ML20217Q952
| ML20217Q952 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/22/1997 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19317C692 | List: |
| References | |
| IEB-96-003, IEB-96-3, NUDOCS 9709040016 | |
| Download: ML20217Q952 (15) | |
Text
e Ctition Support Department NRCB No. 96 03 o
%V PECO NUCLEAR
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W inCiol.1,9tCK4 (ks.ignitrJ A Unit of PECO Energy me a mv wu August 22,1997 Docket Nos. 50 277 50 278 Ucense Nos. DPR 44 DPR 56 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Subject Peach Bottom Atomic Power Stallun, Units 2 and 3 Response to Request for AdditionalInformat!on Concerning NRC Bulletin 96-03,
- Potential Plugging of Emergency Core Cocling Suction Strainers by Debris in Boiling Water Reactors
- Gentlemen:
This letter is being submitted in response to an NRC Request for Additional Information (RAI)
Issued by letter dated August 1,1997, concerning PECO Energy Company's Response to NRC Bulletin (NRCB) No. 96-03,
- Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors," for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.
NRCB 96-03 was issued on May 6,1996, and requested that licensees implement appropriate procedural measures and plant modifications to minimize the potential for clogging of Emergency Core Cooling System (ECCS) suppression pool pump suction strainers by debr4 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 this NRCB 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 new large-capacity, passive, strainers on ECCS pump suction piping, with the exception of the High Pressure Coolant injection (HPCI) system. The installation of the replacement strainers would be completed during the next scheduled refueling outage for each unit.
By letter dated May 5,1997, PECO Energy submitted, in accordance with the requirements of 10 CFR 50.90 and 10 CFR 50.59, a request for license amendments to Facility Operating License Nos. DPR-44 and DPR 56 for PBAPS, Units 2 and 3, respectively, to facilitate implementation of the plant modification for installing the new replacement strainers. We requested that the NRC review and approve our request for license amendments by September 30,1997, in order to support installation of the replacement strainers on Unit 3 during its next refueling outage scheduled for October,1997.
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9709040016 970822 PDR ADOCK 05000277 S.
August 22,1997 Page 2 l
However, as a result of the NRC's continued review of PECO Energy's responses and implementation efforts associated with NRCB 96 03, several additionalissues were identified in which supplementallnformation is needed in order for the NRC to complete its review.
Specifically, in the August 1,1997 letter, the NRC requested additionalinformation conceming some of the design aspects of the replacement strainers.
Accordingly, Attachment i to this letter provides PECO Energy's response to the specific issues identified by the NRC regarding the design of the replacement strainers for PBAPS, Units 2 and 3. The attachment to this letter includes a restatement of these issues followed by 1
our response. This information is being submitted under affirmation, and the required affidavit is provided with this response. and Enclosure 3 contain information proprietary to ABB, ABB requests that the and Enclosure 3 information be withheld from public disclosure in accordance with 10 CFR 2.790 (a)(4). In accordance with 10 CFR 2.790 (b)(1), an affidavit supporting this request to withhold from public disclosure is provided in Enclosure 4.
If you have any questions or require additionalinformation, please do not hesitate to contact us.
Very truly yours, G. A. Hunger, Jr.
Director. Licensing Attachment Enclosures cc:
H. J. Miller, Administrator, USNRC, Region I (w/ attachment / enclosures)
W. L. Schmidt, USNRC Senior Resident inspector, PBAPS (w/ attachment / enclosures) 4 et-
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l COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF YORK l
T. N. Mitchell, being first duly sworn, deposes and says:
i That he is Vice President of PECO Nuclear a Unit of PECO Energy Company; the Applicant herein; that he has r d the attached PECO Energy response to the U. S. Nuclear Regulatory Commission's letter dated August 1,1997 requ: sting additional information regarding PECO Energy's response to NRC Bulletin 96-03, " Potential Plugging of l
Emergency Core Cooling Suction Strainers by Debris in Bolling Water Reactors", for Peach Bottom Facility Operating Lic:nses DPR-44 and DPR 56, and knows the contents thereof; and that the statements and matters set forth therein are l
tru) cnd correct to the best of his knowledge, information and belief.
1 L
Vice President i
l Subscribed and sworn to before me this 22nd ay d
of August 1997.
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Notary Public NoterialSeal i*
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, Notary W M. %a.
Peach Boeom u
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AuguW 22,1997 l
ENCLOSURE 4 Peach Bottom Atomic Power Station, Units 2 and 3 ABB affidavit supporting withholding from public disclosure in accordance with 10 CFR 2.790(a)(4)
(4 Pages)
AFFIDAVIT PURSUANT l
IQ_10_CFR 2J90 l, Ian C. Rickard, depose and say that I am the Director, Operations Lio'nsing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conjunction with the application of Philadelphia Electric Company and in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following documents:
1.
MISC PENG-CALC-059 REV. 00, *Model for Sizing and Evaluating Performance of -
BWR Replacement Strainers with Pleated Surfaces", July 1997 2.
Drawing E 2007085 908-008, Rev. 03," Peach Bottom Units 2&3 RHR Strainer Module", August 1997 3.
Drawing E-2007085 908-010, Rev. 04,
- Peach Bottom Units 2&3 CS Strainer Modules and General Arrangement", August 1997 These documents have been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
M
2-1.
The information sought to be withheld from public disclosure, is owned and has been held in confidence by Combustion Engineering, it consists of the information concerning the test data and methods for calculating Emergency Core Cooling System (ECCS) strainer size and design and fabrication details of ECCS strainers.
2.
The information consists of test data or other similar cata concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the public. Combustion Engineering has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F. M. Stern to Frank Schroeder dated December 2,1974. This system was applied in determining that the subject document herein is proprietary.
4 The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.
5.
The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
6.
Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
e 3-A similar product is manufactured and sold by major a.
pressurized water reactor competitors of Combustion Engineering.
b.
Development of this information by Combustion Engineering required hundreds of thousands of dollars and tens of thousands of manhours of effort. A competitor would have to undergo similar expense in generating equivalent information.
c.
In order to acquire such information, a competitor would also require considerable time and inconvenience to develop test data and methods for calculating ECCS strainer size and to develop an ECCS strainer design.
d.
The information consists of test data and methods for calculating ECCS strainer size and design and fabrication details of ECCS strainers, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus, e.
In pricing Combustion Engineering's products end services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included. The ability of Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
I i'
4-i f.
Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development. In addition, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
gny lanbie Director, Operations Licensing Sworn to before me this Ac9 #
day of 26fu
__,1997
/ Olb Notary Public j / 9)
My commission expires:
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i ATTACHMENT 1 Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information Concerning NRC Bulletin 96-03," Potential Plugging of Emergency Core Cooling Suction Stralners by Debris in Bolling Water Reactors"
August 22,1997 Page 1 of 3 Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional information Concerning PECO Energy Company's Request for Uconee Amendments Associated with ECCS Pump Suction Strainer Plant Modification,
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Question 1.-
What is the maximum outside diameter (O.D.) on which Insulation is Installed? %1 tat is the pipe O.D. M which the breakis postulated?
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Response
i The maximum diameter piping on which insulation is installed is the 28 inch diameter Recirculation System pump suction line piping. The break used to define the debris loading for the strainer design was a 26 inch diameter pipe for the main steam line. The basis for using the smaller line was that the smaller line break exposed a greater number of targets and generated more debris. Both lines were evaluated in order to determine which yielded the most conservative debris generation results.
Question l
2.
Submit stralner prellminaryMnal design (areas, etc.)?
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Response
4 i
The final design for the PBAPS replacement strainer modules has been developed. Enclosure 1 i
contains General Plant Arrangement drawings depicting the replacement strainer locations and j provides drawings depicting the design of the replacement strainer modules.
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i Since our submittal, the design dimensions of the strainers have been finalized. The final volume of water j
displaced and the corresponding difference in heat capacities between the water displaced and the steel of the replacement strainers are each now less than 0.3E This revision does not alter the conclusion that the i
i replacement strainers have no measurable effect on the capabilities of the torus as a heat sink due to their l
increased size.
li Question l
3.
%1aat headloss correlation willyou use to estimate strainer head losses? If you intend to use hdependent testing, have you developed plans forperformance testing? Provide the details on l
the procedures and the head loss data (if available).
Mesponse The head loss correlation used at PBAPS was developed and provided by ABB, and is based on head loss testing performed at the EPRI NDE Test Center, The head loss testing performed by ABB included 4
testing with heavy insulation loads, and therefore, bounds the design and operating conditions for d
i PBAPS, Units 2 and 3. Enclosure 3 contains the requested information conceming the specific head loss correlation. Final testing to verify the head loss correlation was recently completed at the EPRI NDE
-Test Center. A preliminary review of the data from this testing shows that the ABB correlation accurately i
predicts the head loss for the expected debris loads. The test report is in the process of being finalized j
and will be available for review upon request.
l 3
August 22,1997 Page 2 of 3 Question 4.
Is the containment overpressure according to the plant cunent licensing basis? Define the plant current licensing basis.
Response
A containment overpressure value of approximately 9 psl is currently included in the licensing basis of the plants for PBAPS, Units 2 and 3. The use of a 9 psl containment overpressure value was specifically addressed as part of the PBAPS Power Rerate submittal (i.e., letter dated June 23,1993), and our response to a staff RAI ( dated July 20,1994) which was subsequently approved by the NRC as documented in letters dated October 18,1994 and July 18,1995.
Question 5.
Provide additionalInformation clarifying use of the URG bump-up factor used to determine that doubling the corrosion product inventory willincrease calculated head loss by approximately 18%. Include your rationale for using 1000 pounds of sludge rather than miscellaneous particulate debris (e.g., ditt and concrete dust).
(Note that the bump-up factor is intended to estimate Increased head loss associcted with miscellaneous debris rather than corrosion products. The head loss increase arsociated with doubling the corrosion products should be estimated by doubling the corrosion product Inventory in the appropriate head loss correlation and the head loss increase may well exceed 18%
depending upon the correlation used and other conditions.)
Response
Early in the design process, before an estimate of operational debris was available, PECO decided to include an additional 1000 pounds of corrosion products in the desigd debris loading for the strainer to bound any expected operational debris. The discussion conceming the " bump-up" factor with respect to doubling the corrosion product loading was introduced to show that analyzing an additional 1000 pounds of corrosion products in lieu of the estimated operational debris load suggested by the BWROG URG was conservative. it is our intent, with the design of the strainers, to consider an additional 1000 pounds of corrosion products in order to bound the head loss contribution of operational debris such as rust, dust, dirt, paint chips, etc.,
Question 6.
How did you determine the 176% estimate for the operationalmargin for the NUKON debris load? How does this margin relate to the actual strainer sizing using the entire drywellInventory of NUKON (1600 ft')? Also, explain what you mean by operationalmargin.
Response
The estimate of ' operational margin" was derived as follows:
(1800 ft'. 650 ft') /650 ft' = 1,76 or 176% margin.
In this circumstance, PECO Energy defines ' operational margin" as the margin between the total NUKON inventory assumed in designing the strainer (in the case of Peach Bottom, the total drywell inventory of NUKON of 1800 ft') and inventory of NUKON in the zone of destruction multiplied by the transpcrt factor ( 650 ft' x 100%)
which is defined as the maximum expected accident debris loads. Since the strainers to be installed at Peach Bottom are designed for the drywell NUKON inventory, PECO Energy will be able to utilize this margin to offset concerns that may result from future plant modifications, plant transients, etc., We would expect that this margin
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Au0ust 22,1997 Att:chment 1 Pape3cf3 3
i will be available for use, without seeking prior NRC approval, since the margin of safety as defined by the design j
basis of the strainers would not be impacted.
Neit:
Since our original submittal, the debris inventory of the zone of destruction has been finalized. The final debris inventory is 700 ft'instead of 650 ft'. Therefore the final value for operational margin is defined as:
(1800 ft'. 700 ft')/ 700 ft' = 1.67 or 157% margin.
l As a result of the finalized assumptions listed above, and since the maximum poet accident NUKON inventory for j
any given break is expected to be approximately 700 ft'. the inventory for each strainer, when distributed in
,1 proportion to each individual strainer flow versus total ECCS flow, is defined as follows:
RHR system: 188 ft' CS system: 69 ft'
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[ ' ' u0ust 22,1997 I
ENCLOSURE 1 Peach Bottom Atomic Power Station, Units 2 and 3 (M-4853 AND M4854)
General Plant Arrangement drawings depicting the replacement stralner locations (2 sheets)
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9709)0 003 3 l
NC9/000Sb i
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