ML071840169

Proposed Licence Amendment Request; Increased Maximum Service Water Temperature Limit

ML071840169
Person / Time
Site:	Surry
Issue date:	06/25/2007
From:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
07-0401
Download: ML071840169 (34)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 June 25, 2007 10CFR50.90 U. S. Nuclear Regulatory Commission Serial No. 07-0401 ATTN: Document Control Desk NLOS/GDM R1 Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 PROPOSED LICENSE AMENDMENT REQUEST INCREASED MAXIMUM SERVICE WATER TEMPERATURE LIMIT Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests amendments, in the form of changes to the Technical Specifications (TS) to Facility Operating License Numbers DPR-32 and DPR-37 for Surry Power Station Units 1 and 2, respectively. The proposed change increases the maximum service water temperature limit from 95 0F to 100 0 F. The proposed change is necessary to proactively address observed increases in service water intake temperatures during the past two summers, which have approached the existing TS limit. A discussion of the proposed change is provided in Attachment 1. The marked-up and typed proposed TS pages are provided in Attachments 2 and 3, respectively. An associated Basis change is provided for information only and will be implemented in accordance with the TS Bases Control Program and 10 CFR 50.59.

We have evaluated the proposed amendment and have determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for our determination is included in Attachment 1. We have also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite and no significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change. The proposed TS change has been reviewed and approved by the Station Nuclear Safety and Operating Committee. NRC approval of the proposed TS change is requested by May 31, 2008.

As discussed in the attachment, this license amendment request includes a proposed revision of TS Figure 3.8-1, which provides containment operational limits associated with containment partial pressure vs. SW temperature. It should be noted that the current Surry TS include different versions of TS Figure 3.8-1 for Surry Units 1 and 2 due to the different NRC-approved schedules for the implementation of Surry License AV~

Serial No. 07-0401 Docket Nos. 50-280/281 Page 2 of 4 Amendments 250/249 for Surry Units 1 and 2, respectively, dated October 12, 2006.

These license amendments also revised TS Figure 3.8-1 as part of Dominion's resolution of Generic Safety Issue (GSI)-191, Assessment of Debris Accumulation on PWR Sump Performance, and noted that the approved TS changes were to be implemented by the end of the fall 2007 refueling outage for Surry Unit 1 and by the end of the fall 2006 refueling outage for Surry Unit 2. Consequently, we respectfully request that the proposed TS changes discussed in the attachment not be approved prior to December 31, 2007, to ensure that the changes to TS Figure 3.8-1 that were approved by License Amendments 250/249 have been implemented for both units.

If you have any questions or require additional information, please contact Mr. Gary D.

Miller at (804) 273-2771.

Sincerely, Gerald T. Bischof Vice President - Nuclear Engineering Attachments

1. Discussion of Change

2. Proposed Technical Specifications Pages (Mark-Up)

3. Proposed Technical Specifications Pages (Typed)

Commitments made in this letter: None

Serial No. 07-0401 Docket Nos. 50-280/281 Page 3 of 4 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. D. C. Arnett NRC Resident Inspector Surry Power Station State Health Commissioner Virginia Department of Health James Madison Building - 7 th Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. S. P. Lingam NRC Project Manager - Surry U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8G9A Rockville, Maryland 20852 Mr. R. A. Jervey NRC Project Manager - North Anna U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8G9A Rockville, Maryland 20852

Serial No. 07-0401 Docket Nos. 50-280/281 Page 4 of 4 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering, of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this Av", day of * , 2007.

v/

My Commission Expires: 4~A~ LI, ?v08 15.

Ay Publi Notary Public i MARGARET B. BENNETT Notary Public S 143 6,-

4 Commonwealth of Virginia My Commiulon Expires Aug 31. 2008 I

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(SEAL)

-/I it Serial No. 07-0401 Docket Nos. 50-280/281 ATTACHMENT 1 DISCUSSION OF CHANGE Virginia Electric and Power Company (Dominion)

Surry Power Station Units 1 and 2

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 DISCUSSION OF CHANGE INTRODUCTION Pursuant to 10 CFR 50.90, Virginia Electric and Power Company (Dominion) requests an amendment to Facility Operating License Numbers DPR-32 and DPR-37 for Surry Power Station Units 1 and 2. The proposed change increases the maximum Technical Specification (TS) Service Water (SW) temperature limit from 95 0 F to 100°F. This increase in the maximum SW temperature limit is reflected in revised TS Figure 3.8-1, which provides allowable containment air partial pressure versus SW temperature.

The maximum SW temperature limit is being increased to address the potential for isolated peaks in the seasonal peak temperature of the James River, which is the source for the Surry Circulating Water (CW) and SW systems. A related TS Basis change is also included for information. The TS Basis will be revised following NRC approval of the proposed license amendment.

The proposed change has been reviewed, and it has been determined that the change has no adverse impact on plant operation and that no significant hazards condition exists as defined in 10 CFR 50.92. In addition, it has been determined that the change qualifies for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9); therefore, no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

BACKGROUND The Ultimate Heat Sink (UHS) for Surry Power Station (Surry) Units 1 and 2 is the lower James River and the intake canal. The James River is connected through the Chesapeake Bay to the Western Atlantic Ocean. Water is pumped from the James River into an elevated intake canal. The CW system draws water from the intake canal and' supplies the SW system which is used as cooling water for heat exchangers that remove heat from the Component Cooling Water (CCW) system, Bearing Cooling Water (BCW) system, Recirculation Spray (RS) system, Charging Pump Service Water (CPSW) subsystem and other station applications such as air conditioning and Chilled Water.

At full-power operation, Surry discharges approximately 11.9 x 109 British thermal units (Btu)/hr into the James River estuary by way of cooling water discharged into Cobham Page 1 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Bay. The Surry discharge permit limits waste heat rejected to the James River from Surry to 12.6 x 10 9 Btu/hr, but does not require the reporting of discharge temperatures.

Unusually hot summer temperature peaks, combined with decreased river flows due to low rainfall in the upper James River basin, coupled with a seasonal increase in' radiational heating of the lower Chesapeake Bay during the July to early August time period, have caused SW temperatures to approach the current TS limit of 95°F during each of the last two years. Based upon these isolated peaks in SW temperature, the potential exists for SW temperature to exceed the TS limit in the future. The proposed change will allow continued plant operation with a maximum SW temperature limit of 100°F.

LICENSING BASIS Surry TS Section 3.8 provides the limiting conditions for operation and the associated action statements to maintain the integrity and operating pressure for the reactor containment. Containment integrity ensures that in the event of a Design Basis Accident (DBA), the release of radioactive material from containment will be restricted to those leakage paths and associated leak rates assumed in the accident analysis.

TS 3.8.D requires that whenever the reactor coolant system temperature and pressure are greater than 350°F and 450 psig, containment air partial pressure will be maintained within the acceptable operating range of TS Figure 3.8-1. As noted in TS Figure 3.8-1, containment air partial pressure is limited by SW temperature, and there are currently no containment air partial pressure limits specified for SW temperatures greater than 95 0 F.

TS 3.8.D.1.a requires air partial pressure to be within acceptable limits within one hour or place the unit in at least Hot Shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Section 9.9, Service Water System, of the Surry Updated Final Safety Analysis Report (UFSAR) states that the system is designed for the removal of heat resulting from the simultaneous operation of various systems and components of the two Surry units based on a maximum river water temperature of 95 0 F.

The SW temperature limit was changed from 92 0 F to 95 0F in 1993 to address previously experienced extended hot weather, minimal rainfall, and low tide that caused the SW temperature to approach the 92 0 F limit. The increase in the SW temperature limit was incorporated into the Surry TS by Amendments 183/183 dated September 7, 1993, for Page 2 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Surry Units 1 and 2, respectively. The existing temperature limit of 95"F was set 2°F warmer than the highest river water temperature on record.

DESIGN BASIS The James River, by way of the intake canal, is the source of water for the Surry SW System and is the UHS for Surry Power Station. Water is pumped from the river to the intake canal by the CW pumps. Three diesel-driven emergency service water (ESW) pumps are also provided to ensure that water can be supplied to the intake canal when power is not available to the CW pumps. Water in the intake canal gravity flows to the high-level intake structure for each unit and enters into the CW System piping. Service water then branches from the CW System piping and flows to the various heat loads and services associated with Units 1 and 2. Service water returns to the James River by way of a discharge tunnel from each unit, which empties into a common discharge canal. A SW System is provided for each unit, and portions of each unit's SW System are common to both units and are designed for the simultaneous operation of various subsystems and components of both units.

The intake canal is elevated and has an intrinsic storage capacity that provides a reservoir of water for the SW and CW Systems. Units I and 2 are located at the end of the intake canal approximately 1.5 miles downstream of the intake structure. Water from the intake canal is directed to Units 1 and 2 by CW System lines that originate at the high-level intake structure. SW System piping originates from branches in the 96-inch CW lines upstream of the CW motor-operated valves (MOVs) that supply water to the main condensers.

The SW System supplies cooling water through the plant by way of several supply headers, which can be isolated by hand-operated valves or MOVs. Return headers collect the SW from the cooled components and subsystems and return the water to the James River via the discharge tunnel and the discharge canal. The elevation difference between the intake canal and the discharge tunnel provides the motive force for the flow of the service water to the various loads. Various components are supplied directly by gravity flow, and other components are supplied via booster pumps.

The SW System is required to supply cooling water to safety-related (SR) heat exchangers during accident conditions and abnormal environmental conditions (e.g., hurricane conditions). The SW System provides water for cooling to the following typical components:

Page 3 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment I

1. Recirculation Spray (RS) System heat exchangers (RSHX) 2.. Chemical and Volume Control (CH) System charging pump intermediate seal cooler and lube oil coolers

3. Main Control Room and Emergency Switchgear Room Air Conditioning System chiller condensers

4. Component Cooling Water (CC) System heat exchangers

5. Bearing Cooling Water (BC) System heat exchangers The MOVs that supply and isolate the RS System heat exchangers are normally closed.

The MOVs open automatically in the event of a containment atmosphere high-high pressure signal (CLS hi-hi), which indicates a loss of coolant accident (LOCA) or main steam line break (MSLB). The CW System MOVs to the main condensers and the SW System MOVs to the BC system heat exchangers and CC system heat exchangers are normally open. The valves associated with the accident unit close automatically upon a CLS hi-hi signal initiated in the event of a LOCA (or MSLB) that occurs coincident with a loss of offsite power (LOOP) to both units. The SW System is shared between Unit 1 and Unit 2; therefore, it is required to support both the accident unit and the non-accident unit.

Should the intake canal drop below the low level setpoint, the turbine would trip, and the CW condenser isolation valves and CC and BC heat exchangers' SW isolation valves would close.

The SW System is a Safety Related (SR) system because its main function is to transfer heat from other SR systems and equipment and reject it to the UHS (i.e., James River).

The specific safety functions are:

1. Transfer heat from the RS System to ensure adequate depressurization of containment following a design basis accident.

2. Transfer heat from containment sump fluids (via the RSHXs) to ensure the Safety Injection (SI) System can provide adequate core cooling following a design basis accident.

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Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1

3. Transfer heat from the Main Control Room (MCR) and Emergency Switchgear Room (ESGR) Air Conditioning System chillers such that MCR and ESGR temperatures are maintained following a design basis accident.

4. Provide cooling to the charging pumps to support their operation following a design basis accident.

5. Provide makeup flow to the Intake Canal such that required flows following a design basis accident can be maintained.

PROPOSED CHANGE The proposed change will increase the maximum service water temperature limit by 5°F.

This will allow continued operation of the station with a SW temperature up to 100°F. TS Figure 3.8-1 is revised to address operation with SW temperatures up to 100°F.

The maximum SW temperature limit in the TS 3.8 basis is also revised from 95°F to 100°F.

TECHNICAL EVALUATION The following paragraphs provide the technical evaluation of increased SW temperature on affected systems, accident analyses and other considerations.

Component Cooling (CC) Water System The SW system provides cooling for the CC heat exchangers (CCHX) and the charging pump intermediate seal coolers. The CCHXs were evaluated by limiting the CC outlet temperature to the original design specification limit of 1200 F. For the worst-case heat load (normal shutdown of two units following a loss of offsite power) and 100°F SW temperature, three CCHXs have the capacity to support the CC system design requirements.

Equipment supported by the CC system will not be impacted by increasing the SW temperature to 100°F due to the analytical restrictions imposed by this evaluation. In this evaluation the maximum CCHX outlet temperature was constrained to the same value as in previous evaluations in which the SW temperature limit was 95 0 F. The CC fluid outlet temperature of the CCHXs will be no more than the 120°F currently supplied to CC system Page 5 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 loads. As a result there will be no difference in plant response for systems supported by CC due to this proposed increase in SW temperature.

Main Control Room (MCR) and Emergency Switchgear Room (ESGR) Air Conditioning Systems (ACS)

A SW temperature of 100°F will result in a small decrease in capacity of the MCR/ESGR ACS chillers. However, the small decrease in capacity has been evaluated and it has been determined that there is no impact on the ability of the MCR/ESGR ACS to maintain space temperatures within equipment design limits under maximum heat load conditions.

Chemical and Volume Control (CH)

The SW System provides cooling for the charging pump lube oil coolers and intermediate seal coolers. The Lube Oil Coolers and the Intermediate Seal Coolers have been evaluated and shown to provide adequate margin with the SW temperature limit increased to 100 0 F.

Impact of Increasing SW Temperature on Accident Analyses The Surry SW system is the heat sink following a design basis loss of coolant accident (LOCA). The SW system provides cooling water for the four containment recirculation spray (RS) heat exchangers. After the containment pressure reaches the Consequence Limiting Safeguards (CLS) setpoint and the refueling water storage tank (RWST) level decreases below 60% wide range level, the four RS pumps receive a start signal. The RS pumps take suction from the containment sump strainer assembly, pass the water through the shell side of the RS heat exchangers, and deposit the water as spray droplets in the containment atmosphere. Containment analyses in the Surry Updated Final Safety Analysis Report (UFSAR) Chapters 5 and 6 were performed to verify that containment design criteria are met and to confirm that available net positive suction head (NPSHa) is greater than required for the RS pumps and the low head safety injection (LHSI) pumps during recirculation mode for operation within the TS 3.8 limits for containment air partial pressure, SW temperature, RWST temperature and containment temperature.

Table 1 describes the effect on the Surry UFSAR containment analysis acceptance criteria from increasing SW temperature above 95°F. The proposed change to increase the SW temperature limit from 95 0 F to 100°F only adversely impacts the LOCA containment depressurization analyses in UFSAR Section 5.4.2. At high SW temperature, it is more Page 6 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 difficult to depressurize the containment atmosphere and reduce sump temperature following a LOCA. To meet the LOCA containment depressurization requirements, the accident analysis requires a reduction in containment air partial pressure as SW temperature increases. This explains the downward sloping line in Fig.4 (proposed TS Figure 3.8-1) above 70°F SW temperature. The LOCA containment peak pressure, MSLB containment peak pressure, and MSLB containment peak temperature analyses are independent of SW temperature, and the NPSHa analyses for the LHSI and RS pumps do not produce limiting results at higher SW temperatures (see Table 1). Therefore, explicit analyses at 100 0 F SW were not required for those design criteria.

LOCA Containment Depressurization Analyses To evaluate a SW temperature maximum operating limit of 100 0F, LOCA containment depressurization analyses were performed to demonstrate margin to the design requirements for containment integrity, dose consequences, and equipment qualification.

The analyses were performed using the GOTHIC analysis methodology outlined in Reference 3, which was approved by the NRC in August 2006 and was applied to the Surry applications that were reviewed by the NRC in Reference 2. The "proposed configuration" analyses that were included in Attachment 1 of Reference 1 were used as the starting point for the analysis. These analyses modeled the new RS pump start logic of CLS High High containment pressure coincident with 60% RWST wide range level. The minimum SW flow rate to each RSHX was confirmed to be bounding for 101°F SW and the assumed RS heat exchanger thermal performance at 101°F was confirmed to be conservative. The objective of the analysis was to identify containment air partial pressure TS upper limits from 70°F to 100OF SW temperature that would continue to meet the containment depressurization requirements.

Separate GOTHIC analyses were performed to determine the maximum containment depressurization time (CDT) and the depressurization peak pressure (DPP). CDT represents the time when containment pressure drops below the pressure at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> that is assumed in the LOCA dose consequences analysis (i.e., 1.0 psig). Maximum initial containment air temperature is generally conservative for determining CDT. When the containment spray (CS) pumps are stopped after RWST depletion, only the RS system provides spray flow to the containment and at higher temperatures than the CS system (the maximum RWST temperature is 450 F). Once CS is terminated, the containment pressure increases from subatmospheric conditions until it reaches the DPP, which is limited by the heat removal capacity of the RS system and the air mass in containment. A minimum initial containment temperature is conservative for the DPP case, because higher Page 7 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 initial air mass makes it more difficult to maintain subatmospheric conditions after CS termination. All cases assume a maximum initial RWST volume, which produces the longest time to reach the RS pump actuation setpoint and maximum CDT and DPP.

A proposed TS Figure 3.8-1 is inciiuded as Figure 4. The proposed change revises only the TS upper limit that extends from 11.3 psia containment air pressure at 70°F SW to 10.3 psia at 95°F SW. The proposed limit extends from 11.3 psia at 70°F SW to 10.3 psia at 100OF SW. Because the remaining limits in TS Figure 3.8-1 are not modified, the scope of analyses is limited to CDT and DPP analyses between 70°F and 100°F SW. Cases 1 and 2 in Table 3.4-1 of Attachment 1 of Reference 1 documented the results for the TS statepoint of 11.3 psia and 70°F SW. Those cases are not repeated. Cases 3 and 4 in that same table documented results for the TS statepoint of 10.3 psia and 95°F SW. Cases 3 and 4 are repeated in Tables 2 and 3 herein for comparison to the new design cases for a TS limit of 100°F SW.

Table 2 documents three DPP cases that were performed at 101 0F, 96°F, and 91°F SW and their corresponding containment air partial pressures along the proposed TS Figure 3.8-1 upper limit. As expected, at the same initial containment air partial pressure of 10.3 psia, a 5°F increase in SW temperature (DPP Case 1 compared to DPP Base Case) increases the containment depressurization time and the DPP from 0.45 psig to 0.58 psig.

New cases at 96 0 F and 91°F were analyzed to demonstrate that reducing SW temperature offsets the higher air pressure from the new limit line. All three DPP cases show little difference in the initial depressurization time to reach 0.0 psig and the DPP value, but they show a clear trend in the final subatmospheric time, with the 101°F case providing the maximum depressurization time of 11,490 seconds. The pressure profiles from the DPP cases remain less than the limit of 1.0 psig during the period of 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after a LOCA that is assumed in the LOCA Alternate Source Term (AST) analysis that was approved by the NRC in Reference 2.

Table 3 documents three CDT cases that were performed at 101°F, 96°F, and 91°F SW and their corresponding containment air partial pressures along the proposed TS Figure 3.8-1 upper limit. The CDT cases are all subatmospheric before one hour and the DPP is less than 1.0 psig during the period of 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after a LOCA that is assumed in the LOCA AST analysis that was approved by the NRC in Reference 2.

Figures 1 (containment pressure), 2 (containment vapor and liquid temperature), and 3 (total RS heat exchanger duty) show the behavior of key variables from DPP Case 1 (TS limits of 10.3 psia, 750 F air, 100°F SW), which takes the longest to reach a final Page 8 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 subatmospheric state. Table 4 compares the time sequence of events for DPP Case 1 and CDT Case 1 to illustrate the difference in accident response from assuming maximum versus minimum initial containment temperature.

For all cases, the GOTHIC containment pressures are less than the assumed pressures in the LOCA AST analysis in Reference 2. Specifically, the GOTHIC containment pressure is less than 1.0 psig during the period of 1-4 hours after a LOCA and is less than 0.0 psig after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In addition, the GOTHIC containment pressure and temperatures increased slightly due to the higher SW temperature, which reduced the heat removal capability of the RS heat exchangers and created slightly higher RS spray temperatures. The GOTHIC containment pressures and temperatures for the LOCA depressurization analyses were confirmed to be bounded by the analyzed limits for environmentally qualified equipment inside containment.

Emergency Service Water Pumps (ESWP)

SW is used to cool the heat exchanger for the water jacket of the diesel engines that power these pumps. Emergency Service Water Pump diesels were evaluated and found to have no significant effects from an increase in the SW temperature limits. Additionally, there were no changes in the requirements for alarms or controls resulting from an increase in the SW temperature limit to 100°F.

Emergency Diesel Generator Cooling The Emergency Diesel Generator units are air-cooled; therefore there is no impact on their performance due to the increase in the maximum SW temperature limits.

Service Water Related NPSH Pump Requirements Calculations were reviewed with respect to the NPSH requirements of pumps that are supplied with Service Water. With the increase in the SW temperature limit to 100 0 F, the vapor pressure of the water being supplied to these pumps decreases slightly. However, the small decrease in vapor pressure has been evaluated and it has been determined that the small decrease in NPSH which results from the proposed SW temperature limit increase remains within the NPSH margins available.

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Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Environmental Qualification The temperature effect of the increase in the SW temperature limit to 100°F has no significant impact on the rooms where the SW and CW lines are located. These rooms are already evaluated for room temperatures at 100°F or above. Therefore, the increase in SW and CW line temperatures resulting from the increase in the maximum SW temperature limit to 100°F will have no impact on these environments or their equipment.

During the anticipated brief periods of operation at the elevated SW and CW operating temperature, the increase in normal ambient temperatures in various areas of the plant

-should be less than 1 to 20 F. This 1 to 20 F short term increase has an insignificant effect on the aging calculations performed on the associated EQ equipment and is bounded in the ambient temperature margin used in the calculations.

The Surry containment analysis for a maximum SW limit of 100°F shows that the containment depressurization analysis requirements are met for operation in accordance with the proposed TS Figure 3.8-1 with a maximum SW temperature of 100°F at a maximum containment air partial pressure of 10.3 psia. The GOTHIC containment pressure and temperature profiles were also shown to be bounded by the containment equipment qualification (EQ) limits.

Fire Protection/Appendix "R" The Licensing Basis for the Surry Power Station is to achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an Appendix R event. This requirement will continue to be met with an increased service water temperature limit of 100 0F. Section 5 of the Appendix R report describes four limiting fires:

1. Inside the reactor containment (unit specific).

2. Outside the reactor containment (common to both units). This includes portions of the Auxiliary Building and Turbine Building.

3. Outside the reactor containment (unit specific) such as the Cable Vault and Tunnel, Emergency Switchgear Rooms, and Main Steam Valve House.

4. Control Room (common to both units).

None of the analyses for these postulated fires are affected by the increased maximum SW temperature limit. Therefore, Appendix R requirements will continue to be met with an increase in the maximum SW temperature limit to 1000 F.

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Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Piping Stress Analysis The stress analysis for all piping influenced by SW has been reviewed with particular focus on the safety related fiberglass piping. The safety related fiberglass piping has the most limiting stress margins of any of the piping at Surry related to the increase in the maximum SW temperature limit to 100 0 F. The fiberglass piping has been evaluated for the increase in the maximum SW temperature limit and has been determined to be acceptable.

Impact on GL 96-06 Evaluations of the Component Cooling System The CC system head tank elevation and piping arrangement provides adequate head to ensure that there is no potential voiding in the CC system inside of containment. CC system fluid temperature will not increase over the existing evaluated temperature values; therefore, piping penetrations supplied by the CC system will not be impacted.

Impact on Station Blackout The Emergency Diesel Generators (EDG) and the Station Blackout (SBO) Diesel Generators are air-cooled and are not affected by increased SW temperature. Increasing the maximum SW temperature limit to 100°F does not impose any additional requirements on the assumptions pertaining to the station black out requirements. Therefore, no adjustments to plant-specific assumptions related to station blackout were found to be necessary during the evaluation of the plant response to a rise in the maximum SW temperature limit to 100°F.

Impact on Spent Fuel Pool Cooling Spent Fuel Pool cooling is supported by the CC system and will not be impacted by an increase in the maximum SW temperature limit to 100 0 F. In the evaluation of the CC system, the maximum CC fluid temperature was constrained to the same value as in the previous evaluations based upon a SW temperature limit of 95 0F. The CCHX outlet side temperature will be no more than 120°F as currently supplied to the CC system loads. As a result, there is no difference in how the Spent Fuel Pool Cooling system responds due to the increase in the maximum SW temperature limit to 100°F.

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Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Impact on Shutdown Cooling The Component Cooling System when supplied with Service Water at 100°F can continue to cool down Surry Units 1 and 2 within the existing Technical Specification requirements.

The CC system was evaluated to demonstrate that the CC system remains capable of cooling down the units within TS limits given the restrictions imposed on this evaluation (i.e., CCHX maximum CC outlet temperature was not allowed to increase beyond 120'F as SW inlet increased to the proposed maximum temperature limit of 100°F).

Environmental Considerations There are no changes in the plant thermal discharge limits as a result of a change in the SW temperature limit to 100 0 F. Plant discharge limits are a function of the quantity of heat rejected into the UHS during plant operations and are not temperature limited. The Surry discharge permit limits waste heat rejected to the James River from Surry to 12.6x10 9 Btu/hr, but does not require the reporting of discharge temperatures. The quantity of heat being rejected into the UHS will not change due to the increase in allowable SW temperature limits. Studies show that elevated temperatures in the James River due to the thermal discharge dissipate from 1 to 20 F for every 1000 feet from the discharge point.

Although the thermal plume is shown to remain close to the shore extending around Hog Island on an ebb tide, with approximately six miles between the discharge and intake, little if any thermal effects at the intake are expected from the discharge.

NUREG-1431 CONSIDERATIONS Although this request is not based on the averaging methodology of Technical Specification Task Force (TSTF) change traveler TSTF-330-A, Rev. 3, the following information is provided to ensure this license amendment request more completely addresses possible concerns.

Consideration: The UHS is not relied upon for immediate heat removal (such as to prevent containment over-pressurization), but is relied upon for longer-term cooling such that the temperature averaging approach continues to satisfy the accident assumptions for heat removal over time.

Response: Surry does not propose to use a time-weighted temperature averaging approach for verifying TS compliance. Instead, the proposed TS limit of 100°F will be verified as an instantaneous value in the same manner as it is currently verified. The Page 12 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 engineering analyses assume a maximum SW temperature of 101 0 F, which includes 1F instrument uncertainty above the proposed TS limit of 100 0 F, for the duration of the analyses. The current instrument uncertainty is 0.960 F for each of four SW temperature indicators on each unit. The operators can average the four indicators to reduce the uncertainty to 0.48°F (0.96°F divided by the square root of 4 channels). Thus, the engineering analysis assumption of 1°F is conservative compared to the uncertainty for a single indicator and for the average of all four indicators.

Consideration: When the UHS is at the proposed maximum allowed value of 100 0 F, equipment that is relied upon for accident mitigation, anticipated operational occurrences, or for safe shutdown, will not be adversely affected and are not placed in alarm condition or limited in any way at this higher temperature.

Response: All equipment and systems that interface with the SW system have been evaluated for the increase in service temperature to 100F. The evaluation determined that the systems supported by the SW system can support plant operations at the increased temperature. The LOCA containment analysis (previously discussed) confirmed the accident response at an increased SW temperature is bounded by the LOCA AST analysis approved by the NRC in Reference 2. There are no changes in expected alarms or limiting conditions that result from increasing in the maximum SW temperature limit to 100 0 F. Equipment supported by the Component Cooling System will not be impacted due to the restrictions imposed upon the CC system during the evaluation of the increase in the maximum SW temperature limit to 100°F.

Consideration: Plant-specific assumptions, such as those that were credited in addressing station blackout and Generic Letter 96-06, have been adjusted (as necessary) to be consistent with the maximum allowed SW temperature of 100°F that isproposed.

Response: As discussed above, no adjustments to plant-specific assumptions related to station blackout or GL 96-06 were determined to be necessary during the evaluation of the plant response to an increase in the SW temperature limit to 100F.

Consideration: Cooling water that is being discharged from the plant (either during normal plant operations, or during accident conditions), does not affect the UHS intake water temperature (typical of an infinite heat sink) but location of the intake and discharge-----

connections, and characteristics of the UHS can have an impact.

Page 13 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Response: There are no changes in the plant discharge limits as specified in the Surry Power Station discharge permit in response to an increase in the maximum SW temperature limit to 100 0F. Plant discharge limits are a function of the quantity of heat rejected into the UHS during plant operations and are not temperature limited. The quantity of heat being rejected into the UHS will not change due to the increase in allowable SW temperature. Studies show that elevated temperatures in the James River due to the thermal discharge dissipate from 1 to 2°F for every 1000 feet from the discharge point.

Although the thermal plume is shown to remain close to the shore extending around Hog Island on an ebb tide, with approximately six miles between the discharge and intake, little if any thermal effects at the intake are expected from the discharge.

Technical Evaluation Conclusions The TS 3.8 containment air partial pressure limits of 10.1-10.3 psia at 95 0 F SW that were approved in Reference 2 can be shifted to 100°F with a small reduction in LOCA containment depressurization margin. Figure 4 documents the proposed TS Figure 3.8-1 with changes to the maximum containment air partial pressure limits from 70°F to 100°F SW and the minimum limit of 10.1 psia from 95°F to 100°F SW. GOTHIC containment analyses demonstrate that containment design criteria continue to be satisfied for these changes. The LOCA containment pressure profile is less than 1.0 psig from 1-4 hours and is subatmospheric after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, so the LOCA AST analysis in Reference 2 remains bounding. Further, the GOTHIC containment pressure and temperature profiles are within the analyzed limits for environmentally qualified equipment inside containment.

Based on the evaluation of the effect on station systems and components, operation with a maximum SW temperature limit of 100°F is acceptable.

REGULATORY SAFETY ANALYSIS Significant Hazards Consideration (SHC)

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Operating with increased maximum service water temperature limits does not affect the frequency of accident initiating events. Therefore, the probability of an accident previously analyzed is not increased. Plant systems supported by SW have been evaluated for operation with a service water temperature limit of 100°F, and it Page 14 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 determined that there is no operational impact when operating at the higher SW temperature.

Although the service water temperature limit is being increased, the containment will continue to meet its design basis acceptance criteria following a large-break loss of coolant accident as identified in the UFSAR. Therefore, there is no increase in the consequences of any accident previously evaluated resulting from operation of Surry Units 1 and 2 with an increased service water temperature limit.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

There are no new failure modes or mechanisms associated with operating Surry Units 1 and 2 with an increased service water temperature limit of 100 0F. As noted above, the increased service water temperature limit does not affect plant operation, since plant systems supported by SW have been evaluated for operation with a SW temperature limit of 100°F and no operational impact was identified. Therefore, there are no new or different kinds of accidents created by operation of Surry Units 1 and 2 with increased service water temperature limits.

3. Does the proposed change involve a significant reduction in the margin of safety?

The containment analysis acceptance criteria continue to be met when operating with the proposed increased maximum service water temperature limit. Containment integrity will not be challenged and will continue to meet its design basis acceptance criteria following a large break loss of coolant accident. Therefore, the existing margin of safety is not significantly reduced by operation of Surry Units 1 and 2 with increased service water temperature limits.

ENVIRONMENTAL ASSESSMENT This amendment request meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) as follows:

(i) The amendment involves no significant hazards consideration.

As described above, the proposed change involves no significant hazards consideration.

Page 15 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 (ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed change does not involve the installation of any new equipment, or the modification of any equipment that may affect the types or amounts of effluents that may be released offsite. Therefore, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

(iii) There is no significant increase in individual or cumulative occupation radiation exposure.

The proposed change does not involve plant physical changes, or introduce any new mode of plant operation. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure.

Based on the above, Dominion concludes that the proposed changes meet the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.22 relative to requiring a specific environmental assessment by the Commission.

Conclusion The proposed increase in the maximum SW temperature limit is required due to the potential for isolated peaks in the intake temperature from the James River, which is the UHS and the source for the Surry CW and SW systems. The Surry containment response analysis was re-performed and it was determined that Surry will continue to meet the applicable acceptance criteria while accommodating a maximum operating SW temperature limit of 100 0F. Plant systems that could potentially be affected by the increased maximum SW temperature limit were also evaluated for integrity and performance at a SW temperature of 100'F during operation for both full power and accident conditions and were determined to be acceptable.

Page 16 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 REFERENCES

1. Letter from Leslie N. Hartz (Dominion) to USNRC, "Virginia Electric and Power Company, Surry Power Station Units 1 and 2, Proposed Technical Specification Change and Supporting Safety Analyses Revisions to Address Generic Safety Issue 191, "Serial No.06-014, January 31, 2006.

2. Letter from Siva P. Lingam (USNRC) to David A. Christian (Dominion), "Surry Power Station, Unit Nos. 1 and 2 - Issuance of Amendments Regarding Implementation of Generic Safety Issue 191 (TAC Nos. MC9724 and MC9725)," October 12, 2006.

3. Dominion Topical Report DOM-NAF-3-0.0-P-A, "GOTHIC Methodology for Analyzing the Response to Postulated Pipe Ruptures Inside Containment," September 2006.

4. Letter from Bart C. Buckley of the USNRC to W. L. Stewart of Virginia Electric and Power Company dated September 7, 1993, "

Subject:

Surry Units 1 and 2 - Issuance of Amendments Re: Service Water Temperature Limit (TAC NOS. M86944 and M86945)."

Page 17 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Table 1: Impact of SW Temperature > 95 0F on Containment Design Analyses Acceptance Criterion UFSAR Impact of SW Temperature > 95°F Section LOCA peak containment 5.4.2 Peak pressure and temperature occur pressure and temperature before RS system actuation and are independent of SW temperature LOCA containment 5.4.2 Increasing SW temperature will reduce depressurization effectiveness of RS heat exchangers, increase containment pressures and temperatures, and increase final containment depressurization time to subatmospheric MSLB peak containment 5.4.3 MSLB analyses do not credit the RS pressure and temperature system, so SW changes do not change the analysis NPSHa for the LHSI 6.2.3.11.1 NPSHa is limiting for 45 0F -70°F SW and pumps increases for SW temperature above 70°F due to higher containment backpressure from warmer RS spray; 100°F is non-limiting NPSHa for the RS pumps 6.2.3.11.3 NPSHa is limiting at minimum (250 F) SW temperature Page 18 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Table 2: GOTHIC Results for LOCA Depressurization Peak Pressure Analysis Case 4 DPP Case DPP Case DPP Case from Table 1 2 3 3.4-1 in Reference 1*

TS Initial Air Partial Pressure, 10.3 10.3 10.467** 10.633**

psia TS Initial Air Temperature, OF 75.0 75.0 75.0 75.0 Relative Humidity 100% 100% 100% 100%

Initial Total Pressure in GOTHIC, 10.97 10.97 11.137 11.303 psia (includes 0.25 psi uncertainty)

TS SW Temperature, OF 95.0 100.0 95.0** 9,0.0**

GOTHIC SW Temperature, OF 96.0 101.0 96.0 91.0 Results Containment Pressure < 1.0 psig 3024 sec 3080 sec 3079 sec 3076 sec Containment Pressure < 0.0 psig 3358 sec 3432 sec 3431 sec 3438 sec Containment Pressure at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> -0.69 psig# -0.51 psig -0.50 psig -0.50 psig Depressurization Peak Pressure 0.45 psig 0.58 psig 0.63 psig 0.55 psig (DPP)

Time of DPP 5121 sec 5425 sec 5047 sec 4988 sec Time < 0.0 psig permanently 8268 sec 11,490 9479 sec 8613 sec sec I his case provided the imiting depressurization peak pressure and final depressurization time to subatmospheric conditions for operation within the TS Figure 3.8-1 that was submitted to the NRC in Reference 1 and approved in Reference 2.

For these cases along the proposed TS limit line that runs from 11.3 psia at 70OF to 10.3 psia at 100°F, the air partial pressure limit is derived by linear interpolation. The case at 96 0 F produces a more limiting DPP than the case at 101°F, because the increase in initial air mass is not fully offset by the 50 F reduction in SW temperature.

1. This data point was not provided in Reference 1 but is included here for comparison to the containment pressures from the new analyses.

Page 19 of 23

Serial No. 07-0401 Docket Nos. 50-280/281 Attachment 1 Table 3: GOTHIC Results for LOCA Containment Depressurization Time (CDT)

Analysis TS SW Limit - Case 3 CDT Case CDT Case CDT Case from Table 1 2 3 3.4-1 in Reference 1*

TS Initial Air Partial Pressure, 10.3 10.3 10.467** 10.633**

psia TS Initial Air Temperature, OF 125.0 125.0 125.0 125.0 Relative Humidity 100% 100% 100% 100%

Initial Total Pressure in GOTHIC, 12.52 12.52 12.687 12.853 psia (includes 0.25 psi uncertainty)

TS SW Temperature, OF 95.0 100.0 95.0** 90.0**

GOTHIC SW Temperature, OF 96.0 101.0 96.0 91.0 Results Containment Pressure < 1.0 psig 3099 sec 3149 sec 3138 sec 3148 sec Containment Pressure < 0.0 psig 3362 sec 3420 sec 3409 sec 3424 sec Containment Pressure at 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> -0.78 psig# -0.63 psig -0.67 psig -0.52 psig Depressurization Peak Pressure -0.10 psig 0.20 psig 0.06 psig -0.05 psig (DPP)

Time of DPP 5145 sec 5215 sec 5207 sec 5084 sec Time < 0.0 psig permanently 3376 sec 6843 sec 5872 sec 3424 sec

• This case provided the limiting containment depressurization time for operation within the TS Figure 3.8-that was submitted to the NRC in Reference 1 and approved in Reference 2.

For these cases along the proposed TS limit line that runs from 11.3 psia at 70°F to 10.3 psia at 100 0 F, the air partial pressure is derived by linear interpolation.

1. This data point was not provided in Reference 1 but is included here for comparison to the containment pressures from the new analyses.

Page 20 of 23

Serial No. 07-0401

8. Docket Nos. 50-280/281 Attachment 1 Table 4: Accident Chronology for LOCA Depressurization Analyses with 100°F SW Limit CDT Case 1 DPP Case 1 Initial Conditions*

TS Containment Air Partial Pressure, psia 10.3 10.3 Initial Containment Total Pressure, psia 12.52 10.97 TS Containment Air Temperature, OF 125.0 75.0 TS Service Water Temperature, OF 100.0 100.0 Event Time (seconds)

Accident Start 0.0 0.0 CLS High High Pressure 2.1 2.3 Start SI 22.6 22.6 CS flow reaches containment 99.1 99.3 IRS pump starts at 57.5% level + 10 sec 1792 1758 IRS spray delivered to containment 1867 1832 ORS pump starts at 57.5% level + 142 seconds 1924 1890 ORS spray delivered to containment 2007 1978 Containment pressure reaches 14.7 psia 3420 3432 Switchover to SI recirculation 3776 3735 Containment spray pumps stopped 4343 4304 Depressurization peak pressure occurs 5215 5425 Containment pressure < 14.7 psia permanently 6843 11,490 Analyses include uncertainties of 0.25 psi air pressure, 0.5 0F air temperature, and 1.0°F SW temperature.

Vapor pressure is 1.97 psia at 125.5 0 F and 0.42 psia at 74.5 0 F.

Page 21 of 23

Serial No. 07-0401 fia Docket Nos. 50-280/281 Attachment 1 Figure 1: Containment Pressure from DPP Case 1 (10.3 psia, 100°F SW, 75°F air)

Containment Pressure Pump Suction DER Depressurization Analysis 60 50 ___________ ___________

45-___________

40-___________

a.

C 35 Ck 30 ___________

25-20-15 in 0.1 1 10 100 1000 10000 Time (sec)

Figure 2: Containment Temperatures from DPP Case 1 (10.3 psia, 100OF SW, 75°F air)

Containment Temperature Pump Suction DER Depressurization Analysis 300 E

1!

0.1 10 100 1000 10000 Time (sec)

Page 22 of 23

Serial No. 07-0401 I' Docket Nos. 50-280/281 Attachment I Figure 3: RS Heat Exchanger Heat Rate from DPP Case 1 (10.3 psia, 100`F SW, 75OF air)

Total RSHIX Heat Rate Pump Suction DER Depressurization Analysis 200 . ..... I-100 -

I 1000 2000 3000 4000 5000 6000 Time (sec)

Figure 4: Proposed TS Figure 3.8-1 with Revised Containment Air Partial Pressure Upper Limits from 70°F to 100OF TS Figure 3.8-1 SURRY TECHNICAL SPECIFICATION CURVE FOR CONTAINMENT ALLOWABLE AIR PARTIAL PRESSURE INDICATION VS. SERVICE WATER TEMPERATURE 11.6 11.4

- (70,11.3) 11.2 ACCEPTABLE OPERATION I. 11.0 INSIDE THE LINES C

C 2 10.8 C-C CONTAINMENT TEMPERATURE BETWEEN 75 F AND 125 F C

0.

10.6 10.4 (100, 10.3) 10.2 (25, 10.3) (70, 10.1)

• * (100!

10.1) 10.0 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 105 Service Water Temperature, deg-F Page 23 of 23

Serial No. 07-0401 Docket Nos. 50-280 and 281 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS PAGES (MARK-UP)

Virginia Electric and Power Company (Dominion)

Surry Power Station Units I and 2

• Ti' 1,5.-4 (3)assuring that envirommental conditions will not preclud agems to close the valves and

4) that this administwitve or manual action will prevent the release of radioactivity outside the containment.

The Reactor Coolant System tempature and pressure bein8 below 350*F and 450 psuS, respectively, ensures that no significant amount of flashing steam will be formed and hence thas them would be no signi*icant pressure buildup In the conainment if them is a loss-of-coolant accident. Therefore, the containment interal pressure is not required to be subatmospheric prior to exceceing 350aiF.mad 450 ps.g, The allowable value for the containment air pLrtial pressure is presented in TS Fiure 3,8-1 for service waute temperatures from 26 to9 P. The RWST water shall have a maximum temperatare of 45?.

The horizontal upper limit line In TS Figure 3.8-1 Is based on MSLB peak calculated pressure criteria, and the sloped line from 70*F toWrF service water temperatures Is based on LOCA depressurization criteria.

-A.....L.tdnent. h-Z5fl249

TS Figuxe 3.8-1 SUIt*Y TBCHNCAL CFTION CUM FO CONTAINMENT ALLOWABLE AIR PARTIAL PRESSURE INDICATION VS. SERVICE WATER -FERATU 11.6 I

Ua B.

I I

i 25 30 40 45 50 .55 60 65 '70 75 80 85 90 95 100 serviceWaurTmpapwtum, dbgF LN7i-:- LiOle.*7b#ON OR OLLTSIbiF 7S1~ -144= W:6 Q# tgAW M~r7-S X B

Serial No. 07-0401 Docket Nos. 50-280 and 281 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATIONS PAGES (TYPED)

Virginia Electric and Power Company (Dominion)

Surry Power Station Units I and 2

rj/ TS 3.8-4 (3) assuring that environmental conditions will not preclude access to close the valves and

4) that this administrative or manual action will prevent the release of radioactivity outside the containment.

The Reactor Coolant System temperature and pressure being below 350'F and 450 psig, respectively, ensures that no significant amount of flashing steamwill be formed and hence that there would be no significant pressure buildup in the containment if there is a loss-of-coolant accident. Therefore, the containment internal pressure is not required to be subatmospheric prior to exceeding 350'F and 450 psig.

The allowable value for the containment air partial pressure is presented in TS Figure 3.8-1 for service water temperatures from 25 to 100'F. The RWST water shall have a maximum temperature of 45°F.

The horizontal upper limit line in TS Figure 3.8-1 is based on MSLB peak calculated pressure criteria, and the sloped line from 70'F to 100°F service water temperatures is based on LOCA depressurization criteria.

Amendment Nos.

'-I TS Figure 3.8-1 SURRY TECHNICAL SPECIFICATION CURVE FOR CONTAINMENT ALLOWABLE AIR PARTIAL PRESSURE INDICATION VS. SERVICE WATER TEMPERATURE 11.6 11.4

-(70,11.3) 11.2 ACCEPTABLE OPERATION INSIDE THE LINES C. 11.0 U-l.8 10 10 CONTAINMENT TEMPERATURE BETWEEN 75 F AND 125 F S10.6 10.4 N (100, 10.3) 10.2 -(25, 10.3) 10.1) -~ +/- + I I 1 (100, 10.1) 0 10.0 i1?1 ii ir iiii !i i i i ! i i  ! i i i i i i i i i i ! i ! !

rýi 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 105 Service Water Temperature, deg-F Note: Operation on or outside the line requires entry into TS 3.8.D. 1.a I--,

mr- -1q