W3F1-2004-0100, Response to Request for Additional Information Regarding Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors.

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Response to Request for Additional Information Regarding Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors.
ML043060360
Person / Time
Site: Waterford Entergy icon.png
Issue date: 10/27/2004
From: Dodds R
Entergy Nuclear South, Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-03-001, W3F1-2004-0100
Download: ML043060360 (9)
v • d • e


Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road i- Entergy Killona. LA 70057-3093 Tel 504 739 6379 Fax 504 739 6698 rdodds~entergy.com R.A. (Al) Dodds, IlIl Director, Nuclear Safety Assurance Waterford 3 W3F1-2004-01 00 October 27, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Response to Request for Additional Information Regarding Bulletin 2003-01, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors" Waterford Steam Electric Station, Unit 3 (Waterford 3)

Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

By letter dated August 7, 2003, (W3Fl-2003-0050) Entergy provided a 60-day response to NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors. NRC letter dated September 2, 2004 stated that a preliminary review of Entergy's response has been completed and a determination was made that additional information is needed. Attachment 1 provides the additional information requested in NRC letter dated September 2, 2004.

New commitments contained in this submittal are summarized in Attachment 2.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 27, 2004.

Sincerely, R. A. Dodds Director, Nuclear Safety Assurance RAD/GCS/cbh Attachment(s) 4XI©3

W3F1 -2004-0100 Page 2 cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502

Attachment 1 W3Fl -2004-0100 Waterford 3's Response to NRC Bulletin 2003-01 Request for Additional Information

Attachment I to W3Fl -2004-0100 Page 1 of 3 Bulletin 2003-01 RAI Responses RAI 1: On page 1 of Attachment 1 of your Bulletin 2003-01 response, you state that you will train licensed operators on indications of and responses to emergency core cooling system (ECCS) sump clogging, with a completion date of March 31, 2004. However, although your response provides some detail regarding existing available indications which might be used to detect a sump clogging scenario, your response does not completely discuss the operator training to be implemented. Please provide a detailed discussion of the operating procedures to be implemented, the indications of sump clogging that the operators are instructed to monitor, and the response actions the operators are instructed to take in the event of sump clogging and loss of ECCS recirculation capability.

Response

The following Emergency Operating Procedures, OP-902-002, Loss of Coolant Accident and OP-902-008, Safety Function Recovery Procedure are the documents that will be used to specify and address indications of sump clogging. These procedures address the availability of alternate water sources to supplement the RWSP in the event the emergency core cooling sump is clogged. The water sources will be as follows:

  • Borated water sources are available for injection by either the HPSI pumps or the charging pumps
  • Transfer of excess spent fuel pool (SFP) inventory to the RWSP
  • Transfer of any holdup tank inventory to the RWSP
  • Manually unisolate the Volume Control Tank and inject the remaining volume into the RWSP using the charging pumps
  • To provide additional borated inventory to the RWSP, water from the SFP can be transferred to the RWSP. The SFP can be replenished from the condensate storage pool or the fire protection system.
  • Pure unborated makeup water can be provided directly to the suction of the charging pumps or to the RWSP for injection by the HPSI pumps Regarding indications of sump clogging, the operators are instructed to monitor, for abnormal conditions, the following parameters as possible indicators of emergency core cooling sump blockage:
  • ECCS sump level - Normally > 10 feet during Recirculation Actuation Signal
  • High Pressure Safety Injection (HPSI) pump flow
  • HPSI pump discharge pressure
  • CS pump current
  • Containment pressure The response action the operators are instructed to take following the above indications is, in addition to obtaining alternate sources of water, to secure redundant high pressure safety injection pumps and containment spray pumps when indication of sump blockage occurs.

Both of these pumps take suction from the emergency core cooling sump following a recirculation actuation signal.

RAI 2: On Page 2 of Attachment 1 of your response you state: "Entergy's procedures delay switchover to the ECCS sump recirculation to the extent practical ...Potential changes to the guidance in CEN-152 are being evaluated by Westinghouse. Procedure changes have not been implemented at this time..." Westinghouse Owner's Group (WOG) has developed operational guidance in response to Bulletin 2003-01 for Westinghouse and Combustion Engineering type pressurized water reactors. Please provide a discussion of your plans to consider implementing this new WOG guidance. Include a discussion of the WOG recommended compensatory measures that have been or will be implemented at your plant, and the evaluations or analyses performed to determine which of the WOG recommended compensatory measures not being implemented by your plant. Provide technical justification for those WOG recommended compensatory measures not being implemented by your plant. Also include a detail discussion of the procedures being modified, the operator training being implemented, and your schedule for implementing these compensatory measures.

Response

Waterford 3 has reviewed WOG recommended compensatory measures provided in CEN-152. The recommended actions in CEN-152 will be implemented in Waterford 3 Emergency Operating Procedures with one exception related to Alternate RCS Injection.

Specifically, the CEN states, as a means of providing water to the RCS, to initiate actions to lineup to inject directly to the RCS bypassing the RWSP. This action will not be taken at Waterford 3 as the plant lineup cannot inject water directly to the RCS. CEN-1 52 actions will be incorporated in Emergency Operating Procedures, OP-902-002, Loss of Coolant Accident and OP-902-008, Safety Function Recovery. The training associated with CEN-152 actions will be performed in the 2005 cycle 2 License Operator requalification training.

The training will consist of a review of the procedure changes and the basis for the changes.

RAI 3: NRC Bulletin 2003-01 provides possible interim compensatory measures licensees could consider to reduce risks associated with sump clogging. In addition to those compensatory measures listed in Bulletin 2003-01, licensees may also consider implementing unique or plant-specific compensatory measures, as applicable. Please discuss any possible unique or plant-specific compensatory measures you considered for implementation at your plant. Include a basis for rejecting any of these additional considered measures.

to W3F1 -2004-01 00 Page 3 of 3

Response

Waterford 3 does not implement any unique or plant specific compensatory measures for ECCS sump clogging. The compensatory measures to be used by Waterford 3 are delineated in Bulletin 2003-01.

Attachment 2 W3Fl -2004-0100 List of Regulatory Commitments to W3Fl -2004-0100 Page 1 of 2 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPESCHEDULED ONE- ) COMPLETION TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (IfRequired)

CEN-152 actions will be incorporated in 2/28/2005 Emergency Operating Procedures, OP-902-002, Loss of Coolant Accident and x OP-902-008, Safety Function Recovery.

The training associated with CEN-152 4/15/2005 actions will be performed in the 2005 cycle 2 License Operator requalification x training. The training will consist of a review of the procedure changes and the basis for the changes.

The following Emergency Operating 2/28/2005 Procedures, OP-902-002, Loss of Coolant Accident and OP-902-008, x Safety Function Recovery Procedure are the documents that will be used to specify and address indications of sump clogging. These procedures address the availability of alternate water sources to supplement the RWSP in the event the emergency core cooling sump is clogged. The water sources will be as follows:

  • Borated water sources are available for injection by either the HPSI pumps or the charging pumps
  • Transfer of excess spent fuel pool (SFP) inventory to the RWSP
  • Transfer of any holdup tank inventory to the RWSP
  • Manually unisolate the Volume Control Tank and inject the remaining volume into the RWSP usina the charaina to W3FI -2004-0100 Page 2 of 2 pumps
  • To provide additional borated inventory to the RWSP, water from the SFP can be transferred to the RWSP. The SFP can be replenished from the condensate storage pool or the fire protection system.
  • Pure unborated makeup water can be provided directly to the suction of the charging pumps or to the RWSP for injection by the HPSI pumps

Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road i- Entergy Killona. LA 70057-3093 Tel 504 739 6379 Fax 504 739 6698 rdodds~entergy.com R.A. (Al) Dodds, IlIl Director, Nuclear Safety Assurance Waterford 3 W3F1-2004-01 00 October 27, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Response to Request for Additional Information Regarding Bulletin 2003-01, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors" Waterford Steam Electric Station, Unit 3 (Waterford 3)

Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

By letter dated August 7, 2003, (W3Fl-2003-0050) Entergy provided a 60-day response to NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors. NRC letter dated September 2, 2004 stated that a preliminary review of Entergy's response has been completed and a determination was made that additional information is needed. Attachment 1 provides the additional information requested in NRC letter dated September 2, 2004.

New commitments contained in this submittal are summarized in Attachment 2.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 27, 2004.

Sincerely, R. A. Dodds Director, Nuclear Safety Assurance RAD/GCS/cbh Attachment(s) 4XI©3

W3F1 -2004-0100 Page 2 cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1400 L Street, NW Washington, DC 20005-3502

Attachment 1 W3Fl -2004-0100 Waterford 3's Response to NRC Bulletin 2003-01 Request for Additional Information

Attachment I to W3Fl -2004-0100 Page 1 of 3 Bulletin 2003-01 RAI Responses RAI 1: On page 1 of Attachment 1 of your Bulletin 2003-01 response, you state that you will train licensed operators on indications of and responses to emergency core cooling system (ECCS) sump clogging, with a completion date of March 31, 2004. However, although your response provides some detail regarding existing available indications which might be used to detect a sump clogging scenario, your response does not completely discuss the operator training to be implemented. Please provide a detailed discussion of the operating procedures to be implemented, the indications of sump clogging that the operators are instructed to monitor, and the response actions the operators are instructed to take in the event of sump clogging and loss of ECCS recirculation capability.

Response

The following Emergency Operating Procedures, OP-902-002, Loss of Coolant Accident and OP-902-008, Safety Function Recovery Procedure are the documents that will be used to specify and address indications of sump clogging. These procedures address the availability of alternate water sources to supplement the RWSP in the event the emergency core cooling sump is clogged. The water sources will be as follows:

  • Borated water sources are available for injection by either the HPSI pumps or the charging pumps
  • Transfer of excess spent fuel pool (SFP) inventory to the RWSP
  • Transfer of any holdup tank inventory to the RWSP
  • Manually unisolate the Volume Control Tank and inject the remaining volume into the RWSP using the charging pumps
  • To provide additional borated inventory to the RWSP, water from the SFP can be transferred to the RWSP. The SFP can be replenished from the condensate storage pool or the fire protection system.
  • Pure unborated makeup water can be provided directly to the suction of the charging pumps or to the RWSP for injection by the HPSI pumps Regarding indications of sump clogging, the operators are instructed to monitor, for abnormal conditions, the following parameters as possible indicators of emergency core cooling sump blockage:
  • ECCS sump level - Normally > 10 feet during Recirculation Actuation Signal
  • High Pressure Safety Injection (HPSI) pump flow
  • HPSI pump discharge pressure
  • CS pump current
  • Containment pressure The response action the operators are instructed to take following the above indications is, in addition to obtaining alternate sources of water, to secure redundant high pressure safety injection pumps and containment spray pumps when indication of sump blockage occurs.

Both of these pumps take suction from the emergency core cooling sump following a recirculation actuation signal.

RAI 2: On Page 2 of Attachment 1 of your response you state: "Entergy's procedures delay switchover to the ECCS sump recirculation to the extent practical ...Potential changes to the guidance in CEN-152 are being evaluated by Westinghouse. Procedure changes have not been implemented at this time..." Westinghouse Owner's Group (WOG) has developed operational guidance in response to Bulletin 2003-01 for Westinghouse and Combustion Engineering type pressurized water reactors. Please provide a discussion of your plans to consider implementing this new WOG guidance. Include a discussion of the WOG recommended compensatory measures that have been or will be implemented at your plant, and the evaluations or analyses performed to determine which of the WOG recommended compensatory measures not being implemented by your plant. Provide technical justification for those WOG recommended compensatory measures not being implemented by your plant. Also include a detail discussion of the procedures being modified, the operator training being implemented, and your schedule for implementing these compensatory measures.

Response

Waterford 3 has reviewed WOG recommended compensatory measures provided in CEN-152. The recommended actions in CEN-152 will be implemented in Waterford 3 Emergency Operating Procedures with one exception related to Alternate RCS Injection.

Specifically, the CEN states, as a means of providing water to the RCS, to initiate actions to lineup to inject directly to the RCS bypassing the RWSP. This action will not be taken at Waterford 3 as the plant lineup cannot inject water directly to the RCS. CEN-1 52 actions will be incorporated in Emergency Operating Procedures, OP-902-002, Loss of Coolant Accident and OP-902-008, Safety Function Recovery. The training associated with CEN-152 actions will be performed in the 2005 cycle 2 License Operator requalification training.

The training will consist of a review of the procedure changes and the basis for the changes.

RAI 3: NRC Bulletin 2003-01 provides possible interim compensatory measures licensees could consider to reduce risks associated with sump clogging. In addition to those compensatory measures listed in Bulletin 2003-01, licensees may also consider implementing unique or plant-specific compensatory measures, as applicable. Please discuss any possible unique or plant-specific compensatory measures you considered for implementation at your plant. Include a basis for rejecting any of these additional considered measures.

to W3F1 -2004-01 00 Page 3 of 3

Response

Waterford 3 does not implement any unique or plant specific compensatory measures for ECCS sump clogging. The compensatory measures to be used by Waterford 3 are delineated in Bulletin 2003-01.

Attachment 2 W3Fl -2004-0100 List of Regulatory Commitments to W3Fl -2004-0100 Page 1 of 2 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPESCHEDULED ONE- ) COMPLETION TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (IfRequired)

CEN-152 actions will be incorporated in 2/28/2005 Emergency Operating Procedures, OP-902-002, Loss of Coolant Accident and x OP-902-008, Safety Function Recovery.

The training associated with CEN-152 4/15/2005 actions will be performed in the 2005 cycle 2 License Operator requalification x training. The training will consist of a review of the procedure changes and the basis for the changes.

The following Emergency Operating 2/28/2005 Procedures, OP-902-002, Loss of Coolant Accident and OP-902-008, x Safety Function Recovery Procedure are the documents that will be used to specify and address indications of sump clogging. These procedures address the availability of alternate water sources to supplement the RWSP in the event the emergency core cooling sump is clogged. The water sources will be as follows:

  • Borated water sources are available for injection by either the HPSI pumps or the charging pumps
  • Transfer of excess spent fuel pool (SFP) inventory to the RWSP
  • Transfer of any holdup tank inventory to the RWSP
  • Manually unisolate the Volume Control Tank and inject the remaining volume into the RWSP usina the charaina to W3FI -2004-0100 Page 2 of 2 pumps
  • To provide additional borated inventory to the RWSP, water from the SFP can be transferred to the RWSP. The SFP can be replenished from the condensate storage pool or the fire protection system.
  • Pure unborated makeup water can be provided directly to the suction of the charging pumps or to the RWSP for injection by the HPSI pumps
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