ML20009B668
| ML20009B668 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/06/1981 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8107160633 | |
| Download: ML20009B668 (49) | |
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DocketHos.'50-35Er and 50-353 /
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Mr. Edward G. Bauer, Jr.
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Philadelphia Electric Company
[g. #'4k j8 Vice President and General Counsel d
2301 Market Street
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/g P. O. Box 8699
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Philadelphia, Pennsylvania 19101 J
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Dear Mr. Bauer:
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SUBJECT:
ACCEPTANCE REVIEW OF APPLICATION FOR OPERATING LICENSES FOR LIMERICK GENERATING STATION, UNITS 1 AND 2 Os March 17, 1981, you tendered an application for cperating licenses, Amendment 25 to the license application, for Limerick Generating Station, Units 1 and 2.
Your application included a Final Safety Analysis Report (FSAR) and an Environ-mental Report - Operating License Stage (ER0L). The FSAR consisted of a basic submittal of 16 volunes, an Emergency Plan of two-volums, a Fire Protection Evaluation Report of one volume and a Security Plan and Safeguards Contingency Plan. As requested by HRC you also submitted a two vol"m Probabilistic Risk Assessment.
We have completed our acceptance review of the majority of your te.. ered appli-cation and have concluded that it is acceptable for docketing. As a result of heavy workloads it was possible to only partially complete the acceptance review of the Fire Protection Evaluation Report of the FSAR.
It is anticipated that the review of this section will be completed about August 1,1981. Questions arising from that section will be sent to you separately. This will be done in order to avoid delays in docketing and in your responses to the questions on major portions of your appli: tion for operating licenses.
Following your submittal of the required number of copies your application will be docketed. These should include forty (40) copies of the FSAR (16 volumes)
Energency Plan (2 volumes), Fire Protection Evaluation Report (1 volume) and Probabilistic Risk Assessment (2 volumes). As required by 10 CFR 50.30, you should retain an additional thirty (30) copies of these for direct distribution in accordance with Enclosum 1 to this letter and further instructions which might be provided later.
In addition, twelve (12) copies of the proprietary fault trees for the Probabilistic Risk Assessment and two (2) copies of the separate report containing the volumincus computer printouts referenced as meteorological tables for Sections 2.3 of both the FSAR and.EROL will be needed. In the case of the EROL, forty one (41) copies are required for submittal and an additional one hundred nine (109) copies should be retained for direct
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Mr. E. G. Bauer, J r. g distribution in accordance with the instructions in Enclosure 2.
Within ten (10) days after docketing, you must provide an affidavit stating that the distribuion in accordance with Enclosures 1 and 2 has been completed. These requirements will also apply to all subsequent amendments to your application.
During the course of our acceptance review the enclosed Requests for Additional Infomation, Enclosure 3 for FSAR and Enclosure 4 for ER0L were developed. The NRC must receive your response to the numbered questions within 60 days of docket-ing to allow us to proceed with the technical review of the areas involved.
Your failure to do so will necessitate a delay in your schedule.
In addition to tne responses to the numbered questions, other supplementary information is needed to enable and/or expedite tne reviews. In most of these cases, PECo was previously informed by generic letters, requests for additional infomation, evaluations and statements of the need to provide the necessary infomation for staff review.
The most important of these questions and concerns are listed in Enclosures 5 14, Supplementary Request for Additional Infomation.
As stated above, the schedules for our reviews will be developed on the basis that tne information required will be available in 60 days. You will be advised of key milestones of the safety and environmental reviews as soon as the schedule is developed.
If, during the course of our review, you believe there is a need to appeal any staff position because of disagreement, this need should be brought to the staff's attention as early as possible. A written request is not necessary. All such requests shculd be initiated througn our staff project Manager, Don Calkins, assigned to review your application. He may be contacted by telephone on 301-492-8432. This procedure is an infomal one, designed to allow opportunity for applicants to discuss with management areas of disagreement in the case review.
Sincerely, Original signed by Darrell G. Eisenhut Darrell G. Eisenhut,' Director Division of Licensing
Enclosures:
As stated cc w/ enclosure:
See next page
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DISTRIBUTION:
Docket File (2)
Attorney, OELD LB#2 File DEisenhut RPurple RTedesco-ASchwencer MService Ol&E(3)
'CCs:
POR EPPDR ACRS (16)
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catc) sac ro=u sis tc e:isacu ezaa O FFICI A L R ECO R D CO P Y e n:-ura;
Mr. Edward G. Bauer, Jr.
Vice President & General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Troy B'.
Conner, Jr., Esq.
Mr. Vincent Boyer cc:
Senior Vice President Conner, Moore & Corber 1747 Pennsylvania Avenue, N. W.
Nuclear Operations Philadelphia Electric Company Washington, D. C.
20006 2301 Market Street Philadelphia, Pennsylvania 19101 Deputy Attorney General Room 512, Main Capitol Building Harrisburg, Pennsylvania 17120 Karl Abraham Public Affairs Officer Mr. Robert W. Adler Region I, OIE Assistant' Attorney General U. S. Nuclear Regulatory Commission Bureau of Regulatory Counsel 631 Park Avenue 505 Executive House King of Prussia, PA 19805 P. O. Box 2357 Harrisburg, Pennsylvania 17120 Allan Kanner, Esq.
1622 Locust Street Honorable Lawrence Coughlin Philadelphia, Pennsylvania 19103 House of Representatives Congress of the United States Ms. Phyllis Zitzer Washington, D. C.
20515 Limerick Ecology Action P. O. Box 761 Rcger B. Reynolds, Jr., Esq.
Pottstown, Pennsylvania 19464 324 Swede Street Norr;stown, Pennsylvania 19401 Robert J. Sugarman Berle, Butzel, Kass & Case 4J Rockefeller Plaza Lawrence Sager, Esq.
New York, New York 10111 Sager & Sager Associates 45 High Street Frank R. Romano Pottstown, Pennsylvania 19464 61 Forest Avenue Ambler, Pennsylvania 19002 Joseph A. Smyth Assistant County Sol;citor Marvia I. Lewis County of Montgomery 6504 Bradford Terrace Courthouse Philadelpnia, Pennsylvania 19149 Norristown, Pennsylvania 19404 John Shniper Eugene J. Bradley Meeting House Law Building & Gallery Philadelphia Electric Company Mennonite Churst Road Associate General Counsel Schulykill Road (RT 724) 2301 Market Street Spring City, Pennsylvania 19475 Philadelphia, Pennsylvania 19101 Steven P. Hershey U "" W esident ec r Inspector Sy(an'aHo U. S. Nuclear Regulatory Ccmmission Junniper and Locust Streets P. O. Box 47 Philadelphia, Pennsylvania 19107 Sanatoga, Pennsylvania 19464
. Alan J. Nogee Keystone Alliance 3700 Chestnut Street Philadelphia, Pennsylvania 19104 R. L. Anthony Box 186 Moylan, Pennsylvania 19065 Dr. M. Bruce Irvin, Pastor The Church of the God Shepard 35 West Philadelphia Avenue Boyertown, Pennsylvania 19512 Harodl A. Lockwood, Jr.
Lockwood, Rend & Bolger 2126 Land Title Building Philadelphia, Pennsylvania 19101 David Cohen, Councilman - at - Large City Council, Room 588 City Hall Philadelphia, Pennsylvania 19100 l
ENCLOSURE 1 DISTRIBUTION LIST FINAL SAFETY ANALYSIS REPORT, FIRE PROTECTION EVALUATION REPORT, AND PROBABILISTIC RISK ASSESSMENT STATE Governor's Office of the Budget ATTN: Coordinator, Pennsylvania State Clearinghouse Post Office Box 1323 Harrisburg, Pennsylvania 17102 Department of Environmental Resources ATTN:
Director, Office of Radiological Health Post Office Box 2063 Harrisburg, Pennsylvania 1710S LOCAL Chairman Board of Supervisors of Limerick Township 452 Limerick Center Road Linfield, Pennsylvania 19468 FEDERAL U. S. Environmental Protection Agency ATTN:
EIS Coordinator Region 111 Office Curtis Building (Sixth Floor)
'6th and Walnut Streets Philadelphia, Pennsylvania 19106 OfHERS Mr. Jacque Durr Resident Reactor Inspector U.S. Nuclear Regulatory Commission Post Office Box 47 i
Sanatoga, Pennsylvania 194C4
ENCLOSURE 2 DISTRIBUTION LIST ENVIRONMENTAL REPORT AND SUPPLEMENTS LIMERICK GENERATING STATION ADVISORY COHNCIL ON HISTORIC PRESERVATION ENVIRONMENTAL PROTECTION AGENCY Mr. Pe ter 11. Smith (1)
Advir;ory Council on llistoric Preservation Director (1) 1522 K Street, N.
W.,
Suite 536 Criteria and Standards Division Washington, D.
C.
20005 Office of Radiation Programs (ANR-460)
U.
S.
Environmental Protection Agency Mr. Ed Weintraub, SilPO (1)
Washington, D.
C.
20460 Pennsylvania IIistorical and Museum Commission Federal Activities Branch (2)
P.
O.
Box 1026 U. S. Environmental Protection Agency lia rrisburg, Pennsylvania.17120 Region III Office Curtis Bujlding 6th & Waluut Streets Philadelphia, Pennsylvania 19106 ARMY ENGINEER DISTRICT U.S. Army Engineer Division, (1)
North Atlantic HOUSING AND URBAN DEVELOPMENT 90 Church Stract New York, New York 10007 Mr. Richar el II. Broun, Director (2)
Of fice of J'.nvironmental Quality U.S.
Army Engineer District, (1)
U.S. Department of Ilousing and Philadelphia Urban Deve-opment U.S.
Custom liouse Room 7276, llUD Building 2nd & Chestnut Streets 451 Seventh Street, S.
W.
Philadelphia, Pennsylvania 19106 Washington, D.
C.
20410 COMMERCE IIUD REGION Mr. Thomas C. Maloney (2)
Mr. Bruce Barrett (6)
Regional Administrator U.S. Department of Commerce Curtis Building Room 3425, Commerce Building 6th & Walnut Streets Washington, D. C.
20230 Philadelphia, Pennsylvania 19106 Mr. Robert Ochinero, Director (1)
National Oceanographic Data Center INTERIOR Mr. Bruce Blanchard, Director (18) llEALTil AND llUMAN SERVICES Office of Environmental Project Review U.S. Department of the Interior Mr. Charles Custard (2)
Room 256 U.S D partment of Ilealth and lluman C Streets, N.
W.
Washington, D. C.
20240 Room 537F,_llumphrey Building 200 Independence Avenue, S.
W.
Washington, D. C.
20201
. RIVER BASIN COMMISSION STATE OFFICIALS lionorable Frederick J.
Krumholtz (1)
- overnor's Of fice of the Budget (1)
Chairman, Ohio River Basin Commission
\\TTN:
Coordinator, Pennsylvania 36 East Fourth Street, Suite 208-220 State. Clearinghouse Cincinnati, Ohio 45202 P.O. Box 1323 Harrisburg, Pennsylvania 17102 Mr. David Robinson, Vice Chairman (1)
Ohio River Basin Commission Department of Environmental Resources (l)
Director, Office of Radiological Department of Natural Resources Attn:
State Office Building No. 3 Health 1800 Washington Street East P.
O.
Box 2063 Charleston, West Virginia 25305 Harrisburg, Pennsylvania 17105 OFFICIALS OF ADJOINING STATES TRANSPORTATION Director, Technical Development Programs Mr. Joseph Canny (1)
State of New York Energy Office (1)
Office of the Assistant Secretary Agency Building 2 for Policy and International Affairs Empire State Plaza U.S. Department of Transportation Albany, New York 12223 400 7th Street, S.W.,
Room 9422 Washington, D. C.
20590 Richard B. McGlynn, Comnissioner (1)
Department of Public Utilities, Capt. Wm.
R.
Riedel (1)
State of New Jersey Water Resources Coordinator 101 Commerce Street W/S 73 U.S.C.G.,
Room 1112 Newark, New Jersey 07102 U.S. Department of Transportation Director, Department of State Planning 2100 Second Street, S. W.
Washington, D.
C.
20590 301 West Preston Street (1)
Baltimore, Maryland 21201 Mr. Lee Santman, Director (1)
Attn:
Mr. Joe Nalevanko LOCAL OFFICIAL (S)
Materials Transportation Bureau (1) 2100 Second Street, S.
W.
Chairman Washington, D. C.
20590 Board of Supervisors of Limerick Township 452 Limerick Center Road Linfield, Pennsylvania 19468 DOT REGIONAL OFFICE Mr. Robert Brown, Jr.
(1)
DOT Secretarial Representative CLEARINGHOUSES U.
S. Department of Transportation Pennsylvania State Clearinghouse (10 Suite 1000 Governor's Budget Office 434 Walnut Street Philadelphia, Pennsylvania 19106 Intergovernmental Relations Division P.O. Box 1323 Harrisburg, Pennsylvania 17120 ENERGY Delaware Valley Regional Planning D.
Jack M. lleinemann (1)
Commission (1)
Federal Energy Regulatory Commission Penn Towers Building, Third Floor 1819 John F.
Kennedy Boulevard Room 3347 825 North Capitol Street, N.
E.
Philadelphia, Pennsylvania 19103 Washington, D. C.
20460
g
.. OTilERS Librarian (1)
Thermal Reactors Safety Group Brookhaven National Laboratory Building 130 Upton, Long Island, New York 11973 Mr.iFred Vaslow (1)
Energy and Environmental Systems Division Building 12B Argonne National Laboratory 9700 South Cass Avenue Argonne, Illino,is 60439 Ms. Liz Hannon (1)
Atomic Industrial Forum 1016 16th Street, N.
W.
Suite 850 Washington, D.
C.
20036 b1r..lacque Durr Resident Reactor Inspector ll. S. Nuclear Regulatory Commission l'o s t Office Box 7 Sanataga, Pennsylvania 19464 del. AWARE RIVER BASIN C0bih11SSION bir. Gerald bl. Ilansler lixecutive Director Delaware River Basin Commission l'o s t Office Box 7360 West Trenton, New Jersey 08628
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REQUEST F'OR ADDITIC:;Ax :::TOF.:'?.IIO:'
FOR FSAR AND Fi<A 100.1 (I)
The plan for guard training and qualification is missing and must i (13.'i) br. provided.
Clarify (carefully cross reference) the relationship of the 100.2 (1.1,9.5, various parts of your submittal for operating licenses to the 13.3, 13.6, 15.11,E7.1)
The introductions to the FSAR and ER0L should FSAR, and ER0L.
tie the various pieces together.
The Fire Protection Evaluation Report does not indicate whether it is all or partially in Section 9.5 of the FSAR.
Likewise the Probabilistic Risk Apalysis does not indicate whether it is all or partially a part of the FSAR or ER0L.
Per the requirements of Regulatory Guide 1.70, address your extent 220.1 (3.8.4) &
(3.8.5) of compliance with ACI-349.
Per Regulatory Guide 1.70, provide seismic design criteria for the 230.1 (2.4.1.2.2)
Maiden Creek and Ontelaunee dams (Blue Marsh is provided in Section 2.4.4).
1 l
Per Regulator.' Guide 1.70, provide a table of shear wave velocities 231.1 (2.5.4.4.2) obtained from surveying.
TIT iix.x question number for FSAR or PRA
(
)
240.1 (12.2.1.8.1)
The review of Section 12.2.1.5.1 cannot be completed unti' af ter the shielding design source terms for Tables,12.2-79 through 12.2-82 are available.
Provide this information or a schedule for submittal of this information.
240.2 Indicate whether the guidance provided by Regulatory Guide 8.8 (12.3.2) has been followed.
240.3 Indicate whether the guidance provided by Regulatory Guide 1.21 (12.3.4.1.1) and Af1SI til3.1-1969 will be followed.
240.4 Indicate whether the guidance provided by Regulatory Guide 8.10 (12.5.1) will be followed.
240.5 Indicate whether the guidance provided by Regulatory Guides 8.8, (12.5.2) 8.12, 8.15, and 1.97 will be followed.
240.6 Provide the procurement schedule for health physics and chemistry (12.5.2.2) instrumentation.
240.7 Indicate whether the guidance provided by Regulatory Guides 8.2, (12.5.3) 8.7, 8.8, 8.9, 8.10, 8.13,1.8,1.16,1.33, and 1.39 will be followed.
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N1.1 Per Regulatory Guide 1.70, measures f or monitonng of foundation (2.5.4.5) rebound and heave are to be discussed.
Per Regulatory Guide 1.70, the actual data and analysis for assessing 241.2 (2.5.4.5.5) static stability are to be provided.
241.4 Per Regulatory Guide 1.70, the verification program designated to (2.5.4.12) permit a thorough evaluation of the effectiveness of foundation improvement measures is to be discussed.
Per the requirements of Regulatory Guide 1.70, provide or reference 251.1 (5.3.2.1) a discussion of your compliance with Regulatory Guide 1.99.
Specify or reference the material chemical analysis of the disc and 2 51.2
( 10. 2. 3.1 )
rotor forgings.
List or reference the mechanical properties of the disc material.
251.3
( 10. 2. 3.1 )
Specify the values for the FATT and minimum operating temperatures.
251.4 (10.2.3.2) 251.5 Provide or reference values for the stress-rupture properties of the (10.2.2.3.3) high pressure rotor material and describe the methods of obtaining these properties.
252.1 Per the requirements of Regulatory Guide 1./0, provide or reference (5.2.3.3) a discussion of your compliance with Regulatory r."ide 1.43.
e-260.1 As per Regulatory Guide 1.70, provide resumes of individuals whose (13.1.1) job position corresponds most closely to that identified as " engineer in charge."
~260.2 As per Regulatory Guide 1.70, explain the delegation of authority (13.1.2.19) to operating and shift supervisors regarding the issuance of standing or special orders.
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Per Regulatory Guide 1.70, provide descriptions of any hazardous 310.1 (2.2.2.2) materials and explosives transported on highways and railroads.
Further, provide statistical data on the amounts involved, fre-quency of shipments, and the maximum quantity likely to be trans-ported at any given time.
Per Regulatory Guide 1.70, provide information on the flying 310.2 (2.2.2.5) pattern associated with each airport and statistics on aircraft accidents for all airports within five miles of the nu.
'r plant.
Per Regulatory Guide 1.70, consideration of flamable vapor is to be 310.3 (2.2.3.1.2) made under " worst case" meteorological conditions.
Per Regulatory Guide 1.70, verify that the plan,t property lines 311.1 (2.lcl.2) and the site boundary lines are identical.
If not, label the property lines in the FSAR figures (e.g., Figure 2.1-3).
Expand Tahie 2.2-2 to include the type of isolation valves and 311.2 (2.2.2.3) specity wnetner each pipeline is used for gas s:crage at higher than nonnai pressure.
Per the requirements of Regulatory Guide 1.70, discuss the relief
. 9.1 (5.2.2) protection provided to the emergency and auxiliary systems connected to the reactor coolant system.
Provide or reference a discussion showing your compliance with the 420.1 (3.11.2.1.1) requirements of NUREG-0588.
Per the requirements of Regulatory Guide 1.70, provide or reference 430.1 (8.3.1.1) a discussion of on-site AC power systems that are shared between Units 1 and 2.
Indicate or reference performance requirements under normal, 430.2 (10.2.1) upset, emergency and faulted conditions.
430.3 Identify the design codes which are to be applied.
(10.2.1)
Indicate the length of time the condenser may operate with degraded 430.4 (10.4.1) conditions without affecting condensate /feedwater quality for safe operation.
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Per the requirements of Regulatory Guide 1.70 provide or reference 440.1 (5.4.6.1) a discussion of your compliance with General Design Criteria 34, 55, 56 and 57.
FSAR Section 12.2.1 states "The guidance provided in ANSI f237.:n P.U. 2
( 17. 2.1,)
not followed for Limerick" yet Section 11.1 states that it t;n.
Which statement is correct?
Per Regulatory Guide 1.70, provide a calculation of the maximum 450.1 (2.3.5) annual average X/Q at or Devond the site boundary utilizing approximate meteorological data for each ventiing location.
Per the requirements of Regulatory Guide 1.70, provide or 450.2 (3.5.1.5) reference a discussion of the missiles generated by the following events near the site:
1.
Truck explosions 2.
Shi9 or barge explosions
=
3.
Industrial explosions 4.
Pipeline explosions 5.
Military facilities 450.3 Per the requirements of Regulatory Guide 1.70, provide or reference (3.5.1.6) a discussion of the following aircraft hazard analyses.
1.
Airports with projected operations greater than 500 d2 movements per year located within 10 miles of the site and greater than 1,000 d2 outs'de 10 miles, where d is the distance in miles from the site.
2.
Military installations or any airspace usage that might present a hazard to the si te.
3.
An analysis of the probability c/ an aircraft accident with consequences worse than those of the design basis accident.
i
4.
lne rat.iona'se used fur-Use oist.: ait selectcd as design barit impact events.
The whole aircraft or parts thereof should be characterized in 5.
terms of dimensions, mass (including variations along the length of the aircraft), energy, velocity, trajectory and energy density, along with the resultant loading curves on structures.
As per Rsgulatory Guide 1.70, provide or reference the following 450.4 (15.7.4) information:
1.
Maximum fuel rod pressurization.
2.
Minimum water depth between top of fuel rods and fuel pool surface.
3.
Peak linear power density for the highest power assembly,
discharged.
4.
Maximum centerline operating fuel temperature for the fuel assembly in 3.
451.1 Indicate whether any data reflecting the monthly and annual (2.3.2.1) expected values and extremes for the duration of fog are a t tai ne'.
from local Weather Service data, and whether or not such measurements will be made in the future at the Limerick si te.
per Regulatory Guide 1.70, provide joint frequency distribution 451.2 (2.3.3.2) of wind speed and direction by atmospheric stability class accompanied by an hour-by-hour listing of hourly-averaged parameters on magnetic tape.
_p_
4bl.1 Fer the requirements of Regulato v Guide 1.10 viloslate the
( 3. 5.1. d. )
energy of tornado-generated missiles.
460.1 Provide a summary discussion or reference the anticipated operating
)
(10.2.4) concentration of radioactive contaminants in the system and the attendant radiation levels associated with the turbine components.
l 460.2 for those locations subject to ro : tine sampling, provide expected (11. 5. 2 )
flow, composition and concentration.
t i
460.3 Provide a discussion on the provisions for radiological monitoring l
(11.5.2.8) instrument calibration, maintenance, inspectior., decontamination, and replacement.
480.1 Per the requirements of Regulatory Guide 1.70, provide or reference l
(6.2.1.3) a discussion of core reflood model, descriptiori of long term cooling l
l model and a single failure analysis.
610.1 As per Regulatory Guide 1.70, identify by position the personnel (13. 2.1.1 )
to be trained in the plant staff training program.
610.2 As per Regulatory Guide 1.70, provide a diagram of the control (13.5.1.3) area that indicates the area designated "at the controls."
720.1 Property damage consequences must be added (3.0 PRA)
-s-720.2 Sensitivity studies for latent cancer ano property damage arc (3.0 PP,A) needed to allow comparison with WASH-1400 results based on design and site <tittarences only.
720.3 Failure probabilities need to be added to fault trees to permit (PRA Fault Trees) identification of major contributors to system unavailabilities.
810.1 As per Regulatory Guide 1.70, provide curves for thyroid doses (13.3) of 5, 25, 150, and 300 REM in Appendi: B.
810.2 Review of Section 13.3 Appendix A cannot be completed until after (13.3) the information identified as "later" in Exhibits A-1 through A-5 is submitted.
Either provide this information or a schedule:for submittal of this information.
810.3 The review of Section 13.3 cannot be completed until after Appendix (13.3)
G is available.
Provide this information or a schedule for submittal of this information.
ENCLOSURE 4 REQtlFST FOR ADDITIONAL INFORMATION FOR ER0L o
Identify the anticipated date of operation of Maiden Creek Dam.
E240.1 (2.4.1)
Identify the period of record used to develop the flood frequency-E240.2 (2.4.2) curve (Figure 2.4-3).
The period of record considered was apparently prior to the date indicated in Reference 2.4-5 (1968).
Re-estimate the curve using the period of record through 1980 so that the effects of Tropical Stonn Agnes (June 1972) and other events since may be included.
E240.3 Table 2.4-7 and Figure 2.4-5 apparently have been based on records (2.4.2) through 1967.
We understand other incidents of low flow have occurred which may alter estimates of the low flow frequency characteristics of strehms in the site region.
Accordingly, discuss the low flow characteristics of the Schuylkill River, Perkiomen Creek, and the Delaware River at Trenton through 1980.
240.4 The last paragraph of Section 2.4.2.2 does not indicate whether flow (2.4.2) augmentation will be achieved by any storage to be provided by Philadelphia Electric Company as a result of requirements imposed by the Delaware River Basin Commission.
Indicate whether such augmentation will occur, when it is likely to occur, and the amount and reliability of such augmentation.
If the Point Pleasent Diversion Plan is the source of that augmentation the appropriate
.a Indicate the date by which cither of the procedures listed above will provide Philadelphia Electric Company the authority to deter.;.ine all activities within the exclusion area as required by 10 CFR Part 100.
Indicate whether estimates of water levels are likely to change during E240.5 (2.4.3) the course of plant operation due to erosion and sedimentation, and discuss the basis for your evaluation.
The last paragraph of Section 2.4.3 indicates that flow-frequency E240.6 (2.4.3) estimates have been based on pre-1968 data.
Revise the estimates to reflect the flow history through 1980.
The bed slope for Possum llollow Run appears to be incorrect and E240.7 (2.4.4) should be checked.
Tables 2.4-10 and 2.4-11 indicate downstream water users apparently E240.8 (2.4.5) identified at the time the ER for the CP was written.
Provide any other anticipated users or changing user requirements that have been identified for the future.
240.9 (a) The Delaware River Basin Commission permit for water use was E
(2.4.6) the subject of considerable discussion during the course of the Construction Permit review.
The initial decision of the Atomic Safety and Licensing Board indicated that a separate DRBC Decision was to be made by January 1,1977 on whether or not background information should be referenced and sum :arized such as:
the DRBC FEIS of February 1973, the DRBC Final Environmental Assessment of August 1980, the DRBC Proceedings on Docket No. D 52CP of February 18, 1981, the DRBC Proceedings on Docket No. D 7CP(8) of February 18, 1981, and the Army actions on NAPOP-H-0534-3 and NAP 0P-R-0813-13.
E290.1 Endangered Species (3.9.2 and 5.5)
Are there any proposed or listed Threatened or Engangered Plant Species potentially occurring along the proposed Limerick trans-mission line cooridors?
E290.2 Provide a description of the grounding systems which will be_used (3.9.3 and 5.5) to reduce induced voltages and currents in c;-%cting objects, such as metal fences, in the vicinity of the right-of-way.
It is indicated on page 2.1.-2 of the environmental report that E311.1 (2.1.1.2) there are sections of land within the exclusion area that are not 1
presently owned by Philadelphia Electric Compacy but are controlled by the Commonwealth of Pennsylvania, and that they will be acquired or an agreement will be executed with the Comonwealth so that Philadelphia Electric Company can restrict access to these properties, if necessary.
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- .c=pensation storage would be required.
Indicate what the status of that process has been.
(See Question E240.4 above).
l (b) As part of the same issue, considerable discussion occurred about the consequences of plant operation if Tocks Island l
Dam was not constructed and compensating storage was not provided..The data used to project the periods of non-full power operation did not include information for the middle I
and late 1970s.
Identify the likelihood and duration of plant shutdown assuming that the present flow augmentation planning process is carried out.
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E240.10 Identify any effects on runoff that have occurred due to plant (4.5.1) construction.
Include an evaluation of the erosion that has occurred on drainage courses upsteam of construction areas, and the impact of erosion and/or deposition on downstream areas.
E240.11 In Section 5.1 two additienal effects should be icentified.
- First, (5.1) the effects of plant water use on other users should be identified (and possibly cross references to other sections of the ER).
Secondly erosion and deposition effects of water intake and discharge should be considered.
E240.12 Identify Department of Environmental Resources and Delaware River Basin (5.1.1)
Commission standards for receiving waters that may differ.
Indicate which standards you intend to comply with.
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e
?40.13 Identity the range of initial blowdown dilution areas anticipatc1 I
(5.1.2) for the corresponding senage of Schuylkill River flows that are likt:1y to occur during plant operation.
Describe the deposition and erosion in front of the intake structure anticipated during the life of the plant.
[240.15 Average monthly blowdown temperature alone do not indicate the range (5.1.3) of temperature likely to occur during plant operation.
Provide your estimatt of the extreme temoeratures likely to occur during operation and indicate whether such temperatures are likely to cause impacts such as being a constraint on plant operation.
E Indicate the likelihood of the intake structure on Perkiomen Creek 240.16 (5.1.3) ibeing inoperable due to flooding or erosion.
Provide the basis for your analysis.
E Indicate the period of record v.ad to estimate the percentage of, 240.17 (5.1.3) diverted flow in Perkiomen Creek described in Section 5.1.3.2.2, and, if necessary, update for data collected through 1980.
E240.18 Indicate whether depositica in front of the intake structure on (5.1.3)
Perkiomen Creek is likely to cause plant shutdown.
240.19 Estimate the increased flood risk to property along the east branch E
(5.1.3) of Perkiomen Creek due to diversion from the Delaware River; that is, provide an estimate of the increased likelihood of flooding due to high creek flows from diversions coincident with heavy precioitation.
C (You may cross reference your response to Questions 240.22 and 240.23).
E240.20 Were any streamflow and water level measurements made by Philadelphia (6.1.1)
Electric Company on either the Schuylkill River or Perkiomen Creek?
If so, describe their nature and data collected.
E240.21 Calculate the radiological consequences of a liquid pathway release (7.1) from a postulated core melt accident.
The analysis should assume, unless otherwise justified, that there was a penetration of the reactor basemat by the molten core mass, and that a substantial portion of radioactively contaminated suppression pool water was released to the ground.
Doses should be compared to those calculated in the Liquid Pathway Generic Study (NUREG-0440, 1978).
Provide a summary of your' analysis procedures and the values of parameters used (such as permeabilities, gradients, populations affected, water use).
It is suggested that meetings with the staff of the Hydrologic Engineering Section be arranged so that we may share with you the body of information necessary to perform this analysis.
E240.22 Descriptions of floodplains, as required by Executive Order 11988, (2.4.2)
Floodplain Management, have not been provided.. The definition used in the Executive Order is:
Floodplain:
The lowland and relatively flat areas adjoining inland and coastal waters including floodprone areas of offshore islands, including at a minimum that area subject to a one percent or greater chance of flooding in any given year.
7.
Provice aestrmuons of t.he floudpic. ins adjv i en e,,9 U.c 2,ujltil:
a1 River. Feniomen Creek. East Branch Perkiomen Crcck, and the Delaware River adjacent to the site, plant facilities and reaches used for carrying pumped diversion flow.
On a suitable scale map (s) i provide delineat"ons of those areas that will be flooded during the one percent (100 year) flood both before and after plant construction or operation.
b)
Provide details of the methods used to determine the floodplains in response to a. above.
Include your assumptions of and basis for the pertinent parameters used in the computation of the flood fl_As and water elevations.
If studies approved by the Federal Insurance Administration (FIA) are available for the site and other affected areas, the details of the analysis used in the reports netJ not be supplied.
You can instead provide the reports from which you obtained the floo'dplain information.
c)
Identify, locate on a map and describe all plant structures and topographic alterations in the floodplains.
Indicate the start and completion dates of all such items.
E 240.23 a)
Discuss the hydrologic effects of all items identified in response to (5.6)
Discuss the potential for altered flood flows and questions 240.22c.
levels, offsite.
Discuss the effects on offsitc, areas of debris generated from the site during flood events.
b)
Provide the details of your analysis used in response to a. above.
The level of detail is similar to that identified in item 240.22b.
n.
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'f' i
b E450.I in accoraance witn HKL's interim Policy (45FR40luli revise
-(7.1.1)
Section 7.1.1 to incinae a urobabilistic evaluation of imnacts of accidents including those formerly called class 9 accidents.
E451.1 Table 2.3.2-86 present: offsite terrain elevation.
In order to (2.3.2.2) determine the effect of terrain on an effluent, onsite evevations, by direction, using the same distance intervals as in Table 2.3.2-86 are needed.
E4 51.2 As specified in Regulatory Guide 4.2, Re Mion 2, the following (2.3.2.2) maps are needed:
(a) a map showing detailea topographic features (as modified by the station) on a large scale within a five-mile radius of the station and, (b) a smaller scale map showing topo-l grap'hy within a 50-mile radius of the station.
E4 51.3 A separate report, referred to in the ER as "Micrometeorological (2.3.2)
Data and Analysis for the Limerick Generating Station Environmental Report - Operating.jlicense Stage and Final Safety Analytis Report Submittal s," has not been submitted to the NRC.
Since this report appears to have essential information which will be used in DES preparation, we request the applicant to submit two copies of it.
E451.4 No data are presented in the ER to permit an independent assessment (5.1.4.2) of the environmental impact of the cooling tow plume as specified in Regulatory Guide 4.2, Revision 2, Section 2.3.
471.1 The agricultural survey should be extended from 5 miles to 50 miles
'(2.1.3.6 and 5.2.4.1)
(not river miles).
Same comment both page 2.1-11 and page 5.2-14.
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F i471.>-
Although PEC cl' alms to De usino I.lus equdtioris orid dssuinpliuns, (5;2) itf appears they have. modified crit.isoi uordiiieters such as. dose co'nversion factors.
While they are free to do so, NRC will perform an independent assessment of population dose to determine compliance with 10 CFR part 50, Appendix I.
E471.3 Table I.2-51 "X/Q depleted"'should include both radioactive' decay (5.2.2.1) and de' position occuring during atmospheric transport.
E471.4 Table 6.1-45:
1 year and 6 months prior to' fuel load: While six
-(6.1.5.2) radiciodine air samples per week is more than adequate, the samples should include 3 offsite areas expected to exhibit the highest annual average D/Q during. operation.
Direct Radiation Measurements:
There should be 2 rings of 16 each (32) plus 8 areas of special interest such as schools, nearby residences, and population centers, for a total of 40.
Thirty-five stations may be enough, but the smaller number will require a.
justification.
Surface Water Samples and Drinking Water Samples should be collected by continuous. sampling, not composited from grab samples.
It is not clear from this table (or Table 6.1-47) whether PEC proposes to do that.
L-Ground Water' Samples:
should be collected quarterly if the wells are.
llikely to be affected, 3
(4, s E471.5 Table 6.1-46: MDL I-131 in water is missing.
Is there a reason (6.1.5.2) for this?
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ENCLO56RF f
. SUPPLEMENTAL REQUEST FOR
~
ADDITIONAL INFORMATION
'In addition to the TMI-related. requirements discussed in Section 1.9 of your FSAR, there are other areas in which requirements have been added or modified, or in which staff concerns have been raised in the review of other Tending OL applications. A number of these areas are discussed below. In-arder to expedite the review process for your application, we request, that you
- e. valuate these areas and, where appropriate, upgrade your FSAR to include h w these. requirements are met or how these staff concerns are resolved for your plant. We further request that you submit these changes to the FSAR,
-in amendment form, within two months from the docketing date.
~
(1) Environmental Qualif ~ cation of Safety Related Electrical Equipment-Commission Memorandum and Order of May 23, 1980 defines the current staff require'ments for qualification of this equipment. Additional guidance on this matter was provided in a subsequent NRR Order.
-dated November 26,1980 (concerning record requirements), Supplements 2 and 3, dated September 30, 1980 and October 24, 1980, respectively, to IE Bulletin No. 79-018, and a generic letter to all holders
- of cps and Ols, dated October 1,1980.
(2) Seismic-Q'ualification - A staff request for additional information in this review area has been sent to a number of pending OL applicants. A copy of that request is provided as Enclosure 6, (3)
Emergency Preparedness - Guidance on the preparation of emergency plans is presento in NUREG-0654 (FEMA-REP-1), " Criteria for Preparation and d'.11uation of Radiological Emergency Response Plans
-and Preparedness in Support of Nuclear Power Plants".
The require-ments for the emergency response facilities are included in NUREG-0696, " Functional Criteria for Emergency Response Facilities."
Further guidance on emergency preparedness is provided in the revised Appendix E to 10 CFR Part 50.
-(4)
Fire Protection - The current requirements for the fire protection programs are defined in the new Appendix R to 10 CFR Part 50.
As further guidance, a cooy of a recent staff request for additional
~information on Catawba is provided as Enclosure 7 (5) Masonry Walls - The staff concerns regarding this issue and a request for information to assist in its resolution were provided in a generic letter, dated April 21, 1980 to all CP and OL applicants.
(6)
Fracture Prevention of Cmteinment Pressure Boundary (GDC 51) -
. provides ciarification on how the staff determines compliance with GDC 51.
(7)
Initial Test Program Descriptions (Chapter 14) - Staff review of.
near term OL' applications has revealed a number of concerns which are. coninon to pending applicat%1s. The nature of these concerns are typically expressed ir, t'e astions the staff has raised in its.
review of.the Summer and t*
nofre 2 & 3 appifcations.
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(8)
Special Low Power Test Program (Task Action Plan Item I.G.1) -
The staff has recently established guidance on this matter for transmittal to all pending and prospective OL applicants. A copy of that guidance is provided as Enclosure 9
_(9)
Preservice and Inservice Inspections - Staff guidance in this review area has been sent to a number of pending OL applicants. A copy of that guidance is provided as Enclosure 10.
(10) Procedures and Training for Station Blackout - In response to a recommendation in a recent decision by the Atomic Safety and Licensing Appeal Board (ALAB-603), to ensure that station blackout events can be accomodated, the staff is requesting licensees and OL Applicants to implement emergency procedures and a training program for station blackout events. A copy of that request is provided as Enclosure 11.
(11) Preservice Inspection and Testing of Snubbers - The staff has recently established requirements to ensure snubber operability which have been transmitted to pending OL apolicants.
A copy of those requirements is p.rovided as Enclosure 12.
(12) Effects of Contairment Coattngs and Sump Debris on ECCS and Containment Spray Operation - A copy of the NRC staff concerns on this issue, including a request for additional information which has been sent to a number of OL applicants, is provided as Enclosure 13.
(13) Instrumentation for Detection of Inadequate Core Cooling (:TMI Action Item II.F.2 in NUREG-0737) - Discussion of this item should address how core thermocouple readouts are provided in the control room including location and rate of printout-(see Part (4) of attach-ment 1 to Item II.F.2).
(14) Safety - Related Structures Systems and Components (Q-list)
Controlled by the QA Program - Staff requests for additi, al information regarding this issue have been sent to a number of OL applicants. A recent request regarding the Diablo Canyon is pro-vided as Enclosure 14.
(15) Instrumentation and Control Systems Concerns - Operating reactors and some near term OL applicants have previously received I&E Bulletin 79 - ? ~'.
The concerns which prompted the Bulletin apply to all OL app'icants.
If you have not alread'; responded to the concerns of Bul etin 79-27, you are now requested to do so, but with two exceptions.
Fir.., tne '.ime for response wil' be determined on a case by case basis so that the 90 day i.mit in Itru 4 is not applicable.
Secondly, your reply should be made in the same way as other resoonses to requests for additional infonnation by NRR.
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ENCLOSURE 6 Equipment Qualification Branch Seismic Qua~lification Revies Team
~
Request for Additional Information
- 1. 'In accordance with the* requirements of.GDC 2 and 4 all safety-related.
cquipment is' required to be designed to. withstand the effects of earth-quakes, and dynamic loads from normal operation, maintenance, testing GDC 2 further require's.that such and postulated accident conditions.
equipment be designed to withstand appropriate combinations of the effects of normal and accident conditions with the effects of earth-quake loads, s
The-criteria to be used by the staff to determine the acceptability of your equipment qualification program for seismic and dynamic loads are IEEE Std. 344-1975 as supplemented by 9,egulatory Guides 1.100 and State the 1.92, and Standard Review Plan Sections 3.9.2 and 3.10.
extent to which the equipment in your plant meets these requirements
)
and the above requirements to combine seismic and dynamic loads.
Fo r,
equipment that does not meet these requirements provide justification for the use of other criteria.
related systems together with a list of Provide a list of all safety"and support structures associated with 2.
all sa fety-related equioment' The equipment lists should indicate whether the equip-each system.
ment is NSSS supnlied nr RCD sun,nl i ed., These lists should fnclude all safety-related mechanical ccmponents, electrical, instrumentetion, and control equipment, including valve actuators and other, appurtenances of active pumps and valves, 3, ' For each safety-rdlated equipment item, the following information should be provided:
(1)
Method of qualification used:
Analysis or test (indicate the company that prepared the a) report, the reference report number and date of thrt pubit-cation).
If by test, describe whether it was a single or multi-b) frequency test and whether input was single axis or multt-
- axis, c)
If by analysis, describe whether static or dynamic, single or multiple-axis analysis was used.
d)
Provide natural-frequency (or frequencies) of equipment.
Indicate whether the equipment'has met the qualification require $ent (2)
~
(3)
Indicate whether the equipment is required for:
a). hot stand-by t.
b)* cold shutdown e
e c) both 7
d)' neither
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.4 (4) Location of. equipnent, f.e., building, el evation.
(5) Availability for inspection (Is the equipment already installed at the plant site?)
(6)
A' compilation of the required response spectra (or time history) and corresponding damping-for each seismic and dynamic load specified for the equipment together with all other loads considered in the qualification and the method of cofabining all loads.
Identify all equipment that may be effected by vibration fatigue cycle -
4 effects and describe the methods and criteria used to qualify this equipment for such leading conditions Describe tne results of any in plant tests, such as in situ impedance,
5.
tests, and any plans for operational tests which will be used to confirm the qualification of any item of equipment.
t To confirm the extent to which the safety-related equipment meets the
'6.
requirements of General Desig"n Criterion 2 and 4, the Seismic Qualiff-For selected cation Review Team (SQRT) will conduct a plant s.ite review.
equipment, SQRT will review the combined required response spectra (RRS).
or the combined dynamic response, examine the equipment configuration and mounting, and then determine whether the test or analysis which has been conducted demonstrates compliance with the RRS if the equipment was qualified by test, or the acceptable analytical criteria if qualified by analysis.
The staff requires that a " Qualification Summary of Equipment" as shown on the attached pages be prepared for each selected piece of equipment and The submitted to the staff two weeks prior to the plant, site visit.
applicant should make available at the plant site for SQRT review all the pertinent documents and recorts of the qualification for the selected
~
After the visit,'the applicant should be prepared to submit equipment.
certain selected documents and reports for further staff review.
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Qualification Summary of Equipment Tyoe:
I.
Plant Name:
PWR 1._
Utility:
BWR 2.
NSSS:
3.
A/E:
l:
II.
Comoonent Name 1.
Scope:
[ ] NSSS
[ 3,,OP B
Quantity:
2.
Model Number:
3.
Vendor:
If the component is a cabinet or panel, name and model Nr. of tte
.4.
devices included:
5.
Physical Description a.
Appearance
~
b.
Dimensions c.
Weight 6.
Location:
Building:
Elevation:
, Size
')
7.
Field Mounting Conditibns [ ] Bolt (No.~
)
[] Weld.(Length
[]
System in which located:
8.
a.
b.
Functional
Description:
'Is the equipment required for [] Hot Standby [] ColdShutdow c.
[ 3, Both
[] Net $er
+
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Pertinent Reference Design Specifications:
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III. Is Equipment Available for Inspection in the Plant: [] Yes
[] No IV. Equipment Qualification Method:
[ ] Test
- [ ] Analysis
[ ] Comoimation of Test and Analysis Qualification Report *: __..___.......___________-_....____
(No., Title and Date)
< Cocpany that Prepared Report:
Company that Reviewed Report:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
V.
Vibration Input:
1.
Loads considered:
- a. [ ] Seismic only 9
- b. [ ] Hydrodynamic only
- c. [ ] Coc6f nation of (a) and (b) 2.
Method of Combining RRS: [ ] Absolute Sum [ ] SRSS
[]*15UiiF'"sjiecirJ) 3.
Required Response Spectra (attach the graphs):
~~
4.
Dacping Correspcnding to RRS: OBE SSE 5.
Required Acceleration in Each Direction:
["] IP A
[ ] Other(s pect ry]~~*
OBE S/S =
F/B =
V=
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5 5g. S, g,.....-- -. --_
7,g,--._--
6.
Were fatigue effects or other vibration loads considered?
[ ] Yes
[ ] No If yes, describe loads considered and how they were treated in overall qualification program: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _, - - - -
....___.............=___.______ _e.___.==========*******==
m e..
6--..___
...-. MM....
6-_###M N##*****
- NOTE:
If more than one report cocplete items IV thru VII for each report.
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If Qualification by Test. then Complete *:
[ ] random ~
0 1.
[ ] Single Frequency
[ ] Multi-Frequency:
[ ] sine beat
[]
- 2. -[ ]ISingle Axis
[ ] Multi-Axis 3.
No. of Qualification Tests:
4.
Frequency Range:
5.
Natural Frequencies in Each Of rection (Side / Side, Front /Back, Vertical):
S/S =
F/B =
V '=
6.
Method of Determining Natural Frequencies
[ ] Lab Test
[ ] In-Situ Test
[ ] Analysis 7.
TRS enveloping RRS us;ng Multi-Frequency Test [ ] Yes (Attach ~#.5 & RRS grap:
[ ] No 8.
Inpt g-level Test: OBE S/S =_
_ F/B =
Y=
SSE S/S =
F/B =
V=
'T 9.
Laboratory Mounting:
- Size,
_ ) [ ] Weld (Length
- )
[]
1.
[ ] Bolt (No.
10.
Functional operability verified:
[ ] Yes
[ ] No
[ ] Not Applicable 11.
Test Results including modifications made:
- 12. Other test perfortned (such as aging or fra~gility test, including results):
- Note:
If qualification by a con 6tnati)n of test and analysis also complete Item VII.
12/80 T
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VII. If Qualification by Analysis, then complete:
1.
Method of Analysis:
[ ] Static Analysis
[ ] Equivalent Static Analysis
[ ] Dynamic Analysis:
[] Time-History
[ ] Response Spectrum 2.
Natural Frequencies in Each Of rection (Side / Side, Front /Back, Vertical):
S/S =
F/B =
V=
3.
Model Type:
[]30
[ ] 20
[ ] 10
[ ] Finite Element
[ ] Beam
[ ] Closed Form Soluth.
4.
[ ] Cocputer Codes:...............................................
Frequency Range and No. of modes considered:_,_,___,________
[ ] Mand Calculations-5.
Method of Combining Dynamic Responses:
[ ] Absolute Sum [ ] SRSS
[ ] Other:
6.
Oamping: OBE_ _ _ _, SSE_,_, Basis for the damping used:_____
7.
Support Considerations in the model:_______,_,___,_,,j__
8.
Critical Structural Eierents:
Governing Load or Response Seismic Total Stress A.
Identification Location Combination Stress Stress Allowable Maxicum Allowable Deflection B.
Max. Critical to Assure Functional Opera-Deflection,
Location bility s......
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l ENCLOSURE 7 FIRE PROTECTION QUESTIONS ST. LUCIE PLANT, UNIT 2
- In accordance with section 9.5.1 Branch Technical Position ASB 9.5-1, position C.4.a.(1) of NRC Standard Review Plan and section III.G of new Appendix R to 10 CFR Part 50, it is the staff's position that cabling for redundant safe shutdown systems should be separated by walls having a three-hour fire rating or equivalent protection (see sectica III.G.2 of Appendix R). That is, cabling required for or associated with the primary method of shutdown, should be physically separated by the equivalent of...three-hour rated fire crier from cabling required for or associated with the redundant or alternate method of shutdown.
To assure that redundant shutdown cable systems and all other cable systems that are associated with the shutdown cable systems are separated from each other so that both are not subject to damage from a single fire hazard, we require the following information for each system needed to bring the plant to a safe shutdown.
1.
Provide a table tha't lists all equipment including instrtnentation and vital -
support system equihent required to achieve and maintain hot and/or cold
~
shutd:wn. for each equipment listed:
a.
Difrerentiate between equipment required to achieve and c.afntain hot shutdown and equipment required to achieve and maintain cold shutdown, b.
Define each equipment's location by fire area.
c.
Define each equipment's redundant counterpart.
~
- Applicable,to Limerick s
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d.
Identify each equipment's esser.tial cabling (instrumentation,
'* control, and power). For each ca le identified: (1) Describe the cable routing (by fire area) fitm source to te$nination, and n
P' (2) Identify each fire area location where the cables are se;iarated by less than a wall having a three-hour fire rating from cables for-any redundant shutdown system, and
't List any problem areas identified by item 1.d.(2) above that will e.
be corrected in accordance.with Section III.G.3 of /,ppendix R (i.e., alternate or dedicated shutdown capability).
2.
Provide a table that lists Class 1E and f;on-Class 1E cables that are associated with the essential safe shutdown systems ideritified in item 1 a bo ve.
For each cable listed:
(* See note on Page'3).
Define the cables' a;sociation to the safe shutdown system (co.mn a.
pcwer source, cocron raceway, separation less than IEEE Standard-384 guidelines, cables for equipment whose spurious operation will adversely affect shutdown systems, etc.),
b.
Gescribe each associated cable routing (by fire area) frca source to terminat. ton, and Identify each location where the associated cables are separated c.
by less than a.eall having a three-hour fire rating from cables required for or associated with any redundant shutdown systa:5.
~
3.
Provide one o'r the following for each of the circuits identified in item 2.c above:
(a) The results of an analysis that demonstrates that failure caused by open, ground, or hot short of cables will not affect it's-associated shutdown iistem,
- Note *
(b)
Identify each circuit requiring a solution. in accordance with
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section III.G.3 of Appendix R,, or ;;
(c) Identify esch circuit meeti,ng or that will be modified to meet the requirements of section III.G.2 of Appendix R (i.e., three-hour wall, 20 feet of clear space with automatic fire suppression, or one-hour barrier with automatic fire suppression).
~
4.
To assure compliance with GDC 19, we require the following inforcation be '
provided for the control room.
If credit is to be taken for an alternate or dedicated shutd:wn method for other fire areas -(as identified by iten 1.e or 3.b above) in accordance with section III.G'.3 'of new Appendix R to 10 CFR Part 50, the following information vill also be required for each of these plant areas.
A table.that lists all equipment including instrumentation and vital a.
support system equipment that are required by the primary method of achieving and maintaining, hot and/or cold shutdown.
- NOTE Option 3a is considered to be one method of meeting the requirements of Section II.G.3 Appendix R.
If option 3a is selected che information requested in items 2a and 2c above should be provided in general terms and the infor-mation requested by 2b need not be provided.,
a e
4-s b.
A table that Ifsts all equipment th*gluding instrumentation and Yital support system equipment that are required by the alternate, dedicated, or remote method of achieving and c.afntaining hot and/or cold shutdown.
Identify each altarnat[ shutdown equipcent ifsted in iten 4.b' above c.
with essential cables (instrumentation, control, and power) that ~are located in the fire area containing,the prir.ary shutdown' equipment.
Or each etuipment lis ed crovide one of the following:
- (1 )
Detailed electrical schematic crawings that show the essential cables that are duplicated elsewhere and are electrically isola.ted from the subject fire areas. or
's
~
(2) The results of an analysis that demonstrates that failure (open, ground, or hot short) of each cable identified will not affect the capability to achieve and e.aintain hot or
~
~
cold shutdown.
d.
Provide a table that lists Class 1E and Non-Class 1E cables that are associated with the af ternate, dedicated,or rarote method of shutdown.
For each item ifsted, identify each associated cable located in the fire area containing the prir.ary shutdown equipment. For each cable so identified provide the results 'of an analysis that demonstrates that fatture (open.
. ground, or hot short) of the associated cable will not adver:ely affect the alternate, dedicated.or rarote e,ethod of shutdown.
e 4
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5-5.
The residual heat removal syst'e5 is generally a low pressu e system that interfaces with the high pressure pridary coolant system. To preclude a LOCA thmugh this interface, we require compf f ance with the recer.:enda-tions of Branch Technical Position RSB 5-1.
Thus, this interface mst likely consists of two redundani and independent rotor operated valves with diverse interlocks in accordance with Branch Technical Position'ICSB 3.
These two motor operated valves and their 4ssociated cable may be subject to a single fire hazard.
It is our concerti that this single fire could cause, the two valves to open resulting in a fire-initiated LOCA through the subject high-low pressure system interface. To assure that this interface and other high-low pressure interfaces are adequately protected from the effects of a single fire, we require the following information:
a.
Identify each high-low pressure interface that uses redundant electrically controlled devices (such as two seri)s rotor operated valves) to isola ~te or preclude rupture of any primary coolant boundary.
b.
Identify each device's essential cabling (power and control) and describe the cable routing (by fire area) from source to s
termination.
Identify each location where the identified cables are separated c.
by.less than a wall having a three-hour fire rating from, Cables for the redundant device.
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d.
For the areas identified in item Sic ahve (if any), provide the bases and justification ~ as to the* acceptability of the existing design or any prop: sed codifications.
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An
-Fracture-Pr~mation of Contain, ment Pressure Boundary (GDC-51)
~GDC251 requires that under operating, maintenance.. testing and postulated '
accident' conditions, (1) the Ferritic materials of the containment pressure boundary behave 'in a nonbrittle manece and (2) the probability of-rapidly ;
propagating fracture is minimized.
The Ferritic materials of the containment pressure boundary which are assessed by the staff are those of components such as freestanding containment vessel, equipment hatches, personnel airlocks, primary containment drywell head, heads containment penetration sleeves, proccess pipes, end closure caps and.
flued heads and penetrating piping systems downstream of penetration process pipes extending to and including the system isolation valves.
The acceptability of these materials within the context of GDC-51 is determined in accordance with-the fracture toughness criteria identified for Class 2' materials by the Summer 1977 Addenda to ASME Code Section III.
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' EriCLOSURE 9 s.
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SUBJECT:
Tt41-2 FASK ACTION PLAN ITEri 1.G.1 - SPECIAL LOW POWER TESTli;G f?UREG-0694 Tri! 7e1ated Requirements for ?!cw Ope.ra' ting Licenses", Item I.G.1, requires applicants to perform "a special low power testing 'prograr..
approved by t;RC to be conducted at power levels no greater than 5 percent for the purposes of providing meaningful technical information.beyond that obtained in the normal startup tr t program and to provide supp emental training".
To coq 11y with this requirement new PWR applicants have comitted
' j to a series of nat:ral circulation tests.
To date such tests have been performed at the Sequoyah 1, f; orth Anna 2' a.id Sales. 2 facilities.
Based on the success of the programs at these plants, the staff has concluded that augmented natural circulation training should be performed for all future P;.'R operating licenses.
This is to be icplerented by including descriptions of natural circulation tests in your FSAR (Chapter 14 -
Initial Test Procram).
If they are not already included in your FSAR, the natural circulation tests and associated training should be include *d,
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either by modifying existing on adding new test descriptions-in accordance with Regulatory Guide 1.70 (Paragraph 14.2.12).
The tests should fulfill the following' objectives:
Training Each licensed reactor operator (R0 or SR0 who performs RO or SRO duties, respectively) should participate in the initiation, maintenance and recovery from natural circulation' mode.
Operators-should be able to recognize when natdral circulation has stabilized, and should be able to control saturation margi.n, RCS pressure, and heat removal rate without exceeding specified o'perating limits.
Testing The tests should demonstrate the following plant characteristics:
length of time required to stabilize natural circulation, core ficw distribution, ability to esta.blish and r.aintain natural c.rculation with or without onsite and offsite power, the ability to uniformly borate and cool.down to hot shutdown conditions using natural circulation,and subcooling monitor performance.
If these tests have been tierformed at a comparable prototype plant, they need be repeated o. 'y to the extent necessary to accomplish the above training objectives.
Procedura Validation The-tests should make maximum practical use of written plant procedures to' validate the completeness and accuracy of the procedures.
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The natural circulation tests require a source of actual or simulated ~
decay heat. (The tests may be performed during initial startup using nuclear heat to ' simulate decay heat, or may be performed later in the
.init'iale fuel--cycle when actual ' decay heat is adequate to permit meaningful testing.
If.th'e test objectives are not compromised, pump
' heat during forced circulation operation could provide an acceptable
. source of simulated decay heat (e.g., the loss-of-Onsite 'and Offsite A/C Test performed at North Anna 2).
Applicants who perform a natural circulation boron-mixing and cooldown
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. test to demonstrate compliance with Branch Technical Position RSB BTP 5-1 may use that-test.to accomplish some or all of the above training.
and testing objectives.
This guidance is provided for all new PNR OL applicants'. -Regulatory. Guide 1.68 and/or the Standard Review Plan will be revised at a future.date to
' include natural circul'ation teiting and the associated training.
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applicants should submit test dhscr.iptions in accordance with Regulatory.
Guide 1.70' Paragraph 14.2.12 as part of their FSA?. or an amendment thereto.
Detailed. test procedures should be made available for NRC review 60 days prior tcf scheduled test performance (see Regulatory Guide 1.68-Appendix B).
When required by 10 CFR 50.59, a safety analysis must be prepared and distributed in-accordance with the requirements stated therein.
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' Enclosure 10
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-PRESERVIC'EIllSPECTIONPROGRAMREVIEWSFOROPERATII N, ' '
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121.0 '
ImTERIALS Ei!GINEERING BRANCH He require that your inspection program for Class 1, 2 and 3 components be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a, paragraph (g). Accordingly, submit the-following information:
(1). A preservice inspection plan which is consistent with the required
. edition of the ASME Code.
This inspection plan should include any exceptions you propose to the Cote requireme,nts.
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it (2) ' An inservice -inspection plan submitted within six months of the
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anticipatad date for commercial operation.
This preservice inscection plan will be required to supoort the sarety evaluation report finding.regarding your compliance with preservice
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and inservice inspection vequirements. Our determination. of your complia'nce will be based on the edition of Section XI of the ASME Code referenced in your FSAR or later editions of Section XI referenced in the FEDERAL REGISTER that you may elect to apply.
Your response to this item should define the applicable edition (s) and subsections of _Section XI of the ASME Code.
If any of the examination requirements of the particular edition of Section XI you referenced in the FSAR cannot be met, a request for relief must be submitted, ' including complete technical justification to support your request.
Detailed guidelines for the preparation and content of the inspection programs-to be submitted for staff review and for f511ef requests are attached as an Appendix to Section 121.0 of our review questions.
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APPENDIX TO SECTION 121.0 GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUESTS PURSUANT TO 10 CFR 50.55a(9)
A.
Description of the Preservice/ Inservice Inspection Procram and (program should cover the requirements set forth in Section 50.55a(b)
This g) of 10 CFR Part 50; the ASME. Boiler and Pressure Vessel Code,Section XI.
Subsections IAW, IWB, IWC and IWD; and Standard Review Plans 5.2.4 and 6.6.
The guidance provided in this enclosure is intended to illust, rate the type and extent of information that should be provided for NRC review.
It also describes the information necessary for. " request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code.
By utilizing these guidelir.es, applicants can significantly reduce the need for requests. for additional informa-tion from the NRC staff.
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B.
Contents of the Submittal The information listed below should be included in the submittal:
1.
For each facility, include the applicable date for the ASME Code and the appropriate addenda date.
2.
The period and interval for which this prog,r,am is applicable.
3.
Provide the proposed codes and addenda to be used for repairs,
, modifications, additions or alternations to the facility which might be implemented during this inspection period.
d.
Indicate the components and lines that you have exempted under the rules of Section XI of the ASME Code. A reference to the applicable paragraph of the code that grants the exemption is necessary. The inspection requirements for exempted components should be stated (e.g., visual inspection during a pressure test).
i' 5.
Identify the inspection ~and pressure test 'ng requirements of the applicable portion of Section XI that are deemed impractical because of the limitations of design, geometry, or materials of construction of the components.
Provide the information requested in the following section of this appendix for the inspections and pressure tests identified in Item 4 above.
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Request for Relief frem Certain Inscection and Testino Reouirements It has'been the staff's experience that many requests for relief:from testing = requirements submitted by applicants and licensees have not
" been supported by. adequate descriptiv'e and detailed technical infor-mation.
This detailed information is-necessary to:
(1) document the impracticality of the ASME Code requirements within the limita-tions of design, geometry, and r.aterials of construction of components; and-(2) determine whether the use of alternatives will provide an acceptable -level of quality and safety.
Reli'ef requests submitted with a justification such as " impractical,"
" inaccessible," or any other categorical basis, require additional
- information to permit the staff to make an evaluation of that relief request.1The objective of.the guidance p ovided in this section is'to illustrate the extent of-the in#ormation that is required by the NRC-staff-to make a proper evaluation and to adequately document the basis for granting the relief in the staff's Safety Evaluatior The NRC staff believes subsequent requests for additional
- 4 Report.
information and delays in completing the review can be considerably reduced if this information is provided initially in the. applicant's submittal.
For each relief request submitted, the following information should be included:
l.
An identification of the component (s) and/or the examination requirements for which' relief is requested.
2.
The number of items associated with the requested relief.
3.
.The ASME Code class.
An identification of the specific ASME Code requirement that has 4.
been determined-to be impractical.
5.
The information to support -the determination that the requirement is impractical; i.e., state and explain the basis for requesting relief.
6.
An identification of the alternative examinations that are (a) in lieu of the requirements of Section XI; or proposed:
(b) to supplement examinations performed partially in compliance with-the requirements of Section XI.
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A description and justification of any changes expected in the overall icvel of plant safety by performing the proposed alternative examinations in lieu of the examination _ required by Section XI.
I.f it 's not possible to perform alternate examinat' ions, discuss the impact on the overall level of plant quality and safety.
For inservice inspection, provide the following additional information regarding the inspection frequency:
8.
State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination).
9.
State when the proposed alternative examinations will be implemented and performed.
10.
State the time period for which the requested relief is needed.
Technical justification or data must be sumicted to support the relief request. Opinions without substantiation that a change will not affect the quality level ar'e unsatisfactory.
If the relief is reques.ted for inaccessibility, a detailed description or drawing which depicts the inaccessibility must accompany the request. A relief request is not required for tests prescribed in Section XI that do not apply to your facility. A statement of "N/A" (not.
applicable) or "None" will suffice.
D.
Request for Relief for Radiation Considerations Exposures of test personnel to radiation to acfomplish the examina-tions prescribed in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examination must be performed.
A request for relief must be submitted by the licensee in the manner described above for inaccessibility and must be subsequently approved by the NRC staff.
We recognize that some of the radiation considerations will only be known at the time of the test. However, the licensee generally is aware, from experience at operat 'ng facilities, of those areas where relief will be necessary and show'd submit as a minimum, the following information with the request for relief:
1.
The total estimated man-rem exposure involved in the examinatio'n.
2.
The radiation leve.ls at the test area.
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- 3. ; Flushing ~or shieldin'g capabilities which might reduce radiation.-
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- 4. ' A proposal for'aiternate inspection techniques.
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5.
A ' discussion 'of the considerations involved in remote inspections.
6.
Simila~ welds in redundant systems or similar welds in the same:
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. systems which can be inspected.
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The' results of preservice inspection and any inservic'e results.
-'for the welds for which the relief is being requested.
- 8.. A-discussion for the consequences if the weld which was -not examined, did. fail.
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'en ENCLOSURE 11-f * * %g,#o _
UNITED STATES
'e l-E NUCLEAR REGut.ATORY COMMISSION c
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February 25, 1981 TO ALL LICENSEES OF OPERATING NUCLEAR POWER REACTORS AND APPLICANTS FOR
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OPERA 11NG LICfNSES (UCLPT FOR ST. LilCIE UNIT NOS.1 & 2)
SUBJECT:
EMERGENCY PROCEDURES AND TRAINING FOR STATION BLACK 0UT EVENTS (Generic Letter 81-04)
A recent decision by the Atomic Safety and Licensing Appeal Board (ALAB-603) concluded that station blackout (i.e., loss of all offsite and onsite AC power) should be considered a design basis event for St. Lucie Unit No. 2.
An amendment to the Construction Permit for St. Lucie Unit No. 2 was subseogently issued on September 18, 1980. The NRC staff is currently assessing station blackout events on a generic basis (Unresolved Safety Issue A-44). Th; results of this study, which is scheduled to be completed in 1982, will identify the extent to which design provisions should be included to reduce the potential for or consequences of a station blackout event.
However, the Board has recommended that more immediate measures be taken
'to ensure that station blackout events can be accommodated while task A-44 is being conducted.
Although we believe that, qualitatively, there appears.
to be sufficient time available following a station blackout event to restore AC power, we are not sure if licensees have adequately prepared their operators to act during a station blackout event.
Consequently, we request that you review your current plant operations to determine your capability to mitigate a station blackout event and promptly implement, as necessary, emergency procedures and a training program for s tation blackout events. Your review of procedures and training should consider, but not be limited to:
a.
The actions necessary and equipment 'vailable to maintain the reactor coolant inventory and heat removal w.th only DC power availablf, including consideration of the unavailability of auxiliary systems such as ventilation and component cooling.
b.
The estimated time available to restore AC power and its basis.
c.
The actions for restoring offsite AC power in the event of a loss of the grid, d.
The actions for restoring offsite AC power when its loss is due to postulated onsite equipment failures.
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The actions necessary to r'estore emergency onsite AC power. Tne actions required to restart diesel generators should include consideration of loading sequence and the unavailcbility of AC power.
f.
Consideration of the availabilit;y of emergency lighting, and any actions required to provide such lighting, in equipment areas where operator or maintenance actions may be necessary.
g.
Precautions to prevent equipment damage during the return to normai operating conditions following restoration of AC power. For example, the limitations and operating sequence requirements which must be followed to restart the reactor coolant pumps following an extended loss of seal injection water should be considered in the recovery procedures.
.The annual requalification training program should consider the emergency procedures and include simulator exercises involving the postulated loss of all AC power with decay heat removal being accomplished by natural circulation and the. steam-driven auxiliary feedwater system for PWR plants, and by the steam-driven RCIC and/or HPCI and the safety-relief valves in BWR plants.
We conclude that the actions described above should be completed as soon as the,y reasonably can be (i.e., within 6 months).
In addition, so that we may
.detemine whether your license should be amended to incorporate this require-ment, you are requested, pursuant to f50.54'(f), to furnish within niaty (90),
days of receipt of this letter, an assessment of your existing or planned facility ~ 7cedures and training programs with respect to the matters described accve.
Please refer to this letter in your..r,esponse. In the event that completion within 6 months can not be met, please propose a revised date and justification for the delay.
Tnis request for information was approved by GAO under a blanket clearance number RC072 which expires November 30, 1983. Coments on burden and duplication may be directed to the U.S. Gu.eral Accounting Office, Regulatory Reports Review, Room 5136, 441 G Street, NW., Washington, D.C.
20548.
Sincerely.
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Darre G.T EisenhuS 0irec'ter Division oi' Licensing Office of Nuclear Reactor Regulation m
A a
o PRESERVICE INSPECTION Af!D TESTIllG OF S!!UBBERS ENCLOSURt 12 TG ALL APPLICANTS:
r.:
Due to a long history of prob 1 cms dealing with inoperable and incorrectly installed snubbers, and due to, the potential safety significance nf failed '.
v-snubbers in safety related. systems and components, in is requested that N.
maintenance records fcr snubbers be documented as follows pre-service Examination A pre-scrvice examinatiw should be made on all snubbers listed in tables 3.7-4a and 3.7-4b of %.dord Technical Specifications 3/4.7.9 This exami-nation should be made after snubber installation but not more than six months prior to initial system pre-operational testing, and should as a mimimum verify the following:
(1)
There are no visible signs of damage or impaired operability as a result of storage, handling, or installation.
- (2)
The snubber location, orientation, posit 4n setting, and configurati'on (attachments, extensions, etc.) are according to design drawings end specifictions.
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(3)
Snubbers are not seized, frozen or janrc.ed, (4) Adequate swing clearance is provided to allow snubber movement.
(5)
If applicable, fluid is to the recommended level and is not leaking g@$.
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from the snubber system.
(6)
Structural connections such as pins, fasteners and other connecting hardware such as lock nuts, tabs, wire, cotter pins are installed co'rrectly.
i If the period betv.er, the initial pre-service examinaIion and initial system pre-operational test exceeds six :nonths due to unexpected situations, re-examiration of items 1,4, and 5 shi.ll be performed.
Snubbert. which are installed incorrectly or otherwise fail to meet the above requirements must be repaired or replaced and re-examined in.accordance with the above criteria.
Pre-Operaticnal Testing During pre-operational testing, snubber thermal movements for systems whose operating temperature exceeds 250' F should be verified as follows:
During initial system heatup and cooldown, at specified temperature (a) intervals for any system which attains operating temperature, verify the snubber expected thermal movement.
For those systems which do not attain operating temperature, verify (b)
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via observation and/or calculation that the snubber will accommodate the projected thermal movement.
(c)
Verify the snubber swing clearance at specified heatup and cooldown intervals.
Any discrepencies or inconsistencies shall be evaluated for f-\\
cause and corrected prior to proceeding to the next specified interval.
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The'above described operability program for snubbers should be included I'
land. documented by the pre-service-inspection and pre-operational-test N.;.
. programs.-
- The pre-service inspection must be a prerequisite for the pre-operational
'ttsting of snubber thermal motion. This test-program should be specified in -Chapter 14 of the: FSAR.
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ENCLOSURE 13
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REQUEST FOR ADDITIONAL INFORMATION
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.tain_ ment Sump and its effect on long term cooling following a LOCA During our revitas of license applications we have identified concerns related to the containment sump design and its effect on long term cooling follo' wing a
' toss of Coolant Accident (LOCA).
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These concerns are related to (1) creation of debris which could potentially block the sump screens and flow passzges in the ECCS and the core, (2) inadequate NPSH of the pumps taking suction from the containmert sump, (3) air entrainment
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from streams of water cP steam which can cause loss of adequate NPSH, (4) forma-tion of vortices which can cause loss of adequate NPSH, air entrainment and suction of ' floating debris iato the ECCS arjd (S) inadequate emergscy procedures and'
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operator training to enable a correct response to these problems.. Preoperational recirculation tests performed by utilities h' ave consistently identified the 4
need for plant modifications.
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The NRC has begun a generic program to resolve. this issue.
However, more imediate actions are required to assure greater reliability of safety sys em ol.eration.
We therefore require you take the following actions to provide additional assurance that long tenn cooling of the reactor core can be achieved and raintained following a postulated LOCA.
1.
Establish a procedure to perform an inspection of the containment, and the
_antainment sump area in particular, to identify any materials which have the potent.J for becoming debr,is capable of blocking the containment
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sum, when required for recirculation of coolant water.
Typically, these materials consist of: plas, tic bags, step-off pads, health physics instru-mentation, welding equipment, scaffolding, metal chips and screws nortable es
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inspection-lights,-unsecured wood, construction naterials and tools.as.
well as other ' miscellaneous loose equipment.
"As licensed" cleanliness shouldbeassuredpriortoeachsbartu'.'
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Thit inspection shall'be
-formed at '.he end of each shutdown as soon as practical before containment isolation.
2.
' Institute an inspection program according to the requirements of Regulatory Guide 1.82, item 14.
This item addresses inspection of the containment sump components including screens and intake structures.
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L. Develop and implement procedures for the operator which address bo'th a
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possible vortexing prdblem (with consequent pump cavitation) and sump blockage due to debris. These procedures should address all likely scenarios and should Tist all instrumentation available to the operator-(and its location) to aid in detecting problems which may arise, indications the operator should look for, and operator actions to mitigate these problems.
f 4.
Pipe breaks, drain flow and channeling of spray flow released below or impinging on the containment water suiface in the area of the sump can f
cause a variety of problems; for example, air entrainment, cavitation and vortex formation.
Describe any changes you plan to make to reduce vortical flow in the neighborhood of the sump.
Ideally, flow should approach uniformly from
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all directions.
- 5. -Evaluate-the extent to which the containment sump (s) in your plant mee't the requirements for each of the items previously identified; namely
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t debris, inadequate NPSH, air entrainment, vortex formation, and operator
' tris. 3nadequate N,i.:,
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actions.
ions.
The-following additional ~ guidance i pr$vided for performing this evaluation.
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ir (1)
Refer to the reccernendations in Regulatory Guide 1.82 (Section C) which r
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P ier to the r may be of assistance in performing this evaluation.
may be of assistano in >
a 1"i; c,l' (2)
Provide a drawing showing the location of the drain sump relative (Z)
Provide a crawing P H M the IN :tirr j f' '
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to the containment sumps.
to the contal.
c n '. 'a ' n.
(3)
Provide the following information with your evaluation of debris:
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Prev.Je the folica ng
<o',rm tion - th 2 c ur '
(a)
Provide the size of openings in the fine screens and compare thi,s r
a c Nre this (a )
provide the size of epenings in.t' tio with the minimum dimensions in the pumps which take suction from with the minirm dirmnsions in the puc,e J i ". t ue suction from the sump (or torus), the minimum dimension in any spray nozzles the sump (cr toru:.), th: -ini m c; - ct m v nav les and in the fuel assemblies in the reactor core or any other line and in the fuel an.semblies in the rc ciar ora or any ather line in the recirculation flow path whose size is comparable to or in the recirculation n ~ path whose s,s c c m ra';?e to or smaller than the sump screen mesh size in order' to show that no snaller then the sump screen U sh size a,+>T to c.< that no flow blockage will occur at any point past the screen.
ficw blockege mil occur at *ny poim
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(b)
Estimate the extent to which debris could block the trash rack (b)
Ettirate % utent to W ch debris w.'
th-tc::h rack or' screens (50 percent limit).
If a blockage problem is identified,
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screcns (50 po cent Ti,it).
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or describe the corrective actions you plan to take (. replace insul,ation, p.
t imui: tion, describ, the corrective etiens ysu f enlarge cages, etc.).
enlarce raget,, "tc.).
(c)
For each type of thermal insulation used in the containment,
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(c)
For nach type of therma' insulat'r provide the following information:
[nrovide tb following infcrnation: type of material including compositio i)
(i) type of m:terial in:loding c an t
'ty, (i.i ) manufacturer and brand name, (ii) mco 'acturer
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' und nn, (iii) method of attachment, (ii;) e ' < >
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s (iv) :Tocation and quantity in containment of each. type.
.(h) an estimate of the tendency of each type to form particles -
small enough to pass through the fine scre'en in the suction lines.
(d)
Estimate what the ef'fect of these insulation particles'would be on the operability and performance of all pumps useJ. for recirculation cooling.. Address effects on pump seals an'd bearings.
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