ML20098D076
| ML20098D076 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/21/1984 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| OL, NUDOCS 8409270347 | |
| Download: ML20098D076 (15) | |
Text
{{#Wiki_filter:- PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 1 JOHN S. KEMPER .... = ="l1.. SEP 21 1984 Docket Nos. 50-352 50-353 Mr.. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing - U.S. Nuclear Regulatory Ccmnission Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 & 2 Information for Containment Systans Branch (CSB) Drywell/ Suppression Chamber Vacuun Breaker Valve Position Switches
Reference:
9/20/84 Telecon Between D. R. Helwig (PECo) and F. Eltawila (NBC-CSB) File: GOVT 1-1 (NBC)
Dear Mr. Schwencer:
Attached are draft changes to FSAR Sections 9.4.5.1.5 and response to RAI 480.7 which are being made as a result of discussions during the referenced telephone conversation. 'Ihe information contained on these draft FSAR changes will be incorporated into the FSAR, exactly as it appears on the attachments, -in the revision scheduled for October, 1984. Sincerely, DAA/auv/09108413 Attachnent Copy to: See Attached Service List h'0 8409270347 840921 6 PDR ADOCK 05000302 A PDR l
cc: ' Judge Lawrence Brenner (w/o enclosure) Judge Peter A. Morris (w/o enclosure) Judge Richard F. Cole-(w/o enclosure) Judge Christine N.' Kohl (w/o enclosure) Judge Gary J. Edles. (w/o enclosure) Judge Reginald L. Gotchy . (w/o enclosure) Troy B. Conner, Jr., -Esq. (w/o enclosure) Ann P. Hodgdon,'Esq. (w/o enclosure) Mr.' Frank R. Romano (w/o enclosure) Mr. Robert L. Anthony (w/o enclosure) Ms. Maureen Mulligan .(w/o enclosure) Charles W. Elliot, Esq. (w/o enclosure) Zori G. Ferkin, Esq. (w/o enclosure) Mr. 'Ihmas Gerusky (w/o enclosure) Director, Penna. Dnergency (w/o enclosure) Management Agency Angus R. Love, Esq. (w/o enclosure) David Wersan, Esq. (w/o enclosure) Robert J. Sugarman, Esq. (w/o enclosure) Martha W. Bush, Esq. (w/o enclosure) Spence W. Perry, Esq. (w/o enclosure) Jay M. Gutierrez,-Esq. (w/o enclosure) Atmic Safety & Licensing (w/o enclosure) Appeal Board Atanic Safety & Licensing (w/o enclosure) Board Panel Docket & Service Section (w/o enclosure) Mr. James Wiggins (w/o enclosure) Mr. Timothy R. S. Canpbell (w/o enclosure) l l -e-
a Qf IN Fo. DAILY LGS FSAR series, for containment isolation.Each gas sample line is provided with tw valves may be overriden by using keylocked bypass switches.The isolation signa Containment Hydrocen Recombiner Packaaes the primary containment.In the event of a LOCA, hydrogen and oxyge'n may be g To control the buildup of oxygen and prevent a combustible concentration from occurring, redundant containment hydrogen recombiners are provided, as described in Section 6.2.5. The process gas supply and return lines for the recombiner packages connect to the high-volume purge lines, inboard of the~1atter's containment isolation valves. return lines are each provided with a normally-closed,The supply and moter-operated butterfly valve for containment isolation. operation, and they automatically close upon receipt of avalv These containment isolation signal. For operation of the r combiners after a LOCA, the isolation signals to these valves.ce overridden by esing keylocked bypass switches. Redundant isolation valves refueling outage.will be added.to the recombiner lines before the end of the first be exposed to the post-LOCA containment atmosphere have beenThe Containmentisolationisdiscussedfurthe[rinSection6.2.4 de Post-LOCA Purce ( As a. backup to the redundant oxygen recombiners, post-LOCA oxygen concentration can be controlled by purging the containment i atmosphere. The post-LOCA purge is accom described above for the low-volume purge.plished by the same method Under post-LOCA conditions, however, the gases exhausted from the containment are processed through the RERS and the SGTS (both are described in Section 6.5.1) prior to release to the environment. signals to the containment isolation valves on the low-volume purge The isolation l i lines may be overridden by using keylocked bypass switches. Containment isolation is discussed further in Section 6.2 4 Primary Containment Vacuum Relief Valve Assemblies In order to limit the degree to which suppression chamber pressure o v. can exceed drywell pressure, four primary containment vacuum relief valve assemblies are suppression chamber, provided. The assemblies are located in the each assembly being mounted on the side of a downconer. Each assembly consists of two 24-inch (nominal diameter) vacuum relief valves mounted in series. specified amount, the vacuum relief valves open automatica When the allowing gases from the suppression chamber to enter the downcomer and flow u i and below.pward into the drywell, thereby equalizing pressure above the diaphragm slab. ( Rev. 33, 06/84 9.4-40 NJ
fbA / N Fu. CAJLY LGS FSAR I l A single vacuum relief valve (upstream type) is shown schematically in Figure 9.4-6. same, except for a shorter body length.The downstream valves are the swinging disk that closes an orifice in the body of the valve.The valve consist The valve disk.is keyed to a body-penetrating shaft that rotates as the disk opens or closes. By way of lever arms also keyed to i this shaft,'s compression spring holds the valve disk against the seat. When the differential pressure across the disk (in the opening direction) results in a force greater than the force exerted by the spring, the valve begins to open. The opening set y pressur.e of the valve is 0.5 psid. However, because each when the differential pressure across the valve assembly re differential pressur,e is 2.9 psid.about :1 psid, and both valves reach full i t ( r-9.4-40a Rev. 33, 06/84
fdy$2. / Wf0. Ob)Lj LGS FSAR { The flow loss coefficient for the vacuum relief valves was calculated based on actual flow measurements conducted in the manufacturer's shop. differential pressure established across the valve, and theThe valve resulting flow rate was measured. i Using this measurement, the loss coefficient for 24-inch pipe size was calculated to be 2.7 for a single valve and 5.63 for two valves mounted in series. 1 A valve operator is provided so that the valve can be opened to check the operation of the valve and the disk position indication system. Associated hand switches are located on a test panel in When the switches are actuated, air pressure is applied to th actuhting cylinder. applied by the spring and thus opens the valve.This pressure overcomes the 9.4 5.1.3 Safety Evaluation The safety-rel'ated functions of the CAC system include primary containment isolation, suppression chamber to dr relief, suppression chamber pressure monitoring,ywell vacuum and post-LOCA combustible gas monitoring and control. t All safety-related portions (including supporting s ructures) of the CAC system are designed to seismic Category I requ.irements as defined in Section 3.7. That piping which is safety-related is designed, fabricated, inspected, and tested in accordan,e with the requirements of the ASME B&PV Code, Section III, Class 2, discussed in Section 3.2. as All safety-related portions of the CAC system are located within the reactor enclosure, which is designed to seismic Category I requirements as discussed in Section 3.8.4. Evaluation of the CAC system with respect to the following areas is discussed in the following sections: Protection from wind and tornado a. Section 3.3 effects h b. Flood design Section 3.4 c. Missile protection Section 3.5 d. Protection against dynamic effects Section 3.6 associated with the postulated rupture of piping e. Environmental design Section 3.11 9.4-41 Rev. 29, 02/84
fcf )WFa. 6rJL.f LGS FSAR hydrogen recombiner supply and return lines)Each line pene ( is provided with redundant isolation valves powered from different divisions of 4 Class 1E power. Therefore in the even), of failure of one division of Class 1E power,, no more than one containment isolation valve in each pair is disabled, and the isolation function is assured. Each supply and return line for the hydrogen recombiners is provided with a single containment isolation valve. The hydrogen recombiner loops are closed systems outside containment, so that failure of an isolation valve in the open position would not constitute a breach of containment integrity. valve is annunciated in the control room.The bypass of an isolation signal to any TheIsimplicity of design of the primary containment' vacuum relief to limit the differential pressure across the diaphragm sla valves are of the swing check configuration and require no motive The power other than the differential pressure across the valve. use of two valves in series within each assembly prevents a failure The of any single. valve in the stuck-open position from compromising the pressure suppression capability of the primary containment. detail in Section 6.2.5. Post-LOCA combustible gas monitoring and control is ( drywell air cooling system is presented in Table 9.4-11.A fa 9.4.5.1.4 Tests and Inspections The CAC system is preoperationally tested in accordance with the with the requirements of Chapter 16. requirements of Chapter 14 and safety-related portions of the system is in accordance with theInservice inspe ASME B&P't Code, Section XI, for Section III, Class 2 components. The primary containment vacuum relief valve assemblies are preoperationally tested by the manufacturer to verify the openin( set pressure. increasing pressure to the inlet side of the valve and observinThe This point indicates the start of leakage across the valv g which is the definition of the beginning of valve opening. <t 9.4.5.1.5 Instrumentation Applications The CAC system is designed to be operated remotely fromsthe control position indicating lights in the control room. Power-operated valves a room. other than contsinment isolation are performed manually.All operations Rev. 12, 10/82 9.4-42
~ DRAET LGS FSAR b i i J g g W J The liquid nitrogen facility is provided with controls and j >- x d l-instrumentation necessary to maintain the pressure and 5 temperature of the gaseous nitrogen supplied by the facility g3 l within appropriate ranges. The steam inlet piping to the water , g bath vaporizer is provided with a control valve which modulates 5 to control the rate of steam admission to the steam coil inside 4.* i the vaporizer. A temperature sensor immersed in the water bath provides a signal to this control valve so that the water bath j, temperature can be automatically controlled within a preset S Ti g range. The pressure of the gaseous nitrogen leaving the liquid DA nitrogen facility is maintained at 50 psig by a pair of pressure controlvalveslocatedinthenitrogensupplypipingdownstreamIy.o, of the vaporizer. A dual setpoint temperature switch installed I f in the nitrogen supply piping near the two pressure control ( {T, The presence of nitrogen in the piping at a temperature outside I y <@ p valves is wired into the control circuits of those two valves. f a the range defined by the setpoints of'the temperature switch will q I cause the switch to trip and the pressure control valves to 1, k close, thereny terminating the flow of nitrogen gas from the gy liquid nitrogen facility. I high-volume purge penetrations, the desired flow rate of nitroger' During inerting of the primary containment through the into the high-volume purge piping is set by the operator on a J $ flow controller in the control room. The measured flow rate in ' )r the nitrogen supply piping is displayed on the flow controller ')p 0 and is automatically compared to the value.eet on the flow controller; a signal corresponding to the difference between 3 these two values is used to automatically modulate a flow control, R 3 . valve in the nitrogen supply piping so as to maintain the desired' E
- d l-flow rate.
When nitrogen is introduced into.the primary age l containment in the low-volume purge mode, the nitrog'en flow rate I.aQ in the low-volume purge piping is recorded in the control room 6 and.the operator controls the flow rate by remotely actuating a 3 y w' motor-operated valve in that piping. 3g 1 Gas pressure in the nitrogen supply lines is indicated in the I control room. Temperature in the nitrogen supply lines is indicated locally. I Position indication for ea vacuum r_elief valve is provided by a set of position switches that operate off the same body-penetrating shaft to which the valve disk is attached,f The -redundant position switches and their associated indicating lights on a test panel'in the reactor enclosure provide visual I indication when the valve is "not fully closed" or "not fully { - g sc. o " When the valve is in an intermediate position, both the - perY " pen.not fully closed" and "not ful-ly open" sets of-lights. are on. l _ The plunger-type "not fully closed" switches have a hysteresis, l _or_ differential travel)fof 0.00 in h. We wi ch h st es i y LETE i ) - l iplJ ugty tnpr me an al in ge o e lv di o L tipfe vafve 14 o eni g u er iff re ial pr sur, e 9.4-43 Rev. 11, 10/82
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i l fD N [i 2 m y% c p. : t pfLerE 2=d'b'...aD.n.b3 LGS FSAR d ko th dow stre val e is .06 i h of the s' eat b ore el.' " ot ull c1 ed" hts comes on. e up tream alve can b I .06 in of the at i the ame s unti n. W en th valv is I cle in und dif ren al pr ssure or w n the valve is op nin j or el sing y th act
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efnot ully losed lich s are on un ess the disk is on the / eM._)~A valve position other than fully closed is annunciated in the control room. Atmosphere temperature in the drywell and suppression chamber is monitored by two temperature elements in each volume. The temperatures at all four points are recorded simultaneously in the control room. Drywell temperature is also indicated at the remote shutdown panel. prs"sures in the drywell and suppression chamber are monitored by s pressure transmitters mounted outside the containment and are indicated in the control room. Suppression chamber pressure is-also recorded in the control room. 9.5.5.2 Drywell Air Coolino System The drywell air cooling system serves to. remove heat from the drywell during normal plant operations and to maintain air circulation in the drywell under accident conditions. This latter function is safety-related. {} 9.4.5.2.1 Design Bases The drywell air. cooling system is designed to 1.imit the .a. temperature inside the drywell, during normal reactor operation, to an average of 1350F, with the maximum not to exceed 1500F. l l b. The drywell E.ir cooling system is designed to limit the temperature inside the drywell, in the event of Icss of offsite power and reactor scram, to 1860F in ganeral drywell areas and 2100F in the area below the reactor vessel (inside the reactor pedestal). The drywell air cooling system is designed to prevent c. concrete structures within the primary containment from l exceeding their maximum design temperature during normal operation. 1 d. The drywell air cooling system is designed to maintain the drywell atmosphere in a thoroughly mixed condition following a LOCA to prevent stratification of oxygen .that may be generated as a result of the accident. i e. Safety-related portions of the drywell air cooling ( system are designed to remain functional after an SSE. ,) Rev. 29, 02/84 9.4-44
Ft1 W Fo orJL4 e LGS FSAR l DUESTION 480.7 (Section 6.2.1.1) i Appendix I to SRP Section 6.2.1.1.C provides criteria designed to upgrade the steam bypass capability of the Mark II containment -design and to assure that the bypass leakage is not substantially increased over'the life of the plant. Provide the following infcrmation to demonstrate compliance with Appendix I to SRP Section 6.2.1.1.C: The analysis of the Limerick steam bypass capability for a. small breaks presented in FSAR Section 6.2.1.1.5 is ,~ unacceptable. Provide an analysis that shows the suppression chamber design pressure is not exceeded when a leakage area of A/vK equal to 0.05 ft2 is assumed and a minimum of 30 minutes is assumed for operator action to terminate the suppression chamber pressure transient following indication in the main control room that a bypass leakage path exists. Specify the plant parameter that Will indicate the existence of a bypass leakage path, and commit to providii.g main control roo:a annunciation of this condition. Also specify the . specific operator action that will be taken to terminate l{- the suppression chamber transient. If this analysis shows the suppression chamber design pressure is -exceeded prior to the time when operator action can be assumed, then NRC's pcsition is-that the wetwe11,-spray must be automatically actuated. If the wetwell sprays must be automatically actuated, the consequences of automatic actuation of the wetwell sprays on ECCS L function and long-term pool cooling must be evaluated to show that the minimum ECCS and pool cooling requirements are met. b. Provide a' complete description of the transient analysis requested in part (a) including all analysis assumptions; initial conditions; the pressure history in 3 the drywell and wetwell; wetwell spray capacity, L efficiency, coverage, start time and temperature history; and identification and quantification of heat sources. In addition, for the wetwell spray nozzles, provide the spectrum of drop sizes and mean drop size emitted from the nozzles as a function of pressure drop acrcss the nozzles and describe how this data was obtained (e.g., a spray nozzle test program). ' A.lso, j discuss the consideration given to evaporation'dd'e to impingement of spray water on the hot downcomer i surfaces. l 480.7-i Rev. 14, 12/82
~ FM-RJFo OWI LGS FSAR c. If the wetwell spray system is to be used to mitigate the consequences of suppression pool steam bypass either ~ manually or automatically, it-is our position that the wetwell spray headers must meet Quality Group B standards rather than the Quality Group C standards shown in FSAR Table 3.2-1.- Provide information on how you will comply with this position. d. Per the guidance of SRP 6.2.1.1.C (Appendix I) it is our position that.a preoperational high-pressure leakage test and postoperational low-pressure leakage tests should be performed to detect leakage from the drywell 3 to the suppression chamber. The high-pressure test should be performed at approximately the peak drywell to wetwell differential pressure. The low-pressure test should be performed at a differential pressure corresponding to approximately the submergence of the -vents during each refueling outage. Acceptance criteria ~for both tests shall be a measured leakage less than 10% of the* capability of the containment to accommodate bypass leakage at the test pressure. Verify that the above testing requirements will be met for Limerick. e. Verify that a visual inspection will be conducted during each refueling outage to detect possible Idhkage paths and to check each vacuum relief valve and associated piping to determine that it is clear of foreigh matter. f. Demonstrate that the vacuum relief valve position indicator system has adequate sensitivity to detect a total valve opening, for all valves, that is less than the bypass capability of a small break. The detectable l valve opening should be based on the assumption that the valve opening is evenly divided among a.11 the vacuum breakers. g. Verify that the vacuum breakers will be tested for g operability at monthly intervals.
RESPONSE
l a. No automation of the wetwell spray syst4m is needed. It has been determined for the SBA that the minimum time available to the operator to terminate suppression chamber pressurization by manually activating the (, Rev. 14, 12/82 480.7-2
~ Fzy(2. irdFo OM LGS FSAR wetwell spray system exceeds the SRP 30 minute criterion for operator action.- i The operator will be alerted to the existence of significant ateam bypass leakage by the attendant .drywell pressure increase which the operator will be monitoring as part of the emergency procedures. The L operator will initiate the wetwell spray in accordance with plant emargency procedures which will be based on the BWR Owners Group Emergency Procedure Guidelines (EPGs). These EPGs explicitly consider the possibility of suppression pool bypass leakage in determining spray . initiation points. The BWROG EPGs have been reviewed 'and approved by the NRC (Memorandum for D. Eisenhut (NRC) from R. Matson and H. Thompson sNRC) dated December 9, 1982). , Termination of the wetwell (and drywell) pressure / increase is assured by the operation of only one of the two wetwel,1 sprays, b.1 Assumptions The following assumptions were made i_n perforr.ing the 'd small. break bypass leakage computations to demonstrate conformance to the SRP 30 minute criterion.' a. The steam that. leaks into the wetwell air space does not mix with the air already there. b. No portion of the steam that has leaked into the wetwell air space condenses, c. Only steam leaks into the wetwell; any air moving L from the drywell into the wetwell goes through the i. vents. .d. All of the air initially in the drywell is cleared into the wetwell before the moment when the operator is alerted. [ e. The vents do not refill with water during the time span considered in this procedure. f. The flow of steam through leakage paths is treated as being incompressible. l g. The pressure difference across the leak' age path'"is assumed to be~ constant and equal to the vent submerged hydrostatic pressure difference. 480/7-3 Rev. 22, 07/33
Foe iu ro qt LGS FSAR h. The drywell pressure at which the operator is alerted is 30 psig. i. The wetwell air temperature when the operator is alerted to the occurrence of bypass leakage is assumed to be equal to the initial wetwell temperature (950F). Later, when the drywell / pressure is reduced due to operator action, the wetwell air temperature is assumed to be 500F ~ greater than the initial wetwell temperature, i.e., 1450F. 2 j. MaximumallowableleakageareaA/[E=0.05fta, k. The wetwell air space is saturated at the time of spray initiation. 2, Initial Conditions Drywe1{ Temperature 1350F Drywell Pressure 15.45 psia Drywell Relative Humidity , 20% Wetwell Temperature 950F Wetwell Relative Humidity 100% Drywell Volume '248390 ft8 (HWL) l Wetwell Volume 149425 ft8 (HWL) Vent Submergence 12.25 ft (HWL) 3. Time for Operator Action l. Using the above assumptions and initial conditions, a small break LOCA in the drywell produces a constant drywell-to-wetwell pressure differential equivalent to the vent submergence static head (5.28 psid). The resulting bypass steam flow through the leakage path of A//E = 0.05 fta is 3.'6 lbm/s. The operator becomes l-alerted to the existence of bypass leakage when the i drywell pressure reaches 30 psig. For the drywell i pressure to increase from 30 psig to 55 psig (design L pressure), the corresponding wetwell pressure rise is from 24.72 to 49.72 psig. Therefore, ba' sed on the amount of bypassed steam needed to produce this pressure l rise, the operator has about 31 minutes to complete an action that will terminate the pressure increase. ( Rev. 22, 07/83 480.7-4
_ _ = I e., - s 4. Wetwell Spray Termination Adequacy The following table shows the minimum required spray efficiency as a function of spray temperature. Because the wetwell airspace is saturated when the spray is initiated (this conservative assumption maximizes pressurization at a given temperature), no net evaporation from hot downcomer surfaces will occur ', counteract the spray depressurization effect. The mass flow rate of one spray system is 500 gym. With two - spray systems in operation, the required efficiency would be halved. The spray efficiency is typically on the order of 0.7 and, therefore, even with a single , system is operation, the termination of the wetwell (and
- drywe71) pressure increase is assured.
Required Efficiency of Spray Temperature 1 Wetwell Spray System 700F 0.22 ~ WoF 0.24 1200F 0.28 Table 3.2-1 has been changed to correct the quality c. group classification. d. Section 6.2.6.5.1.and Table 14.2-4 have been changed to . provide the requested information. A visual inspection will be conducted at each refueling e. outage to detect possible drywell-to-suppression bypass l 1eak' age paths. A visual inspection of each primary l contafnment vacuum relief valve assembly will be conducted during each refueling outage to verify that it is clear of foreign matter. f. The vacuum relief valve position indicator system has adequate sensitivity to detect a total valve opening, Pert. ace ' mW for all valves, that is less than the bvoass capability g% 'Wseer g* for a small break,J vp1ve o nin is ete able r \\ [di lif.of 0.0 inches gre er y the alv ($gh >s t. ve ass min the all e v cuu bre ers ce I n 0 6 ch , th corr pon ing eaka e a ea,J )go A/d? i well_ bel w 0. fta.J Therefore, the valve o 3-l Ieakage, which is basea on the assumption that the valve / opening is evenly divided among all the vacuum breakers,[ w '( 3 9 is well within the' limits of acceptable by' pass leakage. g.l g. Vacuum breakers will be tested for operability at an L (* *1 [ interval specified by the technical specifications. E b 480.7-5 Rev. 23, 08/83 l -.,n,.,. -.,-..,.n- . n.n.
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