ML20236G518

Submits Response to NRC 980403 RAI Re Util Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions

ML20236G518
Person / Time
Site:	Farley
Issue date:	06/29/1998
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-96-06, GL-96-6, NUDOCS 9807060281
Download: ML20236G518 (16)

Text

{{#Wiki_filter:_ _ _ _ + Dave Morey Szuthern Nuclxt Mce President Optr: ting Company Farley Project P.O. Box 1295 j J Birmingham. Alabama 35201 Tel 205.992.5131 SOUTHERN h June 29,1998 COMPANY Energyro Serve YourWorld" Docket Nos.: 50-348 10 CFR 50.4 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,DC 20555 Joseph M. Farley Nuclear Plant (FNP) . Response to Reauest for Additional Information Related to Generic Letter 96-06 Ladies and Gentlemen: On September 30,1996, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 96-06, " Assurance ofEquipment Operability and Containment Integrity During Design-Basis Accident Conditions." Southern Nuclear's (SNC's) 120 day response to GL 96-06 was provided by letter dated January 27,1997. On April 3,1998, a Request for Additional Information (RAI) Related to GL 96-06 was issued to SNC. Attached is our response to this RAI. Consistent with our original GL 96-06 response, SNC has detennined that the containment air cooler cooling water system (service water) is not susceptible to either waterhammer or two phase flow conditions during postulated accident conditions. / A Service Water System Operational Performance Inspection (SWSOPI) was conducted by the NRC on August 16 through September 3,1993. The issue of containment air coolers L g being susceptible to waterhammer resulted in unresolved item (URI) 50-348, 364/93-13-02. / r i SNC letter dated November 5,1993, provided the results of an updated waterhammer analysis. On February 16,1994, representatives of SNC met with NRC Region II representatives in Atlanta to discuss the status of the URI. Following the discussion and calculation review, the NRC representatives were satisfied with the FNP waterhammer analysis and the URI was subsequently closed. NRC staff personnel may find the results of the SWSOPI useful in supporting their evaluation. 9807060291 990629 PDR ADOCK 05000348 P POR

4 U.S. Nuclear Regulabry Commission Page 2 Ifyou have any questions, please advise. Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY b Dave Morey EWC/ cit:RAI9606B. doc

Enclosure:

Response to RAI Related To Generic Letter 96-06 cc: Mr.L. A.Reyes, RegionII Administrator { Mr. J. I. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident Inspector i l l 1 l i i 1 i i I l

o. 4 l 1 i ENCLOSURE Response to Generic Letter 96-06 RAI

TNP Response to GL 96-06 RAI i GL 96-06: " Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Conditions" Backaround: During the Service Water System Operational Performance Inspection (SWSOPI) conducted by the NRC on August 16 through September 3,1993, potential waterhammer concerns were raised by the inspectors. Following the review of the existing service water system waterhammer calculation (SM.-ES-89-1524-001, Rev.1), an unresolved item (URI) 50-348, 364 / 93-13-02 was documented in NRC Inspection Report 93-13 stating, "Certain assumptions associated with initial SW temperature, time to energize SW pumps following an LOSP, heat input into the SWS and SWS backpressure control appeared to be nonconservative and could adversely affect the results." In order to resolve all aspects of the URI, SNC/SCS revised the existing FNP waterhammer analyses with the assistance ofDr. C. S. Martin' of the Georgia Institute of Technology. The. l results of these analyses were documented in calculations SM-REA-94-0417-001, Rev. O and SM-ES-89-1524-001, Rev. 3. The revised waterhammer analyses (Dr. Martin's analysis, SM-ES-89-1524-001) determined that a peak pressure of 150 psig would occur upon the collapse of a vapor cavity formed at a temperature of 164*F in the service water containment cooler discharge piping. Provided the service water temperature does not reach 164 F, the resulting peak pressure from void collapse would not result in any damage to the containment coolers or the service water piping since the design ratings of these components are 200 psig and 150 psig, respectively. Finally, calculation SM-REA-94-0417-001 determined that the maximum service water temperature in the containment cooler discharge during the LOCA/LOSP event is 119"F. Since the maximum calculated temperature is well below the temperature at which a vapor cavity collapse would result in a 150 psig peak pressure, no potential damaging vapor cavity will form or potential damaging waterhammer will occur. In addition, the results of these analyses were presented to the NRC Region II representatives in Atlanta, Georgia, on Febiuary 16,1994. Following this presentation and the NRC review of the design calculations, the inspector reached the same conclusions as SNC (i.e., a potential damaging vapor cavity will not form, arid thus, waterhammer will not occur), and the URI was closed in Inspection Report 94-21, dated September 29,1994. One of the requested actions from Generic Letter (GL) 96-06 was to " determine if containment air cooling systems are susceptible to either waterhammer or two phase flow i conditions during postulated accident conditions." The FNP 120-day response re-iterated the conclusions of the FNP documented waterhammer analyses that was presented and reviewed by the NRC in 1994, which stated the maximum service water tempeinture downstream of the containment coolers followirig a LOCA coincident with an LOSP is significantly less than 8 Dr. Martin is a recognized expert in waterhammer analyses, and his research papers have been utilized in the development of the NRC NUREG/CR-5220," Diagnosis of Condensation-Induced Waterhammer." E-1

l (.- ~ FNP Response to GL %-06 RAI the temperature required to form a potentially damaging vapor cavity. The primary reason for the service water temperature remaining relatively low is the reduced, but continued, service water flow through the containment coolers when the pumps are stopped. The continued flow is due to service water pump coastdown and the FNP physical configuration l of the service water system (i.e., gravity). Since a vapor cavity of the size to potentially cause damage will not form, waterhammer will not occur when the pumps are restarted. The FNP waterhammer analyses / calculations were performed in accordance with the SCS QA Program and calculation procedures which require documentation and verification of computer programs, documentation and review of assumptions r.nd design inputs, independent verification, and consideration of" worst case" single failures and analysis uncertainties. The results of the waterhammer analyses determined the service water system is capable of performing its safety function and meets the design and licensing basis as documented in the safety analysis report for FNP. Furthermore, the NRC inspectors concurred with the analyses results following the detailed presentation by SNC/SCS and the review of the design calculations. Based on the previous presentations to the NRC and NRC l review ofFNP calculations, SNC believes waterhammer and two-phase flow in the service water system to containment coolers following a LOCA/LOSP has been adequately evaluated, and the following responses are provided. Ouestion 1: If a methodology other than that discussed in NUREG/CR-5220, " Diagnosis of Condensation-Induced Waterhammer," was used in evaluating the effects of waterhammer, describe this alternate methodology in detail. Also, explain why this methodology is applicable and gives conservative results for the Farley units (typically accomplished through f' rigorous plant-speci6c modeling, testing, and analysis). FNP Response: - The methodology utilized to evaluate the effects of waterhammer included modeling the service water system to the containment coolers using computer code AWHAM to determine the temperature at which a vapor cavity of sufficient size would form, and upon its collapse, could potentially result in a peak pressure equal to the design pressure of the most limiting l component. The methodology and equations utilized in the AWHAM computer code for the l-FNP waterhammer analyses are consistent with the methodology and calculations presented in NUREG/CR-5220. This is the same methodology and waterhammer analyses presented in detail, reviewed, and found to be acceptable by the NRC in 1994 as documented in Inspection Report 94-21 (see background discussion). Calculations are available for review at the SNC corporate office. Ouestion 2a: For both the waterhammer and two-phase flow analyses, identify any computer codes that l were used in the waterhammer and two-phase flow analyses and describe the methods used l to benchmark the codes for the specific loading conditions involved (see Standard Review ] Plan Section 3.9.1). E-2 [.

l ~ FNP Response to GL %06 RAI j 1 FNP Response: The FNP waterhammer calculations utilized computer codes AWHAM (developed by Dr. ] Martin), MATHCAD version 4.0, and COOLNUC version 2.0. As required by the SCS QA program and calculation procedure, verification of these computer codes is documented in the calculations. Verification of the computer code AWHAM is provided by EPRI Report No. NP-6766, Volume IV, "Waterhammer Prevention, Mitigation, and Accommodation - Programs 1 Benchmark Problems Comparative Study," EPRI Research Project 2856-3, July 1992. EPRI provided benchmark ~ problems, compared the results of benchmark problems from various computer codes, and performed detailed reviews of the computer code capabilities and theoretical bases (including AWHAM) The EPRI report summarizes this study and states the AWHAM results compare reasonably well to the benchmark problem reference data with respect to the magnitude, shape, and time of the predicted peak pressure. Verification of the COOLNUC computer code is provided in the FNP waterhammer calculation by solving a problem previously performed by another methodology in an existing approved calculation. The COOLNUC computer code results for the problem are compared to the results in the existing calculation and determined to be acceptable. In addition, COOLNUC version 2.0 is maintained and verified by American Air Filter Company under their 10 CFR 50, Appendix B program. Similarly, verification ofMATHCAD is provided in the FNP waterhammer calculation by solving additional, randomly chosen, heat exchanger problems using the MATHCAD and the COOLNUC codes and comparing the results. Verification ofMATHCAD was determined to be acceptable based on an average error of 1.5% between the MATHCAD and COOLNUC results for these additional problems. Ouestion 2b: For both the waterhammer and two-phase flow analyses, describe and justify all assumptions and input parameters (including those used in any computer codes) such as amplifications due to fluid structure interaction, cushioning, speed of sound, force reductions and mesh sizes, l and explain why the values selected give conservative results. Also, provide justification for omitting any effects that may be relevant to the analysis (e.g., fluid structure interaction, flow induced vibration, erosion). FNP Resoonse: The FNP waterhammer design calculations have documented the appropriate and conservative assumptions and inputs in the calculations as required by FNP calculation j procedure. These conservative assumptions and design inputs have been reviewed and verified to be acceptable and consistent with the calculation methodology and conclusions. Assumptions and inputs utilized in the computer code AWHAM relative to amplifications due to fluid structure interaction, cushioning, speed of sound, force reductions, mesh sizes, flow l E-3 w _- _ _ -_ - ___-____ ___-_. . _ _ _ _ _ _ _ _ = _ _.

FNP Response to GL 9646 RM induced vibration, and erosion have been reviewed and determined to be acceptable as part of the detailed EPRI review of the computer code capabilities and theoretical bases. l Furthermore, the FNP waterhammer analyses (including the assumptions and inputs) were presented in detail and reviewed, as described above, by the NRC and found to be acceptable as documented in Inspection Report 94-21. SNC will provide copies of the calculations for NRC review at the SNC corporate office upon request. J Ouestion 2c: Provide a detailed description of the " worst case" scenarios for waterhammer and two-phase flow, taking into consideration the complete range of event pos:,ibilities, system configurations, and parameters. For example, all waterhammer types and water slug ) scenarios should be considered, as well as temperatures, pressures, flow rates, load combinations, and potential component failures. Additional examples include: the effects of void fraction on flow balance and heat transfer; e the consequences of steam formation, transport, and accumulation; e cavitation, resonance, and fatigue effects; and e erosion considerations. j e FNP Response: l The appropriate " worst case" single failures, system configuration, and system parameters including heat transfer properties have been documented, reviewed, and verified in the FNP waterhammer design calculations. The " worst case" scenarios evaluated in the FNP j waterhammer calculations are consistent with the licensing and design bases of the service water and containment cooling systems. The following is: a) the statement of problem and the limiting service water waterhammer event, b) the acceptance criteria, and c) the description of the cases analyzed as documented in the FNP service water waterhammer calculation SM-ES-89-1524 001, Rev. 3. This is the same calculation which was previously reviewed and found acceptable by the NRC as documented in Inspection Report 94-21. a) Statement of Problem and Limiting Service Water Waterhammer Event As stated in the waterhammer calculation: Waterhammer events occur most frequently in liquid systems as a result of either rapid valve closure or pump stoppage and restart. Waterhammer induced by rapid valve closure is unlikely as most valves in the FNP service water system have stroke times of 30 seconds or greater. In a system with pumps that can autostart, pump stoppage and restart is usually the most serious transient that can occur. The stoppage can result in water column separation or vapor cavity fonnetion, which collapses upon system repressurization following pump restart. Based on this information, the limiting waterhammer event is postulated as follows: ) E-4

FNP Response to GL 96-06 RAI , A Loss of Coolant Accident (LOCA) occurs in one unit concurrently with a site LOSP, causing a loss of power to the service water pumps on both trains of both units. As the service water pumps coast down, vapor cavities may begin to form in the service water system or components at higher system elevations. Following the LOSP, the diesel generators start and load the service water pumps. Two service water pumps will automatically be sequenced on to each train. Since a LOCA has occurred, both pumps will start between 11 and 23 seconds following the LOSP. As the service water pumps accelerate, the service water system repressurizes causing any vapor cavities that have formed to collapse. This vapor cavity collapse rejoins the fluid columns resulting in a waterhammer that the system sees as a pressure spike. b) Accentance Crite-b > Should waterhammer occur in the Farley Nuclear Plant service water system when the service water pumps are automatically restarted following a loss of offsite power (LOSP), the resulting pressure spikes must not exceed the design pressure of any safety-related service water piping or component. This will ensure that the FNP service water system can provide its safety-related functions following a waterhammer event. c) Analyzed Cases Two series of cases were analyzed which envelop the pressure conditions the system could experience following a LOCA concurrent with a LOSP. The first series of cases was analyzed with normal back pressure on the system. For these cases, it is assumed that the service water system is discharging flow through the standpipe / surge tank at its normal elevation of 190'-0." Additionally, all AOVs have not yet moved to their loss-of-air positions and remain throttled. The second series of cases were analyzed with the lowest possible system back pressure. For these cases, it is assumed that the standpipe has fallen, resulting in a double-ended guillotine break at the ground. Therefore, the service water system is discharging flow at the standpipe grade elevation of 154'-6". Additionally, all AOVs have moved to their loss-of-air positions, most moving to the wide open position, resulting in minimum back system pressure. Ouestion 2d: For both the waterhammer and two-phase flow analyses, confirm that the analyses include a - complete failure modes and effects analysis (FMEA) for all components (including electrical and pneumatic failures) that could impact performance of the cooling water system and confirm that the FMEA is documented and available for review, or explain why a complete and finly documented FMEA was not performed. FNP Resoonse: 'A complete and fully documented FMEA is not required to determine the " worst case" L scenario for the FNP service water waterhammer analysis. Per the FNP licensing and design bases, only ONE single failure is required to be postulated in conjunction with or following a design basis accident. Considering any ONE single failure of any component in the service E-5

I FNP Response to GL 96-06 RAI water or associated interfacing systems, including any electrical and pneumatic failures, a waterhammer event more severe than analyzed would potentially occur in only one service water train. That is, the other train of service water would perform as analyzed without any damage occurring from waterhammer following the pump restart. The service water system and the containment coolers are designed such that their safety functions can be performed following the complete loss of a service water train. Based on this, a complete and fully documented FMEA is not warranted and has not been performed. l Ouestion 2e: For both the waterhammer and two-phase flow analyses, explain and justify all uses of "engineeringjudgment." FNP Response: The FNP waterhammer analysis does not utilize any engineering judgments; however, assumptions and input parameters have been documented, reviewed, and verified in the FNP waterhammer calculations. The FNP waterhammer analyses (including the assumptions and inputs) were presented in detail, reviewed by the NRC, and found to be acceptable as ~ documented in Inspection Report 94-21. These calculations are available for review at the SNC corporate office upon request. L Ouestion 3: L Determine the uncertainty in the waterhammer and two-phase flow analyses, explain how the uncertainty was determined, and how it was accounted for in the analyses to assure . conservative results for the Farley units. FNP Resoonse: The computer codes utilized in the FNP service water waterhammer analyses have been verified u described in the response to question 2a. The result of the EPRI benchmark verification has determined the AWHAM computer code is capable of reasonable and accurate predictions for waterhammer events. Also, the MATHCAD and COOLNUC computer codes have been verified to provide accurate results for modeling heat exchangers. Based on verification of the computer codes and the FNP waterhammer analyses redts, adequate margin between the predicted service water octlet temperature of 119 F and the critical temperature of 164'F is available to account for any analysis uncertainty. Questinai Confirm that the waterhammer and two-phase flow loading conditions do not exceed any design specifications or recommended service conditions for the piping system and components, including those stated by the equipment vendors; and confirm that the system will continue to perform its design-basis functions as assumed in the safety analysis report for the facility. E-6 4

FNP Response to GL 96-06 RAI FNP Response: As described above in question 2c, the acceptance criteria for FNP's waterhammer analysis was that the resulting peak pressure from a vapor cavity collapse must remain below the design pressure of the most limiting component (150 psig). The maximum calculated service water temperature remains significantly below the temperature required to form a vapor cavity which would result in a peak pressure of 150 psig upon collapsing; therefore, the containment coolers and service water system are capable of performing their design-basis functions as assumed in the safety analysis report for FNP. Ouestion 5: Provide a simplified diagram of the system, showm' g major components, active components, relative elevations, lengths of piping runs, and the location of any orifices and flow restrictions. FNP Responst Attached are Figures F-1, F-7, and F-10 from the FNP Service Water Functional System Description. Included on these figures are the major components, relative elevations, and approximate piping lengths associated with the containment coolers. E-7

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