ML18003A911

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Forwards Responses to Containment Sys Branch Draft SER Open Items 64 & 71 Re Containment Pressure Instrument Lines & Containment Leakage Testing Program,Respectively.Responses to Remaining Open Items Forthcoming
ML18003A911
Person / Time
Site: Harris  
Issue date: 06/14/1983
From: Mcduffie M
CAROLINA POWER & LIGHT CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
LAP-83-204, NUDOCS 8306200309
Download: ML18003A911 (11)


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REGULATOR NFORMATION DISTRIBUTION TEM (RIDS)

ACCESSION NBR:8306200309 DOC ~ OATEi 83/06/14 NOTARXZED; NO FAOIL:50 4do.Shearon Harris Nuclear Power Planti Uni,t lr Carolina 50 401 Shear on.Harris Nuclear Power Plantg Uni,t 2q )Carolina AUTH,NAME AUTHOR AFFILIATION MCDUFFIEgM~ A ~

Car ol ina iPower 8 Light Co ~

'ECIP ~ NAME RECIPIENT AFFILIATION DENTONeH ~ RE Office, of Nuclear Reactor Regulationi Director" SUBJECT>

Forwards responses to Containment Sys Branch draft -SER. Open Items 64 L 71 re. containment pressure instrument lines~ 5 containment leakage testing pr ogt amirespectively,Responses to remaining open items forthcoming, DISTRIBUTION CODEt 8001S COPIES 'RECEIVED:LTR ENCL SIZE;,

I "TITLE: Licensing 'Submittal:,PSAR/FSAR Amdts L Related Correspondence NOTES:

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CSQE, Carolina Power 5 Light Company JUN 14 1983 SERIAL:

LAP-83-204 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NOS.

1 AND 2 DOCKET NOS ~ 50-400 AND 50-401 DRAPT SAPETY EVALUATIONREPORT RESPONSES CONTAINMENT SYSTEMS BRANCH

Dear Mr. Denton:

Carolina Power

& Light Company hereby transmits one original and forty copies of the responses to the Shearon Harris Nuclear Power Plant Draft Safety Evaluation Report (DSER)

Open Items 64 and 71.

Carolina Power

& Light Company will be providing responses to other Open Items in the DSER shortly.

Yours very truly, PS/ccc (6956PSA)

Attachment M. A. McDuffie Senior Vice President Engineering

& Construction cc:

Mr. Yun-Seng Huang (NRO-CSB)

Mr. N. Prasad Kadambi (NRC)

Mr. G. P. Maxwell (NRC-SHNPP)

Mr. J.

F. O'Reilly (NRC-RII)

Mr. Travis Payne (KUDZU)

Mr. Daniel P.

Read (CHANGE/ELP)

Chapel Hill Public Library Wake County Public Library Mr. Wells Eddleman Dr. Phyllis tutchin Mr. John D. Runkle Dr. Richard D. Wilson Mr. G. 0. Bright (ASLB)

Dr. J. H. Carpenter Mr. J. L. Kelley (ASLB) 8306200309 8306i4 PDR ADOCK 05000400 E

411 Fayetteville Street o P. O. Box 1551 o Raleigh, N. C. 27602

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Shearon Harris Nuclear Power Plant (SHNPP)

Draft Safety Evaluation Report (DSER) 0 en Item 64 (DSER Section 6.2.4 a e 6-25)

Provide the information requested in Q480.34 to verify that the containment pressure instrument lines associated with the Engineered Safety Features Actuation System (ESPAS) are designed to Safety Class 2 requirements.

~Res esse The containment pressure instrument lines at SHNPP are capillaries, not pipes, and as such are not subject to ASME Code requirements.

They are the same as Westinghouse has historically supplied for this application.

The Westinghouse qualification groups follow the ANS definitions.

The capillaries are made of SA-316 stainless steel and are procured to ASTM A-269.

Although these capil-laries do not fit the'ASME Safety Class 2 definition, they are seismically

designed, and thus it is appropriate to designate them as safety-related.

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Shearon Harris Nuclear Power Plant (SHNPP)

Draft Safety Evaluation Report (DSER) 0 en Item 71 (DSER Section 6.2.6 a es 6-30 and 6-31)

The staff has reviewed the containment leakage testing program contained in the SHNPP Final Safety Analysis Report (FSAR) and the responses to NRC Questions 480.48 through 480.55, and finds them acceptable with the following exceptions regarding Type C testing of certain containment isolation valves:

1) Until justification is provided (see NRC Question 480.53),

a Type C test will be required for those valves associated with Penetrations 9, 10, 11, 12, 13, 14, 17, 18, 20 through 32, 47, 48, 49, and 50.

2)

The staff has found the justification provided in the responses to NRC Question 480.54 inadequate for certain containment isolation valves.

Unless additional justification is provided a Type C test will be required for those valves associated with penetrations numbered 8, 15, 16, 35, 36, and 39.

3) Appendix J permits reverse direction testing of an isolation valve if it can be demonstrated that leakage rates measured in the reverse direction are equivalent to or more conservative than those measured in the accident pressure direction.

However, the applicant must prepare to make such a

demonstration when requested, and retain the documentation on site for use by NRC inspectors.

Response

1) Valves associated with penetrations 9,

10, 11, 13, 14, 17, 18, 20, 21, 22, 25 through 32, and 47 through 50 will not be Type C leak tested.

Justification for this exception is as follows:

a)

Lf.nes and components associated with penetrations 9, 10; 11 (Chemical and Volume Control System (CVCS) seal water to Reactor Coolant Pumps);

13, 14, 18 (Emergency Core Cooling System (ECCS) low head safety injection to hot/cold legs);

and 17, 20, 21, 22 (ECCS high head safety injection to hot/cold legs) are always pressurized above maximum containment pressure during and after a loss-of-coolant accident (LOCA).

These'systems are all classified as closed systems outside containment in accordance with FSAR Section 6.2.4.2.4.4.

No containment air leakage can occur due to a single active failure of any component in any of these systems.

b)

(In accordance with ANSI/ANS 8.9-198 1, a single active failure is a malfunction, excluding passive failure, of a component which relies on mechanical movement to perform its intended safety function(s).

This malfunction may occur when the component is called upon to perform its intended safety function (demand failure) or it shall be deemed to have occurred if the component actuated due to a spurious signal within its control system.

0 en Item 71 (Continued)

Examples of single active failures that have been considered in this and subsequent analyses are the failure of a pump, diesel generator to start, or a powered valve or check valve to move to its correct position.

Also considered is the unintended energization of a powered valve to open or close.)

c)

Lines and components associated with penetrations 25 through 32 (service water to and from fan coolers) are all part of a closed system inside containment in accordance with FSAR Section 6.2.4.2.4.4.

No containment air leakage can occur due to a single active failure of any component in any of these systems.

d)

Lines passing through penetrations 47, 48 (residual heat removal (RHR)/low pressure safety injection (LPSI) recirculation) and 49, 50 (containment spray recirculation) are connected to the containment sump.

During and after a LOCA, the sump will provide a water seal to the associated isolation valves.

A single active failure of any component will not affect the existence of this water seal nor will activation of the recirculation modes in either system.

Valves associated with penetrations 1 2 (CVCS seal water return) and 23, 24 (containment spray injection) will be Type C tested.

2) Valves associated with penetration 8

(CVCS charging) will be Type C leak tested.

Valves associated with penetrations 15 and 16 will not be Type C leak tested for the following reasons:

Lines passing through penetrations 15 and 16 terminate at the suction to the RHR pumps.

At this elevation (RHR pump suction),

the refueling water storage tank (RWST) provides a water seal during the Engineered Safety Features (ESF) injection phase and the containment sumps provide a water seal during the ESF recirculation phase.

A single active failure of any valve or pump in the RHR system will not affect the existence of this water seal.

The RHR system, itself, is a closed system outside containment in accordance with SHNPP FSAR Section

6. 2.4. 2.4.4.

Valves associated with penetrations 35, 36, and 39 will not be Type C leak tested for the following reasons:

The Component Cooling Water System (CCWS) inside and outside of containment is a closed loop system in accordance with SHNPP FSAR Section 6.2.4.2.4.4.

This closed loop criteria has been verified for all piping, valves, fittings, pumps, reactor coolant pump (RCP) thermal

barrier, RCP motor oil coolers, heat exchangers, etc., of the CCWS.

The system can accommodate a single active failure and still maintain containment integrity.

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0 en Item 71 (Continued) 3)

When a reverse direction test of an isolation valve is used to facilitate the Type C test, on-site documentation shall be made available for NRC inspector's use.

This documentation shall demonstrate that leakage rates so measured are equivalent to or more conservative than those measured in the accident pressure direction.

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