JAFP-09-0037, Supplemental Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems

Supplemental Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems

ML090960469
Person / Time
Site:	FitzPatrick
Issue date:	03/31/2009
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-09-0037
Download: ML090960469 (73)

Text

• .. - ý :.- - -.1 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP 4

v~uav~u~P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Pete Dietrich Site Vice President - JAF NPP March 31, 2009 JAFP-09-0037 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission" Washington, DC 20555-0001 7'

Subject:

Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Station License No. DPR-59 Docket No. 50-333 Supplemental Response to NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems"

References:

1. Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems",

dated January 11, 2008.

2. Entergy Letter, Peter Dietrich to U.S. Nuclear Regulatory Commission, "Extension Request for Response to GL 2008-01 ,"JAFP-08-0092, September 12, 2008.

3. Entergy Letter, Peter Dietrich to U.S. Nuclear Regulatory Commission, "Nine-Month Response to NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", JAFP-08-0107, October 14, 2008.

Dear Sir or Madam:

The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference 1) to address the issue of gas accumulation in emergency core cooling, decay heat removal, and containment spray systems. Entergy requested an extension of time to complete the actions required by Generic Letter 2008-01 (Reference 2) and agreed to submit a nine-month response to address the results of assessment and inspection activities conducted outside containment (Reference 3). Entergy also committed to providing a supplemental response that would include the results of assessment and inspection activities conducted inside, containment during the fall 2008 refueling outage. The enclosure to this letter provides that supplemental response.

4 cf

JAFP-09-0037 Page 2 of 2 There are no new regulatory commitments made in this letter.

If you have any questions, please contact Mr. Joseph Pechacek at (315) 349-6766.

I declare under the penalty of perjury that the enclosed information is true and correct.

Executed on this 3 1 st of March 2009.

Pete Dietrich Site Vice President

Enclosure:

Entergy Engineering Report, "Summary of Activities Associated with the Resolution of GL 2008-01 ," JAF-RPT-08-00015, Revision 0, March 2009.

cc:

Mr. Samuel J. Collins, Regional Administrator Mr. Bhalchandra Vaidya, U.S. Nuclear Regulatory Commission, Project Manager Region I Plant Licensing Branch 475 Allendale Road U.S. Nuclear Regulatory Commission King of Prussia, PA 19406-1415 Mail Stop O-8-C2A Washington, DC 20555 Office of NRC Resident Inspector James A. FitzPatrick Nuclear Power Plant Mr. Charles Donaldson, Esquire P.O. Box 136 Assistant Attorney General Lycoming, New York 13093 New York Department of Law 120 Broadway Mr. Paul Tonko, President New York, New York 10271 New York State Energy Research and Development Authority Mr. Paul Eddy 17 Columbia Circle New York State Department of Public Albany, New York 12203-6399 Services 3 Empire State Plaza Albany, New York 12223-1350

JAFP-09-0037 ENCLOSURE, Summary of Activities Associated with the Resolution of GL 2008-01

Engineering Report JAF-RPT-08-00015 MAI - Revision 0 7ý- En.tergy Page 1 of 70 Engineering Report No. JAF-RPT-08-00015 Rev. 0 Page 1 of 70

=En tergy ENTERGY NUCLEAR Engineering Report Cover Sheet Summary of Activities Associated with the Resolution of GL 2008-01 Engineering Report Type:

New Z Revision E] Cancelled F-D Superseded D Applicable Site(s)

IPI El IP2 E-- -P3 I - JAF Z PNPS EI VYD wPo L ANO!I- PLP [---

ANO2 [-] ECHLI GGNS [:] RBS LI WF3 L DRN (EC) No. -N/A; Z<] EC 10507 Report Origin: Z Entergy [-D Vendor Vendor Document No.:

Quality-Related: Z Yes D- No Prepared by: Date: z IL o Responsible Engineer (Print Name/Sign)

Design Verified: Date:

Design Verifier (if required) (Print Name/Sign)

Reviewed by: Date: '361 01 Reviewr (Print Name/Sign)

Reviewed by*: N/A Date:

ANII (if required) (Print Name/Sign)

Approved by: Date: 3[9[09 Supe visor (Print Name/.gT)

• . For ASME Section-XI Code Program plans per EN-DC-120, if required

Engineering Report JAF-RPT-08-00015 in Revision 0 EnteW Page 2 of 70 TABLE OF CONTENTS 1.0 BACKGROUIND 3 2.0 PURPOSE & SCOPE 3 3.0 SYSTEM DESCRIPTION 4 4.0 LICENSING BASIS EVALUATION 5 5.0 DESIGN EVALUATION 12

-5.1 DESIGN BASIS DOCUMENTS REVIEW 12 5.2 DRAWING REVIEW 28 5.3 SYSTEM WALKDOWNS 29 5.4 SYSTEM REVIEW 36 6.0 TESTING EVALUATION 52 7.0 CORRECTIVE ACTIONS 57 8.0 TRAINING 58 9.0

SUMMARY

OF INTERNAL OE REVIEW 59

10.0 CONCLUSION

S 60

11.0 REFERENCES

60 12.0 ATTACHMENTS 64 12.1 OE REVIEW 65 12.2 ABS PROJECT DELIVERABLES 70 12.3 ABS CONSULTING REPORT (See EC 10507 in INDUS)

Engineering Report JAF.-RPT-08-00015 Revision 0 Page 3 of 70

1.0 BACKGROUND

The NRC requested via GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" that licensees evaluate their Emergency Core Cooling System (ECCS), Decay Heat Removal (DHR) system, and..

containment spray system licensing basis, design, testing, and corrective actions to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.

2.0 PURPOSE & SCOPE:

The purpose of this Engineering report is to document the review of the High Pressure Coolant Injection (HPCI), Core Spray (CS) and Residual Heat Removal (RHR) systems in accordance with the requirements of the NRC Generic Letter 2008-01.

The systems at JAF Nuclear PowerStation that are in the scope of GL 08-0] include operating modes of the RHR system, the CS system and the HPCIsystem.

All susceptible piping in each of the identified systems was walked down, the pipe slope measuredand recorded,and the vent locations identified. This includedpump suction piping from the Condensate Storage Tank (CST) and the suppressionpool andpump dischargepiping up to the containmentpenetrations. Pumpflow test lines that return to the suppressionpool have been evaluated and all piping on the pump suction side, with the possibility of transportingaccumulatedgas to the pump suctions under postulatedpost-accidentflow scenarios, have been evaluated. In addition, dischargepiping that could either deadheadgas pockets or sweep gases into the Reactor CoolantSystem (RCS) or containment have also been evaluated.

The Torus Spray piping and the RHR ContainmentSpray piping are included in the scope of GL 2008-01 except for the portions ofpipingfrom the inboardisolation valve to the injection point which have been excludedfrom the scope of GL 08-01. These pipe segments are excluded on the basis that they are open to the containmentatmosphere and not requiredto be waterfilled priorto system actuation. Fillingof these lines on containment spray initiation is included in the system design. The Reactor Core Injection Cooling (RCIQ)System, although credited in the FSAR for the loss offeed water transient,is not consideredan Emergency Core Cooling System (ECCS)therefore is being excludedfrom the evaluation of this Generic Letter.

The exclusion of this system is consistent with industrypeers.

The Shutdown Cooling System is excludedfrom the scope of GL 2008-01 due to the fact this system is a manually initiatedmode of the RHR System and is placed in service during normal shutdown and cool down, which requiresmanual venting andfilling of the system prior to start.

This ensures no voids arepresent.

Engineering Report JAF-RPT-08-00015 Revision 0 Page 4 of 70 3.0 SYSTEM DESCRIPTIONS:

High Pressur'eCoolant Injection (HPCI) System Description The HPCISystem provides and maintainsan adequate coolant inventory inside the reactor vessel to preventfuel clad melting as'a result ofpostulatedsmall breaks in the Reactor Coolant PressureBoundary. A high pressure system is'neededfor such breaks because the reactor vessel depressurizesslowly, preventing low pressure systems from injecting coolant. The HPCI System includes a turbine-pumppowered by reactorsteam generated by residual decay heat in the core. *Thisensures availabilityof the system in case of a loss of off-site power. (FSAR Section 1.6.2.11; OP-15, Rev. 54, "High Pressure CoolantInjection ")

The'HPCIpump suction is normally lined up to the CondensateStorage Tanks (CST) in order to maintain the pump primed. The alternateHPCIpumpsuction supply takes suction from the torus. Both line-ups will supply coolant to the reactorpressurevessel (RPV)to lower RPV pressureso that low pressure coolant injection systems can supply coolant to the RPV. HPCI is normally maintained in standby and is capableof cold quick start immediately upon initiation. The HPCI turbine is driven by decay heat steam. The HPCIpump injects water from the CSTs or torus into the RPV to lower RPVpressureso that'lowpressure coolant injection systems can supply coolant to the.RPV. HPCIincludes a steam turbine driven pump, piping, valves, and controls. With the exception of HPCISteam Supply Line InboardIsolation 23MO V-15 and HPCI Turbine Exhaust Line Vacuum Breaker Valve 23MO V-59, which are powered by AC, all turbinecontrols and electric motor driven components arepowered by DC.

Because 23MO V-15 is normally open when HPCIis requiredto be operable and HPCIcan operate with 23M0V-59 in the open or closedposition, no ACpower is normally requiredfor HPCIoperation under the conditions that exist during automatic initiation. (FSAR Section 1.6.2.11; OP-15, Rev. 54, "High Pressure Coolant Injection")

Core Spray System Description The Core Spray (CS) system consists of two independent systems. Each system includes one 100 percent centrifugalwaterpump driven by an electric motor that can deliver cooling water to spray spargers directly over the core. The system is actuated by conditions indicatingthat a breach exists in the Reactor CoolantPressureBoundary, but water is delivered to the core only after reactor vessel pressureis reduced. This system provides the capabilityto cool thefuel by sprayingwater-onto the core. The Core Spray system is capable ofpreventing excessive fuel clad temperaturesfollowing a loss-of-coolant accident. Suction can also be lined up to condensate storage tanks. (OSARSection 1.6.2.11; OP-14 Rev. 31, "Core Spray System ")

ResidualHeat Removal System Description Low Pressure Coolant Injection (LPCI) is an operatingmode of the ResidualHeat Removal (RHR) system. The LPCI mode acts as an engineeredsafeguardin conjunction with the other Emergency Core Cooling Systems. LPCI uses the pump loops of the RIIR system to inject cooling water at low pressure into a reactor recirculationloop. LPCI is actuated by conditions

Engineering Report JAF-RPT-08-00015 Revision 0 Sntery Page 5 of 70 indicatinga breach in the Reactor Coolant Pressure'Boundary,but water is delivered to the core only after reactor vessel pressure is reduced. LPCI operation, together with the core shroud andjetpump arrangement,provides the capabilityof core re-floodingfollowing a loss-of coolant accident in time to prevent excessive fuel clad temperatures' The Suppression Pool Cooling (SPC) subsystem of RHR is-placedin operation to limit the temperatureof the water in the suppressionpoolfollowing a design basis loss-of-coolant accident. In the suppr~essionpool cooling mode of operation the RHR pumps take suctionfrom the suppressionpool andpump the water through the RHR heat exchangers where cooling takes place. The cooledfluid is then dischargedback to the suppressionpool. (FSAR Section 1.6.2.11)

The Containment Spray mode is an integralpart of the RHR System and is used to aid in reducing drywell pressurefollowing a LOCA. The Containment Spray mode is initiated manually after the LPCI cooling requirements have been satisfied. An interlock is providedso that the control room operatordoes not inadvertently initiate containment spray before LPCI requirements are met.

As stated in Section 2.0 PURPOSEand SCOPE: "The Torus Spray piping and the RHR ContainmentSpray piping are included in the scope of GL 2008-01 exceptfor the portions of pipingfrom the inboardisolation valve to the injectionpoint which have been excludedfrom the scope of GL 08-01. These pipe segments,are excluded on the basis that they are open to the containment atmosphere and not requiredto be waterfilled prior to system actuation".

Duringcontainmentspray operation,RHR pumps take suctionfrom the torus and discharge through RHR heat exchangers, where heat is transferredto RHR service water. The cooled water is then diverted into either the drywell spray header or the torus spray header. The spray in the drywell condenses steam to lower drywell pressure. The water collects on the bottom of the drywell until water level reaches the suppression vent lines, it then overflows and drains back to the torus. The spray in the torus airspace cools non-condensablegases. (FSAR 4.8.6.2; OP-13 Rev. 13, "ResidualHeat Removal System ")

4.0 LICENSING BASIS EVALUATION:

Discuss the review of: Tech Specs (TS) and Bases, UFSAR, Licensee controlled documents and Bases, Responses to NRC Generic Communications, Regulatory Commitments.

Summarize the changes to the licensing basis.

4.1 Identify and review the Current Licensing Basis with respect to gas accumulation for the systems to be evaluated, including periodic venting requirements based on a review of, for example, the TS, TS Bases, UFSAR, Licensee Controlled Documents (e.g.,

Technical Requirements Manual (TRM) and TRM Bases), docketed correspondence, Licensing Commitments, and License Conditions.

The licensing basis documents that were reviewedfor venting requirements were the OperatingLicense (OL), Technical Specifications (TS), Updated FinalSafety Analysis

Engineering Report JAF-RPT-08-00015 Revision 0 Page 6 of 70 Report (UFSAR), TRM andplant specific regulatorycommitments. An electronic search was performed of these documents using the words "air", "gas ", "vent" and void".

OperatingLicense.(OL)

The OL does not contain any license conditions that specifically address gas accumulation.

Technical Specifications(TS)

Limiting Condition of Operation (LCO) 3.5.1 states "Each ECCS injection/spray subsystem and the Automatic DepressurizationSystem function of six safety/relief valves shall be OPERABLE.

o SR 3.5.1.1 states, "Verify, for each ECCS injection/spraysubsystem, the piping isfilled with waterfrom the pump dischargecheck valve to the injection valve. Frequency-31 days.

o The basesfor Surveillance Requirement (SR) 3.521.1 states, "Theflow path air.

piping has the potential to develop voids andpockets.of entrained Maintainingthe pump discharge lines of the HPCISystem, CS System, and LPCI subsystemsfull of water ensures that the ECCS will perform properly, injecting itsfull capacity into the RCS upon demand. This will alsoprevent a water hammerfollowing ECCS initiationsignal. One acceptable method of ensuring that the lines arefull is to vent at the high points and observe waterflqw through the vent. Another acceptable method,is to verify that the associated "keep full" level switch alarms are clear. The 31 dayfrequency is based on the gradualnature of void buildup in the ECCS piping, the proceduralcontrols governing system operation, and operatingexperience.

LCO 3.5.2 states "Two low pressure ECCS injection/spraysubsystems shall be OPERABLE.

o SR 3.5.2.3 states, "Verify, for each ECCS injection/spraysubsystem, the piping isfilled with waterfrom the pump discharge check valve to the injection valve. Frequency-31 days.

o The basesfor SR 3.5.2.3 states, "Theflow path piping has the potential to develop voids and pockets of entrainedair. Maintainingthe pump discharge lines of the HPCISystem, CS System, and LPCIsubsystems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent a water hammerfollowing ECCS initiationsignal.. One acceptablemethod of ensuringthat the lines arefull is to vent at the high points and observe waterflow.through the vent.

Another acceptable method is to verify that the associated "keep full" level

Engineering Report JAF-RPT-08-00015 gog Revision 0 Page 7 of 70 switch alarms are clear. The 31 day frequency is based on the gradual natureof void buildup in the ECCS piping, the proceduralcontrols governingsystem operation, and operatingexperience.

UpdatedFinal Safety Analysis Report The UFSAR was searchedfor any reference to gas accumulation or periodic venting and the following statement concerning the operation of the Core Spray pump was identified. No discussion concerning gas accumulation or periodic venting associated with HPCIor RHR wasfound in the UFSAR.

Operationof a Core Spray pump, other than in performance of its accident mitigationfunction, is performed with thatpump train declared inoperable.

Analysis performed in support of the ECCS suction strainerreplacement, during the 1998 refueling outage, identified a potentialfor gas entrainment into a Core Spray pump if a LOCA were to occur while the pump was operating. The limiting conditionsfor operation ensure that the minimum complement of ECCS subsystems are available in the event the operating Core Spraypump is degradedwhen the LOCA downcomers clear. (UFSAR 6.6)

Technical Requirements Manual The TRM was searched and the following statement concerning the Emergency Core Cooling System (ECCS) Discharge Line Keep Full, Alarm Instrumentation was identified. (TRS 3.3.E) o Perform a CHANNEL FUNCTIONAL TEST of the Core Spray and RHR System discharge line keep full alarm instrumentation on a frequency of 92 days.

Docketed Correspondence,Licensing Commitments and License Conditions JAF's docketed correspondence, licensing commitments and licensing conditions were searchedand thefollowing commitments were identified:

o A-1273 NRC Inspection 50-333/75-04 Summary: During routine plant inspection,found damaged pipe restraints and broken snubber on containment spray line. Probable cause was due to operating the RHR system with the discharge piping not full of water.

Operating only one side of RHR in shutdown cooling mode, the keep full system was not availableto the other side.

Action: Add a keep full system to the "A "RHR System.

o A-1485 DamagedContainment Spray Line Pipe Support

Ask Engineering Report JAF-RPT-08-00015 Revision 0 En teWPage 8 of 70 Summary: During routine plant inspection, found damaged pipe restraints and broken snubber on containment spray line. Probablecause was due to operating the RHR system with the discharge piping not full of water.

Operating only one side of RHR in shutdown cooling mode, the keep full system was not availableto the other side.

Action: Modify RHR System to provide a keep full system to avoid water hammer.

o A-2232 Proposedchange to Technical Specifications Summary: Added level switches to the discharge piping of the Core Spray and RHR Systems to monitor the dischargepiping.

Action: Add level switches to Core Spray and RHR Keep Full Systems o A-2583 NRC Inspection 50-333/78-19 Summary: On August 6, 1978, when the High Pressure Coolant Injection (HPCI) system became inoperable due to a failed suction valve, the system was not declared inoperableand the required operability demonstrations of the other core cooling systems were no't performed.

Action: To prevent a similar occurrence on the RHR System, procedures were revised to assurethat the RHR Keep Full System was, in fact, kept full.

o A-5408 NUREG-0737 Item I1.B.] - NYPA Response to NRC Question Summary: NUREG- 0737Item 11.B.1 Action: Venting of the RHR heat exchanger is accomplished through two safety related motor operated valves, installed in series and operatedfrom the control room. Operatingproceduresprovide the operatorwith guidance for venting the heat exchanger to prevent accumulation of noncondensible gases.

o A4-11262 ProposedChange to Technical Specifications Summary: The proposed amendment to the JAF Technical Specifications updates tables 3.7-1 ("Primary Containment Isolation Valves ") and 4.7-2

("Exception to Type C Tests') to reflect the ContainmentIsolation Valves in the RHR and Core Spray keep-full systems.

Action: The RIHR Keep Full System will be installed during the 1990 refueling outage and will not be declared operationaluntil this proposed Technical Specification change has been issued by the NRC Staff. Until then, the RHR Keep Full minimum flow discharge lines will remain isolated and active equipment will be de-energized.

Engineering Report JAF-RPT-08-00015 Revision 0 Li1t7I Page 9 of 70 4.2 Determine if changes to the Current Licensing Basis, e.g. UFSAR, TS, TS Bases, TRM or TRM Bases, are required for each system being evaluated.

4.2.1 The GL states that TS Surveillance Requirements (SR)s should be complete and address both the suction and discharge piping, when applicable.

TS 3.5.1, SR 3.5.1.1 and TS 3.5.2, SR 3.5.2.3 have a requirement to ensure for each ECCS injection/spray system, the pump discharge piping is filled with waterfrom the pump discharge check valve to the injection valve on a 31 day frequency. Entergy is aware that the NRC is' working with the industry to establish SR requirements and will commit to consider these changes once staff has approved the proposed approach.

Entergy does not consider the lack of SRs on pump suction piping to be a safety issue since the suction pipingfrom the Torus and CST creates a positive pressure up to the pump. There is minimal potentialforgas intrusion once the suction lines are shown to be full of water andfree of voids. JAF recognizes that there is a vulnerability that the suction piping,pump casing and the dischargepipingfrom the pump up to the discharge check valve may have a potentialfor gas voiding. However, based on the results of the walkdowns performed by ABS, seven potentialvoid areaswere identified in suction side piping. A UT was performedat each of these seven locations and no voids were identified. (ABS Report 1924850-R-001, Revision 1, Section 4.2, Table 4-1).

Duringnormalpower operation conditions the pump / system ST and operation have not exhibited any adverse operationalcharacteristicsindicative of air intrusion (such as pump cavatation, water hammer or vapor bound heat exchangers where applicable,etc.).

4.2.2 The Bases for the TS Surveillance Requirement(s) should be written to ensure the systems are "sufficiently full of water" vs. "full of water" (see GL, page 6, paragraph 2 of the Discussion Section).

The Basesfor the SR currently states that the flow path piping has the potential to develop voids andpockets of entrainedair. Maintainingthe pump discharge lines of HPCI, CS, and LPCI systems full of water ensures that the ECCS will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent a water hammerfollowing an ECCS initiationsignal. One acceptable method of ensuring that the lines arefull is to vent at the high points and observe waterflow through the vent. Another acceptablemethod is to verify that the associated "keep full" level switch alarms are clear. The 31 day Frequencyis based on the gradualnature of void buildup in the ECCSpiping, the proceduralcontrols governing system operation and operatingexperience.

Engineering Report JAF-RPT-08-00015 Revision 0 Page 10 of 70 The subject TS Surveillance Requirement does not address the suction side, or the section of dischargepipingfrom the pump tothe discharge check valve, including the pump casing. JAF does recognize that there is a vulnerability that the suction piping,pump casing and the dischargepipingfrom the pump up to the discharge check valve may have a potentialfor gas voiding.. The current wording in the Bases is nonconservative in ensuring that the system has been properly vented. This was addressedin ABS evaluation. .(Reference ABS Report 1924850-R-001, Revision 1, Section 3.3.9 Potential Voids at Component and Piping ConfigurationLo'cations).

or revising TRM 4.2.3 Revise the Bases for the Tech Spec SR(s) and consider adding requirements for these systems to address periodic monitoring due to gas accumulation vulnerabilities, if required.

The discussion on revising the Bases and the TS Surveillance Requirements is discussed above. JAF will commit to a long-term action to determine the need to ensureproperventing of the suction piping, the pump casings and the dischargepipingfrom the pump up to the discharge check valve. Based on these evaluations,further actions may be defined. This was addressedin ABS evaluation. (Reference ABS Report 1924850-R-001, Revision 1, Section 3.3.9 Potential Voids at Component and Piping Configuration'Locations).

4.3 Identify Current Licensing Basis changes resulting from the evaluation performed in Section 4.2 above.

• JAF will revise TS Bases to specify that the subject systems are "sufficientlyfull of water" vs. 'full of water". Included in this commitment will be an evaluation of the need to vent on a specifiedfrequency to ensure subject systems are sufficiently full.

JAF will revise commitment A-5408 for venting of the RHR heat exchangers. The revised commitment will vent through the existing high point vents in conjunction with the two safety-related motor operatedvalves (MOVs). ,Use of the high point vents in conjunction with the MOVs will reduce stay time and ensure adequate venting.

4.4 State that changes proposed by the Technical Specification Task Force (TSTF) will be considered for implementation following NRC approval.

Entergy is aware that the NRC is working with the industry to establish TS Surveillance Requirements and will commit to implement these changes once staff has approved the proposed approach.

14.5 Enter applicable changes that were identified as part of the'Current Licensing Basis review in the Corrective Action Program (CAP).

Engineering Report JAF-RPT-08-0001 5 Revision 0 Entfffl(Page 11 of 70

• LO-LAR-2008-00020 JAF will revise TS Bases to specify that the subject systems are "sufficientlyfull of water" vs. 'full of water". Included in this commitment will be an evaluation of the need to vent on a specifiedfrequency to ensure subject systems are sufficiently full.

LO-LAR-2008-00020 JAF will revise commitment A-5408 for venting of the RHR heat exchangers. The revised commitment will vent through the existing high point vents in conjunction with the two safety-related motor operatedvalves (MOVs). Use of the high point vents in conjunction with the MOVs will reduce stay time and ensure adequate venting.

4.6 Document the results of the Current Licensing Basis review and summarize the changes that will be implemented and the schedule for implementation of the changes.

Based on the review of the CurrentLicensing Basis as requested by GL-2008-01, JAF has determined the following changes will be required.

JAF will revise TS Bases to specify that the subject systems are "sufficientlyfull of water" vs. 'full of water ". Included in this commitment will be an evaluation of the need to vent on a specifiedfrequency to ensure subject systems are sufficiently full.

This action will be completion within 90 days following NRC publicationof the Notice of Approval of the TSTF Traveler in the FederalRegister.

JAF will revise commitment A-5408 for venting of the RHR heat exchangers.

The revised commitment will vent through the existing high point vents in conjunction with the two safety-related motor operated valves (MOVs). Use of the high point vents in conjunction with the MOVs will reduce stay time and ensure adequate venting.

This action will be completed on or before 04/30/09.

4.7 The Current Licensing Basis review activities discussed in sections 4.1 and 4.2 will be completed by October 11, 2008. However, the need for additional changes to Current Licensing Basis documents may be identified during activities that occur after October 11, 2008 (e.g., piping walkdowns performed during a refueling outage and the results from any industry testing and analytical programs).

The Licensing Basis review activities discussed in sections 4.1 and 4.2 have been completed.

A walkdown ofpiping, both non-insulated and insulated,inside and outside of containment, has been completed with the exception of the inaccessiblepipe identified below:

Engineering Report JAF-RPT-08-000 15 Revision 0

-Enterg Page 12 of 70 o HPCIsuction pipingfrom CST Pit to Reactor Building Wall - Buried o RCJCsuction pipingfrom CSTPit to Reactor Building Wall - Buried o CS suction pipingfrom CST Pit to Reactor Building Wall - Buried o CS suction pipingfrom CST in East Crescent - inaccessiblewithout scaffolding o Portionof RHR Train B Containment Spray line overhead at 300' RXBLD NE -

inaccessiblewithout scaffolding o Portionof RHR TrainsA to LPCI in West Crescent- inaccessiblewithout scaffolding o Portionof RHR Trains B to LPCI in East Crescent - inaccessible without scaffolding A tabletop review was conducted with Engineering,Operations,PS&O, Maintenance, and RP which reviewed system isometric drawingsfor the inaccessiblepiping areas. It was determined through drawing reviews during the tabletop mulit-departmental reviews that the above locations did not cite any areasfor the potentialto exhibit any gas intrusion. Also, due to the satisfactory results of the piping that was accessedfor the walkdown and the history offew air voiding events at JAF, included with the table top reviews, it is not necessary to perform walkdowns of the inaccessiblesections of this piping. The aforementionedreview conclusionperformed by JAF was corroboratedby the ABS evaluation which did not require additionalwalkdowns and void testing of the piping that was not walked down. System walkdowns isfurther discussed in Section 5.3.

4.8 Determine if any corrective actions will be completed after October 11, 2008 and identify as licensee commitments that will not be completed within the 9-month GL response date.

a JAF will revise TS Bases to specify that the subject systems are "sufficientlyfull of water" vs. 'full of water". Included in this commitment will be an evaluation of the need to vent on a specifiedfrequency to ensure subject systems are sufficiently full. (LO-LAR-2008-00020, CA-14) a JAF will revise commitment A-5408 for venting of the RHR heat exchangers.

The revised commitment will vent through the existing high point vents in conjunction with the two safety-relatedmotor operatedvalves (MOVs). Use of the high point vents in conjunction with the MOVs will reduce stay time and ensure adequate venting. (LO-LAR-2008-00020, CA-12)

Engineering Report JAF-RPT-08-00015 Entergy *Revision 0 Page 13 of 70 5.0 DESIGN EVALUATION:

Discuss the review of Design Basis Documents (Calculations, Isometric drawings, P&IDs, etc),

gas intrusion mechanisms and acceptance criteria. Summarize the changes to the design basis.

5.1 DESIGN BASIS DOCUMENTS REVIEW Include Calculations and Engineering Evaluations and Vendor Technical Manuals, with respect to gas accumulation for the systems to be. evaluated.

Examples of relevant Design Basis documentation include:

0 System periodic venting requirements.

Tech Spec SR 3.5.1.1 states, "Verify, for each ECCS injection/spraysubsystem, the piping is filled with waterfrom the pump discharge check valve to the injection valve. ". The frequencyfor this SR is 31 days.

• Statements regarding system keep-fill designs and requirements, if installed.

RHR System The RHR Keep-full pumps keep the RHR System dischargepipingfull of water during the Standby mode of operation. Whenever an RHR pump is running, the keep-full pump in the associatedoperatingloop should be secured.

Requirement: The RHR Keep-Full Subsystem and instrumentsfor maintainingand monitoring the RHR dischargepiping in a filled condition must be,adequate.

Section 4.5.6 of the RHR system design specification 22A,14 72 states that, "A means such as a pressurized water supply must be provided to insure that the discharg'e piping remainsfull of water." RHR keep-full pumps were installedunder modification F1- 75-253.

Reason: The RHR pump dischargepiping is requiredto be maintainedfull of water to avoid water hammer and delay ofLPCI injectionflow. Based on experience in operatingBWRs, the NRC had a concern that it may be difficult to maintain the ECCSpump dischargepipingfull of water. This NRC concern was realized in the following event at JAF.

Duringa shutdown cooling operation in 1975, the 'A' Containment Spray line was found to be damaged due to water hammer. The cause was identified to be the 'A' RHR loop piping not being kept full by the Keep-Full Subsystem during the SDC operation. The cause was attributedto the improperdesign of the Keep-Full Subsystem. The Keep-Full Subsystem was connected only to the 'B' RHR loop piping. Duringpower operation, the Keep-Full Subsystem charges both RHR loops via RHR loops cross-tie line. Duringthe SDC mode, the cross tie line isolation valve IOMOV-20 was closed causing 'A'RHR looppipingto be isolatedfrom the

'B' loop and the Keep-Full Subsystem.

Engineering Report JAF-RPT-08-00015 Entery Revision 0 Page 14 of 70 Design Feature: As a result of the LPCIfix, the RHR discharge header is isolated from the originally installedKeep-Full Subsystem by I OMOV-20 which is closed when the RHR system is in the standby mode. Under the two identical modifications, F1-74-052 and F1-75-13 a line was installedfrom the existing Keep-Full Subsystem header to RHR loops 'B' and 'A 'respectively. A new Keep-Full pumping subsystem using the Keep-Fullpumps I OP-2A, B was added by Modification F1-75-253 to maintain the RHR pipingfull of water. The replacement pump installedfor the Keep-Full Subsystem was evaluated to confirm its adequacy.

Source: Design Basis Document (DBD)-010, "Design Basis'Documentfor the Residual Heat Removal System Modification JD-03-005 (ER-02-0031) replacedpreviously used strap-on ultrasonic level detectors mounted external to piping and used to monitor high points in the RHR and core spray systems for waterfilled condition with thermal dispersion level detectors which place the sensor in the monitoredfluid to ensure high points in the piping arefilled with water. This change was made to correctprevious performance deficiencies with the external ultrasonicdetectors and have performed successfully for a number ofyears.

Core Spray System The CS Keep-Full Subsystem is provided to maintain the CS system discharge piping in a full condition. The subsystem consists of a hold pump and associated piping, valves, instrument and controls.

Requirement: Provisionsmust be made to assurethe CS system piping is full of water toiavoid water hammer on pump start. Section 4.5.5 of the core spray design specification 22A1435 states that, "Provisionshall be made to keep the core spray discharge continuouslyfull of water to avoid time delays in filling the lines and to avoid hydraulic hammer." Section 4.4.3.1 of the core spray design specification 22A.1435 states that, "A check valve shall beprovided in the pump dischargeline below the water level,in the suppressionpool. This valve shall cause the line downstream of the valve to remainfilled with water."

Reason: Based on experience in operatingB WRs, the NRC had a concern that it may be difficult to maintain the ECCSpump dischargepipingfull of water. In 1975, damage to the RHR system piping due to water hammer occurredat JAF when the RHR pump was startedfor the shutdown coolingfunction. The CS system was consideredto have the same potentialproblem on pump start. Core spray keep full pumps appear to have been included in the initialplant design and were purchased under APO-73B.

Engineering Report JAF-RPT-08-00015 Revision 0 Enlitgy Page 15 of 70 Design Features: A Core Spray (CS) Hold Pump in each CS system loop normally operates to maintainthe CS pump dischargepiping up to the isolation valves full of water. The Condensate TransferPump has the capabilityto provide backup to the hold pumps if needed through a normally closedgate valve. A modification improved the power supplies to the hold pumps to assurepump operation in the event of a loss of offsite power (LOOP)event. Level switches and control room alarms are used to monitor the CS pump dischargepiping and alert the operatorof piping notfull condition. Modification JD-03-005 (ER-02-0031) replaced previously used strap-on ultrasoniclevel detectors mounted external to piping and used to monitor high points in the RHR and core spray systems for waterfilled condition with thermal dispersion level detectors which place the sensor in the monitoredfluid to ensure high points in the piping arefilled with water.

Source: Design Basis Document (DBD)-O14, "DesignBasis Documentfor the Core Spray System ".

HPCISystem The HPCIsystem at JAF's has no keep full system. A keep full system is not requiredsince the CST level is maintained above the elevation of the discharge check valves.

System designs that include voided pipes (e.g. drywellspray piping inside containment).

RHR System A mode of operationfor the RHR system is Drywell Spray during a LOCA. This flow path is through a normally closed out-boardisolation valve into an open spray header. The Drywell Spray nozzles and inboardpiping are voided by design, as the lines are open ended in the vessel.

Core Spray System The Core Spray spargerand incorepiping is voided by design, as the lines are open ended in the vessel.

HPCISystem The HPCISystem at JAF has no voidedpipe by design. This system does not have a keep-full system due to the fact that HPCIis normally lined up to take suctionfrom the CST and the CST level is above the HPCIdischargecheck valves. This configuration ensures the piping isfull of water.

System realignments during Design Basis actuations and how the system remains full.

ForRHR and CS, experience at similarplants has shown a tendencyfor leakage to develop through the pump discharge check valves. A Keep Fullpump is provided

Engineering Report JAF-RPT-08-00015 Revision 0

--- V Page 16 of 70 for each RHR and CS loop. The Keep Fullpumps will re-circulatetorus water aroundthe dischargecheck valves should any leakage occur.. The Keep Fullpump is not essential to maintainingthe linefull of water, but eliminates theflow of condensate storage tank water to the torus. (UFSAR Section 64.5)

The HPCIsystem requiresno fill-line arrangement,since the requiredvalves are normally open, and the piping is located below the reserve water level of the CSTs.

(UFSAR Section 6.4.5)

HPCIalso has a second source of water, an automatic transferto the Torus suppressionpool occurs when the CSTs reach low level. (UFSAR Section 16.6.1)

The suction piping is located below the reserve water level of the condensate storagetank and the minimum water level of the suppressionpool.

The potential for gas intrusion due to debris laden suction strainer geometry.

NRC Bulletin 96-03 imposed requirements on BWR licensees to address the impact of debris generation in the drywell on ECCSpump NPSHfollowing a.design basis LOCA. The Bulletin cited industry experience and NRC study data in its conclusion that there was a high probabilitythat the availableNPSH marginfor the ECCS pumps would be inadequatefollowing dislodgingof insulation and other debris caused by a LOCA and transportof the debris to the suppressionpool suction strainers.

In response to the issues raised in the NRC Bulletin, modification F1-97-031 was implemnented in 1998, during Refueling Outage 13, to install larger,high capacity suppressionpool suction strainersfor both Core Spray loops. The new strainers were designed to ensure adequate NPSH would be availableto the pumps assuming the maximum quantity of debris that could be generatedand transportedto the suppressionpool as a result of a design basis LOCA and the peakpool temperature postulatedfor the accident.

In additions to ensuring adequate NPSH to the ECCS pumps, installationof the larger,high capacity, suppressionpool suction strainersmakes the potentialforgas intrusion associatedwith debris less likely.

Vortex correlations used to establish minimum water level set points or manual actions credited in the design basis LOCA.

HPCISystem Duke Engineering& Services CalculationNo. A384.F02-03, "RHR, CS, HPCIand RCIC Suction Strainer Vortex/Minimum Submergence ",Rev. 1 concluded that the new suction strainersrequire only partialsubmergence to prevent vortexing. The Technical Specification minimum suppressionpool water level is well above the level requiredto prevent vortex conditions. The elevations at the top of the debris

Engineering Report JAF-RPT-08-00015 Revision 0

-t- Page 17 of 70 postulated to accumulate on the strainersfollowing a design basis LOCA are below the Technical Specification minimum suppressionpool water level. (DBD-023)

CS SVstem Duke Engineering& Services CalculationNo. A384.F02-03, "RHR, CS, HPCIand RCIC Suction Strainer Vortex/Minimum Submergence", Rev. 1 concluded that the new suction strainersrequireonly partialsubmergence to prevent vortexing. The Technical Specification minimum suppressionpool water level is well above the level requiredto prevent vortex conditions. The elevations at the top of the debris postulated to accumulate on the strainersfollowing a design basis LOCA are below the Technical Specification minimum suppressionpool water level. (DBD-014)

RHR System' Duke Engineering& Services CalculationNo. A384.F02-03, "RHR, CS, HPCIand RCIC Suction Strainer Vortex/Minimum Submergence ", Rev. 1 concluded that the new suction strainersrequire only partialsubmergence to prevent vortexing. The Technical Specification minimum suppressionpool water level is well above the level requiredto prevent vortex conditions. The elevations at the top of the debris postulated to accumulate on the strainersfollowing a design basis LOCA are below the Technical Specification minimum suppressionpool water level. (DBD-010)

Allowable leakage between high pressure and low pressure interfaces.

The allowable high to low pressure leakage is bounded by the Containment Isolation Valve Local Leak Rate Testing Program.

CS and RHR are both equipped with alarmingpressure instrumentationto alert the operatingstaff to a potential high to low pressure interface leakage path. The alarms are set at 450 psigfor the systems and are provided by pressureswitches I OPS-122A, I OPS-122B, 14PS-47A and 14PS-47B should the respective system discharge containment isolation valves exhibit back-leakage. Station Annunciator Response Procedures(ARPs) 09-4-3-23, 09-3-1-11 and 09-3-2-11 provide the operatingstaff with the proceduralmitigation actions.

HPCIby design is not provided with similar instrumentationas discussed abovefor CS and RHR since HPCIpiping downstream of the pump is designedfor high pressure. The HPCIdischarge is isolatedfrom the high pressure source by two normally closed check valves and one normally closed motor operatedvalve (23MOV-19). Triple valve isolation mitigates the likelihood of a high to low pressure interface condition and therefore alarmingpressure instrumentation is not required.

0 Existing documents which evaluate void size acceptability.

Engineering Report JAF-RPT-08-00015 Revision 0

- terg Page 18 of 70 ECCS Suction Voiding:

Based on evaluation of the gas intrusion data that was reviewed by the B WROG and GEH applicable to the performance of centrifugalpumps, a bounding 2% by volume continuous suction gas void fraction is acceptable. It could cause increasedwear of the pump, but will not cause pump operabilityproblems. Although, test data is availableforfractions up to 4% having minimal effects on pump performance, other test data shows performance degradation(although minor) under certain conditions, such as low flow andflow beyond the Best Efficiency Point (BEP),

beginningat about 2%. Due to the large number of variablesandpump types that can affect pump performance while ingestinggas, a bounding 2% voidfraction is consideredappropriateand conservativefor continuous pump operation. However, due to the lack of test data or operatingexperience ofpump operation above 120%

of the BEP, it is recommended thatpumps which operate above this point be limited to a 1% allowable continuous voidfraction. System operability would still need to be assessedfor either limit above, including such factors as requiredNPSH versus availableNPSH, duration ofgasflow, and transientsfor which the system is credited.

Gas accumulation in the suction lines ofBWR ECCS systems is not expected to occur. If a gas void isfound in a suction line it will be a fixed volume and will not cause a continuous gas void flowing through the pump. As such it is overly conservative to apply the above void criteriato these types of voids. To evaluate pump and system effects of a void of a known volume, it is appropriateto use the guidance that an average voidfraction less than 10% can be toleratedby the pump and system for a period of no greater than 5 seconds.

To evaluatepump and system effects of a void of a fixed known volume, it is appropriateto use the guidance developed by GEH and the B WROG, that an average voidfraction less than 20% can be toleratedby the pump for a period of 5 seconds. However, since this criterion is qualitativein nature, a more conservative guidelineof an average 10% voidfractionfor no greaterthan 5 seconds is recommendedfor use. This assumes that the void is not initially located in the pump during a pump start. Proposingan acceptance criterionof 10% voidfraction over no greaterthan 5 seconds to evaluatepump and system operabilityacknowledges the qualitativenature by which the limit was developed. Additionally, this limit more closely aligns with similar limits that Westinghouse is developing. Also, bubble surges during transportwill result in a varying void fraction that will likely peak over 10%, but should average less than 10%. The actual gas volume this constitutes will depend on pump suction line diameter,flow rate,andpressure.

Although no specific test data was located which empirically validates this guidance, it is consideredbounding'andappropriatefor the following reasons:

Engineering Report JAF-RPT-08-00015 En tery Revision 0 Page 19 of 70 o At thepump BEP or ratedspeed, a gas voidpresent in a suction line would be swept through the pump due to system flow inertiaas bubblyflow in a short amount of time (seconds).

o The flow of entrainedgas through the pump would occurfor a short duration (seconds), during which, a small reduction inflow may occur, but will not compromise system performance. As such, recalculationofpump NPSHr should not be required.

o As noted above, a-small reduction inflow may occurfor several seconds.

o Although it difficult to quantify the short duration reduction inflow, it is more than offset by conservative accident analysis assumptions, such as not creditingECCSflow until the time the injection valve is assumedfull open.

In reality,,significantflow occurs early in the opening stroke, beforeflow is actually credited.

o Ifgas was present in an ECCS pump suction line, ingestion by the pump would be expected to occur early in an event when NPSHa is higher, rather than later in an event.

o A pump vendor's review of an event with a similaramount of voiding, averaging 15% voidfraction over 5 seconds, indicatedthat the pump will continue to operate,and the pump will return to its pre-transientflow as the voiding clears.

o BWROG/GEH Test documentationfound that after air injection was increasedto the point thatflow collapsed or totally ceased, air injection was switched off and the head andflow normalized in afew seconds back to the originalvalues, with one exception. With the smallestflow rate (200gpm or approximately 20% of ratedflow), it took about30 secondsfor the pump head to normalize.

o Due to the short duration of time (generallyminutes) thatpumps are expected to run on minimum flow, accumulation of sufficient gas to cause pump binding is not expected. Additionally,flow velocities on minimum flow are not high enough topush minor voiding into the pump suction. As such, time restrictionsfor minimum flow operation are not recommended.

o The criteria chosen assumes all of the void volume in the suction line is transportedthrough the pump. Depending on the suctionflow rate, a lower percent of this volume will be transportedthrough the pump (lowerflow yields a.lower Froudenumber).

This guidance is generic and conservative. It is intendedfor evaluatingshort term system operabilitydue to a voidfound in the ECCS suction piping and not for long term design basis. A plant specific evaluation of any voiding discovered in the suction piping is not precluded and may provide a largeracceptable voidfraction.

If voiding near, or exceeding, the acceptance limit establishedin this report is

Engineering Report JAF-RPT-08-00015 Revision 0 E

egPage 20 of 70 identified in an ECCS suction line, it is recommended that the pump vendor also be consulted to ensure that the pump is not an outlier relative to any of the generic assumptions made.

ABS Calculation 1924850-C-002, Revision 1, Titled "Generic Letter GL2008-0:

Evaluation ofAcceptable Void Sizes in ECCS,Decay Heat Removal, and Containment Spray Systems " determined acceptable void sizes that.could potentially be found in pump suctionpiping in the ECCS and determined the maximum pressure andpipe segment pressurizationrate that could resultfrom void compressionfollowing pump start. These systems included RHR, HPCIand CS.

The maximum acceptable gas accumulationfor the sum Qf the suction and discharge piping is limited. Based on guidanceprovided the BWROG by GE/Hitachi,an evaluation based on the delay in ECCSfunction of up to 4 seconds demonstrated that peak cladding temperature was maintainedwithin 50°Fof analyzed conditions and therefore is within the plant's licensing basis.

The maximum void that can be pumped into the vessel is the sum of the acceptable suction void and dischargevoid. Therefore, the upper limit on dischargeside voids is the difference between the vessel acceptable void and the suction acceptable void.

In this evaluation, 87.5% of the pumpflow over 4 seconds was used. The 87.5%

value is based on the considerationthat the suction side can be voided 10% for 5 seconds, which is equivalent to 12.5% over 4 seconds.

This volume is also adjustedfor voids that occur in piping downstream of the closed isolation valve on the path to the reactor. This is required if the void is exposed to reactorpressure during operation and a lower pressure under ECCS injection.

Under accident conditions, the vessel pressurewould drop and the void would expand and could occupy more volume. To adjustfor measurements made during operation, the void volume is lowered by the ratio of the pump head to the reactor pressure.

ABS ConsultingReport 1924850-R-001 Revision I Table 4-1: Acceptable Suction Side Voids Numbers shown (X), refer to notes following table.

Pump Volume (ft3) (1) Volume OT3) (2)

HPCI 4.2 4.7 RCIC 0.42 0.46 RHR 7.7 9.1 CS 4.7 5.6 Notes:

Engineering Report JAF-RPT-08-00015 Revision 0 Entegy Page 21 of 70

1. Based on 10%flow for 5 seconds or 5% flow for 20 seconds.

2. For void at elevation> 10 feet above pump.

ECCS DischargePipinz:

A significantflow transient can result when a water mass is acceleratedinto a non-condensablegas volume as the result of a pump start or the opening of a valve.

This accelerationis due to a pressure difference acting on the available water mass with the subsequent motion compressingthe gas volume thereby increasingthe pressure. Eventually, the gas volume pressure exceeds the pump shutoff head pressureor the stagnationpressure of the water upstream of the valve and the water begins to decelerate. If this decelerationprocess occursfaster than the resulting compressionpressure waves caused by the continued compression of the gas volume, the hydrodynamicprocess is essentiallygoverned by the acoustic transmission of these pressure waves through the water in the piping.

Consequently, this evolves into a gas-water water hammer event'and the accompanyingforce imbalances on the piping segments can be sufficient to challenge the piping supports and restraints.

The B WROG and GEH work demonstratesthat any voids for the sections ofpiping downstream of the first normally closed motor operatedisolationvalve will not create a water hammer that could challenge the operability of those systems when requiredto mitigate any postulated events. A portion ofpiping that discharges into the vessel, or lines directly connected to the vessel, will void (due to flashing) during vessel de-pressurizationand are designed accordingly. Any pressure transients occurring due to voids are accountedfor in the originalpipingdesign margin.

Piping design philosophy is to design piping to preclude severe water hammer events. Partof this philosophy is to include hardpipe vents on piping sections where voidformation is detrimental. Forthe piping downstream of the normally closed isolation valve, vents may be installed between the isolation and downstream check valve. These vents can be used to ensure that the piping is vented after a drain down or maintenance in a plant outage but usage at power needs to be carefully evaluated. Generally, the water in this section ofpiping can be above the saturationtemperatureat atmosphericpressure, so venting with the system above 212 YF will void the pipe. It will not vent non-condensables.

Given the above, the concerns of GL 2008-01 are addressedfor the LPCI,HPCI and CS systems. ContainmentSpray systems are designed to be voided in standby.

No further actions in verifying the piping's actual configuration are necessary to address GL 2008-01 for the dischargepiping downstream of the isolation valve.

Engineering Report JAF-RPT-08-00015 Revision 0 Enter y Page 22 of 70 ABS ConsultingReport 1924850-R-001 Revision 1 Table 4-2 Acceptable DischargeSide Voids for Vessel Injection Numbers shown (A) refer to notesfollowing table.

Max Void Max Void Discharge Void (Pump Side) ft (1) (Vessel Side) ft3 (2)

HPCI 36.4 36.4 RCIC, 3.5 3.5 RHR 132.1 34.8 CS 40.7 13.8 Notes.

1. Pump side =from pump to first isolation valve.

2. Vessel side =fromfirst isolation valve to vessel.

How the GDCs or plant specific principle design criteria listed in GL are met or applied to the station.

DRAFT AEC Criterion38- Reliability and Testability of EngineeredSafety Features All engineeredsafety features shall be designed to provide high functional reliabilityand ready testability. In determining the suitability ofa facilityfor a proposed site, the degree of reliance upon and acceptanceof the inherent and engineeredsafety afforded by the systems, including engineeredsafety features, will be influenced by the known and the demonstratedperformance capability and.

reliabilityof the systems, and by the extent to which the operabilityof such systems can be tested and inspected where appropriateduringthe life of the plant.

UFSAR 16.6.2.4 Group IV- Fluidsystems (Criteria30-46)

Interpretationand Conclusion.

The criteria of Group IV are intended to:

(1) Identify those nuclear safety systems within the general category offluid systems; (2) Examine each one for capability, redundancy, testability,and inspect ability; and (3) Assure that each safety feature's capability-scopeencompasses all the anticipatedand crediblephenomena associatedwith the operational transients or design basis accidents.

def Engineering Report JAF-RPT-08-00015 Revision 0 En-- Page 23 of 70 In addition, the criteria in Group IV are intended to establish the design requirementsfor the Reactor CoolantPressureBoundary (RCPB) and to identify the means for satisfying these design requirements. It was concluded that the JAF NuclearPower Plant conformed with the intent of the AEC General Design Criteria for Nuclear Power Plantsto the maximum extent possible consistent with the state of design and construction at the time of issuance of these criteria.

Furtherthis section of the UFSAR states:

The plant is provided with a Residual Heat Removal System to transferfission products and other residual heatfrom the reactor core at a rate such that specified acceptablefuel design limits and the design conditions of the RCPB are not exceeded (Criterion34). The Emergency Core Cooling Systems (ECCS) are designed to prevent excessive fuel cladding temperatures over the entire spectrum of postulateddesign basis Reactor Coolant System (RCS) breaks. Such capability is available concurrentwith loss of all off-site power. The ECCS themselves are designed to yarious levels of component redundancy to prevent a single active componentfailure, in addition to the accident,from negating the requiredcore cooling capability (Criterion35). To assurethat the ECCSfunctions properly, specific provisions are made for testing the sequential operabilityandfunctional performance of each individualsystem (Criterion 37). Design provisions have also been made to enable physical and visual inspection of the ECCS components to the degreepracticable(Criterion 36). Provisions are made for the removal of heat from within the primary containmentfor as long as is necessary to maintain the integrity of the containmentfollowing the variouspostulated design basis accidents (Criterion 38). The capability to test the functionalperformance and to inspect the containment heat removal system is provided.

Mission times for system pumps.

The IPE mission times for the Core Spray, RHR and HPCIpumps is determined to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. These values are described in Appendix L, "Success Criteria"from reportJAFRPT-MULT-02107, "JamesA. FitzPatrickNuclear Power Station IPE Update,"Rev. 2. The considerationsthat have dominated the choice of the mission time are as follows:

• After approximately] hour, the Technical Support Center (TSC) and Emergency Offsite Facility (EOF)would be manned and additionalexpertise and support could be available by phone or transportedto thesefacilities.

" Fortimes greaterthan 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, it is consideredhighly likely that offsite resources (i.e., equipment, power, vehicles, etc) would be availablefor recovery actions.

• From a risk perspective, actual datafrom naturaland man-caused disasters have indicatedthatpublic evacuationscan be effectively carriedout in time frames of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

A , Engineering Report JAF-RPT-08-00015 Revision 0 Page 24 of 70 Based on the above considerations,it has been considered in past IPEs (including NUREG-1150) appropriateto use equipment mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if conditions at that time arestable.

This considerationdictates the use of equipment "run"failure rates (perhour) coupled with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mission time to calculate the "run"failureprobabilityof equipment. This calculated "run"failureprobabilityis then sometimes treated conservatively by assuming thisfailure occurs at time zero.

Fuel evaluation for acceptable air voids sent to the core during injection.

The B WR Owners Group draft document on the "PotentialEffects of Gas Accumulation on ECCS Analysis as Partof GL 2008-0] Resolution " has provided information that supports that there are no adverse effects of an air void being injected into the reactor. In summary, three main factors would determine why air bubbles (i.e., gas voids) passingthrough a BWR core do not pose an additional safety concern: (1) unlikely pathfor air to get into the core, (2) high void conditions alreadypresent in the core during a LOCA, and (3) air that does enter the core does not accumulate there, but passes through into the upperplenum and upper parts of.

the vessel.

From the survey of the BWROG and GEH, the most limiting heatup rate is determined as 12 WF/s. For small amount of delay in actuation of the most effective ECCS component, the anticipatedPeak Cladding Temperature (PCT)impact on plant LOCA analyses is provided below:

LOCA PCTImpactfor HypotheticalECCS DelayAmounts.

Delay in ECCS PCTImpact 1 Seconds 12 OF 2 Seconds 24 OF 3 Seconds 36 OF 4 Seconds 48 OF

>4 Seconds Must Be Analyzed The delays indicatedare assumed to be the delay in actuation of the ECCS component most effective in mitigating LOCA. Forexample, for a large-breakLOCA, this would be LPCI or CS,for a small-breakLOCA, this would be HPCI. Automatic DepressurizationSystem (ADS) is not considered to be impacted by the gas intrusion issue. If the delay in multiple components is to be assumed, the combined effect would be less severe than simple addition of the impact given in the identified delay times.

From the initial injection rates of low-pressuresystems, a four-second delay would be

Engineering Report JAF-RPT-08-00015 Revision 0 SEnteg Page 25 of 70 equivalent of approximately 25ft3 of coolant displaced by gas intrusion in the ECCS line.

Any change greater than 50YF in plant's licensing basis PCT is considereda significant change and requiresfurther action in accordancewith] OCFR5O.46 (a)(3). Therefore, a delay in ECCS greaterthan 4 seconds cannot be supported by the B WROG/GEH evaluation.

A survey ofBWR LOCA analyses was conducted and a limiting LOCA PCT heatup rate of 12 0F/s is determinedfor the entire U.S. BWR fleet. Using this heatup rate, 48 YF of PCT impact is assessed with a maximum of 4-second delay in the ECCS actuation. The validity of this assessment is confirmed using representativecalculations with high heatup rate cases and cases with high PCT. This evaluation is provided as a conservative "worst case" scenario; the majority of the units would benefitfrom plant-specific evaluations or analyses.

An assessment on the potentialimpact of gas voids passingthrough the core was performed by the B WROG and GEH. This assessmentjustified that gas voids passing through the core do not cause an additionalsafety concern mainly because of the unlikely pathfor air to get into the core and high void conditions in the corepresent duringLOCA. Assessments on the Loss of Feedwater (LOFW)and Anticipated Trip Without a Reactor SCRAM (ATWS) events concluded that a delay of 5 seconds in ECCS flow would affect the analysis results insignificantlyand have no impact on meeting the acceptancecriteria. The evaluation of station blackout events indicates that a delay of 10 seconds would not impact the ability of the water makeup system to maintain the vessel water level above the top of active fuel. Similarly, it is concluded that a delay of 10 seconds would have an insignificantimpact on meeting the acceptance criteriain Appendix Rfire safe shutdown analysis.

Currently the JAF Core Reload Analysis shows the ECCS response times for injection is analyzed to be 36 secondsfor CS, 62 secondsfor LPCI and 60 secondsfor HPCI.

(GEH-EPIWXIWZ-015, "ECCS-LOCA EVAL " and EC 8182 "ECCS LOCA Analysis SAFER/GESTR (T0407) Evaluation). Creditfor injection time is taken from the time the injection valve is full open.

5.1.1 Review the design control program and ensure that the design change review checklists have an explicit line item to determine if the design change introduces or increases the potential for gas accumulation beyond established acceptance criteria.

EN-DC-115, 117, 136 and 141 all were found to not address the above review attribute. It is recommended to consider the proceduresfor improvement pursuantto the Entergy review Criteriato promulgate the requirements pursuant to GL 2008-01.

Engineering Report JAF-RPT-08-00015 EnterW Revision 0 Page 26 of 70 EN DC-115, "EngineeringChangeDevelopment"

• Attachment 9.3, "Impact Screening Summary" does not contain an explicit line item to determine if the design change introduces or increases the potentialfor gas accumulationbeyond establishedacceptance criteria.

EN-DC-1] 7, "PostModification Testing and Special Instructions"

• Attachment 9.1, "MechanicalComponent Test Guide", does not contain an explicit line item to define the testing methodologies of a design change to ensure that it does not introduce or increase the potentialfor gas accumulation beyond establishedacceptance criteria Attachment 9.4, "PostModification Test Plan Form ", does not contain an explicit line item to determine if the design change introduces or increases the potentialforgas accumulation beyond establishedacceptance criteria.

o The PMTP identifies the testing required(Construction,Functional, EC Assumptions, Operations,Post Return to Service). The PMTP documents all tests or series of tests that will be performed to comply with any code requirementsfor construction testing as well as those that will be performed to demonstratecomponent and system functionality after completion of the modification. This will include, any existing surveillance tests, maintenance tests, or ECTs developed specificallyfor the modification.

EN-DC-136, "Temporary Modifications"

• The procedure content does not contain an explicit line item to determine if the design change introduces or increases the potentialfor gas accumulation beyond establishedacceptancecriteria.

EN-DC-141, "DesignInputs"

• Attachment 9.3, "Impact Screening Summary does requirethe Engineer to considervent paths under Mechanical Considerations,step 43j. However, this line item does not explicitly pertain to determining if the design change introducesor increases the potentialfor gas accumulationbeyond established acceptance criteria. It is suggested to prescribe input activities such as consideringproposed isometric configuration or equipment to assure that vents are located at high points or that inverted loops are ventable.

5.1.2 Enter changes that were identified as part of the design basis review in the CAP.

EN-DC-115, 117, 136 and 141 all were found to not addressthe above review attribute. It is recommended to consider the proceduresfor improvement

Engineering Report JAF-RPT-08-00015 Revision 0 Page 27 of 70 pursuantto the Entergy review Criteriato promulgate the requirements pursuantto GL 2008-01. (CR HQN-2008-00880, CA-I & CA-2)

K 0 ENDC-115, "EngineeringChange Development" Attachment 9.3, "'ImpactScreening Summary" does not contain an explicit line item to determine if the design change introduces or increasesthe potentialfor gas accumulation beyond established acceptance criteria.

0 EN-DC-11 7, "PostModification Testing and Special Instructions" Attachment 9.1, "Mechanical Component Test Guide ", does not contain an explicit line item to define the testing methodologies of a design change to ensure that it does not introduce or increase the potentialfor gas accumulation beyond establishedacceptance criteria.

Attachment 9.4, "PostModification Test Plan Form ", does not contain an explicit line item to determine if the design change introduces or increases the potentialfor gas accumulation beyond established acceptance criteria.

The PMTP identifies the testing required(Construction,Functional,EC Assumptions, Operations,Post Return to Service). The PMTP documents all tests or series of tests that will be performed to comply with any code requirementsfor construction testing as well as those that will be performed to demonstratecomponent and system functionality after completion of the modification. This will include any existing surveillance tests, maintenance tests or ECTs developed specificallyfor the modification.

" EN-DC-136, "Temporary Modifications" The procedure content does not contain an explicit line item to determine if the design change introduces or increases the potentialfor gas accumulation beyond establishedacceptancecriteria.

" EN-DC-141, "DesignInputs" Attachment 9.3, "Impact Screening Summary ", does requirethe Engineer to consider vent paths under Mechanical Considerations,step 43j. However, this line item does not explicitlypertain to determiningif the design change introducesor increases the potentialfor gas accumulation beyond establishedacceptance criteria. It is suggestedto prescribe input activities'such as consideringproposedisometric configuration or equipment to assure that vents are located at high points or that,inverted loops are ventable.

Engineering Report JAF-RPT-08-00015 Revision 0

7 Enfte

W Page 28 of 70 5.1.3 Summarize and document the results of this design basis document review.

Based on the information reviewed including the work by the B WROG, GEH, and ABS, JAF adequately meets the design basis as well as the intent of the AEC General Design Criteriafor Nuclear PowerPlants to the maximum extent possible consistent with the state of design and construction at the time of issuance.of these criteria. Furtherthe plant testing and operation has demonstratedcompliance with the design requirements in that there have been no documented evidence of inoperdblesafety systems due to gas accumulation issues.

Based on the reviews performed to respond to GL 2008-01 JAF has identified areas of improvements to processes to ensurefurther,compliance with the requirements by identifyingproceduralandprogram revisions to identify.

potential voiding issues in ECCS and otherfluid systems.

5.1.4 The Design Basis review activities were complete by October 11, 2008.

All. design basis review activities have been completed.

.5.1.5 Determine if any corrective actions will be completed after October 11, 2008 and identify as licensee commitments that will not be completed within the 9-month GL response date.

Entergy is evaluating the enhancement to the engineeringprocesses and procedures as outlined in Section 5.1.2 to ensure thatfuture modifications are adequatelydeveloped to ensure gas accumulation in fluid systems is evaluated.

(CR HQN-2008-00880, CA-i & CA-2, Due 07/30/09) 5.2 DRAWING REVIEW 5.2.1 Review the system P&IDs and isometrics drawings.

Note: SER 2-05, Rev. 1 recommends that simple one-line isometrics be developed for each system to aid the personnel performing the drawingreviews and subsequent venting/verification activities on the systems.

Document the review of the drawings and identify all system vents and high points. System high points include all areas where gas can accumulate in the system, including isolated branch lines, valvebodies, heat exchangers, improperly sloped piping, or located upstream of components in horizontal lines.:

See Section 5.3 for walkdown activities related tothe drawing reviews.

The walkdown drawingsfor RHR, CS, and HPCJare included in an attachment to ABS Report 1924850-R-001, Revision 1, to aidpersonnelperforming the reviews. The grade elevation drawings were developed using the supportstress

Engineering Report JAF-RPT-08-00015 Revision 0 Entery Page 29 of 70 isometrics, P&IDs and walkdown data. They show the component andpipe elevation relative to the system flow path, reactor, CST and Torus.

5.2.2 Summarize new vent valve locations identified as a result of the drawing review.

No new vent valve locations were identified as a result of the drawing review.

5.2.3 Enter the changes that are identified as part of the drawing review in the CAP.

No changes were identified as a result of the drawing review.

5.2.4 Drawing reviews will be completed by October 11, 2008.

All drawing reviews have been completed.

5.3 SYSTEM WALKDOWNS 5.3.1 The scope should include:

• Verification that vents are in the proper location along horizontal (nominal) runs of pipe.

Based on a review of ABS Report 1924850-R-001, Revision 1 and the ABS generatedisometrics, there are eleven locations identified where no vent is availableand the potentialforvoid formation exist. These eleven locations are indentified in Table 4-4 of the report. UT examinations of the eleven potentially void locations were performedand all locations were found to befull of water with no evidence of air voiding. Based on the UT results, no additionalvents are needed at these locations.

" Verification that vents are in the proper location along circumference of the pipe.

Based on a review of ABS Report 1924850-R-001, Revision 1 and the ABS generatedisometrics, all vents were found to be locatedproperly along the circumference of the pipe.

0 Verification that piping is sloped in the proper direction.

The subject system piping was either verified to have proper slope, or UT inspections were performed on suspect pipe sections. UT examinationsare complete and the pipe sections were found to be full of water. Based on the UT results, the slope of the subjectpipingis determined to be acceptable.

• Verification that horizontal (nominal) runs of pipe do not contain local highpoints.

Engineering Report JAF-RPT-08-0001 5 RevisionO0

.nteW Page 30 of 70 UT examinations were performed on pipe sections shown to have a local highpoint. No evidence of air voiding was found, as the pipe sections werefound full of water. Based on these results, the horizontalpipe runs do not contain local highpoints that would contributeto air accumulation in these locations.

Walkdowns should be performed on portions of the systems that would require venting to ensure the systems are sufficiently full of water.

Walkdowns are not required on portions of the systems that do not require venting to ensure the systems are sufficiently full of water. For example, the containment spray system piping from the containment spray isolation valves to the spray headers is not designed to ensure that the system is sufficiently full of water for some plants. Therefore, these sections of the system do not need to be walked down.

Walkdowns to measurepipe slope of ECCS piping both outside and inside containment has been completed.

The following is a briefsummary of the pipe slope resultsfrom ABS Report 1924850-R-001, Revision 1, Attachment B.

HPCI Sum segment length ofpiping - 357.4 'Max total slope w/ error-2.35'") 47 records.

CS "A" Sum segment length ofpiping - 93.7'/Max total slope w/ error- (1.60")

17 records.

CS "B" Sum segment length ofpiping - 223.6 '/Max total slope w/error -

(2.13") 32 records.

RHR "A" Sum segment length ofpiping- 270.6" Max total slope w/ error-(3.40 ") 36 records.

RHR "B" Sum segment length ofpiping -250.87 Max total slope w/ error-(2.11 ") 37 records.

• Analytical based assessments may result in refining the scope. and level of detail of the walkdown (e.g., an analytical assessment may be used to demonstrate that worst case gas accumulation volumes are acceptable in the pump discharge piping).

Engineering Report JAF-RPT-08-00015 Revision 0 Page 31 of 70 A walkdown ofpiping, both non-insulatedand insulated,inside and outside of containment, has been completed with the exceptions listed in section 5.3.2.1. Based on the evaluationsdocumented in ABS Report 1924850-R-001, Revision 1 no additionalwalkdowns and void testing was determined to be necessary of the piping that was not walked down.

5.3.2 Perform system walkdowns for all un-insulated piping located outside containment that does not require scaffolding to access it, and is not located in high radiation areas. These walkdowns will be completed by October 11, 2008.

5.3.2.1 A walkdown of piping which is located outside of containment and not in a high radiation area but is insulated will be performed by October 11, 2008 to gather information which can be reliably obtained without removing the insulation (e.g., high point vent location or correct piping slope).

A walkdown ofpiping, both non-insulatedand insulated,inside and outside of containment, has been completed with the exception of the inaccessiblepipe identified below:

• HPCIsuction pipingfrom CST Pit to Reactor Building Wall - Buried

• RCIC suction pipingfrom CST Pit to Reactor Building Wall - Buried

• CS suction pipingfrom CSTPit to ReactorBuilding Wall - Buried

" CS suction pipingfrom CST in East Crescent- inaccessiblewithout scaffolding

" Portionof RHR Train B ContainmentSpray line overheadat 300' RXBLD NE - inaccessiblewithout scaffolding

" Portionof RHR Trains A to LPCI in West Crescent - inaccessible without scaffolding

• Portionof RHR Trains B to LPCI in East Crescent - inaccessible without scaffolding A tabletop review was conducted with Engineering,Operations,PS&O, Maintenance, and RP which reviewed system isometric drawingsfor the inaccessiblepiping areas. It was determined through drawingreviews during the tabletop mulit-departmentalreviews that the above locations did not cite any areasgas intrusion may be of concern. Also, due to the satisfactory results of the piping that was accessedfor the walkdown and the history offew air voiding events at JAF, included with the table top reviews, it is not necessary to perform walkdowns of the inaccessible sections of this piping. The aforementioned review conclusion performed by JAF was corroboratedby the ABS evaluation which did not require additionalwalkdowns and void testing of the piping that was not walked down.

Engineering Report JAF-RPT-08-00015-Revision 0 Page 32 of 70 5.3.3 Portions of systems that are in containment, in high radiation areas, insulated, or require scaffolding to access it may require a refueling outage for proper access and sufficient planning time in advance of the refueling outage and thus may not be walked down by October 11, 2008. Document the walkdown schedules (e.g.,

refueling outage) and the basis (e.g., in containment, in high radiation areas, insulated, or require scaffolding to access it) for these portions of the systems.

A walkdown ofpiping inside containment, both insulatedand non-insulated,was completed during R018 in September, 2008.

5.3.4 Develop a prioritized walkdown list of piping sections based on the configuration, pressure change potential, and source analysis (vulnerability to gas intrusion, see Section 5.4.2). In general, suction piping is more critical than discharge piping.

A prioritizedwalkdown list ofpiping sections was developed based on the Core Damage Frequency number assigned by the site specific PRA. All walkdowns have been completed perprojectplan documented in LO-LAR-2008-00020. No further walkdowns are scheduled.

5.3.5 Document the results of the walkdown, including any deficiencies and concerns.

The piping sections and the applicable drawing numbers should be included in the review documentation. Descriptions should include the scope of the walkdowns and any basis for excluding portions of the system from detailed walkdowns.

All aspects of the walkdown activities are documented in ABS Report 1924850-R-001, Revision 1. A walkdown ofpiping outside and inside containment, both insulatedand non-insulated,was completed priorto or during R018, with the exception of the inaccessiblepipe located outside containment:

0 HPCIsuctionpipingfrom CST Pit to ReactorBuilding Wall - Buried

• RCIC suction pipingfrom CSTPit to ReactorBuilding Wall - Buried 0 CS suctionpipingfrom CST Pit to Reactor Building Wall - Buried

• CS suctionpipingfrom CST in East Crescent - inaccessible without scaffolding

• Portion of RHR Train B Containment Spray line overhead at 300' RX BLD NE - inaccessible without scaffolding

• Portion of RHR Trains A to LPCI in West Crescent - inaccessible without scaffolding

• Portionof RHR Trains B to LPCI in East Crescent- inaccessible without scaffolding

Engineering Report JAF-RPT-08-00015 Revision 0 Page 33 of 70 Due to the satisfactory results of the piping that was accessedfor the walkdown and the history offew air voiding events at JAF, it is not necessary to perform walkdowns of the inaccessiblesections of this piping. In addition, collegial "

reviews of systems piping diagrams did not cite areas where gas intrusion may be of concern in the piping that was not walked down. The aforementioned review conclusion was corroboratedby the ABS evaluation which did not requireadditionalwalkdowns and void testing of the piping that was not walked down.

5.3.5.1 Identify any discrepancies between as-built field conditions and the drawings relevant to gas accumulation issues (e.g. vent not installed, pipe slope not as identified, etc.).

Based on a review ofABS Report 1924850-R-001, Revision 1, all vent valves were found to be installedas shown on the drawings.

5.3.5.2 Verify vent locations, including the location on the pipe (circumferentially, as well as the location along the length of pipe).

Based on a review of ABS Report 1924850-R-001, Revision 1 and the ABSgenerated isometrics, all vents were found to be locatedproperly along the length of the piping sections and aroundthe circumference of the pipe.

5.3.5.3 Identify additional high points (all areas vulnerable to gas accumulation).

The GL includes the following areas for consideration:

0 High points in pipe runs, including elevation variation in nominally horizontal pipes (e.g. improperly sloped piping).

ABS Report 1924850-R-001, Revision 1, Table 4.4 identified 15 areas ofpotentialconcernfor gas voiding. These 15 locations were subsequently UT inspected. No potential concerns were identified.

0 High points created by closed valves in vertical piping runs.

Valves lOMOV-27 A & B were identified by ABS (see ABS Report 1924850-R-001, Revision 1). These valves are listed in Table 4.5 of this report as ID numbers 8 and 9. UT examinations demonstrated that these areaswere full of water and are therefore no longer a potential concern.

0 DHR system heat exchanger U-tubes, or other heat exchangers The RHR heat exchangers are lower than the system high point vent valves. Entrainedair within the shell side of the RHR heat exchangers will migrate out of the heat exchanger to the high point vent valves due to elevation difference. The RHR heat exchangers

Engineering Report JAF-RPT-08-00015 Revision 0 Page 34 of 70 have vent valves to vent air voids from the shell side; however, sufficient proceduralguidance does not exist to address system /

equipment ventingfollowing maintenanceactivities and on a prescribedfrequency during normalplant operation.

OP-13D was enhanced in September 2008 to include RHR HX vents (1ORHR-451A &B) to ensure system venting to lessen the likelihood of a Shutdown Cooling System trip on pump start due to hydraulic transient. The 'A,'and 'B' heat exchangers was vented andfound full of water (no air).

Horizontal pipe diameter transitions that introduce traps at the top of the larger piping or piping upstream of components (including orifice plates, reducers, and backing rings)

This attribute was addressedand bounded by ABS evaluation (ABS Report 1924850-R-001, Revision 1, Section 3.3.9 Potential Voids at Component and Piping ConfigurationLocations).

Tees where gas contained in flowing water can pass into a stagnant pipe where it then accumulates This attributewas addressedand bounded by ABS evaluation (ABS Report 1924850-R-001, Revision 1, Section 3.3.9 Potential Voids at Component and Piping ConfigurationLocations).

" Valve bonnets This attribute was addressed and bounded by ABS evaluation (ABS Report 1924850-R-001, Revision 1, Section 3.3.9 Potential Voids at Component and Piping ConfigurationLocations).

" Pump casings This attribute was addressedand bounded by ABS evaluation (ABS Report 1924850-R-001, Revision 1, Section 3.3.9 Potential Voids at Component and Piping ConfigurationLocations).

5.3.6 If previous walkdowns will be relied upon in the GL response, ensure that they were performed in a manner sufficient to address the intent of the GL.

Document previous walkdowns or validations performed, assess their adequacy and develop a plan (scope/ schedule/ responsible groups) for future walkdowns, if needed. Document corrective actions and the schedules for future walkdowns that will be performed after October 11, 2008 (See Section 5.3.3).

Walkdowns were performedfor the GL 08-01 response; no previous walkdowns were relied upon.

Engineering Report JAF-RPT-08-O0015 Revision 0

7 .*_.-Page 35 of 70 5.3.7 Document the location of inaccessible areas (e.g. buried piping), the basis for its exclusion from the walkdowns, and the justification for acceptable system operation without walkdown data. The evaluation and justification of this piping should be completed by October 11, 2008.

A walkdown ofpiping, both non-insulatedand insulated,inside and outside of containment has been completed with the exception of the inaccessiblepipe identified below)

• HPCIsuction pipingfrom CST Pit to Reactor Building Wall - Buried 9 RCIC suction pipingfrom CST Pit'toReactor Building Wall - Buried 0 CS suctionpipingfrom CSTPit to Reactor Building Wall - Buried

• CS suctionpipingfrom CST in East Crescent - inaccessible without scaffolding 9 Portion of RHR Train B Containment Spray line overhead at 300' RX BLD NE - inaccessible without scaffolding.

• Portionof RHR Trains A to LPCIin West Crescent - inaccessible without scaffolding e Portion of RHR Trains B to LPCI in East Crescent - inaccessible without scaffolding Due to the satisfactory results of the piping that was accessedfor the walkdown and the history offew air voiding events at JAF, it is not necessary to perform walkdowns of the inaccessiblesections of this piping. In addition, collegial reviews of systems piping diagrams did not cite areas where gas intrusion may be of concern in the piping that was not walked down. The aforementioned review conclusion was corroboratedby the ABS evaluation which did not require additionalwalkdowns and void testing of the piping that was not walked down.

5.3.8 Summarize new vent valve locations identified as a result of the walkdowns.

No new (undocumented) vent valve locations Were identified as a result of the walkdowns.

5,3.9 Enter the changes that are identified as part of the system walkdowns in the CAP.

No needed changes were identified by the system walkdowns.

Engineering Report JAF-RPT-08-00015 Revision 0 E

e Page 36 of 70 5.4 SYSTEM REVIEW All reviewed procedures must be listed, the responsible department identified and the title/brief description included. Any required changes are to be described along with the reason for change or state if no changes are required. Provide a status for the change:

state if complete, or provide a tracking number and a reason why it is acceptable and why it can't be completed prior to October 11, 2008.

5.4.1 Fill and Vent 5.4.1.1 For each system (including branch lines), review the process used for filling and venting each section of piping, including all applicable procedures.

A review ofJAFproceduresforfillingand venting determined that adequateproceduralguidance is in place to ensure that the subject systems are sufficiently full with water. This determination was validated by the results of UT exams conducted during R18 which demonstratedthat the subject systems remain sufficiently full with water Proceduralchanges were identified to further enhance existingplant methods and processes. These include enhancements which ensure the filling and venting ofpiping systems where gas may accumulate.

5.4.1.1.1 Review and verify that all venting activities are controlled by an approved operating procedure. This includes a review of existing procedures to identify any required revisions, as well as identifying the need for the creation of new procedures to address venting.

A review ofprocedures was conducted. Based upon the review of these procedures,guidanceforfilling and venting was found.

The following procedures were reviewed:

• OP-13, RHR System OperatingProcedure

• OP-13E, RHR System Keep-Full OperatingProcedure

" OP-14, CS System OperatingProcedure

• OP-15, HPCISystem OperatingProcedure 0 EN-OP-102,Revision 10, Protective and Caution Tagging x EN-OP-102-O1, Revision 4, Protective and Caution TaggingForms & Checklist

, ST-3AA, Core Spray loop A Monthly Operability Test

Engineering Report JAF-RPT-08-00015 Revision 0

-- Entergy Page 37 of 70

• ST-3PA, Core Spray loop A Quarterly Operability Test

• ST-3AB, Core Spray loop B Monthly Operability Test

• ST-3PB, Core Spray loop B Quarterly Operability Test

• ST-2AN, RHR Loop A Monthly OperabilityTest

• ST-2AL, RHR Loop A QuarterlyOperability Test

• ST-2AO, RHR Loop B Monthly OperabilityTest

• ST-2AM, RHR Loop B Quarterly Operability Test 5.4.1.1.2 Verify that procedures exist to vent all locations where gas may accumulate using existing vent valves.

A review ofprocedures was conducted. Based upon the review of these procedures, guidanceforfilling and venting wasfound. There are some high point vents that are not currently usedfor venting however; procedural enhancements are being made to correct this issue. (LO-LAR-2008-00020, CA-is & CA-20) 5.4.1.1.3 Ensure venting procedures and practices utilize the effective sequencing of steps, adequate venting durations, and acceptance criteria for the completion of venting.

A review ofprocedures was conducted. Based upon the review of these procedures,guidanceforfilling and venting was found. However, the sequencingof steps, adequate venting durationsand acceptance criteria werefound to be inadequate. Proceduralenhancements will be made. (LO-LAR-2008-00020, CA-is & CA-20) 5.4.1.1.4 Ensure that venting of instrument lines, including the backfilling of level and flow transmitters, is included in system venting procedures.

A review ofprocedures was conducted. Based upon the review of these procedures,guidanceforfilling and venting of instrument lines was found. However, procedural enhancements were identified and will be made. (LO-LAR-2008-00020, CA-15 & CA-20) 5.4.1.1.5 Demonstrate the effectiveness of dynamic venting methods for all locations where dynamic venting is used (adequate flow rates/fluid velocities). Revise procedures as necessary to ensure that dynamic venting is adequately implemented.

Engineering Report JAF-RPT-08-00015 Revision 0

--- W "Page 38 of 70 JAF, currently, has no plans to utilize dynamic venting methodsfor the subject systems.

5.4.1.1.6 Discuss if vacuum fill operations are used for piping sections which are difficult to fill and vent following maintenance.

This activity will be completed by October 11, 2008.

Utilizing vacuumfilling methodology is not being considered due to 'the limited amount of air voiding evidenced in the subject systems.

5.4.1.1.7 Evaluate the use of vacuum fill operations for piping sections which are difficult to fill and vent following maintenance.

Implementation of vacuum fill may require plant modifications, changes to procedures, and personnel training.

This activity may not be completed by October 11, 2008 Not applicable based on 5.4.1.1.6 above.

5.4.1.1.8 Ensure that fill and vent procedures provide instruction to modify restoration guidance to address,changes in maintenance work scope or to reflect different boundaries from those assumed in the procedure.

ProceduresEN-OP-102 and EN-OP-102-1 were reviewed.

The procedure was reviewed. Direction to assure thatfilling and venting each.section ofpiping is requiredin the development of Tagout Restoration but was notfound. As such, compiling the restorationsection of the tagout becomes a knowledge base task reliantupon use of a previously compiled tagout template. Proceduralenhancements were identified and will be made. (LO-LAR-2008-00020, CA-15 &

CA-20) 5.4.1.1.9 Review and revise the procedures to ensure they incorporate verification techniques to validate that systems are sufficiently full of water following fill and vent; based on quantification of any remaining gas void against the established acceptance criteria.

Currentprocedures as referenced in 6.1, were revised to ensure that "any" air noticed during venting operationsgets documented per a condition report. Actual volume is not determined since air quantitiescurrently cannot be accurately measuredin an effective and cost efficient manner.

Engineering Report JAF-RPT-08-000105 Revision 0 EntcaWPage 39 of 70 While no acceptance criteriahave been established to quantify gas volume, procedure ST-4B, Revision 56, "HPCI Monthly Operability Test" does require a determination of the amount of air released during venting. The amount of air must be characterizedas either "significant"or "insignificant" based on the following definition. A significant amount of air is defined as requiringmore than ]

minute to obtain a solid stream of waterfrom hose.

JAF will continue to monitor this issue with the industry as they determine-the best means a'vailablefor performing this task. If acceptance criteriaredeveloped along with measurement means, JAF will revise the ventingprocedures at that time to incorporatethe standards.

A review ofprocedures was conducted. Based upon the review, procedures were not found to validate that the subject systems are sufficiently full of waterfollowingfillingand venting.

5.4.1.1. 10 For any high points without adequate vents, dynamic venting justification, or venting verification (including improperly sloped piping or located upstream of components in horizontal runs), initiate corrective actions to modify the system to install any required vents and utilize the new vents in process documents (e.g. venting procedures, work orders, etc.).

There are no known high point locations that do not currently contain vents. There are some high point vents that are not currently usedfor venting however; procedure enhancements will be performed to correct this issue. (LO-LAR-2008-00020, CA-15 & CA-20) 5.4.1.2 Summarize the new vent valve locations identified as a result of the system review.

Based on the system reviews performed and documented in this report, there were no locations identified that required installationof new vent valves.

5.4.1.3 All unvented gas must be quantified, trended and justified through a formal Technical Evaluation or Calculation process (consistent with Section 5.4.3).

Engineering Report JAF-RPT-08-00015 Revision 0 teW .Page 40 of 70 A technical evaluation of CS, HPCI 'andRHR unvented gas was evaluated by ABS Report 1924850-R-001, Revision 1. The results of the ABS report are detailed later in Section 5.4.3 of this report.

5.4.1.4 Review of the fill and vent activities and the identification of procedure changes and corrective actions will be completed by October 1.1, 2008.

A review of the fill and vent activities, identification ofprocedure changes, and initiation of corrective actions has been completed.

5.4.1.5 Enter the changes that are identified as part of the fill and vent activity review in the CXP.

CR-HQN-2008-00882, Generic Letter 2008-01 Issue

'Entergy review criteriafor GL 2008-01 indicates to review the process usedforfilling and venting each section of in-scope ECCSpiping, including all applicableprocedures.

EN-OP-102 and EN-OP-102-01 were found not to address the above review attribute. It is recommended to consider improving the proceduresper the Entergy review Criteriato promulgate the GL 2008-01 requirements.

EN-OP-102, "Protective and Caution Taggingz' The procedure was reviewed. Direction to assure thatfilling and venting each section ofpiping is requiredin the development of Tagout Restoration but was not found. As such, compiling the restorationsection of the tagout becomes a knowledge base task reliantupon use of a previously compiled tagout template. Without clearprocedure direction, impropersystem venting during restorationcan and has occurred. It is recommended to provide direction to the use of the system 'sfillingand venting procedure when clearingthe Tagout to assurefilling and venting each section ofpiping.

• EN-OP-102-01, "Protectiveand Caution Tazging Forms &

Checklist" The procedure was reviewed. Attachment 9.17, "Protectiveand Caution Tagging Forms & Checklists" does provide a Pre and Post-job briefing checklists for clearinga Tagout. The Pre-job briefing checklistform. contains a line item to discuss how a system will be filled and vented. The Post-job briefing checklist contains a line item asking if the system is completely filled and vented and if additional actions are required.

Engineering Report JAF-RPT-08-00015 Revision 0 Enf- Page 41 of 70 EN-OP-C12 and EN-OP-102-01 were developed to work in consort with each other. In the absence ofproviding direction (system venting procedure) to assurethatfilling and venting each section ofpiping is requiredin the development of Tagout Restoration, the Pre-job and Post-job checklistsfor Tagout Restoration are not set-up to assure adequatesystem filling and venting.

LO-LAR-2008-00020, CA-15 & CA-20, Generic Letter 2008-01 Issue Entergy review criteriafor GL 2008-01 (in-scope ECCS systems) indicated to review the process usedforfilling and venting each section ofpiping, including all applicableprocedures.

A reviewforprocesses and orprocedures was conducted. Based upon the review, processes and or procedureswere notfoundforfilling and venting each section ofpiping. The following items should be considered for improving currentproceduralguidance.:

• All system vent locations were not found to be periodicallyvented.

System venting via installed'system vents should be considered to enhance currentproceduralguidance. Considerationof venting at installedsystem vent locations could be an enhancement to the surveillance test (which would addressfrequency ofperformance).

• Proceduralguidance should be considered to be developedforfilling

/ venting systems following maintenance activities.

CR-HQN-2008-00881, GenericLetter 2008-01 Issue Entergy review criteriafor GL 2008-01 indicates to review the process usedforfilling and venting each section of in-scope ECCS piping, including all applicableprocedures.

Based upon Section 5.4 of the scope and recommendationscontained within the Entergy Templatefor addressingEngineering/ Operatingand Maintenancetype proceduresfor ensuring systems are designed, operated and maintainedin such a manner as not to introduce or increasethe potentialforgas accumulation beyond established acceptance criteria. It is recommended to consider Operational proceduraldevelopment pursuantto the Entergy review Criteriato promulgate the requirementspursuant to GL 2008-01.

5.4.2 Gas Intrusion 5.4.2.1 Identify all areas of potential gas intrusion into each system and each system segment vulnerable to subsequent gas accumulation. Assess the system against all potential areas of intrusion/accumulation identified in GL 2008-01 and listed below. The evaluation of gas intrusion

Enteg AEngineering EnMoW ~Page Revision 0 Report JAF-RPT-08-00015 42 of 70 prevention, monitoring, evaluation, and acceptance criteria (consistent with Section 5.4.3) should be included, as applicable, for each system piping segment determined to be vulnerable to gas intrusion and accumulation in any of the areas listed below.

5.4.2.1.1 Leakage from accumulators or other high-pressure sources can result in gases coming out of solution.

Accumulators are not utilized in the RHR, CS or HPCI systems.

5.4.2.1.2 Leakage from the RCS can result in the formation of steam pockets or hydrogen coming out of solution.

Any. leakage comingfrom the RHR or CS systems will not form a steam pocket or hydrogen coming out ofsolution. Any system leakage does not create a drop in system pressure since the pressurizedkeep full supply constantly pressurizes the systems. Additionally, any leak pathfrom RHR or CS would be discoveredduring Operations and system engineeringwalkdowns.

5.4.2.1.3 Dissolved gas can come out of solution due to a pressure reduction such as through control valves, orifices, and ECCS sump screens, or because of elevation changes or venting.

All the ECCS systems typically are in standby and depressurizedcondition. The only areas of a High /Low pressure interface in the ECCS systems are exhibited at the interactionfrom reactorvessel pressure to the RHR injection

.piping at the normally closed injection valve. All the keep full systems are a Low /Low pressure interface. Any gas that comes out of solution as a result of a pressure drop due to orifice, control valve, screen geometries, would be due to flow and will be swept away.

5.4.2.1.4 Inadvertent draining, system realignments, and incorrect maintenance and testing procedures can result in gas intrusion.

• Verify that discharge low-pressure alarms are set conservatively on keep-fill systems, if installed.

Level switches are used instead of low pressurealarms In an effort to verify keep-full level switches were in calibration,it was discovered that RHR keep-full level switch

Ak ,Engineering Report JAF-RPT-08-00015 Revision 0

--- Page 43 of 70 1OLS-IO1 does not have a calibrationPMposted against it, and the calibrationfrequency and basisfor the RHR and Core Spray keep-full level switches does not meet Entergy PM template standards. REF: CR-JAF-2008-03373.

Ensure that system response actions following a loss of the keep-fill system adequately address gas void. formation and system restoration.

Reviewed ARP 09-3-1-18 (RHR A or B Disch Line Not Full and ARP 09-3-1-10 (Core Spray A or B Disch Line Not Full).

Both documents give guidance on system restorationafter air intrusion into system, with adequate warnings on water hammer issues.

5.4.2.1.5 Air in-leakage can occur through system pathways which allow drain back to the system.

Air in-leakage through system pathways which allow drain back to the system would not occur unless a leak was present.

The suctionpipingfor the RHR and CS are pressurizedfrom the torus. The dischargepiping is continuouslypressurized with a keep-full system. The HPCIsuction and discharge piping is pressurizedfrom the CST Should a leak occur that could cause air in leakage, this would be noticed by operator rounds or by level indicationsin the Torus or the CST 5.4.2.1.6 Failure of level instruments to indicate the correct level for tanks used as a pump suction source can result in gas intrusion.

The table below reflects the annunciatorResponse Procedures (ARP)for Condensate Storage Tank Level Instrument Alarm Actions for the HPCIand RCIC Systems.

Understandingthat RCIC is not within the scope of the Generic Letter, the table illustratesinstrumentation redundancyfor each system (HPCJand RCJC) as well as a tertiarytank level indication independent of these two systems. While there is a potentialfora singularlevel instrumentfailure to occur, the likelihood of a total loss of CST level indication is unlikely. Therefore, gas intrusion due to a failure of CST level indication is not probable.

AnnunciatorResponse Procedures(ARP)for Tank Level Instrument Alarm Actions for HPCIand RCIC Systems

A90k Engineering Report JAF-RPT-08-00015 Revision 0 tervv

(__Yý/ Page 44 of 70 ARP PRoeu Annunciator Leendo Device Setpoint Cause Procedure No. Legend 09-3-3-07 HPCI CST A 23LS-74A, 60 inches Low water LVL LO 23LS-75A, and 23HPI- level in 33TK-23PNS-IOIA 01A not full 12A open. (condensate storage tank A) due to loss of inventory from tank or HPCI and RCIC usage 09-3-3-08 HPCI CST B 23LS-74B and 60 inches Low water LVL LO 23LS-75B and 23HPI- level in 33TK-01b not full 12B open (condensate storage tank B) due to loss of inventory from tank or HPCI and RCIC usage 09-4-0-28 RCIC CST A 13LS-76A 59.5 inches CST level less LVL LO (condensate than 59,5 storage tank A inches RCIC logic level switch 09-4-0-29 RCIC CST A 13LS-76B 59.5 inches CST level less LVL LO (condensate than 59.5 storage tank B inches RCIC logic level switch 09-6-2-10 CST A OR B 33LS-101 Low: 238- Low: Hotwell LVL HI OR (Cond Storage' 19 inches level control LO TK-12A&B HI High 350.81 failure and Lo Level inches Switch) 5.4.2.1.7, Leakage through isolation valves or through check valves can result in gas transport from the intrusion location to other locations in the ECCS.

Air in-leakage through system pathways which allow drain back to the system would not occur unless a leak was present.

The suction pipingfor the RHR and CS are pressurizedfrom the torus. The dischargepiping is continuouslypressurized with a keep-full system. The HPCIsuction and discharge

Engineering Report JAF-RPT-08-00015 Revision 0

--- e Page 45 of 70 piping is pressurizedfrom the CST. Should a leak occur that could cause air in leakage, this would be noticedby operator rounds or by level indicationsin the Torus or the CST.

5.4.2.1.8 Leakage through vent valves can occur when the local system pressure is less than the nominal atmospheric vent pressure.

The local system pressurewill not be less than nominal atmosphericpressure,as the RHR & Core spray suction is pressurizedto Torus head of water and the discharge is pressurizedto keep full system pressure.

5.4.2.1.9 Temperatures at or above saturation temperature can occur due to heat conduction through piping connected to the RCS or due to leakage of RCS fluid through isolation valves.

• Verify that any discharge thermocouple monitoring thresholds are set conservatively, if applicable.

CS, HPCIand RHR were reviewedfor discharge thermocouple configurations. Thermocouple applications were not found during this review. Of note, CIVs are normally closed which provides a thermal barrier between the subject systems and RCS.

5.4.2.1.10 Gas can be introduced from suction sources due to formation of air entraining vortices or by not isolating the suction source before it is completely drained.

The potentialfor a vortex to form, while HPCI,RHR or CS is alignedto take suctionfrom the Torus suppressionpool, was evaluated by calculationA384.F02-03. This calculation concluded that a vortex would not develop at the HPCI,RHR or CS suction strainerssince the minimum water.level in the suppressionpool is well above the water level where conditions would support theformation of a vortex.

HPCIhas two suction sources, the Torus suppressionpool as addressedabove, and the CSTs. The potentialfora vortex to form while HPCIis taking suctionfrom the CSTs was evaluated by calculationJAF-CALC-07-00032. This calculationconcluded that there was sufficient submergence depth to prevent the formation of a vortex.

5.4.2.1.11 Review air-operated valve designs for potential air leakage into the system.

Engineering Report JAF-RPT-08-00015 Revision 0 ntleW' Page 46 of 70 CS, HPCIand RHR were reviewedfor Air Operated Valve (AOV) design configurations (i.e., Flow Control Valve, Pressure Control Valve, andAir Operated Valve) where the associatedairoperatormay provide a potential air in-leakage path. AOV type applicationswere identified in the review however none were noted as providing a air in-leakage communicationpathfrom the air operatorto the fluid side of the system.

5.4.2.1.12 Identify other plant specific methods of gas intrusion.

Off-gassing of non-deoxygenated water used duringsystem filling and ventingfollowing maintenance activities (given enough time) will provide a gas intrusion mechanism. This concept is thought to be equally applicablefollowing system operation in support ofplant operationsor surveillance testing. For these reasons, the recommendationfor considerationof conductingperiodicsystem venting was developed (LO-LAR-2008-00020, CA-15 & CA-20).

Otherwise, there are no other methods of gas intrusion that have not already been identified.

5.4.2.1.13 Enter changes that were identified as part of the gas intrusion review.

LO-LAR-2008-00020, CA16, Generic Letter 2008-01 Issue Entergy review criteriafor GL 2008-01 (in-scope ECCS systems) indicate to identify all areas ofpotentialgas intrusion into each system and each system segment vulnerable to subsequent gas accumulation. Assess the system against allpotential areas of intrusion/accumulation identified in GL 2008-01 and in the Entergy Engineering Templatefor addressingthe GL.

RHR system heat exchangers (I OE-2A and I OE-2B, referred to hereafter as 'HX') inlet piping configuration inherently provides a system high point at each HX inlet piping manifold. This piping configurationprovides an area vulnerable to gas accumulation. This piping is provided with high point vent locations (1ORHR-451A / B) that are not currently vented from at anyfrequency due to the valves location in a High Radiation Area.

Engineering Report JAF-RPT-08-00015 Revision 0 Page 47 of 70 Pursuantto Licensing commitment A-5408, NUREG-0737 Item H.B. 1 - NYPA Response to NRC Question, JAF has committed to the following.

"Venting of the RHR heat exchanger is accomplished through two safety related motor operatedvalves, installedin series and operatedfrom the control room. Operatingprocedures provide the operatorwith guidancefor venting the heat exchanger to prevent accumulation of noncondensible gases.

The licensing discrepancy is cited in LO-LAR-2008-00020, CA-12. It is recommended that in addition to ventingfrom 1OMOV-166A (B) and 10MOV167A (B) asper the Licensing Commitment that the HX's be fully vented by use of IORHR-451A (B). If the HX was drained,using the MOV's willfill the HX most of the way and then could be fully vented using 10RIHR-451A /B. This approach to venting will reduce area stay time and dose accrual.

LO-LAR-2008-00020, CA-15 & CA-20, Generic Letter 2008-01 Issue Entergy review criteriafor GL 2008-01 (in-scope ECCS systems) indicated to review the process usedfor filling and venting each section ofpiping, including all applicable procedures.

A reviewfor processes and orprocedures was conducted.

Based upon the review, processes and orprocedureswere not foundforfilling and venting each section ofpiping. The following items should be consideredfor improving current proceduralguidance:

M All system vent locations were notfound to be periodically vented. System venting via installed system vents should be considered to enhance current proceduralguidance. Considerationof venting at installedsystem vent locations could be an enhancement to the surveillance test (which would addressfrequency ofperformance).

8 Proceduralguidance should be consideredto be developedforfilling / venting systems following maintenanceactivities.

LO-LAR-2008-00020, CA] 7, GenericLetter 2008-01 Issue

Aft Engineering Report JAF-RPT-08-00015 Revision 0 Page 48 of 70 Entergy review criteriafor GL 2008-0] (in-scope ECCS systems) indicate to. identify all areasofpotentialgas intrusion into each system and each system segment vulnerable to subsequent gas accumulation. Assess the system against allpotential areas of intrusion/accumulation identified in GL 2008-01 and in the Entergy Engineering Template for addressingthe GL.

RHR system heat exchangers (I OE-2A and I OE-2B, referred to hereafter as 'HX') inletpiping configuration inherently provide a system high point at each HX inletpiping manifold.

This piping configurationprovides an area vulnerable to gas accumulation.

This piping is provided with high point vent locations (10RHR-451A /B) that are not currently vented from at any frequency due to ALARA concerns. Presented with this system vulnerability, a system design enhancement evaluation pursuantto GL 2008-01 should be consideredto enhance the installationof vent valve JORHR-451A /B effluent routing configuration in such a manner as to allow venting of the switches from an accessible - low dose area In addition, this piping is provided with high point vent locations (JO0RHR-451A /B) that are not currently vented from at any frequency due to ALARA concerns. Presented with this system vulnerability, a system design enhancement evaluation pursuantto GL 2008-01 should be consideredfor the installation of level instrumentation/ switchesfor continuous monitoring capabilityto assure the system HX's remainfull. Such level switches are currently installed elsewhere in the RHR system for this very function (reference: IOLS-100, 101, 102, 103,& 104).

Should level switches be installedat the HX high points, considerationshould be given to evaluate the following as a part of the design / operation:

• Periodiclevel switch venting is recommended to corroborateswitchfunctionality.

• The level switch piping/ tubing / vent valve routing configurationshould be configured in such a manner as to allow venting of the switchesfrom an accessible

- low dose area.

Engineering Report JAF-RPT-08-00015 Revision 0 EItle Page 49 of 70 5.4.2.2 All of the gas intrusion review activities will be completed by October 11,2008.

All gas intrusion review activities have been completed.

5.4.3 Acceptance Criteria 5.4.3.1 Identify applicable acceptance criteria for allowable gas volume limits for each piping section where gas may accumulate. See Section 5.4.2 for Gas Intrusion vulnerability reviews. This will be completed by October 11,2008.

5.4.3.1.1 Verify that the acceptance criteria for pump suction piping gas volume limits are sufficient to ensure the gas volume fraction at the pump suction is acceptable under flowing conditions.

The suction side piping was evaluated to determine acceptable size voids to meet the acceptancecriteriaas outlined in Section 3.3 ofABS Report 1924850-R-001, Revision 1. The resultingacceptable suction side voids, based on the evaluation contained in calculation 1924850-C-002 are outlined in Table 4-1.

Table 4-1: Acceptable Suction Side Voids ABS Consulting Report 1924850-R-001 Revision 1 Numbers shown (xx), refer to notes following table.

Pump Volume (ft) (1) Volume (ft) (2)

HPCI 4.2 4.7 RCIC 0.42 0.46 RHR 7.7 9.1 CS 4.7 5.6 Notes:

1. Based on 10%flowfor 5 seconds or 5%flow for 20 seconds

2. For void at elevation > 1 Ofeet above pump.

9 In lieu of specific pump testing results, acceptance criteria should be based on industry guidance for acceptable pump performance.

Engineering Report JAF-RPT-08-00015 Revision 0 Entergy Page 50 of 70 The acceptancecriteria referencedin ABS Report 1924850-R-001, Revision 1, is based on guidance provided the BWROG by GE/Hitachi.

Acceptance criteria should correlate the allowable accumulated gas volume with the allowable rate of transport to the pump under flow conditions. The range of flow conditions evaluated should be consistent with the full range of design base flow rates for various break sizes and locations.

ABS Report 1924850-R-001, Revision 1, Section 3.3.1, states ECCS pumps are expected to remain operable with an average continuous voidfraction and limited time void fraction. Based on guidanceprovided the B WROG by GE/Hitachi., the following criteria can be applied to any void in the suctionpiping.:

0 Continuous void fraction at the pump of] %

0 Limited time void fractionpassingthe pump of 10% for 5 seconds Most testingperformedfor gas intrusion effects was at the Best Efficiency Point (BEP)for the pump. However, there are concerns,on the effects of gas intrusionduring lower and higherflow scenarios. During most BWR accident scenarios,HPCIand/orRCIC will start and inject immediately. RHR and CS may run on minimum flow for a period of time before low pressurepermissives for injection are satisfied. Minimum flow is generally at approximately 10% ofpeak efficiency flow on the pump curve and is provided to ensure the pump does not overheat.

The reportfurther states that it is overly conservative to apply a continuous void fraction to B WR suction line voiding. The most probableevent in a B WR will involve a shorter durationflow ofgas afterpump start because of gas trapped in the suction line due to inadequate venting following maintenanceactivities.

Acceptance criteria should consider the prevention of pump air binding, limit pump wear to within the acceptable mission time of the pump, and limit the

Engineering Report JAF-RPT-08-00015 Revision 0

---

Ert w Page 51 of 70 hydraulic performance reduction in the pump to limits defined by the safety analyses.

Based on evaluation of the gas intrusion data that was incorporatedinto ABS Report 1924850-R-001, Revision 1 Section, 3.3.1 and guidanceprovided the B WROG by GE/Hitachi,a bounding 2% by volume continuous suction gas voidfraction is acceptablefor continuous pump -

operation. It could cause increasedwear of the pump, but will not causepump operabilityproblems. However, due to the lack of test data or operatingexperience ofpump operation above 120% of the BEP, it is recommended that pumps which are operatedabove this point be limited to a 1% allowable continuous voidfraction.

5.4.3.1.2 Ensure the acceptance criteria for pump discharge side voiding address water hammer.

Acceptance criteria should consider force loads on pipes and hangers, peak pressure pulses, relief valve opening and reclosing, secondary water hammer due to check valve slamming, and delays or reduction in flow delivery.

Longitudinalpipe stresses as a result of the discharge side pressure transients were screened as outlined in Section 4.6.2 ofABS Report 1924850-R-001, Revision 1 and evaluated in calculation 1924875-C-001. The results of this evaluation are summarized in Table 4-8 of the same ABS Report.

The acceptance criteria are met for all cases.

5.4.3.2 Develop acceptance criteria for allowable gas volume limits for each location where gas may accumulate, if it does not exist. This will be completed by October 11, 2008.

Acceptance criteriafor allowable gas volume limits were calculatedby ABS andprovided in ABS Report 1924850-R-001, Revision 1.

5.4.3.3 Follow industry activities related to the development of acceptance criteria on allowable gas volume limits for pumps and piping. Determine the need for revised acceptance criteria as new information becomes available. This will not be completed by October 11, 2008.

Allowable gas volume limits were calculated by ABS andprovided in ABS Report 1924850-R-001, Revision 1. JAF will utilize all resources

Engineering Report JAF-RPT-08-000oo15 Revision 0 EnteWPage 52 of 70 available,such as B WROG, to keep abreast of new developments, research, and information, and incorporateinto processes and procedures as it becomes available. This will be an ongoingprocess and will not be completed by 10-11-08.

5.4.3.4 Enter the changes that are identified as part of the acceptance criteria review in the corrective action program.

The acceptancecriteria is detailed in ABS Report 1924850-R-001, Revision 1. There'were no changes required.

6.0 TESTING EVALUATION:

All reviewed procedures (and WOs) must be listed, the responsible department identified and the title/brief description included. Any required changes are to be described along with the reason for change, or state if no changes are required. Provide a status for the change: state if complete, or provide a tracking number and a reason why it is acceptable and why it can't be completed prior to October 13, 2008.

6.1 Identify periodic venting (e.g., the Tech Spec 31-day venting surveillance) or gas accumulation surveillance (e.g., ultrasonic testing) procedures that are performed on each system.

The following Operating procedures / surveillances were reviewed:

o OP-13, RHR System OperatingProcedure o OP-13E,RHR System Keep-Full OperatingProcedure o OP-14, CS System OperatingProcedure o OP-15, HPCISystem OperatingProcedure o EN-OP-102, Revision 10, Protective and Caution Tagging o EN-OP-102-01, Revision 4, Protective and Caution TaggingForms & Checklist o ST-3AA, Core Spray loop A Monthly Operability Test o ST-3PA, Core Spray loop A Quarterly Operability Test o ST-3AB, Core Spray loop B Monthly Operability Test o ST-3PB, Core Spray loop B Quarterly OperabilityTest J o ST-2AN, RHR Loop A Monthly Operability Test o ST-2AL, RHR Loop A QuarterlyOperability Test o ST-2AO, RHR Loop B Monthly Operability Test o ST-2AM, RHR Loop B QuarterlyOperability Test If airflow was observed duringthe venting process, a CR is requiredto be initiated.

Procedure ST-4B, HPCIMonthly Operability Test, provides the actions to vent piping' andfurther defines the measurement of the gas / air discharge. This test defines a

Engineering Report JAF-RPT-08-00015 Revision 0 Page 53 of 70 "significantamount of air/gas" as that requiringmore than a minute to obtain a steadyflow of water. If this amount is exceeded, then a CR would be initiated.

6.2 Review the periodic venting or gas accumulation surveillance procedure to:

6.2.1 Ensure consistent and adequate processes are used to verify the effectiveness of periodic venting and surveillance procedures.

All system vent locations were notfound to be periodicallyvented. System venting via installedsystem vents should be consideredto enhance current proceduralguidance. Considerationof venting at installedsystem vent locations could be an enhancement to the surveillance test (which would addressfrequency ofperformance).

6.2.2 Ensure that procedures identify the quantity of gas present or vented during surveillances.

Currentproceduresas referenced in 6.1, were revised to ensure that "any" air noticed during venting,operationsgets documented per a condition report.

Actual volume is not determined since air quantities currently cannot be accuratelymeasured in an effective and cost efficient manner.

While no acceptancecriteriahave been establishedto quantify gas volume, procedure ST-4B, Revision 56, "HPCIMonthly Operability Test" does require a determination of the amount of air released duringventing. The amount of air must be characterizedas either "significant" or "insignificant" based on the following definition: "Asignificant amount of air is defined as requiringmore than 1 minute to obtain a solid stream of waterfrom hose JAF will continue to monitor this issue with the industry as they determine the best means availablefor performing this task. If acceptance criteriaare developed along with measurement means, JAF will evaluate revising the venting procedures at that time to incorporatethe standards.

6.2.3 Ensure that procedures have acceptance criteria (consistent with Section 5.4.3) for the allowable of gas at each location which is periodically vented or verified by surveillance procedures, including an allowance for measurement uncertainty (where required). If acceptance criteria are not included, then require it to be entered into the CAP when a void is detected.

Currentprocedures as referenced,in 6.1, were revised to ensure that "any" air noticed during venting operationsgets documentedper a condition report.

Actual volume is not determinedsince airquantities currently cannot be accurately measured in an effective and cost efficient manner.

While no acceptancecriteria have been established to quantify gas volume, procedureST-4B, Revision 56, "HPCIMonthly Operability Test" does require a

Engineering Report JAF-RPT-08-0001 5 RevisionO0 Lfltergy Page 54 of 70 determination of the amount of air released duringventing. The amount of air must be characterizedas either "significant" or "insignificant" based on the following definition: "A significant amount of air is defined as requiringmore than 1 minute to obtain a solid stream of waterfrom hose."

JAF will continue to monitor this issue with the industry as they determine the best means availablefor performing this task. If acceptancecriteriaare developed along with a measurement means, JAF will evaluate revising the venting proceduresat that time to incorporatethe standards.

6.2.4 Ensure that procedures require entry into the CAP when gas accumulation in excess of the acceptance criteria is identified Currentproceduresas referenced in 6.1, ensure that "any" air noticed during venting operationsgets documented per a condition report. No acceptance criteriahave been established to quantify what amount is acceptable. Vented air quantitiescurrently cannot be accurately measuredin a cost efficient manner.

JAF will continue to monitor this issue with the industry as they determine the best means availablefor performing this task. If acceptancecriteriaare developed along with a measurement means, JAF will evaluate revising the venting procedures at that time to incorporatethe standards.

6.2.5 Ensure that a procedure exists to verify that the piping is sufficiently full, of water for each system and for each source of gas intrusion identified in Section 5.4.2. Develop new procedures where none exists, ensuring that requirements in 6,2.4 are included.

m ST-2AL, ST-2AM, ST-2AN, and ST-2A0 (RHR Quarterly and Monthly Operability Test) 0 ST-3AA, ST-3AB, ST-3PA, and ST-3PB (CS Quarterlyand Monthly Operability Test)

• ST-4B (HPCIMonthly)

These procedureswere revised to ensure that any air noticed during venting operations is requiredto be documented per a condition report. RHR and CS system are not vented if the level switches are verified to be working. The HPCI system is vented since there are no level switches installed on the system.

6.3 Review current procedures that address periodic venting or gas accumulation surveillance requirements.

6.3.1 Verify that the system is not pre-conditioned by other surveillance procedures such that the system is filled by the previous testing activity prior to the venting surveillance.

Engineering Report JAF-RPT-08-0001 5 Revision 0 EPage 55 of 70 No such precautionscurrently exist. Revise surveillanceprocedures to add a prerequisiteto verify that the system' has not been pre-conditioned. (CR-HQN-2008-0881) 6.4 Identify revisions required to current periodic venting or gas accumulation surveillance procedures, and any new procedures required, and enter them into the CAP.

LO-LAR-2008-00020, CA-15 & CA-20, Generic Letter 2008-01 Issue Entergy review criteria for GL 2008-01 (all in-scope ECCS systems) indicate to review the process used for filling and venting each section of piping, including all applicable procedures.

A review for processes and orprocedureswas conducted. Based upon the review, processes and orprocedures were notfound forfilling and venting each section of piping. The following items should be consideredfor improving currentprocedural guidance:

• All system vent locations were notfound to be periodicallyvented. System venting via installedsystem vents should be considered to enhance currentprocedural guidance. Considerationof venting at installedsystem vent locations could be an enhancement to the surveillance test (which would addressfrequency of performance).

" Proceduralguidance should be consideredto be developedforfilling/ venting systems following maintenanceactivities.

6.5 Trend periodic venting results to confirm that the systems are sufficiently full of water and that the venting frequencies are adequate. Records on the quantity of gas at each location should be maintained and trended as a means of preemptively identifying degrading gas accumulations.

JAF will evaluate the need to develop a program to monitor and trendgas accumulation in ECCS systems within the scope of this report. The intent of the program would be-to conduct monitoringand could be suspended if trendingindicates no issues have developed in the specific systems. (LO-LAR-2008-00020, CA-19) 6.5.1 Ensure gas is sampled for any unexpected void to identify the type of gas to assist in determining the source and required monitoring and control actions, as necessary.

When performing venting operations in the plant, a sample is not collectedfor determiningthe source. This is due to the fact that the gas vented is assumed to be air based on no othergas being introduced into the system.

Engineering Report JAF-RPT-08-00015 Revision 0

- nte Page 56 of 70 6.6 Review the procedures to verify that gas intrusion does not occur as a result of inadvertent draining, system realignments, or incorrect maintenance procedures. For example, these activities may include the following:

• Maintenance activities

. Quarterly pump testing (including restoration to standby conditions)

• Suction source changes (e.g. tank to suppression pool, or RWST to containment sump, etc.)

• Testing evolutions

• Idle train startup activities Identify the schedule to complete this procedure review.

According to section 6.7 below, procedure reviews identified in this section are not requiredto be completed by the October 11, 2008 deadline. JAF will review the associatedprocedures and initiate corrective actionsfor any deficiencies identified or.

where proceduralenhancements are needed. JAF will commit to performing these procedurereviews by April 11, 2009. (LO-LAR-2008-00020, CA-15 & CA-20) 6.7 All of the testing evaluations, except for procedure reviews identified in Section 6.6, will be completed by October 11, 2008.

Based on a review of ABS Report 1924850-R-001, Revision 1 and the ABS generated isometrics, there are eleven locations identified where no vent is availableand the potentialfor voidformation exist. These eleven locations are indentified in Table 4-5 of the report. UT examinationsof the eleven potentially void locations were performed and all locations werefound to be full of water with no evidence of air voiding. Based on the UT results, no additionalvents are needed at these locations.

6.8 Enter the changes that are identified as part of the testing review in the CAP.

LO-LAR-2008-00020, CA-15 & CA-20, Generic Letter 2008-01 Issue Entergy review criteria for GL 2008-01 (all in-scope ECCS systems) indicate to review the process used for filling and venting each section of piping, including all applicable procedures.

A review for processes and orprocedures was conducted. Based upon the review, processes and orprocedures were notfound forfilling and venting each section of piping. Currentproceduralguidance should be consideredfor enhancementfor the periodic venting of installedsystem level switches.

• In addition to the Level Switch venting recommendation, installedsystem vent locations were notfound to be periodically vented. System venting via installed system vents should be considered to enhance currentproceduralguidance.

Engineering Report JAF-RPT-08-00015 Revision 0 Ente-WyPage 57 of 70 Considerationof venting at installedsystem vent locations could be an enhancement to the surveillance test (which would addressfrequency ofperformance).

• Proceduralguidance should be consideredto be developedforfilling / venting systems following maintenanceactivities. (LO-LAR-2008-00020, CA-15 & CA-20) 7.0 CORRECTIVE ACTIONS:

7.1 Summary of as-found conditions 7.1.1 Summarize the results of any non-conforming, as-found gas accumulations and the correction actions that were identified as a result of the reviews identified in Sections 4 through 6.

UT examinations were performed on the eleven areas identified in ABS Report 1924850-R-001, Revision 1, Section 4.0 and are listed in Table 4.4. No as-found, non-conforming gas accumulationswere discovered as a result of these reviews.

7.2 Summarize the corrective actions that have been or will be completed by October 11, 2008 resulting from the Licensing Basis, Design, and Testing Evaluations.

No immediate corrective actions are required based on the evaluation performedfor GL-2008-01. Walkdowns identifiedpotential void areas that were verified to be full of water or analyzed as acceptable. No Plant damage has been identified as attributableto gas accumulation.

7.3 For the follow-up actions that will not be completed by October 11, 2008, summarize the scope and schedule (and basis for the schedule) for any follow-up actions and corrective actions resulting from the Licensing Basis, Design, and Testing.Evaluations. Note: The GL specifically requests a basis be provided for the schedule of future corrective actions.

Proceduralrevisions are requiredto enhancefuture compliance with the management of gas accumulation issues. These procedures include Operations and Engineering. No additionalvent locations were identified however, additionaltraining in filling and venting of systems is recommended. The remaining required corrective actions will be completed on or before 10/11/2009.

Engineering Report JAF-RPT-08-00015 Revision 0 Enrwl~y Page 58 of 70 7.4 General Corrective Action Process 7.4.1 Describe how gas voids are trended, documented and dispositioned, if found on any of the subject systems. This item may be covered in Section 6.2.4.

• The site CAP is the primary program that is used, however other details related to void specific disposition should also be discussed here. Gas intrusion/accumulation issues should be documented as nonconforming conditions and should be. trended to determine if increased or alternate monitoring is required. Previous OE can be used to demonstrate program effectiveness.

JAF will evaluate the need to develop a program to monitor and trend gas accumulation in ECCS systems within the scope of this report. The intent of the program would be to conduct monitoring and could be suspended if trending indicates no issues have developed in the specific systems. (LO-LAR-2008-00020, CA-19)

8.0 TRAINING

8.1 SER 2-05, Rev 1 recommends that training be provided to plant personnel on Gas Intrusion/Accumulation issues as described below. Note that a description of training activities is not requested by the GL.

8.1.1 Provide initial and continuing training on gas intrusion to personnel responsible for the design, performance monitoring, operation, and maintenance of safety systems susceptible to gas intrusion or systems and components that may cause gas intrusion in safety systems. Train personnel who plan and perform fill and vent evolutions and who develop work instructions or procedures on these systems. This training should address the following:

• Reviews of site and industry gas intrusion events, including actual and potential consequences and lessons learned.

• Causal factors and conditions for gas intrusion--design characteristics, operating practices, and equipment performance problems.

• Plant-specific actions and strategies for the identification, prevention, and mitigation of gas intrusion.

• Association of the void location in pump suction piping or pump discharge piping with the physical phenomenon it causes and the part of the design basis adversely affected (e.g., reduction in core and containment cooling, lower NPSHA,air binding, flow reduction, delay in flow, pressure pulse, relief valve opening and re-closing, force loads on hangers and piping).

• Location of each system's void acceptance criteria and trending records.

JAF-TEAR #624

Engineering Report JAF-RPT-08-00015 Entery Revision 0 Page 59 of 70

Title:

Generic Letter 2008-01 Issue: JAF- TrainingEnhancements Entergy review criteriafor GL 2008-01 (in-scope ECCS systems) recommends thatpursuantto SER 2-05, Rev 1, trainingbe provided to plant personnelon Gas Intrusion/Accumulationissues as described below. Note that a description of trainingactivities is not requested by the GL. A training review was conducted. Based upon this review, it is recommended to provide initial and continuing trainingon gas intrusion to personnel responsiblefor the design, performance monitoring,operation, and maintenance of safety systems susceptible to gas intrusion or systems and components that may cause gas intrusion in safety systems. Train personnel who plan andperform fill and vent evolutions and who develop work instructionsorprocedures on these systems. This trainingshould address the criteriaoutlined in 8.1.1 of this report.

9.0

SUMMARY

OF INTERNAL OE REVIEW:

9.1 Summarize the review of internal OE and corrective actions for gas intrusion, Water hammer or air entrapment. Include details in attachment 12.3.

A review of internal and external OE was completed. Keyword searches related to the ECCS systems and factors related to gas accumulation were run to identify any previous or current problems related to gas accumulation and its effects. Keywords used in this search included combinations of the following:

w Emergency Core Cooling System or ECCS 0 Residual Heat Removal or RHR N Low Pressure Core Spray or LPCS 0 High PressureCore Spray or HPCS 0 High PressureCoolantInjection or HPCI N Low Pressure Core Injection or LPCI 0 Core Spray

• Gas intrusion; Gas accumulation; Gas binding 0 Binding, Pump binding 8 Water hammer E Void; Voiding 0 Venting The majority of 0E, reviewed, dealt with the issue of inadequate, or lack.ofproper venting during maintenance and or testing evolutions. These OEpointed to the critical aspect ofproper venting methods being utilized to ensure system availability. There has not been any incident where damage due to the existence of air or gas in these systems

Engineering Report JAF-RPT-08-00015 in__ Revision 0 Page 60 of 70 has impairedthe systems in a way that would keep them from performing their safety function.

The review of external operatingexperience (OE) also confirms and supports the conclusions of this report. Most of the lessons learned in the external operating experience search have already been incorporatedinto currentJAFpractices. Those practices that have not yet been incorporated,such as dynamic venting, enhancements to post maintenance/ outage operabilitytesting of ECCS systems and revisions to currenttesting procedures to enhance acceptance criteria,will be incorporatedthrough the CR process as outlined in Section 7. 0.

10.0 CONCLUSION

S:

Based on the evaluations completed and documented herein and completion of identified corrective actions the JAF plant concludes that the evaluatedsystems are in compliance with the current licensing basis and design basis and applicableregulatory requirements. Upon completion of the identified correctiveactions, suitable design, operationaland testing control measures are or will be in placefor maintainingthis compliance.

It should be noted that additionalindustry activitiesýare under consideration(e.g. pump testing for void limits, gas transportprocesses,procedurefor quantificationof venting, best practices forfill and vent surveillances, etc.). As these activities are completed, the results of these activities should be reviewedfor relevance,and applicability.

11.0 REFERENCES

11.1 NRC Generic Letter 2008-01, "ManagingGas Accumulation in Emergency Core Cooling,Decay Heat Removal, and Containment Spray Systems ", Dated 01/11/2008.

11.2 INPO Significant Event Report SER 2-05, "Gas Intrusion in Safety Systems ", Dated 01/09/2008.

11.3 NEILetter to Nuclear Strategic Issues Advisory Committee, "Response to GL 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems ", Dated 07/24/2008.

11.4 NRC Letter to NEI Summarizing NRC Requirements for the GL 2008-01 Response, Dated 07/08/2008.

11.5 Westinghouse Electric Co., SEE-Ill- WP-08-01 Rev 0, "Walkdown Procedurefor Gas Accumulation Evaluation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems ".

11.6 Westinghouse Electric Co., WCAP-16631-NP Rev 0 Volumes 1 & 2, "Testing and Evaluation of Gas Transport to the Suction of ECCS Pumps ",Dated October2006.

11.7 GE- HitachiNuclear Energy, GEH-EPIWXIWZ-015, "ECCSLOCA Evaluation".

Engineering Report JAF-RPT-08-00015 is "Revision 0

--- W Page 61 of 70 11.8 EC 8182, ECCS/LOCA Analysis Input Parameters,-SAFER/GESTR (T0407) Evaluation 11.9 ABS ConsultingReport 1924850-R-001 Revision 1, "Summary Report Associated with NRC Generic Letter (GL) 2008-01 Managing Gas Accumulation in ECCS, Decay Heat and Containment Spray Systems" Dated October 2008.

11.10 ABS ConsultingReport 1924850 -R-003, Rev. 0, "Walkdown Report Associated with GL 2008-01 Managing Gas Accumulation in ECCS, Decay Heat and Containment Spray System ".

11.11 ABS ConsultingReport 1924850-C-001, Rev. 1, "GL 2008-01: StructuralScreening of Fluid TransientEffects" Dated September 2008.

11.12 ABS ConsultingReport 1924850 -C-002, Rev. 2, "GL 2008-01: Evaluation of Acceptable Void Sizes in ECCS, Decay Heat, and Containment Spray Systems" Dated September 2008.

11.13 ABS ConsultingReport 1924850-P-002,Revision 0, "Field Walkdown and Data Recording Associated with Managing Gas Accumulation in Emergency Core Cooling, Decay Heat and Containment Sprays Systems, James A. Fitzpatrick".

11.14 ABS Consulting Walkdown Drawings 11.14.1 1924850-D-001, Revision, "GL2008-01 Walkdown Data Points - ECCS All" 11.14.2 1924850-D-002, Revision 0, "GL2008-01 Piping Segment Elevation Data for HPCISystem, JAF Station" 11.14.3 1924850-D-004, Revision 0, "GL2008-01 PipingSegment Elevation Data for CS System, JAF Station".

11.14.4 1924850-D-005, Revision 0, "GL2008-01 PipingSegment Elevation Data for RHR System, JAF Station ".

11.15 Letterfrom NYPA, concerningJAF CST Vortexing during HPCI/RCICOperation, Letter # CM-JAF-93-016, Dated January27, 1993.

11.16 Report JAFRPT-MULT-02107, "JamesA. FitzpatrickNuclear Power Station IPE Update, Revision 2".

11.17 Duke Engineering& Services CalculationNo. A384.F02-03, "RHR; CS, HPCIand RCIC Suction Strainer Vortex/Minimum Submergence, Rev. 1" 11.18 JAF UpdatedFSAR 11.19 JAF Technical Specifications 11.20 JAF Technical Specifications Bases 11.21 JAF Technical Requirements Manual 11.22 NRC Bulletin 96-03, "PotentialPlugging of Emergency Core Cooling Suction Strainers by Debris in Boiling-Water Reactors".

11.23 NUREG-073 7, "Clarificationof TMI Action Plan Requirements, 1980".

Engineering Report JAF-RPT-08-00015 A Entergy Revision 0 Page 62 of 70 11.24 NUREG-150, "Severe Accident Risks: An Assessment for Five US NuclearPower Plants, 199".

11.25 Calculation:

11.25.1 A384.F02-03, Revision 0, "RHR, CS, HPCI,and RCIC Suction Strainer Vortex/ Minimum Submergence 11.25.2 JAF-CALC-07-00032, "RequiredLevelto PreventAir-entraining Vortices at HPCI & RCIC CST Suction ".

11.26 Modifications:

11.26.1 F1-74-052 11.26.2 F1-75-13 11.26.3 F1-75-253, "RHR Keepfull Pump Installation".

11.26.4 JD-03-005 (ER-02-0031).

11.27 Design Basis Documents:

11.27.1 DBD-O10, Revision 12, "ResidualHeat Removal System ".

11.27.2 DBD-014, Revision 10, "Core Spray System ".

11.27.3 DBD-023, Revision 11, "High Pressure Coolant Injection System ".

11.28 Design Specifications:

11.28.1 22A1435, Revision 1, "Core Spray System Design ".

11.28.2 22A1472, Revision 1, "GE Design Specification Residual Heat Removal System (with Steam Condensing)".

11.29 Procedures:.

11.29.1 ARP-09-3-1-10, Revision 3, "Core Spray A and B DischargeLine Not Full".

11.29.2 ARP-09-3-1-11, Revision 4, "Core Spray Sys. A Hi Press Valve Leakage ".

11.29.3 ARP-09-3-1-14, Revision 6, "Torus Bulk Temp Hi or RTD Failure".

11.29.4 ARP-09-3-1-18, Revision 5, "RHR A or B Disch Line Not Full".

11.29.5 ARP-09-3-2-11, Revision 4, "Core Spray Sys B Hi Press Vlv Leakage ".

11.29.6 ARP-09-3-2-14, Revision 5, "RHR HXA or B Inlet WTR Temp Hi ".

11.29.7 ARP-09-3-3-07, Revision 4, "HPCICSTA LVL LO".

11.29.8 ARP-09-3-3-08, Revision 3, "HPCICSTB L VL LO".

11.29.9 ARP-09-4-0-28, Revision 5, "ADS Timers Actuation 11.29.10 ARP-09-4-0-29, Revision 5, "RXBldg Equip Sump A L VL HI".

11.29.11 ARP-09-4-3-23, Revision 2, "RHR HX A or B PRESS HI".

Engineering Report JAF-RPT-08-00015 AEntergy Revision 0 Page 63 of 70 11.29.12 ARP-09-6-2-10, Revision 5, "CSTA OR B LVL HI OR LO".

11.29.13 ARP-09-6-3-1 0, Revision 2, "TURB BLDG EQUIP SUMP VA C DRA G VL V OUT OFAUTO".

11.29.14 EN-DC-i 15, Revision 5, "EngineeringChange Development".

11.29.15 EN-DC- 117, Revision 1, "PostModification Testing and Special Instructions".

11.29.16 EN-DC-136, Revision 3, "Temporary Modifications".

11.29.17 EN-DC-i 41, Revision 5, "Design Inputs".

11.29.18 EN-OP-102, Revision 10, "Protectiveand Caution Tagging".

11.29.19 EN-OP-102-01, Revision 4, "Protective and Caution Tagging Forms &

Checklist ".

11.29.20 OP-13,'Revision 93, "ResidualHeat Removal System 11.29.21 OP-13D, Revision 20, "RHR Shutdown Cooling".

11.29.22 OP-1 3E, Revision 4, "RHR-Keep-Full".

11.29.23 OP-13F,Revision 10, "RHR System Operations".

11.29.24 OP-14, Revision 31, "Core Spray System ".

11.29.25 OP-15, Revision 54, "High PressureCoolant Injection ".

11.29.26 ST-2AL, Revision 27, "RHR Loop A QuarterlyOperability Test (IST)"

11.29.27 ST-2AM, Revision 26, "RHR Loop B QuarterlyOperability Test (IST)".

11.29.28 ST-2AN, Revision 13, "RHR Loop A Monthly Operability Test (IST)".

11.29.29 ST-2AO, Revision 13, "RHR Loop B Monthly Operability Test (IST) "

11.29.30 ST-3AA, Revision 8, "Core Spray Loop A Monthly Operability Test (IST)".

11.29.31 ST-3AB, Revision 8, "Core Spray Loop B Monthly Operability Test (IST)".

11.29.32 ST-3PA, Revision 11, "Core Spray Loop A Quarterly Operability Test (IST)".

11.29.33 ST-3PB, Revision 12, "Core Spray Loop B QuarterlyOperability Test (IST) ".

11.29.34 ST-4B, Revision 56, "HPCIMonthly Operability Test ".

11.30 Licensing Commitments:

11.30.1 A-1273, "NRC Inspection 50-333/75-04".

11.30.2 A-1485, "DamagedContainment Spray Line Support".

11.30.3 A-2232, "ProposedChange to Technical Specifications".

Engineering Report JAF-RPT-08-00015 Revision 0 a

. EnteW Page 64 of 70 11.30.4 A-2583, "NRC Inspection 50-333/78-19".

11.30.5 A-5408, "NUREG'0737Item II.B.1 - NYPA Response to NRC Question 11.30.6 A-1126, "ProposedChange to Technical Specifications ".

12.0 ATTACHMENTS:

12.1 OperationalExperience Reviews.

12.2 ABS ProjectDeliverablesListing..

12.3 12.3 ABS ConsultingReport 1924850-R-001 Revision 0, "Summary Report Associated with NRC GenericLetter (GL) 2008-01 Managing Gas Accumulation in ECCS, Decay Heat and ContainmentSpray Systems" Dated October 2008. (See EC-10507 attachment in INDUS).

Engineering Report JAF-RPT-08-00015 ftEntervv Revision 0

ý-Y./ Page 65 of 70 ATTACHEMENT 12.1 OPERATIONAL EXPERIENCE REVIEWS DATE OE NUMBER OE TITLE LESSONS LEARNED 09/12/2007 CR-JAF-2007- Shutdown cooling isolated The system / pump trip was due to a high 03221 two times on'high RPV pressure system isolation signal when Reactor pressure with RPV Pressure was less than 5 psig (well below the pressure at less than 5 psig isolation signal setpoint of 102 - 108'psig).

The investigation attributed this failure to the collapse of gas (air) voids within the system suction and / or discharge piping.

Voids were determined present within the system due to inadequate system venting and

_ _ _system flushing.

09/14/2008 CR-JAF-2008- Shutdown cooling isolated I The system / pumptrip was due to a high 02933 two times on high RPV pressure system isolation signal when Reactor pressure with RPV Pressure was less than 5 psig (well below the pressure at less than 5 psig. isolation signal setpoint of 102'- 108 psig).

The event was similar to CR-JAF-2007-03221.

However, following the CR-JAF-2007-03221 investigation / corrective actions coupled with the ongoing .GL 2008-01 review, the CR-JAF-2008-02933 event yielded consideration of a cause other than inadequate venting.

Actions are being developed to address the latent error to prelude future occurrence.

Engineering Report JAF-RPT-08-00015 ift 77!:-- Entergy Revision 0 Page 66 of 70 DATE OE NUMBER OE TITLE LESSONS LEARNED

• 01/9/2008 SER 2-05 Gas Intrusion in Safety

• Review safety system configurations for the Systems susceptibility to gas intrusion.

Enhance the effectiveness of venting by reviewing procedures, vent locations etc.

E Give a high priority to known equipment deficiencies that contribute to air intrusion into safety systems.

• Provide training to personnel on air intrusion.

• Provide guidance in procedures (operating, tests and maintenance) regarding activities that could result in air intrusion in safety systems.

Review maintenance procedures and preventative maintenance programs that involve safety related systems for establishing adequate system operability following maintenance activities.

01/29/1998 SEN 179 Long Standing Design

• Industry OE not used to resolve problem of gas Weakness and Ineffective binding.

Corrective Actions Cause

• The pump manufacturer did not notify stations Gas ,Binding Failures of of updated information on orifice design that High Head Safety Injection were found to eliminate generation of gas in the Pumps system.

(

• Venting of pump to purge accumulated suction piping voids was proceduralized and was not considered an operator workaround thus delaying implementation of corrective actions.

09/11/2003 SEN 243 Airbound Containment N The operating procedure for performing a static Spray Pumps 'fill and vent was inadequate to eliminate voids in the pump casing.

• Operating procedures did not incorporate guidance for dynamic venting.

• Surveillance procedures specified the normal

• and expected values for pump discharge pressure and spin-up time, but did not specify values, for pump motor amperage and flow rate as a reference for the operators to verify proper pump operations.

08/11/2008 OE27271 Gas Accumulation The procedure for ECCS flow path verification Discovered in RHR did not include venting the high point inside System (Vogtle) cContainment.

Engineering Report JAF-RPT-08-00015 Revision 0 OEnteigy Page 67 of 70 DATE OE NUMBER OE TITLE LESSONS LEARNED 08/11/2008 OE27270 Gas Intrusion in Safety Maintenance activities required the pumps to be Related System as a Result isolated drained. When returning the pump to of Maintenance and Safety service, venting involved opening suction valve, Tagging Activities (Calvert venting pump casing and opening discharge Cliffs) valve.

This did not account for small amounts of gas voids created within the safety tagging boundaries migrating to high points of the system against the filling flow direction at the beginning of the restoration steps. (allow for migration of air bubbles outside the tagged boundaries) 08/13/2008 OE27287 Gas Accumulation in a Cause was packing leak on pump. Corrective Suction Piping for Standby actions included possibly further enhancement Makeup Pump (Catawba) to the preventative maintenance performed on these pumps and/or monitoring leakage after pumps are shut down upon completion of testing 01/13/2008 OE26090 / LER Preliminary-T/S 3.0.3 a Voids were vented, this is still being evaluated 482-08001 Entry Due to Both CPP's further.

and Both SIP's Being Declared Inoperable Due to Gas Voiding. (Wolf Creek) 08/12/2008 OE27279 HPCI Main pump seal fails m Inadequate instructions provided by system due to inadequate venting engineer which were included in Clearance Special Instructions.

0 Revise HPCI operating procedure to include a sequence of steps required to properly vent the system.

03/19/2008 OE26474 DHS Voiding due to N Inadequate venting procedures when returning Inadequate Restoration from maintenance. Review fill and vent from Maintenance procedure for adequacy.

Engineering Report JAF-RPT-08-00015 AEntergy Revision 0 Page 68 of 70

. DATE OE NUMBER OE TITLE LESSONS LEARNED 02/01/2005 OE 19931 Decision Making with Air

• There was a lack of important information Entrainment in Millstone 3 contained in the surveillance criteria associated RHR system (Updated by with the as-found conditions of the RHR system OE20979) not being full of water.

Contrary to the requirements of the procedure, "A" RHR train was not swept to remove entrained gases.

Key internal and external OE information was missed.

OE explained the need for sweeping and venting the RHR system and provided detailed guidance on methods to determine impacts on operability and reportability for gas voids found in the system.

07/17/2008 OE27319 Gas Accumulation is Collection of gases in vertical runs of pipe -

suction piping for the part of the minimum flow path.

centrifugal charging pumps Procedures are to be revised to preclude the use of minimum flow alignment to the centrifugal charging pump suction.

3/06/2001 OE1 1969 Unexpected Buildup of N2 Gas pocket was detected in decay heat closed Gas in Decay Heat Closed cooling system train A. During the venting Cooling System 4 at TMI process the gas was sampled and determined to Unit 1 be primarily nitrogen gas.

The source of the nitrogen is microbiological activity in the closed cooling systems.

Denitrifying bacteria produce gas through the consumption of sodium nitrite which is used as a system corrosion inhibitor.

2/23/1998 OE8801 ECCS Discharge Piping

• Corrective actions include recording whether or Venting (Seabrook Station) not air is observed during venting.

N Provide direction to write a CR if an unusual amount of gas is present.

09/14/1999 OE10248 System Configuration and a Enhancement of post outage and maintenance Inadequate Flushing Lead venting, installing new vents, modifying to ECCS Void Formation existing vents and adding certain vent valves to the monthly ECCS venting procedure to reduce the potential for the presence of small voids.

Engineering Report JAF-RPT-08-00015 Revision 0 OEnterg Page 69 of 70 DATE OE NUMBER OE TITLE LESSONS LEARNED

• 11/06/2003 OE17226 ECCS system Design Inadequate venting procedures to demonstrate Configuration Render the operability of the keepfill portion of the Systems Susceptible to system.

Gas Binding Events 0 High point vent valves were not included in initial ECCS system Fill and Vent procedures.

0 Venting practices were of an inadequate duration to eliminate bubbles from long horizontal piping runs.

a System elevation difference between waterleg pump discharge and dead leg piping allowed a head pressure drop that reduced re-absorption of gasses.

• Suppression pool conditions (SRV discharge, suppression pool cooling, suppression pool temperatures LPCS operation) increased aeration of the process fluid resulting in increased rates of gas accumulation.

02/28/2008 LER2007-002 DHR Discharge Piping

• Systems will be reviewed and venting Void Due to Inadequate procedures will be revised.

procedure for Venting Following Maintenance

A0k Engineering Report JAF-RPT-08-00015.

Revision 0 terg( Page 70 of 70 ATTACHEMENT 12.2 ABS PROJECT DELIVERABLES ABS CONSULTING ITEM DOCUMENT NO. REV DOC TYPE DOCUMENT TITLE 1 1924850-0-006. 2/9/09 Transmittal Transmittal of Project Deliverables -

Engineering Support Services Associated with US NRC GL 2008-01 Fitzpatrick Station 2 1924850-R-001 1 Report Summary Report Associated with NRC Generic Letter (GL) 2008-01 Managing Bas Accumulation in ECCS, Decay Heat and Containment Spray Systems 3 1924850-R-002 1 Report Calibration of ZipLevel ID: ABS-ZIP-3 &4 4 1924850-R-003 0 Report Walkdown Report Associated with NRC GL 2008-01 Managing Bas Accumulation in ECCS, Decay Heat and Containment Spray Systems

' ý5 1924850-R-004 0 Report Evaluation of Elevation Measurement Taken, on Insulated Pipes (in support of GL 2008-01) 6 1900039-R-004 0 Report Piping Structural Screening Methodology for NRC GL 2008-01 Associated ECCS, Decay Heat and Containment Spray Systems 7 1924850-C-001 1 Calculation GL 2008-01: Structural Screening of Fluid Transient Effects 8 1924850-C-002 2 Calculation GL 2008-01: Evaluation of Acceptable Void Sizes in ECCS, Decay Heat; and Containment Spray Systems 9: 1924850-P-002 0 Procedure Field Waldown & Data Recording-Engineering Support Associated with NRC Generic Letter GL 2008-01 10 1924850-D-001 0. Drawing GL 2008-01 Walkdown Data Points - ECCS All (1 sheet) 11 1924850-D-002 0 Drawing GL 2008-01 Walkdown Data Points - HPCI System (2 sheets) 12 1924850-D-003 0 Drawing GL 2008-01 Walkdown Data Points - RCIC (1 sheet) 13 1924850-D-004 0 Drawing GL 2008-01 Walkdown Data Points - CS (2 sheets)

14. 1924850-D-005 0 Drawing GL 2008-01 Walkdown Data Points - RHR (4 sheets)