ML20151X848
| ML20151X848 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/11/1998 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20151X850 | List: |
| References | |
| GL-97-04, GL-97-4, IEB-96-003, IEB-96-3, NUDOCS 9809170274 | |
| Download: ML20151X848 (15) | |
Text
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Station Support Department
_ GL 97-04 PECO NUCLEAR esco cee<ov cemneev 965 Chesterbrook Boulevard
- A Unit of PECO Energy wayne.PA 19087 5691 September 11,1998 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Response to Requests for Additional Information Concerning Bulletin 96-03," Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors," and Ge 'eric Letter 97-04," Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling and Containment Heat Removal Pumps"
Dear Sir / Madam:
This letter is being submitted in response to NRC letters dated August 14,1997, and August 14, 1998, requesting additional hJormation regarding the use of containment overpressure for ensuring adequate Net Positive Suction Head (NPSH) for the Emergency Core Cooling System (ECCS) pumps at Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.
Accordingly, the attachments and enclosures to this letter provide PECO Energy's response to the specific issues / questions identified by the NRC in its letters dated August 14,1997, and August 14,1998. Attachment 1 contains background information with regard to Bulletin 96-03 and Generic Letter 97-04 and the use of containment overpressure. Attachment 2 contains information in response to the NRC's letter dated August 14,1997, and includes a restatement of each specific question identified by the NRC followed by our response. Attachment 3 contains information in response to the NRC's letter dated August 14,1998, discussing the use of containment overpressure as it relates to our response to GL 97-04 and the current licensing basis for PBAPS. Enclosures 2-4 contain the associated calculations regarding the minimum containment pressure and NPSH for the RHR and CS systems' pumps. This letter is being submitted under affirmation, ard the required affidavit is provided in Enclosure 1 of this letter.
Information contained in this letter updates information previously submitted in our letter dated May 5,1997, requesting license amendments for PBAPS with regard to the debris generation methodology developed in response to Bulletin 90-03. As a result, PECO Energy plans to re-submit relevant updated information supporting the no significant hazards consideration (i.e.,
j 10CFR50.92) for the license amendments to reflect the information contained in this letter.
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9909170274 980911 ADOCK O g 2 7 ,
P,DR . _
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1 y September 11,1998
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l' If you have any questions or require additional information, please do not hesitate to contact us.
' Very truly yours, L'
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-nf arrett D. Edwards
- Director- Licensing Attachments Enclosures -
cc: H. J. Miller, Administrator, USNRC, Region 1 (w/ attachments / enclosures)
A. C. McMurtray, USNRC Senior Resident Inspector, PBAPS (w/ attachments / enclosures)
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4 ATTACHMENT 1 Peach Bottom Atomic Power Station Units 2 and 3 Response to Request for Additional Information Conceming Bulletin 96-03 and Generic Letter 97-04 Background information 1
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Attachment 1 Page 1 of 2 September 11,1998 Peach Bottom Atomic Power Station, Units 2 and 3 Background Information Related to Bulletin 96-03 and Generic Letter 97-04 Backaround By letter dated August 14,1997, the NRC requested additional information regarding PECO Energy's request for license amendments to Facility Operating License Nos. DPR-44 and DPR-56 for PBAPS, Units 2 and 3, regarding the implementation of ECCS pump suction strainer modifications. PECO Energy requested the license amendments by letter dated May 5,1997, in order to facilitate implementation of a plant modification to install new large-capacity, passive, pump suction strainers on the ECCS. The request was submitted in accordance with the requirements of 10CFR50.59 and 10CFR50.90.
The replacement strainers are being installed in response to NRC Bulletin (NRCB) 96-03, " Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors," which was issued on May 6,1996. NRCB 96-03 requested that licensees implement appropriate procedural measures and plant modifications to minimize the potential for clogging of ECCS suppression pool pump suction strainers by debris generated during a Loss-of-Coolant-Accident (LOCA). The NRC requested that licensees implement the actions identified in this Bulletin by the end of the first refueling outage starting after January 1,1997.
PECO Energy responded to Bulletin 96-03 for PBAPS, Units 2 and 3, by letter dated November 1,1996.
In our response, we indicated that a plant modification would be implemented to install replacement strainers on ECCS pump suction piping, with the exception of the High Pressure Coolant Injection (HPCI) system.
The new strainers were installed on the Unit 3 Residual Heat Removal (RelR) and Core Spray (CS) systems' pump suction piping in the Torus during refueling outage 3R11 completed in October 1997. The new strainers will be installed on the Unit 2 RHR and CS systems during refueling outage 2R12 scheduled for October 1998. Final resolution of the actions associated with NRCB 96-03 (i.e., revision of the plant licensing basis to include the new debris generation loading assumptions) was extended until December 31,1998, as documented in an NRC letter to PECO Energy dated October 21,1997.
As a result of the NRC's review of the information provided in our letter dated May 5,1997, several additional issues were identified for which the NRC requested supplemental information in order to complete its review. Specifically, in the August 14,1997 letter, the NRC requested additional information regarding minimum NPSH requirements associated with the RHR and CS pumps and use of containment overpressure. As a result of the NRC's request for additional information, PECO Energy undertook efforts to re-evaluate the NPSH requirements for the ECCS pumps. This included a re-analysis of the methodology used to establish minimum post-LOCA containment pressures when PBAPS, Units 2 and 3, were uprated in power de 1994 and 1995. PECO Energy had a number of subsequent discussions with the NRC relative tc ne 'ysis performed during the Power Rerate effort and NPSH requirements.
In addition. shortly after s ust 14,1997, letter was issued, the industry became aware that the NRC was planning to issue Gs ;nc Letter (GL) 97-04," Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling and Containment Heat Removal Pumps."
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Attachment 1 Page 2 of 2 l September 11,1998 l
l On October 7,1997, the NRC issued GL 97-04 requesting that licensees provide the information outlined l below relative to NPSH requirements.
. Specify the general methodology used to calculate the head loss associated with the ECCS suction strainers.
. Identify the required NPSH and the available NPSH.
Specify whether the current design-basis NPSH analysis diffe.s from the most recent analysis reviewed and approved by the NRC for which a safety evaluation was issued.
Specify whether containment overpressure (i.e., containment p'ossure above the vapor pressure of the sump or suppression pool fluid) was credited in the calculation of available NPSH. Specify the amount of overpressure needed and the minimum overpressure available.
When containment overpressure is credited in the calculation of the available NPSH, confirm that an appropriate containment pressure analysis was done to establish the minimum coritainment pressure.
PECO Energy responded to GL 97-04 for PBAPS, Units 2 and 3, by letters dated November 4,1997, and l December 30,1997, indicating that, consistent with the plant's licensing basis, cuaainment overpressure was required to meet ECCS pump NPSH requirements.
l l Subsequently, by letter dated August 14,1998, the NRC requested additional information legarding PECO Energy's response to GL 97-04 for PBAPS, Units 2 and 3. Specifically, the NRC identified a concern associated with the use of containment overpressure, in that, the amount of containment overpressure currently credited may be greater than the overpressure previously approved by the NRC. The NRC requested that PECO Energy respond within 30 days of receipt of the August 14,1998 letter, discussing i how our response to GL 97-04 for PBAPS relating to containment overpressure compares with our current licensing basis.
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i ATTACHMENT 2 Peach Bottom Atomic Power Station Units 2 and 3 Response to Request for Additional Information Dated August 14,1997, Concerning Bulletin 96-03 i
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Attachment 2 Page 1 of 3 September 11,1998 Peach Bottom Atomic Power Station, Units 2 and 3 Response to Requests for Additional Information Concerning Bulletin 96-03 The following information is being provided in response to questions identified by the NRC in its August 14,1997, letter pertaining to the license amendment requests submitted in support of the resolution of Bulletin 96-03. Each question is restated below followed by our response.
As documented in the NRC's October 21,1997 letter (referenced in Attachment 1), PECO Energy would complete actions associated with changing the licensing basis to account for greater suction strainer debris loading, such that the actions associated with NRCB 96-03 could be resolved for PBAPS, Units 2 and 3, by the end of 1998. The following responses and calculations (Enclosures 2-4) are provided to facilitate this closure.
Question
- 1. Did you submit net positive suction head (NPSH) calculations to the staff during the power rerate review? If so, please provide the NPSH calculations submittal date.
! Response ECCS system NPSH calculations were not submitted to the NRC during the Power Rerate review. A discussion of the key containment parameters (i.e., pressure and temperature) and a summary of the results of NPSH calculations were provided to the NRC in response to RAl-6 in our letter dated July 20, 1994. It should be noted, however, that the rerate NPSH calculations are not applicable to the suction strainer replacement. These calculations were based on the General Electric (GE) containment analysis which did not account for the effects of drywell leakage and sprays, nor did the calculations address new debris generation methodology developed in response to Bulletin 96-03. The Power Rerate analysis was discussed with the NRC (i.e., NRR Containment Systems Branch staff) during a meeting held on
! September 15,1997.
Question
- 2. Please provide NPSH calculations, if you did not previously submit the NPSH calcula.' ions to the l NRC. The calculations shouldinclude the working equation used to calculate NPSH, the NPSH l required and available. and all assumptions and losses considered. Provide a time-dependent NPSH-required versus NPSH-available curve, if available. This curve would be similar to the I curves that Dresden, Pilgrim, and Monticello licensees recently provided to the NRC.
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Response
The NPSH calculations for the PBAPS, Units 2 and 3, Residual Heat Removal (RHR) and Core Spray
- (CS) systems are provided in Enclosure 3 and 4. The minimum containment pressure analysis is provided in Enclosure 2, which provides information depicting time-dependent curves for NPSH available and NPSH required. Several points should be noted when reviewing /using these calculations.
a) The NPSH calculations submitted have been revised to account for the new, large-capacity strainers, new debris generation loading, and the effects of containment sprays and leakage on containment
- overpressure. The NPSH margin cited in our original submittal dated May 5,1997., ( l.e.,9.6 feet for
( RHR and 8 feet for CS) did not include the head losses associated with the new strainers, and did not account for the effects of containment sprays and leakage on containment overpressure .
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Page 2 of 3 September 11,1998 l
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b) The revised calct ations contained in the Enclosures account for theTorus water temperature at which the limiting NPSH is reached. This is 205.7'F, which assumes a maximum Service Water i temperature of 90*F, and an RHR system flow of 10,000 gpm for Torus cooling. The maximum Torus water temperature used in the Power Rerate analysis was 208'F, which assumed a degraded RHR system flow rate of 7,600 gpm for Torts cooling. However, due to the reduced system lossos and lower required NPSH associated with bwer flow rates, the higher Torus temperature (i.e.,208'F) case I was not bounding for NPSH consiev&ons. Our original submittal dated May 5,1997, referenced a Torus water temperature of 213*F. Huever, this analysis was based upon a Service Water temperature of 95'F, which is above the Technical Specifications (TS) limit of 90*F for PBAPS, Units 2 and 3. This constitutes a conservatism in the Power Rerrw analysis, c) The Torus water temperature at which the limiting NPSH is calculated is based on a power level of 3696 Mwm. The actuallicensing analysis power level for Power Rerate is 3528 Mw..
Question
- 3. In the Current Design Basis section of your May 5,1997, letter, you indicated that the "The available margins for the RHR and CS pumps are currently defined as 9.6 feet for RHR and 8 feet for CS with system flow rates of 9500 gpm for RHR and 3125 gpm for Core Spray." This margin does not appear to be consistent with the margins discussed in your July 20,1994, letter responding to staff Requests for AdditionalInformation. Response 2 of your July 20,1994, letter indicates that "the NPSH margin for the RHR pumps was reduced from 8.8 feet for the current conditions to 8.1 feet for power rerate. The NPSH margin for the core spray pumps was reduced from 9.9 feet for the current conditions to 9.2 feet forpower rerate " Please explain the discrepancy between these two letters.
Response
The NPSH margins referred in our May 5,1997 submittal, and the margins discussed in our July 20,1994 letter, were both based on a Torus pressure of 23.8 psia. This value was based on an analysis performed by General Electric (GE)in support of the PBAPS Power Rerate effort. The NPSH margin identified in the July 20,1994 letter, was computed by GE for Power Rerate using information from their design files. The margin listed in the May 5,1997 letter, was computed by PECO Energy in our plant specific NPSH calculations. The differences between the NPSH margins listed in our July 20,1994, and May 5,1997 letters, result from differences in the design inputs used to compute the margins. For example, flow losses were refined and peak Torus temperature was changed. In addition, these analyses did not account for the use of drywell sprays and leakage.
Our current analysis, which is provided in Enclosures 2-4, includes the effects of both sprays and leakage, and results in a maximum Torus pressure of 22.1 psia. Therefore, the values indicated in the above question are not applicable to our current analysis.
Question
- 4. In the NPSH Margin section of your May 5,1997, letter, you indicated that " ..the proposed design basis for sizing the new replacement strainers is to limit the head loss of fully fouled strainer to 2 I feet less than the NPSH margin for each ECCS pump for those accident conditions specified l above." What amount of containment overpressure credit does this reduction in margin relate?
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Attachment 2 Page 3 of 3 September 11,1998
Response
Although no margin is required for NPSH, the current analysis for sizing the new strainers limits the head loss of a fully fouled strainer to 2 feet less than the available NPSH margin for the RHR and CS pumps under design basis LOCA conditions assuming the maximum combined insulation and corrosion product debris load. This margin is intended to offset ma;iufacturing tolerances and differences in piping configurations. This amount of margin equates 9 approximately 0.8 psi of containment overpressure at the expected maximum Torus temperature of 205.7 F. The total amount of NPSH rnargin for RHR is 3.2 feet and 6.7 for CS based on the calculations contained in Enclosures 3-4. The analyses also conclude that in the extremely unlikely event a LOCA would occur during containment purging, there would be a reduction in available NPSH margin, but sufficient margin would still exist. Specifically, the NPSH margin for RHR would be reduced from 3.2 feet to 1.4 feet, and the NPSH margin for CS would be reduced from 6.7 feet to 4.6 feet.
l The maximum containment pressure in our current analysis is 22.1 psia, at the maximum Torus temperature (i.e.,205.7 F), which occurs approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> into the DBA LOCA event. Lower amounts of owpressure will be required during the transient as depicted on the minimum containment pressure profile curve in Enclosure 2. This analysis assumes that drywell sprays are activated at the start of the event, and that cooling water to the RHR hea' exchangers is established at 10 minutes following the accident. The analysis also assumes drywellleakage at a rate of 0.5% per day.
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i ATTACHMENT 3 Peach Bottom Atomic Power Station -
' Units 2 and 3 l l
Response to Request for Additional information l Dated August 14,1998 Conceming Generic Letter 97-04 l
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Attachm:nt 3 Page 1 of 3 September 11,1998 Peach Bottom Atomic Power Station, Units 2 and 3 l Response to Request for AdditionalInformation Concerning Generic Letter 97-04 The following information is being provided in response to the NRC's letter dated August 14, 1998, requesting that PECO Energy provide additional information with regard to our response to Generic Letter 97-04 for PBAPS, relating to the use of containment overpressure, and how this compares to our current licensing basis. In order to clearly respond to this request for ,
information, this response will summarize the evolution of the PBAPS licensing basis from the I original plant licensing through the current licensing basis up to the configuration that will exist at x the end of 1998 when NRCB 96-03 closure is expected to be achieved.
Oriainal Licensina Basis The originallicensing basis credited containment overpressure for meeting ECCS pump NPSH requirements. Specifically, in response to FSAR Ouestion 6.3, an analysis was performed which showed that adequate NPSH would be available for meeting ECCS pump performance requirements. This analysis also showed that there was some margin between the available NPSH and what was required for the pumps. The analysis assumed several conservatisms (e.g., Service Water temperature remains at its maximum possible value of 90 F throughout the transient, the RHR heat exchanger is operating with its design fouling factor, etc.). The NRC reviewed the information provided in response to FSAR Ouestion 6.3, as documented in its Safety Evaluation Report (SER) dated August 11,1972. There was no specific value or limit for containment overpressure identified by the NRC in its SER. The NRC indicated that: "..the applicant has fumished an analysis based on conservative design assumptions showing that a positive NPSH margin would be available following the accident, however, the analysis assumes that containment pressure created by the LOCA is available for assuring the required NPSH."
Power Rerate By letter dated June 23,1993, PECO Energy submitted license amendment requests for PBAPS, Units 2 and 3, in support of the Power Rerate effort. The Power Rerate analysis assumed the use of containment overpressure for meeting ECCS pump NPSH requirements and determined that margin exists between the minimum containment pressure available and that required. The basis for crediting containment overpressure is contained in the Power Rerate engineering report which was prepared by General Electric (GE), and is based on the minimal point on the containment design containment pressure curve (i.e.,23.8 psla). This report was submitted to the NRC in conjunction with the license amendment requests, by letter dated June 23,1993. The use of containment overpressure for ensuring adequate NPSH for the ECCS pumps for rerate conditions was the subject of additional correspondence as discussed in our letter to the NRC dated July 20,1994 (i.e., response to RAl-6). The NRC subsequently approved the license amendments for Power Rerate as documented in letters dated October 18, 1994 (Unit 2) and July 18,1995 (Unit 3). There was no specific value or limit for containment overpressure delineated by the NRC, only that containment overpressure was needed for meeting ECCS pump NPSH requirements and that some margin existed. Specifically, the NRC indicated that: " ..at design conditions, sufficient margin to the required NPSH exists with the RHR and CS systems at rated loop flows. Assuming a LOCA occurs during operation at the uprated power, the calculated suppression pool temperature will remain below the value used in the NPSH analysis. Therefore, power uprate will not affect compliance with NPSH requirements for the ECCS pumps." In addition, the NRC also indicated that:
- Power relate increases the calculated peak suppression pool temperature, which could decrease the NPSH available to the ECCS pumps. However, as suppression pool temperature increases, so does the containment pressure, which increases the NPSH available to the ECCS pumps."
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Page 2 of 3 September 11,1998 l
Although there was a rationale for using the minimal point on the containment design containment pressure curve (i.e.,23.8 psia), PECO Energy elected to re-perform the minimum containment pressure and NPSH analyses using assumptions similar to those in our original licensing basis. This provided the basis for establishing our current licensing basis as discussed in the section below.
The Power Rorate analysis used the guidance provided in ANSI /ANS 5.1," Decay Heat Power in Lyht Water Reactors," for calculating the decay heat loading. However, the rerate analysis did not consider the effects of 2a.
Current Licensina Basis The current licensing basis analysis establishes a minimum containment pressure profile (i.e.,
curve), which is based on a re-analysis of containment pressure during LOCA conditions. The analysis considers the effects of operating at rerated conditions (i.e., new power levels), and the use of containment sprays and leakage. This analysis also assumes piping losses which correspond to actual piping configurations for the most limiting ECCS pump suction line. The results of this analysis were the basis for PECO Energy's previous response to GL 97-04 for PBAPS. Please note, that this analysis does not account for the head loss associated with the revised accident debris loads calculated in response to Bulletin 96-03.
The bases for the PBAPS Technical Specifications (TS) do not discuss ECCS pump performance in terms of NPSH requirements. Rather, the TS indicate that the ECCS pumps l must provide adequate flow under design conditions. Therefore, achieving the required flow rates is the basis for he current Technical Specifications (TS) requirements for ECCS. The current PBAPS design basis NPSH analysis continues to show that these requl red flow rates will be achieved.
Proposed Licensina Basis The PBAPS, Units 2 and 3, proposed licensing basis assumes the use of containment overpressure for meeting ECCS pump NPSH requirements, and that margin exists between the minimum containment pressure available and that required. The containment pressure required to ensure adequate NPSH is calculated to be 20.8 psia. This value is based on the most recent NPSH calculations for the RHR and CS systerns. The analysis includes the effects of the new strainers along with the new debris loading considerations.
The proposed containment analysis also contains significant conservatisms to offset the omission of 2o from the ANSI /ANS 5.1 heat loading analysis, as described in Section 5 of Enclosure 2, as well as the following examples:
. Analysis assumes no credit for passive structures acting as heat sinks.
. Analysis assumes all containment leakage to be nitrogen.
. Analysis is based on 110% rated power vs.105% for licensed rerated conditions.
. Analysis assumes that containment sprays are 100% efficient.
j (Note: Similar assumptions were also made as part of the analysis for the current licensing l basis, as discussed above, with the exception of the containment leakage being all nitrogen.)
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The combined effects of these assumptions provide a high degree of assurance that the containment overpressure available to support ECCS pump NPSH requirements will always i exceed the amount of containment overpressure needed for design basis events.
The proposed analysis contains a sufficient amount of margin with regard to NPSH. The design l of the new strainers does account for some amount of operational debris beyond the NUKOr4 insulation debris (e.g., paint chips). However, the analysis does not include provisions to account for future plant modifications or regulatory actions (e.g., recently issued Generic Letter 98-04) which would require re-analysis. Any re-analysis may result in a reduction in the available NPSH margin. Therefore, crediting the NPSH margin (i.e., crediting containment overpressure equal to the minimum containment pressure available as shown in Enclosure 2) available is considered prudent since it will provide flexibility should it be necessary to re-analyze our NPSH requirements in the future.
Conclusion The containment pressure required to assure adequate NPSH has always been less than the containment pressure available in any/all of the containment analyses. The originallicensing basis included the use of containment overpressure, and demonstrated that margin existed between the available NPSH and what was required. The current licensing oasis also credits containment overpressure for meeting ECCS NPSH pump requirements, and shows that sufficient margin is still maintained between available NPSH and required NPSH. Sufficient margin has always been maintained with regard to NPSH for the ECCS pumps when comparing the originallicensing basis analysis and the current licensing analysis. Based on our assessment, we believe that PBAPS, Units 2 and 3, are currently, and have operated, within their licensing bas.is with regard to meeting ECCS NPSH requirements.
It is importar.t to note that the information contained in Enclosures 2-4 reflects the design /licersing basis for the plants after installation of the new strainers and subsequent to closure of Bulletin 96-03. In the future, it may be necessary to revise these analyses and associated documentation in support of other plant modifications or regualtory action. If it is necessary to do so, the revision will be performed in accordance with our approved revision processes and applicable regulatory requirements.
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l ENCLOSURE 1 l l
.. . s 1-COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF CHESTER :
J. J. Hagan, being first duly swom, deposes and says:
That he is Vice President of fiiCO Energy Company; that he has read the foregoing response to the request for additional information regarding Bulletin 96-03 and Generic Letter 97-04 for Peach Bottom Atomic Power Station, Units 2 and 3, conceming the use of containment overpressure for ensuring adequate Net Positive Suction Head (NPSH) for Emergency Core Coo!ing System (ECCS) pumps, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
ce resident Subscribed and swom to before me this /h day of d c1998.
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Notary Public NOTARIAL SEAL CAROL A.WA!. TON. Notary Putmo Mv h y 282b1 l