
demnactrate that the effects of agmg associated with the he TLAA DISCUSSION NEEDS TO BE REVISED TO TLAA are adequately wwsd during the penod of ertended BETTER REFLECT THE AGING MANAGEMENT operations) for a set of SCs, it follows that the requirement EXPECTATIONS.
under {54.21(c) would also be satisfied. (He requirements
}
are identical.)
L Ifcertam agmg effects associated with the TLAA are difficult or impossible to momtor directly as sugge**d the IPA l
process would have been va=MI in '--- ---a ting that i
a the effects of agmg are 2d~; -*4y Esgd by a plant program, Instead, the IPA process would have chosen a more analytical approach, cather by ev'eadhg the existmg time-l related analysis or substituting an alternate analysis, to j
l
&wsonate that the effects of agmg would not prevent performance of the intended function. In cather case, the requirements of {54.21(c) would still have been satisfied, l
since (54.21(c) allows extendmg the TLAA or justifying by analysis that the current analysis remains valid for the penod ofextended operatum Hus, the only remammg step would be to review the IPA l
results to ensure that the associated TLAA requirements are i
also met.
21 l
_ ATTACHMENT m p
BGE RESPONSE TO
[
NRC REQUEST FOR ADDITIONAL INFORMATION -
[
INTEGRATED PLANT ASSESSMENT METHODOthGY j
t METHODOLOGY f
- BGE RESPONSE
.NRC COMMENT
-CHANGE
- 40. Page 84, Section 8.3 does not provide a methodology on Yes We believe that the actual techniqm for reanalysis or l
how the re-evaluation of TLAAs would be performed The extending an existing TLAA would be specific to each time-i rule in {54.21(c) provides options in evaluating TLAAs dependent issue. Where there is already a well defined, Take metal fatigue, as an example: A component would widely accepted practu:e (such as 10 CFR 50.61, l
meet (54.21(cXIXi) ifit has been designed for 200 fatigue 10 CFR 50.49 or ASME code) which governs the TLAA, we cycles and is expected to see less than 200 cycles for will continue to use that process to re-evaluate or extend the i
60 years. A component would meet {54.21(c)(IXii) if it TLAA Wording will be =MM to Section 8.3 to reflect this
[
has a fatigue " cumulative usage factor (CUF)" ofless than discussion.
[
0.6 for 40 years, which would be less than unity if j
increased by 50 percent to cover 60 years. The option in For example, 10 CFR 50.61 clearly describes the l
{54.21(cXIXiii) would be evaluated case-by-case, such as requirements associated with pressurized thermal shock.
?
ASME Section XI ongoing activities regardmg These requirements would be implemental to account for
[
management of components with cumulative usage factors pressurized thermal shock during the period of extended that may have exceeded the code limit of unity.
operations. Because this regulatum requires a submittal prior to LRA approval, the results of this analysis would be The REPORT SHOUID EXPAND SECTION 8.3 TO submitted and approved prior to LRA approval.
DESCRIBE THE METHODOLOGY FOR RE-EVALUATING l
TLAAS.
If there is an outctma&ag generic issue ased=*M with the re-l analysis process (such as for EQ), the SOC to the Rule (60FR22484) provides three options: (1) if the issue is resolved before LRA submittal, the applicant can incorporate
[
the resolution into their LRA; (2) an applicant can justify that l
the CLB will be maintamed until a point in time when one or l
mom reasonable options would be available to =Aaa==*dy manage the effects of aging (for this alternative, the applicant j
would have to describe how the CLB would be mainemiaed j
until the chosen point in time and generally describe the options available in the future); (3) an applicant could develop a plant-specific program that mcorporates a i
resolution to the agmg issue.
[
i L
22 l
ATTACIIMENT 0)
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY I
METHO90 LOGY
' NRC COMENT BGE~ RESPONSE -
CHANGE For example, the requirements for evtending a qualified life under the EQ Program are dermed in {50.49 and supportmg regulatory information. If as a result of current activities, a GSI is associated with EQ, BGE may chose option (2) above to resolve this TLAA. Reliance on the existmg 40-year qualification would demonstrate that the CLB is maintained until the 40-year point. 'Ihe regulatory documents related to the GSI already describe the alternatives which would be available to resolve the issue.
Because the above discussion includes BGE's approach for TLAAs which are subject to a GSI or USI, a new Section 6.3.5 will also be added to the methodology to explain the BGE approach for aging management programs which are the subject ofa GSIor USI.
i l
t i
l
)
i I
23 i
. ~ -... -
ATTACHMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY TABLE (1)
Relationship Between Previous and Current Revisions of IPA Methodology Revision 1993 METHODOLOGY 1995 METHODOLOGY Volume 1, Section 1: " Introduction" &
Section 1: " Introduction."
Volume 2, Section 1: " Introduction."
Volume 1, Section 2: " Screening Methodology Section 2: " IPA Methodology Basis and Oveniew."
Basis and Overview."
Volume 2, Section 2: "Cemponent Evaluation Methodology Basis and Oven >iew."
Volume 1, Section 3: " System Level Screening."
Section 3: " System Level Scoping."
Volume 1, Section 4: " Component Level Section 4: " Component Level Scoping."
Screening."
Volume 1, Section 5: " Component Evaluation and Deleted. This section in the presious nx:thodology Component Aging Evaluation Tasks."
was a briefintroduction to the next volume.
Volume 2, Section 3: " Component Evaluation."
Section 5: " Pre-Evaluation."
Volume 2, Section 4: " Component Aging Section 6: " Aging Management Resiew",
Evaluation."
specifically 6.2 " Performing the Aging Management Review by Evaluating Aging Mechanisms."
Section 6.1 was added to describe other methods for conducting the AMR.
Volume 2, Section 5: " Implementation Planning Section 6.3: " Methods to Manage the Effects of Overview."
Aging" Section 7: " Commodity Evaluations." 'nis section describes six cases where the normal IPA process was modified to add efficiency to specific evaluations.
Section 8:" Time Limited Analyses Review." This section describes the process for completing this new requirement in the revised LR Rule.
24
ATTACI1 MENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PwT ASSESSMENT METHODOLOGY TABLE (2)
Resolution of NRC Review Items Associated with the 1993 IPA Methodology NRC Review Item -
Methodology Page -
NRC Review Item -
Methodology Page
RAI 1
2
RAI 22
No changes
RAI 2
3
RAI 23
No changes RAI 3 (ConfItem 3) 15
RAI 24
35
RAI 4
Deleted reference to
RAI 25
37 CLB/D throughout the methodology.
RAI 5
No changes
RAI 26
38 RAI 6 (ConfItem 1)
Section deleted from RAI 27 (Open Item 1) 19 & 20 the methodology as requested.
a
RAI 7
13 RAI28 9 & 10
RAI 8
See response to
RAI 29
Bracketed information
RAI 6
was deleted as requested.
RAI 9
17
RAI 30
Terminology changes made for consistency throughout.
RAI 10
See response to RAI31 2
RAI 6
RAI 11 No changes
RAI 32
Terminology changes made for consistency throughout.
RAI 12
See response to RAI33 15,29 & 30
RAI 35
RAI 13 16
RAI 34
13
RAI 14
19
RAI 35
Terminology changes made for consistency throughout.
RAI 15
18 & 19
RAI 36
No changes
RAI 16
See response to
RAI 37
Definition deleted.
RAI 14
RAI 17 No changes
RAI 38
See response to RAI4
RAI 18
No changes RAI39 22 RAI 19 (ConfItem 5) 21 RAI 40 (ConfItem 2) 22 RAI 20 (ConfItem 4) 21 & 34 RAI41 No changes
RAI 21
No longer applicable
RAI 42
38 & 39 due to rule change.
Note: Page numbers refer to the August 18, 1995 submittal of the BGE IPA Methodology. These page numbers will vary slightly in the marked up version of the methodology.
25
ATTACHMENT 1
BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY TABLE (3)
List of Search Criteria in CCNPP Electronic Docket 1968-92 & Updated Final Safety Analysis Report Revision 17 for Identifying Potential TLAAs During Plant-Specific Search Search was performed using the first word within five words of the second word. For those with an asterisk, search was also performed using the second word within five words of the first word.
Different forms of the words were included in the search using the "+" command.
plant / life design / life component / life
- fatigue / life
- fatigue / analysis
- fatigue / analyses
- fatigue / evaluation
- analysis / year analyses / year analysis /yr*
analyses /yr*
40/ year or 40/yr forty / year or forty /yr license / term license / period license / life
- erosion / allowance
- corrosion / allowance
- EFPY effective full power years (searched as complete phrase) effective full power yr (searched as complete phrase) life / limit equipment / life cycle / year useful/ life
- installed / life
- service / life
- qualified / life
- residual / life
- life expectancy (searched as complete phrase) life of the plant (searched as complete phrase) 26 w
ATTACHMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT MET.lODOLOGY TABLE (4)
List of Search Criteria in CCNPP Electronic Docket 1968-92 & Updated Final Safety Analysis Report Revision 17 for Identifying Potentia! Based on Other Utility's Results Search was performed using the first word within five words of the second word.
reactor / coolant / pump / flywheel / missile RCP/ flywheel / missile pump / flywheel / missile pump / flywheels / missile flywheel CE/ topical / report Combustion / Engineering / topical report CEOG/ topical / report Bechtel/ topical / report vendor / topical / report topical / report topical / reports 27
ATTACHMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY TABLE (5)
POTENTIAL TLAAS ASSOCIATED WITH CODES, STANDARDS AND REGULATORY DOCUMENTS CODE / STANDARD / '
ISSUE '
SSC TLAA-ISSUE
_ REGULATORY DOCUMENT DATE(S) 10 CFR Part 50, Reactor Vessel Fracture Toughness Appendix G, 10 CFR Part 50, Reactor Vessel Embrittlement-Neutron Appendix H Fluence Limit 10 CFR 50.49 Electrical Components Resistance to Radiation Instrumentation Degradation EfTects Controls Aging Qualification Tests 10 CFR 50.61 Reactor Vessel Embrittlement-Ductility ACI 318 1971,1983 Intake Structure Loss of Prestress Class 1 Structures Containment Offgas Stack and Flue Intake Canal Equipment Supports and Foundations ACI 349 1980 (1977)
Class 1 Concrete Loss of Prestress Structures AISC 1970 Class 1 Structures Fatigue Seventh Spent Fuel Pool Liner Edition Intake Structures Primary Containment Structure Reactor Vessel Supports Intake Canal AISC 1970 Crane Rails Fatigue Seventh Edition ANSI B31.1 1967 Class 1,2,3 Piping Fatigue B31.1.0 Non-Nuclear Piping Corrosion Hangers, Supports, Embrittlement Blind Flanges, Fittings ANSI B31.7 1969 Class 1,2,3 Piping Irradiation Class 1 :Iangers, Corrosion Supports, and Fatigue Snubbers Service Water Piping
' Saltwater at BGE) 28
~ _ _ - -....... -
ATTACHMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY TABLE (5)
POTENTIAL TLAAS ASSOCIATED WITH CODES, STANDARDS AND REGULATORY DOCUMESTS CODE / STANDARD /
' ISSUE REGULATORY DOCUMENT DATE(S)-
API 620 12/31n8 Condensate Storage Settlement Revision 2 Tanks Corrosion Sixth Edition API 650 1979 Above Ground Oil Corrosion J
Revision 3 Tanks Settlement Sixth Edition Condensate Storage Tanks ASME Section til 1965 Edition Reactor Vessel Embrittlement Nuclear Vessels Steam Generator Fatigue Pump Bodies Corrosion Valve Bodies Pressurizer Accumulator Containment ASME Section VIII 1968 Edition Pressure Vessels Corrosion Division 1 Heat Exchanger Pressure Vessels Demineralizers Containment Accumulators Head Tanks ASME Section VIII 1968 Edition Air Dryers Corrosion Division 1 Pressure Vessels ASME Section XI 1983 Edition Reactor Vessel Fatigue Inservice Inspection Steam Generator Crack Growth Pressurizer Hydrotest Temperature Pumps Valves Supports Piping Core Structures ASME Section III 1977 Concrete Containment Loss of Prestress Division 2 Settlement (Code for Concrete Reactor Fatigue Vessels and Containments) 29
ATTACllMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METHODOLOGY TABLE (5)
POTENTIAL TLAAS ASSOCIATED WITil CODES, STANDARDS AND REGULATORY DOCUMENTS CODE / STANDARD /
ISSUE 33g.
TLAA ISSUE REGULATORY DOCUMENT -
DATE(S) -
ASME Section III Nuclear 1971 Edition Reactor Vessel Fatigue Power Plant Components Steam Generator Division 1 Pressurizer Accumulator Pumps Valves Piping Containment Classes 1,2,3 MC ASME Section III Nuclear 1971 Edition Steam Generator Embrittlement Power Plant Components Pressurizer Division 1 Accumulator Pumps Valves Piping Containment Classes 1,2,3 MC ASME Section Ill Nuclear 1971 Edition Reactor Vessel Embrittlement Power Plant Components Division 1 ASME Section III Nuclear 1971 Edition Reactor Vessel Corrosion Power Plant Components Steam Generator Division 1 Pressurirrt Accumulator Piping Containment MC ASME Section III Nuclear 1971 Edition Pumps Corrosion Power Plant Components Valves Division 1 Classes 1,2,3 30
ATTACilMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METIIODOLOGY TABLE (5)
POTENTIAL TLAAS ASSOCIATED WITil CODES, STANDARDS AND REGULATORY DOCUMENTS CODE / STANDARD / -
ISSUE SSC TLAA-ISSUE REGULATORY DOCUMENT.
DATE(S)
ASME Section til Nuclear 1971 Edition Reactor Vessel Deterioration of Materials in Power Plant Components Steam Generator Senice Division 1 Pressurizer Accumulator Pumps Valves Piping Containment Classes 1,2,3 MC AWS DI.1 1975 Class 1 Structures Fatigue (steel)
Reactor Vessel Supports Pipe Whip Restraints and Jet Impingement Shields llangers and Supports AWWA D100 1973 CST Corrosion AWWA D100 1973 Reservoirs Corrosion EJMA 1969 Bellows Fatigue 3rd Edition Corrosion IEEE-317 1976 Electrical Penetration Qualified Life Assemblies IEEE 323 1974 Class 1E Electrical and General Aging Instrumentation Equipment in liarsh Emironments IEEE-334 1974 Motors Aging Simulation Motor Life IEEE-382 1972,1980 Safety-Related Valve Qualified Life Actuators IEEE-383 1974 Cables, Splices, Environmental Aging (ANSI N41.10)
Connectors NUREG-0800 June 1987 Class 1 Piping Pipe Rupture Locations SRP 3.6.2 NUREG-0800 June 1987 Circuit Breakers Life Cycle Operability SRP 8.2 NUREG-0800 June 1987 Class 1 Piping Fatigue SRP 3.6.1 31
ATTACIIMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT MET 110DOLOGY TABLE (5)
POTENTIAL TLAAs ASSOCIATED WITil CODES, STANDARDS AND REGULATORY DOCUMENTS CODE / STANDARD /
ISSUE REGULATORY DOCUMENT DATE(S)
NUREG-0800 June 1987 Conduits Soil Settlement SRP 3.7.3 Tennels Buried Piping NUREG-0800 June 1987 Stect Containment Fatigue SRP 3.8.2 NUREG-0800 June 1987 Reactor Coolant Fatigue SRP 3.9.1 Pressure Boundary NUREG-0800 June 1987 Snubbers Evaluation of Fatigue Strength i
SRP 3.9.3 (Piping Supports)
NUREG-0800 June 1987 Control Rod Life Cycle Operability SRP 3.9.4 Drive System NUREG-0800 June 1987 Class IE Equipment Equipment Qualification SRP 3.ll NUREG-0800 June 1987 - Reactor Vessel Material Surveillance of Vessel SRP 5.3.1 NUREG-0800 June 1987 Reactor Vessel Material Surveillance of Vessel SRP 5.3.2 NUREG-0800 June 1987 Reactor Vessel Fracture Toughness BTP MTEB 5-2, B.I.2 NUREG-0800 June 1987 Reactor Vessel Fracture Toughness BTP MTEB 5-2, B.3.2 NUREG-0800 June 1987 Reactor Vessel Fracture Toughness SRP 5.3.2 NUREG-0800 June 1987 ECCS Components Corrosion SRP 6.1.1 NUREG-0800 June 1987 MSIV Actuators Corrosion SRP 6.1.1 Regulatory Guide 1.121 August 1976 Steam Generator Tubes Fatigue Resision 0 Regulatory Guide 1.131 August 1977 ClassIE Qualification Testing Revision 0 Electric Cables Regulatory Guide 1.154 January 1987 Reactor Vessel Operation Under Pressurized Revision 0 Thermal Shock Situation Regulatory Guide 1.35.1 July 1990 Concrete Containment Loss of Prestress Revision 0 Structures Regulatory Guide 1.89 June 1984 Safety Related Electric Requalification of Electrical Revision 1 Equipment Components Regulatory Guide 1.90 August 1977 Concrete Containment Loss of Prestress Revision 1 Structures 32
ATTACIIMENT BGE RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION INTEGRATED PLANT ASSESSMENT METilODOLOGY TABLE (5)
POTENTIAL TLAAS ASSOCIATED WITil CODES, STANDARDS AND REGULATORY DOCUMENTS CODE / STANDARD /.
ISSUE i
C TLAA-ISSUE REGULATORY DOCUMENT DATE(S)
Regulatory Guide 1.99 May 1988 Reactor Vessel Embrittlement Resision 2 l
33
s m
Calvert Cliffs Nuclear Power Plant Supporting Information for BGE/NRC License Renewal Discussions December 6,1995 For Information Only
Industry Operating Experience Information Processing NS-1-300 rmw:o:n)
-hf Functional Evaluation / Operability j '
a,.: ' ;j Determination kJ Issue Reporting and Assessment
. 3 QL-2-100 Commitment Management l
RM 1-103 Erosion / Corrosion Monitoring of Secondary Piping 5
M N-3-111
........q.
l(;<G0pg Specification and Surveillance:
.W.1:.E..E.d Secondary Chemistry
. 4. ; ;;y 5[.~::[ d CP-217
- f;.} \\
j&
t :! :
i Not Used
+;:
' ikk dd$
Not Used 1