ML102910697
| ML102910697 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/01/2009 |
| From: | Williams C Progress Energy Co |
| To: | Robert Carrion, Lake L, George Thomas, Naus D NRC/RGN-II/DRS/EB3, Oak Ridge |
| References | |
| FOIA/PA-2010-0116 | |
| Download: ML102910697 (13) | |
Text
Senguipta, Abhijit From: Williams, Charles R. [CharWes.Williams@pgnmail.com]
Sent: Tuesday, December 01, 2009 3:01 PM To: Lake, Louis; Thomas, George; nausdj@ornl.gov; Carrion, Robert
Subject:
,.Draft Refute 8.3 for your Review /11 1p p /(f6C-Attachments: " -.FM 8.3.pptx; SP-178 Rev 28 (tmp) 205.pdf; Pages from SP-178 Rev 28 (tmp) 1.pdf; SP-178 Rev 28 - 50.59 Screen.pdf; EC-ED 62366R0.doc Mr Lake and others, Attached for your review is draft of refute 8.3 and its exhibits. If you have any questions, please call me.
Thanks you, Charles Williams 919-516-7417
FM 8.3'Exhibit 2 Page _1 of 4 REG-NGGC-0010 Rev. 8, Attachment I - Screen IdentificationeNumbee(s)
Applicable 171865 RRevisio.n Number: 0 Plant(s): SBNP N. CR3 <HNP RNP Implementing Document No: SP-178 Revision No: 28 Also FSAR Change Package 2005-0020, Appendix J Program Manual Implementing Activity
Description:
SP-178 is being revised to bring it up-to-date with industry practices regarding the performance of containment integrated leak rate tests. The significant changes are the lack of operation of the containment fans and the increase in maximum allowable pressurization/depressurization rates to 15 psi/hr. The changes also include the incorporation of PT-125, Integrated Leak Rate Instrument Pre-Test Verification, into this procedure, general formatting changes, and the use of vendor-provided equipment (instruments, driers, etc.) instead of installed plant equipment. The change in fan operation is the result of industry experience that has shown that fan operation actually introduces some instability and prolongs the testing. The change in pressurization/depressurization rates will reduce critical path time in the outage. The rate of change is still much less than accident conditions and is consistent with other plants, including BNP.
SECTION 1: Predetermination la Is a change to the Technical Specifications or Operating License Yes No necessary to implement the proposed activity?
Initiate a change Continue to the in accordance next question with applicable procedure and go to Section 2 lb Is the proposed activity fully bounded by a previously completed Screen Yes No or Evaluation performed in accordance with REG-NGGC-0010?
Or I-- e ]
Enter the Go to Section 2 1C Has the proposed activity been formally approved by the NRC? Reference below and go to Section 4 Previous Screen/Evaluation and/or NRC Approval
Reference:
N./A K SECTION 2: Applicabilityo egltr Processes Other Than 10 CFR 50.59~
Address the questions below for all aspects of the activity. Refer to Attachment1 1 and contact the responsible program owner, as appropriate, to assure the effect of the activity is accurately and thoroughly addressed.
If the answer is "Yes" for any portion of the activity, complete the associated attachment (e.g. Question 3 and Attachment 3). Note that it is not unusual to have more than one process apply to a given activity.
2 Does the proposed activity involve a change to the Emergency Plan or an Yes No Emergency Plan implementing procedure needed to comply with the r requirements of 10 CFR 50 Appendix E? (Attachment 2) 3 Does the proposed activity involve a change to the Physical Security Yes No Plan, the Safeguards Contingency Plan or the Guard Training and D-Il Qualification Plan or the implementing procedures for these plans?
(Attachment 3) 4 Does the proposed activity involve a change to the Quality Assurance Yes No Program Description? (Attachment 4) " I N
S Page _2 of _4 REG-NGGC-0010 Rev. 8. Attachment I - Screen Identification Number(s)
Applicable 171865 1 1 Revision Number: 0 Plant(s):~ BNP CR3 HNP 1 RNP Implementing Document No: SP-178 Revision No: 28 5 Does the proposed activity involve a change to the Fire Protection Yes No Program (including safe shutdown and Appendix R requirements for ED example)? (Attachment 5) 6 Does the proposed activity involve a change to the licensed operator Yes No requalification program? (Attachment 6) I-1I 7 Does the proposed activity involve a change in thermal or chemical Yes No effluents, involve a change to the Environmental Protection Plan, or I involve a significant change to land use that could impact the environment? (Attachment 7) 8 Does the proposed activity involve a change to the Emergency Response Yes No Data System? (Attachment 8) EI1 Yes No 9 [RNP Only - A response to this question is not to be provided by Evaluators at BNP, CR3, and HNP]
Does the implementing activity affect a dry fuel storage facility or associated activities? (Attachment 9)
Yes No Applicability Conclusion Are all aspects of the activity controlled by one or more of the Regulatory I Processes identified in question la and questions 2 through 9 above? Complete the Complete the required required attachments attachments and and go to Section 4 go to Section 3
~SECTION 3:~10 CFR 50.59 Screen 10a Does the proposed activity involve a change to an SSC that adversely affects any FSAR-described design function? T Y-es No Ei Enter Justification Justification: Procedure SP-178 provides instructions for performing the integrated leak rate test on the CR-3 containment building. The changes to the procedure do not affect the function of the containment building, which is to provide one of the three fission product barriers. Neither the test acceptance criteria, nor the design conditions (i.e., pressure), are being changed by this procedure revision.
Yes No 10b Does the proposed activity involve a change to a procedure that LN L1 adversely affects how any FSAR-described SSC design function is performed or controlled? Enter Justification
Page _3 of _4 REG-NGGC-0010 Rev. 8. Attachment I - Screen Identificatidn Numnber(s)'
Applicable 171865 Revision Number: 0 SPlant(s): .*~BNP~ CR3 '3/4 HNP N Implementing Document No: SP-178 Revision No: 28 Justification: The design function of the containment building is to provide a fission product barrier in the event of a loss of coolant accident. This procedure ensures that the containment building can perform this function by measuring actual leakage rates at design pressure and comparing it to established allowable leakage criteria. The design pressure and acceptance criteria are not changing in this procedure revision.
However, the FSAR does describe some of the specifics of the test, such as the use of fans and the number of instruments used. While not using the fans and changing (increasing) the number of instruments will not adversely affect how thefission barrier function of the containment building is performed or controlled, this question will conservatively be answered "yes" to invoke a full 50.59 evaluation.
Yes No 10c Does the proposed activity involve revising or replacing any FSAR-described evaluation methodology that is used in establishing the design E]
bases or used in the safety analyses? Enter Justification Justification: The evaluation methodology is not changing in the revision to SP-178. Some of the details of what equipment is used during the test is changing, but the methodology is unaffected. The absence of running fans will allow the RB atmosphere to stabilize quicker, and the use of additional instrumentation will provide more accurate results. The testing will continue to be performed in accordance with Appendix J to 10CFR50.
10d Does the proposed activity involve a test or experiment not described in Yes No the FSAR, where an SSC is utilized or controlled in a manner that is I1 outside the reference bounds of the design for that SSC or is inconsistent Enter with analyses or descriptions in the FSAR? Justification Justification: The ILRT is described in the FSAR and is in accordance with Appendix J requirements.
The procedure revision does not put any SSC in any condition that is inconsistent with its design.
Are any of these questions (11a, 1Ob, 1Oc, or 1Od) answered "Yes?" Yes No Complete and Enter attach References Attachment 10 below and go to and go to Section 4 Section 4
References:
FSAR Rev. 29, Sections 5.6.3, 5.6.4, 5.6.5 ITS 3.6.1 ITS 5.6.2.20
- SECTION 4: Signatuzres and Distrib~ution Evaluator: C.L. Miller Date:
Reviewer: B. Foster Date:
Supervisor: T. Howard Date:
After Approval, the Evaluator shall ensure proper distribution of the forms.
Addiew eviews (if required)
Reviewer: Date:
Page _4 of _4 REG-NGGC-0010 Rev. 8, Attachment I - Screen
- 2 IdedtifctionIWumber(s)
Applicable 171865 Revision Number: 0
- > BNP
.RNP
Reviewer: Date:
FM 8.3 Exhibit 1 pg 1 of.2 C
R Progress Energy Continuous Use PROGRESS ENERGY CRYSTAL RIVER UNIT 3 PLANT OPERATING MANUAL SP-178 CONTAINMENT LEAKAGE TEST-TYPE "A" INCLUDING LINER PLATE SP-178 Rev. 28 Page 1 of 205
JFM 8.3 Exhibit 1 pg 2 of 2 1 REVISION
SUMMARY
SECTION DESCRIPTION Entire This revision to SP-1 78 is a total re-write. It is being revised to bring it up-to-Procedure date with industry practices regarding the performance of containment integrated leak rate tests. The significant changes being made are listed below:
" The Reactor Building Cooling Units will be modified such that they are considered available for AI-504 Shutdown Condition 4; however, they will not be in operation during any phase of the ILRT. Industry experience is that stabilization time is minimized with the units secured. ED 62366
- The maximum allowable pressurization/depressurization rates have been changed to 15 psi/hr. This change in pressurization/depressurization rates will reduce critical path time in the outage. ED 62366
" PT-125, Integrated Leak Rate Instrument Pre-Test Verification, has been incorporated into this procedure.
" Rented test instruments will be used in lieu of installed plant instruments.
This will allow use of modern and more reliable instrumentation.
" All pressurization equipment will be rented and the plant LR system will be bypassed. The rented equipment is more reliable and allows greater air flow capacity allowing for a shortened ILRT duration.
- Added/Reformatted sections in accordance with AI-402B.
" Updated position titles and procedure references.
SP-178 Rev. 28 Page 205 of 205
I FM 8.3 Exhibit 3 ED Engineering Change 0000062366R0 M REACTOR BUILDING COOLING UNIT AVAILABILITY DURING ILRT
- 1 C.L. Miller A.1 EC Folder Contents ED template 7/05/05 ADO 0 Contents doc A.1 EC Folder Contents I 5 A.2 List of Hard Copy Only Pages 1 5 A.3 Revision Summary 1 5 A.4 Problem Statement 1 5 A.5 Solution Statement 2 5 A.6 Evaluation 2 5 A.7 References 5 5 BOO 0 Review doc BA Engineering Review I Design Verification I I ZOO 0 Attach 1 xis Info Spreadsheet - Time to Boil 1 2 Z01 0 Attach 2 pdf Sketch - ILRT Equipment Layout 1 1 Z02 0 Attach 3 pdf Email from ILRT Contractor (B. Carey) 1 1 Open selected doc files from the folder Administrative Review Report Print selected doc files from the folderfrmteolr Close & save changes to all doc files opened from the folder Close & discard changes to all doc files opened Update "EC Folder Contents" table and update from the folder headers, footers, & chapters of doc files Save all EC Folder doc files as read-only Allow change to all EC Folder doc files Select an open doc and insert an 11x8.5 page Select an open doc and insert a 17xW1 page following its current page following its current page Instructions: Click in the appropriatecell; hit F2 to execute A.2 List of Hard Copy Only Pages N/A A.3 Revision Summary This is the original version.
A.4 Problem Statement An RB fan is required to be available during AI-504 Shutdown Condition 4, which is when the ILRT will be performed in 14R. Since air is denser than steam at a given pressure, it is desired to know how much the RB will need to be depressurized to allow an RB fan to operate if a loss of decay heat is experienced. This evaluation will determine the maximum RB pressure to operate the fans with no change to the current configuration (baffles, overloads), as well as for larger overloads without baffles. These values will be compared to the estimated time to boil for the RCS and a recommendation will be made regarding configuration during 14R.
This EC-ED will also evaluate the ability to depressurize the RB at 15 psi/hr.
ADO Contents Page 1 of 5
ED Engineering Change 0000062366RO A.5 Solution Statement The pressure at which the density of air equals the post-accident containment steam/air density of 0.19 Ibm/ft 3 is approximately 24 psig. If the RB fan motor overloads are replaced with 129 amp overloads, the allowable pressure can be increased to approximately 29 psig. This means the RB fans would not be considered "available" above these pressures. If decay heat removal was lost while the ILRT was in progress and at the maximum potential pressure of 55 psig, it would take approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to depressurize at 15 psi/hr, plus the time required to perform the necessary valve and equipment manipulations. The entire evolution would need to be completed prior to reaching the time to boil (estimated at approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).
The alternative to depressurizing the RB is to install baffles and change the fan motor overloads, similar to previous ILRTs. This would result in the fan being available during the entire duration of the ILRT. This is the recommended option. The baffles are stored in the oil tank warehouse (CATID 52700753). Details regarding their installation are included on drawing 311-725.
The installed ILRT depressurization line and two 8" temporary lines have adequate capacity to initially depressurize containment at 15 psi per hour. The containment pressure will eventually decrease to the point that there is insufficient AP to continue at 15 psi/hr and a slower rate will result.
A.6 Evaluation During previous performances of the containment integrated leak rate tests (ILRT), the RB fans operated while the RB was pressurized. Since air is denser than steam at a given pressure, baffles were installed in the intake plenums of the fans and the motor overloads were replaced with overloads with higher ratings to prevent the fans from tripping. During 14R, the RB fans will not be operating during the ILRT. One fan, however, must still be available per AI-504, . This ED will evaluate how much RB pressure would need to be reduced to allow the fans to operate, and also determine if a 15 psi/hr depressurization rate is feasible.
The following items will be included in this evaluation:
- 1. Determine the RB pressure that will allow a RB fan to operate in low speed if the ILRT baffles are not installed and the motor overloads are not changed.
- 2. Determine the RB pressure that will allow a RB fan to operate in low speed if the ILRT baffles are not installed and the motor overloads are changed
- 3. Determine the time to boil for the RCS during the ILRT.
- 4. Determine if the RB can be depressurized at a rate of 15 psi/hr.
Design Inputs:
Design Accident Ratings for AHF-1A/B/C [References 1 and 4]
Volumetric Flow Rate = Q 3= 50,000 ft 3/min Density = PRB = 0.19 Ibm/ft Full Load Motor Current = FLA = 114 A Volume of Containment is 2,060,000 ft 3 [Reference 10]
AOO Contents Page 2 of 5
ED Engineering Change 0000062366RO Assumptions:
- 1. The average air temperature inside containment during the ILRT is 90°F (the average air temperature during the ILRT in 6R was -89°F with mixing/cooling [Ref.
3]. This is conservative because air temperature is expected to be higher without mixing/cooling (higher temperature = lower density).
- 2. Pressure drop in the suction ductwork is neglected (low velocity).
- 1. Determine the RB pressure that will allow a RB fan to operate in low speed if the ILRT baffles are not installed and the motor overloads are not changed Per the RB fan vendor manual [Ref. 1], the design density of the air/steam mixture inside containment during accident conditions is 0.19 Ibm/ft 3. The pressure of air that corresponds to this density can be approximated from the following equation (ignores humidity and losses):
P = [p
- R * (t + 460)/144] - 14.7 where R = 53.3 ft-lbf/IbmrR for air and t = OF For p = 0.19 Ibm/ft 3 and t = 90°F, P = [0.19
- 53.3 * (90 + 460)/144] - 14.7 Pmax = 24 psig
- 2. Determine the RB pressure that will allow a RB fan to operate in low speed if the ILRT baffles are not installed and the motor overloads are changed Fans are constant volume devices, i.e., the volume of gas being transferred does not significantly change as temperature and pressure are varied. What does change is the mass flow rate, which is equal to the volumetric flow rate times the density. The change in mass flow rate has a direct impact on the motor current. The relationship of power input (H) and air density (p) can be approximated by the following equation [Reference 2]:
H1 /H 2 = P1 / P2 If the motor overloads are replaced with higher-rated overloads, as was done during the previous ILRTs, the fans will be able to operate at higher containment pressure (density). The density of air that will result in the higher overload current rating of 129 amps is P2 = P1 * (H2 / H1 )
= 0.19 Ibm/ft 3 * (129/114) 0.215 Ibm/ft 3 The corresponding RB pressure is P = [0.215
- 53.3 * (90 + 460)/144] - 14.7 Pr.ax,= 29 psig AOO Contents Page 3 of 5
ED Engineering Change 0000062366RO
- 3. Determine the time to boil for the RCS during the ILRT for the containment pressures determined above The spreadsheet included in Attachment 1 calculates time to boil for CR-3's core configuration in 14R at 20 days after shutdown with a RB pressure of 24 psig. The time to boil varies with RCS level and initial temperature, but will be approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> if the RCS is above 141 feet and initially controlled at 120 0 F. The time can be extended about 12 minutes if RB pressure is 29 psig. Note: this is an unverified spreadsheet,but the results are consideredreasonable based on comparison to previous time to boil calculations.
- 4. Determine if the RB can be depressurized at a rate of 15 psi/hr The depressurization of the RB will be performed utilizing the ILRT depressurization line as well as two 8" temporary lines that will also be used for pressurization.
Assuming a maximum RB pressure of 55 psig, the mass of air in the containment building is M = PV/RT
= (55 Ibf/in 2 + 14.7 lbf/in 2 )(144 in2/ft2 )(2,060,000 ft3)/(53.3 ft-lbf/IbmrR)(90 + 4600 R)
= 705,300 Ibm Similarly, the mass of air in containment at 40 psig is
= (40 lbf/in 2 + 14.7 lbf/in 2)(144 in2/ft 2)(2,060,000 ft3 )/(53.3 ft-lbf/Ibm°R)(90 + 460 0R) 553,500 Ibm Therefore, the mass flow required to reduce RB pressure 15 psi/hr at 55 psig is 705,300 Ibm - 553,500 Ibm = 151,800 Ibm/hr The volumetric flow rate, in terms of standard cubic feet per minute (scfm),would be Q = m/p 3
= (151,800 Ibm/hr)(1 hr/60 min)/0.0764 Ibm/ft Q = 33,115 scfm The installed ILRT depressurization line (from Penetrations 305 and 306 through LRV-122 to RB Purge Exhaust ductwork [Ref. 7]) has been analyzed to pass 12,000 scfm (55,008 Ibm/hr) at an RB pressure of 60 psig [References 5 and 6]. Although the flow rate will be slightly less when considering 55 psig vs 60 psig RB pressure, there is sufficient pressure drop across the control valve (LRV-1 22) in the calculation (35 psi) to increase the flow rate by opening the valve further.
AOO Contents Page 4 of 5
ED Engineering Change 0000062366RO If 12,000 scfm passes through the ILRT depressurization line, the remaining 21,115 scfm will need to exhaust through the two temporary 8" lines. These lines are a combination of carbon steel pipe and flexible hose, and are approximately 225' long each from the RB penetration to the exhaust muffler. The exact configuration is not presently known, as they will be field-run during the outage, but the general arrangement is shown on Attachment 2. Conservatively assuming each line is 1000' long to account for bends, fittings and valves, and using 11,000 scfm per line, the pressure drop is [Reference 8]:
AP = AP100 psig, 60°F *[(100 + 14.7)/(P + 14.7)] * [(460 + t)/520]* L ft AP = 0.633 psi/100 ft *[(114.7)/(55 + 14.7)] * [550/520]* 1000 ft AP = 11 psi As long as the flow is not limited due to the velocity becoming sonic, the 8" lines (in conjunction with the ILRT depressurization line) will pass sufficient air flow to reduce RB pressure at 15 psi/hr. From Reference 9 Equation 9-23, the critical pressure (where velocity becomes sonic) is 52.8% of initial pressure. For a starting pressure of 55 psig (69.7 psia), the flow will become sonic if pressure drops below 22 psig. Therefore, since 55 psig - 11 psi = 44 psig (> 22 psig),
sonic flow is not reached in the pipe line, and 15 psi/hr is achievable.
From a structural standpoint, depressurizing (or pressurizing) the RB at 15 psi/hr is not challenging, as accident conditions are much more severe. The concern with the ILRT pressure change rates is with the impact on insulation, paint, electrical boxes, etc. There is no analysis that evaluates the 15 psi/hr. However, industry experience has demonstrated its acceptability.
Brunswick Nuclear Plant currently uses this limit in BNP Procedure OPT-20.5, and the ILRT vendor contracted for 14R provided a listing of plants that had previously depressurized at this rate (Attachment 3). One station did experience some insulation being displaced from a penetration, but this is considered minor and unusual. Containment inspections after the ILRT will identify any damage and evaluations or corrective actions will be performed as necessary.
A.7 References
- 1. Vendor Manual 0002, Reactor Containment Fan Cooler, Rev. 11
- 2. Marks' Standard Handbook for Mechanical Engineers, Ninth Edition
- 3. SP-178, Rev. 10 (completed 1987, Refuel Outage 6)
- 4. EDBD 8/11, Reactor Building Air Handling System, Rev 13
- 5. Calculation M92-0056, H2 Purge Pressure Loss Calculation, Rev. 0
- 7. Drawing 302-723, Post-Accident Venting System, Rev. 15
- 8. Crane Technical Paper No. 410, Flow of Fluids Through Valves, Fittings, and Pipes, 1969
- 9. Essentials of Engineering Fluid Mechanics, Second Edition
- 10. Calculation M98-0010, Containment Free Volume, Rev. 0
- 11. Drawing 311-725, Reactor Building Plan at Floor Elev. 95-0", Rev. 9 AO0 Contents Page 5 of 5
8.3 Effect of Faster Pressurization/Depressurization Rates During Last ILRT
==
Description:==
The procedure for conducting the containment Integrated Leak Rate Test (ILRT) (SP-178) was changed before the last ILRT, which was performed in 1995. That change (2005) included a provision to allow the rate of change ininternal pressure to 15 psi/hr, a higher rate than was used inprevious ILRTs.
Data to be collected and Analyzed:
- 1. ILRT procedure. (FM 8.3 Exhibit 1)
- 2. 10 CFR 50.59 Evaluation of the ILRT procedure change relative to the pressurization/depressurization rate of 15 psi/hr. (FM 8.3 Exhibit 2)
- 3. Engineering disposition to and engineering change (ECED 62366RO) included an evaluation to depressurize containment at 15psi/hr.
(FM 8.3 Exhibit 3)
~1 Verified Refuting Evidence: Verified Supporting Evidence:
- a. The ILRT procedure was appropriately changed and evaluated inaccordance with Progress Energy Not applicable procedures and 10 CFR 50.59. (FM 8.3 Exhibits 1 and 2)
- b. ECDC 62366RO evaluated the 15 psi/hr change of containment pressurization/depressurization and concluded that "From a structural standpoint, depressurizing (or pressurizing) the RB at 15 psi/hr is not challenging, as accident conditions are much more severe" . Although other issues may result from this change, they are not considered relevant to the structural integrity of the containment and therefore not contributors to the delamination issue. (FM 8.3 Exhibit 3, pg 5 of 5)
- c. Inaddition, Impulse Response scans of the exterior containment surface revealed no delamination in any sections between buttresses beyond the panel where the SGR hole was cut
==
Conclusion:==
There was no effect on the containment structure from changing the ILRT procedure that had not already been bounded by its design. May identif'V additional perspective on this islue as RCA relhted efforts proceeds 3/19/2010 R11 !'roPmetarj bemadentlaI, 2UU091 1