ML20039B360
| ML20039B360 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/10/1981 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-531, NUDOCS 8112220578 | |
| Download: ML20039B360 (15) | |
Text
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i UNION ELECTRIC COMPANY 1901 GRATIOT STREET ST. Louis, Missouri coNato sr. scHNELL 9
, go December 10, 1981 4
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Mr. "arold R.
Denton Q
ObCgy7 Dire or of Nuclear Reactor Regulation Q%
GIA /
U.S. Nuclear Regulatory Commission c; '" 4 +
washington, D.C.
20555 C3 C ""
y UL htC-}5gjh'
Dear Mr. Denton:
Docket Number 50-483 Callaway Plant Unit 1 Final Safety Analysis Report f
Revised Responses to ITEMS FROM NRC QUESTION 260.71C 4'
Ref:
Union Electric Letter to the NRC (ULNRC-521).
dated October 1, 1981, signed by D.
F.
Schnell 4
The attached are revised responses to items raised from your question 260.71C which was transmitted by a letter from R.
L. Tedesco to J. K.
Bryan dated August 12, 1981.
Initial Union Electric responses were submitted via the referenced. letter.
In meetings with the NRC subsequent to submittal of our initial' responses, the attached items of question 260.71C were identified as needing revised or additional responses.
The resolution of these items for the most part refer back to a revision of the SNUPPS FSAR Section 3.2 and Table 3.2-1.
These revisions are indicated in four attachments following the Union Electric revised responses.
This information and the Union Electric responses are 1
hereby-incorporated into the Callaway Application and will be incorporated into the next revisions of the Callaway FSAR Site Addendum and the SNUPPS FSAR.
Very truly yours, ty m
Donald F. Schnell 300 I i
DJW/mdj r
Attac.hments 4
4 m
8112220578 y h [h, PDR ADOCK po A
STATE OF MISSOURI )
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Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an of ficer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has avacuted the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
)
By C
' Donald F.
Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this 15th day of December, 1981 tb M BARBARA J. PFAFF NOTARY PUBUC, STATE OF M'SSOURI MY CC'etMfSS!ON EXFIRES APRIL 22. IMS ST. LOUIS COUNTY
cc:
Glenn L. Koester Vice President Operations Kansas Gas & Electric P.O.
Box 208 Wichita, Kansas 67201 John E. Arthur Chief Engineer Rochester Gas & Electric Company 89 East. Avenue Rochester, New York 14649 A. V.
Dienhart Vice President Plant Engineering and Construction Northern States Power 414 Nicollet Mall Minneapolis, M'nnesota 55401 Donald T. McPhee Vice President Kansas City Power and Light Company 1330 Baltimore Avenue Kansas City, Missouri 64141 Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M.
Street, N.W.
Washington, D.C.
20036 Nicholas A.
Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 W. Hansen Callaway Resident Of fice U.S.
Nuclear Regulatory Commission RR#1 Steedman,- Missouri 65077 Gordon Edison Project Manager-SNUPPS U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
bec:
3456-0021.6 3456-0547.5 3456-0546.8 Nuclear Date DFS/ Chrono D.
F.
Schnell J.
F. McLaughlin J.
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Birk W.
H. Weber F.
D.
Field R.
J.
Schukai M. A. Stiller D.
E.
Shain F. W.
Brunson J.
J.
Beisman Missouri Public Service Commission D.
W.
Capone A.
C.
Passwater W.
H.
Zvanut R.
P. Wendling N.
G.
Slaten V.
M. Weber D.
E.
Shafer D.
J.
Walker
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L Union Electric's Revised Responses to NRC Selected ITEMS of Question 260.71C t
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SNUPPS-C Item 260.71C Section 17.1.2.2 of the standard format (Regulatory Guide 1.70) requires the identification of. safety-related structures, systems, and components controlled by the QA program.
You are requested to supplement and c.1arify Table 3.2-1 of the Callaway FSAR in accordance with the following:
The following items do not appear on FSAR Table 3.2-1.-
Add a.
the appropriate items to the table and provide a commitment that the remaining items.are subject to the pertinent requirments of the FSAR operational quality assurance program or justify not doing so.
a.5 Refueling machine Callaway Position:
Already in Table 3.2.1, Section 3.0, revision 7.
Table 3.2.1 will be revised to show QA program Y-W2.
See attachment 1.
a.6 Spent fuel handling tool Callaway Pocition:
Already in Table 3.2-1, Section 3.0, revision 7.
Table 3.2-1 will be further revised to show QA program Y-W2.
See attachment 1.
a.7 Radiation shielding doors t
Callaway Position:
Already in Table 3.2-1, Section 8.2 (Our position is that this item is not safety related).
Adequacy of this shielding is verified by periodic radiation surveys.
a.8 Radic' ion monitoring (fixed and portable)
Callaway Position:
It is Union Electric's position that items 8-16 of 260.71c(a) should not be included in Table 3.2-1, or be subject to the requirements of the operational quality assurance program.
Union Electric does feel that NUREG 0761,
" Radiation Protection Plans for Nuclear 1
Power Reactor Licensees" Draft Report, March 1981, which is presently in draft form and out for comments, provides the c
necessary guidance in formulating the Callaway Radiatlon Protection Plan.
The Callaway Radiatica Protection Manual (CRPM) and Radiation Protection (RP) procedures together will constitute the Callaway Radiation Protection Plan.
(CRPP). outlines the proposed CRPM.
The outline lists the 260.71C-2 i
f SNUPPS-C major areas to be addressed in the manual.
It is intended that the CRPM will be a concise statement of the Callaway Radiation Protection Plan that can be understood by all plant personnel.
The manual will be written in general and brief terms with the specifics of the plan to be addressed in the implementing RP procedures.
The Callaway Radiation Protection Plan will be developed in accordance with applicable regulatory requirements, regulatory guides, industry standards, and accepted industry practices, and will incorporate sufficient managerial and administrative controls to ensure that a 4
high level of radiation protection is provided. outlines the implementing procedures.
These procedures have been broken down into areas as recommended by the NUREG.
Ic is intended that administrative controls will be implemented via incorporation into administrative and programmatic level procedures which will receive Onsite Review Committee (Plant Review To verify Group) review and approval that radiation protection functions are being performed as required and that a high level of radiological safety is maintained, periodic review and audit of the radiation protection program will be performed by an independent audit group of Union Electric Nuclear Engineering (i.e., the corporate health physics group or their consultant).
Periodic is to be interpreted as annual; however, when warranted by identified program deficiencies a more frequent review-schedule of the deficient area may be implemented.
The specified audi t frequency is based on established l
industry auditing practice and the assumption that a corporate audit at an annual frequency in combination with regulatory, ANI and INPO inspections will l
provide adequate review and evaluation of program performance.
The General Office Quality Assurance Group will review the i
activities and Audit program of the independent audit group to assure that i
appropriate audit procedures are r
260.71C-3 i
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SNUPPS-C established and implemented.
The performance of audit and review of the areas identified in items 8-16 to assure program effectiveness is_ consistent with the position of NUREG 0761.
The audit program will be conducted in accordance with established auditing principles:
1.
use of inspectors / auditors with training and expertise in the area being audited 2.
use of audit personnel with no responsibilities or " vested interests" in the areas being reviewed 3.
documentation and review by management of audit results and findings 4.
performance of corrective or followup actions as appropriate Additional quality assurance for items 8-16 of 260.71c(a) are built into RP procedures utilizing quality assurance provisions from regulatory guides.
An example is the respiratory protection program.
Quality assurance for procurement of respiratory equipment is maintained by the purchasing of only NIOSH certified equipment.
In complying with Reg. Guide 8.15, additional quality assurance is established in the respiratory protection program.
In summary, the program described above will meet or exceed the equivalent applicable portions of the Union Electric sperational quality assurance program.
a.20 Roof drains and parapets of buildings which house safety related equipment.
Callaway Position: Not safety related--no credit is taken for these in FSAR safety analyses, but.they are considered in the overall load design of the building.
Any subsequent modifications would be reviewed as part of the impact to modifying the overall building design.
260.71C-4
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SNUPPS-C a.24 Valve operators for all safety related valves.
- Callaway Position: See the revised 4th paragraph of FSAR Section 3.2, given in attachment 2.
The P i
& ID's for safety related systems define system' boundaries and those components which are safety related.
b.
The following items from FSAR Table 3.2-1 need expansion and/or clarification as noted.
Revise the list as indicated or justify not doing so.
1.
Identify the safety-related instrumentation and control i
systems to the same scope and 1cvel of detail as provided in Chapter 7 of the FSAR.
(This can be done by footnote).
Callaway Position:
Table 3.2-1 will be revised to include the following footnote:
(13) Safety Related Instrument and Controls are described in SNUPPS FSAR Sections 7.1-7.6.
See Attachment 3.
2.
For the sy. stems shown below, expand the list in Table 3. 2-1.
to include the indicated components under the pertinent 10 CFR 50 Appendix B quality assurance requirements or verify that they are included as part of the components already i
listed.
j b.2.1.5 Containment spray system containment sump.
Callaway Position: Part of Section 8.1 of. Table 3. 2-1.
Sumps are part of the reactor building.
b.2.1.6 Containment cooling system ductwork.
Callaway Position: See revised 4th paragraph of Section 3.2.
(Attachment 2) b.2.2.7 Ultimate heat sink retention pond slopes, retention pond rip rap.
Callaway Position: Part of Section 2.7 of Table 3.2-1.
- c. of NUREG-0737, " Clarification of TMI Action Plan Requirements" (November 1980) identified numerous items that i
are safety-related and appropriate for OL application and therefore should be in Table 3.2-1.
These items are listed i
below.
7dd the appropriate' items to Table 3.2-1 and provide commitment that.the remaining items are subject to the apertinent requirements of FSAR operational OA program or f
justify not doing so.
col Plant safety-parameter display console.
260.71C-5 a
SNUPPS-C Callaway Position: Not available yet--appropriate quality assurance programs will be. applied.
c.2 Reactor coolant system vents.
Callaway Position. Included as part of 1.1 of Table 3.2-1.
See revised 4th paragraph of Section 3.2 given in attachment 2.
c.4 Post accident sampling capabilities.
Callaway Position: The equipment used for inplant post accident sampling is not safety related and therefore is not included in Table 3.2-1.
However, the portions of the system which are involved-in maintaining containment integrity are procured and installed as safety related equipment.
The programs which control the monitoring activities are administered to meet the requirements of 10CFR20.
c.5 Valve position indication.
Callaway Position: Part of Section 1.1 of Table 3.2-1.
(See revision in attachment 4).
See revised 4th paragraph of Section 3.2 of the SNUPPS FSAR.
(attachment 2).
c.14 Automatic PORV isolation.
j Callaway Position: See revised 4th paragraph of Section 3.2.
(attachment 2).
c.17 Anticipatory reactor trip on turbine trip.
Callaway Position: Part of Section 9.0 of Table 3.2-1 for the Reactor Protection System.
The remainder of the system is non-IE 'but meets special criteria.as defined in the SNUPPS FSAR, Section 7.2.1.1.2.f.
c.19 Emergency plans (and related equip).
Callaway Position: Emergency Plans are not systeme, structures, or components, are not considered safety-related and are therefore not included in Table 3.2-1.
i However, Emergency P1,cn procedures will exist and will be subject to audit.
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SNUPPS-C c.20 Equipment and other items associated with the emergency support facilities.
Callaway Position: These are not considered safety related and are therefore not included in Table 3.2-1.
However periodic checks of radiation measurement and' communication equipment-is required by written procedure.. Appropriate engineering and reference documents (i.e., FSAR, prints, procedure manuals) will be placed in Callaway emergency response _ facilities.
The controls and update of reference documents will be handled in accordance with procedures.
These procedures will be subject to audit by indivi' duals not' directly responsible for procedure implementation.
c.21 Inplant Ig radiation monitoring.
Callaway Position: Inplant iodine monitoring is not considered safety related and is theref6re not included in Table 3.2-1.
Provisions for monitoring of inplant. iodine levels are incorporated-within the scope of.the Callaway Radiation Protection Plan as described in Union Electric's response to question 260.71C, items a.8-a.16.
4 4
260.71C-7 4
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TABLE 3.2-1 (Sheet 9) 1 Quality' Principal I
Group ANS Construction Seismic Classifi-Sa fe ty Quality Codes and i
cation Class Assurance
. Standards Location System / Component (l3) Category I (1)
-(2)
(3)
(4)
(5)
(6)
Remarks i
Wolf Creek
'l i
Excavated cooling Y
NA 3
Y-U ACI-318-7/
O pond and dam 3.0 FUEL IIANDLING AND STORAGE Fuel transfer system Non-Class IE Fuel transfer tube power supply and flange S
NA 2
Y-W2 III/MC C/F Conveyor system i
and controls Y
NA 3
Y-W2 NA C/F Remainder of system N
NA NNS N
NA C/F RCC changing fixture N
NA NNS N
NA-C Fuel transfer
)
Flange Y
B 2
Y-W2 III/MC C
Tube i
Y B
2 Y-W2
, !!!/MC C/F.
I Valve N
D NNS N
MS F
i Sleeve Y
B 2
Y-B III/MC C/F
'l Spent fuel storage Y
NA 3
Y-B NA F
racks New fuel storage Y
NA 3
Y-W2 NA F
racks 1
Reactor vessel head N
NA NNS N
NA C
lifting device-Polar crane S.
NA 3
Y-B NA C
Non-Class IE power supply Refueling machine N
NA NNS Y-N1 NA C
Non-Class IE g
i power supply Cask handling crane S
NA 3
Y-B NA F
Non-Class 15 power supply Spent fuel pool bridge S
NA 3
Y-B-NA
-F Non-Class IE crane power supply Internals lifting N
NA NNS N
NA C
5 poot b,aig wl-Y gA 3
Y.W 1 NA F
g 4.0 RADWASTE MANAGEMENT SYSTEMS 4.1 Boron Recycle System TFTgure 9.3-10)
Rw. 8
WDMGWTC&T SNUPPS Y
3.2 CLASSIFICATION OF STRUCTURES, COMPONENTS, AND SYSTEMS i
certain structures, components, and systems of the nuclear
(
s_,
plant are important to safety because they:
a.
Assure the integrity of the reactor coolant pres-sure boundary.
b.
Assure the capability to shut down the reactor and maintain it in a safe condition.
L c.
Assure the capability to prevent or mitigate the consequences of accidents which could result in potentiel offsite exposures comparable to the
. guideline exposures of 10 CFR 100.
d.
Contain or may contain radioactive material.
The purpose of this sect! n is to classify structures, i
systems, and components according to the importance of the item in order to provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public.
Table 3.2-1 delineates each of l
the items in the plant which fal1 Sunder the above-mentioned categories and the respective associated classification that the NRC, ANS, and industrial codes committees have devel-i oped.
Each of the classification categories in Table 3.2-1 is addressed in the following sections.
For identification of system and subsystem boundaries, Table 3.2-1 is supplemented (i.e., referenced to applicable figures) by piping and instrument diagrams which have been marked to i
clearly show the limits of the seismic Category I and various
[
quality group classifications on a system.
The legend for L
the piping and instrument diagrams is provided in Figure g
gY.cb gnkch>footet5 2 i
1.1-1.
work and dampers,{instrumentationA piping and valves, l
Classification of, duct-l and associated supports, hangers, and
[
restraints is not delineated in Table 3.2-1 because of the extensive listing required.
Their classification, however, is consistent with the boundaries shown on the piping and instrumentation drawings. 0 lislingudd /6 pipinj 4.,d ins /rmen/dh E^""js >
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$.2.1 SEISMIC CLASSIFICATION h
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Seismic classification criteria are set forth in 10 CFR 100 and supplemented by Regulatory Guide 1.29.
Clarifications and specific exceptions to Regulatory Guide 1.29 are dis-I cussed in Table 3.2-3.
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NOTES TO TABLE 3.2-1 (Sheet 4)
Table indicates the required code based on its safety-related importance as dictated by cervice and functionalNote that the actual equi g
(7) requirements and by the consequences of their failure.
principal construction code than required.
(8) Access for inspection and test required. Ilowever, no formal quality program appreva! is required.
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A 3/8-inch restriction is provided for all instrument connections to Quality Group A liquid piping to change the instrument
(
A 3/4 instrument connection is used en Quality Group A piping to
{
(9) piping Quality Group classification from A to B.
change the instrument piping quality group classification from.\\ to B.
9:
i (10) Requirements of ASPE Boiler and Pressure Vessel Code Section III are net, except that the instru:sent sensing line The instrument sensing line I-between the instrument shutoff valve and the instruraent is not hydrostatically tested.
between the process tap and the instrument shutof f valve will be hydrostatically tested in accordance with the Code.
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(11) See Site Addendum.
I.
(12) Pressure boundary is Safety Class 1; heaters are electrically NNS.
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4ABLE 3.2-1 (Sheet <3)
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Principal' e
f-(aality
,ANc, Cuestruction Group Soimic Classifi-
-- Safety, Quality
' ods,wd i
<0
~ (1)
(2)
JL (4)
(5)
'_ 2 _ (6)
Remarks cation
<1 ass
,L3su rance Stia6tds ' '
Locatun Syatem/Cor.ponent [l3) Category I sr-l 9r de [ Y SVes Y
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Pzemsurizer salety Y
A 1
Y-k'l :
311-1
/
C valves
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Pressurizer power-opic-Y A
1 Y-dl 111-1 C
l lass IE ated relief valves power supply Valves.to RCS bound 3ry Y
A 1
Y-W1 111-1 C
Pressu'.1:er f ilie f,t enk, N D
NNS N
B31.1 C
/
bot /.dary valves pot, re-
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1, quired for con *.agrynt asola*lon or part ut
. ICS boundary
/
c' "1.2
' cheraical'and volume control System
/
Tfigu W 9.3-u)
/
Letdowr. and Charging Loop Regenerativa heat exchanger Tube side - letdown Y
B 2
Y-W1 III-2/TEMA-R C
Shell side - charging Y B
2 Y-W1 III-2/TEMA-R C
Letdown heat exchanger Tube side - letdcwn Y
B 2
Y-W1 III-2/TEMA-R A
she11 nide - CCW Y
C 3
Y-W1 III-3/TEMA-R A
Letdown orifices Y
B 2
Y-W2 III-2 A
Excess letdown heat exchanger Tube side - letdown Y
B 2
Y-W1 III-2/TEMA-R C
Shell side - CCW Y
C 3
Y-W1 III-3/TEMA-R C
Seal water return heat exchanger Tube side - letdown /
Y B
2 Y-W1 III-2/TEMA-R A
sealwater Shell side - CCW Y
C 3
Y-W1 III-3/TEMA-R A
Mixed bed demineral-N D(A)
NNS Y-W2 VIII(7)
A 1:els Cation bed demineral-N D(A)
NNS Y-W2 VIII(7)
A Izers Boro.; meter N
D NNS N
B31.1 A
RC filter Y
B 2
Y-W1 III-2 A
Volume control tank Y
B 2
Y-W1 III-2 A
Centrifugal charging Y
B 2
Y-W1 III-2 A
Class IE power pump supply. CCW is required.
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