ML20195E391
| ML20195E391 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/13/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-98-04, GL-98-4, NUDOCS 9811180328 | |
| Download: ML20195E391 (5) | |
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CHA2LE: H.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 13,1998 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 Generic Letter 98-04," Potential for Degradation of the Emergency Core Cooling System and the Containment Spray System After a Loss-of-Coolant Accident Because of Deficiencies and Foreign Material in Containment" j
Generic Letter 98-04 expressed a concern about degradation of containment coatings and the resultant effect on the performance of the Emergency Core Cooling System. The Nuclear Regulatory Commission (NRC) has stated several times in public meetings that the purpose of Generic Letter 98-04 is to gather information about how the industry manages coatings in containment. Therefore, the information contained in this letter represents the current state of the Calvert Cliffs Nuclear Power Plant (CCNPP) coatings program and is not a commitment for future action.
I Reautred Information
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j Paragraoh (1)
A summary description of the j>iant-specific program or programs implemented to ensure Level 1 protective coatin;. used inside the containment are procured, applied, and maintained in compliance with applicable regulatory requirements and the plant-specific licensing basis for the facility. Include a discussion of how the plant-specific program meets the applicable criteria of 10 CFR Pcart 50, Appendix B, as well as information regarding any applicable standards, plant-specific procedures, or other guidarce usedfor: (a) controlling the procurement ofcoatings andpaints used at thefacility, (b) the qualification testing ofprotective coatings, and (c) surface preparation, application, surveillance, and maintenance activities for protective coatings.
Maintenance activities involve reworking degraded coatings, removing degraded coatings to sound coatings, correctly preparing the surfaces, applying new coatings, and verifying the quality ofthe coatings.
9811180328 981113 O
PDR ADOCK 05000317E P
PDR{
Document Control Desk Novembcr 13,1998 Page 2 BGE Response Baltimore Gas and Electric Company (BGE) has implemented controls for the procurement, application, and maintenance of Service Level 1 protective coatings used inside the Containment. As used in this response, Service Level I coatings are those coatings used in Containment that are procured, applied, and maintained by BGE or our contractor (s). These controls are consistent with the licensing basis and regulatory requirements applicable to CCNPP. The requirements of 10 CFR Part 50, Appendix B, are implemented through specification of technical and quality requirements for the Service Level I coatings program, including ongoing maintenance activities.
For CCNPP, Service Level I coatings are subject to the requirements of Regulatory Guide 1.54, dated June 1973, and American National Standards. Institute (ANSI) N101.4-1972. Regulatory Guide 1.54 1
and ANSI N101.4-1972 are invoked by CCNPP's Quality Assurance Policy. Use of controlled procedures and processes provides adequate assurance that the quality of the coatings program will be maintained.
Service Level I coatings used for new applications or repair / replacement activities are procured from a vendor (s) with a quality assurance program meeting the applicable requirements of 10 CFR Pan 50, Appendix B. The technical and quality requirements that the vendor is required to meet are specified by BGE in procurement documents. Acceptance activities are conducted in accordance with procedures that are consistent with ANSI N45.2 requirements (e.g., receipt inspection, source surveillance, etc.).
This specification of required technical and quality requirements, combined with acceptance activities, provides adequate assurance that the coatings received meet the requirements of the procurement documents.
In addition to 10 CFR Part 50, Appendix B, and ANSI N45.2, qualification testing of Service e
Level I coatings used for new applications or repair / replacement activities inside Containment also meets the applicable requirements of ANSI N101.2-1972 and ANSI N5.9-1967 or ANSI N5.12-1974.
The surface preparation, application, and surveillance during matallation of Service Level I coatings used for new applications or repair / replacement activities inside Containment meet the c
applicable portions of the standards and regulatory commitments referenced in this response.
Containment coating activities and documentation of those activities are performed in accordance with plant procedures. Where the requirements of standards and regulatory commitments do not address or were not applicable to coating repair / replacement activities, these activities are performed in a manner consistent with the generally accepted industry practices for coatings repair / replacement. These practices are typically described in various American Society for Testing and Materials standards and coating practice guidelines by industry organizations issued subsequent to those to which BGE has a regulatory commitment.
Baltimore Gas and Electric Company recognizes that the NRC has not formally endorsed ANSI N101.2-1972, ANSI N5.12-1974, or many of the more recent American Society for Testing and Materials standards or industry guidelines; but nonetheless, they provide useful information that can be appropriately applied to provide assurance that repair / replacement activities on Service Level I coatings are effective in maintaining the acceptability of the coatings.
Baltimore Gas and Electric Company conducts condition assessments of Service Level I coatings inside the Containment when a unit is being refueled. Generally, all of the accessible areas within the
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i Document Control Desk -
November 13,1998 '
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Containment are visually inspected. As localized areas of degraded coatings are identified, those l
- areas are evaluated and scheduled for repair or replacement, as necessary. The periodic condition assessments, and the resulting repair / replacement activities, assure that the amount of Service Level I coatings that may be susceptible to detachment from the substrate during a loss-of-coolant accident l
(LOCA) event is minimized.
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Required Information Eatagraph.(2)(ii)
Forplants without the above licensing-basis requirements, information shall be provided to demonstrate l
compliance with the requirements of 10CFR50.46b(S), "Long-term cooling" and the functional
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capability of the safety-related CSS [ Containment Spray System} as setforth in your licensing basis. Ifa licensee can demonstrate this compliance without quantifying the amount of unquahfied coatings, this is l
acceptable.
L BGE Response Following a LOCA, the Containment Spray (CS) System sprays borated water from the refueling l
-water tank through the containment atmosphere to reduce the temperature and pressure of the l
containment atmosphere. The high pressure and low pressure safety injection pumps, which are part i
of the Safety Injection System, cool the reactor core by injecting water initially taken from the L
refueling water tank. When the refueling water tank has been depleted, CS and core cooling water are l
taken from the containment sump through the recirculation lines. In the recirculation mode, heat is transferred from the recirculating water to the Component Cooling System, the Saltwater System and, ultimately, the Chesapeake Bay.
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Both suction lines from the containment sumps are completely enclosed by a welded steel grating l
. screen box, which prevents debris from getting into the recirculation system.
1 Supporting steel beams are on approximately 3'-0" centers.
There is a welded steel grating with bearing bars spaced 1-3/16" on centers, crossbar spaced 4" on 2
- centers and a bar size of 1-1/4" x 3/16". ' The load-carrying capacity is 716 lbs/ft. The open area
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of the steel grating strainer box, including the supporting steel beams; is approximately 70%.
Square mesh steel wire cloth is tack-welded to the inside of the strainer box. Meshes per linear l
e ll inch: 2-3/4. Wire diameter: 0.120". Width opening: 0.244". Percentage of open area: 45%.
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e A fourth construction element exists on the Unit 2 screen box. There is a debris cover fabricated from removable stainless steel sections bolted to supporting stainless steel angle columns, which are, in turn, bolted to the top of the supporting steel beams of the grating screen box. The minimum clearance between the debris cover and the top of the sump grating box is approximately 7 inches.
The design of the screen box constitutes a strong construction and will withstand severe shock and loading.
Due to the extremely low flow velocity through the strainer box, the pressure drop resulting from a partial blockage will be negligible.
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Docum:nt Control Desk November 13,1998 i
Page 4 Thus, the requirement for long-term cooling [10 CFR 50.46b(5)] are satisfied in terms of ensuring water supply to the suction of the long-term cooling pumps.
Required Inlurmation Paragranh (2ViiYa)
Ifcommercial-grade coatings are being used at yourfacilityfor Service Level 1 applications, and such coatings are not dedicated or controlled underyour Appendix B Quality Assurance Program, provide the regulatory and safety basis for not controlling these coatings in accordance with such a program.
Additionally, explain why thefacility's licensing basis does not require such aprogram.
BGE Response Baltimore Gas and Electric does not currently use commercial grade dedication for Service Level I coating applications inside Containment at Calvert Cliffs.
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Docum:nt Control Desk November 13,1998 Page5 Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, l
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STATE OF MARYLAND
- TO WIT:
l 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 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.
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7 Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of Calved
,this /3 dayof flouember
,1998.
l WITNESS my Hand and Notarial Seal:
Notary Public
! (MOM My Commission Expires:
4Au I6te CHC/EMT/ dim l
l cc:
R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NR.C S. S. Bajwa, NRC R. I. McLean, DNR A. W. Dromerick, NRC J. H. Walter, PSC l
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