ML20151V390
| ML20151V390 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/01/1998 |
| From: | Dave Solorio NRC (Affiliation Not Assigned) |
| To: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| References | |
| TAC-M99209, TAC-M99595, TAC-M99596, NUDOCS 9809140290 | |
| Download: ML20151V390 (6) | |
Text
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September 1, 1998 Mr. Chari:s H Cruss, Vics Presidcnt e'.
Nuclear Energy Division Baltimore Gas & Electric Company 1650 Calvert Cliffs Parkway Lusby, MD 20657-47027
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 & 2, INTEGRATED PLANT ASSESSMENT REPORT FOR THE SPENT FUEL POOL COOLING SYSTEM (TAC NOS. M99595, M99596, AND M99209)
Dear Mr. Cruse:
By letter dated August 21,1997, Baltimore Gas and Electric Company (BGE) submitted for review the Spent Fuel Pool Cooling System (5.18) integrated plant assessment technical report as attached to the " Request for Review and Approval of System and Commodity Reports for License Renewal." BGE requested that the Nuclear Regulatory Commission (NRC) staff review report 5.18 to determine if the report meet the requirements of 10 CFR 54.21(a), " Contents of application-technical information," and the demonstration required by 10 CFR 54.29(a)(1),
" Standards for issuance of a renewed license," to support an application for license renewal if BGE applied in the future. By letter dated April 8,1998, BGE formally submitted its license renewal application.
The NRC staff has reviewed the Spent Fuel Pool Cooling System (5.18) against the requirements of 10 CFR 54.21(a)(1),10 CFR 54.21(a)(3). By letter dated April 4,1996, the NRC staff approved BGE's methodology for rneeting the requirements of 10 CFR 54.21(a)(2).
- Based on.a review of the information submitted, the NRC staff has identified in the enclosure, areas where additional information is needed to complete its review.
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 NRC staff would be willing to meet with BGE prior to the submittal of the responses to provide clarifications of the staff's requests for additionalinformation.
Sincerely, M By David L. Solorio, Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-3' R
Enclosure:
Request for AdditionalInformation
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DATE 8/3l/98 8/3//98
[ 8/ /91 t$/l /98 #l OFFICIAL RECORD COPY 9909140290 980901 W
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e Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant
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Baltimore Gas & Electric Company Unit Nos.1 and 2 i
cc:
1 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 Cornpany Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre i
Baltimore, MD 21203 Suite 2102 i
Baltimore, MD 21202-1631 Jay E. Silberg, Esquire i
- Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire 2300 N Street, NW Co-Director I
' Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Thomas N. Prichett, Director Baltimore, MD 21218 j
NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donateli j
1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector i
U.S. Nuclear Regulatory Commission.
David Lewis P.O. Box 287 Shaw, Pittman, Potts, and Trowbridge i
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 DJW@NEl.ORG Regional Administrator, Region i U.S. Nuclear Regulatory Commission Barth W. Doroshuk 475 Allendale Road Baltimore Gas and Electric Company King of Prussia, PA 19406 Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway NEF ist Floor Lusby, Maryland 20657
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REQUEST FOR ADDITIONAL INFORMATION CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS.1 & 2 SPENT FUEL POOL COOLING SYSTEM INTEGRATED PLANT ASSESSMENT. SECTION 5.18 DOCKET NOS. 50-317 AND 50-318 i
Section 5.18.1 - Sconina
)
j 1.
The simplified diagram of the spent fuel pool cooling system (SFPCS) on page 5.18-3 in subsection 5.18.1.1 shows system interfaces with the Solid Waste Disposal System and
- the Domineralized Water and Condensate Storage System These interfaces show boundary valves (diaphragm valves) with small pipe segments extending a short distance beyond the boundary valve and then ending (no pipe support, isolation valve or apparatus is apparent). Are these small pipe segments within the scope of license renewal? If so, specify the interfaces at the end of these pipe segments that separate the portions of the system within the scope of license renewal from those portions of the system outside the scope of license renewal.
2.
Calvert Cliffs Nuclear Power Plant (CCNPP) Updated Final Safety Analysis Report (UFSAR) Figure 9-7 (Baltimore Gas and Electric Company Drawing 64-314, Rev. 2) y shows an additional interface (five piping connections to the demineralizer compared i
with the four shown on Figure 5.18-1) with the Spent Fuel Pool Demineralizer. The line appears to be from the Instrument Air System and is not addressed in Section 5.18.
Please provide an evaluation of this line including its scoping boundaries for license renewal.
3.
CCNPP UFSAR Figure 9 7 shows a portable resin addition tank connected to the spent fuel pool (SFP) Demineralizer by a spool piece. Figure 5.18-1 does not clearly indicate where the scoping boundary for the sections of piping up to and including the resin addition tank. Please provide the basis for why this portion of the spent fuel pool cooling system line including its boundaries were excluded from the scope of license renewal or a cross reference to where it is addressed in the license renewal application (LRA).
4.
CCNPP UFSAR Figure 9-7 includes the following " device" that is not included in Table 5.18-1, "SFPCS Device Type Disposition" FG. Three of these devices are located in the piping connected to the demineralizer. Please explain what device type these symbols represent and how they are dispositioned for license renewal.
Section 5.18.2 - Aalna Manaaement 5.
Section 5.18.1 indicates that there were several instances of cracking of SFPCS piping and a detailed study was performed in early 1990 to determine the root cause and appropriate remedy. The study determined that the cracking was due to high-cycle -
fatigue caused by cavitation-induced vicration. Subsequently, certain orifices and valves were modified to eliminate system cavitaCon. This section of the LRA also indicated that implementation of these improvements has prevented recurrence of cracking in SFPCS Enclosure.
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piping. Please address whether the piping susceptible to cracking is subject to an aging i
management review (AMR). If so, please provide a summary discussion of the AMR l
performed for this piping that demonstrates there is reasonable assurance that the intended functions for these components will be maintained during the period of i
extended operation by managing high-cycle fatigue and other aging effects of the 4
SFPCS piping, if not, provide the basis from excluding these components from an AMR.
l Please address whether these modified orifices and valves are subject to an AMR. If so, please provide a summary discussion of the AMR performed for these orifices and l
valves that demonstrates there is reasonable assurance that the intended functions for j
these components will be maintained during the period of extended operation by managing high-cycle fatigue and other aging effects (e.g., erosion) of these orifices and valves. If not, provide the basis from excluding these components from an AMR.
i' Subsection 5.18.1.1 states that since normal service loads do not result in significant vibration or other rtynamic loading conditions, fatigue is not plausible for SFPCS. Please provide the values and the basis for the determination of "significant vibration" and provide a description of the monitoring activities used to determine any post-modification i
vibration significance. Please indicate if monitoring is ongoing, performed periodically, or j
planned for some time in the future to indicate and track any future vibration.
5 The Calvert Cliffs UFSAR Section 9.4.3.2 states that the SFPCS piping was designed to I
ANSI B31.7 Code requirement. While the Code does not require an explicit fatigue analysis for Class 11 and 111 piping system, it does specify allowable stress levels based i
on the number of anticipated thermal cycles. Please provide a discussion on the fatigue evaluation for the SFPCS piping with respect to the requirements of 10 CFR 54.21(c)(1) focusing why the number of thermal cycles expected to occur during the period of extended operation will preclude reaching allowable stresses for the SFPCS components.
y 6.
Table 5.18-3 indicates that wear is a plausible age-related degradation mechanism for hand valves in the SFPCS. Section 5.18.2 indicates that the local leak rate testing (LLRT) of the containment isolation requires corrective actions as part of the program 1
which will ensure that the intended function of the containment isolation hand valves will j
be maintained under the current licensing basis during the period of extended operation.
I i
However, the staff noted in Figure 5.18-1 that the SFPCS includes certain hand valves
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that are not containment isolation valves and, therefore, are not subject to the LLRT.
Please specify any aging management program for these valves to manage the effects 2
of wear in order to maintain their intended function during the period of extended operation.
7.
Table 5.18-4 in Section 5.18.2 shows the list of subcomponents and materials subject to aging. Provid6 the basis for excluding the SFP heat exchanger tubing, which has the J
. Intended function of removing heat from the SFP, the refueling pool water, and
. maintaining the pressure boundary of the SFPCS from this table.
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intended function of removing heat from the SFP, the refueling pool water, and maintaining the pressure boundary of the SFPCS from this table.
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8.
Discuss plans for detection of inadvertent ingress of service water from the shell side of the heat exchanger which is at a higher pressure than that of the tube side, through 4
j degraded SFP heat exchanger tubes into spent fuel pool water and into other interface systems which could lead to a chloride excursion.
I 9.
Are there any parts of the systems, structures and components within the SFPCS system 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 I:onditions 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 degtadation; (b) Parameters monitored or inspected relative to degradation of specific structure and component intended functions; (c) Detection of aging effects before loss of structure acd component intended functions; (d) Monitoring, trending, inspection, testing frequency, ar,d 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.
10.
Provide a summary description of Calvert Cliffs operating and maintenance experience related to boric acid corrosion of carbon steel components. In particular, characterize the extent to which boric acid corrosion of carbore steel components has changed since the initialimplemntation of the boric acid corrosic n inspection (BACl) program. Also, describe the extent to which carbon steel compor.ents in the spent fuel pool cooling system have had to be repaired or replaced because of boric acid corresion, since the implementation of the BACI program.
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