ML20195E668
| ML20195E668 | |
| 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 9811190061 | |
| Download: ML20195E668 (11) | |
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Curatxs H. C UsE Baltimore Gas and Electric Company l Vice President Calvert Cliffs Nuclear Power Plant i Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 l
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November 16,1998 l l
U. S. Nuclear Regulatory Commission Washington,DC 20555 ATTENTION: Document Control Desk l
SUBJECT:
Calvert Cliffs Nuclear Power Plant l 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 Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydronen Systems. and Errata .
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REFERENCES:
(a) Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated October 22,1998 " Request for Review and Approval of System j and Commodity Reports for License Renewal" 1 (b) Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE),
August 31,1998," Request for Additional Information for the Review of i the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Report for the Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems" (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 ClitTs Nuclear Power Plant License Renewal Application Submitted by the Baltimore Gas and Electric Company" Reference (a) forwarded four Baltimore Gas and Electric Company (BGE) system and commodity ,
reports for license renewal. Reference (b) forwarded questions from NRC staff on one of those four l l reports, the Integrated Plant Assessment Report for the Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems. 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). l ,
l Attachment (2) provides errata to Section 5.12 of the BGE LRA, " Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems."
! 9811190061 981116 #
PDR ADOCK 050003 7 NRC Distribution Code A036D
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' Document Control Desk November 16,1998 Page 2 l 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 ata 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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1 Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of '
f4fredJ i .this //n1 A glay of Ment /Av ,1998. i WITNESS my Hand and Notarial Seal: b1LdD b 7tu.Avd i Notary Public My Commission Erpires: S !/ ! 2 67) 1 '
Date CHC/KRE/ dim
Attachment:
(1) Response to Request for Additional Information; Integrated Plant Assessment Report for the Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems; License Renewal Application ;
(2) Errata to Section 5.12, Main Steam, Steam Generator Blowdown, Extraction Steam, )
l and Nitrogen and Hydrogen Systems; License Renewal Application i l 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.1. McLean, DNR i i H. J. Miller, NRC J. H. Walter, PSC 1
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ATTACHMENT (1) i i
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RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; j INTEGRATED PLANT ASSESSMENT REPORT FOR THE MAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM AND i
NITROGEN AND HYDROGEN SYSTEMS 4
Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 16,1998
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! RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; l INTEGRATED PLANT ASSESSMENT REPORT FOR THE MAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRAC110N STEAM, AND NITROGEN AND HYDROGEN SYSTEMS NRC Ouestion No. 5.12.1 l In Section 5.12.1 (bottom of Page 5.12-1) you identify that the Erosion Corrosion Program is credited for l the mitigation of several components within the scope oflicense renewal. It is not clear what the term l " mitigation of several components" is intended to imply. Please clarify this statement and explain its relationship'to license renewal.
l BGE Resnonse l
As stated in the discussion for the Erosion Corrosion Program on page 5.12-29 of the Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA), all of the main steam-related piping addressed in this report is included in this program. This includes piping that comprises the i main steam headers, main steam to the auxiliary feedwater turbine-driven pumps, main steam drains, I and steam generator blowdown. The Erosion Corrosion Program is credited with detecting and managing the effects of erosion corrosion of this piping, as well as the general corrosion, crevice corrosion, and pitting of this piping.
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NRC Ouestian No. 5.12.2 !
l In Section 5.12.1 you also state that there have been problems with system drains associated with l portions of the system not within the scope oflicense renewal. It is not clear whether the system referred l to is the extraction steam system, main steam system, steam generator blowdoven system (SGBS), or all 1 three of these steam systems. Please clarify this statement.
BGE Response Those system drains were in the Main Steam System.
NRC Ouestion No. 5.12.3 ;
1 The portions of the SGBS that are inside containment are included (see Section 5.12.1) in the scope of Section 5.12. However, according to Section 5.12.1.1, the SGBS is apparently not included in Section 5.12, nor does it appear to be included in any of the other referenced reports listed in Section 5.12.4. Please identify which section of the LRA discusses scoping and aging management for tl:.e SGBS or provide the basis for its exclusion.
l BGE Response Steam generator blowdown is part of the Main Steam System. It is included within the scope of Section 5.12 of the LRA as indicated on Figure 5.12-1, Main Steam and Interfacing Systems, on page 5.12-8 of the LRA. This figure is representative of all four Calvert Chffs steam generators. It shows the piping sections both inside and outside of containment that are within scope of license renewal. The inclusion of piping, valves, and heat exchangers are addressed specifically in the LRA as follows:
e In the second full paragraph on page 5.12-2 under Operating Experience; e In the first full paragraph, and its four bullets, on page 5.12-5 under System Interfaces;
- In the second paragraph, and its eight bullets, as applicable, on page 5.12-6 under System Scoping Results; i
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR THEMAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM, AND NITROGEN AND HYDROGEN SYSTEMS e In the first paragraph on the top of page 5.12-7, still under System Scoping Results; e Under 5.12.1.2, Component Level Scoping, in the first paragraph on page 5.12-10; e On page 5.12-17, in the first two paragraphs, and in the applicable bullets in the second pvagraph, under Group 1 - Materials and Environment; e
On page 5.12-18, in the second full paragraph at the top of the page, still under Group 1 -
Materials and Environment, and in the last paragraph on that page under Group 1 - Aging Mechanism Effects; e
On page 5.12-19, in the last full paragraph on the page, still under Group 1 - Aging Mechanism Effects; e On page 5.12-21, in the first paragraph of Group 1 - Aging Management Program (s);
- In the last paragraph on page 5.12-22, still under Group 1 - Aging Management Program (s);
e On page 5.12-25, in the first paragraph under Discovery;
- In the last bullet on page 5.12-26, under Group 1 - Demonstration of Aging Management;
- In the first paragraph under Group 2 - Materials and Environment on page 5.12-27; e in the first paragraph on the top of page 5.12-28, still under Group 2 - Materials and Environment; e On page 5.12-29, in the second paragraph under Mitigation for Group 2 - Aging Management Programs;
- In the first paragraph under Discovery on the same page; e in the last paragraph on page 5.12-30 still under the discussion on Discovery for Group 2 -
Aging Management Programs;
- In the second and third bullets under Group 2 - Demonstration of Aging Manoment on page 5.12-31;
- In the entire Group 3 discussion, about selective leaching of the steam generator blowdown radiation monitor cooler, from page 5.12-31 to 5.12-33; and '
e in Table 5.12-5 on page 5.12-36.
NRC Ouestion No. 5.12.4 -
Section 5.12.1.1 describes the functional requirements of the main steam, extraction steam, and nitrogen and hydrogen systems, but does not provide similar information for the SGBS. Please describe the functional requirements of the SGBS. Also identify if there is a containment isolation function associated with the SGBS and indicate whether it is or should be included in this section of the LRA.
BGE Response i As stated in the answer to the previous question, steam generator blowdown is part of Main Steam and is not recognized as a separate system within the plant like the Main Steam, Extraction Steam, and Nitrogen and Hydrogen Systems. The functional requirements and the intended functions for these systems were determined based on the very rigorous system and component screening process i
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR TIIE MAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM, AND NITROGEN AND HYDROGEN SYSTEMS for applicability under the license renewal rule, as detailed in the BGE Integrated Plant Assessment Methodology. As such, the functional requirements for the Main Steam System, as they apply to steam generator blowdown within the scope of license renewal, are identified in Section 5.12.1.1 (on pages 5.12-2 and -3) as noted in the request for additional information.
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j The system intended functions are included under the System Scoping Results, on page 5.12-6 of the LRA. As noted, containment isolation is not one of them. The basis for this is quoted below from the ;
Calvert Clifts Updated Final Safety Analysis Report (UFSAR), Revision 22, Section 5.1.4.4:
"Each line which penetrates containment and contains high pressure or high temperature fluids (steam, feedwater, and steam generator blowdown) passes through a structural steel sleeve l mounted on the containment wall. This sleeve acts as a positive stop to prevent whipping I associated with fracture of a line containing high internal energy and thereby prevents damage to the penetration and breaching of the containment."
This statement implies that the steam generator and the above sleeve act as a containment boundary.
This position is additionally supported by the absence of the containment isolation valves from the i technical specification. The function of steam generator isolation valves (including the main steam isolation valves [MSIVs] and the steam generator blowdown isolation valves) is to provide isolation l of the steam generators during a main steam rupture or a steam generator tube rupture to prevent exceeding the 10 CFR Part 100 limits. This is reflected in the list of intended functions for Main Steam on page 5.12-6 of the LRA.
NRC Ouestion No. 5.12.5 You have identified that the non safety-related portions of the main steam system that are within the scope of license renewal for fire protection considerations are addressed in Section 5.10 of your application. The NRC staff would expect that the aging mechanisms and management programs would be the same for the non-safety and safety-related portions of the main steam system. In light of this assumption, provide a summary discussion on why portions of the main steam system are addressed in multiple sections of the LRA. Also, identify the functional requirements and intended functions of the main steam system that are within the scope oflicense renewal for fire protection considerations.
i BGE Response 1 Baltimore Gas and Electric Company LRA Secticn 5.10, " Fire Protection," describes why an aging i management review process separate and unique from that used for other plant systems and structures was used for fire protection. Section 5.10.2,"AMR Methods," describes four different methods used to demonstrate aging management of non-safety-related pressure retaining components which support l passive fire protection intended functions. Section 5.10.3.16.2, " Scoping Summary" (for the Main Steam System), identifies the safe shutdown functions for the main steam system in the event of a fire; the passive fire protection intended function of the main steam system; and the portion of the main steam system within the scope of license renewal for fire protection. Section 5.10.3.16.3,
" Aging Management Demonstration," identifies the method used to demonstrate aging management of the portion of the Main Steam System within the scope oflicense renewal for fire protection.
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR THEMAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM, AND NITROGEN AND HYDROGEN SYSTEMS NRC Ouestion No. 5.11(t I'
On page 5.12-4, you identify that the main steam lines from the steam generators to the MSIVs are l within the scope of license renewal. Please clarify this statement to indicate if the scope includes the
! MSIVs and if the scope extends to the first restraint downstream of each MSIV. Ifit does not extend to I. the first restraint downstream of the MSIV provide appropriate justification for the exclusion of this !
portion of the system (and its restraint).
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BGE Response -
The MSIVs are within the scope of license renewal. This is depicted in Figure 5-12.1. The piping
, between the MSIVs and the next downstream anchor is within the scope of license renewal and is i l addressed in BGE LRA Section 3.l A, " Piping Segments That Provide Structural Support."
NRC Ouestion No. 5.12.7 I l
You have identified that the extraction steam system inside containment has been abandoned in place and that only the associated containment penetration is within the scope of license renewal. Assuming l that the piping inside containment needs to be seismically supported for Seismic 11 over I (114) l l'
considerations, describe whether the supports for this piping are within the scope of license renewal. l Additionally, please provide similar discussions for any other abandoned equipment that may potentially i affect the performance of a safety-related function during a design basis event, and the extent to which that equipment was determined to be within the scope oflicense renewal.
BGE Response l Updated Final Safety Analysis Report Section SA.3.2.2 describes the design provisions for l Seismic IIS piping, and this approach minimizes the potential for problems. Subsequent to the initial plant construction (1993), BGE contracted the evaluation of Seismic 114 piping systems to identify installed conditions that could lead to seismic interactions and/or to provide a basis for considering this piping to be seismically acceptable. This was done by walking down a sampling of Seismic Ild piping from various systems and on various elevations of the Auxiliary Building and intake Structure.
l - The walkdown process and results were documented and compared to acceptance criteria. The 1 l sampling of Seismic 114 systems was large enough in quantity, as well as in individual system length, to establish an acceptable inspection level. Since no critical defects were found during the walkdown ;
evaluation, a high confidence level was achieved that all Seismic IIM systems at Calvert Cliffs (e.g., including those in Containment) are seismically adequate and do not present any safety threat to safety-related piping systems.
l The design approach for Seismic IIM equipment is similar to that for piping. A listing of abandoned equipment was reviewed. Most is not located in the proximity of Category I equipment if it is, its support requirements were designed as discussed in UFSAR Section 5.A.3.3 and above.
Note that all items in the plant are observed during the course of system and structure walkdowns and during maintenance activities. During these activities, degradation that may exist is documented, i
evaluated, and resolved in accordance with our Corrective Actions Program. For these reasons, abandoned piping and abandoned equipment are not within the scope oflicense renewal.
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR THE MAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM, AND NITROGEN AND HYDROGEN SYSTEMS NRC Ouestion No. 5.12.R Section 5.12.1.2 identifies the air supply piping to the auxiliary feedwater stop control valves as being within the scope of license renewal. Describe why other air-operated components in the systems included in Section 5.12 are not within the scope of license renewal. Also, explain why potential and
- plausible aging mechanisms (Table 5.12-4) for portions of the compressed air system that are included in this report are not identified, or provide an appropriate icfcrcr.ce to where these components are subjected to an aging management review.
BGE Response ;
The safety-related portions of the Compressed Air System are within the scope oflicense renewal and are addressed in Section 5.4," Compressed Air System," of the BGE LRA. Those non-safety-related portions of the system that are normally aligned for use during normal operation in accordance with plant Operating Instructions are also within the scope of license renewal (for fire protection) and are ,
addressed in Section 5.10 of the BGE LRA. The remaining non-safety-related portions of the system are not within the scope of license renewal and are not subject to aging management review. It should be noted that some components are addressed generically in the commodity evaluations, e.g., the tubing is addressed in Section 6.4, " Instrument Lines," of the BGE LRA.
In some cases, BGE included a portion of the cornpressed air piping with the system being supplied.
For the Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen ;
Systems, the only compressed air piping that was included in Section 5.12 of the BGE .LRA is a j portion that is dedicated to supplying air to the auxiliary feedwater stop control valves. This includes l piping, hand valves, pressure control valves, relief valves, and accumulators, which are addressed in 4
this report as Main Steam device types in Table 5.12-4. It also includes pressure switches and pressure indicators, which are addressed in Section 6.4 of the BGE LRA.
NRC O'agallon No. 5.121 Are there any parts of the systems structures or components described in Section 5.12 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 ofinaccessible 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) Preventive 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.
l RGE Response Baltimore Gas and Electric Company can access all Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems' components if required.
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', ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR THEMAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM, AND NITROGEN AND HYDROGEN SYSTEMS NRC Ouestion No. 5.12.10 Table 5.12-4 shows that fatigue is not plausible for the Main Steam System. However, Table 2.1-1 in Section 2.1 shows that the main steam piping fatigue is one of the time-limited aging analyses that were determined to be subject to license renewal review. Additionally, in Section 2.1.3.4, a discussion is provided to demonstrate that the main steam piping fatigue analyses meet the criteria of 10 CFR 54.21(cXIXI), such that the 7,000 assumed thermal cycles will not be exceeded during the period of extended operation. Provide the basis for concluding fatigue is not a plausible age-related degradation mechanism in light of the above information. Please also discuss if there is an inconsistency ,
between Tables 5.12-4 and 2.1-1 as a result of above information.
l BGE Response As noted above, a main steam fatigue analysis is discussed in Section 2.1.3.4 that concludes the analysis is valid for the period of extended operations. The fact that main steam piping fatigue analyses constitute a TLAA has no bearing on the plausibility of fatigue, it only indicates an evaluation involving time-limited assumptions was performed. The system is designed to withstand a much larger number of thermal cycles than it will actually experience through the period of extended operations. There is no inconsistency between Table 5.12-4 and Table 2.1-1.
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ATTACHMENT (2) i i
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l- ERRATA TO SECTION 5.12, MAIN STEAM, STEAM GENERATOR BLOWDOWN, ErrRACTION STEAM AND NITROGEN AND HYDROGEN SYSTEMS; LICENSE RENEWAL APPLICATION Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant November 16,1998
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ATTACHMENT (2)
ERRATA TO SECTION 5.12, MAIN STEAM, STEAM GENERATOR BLOWDOWN, EXTRACTION STEAM, AND NITROGEN AND HYDROGEN SYSTEMS; LICENSE RENEWAL APPLICATION The following changes apply to Section 5.12 of the BGE LRA:
On page 5.12-6, a ninth bullet should be added to those at the top of the page, indicating an additional Main Steam System intended function, as follows: i
" To provide containment overpressure protection." 1 I
On page 5.12-36, in Table 5.12-5, the line item for existing program CP-217 (Calvert Cliffs Technical j Procedure CP-217, " Specifications and Surveillance - Secondary Chemistry") should read, in part, l
"(Group 1), and erosion corrosion (Group 2) of Main Steam . . .," vice "(Group 1), erosion corrosion (Group 2), and wear (Group 4) of Main Steam . . ." l l
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