ML20239A072

Forwards RAI Re Integrated Plant Assessment Rept Contained in Application Against Requirements of 10CFR54.21(a)(1) & 10CFR54.21(a)(3).Response Requested within 30 Days of Receipt of Ltr

ML20239A072
Person / Time
Site:	Calvert Cliffs
Issue date:	08/28/1998
From:	Dave Solorio NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
TAC-MA2156, NUDOCS 9809080129
Download: ML20239A072 (6)

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August 28, 1998 I

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

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 & 2, INTEGRATED PLANT ASSESSMENT REPORT (TAC NO. MA2156)

Dear Mr. Cruse:

By letter dated April 8,1997, Baltimore Gas and Electric (BGE) submitted its license renewal application. The staffis reviewing the integrated plant assessment reports contained in the application against the requirements of 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(3). Based on a review of the information submitted, the staff has identified in the enclosure, generic areas where additionalinformation is needed to complete its review.

Please provide a schedule by letter or telephonically for the submittal of your respontes 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 additionalinformation.

Sincerely, W$UY David L. Solorio, Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation k

Docket Nos. 50-317 and 50-318 f

Enclosure:

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i Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company. Unit Nos.1 and 2 cc:

President Mr. Joseph H. Walter, Chief Engineer ?

Calvert County Board of Public Service Commission of Commissioners Maryland ,

l 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 l 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 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 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 i Street, N.W.

Tawes State Office Building, B3 Suite 400 Annapolis, MD 21401 Washington, DC 20006-3708 Regional Administrator, Region I 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 Lusby, Maryland 20657 l i

REQUEST FOR ADDITIONAL INFORMATION CALVERT CLIFFS NUCI FAR POWER PLANT UNIT NOS.1 & 2 LICENSE RENEWAL APPLICATION DOCKET NOS. 50-317 AND 50-318 Generic Requests for information

1. The BGE application contains aging management review of valve intemais, such as disk, seat, and pivot rod. However,10 CFR 54.21(a)(1)(l) excludes valves, other than the valve body, from the aging management review requirements. The statements of consideration (SOC) of the license renewal rule provides the basis for excluding structures and components that perform their intended functions with moving parts or with a change in configuration or properties from an aging management review for license renewal. It statesi "On the basis of consideration of the effectiveness of existing -

programs which monitor the performance and condition of systems, structures, and - l components that perform active functions, the Commission concludes that structures and l components associated only with active functions can be generically excluded from a j license renewal aging management review. Functional degradation resulting from the effects of aging on active functions is more readily determinable, and existing programs and requirements are expected to directly detect the effects of aging." (60 FR 22471)

The SOC contains an example of the valve intemals. It states: "The Commission has determined that passive structures and components for which aging degradation is not readily monitored are those that perform an intended function without moving parts or without a change in configuration or properties. For example, a ... valve has moving -

parts, ... Therefore, the performance or condition of these components is readily monitored and would not be captured by this description." (60 FR 22477) Further, in response to a public comment regarding rarely operated valves, the SOC states: "The ,

Commission disagrees with the commenter's assertion that there is insufficient evidence that the active functions will be maintained in the renewal period. Such valves are within the scope of various regulatory programs, including the maintenance rule. 1 Consequently, the ability of the valves to perform their intended function must be assured through either (1) effective preventive maintenance or (2) performance or condition  ;

monitoring." (60 FR 22472) In addition, the industry guideline developed by the Nuclear Energy institute (NEI) in NEl 95-10, Revision 0, " Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," which the staff has proposed to endorse in a draft regulatory guide, indicates that only valve bodies are subject to an aging management review for license renewal.

Please provide basis of BGE's determination that valve intemals are subject to an aging management review for license renewal.

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2. The BGE application contains a statement to indicate that component replacements are  ;

. not subject to an aging management review for license renewal. By letter dated February 19,1998, the staff issued a request for additional information (RAI) on the Enclosure L -- - - . _ _ _ _ _ _ - - _ - - - - - - - -

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2-diesel fuel oil system described in the application. In Question 6 of the RAl, the staff requested information regarding component replacements in the diesel fuel oil system.

Your July 30,1998, response indicates that the BGE statement is meant to be generic

' and accounts for a future hypothetical scenario. No components were excluded from an aging management review based on the hypothetical scenario. Because this statement appears throughout the BGE application, please verify that your response to Question 6 of the diesel fwi oil system RAI is applicable to the entire BGE application.

3. The BGE application relies, in part, on " Age-Related Degradation inspection (ARDI)"

programs to manage the effects of aging for license renewal. The application also re;ies, in part, on new programs to manage the effects of aging for license renewal. Please discuss the differences between ARDI and new programs.

4. The BGE application relies, in part, on ARDI programs to manage the effects of aging for license renewal. For each of these ARDI programs, please provide a reference to the ,

section of the application, supplemented as needed, that describes a summary that addresses the elements listed below. The summary should include a discussion of the bases for each of these elements. (1) Parameters to be monitored or inspected relative to degradation of specific structure and component intended functions; (2) Assurance that detection of aging effects will occur before loss of structure and component intended

-- functions; (3) Program inspection, technique, inspection schedule, and sample size to ensure structure and component intended functions; (4) Acceptance criteria to ensure L structures and components can perform their intended functions; and (5) Operating l exponence from similar programs or inspection techniques used by BGE or the industry.

L Also discuss the schedule for implementation of each of these ARDI programs, For programs that are yet to be developed, please provide information on those elements that are available. For the remaining elements, please provide the detailed process, including the basis, that BGE will use to develop them and a schedule for when the program development will be completed.

5, The BGE application relies, in part, on new programs to manage the effects of aging for license renewal For each of these new programs, please provide a reference to the section of the application, supplemented as needed, that describes a summary that  !

addresses the elements listed below. The summary should include a discussion of the l

bases for each of these elements. (1) Scope of program that includes the specific structures and components subject to an aging management review; (2) Preventive  !

l . actions that will be used to mitigate or prevent aging degradation; (3) Parameters to be l

monitored or inspected relative to degradation of specific structure and component i intended functions; (4) Assurance that detection of aging effects will occur before loss of structure and component intended functions; (5) Program monitoring, trending, ,

inspection, technique, testing frequency, and sample size to ensure structure and l component intended functions; (6) Acceptance criteria to ensure structures and components can perform their intended functions; and (7) Operating experience from similar programs or inspection techniques used by BGE or the industry. Also discuss the schedule for implementation of each of these new programs. '

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1 For programs that are yet to be developed, please provide information on those elements that are available. For the remaining elements, please provide the detailed process, including the basis, that BGE will use to develop them and a schedule for when the program development will be completed.

6. Section 2.0, " Integrated Plant Assessment Methodology," of Appendix A to the BGE application indicates that the purpose of an ARDI is either to support a "non-plausible" aging mechanism determination or to confirm that a mitigation program is effective. The ARDI is a one-time inspection which may be performed prior to or during the period of extended operation. The staff is requesting additional information to clarify the purpose of an ARDI program and when an ARDI is used as discussed below.

Section 5.16, " Saltwater System," of Appendix A to the application indicates that there is an ARDI program to manage the effects of corrosion of certain saltwater system group 1 components. These components are unlined piping, valves, etc., and BGE has determined that corrosion is " plausible." BGE also identified that there is no program to mitigate corrosion for these components. Then, BGE proposed to develop an ARDI program. Based upon operating experience, corrosion of saltwater system components may be likely. Thus, the staff believes a periodic inspection program may be more appropriate than a one-time inspection at a future unspecified time. In addition, 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.

There are other similar examples, such as managing stress relaxation and stress corrosion cracking of reactor vessels intemals (Section 4.3). Please provide criteria for determining when an ARDI versus a new program is selected for aging management for license renewal.

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