ML20006D120

Responds to Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety-Related Equipment. Responsibility for post-accident,long-term Cooling Primarily Relegated to post- Incident Sys & Interfacing Support Sys

ML20006D120
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	01/29/1990
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-13, NUDOCS 9002120119
Download: ML20006D120 (13)

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-Nuclear Regulatory Commission Document Control Desk: - Washington, DC' 20555 =[ t

DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

RESPONSE TO GENERIC LETTER 89 SERVICE WATER SYSTEM PROBLEMS AFFECTING SAFETY-RELATED EQUIPMENT' q Generic Letter 89-13. " Service Water System Problems Affecting Safety-Related . Equipment", dated July 18, 1989, required licensees and. applicants to-supply information about their-respective service water systems to assure the NRC of compliance to the requirements of the General. Design Criteria in 10 CFR-Part 50 Appendix A;. ' Pursuant. to. the provisions of Section 182a of' the Atomic l Energy Actiof'1954, as amsnded, and 10 CFR 50.54(f), this letter constitutes ' Consumers Power Company's response-to Generic Letter'89-13 for the Big Rock l Point Plant. 1 Attachmentfl to this letter provides Consumers Power Company's response to 'l

esch of the recommended actions' to be taken in-the Generic Letter. As discussed in Attachment 1, significant differences exist in the Big Rock Point design which reduce the' role that the Service Water System performs in j

-accident mitigation. In view of this, most of the recommendations contained 'l -in the Generic Letter have been reviewed against the Fire Protection and Post Incident Systems which provide the accident mitigation and long term cooling -functionstat Big Rock Point. } 1 provides Consumers Power Company's schedule of plans for ' implementation of the various actions. Within 30 days of implementation of r -=900212011p 9oof29 {DR ADOCK 05000255' PDC Af Oh OC0190-0250-NLO4 A GHS ENERGYCOMPANY y

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rmW i N7 sa ?" CONSUMERS POWER COMPANY Big Rock Point Plant Docket 50-155 License DPR-6 Response to Generic Letter No 89-13 dated January 29, 1990 [ ' At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's ~ - Rules and Regulations thereunder, Consumers Power Company submits our_ response .to NRC letter dated July 18,.1989, entitled, " Service Water System Problems Affecting Safety-Related Equipment". Consumers Power Company's response is dated 4 - January-29,~ 1990. CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this I submittal are truthful and complete. By David P Hoffman, W resident Nuclear Operations Sworn and subscribed to before me this 29th day of January 1990. i: W / -t. Elaine E Buehrer, Notary Public Jackson County, Michigan My commission expires October 11, 1993 0C0190-0250-NLO4

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RESPONSE TO GENERIC LETTER 89 RECOMMENDED ACTIONS TO BE TAKEN 'As stated in the title, Generic Letter 89-13 is concerned with Service Water System (SWS) problems that affect Safety-related equipment. The Generic ~ Letter is interpreted as intending to insure components utilized to remove decay heat during post accident long term cooling events can perform their function. This interpretation was based on the premise that the safety-related function discussed in the Generic Letter dealt with long term heat removal capabilities rather than plant reliability. This response does'not consider " interim" system operation which precedes post-accident long term cooling as being applicable to the requirements of the Generic Letter. For the purposes of the response, Lake Michigan is considered to be the Ultimate -f Heat Sink (UHS) during emergency or accident conditions as compared to the i main condenser and the Shutdown Cooling System.(SCS) which are utilized for { routine shutdown or off-normal conditions. The plant SWS utilizes raw lake water to provide cooling to components and j systems and would be designated an open-cycle system per the Generic Letter. j Closer inspection of the SWS.will find that it delivers lake water to j individual component coolers. If this cooling water were restricted, or the coolers disabled in any manner, then that component.or system would be taken out of service in order to prevent equipment failure. Although component failure would ultimately affect full power operation and/or plant reliability. l it would not prevent the mitigation of an accident. The SWS also removes heat from the Reactor Cooling Water System (RCW), a closed-cycle system which l provides cooling for several components inside containment. Of all systems l and components that the RCW services, only the Reactor Recirculating Water j Pump seal coolers and the Shutdown Cooling System (SCS) could possibly fall within the Generic Letters selection criteria. Although the RCW provides cooling water to the reactor recirculating water pump seal coolers, l previous analysis has determined that their failure will not result in a LOCA, l and is.therefore not addressed in this response. With respect to the SCS, it j is a low pressure system utilized to remove decay heat in accordance with 1 approved cooldown limits during a controlled shutdown. No credit is taken for ~i the availability of this system during accident conditions as it_is not l environmentally qualified.. Plant Technical Specifications state that the SCS i' shall be ready for. service during power operations with the pump 480 volt breakers checked "open" when reactor pressure is above 300 psig due to piping a design considerations. Based upon the above discussion regarding system configuration operation and function, both the SUS and RCW systems are not 1 considered to be subject to the scope of the Generic Letter as they do not contribute or function in the capacity of post accident long term cooling. The responsibility for post accident long term cooling is primarily relegated to the Post Incident System (PIS) and interfacing support systems. The components of specific concern are the core spray heat exchanger in the PIS, I both Fire Protection System (FPS) pumps, and the Emergency Diesel Generator I (EDG) diesel cooling water sub-system. l -The FPS not only fulfills its fire protection function, but also provides water for actual core spray during the early stages of a LOCA prior to the need to service the core spray heat exchanger. Cooling water to the core spray heat exchanger is provided by two FPS pumps which draw their supply from the lake. One is a motor driven pump while the other is a diesel driven pump. l The diesel driven FPS pump and the remaining component, the EDG, both employ a ) treated water closed cooling low containing antifreeze which is in turn i cooled by raw lake water. The SWS and the FPS can be, but normally are not OC0190-0250-NLO4

{' y.f _ U' s b' 2 E utilized as back-up methods for cooling the EDG. These system configurations are considered open-cycle systems. The> remainder of this response will address the Generic Letter as it applies-to these components. The required " Recommended Actions To Be Taken by Addressees" of the Generic Letter will be discussed-sequentially. Each component will be discussed within the context of the separate recommended actions. 3 Recommended Action It Reducing the incidence of bio-fouling Bio-fouling considerations have been of minimal concern at Big' Rock Point in the past. Periodic chlorination of the intake bay has been effectively used I to prevent bio-fouling. With respect to the introduction of foreign bivalves i to the Great Lakes, Big Rock Point lake water temperatures do not reside in i the range preferred by these and other problem organisms for any great length of time. A review of 1989 lake temperatures obtained from the intake bay was performed and compared to the preferred environment of aquatic bivalves, ie, water greater than 54'F. The review indicated that lake temperatures were less than 54*F for 75% of 1989 and therefore not conducive to bivalve proliferation. This is primarily a result of Big Rock Point's intake crib being a deep water structure which draws its supply 1500' from shore and 30' j below the lake surface. Lake water drawn from this location will normally be much cooler than that drawn from the shallows or discharge canal. Although I the discharge canal temperatures are higher, the environmental conditions at the. intake bay are potentially a more significant operational concern. Recognizing that there is evidence of northward movement of undesirable aquatic bivalves in the great lakes, an effective method of detection is considered prudent. Test' samples of material suitable for mussel and clam-proliferation will be placed in the intake bay and/or discharge canal. These samples will be monitored for evidence of organism growth. Permits to apply biocide are available but normally take approximately one month to obtain from j the Michigan Department of Natural Resources (MDNR). However, this process can be expedited as the need arises. A generic permit has been discussed, but as yet has not been pursued since it is a site-specific approval process. The MDNR is very familiar with current bio-fouling problems and has been quick to j respond to infested facilities. Other indicators of bio-fouling are currently available. The overall performance-of the SWS can be utilized as a positive indicator of bio-fouling. q The result of any type of bio-fouling will show an immediate affect on j components serviced by this system. In addition, the condenser efficiency as i associated with routine plant operation will also be influenced by bio-fouling. Utilization of these indirect indicators is considered as effective as the previously discussed monitoring. Recommended Action II: Test Program The Generic Letter identifies the need to develop and implement two stages of u testing, initial and periodic re-test. The intent of the required testing is OC0190-0250-NLO4

5' t i ? .l l 3 O t to provide verification of heat transfer capability for the components in question. The scope'of this testing was defined in Enclosure 2 of the Generic Letter and further clarified at an information meeting conducted by the NRC on December 5, 1989.- The testing is to consist of monitoring cooling water h, parameters and the performance of functional testing. I Functional testing of.the core spray heat exchanger per the Generic Letter is not possible. The system configuration allows the core spray heat exchanger L loading only under actual accident conditions. Specifically, when a LOCA has occurred and the containment level has risen to a pre-determined level, the PIS~(in the recirculation mode) is needed to provide long term cooling. Primary system water is drawn from the lower elevations of the containment via the core spray pumps, passed through the core spray heat exchanger and then re-circulated through the core spray and containment spray systems. This flow path is repeated as long as needed with the FPS providing cooling water to the core spray heat exchanger. The outlet side of the heat exchanger discharges heated lake water to a drainage ditch that empties back to the lake. When not in an accident mode of operation, the core spray heat exchanger is not subject to any heat load. The only other occasion that this heat exchanger is used is during. periodic surveillance testing at which time a leak rate or flow rate measurement is performed. No additional testing is considered necessary for the core spray heat exchanger in light of the requirements of the Generic Letter. Conformance to the requirements of the Generic Letter via surveillance testing is discussed in later sections. The fire protection system utilizes two pumps to supply water for the various demands placed on the FPS. As stated previously, one is a diesel driven pump while the other is a motor driven pump. Each of these pumps are subject to testing criteria as dictated by the ASME pump program. In addition, the diesel fire pump which uses a treated-water closed cooling-system is subjected to a weekly test. The diesel fire pump incorporates a thermostatically controlled method of closed cooling similar to a car engine. The engine's closed cooling loop is serviced by a heat exchanger which is cooled by raw lake water supplied by the pump discharge. Acceptable engine coolant- . temperature indication is provided for the closed cooling loop via a temperature gauge. Temperature problems are alarmed on a local panel and in the-control room. This configuration and method of cooling does not lend r -itself to accurate measurement of heat rejection and is thereby considered . inappropriate and not applicable. However, existing surveillance testing of the diesel-fire pump will be reviewed and revised accordingly so as to allow -trending and monitoring of the closed loop heat exchanger performance. No additional testing is considered necessary for these-pumps in light of the requirements specified by the Generic Letter. The general condition of the system piping will be addressed by direct or indirect actions relating to Generic Letter compliance for other identified components. Functional testing of the treated water closed cooling loop on the EDG is also determined not applicable. The EDG closed cooling system incorporates a thermostatically controlled method of cooling similar to that described for L the diesel fire pump. The difference is that this method utilizes an l L OC0190-0250-NLO4 L

p p) 4 auxiliary pump driven by the diesel itself to provide for all lake water for closed loop cooling purposes. The EDG is equipped with a high temperature alarm. located on a nearby annunciator panel. An annunciator'in the control room actuates when the local panel detects an alarm or off-ncrmal indication. Acceptable' temperatures during diesel operation are indicateo. by means of a green / red temperature gauge installed in the closed cooling loop. This configuration and method of cooling is also determined not to lend itself to accurate measurement of heat rejection and thereby considered inappropriate and not applicable. Although exception to the functional testing requirements of the Generic Letter have been made, we believe there are other available methods which will provide the level of assurance desired. There are existing surveillance procedures that monitor cooling water related parameters and verify proper operation. Data recorded by these surveillance tests accommodate the trending of critical parameters. Subsequently, as a result of system configurations which do not support practical functional testing, information derived from existing surveillance testing will be trended and monitored to constitute . compliance with the requirements of the Generic Letter for continuing and periodic testing, q Recommended Action III: Routine inspection and maintenance .The Generic Letter specifies that a routine inspection and maintenance program be' established'for open-cycle service water systems to ensure that corrosion. erosion protective coating failure, silting, and bio-fnuling does not degrade safety-related' system performance. l The core spray heat exchanger will be inspected during the.next refueling outage. The. inspection will include a visual inspection-of both tube and shell side for evidence of any type of fouling. If determined necessary, non-destructive testing of the heat exchanger tubes will also be performed in order tx) insure their integrity. Corrective action such as repairs and/or the removal of corrosion or fouling products will be performed as needed. Routine periodic inspection or maintenance of the core spray heat exchanger is not . anticipated until such a time that surveillance testing indictates the presence or probability of bio-fouling. Existing surveillance testing procedures will be evaluated and revised to incorporate trending of available l and appropriate parameters indicative of component cooling performance. j Inspection of the fire pumps is scheduled to occur during the next two i refueling outages..The diesel fire pump will be inspected during the 1990 i fueling outage with the motor driven fire pump being inspected during the following refueling outage. Commitments to inspect these pumps were previously made as part of the resolution to NRC Bulletin 88-04, Potential Safety-Related Pump Loss. Inspection of the motor driven pump is not anticipated to occur this upcoming refueling outage unless the material condition of the diesel driven fire pump dictates that an inspection is prudent. The diesel engine is subjected to inspection and maintenance each refueling. Both pumps are tested annually to ASME pump program criteria. Corrective maintenance is performed as needed. No additional periodic OC0190-0250-NLO4

L r i s 5 maintenance or inspection is determined necessary unless degraded component performance is observed during surveillance testing or as a result of changing environmental conditions. inspection of the FPS piping is not being considered.- The fire system hydrant header.is routinely flushed with no observations to date of any evidence of bio-fouling. This is supported by the results of an internal inspection performed in late 1987 on a section of main fire loop as part of a modification to site facilities. No corrosion products of any type were observed in the pipe interior at that time. It is assumed that these facts as well as the results obtained by the refueling outage inspections of the various pumps and components affected by the Generic Letter will be indicative of FPS piping material condition. Routine periodic maintenance or inspection beyond that which already exist is not planned unless existing surveillance test results or changing environmental conditions dictate additional actions. In an attempt to avoid the introduction of aquatic hivalves into the FPS, operating practices and surveillance test which utilize the FPS will be reviewed and revised accordingly to incorporate an action or response level. Performance related data recorded by existing surveillance procedures will be trended. . Routine inspection of the EDG is satisfied.by existing surveillance testing. EDG operability testing is performed weekly whereas preventative maintenance is performed ~each refueling. The weekly operability testing observes and records cooling water pump suction pressure (from the lake) and compares it to established acceptance criteria. The performance of the water pump supplying lake. water to the closed cooling water heat exchanger is evaluated each ' refueling. These parameters will be trended in compliance with the Generic Letter. Additionally, these surveillance tests will be reviewed and revised to establish pre-test inspections which will reduce the potential of bio-fouling during component operation and/or maintenance. Recommended Action IV: Licensing basis conformance The Generic Letter states that a system review should be made to ensure and/or confirm its ability to perform required safety functions when subjected to a single failure event. The Generic Letter goes on to say that a system walkdown inspection be performed in support of this requirement. An operational readiness assessment of the P1S and FPS was performed in 1986. The core spray system in the recirculation mode was evaluated as part of this endeavor. One of the objectives of the evaluation was to compare system design against system functional requirements. The conclusions and recommendations resulting from the evaluation were submitted to the plant and incorporated as appropriate. However, system configuration of the components affected by the Geneic Letter will be re-verified during the next refueling outage. A field walkdown will be performed to corroborate the present system design. Any deviation or non-conservatism suspected to affect component cooling or performance capabilities will be evaluated. No significant discrepancies, if any, in configuration are OC0190-0250-NLO4

0l=h! ~) E '. !!i" *l 1 6~ M -p i expected to be identified as BRP has not been subjected to numerous modifications. The FPS and PIS systems at BRP do not meet the single-failure criteria as specified in Appendix K. Discussion of this issue can be found in NRC E, Memorandum and Order dated Nay 26, 1976 fu which a lifetime exemption to certain' aspects of the single-failure criteria was granted. 4 Recommended Action V: ' Procedures and training . The above discussions identify various activities to be performed in the interest of verifying and insuring the continued ability of the core spray heat exchanger, fire pumps and EDG to fulfill their safety functions. A number of procedures will need review.and revision as a result of these commitments and activities. Surveillance tests which introduce raw lake water to the systems and components'affected by the Generic Letter will be appropriately revised to include inspection of suction and discharge lines, stand-pipe, and sample blocks in the screen house intake otructure and the discharge canal for evidence of bio-fouling. Operating procedures will be revised appropriately, or some other equally effective method of communication will be employed to alert operations personnel to the threat and consequences of bio-fouling. If necessary, emergency procedures will be revised to insure the availability and ability of the affected components to perform their safety function.. Maintenance procedures which deal with the components affected by the Generic Letter will be appropriately revised to insure that corrosion and bio-fouling. considerations are included during routine maintenance inspection and activities on those systems. Appropriate chemistry practices and/or training will be implemented which will enhance that departments awareness and response to the potential and consequences of bio-fouling. Data collection and trending of performance indicators collected from affected surveillance tests will be implemented. Action levels will.be established which require or initiate investigative or corrective actions. A copy of the Generic Letter and this response will be forwarded to the training department for review and discussion during operator training as appropriate.- The above discussed revisions to operating procedures need not be forwarded to the training department as they are programmatically incorporated into operator training. The plant technical specifications need not be revised as Limiting Conditions b for.0peration (LCO) already exist for the Fire Protection and Post Incident L systems and the EDG. Conclusion It is recognized that the concerns expressed in the Generic Letter are significant and relevant. Despite differences between Big Rock Point and l modern BWR system design basis and configurations, all background events described in the Generic Letter have the potential to occur at Big Rock Point. We have addressed the concerns of the Generic Letter as they apply to Big Rock Point. It is believed that the elements outlined above satisfy the Generic Letter and will provide both short and long term assurance that critical C OC0190-0250-NLO4 1

w, ,4 S : '.' t F 7 p [ cdaponents will' fulfill their intended safety related post accident heat . removal' functions. There is confidence that these actions will afford this r[ assurance despite.the inability to perform functional testing per the Generic i Letter.. Plant reliability and availability will also benefit as-a result of our heightened awareness of the Generic Letter concerns and efforts to prevent their occurrence.< The' component' inspections, practices, and procedure-revisions-identified within'this response will be completed prior to start-up p ~from the next refueling outage. i. i i -1 I \\ ^ l I OC0190-0250-NLO4 i -) a

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NN lsj.s a ; *f. t: 1 SCHEDULE OF PLANS FOR IMPLEMENTATION OF GENERIC LETTER 89-13 ACTION 3 The actfons listed below will be completed prior to start-up from the 1990 refueling outage. 1. Test samples of material suitable for mussel and clam proliferation will be placed in the intake bay and the discharge canal and monitored for organism growth. 2. Perform an inspection of the core spray heat exchanger during the 1990 refueling outage. 3. If determined necessary, perform non-destructive testing of core spray heat exchanger tubes during the 1990 refueling outage. 4. Following inspection, perform repairs and/or removal of corrosion or fouling products from the core spray. heat exchanger as needed. f 5. Evaluate and revise existing surveillance testing procedures, for components affected by the Generic Letter, to incorporate trending of parameters indicative of component cooling performsnce. 6. Review and revise PIS, FPS, and EDG surveillance tests, to establish pre-teet inspections and action or response levels, which will reduce the. potential for bio-fouling. 7.- Verify system configuration by performing a field walkdown of the systems 1 and. components affected by the Generic Letter to corroborate the present system design considerations. 8. Evaluate any deviation or non-conservatism discovered during the field j walkdown which may affect system cooling or performance. 9. Revise Operating Procedures or employ an equally effective method of 3 communication to alert operations personnel to the threat and consequences j of' bio-fouling. ,l 10. Revise affected maintenance procedures to insure that corrosion and bio-fouling considerations are included during routine maintenance Linspections and activities for those systems and components subject to the Generic Letter. 11. Chemiutry practices and/or training will be implemented to enhance awareness of the potential for and consequences of bio-fouling. 12.. A copy of Generic Letter 89-13 and Consumers Power Company's response will be forwarded to the training department for review and discussion during operator training as appropriate. OC0190-0250-NLO4}}