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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:NRC TO UTILITY
MONTHYEARML20062E0071990-11-14014 November 1990 Forwards List of Unimplemented GSIs at Facility,Per Generic Ltr 90-04 ML20062D6651990-11-0808 November 1990 Ack Receipt of Forwarding Util Evaluation of NRC Inspector General Rept 90N-02 Re Offsite Emergency Planning ML20058G9761990-11-0707 November 1990 Forwards Safety Insp Rept 50-293/90-20 on 900816-1008 & Notice of Violation ML20058C5501990-10-26026 October 1990 Requests Written Policies & Procedures Needed for NRC Preparation for Planned fitness-for-duty Insp ML20062B4311990-10-17017 October 1990 Advises That 901012 Response to Generic Ltr 90-03 Re Vendor Interface for safety-related Components,Acceptable ML20062B7161990-10-12012 October 1990 Extends Invitation to Attend 910220-21 Util Symposium/ Workshop in King of Prussia,Pa Re Engineering Role in Plant Support.Interest to Participate,Intent to Attend & Approx Number of Representatives to Attend Requested by 901115 ML20062B6281990-10-12012 October 1990 Forwards Insp Rept 50-293/90-21 on 900905-07.Insp Conducted to Review Event of 900902-03 Which Involved Number of Component Malfunctions & Operational Complications Following Shutdown ML20059N7251990-10-0101 October 1990 Requests That Matls Listed in Encl Be Furnished to Assist Maint Program Team Insp Scheduled for 901105-16 ML20059K6901990-09-11011 September 1990 Forwards Transcript of 900906 Public Meeting in Plymouth,Ma W/State & Local Officials Re Emergency Planning.W/O Encl ML20059H5871990-09-0101 September 1990 Advises That Reactor Operator & Senior Reactor Operator Exams Scheduled for 901203.Encl Listed Ref Matl Requested ML20059J6521990-08-29029 August 1990 Forwards Safety Insp Rept 50-293/90-09 on 900806-10.No Violations Noted.Concludes That Engineering & Technical Support Organizations Continue to Provide Strong Station Support ML20059A1481990-08-17017 August 1990 Forwards 900816 Summary of 900807 Meeting Re Inservice Testing Program ML20058P0471990-08-0909 August 1990 Forwards Safety Insp Rept 50-293/90-18 on 900709-13.No Violations Noted ML20058N0401990-08-0606 August 1990 Discusses Licensee Engineering Initiatives.Power Reactor Licenses in Region 1 Should Initiate Similar Program to Provide Sharing of Info & Experiences Involving Engineering Initiatives & Solution to Problems Common to All ML20056A4801990-07-30030 July 1990 Forwards Safeguards Insp Rept 50-293/90-16 on 900625-29.No Violations Noted.One Unresolved Item Identified ML20058L7051990-07-27027 July 1990 Forwards Safety Insp Rept 50-293/90-17 on 900625-29.No Violations Noted ML20055F2461990-06-29029 June 1990 Forwards Safety Insp Rept 50-293/90-13 on 900501-0611.No Violations Noted.Repetitive Failures of Diesel Driven Fire Pump Noted,Requiring Increased Mgt Attention ML20059M8421990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20247R8071989-09-21021 September 1989 Forwards SALP Rept 50-293/88-99 for 880516-890630.Instances of Deviation from Approved Practices & Lack of Attention to Detail Which Led to Challenges to Plant Equipment & Personnel Noted ML20247K6661989-09-0707 September 1989 Forwards Insp Rept 50-293/89-07 on 890525-0710 & Notice of Violation ML20246K5091989-08-24024 August 1989 Accepts Summary of QA Program Description Changes for 1989, Forwarded by ML20246L7821989-08-23023 August 1989 Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Failures to Properly Plan, Supervise & Inspect Tagout of Circuit Breakers Directly Contributed to Event IR 05000293/19890071989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20246G1861989-08-18018 August 1989 Approves Reactor Operation Up to 75% of Full Power Per Licensee Power Ascension Test Program.Nrc Findings Docketed in Insp Repts 50-293/89-07 & 50-293/89-08 & Status of Emergency Preparedness for Communities Encl ML20246J4811989-08-18018 August 1989 Clarifies NRC Position Re Definition of Extremity for Purposes of Setting Occupational Exposure Limits.Due to Misunderstanding,No Enforcement Action Planned If Licensee Procedures Incorporated Misunderstanding ML20246D7261989-08-18018 August 1989 Submits Response to Re Plant Power Ascension Program.Util Proposal to Defer Phase 2 of Shutdown from Outside Control Room Test to Planned Fall 1989 mid-cycle Outage Accepted ML20245F1781989-07-31031 July 1989 Forwards Insp Rept 50-293/89-06 on 890411-0524.No Violations Noted.Licensee Actions W/Respect to 890503 Turbine Trip/Reactor Scram Demonstrated Excellent Approach to Problem Investigation & Resolution ML20247D0181989-07-18018 July 1989 Ack Receipt of Re Response to NRC Bulletin 89-003, Inadequate Latch Engagement in Hfa Type Relays Mfg by Ge. Necessary Actions Performed to Address Issues in Bulletin ML20246N3921989-07-14014 July 1989 Forwards Safety Insp Rept 50-293/89-09 on 890619-22.No Violations Noted ML20246D4961989-07-0606 July 1989 Advises That 880713 Response to NRC Bulletin 88-004, Potential Safety-Related Pump Loss Acceptable ML20246A7561989-06-26026 June 1989 Approves Reactor Operation Up to 50% Full Power,Per Util Power Ascension Test Program & Confirmatory Action Ltr 86-10.Assessment of Licensee Readiness for Release from NRC Approval Point 3 & Related Info Encl ML20246B5961989-06-22022 June 1989 Forwards,For Info,Nrr Ack Receipt of Petition Filed by Ecology Ctr of Southern CA & Stating That Petition Being Treated Under 10CFR2.206 of Commission Regulations ML20245A5371989-06-0909 June 1989 Forwards Insp Rept 50-293/89-05 on 890311-0410.Weaknesses Noted Re Evaluation of Failure Rate & Root Causes for Failures of Airlock Doors & Interlocks ML20244C2121989-06-0707 June 1989 Responds to Util 881011 Response to Generic Ltr 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors. Implementation Schedule Contingent Upon Resolution of Procedure ML20244C2751989-06-0606 June 1989 Forwards Draft Safety Evaluation Re Plant Compliance W/ 10CFR50.62, ATWS Rule. Requests Response to NRC Concerns Re Diversity & Testability of Alternate Rod Injection & Reactor Pump Trip Sys NUREG-1275, Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys1989-06-0202 June 1989 Informs That Util Fulfilled Requirements of Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety Related Sys ML20247P5501989-06-0101 June 1989 Forwards Request for Addl Info on Proposed Tech Specs Change Re Visual Insp of High Energy Piping.Listed Concerns Based on Review of Bechtel Calculation 17322-S5,Rev 1 ML20247M2661989-05-26026 May 1989 Forwards Director'S Decision,Ltr of Transmittal & Fr Notice in Response to Ocre 2.206 Petition Expressing Concerns Re 880309 Power Oscillation Event at LaSalle Unit 2 & Request to Reopen Rulemaking on ATWS Issue.W/O Encls ML20246P6051989-05-15015 May 1989 Forwards Notice of Withdrawal of Application for Amend to License DPR-35.Amend Would Modify Tech Specs Re ECCS Surveillance Requirements ML20247D5481989-05-0808 May 1989 Forwards Augmented Insp Team Rept 50-293/89-80 on 890413-19 & 17-26.Team Concluded That Safety Significance of 890412 Pressurization Transient Was Minor,Though Event Raised Concerns Re Proximate Human Factors & Equipment ML20246N7951989-05-0404 May 1989 Forwards Mgt Meeting Rept 50-293/89-04 on 890328-30 W/Commonwealth of Ma & Local Officials ML20247A6911989-05-0303 May 1989 Extends Invitation to Attend Power Reactor Operator Licensing Seminar on 890531 in King of Prussia,Pa.Agenda & Info Re Lodging Arrangements Encl ML20245H8371989-04-26026 April 1989 Forwards SAIC-89/1121, In-Progress Audit Rept of Dcrdr at Boston Edison Co Pilgrim Nuclear Power Station & SAIC-89-1119, In-Progress Audit Rept for Boston Edison Co Pilgrim Nuclear Poser Station Spds ML20245H9551989-04-26026 April 1989 Forwards Insp Rept 50-293/89-01 on 890206-0310 & Notice of Violation ML20245J1441989-04-25025 April 1989 Advises That 880921 & 890302 Responses to NRC Bulletin 88-007 & Suppl 1, Power Oscillations in BWRs Meet Requirements of Both Bulletins ML20244E4611989-04-14014 April 1989 Requests Prompt Review & Reporting of Status of Implementation of TMI Action Plan Items at Facility.Printout of All TMI Items Annotated Where Tracking Sys Indicates That Implementation Not Complete Encl ML20244C2771989-04-10010 April 1989 Informs of Completion of Followup on Plant Regulatory Effectiveness Review Effort & Activities Re TAC 56995. Previous Compensatory Measures Removed as Result of Implementing Corrective Action ML20244A6931989-04-0707 April 1989 Forwards Mgt Meeting Rept 50-293/89-43 on 890309 to Discuss Util Followup Actions to 890304 Reactor Scram ML20244A6281989-04-0303 April 1989 Forwards Insp Rept 50-293/88-37 on 881227-890205.Violation Noted Re Failure to Control Locked High Radiation Area Access ML20235V7311989-03-0303 March 1989 Forwards Safety Evaluation Accepting Revised Temp Profile, Per GE EAS-98-0887, Drywell Temp Analysis for Pilgrim Nuclear Power Station. Profile Requested to Be Documented in Next Updated FSAR 1990-09-11
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20195K3071999-06-15015 June 1999 Forwards Safety Evaluation Granting Licensee Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Water Sys Piping for Plant ML20195K3851999-06-11011 June 1999 Forwards Copy of Notice of Consideration of Approval of Application Re Proposed Corporate Merger & Opportunity for Hearing.Application Seeks Approval of Proposed Indirect Transfer of FOL for Plant ML20196K9921999-06-0404 June 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328.As Part of Reorganization,Division of Licensing Project Mgt Created ML20207E7351999-05-27027 May 1999 Responds to Requesting Reduction in IGSCC Insp Frequency Per GL 88-01 to Be Performed During Upcoming RFO 12.Forwards SE Re Reduction of IGSCC Insp of Category D Welds Due to Implementation of H Water Chemistry ML20207B6341999-05-26026 May 1999 Informs That Licensee 990415 Submittal Re Financial Position of Entergy Intl Ltd,Llc Will Be Marked as Proprietary & Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act ML20207B7391999-05-24024 May 1999 Forwards from Kc Goss of FEMA to Cl Miller Forwarding FEMA Analysis of Prompt Alert & Notification Sys for Pilgrim Nuclear Power Station.Based on Review,No Significant Problems Exist with Alert & Notification Sys ML20207B0701999-05-24024 May 1999 Responds to Sent to Ofc of Congressional Affairs Requesting Info on Concerns Raised by One Constituent,J Riel Re Y2K Compliance of Pilgrim NPP in Plymouth,Ma ML20207C0321999-05-18018 May 1999 Forwards Fifth Rept Which Covers Month of Apr 1999. Commission Approved Transfer of TMI-1 Operating License from Gpu to Amergen & Transfer of Operating License for Pilgrim Station from Beco to Entergy Nuclear Generating Co ML20206U7501999-05-17017 May 1999 Forwards Insp Rept 50-293/99-02 on 990308-0418.Two Severity Level 4 Violations Occurred & Being Treated as NCVs ML20206M1891999-05-11011 May 1999 Forwards SE of 980826 Request to Use Guidance of GL 90-05 to Repair Flaws in ASME Class 3 Salt Svc Sys Piping for Plant ML20206E0551999-04-29029 April 1999 Discusses Bulletin 96-03 Issued on 960506 & Beco Responses ,970207,981230,990121 & 990309 for Pilgrim Npp. Determined That Actions Taken Should Minimize Potential for Clogging of ECCS Suction Strainers ML20206B3031999-04-20020 April 1999 Forwards Insp Rept 50-293/99-01 on 990125-0307.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy.Security Program Was Also Inspected ML20205Q9491999-04-0909 April 1999 Informs That on 990225 NRC Staff Completed PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205B9391999-03-24024 March 1999 Forwards Second Request for Addl Info Re GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves ML20204C7871999-03-17017 March 1999 Informs That Application Submitting Transfer of Facility Operating License & Matls License & Proposed Amend, Will Be Marked as Proprietary & Be Withheld from Public Disclosure Pursuant to 10CFR2.709(b)(5) ML20199K8321999-01-22022 January 1999 Forwards Request for Addl Info Re Transfer of Facility Operating License for Plant ML20199H5811999-01-20020 January 1999 Submits Exemption Withdrawal of 10CFR70.24(a) Re Criticality Accident Monitoring Requirements ML20198L7781998-12-22022 December 1998 Forwards Insp Rept 50-293/98-10 on 981020-1208.No Violations Noted.Nrc Regional Specialists Reviewed EP & Fire Protection Programs.Ep Program Was Found to Be Well Implemented ML20198J0891998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Senator Kerry Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20198J1041998-12-21021 December 1998 Forwards NRC Response to Me Lampert Re Transfer of Ownership of Pilgrim Station in Response to Congressman Markey Ltr Dtd 981019.NRC Will Terminate License Only When Licensee Remediates Site to Levels Specified in Regulations ML20137T2211998-12-17017 December 1998 Responds to to Chairman Jackson Re Concerns About Possible Sale of Pilgrim Station & Waste Disposal Issues.No Application for License Received Nor Contract of Sale Between Beco & Entergy.Record Copy ML20198J1161998-12-17017 December 1998 Responds to to Chairman Jackson in Which Recipient Expressed Concern About Possible Sale of Pilgrim Station & About Waste Disposal Issues.Nrc Has Not Received Application for Transfer of License to Date ML20198P2781998-12-17017 December 1998 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety.App B Records Being Withheld in Entirety (Ref FOIA Exemption 4) ML20198B2021998-12-0909 December 1998 Advises of Planned Insp Effort Resulting from Licensee Irpm Review.Details of Insp Plan for Next 6 Months & Historical Listing of Plant Issues Encl ML20197H8521998-12-0909 December 1998 Responds to Ltr Sent to Chairman SA Jackson on 981028 Re Concern That NRC Will Not Perform Environ Assessment in Connection with Consideration of Approval of Transfer of License for Plants to Permit Sale ML20196J1201998-12-0404 December 1998 Ack Receipt of 971217 & 30 & 980112,0309,0423 & 0630 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-293/97-02,50-293/97-11,50-293/97-13, 50-293/97-80 & 50-293/98-01.Actions Found Acceptable ML20196B5421998-11-24024 November 1998 Forwards Plant SRO & RO Initial Exam Rept 50-293/98-301OL During Wk of 981016-23 ML20196F7631998-11-24024 November 1998 Forwards Insp Rept 50-293/98-203 on 980928-1023.No Violations Noted.Three Issues Identified Re Containment Flooding,Surveillance Testing Criteria & Protection for RBCCW System from High Energy Line Break Inside Drywell ML20196C1191998-11-20020 November 1998 Forwards Insp Rept 50-293/98-08 on 980907-1019.No Violations Noted.During Insp Period,Chemical Decontamination of Residual Heat Removal Sys Was Well Planned & Implemented Which Reduced Radiation Doses in Heat Removal Quadrants ML20195H7361998-11-16016 November 1998 Informs of Individual Exam Results for Applicants on Initial Exam Conducted on 981016 & 981019-23 at Facility.Nine Applicants Were Administered Exam & Nine Passed.Licenses Issued & Individual Test Results Encl.Without Encl ML20155C4781998-10-29029 October 1998 Forwards RAI Re Resoultion to GL 96-06 Issues at Plant,Unit 1.Response Requested by 981130 ML20154J7881998-10-0808 October 1998 Authorizes Mb Santiago to Administer Initial Written Exams to Applicants Listed (Except Applicants Redlined), on 981016.NRC Region I Operator Licensing Staff Will Administer Operating Tests During Week of 981019 1999-09-30
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January 23, 1986 Docket No. 50-293 Mr. William D. Harrington Senior Vice President, Nuclear Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Harrington:
SUBJECT:
MODIFICATION OF VACUUM BREAKERS ON MARK I CONTAINMENTS (GENERIC LETTER 83-08)
Re: . Pilgrim Nuclear Power Station By letter dated May 13,-1983 you responded to Generic Letter 83-08 dated' February 2,1983. We are continuing the review and find that we need the information requested in the enclosure to this letter in order to complete our review regarding the vacuum breakers. Please respond to this request on a schedule to be negotiated with your project manager. I would like to see this issue fully resolved as expeditiously as possible and therefore recommend you provide a timely response.
This request for information was approved by the Office of Management and Budget under clearance No. 3150-0011. Coments on burden and duplication -
may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D.C. 20503.
Sincerely, p .u..on John A. Zwolinski, Director BWR Project Directorate #1 Division of BWR Licensing
Enclosure:
As stated cc w/ enclosure:
See next page
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DISTRIBUTION Docket EJordan NRC PDR BGrimes Local PDR JPartlow PD #1 RDG- PLeech 9601280260 e60123~
RBernero CJamerson DR ADOCK 05000293 p
OELD ACRS (10) PDQ Pilgrim File DVassallo .
FEtlawila WLong DBL:PD#1 DBL: DBL:PD#1 CJamerson Pleecn:Jg JZwolinski
[ /p./86 1/M/86 i /4,/86
Mr. William D. Harrington
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Boston Edison Company Pilgrim Nuclear Power Station cc:
Mr. Charles J. Mathis, Station Mgr.
Boston Edison Company RFD #1, Rocky Hill Road Plymouth, Massachusetts 02360 Resident Inspector's Office U. S. Nuclear Regulatory Commission Post Office Box 867 Plymouth, Massachusetts 02360 Mr. David F. Tarantino Chairnan, Board of Selectman 11 Lincoln Street Plymouth, Massachusetts 02360 Office of the Commissioner Massachusetts Department of Environmental Quality Engineering One Winter Street Boston, Massachusetts 02108 Office of the Attorney General 1 Ashburton Place 19th Floor Boston, Massachusetts 02108 Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health -
150 Tremont Street Boston, Mhssachusetts 02111 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. A. Victor Morisi Boston Edison Company 25 Braintree Hill Park Rockdale Street Braintree, Massachusetts 02184 l
l l
Request for Additional Information Related to the Modification of Vacuum Breakers on Mark I Containment Pilgrim Nuclear Power Station The results of the staff review of the Pilgrim Station torus-to-drywell vacuum breaker modification identified several areas where further information is needed before the staff can complete its review. These areas summarized below were delineated in the staff's generic evaluation of the methodology proposed to predict vacuum breaker valves opening and closing impact velocities, letter from D. Vassallo to H. Pfefferlen, dated December 24, 1984 (copy attached).
- 1. Is the chugging source rate used in the BSEP evaluation the same as the one developed in CDI Report (#84-3)? If not the same, provide the chugging source rate with the supporting justification.
- 2. Did the BSEP. calculation apply the 1.07 load factor to account for the uncertainty in calculating the underpressure (Section IV of the staff's generic evaluation).
- 3. Have the BSEP calculations used the drywell model which results in the most conservative prediction (Section V of the generic evaluation)?
. g[
'/ (g UNITED STATES NUCLEAR REGULATORY COMMISSION a wAsunciow. o. c. 20sss
}' \...../ December 24, 1984 A'TTACHMENT T0 REQUEST FOR ADDITIONAL INFORMATION i
a Mr. H. C. Pfefferlen, Manager BWR Licensing Programs General Electric Company 175 Curtner Avenue, MC 682 San Jose, California 95125
Dear Mr. Pfefferlen:
SUBJECT:
EVALUATION OF MODEL FOR PREDICTING DRYWELL TO WETWELL VACUUM BREAKER VALVE DYNAMICS The staff issued Generic Letter 83-08 dated February 2,1983, to all applicants and licensees of plants with Mark'I containments reouesting .
submittal of information related to a potential failure mode of the
. drywell-to-torus vacuum breakers during the chugging and condensation oscillation phases of a loss-of-Coolant Accident (LOCA). As stated in the generic letter, this issue was discovered at the time the generic phase of the Mark I Containment Long-Term Program was near completion, however, the
- Mark I Owners Group comitted to resolve this issue although not necessarily as part of the NUREG-0661 Long Tem Program.
To resolve the generic aspects of this issue the following reports were
' prepared by Continuum Dynamics Inc. (CDI) for the General Electric Company and the Mark I Owners Group:
CDI TECH NOTE 82-31 " Mark I Vacuum Breaker Improved Dynamic Model -
Model Development and Validation" transmitted by your letter dated October 28, 1982 -'
l l CDI Report No. 84-3, " Mark I Wetwell to Drywell Vacuum Breaker Load Methodology" transmitted by your letter dated March 2, 1984 These reports describe the models to be used to compute the vacuum breaker valve response to chugging and condensation events in Mark I plants.
Based on our review of these reports and the additional infomation provided in your letters dated September 26, 1984 and November 6, 1984, we have concluded that the valve dynamic model conservatively predicts the opening and closing velocities for the valve and, therefore,'is acceptable for use in the analyses and/or qualification of Mark I wetwell-to-drywell 99 1
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, 1 4 . o Mr. H. C. Pfefferlen i l
vacuum breaker valves subject to the restrictions set forth in Section V of i the enclosed Safety Evaluation (SE). l Sincerely, l
l omenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing
Enclosure:
As stated D
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E NUCLEAR REGULATORY COMMISSION teASHINGTON. D. C. 30555 e...e .
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON THE ACCEPTABILITY OF THE ANALYTICAL MODEL FOR PREDICTING VALVE DYNAMICS
- 1. Introduction
' Mark I containments are equipped with simple check valves to serve as vacuum breakers to equalize any overpressure of the wetwell air space region relative to the drywell so that the reverse direction differential pressure will not
- exceed the design value. In general, the vacuum breakers will swing open when the wetwell air space pressure is 0.5 psi (or more) greater than the vent. header pressure. Typical vacuum breaker arrangements for the Mark I plants are shown in
~
Figure 1. As shown, internal vacuum breakers are located on the vent pipes, and external vacuum breakers are located in a supplementary piping system.
' - - Following the onset of a loss;of-coolant accident (LOCA) and during the chugging phase, caused by the rapid condensation of the steam at the vent exit, the s
vacuum breaker.may be called upon to function in a cyclic manner. This is due t3 the fact that the chugging phenomenon is repeate'd on the average every two i
seconds ca'using strong dynamic underpressure conditions in the vent pipe, which depending on the chug strength may open the vacuum breaker with high velocity. The underpressure condition which normally lasts for about 5 msee is followed by a dynamic overpressure condition, which again depending on the strength of the chug, may close the vacuum breaker with high velocity.
Failure of a vacuum breaker to reclose could result in a pathway for steam bypass of the pool, thus jeopardizing the integrity of the con}tainment.
. 1 l
1 I II. Background During the Mark I Full Scale Test Facility (FSTF) containment ~ loads program, a GPE wetwell to drywell vacuum breaker was observed to cycle. Inspection of the valve after Test MI, which had the highest opening velocity, revealed that ,
the pallet hinge was bent, the latching magnet was broken and indentation was observed in the valve casing which suggested that the pallet opened fully during the test. In other tests, there also was observed damage but it was limited to
[ the pallet sealing gasket. MI was the only test in the FSTF test series which
~
had fully opened the vacuum breaker. 'Having presented the test results it should be noted that the actuation velocities sustained in the FSTF test program are not considered to be prototypical. The results are considered very conservative because the drywell volume in the FSTF is much smaller than any domestic Mark I plant. For this reason, it was concluded in CDI report #84-3, that opening impacts and hence the vacuum breaker damage observed in test MI, are i
not anticipated in domestic Mark I plants.
III. Sundary of the Topical Reports Report CDI #82-31 describes the methodology used to predict the drywell to wetwell vacuum breaker cycling velocities, particularly when and if the valve disk strikes the full open stop or seat. Since the location of vacuum breakers vary from plant to plant, a need exists to quantify the ring l
header /wetwell pressure fluctuations for plant unique application. ..CDI report
- 84-3 describes an analytical model to extract condensation source time
I
- 3- . i I
histories from the FSTF test facility. After transferring these condensation sources to a model of an actual Mark I plant, the analytical model would compute the pressure time history across the disk of the vacuum breaker.
Figure 2, extracted from CDI report 84-3, provides the steps followed to determine the plant unique vacuum breaker forcing functions.
III.1 _ Valve Dynamic Model Verification 7 The dynamics of the vacuum breaker, described in CDI report 82-31, is simulated in terms of the hydrodynamic torque about the valve shaft. This "
torque is as a consequence of a differential pressure across the valve disk.
g During run #S-DA of the FSTF tests, the vacuum breaker was instrumented such I
b that the valve displacement and pressure differential across the valve disk were recorded. This information was used to verify the valve dynamic model as follows. .By driving the valve dynamic model with the measured differential t
pressure across the valve from test iS-DA, predictions of valve displacement
~
versus time were made and compared against the measured data from the same FSTF run #S-DA.
The results of this comparison indicated that the predicted impact velocities were greater than the experimental values by an average factor of more than
- 21. This extreme conservatism was attributed to the fact that the valve dynamic model did not account for the reduction in the hydrodynamic torque as I
a result of the reduced static pressure across the valve disk due to flow computations. A parametric study was performed to reduce this
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- 4-I conservatism. The result was the development of a conservative yet realistic i
valve dynamic model described in CDI report #82-31. Comparison of the predicted valve impact velocities based on the improved model still bounded all test impact velocities with approximately a 12% margin.
It was, therefore, concluded in the CDI report #82-31 that the valve dynamic model is appropriate for the analysis and/or qualification of Mark I wetwell to drywell vacuum breaker.
III.2 Vent Dynamic Model Verification .
The model descri. bed in CDI report #B4-3 was developed to allow the development (rk- -
_ of unsteady condensation rate at the vent exit from the measured FSTF drywell pressure. A transfer function was developed which translates the condensation source at the vent exit to a pressure at any location in the vent system.
The pressu*re time history measured in the drywell was used with the transfer -
function to deduce the condensation rate at the vent exit. This source was then used with the transfer function to predict the unsteady pressure at a
-location in the vent header where measurements were taken. The comparisons between the measured and predicted pressures were favorable and, therefore, it was concluded that the transfer function model c'ntains the essential elements required to predict pressure oscillations in Mark I steam vent systers. Since the condensation rate is fixed by local conditions at the vent exit, i.e.,
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i steam mass flow rate, noncondensibles and thermodynamic conditions, these conditions would only vary slightly between plants and, therefore, the condensation rate / source thus developed can be used in any Mark I facility to predict the unsteady pressure at the prescribed location of the vacuum breaker.
III.3 Selection of the Condensation Source
- The FSTF test data were screened to determine the chugging events that produced the most severe actuation of the vacuuti breaker, i.e., large impact
~
velocities. Over 1000 seconds of chugging data were recorded in which 400 distinct chug events actuated the vacuum breaker 179 times. Three runs were
'{ noted to have significant chugging: runs M1, M4 and M9. Data from these runs
,~ were used to drive the vacuum breaker valve described in Section 111.1 to ;
determine the maximum impacts of the valve disk on the body and the seat of i the valve. It was detennined by CDI that the time interval 65.9-105.9 seconds j of run M1 would bound all FSTF data including those that caused the valve
- damage in test' M1; therefore, the 65.9 to 105.9 seconds time interval was chosen to determine the condensation rate as described in Section III.2 IV. Plant Unique Application i
The transfer function discussed in Section 111.2 is modified for plant unique application by inputting the 1) drywell volume / total vent area, 2) ' pool submergence and 3) damping due to external piping length (for the six Mark I i
plants that have external vacuum breakers). The condensation rate discussed i
1
in Section 111.3 is used with the plant unique modified transfer function to compute the pressure on the vent side of the vacuum breaker disk and the wetwell air space pressure. A ' sensitivity study of the vent dynamic model demonstrated that the wetwell air space pressure is insensitive to the wetwell air space volume. (Pool pressure coefficient in response to question 4 represents the wetwell air space volume in the sensitivity study). Therefore, this volume is not considered as a plant unique input in the model.
_ These two pressures are then subtracted, multiplied by a load factor of 1.07 (to account for uncertainty in calculating the underpressure) and applied across the vacuum breaker valve dynamic model discussed in Section III.1 to obtain disk actuation velocities.
(" ' .
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I V. Staff's Evaluation and Recommendation During the review of the information presented in the CDI reports, the staff expressed concern on weather the damage sustained to the valve installed on the FSTF could* occur in domestic' Mark I plants. The ' staff also expressed concern that using the methodology, no opening impacts were anticipated in Mark I plants even though the valve that was installed on the FSTF had an opening impact during test M1.
In response to these concerns, CDI stated that the vacuum breaker response in the FSTF was not prototypical and is very conservative. This is due to the fact that the drywell volume / total vent area ratio in the FSTF is much smaller than any domestic Mark I plant. CDI contends that this ratio has a significant
)
1
. 7-l influence on the pressure oscillation in the ring header and in turn, .an influence on the load across the vacuum breaker. To illustrate this point. CDI provided the results of analyses which showed that the vent pressure monotonically decreases with increasing.drywell volume / vent area ratio. The calculated load across the vacuum breaker would also decrease as this ratio increased. Based ,
on the above, CDI concluded that the large opening impact velocities and valve damage experienced during the FSTF test M1 are unlikely to occur in any domestic Mark I plant.
~
Based on our review of the methods and assumptions described in the CDI reports, and the response to the request for additional infonnation (RAI),
{ we conclude that the valve dynamic model conservatively predicts valve opening
. and closing velocities and, therefore, is acceptable for use in the analysis and/or qualification of Mark I wetwell to drywell vacuum breakers subject to the following restrictions:
- 1. The p1 ant unique loads 'are to be computed using one of two drywell models which result in the most conservative prediction. One model examined by i
CDI represents the drywell by a capacitance in the vent dynamic model as
- discussed in Section 111.2. The other model divides the drywell into two l
cylinders; treating each volume as an acoustic circuit in the vent dynamic
- model;
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- 2. The value of all plant unique parameters inputted to the models to obtain plant-unique wetwell to drywell vacuum breaker load definitions should be provided with the results; and
- 3. Any plant-unique deviations of the methodology and/or assumptions that were found acceptable in this report should be identified. Additionally, the rationale and justification for the proposed alternative method and/or assumptions should be provided. Justification should include the identification of the conservatism associated with the deviation.
Principal Contributor: F. Eltawila Dated: December 24, 1984 r -
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REFERENCES
( 1s CDI TECH NOTE S2-31. " Mark I Vacuum Breaker Improved Dynamic Model -
Model Development and Validation."
- 2. CDI Report No. 84-3. " Mark I Wetwell to Drywell Vacuum Breaker Load Methodology."
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INTERNAL M" VActMN TO DRMELL
. BREAKER MAIN VENT I- [
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i Tigure 1 Mark I Vactus Breaker Location n.-- . , , . , , , _ , , - . , , - - . - - - - _ , . - - _._,7, , , , , , , , _ _ _ . _ _ . - - _ - _ _ - ___._a,.,,- . . , , ,---e , ,,., .,,, ,,,- ._ w..
o STEP Develop a dynamic model of the vent system, steam water inter-1 face and pool slosh with the condensation rate at the inter-face unkncun.
- p .
Use measured dryvell pressure to 2 determine the condensation rate. -
o With-the condensation rate l ( l, 3 deter =ined, predict unsteady L pressures at other vant locations to validate the model.
l -
1 Use the condensation source at the vent exit to drive dyns=ic 4 models of Mark I plants to
- determine unique vacuum -
breaker forcing functions.
. Figure 2 steps in determining plant unique vacuum braaker i forcing functions I
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