ML060380407

RAI Re Response to Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized-Water Reactors.

ML060380407
Person / Time
Site:	Fort Calhoun
Issue date:	02/09/2006
From:	Wang A Plant Licensing Branch III-2
To:	Ridenoure R Omaha Public Power District
Wang A, NRR/DLPM, 415-1445
References
TAC MC4686
Download: ML060380407 (10)

Text

February 9, 2006Mr. R. T. RidenoureVice President - Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

Post Office Box 550 Fort Calhoun, Nebraska 68023-0550

SUBJECT:

FORT CALHOUN STATION, UNIT 1, REQUEST FOR ADDITIONALINFORMATION RE: RESPONSE TO GENERIC LETTER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN-BASIS ACCIDENTS AT PRESSURIZED-WATER REACTORS" (TAC NO. MC4686)

Dear Mr. Ridenoure:

On September 13, 2004, the Nuclear Regulatory Commission (NRC) issued Generic Letter(GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," as part of the NRC's efforts to assess thelikelihood that the emergency core cooling system (ECCS) and containment spray system(CSS) pumps at domestic pressurized water reactors (PWRs) would experience a debris-induced loss of net positive suction head margin during sump recirculation. The NRC issuedthis GL to all PWR licensees to request that addressees (1) perform a mechanistic evaluation using an NRC-approved methodology of the potential for the adverse effects of post-accidentdebris blockage and operation with debris-laden fluids to impede or prevent the recirculation functions of the ECCS and CSS following all postulated accidents for which the recirculation of these systems is required, and (2) implement any plant modifications that the above evaluationidentifies as being necessary to ensure system functionality. Addressees were also required tosubmit information specified in GL 2004-02 to the NRC in accordance with Title 10 of the Codeof Federal Regulations Section 50.54(f). Additionally, in the GL, the NRC establis hed aschedule for the submittal of the written responses and the completion of any corrective actions identified while complying with the requests in the GL.By letter dated March 4, 2005, as supplemented by letters dated August 1 and August 31,2005, Omaha Public Power District provided a response to the GL. The NRC staff is reviewingand evaluating your response along with the responses from all PWR licensees. The NRC staffhas determined that responses to the questions in the enclosure to this letter are necessary in order for the staff to complete its review. Please note that the Office of Nuclear Reactor Regulation's Division of Component Integrity is st ill conducting its initial reviews with respect tocoatings. Although some initial coatings questions are included in the enclosure to this letter, the NRC might issue an additional request for information regarding coatings issues in the nearfuture.

R. T. Ridenoure-2-Please provide your response within 60 days from the date of this letter. If you have anyquestions, please contact me at (301) 415-1445.Sincerely,/RA/Alan B. Wang, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-285

Enclosure:

Request for Additional Informationcc w/encl: see next page R. T. Ridenoure-2-Please provide your response within 60 days from the date of this letter. If you have anyquestions, please contact me at (301) 415-1445.Sincerely,/RA/

Alan B. Wang, Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-285

Enclosure:

Request for Additional Informationcc w/encl: see next pageDistribution

PUBLICRidsNrrDorlDprRArchitzel LPLIV Reading FileWBatemanTHaffera RidsNrrDorlLpgRidsNrrPMJHopkinsJLehning RidsNrrLALFeizollahiRidsNrrDorlHWagage RidsNrrPMAWangMMurphySLu RidsOgcRpPKleinJHannon RidsAcrsAcnwMailCenterMYoderMScott RidsRgn4MailCenter (DGraves)BSingal, DORL DPRAccession No.: ML060380407* per e-mailOFFICELPL4/PMLPL4/LADSS/SSIBDCI/CSGBLPL4/BCNAMEAWangLFeizollahiDSolorio*EMurphy*DTerao DATE02/07/0602/07/062/6/0602/08/0602/09/06OFFICIAL RECORD COPY EnclosureGL 2004-02 RAI QuestionsPlant Materials1.(Not Applicable).2.Identify the amounts (i.e., surface area) of the following materials that are: (a) submerged in the containment pool following a loss-of-coolant accident (LOCA),

(b) in the containment spray zone following a LOCA: - aluminum- zinc (from galvanized steel and from inorganic zinc coatings)

- copper

- carbon steel not coated

- uncoated concreteCompare the amounts of these materials in the submerged and spray zones at yourplant relative to the scaled amounts of these materials used in the Nuclear Regulatory Commission (NRC) nuclear industry jointly-sponsored Integrated Chemical Effects Tests(ICET) (e.g., 5x the amount of uncoated carbon steel assumed for the ICETs). 3.Identify the amount (surface area) and material (e.g., aluminum) for any scaffoldingstored in containment. Indicate the amount, if any, that would be submerged in the containment pool following a LOCA. Clarify if scaffolding material was included in the response to Question 2.4.Provide the type and amount of any metallic paints or non-stainless steel insulationjacketing (not included in the response to Question 2) that would be either submerged or subjected to containment spray.Containment Pool Chemistry 5.Provide the expected containment pool pH during the emergency core cooli ng syst em(ECCS) recirculation mission time following a LOCA at the beginning of the fuel cycleand at the end of the fuel cycle. Identify any key assumptions.6.For the ICET environment that is the most similar to your plant conditions, compare theexpected containment pool conditions to the ICET conditions for the following items:

boron concentration, buffering agent concentration, and pH. Identify any othersignificant differences between the ICET environment and the expected plant-specificenvironment.7.(Not Applicable). Plant-Specific Chemical Effects8.Discuss your overall strategy to evaluate potential chemical effects includingdemonstrating that, with chemical effects considered, there is sufficient net positive suction head (NPSH) margin available during the ECCS mission time. Provide an estimated date with milestones for the completion of all chemical effects evaluations.9.Identify, if applicable, any plans to remove certain materials from the containmentbuilding and/or to make a change from the existing chemicals that buffer containment pool pH following a LOCA.10.If bench-top testing is being used to inform plant-specific head loss testing, indicate howthe bench-top test parameters (e.g., buffering agent concentrations, pH, materials, etc.)

compare to your plant conditions. Describe your plans for addressing uncertainties related to head loss from chemical effects including, but not limited to, use of chemical surrogates, scaling of sample size and test durations. Discuss how it will be determi ned that allowances made for chemical effects are conservative.Plant Environment Specific 11.Provide a detailed description of any testing that has been or will be performed as partof a plant-specific chemical effects assessment. Identify the vendor, if applicable, that will be performing the testing. Identify the environment (e.g., borated water at pH 9,deionized water, tap water) and test temperature for any plant-specific head loss or transport tests. Discuss how any differences between these test environments and your plant containment pool conditions could affect the behavior of chemical surrogates.

Discuss the criteria that will be used to demonstrate that chemical surrogates producedfor testing (e.g., head loss, flume) behave in a similar manner physically and chemically as in the ICET environment and plant containment pool environment.12.For your plant-specific environment, provide the maximum projected head loss resultingfrom chemical effects (a) within the first day following a LOCA, and (b) during the entire ECCS recirculation mission time. If the response to this question will be based ontesting that is either planned or in progress, provide an estimated date for providing this information to the NRC.ICET 1 and ICET 5 Plants 13.(Not Applicable).Trisodium Phosphate (TSP) Plants 14.Given the results from the ICET #3 tests (Agencywide Document Access andManagement System (ADAMS) Accession No. ML053040533) and NRC-sponsoredhead loss tests (Information Notice 2005-26 and Supplement 1), estimate the concentration of dissolved calcium that would exist in your containment pool from all containment sources (e.g., concrete and materials such as calcium silicate, MariniteŽ, mineral wool, kaylo) following a large-break loss-of-coolant accident (LBLOCA) anddiscuss any ramifications related to the evaluation of chemical effects and downstream effects.15.(Not Applicable).

16.(Not Applicable).Additional Chemical Effects Questions 17.(Not Applicable).18.(Not Applicable).

19.(Not Applicable).

20.(Not Applicable).

21.(Not Applicable).

22.(Not Applicable).

23.(Not Applicable).

24.(Not Applicable).Coatings Generic - All Plants25.Describe how your coatings assessment was used to identify degradedqualified/acceptable coatings and determine the amount of debris that will result fromthese coatings. This should include how the assessment technique(s) demonstrates that qualified/acceptable coatings remain in compliance with plant licensing requirements for design-basis accident (DBA) performance. If current examination techniques cannot demonstrate the coatings' ability to meet plant licensing requirementsfor DBA performance, licensees should describe an augmented testing and inspection program that provides assurance that the qualified/acceptable coatings continue to meetDBA performance requirements. Alternatively, assume all containment coatings fail and describe the potential for this debris to transport to the sump.Plant Specific26.(Not Applicable).

27.(Not Applicable).

28.(Not Applicable). 29.(Not Applicable).30.The NRC staff's safety evaluation (SE) addresses two distinct scenarios for formation ofa fiber bed on the sump screen surface. For a thin bed case, the SE states that all coatings debris should be treated as particulate and assumes 100% transport to the sump screen. For the case in which no thin bed is formed, the staff's SE states that the coatings debris should be sized based on plant-specific analyses for debris generated from within the ZOI and from outside the ZOI, or that a default chip size equivalent to the area of the sump screen openings should be used (Section 3.4.3.6). Describe how your coatings debris characteristics are modeled to account for your plant-specific fiber bed (i.e. thin bed or no thin bed). If your analysis considers both a thin bed and a non-thin bed case, discuss the coatings debris characteristics assumed for each case. If your analysis deviates from the coatings debris characteristics described in the staff-approved methodology, provide justification to support your assumptions.31.You indicated that you would be evaluating downstream effects in accordance withWCAP 16406-P. The NRC is currently involved in discussions with the WestinghouseOwner's Group (WOG) to address questions/concerns regarding this WCAP on a generic basis, and some of these discussions may resolve issues related to your particular station. The following issues have the potential for generic resolution; however, if a generic resolution cannot be obtained, plant-specific resolution will berequired. As such, formal RAIs will not be issued on these topics at this time, but maybe needed in the future. It is expected that your final evaluation response willspecifically address those portions of the WCAP used, their applicability, and exceptionstaken to the WCAP. For your information, topics under ongoing discussion include:ee.Wear rates of pump-wetted materials and the effect of wear on componentoperationff.Settling of debris in low flow areas downstream of the strainer or credit forfiltering leading to a change in fluid compositiongg.Volume of debris injected into the reactor vessel and core region hh.Debris types and properties ii.Contribution of in-vessel velocity profile to the formation of a debris bed or clog jj.Fluid and metal component temperature impact kk.Gravitational and temperature gradients ll.Debris and boron precipitation effects mm.ECCS injection paths nn.Core bypass design features oo.Radiation and chemical considerations pp.Debris adhesion to solid surfaces qq.Thermodynamic properties of coolant32.Existing calculations have been performed to support crediting containmentoverpressure in NPSH margin calculations for a one-day period following a LOCA.

During the pilot audit review, the staff noted that containment overpressure was cited asa possible source of margin to provide relief against chemical effects, which might cause increasing head loss over a timeframe from days to weeks. The staff also noted that, in the GL response, a potential license amendment to change the methodology forcrediting overpressure was discussed. Will the revised methodology analyze extendingoverpressure credit beyond the one-day period currently analyzed, to the timeframe of days or weeks over which chemical effects head loss might act?33.During the pilot audit review, the NRC staff noted a potential nonconservatism in that therefueling cavity drains were not explicitly modeled in the CFD analysis. The staff also observed, during the pilot audit review, that the potential exists that other significantsources of nonuniformity in the spray drainage pattern might exist. Will the CFDcalculation be updated to account for refueling cavity drainage and/or any other potentially significant sources of concentrated containment spray or other waterdrainage into the containment pool? 34.During the pilot audit review, the staff noted that debris settling (i.e., the near-fieldeffect) was credited to support the design basis of the proposed replacement strainers.

Please estimate the fraction of debris that settled and describe any analyses (beyond the limited generally qualitative information provided during the pilot audit) that were performed to correlate the scaled flow conditions and any surrogate debris in the test flume with the actual flow conditions and debris types in the plant's containment pool.35.Are there any vents or other penetrations through the strainer control surfaces whichconnect the volume internal to the strainer to the containment atmosphere above the containment minimum water level? In this case, dependent upon the containment pool height and strainer and sump geometries, the presence of the vent line or penetration could prevent a water seal over the entire strainer surface from ever forming; or else this seal could be lost once the head loss across the debris bed exceeds a certain criterion, such as the submergence depth of the vent line or penetration. According to Appendix A to Regulatory Guide 1.82, Revision 3, without a water seal across the entirestrainer surface, the strainer should not be considered to be "fully submerged."

Therefore, if applicable, explain what sump strainer failure criteria are being applied for the "vented sump" scenario described above.36.The staff noted that the GL response stated that the licensee is evaluating a possiblemodification to the refueling cavity and reactor cavity drain caps to minimize potential debris blockage. Please confirm whether or not this modification will be performed. Inaddition, the staff requests that the licensee describe the potential types andcharacteristics of debris that could reach these drains. In particular, could large pieces of debris be blown into the upper containment by pipe breaks occurring in the lower containment, and subsequently drop into the cavity? 37.What is the minimum strainer submergence during the postulated LOCA? At the timethat the re-circulation starts, most of the strainer surface is expected to be clean, and the strainer surface close to the pump suction line may experience higher fluid flow than the rest of the strainer. Has any analysis been done to evaluate the possibility of vortexformation close to the pump suction line and possible air ingestion into the ECCS pumps? In addition, has any analysis or test been performed to evaluate the possible accumulation of buoyant debris on top of the strainer, which may cause the formation ofan air flow path directly through the strainer surface and reduce the effectiveness of the strainer?38.You submitted its computational fluid dynamics (CFD) calculation performed using aFLOW-3D computer code and the NRC staff reviewed it as part of a pilot plant audit. However, the September 2005 GL response noted that OPPD used a different computercode, Fluent, for CFD analysis. Please identify major changes made to CFD modeling with the computer code change.39.The September 2005 GL response noted that you are considering testing to determinecalcium silicate debris transportability. If the testing is used to design the sump scr een,please summarize the basis, results, and conclusions of the testing and how you apply testing for the design.All other RAIs that were provided previously as part of the pilot audit process need to beanswered for completeness.

Ft. Calhoun Station, Unit 1 cc:Winston & Strawn ATTN: James R. Curtiss, Esq.

1400 L Street, N.W.

Washington, DC 20005-3502ChairmanWashington County Board of Supervisors

P.O. Box 466 Blair, NE 68008Mr. John Hanna, Resident InspectorU.S. Nuclear Regulatory Commission

P.O. Box 310 Fort Calhoun, NE 68023Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007Mr. David J. Bannister, ManagerFort Calhoun Station Omaha Public Power District Fort Calhoun Station FC-1-1 Plant

P.O. Box 550 Fort Calhoun, NE 68023-0550Mr. Joe L. McManisManager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 550 Fort Calhoun, NE 68023-0550Mr. Daniel K. McGheeBureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319