ML20154A112
| ML20154A112 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/30/1988 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML19297G891 | List: |
| References | |
| ULNRC-1822, NUDOCS 8809120073 | |
| Download: ML20154A112 (32) | |
Text
,
1901 Grwt Dret Post Ofice B,s 143 St Icws, Unwr 631CE 314 55t2650 UVIG Duaid F. Sehnell Eucenu,N
~ ~ ' ~ ~
e' August 30, 1988 tua U.S. Nuclear Regulatory Commission ATTH:
Document Con trol Desk Mail Station Pl-137 Washington, D.C.
20555 Gentlemen ULNRC-1822 DOCKET NO. 50-483 CALLAWAY PLANT STEAM, GENERATOR _ LEVEL _REACTOJ3,, TRIP MOD _IFICATION Un'on Electric herewith transmits one original and one conform 0d copy of an applica6, ion for amendment to Facility Operating License No. NPP-30 for the Callaway Plant.
The requested amendment af fects the steam generator low-low level trip circuitry by adding an Environmental Allou3nce Mod ifier (EAM) and a Trip Time Delay (TTD).
The EA:1 will distinguish between a normal and an adverse containment environment and will adjust the steam generator low-low level setpoint accordingly.
The TrD will delay the trip signals during low power operations (lesc than or equal to 20% of rated thermal power, 3 565 MWt, or 713 MWt).
These changes have been developed by the Westinghouse Owners Group Trip Reduction Assessment Program as a means to reduce the frequency of unnecessary foodwater-related reactor trips.
The EAM arvi TTD conceptual designs are documented in WCAP-11325-P-A and WCAP-11342-P-A, which were approved by MRC in January, 1988.
This submittal includes a safety Evaluation ( Attachment 1) which provides the basic for our conclusion that implementation of EAM a nd TTD is acceptable and that it does not involve an unreviewed sa fety question. also provides the additional plant-specific information which the NRC requested in
$'(g their SERs for WCAP-ll325-P-A and WCAP-ll342-P-A.
$ describes the transient analysis per formed awl b
hardwaro changes associated with the implementation of EAM and Q
TTD.
This attachment contains information proprietiry to q
Westinghouse Electric Corporation.
As such, tie following M
versions of Attachment 2 are enclosed:
Eog 1.
WCAP-ll883, Implementation of the Steam Generator Low Low
$ o.o.
Level Reactor Trip Time Dolay and Environmental Allowanc p
CHAPGE l-1,'t sect I
L w trIl c dGCk -f I50 y
t emm
>:3,"
'A sek w
.ws s
i August 30, 1988 ULNRC-1822 Modifier in the Callaway 'lant, Wectinghouse Proprietat; Class 2, August 1988.
2.
WC AP-ll884, Implementat'on of the Steam Generator Lov Riw Level Reactor Trip Time Delay and Environmental Allowac.ee Modifier in the Callaway Plant, Westinghouse Non-i Proprietary Class 3, August 1988.
l Also enclosed is a Westinghouse Application for Withholding, CAW-88-080, Proprietary Information Notice, and accompanying Affidavit AW-76-031.
As this submittal contains information proprietary to r
Westinghouse Electric Corporation, it ic suppor ted by an af fidavit signed by Westinghouce the owner of the information.
The affidavit setc forth the basic on which the information may be withheld f rom public disclosure by the Commission and addresses sith specificity the considerations listed in parag r aph (b) (4) of Section 2.790 of the Commission's reguistions.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld f rom public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the l
cupporting Westinghouse af fidavit should reference CAW-88-080 and should be addressed to R. A. Wiecemann, Manager Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P.O. Dox 355, Pittsburgh, PA 15230. provides typical process control block diagrams, functional diagrams, and wiring diagrams.
Attachments 4 and 5 provide the necessary Technical Specification changes and the Significant Hazards Evaluation in support of this amendment request. contains the draft FSAR Chopter 7 changes, as requested by NRC in their SSRn for WCAP-11325-P-A and WCAP-11342 P-A.
This request has been reviewed and approved by the Callaway Onsite Review Committeo and the Nuclear Safety Leview Board.
It has been determined that thic request does not involve any ur. reviewed safety questions an defined in 10Crh50.39 nor a significant hazard consideration as determined by the three factor test por 10CFR50.92.
Union Electric pland to utplom-snt thece hardware changes during the Refuel 3 outage planned to beg (n in March, 1989.
It is therefore requested that NRC approve the amendment by February 15, 1989 to allow adequate planning for the work to be performed during the refueling outage, m
u m
Auguot 30, 1988 ULNRC-1822 Enclosed is a check for the $150 application fee required by 10CFR170.21.
Very truly youro,
&u h)
Donald F. Schnell DS/GGY/jal Attachments:
1-Safety Evaluation 2-WCAP-il883 (Proprietary Class 2)
WCAP-ll884 (Non-proprietary Class 3) 3-Process Control Block Diagrams, Functional Diagrams, and Interconnecting Wiring Diagrains (for typical channel) 4-Technical Specification Changes 5-Significant !!azards Evaluation 6-Draf t FSAR Chr.pter 7 changes
d 4.
STATE OF HISSCORI )
)
Donald F. Schnell, of lawful age, being first-duly sworn upon octh says that he is Senior Vice President-Nuclear and an officer of Union Electric Company; that he han read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
By
/
Donald F.
Schnell Senior Vice President Nuclear SUBSCRIBED and sworn to before me thir of9N day of b
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,,_o e,a,, v h0TARY Puhuc, STAIL Of L' 5TU11 Wy COWIS$iOM EIPiKL5 AFR!L 22.1583 ST. LOUIS COUNTf I
i Attachm:nt - 1 i
ULNRC-18 22 l
l l
SAFETY EVALUATION 1
STEAM GENERATOR LEVEL _ REACTOR TRIP MODIFICATION i
I.
Introduction l
II.
11ardware and Circuitry Description l
l III. Accident Analyses 1
A.
Trip Time Delay Analysis i
B.
Environmental Allowance Modifier' Analyses C.
SG Level Reference Log Heatup Uncertainty D.
Setpoint Analysis l
IV.
SER Applicability l
j V.
Conclusions VI.
References f
s
l l
I.
_I_nt_roduc tion This Safety Evaluation supports the proposed implementation of the steam generator (SG) low-low level trip Environmental Allowance Modifier (EAM) and Trip Time Delay (TTD) at Callaway Plant.
Implementation of the EAM/TTD modification will reduce the frequenay of unnecessary feedwater-related trips.
The development of EAM/TTD is described in the NRC-approved topical reports WCAP-ll325-P-A and WCAP-11342-P-A.
The implementation of EAM/TTD at Callaway Plant will be in accordance with the requirements of the NRC-issued Safety Evaluation Reports (SERs) which approved the EAM/TTD topical reports.
Section 11 summarizea the hardware and circuitry modifications and protection system logic for EAM/TTD.
Section III summarizes the accident analyses and setpoint analysis which support EAM/TTD.
The applicable design bases were evaluated or reanalyzed to support the SG low-low level Trip Time Delay.
Containment analyses were performed to support the Environmental Allowance Modifier.
Section IV contains Callaway plant-specific responses to NRC questicna specifically identified in the EERs which approved the implementation of EAM/TTD.
Section V provides concluding comments and a safety evaluation pursuant to 10CFR50.59.
II.
Hardware und Circuitry Descrip_ tion 1
This section provides a brief discussion of the hardware to be used in the EAM/TTD design and the Callaway-specific changes to the basic design described in WCAP-ll325-P-A and WCAP-11342-2-A.
The hardwaro to be used in implementing the modification is Westinghouse 7300 series equipment as is currently usad in callaway's 7300 process protection cabinets.
The fo11 ewing printed circuit cards will be used in implementing the EAM/TTD modification.
1.
NCT - Channel Test Card 2.
N!U - Master Test Card 3.
MAL - Comparator Card (single, double, and dual comparator cards) 4.
NAI - Annunciator Intsrf ce Cala 5.
NPL - PR0d Logic Cbrd A detazied descripti n of each type of card is pro'cided in Attachment 2, Section 3.4.
The reliability of 7300 series hardware has been demonstrated through field e.perience and the mean time between failure rates for 1-
4 l
{
the active cards in the EAM/TTD modification have been examined and no degradation of protection system relia-i l
bility will occur.
For a more detailed discussion of card reliability, see Section 3.4.2 of Attachment 2.
All equipment to be used in implementing this modification
[
was previously qualified under the Westinghouse 7300 3
tj' Process Protection System equipment qualification program.
Existing equipment that will interface with the new EAM/TTD hardware (i.e.,
containment pressure transmitters, steam generator level transmitters, RCS narrow range hot and cold leg bypass manifold RTDs, and interconnecting cable) were previously qualified under separate test j
programs in accordance with NUREG-0588 Category I require-l ments.
A detailed discursion of the EQ program may be d
found in Section 3.5 of Attachment 2.
Figure 1 of Attachment 2 shows a functional diagram of j
the EAM/TTD modification.
The following is a brief description of functional and implementation information for each part of the modification.
i II.A.1 Environmental Allowance Modifier Functional Descrip_ tion The EAM will distinguish between a normal or an adverse l
containment environment and enable a higher adverse environment steam generator low-low level trip setpoint i
4 j
when an adverse containment condition is sensed by elevated containment pressure.
The adverse environment i
level setpoint will be higher due to the inclusion of instrument uncertainties related to the harsh environment.
j Otherwise, a lower setpoint will be used in conjunction 1
with a normal environment.
Consequently, the frequency j
of unnecessary steam generator low-low level trips will be decreased by increasing the operating margin, the distance between the nominal steam generator level and l
l the normal environment low-low level trip setpoint.
r
{
II.A.2 EAM Imp _lementation Descriptior.
l l
t l
The EAM vill utilize an input signal from the existing I
containment pressure and steam generator level trans-I mitters.
A single comparator card will be added to each l
l of the four existing containment pressure channels to l
enable the steam generator low-low level setpoint corre-j sponding to an adverse environment.
The EAM circuitry f
f will havs a latch-in feature that will ensure that this l
setpoint remains enabled once an adverse environment has i
been detected.
In order to disable the adverse environ-l l
mont setpoint, containment pressure must decrease below i
ito set; tint and the switch must be manually reset.
In addition, the latch-in feature will be interlocked with j
the EAM comparator channel test switch as described in j
l, Section 3.1.2 of Attachment 2.
l l
l
! I i
l l
i i
a The existing steam generator low-low level comparator cards will operate with a setr int corresponding to an r
o adverse environment.
Eight new steam generator level l
double comparator cards (two per protection set with each double comparator card handling two steam generators) e will be added.
These double comparator cards will operate with a setpoint associated with a normal environment.
I II.B.1 Trip Time Delay _ Functional DescriRtion The Trip Time Delay may be generally described as a I
system of pre-determined programmed trip delay times that i
are based upon the prevailing power level at the time a low-low level setpoint is reached.
Section 3.2.1 of i refers to trip time delays based upon power i
level and upon the number o* affected steam generators.
However, the results of the Callaway-specific analyses i
were unaffected by the number of steam generators experiencing low level conditions. As such, the duration of trip time delays at callaway Plant will be a function of power level only, as further discussed in Sections II.B.2 and III.A below.
These delay times will be longer at icw power versus high power.
This correlates to the use of timers, each with a preset value, which are used to detain the actuation of the reactor trip, main feedwater l
isolation, and initiation of auxiliary feedwater so that steam generator level anomalies, such as shrink /svel' transients, may naturally stabilize.
I l
II.B.2 ITD_ Imp _l e m ent a t i o n D e s c r i p_t_i_o q j
I As shown in Figure 1 of Attachment 2, the input to the TTD circuitry is the EAM logic output and power level.
In l
order to determine power level, the TTD will utilize the Delta-T signal from the Overtemperature and overpower i
protaction channels.
The Delta-T signal will be processed j
by four new dual comparator cards (one per protection set).
[
These dual comparator cards will enable the appropr^ ate timer associated with the power level at the time a steam generator low-low level condition is detected.
As shown in Figure 1 of Attachment 2, once the TTD f
receives a low 41ow steam generator level signal from the j
EAM circuitry, all four timers will be started.
The timer 2
that determines the delay of the trip actuation signal will depend on the applicable logic fulfilled for each timer (an enabled condition).
The effective time delay I
of the trip signal will be the shortest delay of s11 the enabled timerc.
Timer A will be the effective ticar with j
the conditions of a law-low level signal in any one steam generator and the power level below the low power set-point of 10% of rated thermal power.
Timer B will be the I
effective timer with power levels between the low power (10%) and high power (20%) setpoints coincident with a low-low level signal in any one steam generator.
Timer C 3-I r
I i
will be the effective timer at power levels less than 10%
with a low-low level signal in more than one steam generator.
Finally, timer D will ba the effective timer with low-low level signals in more than one steam generator coincident with the power lovel between 10% and 20% of rated thermal power.
For power levels above the 20% power set-point, all time delays will be bypassed, thus, the reactor trip signal will not be delayed by the EAM/TTD circuitry.
Ticers, once enabled, will be latched in until all steam generator level signals in a protection set are restored to levels above the low-low level setpoint.
Restoration of all steam generator levels to levels above the low-low level set-point will terminate the timing, reset the timers to their predetermined values, and reset the trip logic signals.
I In summary, timer B will be interlocked with the low power setpoint.
Timer C will be interlocked with the two out of four stoani generator low-low level logic and timer D will be interlocked with both the two out of four level signals as well as the low power setpoint.
- Moreover, above the 20% power setpoint there will be no EAM/TTD i
delay of the trip actuation signal.
1 The TTD circuitry described in WCAP-11325-P-A differs from the proposed Callaway design only in the location of the t1:ne r s.
At Callaway, these timers will be located in the 7300 Preense Protection System cabinets rather than in the SSPS cabinets.
This minor change simplifies field installa-tion and reduces the overall impact on existing plant design.
II.C Alarms, Annunciators, Indicators, and Status Li_ghts Alarms, annunciators, indicators, and status lights are necessary to ptovide the operator with accurate, complete, and timely information pertinent to the protection system status.
Status lights and control board indicators provide the operator with specific information with respect to which individual channels generated the alarm and/or trip condition.
Presently, for the steam generator low-low level protection system, sixteen instrumentation
)
channels (one per steam generator, per protection set) are provided.
Each level channel is configured with a bistable trip atatuo light which te illuminated on the control board anytime that an enabD i bistable trip setpoint has been reached.
An alarn and annunciator (one per steam generator) is provided to inform the operator that at least one level channel has dropped below its j
trip eetpoint.
If more than one level channel for any one steam generator has fallen below its trip setpoint, a "first out" reactor trip alarm and annunciator is provided to alert the op1rator that a reactor trip has occurred.
l After the EAM/YTD modification has been installed, all of tra alarms, annunciators, and status lights will continue I
4-I
I.
l l
to function as described.
However, since these signals originate at the SSPS voting citcuitry, tney will not be actuated until all applicable time delnys have expired.
Additional alarms and annunciators vill be provided with thtt EAM/TTD hardware modification.
These will inforan the operater that an adverse environment and/or a low-low steam generator water level has been detected.
A new low-low level alarm will be provided for each steam generator to signify that the water level in at least one channel has dropped below the low-low level setpoint in that steam generator.
The operator may then observe the individuai channel steem generator level indicators to determine appropriate actions.
Finally, a common alarm and annunciator will be provided to indicate the presence l
of an adverse environment.
The input to this window will be derived from the four containment pressure channels (one per protection set).
The operator may then observe the individual channel containmant presc,ure indicaters to i
determine which channel (s) hrve the adverse steam generator low-low level setpoint enabled, i
II.D SurveD iance Testilig The EAM/7TD steam generator level channels will be periodi-cally tested on a monthly basis consistent with the I
remainder of the 7300 Process Protection System.
The level channels may be tested one-at-a-time to verify one-out-i l
of-four operation, and with various combinations of two-at-l a-time to verify two-out-of-four operation.
The EAM and l
Delta-T comparators will also be tested at this time.
After the normal snvitonment comparators have been tested, periodic surveillance of the EAM/T1D steam generator level channel is complete.
Section 3.6.2.2 of Attachment 2 describes surveillances to be performed on a refueling outage (18 month) interval.
l l
III.
A_ccidept_Analy.ses Analyses were performed to establich Safety Analysis Limits (SALs) for the SG low-low level trip time delays, the normal and adverse containment condition trip setpoints, and for the EAM containment pressure setpoint.
The analytical methodology employed is consistent with NRC-approved methodologies for implementation of the EAM/TTD modifications.
Instrument uncertainties and environmental allowances were calculated to account for instrumentation and measurement errors and the ef fec t of postulated po'st-accident environ-mental conditions on SG low-low level trip and EAM contain-ment prersure setpoints.
The methodotogies employed are consistent with methodologies previously accepted by the NRC.
i III.A.
Trip _ Time Delay _Analy_se_s Analyses to determine SG low-low level trip setpoint and trip time delay SALs were performed consistent with the NRC-approved methodology of WCAP-11325-P-A, "Steam Generator Low Water Level Protection System Modifications to Reduce Feedwater-Reinted Trips."
The analyses which l
support the implementation of the TTD modificat. ion are described in Attachment 2.
An evaluation of the impact of the SALs for trip time delays and trip setpoints on the safety analysis design bases was performed, Both LOCA and non-LOCA design bases were considered in the evaluation.
1 The following desiqn basis transients assume the actuation of automatic protection features by means of the SG low-low level trip signal and were explicitly reanalyzed to determine the impact of power-dependent trip time delays and environment-dependent trip 4
j setpoints:
1.
Loss of Nonemergency AC Power to the Station Auxiliaries (FSAR Section 15.2.6),
2.
Loss of Norme.1 Feedwater Flow (FSAR Section 15.2.7),
3.
Feedwater System Pipe Break (FSAR Section 15.2.8),
l 4.
Steamline Break Mass / Energy Releases for Equipment j
Environmental Qualification Outside Containment (WCAP-10961-P).
Sensitivity studies were performed to assess the effects J
of trip time delays at low power on the equipment surface temperatures listed in Table 3.4 of Reference 1.
It was concluded that these equipment surf ace te.nperatures, as given in Table 3.4 of Reference 1, remain bour. ding and 3
j are unaffected by the proposed EAM/TTD modification.
Other design basis transients, which do not assume automatic protection by means of the SG low-low level trip signal, are unaffected by the SG low-low level trip l
time delays and trip setpoints.
l The evaluatione and analyses of the above design basis transinnto justify the implementation of the following SG l
low-low level trip time delay and trip setpoint SALs:
l Trip Setpoint 0% narrow range span I
l Trip Time Delay l
10% nominal power, 2/4 SG logic 240 seconds 10% nominal power, 1/4 SG logic 240 seconds 20% nominal power, 2/4 SG logic 130 seconds 20% nominal power, 1/4 SG logic 130 seconds
_s.
i
r i
III.B.
Enyironmental Allowance Modifier Analyseo The NRC has previously approved the Westinghouse topical report WCAP-11342-P-A, "Modification of the Steam Generator Low-Low Level Trip Setpoint to Reduce Feedwater-Related Trips."
This WCAP proposes a design modification which can reduce the inadvertent plant trips related to low steam generator level signals by installing an Environmental Allowance Modifier which distinguishes between normal (low temperature) and adverse (high temperature) containment environmental l
conditions and automatically selects a low or high setpoint for the low-low level trip corresponding to i
normal or adverse containment conditions.
These setpoints reflect the exclusion / inclusion of instrumentation uncertainties related to harsh environmental conditions.
By using the two different setpoints, more operational flexibility (and fewer spurious trips) is provided during normal conditions, while adequate protection is still provided during accident / adverse conditions.
l WCAP-ll342-P-A discusses the measurement of containment pressure, rather than containment temperature directly, and conservatively relates pressure to = corresponding containment temperature.
This is dons oecause containment pressure is easily and accurately measured I
and equalizes more repidly throughout containment during i
a transient than temperature.
III.B.1 Containment Temperatute Defining _Adye.rse_ Enviro _nment I
WCAP-ll342-P-A specifies a minimum containment temperature which defines an adverse environment.
This
)
temperature correspends to the normal temperature limit i
- or Westinghouse supplied differential pressure (level) i transmitters.
The Callaway-specific analyses, however, use a transmitter surface temperature of 180*F, rather than the containment atmosphere temperature, to define an adverse containment environment.
This approach is consistent with the methodology accepted by the NRC for safety-related component thermal lag analysis described in NUREG-0588, "Interim Staff Position en Environmental Qualification of Safety-Related Electrical Equipment."
j Environmental allowance errors associated with the transmitters themselves were calculated at 230'F, i
l yielding a 50*F margin between the temperature utilized in the containment analysis and the temperature assumed I
for instrurcent error calculations.
Environmental allowance errors associated with SG reference leg heatup are diset'esed in Section III.C below.
I I
1
' 1
l III.B.2 Mi imum Feedline Break Size D
Consistent with the methodology of WCAP-ll342-P-A, minimum break size was determined below which steam generator level could be maintained by the feedwater system.
Break flow rates for which the feedwater system can maintain an adequate steam generator water level do not require automatic protection by tripping the reactor i
on icw-low SG level.
Adequate heat removal is assured l
for small feedline breaks as long as the steam generator U-tubes remain covered.
The Callaway feedwater system is comprised of two 67%-capacity turbine-driven feedwater pumps and four l
feedwater control valves which are designed with a range of 0-120% nominal flow.
An evaluation of design and 4
operating data has determined that, for the Callaway Plant feedwater system, break mass flow rates below 225 l
4 l
lbm/sec for a single steam generator are within the 1
I capacity of the feedwater system to maintain water level in the affected steam generator.
It addition, for such i
i small break flow rates, plant operators would have ample time to detect a problem from a number of plant indications, e.g.,
containr.ent pressure, containment temperature, SU steam /foeddater mismatch, cor.tainment
]
sump level, etc.
i III.B.3 BreaL D_i_scharge_ Assumption _s l
As described in WCAP-ll342-P-A, the limiting break discharge enthalpy for largo dry containments was found I
to be 1205 BTU /lbm.
This enthalpy corresponds to the greatest enthalpy of seturated water vapor physichily possible.
Use of this superheated break discharge for a specified break mass flow rate maximizes containment temperature while minimizing containment pressure.
i In accordance with the WCAP methodology, the above break dis-charge enthalpy was used in the Callaway-specific containment l
analyses discussed in Section III.B.4.
Tha important SG l
parameters identified by Westinghouse are SG type (feedring or preheat), maximum break size, the SG pressure, the SG temperature, and the feedwater temperature.
With the i
exception of feedwater temperature, all Callaway-specific SG parameters are bounded by those assumed in the WCAP.
As previously stated in Reference 2, the maximum feedwater temperature at uprated cond tions with no SG tube plugging is predicted to be 44G"F.
The maximum feedwater tempera-f ture assumed in the WCAP analyses is 445'F for the Carroll County 1 & 2 plants.
Considering the conservatisms of the WCAP methodology and the Callaway-specific analyses, this l'F deviation is judged to have a negligible impact on both the applicability of the WCAP methodology to the Callaway Plent at uprated conditions and on the validity of the results of the Callaway-specific analyses.
III.B.4 C_al_la_way-Spec _ific EAM Containment Analyses Callaway-specific EAM containment analyses were performed to assure the implementation of conservative SALs at Callaway Plant because of slight differences in the containment heat sinks and purge system modelling between what was assumed in WCAP-11342-P-A and what applies to callaway Plant.
The Callaway-specific distribution of heat sink areas is greater than that assumed in the WCAP analyses.
Also, the WCAP assumes an 8-inch purge valve equivalent diameter.
The nominal diameter of the callaway Plant mini-purgo valves is 18 inches with a calculated equivalent diameter ranging from a minimum of 9.3 inches to a maximum of 10.4 inches.
The WCAP methodology utilizes a single containment analysis to determine both the containment pressure and containment temperature for a given break mass flow rate.
Through this single containment analysis approach, the minimum containment pressure for a specified containment temperature was calculated.
With the exception described in Section III.B.1 above, the Callaway-specific EAM containmGnt analysea were performed consistent with the i
methodology of NCAP-11342-P-A with the additional I
conservative enhancements described below to further minimize the EAM containtent pressure SAL.
In the callaway-specific analysis, for each assumed break, dual containment pressure /terperature calculations j
were performed: 1) A "temperatura inaximizing" case to i
maximize containment temperature and, thereby, the SG level transmitter surface comperature and 2) A "pressure-minimi ting" case to minimize containment pressure.
Both case, used the NRC-approved computer code COPATTA which has oben previously used to perform FSAR Chapter 6 analyaes to conservatively predict the Callaway Plant containment pressure / temperature response following i
a LOCA or SSLB.
i The EMi containment pressure SAL was determined by seletting the containment pressare from the pressure-l minimizing case at the time at which the SG 1evel trann-mitter surface temperature reaches 190'F from the temperature-i naximizing case.
If the containment pressure was determined to peak prior to the time the SG 1evel trans-mitter surface temperature reached 180*F, the peak pressure I
would be used in the determination of the EAM containment pressure SAL.
The temperature-maximizing case was used to determine a minimum time for the SG level transmitter surface temperature to reach 180*F.
The pressure-minimizing case l
was then used to determine a lower bound on containment i
pressure which could occur up to the time the SG level trans -
I mitter surface temperature reaches 180*F. This method assures l
that the EAM containment pressure setpoint will be minimized which, in turn, assures that swap-over from the normal to adverse SG low-low level setpoint will occur prior to the SG level transmitter surface temperatures reaching 180*F, 1
r By perturbing the WCAP single-case methodology in this manner, additional assurance is obtained that the containment pressure is minimized foi a specified j
containment temperature.
As discussed in Section III.B.5 t
below, a comparison of the generic results in the WCAP and the Callaway-specific results demonstrates that the Callaway-specific results conservatively underpredict the EAM containment pressure SAL relatjvo to the generic WCAP results.
[
)
III.B.4.1 hasumpilons Used to Maximizo _ Temperature Inc r_ea se To calculase the shortest time to heat up the SG 1evel 5
transmitters, the overall containment temperature rise j
was maximized.
The iollowing assumptions were used in this analysis:
(
l The flow coef ficient of the niini-purge system open exhaust luct was minimized (a value of 0.269 was used).
This is consistent with the WCAP-11342-P-A i
i methodology.
(
r 1
No containment spray was modelled.
Three containment air coolers were modelled using ncrmal operating 1
conditions (normal fan speed) with 95*F service water.
A sensitivity study was porformed to evaluate the I
effect of assuming no containment coolers on the renilts of thu analysis.
The results of the t
l sensitivity study demonstrate that, for the limiting i
i small break cases, modelling containment coolers has J
no effect on the calculated EAM containsnent pressure
- SAL, For these small break cases, the cor.ta2hment j
pressure reaches a peak long before the SG 1evel transmitter surface temperature reachew 180*F.
[
]
The exclusion of the effect of containment coolers results in a minor increate in SG level transmitter l
surface temperature; however, it does not affnet the i
conclusion tha' the calculated EAM containment i
pressure SAL v.11 assure swap-over to the adverse l
j environment setpoint prior to the SG level l
transmitter surface temperature reaching 180*F.
i A minimum containment free volume of 2.5E6 ft3 was i
- used, i
i Outside atmospheric conditions were initially assumed l
l l
to be 95'F, 14.4 psia, and 0% relative humidity, t
l Conditions inside the containment were initially
[
l assumed to be 120'F, 14.4 psia, and 100% re!ative
(
humidity.
I The fraction of condensate from all heat sinks that l
revaporizes was assumed to be 8%, the maximum allowed l
f i l
i
under NUREG-0588, Appendix B.
This is consistent with the thermal lag methodology used for EQ calculations, as discussed in EsAR Section 3.ll(B).1.2.2.
This methodology was approved by NRC in Section 3.11.3.3.1 of Supplement 3 to the callaway SER.
The Uchida heat transfer coefficient was used for heat transfer to all passive heat sinks.
To maximize heat transfer to the SG 1evel transmitter housing, the larger of either a condensing or forced-convection heat transfer coefficient was used.
The heat transfer coefficient for condensation was four times the Uchida coefficient as specified in NUREG-0588.
The heat transfer coefficient for forced convection was determined internally by COPATTA.
Minimum calculated areas for passive heat sinks were used to nsaximize temperature increase.
l r
III.B.4.2 b a cumpj; i_on s U s e d t o_J11 ni m i z e_P r e s su r e_I nc r e a s e The following assumptions were used in this analysis:
The flow coefficient of the mini-purge system open exhaust duct was maximized (a value oi 0.332 was used).
Four containment air coolers were modelled using normal operating conditionn (normal fan speed) with 33'F service. water.
Containment spray was not medelled since at all times the containment pressure remains below the containment pressurs HI-3 uetpoint (27.0 psig) for actuation of containment spray.
A maxinum containment free tolume of 2.7E6 ft3 van used.
Initial atmospheric conditions outside the containment were assumed to be -60*F.
14.4 psia, and 0% relative humidity, t
Initial conditions inside containmor.t very aceumed to to 90*F, 14.4 psia, and 100% r31ative humidity.
Consistent with the ECJS backpresaure analysis contained in FSAR Section 6.2..'.5, no revaporization of condensate was considered.
The maximum calculated passive heat slak surface l
areas wcre used.
This included the containment floor.
These areas were further multiplied by 1.2 to increase the heat transfer ; ate in accordance with Standard Review Plan Section 6 f. 1.5.
l t I t
1 4
IIT.B.5 Qontainment EAM Analysis Results Figure III-l depicts the containment preneure and SG J
level transmitter aurface temperature respon.se for the limitir:0 140 lbm/see break.
The 140 lba/sec break is limiting Pince it is the smallest analyzed break for which the BAM circuitry would detect an adverse ettvironmental condition, thereby providing the longest SG level setpoint swap-over time and the highest SG 1evel transmitter surface temperature at the timt of swap-over, t
i This break is characterized as the smallest break for i
which a setpoint change (from normal to adverse) is 1
needed and for which the CG 1evel transmittera coms the closest to exeseding their normal operation limit (180*f) prior to enabling the setpoint change.
Recall that the containment pressure curve comes from the pressure-
[
l minimizing containment model and the transmitter surface t
temperature curve comes from the temperature-maximizing t
containment model.
These models are described above in t
Section III.B.4.
Determining the
- ontairanent pressure and transmitter surface temperature in this manner assures that the containment preseure is minimized for a specified transmitter surface temperature.
l From Figure III-1, the transmitter surface temperature i
reaches the 180*F limit at 539 sec.
The containment pressure at 539 see is approximately 18.2 psia (3.5 psig).
However, containment presrure is 18.5 pain (3.8 psig) at 41G sec.
Since the containment model for the containment pressure calculation was unlected to minimize the i
pressure within containment, this peak pressure defines l
the EAM safety analysis limir..
The SG level transmitter l
surface temperature at 410 see is approximately 175'F.
I Figure III-2 depicts the results of the containment l
pressuse/ temperature calculations for break mass flow t
rates of 100 lbm/sec, 140 lbm/sec and 200 lbm/sec.
j Specifically, Figure !!I-2 depicts the maximum containment pressure, up to the time that the S0 level t
c transmitter surface temperature reaches 180*F, versus i
l break mass flow rate.
It should be noted that for the I
100 lbm/sec and 140 lbm/sec breaks, the pressure peaks l
before the SG level tr ansmitter surf ace temperature
[
reaches 180*F.
For these cases, Figure III-2 depicts tho
=
l peak pressure.
Also depicted in Figure !!I-2 are two points taken from WCAP-ll342-P-A.
These two points l
represent *ho containment pressure at the time containment temperature reaches 180*F for a 4-Joop plant with a *arge dry containment.
The point at 140 lbm/sec is extrapolated from the WCAF results.
The Callaway-speciflc results are I
seen to conservatively underpredict the containment pressure relative to the generic results of the WCAP.
The calculated EAM containment pressure SAL was calculated to be 18.5 psia (3.8 psig) for the limiting l
i l
i break mass flou rate of 140 lbm/sec.
This limiting mass i
flow rate of 140 lbm/sec is well below the 225 lbm/sec l
limit on feedwater system capacity to maintain SG level, i
.III.C.
SG Lev _eLRefe_tyn_ceJeg Heatqp UrtcerJairit;_y l
t Environmental allowanco etrors associated with SG reference leg heatup were calculated using a methodology consistent l
with that u.tilized previously to calculate the environ-l mental allowance due to SG reference leg heatup in an adverse containment environment (Reference 3).
i The following assumptions were made in calculating the reference leg temperature due to hectup following a main feedline break.
These ansumptions wera made to assure that the calculated reference leg temperature overpre-f dints the reference leg temperature which would actually I
follow a main feedline break.
The temperature-maximizing COPATTA containment model detailed above was used with l
the exceptions described below:
Conservative break uischarge conditions were assumed i
to maximize the mass and energy transferred to the containment.
The EAM containment analyses described above in Section III.B assumed constant break discharge i
conditions (mass flow rate and enthalpy).
For the Callaway-specific SG level reference log heatup calcu-lations, a double-ended guillotine (hEG) break was j
modelled.
Conservative initial conditions (SG pressure 3
and level), brenk discharge flow areas, and break dis-t charg9 quality were assumed in order to maximize the mass and energy transferred to the containment.
The Moody model was used to calculate critical flow rates from the break, f
For break sizes greater than or equal to 200 lbm/sec, i
the break discharge mass flow rate and enthalpy are I
time-dcrendent and account for the depressurization of the SG during the blowdown.
The contribution of l
feedwater from the upstream side of the break was
}
minimized.
Although the 200 lbm/see break discharge l
is less than the 225 lbm/sec limit on feedwater system I
capacity to maintain SG level (as described above in 1
Section III.B.2),
thu assumption of a time-dependent break dischargo results in a higher 30 level reference leg temperature than would be the case if a constant break discharge were assumed (as assumed for break sizes less than 200 lbm/sec).
This higher temperature is due tu the time-dependent break enthalpy, approaching f
1190 Btu /lbm for saturated vapor, being much greater than the constant break enthalpy corresponding to a mixture of saturated steam and cold feedwater (593 Btu /lbm),
f i
For break sizes below 200 lbm/sec, the break was modelled as a DEG break with a break area less than
[
the large break area.
Modelling the break enthalpy f
L I i l
for small breaks in this manner is conservative with respect to maximizing mass and energy transfer to containment since the break onthalpy, for small feedline breaks, would actually be equal to tho enthalpy of cold feedwater.
The break discharge mass flow rate and enthalpy are constant since the steam generator conditions do not change for break mass flow rates less than 225 lbm/sec.
The reference leg is an uninsulated 3/8" stainless steel tube containing water. One-dimensional heat transfer in cylindrical coordinates was modelled, o
No resistance to heat transfer between the inner wall of the reference leg tube and the water was assumed.
Four times the Uchida heat transfer coefficient van l
used for condensing heat transfer on the outer surface of the reference leg.
No containment coolers or spray were modelled.
Consistent with the WCAP methodology, 50'E was added i
to the calculated SG reference leg temperature as margin to account for temperature gradients inside the containment.
The geometric parameters which affect SG reference leg temperature were based on as-built dimensions.
r The containment mini-purge system exhaust duct was assumed to be closed.
i The reference leg calibration conditions were assumed to be 90"F containment temperature and 1000 psia SG i
- pressure, Steam generator level reference leg water temperature was assumed eoual to the inside wall temperature.
L i
Table III-l lists the calculated SG level reference leg temperature at the time the containment pressure y
reaches the FAM containment pressure SAL (10.5 psia, 3.8 psig) versus break size.
The limiting SG 1evel reference leg temperature was found to be 165'r plus 50'F margin or 215'F.
This value represents the e
maximum impact of the competing effects of large mass and energy transfer rates for large breaks and long heatup times following small breaks.
The s
environmental allowance in the SG low-low level trip setpoint due to SG reference leg heatup to 225'F is i
t j
5.0% of span.
This may be compared to the current adverse environment SG 1evel reference leg heatup uncertainty of 9% of span corresponding to a tempera-ture of 265'F reported to the NRC in Reference 3.
[
I III.D.
S e_t p.o i n t A n a l. y s i s The nominal SG low-low level trip time delays, trip setpoints, and EAM containment pressure setpoint are dotermined by adjusting the corresponding SALs for instrument and measurement uncertainties.
I Instrument loop uncertainty calculations were performed to confirm the necessary Technical Specification and Safety Analysis values.
A detailed description of the calculations may be found in Section 4.0 of Attachment 2.
i The methodology used is essentially the same as that used in previous setpoint analyses for callaway Plant.
Some minor differences can be noted in the treatment of RTD and R/E uncertainties which reflect the latest methods I
I for use of Delta-T instead of Tavg.
The use of TTD requires that two sets of Vessel Delta-T and Time Delay setpoints be noted in the Technical
(
Specifications; one set (Power-1) for Vessel Deltr.-T less j
than or equal to the equivalent of 10% RTP and one set (Power-2) for Vessel Delta-T less than or equal to the j
equivalent of 20% RTP.
The inclusion of the EAM results
[
in two trip setpoints for SG Water Level - Low-Low; one for a maximum containment ambient temperature of 230*F l
(Normal) and one that reflects a maximum containment temperature of 320*F (Adverse).
The environmental
)
allowance in the SG low-low water level setpoint resulting from SG 1evel reference leg heatup was calcu-l l
lated at a temperature of 215'F for Normal conditions and at 265'E for Adverse conditions as described above in j
Section III.C.
[
1 i
The results of the setpoint analysis are summarized in j
Table III-2, 1
1 l
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1 I
l l
1 t
}
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TABLE III-1 SG LEVEL REFERENCE LEG TEMPERA 111RE AT EAM CONTAINMENT PRESSURE SAFETY MIAL1S3 S, hMilT___._
Reference Leg Temperature ('F) aLeA}L.Siu I10_'.F/_t19 '._D DEG* (O.89 ft )
130/180 hDEG (0.22 ft )
146/196 200 lbm/sec (0.080 ft2) 165/215 140 lbm/sec 145/195
- DEG - Double-Ended Guillotine l
t I
i -
TABLE III-2 9%LbtfAY_E L^t tLE3MSTD_SETP.0J HT_AU AL*LS_I S Safety Analysis Nomtual Trip Protection Channel Limit Setpoint SG Water Loyal - Low-Low 0.0% NR span 14.8% NR opan (Normal) so Water Level - Low-Low 0.0% NR span 20.2% NR 6 pan (Advorno)
Vessel Delta-T - Power 1 19.0% RTP 10.0% RTP Vesse). Delta-T - Power-2 29.0% RTP 20.0% RTP Trip Time De)ny - Power-1 240 sec 232 nec Trip Time Delay - Pcwor-2 130 noc 122 sec Containment Prnasure - KAM 3.8 psig 1.5 psig 4
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IV.
SKL bpplippblJity l
This section is provided in order to address the items f
the NRC specifically identified in the SERs or.
}
WCAP-11325-P-A and WCAP-11342-F-h.
The SER items will be y
addressed either directly or by reference to the section i
t of this report which provides the required response, This section will be presented in a format which introduces each GER discussion topic followed by our response.
i Id p_TJ m e_D ela y_S FA.RC3 Pal 32 5 - f.- M (1) Plant-cpe:ific protection myctem logic diagrams accompanied by proposed revicions to Chapter 7 of the FSAR including compliance statements with the applicable, plant-specific safety criteria (General f
Design Criteria, Regulatory Guides, IEFE STD 279, etc.) covering the design modification.
Plant-specific logic diagrams tre provided in I.
Preposed FSAR Chapter 7 ravisions are l
provided in Attachment 6.
Since the EAM/TTD hardware l
will be installed in tha 7300 process protection cabinets, all applicable codes and standards discussed in Chapter 7 will remain valid.
For l
additional discussion, see Section 3.7 of Attachment 2.
l (2) Proposed changus to the plant-specjfic Technical
)
Specifications with an accompanying Significant liezards Evaluation, covering any new response time
[
values for reactor trip and auxiliary feedwater ectuation on a low-low steam generator water level signal, the adjustment for the time delays (setpoint and allowable value accounting for calibration accuracy, drift, etc.) as part of the operability /
l surveillance requirements of the automatic actuation j
logic. and new setpoint and allowable values for the j
P-8 and/or ot.her interlocks utilized, j
i The proposed Technical Specification changes, including trip time delais and operability /
surveillance requirements are included in Attachment l
4 with the Significant flazards Evaluation covering FAM/TTD given in Attachment 5.
The interlock i
netpoi.it and allowable values are part of the Technical Specification changes and are discussed in more detail in Section III.D of this Safety i
Evaluation and in Section 4.0 of Attachment 2.
l (3) Detailed electrical schematics covering the design modification with a discussion ef the proposeu periodic i
testing to be performed on the modified hardware installed.
Ibe marked up electrical schematics are provided in.
Surveillance testing is (It acussed in I
Section 3.6 of Attachment 2.
l
- 21
(4) Discussion of the environnzantal qualification of equipment (sensors, timers, etc.) related to the design modification.
Environmental qualification of the equipment to be used is addressed in Section 3.5 of Attachment 2.
(5) Discussion of the total instrumentation uncertainties (calibration, drift, etc.) for the plant-epecific power interlocka utilized and their impace upon the relection of the corresponding time delays.
The setpoint study performed to support this modifi-cation may be found in Attachment 2, Section 4.0.
(6) Plant-specific changes to the operator procedures resulting from delay of reactor trip and auxiliary feedwater initiation.
No normal operating procedure changes are required to support the Trip Time Delay modification.
The TTD is not intended to modify the operators' actions but simply to provide more response time in which to take the actions currently outlined to restore Steam Generator level.
(7) Plant-specific human factors analyses for any addi-tional displays in the control room.
The only additiors to the control room will be annunciators; thene will be added consistent with the human factors philosophy established during the SNUPPS Detailed Control Room Design Review.
E nliLo pm e nt a (_A (l o w a n te_Mo d ifi eLS E U W_ CAP - llM 2 - P - A ).
(1) Plant-specific protection system logic diagrams accompanied by proposed revisions to Chapter 7 of the FSAR including compliance statements with the applicable, existing plant-specific safety criteria (GDC's, RG's, IEEE STD 279, etc.) covering the plant design modifications.
Plant-specific logic diagrams are provided in.
Proposed FSAR Chapter 7 revisions are provided in Attachment 6.
Since the EAM/TTD hardware will be installed in the 7300 process protection cabinets, all applicable codes and standards discussed in Chapter 7 remain valid.
For additional discussion, see Section 3.7 of Attachment 2.
(2) Proposed changes to the plant-specific Technical Specifications with accompanying Significant Hazards Evaluation covering the EAM installation.
This shall include new setpoints and allowable values for the 22 -
steam generator low-Icv level trip and the new containment pressure bistables as part of their operability / surveillance requiraments for the EAM circuitry.
Also, a discussion of the applicability of the WCAP methodology should be provided including a determination of the pressure setpoint.
The proposed Technical Specification changes, including new setpointo and allowable values, are found in Attachment 4 with the Significant Hazards Evaluation covering EAM/TTD given in Attachment 5.
The pressure setpoint was determined by the plant-specific containment analysis presented in Section
!!! of this attachment and the setpoint methodology presented in Section 4.0 of Attachment 2.
A discussion of the applicability of the WCAP-11342-P-A methodology is included in Section 2.0 of.
(3) Proposed changes to the plant-specific Technical Specifications with accornpanying Significant Hazards Evaluation covering any changes related to operation of containment systems, if required, to ensure acceptability of the EAM installation.
The containment pressure / temperature analysis was performed assuming the mini-purge valves were open, therefore no Technical Specification changes concerning l
containment operations are required.
(4) Plant-specific changes to the operator procedures to cover the use of the EAM reset controls.
Plant procedures (!&C and annunciator response) 2211 be changed prior to operation with this modification installed.
The procedure changes will require a review of plant conditions causing the EAM activation to ensure adverse temperature conditions were not observed prior to reset.
Surveillance testing vill not require a review prior to reset.
(5) Detailed electrical e.hematics covering the design modification.
These drawings are provided in Attachment 3.
(6) Plant-specific human factor analyses for any hardware modification to the control room.
The only additions to the control room for this modification will be annunciators.
Human factors will be considered in their inclusion, consistent with the philosophy established in the SNUPPS Detailed Control Room Design Review.
23 -
(7) The EAM conceptual design provides for testing of the associated instrument channels in the bypass mode.
Since the licensing basis for a typical Webtinghouse l
plant provides for testing with the channel under test j
in the trip mode, a discussion of the acceptability for i
testing in bypaso (referenco to an applicable, approved WUAP such as WCAP-10271 is acceptable) should be
- provided, f
6 Testing will be performed as discussed in Section 3.6 of Attachment 2.
l i
I L
i i
l r
i I
i
[
t l
f l
y n
l i
r F
t 1
i I
i
- 24
i i
)
V.
p_gng.lu_s1ons i
i I
j This safety evaluation and suppor ting documentation demonstrate that the implementation of the Environmental f
j Allowance tiodifier and Trip Time Delay modification at i
Callaway Plant will not reduce any safet," margins and l
J does not involve an unreviewed safety quantion as defined by 10CFR50.59.
Callaway Piant remains f.n cWcpliance with i
applicable criteria anr1 safety limits and will be i
operated anfely and reliably provided the plant is
]l operated in accordance with the proposed Technical Specification changes.
The evaluation has verified the l
following l
1.
The probability of sn accident previously evaluated 1
in the FSAR will r.et be increated.
l 2.
The consequences of an accident previously evaluated in the FSAR will not b3 increased.
.1 3.
The possibility of an accident which is different than any already evtluatud in the FSAR will not be r
created.
8 4
4.
The probability of a malfunction of equipment l
]
important to safe *" previously evaluated in the FSAR i
will not be increased.
l 5.
The consequences oc s malfut.ction of equipment 4
j important to safety previously e"aluated in the FSAR j
will not be increased j
u 6.
The possibility o' a malfunction different from any already evaluated in the FSAR of equipment important to safety will not be created, t
)
7.
The margin of safety as definx' h the bases to any I
Technical Specification will not ?6 reduced.
l i
t I
{
i t
l 1
i
-2s-I i
VI.
References 1.
ULNRC-1473 dated 3/24/87 2.
ULNRC-1471 dated 3/31/87 3.
SLNRC 81-115 dated 10/2/81 l
l i
l I
WCAP-ll883 (Proprietary Class 2)
WCAP-ll884 (Non-proprietary Class 3)
ULNRC-1822 I!!PLEMENTATION OF THE STEAM GENERATOR LOW LOW LEVEL REACTOR TRIP TIME DELAY AND ENVIRONMENTAL ALLOWANCE MODIFIER IN THE CALLAWAY PLANT STEAM G_ENERATOR _IgEVFL REACT,0,R TRI_P MODIFICATION
- Westinghouse Ap' plication.se Withholding Proprietary Information f rom Pttblic 'Jisclosure
- Proprietary Information Notice
- Affidavit AW-76-31
- WCAP-il883 (Proprietary) and WCAP-ll884 (Non-proprietary) 1.0 Introduction 2.0 Sa'ety Analysis Design Basis 3.0 I&C Design Information 4.0 cesign Document: tion 5.0 References I