ML20198S429

Requests Addl Info Re License Renewal Application as Application Relates to Staff Position on Environ Qualification

ML20198S429
Person / Time
Site:	Calvert Cliffs
Issue date:	01/07/1999
From:	Charemagne Grimes NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 9901110324
Download: ML20198S429 (5)

Text

1 t

UNITED STATES j pp i

g NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D.C. 200 6 0001

'+,.....,o January 7, 1999 Mr. Charles H. Cruse, Vice President Nuclear Energy Division Baltimore Gas and Electric Company 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

SPECIFIC INFORMATION NEEDED FOR THE STAFF EVALUATION OF ENVIRONMENTAL QUALIFICATION FOR LICENSE RENEWAL

Dear Mr. Cruse:

i On October 22,1998, the staff met with representatives of Baltimore Gas and Electric Company (BGE) to discuss its license renewal application (LRA) for the Calvert Cliffs Nuclear Power Plant (CCNPP) as the application relates to the staff's position on environmental qualification (EQ).

The staff had documented its position on EQ in guidance enclosed with a letter to Nuclear J

4 Energy Institute, dated September 23,1998. During the October 22 meeting, BGE

(

representatives described five options for ensuring equipment remains qualified in accordance with 10 CFR 50.49 which would constitute the aging management program during the period of j

extended operation. In addition, BGE representatives identified specific text within the LRA which describes the procedures for complying with 650.49.

The staff reviewed this information and found some areas where a clarification of the EQ options will assist the staff in developing a safety evaluation basis which describes how the procedures for compliance with $50.49 adequately manage EQ time-limited aging analyses pursuant to

$54.21(c)(1)(iii). For example, the LRA contains a description of activities by which equipment qualified to $50.49 would be replaced, and discusses an attemate approach when there are

" sound reasons to the contrary." However, the staff also found the need for more specific information to assess the " sound rehsons to the contrary," as well as procedural aspects for the other options available. Accordingly, we request that BGE provide the following information for the options discussed during the October 22,1998, meeting:

1 Describe the procedures that are used to control the use of the " sound reasons to the contrary" attemative for equiprnent replacement, or commit to maintain such procedures in accordance with Regulatory Guide 1.89, Revision 1.

2.

The LRA does not contain a discussion on refurbishment. Rather, the LRA states that

"[t]he only corrective action currently taken by CCNPP 50.49 Program is replacement with new equipment,... This same corrective action will be used during the period of

)

1 extended operation." Describe the process for refurbishment as it applies to EQ, and g

describe the procedural controls that BGE relies upon that ensure that replacement components or groups of devices are retumed to their origir;al qualified condition.

,N linan

($

% +

n d

Charles H. Cruse January 7, 1998 3.

The LRA contains a statement that an approach for ongoing qualification does not currently exist at CCNPP. During the October 22,1998 meeting, BGE stated that it sought to keep this option open for EQ components and groups of items during the period of extended operation. To apply this option, the staff would expect the licensing basis to include a testing program that conforms to the guidance in IEEE 323-1974, Section 6.6 (1) or (2). Describe how BGE would intend to incorporate such an ongoing i

qualification program into the licensing basis for Calvert Cliffs at some time in the future.

i 4.

The attributes of re-analyses that need to be specifically provided for the EQ device types listed in Table 6.3-1 include the following: analytical methods; data collection (including a description of the method used to monitor service conditions) and reduction methods; underlying assumptions; acceptance criteria; corrective actions if acceptance l

criteria are not met; and the period of time prior to the end of qualified life when the re-analyses will be completed. The LRA currently discusses analytical methods, underlying assumptions, and corrective actions. However, clarifications with respect to data i

col!ection and reduction methods and underlying assumptions are needed for the staff to develop a technical basis for the adequacy of the aging management aspects of re-analysis methods.

L The LRA contains the following information: devices that are exposed to temperatures i

i wellbelow the maximum normal design value may be re-evaluated using a bounding i

value that envelopes the maximum temperatures experienced instead of the maximum design temperature. There is no need to maintain the excess conservatism that exists in l

the current qualificationJust because the maximum design temperature was used as the l

basis for the current qualified life. This concept holds for all equipment qualification parameters, including temperature, pressure, radiation...' identify if any changes have been made to the underlying assumptions affecting equipment qualified life related to the l

normal thermal, radiation, mechanical, electrical, and chemical environment in which the equipment operates, and describe the process by which such changes will be made in the future. Any changes made to underlying assumptions should be identified. Data collection and reduction methods, such as the degradation-weighted average temperature techniques that will be used to re-evaluate qualified life, should be provided as part of the description of the process by which continued compliance with $50.49 will l

adequately manage EQ re-analysis through the period of extended operatinn.

1 in addition, the appication is not clear whether there will be any changes in the use of the cunrently-approved methodology and acceptance criteria. If BGE has made any changes to analytical methods or acceptance criteria, describe those changes so that they may evaluated as they were at the time of initial licensing and describe the procedures that will be used to make such changes in the future. If no changes have been made or are planned, please so state.

s e

4 Charles H. Cruse January 7, 1998 l

l Please provide a schedule by letter, electronic mail, or telephonically for the submittal of your response to these additional questions within 30 days of the receipt of this letter. Additionally, the staff would be willing to meet again with BGE prior to the submittal of the iesponses to provide clarifications of the staff's requests for additional information.

Sincerely, M8f SI9fted By Christopher 1. Grimes, Project Director License Renewal Project Directorate Division of Reactor Program Management i

Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 DISTRIBUTION: See next page DOCUMENT NAME:C:WYFILESEQ GUID2.cig.WPD

• See previous con:urrence OFFICE PDLR EELB OGC PDLR:Kg DRPM:D DE:D (%

NAME R Prato

• J Calvo

• R Weisman

• CGrimW D Matthews

• J Strohider DATE 11/10/98 12/03/98 12/04/98 1/07/99 1/06/99 1/ 7 /99 l

OFFICIAL RECORD COPY

c

-e

. Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos.1 and 2 President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland i

175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre l

Baltimore, MD 21202-6806 L

' James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre o

Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire j

Shaw, Pittman, Potts, and Trowbridge Patricia T. Bimie, Esquire i

2300 N Street, NW Co-Director Washington,I')C 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Bruce S. Montgomery, Director Baltimore, MD 21218 NRM Calvert Cliffs Nu./ sar Power Plant Mr. Loren F. Donatell 1650 Calvert Clins Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector U.S. Nuclear Regulatory Commission David Lewis P.O. Box 287 Shaw, Pittman, Potts, and Trowbridge St. Leonard, MD 20685 2300 N Street, NW Washington, DC 20037 Mr. Richard I, McLean l

Nuclear Programs Douglas J. Walters l

Power Plant Research Program Nuclear Energy Institute Maryland Dept.' of Natural Resources 1776 l Street, N.W.

Tawes State Office Building, B3 Suite 400 Annapolis, MD 21401 Washington, DC 20006-3708 DJW@NEl.ORG Regional Administrator, Region i U.S. Nuclear Regulatory Commission Barth W. Doroshuk 475 Allendale Road Baltimore Gas and Electric Company l

King of Prussia, PA 19406 Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway NationalWhistleblower Center NEF 1st Floor 3233 P Street, N.W.

Lusby, Maryland 20657 Washington, DC 20001 l

l

A Distribution:

HARD COPY Docket Files PUBLIC 4

PDLR R/F OGC MEl-Zeftawy DISTRIBUTION: E-MAIL FMiraglia (FJM)

JRoe (JWR)

DMatthews (DBM)

J CGrimes (CIG)

TEssig (THE)

Glainas (GCL)

JStrosnider (JRS2)

GHolahan (GMH)

SNewberry (SFN)

GBagchi(GXB1)

RRothman (RLR)

JBrammer (HLB)

CGratton (CXG1)

JMoore (JEM) i MZobler/RWeisman (MLZ/RMW)

- SBajwa/ADromerick (SSB1/AXD)

LDoerflein (LTD)

BBores (RJB) 4 SDroggitis (SCD)

RArchitzel(REA)

(

CCraig (CMC 1)

LSpessard (RLS)

RCorreia (RPC)

RLatta (RML1)

EHackett (EMH1)

AMurphy (AJM1)

TMartin (TOM 2)

DMartin (DAM 3)

GMeyer (GWM)

WMcDowell(WDM)

SStewcrt (JSS1)

THiltz (TGH)

SDrogg!!is (SCD)

DSolorio (DLS2)

PDLR Staff

.