3F1297-40, Responds to Verbal NRC RAI Re CR-3 Svc Water Temperature Calculation Containing non-conservative Assumptions

Responds to Verbal NRC RAI Re CR-3 Svc Water Temperature Calculation Containing non-conservative Assumptions

ML20203D680
Person / Time
Site:	Crystal River
Issue date:	12/11/1997
From:	Grazio R FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F1297-40, GL-91-18, NUDOCS 9712160261
Download: ML20203D680 (14)

Text

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Florida l

Power

?R. M M

• Z;#E.'%

o onn December 11, 1997 3F1297-40 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Additional Information on the Service Water Temperature Calculation Containing Non-Conservative Assumptions

References:

1. FPC to NRC letter, 3F0997-09, dsted September 10, 1997, Licensee Event Report (LER) 97-025-00 Service Water (SW) Raw Water (RW)

Temperature Calculation Contains Non-Conservative Assumptions

2. FPC to NRC le.ter, 3F1297-01, dated December 5,1997, Licensee Event Report (LER)97-02F 01, Service Water (SW) Raw Water (RW)

Temperature Calculation Contains Non-Conservative Assumptions

Dear Sir:

The purpose of this letter.is to respond to a verbal NRC Request for Additional Information relative to the Crystai River Unit 3 (CR-3) Service Water Temperature Calculation Containing Non-Conservative Assumptions. During a December 8,19W7, telephone conversation, the NRC requested a copy of the Justification for Continued Operation (JCO) that would allow CR-3 to restart ano operate prior to corre>9ing the condition reported in the above refeienced LERs. A copy of this JCO is attact'ed to this letter.

In Reference 2, Florida Power Corporation stated that an evaluation would be prepared j that would permit plant operation below a maximum Ultimate Heat Sink (UHS) temperature of 79.9 degrees F. The operability of tne SW and RW systems has been .I demonstrated below this temperature end is documented in the attached JCO. This JCO was prepared consistent with the guidance provided in Generic Letter 91-18, Revision 1, "Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconfomling Conditions."

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5 No new commitments are made in this letter.

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. m. u, 9 CRYSTAL RIVER ENERGY COMPLEX: 15760 W. Power une Stro(

• Crystal Fhver, Florida 344284708 - (352) 795-6486 sa cornpaq 9712160261 971211 PDR ADOCK 05000302 8 FM

I I U.S. Nuclear Regulatory Commission 3F1297-40 Page 2 If you have any questions concerning this response, please contact Mr. David Kunsemiller, Manager, Nuclear Licensing at (352) 563-4566.

Sincerely, a LLt 'b 0 W Robert E. Grazio, Ditector Nuclear Regulatory Affairs REG:pei Attachment xc: Regional Administrator, Region 11 NRR Project Manager Senior Resident Inspector l

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DEFICIENCY REPORT INSTRUCTIONS Precursor Number; 3 C97-5265 Work Request:

Safety Class: Safety Code Class: 2 Repair, other than original design [ ]

Use-As-Is [ ]

Interim Use-As-Is [ /) Expiration /re evaluation date 6/1/98 Rework (only applicable for ASME Code Class 1, 2 or 3 components) [ ]

Engineering SA/USQD Attar: sed [ /) N/A [ ]

Justification:

This is Revision 1 of the OR on the " Reduction in Ultimate Heat Sink Operability Temperature."

Revision 0 of the JC0 and SA/USQD were approved on 11/22/97. As a result of comments from the NCRC. the JC0 and 5A were r evised.

The engineering just1fication is in the attached revision 0 of the approved OR.

The JC0 and SA/USQO are now revision 1.

C. C. Ward / o- d. p -W Orig s na tor /.2- f7 Date T. R. Powers /

Verification Engineer / J 97 Date C. L. Miller / '

Engtneering Super'v~tsor 2-Date NA Qualt ty Systens (as required)

Date NA ,

ANil (a require Date

?Wosn. , .

y /1/Wf) remg 'fds Fequired) Date PRC ing humber Yl$

ADNQ dem fM llo (as required) / 7 /z./17 '

sl;)hn Date '

CP-111 Rev. 61 Page 1 (LAST PACE) '

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Justification for Continued Oncration Reduction in Ultimate Heat Sink Oncrability Temperature Revision 1 (W

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c (f LO Description and Purpose During the evaluation of Restart Item D-28, "Further Evaluation of Variables Used in Senice Water Heat Exchanger (SWHE) Blockage Calculation," enginecting discovered the analyses performed in 1987 to support the increase in design basis seawater (UHS) temperature from 85 to 95 'F were deficient.

The degraded condition centers around the limited ability of the SWHE to transfer post-accident heat loads from the Nuclear Senices Closed Cycle Cooling Water system (SW) to the Nuclear Senices Seawater system (RW). For the limiting Loss of Coolant Accident (LOCA), SW could rernove more heat from containment through the Reactor Building (RB) fan coolers than the RW system can remove from SW. This mismatch in heat removal results in SW temperature exceeding its design limit of I10' F. The equipment cooled by SW could fail to perform its safety function if the SW dasign temperature is exceeded.

~The purpose of this JCO is to allow startup and continued operation with SW, RW and -

Ultimate Heat Sink (UHS) that are OPERABLE, but not fully qualified. Operation will be allowed only while UHS temperatures remain below the limits specified in OP-103B, Curve 15 (maximum temrerature 79.9 F), until a modification is installed that will permit operation with UHS temperatures up to the current Improved Technical Specifications (ITS) Limit of 95.0 F.

2.0 Safety C!assification The SW, RW and UHS are safety-related systems designed and required for acciaent mitigation. .

3.0 Licensine Basis Proposed 10CFR50 Appendix A," General Design Criteria far Nuclear Power Plant Construction Permits" (July 11,1967), Criterion 52, " Containment Heat Removal Systems" requires a minimum of two different systems to remove heat and prevent containment pressure from exceeding its design pressure following an accident. The RB Spray and RB Ventilation are the systems responsible for meeting the requirements of this criterion.

The FS AR identifies three acceptable RB fan cooler and RB Spray combinations to limit post-accident ambient pressures and temperatures in the RB as follows:

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PC C 3-C97-5265 Page1ofIi 12/2/97 l

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e Justification for Continued Operation Reduction in Ultimate IIcat Sink Operability Temperature Revision 1 3.

1) one RB Spray train and one RB fan cooler (the Design Basis LOCA evaluation is based on this combination), or

2) Two RB Spray trains, or

3) two RB fan coolers and one RB Spray train.

The NRC Safety Evaluation Report (SER), dated July 5,1974, concluded the containment heat removal systems were acceptable in providing adequate heat removal capability following a LOCA. The NRC stated the one RB spray, one RB fan cooler and the two RB Spray cases (numbers 1 and 2 above) were both acceptable means of maintaining post-accident RB temperature and pressure below design requirements.

The NRC acceptance criteria did not include the two RB fan cooler, one RB Sprif scenario (number 3 above), therefore, this case can be removed from the FSAR wi ..out NRC concurrence. THs change to the FSAR will be required as part of the modification MAR 97-09-05-01. RB Fan Run Logic.

There are three installed RB fan coolers, but operation is currently restricted to two at any one time due to limitations on emergency power supply and SW system heat load. The third RB fan cooler is maintained isolated and unavailable. This design basis change was -

documented in LER 94-014-00.

The original design basis assumed an 85 F UHS temperature which resulted in a peak SW temperature of 105 F. UHS temperatures routinely surpass 85 F in the summer, therefore, the license and the analysis needed to be modMed.

Licensing Amendment 109 ',2/14/89) changed the UHS temperature from 85 F to 95 F.

The analysis that accompanied Licerse Amendment 109 assumed only one SW pump and one RW pump were running, and the Reactor Building fan coolers were operating at the maximum design fouling iactor. The FSAR analysis was also revised to incorporate the 95"F maximum UHS temperature.

A UHS temperature of 95 F results in a peak SW temperature of 110 F. The maximum UHS temperature of 95 F is required to be verified every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by Improved Technical ~

Specifications (ITS) Surveillance Requirement 3.7.I1.2.

To account for levels of blockage on the RW side of the SWHE and the corresponding reduction in heat transfer capability, OP-103B, " Plant Operating Curves," Curve 15, "SW System Heat Transfer Capability," was created This curve applies administrative limits on UHS temperature to ensure r.dequate SW cooling is available post-LOCA. As blockage inceases, the allowable UHS temperature decreases. If the UHS temperature exceeds the l

curn limits, then the required actions ofITS 3.7.11 are performed. The ITS limit of 95 F is only applicable at 0% blockage.

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l PC #: 3-C97-5265 Page 2 of 11 t2/2/97

( Justification for Continued Operation I

Reduction in Ultimate IIent Sink Onerability Temperature Revision 1

- 4'.0 Description ofIdentified Conce:n .

Previous analyses (including original SW systerr. design and sizing studies) assumed the RB fan coolers operated in the worst case degraded (maximum fouling factor) condition and the fan coil coeling water (SW) flow: ate was at the minimum design point of 1780 gpm. With these assumptions, SW was espable of removing the design heat load. These assumptions are conservative with respect to the containment peak temperature and pressure analysis but not for the maximum SW load calculation. Recent analyses have shown the SW system becoming overloaded due to excessive heat removal from the RB by the RB fan coolers following a postulated LOCA.

After a LOCA, the maximum allowable SW temperature could be exceeded if the following conditions exist: the RB fan coolers are actually in a cler_n (fouling factor =

0.000), non degraded condition; two SW pumps are providing greater than 2000 gpm to each RB fan cooler; and one RW pump is in senice (the single failure of the second RW pump is limiting for this scenario). These conditions result in a considerably greater predicted heat transfer rate from the RB atmosphere into SW via the RB fan coolers At high UHS temperatures, the additional heat load in the SW system exceeds RW system capacity and causes the SWHE outlet temperature (returning to SW loads) to exceed the -

110 F limit. Exceeding the SW design basis temperature could cause the failure of the SW cooled loads and lead to unacceptable accident mitigation capability.

Analyses have s' awn, for two RB fan coolers with minimum fouling factors and SWHEs with zero blockage, the maximum allowable UHS temperature is 79.9 F. If only one RB fan cooler is in sersice, the allowable UHS temperatur 3 increases to 95.0 F due to the decreased heat load. However, as the blockage of the SWHE increases, the maximum ,

allowable UHS temperature decreases due to the decrease in RW flow. For example, if two RB fan coolers are in service, with 20% blockage, the maximum allowable UHS temperature is 75.0 F. With only one RB fan cooler in service, and the same level of blockage, the maximum allowable UHS temperature is 92.2 F. Higher levels of blockage will result in ever lower acceptable UHS Temperatures.

1 1 5.0 Impact Analysis and Reliability Considerations Surveillance Requirement SR 3.7.11.2 requires UHS temperature to be equal to or less than 95 F in order to be OPERABLE. If UHS temperature exceeds 95 F then the UHS is not OPERABLE and the required action is to be in MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> In the current RB fan cooler ES logic configuration, two fans will start on an ES signal E cen with minimum SWHE tube blockage, the SWHE outlet temperature could exceed 110 F if the UHS temperature is above 79.9 F. Therefore, plant operation could be within Technical Specification limits but outside the safety analpis. This condition is a nonconformance and was reported in LER 97-025-00.

PC #: 3-C97-5255 Page 3 of 11 12/2/97

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Justification for Continued Operation l

Reduction in Ultimate Heat Sink Operability Temperature Revision 1

. 6.0 Operability Determination ,

Calculation hi94-0056, " Allowable SWHE Tube Blockage vs. UHS Temperature," was revised to account for the RB fan coolers with minimur.1 fouling factors. Based on this calculation, the UHS is OPERABLE and two fan operation is acceptable as long as the UHS temperature is below the limits listed in h194-0056, however, the system is considered "not fully qualified" since it cannot perform its required function at all licensed plant conditioWap to 95 F).

The SW and RW systems are also OPERABLE but not fully qualified since they are not capable of transferring post-accident heat loads to the UHS unoer all required conditions.

7.0 Justification for Continued Operation Calculation h194-0056, " Allowable SWHE Tube Blockage vs. UHS Temperature," has been revised to account for higher SW flow and cleaner RB fan coolers. The calculation evaluated various levels of blockage on the RW side of the SWhF. For one RB fan in operation and 0% blockage the maximum allowable UHS temperature is 95 F. For two -

RB fans in operation (current design) a maximum UHS temperature of 79.9 F will be allowed.

OP-103B, Curve 15 will be rmised to account for the reduced allowable UHS temperatures from h194-0056. These reduced administrative limits in OP-103B, Curve 15 (maximum temperature 79.9 F), will remain in effect until modification (hiAR 97-09 01) is install:d to limit operation to one RB fan cooler following a LOCA. After the modification is innalled, OP-103B Curve 15 will be revised to the previous limits which correspond to an allowable maximum UHS temperature of 95 F (ITS 3.7.11.2 limit).

Four regions are identified on OP-103B Curve 15: ' A', 'B', 'C' and 'D.' Region A and B are below the SWHE operability curve and Region C and D are above the curve. If a SWHE is fcund in the Region B, C or D, or the blockage exceeds 20%, then corrective actions are initiated. Actions include, cleaning one or more SWHEs and determining if the overall system blockage versus UHS temperature is above or below the operability curve.

If the determination finds the system is operating in the Region C or D then the requirements ofITS 3 't.11 are initiated.

Based on operating experience, each SWHE typically has approximately 20% tube blockage depending on the length of time since it was cleaned and the amount of debris i

picked up by the RW system. Each of the four SWHEs are cleaned approximately once I per month (one per week). At this cleaning frequency, it is reasonable to assume that an average of 20% SWHE blockage can be maintained.

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..% B Justifhstion for Continued Operation Reduction in Ultimate Heat Sink Operability Temperature Revision !

If SWHE blockage exceeds 20%, cleaning frequency will be increased. This additional restriction is based on the fact that at 20 % blockage, the maximum allowable UHS temperature is 75.0*F, which has been determined to be adequate to allow continued operation past mid-Mar.:h. Blockage in excess of 20% (for all SWHE) could lower the allowable UHS temperature tc less than actual UHS temperature and result in a plant shutdown prior to the requested NRC approval date for the corrective MAR.

Another consideration, during the interim before MAR 97-09-05-01 is installed, is the measurement of UHS temperature. When performing surveillance requirement 3.7.11,2, the UHS temperature is normally taken from RW-19-TI, RW Pump Discharge Header.

During normal operation the 'B' train RW system intake water is maintained at approximately 78 F to prevent thermal shock to SW equipmen: (this is not a concern post-accident because the recirculation flow is terminated on a start ofRWP-2A or RWP-3B). Due to the elevated temperatures caused by the recirculation of RW, this indication is not an accurate measure of the true UHS temperature. The elevated RW temperature would not meet the more stringent limits set out in OP-103B Curve 15.

During the implementation of the Contingency Actions, to get an accurate measurement of '

the UHS temperature, CR-3 will measure the Circulating Water (CW) inlet temperature. -

CW is not maintained at a temperature above actual intake canal water temperature.

Therefore, this is a truer measurement of UHS tempere.ure. The measurement will be made locally on indicators mounted in thermal wells on each CW inlet line into the Main Condenser. Each gauge is calibrated and has an accuracy of 1 F. This location was selected for its accessibility.

Due to gauge inaccuracies and different tempe'sture rises across the RW and CW pumps, the CW temperature gauges will only be used up to a temperature or 75 F. Above this temperature, high accuracy measuring devices will be used at the intake structure, upstream of the RW pumps. To account for instrument inaccuracies and the heat rise across the RW pump, the maximum calculated temperature rise across the RW pump and the instrument tolerance will be added to the measured temperature. This corrected temperature will then be used to verify compliance with the administrative UHS limit.

The SW and R~W systems are capable of removing post-accident heat loads while UHS temperatures are below the limits specified in M94-0056. Therefore, continued operation below these temperatures are acceptable for MODES 1,2,3 and 4. The concern with the UHS temperature is not valid in MODES 5 and 6 since a high-energy LOCA is not possible in these MODES.

PC #: 3-C97-5265 Page 5 of 11 t2/2/97

,lustification for Continued Operation Reduction in Ultimate IIcat Sink Operability Temocrature Revision 1 h -

7,1 Summary of Contineeney Actions ,

A. Administratively reduce SR 3.7.11.2 limit from 95 F to 79.9"F B. Revise OP-103B, Curve 15 to account for the reduced allowable UHS temperatures at various blockage levels (Attachment C). In the " Notes" l section for Curve 15, note 6.c will be revised from 40% to 20% blockage and note 7 will be revised from E0% to 70% blockage.

C. Revise SP-300, Sequence # 89, to take the UHS temperature at CW-1-TI, CW-3-T1, CW-5-TI and CW-7-TI. The highest reading of the four instruments will be recorded. The maximum tolerance of 90 F will be reduced to 75 F.

D. If the SP-300 maximum tolerance of 75 F is exceeded, then high accuracy temperature measuring equipment can be used to monitor the temperature of the UHS at the intake stmeture. This temperature should be taken approximately 18" below the surface and as close to the intake of the RW pumps as possible. To ensure the administrative limit of 79.9 F is not -

exceeded the instrument error shall be added to the temperature measurement.

UHS temperature is usually taken on the discharge header of the RW pumps. -

Taking the temperature at this location accounts for the heat added by the pump. The temperature rise across the pump is 0.20 F (Ref.12). To account for this rise, an additional 0.20 F will be added to the intake temperature measurement.

Therefore, the recorded UHS temperature shall be the measured temperature, plus the instrument error, plus 0.20 F to account for pump heat. As an eumple:

Measured Temperature = 77 F Instrument Accuracy = 0.5 F Pump Heat Correction = 0.20 F The UHS te;nperature would be recorded as, UHSr , = (77 F) + (0.5 F) + (0.20 F}

, UHST,mp =1' .

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PC #: 3-C97 5263 Page 6 of i1 12/2/97 l

Justification for Continued Operation f Reduction in Ultimate Heat Sink Operability Temperature Revision 1 I, *:

8.0 Corrective Action to Obtain Full Oualification As an interim inethod of restoring quelification, a modification (MAR 97-09-05-01, RB Fan Run Logic) will be installed that will allow one and caly one RB fan to star on an ES signal. This change will limit the heat load on the SW system such that the RW system can reject enough heat to maintain the SW system below 110' F with UHS up to 3 temperature of 95.0" F.

The proposed change to the RB fan run logic has been determined to constitute an Unreviewed Safety Question (USQ). Therefore, NRC approvalis required before implementation of the modification. FPC will request that the NRC approve the USQ by February 13,1998, to allow implementation of the mooification before UHS temoeratures rise above the limits set out in OP-103B, Curve 15. Per the attached graph, UHS temperatures generally rise to unacceptable levels after mid-March-Due to the complexity of this issue, FPC will perform a study f : valuate the RB fan logic modification and other alternatives to restore full qualification .., the RW system. This resiew will be complete in the second quarter 1998. l I

PC #: 3-C97 5265 PaFe 7 of i1 12/2/97

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. .. Justification for Continued Operation  ;

Reduction in Ultimate Heat Sink Operability Temocrature 1 Revision 1

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9.0 References ,

1. Safety Evaluation by the Directorate ofLicensing U. S. Atomic Energy Commission in the Matter of Florida Power Corporation Crystal River Unit 3 Docket No. 50-302, July 5,1974.

2. Licensee Event Report (LER) 50-302/97-025-00, September 10,1997.

3. NRC to FPC letter dated February 14,1989, " Crystal River Unit 3 - Issuance of Amendment RE: Ultimate Heat Sink Temperature (TAC No. 69298)."

4. Improved Technical Specifications (ITS), Amendment No.149.

5. Final Salety Analysis Repo" (FSAR), Revision 23.

6. MAR 97-09-05-01, "RB Fan ES Run Logic," Revision 0.

7. Proposed 10CFR50.34 Appendix A, " General Design Criteria for Nuclear Power Plant Construction Permits," July 11,1967. -

8. EDBD for the Nuclear Services C!osed Cycle Cooling Water System (SW), Revision 3.

9. EDBD for the Nuclear Services and Decay Heat Sca Water System (RW), Revision 3.

10. EDBD for the Reactor Building Air Handling System (AH-XA-XB), Revision 3.

I 1. FPC calculation M94-0056, " Allowable SWHE Tube Blockage vs UHS Temperature," Revision 4.

I

12. FPC calculation M97-0133, " Evaluation of UHS Temperature for Restart Item D-28,"

Rev. O.

10.0 Attachments andicLres Attachment A - SW Ske+ch l- Attachment B - UHS Temperature

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. PC #: 3-C97-5265 - Page 8 of i1 12/2/97 i

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Reduction in Ultimate Heat Sink Operabihty Temperature Revision 1 i.c ,, .

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