ML20195C782

Forwards Responses to NRC 980828 RAI for Review of CCNPP, Units 1 & 2 Integrated Plant Assessment Rept for Generic Areas

ML20195C782
Person / Time
Site:	Calvert Cliffs
Issue date:	11/12/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9811170217
Download: ML20195C782 (13)

Text

CHC1.Es 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 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, Generic Areas

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 28,1998," Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Report" (c)

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

September 24,1998, "Re tumbering 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 (LRA). -Reference (b) forwarded questions from NRC staff on generic areas of the BGE LRA.

Reference (c) forwarded a numbering system for tracking BGE's response to all of the BGE LRA 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).

1?QP(10 9811170217 981112

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PDR ADOCK 05000317 PDR p

NRC Distribution Code A036D

o Docunisnt 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 1, 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 i

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 reliable.

/

/

Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of fAllAAt/

.this /2didayof 71stxath/4/,1998.

WITNESS my Hand and Notarial Seal:

AdlA L 11HIM Notary Public My Commission Expires:

b!l 2 (1T) A Date CHC/KRE/dlm

Attachment:

(1) Response to Request for Additional Information; Integrated Plant Assessment, Generic Areas cc:

R. S. Fleishman, Esquire C. I. Grimes, NRC J. E. Silberg, Esquire D. L. Solorio, NRC S. S. Bajwa, NRC Resident Inspector, NRC A. W. Dromerick, NRC R. I. McLean, DNR H. J. Miller, NRC J. H. Walter, PSC

ATTACHMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT, GENERIC AREAS I

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

ATTACHMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS NRC Ouestion No.11.1 l

The Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA) contains aging management review (AMR) of valve internals, such as disk, seat, and pivot rod.

However, 10 CFR 54.21(a)(1)(I) excludes valves, other than the valve body, from the AMR requirements. The statements of consideration (SOC) of the license renewal rule provides the basis for excluding structures and components that perform their intended functions with moving parts or with a change in con 0guration or properties from an AMR for license renewal. It states: "On the basis of consideration of the effectiveness of existing programs which monitor the perfor. nance and condition of systems, structures, and components that perform active functions, the Commission concludes that structures and components associated only with active functions can be generically excluded from a license renewal AMR. Functional degradation resulting from the effects of aging on active functions is more readily l

determinable, and existing programs and requirements are expected to directly detect the effects of j

aging." (60 FR 22471) The SOC contains an example of the valve internals. It states: "The l

Commission has determined that passive structures and components for which aging degradation is not i

readily monitored are those that perform an intended function without moving parts or without a change in configuration or properties. For example, a... valve has moving parts,... Therefore, the performance or condition of these components is readily monitored and would not be captured by this description." (60 FR 22477) Further, in response to a public comment regarding rarely operated valves, the SOC states: "The Commission disagrees with the commenter's assertion that there is insufficient evidence that the active functions will be maintained in the renewal period. Such valves are within the scope of various regulatory programs, including the maintenance rule. Consequently, the ability of the j

valves to perform their intended function must be assured through either (1) effective preventive

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maintenance or (2) performance or condition monitoring." (60 FR 22472) In addition, the industry guideline developed by the Nuclear Energy Institute in NEl-95-10, Revision 0, " Industry Guideline for implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," which the staff has proposed to endorse in a draft regulatory guide, indicates that only valve bodies are subject to an AMR for license renewal.

Please provide the basis of BGE's determination that valve internals are subject to an AMR for license renewal.

BGE Response Baltimore Gas and Electric Company is aware that 10 CFR 54.21(a)(1)(i) excludes valves, other than the valve body, from the AMR requirements. Baltimore Gas and Electric Company performed an AMR on valve internals in two circumstances - valves that are credited for containment isolation and valves at the boundaries between safety-related portions of systems and non-safety-related portions of systems.

Baltimore Gas and Electric Company performed this AMR, which is beyond the 10 CFR 54.21(a)(1)(i) requirements, for our benefit, and did it during the system AMR process for efficiency's sake.

NRC Ouestion No.11.2 The BGE application contains a statement to indicate that component replacements are not subject to an AMR for license renewal. By letter dated February 19,1998 (Reference 1), the staff issued a request for additional information (RAI) on the Diesel Fuel Oil System described in the application. In Question 6 of the RAI, the staff requested information regarding component replacements in the Diesel Fuel Oil System. Your July 30,1998 (Reference 2), response indicates that the BGE statement is meant to be generic and accounts for a future hypothetical scenario. No components were excluded from an AMR 1

6 ATTACIIMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS based on the hypothetical scenario. Because this statement appears throughout the BGE application, please verify that your response to Question 6 of the Diesel Fuel Oil System RAI is applicable to the entire BGE application.

BGE Responac i

The response to Diesel Fuel Oil System RAI Question 6 provided in Reference (2):

The statements addressed in the question were meant to be generic and account for a future hypothetical scenario where BGE may elect to replace a component based on time or qualified life, hence removing it from the population of components requiring AMR. No components were excluded from AMR based on the hypothetical scenario above. Any components specifically excluded from AMR based on a time or qualified life replacement schedule are clearly identified in the LRA.

This statement is applicable to the entire BGE LRA.

NRC Ouestion No.11.3 The BGE application relies, in part, on age-related degradation inspection (ARDI) programs to manage the effects of aging for license renewal. The application also relies, in part, on new programs to manage the effects of aging for license renewal. Please discuss the differences between ARDI and new programs.

BGE Response The ARDI is a new program. It is one of several new programs, all of which are listed in the response to Question No. I1.5 below.

NRC Ouestion No.11.4 The BGE application relies, in part, on ARDI programs to manage the effects of aging for license renewal. For each of these ARDI programs, please provide a reference to the section of the application, supplemented as needed, that describes a summary that addresses the elements listed below. The summary should include a discussion of the bases for each of these elements. (1) Parameters to be monitored or inspected relative to degradation of specific structure and component (SC) intended functions; (2) Assurance that detection of aging effects will occur before loss of SC intended functions; (3) Program inspection, technique, inspection schedule, and sample size to ensure SC intended functions; (4) Acceptance criteria to ensure structures and components can perform their intended functions; and (S) Operating experience from similar programs or inspection techniques used by BGE or the industry.

Also discuss the schedule for implementation of each of these ARDI programs.

i BGE.Reanonse Please see the response to Question No. I1.5 for a reference to the BGE LRA sections that credit ARDI. Age-related degradation inspection will be discussed as separate programs for the following commodities: Cables, Electrical Commodities, Piping, Reactor Vessel Internals (RVI) and Supports.

Cables ARDI This ARDI is complete. Please see the response to NRC Question No. 6 in Reference (3).

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ATTACIIMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS Electrical Commodities ARDI For the Electrical Commodities, otherwise known as the panels, ARDI is applied to panels not subject to a routine " clean and inspect" procedure, but for which aging is considered plausible. Panels will be subjected to a one-time inspection for the effects of aging.

(l) Parameters to be monitored or inspected relative to degradation of specific SC intended functions The intended function of these panels / cabinets is to provide protection of the electrical continuity function. The following is a list of physical indications of aging for possible aging mechanisms that will be explicitly included in inspection guidance depending on which aging mechanisms are deemed plausible.

Plausible Wear (a) Binding of hinged or sliding parts (b) Excessive play in hinged parts (c) Loosening of bolted connections Plausible Dynamic Loading (a) Cracking of metal braces and fasteners Plausible Electrical Stress (a) Indications of terminal block overheating such as cracking, crazing, or locally discolored spots.

(b) Loose electrical terminations (c) Indications of insulation overheating such as cracking, crazing, or locally discolored spots.

(d) Indications of degradation of stand-cff insulators due to overheating such as cracking, crazing, or locally discolored spots.

Plausible Fatigue (a) Cracking of metal braces and fasteners Plausible Corrosion (a) Pitting (b) Loss ofmetal Please note that the actual wording to be included in inspection guidance is subject to plant review and approval. The above is provided to illustrate the visual cues associated with plausible aging mechanisms available to inspection personnel.

(2) Assurance ofdetection ofaging effects will occur before loss ofSC intendedfunctions i

The degradation due to the plausible aging mechanisms is expected to progress at a very low rate. This is consistent with indications over the life of the Calvert Cliffs Nuclear Power Plant. Any aging effects are expected to manifest themselves well before structural failure becomes imminent even under seismic loading.

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ATTACIIMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS 1

(3) Program inspection, technique, inspection schedule, and sample size to ensure SC intended functions All panels not subject to a routine clean and inspect procedure and that are subject to i

plausible aging will be subjected to a visual inspection prior to the period of extended operation to determine if there is any evidence of aging effects.

(4) Acceptance criteria to ensure structures and components can perform their intended 1

functions Any evidence of aging effects will be documented and subsequent corrective actions taken in accordance with BGE's Corrective Actions Program as described in the LRA.

(5) Operating experience from similar programs or inspection techniques used by BGE or the Industry A panel installed in an environment that promotes aging is subjected to a routine " clean and inspect" task to detect the effects of aging. A panel installed in an environment that does not promote aging would age at a very slow rate. System engineering walkdowns and an ARDI will detect the effects of aging prior to any loss of intended functions. Any significant abnormal indications would be documented and corrective action taken. Corrective action may include instituting a routine clean and inspect task.

ARDI Program Schedule l

Baltimore Gas and Electric Company currently estimates that this ARDI will be established by the end of the year 2000.

Piping ARDI l

Baltimore Gas and Electric Company provided the NRC with a presentation on the ARDI Program during a public meeting on June 25, 1998. The presentation provided a mapping of Program Requirements from Section 3.II.C of the Working Draft of the Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants to the elements of the piping ARDI Program as described in the BGE LRA. Information presented below, for elements (1) through (5),

corresponds to the information provided during the presentation relative to draft Standard Review Plan Program Requirements 3,4,5,6, and 10, respectively. Additionally, the presentation provided a schedule for ARDI Program development. This schedule is summarized below.

ARDI Program Elements (1) Parameters to be monitored or inspected relative to degradation ofspecific SC intended functions The ARDI Program will inspect for the presence and extent of aging effects on a system-by-system basis. For systems where the program is credited, sections of the LRA under the heading Aging Management Program (s) describe what components and age-related degradation mechanisms (ARDMs) the program will inspect. In accordance with Calvert Cliffs procedures, proven and accepted non-destructive examination techniques will be employed to carry out the ARDI. The sample size of SCs inspected will be chosen from a population of components that perform the intended function. In I

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l ATTACHMENT (1)

RESPONSC TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS this fashion, direct inspection or measurement of affected component or subcomponent parts that perform the intended function will be assured. Thus, the basis for choosing the parameters monitored or inspected is that they directly reDect the ability of the SC to perform its intended function.

j (2) Assurance that detection ofaging effects will occur before loss ofSC intendedfunctions The ARDI Program will provide reasonable assurance that aging effects will be detected before loss of SC intended functions will occur. For systems where the program is credited, sections of the LRA under the heading Aging Management Demonstration describe how this is accomplished. The ARDI will generally be carried out with the expectation that unacceptable degradation will not be discovered. This program provides the added measure of assurance needed for SCs that do not already have an existing degradation discovery program. If unacceptable degradation is discovered, the inspection sample size will be increased accordingly, and the site Corrective Actions Program will provide appropriate engineering analysis and long-term corrective actions. Thus, the ARDI Program itself provides the basis for reasonable assurance that detection of aging effects will occur before loss of intended functions.

(3) Program inspection, technique, inspection schedule, and sample si:e to ensure SC intendedfunctions in accordance with Calvert Cliffs procedures, proven and accepted non-destructive examination techniques will be employed to carry out the ARDI. If follow-up inspections are required, the specified schedule will take into account the rate of expected degradation. Sample sizes will be chosen to provide a 90% confidence that 90% of the population does not have the degradation mechanism present. Thus, these elements of the program provide the necessary reasonable assurance that is the basis for these choices.

(4) Acceptance criteria to ensure structures and components can perform their intended functions Acceptance criteria for the ARDI will be consistent with the design requirements of the SCs. Thus, verification that the design parameters ofinterest are within acceptable limits provides reasonable assurance that the SCs can perform their intended functions. The basis for choosing these acceptance criteria is that they reflect design requirements.

(S) Operating experiencefrom similar programs or inspection techniques used by BGE or the industry Standard industry methods will be used to carry out the ARDI. As stated previously, proven and accepted non-destructive examination techniques will be employed. Since this is the first program of its kind, operating experieace will be incorporated into the l

program as it is acquired and implemented. The basis for this element of the program is that there is no existing experience from similar programs.

i The BGE ARDI presentation to the NRC on June 25,1998, contained an example that illustrated the points described above.

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A'ITACIIMENT (1) i RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS ARDI Program Schedule Baltimore Gas and Electric Company has established an internal schedule to prepare an administrative procedure and a technical requirements document by December 31, 1998.

Together these documents will allow for consistent implementation of the ARDI Program.

RVI ARDI Age-related degradation inspection is credited for RVI only as a contingency in the event that analyses are not able to demonstrate that ARDMs would not effect the intended function of BGE LRA Section 4.3," Reactor VesselInternal," Group 5 and Group 6 components. This is summarized on page 4.3-31 of the LRA. A detailed discussion about the ARDI contingency to address stress relaxation of control element assembly shroud bolts and core shroud tie rods is contained on page 4.3-24 of the LRA. A detailed discussion about the ARDI contingency to address stress corrosion cracking of the control element assembly shroud bolts is contained on page 4.3 27 of the LRA.

The RVI ARDI is not yet developed and may not need to be developed pending the outcome of the analyses mentioned above. Baltimore Gas and Electric Company has provided additional information about the analyses in the responses to Questions 4.3.5 and 4.3.15 of the RVI requests for additional information.

Supports ARDI (l) Parameters to be monitored or inspected relative to degradation of specific SC intended functions The ARDI Program will determine if effects of aging are occurring on accessible supports with the same environment as those supports that are described on page 3.1-18 and 3.1-19 of the LRA. As noted on page 3.1-14 of the LRA, these effects would be due to corrosion, loading due to hydraulic vibration or water hammer, and loading due to thermal expansion.

(2) Assurance that detection ofaging effects will occur before loss ofSC intendedfunctions The ARDI Program will provide reasonable assurance that aging effects will be detected before loss of SC intended functions will occur. The ARDI will generally be carried out with the expectation that unacceptable degradation will not be discovered. This program provides the added measure of assurance needed for the inaccessible supports. If unacceptable degradation is discovered, the site Corrective Actions Program will provide appropriate engineering analysis and long-term corrective actions. Thus, the ARDI Program itself provides the basis for reasonable assurance that detection of aging effects will occur before loss ofintended functions.

(3) Program inspection, technique, inspection schedule, and sample size to ensure SC intended functions In accordance with Calvert Cliffs procedures, proven and accepted non-destructive examination techniques will be employed to carry out the ARDI.

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V ATTACHMENT (1)

. RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS (4) Acceptance criteria to ensure structures and components can perform their intended functions Acceptance criteria for the ARDI will be consistent with the design requirements of the supports. Thus, verification that the design parameters ofinterest are within acceptable limits provides reasonable assurance that the SCs can perform their intended functions. The basis for choosing these acceptance criteria is that they reflect design requirements.

(S) Operating experiencefrom similar programs or inspection techniques used by BGE or the industry Standard industry methods will be used to carry out the ARDI. As stated previously, proven and accepted non-destructive examination techniques will be employed. Since this is the first program of its kind, operating experience will be incorporated into the program as it is acquired and implemented. The basis for this element of the program is that there is no existing experience from similar programs.

ARDI Program Schedule Baltimore Gas and Electric Company currently plans to complete development of the program by mid-1999.

NRC Ouestion No.11. 5 The BGE application relies, in part, on new programs to manage the effects of aging for license renewal.

For each of these new programs, please provide a reference to the section of the application, supplemented as needed, that describes a summary that addresses the elements listed below. The summary should include a discussion of the bases for each of these elements. (1) Scope of program that includes the specific structures and components subject to an AMR; (2) Preventive actions that will be used to mitigate or prevent aging degradation; (3) Parameters to be monitored or inspected relative to degradation of specific SC intended functions; (4) Assurance that detection of aging effects will occur before loss of SC intended functions; (5) Program monitoring, trending, inspection, technique, testing frequency, and sample size to ensure SC intended functions; (6) Acceptance criteria to ensure structures and components can perform their intended functions; and (7) Operating experience from similar programs or inspection techniques used by BGE or the industry. Also discuss the schedule for implementation of each of these new programs.

For programs that are yet to be developed, please provide information on those elements that are available. For the remaining elements, please provide the detailed process, including the basis, that BGE will use to develop them and a schedule for when the program development will be completed.

BGE Resnonse The following table provides a reference to the applicable sections of the application for each new aging management program. The table also provides a reference to the groups in the section where the program is credited. The process and schedule for development and implementation of a new program depends on the particular program. This process is controlled under BGE's program for managing NRC commitments.

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ATTACIIMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS New Aging Management Program LRA Subject LRA Section LRA Group (s)

ARDI Component Supports 3.1 1

ARDI Cables 6.1 1, 2, 3, 6 ARDI Electrical Commodities 6.2 5,6,7 ARDI Auxiliary Feedwater 5.1 1,2,3,5,7 ARDI Compressed Air 5.4 2

l ARDI Component Cooling Water 5.3 1,2,3,5,6 ARDI Containment Isolation 5.5 1, 2, 3 ARDI Containment Spray 5.6 2

ARDI Charging and Volume Control 5.2 2,4,5,6 ARDI Emergency Diesel Generators 5.8 1,2,3,4,5, ARDI Fire Protection 5.10 see page 5.10-32 ARDI ilVAC - Auxiliary Building 5.1 I A 1, 2 ARDI HVAC - Containment 5.l lB 1, 2, 5 ARDI IIVAC Control Room and EDG 5.11C 1, 2 ARDI Instrument Lines 6.4 1, 2 ARDI Main Steam 5.12 1, 2, 3, 4 ARDI Main Feedwater 5.9 3

ARDI NSSS Sampling 5.13 1, 2, 5 ARDI Radiation Monitoring 5.14 1

ARDI RVis 4.3 5, 6 ARDI Spent Fuel Pool Cooling 5.18 1,2 ARDI Safety injection

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5.15 2,3,5 ARDI Service Water 5.17 1, 2, 3, 4 ARDI Saltwater 5.16 1, 2, 4, 6 Buried Pipe inspection Auxiliary Feedwater 5.1 4

Buried Pipe inspection Diesel Fuel Oil 5.7 2

Caulk and Sealant inspection Auxiliary Feedwater 5.1 9

Caulk and Sealant inspection Auxiliary Building 3.3E I

Caulk and Sealant inspection Diesel Fuel Oil 5.7 4

Caulk and Sealant Inspection intake Structure 3.3C 1

Caulk and Sealant inspection Turbine Building 3.3B 1

Fatigue Analyses Main Feedwater 5.9 2

Fatigue Analyses RVIs 4.3 3

Stress Corrosion Cracking Analysis RVis 4.3 6

Stress Relaxation Analysis RVis 4.3 5

Tank Internals inspection Diesel Fuel Oil 5.7 3

CASS Thermal Aging Reactor Coolant System 4.1 8

CASS Thermal Aging RVIs 4.3 4

Baseline Walkdown Component Supports 3.1 1, 2, 7 CASS - Cast Ausenitic Stainless Steel EDG

- Emergency Diesel Generator ilVAC - lleating, Ventilation,and Air Conditioning 8

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4 ATTACHMENT (1)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS l

i NRC Ouestion No.11. 6 Section 2.0, " Integrated Plant Assessment Methodology," of Appendix A to the BGE application indicates that the purpose of an ARDI is either to support a "non plausible" aging mechanism determination or to confirm that a mitigation program is effective. The ARDI is a one-time inspection which may be performed prior to or during the period of extended operation. The staff is requesting additional information to clarify the purpose of an ARDI program and when an ARDI is used as discussed below.

Section 5.16, " Saltwater System," of Appendix A to the application indicates that there is an ARDI program to manage the effects of corrosion of certain Saltwater System Group 1 components. These l

components are unlined piping, valves, etc., and BGE has determined that corrosion is " plausible."

Baltimore Gas and Electric Company also identified that there is no program to mitigate corrosion for these components. Then, BGE proposed to develop an ARDI program. Based upon operating experience, corrosion of Saltwater System components may be likely. Thus, the staff believes a periodic inspection program may be more appropriate than a one-time inspection at a future unspecified time. In addition, the selection of an ARDI for this case may not be consistent with the purpose of the ARDI.

Please clarify why an ARDI is appropriate for these Saltwater System components. There are other similar examples, such as managing stress relaxation and stress corrosion cracking of RVis (Section 4.3).

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Please provide criteria for determining when an ARDI versus a new program is selected for aging i

management for license renewal.

BGE Response The components in question are subject to " plausible" crevice corrosion, microbiologically-induced corrosion, and pitting (General corrosion is additionally plausible for bolting on some of these components, but this ARDM will manifest itself externally). The materials of construction include red brass,70-30 copper nickel, bronze, stainless steel, and monel.

These materials are resistant to most forms of corrosion and are generally expected to undergo no significant degradation in the brackish water environment. Baltimore Gas and Electric Company has conservatively determined these ARDMs to be plausible for these components. The ARDI is expected to verify this conclusion.

Age-related degradation inspection was typically selected as an aging management program in circumstances such as this.

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ATTACIIMENT (1) 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT, GENERIC AREAS References j

1.

Letter from Mr. D. L. Solorio (NRC) to Mr. C.11. Cruse (BGE), dated February 19,1998, Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Report for the Diesel Fuel Oil System (TAC Nos. M95457, M95458, M99180) 2.

Letter from Mr. C. ii. Cruse (BGE) to NRC Document Control Desk, dated July 30,1998,

" Responses to Requests for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Reports for the Feedwater System and Diesel Fuel Oil System" 3.

Letter from Mr.

C.

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Cruse (BGE) to NRC Document Control Desk, dated September 17,1998, " Response to Request for Additional Information for the Review of the Calvent Cliffs Nuclear Power Plant, Units 1 & 2, Commodity Report for Cables" 4

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