ML103050148
| ML103050148 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/26/2010 |
| From: | John Carlin Constellation Energy Nuclear Group, EDF Group, Ginna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-04-002 | |
| Download: ML103050148 (12) | |
Text
John Carlin Site Vice President CENG a joint venture of Constellation
- =,q,--6eDF Eneg-y0 R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5200 585.771.3943 Fax iohn.carlin(acenqllc.com October 26, 2010 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:
SUBJECT:
Document Control Desk R.E. Ginna Nuclear Power Plant Docket No. 50-244 Response To Commitments Regarding Generic Letter 2004-02 Specific To Debris Transport Analysis and Strainer Head-loss Testing (1) Letter from Douglas Pickett (NRC) to John Carlin (Ginna LLC), dated December 4, 2009, Request for Additional Information Re: Generic Letter 2004-02 (TAC No. MC 4687)
(2) Letter from John Carlin (Ginna LLC) to Document Control Desk (NRC),
dated April 6, 2010, Request For Additional Information Regarding Generic Letter 2004-02.
REFERENCES:
On December 4, 2009, the NRC requested additional information regarding Generic Letter 2004-02: "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors" (Reference 1). On April 6, 2010, R.E. Ginna Nuclear Power Plant LLC (Ginna LLC), responded to that request of which included regulatory commitments (Reference 2). Enclosed please find our response to those regulatory commitments.
If there are any questions or if additional information is-required, please contact Mr. Thomas Harding at (585) 771-5219 or at Thomas.Hardin Jr(cenqllc.com JhCarlin
STATE OF NEW YORK:
- TO WIT:
COUNTY OF WAYNE:
I, John Carlin, being duly sworn, state that I am Vice President, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this request on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordlance with company practice and I believe it to be reliable.
Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Monroe, this day of October, 2010.
WITNESS my Hand and Notarial Seal:
My Commission Expires:
Notary Public SHARON L. MILLER Notary Public, State of New York Registration No. 01MI6017755 Monroe County 0**
rnommission Expires December21, 2 Date
Attachment:
Ginna LLC Response to Regulatory Commitments: Debris Transport Analysis And Strainer Head-Loss Testing.
CC:
W. M. Dean, NRC D.V. Pickett, NRC Resident Inspector, NRC (Ginna)
P.D. Eddy, NYSDPS A.L. Peterson, NYSERDA 2
ATTACHMENT Ginna LLC Response to Regulatory Commitments: Debris Transport Analysis And StrainerHead-Loss Testing.
ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
==
Introduction:==
The following information serves to fulfill commitments to update the-NRC, as identified in of Ginna LLC's response to the NRC in a letter dated April 6, 2010, on activities resulting from response to request for additional information (RAI) regarding GL 2004-02, letter dated December 4, 2009.
Debris Transport Analysis Commitment:
The debris transport analysis will be revised to:
" Remove credit for any small fiberglass debris retention in upper containment
" Incorporate the potential for 0. 8% fine debris to wash out of the reactor cavity and transport to the ECCS sump strainer
" Remove credit for any fine debris settling in the recirculation pool.
Response to Debris Transport Analysis Commitment:
As a result of teleconference discussions with the NRC regarding Ginna's updated GL 2004-02 RAI responses, the Ginna Debris Transport Analysis, ALION-CAL-GINNA-4376-03, Revision 3, was revised on June 8, 2010, thereby fulfilling the commitment to have it revised by July 30, 2010.
The Ginna Debris Transport Analysis revision incorporates the agreed upon changes, as delineated in the following:
- Removed credit taken for holdup of small pieces on grating in upper containment. (RAI Response 3.0)
- Removed credit taken for settling of fine debris in the active recirculation pool. (RAI Response 3.7)
- Reduced credit taken for the transport of fine debris to the inactive cavity. Incorporated the potential for 0.8% of the fine debris to wash out of the reactor cavity and transport to the Emergency Core Cooling System (ECCS) sump strainer. (RAI Response 3.6)
- Added Appendix 6 to discuss transport of fines from the inactive cavity to the recirculation pool. (RAI Response 3.6)
- Incorporated results of the plant specific erosion test report.
As a result of the Ginna Debris Transport Analysis revision, the quantity of debris calculated to transport to the sump strainers increased from that previously calculated. The following tables are a comparison of the quantities determined to be transported to the sump between the latest and the earlier revision of the Ginna Debris Transport Analysis.
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ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
CASE 1 - Worst Case Break in Steam Generator Compartment "A" Debris Debris Quantity at Sump Debris Quantity at Sump Debris Type Debris Size Quantity ALION-CAL-GINNA-4376-03, ALION-CAL-GINNA-4376-03, Generated Revision 02 Revision 03 Fines 90.2 ft' 55.9 ft 3 75.8 ft3 Small Intact 3
3.2 ft3 6.3 ft3 Pieces Eroded to Fines 316.4 ft 9.5 ft3 25.3 ft 3 Thermal Wrap Large Intact 107.8 ft3 0
ft ft 3 Pieces Eroded to Fines 4.3 ft3 4.3 ft 3 Intact Pieces 115.4 ft3 0 ft 3 0 ft 3 Total 629.8 ft3 72.9 ft 3 111.7 ft3 Fines 9.5 ft3 5.9 ft 3 8.0 ft 3 Small Intact ft3 12.8 ft 3 32.4 ft3 Pieces Eroded to Fines 0 ft 0 ft3 Temp Mat Large Intact 5.6ft3 2.1 2.1 ftf Pieces Eroded to Fines 0 ft3 0 ft3 Intact Pieces
- 6. ftý 2.3 ft 3 2.3 ft3 Total 58.8 ft3 23.1 ft3 44.8 ft3 Fines 8.7 ft 7.2 ft3 7.3 ft3 Small Intact 30 ft3 0 ft3 Pieces Eroded to Fines 6.9 3.5 ft3 3.5 ft3 Total i5.6 ft3 10.7 ft3 10.8 ft3 Qualified Fines 757 lb 628 lb 636 lb Phenolics Chips 199 lb 0 lb 0 lb Qualified IOZ Fines 182 lb 151 lb 167 lb Small Pieces 1656 ft2 0 ft2 0 ft 2 RMI Large Pieces 552 t2 0 ift 2
0 ft 2
Total 2208 ft2 0 ft2 0 ft2 Dust/Dirt Fines 85 lb 85 lb 85 lb Latent Fiber Fines 15 lb 15 lb 15 lb Page 2
ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
CASE 2 - Worst Case Break in Steam Generator Compartment "B" Debris Type Debris Size Fines Small Intact Pieces Eroded to Fines Thermal Wrap Large Intact Pieces Eroded to Fines Intact Pieces Total Fines Small Intact Pieces Eroded to Fines Temp Mat Large Intact Pieces Eroded to Fines Intact Pieces Total Fines Cal-Sil Small Intact Pieces Eroded to Fines Total Qualified Fines Phenolics Chips Qualified IOZ Fines Small Pieces RMI Large Pieces Total Dust/Dirt Fines Latent Fiber Fines Debris Quantity Generated Debris Quantity at Sump ALION-CAL-GINNA-4376-03, Revision 02 Debris Quantity at Sump ALION-CAL-GINNA-4376-03, Revision 03 Page 3
ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
Strainer Head-Loss Testing Commitment:
The strainer head loss testing will be re-performed to:
" Include 10% erosion of the debris, determined to be transported to the sump strainer that does not become part of the strainer debris bed, to account for any potential for erosion of the debris pile in front of the face of the strainer
" Use appropriate quantity of Cal-Sil fines, without crediting a zinc dust surrogate.
Response to Strainer Head-Loss Testing Commitment:
As a result of the analysis in debris transport to the sump strainers, new strainer head loss testing was conducted, thereby fulfilling the commitment to re-test by September 30, 2010. Two series of head loss tests, in July 2010 and September 2010, were conducted with the new debris quantities. The largest quantity of debris, for each debris type and size, was used without regard to Case. This results in the most conservative test results, and is bounding for all break locations.
The debris used in the head loss testing was the actual debris material (cal-sil, Thermal Wrap, Temp Mat), except for the use of zinc dust for inorganic zinc coating (IOZ), stone flour for dust/dirt and phenolic coating fines, and Thermal Wrap for latent fiber. The use of these materials during testing addresses the NRC's concern for the previous use of zinc dust as a surrogate for cal-sil.
Additionally, to address the potential for erosion of the debris pile in front of the strainer, 10% of the debris pile Thermal Wrap and Temp Mat small and large pieces, and 50% of the debris pile cal-sil small intact pieces were also added as fines to the testing debris quantities. The following table provides the derivation and scaled quantities of the debris used for testing.
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ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
Ginna Strainer Head Loss Testin2 - 2010 Quantities to Use Debris Type and Size Case 1 Case 2 Wost in Strainer Head Loss Testing Debris Total Debris Total Worst Case Debris Debris Quantity Quantity Debris Quantity Quantity Quantity Quantity Quantity at Sump Transported Quantity at Sump Transported Transported for Testing Quantities to Use Generated (17D ZOI)
(incl. debris Generated (17D ZOI)
(incl. debris (incf. debris Scaling Factor in Strainer Head (17D ZOI)
(No Settling) pile erosion)
(17D ZOI)
(No Settling) pile erosion) pile erosion) of 51.04 Weight Loss Testing ft3 ft3 ft3 ft3 ft3 ft3 ft3 ft3 Ibs kg Thermal Wrap Fines 90.20 75.80 105.78 90.70 76.20 99.01 105.78 2.07 4.97 316.40 Small Pieces Intact 6.30 5.92 207.10 194.67 194.67 3.81 9.15 Fines 25.30 318.60 6.40 107.80 Large Pieces Intact 0.00 0.00 13.00 12.22 12.22 0.24 0.57 Fines 4.30 108.10 3.20 Intact Blankets 115.40 0.00 0.00 115.70 15.00 15.00 15.00 0.29 0.71 Debris Total Debris Total Worst Case Debris Debris Quantity Quantity Debris Quantity Quantity Quantity Quantity Quantity at Sump Transported Quantity at Sump Transported Transported for Testing Quantities to Use Generated (11.7D ZOI)
(incl. debris Generated (11.7D ZOI)
(incl. debris (incl. debris Scaling Factor in Strainer Head (11.7D ZOI)
(No Settling) pile erosion)
(11.7D ZOI)
(No Settling) pile erosion) pile erosion) of 51.04 Weight Loss Testing ft3 ft3 ft3 ft3 ft3 ft3 ft3 ft3 Ibs kg Temp Mat Fines 9.50 8.00 10.07 7,70 6.50 8.38 10.07 0.20 1.78 37.70 30.60 Small Pieces Intact 32.40 30.46 26.30 24.72 30.46 0.60 5.37 Fines 0.00 0.00 5.60 13.30 Large Pieces Intact 2.10 1.97 5.10 4.79 4.79 0.09 0.85 Fines 0.00 0.00 Intact Blankets 6.00 2.30 2.30 14.10 5.40 5.40 5.40 0.11 0.95 Page 5
ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
Ginna Strainer Head Loss Testing - 2010 Quantities to Use Debris Type and Size Case 1 Case 2 Wost in Strainer Head Loss Testing Debris Total Debris Total Worst Case Debris Debris Quantity Quantity Debris Quantity Quantity Quantity Quantity Quantity at Sump Transported Quantity at Sump Transported Transported for Testing Quantities to Use Generated (6.4D ZOI)
(incl. debris Generated (6.4D ZOI)
(incl. debris (incl. debris Scaling Factor in Strainer Head (6.4D ZOI)
(No Settling) pile erosion)
(6.4D ZOI)
(No Settling) pile erosion) pile erosion) of 51.04 Weight Loss Testing ft3 ft3 ft3 ft3 ft3 ft3 ft3 ft3 Ibs kg Cal-Sil Fines 8.70 7.30 10.80 14.70 12.30 17.34 17.34 0.34 5.10 Small Pieces Intact 6.90 0.00 0.00 11.50 3.80 3.57 3.57 0.07 1.05 Fines 3.50 3.90 Debris Debris Debris Debris Quantity Debris Quantity Quantity Quantity at Sump Total Quantity at Sump Total Worst Case for Testing Quantities to Use Generated (1OD ZOI)
Quantity Generated (1OD ZOI)
Quantity Quantity Scaling Factor in Strainer Head (lOD ZOI)
(No Settling)
Transported (10D ZOI)
(No Settling)
Transported Transported of 51.04 Weight Loss Testing lbs lbs lbs lbs lbs lbs lbs lbs lbs kg Qualified Phenolic Fines 757.00 636.00 636.00 869.00 730.00 730.00 730.00 14.30 14.30 Chips 199 0
0 199 26 26 26 0.51 0.51 Debris Debris Debris Debris Quantity Debris Quantity Quantity Quantity at Sump Total Quantity at Sump Total Worst Case for Testing Quantities to Use Generated (10D ZOI)
Quantity Generated (10D ZOI)
Quantity Quantity Scaling Factor in Strainer Head (10D ZOI)
(No Settling)
Transported (10D ZOI)
(No Settling)
Transported Transported of 51.04 Weight Loss Testing lbs lbs lbs lbs lbs lbs lbs lbs lbs kg Qualified IOZ Fines 182.00 167.00 167.00 210.00 190.00 190.00 190.00 3.72 3.72 Page 6
ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
Ginna Strainer Head Loss Testin2 - 2010 Quantities to Use Debris Type and Size Case 1 Case 2 Wost in Strainer Head Loss Testing Debris Quantity Debris Debris Total Debris Debris Total Worst Case forTesting Quantities to Use Quantity Quantity Quantity Quantity Quantity Quantity Quantity Scaling Factor in Strainer Head Generated at Sump Transported Generated at Sump Transported Transported of 51.04 Weight Loss Testing ft2 ft2 ft2 ft2 ft2 ft2 ft2 ft2 lbs kg RMI Small Pieces 1656.00 0.00 0.00 1656.00 646.00 646.00 646.00 12.66 1.04 Large Pieces 552.00 0.00 0.00 552.00 215.00 215.00 215.00 4.21 0.35 Debris Quantity Debris Debris Total Debris Debris Total Worst Case for Testing Quantities to Use Quantity Quantity Quantity Quantity Quantity Quantity Quantity Scaling Factor in Strainer Head Generated at Sump Transported Generated at Sump Transported Transported of 51.04 Weight Loss Testing lbs lbs lbs lbs lbs lbs lbs lbs lbs Dust/Dirt Fines 85.00 85.00 85.00 85.00 85.00 85.00 85.00 1.67 1.67 Debris Quantity for Debris Debris Total Debris Debris Total Worst Case Testing Quantities to Use Quantity Quantity Quantity Quantity Quantity Quantity Quantity Scaling Factor in Strainer Head Generated at Sump Transported Generated at Sump Transported Transported of 51.04 Weight Loss Testing lbs lbs lbs lbs lbs lbs lbs lbs lbs Latent Fiber Fines 15.00 15.00 15.00 15.00 15.00 15.00 15.00 0.29 0.29 Page 7
ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
The head loss testing results, for the tests conducted in July 2010 and September 2010, are summarized in the following table. Additionally, test results from March 2008 are included for comparison purposes.
Total Head Tested Head Loss Loss Temperature Head Normalized Including Test Date Loss to 195 OF Strainer (mbar)
(mbar)
Ducts (mbar)
Mar-08 20 95.2 29.7 33.6 Jul-10 48.1 40.5 22.3 26.2 Sep-10 41.8 29.7 14.6 18.5 Acceptance Criteria 2.99 ft*
89.4 29.9 mbar/ft The primary difference between the tests performed in July 2010 and September 2010 is the sequence in which the debris was added to the test loop. All other parameters were the same. In the July 2010 test, the precipitate was added last, after all fiber and particulate was added. In the September 2010 test, the precipitate was added following the addition of all fiber and particulate fines, and before the fiber and particulate small and large pieces. The later test was designed to determine the effect of the precipitant on the potential formation of a thin bed.
In the July 2010 test, the most rapid head loss increase occurred after the addition of the precipitant. The quantity of fiber fines, fiber small pieces, and fiber large pieces was enough to form a "bridge" across the face of the strainer at the pocket openings. This layer of fiber across the face of the strainer was able to filter out the precipitant and was strong enough to withstand the created head loss. However, due to the pocket design and strainer configuration, significant open strainer surface area remained to preclude additional head loss increase.
In the September 2010 test, the precipitate addition did not result in a rapid head loss increase.
These results are due to the behavior of the layer build-up. The precipitate caused the layer of fiber and particulate fines to become compressed, diverting more and more of the flow through the relatively open areas of the strainer. The addition of precipitate before the fiber and particulate small and large pieces resulted in a less distributed layer of precipitate, thereby lessening its impact on overall strainer head loss. The most rapid rise in head loss occurred following the Page 8
ATTACHMENT Ginna LLC Response to Regulatory Commitments:
Debris Transport Analysis And Strainer Head-Loss Testing.
addition of the fiber and particulate small and large pieces, after the precipitate had been filtered by the fines. The fiber and particulate small and large pieces tended to enter the pockets with the more open area, creating additional head loss increase. However, the impact of "bridging" across the pockets had a lesser impact on head loss as compared to the July 2010 test, due to the absence of precipitate.
The 2010 head loss tests resulted in a slightly lower head loss as compared to that from March 2008. Slight variation of results between tests is expected, given the number of variables that can differ from test to test. The most significant difference in the tests performed, aside from the differences in debris quantity, is the rate at which the chemical precipitate was added. In the March 2008 head loss test, the entire chemical precipitate quantity was conservatively added within 20 minutes. In the 2010 tests the chemical precipitate was added at a rate greater, but more consistent with, the formation rate of the chemical precipitate in containment.
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