ML20151X966

Forwards Request for Addl Info for Review of Units 1 & 2, Integrated Plant Assessment Rept for EDG Sys

ML20151X966
Person / Time
Site:	Calvert Cliffs
Issue date:	08/27/1998
From:	Dave Solorio NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
TAC-M99218, TAC-MA1036, TAC-MA1037, NUDOCS 9809180039
Download: ML20151X966 (5)

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- Mr. Ch rl;s H. Crusa, Vice Prssid:nt 9"* *

~, Nucint En2rgy Division Baltimore Gas and 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, UNIT NOS.1 & 2, INTEGRATED PLANT ASSESSMENT REPORT FOR THE EMERGENCY DIESEL GENERATOR SYSTEM (TAC NOS. MA1036, MA1037, AND M99218)

Dear Mr. Cruse:

By letter dated January 21,1998, Baltimore Gas and Electric Company (BGE) submitted for review the Emergency Diesel Generator System (5.8) 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 the Emergency Diesel Generator System (5.8) integrated plant assessment technical report to determine if the report meets 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 Emergency Diesel Generator System (5.8) integrated plant assessment technical report against the requirements of 10 CFR 54.21(a)(1),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 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 staff would be willing to meet with BGE prior to the submittal of the responses to provide clarifications of the staffs requests for additionalinformation.

Sincerely, @Slgud 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 50-318

Enclosure:

Request for Additional Information cc w/ encl: See next page I c

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

Baltimore Gas & Electric Company Unit Nos.1 and 2 cc: '

Mr. Joseph H. Walter, Chief Engineer President ' . .

Public Service Commission of Calvert County Board of Maryland Commissioners- Engineering Division- I 175 Main Street 6 St. Paul Centre i Prince Frederick, MD 20678 Baltimore, MD 21202-6806 James P. Bennett, Esquire Kristen A. Burger, Esquire Counsel Maryland People's Counsel i Baltimore Gas and Electric Company 6 St. Paul Centre

~ P.O. Box 1475 Suite 2102 i Baltimore, MD 21203 Baltimore, MD 21202-1631 1

Jay E. Silberg, Esquire Patricia T. Birn!s, Esquire Shaw, Pittman, Potts, and Trowbridge Co-Directer 2300 N Street, NW Maryland Safe Energy Coalition Washington, DC 20037 P.O. Box 33111 Baltimore, MD 21218 Mr. Thomas N. Prichett, Director <

NRM Mr. Loren F. Donatell Calvert Cliffs Nuclear Power Plant NRC Technical Training Center 1650 Calvert Cliffs Parkway 5700 Brainerd Road Lusby, MD 20657-4702 Chattanooga, TN 37411-4017  ;

' Resident inspector David Lewis -

U.S. Nuclear Regulatory Commission Shaw, Pittman, Potts, and Trowbridge -

P.O. Box 287 2300 N Street, NW St. Leonard, MD 20685 Washington, DC 20037 l Mr. Richard I. McLean Douglas J. Walters Nuclear Programs Nuclear Energy Institute Power Plant Research Program 1776 l Street, N.W.

Maryland Dept. of Natural Resources Suite 400  !

Tawes State Office Building, B3 Washington, DC 20006-3708 Annapolis, MD 21401 DJW@NEl.ORG  ;

.. Regional Administrator, Region I Barth W. Doroshuk U.S. Nuclear Regulatory Commission Baltimore Gas and Electric Company 475 Allendale Road Calvert Cliffs Nuclear Power Plant King of Prussia, PA 19406 1650 Calvert Cliffs Parkway .

I NEF ist Floor l

. Mr. Charles H. Cruse, Vice President Lusby, Maryland 20657 I Nuclear Energy Division Baltimore Gas and Electric Company .

1650 Calvert Cliffs Parkway l Lusby, MD 20657 4 7027 l l

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REQUEST FOR ADDITIONAL INFORMATION

.QALVERT CLIFFS NUCLEAR POWER PLANT UNIT NOS.1 & 2 EMERGENCY DIESEL GENERATOR SYSTEM INTEGRATED PLANT ASSESSMENT. SECTION 5.8 DOCKET NOS. 50-317 AND 50-318 Section 5.8.1 - Sconina

1. Figure 5-8.1 in Section 5.8.1.1 provides the system boundaries and interfaces for the starting air system and appears to indicate that the check valve upstream of the air receiver is not within the scope of license renewal. Please clarify the location of the i interface upstream of the air receiver and provide additional clarification as to which components on either side of the interface are within the scope of license renewal. If the l starting air system equipment upstream of the receiver check valve is included in a '

separate section of the license renewal application please provide a cross reference to I the applicable section.

2. If the check valve upstream of the air receiver, as discussed in the previous request for additional information, is not within the scope of license renewal, provide the basis for its exclusion and emphasize how the pressure boundary is maintained at the check valve interface with the air piping it is attached to.

Section 5.8.2 - Aalna Manaaement

3. Explain ger.erally how the degradation of tank bottoms is managed, particularly the aging  !

management for the bottom of the diesel fuel oil tanks.

4. Several plants with Fairbanks Morse (FM) emergency diesel generators (EDGs) have experienced problems with degradation of welds in the skid-mounted lube oil and Jacket water piping of EDGs during normal operation. Subsequent evaluation showed significant lack of penetration and general lack of quality in the welds, which was believed to have occurred during manufacturing. Since some portions of the piping are subject to vibration induced loads, the potential exists for fatigue failure of welds in the piping during the period of license renewal. Section 5.8.1.2.2 discusses that the skid-mounted piping is not subject to aging management review (AMR) in accordance with 10 CFR Part 54. Discuss the basis for excluding the welds in the Jacket cooling water piping bevond the skid from an AMR.

5. Describe the diesel exhaust system at the location where it exits the diesel building. At some facilities, structures surrounding the exhaust components have been damaged by l the exhaust gases. Debris from these damaged structures has the potential of blocking the diesel exhaust ducts. If the potential for this condition exists at Calvert Cliffs Nuclear Power Plant Units 1 and 2, provide a discussion of which aging management program is relied on for managing thic condition during the proposed extended period of operation.

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6. Provide information regarding parameters which will be inspected, monitored and trended for detection of aging effects due to corrosion and fatigue on the intemal and extemal surfaces of the EDG exhaust piping and mufflers. Also provide the acceptance criteria for these parameters.

7. Discuss the corrosion allowances in the design of EDG system components that are subject to corrosion, and how they will be addressed as part of the aging management program. l I

8. Page 5.8-1 of the report states that operating experience relevant to aging was obtained I based on Calvert Cliffs Nuclear Power Plant specific information and past experience.

l Describe the basis upon which Baltimore Gas and Electric Company concluded that 1 cavitation corrosion, intergranular attack, stress corrosion cracking, and thermal damage were not plausible aging effects for EDG systems in relation to any industry-wide  !

experience with these aging effects in EDG systems.

9.

Are there any parts of the systems, structures and components within the EDG 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 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.

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