ML20006D106

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Responds to Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety-Related Equipment. Dredge & Visual Shoreline Insps of Missouri River Near Plant Intake Indicated Presence of Small Numbers of Asiatic Clams
ML20006D106
Person / Time
Site: Callaway Ameren icon.png
Issue date: 01/29/1990
From: Schnell D
UNION ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-13, ULNRC-2146, NUDOCS 9002120103
Download: ML20006D106 (21)
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(j r January 29, 1990 Donwdt.sennen EtuN!r?Nc ,2 " '~~ l M U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Statio'n P1-137  !

Washington, D.C. 20555  :

Gentlemen: ULNRC- 214 6 DOCKET NO. 50-483 '

CALLAWAY PLANT RESPONSE TO GENERIC LETTER 89-13 SERVICE WATER SYSTEM PROBLEMS AFFECTING SAFETY-RELATED EQUIPMENT i i

Union Electric Company received the subject NRC l' Generic Letter 89-13 in July 1989. The letter requested a response within 180 days to show that the callaway +

programs for service water systems are in compliance with ,

regulatory requirements and to addreas the NRC i recommendations presented in the Generic Letter. The Generic Letter defines the service water system as the  !

system or systems that transfer heat from safety-related structures, systems, or components to the ultimate heat sink. Attachment 1 to this letter provides a description  ;

of those systems for Callaway.

Attachment 2 to this letter provides the information  ;

requested in the Generic Letter, in accordance with -

10CFR50.54(f). Attachment 2 provides a restatement of the relevant portions of the NRC recommendations, followed by the Union Electric response to each item. 7 Attachment 3 to this letter provides a comparison between the Callaway Heat Exchanger Monitoring Program

, and Enclosure 2 of the Generic Letter.

l l A confirmatory letter will be sent to the NRC when L all action items of Union Electric's response are implemented. Implementation of actions which are not in place at this time will be complete by startup after Refuel 4, scheduled to begin September, 1990.

I Union Electric responses are based on current and planned Callaway programs which are subject to change as t plant procedures and practices are revised. Any such changes are reviewed to assure that they do not adversely impact plant safety (i.e., a review based on 10CFR50.59).

9002120103 900129 O Sh l PDR ADOCK 050004S3

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If additional information is required, please contact me or Mr. D.E. Shafer of my staff.

Very truly yours, Donald F. Schnell DJW/dvd-Attachment 1, Service Water Systems Descriptions-Attachment 2, Union Electric Responses to NRC Recommendations Attachment 3, Callaway Heat Exchanger Monitoring Program Comparisons to Generic Letter 89-13, Enclosure 2

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STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Senior Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct t o the best of his knowledge, information and belief.

By / A d Donald F. Schnell Senior Vice President Huclear SUBSCR(BED and sworn to before me this dM day of Chueu * , 1990.

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DARDARA [PFAFF 8 O I40TARY PUDtlC, STATI Of MISSOURI WY COMMISSIVN [XPlRES Al'Ril 22, 1993 ST. LOUIS COUNTY

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cc Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C. 20037 f

Dr. J. O. Cermak CFA, Inc.

4 Professional Drive (Suite 110)

Gaithersburg, MD 20879 R. C. Knop Chief, Reactor Project Branch I h-U.S. Nuclear Regulatory Commission Region III

J 499. Roosevelt Road Glen Ellyn,.Il 60137 Bruce-Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRM1

' Steedman, MO 65077 S. V. Athavr.le (2) m Office of Nuclear Reactor Regulation

' U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, Maryland 20852

. Manager,. Electric Department Missouri Public Service Commission P.O. Box 360 t Jefferson City, MO 65102-U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 4

Washington, D.C. 20555 i.

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bec: D. Shafer/A160.761

/QA Record (CA-758)

Nuclear Date E210.01 DFS/ Chrono D.F. Schnell J.E. Birk J.V. Laux M.A. Stiller G.L. Randolph R.J. Irwin H. Wuertenbaecher W.R. Campbell A.C. Passwater R.R. Wendling D.E. Shafer D.J. Walker O. Maynard (WCNOC)

N.P. Goel (Bechtel)

T.P. Sharkey NSRB (Sandra Auston)

.A.160.0412(89-13)

D.S. Hollabaugh D.G. Adams 1

I

E

The Essential Service Water System circulates water from an Ultimate Heat Sink (UHS), through plant components required for safe shutdown of the reactor following an accident, and returns the water to the UHS cooling towers. The Essential Service Water System performs its cooling function, automatically and without operator action, following a LOCA or loss of off-site power. This system also provides an emergency source of water for the Auxiliary Feedwater System, the Component Cooling Water System, and the Fuel Pool Cooling and Cleanup Syster. The Callaway UHS is a man-made pond located on site. The pond is sized to supply the cooling water necessary for safe shutdown, cooldown, and maintensuce of the cooldown condition for a thirty day period, without addition of makeup water.

The various water systems referred to in the Union Electric response to Generic Letter 89-13 will be designated by the system title followed by the system abbreviation and the system designator in parentheses. These systems are the (Safety-Related) Essential Service Water System (ESWS) (EF), the (Safety-Related) Component Cooling Water System (CCWS) (EG), and the (non-Safety-Related) Service Water System (SWS) (EA).

Essential Service Water System (ESWS) (EF) Purpose and__Descri_ption The ESWS (EF) functions to automatically provide cooling water to safety related components that are required to safely shut down the reactor following a LOCA or loss of offsite power.

The ESWS (EF) consists of two Essential Service Water pumps, one mechanical draft cooling tower, with two cells per train, heat exchangers and room coolers and motor-operated valves. Two independent loops provide reliability and redundancy.

Under normal operating conditions the ESW pumps remain idle. System loads are supplied by Service Water. The ESW pumps will automatically start on the following signals:

Safety Injection Signal Loss of Offsite Power Signal Low suction pressure to Auxiliary Feedwater Pumps

. Attcchm:nt 1

. ULNRC - 2146 i Page 2 of 2 l

, l The ESWS (EF) supplies the following loads: )

Containment coolers j

Component Cooling Water Heat Exchangers

  • Diesel Generator Heat Exchangers i Room Coolers

- Safety Injection pump rooms

- Spent Fuel Pool pump rooms

- Residual Heat Removal pump rooms

- Component Cooling Water pump rooms ,

- Centrifugal Charging pump rooms

- Containment Spray pump rooms

- Electrical Penetration rooms

- Motor-driven Auxiliary Feedwater pump rooms Air Conditioning Units Control Room

- Class IE Electrical equipment Emergency Make-up

- Spent Fuel Pool

- Auxiliary Feedwater

- Component Cooling Water System Component Cooling Water System (CCWS) (EG) Purpose and Description The CCWS (EG) provides cooling water to selected nuclear auxiliary ,

components during normal plant operation and will provide cooling water to engineered safety feature systems during a loss-of-coolant ~'

accident (LOCA). The system is a closed loop system which acts as an intermediate barrier between the ESWS (EF), or the SWS (EA) and potentially radioactive systems.

The following safety-related equipment is serviced by the CCWS (EG):

- Residual Heat Removal Heat Exchanger

- Centrifugal Charging-Pump Oil Coolers Spent Fuel Pool Heat Exchangers

- Post Accident Sampling Station Sample Coolers

- Residual Heat Removal Pump Seal Coolers

- Safety Injection Pump Oil Coolers t

one CCWS pump and one heat exchanger are required during normal plant operation.

L

. Atttchm:nt 2

. ULNRC - 2146 Page 1 of 10 Union Electric Responses to NRC Recommendations in Generic Letter 89-13, Service Water System Problems Affectine Safety-Related Equipment The Callaway service water system is in compliance with the General Design Criteria and quality assurance requirements as set forth in the subject Generic Letter 89-13. The Callaway program is equally effective, and in most cases, meets the NRC recommendations detailed in the Generic Letter. Union Electric confirms that the safety functions of the service water system are being met.

Implementation of actions which are not in place at this time will be complete by startup after Refuel 4, scheduled to begin September, 1990.

NRC Recommendation I (GL 09-13)

For open-cycle service water systems, implement and maintain an ongoing program of surveillance and control techniques to significantly reduce the incidence of flow blockage problems as a result of biofouling. A program acceptable to the NRC is described in

" Recommended Program to Resolve Generic Issue 51" (Enclosure 1). It should be noted that Enclosure 1 is provided as guidance for an acceptable program. An equally effective program to preclude biofouling would also be acceptable. Initial activities should be completed before plant startup following the first refueling outage beginning 9 months or more after the date of this letter. All activities should be documented and all relevant documentation should be retained in appropriate plant records.

Union Electric's Response to Recommendation I Union Electric has established a surveillance program that is based upon a source of fresh water with virtually little or no clams. This program assures that the heat removal requirements of the service water system are met.

Dredge and visual shoreline inspections of the Missouri River in the vicinity of the Callaway Plant intake have indicated the presence of small numbers of Asiatic clams. The swift current, high silt load, instable substrates and low primary production of the lower Missouri River are not favorable conditions for most macroinvertebrates, particularly filter feeders like Asiatic clams.

A. Enclosure 1, Section A (GL 89-13)

The intake structure should be visually inspected, once per refueling cycle, for macroscopic biological fouling organisms (for example, blue mussels at marine plant, American oysters at estuarine plants, and Asiatic clams at freshwater plants), sediment, and corrosion. Inspections should be performed either by scuba divers or by dewatering the intake structure or by other comparable methods. Any fouling accumulations should be removed.

. Attachm:nt 2 ULNRC - 2146 Page 2 of 10 Union Electric Response Several actions have been taken to reduce the incidence of flow blockage problems as a result of fouling due to biofouling, mud, silt and corrosion products.

The river intake pumps are not safety-related and are inspected along with the intake pump bays for any mollusks, ,

specifically Asiatic clams, sediment and corrosion, and l shells whenever they are dewatered for maintenance purposes, i The cooling tower basin is inspected when it is drained during a planned basin outage, normally each refueling. -

This has been done each refueling since 1986. The Essential Service Water pumps and pump bay will be scheduled for ,

inspection during the next refueling outage while drained down for installation of a modification. Future inspections will be based on the results of this initial inspection, i The UHS and sludge ponds are sampled each fall for adults and new velifers. The Missouri River is normally sampled  ;

each winter during low water conditions. To date, no clam infestations have been identified in Callaway Plant systems.

B. Enclosure 1, Section B(GL 89-13) I The service water system should be continuously (for example, i during spawning) chlorinated (or equally effectively treated with another biocide) whenever the potential for a macroscopic biological fouling species exists (for example, blue mussels at marine plants, American oysters at estuarine plants, and Asiatic clams at freshwater plants).

Chlorination or equally effective treatment is included for ,

freshwater plants without clams because it can help prevent microbiologically influenced corrosion. However, the chlorination (or equally effective) treatment need not be as stringent for plants where the potential for macroscopic

! biological fouling species does not exist compared to those plants where it does. Precautions should be taken to obey Federal, State, and local environmental regulations regarding the use of biocides.

i Union _ Electric Response 1

l Callaway plant uses periodic chlorination to control microbiologically induced corrosion and fouling. Continuous ,

chlorination is not required as there is no significant potential for macrofouling due to clams.

l The SWS (EA) is chlorinated approximately two times per day l with sodium hypochlorite to control microscopic biological l fouling. Even distribution of chlorine is achieved through l batch injection of chlorine into the suction of the service l water pumps. The service water is sampled immediately after I each chlorination to ensure the proper amount of chlorine i

has been added to control microscopic biological fouling and to ensure Federal and State chlorine limitations are being i met.

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. Attochm:nt 2 ULNRC - 2146 ,

Page 3 of 10 '

NRC Recommendation I continued C. Enclosure 1, Section_C_(GL 89-13)

Redundant and infrequently used cooiing loops should be flushed and flow tested periodically at the maximum design flow to ensure that they are not fouled or clogged. Other components in the service water system should be tested on a regular schedule to ensure that they are not fouled or clogged. Service water cooling loops should be filled with chlorinated or equivalently treated water before layup.

! Systems that use raw service water as a source, such as some fire protection systems, should also be chlorinated or equally effectively treated before layup to help prevent microbiologically influenced corrosion. Precautions should be taken to obey Federal, State, and local environmental regulations regarding the use of biocides.

Union Electric Response Major branches of infrequently used cooling loops served by raw service water will be flushed using the Preventive Maintenance Program once per fuel cycle. Branches that receive flow periodically to satisfy equipment running requirements are not considered to be infrequently used or in wet layup. There are no ESWS (EF) system sections in wet layup. During flushing, the flow will be measured and trended for degradation. Due to the lack of design flush  ;

connections in certain lines, this will not be done at maximum design flow, but will be indicative of proper system performance. After the initial flush, selected lines not flushed at design flow rate will be visually inspected for fouling.

A complete flow balance of the ESWS (EF) is performed during each refueling outage. A monthly verification of major  ;

branch flows will be expanded for gross trending after ,

installation of additional instrumentation.

D. Enclosure 1, Section D_(GL 89-13).

Saaples of water and substrate should be collected annually to determine if Asiatic clams have populated the water source. Water and substrate sampling is only necessary at freshwater plants that have not previously detected the presence of Asiatic clams in their source water bodies. If Asiatic clams are detected, utilities may discontinue this sampling activity if desired, and the chlorination (or equally effective) treatment program should be modified to be in agreement with paragraph B, above.

I, Att chm:nt 2 ULNRC - 2146 Page 4 of 10 Union Electric Response Callaway Plant has an effective water and substrate sampling L program to detect any population or infestation of corbicula and other microorganisms.

The present mollusk sampling program includes the following:

1. Dredge and visual shoreline inspections of the Missouri River in the vicinity of the Callaway Plant intake during low water conditions, normally during the fall of each year.
2. Annual fall inspection and dredge sampling in the UHS and sludge ponds.
3. Inspection of intake pump bays once per year and the cooling tower basin during each refueling outage (eighteen months).

At present, Callaway personnel notify Union Electric's Environmental Services Department when shello are found during operation or maintenance activities. Additional action is then taken as necessary. No modifications to the present program are planned. The present program provides adequate protection from Asiatic clam infestations that would threaten safety-related water systems. If significant increases in the incidence of shells either in the plant or in the river is documented, additional investigation will be ovaluated.

The occurrence of the Zebra mussel (Dreissena-Polymorpha) has not been documented in Missouri. The present program will identify the Zebra mussel if and when it appears in the Missouri River or in the plant, and appropriate steps will be taken.

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L L .- Atttchm:nt 2 ULNRC - 2146 Page 5 of 10 NRC Recommendation II (GL 89-13_1 Conduct a test pregram to verify the heat transfer capability of all safety-related heat exchangers cooled by service water. The total test program should consist of an initial test program and a periodic retest program. Both the initial test program and the periodic retest program should include heat exchangers connected to or cooled by one or more open-cycle systems as defined above, operating experience and studies indicate that closed-cycle service' water systems, such as component cooling water systems, have the potential for significant fouling as a consequence of aging-related in-leakage and erosion or corrosion. The need for testing of closed-cycle system heat exchangers has not been considered necessary because of the assumed high quality of existing chemistry control programs. If the adequacy of these chemistry control programs cannot be confirmed over the total operating history of the plant or if during the conduct of the total testing program any unexplained downward trend in heat exchanger performance is identified that cannot be remedied by maintenance of an open-cycle system, it may be necessary to selectively extend the test program and the routine inspection and maintenance program addressed in Action III, below, to the attached closed-cycle systems.

A program acceptable to the NRC for heat exchanger testing is described in " Program for Testing Heat Transfer Capability" (Enclosure 2). It should be noted that Enclosure 2 is provided as guidance for an acceptable program. An equally effective program to ,

ensure satisfaction of the heat removal requirements of the service water system would also be acceptable.

Testing should be done with necessary and sufficient instrumentation, though the instrumentation need not be permanently installed. The relevant temperatures should be verified to be within design limits.

If similar or equivalent tests have not been performed during the past year, the initial test should be completed before plant startup following the first refueling outage beginning 9 months or more after the date of this letter.

As a part of the initial test program, a licensee or applicant may decide to take corrective action before testing. Testa should be performed for the heat exchangers af ter the corrective actions are taken to establish baseline data for future monitoring of heat exchanger performance. In the periodic retest program, a licensee or applicant should determine after three tests the best frequency for testing to provide assurance that the equipment will perform the intended safety functions during the intervals between tests.

Therefore, in the periodic retest program, to assist that determination, tests should be performed for the heat exchangers before any corrective actions are taken. As in the initial test program, tests should be repeated after any corrective actions are taken to establish baseline data for future monitoring of heat exchanger performance.

7_

Att chm:nt 2 c'=

ULNRC - 214 6

Page 6 of 10 t

NRC Recommendation __II (GL 89-13) - continued l An example of an alternative action that would be acceptable to the NRC is frequent regular maintenance of a heat exchanger in lieu of ,

l testing for degraded performance of the heat exchanger. This L

alternative might apply to emall heat exchengers, such as lube oil coolers or pump bearing coolers or readily serviceable heat exchangers located in low radiation areas of the facility.

In implementing the continuing program for periodic retesting of safety-related heat exchangers cooled by service water in open-cycle systems, the initial frequency of testing should be at least once each fuel cycle, but after three tests, licensees and applicants should  :

determine the best frequency for testing to provide assurance that the  ;

equipment will perform the intended safety functions during the I intervals between tests and meet the requirements of GDC 44, 45, and

46. The minimum final testing frequency should be once every 5 years.

A summary of the program should be documented, including the schedule for tests, and all relevant documentation should be retained in appropriate plant records.

Union Electric's Response to Recommendation II A program to verify the heat transfer capability of all safety related ,

heat exchangers cooled by the ESWS (EF), is presently in place at ,

Callaway Plant. This program follows, with few exceptions, the guidelines of NRC Generic Letter 89-13, Enclosure 2. A comparison of this Heat Exchanger Monitoring Program and Enclosure 2 of the Generic Letter are shown in Attachment 3 to this letter. This program also utilizes the " Heat Exchanger Performance Guidelines For Service Water Systems" prepared by the EPRI Service Water Working Group where deemed ,

appropriate.

The Diesel Generator and Component Cooling Water heat exchangers are inspected each outage in addition to heat transfer testing. The regular maintenance on the heat exchangers will continue until sufficient maintenance and testing history are obtained. Tho testing and maintenance program may be revised on the affected heat exchangers at that time.

Heat exchangers supplied by the CCWS (EG) are not tested for heat transfer capability because of the high quality of water chemistry control. Sodium molybdate and Tolytriazol have been added since initial operation. Corrosion coupons removed from the system show mild steel corrosion rates consistently less than one mil per year.

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. Attcchm:nt 2 I

ULNRC - 2146 Page 7 of 10 NRC Recommendation III (GL_89-131 Ensure by establishing a routine inspection and maintenance program for open-cycle service water system piping and components that corrosion, erosion, protective coating failure, silting, and '

biofouling cannot degrade the performance of the safety-related systems supplied by service water. The maintenance program should have at le>1t the following purposes:

A. To remove excessive accumulations of biofouling agents, corrosion products, and silt; B. To repair defective protective coatings and corroded service

water system piping and components that could adversely affect performance of their intended safety functions. -

This program should be established before plant startup following the first refueling outage beginning 9 months after the date of this letter. A description of the program and the results of these maintenance inspactions should be documented. All relevant documentation should be retained in appropriate plant records.

Union Electric's Response to Recommendation III Selected sections of ESWS (EF) piping are inspected each refueling outage for corrosion, erosion, and biofouling. Specific combinations of piping locations such as upstream and downstream of valves, reducers, fittings, elbows, and straight piping runs have been selected for inspection. Each pipe is radiographed to determine any localized pitting. This is followed by ultrasonic testing using accurately placed grid locations to determine the extent of any damage. These results are evaluated to determine appropriate action.

  • ESWS (EF) piping four inches and less have been selectively tested except for the RHR Pump Room Cooler piping due to high radiation levels. The SI Pump Room Cooler piping inspection results will serve  ;

as an acceptable indicator for RBR piping corrosion damage. Any piping with localized damage will be retested and trended each refueling outage. Other piping which clearly shows no damage will be retested at extended frequencies. Based upon these results, piping will be repaired or replaced, material selection evaluated, and chemicel treatment methods assessed.

. Att: chm:nt 2-ULNRC - 214 6 Page 8 of 10 L NRC Recommendation IV_(0L 89-13),

Confirm that the service water system will perform its intended function in accordance with the licensing basis for the plant.

Reconstitution of the' design basis of the system is not intended.

This confirmation should include a review of the ability to perform

required safety functions in the event of failure of a single active component. To ensure that the as-built system is in accordance with the appropriate licensing basis documentation, this confirmation should include recent (within the past 2 years) system walkdown inspections. Results should be documented and retained in appropriate plant records.

! Union Electric's Response to Recommendation IV The ESWS (EF) and the CCWS (EG) will perform its intended function in accordance with the licensing basis of the plant. Items considered were the single active failure analysis and recent configuration walkdowns.

Single active failure analyses for the ESWS (EF) and CCWS (EG) system are depicted in FSAR Table 9.2-5 and Table 9.2-12 respectively. All of the failure scenarios from both FSAR tables were reviewed against design drawings and verified to be correct. The design drawings used for the ESWS (EF) were verified correct by a system configuration' walkdown. This walkdown was performed during the 1988 Safety System Functional Assessment (SSFA) of the ESWS (EF), performed by a Union Electric multi-disciplined task force. Paragraph 7.1.3 of the final SSFA report-88-01 (EF) describo the system walkdown performed. Items reviewed included the following:

separation criteria II/I design-seismic qualification

-design ratings of equipment conformance with design drawings pipe supports equipment material condition valve position position indication equipment labeling Results of this walkdown confirm the effectiveness of the Callaway Plant Configuration Control Program. Based upon this confirmation, no-walkdown is planned or deemed necessary for the CCWS (EG).

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. Attcchm:nt 2 f -

ULNRC - 2146 Page 9 of 10 NRC Recommendat_ ion V Confirm that maintenance practices, operating and emergency procedures, and training that involves the service water system are adequate to ensure that safety-related equipment cooled by the service water system will function as intended and that operators of this equipment will perform effectively. This confirmation should include i recent (within the past 2 years) reviews of practices, procedures, and training modules. The intent of this action is to reduce human errors in the operation, repair, and maintenance of the service water system.

This confirmation should be completed before plant startup following the first refueling outage beginning 9 months or more after the date of this letter. Results should be documented and retained in appropriate plant records.

Union Electric's Response to Recommendation _V _

A. MAINTENANCE Current maintenance practices and methods wore reviewed for adequacy to ensure safe and reliable operation of the cafety related Service Water System. Other items reviewed were the.INPO program for mechanical and electrical programs, the Callaway.

Administrative program, appropriate maintenance department -

procedures and the Safety System Functional Assessment. Licensee Event Reports and Incident Reports related to ESWS (EF), CCWS (EG), and SWS (EA), were reviewed during semi-annual maintenance personnel requalification.

B. OPERATIONS The Callaway Operations Department completed a comprehensive review and revision of Emergency Operating Procedures in May of .

1989 which ensured that all Emergency Operating Procedures satisfied all of the criteria established by the Emergency Response Guidelines issued by the Westinghouse Owners Group.

These criteria encure that Equipment Operators and Licensed Operators will initiate the appropriate actions to mitigate the consequences of any accident bounded by the FSAR analyses. ,

Furthermore, Operations performed an extensive review of the items in NUREG 1275, Vol. 3, Appendix A. Forty-six of the 276 events were attributable to persor.nel/ procedural errors. No trend was identified to warrant changing any Callaway Plant operating procedure.

The Workman's Protection Assurance Program combined with the standing policy to perform all normal system operating procedure valve / breaker lineups after major outages and major maintenance work is sufficient to minimize the occurrence of incorrectly positioned valves and breakers.

n: 1 Attachm^nt 2 l ULNRC - 2146 Page 10 of 10-Union Electric's Response to '

pocommendation V continued The existing Annunciator Response Procedures, Normal Operating i Procedures, and Off-Normal Operating Procedures were reviewed and i are adequate to ensure that safety-related equipment cooled by z the_ service water system will function as intended, and that l appropriate operator guidance is provided. Specific current i L system related industry events, Licensee Event Reports, and  !

-Incident Reports are covered during requalification training.

e i t- C. TRAUUNj;!  ;

o Adequate attention has been given to service water system L problems training involving the loss of ESWS (EF) and CCWS (EG). I Training is performed annually on the plant simulator as part of ,

Licensed operator Requalification Training. Samples of actual l Asiatic clam shells are used during training to help reinforce  ;

the importance of recognizing them and notifying Environmental e Services. Current industry events, Licensee Event Reports and  !

Incident Reports related to ESWS (EF), CCWS (EG), and SWS (EA)  ;

are evaluated for inclusion into all initial and requalification .;

training.

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Attachment 3 IJLNRC .2146 Page 1- cf G COMPARISON BETWEEN GENERIC LtAAnR 89-13, ENCLOSURE 2 AND CALLAWAY'S HEAT EXCHANGER MONITORING PROGRAM GENERIC LtciAtx 89-13 UNION ELECTRIC ENCLOSURE 2 RESPONSE I. For all heat exchangers The major branch flows of the ESWS (EF) in an emergency lineup Monitor and record cooling water flow and inlet are verified every month; flows and outlet temperatures for all affected heat are trended.

exchangers during the modes of operation in which cooling water is flowing th rough the heat A complete flow balance of the ESWS exchanger. For each measurement, verify that (EF) is performed every 18 the cooling water temperatures and flows are months.

Within design limits for the conditions of the measurement. The test results from periodic Normal operation procedures and testing should be trended to ensure that flow surveillance testing verify blockage or excessive fouling accumulation does temperatures of components and not exist. areas cooled by coolers are within acceptable limits as applicable.

II. In addition to the considerations for all heat The Diesel Generator, Component exchangers in Item I, for water-to-water heat Cooling Water, Control Room Air exchangers Conditioner and Class IE Air Conditioners are tested near A. Perform functional testing with the heat design accident conditions. If exchanger operating, if practical, at its the conditions at which the unit design heat removal rate to verify its is tested significantly differ capabilities. Temperature and flow from design conditions, the test compensation should be made in the results will be corrected to calculations-to adjust the results to the design conditions. Test results design conditions. Trend the results, as will be trended.

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Attachment 3 ULNRC -2146 Page 2 cf G COMPARISON BETWEEN GENERIC LETIER 89-13, ENCLOSURE 2 AND CALLAWAY'S HEAT EXCHANGER MONITORING PROGRAM

. GENERIC LEr1ER 89-13 UNION ELECTRIC ENCLOSURE 2 RESPONSE explained above, to monitor degradation. An example of this type of heat exchanger would be that used to cool a diesel generator.

Engine jacket water flow and temperature and service water flow and temperature could be monitored and trended during the diesel generator surveillance testing.

B. If it is not practical to test the heat See Above exchanger at the design heat removal rate, then trend test results for the heat exchanger efficiency or the overall heat transfer coefficient. Verify that heat removal would be adequate for the system operating with the most limiting combination of flow and temperature.

III. In addition to the considerations for all heat exchangers in Ite.m I, for air-to-water heat exchangers A. Perform efficiency testing (for example, in A. The Containment Coolers and conjunction with surveillance testing) with Penetration Room Coolers heat the heat exchanger operating under the removal rate will be trended maximum heat load that can be obtained and compared to design values practically. Test results should be to identify degraded equipment.

corrected for the off-design conditions.- The Penetration Room Coolers e

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Attachment 3 ULNRC -2146 Page 3 cf 4 COMPARISON BETWEEN GENERIC Lhrrhx 89-13, ENCLOSURE 2 AND CALLAWAY'S HEAT EXCHANGER MONITORING PROGRAM GENERIC LErlhx 89-13 UNION ELECTRIC ENCLOSURE 2 RESPONSE Design heat removal capacity should be will be used as a verified. Results should be trended, a3 representative sample of all explained above, to identify any degraded room coolers because it is the equipment. only room cooler with a significant heat load.

B. If it is not possible to test the heat exchanger to provide statistically significant results (for example, if error in the measurement exceeds the value of the parameter being measured), then

1. Trend test results for both the air and B. 1. Air and water flow rates of water flow rates in the heat exchanger. all air to water heat exchangers are taken and the results trended.
2. Perform visual inspections, where B. 2. Visual inspections of the possible, of both the air and water sides air side of the heat of the heat exchanger to ensure exchangers will be cleanliness of the heat exchanger. performed. Visual inspection of the water side is not possible, however differential pressure (DP) testing of the coolers will be performed to detect macro fouling and test results trended.

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Attachment 3 ULNRC - 2146 Pcge G cf G COMPARISON BETWEEN GENERIC Ltmx 89-13, ENCLOSURE 2 AND CALLAWAY'S HEAT EXCHANGER MONITORING PROGRAM GENERIC LtutR 89-13 UNION ELECTRIC ENCLOSURE 2 RESPONSE IV. In addition to the considerations for all heat All heat exchangers are covered by exchangers in Item I, for types of heat Union Electric's responses to exchangers other than water-to-water or Table Items I through III.

air-to-water heat exchangers (for example, penetration coolers, oil coolers, and motor coolers)

A. If plant conditions allow testing at design heat removal conditions, verify that the heat exchanger performs its intended functions. Trend the test results, as explained above, to monitor degradation.

B. If testing at design conditions is not possible, then provide for extrapolation of test data to design conditions. The heat exchanger efficiency or the overall heat transfer coefficient of the heat exchanger should be determined whenever possible.

Where possible, provide for periodic visual inspection of the heat exchanger. Visual inspection of a heat ex<-hanger that is an integral part of a larger component can be performed during the regularly scheduled disassembly of.the larger component. For example, a motor cooler can be visua.11y inspected when the motor disassembly and inspection are scheduled.

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