ML20095J183

Proposed Tech Spec 3.7.5.b Re Standby Nuclear Svc Water Pond

ML20095J183
Person / Time
Site:	Catawba
Issue date:	04/22/1992
From:	DUKE POWER CO.
To:
Shared Package
ML20095J179	List: ML20095J175 ML20095J183
References
NUDOCS 9205010154
Download: ML20095J183 (10)

Text

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e PLANT SYSTEMS 3/4.7.5 STAND 8Y NUCLEAR SERVICE WATER POND LJMITINGCON0!TIONFORO'8ERATION 3.7.5 The standby nuclear service water pond (SNSWP) shall be OPERABLE with:

i a. A minimum water level at or above elevation 570 feet Mean Sea Level, USGS datum, and -

b. An average water temperature of less tha5 nr equal to 00.S"T at elevation 5M feet in the SNSWP.4nte: 4tet tues,-

APPLICABILITY: MODES 1, 2, 3, and 4.

g"g: (Unter 1 and 2)

Wit:1 the requirements of the above specification not satisfied, be in at least t HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. 1 SURVEILLANCE REQUIREMENTS , 4.7.5 The SNSWP shall be determined OPERABLE:

a. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifyin0 the water level to be within its limit,

b. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during the months of July, August, and September by verifying the water temperature to be within its limit,

c. #t least once per 12 months by visually inspecting the SNSWP dam and verifying no abnormal degradation, erosion, or excessive seepage, and

d. At least once per. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during the months of July, August and September while the Nuclear Service Water System is aligned to <.ske Wylie by recording the water temperature of Lake Wylie, as measuccd in the discharge path of an operating Nuclest Service Water pump.

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' CATAWBA 92050;0154 920422

' UNITS 1 & 2 3/4 7-13 h.it=t k.M Didt4)-

PDR ADOCK 05000413 fr:Mt M. 'd (Ud@

P PDR

PLANT SYSTEMS

'8ASES _

3/4.7.5 STAND 8Y NUCLEAR SERVICE WATER POND I

The limitations on the standby nuclear service water pond (SNSWP) level and temperature enscrc that sufficient cooling capacity is available to either:

(1) provide normai cooldown of the facility, or (2) mitigate the effects of accident conditions within acceptable limits.

The limitations on minimum water level and maximum terperature are based on paoviding a 30-day cooling water supply to safety-related equipment without exceeding its design bcsis temperature and is consistent with the recommend-ations of Regulatory Guide 1.27, " Ultimate heat Sink for Nuclear Plants,"

March 1974.

The peak containment pressure analysis assumes that the Nuclear Service l

Ade) Water (RN) flow to the Containment Spray and Component Cooling heat exchangers Mc M has a temoarature ofd6r58F- Tht temperature is important in that it, in part, determines the" capacity for energy removal from containment. The peak containment pressure occurs when energy addition to containment (core decay he d) is balanced by energy removal from these heat exchangers. This balance is reached far out in time, after the transition from injection to cold leg recirculation and after ice melt. Because of the effectiveness of the ice bed l in condensing the steam which passes through it, containment ptssure is insensitive to small variations in contains geay 7 temperatureJrior

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to,1cems meltout. Add \ xser+Q n . +he peak con % ent pressuN

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% temperature To ensu the R se b dure assump tored.

fi g netT wake eDM During periods of time while Lake Wylie temperature p g )_ is grea_ter th F, the emergoney procedure for transfer of ECCS flow l V paths to cold leg recirculation directs the operator to align at least one l train of containment spray to be cooled by a loop of Nuclear Service Water l which is aligned to the SNSWP. Ac/cl / n s e ,--f- 3 3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM The OPERABILITY of the Control Room Area Ventilation System ensures that:

(1) the ambient air temperature does not exceed the allowable temperature for continuous-duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel during and following all credible accident conditions. Operation of the system with the heatcrs operating to maintain low humidity using automatic control for at least 10 continuous hours in a 31-day period is sufficient to reduce the builoup of moisture on the adsorbers and HEPA filters. The Control Room Area Ventilation System filter units have no bypass line. Either Control Room Area Ventilation System train must operate in the filtered mode continuously. When a train is in operation, its associated heater also runs continuously. The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rems or less whole body, or its equivalent. This limitation is con-sistent with the requirements of Ganeral Design Criterion 19 of Appendix A, 10 CFR Part 50. ANSI N510-1980 will be used as a procedural guide for surveil-lance testing.

CATAWBA - UNITS 1 & 2 8 3/4 7-3a -Amendment-No. 73 (Unit IF

? = h t No. 72 (Unit 2 F

Insert 1 92*F. To ensure that this condition is not exceeded, and to ensure that long term RN temperature does not exceed the 100*F design basis of RN components (including a 2.4*F margin de. scribed in Section 2.4.4.2 of the Catawba SER, Supplen ents 1 and 2) a TS limit of 91l*F is conservatively observed for the SNSWP.

Insert 2 Long term equipment qualif. cation of safety related components required to mitigate the accident is based on a continuous, maximum RN supply temperature of 100*F.

Insert 3 Swapover to the SNSWP is required at 92'F rather than 91.5'F because lake Wylie is not subject to subsequent heatup due to recirculation, as is the SNSWP; hence the 100'F design basis maximum temperature is not approached.

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w warr,s--- w-- o- m -

f Attschment II 4

Proposed Tedtrdeal Speci0 cation Revisim This proposed Technical Specification (TS) revision changes TS 3.7.5.b to read "An average water temperature of less than or equal to 9L01F 91.5'F at an elevation of-563 568 feet in the S'andby Nuclear Service Water Pond (SNSWP)." In' this Technical Specification,1 Bases and supporting]Ustification, the~apparentLdiscrepancy between;the initial temperature.of 92'F in the peak accident pressure analysis and the 91.5'F-limit proposed for maximum SNSWP temperature is a result of an adjustment that has been made to ecount for historical! differences between the Duke and:NRC SNSWP models~ as discussed in the; Catawba 1SER supplements 1 and 2 S.ection 2.4.4.2. The TS Bases are revised to re0cct this change.

Discussion Duke Power has determined that TS 3.7.5 is non-conservative in ensuring that the Standby Nuclear Service Water Pond (SNSWP) can meet its Design Basis safety function, which is to provide an adequate source of cooling water to dissipate waste heat rejected during a unit LOCA plus a unit cooldown.

In the event of a seismic event which caused the loss of Lake Wylie, the SNSWP would be the ultimate heat sink for the station. The existing TS requires that the SNSWP temperamre be monitored at the bottom of SNSWP at the center line elevation of the Nuclear Service Water System (RN) SNSWP intake pipe (540 feet). Because this monitoring point is at the bottom of the SNSWP there is the opportunity for warmer water, which is less dense, to exist above the monitoring point. The assumed initial Nuclear Service Watefl(RN)lSystein temperature in the FSAR pbsk"contahmesi pressure analysis GNSWP is S6.53*F (FSAR-Figwe 0.2.5 3) is 92'F (FSAR Section _6.2il.li3).hTo essurs that'long'tsrm RNihmperature'doesi3t"ensed the 100*Filesign basis o.f_RN' components (including a 2.4*F margin described in Section 2.4.4.2 of the Catawba SERLSupplements 1 and 2), a TS 1imi.t of 91.5*F_is conservatively; observed for;the SNSWP) Since the entire pond is assumed to be at the same initial tempen.ture, with no stratification, it is not conservative to do the surveillance for maximum allowed SNSWP temperature at the intake level. At the present time Duke Power is observing the existing Technical Specification requirements. Additionally, manual temperature readings are being taken at a higher elevation to ensure continued operability of the SNSWP until the proposed Technical Specification changes are approved.

Analysis of the 9FF 91;5fF initial SNSWP temperature involved updating the computer analysis of the SNSWP (FSAR Figure 9-55). The updated analysis assumes an initial mixed pond temperature of 9FF 91.5*F instead of the previously assumed temperature of 86.53

• F. Although temperatures pensss]f 86.53*F has Isiye never been exeeeded ineasured in the SNSWP, this assumption is based solely on meteorological heat input to the SNSWP, and does not necessarily allow for heat loading which could result from 1

- extreme meteorology combined with plant operations. Results of the analysis indicate that monitoring for a maximum temprature of 922F 91.5'F at elevation %3 568 feet hican Sea Level (MSL) in the SNSWP will provide the volume of cooling water at or below 9NF 91;5"P which will allow the design basis of the SNFWP to be met (FSAR Section 9.2.5.1).

568 feet is' considered to be the highest elevation at which an averaEe p6nd temperature 6an be attained ~without substantial surface heating and cooling effects d6e to daily variation in air temperature, rainfall, and solar heat input. Thus'it is considered to be a fsurfacci temperature monitoring point' .

Ipchnical Justification An extensive design analysis was completed in order to qualify the SNSWP temperature analysis for a-more-conservative the new initial temperature and evaluate its impact on station structures, systems, and equipment.

The first step in the analysis was to evaluate the physical characteristics of the SNSWP.

An Area / Volume survey of the SNSWP was completed, which determined that existing FSAR data and SNSWP n.odel inputs remain valid. Several temperature surveys of the SNSWP were performed during throughos'til989(and;1990[ incl 6dingTniorelfrequent monitoring during the summer months. These temperature surveys characterize SNSWP temperature during the time of year most likely to challenge TS temperature restrictions.

92 F was chosen as a maximum SNSWP temperature, this temperature was considered conservative both from the standpoint of p: ant operation and meteorological conditions.

RessitingiWestingli6u'se" peak ~contaitiniciitjressureEirialisisMaFsuccessfel af anlinitial SNSWPitemperaturefof.92?F, as ' described below,fand;the heat inpststosthe SNFWP analytical modelL resbited(in"aipdakiSNSWPfintake;tempeiaturefof lessithahs1(XPF.

However, Lthis peak temperature;didinot; allow Jforithe1NR_Cf pond analyticul model discrepancy;of 2.4*F as doc 6mented in the Catawba SER?Further discussions have bsen held with the NRC, andiseveral model revisions' wRe~made'"to remoye conservative heat input assnmptions in an~ unsuccessful attempt ta de_monstratithatLs 2.4*F margin l exists between the predicted SNSWP' peak temperature and the100*F desigr(basis lof;the safetp related components.fTherefore it hs been decidedjtoiconservatively limit the.SNSWP ,

initial temperature to 9.1.5*F rather than)92*F/ LThii resukintaipredisted" peak}ntike temperaturd of 97.57F thus preserving t!)e,2.49F,marginj Since the current FSAR analysis assumes that the entire SNSWP is at the same temperature, to remain consistent witn existing FSAR analysis, no credit is taken for stratification.

Westinghouse was contracted to perform a containment analysis using an initial SNSWP temperature of 92*F. Two inputs were changed in the Westinghouse analysis. The initial temperature of the SNSWP was changed from 86.5'F to 92*F, and the assumed temperature of the Refueling Water Storage Tank was changed from 120*F to 105*F. The use of the 105*F temperature for the Refueling Water Storage Tank is based on TS required temperatures of:

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1) a minimum of 70*F and a maximum of 100*F in modes I through 4, and

2) a minimum of 70'F in modes 5 and 6.

The resulting peak analyzed pressure is 14.05 psig. Since 14.05 psig is below the 14.7 psig assumed containment peak design pressure, the results were acceptable.

The maximum time necessary from start of the LOCA until containment peak pressure is reached and pressure reduction is underway is conservatively 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The assumed water temperature during the first 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is 92*F. The volume of water needed to supply the RN system for 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> is available below the 563 557 feet elevation. This volume of water was determined using RN System demand for 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with all four RN pumps and all four trains of essential components running for the first 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 2 trains thereafter. r ming-FSAR Section 9.2.5-methodology-ThiaswmptioFHnakeS4he+eieetion of the 563 feet dermuion-for-GNSWP-operability-tnere-conservative 4ht.n-in-whieh-it-is petulated4haHwe4 mins of cmergeney-dicscl j;cnerators-and-assoeinted-tmin-componen*s

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are-shut-off-after-four-hours: This is corisistent with:the meth'odologp iri Section 9.15 of ths FSAR whichTassumssTthit two trains of emergeheyidieselfgenerators andLassociated train components ary shut.down;after four. hours!

Assuming ~aii initial,^unitratifiedfteinperature 6f 91.5'F, following the initial turnover of the SNSWP volume through the RN System, the predicted peak SNSWP temperature is equal to 40FF 97.5'F. All safety related components and assured makeup demands were previously designed for a~inaximum of 100*F. Thus,lthe 2.'4*F margin between ths Duke analvticalLm6 del and. the independs6tjoridTanalysis(performed /by;thejNRCs isfstill preserved.

The analysis which identifies 9FF 925*F at elevation 663 568 as a criterion for judging acceptable SNSWP cooling function is conservative in several ways. First, the SNSWP ,

would be stratified under warm-weather conditions associated with worst-case metconology, ,

unless unusual pumping operations had resulted in mixing of the pond. Therefore, water i below elevation 563 56,8 would be at a temperature lower than the assumed 9FF 915'F

! due to density stability associated with thermal stratification. Second, the 9FF 91l.5'P assumed temperature significantly exceeds the maximum expected equilibritan temperature which would result from extreme meteorology. Thiid, the highest measured water temperatures experienced in the Catawba SNSWP under warm weather conditions gave a surface temperaturc of approximately BFF-M 1986 85*Flin?Jsnel1990. Under these l conditions, the pond was stratified, 'witRistiiperifdRof 84'u taelevation 168Jeet, and I

water temperature declining to a low of 742F (I*E at the pad bottom. Therefore, the heat content was much lower than that corresponding to assumed isothermal conditions at either 86.53*F or 9FF 9115'F. Fourth, the total V61striefof'siit0Fbe16wlfthF568'fsel elevation"cdiirespondsltoltQRN?Sfsteni[derdshdffor(124holirs tmderiaccidsrit!flo@ 4 conditions asEdesciibed in:FSAR Sectioh 9.2.5PandTsummariied5bbse?plus(sufficient

'margir(to allop for possible entrainmeni of water lfr6mjbovelth@intalie strudture.lln i 1

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addition, it 'will allow for daily' fluctuation in the top 2 to 3 feet above 568 feet elevation without adversely affecting peak containment pressure: analysis or long term equipmenj _

qualification.volumeef-water-wbich-would-bedreulatt+through-the RN Systenamder-the maximumfkw-assumptiernleseribed-above-iweeountedfor-below4he4@ fee c!cvatiern

%Hedditional--three-fect of water-also-fequired-to-te at 92'F, allows-for-powible entrainment-cf water-from-above-the-RN-intake.

New Test Acceptance Criteria fe the major RN System heat exchangers have been issued to ensure that heat exchanger cleanliness is maintained adequately for LOCA heat rejection at the rates calculated in the corresponding Westinghouse containment peak pressure analysis. Appropriate margin is maintained to account for fouling between performance tests and/or cleaning.

Equipment Qualification analyses for long-term containment temperature have been revised conservatively to account for 92'F initial SNSWP temperature followed by 100'F RN cooling water temperature. The results have bcen evaluated and found to be acceptable.

Based on the results of the Design analysis described above the requirements for operability of the SNSWP are as follows:

1) Water at elevation M3 5.68 feet and below must be at a temperature less than or equal to 92'-F 9.1;5.*f!.

2) Maximum water temperature for the SNSWP must remain below 100'F Including st least the 2.4Tmargin described in Sectiori2;4.'4:2 of the;Catsvbs SER/ Supplements 1andf1 3); LNormat RN intaksieniperatiire fmm LakeLWylie is monitored." During peri 6ds'of time when l_akeLWylie temperature isLgreater t.han 92*Fi .th& emergency procedure for ECCS flow pr.ths to'coM leg recirculation requires thatlthe operator align at least 'one train of contain,mentjpray;to be cooled byLa'trainsof.;RN whichLisfa!ign&to;the SNSWP,;

The analysis described above demonstrates continued operability of the SNSWP as long as these operability requirements are met.

BLSignificant Harards Analysis 10 CFR 50.92 states that a proposed amendment involves no significant hazards consideration if operation in accordance with the proposed amendment would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or 4

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2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3) Involve a significant reduction in the margin of safety.

This proposed TS amendment will not have a significant increase in the probability or consequences of an recident previously evaluated. The probability of an accident will not be increased because the SNSWP does not play a role in the initiation of any accident sequence. There will not be an increase in the consequences of an accident because monitoring the SNSWP temperature at the %3 568 feet elevation will cnsure that a sufficient volume of water is maintained at or below tlm required temperature to meet the design bases of the SNSWP.

The volume of water below the M3 568 clevation corresponds to the RN System demand for 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> using, 'ssuming a all four RN pumps, all four trains of essential components, plus sufficient water at or below 9FF 91'.5T to allow for possible hydraulic entrainment of water elevations above the RN intake. At 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> containment peak pressure will have been reached and pressure reduction will be under way. Since temperature stratification will occur, and temperatures at lower depths will be lower, monitoring the temperature et this point is conservative compared to the existing monitoring point at the SNSWP intake, which monito" cool water at the bottom of the SNSWP with the possibility of warmer water existing above. Changing the initial temperature of the SNSWP Nuclear

$6rsice ,Waterf(RNTsopply to 92*F has bec.: determined to have acceptable results. The Containment peak pressure anrlysis was performed by Westinghouse, and the resulting peak analyzed pressure was 14.05 psig, which is below the 14.7 psig assumed containment peak design pressure. All equipment has been verified to be able to function assuming the higher SNSWP initial temperatures, and essential heat exchanger cleanliacss factors have been revised to account for higher initial SNSWP temperatures.

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This proposed TS amendment will not create the possibility of a new or different kind of accident from any pr.:viously evaluated. The needed analysis has been completed to ensure that the design bases of the SNSWP can still be met with SNSWP temperature at 9FF 91.5'F monitored at the %3 568 feet elevation. All essential equipment will function as needed assuming a higher initial water temperature. The test acceptance criteria for major RN heat exchangers have been revised to ensure adequate LOCA heat rejection at the rates calculated in corresponding Westinghouse containment peak pressure analysis.

Since all initial design inputs have been verified to be correct, and all other requirements relative to the SNSWP remain the same, this proposwi amendment will not create the possibility of a new or different accident from any previausly evaluated. In"6fddfis fsilh6r reduc 6 heat iripstit'6 lthe SNSWIVtliffuer pooly6olidg'heatinhasidis onlthe non;LOCA unit 1will-now be isoluteeIniddition tolthel previous automaticiisolati6nTofJFuel Pool Cooling tto Lthe L LOCA(Unite iSince: thelFuel! Handling? Building [includ_ingi thelpooll structure [11ner platcLand HVAC hnqbeenl designed forlheatup:and7 subsequent boiling conditions,Lthis does;not.representithelpossibilitypf'ainew;or differest accidentfr;om any previously evaluated) 5

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• e This proposed TS amendment will not involve a significant reduction in the margin of safety. Measuring SNSWP temperature at 663 568 feet is more conservative than measuring the temperature at the SNSWP intake structure. Measuring SNSWP temperature at the intake struture allows warmer, less dense water to exist at higher elevations.

Taking the temperature measurement at 663 568 feet ensures that a sufficient volume of water is at 922F 91.5'F to supply the RN system demand for 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> during a design bases accident includ_ing~signifidant"mstginlforpdssiblientraliinsnf ofMater elevalions hbove the.RN intake; This is the maximum time necessary from the start of a LOCA until containment peak pressure is reached and pressure reduction is under way. Since siithinatic swapoveif to the SNSWPfis;! anger o6ciirs"oii'SWthE teinperatiirsbf IMe Wylie supply water w:ill be measured at the RN Pumplischarge to ensure proceduralisteps are followed l for temperatures inl excess;of 92*F. Performance of appropriate system equipment has been analyzed for an initial temperature of 92*F. Peak SNSWP temperature never exceeds 100*F (yfiidinglaihihigiii"oflstilessi'2f4?F), which is the temperature that all safety related components and assured makeups were designed for. Equipment qualification and long term containment temperature have been revised to account for 92*F initial SNSWP -

temperature followed by 100*F RN cooling water temperature. The results have been evaluated and found to be acceptable. For these reasons this proposed TS amendment will  ;

not involve a significant reduction in the margin of mfety. 1 Environmental Impact Statement The proposed TS change has been reviewed against the criteria of 10 CFR 51.22(c)(9) for environmental considerations. As shown above, the proposed change does not involve any significant hazards consideration, nor increase the types or amounts of effluents that may be released offsite, nor increase the individual or cumulative occupational radiation exposure. Based on this, the proposed Technical Specification change meets the criteria given in 10CFR 51.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.

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O This proposed TS amendment will not involve a sigmficant reduction in the margin of safety. Measuring SNSWP temperature at 663 568 feet is more conservative t:mn ,

measuring the temperature at the SNSWP intake structure. Measuring SNSWP temperature I at the intake stmeture allows warmer, less dense water to exist at higher elevations.

Taking the temperature measurement at 563 568 feet ensures that a sufficient volume of water is at 9FF 913*F to supply the RN system demand for 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> during a design bases accident including significant maigin forlpossibis entrainment 0fjater cleyalions above the RN intake. This is the maximum time necessary from the start of a LOCA until ,

containment peak pressure is reached and pressure reduction is under way. Sidee hutomatid l iwapover to'thelSNSWPfno~1o'nger"occurirorfSpfthe temperaturefof 4 1 ks:Wylie supply water will be measured at th'e RN Pump dischstgelto ensure procedura1 steps are followed for.' temperatures in. exc9ss of 92*F. Performance of appropriate system equipment has been analyzed for an initial temperature of 92'F. Peak SNSWP temperature never exceeds 100'F (including amarhin of at11 east 2A'F), which is the temperature that all safety related components and assured makeups were designed for. Equipment qualification and long term containment temperature have been revised to account for 92'F initial SNSWP temperature foll owed by 100'F RN cooling water temperatare. The results have been evaluated and found to be acceptable. For these teasons this proposed TS amendment will not involve a significant reduction in the margin of safety.

Environmental ImplcLStatemeDi The proposed TS change has been reviewed against the criteria of 10 CFR 51.22(c)(9) for environmental considerrions. As shown above, the proposed change does not involve any significant hazards consWeration, nor increase the types or amounts of effluer.ts that may be releascJ offsite, nor increase the individual or cumulative occupational radiation exposure. Based on this, the proposed Technical Specification change meets the criteria given in 10CFR 51.22(c)(9) for categorical exclusion from the requirement for an Environmental Impact Statement.

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