ML20195E658
| ML20195E658 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/16/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9811190059 | |
| Download: ML20195E658 (9) | |
Text
s Cauu.cs II. C USE Baltimore Gas and Electric Company Vice President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 November 16,1998 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 Assessmt:nt Report for the Service Water System. and Errata
REFERENCES:
(a)
Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated August 21,1997, " Request for Review and Approval of System and Commodity Reports for License Renewal" (b)
Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE),
September 3,1998, " Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Unit Nos.1 & 2, Integrated Plant Assessment Report for the Service Water System" (c)
Letter from Mr. D. L. Solorio (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" i
Reference (a) forwarded three Baltimore Gas and Electric Company (BGE) system and commodity reports for license renewal. Reference (b) forwarded questions from NRC staff on one of those three j
reports, the Integrated Plant Assessment Report on the Service Water System. Reference (c) forwarded a numbering system for tracking BGE's response to all of the BGE License Renewal Application requests I
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 j
Reference (c).
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9811190059 981'1'd PDR ADOCK 05000317 i
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u NRC Distribution Code A036D L -
. Doc,um:nt Control Desk November 16,1998 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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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 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.
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Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of b hHetJ
.this [N4 day of 7lnerrtL@t/,1998.
WITNESS my Hand and Notarial Seal:
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1Rt b.m Notary Public 2!/
F07 My Commission Expires:
Date CHC/KRE/ dim Attachments: (1) Response to Request for Additional Information; integrated Plant Assessment Report for the Service Water System (2) Errata to Section 5.17, Service Water System; License Renewal Application cc:
R. S. Fleishman, Esquire C.1. 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) l RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR THE SERVICE WATER SYSTEM 4
Baltimore Gas and Electric Company Calvert Cliffs Nudear Power Plant November 16,1998
ATTACIIMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FORTilE SERVICE WATER SYSTEM NRC Ouestion No. 5.17.1 Section 5.17, " Service Water System," [of the Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA)J indicates that a previously performed evaluation concluded that the non-safety-related portions of the Service Water (SRW) System are adequately rugged to withstand a design basis earthquake, which is credited in the design basis for preserving system inventory. The same j
section also indicates that all safety-related portions of the SRW are within the scope for license renewal.
Since the non-safety-related portions of the SRW piping are credited in preserving system inventory during a design basis earthquake, it is not clear why this portion of piping is not within the scope for
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license renewal. Provide the basis for excluding this portion of SRW from the scope oflicense renewal or a cross reference to where it is addressed in the LRA.
1 BGE Responss Turbine Building SRW System components downstream of the header isolation control valves up to the check valves in the return piping do not meet 10 CFR 54.4(a)(1) and (2) scoping requirements.
Additional information on this subject is contained in Calvert Cliffs Nuclear Power Plant Updated Final Safety Analysis Report, Revision 22, Section 9.5.2.2; References (1), (2), and (3) [previously References 4, 5, and 6 ofBGE LRA Section 5.17]; and Reference (4).
The bottom of page 5.17-1 indicates that the aforementioned non-safety-related SRW piping and valves in the Turbine Building associated with the instrument and plant air compressors and j
aftercoolers are within the scope oflicense renewal to support fire protection functions. These non-safety-related SRW components are addressed in BGE LKA Section 5.10, Fire Protection.
NRC Ouestion No. 5.17. 2 Section 5.17.2, indicates that the safety-related SRW System piping will be included in an Age-Related Degradation Inspection (ARDI) Program to verify that degradation of the piping is not occurring, and the results of that inspection will be evaluated for applicability to the non-safety-related SRW piping. In addition, you state that the non-safety-related portions of SRW piping and the safety-related piping were both originally designed to [ United States of America Standard] (USAS) B31.1 and both are subject to i
the same environmental service conditions and chemistry controls. The applicability evaluation will also consider, at a minimum, flow rate and configuration differences between safety-related and non-safety-related SRW piping. Please clarify how the flow rate and configuration differences between safety-related and non-safety-related SRW piping will be considered in the applicability evaluation, and clarify the basis upon which you concluded that the results of the inspection of the safety-related piping are adequately representative of the aging degradation of the non-safety-related piping.
BGE.Resnanse The ARDI Program is intended to provide the additional assurance to conclude that the effects of plausible aging are being effectively managed for the period of extended operation. Table 5.17-3 indicates that the plausible age-related degradation mechanisms (ARDMs) for safety-related SRW System piping includes crevice corrosion, general corrosion, pitting, and erosion corrosion.
Service water ARDI results (which will be based on safety-related pressure boundary component inspections) will be evaluated for applicability to the non-safety-related SRW piping. The details of the applicability evaluation, including flow rate and configuration differences, will be developed as 1
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FORTilE SERVICE WATER SYSTEM part of the ARDI Program. The ARDI Program is a new program. For additional information on the ARDI Program, please see BGE Response to Generic Areas Question No. I 1.4 (Reference 5).
NRC Ouestion No. 5.17. 3 According to Subsection 5.17.1.1, the SRW piping to the instrument and plant air compressors and aftercoolers is within the scope oflicense renewal for fire protection. However, a failure anywhere in the SRW supply or return piping to these components (or any connected systems or components) can affect not only the fire protection safe shutdown, but also all other safe shutdown events requiring the operation of the SRW System. Clarify the basis for determining why the SRW System piping to the compressors and aftercoolers is within the scope oflicense renewal for fire protection, but not within the scope for the SRW.
BGE Responas Turbine Building SRW System compenents downstream of the header isolation control valves up to the check valves in the return piping do not meet 10 CFR 54.4(a)(1) and (2) scoping requirements.
A safety injection actuation signal shuts the SRW Turbine Building header isolation control valves to isolate Turbine Building SRW components. The instrument air and plant air compressors, which are cooled by non-safety-related SRW, are not relied on to remain functional during and following design basis events and are classified non-safety-related. Calvert Cliffs has a safety-related air supply for each Unit known as the Saltwater Air Compressors (SWACs). The SWACs are air-cooled and, therefore, do not rely on SRW for cooling. The SWACs are addressed in BGE LRA Section 5.4,
" Compressed Air."
The bottom of page 5.17-1 indicates that the non-safety-related SRW piping and valves in the Turbine Building associated with the instrument and plant air compressors and aftercoolers are within the scope of license renewal to support fire protection functions. These non-safety-related SRW components are addressed in BGE LRA Section 5.10. Page 5.17-7 identifies the fire protection intended function which was determined based on the requirements of 10 CFR 54.4(a)(3).
NRC Ouestion No. 5.17. 4 In Section 5.17.1.3, you have identified that the only passive function associated with the SRW System not otherwise dispositioned is "to maintain the pressure boundary of the system liquid." In light of your response to Component Cooling Water System Question No. 2 [ Reference 6], and the air-operated components in the SRW System, identify how the aging management review has been conducted for the air-operated components in the SRW System.
BGE Response The intended function fe maintaining the pressure boundary should be revised on pages 5.17-7,-8, and -10 to read "To m.atain the pressure boundary of the system fluid." Thus, the intended function encompasses air and liquid environments.
Compressed air components are addressed in various parts of the BGE LRA. Baltimore Gas and Electric Company LRA Section 5.4 generally addresses compressed air components in the compressed air system. However, some safety-related compressed air components associated with specific system loads are addressed in the section for that specific system. For example, Group 3 of 2
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; f
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INTEGRATED PLANT ASSESSMENT REPORT FORTIIE SERVICE WATER SYSTEM Section 5.17, which is described on pages 5.17-19 through 5.17-22, addresses SRW air-operators for control valves. Some of the air components are addressed generically in the commodity evaluations, e.g., the tubing is addressed in Section 6.4.
NRC Ouejilon No. 5.17. 5 Are there any parts of the SRW systems, structures or components 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: (1) preven'ive actions that will mitigate or prevent aging degradation; (2) parameters monitored or inspected relative to degradation of specific structure and component intended functions; (3) detection of aging effects before loss of structure and component intended functions; (4) monitoring, trending, inspection, testing frequency, and sample size to ensure timely detection of aging effects and corrective actions; (5) acceptance criteria to ensure structure and component intended functions; and (6) operating experience that provides objective evidence to demonstrate that the effects of aging will be adequately managed.
BGE Response Baltimore Gas and Electric Company can access all SRW components if required.
NRC Ouestion No. 5.17. 6 Section 5.17 indicates that the SRW System was designed to USAS B31.1 Code requirements. While B31.1 does not require an explicit fatigue analysis, it does specify allowable stress levels based on the number of anticipated thermal cycles. Table 5.17-3 indicates that fatigue is not a plausible ARDM for the SRW System. Because fatigue is normally treated as a Time-Limited Aging Analyses (TLAA) in accordance with the requirements of 10 CFR 54.21(C), please provide the basis for concluding fatigue is not a plausible ARDM for SRW components.
BGE Response Fatigue is not a plausible ARDM for SRW components because the system maintains a relatively steady temperature and pressure. Additionally, it is a low temperature system. The highest normal service condition temperature for SRW pipe classes is 130 F. Therefore, an environment conducive to fatigue does not exist. Baltimore Gas and Electric Company does not agree fatigue is normally a TLAA. Only analyses that meet all six TLAA criteria contained in 10 CFR 54.3(a) are TLAAs.
NRC Ouestion No. 5.17. 7 The rate of corrosion of the components in the SRW System can be mitigated by proper control of the water chemistry. Provide the specifications for the water chemistry in the SRW System. Include the target values for the individual parameters and their monitoring frequency.
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4 ATTACHMENT (I) l b
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR TIIE SERVICE WATER SYSTEM BGE Response 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.
References 1.
Letter from Mr.
R.
E.
Denton (BGE) to NRC Document Control Desk, dated December 14,1990, LER-89-023, Revision 2, " Postulated Rupture in Non-Safety-Related Service Water Subsystem (SRW) Could Cause Failure of Both Safety-Related Subsystems" 2.
Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, dated July 7,1993,
" Evaluation ofisolation Provisions for Service Water System" 3.
Letter from Mr. L. T. Doerflein (NRC) to Mr. R. E. Denton (BGE), dated October 16,1995, "NRC Region I Inspection Report Nos. 50-317/95-08 and 50-318/95-08" 4.
Letter from Mr.
R.
E. Denton (BGE) to NRC Document Control Desk, dated September 6,1994, " Response to Request for Additional Information Concerning Isolation Provisions for the Service Water System" 5.
Letter from Mr.
C.
H.
Cruse (BGE) to NRC Document Control Desk, dated November 12,1998, Response to Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment, Generic Areas 6.
Letter from D. L. Solorio (NRC) to Mr. C. H. Cruse, dated August 11,1998, " Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Report for the Component Cooling System (TAC No. M99583, M99584, M99205)"
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ERRATA TO SECTIOd 5.17, SERVICE WATER SYSTEM; i
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 16,1998
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ATTACHMENT (2)
ERRATA TO SECTION 5.17, SERVICE WATER SYSTEM; LICENSE RENEWAL APPLICATION The following two items apply to Section 5.17 of the BGE LRA:
Item 1: Age-Related Degradation Mechanism (ARDM)" Wear" has been determined to be not plausible for the relief valves in the Service Water System, for the following reasons:
The valves relieve pressure relatively infrequently; and ne leakage that would result from wear of the seating surface would not significantly affect the e
passive pressure boundary function of the.
Herefore, in regards to Section 5.17 of the BGE LRA:
Page 5.17-11, delete " Group 5 - wear" on the bottom of the page.
Page 5.17-12, Table 5.17-3, should not have a check (4) for Device Type "RV" and ARDM
" Wear."
Disregard the discussion for Group 5 (wear) on pages 5.17-24 through 5.17-25, and the line item e
for existing Checklists MPM 01013,01147,01153, and 01155 in Table 5.17-4 on page 5.17-26.
Item 2 On page 5.17-27, Reference 5 is better described as " Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, dated July 7,1993, ' Evaluation ofisolation Provisions for Service Water System'"
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