ML20147G865

Summary of 970226 Meeting W/Bge in Rockville MD to Discuss Util Response to Staff 960830 Rai.List of Attendees & Matls Distributed at Meeting Encl

ML20147G865
Person / Time
Site:	Calvert Cliffs
Issue date:	03/26/1997
From:	Scott Flanders NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9703280344
Download: ML20147G865 (17)

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, p e %g 3" 4 UNITED STATES g g NUCLEAR REGULATORY COMMISSION

'# WASHINGTON, D.C. 20555-0001

% ,,, g # March 26, 1997 j

ORGANIZATION: Baltimore Gas and Electric

SUMMARY

OF MEETING WITH BALTIMORE GAS AND ELECTRIC COMPANY (BGE) ON BGE LICENSE RENEWAL ACTIVITIES On February 26, 1997, the Nuclear Regulatory Commission (NRC) staff met with representatives of BGE in Rockville, Maryland to discuss BGE's response to the staff's August 30, 1996, request for additional information (RAI). Attachment I is a list of the meeting attendees, and Attachment 2 is a copy of the materials distributed at the meeting.

BGE submitted its response to the staff's RAI by letter dated February 14, 1997. The intent of this meeting was to allow BGE to explain the structure of the RAI response and to discuss BGE's position on some technical issues. With the meeting intent in mind, the staff did not debate any of BGE's positions on the technical issues, but only asked questions when clarification was needed.

BGE started the meeting by discussing the structure of its RAI response. BGE stated that the RAI questions were divided into four major categories:

methodology, template, technical scoping, and technical aging evaluation. BGE stated that some of the RAI questions were purely editorial; these questions were acknowledged and will be addressed as stated in the RAI response submittal letter. Therefore, an explicit response to the editorial questions were not included in the RAI response. BGE stated that it believes the questions in the template category (74 questions) would not have been asked if the template were available when the reports were written. BGE stated that the details of these questions will be addressed by the revised reports, which will be written according to the template. BGE also provided the rationale for how they responded to questions in each of the other categories.

BGE then discussed their position on some technical issues. The staff acknowledged that many of these issues will need to be addressed as part of the review of the technical reports. The staff also pointed out that many of the technical issues presented by BGE include issues that are being addressed as part of the staff's regulatory guidance development process. Several of these issues are generic and the staff is involved in on-going discussions with the other parts of the industry as well.

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J BGE and the staff agreed to meet in late March or early April to discuss the RAls in more detail after the staff completed its initial review of the RAls.

I 5' cot . F1 ide , Pro f./ v er License Renewal Pr irectorate Division of Reacto Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-317, 50-318 Attachments: 1. Attendance List i

2. Meeting Handouts I i

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1 L e'-

1 Mr. Charles H. Cruse Calvert Cliffs Nuclear Power Plant j Calvert Cliffs Nuclear Power P1 ant Unit Nos. 1 and 2 j cc: i l

President- Mr. Joseph H. Walter Chief Engineer i 1 Calvert County Board of Public Service Commission of

Commissioners Maryland 175 Main Street Engineering Division

, ~ Prince Frederick. MD 20678. 6 St. Paul Centre 1

Baltimore. MD 21202-6806 .

] D. A. Brune. Esquire  !

! General Counsel Kr' sten A. Burger. Esquire Baltimore Gas and Electric Company Maryland People's Counsel

! P.O. Box 1475 6 St. Paul Centre t Baltimore. MD 21203 Suite 2102 i Baltimore, MD 21202-1631 4

-Jay E. Silberg Esquire Shaw, Pittman, Potts. and Trowbridge Patricia T. Birnie. Esquire

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2300 N Street. NW Co-Director Washington. DC 20037 Maryland Safe Energy Coalition

! P.O. Box 33111 I Mr. Terrence J. Camilleri . Director, Baltimore. MD 21218 4 NRM  :

1 Calvert Cliffs Nuclear Power Plant Mr. Larry Bell '

l 1650 Calvert Cliffs Parkway NRC Technical Training Center

Lusby, MD 20657-47027 5700 Brainerd Road r

Chattanooga, TN 37411-4017 Resident Inspectcr

. U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard. MD 20685

.Mr. Richard I. McLean Administrator - Radioecology Department of Natural Resources ,

580 Taylor Avenue i Tawes State Office Building, B3 Annapolis, MD 21401 i 1

Regional Administrator, Region I U.S. Nuclear Regulatory Commission  :

475 Allendale Road  !

King of Prussia, PA 19406

i i ATTENDANCE LIST NRC MEETING WITH BALTIMORE GAS AND ELECTRIC February 26. 1997 5

1 88ME ORGANIZATION

1. Scott Flanders NRC/NRR/DRPM/PDLR

2. Paul Shemanski NRC/NRR/DRPM/PDLR

3. Sam Lee NRC/NRR/DRPM/PDLR i 4. Bob Prato NRC/NRR/DRPM/PDLR

5. Christopher M. Regan NRC/NRR/DRPM/PDLR

6. Barth Doroshule BGE

7. Barry Tiden BGE

8. Hai-Boh Wang NRC/NRR/DRPM/PDLR

! 9.- Winston W. C. Liu NRC/NRR/DRPM/POLR  ;

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10. Scott Newberry NRC/NRR/DRPM/PDLR

, 11. P. T. Kuo NRC/NRR/DRPM/PDLR

12. Steve Hoffman NRC/NRR/DRPM/PDLR I

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Attachment 1 4

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Life Cycle Management Unit Responses to NBC Reauests for Additional Information February 26,1997 1

i Life Cycle Management Unit Background j

• BGE submitted five License renewal technical reports in May 1996 with two goals

- Obtain technical review of scoping, pre-evaluation and aging evaluation results.

- Reach agreement on level of detail to be included in a license renewal application.

• Eleven Aging Management Review Reports were submitted with the LRTRs i

- AMRRs were submitted as background information to supplement NRC's review of the LRTRs.

• in late August, the NRC delivered 248 technical and 35 editorial RAls.

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ATTACHMENT 2

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I Life Cycle Management Unit fdttegories of RAls a BGE initially evaluated the 248 technical RAls and binned them as follows -

- 51 requested information on the BGE IPA process and could be answered through a clarification of the NRC approved BGE IPA Methodology.

- 74 were level of detail issues which have been resolved generically through the template interactions.

- 22 were technical scoping issues.

- 120 were technical aging evaluation issues.

(Clarification of plausibility determinations)

- Several fit into more than one category.

3 NRC RAls Life Cycle Management Unit NRC RAI Categories Template Methcdo'ogy Technical Scoping , q'q: l(' '_ , , ,

p$r Ny?,y'ps N!Nlt""

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Technical Aging Evaluation 4

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Life Cycle Management Unit BGE Responses - By Category Methodology

• For Methodology type questions

- BGE provided some clartfication discussion.

g,mg - Pointed to the appropriate section of the methodology for more detail.

• BGE recognizes that the SER Template #

reca,,,,,, "Try provides two different levels of approval of Methodology -

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1. "8 %.. " acceptable for meeting the requirements of 10 CFR 4 A  %

54.21(a)(2) of the LR Rule and if implemented provides Technicai beiden d" "provides processes for demonstrating that the effects of aging will be adequately managed pursuant to 1.

CFR 64.21(a)(3) and for evaluating TLAAs pursuant to 10 CFR 54.21(c) that are conceptually sound and consistent with the intent of the LR Rule."

• RAI responses reflect this.

5 Life Cycle Management Unit BGE Responses - Bv Category Format and. Content

• For format and content type Templa questions, BGE either

- Verified that the BGE Template would provide the requested info cr

- stated that the requested info is

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• avallable for review on sito.

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• For many of these RAls, BGE's r-yj,ca',, ,,,,,

response was that the revised LRTR would include the requested information.

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Life Cycle Management Unit BGE Responses By Category Technical Scoping

"'* * . BGE provided some clarification of why certain SCs were WSLR and others were not.

. . Severalintended functions were w/ changed or added based on the

'"*ds,Th;:' NRC's input -

ruie,iic i - Structures '

Asiao rv.i' - Subcomponentievel i

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i Life Cycle Management Unit BGE Responses - By Category Technical Aging Evaluations

. Many responses provided more information to justify non-plausibility determinations.

. Some plausibility run,,u.i em - determinations were altered Saa**y @j>j' 4

based on NRC feedback.

. Many responses were

'"1"A',' ev.i. clarifications related to the format of AMR reports.

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i Life Cycle Management Unit Technical issues - 54.4.afii) 1 LR Rule SOC emphasizes that " cascading"

. should be consistent with CLB.

- The BGE scoping process implemented this criterion by relying on the site Q List which scoped an identical set of SCs (related to 54.4.a(i) and (ii)).

- If BGE Q List did not identify an SC as meeting this criteria (SSCs whose failure could prevent accomplishment of an intended function),it was not scoped as WSLR.

- Several questions related to this issue.

- NSR fuel piping from FOST bottom.

- Feed Reg Valves.

9 Life Cycle Management Unit Technical issues - SCs that Prevent Aging

• A common RAI relate 41 to components relied on to mitigate / prevent aging of other components.

- e.g. cavity cooling fans, component cooling water to containment penetrations, containment roof drains, RMS filters.

1 - Such SCs were not included as WSLR since they do not meet the 54.4 criteria.

- The role of such SCs in a non plausibility determination is documented in the AMR Report.

- In some cases, site processes already ensure that such SCs cannot be altered. (e.g. already discussed in FSAR)

- In other cases, site processes may need to be adjusted to ensure the role these SCs play in non plausibility determinations is considered in the future.

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I Life Cycle Management Unit 1

Technicalissues - Active vs Passive l BGE followed the process described in the IPA Methodology to determine SCs that can be excluded as active.

- BGE process addresses active and passive intended functions consistent with SOC.

- BGE process recognizes that " passive characteristics" of SCs which cause them to require an AMR are complex and much discussion in SOC is provided on this topic.

- BGE Methodology states " Active functions require moving parts or a change in configuration or properties to carry out the intended function. For such tunctions, .

plant parameters change in a measurable manner during j normal plant operation. Performance of this equipment  !

may be assessed by observing, monitoring or trending these parameters." Methodology cites circuit breakers and fuses as examples of active components.

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l Life Cycle Management Unit Technic 3J1ssues - Active vs Passive (2)

Following the process described in the BGE IPA methodology -

- Fuses, Indicating lights and transformers are active because they require a change in configuration or properties to perform their function.

- Effects of aging on these components causes changes in plant parameters which are readily detectable.

- Heat transfer is an active function because it requires a change in configuration to perform this intended function.

- Effects of aging on this function are readily detectable through changes in plant parameters.

• BGE RAI responses reflect these positions.

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Life Cycle Management Unit Technical issues - Status of Consumables i

- Several questions related to aging of gaskets  ;

and seals.

- These consumable subcompe ants are intended M be "used up" during the life of a component and rep., :ed as needed.

- Per the CCNPP Q List, gaskets and seals are controlled ,

as SR at CCNPP to " limit leakage." '

- Degradation of these items (i.e. minor leakage)is readily detectable and correctable through observing plant i conditions. Since no structural support function is provided, more severe loading conditions are not an issue.

BGE did not include such consumables in the AMR. y l

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Life Cycle Management Unit ,

I Technicallssues - Level of Justification for Non Plausible Determinations RAls requested justification for non plausible determinations which BGE did not Consider to be " highly visible"--

- SCC of carbon steelin a normal environment.

- EC of piping in a system where the fluid is filtored air.

- Corrosion of stainless steelin an air environment.

- Items where agreement has already been documented in NUREG 1557 (aluminum concrete interaction &

contributionof stray electrical currents to rebar corrosion.)-

LRTRs will not provide justification for non i plausible determinations unless they are

" highly visible."

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Life Cycle Management Unit i

, Technical Issues - Level of information May Be

Different in Different AMRs

• Staff RAls seemed to imply that an identical level of information is needed for every AMR.

- e.g. Material designations, details on environment, details on design loading conditions.

This does not recognize the fact that different AMRs have different strategies. For example,

- if the intent is to show that materials are not susceptible ,

to aging, more material and t.nvironment information is l relevant.

- If the intent is to show that, based on plausible aging i effects & current observed material condition, continued walkdowns will effectively manage aging, much less material and environment type information is pertinent.

15 Life Cycle Management Unit Technical Issues - Generic Correspondence Several RAls asked how BGE addressed an info notice or bulletin.

• As described in our methodology,it is BGE's intent to explicitly address aging of SCs, not generic correspondence.

• In all cases, it was determined that the BGE process addressed the aging issue (if any) which was the subject of the generic correspondence in the RAl.

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f A l l [ Life Cycle Management Unit ) l l- Technical Issues - GSis/USls ]

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i- One RAI asked for a discussion of GSis and 1 i USls related to a commodity group.

• The statement in the LR Rule SOC related to i GSis and USis was made in response to an i industry comment.

.l - Comment stated that if an issue is the subject of an open

GSI, an applicant should not have to solve the issue for LR j on a plant specific basis,

i. - SOC agreed somewhat but also stated that it would not be sufficient to just state that a GSI exists. Three options were

, provided in the SOC.

This comment and response have evolved into a perceived requirement to review & address all GSis/USis in the IPA. That was never the intent.

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Life Cycle Management Unit j l Technical issues - Environmental Stressors l i

1 Several RAls asked BGE to address aging j that would be caused by abnormal i environments.

• Examples include degradation of external surfaces due to piping leaks and effect of l accident dose' rates on concrete. l BGE's IPA process considers the normal environment as the one wb :h contributes to aging and which needs to be addressed in the AMR.-

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i Life Cycle Management Unit 1

Other Technical issues - New Eauipment '

LR Rule is silent on new equipment which will not operate more than 40 years.

- New emergency diesel generators and associated 'l cooling water, fuel oil, electrical panels, Class 1 structure and HVAC system.

l - New plate and frame HXs in service water system. l

- Replacement SGs. l Based on Guidance in the original LR Rule SOC, BGE believes no AMR is required for such equipment.

- " since license renewal will result in operation of these SSCs beyond the 40 years assumed in their design, i

, additional analyses and/or actions may be necessary to l ensure that an acceptable level of safety is maintained l during the period of extended operation."

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Life Cycle Management Unit l

Other Outstanding issues

= Interpretation of the 54.29 words -

- (a) Actions have been identified and have been or will be taken with respect to the matters identified in Paragraphs (a)(1)[IPAJ and (a)(2)[TLAAs] of this section, such that there is reasonable assurance that the l

activities authorized by the renewed license will continue to be conducted in accordance with the CLB..."

- Timing of TLAAs.

- Other analyses / calculations for which a commitment is made in the LRTR.

• FSAR Supplement level of detail.

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I M ufe cycie Management unit i C_Qnclusions i

a Many NRC questions were insightful and

their resolution has improved the quality of i

BGE's Integrated Plant Assessment.

BGE looks forward to continued interaction

on RAI responses to resolve scoping, pre-

] evaluation and aging evaluation issues.

• BGE also looks forward to meaningful interaction on the demonstration portion of the LRA after the rewritten LR technica'

reports are submitted this spring.

- Rewrites will reflect RAI responses and new template 4

level of detail.

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BGE and the staff agreed to meet in late March or early April to discuss the ,

RAls in more detail after the staff completed its initial review of the RAIs. '

Original signed by:

$ Scott C. Flanders, Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-317, 50-318 i l

l Attachments: 1. Attendance List '

2. Meeting Handouts 4

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Distribution:

Hard Copy Central.. File / Docket File':

PUBLIC PDLR R/F ACRS E-MAIL SCollins/AThadani (SJC1/FJM)

RZimmerman (RPZ)

TMartin (TTM)

MSlosson (MMS)

SNewberry (SFN)

SFlanders (SCF)

SMeador (SAM)

PShemanski (PCS)

Slee (SSL1)

BPrato (RJP2)

CP.egan (CMRI)

HBWang (HXWI)

WLiu (WCL2)

PTKuo (PTK)

SHoffman (STH)

WDean (WMD)

LDoerflein (LTD)

JSStewart (JCS1)

RWessman (RHW)

SStrosnider (JRS2)

SDroggitis (SCD)

SPeterson (SRP)

Glainas (GCL)

BMorris (BRM)

JMoore/EHoller (JEM/EJH)

GHolahan (GMH)

GMizuno (GSM)

BSheron (BWS)

GBagchi (GXB1)

-