View source for 1CAN119002, Forwards Responses to 901025 Request for Addl Info Re 100% Power Tech Spec Change

{{Adams
| number = ML20058G561
| issue date = 11/05/1990
| title = Forwards Responses to 901025 Request for Addl Info Re 100% Power Tech Spec Change
| author name = Fisicaro J
| author affiliation = ENTERGY OPERATIONS, INC.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000313
| license number = 
| contact person = 
| document report number = 1CAN119002, NUDOCS 9011130273
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 19
}}

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                          ' November 5, 1990-1CAN119002 U. S. Nuclear Regulatory Commission Document Control Desk Mall Station P1-137 Washington, DC 20555

==Subject:==
Arkansas Nuclear One - Unit 1 m                                     Docket Nos. 50-313 License Nos. DPR                                                                                                                              4 Response to Request for Additional Information on 100% Power Technical Specification Change Gentlemen:
Your. letter of October-25,-1990, License Amendment Request to Increase
                           . Reactor Power to 100% (TAC NO 74894) (1CNA109006), requests additional-                          !
information to that requested in your letter of October 15, 1990 (1CNA109003).
AttachmentL1 provides Entergy's responses to your request for additional
      . u .-                 information of October ~25, 1990.~ Additionally, responses.to verbal questions:as discussed.with Mr. Thomas Alexion are provided in Attachments-2 and 3.=: Enclosure 1 provides revised pages for Engineering Report 89R-1006-02: modified =as a result of further calculations and editorial corrections.
o Please contact me regarding any additional inform tion you may require on-
                            .this - matter..
: t.                                                                                                                            i
:Very truly yours,                                                                               j l
d**-s-,
James'      . 'isicaro Manager, Licensing 1
JJF/ CWT                                                                                        1 Attachments / Enclosures F
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9011130973 901105                                                         A PDR      ADOCK 05000313                                                  V P                      PDC I   I f
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F                  U. S. NRC November 5, 1990 Page 2 cci Mr. Robert Martin U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Senior Resident Inspector Arkansas Nucicar One - ANO-1 & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Hr. Thomas Alexion NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 15-D-18
                           - One White Flint North 11555 Rockville Pike RockvJile, Haryland 20852 Mr. Chester Poslunny NRR Project Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR_ Mail Stop 13-D                             One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 l
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a ATTACHMENT 1 R**Ponses to Reactor Systems Branch Questions i
i

t ATTACHMENT 1 QUESTION The hRC letter of October 25, 1990 requests additional information with respect to the RBS pump NPSil considerations. Specifically, the Staff reviewer stated that in order for statements made about the RBS pump NPSil to be a justified position, the postulated short duration cavitation concern must be quantified (i.e., anticipated length of cavitation vs.
pump test results for operation under no flow conditions).

===RESPONSE===
The extrapolation referred to in Revision 1 of ANO Engineering Report b                89R-1006-02 has been replaced by an additional caso consideration in the RBS and LPI NPSil calculations, in order to quantify the potential short duration cavitation concern. This concern results from high LPI flows a
that may exist prior to securing the llPI pi gyback h     flow. This revision demonstrates that adequate NPSil margin exists to avoid cavitation for this potential short duration condition. The corresponding sections in Engineering Report 89R-1006-02 have been revised and are provided as Enclosure 1 to this letter. These are replacement pages to the previously submitted report [ attachment to the 100% power licensee amendment request,     ;
(ICAN089002)). The changes to Table 5 of Engineering Report 89R-1006-2          i corrects an editorial error in the column headings.                            1 The revisions to the LPI and RBS pump NPSil calculations also provide more detailed considerations of the piping and fitting losses between the             !
:                 reactor building sump and the pump inlets. Previously, bounding assessments were used from the original Architect Engineer calculations.
The recent more detailed consideration uses results from the ongoing isometric update program and the updated Technical Manual program that provide a more accurate representation of the as-built system configurations.
The more detailed consideration provides notable NPSil margin and, when           1 combined with E0P guidance to throttle llPI flow during high LPI flow             l conditions, eliminates the previously postulated NPSil " window of conc rn."
Therefore, cavitation is not analyr.ed to occur and pump data for oporttion under no flow conditions is not needed to support safe operation.
             ,            -    ei - - -ee

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ATTACHMENT 2 Responnes to 8tructural and Geosciences Branch Questione 5

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ATTACHMENT 2
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t QUESTION                                                                            i
                                         'In Entergy's response dated October 25,'1990 (1CAN109008) to Question 2 of         l Attachment 2, no date was given as to when the Seismic Qualiffention               i Utility Group (SQUG) calculation results for checking Borated Water               !
i '                                   . Storage Tank flexibility would be submitted to the NRC. Please' provide a        ;
commitment as to when the results of this calculation will be completed           l and submitted to:the NRC.                                                         i RESPONSE                                                                          j r.
Entergy will complete the SQUG calculations and submit the results to the
                                         !NRC by January 31, 1991.                                                           ;
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ANACHNENT 3 Rassponses to Human Facto 4 Assessment Branch Question -;
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h                                                      ATTACHMENT 3 QUESTION E                  Provide clarification in the response to Question 5 of Attachment 3 to the {{letter dated|date=October 25, 1990|text=October 25, 1990 letter}} (ICAN109008) of the statement "In the interim, operator interface with the HP1 systems will be de-emphasized during p                  simulator training until appropriate modifications have been completed"
                   -RESPONSE Simulator training on the High Pressure Injection (HPI) modifications will be conducted as soon as simulator hardware and software changes are complete. In the interim, normal simulator training will take place with the following provisions:
l'                'o      _ Tor all training where HPI System / Operator interface is possibic or required, trainers will insure differences between plant and simulator equipment'are described and discussed before the training starts to preclude negative training.
* Training on HP1 line ruptures that requires throttling and flow balancing with equipment not 2nstalled on the simulator will not be p                           conducted at this time.
When hardware and software changes have been made to the simulator to model 1R9 HP1 modifications, special care will be taken to ensure training in the use'of the system in all relevant operating modes is completed in an expeditious manner.. Additional classroom training on the modifications will be coordinated to coincide with the simulator training at that time.
As discussed in our-letter.of October 25,'1990, simulator modifications will be complete within time limits prescribed by ANS 3.5. Tiaining will be completed during the next full training cycle following the simulator modifications.
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e ENCLOSURE 3 REVI8ED PAGE8 FOR ENGINEERING REPORT i
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ENGINEERING REPORT                                                           1 FOR                                                               j L                                                      ARKANSAS NUCLEAR ONE                                                           i RUSSELLVILLE, ARKANSAS i
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Enginocring Report Not         99 Roport                  lCC6*o2 Data Shoet                                                                              Uniti (Cont.)
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                        *Rev. Noi      I            Verification Methodi                                                                                                     Design Reviewi -
Alternate Calculationi                                                                                                                     Qualification Testing Pages Revised and/or Addedi 5' N 2o n. 2                                                                               ,
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    .                                               Alternate Calculationi                                                                                                                     Qualification Testingi Pages Revised and/or Addedi 0 7 L f% to Tab ?, Ta&r6 ; 8                                           ,
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Check if Additional Revisionsi Sapet                         ARKANSAS NUCLEAR ONE E         _ . < - - . . .

The RBS flow is actually subject to variations due to the allowed operator throttling tolerance (1125 gpm 175 gpm) and due to potential instrument error (reference 7). The applicable variations have been considered to be independent and essentially random, although it could be easily argued that this is conservative and that the operator throttling tolerance is not completely random. The operator should tend toward the middle of the allowed tolerance band, correcting to this mid-point if flow strays near the edge of the allowed band. However, it is also recognized that one could argue that the operator might delay until near the edge of the d
allowed band to correct to the midpoint. Per Reference 15, independent and random errors can be combined by means of the square root of the sum             '
of the squares. Using this methodology, Reference 34 has assessed the potential RBS flow variations due to the combined effects of the allowed operator tolerance error and the instrument loop error. These potential RBS flow variations are 1014.83 gpm to 1308.78 gpm.
Correspondingly, the minimum RBS flow effects have been conservatively assessed at 1000 gpm while maximum effects have been conservatively assessed at 1320 gpm for long-term operation, as shown in Table 2. For the postulated short-term increased LPI flow condition discussed below,            g the maximum RBS flow effects have been conservatively assessed at 1310 gpm.
2 1.11ow Consideratio.n,3 No manual action is required to assure the allowed LPI flow since it is the maximum expected due to the flow limiting cavitating venturis.                   ;
Attachment I documents test results which indicate a maximum flow through a cavitating venturi of 1910 gpm. Page 17 of reference 32 documents the expected flows for the limiting case of an LPI line break, demonstrating that the expected flow is bounded by the 1910 gpm test results. With two venturis per train, the maximum train flow is not expected to exceed 3820 gpm. These maximum flow conditions have been used to conservatively assess the long-term LPI pump NPSH performance while aligned for RB sump       &,
recirculation, as shown in Table 2.                                                  '
Higher LPI pump flow could occur for a short duration due to additional              ,
HPI " piggyback" riow if the HPI termination criteria (3100 gpm LPI flow for 20 minutes for single train operation or 2650 gpm LPI flow for 20 minutes for two train operation) from the E0P (reference 4) is not met prior to establishing RB sump recirculation. Reference 3 conservatively              ,
assesses the expected LPI flow and the capability to meet the HPI termination criteria subsequent to a spectrum of small-break LOCAs. This assessment identifies a s m il " window" of breaks around approximately 0.03 to 0.05 f t' for one train operation and around approximately 0.06 to c         0.10 f t' for two train operation that is potentially of concern. Breaks larger than thi window, up to a complete 7.1 f t' guillotine hot leg break, have adequate injection flow such that HPI will be secured prior to aligning for RB sump recirculation. Breaks smaller than this window                 .
physically restrict the combined HPI and LPI flow such that adequate LPI               l pump NPSH is assured. Since a potential small-break LOCA window of concern has been identified for which adequate ECCS NPSH may not be assured without manual action, specific consideration was taken for this     lg condition and it has been concluded that this window can be adequately accommodated within the design basis. This conclusion is based upon                     j l
6                        89R-1006-02                   '
_                     ~ . _

the inclusion in the E0P of specific guidance to limit HPI flow such that cavitation does not recur during piggyback conditions with high LPI flow.
It should also be noted that, though it may appear for this specific break " window" that reduced NPSH margin exists, actually considerable margin is available due to the conservative nature of this evaluation.
These conservatisms include:
the short duration of high flows during the potential window of concern the use of worst case assumptions for the RB sump water level, temperature and flow conditions the low likelihood of the occurrence of the specific break
                              " window" of concern the expected presence of a RB pressure in excess of the sump saturation pressure, providing significant NPSH margin (see Table 3).
These considerations are discussed in greater detail below:
: 1. Specific E0P guidance is to be added to throttle the HPI flow to between 90 and 110 gpm during high LPI flow piggyback conditions (LPI flow >3300 gpm). Under these conditions, the potential HPI g,
flow instrument error is less than 20 gpm (reference 35). In addition, a caution is expected to be added to the E0P to alert the operator to the possibility that under high LPI flow piggyback conditions, LPI pump NPSH margin may be minimal. However, it should be noted that based upon the consideration in references 5 and 6 of 3950gpm(3820gpm+130gpm)LPIand1310gpmRBSflowconditions,lA adequate NPSH margin exists to avoid cavitation. At these conditions the "B" RBS pump is estimated to be limiting with a net NPSH margin as follows:
REQUIRED                                     AVAILABLE         EXCESS Pump Train         Flow (gpml     NPSH(ft)                                        NpSH(ft)       NPSH(ft)
RBS A        1310 gpm         11.69                                          14.20           2.51 RBS B         1310 gpm        11.69                                          11.76           0.07 LPI A         3950 gpm        11.17                                          12.69           1.52 LPI B         3950 ppm        11.17                                          12.34           1.17 It should be noted that these conditions would exist for a period of 30 minutes or less, as discussed below. Thereafter, the conditions shown in Table 2 are boundingly applicable.
: 2.       The window of concern occurs because the HPI and EFW termination criteria (>3100 gpm LPI flow for 20 minutes - one train or >2650 gpm - two trains) may not be satisfied prior to establishing RB sump recirculation. During the conditions of 7                                                        89R-1006-02
_________j

concern. the LPI flow is well in excess of the required flow rate,             !
u                     however the 20 minute criteria is not yet satisfied. Once it is satisfied HPI flow can be terminated, eliminating the window of
                     . concern (i.e., LPI flow limited to 3820 gpm). From reference 3 it is estimated that the time of operation in this window should be 10           t minutes or less; however, from the HPI termination criteria it is             >
l assumed that the window of concern will exist for a duration not to exceed 20 or 30 minutes.
: 3. As discuned previously, the window of concern is limited to only a small rarige of small-break LOCAs. In addition, the minimum water level calculation (reference 12) assumes a high elevation hot leg break that maintains the RCS full of water. Lower elevation RCS breaks would provide more RB sump inventory for LPI pump NPSH further minimizing the small window for which HPI throttling is               '
required. Peak RB sump water temperature and maximum expected flows also have been assumed (references 5 and 6) to provide a boundingly conservative assessment, g ;
l              4      Du,'ing post-LOCA recirculation the RB pressure exceeds the                   ,
l                     satu,ation pressure of the RB sump water, as shown in Table 3.         NRC    !
Safet> Guide 1 (reference 14) states that no credit should be taken           .
L                     for thu excess pressure to provide adequate ECCS and containment heat rem 0 val system NPSH. This position is maintained for the            i
!                     entire ANU-1 LOCA break spectrum.      Recognizing that 1 psi is equal l                     to more than 2 foot of head, Table 3 shows that the expected RB pressure in excess of the sump saturation pressure provides considerable additional NPSH margin during post LOCA RB sump                  ;
recirculation.                                                                ~
: l.            'Therefore, although this short duration condition of additional LPI flow-            !
is'not typical of long-term ECCS and RBS pump NPSH considerations, it has'           !
: j.             been considered and adequately accommodated within the design basis,                   t l                                                                                                    t l
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7a 89R-1006-02 L

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B. Post LOCA RB Water Level                                                       I Since the BWST Technical Specification minimum water level limit will be increased to provide additional water for LPI and RBS pump NPSH during sump recirculation, the impact of this additional water level was assessed for both the maximum and minimum post LOCA sump water level conditions.
The reassessment also provided the opportunity to check the consistency of the new calculational assumptions with planned operating practice and phenomenological understancing.
Previously identified discrepancies (reference 1) had resulted in a reduced minimum post LOCA sump water level.      An increase in the minimum required BWST water level provided a means to restore some of this reduced I
sump water level. Reference 12 concludes that the new minimum post LOCA RB sump water level will be 4.51 feet above the 336'-6" RB floor level.      A minimum injected water heignt of 32.3 feet was assumed for the BWST in this calculation. This heignt is conservatively 0.1 ft less than the minimum expected with the new Technical Specification limits, as calculated in reference 18.
The maximum post LOCA sump water level (reference 13), which conservatively considers the maximum addition of potential water sources to_the RB sump, was also reassessed to determine the impact of the increased water addition from the BWST. Of principle concern in this analysis was the potential for submergence of equipment not                    :
environmentally qualified to be submerged. In the reassessment of the maximum post LOCA water level, additional increases in the potential water level were caused by the increase in the BWST level and by the use of more conservative assumptions for the water held-up in the RCS. The maximum water level, as determined in reference 13, following a large break LOCA is 9.18 feet above elevation 336'-6" and 8.88 feet for a small break LOCA      ,
(different flood levels result due to assumptions related to the expected blowdown phenomena, the corresponding RCS voiding and refill and the expected BWST drawdown). These increased maximum water levels have not resulted in the submergence of any additional EQ components not qualified for submergence.
Reference 30 summarizes the EQ component review. It should be noted that during a large break LOCA that the potential exists for some of the Emergency Feedwater Initiation and Control (EFIC) steam generator (SG) water level transmitters to De slightly submerged. However, SG cooling during a large LOCA is physically impossible due to RCS voiding, so no required functions would be lost. As previously discussed, the EFW pumps should be secured prior to depleting the BWST _(time of maximum cump level) so if the transmitters were to fail low if submerged SG overfill would not occur. During a small break LOCA, when SG cooling is potentially possible, the EFIC SG 1evel transmitters are not submerged. In addition, the conservative accounting of potential water sources makes the calculated levels very unlikely.
8                           89R-1006-02

Y.
: 5. ANO Calculation 89E-0010-26 Rev. 3, "ANO-1 LPI Pump NPSH," dated 11/02/90                                                                g
: 6. ANO Calculation 90E-0046-01, Rev. 2, "ANO-1 RBS Pump NPSH", dated 11/02/90 6
: 7. ANO Calculation 85E0-0003-01, Rev. 3, "RBS Flow Indication Loop Error", dated 08/03/90
: 8. AND DCP #90-1043, " Upgrade LPI and RBS Flow Indication Loops to R.G. 1.97. Category 1 Type A Variables" L          9. AND Calculation 88E-0105 01, Rev. 3. " Effects of Rev'd LOCA Curves on E0 of E0T in the RB", dated 07/19/90
[          10. ANO Calculation 88E-0098-14, fev.1, "ANO-1 DBA LOCA w/ Lower Spray Flow and Higher BWST Level" dated 07/17/90
: 11. AND Calculation 88E-0098 02, Rev. 2, "ANO-1 DBA LOCA w/1600 gpm Service Water Flow (a 95'F, 98'F tc Decay Heat Cooler + Additional            ,
Cases", dated 08/11/89                                                       l
: 12. ANO Calculation 89E-0164 01, Rev.1, " Post-Accident Water Level in Containment," dated 05/31/90
: 13. ANO Calculation 89E-0164-05, Rev. 2, " Maximum RB Sump Water Level post LOCA", dated 07/13/90
: 14. 'NRC Safety Guide 1, " Net Positive Suction Head for Emergency Core Cooling And Containment Heat Removal System Pumps," dated 12/1/70
: 15. AP&L Design Guide IDG-001-0, " Instrument Loop Error Analysis and Setpoint Methodology Manual," dated 01/16/90
: 16. ANO DCP #89-10128, "HPI Line Break Modifications"
: 17. ANO Calculation 88E-0098-10 Rev. O "DBA LOCA w/1600 gpm Service Water Flow 0 95'F, smaller RCB, smaller BWST, Additional Area Input",
dated 12/6/89
: 18. AND Calculation 83D-1153-01,' Rev. 2, " Error and Setpoint Analysis For BWST Level Instrumentation Loops", dated 07/16/90
: 19. ANO Calculation 89E-0164-06, Rev. O, " Spray Lambdas and LOCA Radiation Doses with Reduced Spray Flow", dated 07/17/90
: 20. ANO Calculation 89E-0164-07, Rev. O " Containment Spray Orifice Sizing", dated 07/17/90
: 21. ANO Calculation 89E-0164-08, Rev. 0", ANO-1 Maximum and Minimum Spray       _
and Sump pH", dated 07/18/90 I
i          '
i 89R-1006-02 39                                                l

L
: 22. ANO Calculation 89E-0164-09, Rev. O, "BWST/NaOH Tank Flow Analysis",
dated 07/17/90
: 23. AND Calculation 88E-0034-14, Rev. 1 " Seismic Qualification of i
Equ'",nent - T3 BWST Tank", dated 07/20/90 24     ANO Calculation 89E-0163-01, Rev. 2, "ANO-1 Sump Vortex Calculation",
dated 08/03/90                                                                          d'
: 25. ANO 1RF #3997, " Assessment of 255' F Sump Qter on the Piping Analysis for Decay Heat Lines", dated 07/20 90
: 26. ANO Calculation 89E-0018-05. Rev. .                    "Bechtel COPATTA Analysis for Peak ANO-1 Containment Sump Temperatare for a Spectrum of SBLOCAs",
dated 03/08/89
: 27. ANO Calculation 89E-0013-02, Rev.1, " Thermal Analysis of Makeup Pump Suction", dated 03/14/90.
: 29. NUREG-0897, Rev. 1 " Containment Emergency Sump Performance",
October, 1985.
: 29. NUREG/CR-2759, "A Parametric Study of Containment Emergency Sump Performance"
: 30. ANO Calculation 89E-0164-10, Rev. O, "EQ Component Review of
        ,,                                               Submergence Conditions," dated 07/23/90
: 31. f.NO Calculation M3860-3, Rev. 1, " Containment Volume Determination",
dated 06/30/89
: 32. B&W Calculation 32-1102665-00, Rev. O, "LPI Flew Split For.CF Line Break (NSS-8)", dated 5/27/79                                                            ,
: 33. ANO Calculation 870-1098-02, Rev, 5, " Piping Analysis for Decay Heat
                                                       . Lines", dated 01/27/90
: 34. ANO Calculation 90E-0058-01, Rev. O, "ANO-1 RBS A0TE and Loop Error                       g Analysis," dated 08/03/90                                                                 !
: 35. ANO Calculation 85EQ-0003-02, Rev                 6, " Loop Error Analysis for the         !
High Pressure Injection (HPI) Flow Lnops," dated 10/3/90, Table 2                      b 20 89R-1006-02
                                                                                                                                                      ]
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                                                                                                      -TALLE 2 ANO-l'ECCS PUMP MPSH DURING POST-LOCA RB SUMP RECIRCULATION REQUIRED                     AVAILABLE                       EXCESS Pumo Train       - Flow (ans)      NPSHfftl'                        NPSHfft)                  NPSHfft)
RBS A-           1320 gpa          _11.69                          14.7-                              3.01                  Ib RBS B            1320 gpe.         11.69                           12.09                              0.40 A.
LPI A           3820~gpa.          10.53                           13.35                              2.82 A-LPI B           3820 gpm           10.37                           12.79                              2.42 NOTEi No credit was taken for the feet of additional NPSH available                                                            .
due to the RB' pressure exceeding the RB sump saturation ~
                                                                              . pressure'(as shown in Table 3).
Based upon References 5 and 6.
mm.m,5  4--m_-- - - , ..m.a           -- -.-- .---.                           a.a    w-m-                        ,q ,.,rg.,g. g.,wy.,p   -e..w 3,_ , _ , ,.ry g_  .*w,gggpp.    , . __,w,,,,y,.4             .,g_gp.,        _, , , . ,
* TABLE 5                                           ,
IMPORTANT ANALYSIS INPUT ASSUMPTIONS lA 88E-0093-02    88E-0098-10      88E-0098-14    88E-0098-14 88E-0098-14 Assumptions                     Case 2                        _ Case 1         Case 2       Case 3 1.865 x 10'     I.83 x 10'      1.83 x 10'     1.83 x 10'  3.83 x 10'
: 1)   Net Free Volume (ft')
Yes             Yes            Yes         Yes
: 2)   Corrected Decay Heat              No No              Yes            Yes         Yes
: 3)   Reduced Cooler                    No Performance 110             110            110         110
: 4)   BWST Temperature (*F)            85 Yes             Yes            Yes         Yes
: 5)   Hydrogen Recombiner              No Heat Loads 3670            4128           3745        4257
: 6)   Time to Recirculation           3800 (seconds)
No              Yes            Yes         Yes
: 7)   Recirculation Time               No Properly Accounts for ECCS Injection Flow Yes             Yes            Yes         Yes
: 8)   BWST Instrument Errors           No Accounted for 3500/3000       3500/3000       3500/3000      3500/3000   3500/3000
: 9)   ECCS Flow Before/After Recirculation (gpm) l 1500/1500       1500/1500       1000/1000      1500/1000   1000/1000
: 10) RBS Flow Before/
Af ter Recirculation (gpm) 280,463         302,574        302,574     312,210         .
291,463
: 11) BWST Volume Assumed (gal)                                                                                                         ,
89R-1006-02
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