ML20135C761
| ML20135C761 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/04/1996 |
| From: | Scott Flanders NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9612090074 | |
| Download: ML20135C761 (11) | |
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'C M STATES j } NUCLEAR REGULATORY COMMISSION j WASHINGTON. D.C. 30006-0001
\...../ December 4, 1996 ORGANIZATION: Baltimore Gas and Electric -
SUBJECT:
SUf91ARY OF MEETING WITH BALTIMORE GAS AND ELECTRIC COMPANY (BGE) ON BGE LICENSE RENEWAL ACTIVITIES On November 14, 1996, the Nuclear Regulatory Commission (NRC) staff met with !
representatives of BGE in Rockville, Maryland to provide comments-to BGE on the sample revisions of the BGE Structures, Component Supports, and Main !
Feedwater System integrated plant assessment (IPA) reports delivered on October 24, 1996. On November 7 and 8,1996, the staff visited Calvert Cliffs ;
Nuclear Power Plant to review BGE site documentation and meet with plant !
personnel. The purpose of this visit was to determine if any additional on-site information should be included in the reports. The observations made ,
during the staff's site visit assisted in the development of the staff comments presented during this meeting. A list of meeting attendees is provided in Attachment 1. Attachment 2 is a copy of the materials distributed ;
during the meeting.
At the beginning of the meeting, the staff stated that the purpose of this 90 day review effort was to fully exercise the BGE template in the areas of I intended functions (loading conditions), operating experience, and corrective '
actions to ensure that BGE' interpretation and implementation of the template '
and agreements in principle {for each of these issues will result in reports ;
with the content and level of detail expected by the staff. Therefore, the staff's review of the October 24, 1996, sample report revisions only focused on these three areas. The staff stated that the sample report revisions did not fully satisfy expectations in these three areas. In addition to providing specific comments on the sample reports, the staff developed general guideline examples to illustrate the content and level of detail the staff expects to see relative to these issues in an app 1tcation or IPA report (see attachment 1).
BGE asked if an application [ technical content portion only] with the same content and level of detail as the October 24, 1996, sample reports would be rejected. The staff stated that it had not considered such a situation and was not prepared to answer that question. The staff went on to say, that the general guideline examples it will discuss during the meeting reflect the information it expects to see in an application and needs to make a 54.29 finding.
The first issue discussed during the meeting was intended functions. The staff stated that for aging management programs that monitor the condition of $L11 a component, allow degradation of the component, and set an alert value(s), 1
'The agreements in principle were discussed during the September 11, 1996, NRC/BGE management meeting.
9612090074 961204 PDR ADOCK 05000317
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{ based on the component's functional requirements, to trigger corrective i actions, the application should include specific informatnon for all of the '
, current licensing basis (CL8) design conditions considered in establishing the alert value. The staff also stated that it expects to see a brief discussion, j with supporting information maintained on-site, that identifies the governing j design condition (s) and the bases for the alert value(s). The staff clarified that this is not necessarily expected for programs that are intended to j mitigate the onset of component (s) degradation. The staff used three examples
! to demonstrate its position. The first example illustrated the informtion i the staff expects to see for a program that monitors a components degradation i to ensure that a specific component parameter does not exceed a set alert value. The example includes specific design information for the system (loading cases for the system), a discussion of the controlling loading
- condition, and the bases for the alert value. The second example depicts an 4
aging management program which relies on monitoring the condition of a
( protective coating (e.g., paint) that is intend to mitigate the onset of the j aging effect. The third example was intended to demonstrate a situation where j the requisite information concerning the system or structure loading i conditions are contained in the final safety analysis report (FSAR) or other j reference documents.
! BGE stated that it believes the information provided in the IPA report sample
- revisions satisfy the second and third example. The staff stated that SGE satisfied the third example, but needed to clarify that the painting program i
relies on monitoring the condition of the paint, not the component supports to i satisfy the second example. The staff stated that from the discussion in the 4
Component Supports report sample revision, it appeared as though the program j actually monitors the condition of the supports (allowing degradation before
- taking corrective actions) as oppose to monitoring the condition of the paint.
i BGE expressed concern with the staff's first example, and questioned the need ,
j to provice the bases for alert values of NRC approved programs that are l currently in place and continually inspected.
i The next issue discussed was operating experience. The staff stated that l operating experience should be used for identifying aging effects and j providing objective evidence regarding the effectiveness of an aging
- management program. The staff provided examples that demonstrated the level j of detail and the type of operating experience it expected to see in the l reports. The first and third examples illustrated the type of operating l experience discussion expected in the IPA reports when discussing aging
- effects. The staff stated that it expects an applicant to identify al' aging i
i effects that have actually occurred at its facility. The remaining examples described the type of operating experience discussion the staff expects when an applicant is discussing the effectiveness of an existing program.
! BGE stated that it intends to begin holding meetings with program and system i engineers to discuss operating experience, and will include any relevant information from these meetings in the IPA reports. BGE went on to say, that 1
it will discuss any significant aging effects, however, it will not discuss j aging effects that occurred in systems or portions of a system that is not
Baltimore Gas & Electric within the scope of license renewal. With res m t to providing objective evidence for a program, BGE will not make absolute statements about the program. BGE stated that in order for absolute statements to be made in the IPA reports, it would require going back through plant information to confirm any specific statements of fact regarding the effectiveness of a program. BGE stated that aging effects that are aggressive such as wall thinning due to erosion / corrosion are well understood by the industry and the NRC. The industry has studied these aging effects and developed programs which the NRC has approved and continually inspects to address these aging effects. BGE questioned why the staff does not rely on NRC inspection reports to assess the effectiveness of existing programs.
The final issue discussed was corrective actions. The staff stated that the emphasis of its corrective actions comments is on program enhancements. The staff stated that any component or system failures that resulted in an enhancement to a program should be discussed. The examples illustrates the staff's threshold for the type of progran enhancements it expects to see discussed in the IPA reports. BGE stated that significant program enhancements will be discussed in the IPA reports. ;
At the conclusion of the meeting, the staff asked if BGE wanted to meet again to provide additional thoughts on the staff's comments. The staff stated that the focus of the meeting would not be to negotiate the staff positions stated during this meeting, but rather to hear BGE's comments and position on the issues discussed. BGE stated that they would like to meet with the staff. A meeting has been scheduled for November 21, 1996.
i
! S ott C. la rs, Pr Manager ,
License Renewal Project Directorate i Division of Reactor Program Management i Office of Nuclear Reactor Regulation Docket Nos.: 50-317&50-318 Attachments: l
- 1. Attendance List
- 2. Meeting Handouts cc w/ attachments:
Service list (with all enclosures) i l
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ATTEMWYiCE LIST NRC EETING WITH BALTIMNtE GAS Als ELECTRIC November 14. 1996 NAME ORGANIZATION 1
1
- 1. _jcott Flanders NRC/NRR
- 2. John Moulton RC/NRR i
- 3. P.T. Kuo NRC/NRR
- 4. Sam Lee NRC/NRR
- 5. Scott Newberry NRC/NRR
- 6. Bob Prato NRC/NRR I i
- 7. Tricia Heroux for EPRI l
- 8. Chris Recan NRC/NRR I
- 9. _Eaul Shenanski NRC/NRR
- 10. Hai Boh Wano NRC/NRR
- 11. Steve Hoffman NRC/NRR <
4
- 12. Ra1 Anand NRC/NRR
- 13. Don Shaw BGE/LCMU
- 14. Barth Doroshuk BGE/LCNU
- 15. Mary Bowman BGE/LCMU
- 16. Barry Tilden BGE/LCMU 4
g ATTACHMENT 1
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- Attachment 2 11/14/96
- 1. INTENDED FUNCTIDN i 1113t:
- Maintain intended functions under all CLB design conditions Information to be Included in Aeolication
, Specific information that all CLB design conditions are considered in developing " alert values" for programs
. References should be cited in application and details should be available on site for staff review / audit 4
l Ex== ales (Discuss in Anolication):
- 1. Feedwater einina/ erosion corrosion oroaram:
l Designed for thermal, pressure, ... loads; loading combinations; and
' codes and standards; as described in FSAR ## and/or other appropriate {
documents <
Pressure controls for this system and has been verified by reviewing l sample stress calculations Minimum allowable pipe wall (" alert value") is calculated based on i pressure
- 2. Pinina suonorts/ corrosion (paintina) orocram:
Piping supports designed to support piping consistent with system piping design loading conditions 1
Painting ensures that no material is lost due to corrosion and thus, !
piping supports would continue to perform their intended function as originally designed (include references to the painting and inspection ;
programs) 1
- 3. Auxiliary buildina/crackina oroaram:
J Designed for loads, loading combinations, and codes and standards, as described in FSAR ## and/or other appropriate documents t
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- 2. OPERATING EXPERIENCE Issue:
Operating experience for identifying applicable aging effects and program implementation experience providing " objective evidence" on effectiveness of
. programs l Information to be Included in Anolication:
Specific information on operating experience and maintenance history References should be cited in application and details should be available on site for staff review / audit Examnles (Discuss in Acolication):
- 1. Feedwater einina: (Aging effects)
High fatigue usage due to thermal stratification near steam generator nozzle; industry has experienced fatigue cracking at this location Wall thinning has been found in portion of feedwater system not in scope of renewal and also in the check valve within scope of renewal Wall thinning has not been observed in portion of feedwater piping within scope of renewal :
- 2. Feedwater einina/ erosion corrosion orocram: (Objective evidence)
Erosion corrosion program has been in place for 10 years Wall thinning has been found mostly in the steam extraction system and has resulted in timely piping replacement No wall thinning has resulted in less than minimum wall since program implementation, except for small drain lines
- 3. Pioina sucoorts: (Aging effects)
Very few piping supports have been found with aging degradation; however, industry has experienced loosening of anchor bolts ,
- 4. Pioina suooorts/ISI oroaram: (Objective evidence)
Hundreds of piping supports are inspected every refueling and a few supports have been found with manufacturing or installation defects
- 5. Auxiliary buildina/crackina orocram: (Objective evidence)
Cracks in concrete were found by walkduwns Cracks were repaired and monitored; cracking has not reappeared 2
- 3. CORRECTIVE ACTION Issue:
Provides appropriate feedback to enhance programs
- Information to be Included in Aeolication
Specific information on corrective actions to show program inadequacies have been addressed References should be cited in application and details should be available on l
, site for staff review / audit Ex = les (Discuss in Anolication):
- 1. Egedwater einino/ erosion corrosion orocram: l Wall thinning in check valve in feedwater system i Check valve has been replaced Implemented separate program to inspect similar check valve, including a
check valve in scope of renewal 1
- 2. Feedwater oioina/ erosion corrosion orocram:
1 Small lines have leaked due to wall thinning Ultrasonic inspection was not effective for small lines and program has l been modified to use radiography for small lines l
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- 3. Auxiliary buildina/crackina proortm: l Cracks in concrete were found, repaired, and monitored Crreks reappeared; program has been modified to include detailed root cause evaluation to prevent reoccurrence 3
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k COMNENTS ON BGE SAMPLES
- 1. INTENDED FUNCTIONS BGE Sample: :
1 A generalized statement claiming all design loadings are met.
For example, BGE states in the feedwater system sample: "The minimum wall thickness ... ensures the piping intended function will be maintained under all design loadings required by the CLB."
Staff Cc-- nt: !
A generalized statement / claim contains no specific information for the staff to review regarding whether the applicant has actually considered the design conditions for specific system, structure, and component.
- 2. OPERATING EXPERIENCE BGE Samale:
A generalized discussion that claims the programs are effective.
For example, BGE states in the feedwater system sample: "The Erosion Corrosion Program has demonstrated its effectiveness through discovery and !
trending of pipe wall thinning due to. erosion corrosion in the Feedwater System and some pipe segments have been replaced due to erosion corrosion degradation."
Staff Comment:
A generalized statement may be said for any program for any system: "The ...
program has been effective and has resulted in component repair / replacement."
Such a statement contains no specific information for the staff to review regarding what aging effects have cccurred and how effective is the specific programs in managing the aging for system, structure, and component.
- 3. CORRECTIVE ACTION BGE Sam,le:
A generalized reference to a plant. corrective action procedure.
BGE states in the samples: "The ... corrective action ... process for license renewal is in accordance with QL-2, ' Corrective Actions Programs.' QL-2 is pursuant to Appendix B and covers all structures and components subject to !
aging management review." :
Staff Comment:
A statement referencing Appendix B is applicable to future corrective actions.
However, program weaknesses are not unusual and a past failure does not ;
necessarily invalidate an aging management program. Specific information '
should be provided on what corrective actians have occurred and whether program enhancements have resulted. A renewal application should contain a discussion of any appropriate corrective actions taken to enhance programs due to operating experience in specific system, structure, and component.
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- Calvert Cliffs Nuclear Power Plant
! Baltimore Gas & Electric Company Unit Nos. I and 2 I
CC:
President Mr. Joseph H. Walter, Chief Engineer j Calvert County Board of Public Service Commission of Commissioners Maryland 175 Main Street Engineering Division i Prince Frederick, Md 20678 6 St. Paul Centre i Baltimore, MD 21202-6806 1 D. A. Brune, Esquire General Counsel Kristen A. Burger, Esquire 4 Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2101 .
Baltimore, MD 21202-1631 l 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. Terrence J. Camilleri, Director, Baltimore, MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Robert E. Denton 1650 Calvert Cliffs Parkway Vice President - Nuclear Energy Lusby, MD 20657-4702 Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Resident Inspector 1650 Calvert Cliffs Parkway c/o U.S. Nuclear Regulatory Lusby, MD 20657-4702 Commission P,0. Box 287 Mr. Larry Bell St. Leonard, MD 20685 NRC Technical Training Center 5700 Brainerd Road Mr. Richard I. McLean Chattanooga, TN 37411-4017 Administrator - Radioecology Department of Natural Resources 580 Taylor Avenue 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
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- FMiraglia/AThadani (A) (FJM)/(ACT)
H8 Wang (HXWI) l RCorreia (RPC)
RZimmerman (RPZ)
JMoulton (JPMI)
SHoffman (STH) ;
j RWessman (RHW) !
TMartin (TTM) l PTKuo (PTK) i RAnand (RKA) i JStrosnider (JRS2)
DMatthews (DBM)
- Slee (SSL1) !
l WDean (WMD) l SDroggitis (SCD)
SNewberry (SFN)
BPrato (RJP2)
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JMitchell (JAM)
SPeterson (SRP)
SFlanders (SCF)
CRegan (CMRI)
LDoerflein (LTD)
Glainas (GCL)
EJordan (JKR)
PShemanski (PCS)
JSStewart (JSSI)
TSpeis (TPS)
JMoore/EHoller (JEM)/(EJH)
GMizuno (GSM)
GHolahan (GMH)
BSheron (BWS)
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within the scope of license renewal. With respect to providing objective evidence for a program, BGE will not make absolute statements about the program. BGE stated that in order for absolute statements to be made in the IPA reports, it would require going back through plant information to confirm
, any specific statements of fact regarding the effectiveness of a program. BGE stated that aging effects that are aggressive such as wall thinning due to
( erosion / corrosion are well understood by the industry and the NRC. The industry has studied these aging effects and developed programs which the NRC has approved and continually inspects to address these aging effects. BGE questioned why the staff does not rely on NRC inspection reports to assess the i effectiveness of existing programs. ;
1 The final issue discussed was corrective actions. The staff stated that the i emphasis of its corrective actions comments is on program enhancements. The- i staff stated that any component or system failures that resulted in an 'l enhancement to a program should be discussed. The examples illustrates the staff's threshold for the type of program enhancements it expects to see discussed in the' IPA' reports. BGE stated that significant program enhancements will be discussed in the IPA reports.
At the conclusion ^ of the meeting, the staff asked if BGE wanted to meet again to provide additional thoughts on the staff's comments. The staff stated that the focus of the meeting would not be to negotiate the staff positions stated during this meeting, but rather to hear BGE's comments and position on the issues discussed.' BGE stated-that they would'like'to meet with the staff. A meeting has been scheduled for November.21, 1996.
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 Attachments:
- 1. Attendance List
- 2. Meeting Handouts cc w/ attachments:
Service list (with all enclosures)
Distribution: See page 4 DOCUMENT NAME: A:1114MS (SFlanders Disk)
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f D:PDLRE.f/Wl, 1 NAME SFlandeis/ SFNewbdrr W DATE 2 /L 66 12.4 (P /96'
' 0FFICIAL RECORD COPY
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