View source for ULNRC-03774, Forwards Proprietary & non-proprietary Response to 980313 RAI Re 971017 License Amend Request,Revising TS 3/4.4 for Heatup,Cooldown & Cold Overpressure Mitigation Sys Curves. Proprietary Info Withheld,Per Encl Affidavit

{{Adams
| number = ML20217D600
| issue date = 03/17/1998
| title = Forwards Proprietary & non-proprietary Response to 980313 RAI Re 971017 License Amend Request,Revising TS 3/4.4 for Heatup,Cooldown & Cold Overpressure Mitigation Sys Curves. Proprietary Info Withheld,Per Encl Affidavit
| author name = Passwater A
| author affiliation = UNION ELECTRIC CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000483
| license number = 
| contact person = 
| document report number = TAC-M99918, ULNRC-03774, ULNRC-3774, NUDOCS 9803300099
| package number = ML20013G012
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 12
| project = TAC:M99918
| stage = Other
}}

=Text=
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      ,     * :*.     ,      Union rixtric                                                                          One Ameren Ylaza I
                                 ,                                                                                  1901 Chouteau Avenue PO Box 66149 St. Louis, MO 631666149 March 17,1998                                                                         NN2 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137                                                                                           I Washington, D.C. 20555-0001 ULNRC-03774 Gentlemen:                                                                   TAC No. M99918 DOCKET NUMBER 50-483                                               ,
CALLAWAY PLANT
   .Md.                                                                UNION ELECTRIC COMPANY Y/jgggg'                                                 REVISION TO TECHNICAL SPECIFICATION 3/4.4 -REACTOR COOLANT SYSTEM

==References:==
: 1) ULNRC-03664 dated October 17,1997 l
: 2) ULNRC-03756 dated March 3,1998
: 3)  B. C. Westreich letter to G. L. Randolph dated March 13,1998 Reference 1 requested a revision to Technical Specification 3/4.4 for the heatup, cooldown and Cold Overpressure Mitigation System (COMS) curves.
l Reference 2 provided additional information in support of this amendment request.
l                                        Attached please find the additional information requested in Reference 3.
L                             A portion of this information is considered proprietary by Westinghouse Electric
: l.                            Corporation. Therefore included as Attachment C is an Application for Withholding Proprietary Information From Public Disclosure, including an affidavit which sets forth the basis by which the information may be withheld per 10 CFR Section 2.790.
If you have any questions concerning this information, please contact us.
l Sincerely, 1
1f      AQgeg Alan C. Passwater Manager, Licensing and Fuels
    ,                         WEK/pir Attachments: 1) Response to NRC RAI dated 3/13/98 (Proprietary)
: 2) Response to NRC RAI dated 3/13/98 (Non-Proprietary)'                   \,
9
                      *"^ C v, v 9
: 3) Application for withholding Proprietary Information From Public Disclosure             .
                                                                                                                                      \f g C1A         . l_ l- y ' 13
                                                                                                                                      . QO 9003300099 900317 N PDR       ADOCK 05000483                                      . D(t       I I     O fE0 A                       h p                          PDRa

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STATE OF MISSOURI )
                                                                           )                                          SS CITY OF ST. LOUIS )
Alan C. Passwater, of lawful age, being first duly sworn 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 stated are true and correct to the best of his knowledge, information and belf.ef.
By                  * *4*
Alan C. Passwater Manager, Licensing and Fuels Nuclear l
l SUBSCRIBED anct sworn to before me this                                                                    /7M          day of             ya444                                                                   , 1998.
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                            - cc:      M. H.: Fletcher-.
Professional Nuclear Consulting, Inc.
19041 Raines Drive
                                      - Derwood, MD 20855-2432
                                      - Regional Administrator U.S. Nuclear Regulatory.Com ussion Region IV' 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S.-Nuclear Regulatory: Commission 8201 NRC Road Steedman,-MO 65077-Barry. C. Westreich (2)
Office of Nuclear Reactor. Regulation U.S. Nuclear Regulatory Commission 1 White Flint,. North, Mail Stop 13E16 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 Denny Buschbaum TULElectric
                                      - P.O. Box 1002 Glen Rose, TX'76043 Pat Nugent' Pacific Gas'& Electric Regulatory. Services
                                      - P.O. Box 56-Avila Bea'ch,'CA 93424 1
J J

                                                -                                                      Attachment 2 WESTINGHOUSE PROPRIETARY Cl. ASS lil        ULNRC-03774 Page 1 of 9 RESPONSE TO NRC RAI DATED 3/13/98 Ouestion 1:                                                                                     l Input assumption #8 in the March 3,1998 submittal states that the pressure uncertainty          J calculated by Westinghouse is 85 psi, and the temperature uncertainty calculated by Westinghouse is 16'F, and includes 14'F streaming effect. These uncertainties are different from Section 4 of WCAP-14894, which states that the heatup and cooldown curves in Figures 1 and 2 (of WCAP-14894) include margins of 10'F and 60 psi for pouible instrument errors.
i Clarify the differences and/or consistencies in the values ofuncertainties discussed above by providing (a) 'a breakdown of each uncertainty component (such as allowances for instrument errors and RCS temperature and pressure differences between the sensor locations and the reactor vessel limiting beltline region), (b) a discussion of how these uncertainties are applied to the heatup and cooldown pressure / temperature limit curves, the design basis analyses of mass and heat input transients, and the establishment of PORV setpoints.
Resnonse to Ouestion 1:
For the heatup and cooldown curves the Callaway Plant has always included an additional conservative margin of 10 F and 60 psig. In this most recent COMS curve development, plant specific uncertainties of 16*F and 85 psi were applied during the j'                         COMS setpoint development.
The Callaway Technical Specifications require COMS to be enabled at 368 F. The maximum temperatures on the heatup and cooldown curves are 310 F and 270*F respectively. Since the COMS curve (with the higher uncertainties) protects all points of the heatup and cooldown curves, revision to the uncertainties in those curves were not made.
Based on WCAP-14040-NP-A, COMS PORV setpoints are devebped from the steady state heatup/cooldown curves without margins for instrument error. Therefore, the 10F and 60 psi margins were removed from the curves shown in WCAP 14894. That is for setpoint development, the limits were shifted to the left, by 10F, and up by 60 psi. Plant specific instrument uncertainties (16F and 85 psi) were applied during setpoint development.
For more information on adjustments made to the Appendix G limits, please refer to
                      . Question 4.

a i
l
                                                             .                                                     A**-h=aa* 2 WESTINGHOUSE PROPRIETARY CLASS lil                ULNRC-03774 Page 2 of 9       ;
RESPONSE TO NRC RAI DATED 3/13/98                                   l Ouestion 2:
Input Assumption Item #2 states that " Reference 3 provides composite flows from the                             i two pumps over a range of RCS pressures.... The analysis conservatively uses flow rates                           l which were increased to 105% of the calculated flow."
: a. Provide the title of" Reference 3" and provide individual mass flow rates as a function of RCS pressure for the two pumps (i.e., a centrifugal charging pump and a " normal" charging pump).
: b.      Confirm that the mass injection rates in Table 1 of the March 3 submittal, which indicates 100% of the NCP and CCP flows, are indeed 105% of the combined flow from both pumps.
Response to Ouestion 2:
: a. Reference 3 is Union Electric letter to Westinghouse, NED 97-098, dated May 12,1997. The letta provided the final results of Union Electric flow calculation, BG-073, Revision 0 which calculated the maximum flow into the RCS assuming the Normal Charging Pump (NCP) and the most powerful Centrifugal Charging
,                          Pump (CCP) are operating in parallel. The most limiting case, which results are presented below, assumes the NCP is operating, an inadvertent Safety Injection occurs, and the NCP fails to trip.
RCS press.                          Seal WtrRCS flow BIT Flow       TotalFlow to RCS New 10$% Flow (psig)                                  (spm)       (spm)               (spm)          (spm) 0                                133.29      528.07              661.36         694.43 100                                  130.76      518.09              648.85         681.41 200                                   128.20      508.06              636.26         668.07 300                                   125.62      498.00              623.62         655.39 400                                   122.99      487.89              610.88         641.42 500                                   120.32      478.72              599.04         628.99 600                                   117.60      468.38              585.98         615.90 700                                   114.83      457.64              572.47         601.09 800                                   112.01      446.44              558.45         586.37 900                                   109.15      434.73              543.88         571.07 1000                                  106.21      421.53               527.74        554.66 1100                                  103.28      409.00              512.28         537.89 1200                                  100.20      396.26 -            4 %.46         521.93-1300                                  97.04       383.32              480.36         504.82 1400.                                 93.78       370.56              464.34         488.79 1500                                  90.40       356.90              447.30         470.27 l
i l
l 1
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    "        ~
                                         .                                                                 Attachment 2
                                  ~
WESTINGHOUSE PROPRIETARY CLASS lll                           ULNRC-03774 Page 3 of 9 RESPONSE TO NRC RAIDATED 3/13/98
: b.       A comparison of the above values, which were originally provided to Westinghouse as Reference 3, and the flow rates provided in Table 1 of the March 3 submittal shows that the flows used in the COMs development analysis include the extra 5% flow for additional margin.
Ouestion 3:
Provide the PORV relieving capacities as a function ofRCS pressure and valve opening, and how they are applied in the analysis for the design basis mass and heat injection transients.
Resnonse to Ouestion 3:
LOFTRAN uses two lookup tables in order to determine the PORV relieving capacities.
Following the actuation signal to open the PORVs, the full open relief capacity is determined from the internally calculated RCS pressure, as follows:
Pressure                                   PORY Capacity (psia)                                     (ft^3/sec) sw.                                     _  . =A.
The Garrett PORV has a stroke open time of[            ]'A' seconds with the non-linear flow      -)
characteristics shown in the table below. In order to account for the flow through the PORV as the valve strokes from fully closed to fully open, the full open capacity at the LOFTRAN           l intamally calculated pressure is inuitiplied by this time A* flow fraction s

E               .
Attachment 2 WESTINGHOUSE PROPRIETARY CLASS lil                      ULNRC-03774 Page 4 of 9 RESPONSE TO NRC RAI DATED 3/13/98 Time                      Flow (seconds)                (fraction)
: a.              _        . . a.
Time zero is time at which valve begins to stroke LOFIRAN also models a [. ]** wand transnussion delay betwoca the tirse the PORV setpoint is reachad and the time that the valve begins to stroke open.
buestbn 4:
The design basis analysis results for mass and heat injection transients are described in Tables 1 and 2, respectively.
: n. Provide a comparison of the PORV setpoints, the resulting RCS peak pressures, and the pressure / temperature limits (x110%), with pressure and temperature uncertainties accounted for.
1
: b.      Describe how Table 3, " Maximum Allowable Function Generator Setpoints" in derived from the results ofTables 1 and 2.
Resnonse to Ouestion 4:
Limiting overshoots and peak RCS pressures from plant specific analyses of the mass injection and heat injection events are determined by the LOFTRAN computer code.
Using this data, a line can be defined which represents the peak RCS pressure versus setpoint, before consuleraten ofinstrument uncertantics, streaming effects, heat transport effects and the delta-P.
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Attachment 2 WESTINGHOUSE PROPRIETARY CLASS lil                                 ULNRC-03774 Page 5 of 9 RESPONSE TO NRC RAIDATED 3/13/98 The steady state AWN G limit (without margins) are adjusted in order to account for any pressure effects, as follows:
: a.       The Code Case permits a 10% relavat=i of the steady state Appendix G limit up to the calculated enable temperature of 200F.
: b.       Pressure uncertainties ===acintad with the wide range pressure transmitter
[         ]d'.                                                                                        )
: c.       The delta-P between the wide range pressure transmitter and the limiting beldine region. For 0 RCPs naning this corresponds to O psi.
For 4 RCPs running, this cesw.ds to [              ] '''.                                             !
T...,, ure effects are Wad for later. Also note that the PORV piping' limit becomes more limiting than the Appendix G limit at appmximately [                        ] ' #.
The intersection of the adjusted Appendix G limits at a given temperature with the line defined by the peak RCS pressure versus setpoint represents the maximum allowable setpoint, before accounting for temperature uncertainties, streaming effects and heat transport effects.
Maxunum allowable setpoints are determined uniquely for the mass injection event and for the heat injection event betwoca [        ]"' and [       j'''. Each maximum allowable setpoint curve is then shifted to the right in order to account for temperature effects, as follows:
: a.       T...,, mere uncertainties and streaming effects associated with the wide range temperature sensor,16F.
: b.       "Ihe maximum allowable setpoints based on the heat injection event are further adjusted by [      ] *' ([ ] *' total) ir order to account for heat ibility transport that the wideeffects. Heat range ^ ..p. Aretransport measurement  effects is [ account j'             for the p' hotter than the 1 reactor vessel temperature.
By superposhig the maximum allowable setpoints for each design basis transient and appheable number of RCPs in operation, a limiting composite maximum allowable sospoint curve is selected. Function generator breakpoints are chanan so that they do not exceed the maximum allowable setpoint cur e, as shown in the attached figure.

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Attachment 2
                                 .      WESTINGHOUSE PROPRIETARY Cl. ASS 111               ULNRC-03774 Page 7 of 9 iESPONSE TO NRC RAI DATED 3/13/98 Ouestion 5:
Provide the upper pressure limit of the COMS to maintain the integrity of the PORV piping with a discussion of how the value is selected.
Response to Ouestion 5:
The upper pressure limit for COMS in regards to the piping limit is 800 psig. This is a generic setpoint to pretent the piping loads in the PORV discharge line piping from becoming excessive.
If the PORV setpoint was allowed to incuease with the increase in the Appendix G limit, the loads in the PORV discharge piping induced by the rapid cycling open and clossi of the PORV during a COMS transient could become excessive. A generic upper limit of 800 psig for the PORV setpoint would maintain the loadings within design limits. Since the pressure at the PORV inlet will always be less than the pressure measured by the wide-range pressure transmitter, there is no need to include pressure measurement uncertainties in the PORV setpoint development when the PORV discharge piping becomes the pressure limit.
Ouestion 6:
As part of the findings from the NRC Mainc Yankee Lessons Learned Task, the staff needs to verify thst, when applying codes or methodologies described in a topical report by vendors or licensees for licensing actions, the conditions or restrictions specified in the safety evaluation report accepting the topical report are met. Therefore, it is requested that each submittal listing all restrictions and conditions specified in the SERs for the referenced topical reports, as well as an evaluation demonstrating conformance with these restrictions and conditions. Since the COMS
:etpoint analysis referenced the methodologies described in WCAP-14040, Rev. 2, please list all conditions and restrictions, if any, related to the COMS setpoint methodologies in the SERs of WCAP-14040, and other referenced topical reports, if any, and provide an evaluation of their conformance.-
Bcgge.pse to Ouestion 6:
The conditions and restrictions related to the COMS setpoint methodologies as listed in the SER associated with WCAP-14040 are:
: 1)       The use of a plant-specific surveillance program.
The Callaway plant-specific surveillance program was determined to be credible in WCAP-14895, Appendix D. This WCAP was transmitted via ULNRC-03664 (October 17,1997) as Attachment 5.
: 2)       The use of plant-specific surveillance data in calculating adjusted reference temperatures.

T.  '
                                                                                                               \
Attachment 2          f WESTINGHOUSE PROPRIETARY CLASS lll                 ULNRC-03774 Page 8 of 9 RESPONSE TO NRC RAI DATED 3/13/98 The use of Callaway plant-specific surveillance data is discussed in WCAP-14896 This WCAP was transmitted via ULNRC-03664 (October 17,1997) as Attachment 6.
: 3)    The use of relief valves of the RHR system as a part of COMS.
The Callaway COMS analysis assumes that the RHR suction relief valves are available for cold overpressure protection. These valves are sufficient to prevent overpressurization for the heat or mass injection events (Reference ULNRC-03756, dated March 3,1998). The RHR suction relief valves are also part of Callaway Technical Specification 3.4.9.3, Overpressure Protection System.

      .                                                                           Attachment 2 WESTINGHOUSE PROPRIETARY CLASS lil      ULNRC-03774 Page 9 of 9 RESPONSE TO NRC RAI DATED 3/13/98
                                                          ~
Callaway COM8 Maximum Allowed Setpoint vs. Steekpoints em i
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Maximum Allowed Setpoint                  , Function Generator Breakpoints 1
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