ML20205F885
| ML20205F885 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/02/1999 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9904070049 | |
| Download: ML20205F885 (23) | |
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or CHAELES II. CRUSE Baltimon Gas and T~.ectric Company Vice President Calven Cliffs Nuclear Power Plant a
- 14uclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 April 2,1999 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 First Annual Amendment to Aoplication for License Renewal
REFERENCE:
(a) Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated April 8,1998," Application for License Renewal" Reference (a) formrded Baltimore Gas and Electric Company's (BGE's) application for the renewal of the operating license for Calvert Cliffs Nuclear Power Plant Units 1 and 2. Included herein, Attachment (1) provides the first annual amendment to the BGE License Renewal Application (LRA), as required by 10 CFR Part 54.
Attachment (1) covers BGE LRA Attachment (1) Appendix A Chapters 2.1 through 6.4 and Appendix B, Updated Final Safety Analysis Report Supplement, as required by 10 CFR 54.21, " Contents of application - technical information," subpart (b). Attachment (1) also contains changes to the BGE LRA stemming frotn recent interactions with Nuclear Regulatory Commission staff and is arranged by )if Chapter, with the Chapter numbers corresponding to the BGE LRA. Attachment (1) items are categorized as either: (1) Request for additional information clarification; (2) plant modifications; (3) Integrated Plant Assessment changes; or (4) errata. In some ;ases, there were no changes required for a Chapter of the BGE LRA.
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9904070049 990402 l PDR ADOCK 05000317s P PDR j I
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Document Control Desk April 2,1999 Page 2
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. . 1 Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, i STATE OF MARYLAND :
- TO WIT:
. COUNTY OF CALVERT :
I, Charles II. Cruse, being duly swor.i, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am 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 l document are true and correct. To the extent that these statements are not based on my pen. anal i knowledge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company pr etice an I belie to be reliable.
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Aw .w w
y-i Subsefibed and sworn before me, a Notary P blic in and for the State of Maryland and County of (A/ucet ,this 1 day of .<!/ .1999.
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WITNESS my Hand and Notarial Seal: -
Notary Public My Commission Expires: [ MOM D' ate ' !
CHC/RCG/ dim
Attachment:
(1) First Annual Amendment to Application for License Renewal ec: 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. I. McLean, DNR H. J. Miller, NRC J. H. Walter, PSC
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. ATTACHMENT (1) i l
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FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL 1
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Baltimore Gas and Electrie Company Calvert Cliffs Nuclear Power Plant l
April 2,1999 j i
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FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL Chant'er 2.1 Time-Limited Agine Analyses RAI Clarification 2.L1 In response to discussions on Request for Additional Information (RAI) 2.1.1, Containment Liner )
Fatigue, Baltimore Gas and Electric Company (BGE) has provided the following evaluation demonstrating that the current analysis remains valid for the period of extended operation. Since this evaluation demonstrates that the current analysis remains valid for the period of extended operation, no further action or analysis is required for this Time-Limited Aging Analysis (TLAA).
Updated Final Safety Analysis Report Section 5.1.4.3 states that the liner plate was designed with the j following considerations:
l "The best basis for establishing allowable liner plate strains is considered to be that portion of the American Society of Mechanical Engineers (ASME), Boiler & Pressure Vessel (B&PV) Code,Section III, Nuclear Vessels, Article 4. Specifically, the following sections have been adopted as guides in establishing allowable strain limits: 4 Paragraph N-412(m) Thermal Stress Paragraph N-414.5 Peak Stress Intensity Table N-413 Classification of St esses for Some Typical Cases )
Figure N-414 Stress Categories and Limits of Stress Intensity Figure N-415(A) Design Fatigue Curves Paragraph N-412(n) Operational Cycle Paragraph N-415.1 Vessels Not Requiring Analysis for Cyclic Operation American Society of Mechanical Engineers design codes require that the liner material be prevented from experiencing significant distortion due to the thermal load and that the stresses be considered from i a fatigue standpoint [ Paragraph N-412(m)(2)]. The following fatigue loads were considered in the design of the liner plate: l
- a. Thermal cycling due to annual outdoor temperature variations. Daily temperature variations do not penetrate a significant distance into the concrete shell to appreciably change the average temperature of the shell relative to the liner plate. The number of cycles for this loading is 40 cycles for the plant life of 40 years,
- b. Thermal cycling due to interior temperature variations during the start up and shut down of the reactor system. The number of cycles for this loading was assumed to be 500.
- c. Thermal cycling due to the loss-of-coolant accident (LOCA) was taken very conservatively to occur only once during plant life. Thermal load cycles in the piping systems are somewhat isolated from the liner plate penetrations by the concentric sleeves between the pipe and the concrete. The attachment sleeve was designed in accordance with ASME, B&PV Code, Section 111 fatigue considerations. All penetrations were reviewed for a conservative number of cycles to be expected during plant life.
Thermal stresses in the liner plate fall into the categories considered in Article 4,Section III, Nuclear Vessels of the ASME, B&PV Code. The allowable stress in Figure N-415(A) is for alternating stress intensity for carbon steels and temperatures not exceeding 700 F. In addition, the ASME Code further requires that significant distortion of the material be prevented.
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ATTACHMENT (1) t FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL In accordance' with ASME, B&PV Code, Paragraph 412(m)(2), the liner plate is restrained against significant distortion by continuous angle anchors and never exceeds the temperature limitation of 700 F. It also satisfies the requirements for limiting strains on the basis of fatigue consideration. A typical section showing the anchors is include Figure 5-1.
American Society of Mechanical Engineers, B&PV Code, Paragraph 412(n), Figure N-415(A), has been developed as a result of research, industry experience, and the proven performance of code vessels.
Because of the conservative factors it contains on both stress intensity and stress cycles, and its being a part of a recognized design code, Figure N-415(A) and its appropriate limitations have been used as a basis for establishing allowable liner plate strains. Since the graph in Figure N 415(A) does not extend below ten cycles, ten cycles was used for the LOCA instead of one cycle mentioned above.
Establishing an allowable strain based on 10 sig tificant thermal cycles of the LOCA condition would permit an allowable strain [from Figure N-415(A)] of approximately 2%. Maximum allowable tensile or compressive strain has been conservatively set at 0.5% (compared to 2% shown above). The maximum predicted strain in the liner plate during LOCA conditions has been found to be 0.25% compression.
At the design LOCA condition, there will be no tensile stress anywhere in the liner plate membrane.
This is true both at the time of initial pressure release and under any later pressure and temperature condition. The purpose of specifying a non-destructive examination temperature requirement is to provide protection against a brittle fracture or cleavagt mde of failure. However, this type of failure is precluded by the absence of tensile stresses.
No allowable compressive strain value has been set for the test condition because the value will be less than that experienced under the LOCA condition. The maximum allowable tensile strain will be 0.2%
under test conditions; the predicted value is much smaller.
The maximum compressive strains are caused by LOCA pressure, thermal loading prestress, shrinkage, and creep. The maximum calculated strains do not exceed 0.0025 in./in. and the liner plate will always remain in a stable condition."
Using a rnaximum strain of 0.0025 inch / inch (in/in)(which includes LOCA loads), the stress range is found using Hook's law, or:
E=E e
6 Where: E = Young's Modulus = 30 x 10 pounds per square inch (psi) o = Stress, psi e = Strain, in/in From this the stress range for the maximum load state is 75,000 psi. This includes LOCA, pressure, thermal loading pres'ress, shrinkage, and creep. Using 75,000 psi, the number of allowable cyc:es in Figure N-415(A) is in excess of 1,000.
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s l ATTACIIMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL The nu'mber of' cycles required to be considered is as follows: l 1 LOCA (Although 10 were considered because the fatigue curves start at 10) 40 Seasonal changes (40 years) 5DD Heat ups and Cool downs 541 Total This is well below the limit of 1,000 shown above. If the seasonal variations te hangcd from 40 years to 60 years, the total would be 561 cycles. This very conservatively results in the following usage:
No. of Years n N U 40 years 541 1000 0.54 60 years 561 1000 0.56 l l
The above approach is approximate and grossly overestimates the usage for the specified loadings. This is because the stress range for the maximum load case is applied to all load cases. From the large !
difference in severity between load cases (i.e., LOCA vs. normal) this approximation is likely to be l conservative by at least a factor of 10. Regardless, the usage is less than 1.0, which will ensure a leak- l tight containment. The overall impact of the extended period will be less than a 4% change in usage.
Based on the above, it is concluded that the containment liner plate is acceptable for 60 years without consequence.
Chapter 3.1 - Component Supports RAI Clarification .1.L M In response to RAI 3.1.14 as to whether all ring foundations are within the scope of license renewal in the Inservice Inspection Program, concrete ring foundations, by themselves, are not in the Inservice Inspection Program. However, System 036 (Auxiliary Feedwater System - Condensate Storage Tank No 12) and System 37 (Demineralized Water and Condensate Storage System - Condensate Storage Tanks No.11 and No. 21) have their supports inspected as part of the Inservice Inspection Program.
This includes a check for concrete damage in the vicinity of the supports.
Note that Condensate Storage Tank No.12, which is evaluated in System 036, rests on the floor slab of Condensate Storage Tank No.12 Enclosure, which is evaluated in BGE License Renewal Application (LRA) Chapter 3.3D, Miscellaneous Tank and Valve Enclosures. It is included in the Component Support Group - Ring Foundations for Flat Bottom Vertical Tanks, for similarity purposes, because of its tank chairs and anchor bolts.
Errata e Page 3.1-2, in the first line at the top of the page, change the number of component support types from "2F' to "19."
4 Chapter 3.1 A - Piping Secments that Provide Structural Support No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 3.2 - FutWandline Eauipment and Other IIcavy Load IIandling Crancs No changes to this Chapter of BGE LRA are required for the annual amendment.
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1 ATTACIIMENT (1)
F!RST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL Chapter 3.3A - Primary Containment Structure No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 3.3B - Turbine Building Structure No changes to this Chapter of the BGE LRA are required for the annual amendment.
fhapter 3.3C - Intake Structure i
No changes to this Chapter of the BGE LRA are required for the annual amendment. !
Chanter 3.3D - Miscellaneous Tank and Valve Enclosures Errata e Page 3.3D-7, in Table 3.3D-2, the " Post-Installed Anchors" should have a "1" listed versus "NA" under the "AFW Valve Enclosure" column. The " floor gratings" and " stairs and ladders" should have "None" listed versus "5" under the "AFW Valve Enclosure" column.
Chapter 3.3E - Auxiliary Building and Safety-Related Diesel Generator Building Structures l No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 4.1 - Reactor Coolant System IPA Chartggs The stress corrosion cracking /intergranular stress corrosion cracking (SCC /lGSCC) for bolting on Reactor Coolant System (RCS) valves, piping and manway covers has been changed from plausible to not plausible. The reason for this change is that the occurrence of general corrosion on the external surfaces of these device types exposed to boric acid leakage would preclude the initiation of SCC /lGSCC. In addition, SCC /IGSCC in the presence of borated water leakage has only been reported to le a problem in the case of highly loaded steam generator manway studs that have been coated with lubricants containing sulfur. Therefore, SCC /lGSCC is not plausible for the device types listed below:
and the "/(7)" in the SCC row for device types CKV, CV and MOV. ,
1 e Page 4.1-41, remove "manway bolting (alloy steel)" from the PZV paragraph under the Group 7 heading Materials and Environment.
- Page 4.1-42, delete the " primary manway studs (alloy steel)" from the first bullet paragraph (SG HX) at the top of the page. Remove " bolting studs and hex nuts (carbon steel)" from the second bullet paragraph (-CC). Delete the third bullet item (device type -GC), the fourth bullet item (CKV), the fifth bullet item (CV) and the eighth bullet item (MOV). Delete " bonnet studs" from the last bullet item (RV).
- Page 4.1-48, delete the first full paragraph on this page that credits Boric Acid Corrosion Inspection (BACI) Program with discovering SCC /IGSCC on RCS pipe studs / nuts and valve botting.
- Page 4.1-49, delete the fifth bullet that credits the BACI Program for discovering SCC /lGSCC on RCS piping and valve components.
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ATTACIIMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL l
. l e Page 4.'l-53, delete "and SCC /IGSCC (Group 7)" in the last row item (for the BACI Program) under the column heading, Credited As.
As a result of the above change of plausibility for SCC /IGSCC of RCS bolting, RCS-10, " Pressurizer Manway Cover Removal and Installation," is no longer credited for discovering SCC /IGSCC on the pressurizer manway bolting as was sated in Reference (1). The procedure RCS-10 is no longer credited for Chapter 4.1," Reactor Coolant System" of the BGE LRA and should be removed. The IPA Results Changes for Chapter 4.1 of Reference (1) concerning RCS-10 should be deleted from the BGE LRA.
j In Reference (1), Chapter 4.1, it was stated that erosion corrosion of the steam generator internal l supports was not plausible as described in the BGE response to Generic Letter 97-06 (Reference 2) and subsequent supplemental response to Generic Letter 97-06 (Reference 3). However, this response also !
states that no degradation of any kind was found on the steam generator tube support structures.
Therefore, general corrosion for the steam generator internal supports was also determined to be not i plausible. This determination will change the following portions of Chapter 4.1 of the BGE LRA: )
e Page 4.1-34, delete the heading and bullet underneath for " General Corrosion - Internal" in the middle of this page. General corrosion of the steam generator internals is no longer plausible.
Chapter 4.2 - Reactor Pressure Vessels and Control Element Drive Mechanisms / Electrical System RAI Clarification 4.2.6 In response to RAI 4.2.6, on the reactor pressure vessels (RPV) surveillance capsule, BGE will revise the l surveillance capsule withdrawal schedule from 40 to 60 years (48 Effective Full Power Years). The new schedule will include the withdrawal of at least one capsule from each unit that will provide data at a neutron fluence equal to or greater than the projected peak neutron fluence at 60 years (48 Effective Full i Power Years). l If BGE withdraws the last capsule from either RPV prior to year 55, BGE will establish the neutron irradiation environment (fluence, spectrum, temperature, and flux) applicable to the surveillance data and Pressure-Temperature Limits for the affected RPV. If the RPV(s) operates outside these limits, BGE will inform NRC and determine the impact of the condition on the RPV(s) integrity.
If BGE withdraws the last capsule from either RPV prior to year 55, BGE will provide additional dosimetry for the affected RPV.
No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 4.3 - Reactor Vessel Internals System No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 5.1 - Auxiliary Feedwater Syslun Errata The following item was inadvertently left out of Table 5.1-2 in the BGE LRA for Chapter 5.1.
- Page 5-10, add a "/(1)" for " Cavitation Erosion" under device type EB in Table 5.1-2.
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FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL Chanter 5.2 - Chemical and V.olume Control System RAI Clarlucation 7.8 (Resulted in IPA Chances)
In response to RAI 7.8, on how vibration fatigue near the charging pumps is managed, BGE has determined that vibration fatigue is not plausible for the Chemical and Volume Control System charging pumps. This determination is based on the redesign of the charging pump block and piston, pipe routing and pipe supports, which eliminates the possibility of vibration fatigue. The details of the resulting Integrated Plant Assessment (IPA)/LRA changes are provided below.
IPA Changes Baltimore Gas and Electric Company has determined that vibrational fatigue is not a plausible age-related degradation mechanism (ARDM) for the portion of the Chemical and Volume Control System at the charging pumps between the discharge desurgers and the suction stabilizers. SigniGcant modifications have been made to the pumps, piping, and components in this area to greatly reduce the magnitude of the vibration that may have existed and to lessen the effects of any remaining vibratory loading on this part of the system. As a result of these modifications, vibrational fatigue should be removed from Chapter 5.2 of the BGE LRA as described below:
- Page 5.2-12, delete Group 6 (includes the device types subject to vibrational fatigue) from the list of Groups. Change Group 7 (includes the device types subject to stress corrosion cracking) to be the new Group 6.
- Page 5.2-13, remove the "/(6)" from Table 5.2-3 in the row for Fatigue for device types #HC, HV, PUMP and RV. Change "/(7)" in the row for stress corrosion cracking to be "/(6)."
- Page 5.2-33, delete the write-up for Group 6 (device types subject to vibrational fatigue) on this page and pages 34 and 35.
- Page 5.2-35, change Group 7 (device types subject to stress corrosion cracking) to be Group 6 here and on pages 36 and 37.
- Page 5.2-38, change Group 7 to Group 6 in the seventh row of Table 5.2-4 under the column, Credited For. Delete the second paragraph concerning fatigue of Group 6 in the last row of Table 5.2-4 under the column heading, Credited For.
- Page 5.2-41, delete Reference (43) from the reference & .
Errata )
The following Chemical and Volume Control System Intended Function was inadvertently left out of the BGE LRA for Chapter 5.2:
- Page 5.2-6, add the following bullet under the Intended Functions based on the requirements of 10 CFR 54.5(a)(3): l I
= To provide RCS isolation to maintain RCS inventory during a Station Blackout.
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FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL Chanter 5 Component Cooling System IPA Chanees The following changes primarily remove wear as plausible for relief valves and add some additional hand valves to the Component Cooling (CC) System. Because relief valves relieve pressure infrequently, wear is not a significant concern. If these relief valves do leak, it would be readily discovered and corrected prior to an unacceptable breech of the pressure boundary. Therefore, wear of the CC System relief valves is not a plausible aging mechanism.
- Page 5.3-12, remove the "/(6)" for the device type "RV" for wear in Table 5.3-3. Add HV-08 to the list of device types for Refuence 1 at the end of the paragraph under Group 1 (crevice corrosion / pitting)- Materials and Environment.
- Page 5.3-25, delete the third bullet under Group 6 (wear)- Materials and Environment.
- Page 5.3-26, delete the second sentence of the first full paragraph titled " Discovery." Delete the last paragraph on this page.
. Page 5.3-27, delete the last bullet under Group 6 (wear)- Demonstration of Aging Management.
- Page 5.3-28, delete the fourth row item in Table 5.3-4 for PM Checklists MPM012012, MPM01013 and MPM01143.
- Page 5.3-29, delete References 12,13, and 14.
Chapter 5.4 - Comnressed Air Systent Errata The following device type was inadvertently omitted from the BGE LRA Chapter 5.4, Compressed Air System. This device type was scoped, but not subject to aging management review (AMR) because this device type is Active.
- Page 5.4-5, change the "27" to "28" in the second paragraph above the list of device types. Add
" Indicating Lamp" to the list of device types on this page.
- Page 5.4-6, change the number of device types from "27" to "28" in the first sentence after the heading, Device Types Subject to AMR. Change the first word in the first bullet under Device Types Subject to AMR from "Nine" to " Ten" and add " Indicating Lamp" to the list of active device types that were dispositioned in this first bullet.
Chapter 5.5 - Containment Isolation Group No changes to this Chapter of the BGE LRA are required for the annual amendment.
1 Chapter 5.6 - Containment Spray System j IPA Chances ,
Baltimore Gas and Electric Company inadvertently identified the Containment Isolation function for the Containment Spray System as being a passive function when it was actually an active function. Because it is an active function, the components that perform this function are not subject to AMR. The following changes remove these components from AMR in Chapter 5.6.
- Page 5.6-14, remove the words " stainless steel internals for containment isolation CKVs in the !
CS headers" in the second bullet under Group 2 - Materials and Environment; l i
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ATTACHMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL
'Page 5.'6-16, remove the second and third sentences in the second paragraph (Discovery) under Group 2 - Methods to Manage Aging; Page 5.6-17, delete the paragraph at the bottom of the page that continues at the top of the next page;
- Page 5.6-18, delete this page entirely;
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i e Page 5.6-19, delete the first paragraph; l I
e Page 5 6-20, delete the third bullet item;
- Page 5.6-21, delete the fifth row item for CCNPP M-571G-1(2) in Table 5.6-3.
Chapter 5.7 - Diesel Fuel Oil System No changes to this Chapter of the BGE LRA are required for the annual amendment. )
I Chapter 5.8 - Emergency Diesel Generator System j No changes to this Chapter of the BGE LRA are required for the annual amendment. l i
Chapter 5.9 - Feedwater System No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 5.10 - Fire Protection System Errata e Page 5.10-1, replace the second sentence under 5.10.1 - Scoping, to state the following:
"All components required for FP in 26 of these systems are included within their respective {
SR system or structural AMR or in a commodity evaluation, hence they are fully addressed in other Chapters of the BGE LRA."
Chapter 5.11 A - Auxiliary Building Heating and Ventilation System l Errata The following changes reflect the addition of heating and ventilation (II&V) equipment that was inadvertently removed from the scope of the Auxiliary Building il&V System AMR.
- Page 5.ll A-10, in Table 5.11-2, add a "/(2)" under the column for device type DAMP for
" Elastomer Degradation" and " Wear."
I e Page 5.11 A-17, add the words "and preventative maintenance procedures" after the words I
" Routine system walkdowns" in the first sentence of the first paragraph under the title, Discovery."
- Page 5.11 A-18, add the following to the top of the page:
Preventive Maintenance Procram The Calvert Cliffs Nuclear Power Plant (CCNPP) Preventive Maintenance (PM) Program has been established to maintain plant equipment, structures, systems, and components in a reliable ,
condition for normal operation and emergency use, minimization of equipment failure, and I extension of equipment and plant life. The program covers all PM activities for nuclear power 1
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FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL
' plant st'ructures and equipment within the plant, including the Auxiliary Building H&V System components within the scope oflicense renewal. [ Reference 17] Guidelines drawn from industry experience and utility best practices were used in the development and enhancement of this program.
Calvert Cliffs MPM0ll59, inspect / Lubricate Spent Fuel Pool Exhaust Fan Filter Bypass Damper, is currently performed every 6 months with Repetitive Task 00322003, which directs the user to inspect the damper gasket material for signs of deterioration. [ References 18,19] This inspection would discover elastomer degradation and/or wear of the damper seal gasket material if it were occurring. Corrective actions are taken in accordance with the CCNPP Corrective Actions Program.
The plant maintenance program has numerous levels of managemer.t review, all the way down to the specific implementation procedures. For example, there are specific responsibilities assigned to BGE personnel for evaluating and upgrading the PM Program. [ Reference 17] The PM Program has also undergone evaluation by the NRC as part of their routine licensee assessment activities. These assessments and controls provide reasonable assurance that the PM Program will continue to be an effective method of managing the effects of elastomer degradation and I wear for the damper gasket seals. i e Page 5.ll A-18, add the following bullet under the Group 2 Demonstration of Aging Management:
. Existing routine PM activities to periodically inspect the Spent Fuel Pool Exhaust Fan Filter Bypass Dampers will provide reasonable assurance that the effects of elastomer degradation and wear on the damper gasket seals would be detected.
- Page 5.11 A-21, add the following to Table 5.11 A-3:
Table 5.11A-3 AGING MANAGEMENT PROGRAMS FOR TIIE PRIMARY CONTAINMENT II&V SYSTEM Program Credited For Existing CCNPP Preventive Maintenance Program
- Preventive Maintenance Checklist -
Discovery and management of the effects of MPM01159 with Repetitive Tasks elastomer degradation and wear of damper l 00322003 seals (Group 2) e Page 5.11 A-22, add the following to the reference section:
- 17. CCNPP Administrative Procedure MN-1-102," Preventive Maintenance Program,"
Revision 5, September 27,1996 i
- 18. CCNPP Preventive Maintenance Checklist MPM01159," Inspect / Lubricate Spent Fuel Pool Exhaust Fan Filter Bypass Damper," Revision 0, January 08,1992
- 19. CCNPP Repetitive Task 00322003," Inspect / Lubricate i1/12 Spent Fuel Pool Exhaust Fan Charcoal Filter Bypass Dampers" 9
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FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL Chanter 5.11B - Primary Containment Heating and Ventilation System No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 5. llc - Control Room and Diesel Generator Huildings' Heating. Ventilating. and Air Conditioning Systems Errata The device type Radiation Element (RE) was inadvertently left out of the BGE LRA Chapter 5.1 IC. The following errata items correct Chapter 5.1IC of the BGE LRA:
- Page 5. llc-4, add the device type "RE Radiation Element" after "PY Pressure Converter (Relay)"in the list of device types.
- Page 5.11C-6, add the device type " Radiation Element" rder " Hand Valve (1)" in Table 5.11-1.
. Page 5.11C-8, add a column titled "RE" in Table 5.18 C-2 with no check marks since no ARDMs are plausible.
Chapter 5.12 - Main Steam. Steam Generator Blow. lown. Extraction Steam. and Nitrogen and Hydrogen Systems IPA Changes The following changes the program credited for managing aging of main steam isolation valve (MSIV) l components. Baltimore Gas and Electric Company has decided that the existing MSIV-13 program only )
provided valve actuator removal and installation. Instead of this program, BGE has elected to credit existing repetitive tasks that schedule periodic refurbishment of these valve actuators by the vendor.
Additionally another program, MSIV-04, was modified to identify particular subcomponents and ARDMs.
- Page 5.12-12, in the second bullet paragraph under the heading " Component Types Subject to j AMR," replace "the MSIV-13 Refurbishment Program;" with " refurbishment,". '
e Page 5.12-13, in the first paragraph after Table 5.12-1, replace "The MSIV-13 Refurbishment Program (Reference.20] is a PM Program through which the MSIV actuators and their associated
. ." with "The MSIVs are subject to refurbishment. The actuators and their associated . . ."
Also, delete " Reference 20" at the end of this paragraph.
. Page 5.12-16, in " Note 2" under Table 5.12-4, replace ". . . are in the MSIV-13 Refurbishment l Program." with " . . . are subject to refurbishment." l
- Page 5.12-26, add following sentence after the second sentence in the second full paragraph that starts with " Main Steam . . . .":
"The procedure MSIV-4 will be modified to inspect for corrosion of valve body and seating surfaces and to inspect the piston and bonnet."
. Page 5.12-36, replace the word " Existing" with " Modified" in the Status column of Table 5.12-5 for Program MSIV-4 (row 5 of the table). Replace program "MSIV-13, MSIV Actuator Removal and Installation" in row six of Table 5.12-5 with the following existing rep tasks:
"PM Rep Tasks 10832067,10832068,20832062,20832063"
- Page 5.12-38, delete Reference 20.
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FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL Chapter 5.13 - NSSS Sampline System No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 5.14 - Radiation Monitorine System IPA Changes I It was determined by BGE that the pump in this Chapter of the BGE LRA is subject to periodic replacement, and therefore, not subject to an AMR. The following changes are applicable to Chapter 5.14 of the BGE LRA:
- Page 5.14-10, delete the words "and pump" in the second sentence of the " Note" at the bottom of this page. Add the following sentence to the end of the Note:
" Pump is subject to periodic replacement."
- Page 5.14 * ' add the following bullet under the heading " Components Subject to Replacement":
e " Control Room Ventilation Radiation Monitor - the pump shown in Figure 5.14-7 is subject to a maintenance replacement program. The entire pump is replaced every 48 weeks."
- Page 5.14-13, delete the words "and pump" in the first sentence of the second bullet. Replace the word "are" with "is" after " Figure 5.14-7" in the second sentence of the second bullet. Delete "030 PUMP 01" in the references at the end of the first paragraph Chapter 5.15 - Safety Inlection System Errata e Page 5.15-30, revise the first sentence in the first paragraph to read as follows:
"Since the SI System vent / drain / test HVs, instrument isolation HVs, and RVs, connected to the piping in Group 4 are outside of the main process flowpath, they do not experience the large temperature gradients that would be necessary to cause significant degradation."
Chanter 5.16.. Saltwater System RAI Clarification 11.6 In response to RAI 11.6, on inspection of BGE LRA Chapter 5.16 Group 1 saltwater (SW) bolting (low alloy and carbon steel), BGE has elected to credit MN-1-319, Systems and Structures Walkdowns, instead of the Age-Related Degradation Inspection (ARDI) Program to inspect the SW System bolting for signs of general corrosion. Refer to Chapter 3.3A, Primary Containment Structure, Group (2) -
Corrosion of Steel - Aging Management Programs (page 3.3A-21), for a complete discussion of MN-1-319.
IPA Changes Based on revised results for the SW System, BGE has determined that erosion corrosion is not plausible for the SW System check valves and SW inlet to the CC heat exchanger. The previous damage to these components that was thought to be erosion corrosion was in fact general corrosion resulting from damage to the SW System internal lining / coating. Because of this finding, the Staff should disregard the IPA Results Changes applicable to Chapter 5.16, SW System, that were submitted in the document, 11
s e
ATTACHMENT (1)
FIRST ANNUAL A?"ENDMENT TO APPLICATION FOR LICENSE RENEWAL
" Changes to tlie Application for License Renewal," dated February 4,1999. In its place, the following change should be made to Chapter 5.16 of the BGE LRA:
Page 5.16-10, in Table 5.16-3, add a "/(2)" under the column for device type CKV for " General Corrosion" Plant Modification Chapter 5.16 is amended to account for the replacement of CCNPP Unit I service water (SRW) heat exchangers. The new Unit 1 SRW heat exchangers are a plete and frame type heat exchanger, which is different from the previous tube and shell heat exchangers. The Unit 2 SRW heat exchangers are scheduled to be replaced with plate and frame heat exchangers during the 1999 Unit 2 refueling outage.
This change to the Unit 2 heat exchangers will be documented in the next BGE LRA annual amendment update, e Page 5.16-6, add the following device types to Table 5.16-1 to account for new equipment added during the Unit 1 SRW heat exchanger replacement:
Device Code Device Description AVV Auto Vent Valve FE Flow Element FIC Flow Indicating Controller P/P Pneumatic Amplifier ZC Positioner
. Page 5.16-7, change the number of device types in the first sentence under the heading " Device Types Subject to AMR" from "40" to "45." Change the number of device types in the last paragraph from "20" to "25."
- Page 5.16-8, add the following device types to Table 5.16-2 to account for new equipment added j during the Unit 1 SRW heat exchanger replacement: !
Device Code Device Description AVV Auto Vent Valve ,
FE Flow Element FIC Flow Indicating Controller
{
P/P Pneumatic Amplifier I ZC Positioner l l
- Page 5.16-10, add the following device types and associated ARDMs where applicable:
]
Note: There are no plausible ARDMs for the device types FIC, P/P, and ZC. .
l I
i 12 1
1 ATTACHMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL TABLE 5.16-3-continued
. POTENTIAL AND PLAUSIBLE ARDMs FOR THE SW SYSTEM (new device types) !
I Potential ARDMs Device Types AVv- IE HC P!P ZC Cavitation Corrosion Corrosion Fatigue j Crevice Corrosion /(1) /(1)
Dynamic Loading {
i Elastomer Degradation j Electrical Stressors I Erosion Corrosion l Fatigue Fouling Galvanic Corrosion General Corrosion liydrogen Damage Intergranular Attack Microbiologically-Induced /(1) /(1)
Corrosion (MIC)
Oxidation Particulate Wear Erosion Pitting /(1) /(1)
Radiation Damage Saline Water Attack Selective Leaching Stress Conosion Cracking Thermal Damage Thermal Embrittlement Wear l
/ indic.-?cs plausible ARDM determination l
(#)- indicates the group (s) in which the ARDM/ device type combination is evaluated e Page 5.16-11, add the device types "AVV" and "FE" to the first sentence under the Group i heading, Materials and Environment, and include the device types "AVV-01/02," "FE-01" and "CV-06/07" in Reference 1 at the end of the second paragraph. Delete device types "HV-01/07" in Reference 1.
- Page 5.16-11, add the materials " cast bronze" and " cast brass" to the list of materials in the last paragraph under the Group I heading, Materials and Environment.
- Page 5.16-13, add the device types "AVV-01/02," "FE-01," "CV-06/07," and delete "HV-01/07" in Reference 1 at the end of the second paragraph under the Group I heading Aging Management Program (s) that is listed as Discovery.
- Page 5.16-14, add the device type "BS-02" and delete "CV-04" in Reference 1 at the end of the second paragraph under the Group 2 heading, Materials and Environment.
- Page 5.16-17, delete device type "CV-04" from Reference 1 under the Group 2 heading, Aging Management Program (s) that is listed as Discovery.
- Page 5.16-17, add the device type "BS-02" to Reference 1 for the second paragraph under the Group 2 heading, Aging Management Program (s).
13
4 ATTACIIMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL
- 'Page 5.'16-19, delete the fifth bullet paragraph.
- Page 5.16-19, change "PM checklists MPM04004 and MPM04144" to "PM checklist MPM04194" in the first sentence of the second bullet paragraph. In t':e second sentence of the same paragraph, delete "MPM04004 is performed every 12 weeks and" and in the third sentence change "These checklists include" to "This checklist includes",
e Page 5.16-19, change the third bullet paragraph to the following:
e
" Management of crevice corrosion, galvanic corrosion, MIC, and pitting for SW pump j discharge check valves (device type CKV) to carried out by periodic overhaul through Repetitive Tasks 10122086,10122087,10122088,20122092,2011093, and 20122094. They are overhauled on a six-year frequency that will identify any degradation of the pressure ,
boundary and take corrective actions to repair any deficiencies discovered. [ Reference 1, Attachments 1 and 8 for Group ID CKV-02]" f
- Page 5.6-19, change the last bullet paragraph to the following:
- " Management of crevice corrosion, galvanic corrosion, general corrosion, MIC, and pitting of the hand valves (device type HV) that provide the path to the circulating water discharge conduits is carried out by periodic inspection through Repetitive tasks 10122068 and 20122072 and ultrasonic testing through PM Checklists MPM01180 and MPM01181. These activities are performed during refueling outages to verify that degradation is not occurring and to take corre.ti re actions to repair any deficiencies discovered. [ Reference 1, Attachments I and 8 for Group ID llV-04; Reference 2; Reference 12, Table 2]"
- Page 5.16-19, add the following bullet paragraph to the page:
e " Management of crevice corrosion, galvanic corrosion, general corrosion, MIC, pitting, and elastomer degradation for Unit 1 SRW heat exchanger basket strainers (device type BS) is carried out by periodic inspection and testing through Repetitive Tasks 10122107,10122108, 10122109, and 10122110. They are performed every 48 weeks and include steps to inspect i for signs ofleakage and degradation and to verify the integrity of the liner. These activities
{
detect degradation of the pressure boundary or bolting, and corrective actions are taken to {
repair any deficiencies discovered. [ Reference 1, Attachments 1 and 8 for Group ID BS-02]" !
- Page 5.16-23, add the device type "IlX-03" to Reference 1 of the second paragraph under the Group 4 heading, Materials and Environment. Add the following paragraph to the bottom of this Page:
"The Unit 1 SRW tube and shell heat exchangers were replaced with plate (titanium) and frame heat exchangers during the 1998 Unit I refueling outage. This Chapter includes aging management review for both the new heat exchangers and the older models that still exist on j Ur.it 2. The Unit 2 SRW heat exchangers will be replaced with these newer plate and frame l I
heat exchangers during the 1999 Unit 2 refueling outage."
e Page 5.16-24, add the following table under the existing Table 5.16-4 to account for the new Unit 1 SRW plate and frame heat exchangers:
14
1 ATTACHMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL TABLE S.16 Continued CCNPP UNIT 1 SRW IIEAT EXCilANGERS(new)
Subcomponent Part Material . Environment Plausible ARDMs crevice corrosion Frame / Pressure Plate Carbon Steel external to process fluid general corrosion pitting Plates TitanNm SW none crevice corrosion Bolts Alloy Steel external to process fluid general corrosion pitting {
crevice corrosion Nuts Carbon Steel external to process fluid general corrosion pitting SW Connection Liner Titanium SW none SRW Connection Liner l
Stainless Steel SRW crevice corrosion '
pitting
- Page 5.16-27, add the following sentence to the end of third paragraph (titled Discovery):
"The ARDI Program will also be credited with discovering crevice corrosion, general corrosion and pitting for the frame and plate heat exchangers." l
- Page 5.16-27, delete Repetitive Tasks "10112052" and "10112053" from the second bullet paragraph (6th paragraph on the page) under Discovery which credits the repetitive tasks with cleaning and inspecting the heat exchangers.
- Page 5.16-28, add the following new bullet paragraph after the third bullet:
- "For the new plate and frame heat exchangers, the ARDI Program will conduct inspections of I a rg w:sentative sample of susceptible areas to discover signs of degradation, and will contain acceptance criteria that ensure corrective actions will be taken such that the heat exchangers remain capable of performing their passive intended functions under all CLB conditions."
- Page 5.16-34, delete Repetitive Tasks "10112052" and "10112053" from the fifth row of Table 5.16-5 under the Programs column.
- Page 5.16-34, make the following changes to the third row o Table 5.16-5:
Add the following Repetitive Tasks to the listed items:
"10122086 through 10122088;"
"10122107 through 10122110;"
"20122092 through 20122094;'
- Change the list of checklists to:
"MPM04194; MPM0ll80; and MPM0ll81"
- Page 5.16-35, add the words, "and susceptible areas of the Unit I plate and frane heat exchangers," at the end of the third paragraph under the column heading, Credited For.
15
y-
)
ATTACIIMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICAl' ION FOR LICENSE RENEWAL Chapter 5.17 I Service Water System BAI ClariReation 117.2 on Non-Safety Related SR W Pinine: (Resulted in an IPA Chance)
In response to the RAI on non-safety-related portions of the SRW System, BGE now includes non-safety-related portions of the Turbine Building SRW System piping as within the scope of license renewal and will include those portions in the ARDI Program j I
Therefore, on page 5.17-18, delete the enond paragraph under " Discovery" and replace with "To ensure
{
that the non-safety-related Turbine Building SRW piping maintains its seismic adequacy, the SRW j ARDI for erosion corrosion will include the non-safety-related piping serving Turbine Building loads." '
Chapter 5.18 - Spent Fuel Pool Cooling System No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 6.1 - Cables 1
Clarification on Elec1rical Connectors l In response to NRC staff verbal questions on how electrical connectors and splices were dispositioned during the IPA process, .BGE has provided the following response:
Splices and connectors are subcomponents of the CCNPP cabling system. As such they are not components subject to scoping. However, they were considered during the aging management review process.
No plausible aging was found for splices except for splices local to 4kV motors. This is discussed in Chapter 6.1 of the BGE LRA under Group 4 - Thermal aging for ethylene-propylene-rubber (EPR) non-environmentally qualified (EQ) cables in power service, associated with the SW System and SRW System 4kV pump motor terminations.
No plausible aging was found for non-EQ connectors. The environment for connectors on panel or rack-mounted drawers is limited by the associated electronics. This is considered a non-stressful environment for the associated connectors. Connectors on transmitters are recognized as a subcomponent of an excluded device, and as such were given no further attention.
The information on sp! ices and connectors is contained and available for review in the onsite Cables Aging Management Repo.t.
IPA Changes There are several changs to the BGE LRA Chapter on Cables. These changes are described below. The most notable change was the removal of " treeing" (Group 6 in Chapter 6.1) as a plausible aging mechanirn. The changes are as follows:
e Page 6.1-2, add the following sentence to the top of this page:
"The exception is the polyolefin insulated wiring in motor control centers that are subject to plausible thermal degradation. See Chapter 6.2 of the LRA for further discussion."
16
t 3
ATTACllMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL e 'Page 6.'l-4, under the notes for Table 6.1-1, add "all but (2)" after "All polyvinyl chloride and" in the first sentence ofitem 1. Add the following sentence to the end ofitem 1:
e "The Teflon insulated cables r.re not subject to plausible aging."
e Page 6.1-6, delete Group 6 for treeing of EPR non-EQ cables in 4kV power service.
- Page 6.1-7, delete Group 6 as plausible for treeing of EPR cables in Table 6.1-2. Put an (x) in the Not Plausible column for the row entitled Treeing. Delete Group 6 line item in the description of groups under Table 6.1-2.
- Page 6.1-11, replace the first sentence of the last paragraph entitled Discovery with the following sentence:
"To manage the effects of thermal aging for the Group 1 cables, a new plant program was developed to assess the upper limit on Group 1 cable service temperatures."
e Page 6.1-12, add "The program has been completed." after the sentence at the top of the page.
- Page 6.1-12, replace the two-sentence header for bulleted list with the following:
"The cables ARDI Program included the elements listed below."
e Page 6.1-12, delete the word "(Completed)" from the end of bullet Items 1,2 and 3. Delete the wocds "(Partially Completed)" from the end of bullet Items 4 and 5.
- Page 6.1-12, add the following sentence to the end of bullet item 6:
"The limiting case was found to be 2TE19 in which the highest peak, average, and median temperatures were recorded."
e Page 6.1-12, replace bullet item 7 with the following:
" Determining the bounding annual equivalent cable service temperature for Group 1 cables.
An annual equivalent temperature was developed for EPR and crosslinked polyethylene (XLPE) insulation using the 2TE19 data and the methodology from Electric Power Research Institute Report TR-100516. The EPR case was limiting and yielded the highest annual equivalent temperature. This temperature was less than 149 F including a 17 F temperature rise through the insulation."
- Page 6.1-12, replace bullet item 8 with the following:
" Determining if ongoing aging management is required for Group 1 cables by comparing the bounding annual equivalent temperature to the 60-year service limits. A 35 F margin exists between the limiting case (149F) and the 60-year service limit for EPR (184 F) (184 F -
149 F = 35F)."
e Page 6.1-13, delete the first three paragraphs on this page and add the following sentence to the top of the page:
"No ongoing aging management of Group I cables is required."
- Page 6.1-13, replace the third bullet item under Group 1, Demonstration of Aging Management, with the following:
"The CCNPP Cables ARDI Prog am determined that no ongoing aging management of
) Group 1 cables is required since service temperatures are well below the 60-year service limiting temperatures."
17
-r i
e ATTACIIMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATIO. . LICENSE RENEWAL e Page 6.'l-13, replace the last paragraph under Group 1 cables with following:
"Therefore, tl.e effects of thermal aging of Group I cables will not prevent the functi ) of preventirg or isolating faults in an electrical circuit, consistent with the CLB, during the period of extended operation."
- Page 6.1-14, add,"The maximum design ambient temperature for Group 2 cables is 123 F." to the end of the second paragraph. Change the 160 F temperature in the third paragraph to 123 F.
Page 6.1-15, replace the first sentence of the last full paragraph [ Discovery], with the following sentence:
"To assess the effects of thermal aging for the Group 2 cables, a new plant program was developed."
- Page 6.1-15, delete the word "will" from the last sentence.
- Page 6.1-16, replace the second sentence in the third bullet with the following:
" Corrective action is replacement of the Group 2 cables subject as plausible aging before the period of extended operation unless one of the following alternatives are deemed viable and preferable."
e Page 6.1-16, delete item 6 under bullet item 3. Delete both paragraphs after the item 6 in bullet three. Replace the paragraph after the two deleted paragraphs above (starts with corrective actions) with the following:
" Replacement of Group 2 cables found subject to plausible aging before the period of extended operation will ensure that the Group 2 cables remain capable of performing their intended function to prevent or isolate faults in an electrical circuit under all CLB conditions."
- Page 6.1-17, replace the third bullet item under Group 2, Demonstration of Aging Management, with the following:
" Group 2 cables subject to plausible aging will be replaced before the period of extended operation such that there is reasonable assurance that the prevention or isolation of faults in an electrical circuit will be maintained."
- Page 6.1-17, replace the third sentence in the last paragraph with the following:
"There are no Teflon insulated Group 3 cables associated with cable schemes that support any license renewal functions.
- Page 6.1 19, delete the second paragraph (under Discovery), the Cables ARDI Program below it (with five bullet items) and the two paragraphs immediately fo"owing the Cables ARDI Program description and replace it with the following:
"Discoverv: Screening criteria we.s used to identify any cables that are potentially sabject to synergistic radiative and thermal aging. Any power cables that satisfied all of the following criteria are considered subject to plausible aging:
- Inside containment;
- Insulated with EPR or XLPE;
- In scope of License Renewal; e Not environmentally qualified (EQ).
I8
)
l ATTACHMENT (1) j FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL 1
e 'Page 6.'l-19, replace the last paragraph with the following:
"The replacement of Group 3 cables before the period of cxtended operation will ensure that the cables remain capable of performing their intended function to prevent or isolate faults in an electrical circuit under all CLB conditions."
Page 6.1-20, replace the third bullet item under Demonstration of Aging Management with the following:
" Group 3 cables will be replaced before the period of extended operation such that there is reasonable assurance that the prevention or isolation of faults in an electrical circuit will be maintained."
- Page 6.1-28, change the third row, second column in Table 6.1-3, to read " Cables Replacement r ro gram." Change the third row, third column in Table 6.1-3 to the following:
" Management of the effects of plausible aging for:
Group 2 (EPR/XLPE non-EQ cables in power service, routed with maintained spacing)
Group 3 :5"7/XLPE non-EQ cables in power service, routed inside containment)"
Chapter 6.2- - Electrical Commodities IPA Changes Due to the extent of changes to this Chapter of the LRA, BGE has elected to replace the existing LRA Chapter 6.2 with a revised Chapter 6.2 for Electrical Commodities. This replacement for the existing Chapter 6.2 contains 6 nges to the programs credited for managing aging of the electrical panels. The plausibility of aging mechanisms has not changed for Chapter 6.2, only the programs credited with managing aging of the electrical panels. Some of the panels were also moved to different groups within the LRA. A description of the changes to this Chapter and the new Chapter were previously included in the References (1) and (4).
Chapter 63 - Environmentally Oualified Equipment No changes to this Chapter of the BGE LRA are required for the annual amendment.
Chapter 6.4 -Instrument Lines No changes to this Chapter of the BGE LRA are required for the annual amendment.
Appendix B - Updated Final Safety Analysis Report Supplement No changes to this Chapter of the BGE LRA are required for the annual amendment.
REFERENCES
- 1. Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated February 4,1999,
" Changes to the Application for License Renewal"(Chapter 6.2) l 2. Letter from Mr. C. IL Cruse (BGE) to NRC document Control Desk, dated March 31,1998,
" Response to NRC Generic Letter 97-06: Degradation of Steam Generator Internals" 19
1 1
6 ATTACHMENT (1)
FIRST ANNUAL AMENDMENT TO APPLICATION FOR LICENSE RENEWAL l
3.' ' I tte'r from Mr. C. H. Cruse (BGE) to NRC document Control Desk, dated November 9,1998,
" Supplemental Response to NRC Generic Letter 97-06: Degradation of Steam Generator Internals"
- 4. Letter from Mr. C. H. Cruce (BGE) to NRC Document Control Desk, dated March 12,1999,
" Revision 1 for License Renewal Application Section 6.2, Electrical Commodities" I
l 20