ML17193B353

Forwards Request for Addl Info Re SEP Topic VI-4,containment Isolation Sys.Util Must Discuss Administrative Controls Applied to All Test Connections & Vent Lines Located Near Final Outboard Isolation Valve

ML17193B353
Person / Time
Site:	Dresden
Issue date:	04/23/1981
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Abel J COMMONWEALTH EDISON CO.
References
TASK-06-04, TASK-6-4, TASK-RR LSO5-81-04-046, LSO5-81-4-46, NUDOCS 8104290422
Download: ML17193B353 (5)

Text

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Apri 1

• 23, 198,1

• Docket No. 50-237 LS05-81-04-046 l

Mr. J

• S. Abe 1 Director of Nuclear Licensing Commonwealth Edison Company Post Office Box 767 Chicago. Illinois 60690

SUBJECT:

REQUEST FOR ADDTI.ONAL INFORMATION FOR SEP TOPIC VI-4, CONTAINMENT.

ISPLATION SYSTEMS (DRESOEN}2)

Duri'ng 'our re.view of SEP Topic Vli4, "Containment Isolation Syste~",

11 we found that addittonal infonnation (see enclosed) is needed to complete out review..

R.rovtde your response within 30 4ays of the receipt of this letter so that ou.r evaluation ca~ be completed in a timely manner

• Enlosure:

Request for Addt*t~)ooal Informat1on cC/-W!Aeric 1 osure:

See,~ex_t pag~

• 810.4--2*9 0 '/2~.

--p -- -. --

Dennis M. Crutchfield, Chief Operating Reactors Branch #5 D1v1si~n ~f Licensing

I*.

REQUEST FOR ADDITIONAL INFORMATION SEP TOPIC VI-4 CONTAINMENT ISOLATION.

DRESDEN I UN IT 2 DOCKET NO. 50-237

l.

The SEP review for containment isolation was based upon docket infonnation listed below:

a)

Dresden Nuclear Power Station, Units 2 and 3, Safety Analysis Report, Volume l, thru Amendment 20.

b) Letter dated 2/25/80, fro~ D. L. Peoples, CE, to H. R. Denton, "Compliance with Category A Items of NUREG-0578 at Dresden 2/3 and Quad Cities Station~"

c)

Piping and Instrumentation Diagrams M-12, Revision JJ, to M-173, Re vision M.

d)

Letter dated 8/18/80 from R. F. Janecek, CE, to Gus Lainas, "SEP Topic XV-16."-

e) Appendix A to Operating License DPR-19, "Technical Specifications and Bases for Dresden Nuclear Power Station, Unit 2," May 5, 1971.

Please furnish the staff with any ar.tditional documents pertaining to contain-ment isolation which might be helpful in this review.

2.

Capped branch lines, test connections and vent lines* need to be under ad-ministrative control to assure;that they are not inadvertently opened o~

left open after use.

Discuss the administrative controls applied to all test connections, capped branch lines, and vent lines ~ocated before the final outboard isolation valve.

Note wheth_er they have tags which identify them as being admi ni strati ve ly controlled, require control room authori za~

tion to open, or are physically secured by locks to assure they will not be opened.

(

Examples include:

P.&I.D. No.

M-27 M-27 M-27 M-29 M-29 M-29 M-29 M-34 M-34 Line or Valve No.

Line 2-1414: - 3/4 ECCS Line 2-1412 - 3/4 ECCS Valve 2-1402-108 Line 2-1506-16"-A Line 2-1519-16"-A Valve 2-1501-70-A Valve 2-1501-70-8

• Valve 2-1301-97 Valve 2-0399-504 Item Cap and Floor Drain Cap and Floor Drain Screwed Cap Test Connection Test Connection Screwed Cap Screwed Cap Cap "To CRD Repair Shop".

3.

SRP Section 6.2.4, II.3.c states that remote-manual valves may be us.ed on piping lines needed for safe shutdown of the plant or ESF systems, however, provisions should be made to detect possible leakage from these lines out-side containment.

Dresden, Unit 2 technical specifications Section 4.7 addresses local leak rate testing on penetrations and automatic isolation valves listed in Table 3.7.1 but does not include leakage detection for re-mote-manual valves listed in SAR Table 5.2.4, 11 Principal Penetrations of Primary Containment and Associated Isolati.on Valves." Discuss what provi-sions are provided for monitoring leakage of each system with remote-manual valves which serve as containment isolation boundaries.

4.

SAR Table 5.2.4 does not agree completely with oth~r docket information such as Items b and c i.n question 1.

Examp 1 es of differences include nii s-

• numbered valve and penetration numbers and incorrect valve size:

... (

SAR Table 5.2.4 Penetration X-150A~ B II X-110 11*

II II II X-1168 X-138 X-108, 109 X-199A, B Va 1 ve 2-2301-9 1 11 Drywell N2 make-up line

( X-126)

,.r*

P.&I.D. or 2/25/80 letter X-145*, 150 X-130.

X-116A, B X-144 X-108A, 109 X-149A, B 2-2301-4 1 1/2 11 Drywell N2 line Provide a table of all containment isolation _provision similar to SAR Table 5.2.4 that destribes the as-built condition.

In addition, include the following information for each entry in the table:

a)

The appropriate GDC or Regulatory Guide acceptance criteria.

b)

The fluid-contained in each line.

c}

Primary and secondary mode of valve actuation.

d)

Shutdown, post-accident and power failure valve position.

5.

Lines 2-9208-1 11H and 2-9207-l"H each contain a connection for portable pumps-~nd appear on P.&I.D. M-25 to penetrate containment.

If so, in-dicate in the As-Built Containment Isolation Table (s_ee, Question 4).

6.

SAR Table 5.2.4 lists.the.service water, service air~ and instrument air supply as containing hand operated local isolation valves inside and,out-side containment.

Reference.b in Question 1 above,: however, indicates both valves are outside the containment and does not agree with the type of _.valve given in the table.

a)

Clarify which is correct.

b)

Disc,:uss the advi.seability of using local manual valves since they are not considered to be acceptable as isolation valves and it is not possible to verify the position of the inboard manual valve.

)

c) *What are the isolation provisions on the line labeled "To other re-actor building *1ocath:ms 11 on Fig_ure 38 of Reference b.

7.

Line 2-2504-1 "-LA on M-25 and M-707, Sheet l, is a branch 1 i ne 1 ocated before the isolation valves on the drywell vent line. What isolation provision exists for this line. Similarly, on M-20 lines 2-3316A, B. C, 0-14"-L need isolation provisions.

Discuss the containment isolation pro-visions for these lines.

Make sure all valves relied upon for contain-ment isolation ~re listed in the As~Built Containment Isolation Table, (see, Question 4).

8.. It appears that certain relief valves are being relied upon to perform the isolation function but are not designated anywhere as such.

For example, on M-29, relief valves RV-2-1501-85A, B, C, D and on M-51, Relief valve RV-2301-53 appear to be isolation valves. If so, do they conform to SRP Section 6.2.4. II.3.g, i.e., is the set point greater than 1.5 times the desjgn pressure?

9.

Provide a copy of Drawing B~24 for Dresden, Unit 2 penetrations.

.