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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M2871999-10-21021 October 1999 Refers to Rev 5 Submitted in May 1999 for Portions of Byron Nuclear Power Station Generating Stations Emergency Plan Site Annex.Informs That NRC Approval Not Required Based on Determination That Plan Effectiveness Not Decreased ML20217P6171999-10-21021 October 1999 Forwards non-proprietary & Proprietary Versions of HI-982083, Licensing Rept for Byron & Braidwood Nuclear Stations. Proprietary Rept Withheld,Per 10CFR2.790(b)(4) ML20217M4361999-10-19019 October 1999 Forwards Rev 46 to Braidwood Station Security Plan, IAW 10CFR50.4(b)(4).Description of Changes,Listed.Encl Withheld Per 10CFR73.21 ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217G9791999-10-14014 October 1999 Forwards SE Accepting Relief Requests to Rev 5 of First 10-year Interval Inservice Insp Program for Plant,Units 1 & 2 ML20217F7891999-10-0808 October 1999 Forwards Insp Repts 50-454/99-12 & 50-455/99-12 on 990803- 0916.One Violation Occurred Being Treated as NCV ML20217B6351999-10-0505 October 1999 Forwards for Info,Final Accident Sequence Precursor Analysis of Operational Event at Byron Station,Unit 1,reported in LER 454/98-018 & NRC Responses to Util Specific Comments Provided in ML20212L1791999-10-0505 October 1999 Informs That as Result of Staff Review of Util Responses to GL 92-01,rev 1,suppl 1 & Suppl 1 Rai,Staff Revised Info in Rvid & Is Releasing Rvid Version 2 ML20217B2991999-10-0101 October 1999 Forwards Insp Repts 50-454/99-16 & 50-455/99-16 on 990907-10.No Violations Noted.Water Chemisty Program Was Well Implemented,Resulted in Effective Control of Plant Water Chemistry ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20212J6751999-09-30030 September 1999 Forwards Replacement Pages Eight Through Eleven of Insp Repts 50-454/99-15 & 50-455/99-15.Several Inaccuracies with Docket Numbers & Tracking Numbers Occurred in Repts ML20217A5821999-09-29029 September 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities ML20217A9311999-09-29029 September 1999 Informs That NRC 6-month Review of Braidwood Identified That Performance in Maint Area Warranted Increased NRC Attention. Addl Insps Beyond Core Insp Program Will Be Conducted Over Next 6 Months to Better Understand Causes of Problem ML20216H4301999-09-23023 September 1999 Informs That Arrangements Made for Administration of Licensing re-take Exams at Braidwood Generating Station for Week of 991108 ML20216F7441999-09-17017 September 1999 Forwards Insp Repts 50-456/99-13 & 50-457/99-13 on 990706-0824.Three Violations Noted & Being Treated as Ncvs. Insp Focused on C/As & Activities Addressing Technical Concerns Identified During Design Insp Completed on 980424 ML20216F8051999-09-17017 September 1999 Forwards Insp Rept 50-454/99-14 & 50-455/99-14 on 990823-27. Security Program Was Effectively Implemented in Areas Inspected.No Violations Were Identified ML20212A6991999-09-10010 September 1999 Forwards SE Accepting Licensee Second 10-year Interval ISI Program Request for Relief 12R-07 for Plant,Units 1 & 2 ML20211Q9011999-09-0808 September 1999 Advises That Us Postal Service Mailing Address Has Changed for Braidwood Station.New Address Listed ML20211P1841999-09-0808 September 1999 Forwards Insp Repts 50-454/99-15 & 50-455/99-15 on 990824- 26.No Violations Noted.Objective of Insp to Determine Whether Byron Nuclear Generating Station Emergency Plan Adequate & If Emergency Plan Properly Implemented ML20211Q6821999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Byron Operator Licesne Applicants During Wks of 000619 & 26.Validation of Exam Will Occur at Station During Wk of 000529 ML20211Q6611999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Braidwood Operator License Applicants During Wk of 010115 & 22.Validation of Exam Will Occur at Station During Wk of 001218 ML20211P1901999-09-0303 September 1999 Forwards Insp Repts 50-456/99-12 & 50-457/99-12 on 990707-0816.No Violations Noted.Insp Generally Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Careful Radiological Work Controls ML20211N5151999-09-0303 September 1999 Ack Receipt of Re Safety Culture & Overtime Practices at Byron Nuclear Power Station.Copy of Recent Ltr from NRC to Commonwealth Edison Re Overtime Practices & Safety Culture Being Provided ML20211M1371999-09-0202 September 1999 Discusses 990527 Meeting with Ceco & Byron Station Mgt Re Overtime Practices & Conduciveness of Work Environ to Raising Safety Concerns at Byron Station.Insp Rept Assigned for NRC Tracking Purposes.No Insp Rept Encl ML20211K1081999-09-0202 September 1999 Responds to Request for Addl Info to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity, for Braidwood,Units 1 & 2 & Byron,Unit 2 ML20211P1761999-09-0202 September 1999 Discusses Licensee Aug 1998 Rev 3K to Portions of Braidwood Nuclear Power Station Generating Stations Emergency Plan Site Annex Submitted Under Provisions of 10CFR50.54(q). NRC Approval Not Required ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211G4021999-08-25025 August 1999 Forwards Insp Repts 50-454/99-10 & 50-455/99-10 on 990622-0802.No Violations Noted ML20211B8691999-08-20020 August 1999 Forwards Insp Repts 50-254/99-10,50-265/99-10,50-454/99-09, 50-455/99-09,50-456/99-10 & 50-457/99-10 on 990628-0721. Action Plans Developed to Address Configuration Control Weaknesses Not Totally Effective as Listed BW990053, Forwards post-outage Summary Rept for ISI Examinations Conducted During Seventh Refueling Outage of Braidwood Station,Unit 21999-08-13013 August 1999 Forwards post-outage Summary Rept for ISI Examinations Conducted During Seventh Refueling Outage of Braidwood Station,Unit 2 BW990052, Informs That RW Clay,License OP-31044,no Longer Requires Operator License at Braidwood Station1999-08-12012 August 1999 Informs That RW Clay,License OP-31044,no Longer Requires Operator License at Braidwood Station 05000454/LER-1998-008, Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER1999-08-12012 August 1999 Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes BW990049, Informs NRC of Plans to Demonstrate Compliance with 10CFR50.46 Requirements for Fuel Predicted to Experience Fuel Pellet to Rod Cladding Gap Reopening,During Current Cycle1999-08-0404 August 1999 Informs NRC of Plans to Demonstrate Compliance with 10CFR50.46 Requirements for Fuel Predicted to Experience Fuel Pellet to Rod Cladding Gap Reopening,During Current Cycle ML20210U8031999-08-0404 August 1999 Forwards SER Granting Licensee Relief Requests VR-1,VR-3 & Portion of VR-2 Pursuant to 10CFR50.55a(a)(3)(ii).Relief Request VR-4 Does Not Require Explicit NRC Approval for Second 10-year Inservice Testing Program ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed ML20210K0771999-07-30030 July 1999 Submits 30-day Rept Re Discovery of ECCS Evaluation Model Error for Byron & Braidwood Stations,As Required by 10CFR50.46 ML20210K9761999-07-30030 July 1999 Forwards SE Accepting Licensee 60-day Response to GL 96-05, Periodic Verification of Design Basis Capability of Safety-Related Movs, for Plant ML20210G6291999-07-29029 July 1999 Forwards Insp Repts 50-456/99-11 & 50-457/99-11 on 990525-0706.Two Violations Noted & Being Treated as NCV, Consistent with App C of Enforcement Policy ML20210J8951999-07-29029 July 1999 Submits Other Actions,As Described,To Be Taken for Valves to Resolve Potential Pressure Locking Concerns,In Light of Extended Period for Valve Bonnet Natural Depressurization,In Response to GL 95-07, Pressure Locking & Thermal.. BW990045, Forwards Errata to 1998 Radioactive Effluent Release Rept. Info Has Been Corrected & Revised Spreadsheets Included in Attachment to Ltr1999-07-28028 July 1999 Forwards Errata to 1998 Radioactive Effluent Release Rept. Info Has Been Corrected & Revised Spreadsheets Included in Attachment to Ltr ML20210E2151999-07-23023 July 1999 Forwards Byron Unit 1 B1R09 ISI Summary Rept Spring 1999 Outage,980309-990424, in Compliance with Requirements of Article IWA-6000, Records & Repts of Section XI of ASME & P&PV,1989 Edition ML20216D3781999-07-21021 July 1999 Forwards Revised NFM9900022, Braidwood Unit 2 Cycle 8 COLR on ITS Format & W(Z) Function, to Account for Error That W Discovered in Computer Code Used to Calculate PCT During LBLOCA ML20210C3961999-07-20020 July 1999 Forwards Insp Repts 50-456/99-09 & 50-457/99-09 on 990517-0623.No Violations Noted.Weakness Identified on 990523,when Station Supervisors Identified Individual Sleeping in Cable Tray in RCA ML20216D7061999-07-19019 July 1999 Forwards Rev 45 to Braidwood Station Security Plan,Iaw 10CFR50.4(b)(4).Plan Includes Listed Changes.Rev Withheld, Per 10CFR73.21 BW990042, Forwards Braidwood Station,Unit 1 Post Accident Monitoring Rept for Reactor Vessel Level Indication Sys (Rvlis),Due to Facility Train B RVLIS Being Restored to Operable Status After 7-day Completion Time,Per TS 3.3.3 & 5.6.71999-07-16016 July 1999 Forwards Braidwood Station,Unit 1 Post Accident Monitoring Rept for Reactor Vessel Level Indication Sys (Rvlis),Due to Facility Train B RVLIS Being Restored to Operable Status After 7-day Completion Time,Per TS 3.3.3 & 5.6.7 ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20210A3151999-07-16016 July 1999 Forwards Insp Repts 50-454/99-08 & 50-455/99-08 on 990511-0621.Three Violations Being Treated as Noncited Violations ML20209H2991999-07-16016 July 1999 Withdraws 980529 LAR to Credit Automatic PORV Operation for Mitigation of Inadvertent Safety Injection at Power Accident.Response to NRC 990513 RAI Re LAR Encl BW990040, Forwards Revised Monthly Operating Repts for May 1999 for Braidwood Station,Units 1 & 2.Since Issuance of Rept,It Was Determined That Rt That Occurred on Unit 2 During Startup Was Inadvertently Omitted1999-07-15015 July 1999 Forwards Revised Monthly Operating Repts for May 1999 for Braidwood Station,Units 1 & 2.Since Issuance of Rept,It Was Determined That Rt That Occurred on Unit 2 During Startup Was Inadvertently Omitted 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217P6171999-10-21021 October 1999 Forwards non-proprietary & Proprietary Versions of HI-982083, Licensing Rept for Byron & Braidwood Nuclear Stations. Proprietary Rept Withheld,Per 10CFR2.790(b)(4) ML20217M4361999-10-19019 October 1999 Forwards Rev 46 to Braidwood Station Security Plan, IAW 10CFR50.4(b)(4).Description of Changes,Listed.Encl Withheld Per 10CFR73.21 ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20211Q9011999-09-0808 September 1999 Advises That Us Postal Service Mailing Address Has Changed for Braidwood Station.New Address Listed ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) BW990053, Forwards post-outage Summary Rept for ISI Examinations Conducted During Seventh Refueling Outage of Braidwood Station,Unit 21999-08-13013 August 1999 Forwards post-outage Summary Rept for ISI Examinations Conducted During Seventh Refueling Outage of Braidwood Station,Unit 2 BW990052, Informs That RW Clay,License OP-31044,no Longer Requires Operator License at Braidwood Station1999-08-12012 August 1999 Informs That RW Clay,License OP-31044,no Longer Requires Operator License at Braidwood Station 05000454/LER-1998-008, Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER1999-08-12012 August 1999 Informs That Licensee Determined That Suppl Rept to LER 98-008 Is Not Warranted.No Addl Info Was Generated Following Completion of Root Cause Investigation of Following Completion of Corrective Actions Stated in Original LER ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes BW990049, Informs NRC of Plans to Demonstrate Compliance with 10CFR50.46 Requirements for Fuel Predicted to Experience Fuel Pellet to Rod Cladding Gap Reopening,During Current Cycle1999-08-0404 August 1999 Informs NRC of Plans to Demonstrate Compliance with 10CFR50.46 Requirements for Fuel Predicted to Experience Fuel Pellet to Rod Cladding Gap Reopening,During Current Cycle ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed ML20210K0771999-07-30030 July 1999 Submits 30-day Rept Re Discovery of ECCS Evaluation Model Error for Byron & Braidwood Stations,As Required by 10CFR50.46 ML20210J8951999-07-29029 July 1999 Submits Other Actions,As Described,To Be Taken for Valves to Resolve Potential Pressure Locking Concerns,In Light of Extended Period for Valve Bonnet Natural Depressurization,In Response to GL 95-07, Pressure Locking & Thermal.. BW990045, Forwards Errata to 1998 Radioactive Effluent Release Rept. Info Has Been Corrected & Revised Spreadsheets Included in Attachment to Ltr1999-07-28028 July 1999 Forwards Errata to 1998 Radioactive Effluent Release Rept. Info Has Been Corrected & Revised Spreadsheets Included in Attachment to Ltr ML20210E2151999-07-23023 July 1999 Forwards Byron Unit 1 B1R09 ISI Summary Rept Spring 1999 Outage,980309-990424, in Compliance with Requirements of Article IWA-6000, Records & Repts of Section XI of ASME & P&PV,1989 Edition ML20216D3781999-07-21021 July 1999 Forwards Revised NFM9900022, Braidwood Unit 2 Cycle 8 COLR on ITS Format & W(Z) Function, to Account for Error That W Discovered in Computer Code Used to Calculate PCT During LBLOCA ML20216D7061999-07-19019 July 1999 Forwards Rev 45 to Braidwood Station Security Plan,Iaw 10CFR50.4(b)(4).Plan Includes Listed Changes.Rev Withheld, Per 10CFR73.21 ML20209H2991999-07-16016 July 1999 Withdraws 980529 LAR to Credit Automatic PORV Operation for Mitigation of Inadvertent Safety Injection at Power Accident.Response to NRC 990513 RAI Re LAR Encl BW990042, Forwards Braidwood Station,Unit 1 Post Accident Monitoring Rept for Reactor Vessel Level Indication Sys (Rvlis),Due to Facility Train B RVLIS Being Restored to Operable Status After 7-day Completion Time,Per TS 3.3.3 & 5.6.71999-07-16016 July 1999 Forwards Braidwood Station,Unit 1 Post Accident Monitoring Rept for Reactor Vessel Level Indication Sys (Rvlis),Due to Facility Train B RVLIS Being Restored to Operable Status After 7-day Completion Time,Per TS 3.3.3 & 5.6.7 BW990040, Forwards Revised Monthly Operating Repts for May 1999 for Braidwood Station,Units 1 & 2.Since Issuance of Rept,It Was Determined That Rt That Occurred on Unit 2 During Startup Was Inadvertently Omitted1999-07-15015 July 1999 Forwards Revised Monthly Operating Repts for May 1999 for Braidwood Station,Units 1 & 2.Since Issuance of Rept,It Was Determined That Rt That Occurred on Unit 2 During Startup Was Inadvertently Omitted ML20207H7501999-07-12012 July 1999 Forwards Revised Pressure Temp Limits Rept, for Byron Station,Units 1 & 2.Revised Pressurized Thermal Shock Evaluations,Surveillance Capsule Rept & Credibility Repts, Also Encl ML20209G1391999-07-0909 July 1999 Forwards Results of SG Tube Insps Performed During Byron Station,Unit 1,Cycle 9 Refueling Outage within 12 Months Following Completion of Insps ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes ML20196G2161999-06-25025 June 1999 Forwards for NRC Region III Emergency Preparedness Inspector,Two Copies of Comed Emergency Preparedness Exercise Manual for 1999 Byron Station Annual Exercise. Exercise Is Scheduled for 990825.Without Encls ML20209D4861999-06-17017 June 1999 Informs That R Heinen,License OP-30953-1 & a Snow,License SOP-30212-3,no Longer Require License at Byron Station 05000456/LER-1998-004, Forwards LER 98-004-01,IAW 10CFR50.73(a)(2)(i)(B). LER 98-004 Included Commitment to Transmit Supplemental Rept by 990628,due to on-going Evaluations1999-06-16016 June 1999 Forwards LER 98-004-01,IAW 10CFR50.73(a)(2)(i)(B). LER 98-004 Included Commitment to Transmit Supplemental Rept by 990628,due to on-going Evaluations 05000457/LER-1998-003, Forwards LER 98-003-00 Re Unit 2 Reactor Trip.Actions & Associated Action Tracking Number That Braidwood Station Is Committed to Implement in Response to LER Described Below1999-06-16016 June 1999 Forwards LER 98-003-00 Re Unit 2 Reactor Trip.Actions & Associated Action Tracking Number That Braidwood Station Is Committed to Implement in Response to LER Described Below 05000456/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B). Description of Action & Associated Action Request Number That Braidwood Station Is Committed to Implement Is Response to LER Is Listed1999-06-15015 June 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B). Description of Action & Associated Action Request Number That Braidwood Station Is Committed to Implement Is Response to LER Is Listed BW990028, Forwards Braidwood Unit 2 Cycle 8 COLR in ITS Format & W(Z) Function, IAW TS 5.6.51999-06-10010 June 1999 Forwards Braidwood Unit 2 Cycle 8 COLR in ITS Format & W(Z) Function, IAW TS 5.6.5 05000454/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i)(b).There Are Two Actions Remaining to Address Cause of Event.Both Actions Are Listed1999-06-0808 June 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(i)(b).There Are Two Actions Remaining to Address Cause of Event.Both Actions Are Listed ML20195E3451999-06-0707 June 1999 Forwards 3.5 Inch Computer Diskette Containing Revised File Format for Annual Dose Rept for 1998,per 990520 Telcon Request from Nrc.Each Station Data Is Preceded by Header Record,Which Provides Info Necessary to Identify Data ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs ML20211M1611999-05-28028 May 1999 Discusses 990527 Meeting with Comed Re Safety Culture & Overtime Control at Byron Nuclear Plant from Videoconference Location at NRC Headquarters.Requests That Aggressive Actions Be Taken to Ensure That Comed Meets Expectations ML20207D5261999-05-26026 May 1999 Forwards Response to NRC 990318 RAI Concerning Alleged Chilling Effect at Byron Station.Attachment Contains Responses to NRC 12 Questions ML20195C7911999-05-25025 May 1999 Forwards Revised COLR for Byron Unit 2,IAW 10CFR50.59.Rev Accounts for Planned Increase of Reactor Coolant Full Power Average Operating Temp from 581 F to 583 F ML20211M1781999-05-25025 May 1999 Summarizes Concerns with Chilling Effect & Overtime Abuses at Commonwealth Edison,Byron Station.Request That Ltr Be Made Part of Permanent Record of 990527 Meeting 05000457/LER-1999-002, Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Listed1999-05-21021 May 1999 Forwards LER 99-002-00,IAW 10CFR50.73(a)(2)(iv).Commitments Made by Util Are Listed 05000454/LER-1999-001, Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B).Required Actions to Address Causes of Event Listed1999-05-21021 May 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(i)(B).Required Actions to Address Causes of Event Listed ML20195B2301999-05-19019 May 1999 Requests Approval of Proposed Changes to QA Topical Rept CE-1-A,rev 66a.Attachment a Describes Changes,Reason for Change & Basis for Concluding That Revised QAP Incorporating Proposed Changes Continues to Satisfy 10CFR50AppB ML20207E9831999-05-18018 May 1999 Forwards Copy of Commonwealth Edison Co EP Exercise Evaluation Objectives for 1999 Byron Station Annual EP Exercise,Which Will Be Conducted on 990825.Without Encl ML20206T3351999-05-17017 May 1999 Provides Written follow-up of Request for NOED Re Extension of Shutdown Requirement of TS Limiting Condition for Operation 3.0.3.Page 9 of 9 of Incoming Submittal Not Included ML20206N7861999-05-14014 May 1999 Forwards 1998 Annual Radiological Environ Operating Rept for Braidwood Station. Rept Contains Info Associated with Stations Radiological Environ & Meteorological Monitoring Programs ML20206Q8521999-05-13013 May 1999 Submits Rept on Numbers of Tubes Plugged or Repaired During SG Inservice Insp Activities Conducted During Plant Seventh Refueling outage,A2R07,per TS 5.6.9 ML20206N8551999-05-11011 May 1999 Forwards 1998 Annual Radioactive Environ Operating Rept for Byron Station. Rept Includes Summary of Radiological Liquid & Gaseous Effluents & Solid Waste Released from Site ML20210C7221999-05-0303 May 1999 Forwards Initial License Exam Matls for Review & Approval. Exam Scheduled for Wk of 990607 ML20206F5381999-04-30030 April 1999 Forwards Magnetic Tape Containing Annual Dose Repts for 1998 for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR20.2206(c).Without Magnetic Tape ML20206U3351999-04-30030 April 1999 Forwards Evaluation of Matter Described in Re Byron Station.Concludes That Use of Overtime at Byron Station Was Controlled IAW Administrative Requirements & Mgt Expectations Established to Meet Overtime Requirement of TS 1999-09-08
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- 1) Owners Grove, II. N)515
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October 3,1995 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 l 1
l Attn: Document Control Desk
Subject:
Additional Information Regarding the Increase in the Interim Plugging Criteria for Byron Unit 1 and Braidwood Unit 1 NRC Docket Numbers:50-454 and 50-456
References:
- 1. D. Saccomando letter to Nuclear Regulatory Commission dated i i
September 1,1995, transmitting the Technical Specification Amendment Request Supplement Pertaining to the 3 Volt Interim Plugging Criteria for the Steam Generators
- 2. D. Saccomando letter to Nuclear Regulatory Commission dated February 7,1995, transmitting WCAP-14273 l
Reference 1 transmitted Commonwealth Edison Company (Comed) supplemental amendment request which addressed Technical Specification changes necessary to l increase the Interim Plugging Criteria (IPC) value to 3 volt for Byron and Braidwood Station Unit 1 Steam Generators. This supplement cites that the technical bases for '
the amendment request is contained in WCAP-14273, " Technical Support for Alternate j Plugging Criteria with Tube Expansion at Tube Support Plate Intersections for Braidwood 1 and Byron 1 Model D-4 Steam Generators," which was transmitted via Reference 2. WCAP-14273 contains the hydrodynamic load model, TRANFLO which was used to calculated the amount of tube support plate movement during a main steam line break event.
Since the submittal of the WCAP-14273, Comed has become aware that RELAPS is
, the more universally accepted model for the evaluation of the hydrodynamic loads produced in a steam generator during a main steam line break event. Comed has investigated the application of MOD 2 and MOD 3 and has concluded that RELAP5/ MOD 3 can be used to determine appropriate pressure loads in the bundle regions, if equilibrium temperature conditions are employed in these regions.
Occo09 kinlaibrybodistagenathydro.wpft1 ESA 488!# !!a88 6 I E. __ _ _ PDR. ,
A UnicOnt Comp.my J
h
NRC Document Control Desk October 3,1995 In the Attachment Comed is providing the following information which justifies the appropriateness of RELAP5/ MOD 3:
- 1. Background l lI. Appilcation of RELAPS Code for Prediction of the Steam Generator Blowdown l History During a Main Steam Line Break l 111. Instabilities in RELAP5/ MOD 3 IV. Conservatism ,
V. Conclusion A margin of 1.5 has been added to the resultant loads to ensure additional conservatism. Comed is proceeding to perform the structural analysis to determine which steam generator tubes need to be expanded to support the design bases as described in WCAP-14273.
In addition to this margin of 1.5, it is important to recognize that several other conservatism and/or margins have been applied to ensure the overall conservatism in I the 3.0 volt IPC application at Byron Unit 1 and Braidwood Unit 1. A letter detalling these conservatism will be forwarded to the Staff promptly.
If you have any questions concerning this correspondence, please contact this office.
Sincerely, w
M' Denise M. Sacco Nuclear Licensing Administrator Attachment cc: D. Lynch, Senior Project Manager-NRR R. Assa, Braidwood Project Manager-NRR G. Dick, Byron Project Manager-NRR S. Ray, Acting Senior Resident inspector-Braidwood H. Peterson, Senior Resident inspector-Byron H. Miller, Regional Administrator-Rill Office of Nuclear Safety-IDNS kinla ibrybwd: stegens ihydro.wpf 2
7 . .
Hydrodynamic Load Model Assessment BackarouDd Rapid depressurization following a main steam line break of a steam generator may result in large differential pressures, and therefore, significant loads on the tube support I plates. The RELAPS/ MOD 3 computer code has been used by Comed to evaluate the differential pressure across the steam generator tube support plates following a main steam line break. A model for the Westinghouse Model D4 steam generator at Byron 1/Braldwood1 was developed and a series of predictions were performed to )
. calculate the pressure history and the differential pressure at the support plates.
The purpose of this document is to demonstrate the applicability of RELAP5 for analysis of a steam line break blowdown scenario. In addition, the method of employing
- RELAPS/ MOD 3 will be discussed in light of metastable conditions in interfacial heat transfer discovered in the course of the performance of these calculations.
i Anoticability of RELAP5 Code for Prediction of the Steam Generator Blowdown History During a Main Steam Line Break RELAP5 code has been developed as a best estimate tool for transient analysis of the j pressurized water reactors. This code has been tested extensively by predicting the i phenomenological problems, separate effects tests, as well as integral test problems.
RELAPS/ MOD 3 has extended the capabilities of MOD 2 by improving some of the existing models and adding new features which include: two energy equations for modeling non-equilibrium effects, reflood heat transfer model, revised constitutive equations for the interface drag and CCFL, and additional component and control l system models.
~
The steam line break of a steam generator can be simulated by a calculational tool which contains governing equations and constitutive relations capable of predicting the depressurization history, void fractions and therefore level swell, and the losses across different components of the steam generator. Although all the best estimate codes are based on constitutive relations which are developed from steady state concepts, they contain empirical parameters which when combined within the codes have been able to predict the transient separate effects and Integral tests, as well as plant transients.
Both RELAP5/ MOD 2 and MOD 3 have been used to simulate liquid and steam blowdown tests. The most relevant separate effects tests are the GE one foot (test
. 1004-3) and four foot (test 5801-15) level swell tests, Ref.1. Comparison of the data i and predicted pressures by RELAP5/ MOD 2 and MOD 3, Figures 1 and 2 (reproduced i
from Ref. 2), shows that both codes are equally capable of predicting the vessel pressure history. This means that the critical flow model and the overall vapor now.m.n.w.wm
+
y._ _. - _ . _ _ _ ._ _ . _ _ _ _ _ _ _ _ _ _.
,.. ,j . , .
l- . .
gen'eration rates are representative of the actual conditions during blowdown. The -
comparison of the measured and predicted void fractions at different axial profiles at i various times.are shown in:
i
! Figure 3' 10 seconds Test 1004-3
- < Figure 4 40 seconds Test .1004-3
- Figure 5- 160 seconds Test 1004-3
. Figure 6'- 5 seconds' Test 5801-15
- Figure 7' 10 seconds Test 5801-15
- Figure 8 20 seconds Test 5801-15 Again, both codes predict the void fraction profiles and, therefore, the level swell during the depressurization. !
I j : GE level swell tests were performed with an open bundle configuration and the
, predictive capability of RELAP with bundle geometric should also be demonstrated.
Comparison of the predicted and measured void fractions for.ORNL THTF rod bundle 1
- boil off tests has shown that RELAP5/ MOD 2 over predicts the void fraction and, l therefore, under predicts the liquid level. The interfacial drag formulation in MOD 3 was modified to incorporate the Chexal-Lellouche drift flux formulation. The predicted void fraction profiles by MOD 2 and MOD 3 for THTF test 3.09.101 are shown in Figure 9 and demonstrated (reproduced from Ref. 3) improved prediction of the void fraction by ,
RELAP5/ MOD 3 for bundle geometries under co-current upward flow.
4 Instabilities in RELAP5/ MOD 3 A RELAPS input model representing the Byron 1/Braldwood1 Model D4 steam generator 4 was developed and the blowdown history during a steam line break was predicted using RELAP5/ MOD 2 (Reference 4). The pressure drop across the P-TSP, Figure 10, shows a peak value of 1.97 psl at 0.6 seconds. This model was converted to MOD 3 format ,
and the prediction of the pressure drop across P TSP, Figure 11, shows a sharp peak of approximately 5.0 psi around 1.2 seconds. Since the MOD 2 results did not indicate any secondary peaks, the spiking behavior was considered suspect and additional eva!uations were performed. Cases were run that: 1) removed the interphase drag models,2) changed the drag models from tube bundle to pipe, and 3) selected equilibrium temperature conditions in the bundle regions. The developers of the RELAPS/ MOD 3 computer code were contacted and extensive discussions and testing were performed. A review of the test results leads to the conclusion that the interfacial heat transfer behavior is a likely cause of the unphysical behavior observed in the
. model. This was additionally corroborated in discussions held with Dr. V. Ransom of Purdue University.
~
' kialasbrytwd stagensthydro.wpf 4
]. .
A review of the RELAPS/ MOD 3 assessment problems shows that Workshop problem 2 exhibits a strong oscillatory behavior with MOD 3, particularly with respect to the bundle riser velocities, where the MOD 1 and 2 results are more quiescent. The D4 SG problem, with its detailed focus on the bundle velocity and dp behavior, along with flow reversal in the tube bundle, is likely to be very sensitive to this behavior.
To demonstrate the effects noted, plots from the test cases performed are provided.
Figure 12 shows the base case (with instability) temperatures in a middle tube volume.
Figure 13 shows the interfacial heat transfer parameters for the same volume (HIF and HIG expanded minor edit parameters). As can be seen, the amount of liquid phase superheat is significant (nearly 6 degrees F) and rapid resolution to near saturation occurs as a result of a rapid increase in HIF. The high levels of liquid superheat in a good mixing environment like the tube regions are not anticipated, and the values that exist following the instability are considered much more representative of the physical situation. Selecting a single momentum equation (by setting h=2 in the junction control words), effectively eliminates the interphase drag from consideration. Figures 14 (One momentum equation case),15 (Fluid Temperature Response), and 16 (Interfacial Hear Transfer Coefficients) provide the predicted differential pressure across the P-TSP as well as the fluid temperatures and interphase heat transfer coefficients in the same middle tube volume. As can be seen, the instability assumes a similar oscillatory behavior as the base case following a rapid approach to saturation precipitated by interfacial heat transfer. This case demonstrates that the instability is not caused by the interphase drag models. The equilibrium case (setting e=1 in tube region volume control cards) shows that by causing the code to maintain the phasic temperatures nearly equal eliminates the pressure spiking behavior, (Figure 17), supports that the metastability is directly related to the determination of interfacial heat transfer, t,_.nEd has been actively engaged in obtaining relevant test data with regard to this issue. To dste we have recovered data for several Model Boller (MB2) tests.
(Reference 5) The data recovered concerns tests 2009, and 2013 which were full size steam breaks from hot zero power conditions, on a scale Model F steam generator.
We have developed a RELAP5/ MOD 3 model of the test apparatus and are currently performing comparisons. Initial reviews indicate that RELAP 5 models macroscopic behavior, (depressurization rate, bulk flows, etc) very well, and our current focus is on the pressure drops in the bundle region. Test 2013 data at 0.1 second intervals and i
test 2009 data available at 1 second intervals support the conclusion that there is no major load causing phenomena beyond the initial fluid surge. This provides additional support for the use of equilibrium temperature modeling in the tube regions.
Based on the above results, Comed has concluded that RELAPS/ MOD 3 can be used to determine appropriate pressure loads in the bundle regions, if equilibrium temperature conditions are employed in these regions. This approach captures the essential physics of the initial fluid motion in the tube region that represents the principal dynamic load on the TSPa, without experiencing non-physical behaviors due to artificial variations in k i nla i brytned ; s tag ens : hydro . wp f i l
e
-inte'rfacial heat transfer. This results in loads that are very comparable, and slightly conservative with respect to those predicted by other RELAP/ MOD 2, TRANFLO and Multiflex.
Conservatism Hydrodynamic loads as defined by RELAP5 MOD 3 have been increased by a factor of 1.5 to assure all unforeseen uncertaintles have been included. In Comed's original submittal, the definition of hydrodynamic loads was based upon the application of a margin of 2 to the loads predicted by TRANFLO. These loads were then backed up with additional evaluations using Multiflex.
Subsequent to that submittal in February 1995, Comed has performed additional analysis using RELAP5 MOD 2 and MOD 3, and has performed and docketed a :
hand calculation intended to quantify a bounding load. Based upon the convergence of all these analysis, Comed's confidence in the bounding loads developed as part of RELAP 5 MOD 3 justify the application of a 1.5 margin.
Conclusions Comed is currently completing an evaluation of the TSP response with differential pressure loads developed based on RELAP5/ MOD 3 version 1.1. This evaluation will include a series of sensitivity studies similar to those performed in WCAP-14273 for the bounding hot zero power case. This is believed to be the appropriate approach because:
- 1. RELAP5/ MOD 3 provides the most accurate characterization of flow regime and void fraction, thereby yielding the most representative load.
- 2. Initial comparisons with MB2 test data indicate that RELAP5/ MOD 3 captures the timing and magnitude of the differential pressures as well as the flow directions more accurately than other analytical tools.
- 3. RELAP5/ MOD 3 produces loads that are directly comparable both in timing and magnitude to previously generated hand calculations. (Reference 6) 4i RELAP5/ MOD 3 produces loads that are very comparable, and slightly conservative to those predicted by RELAPS/ MOD 2, TRANFLO and Multiflex.
- 5. Application of a 1.5 margin to the RELAP5/ MOD 3 hydrodynamic load is justified based on the convergence of analysis performed using other codes.
- 6. Several conservatism / margin exists which further ensures overall conservatism in the application of the 3 volt IPC.
=,,u.i e . w .n.inya,.. ri.
References
- 1. J.A. Findlay and 0.L. Sazzi, "BWR Refill-Reflood Program-Model Qualification Task Plan," EPRI NP-1527, NUREG/CR-1899, GEAP-24898, Oct.1981.
- 2. K.E. Catison et. al., "RELAP51 MOD 3 Code Manual, Volume Ill: Developmental Assessment Problems," NUREG/CR-5535, EGG-2596, (Draft), Vol.111, June 1990.
- 3. J.M. Putnoy, " Development of a new Bubbly-Slug Interfacial Friction Model for RELAP5, Final Report," ESTD/UOO75/R89, Oct.1989.
- 4. K. B. Ramsden, " Calculation of Byron D4 SG Tube Support Plate Differential Pressures during MSLB with RELAP5M2," PSA-B-95-11.
- 5. Mendler et. al., " Prototypical Steam Generator (MB-2) Transient Testing Program Data Package for Steam Line Break Tests," EPRI Project RP1845-08, October 1985.
- 6. K. B. Ramsden, "An Independent Verification of Byron /Braidwood D4 SG Tube Support Plate Differential Pressures during MSLB," PSA-B-95-15.
i i
i c a . e, % . m .n.,wy4r.. ,
8 , , ,
daLa
= = 1270000p-r5m3
- 1270000p-r5m2 6 - o--o 1290000p-r5ml -
TC b '
84 -
E \
c E N 2 -
0 O 50 100 150 200 Time (s) 1 Figure 1 Measured and calculated (RELAP5/M001, MOD 2, M003) pressure in the top Of the vessel for GE level swell Test 1004-3.
~ '
- ---_._-___.__.__________m_ . _ _
o a t e- . l*,
8 , ,
_...~ data
= = 101010000p-r5m3 a---* 101010000p-r5m2 6 -
?
4 -
%k .
E 2 -
N N=%,4 l 1
( - l s.
0 5 10 15 20 O
Time (s)
Figure 2 Measured and Calculated (RELAPS/ MODI, M002, M003) pressure in the top of the vessel for GE level swell Test 5801-15.
i I
l l
l 1.0 , , , , , , l o Data o- o ' RELAPS/ MOD 3 0.8 - . . RELAPS/ MOD 2 l
)
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3 0.6 -
o 0
i ? * ~
1,1 ~
a.-> ^ .-/ ~
D 0.2 -
p V ' ' ' ' ' '
0.0 f
O 2 4 6 8 10 12 14 Time (s) a l
i 4
Figure 3 Measured and Calculated (RELAP5/ MODI, M002, M003) v0id fraction profile in the vessel at 10 s for GE level swell Test 1004-3.
i t
1.0 . ,
, , -=. ,. ,
b, _ : _ '
o' Data e o RELAPS/ MOD 3 '
0.8 - *
RELAPS/ MOD 1 c l
$0 o.8 -
2 3O o.4 - ,
> a -
o - -: !
l
-( _._
- o.2 - o -
o.o o 2 4 5 8 to 12 14 Time (s)
...... l Figure 4 Measured and calculated (RELAP5/ MODI, MOD 2, M003) void fraction profile in the vessel at 40 s for GE level swell Test 1004-3.
j
l 1
1 l
1.0 , , , n p - -
o Data l c 3 RELAPS/ MOD 3 0.8 - *
)
c 0.6 -
E -J 3O 0.4 -
o _, A ;
0.2 -
0.0 14 O 2 4 6 8 10 12 Time (s) ,
Figure 5 Measured and calculated (RELAPS/M001, MOD 2, MOD 3) void
- fraction profile fu the vessel at 160 s for GE level swell Test 1004-3.
l i
1.0 , , , , c_, : ,:.1 :
~
o Data ~
o--o RELAPS/ MOD 3 0.8 - *
o J
0.7 -
o C
8 -
0.6 -
U
[
0.4 -
o . / -
0.3 '- ,
i -
0.2 -
0.1 '-
0.0 0 2 4 6 8 10 12 14 Time (s) i Figure 6 Measured and calculated (RELAP5/M001, M002, M003) void fraction profile ir the vessel at.5 s for GE level swell Test 5801-1. 5 1
l l
l
1.0 ' ' ' r*
L U*l" -
' O.9 a o---o RELAPS/ MOD 3 0.8 :- *
~ -
g 0.7 -
o . -
0.6 o 3 -
O
~ J w
6 0.5 -
J 0.4 -
> o,3 O
~2O ,
O.1 -
0.0 O 2 4 8 8 10 12 14 !
Time (s) s....,,,
I l
Figure 7' Measured and calculated (RELAP5/ MODI, M002, M003) void fraction profile in the vessel at 10 s for GE level swell Test 5801-15.
1.0 , , .- r 2
0.9 -
o 2
0,8 -
0.7 -
0.6 -
8 0.5 -
a 3o 0.4 -
2 0.3 ' o-0.2 o Data RELAPS/ MOD 3 _
' 0.1 -
a a RELAPS/ MOD 2 0.0 O 2 4 6 8 10 12 14 Time (s) 3.......
Figure 8 Measured and calculated (RELAP5/M001, MOD 2, M003) void fraction profile in the vessel at 20 s for GE level swell Test 5801-15.
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Figure 11 ,
.~
Base Case full nonequilibrium DP at P-TSP -
5.00E+00 - - --
4.50E+00 -- l .
4.00E+00 -- ,
3.50E+00 -- i i
I 3.00E+00 --
2.50E+00 -- i a ,
j l cntrivar 1 deltpp sum l
" 2.00E+00 -- ,
1.50E+00 --
1.00E+00 -- :
f 5.00E-01 -- l I
0.00E+00 O.0CE+0 2.00E-014.00E-016.00E-01 8.00E-01 1.00E+0 1.20E+0 1.40E+0 1.60E+0 1.80E+0 2.00E+0
-5.00E-01 "
time seconds t
s
Figure 12 Base Case full nonequilibriurn ,
Temperature Response in 13501 .
560 -- .
558 -
556 i
554 --
g 552 -- ,
i - --- tempf 135010000 #NAME?
$ tempg 135010000 (degf) i E 550 -- ------sattemp 135010000 (degf)
E.
E 8 548 -- !
546 -
l i
544 -- ;
542 --
- : . 5 540 . . : .
0.00E+0 2.00E- 4.00E- 6.00E- 8.00E- 1.00E+0 1.20E+0 1.40E+0 1.60E+0 1.80E+0 2.00E+0 01 0 0 0 0 0 0 0 01 01 01 time seconds 1
m
_ _ _ _ _ _ _ _ - - _ _ - _ . _ - _ _ _ _ _ _ _ _ . _- _.___________.__m. _ _ _ _ _ _ - . . _ _ _ _ _ _
Figure 13 Base case full nonequilibriurn -
Interfacial heat transfer coefficients 2500 -
~
\
l 2000 --
i !
1 7
- I 1500 -- . l
- I 2
g s
hig 135010000 (tdu/sec-f degf) 6 1000 -- . - - - - - hit 13501000013-(tau /seo 83 deOf )
l
.E :
?
a
.ca i
500 - -
. i i
0 -- . . . . .
0.00E+ 2.00E- 4.00E- 6.00E- 8.00E- 1.00E+ 1.20E+ 1.40E+ 1.60E+ 1.80E+ 00 2.00E+
00 01 01 01 00 00 00 00 00 01 i
1
- - - - - - - - - - - - - - -I
-500 - - -- - - - -
time seconds
- - - - - - ---_--_____________m
Figure 14 .
f l
l l
One Mom Eq Case .
DP at P-TSP .
4.00E+00 -- - - - - - - -
i I i 3.50E+00 --
1 '
3.00E+00 -- t i
.2.50E+00 -- 4 2.00E+00 -- - cntrivar1 deltpp sum l
% j l-g '
=
v 1.50E+00 -- i 1.00E+00 -- I i
5.00E-01 --
9 0.00E+00 M. ; ; ; ;
0.0C E+0 2.00E-01 4.00E-01 8.00E-010 8.00E-01 0 1.00E+0 0 1.20E+0 0 0 1.40E+0 0 1.80E+0 1.80E+0 2.00E+0 11 - - - - - -
-S.00E-01 - -
time seconds s
Figure 15 ,
One Mom Eq Case ,
Temperature Response in 13501 560 -- - --- - - - - ,
558 -
556 --
554 -
Lb E 552 -- ; ---- tempf 135010000 #NAME?
$ tempg 135010000 (degf) k ,
. . - - . .sattemp 135010000 (degf)
E 550 --
H 548 -- !
i 1
546 -- {
i 544 --
i 542 : : .
0.00E+0 2.00E- 4.00E- 6.00E- 8.00E- 1.00E+0 1.20E+0 1.40E+0 1.60E+0 1.80E+0 2.00E+0 01 01 01 0 0 0 0 0 0 0 01 time seconds u .m_ m_ ___ ---
. =. _ . __
Figure 16 One Mom Eq Case .
Interfacial Heat Transfer Coefficients 2500 -- . _ _ .. . . . '
..i i
. i 2000 -- . .
I
- i
- i i
E ! !
4 l i i hig 135010000 (btu /sec-f degf) g 1000 -- l j l . . . . . . hif 135010000 t3-(btu /seo-ft3 deOf) m . . ,
'is
II : : i i
500 - r '
'i f~J -
0 ". - . .
0.00E+ 2.00E- 4.00E- 6.00E- 8.00E- 1.00E+ 1.20E^ 1.40E+ 1.60E+ 1.80E+ 2.00E+
00 01 01 01 01 00 00 00 00 00 00 I
-500 - - - -- - -- - - - - - - - - - - - - - ------------------------a time seconds
___m___. _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______m -- -__m
Figure 17 Equilltrium Case _' .
DP at P-TSP .
2.00E+00 --
1.80E+00 - i 1.60E+00 -
1.40E+00 -- >
l 1.20E+00 --
._ 1.00E+00 -- cntrtvar 1 deRpp sum l a l g
" 8.00E-01 --
t 1
6.00E-01 --
4.00E-01 --
i l
2.00E-01 -- i
\
0.00E+00 : :
0.0C E+0 2.00E-01 4.00E-01 6.00E-01 8.00E-01 1.00E+0 1.20E+0 1.40E+0 0 1.60E+0 0 01.80E+0 2.00E+0 0 0 0 2.00E-01 0-time seconds
~
2__.__u__ _ _ - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ . . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _