NL-08-0961, Technical Specifications Amendment Request Engineered Safety Feature Room Coolers Request for Additional Information

Technical Specifications Amendment Request Engineered Safety Feature Room Coolers Request for Additional Information

ML081720349
Person / Time
Site:	Farley
Issue date:	06/20/2008
From:	Stinson L Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors, Office of Nuclear Reactor Regulation
References
NL-08-0961
Download: ML081720349 (9)

Text

L M. Stinson (Mike)

Southern Nuclear Vice President Operating Company, Inc.

Fleet Operations Support 40 Inverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.5181 Fax 205.992.0341 SOUTHERN A.

COMPANY June 20, 2008 Energy to Serve Your World""

Docket Nos.: 50-348 NL-08-0961 50-364 U. S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Technical Specifications Amendment Request Engineered Safety Feature Room Coolers Request for Additional Information Ladies and Gentlemen:

In a letter dated June 5, 2007, Southern Nuclear Operating Company (SNC) requested in accordance with the provisions of 10 CFR 50.90 a change to the Joseph M. Farley Nuclear Plant (FNP) Unit 1 and Unit 2 Technical Specifications (TS). This amendment request is for a new TS to address the operation of Engineered Safety Feature (ESF) Room Coolers required to support ESF TS equipment. This amendment includes surveillance requirements and will establish a Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to allow adequate time to complete maintenance activities on the ESF Room Coolers and thus reduce the need for unnecessary plant shutdowns.

On June 3, 2008, a telecon was held between the NRC and SNC regarding the proposed TS change. The SNC response to the requested information is provided in the Enclosure.

Mr. L.M. Stinson, states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

(Affirmation and signature are provided on the following page.)

U. S. Nuclear Regulatory Commission NL-08-0961 Page 2 This letter contains no NRC commitments. If you have any questions, please advise.

Respectively submitted, SOUTHERN NUCLEAR OPERATING COMPANY L.M. Stinson Vice President Fleet Operations Support Sworn to and subscribed before me thisc!tJ t/J.. day of--->o,l....

e 1.......,.".....

, 2008.

/k;)tl/.L£ Notary Public My commission expires: Je.c..-Ij.5;,;lolO LMS/BDM/phr

Enclosure:

Response to NRC RAls cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. H. Jones, Vice President - Engineering RTYPE: CFA04.054; LC# 14787 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. A. Jervey, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant Enclosure Technical Specifications Amendment Request Engineered Safety Feature Room Coolers Request for Additional Information

SNC Response to NRC RAls Technical Specification for Safety Related Room Coolers NRC Question 1 The LAR submittal, in the new bases pages 3.7.19-4 states the ESF room cooler satisfy Criteria. 4 of 10 CFR 50.36 (c)(2)(ii). The reviewer thinks they are Criteria 3. We need to discuss the resolution of the difference.

SNC Response to Question 1 The proposed FNP technical specification is based in part on the Vogtle Electric Generating Plant technical specification that specifies Criterion 4 of 10 CFR 50.36( c )(2)(ii) in the ESF room cooler bases. Based on discussions with the NRC staff, SNC proposes to change this reference to Criterion 3.

The technical specification bases page will be revised upon NRC approval.

NRC Question 2 The reviewer wants to know the assumptions and temperature inputs for the USFSAR section 9.4.2 statement that the analysis demonstrates that the equipment...are capable of performing...with the plant encountering a DBA.

Based on a telecon on June 3, 2008 the NRC stated that SNC should describe the sequence and process for two cases 1) entering the LCO for normal conditions and 2) entering the LCO and a DBA occurs for the following equipment:

a) where the equipment Completion Time is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or, b) where the equipment Completion Time is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

SNC Response to Question 2 a) Auxiliary Building DC Switchgear / Battery Charger Rooms Subsystem

Background

FNP has three Room Coolers and three battery chargers servicing two trains of Auxiliary Building DC Switchgear / Battery Chargers. One of the Room Coolers and battery chargers is available to manually align and use on either train. The swing equipment is sized to provide 100% capacity redundancy for a train. Therefore, aligning the swing battery charger and Room Cooler power supply, cooling water supply and fan discharge (by opening the room door) to the switchgear train room with an inoperable Room Cooler will provide adequate cooling to the switchgear / battery charger room. With a connecting room door opened to connect the swing room with the original train room, plant procedures ensure that the door is secured in the open position and periodically verified open. During the times when two trains of Auxiliary Building DC Switchgear I Battery Charger are required, only two of three Room Coolers are required with one Room Cooler aligned to each train E1 - 1

SNC Response to NRC RAls Technical Specification for Safety Related Room Coolers room. The proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time allows sufficient time for maintenance activities to be completed without requiring unnecessary plant transients.

With three Room Coolers, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO would be invoked during the time when the swing Room Cooler was being placed in service. During the transition time, ventilation by a non-safety HVAC system provides some heat removal capability. Typically, the transition from the primary train to the swing Room Cooler and securing the connecting door open takes place within one hour. Once the swing Room Cooler is in service and one Room Cooler per Train were in service, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO would be exited.

Case 1 - Entering the LCO for normal conditions Current system operating procedures provide guidance to align the swing Battery Charger Room Cooler to either Train A or Train B to maintain two trains of room cooling capability. An administrative Limiting Condition of Operation (LCO) is initiated to maintain two room coolers operable. A fire watch is established on the door between the two adjacent battery charger rooms. The door between the two battery charger rooms is opened and secured in the open position. Once the swing Room Cooler is placed in service and two Trains of room cooling capability exists, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO would be exited. The time to complete the swing Room Cooler and associated valve and electrical alignments is about one hour. The system alignment with the swing Room Cooler in service would continue until the primary Room Cooler was returned to service.

Case 2 - Design Basis Accident In the event of a Design Basis Accident (DBA), the non-affected train Auxiliary Building DC Switchgear / Battery Charger and Room Cooler is available to support the Engineered Safety Feature equipment to mitigate the accident.

A calculation was performed to determine the steady state room temperature in the Auxiliary Building DC Switchgear / Battery Charger Rooms cooled by Service Water fed room coolers for a DBA. The Ultimate Heat Sink (Service Water pond) maximum temperature was used to determine the steady state room temperature for the DBA.

PROTO-HX, Air Coil Module, Version 4.10 was used to determine the resultant room temperatures. The computer model inputs are based on bounding inputs and heat loads. This calculation utilizes the finned air cooler heat exchanger module. The software model performs evaluations consistent with the methodology of ARI Standard 410, Standard for Forced Air-Cooling Coils. PROTO-HX was developed and is maintained under a 10 CFR 50 Appendix B qualified program.

The resultant room temperature for a DBA with one Room Cooler Train in service was 114°F. Auxiliary Building DC Switchgear / Battery Charger Rooms were evaluated for the capability of equipment to perform the intended E1 - 2

SNC Response to NRC RAls Technical Specification for Safety Related Room Coolers function at an elevated ambient temperature of 133°F for the 30 day mission time of a DBA. The resultant DBA temperature of 114°F is bounded by this evaluation.

b) Load Control Center D and E Subsystem

Background

Normally, Load Center D and E rooms are cooled by the non-safety related normal HVAC (air conditioner). If this system is not functional, the ESF room coolers provide room cooling.

The current FNP technical specification for electrical distribution systems provides a Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the Auxiliary Building AC electrical power distribution sUbsystem. This does not allow sufficient time to complete required maintenance or repairs on the Room Coolers. The addition of this ESF Room Cooler TS will provide a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time to perform the required Room Cooler maintenance and is consistent with other mechanical ESF system Completion Times.

Case 1 - Entering the LCO for normal conditions The normal non-safety HVAC air conditioner maintains the Load Center D and E rooms at approximately 75°F. If the non-safety air conditioner system is not functional, the ESF Room Cooler provides room cooling. Maintenance requiring entry into the Room Cooler LCO would not be routinely planned with the normal air conditioner out of service. For unplanned events, the following description assumes the normal HVAC air conditioner system is not functioning.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO would be invoked if one train of ESF Room Cooler was not operable. Compensatory actions would include temperature monitoring and use of non-safety related HVAC equipment to maintain room temperature below the safety related electrical equipment functional temperature. These compensatory actions are implemented by procedures. The procedural guidance includes the following:

1. Tag-out the Load Center Room Cooler from service and keep the fan motor secured until after the service water is restored to the room cooler

2. Monitoring of the Load Center room temperature is initiated

3. If the affected Load Center room temperature exceeds 104°F, then room temperature monitoring is increased to once per hour and compensatory action is initiated to cool the room.

4. If the affected Load Center room temperature reaches 130°F, then declare the Load Center inoperable and apply the Technical Specification LCO actions (restore to operable status in eight hours or be in Mode 3 in six hours).

E1 - 3

SNC Response to NRC RAls Technical Specification for Safety Related Room Coolers When the Room Cooler is repaired the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO would be exited.

Case 2 - Design Basis Accident In the event of a DBA during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO, the opposite non-affected train Auxiliary Building AC electrical power distribution subsystem and Room Cooler is available to support the ESF equipment to mitigate the accident.

This results in one Room Cooler Train in service.

PROTO-HX, Air Coil Module, Version 4.10 was used to determine the resultant room temperatures. The computer model inputs are based on bounding inputs and heat loads. This calculation utilizes the finned air cooler heat exchanger module. The software model performs evaluations consistent with the methodology of ARI Standard 410, Standard for Forced Air-Cooling Coils. PROTO-HX was developed and is maintained under a 10 CFR 50 Appendix B qualified program.

The resultant room temperature for a DBA with one Room Cooler Train in service was 124°F. Load Control Center D and E Rooms were evaluated for the capability of equipment to perform the intended function at an elevated ambient temperature of 130°F for the 30 day mission time of a DBA. The resultant DBA temperature of 124°F is bounded by this evaluation.

Summary for SNC Response 2 For rooms with electrical equipment with either two or eight hour technical specification Completion Times, at least one train of required electrical equipment will have a Room Cooler available to support the ESF equipment to mitigate a DBA.

The swing train Auxiliary Building DC Switchgear I Battery Charger Room Cooler provides 100% capacity redundancy for a train. During the times when two trains of Auxiliary Building DC Switchgear I Battery Chargers are required, only two of three Room Coolers are required with one Room Cooler aligned to each train room.

Non-safety HVAC equipment will be used as required to maintain adequate cooling of Load Center D and E Rooms when ESF Room Coolers are in an LCO. The majority of the scheduled maintenance will occur with the normal HVAC air conditioner maintaining the Load Center D and E rooms at approximately 75°F. If the non-safety air conditioner system is not functional, the ESF Room Cooler provides room cooling. Maintenance requiring entry into the Room Cooler LCO would not be routinely planned with the normal air conditioner out of service.

NRC Question 3 E1 - 4

SNC Response to NRC RAls Technical Specification for Safety Related Room Coolers Also in that same section you refer to the Battery Charger room and the door open condition. Is this driven by Operations procedure? How is this controlled?

SNC Response Yes, an operations procedure provides guidance to open the door for the Auxiliary Building DC Switchgear / Battery Charger Rooms to place the swing room cooler in service. The specific procedural guidance is provided in SNC response to NRC question 2 above.

E1 - 5

~---------+-l~~",,-:-----"--~--=-----j NRC Correspondence Routing and Information Sheet 10 CFR 72 No.

NRC Due Date:

Hatch U1-321 U2-366 A

Iicable to: 10 CFR 50 Docket No.

72-36 72-42 Author:

_B_"_D_"_M_cK_in_n_e..LY__ Farley U1-348 U2-364 Lie Letter No.

_N_L_-O.;...8;...-o_9_6_1 Vogtle U1-424 U2-425 N/A SUbject of Letter:

FNP Technical Specifications Amendment Request Engineered Safety Feature Room Coolers Response to:

Review I Concurrence Person Initials/Date Person Initials/Date 1

Site Mgmt. Concurrence 4

Other 2

PRB Concurrence 4

Other 3

SRB Sub. Concurrence 4

Other Nuclear Licensing I Management Routing Initials/Date Person InitiaIs/Date Person 1

Preparer 8

2 LE - Review 9

3 NL AA Spelling/Format Vice President - Farley 9

4 NL Manager - Hatch 9

Vice President - Vogtle 1'/

4 NL Manager - Farley Vice President-Engineering 9

NL Manager - Vogtle 4

Vice President - Fleet Ops 9

5 Safety Analysis Executive Vice President 9

(if applicable) 6 Allegations/Orders - Legal 10 Final Review - Preparer

(~~ ~l~lc:D' 7

VP Notification / Draft 11 NL AA - Date & Distribution IJ!A-f.p.,,,J, ~

II General Distributions:

D All extra copies to be issued via email in PDF/Hyperlink format if possible (Except for State, issue hard copy)

D Allegation letters to.IT Gasser and M Caston in Confidential envelope D All letters to Executive: JT Gasser. Corp Licensing: MJ Ajluni, BD McKinney, RD Baker, NJ Stringfellow.

Site Performance Analysis: WR Bayne, WG Copeland, KA Underwood. WH Sims, Submittals Review - FNP only.

D OPC (HNP & VNP only) - Laurence Bergen, Ken Rosanski and Bob Masse.

D All LERs - Draft LERs to AF Thornhill for review; LERevents@inpo.org as a WORD doc; JW Kale - FNP LERs only.

D Special Reports - JW Kale - FNP only.

D Security/EP - Security Coordinator/EP Supervisor/site EP Coordinators as appropriate D NRR Project Managers: All TS Changes, RAI Responses and other items that require a response from the NRC.

Farley: Richard A. Jervey (raj@nrc.gov) Hatch: Robert E. Martin (rem@nrc.gov)

Vogtle: Richard A. Jervey (raj@nrc.gov)

Other Distributions and comments: (List all distribution NOT shown in General Distributions above