ML20050B603

Forwards Response to 820309 Request for Addl Info Re Operational QA program.NUREG-0737 safety-related Items to Be Included in FSAR Table 3.2-1 Listed

ML20050B603
Person / Time
Site:	Perry
Issue date:	03/26/1982
From:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-***, TASK-TM IEB-80-11, NUDOCS 8204060118
Download: ML20050B603 (13)

Text

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THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P o DOX 5000 m CL EVEL AND. OHIO 44101 e TELEPHONE (216) 622-9800 m ILLUtAINATING BLDG e 55 PUBLIC SOUAAE Serving The Best Location in the Nation Dalwyn R. Davidson v'CE FHE 'ilOE NT S Gil M f NGINf [HING AND CCN5f HUCT60N i.

March 26, 198 () Y

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Mr. A. Schwencer c l',,'J 19323 'l E2

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Chief, Licensing Branch No. 2

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Di tision of Licensing ,

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U. S. Nuclear Regulatory Commission v >s s/

Washington, D. C. 20555 . .

Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to Request for Additional Information Regarding PNPP Units 1 and 2 Operational Q. A. Program

Dear Mr. Schwencer:

This letter and the enclosed information is submitted in response to your letter dated March 9, 1982 concerning whether or not the items identified in your letter are covered by our operational quality assurance.

Please advise us if we can be of any flirther assistance Very Truly Yours,

/

/

W , h Dalwyn i. Davidson Vice President System Engineering and Construction DRD: mlb cc: John Stefano Jay Silberg, Esq.

Max Gildner Doo).c

/ /

8204060118 820326 PDR ADOCK 05000440 PDR

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. 16 260.6 section 17.1.2.2 of the standard format (Regulatory Guide 1.70) requires l the identification of safety-related structures, systems, and components controlled by the QA program. You are requested to supplement and clarify Table 3 2-1 of the Perry FSAR in accordance with the following:

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a. 'Ihe following items do not appear on FSAR Table 3 2-1. Add the appropriate items to the table and provide a commitment that the remaining items are subject to the pertinent requirements of the FSAR operational quality assurance i program or justify not doing so.

1. Safety-related maconry walls (see IE Bulletin No. 80-11).

2. Biological shielding within the fuel handling intermediate building, control building, and reactor building complex auxiliary building.

3 Missile barriers within the fuel handling intermediate.

building, reactor building complex auxiliary building, 1 control building, diesel generator building, off-gas building, and emergency service water pump house.

4. Spent fuel pool and' liner.

i 5 Drywell-wetaell vacuum breaker.

6. Diesel generator combustion air intake and exhaust system.

4 7. Radiation monitoring (fixed and portable).

! 8. Radioactivity monitoring (fixed and portable).

9 Radioactivity sampling (air, surfaces, liquids).

10. Radioactive contamination measurement and analysis.

11. Personnel monitoring internal (e.g. whole body counter)

.l and external (e.g. TLD system).

12. Instrument storage, calibration, and maintenance.

13 Decontamination (facilities, personnel, and equipment).

14. Respiratory protection, including testing.

15 Contamination control.

16. Accident-related meteorological data collection equipment.

$ hh 260.6 .

(Con' t)

17. Seismic category I slopes of the Lake Erie shoreline bluff located 305 feet north of the emergency service water pumphouse.

18. Seismic category I fill.

19 Foundation for seismic category I electrical duct banks and manholes.

20. Site grading and watershed alterations.

21. Valve operators for all safety-related valves.

22. Motors for all safety-related pumps,

b. The following ite=s from FSAR Table 3.2-1 need expansion and/or clarification as noted. Revise the list as indicated or justify not doing so.

1. Provide a commitment that the safety-related instrumenta-tion and controls (I&C) described in Sections 7.1 through 7.6 of the FSAR plus safety-related I&C for safety-related fluid systems will be subject to the pertinent requirements of the FSAR QA program. This can be done by footnote to Table 3 2-1

2. For the systems 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 listed.

IX RHR System Containment spray nozzles Conical stainless strainer XXIII Offgas System As per Section C.6 of Regulatory Guide 1.143 XXXII Standby AC Auxiliary Power Systems (Class lE)

Diesel generator packages including auxiliaries (e.g., lube system, jacket cooling, air start system, governor, voltage regulator, excita-tion system) 6900 volt switchgear 480V load centers 480V motor control centers Instrumentation, control, and power cables (including underground cable system, cable splices, connectors and terminal blocks)

~AW-260.6 .

(Con't) .

Conduit and cable trays and their supports containing Class 1E cables and those whose failure may damage other safety-related items 6900/480Vtransformers Valve operators Protective relays and control panels AC control power inverters Containment electrical penetration assemblies other cable penetrations (fire stops)

XXXIII. 125 Volt Class lE DC Vital Power Distribution System lL5V batteries, battery chargers, and distribution equipment Cables Conduit and cable trays and their supports con-taining Class lE cables and those whose fail-ure may damage other safety-related items Battery racks Protective relays and control panels XXXIV Structures Reactor pressure vessel shield wall annulus Drywell head co=partment RWCU heat exchanger compartment RCWU demineralizer valve compartment RCWU demineralizer compartment RCWU valve nest compartment Main steam tunnel compartment Drywell-to-suppression pool vents XXXV.1 Annulus Exhaust Gas Treatment System Units Filter housing Fans and motors Demisters Heaters Ductwork Dampers XXXV.12 Fuel Handling Building Exhaust System Units Filter housing Fans and motors Demisters 1 Heaters .

Ductwork Dampers

g:  ;.gy ;pc"

, . 26o.6 -g (Con't)

XXXV.25 Control Room Emergency Recirculation Units Filter housing Fans and motors Demisters Heaters Ductwork Dampers XXXV.30 Combustible Gas Control Hydrogen analyzer Hydrogen recombiners XXXV. Control Room HVAC System Fans and motors Cooling coils (DX)

Filters Humidifiers Condenser Charcoal filter housing Ductwork and dampers Valves with safety isolation function Utility exhaust fan Unit heaters

c. Enclosura 2 of NUREG-0737, " Clarification of TMI Action Plan Requirements" (November 1980) identified numerous items that are safety-related and appropriate for OL application and therefore should be on Table 3 2-1. These items are listed below. Add

, the appropriate items to Table 3 2-1 and provide a commitment that the renaining items are subject to the pertinent requirements of the FSAR operational QA program or justify not doing so.

NUREG-o737 Enclosure 2 Clarification Item

1) Plant safety-parameter display console. I.D.2

2) Reactor coolant system vents II.B.1

3) Plant sheilding. II.B.2 t 4) Post accident sampling capabilities. II.B.3 i

i 5) Valve position indication. II.D.3 l 6) Dedicated hydrogen penet-l rations. II.E.4.1

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7) Contain=ent isolation dependability. II.E.4.2 i

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. 260.6 ,

(con't) ,

8) Accident monitoring instrumentation. II.F.1 .

9) Instrumentation for detection of inadequate core-coolin'g. II.F.2

10) HPCI & RCIC initiation levels. II.K.3(13)

11) Isolation of HPCI & RCIC. II.K.3(15)

12) Challenges to and failure of relief valves. II.K.3(16)

13) ADS actuation. II.K.3(18)

14) Restart of core spray and LPCI. II.K.3(El)

15) RCIC suction. II.K.3(22)

16) Space cooling for HPCI &

RCIC. II.K.3(24)

17) Power on pump seals. II.K.3(25)

18) Common reference level. II.K.3(27)

19) ADS valve, accumulators, and associated equipment and instrumentation. II.K.3(28)

20) Emergency Plans (and related eciuipment) . III.A.l.1/III.A.2

21) Equipment and other items associated with the emergency support facilities. III.A.l.2

22) Inplant I radiation monit-2 oring. III.D.3 3

23) Control-room habitability. III.D.3.4

• i

i. b t,-=- 260.6 -

(Con't)

Response

Table 3 2-1 of section 3 2 is a general sum =ary listing of the safety-class and classifications of various plant structures, systems and components. In general, those structures, systems and components that a: e not safety related are not included in'.

the table. In certa $ 4 cases, non-safety related items have been added to the table in order to differentiate where only a portion of an entry is safety related or to provide ready reference to the classification of specific items. It was not intended that

this table list all the structures, systems and components in the plant.

The primary justification for not adding an item to the table where requested is that the item is not safety related. Other items were already included under different heading and, a reference is provided for these items.- Table 3 2-1 will be revised to add the safety-related items as ncted below.

NOTE 1: Plant operating procedures and administrative controls are not included in Table 3;2-1. These procedures and controls for safety related activities are addressed in and controlled by Technical Specification (FSAR Chapter 16) and by the pertinent requirements of the operational quality assurance pro @am. (FSAR Chapter 17).-

a.1 There are no safety-related masonry walls at perry.

a.2 The biological shield wall is included in the entry for the Reactor Building Complex Item XXXIV 1.c.

Radiation Sheilsling walls are considered part of the l structure of the associated building and covered by the existing entries in ItemXXXIV.

l l a.3 Missile barriers are considered part of the structure of l the associated building and are covered by the j existing entries in Item XXXIV.

I i

a.4 Item XXXIV will be revised to add safety-related spent fuel pool and liner, a.5 Item XXXV will be revised to add the safety-related drywell vacuum breakers.

a.6 The diesel generator combustion air intake and exhaust systems' piping and valves are safety-related except for the intake air filter, exhaust silencer and crankcase l Vent piping. Item XXIX will be revised to add the

! appropriate items.

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, , . 260.6 -7 (con't) .

a.7 Radiation monitors for the main steam lines, containment building vent exhaust, prin_Lry and secondary contairment area high range monitors and airborn effluent monitors from the main plant, off-gar and turbine building heater vents are safety-related and will be added to Table 3.2-1.

a.8 thru a.15 These items are covered by plant operating procedures and administrative controls and are not included in Table 3 2-1. (See NOTE 1)

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a.16 Meteorological data collection equipment is not safety-related. Suchequipaent/calibrationanddatareduction are procedural in nature and are covered by administrative controls. (See NOTE 1) a.17 There are no seismic category I slopes of the Lake Erie shoreline bluff. As discussed in FSAR Fection 2.4.5.5, no safety-related structures are located within 380 feet of the lake shoreline. A survey program is in effect to monitor the effect of shore-line recession and bluff erosion. Permanent safety-related shoreline protection construction would be initiated when the lake shoreline (toe of bluff) has receeded to a point 250 feet away from the emergency service water pu=phouse. At that time, the grading of the shoreline bluff and construction of a permanent protective revetment would be covered by the pertinent requirements of the operational quality assurance program (FSAR Chapter 17),

a.18 Seismic category I fill is safety-related and will be added to Item XXXIV.

a.19 Ibere are no foundations for seismic category 1 electrical duct banks and manholes. The safety-related duct banks are constructed of reinforced concrete, backed by seismic category I fill, and will be added to Item XXXIV.

a.20 The site grading is not safety-related and is not required to be covered by the operational quality assuranc6 program, a.21 Valve operators for safety-related seismic category I valves are included in Table 3 2-1, implicit in the entry for the valves. A note will be added to explicitly address valve operators, a.22 The motors for safety-related pumps are presently included in Table 3 2-1. The safety-related Fuel Pool Cooling and Cleanup system pump motors will be added to Item XX.

260.6 ,

. 4-(Con' tj .

b.1 A note will be added to Table 3 2-1 as follows:

" Safety-related instrumentation u d controls described in Sections 7.1 through 7.6 of the FSAR and safety-related instrumentation and controls for safety-related fluid systems will be subject to the pertinent requirements of the operational quality assurance program.

(FSAR Chapter 17) b.2 Table 3.2-1 will be expanded to include the following system components subject to the pertinent 10 CFR 50 Appendix B quality assurance requirements.

IX RHR System a) Containment spray nozzles are presently included in Item XXXV.35 b) Conical stainless strainers are safety-related and will be added as Item IX.13 XXIII Offgas System The quality program for the off-gas system is described in Note 18 to Table 3 2-1.

XXXII Standby AC Auxiliary Power Systems (Class lE) a) Diesel generator e.uxiliaries are presently covered by Item XXIX, and Jacket water cooling will be added.. _ _ .

b)-1) These items will be includes in Item XXIII with the following exceptions; 6900 volt switchgear is not applicable since PNPP has 1160 6

volt switchgear. Valve operators were addressed in item a.21. Fire stops are supplied and installed in accordance with the quality requirements recommended in the staff supplement guidance, " Nuclear Plant Fire Protection Functional Responsibilities, Adminstrative Controls, and Quality Assurance", dated August 29, 1977 XXXIII 125 Volt Class lE DC Vital Power Distribution System a)-e) These items will be added to Table 3 2-1.

XXXIV Structures a)-h) All items listed are part of the containment, which is included in Item XXXIV.l.

XXXV.1 Annulus Exhaust Gas Treatment System Units a)-f) All items listed are included in this. entry, but will be explicitly added to Table 3 2-1.

260,6 -

(Con't) -

XXXV,12 Fuel Handlin6 Building Exhaust Units All items listed are included in this entry, 3)_f) but will be explicitly added to Table 3 2-1.

XXV.25 Control Room Emergency Recirculation Units

- The items listed are included in this entry a)-f) but will be explicitly added to Table 3.2-L.

XXV.30 combustible cas Control- e a)-b) The safety-related hydrogen analyzer and hydrogen recombiners will be added to this entry in Table 3 2-1.

XXXV Control Room HVAC a)-j) These items are included in Items XXXV.24 but will be added to Table 3 2-1.

i 4

1

h C.1 The SPDS is not required to be Class lE or meet single I.D.2 -

failure criterion in accordance with NUREG-0696.

The display system will be seismice.11y designed and will be added to Table 3.2-1.

C.2 No equipment changes are necessary for the existing II.B.1 design of the reactor coolant system vents.

C.3 The requirements for shielding are included in Table II.B.2 3 2-1 ar part of the entries for each of the buildings in item XXXIV.

C.4 The post-accident sampling system design ;as not been II.B.3 finalized, but it is not required to be safety-related.

C.5 The SRV position indication is a safety grade system II.D.3 and will be added to Table 3.2-1.

C.6 II.E.4.1 Dedicated hydrogen penetrations are covered in Item XXXV.30 of Table 3.2-1. Also, Perry has internal recombiners, which will be added to this entry.

C.7 No additional equipment is required for containment II.E.4.2 isolation dependability. Exisiting equipment is presently included in appropriate section of Table 3 2-1.

C.8 Additional accident monitoring instrumentation requirements II.F.1 has not been finalized, but these items will be added to Table 3 2-1 as appropriate.

C.9 No additional equipment is anticipated as a result of II.F.2 this requirement; thus no changes are required to Table 3 2-1.

C.10 Only logic changes are required for HPCS and RCIC l II.K.3(13) initiation levels; thus no chan oes are required to l Table 3 2-1.

C.11 Only logic modifications to RCIC system break detection II.K.3(15) are required as a result of this item; thus, no changes are required to Table 3 2-1.

l

• M' C.12 No equipment changes are required for challenges to and II.K.3(16) failures of relief valves; thus, no changes are required to Table 3 2-1.

C.13 No equipment changes are anticipated as a result of IT.K.3(18) this requirement; thus, no changes are required to Table 3 2-1.

C.14 Only logic modifications are required fbr the restart II.K.3(21) of HPCS; thus, no changes are required to Table 3 2-1.

C.15 RCIC pump suction equipment is included in Item XII LT.K.3(22) of Table 3 2-1.

C.16 No equipment changes are required for HPCS and RCIC

_II. K. 3 (24 ) room cooling systems; thus, no changes are required to Table 3 2-1.

C.17 No equipment changes are required for the loss of pump II.K.3(25) seal cooling; thus, no changes are required to Table 3 2-1.

C.18 No equipment changes are required for co::non reference II.K.3(27) level; thus, no changes are required to Table 3 2-1.

C.19 No equipment change is anticipated as a result of this II.K.3(28) requirement for ADS equipment; thus, no changes are required to Table 3 2-1.

C.20 Energency plans satisfy the intent of NUREG-0654.

ITI.A.l.1/ Etergency plans are procedural,in nature and are not III.A.2 included in Table 3 2-1 (See NOTE 1).

C.21 Deergency support facilities are not safety-related III.A.l.2 and are not included in Table 3 2-1.

C.22 III.D.3.3 Inplant I, radiation monitoring equipment is not safety-related ahd will not be included in Table 3.2-1.

I

C.23 No equipment changes are required as a result of the ITT.D.3.4_ control room habitability requirement; thus, no changes are required to Table 3 2-1.

In addition to the revisions to the table co=mitted to above, the corrections identified in the letter fran A. Schwencer to D. R. Davidson dated March 10, 1982 will be incorporated in a major revision to Table 3 2-1 which will be provided in an upcoming amendment.

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