ML20198A420

Summary of 981022 Meeting with Util in Rockville,Md to Discuss How Bge Addressed License Renewal Requirements for time-limited Aging Analyses & Generic Safety Issues as Applicable to Environ Qualification

ML20198A420
Person / Time
Site:	Calvert Cliffs
Issue date:	12/11/1998
From:	Dave Solorio NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
TAC-MA1453, TAC-MA1454, TAC-MA1457, NUDOCS 9812160262
Download: ML20198A420 (81)

Text

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December 11, 1998

. LICENSEE: Baltimore Gas and Electric Company FACILITY: Calvert Cliffs Nuclear Power Plant, Unit Nos.1 and 2

SUMMARY

OF OCTOBER 22,1998, MEETING WITH BALTIMORE GAS AND ELECTRIC COMPANY (BGE) REGARDING LICENSE RENEWAL ACTIVITIES FOR CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS.1 AND 2 (TAC l

NOS. MA1453, MA1454, MA1457) '

03 October 22,1998, the Nuclear Regulatory Commission (NRC) staff held a public meeting with representatives of Baltimore Gas and Electric Company (BGE) at Rockville, Maryland, to '

discuss how BGE addressed the license renewal requirements for time-limited aging analyses (TLAA) and generic safety issues as applicable to environmental qualification (EQ) in its license renewal application (LRA), and to discuss BGE's position relative to the staff's proposed

}

guidance on addressing TLAA for EQ. A list of meeting attendees is provided in Enclosure 1 and slides used by BGE for the discussion are provided in Enclosure 2.

At the conclusion of BGE's presentation the NRC staff stated its understanding of how BGE evaluated EQ against the requirements for TLAA. BGE added that the Nuclear Energy Institute (NEI) guidance document for license renewai, NEl 95-10, and the staff's draft Standard Review Plan for License Renewal was not approved NRC guidance. BGE's legal counsel for its LRA application asked the staff why compliance with the requirements of 10 CFR 50.49 was not a  :

sufficient demonstration that aging was being managed. The NRC staff summarized that BGE's presentation sufficiently addressed the staff's request for additional information previously submitted to BGE (by letter dated September 4,1998) along with the additional list i provided on slide 50 in Enclosure 2, and that it was up to the staff to determine what additional information was needed to reach its conclusion that will be documented in the staff's safety evaluation. The staff then closed the meeting by summarizing that they now had a clearer understanding of how BGE addressed EQ against the requirements for TLAA, that the staff would meet internally to further discuss BGE's approach, and that if necessary the NRC would hold another meeting with BGE to discuss further conclusions.

OriginalSigned By  ;

David L. Solorio, Project Manager 98y21g2 g License Renewal Project Directorate P PDR Division of Reactor Program Management Docket Nos. 50-317 and 50-318 '

Enclosures:

1. List of Attendees i

2. BGE's Presentation Slideg 7 g rr "' "] ,

.M3x L1 ; m . -

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_ni cc w/encls: See next page  :. #

s,}y DOCUMENT NAME:G \ WORKING \SOLORIO\OCT_22.MTG OFFICE LA: PD,lp PDLR/Dy PDLR/DRPM:D NAME DsolonoM Slitt[ CGrimes ff DATE 1 2/10/98 12 4 /98 12/ p /98~I OFFICIAL RECORD COPY

-)

Distribution:

MARD COPY (w/ Enclosures 1 & 2)

Dochet Files; i PUBLIC '

PDLR R/F  ;

oGC i MEl-Zeftswy - T2E26 DISTRIBUTION: E-MAIL (w/ Enclosure 1) f

- RZimmerman (RPZ)  :

JRoe (JWR)

DMatthews (DBM) -

CGrimes (CIG)

TEssig (THE) l Glainas (GCL)

JStrosnider (JRS2)

GHolahan (GMH) ' . I SNewberry (SFN) i GBagchi(GXB1) j RRothman (RLR)

JBrammer (HLB) 'l CGratton (CXG1) i JMoore (JEM)

MZobier/RWeisman (MLZ/RMW) l SBajwa/ADromerick (SSB1/AXD)

LDoerflein (LTD) '

BBores (RJB) ,

SDroggitis (SCD) '

RArchitzel(REA)

CCraig (CMC 1) ,

LSpessard (RLS) ,

RCorreia (RPC)

[

RLatta (RML1)

EHackett (EMH1)  :

. AMurphy (AJM1) i TMartin (TOM 2)

DMartin (DAM 3)

GMeyer (GWM) l WMcDowell(WDM)

SStewart (JSS1)

THiltz (TGH) t . SDroggitis (SCD) ,

DSolorio (DLS2) '

PDLR Staff l

i

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, , , a m, ,- -

Baltimore Gas & Electric Company Calvert Cliffs Nuclear Power Plant cc: Unit Nos.1 and 2 ,

I President Mr. Joseph H. Walter, Chief Engineer .

Calvert County Board of Public Service Commission of '

Commissioners Maryland 175 Main Street Engineering Division j Prince Frederick, MD 20678 6 St. Paul Centre i Baltimore, MD 21202-6806 James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Birnie, Esquire 2300 N Street, NW }

Co-Director Washington, DC 20037 Maryland Safe Energy Coalition j P.O. Box 33111 l Mr. Bruce S. Montgomery, Director Baltimore, MD 21218 l NRM 1 Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector U.S. Nuclear Regulatory Commission David Lewis P.O. Box 287 Shaw, Pittman, Potts, and Trowbridge St. Leonard, MD 20685 2300 N Street, NW Washington, DC 20037 Mr. Richard I. McLean Nuclear Programs Douglas J. Walters Power Plant Research Program Nuclear Energy Institute Maryland Dept. of Natural Resources 1776 i Street, N.W.

Tawes State Office Building, B3 Suite 400 Annapolis, MD 21401 Washington, DC 20006-3708 DJW@NEl.ORG Regional Administrator, Region i U.S. Nuclear Regulatory Commission Barth W. Doroshuk 475 Allendale Road Baltimore Gas and Electric Company King of Prussia, PA 19406 Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Mr. Charles H. Cruse, Vice President NEF ist Floor Nuclear Energy Division Lusby, Maryland 20657 Baltimore Gas and Electric Company 1650 Calvert Cliffs Parkway Lusby, MD 20657-47027

NRC & BGE PUBLIC MEETING ON ENVIRONMENTAL QUALIFICATION OCTOBER 22.1998 NAME ORGANIZATION

1. DAVID SOLORIO NRC/PDLR

2. PAUL SHEMANSKl NRC

3. CARL YODER BGE

4. JAMES KILPATRICK BGE

5. STEVE COLLINS BGE

6. GARY DETTER BGE

7. RICHARD HENSEL BGE

8. B.W. DOROSHUK BGE

9. CHRIS GRIMES NRC/PDLR

10. JACK ROE NRC/DRPM

11. DALE THATCHER NRC

12. GUS LAINAS NRC

13. BOB PRATO NRC/PDLR

14. STEVE HOFFMAN NRC/PDLR

15. BOB WEISMAN NRC/OGC

16. SANDRA COOKE NRC/PDLR

17. CHRIS GRATTON NRC/SPLB  !

18. JET VORA RES/DET/EMMEB l

19. P.T. KUO NRC/PDLR l

20. ALTHEIA WYCHE SERCH/ LICENSING /BECHTEL i

21. LYNN CONNOR DOC-SEARCH ASSOCIATES

22. STEPHANIE MARTZ NRC/OGC

23. ALEX DROMERICK NRC

24. JANICE MOORE NRCIOGC

25. DAVID LEWIS SHAW PITTMAN

26. WILLIAM DENNY OGDEN ENVIRONMENTAL & ENERGY

27. R. PAUL COLAIANNI DUKE ENERGY

28. DAVID HOSTETLER VA. POWER

29. DAVID ROTH VA. POWER

30. MICHAEL HENIG VA. POWER

31. MIKE NEAL NUSIS

32. JOHN KUNZMANN BGE Enclosure 1 l

l

, M Life Cycle Management Projec ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT Presentation to the U. S. NRC October 22,1998 Carl J. Yoder Calvert Cliffs Nuclear Power Plant 98-056 Slide 1 Enclosure 2

/

Life Cycle Management Project i

1 Purpose

. Discuss License R'enewal requirements for TLAA and GSI as applicable to EQ

. Discuss the BGE LRA relative to these requirements 1

r . Discuss the BGE LRA relative to proposed staff guidance on EQ TLAA 4

l Y

,98-056 Slide 2

Life Cycle Management Project Objectives

. Demonstrate that continued compliance with 10 CFR 50.49 as described in the LRA meets the requirements of @54.21(c) and @54.29(a)(2)

. Demonstrate that the LRA provides sufficient information for the staff to conclude that continued compliance with 10 CFR 50.49 meets the requirements of @54.21(c) and @54.29(a)(2)

(98-056 Slide 3

Life Cycle Management Project Presentation Outline

Discuss the following

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance (5) Sections 2.0,2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3 (8) Conclusions

[

4

• The Letter to NEl's Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998

which deals with proposed staff guidance on addressing 654.21(c)(1)98-056 Slide 4

l Life Cycle Management Project i

Presentation Outline Discuss the following:

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance (5) Sections 2.0,2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3

! (8) Conclusions i

• The Letter to NEl's Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 /

which deals with proposed staff guidance on addressing @54.21(c)(1)

/

98-056 Slide 5

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1

/ M Life Cycle Management Project TLAA Requirements per 10 CFR Part 54

@54.3(a) Definitions Time-limited aging analyses, for the purposes of this part, are those license calculations and analyses that:

(1) Involve systems, structures, and components within the scope of license renewal, as delineated in @54.4(a);

(2) Consider the effects of aging; (3) Involve time-limited assumptions defined by the current operating 4

term, for example,40 years; (4) Were determined to be relevant by the licensee in making a safety determination;

. (5) Involve conclusions or provide the basis for conclusions related to the capability of the system, structure, and component to perform its intended function, as delineated in @54.4(b); and (6) Are contained or incorporated by reference in the CLB.98-056 Slide 6

i i

y Life Cycle Management Project h TLAA Requirements per 10 CFR Part 54

@54.21(c) Contents of Application - Technical Information (1) A list of time-limited aging analyses, as defined in @54.3, must be provided. The applicant shall demonstrate that:

(i) The analyses remain valid for the period of extended

operation; (ii) The analyses have been projected to the end of the period of extended operation; or

, (iii) The effects of aging on the intended function (s) will be i

adequately managed for the period of extended operation j/

x 98-056 Slide 7

Life Cycle Management Project

] TLAA Requirements per 10 CFR Part 54

@54.29(a) Standards for issuance of a Renewed License

~

(a) ; Actions have been identified and'haite been'oiQtstaRsnylinT j respect to,the:niatters identified in Paragra@sj(a)(j)l arid;(s)(2)!of;!

this section, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted'ih!achordance with ihed5,1 and that any changes made to the plant's CLB in order to comply with this paragraph are in accord with the Act and the Commission's regulations. These f matters are

(1) managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under @54.21(a)(1); and (2) time-limited aging analyses that have beeri identifie'cl16 require!

! . review under @54.21(c). /

98-056 Slide 8

)

1

! g M Life Cycle Management Project lm Requirements of 10 CFR Part 54 The rule requires that TLAAs be identified The rule allows an applicant to demonstrate that the effects of aging will be adequately managed for the period of extended operation i

t 98-056 Slide 9

Life Cycle Management Project

Presentation Outline Discuss the following

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance (5) Sections 2.0,2.1, and 6.3 of the BGE LRA

, (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3 (8) Conclusions i

• The Letter to NEl's Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 which deals with proposed staff guidance on addressing 554.21(c)(1)98-056 Slide 10

1 i

Life Cycle Management Project Relevant SOC Clauses (Principles of Rule)

From SOC lilb(i) Regulatory Philosophy i

in view of this final rule, the first principle can be revised to state that,fwith the possible~j

' exception of the detrimentsi eff6 cts ~of aging on th& fdrictionality:6f~5dhalni lant s

! structures, snd components in the periodi ~of extendedwoperst'dn StiiSr sfid

issuss related to safety 'only during extended operatidnf thdrbdulalbfpIb'f6csss r is'ME adequate to ensure that the licensing bases of all curientlylopeilstihkplaints proYid6sYsrid maintains an acceptabl6 level of ssfety; so that operation will not be inimical to public health and safety or common defenss and security. As modified, the Commission affirms its support of the first principle of license renewal, as well as the (unmodified) j second principle.

The second and equally important principle of license renewal holds that lhe plahi . .,

. ispecific licensing ba' sis must be msintainsd during' the rerisWsl (EirdT i jand to the same extent as during the' original licensing ternt . . . . . . The' Commission

, still believes that mitigation of the detrimental e#ects of aging resulting from operation beyond the initial license term should be the focus for license renewal. . . . . . !The , " l

Commission has concluded that, for certain plant systems, strui

tUrss, and components, j ,

!the existing regulatory process will continue to mitigste the. effects'oflasing;to providej,n.]

jacceptable level of safety in the period of exterided operatiolif J

98-056 Slide 11

l

, Life Cycle Management Project

! Presentation Outline Discuss the following:

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance

(5) Sections 2.0,2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3 l (8) Conclusions The Letter to NEl's Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 which deals with proposed staff guidance on addressing $54.21(c)(1)98-056 Slide 12

Life Cycle Management Project BGE EQ Position Relative to EO, there is no age-related degradation which occurs during the period

, of extended operation which is not addressed under the current license and BGE's existing EQ program:

Comparison of current license term and period of extended operation re: EQ (a) The intended function of EQ equipment for License Renewal is the same as the EQ function under the current license.

t (b) The normal environmental influences, e.g., aging, which could adversely affect the EQ function of 50.49 scoped equipment both during the current license term and the period of extended operation are included in the current qualification process.

(c) The accident induced environment is no different at the end of 60 years of operation vs. 40 years of operation.98-056 Slide 13

Life Cycle Management Project g BGE EQ Position (continued)

Relative to EQ, there is no age-related degradation which occurs during the period of extended operation which is not addressed under the current license and BGE's existing i EQ program Comparisan of current license term and period of extended operation re: EQ (d) EQ equipment can remain in place only as long as there is reasonable assurance that the EQ intended function will be maintained.10 CFR 50.49, DOR guidelines, and NUREG 0558 all require that aging be considered in the evaluation of the equipment. Prior to reaching the point in time when reasonable assurance expires, the equipment must be replaced, refurbished, retested, or subject to an ongoing qualification program.

(e) Current research associated with EQ focuses on condition monitoring, existing aging analysis methods, and equipment failure modes. These are not aging issues unique to the period of extended operation and no aging effects unique to the period of extended operation have been identified.98-056 Slide 14

! Life Cycle Management Project Conclusion

! Continued compliance with 10 CFR 50.49 is adequate

for maintenance of EQ intended functions for the period of extended operation

. Current regulations require that a plant maintain its EQ intended functions for as long as it operates

. There is no aging unique to the period of extended operation not addressed by current regulations Please note that this position on EQ remains unchanged and was formally presented to the NRC at a meeting on 10/16/96.98-056 Slide 15 y w - , w r- w wr wy.=y y

i l Life Cycle Management Project i

NRC SER on BGE Methodology l

3.8 Time-Limited Aging Analysis Evaluation 1

. The BGE process indicates that when extending an existing analysis or . . ,

l justifying that the existing analysis remains valid,ithe }echniquesLused to i perform these tasks are those widelya' cceptEd in the regu ations or O

! National codes and standardsLwhich govern theiT@.I The BGE i methodology cites the pressurized thermal shock rule (50.61) as an example. lThe staff finds this portion of the 5GE pr'6de'ss?acceptalslerc j however the staff wishes to clarify that the applicable analysis technique can be the one that is in effect in the plant's CLB at the time of renewal application.

i - _

98-056 Slide 16 1

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f 1

j [ Life Cycle Management Project l

Presentation Outline Discuss the following:

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance (5) Sections 2.0,2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3 (8) Conclusions

• The Letter to NErs Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 which deals with proposed staff guidance on addressing $54.21(c)(1)98-056 Slide 17

Life Cycle Management Project

~ BGE LRA Template Guidance

1. Scoping A. System / Structure / Component description B. Scoped SCs and their intended functions ll. Aging Management A. Potential / Plausible ARDMs B. Demonstration of Aging Management

1. SC materials and environment

2. Plausible aging mechanisms and their effects on SC functions

3. Methods to manage the ARDMs/ effects of the ARDMs

4. Identification and description of aging management programs

5. Summary of aging management conclusions 111. Conclusion IV. Reference List 98-056 Slide 18

[ Life Cycle Management Project .

Presentation Outline l Discuss the following:

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance (5) Sections 2.0, 2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3 (8) Conclusions

• The Letter to NEl's Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 which deals with proposed staff guidance on addressing 54.21(c)(1)98-056 Slide 19

, -_ __ ~ ._ _ _. _ _ _ _ -.._ _ , _ , . . _ - - - . - - .-

M Life Cycle Management Project Section 2.0 - Methodology

Subsection 6.1.3 Long-Lived EQ Components Explains the scoping of long-lived EQ components Subsection 6.3.5 Explains the aging management for aging issues associated with a GSI Subsection 8.0 Explains how TLAA are addressed in the LRA 98-056 Slide 20 g w +, e - -

m.-,. e -w ---

/

3 Life Cycle Management Project )

Section 2.1 - TLAA Subsection 2.1.3.1 Environmental Qualification This section explains:  !

(1) the regulatory bases of BGE's EQ program, (2) that equipment is replaced before the end of its qualified life (3) that such replacements are scheduled as part of the preventive maintenance program, and (4) that qualified life re-evaluations are an on-going activity

( This subsection directs the reader to Section 6.3 of the LRA for specifics. 3 K

98-056 Slide 21

w Life Cycle Management Project

~

BGE LRA Section 6.3 BGE demonstrates management of the effects of aging for the period of extended operation by providing a description ofits EQ program including the program's design bases and controls in accordance with template guidance for content.

6.3 Environmentally Qualified Equipment 6.3.1 Scoping 6.3.1.1 System Level Scoping 6.3.1.2 Component Level Scoping 6.3.2 The Aging Management Function of the EQ Program 6.3.2.1 ARDM Evaluation 6.3.2.2 CCNPP 50.49 Program Overview 6.3.2.3 Program Operating Experience and Design Basis 6.3.2.4 Aging Effects Management Methodology 6.3.2.5 Conclusion for the Aging Management Function of the EQ Program 6.3.3 The TLAA Function of the EQ Program 6.3.4 EQGSI 6.3.5 Conclusions 6.3.6 References98-056 Slide 22

Life Cycle Management Project BGE LRA Section 6.3 6.3.1 Scoping These sections explain that equipment included in the scope of this Section of the LRA includes all equipment designated as EQ (within the scope of 10 CFR 50.49) at CCNPP and which has a qualified life of 40 years or greater.

Eight EQ device types were identified.

Ref: Table 6.3.1 This portion of Section 6.3 satisfies the requirements of LRA Template Guidance for Section I- Scoping

)

t J J

98-056 Slide 23

Life Cycle Management Project 6.3.1.2 Component Level Scoping (excerpt)

The equipment which satisfies 10 CFR 50.49(b)(1) and (b)(2) is classified as safety-related and further designated as Class 1E on the Calvert Cliffs Q-List. The equipment which satisfies 10 CFR 50.49(b)(3) was identified in the CCNPP response to NRC Inspection and Enforcement Bulletin (IEB)79-018. This equipment is classified as safety-related and further designated as PAM1 or PAM2 on the CCNPP Q-List. Electrical equipment which is required to perform a safety-related function, after being subjected to, or while exposed to, harsh environmental conditions induced by DBEs, is further designated as 5049 on the Q-List. [ Reference 1, Section 1.2.2]

TABLE 6.3-1

SUMMARY

OF EQ DEVICE TYPES WITHIN SCOPE OF LICENSING RENEWAL Cables (CBL) Core Exit Thermocouple System (RI)

Current / Pneumatic Transducer (1/P) Seal (SEAL)

Junction Box (WRNMS) Solenoid Valve (SV)

Level Transmitter (LT) Terminal Block (TB)

Motors (M. MA. MB) Temperature Element (TE)

Valve Motor operator (MoVoP) Reactor Vessel Level Monitoring System In-Core Neutron Flux Monitoring Instrument Assembly (NE) Assembly (TP)

Containment Penetration Assembly (PEN) Temperature Switch (TS)

Pressure Transmitter (PT) Vibration Element (VE)

( Hydrogen Recombiner (RCMB) Vibration Signal Transmitter (VT)

\ Flow Transmitter (FT) Pressure Switch (PS)

)

Radiation Element (RE) Position Switch (ZS)98-056 Slide 24

Life Cycle Management Project BGE LRA Section 6.3

! 6.3.2 The EQ Program and Aging Effects Methodology 6.3.2.1 ARDM Evaluation This portion does the following:

(1) identifies the intended functions of long-lived EQ equipment Ref: Table 6.3-3 Meets requirements of LRA Template Guidance IB -intended functions (2) identifies potential and plausible aging mechanisms and aging effects on long-lived EQ equipment Ref: Table 6.3-2 Meets the requirements of LRA Template Guidance IIA and IIB 1/2 (3) identifies the aging management programs credited including pointers to other parts of the LRA as appropriate Ref: Table 6.3-4/5 and text of 6.3.2.1 relative to each of the (8) device types subject to AMR

. Meets the requirements of LRA Template Guidance IIB 3 98-056 Slide 25

Life Cycle Management Project TABLE 6.3-3 ,

DEVICE TYPE l INTENDED FUNCTION CBL Provide electrical continuity for the execution of safety-related functions under harsh INTENDED FUNCTIONS ' ass ci t with DBE occurring at the end of the plant's

• "',i'

c n ""lIr"e d h'ssN'I"Q) a FOR DEVICE TYPES WRNMS (1) Provide indication of reactor core neutron flux levels (Active).

REQUIRING AMR (2) Provide electrical continuity for the execution of safety-related functions under (eXCefpt) harsh environmental conditions associated with a DBE occurring at the end of the plant's licensed life (Passive-EQ).

PEN (EPA) (1) Provide elect:ical continuity for the execution of safety-related functions under harsh environmental conditions associated with a DBE occurring at the end of the plant's licensed life (Passive-EQ).

(2) Provide a containment pressure boundary function to prevent the release of fission products in the event of a DBE occurring at the end of the plant's licensed life (Passive-non-EQ).

R1(CETX) (1) Provide indication of reactor core exit temperatures (Active).

(2) Provide pressure seal at the reactor vessel (Passive-non-EQ).

(3) Provide electrical continuity for the execution of safety-related functions under harsh emironmental conditions associated with a DilE occurring at the end of the plant's licensed life (Passive-EQ).

SEAL Prevent moisture intrusion into splices, terminations, conduits, and equipment housings, under accident conditions, to protect cables and equipment relied upon to execute safety-related functions, under harsh environmental conditions, associated with a DBE occurring at the end of the plant's licensed life (Passive-EO).

SV (1) Open/close control of venting, sampling, and instrument air (IA) flow paths to support the execution of safety-related functions (Active).

(2) hiaintain system pressure boundary to support safety-related functions (Passive-non-EQ).

TB Provide electrical continuity for the execution of safety-related functions under harsh environmental conditions associated with a DilE occurring at the end of the plant's licensed life (Passive-EQ).

TP (RVLMS) (1) Provide indication of water level in the reactor vessel (Active).

(2) Provide pressure seal at reactor vessel (Passive-non-EQ).

(3) Provide electrical continuity for the execution of safety-related runctions under harsh environmental conditions associated with a DBE occurring at the end cf the plant's licensed life (Passive-EQ).98-056 Slide 26

Life Cycle Management Project TABLE 6.3-2 POTENTIAL AND PLAUSIBLE ARDMS FOR EQ DEVICE TYPES (excerpt)

EQ DEVICE TYPES StJBJECT TO AMR POTENTIAL ARDMs CHL PEN SEAL 3V TB TP RI WRNMS Cavitation Erosion Corrosion Fatigue x Crevice Corrosion x / / /

Erosion Corrosion x Fatigue x x Fouting x Galvanic Corrosion x General Corrosion / x x Ilydrogen Damage x x intergranular Attack x x Kapton Unique Aging /

Microbiologically-Induced Corrosion x x Oxidation x x Particulate Wear Erosion x Pitting x / / /

Radiation Damage / / / / / / / /

Rubber Degradation x Selective Leaching x Stress Corrosion Cracking x x Stress Relaxation x x Thermal Damage / / / / / / / /

Thermal Embrittlement x x Wear x 98-056 Slide 27

Life Cycle Management Project TABLE 6.3-4 AQiNG MANAGEMENT PROGRAMS FOR PLAUSIBLE PENETRATION (PEN) ARDMS (excerpt)

APPLICABI.E EQFS I AGING 51ECilANIShtS PIAUSIBLE AGtNG 51ECIIANIShi PROGRAh!

EPA 004 - Types 2A,2B, Radiation Damage No N/A 2C,2D,3A,3C, & 3E Thermal Damage No General Corrosion

• Yes PEG-7*, MN-3-100*,

QL-2-100

• EPA 004 - Type 3D Radiation Damage Yes CCNPP 50.49 Program Thermal Damage Yes General Corrosion

• Yes PEG-7*, MN-3-100*,

QL-2-100*

EPA 010 - Types 2A, 28, Radiation Damage Yes CCNPP 50.49 Program 4 A, 4 B Thermal Damage Yes General Corrosion

• Yes PEG-7*, MN-3-100*,

QL-2-100*

k 98-056 Slide 28

Life Cycle Management Project i

BGE LRA Section 6.3 6.3.2 The EQ Program and Aging Effects Methodology 6.3.2.2 CCNPP 50.49 Program Overview Provides a description of the EQ program including the scoping criteria, program bases, program elements, program controls, and documentation requirements Meets the requirements of LRA Template Guidance IIB 4 for existing programs 6.3.2.3 Program Operating Experience and Design Basis Provides EQ program design bases and operating experience Meets the requirements of LRA Template Guidance IIB 4 for existing programs 6.3.2.4 Aging Effects Management Methodology Describes how EQ program manages the effects of aging and the information contained in EQ Files Meets the requirements of LRA Template Guidance llB4 for existing programs

6.3.2.5 Conclusion for the Aging Management Function of the EQ Program Meets the requirements of LRA Template Guidance IIB 5 98-056 Slide 29

Life Cycle Management Project 6.3.2.2 CCNPP 50.49 Program Overview (excerpt)

Engineering procedures are in place to ensure the program is administered in accordance with 10 CFR 50.49 requirements and BGE quality assurance procedures. As required by 10 CFR 50.49, the aging of EQ equipment is addressed to ensure that, when exposed to harsh environmental conditions, the equipment will perform its intended function as required. The EQ Program at CCNPP is based on the following regulatory requirements: [ Reference 1, Section 1.2.1]

. Division of Operating Reactors (DOR) Guidelines as transmitted by NRC IEB 79-01B

. NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment

. 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants i

l 98-056 Slide 30 i

Life Cycle Management Project 6.3.2.2 CCNPP 50.49 Program Overview (excerpt continued)

The CCNPP 50.49 Program has the following elements: [ Reference 1, Section 1.2.1]

. Identification of the equipment that is required to be EQ per 10 CFR 50.49(b);

Establishment of documentation that substantiates EQ equipment is EQ;

. Establishment of a maintenance and surveillance program to ensure that qualification is maintained on a continuing basis;-and Establishment of procedures to describe the requirements and process for development and control of the EQ Program documentation.

i 98-056 Slide 31

.- _ _ . _ _ _ . _ . _ _ _ _ . _ . -_ . _ - _ _ .. . . _ . - ~.. _ _, -, .

Life Cycle Management Project 6.3.2.3 Program Operating Experience and Design Basis (excerpt)

The design basis for the EQ Program is NRC IEB 79-01B, applicable generic letters, and 10 CFR 50.49. Calvert Cliffs UFSAR Section 7.12

[ Reference 13] provides an overview of the program design basis requirements.

/

98-056 Slide 32

f Life Cycle Management Project T

6.3.2.3' Program Operating Experience and Design Basis (excerpt continued)

Design Basis Nuclear Regulatory Commission IEB 79-01B, issued on January 14,1980, along with Supplements 1,2, and 3, issued on February 29, September 30, and October 24,1980, respectively, and NRC Generic Letters 81-05,81-15, and 82-09 are the EQ Program design basis for:

. Identifying and environmentally qualifying safety-related electrical equipment required to function, while exposed to postulated harsh environment accident conditions, to bring the plant to its licensed ' safe shutdown' condition. Applicable safety-related electrical equipment relied upon, in emergency procedures, to mitigate the postulated accidents and applicable Three Mile Island Action Plan (NUREG-0737) equipment are also to be identified. (Accident conditions were defined in IEB 79 01B as being the result LOCA/HELB inside containment, including areas outside containment where fluids are recirculated to accomplish long-term cooling following a LOCA, and HELB ~outside containment.)

. Establishing the normal and accident environmental conditions for identified safety-related components.

• Establishing the requirements to be met for EQ ofidentified safety-related components.98-056 Slide 33

Life Cycle Management Projec 6.3.2.3 Program Operating Experience and Design Basis (excerpt continued) 10 CFR 50.49, issued January 21,1983 (effective date of February 22,1983),

is the EQ Program design basis for:

Identifying and environmentally qualifying 'important to safety' electrical equipment required to function while exposed to harsh environmental conditions during and following all applicable DBEs.

Identifying and environmentally qualifying certain post-accident monitoring equipment.

Establishing the requirements to be met for qualifying replacement EQ equipment installed subsequent to February 22,1983.

Notes: Operating reactors were not required to requalify electrical equipment important to safety in accordance with the provisions of 10 CFR 50.49 if the NRC had previously required qualification of that equipment in accordance with the requirements established in the DOR Guidelines or NUREG-0588.

10 CFR 50.49 stipulates that replacement equipment must be qualified to the provisions of 10 CFR 50.49 unless there are ' sound reasons' to the contrary. NRC Regulatory Guide 1.89, Revision 1, provides these sound reasons. If they are met, then qualification of the replacement equipment to the DOR Guidelines, or NUREG-0588, as applicable, is acceptable. This remains unchanged by the process of license renewal.98-056 Slide 34

Life Cycle Management Project 6.3.2.3 Program Operating Experience and Design Basis (excerpt continued)

Operating Experience Over the history of the program, EQ-related issues / problems have been identified by both the NRC and by BGE and its contractors as a result of audits, assessments, and day-to-day plant operation. -They have been documented in Nonconformance Reports, Issue Reports, and Program Deficiency Reports as part of CCNPP's deficiency identification and corrective action program.

In each case, the appropriate corrective action was taken as required.

j

)98-056 Slide 35

Life Cycle Management Project 6.3.2.3 Program Operating Experience and Design Basis (excerpt continued)

Baltimore Gas and Electric Company is a member of the Nuclear Utility Group on Equipment Qualification (NUGEQ). This industry group is comprised of the majority of nuclear utilities in the United States as well as Canada. This group is a working group comprised of technical personnel from each utility who are responsible for the EQ Programs at their plant. This group has, since the early 1980s, provided both technical and licensing support to its members specifically related to the EQ issue as it evolved. Collectively, the group represents the largest collection of EQ experts with the most extensive industry knowledge base in the country. Industry EQ problems and issues are typically addressed by this group, with each member utility benefiting from this knowledge base.

L 98-056 Slide 36

Life Cycle Management Project 6.3.2.4 Aging Effects Management Methodology (excerpt)

.-,..m..,,,.,

! Each EQF also contains the qualification criteria and'criteris justificE,tionior ths1 device covered,!the identification of the.qualifiestidli:sdu;r66l(10 CFR 50.49, '

NUREG-0588, or the DOR Guidelines),[oth'e'f s'tdhdsfdsithat are met in the qualification process (such as Institute of Electrical and Electronic Engineers ~

IEEE-323-1974),!the qualification Methodologyils'ed,] and[tKS jiistificstibiU6fth'e.i ;

~

i use of that methodology.s Acceptable methodologies, include testing, analysis, or analysis, derived from partial test data. lPhrf6riiiadd6 6fisf5ElirlilIbh[ die 5l507 l identified and verified as part of the qualification process to ensure that performance requirements are met. !Anomslids afi~eUiliislid]for impact on the qualification. The accident and normal service environmental conditions used in the qualification of equipment are documented in ES 014. [ Reference 4]

98-056 Slide 37

f  %

[ Life Cycle Management Project 6.3.2.5 Conclusion for the Aging Management Function of the EQ Program (excerpt)

As a regulatory based and monitored program, the CCNPP 50.49 Program has regulatory approval of its implementation, management, evaluation methodologies, surveillance provisions, and documentation as discussed in Section 6.3.2.3 of the BGE LRA. Based on this and the previous discussion, BGE concludes that the CCNPP 50.49 Program adequately addresses and manages the aging (thermal, radiological, and operational stressors) of EQ devices, which could prevent them from performing their required harsh environment safety functions during their qualified lives, in such a way that the intended functions of these devices will be maintained during the period of extended operation consistent with the current licensing basis (CLB) under all design loading conditions.

w 98-056 Slide 38

M Life cycie management Projec \

BGE LRA Section 6.3 6.3.3 The TLAA Function of the EQ Program Methodology for Extending Component Qualified Life Acceptance Criteria for Judging Adequacy of Components Corrective Actions if EQ Component Qualified Life Falls Short of Period of Extended Operation Timing of Resolution Conclusion of the Effectiveness of the TLAA Function of the EQ Program These sections were designed to meet the guidance then available for addressing TLAAs.

Ref: Extract from 6.3.3 98-056 Slide 39

Life Cycle Management Project

~

BGE LRA Section 6.3 (excerpt) 6.3.3 The TLAA Function of the EQ Program

. . . . . Whenever the Commission must find that actions "will be taken" rather than "have been taken," the NRC staff has indicated that the following information should be provided to support this finding:

. Details concerning the methodology which will be used for TLAA evaluation;

. Acceptance criteria that will be used to judge the adequacy of the component, consistent with the CLB, when the TLAA evaluation is performed;

. Corrective actions that CCNPP could perform to provide reasonable assurance that the EQ equipment will perform its intended function when called upon or will not be outside of its design basis, established by the plant's CLB; and

. Identification of when the completed TLAA evaluation will be submitted to the NRC to ensure that the necessary evaluation will be performed before any EQ components would not be able to perform their intended functions consistent j with the CLB /

98-056 Slide 40

Life Cycle Management Projec

~

BGE LRA Section 6.3 6.3.4 EQ GSI This section explains BGE's position relative to issue 168 of the NRC Task Action Plan relative to:

(1) Issues associated with the accelerated aging qualification process, (2) Issues associated with failure mechanisms of soeciel cables, (3) Issues associated with condition monitoring technigt.es, and (4) Conclusions of EQ GSI This section was designed to meet the available guidance on addressing GSis in an LRA. BGE chose the SOC option ofjustifying that the CLB willbe maintained until a point in time when one or more reasonable options would be available to adequately manage the effects of aging including a description of the program to maintain the CLB and the options available in the futu:4. BGE willcontinue to 1 comply with 10 CFR 50.49 and subsequent requirements for EQ applicable to  ;

BGE. /

98-056 Slide 41

1 Life Cycle Management Project GSI Relevant SOC Clauses:

IV(2)

. . . . . GSIs and USIs that do not contain issues related to the license renewal aging management review or time-limited aging evaluation are not a subject of review or finding for license renewal. . . . .

. . . . . ! An applicant may choose Io submit a fechnlcaI E$tioEale Which fdeblobstrates that,tlie CLB 'will be maintainedNINbinIbbI '

dhli[36 nidi.lSt'e l period of extencied' operation,' af which point 6he$r dib'rs reasonatilS'$kildfisd$

(e.g., replacement, analytical evaluation, or a surveillance / maintenance program)

~

[would beiavaiiatilE to adequatei[rhAnage tiis eifE(8(dd[56d (An applicant would have to describe its basis for concluding that the CLB is maintained, in the license renewal application, and briefly describe options that are technically feasible during the period of extended operation to manage the effects of aging, but would not have to preselect which option would be used) . . . . .

K 2 98-056 Slide 42

Life Cycle Management Projec 4

6.3.4 EQ GSI (excerpt)

According to the BGE IPA methodology and the Statements of Consideration to the License Renewal Rule (60FR22484), there are three options available to resolve issues associated with license renewal which are also the subject of a GSI. Those three options are listed in Sections 6.3.5 and 8.3.2 of the BGE IPA methodology as follows: [ Reference 1, Section 6.1]

If the issue is resolved before BGE LRA (LRA) submittal, the applicant can incorporate the resolution into the LRA; e

An applicant can justify that the CLB will be maintained until a point when one or more reasonable options would be available to adequately manage the effects of aging; or An applicant could develop a plant-specific program that incorporates a resolution to the aging issue.98-056 Slide 43

M Life cycie management project N

)

NRC June 2,1998 Guidance re: GSI 168*

. GSI 168 issues have not been defined to a point that an LR applicant can be reasonably expected to address these issues, specifically at this time

. An acceptable approach is to provide a technical rationale demonstrating that the CLB for EQ will be maintained in the period of extended operation

• Letter from NRC (Chris Grimes) to NEl (Doug Walters) v 98-056 Slide 44

Life Cycle Management Project N

)

Conclusions of EQ GSI (excerpt)

With regard to this GSI, BGE is opting for the second of the approaches discussed at the beginning of this section, in that it will continue to manage the effects of aging in accordance with the CLB, modified as appropriate to address regulatory changes. The current 40-year equipment lives are, therefore, adequate until the period of extended operation because, under the CLB, EQ equipment is qualified for 40 years using the currently acceptable techniques for calculating such lives.

(98-056 Siide 45

e-

, Life Cycle Management Project ,

BGE LRA Section 6.3 6.3.5 Conclusions Meets the requirements of LRA Template Guidance III 98-058 Slide 46

. _ _ _ - _ _ . - - _ - _ _ _ _ . - _ - . _ _ _ _ _ _ - _ . _ - _ _ - _ . . _ - _ . _m ___ -....__.... . _ _ _ . . _ _ _ - _____ _ _ _ . . _ _ _ - m. --. _. ________ _. _ ___ .-_____-- ______-._.._.-_.__m- - _- ___ ___

i M Life Cycle Management Project 6.3.5 [Overall LRA] Conclusions (paraphrased)

. This section of the BGE LRA does not change our CLB relative to EQ.

Calvert Cliffs will continue to function in the period of extended operation as it does today relative to EQ, except as required by changes to regulatory requirements.

. The CCNPP 50.49 Program has regulatory approval of its implementation, management, evaluation methodologies, surveillance provisions, and documentation

. Based on this and the discussion provided in the balance of Section 6.3.2, BGE concludes that the CCNPP 50.49 Program adequately addresses and manages the aging (thermal, radiological, and operational stressors) of EQ devices, which could prevent them from performing their required harsh environment safety functions during their qualified lives, in such a way that the intended functions of these devices will be maintained during the period of extended operation consistent with the CLB under all design loading conditions.98-056 Slide 47

Life Cycle Management Project 6.3.5 [Overall LRA] Conclusions (paraphrase continued)

. During the period of extended operation, EOFs which contain the TLAAs for EQ equipment will be maintained and controlled under the current EQ Program in the same manner they are maintained and controlled under the CLB, in accordance with 10 CFR 50.49.

. With regard to GSI 168, BGE is opting for the provision by which it is allowed to provide justification that the CLB will be maintained until a point when one or more reasonable options will be available to adequately manage the effects of

. cable aging.

. The program analyses / assessments, corrective actions, and confirmation /

documentation process for license renewal are in accordance with QL-2,

" Corrective Action Program." QL-2 is pursuant to 10 CFR. Part 50, Appendix B, and covers all structures and components subject to AMR.

)98-056 Slide 48

Life Cycle Management Project Presentation Outline Discuss the following:

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance (5) Sections 2.0,2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3 (8) Conclusions The l'etter to NEl's Mr. Douglas Walters from NRC's Christopher Grirnes dated September 23,1998 which deals with proposed staff guidance on addressing $54.21(c)(1)98-056 Slide 49

M Life cycie management Project

Proposed Staff Guidance

• on Addressing Q54.21(c)(1)

Staff guidance:

In accordance with @54.21(c)(1), "[a] list of time-limited aging analyses, as defined in @54.3 must be provided.

BGE response:

i . The TLAAs (identified by EQF numbers) for passive, long-lived EQ B

components are identified in Section 6.3 of the BGE LRA

. The following EQ files also contain 40-year life calculations

1 MTR003 MTR006 MTR049 MTR054 MTR001 MTR002 i MTR008 MTR057 MOV001 MOV002 HR0001 FT0001 HRRMS1 TC0001 RTD002 PS0011 VFM501 PS0008 ZS0007

. . The above list plus the TLAAs identified in Section 6.3 of the BGE LRA encompasses all EQ 40-year life calculations /

! \

98-056 Slide 50

/ M Life cycie management Project Proposed Staff Guidance

• on Addressing l g54.21(c)(1)

@54.21(c)(1)(i) "The analyses remain valid for the period of extended operation"

@54.21(c)(1)(ii) "The analyses have been projected to the end of the period of extended operation" 954.21(c)(1)(iii) "The effects of aging on the intended function (s) of EQ equipment will be adequately managed for the period of extended operation" BGE is implementing @54.21(c)(1)(iii) for EQ TLAAs i

4

• The Letter to NEl's Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 which deals with proposed staff guidance on addressing $54.21(c)(1)98-056 Slide 51

1

, M Life cycie management Projec Proposed Staff Guidance

• on Addressing

@54.21(c)(1)(iii) 10 CFR 50.49 allows five options for maintaining EQ intended functions. These options are reiterated in the proposed staff guidance

! (1) Replacement (2) Refurbishment (3) On-going Qualification ,

(4) Retest (5) Re-analysis BGE has not preselected or closed out any options allowed under 10 CFR 50.49.

Information is provided at a summary level for those options currently being use.d by i BGE. Currently BGE maintains EQ intended functions by replacement, refurbishment, and re-analysis. On-going qualification and retesting are allowed by 10 CFR 50.49, but BGE is currently not exercising these aging management options.98-056 Slide 52

1 Life Cycle Management Project l Proposed Staff Guidance

• on Addressing l Q54.21(c)(1)(iii)

Replacement, Refurbishment, On-going Qualification Program Options

) The proposed guidance states that, consistent with 10 CFR 50.49, an applicant has the option of managing the aging of EQ equipment by replacement or refurbishment at the end of qualified life or demonstrating by an on-going qualification program that additional life exists.

For those EQ TLAAs for which aging management will be accomplished by one of these options, the NRC has asked that the following information be provided:

(1) Those features related to aging considerations described in 10 CFR 50.49 (2) Decision criteria for replacing or refurbishing EQ equipment before the end of the equipment's qualified life. >

98-056 Slide 53

_ -~_

i i

Life Cycle Management Project Proposed Staff Guidance

• on Addressing

., $54.21(c)(1)(iii)

Replacement, Refurbishment, On-going Qualification Program Options

! BGE Response:

! (1) BGE identifies and evaluates all aging considerations and aging effects which are applicable to the equipment to ensure that its intended function is protected for EQ service conditions the equipment is required to endure. The applicable aging l considerations are documented in the applicable EQ File for the EQ equipment.

J 98-056 Slide 54 J

i

. _ . - _.- - _ _ . .m . . . _ , . _ . _ _ . -._ . - - , . , , - . . _ . . . _ . , _ , _ . . - . . _ , . . . , , . - . - ,

[f _

Life Cycle Management Project Proposed Staff Guidance

• on Addressing

$54.21(c)(1)(iii)

Replacement, Refurbishment, On-going Qualification Program Options BGE Response:

(2) No equipment may remain in place beyond its qualified life.

Prior to the end of the qualified life BGE is required to:

(a) replace the equipment, or (b) refurbish the equipment, or (c) institute an on-going qualification program, or (d) retest and requalify the equipment, or (e) re-analyze the qualified life.

When end-of-life is approached,10 CFR 50.49 allows any of the above options for maintaining the EQ intended function. The final choice will be based on viability and cost-effectiveness at the time.

Please note that BGE knows of no on-going qualification program with NRC and industry consensus at this time. Development of condition monitoring is a future option.

j 98-056 Slide 55

Life Cycle Management Project Proposed Staff Guidance

• on Addressing

Q54.21(c)(1)(iii)

Retesting Option

! The proposed guidance states that, consistent with 10 CFR 50.49, an applicant has the option of managing the aging of EQ equipment by retesting.

If an applicant chooses to rely on testing to maintain an EQ intended function, the NRC has asked that the following information be provided:

l (1) Describe the program consistent with the guidance in IEEE 323-19'/4, Section G.6 (1) or (2),

(2) Current qualified life, and (3) Period of time prior to the end of qualified life when testing will be completed.

BGE does not currently rely on testing to maintain EQ intended functions. No i

decision has been made regarding what EQ equipment will be subjected to retest.

This decision, as previously noted, is based on viability and cost-effectiveness at the time.

Y 98-056 Slide 56 w- 3 . , , . .,,,-.m.- ....y --

, ,,,,,--,r--r. .y v _M

1 i

Life Cycle Management Project l Proposed Staff Guidance

• on Addressing Q54.21(c)(1)(iii) l Re-analysis Option To meet the requirements of @54.21(c)(1)(iii), the NRC has asked that

the following information be provided relative to EQ TLAAs which will undergo re-analyses

(1) Describe analytical methods to be used in re-analyses including data

collection and reduction methods,

(2) underlying assumptions, l (3) acceptance criteria, I

(4) corrective actions if acceptance criteria are not met, and (5) period of time prior to the end of qualified life when re-analyses will be '

completed.

The following slides direct you to the applicable sections of the LRA where the requested information is provided at a summary level. Re-analysis is an on-going activity of BGE's EQ program.98-056 Slide 57

. . , - . - . , . . , . _ . _ ._.-.._.,,.,..,,.__m.,m. , v,-, , , . , . .,-,,.,_,..c,, ..-.x_,_m.._.,_,,__y.._y., , , - .- , .,, .y... x . ,,

i M Life Cycle Management Project

~

i ltem (1)

Analytical Methods The information requested under item (1)is provided in summary form in the BGE LRA Section 6.3:

Pages Paragraphs 6.3-9 Paragraph beginning with:

"The equipment within the scope of the CCNPP 50.49 Program . . . . "

6.3-14/15 Each EQF also contains ... the qualification methodology used, and the justification for the use of that methodology. Acceptable methodologies, include testing, analysis, or analysis derived from partial test data.

Performance characteristics are also identified and verified as part of the qualification process to ensura that performance requirements are met.

Anomalies are. evaluated for impact on the qualification.

Paragraph beginning with:

" The identification of materials susceptible to significant thermal . . . . "

t 6.3-16/17 First two paragraphs under

\v Methodology for Extending Component Qualified Life 98-056 Slide 58

N 4

Life Cycle Management Project Item (2)

Underlying Assumptions 1

The information requested under item (2) is provided in summary form in the BGE LRA Section 6.3:

Pages Paragraphs

, 6.3-9 The paragraph beginning with:

"The CCNPP 50.49 Program considers exposure to harsh . . . ."

6.3-15 The accident and normal service environmental conditions used in the qualification of equipment are documented in ES-014.

Activation energies, and their source, as well as radiation thresholds, and their source, are identified.98-056 Slide 59

Life Cycle Management Project item (3)

Acceptance Criteria The information requested under item (3) is provided in summary form in BGE LRA Section 6.3:

Pages Paragraphs 6.3-14 Each EQF also contains the qualification criteria and criteria justification for the device covered.

6.3-17/18 Section entitled:

Acceptance Criteria forjudging Adequacy of Components98-056 Slide 60

Life Cycle Management Project item (4)

Corrective Actions

, The information requested under item (4) is provided in summary form in BGE LRA Section 6.3:

Pages Paragraphs 6.3-18 Section entitled:

i Corrective Actions if EQ Component Qualified Life Falls Short of Period of Extended Operation J

j 98-056 Slide 61

x Life Cycle Management Project i

item (5)

Schedule for Re-analyses BGE addresses the issue of the timing of re-analyses in BGE LRA Section 6.3:

Pages Paragraphs 6.3-18 Section entitled:

Timing of Resolution j

98-056 Slide 62

Life Cycle Management Project r

l Presentation Outline Discuss the following:

(1) Requirements of 10 CFR 54 (2) Relevant Statement of Consideration sections (3) BGE Position on EQ i

(4) BGE LRA Template Guidance (5) Sections 2.0,2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEI 95-10, sections 4.2.1.2 & 4.2.1.3 (8) Conclusions The Letter to NErs Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 /

which deals with proposed staff guidance on addressing $54.21(c)(1)98-056 Slide 63

Life Cycle Management Project NEl 95-10 4.2.1.2 Identify Plant Aging Management Programs Features of aging management programs to be considered include:

! Preventive actions to mitigate aging Parameters monitored, inspected, or tested Action or alert levels Corrective actions

, Confirmation of corrective actions Program administrative controls 4.2.1.3 Demonstrate That the Effects of Aging Are Managed Elements to be included in review checklist:

Program scope includes SC subject to AMR I

Aging effects detected before loss of intended function i

Acceptance criteria provided i

Monitoring and trending to ensure timely corrective actions Program is administratively controlled 98-056 Slide 64

f Life Cycle Management Projec NEl 95-10

. BGE's EQ program is administratively controlled to ensure that EQ intended functions are maintained for as long as the plant operates.

. Expiration of qualified lives initiate corrective actions.

. Corrective actions may include any of the options currently available under 10 CFR 50.49

. The EQ program includes, where necessary, maintenance activities to ensure the validity of qualified lives.

. Inspection, testing, and monitoring of installed EQ equipment is limited and not credited for maintenance of EQ intended functions. Any problems will result in initiation of BGE's Corrective Action Program.98-056 Slide 65

t M Life Cycle Management Project Presentation Outline

Discuss the following

(1) Requirements of 10 CFR 54 1

(2) Relevant Statement of Consideration sections (3) BGE Position on EQ (4) BGE LRA Template Guidance (5) Sections 2.0,2.1, and 6.3 of the BGE LRA (6) Proposed Staff Guidance on TLAA for EQ*

(7) NEl 95-10, sections 4.2.1.2 & 4.2.1.3 (8) Conclusions

• The Letter to NEl's Mr. Douglas Walters from NRC's Christopher Grimes dated September 23,1998 which deals with proposed staff guidance on addressing @54.21(c)(1)98-056 Slide 66

~ >

Life Cycle Management Project Conclusions

] (1) BGE continues to believe that there are no EQ issues unique to License Renewal since the intended functions, aging effects, and methods for managing expiration of qualified lives applicable to the current license term carry over unchanged to the period of extended operation (2) BGE has chosen S54.21(c)(1)(iii) and has demonstrated that aging will be managed by continued compliance with 10 CFR 50.49 via its existing EQ Program. All options allowed by 10 CFR 50.49 for maintaining EQ intended functions are available to BGE for the current license term and the period of extended operation.

(3) BGE has described its EQ program including bases and controls in Sections 2.0 (Methodology),2.1 (TLAA), and 6.3 (EQ) of the LRA.

(4) BGE has provided in summary form the information identified in the most recent proposed NRC staff guidance for EQ TLAAs.

(5) Although NEl 95-10 was not approved guidance for executing Part 54 and developing an LRA, BGE believes it meets the intent of 4.2.1.2 and 4.2.1.3 relative to EQ TLAAs.98-056 Slide 67

- .