ML18019A342
| ML18019A342 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/27/1985 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NLS-85-269, NUDOCS 8509040095 | |
| Download: ML18019A342 (41) | |
Text
REffLTORY INFORNATION DISTRIBUTION SYSTEN (RIBS)
,ACCESSION NBR:8509040095 DOC ~ DATE: 85/08/27 NOTARIZED:
NO FACIL:50-400 Shearon Harris Nuclear Power PlantE Unit ii Carolina AUTH BYNAME AUTHOR AFFILIATION CUTTEREA.BE Carolina Power L Light Co.
RECIP ~ NAME'ECIPIENT AFFILIATION DENTONiH ~ RE Office of Nuclear Reactor Regulationi Director DOCKET 05000400
SUBJECT:
For wards response to 841205 request for addi info re. environ qualification Program audit schedule
Response
to Question 270 '
re environ qualification of safety related mechanical equipment being transmitted in separate ltd DISTRIBUTION CODE; AO<f8D COPIES RECEIVED:LTfk ENCL SIZE:-
TITLE: OR/Licensing Submittal:
Equipment Qualification NOTES:
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Carolina Power 8 LIght Company SERIAL: NLS-85-269 AU827 $85 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO.
1 DOCKET NO.50-000 ENVIRONMENTALQUALIFICATIONPROGRAM
REFERENCE:
Letter dated December 5, 1980, G. W. Knighton to E. E. Utley, Shearon Harris, Unit 1 - Request for Additional Information in Regard to Environmental Qualification Program Audit Schedule.
Dear Mr. Denton:
Carolina Power R Light Company hereby responds (enclosure) to eight of the nine questions received from the staff in reference to the environmental qualification program (reference).
The response to the remaining question (270.6), regarding the program for the environmental qualification of safety related mechanical equipment, is being transmitted in a separate letter.
If you have any questions, please contact Mr. Pedro Salas at (919) 836-8015.
Yours very trul ABC/PS/ccc (1705PSA)
Enclosure A.. Cutter - Vice President Nuclear Engineering R Licensing Cct Mr. B. C. Buckley (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)
Dr. 3. Nelson Grace (NRC-RII)
Mr. Travis Payne (KUDZU)
Mr. Daniel F. Read (CHANGE/ELP)
Wake County Public Library Mr. Wells Eddleman Mr. 3ohn D. Runkle Dr. Richard D. Wilson Mr. G. O. Bright (ASLB)
Dr. 3. H. Carpenter (ASLB)
Mr. 3. L. Kelley (ASLB) 8509040095 85D827 PDR ADOCK 05000400 A,.
PDR t
411 Fayettevilte Street
~ P. O. Box 1551 o Raleigh, N. C. 27602
0
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UESTION 270.1
\\
Please describe in detail the methodology used to select equipment to be included in the SHNPP [environmental qualification] EQ program developed in response to 10 CFR 50.09.
Your response should address the internal review process used to assure the accuracy and completeness of the list of equipment and the criteria used for excluding any equipment item from the program.
RESPONSE
The methodology used to select equipment to be included in the EQ program is based on the guidance presented in IE Bulletin 79-01B for reviewing plant systems and establishing a master list of equipment to be qualified.
The review process includes identification of:
I) the design basis accidents (e.g., loss of coolant accident) and the resulting environmental conditions, 2) the major safety functions required to mitigate the event (e.g., emergency core cooling),
3) the systems necessary to perform the primary mitigation function (e.g., safety injection),
0) the components of those systems and the devices necessary to sense accident conditions and initiate actuation of the safety system, and 5) the auxiliary supporting features and components required to support the primary safety function (e.g., component cooling water and electrical power).
This process has been included within the activities performed during design (e.g.,
preparation and review of equipment specifications and design drawings).
The generic safety systems list and major safety functions included in Enclosure 0 of IE Bulletin 79-01B have been considered in developing the Shearon Harris list of systems and equipment included in the environmental qualification program.
The Shearon Harris list encompasses these generic systems and major safety functions (see response to Question 270.2).
The environmental parameters resulting from the design basis events are included on the environmental parameter zone maps (FSAR Appendix 3.11B). The zone maps identify the areas that may experience a harsh environment.
The criteria used for the equipment review process is based on the four categories listed in NUREG-0588, Appendix E, "Standard Question on Environmental Qualification of Class 1E Equipment."
The equipment identified as safety-related is placed into one of the various functional categories.
Category C and D equipment are considered located in a mild environment and are excluded from the harsh environment qualification program.
The methodology and criteria described above are implemented in accordance with the Quality Assurance Program.
0 (1705PSA/ccc)
UESTION 270.2 Page 3.11.1-1 of the FSAR states that plant safety related systems are identified in Table 3.2.1-1.
Please correlate the systems listed on Table 3.2.1-1 with the systems included in the EQ program.
For any system listed in Table 3.2.1-1 which is not included in the EQ program, provide the justification for exclusion of the system (e.g., all system components located in a mild environment, etc.).
Indicate the safety functions of the systems included in the EQ program.
RESPONSE
Table 270.2-1 correlates the systems listed in Table 3.2.1-1 with the systems included in the EQ program (e.g., systems listed on the master list). Where the system name included in the EQ program is not identical to Table 3.2.1-1, it is so noted.
Any other differences between the two lists of systems are also justified.
Table 270.2-2 indicates the safety function(s) of each safety system in the EQ program.
Systems performing an auxiliary supporting safety function (e.g., electrical power, heating and ventilation) are listed as ESF supporting systems.
Systems which are non-safety systems (e.g., Fire Protection) but include safety-related isolation valves, are also listed.
(1705PSA/ccc)
pW
TABLE 270.2-1 CORRELATION OF SYSTEMS LISTED IN TABLE 3.2.1-1 OF SHEARON HARRIS FSAR WITH SYSTEMS LISTED IN THE EQ PROGRAM MASTER LIST SYSTEMS LISTED IN TABLE 3.2.1-1 CORRESPONDING SYSTEMS INCLUDED IN E PROGRAM 3USTIFICATION FOR EXCLUSION FROM E PROGRAM Reactor Coolant Incore Instrumentation Chemical 2 Volume Control Boron Thermal Regeneration Boron Recycle Reactor Coolant Reactor Coolant Chemical k Volume Control System components are located in a mild environment.
System components are located in a mild environment.
Safety Injection Residual Heat Removal Containment Spray Component Cooling Containment Penetration Pressurization Waste Processing Building (WPB) Cooling Screen Wash Safety Injection Residual Heat Removal Containment Spray Component Cooling is included as Component Cooling Water System electrical components are non-safety related.
System components are non-safety related.
System components are located in a mild environment. (1705 PSA/ccc)
CORRELATION OF SYSTEMS LISTED IN TABLE 3.2.1-1 OF SHEARON HARRIS FSAR WITH SYSTEMS LISTED IN THE EQ PROGRAM MASTER LIST SYSTEMS LISTED IN TABLE 3.2.1-1 Service Water Sampling Compressed Air (Subsystems)
Instrument Air Service Air CORRESPONDING SYSTEMS INCLUDED IN E PROGRAM Service Water Sampling Instrument Air Subsystem as Part of Containment Isolation 3USTIFICATION FOR EXCLUSION FROM E PROGRAM System components are non-safety related.
Containment Isolation Containment Isolation is a function performed by multiple systems.
Table 2 lists the systems located in a harsh environment, performing a containment isolation function.
Fuel Pool Cooling and Cleanup Fuel Handling Liquid Waste Processing Gaseous Waste Processing Solid Waste Processing This system is included as Spent Fuel Pool Cooling and Cleanup Waste Processing (Liquid)
Waste Processing (Gas)
System components are located in a mild environment.
System components are non-safety related.
Containment Cooling Containment Ventilation Containment Cooling System components are non-safety related.
(1705 PSA/ccc)
CORRELATION OF SYSTEMS LISTED IN TABLE3.2.l-l OF SHEARON HARRIS FSAR WITH SYSTEMS LISTED IN THE EQ PROGRAM MASTER LIST SYSTEMS LISTED IN TABLE 3.2. I-I CORRESPONDING SYSTEMS INCLUDED IN E PROGRAM 3USTIFICATION FOR EXCLUSION FROM E PROGRAM Containment Combustible Gas Control Containment Vacuum Relief Primary Shield Cooling Containment Combustible Gas Control Containment Vacuum Relief This System is Included as Reactor Support/Cavity HVAC Reactor Support Cooling This System is Included as Reactor Support/Cavity HVAC 1
Reactor Cavity Pressure Relief Damper This System is Included as Reactor Support/Cavity HVAC Reactor Auxiliary Building (RAB)
Ventilation Waste Processing Building Ventilation Control Room HVAC Fuel Handling Building HVAC Fuel Oil Transfer Pump I-louse Ventilation Diesel Generator Building Ventilation Emergency Service Water Intake Structure Ventilation Essential Services Chilled Water This System is Included as Reactor Auxiliary Building HVAC Control Room HVAC Fuel Handling Building HVAC Essential Services Chilled Water System components are non-safety related.
System components are located in a mild environment.
System components are located in a mild environment.
System components are located in a mild environment.
(1705 PSA/ccc)
CORRELATION OF SYSTEMS LISTED IN TABLE 3.2.1-1 OF SHEARON HARRIS FSAR WITH SYSTEMS LISTED IN THE EQ PROGRAM MASTER LIST SYSTEMS LISTED IN TABLE 3.2.1-1 Non-Essential Services Chilled Water CORRESPONDING SYSTEMS INCLUDED IN E PROGRAM 3VSTIFICATIONFOR EXCLUSION FROM E PROGRAM System components are non-safety related; Containment Atmosphere Purge Hydrogen Purge Standby Diesel Generator This System is Included as Containment
. Atmosphere Purge/Makeup This System is Included as Containment Atmosphere Purge/Makeup System components are located in a mild environment.
DG Fuel Oil Storage and Transfer System components are located in a mild environment.
Diesel Generator Cooling Water System components are located in a mild environment.
Diesel Generator Air Starting System components are located in a mild environment.
Diesel Generator Lubrication System components are located in a mild environment.
Diesel Generator Air Intake and Exhaust System components are located in a mild environment.
Fire Protection Nitrogen Supply Fire Protection System (This is a Non-Safety Related; However, Some Components are Classified as Safety-Related)
System components are non-safety related and/or located in a mild environment.
(1705 PSA/ccc)
CORRELATION OF SYSTEMS LISTED IN TABLE 3.2.1-1 OF SHEARON HARRIS FSAR WITH SYSTEMS LISTED IN THE EQ PROGRAM MASTER LIST SYSTEMS LISTED IN TABLE 3.2.1-1 CORRESPONDING-SYSTEMS INCLUDED IN E PROGRAM 3VSTIFICATIONFOR EXCLUSION FROM E PROGRAM Hydrogen Supply System components are non-safety related.
Main Steam Steam Generator Blowdown Condensate and Feedwater Auxiliary.Feedwater Condenser Circulating Water Main Steam This System is Included as Blowdown These Systems are Listed Separately as Condensate System and Feedwater System Auxiliary Feedwater System components are non-safety related.
Demineralized Water Storage System components are located in a mild environment.
Chlorine Leak Detection Radiation Monitoring Post Accident Monitoring Instrumentation NUREG-0737 Electrical Systems Chlorine Leak Detection Radiation Monitoring See Response to 270.9 These Systems, Located in a Harsh Environment, are Included as AC Power Distribution, Cable and Raceway, Conta'inment Penetrations and DC Power Distribution (1705PSA/ccc)
I I
CORRELATION OF SYSTEMS LISTED IN TABLE 3.2.1-1 OF SHEARON HARRIS FSAR WITH SYSTEMS LISTED IN THE EQ PROGRAM MASTER LIST'YSTEMS LISTED IN TABLE 3.2.1-1 CORRESPONDING SYSTEMS INCLUDED IN E PROGRAM 3USTIFICATION FOR EXCLUSION FROM E PROGRAM Reactor Protection Out-of-Core Neutron Monitoring
-ESF Protection Reactor Coolant System Vents Inadequate Core Cooling Systems Presently not Included in Table 3.2.1-1 But Which Will Be Included in the Future:
Uninterrupted AC Power (Mild Environment)
Reactor Makeup Water (Included in EQ Program)
Control Board and Panel (INC) (Included in EQ Program)
Miscellaneous Drains (Included in EQ Program)
Steam Generator Wet-Layup (No Safety-Related Electrical Equipment)
Leak Rate Testing (No Safety-Related Electrical Equipment)
Excore Neutron Monitoring Reactor Coolant Reactor Coolant This system does not represent an actual process system but is a logic function performed on signals from the process systems listed herein.
This system does not represent an actual process system but is a logic function performed on signals from the process systems listed herein.
(1705PSA/ccc)
TABLE 270.2-2 LIST OF SHEARON HARRIS EQ PROGRAM SYSTEMS NEEDED TO PERFORM MA3OR SAFETY FUNCTIONS SYSTEM AC Power Distribution Auxiliary Feedwater SAFETY FUNCTION ESF Supporting System Emergency Reactor Shutdown Reactor Heat Removal FSAR SECTION 8.3.1 10.0.9 Cable and Raceway Chemical dc Volume Control Chlorine Leak Detection Containment Combustible Gas Control ESF Supporting System Emergency Reactor Shutdown ESF Supporting System ESF Supporting System 9.3.0 6.0 6.2.5 Component Cooling Water Condensate Containment Cooling Containment Atmosphere Purge/Makeup "Containment Isolation Auxiliary Feedwater Blowdown Chemical R Volume Control Component Cooling Water Containment Atmosphere Purge/Makeup Containment Hydrogen Purge/Makeup Containment Penetration-Containment Spray Containment Vacuum Relief Feedwater Fire Protection Instrument Air Main Steam ESF Supporting System ESF Supporting System Containment Heat Removal ESF Supporting System Containment Isolation 9.2.2 10.0.7 6.2.2 6.2.5 6.2.0 The Containment Isolation System consists of safety-related valves, penetrations, and other devices which may be contained in non-safety related systems.
(1705PSA/ccc)
TABLE 270-2 (Co SYSTEM SAFETY FUNCTION FSAR SECTION Miscellaneous Drains Safety Injection Sampling Service Air Service Water Containment Spray Containment Heat Removal Containment Vacuum Relief ESF Supporting System Control Boards R Panels ESF Supporting System (Instrumentation) 6.2.2 6.2.1.1.3.0 Control Room HVAC DC Power Distribution Essential Services Chilled Water ESF Supporting System ESF Supporting System ESF Supporting System 6.0 8.3.2 9.2.8 Excore Neutron Monitoring Fire Protection Emergency Reactor Shutdown ESF Supporting System 7.2.1.1.2 9.5.1 Fuel Handling Building HVAC ESF Supporting System 6.5 Main Steam Emergency Reactor Shutdown, Reactor Heat Removal 10.3 Miscellaneous Drains (Instrumentation)
Miscellaneous Items Radiation Monitoring ESF Supporting Systems ESF Supporting System Prevention of Significant Release of Radioactive Material to Environment 11.5, 12.3.0 Reactor Auxiliary Building HVAC ESF Support System 9.0 Reactor Coolant Reactor Makeup Water Emergency Reactor Shutdown Reactor Core Cooling Reactor Support/Cavity HVAC ESF Supporting System 5
9.3.0 6.2.2 Residual Heat Removal Safety Injection Reactor Heat Removal, Reactor Core Cooling Emergency Reactor Shutdown; Reactor Core Cooling 6.3 6.3 (1705PSA/ccc)
I I
SYSTEM Service Water Spent Fuel Pool Cooling and Cleanup Waste Processing (Liquid)
Waste Processing (Gas)
TABLE 270-2 (Co SAFETY FUNCTION Containment Heat Removal, Prevention of Significant Release of Radioactive Material to Environment, ESF Supporting System ESF Supporting System ESF Supporting System ESF Supporting System FSAR SECTION 9.2.1 9.1.3 11.2 11.3
- ll-(1705PSA/ccc)
UESTION 270.3 Provide information which demonstrates how the SHNPP EQ program complies with the scope of 10 CFR 50.09.
Specifically, you must address how the EQ program is in compliance with 10 CFR 50.09(b)(2) and (b)(3) and the requirement that all design basis events have been considered in the development of the list of equipment in the EQ program.
RESPONSE
FSAR Section 3.11 provides detailed information demonstrating how the Shearon Harris environmental qualification program complies with NUREG-0588, Category ll, and therefore encompasses the scope of 10 CFR 50.09.
FSAR Appendix 3.11A includes a point-by-point correlation of the Shearon Harris program with the positions in NUREG-0588.
The (conservative) environmental conditions were established considering the design basis events and the applicable areas of the plant which could potentially be affected.
The safety-related equipment located in these areas were qualified for the limiting environmental conditions postulated including the anticipated operational occurrences.
Additional information demonstrating the consideration of design basis events is provided in FSAR Subsections 3.11.0, 3.11.5, 3.11.6, and Appendix 3.11A, Paragraphs I.I through 1.5.
Equipment which does not perform a safety function but whose failure could prevent the satisfactory accomplishment of safety functions has been classified as safety-related on the applicable Shearon Harris design documents.
Therefore, the methodology used to select equipment to be included in the environmental qualification program, which includes review of these design documents (see response to Question 270.1), assures inclusion of the appropriate components.
For Shearon Harris, the concern that non-Class IE systems or components may degrade Class IE systems is addressed by virtue of compliance with Regulatory Guides 1.6 and 1.75 (see FSAR Chapter 8), as well as by other plant safety reviews (e.g., fire hazards, jet impingement, seismic design, etc.).
Where the possibility of safety system circuitry degradation exists, the inclusion of qualified isolation devices prevents credible failures due to non-Class IE equipment malfunctions.
Post-accident monitoring instrumentation identified as Category I and 2 of Regulatory Guide 1.97 is included in the environmental qualification program and identified as such on the master list (R.G. 1.97 information was submitted to the NRC under separate cover ). (1705PSA/ccc)
UESTION 270.0 Provide a description of the surveillance/maintenance program which willbe used to assure that the qualification status of equipment is maintained.
Describe also the specific surveillance/maintenance activities to be performed on the following types of equipment:
cables located inside primary containment, ASCO solenoid valves, Limitorque motor operators, Barton pressure transmitters.
RESPONSE
CPRL is developing a surveillance/maintenance program at Shearon Harris which will assure that the qualification status of equipment is maintained.
This program is in accordance with the guidance of Regulatory Guide 1.33, Revision 2.
The program will include the following elements:
preventive maintenance, corrective maintenance, and performance testing.
The first element of the EQ part of this program is the review of the specific equipment qualification reports.
Vendor submitted reports are reviewed for applicability to plant specific criteria.
As a result of this review, certain equipment maintenance requirements are documented and are referenced on the component evaluation sheets for each piece of equipment.
This information is utilized in the planning and scheduling of maintenance activities.
The maintenance organization is responsible for performing corrective and preventive maintenance on environmentally qualified equipment.
Plant procedures describe the following: maintenance objectives, program requirements, and responsibilities of organizational units relative to the management of equipment qualification.
Implementing procedures for equipment qualification maintenance appear throughout the plant operating manual.
With respect to preventive maintenance, the program considers equipment manufacturer's recommendations and operating experience.
Additionally, parts substitutions willbe made under an engineering evaluation process.
The equipment included in the program willbe replaced or refurbished at the end-of-installed life unless ongoing qualification demonstrates that the item has additional life.
This designated life willbe determined considering the materials susceptible to the effects of aging.
This consideration willbe based on information extracted from the vendor's test reports, and A/E'review. Additionally, the equipment qualification data
- packages, component evaluation sheets, vendor technical manuals and maintenance history willbe reviewed to ascertain any additional maintenance necessary to maintain the qualification of equipment.
The above information is also used in the technical manual control process.
Information concerning equipment qualification received from vendor recommendations, equipment qualification report revisions and/or technical information from off site sources are forwarded to the applicable sections for technical manual review. This information is reviewed for applicability. If not applicable to the plant equipment, the determination of non-applicability is documented and filed as a permanent plant record. If the information is applicable, the vendor manual is updated accordingly and re-issued.
- l3-(1705PSA/ccc)
There are no planned maintenance activities on cables located in the primary containment.
However, current plans call for meggering selective power cables.
Cables installed in safety related circuits in containment have been qualified in accordance with 10 CFR 50.09 and IEEE 383-1970 "Types Tests of Class IE Electrical Cables, Field Splices, and Connections for Nuclear Power Generating Stations."
This provides reasonable assurance that the cables are qualified for'00-plus years for all conditions.
In addition good maintenance practice provides that, during performance of maintenance, a
visual check of the equipment's condition be conducted, including the condition of cable terminations, in order to detect component degradation which may be due to wear and/or in-service aging.
Also, CPRL has an operational feedback system which monitors industry reports to look for reports of unanticipated degradation in cable as well as other equipment.
Solenoid valves are being reviewed for maintenance requirements as described above.
An example of specific requirements identified to date concern an auxiliary feedwater valve.
Each solenoid willbe cycled and inspected on the same frequency as the actuator of that valve.
The particular application of the ASCO solenoids on the auxiliary feedwater valve requires no replacement over the 00 year life of the plant. This is due to the normal ambient temperature in the valve area.
Other ASCO solenoid valves have similar replacement requirements.
1 With regard to Limitorque motor operators, Limitorque Corporation has provided, as part of their equipment qualification report, lubrication and maintenance instructions.
These instructions include, but are not limited to, the frequency of lubrication inspections and recommended lubricants.
Spare parts and replacement intervals for these parts have not been identified, but willbe generated in the same manner as described in the ASCO discussion above.
Barton pressure transmitters have been provided by Westinghouse for Shearon Harris.
The 0-ring willbe replaced everytime the cover is removed or in accordance with the replacement schedule specified in the qualificaton documentation.
This information is being used by maintenance personnel in their surveillance and maintenance program.
Presently these transmitters are qualified for greater than 20 years.
The Shearon Harris surveillance and maintenance program includes features that enable identification, review, approval, and distribution of equipment qualification related data to appropriate individuals. This assures that equipment is maintained per the requirements of 10 CFR 50.09. (1705 PSA/ccc)
IJ n
UESTION 270.5 Provide detailed descriptions of the methods and assumptions used to take credit for radiation dose reduction at specific equipment locations and methods used to calculate the surface temperature of equipment for which credit is taken for thermal lag.
RESPONSE
a)
Radiation Dose Reduction Radiation dose values were determined for normal and post-accident situations at locations throughout the plant where safety-related equipment is located.
The basis for these values is discussed in FSAR Subsection 3.11.5.2.
These doses are conservative; the calculations assumed worst case conditions of operation, shielding, radionuclide inventories, etc. Calculations were done for locations inside and outside the containment, for both gamma and beta radiation (as applicable),
and the values were recorded on dose maps which are included in FSAR Appendix 3.11B.
The dose values are listed separately for normal operation and post-accident situations and for gamma and beta radiation.
As discussed in FSAR Appendix 3.11A, Paragraph 1.0, dose reduction credit may be applied in some cases to account for distance of equipment from the source, and for shielding between the equipment and the source.
The free-air beta dose presented on the maps can be reduced through consideration of the attenuation effects of covering material that may be present between the beta source and the sensitive components of the equipment.
Beta dose reduction factors were determined as a function of covering thickness for various materials and used where applicable in the environmental qualification program.
These dose reduction factors are listed in the attached Table 270.5-1.
The resultant radiation service condition is determined by the sum of the gamma and reduced beta doses.
The dose map values are conservative and cover wide areas by listing the highest dose in each area.
Therefore, further shielding or geometry-based dose reduction credit may be taken on a case-by-case basis in the individual equipment qualification reviews.
A gamma radiation dose reduction factor was developed from the ratio of the contact source dose rate to the dose rate at a given distance.
The source assumed was a cylinder of various isotypes calculated by an Ebasco computer code GROUB.
Dose rates were determined by the ISOSHLD computer code, a remal integration code used for isotope shielding analysis as discussed in FSAR Sections 12.3.2.3 and 12.3.2.16.
This code determined dose rates from the source with gamma energies from 0 to 2.7 MeV and included buildup factors as applicable.
Dose rates for shielding material were calculated using the appropriate density and thickness of the material.
The calculated dose rate to contact dose rate provides the appropriate dose reduction factor.
A dose reduction credit based on distance of the equipment from the nearest source may be applied as shown in attached Table 270.5-2.
A dose reduction credit for shielding may be applied if the equipment being considered is situated in a cubicle or compartment where there is no direct line-of-sight between the equipment being considered and other radioactive equipment in the cubicle or compartment.
The reduction credit that may be applied is based on the material and thickness of the intervening wall, as listed in Table 270.5-3. (1705PSA/ccc)
For equipment that has multiple locations, such as cables, the highest dose of the possible locations is used.
For equipment that is required to operate following an accident, use of the one year post-LOCA is considered conservative.
b)
Thermal La Anal ses As discussed in FSAR Appendix 3.11A, Paragraph 1.2(5), in some cases a thermal lag analysis may be applied in individual component qualification reviews.
These analyses and their results are used to determine the thermal response of the component and the consequent ability to survive and operate during and after the design basis accident (DBA).
These analyses are used where the transient temperature of the test profile is lower than that which occurs during the DBA. For these instances, analyses are conducted to demonstrate that the relatively short duration of the calculated maximum thermal transient does not adversely affect the operation of the particular safety-related component being considered.
It is demonstrated that the equipment's thermal response sufficiently lags the DBA thermal transient such that the equipment never attains a peak temperature in excess of that to which it is qualified. The following description specifically discusses thermal lag inside containment but the same methods apply with respect to DBA thermal transients outside the containment.
The methods used to take credit for the equipment surface temperature are consistent with the guidelines of NUREG-0588.
The mass and energy release data for the DBA worst case containment atmosphere temperature was used in the calculations for the predictions of a conservative equipment temperature.
The equipment surface heat transfer coefficients were also conservatively calculated in accordance with the criterion of NUREG-0588.
Most of the thermal lag analyses performed for Shearon Harris have used the Ebasco version of CONTEMPT-CTD MOD26 computer code (described in the FSAR Appendix 6.2A), which has been modified to allow equipment to be modeled as a heat sink structure with heat transfer coefficients calculated following the methodology of Appendix B in NUREG-0588.
Figures 270.5-1 and 2 represent typical results of thermal lag analyses performed for Shearon Harris on an instrument cable and an electrical penetration module, respectively.
As indicated by these figures, the thermal response of these components is demonstrated to sufficiently lag the DBA response such that the peak transient conditions used to quality the equipment adequately enveloped the actual equipment thermal response. (1705PSA/ccc)
TABLE 270.5-1 BETA DOSE REDUCTION FACTORS MATERIAL DENSITY gm/cc 10.0 DOSE REDUCTION FACTORS FOR THICKNESS IN MILS 30 50 70 90 Plastic 1.0 3.3 10 33 99 300 Finish Coat 7075 1.2 0.0 12.5 38 120 370 Nutec 11S Aluminum Steel 1.95 2.7 7.8 6.1 25.0 20 27 78 61 86 255 193 270 800 600 850 2500 (1705PSA/ccc)
TABLE 270.5-2 GAMMARADIATIONDOSE REDUCTION FACTORS BASED ON DISTANCE FROM SOURCE DISTANCE IN FT.
FROM SOURCE 10 12 16 18 20 DOSE REDUCTION FACTOR 1.5 3.8 8.8 21.0 52.0 120.0 205.0 320.0 020.0 510.0 (1705PSA/ccc)
TABLE 270.5-3 GAMMARADIATIONDOSE REDUCTION FACTORS BASED ON SHIELDING MATERIAL Steel Lead Concrete DENSITY gm/cc 7.8 11.35 2.21 DOSE REDUCTION FACTORS FOR THICKNESS IN INCHES 1
2 3
0 5
6 9
12 15 18 6
27 105 380 1300 0000 9.2 100 750 0950 5
23 110 020 1750 6600 (1705PSA/ccc)
JACKET (CSPE)
IELD TAPE
(.oos")
CSP E INSULATION JACKET INSULATION (EPR)
COPPER CONDUCTOR COPPER DRAIN WIRE (GROUND)
FIG 270.5-1 380 ELECTRIC INSTRUMENTATIONCABLE CONTAINMENTAIR TEMPERATURE QUALIFIEDTEMP.
300
/
I l
200 100 50 TIME (SEC) 100
UESTION 270.7 Indicate compliance with one hour time margin for equipment item with operability times less than ten hours, or provide justification for reduced margin.
RESPONSE
Some equipment may be required, by design, to perform its safety function only for a short time into an event (i.e., seconds or minutes).
Once this function is complete, subsequent failures are not detrimental to plant safety.
Other equipment may not be required to perform a safety function but must not fail within a short time period into the event.
Subsequent failures are also shown not to be detrimental to plant safety.
Equipment procured for short-term operation (i.e., less than one hour operation) has been reviewed against the above criteria to assure that it is qualified for the time required to operate with additional margin.
This justification includes, but is not limited to, consideration of the spectrum of breaks, the potential need for the equipment later in an event or during recovery operations, or a determination that the failure of the equipment after the maximum operability time will not degrade any safety functions or mislead the operator.
In the few cases where this justification has been required, the documentation has been included in the Equipment Qualification package.
In most cases equipment has been qualified for a minimum of l.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to I year past DBA. Specific compliance to the one hour time margin is available by reviewing the specific equipment qualification package. (1705PSA/ccc)
UESTION 270.8 Please provide details of the assumptions made and an example of the calculations used to determine the environmental conditions due to a high energy line break in areas outside containment.
In your response you should address the range of breaks considered in the analysis and assumptions made regarding isolation of pipe breaks.
RESPONSE
High energy (HE) lines outside containment are described in FSAR Section 3.6.1.2.1 and are summarized here as follows:
1.
2.
3.
5.
6.
7.
Main Steam Supply System (MS)
Extraction Steam System (ES)
AuxiliarySteam System (AS) - including condensate return Feedwater System (FW)
Auxiliary Feedwater System (AFW)
Steam Generator Blowdown System (BD)
Chemical and Volume Control System (CVCS) - charging pump discharge lines, i.e.,
charging line and seal injection lines, letdown line to downstream of letdown heat exchanger.
The location and type of pipe breaks postulated in the HE lines are described in FSAR Sections 3.6A.2 and 3.6.2.1.5, respectively.
The HE lines are located in the Reactor Auxiliary Building (RAB), the Steam Tunnel, the Turbine Building and Waste Processing Building. Listed below is an area by area description of the HE lines and a summary of the assumptions and evaluations performed to address the question of equipment environmental qualification. Details of the assumptions used in pipe break analysis are listed in FSAR Section 3.6.1.3.
STEAM TUNNEL Main Steam, Feedwater, and AuxiliaryFeedwater-For MS and FW lines located in the steam tunnel, a crack equivalent to the flow area of a single-ended non-mechanistic pipe break, has been'postulated to evaluate the consequences of environmental conditions.
Each main steam line is provided with a flow restriction orifice (each steam generator has a flow limiter on the outlet nozzle as described in FSAR Section 10.3.2), therefore, the mass flow rate from the postulated MS line crack is limited to 1.0 square feet (see FSAR Sections 3.6.2.1.0 and 3.6A.3.2).
The environmental conditions resulting from a postulated break in the AFW piping in the Steam Tunnel are enveloped by the MS and FW pipe break evaluation.
REACTOR AUXILIARYBUILDING Feedwater No breaks are postulated in the FW system in the RAB as described in the FSAR Section 3.6.2.1.2, therefore, there can be no adverse environmental qualification effect due to HE line break in the FW system.
With the exception of the previously described break in the steam tunnel, the location of the first postulated FW piping failure outside 23-(1705PSA/ccc)
containment is in the turbine building. No essential systems or components are housed within the turbine building, therefore, safety-related functions cannot be adversely affected by any postulated break.
Main Steam-No breaks are postulated in the MS system in the RAB as described in the FSAR Section 3.6A.2.3, therefore, there can be no adverse environmental qualification affect due to HELB in the MS system.
With the exception of the previously described break in the steam tunnel, the location of the first postulated MS piping failure outside containment is in the turbine building. No essential systems or components are housed within the turbine building, therefore, safety-related functions cannot be adversely affected by any postulated break.
Blowdown-The blowdown system is designed to detect a pipe break in the line outside containment, and automatically isolate the blowdown system, thereby limiting the mass energy release into the RAB.
The blowdown system in the RAB consists of three (3) four (0) inch lines, one from each steam generator.
The piping between the containment penetration and containment isolation valves is designed and analyzed to Safety Class 2, Seismic Category I standards.
Although the piping downstream of the containment isolation valves is not required to be safety class, this piping in the RAB up to and including the RAB - Turbine Building penetration interface is designed, fabricated and analyzed to Safety Class 3, Seismic Category I standards.
Full circumferential breaks in the blowdown lines inside the RAB are postulated as described in FSAR Sections 3.6.1 and 3.6.2.
Two redundant safety related pressure transmitters on the blowdown line from steam generator lA-SN are provided to detect low line pressure due to a postulated pipe rupture.
Upon low line pressure, transmitter PT-8005AI-SA automatically closes containment isolation valve 2BD-V11SA-1 and transmitter PT-8005A2-SB automatically closes containment isolation valves 2BD-P6SB-1 and 2BD-V2SB-1. Similar protection is also provided on the blowdown lines from steam generators 1B-SN and 1C-SN.
See FSAR Figure 10.1.0-6 and FSAR Table 6.2A-l.
These isolation valves are designed to fail closed upon loss of air or electric power.
Considering the aforementioned system safeguards and comparing the blowdown flow associated with a postulated double-ended guillotine break to the large free volume available in the RAB for steam dispersion (approximately 500,000 ft ), a BD line failure within the RAB willnot have significant impact on established environmental profiles.
AuxiliaryFeedwater-The AFW system piping takes suction from the Condensate Storage Tank which is at ambient temperature.
Therefore, the environmental pressure/temperature consequences due to a pipe break in the AFW system are limited to postulated jet impingement, pipe whip and flooding effects.
(1705PSA/ccc)
These conditions willnot adversely affect the safety-related equipment.
Safety-related instruments are available to indicate an AFW pipe break in the RAB. The AFW pumps are equipped with redundant safety-related Class lE low discharge pressure alarms.
Safety-related Class lE flow transmitters on each AFW pump discharge line willprovide flow indication in the control room to initiate appropriate operator action.
Redundant safety-related level switches and associated main control room indicating lights warn the operator of excessively high RAB Equipment Drain Sump water levels. Safety-related equipment is either located above the flood level or is environmentally qualified for the appropriate conditions.
Additional information regarding the AFW system is contained in FSAR Sections 10.0.9 and 7.3.1.3.3.
AuxiliarySteam (AS)-
There is one auxiliary steam header that willbe routed through the RAB to supply steam to the boric acid batch tank and waste recycle evaporator.
The line willbe routed through cubicles containing non-essential components and willbe equipped with automatic isolation devices (i.e., Safety Class 3, Seismic Category I excess flow check valves) which would limit blowdown due to a postulated pipe rupture.
Chemical and Volume Control (CYCS)-
The CVCS letdown line is routed in the shielded pipe tunnel, and the environmental conditions resulting from a break in this line are contained within the tunnel.
No essential components are located within the tunnel.
As described in FSAR Section 3.6A.2.3, the tunnel is designed for the resulting pressure and temperature.
The CVCS charging pumps and the letdown exchanger are located in individual compartments as shown on FSAR Figure 1.2.2-23.
The environmental effects resulting from postulated breaks within these individual compartments willnot adversely effect other safety-related components needed to mitigate the HELB or to shutdown the unit.
Additional information regarding the CVCS is found in FSAR Section 9.3.0.
TURBINE BUILDING Portions of the MS, FW, AS, ES and BD piping systems are routed in the Turbine Building. The Turbine Building is an open structure and any high energy pipe break in the Turbine Building willnot result in high temperature and pressure buildup.
In addition, the environmental effects of a high energy pipe break in the Turbine Building were not considered because no essential components are located in the Turbine Building.
WASTE PROCESSING BUILDING Portions of the AS piping system is routed in the Waste Processing Building. The environmental effects of a high energy pipe break in the WPB were not considered because no essential components are located in the Waste Processing Building. (1705PSA/ccc)
UESTION 270.9 Identify, by categories listed in NUREG-0737, the components included in the qualification program in response to TMIAction Plan Requirements.
RESPONSE
See attached table. (1705PSA/ccc)
TABLE 270.9 NUREG 0737 CATEGORY TITLE DESCRIPTIONS QUALIFICATIONPROGRAM (PER TMI RE UIREMENTS)
I.D.2 II.B.I Plant-Safety-Parameter Display Display Console Reactor Coolant System Vents Plant-Safety-Parameter Display Reactor Coolant Boundary Isolation Valve (6 Isolation Valves) See FSAR Section 5.0.12.9 Not Included (Only Qualified to Demonstrate Conformance to Design Criteria)
Included II.B.3 II.D.I Post Accident Sampling Relief and Safety Valve Test Requirements Sampling Valves 3 Safety Valves Included See Docket Letter NLS-80-263 3 Power Operated Relief Valves See Docket Letter NLS-S0-263 II.D.3 Valve Position Indication 3 Safety Valve Position Indicators Included
-3 Power Operated Relief Valve Position Indicators Included II.E.1.2 Auxiliary Feedwater System Initiation and Flow Indication Automatic Initiation of Auxiliary Feedwater (See FSAR Section 7.3.1.3.3)
Primary Indication of Auxiliary Feedwater Flow (See FSAR Section 7.0.1.3)
(3 Flow Transmitters)
Steam Generator Level (Backup to Flow)
See FSAR Section 7.3.2.2.1 Mild Environment Included (1705PSA/ccc)
TABLE 270.9 NUREG 0737 CATEGORY TITLE DESCRIPTIONS QUALIFICATIONPROGRAM (PER TMI RE UIREMENTS)
II.E.0.2 II.F.1 Containment Isolation Dependability Accident Monitoring A.
Noble Gas Effluent Radiological Monitors Containment Purge Isolation on High Radiation 0 Ion Chamber Monitors (See FSAR Section 12.3.0.1.8.1) 1.
Plant Vent Stack - (Includes RAB, Containment and FHB Exhausts) 1 Wide Range Noble Gas Radiation Monitor Included Included 2.
Waste Processing Building Mild Environment Vent Stacks Two Stacks Each With 1 Wide Range Noble Gas Radiation Monitor 3.
Turbine Building Vent Stack-(Includes Condenser Vacuum Pump Effluent, Gland Seal Condenser and Condensate Polisher Area Effluent)
I Wide Range Noble Gas Radiation Monitor 0.
Main Steam Safety Relief Valve and PORV.
Dischargers 3 Radiation Monitors, 1 per MSL (See FSAR Section 12.5.2)
Mild Environment Included (1705PSA/ccc)
e
~
l
TABLE 270.9 NUREG 0737 CATEGORY TITLE QUALIFICATIONPROGRAM DESCRIPTIONS (PER TMI RE UIREMENTS)
B.
Plant Effluent Iodine and Particulate Sampling Sampling and Analysis of Iodine and Particulates in Plant Gaseous Effluent Streams (Onsite Laboratory Analysis of Effluent Samples) 1.
Plant Vent Stack Contin-uous Isokinetic Sampling via the Wide Range Noble Gas Radiation Monitor Included 2.
Waste Processing Building Vent Stacks - Continuous Isokinetic Sampling via the Wide Range Noble Gas Radiation Monitor Mild Environment 3.
Turbine Building Vent Stack Continuous Isokinetic Sampling via the Wide Range Noble Gas Radiation Monitor Mild Environment C.
Containment High Range Radiation Monitors Containment High Range Radiation Monitors Included D.
Containment Pressure Containment Pressure Indication 0 Transmitters 0-55 psig 2 Transmitters 135 psig 2 Transmitters +5 Inch WG Included E.
Containment Water Level Containment Water Level 2 Level Transmitters for Narrow Range (ECCS Sump) 2 Level Transmitters for Narrow Range (Cavity Sump) 2 Level Transmitters for Wide Range Included (1705PSA/ccc)
a
NUREG 0737 CATEGORY TITLE F.
Containment Hydrogen Concentration TABLE 270.9 QUALIFICATIONPROGRAM DESCRIPTIONS 2 Containment Hydrogen Analyzers (PER TMI RE UIREMENTS)
Included t
l 1
I II.F.2 Instrumentation for ICC Reactor Vessel Level Indication System (RVLIS) Reference Leg Temperatures Reactor Coolant Vessel Upper Plenum Level (RVLIS)
Reactor Coolant Vessel Wide Range Level (RVLIS)
Reactor Coolant Vessel Narrow Range Level (RVLIS)
Reactor Coolant Pressure (RVLIS)
Reactor Coolant Vessel In-Core Thermocouples (Inadequate Core Cooling)
Included Included Included Included Included Included (l705PSA/ccc)