ML20155H277

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Provides Response to RAI for Review of Calvert Cliffs Nuclear Power Plant,Units 1 & 2 Integrated Plant Assessment Re Water Chemistry Program
ML20155H277
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 11/04/1998
From: Cruse C
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9811100046
Download: ML20155H277 (5)


Text

4 CHACLES H. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495 4455 November 4,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

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SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment, Water Chemistry Program l

REFERENCES:

(a)

Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated April 8,1998," Application for License Renewal" (b)

Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE),

August 27,1998, " Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment on Water Chemistry Program" (c)

Letter from Mr. D. L. Solcrio (NRC) to Mr. C. H. Cruse (BGE),

September 24,1998, " Renumbering of NRC Requests for Additional Information on Calvert Cliffs Nuclear Power Plant License Renewal Application Submitted by the Baltimore Gas and Electric Company"

' Reference (a) forwarded the Baltimore Gas and Electric Company (BGE) license renewal application.

Reference (b) forwarded questions from NRC staff on certain sections of the BGE License Renewal Application, on the subject of water chemistry. Reference (c) forwarded a numbering system for tracking BGE's response to all of the BGE License Renewal Application requests for additional information and the resolution of the responses. Attachment (1) provides our responses to the questions contained in Reference (b). The questions are renumbered in accordance with Reference (c).

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I 9811100046 981104 1 PDR ADOCK 05000317 l

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l NRC Distribution Code A036D

  • Docum:nt Control Desk November 4,1998 Page 2 Should you have further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

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M STATE OF MARYLAND

TO WIT:

COUNTY OF CALVERT I, Charles H. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I ana duly authorized to execute and file this response on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it be reliable.

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Subscri a d sworn before me, a Notary Public in nd for the State of Maryland and County of

,this V day of

.1998.

WITNESS myIIand and Notarial Seal:

Notary Pubhc My Commission Expires:

!. SOOM Q Tate '

CllC/KRE/ dim

Attachment:

(1) Response to Request for Additional Information; Integrated Plant Assessment, Water Chemistry Program cc:

R. S. Fleishman, Esquire C. I. Grimes, NRC l

J. E. Silberg, Esquire D. L. Solorio, NRC l

S. S. Bajwa, NRC Resident Inspector, NRC A. W. Dromerick, NRC R. I. McLean, DNR H. J. Miller, NRC J. H. Walter, PSC i

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1 ATTACHMENT (1) i 1

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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT, WATER CHEMISTRY PROGRAM i

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i Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 4,1998

ATTACHMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT, WATER CIIEMISTRY PROGRAM NRC Ouestion No. 9.1 Control of the secondary water chemistry plays an important role in ensuring that steam generators and other components exposed to secondary water will not be damaged by corrosion and will preserve their integrity. Please include the following information on your secondary water chemistry control program:

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(a) What amine is being used for controlling pH in the secondary water system?

(b) Specify major differences in the secondary water chemistry (feedwater and/or steam generator) for power operation, startup, and shutdown.

(c) Describe and provide technical bases for any significant differences in secondary water chemistry parameters specified in the Calvert Cliffs Nuclear Power Plant Technical Procedure CP-217,

" Specifications and Surveillance - Secondary Chemistry," and the values recommended by the Electric Power Research Institute (EPRI) in their guideline reports, referenced in Section 5.12,

" Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems," of Appendix A to the Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA).

(d) Specify the upper limits of the major chemistry parameters and the allowable time period to restore chemistry parameters to acceptable limits.

BGE Respenas Baltimore Gas and Electric Company has requested clarification from NRC on this item and has agreed to work toward clarification through forthcoming interaction, most likely in the form of a public meeting. Baltimore Gas and Electric Company may supplement this response, based on the outcome of that interaction.

NRC Ouestion No. 9.2 Were there any significant secondary water chemistry excursions in the past? If such excursions have occurred, describe any significant impact on the condition of the plant, such as increased potential for corrosion damage of the components in the secondary water system.

BGE Response Secondary water chemistry excursions of varying extent have occurred over the operating history of Calvert Cliffs. The excursions introduced bay water, well water, or resin beads into the condensate system. No significant impact on the condition of the plant has been documented. Extensive experience (inspections and testing) shows that degradation caused by excursions is slow as compared to the inspection interval.

Calvert Cliffs Chemistry programs have incorporated the EPRI Pressurized Water Reactor Secondary Chemistry Guidelines since they were introduced. The Guidelines incorporate industry experience and provide direction to optimize plant-specific chemistry parameters.

NRC Ouestion No. 9.3 The scope of Calvert Cliffs Technical Procedure CP-204, " Specification and Surveillance Primary Systems," includes the Reactor Coolant System (RCS) and the Chemical and Volume Control System (CVCS). These systems perform different functions and consequently have different Chemistry procedures. Please describe how CP-204 is applied to the RCS and CVCS.

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e ATTACHMENT (1) 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT, WATER CHEMISTRY PROGRAM BGE Response

- Calvert Cliffs Technical Procedure CP-204 is used to control not only the chemistry of the RCS, but also for those systems that interface with the RCS. The scope of CP-204 includes the following systems / components:

Reactor Coolant (Modes 1 through 6);-

e Spent Fuel Pool (Modes I through 6);

e-e: Refueling Water Storage Tank (Modes 1 through 6);

Refueling Pool (Mode 6);

e I-Safety injection Tanks (Modes I through 6);

e High Pressure Safety Injection Pump Discharge (Modes 1 through 6);

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e Boric Acid Storage Tank (Modes I through 6);

Reactor Coolant Waste Receiver Tank (Modes 1 through 6);

e Reactor Coolant Waste Evaporator Bottoms (Modes I through 6);

Boric Acid Batching Tank (Modes I through 6);

e CVCS Ion Exchangers (Modes 1 through 6); and e

Spent Fuel Pool Ion Exchangers (Modes I through 6).

e In the case of Section 5.2, " Chemical and Volume Control System," CP-204 is credited with minimizing the effects of crevice corrosion and pitting that occur due to fluid stagnation for components listed in Section 5.2, Group 2 of the BGE LRA. Maintaining system chemistry conditions to minimize impurities will limit the rate and effects of degradation due to these age-related degradation mechanisms. For Section 4.1," Reactor Coolant System," CP-204 is credited in Group 6 with mitigating the effects of intergranular attack on the reactor coolant pump seal water heat exchanger (RCS side) by monitoring and maintaining the RCS chemistry. The procedure is also credited in Section 4.1, Group 7 for minimizing the effects of stress corrosion cracking /intergranular e

stress corrosion cracking on the RCS piping (device code -CC, except the reactor pressure vessel head seal leakage detection line).

i NRC Ouestion No. 9.4 The two factors important to minimize corrosion of the primary coolant system components are pH and lithium hydroxide. Describe the pH level and lithium concentrations during a fuel cycle, or describe the procedure for their control.

BGE Reaganac Calvert Cliffs Procedure CP-204 is credited with controlling water chemistry to: minimize impurity ingress to plant systems; reduce corrosion product generation, transport, and deposition; reduce collective radiation exposure through chemistry; improve integrity and availability of plant systems; and extend component and plant life. Calvert Cliffs Procedure CP-204 lists the parameters to monitor

_ (e.g., lithium, chloride, fluoride, sulfate, oxygen, pH), the frequency of monitoring these parameters, and the acceptable value or range of values for each parameter. Calvert Cliffs Procedure CP-204 is described in Section 4.1, Groups 6 (intergranular attack) and 7 (stress corrosion cracking), of the BGE

'LRA.

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