ML16340D987
| ML16340D987 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/07/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM) |
| Shared Package | |
| ML16340D988 | List: |
| References | |
| NUDOCS 8311170391 | |
| Download: ML16340D987 (64) | |
Text
HOY 0 7 1983 DJ FOR C)airman Palladino Commissioner Gilinsky Camissioner Roberts Commissioner Assel-stine Commissioner Bernthal i)h~~ ~
I ~IV I ~
Uilliam J. Dircks
'Executive Director for Operations atter,g>> CT.
DIABLO CAtlYOll Fnclosed in response to the Secre ary's limited distribution memorandum of llovember 4, 1~83, on Diablo Canyon is the staff evaluation of items previously identified as requiring resolution.
The enclosed evaluation discusses each o
ihe 31 open items identified in Table C.o.l of SER Supplement t!o. 19 and the 15 folio.-up items in Table C.8.3 o, that s oplement.
It concludes that all items designated for resolution prior.o authorization of S.ep 1 (fuel load) have been acceptably resolved for Step l.
The evaluaiion also provides the basis for the staf, conclusion that resolution of the remaining items can bo de erred to a la er time.
Since the ei~aluation is being furnished to the Commission in response
.o a limited distri bution memorandum from the Secretary, the enclosed sta,f evaluation has not been made available publicly or to the other p~rties, The sta f has no objection to releasing this evaluaiion to
-.he parties and to the public.
l!>lliam J.
Oircl;s
~
~
Executive Director for Operations Encl osur e:
~~.s s iated cc v!/encl.
SECY Ql\\C OPE 8311170391 831109 PDR ADOCK 05000275 P
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STAFF EVQ.NTJO l OF ITHH 1D"-fiTEF120 AS RdPLPIfiB PESOLUTHH)
SER Supplet nt @). 19, Table C.8,1, identified 31 ops i~ fro" the SER Suppler=-nt Ho.
18 revie: performed by the staff diich spire resolution.
Furth r, S-R Supplant Ho..19, Table C.8.3, identified 15 folio;-:up items Wch require only confimatory documentation, testing or staff verification to cmlete.
All aadifications identified thus far regarding the WloM-up its have b
n c(depleted subject to verification by the saff.
The folio-ing is the st-tus and scfadule for c~letion of -tne 31 open item end 15 foll+-up item nth respect to the three-st p licensing approach approved by 'O'p Caii0ission.
t.
~3l 3: It All of the 31 i~s list< in SER Supplmwt th.
18 had undergone substantial evaluation during the course of the stiff reviei up to the publication date of the supple nt, Th items listed represent d th. residual of the discussions and informtion axchang s that took place over the pr'evious 18 ax>nths.
Ster i Of the 31 open iteus,
.15 (numbers 1 through 4; 7, 10, 16, 17,
$8, 19, 23, 24.
27, 30 and 31) mre designated for resolution pr ior to authorization of Step 1
(fuel lo"d) based on the following general criteria:
(a) fhtters related to tM contairmnt or containnant internal structuresg or (b} fhtters related to other structures, system and cmqonents required by the plant technical specifications to be op rab)e during rides 5'
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and 6 dere the potential for significant reanalysis or mdifications could not be classÃie5 as highly unlikely based on th staff revie and audits up to that tie ;
(c). hatt ts requiring ari early cmwtaant to assure the aepletion of confi~tory ana1yses prior to authorization of full peer op ration.
Bin of the 15 items required for Step 1 (n~rs 3, 4, 7, M, N, 19, 23, 24 and 27) mew ful'}yresolved in SER Supplant Ya, 19.
The rmsining six i'-.is (n~rs I, 2,'D, 18, 29 and 30) are discussed irdivfdually klo~.
For e"-ch of the six items, th: licensee's responses provided significant addition-1 infarction tet, although those reponses appeared resonable, they either i~re inctrplete in terms of technical content required for full doc~nt tion or contained so apparent inconsistencies that needed to be clarified.
'i.
Fre -hand averaging of sp ctra for containri nt annulus structure should b
in accordance with staff-approved technique.
(5SER M, page C.3-9; SSER 19, paje C.3-1) lt i.".s not clear, based on e"isting documentation suh;,itted that acc pebble sp cpm averaging techniques had few uniformly applied throughout the reverification effort.
The inforriation submitte in the PKE responses on this m>tter, dated August 30, Septerab r 9, and October 12, 19B3, contained smples of sp ctra that had obviously teen plotted incorrectly although the text of the response and previous.
discussions Mith the engineering staf'f of the Oiablo Canyon Project indicated that acceptabl'e practices had boen ~ii loyed.
Correctly
g plotted sp ctra m~re sutaittM on 0".tob r N, I983, and this iss~~ is no'~ considered resolved.
2.
Cutoff frequency for 20 Hz for g neration of f3o~r response spa:tra in contair~nt annulus stre tuse'should
- b. justified.
(SSKR 18, papa C.3-9; SSER 19, page C.3-2j an annulus steel structure has 5 en stiffened to assure that all structural ~mrs have a priory response frequmcy of 20 Hertz or abr.e, referred to as a
2D Hertz cutoff frequency.
The ener gy available I
in seis.".:ic ground aration drops off rapidly frow approxirr~tely 20 Hertz to 33 h=-rtz,.
At 33 Hertz no amplification of the ground mtion input occurs.
In tie 20 Hertz to 33 fLrtz range so".-~ clif'ication can theoretically occur in the annulus structure.mO an atMdant increase.
in the acceleration experien"ed by piping support% by the annulus amours.
The KP has provide analyses of the cg;boned stru."tvre-piping system that indicate very snail effects du to erylification in the 20 H rtz to 33 Hertz 'range.
Although so.
additional analyses nay be requested by the staff to provide a w)l docL nted record for future reference,'he st-ff review to de~~ fes progressed to the point Here the li elihood of additional tmdifications is le..
Any nodifications Ai h rray bnecessary vill not likely affec't systems or cL~onents needed for fuel load or otherwise interfere Rth activities associated vith nodes 5 and 6.
Therefore it is acceptable to the st ff to consider. this nett r resolved f'r Step I.
17.
Buckling criteria for linera supports, sp cifically the Euler buckling equation for calculating critical buckling loads for all slenderness
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ratios, should b
evaluated and justified.
(USER 18, p.g 6.3M:
Sc:g go, paoe C,3-g)
This itm relates to an interpretation of subsection HF of the AS'oHer and Pressure Vessel Code.
Specifically, the staff does not accept the upper rang of the design curve mqloyed by tb KP to ixyle. nt th cthe requimmnts for evaluation of allaabke hrckling lmds (compressive stress}
on sera pipe support smb.rs.
In a response pmvidM dur ing a transcr)ted naeting on Rytmbar 28, H33, "ie D"P stated th"=~ the r-tter ms lars ly rmt temuse the upp
- r. rang 0", th d.sign curve ~as t.arely, if ever, umph'due ta th nature of the supports at Ohb1o Canyon,.i.e.,
short, stiff m"b rs with lm co~ressive stresses.
In a suWtta1 dated 0".tob
", 6, 19S3, the 0"P provided a s~,pie of calculat< mqressive stress fry 24 supports d~nstrating co~mssive stresses v 11 nothin the rang consistent 6th tie staff's interp~tation of th ASK= Code intent.
At a staff audit in San Francisco on Octob r 25<<26, l983, the KP agreed to provide the cwpressive stress data for approxirretely 400 supports (on the order of 450 individual supports are in Unit I) throJghout Unit 1 to provide final confirmation.
Tne progress of the staff revie~ to date indicates that the )ike1ihood of additional aedificatioas is late.
Any radifications Arch tray b a cessary rill not lit:e)y affect systems or co~nents needed for fuel load or others'ise interfere xith activities associated
~ith mvhs 5 and 6.
Therefore it is acceptable to the staff to consider this ratter absolved f'r Step L.
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18.
Calculations for selected piping systems analyzed yrevi'ously in IiR 12 ar3 ITR 17 should b
reputed with revised support configurations and current landings to verify that piping and supports satisfy corresponding design criteria.
R suits of piping system re valuation with high th re load should be'erified.
(SSER l8, page C.3-4S; SSER }9, page C.3-5)
This r-.tter concerns a comit nt to p rforra confimatory ana'Iyses of tm piping system.
Because this is a long-lead'iten, the staff required a euzmtzent to performs'the required analyses prior to approval of Step 1 in order to insure timly aepletion of th task.
promlures and criteria for all piping analys s p rforr~d by th KP
- v. re revie~ and found acceptable by t¹ IDYP.
Hx, ver, consistent 4th current practice. following th> five-plant shutdo'n in }979, th'taff recp$ res a final confirratory analysis to ba p rior d by an.
independ nt party, in this instance th IDYP.
Th~ IOYP has initiated confirretory analyses on bo piping system se1ectH by the staff".
B.sed on the IMP results, the staff concludes tNat no significant nxdifications are likely to be quired.
Any mdifications erich aalu b
necessary e01 not, like'lyiffect systems or co,".,paints need< for fuel load or.othe~hse interfere with activities associated
~1th modes 5 and 6. It is therefore acceptable to th. staff to consider this ratter resolved for Step l.
29.
Consideration of jet impingent loads in design and qualification of all safety-related piping and equitant should b
clearly dsmnstratM.
(SSER 18, pay C.4-29; SSER 19, page C.4-.2)
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Pz noM in SER Supp)~nt No. 39, the suff concluded that the licensee.
nas art the FSAR co=itmnt regarding the consideration of jet i~)nga"nt lo ds inside contairrsnt, confirming the ba,sis upon Ai)ch th operating license ms originally granted.
Under cont~rary staff practice, aspects of jet irpingeat nt analyses that x re jud~nta$ for. plants of th Diablo Canyon era are required to be dmanstrated'y deterministic analyses.
To provide the basis for a jet ioqingxmnt evaluation
.consistent with current practin, the IKP Ias c~)eted a pipe break and jet target evaluati~,
and this effort has b.en revi~ and found acceptable to cut rent standards by the IDVP.
Based on this source and target eva'tuation.
certain piping and structural ~b rs that couM b subje tM to >et loading, in the unlikely event that a large pip. rupture occurred inside coztairmnt, are currently b ing evaluated by aralysis to dete~n debat, if any, additional pro~tion Light be required to fully a et current requirements.
~fn consid ration of the possible irpast on construction efforts, this i's upgraded fry Step 2 as shown'in Table C.S.l of 'SER Supplement ho.
18 to Step 1 as show in SER Supplement Ro, 19.
The progress of the jet impinge nt evaluation discussed above is sufficient to d~nstrate that the licensing basis for the Diablo. Canyon Plant has been mt and that significant aodifications to fullyneet current jet
<nqin~nt protection requi~nts are unlikely.
Any modifications dutch nay be necessary nil not likely affect systems or aapwents
'eeded for fuel load or otherwise interfere vith activities associated
~Iith nodes 5 and 6, Therefore it is acc pebble to the staff to cL>sider this niattel resolved for Step 1;
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- 39. It should b clearly indicaad that rupture restraints inside and outside contain ~nt have b:en properly designed and. installed.
(SSEP, 18, page C.4-31; SSER 19, @g C.4-2)
As noted in SER Supplant Ho. 19, the rratters ranain$ ng for final closure of this, iten related to a staff audit of the test da+x and design criteria ~'foyed for.those pip. Nip restraints inside conwiramt that contain crushable b~~rs.
Restraints of th tge under consideration are required only in the unlikely event of a complete rupture of a pipe.
confining high erargy fluid and are therefore Mt required dur ing rides 5
w~~d 6, sia".e al1 systms inside cmtainmnt are essentially unpressurized, Furth r, th JDYP and staff revim of this r-tt r fes progressed to tie point Sere the likelihood of signific nC additiona1 mdifications is lo.
Any cxfifications Reich r.*y 8 necessary vill not 1$kely affect syst~ or cmponents n ehd for fuel load or otherwise, interfere rith activities associated 4th codes 3 and 6.
Therefore it" is acceptabie to the staff to consider this issue resolved for Step l.
Sten 2
The N items listed in SFR Supp1mant Ho.
18 as designated for c~letion prior'o authorization of Step 2 (lw-pomr testing up to 5X peer)
(nickers 5, 6, 8, 9', lZ, 14, 13, 20, H, 22, 23, 26, 29 and 3l) mre selected b-sed on the follming g rural cr.iteria:
(a)
Y.tters re3ated to structures, system and opponents that are not required to te oper ab3e by the plant technical specifications for'des 3 and 6 (Step 1); or.
(b)
Vetters that have b en sufficiently reviews to allm an assessment that the likelihood of additional significant modifications is 1m.
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wsm~tions in andri for auxiliary building Poor slab qualific"tion recur ding rigidityjflexibilitysleuld be clarified and justified, inc'}uding docen ntation of parametric studies.
(SS~R 18, pa@
C.3-22)'Jm seismic stick aadel used by the DCP to predict the structural loads and produce th floor'esponse spectra is of the generally'ccepted for nornal seislnic analysis and has many simplifications and inh rent assumptions.
On assmpUon is that th floor slabs are rigid as c~red to the calls.
The DCP use of a hand. calculation a thod for distributing.
the stick tA 1 responses to the individual el~nts resisting the loads, resulted in higher stresses than al'1~ble in the floor slabs.
T¹ KP had used the concept or" floor slab flexibUity to redistribJte loads as a b sis for explaining this apparent overstress condition.
This e~lanation ms not acceptable to the staff.
Th D="P subs~u ntly constructed a three<<dimnsional finite el~nt uodel to a@re. realistically
~ distribute the stick aodel loads to th. resisting eler nts.
The results of this finite elephant analysis indicate the stresses in the Boor slabs are nothin the code alleebles.
The IDVP has verified arid accepts the aathodology used by POTE.
The staff is currently ceapleting its revim of this ri~tter.
Tfx progress to date for he resolution of the staff concern indicates that the possibility of additional significant radifications to the structure is reste, Any nad$ f<cations Rich nsy b
necessary Nil} not likely affect systems or ceaponents needed for ful load or otherwise interfere with activities associated with nades 5 and 6.
Therefore it is acceptab)e to th staff to dofer the resolution of Se auxiliary building floor slab apparent overstress to Step 2.
a 0
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6.,
Use of different versions of ACL code in F5'nd in design ver(fication effort of auxiliary b~ilding should be justified.
(SSER 18, page C.3-22)
The ACI 318-63 code is the b sis for. the acceptance criteria far d sign.
Df die auÃiliag'u'Hding<<Th'fs 1963 version of the code do s not expl)citly provide, guidance in evaluating in-p'lane forces in sh ar ills although Section l04 of ACE 3}8-63 all~ crit ria based on test data
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to b used for the d.sign of structural components for loads not covered by its provisions.
Initfally, th ITP used the ACI 3M-77 cow, which explicitly prov~des criteria for in-plane shear, untH criteria could b
developers consist nt with the provisions of ACI 3}8-63.
Th ITP d&elopaf Appendix 2A to the Phase I Final fL~port to provide criter ia for evaluating the in-plane loads.
Th provisions of this d.agent are b=-sed on available t st data for'n-plane sh ar consistent 8th tho.
ACI 318-63 code originally accepted; the ACl 3}8-77 code was usM 4'he ITP for the final~r evaluation of st rmbars and fs mre conservative than Appendix ZA, By using ACI 3}8-77, the provisions of App ndix 2A (atd, th refore, ACI 318-H) are also est.
Mi LOYP has verified the methodology and accepts the use of Appendix 2A.
The Appendix is currently under review by the staff.
The progress to date for th resolution of the staff'oncern indicates Oct th possibility of additional significant nodifications to the structure is robot.
Any aodifications rkich nay b necessary vill not likely affect syst~
and components needed for fuel load or otherwise inter fere with activities.
zssociatM with m"es 6 and 6.
Tlierefore it is acceptable to the staff to defer the resolution of th use of Appendix 2A to Step 2.
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3.
Uw of translations'I and torsional response of auxHiary building 'as irput to base of fuel handling building should be doumnted, including perm=-tric studies.
{SSK 18, pag C.3-2o)
Yne dpmav'c analysis of'he auxiliary teilding in"luded a siayle represen-tation of the fuel hand1ing building.
The fuH handling htHding was decoupled fee th auxiliary building and analyzed separately using a detaHed three-die, nsional finite elm nt eodel and the coupief trowel mtion at th fue) hand1ing building base.
7his notion consists of ba p rts, th. translation and Ne torsional ration to th finite elewnt rAel.
This r. thod of dew~pling stru"ural sys~ is generally accepts by¹ profession and yields satisfactory results.
The IDVP has verified'nd accepts the mthodology.us%
by K'E.
Th. results presented for the finite els nt aedel have be n prelininarily revived by the 'staff and appar consistent ~ith the coupled redel.
The staff is currently cmqleting the revim of this Niattei.
The progress to date for the
'esolUtion of the staff concern indicates that tie possibility of additional s~gn~ficant nodifications to the structure is emote.
Any nadifications erich cay b necessary Mill not likely affect system or em@on nts receded for fuel lo:d or oth n;ise interfere 4th activities.
associated 4th codes 6 and 6.
Therefore it is acceptable to th staff to defer the resolution of the fuel handling keilditg input ration to Step 2e 9.
Selection of set of degrees, of freed'n dynaric fidel for fuel handling building should be justified.
(SSER 18, peg C,3-26)
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e t A s>t~nt in the Phase f Final Peart regarding tfe dynzric d~r:e s
of f~M in the fuel 'fondling building finite el~nt. easel ms not clear. ¹ staff interpretation of tliis statm~nt was that the D~P had reduced th n~r of degrees of freed'rom 156 to 20. T¹ reason for the staff concern is that recent studies have show that reductions of this typ could result in errors in the individual Gab r loads.
Tn 9".P. used the public du+in prog~>
STNOYttE to analyze the fuel handling building finite el~nt exiel.
Caparison of results fry tt finest ele~~nt fidel and the stick rcdH aper to shou the results to b
'consistent for b=.se sh ars, Hat accelerations and displace..
nts.
The sta f is currently aepleting th. review of this mtter.
%e progress to da~ fot the reso'iution. of the staff concern indicates that the
'assibili.y of additional sig, ificant modifications to the structure is ~te.
Any radifications A>ich nay b n cessary ri11 not 1itely affe t s}stars or mqenents needed for fu 1 load or otherwise interfere.
mth activities associated with rides 5 and 6, 'h refore it is acceptable
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to the staff to defer'the resolution of the degrees of fre~ in the fuel handIing teilding mdel to Step 2.
l2,.Effect of one continuous ex'ior m)l in analysiS of tu bine building should be evaluated.
(SSER 18, page C.3-37)
The vertica1 seismic analysis of the turbira building utilized four different made'ts.
The basis for using the fovr different mdels is the fact that the large openings. in the floors at the turbine p destal divide the floors inn separate
- areas, The staff concern ms over the coupling of th se node)s through the exterior wa) ls and their affect on the final results.
Th vertical ills thBrselves are not continuous due
to large op nines
$n the w)ls.
Mh re coupling could possibly o."cur, th. mals are stiff in their ma plane and do'.not significantly aaplify the ground mtion.
% refore, 'tittle or no coupling appears to occur b 5, w the separate sadels.
The 7DYP sa~le included only one of; the four nMs but did verify that resistance of ad)acent toys mre prop rig accounted for.
Th: staff is currently c~leting the revim of this nattet.
Tie progress to date for the resolution of the staff concern
'indicates that th possibility of additional significant auhfications to the structure is remote.
Any mdifications which try be necessary vill not likely affect system or co~nents needed for fuel load or oth rase interfere eth activities associatod 5th mdes 5 arA 6.
Tiarefore it is acceptable to th staff to defer the resolution of th effect of th exter'ior ills on the vertical response to Step 2, 14.
The use of alternative procedures for cxhl co.,binations by SRSS mood should b.explained and clarified.
(SSER 18, page C.3-37)
'Ihe Phase I Final Report contained the statetn nt %at alternative procedures are being revised to assure that turbine bui1ding tidal co&imtions using the SRSS 'method are acceptable.
Th staff ms concerned that so method other than th SPAN uathod >as used to evaluate the structures.
Tle KP did in fact evaluate the dynamic response of the turbine building using the double alp.braic stm method of cmhining ~al responses in addition to using th SRSS nt t'nod.
The stnscture v s s~>
capable of withstanding the loads calculated by either cathode and satisfies the FSN requirerants.
Th IDVP st Ns in their reports that th alternate nt trod (double algebraic sun) ns not
0
used for fir@I~ r evaluatfon in th IDVP s~le.
Th staff is currently revfe;fng this ratter.
$ n rare detail.
Th. progress t" date for the resolution of th. st&f concern indicates Sat th possibility of additional significant aodifica+fons to the structure is rte.
Any ndifications Rich my b necessary vill not likely'ffect system or c~nents n eded for fu.l load or otherwise interfere vith activities associated 6th mdes 5 and 6.
Therefore it is acceptable to the staff to defer tho resolution of tho concern regarding use of alternative procedures far rrrdal mNMtions by th SPSS mthod to St p 2.
15.
Us of increased alliable stresses in accordarce arith ALSC Co&,. 6th.
edition, should be justified 8th respect to criteria delineated in FEAR.
(SScR 18, page C.3-37)
Tb AkSC Cod, 7th edition, shoes certain valves for the allo".able
~ring of bolts against th nlrb r arterial.
For the Hosgrf event the force resisting aewhers are all~ inelastic defonation as indicatM
'I in the HQsgri Report. 'h provisions of AISC Code, Bth edition, allw higKer b aring values and could he an acceptable criteria for raeting th co"iditions of the Hosgt i Report, co it@ nts.
Th IOVP states that I
tbo Iox r or" 1.7 tiaes the A$SC aIIeeble stress or yield strength ms used and the license writer fa was mt.
The staff is currently reviMng this natter in rare detail.
The progress to date for the resolution of the staff ctncern indfcaus that th possibility of additional significant rodiffcations to Ch structure is ~te.
Any rodiffcations Dich cay he necessary will not lfRe')y affect systems or co~nents needed for fuel
'load or otho.mise interfere with activities associated 4th mdes 5 and 6.
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Th refore it $ s acceptable to the staff to defer th reso1ution of the use of,A1SC Code, 8th edition, to Step 2.
- 20. Nl equitant listed in Table 2.3.l of KP Phase 5 Firial fhport should b seismically qualified for nozzle loads and cmjonent configurations should be verified.
(SSER LB, paye C.3-59 and C.3-M3 Tt, results of the,DJ',
chanical equinox.nt reviw are listed in Table 2.3.l-i of th KP Phase L Final. Report.
Each analysis is stated to have Castrated that th equip nt is qualified to perform its safety function without mhfication for th. contro) ling s~tra ard load c~inaUon.
Hm,.ver, tMs Tahe also indicated that th folleHng equip nt had not yet ~ qualified for nozzle loads:
(1) boric acM tank (2)
CCV teat exchanger (3}
CCU p~ lub oil cooler (4) diesel g Motor (5) diesel transfer filter (6)
~~ste gas aapressor The 0"P anticipated that this equiyxet or connected piping supports ified or that the calculated loads could be reduced by further analysis.
In adNtion, -field verification of st urrponent configurations had not keen co."-pleted.
Finally, because not al1 final spectra had teen issued, soof th calculations might have to be revised to ensue that the affected equ)po nt a~s qualified.
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Tb ID)V has revfe'.ed th OV approach to resoletfon of nozzle loads and found this approach and a s~le of r'esults to bo acceptab)e.
1n a respond dated Sep~ r 9, 1%3, the 9> reported that all nozzle lo:d a33o-blas for ftms 2, 3 and 6 had ~ n t and that, furor qua1 ffication for itms 3, 4 and 5 vs undeway.
This is a typical approach to resolution of nozzle loads, and based on th 0."tob r 11, 3983, revision to the'KP Phase I Final P~rt corrective actions for al) rmHnfng ibm are ~ll undervp.
Mff'fcatfons b yond those currently unde~
are not antfcfpaW.
Any mAfications N3ch ray % necessary all not 3&ely affect sys~ or caaponents needed for fuel load or otherwise interfere vith activities asso"fated 4th uvres 5 and 6..Th refore ft is acceptable to th sMf, to defer final resolgtfon to Step 2.
21.. Stresses in extra fib rs at interface b been valse nozzle and pipe should b=- evaluated and results te docuaanM~.
(SSER 18, page C.3-65}
The initia.'l IDVP review of valves s~led the PNE approach to evaluation of the portions of valve structures that support-the op rotors (co tonly th nest'ighly stressed portion of the valve key und r seismic loading) and fo nd this asp ct of th PGK design acceptable, An additional staff requirement for valves that mast function during and after a seismic event (active va)ves} is that the raxi~ stress at th. valve nozzle, pipe int rsectfon ren8in balm the yfeM.stress to assure elastic action in the valve body.
The ID'as subsequently verified a sample ot'CP valve analyses and 'found the stress levels acceptable.
Subject to final review and evaluation, tie staff considers this ratter resolved.
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22.
Stresses in peep flanges should be verified to b v(thin alliable
) ir.:its,'SSER 18, p.ys'.3-69)
Early IOVP revi~ identified s~ situations ~Ire the approach to evaluation of'tresses in~ flanges ms not Mly acceptable and reco rAe6 reevaluation.
In ITR-67 Rev. 1, dated Separator 9, 1%9, th ID3P concluded that th seismic qualification of equ)at, including pxqs, ms performed acceptably.
In the IDVP Phase I Final Report tte 70VP reported that th verification san@le for stresses in peq flang s she.
d acceptable resul ts.
Subject to configuration that the acceptable evaluation aethods have been unifomly applied 4th regard to p~s requiring seismic qualification, the staff considers this notte. resolved.
26.
Tot l lateral forces, total resistarce to sliding and factor of safety against sliding of intake structure should te fully evaluated.
(SSER TB, pe~ C.345) le staff concern vms that the total lateral forces on the intake stnrture
~."=re not evaluated.
Th se forces cons~st of lateral static and dynamic earth pressure, hydrodyna"ic pressures ard seismic forces.
'Ea structure is keyed into the und.rlying rock mteria'l and.sliding at the structure rock interface is. not of concern.
Th st.ff is concerned about sliding occurring in possible clay seams in tb. rock foundation.
Res additional borings data has bee~ available that can b used to address th..se concerns.
'ice IDVP vill use this data in their evaluation and revim their Andings and report them in a revision ta ITR 40. It is expectmf that'he results of this additional investigation
>nll sho the intake structure is stable against sliding; Any modifications
~Sich ramey b n cessary vill
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v 'g not, likely affa".t systms or emponents needed for fuel lo>d or oth aris
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interfere arith activities associat d mth andes 6 and 6, Tferefore it is acceptable to th stMf to defer th. resolution of the factor of safety against sliding to Step 2, Z$,
Additiogl analyses of her jed d>esel fue1 oH tanks should b
pe&oned
]analyses Hth refi ed ash and without deconvolution, partially. filled tank, examnaUon of properties).
ASSER 18, page'C.3-99)
Th staff consultants, Breokhaven flational Laboratory (M.), p rf'oimd
'an inedpendent analysis of th buried diesel fuel oil storago tank.
Tne results of %is analysis mre cornered to the PGK analysis and sha.R that so d ficiencies existed in the PS'nalysis.
PM cmaitted to re-nalpc<ng th tan'ks using different'radels.
Tn results of the later P~j'-
analysis shard th tanks can mthstand the Hosgri v
event.
The IOVP.has verified that the PGK reanalysis has addressed the deficiencies identified in th BHL ana)ys$ s.
The staff. )s currency revie8 ng this Natter
$n further.detail.'he progress to date for the resolution of the staff concern indicates that the possibility of additional'ign<Hcant nahfications to th structure is ~te; Any nedifications mich r~~ b. necessary @ill not likely affect system or arponents needed for fuel load or otherwise interfere mth activities associated ~ith audes 5 and 6.
Therefore it is acceptable to th staff to defer qual ificat>on of the buried diesel fuH oil tanks to Step 2.
N..
The c~ination of codire"tional responses to 3 co~nents of earthquake
'ration for the turbine building should he explained.
(SSER IS, pag C.3-37}
~s I
C'q
/ $
lbe PGE Phase I Final Report contained a stabeent that the codirectional response due to th three orthogonal ueqonnts of grernd ration are co-,.coined on an SRSS basis or equivalent.
This sta~nt indicated that the provisions of the FSAR may not htve teen followed and failed to sp cify Net equivalent n thod ~s used.
PM subsequently inforaed the suff Sat th equivalent mthod used ms th full value of one ueponent added to th sum 'of 40K of each of th. oth r tm eeponents.
'Ros approach appmrs to,lead to an acceptable resolution of this concern, and the staff is n er aepletion of the revim of this natter.
The progress to date for the resolution of the staff concern indicates that the possibility of additional significant nadifications to the structure is remote.
Joy mdifications Rich sag be necessary All not likely affect systems or co.ponents needed for fuel lwd or oth mise interfere 6th activities associated mth andes 5 and 6.
Therefore it is acceptable to the staff to d fer this rratter of codirectional responses to Step 2.
~Sb.
3 Three it:~ {n~rs ll, 13 and 28) mre designated for resolution prior to
\\
~ authorization of Step 3 (full po. r op ration) based on the folladng general
.cr iter'ia:
(a)
Batters concerning structures, sys~
and cmponents +rote from the reactor coolant syshe; or, (b) tht%rs regarding structures, system and aeponents Reich do not present a safety concern during Tee ~r testing.
(he of th three iten'equired for Step 3 (no. 28) ms fully resolved in SER Supplezent Ro. 19.
'7'emaining be-its {nos, 11 and 13} are discussed b lac.
I V
Mkeling of roof trusses in the.turbine ktilding'should b clarified and justified.
(SSER 28, peg C.3-36}
The staff ws concerned Sat the m thad of modeling the roof trusses by ising tm g neralizml Uniaxial aemb rs and obtaining responses fma the rs mg not produce the mmmm response in each individual truss mI her.
Pt" E stated that tie generalized truss nodal eas used only for calculating global'esponses and that individual amb r forces'mre P
obtained fry a rude] that contained al) truss mshers.
The responses fun the global rude] wre applied to the individual. am'~ cxh'} as static loads.
The LDVP has verified the ca>culations and concluded that the idealization. of the roof trusses into be uniaxiH n~Mrs es
'done properly.
Mi staff is currency c~leting the review of this retter.
The pro, ress to date for the resolution of the staf'f conc rn indicates that the possibi3ity of additional significant notifications to the structure is recite.
Any nodÃ$cations Hach nay be recessary oil) not likely affect systens or co:~nents needed for fuel load or otherwise inter fere with activities associated with nodes 5 and 6.
Therefore it is acceptable to tie staff to defer nodeling of t}e turbine bu)lding roof trusses to Step 3.
13.
Differences
<n turbine building mde)ing of steH. fran and roof truss for be vertical aadels should be c1arified; 'SSER'8, pag C.3-37)
The staff was concerned that tie differences in the nant r of degrees of freed'or the nodes above elevation
$40 used in the ba verticaI sade>s of the roof trusses ms not consistent with t}L response of the structure.
PGKE, stated that since the trusses near each end of the turbine building
s l
~
~
\\
I'an produce her)zontal notion fbi' vertical input Rifle those meter th center of the hn)cfin9 could not, 5e nodels mr@ appropriate.
%e ID'r'P s~1ed one of the eodels for their evaluation and found that myel acceptable.
The staff is currently revim)ng this mtter in further' t H.
The progress to date for the resolution of the staff concern irked-;cates that the possibility of additional.significant, aoNf<cations o the structure is reste.
Any mdifications Rich roy be necessary ril not likely affect systems or ceyonents ceded for Ael load or othemfse interfere 0th activities associated 6th nodes 5 and 6.
T¹refore it is acceptable to the staff to defer tea resolution of th deere s of freeckn for tQ. ver UcaI nodels to Step 3.
a]
J
I
TI.. 15 Folio % It~
Presented helm is a brief discussion of each of the lS follow-up iteas.
the.uilestone for the)r closeout and the basis-for the @ilestone.
'iie staff
'qects a ueplete update of the FSAR fry PGK by Parch 1%4.
For any of the items involving F5AR revisions with a milestone prior to this date, PGE '
Al'i provide the necessary inforention per the milestone date, 1.. PGSE vil) perform a startup test of'FMS runout control system to confim
~ic stabHitg.
(SSER l8, page t.4-3)
'n analysis perfoeet by the IDVP indicated that th pressure control setpoints for the AR5 runout cL~trol system nay not b low enough to pernit einiam required floM to th stem generators Mn only one cantor-driven AFH p~ is operating.
PKE, changed the let pw~ discharoe pressure.setpoints and-committed to perform a stat tap test of the runout control austen to confirm adamic stability.
The IDVP revi~
of the n~ setpoints and startup test ccamiha.nt ind)cated that the propos d resolution ias acceptable.
The staff concurred with this resolution in SSEP. 18.
The test nil be conqleted prior to entering mme 3.
The AFMS is not required to be operable by plant technical specifications prior to entering anfe 3.
Therefore it is acceptab>e to the staff to defer the testing to Step 2.
2.
P6K will delete fmm design drawing steam trap in stean supply line for turbine-driven pep of ASS.
ASSET 18, page C.4-5}
The LOYP. p rfomed'a field mlkdow of the AR~~ to verify cmpl>ance of tie as-built installation 4th tb design doamants.
The as-built installation ms confirned to abet design drawings except that, a steam
t I 1
trap on the turbine-dNven AFM pump stean supply line ms not provided.:.
PKE indicated that the design drawings meld be:revised to delete th. statist tNp on the steam supply Wne because satisfactory testing of Qe,turbinMriven pep ms uepleted Athout the need for the trap.
'the IMP conArmd that the actual AR5 installation ws acceptable and no technical concern existed.
The staff concurred 4th the above resolution in SSER. 18, The staff all verify incorporation of the
'draNng change and confim as-buHt drawings prio~ to entering node 3.
The ASS is not required to be operable by plant technical specifications prior to entering rode 3.
Therefore it is acceptable to tie staff to d fer as-buOt conBrmation to Step 2.
3.
PG~E dll revise FSN to reflect acceptability of as-buHt conditions-regarding separation and color coding of electrical circuits for ASS.
{SSER 18, page C.4-8)
Discrepancies regarding the as-built conditions for separation and color coding of ASS electrical circuits ms identified by the LDVP.
PM comitted to revise FEAR Section 8.3,3 to reflect acceptability of as-built conditions regarding separation and color coding.
The staff concladed in SSER
$8 that these concerns have been acceptably resolved and that plant modifications or addit)onal verHication is.
not required.
FSAR revisions confirming AFi!S electrical circuit separation and color coding Hkl b. suhaitted by PGK prior to catering cade 3.
'The AFMS is not required to be op rable by plant technical s~ifications prior to entering code 3.
Vterefore it is acceptable to the staff to defer the FSAP. revision to Step 2.
I
4, PRE rill correct table in.environ"ntal qualifie t)on report with resp=et to flo".'ranm,tters and floe contro1 valves in AFN.
(SSER M; p ge C.4-12)
Th fDVP revim of thenv{retnental qualification of RR!S epi~nt indicat d that a flm transmitter and flo control valve, Rich are erposM to a t@rsh enviroment resulting fry a high energy line break,
. <~re not listed as lo"ated in harsh enviromrants.
PGKE respond by noting th t the Ae: trans..itter ms fdmtified under a different
. identification n~r and that vendor prov)cd justification for interita operation pending co~letion of the enviro~ntal qualification.
The
'lo" control valve ns conditiottally cpel ified, subject to an ongoing sainte.-wce surveillance program; but es erroneoJsly listed as a
aalu:nent net subject to a harsh environment.
PM vill correct errors in th qualification report tables.
The IOVP Hthdres its concern on this r=tter. T¹ staff'oncurred m 4 t¹ IMP resolution of &is ratter in SSEP, l8.
Envirota n&l qual'<AcaUon (Eg) docu.ntation for.
th AFL'5 ~ill be revised and sutaitted Q PGE p'rior to entering aude 3, The ARS is rat required to be operable by plant technical specif'ications
'rior to entering code 3.
Therefore it is accept-ble to th staff to defer Fg do"uaentation update to Step 2.
5, PGK Hll conduct analyses to determine qualified life of wtor capacitor for s~ar. gen rator control valves.
(SS~R 18, page C.4-12}
Th IDYP revim of the enviroraantal qua] ffication of AFHS equi~nt
$ ndica ed that stem g nerator level control valves n~y not be qualified
~
~'
I C
for f~rsh env<ror nts wsulting fro.. high energy~ 'tin breaks as requir~d b.c use the rotor capacitor qualification report >as not yet complete.
The ~alification report did incl&e justification for interit-"op ration mth replacl-nt of this component foll~ng 20,0%'ours of op ration
%5": indicated that an analysis to d termine the qualif/ed life of this cteponent is te)ng cohducted, Tfx IDtV 'concluded that the PME response resolve this concern.
Tate staff concurred with the conclusims of. th EDVP on this netter in SSER18.
Sutu<ttal of th analysis regarding ~itor capacitor qualification life is required prior to entering ~ 3.
Tb stem gen rator level control va1v s (on. th AFH lin s) are nat erquired to b operable by plant technical spifications prior to entering Me 3.
Vrefore ft fs acceptable to the staff to defer completion of the staff reviw of the analyses u St p 2.
In any event, )ustification.for interim operation
'has previously
.b~n sukiittM by P~.
6.
PG"=E mill ~d FSAR to indicate that pipe breaks are not postulated in stem supply Iin. to turbin -driven peag of:AFVS.
(SSER 18, p"g> C.4-16)
Tl~e IMP revim of high emrgy lin cracks irdicated that certain AF4~
ca~onents nre exposed to a postulated break in tfe steam supply line to the turbine-driven AR:S pmp.-
PRE reevaluated the high enera~ line crack analysis against the FSAR cmnitxents (Giambusso letter dated.
D ceahr 18, 1972).
It ns detertaired that the line established in the IMP analysis as a source affecting the aator-driven AFB p~s and'ressure transt"itters
()ocatM on the steam supply line to the turbine-driven AFM pmp do):1>strew of the f)~ control valve) ms not subject to
~
I
~
~
'racks b cause it is not pressurized. during any noel p]ant operating conlitions, incMing startup and shutdown;.
PORE c~itted to revise the FSAR to indicate th above point.
Th IO'dP agreed 6th the above resolution.
%e staff concurred with th resolution in SSER 18, FSAR rei'isions confirming AM turbine stem supply line pipe break resolution vill be sub~itted by PGSE prior to entering node 3.
The AB5 is not
~ required to be operable pr ior to entering ca& 3.
Therefore it is acceptable to the staff to defer the FSAR revision to St p R.
7.. N~~ nil ~nd FSAR to include-el'i changes for equi~~nt qualification
'CRPS and AFV3) that resulted fare reanalysis of pipe break envirormnts:
ou<aide contain nt.
(SSER 18, page C.4-16)
~ Tne IDVP revie of high enerrg line cracks indicated that certain AR!S and GRIPS c~nents a~>y not have b en qualified for the resulting environ.
nts.
PG=E performed a reanalysis of the blossom jet tea@ rature fnn th posts'laM high.energy line crack source affecting the AFMS level valves using the ANS Standard M.2 r tkdoloy in lieu of th HSC mthod docmmted in the FSN.
Th results of. this reanalysis sh~d a
'et t~~irature below the qualification t~rature for tfe valves.
PGK co.ittedto revise th. FSQt to incorporate this reanalysis.
Additionally, for cables/~tres and sjlices in the AFMS and CRYPS identified as targets by the iOYP, PGfE responded by providing docu."antation that indicated
'I th=t the affected cables/vires and splices wre environ ntally qualified for the resulting high energy line crack b)Mum jet environment and
,urtier c mitted to update enviroreental qualification documentation.
I t
)>>'y>>
~
0
'%4l The ID'oncurred Hth th above resolutions.
Tne s~ff concurred nth th resolution in SSEP. 18.'SAR revisions confiMng satisfactory resolution of jet impinge nt tnt rature r thodology end cab1efmre equip. nt qoaWiication doc~ntation ~ill b sutmtted by PS'rior to e"ceeding 140'
{andes 5 and 6).
Ho environ.~ntal qualification concerns
'are present at such a lm t~rattjre since a harsh environment cannot result.
Therefo're it is acceptable to the staff to defer docu ntation to Step 2.
(Also see i~ l3 and I4 belt+.)
8.
PGK vil1 revise FSAR licensing c~itmnt, regarding need. for prot ctive shields for AKS c~nen~a (valves) against effects of'deraoe energy~
lin breaks'.
{SSER 18, page C.4-17)
Th IDVP revier,'f mderate mergy line breaks irAicaM that Cra AFLS wre not provide/ mth prote-tive shields as documnW in a licensing ca.~it@ nt.
PGK indicated that th floe controI valves (suction supply valves freya the alt mate AFH5 v'ter source, the re: ~ter storage reservoir} are ret required to op rate to ensure APHS safety function folio".,ing the postulated. aoderate energy line break; th refore, they are not required to b 'rotected fmm the pip break effects.
PGEE co.-itted to revise the licensing coaeitvent to dele'he n ed for prote"tive shields for these valves.'he LOYP agreed fifth this response.
The staff concurred with the resolution in SSER 18.
PRE letter dated June 15, PA3, do-e nts deletion of the prot ctive shields for the long-ten mter supply'alves for the AFt5.
Therefore this concern has b en closed out.
I
~
r 7 S.
St"ff eilh confirm:P~t any edifications required in safety-related syste=~ ~0th respect to pressure/tenperature rating and'pm; r-op rated valve op raMlity are i~)anted.
(SSER 18, pag C,4-.26)
As a result of'concerns identified by the iDYP re9arding cmpliance 6th applicable design codes for the se'lection of the auxiliary feed~ater syst~ (ANSI design pressure, isolation of 'lm-pressure portions of Ua syst ~.
rom high-pressure
- portions, and the specification of loM I
differential pressure for th motor-operated stem supply valves to the
.AR! urbine-driven ptrq, the IDVP deterrriined.&at additional s~ling in tl-.ose areas ms required.
PGE undertook a revie~ of the above clcerns for all safety-relat& systsm vithfn their design scop
. This g neric revie". result< in several mxfiAcations to safety-related syst~
as dmus nted in PGKE letter dated 0"tober 7; 1983, which have.
been co:yleted..
Th staff ei33 verify that required rrodifications do"iaanted in PGK letter dated 0"tober 7, 1983, are in place prior. Co Step 2.
Prior to St p 2, the plant vi11 not, b in an operating condition.'hich auld result irr pressure/temperature rating and pear-operated valve operability considera ions.
Therefore it is acceptable to the staff to defer as-hrilt verification to Step 2.
10.
PGKE vill verify assumptions regarding closing/opening of doors and operation of ventilation systens in their continuing pressure/temperatJre enviromenta) reanalysis.
(SSER 18, page C.4-27)
As a result of the MVP concerrrs regarding the m'thod for establishing
'r ssure/temperature enviro)nants folie;ing postulated high energy pipe breaks outside containnant, PGK under took a reanalysis in this area.
. ~
W
Sp =ific concerns identified bj th IDVP ~re mph resp'=et to assertions re,"~r ding door positions and venti'lation system operation.
P6"~ mll yrovid verification of the assnptioris.regarding the above asp cts of th reanalysis and v)11 submft the reanalysis results including ass~ties prior to exceeding 140'.
No environ nta1 qual Ãicotion concerns are present at 1N'rature.
Therefore it is.accept"ble. to the. staff to defer verification of the assumptions to Step 2.
11.
PKE wall eke modifications and provide revised do".u; ntation as necessary based on resul ts of pressure/t~rature environmntal reanalysis'.
(SEER 18, pag C.4-27)
As a result of the lDVP con"ens regarding
~he s thoC for establishing pressure/~rature envirmmnts folloving postulated high ee rgy pipe
, breaks outsid contairmnt, P65E undertook a reanalysis in this area.
The
?DVP revie~ of the resulting pressure and ~rature transient conditions deteminM that th reanalyses n, thodology for. the re".,mining auxili'ary feiiding areas
~as consistent fath that used in areas GE and GM
. and in the turbine llilding. NE indicated tfet results obtained are 1
conservative for the break cejertmnt.
PGK has coiitted to cake any redificat<ons necessary as a result or" tHis reanalysis, and provide revised documentation of this wry.
Th 10YP conclude that the reanalyses satisfactorily resolved the 10YP concerns.
~ause of this conclasion, the IDPP determinM that a Further verification of the PGK continuing effort in the selection of p'ressure and terperature conditions and associated enviroraental,. qualification of safety-related equips nt ms not necessary, PGM vill sufxait th resul ts of th pressure/temperature
a ~'
enviro,";~rital reanalysis and exylete necessary mdifica ions or provide justification for int rim operation prior to exceeding 140'.
Any t
nd$ fications required auld b. outs)0e containmnt and auld b. expected to b of a minor n-ture.
iso environmental qualific tion concerns we present at los ~rahrre.
Therefore it is acceptable to the staff to d Fet ucpletion of nndifications to Step. 2.
12.
Staff vill evaluate results of reanalysis Htn respect to assuring enviror ntal qualification of equfp,mt.
(S5ER 18, page C 4-27)
As a result of the MVP concerns regarding the ~od for establishing pressure efhep rature enviroraets fo)io"ing postulated high energy pip bwana;s outside contain=n, PG E undertook reanalysis in this area.
included in the PGEE effort is a verification of enviro~ntal qualification of equip. nt to the enviro~nts resulting fryt¹ reanalysis.
The staff vill confim sat)sfactory enviro~ntal qualification (EQ) has been provided to the reanalyzed environments (see imam 11 above) or acceptable interim operation justif'ication has b~n praviM prior to exceeding 140 F.
Ho environmental qualification concerns are present at }m tmperature.
Therefore it is acceptable to th staH to defer Eg confirmation to Step 2.
D.
PG~E mll revise FEAR ta incorporate use of NS 58.2 jet iayinpm nt temp rature calculatiorial method Dere applicable.
(SSER 18, pago C.4-14 and 16)'he IDVP review of high energy pipe crack amcetns indicated that jet iryingenant any result in terp ratures in excess of the qualification
C
v.lue far ce) tain I>R,>"and CRYPS cmpnnents.'GK utilized the
- t'!S 58.2 jet, i~inga nt Ce~ra~xre calculation m.thod in lieu of that
<Centi ied in the FRR to verify dot th qualification ~rature w~s not exceafad.
PRE co=.itted to demise th FStlR to incorporate use of A4S S3.2 jet impingent t~rature cQculational t thod.
Th IMP re@i~ this E thod and verified that it provides acceptable results.
The staff'oncurred in this resolution in SSER )8.
FSQ', revisions confin;ing use of NS 58.2 jet impingement temp rature.calculational t-thud xill b submitted by 5K'rior to exceeding 140'.
Ro environs otal qualification concet ns are present at lo: tmq.rature Therefore it, is acceptable to th staff to def'er FSPR revisions to S&p 2..
14.
PM R'll revise equip, nt qualification do-e."-nation to includ qv=-lifted PRS cable/vire other than that previously identified.
(SSER 18, page C.4-16)
Tn
.DYP revie'A of'igh Bn re pipe crack caacerns indicated that. cable(
vire other than that previous1y identified ys envirorr~ntally qua1ified for use in the AR!S ms utOized, and v.s subject to high teqnrature
'et imping tt nt.
POLE provided doccmntation v.'~ich indicated that the cable/mre ms qualified to the resulting jet 4;pin-"~nt ~rature.
PRE ~ittM to revise th envinmnantal qua)ification documentation.
'b JDYP revi~ the doc~ntation and concurred rith the resolution.
Th staff concurred with this resolution in SSEP, 18.
Equitant environ-nental qualification documentation confhning satisfactory qualification of cables/vires vill b sutmitted by PGRE prior to e ce ding l40'.
No environwnta) qualification concerns are present at 1'rature.
Th refore it is acceptable to th staff to defer documentation to Step 2.
c
~ "-s 4
15.
PoL Kill.&vise FSN to incorporate results of federate energy kin break analyses m. the CRm.
{SSER 18, page C,4-17)
The LDVP review of Merate energy line breaks indicated that p>E h d failed t0 met its licensing c<imitx nt by not including the CR('PS
$n th original md rate en re line break analysis.
PGSE provided a
subsequent analysis indicating that only one CRYPS e1ectrical train is af ec> by the postulated break identified by the LOVP.
Rheo mbined vlti 8 single fai'lure in tie redundant e1e".trical train, a loss of tie CR'l'PS auld occur, resulting in degradation of contro1 rote habitabHity.
Ho;=-ver, safe shutdown can be provided fry Ne rent shutdown panel in th emnt th control ~ tactics uninhabi.table.
lb.
IDVP concurred viC this ana1ysis.
The staff a1so concurred 6th tnis resolution in SSF".<<;, 18.
FQB revisions confirming satisfactory mderate energy line break protection for the CRYPT eilf. be submitted by PGM prior to initial criticality. ~te shutdown capability is provided in the event of loss of the CRVPS du. to a ooderate energy line break as indicated above.
- Yareover,
(+cause no fission product inventory
$s present, control roca h bitability is not of concern and offsite release consegtNAces apB't present.
Therefor it, is acceptable to the staff to defer the FSAR revision to Step 2..
I
, I
~
~
p gC ~~t s7 C
1')