ULNRC-03165, Forwards Replacement Pages for Various Portions of Attachments 1 & 4 of 940804 Amend Application Replacing TS 3/4.6.2.2, Spray Additive Sys W/New TS 3/4.6.2.2, Recirculation Fluid Ph Control Sys
| ML20081D486 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/14/1995 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20081D490 | List: |
| References | |
| ULNRC-03165, ULNRC-3165, NUDOCS 9503200260 | |
| Download: ML20081D486 (8) | |
Text
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Post 0thceBw 149 St. Loud Masouri63166 u
314-554-2650
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Union March 14, 1995 st"f,="r!;,
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h2l U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station.P1-137 Washington, DC 20555 ULNRC-0316 5 Gentlemen:
l DOCKET NUMBER 50-483 CALLAWAY PLANT CONTAINMENT SPRAY ADDITIVE SYSTEM RETIREMENT t
Reference:
ULNRC-3050 dated August 4, 1994 The referenced amendment application proposed the replacement of Technical Specification 3/4.6.2.2, Spray Additive System, with a new Specification 3/4.6.2.2 entitled Recirculation Fluid pH Control (RFPC) System.
The currently installed Spray Additive l
System will be retired and replaced with a passive system of steel baskets containing trisodium phosphate dodecahydrate (TSP-C).
During the performance of receipt inspection testing of the TSP-C it was discovered that the i
chemical did not meet the titration curve data used to calculate the required mass of TSP-C to ensure an equilibrium sump pH of at least 7.1.
This was i
ascertained by on-site chemistry analysis and confirmed by analyses conducted by the chemical supplier.
It has been determined that the minimum required amount of TSP-C has increased from 5000 lbm to 9000 lbm.
This will result in an increase in the Technical Specifi cation minimum TSP-C depth from 19" to 30".
The chemical's total dissolution time will increase from 100 minutes (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 40 minutes) to 160 minutes (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 40 minutes).
This change will assure long-term retention'of iodine within the containment sumps.
Attached are replacement pages for various portions of Attachments 1 and 4 of the referenced j
amendment application.
Changes to Bases page B 3/4 1-3, given to the NRC during a meeting on September 1, 1994, are formally transmitted herewith.
Changes to the draft FSAR mark-ups transmitted as Attachment 5 to ULNRC-3050 will be made accordingly but are not i
attached.
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Based on several telephone conversations between NRC Staff reviewers and personnel representing Union Electric Company, the following commitments are also made.
Administrative controls will be implemented during the upcoming Refuel 7 to ensure an average atmosphere residence time of greater than or equal.to 0.25 sec for the air flow through the charcoal beds of the control room filtration _ units, FGK01A,B.
These t
controls will limit the flow rate through the units _and will be implemented prior to re-entry into Mode 4 during startup from the outage.
The average atmosphere t
residence time for the control building pressurization units, FGK02A,B, is already greater than 0.25 sec at their upper bound flow rate of 1000 cfm.
No flow rate changes will be needed for FGK02A,B.
- Further, beginning with the next required surveillance on the charcoal adsorber per Technical Specification 4.7.6, dual testing per the Specification and per ASTM D-3803-1989 will be performed on FGK01A,B and FGK02A,B.
Testing to the latter standard will be performed using test protocols of 30*C and 70% RH with a methyl iodide penetration of less than 2%.
An amendment application will be submitted prior to the end of this year that wili revise Technical Specification 3/4.7.6 accordingly.
These commitments support the change in the filter efficiency assumption used in the control room dose calculation from 90% to 95% for the control building pressurization and control room filtration ESF filter assemblies.
The conclusions of the previously submitted I
licensing evaluations performed purauant to 10CFR50.59, 10CFR50.92, and 10CFR51.22 (c) (9) are unaffected and remain valid for the attached changes.
If you have any questions on the attachments, r
please contact us.
Very truly yours, c4 Donald F. Schnell GGY/jdg Attachments: 1 - Replacement Page for Attachment 1 to ULNRC-3050 2 - Replacement Pages for Attachment 4 to ULNRC-3050 i
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STATE OF MISSOURI
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Alan C. Passwater, of lawful age, being first duly sworn i
upon oath says that he is Manager, Licensing and Fuels (Nuclear) for Union Electric Company; that he has 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 i
stated are true and correct to the best of his knowledge, information and belief.
By
/i Alan C. Passwater Manager, Licensing and Fuels Nuclear l
SUBSCyIBED and sworn to before me this~ /
day of 7/ M 1995.
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j' ty BARBARA J. PFAFF N01ARY PUBLIC-STATE OF MISSOURI j
MY COMMISSION EXPIRES APRIL 22,199Z SI. LOUIS COUNTX 1
1 6
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'cc :
T. A. Baxter, Esq.
Shaw, Pittman, Potts-& Trowbridge 2300 N. Street, N. W..
Washington, D.C.
20037 M. H. Fletcher Professional Nuclear Consulting, Inc.
18225-A Flower Hill Way Gaithersburg,-MD 20879-5334 M. J.
Farber Chief, Reactor ProjectsSection III A U.S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 60532-4351 Bruce Bartlett Callaway Resident Office U.S. Regulatory Commission RR#1 Stoedman, MO 65077 L. R. Wharton (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O.
Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O.
Box 176 Jefferson City, MO 65102
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ULNRC-03165 ATTACHMENT ONE REPLACEMENT PAGE FOR ATTACHMENT 1 TO ULNRC-3050 WM.
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a Attachment i Page 2 of 10 rea"act to concentrated NaOH spil~s; and elimination of the-por ;cfal for expensive caustic cleanup of containment in the onit of an inadvertent containment spray actuation.
However, the equilibrium pH of the containment recirculation sump water should still be maintained above 7.0 in order to retain iodine in the sump solution and to minimize chloride-induced stress corrosion cracking of austenitic stainless steels in the Emergency Core Cooling System (ECCS).
Since the initial pH of the RWST spray fluid is greater than or equal to 4.0 but less than 7.0, a chemical additive is needed to raise the pH.
To provide this pH control, UE intends to install a passive system utilizing TSP-C stored in two wire-mesh baskets located within the confines of the recirculation sumps, i+rn One seismically designed TSP-C basket vfill be constructed within the confines of each of the two containment recirculation sumps.
Each basket is d( signed to contain a maximum of 6720 lbm of TSP-C (basis for the maximum depth of 36.8" in the prnposed Technical Specif:. cation) whereas a N,, minimum depth of@ #',
corresponding to1964e lbm, must be contained in each basket to ensure an equilibrium sump pH of at least 7.1.
The baskets will be located at an elevation that will ensure dissolution by the sump fluids.
The baskets will have a stainless steel frame with walls constructed of stainless steel grating and lined with #100 wire mesh stainless steel screening.
Inside dimensions of each basket will be 80" x 56" x 38".
I The calculation of the minimum and maximum depths of TSP-C includes conservative allowances for compaction, spillage through the wire mesh, density variations, and the limited transformation of TSP-C into disodium triphosphate which is a weaker base (expected to have a small impact in the outer surface layer).
The minimum equilibrium sump pH of 7.1 corresponds to a minimum of. 00 lbm of TSP-C in the baskets and a maximum sump boron cor_entration of 2500 ppm.
If the maximum of 13,440 lbm of TS
-C were contained in the baskets at the end of cycle life s h that a minimum sump boron concentration of 2007 ppm ould occur, the maximum equilibrium sump pH would be less than Gwet8"./.
9 Four floor mounted plates will be anchored (using Hilti Kwik Bolt II anchors) within each sump to support carbon steel beams which will support the baskets.
Piping, valves, and flow instrumentation from the spray additive eductors to the common line from the spray additive tank will be removed and the lines will be capped.
The spray additive tank will be retired in place and its level and pressure instrumentation will be removed.
These changes are shown on the mark-up of FSAR Figure 6.2.2-1 in Attachment 5.
The instrumentation,
Page 2 of 10 respect to concentrated NaOH spills; and elimination of-the potential for expensive caustic cleanup of containment in l
the event.of an inadvertent containment spray actuation.
However, the equilibrium pH of the containment recirculation sump water should still be maintained above 7.0 in order to retain iodine in the sump solution and to minimize chloride-induced stress corrosion cracking of austenitic stainless steels in the Emergency Core Cooling System (ECCS).
Since the initial pH of the RWST spray fluid is greater than or equal to 4.0 but less than 7.0, a chemical additive is necded to raise the pH.
To provide this pH control, UE intends to install a passive system utilizing TSP-C stored in two wire-mesh baskets located within the confines of the recirculation sumps.
One seismically designed TSP-C basket will be constructed within the confines of each of the two containment recirculation sumps.
Each basket is designed to contain a maximum of 6720 lbm of TSP-C (basis for the maximum depth of 36.8" in the proposed Technical Specification) whereas a minimum depth of 30",
corresponding to 4500 lbm, must be l
contained in each basket to ensure an equilibrium sump pH of at least 7.1.
The baskets will be located at an elevation that will ensure dissolution by the sump fluids.
The baskets wili have a stainless steel frame with walls constructed of stainless steel grating and linea with #100 wire mesh stainless steel screening.
Inside dimenrions of each basket will be 80" x 56" x 38".
The calculation of the minimum and maximum depths of TSP-C includes conservative allowances for compaction, spil'. age through the wire mesh, density variations, and the lirited transformation of TSP-C into disodium triphosphate which is a weaker base (expected to have a small impact in the c2ter surface layer).
The minimum equilibrium sump pH of 7.1 corresponds to a minimum of 9000 lbm of TSP-C in the baskets l
and a maximum sump boron concentration of 2500 ppm.
If th.)
maximum of 13,440 lbm of TSP-C were contained in the baskets at the end of cycle life such that a minimum sump boron concentration of 2007 ppm would occur, the maximum equilibrium sump pH would be.less than 8.1.
l Four floor mounted plates will be anchored (using Hilti Kwik Bolt II anchors) within each sump to support carbon steel beams which will support the baskets.
Piping, valves, and flow instrumentation from the spray additive eductors to the common line from the spray additive tank will be removed and the lines will be capped.
The spray additive tank will be retired in place and its level and pressure instrumentation will be removed.
These changes are shown on the mark-up of FSAR Figure 6.2.2-1 in Attachment 5.
The instrumentation, l
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ULNRC-03165 ATTACHMENT TWO REPLACEMENT PAGES FOR ATTACHMENT 4 TO ULNRC-3050 4
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