ML20054F122
| ML20054F122 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/07/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.026, RTR-REGGD-1.026 NUDOCS 8206150234 | |
| Download: ML20054F122 (5) | |
Text
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' THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY ILLUMINATING BLDG. e PUBLIC SOUARE e CLEVELAND, OHIO 44101 e TELEPHONE (216) 623-1350 m MAIL ADDRESS: P. O. BOX 5000 Serving The Best Location in the Nation D:fwyn R. Davidson V6CE PRESIDENT SYSTEM ENGINEERING AND CONSTRUCTION June 7, 1982 Mr. A. Schwencer, Chief Licensing Branch No. 2 Division cf Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Schwencer:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 SER Open Item-HPCS D/G Auxiliary Piping This letter is provided in response to SER Open Item No. 17 and FSAR Question 430.17 regarding Quality group classification of HPCS diesel generator skid-mounted auxiliary piping. This response supplements our earlier response to question 430.17 transmitted in a letter dated April 29, 1982.
It is CEI's position the PNPP HPCS diesel generator auxiliaries have been adequately designed in accordance with the guidelines of Regulatory Guide 1.26 and can be considered equivalent to a system designed to ASME Section III Class 3 requirements with regard to system functional operability and inservice reliability. The basis for this conclusion is the requirements imposed on the design, manuf ac ture, inspection and testing, described in detail in the attach-ment to this letter.
Essentially, Seismic Category I, ANSI B31.1, ANSI 45.2, and 10 CFR Appendix B were specified for the auxiliary piping and components. The auxiliary systems have operating pressures well below design capabilities and a proven history of reliabic operational experience. Additionally, PNPP requirements for pre-operational testing, vendor material certifications, and augmented visual and liquid penetrant examinations effectively eliminate the technical differences between ANSI B31.1 and ASME Section III, Class 3 requirements.
We believe this letter and its attachment should resolve this matter and eliminate this item as an open issue in the Perry SER.
Very truly yours, Dalwyn Davidson s.
8206150234 820607 Vice President PDR ADOCK 05000440 System Engineering and Construction E
PDR DRD: dip cc: Jay Silberg, Esq.
John Stefano 8
Max Gildner
Mr. A'. Schwenc:r Juns 7, 1982 Attachment - Page 1 The HPCS Diesel Generator auxiliary systems has been designed as described in F3AR text Section 9 5 Specifically, the com-ponents and piping systems are designated Seismic Category I and are designed either to ASME Section III Safety Class 3 or ANSI B31.1 requirements. Utilization of the codes described above meets Regulatory Guide 1.26 which requires the design-and associated quality requirements be based on the importance to safety of the plant. There are few technical differences between ANSI B31.1 and ASME Section III, Class 3.
Specilying all nafety class auxiliaries as Seismic category I and requiring qualifiestion and pre-operational testing further reduces these differences as reflected in the following table.
PNPP also notes that conservative design pressures were utilized in the auxiliary systems piping design. Verification that correct piping and component materials were used(material certification) during the manufacturing process should elim-inate t.% need for actual mill test reports fer piping. The discussion following the table specifically delineates the differences between the two codes and PNPP's specific design for each of the diesel engine auxiliary systems.
PNPP considers that an acceptable alternative,which prcvides an equivalent level of design and quality an ASME Section III Class 3 requirements, has been provided in its HPCS diesel generator auxiliary systems design.
ASME SECTION III, 3 ANSI B31.1 i
- 1) Requires ASME materials
- 1) Requires only material certi-and mill test reports for fications.
piping.
- 2) Requires seismic design in
- 2) Requires design for pressure, addition to the B31.1 re-temperature, and normal operating quirements.
loads.
- 3) Requires liquid penetrant
pressure and temperatures of the auxiliaries.
- 4) Requires hydrostatic test to
- 4) Requires initial service leak 1.25 x design pressure.
test.
E.
L i
Mr. A. Schwencer June 7, 1982 Attachment - Page 2 l
The diesel generator auxiliaries are separated into three different segments for design and manufacture, as described in FSAR Section 9 5
- The auxiliaries that were supplied as a part of the diesel engine ckid and diesel starting air skid.
- The fuel oil storage tanks and day tanks (provided by a tank fab 11cator).
- The piping that connects the DSA skid with the engine skid, fuel oil storage tanks and day tanks to the engine skid, the cooling water reservoir tank to the cooling water heat exchanger and the diesel engine air intake and exhaust.
A diccussion of each cessent follows.
Diesel Engine and Diesel Sttrting Air (DSA) Skid The diesel generator units and their skid-mounted auxiliary system are designed, fabricated, shop installed, inspected and examined, and tested in accordance with the commitments in FSAR Table 3 2-1, " Equipment Classification."
The engine-mounted piping and components of the fuel oil, engine cooling water (except heat exchangers - ASME Section III, Class 3),
starting air and kbricating oil systems are ceicnically qualified to Category I requirements as part of the diesel engine skid.
These cyctanc, furniched with the engine, are the standard cystems developed by the engine manufacturer in accordance with LEMA standards, and have a long hictory of service and reliability.
These systems, piping, and components, are designed, fabricated, incpected, installed. examined, and tested in accordance with the guidelines and requirements of ANSI B31.1.
It chould be also noted that it is not possible to obtain all auxiliary components to ASME Section III, Class 3 requirement 4.
For example, the diesel oil pump, lubricating oil pump. filters and flex hoses could not be purchased to ACME Section III, Class 3, since they are unique to engine component manufacturera, which do not manufacture to ASME Section III, Class 3 requirements.
For the engine skid and DSA-skid, the technical di.lerences between ANSI B31.1 and ASME Section III, Class 3 are reduced by the specification of Seismic Category I and PHPP intent per test requirements to perform a cyctem pressure test in accordance with the hydroctatic test parameters specified in ASME Section III, Class 3 The technical differences are delineated in the following paragraph, formatted consistent with the above table.(Technical differences are distinguished from the Section III, Clacs 3 administrative requirements in that a technical difference will result in a difference in construction, whereas an administrative requirenent provides additional paper evidence the werk was done in accordance with the Code.)
Mr. A. Schwenc:r June 7, 1982 Attachment Page 3
- 1) By invoking ANSI B31.1, PHPP has received material cert-ification(certificates of compliance) for the skid-mounted piping components and piping. Mill test reports for piping as required by AS4E Section III cannot be obtained.
- 2) By specifying the skids to be Seismic Category I, the skids and auxiliaries on them will withstand a seismic event.
- 3) The only piping on the diesel engine skids that is over 4" are the 6" lines between the cooling water heat exchanger, expansion tank, and engine block. These have not been liquid penetrant examined, but will be prior to preoperational testing.
,4) The engine auxiliary systems will be at operating pressure for a considerable period of time throughout plant startup testing and thus, will provide a good test of their leak tight-ness before the systems are put into operation. Because of the overspecified design pressure of the components and piping, the chance for leakage at other than mechanical, joints is low.
The expansion tank will be hydrostatically tested at 1.5 times its design pressure and the reservoir tank will-be tested at 1.5 times its design pressure. The time at operating pressure during pre-operational testing will be as likely to expose a leak as would occur during operation at the higher, but shorter duration test time of 10 minutes required by ASME Section III, Class 3 Diesel Oil Storage Tank, Day Tank Supplied by Fabricator These components are ASME Section III, Class 3 Piping and Components Connecting Skids The fuel oil piping up to the diesel engine skid, and the cooling water system's piping and components up to the diesel engine heat exchanger, are designed, fabricated, inspected, installed, examined, and tested in accordance with ASME Section III, Class 3 requirements.
The piping connecting the diesel oil storage tank, day tank, and engine skid, is AD4E Section III, Class 3 The piping connecting the DSA skid to the engine skid and the piping connecting the cooling water reservoir tank and the cooling water heat exchanger are designed, fabricated, inspected, installed, examined, and tested in accordance with ANSI B31.1 snd is des-ignated Seismic Category I.
Performance of hydrostatic testing to 1.5 times design pressure will also be accomplished during PNPP onsite testing of the auxiliary systems.
I
Mr..A. Schwencrr June 7,1982 Attachment - Page 4 Easential components of the starting air system ' are designed -
in accordance with the requirements of Section III'of the AS4E Code, 'Ihe system is classified Safety Class 3 and Seismic
' Category I from the check valve upstream of the' receiver tanks. 'The i air intake and exh.ust system, except for the crankcase vent '
linen and exhauct silencers is also classified Seismic Category I Safety Claca 3 Piping and components up to the diesel engine interface, sre designed in accordance with ASME Section III requirements. For both systems, the time at operating preocure during preoperational testing will be as likely to expoce a leak as would occur during operation at the higher, but chorter duration test time of 10 minutes required by AS4E Section III, Claca 3 Therefore, the technical differences between ANSI B31.1 and AS4E Section III, Class 3 are largely closed.
.