ML17249A256

Forwards Description of NRC Requirements for Auxiliary Feedwater Sys,Both Generic & plant-specific

ML17249A256
Person / Time
Site:	Ginna
Issue date:	10/22/1979
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	White L ROCHESTER GAS & ELECTRIC CORP.
References
TASK-10, TASK-RR NUDOCS 7911090306
Download: ML17249A256 (30)

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. NlIgTllRY90'l<@II'l Docket Ho.: 50-244 Og 33 'l979 Mr. Leon D. White, Jr., Vice-President E]ectrfc 8 Steam Production Rocheste'r Gas and Electric Corporation 89 East Avenue Rochester, New York 14649

Dear,

Mr. 'White:

SUBJECT:

NRC RE(UIREMENTS FOR AUXILIARY NUCLEAR, POWER PLANT, UNIT 1

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iJCarter G2ecn DEisenhut' DFKoss 0!?UP~2 t;r. 'hief FEEDWATER SYSTEMS AT ROBERT ED GINNA The purpose of this letter is to advise you of our requirements for the auxiliary feedwater systems at the subject facility.

These requirements were identified during the cqurse of the HRR Bulletins and,Orders Task

~ Force review of operating reactors in light of the accident at Three Mile Island, Unit 2.

t Enclosure 1 to this letter identifies each of the requirements.applicable to the subject faci'lity.

These requirements are of two types, (1) generic

,requirements applicable to most Westinghouse-designed operating plants, and (2) plant-specific requirements applicable only to the subject facility.

Enclosure 2 contains a generic request for additional information regarding auxiliary feedwater system flow requirements.

The designs arid procedures of the subject facility should be evaluated against.

the.applicable requirements specified in Enclosure 1 to determine the degree to which the facility currently conforms to these requirements.

The results of this evaluation and an associated schedule and commitment for implementation of required changes or actions should be provided for NRC staff review within thirty days of receipt of this letter.

Also, this schedule should indfcate -,

your date for submittal of information such as design changes, procedure changes or Technical Specification'changes to be provided for staff review.

You may also provide your response to the items in Enclosure 2 at that time.,

In addition to the 'requirements identified in this letter, other requirements which may be applicable to the subject. facility are expected to be generated by the Bulletins-and Orders Task Force.

Such requirements are those resulting from our review of.the loss-of-feedwater event and the small. break loss-of-coolant accident as described in the Westinghouse report 'WCAP-9600, "Report on Small

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Break Accidents for Westinghouse NSSS System."

Our specific concerns~i'nclude systems rel'iability (other than. the auxiliary feedwater system),

analyses, guidelines and procedures for operators, and operator training.

4 We plan to identify, in separate correspondence, the. requirements resulting from the additional items from the Bulletins and Orders Task Force review.

Sin'cerely, Qripinal sigh"< ~

Enclosures:

As stated Darrell G. Eisenhut, Acting Director

'Division of Operating Reactors Office of Nuclear Reactor Regulation

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+"~~ o 4y*~4 Docket No.: 50-244 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 October 22, 1979 Mr. Leon D. White, Jr., Vice-President Electric 5 Steam Production Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649

SUBJECT:

NRC RE(UIREMENTS FOR AUXILIARYFEEDWATER SYSTEMS AT ROBERT E.

GINNA NUCLEAR POWER PLANT, UNIT 1

The purpose of this letter is to advise you of our requirements for the auxiliary feedwater systems at the subject. facility.

These requirements were identified during the course of the NRR Bulletins and Orders Task Force review of operating reactors in light of the accident at Three Mile Island, Unit 2.

Enclosure 1 to this letter identifies each of the requirements applicable to the subject facility.

These requirements are of two types,

( 1) generic requirements applicable to most Westinghouse-designed operating plants, and (2) plant-specific requirements applicable only to the subject facility.

Enclosure 2 contains a generic request for additional information regarding auxiliary feedwater system flow requirements.

The designs and procedures of the subject facility should be evaluated against the applicable requirements specified in Enclosure 1 to determine the degree to which the facility currently conforms to these requirements.

The results of this evaluation and an associated schedule and comitment for implementation of required changes or actions should be provi'ded for NRC staff review within thirty days of receipt of this letter.

Also, this schedule should indicate your date for submittal of information such as design changes, procedure changes or Technical Specification changes to be provided for staff review.

You may also provide your response to the items in Enclosure 2 at that time.

In addition to the requirements identified in this letter, other requirements which may be applicable to the subject facility are expected to be generated by the Bulletins and Orders Task Force.

Such requirements are those resulting from our review of the loss-of-feedwater event and the small break loss-of-coolant accident as described in the Westinghouse report WCAP-9600, "Report on Small 7911 090+ ~ g F'

Mr. Leon D. White October 22, 1979 Break Accidents for Westinghouse HSSS System."

Our specific concerns include systems reliability (other than the auxiliary feedwater system),

analyses, guidelines and procedures for operators, and operator training.

We plan to identify, in separate correspondence, the requirements resulting from the additional items from the Bulletins and Orders Task Force review.

Sincerely,

Enclosures:

As stated (cv'arrel I

G.

Ei senhut, Acting irectoi Division of Operating Reactors Office of Nuclear Reactor Regulation

Mr. Leon D. White, Jr.

October 22, 1979 cc w/enclosures:

Lex K. Larso i, Esquire

LeBoeuf, Lamb, Leiby 8 MacRae 1757 N Street, N.

W.

Washington, D. C.

20036 Mr. Michael Slade 12 Trailwood Circle Rochester.,

New York 14618 Rochester Committee for Scientific Information Robert E. Lee, Ph.D.

P. 0.

Box 5236 River Campus Station Rochester, New York 14627 Jeffrey Cohen New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza

Albany, New York 12223 Director, Technical Development Programs State of New York Energy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Herbert Grossman, Esq.,

Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Dr. Richard F. Cole Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.

C.

20555 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.

C.

20555 Rochester Public Library 115 South Avenue Rochester, New York 14604

X.4 GINNA AUXILIARY FEEDWATER SYSTEM X.4. 1 X.4. 1. 1 S stem Descri tion Confi uration -Overall Desi n

A simplified flow diagram of the Ginna auxiliary feedwater system (AFWS) is presented in figure 1.

The AFWS consists of a main (M)

AFWS and a standby (SB)

AFWS.

The (SB) 'AFWS was installed subsequent to the (M) AFWS and has recently been placed in service.

The'(M)

AFWS consists of 3 pumps (2 motor-,.driven pumps, each 200 gpm, and 1 turbine-driven 400 gpm).

Normally, each motor driven pump supplies one steam generator (SG) but,with operator action either motor-driven pump can provide feedwater to both steam generators (SG).

The turbine-driven pump normally provides feedwater to both SGs.

Only the flow from one motor-driven AFW pump to one SG is needed to cool the plant down to the temperature where the RHR system can be used to bring the plant to safe shutdown.'he steam generator would boil dry in approximately 30 minutes without any feedwater flow and a reactor trip.

All three of the (M) AFWS are located in the same room and could be rendered inoperable as a result of a high energy line break.

The (SB)

AFWS was added to provide independent AFWS capability following such an event.

The (SB)

AFWS is in a separate plant area from the (M) AFWS.

The (SB)

AFWS consists of 2 motor-driven pumps.

Each motor pump has a

capacity of 200 gpm.

The pumps are in the same room~but separated by a partial wall.

Thus the (SB)

AFWS functions independent of the (M)

AFWS.

The primary sourcesof water for the (M) AFWS are two 30,000 gallon condensate storage tanks (CST).

The tanks are non-seismic Category I and are cross-connected through locked-open

'manual operated valves.

The (M)

AFWS pumps can draw from either tank.

The two condensate tanks are connected to the condenser hotwell and can be connected to a 100,000

~gallon non-seismic Category I condensate storage tank.

The pump that would transfer-water from either the condenser hotwell or the 100,000 gallon tank to the 30,000 gallon tanks is powered fron a non-safety grade supply.

There is an emergency procedure for connecting to these water sources'onnectio'n to either of these water sources requires operator action, which takes approximately 15 minutes.

The (M) AFWS also has a secondary seismic Category I water source;

namely, the

.service water system (SWS).

The primary water source for'he (SB)

AFWS is the SWS.

The SWS draws water from Lake Ontario. It is esti-mated to take approximately 5 minutes to connect the (M) AFWS to the SWS. There is an emergency procedure for connecting the (M) AFWS to the SWS.

X.4. 1.2 Com onents - Oesi n Classification The (M) AFWS, the (S8)

AFMS, and the SWS have a Class I seismic qualification; The primary source (two 30,000 gallon condensate storage tanks) and associated supply lines to the (M) AFWS pumps suction are non-Class I seismic.

X.4.1.3 Power Sources The main and standby auxiliary feedwater systems are powered from the emergency buses.

The two motor-driven pumps, associated valves and lube oil cooling system for the turbine driven pump in the main auxiliary feedwater system receive motive power from two redundant and independent AC emergency buses.

The steam admission and water discharge valves and lube oil cooling systems associated with the steam turbine-driven pump in the main auxiliary feedwater system receive power from the electrical divisions indicated in Figure l.

The two motor driven pumps and valves in the standby auxiliary feed-water system are supplied from redundant and independent AC emergency buses.

The (SB)

AFMS is interlocked with the (N) AFWS so that both are not simultaneously loaded onto the vital AC buses to prevent overloading the vital buses on loss of offsite power.

X.4. 1.4 X.4. 1.4. 1 Instrumentation and Controls Controls Upon 1oss of the main feedwater

system, the (H) AFMS is automatically initiated to-supply water to the steam generators.

Thereafter, the 1'evel in the steam generator is manually controlled from the control

room by adjusting valve positions.

The (SB)

AFWS is manually initi-ated and manually controlled from the control room by adjusting valve positions.

Information Available to 0 erator System information available to the operator in the control room to assess the performance of the auxiliary feedwater system is as fol 1ows:

. Indicating red (open) and green (close) lights associated with each electrical and pneumatic operated valve.

.Steam generator level

.Steam generator pressure

.Auxiliary feedwater flow indication in each of the two water paths to the steam generators as related to the (M) AFWS.

l

.Auxiliary feedwater flow indication in each of the two water paths to the steam generator as related to the (SB) AFWS.

I I

The iH)

'AFW pumps are not<<Matically tripped as a result of low I

pump suction pressure conditions.

This was a potential concern because the non-seismic condensate storage tank supply lines could be severed by a seismic event causing the loss of suction to the (M)

AFWS pumps.

There is also no alarm or indication in the control room to alert the operator of low suction pressure conditions at AFWS pumps.

However the operator does have CST level and pump discharge pressure and flow indication.

Further, however, in the event of

seismic damage to the (M) AFWS primary water source, the (SB)

AFWS would be available since its water souce (SWS) is seismic Category I.

Initiatin Si nals-for Automatic o eration The steam turbine-driven and motor <<~ver pumps and corresponding valves in the (M) AFWS are automatically initiated by the following signals:

Motor-Driven Auxiliary Feedwater Pump A

'/3 lo-lo level in either SG Both main feedwater pumps trip Safety injection initiation Motor-Driven Auxiliary Feedwater Pump B

2/3 lo-lo level in either SG Both main.feedwater pumps trip

..Safety injection initiation

'Steam Admission Valve to the Turbine-Driven Auxiliary Feedwater Pump 2/3 lo-lo level in both steam generators Loss of voltage on both 4 KV buses (non-safety buses)

.Motor anU Turbine Driven Pumps Discharge Valves pump start

The (SB)

AFWS is manually initiated.

Both the main and standby auxiliary feedwater systems flow paths to the steam generators are not isolated automatically as a result of a steam or feedwater (main or auxiliary) line break.

The isolation is accomplished manually.

X.4.l. 5 Testin and Technical S ecifications Subsequent to this review, the licensee proposed a Technical Specification revision which provides limiting conditions of operation and periodic testing for both the (H) and (SB)

AFWS.

These proposed revisions have been.revewed by the staff (Systematic Evaluation Program) and found acceptable.

The Technical Specific-ation revisions were approved in Amendment 29 to the Ginna operating license (DPR"18) dated August 24, 1979.

X.4. 2 X.4.2.1 Reliabilit Evaluation Dominant Failure Modes LOFW with offsite ower available Failure of operator to throttle pumps and failure of operator to switch to service water supply and failure of operator to actuate the (SB) AFWS.

The condensate storage tanks have 15,000 gallons dedicated to the (M)

AFWS.

When the system starts, all 3 pumps have the possibility of starting.

Their total capacity is 800 gpm.

However, only 200 gpm

flow to one SG is necessary.

To achieve the 200 gpm,flow rate, the operator must either throttle or shut off some pumps.

If this action is not taken, the CSTs could empty in 20 minutes.

The short time interval may not allow the operator time enough to valve in the backup water source from the hotwells and 100,000 gallon tank.

A procedure is available; however, it requires operator action outside the control room.

The next alternative is to

'open a service water system valve which is outside the control room.

A procedure exists and the licensee estimates 5 minutes to take this action.

The final alternative is'o valve in from behind the control panel the (SB)

AFMS for which procedures exist.

If the operator throttles the pumps correctly initially, there should be adequate time and supply to prevent a problem.

The licensee esti-mates the steam generator boil dry time to be approximately 30 minutes which should allow sufficient time to valve in the service water.

LOFW with onsite ower available Same as for LOFT with offsite power available.

For this event the condenser hotwell and 100,000 gallon backup condensate storage tank are not available since the transfer pumps are powered from non-vital AC. bus.

LOFW with onl DC available Failure of the turbine pump train.

This is the short term failure.

For this condition, the turbine could eventually fail since the AC powered service water pumps are not operating.

Thus, there is no water flow to cool the turbine pump lube oil.

The CST (assuming 15,000 gal level) could go dry in 40 minutes and also cause failure.

The backup sources from the service water and (%) AFWS are all AC dependent and would not be available.

See Recommendations.

Princi al De endencies l.

All (M) AFWS pumps are in the same room with high energy piping over-head.

However, a postulated high energy line break in this room is mitigated by the installation of the (SB)

AFWS in a separate plant area.

2.

The DC controlled turbine lube oil pump forces oil through a

heat exchanger which depends on the AC powered service water system to cool the oil.

In a total loss of AC, the turbine could fail.

See Recommendat'ions.

X.4.3 Recommendations for this Plant The short-term recommendations (both generic, denoted by GS, and plant-specific) identified in this section represent actions to improve AFW system reliability that should be implemented by January 1, 1980, or as

soon thereafter as is practicable.

In general, they involve upgrading of Technical Specifications or establishing procedures to avoid or mitigate potential system or operator failures.

The long-term (both generic, denoted by GL, and plant-specific) recommendations identified in this sec-tion involve system design evaluations and/or modifications to improve AFW system reliability and represent actions that should be implemented by January 1, 1981, or as soon thereafter as is practicable.

X.4.3. 1 Short-Term 1.

Recommendation GS The licensee has stated that it throttles AFW system flow to avoid water hammer.

The licensee should reexamine the practice of throttling AFW system flow to avoid water hammer.

The licensee should verify that the AFW system will supply on demand sufficient initial flow to the necessary steam generators to assure adequate decay heat removal following loss of main feedwater flow and a reactor trip from 100K power.

In cases where this reevaluation results in an increase in initial AFW system flow, the licensee should provide sufficient information to demonstrate that the reaquired initial AFW,system flow will not result in plant damage due to water hammer.

2.

Recommendation

" The plant has AC dependent service water cooling of the lube oil for the turbine driven pump.

The

"10-turbine driven feedwater pump has an AC lube oil pump and a

OC lube oil pump.

These pumps direct the oil through a

heat exchanger which depends on the AC powered service water system pumps to cool the oil.

In the event of a total loss of AC power, lube oil cooling capability for the turbine-driven pump will be lost due to the loss of AC power to the service water pumps.

The turbine-driven pump could cease to function due to the loss of lube oil cooling.

The as-built plant should be capable of providing the required AFM flow for at least two hours from one AFW pump train independent of any alternating current power source.

Subsequent to this. review, the licensee conducted a test to demonstrate that the turbine-driven pump could operate for two hours without lube oil cooling water flow.

The test was run for one hour and 45 minutes with the final one hour and 15 minutes of the test with the pump at rated speed,but at 5(C of required plant flow.

Preliminary test results indicate the pump and turbine bearing temperatures remained within allowable limits.

The staff is evaluating these test results to determine if the test data will support a

conclusion that the required AFM flow can be provided independent of any AC power source.

Until this evaluation is complete, interim emergency procedures should be established which provide for an individual to be stationed at the turbine-driven pump in the event of the loss of all

-11" alternating current power to monitor pump/turbine bearng and/or lube oil temperatures.

If necessary, this operator would operate the turbine-driven pump in an on-off mode until alternating current power is restored.

Adequate lighting powered by direct current power sources and communications at local stations should also be provided if manual initiation and control fo the AFW system is needed.

(See Recommendation GL-3 for the longer term resolution of this concern).

Recommendation GS-6 The licensee should confirm flow path availability of an AFW system flow train that has been out of service to perform periodic testing or maintenance as follows:

Procedures should be implemented to require an operator to determine that the AFW system valves are properly aligned and a second operator to independetly verify that the valves are properly aligned.

The licensee should propose Technical Specifications to assure that prior to p'lant startup following an extended cold shutdown, a flow test would be performed to verify the normal flow path from the primary AFW system water source to the steam generators.

The flow test should be conducted-with AFW system valves in their normal alignment.

12 "

Recommendation GS The licensee-should verify that the automatic start (iMj AFW system signals and associated circuitry are safety-grade.

If this cannot be verified, the jN) AFW system automatic initiation system should be modified in the short-term to meet the functional requirements listed below.

For the longer term, the automatic initiation signals and c>rcui>>><<d inven<o~ o~ condensate storage tank water r

~ E gravity feed to the turbine pump suction to as<<<<

. that there is a

water source sufficient to supply the required AFW flow for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> independent of any AC power source.

3.

Recommendation

- GL-5.

The licensee should upgrade the AFW system automatic initiation signals and circuits to meet safety-grade requirements.

4.

There is no provision for either the main or standby AFWS automatically terminate flow to a depressurized steam generator and automatically provide flow to the intact steam generator.

This is accomplished by the control room operator.

The lack of this automatic capability will be further evaluated as part of the Systematic Evaluation Program.

5.

The main and standby AFWSs will be reevaluated for internal and external missiles, seismic design requirements, and flood and tornado protection as part of the Systematic Evaluation Program.

LEGEND M.D

- MOTOR DRIVEN T.D

- TURBINE DRIVEN

- NORMALLYCLOSED foal

- NORMALLYOPEN

- AIR OPERATED

- MOTOR OPERATED SG

- STEAM GENERATOR I,II,III-POWER DIVISIONS A

- ALTERNATINGCURRENT D

- DIRECT CURRENT TB

- TURBINE FO

- FAILOPEN LO

- LOCKED OPEN PMP

- PUMP CONDENSATE STORAGE TANK1A 30,000 GAL LO LO LO CONDENSATE STORAGE TANK 1B LO LO LO 30,000 GAL CONDENSATE STORAGE TANK LO LO LO LC.

I-A M

II.A M

IA II.A I.A M

II.D M

A II.A M

~L.O.

C NOTES i PROPOSED ADDITIONTO BE IMPLEMENTEDIN THE SPRING OF 1980 HOSE

'00,000 GAL I

PMP m HOSE T.D AC LUBE OIL PUMP I.A PMP NON SAFETY BUS CONDENSER HOTWELL I-A A

I.A II.A M

II.A DC LUBE OIL PUMP ID II.A SEFIVICE p

WATER PUMPS SERVICE WATER SCREEN WELL AuxiliaryFeedwater System Ginna Figure 1 (Sheet 1)

OA

'iA SG OB II.A M

~NSIDE CONTAINMENT SG II D M

FO FO STANDBYAFWS LOOP Q I-A M

IA M

IA I.A M

.I-A M

t SERVICE WATER SYSTEM IA M

II-A M

INSIDE CONTAINMEN LOOP B II-A M

II.A M

II A II A II.A M

M

)

OTHER WATER SOURCES

~J TO ATMOSPHERE AuxiliaryFeedwater System Ginna Figure 1 (Sheet 2)

ENCLOSURE 2 L

Basis for Auxiliary Feedwater System Flow Reouirements As a result of recent staff reviews oV operating plant Auxiliary Feed-water Systems

{AFliS), the staff concludes that tho design bases and criteria. provided by licensees for establishing AFWS reouirements for flow to the steam generator{s) to assure adequate removal of reactor decay heat are nqt well defined or documented.

t'e require that you provide the following AFMS flow design basis infor-mation as applicable to the design basis transients and accident con-ditions for your plant.

l.

a.

Identify the plant transient and accident conditions considered in establishing AFVS flow requirements, including the following events:

1)

Loss of Hain Feed (LHFM) 2)

LMFM w/loss of offsite AC power 3)

LMFM w/loss of onsite and offsite AC power 4)

Plant cooldown 5)

Turbine trip with and without. bypass 6)

Hain steam isolation valve closure 7)

Hain feed line break 8)

Hain steam line break 9)

Small break LOCA 10)

Other transient or accident conditions not listed above A

b.

Describe the plant protection acceptance criteria and corres-oonding technical. bases used for each initiating event identi-fied above.

The acceptance criteria should address plant limits such as:

- Maximum RCS pressure (PORV or safety valve actuation)

- Fuel temperature or damage limits (DtS, PCT, maximum fue'1 central temperature)

- pCS cooling rate limit to avoid excessive coolant shrinkage

- Minimum steam generator level to assure sufficient steam generator heat transfer surface to remove decay heat and/or I

cool down the primary system.

2.'escribe the analyses and assumptions and corresponding technical justification used with plant condition considered in 1'.a.

above including:

a.

Maximum reactor power (including instrument error allowance) at the time of the initiating transient or accident.

b.

Time delay from initiating event to reactor trip.

c.

Plant parameter(s) which initiates AFMS flow and time delay between initiating event and introduction of AR'5 flow into steam generator(s).

d.

Minimum steam generator water level when initiating event occurs.

e.

Initial steam generator water inventory and depletion rate before and after AFMS flow comnences - identify reactor decay heat rate used.

f.

Maximum pressure at which steam is released from steam generator(s) and against which the AFM pump must develop su icient head.

g.

Minimum number of steam generators that must receive AFV flow; e.g.

1 out of 2?,

2 out of 4?

h.

RC flo>> condition - continued operation of RC pumps or natural circulation.

Maximum AFM inlet temperature.

j.

Following a postulated steam or feed line break, time delay assumed to isolate break and direct AFM flow to intact steam generator(s}.

AFN pump flow capacity allowance to accommodate the time delay and maintain minimum steam generator water level.

Also identify credit taken fox primary system heat removal due to blowdown.

k.

Volume and maximum temperature of water in main feed lines between steam generator(s}

and AFMS connection to main feed line.

l.

Operating condition of steam generator normal blowdown following initiating event.

m.

Primary and secondary system water and metal sensible heat used for cooldown and AFM flow sizing.

n.

Time at hot standby and time to cooldown RCS to RHR system cut in temperature to size AFM water source inventory.

3.

Verify that the AFM pumps in your plant will supply the necessary flow to the steam generator(s) as determined by items 1 and 2

above considering.a sinale failure.

identify th margin in sizing the pukp f1ow to allow for pump recirculation flow, seal leakage and pump wear.