ML20151X841

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Forwards RAI Re Plant,Units 1 & 2 Integrated Plant Assessment Rept for Ms SG Blowdown,Extraction Steam & Nitrogen & Hydrogen Sys.Response Requested within 30 Days of Receipt of Ltr
ML20151X841
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/31/1998
From: Dave Solorio
NRC (Affiliation Not Assigned)
To: Cruse C
BALTIMORE GAS & ELECTRIC CO.
References
TAC-M99213, TAC-MA0297, TAC-MA0304, TAC-MA297, TAC-MA304, NUDOCS 9809170272
Download: ML20151X841 (6)


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August 31, 1998 Mr. Charles H. Cruse, Vice President i

Nuclear Energy Division Baltimore Gas & Electric Company 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 l

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE l

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 & 2, INTEGRATED PLANT ASSESSMENT REPORT FOR THE MAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM, AND NITROGEN AND HYDROGEN SYSTEMS (TAC NOS. MA0297, MA0304, AND M99213)

Dear Mr. Cruse:

By letter dated October 22,1997, Baltimore Gas and Electric Company (BGE) submitted for review the Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and i

I Hydrogen Systems (5.12) integrated plant assessment technical report as attached to the i

" Request for Review and Approval of System and Commodity Reports for License Renewal."

BGE requested that the Nuclear Regulatory Commission (NRC) staff review report 5.12 to determine if the report meet the requirements of 10 CFR 54.21(a), " Contents of application-i technical information," and the demonstrati s aquired by 10 CFR 54.29(a)(1), " Standards for l

issuance of a renewed license," to support ca application for license renewal if BGE applied in the future. By letter dated April 8,1998, BGE formally submitted its license renewal application.

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The staff has reviewed report 5.12 against the requirements of 10 CFR 54.21(a)(1) and i

10 CFR 54.21(a)(3). By letter dated April 4,1996, the staff approved BGE's methodology for meeting the requirements of 10 CFR 54.21(a)(2). Based on a review of the information submitted, the staff has identified in the enclosure, areas where additional information is i

needed to complete its review.

i Please provide a schedule by letter or telephonically for the submittal of your responses within 30 days c f 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 l

additional information.

Sincerely, l

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l David L. Solorio, Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

Request for Additional Information cc w/ encl: See next page g {)

DISTRIBUTION l

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  • see previous concurrence DOCUMENT NAME-GTWORKING\\SOLORIO\\MS RAILTR

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OFFICE LA:PDI-1 PDLR/DRPM PQDRff0I:ASC PDLR/DRPM:D NAME Slittle DSolorio BPratk CGrime( Q DATE 8/31 /98*

8/31 /98*

/ 8/ /91 861/98 OFFICIAL RECORD COPY 9909170272 990831 P

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Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant I'

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 l

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 Trowbridge 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 l 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 i

475 Allendale Road Baltimore Gas and Electric Company King of Prussia, PA 19406 Calvert Cliffs Nuclear Power Plant i

1650 Calvert Cliffs Parkway NEF ist Floor Lusby, Maryland 20657 i

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Distribution:

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PDLR R/F MEl-Zettawy l

DISTRIBUTION: E-MAIL:

l FMiraglia (FJM) i l

- JRoe (JWR)

DMatthews (DBM) l CGrimes (CIG)

TEssig (THE)

GLainas (GCL)

JStrosnider (JRS2)

GHolahan (GMH)

SNewberry (SFN)

GBagchi(GXB1)

RRothman (RLR)

JBrammer (HLB)

CGratton (CXG1)

JMoore (JEM)

I 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) l DSolorio (DLS2)

PDLR Staff TMarsh/GHubbard (LBM/GTH) l WLefave (WTL1) l GGeorgiev (GBG)

TSullivan (EJS)

KParczewski(KIP)

RWessman (RHW)

Yeuh-Li Li(YCL)

SLittle (SSL)

REQUEST FOR ADDITIONAL INFORMATION CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS.1 & 2 MAIN STEAM. STEAM GENERATOR BLOWDOWN. EXTRACTION STEAM. AND NITROGEN AND HYDROGEN SYSTEMS INTEGRATED PLANT ASSESSMENT. SECTION 5.12 DOCKET NOS. 50-317 AND 50-318 Section 5.12.1 Scoolna 1.

In Section 5.12.1 (bottom of Page 5.12-1) you identify that the Erosion Corrosion Program is credited for the mitigation of several components within the scope of license renewal. It is not clear what the term " mitigation of several components" is intended to imply. Please clarify this statement and explain its relationship to license renewal.

2.

In Section 5.12.1 you also state that there have been problems with system drains associated with portions of the system not within the scope of license renewal (WSLR).

It is not clear whether the system referred to is the extraction steam system, main steam system, steam generator blowdown system, or all three of these steam systems.

Please clarify this statement.

3.

The portions of the steam generator blowdown system (SGBS) that are inside containment are included (see Section 5.12.1) in the scope of Section 5.12. However, according to Section 5.12.1.1 the SGBS is apparently not included in the Section 5.12, nor does it appear to be included in any of the other referenced reports listed in Section 5.12.4. Please identify which section of the license renewal application (LRA) discusses scoping and aging management for the SGBS or provide the basis for its exclusion.

4.

Section 5.12.1.1 describes the functional requirements of the main steam, extraction steam, and nitrogen and hydrogen systems, but does not provide similar information for the SGBS. Please describe the functional requirements of the SGBS. Also identify if there is a containment isolation function associated with the SGBS and indicate whether it is or should be included in this section of the License Renewal Application (LRA).

5.

' You have identified that the non-safety related portions of the main steam system that are WSLR for fire protection considerations are addressed in Section 5.10 of your application. The NRC staff would expect that the aging mechanisms and management programs would be the same for the non safety and safety-related portions of the rnain steam system. In light of this assumption, provide a summary discussion on why portions of the main steam system are addressed in multiple sections of the LRA. Also, identify the functional requirements and intended functions of the main steam system that are within the scope of license renewal for fire protection considerations.

6.

On Page 5.12-4, you identify that the main steam lines from the steam generators to the main steam isolation valves (MSIVs) are WSLR. Please clarify this statement to indicate if the scope includes the MSIVs and if the scope extends to the first restraint downstream of each MSIV. If it does not extend to the first restraint downstream of the l

Enclosure

t MSIV provide appropriate justification for the exclusion of this portion of the system (and its restraint).

7.

You have identified that the extraction steam system inside containment has been abandoned in place and that only the associated containment penetration is WSLR.

Assuming that the piping inside containment needs to be seismically supported for Seismic ll over I considerations, describe whether the supports for this piping are WSLR. Additionally, please provide similar discussions for any other abandoned equipment that may poteatially affect the performance of a safety-related function during a design basis event, and the extent to which that equipment was determined to be WSLR.

8.

Section 5.12.1.2 identifies the air supply piping to the auxiliary feedwater (AFW) stop control valves as being WSLR. Describe why other air-operated components in the i

systems included in Section 5.12 are not WSLR. Also, explain why potential and plausible aging mechanisms (Table 5.12-4) for portions of the compressed air system that are included in this report are not identified, or provide an appropriate reference to where these components are subjected to an aging management review.

Section 5.12.2 Aalna Manaaement 9.

Are there any parts of the systems structures or components described in Section 5.12 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 er aging management techniques are needed for the inaccessible areas, please provide a summary to address the following elements for the inaccessible areas:

(1) Preventive actions that will mitigate or prevent aging degradation; (2) Parameters monitored or inspected relative to degradation of specific structure and component intended functions; (3) Detection of aging effects before loss of structure and component intended functions; (4) Monitoring, trending, inspection, testing frequency, and sample size to ensure timely detection of aging effects and corrective actions; (5)

Acceptance criteria to ensure structure and component intended functions; and (6)

Operating experience that provides objective evidence to demonstrate that the effects of aging will be adequately managed.

10.

Table 5.12-4 shows that fatigue is not plausible for the main steam system. However, Table 2.1-1 in Section 2.1 shows that the main steam piping fatigue is one of the time-limited aging anplyses (TLAAs) that were determined to be subject to license renewal review. Additionally, in Section 2.1.3.4, a discussion is provided to demonstrate that the main steam piping fatigue analyses meet the criteria of 10 CFR 54.21 (c)(1)(l), such that the 7000 assumed thermal cycles will not be exceeded during the period of extended operation. Provide the basis for concluding fatigue is not a plausible age related l

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3 degradation mechanism in light of the above information. Please also discuss if there is an inconsistency between Tables 5.12-4 and 2.1-1 as a result of above information.

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