ML20199A111
| ML20199A111 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/21/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9801270121 | |
| Download: ML20199A111 (103) | |
Text
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CH 49tlis 11. CRt'hE llaltimore Gas und lilectrK Company Vice Preskient Cahen Chff s Nuclear Powtr Plant Nuclear linergy 1650 Cahert Chih Parkv a)
Lusby. Ntan land 2tmS7 410 495-4455 H l January 21,1998 U. S. Nuclear Regulatory Commissio 1 Washington, DC 20555 ATTENTION: Document Control Desk -
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 310 Request for Review and Approval of Commodity and System Reports fo.
]
REFERENCES:
(a) Letter from hir. R. E. Denton (BGE) to NRC Documera Control Desk, dated August 18,1995, Integrated Plant Assessment hiethodology
]
(b) Letter from utr. D. hi. Crutchfield (NRC) 'o hir. C.11. Cruse (BGE),
dated, April 4,1996, Final Safety Evaluation (FSE) Concerning The ..
Bahimore Gas and Electric Company Report entici ' Integrated Plant Assessment hiethodology" (c) Letter from hir. S. C. Flanders (NRC), dated Niarch 4,1997, "Sumi. wry of Meeting with Baltimore Gas and Electric Company (BGE) on BGE
_^
License Renewal Activities" This letter forwards the attached Integrated Plant Assessment (IPA) Comniodity and System Reports for review snd app. oval in accordance with 10 CFR Part 54, the license renewal rule. Should we apply for ;
License Renewal. we will reference IPA Commodity and System Reports as meeting the requirem-nts 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."
The information in this report is accurate as of the dates of the references listed therein. Per l
10 CFR 54."'(b), an amend.nent or amendments will be subraitted that identify any changes to the '
current licensmg basis that materially afTect the content of the license renewal application.
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. e Document Control Desk-January 21,1998 Page 2, in Reference (a), Baltimore Gas and Electric Company submitted the IPA Methodology for review and
- approval.- In Reference (b), the Nuclear Regulatory Commission (NRC) concluded that the IPA Methodology is acceptable for meeting 10 CFR 54.21(aX2) of the license renewal rule, and if -
Implemented, provides reasonable assurance that all structures and components subject to an aging-management review pursuant to 10 CFR 5_4.21(aXI) will be identified. Additionally, the NRC concluded that the methodology provides processes for demonstrating that the effects of aging will be adequately managed pursuant to 10 CFR 54.21(aX3) that are conceptually sound and consistent with the intent of the license renewal rule.
In. Reference (c), the NRC stated that if the format and content of these reports met the requirements of the template developed by BGE, the NRC could begin the technical review. This report has been produced and formatted in accordance with these guidance documents. We look forward to your comments on the reports as they are submitted and your continued cooperation with our license renewal efforts.
. o.
Document Control Desk January 21,1998 Page 3 ;
Should you have questions regarding this matter, we will be p' eased to discuss them with you.
Very truly yours,
,. g h ArP STATE OF MARYLAND :
- TO WIT:
COUNTY OF CALVERT :
.1, Charles 11. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this response on behalf of BGE. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowleuge, they are based upon information provided by other BGE employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it be reliable.
s v/' . 4mL
/ r Stypscribed and swom before me, a Notary Public in and for the State of Maryland and County of LL/utAL ,thisc 0/Vday ofG6rnaro ,1998.
0 0 s WITNESS my lland and Notarial Scal: MC #
Notary Public U o
My Commission Expires: k.O 4 eta 41 / ,M OdA O' () ate CilC/DLS/ dim Attachments: (1) 5.6 Containment Spray System (2) 5,8 Emergency Diesel Generator System (3) 5.1IC Control Room and Diesel Generator Buildings' ileating, Ventilation, and Air Conditioning Systems (4) 6.4 Instrument Lines cc: R. S. Fleishman, Esquire II. J. Miller, NRC J. E. Silberg, Esquire Resident inspector, NRC Director, Project Directorate I-1, NRC R.1. Mc Lean, DNR A. W. Dromerick, NRC J. II. Walter, PSC D. L. Solorio, NRC
_ _ _ . _ _ _ _ _ J
ATTAC11 MENT (1)
APPENDIX A - TECIINICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM Baltimort 5 -
and Electric Company Calvert Ct.as Nuclear Power Plant January 21,1998
ATTACilMENT (1)
APPENDIX A - TECilNICAL INI'ORMATION 5.6 CONTAINMENT SPRAY SYSTEM 5.6 Containment Spray System This is a section of the Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA), addressing the Containment Spray (CS) System. The CS System was evaluated in accordance with the Calvert Cliffs Nuclear Power Plant (CCNPP) Integrated Plant Assessment (IPA) Methodology described in- Section 2.0 of the BGE LRA. These sections are prepared independently and will, .
collectively, comprise the entire BGE LRA. !
5.6.1 Scoping j System level scoping describes conceptual boundaries for plant systems and structures, develops screening tools which capture the 10 CFR 54.4(a) scoping criteria, and then applies the tools to identify systems and structures within the scope of license renewal. Component level scoping describes the components within the boundaries of those systems and structures that contribute to the~ intended functions. Scoping to determine components subject to aging management review (AMR) begins with a listing of passive intended functions and then dispositions the component types as either only associated with act!ve functions, subject to replacement, or subject to AMR either in this report or another report.
Representative historical operating experience pertinent to aging is included in appropriate areas to provide insight supporting the aging management demonstrations. This operating experience was ,
obtained through key word searches of BGE's electronic database ofinformation on the CCNPP dockets !
and through documented discussions with currently assigned cognizant CCNPP personnel.
1 Section 5.6.1.1 presents the results of the system level scoping; 5.6.1.2 the results of the component level scoping; and 5.6.1.3 the results of scoping to determine components subject to an AMR.
5.6.1.1 System Level Scoping
'this section begins with a description of the system which includes the boundaries of the system as it was scoped. The intended functions of the system are listed and are used to define wha: portions of the system are within the scope oflicense renewal.
System Descrintion/Concentual Loundaries The major function of the CS System is to limit the pressure and temperature of the containment atmosphere so the associated design limits are not exceeded following Design Basis Events (DBEs).
This function is performed by spraying cold borated water into the containment atmosphere. The CS j System is also utilized to remove heat from the Reactor Coolant System (RCS) during plant cooldown once RCS temperature is below 300'F, and to maintain the RCS temperature during cold shutdown and !
refueling operation modes. During normal plant operations, the CS System is maintained in a standby mode. [ Reference 1, Section 1.1.l]
1he mejor components of the CS System for each CCNPP Unit are two electric motor-driven pumps, two shutdown cooling heat exchangcrs (SDCilXs), two CS headers that include spray rings ar.d nozzles inside containment, and associated piping, valves, controls and instrumentation. [ Reference 2,
-Section 6.4.2)
In the early 1990s, the SDCIIX tubes were found to rattle at high cooling water Dowrates. [ Reference 3]
Initially, cooling water flow was throttled using butterfly valves at the SDCHX inlet to reduce tube Application for License Renewal 5.6-1 Calvert Cliffs Nuclear Power Plant i
AIL 4CllMENT .(1)
APPENDIX A TECIINICAL INFORMATION 5.6 CONTAINMENT SPRAY SYSTEM rattling. Ilowever, these valves were not capable of maintaining the desired flow rates without
^
occasionally drilling out of position. To provide a wider control band for the valves while preventing tube rattling, the SDCilXs were disassembled during the 1992 and 1993 refueling outages (for Units I and 2, respectively), and the tubes were staked with helical spacers that stiffened the entire tube assembly. Plant Engineering representatives inspected the internal surfaces of the EDCilXs when the shells were umoved, and no signs of excessive tube wear were noted.
In the past, the inboard containment isolation check valves in the CS ring headers have failed leakage "
testing. Following several analyses, the root cause of these failures was attributed to valve discs that were too light to rescat after securing fiow during the tests. During the 1997 Unit 2 refueling outage, a new (heavier) disc design was incorporated in these valves. While the valves were disassembled, no signs of wear were noted on the discs er the seats.
Many other CS Sbtem components have been disassembled over the plant's operating history with no unusual or unexpected signs of wear or degradation noted.
The CS System is composed of the following general categories of equipment and devices:
[ Reference 1, Section 1.1.2]
Instruments Measure and indicate system flow rates, temperatures, and pressures; lleat Exchangers Provide a heat sink for post-accident containment heat removal or normal shutdown cooling (SDC) operations; Piping Convey borated water to/from the SDC11Xs and to the CS headers; Pumps Provide motive force to move borated water through the system; cnd Valves Control valves (CVs), check valves (CKVs), hand valves (liVs), motor-operated valves (MOVs), relief valves (RVs), and solenoid valves, which provide containment isolation and system alignment / isolation.
Svstem Interfaces The CS System has interfaces with eight plant systems. [ References 4 through 9] These interfaces and their applicability for license renewal are discussed below.
The following interfaces with the CS System are within the scope oflicense renewal:
- Engineered Safety Features Actuation System (ESFAS). [ Reference 1, Section 1.1.2] 7e ESFAS supplies control signals to CS System components in response to DBE condition.. A signal starting the CS pumps is provided when a Safety injection Actuation Signal has been generated. A signal opening the CS header isolation CVs is provided when a Containment Spray Actuation Signal (CSAS) has been generated. [ Reference 2, Section 6.4.4] This interface involves cables / conduits associated with transmitting the ESFAS signals to the CS System an<l controls associated with the pumps and valves.
Safety injection (SI) System. [ Reference 1, Section 1.1.2] The CS System piping has several interfaces with the SI System. On CS pump start in response to a Safety injection Actuation Signal, the SI System provides borated water to the CS pump suction header from the refueling water tank (RWT). Prior to initiation of a CSAS, flow from the CS pump returns to the RWT Application for License Renewal 5.6-2 Calvert C!iffs Nuclear Power Plant
ATTACllMENT m APPENDIX A - TECilNICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYETEM through the CS pump mini-flow return CKVs. [ Reference 2, Section 6.4.4] When the inventory in the RWT is nearly depleted, a Recirculation Actuation Signal (RAS) is generated 'i the ESFAS. After a RAS initiation, operators may choose to diven a portion of the cooled water from the CS headers to the suction of the high pressure SI (llPSI) pumps. [ Reference 2, Section 6.3.1] In the SDC mode of operation, borated water from the low-pressure SI (LPSI) pump discharge header Oo,vs through the SDCliX to the LPSI return header on its way into the RCS cold leg. [ Reference 2, Section 9.2.1] Additional connections to the SI System allow Dow:
(a) from the SDC return header to flow instrumentation in the SI System Dowpath used during purification; (b) from the SDC return header to the RWT return header; and (c) from the CS header to the RWT return header. [ Reference 10 Sections 6.11 and 6.12; Reference 11, Section 6.5: Reference 12, Section 6.2]
- Component Cooling (CC) System. [ References 13 and 14] The CC System provides flow to the SDCilXs following a RAS initiation and during SDC operation. [ Reference 2, Section 9.2.1]
- Spent Fuel Pool (SFP) Cooling System. [ Reference 15] The CS System piping from the SDC return header interfaces with the SFP Cooling System, allowing the SDCHXs to provide additional SFP cooling when the complete core is removed from the reactor vessel and temporarily stored in the SFP. [ Reference 2, Section 9.2.1; Reference 12]
The following interfaces with the CS System are not within the scope of licce cenewal:
- Primary Containment Ileating and Ventilation System. A second CS System piping interface with the Primary Containment lleating and Ventilation System is found where the emergency dousing noules provide spray for the iodine removal units inside containment.
- Chemical and Volume Control System. The CS System piping leading to the emergency dousing nonles for the iodine removal units interfaces with the excess flow CKV test connections in the Chemical and Volume Control System. [ Reference 16]
- Compressed Air System. The CS System piping leading to the emergency dousing nonles for the iodine removal units inside Unit I containment interfaces with a service air connection in the Compressed Air System; a similar connection in Unit 2 has been permanently capped.
[ Reference 17]
Figure 5.61 is a simplified diagram of the CS System and is provided for information only. This Ogure depicts the major CS System components and interfaces discussed above.
Application for License Renewal 5.6-3 Calvert Clifts Nuclear Power Plant
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ATTACHMENT (1)
APPENDIX A - TECHNICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM WSLR-within the scope oflicense h
- renewal !
I AUXILIARY
- CONTN ~ BunciNo BOLD UNES indicate cconinis.3 e
< > that are WSLR for CS Systern.
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FIGURE 5.6-1 l CONTAINMENT SP2AY SYSTEM
!' (SIMPLIFIED DIAGRAM - FOR INFORMATION ONLY)
Application for License Renewal .5.6-4 Calvert Cliffs Nucicar Power Plant .;
A'ITACHMENT (1)
APPENDIX A - TECHNICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM n_ .
System Sconing Results The CS System is in scope for license renewal based on 10 CFR 54.4(a). The following intended functions of the CS System were determined based on the requirements of f54.4(aXI) and (2) in accordance with the CCNPP IPA Methodology Section 4.1.1: [ Reference 18, Table 1]
- To provide containment pressure control and cooling;
- To provide containment isolation;
- To maintain electrical continuity and/or provide protection of the electrical system;
- To maintain the pressure boundary of the system (liquid and/or gas); and
. To restrict now to specified value in support of the DBE response.
The following intended functions of the CS System were determined based on the requirements of
$54.4(aX3): [ Reference 18, Table 1]
. To provide RCS heat removal to ensure safe shutdown in the event of a postulated severe fire;
- To provide information used to assess the environs and plant condition during and following an accident; and e To maintain functionality of electrical components as addressed by the Environmental Qualification Prograrn.
All components of the CS System that meet the environmental qualification criteria of 54.4(aX3) are also safety-related. Some of the components that meet the fire protection criteria are non-safety-related and are within the scope oflicense renewal only because of the 54.4(aX3) criteria.
All components of the CS System that perform functions based on the requirements of Q54.4(aXI) and(2) meet Seismic CategoryI requirements. [ Reference 2, Section 6.4.4; References 4 through 9; References 16 and 19] All CS System piping complies with the design requirements for Class 11 piping in American Nuclear Standards Institute (ANSI) Nuclear Power Piping Code B31.7,1969..
[ Reference 20, Piping Class llc-4; Reference 21, Piping Class HC-33; Reference 22, Piping Class HC-38; Reference 23, Piping Classes GC-1, GC-2, GC-3, and GC-7] The design parameters for the major CS System components are presented in Section 6.3.2.5 and 6.4.2 of the CCNPP Updated Final Safety Analysis Report.
5,6.1.2 Component Level Scoping Based on the intended 6metions listed above, the portion of the CS System that is within the scope of license renewal includes all components (electrical, mechanical, and instrument) and their supports along the following system flowpaths (refer to Figure 5.6-1): [ Reference 2, Sections 6.3.1 and 9.2.2; References 4 through 9; Reference 18, Table 2]
- Shutdown cooling mode flowpath (motive force provided by LPSI pumps)- from the SI System interface at the outlet of the SDCHX LPSI inlet MOV, through the SDCHXs, up to and including the SDC temperature / flow CV, which returns flow to the LPSI header; Application for License Renewal 5.6-5 Calvert Cliffs Nuclear Power Plant
. -_ ~ . - - - .- -- ...
ATTACHMENT (1)
APPENDIX A TECIINICAL INFORMATION
- 5.6 - CONTAINMENT SPRAY SYSTEM e Minimum-flow recirculation Dowpath (post-DBE operations prior to a CSAS; motive force provided by CS pumps)- from the CS pump discharge header up to and including the CS pump mini-flow return CKVs; and e injection mode flowpath (post DBE operations afler a CSAS; motive force provided by CS pumps)- from the SI System interface at each CS pump inlet, through the CS pumps, SDCIIXs, up to and including the following:
Brough the CS headers to the nozzles installed in the inner and outer CS ring headers; or To the SDC-to llPSI suction MOVs, which allow operators to return a portion of the cooled water from the CS System to the suction of the IIPSI pumps during post DBE operations afler a RAS.
Additional components that form parts cf the system pressure boundary along these flowpaths (e.g., piping, flow orifices, normally closed 11Vs) and their supports are also included within the scope of license renewal for the CS System.
The following 33 device types in the CS System have at least one intended function: [ Reference 1, Table 21]
. Class "GC" Piping (stainless steel, primary rating 300 psig at 1125*F)
. Class "IIC" Piping (stainless steel, primary rating 150 psig at 500 F)
- Check Valve . Power Lamp Indicator
. Coil . 4kV Motor
. Control Valve -
125/250Vdc Motor
. Control Valve Operator
- Motor Operated Valve
. Voltage / Current Device .
Motor Operated Valve Operator
. Flow Element
- Pressure Switch
- Flow Indicator .
Pressure Transmitter
. Flow Orifice .
Pump / Driver Assembly
. Flow Transmitter .
ReliefValve Fuse .
Relay
. Iland Indicator Controller .
Solenoid Valve e llandswitch -
Temperature Element Hand Valve . Temperature Indicator a lleat Exchanger
- Position Indicating Lamp
. Current / Pneumatic Device . Position Switch
. Ammeter Some components in the CS System are common to many other plant systems and have been included in separate sections of the BGE LRA that address those components as commodities for the entire plant.
These components include the following: [ Reference 1, Section 3.2]
- Except for the SDCilX supports that are addressed in this report, structural supports for piping, cables, and components are evaluated for the efTects of aging in the Component Supports Commodity Evaluation in Section 3.1 of the BGE LRA.
- Electrical cont ol and power cabling are evaluated for the effects of aging in the Electrical Cables Commodity Evaluation in Section 6.1 of the BGE LRA. This commodity evaluation completely Application for License Renewal 5.6-6 Calvert Cliffs Nuclear Power Plant
4 ATTACilMENTJ1)
APPENDIX A - TECilNICAL INIORMATION 5.6 CONTAINMENT SPRAY SYSTEM addresses the passive intended function entitled " maintain electrical continuity and/or provide protection of the electrical system" for the CS System.
- Instrument tubing and piping and the associated tubing supports, instrument valves and fittings (generally everything from the outlet of the final root valve up to and including the instrument),
and the pressura boundaries of the instruments themselves, are all evaluated for the effects of aging in the Instrument Lines Commodity Evaluation in Section 6.4 of the BGE LRA. This commodity evaluation partially addresses the passive intended function entitled " maintain the pressure boundary of:he system (liquid and/or gas)" for the CS System.
5.6.1.3 Components Srbject to AMR This section describes the componcnts within the CS System that are subject to AMR. It begins with a listing of passive ,nded functions and then dispositions the device types as eithu only associated with active functions, subject to replacement, evaluated in other reports, evaluateo in commodity reports, or remaining to be evaluated for aging management in this section.
Panive Intended Functions lu accordance with CCNPP IPA Methodology Section 5.1, the foMowing CS System functions were determined to be passive: (Reference 1, Table 3 1]
- To maintain electrical continuity and/or provide protection of the electrical system; e To maintain the pressure boundary of the system (liquid and/or gas); and e To restrict flow to specified value in support of the DBE response.
Device Tynes Subject to AMR Of the 33 device types within the scope oflict ise renewal for the CS System: (Reference 1, Table 3-2; Reference 24, Attachment 4A]
- Seventeen device tmes were associated with only active functions: Coil, Control Valve Operator, Voltage / Current Device, Flow Indicator, Fuse, lland Indicator Controller, llandswitch, Current / Pneumatic Device, Ammeter, Power Lamp Indicator,4kV Motor, 125/250Vdc Motor, Motor Operated Valve Operator, Relay, Solenoid Valve, Position Indicating Lamp, and Position Switch;
- No device types were identified as subject to periodic replacement based on a qualified life or specified time period; e No device types in this system were evaluated in the AMR for a system addressed in another section of the BGE LRA; and
- Three device types are associated with a separate commodity evaluation. Flow Transmitters, Pressure Switches, and Pressure Transmitters in the CS System are evaluated separately in the Instrument Lines Commodity Evaluation in Section 6.4 of the BGE LRA.
The remaining 13 device types, listed in Table S.6-1, are subject to AMR arid are included in the scope of this section. [ Reference 1 Table 3 2] Except for HVs and fos, all components of each listed device type are addressed in this section. The Unit 1 CS header drain valve flow orifices, as well as manual drain, equalization, and isolation valves in CS instrument lines that are subject to AMR, are evaluated for Application for License Renewal S.6-7 Calvert Cliffs Nuclear Power Plant
ATTACHMENT (1)
APPENDIX A TEC11NICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM the effects of aging in the instrument Lines Commodity Evaluation in Section 6.4 of the BGE LRA. The manual root valves that are used to isolate these components are evaluated in this section. [ Reference 24, Attachments 4 and 4A)
Baltimore Gas and Electric Company may elect to replace components for which the AMR identifies that further analysis or examination is needed. In accordance with the License Renewal Rule, components subject to replacement based on qualified life or specified time period would not be subject te AMR.
Table 5.6-1 CONTAINMENT SPRAY SYSTEM DEVICE TYPES SUBJECT TO AMR Class "GC" Piping ( GC)
Class "IIC" Piping ( ilC)
Check Valve (CKV)
Control Valve (CV)
Flow Element (FE)
Flow Orifice (FO) liand Valve (ilV)
IIcat Exchanger (liX)
Motor Operated Valve (MOV)
Pump / Driver Assembly (PUMP)
Relief Valve (RV)
Temperature Element (TE)
Temperature Indicator (TI) ,
5.6.2 Aging Maangement The list of potential Age-Related Degradation Mechanisms (ARDMs) identified for the CS System components is given in Table 5.6 2, with plausible ARDMs identified by a check mark (/) in the appropriate device type column. [ Reference 1, Table 4-2] A check mark indicates that the ARDM applies to at least one component for the device type listed. For efficiency in presenting the results of these evaluations in this report, ARDM/ device type combinations are grouped together where there are similar characteristics and the discussion is applicable to all components. Table 5.6-2 also identifies the grom to which each ARDM/ device type combination belongs. Exceptions are noted where appropriate.
The following groups have been selected for the CS System:
Group 1: general corrosion of external surfaces due to leakage of borated water; and Group 2: general corrosion. crevice corrosion. and/or oitting of internal surfaces exposed to chemically-treated water.
' Some components in the SDC flowpath experience significant thermal transients during SDC operations.-
- Since the CS System vent / drain llVs and instruments connected to the SDC flowpath are generally thin wall components, they do not experience large temperature gradients under SDC initiation conditions, and fatigue is not a concern. For the CS System components in the SDC flowpath (i.e., the SDCilXs, the associated piping, temperature instruments, and valves), fatigue usage is bounded by the fatigue usage of the SIX' and Si nozzles that connect SI System piping to the RCS. These nozzles are Application for License Renewal 5.6-8 Calvert Cliffs Nuclear Power Plant
ATTACllMENT m APPENDIX A - TECilNICAL INFORMATION 5.6 CONTAINMENT SPRAY SYSTEM __
among the 11 fatigue-critical locations selected for monitoring under the CCNPP Fatigue Monitoring Program, and represent the most bounding locations for the thennal transients for components in the SDC Dowpath. [ Reference 25; Reference 26, Sections 1.1,1.2.A,2.1.E,6.0) Analysis has determined that up to 500 SDC initiation transients, each consisting of a rapid temperature rise from ambient (about 70*F) to RCS temperature (no greater than 300'F), are allowed over the service life of the components in the SDC flowpath. Partial thermal cycle analysis projections out to 60 years, based on actual occurrences to date, estimate the number of effective full cycles to be approximately 10% of the total allowable. Since the normal and design operating conditions applied to these components do not result in the quantity of cycles or the loading conditions (mechanical, vibrational, thermal, and/or pressure) necessary to cause significant degradation, fatigue is not plausible for the CS System.
Since the CS pump discharge piping and the HPSI pump suction piping from the SDC11X discharge may not have any flow due to flushing or performance testing for periods of at least 30 days during normal reactor operation, they were recognized as portions of the CS System with a high likelihood of containing stagnant oxygenated borated water. Inservice inspections and additional examinations have concluded that the integrity of welds in this piping has not been affected by service environment and residual stresses that have induced pipe cracking in the industry. [ References 27 and 28]
Application for License Renewal 5.6-9 Calvert Cliffs Nuclear Power Plant
ATTACllMENT (1)
APPENDIX A TECIINICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM Table 5.6-2 POTENTIAL AND PLAUSIBLE ARDMs FOR Tile CONTAINMENT SPRAY SYSTEM Device Types Not Potential ' - - C C F F - II H M P R T T Plausible ARDMs G II K V E O V- 'X 0 U V E I for System C C V V M P
Cavitation Erosion x Corrosion fatigue x Crevice Corrosion /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2)
Dynamic Loading x Erosion Corrosion x fatigue x i ouling x Galvanic Corrosion x General Cmosion /g) /(1) /(1) <(1) /(1) /(*) /(1) /(1) liydrogen 1)amage x Intergranular Attack x Microbiologically. x Induced Corrosion Particulate Wear x Erosion Pitting /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2) /(2)
Radiation Damage x Rubber / Elastomer x Degradation Saltwater Attack x Selective Leaching x Stress Corrosion x Cracking
'Ihermal Damage x Thermal x Embrittlement Wear x
/ indicates plat.sible ARDM determination for this device type (number) Indicates the group in which th!s ARDM/ device type combination is evaluated
(*) indicates that both Groups I and 2 evaluate components within this ARDM/ device type combination Note: Not every component within a device type may be susceptible to a given ARDM. This is because components (and subcomponents) within a device type are not always fabricated from the sama materials nr subjected to the same environments. Exceptions for each device type will be indicated in the aging management subsection for each ARDM diseassed in this report.
Application for License Renewal 5.6-10 Calvert Cliffs Nuclear Power Plant
AWACHMENT (1)
APPENDIX A - TECHNICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM The following is a discussion of the aging management demonstration process for each group identified above. It is presented by group and includes a discussion of materials and environment, aging mechanism effects, methods of managing aging, aging management program (s), and aging management .
demonstration.
- Group 1 - (general corrosion of external surfaces)- Materials and Environment Group 1 comprises the various CS System components that are exposed to climate-controlled air in the Auxiliary Building or the Containment, and whose extemal surfaces are subject to general corrosion.
The components in this group are meluded in the -GC, -HC, CKV, CV, HV, llX, MOV, and PUMP device types. All of these components provide the passive intended function of maintaining the system pressure boundary. [ Reference 1, Attachment 1] For the HXs, the susceptible subcomponents include alloy steel studs, carbon steel nuts and vessel supports, and the external surfaces of the carbon steel shell assembly and associated carbon steel welds. [ Reference 1, Attachments 4 and 5 for HXs] The applicable subcomponents for all other device types in this group are carbon steel nuts and/or alloy steel studs. [ Reference 1. Attachments 4 and 5 for -GC Piping HC Piping, CKVs, CVs, HVs, MOVs, and PUMPS]
The external surfaces evaluated in Group 1 are not normally exposed to a corrosive environment, but may be exposed to boric acid as a result of leakage from the associated components or nearby systems and components that contain borated water. The possible effects of such leakage include general corrosion of susceptible external surfaces. A potential source of borated water leakage is the internal environment for the components in Group 1, with maximum operating pressures as high as 450 psig, and normal operating temperatures as high as 300 F. [ Reference 1, Attachment 6s for -GC Piping, -IIC Piping, CKVs, CVs, llXs, HVs, MOVs, and PUMPS; Reference 20, Piping Class HC-4; Reference 21, Piping Class 11C.33; Reference 22, Piping Class HC-38; Reference 23, Piping Classes GC-1, GC-2, GC-3, and GC-7]
iv; all components evaluated in Group 1, the external surfaces are exposed to an environment of climate-controlled air in either the Auxiliary Building or the Containment. [ Reference 1, Attachment 3s]
During nonnal operation, temperature and humidity in the Auxiliary Building do not exceed 160'F and 70%, respectively. [ Reference 29, page 54] For the general areas inside Containment where CS System components are located, the maximum normal temperature and hum'dity values are 120 F and 70%,
respectively. [ Reference 29, pages 29,30,62, and 63]
Group 1 -(general corrosion of external surfaces)- Aging Mechanism Effects General corrosion is thinning of a metal by the chemical attack of an aggressive environment at its surface. An important concem for pressurized water reactors is boric acid attack upon carbon steels and low alloy steels. General corrosion is not a concern for austenitic stainless steels. [ Reference 1, Attachment 7s for -GC Piping,-IIC Piping, CKVs, CVs, HXs, HVs, MOVs, and PUMPS]
' General corrosion is plausible for all carbon steel and alloy steel subcomponents in this group.
= Mechanical joints in pressure boundary subcomponents provide tH opportunity for leakage of borated water onto external component surfaces. The carbon str' r toy steel surfaces are particularly susceptible to significan' acceleraticn of corrosion when exi . a boric acid in the concentrations Application for License Renewal 5.6-11 Calvert CliiTs Nuclear Power Plant
ATTACllMFNT (1)
APPENDIX A - TECilNICAL INFORMATION 5.6 CONTAINMENT SPRAY SYSTEM present in the CS System. [ Reference 1, Attachment 6s for GC Piping, IlC Piping, CKVs, CVs, liXs, IIVs, MOVs, and PUMPS)
The result of this corrosion mechanism is a reduction in the integrity of the corroded parts and a resulting (acrease in the likelihood of mechanical failure. If unmanaged, long-term exposure to general corrosion could eventually result in loss of the press re-retaining capability under cr.rrent licensing baeis (CLB).
design loading conditions.
Group I -(general corrosion of external surfaecs)- Methods to Manage Aging Mitigntion: Boric acid corrosion can be mitigated by minimizing leakage. The susceptible area; of the CS System (i.e., mechanical joints) can be routinely observed fc signs of borated water leakage, and appropriate corrective action can be initiated as necessary to eliminate leakage, clean spill areas, and assess any corrosion. [ Reference 1, Attachment 6s for -CC Piping, -lIC Piping, CKVs, CVs, liXs, ilVs, MOVs, and PUMPS]
Discoserv: The effects of corrosion are generally detectable by visual techniques. Visual inspections would need to be performed to detect corrosion associated with leakage of fluids onto the external surfaces of CS System components. [ Reference 1, Attachment 6s for -GC Piping -IlC Piping, CKVs, CVs, llXs, IIVs, MOVs, and PUMPS]
Group 1 -(general corrosion of external surfaces)- Aging Management Program (s)
Mitigetion: The CCNPP Boric Acid Corrosion Inspection (BACl) Program (MN-3-301) is credi*ed with mitigating the effects of boric acid corrosion through timely discovery of leakage of borated water and removal of any boric acid residue that is found. [ Reference 1 Attachment 8] This program requires visual inspection of the components containing boric acid for evidence of leaks, quantification of any leakage indications, and removal of any leakage residue from component surfaces. [ Reference 30]
Further details on the BACI Program au detailed in the Discovery subsection below.
Discomy- Discovery of boric acid leakage is ensured by the BACI Program. [ Reference 1, Attachment 8] This program also requires investigation of any leakage that is found. A visual examination of external surfaces is performed for components containing boric acid. [ Reference 30]
The Inservice Inspection Program required the establishment of the BACI Program to systematically ensure that boric acid corrosion does not degrade the primary system boundary. [ Reference 3!,
Section 5.8.A.I.] The program also applies to " valves in systems containing borated water which could leak onto Class I carbon steel components," and it identifies other plant areas to be examined.
[ Reference 30, Section 5.lB] The program controls examination, test methods, and actions to minimize the loss of structural and pressure-retaining integrity of components due to boric acid corrosion.
[ Reference 30, Section 3.0.C] The basis for the establishment of the program is Generic Letter 88-05, "Bc;ic Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants."
[ Reference 30, Section 1.1]
The scope of the program is threefold in that it: (a) identifies locations to be examined; (b) provides examinath.n requirements and methods for the detection ofleaks; and (c) provides the responsibilities for iritiating engineering evaluations and necessary corrective actions. [ Reference 30, Section 1.2]
Application for License Renewal 5.6-12 Calvert Cliffs Nuclear Power Plant
ATTACHMENT (1)
APPENDIX A - TECHNICAL INFORMATJON 5.6. CONTAINMENT SPRAY SYSTEM
- During each refueling outage, inservice inspection personnel perfonn r, walkdown inspection to identify and quantify any leakage found at specific locations ir. side the Containment and in the Auxiliary Building. The inservice inspection ensures that all comoonents, where boric acid leakage has been previously documented, are also examined in accordance witt the requirements of this program. A
- second inspection of these components is performed prior to phnt startup (at normal operating pressure and temperature) ifleakage was identined previously and corrective actions were taken. [ Reference 30, Sections 5.1 and 5.2]
Under the BACI Program, the walkdown inspections applicable to CS System components are type VT 2 (a type of visual examination described in ASME Section XI, IWA 2212). The VT-2 visual a examinations include the accessible external exposed surfaces of pressure-retaining, non-insulated components; Coor areas or equipment surfaces located underneath non-insulated components; vertical surfaces of insulation at the lowest elevation where leakage may be detected, and horizon:al surfaces at each insuletion joint for insulated compoacnts; floor areas and equipment surfaces beneath components
, and other areas where water may be channeled for insulated components whose external insulation surfaces are inaccessible for direct examination; and for discoloration or residue on any surface for evidence of boric acid accumulation. [ Reference 30, Section 5.2]
If either leakage or corrosion is discovered, issue reports (IR*) are generated in accordance with CCNPP procedure Ql-2-100, " Issue Reporting and Assessment," to document and resolve the deficiency.
Corrective actions address the removal of boric acid residue and inspection of the afTected components for general corrosion. If general corrosion is found on a component, the IR provides for evaluation of the component for continued _ service and corrective actions to preven ( recurrence. [ Reference 30, Section 5.3] ,
The BACI Program has evolved with regard to boric acid leaks discovered during other types of walkdowns and inspections. The progra.n specifies the minimum qualification level for inspectors evaluating boric acid leaks. Appaent leaks that are discovered during these other wulkdowns/ inspections are documented in IRS by the individual discovering the leak. These irs are then routed to the inservice inspection group fbr ek.ser inspection and evaluation by a qualified inspector.
This approach provides for more boric acid leakage inspection coverage while still ensuring that appropriately quali0ed individuals assess and quantify any resultant damage, The corrective actions taken as a result of irs under this program will ensure that CS System components containing borated water remain capable of performing their intended function under all CLB conditions during the period of extended operation.
Group 1 -(general corrosion of external surfaces)- Demonstration of Aging Management Based on the information presented above, the following conclusions can be reached with respect to general corrosion of external surfaces for CS System components:
- The components in Group 1 contribute to maintaining the system pressure boundary, and their integrity must be maintained under all CLB design conditions.
- The materials of construction for subcomponents in this group are carbon steel or alloy steel.
Application for License Renewal 5.6-13 Calvert Clifts Nu' $ar Power Plant r-
ATTACllMENT (1)
APPENDIX A - TECilNICAL INFORMATION ,
5.6 - CONTAINMENT SPRAY SYSTEM e General corrosion is a plausible ARDM for this group because the susceptible external surfaces are exposed to potential borie acid leakage from mechani'al joints, if unmanaged, this ARDM could eventually result in the loss of pressure-retaining capability under CLl3 design loading conditions.
- 'lhe cormsive effects of boric acid leakage will be managed by means of the BACI Program.
When boric acid leakage is identified, either through required program inspections or through irs resulting from other types of walkdowns and inspections, this program will ensure that co rosion indaced by boric acid is discovered and that appropriate corrective action is taken.
Therefore, there is a reasonable assurance that the efTects of general corrosion will be adequately ,
managed for external surfaces of CS System components such that they will be capable of performing 1 their miended functions consistent with the CLB during the feriod of extended operation under all design
, loading conditions.
Group 2 -(general corrosion, crevice corrosion, and/or pitting ofinternal surfaces)- Materials and Environment Group 2 comprises the various CS System components that are exposed to chemically treated water and whose internal surfaces are subject to general corrosion, crevice corrosion, and/or pitting. Components from all CS System device types are included in this group. The internals for the containment isolation CKVs in the CS headers provide a containment pressure-boundary function when the injection mode flowpath is not active. The remaining components provit the passive intended function of maintaining ;
the system pressure boundary. [ Reference 1, Attachment 1) The applicable subcomponents in these device types are constructed of the following materials: (Reference 1, Attachments 4 and 5 for all device i types]
- Piping - internal surfaces of sta:nless steel fittings and flanges, as well as hidden surfaces of carbon steel nuts and alloy steel studs; e CKVs - internal surfa: s of stainless steel body / bonnet, as well as hidden surfaces of carbon steel nuts and alloy steel studs; also, stainless steel internals for containment isolation CKVs in the CS headers; e CVs - internal surfaces of stainless steel body / bonnet and stem, as well as hidden surfaces of carbon steel nuts and alloy steel studs; e FEs - stainless steel; e fos - stainless steel orifice plates; e llVs - internal surfaces of rtainless steel body / bonnet and stem, as well as hidden surfaces of carbon steel nuts and alloy steel studs, for all llVs except for normally open instrument root and seal leakoff stop IIVs; also, stainless steel disc / seat for normally closed liVs; e llVs - internal surfaces of stainless steel body / bonnet and stem, as well as hidden surfaces of carbon steel nuts and stainless steel studs for normally open instrument root and seal leakoff stop liVs;
- IlXs - stainless steel tubes, channel assembly /tubesheet and welds; internal surfar : of the carbon steel shell assembly and carbon steel welds; hidden surfaces of carbon steel c., ud alloy steel studs; Application for License Renewal 5.6-14 Calvert Cliffs Nuclear Power Plant
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ATTACllMENT (1) f APPENDIX A TECHNICAL INFORMATION
!.6 - CONTAINMENT SPRAY SYSTEM e MOVs - internal surfaces of stainless steel body / bonnet and stem, as well as hidden surfaces of carbon steel nuts atJ alloy steel studs;
- PUMPS - internal surfaces of the mechanical seal (stainless steel, with stellited rotating face);
stainless steel casing and shaA; hidden surfaces of carbon steel nuts and alloy steel studs; e RVs - Inconel disc and guide / ring; internal surfaces of stainless steel base and cylinder;
- TEs stainless steel; and e Tis - stainless steel well.
Except as noted below, the internal surfaces ior all components evaluated in Group 2 are exposed to the borated water environment described in subsection Group 1 - Materials and Environment, above. For the SDCilXs, the internal environmen' includes chemically-treated water from the CC System between the inside of the shell and 'he outside of the tubes that contain the borated water. The CC System has a design pressure of 150 psig and maximum operational temperature of 167'F. [ Reference 1, Attachment 3s for IIXs; Reference 32, Piping Class 11B-23] Since the CS System is maintained in a standby mode during normal operations, stagnant conditions exist throughout the system. Stagnant conditions may allow impurities in the process Guid to concentraie. [ Reference 1, Attachment 6s for all device types]
Gronp 2 - (general corrosion, erevice corrosion, and/or pitting of vernal surfaces) - Aging Mechanism Effects __
General corrosion is described in subsection Group 1 - Aging Mechanism Effects, above. Crevice corrosion and pitting are related forms of intensive, localized corrosion. Crevice corrosion occurs in crevices that are wide enough to permit liquid entry and narrow enough to maintain stagnant conditions.
Such locations may include spaces under nuts and/or bolt heads, holes, gasket surfaces, lap joints, !
surface deposits, designed crevices for attaching thermal sleeves to safe-ends, and integral weld backing l rings or back up bars. Pitting occurs when corrosion proceeds at one small location at a rate greater than l the corrosion rate of the surrounding area. Pitting is an autocatalytic process that produces conditions !
that stimulate the continuing activity of the pit. In either case, the stagnant Duid within the pit or crevice l tends to accumulate corrosive chemicals such as chlorides and sulfates, and thereby to accelerate the !
local corrosion process. Crevice corrosion can initiate pitting in many cases. Pitting can result in complete perforation of the material. [ Reference 1, Attachment 7s for all device types]
Crevice corrosion and pitting are plausible for all subcomponents in this group. Additionally, general corrosion is plausible for the internal carbon steel surfacer of the SDCHXs. These ARDMs are plausible at mechanical joints (e.g., Banges, body / bonnet joints) since they present a crevice geometry at the se iing surfaces that may allow process Guids to stagnate and caus concentration of environmentally-produced impurities. [ Reference 1 Attachment 6s for -GC Piping, -lIC Piping CKYs, CVs, FEs, fos, ilVs, MOVs, PUMPS, and RVs] Similar stagnation and impurity deposits are possible at other
-component interior crevices that are formed by close-fitting interface points at interio: ;ubcomponents (e.g., tubes /tubesheets in llXs, fittings in piping, pump shans, valve stems, valve seating surfaces).
[ Reference 1, Attachment 6s for -GC Piping, -HC Piping, CVs, ilVs, HXs, MOVs, PUMPS, RVs, TEs,
- and tis]
Application for License Renewal 5.6-15 Calvert Cliffs Nuclear Power Plant
ATTACIIMENT (1)
APPENDIX A - TECilNICAL INFORMATION 5.6 CONTAINMENT SPRAY SYSTEM Group 2 - (genebrrosion, erevice corrosion, and/or pitting of internal surfaces) - Methods to
- Manage Aging
- Mitigation: Control of Duid chemistry in the CS System and interfacing systems can significantly limit the LTects of gene.al corrosion, crevice corrosion, and pitting. (Reference I, Attachment 6s for all device types] T}.c chemistry control program should monitor pertinent chemical parameters on a frequency that wt uld allow for corrective actions to minimize creation of an envirom ent conducive to Corrosion.
Dinovervt The efTects of corrosion are generally detectable by 1isual techniques. Scating surface degradation can be discovered by testing the components that are susceptible to this ARDM. Pressure testir.g of the containment isolation CKVs in the CS headers can provide for detection of leakage that
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could be the result of crevice corrosion and pitting of the valve seating surfaces. Internal surfaces of components that are not routinely inspected can be subjected to inspection to determine the extent of general and/or localized degradation that may be occurring. [ Reference 1, Attachment 6s for all device types]
Group 2 - (general corrosion, erevice corrosion, and/or pitting of internal surfaces) - Aging Management Program (s)
Mitigation: Maintenance of proper fluid chemistry in the CS System and interfacing systems will limit the effects of general corrosion, crevice corrosion, and pitting on internal surfacea for Group 2 subcomponents. [ Reference 1, Attachment 8]
The CCNPP Chemistry Program has been established to: minimize impurity ingress to plant systems; reduce corrosion product generation, transport, and deposition; reduce collective radiation exposure through chcmistry; impiue integrity and availability of plant systems; and extend component and plant life. [ Reference 33, Section 6.1.A] The program is based on Technical Specifications, BGE's interpretttion of industry standards, and recommendations made by Combustion Engineering.
[ Reference 33, Section 2.0]
Calvert Cliffs Technical Procedure CP 204, " Specification and Surveillance-Primary Systems," provides for monitoring and maintaining chemistry in the RCS and associated systems. [ Reference 34, Section 2.0, Attachments I through 15] Control of primary water chemistry is credited with limiting the effects of crevice corrosion and pitting in CS System components. [ Reference 1, Attachment 8]
Calven Cliffs Technical Procedure CP-206, " Specifications and Surveillance-Component Cooling /Scryice Water Systems," provides for monitoring of CC System chemistry to control the concentrations of oxygen, chlorides, and other chemicals and contaminants. [ Reference 35, Section 2.0, Attachment 1] For the SDCIIXs, which are cooled by water from the CC System, control of the water chemistry provides an environment that limits the rate of degradation and its effects. [Referenc: 1, Attachment 8]
Each of the program procedures describes the surveillance and specifications for monitoring fluid chemistry for the applicable systems. They list the parameters to be monitored, the frequency for
- monitoring of each parameter, and the acceptable value or range of values for each parameter.
[ Reference 34, Attachments I through 15; Reference 35, Attachment 1] Each parameter is measured at a Applicsion for License Renewal 5.6-16 Calvert Cliffs Eclear Power Plant
ATTACHMENT f H APPENDIX A - TECHNICAL INFORMATIOS 5.6 - CONTAINMENT SPRAY SYSTEM procedurally-speciGed frequency (e.g., daily, weekly, monthly) and compared against a target value that represents a goal or predetermined warning limit. [ Reference 34, Section 3.0; Reference 35, Section 3.0)-
If a measured value is outside of its required range, corrective actions are taken (e.g., power reduction, plant shutdown) as prescribed by the procedure, thereby ensuring timely response to chemical excursions. He procedures provide for rapid assessment of off. normal chemistry parameters so that steps can be taken to return them to normal levels. [ Reference 34, Section 6.0.C; Reference 35, Section 6.0.C]
.ne CCNPP Chemistry Program has been subject to periodic internal assessment activities. Internal audits are performed to ensure that activities and procedures established to implement the requirements of 10 CFR Part 50, Appendix B, comply with BGE's overall Quality Assurance Program. These audits provide a comprehensive independent verification and evaluation of quality-related activities and procedures. Audits of selected aspects of operational phase activities are performed with a frequency commensurate with their level of performance and safety significance, and in such a manner as to assure that an audit of all safety-related functions is completed within a period of two years. [ Reference 36, Section 10.18] These activities, as well as other external assessments, help to maintain highly effective chemistry control, and facilitate continuous improvement through monitoring industry initiatives and trends in the area of corrosion control.
A review of operating experience identified no site specific problems or events related to general corrosion, crevice corrosion, or pitting that required significant changes or adjustments to the CCNPP Chemistry Program. It has been effective in its function of mitigating corrosion and controlling corrosion related failures and problems within acceptable limits, in 1996, CP-206 was revised to include monitoring of dissolved iron as a method for discovering any unusual corrosion of carbon steel components. Self-assessments of chemistry control performance h:ve resulted in activities to reduce the number of times that chemistry parameters exceed action levels (e.g. additional scheduling coordination for outage evolutions that could affect CC/ Service Water chemical parameters).
Discoverv: Calvert Cliffs procedure CP-224, " Monitoring Radioactivity in Systems Normally Uncontaminated," provides for detection of radioactivity in the CC System. [ Reference 37] Degradation of tubes in the SDCIIX may result in a detectable radioactivity level in the CC System that would trigger investigations and corrective actions. Therefore, this program is credited as a method for discovery and management of general corrosion, crevice corrosion, and pitting for the SDCHXs. [ Reference 1, Attachment 8]
Calvert Cliffs procedures STP M 57101(2)," Local Leak Rate Test, Penetrations 9,10,23,24,37,39,"
which cover local leak rate testing (LLRT) for the inner and outer CS ring header containment penetrations, are part of the overall CCNPP Containment Leakage Rate Testing Program. [ References 38 and 39] The CCNPP Containment Leakage Rate Testing Program was established to implement the leakage testing of the containment as required by 10 CFR 50.54(o) and 10 CFR Part 50, Appendix J, Option B, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors."
- Appendix J specifies containment leakage t
- sting requirements, including the types of tests required, frequency of testing, test methods, test pressures, acceptance criteria, and reporting requirements.
Containment leakage testing requirements include performance of Integrated Leakage Rate Tests, also known as Type A tests, and LLRTs, also known as Type B and C tests. Type A tests measure the overall leakage rate of the containment. Type B tests are intended to detect leakage paths and measure leakage for certain containment penetrations (e.g., airlocks, flanges, and electrical penetrations). Type C tests are Application for License Renewal 5.6-17 Calvert Cliffs Nuclear Power Plant
4 ATTACllMENT (1) l APPENDIX A TECilNICAL INI'ORMATION l 5.6 - CONTAINMENT SPRAY SYSTEM l
intended to measure containment isolation valve leakage rates. [ Reference 40, Section 6.5.6; References 41 and 42]
The CCNPP LLRT Program is based on the requirements of . CCNPP Technical Specifications 3.6.1.2,4.6.l.2, and d.5.6. The scope of the program includes Type B and C testing of containment penetrations. The CKVs that provide a containment pressure-boundary function for the inner and outer CS ring headers when the injection mode flowpath is not active are included in the scope of this program as part of the leakage testing fi t the associated containment penetrations. [ Reference 40]
The LLRT is done on a performance-based testing schedule in accordance with Option B of 10 CFR Part 50, Appendix J, as implemented by CCNPP Technical Specifications. [ References 40,41, and 42). Local leak rate testing presently includes the following procedural steps:
- Leak rate monitoring test equipment is connected to the appropriate test point.
- The test volume is pressurized to the LLRT Program test pressure, which is conservative with respect to the 10 CFR Part 50, Appendix J, test pressure requirements. Appendix J requires testing at a pressure "P.," which is the peak calculated containment internal pressure related to the design basis accident.
- Leak rate, pressure, and temperature are monitored at the frequency specified by the LLRT procedure and the results are recorded.
- The maximum indicated leak rate is compared against administrative limits that are more restrictive than the maximum allowable leakage limits.
- "As found" leakage equal to or greater than the administrative limit, but less than the maximum allowable limit, is evaluated to determine if further testing is required and/or if corrective maintenance is to be performed.
- For "as found" leakage that exceeds the maximum allowable limit, plant personnel determine if Tec$nical Specification Limiting Condition for Operation 3.6.1.2.b has been exceeded. Technical Specification 3.6.1.2.b contains the maximum allowable combined leakage for all penetrations and valves subject to the Type B and C tests Corrective action i: taken as required to restore the leakage rates to within the appropriate acceptance criteria.
- If any maintenance is required on a containment isolation valve that changes the closing characteristic of the valve, an "as left" test must be performed on the penetration to ensure leakage rates are acceptable.
The corrective actions taken as part of the LLRT Program will ensure that the seating surfaces of the containment isolation CKVs in the CS headers remain c:pable of performing their intended functions under all CLB conditions during the period of extended operation.
Baltimore Gas and Electric Company will include all Group 2 components in an Age-Related Degradation inspection (ARDI) Program to verify that unacceptable degradation of internal surfaces by general corrosion, crevice corrosion, or pitting is not occurring. [ Reference 1, Attachment 8]
The ARDI Program is defined in the CCNPP IPA Methodology presented in Section 2.0 of the BGE LRA.
Application for License Renewal 5.6 Calvert Cliffs Nuclear Power Plant
ATTACllMENT (1)
APPENDIX A - TECliNICAL INFORMATION 5.6 CONTAINMENT SPRAY SYSTEM The elements of the ARD1 Program will include:
e . Determination of the examina'len sample size Sased on plausible aging effects; e identification of inspection locations in the system / component based on plausible aging effects and consequences ofloss of component intended function; e Determination of examination techniques (including acceptance criteria) that would be effective, considering the aging effects for which the component is examined; e Methods for interpretation of examination resn'ts;
- Methods for resolution of adverse examination findings, including consideration of all design loading conditions required by the CLB and specification of required corrective actions; and
- - Evaluation of the need for follow-up examinations to monitor the progression of any age-related degradation.
Any corrective actions that are required will be taken in accordance with the CCNPP Corrective Actions Program and will ensure that the components will remain capable of performing their intended function under all CLB conditions.
Group 2 - (general corrosion, crevice corrosion, and/or pitting of internal surfacer) -
Demonstration of Aging Management Based on the information presented above, the following conclusiens can be reached with respect to general corrosion, crevice corrosion, and pitting of internal surfaces for CS System components that are exposed to chemically-treated water:
- The components in Group 2 contribute to meintaining the system pressure boundary.
Additionally, the containment isolation CKVs in the CS headers provide a containment pressure-boundary function when the injection mode flowpath is not active. The integrity of these componer.ts must be maintained under all CLB derign conditions.
- The materials of construction for subcomponents in this group are carbon steel, stainless steel, or inconel.
- General corrosion, crevice corrosion, and pitting are plausible ARDMs for this group and, if
- _ unmanaged, these ARDMs could eventually result in the loss of pressure-retaining capability under CLB design loading conditions.
- Maintenance of proper fluid chemistry in the CS System (in accordance with CP-204) will limit the effects of general corrosion, crevice corrosion, and pitting on susceptible pressure boundary subcomponents for Group 2 components. Chemistry control in accordance with CP-206 will ensure that cooling water supplied to the SDCHXs is of an appropriate chemistry to minimize
- corrosion.
- Monitoring CC System radioactivity in accordance with CP-224 will detect radioactivity levels that may result from tube degradation in the SDCHX and ensure that appropriate corrective action is initiated.
- Application for License Renewal 5.6-19 Calvert Cliffs Nuclear Power Plant a
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ATTACilMENT (1)
APPENDIX A TECilNICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM e The CCNPP LLRT Program performs leakage testing that could detect the effects of crevice corrosion and pitting on the seating surfaces of the containment isolation CKVs in the CS headers (i.e., degraded leak tightness). This program ensures that appropriate corrective actions will be taken if significant leakage is discovered.
- All Group 2 componeris will be subjected to a new ARDI Program. This program will examine a representative sample of the components for degradation, and ensure that appropriate corrective actions are initiated on the basis of the findings.
Therefore, there is a reasonable assurance that the effects of general corrosion, crevice corrosion, and/or pitting will be adequately managed for internal surfaces of CS System components exposed to chemically-treated water such that they will be capable of performing their intended functions cons: stent with the CLB during the period of extended operation under all design loading conditions.
5.6.3 Conclusion He aging management programs discussed for the CS System are listed in Table 5.6-3. These programs are administratively controlled by a formal review and approval process. As demonstrated above, these programs will manage the aging mechanisms and their effects in such a way that the intended functions of the components of the CS System will be maintained during the period of extended operation consistent with the CLB under all design loading conditions.
The analy;is/ assessment, corrective action, and confirmation /documentatior, process for license renewal is in accordance with QL-2, " Corrective Actions Program." QL-2 is pursuant to 10 CFR Part 50, Appendix B, and covers all structures and components subject to AMR.
Application for License Renewal 5.6-20 Calvert Cliffs Nuclear Power Plant
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ATTACHMENT (1)
APPENDIX A . TECHNICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM Table 5.6-3 AGING MANAGEMENT PROGRAMS FOR THE CONTAINMENT SPRAY SYSTEM Program Credited As :
Existing CCNPP Administrative Procedur. Program for mitigation and discovery of general MN-3 301, " Boric Acid Corrosion corrosion for external surfaces of piping, CKVs, Inspection Program" CVs, liVs, ilXs, MOVs, and PUMPS (included in Group 1) that are exposed to borated water (due to leakage) by performing visual inspections.
Existing CCNPP Technical Procedure CP-204, Program for mitigation of general corrosion, crevice
" Specification and Surveillance corrosion, and/or pitting for internal surfaces of Primary Systems" piping, CKVs, CVs, FEs, fos, ilVs, IIXs, MOVs, PUMPS, RVs, TEs, and Tis (included in Group 2) that are exposed to borated water (as process fluid) by ecatrolling chemistry conditions.
Existing CCNPP Technical Procedure CP 206, Program for mitigation of general corrosion, crevice
" Specification and Surveillance corrosion, and/or pitting for internal surfaces of the Component Cooling / Service Water SDCliXs (included in Group 2) that are exposed to System" chemically-treated water from the CC System by controlling chemistry conditions in the CC System.
Existing CCNPP Technical Procedure CP-224, Program for discovery of crevice corrosion and
" Monitoring Radioactivity in Systems pitting of tubes in the SDCIIXs (included in Normally Uncontaminated" Group 2) that are exposed to borated water (as process fluid) and chemically-treated water from the CC System by detecting radioactivity in the CC System.
Existing CCNPP Surveillance Test Program for discovery and management of leakage M 571G-l(2)," Local Leak Raw Test, that could be the result of crevice corrosion and Penetrations 9,10, 23,24,37, 39" pitting for seating surfaces of the containment isolation CKVs in the CS headers (included in Group 2).
New ARDI Program Program for discovery and management of general corrosion, crevice corrosion, and/or pitting for internal surfaces of piping, CKVs, CVs, FEs, fos, IIVs, ilXs, MOVs, PUMPS, RVs, TEs, and Tis (included in Group 2) by identifying and correcting degraded conditions.
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ATTACHMENT (1)
APPENDIX A TECHNICAL INFORMATION 5.6 - CONTAINMENT SPRAY SYSTEM 5.6.4 References
- 1. CCNPP Aging Management Review Report," Containment Spray System," Revision 2
- 2. CCNPP Updated Final Safety Analysis Report (UFSAR), Units I and 2, Revision 21
- 3. Letter from Mr. R. E. Denton (BGE) to NRC Document Control Desk, dated February 26,1990,"Licensce Event Report 90-005"
- 4. BGE Drawing 60731Siles01. ' Safety injection & Containment Spray Systems," Revisior 65
- 5. BGE Drawing 60731 S110003, " Safety injection & Containment Spray Systems," Revision 21
- 6. BGE Drawing 60711, " Containment Charcoal Filter Spray System," Revision 15
- 7. BGE Drawing 62731 Sil0001, " Safety injection & Containment Spray Systems," Revision 63
- 8. BGE Drawing 62731S110003, " Safety it.jection & Containment Spray Systems," Rev:sion 17
- 9. BGE Drawing 62711," Containment Charcoal Filter Spray System," Revision 14
Revision 3
- 11. CCNPP Operating Instructions, OI 3A-l(2), " Safety injection and Containment Spray, Unit 1(2)," Revision 3
- 12. CCNPP Operating Instructions,01-3B-1(2)," Shutdown Cooling, Unit 1(2)," Revision 7
- 13. BGE Drawing 60710SH0002," Component Coolnq System," Revision 31 14 BGE Drawing 62710SH0002," Component Cooling Eystem," Revision 19
- 15. BGE Drawing 60716," Spent Fuel Pooi Cooling, Poo' Fill & Drain Systems," Revision 47
- 16. BGE Drawing 62730S110002," Chemical snd Volume Control System," Revision 40
- 17. BGE Drawing 60746S110002," Plant Water & Air System Service," Revision 24
- 18. CCNPP Component Level Scoping Results, " System 061 - Condnment Spray System,"
Revision 1
Revision 2
- 20. BGE Drawing 92769Sil HC-1,"M-601 Piping Class Summary," Reviss.i 26
- 21. BGE Drawing 92769SH-llc-3,"M-601 Piping Class Summary," Revision 20
- 22. BGE Drawing 92769Sil-llc-4,"M-601 Piping Class Summary," Revision 21
- 23. BGE Drawing 92769Sil-GC-1,"M-601 Piping Class Summary," Revision 23
- 24. CCNPP Life Cycle Management Pre-Evaluation Results," Containment Spray System (061),"
Revision 2
- 25. Combustion Engineering Owners Group Task 571, Report No. CE-NPSD-634-P, " Fatigue Monitoring Program for Calvert Cliffs Nuclear Power Plants Units I and 2," April 1992
- 26. CCNPP Administrative Procedure EN t-300, " Implementation of Fatigue Monitoring,"
Revision 0 Application for License Renewal 5.6-22 Calvert Cliffs Nuclear Power Plant
. e ATTACilMENT m AF?ENDIX A - TECilNICAL INFORMATION S.6 CONTAINMENT SPRAY SYSTEM
- 27. Letter from Mr. A. E. Lundvall, Jr. (BGE) to Mr. B.11. Grier (NRC), dated August 24,1979, "IE Bulletin No. 79-17"
- 28. Letter from Mr. A. E. Lundvall, Jr. (DGE) to Mr. B. H. Grier (NRC), dated November 27,1979, "lE Bulletin No.7917 Revision 1 (Pipe Cracks in Stagnant Borated Water Systems at PWR Plants)
- 29. CCNPP Engineering Standard ES-014, " Summary of Ambient Environmental Service Conditions," Revision 0
- 30. CCNPP Administrative Procedure MN 3 301, " Boric Acid Corrosion inspection Program,"
Revision 1
- 31. CCNF? Administrative Procedure MN 3-110 " Inservice inspection of ASME Section XI Components," Revision 2
- 32. BGE Drawing 92769S11118-3,"M 601 Piping Class Summary," Revision 29
- 33. CCNPP Nuclear Program Directive CII-1," Chem;stry Program," Revision 1
- 34. CCNPP Technical Procedure CP 204, " Specification and Surveillance Primary Systems,"
Revision 8
- 35. CCNPP Technical Procedure CP 206, " Specifications and Surveillance Component Cooling / Service Water System," Revision 3
- 36. BGE " Quality Assurance Policy for the Calvert Cliffs Nuclear Power Plant," Revision 48
- 37. CCNPP Technical Procedure CP-224, " Monitoring Radioactivity in Systems Normally Uncontaminated," Revision 3
- 38. CCNPP Surveillance Test Procedure M 5710-1," Local Leak Rate Test, Penetrations 9,10,23, 24,37,39"(Unit 1), Revision 0
- 39. CCNPP Surveillance Test Procedure M 571G 2," Local Leak Rate Test, Penetrations 9,10,23, 24,37,39"(Unit 2), l'evision 1
- 40. Letter from Mr. A. W. Dromerick (NRC) Mr. C. II. Cruse (BGE), dated February 11,1997,
" Issuance of Amendments for CCNPP Unit No.1 (TAC No. M97341) and Unit No. 2 (TAC No. M97342)" (Amendment Nos. 219/196)
- 41. 10 CFR Part 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors'
- 42. Letter from Mr. C, 11. Cruse (BGE) to NRC Document Contrl Desk, dated November 26,1996, "Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317
& 50-318 License Amendment Request: Adoption of 10 CFR Part 50, Appendix J, Option B for Types B and C Testing" Application for License Renewal 5.6-23 Calvert Cliffs Nuclear Power Plant
t AII'ACHMENT (2)
APPENDIX A - TECHNICAL INFORMATION 5.8 - EMERGENCY DIESEL GENERATOR SYSTEM Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Janusry 21,1998
, AIIAGtMENT (2)
APPENDIX A TECilNICAL INFORMATION 5.N - EMERGENCY DIESEL GF.NERATOR SYSTEM 5.N Emergency Dieul Generator hystem
, Tris is a section of the Haltimore Gas and Electric Company (IlGE) 1.icense Renewal Application i
(LRA), addressing the Emergency Diesel Generator (EDG) System. 'Ihe EDO System was evaluated in accordance with the Calvert Clift Nuclear Power Plant (CCNPP) Integrated Plant Assessment (IPA)
Methodology described in Section 2.0 of the HOE LRA These sections are prepared independently and will, collectively, comprise the entire llGE LRA.
5.L.1 Scoping I
Sptem level scoping describes conceptual boundaries for plant systems and structures, develops screening tools that capture the 10 Cl R 54.4(a) scoping criteria, and then applies the tools to identify systems and structures within the scope of license renewal. Component level scoping describes the components within the boundaries of those systems and structures that contribute to the intended functions. Scoping to determine components sub)cet to aging management review (AMR) begins with a listing of passive intended functions and then dispositions the device types as either only associated with ac'ive functions, subject to replacement, or subject to AMR either in this repon or another report.
Representative historical operating experience pertinent to aging is included in appropriate areas to provide insight supporting the aging management demonstrations. This operating experience was obtained through key. word Searches ofIlGE's electronic database ofinforn ation on the CCNPP dockets ,
1 and through documented discussions with currently assigned cognizant CCNPP personnel.
Section 5.8. i presents the results of the system level scoping,5.8.1.2 the results of the component level scoping, and 5.8.1.3 'n res'alts of scopi g to determine components subject to an AMR.
5.N.1,1 Systtm level Sconing This section begins with a description of the system that includes the boundaries of the system as it was scoped. The intended functions of the system are listed and are used to define what portions of the system are within the scope oflicense renewal.
System Desniption/ Conceptual Houndaries
%c EDGs are designed to provide a dependable onsite power source capable of automatically starting and supplying the essential loads necessary to safe y shut down the plant and maintain it in a safe shutdown condition under all conditions. Four EDGs (4.16 kV, three phase,60 cycle) are provided for the plant, although each unit requires only one diesel generator to supply the minimum power requirements for its Engineered Safety Features equipment. Emergency Diesel Generator IA is furnished by Societe Alsacienne De Constructions Mecaniques De Mulhouse (SACM) and EDG= 18, 2A, and 2H are furnished by Fairbanks Morse. Emergency Diesel Generator l A (nominal continuous rating 5400 kW) is connected to 4.16 LV Hus 11. EDG 111 (nominal continuous rating 2500 kW) is connected to 4.16 kV Hus 14, EDO 2A (nominal continuous rating 3000 kW) is connected to 4.16 kV Hus 21, and EDG 21F (nominal continuous rating 30W kW) is connected to 4.16 kV Hus 24.
[ Reference 1, Section 8.4]
Application for License Renewal 5.8 l Calvert Cliffs Nuclear Power Plant
NITACilMENT (2) l APPENDIX A TECHNICAL INFORMATION 5.3 - FMERGENCY DIESEL GENERATOR SYSTEM i
The EDGs are designed to reach rated speed and voltage and start accepting load within 10 seconds after the receipt of a starting signal. Emergency Diesel Generators and their auxillaries are designed to withstand Seismic Category I accelerations and are installed within Seismic Categoiy I structures. The SACM EDU is installed in a separrae and independent Category I building. Each EDO set is physically separated and electrically isolated from the other generator sets in accordance with Regulatory Guide 1.75 and Institute of Electrical and Electronic Engineers IEEE 3841981. The diesel generators are started by either a 4.16 kV bus undervoltage or safety injection actuation signal; however, in the latter ease, actual transfer to the bus is not made until the freferred ofTsite source of power is s.:tually lost. When the four EDGs are availab!c, the design provides two independently-capable and concurrently-operating systems for safety injectica, containment spray, and miscellaneous 480 Volt auxiliary devices for the unit incurring the Design Basis Event, in addition, the design provides power to operate two sets of equipment for shutting down the non. accident unit. [ Reference 1. Section 8.4]
The independence and redundancy of the auxiliary power system features that initiate and control the connection of EDGs to the AC emergency busses are designed in accoro,nce with General Design Critsria 18 ( February 20,1971) to permit periodic inspection and testing. [ Reference 1, Section 8.4)
During accident conditions accompanied by simultaneous loss of offsite power, the loss-of coolant incident sequencer will start automatically to load the EDGs sequentially, Fimilarly, the shutdc vn sequencer for the non accident unit will start automatically. At no time during the loading sequence will the frequency and voltage at the generator tenninals decrease to less than 95% of normal and 75% of norm 61, respectively, for the Fairbanks Morse EDGs, and less than 95% of normal and 82% of normal, respective!y, for the SACM EDGs.1he nominal values of speed, voltage, and frequency are defined in Technical Specification 4.8.1.1.2. [ Reference 1. Section 8.4]
In addition, the CCNPP site has a fifth EDG, OC (nominal continuous rating of approximately 5000 kW).
This is a non safety related diesel generator built by SACM to the quality standards of Regulatory Guide 1.155, Station Blackout. It can be manually aligned to four of the four 4.16 kV busses to suppon Station Blackout, or Engineered Safety Features loads, if necessary. It is capab.e of supplying the essential loads necessary to safely shut down one unit and maintain it in a safe condition during a Station Blackout Event. [ Reference 1, Section 1.2.8, Section 8.4]
'the auxiliary systems that support the EDGs are diesel fuel oil, lube oil, service water (SRW) cooling, starting air, keep warm systems, instrumentation / controls, and intake and exhaust air Refer to Figures 8 8A,8 80,8 8C in the CCNPP Updated Final Safety Analysis Report for more detail on these systems.
[ Reference 1, Section 8.4; Reference 2, Section 1.1.1)
System Boundaries For the purposes of license renewal, this System is composed of four EDGs and one Station Blackout diesel ;;enerator, engine auxiliaries, and electrical equipment. Emergency Diesel Generators IB,2B, and 2A were installed during CCNPP construction, whereas EDGs l A and OC were recently installed. The License Renewal Rule recognites that the diesel engines and associated generators are active and excludes them from the group of equipment that is subject to AMR [10 CFR 54.21(a)(1)(i)). All auxiliary components supplied as part of the engine and located on the engine skid (on the engine side of the auxiliary mbsystem ficxible couplings) are considered part of the engine for the purposes of license renewal. The passive, long lived components associated with the engine auxillaries outside the skid Application for License Renewal 5.8 2 Calvert Cliffs Nuclear Power Plant
ATTACllMENT (2)
APPENIMX A TECilNICAL INFORMATION 5.N . EMERGENCY 1)lESEI GENERATOR SYSTEM boundary and electrical equipment are subject to AMR. 'lhe boundaries of the EDG System for this evaluation are the folle. wing: [ Reference 2, Section 1.1.2)
- Diesel Fuel Oil System: The boundary between the Diesel Fuel Oil System and the EDO System '
is just upstream of the Y strainers installed in the suction pipe to the fuel oil transfer pumps.
- SRW System: 'Ihe boundary between the SRW System and the EDO System is at the diesel cooler /SRW interface expansion joints (expansion joints are included in EDO System); and at the interface of SRW piping with the starting air subsystem air compressor.
- 4 kV Transformers and Ilusses System: The boundary between the EDG System and the 4 kV Transformers and Dusses System is at the EDO side of the 4 kV bus breal ers.
- Engineered Safety Features Actuation System: The boundary of the EDO is at the contact outputs from relay cabinets 1/2 C67/68 interface with the EDO starting logic.
The typical components associated with the EDG auxillaries outside the skid boundary include the following: [ Reference 1, Figures 8 8A,8 811,8 8C)
- EDO Fuel Oil Day Tanks;
- EDO Fuel Oil Transter Pumps;
Refer to Figure 5.81 for a typical representation of the systems and components associated with the EDGs. 'lhose portions of the EDO Systems that are in scope for license renewal are indicated in this figure. Other components in this ilgure are not in scope of this section (5.8) because they are evaluated in other sections or are active components outside the scope of license renewal. [ Reference 1, Section 8.4, Figures 8 8A,8 8B,8 8C)
Qocrating EincricDCc Review of the failure detail reports on EDGs indicate that from the very beginning of commercial operation of CCNpP, the EDO System has received a very high level of attention in surveillance and maintenance. There have been instances of EDG System component failures, some of which have been due to various aging mechanisms. Examples of some of the components and failure mechanisms are described below, Emergency diesel generator re..cf valves, solenoid valves (fuel oil inlet), and other components have leaked due to instances of wear. In many cases, this is considered normal wear of the component; but in some cases, the wear was considered excessive. General corrosion has also caused some of the EDG relief valves to stick open and check valves to stick shut due to buildup of cerrosion products (rust) around the valve seats and disks. Cyclic fatigue has caused the failure and cracking of fuel oil injectors, check valves, switches, tubing, and other EDO components, in each case, BGE repaired, adjusted, or replaced the affected component so that it could perform its intended function. [ Reference 3) Corrosion Application for License Renewal 5.83 Calvert Clifts Nuclear Power Plant
. - _ .. _ _ _ . _ _ _ . - . . ~ - - . . - _ _ _ _ _ _ _ _ - _ _ . .
NITACHMENT (D APPENDIX A - TECHNICAI, INFORMATION :
5.8 EMEMGENCY DIESEL GENERATOR SYSTEM and wear in the EDO air start distributors have caused the EDGs to fail some surveillance tests. In each !
case,11GE replaced and/or cleaned the affected parts and the components were successfully retested.
[Refercrce 4]
hiany of the affected components are on the EDO skid and not within the scope of AhiR. Due to the ;
built in redundancy of the EDO System, CCNPP has not suffered a simultaneous forced outage of both units due to EDG unavailability. On several occasions, the output of one or both units was reduced or curtailed because one or more EDGs were unavailable due to EDO System component failures, limitations imposed by the failures, or reduced performance of other system components such as SRW System heat-exchangers. [ Reference 3]
System lnterfr.ces The EDG System has interfaces with the Diesel Fuel Oil System, SRW cooling system, 4 kV Transformers and flusses, and Engineered Safety Features Actuation System Control and Interlocks. Those systems or systems' components interfacing with the EDG System that are within the scope for license renewal are noted in Figure 5.81, Where a system, component, commodity, or structure interface is within scope for license renewal, it is addressed by the respective section of the llGE LRA for that system, component, commodity, or structure, as listed in Figure 5.8 1.
[ References 5,6, and 7]
)
V Application for License Renewal 5. ' 4 Calvert Clifts Nuclear Power Plant
ATTACHMENT (2)
APPENDIX A - TECHNICAL INFORMATION 5.8 - EMERGENCY DESEL GENERATOR SirMM
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FIGURE S-8.1 CCNPP EMERGENCY DIESEL GENERATOR SYSTEM SIMPLIFIED DIAGRAM (For Information Only)
Application for License Renewal 5.8-5 Cahut Clifts Nuclear Power Plant
_. __ _ __ _ __ . ._ _ ___. - ~_ .
, NLTACilMrNT d)
APPENDIX A TECHNICAL INFORMATION ;
5.8 EMERGENCY DIESEL GENERATOR SYSTEM _ _ _
SyshntA 'ningJesults !
O s /9 c., tem is in scope for license renewal based on 10 CFR $4.4(a). The following intended
!wjtj.g. of the EDG System were determined based on the requirements of $54.4(a)(1) and (2), in eccoidance with the CCNPP IPA Methodology Section 4.1.1. [ Refer.nce 8, Table 1)
- Provide the vital auxiliary power supply for components used to mitigate Design Basis Events;
- To maintain the pressure boundary of the system (llquid and/or gas);
- To maintain electrical continuity and/or provide pmtection of the electilcal system;
- To maintain mechanical operability and/or provide protection of the mechanical system; and
- To provide seismic integrity and/or protection of safety.related components.
The folluwing intended functions of the EDG System were determined based on the requirements of
$54.4(a)(3): [ Reference 8. Table 1)
- For envitonmental quali0 cation (650.49) Provide information used to assess the environs and plant condition during and aller an accident.
5.8.1.2 Component Level Scoping 1his report addresses the component level scoping for EDGs in two separate sections. Section 5.8.1.2.1 addresses that portion of the EDG System consisting of the three original EDGs (10,2A, and 28), which were furnished by Fairbanks Mors.c and have been operating since before the start of commercial operation of the plant. Section 5.8.1.2.2 addresses the new diesel generators (OC and l A) provided by SACM.
5.R.1.2.1 Component Level Scoping of Diesel Generators IH.2A, and 2H Dased on the intended functions listed above, the portion of the EDO System that is within the scope of license renewal consists of piping, components (e.g., heat exchangers, pumps, valves, tanks, etc.),
component supports, and instrumentation and cables supporting operation of the EDGs through the diesel lube oil, diesel fuel oil, diesel starting air, diesel combustion air, and diesel cooling water subsystems.
[ Reference 2, Section 2.2]
The 48 EDG System device types listed in Table 5.81 were designated as within the scope of license renewal because they have at least one intended function: [ Reference 2, Table 21]
l Application for License Renewal - 5.8-6 Calvert Clifts Nuclear Power Plant
J
, ATTACllMENT (2)
^PPENDIX A - TECilNICAL INFORMATION 5.N . EMr.RGENCY DIESEL GENERATOR SYSTEM TAllLE 5.81 l EDG SYSTEM DEVICE TYPES WITilIN Tile SCOPE OF LICENSE RENEWAL ,
Devlee Type Composest Desedption. DevieriType Consponent Desertpelon l 1111 Piping lill LS Level Switch ACC Accumulator M Motor ANN Annunciator MCC Motor Control Center ilKR lireaker MD Motor CKV Check Valve MO Motor Coll Coil MUFF MufUcr CS Control Switch Pl Pressure Indicator DISC Disconnect PNL Panel DT Drain Trap PS Pressure Switch F/li Voltage Regulator PUMP Pump _
li!Xi timergency Diesel Generator RV Relief Valve til isolator RY Relay FAN Fan SC Speed Controller >
1:1 1:llter SI Speed Indicator Fi) Fuse SS Speed Switch GOV Governor TC Temperature Controller ilS Iland Switch TK Tank llV lland Valve TS Temperature Switch flX lleat lixchanger 'IT Temperature Transmitter ll Isolator U lleater Ji Indicator X Transformer JKI Indicator XL Indicating Lamp JL Indicating Light YS Wye Strainer Li Level Indicator ZL Position Indicating Light Several components are common to many plant systems and perform the same passive functions regardless of system. These components include the following:
e Structural supports for piping cables, and components; e filectrical control and power cabling; e instrument tubing and piping and the associated supports, instrument valves and fittings (generally everything from the outlet of the final root valve up to and including the instrument),
and the pressure boundaries of the instruments themselves.
5.8.1.2.2 Component Level Scoping of New Diesel Generators DC and l A For the new SACM diesels, e one time procedure was used to identify the components that passively support the pressure boundary or Class !!! functions that are also common with the existing Fairbanks Morse EDO components.
'lhe two new SACM diesel generators are excluded from AMR as previously described in the Systems lloundaries section. The equipment supplied by Fairbanks Morse, and located on the vendor supplied Application for License Renewal 5.8 7 Calvert Cliffs Nuclear Power Plant
, NITACllMENT (2)
APPENDIX A - TECllNICAL INFORMATION :
5.8 . EMERGENCY 1)lESEL GENERATOR SYSTEM skid, is identined as the diesel generator and is, therefore, excluded by the License Renewal Rule. The corresponding portions of the SACM diesels are similarly excluded.
The passive, long lived components associated with the engine auxiliaries outside the engine skid j boundary and electrical equipment are subject to AMR. The components of the new SACM diesels were mapped to their corresponding components on the Fairbanks Morse EDGs. This mapping procedure provides assurance that all SACM diesel components have been evaluated for AMR through the evaluation process used for the Fairbanks Morse EDGs. Maintenance on the Fairbanks Morse EDGs also .
provides a 20-year lead time for aging of new SACM diesel components.
The results ofinis mapping are summarired below.
Dicic1Lubc.Dil No plausible aging was identified for any SACM Diesel Lube Oil components.
Diesel Fuel Oil Plausible aging was identified for the SACM Diesel Fuel Oil tanks, basket strainer, tornado damper, and flame arrestor, in each case, the material, environment, and ARDMs for these SACM components were the same as the material, environment, and ARDMs for the corresponding Fairbanks Morse components, DiciclStarting Air No plausible aging was identified for the SACM Diesel Starting Air components even though plausible aging was identified for the corresponding Fairbanks Morse Diesel Starting Air components. The SACM Diesel Starting Air components are stainless steel subject to dry air, while the corresponding Fairbanks Morse Diesel Starting Air components are carbon steel subject to moist air.
DieselCombustion Air Plausible aging was identified for the SACM Diesel Combustion Air intake air filter and piping, in each case, the material, environment, and ARDMs for these SACM components are the same as the material, environment, and ARDMs of the corresponding Faittanks Morse components. Plausible aging was identified for the SACM Diesel Combustion Air exhaust air muffler and piping. The material, environ. ment, and ARDMs for the SACM exhaust muffler were the same as the material, environment, and ARDMs for the corresponding Fairbanks Morse exhaust muffler, The SACM exhaust piping is chromium-molybdenum versus carbon steel exhaust piping for the Fairbanks Muse diesels. Therefore, the SACM diesel exhaust piping is subject to a subset of the ARDMs affecting the Fairbanks Morse diesel exhaust piping.
Diese! Cooling Watct -
Plausible aging was identified for the SACM cooling water piping, tanks, and valves. These SACM components are made of the same material and subject to the same ARDMs as the corresponding Fairbanks Morse piping, tanks, and valves even though the process fluid is difTerent. The process fluid for the SACM cooling water system is a solution of ethylene glycol antifreeze in demineralized water.
The process fluid for the jacket cooling water system for the Fairbanks Morse diesels is service water treated with hydrazine. The aging of the SACM radiators is expected to be bounded by the aging of the Fairbanks MorseJacket water cooling system piping.
Application for License Renewal 5.8 8 Calvert Cliffs Nuclear Power Plant
l
, ATTACHMl:NT (2)-
APPENDIX A TECHNICAL INFORMATION 1 5.8 - EMERGENCY DIESEL GENERATOR SYSTEM 3 I
l In the few instances where there was not a corresponding original EDG component for a new SACM :
component, there were no plausible ARDMs due to the material / environment characteristics of the new SACM component. l Thus, for purposes oflicense renewal, the aging and the management thereof for the new SACM diesel support systems are enveloped by the aging and aging management for the corresponding Fairbanks .
Morse diesel support systems. Any aging discovered by the aging management program for the l Fairbanks Morse diesels will result in corrective action and a review for applicability to the corresponding new SACM diesel support system.
5.8.lJ Components Subject to AMR His section describes the components within the EDG System that are subject to AMR. It begins with a listing of passive intended functions and then dispositions the device types as either only associated with active functions and/or is skid mounted equipment excluded from AMR, evaluated in commodity reports, or remainir,g to be evaluated for aging management in this section.
fasshrintended Functions in accordance with CCNPP IPA Methodology Section 5.1, the following EDG System functions were determined to be passive: [ Reference 8, Pre Evaluation Section]
e Maintain the pressure boundary of the system (liquid and/or gas);
- To maintain electrical continuity and/or provide protection of the electrical system; and
- Provide seismic integrity and/or protection of safety related components.
Device Typcaluhject to AMR The components of the EDO support systems were reviewed and those that have the passive intended i functions were ident;fied. Of the 48 device types identified within s: ope for license renewal:
[ Reference 2 Table 3 2]
e Thirty device types (Annunciator, Circuit Breaker, Coil, Control Switch, Disconnect, Voltage Regulator, Emergency Diesel Generator, Isolator {EI), Fan, Fuse, Governor, lland Switch, Iselator{ll), Indicator (JI), Indicator {JKI), Indicating Light (JL), Motor (M), Motor {MD),
Motor (MO), Relay, Speed Controller Speed Indicator, Speed Switch, Temperature Controller, Temperature Switch, Temperature Transmitter, lleater, Transformer, Indicating Lamp, Position Indicating Light ) are only associated with active functions. [ Reference 2, Table 3 2].
- One device type (lleat Exchanger) is a skid mounted component on the Fairbanks Morse EDO and is not considered for further aging evaluation.
- Four device types (Level Indicator, Level Switch, Pressure Indicator, Pressure Switch) are evaluated in the instrument Line CommoJity Evaluation in Section 6.4 of the BGE LRA.
[ Reference 2, Table 3 2]
- Two device types (Motor Control Center, Panel) are evaluated in the Electrical _ Commodity Evaluation in Section 6.2 of the llGE LRA. [ Reference 2. Table 3 2]
Application for License Renewal 5.8 9 Calvert Clifts Nuclear Power Plant
, AITACilMENT (2)
APPENDIX A TECilNICAL INFORMATION !
5.8 . EMERGENCY DIESEL GENERATOR SYSTEM e Structural supports for piping, cables and components in the EDG System that are subject to AMR are evaluated for the effects of aging in the Component Supports Commodity Evaluation in Section 3.1 of the BGE LRA. This commodity evaluation completely addresses the passive intended function," Provide seismic integrity and/or protection of safety related components."
- Electrical control and power cabling for components in the EDG System that are subject to AMR are evaluated for the effects of aging in the Electrical Cables Commodity Evaluation in Section 6.1 of the BGE LRA. This commodity evaluation completely addresses the passive intended function, "To maintain electrical continuity and/or provide protection of the electrical system."
- Instrument tubing and piping and the associated supports, instrument valves and fittings (generally everything from the outlet of the final root valve up to and including the instrument),
and the pressure boundaries of the instruments themselves, are all evaluated for the effects of aging in the instrument Lines Commodity Evaluation in Section 6.4 of the BGE LRA.
As a result of the evaluation described above, the only passive intended function associated with the EDO System is the following:
e Maintain the pressure boundary of the system (liquid &/or gas).
The remaining 11 device types that require an AMR are listed in Table 5.8 2. These are the subject of the rest of this section. Unless otherwise annotated, all components of each listed type are covered in this section. [ Reference 2 Table 3 2]
Haltimore Gas and Electric Company may elect to replace components for which the AMR identilles further analysis or examination is needed, in accordance with the License Renewal Rule, components subject to replacement based on qualified life or specified time period would not be subject to AMR.
TAHLE 5.8-2 EDG SYSTEM DEYICE TYPES REQUIRING AMR Piping ( HB)
Filter (1 L)
Muffler (MUl:F)
Drain Trap (DT)
Wye Strainer (YS)
Relief Valve (RV)
Check Valve (CKV) ~
lland Valve * (IIV)
Pump (PUMP)
Accumulator (ACC)
Tank (TK)
- Instrument line manual drain, equalization, and isolation valves in the EDO System that are subject to AMR are evaluated for the effects of aging in the Instrument Line Commodity Evaluation in Section 6.4 of the DGE LRA. Instrument line manual root valves are evaluated in this Section.
Application for License Renewal 5.8 10 Calvert ClitTs Nuclear Power Plant
A'ITACitMrNTJ) ,
APPENDIX A - TECilNICAL INFORMATION 5.N - EMERGENCY DIESEL GENERATOR SYSTEM 5.8.2 Aging Management The list of potential Age Related Degradation Mechanisms (ARDMs) identified for the EDO System components is given in Table 5.8 3, with plausible ARDMs identified by a check mark (/) in the appropriate device type column. [ Reference 2, Table 4 2) For AMR, some device types have a number of groups associated with them because of the diversity of material used in their fabrication or differences in the environments to which they are subjected. A check mark indicates that the ARDM applies to at least one group for the device type listed. For elliciency in presenting the results of these evaluations in this section, the device types are grouped together based on similar ARDMs.
[ Reference 2, Section 4)
The following discussions present the information on plausible ARDMs. The discussions are grouped by ARDMs and address the materials and environment pertinent to the ARDM, the aging effects for each plausible ARDM, the device types that are affected by each, the methods to manage aging, the aging management program (s), and tis aging management demonstration. In some groups there will be a distinction made between the programs credited with aging management for the external and internal portions of the EDO System components. The groups addressed here are:
Group 1 General Corrosion, Crevice Corrosion, and Pitting; Group 2 torrosion Fatigue, Fatigue; Group 3. Erosion Corrosion, Particulate Wear Erosion; Group 4 Microbiologically induced Corrosion (MIC); and Group 5 Wear.
Application for License Renewal 5.8 11 Calvert Cliffs Nuclear Power Plant
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, ATTACllMENT (2)
APPENDIX A TECllNICAL INFORMATION ,
5.8 . EMERGENCY DIESEL GENf7ATOR SYSTEM ;
Group i (general cortoslou, cresice corrosion, and pitting) . Materials and Environment Table 5.8 3 shows that there are several device types sebject to general corrosion, crevice corrosion, and pitting. Some of these device types are susceptible to these ARDMs on both their internal and external surfaces as noted below. The device types and their material characteristics are: [ Reference 2, ACC01, 111101/04/05, CKV01, llV01/02/05, DT01, FL01, MUFF 01/02, TK01/02, YS01, Attachments 4,5,6]
thiernal/ Internal ARDhis;
e FL intake filter bodies (carbon teel);and 6
MUFl! . exhaust mullier bodies (carbon steel).
Internal ARDMs Only:
- ACC . air accumulator vessels (carbon stect);
- CKV - bodies (carbon steel) and disk seats (low alloy steel);
- DT. drain trap bodies (cast iron);
e lill . EDO cooling water piping (carbon steel) is subject to all Group i ARDMs, the air intake piping, fittings, and flanges (carbon steel) are only subject to general corrosion; e llV . bodies (carbon steel) and disk seat (stellited carbon steel);
- MUFF . air intake mutiler bodies (carbon stect);
- TK . Jacket water expansion tank, diesel fuel oil day and drin tanks with tank mounted level switches (carbon steel); and ,
- YS - dicsci fuel oil wye strainer bodies (cast carbon steel).
The external environment for compownts subject to general corrosion, crevice corrosion, and/or pitting is the controlled environment of the Diesel Generator ilulldings' (SACM l A is ' used in the " Diesel Generator ilullding," OC in the "SBO Diesel Generator lluilding," and Fairbanks Morse IB,21),2A in the Auxiliary Building) atmosphere (for some of the these components; ilV, CKV, llB, DT, MUFF, YS, ACC, TK), and outdoor ambient conditions with variable daily and seasonal changes (some of these components; llB, FL, MUFF).
The intemal environments are treated SRW (some of these components; llB, ilV, TK), air (11B), hot diesel engine exhaust gases containing moisture and particulates (llB, MUFF), diesel starting air (some of these components; CKV, llV, DT, ACC), ambient air containing moisture (FL), diesel intake air containing moisture (MUFF), and dicsci fuel oil (YS, TK). [ Reference 2, Attachments 4,5)
Group 1 (general corrosion, crevice corrosion, anti pitting) . Aging Mechanism Effects:
General corrosion is the thinning (wastage) of a metal by chemical attack (dissolution) at the surface of
- the metal by an aggressive environment. The expected effects of general corrosion in an air environment would be superficial rust speckles and a slight dusting ofloose passive surface rust. General corrosion in piping systems containing EDG jacket cooling water can occur due to stagnant conditions that last for Application for License Renewal- 5.8 13 Calvert ClitTs Nuclear Power Plant T- t?*i--+ -+ -- ------i--r-Tr e 4
t I
NITACllMENT (2) i APPENDIX A TECHNICAL INFORMATION 5.8 . EMERGENCY DIESEL GENERATOR SYSTEM ,
extended periods of time. Moisture in the starting air and EDO air intake lines is suflicient to result in .
corrosion of the untreated internal carbon steel piping surfaces. Stagnant, moist conditions can also exist in the E!X) exhaust piping and mufflers. General corrosion of the carbon steel exhaust material exposed to high temperatures may also be significant 1he consequences of the damage from general corrosion a are loss ofload carrying cross sectional area. General corrosion requires an aggressive environment and materials susceptible to that environment. [ Reference 2 Attachment 7s] :
6 Crevice corrosion is intense, localized corrosion within crevices or shleided areas. It is associated with a ;
small volume of stagnant solution caused by holes, gasket surfaces, lap joints, crevices under bolt heads, !
surface deposits, and integral weld backing rings or back up bars. Crevice corrosion is closely related to pitting corrosion and can initiate pits in many cases, as well as lead to stress corrosion cracking. In an oxidizing environment, a crevice can set up a differential aeration cell to concentrate an acid solution ,
within the crevice. [ Reference 2 Attachment 7s]
Pitting is a form oflocalized attack with greater corrosion rates at some locations than at others. This form of corrosion essentially produces holes of varying depth to diameter ratios in the steel. These pits are, in many cases, filled with oxide debris, especially in ferritic materials such as carbon steel. In many cases, erosion corrosion, fretting corrosion, and crevice corrosion can also lead to pitting. Corrosion ;
pitting is an anodic reaction, which is an autocatalytic process. That is, the corrosion process within a pit produces conditions that stimulate the continuing activity of the pit. liigh concentrations of impurity anions such as chlorides and sulfates tend to concentrate in the oxygen depleted pit region, giving rise to a potentially concentrated aggressive solution in this zone. [ Reference 2, Attachment 7s)
The exterior surfaces of all ElX1 Jacket cooling water piping and piping components in the Diesel Generator Buildings are not susceptible to these corrosion mechanisms. They are located in the diesel generator room ventilated environment. The conditlans are not conducive to the pooling of moisture -
necessary for the propagation of the mechanisms. [ Reference 2. LID, Attachment 6)
The exterior surfaces of EDG intake filter, exhaust piping and muftlers are susceptible to these same corrosion mechanisms. They are located on the Diesel Generator Building roof and are subjected to harsh environmental conditions. [ Reference 2,11, Attachment 6)
General corrosion, crevice corrosion, and pitting are plausible ARDMs for the EDO System components /subcomponents because of the nature of their mr.terial of construction and exposure to slightly moist starting and intake air; humid, moist, or wet ambient conditions; stagnant water; exhaust gases; and/or concentration of moisture and contaminants from diesel fuel oil. [ Reference 2, Attachments 6s]
If unmanaged, these plausible ARDMs could eventually resdt in the loss of pressure-retaining capability under Ct.D design loading conditions, ,
i Application for License Renewal 5.8 14 Calvert Cliffs Nuclear Power Plant i
, A'f7ACIIMENT (2)
APPENDIX A
- TECHNICAL INFORMATION 5.N . EMERGENCY DIESEL, GENFRATOR SYSTEM Sroup 1 (general corrosion. crevice corrosion, and pitting) Methods to Manage Aging Effects t h rnal Mitiation: Though most EDG components are not susceptible to external corrosion mechanisms because they are located in the controlled environment of the Diesel Generator Building, the possibility of corrosion can be mitigated by painting the exposed surfaces.
Dhcong: Aging management of exterior surfaces of the intake filter can be accomplished by visual inspections for degraded paint and the performance of any required corrective actions. (Reference 2, Attachment 8]
hitsInal Mitigation: Diesel fuel oil is corrosive when water is present with the fuel oil. While the presence of water ir, the tank cannot be totally prevented, minimiting the amount of water and the length of time it may be present in the tank is an effective method of mitigating the effects of genual corrosion, crevice corrosion, and pitting. Draining any potential water from the carbon steel fuel oil day tank and drip tank after perfonning diesel run testing can contribute toward mitigating the efTects of general corrosion, c>r At corrosion, and pitting. Draining water from the fuel oil day tank will contribute to the mitigation oi 4ae ARDMs in the diesel fuel oil drip tank. This technique will also contribute toward mitigating the cifects of MIC, (Reference 2, Attachment 8]
Maintaining fuel oil within established chemistry specifications can minimize the possibility of microbe growth, build up of sludge, and corrosive efTects of water in the carbon steel tanks. [ Reference 2, Attachment 8)
Maintaining the EDO jacket cooling water chemistry can minimize the possibility of corrosion and pitting on the internal surfaces of this cooling system. The other environments mentioned above do not lend themselves to mitigation of thcae ARDMs, so the discovery methods mentioned below are utilized to manage aging of general corrosion, crevice corrosion, and pitting on the internal surfaces of the remaining EDO System components.
Discong: The effects of these ARDMs are detectable by visual and sampling techniques. Inclusion of EDG System components in a program that examines a representative sample of susceptible areas of the system for the signs of general corrosion, crevice corrosion, and pitting prior to the period of extended operation could discover whether these ARDMs are actually occurring in the EDO System.
[ Reference 2, Attachment 8)
Regular maintenance, overhaul, and inspections of EDO System components could also discover signs of general corrosion, crevice corrosion, and pitting. [ Reference 2, Attachment 8]
Application for License Renewal 5.8 15 Calvert Cliffs Nuclear Power Plant
- AIIACEMrNT (2i APPENDIX A TECHNICAL INFORMATION 5.3 . EMENGENCY DIESEL GENERATOR SYSTEM Group I (general corrosion, cres lee corrosion, and pitting) . Aging Managensent Prograses Ihternal Mitigarlon: 1 hough painting of the exterior surfaces mitigates the possibility of external corrosion, no credit is taken for this coating in mitigating extemal corrosion.
Djunny: Calvert Cliffs Mechanical Preventive Maintenance (MPM) MPM07117," Inspect EDO Air intake Filters," is credited with the discovery of general corrosion, crevice conrosion, and pitting on the external surfaces of the EDO intake filters. Calvert Cliffs MPM13110," Perform Visual Examination for EDO Exhaust Components," is credited for discovery of external crevice corrosion, general corrosion, and pitting of the EDO exhaust piping and exhaust mumer. These MPMs are performed in accordance with CCNPP Administrative Procedure MN.I.102," Preventive Maintenance Program." Refer to the full discussion of these programs in the Discovery Section below.
internal Mitigation:
Calmi. Cliffs Technical Procedure cP 226 Calvert Cliffs Technical Procedure CP.226, " Specification and Surveillance Diesel Fuel Oil," is credited for mitigating the effects of crevice corrosion, general corrosion, and pitting on the interior-surfaces of the E!X) diesel fuel oil day tanks, and drip tanks with associated tank mounted level switches by sampling fuel oil before it is unloaded to the FOSTs. Under CCNPP Technical Procedure CP 226, fuel oil chemistry is controlled, including testing for the presence of biologics. The procedure establishes surveillance frequencies, fuel oil specifications (e.g., viscosity, % water and sediment, paniculate contamination and biologics), and corrective actions. Sampling and analysis are performed on new fuel prior to unloading from fuel trucks. This procedure specifies limits for water, viscosity, and sediment for both receipt inspection and Technical Specification surveillance for fuel oil in the FOSTs in accordance with the standard American Society for Testing and Materials ASTM D975 81. The procedure currently has target values and action levels that give an acceptable range or limit for a given parameter. There are two action levels associated with CP 226. Action Level I gives a value or range of values that are inconsistent with the goals of HGE's Chemistry organization (indicate an adverse trend),
while Action Level 2 gives a value or range of values that exceed Technical Specifications. Two of the parameters, kinematic viscosity and waterhediment, have Action Level 2 associated with them. The CCNPP Technical Specifications related to CP 226 are 4.7.11.1.2b and 4.8.1.1.2.b. [Ref . ice 9]
lhis procedure now requires the addition of a stabilizer / corrosion inhibitor prior to unloading fuel oil into the focl oil storage tanks (FOSTs). Prior to adoption of this new approach, the stabilizer / inhibitor was being added in $$ gallon batches once a year. The new approach provides a better assurance that the desired ratio of inhibitor to fuel oil exists, in August 1989, chemistry procedure. CP.226 was revised to incorporate criteria in accordance ASTM D270 65 for taking quarterly samples from the diesel FOSTs. This revision involves taking multilevel samples from each diesel FOST rathcr than sampling only from the tank bottom, as was donc previously.
Application for License Renewal . 5.8 16 Calvert Clifts Nuclear Power Plant
, ATTACHMENT (2)
APPENDIX A - TECilNICAL INFORMATION 5.8 . EMERGENCY DIESEL GENERATOR SYSTEM Calvert Cliffs Chemistry Procedure CP 222 Calvert Cliffs Chemistry Procedure CP 222, "Specl0 cations and Surveillance for Diesel Generators' Jacket Cooling Water System," is credited with mitigating the effects of general corrosion, crevice ;
corrosion, and pitting of the cooling water piping and jacket water expansion tanks by monitoring and maintaining EDG jacket water chemistry (e.g., pil, dissolved oxygen). This procedure contains two different sets of chemistry parameters, one for the I airbanks Morse EDGs and one for the SACM EDO.
'the water is treated with hydrazine cr corrosion inhibitors to minimize the amount of oxygen in the water, which aids in the prevention and control of most corrosive mechanisms. Continued maintenance of system water quality will ensure minimal EDO jacket water expansion tank and cooling water piping degradation. [ Reference 10]
Procedure CP 222 describes the surveillance and speci0 cations for monitoring the EDO jacket water.
Procedure CP 222 lists the parameters to monitor, the frequency of monitoring these parameters, and the target and action levels for the EDO jacket cooling water parameters. Action Level I gives a value or range of values that are inconsistent with the goals of13GE's Chemistry organization and that indicate an adverse trend. 'the target level is a valu; or range of valaes for a chemical parameter that is a goal or predetermined warning ilmit. The parameters currently monitored by CP 222 are pli, hydrazine, dissolved oxygen, dissolved copper, dissolved iron, suspended solids, biological activity, and propylene glycol concentrations. 'luese chemistry parameters are currently monitored on a frequency ranging from once per week to once a year. [ Reference 10, Section 3, Attachments 1,2)
Procedure CP 222 provides for a prompt review of EDO jacket water chemistry parameters so' that steps can be taken to return chemistry parameters to normal levels, and thus minimize the effects of general corrosion, crevice corrosion, and pitting.
'the CCNPP Surveillance Test Procedures STP 0 8A 2. STP 0-8B 1, STP-O-8B 2 are credited for mitigation of crevice corrosion, general corrosion, pitting 2d MIC on the interior of the diesel fuel oil '
day tanks. the procedures provide for periodic draining of diesel fuel oil day tank of any water that may be present, which minimizes the corrosive effects of water on carbon steel and the drip tanks that drain to the day tanks. 'lle tank sample is taken and visually examined for the presence of water in the fuel. This procedure is currently perfonned monthly aner the EDGs are shut down from testing. [ References 11, 12, and 13]
Dhcacry: The CCNPP Age Related Degradation inspection (ARDI) Program will be credited with the discovery of crevice corrosion, general corrosion, and pitting on EDG starting air system hand valves, EDO cooling water hand valves, drain traps, starting air accumulators, Jacket water expansion tanks, diesel fuel oil day tanks and drip tanks with associated level switches, EDO cooling water piping, and EDG System exhaust piping and mufDers. [ Reference 2, Attachment 1)
The ARD1 Program is denned in the CCNPP IPA Methodology presented in Section 2.0 of this application.
Application for License Renewal 5.8 17 Calvert C!iffs Nuclear Power Plant
, ATTACHMENT (2)
APPENDIX A - TECHNICAL INFORMATION
,1 - EMERGENCY DIESEL GENERATOR SYS'IEM ne elements of the ARDI Program willinch!de:
e Determination of the examination sample size based on plausible aging effects; }
e Identification of inspection locations in the system / component based on plausible aging effects and consequences ofloss of component intended function; e Determination of examination techniques (including acceptance criteria) that would be effective, considering the aging effects for which the component is examined; ,
- Methods for interpretation of examination results;
- Methods for resolution of adverse examination firidings, including consideration of all design loadings required by the CLI) and specification of required corrective actions; and
- Evaluation of the need for follow up examinations to monitor the progression of any age-related degradation.
%c ARDI Program will contain acceptance criteria that ensure corrective actions taken will bc taken such that the hand valves and drain traps subject to general corrosion, crevice corrosion, and pitting remain capable of performing their intended functions under all CLB conditions.
Calvert Cliffs Preventive Maintenance (PM) Program The CCNPP PM Program has been established to maintain plant equipment, structures, systems, and components in a reliable condition for normal operation and emergency use, minimize equipment failure, and extend equipment and plant life. [ Reference 14, Section 1.1]
ne program is governed by CCNPP Administrative Procedure MN 1 102 and covers all PM activities ,
for nuclear power plant structures and equipment within the plant, including the EDG System components within the scope oflicense renewal. Guidelines down from industry experience and utility best practices were used in the development and enhancement of this program.
He PM Program includes periodic inspection of specific components through various maintenance activities. These activities provide an effective means to discover and manage the age-related degradation effects on these components. The program requires that an issue Report be initiated according to CCNPP Procedure QL 2100, " Issue Reporting and Assessment," for deficiencies noted during performance of PM tasks. Corrective actbns are taken to ensure that the affected components remain capable of performing their passive intended ftmetions under all CLB conditions. [ Reference 14, Section 5.2.B.I.f]
The PM Program undergoes periodic evaluation by the NRC as part of their routine licensee assessment activities. [ Reference 15] ne PM Program also has had numerous levels of management review, all the way down to the specific implementation procedures. Specific responsibilities are assigned to BGE personnel for evaluating and upgrading the PM Program and for initiating program improvements based on system performance issue Reports are initiated according to CCNPP Procedure QL-2-100 to request changes to the program that could improve or correct plant reliability and performance. Changes to the PM Program that require issue Reports include changes to the PM task scope, frequency, process, and those resulting from operating experience reviews. [ Reference 14, Sections 5.1.A and 5.4]
. Application for License Renewal 5.8 18 Calvert Clifli Nuclear Power Plant
ATTACHMENT (2)
APPENI)fX A - TECHNICAL INFORMATION
- 5.8 - EMERGENCY DIESEL GENERATOR SYSTEM Under the PM program, general corrosion, crevice corrosion, pitting, MIC, foullng, fatigue, corrosion fatigue, wear, and/or particulate wear erosion for several EDO components are managed through existing !
PM tasks and checklists, which can require inspections and overhauls. Preventive maintenance is ,
scheduled by PM repetitive tasks. He implementation of the PM san be just the repetitive task, or a checklist, maintenance praedure, or checklist called for by a repetitive task that then calls for a maintenance procedure. [ Reference 2, Attachment l] ne following summarizes the components and corresponding PM checklists that will manage ARDMs for these components.
He following CCNPP MPM checklists are credited with the discovery of the effects of general corrosion of internal piping surfaces for EDO starting air, and combustion air intake systems: [ Reference 2, Attachment 1]
- Calvert Cliffs MPM0ll25, " Remove Relief Valve, Test and Reinstall," is currently performed every four years; [ Reference 16)
- Calvert Cliffs MPM07006, " Disassemble, inspect and Overhaul EDO Check Valve," is currently prformed every 6 years; [ Reference 17]
- Calvert Cliffs MPM13000," Clean and Inspect EDO Air Stad Distributor and Check Valves," is currently perfcrmed every 4 years; [ Reference 18]
- Calvert Clifts MPM13002," Inspect EDO Air Start Valves and Filters," is currently performed every 96 weeks; and [ Reference 19]
nes: MPMs will be modified to inspect specifically for corrosion of piping and check for the presence of debris in valves that t.ould indicate the piping in these systems is undergoing corrosion. [ Reference 2, Attachment 1]
Calvert Cliffs MPM07117 " Inspect EDO Air intake Filters," is currently performed at approximetely 4 year intervals. [ Reference 20] The MPM will be modified to inspect the attached piping fer signs of corrosion. [ Reference 2, Attachment 1]
Checklist MPM13110 is credited with the discovery of crevice corrosion, general corrosion, and pitting of the EDO exhaust piping and exhaust mutiler. His task is performed at approximately two year intervals. [ Reference 2, Attachment 1; Reference 21]
Checklist MPM07006 is credited with discovery of the effects of pitting. crevice corrosion, and general corrosion of the internal surfaces of EDO Starting Air System check valves. [ Reference 2, Attachment 1; Reference 17)
- Checklists MPM13003, " Clean / Inspect 2B EDO Lube Oil "Y" Strainers and Baskets," MPM13004, ;
" Clean / Inspect IB EDO Lube Oil "Y" Strainers," and MPM13005, " Clean / Inspect 2A EDO Lube Oil j "Y" Strainers and Baskets," are credited with discovery of the effects of pitting, crevice corrosion, and general corrosion on the wye strainer internal surfaces. The MPMs will be modified to check for signs of corrosion on the wye strainer internal surfaces, nese tasks are currently performed at approximately 96 week intervals. [ Reference 2. Attachment 1; References 22,23, and 24]
, ; Application for License Renewal 5.8 19 Calvert Cliffs Nuclear Power Plant -
-, -~-
a s + .c ,,---. - - _aw,- .
, ATTACHMENT m APPENI)lX A - TECHNICAL INFORMATION 5.3 . EMERGENCY DIESEL GENERATOR SYSTEM Clwklist MPM07117 is credited with discovery of the effects of pitting, crevice corrosion, and general corrosion on internal surfaers of the EDO intake ihrs and intake mumers as previously described above 'Ihh MPM will be modified to check for signs of corrosion and to specifically include the intake mumer in l's scope. [ Reference 2, Attachment 1, Reference 21]
Group 1 (general corrosion, erevlee corrusion, and pitting) . Demonstration of Aging Management Based on the information presented above, the following conclusions can be reached with respect to general corrosion, crevice corrosion, pitting of the components of the EDO System:
e 'Ihe EDO System Group I components listed under Materials and Environment contribute to meintainmg pressure boundary function.
e General corrossen, etevice corrosion, and pitting are plausible ARDMs for both the internal and extetnal surfaces of EDO System components because of their materials of construction and exposure to enstrorneuts that contribute to these ARDMs. If unmanaged, these ARDMs could ven% u:sult tsuhe loss of piessure-retaining capability under CLB design loading conditions.
- Cahen uii's Tedmisal Drncedure CP 226 mitigates the effects of crevice corrosion, general corrosion, and pitting on the interior surfaces of the EDO ii.cl oil day tanks through the control of fuel cil chemistry, inciJng biologics.
- Calvert Cliffs Chemical Procedure CP 222 mitigates the effects of crevice corrosion, general
. corrosion, and pitting on the interior surfaces of the EDG jacket water expansion tank and cooling water piping by monitoring and maintaining the EDO jacket cooling water chemistry.
- The CCNPP ARDI Program will discover the efTects of crevice ce Tosion, general corrosion, and pitting on the internal surfaces of EDO starting air system hand valves, SRW cooling hand valves, drain traps, sttn.ng air accumulators, Jacket water expansion tanks, diesel fuel oil day tanks and drip tanks with associated tank mounted level switches, EDO cooling water piping, and EDO System exhaust piping and mufflers.
- 'Ile CCNPP Preventive Maintenance Program will dircover the effects of external and internal general corrosion, crevice corrosion, and pitting for several EDG components through the use of MPMs. The ARDMs are managed through existing PM checklists, periodic inspections, and periodic overhauls. Some of the MPMs previously listed will be modified to add these ARDMs and/or EDG components to the scope of their existing surveillance.
- 'lhe CCNPP Surveillance Test Procedures STP 0 8A 2, STP-O-8B-1, and STP O-88 2 will mitigate the effects of crevice corrosion, general corrosion, and pitting on the interior of the diesel fuel oil day tanks by sampling these tanks for the presence of water and draining any water that is found.
Therefore, there is reasonable assurance that the effects of general corrosion, crevice corrosion, and
- pitting will be adequately managed for the EDO System components such that they will be capable of performing their intended functions consistent with the CLB during the period of extended operation under all design loading conditions.
s Application for Ucense Renewal 5.8 20 Calvert Cliffs Nuclear Power Plant
A*ITACIIMENT (2) ;
APPENI)IX A . TECHNICAL INFORMATION i 5.g - EMERGENCY DIESEL GENERATOR SYSTEM '
Group 2 teorrosion fetisme/ fatigue) . Materials and Environment Table $.8 3 shows that the EDO exhaust piping and muffler are susceptible to corrosion fatigue and/or fatigue. The material characteristics of these device types are listed below: [ Reference 2, Attachments 4,5,6,111105, MUFF 02]
e lill . exhaust piping, fittings, flanges (carbon steel), and bolting (alloy steel); and
- MUFF exhaust muffler bodies (cark n steel).
De external environment for components subject to corrosion fatigue / fatigue is the Diesel Generator ilullding atmosphere and outdoor ambient air. Outdoor ambient air is variable and subject to daily and seasonal weather changes.
The internal environments for these components consist of periodic exposure to hot diesel engine exhaust gases that contain moisture and entrained particulates. liigh temperatures during diesel operation, wetting, and drying of the piping / muffler exterior in inclement weather provide the necessary conditions ,
foi these ARDMs to occur. [ Reference 2,Illi, MUFF, Attachments 4,6)
Gromp 2 (corrosion fatigue / fatigue). Aging Meehanism Effects Corrosion fatigue occurs when plant equipment operates in a corrosive environment subjected to cyclic -
(fatigue) loading that may initiate cracks and/or fall sooner than when these ARDMs are applied separately. Fatigue crack initiation and growth usually follow a transgranular path, although there are some cases where intergranular cracking has been observed. In some cases, crack initiation occurs by fatigue and is subsequently dominated by corrosion advance, in other cases, a corrosion mechanism can be responsible for crack initiation below the fatigue threshold, and the fatigue mechanism can accelerate the crack propagation. Corrosion fatigue is a potentially active mechanism in carbon and low alloy steels. (Reference 2, Attachment 7]
Fatigue damage results from progressive, localized structural change in materials subjected to fluctuating stresses and strains. Associated failures may occur at either high or low cycles in response to various kinds of loads (e.g., mechanical or vibration loads, thermal cycles or pressure cycles). Fatigue cracks initiate and propagate in regions of stress concentratlo;, that intensify strain. [ Reference 2, Attachment 7]
%c EDO components listed above in the Materials and Environment Section are subjected to corrosive environments and also experience cyclic stresses during EDO operation. Therefore, these ARDMs are plausible for the these EDO components and, if unmanaged, may lead to loss of the pressure boundary function. [ Reference 2 Attachment 6]
Group 2 (corrosion fatigue / fatigue) JMethods to Manage Aging MI'le*'lon: There are no feasible ways to prevent corrosion fatigue and fatigue from occurring on the EDO exhaust pipmg and mufilers other than limiting operation of the EDGs. The EDGs must be periodically operated to ensure that they are capable of performing their design functions. Therefore, there are no means to mitigate these ARDMs.
Application for License Renewal S.8 21 Calvert Cliffs Nuclear Power Plant L
. ATTACllMENT fB APPENDIX A TECHNICAL INFORMATION '
5.8 . EMERGENCY DIESEL GENERATOR SYSTEM Discovsty: The effects of corrosion fatigue and fatigue can be discovered by periodic examinations of the EDO exhaust piping and mufflers. ;
Group 2 (corrosion fatigue / fatigue). Aging Management Programs Mitiggion: 1here are no CCNPP programs credited with the mitigation of corrosion fatigue and fatigue i of the EDO exhaust piping and mumers.
Discoverv: The CCNPP PM Program includes MPM13110, which is credited with the discovery of corrosion fatigue and fatigue on the external surfaces of the EDO exhaust piping and exhaust mumer, This will be performed through inspections of the EDO exhaust piping and mumer. This task is currently performed at app.oximately two year intervals. The PM Program is discussed in Group 1 (general corrosion, crevice corrosion, and pitting) under Aging Management Programs.
[ Reference 2, Attachments 8,10; Reference 21] ,
lhe CCNPP ARDI Program will provide for the discovery of the effects of corrosion fatigue / fatigue on the internal surfaces of the EDO exhaust piping and exhaust mumers. Refer to the pwvious discuss!on of this program in Group 1 (general corrorlon, crevice corroshn, and pitting) under Aging Management Programs.
Group 2 (corrosion fatigue / fatigue) . Demonstration of Aging Management llased on the information provided above, the following conclusions can be reached with respect to corrosion fatigue and fatigue of the EDO components:
- The EDO exhaust piping and mumer contribute to the pressure boundary function, which must be maintained under all CLil design loading conditions.
- The EIX3 exhaust piping and mumer are susceptible to these ARDMs due to the environmental and service conditions they are exposed to during operational testing and emergency use, e Calvert Cliffs MPM13110 will discover the effects of corrosion fatigue and fatigue on external surfaces of the EDO exhaust piping and exhaust mumers. This MPM will be modified to include inspection of the piping and mumer for signs of these ARDMs.
- 1he CCNPP ARDI Program provide for the discovery of the effects of corrosion fatigue / fatigue on the internal surfaces of the EtX) exhaust piping and exhaust mumers.
Therefore, there is reasonable assurance that the effects of corrosion fatigue and fatigue will be adequately managed for EDO System components such that it will be capable of performing their intended function consistent with the CLB during the period of extended operation under all design loading conditions, n i Application for License Renewal 5.8 22 Calvert Cliffs Nuclear Power Plant
' AlTAcilMhT di i APPENDIX A - TECilNICAl, INFORMATION 5.8. EMERGENCY DIESEL GENERATOR SYSTEM Group 3 (erosion corrosion / particulate wear erosion)-Materials and Environment As Table 5.8 3 shows, the EDO cooling water piping is susceptible to erosion c, rosion, and the ElX1 ^
exhaust muf0ers are susceptible to erosion corrosion and particulate wear crosion. The material characteilstics of these device types are listed below: [ Reference 2, 11001, MUFF 02, Attachments 4,5,6]
e 1111. pipe and fittings (carbon steel); and e MUFF . exhaust mumer bodies (carbon steel).
1hc internal environment for the EDO exhaust mumers experience periodic exposure to hot diesel engine exhaust gases that contain moi 'ure 89d entrained particles. The cooling water serving the EDOs contains chemically. controlled SRW that has reduced levels of oxygen. [ Reference 2,11B01, MUFF 02, Attachments 4,6]
Group 3 (crosion corrosion / particulate wear erosion) Aging Mechanism Effects Erosion corrosion is the increased rate of attack on a metal because of the relative movement between a corrosive Guld and the metal surface. Mechanical wear or abrasion can be involved, characterized by grooves, gullies, waves, holes, and valleys on the metal surface. Carbon or low alloy steels are particularly susceptible when in contact with high velocity water (single or two phase) with regions of disturbed flow, low oxygen, and Guld pil < 93. The water in the SRW piping has a low oxygen content and regions of disturbed How; therefore, crosion corrosion is plausible for this EDO piping. Ilot exhaust gases with levels of particle matter and moisture may tend to erode internal EDO exhaust mumer material. [ Reference 2, .1111, MUFF, Attachments 6,7]
Particulate wear erosion is the loss of material caused by mechanical abrasion due to relative motion between a Duld (liquid or gas) and material surface. This form of crosion requires high velocity Huld, entrained particles, regions of disturbed Dow, How direction change, and/or impingement. The EIXi exhaust gases at high temperatures may tend to erode certain locations in the mumers as these gases traverse v:'ous now pathe. Although the particulate loading is not likely to result in "true" particulate wear crosion, the impact of high temperature gases with some particulate matter and moisture may tend to erode the pressure boundary material, especially in locrJOns of Cow direction changes. [ Reference 2, FL, Attachment 7, MUFF, Attachment 6]
Group 3 (crosion corrosion / particulate wear erosion)- Methods to Manage Aging Mitintion: The effects of erosion corrosion of the coo!lng water piping can be mitigated by control of the system's water chemistry. Maintaining higher levels of oxygen can lower the effects of crosion corrosion; however, higher oxygen levels can lead to other ARDMs such as corrosion. There are also no means of mitigating the effects of particulate wear erosion of the exhaust mumer bodies other than not operating the system 'this is not a feasible solution since the EDGs must be periodically operated to ensure they are available to perform their intended functions.
Discosern 1he effects of crosion corrosion on pipe internal surfaces can be discovered with a program of inspections. Similarly, inspections can discover the effects of crosion corrosion / particulate wear erosion on the internal surfaces of the EIX) exhaust mumer.
- Application for I.icense Renewal 5.8 23 Calvert Cliffs Nuclear Power plant
i KITACllMENT (2) t APPENDIX A TECHNICAL INFORMATION 5.8 . EMERGENCY DIESEL GENERATOR SYSTEM _ l Group 3 (erosion corrosion / particulate wear erosion) . Aging Management Programs Mitigation: There are no programs credited with the mitigation of crosion corroslon or particulate wear crosion on the EDO piping or exhaust mumers.
Discovery; The CCNPP ARDI Program provide for the discovery of the efTects of erosion corrosion on the internal surfaces of the EDG cooling water piping and erosion corrosion / particulate wear crosion on the EDO exhaust mumers. Refer to the previous discussion of this program in Group 1 (crevice corrosion, general corrosion, and pitting) under Aging Management Programs. [ Reference 2, Attachments I,8]
Group 3 (erosion corrosion /,naj se wear erosion). Demonstration of Aging Management liased on the information prc','.dco above, the following conclusions can be reached with respect to the crosion corrosion / particulate wear crosion of the EDO components:
e lhe !!DO cooling water piping and mumer contribute to the passive intended pressure boundary fur.. tion, which must be maintained under all CLil design loading conditions.
- The EDO cooling water piping and mumer are susceptible to crosion corrosion and particulate wear crosion for which the effects of these aging mechanisms must be managed during the period of extended operation.
- 1he CCNPP ARDI Program will provide for the discovery of the effects of crosion corrosion on the internal surfaces of the EDO cooling water (SRW) piping and the efTects of crosion corrosion / paniculate weer crosion on the EDG cxhaust mumers.
Therefore, there is reasonable assurance that the effects of crosion corrosion and particulate wear erosion will be adequately managed for EDO System components such thet they will be capable of performing their intended function consistent with the CLil during the period of extended ope i under all design loading conditions.
Group 4 (MIC) . Materials and Environmeat As Table 5.8 3 shows, the EDG dicsci fuel oil day tanks, drip tanks and their level switches, are susceptible to the effects of MIC. The material characteristics of these components are listed below:
[ Reference 1, TK02, Attachments 4,5,6)
- TK fuel oil day tank vessels (carbon steel);
e TK fuel oil drip tank vessels (carbon steel); and e TK . fuel oil drlp tank level switches (no material given).
- The internal environment of these tanks is diesel fuel oil, dicsci fuel oil vapon, and atmospheric air containing moisture, in addition, some water may condense in the tank and biological contaminants may be present. The external environment for these tanks is the controlled environment of the Diesel ,
Generator ilullding atmosphere. [ Reference 2, Attachments 4s,6s]
Application for License Renewal 5.8-24 Calvert Cliffs Nuclear Power Plant
ATTACllMENT (2)
APPENDIX A TECHNICAL INFORMATION 5.8 - EMERGENCY DIESEL GENERATOR SYSTEM Group 4 (MIC) Aging Mechanism Effects Microbiologically-induced corrosion is the accelerated corrosion of materials resulting from surface microbiological activity. Sulfate reducing bacteria, sulfur oxidizers, and iron oxidizing bacteria are most commonly associated with corrosion effects. His can ollen result in pitting followed by excessiw deposition of corrosion products. Temperatures between about 50'F and 120'F with stagnant conditions are most conducive to MIC, in diesel fuel oil applications fur i have been known to grow into long strips, and form large mats or globules. They may grow throughout tie fuel or at the interface area between the fuel and any water that is in the tank bottom. %cir growth chemically alters the fuel by producing sludge, acids, and othe, products of metabolism. When they adhere to the fuel containing surfaces, the water and waste products lead to corrosion. [ Reference 2. ACC, Attachment 7]
Group 4 (MIC)- Methods to Manage Aging Mitigationi Diesel fuel oil is corrosive when water (from condensation) is present with the fuel oil.
Periodic draining of water from the carbon steel fuel oil day tank and drip tank after performing diesel run testing can mitigate the effects of MIC. [ Reference 2, Attachment 8]
Maintaining fuel oil within established enemistry specifications can minimize the possibility of microbe growth, build up of sludge, and corrosive effects of water in the carbon steel tanks. [Referrence 2, Attachment 8]
The effects of MIC can be mitigated by removing environmental factors, like water, essential for this ARDM to exist. In addition, surveillance programs that can detect and control contributing environmental factors can mitigate MIC from forming in or on the Group 4 EDG components.
Discoverv: Inclusion of EDO System components in an ARDI Program, which examines a r:presentative sample of susceptible areas of the rystem for the signs of MIC prior to the period of extended operation, could discover whether this ARDM is actustly occurring in the EDO System.
[ Reference 2, Attachment 8]
Group 4 (MIC) Aging Management Programs Mitigation: Calvert Clifts Technical Procedure CP 226 is credited with mitigating the elTects of MIC on EDO diesel fuel oil day tanks / drip tankc interior surfaces and on the surfa:e of the drip tank level switches. Under CP 226, fuel oil chemistry is controlled, including testing for the prescuce of biologics.
Refer to the previous discussion of this procedure in Group 1 (generai corrosion, crevice corrosion, and pitting)under Aging Management Programs.
He CCNPP Surwillance Test Procedures STP-0-8A 2, STP 0-8111. STP O-8Il-2 are credited for the mitigation of MIC on the interior surfaces of the diesel fuel oil day tanks / drip tanks and surface of the
__ drip tank level switches. He procedure provides for periodic draining of diesel fuel oil day tanks for the presence of water. He tanks are completely drained of all water if any is present. Draining the day tanks of all water minimizes the corrosive efTects of water on carbon steel and the drip tanks that drain to the day tanks ~A drain sample is taken and visually examined foi the presence of water in the fuel. His procedure is currently performed monthly afler the EDGs are shut down for testing. [ References ll,12, and 13]
Application for License Renewal- 5.8 25 Calvert Cliffs Nuclear Power Plant
. ATTACllMENT (2)
APPENDIX A TECHNICAL INFORMATION 5.8 - EMERGENCY DIESEL GENERATOR SYSTEM Discoverv: he CCNPP ARDI Program will provide for the discovery of the effects of MIC on the internal surfaces of the EDO diesel fuel oil day tanks / drip tanks and surfaces of the drip tank level switches. Refer to the previous discussion of this procedure in Group 1 (general corrosion, crevice corrosion, and pitting) under Aging Management Programs Group 4 (MIC) Demonstration of Aging Management Based on the information provided above, the following conclusions can be reached with respect to the efTects of MIC of the EDG components:
- The EDO diesel fuel oil day tanks, and drip tanks with associated tank mounted level switches, provide the pressure boundary function of the system, which must be maintained under all CLB conditions during the period of extended operation.
- Microbiologically induced corrosion is plausible for the EDO dicsci fuel oil tanks, and drip tanks with associated level switches, because of their material of construction and exposure to environments that contribute to this ARDM. If unmanaged, this ARDM could eventually result in the loss of pressure retaining capability under CLB design loading conditions.
- Calvert Cliffs Technical Procedure CP 226 will mitigate the effects of MIC on the interior surfaces of the EDO fuel oil day tanks, and drip tanks with their associated level switches, through the control of fuel oil chemistry, including biologies and corrosion inhibitors.
- The CCNPP Surveillance Test Procedures STP 0 8A 2 STP.O-8B 1, and STP-O 8B 2 will mitigate the effects of MIC on the interior surfaces of the EDG fuel oil day tanks, and drip tanks ,
with their associated level switches, by periodically sampling the fuel oil day tanks for the presence of water and draining them of water if any is found.
- Calvert Clifts ARDI Program will provide for the discovery of the effects of MIC on the interior surfaces of the EDO fuel oil day tanks, and d' tanks with their associated level switches.
Herefore, there is reasonable assurance that the efTects of MIC will be adequately managed for EDG System components such that it will be capable of performing their intended function consistent with the CLB during the period of extended operation under all design loading conditions.
Group 5 (wear)- Materials and Environment As table 5.8 3 shows, only the drain traps are subject to wear in the EDO System. The materials of drain traps subcomponents susceptible to wear are: [ Reference 2, Table 4 2, DT, Attachments 3,4,6)
- DT- disk / seat (stainless stect) and pivot rod / plugs (brass).
The intemal environment for these components is that of the EDG starting air system, which is compressed air that can contain moisture, nese valves are subject to periodic movement in performing their operational function.
Application for License Renewal 5.8 26 Calvert Clifts Nuclear Power Plant
- ~ - . - __- _ _. - - . . . . ~ ~ . . . - - _ _ _ _ . . . -
i
. ATTACHMENT (2)
APPENDIX A - TECHNICAL INFORMATION 5.8 . EMERGENCY DIESEL GENERATOR SYSTEM Group 5 Wear). Aging Mechanism Effects Wear results from relative motion between two surfaces (adhesive wear), from the influence of hard, abrasive particles (abrasive wear, see particulate crosion) or fluid stream (erosion), and from small, l vibratory or sliding motions under the influence of a corrosive environment (fretting). In addition to material loss from the above wear mechanisms, impeded relative motion between two surfaces held in intimate contact for extended periods may result from galling /self welding. Motions may be linear, circular, or vibratory in inert or corrosive environments. 'ihe most common result of wear is damage to one or both surfaces involved in the contact. Wear most typically occurs in compoi.ents that experience considerable relative motion, such as valves and pumps, in components that are held under high loads with no motion for long periods (valves, flanges). Wear may proceed at an ever increasing rate with much higher contact stresses then the surfaces of the original geometry. [ Reference 2, PUMP, Attachment 7)
Wear of the internals and pivot rod are possible due to the periodic relative movement of these components during equipment function. Although not operated continuously, these components are subjected to cyclic operation and are subject to these various wear mechanisms. Wear of the seating surface, if unmanaged, could lead to loss of pressure boundary integrity. [ Reference 2, DT, Attachment 6]
Group 5 (wear) . Met' nods to Manage Aging Mitigation: The effects of wear could be mitigated by minimizing equipment operation. Ilowever, this is not operationally feasible; therefore, the effects of wear cannot be mitigated during plant operation.
Discmsty; inclusion of the drain trap components in an ARDI Program that visually examines a representative sample of susceptible areas of the system for the signs of wear prior to the period of extended omation could discover whether wt .r is a;tually occurring in the DT components.
[ Reference 2 Attachment 8]
Group 5 (wear) . Aging Management Programs Mitigation: Other than proper material selection, design, and installation, there are no programs credited with the mitigation of wear on the EDO drain trap components.
Discoverv; The CCNPP ARDI Program will provide for the discovery of the efTects of wear on the EDO starting air system drain trap components. The ARDI Program will include the representative inspections of the internal surfaces of the EDG starting air system drain trap components. [ Reference 2, Attachment 1] Refer to the previous discussion of this ARDI Program in Group 1 (general corrosion, crevice corrosion, and pitting) under Aging Management Programs, i< Application for License Renewal 5.8 27 Calvert Clifts Nuclear Power Plant
. ATTACHMENT (2)
APPENDIX A TECilNICAL INFORMATION 5.8 . EMERGENCY DIESEL GENERATOR SYSTEM Group 5 (wear) . Desmonstration of Aging Management
!!ased ot. the information presented above, the following conclusions can be reached with respect to the EDO starting air system drain trap components susceptible to wear:
e lhe EDG drain trap components contribute to maintaining the pressure boundary that must be maintained under CLB design conditions.
e Wear is plausible for the EDO drain trap components. The internals and pivot rod may periodically experience cyclic operation. The expected effect of wear is a progressive loss of pressure boundary scaling capability, e The CCNPP ARDI Program , vill provide for the discovery of any wear on the internal surfaces of EDO drain traps components.
Therefore, there is reasonable assurance that the efTects of wear of EDG starting air system drain traps will be managed in order to maintain their intended function under all design loading conditions required by the CLB during the period of extended operation.
5.8.3 Conclusion ,
The programs discussed for the EDO System components are listed on the following table. E cse programs are, or will be. administratively controlled by a formal review and approval process. As demonstrated above, these programs will manage the aging mechanisms and their effects such that the intended functions of the E!X) System components will be maintained consistent with the CLB during periods of extended operation.
The analysis / assessment, corrective action, and conf'rmation/ documentation pro.ess for license renewa' is in accordance with Ql-2, " Corrective Actions P.mgram." QL 2 is pursuant to 10 CFR Part 50, Appendix !!, and covers all structures and componer.ts subject to AMR.
e Application for License Renewal 5.8-28 Calvert Cliffs Nuclear Power Plant
ATTACllMENT d)
APPENDIX A - TECilNICAL INFORMATION 5.8 EMERGENCY DIESEL GENERATOR SYSTEM TABLE 5.8-4 LIST OF AGING MANAGEMENT PROGRAMS FOR EDG SYSTEMS Program . Credited as Existing CCNPP Specification and Mitigation of the effects of general corrosion, crevice Surveillimee Diesel corrosion, and pitting (Group 1) for the EDG jacket water Generators' Jacket Cooling expansion tanks and cooling water piping.
System (CP 222)
Existing CCNPP Specification and Mitigation ci the effects of general corrosios crevice Surveillance D esel Fuel corrosion, pitting (Group 1), and MIC (Group 4) for the Oil (CP 226) interior surfaces of the diesel fuel cil day tanks, drip tanks with associated level switches.
Existing CCNPP Surveillance Test Mitigation of general corrosion, crevice corrosion, pitting Procedures (STP O-8A 2. (Group 1), and MIC (Group 4) for the interior surfaces of STP O-8B-2, STP O-8tM) the diesel fuel oil day tanks / drip tanks by draining them for Testing EDGs and the after EDG testing for the presence of any water.
4 kV LOCA Sequencers Modified Several repetitive tasks Discovery of effects of general corrosion, crevice calling for MPM0ll25, corrosion, and pitting (Group 1) on the internal surfaces of Remove Relief Valve, Test the EDG starting air and combustion air intake piping, and Reinstall The MPM will be modined to inspect for corrosion of piping and check for the presence of debris in valves that could indicate the piping in these systems is undergoing corrosion.
Modified Several repetitive tasks Discovery of effects of general corrosion, crevice calling for MPM07006, corrosion, and pitting (Group 1) on the internal surfaces of Disassemble, inspect and the EDG starting air acd combustion air intake piping and Overhaul EDG Check starting air system check valves. The MPM vill be Valve modified to inspect for corrosion of piping and check for the presence of debris in valves that could indicate the piping in these systems is undergoing general / crevice corrosion.
Modified Several repetitive tasks Discovery of effects of general corrosion, crevice calling for MPM13000, corrosion, and pitting (Group 1) on the internal surfaces of Clean and Inspect EDG Air the EDG starting air and combustion air intake piping.
Start Distributor ar.d Check The MPM will be modified to inspect for corrosion of Valves piping and check for the presence of debris in valves that could indicate the piping is undergoing corrosion.
Modified Several repetitis e tasks Discovery of effects of general corrosion, crevice calhng for MPM13002, corrosion, and pitting (Group 1) on the internal surfaces of Inspect EDG air Start the EDG starting air and combustion air intake piping.
Valves and Filters The MPM will be modified to inspect for corrosion of piping and check for the presence of debris in valves that could indicate the piping in these systems is undergoing corrosion.
l Application for License Renewal 5.8-29 Calvert Cliffs Nuclear Power Plant
AllACilMENT (2)
APPENDIX A - TECIINICAL INFORMATION 5.8 - EMERGENCY DIESEL GENERATOR SYSTEM TABLE 5.8-4 LIST OF' AGING MANAGEMENT PROGRAMS FOR EDG SYSTEMS J Program - '
i Credited as :
Modified Several repetitive tasks Discovery of etfects of general corrosion, crevice calling for MPM07117, corrosion, and pitting (Group 1) on the internal surfac< of Inspect EDG Airintake the EDG starting air / combustion air intake piping, in ernal Filters surfaces of the EDG intake filters and intake mufness, and external surfaces of the EDG intake filters. The MPM will be modi 6ed to inspect attached piping for signs of corrosion.
Modified Several repetitive tasks Discovery of effects of general corrosion, crevice calling for MPM13003, corrosion, and pitting (Group I) on the internal surfaces of
, MPM13004/MPM13005 the wye strainers. These MPMs will be modified to check Clean / Inspect 21),1 B, and for signs of corrosion on the wye strainer internal surfaces.
2A EDG I ube Oil"Y" Strainers and Baskets Modified Several repetitive tasks Discovery of the effects of general corrosion, crevice calling for MPM13110, corrosion, and pitting (Group 1); corrosion fatigue / fatigue Perform Visual (Group 2) on the external surfaces of the EDG cxhaust Examination for EDG piping and mufilers. The MPM will be modified to look Exhaust Components for signs of corrosion fatigue / fatigue on the external surfaces of the EDO exhaust piping and exhaust muf0ers.
New CCNPP ARDI Program Discovery of the effects of general corrosion, crevice corrosion, and pitting (Group 1) on the internal surfaces of the EDG starting air accumulators, jacket water expansion tanks, diesel fuel oil day tanks, and drip tanks with their associated tank level switches, hand valves, drain traps, exhaust piping and muf0ers, and cooling water piping. It is also credited with the discovery of corrosion fatigue / fatigue (Group 2) on the internal surfaces of the EDG exhaust piping and exhaust muf0ers; crosion corrosion (Group 3) on the internal surfaces of the EDG cooling water piping and erosion corrosion / particulate wear crosion on the internal wrfaces of the EDG exhaust mufflers: MIC (Graup 4) on the internal surfaces of the EDG fuel oil day tanks, drip tanks, and their associated tank level switches; and wear (Group 5) on the internal surfaces of the EDG drain traps.
i Application for License Renewal 5.8-30 Calvert Cliffs Nuclear Power Plant
l *
+ A'ITACilMENT (2)
APPENDIX A - TECilNICAL INFORMATION I 5.8 . EMERGENCY DIESEL GENERATOR SYSTEM __
1 5.8.4 References
- 1. Calvert Cliffs Nuclear Power Plant, Updated Final Safety Analysis Report, Revision 20
- 2. CCNPP Aging Management Review Report for the Emergency Diesel Generator System, Revision 1, Dated September 22,1997
, 3. CCNPP Failure Detail Report for the Emergency Diesel Generators - January 1,1980 to June 1,1997
- 4. Letter from Mr. C. J. Cowgill (NRC) to Mr. R. E. Denton (DGE), ), dated December 9,1993, "NRC Region I Combined Inspection Report Nos. 50-317/318/93-30 (October 10,1993 -
November 13,1993
- 5. BGE Drawing 64320,"Simplined System Drawing Diesel No. 2A Starting Air, Fuel & Lube Oil," Revision 6, April 29,1997
- 6. BGE Drawing 64321, "Simplined System Drawing Diesel No. IB Starting Air, Fuel & Lube Oil," Revision 3, October 3,1996
- 7. BGE Drawing 64322,"Simplined System Drawing Diesel No. 2B Starting Air, Fuel & Lube Oil," Revision 4. March 16,1997
- 8. CCNPP Component Level ITLR Screening Results for the Emergency Diesel Generator System, Revision 2, September 22,1997
- 9. CCNPP Chemistry Procedure CP-226, " Specification and Surveillance Diesel Fuel Oil,"
Revision 4, dated March 27,1997
- 10. CCNPP Chemistry Procedure CP-222, "Speci0 cations and Surveillance Diesel Generators' Jacket Cooling System," Revision 3. November 4,1996
- 11. CCNPP Surveillance Test Procedure STP-O-SB 1, " Test of IB DG and 14.4KV Dus LOCA Sequencer," Revision 12, May 21,1997
! 2. CCNPP Surveillance Test Procedure STP O-88 2," Test of 2B DG and 4KV Bus 24 LOCA Sequencer," Revision i1, May 21,1997
- 13. CCNPP Surveillance Test Procedure STP O-8A 2," Test of 2A DG and 4KV Bus 21 LOCA Sequencer," Revision 12, May 21,1997
- 14. CCNPP Administrative Procedure MN-1-102," Preventive Maintenance Program," Revision 5, September 27,1996
- 15. Letter from Mr. R. W. Cooper 11 (NRC) to Mr. C.11. Cruse (BGE), dated May 31,1996, "Calvert Cliffs Plant Performance Review Results"
- 16. CCNPP MPM0ll25 Checklist Sheet," Remove Relief Valve, Test and Reinstall," Revision 0, December 23,1991
- 17. CCNPP MPM07006 Checklist Sheet," Disassemble, inspect and Overhaul LDG Check Valve,"
Revision 0, November 22,1994
- 18. CCNPP MPM13000 Checklist Sheet," Clean and Inspect EDG Air Start Distributor and Check Valves," Revision 0, October 3,1991
- 19. CCNPP MPM13002 Checklist Sheet," Inspect EDG Air Start Valves and Filters," Revision 0, February 5,1992 Application for License Renewal 5.8-31 Calvert Cliffs Nuclear Power Plant
o A'lTACIIMENT (2)
APPENDIX A - TECIINICAL INFORMATION 5.8 - EMERGENCY DIESEL GENERATOR SYSTEM __
- 20. CCNPP MPM07117 Checklist Sheet, " Inspect EDG Air intake Filters," Revision 0, July 14,1993
- 21. CCNPP MPM13110 Checklist Sheet, " Perform Visual Examination for EDG Exhaust Components," Revision 0, May 23,1995
- 22. CCNPP MPM13003 Checklist Sheet, " Clean / Inspect 2B Lube Oil "Y" Strainers and Baskets,"
Revision 0, November 12,1991
- 23. CCNPP MPM13004 Checklist Sheet, " Clean / Inspect IB Lube Oil "Y" Strainers," Revision 0, December 12,1991
- 24. CCNPP MPM13005 Checklist Sheet," Clean / Inspect 2A Lube Oil"Y" Strainers and Saskets,"
Revision 0, November 12,1991 Application for License Renewal 5.8-32 Calvert Cliffs Nuclear Power Plant
- . .. . . - . . .. . . = . - - . . .__. -.
l NITACIIMENT G) p 4
^
APPENDIX A - TECIINICAL INFORMATION 5.11C - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEM 1
Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant January 21,1998 c; . 4
I ATTACHMENT G)'
APPENDIX A'- TECHNICAL INFORMATION 5.11C - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS
- 5. llc Control Room and Diesel Generator Buildingsllenting, Ventilation, and Air Conditioning Systems This is a section of the Baltimore Gas and Electric Company (BGE) License Renewal Application (LRA) addressing the Control Room lleating, Ventilation, and Air Conditioning (1 VAC) System. This section also addresses the Diesel Generator Buildings' ilVAC System, which has similar equipment. The Control Room and Diesel Generator Buildings' HVAC Systems were evaluated in accordance with the Calvert Cliff Nuclear Power Plant (CCNPP) Integrated Plant Assessment (IPA) Methodology described in Section 2.0 of the BGE LRA. These sections are prepared independently and will, collectively, comprise the entire BGE LRA.
5.11C,1 Scoping System level scoping describes conceptual boundaries for plant systems and structures, develops screening tools which capture the 10 CFR 54.4(a) scoping criteria, and then applies the tools to identify systems and structures within the scope of license renewal. Component level scoping describes the components within the boundaries of those systems and structures that contribute to the intended functions. Scoping to dete mine components subject to aging management review (AMR) begins with a listing of passive intended functions and then dispositions the device types as either only associated with active functions, part of a complex assembly, or subject to AMR either in this report or another report.
t Representative historical operating experience pertinent to aging is included in appropriate areas, to provide insight supporting the agmg management demonstrations. This operating experience was obtained through key-word searches of BGiss electronic database ofinformation on the CCNPP dockets and through documented discussions with currently assigned cognizant CCSPP personnel.
Section 5.1IC.l.1 presents the results of the system level scoping; 5.11C.1.2 the results of the component level scoping; and 5.11C.I.3 the results of scoping to determine componeats subject to an AMR for the Control Room HVAC System. Section 5.11C.14 summarizes the results of the scoping and AMR process for the Diesel Generator Buildings' HVAC System.
5.11C.1.1 System Level Scoping This section begins with a description of the system, which includes the boundaries of the system as it was scoped. The intended functions of the system are listed and are used to define what portions of the system are within the scope oflicense renewal.
System Descriotion/Concentual Boundaries Although it is named for the Control Room, the Control Room IIVAC System provides ventilation to the Control Ro m, the Units I and 2 Cable Spreading Rooms, and the Units 1 and 2 Battery Rooms. The Control Room and Cable Spreading Rooms are supplied by a single, year-round air-conditioning system serving both Units 1 and 2. Air handling equipment and refrigeration units are redundant, but the ductwork is not. The Control Room and Cable Spreading Room areas have a third source of cooling, which is not safety related, in ;he form of a water chiller supplying a second set of coils in the safety-related air handling systems, if airborne contamination occurs at the fresh air intake, a self-contained recirculation system is automatically initiated through a post-loss-of-coolant accident tilter system. The Application for License Renewal 5.1 IC-1 Calvert Cliffs Nuclear Power Plant a
ATTACilMENT Q)
APPENP1X A - TECHNICAL INFORMATION
- 5. llc - CONTROL ROOM AND DIESEL GENERATOR BUILDI!1GS' HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS moup' Control Room air is then processed through high efficiency particulate air and charcoal filters.
[ Reference 1)
The air conditioning system is divided into three supply and return duct systems: one for each of the two Cable Spreading Rooms, and one for the Control Room. Each branch contains isolation dampers that are automatically closed if smoke is detected within the branch. The remaining branches continue to serve the other two zones without interruption. Smoke can be evacuated from the isolated zone by means of an auxiliary fan, motorized dampers, and an outside air intake [ Reference 2]
The llattery Rooms are separately ventdated, lleated and filtered air is supplied to the four Battery Rooms and the reserve 125V DC Dattery Room on the 27 foot and 45 foot levels of the Auxiliary lluilding, using one supply fan, one exhaust fan, a heating coil, roughing filter, and motor-operated dampers. Separate supply and exhaust fans are utilized to maintain a negative pressure in these rooms, with respect to the surrounding areas, to preclude the hydrogen concentration in the air from reaching the explosive limit. Upon loss of either fan, sufficient ventilation is provided by the remaining fan to prcJude the fosibility of hydrogen accumulation within the Battery Rooms. [ References I and 3]
System Intedges The Control Room HVAC System has an interface with the following systems and components:
(Reference 2]
- Main Exhaust Equipment Room;
- Auxiliary Building Ileating ard Ventilation Sysiem; and e Radiation Monitoring System System Sconing Results The Control Room IIVAC System is within the scope oflicense renewal based on 10 CFR 54.4(a). The following intended fuoetioris of the Control Room IIVAC System were determined based on the requirements of 654.4(a)(1) and (2), in accordance with the CCNPP IPA Methodology, Section 4.1.1:
[ Reference 4 Table 1]
- To provide llVAC to the Control Room, Cable Spreading Rooms, and Battery Rooms to ensure habitability during design basis events, limit Reactor Protective System / Engineered Safety Features Actuation System temperatures, and minimize hydrogen accumulation;
. To provide seismic integrity and/or protection of safety-related components;
- To maintain the pressure boundary of the system (liquid and/or gas); and
. To maintain electrical continuity and/or provide protection of the electrical system.
7 The following Control Room IIVAC System intended functions were determined based on the requirements of j54.4(a)(3): [ Reference 4, Table 1]
For fire protection (Q50.48):
- To provide Technical Support Center supply and exhaust ventilation duct isolation to confine or
- retard a fire from spreading to adjacent areas; and Application for License Renewal 5.1IC-2 Calvert Cliffs Nucicar Power Plant
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ATTACilMENT (3)
APPENDIX A - TECIINICAL INFORMATION
- 5. llc - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS e To detect smoke, maintain ventilation in unaffected zones, and remove smoke / supply fresh air to affected zones in the event of a fire in the Control Room or Cable Spreading Rooms.
All components of the Control Room IIVAC System that support the above functions, with the exception of the fire protection functions, are safo-related and Seismic Category I and are subject to the applicable loading conditions identified in the Updated Final Safety Analysis Report Section 5A.3.2 for Seismic Category I systems and equipment design. Portions of the system that are within the scope of license renewal only because of the fire protection functions are non safety-related and non seismic.
[ References 5 and 6] The ductwork is constructed of galvanized carbon steel, which conformed to the then current guide from the American Society of Ileating, Refrigeration, and Air Conditioning Engineers, it was installed in accordance with high velocity and low velocity duct construction standards from the Sheet Metal and Air Conditioning Contractors National Association. [ Reference 2, Attachments 4; Reference 7]
Operating Exneriencs Over 20 years of operating experience has shown that the heating and ventilation systems at CCNPP are highly reliable in maintaining their passive functions. Some cracking has been discovered in plant ilVAC ducting due to vibration-induced fatigue, llowever, these isolated failures were due to a combination of design and installation deficiencies. In one case, additional supports were added to the ducting to prevent recurrence in another case, the fans were balanced to minimize the vibration. Some loosening of fasteners has been experienced due to dynamic loading. Vibration-related aging concerns are minimized through system design and existing maintenance practices, which are further described below in the discussions on aging management. Vibration isolators, i.e., flexible collars, are installed around the fans to minimize the vibration being transferred to other equipment. [ Reference 2,
- Attachments 6] Furthermore, fans are monitored for vibration whenever the fan belts are retensioned or replaced. [ References 8 and 9]
1r.1980, a Control Room Air conditioning unit was placed out-of service to repair broken damper linkages. This failure was caused by excessive wear due to inadequate lubrication of the damper linkages. The existing preventive maintenance procedure was modified to include lubrication along with periodic visual inspection. [ Reference 10] During performance of these periodic inspections, elastomer degradation of the seals has also been identified. If the seals on jambs or blade edging lose their resiliency or are deteriorated, corrective actions are taken to have the seals replaced. [ Reference 11]
Corrosion has been discovered below the cooling coils in several of the plant ilVAC units. These areas have been reinspected in order to assess the corrosion rates and the adequacy of the system pressure boundary. Other than the limited amount of degradation experienced due to vibration, wear, and corrosion, no other significant aging concerns have been identified that could affect the ability of the Control Room IIVAC System components to perform their passive functions.
Application for License Renewal 5.1IC-3 Calvert Cliffs Nuclear Power Plant
l ATTACIIMENT (3)
APPENDIX A - TECllNICAL INFORMATION
- 5.11C'- CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS 5.11C.1.2 Component Level Scoping Based on the intended system functions listed above, the portions of the Control Room IIVAC System that are within the scope of license renewal include all safety related components in the system
- (electrical, mechanical, and instrument) and their supports. This includes the Control Room IIVAC units; the supply, exhaust, and recirculation portions of the Control Room IIVAC ducting, dampers, and filters; the safety related refrigeration units; and the Battery Room supply and exhaust fan, ducting, filter, and dampers. It does not include the non safety-related Control Room chillers and associated piping, pumps, valves and instrumentation. [ References 4,5, and 6)
Portions of the Control Room IIVAC System that are non safety-related and have only fire protection-related intended functions are also within the scope of license renewal. This includes the exhaust fan, supply and exhaust ducting, aad dampers associated with the smoke removal function and the smoke detectors for the Technical Support Center. [ References 4,5, and 6)
The following 44 device types in the Control Room IIVAC System were designated as within the scope of license renewal because they have at least 1 intended function: [ Reference 2, Section 2.2 and Table 2-1]
Device Device Device Description Device Description Type 1ype ACC Accumulator LG Level Gauge AE Analyzer Element M 480V Motor (Feed from Motor Control Center)
CKV Check Valve MB 480V Motor COIL Coil MD 125/250VDC Motor COMP Compressor MO Motor Operator CV Control Valve PCV Pressure Control Valve DAMP Damper PDI Pressure DifferentialIndicator DISC Disconnect Switch / Link Pi Pressure Indicator DRY Air Dryer PNL Panel DUCT llVAC Duct PO Piston Operator FAN Fan PS Pressure Switch FG Flow Gauge PY Pressure Corwener (Relay)
FL Filter RV ReliefValve FS Flow Switch RY Relay FU Fuse SV Solenoid Valve GD Gravity Damper TC Temperature Controller llS Handswitch TCV Temperature Control Valve llV lland Valve TS Temperature Switch IIX lleat Exchanger TT Temperature Transmitter llY Converter /Rc!ay XL Miscellaneous Indicating Lamp JD Tubing with Piping Code of ZL Position Indicator Lamp "JD" JL Power Lamp indicator ZS Position Switch Application for License Renewal 5.1 IC-4 Calvert Cliffs Nuclear Power Plant
ATTACIIMENT m APPENDIX A - TECIINICAL INFORMATION
- 5. llc - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' liEATING,
-VENTILATION. AND AIR CONDITIONING SYSTEMS Some components in the Control Room IIVAC System are common to many other plant systems and have been included in separate sections of the BGE LRA that address those components as commodities for the entire plant. These components include the following: [ Reference 2, Section 3.2)
- Structural supports for piping, cables, and components are evaluated for the effects of aging in the Component Supports Commodity Evaluation in Section 3.1 of BGE's LRA.
- Electrical control and power cabling are evaluated for the effects of aging in the Electrical Cables Commodity Evaluation in Section 6.1 of BGE's LRA.
- Process and instrument tubing and tubing supports are evaluated for the effects of aging in the Instrument Line Commodity Evaluation in Section 6.4 of BGE'c LRA.
5.11C.1.3 Components Subject to AMR This section describes the components within the Control Room IIVAC System that are subject to an AMR. It begins with a listing of passive intended functions and then dispositions the device types as either only associated with active f metions, part of a complex assembly, evaluated in other reports, evaluated in commodity reports, or remaining to be evaluated for aging management in this section.
Passive Intended Functions In accordance with CCNPP IPA Methodology Section 5.1, the following Control Room 11VAC System functions were determined to be passive: [ Reference 2, Table 3-1) e Maintain the pressure boundary of the system (liquid and/or gas);
e Detect smokr maintain ventilation in unaffected zones, and remove smoke / supply fresh air to affected zones m the event of a fire in the Control Room or Cable Spreading Rooms (includes only those device types that perform the function by requiring no motion or change of properties or configuration);
e Maintain electrical continuity and/or provide protection of the electrical system; and e Provide seismic integrity and/or protection of safety related components.
Device Tynes Subject to AMR Of the 44 device types within the scope oflicense renewal: [ Reference 2, Table 3-2; Reference 12]
- 17 device types have only active functions and do not require AMR: Coil, Control Valve, Fuse, lland Switch, Converter / Relay, Power Lamp indicator,480V Motor (Feed from Motor Control Center),480V Motur, 125/250VDC Motor, Motor Operator, Piston Operator, Pressure Converter (Relay), Relay, Temperature Controller, Miscellaneous Indicating Lamp, Position Indicator Lamp, and Position Switch.
- 4 devices types are evaluated in another section of this application:
> Panel and Disconnect Switch / Link are evaluated for the effects of aging in the Electrical Commodities Evaluation in Section 6.2 of BGE's LRA.
> Flow Switch and Pressure Differential Indicator are evaluated for the efTects of aging in the Instrument Line Commodity Evaluation in Section 6.4 of BGE's LRA.
Application for License Renewal 5.11C-5 Calvert Cliffs Nuclear Power Plant a'
ATTACIIMENT (3)
APPENDIX A - TECIINICAL INFORMATION
- 5. llc - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS
- 14 device types do not require a detailed evaluation of specinc aging mechanisms because they are considered part of a complex assembly whose only passive function is closely linked to active performance, as discussed below: Accumulator, Air Dryer, Compressor, Flew Gauge, Level Gauge, Pressure Indicator, Tubing with Piping Code of 3D, Pressure Switch, Temperature Switch, Check Valve, Pressure Control Valve, Relief Valve, Solenoid Valve, and Temperature Control Valve.
In accordance with the provisions of Section 6.1.1 of the CCNPP IPA Methodology, compor.ents that comprise the refrigeration units do not require a specific evaluation of age-related degradation mechanism (ARDM), because the detrimental effects of aging mechanisms can be observed by detrimental changes in the perfonnance characteristics or condition of refrigeration unit components if they are properly monitored. Therefore, by adequately monitoring these performance or condition characteristics, the effects of aging on the passive intended function are also adequately managed. The active functions are mo.iitored by: (1) operational requirements that must be satisfied for continued plant operation; (2) Maintenance Rule system performance monitoring; and (3) component-specific condition monitoring addressed under the CCNPP Maintenance Program. (Reference 2, Appendix B)
The 14 device types listed above are entirely included in faese complex assemblies. One other device type, i.e., fan, includes the air conditioning condenser fan that is part of these complex assemblies. Other fans in the system are included in the AMR presented herein.
Maintenance of the pressure boundary of the system is the only passive intended function associated with the Control Room IIVAC System not addressed by one of the commodity evaluations referred to above.
Therefore, only the pressure retaining function for the nine device types listed in Table 5. llc-1 is considered in this section of the BGE LRA. Unless otherwise annotated, all components of each listed device type are subject to AMR.
TABLE 5.11C-1 CONTROL ROOM IIVAC SYSTEM DEVICE TYPES REOUIRING AMR Analyzer Element Gravity Damper Damper lleat Exchanger ilVAC Duct lland Valve (1)
Fan Temperature Transmitter Filter (1) The hand valves that are part of the Control Room IIVAC System's refrigeration units are not evaluated herein because the aging is being adequately managed as specified in Section 6.1.1 of the CCNPP IPA Methodology.
5.11C.I.4 Diesel Generator F>ulldings' IIVAC System Scoping in 1995, two new diesel generators were placed into operation at CCNPP, These diesel generators are located in two separate buildings that are dedicated to housing these diesels. The Diesel Generator Buildings' ilVAC System provides ventilation, heating, and cooling for these building spaces. Due to the unique circumstances pertaining to these llVAC systems (i.e.,they have been placed into service approximately 20 years aller other similar llVAC systems at CCNPP, and they have a design life of Application for License Renewal 5.1IC-6 Calvert Cliffs Nuclear Power Plant
ATTAC1fMENT (3)
I APPENDIX A TECilNICAL INFORMATION 1 5.IIC - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' IIEATING, i VENTILATION, AND AIR CONDITIONING SYSTEMS 45 years), an Ah1R process separate and unique from that used for other plant systems and structures was used, Since aging of the existing Control Room IIVAC System equipment is some 20 years ahead of the aging of the Diesel Generator Buildings' ilVAC System equipment, and since this equipment is just at the beginning of its design life, aging management of the new equipment can be deferred and then be based on future results of aging management from similar equipment groups associated with the Control Room IIVAC System. [ Reference 13]
All passive intended functions of the Diesel Generator Buildings' IIVAC System are equivalent to the Control Room liVAC System's passive intended functions. Cominon attributes, like intended functions, component configuration, material, and service conditions, result in the conclusion that the efTects of aging for these components will be very similar between systems. De aging management programs for the Control Room IIVAC System will provide 20 years experience for application to the Diesel Generator Buildings' ilVAC System. Therefore, there are no new programs or modifications to existing programs needed to manage the aging of the Diesel Generator Buildings' IIVAC System.
5.11C.2 Aging Management A list of potential ARDMs identified for the Control Room IIVAC System components is given in I Table 5.1 IC-2. The plausible ARDMs are identified in the Table by a check mark (/) in the appropriate i device type column. A check mark indicates that the ARDM applies to at least one component for the !
device type listed. [ Reference 2, Table 4 2] For efficiency in presenting the results of the evaluations in i this section, ARDM/ device type combinations are grouped together where there are similar characteristics and the discussion is applicable to all components within that group with exceptions
)
noted, where appropriate. Table 5.11C-2 identifies the group in which each ARDM/ device type combination belongs. The following groups have been selected for the Control Room 11VAC System: I Group 1 - Includes crevice corrosion, general corrosion, microbiologically induced corrosion (MIC), ;
I and pitting for components potentially exposed to moisture.
Group 2 - includes elastomer degradation and wear for non-metallic duct and damper parta Group 3 - Includes dynamic loading for fans.
l The following is a discussion of the aging manayment demonstration process for each group identified above, it is presented by group and includes a discussion on materials and environment, aging mechanism effects, methods to manage aging, aging management program (s), and aging management demonstration.
Application for License Renewal 5.1 IC-7 Calvert Cliffs Nuclear Power Plant
A*ITACIIMENT Q)
APPENDIX A - TECilNICAL INFORMATION
- 5. llc - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS TABLE 5.11C-2 POTENTIAL AND PLAUSIBLE ARDh FOR TIIE CONTROL ROQM IIVAC SYSTEM Control Room flVAC System Device Types -
Plausible ARDMs ^L DAMP puci iAN IL GD llX llV TI Cavitation Erosion Corrosion Fatigue Creep / Shrinkage Crevice Corrosion '
4(1) 4(1) 4(1) 4(1) 4(1)
Dynamic Loading 4(3) ~
Elastomer Degradation 4(2) 4(2)
Erosion Corrosion Fatigue Fouling Galvanic Corrosion General Corrosion V(1) V(1) 4(1) 4(1) 4(1) liydrogen Damage Intergranular Attack Irradiation Embrittlement MIC 4(1) V(1)
Oxidation Particulate Wear Erosion Pitting 4(1) V(1) V(1) 4 (1) 4(1)
Radiation Damage Saline Water Attack Schetive Leaching Stress Corrosion Cracking Stress Relaxation Thermal Damage Thermal Embrittlement
' ^
Wear Y(2) 4(2) 4 - Indicates that the ARDM is plausible for component (s) within the device type
(#)- Indicates the group in which this device type /ARDM combination is evaluated Note: Not every component within the device types listed here may be susceptible to a given ARDM.
This is because components within a device type are not always fabricated from the same materials or subjected to the same environments. Exceptions for each device type will be indicated in the aging management section for each ARDM discussed in this reput.
~
Application foc License Renewal 5.1IC-8 Calveit Cliffs Nuclear Power Plant
AUACllMENT (3)
APPENDIX A - TECifNICAL INFORMATION 5.11C - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' ilEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS Group I (crevlee corresion, general corrosion, MIC, and pitting for components potentially esposed to moisture)- Materials and Environment Group 1 is comprised of components that are potentially exposed to moist air and condensation. The flow paths of concern include the outside air intakes for the Control Room, the outside air intake and exhaust for the Battery Rooms, and the outside air intake and exhaust for smoke removal. The ducts, dampers, fans,0lters, and heat exchangers that are located in these Dow paths are exposed to potentially moist air, which can cause corrosion of the steel materials. The Battery Room exhaust fan and heat exchangeru are subject to even wetter conditions since the fan is exposed to the weather and the Control Room coolers are exposed to condensation from the cooling coils. Both the Battery Room exhaust fan and the heat exchangers have drains to remove this moisture. Ilowever, the drains could become clogged and allow water to remain standing in the lower portions of the housings. If there is stagnant water, MIC may develop and contribute to local corrosive efTects. [ Reference 2, Attachments 6)
' The materials of construction orl each device type are as follows:
e damper . The Control Room outside air dampers and the Battery Room inlet air dampers have frames, shutters, and internals constructed of galvanized steel, axles of carbon steel, bearings of bronze, and seals of neoprene sponge material, The Control Room fresh air dampers and the smoke removal supply and exhaust dampers have their sleeve, Dange, stuffing box, axle, and blade constructed of carbon steel and the seals of a neoprene sponge material. [ Reference 2, Attachments 4]
e duct - The duct, Ottings, doors, and door hinges / latches are constructed of galvanized carbon steel. The joint angles are constructed of carbon steel, and the bolts and rivets are plated carbon steel. The ducting includes Dexible collars that are constructed of elastomer materials and secured to fans and ducts with galvanized sted bars. The supply and exhaust registers are constructed of either painted carbon steel or aluminum. [ Reference 2, Attachments 4]
. . fan - The Battery Room exhaust fan housing and supports are constructed of aluminum. The Battery Room supply fan and the Control Room supply fan housings and supports are constructed of carbon steel and are painted. All fan fasteners are constructed of carbon steel. The motors / fans do not perform a passive intended function. [ Reference 2, Attachments 4]
e- fdtcr - The Battery Room supply fan filter cabinets are constructea of galvanized carbon steel.
The Control Room cooling coil Glter housing is constructed of carbon steel and painted. The Diters and internals do not perform a passive intended function. [ Reference 2, Attachments 4) e heat exchanger - The Control Room cooling evaporator housing and supports are constructed of carbon steel and painted. The coils themselves have the system pressure boundary intended function; however, they do not require AMR because they are part of the refrigeration units and are considered a complex assembly, as discussed in Section 5 llc.13. [ Reference 2, Attachments 4]
The internal environment for the Control Room IIVAC System can be conditioned air, outside air, or air drawn from ventilated areas. The Control Room IIVAC System is designed to maintain the temperatures inside the Control Room and Cable Spreading Room at 75"F and 90'F, respectively, assuming the outdoor air temperature is 95'F. [ Reference 1, Table 9-18] The maximum normal relative humidity Application for License Renewal 5.1IC-9 Calvert Cliffs Nuclear Power Plant
ATTACHMENT G)
APPENDIX A - TECliNICAL INFORMATION 5.IIC - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS inside the Auxiliary Building areas is 70% [ Reference 14] Outdoor air reaches a relative humidity of up to 100%.
Most of the Control Room IIVAC equipment is located in ventilated areas indoors and, therefore, the external surfaces are not exposed to the nutside weather pr sunlight. De Auxiliary Building maximum area temperatures for normal operating conditions are ll0'F with a maximum relative humidity of 70%.
[ Reference 14] ne Battery Room exhaust fan and the exhaust register for the duct are located outdoors and, therefore, are exposed to the weather, Group I (crevice corrosion, general corrosion, MIC, and pitting for components potentially esposed to moisture). Aging Mechanism Effects Crevice corrosion is intense, localized corrosion within crevices or shielded areas, it is associated with a small volume of stagnant solution caused by holes, gasket surfaces, lap joints, crevices under bolt heads, surface deposits, designed crevices for attaching thermal sleeves to safe-ends, and integral weld backing rings or back up bars. The crevice must be wide enough to permit liquid entry and narrow enough to maintain stagnant conditions, typically a few thousandths of an inch or less Crevice corrosion is closely related to pitting corrosion and in many cases can initiate pits. [ Reference 2, Attachment 7s]
General corrosion is the thinning (wastage) of a metal by chemical attack (dissolu: ion) at the surface of the metal by an aggressive environment. General corrosion requires an aggressive environment and materials susceptible to that environment. The consequences of the damage are loss of load carrying cross sectional area. [ Reference 2, Attachment 7s]
Microbiologically-induced corrosion is accelerated corrosion of materials resulting from surface microbiological activity. Sulfate reducing bacteria, sulfur oxidizers, and iron oxidizing bacteria are most commonly associated with the corrosion efTects. Microbiologically induced corrosion most often results in pitting, followed by excessive deposition of corrosion products. Stagnant or low flow areas are most susceptible. Essentially all systems using untreated water and most commonly used materials are susceptible. Consequences range from leakage to excessive differential pressure and flow blockage.
Microbiologically-induced corrosion is generally observed in service water applications utilizing raw, untreated water. [ Reference 2, Attachment 7s]
Pitting is another form oflocalized attack with greater corrosion rates at some locations than at others.
Pitting can be very insidious and destructive, with sudden failures in high pressure applications (especially in tubes) occurring by perforation. This form of corrosion essentially produces holes of varying depth-to-diameter ratios in the steel. Deep pitting is more common with passive metals, such as -
austenitic stainless steels, than with non passive metals. Pits are generally elongated in the direction of gravity, in many cases, erosion corrosion, fretting corrosion, and crevice corrosion can also lead to pitting. [ Reference 2, Attachment 7s]-
For Group 1 components, there are two possible effects from long term exposure to the moist environment: a uniform corrosion of the exposed steel surfaces causing material thinning, and localized attack resulting in pits and cracks. Crevice corrosion, general corrosion, and pitting are plausible for the subcomponents constructed of carbon steel or galvanized carbon steel. Those items that are painted or galvanized are generally protected from the effects of corrosion; however, where the coating is damaged, Application for License Renewal 5.! !C-10 Calvert Cliffs Nuclear Power Plant i
ATTACHMFNT Q)
. APPENDIX A TECIINICAL INFORMATION 5,11C - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS corrosion may take place. He most likely loutions for corrosion is in crevices at duct joints and between support angles and sheet metal. Corrosion is not plausible for subcomponents constructed of aluminum, bronze, or neoprene sponge material because these materials are generally resistant to corrosion. The Battery Room exhaust fan and the Control Room cooling evaporator housing are also subject to MIC due to the potential for stagnant water, if corrosion, i.e., crevice corrosion, general corrosion, MIC, and pitting, were left unmanaged, it could eventually result in loss of the pressure-retaining capability under current licensing basis (CLB) design loading conditions. [ Reference 2, Attachment 6)
Group 1 (crevice corrosion, general corrosion, MIC, and pitting for components potentially exposed to moisture)- Methods to Manage Aging Mitigation: Since there are no design features for control of humidity, the only feasible method of preventing exposure of these components to a corrosive environment is to apply a protective coating to them. Those subcomponents without a protective coating, or where the c "ng has degraded, will potentially be exposed to moisture from condensation. The subcomponents s structed of carbon steel materials could be replaced with subcomponents constructed of more corrosion-resistant materials.
Discoverv: The etTects of crevice corrosion, general corrosion, MIC, and pitting on Group 1 components -
can be discovered and monitored through non destructive examination techniques, such as visual inspections. [ Reference 2, Attachment 8] Representative samples at susceptible locations can be used to assess the need for additional inspections at less susceptible locations.
Group 1 (crevice corrosion, general corIosion, MIC, and pitting for components potentially exposed to moisture). Aging Management Program (s)
Mitigation: Maintaining the protective coatings, as discussed below in Discovery, will help to mitigate corrosion of these components. No other mitigation techniques are deemed necessary at this time, so there are no mitigation programs credited for managing corrosion of Group I components.
Discoverv: For Group 1 components, crevice corrosion, general corrosion, and pitting can be readily detected through visual examination. Additionally, degradation of protective coatings, which help mitigate corrosion, can also be visually detected so that corrective actions can be taken to restore the coatings. An inspection program can provide the assurance needed to conclude that the etTects of corrosion are being e:Tectively managed for the period of extended operation. Routine system walkdowns would discover corrosion of the external surfaces of the Group I components. Periodic preventive maintenance would lead to the discovery of corrosioe on the internal surfaces of components that are readily observable during the activity, including the adjacent ductwork. Components not covered by periodic preventive maintenance will be included in a new Age Related Degradation inspection (ARDI) Program to accomplish the necessary inspections. The components to be included in the ARDI Program for corrosion include the battery room inlet dampers, fresh air intake dampers, battery room supply fans, and ducting. [ Reference 2, Attachment 8]
System Walkdowns Calvert Cliffs Administrative Procedure MN-1-319, " Structure and System Walkdowns," provides for discovery of general corrosion, and conditions that could allow corrosion to occur (e.g., degraded paint),
Application for License Renewal 5.1 IC-11 Calvert Cliffs Nuclear Power Plant
[ ATTACHMENT (3)
APPENDIX A - TECilNICAL INFORMATION 5.11C CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' IIEATING, VENTILATION AND AIR CONDITIONING SYSTEMS of the Control Room HVAC System components by performance of visual inspections during plant walkdowns. The purpose of the procedure is to provide direction for the perfomance of structure and system walkdowns and for the documentation of the walkdown results. [F.d: reno 15, Sections 1.1 and 1.2]
Under procedure MN 1-319, personnel with assigned responsibility for specific structures and systems perform periodic walkdowns. Walkdowns may also be performed as required for reasons such as material condition assessments; system reviews before, during, and after outages; start up reviews (i.e.,when a system is re-energized or placed in service); and as required for plant modifications.
[ Reference 15, Section 5.1]
One of the objectives of system walkdowns is to assess the condition of the CCNPP structures, systems, 1 and components such that any degraded condition will be identiDed, :locumented, and corrective actions take, before the degradation proceeds to failure of the structures, systems, and components to perform their intended functions. [ Reference 15, Sections 5.1.C, 5.2.A.1, and 5.2.A.5] The aisting procedure will be modified to include specific inspection items with respect to discovery oQhese ARDMs to help ensure they are being adequately managed. Conditions adverse to quality are documented and resolved by the Calvert Cliffs Corrective Actions Program.
Procedure MN 1-319 provides guidance for specific types of degradation or conditions to inspect foi when performing the walkdowns. Inspection items related to aging management include the following:
[ Reference 15, Section 5.2 and Attachments 1 through 13]
- Items reiated to specific ARDMs such as corrosion or vibration; e Effects that may have been caused by ARDMs such as damaged supports, concrete degradation, anchor bolt degradation, or leakage of Guids; and e Conditions that could allow progression of ARDMs such as degraded protective coatings, leakage of fluids, presence of standing water or accumulated moisture, or inadequate support of components (e.g., missing, detached, or loose fasteners and clamps).
System walkdowns promote familiarity with the systems by the responsible personnel and provides extended attention to plant material condition beyond that afforded by Operations and Maintenance alone. The structure and system walkdown procedure has been improved over time based on past experience to provide guidance on specific activities to be included in the scope of the walkdowns.
Preventive Maintenance Procram The CCNPP Preventive Maintenance Program has been established to maintain plant equipment, structures, systems, and components in a reliable condition for normal operation and emergency use, '
minimize equipment failure, and extend equipment and plant life. The program covers all preventive maintenance activities for nuclear power plant structures and equipment within the plant, including the Control Room liVAC System components within the scope of license renewal. Guidelines drawn from industry experience and utility best practices were used in the development and enhancement of this program. (Reference 16]
Application for License Renewal 5.11C-12 Calvert Cliffs Nuclear Power Plant
ATTACIIMENT (3) d APPENDIX A 'TECHNICA't INFORMATION 5.11C - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS Calvert Cliffs currently has a number of Preventive Maintenance Tasks to periodically perform maintenance and inspections on many of the Group I components. Rese activities include damper inspections, fan lubrications, and fan belt inspections, which are all currently scheduled to be performed every 24 weeks (the Control Room and Cable Spreading Room smoke removal damper inspections are currently scheduled to be performed every 44 months). It also includes fan refurbishment and inspection / cleaning of cooling coils, which are curremly scheduled every 48 weeks, and filter inspections, which are currently scheduled every 12 weeks. Each of these activities would lead to the discovery of corrosion for those components that are readily observable during the activity, including the adjacent ductwork. If unsatisfactory conditions are detected, corrective actions will be taken in accordance with the CCNPP Corrective Actions Program. [ References 8, 9, and 11; References 17 through 22]
He specific PM activities credited are listed in Table 5. llc-3. During past performance of these
- maintenance activities, corrosion has been discovered below the cooling coils in several of the HVAC units. These areas have been reinspected in order to assess the corrosion rates and adequacy of the system pressure boundary. Baltimore Gas and Electric Company is currently evaluating alternatives for addressing corrosion in the cooling coil housings.
Specific r(sponsibilities are assigned to BGE personnel for evaluating and upgrading the PM Program and for initiating program improvements based on system performance. Issue Reports are initiated accordmg to CCNPP Procedure QL 2100 to request changes to the program that could improve or correct plant reliability and performance. Changes to the PM Program that require issue Reports included changes to the PM task scope, frequency, process changes, results from operating experience reviews, as well as other types of changes. [ Reference 16, Section 5.1.A and SA]
The PM Program is subject to periodic intemal assessment. Intemal audits are performed to ensure that activities and procedures established to implement the requirements of 10 CFR Part 50, Appendix B, comply with BGE's overall Quality Assurance Program. These audits provide a comprehensive in6 pendent verification and evaluation of quality related activities and procedures. Audits of selectnd aspects of operational phase activities are performed with a frequency commensurate with their strength of performance and safety significance, and in such a manner as to assure that an audit of all safety-related functions is completed within a period of two years. An audit performed in 1997 of the CCNPP Maintenance Program (which includes the PM Program) concluded that the program is effectively implemented at CCNPP. No age-related degradation issues were identified. [ Reference 23, Section 10.18]
ARDI Progunn To monitor the effects of corrosion for internal surfaces of Group I components where periodic preventive maintenance is not performed, these components will be included within a new plant program to accomplish the needed inspections. The components to be included in the ARDI Program for .
corrosion include the battery room inlet dampers, fresh air intake dampers, battery rocm supply fans, and ducting. This program is considered an ARDI Program as defined in the CCNPP IPA Methodology presented in Section 2.0 of the BGE LRA.
Application for License Renewal 5.1IC-13 Calven Cliffs Nuclear Power Plant
ATTACilMEhiTJ)
APPENDIX A TECHNICAL INFORMATION 5.IIC - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS The elements of the ARDI Program will include:
- Determination of the examination sample size based on plausible aging effects;
- Identification of inspection locations in the system / component based on plausible aging effects and consequences ofloss of component intended function;
- Determination of examination techniques (including acceptance criteria) that would be effective, considering the aging effects for which the component is examined; e Methods for interpretation of examination results; e Methods for resolution of unacceptable examination findings, including consideration of all design loads required by the current licensing basis (CLB), an<l specification of required corrective actions; and
. Evaluation of the need for follow-up examinations to monitor the progression of any age-related degradation.
Corrective actions will be taken, as necessary, in accordance with the CCNPP Corrective Actions Program and will ensure that the components will remain capable of performing the system pressure boundary integrity function under all CLB conditions.
Group 1 (crevice corrosion, general corr = ton, MIC, and pitting for components potentially exposed to moisture)- Demonstration of AWg Management Based on the factors presented above, the following conclusions can be reached with respect to crevice corrosion, general corrosion, MIC, and pitting of components potentially exposed to moisture:
- The Group I components provide a system pressure-retaining boundary function and their integrity must be maintained under all CLB conditions.
- Crevice corrosion, general corrosion, and pitting are plausible for the components that are potentially exposed to moist air. Microbiologically-induced corrosion is plausible for the Battery Room exhaust fan and the Control Room IIVAC cooling coils due to the potential for stagnant water to collect in the housings. These corrosion mechanisms result in material loss which, iflen unmanaged, can lead to loss of pressure-retaining boundary integrity.
- Visual inspections will continue to be performed in accordance with a modified MN-1-319 to help ensure that these ARDMs are being adequately managed. Signs of degraded paint on galvanized surfaces, of external corrosion, or of internal corrosion that resulted in holes in a duct or cooler housing would be detected during these walkdowns. If unsatisfactory conditions are detected, corrective actions wi!! be taken in accordance with the CCNPP Corrective Actions Program.
- Existing routine preventive maintenance activities will continue to be performed on many of the Group I components. Perfornance of these activities will allow for discovery of corrosion in accessible intemal surfaces, it cluding the adjacent ductwork.
- Components that do not havt routine maintenance will be included in the scope of an ARDI Program to -provide the neco:d -inspections of the internal surfaces. Inspections will be
- performed, and appropriate corrective action will be taken if significant corrosion is discovered.
Application for License Renewal 5.1IC-14 Calvert Cliffs Nuclear Power Plant n=
g
ATTACHMENT (3)
- APPENDIX A - TECHNICAL INFORMATION 5.11C - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS Therefore, there is reasonable assurance that the effects ot'cre vice corrosion, geratal corrosion, MlO, and pitting on Group I components will be m:naged in such a way as to maintain the components' pressure boundary intepity, consistent with the CLB, during the period of extended opnation.
Group 2 (elastomer degradation and wear for non-metallie act and damper parts)- Materials and Environment The Control Room IIVAC System galvanized carbon steel ducting was installed with flexible emlars in connections between fans and ducts or ceings to prevent excessive movements of long duts. These flexible collars are constructed of clastomers and are installed with sufficient slack to prevent transmission of vibration Collars are secured to fans and ducts with galvanized steel bars fastened with boltr, for an air-tight construction. Some of the Control Room IIVAC System dampers au required to maintain system pressure boundary while in the closed position, and they are ;onstructed with compressible seals to provide leak tightness. These seals are constructed of neoprene spcnge material, which is an clastomer. [ Reference 2, Attachment 4s; Reference 7]
Refer to the Group i discussion on Materials and Environment for a discussion of the internal and external environments for the Control Room IIVAC System Group 2 components.
Group 2 (clastomer degradation and wear for non-metallic duct and damper parts) - Aging Mechanism Effects 1 An elastomer is a material that can be stretched to significantly greater than original length and, upon release of the stress, will return with force to approximately its original length, When an clastomer ages, there are three mechanisms primarily involved:
- Scission - the process of breaking molecular bonds, typically due to ozone attack, ultraviolet light, or radiation; a Crosslinking - the process of creating molecular bonds between adjacent long-chain molecules, typically due to oxygen attack, heat, or curing; and
+ Compound ingredient evaporation, teaching, mutation, etc.
Measurable properties that change include hardness, modulus, elongation, tensile strength, and compression strength. Elastomers generally harden as they age, making sealing more difficult.
[ Reference 2, Attachment 7s]
o Wear results from relative motion between two surfaces (adhesive wear); from the influence of hard, abrasive particles (abrasive wear), or fluid stream (erosion); and from small, vibratory or sliding motions
.under the influence of a corrosive environment (fretting). Motions may be linear, circular, or vibratory in inert or corrosive environments. Fretting is a wear phenomenon that occurs between tight-fitting surfaces subjected to a cyclic, relative motion of extremely small amplitude. Common sites for fretting are in joints that are bolted, keyed, pinned, press fit, or riveted; in oscillating bearings, couplings, spindles, and seals; in t xss fits on shafts; and in universaljoints. [ Reference 2, Attachment 7s]
Application for License Renewal 5.11C-15 Calvert Cliffs Nuclear Power Plant
ATTACHMENT 0)
APPENDIX A - TECilNICAL INFORMATION 5.11C - CONTMOL ROOM AND DIESEL GENERATOR BUILDINGS' HEATING, VENTILATION, AND A1R CONDITIONING SYSTEMS l
Elastomer degradation and wear are plausible for the flexible collars since the elastomers will degrade at j the joints in the llVAC equipment due to the relative motion caused by vibrating equipment, pressure l variations, and turbulence; and exposure to temperature changes and oxygen. These stressors will result in es entual tearing of the collars. Elastomer degrariation and wear are plausible for the damper seals due j
to relative motion between the blade and sleeve during daminr operation, and exposure to temperature j changes and oxygen. These stressors will result in eventual breakdown cf the seal. [ Reference 2, Attachment 6s] Ifleft unmanaged, elastomer degradation and wear could eventually result in the loss of pressure boundary integrity of the duct flexible collars and damper seals under CLD design loading conditions.
Group 2 (elastomer degradation and wear for non-metallic duct and damper parts)- Methods to Manage Aging Mitigation: . Elastomer degradation can be mitigated by utilizing materials that are less susceptible to heat and oxygen. Wear can be mitigated by minimizing vibration of the duct and dampers and by minimizing operation of the dampers to slow degradation of the seating surfaces, which leads to a loss of leak tightness.
Discoverv: Periodic visual ir,spections can be performed for the equipment in Group 2 to detect the effects of clastomer degradation imd wear. Degradation of the flexible collars can be detected through periodic system walkdowns because the collars are readily accessible. Degradation of damper seals can be detected through periodic inspections and walkdowns. If significant degradation is discovered, the flexible collars or damper seals can be repaired or replaced as appropriate. [ Reference 2, Attachment 8]
Another method to discover the effects of clastomer degradation and wear would be to perform periodic inleakage testing of the system. An increase in system inleakage may be caused by worn damper seals or torn Dexible collars and would be an alert condition that would trigger investigations as to the location and cause of the increased inleakage.
Group 2 (ei stomer degradation and wear for non-metallic duct and damper parts) - Aging Management Program (s)
Mitigation; The system was designed to minimize vibrations by using equipment support isolators and equipment-to-duct isolators, such as the flexible collars. Changes to materials or to system operating practices are not deemed necessary to mitigate the effects of this ARDM because the discovery methods discussed below are adequate methods to manage aging. Since there are no additional methods of mitigating elastomer degradation and wear, there are no programs credited with mitigating the aging
- effects due to these ARDMs. [ Reference 2, Attachment 6s and 8]
Discovery: Elastomer degradation and wear can be readily detected for Group 2 components through visual examination. An inspection program can.orovide the assurance needed to conclude that the effects of plausible aging are being effectively managed for the period of extended operation. Routine system walkdowns would discover the effects of these ARDMs on the external surfaces of the Group 2 components. Periodic preventive maintenance would lead to the discovery of the effects of these ARDMs on the internal surfaces of components that are readily observable during the activity.
Components not covered by periodic preventive maintenance will be included in a new ARD1 Program to accomplish the necessary inspections, ne components currently included in the ARDI Program for Application for License Renewal 5.11C-16 Calvert Cliffs Nuclear Pcwer Plant '
ATTACHMENT b)
APPENDIX A - TECHMCAL INFORMATION 5,IIC - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' IiEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS clastomer degradation and wear include the return air exhaust dampers, battery room inlet dampers, and the fresh air intake dampers. [ Reference 2, Attachment 8]
System Walkdowns ,
Routine inspections are performed on system components in accordan:e with CCNPP Administrative Procedure MN 1319. These walkdowns provide for discovery and management of the efTects of clastomer degradation and wear through visual inspections, reporting the walkdown results, and initiating corrective action. Under this procedure, inspection items typically related to aging management include identifying poor housekeeping conditions, such as degraded paint, and identifying system and equipment stress or abuse, such as excessive vibrations, bent or broken component supports, etc. Signs of cracking or tearing of duct flexible collars would be detected during these walkdowns. The accessible external surfaces of the subject equipment are monitored and conditions identified as adverse to quality are corrected in accordance with the CCNPP Corrective Actions Program. [ Reference 15] The existing procedure will be modified to include specific inspection items with respect to discovery of these ARDMs to helt er.sure they are being adequately managed. Refer to the discussion on Aging Management Programs for Group 1 for a detailed description of MN-1 319.
heventive Maintenance Program The CCNPP Preventive Maintenance Program has been established to maintain plant equipment, structures, systems, and components in a reliable condition for normal operation and emergency use, minimize equipment failure, and extend equipment and plant life. Calvert Cliffs currently has a Preventive Maintenance Task to periodically perfarm inspections of the outside air supply dampers for the Control Room and Battery Rooms. This task, which is scheduled to be performed every 24 weeks, requires that the accessible damper, operator, and attachments be visually inspected and that the damper be stroked and visually inspected again. Damper linkage pivot points are also lubricated. The visual inspection specifically includes verification that seals on jambs and blade edging is resilient and not deteriorated. [ Reference 11] This inspection would discover if significant elastomer degradation and wear is occurring to the damper seals. During past performance of these periodic inspections, degradation of the seals had been identified. Corrective actions were taken to have the seals replaced.
Refer to the discussion on Aging Management Programs for Group 1 for a detailed description of the Preventive Maintenance Program.
ARDI Program To provide the needed inspections for the internale of Group 2 dampers that are not subject to routine maintenance, an inspection of the internals of those dampers will be accomplished as part of an ARDI Program, as defined in the CCNPP IPA Methodology presented in Section 2.0. The components currently included in the ARDI Program for elastomer degradation and wear include the return air exhaust dampers, battery room inlet dampers, and the fresh air intake rhmpers. Corrective actions will be taken in accordance with the CCNPP Corrective Actions Program and will ensure that the components will remain capable of performing their pressure boundary integrity function under all CLB conditions.
Refer to the Group 1 discussion on aging management programs for a detailed discussion of the ARDI
' Program.
Application for License Renewal 5. llc-17 Calvert Cliffs Nuclear Power Plant
A*ITACllMENT (3)
APPENDIX A - TECliNICAL INFORMATION
- 5. llc - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS Group 2 (elastomer degradation and wear for non-metallie duct and damper parts) -
Demonstration of Aging Management Based on the factors presented above, the following conclusions can be reached with respect to elastomer degradation and wear for duct flexible collars and damper scals:
- Control Room liVAC System ducts and dampers provide a system pressure-retaining boundary function and their integrity must be maintained under CLB design conditions.
- Elastomer degradation and wear are plausible for the flexible collars due to the relative motion between vibrating equipment, pressure variations, and turbulence; and exposure to temperature changes and oxygen. Elastomer degradation snd wear are plausible for the seals due to relative motion between the blade and sleeve during damper operation and exposure to temperature changes and oxygen.
. if left umranaged, clastomer degradation and wear can result in material loss, tearing, or cracking, which could lead to loss of pressure-retaining boundary integrity, e Visual inspections will continue to be performed in accordance with a modified MN-1-319 to help ensure that these ARDMs are being adequately managed. Signs of cracking or tearing of duct collars would be detected during these walkdowns, as well as such conditions as unusual noises, leaks, or vibrations, if unsatisfactory conditions are detected, corrective actions are taken in accordance with the CCNPP Corrective Actions Program.
- An existing routine preventive maintenance activity to periodically inspect the outside air supply damper seals will continue to be conducted as part of the Preventive Maintenance Program. If unsatisfactory conditions are detected, corrective actions will be taken in accordance with the CCNPP Corrective Actions Program.
- To provide the needed inspections for the internals of Group 2 dampers that are not subject to routine maintenance, they will be included in the scope of an ARDI Program, inspections will be performed, and appropriate corrective action will be taken if significant degradation of the damper seals is discovered.
Therefore, there is reasonable assurance that the effects of clastomer degradation and wear for duct flexible collars and damper seals will be managed in such a way as to maintain the components' pressure boundary integrity, consistent with the CLB, during the period of extended operation.
Group 3 (dynamic loading for fans) . Materials and Environment Gmup 3 is comprised of fans because the rotating equipment can cause vibrations that can lead to dynamic loading concerns for fasteners. Normal bearing wear and dirt buildup cause imbalances in the rotating p.trts of the fans, thereby creating vibrations. Flexible collars are installed on the fans to provide dynamic kolation for adjacent components, which minimizes the dynamic loading for those components.
The internal and externsi environments of the fans are discussed above in the Materials and Environment section for Group 1 [ Reference 2, Attachment 7s]
The Battery Room exhaust fan housing and supports are constructed of aluminum. The Battery Room supply fan, Control Room supply fan, Control Room return fan, and the post-loss-of-coolant accident
. filter fan housings and supports are constructed of carbon steel, and some are painted. All fan fasteners
- Application fer License Renewal 5.11C-18 Calvert Cliffs Nuclear Power Plant
ATTACHMENT m
- APPENDIX A - TECHNICAL INFORMATION
- 5. llc - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS i
are constre;ted of carbon steel. The motors / fans do not perform a passive intended function.
[ Reference 2, Attachments 4] !
l Group 3 (dynamic leading for fans) . Aging Mechanism Effects Dynamic loadings (vibrations) are created at blowers by rotating parts with imbalances due to dirt buildup and normal bearing wear. There is a history of loosened mechanical fasteners due to vibration in fans at CCNPP. His mechanism is plausible for the fans, but is not considered plausible for adjacent ilVAC equ pment due to the dynamic isolation provided by flexible collars. If dynamic loading was left unmanaged, it could result in the loss of pressure boundary integrity of the Group 3 components under l CLB design loading conditions. [ Reference 2, Attachments 5 and 6] l l
1 Group 3 (dynamic loading for fans) . Methods to Manage Aging Mitigation: Dynamic loading can be mitigated by minimizing the mechanical loading due to vibration. )
De system is designed to minimize vibration by using equipment support isolators and equipment-to-duct isolators, such as flexible colors. Visual inspections through system walkdowns would provide for detection of vibration so that corrective actions could be taken to minimize vibration and, thereby, I mitigate the effects of dynamic loading. [ Reference 2, Attachment 8] l Discoverv: The effects of dynamic loading, e.g., loosened fasteners, can be detected through visual 1 inspections. Periodic visual inspections through system walkdowns would provide for detection of the effects of dynamic loading, as well as vibration problems, which can cause this ARDM to occur.
[ Reference 2, Attachment 8]
Group 3 (dynamic loading for fans) . Aging Management Program (s)
Mitigation: Routine system walkdowns provide for periodic visual inspections of the external surfaces of Control Room IIVAC System components. During these walkdowns, any vibration problems would be detected so that corrective actions can be taken to minimize the vibration. [ Reference 2, Attachment 8] Refer to the discussions below in Discovery for a description of the walkdown activities relied on for managing dynamic loading.
Discoverv: Routine inspections are performed on system components in accordance with MN-1-319.
The walkdowns provide for discovery of the effects of dynamic loading. e.g., loosened fasteners, as well as abnormal or excessive vibration, which can cause this ARDM to occur. Administrative Procedure MN-1-319 requires routine system walkdowns that include visual inspections, reporting the walkdown results, and initiating corrective action. Under this program, inspection items typically related to aging management include identifying unusual noises and identifying system and equipment stress or abuse, such as excessive vibrations, bent or broken component suppons, etc. Signs ofloosened fasteners would
- be discovered during these walkdowns. The corrective actions required as a result of the system walkdowns will be taken in accordance with the CCNPP Corrective Actions Program, and will ensure that the fans will remain capable of performing the system pressure boundary integrity function under all CLD conditions; [ Reference 15] The existing procedure will be modified to include specific inspection items with respect to discovery of these ARDMs to help ensure they are being adequately managed.
Application for License Renewal - 5.11C-19 Calvert Cliffs Nuclear Power Plant
ATTACHMENT 0)
APPENDIX A - TECilNICAL INFORMATION 5, llc - CONTROL ROOM AND DIESEL GENERATOR HUILDINGS' ilEATING.
VENTILATION, AND AIR CONDITIONING SYSTEMS Refer to the discussion above in Group 1 under Aging Management Programs for a detailed discussion of MN t 319.
Group 3 (dynamic loading for fans)- Demonstration of Aging Management ,
Based on the factors presented above, the following conclusions can be reached with respect to dynamic loading for fans:
- Control Room IIVAC System fans provide a system pressure-retaining boundary function and their integrity must be maintained under CLB design conditions, e Dynamic loading is a plausible ARDM for the fans due to excessive vibration resulting from fan operation.
e if left unmanaged, dynamic loading can result in loosened fasteners, which could lead to loss of presst.ic-retaining boundary integrity.
- Visual inspections will continue to be performed in accordance with a modified MN-l-319 to help ensure that these ARDMs are being adequately managed. Signs ofloosened fasteners on the fans would be detected during these walkdowns, as well as such conditions as unusual noises or vibrations, so that corrective actions can be taken to mitigate this ARDM.
Therefore, there is reasonable assurance that the effects of dynamic loading for fans will be managed in such a way as to maintain the components' pressure bounda y integrity, consistent with the CLB, during the period of extended operation.
5.11C.3 Conclusion The programs discussed for the Control Room IIVAC System are listed in Table 5. llc-3. These programs are (and will be for new programs) administratively controlled by a formal review and approval process. As has been demonstrated in the above section, these programs will manage the aging mechanisms and their effects such that the intended functions of the components of the Control Room IIVAC System will be maintained, consistent with the CLB, during the period of extended operation.
For the Diesel Generator Buildings' ilVAC System equipment, aging management of the new equipment can be deferred and then be based on future results of aging management from similar equipment groups associated with the Control Room IIVAC System, since aging of the existing Control Room IIVAC System equipment is some 20 years ahead of this equipment, and sir.ce this equipment is just at the beginning of its design life. Therefore, there are no new programs or modifications to existing programs needed to manage the aging of the Diesel Generator Buildings' ilVAC System.
The analysis / assessment, corrective action, and confirmation / documentation process for license renewal is in accordance with QL-2, " Corrective Actions Program." QL-2 is pursuant to 10 CFR Part 50, Appendix B, and covers all structures and components subject to AMR.
Application for License Renewal 5.1 IC-20 Calvert Cliffs Nuclear Power Plant
ATTACilMENT (3)
APPENDIX A - TECIINICAL INFORMATION
- 5. llc - CONTROL ROOM .AND DIESEL GENERATOR BUILDINGS' IIEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS Table 5.11C-3 LIST OF AGING MANAGEMENI' PROGRAMS FOR TIIE CONTROL ROOM IIVAC SYSTEM Program Credited As Existing CCNPP M. intenance Program
- Preventive Maintenance
- Discovery and management of the effects of Checklists MPM09109, crevice corrosion, general corrosion, MIC, and MPM09000, MPM04169, pitting for internal surfaces of components MPM09021, MPM09115, potentially exposed to moisture. (Group 1)
MPM09132, MPM07111, MPM09022, and EPM 30700
- Preventive Maintenance Checklist
- Discovery and management of the efTects of MPM09021 elastomer degradation and wear for damper seals. (Group 2)
Modified CCNPP Administrative Procedure
- Discovery and management of the etTects of MN 1-319, " Structure and System crevice corrosion, general corrosion, MIC, and Walkdowns" pitting for external surfaces of components p tentially exposed to meisture. (Group 1)
Existing procedure will be modified to include specific items with respect to . Discovery and management of the effects of discovery of these ARDMs to help elastomer degradation and wear for duct flexible ensure each plausible ARDM is being collars. (Group 2) adequately managed.
- Discovery and management of the effects of dynamic loading for fans. (Group 3)
New ARDI Program (new)
- Discovery and management of the effects of crevice corrosion, general corrosion, MIC, and pitting for internal surfaces of components potentially exposed to moisture and that are not subject to routine maintenance. (Group 1)
Discovery and management of the effects of elastomer degradation and wear for the seals of dampers that are not subject to routine maintenance. (Group 2)
Application for License Renewal 5.1IC-21 Calvert Cliffs Nuclear Power Plant
ATTACHMENT G)
APPENDIX A - TECilNICAL INFORMATION 5.11C - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' HEATING,
{NTILATION, AND AIR CONDITIONING SY3TEMS 5.11C.4 References
- 1. "CCNPP Updated Final Safety Analysis Report," Revision 21
- 2. "CCNPP Control Room HVAC System Aging Management Review Report," Revision 1, March 1997
- 3. CCNPP " System Level Screening Results," Revision 4, April 6,1995
- 4. CCNPP Report," Component Level Screening Results for the Control Room IIVAC System, System No. 030," Revision 1, July 1, if 96
- 5. BGE Drawing No. 60723S11004, " Ventilation Systems: Control Room and Cable Spreading Room 11VAC," Revision 34, August 14,1996
Revision 4, Augast 27,1996
- 7. CCNPP Specification No. 6730-M-196-A, " Specification for Heating, Ventilating, and Air Conditioning Ducts," Revision 2, May 29,1974
- 8. CCNPP Preventive Maintenance Checklist MPM09109, " Inspect / Replace Belts for Control Room HVAC Unit Fan Coil"
- 9. CCNPP Preventive Maintenance Checklist MPM09000," Inspect Belt (s) and Sheaves"
- 10. Letter from Mr. L. B. Russell (BGE) to Mr. B.11. Grier (NkC), dated July 18,1980, " Thirty-Day Report for Licensee Event Report 80-29/3L" I 1. CCNPP Preventive Maintenance Checklist MPM09021, " Control Room HVAC Damper Inspection"
- 12. CCNPP Report, " Component Pre-Evaluation for the Control Room IIVAC System (030),"
Revision 1, January 31,1997
- 13. "CCNPP Diesel Generator Buildings HVAC System Aging Management Review Report,"
Revision 0, April 4,1997
- 14. CCNPP Engineering Standard ES-014, " Summary of Ambient Environmental Service Conditions," Revision 0, November 8,1995
- 15. CCNPP Administrative Procedure MN-1-319," Structure and System Walkdowns," Revision 0, September 16,1997
- 16. CCNPP Administrative Procedure MN-1-102," Preventive Maintenance Program," Revision 5, September 27,1996
- 17. CCNPP Preventive Maintenance Checklist MPM04169, " Inspect Filter /Lubrieste Battery Room Supply Fan / Motor"
- 18. CCNPP Preventive Maintenance Checklist MPM09115," Lubricate Control Room HVAC Unit Fan and Motor Bearings"
- 19. CCNPP Preventive Maintenance Checklist MPM09132," Inspect / Clean Control Room HVAC Evaporator Coils" Application for Licen<e Renewal 5.1IC-22 Calvert Cliffs Nuclear Power Plant 1
ATTACIIMENIJ)
APPENDIX A - TECllNICAL INFORMATION 5.11C - CONTROL ROOM AND DIESEL GENERATOR BUILDINGS' HEATING, VENTILATION, AND AIR CONDITIONING SYSTEMS
- 20. CCNPP Preventive Maintenance Checklist MPM07111, " Inspect / Replace Filters for Control Room }{VAC Unit Fan Coil"
- 21. CCNPP Preventive Maintenance Checklist EPM 30700," Control Room and Cable Spreading Room Smoke Removal Damper and MCC Breaker Inspection"
- 22. CCNPP Preventive Maintenance Checklist MPM09022," Air liandling Unit Refurbishment of No.11 and No.12 Control Room Air Conditioning Unit"
- 23. DGE " Quality Assurance Policy for the Calven Cliffs Nuclear Power Plant," Revisics 48, March 28,1997 Application for License Renewal 5.11C-23 Calvert Cliffs Nuclear Power Plant
NITACllM_ENT (4) i i
b APPENDIX A - TECilNICAL INFORMATION 6.4 - INSTRUMENT LINES E
Baltimore Gas and Electric Company Calvert Clins Nuclear Power Plant Janvary 21,1998 ,
ATrAcilMENT (()
APPENDIX A TECHNICAL INFORMATION 6.4 INSTRUMENT LINES 6.$ instrument Lines lhls is a section of the Haltimore Gas and Electric Company (1106) License Renewal Applicatlon (LRA), addressing instrument lines, instrument lines have been evaluated as a " commodity" in accordance with the Calvert Cliffs Nuclear Power Plant (CCNPP) Integrated Plant Assessment (IPA)
Methodology described in Seetion 2.0 of the DGE LRA. 'Ihese sections are prepared independently and will, collectively, comprise the entire LRA.
6.4.1 Scoping 6.4.1,1 Instrument Lines Commodity Scoping For the purposes of this commodity evaluation, an " instrument line" is generally defined as the components loceed downstream of the process root valve. The " root valve" is the first hand valve off of the main process line or vessel. The root valve provides a point ofisolation between the process and the
'nstrument that senses the process. Sometimes piping class considerations require that two root valves be utillied in series to provide double isolation. In such cases, the instrument line begins at the exit of the valve most removed from the process. Iloth root valves and the connecting piping, fittings, draln/ vent vahes, etc., between the root valves, are considered part of the process line. [ Reference 1, Section 2.3.1.a and Figure 8 F3]
An instrument line may include the following components: [ Reference 2, Section 5.3.2]
e Small bore piping (i.e.,2 inch diameter and smaller), tubing, and fittings from the root valve to the instrument; e Iknd valves that are part of the instrument lines (e.g., transmitter equalization, vent, drain, and isolation valves); and e Any other components associated with the instrument line that contribute substantially to snalntaining the pressure-retaining boundary function of the instrument line (e.g., connected instruments and supports for the small bore piping and tubing).
For clarification purposes, an " instrument line" could include tubing and small bore piping that is required for operation of system components (e.g., compressed air lines to air operated valves) as well as lines for monitoring of the process conditions (e.g., tubing to a pressure indicator).
Instrument lines (i.e.,small bore piping, tubing, fittings, valves, and connected instruments) were originally excluded from the CCNPP IPA on the basis that manual actuation of root isolation valves could be credited for maintenance of the system pressure boundary in the event of leakage from an instrument line. Subsequent to the development of this approach, the final version of 10 CFR Part 54 was issued.Section V.3 of the Statemena of Consideration for the final License Renewal Rule state that it is not appropriate to generically credit operator action (e.g., manual component isolation), exclusively as 4dequate aging management for portions of systems that would otherwise require an aging management review (AMR). Therefore,13GE added instrument lines to the IPA as components to be evaluated for AMR. [ Reference 3, Section 1.0]
Instrument lines are associated with most plant systems. They perform the same passive function (i.e., maintenance of the system pressure boundary) and are constructed of the same basic materials regardless of the system with which they are associated. For these reasons, it was determined that a Application for License Renewal 6.41 Calvert Cliffs Nuclear Power Plan 7
A'ITACllMENT (4) c APPENDIX A TECilNICAL INFORMATION 6.4 - INSTRUMENT LINES M'
commodity evaluation approach would be more efficient than evaluating the instrument lines as part of l each system AMR. [Rcference 2 Sections 5.3.2 and 7.1.2)
Conceptual Boundwigg As discussed in Section 5.0 of the CCNPP IPA Methodology, system components are assigned to the scope of the instrument lines commodity evaluation during the system pre-evaluation process, he system pre evaluation includes steps to determine which instrument lines in the system pressure boundary are isolable from the rest of the system pressure boundary using installed root valves. Isolable instrument lines that are connected to portions of the system that perform the pressure boundary passive intended function are assigned to the scope of the instrument Lines Commodity Evaluation (ILCE).
Since some of the small bore piping and tubing do not have equipment number identifiers in the CCNPP equipment database, the pre evaluation identifies the root valves and all the components within the isolable instrumet.t lines (e.g., instrumtnts, instrutnent hand valves) as a means to identify the instrument lines that are in scope for the ILCE. De root valves are normally included within the scope of the system evaluation and not within the scope of the ILCE. [Refe ence 4, Section 5.2.B.10]
Dere are also some instrument lines that do not heve root valves. Therefore, the system pre-evaluation includes steps to identify any pressure transmitters, pressurt indicators, pressure differential transmitters, or similar instruments that have a pressure boundary passive function but are not included within an t
isolable instrument line. For these instruments, the pre evaluation determines whether the instrument and its associated components (e.g., tubing, instrument valves) should be included in the ILCE or remain in the system evaluation. [ Reference 4, Section 5.2.C.1)
Supports for tubing are also included in the ILCE. Supports for small bore piping and for the instruments connected to the instrument lines are included in the Cormanent Supports Commodity Evaluation in Section 3.1 of the BGE LRA. Instrument line supports interface with the structure to which they are attached (e.g., wall). At this interface, if anchor bolts are used, there is an overlap between the evaluations of site structures in Sections 3.3A through 3.3E of the BGE LRA and in the ILCE, The systems for which the pre evaluation process identified instrument lines within the scope of the ILCE are shown in Table 6.41. The CCNPP system numbers and the applicable DGE LRA sections for
, the systems are also shown in the table. [ Reference 3 Section 3.0)
Based on the abom the scope of the ILCE generally inclades the instrument lines and associated components (i.e., small bore piping, tubing, tubing supports, fittings, valves, and connected instruments) for the systems shown in Table 6.41. Ilowever, some of the valves and connected instruments may be scoped in the respective system evaluation. For example, the Nuclear Steam Supply System Sampling evaluation i;.ch:d:: the instrument line valves and instruments. Only the Nuclear Steam Supply System Sampling small bore piping and tubing are included in the ILCE. De specific boundaries for each system with the ILCE can be found in the Scoping section of each of the DGE LRA sections referenced in Table 6.4-1.
Application for License Renew 6.42 Calvert Cliffs Nuclear Power Plant
I ATTAClLMf.hT_(O APPENDIX A - TECilNICAL INFORMATION 6.4 INSTRUMENT LINES te TAHLE 6.41 SYSTEMS CONTAINING INSTRUMENT LINES WITillN Tile SCOPE OF TiiE ILCE System g y ,,,,g,,, BGB W Number Section 01i Service Water 5.17 012 Saltwater 5.16 013 Fire Protection 5.10 015 Component Cooling 5.3 019 Compressed Air 5.4 023 Diesel Fuel Oil 5.7 024 Emergency Diesel Generators 5.8 030 Control Room lleating. Ventilation, and Air Conditioning 5.11.C 032 Auxiliary fluilding and Radwaste lleating and Ventilation 5.11.A 036 Auxiliary Feedwater 5.1 038 Nuclear Steam Supply System Sampling 5.13 041 Chemical and Volume Control 5.2 045 Feedwater 5.9 052 Safety injection 5.15 060 Containment lleating and Ventilation 5.11.11 061 Containment Spray 5.6 064 Reactor Coolant 4.1 067 Spent Fuel Pool Cooling 5.18 069 Waste Gas See Note 1 071 Liquid Waste See Note 1 077/079 Radiation Monitoring 5.14 083 Main Steam 5.12 Notes icthble 6.4-1
- 1. The instrument lines and associated components for the Waste Gas and Liquid Waste Systems were included in the pre evaluation for the Containment Isolation Group of systems. The Containment Isolation Group is discussed in BGE LRA Section 5.5. [ Reference 3, Section 3.0 and Appendix At Reference 5, Attachment 4A]
Operating ihnericncs Representative historical operating experience pertinent to aging is included to provide insight in suppo-ting the aging management demonstrations provided in Section 6.4.2 of this report. This operating experience was obtained through key word searches of IlGE's electronic database of information on the CCNpP dockets, through documented discussions with currently assigned cognizant CCNPP personnel, and through other sources as indicated below.
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APPENDIX A - TEC!!NICAL INFORMATION 6.4 - INSTRUMENT LINES An internal review was performed by BGE in 1996 of CCNPP tubing failures for the period of da9 through 1995, Approximately 400 maintenance orders (MOs) associated with tubing failures were reviewed. 'Ihe MOs were generated to resolve the following general types of tubing issues:
. Approximately 93% of the MOs were written for tubing end fitting leaks / failures due to improper maintenance or installation practices; e Approximately 5% of the MOs were written for tubing abuse; and
- Approximately 1% of the MOs were written for vibration problems.
A breakdown of the tubing failures by year is provided in Table 6.4 2.
TAllLE 6.4 2 lilSTORY OF TUll1NG FAILUNM AT CCNPP - 1989 TilROUGli 1995 Year Non Safety Related Safety Related Total Tubing / Fitting Tubing / Fitting Tubing / Fitting Failures Failures Failuivs 1995 79 3 82 1994 53 3 56 1993 72 5 77 1992 84 9 93 1991 64 0 64 1990 17 0 17 1989 4 0 4 TOTAL 373 20 393 There are approximately 100,000 fittings in the plant (average 10 fittings per instrument and approximately 10,000 instruments for both units). Based on the MOs for 1989 through 1995, the failure rate for all tubing /Ottings is 0.056% per year (l.c., [393 failures / 7 years) /100,000 Ottings),
From the information contained in the MOs, the probable root causes of the tubing / fitting failures are as follows:
- Improper maintenance practicess loose fitting, improper seating of ferrule, improper make up of fitting, mixing fitting parts, too much torque applied, damaged tubing Otting, Otting not properly retightenend, dirt entered fitting / ferrules while tubing disconnected; e Improper installation practices: unsupported tubing span, missing support or tube tray clips, missing suppon hardware; and :
- Tubing at.uses tubing kinked, bent, crimped, or damaged due to external force (e.g., tubing stepped on).
Ilased on the information provided by the BGE . internal review of tubing failures at CCNPP, it can be concluded that tubing /Otting failures are predominately due to root causes other than age related degradation. The only tubing failure issue identified that could be construed as age-related was Application for License Renewal 6.44 Calvert Cliffs Nuclear Power Plant
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APPENDIX A - TECHNICAL INFORMATION 6.4 INSTRLMENT IINES vibration, which accounted for approximately 1% of the tubing failures that were reviewed. Some of these vibration problems nay have been due to improper maintenance or installation practices (e.g., loose fittings or missing supports). V;bration problems that are due to causes other than improper maintenance or installation practices are typically resolved by design changes (e.g., strengthening / addition of supports or use of Dexible tubing). Herefore, vibration problems are considered the result ofinstallation inadequacies and not the result of ncrmal aging mechanisms.
Based on lessons learned from pest tubing failures at CCNPP, corrective actions have been taken to minimize tubing failures for new or modified tubing installations, nese actions include the recent development of a technical procedure for proper installation and inspection of compression Ottings. This procedure replaced guidelines that relied more on " skill of the craft" for compre# ion fitting installation rather than specine requirements. %e procedure includes acceptance criteria to ensure that the Ottings are adequately tightened and also provides speciuc instructions for disconnecting and reconnecting Ottings on existing tubing. Other corrective actions taken include training of plant personnel in the use of the new procedure and training to stress the importance of adequate follow through on lessons learned from industry and site operating experience. [ Reference 6)
Scoped Structures and Comoonents and Their Intended Functions As discussed above, instrument lines all perform the passive intended function of maintaining the system pressure boundary. Based on the discussion in Section 4.1.1 of the CCNPP IPA Methodology, instrument lines that maintain the Reactor Coolant System pressure boundary, maintain radiological boundaries to ,.. . vent ecceding 10 CFR Pan 100 limits, or maintain safety system boundaries to limit system leakage, are within the scope oflicense renewal based on $54.4(aXI) and $54.4(aX2).
All ef the instruments included in the ILCE perform the passive intended function of maintaining pressure boundary in their respective systems and would normally be subject to AMR. Ilowever, some instruments also perform active functions (in additica to their pressure boundary function) and are excluded from AMR based on 654.21(aXIXI). Pressure transmitters, pressure indicators, and water level indicators are examples of" active" instruments, which perfonn their intended functions with moving parts or with a change in con 0guration, and are explicitly excluded from AMR based on 654.21(aXIXi).
As stated in the NRC Final Safety Evaluation for the CCNPP IPA Methodology, ". ..the pressure retaining boundary of " active" instrumentation may be excluded from an AMR because functional degradation resniting 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." For example, aging effects on the diaphragm of a pressure transmitter will affect the analog output of the transmitter (i.e., active function) prior to loss of the transmitter passive pressure boundary function. Surveillance testing or calibration of the transmitter will detect the aging effects on the diaphragm. [ Reference 2, Section 7.1.2t Reference 3 Section 2.0; Reference 7, Section 3.7.2)
Other instruments included in the scope of for the ILCE (in addition to pressure transmitters, pressure indicators, and water level indicators) also have active furactions and, depending on certain characteristics, may be excluded from AMR In order to be excluded, age related degradation of the active function must directly correlate to age related degradation of the passive pressure boundary ftmetion, instruments that sense pressure as their means of measuring the process have internal subcomponents such as diaphragms, seals, and mechanical linkages to convert the pressure input to an analog output signal (e.g.,4 to 20 milliamps), to provide a digital contact output, or to provide local indication (e.g., meter movement). The conversion of the process pressure to a monitorable output signal
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APPENDIX A - TECHNICAL INFORMATION I 6.4 . INSTRUMENT LINES or indication would be considered the active function for these pressure sensing instruments. l Detrimental effects of aging on the pressure-conversion active function are readily determinable, and existing programs and requirements (such as surveillance testing of response time or calibration of the instrument) are expected to directly detect the effects of aging. ;
llased on the above, Instruments that have one or more of the following characteristics may be excluded from AMR:
e Instruments that sense pressure and have an analog output signal; e Instruments that sense pressure and have a digital output signal; or
. Instruf ats that sense pressure and provide local indication by a moving part (e.g., meter movement).
Therefore, examples of other types of instruments (in addition to pressure transmitters, pressure indicators, and water level indicators) that may also be excluded from AMR include:
- l' low transmitters; e Level transmitters; e Differential pressure transmitters; e Level switches; e Pressure switches; and e DilTerential pressure indicators.
instruments included in the scope of the ILCE that are subject to AMR would include non pressure sensing instruments such as level sight glasses.
Ilased on the above, the ILCE components subject to AMR are as follows: [ Reference 3 Sections 2.0, 3.0, and 4.0)
. Small bore piping, tubing, and fittings; e lland valves; e Non pressure sensing instruments; and
. Supports for instrument line tubing.
6.4.2 Aging Management For efliciency in presenting the results of the aging management evaluations for this report, the ILCE components subject to AMR are grouped as follows:
Group 1 Includes instrument line pressure boundary components (i.e., small bore piping, tubing, fittings, hand valves, and non-pressure sensing instruments).
Group 2 - includes instrument line supports.
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6.4 INSTRUMENT LINES 1hc following discussion of the aging management demonstration process is presented by group and covers materials and environment, aging mechanism effects, methods to manage aging, aging management program (s), and demonstration of aging management.
Group I (Instrument line pressure boundary components) . Materials and Environment Group l includes the following instrument line pressure boundary components: small bore piping, ,
tubing, fittings, hand valves, and non pressure sensing instruments, i
instrument tubing at CCNpp is made up of three different materials: carbon steel, stainless steel, and I copper. In general, steels are used in liquid systems and copper is used in air applications. Steels are also used in some air applications and copper is used in some oil applications. Liquid systems with more ;
aggressive environments or high purity water primarily use stainless steel instead of carbon steel. ;
Tubing Ottings and valves are selected based on the type of tubing: carbon steel for carbon steel tubing, stainless steel for stainless steel tubing, and brass or bronte for copper tubing. Materials for small bore piping and the associated valves and fittings are determined based on the respective piping class.
[ Reference I; Reference 3, Section 3.0; Reference 8]
The instrument line pressure boundary components are subjected to internal and external enviroamental conditions similar to those for the main process line components in their respecilve systems.
Group I (instrument line pressure boundary components). Aging Mechanism Effects The small bore piping, tubing, Ottings, hand valves, and non pressure sensing instruments are constructed of materials similar to those for the main process line components in the systems in which they are installed in addition, they are exposed to internal and external environmental conditions similar to those for the main process line components in their respective systems. For these reasons, any plausible age related degradation mechanism (ARDM) applicable to the main process line pressure boundary components in a specinc system is also considered applicable for the instrument line pressure boundary components in tlat system, The specific ARDMs are adhessed for each of the systems containing instrument lines within the scope of the ll.CE per the llGE LRA sections shown in Table 6.41. [ Reference 3, Section 3.0]
Due to the smaller inside diameter and thinner walls ofinstrument lines (relative to process piping), and other design considerations such as use of compression fittings, the following potential ARDMs are addressed for instrument line presrure boundary components, since they may not be considered plaunble
- for the system main process line components:
- Fouling; e Fretting; and e liigh cycle fatigue. .
Fouling refe,s to the necumulation of deposits on the inside of components that increases resistance to
- Guld How (e.g, longterm accumulation of corrosion products). This ARDM could eventually cause -
instrument line blockage, llowever, this ARDM has no impact on the pressure boundary passive
- intended fmwtlon. [ Reference 3. Section 3.0; Reference 9, Attachment 7 for Pipe)
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APPENDIX A . TECHNICAL INFORMATION 6.4 INSTRUMENT LINES Fretting is a wear phenomenon that occurs due to small vibratory or sliding motions. For instrument lines, fretting can occur at the tubing / compression utting interface or at the tubing / tubing .upport interface. Improperly installed Attings or inadequate support can allow the tubing to vibrate, which could eventually cause loss of tubing material and eventually cause tubing failure. As discussed in the Operating Experience section above, vibration problems are due to installation inadequacies (e.g., improper maintenance or installation practices or design problems) and are not considered the result of r.ormal aging mechanisms. These types of failures typically occur soon after tubing installation or modincation. Strict compliance with CCNPP's Instrument and Tubing installation speciucation (Reference 1) ensures that failures due to fretting are minimized. [ Reference 3, Section 3.0; Reference 9, Attachment 7 for Pipe) liigh cycle fatigue occurs when the component cyclic stresses (including modifying factors such as stress concentrations, surface conditions, and plating) exceed the material fatigue strength for the number of cycles, improperly installed Ottings or inadequate suppost can allow the tubing to vibrate, which could eventually result in fatigue cracking of the instrument line. As discussed in the Operating Experience section above, vibration problems are due to installation inadequacies (e.g., improper maintenance or installation practices or design problems) and are not considered the result of normal aging mechanisms.
Dese types of failures typically occur soon afler tubing installation or modification. Strict compliance with CCNPP's Instrument and Tubing Installation specincation (Reference 1) ensures that failures due to high cycle fatigue are minimized. (Reference 3, Section 3.0; Reference 9 Attachment 7 for Pipe]
Based on the above, the " instrument line specific" potential ARDMs (l.c., fouling, fretting, and hign cycle fatigue) are not considered plausible aging mechanisms. Only the plausible ARDMs applicable to the pressure boundary components in the systems shown in Table 6.41 are considered applicable for the instrument line pressure boundary components in those systems, ne pt:usible ARDMs applicable to the main process line pressure boundary components, if unmanaged, could eventually result in effects such that the instrument line pressure boundary components may not be able to perform their pressure boundary function under CLil conditions. Therefore, the effects of these ARDMs must be managed for the instrument line pressure boundary components.
Group I (instrument line pressure boundary components)- Methods to Manage Aging Since the instrument line pressure boundary components are subject to the same plausible ARDMs as the main process line pressure boundary components in their respective systems, the methods to manage aging of the instrument line components would be the same as for these main process line components.
Some of the ARDMs can be mitigated by minimizing the exposure of the components to an aggressive environment. His can sometimes be accomplished by methods that control the environment (e g., maintaining process Guid chemistry or maintaining dry air in the Instrument Air System). For ARDMs that cannot be mitigated or to provide additional assurance that degradation is not occurring, discovery methods such as visual inspections can be used.
Group 1 (instrument line pressure boundary components). Aging Management Program (s)
As' discussed above, there are similarities between instrument line pressure boundary components and the main process line pressure boundary components with respect to materials, internal and external environmcnts, plausible ARDMs, and methods to manage aging. Herefore, the aging management Application for License Renewal 6.48 Calvert Cliffs Nuclear Power plant
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APPENDIX A - TECHNICAL INFORMATION 6.4 . INSTRUMENT LINES r programs applicable to the main process line pressure boundary components, for the systems shown in l
~
Table 6.41, would also be effective in rnanaging aging for the instrument line pressure boundary components. For example, if a system credits a chemistry program to mitigate crevice corrosion and pitting in a main process line, the chemistry prograrn would directly apply to the connected instrutnent lines due to the common Guid. Discovery programs such as the Age Related Degradation Inspection !
(ARDI) Program that are credited for specinc main process line pressure boundary components, bound the aging management for the instrument line pressure boundary components. The results of these inspections (including the associated corrective actions) provide the means to discover age related degradation for the instrument line pressure boundary compments, as discussed below. [ Reference 3 - ,
Section 3.0]
All of the CCNPP aging management prograrns require that corrective actions be taken if any actual or suspected conditions adverse to quality are identified (e.g., chemistry parameters out of acceptable range, age related degradation discovered). Conditions adverse to quality are documented on issue Reports in accordance with the CCNpP Corrective Actions Program. Issue Reports are required to identify the extent of the issue, including the suspected boundary of the problem. In addition, Issue Reports are required to indicate if the problem could have generic implications or affect the operability of other associated equipment and systems. Corrective actions are taken as required as part of the issue Report resolution process. (Reference 10. Section 1.2.A; Reference 11. Section 5.5.A Attachment 1)
Based on the above, if conditions adverse to quality arn identined in a main process line, then the boundary of the problem and generic implications would be investigated. The scope of the investigation would be expanded to include the associated instrument lines, if applicable. For example, age related degradation discovered in a main process line durirg t, visual inspection would cause an issue Report to be initiated. Generic implications and the boundary of the degradation would be identified as part of the issue Report process (i.e., other components or systems may also be experiencing degradation due to the same root cause). As a result of the investigation, the scope of the visual inspections may need to be expanded to the instrument lines in order to determine the full extent of the degradation in the system.
[ Reference 3, Section 3.0)
To provide further assurance that aging for the instrument line pressure boundary components is managed, the ARDI Program will provide guidance regarding the expansion of scope from the main process lines to the instrument lines if conditions adverse to quality are found. Age related degradation in the main process lines is expected to occur prior to age-related degradation of the instrument lines, since the main process lines are typically exposed to more aggressive environments. The Duld temperature in instrument lines generally decreases to near ambient room temperature within several feet of the main process line connection. Therefore, corrosion rates (which typically increase with temperature) are expected to be lower in the instrument lines than the main process lines. In addition, instrument lines lack Dow. Therefore, degradation from Dow dependent ARDMs such as crosion corrosion is not expected in the instrument lines. [ Reference 1. Figure 8 F6; Reference 3, Section 3.0; Reference 12, pages 21 and 76)
The corrective actions taken as a result of conditions adverse to quality identined for the main process line pressure boundary components (during aging management program activities) will ensure that the
- instrument line pressure boundary components will remain capable of performing their pressure boundary function under all CLB conditions during the period of extended operation.
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APPTNDIX A TECilNICAL INFORMATION 6.4 INSTRUMENT LINES Group I (instrument line pressure boundary components)- Demonstration of Aging Management
!!ased on the information presented above, the following conclusions can be reached with respect to the instrument line passure boundary components:
e ne instrument line pressure boundary components (i.e., small bore piping, tubing, fittings, hand valves, and non pressure sensing instruments) hase the passive intended function of maintaining the sptem pressure boundary under CLII conditions.
e %e ARDMs applicable to the main process line pressure boundary components are also applicable to the instrument line pressure boundary components. These ARDMs, if unmanaged, could eventually result in effects such that the instrument line pressure boundary components may not be able to perfonn their pressure boundary function under CLB conditions.
- The aging management programs applicable to the main process line pressure boundary components, for the systems shown in Table 6.4 1, provide the means to mitigate and/or discover i age related degradation for the instrument line pressure boundary components, e To provide further assurance that aging for the instrument line pressure boundary components is managed, the ARDI Program will provide guidance regarding the expansion of scope from the ,
main process lines to the instrument lines if conditions adverse to quality are found i e Corrective actions taken as a result of conditions adverse to quality identified for the main l process line pressure boundary components (duriug aging management program activities) will I
ensure that the instrument line pressure boundary components will remain capable of performing their pressure bounAry function.
%erefore, there is reasonable assurance that the effects of the applicable ARDMs will be managed for the instrument line pressure boundary components such that they will be capable of performing their :
pressure boundary function, consistent with the CLB, during the period of extended operation.
Group 2 (instrument line supports)- Materials and Environment i
Group 2 consists of supports for instrument line tubing.
De materials of construction for instrument line supports include: carbon steel, stainless steel, brass, bronze, aluminum, and clastomers. (Reference 3, Section 4.0]
%e plant environmental conditions are as follows: [ Reference 13. Sections 5.4,A and 5.4.C]
Inside Containment:
- The maximum design ambient air temperature is 120*F for normal conditions, e %e design ambient air re'ative humidity during normal plant operation is 50% at 120'F and l 14.7 psia. j in other buildings:
l e- Ambient temperatures are controlled by plant ventilation systems, as specified in Updated Final Safety Analysis Report Chapter 9 The plant ventilation systems are designed to provide ,
minimum (winter) and maximum (summer) building air temperatures, as specified in Updated Final Safety Analysis Report Table 918. Certain areas are maintained by s.afety related i
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ventilation systems. The remaining areas are ventilated by non safety related ventilation systems and are maintained at or below the maximum design temperatures, f
e 'There are no design humidity requirements for the plant areas outside containment. ,
Outdoors:
e Instrument line suppons located outdoors are subject to the site environmental conditions described in Updated Final Safety Analysis Report Chapter 2.0.
Commonly used subcomponent parts for instrument line supports include: [ Reference 1)
- Structural steci (E.G., Plates, Channel);
e Clamps (typically constructed of carbon steel, stainless steci brass, or aluminum);
e Nuts, bolts, and washers (typically constructed of carbon or stainless steel); and j e Elastomer tubing tray filler material (used to secure tubing within tubing tray).
goup 2 (instrument line supports). Aging Mechanism Effects Instrument line supports are subject to general corrosion and clastomer hardening. General corrosion is only plausible for the carbon steel subcomponents of the suppons (e.g., structural steel, clamps, nuts, bolts, and washers). Elastomer hardening is only plausible for the clastomer subcomponents of the supports (i.e., elastomer tubing tray filler material). [ Reference 3, Section 4.0]
General corrosion is the thinning (wastage) of a metal by chemical attack (dissolution) at the surface of the metal by an aggressive environment. The consequences of the damage are loss of load carrying cross sectional area. General corrosion requires an aggressive environment and materials susceptible to that environment. Unconted carbon steel components will corrode in moist environments. General corrosion is plausible for the carbon steel subcomponents of the instrument line supports due to normal humidity levels in the plant and due to potential leakage of water from components in the vicinity of the supports. 'lhe effects of general corrosloa on the instrument line supports would be a loss of support material and reduction in the support strength if the ARDM were allowed to progress unmanaged.
Exposed carbon steel surfaces at CCNpP are covered with a protective coating in accordance with Reference 14. Ilowever, during the plausibility determination, no credit was taken for the protective coating applied to these instrument line support subcomponents. [ Reference 9, Attachment 7s; Reference 15; pages 2 3 and 2-10]
Extended exposure to light, heat, oxygen, orcne, water, or radiation can cause scission or crosslinking of the polymer chains forming clastomer materials. Chain scission (the breaking of chemical bonds) lowers the clastomer tensile strength and clastic modulus. Crosslinking (undesirable linking of adjacent polymer strings at susceptible sites) causes clastomers to become more brittle and promotes surface cracking. Elastomer hardening is plausible for the tubing tray filler material due to normal plant environmental conditions. . Elastomer hardening of this instrument line support subcomponent could allow excessive movement of tubing within the tubing trays if the ARDM were allowed to progress unmanaged.-[ Reference 15, Page 2 4]
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%ese aging mechanisms, if unmanaged, could eventually result in insufficient support being afforded to the instrument lines such that the instrument lines may not be able to perform their pressure boundary fuNtion under CLB conditions. Therefore, general corrosion and clastomer hardening were determined to be pit.usible ARDMs for which the aging effects must be managed for the instrument line supports.
I Group 2 (Instrument llae supports) . Methods to Manage Aging
- Mitiption:
i To mitigate the effects of general corrosion, the conditions on the external surfaces of the carbon steel subcomponents of the instrument line supports must be controlled. Preventing direct and prolonged contact between the carbon steel surfaces and moisture is an effective mitigation technique for general ;
corrosion. Herefore, to mitigate general corrosion, protective coatings ensure that the carbon sicci subcomponents are not in contact with a moist, aggressive environment for extended periods of time. In addition, plant activities that identify conditions such as degmded paint or leaking water can be used to -
mitigate the eITects of general corrosion.
Since clastomer hardening is affected by exposure to environmental conditions that are not feasible to ;
control (e.g., light, heat, oxygen, ozone, water, radiation), there are no practical means to mitigate its effects.
Discoverv: !
De effects of general corrosion are detectable by inspection. De external surfaces of the carbon steel subcomponents of the supports are covered by a protective coating, and observing that significant degradation has not occurred to this coating is an effective method to ensure that corrosion has not l affected the intended function of the support. Coatings degrade slowly over time, allowing visual detection during normal operations. Since the coating does not contribute to the intended function of the supports, observing the coating for degradation provides an alert condition that triggers corrective action prior to degradation that affects the support's ability to perform its intended function, ne degradation of the protective coating, or any actual corrosion that does occur, can be discovered and monitored by periodically inspecting the supports and by carrying out corrective action as necessary.
The effects of clastomer hardening arc detectable by inspection. The inspection would need to examine the tubing tray filler material for signs of surface cracking and could also include a hands-on examination to detect brittleness. if significant degradation is found, appropriate corrective action i (e.g., replacement of tubing tray filler material) can be taken to ensure that the instrument line support continues to perfonn its intended function.
Givup 2 (instrument line supports) . Aging Management Program (s) 8 hii13ation:
He extemal surfaces of the carbon steel subcomponents of the supports are covered by a protective coating that mitigates the effects of general corrosion. The discovery programs discussed below ensure that the protective coatings are maintained and that plant housekeeping conditions are such that general corrosion is miti ated E (e.g., discovery of water leakage).
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There are no CCNPP programs credhed with mitigation of elastomer hardening for the instrument line ;
supports.
Dixmuy:
To verify that no significant general corrosion or elastomer hardening is occurring on the instrument line supports, a new plant program will be developed to provide inspections of representative supports. The l program is considered an ARDI Program as defined in the CCNPP IPA Methodology (refersnee Section 2.0 of the DGE LRA). The program details are provided t nw. [ Reference 3, Section 4.0)
AILDU'Jostam The elements of the ARDI Program will include:
- Determination of the examination sample size based on plausible aging effects; ;
e identification ofinspection locations based on plausible aging effects and consequences of loss of component intended function' l
- Determination of examination techniques (including acceptance criteria) that would be efYective, considering the aging effects for which the component is examined;
- Methods for interpretation of examination results;
- ' Methods fw resolution of adverse examination findings, including consideration of all design loadings re@ ired by the CLB and specification of required corrective actions; and
- Evaluation of the need for follow up examinations to monitor the progression of any age related ;
degradation.
Any corrective actions that are required will be taken in accordance with the CCNPP Correct ive Actions Program and will ensure that the instrument line supports remain capable of performing their passive i intended function under all CLB cond' ions.
In addition to the ARDI Program, ongoing plant activities are credited with managing general corrosion either by discovery of corrosion or by discovery of poor housekeeping conditions that could eventually lead to general corrosion (e.g., degraded paint or leaking water). The CCNPP prmdures for Structure and System Walkdowns, Control of Shift Activities, r.nd Ownership of Plant Opt @g Spaces govern these ongoing activities. The programs are discussed below.
Structure and System Walldnum Calvert Cliffs Administrative procedure MN.I 319 " Structure and System Walkdowns," provides for ,
discovery of general corrosion (or conditions that could allow general corrosion to progress) for the '
instrument line supports by performance of visual inspections during plant walkdowns. ~lhe purpose of the program is to provide direction for the performance of structure and system walkdowns and for the documentation of the walkdown results. [ Reference 16, Section 1.1)
- Under this program, responsible personnel perform periodic walkdowns of their assigned structures and systems. Walldowns may also be performed as required for reasons such as: material condition assesscents; system reviews before, during, and after outages; start up reviews (i.e., when the system is Application for License Renewal - 6.4 13 Calvert Clifts Nuclear Power Plant p
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initially pressurized, energlied, or placed in service); and as required for plant modifications.
[ Reference 16, Section 5.1]
One of the objectives of the program is to assess the condition of the CCNPP structures, systems, and components such that any degraded condition will be identified, documented, and corrective actions ;
taken before the degradation proceeds to failure of the structures, sys* ems, and components to perform their intended functions. Conditions adverse to quality are documented and resolved by the CCNPP Corrective Actions Program. [ Reference 16, Sections 5.l.C. 5.2.A.1, and 5.2.A.5]
He program provides guidance for specific types of degradation or conditions to inspect for when performing the walkdowns. Inspection items related to aging management include the following:
[ Reference 16, Section 5.2 and Attachments I through 13]
e items related to specific ARDMs such as corrosion or vibration; e EITects that may have been caused by ARDMs such as damaged supports; concrete degradation, anchor bolt degradation, or leakage of fluids; and e Conditions that could allow progression of ARDMs such as degraded protective coatings, leakage of fluids, presence of standing water or accumulated moisture, or inadequate support of components (e.g., missing, detached , or loose fasteners and clamps).
Specifically for walkdowns of mechanical systems, the program inspects for proper installation of instrumentation, leaking fittings, and missing components on tubing supports. [ Reference 16, Attachment 1]
This program promotes famillarity of the systems by the responsible personnel and provides extended attention to plant n'aterial condition beyond that afforded by Operations and Maintenance alone. The program has been improved over time, based on past experience, to provide guidance on specific activities to be included in the scope of the walkdowns.
The corrective actions taken as a result of this program will ensure that the instrument line supports remain capable of performing their passive intended function under all CLil conditions.
Controlo[ Shin Activities .
Calvert Clifts Administrative Procedure NO l.200," Control of Shill Activities," provides for discovery of conditions that could allow general corrosion to progress for the instrument line supports by performance of visual inspections during plant operator rounds. He purpose of the program is to ensure that shift operations are conducted in a safe and reliable manner and within the scope of the operator's lleense, procedures, and applicable regulatory requirements. [ Reference 17 Section 1.1]
Under this program, plant operators inspect accessible operating spaces each shif). The containment is
- also inspected once per shill when the plant is shutdown and the containment is open for normal access.
- Conditions adverse to quality that are identified during the operator rounds are documented and resolved ;
by the CCNPP Corrective Actions Program, [ Reference 17, Section 5.8.11]
He program provides guidance for specific conditions to inspect for when performhg the walkdowns.
' Inspection items related to aging management include the following: [ Reference 17, Section 5.8.D]
- Application fbr License Renewal 6.4 14 Calvert Cliffs Nuclear Power Plant
! ATTACithirNT (4)
I APPTNDIX A - TI:CilNICAL INFORMATION 6.4 INSTRUMr.NT LINES
- Items related to specific ARDMs such as vibration; e liffects that may have been caused by ARDMs such as damaged piping and instrument tubing, or leakage of fluids; and
- Conditions that could allow progression of ARDMs such as leakage of Hulds.
Operator rounds have been historically effective in identifying plant deficiencies. The documented guidance and expectations have been improved over the years as a result of lessons teamed and the site emphasis on continual quality improvement.
The corrective actions taken as a result of this program will ensure that the instrument line supports remain capable of performing their passive intended function under all CLB conditions.
02ncIshin of Plant Operating Spaces Calvert Cliffs Adtninistrative Procedure NO l.107," Ownership of Plant Operating Spaces," provides for discovery of general corrosion (or conditions that could allow generr.1 corrosion to progress) for the instrument line supports by performance of visual inspections on plant operating areas. The purpose of the program is to picvide requirements and guidance on pc sonnel accountability for the correction of housekeeping, materi, .. and radiological denciencies. 1he individual responsibilities stated in the procedure are carried out in order to establish a program that will improve the housekeeping and material condition of the plant operating areas on a long term basis. (Reference 18, Section 1.1]
Under this program, owners are identified within each space and provide a point of contact for any individual who finds deficiencies or any concern with the space. The responsible individuals are required to periodically inspect their assigned space (s) for housekeeping / cleanliness, material condition, and radiological protection deficiencies. Conditions adverse to quality that are identified are documented end resolved by the CCNPP Corrective Actions Program. [ Reference 18, Sections 4.4,5.1, and5.2)
The program provides guidann for types of dc0clencies to look for when performing the ins tions.
Inspection items related to aging mansp. nt include the following: (Reference 18, Attachmem .)
- ltems related to specific ARDMs such as corrosion;
- Effects that may have been caused by ARDMs such as loose lines' pipes, loose fasteners, or leakage of Huids; and
- Conditions that could allow progression of ARDMs such as unbracketed lines / pipe, inissing fasteners, inadequate paint, or leakage of fluids.
- lhe corrective actions taken as a result of this program will ensure that the instrument line supports remain capable of performing their passive intended function under all CLl3 conditions.
Application for License Renewal 6.4 15 Calvert ClitTs Nuclear Power Plant
NITACitMENT f()
APPENDIX A TECHNICAL INFORMATION :
6.4 INSTRUMENT LINES
- Gewup 2 (instrument time supports) Demonstration of Aging Managment Ilased on the information presented above, the following conclusions can be reached with respect to the instrument line supports
- -
e lhe instrument line supports have the passive intended function of maintaining the system pressure boundary under CLil conditions. ,
e General corrosion and clastomer hardening were determined to be plausible ARDMs for the instrument line supports. These ARDMs, if unmanaged, could eventually result in insumcient support being afforded to the instrument lines such that the instrument lines may not be able to perform their pressure boundary fimetion under CLil conditions.
. General corrosion is mitigated by applying protective coatings to the instrument line supports,
, periodically examining the supports for degradition of that coating or conditions that could acce! crate degradation, and by maintaining the coatings.
The ARDI Program will conduct inspections of representative instrument line supports to e
, discover the clTects of general corrosion and clastomer hardening. and will contain acceptance criteria that ensure corrective actions will be taken cuch that there is reasonable assurance that the ;
supports remain capable of perfonning their passive intended function under all CLB conditions. .
. Ongoing plant activities (Structure and System Walkdowns, Control of Shif) Activities, and Ownership of Plant Operating Spaces) provide for the discovery of general corrosion (or conditions that could allow general corrosion to progress) for the instrument line supports by performance of visual inspections. Corrective actions will be taken such that there is reasonable assurance that the supports remain capable of performing their passive intended function under all CLil conditions.
- lherefore, there is reasonable assurance that the effects of general corrosion and elastomer hardening will be managed for the instrument line supports such that the instrument lines will be capable of performing their pressure boundary function, consistent with the CLil, during the period of extended operation.
P 6.4.3 Conclusion The programs discussed for instrument lines are listed in the following table. These programs are (or will be for new programs) administratively controlled by a formal review and approval process. As demonstrated above, these prugrams will mannge the aging mechanisms and their efTects such that the inten6 J functions of the instrument lines will be rnaintained during the period of extended operation ,
consistent with the CLB under all design loading conditions.
The analysis / assessment, corrective action, and confirmation / documentation process for license renewal is in accordance with QL 2, " Corrective Actions Program." QL 2 is pursuant to 10 CFR part 50, Appendix B, and covers all structures and components subject to AMR.
Application for License Renewal 6.4 16 Calvert Cliffs Nuclear Power Plant
AITACilMENT (4)
APPENDIX A TECilNICAL INFORMATION 6.4 . INSTRUMENT LINES ,
TAHl.E 6.4 3 LIST OF AGING MANAGEMENT PROGRAMS FOR INSTRUMENT LINES l i
Program Cralited For
~
Existing Structure and System Walkdowns Discovery of the efTects of general corrosion l (hirol.319) for the instrument line supports (Group 2).
Controlof Shift Activities (NO l.200) !
Ownership of Plant Operating Spaces (NO.l.107)
New ARDI Program Providing guidance for expansion of scope from the main process lines to the instrument lines if conditions adverse to quality are found (Group !).
Discovery of the efTects of general corrosion and clastomer hardening for the instrument line supports (Group 2).
Application for License Renewal 6.4 17 Calvert Cliffs Nuclear Power Plant i , . . _ . . _ _ _ _ _ _ _
AITACilMENT_H) ;
APPENDIX A - TECilNICAL INFORMATION :
6.4 . INSTRUMENT LINES l 6.4.4 References
- 1. CCNPP Drawin; 92401," Instrument and Tubing Installation," Revision 18, July 31,1996
- 2. "CCNPP Integrated Plant Assessment Methodology," Revision 1 January 11,1996
- 3. "CCNPP Aging Management Revry Report for the Instrument Line Commodity," Revision 1 August 4,1997
- 4. CCNPP Administrative Procedure EN.I.304, " Component Prc Evaluation," Revision 2, April 9,1997
- 5. "CCNPP Component Pre Evaluation for the Containment Isolation Group (013,029,037,051, 053,069,071)," Revision 0, March 19,1997
- 6. CCNPP Technical Procedure TUllF 01,
- Fabrication and Installation of Parker CPI and Swagelok Compression Fittings," Revision 1, October 1,1997
- 7. 1,etter from Mr. D. M. Crutchfield (NRC) to Mr C. II. Cruse (!!GE), dated April 4,1996,
" Final Safety Evaluation (FSE) Concerning flattimore Gas & Electric Company Report Entitled," Integrated Plant Assessment Methodology"
- 8. CCNPP Drawing 92767,"M 600 Piping Class Sheets," Revision I, April 20,1994
- 9. "CCNPP Aging Management Review Report for the Saltwater System," Revision 4, February 11,1997
- 10. CCNPP Directive Ql 2," Corrective Actions Program," Revision 2, January 2,1996
- 11. CCNPP Administrative Procedure Q!e2100, " Issue Reporting and Assessment," Revision 5, March 3,1997
- 12. " Corrosion Engineering" Second Edition, M. G. Fontana and N. D. Greene, McGraw llill llook Company, Copyright 1978
- 13. CCNPP Engineering Standard ES.014 " Summary of Ambient Environmental Service Conditions," Revision 0, November 8,1995
- 14. CCNPP Technical Requirements Document TRD.A 1000, "I1GE Coating Application Performance Standard," Revision 14, September 29,1997
- 15. "CCNPP Aging Management Review Report for Component Supports," Revision 3, February 4,1997
- 16. CCNPP Administrative Procedure MN.I.319 " Structure and System Walldowns," Revision 0, Septembe 16,1997
- 17. - CCNPP Administrative Procedure NO-1200, " Control of Shift Activities," Revision 11, March 31,1997
- 18. CCNPP Administrative Procedure NO 1107, " Ownership of Plant Operating Spaces,"
Revision 3 September 30,1997 Application for License Renewal 6.4 18 Calvert Cliffs Nuclear Power Plant
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