ML20216A849

Forwards RAI for Review of Calvert Cliffs Nuclear Power Plant,Units 1 & 2,integrated Plant Assessment Report for Diesel Fuel Oil Sys

ML20216A849
Person / Time
Site:	Calvert Cliffs
Issue date:	02/19/1998
From:	Dave Solorio NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
TAC-M95457, TAC-M95458, TAC-M99180, NUDOCS 9803120343
Download: ML20216A849 (7)

Text

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[ j UNITED STATES l

g NUCLEAR REGULATORY COMMISSlON 2 WASHINGTON, D.C. 20566-0001

%, # February 19, 1998 i

l Mr. Charles H. Cruse, Vice President Nuclear Energy Division Baltimore Gas & Electric Company 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-47027 l

l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 & 2, INTEGRATED PLANT ASSESSMENT REPORT FOR THE DIESEL FUEL OIL SYSTEM (TAC NOS. M95457, M95458, M99180)

Dear Mr. Cruse:

By letter dated May 23,1997, Baltimore Gas and Electric (BG&E) submitted for review the Diesel Fuel Oil System (5.7) technical report as attached to the " Request for Review and

, Approval of System and Commodity Reports for License Renewal." BG&E requested that the Nuclear Regulatory Commission staff review the Diesel Fuel Oil System technical report to determine if the report meets the requirements of 10 CFR 54.21(a), " Contents of application-technical information," and the demonstration required by 10 CFR 54.29(a)(1), " Standards for I issuance of a renewed license," to support an application for license renewalif BG&E applies in the future.

As requested, the staff reviewed the Diesel Fuel Oil System (5.7) technical report against the requirements of 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(3). By letter dated April 4,1996, the staff approved BG&E's methodology for meeting the requirements of 10 CFR 54.21(a)(2).

Based on review of the information submitted, the staff has identified in the enclosure, areas where additional information is needed to complete the review.

i Please provide a schedule for the submittal of your responses within 30 days of the receipt of l this letter. Additionally, the staff would be willing to meet with BG&E prior to the submittal of the responses to provide clarifications of the staff's requests for additional information.

S'incerel ,

a T)'o David (. Solorio, Project Manager License Renewal Project Directorate 9803120343 980219 Division of Reactor Program Management PDR ADOCK 05000317 Office of Nuclear Reactor Regulation P PDR

Enclosure:

As stated Docket Nos. 50-317, 50-318 cc: See next page D. Walters, NEl

~

h Mr. Charles H. Cruse, Vice Pr:sid:nt Nucl=r En:rgy Division bCN E 10 Baltimoro G:s & El ctric Company 1650 Calvert Cliffs Parkway

[, { ON ,

l Lusby, Maryland 20657-47027  !

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 & 2, INTEGRATED PLANT ASSESSMENT REPORT FOR THE DIESEL FUEL OIL SYSTEM (TAC NOS. M95457, M95458, M99180)

Dear Mr. Cruse:

By letter dated May 23,1997, Baltimore Gas and Electric (BG&E) submitted for review the Diesel Fuel Oil System (5.7) technical report as attached to the " Request for Review and Approval of System and Commodity Reports for License Renewal." BG&E requested that the Nuclear Regulatory Commission staff review the Diesel Fuel Oil System technical report to determine if the report meets the requirements of 10 CFR 54.21(a), " Contents of application-technical information," and the demonstration required by 10 CFR 54.29(a)(1), " Standards for issuance of a renewed license," to support an application for license renewalif BG&E applies in the future.

As requested, the staff reviewed the Diesel Fuel Oil System (5.7) technical report against the requirements of 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(3). By letter dated April 4,1996, the staff approved BG&E's methodology for meeting the requirements of 10 CFR 54 ?1(a)(2).  !

Based on review of the information submitted, the staff has dentified in the enclosure, areas where additional information is needed to complete the review. {

Please provide a schedule for the submittal of your responses within 30 days of the receipt of this letter. Additionally, the staff would be willing to meet with BG&E prior to the submittal of the responses to provide clarifications of the staff's requests for additionalinformation.

Sincerely, )

] original signed by ]

David L. Solorio, Project Manager '

License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation M

Enclosure:

As stated  !

h N Docket Nos. 50-317,50-318 cc: See next page Distribution:

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DOCUMENT NAME:G:\ WORKING \SOLORIO\DFO_RAl.LTR

• SEE PREVIOUS CONCURRENCE To receive e copy of this document, ind;cete in the boa: %y:

"C" = Copy without enclosures *E" = Copy wdh enclosures *N" = No copy ~~

OFFICE PDLR:TR l PDLR.PL l r'DLR:SC DE l l DSSA l PDLR.D l NAME SLEE DSolorio ACS, , PTKuo GBagchi TMarsh CGrimes DATE 02/12/98* 02/12/98* 4/g/t ? 02/12/98* 2/12 /98* 2/13 /98* 02/19/98*

' OFFICIAL RECORD COPY 2 ,,, t ' 'I O

9.

Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos.1 and 2 President Mr. Joseph H. Waiter, 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 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. Donateli 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. Richard I. McLean Nuclear Programs Power Plant Research Program Maryland Dept. of Natural Resources Tawes State Office Building, B3 Annapolis, MD 21401 Regional Administrator, Region i U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 l

6 REQUEST FOR ADDITIONAL INFORMATION CALVERT CLIFFS NUCLEAR POWER PL/,NT UNIT NOS.1 AND 2 SYSTEM AND COMMODITY REPORTS FOR LICENSE RENEWAL 5.7 - DIESEL FUEL OIL SYSTEM 1.

Page 5.7-1 of the report describes the diesel fuel oil (DFO) system. Please provide a discussion of the pipe sizes within the system and whether corrosion allowances were provided in the piping design.

2.

Page 5.7-1 of the report indicates that the DFO system is a Seismic Category I system.

Figure 5.7-1 of the report indicates that certain portions of piping up to the isolation valves are within the scope of license renewal but the piping downstream of the isolation valves up to the next anchor are not within scope. Under the current licensing basis (CLB) the entire pipe run, which includes the associated pipe and the next anchor downstream from the isolation valves, should have been analyzed by the Baltimore Gas and Electric Company (BG&E) to determine that the piping could withstand design basis event loads, such as a seismic event. If there is a failure in the remainder of the pipe run or the associated piping anchors, the identified portions of the piping may not be able to perform their intended function under CLB design conditions. Did the BG&E piping analysis under the CLB analyze the pipe segments from the downstream anchors to the upstream anchors of the isolation valves in a single analysis? If so, explain how the piping between the isolation valves and the downstream anchor points wil! be appropriately addressed for renewal.

3.

Page 5.7-2 of the report describes the DFO system. However, he report does not identify a non-safety related line from the No. 21 fuel oil storagr tank (FOST) identified in the Final Safety Analysis Report (FSAR) Section 8.4.1.2. fc:cifically, page 8.4-7 of ,

the FSAR contains a statement that indicates that the enclosure for the No. 21 FOST "also acts as a dike for No. 21 FOST with fuel being supplied by way of a non-safety related line." BG&E, in its February 14,1997, response to the staff's request for additional information (question number 17), stated that the non-safety related building drain line for the No. 21 FOST is not within the scope of license renewal because it is not on the "Q-List." Please explain whether this line is relied upon to remain functional during and following any design basis events to ensure any of the intended functions delineated by the license renewal rule (10 CFR 54.4(a)(2)). Since this line is designated to be used to supply the diesel generators in the event of No. 21 FOST rupture, explain whether the rupture of the FOST is postulated to occur as a result of any design basis event that would also require diesel generator operation (via No. 21 FOST).

In addition, page 5.7-3 of the report indicates that the non-safety related line from No.

21 FOST to diesel generating room waste oil collection tank No.11 is not within the scope of license renewal. Discuss whether there is a potential for draining No. 21 FOST if the non-safety related line should rupture, and if there are any isolation valves in the line. If there are isolation valves in the non-safety related line, discuss whether the i

Enclosure

I valves and associated upstream piping are within the scope of license renewal.

4.

Page 5.7-2 of the report discusses operating experience with the DFO system regarding aging effects. The report indicates that the DFO system has "in general, performed l

well." However, later on in the report, on Page 5.7-19, an outstanding site " Issue Report" on the degradation of caulking and sealants which could affem the FOST was mentioned. Provide additional plant-specific operating experience related to the aging effects applicable to the DFO system. Also, discuss any NRC generic communications i

and other industry experience related to aging that are applicable to the DFO system.

l Further, the report indicates that the No. 21 FOST was inspected during the 1997 refueling outage. Please provide information on the results of that inspection.

5. Page 5.7-2 of the report "escribes the DFO system. Discuss whether the DFO system is partially supported by the diesel generator building and foundation, and identify where these structures will be evaluated for license renewal.

6. Page 5.7-6 of the report indicates that BG&E may elect to replace components for which the aging management review identifies further analysis or examination is needed.

BG&E also indicates that the replacements would not be subjet *o an aging management review for license renewal. The license renewal rule excludes aging management review for replacements which are based on a qualified life or specified time period. However, replacing components based on their condition or performance is not a br.,is for excluding components from an aging management review. The condition or pedormance monitoring program, including replacements, is considered an aging management program for license renewal. Please identify the structures and components that will be replaced and therefore excluded from an aging management review for license renewal.

7. Page 5.7-6 of the report indicates that an electrical fuse has only active functions and is not subject to an aging management review for license renewal. The component-level intended function of fuses to provide continuity has been determined by the staff to be passive, as described in the letter to the Nuclear Energy Institute, dated September 19, 1997. Explain how BG&E intends to address aging management for fuses.

8. Table 5.7-1 (Page 5.7-7) in the report indicates that the FOST for the new emergency diesel generator (EDG) is not included in this technical report. Please identify in which report the FOST and supporting components for the new EDG will be addressed for license renewal. If BG&E has determined that this FOST and supporting components are not within the scope of license renewal, provide the justification for that determination and describe the extent to which the new EDG is relied upon to satisfy the station blackout rule.

9. Pages 5.7-10 and 5.7-19 of the report describe plant procedures MN-3-100, " Paint and ,

Other Protective Coatings," PEG-7, " System Walkdown," and OL-2-100, *lssue  !

Reporting and Assessment Procedure," for managing aging of the Group 1 and 4 '

components, respectively, for license renewal. Please expand on the summary description for PEG-7 and provide summary descriptions for MN-3-100 and OL-2-100.

l Enclosure

I The summary descriptions should provide information addressing the specific elements described in Subsection ll.C of Section 3.0 of the working draft standard review plan for license renewal (SRP-LR) dated September,1997. For example, the summary description should include briefinformation on the operating experience of these programs regarding aging detected in the Group 1 and 4 components, extent of degradation when detected, frequency of occurrence, and resulting corrective actions.

Additional examples of what the summary description should include are: inspection frequency, outline of inspection orocedures, techniques used, acceptance criteria, assessment and reporting requirements, and guidelines for corrective actions. '

10. Page 5.7-12 of the report indicates that BG&E will develop a new program for buried pipe inspection for license renewal. Please provide a summary description of this program addressing the specific elements described in Subsection ll.C of Section 3.0 of the working draft SRP-LR. For example, the summary description should include '

frequency of inspection, consideration for variations in environmental conditions, guidelines for selecting representative samples, inspection techniques, acceptance criteria, assessment and reporting requirements, and guidelines for potential corrective actions.

11.

Page 5.7-12 of the report indicates that the existing cathodic protection program is not necessary for license renewal for buried piping. In addition, page 5.7-18 of the report indicates that the FOST bottoms are not subject to any applicable aging effects.

BG&E's basis for this conclusion is that the tank bottoms are coated, set on oil-soaked soil, sealed with grout, and protected by cathodic protection. BG&E provided the same basis in ;ts February 14,1997, response to the staff's request for additionalinformation (question number 5). Hov ever, the staff concludes that the aging effects are applicable for license renewal even if there are preventative or mitigation programs to manage those aging effects and the cathodic protection program constitutes an aging management program.

Accordingly, please identify the applicable aging effects for the FOST bottorns.

Describe the aging management programs for the buried piping and FOST bottoms, including the cathodic protection program, that will ensure effective control of the applicable aging effects during the period of extended operation. In particular, please provide a summary description of these programs addressing the specific elements described in Subsection ll.C of Section 3.0 of the working draft SRP-LR

12. Paga 5.7-15 of the report describes plant procedures PEO-0-023-2-O-M,

• Drain Water From 11 & 21 FOST," CP-226, " Oil Receipt inspection and Fuel Oil Storage Tank Surveillance," and CP-973, " Determination of Particulate Contamination in Diesel Fuel Oil," for managing aging of FOST internal surfaces for license renewal. Please expand on the summary descriptions for these programs addressing the specific elements described in Subsection ll.C of Section 3.0 of the working draft SRP-LR. For example, the summary description should include brief information on the operating experience of these programs regarding water collected and out-of-specification fuel oil found in l FOST, extent of deviation from specification when detected, frequency of occurrence, l and resulting corrective actions. Additional examples of what the summary description Enclosure

l o

j should include are; inspection frequency and its basis, acceptance criteria, assessment l and reporting requirements, and guidelines for corrective actions. Further, please identify the corrosion inhibitor added to the fuel oil, corrosion effects being controlled by

' the inhibitor, and provide the basis for the effectiveness of the inhibitor in controlling corrosion. {

I I

i 13.

Pages 5.7-15 and 5.7-16 of the report indicate that aging management programs are based on specific national codes and standards and industry guidelines. Please expand on how these referenced documents are relied on for aging management and identify )

the specific portions of these documents. Include the document titles and dates or editions for those referenced documents.

14.

Page 5.7-16 of the report indicates that BG&E will develop a new program for the FOST internal inspection for license renewal. Please expand on the summary description of this program addressing the specific elements described in Subsection ll.C of Section 3.0 of the working draft SRP-LR. For example, the summary description should i include frequency of inspection, acceptance criteria, and guidelines for corrective actions if degradation is found.

15.

Page 5.7-19 of the report indicates that BG&E will develop a new program for caulking and sealant inspection for the FOST for license renewal. Please expand on the summary description of this program addressing the specific elements described in Subsection ll.C of Section 3.0 of the working draft SRP-LR and explain the extent to which this program is relied upon for other structures and components. For example, the summary description should include guidance for baseline inspections, inspection techniques, acceptance criteria, and guidelines for potential corrective actions.

16. Table 5.7-3 (Page 5.7-21) of the report lists aging management programs for the DFO system for license renewal. However, the list does not include procedure MN-3-100,

" Paint and Other Protective Coatings," which is credited for managing the Group 1 and 4 components as described in the text of the report. Please correct Table 5.7-3 to include MN-3-100 for consistency with the text or explain the differences.

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Enclosure

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