ML20237E016

Forwards Request for Addl Info Re Integrated Plant Assessment Rept for Compressed Air Sys

ML20237E016
Person / Time
Site:	Calvert Cliffs
Issue date:	08/21/1998
From:	Dave Solorio NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
TAC-M99207, TAC-M99589, TAC-M99590, NUDOCS 9808280155
Download: ML20237E016 (6)

Text

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August 21, 1998 Mr. Charl:s H. Cruss, Vice President Nuclear Energy Division l

l Baltimore Gas and Electric Company 1 1650 Calvert Cliffs Parkway Lusby, MD 20657-47027 '

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE I CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 & 2, INTEGRATED PLANT ASSESSMENT REPORT FOR THE COMPRESSED AIR SYSTEM (TAC NOS. M99589, M99590, AND M99207)

Dear Mr. Cruse:

1 By letter dated July 30,1997, Baltimore Gas and Electric Company (BGE) submitted for review j the Compressed Air System (5.4) integrated plant assessment technical report as attached to the " Request for Review and Approval of System and Commodity Reports for License ]

Renewal." BGE requested that the Nuclear Regulatory Commission staff review the ,

Compressed Air System (5.4) integrated plant assessment 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 l I

a renewed license," to support an application for license renewal if BGE applied in the future.

By letter dated April 8,1998, BGE formally submitted its license renewal application.

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The NRC staff has reviewed the Compressed Air System (5.4) integrated plant assessment I technical report against the requirements of 10 CFR 54.21(a)(1),10 CFR 54.21(a)(3). By letter I

- dated April 4,1996, the staff approved BGE's methodology for meeting the requirements of 10 CFR 54.21(a)(2). Based on a review of the information submitted, the staff has identified in i the enclosure, areas where additional information 173 needed to complete its review.

Please provide a schedule by letter or telephonically for the submittal of your responses within 30 days of the receipt of this letter. Additionally, the staff would be willing to meet with BGE ,

prior to the submittal of the responses to provide clarifications of the staff's requests for j additionalinformation.

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Sincerely gy David L. Solorio, Project Manager License Renewal Project Directorate Division of Reactor Program Management +

Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

Request for AdditionalInformation cc w/ enc! See next page .

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l Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant

[ Baltimore Gas & Electric Company - Unit Nos.1 and 2 cc:

Mr. Joseph H. Walter, Chief Engineer President Public Service Commission of Calvert County Board of Maryland Commissioners Engineering Division 175 Main Street 6 St. Paul Centre Prince Frederick, MD 20678 Baltimore, MD 21202-6806 James P. Bennett,~ Esquire Kristen A. Burger, Esquire Counsel- Maryland People's Counsel Baltimore Gas and Electric Company 6 St.. Paul Centre P.O. Box 1475 Suite 2102 Baltimore, MD 21203 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Patricia T. Birnie, Esquire Shaw, Pittman, Potts, and Trowbridge Co-Director 2300 N Street, NW Maryland Safe Energy Coalition Washirgton, DC 20037 P.O. Box 33111 Baltimore, MD 21218 Mr. Thomas N. Prichett, Director NRM Mr. Loren F. Donatell Calvert Cliffs Nuclear Power Plant - NRC Technical Training Center 1650 Calvert Cliffs Parkway 5700 Brainerd Road Lusby, MD 20657-4702 Chattanooga, TN 37411-4017 Resident inspector David Lewis U.S. Nuclear Regulatory Commission Shaw, Pittman, Potts, and Trowbridge P.O. Box 287 2300 N Street, NW -

St. Leonard, MD 20685 Washington, DC 20037 Mr. Richard I. McLean Douglas J. Walters Nuclear Programe Nuclear Energy Institute Power Plant Research Program 1776 i Street, N.W. l Maryland Dept. of Natural Resources Suite 400 Tawea State Office Building, B3 Washington, DC 20006-3708 Annapolis, MD 21401 DJW@NEl.ORG j Regional Administrator, Region l Barth W. Doroshuk U.S. Nuclear Regulatory Commission Baltimore Gas and Electric Company 475 Allendale Road Calvert Cliffs Nuclear Power Plant King of Prussia, PA 19406 1650 Calvert Cliffs Parkway NEF ist Floor l l Lusby, Maryland 20657 i I

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. Distribution:

HARD COPY Docket Files!

PUBLIC '

PDLR R/F ACRS OGC OEDO Rill 0-16B18 DISTRIBUTION: E-MAIL:

FMiraglia (FJM) .

JRoe (JWR)

DMatthews (DBM)

CGrimes (ClG)

TEssig (THE) .

Glainas (GCL)

JStrosnider (JRS2)

GHolahan (GMH)

SNewberry (SFN)

GBagchi(GXB1)

RRothman (RLD)

JBrammer (HLB)

CGratton (CXG1)

JMoore (JEM)

MZobler/RWeisman (MLZ/RMW)

SBajwa, (SSB1)

ADromerick (AXD)

LDoerflein (LTD)

BBores (RJB)

SDroggitis (SCD)

MMalloy (MXM)

- CCraig (CMC 1)

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WMcDowell(WDM)

DSolorio (DLS2)

SStewart (JSS1)

. PDLR Staff WLefave (WTL1)

Shou (SNH)

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l REQUEST FOR ADDITIONAL INFORMATION CALVERT CLIFFS NUCLEAR POWER PLANT

. UNITS 1 AND 2 COMPRESSED AIR SYSTEM INTEGRATED PLANT ASSESSMENT. SECTION 5.4 i DOCKET NOS. 50-317 AND 50-318 '

Section 5.4.1 - Sconina

1. A simplified diagram of the compressed air system (CAS), Section 5.4, depicting the portions of the system that are within the scope of license renewal, as was included with other sections in the license renewal application (LRA) that the staff has reviewed was not provided. - As a result, the staff is having difficulty gleaning from the CAS report exactly which portions of the CAS are or are not designated to be within the scope of license renewal. The information in the Updated Final Safety Analysis Report (UFSAR) also did not help in this regard. Please provide a simplified diagram depicting the major portions of the system, consistent with the level of detail provided in other system j diagrams provided in the LRA, and discuss in more detail exactly where there are any i boundaries that separate license renewal non-scope and within-scope portions of the l' system. If a simplified diagram is not available then another option would be to use the existing plant P&lDs or UFSAR figures for the air systems, and supplement the drawings with a summary description of the boundaries of the CAS in sufficient detail such that the staff will be able to determine which components are within and outside of the scope of license renewal.

The next two requests for additional information (RAls ), Nos. 2 and 3, arose partly because a simplified diagram was not provided to aid the staff in its understanding of the license renewal boundaries of the compressed air system. In developing your response 3 RAI No.1, please consider the following questions, in part, as additional guidance related to tha level of detail to include, in order to facilitate the staff's understanding of your responses to these RAls.

2. From your description of the CAS and its intended functions we concluded that all parts of the CAS that maintain the pressure boundary (main header, branch piping, tubing to instruments and actuators, etc.) are within the scope of license renewal, as described in the CAS report, or are to be included in other sections of the LRA. We also concluded that the instrument air, plant air, and saltwater air subsystems were within the scope of license renewal since they are all interconnected. In order to verify our conclusions, please identify if there are any pressure retaining components in the compressed air system whose failure would result in loss of system pressure, and are not considered to be within the scope of license renewal. If there are any such components, provide a summary justification as to why they do not fall within the scope of license renewal.

3. The CAS report indicates that all components of the CAS that support the system functions, with the exception of the fire protection function, are safety-related and seismic Category 1. Please provide clarification between the safety-related and l non-safety-related interfaces within the CAS to assist the staff with determining which interfaces within the CAS are within and outside the scope of license renewal.

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Enclosure

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4. In the description of intended functions of the CAS the auxiliary feedwater air subsystem and a containment air subsystem are identified. Briefly describe these subsystems and identify if they are included within the scope of the CAS report. If these subsystems are addressed in other sections of the LRA provide a cross reference to where they are addressed to facilitate the staff's review.

Section 5.4.2 - Aalna Manaaement

5. Provide the CAS piping size, piping material, and corrosion allowances.

6. Provide a description of the CAS external environment (s) and include a discussion of any potential aging effects applicable to the extemal surfaces of the components requiring an aging management review.

7. Describe the extent to which Section XI leak tests and inspections apply to the CAS if at -

all. If so, provide a brief summary of the results and discuss how the results were considered in identifying plausible aging mechanisms.

8. Pages 5.4-11,5.4-12 and references 27 thru 36 mention several Calvert Cliffs Nuclear Power Plant surveillance test procedures and administrative procedures, such as STP M-571F-1, STP M-571F-2, STP M-583-1, STP M-583-2, EN-4-102, EN-4-104 and MN-1-102, for managing aging of the Group 1 and 2 components for license renewal.

Please provide a summary description of the procedures regarding how their implementation addresses the following elements for their related aging management program (s): (a) The scope of structures and components managed by the program; (b)

Actions designed to mitigate or prevent aging degradation; (c) Parameters monitored or inspected relative to degradation of specific structure and component intended functions; (d) Detection of aging effects before loss of function; (e) Monitoring, trending, inspection, testing frequency, and sample size to ensure timely detection of aging effects and corrective actions; (f) Acceptance criteria to ensure intended functions; and (g) Operating experience that provides objective evidence to demonstrate that the effects of aging will be adequately managed.

g. Are there any parts of the systems, structures and components within the CAS that are inaccessible for inspection? If so, describe what aging management program will be relied upon to maintain the integrity of the inaccessible areas. If the aging management program for the inaccessible areas is an evaluation of the acceptability of inaccessible areas based on conditions found in surrounding accessible areas, please provide information to show that conditions would exist in accessible areas that would indicate the presence of, or result in degradation to, such inaccessible areas. If different aging effects or aging management techniques are needed for the inaccessible areas, please provide a summary to address the following elements for the inaccessible areas:

(a) Preventive actions that will mitigate or prevent aging degradation; (b) Parameters monitored or inspected relati've to degradation of specific structure and component intended functions; (c) Detection of aging effects before loss of structure and component intended functions; (d) Monitoring, trending, inspection, testing frequency, and sample size to ensure t!mely detection of aging effects and corrective actions;(e) Acceptance

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criteria to ensure structure and component intended functions; and (f) Operating experience that provides objective evidence to demonstrate that the effects of aging will be adequately managed.

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