ML20199C034

Discusses 970128 & 0502 Ltrs Submitting 120-day Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, for Calvert Cliffs Nuclear Power Plant

ML20199C034
Person / Time
Site:	Calvert Cliffs
Issue date:	11/07/1997
From:	Dromerick A NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
GL-96-06, GL-96-6, TAC-M96792, NUDOCS 9711190193
Download: ML20199C034 (5)

Text

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g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 3084H001

% November 7.-1997 Mr. Charles H. Cruse Vice President- Nuclear Energy Baltimore Gas and Electric Cempany Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

INFORMATION PERTAINING TO CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NO.1 IMPLEMENTATION OF MODIFICATIONS ASSOCIATED WITH GENERIC LETTER 96-06,' ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN BASIS ACCIDENT CONDITIONS" (TAC NO. M96792)

Dear Mr. Cruse:

The staff issued Generic Letter (GL) 96 06 on September 30,1996. The pereric letter requested licensees to determine (1) if containment air cooier cooling water systems are susceptible to either waterhammer or two-phase flow conditions during postulated accident conditions, and (2) if piping systems that penetrate the containment are susceptible to thermal expansion of fluid so that overpressurization of piping could occur By letters dated January 28,1997, as supplemented May 2,1997, you submitted your 120 day response to GL 96-06. Ti,e staff is currently performing a detailed raview of your response.

implementing corrective actions to resolve the GL 96-06 issues can have a significant impact on outage schedules and resources. Somo licensces h6ve indicated that it would be prudent to take more time to better understand the specific concems that have been identified in order to optimize whatever actions are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and ongoing efforts that could influence a licensee's decision in plaaning corrective actions include (1) risk implic:tions of installing relief valves to deal with the thermal overpressurization issue, (2) feasibility of using the acceptar,ce criteria contained in Appendix F to Section 111 of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for the permanent resolution of the GL 96-06 issues, (3) ongoing tests by the Electric Power Research Institute to support a generic resolution of the overpressurization of piping issue, and (4) questions regarding the staffs closure of Generic Safety issue 150, "Overpressurization of Containment Penetrations." Ris!: insights and industry initiatives that are being considered or that may be proposed could also influence the course of action that licensees take to resolve the GL 96-06 issues. 'q Licensees are responsible for assessing equipment operability, determining actions, and establishing scheaules that are appropriate for resolving the specific conditions that have been identified. In determining the appropriate actions and schedules for resolv;ng GL 96-06 issues, I g

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licensees should consider, for example, the contir,ued validity of existing operability l determinations, compensatory actions required to maintain operability, the safety significance associated with the specific nonconformances or degraded conditions that have been identified, t

risk insights, and the time required to complete any generic initiatives and/or plant-specific -

l actions (e.g., engineering evaluations, design change packages, material procurement, and i equipment modification and installation). Also, analytical solutions l

9711190193 971107 l PDR ADOCK 05000317

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Charles H. ' Cruse .2-employing the permanent use of the acceptance criteria contained in the ASME Code, Section til, Appendix F (or other acceptance criteria) may present viable altomatives to plant modirmations and can be used where appropriate, justified, and evaluated in accordance with NRC requirements such as 10 CFR 50.5g, as applicable. Licensees may find the revised guidance contained in GL 91 18, "Information to Lloonsees Regarding Two NRC inspection Manual

, Sections on Resolution of Degraded and Nonconforming Conditions and on Operability,"

Revision 1. dated October 8,19g7, helpful in determining appropriate actions and scheduler,.

Although aqustments in schedules may be warranted on the basis of these (and other)

- considerations, specific actions that have been defined and are clearty needed should not be delayed without suitable justification.

it is the staff's current position that licensees can use the ASME Code, Section lil, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe -

supports until permanent actions have been identified and approved by the NRC (as applicable) for resolving the GL 96-06 issues. This guidance supplements the guidance provided by GL 91 18 for resolutbn of the GL 96-06 issues.

-In order to further facilitate resolution of the GL 96-06 issues, the NRC will participate in a public workshop on this topic later this fall. The workshop proceedings will be summarized by the NRC staff and made publicly available. The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

if you choose to revise your commitments for resolving the GL 96-06 issues, you should submit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations discussed above, the current resolution status, and actions

, remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

• If you have any questions, please contact me at (301) 415-3473.

Sincerely, Alexander W. Dromerick, Project Manager Project Directorate 1-1 4 -

Division of Reactor Projects - t/II Office of Nuclear Reactor Regulation 4

Docket No. 50-317

. and 50 318 cc: See next page

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' Mr. Charles H. Cruse - Calvert ' Cliffs Nuclear Power-Plant Baltimore-Gas & Electric Company Unit Nos. I and 2 Cc

President Mr. Joseph H. Walter, Chief Engineer

. Calvert County Board of Public Service Commission of Commissioners Maryland-

'175 Main Street- Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore, MD 21202-6806 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

-Baltimore, MD ~21203 Suite 2102

' Baltimore, MD 21202-1631 Jay E.~Silberg, Esquire

- Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire 2300 N Street, NW Co-Director Washingtc3, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr.-Thomas N.-Pritchett, Director Baltimore, MD 21210-NRM Calvert Cliffs liuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway . NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident Inspector U.S. Nuclear Regu?atory Commission P.O. Box 287

- St. Leonard, MD 20685 Mr. Richard I. McLean, Manager Nuclear Programs Power Plant Research Program-Ma:ylknd Dept. of Natural Resources Tawes State Office Building, 83 Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 e

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November 7, 1997 Charles H. Cruse employing the permanent use of the acceptance criteria contained in the ASME Code, Section Ill, l Appendix F (or other acceptance criteria) may present viable attematives to plant modifications

' and can be used where appropriate, justified, and evaluated in accordance with NRC requirements such as 10 CFR 50.59, as applicable. Licensees may find the revised guidance contained in GL 91 18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability,"

Revision 1, dated October 8,1997, helpful in determining appropriate actions and schedules.

Although adjustments in schedules (my be warranted on the basis of these (and other) considerations, specific actions that have been defined and are clearly needed should not be delayed without suitable justirication.

It is the staffs current position that ticensees can use the ASME Code, Section 111, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and appruved by the NRC (as applicable) for resolving the GL 96-06 issues. This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96-06 issues.

In order to further facilitate resolution of the GL 96-06 issues, 'he NRC will participate in a public workshop on this topi:later this fall. Tho workshop proceedings will be summarized by the NRC staff and made publicly available. The need for additional NRC guidance and generic communication will be considered upon completion of the woishop.

If you choose to revise your commitments for resolving the GL 96-06 issues, you should submit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations discussed above, the current reso!ution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues. .

1 If you have any questions, please contact me at (301) 415-3473.

Sincerely, Original Signed by Alexander W. Dromerick Project Manager Alexander W. Dromerick, Project Manager Project Directorate 1-1 Division of Reactor Projects - t/il Office of Nuclear Reactor Regulation v . Docket No. 50-317 and 50-316 cc: See next page DISTRIBUTION: See next page DOCUMENT NAME: G:\CC1-2\CC96792.LTR sTo receive a copy of this document, indicate in the box: "C" - Copy without attachment / enclosure "E" - Copy with attachment / enclosure "N" - No copy 0FFICE PM: POI Nf\ lE LA:PDI 1 QL l D:PDI1,,d l l l l NAME A6/edti rdt h/rst Slittle N $8ajwa /# M DATE 11// /97 11/ (f/97 11/[,/97 \

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