UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

Mr. Joseph W. Shea 

Vice President, Nuclear Licensing 

Tennessee Valley Authority 

September 18, 2014 

1101 Market Street, LP 3D-C 

Chattanooga, Tennessee, TN 37402-2801 

SUBJECT: WATTS BAR NUCLEAR STATION, UNIT 2, CLOSEOUT OF GENERIC 

LETTER 2004-02, "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON 

EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS 

AT PRESSURIZED-WATER REACTORS" (TAC NO. MD5560) 

Dear Mr. Shea: 

The U.S. Nuclear Regulatory (NRC) issued Generic Letter (GL) 2004-02, "Potential Impact of 

Debris Blockage on Emergency Recirculation During Design Basis Accidents at 

Pressurized-Water Reactors" (Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML042360586) dated September 13, 2004, requesting that licensees 

address the issues raised by Generic Safety Issue 191, "Assessment of Debris Accumulation on 

Pressurized Water Reactor Sump Performance." 

The stated purpose of GL 2004-02 was focused on demonstrating compliance with Title 1 0 of 

the Code of Federal Regulations (1 0 CFR) Part 50 Section 50.46, "Acceptance Criteria for 

Emergency Core Cooling Systems for Light Water Reactors." Specifically the GL requested 

addressees to perform an evaluation of the emergency core cooling system (ECCS) and 

containment spray system (CSS) recirculation and, if necessary take additional action to ensure 

system function, in light of the potential susceptibility of pressurized-water reactor sump screens 

to blockage during a design-basis accident requiring recirculation operation of the ECCS or 

CSS, and on the potential for additional adverse effects due to debris blockage of flowpaths 

necessary for ECCS and CSS recirculation and containment drainage. 

By letter dated March 4, 2011 (ADAMS Accession No. ML 11 0680248), pursuant to the current 

application for an operating license at Watts Bar Nuclear Plant (WBN), Unit 2, the Tennessee 

Valley Authority (TVA) provided its response to GL 2004-02, "Potential Impact of Debris 

Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water 

Reactors," for WBN Unit 2. The March 4, 2011, letter supersedes TVA's September 10, 2010, 

response (ML 1 02580175) to GL 2004-02, including the commitments that were included in that 

response. Further, responding to requests for additional information and additional evaluation 

guidance provided by the NRC staff, TVA provided additional information by letters dated April 

29, 2011 (ML 11124A083); May 17, 2012 (ML12143A345); and September 16, 2013 

(ML 13262A270). 

In its September 16, 20131etter, TVA stated that the following actions still need to be completed 

for WBN Unit 2; (1) install sump modifications per the requirements of GL 2004-02 prior to 

Unit 2 fuel load, (2) complete a confirmatory walkdown for loose debris after containment work 

is complete, prior to start-up, to ensure that potential quantities of post-accident debris are 
J. Shea - 2 -

maintained within the bounds of the analyses and design-bases that support ECCS and CSS 

recirculation functions, and (3) install new throttle valves in the chemical volume control system 

and safety injection system lines to the reactor coolant system, opened sufficiently to preclude 

downstream blockage. The above required actions are confirmatory inspection items. 

The NRC staff performed a thorough review of the TVA responses to GL 2004-02 and 

concluded that TVA's response to GL 2004-02 is acceptable. The NRC staff conclusions have 

been documented in the enclosure. Based on the NRC staff conclusions, the NRC staff finds 

the information provided demonstrates that debris will not inhibit the ECCS or CSS performance 

of its intended function in accordance with 10 CFR 50.46 to assure adequate long term core 

cooling following a design-basis accident. Therefore, the NRC staff finds the licensee's 

responses to GL 2004-04 are adequate and pending completion of the confirmatory items 

discussed above, considers GL 2004-02 closed for the WBN Unit 2. No further information or 

action is requested of the applicant. 

If you have any questions, please call me at 301-415-2048 or via e-mail at 

Justin.Poole@nrc.gov. 

Docket No. 50-391 

cc w/ enclosure: distribution via Listserv 

Justin C. Poole, Senior Project Manager 

Watts Bar Special Projects Branch 

Division of Operating Reactor Licensing 

Office of Nuclear Reactor Regulation 
NUCLEAR REGULATORY COMMISSION STAFF REVIEW OF THE DOCUMENTATION 

PROVIDED BY TENNESSEE VALLEY AUTHORITY FOR WATTS BAR NUCLEAR PLANT, 

UNIT 2 CONCERNING RESOLUTION OF GENERIC LETTER 2004-02, "POTENTIAL IMPACT 

OF DEBRIS BLOCKAGE ON 

EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT 

PRESSURIZED-WATER REACTORS" 

1.0 INTRODUCTION 

In September 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," to holders of operating licenses for 

Pressurized Water Reactors (PWRs), requesting that the licensees perform an evaluation of 

their emergency core cooling systems (ECCS) and containment spray system (CSS) 

recirculation functions considering the potential for debris-laden coolant to be circulated by the 

ECCS and the CSS after a loss-of-coolant accident (LOCA) or high energy line break (HELB) 

inside containment and, if appropriate, take additional action to ensure system function. The GL 

required that licensees of operating PWRs provide the NRC a written response describing the 

results of their evaluation and any modifications made, or planned, to ensure system function. 

The Tennessee Valley Authority (TVA or the applicant) submitted a response to the GL for 

Watts Bar Nuclear Plant (WBN) Unit 1. That response is under NRC staff review. Holders of 

construction permits (CPs), such as WBN Unit 2, were not required to respond to the GL. 

On August 3, 2007, TVA informed the NRC that it intended to reactivate construction and 

licensing activities for WBN Unit 2. Therefore, in response to direction provided by the 

Commission in its Staff Requirements Memorandum (SAM), SRM-SECY-07-0096, "Staff 

Requirements- Possible Reactivation of Construction and Licensing Activities for the Watts Bar 

Nuclear Plant, Unit 2," dated July 25, 2007 (Agencywide Documents Management System 

(ADAMS) Accession No. ML072060688), the staff established the foundation of a licensing 

review approach that employs the current licensing basis for WBN Unit 1 as the reference basis 

for the review and licensing of WBN Unit 2 (WBN Unit 2 is a mirror image of WBN Unit 1 ). This 

approach is described in SECY -09-0012, "Status of Reactivation of Construction and Licensing 

Activities for Watts Bar Nuclear Plant Unit 2" (ADAMS Accession No. ML0831 00090). In 

implementing this approach, the staff has formulated the activity topics that remain to be 

evaluated, along with the framework for the outstanding reviews of generic communications 

issues and other special programs. GL 2004-02 is included in this review category. 

Therefore, by letter dated March 4, 2011 (Reference 1 ), pursuant to the current application for 

an operating license at WBN Unit 2, TVA provided a response to GL 2004-02, for WBN Unit 2. 

Enclosure 
- 2 -

The March 4, 2011, letter supersedes TVA's September 10, 201 0, letter (Reference 2) 

regarding GL 2004-02, including the commitments that were included in that letter. TVA's 

March 4 letter includes four enclosures consisting of the following: (1) TVA's evaluation of 

GL 2004-02, based on the guidance provided by the NRC in a letter from W. H. Ruland, NRC, to 

A. Pietrangelo, Nuclear Energy Institute (NEI), "Revised Content Guide for Generic Letter 

2004-02 Supplemental Responses," dated November 21, 2007 (Reference 3); (2) a description 

of the open items related to the NRC staff's audit of the WBN Unit 1 GL 2004-02 closure efforts, 

as they apply to WBN Unit 2 (Reference 4); (3) responses to Requests for Additional 

Information (RAis) related to the GL 2004-02 closure efforts for WBN Unit 1, as they apply to 

WBN Unit 2 (References 5 and 6); and (4) a list of regulatory commitments related to the 

closure of GL 2004-02 at WBN Unit 2. By letters dated April 29, 2011 (Reference 7), May 17, 

2012 (Reference 8), and September 16, 2013 (Reference 9), TVA provided additional 

information in response to (1) RAis prepared by NRC staff (References 10 and 11 ), 

(2) additional evaluation criteria/guidance provided by NRC staff in a letter to NEI on May 2, 

2012 (Reference 12), and (3) issuance of Westinghouse Topical Report (TR) 

WCAP-16793-NP-A, Revision 2 (Reference 13). 

2.0 REGULATORY EVALUATION 

2.1 System Function 

The function of the ECCS at WBN Unit 2 is to supply cooling water to the reactor core following 

a LOCA to cool the reactor fuel and maintain it in a geometry that can be cooled. The function 

of the CSS at WBN Unit 2 is to remove heat from the containment building after a LOCA. 

The ECCS and CSS operating conditions involve the circulation of water that has been spilled 

onto the basement floor of the containment building (through a break in the reactor coolant 

system (RCS) pipe, and by spray from the CSS) back to the reactor and/or containment spray 

headers after being cooled by the residual heat removal (RHR) system heat exchangers. In the 

circulation mode of operation with the replacement strainers in place, water from the 

containment pool is drawn through one recirculation strainer assembly that feeds a common 

suction sump via a plenum. The single strainer assembly consists of 23 vertically oriented 

strainer stacks-14 of the stacks are 5.52 feet tall and the remaining stacks are 4.81 feet tall. 

The 23 strainers provide a total of 4675 square feet of strainer area. Flow leaves each of the 

strainers where it enters a rectangular, horizontally oriented, collection plenum that is positioned 

over the top of the sump pit. The WBN Unit 2 sump strainer design is the same as that used for 

WBN Unit 1, except that the strainer stack-to-plenum opening is increased for WBN Unit 2 to 

reduce the strainer pressure drop, thus providing margin to plugging when compared to the 

WBN Unit 1 strainer. 

Because water is drawn from the containment pool, there is a potential for LOCA generated 

debris and latent debris to be transported to ECCS sump strainers. This debris could block 

adequate flow through the strainer or pass through the strainer and prevent the ECCS or CSS 

equipment from performing their safety functions. 

2.2 Requested Action 

GL 2004-02 requested holders of operating licenses for PWRs (e.g., WBN Unit 1) to perform a 

mechanistic evaluation, using an NRC-accepted method, of the potential for the adverse effects 
- 3 -

of post-accident debris blockage and operation with debris-laden fluid to impede or prevent the 

recirculation function of the ECCS and CSS following all postulated accidents for which the 

recirculation of these systems is required. The GL also requested that holders of operating 

licenses for PWRs implement plant modifications that the evaluation identifies as being 

necessary to ensure system functionality, and provide information regarding planned actions 

and the schedule for completing the requested evaluation. The GL requested that addressees 

provide information that includes the following: 

a. A description of the method that is used, or will be used, to analyze the susceptibility of the 

ECCS and CSS recirculation functions for the applicant's reactor to the adverse effects 

identified in this GL of post-accident debris blockage and operation with debris-laden fluids 

identified in this GL. 

b. A statement of whether the applicant plans to perform a containment building walkdown 

surveillance in support of the analysis of the susceptibility of the ECCS and CSS 

recirculation functions to the adverse effects of debris blockage identified in this GL. 

Provide justification if no containment walkdown surveillance will be performed. If a 

containment building walkdown surveillance will be performed, state the planned method to 

be used and the planned completion date. 

c. Confirmation that the ECCS and CSS recirculation functions under debris loading conditions 

are or will be in compliance with the regulatory requirements listed in the Applicable 

Regulatory Requirements Section of this GL. This submittal should address the 

configuration of the plant that will exist once all modifications required for regulatory 

compliance have been made and the licensing basis has been updated to reflect the results 

of the analysis described above. 

d. A general description of and implementation schedule for all corrective actions, including 

any plant modifications that the applicant identified while responding to this GL. 

e. A description of the method that was used to perform the analysis of the susceptibility of the 

ECCS and CSS recirculation functions to the adverse effects of post-accident debris 

blockage and operation with debris-laden fluids. 

The submittal may reference a guidance document (e.g., Regulatory Guide (RG) 1.82, 

Rev. 3), industry guidance, or other methods previously submitted to, and accepted by the 

NRC. The documents to be submitted or referenced should include, at a minimum, the 

following information: 

i. The results of any supporting containment walkdown surveillances performed to identify 

potential debris sources and other pertinent containment characteristics. 

ii. The minimum available net positive suction head (NPSH) margin for the ECCS and CSS 

pumps assuming an unblocked sump screen. 

iii. The submerged area of the sump screen at this time and the percent of submergence of 

the sump screen (i.e., partial or full) at the time of the switchover to sump recirculation. 
- 4-

iv. The maximum head loss postulated from debris accumulation on the submerged sump 

screen, and a description of the primary constituents of the debris bed that result in this 

head loss. In addition to debris generated by jet forces from the pipe rupture, debris 

created by the resulting containment environment (thermal and chemical) and CSS 

washdown should be considered in the analyses. Examples of this type of debris are 

disbanded coatings in the form of chips and particulates and chemical precipitants 

caused by chemical reactions in the pool. 

v. The basis for concluding that the water inventory required to ensure adequate ECCS or 

CSS circulation would not be held up or diverted by debris blockage at choke-points in 

containment ECCS sump return flowpaths. 

vi. The basis for concluding that inadequate core or containment cooling would not result 

due to debris blockage at flow restrictions in the ECCS and CSS flow paths downstream 

of the sump screen (e.g., a high-pressure safety injection (HPSI) system throttle valve, 

pump bearing or seal; fuel assembly inlet debris screen; or containment spray nozzles). 

The discussion should consider the adequacy of the sump screen mesh spacing and 

state the basis for concluding that adverse gaps or breaches are not present on the 

screen surface. 

vii. Verification that close-tolerance subcomponents in pumps, valves and other ECCS and 

CSS components are not susceptible to plugging or excessive wear due to extended 

post-accident operation with debris-laden fluids. 

viii. Verification that the strength of the trash racks is adequate to protect the debris screens 

from missiles and other large debris. The submittal should also provide verification that 

the trash racks and sump screens are capable of withstanding the loads imposed by 

expanding jets, missiles, the accumulation of debris, and pressure differentials caused 

by post-LOCA blockage under predicted flow conditions. 

ix. If an active approach (e.g., back-flushing, powered screens) is selected in lieu of or in 

addition to a passive approach to mitigate the effects of the debris blockage, describe 

the approach and associated analyses. 

f. A description of the existing or planned programmatic controls that will ensure that potential 

sources of debris introduced into containment (e.g., insulations, signs, coatings, and foreign 

materials) will be assessed for potential adverse effects on the ECCS and CSS recirculation 

functions. 

2.3 Review Method 

The NEI developed an evaluation guidance document titled "PWR [Pressurized-Water Reactor] 

Containment Evaluation Methodology-Baseline Evaluation" (Reference 14). The NRC issued 

a safety evaluation (SE) of that document (Reference 15). The final guidance, titled 

"Pressurized Water Reactor Sump Performance Evaluation Methodology," was subsequently 

issued in December of 2004 as NEI 04-07. Volume 1 of NEI 04-07 is titled "Pressurized Water 

Reactor Sump Performance Evaluation Methodology" (Reference 16) and Volume 2 is titled 

"Safety Evaluation by the Office of Nuclear Reactor Regulation Related to NRC Generic Letter 

2004-02," Revision 0, dated December 6, 2004 (Reference 17). Together, these two volumes 
- 5 -

describe a method acceptable to NRC staff for performing the evaluations requested by 

GL 2004-02. 

In a letter from J. C. Butler to the NRC dated December 22, 2011 (Reference 18), NEI proposed 

additional guidance that plants with little or no fibrous debris in the circulated coolant could use 

to expeditiously close Generic Safety Issue (GSI)-191. The NRC staff reviewed the NEI 

proposed "Clean Plant" criteria and found that the guidance, as clarified in NRC letter from W. 

Ruland to J. C. Butler, dated May 2, 2012 (Reference 12), provides an acceptable method for 

closing GSI-191 for operating PWRs. The NRC letter (Reference 12) required that licensees 

that use the "Clean Plant" criteria supplement their GL 2004-02 submittal with information that 

describes the basis for the fiber levels to be used in the plant licensing basis. 

The NEI proposed "Clean Plant" criteria focusses on two aspects of debris plugging: 

containment sump strainer blockage and core blockage. The NRC clarification letter 

(Reference 12) states that licensees that adopt the "Clean Plant" criteria also need to address 

the other areas identified in the revised content guide (Reference 3). WBN Unit 2 is crediting 

the clean plant criteria for the in-vessel downstream-effects portion of the GSI-191 evaluation. 

Sump strainer blockage is evaluated by testing. 

In addition to the evaluation guidance of NEI 04-07 and the "Clean Plant" criteria, the industry 

developed the following topical reports to aid licensees in responding to the GL. 

1. Westinghouse Topical Report WCAP-16530-NP-A, "Evaluation of Post-Accident 

Chemical Effects in Containment Sump Fluids to Support GSI-191 ," March 2008. 

(Reference 19) 

2. Westinghouse Topical Report WCAP-16406-P-A, "Evaluation of Downstream Sump 

Debris Effects in Support of GSI-191 ," Revision 1, March 2008. (Reference 20) 

3. Westinghouse Topical Report WCAP-16793-NP-A, "Evaluation of Long-Term Cooling 

Considering Particulate, Fibrous and Chemical Debris in the Recirculating Fluid," 

Revision 2, July 2013. (Reference 13) 

The NRC Staff determined that the reports listed above, subject to the conditions and limitation 

contained in the NRC SEs for those documents, describe a method acceptable to NRC staff for 

performing the evaluations and analyses within the scope stated in those documents. The NRC 

determined that the "Clean Plant" criteria guidance, as clarified in Reference 12, is an 

acceptable method for addressing sump strainer blockage and core blockage. WBN Unit 2 

references the "Clean Plant" criteria only for the core blockage evaluation. 

To communicate the NRC staff's expectations for the level of technical detail in the licensees' 

submittals, the NRC staff issued "Revised Content Guide for Generic Letter 2004-02 

Supplemental Responses," dated November 2007 (Reference 3) and "Revised Guidance for 

Review of Final Licensee Responses to Generic Letter 2004-02, Potential Impact of Debris 

Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized Water 

Reactors," dated March 28, 2008 (Reference 21 ). The following technical evaluation addresses 

each critical evaluation parameter (review area) in the sequence listed in the revised content 

guide. 
- 6-

3.0 TECHNICAL EVALUATION 

3.1 ECCS and CSS Description 

During the initial phase of a LOCA at WBN Unit 2, the ECCS and CSS pumps draw water from 

the refueling water storage tank (RWST). Upon exhaustion of this water source, the pump inlets 

are realigned to take suction from the ECCS sump located in the basement of the containment 

building. The applicant provided the following description of the operation of the ECCS and 

CSS. 

In response to a safety injection (SI) signal, the RHR pumps, centrifugal charging 

pumps (CCP) and Sl pumps automatically start injecting water from the RWST. 

The CSS pumps start if containment pressure reaches a predetermined setpoint. 

The CSS pumps also inject water from the RWST. When the RWST level 

reaches a low-level setpoint, the RHR pump suction is realigned to take suction 

from the ECCS sump (referred to as ECCS switchover). After ECCS switchover, 

the CSS pump suction is also realigned to the ECCS sump. The system 

response to a small-break loss-of-coolant accident (SBLOCA) is different from 

the large-break loss-of-coolant accident (LBLOCA) response. Depending on the 

break size, the primary system pressure may stabilize at a value too high to allow 

Sl pump or RHR pump injection. Additionally, containment pressure may remain 

below the CSS setpoint. For these cases, depletion of the RWST may be slow 

enough that the RCS is cooled down prior to the need for circulation from the 

ECCS sump. 

TVA stated in its March 4, 2011, letter that prior to fuel load, WBN Unit 2 will install sump 

modifications per the requirements of GL 2004-02 that are very similar to the modifications 

made for WBN Unit 1. The WBN Unit 2 sump strainer design is the same as that used for WBN 

Unit 1, with minor modifications. The strainers are manufactured by Performance Contracting, 

Inc. (PCI) and are of a stacked-disk design. The strainers are comprised of a series of 

approximately 1-inch thick disks covered with a stainless steel skin that is perforated with 0.085-

inch-diameter holes. The discs are stacked on top of each other and are connected through a 

central flow channel to form a strainer module. The central channel collects the water and 

routes it to a manifold that connects to the ECCS and CSS pump suction piping. The total 

strainer area is approximately 4675 square feet. The strainer modules are installed vertically on 

the floor of the containment such that the disks are horizontally oriented. In its September 16, 

2013, letter (Reference 9), TVA reaffirmed that new sump strainers will be installed prior to fuel 

load and stated that the installation was a confirmatory inspection item. 

3.2 Review of Evaluations 

3.2.1 Break Selection 

The objective of the break selection evaluation is to identify the break location that results in 

debris generation that produces the most challenging debris loads for the containment 

recirculation sump strainers. 
- 7 -

Summary of Applicant's GL 2004-02 Evaluation 

The applicant followed break selection guidance in NEI 04-07 (References 16 and 17) (which is 

similar to that in RG 1.82) to determine the potential limiting breaks for WBN Unit 2. The 

applicant stated that the only potential sources of debris in the WBN Unit 2 containment building 

are Reflective Metal Insulation (RMI), coatings, latent debris, and miscellaneous debris. The 

latent and miscellaneous debris terms are not affected by the break selection evaluation. The 

limiting break for each filtering location (screens or core) is determined by examining the debris 

generation and transport assumptions for each of the remaining debris types. 

The applicant stated that the following breaks were analyzed for WBN Unit 2: 

• Break 1: 

• Break 2: 

• Break 3: 

• Break 4: 

• Break 5: 

Locations in the RCS with the largest potential for debris generation . 

Locations with two or more different types of debris . 

Locations with the most direct path to the sump . 

Locations with the largest potential particulate to insulation ratio . 

Locations that would generate debris that could potentially form a thin-bed . 

Because the amounts of latent and miscellaneous debris generated and transported to the 

sump strainers are independent of break location, the only consideration for break selection is 

RMI and coatings debris. The applicant stated that RMI does not transport as easily as the 

particulates and is not a major contributor to head loss. Therefore, the bounding case is the one 

that results in the most destruction of coatings. The debris generation analysis completed by 

the applicant identified that a break in the crossover leg near the steam generator nozzle 

generated the most debris. All coatings in the zone of influence (ZOI) are assumed to generate 

10 micron [0.39 mils] particulates. 

The applicant stated that break locations were selected based on the accident scenarios that 

could lead to ECCS recirculation, the size of the pipe break, and the proximity of other insulated 

pipes or equipment. Secondary line breaks were considered in the evaluation but eliminated as 

bounding events. Secondary line breaks have a smaller ZOI for destruction (due to lower 

pressure), are terminated by operator action (feedwater and auxiliary feedwater isolation), and 

do not require sump recirculation for RCS decay heat removal. Only minimal intermittent 

operation of the containment spray system in the containment sump recirculation mode for long 

term containment temperature reduction may be required if other means of cooling the 

containment building are not available. 

The applicant stated that various breaks were examined to maximize the amount of debris 

generated. Each of the five problematic break locations described in the NEI 04-07 guidance 

(References 16 and 17) were discussed. The applicant used the break selection evaluation to 

determine the breaks that would result in the maximum amount of coatings debris. The 

applicant described how the selected breaks present the greatest challenge to post-LOCA sump 

performance, and stated that the largest quantity of insulation material is installed on the RCS 

and that the worst case break was selected for each of the four RCS loops. The analysis 

identified that a break in the crossover leg, near the steam generator nozzle, generated the 

most particulate debris and, therefore, is considered the limiting break. 
- 8 -

The applicant stated that secondary-side line breaks do not require recirculation for mitigation. 

Therefore, it is not necessary to include secondary-side line breaks in the break selection 

evaluation. 

Staff Review of Applicant's Evaluation 

Based on the staff review of the applicant input and the staff guidance, the staff concluded that 

the applicant had acceptably evaluated the topic. The applicant determined the worst break 

locations for RMI, and then discounted the ability of the RMI to contribute significantly to head 

loss. The applicant also identified the worst case break location for coatings. Because (1) WBN 

Unit 2 contains only RMI, coatings, and latent debris; (2) the RMI is not considered a significant 

contributor to head loss; and (3) all latent debris is assumed to transport to the strainer, the 

important break would maximize coatings debris. The coatings, combined with the fibrous and 

chemical debris, constitute the total debris load on the strainer. 

The staff finds that the spectrum of breaks evaluated is acceptable because the evaluation 

resulted in maximizing the potential problematic debris types. The applicant's procedure meets 

the intent of NEI 04-07 (Reference 16), the related SE for NEI 04-07 (Reference 17), and 

Regulatory Position C.1.3.2.3 of RG 1.82, Revision 3. The staff accepts that RMI will not 

become a significant contributor to head loss for WBN Unit 2 for the reasons cited by the 

applicant, because the strainer is installed above the floor level, and because the approach 

velocities are very low such that RMI will not transport and adhere to portions of the strainer 

located above the floor level. Additionally, the limited amount of fibrous debris in containment is 

not adequate to interact with the RMI to form a significant debris bed over the surface of the 

strainer. Therefore, the staff finds that the break selection evaluation was conducted 

adequately. The applicant stated that some mineral wool is installed inside pipe guards on the 

main feedwater line piping penetrations and also on the in-core instrument tubes that penetrate 

the crane wall. These debris sources are evaluated in Section 3.2.2 as being outside the ZOI 

and, therefore, are not available to interact with the RMI. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately identified the break locations that produce the most 

challenging debris loads for the containment circulation sump strainer. Therefore, staff 

concludes that the break selection is acceptable. 

3.2.2 Debris Generation/Zone of Influence (Excluding Coatings) 

The objective of the debris generation/ZOI process is to determine, for each postulated break 

location: (1) the zone within which the break jet forces would be sufficient to damage materials 

and create debris; and (2) the amount of debris generated by the force of the jet emanating from 

the break. 

The ZOI is the space surrounding a break in which jet forces would be sufficient to damage a 

specific material and generate debris that could be transported to the sump. Different materials 

have different ZOis because some materials are more robust than others. The debris 

generation evaluation determines the amount of debris generated by the jet forces as well as 

the debris characteristics. The debris characteristics are the important properties of this debris 
- 9 -

as they relate to the ability of the debris to transport to the sump strainer and contribute to head 

loss across it, or contribute to downstream effects. Important characteristics include the size 

distribution and material density. Debris characteristics are discussed below within this section. 

The staff considered Section 3.4 of NEI 04-07 and the related SE (References 16 and 17, 

respectively) when evaluating this section, which addresses all debris types except coatings. 

Coatings are discussed in Section 3.2.8 of this evaluation. 

NEI 04-07 recommended reshaping ZOis into spheres in order to simplify quantification of the 

amount of debris generated by each potential break. It is not anticipated that LOCA jets would 

be spherical in shape. However, the reshaping of the ZOI into a sphere with its radius 

dependent on the break size and the relative destruction pressure of the target material was 

determined to provide, in most cases, an adequate estimate or practical approximation for 

debris generation. 

Summary of Applicant's GL 2004-02 Evaluation 

a) Zone of Influence 

In its March 4, 2011, letter (Reference 1 ), the applicant stated that it followed the guidance in 

NEI 04-02 for WBN Unit 2 by assigning a ZOI of 28.6D (i.e., 28.6 times the break diameter) for 

RMI insulation. 

b) Miscellaneous Debris 

The applicant performed a walkdown of WBN Unit 1 to identify the miscellaneous material that 

could potentially block portions of the sump strainer surface area. Examples of miscellaneous 

materials are signs, tags, tape, and placards. The results of the walkdown established a 

conservative estimate of 697 square feet of miscellaneous debris. In the March 4, 2011, letter 

(Reference 1 ), the applicant stated that the WBN Unit 2 design is essentially identical to WBN 

Unit 1 and, therefore, assumed that the amount of miscellaneous debris in WBN Unit 2 would 

not exceed 1000 square feet. Based on NRC guidance that allows a 25-percent overlap of 

miscellaneous debris as it deposits on the strainer, the applicant assumed a blockage of 750 

square feet in the design and testing of the sump strainer. In a letter dated April 29, 2011 

(Reference 7), the applicant responded to NRC RAI number HLV RAI-1, clarifying that the initial 

design of the strainer considered that 750 square feet of strainer area could be blocked by 

miscellaneous debris, based on a conservative application of WBN Unit 1 walkdown information 

for miscellaneous debris. The applicant later performed testing to determine whether the 

miscellaneous debris would transport to the strainer under post-LOCA conditions. The test 

results indicated that the miscellaneous debris did not readily transport. Therefore, the 

miscellaneous debris sacrificial surface area used in testing was set at 200 square feet. 

In its March 4, 2011, letter (Reference 1 ), the applicant stated that mineral wool is installed in a 

few locations inside the WBN Unit 2 containment building, outside of any LOCA ZOI. In a letter 

dated April29, 2011 (Reference 7), the applicant responded to NRC RAI number DG RAI-1, 

clarifying that approximately 1.57 cubic feet of mineral wool is installed at the location where the 

in-core instrument tubes penetrate the crane wall, and mineral wool is also installed on the main 

feedwater lines that are located within the guard pipes routed outside of the crane wall where 

the feedwater lines penetrate the primary containment. The applicant stated that if failure of this 

material were to occur due to a LOCA, the material would be transported to the area outside the 
- 10-

crane wall and the area outside the crane wall does not communicate with the emergency sump 

that is located inside the wall. 

Staff Review of Applicant's Submittal 

The staff finds that the applicant's ZOI for RMI is consistent with the staff guidance found in 

Table 3-2 of theSE to NEI 04-07 (Reference 17). Also, based on the information provided by 

the applicant in Reference 7 regarding the location of the mineral wool insulation, the staff 

concludes that the mineral wool would not contribute to the debris load on the ECCS strainer. 

Therefore, the staff finds these ZOis are acceptable and the evaluation is adequate. 

The applicant's method for determining miscellaneous debris and its treatment is consistent with 

NEI 04-07 and the staff's SE. Therefore the staff finds the evaluation of miscellaneous debris to 

be acceptable. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has adequately determined for each postulated break location the zone within 

which the force of the jet emanating from the break would be sufficient to generate debris and 

the amount of debris that would be generated. Therefore, staff concludes that the applicant's 

evaluation of the ZOI and debris generation is acceptable. 

3.2.3 Debris Characteristics 

The objective of the debris characteristics determination process is to establish a conservative 

debris characteristics profile for use in determining the transportability of debris and its 

contribution to head loss. 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant used the NEI 04-07 guidance to determine the debris characteristics for material 

that could be damaged by a LOCA jet. The applicant stated that RMI is assumed to be 

destroyed as 75 percent small pieces and 25 percent large pieces, where small pieces are 

defined as having dimensions less than 4 inches. The applicant then discussed containment 

coatings and their application. The coatings discussed were Carbozinc 11, Carboline 295, 

Phenoline 305, and Carboline 467 4. The applicant stated that the thicknesses were assumed to 

be 10 microns [0.39 mils] and that the density values were based on manufacturer's data and 

standard references. The applicant discussed the properties of latent debris and stated that the 

properties were as assumed in the staff's SE on NEI 04-07 (Reference 17). 

Staff Review of Applicant's Evaluation 

The staff concluded that the debris characteristics used by the applicant are acceptable 

because they are consistent with the SE on NEI 04-07 for RMI and latent debris, and 

manufacturer's data and standard references for coatings. 
- 11 -

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately characterized the debris for use in determining the 

transportability of debris and its contribution to sump strainer head loss. Therefore, staff 

concludes that the applicant's evaluation of debris characteristics is acceptable. 

3.2.4 Latent Debris 

The objective of the latent debris evaluation process is to provide a reasonable approximation of 

the amount and types of latent debris existing within the containment and its potential impact on 

sump screen head loss. 

Summary of Applicant's GL 2004-02 Evaluation 

In a letter dated May 17, 2012 (Reference 8), the applicant stated that WBN Unit 2 meets the 

"Clean Plant" criteria as clarified in the NRC letter dated May 2, 2012 (Reference 12). The 

"Clean Plant" criteria are applied only to the core blockage evaluation. The strainer evaluation 

is based on strainer flow testing. The applicant's statement is supported by the description of 

the latent debris discussion contained in the March 4, 2011, letter (Reference 1) and repeated in 

the May 17, 2012, letter (Reference 8). The following is a summary of the applicant's 

evaluation. 

The applicant stated that the quantity and composition of the latent debris assumed to be in the 

WBN Unit 2 containment building at the time of commercial operation is based on the results 

obtained during the WBN Unit 1 quantitative latent debris walkdown. The WBN Unit 1 

walkdown was based on the as-found conditions at the start of a refueling outage. The 

walkdown involved the collection of debris samples from 26 locations inside the containment 

building, selected to provide a representative sample of the latent debris present in the 

containment building. The sample collection area for each location varied in size from 1.3 to 

104.5 square feet. The samples collected were analyzed for both quantity and type of debris. 

The latent debris from the sampled areas was then projected for the entire containment building 

based on the total amount of surfaces similar to those surveyed. The applicant stated that a 

similar confirmatory walkdown for loose debris will be performed on WBN Unit 2 after 

containment work is completed and the containment has been cleaned. This walkdown will be 

completed prior to startup. 

The applicant stated that the latent debris walkdown on WBN Unit 1 found small quantities of 

particulate debris such as dust, dirt, paint chips, wood chips, concrete chips, metal shavings, 

metal washers, nails, screws, wire powder, tape, and miscellaneous artifacts that equated to a 

quantity of 69.2 pounds projected to the total containment area. The samples contained only a 

few fibers and string material, resulting in an estimated fiber loading of 1 percent (total of 

approximately 0.7 pounds for the entire containment). The applicant cited Section 3.5.2.2 of 

NEI-04-07 that states that the maximum quantity of latent debris inside containment would 

be 200 pounds. Therefore, WBN Unit 1 assumed a maximum latent debris load of 200 pounds 

in its analyses. Further, consistent with the guidance provided in the NRC SE for NEI-04-07 

(Reference 17), the latent debris characteristics were assumed to be as follows: 
- 12-

• fiber contributes 15 percent of the mass of the total latent debris inventory with 

particulate contributing the remaining 85 percent; 

• latent fiber material has an average density of 94 pounds per cubic feet; 

• latent particulate material has a nominal density of 169 pounds per cubic feet; 

• latent fiber material has an as-manufactured density (dry bed bulk density) of 2.4 pounds 

per cubic feet 

• latent fiber has the same diameter as commercial fiberglass (7 11m (0.27 mil) for Nukon 

per NUREG/CR-6224). 

The applicant stated that the latent debris survey results confirmed that the assumptions 

described above are conservative with respect to both the composition and the quantity of the 

actual latent debris in the WBN Unit 2 containment buildings. 

For WBN Unit 2, the applicant applied the same assumptions as for WBN Unit 1 except that the 

applicant assumed a maximum latent debris load of 1 00 pounds, based on the WBN Unit 1 

walkdown results. [This translates to latent fiber load of 15 pounds in containment.] The 

applicant stated that a confirmatory walkdown for loose debris will be performed on WBN Unit 2 

after containment work is completed and the containment cleaned. This walkdown will be 

completed prior to startup. 

To address latent debris in the form of signs, placards, tags, tape, and similar miscellaneous 

materials, the applicant stated that a sacrificial strainer surface area of 750 square feet 

(1 000 square feet times 0.75 loading factor) has been established. In a letter dated April 29, 

2011 (Reference 7), the applicant responded to NRC RAI number HLV RAI-1, clarifying that the 

initial design of the strainer considered that 750 square feet of strainer area could be blocked by 

miscellaneous debris, based on a conservative application of WBN Unit 1 walkdown information 

for miscellaneous debris. The applicant later performed testing to determine whether the 

miscellaneous debris would transport to the strainer under post-LOCA conditions. The test 

results indicated that the miscellaneous debris did not readily transport. Therefore, the 

miscellaneous debris sacrificial area used in testing was set at 200 square feet. 

Staff Review of Applicant's Evaluation 

The NRC staff reviewed the applicant's response and considered the general approach to be 

consistent with the guidance specified in NEI 04-07 (Reference 16), including the NRC SE 

(Reference 17) of that document. 

The applicant's latent debris evaluation is reasonable and is based on results from a WBN 

Unit 1 latent debris survey. The WBN Unit 2 assumption for latent debris amount is half of the 

WBN Unit 1 amount, but still below the WBN Unit 1 survey amount. Further, for a zero fiber 

plant, the assumption of 100 pounds of latent debris (15 pounds fiber, which is the most critical 

term) is reasonable. The 15 pound maximum fiber load inside containment also satisfies the 

"Clean Plant" criteria that are applied to the in-vessel evaluation. The assumption of 

1 000 square feet of miscellaneous debris is conservatively high compared to most plants and 

well above the value found during a WBN Unit 1 walkdown. The WBN Unit 2 survey should 

validate that the containment is as clean as assumed for this evaluation. 
- 13-

Based on the staff review of the applicant's evaluation and the staff guidance, and an 

application of the guidance to the response, the staff concluded that latent debris assumptions 

are adequate because there is some margin between the estimated amount of latent debris and 

the latent debris amount used in the evaluation. However, the staff notes that the magnitude of 

the margin does not leave significant operational margin for the site. In addition, the applicant 

has not yet completed construction of the plant and has not performed the latent debris survey 

of the WBN Unit 2 containment building. 

Commitments 

In Enclosure 4 of the March 4, 2011, letter, under commitment number 2, the applicant stated 

that a confirmatory walkdown for loose debris will be performed on WBN Unit 2 after 

containment work is completed and the containment has been cleaned. This walkdown will be 

completed prior to startup. In its September 16, 2013, letter (Reference 9), TVA reaffirmed that 

the walkdown will be completed prior to start-up and stated that the action was a confirmatory 

inspection item. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately identified the amount and types of latent debris existing 

within the containment and its potential impact on sump screen head loss. Therefore, staff 

concludes that the applicant's evaluation of latent debris is acceptable. 

3.2.5 Debris Transport 

The objective of the debris transport evaluation process is to estimate the fraction of debris that 

would be transported from debris sources within containment to the sump suction strainers. 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant's method for evaluating debris transport at WBN involves the estimation of the 

fraction of debris that is transported from debris sources (which can depend on break location) 

to the sump screens. The four major debris transport modes used in the WBN methods are: 

• Slowdown transport: the vertical and horizontal transport of debris to all areas of 

containment by the break jet. 

• Washdown spray transport: the vertical (downward) transport of debris by the 

containment sprays and break flow. 

• Pool fill transport: the horizontal transport of debris by break and containment spray 

flows from the refueling water storage tank to areas that may be active or inactive during 

recirculation. 

• Recirculation transport: the horizontal transport of debris from the active portions of the 

recirculation pool to the sump screen by the flow through the ECCS and CSS. 

The applicant analyzed the specific effect of each mode of transport for each type of debris 

generated and developed a logic tree to determine the total transport to the sump screens. The 
- 14-

purpose of this approach is to break a complicated transport problem down into specific smaller 

problems that can be more easily analyzed. 

The debris transport analysis was based on the NEI 04-07 guidance report for refined analyses 

(Reference 16), as supplemented by the associated NRC SE (Reference 17), as well as the 

refined methodologies suggested by Appendices Ill, IV, and VI of theSE. The general 

arrangement inside the WBN Unit 1 and WBN Unit 2 containments are mirror images and the 

pump capacities and flow rates are the same. Thus, the applicant stated that the WBN Unit 1 

transport analysis applies to WBN Unit 2. 

The applicant built a three-dimensional model of the containment building using computer aided 

drafting software, collected and calculated input parameters to support a computational fluid 

dynamic (CFD) simulation of containment pool flows during the recirculation phase of the LOCA, 

performed a CFD analysis, and used the CFD results, along with the analysis of blowdown, 

washdown, and pool fill, to define transport fractions using a logic tree approach. The applicant 

stated that no transport assumptions deviated from the approved guidance. The applicant 

stated that the CFD code used was Flow-3D, Version 8.2. Flow-3D is a commercially available 

general-purpose computer code for modeling of dynamic behavior of liquids and gases 

influenced by a wide variety of physical processes. The program is based on the fundamental 

laws of mass, momentum and energy conservation. It has been constructed for the treatment of 

time-dependent multi-dimensional problems and is applicable to most flow processes. ALl ON 

Science and Technology (TVA Contractor) validated and verified Version 8.2 of Flow-3D under 

its Quality Assurance program. Various aspects of the inputs and modeling assumptions were 

provided in the response. As a conservative measure, the applicant did not credit debris 

interceptors in its transport analysis. Based on the method summarized above, the applicant 

calculated a worst case debris transport rate of 96 percent for fibrous debris and 48 percent 

overall for RMI. A bounding quantity of debris at the strainers was applied using the most 

limiting amount of each debris type from each of the four reactor coolant loop break locations 

examined. In establishing the debris quantities at the strainer, the applicant used conservatively 

higher transport fractions for RMI and fibrous debris (71 percent and 1 00 percent, respectively) 

based on an earlier analysis that remained bounding. 

Staff Review of Applicant's Evaluation 

The NRC staff reviewed the applicant's response and considers the general approach taken by 

the applicant to be consistent with the guidance specified in NEI 04-07. In particular, consistent 

with the approved guidance, the applicant did not credit settlement of fine debris. All debris 

types, other than RMI, were considered to consist of fines, resulting in 100 percent transport for 

all debris other than RMI (i.e., latent debris and coatings particulate). The transport percentage 

calculated for RMI is conservative, based on the results of the CFD analyses as well as not 

crediting debris interception. This calculation is not directly relevant for acceptance of strainer 

performance because RMI was not added to the strainer qualification testing, due to its inability 

to climb onto and adhere to strainer surfaces as well as its potential to lower the test measured 

head loss when it is transported to the strainer. 

The NRC staff concluded that the debris transport evaluation prepared by the applicant, as 

summarized above, is acceptable because the general approach taken by the applicant is 

consistent with NEI 04-07 (Reference 16), and the NRC SE of that document (Reference 17), 

and because the associated debris transport results have been conservatively calculated. 
- 15-

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately estimated the fraction of debris that would be transported 

from debris sources within containment to the sump suction strainers. Therefore, staff 

concludes that the applicant's evaluation of debris transport is acceptable. 

3.2.6 Head Loss and Vortexing 

The objectives of the head loss and vortexing evaluations are to calculate head loss across the 

sump strainer and to evaluate the possibility of a vortex to form above the strainer. 

Summary of Applicant's GL 2004-02 Evaluation 

In a letter dated May 17, 2012 (Reference 8), the applicant stated that the WBN Unit 2 plant 

currently meets the "Clean Plant" criteria with respect to strainer head loss by strainer head loss 

testing as accepted by NRC staff in a letter dated May 2, 2012 (Reference 12). The WBN Unit 2 

strainer and the head loss testing of the strainer are described below. Although WBN Unit 2 

meets the "Clean Plant" criteria, the licensing basis for the strainer is based on head loss 

testing. 

WBN Unit 2 has one recirculation strainer assembly that feeds a common suction sump via a 

plenum. The single strainer assembly consists of 23 vertically oriented strainer stacks, 14 of the 

stacks are 5.52 feet tall and the remaining stacks are 4.81 feet tall. The 23 strainers provide a 

total of 4675 square feet of flow area. Flow leaves each of the strainers where it enters a 

rectangular, horizontally oriented, collection plenum that is positioned over the top of the sump 

pit. The WBN Unit 2 sump strainer design is the same as that used for WBN Unit 1, except that 

the strainer stack-to-plenum opening was increased for WBN Unit 2 to reduce the strainer 

pressure drop, thus providing margin to plugging when compared to the WBN Unit 1 strainer. 

TVA applied the head loss and vortexing test results obtained during the WBN Unit 1 strainer 

testing to WBN Unit 2. The applicant stated that WBN Unit 1 conducted head loss testing using 

debris loads and flow rates specific to WBN Unit 1 to demonstrate the adequacy of the WBN 

Unit 1 containment sump strainers. Tests were designed to determine the maximum head loss 

that could develop across the strainer with the design basis debris loading. The applicant stated 

that the WBN Unit 1 debris loads bound the WBN Unit 2 debris loads because WBN Unit 2 does 

not contain two of the problematic materials found in WBN Unit 1-Min-K® insulation and 

lnteram® fire.barrier. The debris used in the latest series of WBN Unit 1 head-loss evaluations 

consisted of particulate, fiber, lnteram, Min-K, and chemical precipitates. Additionally, the 

evaluation assumed that a portion of the strainer could be blocked by miscellaneous materials. 

Sump strainer testing was conducted using a test strainer consisting of an array of four modules 

of the same design as the plant modules. Testing used a debris load scaled from the plant 

design basis load to the test strainer surface area. Flow through the test strainer was also 

scaled to the test strainer surface area. For test scaling purposes, the applicant reduced the 

strainer area to account for the potential for miscellaneous materials to block a portion of the 

strainer. In the March 4, 2011, letter (Reference 1 ), Section 3.b, the applicant stated that WBN 

Unit 2 assumed that the amount of miscellaneous debris would not exceed 1000 square feet 
- 16-

and based on a 25 percent overlap of miscellaneous debris deposited on the strainer, the 

applicant assumed a blockage of 750 square feet for design and testing of the sump strainer. In 

a letter dated April 29, 2011 (Reference 7), TVA responded to NRC RAI number HLV RAI-1, 

clarifying that the initial design of the strainer considered that 750 square feet of strainer area 

could be blocked by miscellaneous debris, based on a conservative application of WBN Unit 1 

walkdown information for miscellaneous debris. The applicant later performed testing to 

determine whether the miscellaneous debris would transport to the strainer under post-LOCA 

conditions. The test results indicated that the miscellaneous debris did not readily transport. 

Therefore, the miscellaneous debris was not included in the test and an area of 200 square feet 

was subtracted from the total strainer area as margin for the testing. 

Testing was performed at Alden Research Laboratory, Inc.; AREVA NP, Inc. (AREVA) provided 

technical and logistical support for the testing. The NRC staff witnessed one of the tests and 

found the method used during testing acceptable. However, the test witnessed by staff (Test 4) 

resulted in excessive head loss across the debris bed. The staff's findings are documented in a 

memorandum from S. J. Smith to M. L. Scott dated August 19, 2010 (Reference 22). The 

applicant conducted two additional tests (48 and 4C) with reduced debris loads. The final test, 

Test 4C, was conducted using the WBN Unit 2 design basis debris load, plus lnteram® firebarrier material that is not installed in WBN Unit 2 but will likely remain installed in WBN Unit 1. 

The applicant stated that Test 4C is the design basis test for WBN Unit 2. The test is 

considered to be conservative for WBN Unit 2 because it contained significant amounts of 

problematic material that will not be in WBN Unit 2 and, therefore, will not be part of the WBN 

Unit 2 design basis debris load. 

The test facility was designed to add sufficient turbulence to minimize any settling of debris in 

the tank to ensure that the majority of debris transported to the strainer during the test. The test 

facility also implemented features to ensure that debris characteristics were consistent with 

testing guidance and were well mixed and diluted prior to reaching the strainer. 

Prior to the introduction of debris, clean strainer head loss (CSHL) measurements were 

attained. The tested clean strainer head loss value is used to correct test head loss 

measurements to ensure that only debris head loss is reported. Note that a calculated CSHL 

for the plant is added to the measured debris head loss to determine the overall plant head loss. 

The flow rate for the testing was scaled based on the strainer design maximum flow rate 

of 19,100 gallons per minute. The CSHL was calculated to be 0.338 feet of water. 

After the CSHL for the test arrangement is determined, debris is added to the loop according to 

the test plan. Particulate debris surrogates are added first, followed by fibrous debris and 

finally, chemical debris surrogates. Flow and head loss parameters are continuously monitored 

and recorded during the test. Details of a test performed for WBN Unit 1 that is similar to the 

WBN Unit 2 test is documented in a NRC staff trip report dated August 19, 2010 (Reference 22). 

The applicant provided additional details on Test 4C (the design basis test for WBN Unit 2) as 

well as the test method described in their March 2011 letter on GL 2004-02 (Reference 1 ). 

The final debris head loss determined by Test 4C was 1.88 feet of water. Applying a viscosity 

correction factor to account for a post-LOCA water temperature of 190 °F, the applicant 

calculated the expected head loss to be 1.09 feet of water at the onset of circulation. 
- 17-

The applicant stated that the calculations for sump water level validate that the strainers will be 

submerged under all conditions during which circulation could be required. There are two 

different height strainer stacks installed in the WBN Unit 2 containment building. Under the 

most limiting conditions the tall strainers are submerged by at least 0.26 foot. The shorter 

strainer stacks are submerged by at least 0.97 foot. The applicant stated that the strainers 

remain submerged under all accident scenarios. 

The applicant provided information regarding the potential for vortex formation, a condition 

under which air could be drawn into the suction of the pumps that are drawing water from the 

strainer. The original sump intake structure contained vortex prevention features that were 

shown by scaled testing to be effective. The sump intake had to be modified to attach the new 

strainer assemblies, but the vortex suppression features were retained. The applicant's 

evaluation also stated that the construction of the strainer would prevent vortices from forming 

because of the multiple components within the strainer that reduce the probability of vortex 

formation. The applicant stated that the flow velocity near the strainer was 50 percent of that 

required to initiate air ingestion. Although the staff did not validate the applicant's calculation, 

the staff concludes (based on the submergence information contained in the applicant's 

evaluation and on observations of head loss testing at prototypical submergence and flow rates) 

that a vortex would not form. The applicant also stated that air ingestion would likely be less 

than 2 percent and that it would remain less than 3 percent at expected containment conditions. 

The applicant provided information regarding the ability of the strainer to accommodate the 

maximum amount of debris predicted to arrive at the screen, and information regarding the 

ability of the strainer to handle the formation of a thin bed without developing excessive head 

loss. The design basis debris load calculated for WBN Unit 2 does not challenge the maximum 

debris load performance of the strainer because the quantity of fibrous debris in the containment 

building is small compared to the strainer area. The testing conducted for WBN Unit 2 resulted 

in a thin bed because the amount of fiber in the design basis debris load is small. The resulting 

head loss did not cause a challenge to NPSH margins for the ECCS or CSS pumps. In a letter 

dated April 29, 2011 (Reference 7), the applicant responded to NRC RAI number HLV RAI-2, by 

providing a plot of the head-loss versus time data (Figure 6-6 from AREVA document 

66-9144025-000 'Watts Bar, Unit 1 Emergency Core Cooling System Strainer Performance 

Test report") for the entire duration of Test 4C. The applicant also stated that a thin-bed test, 

representing the design-basis test for WBN Unit 2, was performed on July 16, 2010. 

The applicant provided information regarding the method used to determine the total strainer 

head loss. The debris head loss from the head loss testing discussed in this section was added 

to the calculated CSHL. The final viscosity-corrected debris head loss was calculated to 

be 1.09 feet of water at a temperature of 190 °F. The scaling was based on a straight 

temperature/viscosity correction. The applicant stated that flow sweeps were conducted to 

verify that the flow through the debris bed was laminar and that no pressure driven bed 

discontinuities were present. Therefore, the total strainer head loss including debris and clean 

strainer components is 1.428 feet of water. 

In a letter dated April 29, 2011 (Reference 7), the applicant responded to NRC RAI number HLV 

RAI-3, by describing, the method used to perform the extrapolation of test data to the required 

mission time. The response included excerpts from a vendor calculation that performed the 

extrapolation. The response included a graph of the last portion of the head loss test and a 

linear fit of the data near the end of the test. The data show that the head loss was stable and 
- 18-

not increasing or decreasing at the end of the test. The final head loss value is high enough 

that the statistically significant data taken during the test are bounded by the value. 

The applicant stated that near-field settling was not credited during testing. The testing 

performed for WBN Unit 1 and WBN Unit 2, discussed above, has been reviewed and found to 

be acceptable from a near-field settlement perspective. 

The applicant stated that containment accident pressure was not credited in evaluating the 

potential for flashing across the debris bed. 

Staff Review of Applicant's Evaluation 

The staff evaluated the applicant's GL 2004-02 response against the March 28, 2008, guidance 

for head loss and vortexing and chemical effects as (Reference 21 ). 

WBN Unit 2 has a relatively large strainer and a small, non-problematic debris source term. The 

design basis debris load for the strainer is unlikely to result in high head losses because (1) the 

debris mix contains no fibrous debris (except latent), (2) historically problematic debris 

generating materials are not present within the containment building, and (3) the strainer is 

relatively large. Even if a small amount of additional debris were added to the source term the 

strainer would likely function adequately under post-LOCA conditions. The staff has adequate 

assurance that the strainer will perform its function without adding significant head loss to the 

ECCS and CSS pump suction. This assurance is based on the large strainer, small debris 

source term, and lack of problematic materials within the containment building. The staff also 

considered its knowledge of numerous strainer tests at varying debris loads and conservatism 

present in the applicant's evaluation. The staff also noted that the WBN Unit 2 strainer design 

basis head loss test included problematic material that will not present in the WBN Unit 2 

containment. 

The applicant's RAI response number HLV RAI-1 in its letter dated April 29, 2011 (Reference 7), 

clarifying the apparent discrepancy in the sacrificial area assigned to account for miscellaneous 

debris, is found to be acceptable based on staff's observations of similar transport testing 

performed by other licensees. The staff finds that the applicant's testing program was 

conducted properly because similar tests have shown that the majority of miscellaneous debris 

does not readily transport under typical post-LOCA conditions. Therefore, the inclusion of 

200 square feet of sacrificial area is adequate to account for any miscellaneous debris that 

enters the pool near the strainer such that it could transport to the strainer and block part of the 

strainer area. Therefore, the staff finds the response to this RAI acceptable. 

The staff reviewed the applicant evaluations supporting the conclusion that (1) a vortex would 

not form at the strainer such that air could be drawn into the suction of the pumps, and (2) that 

air ingestion would likely be less than 2 percent and would remain less than 3 percent at 

expected containment post-LOCA conditions. The staff concluded that vortex formation for the 

WBN Unit 2 strainers would not occur since the strainers are fully submerged under all 

conditions when recirculation is required. The staff's conclusion is based on previously 

accepted vortex evaluations for similar strainers and plant-specific testing for the WBN Unit 1 

and WBN Unit 2 strainers. Further, the staff recognizes that the WBN Unit 2 strainer is of a 

uniform flow design and, therefore, the flow through the strainer surfaces is equalized so that no 
- 19-

one section of the strainer incurs significantly higher velocities than the average for the strainer. 

Preventing areas of high flow reduces the potential for vortex formation. 

The applicant's statement that air ingestion will be limited was confirmed by staff. Staff 

performed a calculation using bounding conditions for WBN Unit 2 and determined that 

deaeration would not contribute significantly to air ingestion. Additionally, based on strainer 

testing, the formation of a vortex and subsequent air ingestion is not expected. Therefore, the 

staff concluded that air ingestion from these sources will not adversely affect ECCS or CSS 

pump performance. 

The staff reviewed the applicant's sump strainer head loss evaluation, including the applicant's 

response to RAI number HLV RAI-2 in the applicant's letter dated April29, 2011 (Reference 7). 

The staff reviewed the head loss plot provided in the RAI response and determined that the 

head-loss test did not exhibit any behavior that would cause the staff to question the applicant's 

test results or the use of those results as applied to the WBN Unit 2 strainer evaluation. 

Therefore, the staff finds the results of the test and the application of the results acceptable. 

The staff reviewed the applicant's evaluation of the susceptibility of the strainer to thin-bed 

formation that could result in excess head loss. The staff performed a calculation for the 

potential theoretical bed thickness for the WBN Unit 2 strainer. Considering that latent debris 

provides the only fibrous source term for the strainer, and that all the latent fiber reaches the 

strainer, the calculated theoretical bed thickness is about 0.02 inch. Although the staff has not 

defined a theoretical bed thickness below which a filtering bed cannot form, a 0.02-inch thick 

bed would likely not result in a filtering bed over a significant portion of the strainer. Therefore, 

the staff finds the applicant's evaluation acceptable. 

Staff reviewed the applicant's calculation of the CSHL and found that the applicant used 

methods acceptable to the staff. Therefore, the calculation is considered to be satisfactory. 

The staff reviewed the applicant's method used to determine the total strainer head loss, adding 

the head loss obtained from testing with debris to the calculated CSHL and correcting for 

viscosity changes due to temperature. The staff validated that a correction from 120 degrees 

Fahrenheit (°F) (test temperature) to 190 oF (design temperature) would result in a viscosity 

corrected head loss of the magnitude stated by the applicant. Therefore, the staff accepts the 

applicant's viscosity correction method since it was conducted per staff guidance. The staff 

finds that the applicant's calculated total head loss of 1.428 feet of water is acceptable. 

The staff reviewed the applicant's method for extrapolating the test results to the 30-day mission 

time, as described in response to RAI number HLV RAI-3 in the applicant's letter dated 

April 29, 2011 (Reference 7). The staff agreed with the applicant's statement that the final head 

loss value is high enough that the statistically significant data taken during the test are bounded 

by the value. Therefore, the staff finds the applicant's extrapolation acceptable. 

The staff reviewed the applicant's position of not taking credit for containment accident pressure 

when evaluating the potential for flashing across the debris bed. The staff concluded that 

because the debris source term for the plant is small (resulting in little head loss) and the 

maximum sump temperature is predicted to be 190 oF (significant subcooling), flashing across 

the strainer would not occur. The staff also considered that by the time a debris bed forms on 
-20-

the strainer, the temperature would likely be reduced, resulting in additional subcooling such 

that flashing will not occur. Therefore, not crediting accident pressure is conservative. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately determined the head loss across the sump strainer and 

evaluated the potential for formation of a vortex at the strainer. Therefore, staff concludes that 

the applicant's evaluation of head loss and vortexing is acceptable. 

3.2.7 Net Positive Suction Head 

The objective of the NPSH evaluation is to validate that the plant design provides adequate 

margin between the NPSH available and the NPSH required for each pump taking suction from 

the recirculation sump. The evaluation calculates the NPSH available at the pump suctions and 

compares it to a manufacturer's value for NPSH required. The available NPSH is affected by 

several factors; including the elevation of the containment pool surface, elevation of the pump 

suction, friction losses in the piping, temperature of the water, and head loss through the 

strainer. 

The NRC staff's acceptance criteria for the analysis of the available NPSH to the ECCS and 

CSS pumps are based on the guidance and regulatory requirements described in Section 6.2.2, 

"Containment Heat Removal Systems," of the Standard Review Plan (SRP), NUREG-0800 

(Reference 23). 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant provided the pump flow rates for the pumps taking suction from the ECCS sump. 

There are two ECCS trains and two CSS trains. Each ECCS train is capable of a flow of 

5000 gallons per minute. Each CSS train is capable of 4600 gallons per minute flow. Other 

assumptions and inputs to the NPSH calculation are as follows: 

• Both trains of RHR and CSS are in service 

• Sump fluid temperature is 190 oF 

• Containment pressure is zero pound-per-square-inch, gage 

• The SBLOCA evaluation uses the sump level at the time of RHR switchover to 

recirculation 

• The SBLOCA evaluation assumes full 5000 gallons per minute RHR flow even though 

the flow will be less 

• The full CSS flow (4600 gallons per minute, per train) is assumed for all cases 

The applicant stated that the required ECCS and CSS pump NPSH required values were 

determined by factory testing and that the testing typically used a decrease in pump head of 

3 percent to define NPSH required. 

The applicant used a computer flow simulation model to determine the suction line piping losses 

for the ECCS and CSS pumps. The applicant stated that the input parameters conservatively 
- 21 -

maximized flow through the piping to establish the bounding friction losses used in the NPSH 

analysis. 

The applicant stated that the limiting single failure assumption for transients that require 

containment sump recirculation is the complete loss of one train of ECCS equipment. 

The applicant described the method used to determine the containment sump levels listed in the 

NPSH section of his evaluation. The process calculated the minimum volume of water available 

from various sources for different scenarios, subtracted potential water holdup volumes from the 

source total, and finally determined the lower containment free volume that would be filled by 

the inventory. The potential water sources, depending on the scenario, are the RCS, cold leg 

accumulators, RWST, and ice melt from the ice condensers. Volumes that could trap or holdup 

water are the reactor cavity, operating floor, refueling canal, containment atmosphere, CSS 

piping, and the pocket sump. The applicant also stated that for the LBLOCA, water volume 

greater than 367,000 gallons in the sump would spill into a raceway where it would no longer be 

available for recirculation. No spillage is calculated to occur prior to ECCS recirculation. The 

assumptions were made to ensure that the water level credited for the NPSH and strainer 

evaluations is minimized for added conservatism. 

The assumptions for the minimum water level evaluation are as follows: 

• During the injection phase, ECCS and CSS pump flows are maximized. This minimizes 

the time to switchover and minimizes the contribution from ice melt. The applicant 

stated that this minimizes the sump level at both the ECCS switchover point (RWST low 

level) and the CSS switchover point (RWST low-low level). 

• The initial water level in the RWST is the "minimum full" level. 

• Water droplet size remains constant and was chosen to maximize the amount of water 

held up in the containment atmosphere. 

• The lower containment volume was reduced to account for equipment and structures in 

the lower containment. 

• All CSS flow is assumed to fall onto the operating deck prior to flowing into the refueling 

canal. This maximizes holdup on the operating deck. 

Additional assumptions for the SBLOCA are as follows: 

• Two SBLOCA cases were evaluated; a 120 gallon per minute break and a 2000 gallon 

per minute break. 

• Limited credit is taken for ice melt for the SBLOCA. 

• The break flow is assumed to fill the reactor cavity first, thus minimizing volume reaching 

the containment sump. 

• The volume of accumulators is not added to the sump inventory. 

• The only credit taken for RCS volume added to the inventory is based on the assumed 

break flow rate {120 or 2000 gallons per minute). 
-22-

The applicant provided the following table summarizing the sources for sump pool inventory. 

Sump Recirculation Pool Source Inventory Summary (RHR switchover) 

SBLOCA SBLOCA 

(high flow (low flow 

LBLOCA rate( 1

l) rate(2l) 

Primary System Inventory (gallon) 50,500 0 0 

Cold Leg Accumulator lnventory(gallons) 22,900 0 0 

RWST Inventory to ECCS switchover (gallons) 202,000 202,575 202,575 

Ice Melt Inventory (gallons) 147,240 46,516 3,048 

Total (gallons) 422,640 249,091 205,623 

Notes: 1. Volume based on 2000 gallons per minute flow rate through pipe break. 

2. Volume based on 120 gallons per minute flow rate through pipe break. 

The applicant stated that no credit is taken for accident pressure in the determination of NPSH 

available for pumps taking suction from the containment sump. The assumption is that the 

containment pressure remains at the minimum internal building pressure of 14.3 pounds per 

square inch, absolute. The maximum calculated sump temperature of 190 oF is used for the 

NPSH available calculations. The NPSH calculations assume that the vapor pressure of the 

water is 9.34 pounds per square inch, absolute, which corresponds to the maximum sump 

temperature of 190 °F. 

The applicant provided the most limiting NPSH margins calculated for the RHR and CSS pumps 

for two separate points in time following a LOCA. At RHR switchover, the NPSH margin 

is 10.5 feet of water for the RHR pumps and 4.8 feet of water for the CSS pumps. Note that the 

CSS pumps are not taking suction from the recirculation sump at this time so the CSS NPSH 

margin is for information only. At CSS switchover, the NPSH margin is 8.5 feet of water for the 

CSS pumps and 14.2 feet of water for the RHR pumps. Per Enclosure 2, Open Item 4, of 

Reference 1, these values include sump strainer and debris head losses. Additionally, the 

values indicate that the NPSH margins increase as time progresses due to the increase in sump 

pool elevation. 

Staff Review of Applicant's Evaluation 

NRC staff reviewed the applicant's assumptions used to determine the ECCS and CSS pump 

flow rates and the required pump NPSH, as described above, and determined that the 

assumptions meet staff guidance and, in some cases, represent conservatism with respect to 

the guidance documents. 

The staff also evaluated the applicant's use of computer models to calculate the line losses in 

the ECCS and CSS pump suction lines. The staff found these methods acceptable as the staff 

accepts the use of hand calculations and computer models for determination of hydraulic flow 

losses in piping systems. 

The staff reviewed the criteria used by the licensee to determine the ECCS and CSS flow rates 

through the sump strainer. Although the applicant stated that the limiting single failure 

assumption for transients that require containment sump recirculation is the complete loss of a 

train of ECCS equipment, the applicant performed the head loss evaluation using maximum flow 
- 23-

rates assuming both trains of ECCS and CSS operating. The staff notes that assuming a failure 

of single train is limiting from the perspective of core cooling, but from a strainer head loss 

perspective, maintaining operation of all the pumps is more limiting. Because the applicant 

performed the head loss evaluation using maximum flow rates (all trains operating), the staff 

finds the evaluation acceptable. 

The staff reviewed the applicant's method for determining the containment sump water level and 

determined that the applicant properly accounted for the sources of water and the water hold-up 

volumes. The staff considers the calculated minimum water level to be conservative. 

The staff reviewed the applicant's assumptions and inputs for calculating the available NPSH for 

the ECCS and CSS pump, including the applicant's decision to not credit containment accident 

pressure. The staff finds that these assumptions are in accordance with staff guidance for 

calculating the available NPSH and, therefore, are acceptable. The staff noted that the margins 

reported for RHR switchover time and CSS switchover time were not consistent with the strainer 

submergence values reported in Section 3.f.2 of Enclosure 1 of the WBN Unit 2 response 

(Reference 1 ). For the limiting case (SBLOCA), the minimum sump level is stated to increase 

from 5. 78 feet at the time of initiation of ECCS recirculation to 6.91 feet at the time of initiation of 

CSS recirculation. This would contribute to an NPSH margin of 1.1 feet of water. However, the 

NPSH section of the final response states that NSPH margin increases by about 3.7 ft when 

comparing similar conditions. The change in submergence reported in Section 3.f.2 for a 

LBLOCA (3.4 feet) is closer to this value. In a letter dated April 29, 2011 (Reference 7), the 

applicant responded to NRC RAI number NPSH RAI-1, by providing corrected strainer 

submergence values for the SBLOCA condition. In addition, the applicant provided the method 

used to calculate the increase in NPSH margin. The updated submergence levels correspond 

to those expected by the staff for an increase in NPSH margin of 3.7 feet of water. The 

correction to the SBLOCA sump level contained in the head loss and vortexing section is 

adequate for the staff to conclude that the NPSH margins were calculated correctly, including 

the increased margin for the SBLOCA case. 

In Enclosure 3 of the March 4, 2011, letter (Reference 1 ), the applicant stated that the 

calculation for determining the minimum water level for SBLOCAs assumes that the RCS will 

contribute inventory to the reactor cavity and that RCS shrinkage (due to cooling of the primary 

inventory) will reduce the available water volume in the containment sump. The leakage into 

the reactor cavity is greater than the shrinkage calculated for the 2000 gallon per minute 

SBLOCA case. From the information initially provided in the March 4, 2011, letter 

(Reference 1 ), the NRC staff could not determine whether the stated amounts provide for 

conservative estimates of minimum sump level. In a letter dated April 29, 2011 (Reference 7), 

the applicant responded to NRC RAI number NPSH RAI-2, by providing, additional information 

regarding the method used and assumptions made to calculate the minimum sump water level. 

The RAI response clarified that for the 2000 gallon per minute SBLOCA case, the RCS 

cooldown is only carried out to the point where the RCS pressure reaches 600 pounds per 

square inch, absolute. At that point, the accumulators would discharge their volumes, adding to 

the RCS and sump pool volume. For the 120 gallon per minute SBLOCA case, the RAI 

response stated that the RCS is continuing to cool at the time ECCS recirculation is initiated. 

The RCS pressure at the initiation of recirculation was calculated to be 1167 pounds per square 

inch, absolute. The applicant carried out the analysis until the RCS achieved the accumulator 

injection setpoint pressure of 610 pounds per square inch. At that point, the contents of the 

accumulators are assumed to be discharged to the RCS and sump pool. The staff determined 
-24-

that the LOCA cases considered by the applicant demonstrated that a minimum sump level had 

been determined. The staff concluded that the discharge of the accumulators would add 

adequate volume to the pool such that any additional RCS shrinkage would be compensated. 

The staff also recognizes that ice melt will continue to add inventory to the sump pool since ice 

melt was minimized for the SBLOCA evaluations. Therefore, the staff concludes that the 

containment pool elevation has been conservatively calculated. 

Based on the NRC staff's review of the information provided by the applicant for this review 

area, the staff has concluded that the applicant's evaluations and assumptions for determining 

available NPSH margin meet NRC staff guidance and, in some areas, are more conservative. 

The hand calculations and computer models used to determine hydraulic flow losses in the 

piping systems are also found to be acceptable. Therefore, the staff finds the method for 

determining NPSH margin for the ECCS and CSS pumps to be acceptable and in accordance 

with standard engineering practice. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately validated that the plant design provides adequate margin 

between the NPSH available and the NPSH required for each pump taking suction from the 

recirculation sump. Therefore, staff concludes that the applicant's evaluation of NPSH is 

acceptable. 

3.2.8 Coatings Evaluation 

This review area is associated with the applicant's evaluation of various protective coatings 

used inside the containment that can become debris as a result of a postulated pipe break 

inside the containment building. 

Summary of Applicant's GL 2004-02 Evaluation 

WBN Unit 2 calculated the amount and type of debris that could be generated considering such 

evaluation parameters as the coatings characteristics and ZOI of the LOCA jet. TVA stated that 

it made the following assumptions when determining the types and quantities of coatings debris 

that could be generated by the various LOCA scenarios. 

• The ZOI for qualified coatings is 100, 

• All qualified coatings in the ZOI fail as fine particulate 

• All unqualified coatings in containment fail as fine particulate, 

• All coating debris transports to the sump. 

The applicant used silicon carbide and tin particles as surrogate for coatings debris in the 

strainer testing. 

Staff Review of Applicant's Evaluation 

The staff found the approach for testing and the treatment of coatings to be consistent with the 

NRC SE on NEI 04-07. The staff found the surrogates used for testing to be acceptable 
-25-

because the density and particle size of the surrogates are similar to the properties of the 

expected coatings debris. Also, the applicant's coating assessment program met the staff's 

expectations since WBN Unit 2 will visually inspect Service Levell coatings every refueling 

outage with qualified personnel and any coating issues would be reported and put into the 

corrective actions program. During the review, the staff noted that for some coatings, the 1 OD 

ZOI assumed by the applicant was in excess of the 50 ZOI permitted by TR-WCAP-16568-P 

that was endorsed by the staff in its SE on NEI 04-07. The larger 1 OD ZOI results in 

approximately seven times as much epoxy debris than that generated using the 50 ZOI that the 

applicant could have justified. Therefore, the larger ZOI assumption made by the applicant 

adds additional conservatism. 

The staff review found that the WBN Unit 2 coatings assessment was consistent with the NRC 

SE on NEI 04-07 and in accordance with the coating review guidance contained in the letter 

from W. H. Ruland, NRC, to A. R. Pietrangelo, NEI, dated March 28, 2008 (Reference 21). The 

staff reviewed the types of coatings applied inside the containment building, the condition 

assessment program, the assumptions for debris generation, the debris characteristics, the 

assumptions for paint debris transport, and the sump strainer head-loss testing. Based upon 

the satisfactory finding associated with the review of these factors, the staff finds that the impact 

of coatings on sump strainer performance was adequately addressed. 

In its September 16, 2013, letter (Reference 9), TVA stated that the protective coatings program 

for conducting visual examinations of Service Levell and Service Levell I coatings at WBN 

Unit 2 are the same as that approved for WBN Unit 1: WBN Procedure MAI-5.3 for visual 

examination of Service Level I and II protective coatings now also applies to WBN Unit 2. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant appropriately identified the various protective coatings that can be a source of 

debris inside the containment building following a postulated pipe break inside containment. 

Therefore, staff concludes that the applicant's evaluation of coatings is acceptable. 

3.2.9 Debris Source Term 

The objective of the debris source term evaluation is to identify any significant design and 

operational measures taken to control or reduce the plant debris source term to prevent 

potential adverse effects on the ECCS and CSS recirculation functions. 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant provided information regarding the programs in place at WBN Unit 1 to maintain 

containment cleanliness, control foreign material and control design changes that could alter the 

debris source term. The applicant stated that, collectively, the listed programs provide the 

technical and programmatic controls necessary to ensure that design change, maintenance and 

modification activities are conducted in a manner that assures operability of the containment 

sump. In its September 16, 2013, letter (Reference 9), TVA stated that procedures are in place 

at WBN Unit 2 that address material control and containment cleanliness. 
-26-

Staff Review of Applicant's Evaluation 

Staff reviewed the description of the procedures, instructions, and programmatic controls cited 

by the applicant and find them acceptable for maintaining latent debris levels and debris 

sources within the assumptions used in the sump recirculation evaluations. These programs 

and procedures are similar to those used throughout the industry for controlling containment 

cleanliness, plant design configuration and debris sources. Further, the procedures have been 

shown to be effective at maintain reasonable cleanliness by maintaining the latent debris load in 

WBN Unit 1 at less than 70 pounds. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has significant design and operational measures in place to control or reduce 

the plant debris source term. Therefore, staff concludes that the applicant's evaluation of debris 

source terms is acceptable. 

3.2.1 0 Screen Modification Package 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant stated that the ECCS sump strainer installed in WBN Unit 2 will be identical to the 

strainer installed in WBN Unit 1 with minor modifications. A detailed description of the strainers 

is provided in Section 3.1 of this safety evaluation. 

Staff Review of Applicant's Evaluation 

The purpose of this section of the applicant's evaluation is to provide a general description of 

the proposed strainer. The adequacy of these modifications is determined through the review of 

the strainer performance parameters contained in Sections 3.2.6, 3.2.7, and 3.2.11 of this SE. 

Commitments 

In Enclosure 4 of the March 4, 2011, letter, under commitment number 1, the applicant stated 

that WBN Unit 2 will install sump modifications per the requirements of GL 2004-2 prior to WBN 

Unit 2 fuel load. In its September 16, 2013, letter (Reference 9), TVA reaffirmed that new sump 

strainers will be installed prior to fuel load and stated that the installation was a confirmatory 

inspection item. 

Staff's Conclusion 

The applicant has provided an adequate description of the ECCS sump strainer to be installed 

in WBN Unit 2. The adequacy of the strainer performance is addressed in Sections 3.2.6, 3.2.7, 

and 3.2.11 of this SE. Therefore, the staff finds the applicant's ECCS sump strainer acceptable. 

3.2.11 Sump Structural Analysis 

The objective of the sump structural analysis section is to verify the structural adequacy of the 

sump strainer under seismic, differential pressure, missiles, and jet impingement loads. 
-27-

Summary of Applicant's GL 2004-02 Evaluation 

The containment sump strainer assembly at WBN Unit 2 was described by the applicant as 

consisting of 23 vertically oriented strainer modules, each consisting of a number of stacked, 

1-inch-thick disks with 0.085-inch diameter flow openings throughout each disk. In order to 

address item 3.k of the Revised Content Guide for GL 2004-02 Supplemental Responses 

(Reference 3}, the applicant's evaluation (Reference 1) stated that a combination of manual 

calculations and computational finite element analyses (FEA), using the GTSTRUDL and 

ANSYS computer programs, were used in order to demonstrate the abilities of the strainer 

assembly and flow plenum to maintain their structural integrity in the event of a design basis 

accident. In a letter dated April 29, 2011 (Reference 7), the applicant responded to NRC RAI 

number EMCB RAI-1, stating that the damping values used in the development of the operating 

basis earthquake (OBE) and safe shutdown earthquake (SSE) seismic response spectra used 

in the structural analyses of the sump strainer structures were 2 percent and 3 percent, 

respectively. 

Using the analysis methods described above, the applicant evaluated the strainer assembly and 

flow plenum by subjecting the structures to the loads described on page E1-60 of Reference 1 

in order to determine the maximum stresses induced in the individual components making up 

these structures. These loads, combined, make up the design basis loading combinations 

applicable to the sump strainer and flow plenum assembly. The stresses induced by the loads 

are then compared against the corresponding limits outlined on page E1-60. In its evaluation, 

the applicant stated that the analysis for the strainer and the flow plenum considered the 

following loads: dead weight of the structure and supports, thermally induced loads under 

accident conditions, debris weight, differential pressure, and seismic loads induced by OBE and 

SSE. 

The NRC staff issued two RAison the WBN Unit 1 GL 2004-02 submittal regarding the loading 

combinations considered in the structural analysis of the sump strainer and flow plenum 

assembly. The applicant noted on page E1-60 of the March 4, 2011, letter (Reference 1) that 

debris impact loads need not be considered in the structural analysis of the sump strainer and 

flow plenum assembly. In the letter dated April 29, 2011 (Reference 7), the applicant responded 

to NRC RAI number EMCB RAI-2, stating that the debris impact loads were not incorporated 

into the applicable loading combinations because the location of the strainer precludes the 

strainer from the effects of loadings due to debris impacts resulting from potential pipe breaks. 

In Reference 1, TVA stated that loads due to jet impingement, pipe whip, or missile impacts 

from high energy line breaks inside containment were not considered in the structural evaluation 

because a review of pertinent Final Safety Analysis Report (FSAR) figures determined that the 

location of the sump strainers was such that the strainers were not subject to such loads. WBN 

Unit 1 FSAR Amendment 6, Figures 6.3-6 and 6.3-6a, show that the strainers are located in a 

relatively protected area of the lower containment below the refueling cavity. TVA stated that 

the WBN Unit 2 strainers are in the same location with respect to other WBN Unit 2 structures 

as the WBN Unit 1 strainer is to WBN Unit 1 structures and that the WBN Unit 2 FSAR will be 

revised to reflect the new sump strainer. Further, the applicant noted that in accordance with 

the WBN Unit 2 licensing basis for leak-before-break (LBB) criteria, dynamic effects due to 

primary system pipe breaks need not be considered as additional loads. 
- 28-

The applicant also indicated on page E1-61 of the March 4, 2011, letter (Reference 1) that the 

loading combinations that the structures were evaluated against did not require the 

consideration of hydrostatic and hydrodynamic loads in order to demonstrate compliance with 

the code requirements. In the letter dated April 29, 2011 (Reference 7), the applicant 

responded to NRC RAI number EMCB RAI-3, clarifying the application of hydrostatic and 

hydrodynamic loads in the analyses. The applicant stated that the design and licensing basis 

requirements related to the design of the strainer structures do not require the combining of 

loads due to seismic forcing functions, such as hydrodynamic loads due to sloshing, with other 

loads applicable to the period of recovery from a design-basis accident. Additionally, the 

applicant indicated that hydrostatic loads were included within the differential pressure loads. 

Using the analyses methods described above, the applicant compared the maximum stresses in 

the evaluated members and welds to the appropriate American Institute of Steel Construction 

(AISC) Manual of Steel Construction, 71

h Edition, allowable stress limits to demonstrate 

compliance. The applicant also stated that there are certain instances where the AISC manual 

does not provide adequate guidance for the qualification of particular components. For these 

cases, other codes or standards were employed accordingly and are described in detail on 

page E1-59 of the March 4, 2011, letter (Reference 1 ). The most significant examples of these 

divergences from the AISC code are the use of the equations from Appendix A, Article A-8000 

of the American Society of Mechanical Engineers Boiler & Pressure Vessel Code, Section Ill, 

1989 Edition, which deals with perforated plate stresses, and the utilization of Structural 

Engineering Institute/American Society of Civil Engineers 8-02, "Specification for the Design of 

Cold-Formed Stainless Steel Structural Members," for the qualification of thin-gauge and 

cold-formed stainless steel sections. 

The applicant noted on page E1-60 of Reference 1 that the AISC standard allows an increase 

of 33 percent in allowable stresses for steel due to seismic or wind loadings. However, the 

applicant did not credit this increased allowable stresses when comparing the induced stresses 

to the allowable stress indicated in the March 4, 2011, letter (Reference 1 ). The applicant also 

stated that the allowable stresses for carbon steel provided in the AISC code were utilized to 

qualify the stainless steel structure for tensile, shear, bending, and bearing loads, due to the 

lack of well-defined material properties for stainless steel in the AISC standard. 

As indicated above, the design basis loading combinations, to which the strainer assembly and 

flow plenum were subjected, are in accordance with the WBN Unit 2 design and licensing basis 

requirements. Pages E1-61 and E1-62 of the March 4, 2011, letter (Reference 1) provide the 

results of the structural evaluation of the WBN Unit 2 strainer and flow plenum components in 

the form of maximum stress ratios which compare the maximum induced stresses in a 

component, due to the aforementioned loading combinations, with the appropriate allowable 

stress (ratio equals maximum stress divided by allowable stress). These results indicate that all 

of the components included in the evaluation satisfy the design code requirements (i.e., all 

stress ratios are less than 1.0). 

Staff Review of Applicant's Evaluation 

The NRC staff's review of the applicant's assessment of the structural integrity of the sump 

strainer and flow plenum assemblies included a number of items as follows: 
- 29-

The NRC staff reviewed the applicant's general method used in the structural analyses of these 

components to ensure that the analyses were performed consistent with the acceptance criteria 

in GL 2004-02, the NRC revised content guide (Reference 3), and the design and licensing 

basis requirements of WBN Unit 2, with a specific focus on the loading combinations for which 

the structures must be qualified against. 

The NRC staff reviewed the results of the applicant's structural analyses to ensure that 

compliance with the industry codes, standards and design and licensing basis requirements was 

adequately demonstrated. 

NRC staff reviewed the applicant's dynamic effects assessment to ensure that the applicant 

adequately considered whether any potential exists for dynamic effects loads due to pipe whip 

and/or jet impingement to impact the sump strainer and flow plenum assemblies at WBN Unit 2. 

The NRC staff reviewed the open items associated with the WBN Unit 1 audit to confirm that 

any items deemed open as a result of the WBN Unit 1 GL 2004-02 closure audit were 

adequately addressed for the WBN Unit 2 GL 2004-02 closure efforts. 

a. Structural Analysis 

Paragraph 2(d)(vii) of GL 2004-02 specifically requested that sump strainers used to support 

ECCS and CSS have adequate structural margin against design basis loading combinations 

such that the structural integrity of the strainers was not compromised during a design basis 

accident. Item 3.k of Reference 3 provided additional specificity regarding the required 

information relative to the verification of the structural integrity of sump strainers, with respect to 

the closure efforts associated with GL 2004-02. 

The review performed by the NRC staff covers the structural integrity of the sump strainers and 

associated flow plenum assemblies installed at WBN Unit 2. As such, the NRC staff's review 

focused on verifying that the applicant has provided reasonable assurance of the structural 

integrity of the sump strainers and flow plenum under normal and abnormal loading conditions, 

including postulated accidents and natural phenomena such as earthquakes. The design basis 

loading combinations used in the structural analyses of the structures at WBN Unit 2 are located 

in Chapter 3 of the WBN Unit 2 FSAR. 

The NRC staff's acceptance criteria in the areas of civil and mechanical engineering are based 

on the guidance and regulatory requirements described in Section 3.8.4, "Other Seismic 

Category I Structures," of the SRP (Reference 24). The regulatory requirements described in 

SRP Section 3.8.4, Revision 3, include the following: 

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a and 10 CFR Part 50, 

Appendix A, General Design Criterion (GDC) 1, as they relate to safety-related structures being 

designed, fabricated, erected, and tested to quality standards commensurate with the 

importance of the safety function to be performed; GDC 2 as it relates to the design of the 

safety-related structures being capable to withstand the most severe natural phenomena such 

as wind, tornadoes, floods, and earthquakes and the appropriate combination of all loads; and 

GDC 4 as it relates to safety-related structures being protected against dynamic effects, such as 

the loads imposed on structures by postulated missiles. The WBN Unit 2 FSAR references 

Revision 2 of SRP Section 3.8.4 as the guidance used in the design of "Other Seismic 
-30-

Category I Structures" at WBN Unit 2. Although Revision 3 to SAP Section 3.8.4 has been 

issued, the reference to Revision 2 is acceptable because the acceptance criteria related to the 

design of these structures remains unchanged between the Revision 2 and Revision 3 versions. 

Additional guidance related to the structural integrity of sump strainers installed in PWRs to 

address GL 2004-02 can be found in Section 7.1 of the NEI 04-07 report (Reference 8). The 

NRC staff's associated SE (Reference 9), includes additional conditions and limitations and 

required modifications, including alternative guidance, with respect to the use of NEI 04-07 in 

resolving GL 2004-02. 

The NRC staff considers the applicant's assessment of the structural integrity of the sump 

strainers and flow plenum acceptable based on a number of factors. The applicant 

demonstrated that the results of the structural analyses of the sump strainer and flow plenum 

satisfied the applicable design code requirements for the individual components making up each 

structure. All interaction ratios are below a value of 1.0. The NRC staff considers the general 

method used for the structural analyses of these components acceptable based on the fact that 

the use of manual hand calculations, supplemented with computational FEA, is standard 

industry practice for the structural evaluation of these types of structures and provides an 

adequate level of accuracy and conservatism. The applicant's RAI response number EMCB 

RAI-1 in the letter dated April 29, 2011 (Reference 7) regarding the damping values used in the 

seismic analyses for the sump strainer and flow plenum is acceptable given that it is consistent 

with the design basis requirements associated with the design of Seismic Category I structures 

at WBN Unit 2. Additionally, the NRC staff notes that the values used at WBN Unit 2 are 

conservative compared to the damping values which are deemed acceptable for use in the 

design of steel structures in the NRC staff guidance found in RG 1.61, "Damping Values for 

Seismic Design of Nuclear Power Plants," Revision 1. 

The NRC staff considers the loading combinations used in the structural analyses acceptable 

given that they are consistent with the guidance provided in SRP Section 3.8.4 (Reference 4) 

and NEI 04-07 and they are consistent with the design and licensing basis requirements for 

WBN Unit 2. This acceptance also applies to the applicant's responses to NRC staff RAis 

regarding the loads used in the design basis loading combinations used to structurally qualify 

the strainers. The applicant demonstrated that debris impact loads are not required to be 

included in the loading combinations due to the fact that the WBN Unit 2 replacement strainer 

structures are located such that debris impact loads resulting from a postulated pipe rupture 

would not affect the strainers. Additionally, the NRC staff considers the applicant's response 

regarding the omission of hydrodynamic loads acceptable based on the fact that the design and 

licensing basis requirements applicable to the structural design of the strainers does not require 

these seismically-induced loads to be postulated coincident with design basis accident recovery 

loads. 

With respect to the stress limits specified in the applicant's response, the applicant's use of 

carbon steel material properties is acceptable given that at low temperatures (the maximum 

accident temperature is 190 °F, as indicated on page E1-59 of the March 4, 2011, letter 

(Reference 1 ), carbon steel has a lower allowable stress than that of stainless steel as provided 

in the AISC standard. 
- 31 -

b. Dynamic Effects 

The NRC staff considers the applicant's assessment of potential dynamic effects acceptable. 

This acceptance is based on the fact that the applicant presented adequate justification that 

demonstrates that the location of the sump strainers and the application of LBB criteria preclude 

the ability of the strainers to be affected by potential dynamic effects loads, resulting from jet 

impingement, pipe whipping, and/or missile impacts (see evaluation regarding debris impact 

loads in Section 3.2.1.11.a above). As such, the NRC staff considers the applicant's exclusion 

of these loads from the loading combinations previously described acceptable, given that there 

is reasonable assurance that the sump strainers would not be impacted by the aforementioned 

potential dynamic effects. 

c. Audit Open Items 

The NRC staff considers Audit Open Item 5 closed, as it relates to the WBN Unit 2. The NRC 

staff notes that this audit item was first identified for WBN Unit 1 due to the fact that the 

structural analyses for the sump strainers had not been completed at that time. Given that the 

applicant has completed the structural analyses for the WBN Unit 2 sump strainers and flow 

plenum, as summarized in Enclosure 1 to the March 4, 2011, letter (Reference 1 ), the NRC staff 

considers the applicant's assessment of the open item as it relates to WBN Unit 2 acceptable. 

Staff's Conclusions 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately verified the structural adequacy of the sump strainer under 

seismic, differential pressure, missiles, and jet impingement loads. Based on the above 

discussion, the NRC staff concludes that the applicant has provided reasonable assurance that 

the strainer assembly and flow plenum will maintain their structural integrity in the event of a 

design-basis accident. This acceptance is outlined above and is based on the applicant's use of 

a standard structural analysis method and the applicant's demonstration that the strainer 

assembly and flow plenum components meet the applicable design code structural acceptance 

criteria when these components are subjected to design basis loading combinations. The NRC 

staff also considers the applicant's assessment of the WBN Unit 1 GL 2004-02 closure Audit 

Open Item 5 acceptable and closed for WBN Unit 2 based on the fact that the applicant has 

provided the information originally requested. Furthermore, based on its review described 

above, the NRC staff has concluded that the regulatory requirements have been satisfied for the 

sump strainer and flow plenum assemblies. Therefore, staff concludes that the applicant's 

evaluation of the structural analysis is acceptable. 

3.2.12 Upstream Effects 

The objective of the upstream effects assessment is to evaluate the flow paths upstream of the 

containment sump for holdup of inventory which could reduce flow to the sump and possibly 

starve the pumps which take suction from the sump. An evaluation of upstream effects ensures 

that flow necessary for recirculation is not held up by debris blockage at drains or other narrow 

pathways. 
- 32-

Summary of Applicant's GL 2004-02 Evaluation 

The applicant stated that walkdowns of the WBN Unit 1 containment had been completed 

following the guidance of NEI 02-01 (Reference 25) and that the WBN Unit 2 containment is 

similar to WBN Unit 1. The walkdowns identified three potential choke points that required 

evaluation. These potential holdup points are the refueling canal and accumulator rooms 3 and 

4. The evaluation of these potential hold-up points was described as follows: 

The applicant identified accumulator rooms 3 and 4 as a potential location for water hold-up. 

The rooms could have a small amount of containment spray enter through the openings for the 

air return fans. These rooms have drains that are designed to return the spray-water back to 

the containment pool. These accumulator rooms also have curbs at all openings to prevent the 

entry of water and debris flowing along the floor. Therefore, the only water that can enter the 

room is from spray. Because the containment spray is sourced either from the RWST or 

downstream of the sump strainer, any debris in these water sources would be too small to block 

the drains in the accumulator rooms. Therefore, the applicant assumed that only failed coatings 

debris could migrate to the interior of the accumulator rooms and that the failed coatings 

particles would be too small to block the· drains. 

The applicant identified the refueling canal as a potential location for water hold-up. The 

refueling canal has two 14-inch drains that discharge to lower containment at opposite sides of 

the sump strainer. These drains are designed to route almost all the spray water flow from 

upper containment to the lower containment. The applicant stated that a small amount of debris 

fines could be blown to upper containment by bypassing the ice baskets but the debris would 

not be a significant contributor to the potential source for blockage of the drain lines. The other 

debris types that could reach the drains are latent and coatings particles that also are assumed 

to be insufficient to block the drains. 

The applicant identified the ice condenser compartment as a potential location for water hold-up 

if the drains become blocked. The applicant stated that there are 20 drains in the ice condenser 

compartment and that if any-one drain becomes blocked, the water would flow to other drains. 

The applicant also stated that if all the ice condenser drains were to become blocked, the water 

could overflow the ice condenser compartment bay doors (which is the normal drainage 

flow-path early in the LOCA event when the ice melt rate is high). 

The applicant additionally stated that prior to restart from each refueling outage the containment 

is inspected for material that could inhibit the flow of water during recirculation or be washed to 

the sump. 

Staff Review of Applicant's Evaluation 

NRC staff reviewed the applicant's designation of potential water hold-up locations and found 

that the significant potential hold-up locations had been identified. 

Staff reviewed the applicant's rationale for concluding that accumulator rooms 3 and 4 would not 

hold up a significant volume of water. The NRC staff concluded that plugging of the drains with 

fine debris would not occur because the size of the debris that could enter the rooms is 

significantly smaller than the drain lines and, therefore, could not plug the drains. 
-33-

Staff reviewed the applicant's rationale for concluding that the refueling canal would not hold up 

a significant volume of water. The staff considered the size of the drain lines and the size of the 

debris that could reach the drains and concluded that it is not credible that the lines would 

become blocked by debris generated during a LOCA. 

Staff reviewed the applicant's rationale for concluding that ice-condenser compartment would 

not hold up a significant volume of water. The staff considered that although blockage of all of 

the ice condenser drains is extremely unlikely, a small amount of water hold-up could occur in 

the ice condenser compartment late in the LOCA event. However, at this stage in the accident, 

the strainers would already be fully submerged. Therefore, the effect of this very unlikely water 

hold-up would be inconsequential. 

NRC staff's review of the information provided by the applicant, as described above, against the 

staff's review guidance and the WBN Unit 1 audit report, considering the similarity of the two 

units. The staff concludes that the applicant performed an adequate upstream effects 

evaluation and that adequate water would not be prevented from reaching the sump following a 

LOCA. 

Staff's Conclusions 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant has appropriately evaluated the flow-paths upstream of the containment sump 

for holdup of inventory that could reduce flow to the sump and possibly starve the pumps that 

take suction from the sump. Therefore, staff concludes that the applicant's evaluation of 

upstream effects is acceptable. 

3.2.13 Downstream Effects-Components and Systems 

The objective of the downstream effects, components and systems section is to evaluate the 

effects of debris carried downstream of the containment sump screen on the function of the 

ECCS and CSS in terms of potential wear of components and blockage of flow streams. 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant stated that with minor exceptions, WBN Unit 2 is a mirror image of WBN Unit 1. 

The exceptions are: 

• WBN Unit 2 uses modified throttle valves in the chemical and volume control system 

(CVCS) and HPSI to control flow split instead of the restriction orifice/throttle valve 

combination used in WBN Unit 1. 

• WBN Unit 2 does not contain Min-K insulation or 3M fire-wrap found in WBN Unit 1. 

Therefore, the applicant concluded that the WBN Unit 1 downstream effects evaluations for 

components and systems generally bounds WBN Unit 2. A separate evaluation was performed 

to address blockage and wear of the CVCS and HPSI control valves. The applicant provided a 

description of the methods and design inputs used in the evaluations to assess the effects of 

debris carried downstream of the containment sump screen on the function of the ECCS and 

CSS in terms of wear of components and blockage of flow streams. The applicant stated that 

the evaluation incorporates methods from the NRC approved Topical Report WCAP-16406-P-A, 
-34-

Revision 1, "Evaluation of Downstream Sump Debris Effects in Support of GSI -191" 

(Reference 20). The applicant stated that the results of the revised evaluation indicate that the 

WBN Unit 2 ECCS equipment will perform adequately during the required mission time. 

The applicant calculated the concentration of debris assumed to passes through the WBN 

Unit 2 sump strainer to be 835 parts per million (ppm). The primary constituents are: 

• Fibrous debris: 1 ppm 

• Particulate debris: 241 ppm 

• Coatings debris: 593 ppm 

As stated in WCAP-16406-P-A, Revision 1, the effects of debris ingested through the 

containment sump screen during the recirculation mode of the ECCS and CSS include erosive 

wear, abrasion and potential blockage of flow paths. The applicant provided the following 

evaluation results for these phenomena: 

a) Blockage Evaluations 

For the evaluation of the WBN heat exchangers, orifices, and spray nozzles in the recirculation 

flow path, the applicant stated that the smallest clearance found for these components 

is 0.375 inch (containment and RHR spray nozzles). No blockage of flow paths in these ECCS 

components is expected because the WBN Unit 2 sump screen opening size is much smaller 

(0.085 inch). 

The instrumentation tubing was also evaluated for potential blockage of the sensing lines. The 

applicant stated that the transverse velocity past this tubing was determined to be sufficient to 

prevent debris settlement into these lines, so no blockage will occur. The reactor vessel level 

instrumentation system (RVLIS) was also evaluated. The WBN RVLIS is a Westinghouse 

design and, based on this evaluation, no effect on its performance is expected from the debris. 

The applicant evaluated valves for plugging. The applicant stated that 12 valves in the Sl and 

CVCS met the WCAP-16406-P, Revision 1 (Reference 20) criteria for specific plugging 

evaluation. The applicant stated that these valves were being positioned to ensure that no 

plugging will result; therefore, all 12 valves passed the evaluation. 

The applicant evaluated valves for sedimentation. The applicant stated that 23 valves in the Sl, 

RHR and reactor building spray systems meet the requirements in WCAP-16406-P-A for a 

specific sedimentation evaluation. The applicant stated that all the valves passed the 

evaluation. 

b) Wear Evaluations 

The applicant evaluated the WBN heat exchangers, orifices, and spray nozzles for the effects of 

erosive wear caused by a constant debris concentration of 835 ppm over a mission time 

of 30 days. The applicant stated that the erosive wear on these components was determined to 

be insufficient to affect the system performance. 

The applicant evaluated valves for wear. Twelve valves in the Sl system and eves met the 

TR-WCAP-16406-P-A, Revision 1 (Reference 20) criteria for a detailed wear evaluation. Using 
- 35-

the depleting debris wear model detailed in TR-WCAP-16406-P-A, Revision 1 , all valves passed 

the evaluation. 

The applicant evaluated the Sl, CSS, centrifugal charging (CC) and RHR pumps for the effects 

of debris ingestion through the sump screen. Three aspects of operability (hydraulic 

performance, mechanical shaft seal assembly performance, and mechanical performance 

(vibration) of the pump) were evaluated. The hydraulic and mechanical performances of the 

pumps were determined to not be affected by the circulating sump debris. The change in the 

pump wear ring gap due to abrasive wear was calculated and the resulting reduction in the 

pump discharge flow evaluated. For all of the pumps, the hydraulic flow margin was assumed 

to be positive at the start of containment recirculation. The increased clearance for the pumps 

was calculated to be within the TR-WCAP-16406-P-A, Revision 1, acceptance criterion of threetimes the design clearance. Therefore, no effect on the hydraulic performance of the 12 ECCS 

and CSS pumps is expected. 

For the pump seal evaluation of the Sl, CSS, CC, and RHR pumps, the applicant stated that 

WBN Unit 2 has an engineered safety feature atmospheric filtration system, the auxiliary 

building gas treatment system, and the emergency gas treatment system. Therefore, evaluation 

of a primary seal passive failure is not required by NUREG-0800, and so the backup seal is not 

necessary to limit the leakage. Infrequent minor ECCS pump seal leakage that may occur 

during normal operation is bounded by the existing offsite dose analysis. The total ECCS 

recirculation loop leakage evaluated in the offsite dose analysis is 3760 cubic centimeters per 

hour. Since no primary seal failure is imposed by the LOCA dose analysis and primary seal 

failure is unlikely under these conditions, no adverse effect on the backup bushing is expected. 

Staff Review of Applicant's Evaluation 

NRC staff reviewed the evaluation methods, the evaluation results, and the applicant's 

conclusions contained in the applicant's GL 2004-02 responses (Reference 1) and concluded 

that the applicant followed the NRC staff-accepted guidance contained in 

TR-WCAP-16406-P-A, Revision 1, including the NRC SE of that document, for evaluating the 

effect of debris contained in the circulated sump pool on safety-related components located in 

the ECCS and CSS. Based on the staff review of the information provided by the applicant and 

a comparison of this information to the review guidance, a review of the WBN Unit 1 audit 

report, and the fact that the two containment and insulating system designs are very similar, the 

staff concluded that the applicant had performed an adequate downstream effects evaluation of 

components and systems and that the components would be capable of performing their 

safety-related design functions for their required mission times after a LOCA. 

Commitments 

In Enclosure 4 of the March 4, 2011 letter, under commitment number 3, the applicant stated 

that WBN Unit 2 will install new throttle valves in the CVCS and Sl injection lines to the RCS 

and that the new valves will be opened sufficiently to preclude downstream blockage. In its 

September 16, 2013, letter (Reference 9), TVA reaffirmed that new throttle valves will be 

installed in the CVCS and Sl system injection lines and stated that the installation was a 

confirmatory inspection item. 
-36-

Staff's Conclusions 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicants evaluation of the effects of debris carried downstream of the containment 

sump screen on the function of the ECCS and CSS in terms of potential wear of components 

and blockage of flow streams is acceptable. Therefore, staff concludes that the applicant's 

evaluation of the downstream effects on components and systems is acceptable. 

3.2.14 Downstream Effects-Fuel and Vessel 

The objective of the downstream effects, fuel and vessel section is to evaluate the effects that 

debris carried downstream of the containment sump screen and into the reactor vessel has on 

core cooling. 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant's evaluation of in-vessel downstream effects is based on two guidance 

documents: the "Clean Plant" criteria as clarified in the NRC letter dated May 2, 2002 

(Reference 12) and TR WCAP-16793-NP-A, Revision 2 (Reference 13). 

In a letter dated May 17, 2012 (Reference 8), the applicant provided information that 

demonstrated that WBN Unit 2 containment fibrous debris load meets the "Clean Plant" criteria 

and that the quantity of fibrous debris reaching the core inlet is calculated to be 11.9 grams per 

fuel assembly-less than the 15 grams per fuel assembly limit stated in TR-WCAP-16793-NP-A 

(Reference 13). Also, in a letter dated September 16, 2013 (Reference 9), the applicant 

provided results of its maximum post-quench fuel clad temperature and maximum fuel clad 

deposit thickness-398 oF and 11.6 mils, respectively. These values are considerably below the 

TR-WCAP-16793-NP-A allowable temperature of 800°F and deposit thickness of 50 mils. 

Staff Review of Applicant's Evaluation 

Staff reviewed the information provided by the applicant and determined that the evaluations 

meet the staff-accepted "Clean Plant" criteria and TR-WCAP-16793-NP-A, Revision 2. Based 

on the limited quantity of transportable debris at WBN Unit 2, and the available margins, the 

staff concluded that the applicant had performed an adequate evaluation of the downstream 

effects of debris on the fuel and reactor vessel to demonstrate that debris in the circulated postLOCA coolant would not result in blockage at the core inlet that could prevent adequate coolant 

flow to the core. 

Staff's Conclusions 

The staff reviewed the applicant's evaluation and concludes that the applicant has satisfactorily 

resolved the issue of downstream, in-vessel effects. The applicant followed the guidance and 

acceptance criteria in staff-approved TR-WCAP-16793-NP-A, Revision 2 and the "Clean Plant" 

criteria. Therefore, NRC staff accepts the applicant's evaluation. 
- 37-

3.2.15 Chemical Effects 

The objective of the chemical effects evaluation is to evaluate how chemical precipitates affect 

suction strainer head loss. (The NRC staff review of chemical effects within the reactor vessel 

is contained in Section 3.2.14 of this SE, using the TR-WCAP-16793-NP-A acceptance criteria.) 

Summary of Applicant's GL 2004-02 Evaluation 

The applicant used NRC staff approved methods of TR-WCAP-16530-NP-A, "Evaluation of 

Post-Accident Chemical Effects in Containment Sump Fluids to Support GSI-191" 

(Reference 19) to predict the amount of chemical precipitates formed in the sump pool after a 

LOCA, to generate the surrogate precipitates used in testing, and to perform a head loss test 

with the surrogate precipitates. 

The applicant stated that due the small amount of reactive materials in the containment building, 

the moderate pH, the low sump pool temperatures, and the current buffering agent, the 

predicted total amount of precipitates formed for WBN Unit 2 over the assumed 30-day 

post-accident period was 13.08 kilograms. 

Staff Review of Applicant's Evaluation 

The applicant's analysis and testing are consistent with the staff's expectations as described in 

the chemical effects review guidance contained in the letter from W. H. Ruland, NRC, to 

A. R. Pietrangelo dated March 28, 2008 (Reference 21 ). The applicant determined the chemical 

precipitate source term at WBN Unit 2 using an NRC-approved method described in 

TR-WCAP-16530-NP-A) (Reference 19). The applicant performed strainer head loss testing 

with plant-specific debris, including chemical precipitate types and quantities determined per the 

guidance in in the topical report, to demonstrate that adequate ECCS recirculation flow can be 

maintained with this debris load. Therefore, the applicant's overall chemical effects evaluation 

is acceptable. 

Staff's Conclusion 

The staff reviewed the applicant's evaluation against the staff-accepted guidance and concludes 

that the applicant's evaluation of the effect that chemical precipitates have on suction strainer 

head loss is acceptable. Therefore, staff concludes that the applicant's evaluation of chemical 

effects is acceptable. 

3.2.16 Licensing Basis 

The objective of the licensing basis evaluation is to provide information regarding any changes 

to the plant licensing basis due to the sump evaluation or plant modifications 

Summary of Applicant's GL 2004-02 Evaluation 

In its letter dated September 16, 2013 (Reference 9), the applicant stated that the design basis 

of the modified emergency sump strainer has been incorporated into the plant's current 

licensing basis and that the WBN Unit 2 FSAR has been amended to include this information. 
-38-

Staff Review of Applicant's Evaluation 

The staff finds the applicant's response to this review topic acceptable because the applicant 

has updated the WBN Unit 2 licensing basis to include the licensing basis for the modified 

ECCS sump strainer. 

Staff's Conclusion 

The staff reviewed the applicant's actions against the staff-accepted guidance and concludes 

that the applicant has satisfied the requirement to reflect the design basis of the modified ECCS 

sump strainer in the plant design bases. Therefore, staff concludes that the applicant's 

response is acceptable and that the applicant has satisfied this requirement. 

4.0 OVERALL CONCLUSIONS 

Based on the staff review of the applicants GL 2004-02 evaluations and responses to RAis 

(References 1, 7, 8, and 9) as discussed in Section 3 above, the NRC staff concludes that the 

applicant has provided reasonable assurance that the issues identified in GL 2004-02 have 

been adequately addressed at WBN Unit 2. Therefore, the NRC staff finds the applicant's 

response to GL 2004-02 acceptable. The open items identified in this SE are being tracked in 

the WBN Unit 2 Engineering Document Construction Release program and are confirmatory 

inspection items, ensuring that the committed actions will be completed prior to fuel load or 

startup, as applicable. 

5.0 REFERENCES 

1) Letter from D. Stinson, Tennessee Valley Authority, to NRC Document Control Desk, 

'Watts Bar Nuclear Plant (WBN), Unit 2- Response to Generic Letter (GL) 2004-02, 

Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis 

Accidents at Pressurized-Water Reactors," dated March 4, 2011. (ADAMS Accession 

No. ML 11 0680248) 

2) Letter from Masoud Bajestani, Tennessee Valley Authority, to NRC Document Control 

Desk, 'Watts Bar Nuclear Plant (WBN), Unit 2- Response to Generic Letter 

(GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During 

Design Basis Accidents at Pressurized-Water Reactors," dated September 10, 2010. 

(ADAMS Accession No. ML 1 02580175) 

3) Letter from W. H. Ruland, NRC, to A. Pietrangelo, Nuclear Energy Institute, "Revised 

Content Guide for Generic Letter 2004-02 Supplemental Responses," dated 

November 21, 2007. (ADAMS Accession Nos. ML07311 0269 (letter) and ML07311 0278 

(enclosure)) 

4) TVA letter to NRC dated July 3, 2006, 'Watts Bar Nuclear Plant (WBN), Unit 1 -Generic 

Letter 2004-02- Request for Additional Information Regarding the Nuclear Regulatory 

Commission Staff Audit on the Containment Sump Modifications (TAC No. MC4730)." 

(ADAMS Accession No. ML062120472) 
-39-

5) TVA Letter to NRC dated March 3, 2009, 'Watts Bar Nuclear Plant (WBN), Unit 1 -

Response to Request for Additional Information Regarding Generic Letter 2004-02, 

Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis 

Accidents at Pressurized-Water Reactors (TAC. No. 4730)." (ADAMS Accession 

No. ML090720868) 

6) TVA Letter to NRC dated June 3, 2010, "Draft Responses to Requests for Additional 

Information Related to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage 

During Design Basis Accidents at Pressurized-Water Reactors." (ADAMS Accession 

No. ML 1 01590373) 

7) Letter from D. Stinson, Tennessee Valley Authority, to NRC Document Control Desk, 

'Watts Bar Nuclear Plant (WBN), Unit 2- Response to Requests for Additional 

Information (RAis) Regarding Generic Letter 2004-02, Potential Impact of Debris 

Blockage on Emergency Recirculation During Design Basis Accidents at 

Pressurized-Water Reactors (TAC No. MD6726)," dated April 29, 2011. 

(ADAMS Accession No. ML 11124A083) 

8) TVA letter to NRC dated May 17, 2012, 'Watts Bar (WBN), Unit 2-Additionallnformation 

to Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency 

Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC No. 

MD6726)." (ADAMS Accession No. ML 12143A345) 

9) TVA letter to NRC dated September 16, 2013, 'Watts Bar (WBN), Unit 2-Additional 

Information to Generic Letter 2004-02, Potential Impact of Debris Blockage on 

Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors 

(TAC No. MD6726) ." (ADAMS Accession No. ML 13262A270) 

1 0) NRC letter to TVA dated April 19, 2011, 'Watts Bar Nuclear Plant, Unit 2 - Request for 

Additional Information Regarding Generic Letter 2004-02, Potential Impact of Debris 

Blockage on Emergency Recirculation During Design Basis Accidents at 

Pressurized-Water Reactors (TAC No. MD6726)." (ADAMS Accession 

No. ML 11 0950406) 

11) NRC letter to TVA dated April 25, 2011, 'Watts Bar Nuclear Plant, Unit 2 - Request for 

Additional Information Regarding Generic Letter 2004-02, Potential Impact of Debris 

Blockage on Emergency Recirculation During Design Basis Accidents at 

Pressurized-Water Reactors Round 2 (TAC No. MD6726)." (ADAMS Accession 

No. ML 111091 048) 

12) Letter from W. H. Ruland, NRC, to J. C. Butler, Nuclear Energy Institute, "NRC Review 

of Nuclear Energy Institute Clean Plant Acceptance Criteria for Emergency Core Cooling 

Systems," dated May 2, 2012. (ADAMS Accession Nos. ML 120730181) 

13) Westinghouse Topical Report WCAP-16793-NP-A, "Evaluation of Long-Term Cooling 

Considering Particulate, Fibrous and Chemical Debris in the Recirculating Fluid," 

Revision 2, July 2013. (ADAMS Accession Nos. ML 13239A 114 and ML 13239A 115) 
-40-

14) Letter from A. R. Pietrangelo, Nuclear Energy Institute, to J. N. Hannon, NRC, "PWR 

Containment Sump Evaluation Methodology- Baseline Evaluation," dated April 19, 

2004. (ADAMS Accession No. ML041120516) 

15) NRC Staff Safety Evaluation for Nuclear Energy Institute Report, "PWR Containment 

Sump Evaluation Methodology- Baseline Evaluation," December 6, 2004. 

(ADAMS Accession Nos. ML043280007 and ML043280008) 

16) NEI 04-07 "Pressurized Water Reactor Sump Performance Evaluation Methodology," 

Rev. 0, December 2004, Volume 1. (ADAMS Accession No. ML050550138) 

17) NEI 04-07 "Pressurized Water Reactor Sump Performance Evaluation Methodology," 

Rev. 0, December 2004, Volume 2, Safety Evaluation by the Office of Nuclear Reactor 

Regulation Related to NRC Generic Letter 2004-02, Rev. 0, December 6, 2004. 

(ADAMS Accession No. ML050550156) 

18) Letter from J. C. Butler, Nuclear Energy Institute, to S. N. Bailey, NRC, "Transmittal of 

GSI [Generic Safety Issue] 191 Resolution Criteria for "Low Fiber Plants," dated 

December 22, 2011. (ADAMS Accession No. ML 113570219) 

19) Westinghouse Topical Report WCAP-16530-NP-A, "Evaluation of Post-Accident 

Chemical Effects in Containment Sump Fluids to Support GSI-191 ," March 2008. 

(ADAMS Accession No. ML081150379) 

20) Westinghouse Topical Report WCAP-16406-P-A, "Evaluation of Downstream Sump 

Debris Effects in Support of GSI-191," Revision 1, March 2008. (ADAMS Accession 

No. ML081 000027) 

21) Letter from W. H. Ruland, NRC, to A. R. Pietrangelo, Nuclear Energy Institute, "Revised 

Guidance for Review of Final Licensee Responses to Generic Letter 2004-02, 'Potential 

Impact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents 

at Pressurized Water Reactors,"' dated March 28, 2008. (ADAMS Accession 

Nos. ML080230112 (letter), ML080230038 (Enclosure 1 ), ML080230462 (Enclosure 2), 

and ML080380214 (Enclosure 3)) 

22) Memorandum from Stephen J. Smith to Michael L. Scott, Branch Chief, "Staff 

Observation of Testing for Generic Safety Issue 191 During July 12 to July 14, 2010, 

Trip to the Alden Test facility for PCI Strainer Tests," dated August 19, 2010. 

(ADAMS Accession No. ML 1 02160226) 

23) U.S. Nuclear Regulatory Commission, "Standard Review Plan for the Review of Safety 

Analysis Reports for Nuclear Power Plants: LWR Edition- Engineered Safety Features," 

NUREG-0800, Section 6.2.2. 

24) U.S. Nuclear Regulatory Commission, "Standard Review Plan for the Review of Safety 

Analysis Reports for Nuclear Power Plants: LWR Edition- Design of Structures, 

Components, Equipment, and Systems - Other Seismic Category I Structures," 

NUREG-0800, Section 3.8.4. 
- 41 -

25) Nuclear Energy Institute Document NEI 02-01, Revision 1, "Condition Assessment 

Guidelines: Debris Sources Inside PWR Containments," September 30, 2002. 

(ADAMS Accession No. ML030420318) 
J. Shea - 2-

maintained within the bounds of the analyses and design-bases that support ECCS and CSS 

recirculation functions, and (3) install new throttle valves in the chemical volume control system 

and safety injection system lines to the reactor coolant system, opened sufficiently to preclude 

downstream blockage. The above required actions are confirmatory inspection items. 

The NRC staff performed a thorough review of the TVA responses to GL 2004-02 and 

concluded that TVA's response to GL 2004-02 is acceptable. The NRC staff conclusions have 

been documented in the enclosure. Based on the NRC staff conclusions, the NRC staff finds 

the information provided demonstrates that debris will not inhibit the ECCS or CSS performance 

of its intended function in accordance with 10 CFR 50.46 to assure adequate long term core 

cooling following a design-basis accident. Therefore, the NRC staff finds the licensee's 

responses to GL 2004-04 are adequate and pending completion of the confirmatory items 

discussed above, considers GL 2004-02 closed for the WBN Unit 2. No further information or 

action is requested of the applicant. 

If you have any questions, please call me at 301-415-2048 or via e-mail at 

Justin.Poole@nrc.gov. 

Docket No. 50-391 

Sincerely, 

IRA/ 

Justin C. Poole, Senior Project Manager 

Watts Bar Special Projects Branch 

Division of Operating Reactor Licensing 

Office of Nuclear Reactor Regulation 

cc w/ enclosure: distribution via Listserv 

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ADAMS Accession No.: ML14163A658 *Per memo dated March 1 0, 2014 

OFFICE DORULPWB/PM DORULPWB/PM DORULPWB/LA DSS/SSIB/BC (A)* 

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