ML20212H018

Provides Comments on Draft Response to Open Item 3.1.6.3-1

ML20212H018
Person / Time
Site:	Calvert Cliffs
Issue date:	05/18/1999
From:	Stephanie Coffin NRC
To:	Dave Solorio NRC
Shared Package
ML20212G964	List: ML20212G960 ML20212G975 ML20212G985 ML20212G989 ML20212H018 ML20212H024
References
NUDOCS 9909300186
Download: ML20212H018 (1)

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[ David Solorio - BGE response tiOpen it:m 3.1.6.3-1 Pigs 1 From: Stephanie Coffin To: David Solorio k' Date: Tue, May 18,199911:38 AM

Subject:

BGE response to Open item 3.1.6.3-1 You asked me to comment on a draft response to the subject open item...

Auxiliary Feedwater System: Response appears to be committing them to inspection in the 40th year. Is  !

that their plan? Right now the SER does not tie the applicant down to any scheduled date, so the inspection could be performed next week. If the applicant is committed to inspecting near the end of the current operating period, I think the response is reasonable. If they want to perform the inspection next I week (after only 25 years of operation), I think the response needs additional justification.

I Component Cooling System: I don't know why the applicant states in the draft response that " General corrosion of external pipe surfaces is not plcusible for this system." This is not consistent with the LRA.

See for example page 5.3-19,1st paragraph, *Long term exposure to an intemal chemical environment AND POTENTIAL EXTERNAL CORROStVE CHEMICAL ENVIRONMENT may result in general corrosiorvarea materialloss which, if unmanaged, could eventually result in loss of the pressure-retaining I capability under CLB design loading conditions." See also 3rd paragraph, "The effects of general {

corrosion on the CC equipment EXTERIOR surfaces can be r.nitigated through the use of protective l coating and removal of any potentially corrosive materials on component surfaces." Also, the staff finds it difficult to believe that this system is immune from leaking process fluid and potentially corroding external carbon and alloy steel botting. If ARDI is not managing this aging effect, than what is?

Auxiliary Building HVAC: No comments Saltwater System: The staff's comments are NOT in reference to intemal coating degradation of piping. I

, The staff is talking about group 1 components: ' Device types WITHOUT intemal fining subject to crevice I corrosion, general corrosion, MIC, and pitting." On page 5.16-11,6th paragraph, " Crevice corrosion, I k pitting, and/or general corrosion are plausible for metal extemal subcomponent parts (e.g., bolting) that '

may be exposed to leakage of the process fluid." See also page 5.16-12,4th full paragraph, " General I corrosion, crevice corrosion, and pitting are plausible for bolting of the Group 1 components. Although the l botting is not exposed to the process fluid, the potential for leakage of brackish water from the system  !

onto the bolts exists." Also, the staff finds it difficult to believe that this system is immune from leaking process fluid and potentially corroding external carbon and alloy steel botting. If ARDI is not managing this aging effect, than what is?

NSSS Sampling System: No comments SFPC System: No comments s

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