ML20195E676
| ML20195E676 | |
| 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 9811190065 | |
| Download: ML20195E676 (9) | |
Text
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m CHARLES H. CRUSE Baltimore Gas and Electric Company Vice President Calveit Cliffs Nuclear Power Plant i
Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 j
410 495 4455 l
l November 16,1998 1
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 Fire Protection System. and Errata l
REFERENCES:
(a)
Letter from Mr. C. II. Cruse (BGE) to NRC Document Control Desk, dated March 27, 1998, " Request for Review and Approval of Commodity and System Reports and the Time-Limited Aging Analyses Evaluation for License Renewal" (b)
Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE),
September 2,1998," Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Report for Fire Protection System" (c)
Letter from Mr. D. L. Solorio (NRC) to Mr. C. H. Cruse (BGE),
September 4,1998," Request for Additional Information for the Review of the Calvert Cliffs Nuclear Power Plant, Units 1 & 2, Integrated Plant Assessment Report for Fire Protection System" (d)
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" Reference (a) forwarded five Baltimore Gas and Electric Company (BGE) system and commodity reports for license renewal, plus the Time-Limited Aging Analyses Report. References (b) and (c) forwarded questions from NRC staff on one of those five reports, the Integrated Plant Assessment Report on the Fire Protection System. Reference (d) 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 Fire Protection System questions contained in References (b) and (c). The questions are renumbered in accordance with 9811190065 981116' DR ADOCK 050003 7 NRC Distribution Code A036D
Docu* ment Control Desk
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- November 16,1998 Page 2 i
Reference (d). ' Attachment (2) provides errata to Section 5.10, Fire Protection System, of the BGE License Renewal Application.
Should you have further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, s
/
P 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 te 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 Cr81Im{l
,this/MJ Jday of Mm/A/,1998.
)
i WITNESS my Hand and Notarial Seal:
b/nmi1b 11110, d Notary Public My Commission Expires:
2 f / ['AC0%
Date CHC/KRE/ dim j
Attachments: (1) Response to Request for Additional Information; Integrated Plant Assessment Report for the Fire Protection System U
(2) Errata to Section 5.10, Fire Protection System; License Renewal Application ec:
R. S. Fleishman, Esquire C.1. Grimes, NRC i
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) i RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR TIIE FIRE PROTECTION SYSTEM
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Baltimore Gas and Electric Company i
Calvert Cliffs Nuclear Power Plant November 16,1998 i
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR TIIE FIRE PROTECTION SYSTEM NRC Ouestion No. 5.10.1 i
Subsection 5.10.1.3.2 of the [ Baltimore Gas and Electric Company (BGE)] License Renewal Application (LRA) includes a statement that seven systems (Systems 08,13, 29, 37, 44, 53, and 71) rely almost entirely on non-safety-related components to perform their passive fire protection (FP) intended functions. These seven systems are addressed in Section 5.10 of the LRA, and Table 3.1-2 in Section 3.1
(" Components Supports") of the LRA describes component support types requiring an aging management review (AMR) for all systems and the associated equipment within the scope license renewal. Regarding the scope of the AMR for the supports (piping / equipment and/or components) j relating to the FP intended functions within System 71, address the following questions:
Are any piping supports other than piping frames and stanchions (such as spring hangers, constant a.
4 load supports, sway struts, rod hangers, etc.) used for System 71, " Liquid Waste System?"
(Table 3.1-2 does not include these support types for System 71.) If so, list and identify these piping supports. In addition, identify where in the LRA the AMR for these supports is addressed, provide an AMR, or provide ajustification for determining that an AMR is not required for these piping supports.
- b. Are any equipment and/or components (other than piping) supports used for System 71 " Liquid j
Waste System" (Table 3.1-2 does not include these support types for equipment and/or i
components associated with System 71)? If so, list and identify these equipment and/or components supports. In addition, identify where in the LRA the AMR for these supports is addressed, provide an AMR, or provide a justification for determining that an AMR is not required for the equipment and or these component supports.
_BGE Resannst a There are many rod supports and sway strut supports used on the piping in System 71 that are within the scope of license renewal. The omission of System 71 from the system list in Table 3.1-2 for spring hangers, constant load supports, sway struts, rod hangers, and snubber j
supports outside of containment is an oversight. These piping supports are among those included i
in the Additional Baseline Walkdowns program addressed under Group 1 in Section 3.1.2 and Table 3.1-4 of the LRA for those supports that were not included in the Seismic Verification Program and/or the Inservice Inspection Program. These supports are also included in Calvert Cliffs Administrative Procedure MN-1-319," Structure and System Walkdowns," as described.
b There are two portions of System 7I within the scope oflicense renewal. One of those portions is the non-safety-related system piping that directs plant drains (received from multiple paths of the j
Plant Drain System) from rooms containing safety-related equipment to one of the waste receiving tanks, as described in Sections 5.10.3.14.2 and 5.10.3.14.3 of the LRA, to assure drainage of fire suppression water in the event ofits use. The other portion of the system within scope is each unit's containment penetration piping and isolation valves addressed in Section 5.5 j
of the LRA. This piping is safety-related. There are no major System 71 components in those j
flow paths that would require their own supports.
NRC Ouestion No. 5.10.2 i
Table 5.10-2 of the LRA summarizes the four aging management programs that are applied to j
16 systems that rely on non safety-related components. This table indicates that three of the 16 systems are only partially covered by the "FP Program Activities Manage Aging" and " Performance and 1
,o ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR Tile FIRE PROTECTION SYSTEM i
l Condition Monitoring Activities Manage Aging"(for System 36 and System 53), and the " Performance and Condition Monitoring Activities Manage Aging" and "AMR Conducted for Remaining Components" (for System 44). Although the table indicates that Systems 36,44, and 53 are partially covered by the programs identified, no additional aging management programs are identified. Clarify how you concluded that these aging management programs are sufficient to manage the effects of aging associated with Systems 36,44, and 53.
BGE Resnonse l
Section 5.10.2 of the LRA contains a description of the process whereby it was concluded that these aging management programs are sufficient to manage the effects, ! aging for all components addressed by Section 5.10 of the LRA.
l It should be noted that the safety-related portion of System 36, " Auxiliary Feedwater," is addressed by Section 5.1," Auxiliary Feedwater System," of the LRA as indicated in Section 5.10.1.3.1. For the j
non-safety-related portion of System 36 addressed by Section 5.10, aging is managed for part of the system by FP Program Activities, and aging for the remaining part of the system is managed by Performance and Condition Monitoring Activities. Please refer to Section 5.10.3.8.3 of the LRA for further clarification.
For System 44, " Condensate," aging is managed for part of the system by Performance and Condition Monitoring Activities, and the AMR concluded that the remaining part of the system will be managed by the Age-Related Degradation Inspection Program. Please refer to Section 5.10.3.11.3 of the LRA for further clarification.
i For System 53," Plant Drains," aging is managed for part of the system by FP Program Activities, and aging for the remaining part of the system is managed by Performance and Condition Monitoring Activities. Please refer to Section 5.10.3.12.3 of the LRA for further clarification.
NRC Ouestion No. 5.10.3 Subsection 5.10.3.3.3 contains a list of performance and/or condition monitoring activities used to maintain / verify the ability of the FP System to perform its passive FP intended function. Provide the technical basis for concluding that these activities (and related frequencies) can adequately manage microbiologically-induced corrosion, and general corrosion of the components (including system piping) in the FP System.
BGE Response The technical bases for concluding that the FP Program adequately manages aging is contained in Sections 5.10.2, 5.10.2.1, and 5.10.3.3.1 of the LRA. The identified procedures direct periodic activities that will discover degradation. Once discovery occurs, the procedures would invoke the site Corrective Actions Program. Detailed information concerning credited aging management programs is readily available onsite for review.
NRC Ouestion No. 5.10.4 Are there any parts of the systems, structures, or components described in Section 5.10 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 2
0 ATTACilMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR THE FIRE PROTECTION SYSTEM 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 i
effects or aging management techniques are needed for the inaccessible areas, please provide a summary j
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 specinc 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 Responic Baltimore Gas and Electric Company can access all components described in LRA Section 5.10 if required.
NRC Ouestion No. 5.10J Section 5.10, " Fire Protection," addresses the FP functions and the safe shutdown function (Appendix R to 10 CFR Part 50). Describe how the Calvert Cliffs FP Plan, which is required under 10 CFR 50.48,
" Fire Protection," was used in developing the system-level scoping and the integrated plant assessment (including FP and safe shutdown).
BGE Responac The FP Program and various additional licensing basis documents were reviewed to identify the system functions that address regulations on FP and BGE's commitments for implementation of those regulations. This information was used to prepare a Screening Tool as described in Section 3.3.2.1 of the Integrated Plant Assessment Methodology (Section 2.0 of BGE's LRA). The entire methodology, including a discussion of System-Level Scoping (Section 3.0), is available in Section 2.0.
NRC Ouestion No. 5.10.6 Summarize the changes to the post-fire safe shutdown analysis and the fire hazards analysis that have been implemented since plant licensing and briefly discuss how the analyses, including changes, were addressed in the system level scoping process.
BGE Response Baltimore Gas and Electric Company understands that NRC will issue a replacement question for this item.
NRC Ouestion No. 5.10.7 Identify the FP components, if any, that have been excluded from the scope of the rule because they are subject to replacement based on qualified life or a specified time period as permitted under i
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ATTACHMENT (1)
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION; INTEGRATED PLANT ASSESSMENT REPORT FOR TIIE FIRE PROTECTION SYSTEM BGE Response No components encompassed by the systems or portions of systems addressed by Section 5.10 of the LRA are excluded from AMR because they are subject to replacement based on qualified life or specified time period.
NRC Ouestion No. 5.10.8 Describe, in detail, how the post-fire remote or auxiliary shutdown panels were addressed in the system level scoping process and the AMR process.
BGE Response ne auxiliary shutdown panels were identified as in scope for license renewal because they provide a FP function and are safety-related. They were evaluated with other panels in the electrical commodities evaluation, which is documented in Section 6.2, " Electrical Commodities," of the BGE I RA. The auxiliary shutdown panels are susceptible to electrical stress and wear. They are included in Group 7 of Section 6.2. Aging is managed by the Preventive Maintenance Program. Specifically, these panels are periodically cleaned and inspected per Instrumentation Preventive Maintenance Checklists IPM 13118 and 13119 (see page 6.2-26 of the LRA).
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ATTACHMENT (2) 1 l
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ERRATA TO SECTION 5.12, FIRE PROTECTION SYSTEM; l
1 LICENSE RENEWAL APPLICATION 4
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Novemher 16,1998
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c ATTACHMENT (2)
ERRATA TO SECTION 5.10, FIRE PROTECTION SYSTEM; LICENSE RENEWAL APPLICATION The following changes apply to Section 5.10 of the BGE LRA:
On page 5.10-22, in the full paragraph under "S.10.3.5.2. Scoping Summary," the next-to-last sentence should be expanded to read, "The portion of the system in scope for the FP AMR includes all NSR components of the system that are nonnally aligned for use during operation in accordance with plant operating instructions."
On page 5.10-26, in the top line,"CSTs 11 and 12" should read "CSTs i1 and 21."
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