ML20004D930

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Forwards Response to Open Items Re Primary Coolant Outside Containment,Valve Position Indication,Nonqualified Equipment & Bypass Leakage.Draft Revised FSAR Amend 33 & Answers to 810601 Structural Engineering Branch Questions Encl
ML20004D930
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 06/08/1981
From: Colbert W
DETROIT EDISON CO.
To: Kintner L
Office of Nuclear Reactor Regulation
References
EF2-53-492, NUDOCS 8106100344
Download: ML20004D930 (29)


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June 8, 1981 p(hp 19 EF2 - 53,492 S" A Mr. L. L. Kintner Division of Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear 'Ir. Kintner:

Reference:

Enrico Ferr.'i Atomic Power Plant, Unit 2 NRC Docket No. 50-341

Subject:

Responses to Open NRC Questions Please find enclosed several items related to the Fermi 2 docket responding to NRC questions. This information will be included in a forthcoming FSAR amendment as appropriate.

Item 1 AEB/CSB Akstulewic / Lane Bypass Leakage Detroit Edison's response to this verbal equest of maximum bypass leakage and supplemented Tr.ble 6.2-2 information is enclosed as Attachment 1.

Item 2 SEB Q130.9 High Density Spent Fuel Rocks Detroit Edison's response to this SEB question is enclosed as Attachment 2.

Item 3 ETSB H.III.D.1.1 Primary Coolant Outside Containment Detroit Edison will revise theFSAR as detailed on Attachment 3 to further clarify this item.

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Mr..L. L. Kintner June 8, 1981 EF2 - 53,492.

Page 2-1 Item 4 RSB. Savannah River Non-Qualified Equipment in Accidents Det'roit. Edison's response to this item is enclosed as l Attachment 4.

Item 5 ICSB II.D.3 V,alve Position Indication .

In response to a concern from Mr. Gerry Mauch, Detroit Jdison has revised its response to this item. Please see Attachment 5..

Sincerely,

. mA ESM William F. Colbert Technical Director j Enrico Fermi 2 l RMB/WFC:jl l Attachments l

cc: Mr. B. Little

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-R. M.. Berg..

W. F. Colbert' F.-E. Gregor .

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P. A. Marquardt L. E. Schuerman H. Tauber

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R. M. Berg /L. E. Schuerman From: R. J. Beaudry/M. L. Batch Item

4. NRC is requesting that Edison provide its best estimate of the maximum bypass leakage that could be expected (NRC suggests 2%) . A sophisticated calculation is not necessary, but a number is required. NRC notes that FSAR Appendix A was apparently deleted. This appendix could be used as a basis for determining bypass leakage should Edison choose to do so. As a minimum, however, the NR (Fraak Akstulewicz and John Lane) requires that we pro-vide a supplement to Table 6.2-2 which identifies the lines connected to the primary containment and pass through the

- secondary containment which could be potential bypass paths.

Response

We estimate that the amount of primary - containment leakage expected to bypass the SGTS should be no greater than 4%;

moreover, we anticipate that the actual amount will be sign-ificantly below this value.

The attached table lists all potential bypass leakage paths in the broadest interpretation of Section B.5 of Branch Technical Position CSB 6-3. However, as accepted in CSB 6-3, Fermi 2 employs air or water sealing systems which el-iminate leakage through certain valves.

'1. Ths MSIVLCS eliminates leakage through main steam lines and steam line drains.

2. The IWMS suction lines - penetration X-213A and B - are sealed with water in the torus.
3. All leakages to the feedwater system will be sealed with water in that system.

The Bypaso Leakage Program will maintain a running total of

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leak rate measurements through all other valves in the table and compare 'it with the maximum allowable. Decision on valve maintenance will be based on the closeness of these two num-bers.

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BYPASS IFENE PHOCitiv ,

Primary P&ID Containnent Ntzabers Valves Size,

  • Penetration Line 6M721- Tested In.dia. Test IEMAGE TO STEAM MANIEOID AT 'IURBINE-Gt24 ERA' LOR X-7A Main Steam Line 2089 V17-2003 26 MSIVICS
  • V17-2007 26 V17-2101 26 X-7B Main Steam Line 2089 V17-2001 26 V17-2005 26 i V17-2102 26 X-7C Main Steam Line 2089 V17-2002 26 V17-2006 26 V17-2099 26 X-7D Main Steam Line 2089 V17-2004 26 V17-2008 26 V17-2100 26 LEAKAGE 'IO MAIN 00tn2JSER X-8 Steam Line Drains 2089 V17-2009 3 App. J Type C V17-2010 3 App. J Type C t

V10-2003 3 MSIVILS X-10 BCIC Steam Line 2044 V17-2036 1 Sect XI, Cat. B Drain V17-2037 1 Sect XI, Cat. B X-ll llFCI Steam Line 2035 V17-2024 1 Sect XI, Cat. B Drain V17-2025 1 Sect XI, Cat. B

  • Testing Program for MSIVILS described in ESAR 9A.3.4 MIB/dk 6-5-81

BYPASS IEAKAGE PHOGRAM PAGE 2

' Prinary P&ID (bntaintment Nuobers Valves Size, I

Penetration 'Line 6M721- Tested In.dia. Test-IDEAGE 10 FEEIMATElt SYSlm X-9A' Feedwater 2023 V12-2002 20 App. J Type C V12-2008 20 . App. J Type C X-9B Feedwater 2023 V12-2001 20 App. J Type C V12-2007 20 App. J Type C X-21CB SWIS 4100 V8-3847 4 App. J Type C V8-3849 4 App. J Type C X-213A Tess 4100 V8-3832 6 App. J Type C V8-3834 6 App. J Type C X-213B SWE 4100 V8-3831 6 App. J Type C

.V8-3833 6 App. J Type C X-227A *1ws 4100 V8-3848 4 App. J Type C V8-3850 4 App. J Type C 4

IEAKAGE TO C0t0WSATE STORAGE TANK i

11ICI 2035 V8-2198 10 Sect. XI Cat. B X-9A 4

V8-2200 10 Sect. XI Cat. B X-98 ICIC 2044 V8-2232 24 Sect. XI Cat. B IIAKAGE 'IO RAD WASTE BUIIDLNG X-18 Drywell Floor Sunp 2032 V9-2044 3 App. J Type P V9-2005 3 App. J Type C Drywell BJuipment 2032 V9-2022 3 App. J. Type C X-19 S*C V9-2023 3 App. J Type C MLB/dk 6-5-81 ,

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RESPONSE TO STRUCTURAL ENGINEERING BRANCH QUESTIONS OF JUNE 1, 1981 130.9 HIGH DENSITY SPENT FUEL RACKS QUESTION 1 Indicate whether the proposed fuel racks modifications conform with the NRC position on " Fuel Pool Storage and Handling Application" dated April, 1978 and amended January 1979. If any deviations exist identify and justify these deviations.

RESPONSE

The proposed fuel rack modifications do conform with Sawg the NRC position dated April 1978 and amended 1979.

QUESTION 2 The responses to Questions 130.7.2 and 130.7.3 are not satis-factory. Provide the following:

a. Justify why the spent fuel pool liner was designed in accordance with ASME Boiler and Pressure Vessel Code, Section VIII, Division I instead of Section III, Subsection NE and ACI 359.
b. Indicate in detail,the methodology used to demonstrate the leak tight integrity of the fuel pool liner when i

subjected to the postulated fuel assembly drop over spent fuel racks .. directly falling over the fuel l l

pool Liner. The fuel assembly drop should be analyzed for tilted position and straight drop.

. RESPONSE TO STRUCTURAL ENGINEERING BRAHCN QUESTIONS OF JUNE 1, 1981 PAGE 2 I

RESPONSE

a. The following codes and standards are used for .

the design of the spent fuel pool liner.

(i) ASME Boiler and Pressure Vessel Code,Section III, Division 2, also called as ACI 359 (Liner plate design).

(ii)

ASME Boiler and Pressure Vesse' Code, Sectior VIII, Division 1, Subsection B (for welds).

(iii) ACI 347, recommended practice for concrete formwork (for tolerances).

It is to be noted that ASME Boiler and Pressure

  • Vessel Code,Section III, Division 1, Subsection NE is not applicable for spent fuel, pool liner since Subsection NE establishes rules for metal contain-ment vessels and their appurtenances.

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b. The effect of fuel assembly straight drop on to thefuelpoollinerwasevaluatd@Qingthe principles of conservation of energy and con-servation of momentum. The following assumptions were made in the analysis:

- - Fuel assembly weights 700~ pounds (600 lbs sub-merged) l

- Nose of assem'bly assumed 1.5 inches diameter (based upon ass'umed partial crushing of the nose, "TF 44W W WEWWW W** -g-- -@ -

RESPONSE TO STRUCTURAL ENGINEERING BRANCH QUESTIONS OF JUNE 1, 1981 PAGE 3 but this crushing energy neglected in the analysis).

Fuel assemtly assumed rigid as far as energy absorption (all kinetic energy transferred to liner and slab)

Dragcoefficientassumeck . 86 (based upon a cylinder)

Overall behavior of the slab was assumed to be formation of yield lines in a 34' x 42' fixed edge condition slab The. analysis used the Standford Research formula to investigate'the local penetration of the liner plate.

Yield line theory was used to evaluate the overall

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behavior of the slab.

Results of the analysis show that the fuel assembly

. can be dropped 6'-6" (nose of assembly 6'-6" from linct plate) without penetrating the liner or causing over-all slab instability.

The assumption of fuel assembly rigidity is a gross

, approximation, of course, which leads to extremely conservative results. The degree of conservatism, however, cannot be estimated unicas some experimental G

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RESPONSE'TO STRUCTURAL ENGINEERING BRANCl! QUESTIONS OF JUNE 1, 1981 PAGE 4 work has been done measuring the energy in deforma-

' tion on impact; we are not aware of any such work.

The assumption of fuel assembly rigidity would give even more conservativ9 results for the tilted case.

Therefore, the straight drop case would be limiting and no additional work was done for the tilted case.

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QUESTION 3 .

With regard to the fuel assembly drop on top of the rack, provide the following: ,

a. The acceptance criteria used for this case. -
b. Detailed descriptions of the method used to satisfy the acceptance criteria. ,

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c. Comparison between the drops in tne titled position, straight drop on the middle of the rack and on the edge of the rack.
d. Indicate whether other modes of failure of the racks exist beside crushing.
e. Discuss these same concerns for the stainless steel racks and for the. aluminum racks.

e RESPONSE The acceptance criteria used for the drop test is a calculation of the stress induced at the base of the rack, and a calculation of the local stress at the point of impact at the top of the rack. Also calcu-

l RESPONSE TO STRUCTURAL ENGn1EERING BRANCH QUESTIOMS OF JUNE 1, 1981 PAGE 5 lated is a conservative estimate of the deformation of the rack base for the case of a falling object impacting directly on the rack base. The method used involves calculating the total energy of the falling

object, and assuming that all of this energy is absorbed as strain energy in the rack. This item gives an esti-mate of the peak force developed by the impact. For a corner impact, this peak force leads to direct load plus ; two bending movements at the rack base. The stress induced in the rack is shown to be below yield.

4 The cage of corner impact leads to the highest rack stress and.is the only case investigated. The local impact stress at the point of impact is computed using wave propagation theory and a knowledge of the impact-ing body velocity. It is shown that the local stress at the point of impact is below yield.

The possibility of performation of the base plate by an object falling directly to the bottom is addressed.

An energy balance is'used to calculate an estimate

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The deformation is of local plate deformation.

' shown to be less than the plate thickness so that no perfor/ationoccurs. This calculatior. is made neglect-ing any ef fect of strain hardening and neglecting the retarding ef fect of ,the water so that the results are conse r vr.tive . _

RESPONSE TO STRUCTURAL ENGINEERING BRANCH QUESTIONS OF JUNE 1, 1981 PAGE 6

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QUESTION 4 .

Indicate whether material, fabrication, installation and quality control of the racks conform with Subsection NE of the i

ASME Code.

RESPONSE

The fuel rack structural design is per ASME Section NF, the material specifications are per ASTM, and ASME Section III is followed for all items.

QUESTION 5 In.Section 6.2.4 of the Joseph Oat Corporation Report, it is stated that only fluid damping is included in the analysis and is simulated by inclusion of appropriate equivalent linear damping. Indicate what this damping value is and justify the damping value used in the analysis.

RESPONSE

. Section 6.2.4 is being revised to reflect the racks have been qualified by analysis without taking credit for any fluid damping. When and if structural damp-ing has been included, a maximum of 4% during SSE conditions has been used in accordance with URC Regulatory Guide 1.61. The seismic modelin the e

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RESPONSE TO STRUCTURAL ENGINEERING BRANCH QUESTIONS OF JUNE 1, 1981 PAGE 7 Joseph Oat Report contains provisions for inclusion of fluid damping. The damping model used is based on the losses incurr,ed in forcing a fluid in'and out of a narrow gap. As noted above, qualification runs have assumed zero fluid damping values. If fluid damping were to be included, the values chos .: would be such as to insure that the ectal damping from all contributions (structure, material, fluid)did not exceed 4% during SSE conditions.

QUESTION 6 .

Indicate why the empty or nearly empty rack case was,not used in the analysis to predict the maximum rack displacement.

RESPONSE

The Joseph Oat Report is being revised to show the results for the nearly empty rack.

QUESTION 7 Indicate how the increase,in the value of the plant design earthquake and consequently the change in the floor response spectrum could affect the seismic analysis done so far for .

1 the fuel pool racks.

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, BRANCH' QUESTIONS OF JUNE 1, 1981 PAGE 8

RESPONSE

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RESPONSE TO STRUCTURAL ENGINEERING BRANCH QUESTIONS OF JUNE 1, 1981 PAGE 9 a

QUESTION 8 Because different type (169, 108 and 35 cells) modules were used in the proposed modification with different sizes and

' weights, indicate which type was used in the seismic and slicing analysis. Indicate also how other types were quali-fled for the postulated loadings.

. RESPONSE All three modules were qualified separately and completely for seismic and other postulated load-

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EF-2-FSAR k'IDW W W 3 us-c y n H.III.D.l.1 Primary Coolant Outside Containment H.III.D.l.l.1 Statement of Concern Parts 20 and 100 of Title 10 of the Code of Federal Regulations specify radiation limits and guidelines for licensed facilities to ensure the protection of public health and safety. In a power reactor, many systems that may or will contain significant radio-active liquid and/or gas inventories af ter a serious transient or accident have components located outside containment. At TMI-2, the major radioactive releases appear to have come from leaks in such systems. Leakage from the systems must be maintained as low as practicable to prevent releases of significant quantities of radioactive material when the systems are operated. The plant operating staff should know the leakage rate of each system and have positive control over them *.o ensure the maximum availability of the equipment.

H.III.D.l.l.2 NRC Position Applicants shall implement a program to reduce the leakage from systems outside containment that would or could contain signifi- ,

cant radioactive inventories during and after a serious transient  :

or accident to as low as practicable rates. A summary description and the initial leak-test results of the program shall be provided.

Systems that should be leak tested include the following:

! a. Residual heat removal l

l b. Containment spray recirculation

c. High-pressure injection recirculation
d. Containment and primary coolant sampling
e. Reactor core isolation cooling
f. Waste gas including headers and cover gas system, decay system, or storage system l

The testing of gaseous systems should include helium leak detection or equivalent methods. Consideration should also be given to 3 i

design changes that reduce potential release paths.

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t H.III.D.l.l.3 Detroit Edison Position Table H.III.D.l.1-1 identifies those liquid and gaseous systems a containing radioactive fluids following a serious accident. Leak-test methods and procedures, described in Subsection H.III.D..l.l.4, and the baseline leak-test data are the bases for the program to maintain the leakage rates of all the applicable systems as low Q as practicable.

H.III.D.l.1-1 Am?ndment 33 - March 1981

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'H.III.D.l.l.4 Leakage Reduction Program s

H.III.D.l.l.4.1 Design Basis

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The leakage reduction program described in this section is based on Requirement 2.1. 6.a of UUREG-0 578 (Reference 1). It also takes into account the requirements of i tem II I .D. l .1 of NUREG- /

0660, NUREG-0694, and NUREG-07 37, " Primary Coolant Sources Out- /

side Containment" (References 2, 3, and 4).

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The program includes measures to reduce and maintain Icakage to as low as practical for systems outside primary containment that could contain highly radioactive fluids dur{ng,a serious - 3-transient or accident. 7Y'$ M#9 t.x;ac r&.s7J s47 m7.f4.M444 Ne7~ $Q'g%'8b;;r gpg# $ wg W,. &

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4 ypplicabh systems a+--incp :ted f or--+xte rs.2 ' ic axow = ne r* re a

leab t : : t 9 W'hJc,H =4 _ ; y.  ; w a e n d p r "  ; - ' ' 7 - i i' ~-

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aft ^r. Visual inspections are conducted on accessible portion) N ##/54"'

of systems during system operational testing or during normal U#4 ##j

K system operation. Leak-rate testing is performed on specific j((j7y-[a 4 valves on systems that provide an interface to equipment or 3 k systems located external to the secondary containment and which jgy,,g,g, ,

can bypass secondary containment. AW'G#4 ',','

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Records are maintained on the inspections and tests performed #6 J'u 9##7 and are used to identify chronic and generic leakage problems 77 WVE b

g in order to implement measures. These reconds modif.ications and/oravailable are also made corrective to maintenance the plant -

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H.III.D.l.l.4.2 Descriotion -

Table H.III.D.l.1-1 lists systems outside primary containment that could contain highly radioactiva fluids and that would be

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used in mitigation of an accident. Table H.III.D.L.1-2 lists systems outside primary containment.that should rot contain highly radioactive fluids or would not be used in the mitigs-tion of an accident. Only the systems in Table H.III.D.1.1-1 are included in the leakage reduction program.

Each system identified in Table H.III.D.l.1-1 has a surveillance test pack.' age containing the following items:

-a_ Rimolified engineering' sketch indi-'t!.g system test boundaries. into as o used only as an aid in visualizing tha _ omponents 6 " r em to be tested; detaile . st boundaries are verified tr .. ha current r 'oton of the system ' drawings before initial t+. 'a .

dLA. Statement explaining why that particular system is an impor tant factor in mitigating a serious tran.cient or accident.

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EFo2-FSAR b g. Description cf system conditions and plant operating

) conditions necessary to conduct each component leak-rate test, along with an explanation substantiating the test boundary. The division of the system into ,

parts for testing purposes and the emission of parts of the system from testing is included in this explanation. ,

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Elaboration of special test methods necessary to supplement the general test methods.

E g. Data sheet listing system components to be tested.

The data sheet identifies drawing numbers and provides

. for recording of measured leakage.

H.III.D.l.l.4.3 Evaluation The leakage reduction program is designed to minimize leakage from systems outside primary containment that could contain large radioactive inventories after a serious transient or accident; minimizing this leakage will diminish the potential for release of significant amounts of radioactive materials to the anviron-ment. Periodic leak testing, followed by preventive and cor-

.rective maintenance, ensures minimum leakage on a continuing O basis.

o E.III.D.l.l.4.4 General Test Methods

<c In order to ensure system integrity, two general types of tests 3 are conducted. The first type of test consists of periodic H visual inspection of systems and components during system opera-tional testing or during normal system operation. This inspection V is made to identify leakage into the secondary containment through D valve stems, pump seals, fittings, relief valve discharge lines, T drains, vents, and instrument loops. The second type of test s is a periodic individual component leak-rate test used to deter-l 4 mine leakage through valve seats into interfacing systems outside of g p g g ary containment. Leak-rate testing is accomplished in ccr,ur.0 :en with ASME XIstest requirements (Reference 5) .

The following general test methods are used to determine leakage from the systems identified in Table H.III.D.l.1-1.

. ~~p o -o a. Liquid Systems - Sy;tems or portions of systems that

-fej contain liquids during accident conditions are filled k

v7 y} with system operating liquidaand pressurized to opera-tional test pressure or normal operating pressure 7 .< 9 before conducting visual inspections for external

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leakage. Where evidence of leakage exists (e . g . ,

water stains on lc.gging), the source of leakage is

> } verified by visually observing the suspected leakage point for a minimum of 5 minutes. Where measurable

$c4b lj .. V leakage exists, specific techniques for collecting l ]%

Jfe gg the leakage are implemented (see below). Valve seat leaA rate measurements are cdhducted in ac.ordance

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H.III.D.l.1-3 Amendment 33 - March 1981

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,$q y,I 1 ith ASME XI procedures. Measured Icakage is recorded and is used as a basis for impicmenting corrective

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N' B t yh diaseous Systems - For systems or portions of systems

%  % FIthatcontaingasesduringaccidentconditions,a f pressure drop test or measurement required to maintain system pressure provides of makeup gas rate an For such s

3 overall indication of system integrity.

3 tests, the system is pressurized to operational test 9g kNigpressure a clean or source normal of operating air.7) Specificpressure usingofnitrogen points leakage ggs got are located by helium Y leak detection or equivalent testing methods. Valve

)Sntotneseconcarycontatn=ent kgg Q seat leak-rate measurements are conducted in accordance jwithASMEXIprocedures.

. Specific Techniques for Collecting Liquid Leakagq

a. Drains, Vents, and Reliefs is - Leakage from valves collected by connecting piped to open connections polyethylene tubing from the open end to a suitable collection container
b. Pumo seals is

- For pumps with shaft leakoff drain lines, collected by connecting polyethylene tubing -

. leakage from the drain line to a suitably sized container. ,f'

- For pumps without drain lines, a temporary means of collecting leakage is used according to pump con-figuration and accessibility In all cases where polyethylene tubing is used, the length of

< tubing is minimizedWhere in order to collect collection the smallest of leakage amount of is impossible due leakage possible.

to physical configurations, or if the leakage is too small to be collected, a visual method for estimating leakage is used.

For example, 20 drops is equivalent to 1 ml.

H.III.D.1.1.5 References

1. U.S. Nuclear Regulatory Commission, TMI-2 Lessons Learned Task Force Status Repor t and Short-Term Recommendations,

' NUREG-057 8, J uly 19 79.

2. U.S. Nuclear Regulatory Commi'ssion, NRC Action Plan Developed

- as a Result of the TMI-2 Accident, NUREG-0660, Vols. 1 and 2, e May 1980.

'3 . U.S. Nuclear Regulatory Commission, TMI-Related Requirements for New Operating Licenses, NUREG-0694. J une 1980.

H.III.D.l.1-4 Amendment 33 - March 1981

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EF-2-FSAR

--q _4. U.S. Nuclear Regulatory Commission, Clarification of TMI V Action Plan Recuirements, NUREG-0737, Octobot 1980.

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5. ASME Boiler and Pressure Vessel Code,Section XI.

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EF 2-FSAR SYS* EMS OUTSIDE PRIMARY T NTAfh?.D4T TABI.E H. III .O .1.1-1

'I1IAT CCCID CO*;!A!N HICHI.Y RADIOACTIVE Ft.UIDS O Reactor core isolation cooling Residual heat removal Contain=cnt spray

. Suppression pool cooling Ion-pressure coolant injection

' Shutdown cooling Core spray l Reactor water sample Reactor water cleanup Canbustible gas control High-pressure coolant injection ,

Standby gas treat.ent Control rod drive discharge header's,

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THAT WOU!D IKTl CC!r*AIN IttClit.Y MDICACTIVE FI.UIDS System Carnent RER fuel pool cooling Not directly af fected by accident.

Standby liquid control Injects fluid and does not circulate

- reactor coolant.

General service water / emergency Do not circulate reactor coolant and equipment service water could becom conta:ninsted only due to system leaks.

Reactor building closed cooling Do not circulate reactor coolant and water /cmergency equipment could become conta:ninated only due cooling water to system leaks.

Condencate storage Could beccrue contaminated only due to isolation valve leakage.

Domineralized water makeup Could tecoce contasinated only due to isolation valve leakage.

Torus water management Isolated during IOCA and not required for accident mitigation.

Control air / station air Would require system failure.

Fuel-pool cooling and cleanup Not directly affected by accident.

Main stea:s lines Would require f ailure of MSIVs and f ail-ute of MSIV leakage control system.

Feedwater lines Would require failure of isolation valves.

. Drywell cooling system Uses RSCCW or EECW and is not needed for safe shutdown of plant.

RER

  • tea:s condensing Not required for accident mitigation.

Reac or building floor / equipment Not required for accident mitigation.

dr > ins Minimizing leakage frern systees in' Table H.III.D.l.1-1 minimizes input to this syste:n.

Padwaste Not required for accident :nitigation.

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H.III.D.l.1-7 Amendment 33 - March 1981

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16. USE OF NON-SAFETY GRADE EQUIPMENT IN' SHAFT SEIZURE ACCIDENT ANALYSIS (15)_

The applicant must submit additional information with regard to pump shaft seizure accident analysis without allowance for the use of non safety grade equipment.

RESPONSE -

The recirculation pump seizure event is considered to be en extremely unlikely event and as suca falls -

into the category generally classified as an accident.

The event is evaluated as a limiting fault. The potential eifects of the hypothetical pump seizure

" accident" are very conservatively bounded by the effects of the DBA-LOCA.

  • This is easily verified by comparis.on of the two events. In both accidents, the recirculation driving-

- loop flow decreases extremely rapidly. In the case of seizure, stoppage of the pump occurs; for the DBA-LOCA, the severence of the line has a similar, but more rapid and severe influence. Following a pump seizure event, water level s maintained, the core remains submerged, and this provides a continuous core cooling mechanism. However, for the DBA-LOCA complete-flow stoppage occurs and water level decreases due to loss of coolant, thus resulting in uncovery 1

of the reactor core and subsequent overheating of the fuel-rod cladding. Also, complete depressuriza-tion occurs with the DBA-LOCA, while reactor pressure 1

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does not significantly decrease for the pump s41zure event. Clearly, the increased temperature ,

of the fuel cladding and reduced reactor pressure for the DBA-LOCA both combine to yield a much more severe stress and potential for cladding perfora-tion for the DBA-LOCA than for the pump seizure.

Therefore, it is concluded that the potential effects

  • of the hypothetical pump seizure accident are very '

conservatively bounded by the effects of the DBA-LOCA and a specific core performance analysis or ra'dio-Logical evaluation is not considered necessary. How-ever, to be completely responsive to the NRC question,.

the following narrative is provided to show the impact of not taking credit for non-safety-grade equipment to terminate this event:

1. Level 8 Turbine Trip The FSAR analysis of the pump seizure event assumes that the vessel water level swell due to pump seizure will cause high water level (Level 8) trips of the main turbine and the feedwater pumps, and indirectly initiates a reactor sc am as a result of the turbine trip. The level 8 trip for each feedpump and_ M O e, turbit.eggnerator are designed tObec-jinf71e--failbfe#'

Fftbr-- IT,'"for some unknown rea.~n,1tffr'! Walls c6 operat//e, high high moisture-revefHnter%F r, tEu~TdTIrine'would cause,

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vibration to the point where mechanical vibration

. will trip the turbine. In case of the pump seizure without an L8 h ip, the event is less severe than the analysis in the'FSAR with the L8 trip for the following reason: A pump seizure, should it occur, would result in core flow reduction which reduces

' the core powcr and surface heat flux due to the .

effect of the negative void reactivity coefficient.

Hence, the surface heat flux existing when the turbine trip occurs is lower because the turbine trip occurs later. Therefore, a loss of Level 8 trip would result in a less severe event consequence -

from the fuel han that depicted in Subsection 15B.3.3.

2. Main Turbine Byoass System As a result of the NRC's concern regarding reactivity effects of pressure transients, GE and the NRC met on November 20 and 21, 1978 for a comprehensive review of turbine trip and load reject transients without bypass. The principal conclusion of that meeting was that the most limiting BWR transient

, event which takes credit for nonsafety-grade equip-ment is the feedwater controller failure. Analy. sis indicates that a ACPR increase of approximately 0.08 applies to this transient without a functioning main turbine bypass system.

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For recirculation pump seizure with a failure of turbine bypass system, the increase of ACPR would

.be less than that for the feedwater controller . .

failure for the follo ing reason. As this event occurs, the reactor power drops significantly within the first 2 seconds due to decreased core flow. Therefore, by the time of the turbine trip,

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the reactor power is at e low level. The core power is he main parameter which relates to the fuel thermal limit. The effect of f ailure of the main turbine bypass system to stop the steam flow retains pressure on the core but contributes only a small positive reactivity feedback. This is a

' secondary effec't of much less significance than the reactivity decrease due to fluid flow decreasing

. through the core.

The increase of core power is more severe for feed-water controller. failure (increasing) event than for a recirculation pump failure.because it occurs at a higher power level.

3. Relief Function of Safety / Relief Valver The contribution of MCPR from taking credit for the relief function rather than the safety function of safety / relief valves is not significant because the MCPR always reaches its lowest value before opening of the relief valves.

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Analyses of recirculation pump seizure where coolant flow rate drops rapidly have shown that MCPR does not increase

. significantly before fuel surface heat flux begins dropping enough to restore greater ther' mal margins as the plant intrinsically responds to the reduced flow rate. The effect of not taking credit for non-safety-grade equipment is a ACPR increase of 0.08. Therefore, the MCPR for pump seizure event -

is still well above the safety limit of 1.06.

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Integration into op2rator trcining --

65)476/T2 *

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Other alarms during emergency and,nced for priori- kh>

  • tization.of alarms ,

H.II.D.3.3 Detroit Edison Position '

Tha Farmi 2 plant has a valve-position-indication system that uccc cne pressure switch on each of the 15 safety and relief volycc.

The existing tailpipe temperature-monitoring system provides a backup and monitors valve leakage as its normal ,

I function. .

H.II.D.3.4 s

  • Modifiestions H.II.D.3.4.1 . Design Basis -

An in-containment, tailpipe-mounted, pressure-switch system provides of the relief status valves information and safety viavalves.

control room indicating lights -

This system provides the following information cnd obnor=al operating conditions: to the plant operator during normal

' a ." FO itiv indication of valv pe r i t ; a.. , .aciucing the i st'Luk v e s.. . 1+c ca..ditir- _

b. Positive identification of the specific valve or valves that are open e r

e  ?. .;a u uv i v u v:

depressuri:r.icn

.'.; c '~ S nn ne the au t o- e i e system (ADS) in the control room 3Y i ,U 5fL& 'f' By being provided with the immediate indication and annunciation of the valve opening and the identification of the valve, the plant operator can initiate recommended actions to control or rectify the situation.

The NRC has specified in NUREG-0578 and NUREG-0737' (References 1 and 2) that components of the safety / relief valve 5 cystem must (SRV) monitor be qualified for the appropriate environmental condi- i tions to plant operation. be experienced under normal and abnor=al conditions of

  • These environmental conditions include temper-of the component or humidity, and also the seismic acceleration ature, pressure, and aystem are attached. system to which the components of the SRV The system instruments are qualified to IEEE 323-1974 and
IEEE 344-1975. . N She' power for this system comes from a reliable source that *

-in not affected by the loss of offsite power.

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H. II . D. 3 Amendment 33 - March 1981 P00RORIGK1

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