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NRC-2019-000158 - Resp 1 - Final. Agency Records Subject to the Request Are Enclosed
	ML19046A222
Person / Time
Site:	Dresden, Braidwood, Zion
Issue date:	02/08/2019
From:	; NRC/OCIO
To:	;
Shared Package
ML19046A227	List: ML19046A221; ML19046A222; NRC-2019-0001, NRC-2019-000158- Request for Copies of All Records, Documents, and Electronic Data Relating to Use of Asbestos Insulation at the Following Facilities: Zion Nuclear Power Plant in Zion, Il, Braidwood Generating Station in Braceville, Il;
References
	FOIA, NRC-2019-000158
	Download: ML19046A222 (67)
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/.iun. II. <,Otf)'>*.!**r l'dH1--1h..!IIHI 7JlA97016 September 5,} 997 U.S. Nuclear Regulatory Commimon Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Zion Nuclear Power Station, Units 1 and 2 Response to Request for Additional Information Concerning Containment Coatings \

NRC Docket Nos. SQ-295 and S0:JQ4

References:

1) Letter from C. Shiraki. NRC. to I. Johnson. Commonwealth Edison, dared May 23. 1997, Request for Additional Information

Concerning Containment Coatings at Zion Station, Units l and 2

2) Letter from J. H. Mueller. Commor.wealth Edison, to U.S.

Nuclear Regulatory Commission, dated February 5, 1997.

Submittal of Requested Documentation

3) Letter from A. B. Beach. NRC. to J. H. Mueller. Commonwealth Edison. daled June 6, 1997, Supplement to Confirmatory Action l.ctter Rlll-97-002 This letter provicres Commonwealth Edison*s (ComEd's) response to the NRC Request for Additional Information (RAJ) concerning containment coatings at Zion Station (Reference l).

During the current Unit 2 outage. concerns were identified regarding the qualification and condition of coatings in the containment building. In response to an NRC request made in a January 7, 1997. teleconference. ComEd submitted. via Reference 2.

documentation associated with the containment coating issues. Following additional teleconferences. *on May I and May 15. 1997. the NRC requested, in Reference I, additional infonnation concerning these mucs. In a letter dated June 6, 1997.

(Reference 3) the NRC supplemcnred a previous Confirmatory Action Letter, and documented ComEd's intent to resolve containment coating concerns prior to re-stan of

&he uniL ComEd's response to the RAJ is provided in Attachment A to this letrer.

Based on lhe complexity of the coating issue. we would be pleased to meet with you at F'

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{ I your earliest convenience to discuss the details of this RAJ response 9709110060 970905 /ifi PDR MOCK Osoooatl p . PDlf' I. :. .. .

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ZRA97016 Paae 2 of2 Aitachment C to this Jetter lists the commitments made by ~omEd in this submitlal.

Please direct any questions yoo may have concerning this submittal to this office.

Respectfully*

. (2{L_

ohnC. Brons ite Vice President J

. Zion Nuclear Station Attachments Enclosures cc: NRC Regional Administrator - RIii Zion Station Project Manager - NRR Senior Resident Inspector - Zion Station Office of Nuclear Facility Safety - IDNS IONS Resident Inspector Zion NLA Engineering Manager Master Files Reg. Murance File DCD Licensing

ZRA97016 ATIACHMENT A RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION CONCERNING CONTAINMENT COATINGS AT ZION STATION

A1TACHMENT A RUPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION CONCERNING CONTAINMENT COATINGS AT ZION STATION Requested Information

1. In dltcUsslons with ComEd, the staff was Informed that a zone or lnftuence with a radl111 of 20 feet was selected. However, the analysis In the February 5, 1997, submittal atves a varlet)' or calculated radii for the zones of lnftuence depending on the type of coating, some of which are greater than 20 feet.

What Is the basis for the 20 root zone of lnftuence?

ComF.d Response The initial 20 foot Zone of Influence (ZOI) was based on preliminary information provided by the preparers of the ZOI Calculation (Attachment A of Reference 2). Al that time the majority of the ZOls calculated were 20 feel or less. The 20 foot ZOI was used for focusing the initial removal of unqualified coatings effort. Subsequently. the one 20 foot ZOI wa.~ superseded by individual ZOls. based on component coating type. The ZOI for a particular coating is a function of.specific gravity and dry film thickness (DPT).

The final ZOI Calculation addresses a range of coating systems, including coating systems not found in the Zion containment. The resulls of the ZOI Calculation are summari1..ed in Tables I through 3 of the ZOI Calculation.

Table I summarizes the results of the calculation for undocumented coatings inside Zion containment with known specific gravities.

Table 2 summarizes the results of the calculation for undocumented coatings for three different specific gravities with various D17fs. The Table 2 information is used to estimate ZOls for undocumented coatings inside the Zion containment with unknown specific gravities. * * *

Table 3 summari1-es the results of the calculation for documented coatings inside Zion

containment. The information in this table does not play a role in evaluating the quantity of undocumented coating which may reach the containment sump.

Note: the terms "'qualified" and "documented" in the context of this attachment are synonymous u are "unqualified" and ..undocumented."

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Req_... lnformaUon

2. nae February 5, lffl, submittal describes a zone or lnOuence calculatlon and a net positive auction bead (NPSH) calculation. nae zone of lnftuence calculaUon determined a zone of Influence for each paint type and th.e NPSH calculaUon predicted the largest amount of blockage that could be tolerated without loss of NPSH. However, there does not appear to be a connection between the two calculations.

Describe how the calculadom are used.

ComF.d Response The ZOI Calculation establishes the ZOI for a variety of coating systems. The net positive suction head (NPSH) calculation (Attachment B of Reference 2) establishes that 11.,6ft2 of sump screen open area blockage can be tolerated without *arfecting RHR pump operation. Using the System Materials Analysis Department (SMAD) Repon M-00282-97 (Attachment C of Reference 2) and the information detailed below. the maximum quantity of unqualified coating postulated to reach the sump screen was estimated to be approximately l ft2. The 1 fti was established based on an undocumented coating (SMAD Repon, Table I, item 195) that was not removed and has a credible pathway to the sump. This is much lt'ss than the 11.56 fti of screen blockage postulated to affect pump operation.

SMAD Repon, Table I represents a listing of items inside the Unit 2 containment for which the status of the coating qualification was unknown. Subsequent to the initial preparation of the list, several items in SMAD Report, Table I were detennined to have qualified coatings (3371 ftl). This is retlectcd by a "Y" in the SMAD Repon. Table I column labeled "Accept w/o Rem, (i.e .* Acceptable Without Removal). Two items on M

2 the list (items 5 and I03, totaling 3 fl ) were determined to have no coating.

Items with undocumented coating which were removed are annotated with a "Y" in the SMAD Repon. Table I column labeled "REM ITM" (i.e .* Removed Item). Items whose coating was removed are annotated with a "Y" in the SMAD Repon, Table l column labeled "REM PNT' (i.e., Removed Paint). This represcnL~ 2186 ft2 of undocumented coating.

For the remaining items on the list. with the exception of item 152. dry film lhickne~

(DfT) measurements were made and representative samples of specific gravities were determined such that the item's ZOI could be estimated. The coating ~iated with item 152 (Main Steam Line Supports) wa.~ determined to have a tonuous (not credible) path to the sump and no measurements were recorded. The ZOls for the undocumented coatings were estimated utilizing the measured Dl;"'fs, an assumed specific gravity and the parametric evaluation of ZOls provided in ZOI Calculation, Table 2. The specific gravity was wumed to be 1.6. This value is rounded down from the lowest specific gravity value found in the undocumented coatings inside the Zion containment with known specific gravities ( 1.61 from ZOI Calculation, Table I).

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The undocumenled coatings with a ZOI of less than 20 feet were either removed or were confinned to be localed outside their ZOI. While the ZOI calculations are based on the cenlerline of the sump. removal of coatings or components was based on radial measurement from the nearest edge of the sump. For example. if a component was calculaled to have a ZOI of 18.5 feet and il was physically localed 18.5 feet radially from the cenaerline of the sump, but was localed only 16 feet radially from the nearest edge of the sump screen. the coating or component would have been removed.

Por the items with unqualified coatings. with a ZOI greater than 20 feet. the coating location was verified to be outside its respective ZOI wilh 3 exceptions; iccms 34. 161, and 195. for all ilems except item 195, based on the experience of the personnel, the knowledge from walk downs, and a review of general arrangement and structural drawings. it was determined that the path from the component(s) to the sump wa.~

tonuous t~ the extent that the coating could not he transported to the sump (not a credible pathway), or that the trash curb at elevation 568' would prohihit the coating debris from reaching the sump. Item 195 is located inside its respective ZOI. The quantity of coating associated with this item is approximately I ft 2* Conservatively. it is a.~umed that Uie I ft 2 is transported to the sump and blocks the open area of the sump screen.

Requesled -Information

3.

Co~Ed took numerous actions to ensure the Integrity of the Unit 2 contaJnment coatings.

a. Describe, In detail, the steps taken to remove falled, undocumented and unquallffed coatlnp from the Zion, Unll 2, containment prior to Its next startup.

ComEd Response Identified failed coatings were removed hy scraping or grinding. as appropriate.

Undocumented coatings were removed by either removing the componcnL._ containing the undocumented coaling or removing the coating by scraping or grinding. This is reflected by a "Y" in the SMAD Report, Table I columns labeled "REM PNT" (i.e .*

Removed Paint) and "REM .ITM" (i.e., Removed Item).

Identification of the coaling to be removed came from several sources. Zion personnel along with coating specialisL~ performed walk downs of lhe Unit 2 containment specifically to identify locations of failed or undocumented coatings. In addition. system readine.u walk down teams were alerted to look for degraded coaling during suhscquent system walk downs in the containment. When identified. failed coatings were removed.

The disposition of undocumented coatings is described in the response to Question 2.

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b. &tlmate the amount or unquallRed paint remalnlng.-

Comt:d Respome It is estimated lhat 3100 ft2 of undocumented coating remains in Unit 2 containmenL Table l of the SMAD Report identified 8021 ft2 of equipment and component coatings for which the status of the coating qualification was initially unknown. As described in the response to Question 2, 3371 ft2 of coatings were subsequently detennined to be 2

qualified; 2186 ft2 of coatings were removed; and items representing 3 ft were detennined to not have a coating.

The remaining items on SMAD Report. Table 1 represent 2461 ft2 of undocumented coatings in containment. While the walkdowns which gene~ted SMAD Report, Table 1 were extensive, some areas could not effectively be examined. either from a radiological standpoint or from an inability to erect scaffolding to allow direct exaµ1ination. Based on 2

. these uncertainties, ComEd estimates thal the 2461 ft represents approximately 90% of the undocumented coatings inside containment. For additional conservatism. ComEd 2

decreased the confidence level to 80% (or 3100 ft of undocumented coatings remain inside containment).

Requested Information

c. Describe any In sUu testing done on the remaining coatings.

ComEd Respome Adhesion tests were perfonned on qualified coatings inside containment. and dry film thickness and spec~fic gravity determinations were made on unquaHficd coatings.

The adhesion tests were performed by a Level 3 Coatings Inspector tc,. verify that the coating systems meet ANSI N5.l2, "Protective Coatings for the Nuclear Industry,"

Paragraph 6.4 requirements. The minimum adhesion strength specified by ANSI N5.J2 is 200 psi. No adhesion test of qualified coating in proper application failed the acceptance criterion. One test which failed the criterion was for a qualified coating in an improper application. This coating was subsequently removed.

Thirty-three adhesion tests were performed at various elevations. on various surfaces:

including concrete surfaces, carbon steel liner plate, structural steel carbon steel surfaces and component carbon steel surfaces. Test areas were chosen b~d on visual observations and included areas of previously dist~ or visibly degraded coatings, as well as areas where coatings appeared to be in good condition. In the areas near prior coating failure (and subsequent removal), lests were performed within 3 inches, 16 inches. and 36 to 48 inches of the failed edge to determine if adhesion had been degraded in the vicinity of the failure. A minimum clearance of 3 inches frnm the failed edge was necessary to properly mount the Elcometer adhesion tesler.

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4. 111e analysis calculat..:S the farthest distance from which a paint partlde would be transported to the surrp {the radius or the zone or Influence}. But the analysis uses a radial model and does not address the height above the water level In the zone or Influence.

To what height above the elevation 568 root ftoor level were the coatings removed?

ComEd Response Coatings were visually examined from e.levation 568' up to and including the dome.

Unqualified coatings were found and removed on elevation 617'. a.c. reflected by a "Y" in lhe SMAD Repon. Table I. columns labeled "REM PNT" (i.e .* Removed Paint) and "REM ITM" (i.e .* Removed Item). In addition, unqualified coatings were found and subsequently removed on the 2A and 2C Steam G~ncrator catwalks (elevation 624').

The ZOI Calculation considers the ZOl to he a cylinder whh a venical axis at the center of the containment sump with a height extending to the surface of the water. Howev~r.

lhe removal of coatings was ha.~d on extending the cylinder to the containment dome.

As described in the response to Question 2, the removal of coatings or componcnL~ was based on radial measurement from the nearest *edge of the sump rather than the centerline of the sump.

Requested Information S. ComEd has reapplied the coating to sections or the Unit 2 contaJnmenL

a. Describe the extent or the recoating being done In the Zion, Unit 2, contaJnmenL ComEd Response The Unit 2 *containment rccnating is near completion in the following area..,:

I. An area outside the mis..,ilc harricr*bounded hy the containment wall and the missile barrier wall at Elevation 568' between A1jmuth Z22 and Z23. floor to ceiling. This area is approximately 25 feet long. The coating effon will include the coating of concrete walls and floors. containment liner. and structural steel.

2. An area inside the mis.i,ile barrier at Elevation 568' centered at Azimuth Z22. This area is approximately 32 feet by 12 feet and wilJ include the concrete floor and adjacent walls to a height of approximately IO feet.

3. Components which had undocumented coatings removed within 20 fcet mca.t;ured

. radially distance from any edge of the sump.

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As discussed in the May IS. 1997, teleconference, this initial scope of containment recoating is scheduled to be complete prior to Unit 2 startup. In addition. an overall plan for the long term inspection and maintenance or containment coatings is under development. This plan will be completed by second quarter, 1998.

Requested Information

b. What standards were used for this recoatlng?

ComF.cl Response The following standards are being used for the recoating effort during the Z2R 14 outage:

10 CFR .50 Part B. Quality Assurance

ANSI NI O1.4, Quality Assurance for Protective Coatings Applied to Nuclear Facilities

ANSI N101.2, Protective Coatings for Light Water Nuclear Reactor Containment Facilities *

ANSI N5.12, Protective Coatings for the Nuclear Industry

.* ANSI N4.5.2. Quality Assurance Program RequiremcnLi, (Design & Construction)

Requested Information

c. WIii any In-situ testing of the newly applied coatings 'be performed?

ComF.d Response Testing of the newly applied coating system consisLli of dry film thickness measurements and visual examination of the completed application. This testing is pcrfonned by certified coating inspection personnel. These activities arc perfonncd per work specifications and procedures to assure that ,..... field application meets installation requirements such that the qualification or the coating remains valid.

Requested Information

6. The transport calculatlons ~ume a steady slow now toward the containment sump. The coating partldes are amumed to drop onto the surface of the water and now toward the sump whlle they are settling at the termlnal velocity.

L How wo11ld the turbulence due to the break discharge, splllage, and operation or

. the containment sprays, oc:currlog during and following blowdown, affect the amount of coating material reaching the sump?

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ComFAI Response The effects of turbulence are not considered in the zor Calculation. Based on acst results, discussed in Question 8. signific3"t margin exists between the quantity of unqualified coating remaining inside containment and lhc quantity of coa~ng required to create appreciable effects on available NPSH. Given !his margin and the qualitativ~

points discussed below, specific analyses to determine lhe potential effects of turbulence is considered unnece~.

The ismie of turbulence during blowdown (break discharge) can be considered in tenns of general turbulence outside the jet impingement zone, and jet impingement* from the break. General turbulence outside the jct impingement regiori during the relatively short blowdown period is not expected to generate- additional quantities of coating maacrial that would reach the sump screens because I) in the ahscncc of jet impingement, failure of unqualified coating. material is a time dependent process and 2) documented coatings are qualified for the LOCA environment such that the coating system would remain on the substrate that it coats. *

Jct impingement from the break *ha.~ the potential to create debris from coa~ing. insulation and other material. However, the velocity of the flow in the vicinity oflhe break is expected lo be le~ than the velocity at the sump screen (0. 72 ft/sec) because of the increa.'!ed surface area over which the break flow will travel. The decrea.'K!d velocity would increa'ie the potential for material to stay in the vicinity of the break versus being carried to the sump. Insulation dchris is discussed in the _response to Question 7. The response to Question 11, describes activities whic:h would minimiw the existence uf other material that could be carried to the sump.

Turbulence following blowdown is considered in terms of turbulence prior to and upon recirculation flow initiation. Recirculation is not expected to occur until approximately 30 minutes after the LOCA while hlowdown is expected to last approximately 30 second.~. Therefor!!, a uniform velocity field on the containment floor is not e.xpected until slightly after recirculation flow initiation. However, _as descrihed,iri the *response to Question 9, the ZOI Cajculation conservatively models vcltx:ities and flow, maximizing the ZOl and minimizing sliding velocities, which would compensate for the effects of recirculation flow initiation turbulence.

Spillage flow out of the break is not expected to create significant turbulence in the area of the sump.. By the time the spillage reaches the sump area, the flow would not significantly impac,t the unifonn velqcily field in the sump assumption (associated with the 90001pm recirculation flow rate) considered in the ZOI Calculation. The velocity of the spillage in the vicinity of the break is expected to he less than the velocity at the sump screen (0.72 fl/sec) because of increased surface area over which the spillage will flow.

This would minimi1.e the transport of debris. .

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Finally,* containment spray rapidly disperses as tine particles covering lhe majority of containment surfaces. Spray impingement on containment surfaces is much le&§ severe than jet impingement effects from the initial break and therefore the effects of containment spray on the quantity of material transported to the sumps screens is considered negligible.

NEI and the NRC are in conversation with respect to a planned review of PWR ECC~

. sump designs based on insights gathered fram ECCS strainer blockage at BWRs. How

to properly acco~nt for tur~ulence and jet impingement is best handled in a generic mauer by the industry with participation of all PWRs. These generic efforts may result in modifications lo the estimates of material reaching the sump. However, ComEd believes that any additional amount of coating that might reach the sump as the result of

. turbulence will not change the conclusion that adequate NPSH would be available.

Requested Information

b. In particular, would coadngs located outside the zone or lnOuence be swept Into the zone or lnftu~nce by these effects?

ComEd Response .

The only coatings outsidi;: their associated ZOI that might be postulated to be swept into the ZOI are the remaining unqualificd coatings. Based on the test resulL4i discussed in the response to Question 8, *which demonstrate significant margin exists between the

quantity of unqualified coaling remaining and the quantity of coating required to appreciably affect the available NPSH, no specific analyses have been perfonned nor are deemed neces.~ary to determine if coatings located ouL4iidc their ZOI would be swept into their ZOI by turbulence. *

In addition. ba.i;cd on the containment layout and the conservative calculation of the ZOI.

) it is not expected that sufficient quantifies of undocumented coatings outside the 201 would be swept into the ZOI so a.Ii to jeopardi1.c the available RHR pump NPSH.

Requested Information

c. Justify why It Is not Jiecesgry to account ror these effects In the analysis.

ComF.d Response .

To summaril.e the response provided in parts a and b of this question. ComEd believes it is not nece..~ to account for the effccLc; of turbulence in the analysis for the following reasons:

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Tesl resullS (refer to the response to Question 8) indicate significant margin is available between the quantity of unqualified coating remaining inside containment and the quantity of coating required to develop any appreciable Jog in the avv.Hable NPSH ..

Conservatisms in lhe Nr=,~ and ZOI calculations wor,;. ' offset some of the effeclS of turbulence.

For coatings located outside lhe :cneral sump area (e.g., unqualified coatings oulside their ZOI), the containment layout would typically provide a pathway which was tortuous to the extent that the coating would not reach the sump.

Furthennorc, because NEI and the NRC are in conversation wilh respect to properly accounting for turbulence and jet impingement effects in analyses. modifying lhe analyses to account for these effects may be contrary to the final resolution of the issue between the NRC and lhe industry.

Requested Information

d. What action was taken for those coatings that sre undocumented, unquallned or failed that may have a calculated zone of lnnueuce greater than that selected (20 feet), or have an "unbounded" zone or lnftuence 1Table J or Calculation 2JS.B-040M-002, Revision I, Page 26) but that may enter the zone of lnnuence through the mechanisms described above?

ComEd Response As described in the re~ponse to Question 2. there is only one case where the untf:1aMied coating with a ZOI greater than 20 feel remains inside iLi; respective ZOI and is postulated to have a credible pathway to the sump. The quantity of coating is approximately I ft 3* The other coatings were determined to be located outside their respective ZOI. The unbounded ZOls in Table 3 of Calculation 22S-B-040M-002 (ZOI Calculation) are for qualified c~lating *systems w;1ich do nol play a role in the

detennination of how much undocumented coating may reach 1h~~ containment sump. As described in the response to Question 3, part iJ. any identified failed coatings were removed. Thus the only coatings of concern Wlluld be unqualified coatings outside their respective ZOls. Because these coatings are not postulated to reach the sump screen. no action has been taken for these coatings. However as discus.i;ed in the ~ponse to ParlS a and b of this Question. any additional undocumenlCd coatings entering the ZOI would not be expected to change the conclusion lhat the RHI< pumps will have adequate Nt>SH.

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7. 11111 analysis does not account for any Insulation debris which may be transported to the sump screens as a result or a lou-of-coolant accident (LOCA). II any coatl*

are usumed to reach the sump (I.e., all coatings which could reach the sump are not removed prior to the next plant startup) then the combined effect or the paint and the Insulation must be taken Into consideration since the preaure drop from this combination of debris can be slgnlftcantly higher than that due only to failed coatlnp (see NUREG/CR-6224, "Parametric Study of the Potential for BWR ECCS Strainer Blockage Due to LOCA Generated Debris" dated October 1995; see especially Appendix B) and the method of calculating NPSH margin In Section 2.3 or Calculation 22S-B008M-092 would not be correct.

a. Verify and provide calculations that show that the zone of lnnuence Is

. determined so that either no coatings will reach the sump or that the effect on the preaure drop acrou the sump screens of any that do reach the sump is correctly calculated.

ComEd Respome The phenomenon descrihcd in the introduction to Question 7 is not applicable because the NPSH calculation assumes complete screen blockage of a percentage of the screen area. The method of calculating NPSH margin (Section 2.3 of Calculation 22S-B-008M-092) is not affected by the type of material postulated to cause blockage. The amount of undocumented coatings postulated to reach and block the sump screen ( I ftJ) is small relative to the 69% of the open screen surface that can he blocked per the NPSH calculation ( 11.56 ft\ a.~ described in the res~,nnsc to Question 2. 'n addition, lhe test-.

described in the response to Question 8 indicate that failure of large quantities of coatings

' would not result in appreciable pressure loss acros.li the suni: :crccns.

RequestetJ fnformatlon

b. What type of Insulation Is used In the Zion, Unit t, ~~!alnment?

ComF..d Response Insulation inside the containment mis.'iilc barrier is stainll-s.-. steel reflective metal (mirror) type insulation (RMI). Three hundred and thirty seven cubic feet of stainless steel jacketed tiberglw insulation is installed on service water piping ouL4iide the missile barrier. No other insulation type is installed inside the containment.

Requested Information

c. Is It a type which could readily clog srreens?

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RMI has a density greater than paint, and it would therefore have a relatively small ZOI.

Based on the approach velocity determined in the ZOI°Calculation and the information provided in NµREGJCR-36f6, "Transport and Screen Blockage Characteristics of Reflective Melallic Insulation Materials." RMI outside the 7 I.JD is not expected to reach the sump screens; Furthermore. NUREG 0737. Supplement 9 for Commanche Peak, concluded that the RMI dislodged from. jct impingement would not travel to the sump screen. While specific analyses have not been performed. based on the conclusions for Comma~che Peak, ComEd docs not believe that any RMI dislodged from jet impingement would reach the sump screens so as to clog the screen or act as a filter media.

The stainles.~ steel jacketed fihergla.~~ insulation is not postulated to reach the sump screens since it is outside the missile harrier (i.e., will not be subjected to jet impingement from a postulated reaclor coolant system pipe break). jacketed with stainless steel, and banded to preclude failure during a LOCA or postulated high energy line break. The stainless steel jacketed insulation i.r, not affected by the spray effects of containment spray flow.

Requested Information

8. Describe any experimental verlffcatlon or the zone or lnnuence or NPSH analyses or other relevant experimental work and provide any avaJlable documentation.

ComEd Response Flow model tests performed hy Continuum Dynamics Incorporated (C:DI) for Zion Station demonstrate a large volume of paint (several thousand square feel) can fail within the ZOI with<>ut an appreciahlc pressure los.~ across the sump screens, (5000 ftl of coating would result in a pres.liurc drop of 0.25 inches of water.)

Final tests were completed in July. These tests use parameters that are representative of the conditions at Zion (e.g .. screen opening si1.c and flow rates). The final test repon is included as

Enclosure I to this letter. Attachment B provides a brief discu~ion of some of the CDI test parameters and their correlation to the parameters utili1..cd in the ZOI Calculation.

Requested Information

9. List and discuss any conservatisms In the Zion zone or lnnuence calculation and NPSH calculation.

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ZQI Calculation conservatisms:

a) The. maximum dimension of the failed paint chips is a.uumed to be equal to the outer sump screen mesh opening, 0.5 inches. A larger particle size would result in a smaller calculated ZOI, based on the greater velocity required to initiate sliding of the particle.

b) 1be dynamic coefficient of friction between failed paint chips and concrete is

usumed to be 0.35. This is conservative with respt..'Ct to the Gibbs & Hill report*

documenled in NUREG-0797, Supplement 9, which uses a value of 0.42 for the dynamic coerficient of friction. Using this conservative coefficient of friction results in lower velocities required to slide d,:bris along the containment floor. Thus, the calculated ZOI is large*r. Similarly. lhe s1a1ic coefficicnl of friction is conservatively a.uumed to be 0.40 versus the 0.60 used in the Gibbs and Hill repon documented in NUREG-0797, Supplement 9. Using lhis conservative coefficient of friction results in lower velocities required for coatings to begin to slide along the containment floor.

c) When calculating the terminal velocity of a sinking coaling particle. the debris was modeled as a circular disk parallel to the floor. The terminal velocity is minimized for horizontal alignment. since the greatest possible area is projected normal to the direction of motion. maximi7Jng lhe drag force. Minimum terminal velocities resuil in longer transit limes for a sinking paniclc. Thus, the calculated ZOI is larger.

d) Worst case flow conditions were assumed to lX:cur when calculating the ZOls.

SpecificaUy, maximum RHR pump flow rate of 9(){)0gpm during recirculation which maximi1.cs the approach velocities is a.~umed. A conservatively low water temperature of 100 uF. which maximi1.cs the water density and correspondingly minimi1.es the calculated velocity lo initiate particle slide and tenninat particle velocities is wumcd.

e) ZOls were calculaled at both the minimum and maximum expected flood heights and the largest of the* calculated ZOl was used. (See the response Question 10). The .

largest ZOI calculated under these bounding conditions is presented in _summary Tables 1 through :4 of the ZOI Calculation.

NPSH Calculation conservalisma a) No credit is taken for elevated conlainment pressures which may exist following a LOCA, nor is credit taken for nominal atmospheric preMurc at which the containment is maintained. These prcs.~urcs would increase the available NPSH.

b) Maximum pipe lengths and number of fittings for lhc RHR system are used. This maximi1.A!s the pres.1ure drop which increases the required NPSH.

12 of 14

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c) The 4vailable NPSH is compared to the required NPSH at pump run out conditions (4500 gpm per pump; 9000 gpm total). This is conservative since the required RHR pump flow al lhe lime of cold leg recirculation is much less than run out conditions.

Using maximum flow also maximiz.es system pressure drop. which increases the required NPSH.

d) lbe sump flood level is taken to be I fool above the containment floor prior to initiating recirculalio~. Actual flood level during a large break LOCA is expected to be greater than J fool (The maximum level is 5.06 feet.) The increased sump Qood level would increase available NPSH.

e) For purposes of determining lhe kinematic viscosity. the minimum sump water ccmperature at lhe time of recirculation is assumed to be I.SO °F. This maximizes system pressure drop. Actual sump ccmperature dllring a large break LOCA. al the time of recirculation. is expected to he greater (on the order of 22.S 0 f).

Requested Information

10. Explain why the zone of lnnuence Is less at a depth or 3 reet than at l foot or S.06 feet of water above the containment floor. (Calculotlon 22S*B-040M-002, Section 7,

SUMMARY

AND CONCLUSION.)

ComEd Response The ZOI calculated at a flood height of 3 feet is not always less than the calculated ZOI for a flood height of I foot or the ZOI calculated for a llood height of 5.06 feet.

However. the ZOI at a flood height of 3 feet is always les.~ than the ZOI reported, because the reported ZOI reprcscnL~ the bounding value of the 1 foot nood height w: the 5.06. feet flood height value. Ara stated in the Conclusion Section of the ZOI Calculation.

the hounding ZOI was always used.

The ZOI for a panicular coating system is chosen based on two values. The first value represcnL~ the maximum radius from the centerline of the sump for pos..~ible coating particle movement along the containment floor. The SC(:ond value represents an as.liCssment of the coating particle trajectory as it sinks to the containment floor.

The radius of potential particle movement is maximized by high horizontal water velocities. The minimum flood height of I foot maximizes this horizontal water velocity. The particle trajectory is maximized when lhc particle has the largest pos..~ibfo residence time in lhe water before making contact with the containment flotu. This translates to the flood height of 5.06 feel value. (Refer to Figure I of the ZOJ Calculation.)

13 of l4

I .. 41-' ..

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Requested Information

11. Describe f~e l'on Foreign Materials Exclusion Program and how it preve11ts forelgc material (too~ clothing, plastic sbeetlng, etc.) from clogging or damaging the sump screens. 1'bls seen~ espedallr Important to ?:~on, glveu the relatively small area of the sump screen.

C".omEd Response The Foreign .Aaterial Exclusion (FME) Program applies to all personni;I who perform functions that have the potential to introduce foreign material into any plant system. The program includes specific work practices and requirements for training of personnel. In addition to lhe FME program requirements, Zion Checklist E ..Coulainmcnt Close-out for H/"J m* SIU" of GOP-0, "Plant Stanup Documl~ntation Requirements" requires that Operating personnel perfom, a conl'.linmerit walk down prior to Unit operation. This check lisl specifically requires inspection of containment are~ for material which could poh!nlially clog the containment sump. Adherence to lhe requirements of the FME program and GOP-0 provides a.11i.11urance that the items referred to in this question are not left in the containment during operation. Checklis~ E of GOP-0 is provided for reference as Enclosure 2 to this leuer.

lfflluested Information

12. Provide die following documents that are relerenced in the February S, 1997, _

submltlal.

a* -[Reference, sic] S.14 or Calculation 22S-B-008M-092 *.

b. [Reference, sfc] S.S or Calculation 22S-B-008M-092.

c. Ta!Jle on page 2-10 of Referenc~ 5.2.

d. Page 17 or Rer,uence S.17.

e. Drawing or the ~ontalnment sump.

ComF.d Response The requested infonnalion is provided ii~, Enclo:mrcs 3 through 7. It should be noted that items Ila and 12h (Enclosures 3 and 4) were referenced in Calculation 22S-B-OOKM-092 for hisl.>rical purposes and arc considered superseded by that cah:ulation.

Also note that the st:1tcment at the bottom of item 12d (I ~nclosure 6). indicating that the document is not to ~ sent outside of Sargent & Lundy. may be disregarded. Sargent &

Lundy ha." authorized ComEd to rell';1sc this page to the NRC a.11 public information.

14 of 14 t, . *, *,, . n (~ *

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r.)

ATIACHMENT B CDI TEST PARAMETERS CORRELATION TO ZONE OF INFLUENCE CALCULATION PARAMETERS Coarto, Spc:c;ific GrayiLY Tbc ooating used in die lest is described in Seel.ion 3.1 oftbe COi repon (page 7), Ameron/Amen:oat 90HS, was in IIOCk ready for IIIC at COi. This coaling has a specific gravity of 1.4 t,o l.S. As der.c1 ibed in lbe ~ of Influence (ZOI) calculaLlon (Reference 2, Attacbmenl A), the postulated lowest specific gravity of coating at Zion SWioa ls 1.6. Using material wilh a slightly lower specific gravity in the now model tests is conservative. Lower specif'ac aravily resulls in larger ZOls due ao lower velocities required IO initiate sliding and increased uanspon time. (Refer ID Reference I, ComEd response to Question 10.)

Sm;cp Size and Orientation Tbc vertically oriented 5'.-reen segment used in the lest is I.he same height 1u1d vertical orien1alion as the Zion recirculatioo swnp screens. The screr.n segment WIL'i provided by Coml!d 10 CDI and has the same size grid openings as lhe Zion sump screens.

CoaUn, lbicwu aru1 Chip Size The coating chip thicknesses used in ihe Cl>l lf.sL\ (2-3 mils) arc representative of the paint llticknc~s found in 1..ioo Slation (Refer 10 ZOI Calculation, Table I). Additional quantities or coatings with differenl tbicklle~s were also used IO obcain as much inronnalion ns pos.\ible on the tmpac1 or large volwnes of' paint on lbe pl'Cs.\ure drop across the sump screen (Refer 10 Section 3.3 of the rcpon). The chip Siles were of a random size distributioo ranging between 1/8" x 1/8" to 2" x 2"; The ZOI Calculation conscrvalively a.\.\umcd lite maximwn dimension of lbe chips to be equal to the outer sump sc~en mesh opening, or O.S inches. The utili1.ation or varying paint chip sizes 1s appropriate. A VIU)'ing chip size would he expccled in reality. The ZOI Calculation Slates llla1 the assumption is conservative since a larger parliclc size would have a smaller ZOI. However, lite ul.ili1.alion of larger chips \n &be relalivcly (compared 10 Containmclll) small lest appam1us, would tend lo cause more restriction of lbe sump s<<.-reens.

Wa1Cfllei1h1 The bcighl of water in lhe 1es1 lank was chosen to he une roo1 10 correspond to the heigh& al which recirculation is initialed. As described in the respon.~ to Question 10, a hcighl or one root maximizes the horizonlaJ water vclocily, which in lum maximl:r.cs lhe ntdius of polcntial particle movement I-low Yclucity Tbc test now velocity oro.72 fl/sec was b.*u,cd on lhc expected Zion maximum veluci1y (Rdcr to ZOI C'.alculation, Table 1).

ATIACHMENT C List or Commitments ldeoUOed In ZRA97QJ6 The following table identifies those actions commiued to by ComEd in this document.

Any other actions discussed is this submittal represent intended or planned actions by ComEd. They are described to the NRC for lhe NRC's infonnation and arc not regulatory commitments. Please notify Mr. Robert Godley. Zion Station Regulatory

Auurance Manager. of any questions regarding this document or any associated regulatory commitments. .

Commitment Committed Date or Outue Com Ed will develop an ovcraU plan for lhe long term inspection and Second Quaner maintenance of containment coatin2s 1998 Testing of newly applied coating systems will include dry film Ongoing thickness measurements and visual examination of the completed annlication.

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ZRA97016 ENCLOSURE I CONTINUUM DYNAMICS, INC. TEST RE.PORT

. ~

C.D.I. TEalNICAL MEMORANDUM NO. 97-14 EVALUATION OF PAINT CHIP HEAD LOSS ON VERTICAILY ORIENlED ZION STATION STRAJNER SCREEN JULY 1997 TEST PHASE Revision 0 Prepared by Richard G. Louderback, Jr.

Roben W. Dienl Andrew E. Kaufman CONTINUUM DYNAMICS, INC.

P.O. BOX 3073 PRINCETON, NEW JERSEY 08543 Prepared for COMMONWEALTII EDISON COMPANY 1400 OPUS PLACE - SUITE 400 DOWNERS GROVE, ILL 60515 Approved by July 1997

TABLE OF CONTENTS section 1 INTRODUCTION 1 2 TEST FACILITY APPARATUS 2 2.1 Strainer Model 2 2.2 i-low System 2

- -2.3 Head Loss 3 2.4 Insttumentation 3 3 PAINT CHIP DEBRIS 7

3. J Paint Type 7 3.2 Paint Chip Generation 7 3.3 Paint Chip Quantity 7 4 TEST PROCEDURE

SUMMARY

8 5 TEST RES ULTS 9 5.1 Test Mattix 9 5.2 Test Observations 10 5.3 Full Scale Data Application 10 6 QUALITY ASSURANCE 18 7 REFERENCES 19 ii

1.0 INTRODUCTION

This document describes testing conducted for Commonwcalth*Edison Company, Zion Station to evaluate the effects of paint chips on sump sll'liner screen head loss.

Testing was conducted at the laboratory facilities of Continuum Dynamics, Inc. in Princeton, New Jersey following the test plan described in Reference 1. The primary objective of the program was to detennine the head loss across the strainer sump screen as a result* of the buildup of painc chips. Paint chips of different sir.es and thicknesses were tested. All tests were con~ucted with chips niade from Ameron/Amercoat 90HS high perfonnance epoxy paint. The test apparatus consisted of a simulated ponion of the full scale Zion Station strainer.sump screen mounted in a 675 gallon, 82 inch diameter tank. Procotyj,ic:al, full scale strainer screen approach velociti~s were maintained for all of the tests.

in The tests documented this rcpon were observed by Commonweallh Edison personnel on July 9, 1997 at the Continuum Dynamics, Inc. laboratol)' facilities. A series of rests were conducted in March 1997 under similar conditions with essentially the same results bur the tests were nor witnessed by Commonwealth Edison perosnnel (Reference 2). The March 1997 tcsL'i were documented in C.D.I. Technical Memorandum No. 97-05, April 1997.

2.0 T3ST FACILITY APPARArus 2.1 Strainer Mod$:1

The test apparatus is sllown schematically in Figure 2-1. One comer of the full scale Zion Station sump strainer was modeled using nominal 1/2 inch mesh. I4 gage, 304 SS wire cloth supplied by CQmmonwealth Edison. The cloth was painted with Keeler &

Long E-1-7475 Epoxy Enamel paint. The strainer was constructed. with ~wo approximately 6.25 inch deep by 12 inch high sides with a 3 inch by 3 inch angle added at the intersection of the two sides to model a suppon angle. The total ~mface area of the strainer w~s 1.05 square feet. To better visualize the testing; the remainder of the sttucture (re~ning sections of sides and the top) were fabricated from 1/2 inch thick clear polycarbonate sheet. A photograph of the model is shown in Figure 2.2.. The model was mounted to the floor of a 675 gallon tank with a diameter of approximately 82 inches and a height of 30 inches. To simulate prototypical flow conditions through the strainer, bulkhead fittings were insened in ahc floor of the 82 inch tank to produce flow from the bottom of the sarainer. The bulkheads in the floor are visible in Figure 2.2.

2.2 Bow Sys1em Four Hayward 1.5 horsepower pumps were used to provide system flow. Each pump could produce on the order of 9S to 100 GPM. Flow rate for the pumps was determined by establishing the time required to fill a container of known volume.

Knowing the aotal sarainer area and that an approach velocity of 0.72 ft/sec was required for the 1est. the corresponding system flow rate could then be calculated. To minimize the turbulence from the discharge of the pumps back into the 82 inch diameter tank, return flow was directed into a 36 inch diameter diffuser tank installed above the water surface. The center of the diffuser tank was approximately 30 inches away from the tip of the strainer model at the nominal centerline of the tank. Holes were drilled into the bottom of the lank to create a rain effect for water re-entry. A photograph of the .test apparatus setup showing the diffuser tank (left side of photograph) and the strai.ner mounted in the tank is shown in Figure 2.3. If required, flow from an individual pump was regulated through the use of a butterfly valve. Since there was essentially no change in head loss across the pumps, system flow rate was assumed to remain constant throughout each test. This was confinned during shakedown testing when flow rate through the pumps was found to be the same at the beginning and end of a test.

2

2.3 Hc;ad Loss Prcsswe drop across the strainer screen was measured through lhc use of a waler filled manometer and recorded manually dming testing. One end of the manometer was connected to a pressure tap insencd into the model and the Olher end to a bulkhead fitting in the side of the tank wall behind the strainer. The pressure tap in lhe strainer is visible exiting the top of the model in Figure 2.2.

2.4 IosuvrocoWiao

. Minimal instrumentation was required 10 perform the tests for the program.

Measurements of paint chip size and thickness were made using commen:ial grade dial calipers and 1ape rules. Head loss was measured using a water filled manometer.

Readability on the manometer was+/- 1/16 inch of water. The mass of paint chips used in a tes1 was measured using an AND model FX-300 electronic balance. The balance has a readability of 0.001 grams. The commercial grade accuracy of this instrument was adequate for its use in the test program. The balance was subject to confidence checks during testing.

3

SUMMARY

The general tes, procedure for conducting a head loss test is described below.

Test descriptions and initial conditions were recorded. lbe required amount or paint chips were then prepared and presoalted to insure they would not float on the water surface when introdur * :.-nto the tank. The tank was then r.tled with water to the required height and the pumps primed for operation. The screen area was verified and the required flow rate calculated to give an approach velocity of 0. 72 fr/sec. System flow was staned and the paint chips were added to the tank under the nominal center of the diffuser with _!he returning water. Tests continued to run until steady state conditions were observed. Steady state conditions were reached when there was no significant movement of lhe paint chips in the tank and the head loss across the strainer ~ad* been steady for approximately five minutes. Typically, this was about 10 to 15 minutes after introduction of the chips. The strainer head loss was recorded and the strainer photographed. An estimation of 1he amount of the strainer screen blocked by the paint chips was then pcrfonned. Each test was also documented by a video camera. After steady state conditions were reached, the test would be stopped or more paint chips would be added with the flow sys1em continuing to run.

8

S.O TEST RESULTS 5.1 Icv Mattix Table 5.1 contains a matrix of the paint chip tests conducted and the com:sponding steady state head loss measured for each tcsL

. TABLE 5.1 -Test Matrix All tests conducted at an approach velocity of U = 0.72 ft/sec All tes~s conducted with approximately 12 inches of water in the tank

(i.e. warer level in tank was even with rop of sttaincr) uanntyo . pptoxunate nts Paint Chips . Steady State CJ, (square feet) of Strainer Screen Blocked by Paint Chips lpS 10 <- 14 square into tank under 20 feet each diffuser with thickness) flow on (Cont. of IO (~ 28 square 1ps into tank under Tesr #11)

20 feet each

diffuser whh thickness) fiowon 1ps (Com. of 10 (- 42 square into tank under Test #12) 20 feet each diffuser with thickness) flow on 14 I haps (Cont. of 10 (-56 square into tank under Test #13) 20 feet each diffuser with thickness) flow on 5.2 Icsr Observations The majority of the paint chips introduced into the tank sank and remained immobile on the tank floor and did not reach the strainer for alJ of the tests. Turbulence in the tank due to return flow patterns caused some chip movement. When flow was 1enninatcd .upon completion of test 14, the paint chips which had accumulated on the strainer screen immediately fell off of the strainer screen, regardless of paint chip thickness or size.

9

Photographs of the sU'liner taken during testing an: shown in Figmes 5.1 through 5.5. Each photograph was taken looking down at the suaincr from outside the tank and shows one side of the strainer screen. Figure S.1 was taken after reaching steady scate conditions during Test #11 with the pumps running and approximately 43 square feet of paint chips in the tank (- 14 square feet each of 2 to 3. 10 and 20 mil thicknesses, paint chips sizes ranging from - 1/8 10 2 inches). Note the cleanliness of the strainer screen.

Figure 5.2 was photographed after reaching steady state conditions after Test #12 with approximately 85 square feet of paint chips in the cank (- 28 square feet each of 2 IO 3, 10 and 20 mil thicknesses. paint chips sizes ranging from - 1/B to 2 inches). Note the small build up of c:~_ips along the base of the strainer screen. figure 5.3 shows steady state conditions for Test #13 with approximately 128 square feet (-42 square feet of 2-3 mil, 10 mil and 20 mil) paint chips in the tank. Figure 5;4 was taken after reaching steady staie conditions during Test #14 with the fmal in~mcnt for a total of 170 square feet of paint chips in the canlc (-56 square feet each of 2 to 3, 10 mil and 20 mil thicknesses.

paint chip sizes ranging from - 1/8 10 2 inches). Note that some of the strainer sa=n remains free of paint chips. Figure 5.5 shows the strainer upon completion of Test #14 with flow stopped. Compare Figure S.S to Figure S.4 (the test just completed) and note that all of the paint chips on the strainer screen have fallen off after flow was stopped.

The top of the sttainer has been marked for clarity.

5.3 Evil Seate Data AppHcation Testing was conducted on a section of a full scale strainer at full scale approach velocities. To ~etermine the amount of paint chips that correspond to the entire strainer, simply muhiply the test amount of paint chips by the area ratio Area run 1ea1e ,tninrJ Area test strainer ,Where the full scale Strainer has an area Of approximately 28 square feeL 1be head loss values measured in the tests arc the head loss values expected m.ross the entire strainer in the plant. Since the containment floor velocities for the Zion Station are typical to those found in the test t.ank for thjs program, it is anticipaced that the head loss results obtained in the test program are ~prcscntativc of that to be expected across Ziqn's sump screens. A plot of the predicted steady state pressure drop versus square feet of paint chips is shown in Figure 5.6.

Note that the tests con~ucted in March 1997 and detailed in C.D.I. Technical Memorandum 97 -OS featured a slightly different sniner screen area. water level and approach velocity. Upon completion of the March tests, the strainer SCJCen was removed from the test rig and coated with epoxy paint at the request of Commonwealth F.clison.

10

When the screen was reinstalled, the measured surface area was 1.05 square feet instead of I square.foot. 1be March 1997 tests were conducaed with an approach velocity of0.7 .

fr/sec whereas the July tests documented in this repon wen performed at an approach velocity of 0.72 ft/sec per the request of Commonwealth Edison pmonnel. 1be water level for the March tests was approximately 2 feet and was reduced to l foot for the July tests.

11

Fi~ure 5.1: Photograph of strainer at steady state conditions during Test #11. Test run with approximately 43 square feet of

paint chips, approximately 14 square ~eet each of 2 to 3 mil, 10 mil and 20 mil chips ranging in size from approximately 1/8 to 2 inches.

12

Figure 5.2: Photograph of strainer at steady state conditions during Test 1!12. Test run with approximately 85 square feet of paint chips, approximately 28 square feet each of 2 to 3 mil, 10 mil and ~O mil chips ranging in size from approximately 1/8 to 2 inches.

13

Figure 5.3: Photograph of strainer at steady state conditions during Test 013. Test run with approximately 128 square 'feet of paint chips, approximately 42 square feet each of 2 to 3 mil, 10 mil and 20 mil chips ranging in size from approximately 1/8 to 2 inches.

14

- - - , . . .-~.......-. ; , ..*

Fi~ure 5.4: Photograph of strainer at steady state conditions during Test 1114. Test run with approximately 170 square feet of paint chips. approximately 56 square feet each of 2 to 3 mil, 10 mil and 20 mil chips ranging in size from approximately 1/8 to 2 inches.

15

~ ,._ ... ,.;*....

figure 5.5: Photograph of strainer up~n completion of Test i'l4.

16

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Predicted Steady State Pressure Drop Across Strainer Screen vs. Square Feet of Paint Chips For 28ft2 Sump Strainer Screen At U = 0.72 ft/se~

0.5 ___________________ Approach Velocity Cl.

e Q

-0.5 i........&--i~~---"-'-'--"".................-i.....i.....&......i......t.-....r....J..~------'

0 1000 2000 3000 4000 5000 Square Feet of Paint Chips on Full Scale 28 ft 2 Strainer O Even Distribution of 2 to 3, 10, 20 mil thick chips Figure 5.6: Predicted steady state pressure drop across strainer screen vs. square feet of paint chips.

17

a = .

6.0 QUALITY ASSURANCE Although Commonwealth Edison procured lhe testing services of Conrinuum Dynamics, Inc. u non safety related, all ~uality related activities were perfonned in accordance widl the C.D.I. Quality Assurance Manual, Revision 12 (Reference 3).

Quality related activides arc those which were cUrccdy related to die planning, execudon and objectives of the tesL Supponing activities WICh as ~SI apparatus design, fabrlcation and asiiembly ue not conttolled by the C.D.J. Quality Assunnce Manual. C.D.J.'s Quality Assurance Program provides for compliance with die ~ I requirements of 10 CFR Pan 21. All test dam wiU be contained in a Design Record File which v~~~l ~

kept on file ~~Jhe C.D.J. offices.

18

7.0 REFERENCES

I. Continuum Dynarni.~s, Inc., "Pl&i forTesling Evaluadon of Paint.Chip Head Loss on Ven?tally Uriented Zion Station Strainer Screen," First Draft, January 1997.

2. Continuum Dynamics, Inc. Tcc:bnical Memorandum No. 97-05, "Evalualion of Paint Chip Head Loss On Venically Oriented Zion Station Saainer Screen. Fint Draft. April 1997.

3. Conti~~um Dynamics. Inc., Quality Assunnce Manual, Revision l 2, October 1996~

19

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ZRA97016 ENCWSURE2 Checkli1t E or GOP-0, "Containment Clo1e-out for H/U or S/IJ"

GOP-0 Rev. 6 MAY061997 GOP-0 CHECKLIST E (Page 1 of 10)

CONTAINMENT CLOSE OUT FOR H/U.OR SIU 1.0 IUPOSE

1. This checklist provides guidelines for inspecting Contairvnent prior to plant heatup and startup after an outage. *

2. This checklist should also be performed prior to plant startup if major work was performed in Containment. *

2.0 INSTRUCTIONS NOTE

1) The Shift Manager performs steps 1 and 2.

2) For short duration shutdowns when no scaffolding, step-off pads, or change areas "have been set up in the Containment. the Shift Manager may eliminate totally or in part the requirement to perform the Containment inspection. *

1. IF any portions of the Containment close out inspection checksheet are to* be eliminated. .

THEN mark such portions "N/A" and i_nitial them.

2. Initiate Containment inspection checksheet for plant heatup or startup as applicable.

3. Inspect Containment for heatup or startup per GOP-0 Checklist E Checksheet guidance.

ZPOOPW\GOP-0 39

...... '(

GOP-0 Rev. 6 MAY061997 GOP-0 CHECKLIST E (Page 2 of 10)

CONTAINMENT CLOSE OUT FOR H/U OR SIU 2.0 INSTROCTIClfS (Continued)

NOTE The following step stems from an incident where ma~.erial from the air filters of a telll)orary cooling unit plugged the RHR suction strainers in the.suppression pool of a BWR (equivalent to Zion's containment recirculation s~

strainers).

NRC IEB 93-02. Debris Plugging of Emergency Core Cooling Suction Strainers. requires action to identify a.nd reroove all sources of fibrous material from conUirnl'lent prior to power operation.

In addition to loose material. any item that could become dislodged during a LOCA and potentially restrict flow to the containment recirc su111> should be evaluated (consider water/steam iff1)ingement and weakening of*the item and its fasteners by exposure to water/steam}.

4. Inspect all areas of containCJP.nt for material which could potentially clog the containment recirc .suff1) during the recirculation phase of a LOCA. Cf/n 2)

Exalll)les:

Cleaning materials.

Rags. Kim Wipes. paper towels. etc.

Packing materials .

.Wire.

Check for wire used in non-perma~nt installations.

(Non-qualified installations could res~lt in items becoming dislodged by steam/water i111>ingement. and then being swept along to obstruct the sul!J) intake screen).

Posted signs.

Radiation survey tags.

Inspection/maintenance tags.

(e.g. on fire extinguishers and emerqency lights)

OOS cards.

Plastic sheeting.

Visqueen.

Herculite.

ZPGOPW\GOP-0 40

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. ,* .... :-* .:*.~** ~

,'.!:'.,;.' "**":J ..I\ * * *. * .,.. * ,* *>*'!" \ ".";* . **. \ *p"M * '_*:.;** **,** , . : *"

GOP-0 Rev. 6 .

MAY061997 GOP-0 CHECKLIST E (Page 3 of 10)

CONTAINMENT CLOSE OUT FOR H/U OR S/U

2.0 INSTROCTl<*S (Continued)

String. t~irie. rope. etc.

Safety tape.

Fire lagging material properly encased.

Must be enclosed in 11a* wire mesh casing.

Adhesive tape.

Check for installed tape also.

(Adhesive tape will not withstand LOCA environment)

Cardboard.

Wood. plywood. pressboard. etc.

Check for installed ~ood products also.

(Wood w~ 11 not wi ti stand LOCA environment)

Sheet meta1.

Check for installations that may not be of permanent design. (Non-qualified installations could result in the sheets becoming dislodged due to steam/water i""ingement. and then being swept along to obstruct the suq> intake screen).

5. Document satisfactory items by initiaHng in the appropriate spaces.

6. IF an item is NOT satisfactory.

THEN perform tnefol lowing: .

a. Perform corrective action(s) as possible.

b. IF an unsatisfactory condition can NOT be corrected.

TREN perform the following_: -

1) Hark the item *uNSAT".

2) Describe the problem in the *remarks~ section and mark it

Htu* or *stu* as applicable. . .

ZP(X)PW\<ff*O 41

GOP-0 Rev. 6 MAV061997 GOP-0 CHECKLIST E (Page 4 of 10)

CONTAINMENT CLOSE OUT FOR H/U OR S/U 2.0 INSTRUCTIONS (Continued)

7. WHEN the checksheet is caq>leted.

'TRER perform the following:

a. Sign and date the checksheet in the appropriate spaces.

b. Forward.the checksheet to the Unit Supervisor for review.

NOTE The Unit Supervisor performs steps 8 through 10 .

. 8. Review the coq,l~ted. checksheet.

9. IF any unsatisfactory conditions are noted.

TREN initiate corrective actions.

10. WHEN the checksheet has been satisfactorily coll1)leted.

TRER perform the following:

a. Sign and date the checksheet in the appropriate spaces.

b. Initial and date GOP-0 *startup Package Document Checklist" in the 3ppropriate spaces.

3. 0 FOOTNOTES

l. *Individual Plant Examination Insight Nunter ZI-330/IP.

2. 295-101-93-00205

3. 295-100-94-010-I.B.l.l

4. 295-180-94-00706 ZPGJPW\GOP-0 42

-:-.-*) ... , ..

GOP-0 Rev. 6 MAY061997 GOP-0 CHECKLIST E (Page 5 of 10)

CONTAINHENT CLOSEOUT FOR H/U OR SIU CHECKSHEET (Sheet 1 of 6) oa*te tu_p_#---~-

Star....

Unit I- - - -

PRIOR PRIOR INSPECTION-REQUIRED CONDITION TO H/U TO SIU (INITIALS) (INITIALS) 590' ELEVATION INSIDE MISSILE BARRIER RCP Oil Levels - NO~L Upper RCP A Carrow mark to 112- above arrow mark) RCP B RCP C RCP D Lower RCP A RCP B RCP C RCP D NOTE All chain locked items require a UNIT KEY to unlock and.

position in proper loc:ation. .

Ladders for RCPs - CHAINED & LOCKED _ RCP A TO STRUCTURAL STEEL RCP B OR RCP C FASTENED""TO BRACKET "RCP D Lead Storage Gang Boxes - Box #1 CURBED Box #2 or Box #3 BOLTED DOWN or CHAINED &LOCKED TO STRUCTURAL STEEL Loose Tools or Equipment - NONE Trc!sh

REMOVED Anti-C Clothing - REMOVED ZPGOPW\GOP-0

)

43

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GOP-0 Rev. 6 MAY061997 GOP-0 CHECKLIST E (Page 6 of 10)

CONTAINMENT CLOSEOU. )R H/U OR S/U CHECKSHEET (Sheet 2 of 6)

PRIOR PRIOR INSPECTION-REQUIRED CONDITION TO HIU TO SIU (INITIALS) (INITIALS) 568' ELEVATION INSIDE MISSILE BARRIER Reactor Cavity Su~ - STRAINER COVER-CLEAR Reactor Cavity Surrp Blowout Panels

. MsR* LOCKS REMOVED NIA

- EXPLOSION PINS INSTALLED NIA Lead Storage Gang Boxes* Box #1 INSIDE THEIR CURBS Box #2 Box #3 NtS Detectors (8) - FULLY INSERTED IN WELL ANO N/A 2 P'INS INSTALLED. (located on Biological Shield Wall)

Reactor Containment Surrp - STRAINER COVER CLEAR 1(2)DT-0001. *Refueling Cavity to Containment Suq>

Drain Valve* [Z-4(2-31)) - LOCKED OPEN (fin 1)

_Recirc Suq> - STRAINER.COVER CLEAR Tools and Maintenance Equipment - NONE (secure any loose equipment in authorized tool storage boxes on 617' elevation)

Trash - REMOVED

Anti-C clothing - RHOVED 568' ELEVATION OUTSIDE MISSILE BARRIER Missile Barrier Doors - LOCKED N/A Tools and Maintenance Equipment - NONE (secure any loose equipment in authorized

tool storage boxes on 617' elevation)

FOP Ladder - CHAINED &LOCKED Trash - REMOVED Anti-C Clothing - REMOVED Step-off*Pad Papers - REMOVED RCFC drains - CONDENSATION FLOW FROM RUNNING RCFCs ZPGOPW\GOP-0 44

GOP-0 Rev. 6 MAY081997 GOP*O CHECKLIST E (Page 7 of 10)

CONTAINMENT CLOSEOUT FOR H/U OR SIU CHECKSHEET (Sheet 3 of 6)

PRIOR PRIOR INSPECTION-REQUIRED CONDITION TO H/U TO SIU (INITIALS) (INITIALS) 590' ELEVATION OUTSIDE MISSILE BARRIER VERIFY access doors for ALL RCFCs are LOCKED CLOSED.

RVOOOl A Reactor Containment Fan Cooler.

RV0002 B Reactor Containment Fan Cooler.

RV0003 C Reactor Containment Fan Cooler.

RV0004 OReactor Containment Fan Cooler.

RVOOOS E Reactor Containment Fan Cooler.

Loose Too 1s or Equipment .. NONE Trash - REMOVED Anti-C Clothing - REMOVED Step-off Pad Papers - REMOVED Escape Hatch . ~ SECURED IN THE CLOSED POSITION

- CLEAR OF CLUTTER - Containment Side

- OPERABLE*

Escape Hatch door seal air pressure greater tha'n or equal to 2.5.PSIG as read on PI-PP34. 617' directly over Escape Hatch.

617' ELEVATION - RX CAVITY. PZR COFFIN. CRD FANS Tool Storage Gang Boxes - Box /11 BOLTED DOWN Box #2 or CHf,INED & LOCKED TO STRUCTURAL STEEL Air Sa!l1)ler and Dehumidifier - SECURED TO TABLE RT Work Bench

BOLTED DOWN or CHAINED & LOCKED Following Equipment - WIRED TO GRATING Reactor Head Ladder Equipment Lifting Cables .

lifting Rigs Fol lowing Equipment - CHAINED & LOCKED TO STRUCTURAL STEEL Reactor Head Bolt StQrage Racks Manipulator Crane Fans - OFF (switch on crane)

Loose Tools or Equipment - NONE Trash

REHOVED Anti-C Clothing - REMOVED Step-off Pad Papers* REf()VED Transfer Canal Blank Flange. INSTALLED NIA Purge Valves

Pins REMOVED , N/A

Access Hatches INSTALLED N/A ZPGOPW\GOP-0 45

** ,:;*,u *, ****1 GOP-0 Rev. 6 MAY061997 GOP*O CHECKLIST E (Page 8 of 10)

CONTAINMENT CLOSEOUT FOR H/U OR SIU CHECKSHEET (Sheet 4 of 6)

PRIOR PRIOR INSPECTION-REQUIRED CONDITION TO H/U TO SIU (INITIALS). (INITIALS)

CONTAINMENT DOORS Posted as High Radiation Area N/A Personnel access hatch chained and N/A locked after all personnel have exited contai rvnent.

FUEL BUILDING Transfer Canal valve - CLOSED N/A Contairvnent lights*- OFF unless required N/A I

'Manipulate Crane Power Supply - OFF U-1

HCC 13310 - ES U-2

HCC 23318

04 R.C.C. Change Fixture Power Supply - OFF

- U-1

HCC 1331A - Cl U-2

HCC 2331C - J6 PERSONNEL HATCH Tools to open doors in place (located in hatch) .

ZPGOPW\GOP-0 46

.*' *~ . .'"* ...... ,,.,.. .

I GOP-0 Rev. 6 MAY061997 GOP-0 CHECKLIST E (Page 9 of 10}

CONTAINMENT CLOSEOUT FOR H/U OR S/U CHECKSHEET (Sheet S of 6)

PRIOR PRIOR INSPECTION-REQUIRED CONDITION TO H/U TO S/U (INITIALS) (INITIALS)

FHE CAP CHECK (f/n 3) 617' Z-5 (Z-31) at bottom of hatch stairs by RP humidifier CONT AIR MONITORING INLET (P-44)

Must be uncapped unless directed by LSS.

592' Z-5 CZ-30) in letdown orifice block valve room (penetration area)

CONT PRESSURE SENSING LINE FOR PT-CS19 P-41 Must be uncapped in nx>des 1. 2. 3. and 4.

CONT PRESSURE SENSING LINE FOR PT-CS22 P-54 Must be uncapped in RKJdes 1. 2. 3. and 4.

CONT PRESSURE SENSING LINE FOR PT-CS20 P-78 Must be uncapped in RKJdes 1. 2. 3. and 4.

CONT PRESSURE SENSING LINE FOR PT-CS21 P-82 Must be uncapped in liXldes 1. 2. 3. and 4.

CONT PRESSURE AND VACUUM RELIEF P-60 Must be uncapped in RKJdes 1. 2. 3. and 4.

ACCUMULATOR NITROGEN VENT P-76 Must be uncapped in RKJdes 1. 2. 3. and 4.

CONT AIR MONITORING OUTLET P-44 Must be uncapped unless directed by LSS.

560' z.5 CZ-30) pipe penetration area:

HYDROGEN RECOMBINER OUTLET P-56 Must be uncapped in lll)des 1 through 4.

592' puflll deck 1MB:

HYDROGEN MCNITORING SYSTEM (P-15)

ALL 111Jst be uncapped unless directed by LSS.

Z-6 CZ-28) by A RCP near missile barrier wall.

Z-11(2-24) by C RCP near missile barrier wall.

Z-16(2-20) by DRCP near missile barrier wall.

Z-2 (Z-23) by B RCP near missile barrier wall.

ZPGOPW\GOP-0 47

GOP-0 Rev. 6 MAY061997 GOP-O*CHECKLIST E (Page 10 of 10)

CONTAINMENT CLOSEOUT FOR H/U OR SIU CHECKSHEET (Sheet 6 of 6)

REMARKS:

Prior to H/U Inspected By Date Unit Supervisor Review

Ap"'""p=ro,,...v-ea-ey--.-.C,.....,n..._4,----- Date Prior to S/U

- -....1....n-sp-ec-te-a-ey_ __ Date Unit Supervisor Review:

- .....A""'"pp=r=ov'"""e,.,,,.d....

By.,.,........,.(-tl-n......4~)- - Date

.I FINAL ZPGOPW\GOP-0 48

~ ...... ,.-.... ' .. ; .

ZRA97016 ENCL0SURE3 Referente 5.14 of Caltulation 22S-B-008M-092.

~,-*.... *:*, ,...... .....

~

Commonwealth Edison Company ENC-QE-76.5 Engineering and Constructio n *Page 1 of 1 Document Coding Form Computer Entry:

Company SARG Name SLD CECO Station ZD: ZI Zion D8D Code r-, l:i.l.ber :

Docwnent Category: 08 DBD Reterence Number: 08.00586 Document Identificat ion:

Title/Subje ct: RECIRCULATION SUMP SCREEN Revision: 0 create Date: I I Vendor Code: 6040 Originating organizatio n: S&L Department : MECHANICAL Person: Related to DBD?:

In Reference Manual?: N Format: HC Quantity of Pages: 0007 (Including Coding Forms)

Proprietary : N Document Text File:

Abstract:

File Location: BOOK 13 TAB 16

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ZRA97016 ENCWSURE4 Reference 5.5 of Calculation 22S-B-008M-092

~ ' :: *...,, ......... *.

ZRA97016 ENCWSURE5 Table on page 2-10 of Reference 5.2 *or Calculation 22S-B-008M-092

I ~ Ingersoll-Dresser Pumps ( :a1111*ro11 Hyclniulil' I >i.lt ...

Discharge From Rectangu-lar Weir with End Contractions Figures in Table arc in Gallons Per M,nute LP.ngth (LI ot weir 111 reel Length (LI of we,r ,n feel Addi- Add**

Head 11ona1 Head honal (HI gpm for IHI gpm for

,n each It each II inches I J 5 over 5 fl '"

inches J 5 over 5 II 1 JS 4 107 5 1798 3605 8 2l3l' 3956 814 1v.. 49 S ISO 4 250 4 504 av. 2442 4140 850 1111 64 9 197 329.5 66 2 a*., 2540 4312 890 n:. 81 248 415 BJ 5 8~* 2656 4511 929 2 98 S 302 506 102 9 2765 4699 970 2*,. 117 361 605 122 9'/* 2876 4899 1011 2'11 136.2 422 706 143 9'-'z 2985 5098 1051 21,-;. 157 485 815 ,as 91. 3101 52BB 1091 J 111 e 552 926 187 10 3216 5490 1136 J\c 1998 62*1 1047 21 I 10*:1 3480 5940 1230 J'.'1 222 695 1167 236 11 3716 6355 1320 31-:. 245 769 1292 261 I I '-'z 3960 6780 1410 4 '-69 O*lfi 147.'1 280 12 4165 7165 1495

,t** 2936 925 IS59 1575 JIG t:!'1 4430 7595 JIO 1006 1696 3.15 IJ 4660 BOIO 1660 4i, 344 1091 1835 374 13'*1 4950 8510 1780 5 370 1175 1985 405 t-1 5215 8980 1885 51!4 J!l5 5 lc'?li2 21JO 434 1-1 11 Sol7S 9,uo 19135 s**, 421 6 1352 2282 465 15 5740 9920 2090 5\* 449 14~2 2440 495 15*:, 6015 10400 2165 6 476 5 . 1535 2600 528 Iii 6290 10900 2300 Ii* 1632 2760 560 15*:1 6565 11380 21110 6'/i 1742 2920 596 17 6925 I 1970 2520 6¥. 1e;:.; 3094 630 11**1 7140 12410 264C 7 1928 3260 668 18 7410 12900 2745 1*,. 2029 3436 701.S 18'/z 7695 13410 2855 1

7 11 2130 3609 736 19 7980 13940 2970 n,. 2238 3785 774 19Vr 8280 14460 3090 Th,s table ,, based on Francis lorrnula.

0

3.33 (L - 0.2H)H' *

,n wh,ch 0

II' of waler llow,ng per second.

L

lengtl, ol weir opening in feel (should be

to 8 1,mes HI.

H

head on weir in feet (lo be measured al least 6 II back or weir opening) a

shoulcl be al least 3 H 2-10

-*,:';'7(:*- .... , .. . , *., ** ......

ZRA97016 ENCL0SURE6 Page 17 of Reference 5.17 of Calculation 12S-.B-008M-092

'. *._. *: .* *,*. *' ., ;,:..;. *. - .,, '** .,. *( ,, ,. ~*-*

FIGURE 9 RESISTANCE COEFFICIENT FOR STRAINERS ANO COARSE FILTERS

("Local Resistance to Flow,tt Louis Dodge, Product Engineering -

March 1974, Page 68) 10 i LI r ' . L.___. . . .

8 L. .l_!_J _jFo:- a: u6o I I LU 11 I I I I I I 6

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o. 25 o.so o. 75 A0 = O~~~ e.:*~. r~2

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-:", "2 =

,. +sol l"d a:'!a, f t 2

.._ - .1. .... * *-*----*-

0 FIGURE 10 RESISTANCE CORRECTION FACTOR

("Local Resistance td Flow," Louis Dodge, Product Engineering -

March 1964, Page 68) 1.5 ---~~~--~ --~-

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l.O .____ __.________.___ .;..._;,i 50 lCO l5v 200 jOO 400 Re For R < 400 K

Z x K (for R, > 400)

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FOA OFFICE USE ONLy. NOT TO ee SENT OUTSIDE OF SARGENT I LUNDY 1r-... ,.....

S-2.16 Page 17 of 17 E

"='.*.***io*.,*.*'i!*.\I*'.* **;:*;"'* ... .**-*:. * **.,. * *** ,* .,.* ,. ~ ...,..--;- *: * , **. "I ZRA97016 ENCLOSURE 7

Drawing of the Containment Sump I . , ... : ', \, .>.. *"* *".

I ;_, ...

DOCUMENT PAGE(S) PULLED . .

~---------------

SEE APERi,..UR E CARD FILES APERTURE CARD/PAPER COP i AVAILABLE THROUG

- - - - H NRC FILE CENTER NUMBER OF OVERSIZE PAGES FILMED ON APERTU RE CARD(S)

- - - - t:?-

ACCESSION NUMBERS OF OVERSIZE PAGES:

'110~!'/0QO 3

':/10'111000 5' - - - -

ML19046A222

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ML19046A222

Text

Subject:

References:

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SUMMARY

1.0 INTRODUCTION

SUMMARY

7.0 REFERENCES

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