RS-13-227, Response to NRC HELB Audit Request for Information Supporting Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate: Difference between revisions

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{{#Wiki_filter:Genera 10 CFR 50.90 RS-13-227 September 5, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455
{{#Wiki_filter:1 Genera ti RS-13-227 RS-13-227 10 10 CFR CFR 50.90 50.90 September 5, September    5, 2013 U. S. Nuclear Regulatory U.              Regulatory Commission Commission ATTN: Document Document Control Control Desk Washington,DC Washington,    DC 20555-0001 Braidwood Station, Units 11 and 2 Braidwood Facility Operating Facility Operating License License Nos.
Nos. NPF-72 and NPF-77 NRC Docket Nos.
NRC              Nos. STN 50-456 and STN 50-457 Byron Station, Byron  Station, Units 1 and 2 FacilityOperating Facility Operating License License Nos.
Nos. NPF-37 and NPF-66  NPF-66 NRC Docket NRC    Docket Nos.Nos. STN STN 50-454 and STN   STN 50-455 50-455


==Subject:==
==Subject:==
Response to NRC HELB Audit Request for Information Supporting Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate
Response to NRC HELB Audit Request for Information
 
===Response===
Supporting Supporting Request for     tor License Amendment Regarding Measurement Measurement Uncertainty Recapture Uncertainty     Recapture Power Uprate


==References:==
==References:==
: 1. Letter Letter from from Craig Craig Lambert Lambert (Exelon (Exelon Generation Generation Company, Company, LLC)  LLC) to U. S. NRC, U. NRC, "Request "Request for License Amendment Amendment Regarding Regarding Measurement Uncertainty Uncertainty Recapture Power  Power Uprate,"
Uprate," dated June 23,23, 2011 2011[ML1    1 1 790030]
[ML111790030]
: 2. Letter    fromJ.J. S.
Letter from        S. Wiebe (U.
(U. S. NRC)
NRC) to M. M. J. Pacilio (Exelon (Exelon Generation Company, LLC), "Byron Station, Unit            Unit Nos.
Nos. 1 and 2, and and Braidwood Station, Units 11 and Braidwood                          and 22 --Request Requestfor  forAdditional AdditionalInformation Information Suspension of and Suspension        of Review Review of of License LicenseAmendment Amendment Request Requestfor  for Power Power Uprate (TAC Nos. ME6587, ME6588, ME6589,        ME6589, and  and ME6590),"
ME6590)," dated December December 6,      2012 [ML12271A308]
6,2012    [ML12271A308]
: 3. Letter    from David Letter from    David M.M. Gullott Gullott(Exelon (Exelon Generation Generation Company, Company, LLC) to
: u. S. NRC, U.      NRC, "Additional      InformationSupporting "Additional Information      SupportingRequest Request for for License License Amendment Regarding            Measurement      Uncertainty Regarding Measurement Uncertainty              Recapture      Power Power Uprate,"      dated July Uprate," dated      July5,2013 5, 2013 [RS 13-13-189]    [ML13186A178]
189] [ML13186A178]
: 4. E-Mail      from J.S.Wiebe(U.
E-Mail from      J. S. Wiebe (U. S. NRC)NRC) to David David M.
M. Gullott Gullott (Exelon (Exelon Generation Company, Company, LLC), "Preliminary "Preliminary RAI RAI Regarding TB  TB Bldg Bldg HELB,"
HELB," dateddatedAugust August 29, 29, 2013 2013 In Reference 1,1 , Exelon Generation Company, LLC              (EGC)requested LLC (EGC)      requested an amendment amendment to    to Facility Operating License Nos. NPF-72, NPF-77, Facility Operating                                NPF-77, NPF-37 NPF-37 and andNPF-66 NPF-66for for Braidwood Braidwood Station, Units 1 and 2, andand Byron Byron Station, Units Units 11 and and 2, 2, respectively.
respectively. Specifically, Specifically,thethe proposed changes changesrevise revisethetheOperating OperatingLicense Licenseand andTechnical Technical Specifications Specifications to  to implement an increase increase in in rated rated thermal thermal power power of of approximately 1.63% based  based on  on increased  feedwater    flow  measurement increased feedwater flow measurement accuracy. accuracy.
In Reference Reference 2,2, the theNRC NRCrequested requestedadditional additionalinformation information(RAI)
(RAI)pertaining pertainingtotothetheHigh High Energy Line Line Break (HELB)        analysis and an audit (HELB) analysis              audit toto complete complete their their detailed detailedreview review ofof the the
September 5, September      5, 2013 2013 U.S. Nuclear U.S. Nuclear Regulatory Regulatory Commission Commission Page 22 Page power uprate.
power    uprate. The The response responseto  tothis thisRAI RAI was was provided provided in  in Reference 3. On      On July July 17 17 and and 18,  2013 18, 2013    the  NRC NRC conducted the audit. audit. As Asfollow-up follow-up to  to this audit, audit, in in Reference Reference 44 the the NRC requested NRC    requested additional information information regarding the    the assumed assumedTurbineTurbineBuilding BuildingHELB HELB break locations.
break    locations. The response responseto  tothis thisrequest requestisisprovided provided in  in the the Attachment.
Attachment.
EGC has EGC    has reviewed the the information information supporting aa findingfinding of no significant hazards  hazards consideration and the  the environmenta environmentall consideration consideration provided provided to  to the the NRC NRC in in Reference Reference1.1.
The additional The    additional information informationprovided providedininthisthissubmittal submittaldoes  does not not affect affectthe the bases bases for concluding that concluding      that the the proposed license amendment amendmentdoes      doesnotnotinvolve involve aasignificant significant hazards hazards consideration. Furthermore, consideration.      Furthermore,the  theadditional additionalinformation information provided provided in  in this submittal does does not affect not  affect the the bases bases for concluding concluding that neither an environmenta environmentall impact          statement impact statement nor  nor an environmenta an  environmentall assessment assessment needsneedsto to be beprepared preparedininconnection connection with  with the proposed amendment.
There are no regulatory commitments contained in                in this letter.
letter.
Should youyou have any questions questions concerning concerning thisthis letter, letter, please pleasecontact contactLeslie      E. Holden Leslie E. Holden at at (630) 657-3316.
(630)
II declare declare under penalty of perjury perjury that that the the foregoing foregoing isis true true and and correct.      Executed on correct. Executed      on the the 51hth day 5    day ofofSeptember September 2013.
Respectfully, David M. Gullott Gullott Manager    -
Manager - Licensing Licensing
==Attachment:==
===Response===
ResponsetotoNRC  NRCRequest Requestfor  forAdditional AdditionalInformation Information (Non-Propriet (Non-Proprietary)ary)
ATTACHMENT RESPONSE TO RESPONSE TO NRC NRC REQUEST FOR FOR ADDITIONAL INFORMATION 5, 2013 September 5,2013 (NON-PROPRIETARY)


1.Letter from Craig Lambert (Exelon Generation Company, LLC) to U. S. NRC, "Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate," dated June 23, 2011 [ML111790030]
Braidwood/Byron Braidwood/Byron Stations  Stations MURMUR LARLAR Response    to Response to RAI  RAI September September 5,  5, 2013 2013 Attachment, Attachment, page page 1 NRC Request NRC      Request According to Byron According          Byron and Braidwood (BIB) UFSAR Section 3.6, piping                        piping failures failures postulated postulated inin BIB B/B include include high high energy energy (HE) line breaks (HELBs), HE line cracks (HELCs) and                            and moderate energy moderate      energy lineline cracks (MELCs).
2.Letter from J. S. Wiebe (U. S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), "Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 - Request for Additional Information and Suspension of Review of License Amendment Request for Power Uprate (TAC Nos.ME6587, ME6588, ME6589, and ME6590)," dated December 6, 2012 [ML12271A308]
(MELCs).
3.Letter from David M. Gullott (Exelon Generation Company, LLC) to U. S. NRC,"Additional Information Supporting Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate," dated July 5, 2013 [RS 13
Withregard With    regardtotopostulated postulatedpiping pipingfailures, failures,BIB-UFSAR B/B-UFSARSection    Section3.6  3.6states states that:
-189] [ML13186A178]
that.
4.E-Mail from J. S. Wiebe (U. S. NRC) to David M. Gullott (Exelon Generation Company, LLC), "Preliminary RAI Regarding TB Bldg HELB," dated August 29, 2013 In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to Facility Operating License Nos. NPF-72, NPF-77, NPF-37 and NPF-66 for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, respectively. Specifically, the proposed changes revise the Operating License and Technical Specifications to implement an increase in rated thermal power of approximately 1.63% based on
The effects The    effects ofof high high energy energy line line breaks breaks in  in the the turbine turbine building have been evaluated with respect with  respect to  to potential potential impact impact on  on safety-related safety-related equipment equipment located in        in adjoining auxiliary building rooms.
auxiliary and that:
and    that.
The possible The    possible effects effects associated associated with  with the the postulated postulated break of piping considered are loads due structural loads        due to to pressurization, pressurization, increases in pressure and                and temperature which    which could affect environmental could            environmental qualification of equipment, and                    and damage due to          to pipe pipe whip whip and jet impingement.
B/B-UFSAR Section 3.6.1, Postulated Piping Failures in Fluid BIB-UFSAR                                                                            Fluid Systems Outside  Outside the the Containment, provides the criteria for postulating locations of Containment,                                                                                of piping failures (HELBs, HELCs and MELCs) MELes) outside containment.
Describe in detail the postulatedpostulated piping piping failures failures andand their      locations utilized their locations        utilized for the analyses of analyses      ofM&E      release from piping located M&E release                            located in  in the the turbine turbine building building thatthat could could affect affect safety-related equipment located safety-related                        located in  in adjoining adjoining auxiliary auxiliary building rooms  rooms and  andhowhowthisthis information was used to provide input            input to  to the the Gothic Gothic analysis.
analysis. ifIf bounding bounding conditions conditions have been been utilized utilized for thesethese analyses analysesidentifyidentifythe thepiping pipingfailures failuresutilized, utilized,their their bounding bounding M&E M&E and  andthethebounding boundinglocations locations thatthat would wouldenvelop envelop the  the resulting effects effects on on the the safety safety--
related equipment located  located in  in adjoining adjoining auxiliary auxiliary building rooms. In          Inaddition, addition,justify justifyhowhow this/ these M&Es this/these    M&Es and  andlocation(s) location(s) bound bound others.
others. This This justification should  should include, include, but but is not not limited to, consideration considerationof      ofaaHE HErelease releasenear nearaaHELBHELB damperdamperthat  that would wouldallow allow pressurization of      of a  room    while    the  damper      is closing      while is closing while another  another      room    is  not not yet pressurizing pressurizing because becauseits      itsdamper damperisisfarther fartheraway awayfrom  from thethe HEHE release, thereby          creating aa thereby creating differential      pressure across differential pressure          across thethe wall wall that separates separates the   the two two rooms.


increased feedwater flow measurement accuracy.
===Response===
In Reference 2, the NRC requested additional information (RAI) pertaining to the High Energy Line Break (HELB) analysis and an audit to complete their detailed review of the 1 ti RS-13-227 10 CFR 50.90 September 5, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
As As discussed discussedon  onJuly July17,    2013 during 17,2013      duringthe theaudit, audit,the theTurbine Turbine  Building Building(TB)(TB)HighHighEnergy EnergyLine Line Break (HELB)         mitigationstrategy (HELB) mitigation          strategyandand associated associated methodologies methodologies were    wererevised, revised,and  andaanewnewTB  TB HELB      analysis was performed HELB analysis             performed to    to address addressthe  theAuxiliary AuxiliaryBuilding Building (AB)      rooms/areas impacted (AS) rooms/areas        impactedby    by TB TB HELBs.
HELBs. However, However, the  the overall overall equipment equipment qualification qualification design bases  baseswereweremaintained maintained(i.e.,(i.e.,
the the qualification qualification of Class Class 11E electrical electrical equipment in the identified identified AB      rooms/areas are AB rooms/areas          arenot not adversely adverselyimpacted impactedby    byaaTB  TBHELB).
HELB). The  Thenew newTB  TBHELB HELBanalysis analysisconfirms confirmsthat thatthe theadjacent adjacentAB  AB rooms/areas rooms/areasare  aremaintained maintainedasasmild    mildEnvironmental EnvironmentalQualification Qualification(EQ)  (EQ) environments environmentsbased  basedon  on the thebounding boundingTB  TBHELBs.
HELBs.
The The Byron Byron andand Braidwood Braidwood UpdatedUpdatedFinal FinalSafety SafetyAnalysis AnalysisReportReport(UFSAR)
(UFSAR)does    doesnotnotexplicitly explicitly identify identify or discuss the  the locations locations of of the the TBTB HELBs HELBs that need  need to to be be considered consideredororanalyzed analyzedfor  for their their environmental environmental impacts on the safety-related safety-related equipment equipment in    in the the adjacent adjacentAB  AB rooms/areas.
rooms/areas.
As As part part of of our efforts to  to evaluate and resolveresolve thethe non-conformances non-conformancesassociated associatedwith  withthe theexisting existing TB TB HELB HELB analysis, EGC reviewed the existing          existing analysis analysis and anddetermined determinedthat  thatadditional additionalline line breaks breaksshould shouldbe beconsidered consideredfor    forconservatism conservatismand      andtotoverify verifythat thatthethepostulated postulatedbreaksbreaksininthethe new new TBTB HELB HELB analysis would    would be bounding. For      ForthethenewnewTB  TBHELB HELB analysis, analysis, breaks breakswerewere chosen chosenbasedbasedon onthetheresulting resultingseverity severityof  ofthe thebreak break(i.e.,
(i.e.,highest highestenergy energyrelease) release)and andnotnotthe the


==Subject:==
Braidwood/Byron Braidwood/Byron Stations MUR LAR Response to RAI


==References:==
===Response===
September 5, 2013 September Attachment, page Attachment,          page 2 potential of potential      ofthe the pipe pipetoto break break (Le.,
(i.e., piping pipinganalysis analysisresultsresultswerewere not  not used used to  to determine determine break locations).
locations) .
In order In  order to  to determine determine and  and verify verify that that the the bounding bounding conditions conditions have  have been properly properly identified, identified, aa broader spectrum of line broader                        line breaks than previously considered were postulated for each elevation,                                elevation, conservative mass conservative        mass andand energy energy(M&E)              releases were (M&E) releases            were determined determined for    for the postulated postulated line  line breaks, breaks, and evaluations were performed to determine how the postulated breaks                                      breaks would would impact impact the environmental parameters environmental          parameters in    in the the adjacent AB      AB rooms/areas.
rooms/areas. Consideration Consideration of this      this broader spectrum of TB    TB pipe pipe breaks, along with        with maximizing maximizing the      the M&E M&Ereleases, releases, provides provides assurance assurance that  that the most challenging environments environments for        for the safety-related safety-related equipment equipment in      in the the adjacent adjacentAB    AB rooms/areas are      are determined.
determined. The      Themethods methodsemployedemployedare      arebriefly briefly discussed discussedbelow. below.
Postulated Bounding Line Breaks The new TB          HELBanalysis TB HELB        analysis considered considered a broad spectrum      spectrum of    of main main steam steam(MS)  (MS) lineline breaks breaksand    and high energy liquid high                        linebreaks liquid line    breaks in  in the the TB.TB. The breaksbreaks specifically specifically analyzed analyzed resulted resulted in  in the thehighest highest combination of combination        of mass mass flow      rates and enthalpies, flow rates                enthalpies, which which in  in turn resulted in      in the highest highest temperatures in temperatures          in the TB and adjacent AB                  rooms/areas. The AB rooms/areas.              The bounding bounding line  line breaks breaks used  usedin  in the the new TB HELB  HELB analysis analysis areare shown shown in      in Table TableA.1. A.1.
fullyassess To fully    assess what breaksbreaks would would be bounding,bounding, MS    MS breaks from    from the largest to the smallest    smallest line  line size were considered considered for  for each each elevation elevation of    of the TB.TB. The  Thelargest largestMS  MS line line break break sizesize analyzed analyzedwas    was limited to limited    to 1.4 1.4 ft2 ft2due duetotothe theintegral integralflow    flowrestrictors restrictorsininthe    thesteam steamgenerators.
generators. The smallest  smallest MS    MS line break line  break size analyzed was 0.3            0.3 ft2,ft2 , since since the massmass flow  flow rates for  for this this break break represent the lowest mass mass flow flow  rates  for for  the    smallest smallest steam line and liquid line breaks considered steam    line    and    liquid    line  breaks      consideredininthe    theTB. TB.
Additionally, Additionally, the    the 0.3 0.3 ft2 ft2break breakisisthe  the smallest smallest MS  MS line line break break that that would would result result inin an an automatic reactor trip that requires actuation of                of the safety-related safety-related equipment equipment in    in adjacent adjacentAB    AB rooms/areas.
rooms/areas.
Intermediate break sizes    sizes werewereconsidered consideredand      anda abreak breaksize sizeofof0.50.5ft2feconcurrent concurrentwith    withaalosslossofof offsite power power (LOOP)
(LOOP)was    was determined determined to be the limiting                    intermediate break.
limiting intermediate            break. ThisThis break break size size results in in the maximum maximum TB pressure  pressure occurringoccurring as  as thetheAB AB rooms rooms fans fans attempt attemptto    tostart startwhen whenthe    the EDG EDG starts, resulting in a high differential    differential trip. trip. This This scenario scenario represents representsthe    thehighest highestM&E  M&E release release associated associatedwith  withthe thelongest longesttime    timethat thatthetheAB  ABroomroomventilation ventilation is  is not not operating, operating, whichwhich in  in turn leads to  to the the highest highest roomroom temperatures.
temperatures.
These These three three MS  MS main main steam steam lineline breaks breaks are  are postulated postulated to      to occur occur on  on each eachTB  TB elevation elevation that communicates with      with an adjacent adjacent AB    AB room/area (401', 426' and 451' elevations).            elevations).
The liquid      lines breaks liquid lines      breaks evaluated represent  represent the  the liquid liquid lines on each  each elevation elevation that that produce produce the  the highest combination of        of mass flow  flow ratesrates and enthalpies. Although      Although these thesebreaksbreaksdo    donot notresult resultinin higher enthalpies enthalpies than  than the theMS  MS lineline breaks, breaks,they  theymay mayresultresultininhigher highermass massflow flowrates, rates,which whichinin some some cases casesresultresultininfaster fasterinitial initial temperature temperature increasesincreasesininthe    theTB  TBandandadjacent adjacentAB    AB rooms/areas.
M&E Releases Releases to      to Maximize Maximize TB      TB Environmental EnvironmentalConditions    Conditions For each each MS  MS line line break break analyzed analyzed in      in the the new newTB  TB HELBHELB analysis, the transient    transient M&E          releases M&E releases consistent consistent with  with Westinghouse Westinghouse WCAP-10961, WCAP-10961 , "Steamline  "Steam line Break  Break Mass/Energy Mass/Energy Releases  Releasesfor      for Equipment Environment                Qualification Environment Qualification                  Outside    Containment,"            (Reference (Reference A.1)    A.1)    were    used.
used.
Specifically, the Westinghouse Westinghouse transient  transientM&E    M&E releases releasesinvolve involveprogressively progressivelyincreasing increasing enthalpies enthalpies with  with progressively progressively decreasing decreasingmass      massflow  flowrates ratesand andconservatively conservativelymaximize maximize enthalpies enthalpiesto    tomaximize maximize the  theeffect effectof    of M&E      releases on M&E releases            onenvironmental environmentalqualification qualification of    of equipment equipment


Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Response to NRC HELB Audit Request for Information Supporting Request tor License Amendment Regarding Measurement Uncertainty Recapture Power Uprate 1. Letter from Craig Lambert (Exelon Generation Company, LLC) to U. S. NRC, "Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate," dated June 23, 2011 [ML111790030]
Braidwood/Byron Braidwood/Byron Stations MUR LAR
: 2. Letter from J. S. Wiebe (U. S. NRC) to M. J. Pacilio (Exelon Generation Company, LLC), "Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 -Request for Additional Information and Suspension of Review of License Amendment Request for Power Uprate (TAC Nos. ME6587, ME6588, ME6589, and ME6590)," dated December 6,2012 [ML12271A308]
: 3. Letter from David M. Gullott (Exelon Generation Company, LLC) to u. S. NRC, "Additional Information Supporting Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate," dated July 5,2013 [RS 13-189] [ML13186A178]
: 4. E-Mail from J.S.Wiebe(U.
S. NRC) to David M. Gullott (Exelon Generation Company, LLC), "Preliminary RAI Regarding TB Bldg HELB," dated August 29, 2013 In Reference 1 , Exelon Generation Company, LLC (EGC) requested an amendment to Facility Operating License Nos. NPF-72, NPF-77, NPF-37 and NPF-66 for Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, respectively.
Specifically, the proposed changes revise the Operating License and Technical Specifications to implement an increase in rated thermal power of approximately 1.63% based on increased feedwater flow measurement accuracy.
In Reference 2, the NRC requested additional information (RAI) pertaining to the High Energy Line Break (HELB) analysis and an audit to complete their detailed review of the September 5, 2013 U.S. Nuclear Regulatory Commission Page 2 power uprate. The response to this RAI was provided in Reference 3. On July 17 and 18, 2013 the NRC conducted the audit. As follow-up to this audit, in Reference 4 the NRC requested additional information regarding the assumed Turbine Building HELB break locations. The response to this request is provided in the Attachment.
EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1.
The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
There are no regulatory commitments contained in this letter.
Should you have any questions concerning this letter, please contact Leslie E. Holden at (630) 657-3316.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 51h day of September 2013.
Respectfully, David M. Gullott Manager - Licensing


==Attachment:==
===Response===
Response to NRC Request for Additional Information (Non-Proprietary)
Response to     to RAI RAI September September 5,     5, 2013 2013 Attachment, Attachment, page  page 33 located outside located    outside containment.
September 5, 2013 U.S. Nuclear Regulatory Commission Page 2 power uprate. The response to this RAI was provided in Reference
containment. Westinghouse Westinghouse transient transient M&E M&Ereleases releases werewere developed developed to    to bound bound Byron  and  Braidwood        Stations,    Units    1 and  2,  and    include Byron and Braidwood Stations, Units 1 and 2, and include additional conservatisms.      additional      conservatisms.       The Westinghouse approach has Westinghouse                          has been beenapproved approvedfor    forByron Byron andand Braidwood Braidwood Stations Stations by  by the the NRCNRC for for maximizingthe maximizing        the effect effect of ofM&E M&Ereleases releases on  on environmental qualification of equipment      equipment located located outside containment (References outside                        (References A.2,  A.2, p. p. 3-4 3-4 and and A.3,A.3, p.p. 3-18).
: 3. On July 17 and 18, 2013 the NRC conducted the audit. As follow-up to this audit, in Reference 4 the NRC requested additional information regarding the assumed Turbine Building HELB break locations.
3-18).
The response to this request is provided in the Attachment.
For each For    each liquid liquid line linebreak breakevaluated, evaluated, constant constant M&E  M&Ereleases releases based based on the choked choked mass massflow flow rate (Henry-Fauske Critical rate                          Critical FlowFlow Model)
EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference
Model)and   and initial initialenthalpy enthalpywerewere used used with with one one exception; pump runout pump      runout was credited for      for the the FW FW lineline breaks.
: 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.
breaks. Additionally, Additionally, enthalpies were conservatively conservatively maximized. Table A.1 maximized.                  A.1 shows the constant constant M&E            releases used M&E releases          usedforfor the the bounding bounding breaks.
Furthermore, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
breaks.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Leslie E. Holden at (630) 657-3316.
Specifically, ititshows Specifically,         shows the the portion portion of of the the break break M&EM&Ereleasesreleases that flash to steam  steamininthe theTB TB environment and environment        and werewere analyzed for    for the the effects effects on on the adjacent AB          areas.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 5 th day of September 2013. Respectfully, David M. Gullott Manager -Licensing
AB areas.
Differential Pressure Between AB Rooms Differential divisional block The divisional        block walls walls (e.g.,
(e.g., walls walls between between the DivisionDivision 11 11(21)
(21) and Division          12(22) ESF Division 12(22) equipment), between the          the ABAB rooms adjacent adjacent to  to the the TB, TB, have havebeenbeenevaluated evaluatedfor    forthe thedifferential differential pressure that pressure      that may mayexistexistfollowing following a TB HELB. HELB. The  The two two divisional divisional ABAB rooms are adjacent  adjacentto    to each other other and and each eachpairpairof of rooms roomscommunicates communicateswith        withthethesame sameTB  TBelevation elevationHELB  HELB environment. FollowingFollowing aa TB  TS HELB, HELS, the  the TB TB pressurizes, pressurizes, drives drivesflow flow into into the AB AB rooms, and    and pressurizes the pressurizes      the ABAB rooms for    for a short short time time until    HELBdampers until HELB        dampers between the        the TB TB and and AB AB rooms close. By By applying applying the  the lumped-parameter lumped-parameter (i.e.,      (i.e., lumped lumped volume) volume) modeling modeling in    in the the GOTHIC GOTHIC analysis, the the pressurization pressurizationof        ofthe theTBTB elevation elevationisisuniform; uniform; therefore thereforethe  theTB TBHELBHELB environment environment outside eacheach of of the AB      rooms was calculated to be the same.
AB rooms                                              same.However, However,differential differential pressurization was calculated between        between the  the AB AB rooms due    due toto variations variations in    in the closure characteristics characteristics of    of the the HELB        dampers, as HELB dampers,            aswell well as asdifferences differencesininAB  ABroomroomvolumes volumesand  andflow flow paths.
paths. InInparticular, particular,the  theclosure closuretimetimeofofthe theHELB HELBdamper damperofofthe  theABABroomroomfor  forone onedivision divisionwas  was maximized, while the closure                time  of  the  HELB      damper      to the  AB    room closure time of the HELB damper to the AB room for other division was    for other  division    was minimized.
minimized. This results in          in one one ABAB room roomreaching reachingaahigher  higherpeak peak pressure pressure than the adjacent room, creating a differential              pressure across differential pressure          acrossthe  thedivisional divisional block block wall.
wall. TheTheloadloaddueduetotothisthis differential    pressure has differential pressure          has been beenaccounted accountedfor    forininthe thenew newdesigns designstotoreinforce reinforcethe  thedivisional divisionalblockblock walls.
IfIf one divisional divisional AS AB roomroom werewere postulated postulated to  to experience higher  higher TB pressure pressureoutsideoutsidethe theroom, room, the the higher higher TBTS pressure pressure wouldwould result result inin higher higher differential        pressure across differential pressure        acrossthe  theHELB HELSdamper.
damper.
The dampers dampers are are designed designedto    toclose closefaster fasterwithwith increasing increasing differential          pressure. The differential pressure.          Thepeakpeak pressure pressure in  in the the AB      room would AS room      wouldbe  be expected expected to    to be be thethe same as  as analyzed analyzed due    dueto tothe thefaster faster damper damper closure closure time.
time. Therefore, Therefore, basedbasedon    onengineering engineeringjudgment, judgment,the   theimpact impactof  of aapostulated postulated higher pressure pressure outside outside one  one AB AB room would would be  be encompassed encompassed by    by the the HELB HELB damper response  response times analyzed, analyzed, (i.e.,(Le., one damper damper closes closesat  atthe theminimum minimum time verses  verses the the other other damper dampercloses closesatat the the maximum maximumtime). time).


==Attachment:==
Braidwood/Byron Braidwood/Byron Stations Stations MUR MUR LAR


Response to NRC Request for Additional Information (Non-Proprietary)
===Response===
ATTACHMENT RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION September 5, 2013 (NON-PROPRIETARY)
Response to to RAI September September 5,2013 5, 2013 Attachment, Attachment, page page 4
ATTACHMENT RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION September 5,2013 (NON-PROPRIETARY)
Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 1 NRC Request According to Byron and Braidwood (BIB) UFSAR Section 3.6, piping failures postulated in B/B include high energy (HE) line breaks (HELBs), HE line cracks (HELCs) and moderate energy line cracks (MELCs).
With regard to postulated piping failures, B/B-UFSAR Section 3.6 states that.
The effects of high energy line breaks in the turbine building have been evaluated with respect to potential impact on safety
-related equipment located in adjoining auxiliary building rooms.
and that.The possible effects associated with the postulated break of piping considered are structural loads due to pressurization, increases in pressure and temperature which could affect environmental qualification of equipment, and damage due to pipe whip and jet impingement.
B/B-UFSAR Section 3.6.1, Postulated Piping Failures in Fluid Systems Outside the Containment, provides the criteria for postulating locations of piping failures (HELBs, HELCs and MELCs) outside containment.
Describe in detail the postulated piping failures and their locations utilized for the analyses of M&E release from piping located in the turbine building that could affect safety-related equipment located in adjoining auxiliary building rooms and how this information was used to provide input to the Gothic analysis. if bounding conditions have been utilized for these analyses identify the piping failures utilized, their bounding M&E and the bounding locations that would envelop the resulting effects on the safety
-related equipment located in adjoining auxiliary building rooms. In addition, justify how this/these M&Es and location(s) bound others. This justification should include, but is not limited to, consideration of a HE release near a HELB damper that would allow pressurization of a room while the damper is closing while another room is not yet pressurizing because its damper is farther away from the HE release, thereby creating a differential pressure across the wall that separates the two rooms.
Response As discussed on July 17, 2013 during the audit, the Turbine Building (TB) High Energy Line Break (HELB) mitigation strategy and associated methodologies were revised, and a new TB HELB analysis was performed to address the Auxiliary Building (AB) rooms/areas impacted by TB HELBs. However, the overall equipment qualification design bases were maintained (i.e., the qualification of Class 1 E electrical equipment in the identified AB rooms/areas are not adversely impacted by a TB HELB). The new TB HELB analysis confirms that the adjacent AB rooms/areas are maintained as mild Environmental Qualification (EQ) environments based on the bounding TB HELBs.
The Byron and Braidwood Updated Final Safety Analysis Report (UFSAR) does not explicitly identify or discuss the locations of the TB HELBs that need to be considered or analyzed for their environmental impacts on the safety-related equipment in the adjacent AB rooms/areas.
As part of our efforts to evaluate and resolve the non-conformances associated with the existing TB HELB analysis, EGC reviewed the existing analysis and determined that additional line breaks should be considered for conservatism and to verify that the postulated breaks in the new TB HELB analysis would be bounding. For the new TB HELB analysis, breaks were chosen based on the resulting severity of the break (i.e., highest energy release) and not the NRC Request Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 1 According to Byron and Braidwood (BIB) UFSAR Section 3.6, piping failures postulated in BIB include high energy (HE) line breaks (HELBs), HE line cracks (HELCs) and moderate energy line cracks (MELCs). With regard to postulated piping failures, BIB-UFSAR Section 3.6 states that: The effects of high energy line breaks in the turbine building have been evaluated with respect to potential impact on safety-related equipment located in adjoining auxiliary building rooms. and that: The possible effects associated with the postulated break of piping considered are structural loads due to pressurization, increases in pressure and temperature which could affect environmental qualification of equipment, and damage due to pipe whip and jet impingement.
BIB-UFSAR Section 3.6.1, Postulated Piping Failures in Fluid Systems Outside the Containment, provides the criteria for postulating locations of piping failures (HELBs, HELCs and MELes) outside containment.
Describe in detail the postulated piping failures and their locations utilized for the analyses of M&E release from piping located in the turbine building that could affect safety-related equipment located in adjoining auxiliary building rooms and how this information was used to provide input to the Gothic analysis.
If bounding conditions have been utilized for these analyses identify the piping failures utilized, their bounding M&E and the bounding locations that would envelop the resulting effects on the related equipment located in adjoining auxiliary building rooms. In addition, justify how this/these M&Es and location(s) bound others. This justification should include, but is not limited to, consideration of a HE release near a HELB damper that would allow pressurization of a room while the damper is closing while another room is not yet pressurizing because its damper is farther away from the HE release, thereby creating a differential pressure across the wall that separates the two rooms. Response As discussed on July 17,2013 during the audit, the Turbine Building (TB) High Energy Line Break (HELB) mitigation strategy and associated methodologies were revised, and a new TB HELB analysis was performed to address the Auxiliary Building (AS) rooms/areas impacted by TB HELBs. However, the overall equipment qualification design bases were maintained (i.e., the qualification of Class 1 E electrical equipment in the identified AB rooms/areas are not adversely impacted by a TB HELB). The new TB HELB analysis confirms that the adjacent AB rooms/areas are maintained as mild Environmental Qualification (EQ) environments based on the bounding TB HELBs. The Byron and Braidwood Updated Final Safety Analysis Report (UFSAR) does not explicitly identify or discuss the locations of the TB HELBs that need to be considered or analyzed for their environmental impacts on the safety-related equipment in the adjacent AB rooms/areas.
As part of our efforts to evaluate and resolve the non-conformances associated with the existing TB HELB analysis, EGC reviewed the existing analysis and determined that additional line breaks should be considered for conservatism and to verify that the postulated breaks in the new TB HELB analysis would be bounding.
For the new TB HELB analysis, breaks were chosen based on the resulting severity of the break (i.e., highest energy release) and not the Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 2 potential of the pipe to break (i.e., piping analysis results were not used to determine break locations).
In order to determine and verify that the bounding conditions have been properly identified, a broader spectrum of line breaks than previously considered were postulated for each elevation, conservative mass and energy (M&E) releases were determined for the postulated line breaks, and evaluations were performed to determine how the postulated breaks would impact the environmental parameters in the adjacent AB rooms/areas. Consideration of this broader spectrum of TB pipe breaks, along with maximizing the M&E releases, provides assurance that the most challenging environments for the safety-related equipment in the adjacent AB rooms/areas are determined. The methods employed are briefly discussed below.
Postulated Bounding Line Breaks The new TB HELB analysis considered a broad spectrum of main steam (MS) line breaks and high energy liquid line breaks in the TB. The breaks specifically analyzed resulted in the highest combination of mass flow rates and enthalpies, which in turn resulted in the highest temperatures in the TB and adjacent AB rooms/areas. The bounding line breaks used in the new TB HELB analysis are shown in Table A.1.
To fully assess what breaks would be bounding, MS breaks from the largest to the smallest line size were considered for each elevation of the TB. The largest MS line break size analyzed was limited to 1.4 ft2 due to the integral flow restrictors in the steam generators. The smallest MS line break size analyzed was 0.3 ft2, since the mass flow rates for this break represent the lowest mass flow rates for the smallest steam line and liquid line breaks considered in the TB.
Additionally, the 0.3 ft2 break is the smallest MS line break that would result in an automatic reactor trip that requires actuation of the safety-related equipment in adjacent AB rooms/areas.
Intermediate break sizes were considered and a break size of 0.5 ft2 concurrent with a loss of offsite power (LOOP) was determined to be the limiting intermediate break. This break size results in the maximum TB pressure occurring as the AB rooms fans attempt to start when the EDG starts, resulting in a high differential trip. This scenario represents the highest M&E release associated with the longest time that the AB room ventilation is not operating, which in turn leads to the highest room temperatures.
These three MS main steam line breaks are postulated to occur on each TB elevation that communicates with an adjacent AB room/area (401', 426' and 451' elevations).
The liquid lines breaks evaluated represent the liquid lines on each elevation that produce the highest combination of mass flow rates and enthalpies. Although these breaks do not result in higher enthalpies than the MS line breaks, they may result in higher mass flow rates, which in some cases result in faster initial temperature increases in the TB and adjacent AB rooms/areas.
M&E Releases to Maximize TB Environmental Conditions For each MS line break analyzed in the new TB HELB analysis, the transient M&E releases consistent with Westinghouse WCAP-10961, "Steamline Break Mass/Energy Releases for Equipment Environment Qualification Outside Containment," (Reference A.1) were used.
Specifically, the Westinghouse transient M&E releases involve progressively increasing enthalpies with progressively decreasing mass flow rates and conservatively maximize enthalpies to maximize the effect of M&E releases on environmental qualification of equipment Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 2 potential of the pipe to break (Le., piping analysis results were not used to determine break locations) . In order to determine and verify that the bounding conditions have been properly identified, a broader spectrum of line breaks than previously considered were postulated for each elevation, conservative mass and energy (M&E) releases were determined for the postulated line breaks, and evaluations were performed to determine how the postulated breaks would impact the environmental parameters in the adjacent AB rooms/areas.
Consideration of this broader spectrum of TB pipe breaks, along with maximizing the M&E releases, provides assurance that the most challenging environments for the safety-related equipment in the adjacent AB rooms/areas are determined.
The methods employed are briefly discussed below. Postulated Bounding Line Breaks The new TB HELB analysis considered a broad spectrum of main steam (MS) line breaks and high energy liquid line breaks in the TB. The breaks specifically analyzed resulted in the highest combination of mass flow rates and enthalpies, which in turn resulted in the highest temperatures in the TB and adjacent AB rooms/areas.
The bounding line breaks used in the new TB HELB analysis are shown in Table A.1. To fully assess what breaks would be bounding, MS breaks from the largest to the smallest line size were considered for each elevation of the TB. The largest MS line break size analyzed was limited to 1.4 ft2 due to the integral flow restrictors in the steam generators.
The smallest MS line break size analyzed was 0.3 ft 2 , since the mass flow rates for this break represent the lowest mass flow rates for the smallest steam line and liquid line breaks considered in the TB. Additionally, the 0.3 ft2 break is the smallest MS line break that would result in an automatic reactor trip that requires actuation of the safety-related equipment in adjacent AB rooms/areas.
Intermediate break sizes were considered and a break size of 0.5 fe concurrent with a loss of offsite power (LOOP) was determined to be the limiting intermediate break. This break size results in the maximum TB pressure occurring as the AB rooms fans attempt to start when the EDG starts, resulting in a high differential trip. This scenario represents the highest M&E release associated with the longest time that the AB room ventilation is not operating, which in turn leads to the highest room temperatures.
These three MS main steam line breaks are postulated to occur on each TB elevation that communicates with an adjacent AB room/area (401', 426' and 451' elevations).
The liquid lines breaks evaluated represent the liquid lines on each elevation that produce the highest combination of mass flow rates and enthalpies.
Although these breaks do not result in higher enthalpies than the MS line breaks, they may result in higher mass flow rates, which in some cases result in faster initial temperature increases in the TB and adjacent AB rooms/areas.
M&E Releases to Maximize TB Environmental Conditions For each MS line break analyzed in the new TB HELB analysis, the transient M&E releases consistent with Westinghouse WCAP-10961 , "Steam line Break Mass/Energy Releases for Equipment Environment Qualification Outside Containment," (Reference A.1) were used. Specifically, the Westinghouse transient M&E releases involve progressively increasing enthalpies with progressively decreasing mass flow rates and conservatively maximize enthalpies to maximize the effect of M&E releases on environmental qualification of equipment Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 3 located outside containment.
Westinghouse transient M&E releases were developed to bound Byron and Braidwood Stations, Units 1 and 2, and include additional conservatisms. The Westinghouse approach has been approved for Byron and Braidwood Stations by the NRC for maximizing the effect of M&E releases on environmental qualification of equipment located outside containment (References A.2, p. 3-4 and A.3, p. 3-18).
For each liquid line break evaluated, constant M&E releases based on the choked mass flow rate (Henry-Fauske Critical Flow Model) and initial enthalpy were used with one exception; pump runout was credited for the FW line breaks. Additionally, enthalpies were conservatively maximized. Table A.1 shows the constant M&E releases used for the bounding breaks.
Specifically, it shows the portion of the break M&E releases that flash to steam in the TB environment and were analyzed for the effects on the adjacent AB areas.
Differential Pressure Between AB Rooms The divisional block walls (e.g., walls between the Division 11(21) and Division 12(22) ESF equipment), between the AB rooms adjacent to the TB, have been evaluated for the differential pressure that may exist following a TB HELB. The two divisional AB rooms are adjacent to each other and each pair of rooms communicates with the same TB elevation HELB environment. Following a TB HELB, the TB pressurizes, drives flow into the AB rooms, and pressurizes the AB rooms for a short time until HELB dampers between the TB and AB rooms close.By applying the lumped-parameter (i.e., lumped volume) modeling in the GOTHIC analysis, the pressurization of the TB elevation is uniform; therefore the TB HELB environment outside each of the AB rooms was calculated to be the same. However, differential pressurization was calculated between the AB rooms due to variations in the closure characteristics of the HELB dampers, as well as differences in AB room volumes and flow paths. In particular, the closure time of the HELB damper of the AB room for one division was maximized, while the closure time of the HELB damper to the AB room for other division was minimized. This results in one AB room reaching a higher peak pressure than the adjacent room, creating a differential pressure across the divisional block wall. The load due to this differential pressure has been accounted for in the new designs to reinforce the divisional block walls.If one divisional AB room were postulated to experience higher TB pressure outside the room, the higher TB pressure would result in higher differential pressure across the HELB damper.
The dampers are designed to close faster with increasing differential pressure. The peak pressure in the AB room would be expected to be the same as analyzed due to the faster damper closure time. Therefore, based on engineering judgment, the impact of a postulated higher pressure outside one AB room would be encompassed by the HELB damper response times analyzed, (i.e., one damper closes at the minimum time verses the other damper closes at the maximum time).
Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 3 located outside containment.
Westinghouse transient M&E releases were developed to bound Byron and Braidwood Stations, Units 1 and 2, and include additional conservatisms.
The Westinghouse approach has been approved for Byron and Braidwood Stations by the NRC for maximizing the effect of M&E releases on environmental qualification of equipment located outside containment (References A.2, p. 3-4 and A.3, p. 3-18). For each liquid line break evaluated, constant M&E releases based on the choked mass flow rate (Henry-Fauske Critical Flow Model) and initial enthalpy were used with one exception; pump runout was credited for the FW line breaks. Additionally, enthalpies were conservatively maximized.
Table A.1 shows the constant M&E releases used for the bounding breaks. Specifically, it shows the portion of the break M&E releases that flash to steam in the TB environment and were analyzed for the effects on the adjacent AB areas. Differential Pressure Between AB Rooms The divisional block walls (e.g., walls between the Division 11 (21) and Division 12(22) ESF equipment), between the AB rooms adjacent to the TB, have been evaluated for the differential pressure that may exist following a TB HELB. The two divisional AB rooms are adjacent to each other and each pair of rooms communicates with the same TB elevation HELB environment.
Following a TS HELS, the TB pressurizes, drives flow into the AB rooms, and pressurizes the AB rooms for a short time until HELB dampers between the TB and AB rooms close. By applying the lumped-parameter (i.e., lumped volume) modeling in the GOTHIC analysis, the pressurization of the TB elevation is uniform; therefore the TB HELB environment outside each of the AB rooms was calculated to be the same. However, differential pressurization was calculated between the AB rooms due to variations in the closure characteristics of the HELB dampers, as well as differences in AB room volumes and flow paths. In particular, the closure time of the HELB damper of the AB room for one division was maximized, while the closure time of the HELB damper to the AB room for other division was minimized.
This results in one AB room reaching a higher peak pressure than the adjacent room, creating a differential pressure across the divisional block wall. The load due to this differential pressure has been accounted for in the new designs to reinforce the divisional block walls. If one divisional AS room were postulated to experience higher TB pressure outside the room, the higher TS pressure would result in higher differential pressure across the HELS damper. The dampers are designed to close faster with increasing differential pressure.
The peak pressure in the AS room would be expected to be the same as analyzed due to the faster damper closure time. Therefore, based on engineering judgment, the impact of a postulated higher pressure outside one AB room would be encompassed by the HELB damper response times analyzed, (Le., one damper closes at the minimum time verses the other damper closes at the maximum time).
Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 4


==REFERENCES:==
==REFERENCES:==


A.1Westinghouse Report No. WCAP-10961, "Steamline Break Mass/Energy Releases for Equipment Environment Qualification Outside Containment," Rev. 1, October 1985 A.2NRC Report No. NUREG-76, Supplement No. 7, "Safety Evaluation Report related to the operation of Byron Station, Units 1 and 2, Docket Nos. STN 50-454 and STN 50-455," November 1986 A.3NRC Report No. NUREG-1002, Supplement No. 2, "Safety Evaluation Report related to the operation of Braidwood Station, Units 1 and 2, Docket Nos. 50-456 and 50-457," October 1986
==REFERENCES:==


==REFERENCES:==
A.1 A.1  Westinghouse Report No. WCAP-10961, Westinghouse              WCAP-10961, "Steamline "Steamline Break Break Mass/Energy Mass/Energy Releases Releases for Equipment Environment Equipment  Environment Qualification QualificationOutside Outside Containment,"
Containment," Rev.
Rev. 1, October 1985 1985 A.2 A.2  NRC Report NRC  Report No.
No. NUREG-76, NUREG-76, Supplement Supplement No. 7, "Safety Evaluation Report related No.7,                            related to to the the operation of Byron Station, Units operation of Byron Station, Units  1 and 2, Docket Nos. STN  50-454  and STN  50-455,"
Docket Nos. STN 50-454 and STN 50-455,"
November 1986 November A.3  NRC Report NRC  Report No.
No. NUREG-1002, NUREG-1002, Supplement Supplement No. 2, "Safety No.2,  "Safety Evaluation Evaluation Report Report related related toto the operation of Braidwood  Station, Units Braidwood Station,  Units 1 and 2, Docket Nos. 50-456 and 50-457,"
50-457,"
October 1986


Braidwood/Byron Stations MUR LAR Response to RAI September 5,2013 Attachment, page 4 A.1 Westinghouse Report No. WCAP-10961, "Steamline Break Mass/Energy Releases for Equipment Environment Qualification Outside Containment," Rev. 1, October 1985 A.2 NRC Report No. NUREG-76, Supplement No.7, "Safety Evaluation Report related to the operation of Byron Station, Units 1 and 2, Docket Nos. STN 50-454 and STN 50-455," November 1986 A.3 NRC Report No. NUREG-1002, Supplement No.2, "Safety Evaluation Report related to the operation of Braidwood Station, Units 1 and 2, Docket Nos. 50-456 and 50-457," October 1986 Braidwood/Byron Stations MUR LAR Response to RAI September 5, 2013 Attachment, page 5 Table Al:Bounding Turbine Building HELBs Initial Mass Flow Rates and Enthalpies B EL.ine Ty p e inet Initial Line Enthalpyf (Btu/Ibm)Initial Steam Enthalpy in TB Btu/lbm Initial Steam Mass Flow Rate in TB Ibm/sec 451 Steam 1.4 ft 2 MS 1199.3 1199.3 2,730 0.5 ft 2 MS 1199.3 1199.3 1,027 0.3 ft MS 1199.3 1199.3 621.7 Liquid26" HD353.8 1149.8 5,154 426 Steam 1.4 ft2 MS1199.31199.3 2,730 0.5 ft 2 MS1199.31199.3 1,027 0.3 ft 2 MS 1199.3 1199.3 621.7 Liquid 20" HD 352.4 1149.8 2,949 401 Steam 1.4 ft MS 1199.3 1199.3 2,730 0.5 ft 2 MS 1199.3 1199.3 1,027 0.3 ft2 MS 1199.3 1199.3 621.7 Liquid 30"FW 430.0 1149.8 2,398 For conservatism, the enthalpies for steam line breaks are increased by -0.78% to reflect Westinghouse NSSS design parameters.
Braidwood/Byron Braidwood/Byron Stations      MU R LAR Stations MUR   LAR Response  to  RAI Response to RAI September   5,2013 September 5, 2013 Attachment, Attachment, page 5 TableA.1:
f Acronyms: MS - Main SteamHD - Heater drainFW - Feedwater TB El. 451 426 401
Table     Al:     Bounding Turbine Bounding       Turbine Building Building HELBs HELBs Initial Mass Initial    Mass Flow Flow Rates Rates and and Enthalpies Initial Initial Initial Initial      Steam Steam          Initial Initial Steam Steam Line Line        Enthalpy Enthalpy Mass  Mass    Flow  Rate TBB    ine Line                    Enthalpy' Enthalpyf          inTB in TB              inTB in TB EL. Type El. Ty p e       inett Line       (Btu/Ibm)
* Braidwood/Byron Stations MU R LAR Response to RAI September 5,2013 Attachment, page 5 Table A.1: Bounding Turbine Building HELBs Initial Mass Flow Rates and Enthalpies Initial Initial Steam Initial Steam Line Enthalpy Mass Flow Rate Line Enthalpy' inTB inTB Type Line t (Btu/Ibm) (Btullbm) (Ibm/sec)
(Btu/Ibm) (Btullbm)
Steam 1.4 te MS 1199.3 1199.3 2,730 0.5 MS 1199.3 1199.3 1,027 0.3 MS 1199.3 1199.3 621.7 Liquid 26" HD 353.8 1149.8 5,154 Steam 1.4 tt 2 MS 1199.3 1199.3 2,730 0.5 MS 1199.3 1199.3 1,027 0.3 ft2 MS 1199.3 1199.3 621.7 Liquid 20" HD 352.4 1149.8 2,949 Steam 1.4 MS 1199.3 1199.3 2,730 0.5 tt 2 MS 1199.3 1199.3 1,027 0.3 ft2 MS 1199.3 1199.3 621.7 Liquid 30"FW 430.0 1149.8 2,398 For conservatism, the enthalpies for steam line breaks are increased by -0.78% to reflect Westinghouse NSSS design parameters.
Btu/lbm           (Ibm/sec)
t Acronyms:
Ibm/sec 451 Steam 451  Steam 1.4      te 1.4 ft 2 MS MS     1199.3 1199.3         1199.3 1199.3             2,730 0.5 ft 2 MS 0.5 ftMS     1199.3 1199.3         1199.3 1199.3             1,027 1,027 0.3 ft~
MS -Main Steam HD -Heater drain FW -Feedwater}}
0.3       MS ft MS     1199.3 1199.3         1199.3 1199.3             621.7 Liquid     26" HD           353.8         1149.8             5,154 2
426 Steam 1.4 tt   ft2  MS     1199.3           1199.3             2,730 ft 2 MS 0.5 ft~          1199.3           1199.3             1,027 ft2 MS 0.3 ft2         1199.3           1199.3             621.7 Liquid     20" HD           352.4         1149.8             2,949 401 Steam 1.4 1.4 ft~  MS ft MS     1199.3           1199.3             2,730 ft2 0.5 tt 2 MS     1199.3           1199.3             1,027 0.3 ft2 MS       1199.3           1199.3             621.7 Liquid     30"FW           430.0         1149.8 1149.8             2,398 conservatism, the enthalpies
* For conservatism,       enthalpies for for steam steam line line breaks breaks are are increased by -0.78%
                    -0.78% toto reflect reflect Westinghous Westinghouse     NSSS design e NSSS   design parameters.
ft Acronyms:
MS - Main Steam Steam        HD - Heater Heater drain drain              Feedwater FW - Feedwater}}

Latest revision as of 14:51, 4 November 2019

Response to NRC HELB Audit Request for Information Supporting Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate
ML13248A519
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 09/05/2013
From: Gullott D
Exelon Generation Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-13-227, TAC ME6587, TAC ME6588, TAC ME6589, TAC ME6590
Download: ML13248A519 (8)


Text

1 Genera ti RS-13-227 RS-13-227 10 10 CFR CFR 50.90 50.90 September 5, September 5, 2013 U. S. Nuclear Regulatory U. Regulatory Commission Commission ATTN: Document Document Control Control Desk Washington,DC Washington, DC 20555-0001 Braidwood Station, Units 11 and 2 Braidwood Facility Operating Facility Operating License License Nos.

Nos. NPF-72 and NPF-77 NRC Docket Nos.

NRC Nos. STN 50-456 and STN 50-457 Byron Station, Byron Station, Units 1 and 2 FacilityOperating Facility Operating License License Nos.

Nos. NPF-37 and NPF-66 NPF-66 NRC Docket NRC Docket Nos.Nos. STN STN 50-454 and STN STN 50-455 50-455

Subject:

Response to NRC HELB Audit Request for Information

Response

Supporting Supporting Request for tor License Amendment Regarding Measurement Measurement Uncertainty Recapture Uncertainty Recapture Power Uprate

References:

1. Letter Letter from from Craig Craig Lambert Lambert (Exelon (Exelon Generation Generation Company, Company, LLC) LLC) to U. S. NRC, U. NRC, "Request "Request for License Amendment Amendment Regarding Regarding Measurement Uncertainty Uncertainty Recapture Power Power Uprate,"

Uprate," dated June 23,23, 2011 2011[ML1 1 1 790030]

[ML111790030]

2. Letter fromJ.J. S.

Letter from S. Wiebe (U.

(U. S. NRC)

NRC) to M. M. J. Pacilio (Exelon (Exelon Generation Company, LLC), "Byron Station, Unit Unit Nos.

Nos. 1 and 2, and and Braidwood Station, Units 11 and Braidwood and 22 --Request Requestfor forAdditional AdditionalInformation Information Suspension of and Suspension of Review Review of of License LicenseAmendment Amendment Request Requestfor for Power Power Uprate (TAC Nos. ME6587, ME6588, ME6589, ME6589, and and ME6590),"

ME6590)," dated December December 6, 2012 [ML12271A308]

6,2012 [ML12271A308]

3. Letter from David Letter from David M.M. Gullott Gullott(Exelon (Exelon Generation Generation Company, Company, LLC) to
u. S. NRC, U. NRC, "Additional InformationSupporting "Additional Information SupportingRequest Request for for License License Amendment Regarding Measurement Uncertainty Regarding Measurement Uncertainty Recapture Power Power Uprate," dated July Uprate," dated July5,2013 5, 2013 [RS 13-13-189] [ML13186A178]

189] [ML13186A178]

4. E-Mail from J.S.Wiebe(U.

E-Mail from J. S. Wiebe (U. S. NRC)NRC) to David David M.

M. Gullott Gullott (Exelon (Exelon Generation Company, Company, LLC), "Preliminary "Preliminary RAI RAI Regarding TB TB Bldg Bldg HELB,"

HELB," dateddatedAugust August 29, 29, 2013 2013 In Reference 1,1 , Exelon Generation Company, LLC (EGC)requested LLC (EGC) requested an amendment amendment to to Facility Operating License Nos. NPF-72, NPF-77, Facility Operating NPF-77, NPF-37 NPF-37 and andNPF-66 NPF-66for for Braidwood Braidwood Station, Units 1 and 2, andand Byron Byron Station, Units Units 11 and and 2, 2, respectively.

respectively. Specifically, Specifically,thethe proposed changes changesrevise revisethetheOperating OperatingLicense Licenseand andTechnical Technical Specifications Specifications to to implement an increase increase in in rated rated thermal thermal power power of of approximately 1.63% based based on on increased feedwater flow measurement increased feedwater flow measurement accuracy. accuracy.

In Reference Reference 2,2, the theNRC NRCrequested requestedadditional additionalinformation information(RAI)

(RAI)pertaining pertainingtotothetheHigh High Energy Line Line Break (HELB) analysis and an audit (HELB) analysis audit toto complete complete their their detailed detailedreview review ofof the the

September 5, September 5, 2013 2013 U.S. Nuclear U.S. Nuclear Regulatory Regulatory Commission Commission Page 22 Page power uprate.

power uprate. The The response responseto tothis thisRAI RAI was was provided provided in in Reference 3. On On July July 17 17 and and 18, 2013 18, 2013 the NRC NRC conducted the audit. audit. As Asfollow-up follow-up to to this audit, audit, in in Reference Reference 44 the the NRC requested NRC requested additional information information regarding the the assumed assumedTurbineTurbineBuilding BuildingHELB HELB break locations.

break locations. The response responseto tothis thisrequest requestisisprovided provided in in the the Attachment.

Attachment.

EGC has EGC has reviewed the the information information supporting aa findingfinding of no significant hazards hazards consideration and the the environmenta environmentall consideration consideration provided provided to to the the NRC NRC in in Reference Reference1.1.

The additional The additional information informationprovided providedininthisthissubmittal submittaldoes does not not affect affectthe the bases bases for concluding that concluding that the the proposed license amendment amendmentdoes doesnotnotinvolve involve aasignificant significant hazards hazards consideration. Furthermore, consideration. Furthermore,the theadditional additionalinformation information provided provided in in this submittal does does not affect not affect the the bases bases for concluding concluding that neither an environmenta environmentall impact statement impact statement nor nor an environmenta an environmentall assessment assessment needsneedsto to be beprepared preparedininconnection connection with with the proposed amendment.

There are no regulatory commitments contained in in this letter.

letter.

Should youyou have any questions questions concerning concerning thisthis letter, letter, please pleasecontact contactLeslie E. Holden Leslie E. Holden at at (630) 657-3316.

(630)

II declare declare under penalty of perjury perjury that that the the foregoing foregoing isis true true and and correct. Executed on correct. Executed on the the 51hth day 5 day ofofSeptember September 2013.

Respectfully, David M. Gullott Gullott Manager -

Manager - Licensing Licensing

Attachment:

Response

ResponsetotoNRC NRCRequest Requestfor forAdditional AdditionalInformation Information (Non-Propriet (Non-Proprietary)ary)

ATTACHMENT RESPONSE TO RESPONSE TO NRC NRC REQUEST FOR FOR ADDITIONAL INFORMATION 5, 2013 September 5,2013 (NON-PROPRIETARY)

Braidwood/Byron Braidwood/Byron Stations Stations MURMUR LARLAR Response to Response to RAI RAI September September 5, 5, 2013 2013 Attachment, Attachment, page page 1 NRC Request NRC Request According to Byron According Byron and Braidwood (BIB) UFSAR Section 3.6, piping piping failures failures postulated postulated inin BIB B/B include include high high energy energy (HE) line breaks (HELBs), HE line cracks (HELCs) and and moderate energy moderate energy lineline cracks (MELCs).

(MELCs).

Withregard With regardtotopostulated postulatedpiping pipingfailures, failures,BIB-UFSAR B/B-UFSARSection Section3.6 3.6states states that:

that.

The effects The effects ofof high high energy energy line line breaks breaks in in the the turbine turbine building have been evaluated with respect with respect to to potential potential impact impact on on safety-related safety-related equipment equipment located in in adjoining auxiliary building rooms.

auxiliary and that:

and that.

The possible The possible effects effects associated associated with with the the postulated postulated break of piping considered are loads due structural loads due to to pressurization, pressurization, increases in pressure and and temperature which which could affect environmental could environmental qualification of equipment, and and damage due to to pipe pipe whip whip and jet impingement.

B/B-UFSAR Section 3.6.1, Postulated Piping Failures in Fluid BIB-UFSAR Fluid Systems Outside Outside the the Containment, provides the criteria for postulating locations of Containment, of piping failures (HELBs, HELCs and MELCs) MELes) outside containment.

Describe in detail the postulatedpostulated piping piping failures failures andand their locations utilized their locations utilized for the analyses of analyses ofM&E release from piping located M&E release located in in the the turbine turbine building building thatthat could could affect affect safety-related equipment located safety-related located in in adjoining adjoining auxiliary auxiliary building rooms rooms and andhowhowthisthis information was used to provide input input to to the the Gothic Gothic analysis.

analysis. ifIf bounding bounding conditions conditions have been been utilized utilized for thesethese analyses analysesidentifyidentifythe thepiping pipingfailures failuresutilized, utilized,their their bounding bounding M&E M&E and andthethebounding boundinglocations locations thatthat would wouldenvelop envelop the the resulting effects effects on on the the safety safety--

related equipment located located in in adjoining adjoining auxiliary auxiliary building rooms. In Inaddition, addition,justify justifyhowhow this/ these M&Es this/these M&Es and andlocation(s) location(s) bound bound others.

others. This This justification should should include, include, but but is not not limited to, consideration considerationof ofaaHE HErelease releasenear nearaaHELBHELB damperdamperthat that would wouldallow allow pressurization of of a room while the damper is closing while is closing while another another room is not not yet pressurizing pressurizing because becauseits itsdamper damperisisfarther fartheraway awayfrom from thethe HEHE release, thereby creating aa thereby creating differential pressure across differential pressure across thethe wall wall that separates separates the the two two rooms.

Response

As As discussed discussedon onJuly July17, 2013 during 17,2013 duringthe theaudit, audit,the theTurbine Turbine Building Building(TB)(TB)HighHighEnergy EnergyLine Line Break (HELB) mitigationstrategy (HELB) mitigation strategyandand associated associated methodologies methodologies were wererevised, revised,and andaanewnewTB TB HELB analysis was performed HELB analysis performed to to address addressthe theAuxiliary AuxiliaryBuilding Building (AB) rooms/areas impacted (AS) rooms/areas impactedby by TB TB HELBs.

HELBs. However, However, the the overall overall equipment equipment qualification qualification design bases baseswereweremaintained maintained(i.e.,(i.e.,

the the qualification qualification of Class Class 11E electrical electrical equipment in the identified identified AB rooms/areas are AB rooms/areas arenot not adversely adverselyimpacted impactedby byaaTB TBHELB).

HELB). The Thenew newTB TBHELB HELBanalysis analysisconfirms confirmsthat thatthe theadjacent adjacentAB AB rooms/areas rooms/areasare aremaintained maintainedasasmild mildEnvironmental EnvironmentalQualification Qualification(EQ) (EQ) environments environmentsbased basedon on the thebounding boundingTB TBHELBs.

HELBs.

The The Byron Byron andand Braidwood Braidwood UpdatedUpdatedFinal FinalSafety SafetyAnalysis AnalysisReportReport(UFSAR)

(UFSAR)does doesnotnotexplicitly explicitly identify identify or discuss the the locations locations of of the the TBTB HELBs HELBs that need need to to be be considered consideredororanalyzed analyzedfor for their their environmental environmental impacts on the safety-related safety-related equipment equipment in in the the adjacent adjacentAB AB rooms/areas.

rooms/areas.

As As part part of of our efforts to to evaluate and resolveresolve thethe non-conformances non-conformancesassociated associatedwith withthe theexisting existing TB TB HELB HELB analysis, EGC reviewed the existing existing analysis analysis and anddetermined determinedthat thatadditional additionalline line breaks breaksshould shouldbe beconsidered consideredfor forconservatism conservatismand andtotoverify verifythat thatthethepostulated postulatedbreaksbreaksininthethe new new TBTB HELB HELB analysis would would be bounding. For ForthethenewnewTB TBHELB HELB analysis, analysis, breaks breakswerewere chosen chosenbasedbasedon onthetheresulting resultingseverity severityof ofthe thebreak break(i.e.,

(i.e.,highest highestenergy energyrelease) release)and andnotnotthe the

Braidwood/Byron Braidwood/Byron Stations MUR LAR Response to RAI

Response

September 5, 2013 September Attachment, page Attachment, page 2 potential of potential ofthe the pipe pipetoto break break (Le.,

(i.e., piping pipinganalysis analysisresultsresultswerewere not not used used to to determine determine break locations).

locations) .

In order In order to to determine determine and and verify verify that that the the bounding bounding conditions conditions have have been properly properly identified, identified, aa broader spectrum of line broader line breaks than previously considered were postulated for each elevation, elevation, conservative mass conservative mass andand energy energy(M&E) releases were (M&E) releases were determined determined for for the postulated postulated line line breaks, breaks, and evaluations were performed to determine how the postulated breaks breaks would would impact impact the environmental parameters environmental parameters in in the the adjacent AB AB rooms/areas.

rooms/areas. Consideration Consideration of this this broader spectrum of TB TB pipe pipe breaks, along with with maximizing maximizing the the M&E M&Ereleases, releases, provides provides assurance assurance that that the most challenging environments environments for for the safety-related safety-related equipment equipment in in the the adjacent adjacentAB AB rooms/areas are are determined.

determined. The Themethods methodsemployedemployedare arebriefly briefly discussed discussedbelow. below.

Postulated Bounding Line Breaks The new TB HELBanalysis TB HELB analysis considered considered a broad spectrum spectrum of of main main steam steam(MS) (MS) lineline breaks breaksand and high energy liquid high linebreaks liquid line breaks in in the the TB.TB. The breaksbreaks specifically specifically analyzed analyzed resulted resulted in in the thehighest highest combination of combination of mass mass flow rates and enthalpies, flow rates enthalpies, which which in in turn resulted in in the highest highest temperatures in temperatures in the TB and adjacent AB rooms/areas. The AB rooms/areas. The bounding bounding line line breaks breaks used usedin in the the new TB HELB HELB analysis analysis areare shown shown in in Table TableA.1. A.1.

fullyassess To fully assess what breaksbreaks would would be bounding,bounding, MS MS breaks from from the largest to the smallest smallest line line size were considered considered for for each each elevation elevation of of the TB.TB. The Thelargest largestMS MS line line break break sizesize analyzed analyzedwas was limited to limited to 1.4 1.4 ft2 ft2due duetotothe theintegral integralflow flowrestrictors restrictorsininthe thesteam steamgenerators.

generators. The smallest smallest MS MS line break line break size analyzed was 0.3 0.3 ft2,ft2 , since since the massmass flow flow rates for for this this break break represent the lowest mass mass flow flow rates for for the smallest smallest steam line and liquid line breaks considered steam line and liquid line breaks consideredininthe theTB. TB.

Additionally, Additionally, the the 0.3 0.3 ft2 ft2break breakisisthe the smallest smallest MS MS line line break break that that would would result result inin an an automatic reactor trip that requires actuation of of the safety-related safety-related equipment equipment in in adjacent adjacentAB AB rooms/areas.

rooms/areas.

Intermediate break sizes sizes werewereconsidered consideredand anda abreak breaksize sizeofof0.50.5ft2feconcurrent concurrentwith withaalosslossofof offsite power power (LOOP)

(LOOP)was was determined determined to be the limiting intermediate break.

limiting intermediate break. ThisThis break break size size results in in the maximum maximum TB pressure pressure occurringoccurring as as thetheAB AB rooms rooms fans fans attempt attemptto tostart startwhen whenthe the EDG EDG starts, resulting in a high differential differential trip. trip. This This scenario scenario represents representsthe thehighest highestM&E M&E release release associated associatedwith withthe thelongest longesttime timethat thatthetheAB ABroomroomventilation ventilation is is not not operating, operating, whichwhich in in turn leads to to the the highest highest roomroom temperatures.

temperatures.

These These three three MS MS main main steam steam lineline breaks breaks are are postulated postulated to to occur occur on on each eachTB TB elevation elevation that communicates with with an adjacent adjacent AB AB room/area (401', 426' and 451' elevations). elevations).

The liquid lines breaks liquid lines breaks evaluated represent represent the the liquid liquid lines on each each elevation elevation that that produce produce the the highest combination of of mass flow flow ratesrates and enthalpies. Although Although these thesebreaksbreaksdo donot notresult resultinin higher enthalpies enthalpies than than the theMS MS lineline breaks, breaks,they theymay mayresultresultininhigher highermass massflow flowrates, rates,which whichinin some some cases casesresultresultininfaster fasterinitial initial temperature temperature increasesincreasesininthe theTB TBandandadjacent adjacentAB AB rooms/areas.

M&E Releases Releases to to Maximize Maximize TB TB Environmental EnvironmentalConditions Conditions For each each MS MS line line break break analyzed analyzed in in the the new newTB TB HELBHELB analysis, the transient transient M&E releases M&E releases consistent consistent with with Westinghouse Westinghouse WCAP-10961, WCAP-10961 , "Steamline "Steam line Break Break Mass/Energy Mass/Energy Releases Releasesfor for Equipment Environment Qualification Environment Qualification Outside Containment," (Reference (Reference A.1) A.1) were used.

used.

Specifically, the Westinghouse Westinghouse transient transientM&E M&E releases releasesinvolve involveprogressively progressivelyincreasing increasing enthalpies enthalpies with with progressively progressively decreasing decreasingmass massflow flowrates ratesand andconservatively conservativelymaximize maximize enthalpies enthalpiesto tomaximize maximize the theeffect effectof of M&E releases on M&E releases onenvironmental environmentalqualification qualification of of equipment equipment

Braidwood/Byron Braidwood/Byron Stations MUR LAR

Response

Response to to RAI RAI September September 5, 5, 2013 2013 Attachment, Attachment, page page 33 located outside located outside containment.

containment. Westinghouse Westinghouse transient transient M&E M&Ereleases releases werewere developed developed to to bound bound Byron and Braidwood Stations, Units 1 and 2, and include Byron and Braidwood Stations, Units 1 and 2, and include additional conservatisms. additional conservatisms. The Westinghouse approach has Westinghouse has been beenapproved approvedfor forByron Byron andand Braidwood Braidwood Stations Stations by by the the NRCNRC for for maximizingthe maximizing the effect effect of ofM&E M&Ereleases releases on on environmental qualification of equipment equipment located located outside containment (References outside (References A.2, A.2, p. p. 3-4 3-4 and and A.3,A.3, p.p. 3-18).

3-18).

For each For each liquid liquid line linebreak breakevaluated, evaluated, constant constant M&E M&Ereleases releases based based on the choked choked mass massflow flow rate (Henry-Fauske Critical rate Critical FlowFlow Model)

Model)and and initial initialenthalpy enthalpywerewere used used with with one one exception; pump runout pump runout was credited for for the the FW FW lineline breaks.

breaks. Additionally, Additionally, enthalpies were conservatively conservatively maximized. Table A.1 maximized. A.1 shows the constant constant M&E releases used M&E releases usedforfor the the bounding bounding breaks.

breaks.

Specifically, ititshows Specifically, shows the the portion portion of of the the break break M&EM&Ereleasesreleases that flash to steam steamininthe theTB TB environment and environment and werewere analyzed for for the the effects effects on on the adjacent AB areas.

AB areas.

Differential Pressure Between AB Rooms Differential divisional block The divisional block walls walls (e.g.,

(e.g., walls walls between between the DivisionDivision 11 11(21)

(21) and Division 12(22) ESF Division 12(22) equipment), between the the ABAB rooms adjacent adjacent to to the the TB, TB, have havebeenbeenevaluated evaluatedfor forthe thedifferential differential pressure that pressure that may mayexistexistfollowing following a TB HELB. HELB. The The two two divisional divisional ABAB rooms are adjacent adjacentto to each other other and and each eachpairpairof of rooms roomscommunicates communicateswith withthethesame sameTB TBelevation elevationHELB HELB environment. FollowingFollowing aa TB TS HELB, HELS, the the TB TB pressurizes, pressurizes, drives drivesflow flow into into the AB AB rooms, and and pressurizes the pressurizes the ABAB rooms for for a short short time time until HELBdampers until HELB dampers between the the TB TB and and AB AB rooms close. By By applying applying the the lumped-parameter lumped-parameter (i.e., (i.e., lumped lumped volume) volume) modeling modeling in in the the GOTHIC GOTHIC analysis, the the pressurization pressurizationof ofthe theTBTB elevation elevationisisuniform; uniform; therefore thereforethe theTB TBHELBHELB environment environment outside eacheach of of the AB rooms was calculated to be the same.

AB rooms same.However, However,differential differential pressurization was calculated between between the the AB AB rooms due due toto variations variations in in the closure characteristics characteristics of of the the HELB dampers, as HELB dampers, aswell well as asdifferences differencesininAB ABroomroomvolumes volumesand andflow flow paths.

paths. InInparticular, particular,the theclosure closuretimetimeofofthe theHELB HELBdamper damperofofthe theABABroomroomfor forone onedivision divisionwas was maximized, while the closure time of the HELB damper to the AB room closure time of the HELB damper to the AB room for other division was for other division was minimized.

minimized. This results in in one one ABAB room roomreaching reachingaahigher higherpeak peak pressure pressure than the adjacent room, creating a differential pressure across differential pressure acrossthe thedivisional divisional block block wall.

wall. TheTheloadloaddueduetotothisthis differential pressure has differential pressure has been beenaccounted accountedfor forininthe thenew newdesigns designstotoreinforce reinforcethe thedivisional divisionalblockblock walls.

IfIf one divisional divisional AS AB roomroom werewere postulated postulated to to experience higher higher TB pressure pressureoutsideoutsidethe theroom, room, the the higher higher TBTS pressure pressure wouldwould result result inin higher higher differential pressure across differential pressure acrossthe theHELB HELSdamper.

damper.

The dampers dampers are are designed designedto toclose closefaster fasterwithwith increasing increasing differential pressure. The differential pressure. Thepeakpeak pressure pressure in in the the AB room would AS room wouldbe be expected expected to to be be thethe same as as analyzed analyzed due dueto tothe thefaster faster damper damper closure closure time.

time. Therefore, Therefore, basedbasedon onengineering engineeringjudgment, judgment,the theimpact impactof of aapostulated postulated higher pressure pressure outside outside one one AB AB room would would be be encompassed encompassed by by the the HELB HELB damper response response times analyzed, analyzed, (i.e.,(Le., one damper damper closes closesat atthe theminimum minimum time verses verses the the other other damper dampercloses closesatat the the maximum maximumtime). time).

Braidwood/Byron Braidwood/Byron Stations Stations MUR MUR LAR

Response

Response to to RAI September September 5,2013 5, 2013 Attachment, Attachment, page page 4

REFERENCES:

REFERENCES:

A.1 A.1 Westinghouse Report No. WCAP-10961, Westinghouse WCAP-10961, "Steamline "Steamline Break Break Mass/Energy Mass/Energy Releases Releases for Equipment Environment Equipment Environment Qualification QualificationOutside Outside Containment,"

Containment," Rev.

Rev. 1, October 1985 1985 A.2 A.2 NRC Report NRC Report No.

No. NUREG-76, NUREG-76, Supplement Supplement No. 7, "Safety Evaluation Report related No.7, related to to the the operation of Byron Station, Units operation of Byron Station, Units 1 and 2, Docket Nos. STN 50-454 and STN 50-455,"

Docket Nos. STN 50-454 and STN 50-455,"

November 1986 November A.3 NRC Report NRC Report No.

No. NUREG-1002, NUREG-1002, Supplement Supplement No. 2, "Safety No.2, "Safety Evaluation Evaluation Report Report related related toto the operation of Braidwood Station, Units Braidwood Station, Units 1 and 2, Docket Nos. 50-456 and 50-457,"

50-457,"

October 1986

Braidwood/Byron Braidwood/Byron Stations MU R LAR Stations MUR LAR Response to RAI Response to RAI September 5,2013 September 5, 2013 Attachment, Attachment, page 5 TableA.1:

Table Al: Bounding Turbine Bounding Turbine Building Building HELBs HELBs Initial Mass Initial Mass Flow Flow Rates Rates and and Enthalpies Initial Initial Initial Initial Steam Steam Initial Initial Steam Steam Line Line Enthalpy Enthalpy Mass Mass Flow Rate TBB ine Line Enthalpy' Enthalpyf inTB in TB inTB in TB EL. Type El. Ty p e inett Line (Btu/Ibm)

(Btu/Ibm) (Btullbm)

Btu/lbm (Ibm/sec)

Ibm/sec 451 Steam 451 Steam 1.4 te 1.4 ft 2 MS MS 1199.3 1199.3 1199.3 1199.3 2,730 0.5 ft 2 MS 0.5 ft~ MS 1199.3 1199.3 1199.3 1199.3 1,027 1,027 0.3 ft~

0.3 MS ft MS 1199.3 1199.3 1199.3 1199.3 621.7 Liquid 26" HD 353.8 1149.8 5,154 2

426 Steam 1.4 tt ft2 MS 1199.3 1199.3 2,730 ft 2 MS 0.5 ft~ 1199.3 1199.3 1,027 ft2 MS 0.3 ft2 1199.3 1199.3 621.7 Liquid 20" HD 352.4 1149.8 2,949 401 Steam 1.4 1.4 ft~ MS ft MS 1199.3 1199.3 2,730 ft2 0.5 tt 2 MS 1199.3 1199.3 1,027 0.3 ft2 MS 1199.3 1199.3 621.7 Liquid 30"FW 430.0 1149.8 1149.8 2,398 conservatism, the enthalpies

  • For conservatism, enthalpies for for steam steam line line breaks breaks are are increased by -0.78%

-0.78% toto reflect reflect Westinghous Westinghouse NSSS design e NSSS design parameters.

ft Acronyms:

MS - Main Steam Steam HD - Heater Heater drain drain Feedwater FW - Feedwater