ML20151V371
| ML20151V371 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/04/1998 |
| From: | Dave Solorio NRC (Affiliation Not Assigned) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| TAC-M99224, TAC-MA1018, TAC-MA1019, TAC-MA1034, TAC-MA1035, TAC-MA1040, TAC-MA1041, TAC-MA1106, TAC-MA1107, NUDOCS 9809140281 | |
| Download: ML20151V371 (6) | |
Text
-
,l y September 4, 1998 Mr. Chirits H. Cruss, Vice Presid:nt Nuclear Energy Division Baltimore Gas & Electric Company 1650 Calvert Cliffs Parkway Lt.aby, MD 20657-4702
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 & 2, INTEGRATED i
PLANT ASSESSMENT FOR HEATING AND VENTILATION SYSTEMS (TAC 4
]
NOS. MA1018, MA1019, MA1034, MA1106, MA1107, M99224, MA1040, MA1041, AND MA1035)
Dear Mr. Cruse:
By letter dated April 8,1998, Baltimore Gas and Electric (BGE) submitted for review its license renewal application. The staff has reviewed Section 5.11A," Auxiliary Building Heating and Ventilation System;" Section 5.118, " Primary Containment Heating and Ventilation System;" and 3
i Section 5.11C, " Control Room and Diesel Generator Buildings HVAC," of Appendix A to the application against the requirements of 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(3). Based on a review of the information submitted, the staff has identified in the enclosure, areas where i
additional information is needed to complete its review.
I j
Please provide a schedule by letter or telephonically for the submittal of your responses within 30 days of the receipt of this letter. Additionally, the staff would be willing to meet with BGE prior to the submittal of the responses to provide clarifications of the staff's requests for additional 1
information.
4 l
Sincerely, I
M U Of J
David L. Solorio, Project Manager l
License Renewal Project Directorate Division of Reactor Program Management j
Office of Nuclear Reactor Regulation i
Docket Nos. 50-317 and 50-318
Enclosure:
Request for Additional Information I
cc w/ encl: See next page g
DISTRIBUTION:
D1, See next page
}
DOCUMENT NAME:G:\\ WORKING \\ LEE \\HVAC_RAl.LTR LA:PDy/DRPM PDLR/DQ
%R/DRPldl:ASC PDLR/DRPM:D OFFICE l
NAME DSold BPratK CGrime[h DATE 9/p/98 9h8
[ 9/ /A 9/Ar/98 OFFICIAL RECORD COPY 4
- =
^=
NRCIII
}%
9809140281 980904 l
5 4
Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos.1 and 2 cc:
President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland 175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore, MD 21202-6806 James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire 2300 N Street, NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Thomas N. Prichett, Director Baltimore, MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector U.S. Nuclear Regulatory Commission David Lewis P.O. Box 287 Shaw, Pittman, Potts, and Tri wbridge St. Leonard, MD 20685 2300 N Street, NW Washington, DC 20037 Mr. Richard I. McLean Nuclear Programs Douglas J. Walters Power Plant Research Program Nuclear Energy Institute Maryland Dept. of Natural Resources 1776 i Street, N.W.
Tawes State Office Building, B3 Suite 400 Annapolis, MD 21401 Washington, DC 20006-3708 Regional Administrator, Region l Barth W. Doroshuk U.S. Nuclear Regulatory Commission Baltimore Gas and Electric Company 475 Allendale Road Calvert Cliffs Nuclear Power Plant King of Prutsia, PA 19406 1650 Calvert Clif,'s Parkway NEF 1st Floor Lusby, Maryland 20657
~_
Distribution:
HARD COPY Docket Files PUBLIC PDLR R/F MEl-Zeftawy DISTRIBUTION: E-MAIL:
FMiraglia (FJM)
JRoe (JWR)
DMatthews (DBM) i CGrimes (CIG)
TEssig (THE)
Glainas (GCL)
JStrosnider (JRS2)
GHolahan (GMH)
SNewberry (SFN)
GBagchi(GXB1) l RRothman (RLR)
JBrammer (HLB)
CGratton (CXG1)
JMoore (JEM)
MZobler/RWeisman (MLZ/RMW)
SBajwa/ADromerick (SSB1/AXD)
LDoerflein (LTD)
BBores (RJB)
SDroggitis (SCD)
RArchitzel(REA)
CCraig (CMC 1)
LSpessard (RLS)
RCorreia (RPC)
RLatta (RML1)
EHackett (EMH1)
AMurphy (AJM1)
TMartin (TOM 2)
DMartin (DAM 3)
GMeyer (GWM)
WMcDowell (WDM)
SStewart (JSS1)
THiltz (TGH)
SDroggitis ?SCD)
DSolorio (DLS2)
PDLR Staff i
TCheng (TMC)
EHylton (EGH)
i I i
REQUEST FOR ADDITIONAL INFORMATION CALVERT CLIFFS UNITS 1 AND 2 INTEGRATED PLANT ASSESSMENT SECTION 5.11 A. " AUXILIARY BUILDING HEATING AND VENTILATION SYSTEM."
l SECTION 5.11B. " PRIMARY CONTAINMENT HEATING AND VENTILATION SYSTEM." AND l
SECTION 5.11C. " CONTROL ROOM AND DIESEL GENERATOR BUILDING HVAC" DOCKET NOS. 50-317 AND 50-318 i
1.
Sections 5.11 A.1,5.118.1 and 5.11C.1 of the application state that representative historical operating experience pertinent to aging is included in appropriate areas, to provide insight supporting the aging management demonstration. From the past operating experience, provide specific examples of how the corrective actions (including types, methods, criteria, etc.) related to the aging degradation of heating and ventilation (H&V) systems were taken in the auxiliary building, primary containment, and control room and diesel generator buildings.
2.
As described in Sections 5.11A and 5.11C of the application, for the H&V systems located in the auxiliary building, and control room and diesel generator buildings, some cracking has been discovered in pl ant heating, ventilating, and air conditioning (HVAC) ducting due to vibration-induced fatigue. The application also states that these isolated failures were due to a combination of design and installation deficiencies. Please address the following:
a.
Clarify the basis for the conclusion that these isolated failures did not involve any age-related degradation mechanisms (ARDMs).
b.
With regard to the corrective actions, provide details of how these cracks were corrected and how these failures affected the intended function.
3.
As described in the operating experience for Sections 5.11A,5.11B, and 5.11C of the application, loosening of fasteners due to dynamic loading was identified as an ARDM.
Provide a justificat en of why this ARDM is identified as plausible only for fans in the ARDMs tab!es (Tables 5.11A-2,5.11B 2 and 5.11C-2) and not fasteners or other device types exposed to dynamic loads.
4.
Section,5.11 A.2,5.11B.2 and 5.11C.2 of the application describe ARDM and device j
type enmbinations for aging management. Provide a justification as to why mechanical i
wear of the duct systems is not considered as a plausible ARDM.
5.
As described in the application (Sections 5.11 A.1.3,5.11B.1.3 and 5.11C.1.3), some of the device types (such as damper, filters, hand valve, and pressure differe.ntial indicator in the auxiliary building; damper, filter and solenoid valve in the primary containment; analyzer element, gravity damper, hand valve and temperature transmitter in the control room and diesel generator buildings) are subject to a detailed evaluation of ARDMs as part of the aging management review (AMR). However, there are no entries of potential and plausible ARDMs under these device types in Tsbles 5.11A-2,5.11B-2 and 5.11C-2 Enclosure
- (
a
,a i
2
?
of the application. Provide a summary description of the ARDMs considered for these device types and the basis for the plausible ARDM conclusion.
6.
In describing the aging management programs for components such as ducting and heat exchangers, the application (Discoverv in Pages 5.11A-13,5.11B-15 and 5.11C-11) states that crevice corrosion, general corrosion, and pitting can be readily detected through visual examination. Clarify how these aging effects will be managed for j
locations such as lap joints that cannot be readily inspected visually.
L i
7.
Tables 5.11A-1,5.11B-1 and 5.11C-1 of the application list all the H&V system device i
j types for which the AMR is required. Also, Sections 5.11A.1.3,5.11B.1.3 and 5.11C.1.3 of the application include a statement that only the pressure-retaining function (the passive intended function) for these device types is considered in the AMR for the H&V systems in the auxiliary building, primary containment, and control room and diesel j
generator buildings. However, no description of how to maintain this passive intended function is included in the application. Clarify how the aging management programs described in the application maintain the pressure-retaining function of these device
. types.
l 8.
Pages 5.11A-7 and 5.11C-6 of the application indicate that certain device types "do not require a detailed evaluation of specific aging mechanisms because they are considered j
part of a complex assembly whose only passive function is closely linked to active i
performance." The listed device types include accumulators, piping, and valves. Clarify how the passive functions of these devices are adequately managed by such i
performance monitoring, in particular, describe the nature of the monitoring and i
demonstrate that the degrada4on of the particular component intended function is
" closely linked" to the paramoters being monitoring in a performance monitoring program, such that the component intended function would be maintained for the period of extended operation.
9.
Page 5.118-6 of the application indicates that temperature elements do not require an.
3 AMR because they have only active functions. However, thermocouples and RTDs are i
installed in thermowells which perform a pressure retaining function and have housings l
which serve as environmental barriers. Clarify BGE's basis for concluding that
{.
temperature elements do not have any passive functions.
10.
On Page 5.118-10, the application includes a description of two aging degradation 4~
experiences for valves: (1) some wear of the containment purge supply and exhaust containment isolation valves (control valves) were identified, and (2) check valves have i
experienced pressure boundary failures with several valves failing back-leakage tests.
The application also states that the root cause of these failures is due to a combination of t
j wear and misapplication of the valve for its intended function. Please address the j
following:
s.
Clarify the basis for the conclusion that these failures did not involve any age-j-
related degradation mechanisms.
i 4
I e
. s,;
-yy~
..-~.-.e,.
1 8
3 b.
Provide a description of the corrective actions implemented for these two cases.
11.
Are there any parts of the systems, structures and components within the H&V systems that are inaccessible for inspection? If so, describe what aging management program will be relied upon to maintain the integrity of the inaccessible areas. If the aging management program for the inaccessible areas is an evaluation of the acceptability of inaccessible areas based on conditions found in surrounding accessible areas, please provide information to show that conditions would exist in accessible areas that would indicate the presence of, or result in degradation to, such inaccessible areas. If different aging effects or aging management techniques are needed for the inaccessible areas, please provide a summary to address the following elements for the inaccessible areas:
(a) Preventive actions that will mitigate or prevent aging degradation; (b) Parameters monitored or inspected relative to degradation of specific structure and component intended functions; (c) Detection of aging effects before loss of structure and component intended functions; (d) Monitoring, trending, inspection, testing frequency, and sample size to ensure timely detection of aging effects and corrective actions; (e) Acceptance criteria to ensure structure and component intended functions; and (f) Operating experience that provides objective evidence to demonstrate that the effects of aging will be adequately managed.
\\
I 1
i i
\\.
-