ML20003D679

Forwards Response to NRC 810225 Ltr Re Identification of safety-related Structures,Sys & Components

ML20003D679
Person / Time
Site:	Mcguire, McGuire
Issue date:	03/25/1981
From:	Parker W DUKE POWER CO.
To:	Harold Denton, Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8103300318
Download: ML20003D679 (10)

Text

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DUKE POWER COMPANY Powra Scu.oixo 42n SocTn Carucu SrazzT. CHARI.OTTz. N. C. 28342 WIL LI A M Q. RA R et ER, g m, s s55 E*oEc'~[c= March 25, 1981 ''*"* ' *373'.". ll l Mr. Harold .. Denton, Director

-Office of Nuclear Reactor Regulation - :-

U.S. Nuclear Regulatory Comission Washington, D.C. 20555

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Attention: 'Mr. B. J. Youngblood, Chief 6 Y '.D,., "#

Licensing Projects Branch No. 1 ,M C' .> .(% 7-

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Re: McGuire Nuclear Station Docket Nos. 50-369, 50-370 4  %";% c'_

Dear Mr. Denton:

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Attachment 1 provides Duke Power Company's response to Mr. Robert L. Tedesco's letter of February 25, 1981 concerning identificatica of safety-related struc-tures, systems and components at McGuire.

If you have any questions regarding this response, we would be pleased to dis -

cuss it with you.

Ve e.ruly yours e

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William O. Parker, J .

GAC:pw Attachment ec: T. J. Donat Senior Resident Inspector McGuire Nuclear Station f00l .5 i

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ATTACHMENT 1 McGuire Nuclear Station Response to NRC Request for Information Transmitted by Mr. Robert L. Tedesco's Letter of February 25, 1981 Tables 3.2.1-1, 3.2.2-2 and 3.2.3-1 are tabulations of the major safety-related civil structures, mechanical systems and components and electrical systems and components which are part of the McGuire Nuclear Station. These tables are not intended to be a listing of every safety-related component in the station.

In many instances, various safety-related equipment are not listed in these tables. This is for one of several reasons; (1) The safety-related aspects of the equipment is discussed in other sections of the FSAR; (2) System flow diagrams depict the safety-related status of the structure, system or component, (3) the level of detail in the FSAR does not address a particular component.

With regard to the Quality Assurance Branch, " Request for Additional Information" 260.1, numerous items contained in the request are not identified as safety-related in Tables 3.2.1-1, 3.2.2-2 and 3.2 3-1 either because of one of the three reasons stated above or because they are not appropriate for inclusion in the tables, i.e., not a safety-related structure, system or component.

Part a. Response:

The following items are considered safety-related and are included in the FSAR.

(Numbers correspond to those in the request for information):

12) Fuel assemblies.

13) Control rod assemblies.

14) Core. support structure.

15) Reactor vessel internals other than iteas-12, 13, and 14 above.

16) Control rod drive mechanisms.

17) Pressurizer spray nozzles.

18) Steam generator steam flow restrictors.

20)- Sampling system lines connected to safety system components up to and including the isolation valve or block valve.

21)~ Spent' fuel storage racks.

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22) On-site Power Systems (Class 1E)

a. Diesel generator package including auxiliaries (e.g., governors, voltage regulator, excitation system).

b. Protective relays and control panels,

c. Containment electrical penetration assemblies.

d. Other cable penetrations (fire stops).

23) DC Power Systems (Class 1E)

a. Battery racks.

b. Protective relays and control panels.

25) Tornado missile protection for the refueling water storage tank.

28) Essential heating and ventilation. (Control Room and Diesel Generator Ventilation)

29) Missile barriers protecting safety-related equipment, including missile barriers around air intakes, vent stacks, and other outside structures as. applicable.

33) Non-safety systems that penetrate containment and are an extension of the containment boundary up to and including the containment isolation valves.

34). Residual heat removal system piping, spray headers, spray nozzles, and related supports.

35) . Containment spray system piping, spray headers, and related supports.

36) -Annulus _ ventilation system ducting and supports.

.37) Ice basket supports.

38) Supports for containment isolation system valves.

39) Ducting'and supports for the containment air return and hydrogen skimmer system.

'40) Ducting, supports, dampers, and operators _for the ES air handling units of the auxiliary building ventilation system.

42) Containment pressure indication systems (with input to ESF).

43)l Containment sump level indication systems.

The following five items are considered safety-related with some qualifying explanation:

2) Masonry walls per IE Bulletin No. 80-11.

Masonry walls or " block" walls are treated as safety-related if, a) they provide support to any safety-related components or piping, or b) failure of the wall could potentially threaten other safety-related structures, systems or components.

24) Expendable and consumable items necessary for the functional performance of critical structures, systems, and components (i.e., weld rod, fuel oil, boric acid, snubber oil, etc.).

These items are treated as safety-related although they are not spe-cifically identified in the FSAR since the FSAR does not go to this level of detail. These items are included in the more detailed

" Nuclear Safety Related - Structures, Systees and Components" list which is the working document used at the station.

32) Biological shielding within containment and auxiliary buildings and other-radiation shielding.

Installed biological shielding consists of reinforced concrete walls and masonry walls. These walls are considered safety-related to the

, extent that their structural integrity is required under seismic conditions.

The remaining items in Part a., are not considered safety-related and are, therefore, not subject to the_ requirements of the 10CFR50 Appendix B, Quality Assurance Program. Specific reasons for not treating these items as safety-related are given for each item.

1) Measuring and test equipment used-for safety-related structures, systems, and components.

As required by Appendix B, Duke Power Company has in place measures to assure that measuring and test equipment used in activities affecting quality are controlled, calibrated and adjusted to maintain accuracy within specified limits. However, the measuring and test equipment in itself is not safety-related, nor is there a requirement for the equip-ment to be safety-related.

3) Radiation monitoring (fixed and portable).

.4) Radioactivity monitoring (fixed and portable).

5) Radioactivity sampling (air, surfaces, liquids).

6) Radioactive contamination measurement and analysis.

7) Personnel =cnitoring internal (e.g., whole body counter) and external (e.g., TLD system).

3) Instru=ent storage, calibration, and maintenance.

9) Decontamination (facilities, personnel, and equipment).

10) Respiratory protection, including testing.

11) Contamination control.

Radiation monitoring equipment in the plant, installed prior to TMI, is not considered safety-related. Several monitors which were installed as a result of requirements of the TMI Action Plan have been installed as safety grade and will be maintained accordingly.

Items 6) through 11) are not considered safety-related. For the most part, the equipment associated with each ites is controlled and is treated similar to test and measuring equipnent, i.e. , neasures exist to assure proper cali-bration and maintenance of the equipment.

19) Sampling system delay coils up to and including the containment isolation valve.

Delay. coils are no longer installed at McGuire in the sa=pling syste=s.

26) Meteorological data collection prograns.

Meteorological instrumentation does not ec=e under the purviev of an Appendi) B, QA program. The instru=entation is calibrated and =aintained as required by the statica Technical Specifications to assure the vali-dity of the meteorological data. Since the meteorological monitoring

" program" does not affect the quality of any safety-related structure, systes or component, its inclusion in an Appendix B, QA program is not appropriate.

27) Post accident monitoring instrumentation.

Regulatory Guide 1.97 specifies criteria for various categories of post-accident instrumentation. These criteria include requirements for some instruments to be fully qualified and safety grade while other instru-ments are only required to be "high quality ccamercial grade." The current instrumentation at McGuire covers this entire range. Those instruments that were designed and installed as safety-related are so designated and maintained accordingly.

Duke must subait by April 23, 1981,.as a requirement of the McGuire11icense, a description of conformance with Regulatory Guide .l.97. Any required

. changes to;the ' accident monitoring instrumentation would be made af ter NRC review of _this response. It would be inapprcpriate and impractical to change the criteria .to.which this instrumentation was designed until the Regulatory Guide _1.97 review is completed.

30) The Leak Detection System discussed in FSAR Section 5.2.7 should be explicitly identified, or all of its constituent parts should be included as sub systems or components of other entries on the Q-list.

The Leakage Detection System discussed in FSAR Section 5.2.7 is not a single system. Rather, it is a categorization of several different components into a leakage detection function. Virtually all of the various components which are utilized to monitor leakage are not safety grade thus their inclusion on the safety-related component list is not appropriate.

31) Pressurizer relief piping from pressurizer to the pressurizer drain tank.

Piping between the pressurizer and the pressurizer safety valve; .ad power operated relief valves is Class A (Class I) and as such is safety-related. The piping between the safety / relief valve discharge and the pressurizer relief tank is Class E (nonsafety) and, therefore, is not included within the purview of the QA program (See Table 3.2.2-3 in tLe FSAR for a list of piping classification and criteria).

41) . Hydrogen analyzer' system.

-The hydrogen analyzers are connected to redundant Class 1E power sources to assure a source of power under emergency conditions. However, the hydrogen measurement equipment is not safety grade and should, there-fore, not be included on the list of-safety-related components.

Part b. Response:

1) Clarify that the Q-list includes the pres urizer PORVs and associated block valves (including their actuators).

The pressurizer PORV's, associated block valves and their actuators are safety-related components which are subject to tppropriate QA requirements.

2) Clarify that main steam isolation valves are included on the Q-list. It is not clear from the designation "D" in Table 3.2.2-2 whether main steam isolation valves are "Q required."

The main steam isolation valves are safety-related components which are subject to appropriate QA requirement. (The "D" in Table 3.2.2-2 is a typographical error, it should be "X").

3) ' Clarify that main steam piping (S.G. to MSIV) is included on the Q-list.

Main stesa piping between each steam generator and its associated isola-tion valve (MSIV) is Duke Class B piping and is subject to appropriate QA. requirements.

4) Clarify that the containment sump, sump screen, and vortex suppression devices are included on the Q-list.

The containmrat emergency sump components were designed and installed as safety-rela *.ed components and are maintained as such.

5) Clarify what is meant by " selected" in Table 3.2.3-1. When applied to valve motors or solenoids, exempted valves should be justified specifically by their function (s) or lack thereof.

" Selected" valve motor operators or solenoids in Table 3.2.3-1 refers to those operators attached to valves that serve a safety function and are con-nected to a Class 1E power source. Valve operators in this category are classified as safety-related and are subject to appropriate QA requirements.

6) Identify the safety-related instrumentation and control systems to the same scope and level of detail as provided in Chapter 7 of the FSAR.

Table 3.2.3-1 and the various sections in Chapter 7 describe the instru-mentation and control systems in sufficient detail. McGuire station

! drawings, procedures and equipment listings provide the detail necessary l for determining the safety-related status of individual switchgear, area termination cabinets, switches, relays, etc. This level of detail is not required to be included in the FSAR.

7) -Clarify that " Containment" (Table 3.2.1-1) includes

(a) Personnel access' hatches and associated seals, valves, piping, and tanks.

(b) Equipment 1 access hatch and seals.

3 (c) Divider barrier seal.

The criteria for the personnel airlocks (including associated seals, valves, piping and tanks), equipment access hatch and the containment divider barrier seal are discussed in Section 3.8.2 of the FSAR. All of these components are considered safety-related and treated accordingly.

The equipment hatch seals are tested periodically according to the Technical Specifications; however, the seals are not treated as safety-related.

8)' Clarify that operators of valves which require safety-related quality assurance also require safety-related quality assurance.

See response to ites b.5. above.

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Part c. Response:

NUREG-0737 outlines requirements for operating plants and NTCL plants which must be implemented according to specified schedules. NUREG-0737 does not address whether an item is safety-related and does not imply that the items should be on a "Q list".

Several items in NUREG-0737 involved reviews or upgrading of procedures, plans, programs, etc. For these items, it is inappropriate to require that they be safety-related.

For some items, hardware changes were made or new equipment was added.

Appropriate quality assurance requirements were imposed as discussed below.

Several items in NUREG-0737 have not been implemented for various reasons.

Appropriate quality requirements will be imposed when these items are implemented.

Responses to each of the identified items are given below:

1) Plant Safety Parameter Display Console I.D.2 This item is not installed. Quality assurance criteria appropriate to the method of implementation will be utilized.

2) Reactor Coolant System Vents II.B.1 This system was installed as a safety grade system. It is described in the document "McGuire Nuclear Station - Response to TMI Concerns."

This information will be incorporated into the FSAR at a future date.

3) Plant Shielding II.B.2 This item requires a review of the accessibility of various station areas under post-accident conditions. This review is not considered safety related.

4) Post-Accident Sampling II.B.3 Two new sample panels have been designed to meet the requirements of this item. .These panels meet the criteria of NUREG 0578 which did not include a requirement that these panels be built to safety grade criteria.

5) Valve Position Indication II.D.3 This item is discussed in the document "McGuire Nuclear Station -

Response to TMI Concerns" ao4 is identified as safety-related.

6) Auxiliary Feedwater System II.E.1.1 The Auxiliary Feedwater System (AFS) is a safety-related system.  !

Item II.E.1.1 required that 1) a reliabri.:. analysis of the AFS be ,

performed, 2) a review of the AFS against the criteria in SRP 10.4.5, '

be performed and 3) the AFS flow rate design bases be re-evaluated.

These reviews and evaluations were performed; however, they are not considered safety-related.

7) Auxiliary Feedwater System Initiation and II.E.1.2 Flow (Indication)

The automatic initiation circuitry for the AFS is safety-related. The flow indication which was added as a result of Item II.E.1.2 is safety grade and will be maintained accordingly.

8) Emergency Power for Pressurizer Heaters II.E.3.1 Two banks of pressurizer heaters are provided with power from the on-site essential power system. This power system is safety-related.

9) Dedicated Hydrogen Penetrations II.E.4.1 This requirement is not applicable to McGuire.

~ 10) . Containment Isolation Dependability II.E.4.2 The McGuire containment isolation valves and their associated controls are safety-related.

11) Accident Monitoring Instrumentation II.F.1 See response to Item a.27.

12) Instrumentation for Inadequate Core Cooling II.F.2 See response to Item a.27.

13) Power Supplies for Pressurizer Relief Valves, II . G. I .

Block Valves and Level Indicators The power-supplies for this equipment consist of station emergency and vital busses which are identified and treated as safety-related.

-14);. Automatic PORV Isolation II.K.3.(1)

- 15) Autematic Trip of Reactor Coolant Pumps II.K.3.(5)

Neither of these functionscis provided-as part of the McGuire cesign and no decision has been made to install them.

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16) PID Controller II.K.3.(9)

The requirement contained in this item was to prevent the derivative action of the PID controller from opening the pressurizer power operated relief valve. This was done for McGuire. This controller is not safety-related nor does item II.K.3.(9) require that it be designated as such.

17) Anticipatory Reactor Trip on *.*urbine Trip II.K.3.(12)

This trip, like all reactor trips, is processed through solid state protection system which is a safety-related piece of equipment.

18) Power on Pump Seals II.K.3.(25)

The component cooling water pumps provide cooling water to the reactor coolant pump seals. This system is provided with onsite emergency power so that in the event of a loss of offsite power cooling water to the pump seals would be provided. Both the Component Cooling Water System and the onsite emergency power system are safety-related.

19) Emergency Plans III.A.1.1/III.A.2 Emergency plans involve administrative controls to assure that various actions a i taken in the event plant conditions warrant these actions.

The McGuire Emergency Plan and implementing procedures are not safety-related.

20) Emergency Support Facilities III.A.1.2 NRC Generic Letter 81-10 dated February 18, 1981 outlines the NRC requirements for each of the emergency support facilities. - This letter does not require or imply that any of these facilities must be safety-related. -None of the Duke emergency support facilities are considered safety-related.

21) Inplant Iodine Radiation Monitoring III.D.3.3 This monitoring would be performed using portable survey instruments and silver zeolite cartridges as discussed in the document "McGuire Nuclear Station - Response to TMI Concerns." These types of monitoring devices are not safety-related.

.22) Control Room Habitability III.D.3.4 The Control Room Ventilation System at McGuire is considered safety-related and is treated as such.

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