ML20236V756
| ML20236V756 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 07/23/1998 |
| From: | Eric Simpson Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N98369, NUDOCS 9808040188 | |
| Download: ML20236V756 (23) | |
Text
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e.
,o.
e Pubhc Servce Electnc and Gas company E. C. Simpson Public Service Electnc and Gas Company PO Box 236. Hancocks Bndge. NJ 08038 609-339 1700 Lena Vce Pminent Nuclear Engmeeong JUL 281998 LR-N98369 LCR H98-02 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 l
Gentlemen:
SUPPLEMENT TO A REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS ULTIMATE HEAT SINK TEMPERATURE LIMITS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 On June 12,1998, via letter LR-N98274, Public Service Electric & Gas (PSE&G)
Company transmitted License Change Request (LCR) H98-02 to the NRC to request a revision to the Technical Specifications (TS) for the Hope Creek Generating Station.
Specifically, LCR H98-02 requested, in part, a revision to the Hope Creek Ultimate Heat Sink (UHS) temperature limits contained in the TS. On July 17,1998, the NRC issued a Request for Additional Information (RAI) as a result of their review of LCR H98-02.
PSE&G's response to the RAI questions is contained in Attachment 1 of this istter.
PSE&G has determined that the information contained in the attachment to this letter does not alter the conclusions reached in the 10CFR50.92 No Significant Hazards analysis previously submitted with LCR H98-02. In accordance with 10CFR50.91(b)(1),
a copy of this submittal has been sent to the State of New Jersey.
Should you have any questions regarding this request, please contact James Priest at
.609-339-5434.
Sincerely, 1
s Affidavit l,
Attachment
,v9 9808040188 980723 l
PDR ADOCK 05000354t I
p PDR h UMArans
3
~ Document Control Desk g gg g LR-N98s69 C
Mr. H. Miller, Administrator - Region l U. S. Nuclear Regulatory Commission 475 Allendale Road
' King of Prussia, PA 19406 Mr. R. Ennis Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. S. Pindale (X24)
USNRC Senior Resident inspector - HC Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625 I
b5-4933 l
Document Control Desk LR-N98369 JUL 231998 JPP BC Senior Vice President - Nuclear Operations (X04)
Senior Vice President - Nuclear Engineering (N19)
General Manager - Hope Creek Operations (HO7)
Director-QA/NT/EP (X01)
Director - Licensing / Regulation and Fuels (N21)
Director-Design Engineering Manager - Financial Control & Co-Owner Affairs (N07)
Program Manager - Nuclear Review Board (N38)
Manager - Hope Creek Operations (H01)
Manager - System Engineering - Hope Creek (H18)
Manager-Hope Creek Licensing (N21)
R. De Night (N29)
J. Keenan, Esq. (N21)
NBU RM (N64)
Microfilm Copy Files Nos.1.2.1 (Hope Creek),2.3 (LCR H98-02) i l
REF: LR-N98369 LCR H98-02 JtJL 23 m STATE OF NEW JERSEY SS.
COUNTY OF SALEM E. C. Simpson, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek Generating Station, Unit 1, are true to the best of my knowledge, information and belief.
Subscribed and Sworn to before me this c) 3 day of (d
.1998 hh] 0. fd Notary Nblic of NekJersey EUZABETH J. KIDD
$"0TW PUSUC OF NEW JERSEY My Commission expires on
"""""*n E9% ADM 25. 2000
Docum:nt Contral D:ck LR-N98369 Attachm:nt 1 LCR H98-02 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 RESPONSE TO NRC RAI Questions from Plant Systems Branch 1.
Technical Specification (TS) Amendment 106 is referred to in the June 12, 1998, submittal. However, TS Amendment 106 increased the ultimate heat sink (UHS) water level and decreased the UHS temperature limit, and the June 12,1998, submittal proposes to increase the UHS temperature limit.
How can these analyses be compared? What changed between the analysis performed in Amendment 106 to justify the 85 F UHS temperature limit and the June 12,1998, submittal to justify the 89 F limit (e.g...
uncertainties, assumptions, methodology)?
The methodology of the UHS analyses used for the Technical Specification Amendment 106 was used for the current LCR submittal. No changes were made to the methodology or the uncertainty analysis; however, several minor changes have been made to the assumptions used in the analyses. The individual component level heat loads delivered to Safety Auxiliaries Cooling System (SACS) were more accurately defined in the current LCR submittal. The l
SACS heat loads used in the previous UHS LCR submittal were based on original Bechtel design calculations. These original calculations were revised to ensure that they accurately reflect the current as-built configurations, identify overly conservative assumptions, and to ensure that the calculations are performed consistent with current industry standards. The revised heat loads were used in the LCR H98-02 submittal. The changes had an insignificant effect on the UHS temperature limit.
l The SACS hydraulic analysis was redone based on the benchmarking data collected during our last refueling outage (RF07). The revision of the SACS l
hydraulic analysis produced no significant changes. The major change between the analyses from last year and this year is the assumption of the SACS cooling water temperature limit. The maximum SACS heat exchanger outlet temperature limit was assumed to be 95'F. This limit was raised to a value of 100 F during the pmt-accident design conditions.
l The limit was not raised in the normal configuration and under certain allowable Technical Specification alignments (i.e., one SACS pump operable per loop).
Page 1 of 19 l
1 1
Documint Centrol D <::k LR-N98369 Attachmtnt 1 LCR H98-02 The normal configuration temperature limit was not raised since the maximum allowable suppression pool temperature during normal operations is 95 F. Since SACS cooling water is used to cool the suppression pool during normal operation via the Residual Heat Removal (RHR) heat exchanger,100*F SACS cooling water could nos perform this design function.
The limit was not raised in the operational alignment allowed by Tech Spec 3.7.1.1 (i.e., one SACS pump operable per loop), since this degraded condition could not produce the required flows to the RHR heat exchanger necessary with a SACS cooling water temperature of 100 F.
No changes were made to the minimum river water level in the analyses conducted for LCR H98-02. The minimum river water level used is the same as that currently in TS LCO 3.7.1.3.
2.
Proposed TS 3.7.1.3 states that with river water temperature in excess of 85 F, continued plant operation is permitted provided that both emergency overboard discharge valves are open and the emergency discharge pathways are available. How does the licensee ensure that power is removed to the breakers for the emergency overboard discharge valves and the station service water system (SSWS) header isolation valves to prevent inadvertent closure of the associated motor-operated valves?
In a PSE&G letter, LR-N97466, dated August 25,1997, information was provided concerning operation of the emergency overboard discharge valve operation in order to su: port TS Amendment No.106. In that letter, PSE&G stated that:
"To allow continued plant operation with river water temperature above 85.0 F, operators will be required to open the EOBs and their respective breakers; otherwise, the plant will be required to enter Hot Shutdown i
conditions within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to comply with TS. These operator actions are prescribed in the SSWS abnormal procedure and consist of l
remotely opening the two EOBs and locally opening breakers for four valves. The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to reach Hot Shutdown (plus any additional time l
provided by anticipating river water temperatures rising above 85.0 F) will l
provide sufficient time (including anticipated travel time) for equipment operators to complete the local action of opening the four breakers. These operator actions and use of the abnormal procedure have been observed Page 2 of 19 1
Docum:nt Centrcl De k LR-N98369 Attachmtnt 1 LCR H98-02 during training of the operating crews. This training has had successful results. The ready availability of river water temperature information in the control room and operator awareness of TS requirements will ensure that either the actions required to justify continued plant operation with river water temperature above 85.0 F are completed or the actions required to place the plant in a safe shutdown condition are taken."
To support the changes requested in LCR H98-02, no changes to this response are required. Step 4.12.4 of the SSWS abnormal procedure, HC.OP-AB.ZZ-0122, will continue to implement this requirement.
3.
The submittal includes the removal of several operator actions due to t
automatic actions that occur during loss of offsite power (LOP) conditions, etc. Assuming that these operator actions were proceduralized, were 10 CFR 50.59 screenings performed on the removal of these actions? Since some of the operator actions were reduced due to automatic actions, did I
the licensee account for the time that an operator would take to verify the automatic actions?
The LCR H98-02 submittal does not remove any operator actions due to automatic actions that occur during LOP conditions. The submittal does l
state that some post-LOP actions are no longer required (i.e., the throttling l
and isolation of SSWS supply to the RACS heat exchangers) since the l
analyses of SSWS/ SACS performance used to justify the proposed UHS l
temperature limits no longer credit these actions. In addition, there are no l
automatic actions that need to be verified in this situation. The valves will remain in their position in the post-LOP scenario, with no operator verification necessary. Any 10CFR50.59 evaluations of procedure changes to eliminate these operator actions would take place only after l
NRC approval of the proposed UHS temperature limits is received. These procedure revisions will ensure that the station is operated in a manner that is consistent with its design and licensing basis.
i 4.
The June 12,1998, submittal states that in cases where SSWSIsafety auxiliary cooling system (SACS) temperatures cannot be maintained and a LOP and/or loss of coolant accident (LOCA) occurs, the current SSWS abnormal operating procedure will direct operators to isolate SACS flow the fuel pool heat exchangers for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. What effect does this I
l have on the spent fuel pool temperature and the time-to-boil?
Page 3 of 19 L
e-______--_______-....__
Docum:nt C:ntral De:k LR-N98369 Attachm:nt 1 LCR H98-02 l
if the spent fuel pool heat exchangers are isolated (which will occur only if post transient conditions result in SACS temperatures exceeding their maximum allowable limit), the consequences will be an in::reased fuel pool temperature. If it is assumed that the fuel pool is at its maximum normal operating temperature and the fuel pool cooling is isolated, the fuel pool would reach boiling temperatures at times greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with the current decay heat loads in the spent fuel pool. With the maximum end-of-life decay heat loads in the fuel pool, the time until boiling is approximately 17.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. However, the decay heat load in the suppression pool will be low enough to permit SACS flow to be re-established to the fuel pool heat exchangers such that boiling is prevented under these end-of-life conditions. PSE&G will ensure that Hope Creek procedures implement appropriate controls to prevent boiling in the fuel pool in post-transient conditions.
5.
Proposed TS 3.7.1.2.a.3 allows operators to assess the operability of a f
SACS loop when its associated SSWS loop is declared inoperable. How is this consistent with Generic Letter 91-18? How would this be controlled?
As stated in the LCR H98-02 submittal, Generic Letter 91-18 (Section 6.12 of of Generic Letter 91-18, dated November 7,1991) discusses the need to evaluate supported system operability when a support system is declared inoperable. Since SSWS directly supports operability of the SACS system, an evaluation of SACS loop operability must take place when its associated SSWS loop is declared inoperable. This requirement is already contained in the SSWS abnormal operating procedure. The proposed SSWS LCO Action Statements and the existing SSWS abnormal procedure will be used to control this requirement.
6.
Discuss the proposed amendment as related to each of the following Hope Creek Generating Station (HCGS) licensee event report (LERs): 96-022,96-015,96-009,95-037,95-015, and 90-014. Explain how these situations are not a problem or will not reoccur for HCGS.
Hope Creek has written several LERs concerning UHS /SSWS/ SACS design l
basis deficiencies. PSE&G has taken appropriate action to resolve the deficiencies identified in those LERs. Specifically, Hope Creek has taken the l
following actions:
l LER 90-014-00 described an event where the UHS temperature limit was non-conservatively high due to errors in the Hope Creek AE design Page 4 of 19
Docum:nt Crntr:I De k LR-N98369 Attachm:nt 1 LCR H98-02 i
l calculations. PSE&G has thoroughly reviewed the AE calculations for j
UHS /SSWS/ SACS performance and appropriately modeled and analyzed l
system performance. The issuance of Hope Creek TS Amendment No.106 l
provided a correct UHS temperature limit based upon Hope Creek design basis information.
LER 95-015-00 is not related to UHS /SSWS/ SACS issues discussed in LCR H98-02.
LER 95-037-00 described an event where both SACS loops were declared inoperable due to inappropriately low minimum temperature limits for SAGS operation. SACS operating configurations have been reviewed and i
appropriate restrictions have been placed on SACS operation to maintain temperatures within design basis limits.
LER 96-009-00 documented an event where SSWS/ SACS throttle valves
)
were mispositioned, resulting in a configuration that did not match design basis evaluations of SSWS/ SACS performance. Hope Creek has since performed SSWS and SACS benchmarking to ensure that the existing plant I
configurations are bounded by the design analyses supporting the current UHS TS temperature limits. In addition, procedure requirements have been added to help ensure that throttle valve positions are maintained consistent 1
with design basis assumptions.
LER 96-015-00 described an event where the SSWS/ SACS design basis analyses did not account for worst case conditions postulated in the Hope Creek licensing basis. As stated in PSE&G's LCR H97-02 application,
)
Hope Creek has thoroughly reviewed the UHS /SSWS/ SACS design basis analyses to determine UHS temperature limits. The issuance of Hope Creek TS Amendment No.106 provided a correct UHS temperature limit based upon Hope Creek design basis information.
LER 96-022 00 documented additional discrepancies between SSWS/ SACS operation and design basis assumptions. As stated in PSE&G's LCR H97-02 application, Hope Creek has thoroughly reviewed l
the UHS /SSWS/ SACS design basis analyses to determine UHS 1
temperature limits. In addition, procedural controls have been implemented to ensure that SSWS/ SACS is operated in a manner that is consistent with design basis assumptions. The issuance of Hope Creek TS Amendment l
l Page 5 of 19
Docum:nt Crntr:I De:k LR-N98369 Attachm:nt 1 LCR H98-02 No.106 provided a correct UHS temperature limit based upon Hope Creek design basis information.
No additional actions are required to address the deficiencies identified in the above LERs. Accordingly, the situations identified in the referenced LERs should not reoccur at Hope Creek.
7.
The licensee's analyses assume design fouling or maximum fouling conditions for the heat exchangers. Explain how this will provide conservative results, as opposed to clean heat exchangers, for the cooling water exit temperatures. Alternatively, provide the calculation (s) using conservative heat transfer values that will result in the maximum cooling I
water (i.e., SACS, SSWS, UHS) temperatures.
The maximum fouled conditions were used for the SACS heat exchanger to minirnize cooling and heat transfer to the SSWS system. Maximum fouling and minimum flow rates were also used for the SACS system coolers. Maximum fouling was used to maximize the process side fluid temperatures (i.e., room temperatures, lube oil temperatures, etc.). The heat loads delivered to each of the SACS coolers were individually reviewed and calculated. Based on these reviews, the heat loads from equipment, pumps, and rooms were generally found to be constant (i.e., suppression pool temperature is based on the constant heat loads of decay heat, heat loss from motor bearing, etc.).
When the heat loads delivered to the SACS coolers are constant, the process side fluid temperature will adjust based on fouling conditions until the constant heat load is removed and equilibrium reached. Under these assumptions, the fouling conditions on the individual coolers will have little affect on the heat loads transferred to the SACS loop and consequently the SACS temperature. This approach conservatively maximizes the process side fluid temperatures.
8.
Proposed TS 3.7.1.3, uses the terms " river water temperature" and
" ultimate heat sink temperature." Confirm that those are the same i
temperature measurement. Explain where it/they are measured; whero
{
it/they read out; if any alarms exist and the temperature at which they i
alarm.
1 For the purposes of satisfying the TS LCO 3.7.1.3 requirements, the ultimate I
j heat sink (or river water) temperature measurement is taken from the SSWS I
l pump discharge temperature element. In a PSE&G letter, LR-N97466, dated Page 6 of 19 i
Docum:nt Centr:I D=k LR-N98369 Attachmant 1 LCR H98-02 i
\\
August 25,1997, information was provided concerning UHS temperature monitoring in order to support TS Amendment No.106. In that letter, PSE&G stated that:
" River water temperatures at Hope Creek generally do not rise or fall rapidly, but change gradually as the tide changes. River water temperature at the SSWS intake structure is continuously indicated and recorded on a strip chart recorder in the control room. In addition, control room alarms annunciate when SSWS pump discharge temperature reaches 80 F and will alarm again at two degree intervals above 80 F.
This computer data point for SSWS pump discharge temperature provides direct indication (no detailed operator analysis is required) of UHS l
temperatures, which is used to determine compliance with the TS LCO and Action Statements.
Upon receipt of these control room alarms, operators would ensure that appropriate actions are taken to comply with the TS requirements... The i
ready availability of river water temperature information in the control room and operator awareness of TS requirements will ensure that either the actions required to justify continued plant operation with river water temperature above 85.0 F are completed or the actions required to place j
the plant in a safe shutdown condition are taken."
Operators would use the temperatures as indicated by the temperature element on the discharge of the operating SSWS pumps to determine compliance with TS 3.7.1.3.
9.
In the current action statement for TS 3.7.1.3, certain equipmer t is listed that must be operable when the river water temperature is above 85 F. The licensee proposes to change this to above 88 F and remove operability l
requirements between 85 F and 88 F. Please justify this reduction.
l The current lower UHS temperature limit is 85 F. This temperature lims is based l
on conditions resulting from combinations of design basis failures concurrent with l
equipment outages permitted by Technical Specification Allowed Outage Time l
(AOT) Action Statements. The limiting case occurs with only one (1) SSWS pump l
per loop and two (2) SACS heat exchangers per loop available. A SACS temperature limit of 95 F was used in the current analysis for this alignment.
Page 7 of 19
Drcum:nt Centrcl Denk LR-N98369 Attachm:nt 1 LCR H98-02 In order to raise the UHS temperature, the alignment assuming one SSWS pump per loop was re-analyzed using a SACS temperature limit of 100 F. This current limiting case is no longer the limiting case when a SACS temperature of 100 F is used. The lower limiting case for the new proposed UHS temperature limits i
became one SACS pump per loop. The UHS temperature limit for this case is 88*F. This case is limiting since a maximum SACS cooling water temperature of only 95 F is allowed.
The justification from changing the lower UHS Technical Specification limit from 85'F to the proposed value of 88 F is based on new analyses. A UHS temperature up to and including 88*F can support the safe plant operation under all permitted alignments and single failures. While the proposed 88'F limit can support safe plant operations under all permitted configurations and postulated single failures, the Emergency Overboard Valves are opened at 85 F to eliminate the valve as a potential single failure.
10.
Provide flow balance diagrams of the various configurations that will be allowed for the SSWS, SACS, etc. Specifically, but not limited to the scenarios for the maximum allowed UHS temperature, LOP /LOCA, and worst case scenario (if not one of the previous). Describe the conditions l
used in the evaluation.
i
.The SACS flow rates and flow distribution have been obtained by generating a thermal / hydraulic computer model of the SACS system using the computer progem PROTO-FLO. To ensure that the SACS flow model accurately predicts the flow rates, the start-up test data was reviewed to determine the SACS system l
throttle valve positions and to " benchmark" the SACS hydraulic model. During Refueling Outage Number 7 (RFO7), actual system flow versus differential pressure data was collected to further refine the original benchmarking of the SACS hydraulic model. This would ensure that model reflects the current conditions and that no significant changes have occurred since the original start-up test. A similar benchmarked model exists for the SSWS system.
l The SACS hydraulic model was used to determine the SACS system flow rates under various operating scenarios and alignments. The model was used to simulate the worst case accident conditions, degraded system conditions, and single failures. The alignments included the normal configuration, LOP /SSE, LOP, and LOCA/ LOP. The hydraulic analysis was performed to determine the minimum flows to the SACS components and coolers. The maximum degraded pumps i
Page 8 of 19
D:cumtnt Central De::k LR-N98369 Attachm:nt 1 LCR H98-02 were used in the hydraulic analysis. The SACS hydraulic modelis documented under design calculation EG-46.
11.
Similar to Question 10, provide heat balance diagrams. Relate these, if i
appropriate, to the PROTO-FLO data sheets used in the evaluation.
The heat balance distribution for the SACS system is shown in Table 9.2-4 of the UFSAR. The basis for the UFSAR table is the design calculation EG-0020.
l 12.
In attachment 4, Sections 4.1.4,4.1.7,4.1.8,4.1.9, and 4.1.10, the licensee describes automatic or conditional loads. How were these loads used in the evaluation?
The heat loads in 4.1.4,4.1.7,4.1.8,4.1.9, and 4.1.10 are assumed to be transferred to the SACS loop based on the operational conditions. For example, 1
the Core Spray pump heat loads are only assumed if the CS pumps are signaled to run under the analyzed scenario. This will maximize the heat that is transferred to the SACS loop. If it is possible that a component (and associated heat load) could run, the heat !oad was included.
13.
The licensee's analysis for the residual heat removal (RHR) heat exchanger assumes no tubes are plugged. Verify that currently no RHR heat exchanger tubes are plugged.
PSE&G has confirmed that no RHR heat exchanger tubes are plugged.
14.
The licensee's analysis for the RHR heat exchanger is only valid if a minimum RHR flow rate of 10,000 gpm is supplied. How is this parameter ensured?
TS Surveillance Requirement 4.5.1.b.2 requires that each LPCI pump (A & B provide flow to the RHR heat exchangers) provide a flow of at least 10,000 gpm against a test line pressure corresponding to a reactor vessel to primary containment differential pressure of greater than or equal to 20 psid.
Page 9 of 19
Documrnt Csntr:I De2k LR-N98369 i
Attachm;nt 1 LCR H98-02 l
15.
How will the 95 F and 100 F temperature limits on SACS be ensured?
In a PSE&G letter, LR-N97466, dated August 25,1997, information was provided concerning SACS temperature indications in order to support TS Amendment No.106. In that letter, PSE&G stated that:
"In all cases, a SACS temperature remaining below 95.0 F following design bases events or accidents would provide an indication that the operator actions have been successful. [ Operators] monitor SACS temperatures (which is provided in both direct analog and digital format in the control room) and are trained (and directed by plant procedures) to limit heat loads when SACS temperature cannot be maintained and to ensure the SACS loop is in an optimum configuration to support post accident heat removal."
For the cases where SACS temperature will be limited to 100 F, the above descriptions of SACS temperature indications and operator response are also applicable. The SACS abnormal procedure will reflect the 95*F and 100 F limits that correspond to SACS configurations in post-transient scenarios.
16.
In Attachment 4, Section 6.4, the licensee states that one SACS pump per loop, as allowed by technical specifications, is inadequate for RHR heat exchanger cooling if the SACS temperature is 100 F. The licensee concludes that this alignment will not be allowed. How will this be ensured? Also, the licensee states that the current UHS limit for this alignment is 88*F; provide a reference for this statement.
In the LCR H98-02 application, Attachment 4, Section 6.16 provides the results of the UHS temperature limits corresponding to SSWS/ SACS configurations.
The proposed UHS TS LCO 3.7.1.3 will be used to ensure that plant operation is not continued when UHS in excess of 88 F and SACS pumps are out of service.
In addition, the SSWS abnormal procedure, which is entered upon elevated river water conditions, will also have the configuration restrictions described to help ensure that plant operation is maintained within the UHS LCO limits. This use of the LCO requirements and the SSWS abnormal procedure are currently relied upon to maintain plant operation with the design basis analyses.
Page 10 of 19 i
Docum:nt Central Deck LR-N98369 Attachm:nt 1 LCR H98-02 17.
In Attachment 4, Section 6.4, the licensee states that all the analysis cases, except normal operation, are for a LOP /SSE event. For the whole submittal, verify that a LOP /SSE is the most limiting scenario for the UHS / SACS temperature or explain any other limiting scenarios that were used.
Specifically, verify that it is more limiting than a LOCA/ LOP.
The difference between the LOCA/ LOP and LOP /SSE UHS limits was determined in Engineering Evaluation H-0-EG-MEE-1206. The summary of the UHS temperature limits are shown on Attachment 4 of Engineering Evaluation H-0-EG-MEE-1301. The major difference between the two cases (LOP versus LOCA) is the RHR heat load, the inclusion of the Filtration, Recirculation and Ventilation System (FRVS) heat loads, and the SSWS flow rates. The difference between the limiting cases of UHS temperature are shown on Attachment 4. There is only a minor difference between these two cases. For the analyses performed to support LCR H98-02, the LOP /SSE case is the most limiting.
18.
In Attachment 4, Section 6.10, does the increase in room temperature to 125 F qualify these rooms as harsh environments as defined by the HCGS environmental qualification (EQ) program? Also, does the proposed setpoint for the redundant heat exchanger (122 F +/- 2.3 F) provide adequate time for cooling such that the room temperature does not exceed 125 F?
The rooms, which are listed in the Section 6.10 of Attachment 4, are the RHR, Core Spray (CS), High Pressure Coolant injection (HPCI), and Reactor Core Isolation Cooling (RCIC) pump rooms. The equipment within these rooms were reviewed under Engineering Evaluation H-0-GR-MEE-1279. The equipment in these rooms were acceptable from an Equipment Qualification viewpoint to temperatures up to 148 F. The rooms were limited to 125 F in the HVAC analysis to allow for habitability concerns. Based on the results of the engineering evaluation, the transient effects of the fan start and the time for the cooler to reach equilibrium will cause no operability concerns for the equipment in the areas. The setpoint of the redundant cooler was recommended to be at the temperature limit for habitability with an allowance for instrument inaccuracies.
All the equipment within the areas are currently covered by the Equipment Qualification Program. The RHR, CS, HPCI and RCIC rooms are designated as harsh areas in the Equipment Qualification program. This designation was not l
changed based on the temperature limit increase.
Page 11 of 19 i
l
D cum:nt Contrcl De2k LR-N98369 Attachm:nt i LCR H98-02 19.
In Attachment 4, Pages 2 and 22, the licensee refers to tht, UHS temperature limit being 5 degrees higher, in the TS, the ultimate heat sink l
temperature is proposed to be raised by 2 degrees. Please reconcile this l
conflict in descriptions.
The sections that discuss a rise in five degrees in UHS temperatures pertain only l
to the cases, which use a SACS cooling water temperature of 100 F. Th; purpose of this statement is to state that the relationship between the SACS cooling water temperature and the UHS temperature limit is proportional.
However, the proposed Tech Spec UHS limits are based on cases which do not use a SACS cooling water temperature of 100 F. Instead, these cases use the l
current SACS design basis temperatures of 95 F. This limited the raising of the l
UHS temperature limits uniformly by five degrees and resulted in the F.roposed l
TS temperature limits.
20.
Provide an explanation /roadmap for the data printouts in Attachment 4.
Include where the information is from (e.g., SAR, operation data), how the information was used, and any assumptions in using the information.
The information in the attachments to Attachment 4 of the LCR H98-02 submittal was developed based on the following:
Attachment (1) is the computer output of the EDG cooler models. The EDG cooler models were generated using the computer code PROTO-HX. The L
models were validated by comparing the performance to the vendor data sheets. The computer output is based on the methodology and inputs described in Section 6.2 of Attachment 4.
Attachment (2) is the computer output of the RHR Heat Exchanger model.
The RHR heat exchanger model was generated using the computer code PROTO-HX. The model was validated by comparing the performance to the vendor data sheets. The computer output is based on the methodology and inputs described in Section 6.4 of Attachment 4.
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Docum:nt Csntral De2k LR-N98369 Attachm:nt 1 LCR H98-02 Attachment (3) is the computer output of the SACS thermal / hydraulic model. The SACS thermal / hydraulic model was generated using the computer code PROTO-FLO. The benchmarked SACS computer model was used to determine the limiting UHS temperatures for the limiting cases. The fax cover sheets list the limiting case alignment and the resulting UHS temperature. The sheets, which follow the fax cover sheets, are the Flow Summary Report and the Heat Exchanger Data Sheet.
Tho general approach used to determine the UHS temperature limits is to review the system alignment and determine which heat exchangers are active, or in other words, receive SACS flows. These flow paths are analytically opened in the model. The fixed heat loads for each of these components are input into the SACS thermal hydraulic model. The S5WS flow rate is input into the tube flow of the SACS heat exchangers,1A(B)1(2)E201. The SSWS flow rate is based on the minimum flow delivered to the SACS heat exchangers under the analyzed alignment. This flow rate is determined by the SSWS hydraulic analysis, which used a benchmarked computer. mode: of the SSWS. After the SSWS flow rates and the SACS cooler heat loads are input, the SACS thermal / hydraulic model is run. The SACS system flow rates and SACS temperature is determined based on the alignment. The temperature to the SACS coolers / heat exchangers is rev;ewed to determine if the maximum temperature limit is exceeded. The SSWS temperature to the SACS heat r xchanger (i.e., UHS temperature) is adjusted until the SACS temperature is at its maximum value. This value is the maximum UHS value. The value is then corrected for instrument and model inaccuracies. represents the final output file of the limiting cases. The flow summary report shows the calculated SACS flows under the analyzed alignment.
l The Heat Exchanger Data Sheets show the SACS components / heat exchanger input data and performance. The output files give the following information:
The individual heat exchanger is listed in the upper left corner.
Heat exchanger type is listed as a Fixed heat load (constant heat input) or shell and tube (variable conditions).
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l, Documsnt Centrsi Desk LR-N98369 l
Attachmsnt 1 LCR H98-02 l
1 i
l For fixed heat loads type heat exchangers, the following information is also provided:
l
~
Tube Flow (calculated by the computer program).
Tube inlet and outlet temperatures (calculated by computer program based l
on the calculated flow rate and the fixed heat loads).
l For shell and tube type heat exchangers, the following information is also j
provided:
Shell Flow: Calculated by the computer model.
e Shell temperatures: Calculated by the computer model e
Tube temperatures: Inlet (Input by user), Outlet calculated by the computer model.
. Heat Exchanger Physical Parameters, based on the heat exchanger model developed as part of the thermal / hydraulic SACS model.
Heat Load: Calculated by the computer model.
i The fixed heat loads for each SACS cooler were based on the results of the heat loads described in the response to Question 11 of this RAl. The SACS coolers, which are considered " active", are also based on the required cystem components from design calculation EG-0020. The SACS cooler inlet temperature represents the maximum SACS temperature limit. The tube inlet temperature for the SACS heat exchangers,1 A(B)1(2)E201, show the assumed UHS temperature.
21.
Explain the footnotes in Attachment (1) to Attachment 4, "Reynolds number outside range of equation applicability" and "with zero fouling the test heat load could not be achieved."
The footnotes on Attachment 1 of Attachment 4 of the LCR state:
"** Reynolds Number Outside Range of Equation Applicability"
ll With Zero Fouling The test Heat Load Could Not Be Achieved" L
The footnotes represent general footnotes for the output of the heat exchanger modeling tool PROTO-HX. PROTO-HX was used to model all the SACS heat exchangers. If the ***' or 'll' is listed next to any numbers in the PROTO-HX output, the footnotes apply. If there is no '**' or 'll' listed, as is the case in the output files in Attachment 1, no errors are present and the output is valid.
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1 Docum:nt Central Deck LR-N98369 AttachmInt 1 LCR H98-02 Questions from Operator Licensing and Human Performance I:$ ranch l
1.
Discuss any new operator actions that would be required as a result of the technical specification amendment request.
For the UHS temperature limits proposed in LCR H98-02, no new operator actions are required in post-transient situations. Excluding the operator actions that will be deleied, only the operating limits (i.e., SACS temperature limits) will j
change in the procedures used for post-transient situations.
For normal plant operation, where SSWS/ SACS configuration is controlled by the i
TS and plant procedures to maintain the ability to mitigate design basis events, I
no new operator actions are required. As currently required by plant procedures, operators will still have to manipulate SACS configuration (to regulate flow to component room coolers) to support plant operation upon removal (or loss) of a l
SACS loop from service.
1 2.
The markup of the UHS LCO ACTION statement does not appear to contain any " additional" operator actions. Please clarify the following statement l
(page 6, paragraph 2):
At 88*F, additional actions to maintain continued plant operation l
would be required. These actions are contained in the proposed UHS LCO ACTION Statement and are also referenced by LCOs 3.7.1.1, 3.7.1.2, and 3.8.1.1.
For this reference, the context of the discussion concerned TS LCO actions, not operator actions. Specifically, the actions being referred to are the SSWS/ SACS configuration restrictions that will be imposed by the proposed Action Statements l
for UHS TS LCO 3.7.1.3.
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N Docum:nt Centr:1 De:k LR-N98369 Attachm::nt 1 LCR H98-02 i
3.
State operator actions that are no longer required and discuss specifically what the engineering analyses indicated in the following statement (page 6, paragraph 3):
As a result of the Engineering analyses of SSWSISACSIRHR, the
[
proposed UHS temperature limits actually require less operator actions than those limits contained in TS Amendment No.106.
As stated in the LCR H98-02 application, the amount of required operator actions are reduced in the Engineering analyses supporting the proposed UHS temperature limits. In the current operating procedures, l
the operator response in cases where SSWS/ SACS temperatures can l
not be maintained and a LOP Murs includes the isolation and reduction l
of SSWS flow to the Reactor Auxiliaries Cooling System (RACS) heat exchangers. However, isolating / throttling of RACS flow under LOP conditions will no longer be required. The revised SSWS/ SACS / UHS analyses has supported the removal of this post-transient operator action. The cctions associated with isolating / throttling SSWS flow to the RACS heet exchangers are not necessary under LOCA conditions since the SSWS flow to those components is automatically isolated.
. In addition, the current operating procedures also address a condition where a LOP and/or LOCA occurs coincident with: 1) an event which results in blockage of the normal flow path to the cooling tower; 2) the emergency overboard discharge valves are open (as discussed in the previous section); and 3) SACS heat exchanger outlet temperatures can not be maintained below 95'F. In this situation, the procedure directs the operators to: 1) isolate the SSWS outlet from one of the SSWS/ SACS heat exchangers in the SSWS/ SACS loop not servicing residual heat removal (RHR) decay heat loads if all four SSWS pumps are running; or 2) when only two SSWS pumps are operating in one loop and one SSWS pump is operating in the other, ensure that the SSWE outlet from one of the SSWS/ SACS heat exchangers in the loop with only one SSWS pump in service not servicing RHR decay heat loads is closed. Again, these actions are also no longer necessary under these conditions since the SSWS/ SACS / UHS analyses have ensured that sufficient flow to the SSWS/ SACS heat exchangers will be available such that heat removal requirements are satisfied for the proposed 4HS river water temperature limits.
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Dccum2nt Centrol De2k LR-N98369 AttachmInt 1 LCR H98-02 4.
Provide specifics on why the action in the statement that follows is no longer required (page 7, paragraph 1):
l However, isolating / throttling of RACS flow under LOP conditions will not longer be required. The revised SSWSISACSI UHS analyses has supported the removal of this post-transient operator action.
The Engineering analyses of SSWS/ SACS performance was performed with the SSWS to RACS supply valves in their post-LOP position (i.e., no operator actions to throttle flow). In this configuration, adequate flow was provided to the SACS heat exchangers to support the UHS temperature limits proposed in the LCR submittal.
5.
Please explain the apparent inconsistency in the following two statements (page 7, paragraph 1):
The actions associated with isolating / throttling SSWS flow to the RACS heat exchangers are not necessary under LOCA conditions since the SSWS flow to those components is automatically isolated.
Specific. ally, incases where SSWS/ SACS temperatures can not be mainta'ned and a LOP and/or LOCA occurs, the current SSWS abnormai 9perating procedure will direct that operators isolate SACS flow to the hselpool heat exchangers for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, Isolate
(.
SSWS flow to one Reactor Auxiliaries Cooling System (RACS) (see l
UFSAR Figure 9.2-3) heat exchanger and throttle SSWS flow to the remaining RACS heat exchanger (emphasis added).
The apparent inconsistency stems from the use of the "and/or" term used above.
The post-LOP and post-LOCA/ LOP actions required by the operator for SSWS and RACS operation is described in the response to question #3 above.
l 6.
Describe specific operator training that may be needed regarding the TS amendment request.
l I
For the implementation of TS Amendment Nc.106, extensive operator training and simulator evaluations were performed to ensure that the operator actions that were required to support that TS amendrnent were implemented adequately.
Since, as previously stated, the operator actions are going to be reduced in post-Page 17 of 19 i
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Docum:nt Crntral Denk LR-N98369 Attachm:nt 1 LCR H98-02 transient situations, the same level of operator training would not need to be conducted prior to implementation of a TS amendment. The normal procedure revision process would be utilized to implement the changes that reduce the amount of required operator actions. Recurring training will continue to be used to evaluate the effectiveness of operator response to design basis accident and transient conditions.
7.
Describe the schedule for procedural revisions related to the TS amendment request.
In PSE&G'c LCR H98-02 application, a sixty day implementation period was requested to allow for procedure changes that would be required to implement the new TS amendment. The procedure revisions that are required to implement the TS amendment will be completed within that time period.
8.
Provide the results of any sensitivity study that has evaluated the significance of the subject reduced operator actions.
The operator actions, which are being removed, are currently required for the existing UHS temperature limits. These operator actions were necessary to raise the UHS temperature limits under certain operating scenarios by approximately 0.2*F to 0.5'F. However, the proposed UHS temperature limits do not credit these actions.
9.
Explain how the operator accomplishes the following (p. 3/4-7-3 of TS):
" assess operability of the associated SACS loop."
The guidance contained in Generic Letter 91-18, Revision 1, "Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions,"is incorporated in plant procedures as appropriate. For the case where a SSWS loop is declared inoperable, the current SSWS abnormal procedure directs the operator to assess the operability of the associated SACS loop and enter the appropriate SACS LCO if operability of the SACS loop can not be maintained. No changes are necessary to this existing procedure to implement the proposed changes to this SSWS LCO Action Statement a.3.
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D cum:nt Central D:ck LR-N98369 Attachm:nt 1 LCR H98-02 Questions from Containment Systems Branch 1.
PSE&G has indicated that the General Electric Company (GE) SHEX computer code was used in the containment analysis associated with the UHS TS change request. This was not the same computer code used for the original containment analysis. The results of the SHEX computer code can be accepted on a plant specific basis provided that bench marking analysis is performed against the original code. Provide the results of the bench marking analysis of the SHEX computer code Per Section 6.2 of the UFSAR, SHEX was used in the original Hope Creek Generating Containment Analysis, i
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