ML20202J227
| ML20202J227 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/02/1999 |
| From: | Dave Solorio NRC (Affiliation Not Assigned) |
| To: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9902090069 | |
| Download: ML20202J227 (10) | |
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REISSUED TO INCLUDE MEETING AGENDA February 2,1999 MEMORANDUM TO: Christopher I. Grimes, Director License Renewal Project Directorate i
Division of Reactor Program Management FROM:
David L. Solorio, Project Manager License Renewal Project Directorate Division of Reactor Program Management
SUBJECT:
FORTHCOMING MEETING WITH BALTIMORE GAS AND ELECTRIC COMPANY (BGE) ON LICENSE RENEWAL FOR CALVERT CLIFFS NUCLEAR POWER Pl. ANT (CCNPP), UNIT NOS.1 AND 2 DATE & TIME:
Wednesday February 10,1999 9:30 a.m. - 12:30 p.m.
LOCATION:
Education Center Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-3845 PURPOSE:
To discuss the age related degradation inspections described in its license renewal application for CCNPP, Unit Nos.1 and 2.
PARTICIPANTS:*
Participants include members of the Office of Nuclear Reactor Regulation (NRR)
N,_R_Q jlGR R. Wessman, NRR B. Doroshuk C. Grimes, NRR et al.
T. Sullivan, NRR K. Manoly, NRR P.T. Kuo, NRR D. Solorio, NRR et al.
Docket Nos. 50417 and 50-318 Atte.chments: 1. Meeting Agenda s
- 2. Potential Open items f-C) cc w/atts: See next page T
T CONTACT:
David L. Solorio, NRR 301-415-1973
- Meetings between NRC technical staff and applicants or licensees are open for interested members of the public, interveners, or other parties to attend as observers pursuant to " Commission Policy Statement on Staff Meetings Open to the Public" 59 Federal Reai:;ter 48340,9/20/94. Distribution Sea next page DOCUMENT NAME:G:\\ WORKING \\SOLORIO\\FEB04MTG.WPD OFFICE LA g
PDLR PDLR:D 3 _
g, NAME SLittlV DSolorio M CIGrimes ( [ f DATE 2/h99 2/ 7_199 2/ 7 /99 OFFICIAL RECORD COPY DOC 050 7
4
-e
4 Distribution.
tjARD COPY Docket Files PUBLIC i
PDLR R/F OGC Mel-Zeftawy Receptionist - OWFN & TWFN DISTRIBUTION: E-Mall RZimmerman (RPZ).
. BBoger (BAB2).
DMatthews (DBM) -
CGrimes (CIG)
TEssig (THE)
JStrosnider (JRS2)
. GHolahan (GMH)
SNewberry (SFN)
GBagchi(GXB1)
RRothman (RLR) 4 JBrammer (HLB)
CGraMon (CXG1)
JMoore (JEM)
MZobler/RWeisman (MLZ/RMW)
SBajwa/ADromerick (SSB1/AXD)
'LDoerflein (LTD)
BBores (RJB)
. SDroggitis (SCD)
. RArchitzel (REA) -
CCraig (CMC 1)
RCorreia (RPC)
RLatta (RML1)
EHackett (EMH1)
- AMurphy (AJM1)
DMartin (DAM 3)
FCherny-MModes WMcDowell(WDM)
SStewart (JSS1)-
THiltz (TGH)
SDroggitis (SCD)
TSullivan (EJS)
' KManoly (KAM)
OPA PDLR Staff Slittle (SSL)
PMNS
Britimora Grs & Electric Company C !v:rt Cliffs Nucl:cr Pow;r Plint i
cc:
Unit Nos.1 and 2 President Mr. Joseph H. Walter, Chief Engineer l
Calvert County Board of Public Service Commission of I
Commissioners Maryland 175 Main Street Engineering Division i
Prince Frederick, MD 20678 6 St. Paul Centre i
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 l
Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Bimie, Esquire 2300 N Street, NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Thomas N. Prichett, Director Baltimore, MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell I
1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 1
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 Nuclear Programs-Douglas J. Walters 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 4
475 Allendale Road Baltimore Gas and Electric Company King of Prussia, PA 19406 Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Mr. Charles H. Cruse, Vice President NEF 1st Floor Nuclear Energy Division Lusby, Maryland 20657 Baltimore Gas and Electric Company 1650 Calvert Cliffs Parkway Lusby, MD 20657-47027
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POTENTIAL OPEN ITEMS RELATED TO AGE-RELATED DEGRADATION INSPECTIONS in its license renewal application (LRA) dated April 8,1998, Baltimore Gas and Electric Company (BGE) provided an outline of proposed one-time inspections in support of its license renewal effort. For 22 plant systems, the licensee relies, in part, on these Age-Related Degradation Inspections (ARDis) to either: (1) verify an age-related degradation mechanism (ARDM)is nonplausible or (2) verify the effectiveness of a separate prevention / mitigation aging management program. The specific ARDI elements are under development on a system by system basis. Some of the system ARDis are complete, some are nearing completion and others are not scheduled to be complete until the end of the year 2000.
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The licensee stated that the scope of an ARDI would typically include a representative sample of l
the system population. Where practical and prudent, the licensee would bias the sample to l
focus on bounding or leading components. The licensee stated that the inspection technique l
would be capable of detecting the effects of aging identified by the aging management review l
(AMR) for that system. Acceptance criteria for these inspections would be consistent with the l
components' ability to perform intended functions in accordance with the current licensing basis l
(CLB) for the period of extended operation. If the ARDI indicates little or no degradation, the l
licensee would conclude that either: (1) the ARDM is not plausible or (2) the preventive / mitigative program is effective. Therefore, no additional aging management activities or programs or changes to existing aging management programs would be required. If the inspection indicates significant degradation, the licensee would implement actions under its existing corrective action program, and the need for additional inspections and/or program enhancements would presumably be considered.
l Although the staff finds the licensee's broad description of the ARDis acceptable, the staff l
cannot draw a conclusion regarding the adequacy of the ARDIs without a more specific description on a system by system basis. The staff attempted to obtain more specific information related to ARDis in its Request for Additional Information (RAI) dated August 28, j
1998. The licensee's response, dated November 12,1998, did not contain the requested i
information. Thus, the staff remains unable to make any substantive findings relative to ARDIs.
In order to demonstrate compliance with 54.21(a)(3), the licensee needs to provide additional information that supports the licensee's position that the ARDis will provide a sound basis for concluding either: (1) a specific ARDM is nonplausible or (2) an existing preventive / mitigative program is effective. The staff requests the licensee provide information relative to two main l
areas: (1) ARDI applicability and (2) system-specific ARDI details. The staff provides a more detailed discussion of these two areas below.
l (1) ARDI Anolicability In general, the licensee picrded enough operating experience and/or design information to support the ufe of one-time ARDis (as opposed to developing a full-blown aging management program). Thie exceptions to this finding exist and are discussed in more detail below.
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in an RAI dated September 3,1998, the staff asked (question 4.1.18): " Clarify whether crevice
. corrosion for the RCS is a plausible aging effect, and, if so, provide a reference to where aging 4
management is addressed in the LRA. If crevice corrosion is not a plausible aging effect for the l
RCS, describe the basis for that conclusion." The licensee replied in a letter dated November 19,1998, " Baltimore Gas and Electric Company has determined that crevice corrosion is not a plausible ARDM for the RCS Crevice corrosion is not plausible because stainless steelis not susceptible to the ARDM in a demineralized water environment." This statement appears to be a contradiction of the licensee's position in at least three other stainless steel systems: Spent Fuel Pool (SFP) Cooling, Chemical and Volume Control System (CVCS), and the Safety injection (SI) System. In all three of these systems, the licensee considers crevice corrosion and pitting of the stainless steelinternals plausible ARDMs. To manage these ARDMs, the licensee relies on its chemistry control programs as well as a confirmatory ARDI. The environment of these systems is nearly identical to the RCS; i.e., demineralized water (and maybe even more benign than the RCS with respect to temperature). The staff does not follow the licensee's logic in dismissing crevice corrosion in the RCS based on demineralized water environment because BGE considers it plausible in the other three demineralized water systems. The staff requests the licensee discuss why crevice corrosion and pitting of the internal surfaces of the RCS components is not considered plausible. In providing the justification for not considering such ARDMs as plausible for the RCS, contrast the RCS component materials and environments with those in the SFP cooling system, the CVCS, and the SI system. Justify the absence of a confirmatory ARDI for the RCS.
Saltwater System in an RAI dated August 28,1998, the staff asked (from question 11.6): " Based upon operating experience, corrosion of Saltwater System components may be likely. Thus, the staff believes a periodic inspection may be more appropriate than a one-time inspection at a future unspecified time...the selection of an ARDI for this case may not be consistent with the purpose of the ARDI.
Please clarify why an ARDI is appropriate for these Saltwater System components." In its response dated November 12,1998, the licensee responded by stating that the " components in question are subject to ' plausible' crevice corrosion, micro biologically-induced corrosion, and pitting (General corrosion is additionally plausible for bolting on some of these components, but this ARDM will manifest itself externally). The materials of construction include red brass,70-30 copper nickel, bronze, stainless steel, and monel. These materials are resistant to most forms of corrosion and are generally expected to undergo no significant degradation in the brackish water environment....The ARDI is expected to verify this conclusion." Without additional information, the staff cannot reach the same conclusion that various materials in the saltwater system will not undergo significant degradation. For example, deep pitting of stainless steels and nickel alloys can occur in quiet seawater as well as in areas with crevice-like conditions.
Carbon steel can corrode at rates of approximately 5 to 30 mils per year depending on water velocity. Fouling of carbon / alloy steels, stainless steels and bronzes occurs in quiet seawater (Corrosion Enaineerina by M.G. Fontana). The staff requests the licensee provide the basis for l
its conclusion that "these materials are resistant to most forms of corrosion and are generally expected to undergo no significant degradation in the brackish water environment." Provide the justification for relying on a one-time ARDI, versus a new program consisting of periodic inspections, for the unlined saltwater system components. Define what is meant by "significant degradation." Provide more details on the saltwater system component materials and the
- saltwater system environment to justify the conclusion that no "significant degradation" is expected. Specifically address how corrosion of the unlined carbon and alloy steel components will be managed. Cicrify the statement that " General corrosion is additionally plausible for bolting on some of these components, but this ARDM will manifest itself externally." How is this ARDM managed?
. Chemical and Vgl.umo Control System For the CVCS, the licensee credits a one-time ARDI to verify that no significant vibration fatigue is occurring. The licensee provided operational experience indicating that vibration fatigue is a plausible ARDM in this system. Without additionalinformation, ths staff finds the use of a one-time ARDI inspection inadequate for vibration fatigue because the licensee has not described
' how the ARDI will detect fatigue damage. The staff requests the licensee provide the details of the ARDI for this system to support its conclusion that a one-time inspection for vibration fatigue is adequate.
(2) System-Soecific ARDI Details The staff requests the licensee provide and justify, for each system and for each ARp__M in thj!t system shown in Table 1, the following inspection details. The licensee should provide operating experience that supports each response, as appropriate The staff notes that only 12 of the 22 systems that have an ARDI are included in Table 1. For these 12 systems, the staff requires the details of the ARDI to complete their review. For the remaining systems, the staff
. plans to rely on a combination of the licensee's general description of the ARDIs as well as the licensee's response to the requested information for the 12 systems to provide the basis for a
" reasonable assurance" finding that the licensee's ARDis for the remaining systems are acceptable.
Inspection Parameters - The licensee has not supplied this information for any ARDI. The parameter inspected should detect the presence and extent of aging effects (e.g., measurement of wall thickness to detect erosion corrosion).
Inspection Scope - The licensee has not supplied how a " representative sample of susceptible
. areas" will be chosen (e.g., those with the most severe geometry, highest flow areas, oldest
- component, etc.).
Inspection Technique - The licensee has not supplied the inspection technique to be applied (e.g., visual, ultrasonic, etc.).
Inspection Schedule - The licensee has not supplied the inspection schedule for the ARDis.
The licensee need not provide specific dates but should indicate relative timing of these inspections and the basis for the timing.
Inspection Acceptance Criteria - The licensee has not supplied this information for the ARDis.
The acceptance criteria should be described (e.g., wall thickness should not show any signs of deterioration) although a specific value (e.g., wall thickness must 2 inches thick) need not be provided. Define what is meant by "significant degradation." The licensee should provide information relative to corrective actions to be taken in response to ARDI results that contradict the licensee's initial assumption. That is, describe through examples the various corrective
9 l action options available if the licensee finds, through the ARDI, that an ARDM is plausible or that a preventive / mitigative program is not effective. Provide level of approval authority required by such corrective actions.
Table 1: Open items Related to ARDis Section System ARDMs 4.1 Reactor Coolant Discuss why an ARDI is not needed for the RCS to verify the eticctiveness of the chemistry control progroms in preventing crevice corrosion and pitting of the intemal surfaces of the RCS components similar to the Chemical Volume and Control System, the Spent Fuel Pool Cooling System, and the Safety injection System.
4.3 Reactor Vessels Intemals Provide the inspection details discussed above for the following ARDMs: stress relaxation (Group 5) of the CEA shroud bolts and core shroud tie rods and bolts and stress corrosion cracking (Group 6) of the CEA shroud bolts.
5.1 Auxiliary Feedwater Provide the inspection details discussed above for the following ARDMs: cavitation erosion (Group 1) of the intemal surfaces of AFW piping; crevice corrosion, general corrosion, 3
and pitting (Group 2) of the intemal surfaces of AFW components; crevice corrosion, general corrosion, and pitting (Group 3) of the normally inaccessible surfaces of AFW components; crevice corrosion, general corrosion, pitting and erosion corrosion (Group 5) of the APN govemor and control valves; elastomer degradation (Group 7) of AFW valves.
5.2 Chemical and Control Justify the use of a one-time ARDI to verify no Volume System significant vibration fatigue is occurring.
Provide the inspection details discussed above for this ARDM (Group 6).
5.3 Component Cooling Provide the inspection details discussed above for the following ARDMs: erosion corrosion (Group 2) of the CC components.
5-Section System ARDMs 5.5 Containment isolation Group Provide the inspection details discussed above l
for the following ARDMs: crevice corrosion, general corrosion, MIC, and pitting of Cl group components exposed to well water (Group 1);
crevice corrosion, general corrosion, and pitting of the Cl group components exposed to treated water or gaseous waste (Group 2).
5.6
. Containment Spray Provide the inspection details discussed above for the following ARDMs: general corrosion, crevice corrosion, and pitting of CS system components.
5.8 Emergency Diesel Generator Provide the inspection details discussed above for the following ARDMs: general corrosion, crevice corrosion, pitting (Group 1) en the internal surfaces of various EDG components, erosion corrosion (Group 3) of the internal surfaces of the EDG cooling water piping and exhaust mufflers; and MIC of the internal surfaces of various EDG cooling water components.
5.9 Feedwater Provide the inspection details discussed above for the following ARDMs: crevice corresion, general corrosion and pitting (Group 1) of FW components; erosion corrosion (Group 3) of 1
motor operated valve bodies and temperature elements.
5.10.
Fire Protection Provide the inspection details discussed above j
for the following ARDMs: crevice corrosion, general corrosion and pitting (Section 5.10.3.11) of the condensate system piping.
5.16 Saltwater Justify the use of a one-time ARDI to verify no l
s gnificant corrosion of saltwater system components is occurring.
Provide the inspection details discussed above for the following ARDMs: crevice corrosion, general corrosion, rnicro biologically induced corrosion (MIC), and pitting of various saltwater system components. These components include unlined piping, valves, temperature indicators, and temperature test points.
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3-Section System ARDMs 5.17 Service Water Provide the inspection details discussed above for the following ARDMs: erosion corrosion (Group 2) of SRW piping.
Discuss how the ARDI applicability evaluation between safety-related and non-safety-related SRW piping will be performed and clarify the basis for the conclusion that the results of the inspection of the safety-related piping are adequately representative of the aging degradation of the non-safety-related piping (see Note 1 below).
Note 1:
In Section 5.17.2 of the LRA, the licensee indicated that the results of the ARDI of the safety-related (SR) Service Water (SRW) system piping will be evaluated for applicability to the non-safety-related (NSR) SRW piping. The LRA also states that the NSR portions of SRW piping and the SR piping were both originally designed to USAS B31.1 and both are subject to the same environmental service conditions and chemistry controls. In addition, the LRA states that the applicability evaluation will consider, at a minimum, flow rate and configuration differences between SR and NSR SRW piping. In RAI 5.17.2, the staff requested that BGE clarify how the flow rate and configuration differences between SR and NSR SRW piping will be considered in the applicability evaluation, and clarify the basis upon which the licensee concluded that the results of the ARDI of the SR piping are adequately representative of the aging degradation of the NSR piping. The licensee responded that the details of how the SR SRW ARDI will be evaluated for applicability to the NSR SRW is part of the ARDI which has not yet been developed. The staff cannot reach a conclusion regarding the acceptability of the licensee's applicability evaluation without these details.
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Meeting Agenda Clarification Renardina 5 Elements of Ane Related Dearadation inspections (ARDI)
(NRC Presentation)
Inspection Parameters Inspection Scope Inspection Technique Inspection Schedule (Duke's approach)
Acceptance Criteria (Operating Experience factored into develcpment of 5 elements)
BGE's Questions and Comments Recardina Presentation and/or Clarification Reauest on ARDI RAI Responses (Attached) 3 Specific Questions Outstandina Related to Use of ARDI for 3 Systems (NRC Presentation)
Reactor Coolant System Saltwater System Chemical & Volume Control System BGE's Questions and Comments
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