ML060370491
| ML060370491 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/09/2006 |
| From: | Lyon C Plant Licensing Branch III-2 |
| To: | Koehl D Nuclear Management Co |
| lyon C, NRR/DORL, 415-2296 | |
| References | |
| GL-04-002, TAC MC4705, TAC MC4706 | |
| Download: ML060370491 (10) | |
Text
February 9, 2006 Mr. Dennis L. Koehl Site Vice President Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241-9516
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2: REQUEST FOR ADDITIONAL INFORMATION RE: RESPONSE TO GENERIC LETTER 2004-02, POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN-BASIS ACCIDENTS AT PRESSURIZED-WATER REACTORS (TAC NOS. MC4705 AND MC4706)
Dear Mr. Koehl:
On September 13, 2004, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, as part of the NRCs efforts to assess the likelihood that the emergency core cooling system (ECCS) and containment spray system (CSS) pumps at domestic pressurized water reactors (PWRs) would experience a debris-induced loss of net positive suction head margin during sump recirculation. The NRC issued this GL to all PWR licensees to request that addressees (1) perform a mechanistic evaluation using an NRC-approved methodology of the potential for the adverse effects of post-accident debris blockage and operation with debris-laden fluids to impede or prevent the recirculation functions of the ECCS and CSS following all postulated accidents for which the recirculation of these systems is required, and (2) implement any plant modifications that the above evaluation identifies as being necessary to ensure system functionality. Addressees were also required to submit information specified in GL 2004-02 to the NRC in accordance with Title 10 of the Code of Federal Regulations Section 50.54(f). Additionally, in the GL, the NRC established a schedule for the submittal of the written responses and the completion of any corrective actions identified while complying with the requests in the GL.
By letter dated March 7, 2005, as supplemented by letters dated July 18 and September 1, 2005, Nuclear Management Company, LLC provided a response to the GL. The NRC staff is reviewing and evaluating your response along with the responses from all PWR licensees. The NRC staff has determined that responses to the questions in the enclosure to this letter are necessary in order for the staff to complete its review. Please note that the Office of Nuclear Reactor Regulations Division of Component Integrity is still conducting its initial reviews with respect to coatings. Although some initial coatings questions are included in the enclosure to this letter, the NRC might issue an additional request for information regarding coatings issues in the near future.
D. Koehl Please provide your response within 60 days from the date of this letter. If you have any questions, please contact me at (301) 415-2296.
Sincerely,
/RA/
Carl F. Lyon, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301
Enclosure:
Request for Additional Information cc w/encl: see next page
- per e-mail OFFICE LPL3-1/PM LPL3-1/LA DSS/SSIB DCI/CSGB LPL3-1/BC (A)
NAME FLyon DClarke DSolorio*
EMurphy*
TKobetz DATE 2/9/06 2/9/06 2/6/06 2/8/06 2/9/06
Point Beach Nuclear Plant, Units 1 and 2 cc:
Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Mr. F. D. Kuester President & Chief Executive Officer WE Generation 231 West Michigan Street Milwaukee, WI 53201 Regulatory Affairs Manager Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Mr. Ken Duveneck Town Chairman Town of Two Creeks 13017 State Highway 42 Mishicot, WI 54228 Chairman Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Resident Inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, WI 54241 Mr. Jeffery Kitsembel Electric Division Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Nuclear Asset Manager Wisconsin Electric Power Company 231 West Michigan Street Milwaukee, WI 53201 Michael B. Sellman President and Chief Executive Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 Douglas E. Cooper Senior Vice President - Group Operations Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Site Director of Operations Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241
ENCLOSURE GL 2004-02 RAI Questions Plant Materials 1.
(Not applicable).
2.
Identify the amounts (i.e., surface area) of the following materials that are:
(a) submerged in the containment pool following a loss-of-coolant accident (LOCA),
(b) in the containment spray zone following a LOCA:
- aluminum
- zinc (from galvanized steel and from inorganic zinc coatings)
- copper
- carbon steel not coated
- uncoated concrete Compare the amounts of these materials in the submerged and spray zones at your plant relative to the scaled amounts of these materials used in the Nuclear Regulatory Commission (NRC) nuclear industry jointly-sponsored Integrated Chemical Effects Tests (ICET) (e.g., 5x the amount of uncoated carbon steel assumed for the ICETs).
3.
Identify the amount (surface area) and material (e.g., aluminum) for any scaffolding stored in containment. Indicate the amount, if any, that would be submerged in the containment pool following a LOCA. Clarify if scaffolding material was included in the response to Question 2.
4.
Provide the type and amount of any metallic paints or non-stainless steel insulation jacketing (not included in the response to Question 2) that would be either submerged or subjected to containment spray.
Containment Pool Chemistry 5.
Provide the expected containment pool pH during the emergency core cooling system (ECCS) recirculation mission time following a LOCA at the beginning of the fuel cycle and at the end of the fuel cycle. Identify any key assumptions.
6.
For the ICET environment that is the most similar to your plant conditions, compare the expected containment pool conditions to the ICET conditions for the following items:
boron concentration, buffering agent concentration, and pH. Identify any other significant differences between the ICET environment and the expected plant-specific environment.
7.
For a large-break LOCA (LBLOCA), provide the time until ECCS external recirculation initiation and the associated pool temperature and pool volume. Provide estimated pool temperature and pool volume 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a LBLOCA. Identify the assumptions used for these estimates.
Plant-Specific Chemical Effects 8.
Discuss your overall strategy to evaluate potential chemical effects including demonstrating that, with chemical effects considered, there is sufficient net positive suction head (NPSH) margin available during the ECCS mission time. Provide an estimated date with milestones for the completion of all chemical effects evaluations.
9.
Identify, if applicable, any plans to remove certain materials from the containment building and/or to make a change from the existing chemicals that buffer containment pool pH following a LOCA.
10.
If bench-top testing is being used to inform plant specific head loss testing, indicate how the bench-top test parameters (e.g., buffering agent concentrations, pH, materials, etc.)
compare to your plant conditions. Describe your plans for addressing uncertainties related to head loss from chemical effects including, but not limited to, use of chemical surrogates, scaling of sample size and test durations. Discuss how it will be determined that allowances made for chemical effects are conservative.
Plant Environment Specific 11.
Provide a detailed description of any testing that has been or will be performed as part of a plant-specific chemical effects assessment. Identify the vendor, if applicable, that will be performing the testing. Identify the environment (e.g., borated water at pH 9, deionized water, tap water) and test temperature for any plant-specific head loss or transport tests. Discuss how any differences between these test environments and your plant containment pool conditions could affect the behavior of chemical surrogates.
Discuss the criteria that will be used to demonstrate that chemical surrogates produced for testing (e.g., head loss, flume) behave in a similar manner physically and chemically as in the ICET environment and plant containment pool environment.
12.
For your plant-specific environment, provide the maximum projected head loss resulting from chemical effects (a) within the first day following a LOCA, and (b) during the entire ECCS recirculation mission time. If the response to this question will be based on testing that is either planned or in progress, provide an estimated date for providing this information to the NRC.
ICET 1 and ICET 5 Plants 13.
(Not applicable).
Trisodium Phosphate Plants 14.
(Not applicable).
15.
(Not applicable).
16.
(Not applicable).
Additional Non-Coatings Questions 17.
The aluminum and other submerged metallic coupons in ICET #4 experienced little corrosion. In this test, the calcium silicate appeared to produce a beneficial effect by contributing to the protective film that formed on the submerged samples. Given that individual plants have less calcium silicate insulation than was represented by the ICET and that a given plant LOCA could result in little or no calcium silicate in the containment pool, discuss how you are confirming your plant materials will behave similar to ICET #4 for your plant-specific conditions.
18.
(Not applicable).
19.
(Not applicable).
20.
(Not applicable).
21.
(Not applicable).
22.
(Not applicable).
23.
(Not applicable).
24.
(Not applicable).
Coatings Generic - All Plants 25.
Describe how your coatings assessment was used to identify degraded qualified/acceptable coatings and determine the amount of debris that will result from these coatings. This should include how the assessment technique(s) demonstrates that qualified/acceptable coatings remain in compliance with plant licensing requirements for design basis accident (DBA) performance. If current examination techniques cannot demonstrate the coatings ability to meet plant licensing requirements for DBA performance, licensees should describe an augmented testing and inspection program that provides assurance that the qualified/acceptable coatings continue to meet DBA performance requirements. Alternately, assume all containment coatings fail and describe the potential for this debris to transport to the sump.
Plant Specific 26.
(Not applicable).
27.
(Not applicable).
28.
(Not applicable).
29.
(Not applicable).
30.
The NRC staffs safety evaluation (SE) addresses two distinct scenarios for formation of a fiber bed on the sump screen surface. For a thin bed case, the SE states that all coatings debris should be treated as particulate and assumes 100% transport to the sump screen. For the case in which no thin bed is formed, the staffs SE states that the coatings debris should be sized based on plant-specific analyses for debris generated from within the zone of influence (ZOI) and from outside the ZOI, or that a default chip size equivalent to the area of the sump screen openings should be used (Section 3.4.3.6). Describe how your coatings debris characteristics are modeled to account for your plant-specific fiber bed (i.e. thin bed or no thin bed). If your analysis considers both a thin bed and a non-thin bed case, discuss the coatings debris characteristics assumed for each case. If your analysis deviates from the coatings debris characteristics described in the staff-approved methodology, provide justification to support your assumptions.
31.
Your submittal did not provide details regarding the characterization of latent debris found in your containment as outlined in the NRC SE. Please provide these details.
32.
You indicated that you would be evaluating downstream effects in accordance with WCAP 16406-P. The NRC is currently involved in discussions with the Westinghouse Owners Group (WOG) to address questions/concerns regarding this WCAP on a generic basis, and some of these discussions may resolve issues related to your particular station. The following issues have the potential for generic resolution; however, if a generic resolution cannot be obtained, plant-specific resolution will be required. As such, formal RAIs will not be issued on these topics at this time, but may be needed in the future. It is expected that your final evaluation response will specifically address those portions of the WCAP used, their applicability, and exceptions taken to the WCAP. For your information, topics under ongoing discussion include:
a.
Wear rates of pump-wetted materials and the effect of wear on component operation b.
Settling of debris in low flow areas downstream of the strainer or credit for filtering leading to a change in fluid composition c.
Volume of debris injected into the reactor vessel and core region d.
Debris types and properties e.
Contribution of in-vessel velocity profile to the formation of a debris bed or clog f.
Fluid and metal component temperature impact g.
Gravitational and temperature gradients h.
Debris and boron precipitation effects i.
ECCS injection paths j.
Core bypass design features k.
Radiation and chemical considerations l.
Debris adhesion to solid surfaces m.
Thermodynamic properties of coolant 33.
Your response to GL 2004-02 question (d) (viii) indicated that an active strainer design will not be used, but does not mention any consideration of any other active approaches (i.e., backflushing). Was an active approach considered as a potential strategy or backup for addressing any issues?
34.
You stated that detailed containment walkdowns to identify and quantify the types and locations of insulation and debris sources have been completed. Were these walkdowns performed in accordance with guidance in Nuclear Energy Institute (NEI) 02-01? Please provide a discussion of the methodology used to obtain and quantify debris source data.
35.
The NRC staffs SE discusses a systematic approach to the break selection process where an initial break location is selected at a convenient location (such as the terminal end of the piping) and break locations would be evaluated at 5-foot intervals in order to evaluate all break locations. For each break location, all phases of the accident scenario are evaluated. It is not clear that you have applied such an approach. Please discuss how the limiting break locations listed as being evaluated in your GL response were selected.
36.
Please discuss the need to evaluate more break locations for Unit 2 (7 cases for Unit 2 vs. 5 cases for Unit 1).
37.
You provided a table of destruction pressure and ZOI values applied for each debris type in their evaluations. For those debris types for which a value was acquired from Table 4-1 of the NEI guidance report, please discuss the evaluations that were performed to determine that the applied value is applicable for the Point Beach specific insulation type.
38.
You did not provide information on the details of the debris characteristics assumptions other than to state that the NEI and SE methodologies were applied. Please provide a description of the assumptions applied in these evaluations and include a discussion of the technical justification for deviations from the SE-approved methodology.
39.
The September 2005 response to GL 2004-02 stated that Adequate NPSH without crediting submergence of the ECCS suctions is being retained as a working design criterion for the replacement screens. In other words, head losses through the replacement screens must be no greater than the minimum submergence depth of the screens. However the NRC staff notes that Appendix A to Regulatory Guide 1.82, Revision 3, indicates that the failure of partially-submerged sumps should be assumed to occur when the head loss across the debris bed is greater than, or equal to, half of the submerged screen height. Please justify the use of the alternative failure criterion described in your GL response, of assuming the failure of a partially-submerged sump screen when the head loss exceeds the submerged screen height, rather than half the submerged height.
40.
Has debris settling upstream of the sump strainer (i.e., the near-field effect) been credited or will it be credited in testing used to support the sizing or analytical design basis of the proposed replacement strainers? In the case that settling was credited for either of these purposes, estimate the fraction of debris that settled and describe the analyses that were performed to correlate the scaled flow conditions and any surrogate debris in the test flume with the actual flow conditions and debris types in the plants containment pool.
41.
Are there any vents or other penetrations through the strainer control surfaces which connect the volume internal to the strainer to the containment atmosphere above the containment minimum water level? In this case, dependent upon the containment pool height and strainer and sump geometries, the presence of the vent line or penetration could prevent a water seal over the entire strainer surface from ever forming; or else this seal could be lost once the head loss across the debris bed exceeds a certain criterion, such as the submergence depth of the vent line or penetration. According to Appendix A to Regulatory Guide 1.82, Revision 3, without a water seal across the entire strainer surface, the strainer should not be considered to be fully submerged.
Therefore, if applicable, explain what sump strainer failure criteria are being applied for the vented sump scenario described above.
42.
What is the minimum strainer submergence during the postulated LOCA? At the time that the re-circulation starts, most of the strainer surface is expected to be clean, and the strainer surface close to the pump suction line may experience higher fluid flow than the rest of the strainer. Has any analysis been done to evaluate the possibility of vortex formation close to the pump suction line and possible air ingestion into the ECCS pumps? In addition, has any analysis or test been performed to evaluate the possible accumulation of buoyant debris on top of the strainer, which may cause the formation of an air flow path directly through the strainer surface and reduce the effectiveness of the strainer?
43.
The September 2005 GL response stated that the licensee performed computational fluid dynamics (CFD) analysis to calculate debris transport. Please explain how you used CFD results to determine the amount of debris that transports to the sump screen.