RS-14-057, Units 1 & 2 - Responses to NRC Requests for Additional Information, Set 12, Dated February 19, 2014 Related to License Renewal Application
| ML14059A215 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 02/28/2014 |
| From: | Gallagher M Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-14-057 | |
| Download: ML14059A215 (16) | |
Text
10 CFR 50 10 CFR 51 10 CFR 54 RS-14-057 February 28,2014 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455
Subject:
Responses to NRC Requests for Additional Information, Set 12, dated February 10,2014, related to the Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, License Renewal Application
References:
- 1. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon) to NRC Document Control Desk, dated May 29, 2013, "Application for Renewed Operating Licenses."
- 2. Letter from Lindsay R. Robinson, US NRC to Michael P. Gallagher, Exelon, dated February 10, 2014, "Requests for Additional Information for the Review of the Byron Nuclear Station, Units 1 and 2, and Braidwood Nuclear Station, Units 1 and 2, License Renewal Application, Set 12 (TAC NOS. MF1879, MF1880, MF1881, AND MF1882)
In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 (BBS). In the Reference 2 letter, the NRC requested additional information to support the staffs' review of the LRA.
The Enclosure contains the responses to these requests for additional information.
There are no new or revised regulatory commitments contained in this letter.
February 28, 2014 U.S. Nuclear Regulatory Commission Page 2 If you have any questions, please contact Mr. AI Fulvio, Manager, Exelon License Renewal, at 610-765-5936.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 2., ~ f., Z<J/tf!
Respectfully,
~AIt(t Vice President - License Renewal Projects
- Exelon Generation Company, LLC
Enclosure:
Responses to Requests for Additional Information cc: Regional Administrator - NRC Region III NRC Project Manager (Safety Review), NRR-DLR NRC Project Manager (Environmental Review), NRR-DLR NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRC Project Manager, NRR-DORL-Braidwood and Byron Stations Illinois Emergency Management Agency - Division of Nuclear Safety
RS-14-057 Enclosure Page 1 of 14 Enclosure Byron and Braidwood Stations (BBS), Units 1 and 2 License Renewal Application Responses to Requests for Additional Information RAI 2.2-1 RAI 2.3.3.16-1 RAI 2.3.3.18-1 RAI 2.3.3.18-2 RAI 2.3.3.18-3 RAI 2.3.3.19-1 RAI 2.3.3.19-2 RAI 2.3.3.20-1 RAI 2.3.3.20-2 RAI 2.3.3.20-3
RS-14-057 Enclosure Page 2 of 14 RAI 2.2-1 Applicability:
Byron Station (Byron) and Braidwood Station (Braidwood)
Background:
License renewal application (LRA) Section 2.2 provides the results of applying the license renewal scoping criteria, described in LRA Section 2.1, to the systems, structures, and components (SSCs). The results are presented in LRA Table 2.2-1.
Issue:
The following Updated Final Safety Analysis Report (UFSAR) systems could not be located in LRA Table 2.2-1:
UFSAR Section System 3.9.2.7 Loose Parts Monitoring System Loose Parts Monitoring System E.17 Plant Safety Parameter Display System Safety Parameter Display System Request:
Please provide information explaining where these systems are considered in LRA, or provide justification for their exclusion.
Exelon Response:
The loose parts monitoring system is evaluated with the Miscellaneous Instrumentation System.
It is described in UFSAR Section 3.9.2.7 as shown on LRA Table 2.2-1. The loose parts monitoring system does not perform intended functions for license renewal, and failure of the loose parts monitoring system to perform its function will not affect the intended function of any other systems that are in the scope of license renewal.
The plant safety parameter display system is evaluated with the Plant Alarm and Annunciator System as shown on LRA Table 2.2-1. The plant safety parameter display system is described in UFSAR Section E.17. The plant safety parameter display system portion of the Plant Alarm and Annunciator System does not perform intended functions for license renewal, and failure of the plant safety parameter display system to perform its function will not affect the intended function of any other systems that are in the scope of license renewal.
RS-14-057 Enclosure Page 3 of 14 RAI 2.3.3.16-1 Applicability:
Byron and Braidwood
Background:
LRA Section 2.1.5.2 (pg. 2.1-21) states:
For nonsafety-related piping connected to safety-related piping, the nonsafety-related piping was assumed to provide structural support to the safety-related piping if the nonsafety-related is within the analytical boundary of the CLB [Current Licensing Bases] seismic analysis Generally, the analytical boundaries are located at anchor points. In cases where it is impractical to seismically model a piping system from anchor point to anchor point, the analytical boundary can be truncated by utilizing a series of supports designed such that the effects of the piping truncated from the model would not change the response of the piping within the analysis boundary.
Issue:
On LRA drawings LR-BYR-M-65 Sheets 3 and 6 (C1) and LR-BRW-M-65 Sheets 3 and 6 (C1),
the staff could not locate seismic anchors on the 10 CFR 54.4(a)(2) non-safety related lines 0AS35AB 2 and 0AS35AA 2, respectively, continued from M-56 Sheet 4A (E6/E8) to safety-related valve BEF-40 on LR-BYR/BRW-M-65 Sheets 3 and 6 (D5).
Request:
The staff requests additional information on the location of the seismic or equivalent anchor between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.
Exelon Response:
At Byron, structural support for the safety-related valves BEF-40 (0AB5040A and 0AB5040B) shown in green on LR-BYR-M-65, Sheets 3 and 6 (D-5) respectively, is provided by an equivalent anchor consisting of a combination of supports that encompass at least two (2) supports in each of the three (3) orthogonal directions. These supports are located between the safety/non-safety interface and the point on piping line 0AS96A 10, shown in red, just upstream of the pipe tee where line 0AS03KB 6 connects and prior to 0AS96A 10 passing into the turbine building where the (a)(2) boundary ends. (LR-BYR-M-56, Sheet 4A, F-4)
Piping line 0AS35AA 2 connects to line 0AS03KA 6 which then becomes 0AS96A 10. The opposite end of 0AS03KA 6, shown in red, terminates into 0AS02DB Recycle Evaporator where the shell is classified as safety-related and is shown in green on LR-BYR-M-65, Sheet 6 (C-2). 0AS02DB Recycle Evaporator is a base mounted component that is designed not to impose loads on connected piping.
RS-14-057 Enclosure Page 4 of 14 Piping line 0AS35AB 2 connects to line 0AS03KB 6 which then connects to line 0AS96A 10.
The opposite end of 0AS03KB 6, shown in red terminates into 0AS02DA Recycle Evaporator where the shell is classified as safety-related and is shown in green on LR-BYR-M-65, Sheet 3 (C-2). 0AS02DA Recycle Evaporator is a base mounted component that is designed not to impose loads on connected piping.
LR-BYR-M-56, Sheet 4A, is revised to add equivalent anchor symbol F.4.4 at coordinate F-4 on line 0AS96A 10 just to the left of the Auxiliary Building to Turbine Building wall.
At Braidwood, structural support for the safety-related valves BEF-40 (0AB5040A and 0AB5040B) shown in green on LR-BRW-M-65, Sheets 3 and 6 (D-5) respectively, is provided by equivalent anchors consisting of combinations of supports that encompass at least two (2) supports in each of the three (3) orthogonal directions. These supports are located between the safety/non-safety interfaces and the points on piping lines 0AS96A 10 and 0AS03KB 6, shown in red, prior to the lines joining together and passing into the turbine building where the (a)(2) boundary ends. (LR-BRW-M-56, Sheet 4A, F-4)
Piping line 0AS35AA 2 connects to line 0AS03KA 6 which then becomes 0AS96A 10, shown in red. 0AS03KA 6 terminates into 0AS02DB Recycle Evaporator where the shell is classified as safety-related and is shown in green on LR-BRW-M-65, Sheet 6 (C-2). 0AS02DB Recycle Evaporator is a base mounted component that is designed not to impose loads on connected piping.
Piping line 0AS35AB 2 connects to line 0AS03KB 6 which then connects to line 0AS96A 10, shown in red. The opposite end of 0AS03KB 6 terminates into 0AS02DA Recycle Evaporator where the shell is classified as safety-related and is shown in green on LR-BRW-M-65, Sheet 3 (C-2). 0AS02DA Recycle Evaporator is a base mounted component that is designed not to impose loads on connected piping.
LR-BRW-M-56, Sheet 4A, is revised to add equivalent anchor symbol F.4.4 at coordinates E-4 and F-5. At coordinate E-4, the equivalent anchor symbol is located to the right of valve 0AS127B. At coordinate F-5, the equivalent anchor symbol is located to the left of the connection to line 0ASM8A 1.
RS-14-057 Enclosure Page 5 of 14 RAI 2.3.3.18-1 Applicability:
Byron
Background:
LRA Section 2.1, Scoping and Screening Methodology, describes the applicants scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to aging management review (AMR) by reviewing the results of the screening of components within the license renewal boundary.
Issue:
License renewal drawing LR-BYR-M-78 Sheet 7 (C8 and D5) has in scope continuations to M-44 Sheet 3C. Drawing M-44 Sheet 3C was not provided with the LRA.
Request:
The staff requests the applicant provide sufficient information to locate the license renewal boundary. If the continuation cannot be shown on license renewal boundary drawings, then provide additional information describing the extent of the scoping boundary and verify whether or not there are additional component types subject to AMR between the continuation and the termination of the scoping boundary. If the scoping classification of a section of the piping changes over the continuation, provide additional information to clarify the change in scoping classification.
Exelon Response:
LR-BYR-M-78, Sheet 7 shows equipment supporting the Radiation Monitoring System. The drawing shows schematic representations of two types of monitoring skids used at Byron and they are labeled as Detail A and Detail B. Each is highlighted to show what sub-components would be included within the scope of license renewal for a typical in-scope monitor. The text in the table located directly below the schematic representations is highlighted to represent which particular monitors are within the scope of license renewal. The license renewal drawings are produced from the stations piping and instrumentation drawings (P&IDs). Based on the P&ID convention, the Detail A drawing shows the subcomponents and continuation details associated with the station blowdown radiation monitor, which is the first radiation monitor listed in the table. Since the station blowdown radiation monitor is not in scope for license renewal, as can be inferred from the table based on the font color of the component IDs (except for an editorial error that is further discussed below), the interfacing drawing, M-44, Sheet 3C was not provided as a boundary drawing.
As noted above, during the review of this issue it was found that an editorial error exists. The table shows 0RE-PR010 (B) as red. As the station blowdown radiation monitor is not in scope, this should be shown in black. LR-BYR-M-78, Sheet 7, at coordinate C-7, is revised to change the font color of 0RE-PR010 (B) to black.
RS-14-057 Enclosure Page 6 of 14 RAI 2.3.3.18-2 Applicability:
Braidwood
Background:
LRA Section 2.1, Scoping and Screening Methodology, describes the applicants scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.
Issue:
On license renewal drawing LR-BRW-M-78 Sheet 6 (C4), the continuation of piping in scope for license renewal was not provided for the continuation of line 1PR23B 2.
Request:
The staff requests the applicant provide additional information to locate the license renewal boundary. If the continuation cannot be shown on license renewal boundary drawings, then provide additional information describing the extent of the scoping boundary and verify whether or not there are additional component types subject to an AMR between the continuation and the termination of the scoping boundary. If the scoping classification of a section of the piping changes over the continuation, provide additional information to clarify the change in scoping classification.
Exelon Response:
LR-BRW-M-78, Sheet 6 shows equipment supporting the Radiation Monitoring System. At coordinate C-6, the drawing shows the configuration for the equipment hatch and personnel air lock containment air particulate and iodine samplers. Piping line 1PR23B 2 at coordinate C-4, and line 1PR22A 2 at coordinate C-8, are short lengths of piping (one foot or less) that extend into the containment air space and are open-ended. The arrow shown is used to denote the direction of air flow through the sampler and not meant to depict a continuation. Therefore, there are no additional component types subject to AMR since this piping (one foot or less) is the termination of the scoping boundary.
RS-14-057 Enclosure Page 7 of 14 RAI 2.3.3.18-3 Applicability:
Braidwood
Background:
LRA Section 2.1, Scoping and Screening Methodology, describes the applicants scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.
Issue:
License renewal drawing LR-BRW-M-78 Sheet 6 (A5) shows nonsafety-related outlet line number 1PR23B 2 highlighted in green indicating it is in scope for 10 CFR 54.4(a)(1). However, at location (C4), this line is highlighted red indicating the line is in scope for 10 CFR 54.4(a)(2).
Request:
The staff requests the applicant clarify the scoping classification of line 1PR23B 2.
Exelon Response:
The piping and instrumentation drawing found on LR-BRW-M-78, Sheet 6, at coordinate C-6 correctly shows nonsafety-related outlet piping line number 1PR23B 2 highlighted red indicating the line is in scope for 10 CFR 54.4(a)(2). The associated table found directly below incorrectly shows this line number highlighted in green indicating it is in scope for 10 CFR 54.4(a)(1). The inlet and outlet line numbers for the piping beyond the safety class symbols (IB l IID) should be shown in red as these piping lines are nonsafety-related but provide structural support for the safety-related lines that maintain the containment boundary. The table on LR-BRW-M-78, Sheet 6 is revised to show the following piping line numbers highlighted in red: 1PR22B2, 2PR22B2, 1PR24B2, 2PR24B2, 1PR23B2, 2PR23B2, 1PR25B2, 2PR25B2.
RS-14-057 Enclosure Page 8 of 14 RAI 2.3.3.19-1 Applicability:
Braidwood
Background:
LRA Section 2.1.5.2 states in certain instances the analytical boundaries of the CLB seismic analysis are not clearly defined. In these cases, nonsafety-related piping was included in scope for 10 CFR 54.4(a)(2) for the entire run of nonsafety-related piping that is connected at both ends to safety-related piping.
Issue:
On LR-BRW-M-64 Sheet 4A (B7), lines 1WEC4A and 1WEC2A are shown with an F.4.d symbol indicating nonsafety-related piping runs are connected at both ends to safety-related piping. The continuation to LR-BRW-M-48 Sheet 29 (B7) does not connect to safety-related piping.
Request:
The staff requests the applicant provide justification for the F.4.d symbols on LR-BRW-M-64 Sheet 4A.
Exelon Response:
LR-BRW-M-64, Sheet 4A (B-7) incorrectly shows the F.4.d symbol at the safety-related to nonsafety-related interface located at valves 1CV010A and 1CV010B. Structural support for the safety-related equipment shown at this location is provided by the elevation 383-0 floor, as shown on LR-BRW-M-48, Sheet 29. These lines are seismically anchored into the concrete floor (see embedded pipe notation at coordinate A-7). LR-BRW-M-64, Sheet 4A, at coordinate B-7, is revised to remove the F.4.d symbols from piping lines 1WEC4A 2 and 1WEC2A 2.
LR-BRW-M-48, Sheet 29, at coordinate B-7, is revised to show the flags that identify the endpoints of piping subsystems [1CV88] and [1CV098] highlighted in blue to indicate that the floor acts as the seismic anchor for the attached safety-related piping.
RS-14-057 Enclosure Page 9 of 14 RAI 2.3.3.19-2 Applicability:
Braidwood
Background:
LRA Section 2.1.5.2 states in certain instances the analytical boundaries of the CLB seismic analysis are not clearly defined. In these cases, the nonsafety-related piping was included in scope for 10 CFR 54.4(a)(2) for the entire run of nonsafety-related piping that is connected at both ends to safety-related piping.
Issue:
On LR-BRW-M-138 Sheet 4B (A/B7) lines 2WEC4A and 2WEC2A downstream of valves 2CV010A and 2CV010B are shown with an F.4.d symbol indicating nonsafety-related piping runs are connected at both ends to safety-related piping. The continuations to LR-BRW-48 Sheet 29 (B5) do not connect to safety-related piping.
Request:
The staff requests the applicant provide justification for the F.4.d symbol on LR-BRW-M-138 Sheet 4B.
Exelon Response:
LR-BRW-M-138, Sheet 4B (A-7 and B-7) incorrectly shows the F.4.d symbols at the safety-related to nonsafety-related interface located at valves 2CV010A and 2CV010B. Structural support for the safety-related equipment shown at this location is provided by the elevation 383-0 floor, as shown on LR-BRW-M-48, Sheet 29. These lines are seismically anchored into the concrete floor (see embedded pipe notation at coordinate A-7). LR-BRW-M-138, Sheet 4B, at coordinates A-7 and B-7, is revised to remove the F.4.d symbols from piping lines 2WEC4A 2 and 2WEC2A 2. LR-BRW-M-48, Sheet 29, at coordinate B-5, is revised to show the flags that identify the endpoints of piping subsystems [2CVF31] and [2WEF47] highlighted in blue to indicate that the floor acts as the seismic anchor for the attached safety-related piping.
RS-14-057 Enclosure Page 10 of 14 RAI 2.3.3.20-1 Applicability:
Byron
Background:
In LRA Section 2.1.5.2, the applicant states for nonsafety-related piping connected to safety-related piping, the nonsafety-related piping is assumed to provide structural support to the safety-related piping if the nonsafety-related piping is within the analytical boundary of the CLB seismic analysis Issue:
On LRA drawing LR-BYR-M-69 Sheet 1 (E2, E3, E4, E6, E7 and E8), the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) non-safety related lines 0GW04AA, 0GW04AB, 0GW04AC, 0GW04AD, 0GW04AE, and 0GW04AF, all of which are continued from M-69 Sheet 2 (D4) to safety-related valves 0GW9297A, 0GW9297B, 0GW9297C, 0GW9297D, 0GW9297E, and 0GW9297F, respectively.
Request:
The staff requests the applicant provide additional information to locate the seismic or equivalent anchors between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.
Exelon Response:
Piping lines 0GW04AA 1 through 0GW04AF 1 shown in red, which are continued from safety-related valves 0GW9297A through 0GW9297F shown in green, are joined in piping manifold 0GW04B 1 shown in red (LR-BYR-M-69, Sheet 1). After passing through pressure control valve 0GW9293, the line divides into four lines.
- 1) Piping line 0GW04C 2, the central pipe shown in red, continues to 0AB029, a safety-related valve shown in green, found on LR-BYR-M-65 Sheet 2A, at coordinate E-3. No anchor symbol is identified on this pipe line since it re-connects to safety-related equipment.
- 2) Piping line 0GW17A 2 shown in red, branches off of line 0GW04C 2 at coordinate F-1.
Structural support for 0GW17A 2 is provided by an equivalent anchor on 0GW17A 2 consisting of a series of supports that encompass at least two (2) supports in each of the three (3) orthogonal directions. The location of this anchor is the end of the 10 CFR 54.4(a)(2) scoping boundary. Piping beyond this point does not have the potential for spatial interaction as it does not contain water, steam, or oil. This equivalent anchor is identified on LR-BYR-M-69, Sheet 1, at coordinate F-2, with symbol F.4.4 located on line 0GW17A 2 where the line turns from red to black, below Note 3.
- 3) Piping line 0GW60A 3/4 shown in red, branches off of line 0GW04C 2 at coordinate F-1.
This pipe line does not perform a structural support function since this is a smaller
RS-14-057 Enclosure Page 11 of 14 branch line that does not impose loads on the larger piping and does not support the larger piping. As such, this piping is decoupled from the larger piping in the CLB seismic analysis, as indicated by the piping subsystem boundary located at the branch connection [1GW514l1GW513]. LR-BYR-M-69, Sheet 1, at coordinate F-1, is revised to add anchor symbol F.4.f at the point where branch line 0GW60A 3/4 connects to header piping line 0GW04C 2.
- 4) Piping line 0GW09D 2 shown in red, branches off of line 0GW04C 2 at coordinate F-1.
Structural support for 0GW09D 2 is provided by an equivalent anchor consisting of a series of supports that encompass at least two (2) supports in each of the three (3) orthogonal directions. However, LR-BYR-M-69, Sheet 1, fails to identify the appropriate anchor symbol to indicate the location of the equivalent anchor for this piping. LR-BYR-M-69, Sheet 1, at coordinate F-1, is revised to add anchor symbol F.4.4 located on line 0GW09D 2 where the line turns from red to black, below Note 3. The location of this anchor is the end of the 10 CFR 54.4(a)(2) scoping boundary. Piping beyond this point does not have the potential for spatial interaction as it does not contain water, steam, or oil.
RS-14-057 Enclosure Page 12 of 14 RAI 2.3.3.20-2 Applicability:
Braidwood
Background:
LRA Section 2.1, Scoping and Screening Methodology, describes the applicants scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.
Issue:
License renewal drawing LR-BRW-M-48 Sheet 31 (C1) shows nonsafety-related line number 0AC07A 1 connected twice to the in scope Sulfuric Acid Day Tank as not highlighted, indicating it is not in scope for license renewal. Note that on LR-BYR-M-48 Sheet 31 (C1), this line is in scope for 10 CFR 54.4(a)(2).
Request:
The staff requests the applicant clarify the scoping classification of line 0AC07A 1 on LR-BRW-M-48 Sheet 31.
Exelon Response:
LR-BRW-M-48 Sheet 31, at coordinate C-1, incorrectly shows piping line 0AC07A 1 connected twice to the in scope Sulfuric Acid Day Tank. Because of this drawing error, line 0AC07A 1 is incorrectly shown as not in scope. This pipe attaches to the top of the Sulfuric Acid Day Tank and connects to drain line 0AC15A 11/2 (not to the side of the Sulfuric Acid Day Tank as shown on the boundary drawing). Since some drain lines may contain low points which may not completely drain of liquids, they are included in scope per 10 CFR 54.4(a)(2). Therefore, since Braidwood line 0AC07A 1 is connected to drain line 0AC15A 11/2, it is assumed that 0AC07A 1 could contain liquid and is included in scope per 10 CFR 54.4(a)(2). LR-BRW-M-48, Sheet 31, at coordinate C-1, is revised to show the correct configuration of line 0AC07A 1 and to add line 0AC07A 1 and the associated breather vent in scope for 10 CFR 54.4(a)(2) with the components shown in red. The breather vent is included with piping, piping components, and piping elements for license renewal aging management review.
RS-14-057 Enclosure Page 13 of 14 RAI 2.3.3.20-3 Applicability:
Braidwood
Background:
In LRA Section 2.1.5.2, the applicant states for nonsafety-related piping connected to safety-related piping, the nonsafety-related piping is assumed to provide structural support to the safety-related piping if the nonsafety-related is within the analytical boundary of the CLB seismic analysis.
Issue:
On LRA drawing LR-BRW-M-69 Sheet 1 (E2, E3, E4, E6, E7 and E8), the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) non-safety related lines 0GW04AA, 0GW04AB, 0GW04AC, 0GW04AD, 0GW04AE, and 0GW04AF all of which are continued from M-69 Sheet 2A (E2) to safety-related valves 0GW9297A, 0GW9297B, 0GW9297C, 0GW9297D, 0GW9297E, and 0GW9297F, respectively.
Request:
The staff requests the applicant provide additional information to locate the seismic or equivalent anchors between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.
Exelon Response:
Piping lines 0GW04AA 1 through 0GW04AF 1 shown in red, which are continued from safety-related valves 0GW9297A through 0GW9297F shown in green, are joined in piping manifold 0GW04B 1 shown in red (LR-BRW-M-69 Sheet 1). After passing through pressure control valve 0GW9293, the line divides into three (3) lines.
- 1) Piping line 0GW04C 2, the central pipe shown in red, continues through valve 0GW9294 and divides into three (3) lines (0GW04A 3/4 continuing from M-65-2A, 0GW17A 2 continuing to M-65-2A, and 0GW17A 2 continuing to M-69-2). Structural support for line 0GW04C is provided by a seismic anchor identified by the piping subsystem boundary found on LR-BRW-M-69, Sheet 1, at coordinate F-1, and identified as
[1GW513Bl1GW601B] highlighted in blue. The 10 CFR 54.4(a)(2) boundary extends beyond this anchor point due to spatial interaction.
- 2) Piping line 0GW65A 3/4 shown in red, branches off of 0GW04C 2 at coordinate F-2. This pipe line does not perform a structural support function since this is a smaller branch line that does not impose loads on the larger piping and does not support the larger piping.
As such, this piping is decoupled from the larger piping. LR-BRW-M-69, Sheet 1, at coordinate F-2, is revised to add anchor symbol F.4.f at the point where branch line 0GW65A 3/4 connects to header piping line 0GW04C 2.
RS-14-057 Enclosure Page 14 of 14
- 3) Piping line 0GW09D 2 shown in red, branches off of line 0GW04C 2 at coordinate F-1.
Structural support for 0GW09D 2 is provided by an equivalent anchor consisting of a series of supports that encompass at least two (2) supports in each of the three (3) orthogonal directions. However, LR-BRW-M-69, Sheet 1, fails to identify the appropriate anchor symbol to indicate the location of the equivalent anchor for this piping. LR-BRW-M-69, Sheet 1, at coordinate F-1, is revised to add anchor symbol F.4.4 located on line 0GW09D 2 where the line turns from red to black, below Note 3. The location of this anchor is the end of the 10 CFR 54.4(a)(2) scoping boundary. Piping beyond this point does not have the potential for spatial interaction as it does not contain water, steam, or oil.