ML19322E406

Forwards Drawings & Addl Info Re Containment Purge & Vent Sys.Requests Meeting Before 800415 to Discuss Sys Design Philosophy & Vendor Analyses of Valve Closure Capabilities. Drawings Available in Central Files Only

ML19322E406
Person / Time
Site:	FitzPatrick
Issue date:	03/19/1980
From:	Early P POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Ippolito T Office of Nuclear Reactor Regulation
Shared Package
ML19254G073	List: ML19322E406
References
JPN-80-16, NUDOCS 8003270434
Download: ML19322E406 (11)

Text

POWER AUTHORITY OF THE STATE OF NEW YORK 10 CotuMaus CIRCLE NEW YORK. N. Y. loo 19 GEORGE 7. BERRY 42121 397.6200 opin4 Tine oprican TRUSTEES JOHN W. 80STON JOMN S.OYSON c"*"'" ,

"lL"4'O "'..cron oEOnoE L.iNo4LLs JOSEPH R C IEDER v tC . cMasmMAN nicaanO u.rLY~N *aig;ogaj a cai<r KOSENT 1. MILLONZL LEROY W. SINCLAIR March 19, 1980 "c"'.""'U,'c"""

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Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. Thomas A. Ippolito Operating Reactors Branch No. 3 Division of Operating Reactors

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Response to NRC Request for Additional Information for the Containment Purge and Vent System

Dear Sir:

Attached are responses to the NRC Requests for Additional Information attached to your letter of December 19, 1979.

A number of JAF drawings, elementary diagrams, and logic diagrams have been included as part of the responses. The Authority suggests a meeting in which personnel familiar with these drawings and diagrams will be available to provide knowledgeable discussion.

Specific agenda items for such a meeting on containment purging and venting should include system design philosophy, equipment qualifications and the vendor analyses of valve closure capabilities discussed in our letter of February 29, 1980.

It is requested that this technical review meeting be scheduled before April 15, 1980. Arrangements should be made in consultation with our Mr. Paul Reichert (212-397-2944).

Very trulv ours, \ ,

f j ,

! /

Paul J. Early h

f Assis,' tant Chi f Engineer-Projects 8003270VW

. o RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI) OF i

DECEMBER-12, 1979 FOR THE CONTAINMENT PURGE AND VENT SYSTEM RAI-l With regard to the drywell vent and purge penetration cover grating, discuss the design basis of the grating.

In particular:

t

a. Discuss'the design basis for the sizing of the

- grating mesh pattern; 4

b. Discuss the ability of the grating to withstand dynamic LOCA forces;

c. Discuss the provisions taken to assure that the metal grating has been properly qualified (e.g.,

for seismic events); and Describe what routine procedures you use to assure d.

that partial blockage of the grading by debris during normal operation does not affect the ability of the grating to remain in place and perform its function when subjected to LOCA forces.

RESPONSE

la. Specific design bases for the sizing of the grading mesh are not known, however, its purpose is to prevent loose material from being placed in the penetration.

b&c. The Authority has directed the Architect-Engineer l

to design a protective grating which is capable of withstanding d amic LOCA forces and qualified for seismic events.

l l d. The Authority does a routine inspection to assure that no loose equipment or material is left in the drywell after each outage whenever containment entry is made.

RAI-2 The copies of P & ID's attached to your submittal of 4 August 15, 1979 were illegible. Please provide legible drawings as well as a schematic drawing of the Please include the isolation valves in purge system.

. this schematic. ,

, RESPONSE 2.. Enclosed is Drawing No. 11825-FM-18A-20 " Flow Diagram-Drywell Inerting, C.A.D and Purge-System 27" which provides the requested information.

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RAI-3 For the containment purge isolation valves, please specify the differential pressure across the valve for which the maximum leak rate occurs. Provide test results (e.g.,

from vendor tests of leakage rate versus valve differential pressure) which support your conclusion.

RESPONSE

3. The vendor for the subject valves does not have specific test results for leakage rate versus valve differential pressure. The Authority's leak test for these valves are only done at 60 psia.

RAI-4 Please provide operational justification for utilizing 2 supply and 2 exhaust purge lines for the drywell. Discuss the procedures governing the use of the purge system (e.g., sequence of valve openings, etc.)

RESPONSE

4. The Authority does not use 2 supply lines or 2 exhaust lines simultaneously when containment integrity is 4 required. The Authority's letter of February 29, 1980 describe the use of the purge and vent isolation valves.

RAI-5 The overridea of one type safety actuation signal (e.g.,

radiation) must not cause the blocking of any other type of safety actuation signal (e.g., pressure) to isolation valves. Override of a system actuation signal composed ~

of several types of actuation signals is not permitted.

It would appear from your August 15, 1979 response that multiple bypasses of safety actuation signals could be initiated by a single override action. In this perspective, please provide drawings and/or sketches which show the point in valve closure logic where the override signal is introduced. Please provide a discussion of whether an override affects a single actuation signal or more than one actuating signal.

(a) The following definition of an override is given for clarity:

The signal is still present, and it is blocked in order to  ;

1 perform a function contrary to the signal.

l I

. RESPONSE

5. Keylock switches.(one for system A, one for System B) 4 are provided to override'the system actuation signal for the containment Purge and Vent valves. This over-ride system will be expected to be used only in a post-accident condition for hydrogen control in the long term. The system actuation signal is composed of the following individual safety actuation signals:

(i) Drywell pressure high (>2.7 psig)

(ii) Reactor water level low (<12.5 in.)

(iii) Reactor Building common ventilation exhaust radiation high (900 cpm)

(iv) Both radiation monitors for reactor building common ventilation exhaust (17 RIS-452A & B) failed.

In the current design, bypasses of multiple safety actuation signals can be initiated by a single override action.

Logic Diagrams ll825-LSK-27-7A through 7C (enclosed) show the point in valve closure logic where the override signal is introduced. The following electrical elementary diagrams show the circuits for containment vent and purge isolation valves:

Drawing No. Description ll825-ESK-3E Control Switch Contact Diagram - Sheet 5 ll825-ESK-6MBB PCP valves 27MOV-ll3 and 117 ll825-ESK-7AH PCP pilot VV's (Div 1) 27SOV-lli,114,ll5,ll8 ll825-ESK-7AJ PCP pilot VV's (Div 2) 27SOV-112,ll3,ll6,ll7 ll825-ESK-7BB PCP master interlock circuits 11825-ESK-7CD Drywell'inerting and CAD system "A" ll825-ESK-7CE Drywell inerting and CAD system ll825-ESK-llAJ Stdby gas & prim. cont. purge init-CKT (Red) ll825-ESK-llAAK Stdby gas & prim. cont. purge init. CKT (Blue)

When the key-lock selector switch is in the " Normal Standby" position, normal containment isolation for the purge and exhaust valves can occur. If the key-lock switch is selected to " Emergency-Manual Over-ride" position, all the safety actuation signals for a containment isolation valve are bypassed and the valve can.be opened or closed by momentarily placing the respective control switches in the desired position.

All selector and control switches for containment vent and purge system isolation valves are located on Primary Containment Purge & Inerting Panel (PCP Panel) or

'Crywell Inerting and CAD system panel (CAD panel) .

_3_

RAI-6 Sufficient physical features (e.g., key lock switches) should be provided to facilitate adequate administrative

+ control. Initiating or bypassing a safety function should necessitate a deliberate operator action; e.g., physical features such as switch protective covers or keylock switches would preclude inadvertent and operator action.

Your August 15, 1979 letter did not address this concern Please provide information regarding the subject physical features.

RESPONSE

6. All " Emergency-Override" switches are key-lock switches with key removable in " Normal Standby" position only (G.E. type CR-2940 with maintained contacts, Reference 11825-ESK-3E, switch detail AQ6).

Whenever a key-lock switch is selected to " Emergency-Override" position, visual and audible alarm indication is provided in the plant main control room.

RAI-7 The overriding or resetting of the isolation actuation signal should not cause the automatic reopening of any isolation or purge valve. Please describe the manual isolation valve control switches and circuits. Of particular interest is switch type, e.g., spring return to neutral position or maintained contact switches.

RESPONSE

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7. The opening circuits for containment vent and purge system isolation valves have been designed such that overriding or resetting of the actuation signal will not cause automatic reopening of these valves. Under all conditions of operation, the operator must take

• deliberate action to open isolation valves by turning the switches momentarily to "Open" position. The control switches for "Open-Close" operation of containment vent and purge system isolation valves are momentary switches, and spring return to Neutral from either position.

RAI-8 The overriding of redundant valves by initiating a signal bypass is not permissible. Each valve should be provided i

with an independent switch which introduces a bypass or override into the separate control logic for each valve.

Based on your submittal, it is unclear whether a single switch can effect the operation of redundant components.

Please provide information regarding this concern as well as appropriate drawings and/or schematics.

l

_4_

l

RESPONSE

8. The overriding of redundant valves (system A and system B) is accomplished by use of separate " Emergency-Override" key-lock switches. But a single override switch for system A will introduce safety actuation system bypass for a number of valves in the A system and a single override switch for system B will intro-duce safety actuation system bypass for a number of valves in the B system. For example, the override switch for system A on PCP panel will introduce safety actuation system bypass for the following valves:

27AOV-lll - Drywell inerting and purge supply containment isolation valve 27AOV-ll4 - Drywell inerting and purge exhaust containment isolation valve 27AOV-115 - Suppression chamber inerting and purge supply containment isolation valve 27AOV-ll8 - Suppression chamber inerting and purge exhaust containment isolation valve Similarly, the override switch for system B on PCP panel will introduce safety actuation system bypass for the following valves (Blue Bus):

(Reference ESK-6MBB, ESK-7AJ, ESK-7BB) 27AOV-ll2 - Drywell inerting & purge supply containment isolation valve 27AOV-ll3 - Drywell inerting and purge exhaust containment isolation valve 27AOV-ll6 - Suppression chamber inerting and purge supply contairment

" isolation valve 27AOV-ll7 - Suppression chamber inerting & purge exhaust containment isolation valve 27MOV-ll3 - PCP exhaust isolation bypass valve 27MOV-ll7 - PCP exhaust isolation bypass valve The override switch for system A on " CAD" panel intro-duces safety actuation system bypass for the following valves (Red Bus):

(Reference ESK-7CD, ESK-7AK) 27SOV-129A - Instrument header isolation valve 27SOV-131A - Drywell isolation valve 27SOV-132A - Suppression chambcr isolation valve 27SOV-119A - 02 Analyzer suppression chamber suction containment isolation valve 27SOV-120A - 02 Analyzer drywell vent header 27SOV-121A - 02 Analyzer drywell middle area suction containment i isolation valve 27SOV-122A - 02 Analyzer drywell upper area suction containr.ent isolation valve 27SOV-123A - Air parricle de ector and gas sampler suction containment isclation valve

/

27SOV-124A - 02 Analyzer discharge to suppression chamber containment isolation valve 27SOV-125A - Air particle detector and gas sampler discharge containment isolation valve The override switch for system B on " CAD" panel intro-duces safety actuation system bypass for the following valves (Blue Bus) :

(Reference ESK-7CE, ESK-7AL)

L 27SOV-129B - Instrument Header Isolation Valve 27SOV-131B - Drywell isolation valve

-27SOV-132B - Suppression chamber isolation valve 27SOV-119B - 02 Analyzer suppression chamber suction containment isolation valve 27SOV-120B - 02 Analyzer Drywell vent header suction containment isolation valve 27SOV-121B - 02 Analyzer Drywell middle area suction containment 4 isolation valve 27SOV-122B - 02 Analyzer Drywell upper area suction containment isolation valve 27SOV-123B - Air particle detector & gas sampler suction containment isolation valve 27SOV-124B - 03 Analyzer discharge to supjression chamber containment isolation valve 27SOV-125B - Air particle detector & gas sampler discharge containmen isolation valve RAI-9 The staff is concerned about the possibility of inadvertent l

defeat of any isolation provision. These concerns are not

' limited to the question of containment ventilation isolation.

Accordingly, please identify all other containment isolation valve circuits that have the same reset or bypass provisions as do the containment ventilation isolation (CVI) system and describe the bypass and reset features for all isolation valves that are different from the CVI system.

RESPONSE

9. a. Manual Override of Safety Actuation Signal Enclosure 2 of Power Authority letter dated August 15, 1979 to U. S. Nuclear Regulatory Commission (JPN ,

50) presented the review of the design of all safety actuation signal circuits which incorporate a manual override feature.

No change to the list incorporated in this review

, is necessary,

b. Resetting of Isolation Actuation Signal The design of control systems for all containment isolation valves is such that Resetting or Override of the isolation signal will not result in the automatic reopening of the containment isolation valve.

The operator must take delibrate action to open the valves. CVI system valves use spring return to neutral "OPEN-CLCSE" switches.

Other isolation valves use either " SPRING RETURN TO NEUTRAL" switches or maintained OPEN-CLOSE contact switches. Wherever a maintained contact switch is used, the operator must turn the. switch first to "CLOSE" position'and then to "OPEN" position to open the valves'after a " RESET" action.

RAI-10 The instrumentation and control systems provided-to initiate CVI should be designed and qualified as safety grade equipment. In this perspective please discuss the qualifications of control systems including radiation monitoring channels. As a minimum, these components should be qualified for the worst case normal environment expected -

over the life of the plant as well as the worst case accident environment which occurs during that time post accident during which operability is required. Please include discussions on maximum and minimum temperatures, pressures, relative humidity, radiation dose rate, integrated radiation dose, vibration and seismology.

RESPONSE

10. The Instrumentation and Control Systems provided to initiate CVI are designed and qualified as Safety Grade Equipment. Attached sheets list the qualification data for Safety Actuation signal instruments. The monitoring and control of CVI is accomplished from Primary Containment Purge (PCP) panel and Containment Atmosphere Dilution (CAD) panel. These panels are located in the plant relay room which has controlled environment under all operating conditions. All the equipment used on these panels is industrial grade equipment and is qualified to expected 0 environment 0

of (i l" water gage) , temperature (40 F - ll2 F)

Relative Humidity (10-60%) and integrated radiation of 3x10 rads. The data pertaining to radiation dose could not be verified. These panels and all the instruments mounted therein were qualified to SSE I (Safe Shutdown Earthquake) and 1/2 SSE Seismic Requirements.

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EQUIPMENT NUMBER SPS-12A, 12B, 12C, 12D FUNCTION Primary Containment Pressure High MANUFACTUREP/P.O. NO. STATIC-O-RING - GE-APED / API LOCATICN 12A, 12B Rack 25-5 Elev. 300, 12C, 12D Rack 25-6 Elev. 300 In the Reactor Building MODEL NO. 12N-AA-5-9-TT Parameter Expected Environment Qualification (CE DOC. 22A2928 Rev. 2)

Pressure -1.0" to +7.0" -2 to +20 psig (l)

Water Gage Static Temperature Normal 700F Maximum 1400F -65 to 1900FI Minimum 400 F Relative Normal 40% 20% to 100% (Weathorproof, Humidity Maximum 90% Moisture Proof Enclosure)

Minimum 20%

Radiation Operating LOCA Dose Rate .001 Rad /Hr 6.5x102 Rad /Hr NOT AVAILABLE (3)

Integrated 3.5x102 Rads 1.7x105 Rads Seismic (Elev. Operating OBE DeLign Basis DBE GE qualified this equip-300) ment for Seismic but data Acceleratien g .097 0.165 not available. Also racks Displacement in 0.029 0.070 25-5 & 25-6 were qualified NOTE (1) Data verbally obtained from Manufacturer.

(2) Data in manufacturer's catalog, verified by telephone (3) Manufacturer has not performed environmental Radiation Testing on any of their switches.

(4) Operating dose integrated over 40 yrs LCCA, integrated for 6 Mo.

EQUIPMENT NUMBER: 2-3-LIS 101A, B, C, D FUNCTION: Reactor Water Level Low (Cl2.5") Scram MANUFACTURER /P.O. NO.: BARTON-GE APED /AP-1 LOCATION: 101A,B, - Rack 25-5-1 Elev. 300, 101C,D Rack 25-6-1 Elev. 300 MODEL NO.: 288A 4

Parameter Expected Environment Qualification (GE Doc. 22A2928 Rev. 2)

Pressure -1.0" to +7.0 No effect till proof III Water Cage Static pressure of case - very high Temperature Normal 700F Qualified -60 F to 2000F Maximum 1400F Satisfactorily tested i Minimum 40CF till 3400F (1}

Relative Normal 40% 20% to 100% (1)

Humidity Maximum 90% (Weatherproof, Moisture-Minimum 20% proof enclosure)

Radiation I Operating LOCA NOTE 2 i Dose Rate .001 Rad /Hr 6.5x102 Rad /Hr 3x106 Rad /Hr Integrated Rads 3.5x102 Rads 1.7x105 Rads 2x108 Rads Seismic (Elev. Operating OBE Design Basis DBE GE qualified this equipment 300) & Racks 25-5-1 & 26-6-1 Acceleration g 0.097 0.165 But qualification data Displacement in 0.029 0.070 not available i

NOTES (1) Data verbally verified from manufacturer (2) Dose Rate and Integrated Dose Tests performed by manufacturer a number of times since 1971 (3) Operating dose integrated over 40 years LOCA dose integrated over 6 months

EQUIPMENT MUMBER: 17 RIS-462A, 4262 in Panels04-13A, 13B FUNCTION: Reactor Building Exhaust Radiation Mon.

MANUFACTURER /P.O. NO.: Nuclear Measurements /APO-84 LOCATION: Elev. 344 Ft. 6 In.

MCDEL NO.: APM-G25.

Parameter Expected Environment Qualification (GE Doc. 22A2928 Rev. 2)

Pressure -1.0" to +7.0" 0-10 psig III Water Gage Static III Temperature Normal 700F 104 F Maximum 1400F 1560F Minimum 400 F 400F Relative Normal 40% 40t II)

Humidity. Maximum 90% 90%

Minimum 20% 2 0 *.

(Moisture Proof Box)

Radiation (2} Operating LOCA(4) Background Rad. of Dose Rate .001 Pad /Hr 6.5x102 Rad /Hr 1.5 Mil Rad /Hr Integrated 3.5x102 Rads 1.7x10 5 Rads 3" shield around detector Seismic (Elev. Operating OBE Design Basis DBE DBE - Horizontal gl = 2.90 (3) 272) Vertical g2 = 1.25 Acceleration g 0.140 0.257 OBE - Horizontal g3 = 2.00 Vertical g4 = 0.95 Displacement in 0.049 0.120 Shake Test Qualification Manufacturer Report TDR-7573 NOTE: (1) Data in the Spec. - Vendor conformed to.

(2) Integrated Dose Rate - Cperating integrated over 40 yrs.

- LOCA integrated over 6 months (3) Seismic Test was done only for Radiation Monitor 17RIS-456 Refueling Floor Radiation Monitor-17RIS-462A, B use the same monitor and geometry.

(4) System isolated on LOCA.

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