ML20195C771

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Forwards Responses to NRC 980827 RAI for Review of CCNPP Units 1 & 2 Integrated Plant Assessment Rept for CCS
ML20195C771
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 11/12/1998
From: Cruse C
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9811170215
Download: ML20195C771 (5)


Text

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Cuctos II. C:USE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby. Maryland 20657 410 495-4455 I

November 12,1998 U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION:

Document Control Desk

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 Report for the comoonent cooling system

REFERENCES:

(a)

Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated July 30,1997, " Request for Review and Approval of Systein Reports for License Renewal" (b)

Letter from Mr. D. L. Solorio (NRC) to Mr. C. II. 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 for the Component Cooling System" (c)

Letter from Mr. D. L. Solorio (NRC) to Mr. C.11. 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 two Baltimore Gas and Electric Company (BGE) system reports for license renewal. Reference (b) forwarded questions from NRC staff on one of those two reports, the Integrated Plant Assessment Report for the Component Cooling System. Reference (c) forwarded a nurnbering 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).

1no,co 9811170215 981112 PDR ADOCK 05000317' P

PDR<

NRC Distribution Code A036D

Document Control Desk November 12,1998 Page 2 Should you have further questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, 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 am duly authorized to execute and file this J

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 to be reliable, f

of -

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Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of (Allhti)

.this /NU4ay of 71F1XMil@tA998.

WITNESS my Hand and Notarial Seal:

[#llM) b 2 4tli Notary Public My Commission Expires:

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M Date CHC/KRE/ dim

Attachment:

(1) Response to Request for Additional Information; Integrated Plant Assessment Report for the Component Cooling System cc:

R. S, Fleishman, Esquire C. I. Grimes, NRC J. E. Silberg, Esquire D. L. Solorio, NRC S.' S, Bajwa, NRC Resident Inspector, NP.C A. W. Dromerick, NRC R. I. McLean, DNR 1

H. J. Miller, NRC J. H. Walter, PSC

.-. ~

ATTACHMENT (1) 1 i

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR TIIE COMPONENT COOLING SYSTEM l

t Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 12,1998

A'ITACHMENT (1) e

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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT, COMPONENT COOLING SYSTEM NRC Ougation No. 5.3.4 The potential age related degradation mechanisms of the Component Cooling System (CCS) have been identified in Table 5.3 3 of Section 5.3 of the [ Baltimore Gas and Electric Company (BGE)] License Renewal Application. Tire components of the CCS were judged not to be susceptible to low cycle fatigue or corrosion fatigue. Describe the justification and any specific criteria used to make the determination for the piping, check valves, control valves and pump / driver assemblies of the CCS.

BGE Respanac Baltimore Gas and Electric Company has determined that the service loading amplitudes and frequencies in the CCS do not cause these fatigue mechanisms for CCS piping, check valves, control valves, and pump casings.

The CCS maintains a relatively steady service temperature of approxirnately 95*F - 110*F and pressure of 80 psig, thus lacking the temperature and pressure cycles that would make these fatigue mechanisms plausible.

NRC Ouestion No. 5.3.5 Carbon steel piping bends, elbows and nozzles are vulnerable to erosion corrosion which has been identified as an age related degradation mechanism for the CCS piping. General wall thinning is anticipated as a result of erosion corrosion. Describe the specific evaluations which have been performed (or will be performed) to ensure structural integrity of the piping due to the effects of cyclic fatigue at locations where wall thinning may occur during the extended period of operation.

BGE Response Baltimore Gas and Electric Company expects erosion corrosion to be minimal, but plausible for the CCS. The normal CCS operating temperature of approximately 95*F - 110 F is below that generally anticipated for erosion corrosion. The Age-Related Degradation Inspection Program will be utilized to examine representative piping and discover any potential erosion corrosion that may occur.

Inspections will be performed, and appropriate corrective action will be taken if erosion corrosion is discovered. Fatigue was not considered a plausible aging mechanism for the CCS. See the response to Question No. 5.3.4, above, for the discussion of fatigue.

NRC Ouestion No. 5.3.6 The rate of corrosion of components in the CCS can be mitigated by proper control of water chemistry.

Please provide specifications for water chemistry in the CCS. Your answer should include target values for individual parameters and their monitoring frequency.

BGE Responic As stated in Section 5.3.2 (Group 1 - page 5.3-14) of the BGE License Renewal Application, Calvert Cliffs Technical Procedure CP-206, " Specifications and Surveillance Component Cooling / Service Water System," describes the surveillance and specifications for monitoring the CCS fluid.

Procedure CP-206 lists the parameters to monitor, the frequency of monitoring these parameters, and the Target and Action L.evels for the CCS finid parameters. The chemistry parameters are currently I

monitored on a frequency ranging from three times per week to once a month. Details of CP-206 are available onsite for review.

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ATTACHMENT (1)

ML3FONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT, COMPONENT COOLING SYSTEM NRC Ouestion No. 5.3J In a 1996 summary report referenced in Section 5.3.2, several incidents which occurred at Calvert Cliffs that resulted in water chemistry parameters exceeding their action levels were mentioned. Baltimore Gas and Electric Company took actions to correct these conditions. Describe these actions, and the experience gained from implementation of these actions with respect to maintaining water chemistry parameters below action levels.

BGE Resporug Baltimore Gas and Electric Company took actions to minimize CCS chemistry excursions. In particular, BGE determined that the majority of CCS chemistry anomalies were due to major system changes during refueling outages. To alleviate these chemistry anomalies, BGE now considers those outage evolutions that can affect the CCS chemistry and takes actions to prevent chemistry targets from being exceeded. Since 1996, BGE has effectively incorporated outage information to minimize the reoccurrence of these chemical excursions. Before an outage begins, Calvert Cliffs Chemistry personnel take a proactive role by working with Maintenance and System Engineers to determine which portions of the CCS will be out-of-service and drained. The chemistry is then adjusted within the acceptable band to prevent exceeding action levels during a system perturbation. As a result of these actions, only four CCS water chemistry action levels were exceeded during the 1997 Unit 2 refueling outage, and only one CCS water chemistry parameter exceeded its action levels during the 1998 Unit I refueling outage.

Action levels on the CCS chemistry are conservatively set to prevent long-term degradation / corrosion of system components. Baltimore Gas and Electric Company takes immediate action to return chemistry parameters to normal values to minimize the time that chemistry parameters are in action level conditions.

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