Text

Proposed Tech Specs Increasing Allowable Leak Rate for MSIV & Deleting MSIV LCS
	ML20059K583
Person / Time
Site:	Limerick
Issue date:	01/14/1994
From:	; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	;
Shared Package
ML20059K578	List: ML20059K572; ML20059K583;
References
	NUDOCS 9402020168
	Download: ML20059K583 (51)
	v • d • e

. . .

ATTACHMENT 2 UMERICK GENERATING STATION UNITS 1 and 2 Docket Nos. 50452 50453 Ucense Nos. NPF49 !

NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST r

No.93-184 !

PROPOSED CHANGES Ust of Attached Pages i

UNW1 UNW 2 ;

i

?

xil xil i 3/46-2 3/46-2 3/46-3 3/46-3 ,

3/46-7 3/46-7 3/4 6-19 3/4 6-19 3/4 6-31 3/4 6-31 .:'

B 3/4 6-1 B 3/4 6-1 ;

i F

9402020168 940114 PDR P ADDCK 05000352 l PDR ;

INDEX-LIMITING' CONDITIONS FOR OPERATION AND SURVEILLANCE RE0VIREMENTS SECTION PAGE ;

i

' REACTOR COOLANT SYSTEM (Continued)

~

3/4.4.9' RESIDUAL HEAT REMOVAL Hot Shutdown.......................................... 3/4 4-25 ;

Col d S h u td own . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 4-26 3/4.5 EMERGENCY CORE COOLING SYSTEMS 3/4.5.1 ECCS - 0PERATING...................................... 3/4 5-1 3/4.5.2 ECCS - SHUTD0WN....................................... 3/4 5-6 3/4.5.3 SUPPRESSION CHAMBER................................... 3/4 5-8 !

3/4.6 CONTAINMENT SYSTEMS- ,

1 3/4.6.1 PRIMARY CONTAINMENT I

Primary Containment Integrity......................... 3/4 6 '

Primary Containment Leakage........................... 3/4 6-2 Primary Containment Air Lock...................... ... 3/4 6-5 j

3 MSIV Leakage Alternate Drain Pathway.................. 3/4 6-7 -l 1

Primary Containment Structural Integrity. . . . . . . . . . . . . . 3/4 6-8 ;

+

Drywell and Suppression Chamber Internal Pressure...... 3/4 6-9 i

Drywell Average Air Temperature....................... 3/4 S .)- -

Drywell and Suppression Chamber Purge System'.......... 3/4 6-11' ,

3/4.6.2 DEPRESSURIZATION SYSTEMS Suppression Chamber................................... 3/4 6-12 {

S u p p re s s i o n Po ol Sp r ay . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . 3/4 6-15 Suppress ion Pool Cool i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3/4 6-16 >

3/4.6.3 PRIMARY CONTAINMENT ISOLATION. VALVES................... 3/4 6 17 ;

Table 3.6.3-1 Primary Containment Isolation !

3/4 6-19 Valves...........................

f I

LIMERICK.- UNIT 1 xii !

CONTAINMENT. SYSTEMS PRIMARY CONTAINMENT LEAKAGE )

LIMITING CONDITION FOR OPERATION .

3.6.1.2 Primary containment leakage rates shall be limited to:

a. An.overall integrated leakage rate of less than or equal to-La, 0.500 percent by weight of the containment air per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at Pa,44.0 psig.

b. A combined leakage rate of less than or equal to 0.60 La for all .

penetrations and all valves listed in Table 3.6.3-1, except for main :

steam line isolation valves

and valves which are hydrostatically tested per Table 3.6.3-1, subject to Type B and C tests when' pressurized to Pa, 44.0 psig.

d

c. *Less than or equal- to 100 scf- per hour for any one. main steam line through the isolation valves not to exceed 200 scf'per hour '

for all four main steam lines, when tested'at P t, 22.0 psig,

d. A combined _ leakage rate of less than or equal to 1 gpm times the .

total number of containment isolation valves in hydrostatically !

tested lines which penetrate the primary containment, when tested at 1.10 Pa, 48.4 psig. -

APPLICABILITY: When PRIMARY CONTAINMFNT INTEGRITY is required per

- Specification 3.6.1.1.

ACTIONi .!

t With:

a. The measured overall integrated primary containment' leakage rate !

exceeding 0.75 La, or

b. The measured combined leakage rate for all penetrations and all~

valves listed in Table 3.6.3-1,. except for main steam line isolation - ,

valves

and valves which are hydrostatically tested per Table 3.6.3-1, ;

subject to Type B and C tests exceeding 0.60 La, or l

c. The measured leakage rate exceeding 100 scf.per hour for any one l main steam line through the isolation valves, or exceeding 200 scf-per hour for all four main steam lines, or

d. The measured combined leakage rate for all containment' isolation valves in hydrostatically tested lines which penetrate. the primary j!

containment exceeding 1 gpm times the total number of:such valves, !

.F restore: '

f

a. The overall integrated leakage rate (s) to less than or: equal-to ;

0.75La, and ;

1 i

Exemption to Appendix J of'10 CFR Part 50.

LIMERICK - UNIT 1- 3/4_6-2

l

' CONTAINMENT SYSTEMS .

LIMITING CONDITION FOR OPERATION (Continued)

-ACTION: (Continued)

b. The combined leakage rate for all penetrations and all valves listed I in Table 3.6.3-1, except for main steam line isolation valves

and ,

valves which are hydrostatically tested per Table 3.6.3-1, subject to Type B and C tests to less than or equal to 0.60 La, and

c. The leakage rate to less than or equal to 11.5 scf per hour for any i one main steam line through the isolation valves, and the' total Main Steam line leakage to less than 200 scf per hour for all Main Steam '

lines, and

d. The combined leakage rate for all containment isolation valves in hydrostatically tested lines which penetrate the primary containment '

to less than or equal to 1 gpm times the total number of such valves, prior to increasing the reactor coolant system temperature above 200*F.

SURVEILLANCE RE0VIREMENTS 4.6.1.2 The primary containment leakage rates shall ba demonstrated at the i following test schedule and shall be determined in confermance with the criteria specified in Appendix J of 10 CFR Part 50 using the methods and provisions of ANSI 45.4-1972 and BN-TOP-1 and verifying the result by the Mass Point Methodology described in ANSI N56.8-1981:

a. Three Type A Overall Integrated Containment Leakage Rate tests shall -

be conducted at 40 10 month intervals during shutdown at Pa, 44.0 psig, during each 10-year service period. The third test of each set shall- be conducted during the shutdown for the 10-year plant inservice inspection. >

b. If any periodic Type A test fails to' meet 0.75 La, the test schedule e for subsequent Type A tests shall be reviewed and approved by the Commission. If two consecutive Type A tests fail to meet 0.75 La.

a Type A test shall be performed at least every 18 months until two ,

consecutive Type A tests meet 0.75 La, at which time the above test schedule may be resumed.

c. The accuracy of each Type A test shall be verified by a supplemental test which:

1. Confirms the accuracy of the test by verifying that the difference-between the supplemental data' and the Type A test data is within :

i 0.25La. The formula to be used is: [Lo + Lam - 0.25 La] 6 Lc.

s [Lo + Lam + 0.25 La] where Lc - supplemental test result;-Lo =

superimposed leakage; Lam - measured Type A leakage.

l

2. Has duration sufficient to establish accurately the change in leakage rate between the Type A test and the supplemental test.

3. Requires the quantity of gas injected into the containment or j bled from the containment during the supplemental test to be .

l between 0.75 La and 1.25 La-o Exemption to Appendix "J" to 10 CFR Part 50.

[

' LIMERICK - UNIT 1 3/4 6-3

-l CONTAINMENT SYSTEMS 1 i

i l'

HSIV LEAKAGE ALTERNATE DRAIN PATHWAY <

l LIMITING CONDITION FOR OPERATION 3.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

With the MSIV Leakage Alternate Drain Pathway inoperable, restore the pathway to OPERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . !

JURVEILLANCEREQUIREMENTS 4.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be demonstrated OPERABLE: !

a. In accordance with 4.0.5, by cycling each motor. operated valve, required to be repositioned, through at least one complete cycle of full travel.

f L3MERICK - UNIT 1 3/4 6-7

TABLE 3.6.3-1 PART A - PRIMARY CONTAINMENT ISOLATION VALVES

, 2 l s PENETRATION INBOARD ISOLATION OUTBOARD MAX.ISOL.

ISOL.

FUNCTION ISOLATION P.& ID SIGNAL (S) NOTES-i NUMBER BARRIER BARRIER TIME.IF APP. IF APP.

3 (SEC)(26) (20)

[ 0038 CONTAINMENT INSTRUMENT 59-1005B (CK) NA 59 GAS SUPPLY - HEADER 'B' HV59-129B 7 C,H,5

~

003D-2 CONTAINMENT INSTRUMENT 59-1112(CK) NA GAS. SUPPLY TO ADS VALVES HV59-151B 45 M 59 E&K 007A(B,C,D) MAIN STEAM LINE HV41-1F022A 5*- C,0,E,F,P,Q 6 ~41-

'A'(B,C,D) (B,C,D)

HV41-lF028A 5* C,D,E,F,P,Q 6 g (B,C,D) m

.$ 008 MAIN STEAM LINE DRAIN HV41-lF016 30 'C,0,E,F,P,Q 4 ,

41 HV41-lF019- 30 C,0,E,F,P,Q i 009A FEEDWATER- 1F010A(CK)

NA 41 HV41-1F074A(CK) NA 41-1036A(CK) NA HV41-130B'~ 45 HV41-133A 45 HV41-109A NA 32

, HV41-lF032A(CK) NA HV55-1F105 30 7 HV44-lF039(CK) NA

.(X-98) 41- 1016 (X-9f., - NA 31 X-44)

.I i

.. ~ ____.-_,e.-m,... -- ,.. - - . ..,-w,-m, . . + . , ,-~ , - . - , . . .,-.4. . .-.,--.-r -# - , . . . - - . _ . ,.-w- ,e-. - , . - . E ,,

TABLE 3.6.3-1 '(Continued) y PART B - PRIMARY CONTAINMENT ISOLATION EXCESS FLOW CHECK VALVES .

M h INBOARD OUTBOARD ISOL. l

': PENETRATION FUNCTION ISOLATION ISOLATION ' MAX.lSOL. SIGNAL (S) NOTES P&ID NUMBER BARRIER BARRIER TIME.IF APP. IF APP.

g (SEC)(26) (20) ,

003A-1 INSTRUMENTATION 'D' --

XV41-lF0700 1 41 _;

MAIN STEAM LINE FLOW XV41-lF073D 003A-2 INSTRUMENTATION 'A' --

XV43-lF003A 1 43 RECIRC PUMP SEAL PRESSURE 003C-1 INSTR. - HPCI STEAM FLOW -- XV55-lF024A 1 55 003C-2 INSTR. - HPCI STEAM FLOW -- XV55-lF024C 1 55 g 0 03D-1 INSTR. 'A' MAIN STEAM XV41-lF070A 1 41

' *- LINE FLOW XV41-lF073A 007A(B,C,D) INSTR 'A'(B,C,D) MAIN (HV41-lF022A(B, 5* C,D,E,F,P,Q 6 41 STEAM LINE PRESSURE C,D) SEE PART A (HV41-lF028A 5* C,D,E,F,P,Q 6 THIS TABLE) (B,C,D) l .

020A-1 INSTR - RPV LEVEL --

XV42-lF045B 1 42 l

020A-2 INSTR B' LPCI DELTA P -- XV51-102B 1 51 020A-3 INSTR 'D' LPCI DELTA P -- XV51-1038 1 51 0208-1 INSTR.- RPV LEVEL --

XV42-IF045C 1- 42 0208 INSTR 'C' LPCI DELTA P -- XV51-102C 1 51

s U,,--._.... . . - . . . . , - , . - . - - ,--.,-..-..;.o,.. . .1-.,_.-.. -.- - - . .- o , . . , - . ~ - - , - . , - - . - , _ L J. .

. ~ - ~ - . - . - . . - -

3/4.6 CONTAINMENT SYSTEMS !

BASES l 3/4.6.1 PRIMARY r0NTAINMENT-3/4.6.1.1 PRIMAt. CONTAINMENT INTEGRITY j PRIMARY CONTAINMENT INTEGRITY ensures that the release of radioactive mate- ;

rial s from the containment atmosphere will be restricted to those leakage paths i' and associated leak rates assumed in the safety analyses. This restriction, in conjunction with the leakage rate limitation, will limit the SITE B0UNDARY radiation doses to within the limits of 10 CFR Part'100 during accident conditions. ;

3/4.6.1.2 PRIMARY CONTAINMENT LEAKAGE {

The limitations on primary containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the safety :

analyses at the peak accident pressure of 44.02 psig, Pa. As an added conserva- l tism, the measured overall integrated leakage rate is further limited to less l than or equal to 0.75 La during performance of the periodic tests to account for .

possible degradation of the containment leakage barriers between leakage tests. .j Operating experience with the main steam line isolation valves has' i indicated that degradation has occasionally occurred in the leak tightness of I the valves; therefore the special requirement for testing these valves. !

The surveillance testing for measuring leakage rates is consistent with the requirements of Appendix J of 10 CFR Part 50 with the exception of

. exemptions granted for leak testing of the main steam isolation valves, the airlock and TIP shear valves. -

3/4.6.1.3 PRIMARY CONTAINMENT AIR LOCK The limitations on closure and leak rate for the primary containment.' air '

lock are required to meet the restrictions on PRIMARY CONTAINMENT INTEGRITY and the primary containment leakage rate given in Specifications 3.6.1.1 and i 3.6.1.2. The specification makes allowances for the fact that there may be !!

long periods of time when the air lock will be in a closed and secured '.

position during reactor operation. Only one closed door in the air lock l is required to maintain the integrity of the containment. l 3/4.6.1.4 MSIV LEAKAGE ALTERNATE DRAIN PATHWAY l L Calculated doses resulting from the maximum leakage allowances for the a main steamline isolation valves in the postulated LOCA situations will not 1

, exceed the criteria of 10 CFR Part 100 guidelines, provided the main steam line '

system from the isolation valves up to and including the turbine condenser remains intact. . Operating experience has indicated that degradation has occasionally :

occurred in the leak tightness of'the MSIVs such that the specified leakage .

requirements have not always been continuously maintained. The requirement for-i the MSIV Leakage Alternate Drain Pathway serves to reduce the offsite dose.. !

l l

p LIMERICK - UNIT.l B 3/4.6-l' .

i u

~. . - -. .

I INDEX l LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 1

SECTION 'PAGE-i REACTOR COOLANT SYSTEM (Continued) 3/4.4.9 RESIDUAL HEAT REMOVAL ,

Hot Shutdown'............................................ 3/4 4-25 l Cold Shutdown........................................... 3/4 4-26 3/4.5 EMERGENCY CORE COOLING SYSTEMS-3/4.5.1 ECCS - 0PERATING........................................ 3/4 5 3/4.5.2 ECCS - SHUTD0WN......................................... 3/4 5-6 -

3/4.5.3 SUPPRESSION CHAMBER..................................... 3/4 5-8 .

3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT Primary Containment Integrity........................... '3/4 6-1 Primary Containment Leakage............................. 3/4 6-2 Primary Containment Air Lock............................ 3/4 6-5 MSIV Leakage Alternate Drain Pathway.................... 3/4 6-7 Primary Containment Structural Integrity. . . . . . . . . . . . . . . . 3/4 6-8 Drywell and Suppression Chamber Internal Pressure. .. . . . . 3/4 6 !

Drywell Average Ai r Temperature. . . . . . . . . . . . . . . . . . . . . . . . . 3/4 6-10 Drywell and Suppression Chamber Purge System. . . . . . . . . . . 3/4 6-11 3/4.6.2 DEPRESSURIZATION SYSTEMS j Suppression Chamber..................................... 3/4 6-12 -[

Suppression Pool Spray.................................. 3/4'6-15 t

Suppression Pool Cooling................................ 3/4 6-16' ;

3/4.6.3 PRIMARY CONTAINMENT. ISOLATION VALVES.................... 3/4 6-17 !

Table 3.6.3-1 Primary Containment-Isolation .

Valves.......................... 3/4.6-19 ,

I LIMERICK - UNIT 2-- .xii

CONTAINMENT SYSTEMS PRIMARY CONTAINMENT LEAKAGE :

LIMITING CONDITION FOR OPERATION !

Primary containment leakage rates shall be limited to:

3 . 6 '.1. 2

a. An overall integrated leakage rate of less than or equal to La, 0.500 percent by weight of the containment air per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at Pa,44.0 psig.

A combined leakage rate of less than or equal to 0.60 La for all b.

penetrations and all valves listed in Table 3.6.3-1, except for main ,

steam line isolation valves

and valves which are hydrostatically tested per Table 3.6.3-1, subject to Type B and C tests when- ,

pressurized to Pa, 44.0 psig. q

c. *Less than or equal to 100 scf per hour for any one-main steam !

line through the isolation valves not- to exceed 200 scf per hour i for all four main steam lines, when tested at Pt , 22.0 psig.

d. A combined !1eakage' rate of less than or equal to 1 gpm times the i total number of containment isolation valves in hydrostatically tested lines which penetrate the primary containment, when tested at '

1.10 Pa, 48.4 psig.

APPLICABILITY: When PRIMARY CONTAINMENT INTEGRITY is required per Specification 3.6.1.1. l ACTION:

With-

a. The measured overall integrated primary containment leakage rate exceeding 0.75 La, or ;

b. The measured combined leakage rate for all penetrations and all :

valves listed in Table 3.6.3-1, except for main steam line isolation ,

valves

and valves which are hydrostatically tested per Table 3.6.3-1, subject to Type B and C tests exceeding 0.60 La, or I

c. The measured leakage rate exceeding 100 scf per hour for any one main steam line through the isolation valves, or exceeding 200 scf per hour for all four main steam lines, or .

i

d. The measured combined leakage rate for all containment isolation valves in hydrostatically tested lines which penetrate the primary ,

containment exceeding 1 gpm times the total number of such valves, restore: I

a. The overall integrated leakage rate (s) to less than or equal to 1 0.75La, and

Exemption to Appendix J of 10 CFR Part 50. !

LIMERICK - UNIT 2- 3/4 6-2 ]

CONTAINMENT SYSTEMS

= LIMITING CONDITION FOR OPERATION (Continued) j

' ACTION: (Continued) i

b. The combined leakage rate for all penetrations and all valves listed !

in Table 3.6.3-1, except for main steam line isolation valves

and !

valves which are hydrostatically tested per Table 3.6.3-1, subject .. i to Type B and C tests to less than or equal to 0.60 La, and !

c. The leakage rate to less than or equal to 11.5 scf per hour for any ;

one main steam line through the isolation valves, and the total Main Steam line leakage to less than 200 scf per hour for all Main Steam 3 lines, and ;

d. The combined leakage rate for all containment isolation valves in hydrostatically tested lines which penetrate the primary containment ;

to less than or equal to 1 gpm times the total number of such valves, prior to increasing the reactor coolant system temperature above 200*F. .

-SURVEILLANCE REQUIREMENTS '!

4.6.1.2 The primary containment leakage rates shall be demonstrated at the 4 following test schedule and shall be determined in conformance with the criteria l specified in Appendix J of 10 CFR Part 50 using the methods and provisions of !

ANSI 45.4-1972 and BN-TOP-1 and verifying the result by the Mass Point _l:

Methodology described in ANSI N56.8-1981:

a. Three Type A Overall Integrated Containment Leakage Rate tests shall j be conducted at 40 10 month intervals during shutdown at Pa, 44.0 psig, j during each 10-year service period. The third test of each set shall be -

conducted during the shutdown for the 10-year plant inservice inspection.

b. If any periodic Type A test fails to meet 0.75 La, the test schedule' for subsequent Type A tests shall be reviewed and approved by the Commission. If two consecutive Type A tests fail to meet 0.75 Las ;

a Type A test shall be performed at least every 18 months until two consecutive Type A tests meet 0.75La, at which time the above test schedule may be resumed. i

c. The accuracy of each Type A test shall be verified by a supplemental test which: '

1. Confirms the accuracy of the test by verifying that the difference between the supplemental data and the Type A test data is within 0.25La. The formula to be used is: [to + Lam - 0.25 La] s Lc !

$ [Lo + Lam + 0.25 La] where Lc = supplemental test result; Lo - ;

superimposed leakage; Lam = measured Type A leakage. ;

2. Has duration sufficient to establish accurately the change in leakage rate between the Type A test' and the supplemental test. -

3. Requires the quantity of gas injected into the containment or [

bled from the containment during the supplemental test to be >

between 0.75 La and 1.25 La- >

OExemption to Appendix "J" to 10 CFR Part 50.

LIMERICK - UNIT 2 3/4 6-3 i l

' CONTAINMENT SYSTEMS MSIV LEAKAGE ALTERNATE DRAIN PATHWAY l -j LIMITING CONDITION FOR OPERATION i 3.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be OPERABLE.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

'BCTION:

With the MSIV Leakage Alternate Drain Pathway inoperable, restore '

the pathway to 0PERABLE status within 30 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and'in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . i SURVEILLANCE RE0VIREMENTS 4.6.1.4 The MSIV Leakage Alternate Drain Pathway shall be demonstrated OPERABLE:

a. In accordance with 4.0.5, by cycling each motor operated valve, required to be repositioned, through at least one complete cycle of full travel, i

r i

i l

-LIMERICK - UNIT.2 3/4 6-7 i

+

TABLE 3.6.3-1 ~

5: PART A - PRIMARY CONTAINMENT ISOLATION VALVES C. -

jg !

B .

9 INBOARD OUTBOARD ISOL.

L PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. NOTES P&ID i

SIGNAL (S) c: NUMBER . BARRIER BARRIER TIME.IF APP. IF APP.

} (SEC)(26) (20)

N 0038 CONTAINMENT INSTRUMENT 59-2005B (CK) NA 59 GAS SUPPLY . HEADER 'B' HV59-229B 7 C,H,S 003D-2 CONTAINMENT INSTRUMENT 59-2112(CK) NA GAS SUPPLY TO ADS VALVES HV59-251B- 45 M 59 E & K-007A(B,C,D) MAIN STEAM LINE HV41-2F022A 5* C,0,E,F,P,Q 6 41- ,

'A'(8,C,0) (B,C,D) w HV41-2F028A 5* C,D,E,F,P,Q 6 1 (B,C,D) m

C,D,E,F,P,Q 008 MAIN STEAM LINE DRAIN HV41-2F016 30 4 41-HV41-2F019 30 C,n.E,F,P,Q 009A FEEDWATER _41-2F010A(CK) NA 41 HV41-2F074A(CK) NA 41-2036A(CK) NA HV41-230B 45 HV41-233A 45 HV41-209A NA 32 HV41-2F032A(CK) NA HV55-2F105 30 7 .

HV44-2F039(CK) NA (X-98) 41-2016(X-98, NA 31 X-44) m

.. . - _ , _ .,.,.-.~._.,__---,.,,m. . . . . . - - - . - - . . . -_.-.. .. . - ,. , , , . - - ~ . -_.

, . . . . . . ... ._ ,m. . , . ..-

TABLE 3.6.3-1 (Continued) r-PART B- PRIMARY CONTAINMENT ISOLATION EXCESS FLOW CHECK VALVES 1

9 R- INBOARD OUTBOARD ISOL.

i PENETRATION FUNCTION ISOLATION ISOLATION MAX.ISOL. SIGNAL (S) NOTES P&ID c.

NUMBER' BARRIER BARRIER TIME IF APP. IF APP.

(SEC)(26) (20) 003A-1 INSTRUMENTATION 'D' --

XV41-2F070D 1 41-MAIN STEAM LINE FLOW XV41-2F0730 003A-2 INSTRUMENTATION 'A' --

XV43-2F003A 1 43 RECIRC PUMP SEAL PRESSURE i

003C-1 INSTR. - HPCI STEAM FLOW --

XV55-2F024A 1 55 003C-2' INSTR. - HPCI STEAM FLOW --

XV55-2F024C 1 55 .

5m 003D INSTR.

- LINE FLOW

'A' MAIN STEAM --

XV41-2F070A XV41-2F073A 1 41' 0>

~

007A(B,C,D) INSTR ' A'(B,C,D) MAIN (HV41-2F022/s(B, 5* C,D,E,F,P,Q 6:' 41 .

. STEAM LINE PRESSURE C,D) SEE PART A (HV41-2F028A 5* C,D,E,F,P,Q- 6-THIS TABLE) (B,C,D) ,

020A-1 INSTR - RPV LEVEL --

-XV42-2F045B 1 42 020A-2 INSTR 'B' LPCI DELTA P --

XV51-202B 1 51 020A-3 INSTR D' LPCI DELTA P --

XV51-203B 1 51 0208 INSTR - RPV--LEVEL --

XV42-2F045C .1 42 0208-2 INSTR - 'C' LPCI DELTA P - -- .XV51-202C 1- 51

s. j

.-..,,-,J,._. J,c -.--u,....,..,,,v,-.- s ..-..e .--. , ~ - . . .,~,A- ;-,-,,

- , , - - - - - - - - - - , - + - - , - - - -~----_-m -- _ . - . - - - - - - -

- - . . - - . . ~ - , . . .

V 3/4.6 CONTAINMENT SYSTEMS j BASES 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 PRIMARY CONTAINMENT INTEGRITY i

PRIMARY CONTAINMENT INTEGRITY ensures that the release of radioactive mate- ,

rials from the containment atmosphere will be restricted to those' leakage paths !

and associated leak rates assumed in the safety analyses. This restriction, in conjunction with the leakage rate limitation, will' limit the SITE BOUNDARY' radiation doses to within the limits of 10 CFR' Part 100 during accident conditions.

3/4.6.1.2 PRIMARY CONTAINMENT LEAKAGE The limitations on primary containment leakage rates ensure that the total-containment leakage volume will not exceed the value assumed in the safety .

analyses at the peak accident pressure of 44.02 psig, . Pa. As an added conserva- l tism, the measured overall integrated leakage rate is further limited to less 1 than or equal to 0.75 La during performance of the periodic tests to account for. :

possible degradation of the containment leakage barriers between -leakage tests j Operating experience with the main steam line isolation valves has indicated that degradation has occasionally occurred in the leak tightness of the valves; therefore the special requirement for testing these valves.

The surveillance testing for measuring leakage rates is consistent with l the requirements of Appendix J of 10 CFR Part 50 with the exception of exemptions granted for leak testing of the main steam isolation valves, the airlock and TIP shear valves.

3/4.6.1.3 PRIMARY CONTAINMENT AIR LOCK The limitations on closure and leak rate for the primary containment > air :

lock are required to meet the restrictions on PRIMARY CONTAINMENT. INTEGRITY :

and the primary containment leakage rate given-in Specifications 3.6.1.1 and I 3.6.1.2. The specification makes allowances for the fact that there may be long periods of time when the air lock will be in a closed and secured ,

position during' reactor operation. Only one-closed door-in the air lock, ,

is required to maintain the integrity of the containment.

3/4,6.1.4 MSIV LEAKAGE ALTERNATE DRAIN PATHWAY '

Calculated doses resulting from the maximum leakage allowances for the. l main steamline isolation valves in the postulated LOCA situations will not exceed the criteria of 10 CFR Part 100 guidelines, provided'the main steam line system from the isolation valves up to and including the turbine condenser remains intact. Operating experience has indicated that degradation has occasionally-occurred in the leak tightness of the MSIVs such that the specified leakage requirements have not always been continuously maintained. The requirement for the MSIV Leakage Alternate Drain Pathway serves to reduce-the offsite dose. j l

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LIMERICK - UNIT 2 B 3/4 6-1

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ATTACHMENT 3 UMERICK GENERATING STATION UNITS 1 and 2 Docket Nos. 50-352 50-353 Ucense Nos. NPF-39 NPF85 TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 93-18-0

MSIV Leakage Alternate Drain Pathway Evaluation" - 12 pages l

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Attachment 3 1 Page1 MSIV LEAKAGE ALTERNATE DRAIN PATHWAY EVALUATION TABLE OF CONTENTS PAGE NO APPENDICES 2 EXECUTIVE Su MARY 3 I. PURPOSE 3 II. REFERENCES 3 III. SYSTEM DESCRIPTION 3 IV. EVALUATION OF SYSTEM OPERATIONAL REQUIREMENTS 4

A. FUNCTIONAL ADEQUACY OF SYSTEM 5 B. RADIOLOGICAL EVALUATION OF SYSTEM 6 C. SEISMIC EVALUATION OF SYSTEM / STRUCTURE

1. PIPING EVALUATION 6

2. TURBINE BUILDING EVALUATION 9.

3. INTERCONNECTED SYSTEM EVALUATION 10

4. MAIN CONDENSER EVALUATION 10 V. EVALUATION OF TESTING REQUIRED 11 VI. SUMARY OF IMPLEMENTATION ACTIONS REQUIRED A. PLANT MODIFICATIONS 11 B. PURT SOFTWARE CHANGES 11 VII. CONCLUSIONS 12

\

Attchment 3 Page 2 APPENDICES

1. Drawing of "MSIV Leakage Alternate Drain Pathway" (1 page) e

2. " CONTRIBUTION TO THE LOCA DOSE EXPOSURES FOR A MSIV LEAK RATE OF 100 SCFH PER STEAM LINE WITH TOTAL LEAKAGE OF 200 SCFH" (4 pages)

3. " Limerick Station Unit 2 MSIV Seismic Verification Walkdown Report,"

August 6, 1993. (15 pages) i I

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Attachment 3 Page 3 EXECUTIVE

SUMMARY

This evaluation has been performed to define the boundaries of and evaluate the design adequacy of the "MSIV Leakage A!tornate Drain Pathway". This pathway is being evaluated for replacing the design function of the Main Steam isolation Valve (MSIV)-Leakage Control System (LCS). The MSIV-LCS licensed based design function is to serve to redirect MSIV leakage back into secondary containment where it can be processed as a filtered release and reduce the potential contribution to off-site and control room dose. Historically, this system has been susceptible to numerous failures and very costly repairs. In addition, MSIV leakage has on several occasions exceeded the design capacity of the MSIV-LCS. In order to improve the performance of the power plant, both from a nuclear safety viewpoint and elimination of a high cost and high maintenance system, the "MSIV Leakage Afternate Drain Pathway" has been established which will serve to provide a more effective means to process the MSIV Leakage.

The evaluation demonstrates the functional and seismic adequacy of the pathway. The conclusion of the analysis is that with the recommended modifications installed the *MSIV Leakage Alternate Drain Pathway" will meet the design requirements estab!!shed and provide the necessary protection to mitigate the consequences of an accident.

l. PURPOSE:

The purpose of this document is to define and evaluate the adequacy of the Limerick Unit 2 MSIV Leakage Altemate Drain Pathway System. This system will be taking the place of the MSIV-LCS.

Currently, the MSIV-LCS and all associated components are designed, constructed and maintained as Seismic Category I. Furthermore,10CFR100 Appendix A, requires that all systems serving to mitigate the consequences of an accident will be seismically qualified. The designated pathway employs ,

systems, components, and structures which are not qualified as Seismic Category 1. This analysis will -

establish the design boundaries for the new system and evaluate the components, systems, and structures within those boundarles. Specifically, this analysis will evaluate and document the seismic adequacy of the new pathway, and the ability of the new pathway to function under the designated design conditions

11.

REFERENCES:

1. NEDC-31858P," BWROG Report for increasing MSIV Leakage Rate Umits and Eilmination of Leakage Control System," Revision 2, September,1993 i

2. EPRI NP-6041, "A Methodology for Assessment of Nuclear Power Plant Selsmic Margin,"

Revision 1, June,1991.

Ill. SYSTEM DESCRIPTION:

Appendix 1 of this document shows the Umerick Unit 2 MSIV Leakage Altemate Drain Pathway. As l specified in reference 1, the Alternate Drain Pathway establishes a seismic equivalent drain pathway which will serve to contain and direct leakage to the H.P. shell of the Main Condenser from the MSIVs during a Design Basis LOCA. This system will function to hold-up the potential release of fission products which is postulated to occur during a Design Basis LOCA.

Appendix 1 identifies the design boundades of the MStV Leakage Attemate Drain Pathway. The - l designated boundary (block) valves (HV-208, HV-209, HV-211, HV-250, Main Turbine Stop Valves (MTSV), and Main Turbine Bypass Valves (MTBV)) w!!! function to contain the MSIV leakage in the drain pathway. The boundary valves also identify the functional and design boundary of the "MSIV Leakage

Attachment 3 Page 4 Alternate Drain Pathway". All other lines which interface with the designated drain pathway, shown in appendk 1, wRI either be described below as a drain pathway, or lead back through Seismic Category 1/ilA piping back into containment (primary or secondary) and a s such do not represent potential leakage pathways.

There are four potential leakage pathways shown in appendk 1. These pathways are as follows:

1) Flow from all four Main Steam lines directly after the outboard MSIVs, through 2 inch EBD-205, into 3 inch EBD-208, into 4 inch EBD-208, discharging into the H.P. Condenser at elevation 211 feet. (This pathway is the primary pathway high!!ghted in red)

2) Flow from all four Main Steam lines directly before the Main Stop Valves through 1 inch EBB- i 201(2,3,4), into 2 inch EBD-214, into the start-up drain 2 inch EBD-214 discharging into the H.P. Co. denser at elevation 239 feet. (High!)ghted in blue)

3) Flow from all four Main Steam Lines directly before the Main Stop Valves through 1 inch EBB-201(2,3,4), into 2 inch EBD-214, into the operating drain 1 inch EBD-214, discharging into the H.P. Condenser at elevation 239 feet. (Highlighted in blue)

4) Flow from the above seat drain on the Main Stop Valves through 1 inch EBD *, into 2 inch 'i EBD-215 discharging into the H.P. Condenser at elevation 239 feet. (Highlighted in blue)

Although all four drain pathways are capable of directing leakage to the H.P. Condenser the only credited drain line is 1). This is based on the fact that the other drain lines are either not sized property to ensure adequate flow or require the opening of non-class 1E valves. The primary drain pathway has one normally closed valve in the line (HV-041-2F021). This valve will be required to be realigned to establish the drain pathway.

The remainder of the system shown in appendk 1, identifies the total system which was evaluated ,

during the seismic walkdown, and will be evaluated within this Design Analysis for "Selsmic Ruggedness" as specified in referece 1. It also should be noted that the system scope defined in this '

section has been reviewed and r4termined to be bounded by the walkdown scope defined in the EQE Seismic Walkdown provided as appendk 2. This closes open item a of the " Seismic Walkdown?

IV. EVALUATION OF SYSTEM OPERATIONAL REQUIREMENTS:

A. FUNCTIONAL ADEQUACY OF SYSTEM This section of the l>esign Analysis will evaluate the ability of the MSIV Leakage Alternate Drain Pathway to function under the conditions specified in reference 1, and where the current design of the system is inadequate to support the design requirements specified, a modification to the system will be identified. This portion of the Design Analysis will be from a functional system perspective, and will not include a seismic evaluation. The seismic evaluation is in section IV. C. of this document. As currently required for the MSIV-LCS and specified in 6.7.1.1.h of the Umerick UFSAR, all pathway valves will be required to be manually actuated and designed to permit actuation within about 20 minutes, but no earlier than 10 minutes, after a postulated design basis LOCA.

Reference 1 Identifies that all drain pathway valves required to be open will be supplied with Oass 1E power. As identified in Section Ill, HV-041-2F021 will require to be repositioned to establish the pathway, and therefore, will have to be supplied with Oass 1E power. Currently, ,

this valve is not supplied by Cass 1E power so a modification is required to supply Gass 1E '

power to the valve (see section VI.A.1). However, valve HV-C-2F020 is supplied with class 1 E i power and therefore, would be capable of being repositioned.

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Attachment 3 !

Page 5 Reference 1 identifies that all boundary valves be capable of being shut and/or fall shut during a Design Basis LOCA coincident with a Loss of Off site Power (LOOP). As shown in appendix 1, the boundary valves are HV-208, HV-209, HV-211, HV-250, MTSV, and MTBV. The motor operated valves (MOVs) (HV-208, HV-209, HV-211, HV-250) are all supplied with Class 1E power. Therefore, the MOV's current design is adequate to fulfill the required function specified in reference 1.

The hydraulically operated valves, the MTSVs and the MTBVs, are not powered from a Class 1E source, but are designed to faa shut in the event of a loss of power. All of these valves are opened by hydraulle fluid, and if the actuating fluid is removed either by system failure or automatic operation, the valves will shut. Therefore, the hydraulic valves current design is adequate to fulfill the required function specified in reference 1.

Based on the above discussion, we have concluded that the operator actions necessary to functionally align the system can be accomp!!shed within the required time frame. To ensure that the proper required actions are taken by the plant operators, plant emergency response procedures will be modified to incorporate the required changes to ensure the *MSIV Leakage Altemate Drain Pathway" is lined up within about 20 minutes of a Design Basis LOCA (see section VI.B.2). It should also be understood that the above review also resolves open items '

g, h, and I in the EOE Seismic Walkdown report provided as appendix 3.

B. RADIOLOGICAL EVALUATION OF SYSTEM The main purpose of the Alternate Drain Pathway is to ;,rocess the MSIV Leakage to prevent '

the limits of 10CFR100 from being exceeded. This ation of the Design Analysis will document the evaluation of the Umerick Unit 1 and 2 design and configuration for its ability to process the MSIV leakage and limit the total calculated dose to less than the requirements of 10CFR100.

In performing the radiological evaluation, two problems were identified which will require configuration changes to the plant. These two problems are described below:

1) Early in the evaluation of the system, it was identified that the current configuration of the MS drain system is that the H.P. Start-up drain lines, the H.P. Operating drain line, and the MTSV above seat drains are routed into the main condenser at elevation 239 feet. The dose model, demonstrated that this configuration will result in unacceptable doses, because the lines if opened during the event will result in the discharge of leakage at elevation 239 feet in the condenser which will result in the loss of a significant portion of the hold-up volume. Also considered in the evaluation was having these valves isolated. This would require the removal of a protective feature of the Main Turbine which prevents potential damage to the turbine from condensate intrusion. Therefore, it was determined that the three piping lines would be rerouted to elevation 211 feet for this system. This rerouting will require a modification to the plant. (See section VI.A.2)

2. Also identified in the evaluation of the radiological dose, is the fact that the valve HV-C-041-2F020, currently has an opening of only .5 inches diameter. This small opening results in relatively high dose rates due to the model assumption that there is a certain size opening in the MTSV's pathway which allows leakage to bypass the main condenser. To mitigate this problem, a modification will be performed on the HV-C-041-2F020 valve to change the intemals of the valve to increase the size of the opening to 1.687 inch diameter. (See section VIA3)

Attachment 3 Page 6 The calculated dose, using the radiological model identified in reference 1, from leakage of 100 scih per line not to exceed a total of 200 scfh total leakage are within the limits of 10CFR100 and GDC 19 and therefore, from a radiological perspective the

'MSIV Leakage Altemate Drain Pathway' is acceptable. A summary of the calculated doses for Umerick Units 1 and 2 is provided as appendix 2.

C. SEISMIC EVALUATION OF SYSTEM / STRUCTURE The purpose of this section of the Design Analys!s is to evaluate the 'MSIV Leakage Alternate Drain Pathway" for seismic adequacy as specified in reference 1. As previously identified, 10CFR100 currently requires that all systems which serve to limit the off-site dose shall be seismically qualified. Since the system being utilized is an existing system and to redesign the system to seismic category I requirements would be exceedingly costly, an alternate evaluation method has been utilized to demonstrate seismic adequacy. This alternate evaluation methodology is out!!ned in reference 1, which identifies four areas of review (Piping, Turbine '

Building. Interconnected systems, and Main Condenser). The methodology, and results of the evaluations of these areas are as follows:

1. PIPING EVALUATION:

a. Methodology:

In reference 1, a seismic database has been assembled by EOE Engineering Inc., which serves as historical documentation of the performance of non-seismic designed piping systems and main condensers at various power plants throughout the world which have gone through varying levels of seismic events. The ' Experience Database" as documented in reference 1 provides the basis for demonstration of selsmic adequacy of non-seismically designed systems. In order to demonstrate that the Umerick Unit 2 piping falls within the bounds of the " Experience Database

two reviews were performed. First, a review of the construction codes was performed to demonstrate that the designated piping was built to standards simi!nr to those for the plants identified in the ' Experience Database". Second, a " Seismic Walkdown" was performed by the developers of the " Experience Database' to ensure that the MSIV Leakage Alternate Drain Pathway piping design details are consistent with those good performing designs described in the " Experience Database".

In addition to the reviews describ6d above, a ' Margins Assessment

was performed on a sampilng of the attemate drain path. This ' Margins Assessment" was performed in accordance with the guidelines provided in EPRI NP-6041 (reference 2).

b. Eva!uation:

The Umerick Unit 2 piping has been evaluated to ensure it is within the bounds of the " Experience Database" presented in reference 1. The following documents the review and/or analysis performed to demonstrate the ' seismic ruggedness' of the piping identified in section Ill.

Attachment 3 Page 7 j i

As shown in appendix 1, the Main Steam piping up to and including all boundary vs!ves, except the Main Turbine Stop Valves (MTSVs) and the Main Turbine Bypass Valves (MTBVs), is currently Seismic Category I and will be maintained as Seismic Category I piping. Furthermora, the main steam piping has been evaluated and accepted by the NRC as described in Limerick UFSAR Section 3.2 Table 3.2-1 note (28). The fo!!owing is note (28):

"The main steam system from its outer isolation valve up to, but not including, the turbine stop valve and bypass valve chest, and all branch lines 2.5 inches in diameter and larder up to, and including, the first valve (including their restraints), will be designed by the use of an appropriate dynamic seismic-system analysis to withstand the OBE and SSE design loads in combination with other appropriate loads, within the limits r;pecified for Class 2 pipe in the ASME Section !!!

Code. The mathematical model for the dynamic seismic analyses of the main steam system and branch line piping includes the turbine stop valves and the piping from the stop valves to the turbine casing.

The dynamic input loads for design of the main steam system are derived from a history model analysis (or an equivalent method) of the reactor and appilcable portions of the turbine building. An elastic multl4egree-of freedom system analysis is used to determine the input to the main steam system. The allowable stress and associated deformation Ilmits for piping are in accordance with the ASME Section til Class 2 requirements for OBE loading combinations. The main steam system supporting structures (those portions of the turbine enclosure) are such that the main steam system and its supports can maintain their integrity."

Also shown in appendix 1, the remainder of the piping is either Seismic Category llA or 11.

In accordance with reference 1, a Seismic Walkdown was performed of the system defined in section 111 of this report. The Seismic Walkdown report is provided as appendix 3. The walkdown report identified four design anomalies considered to be "out!!ers" which are described and resolved as follows.

1. Several supports on Line 4" EBD-208 were identified as "outiler" supports. These supports are designed without lateral restraint to preclude the subject piping from falling off the support. The supports will be modified to provide adequate lateral restraint. This modification is identified in section VI.A.4.

2. A " beam clamp" support on line 2" EBD-214 was identified as an "outiler". Upon further review, PECo has determined that this " beam clamp" is not identified as a piping support in any "As-Bu!!t" drawings, or credited in piping calculations. This "outiler" has been identified as a non-conformance, and will be removed.

I Attachment 3 l Page 8 l l

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3. The main steam line adjacent to valve HV-204 has been '

identified as a potential seismic interaction point. The concem '

identified is that during an SSE, this portion of the Main Steam line going to the moisture separators will move sufficiently to impact HV-204 possibly impacting the integrity of the system or the functioning of HV-204. To resolve this issue the ,

following is being performed.

a. A calculation has been performed to determine the l maximum displacement of the main steam piping which wl!! give a minimum clearance between the Main :

Steam Une and the valve. This minimum calculated !

clearance is 5.1 inchas.

b. Based on the measured clearance, which only can be measured during a shutdown of Unit 2, PECo will develop contingency plans to relocate the drain piping and valve to eliminate the seismic interaction concem.

4. The pressure averaging manifold, between the four main steam lines, needs to be reviewed to ensure that the proper connections are made for positive attachment to the Main Steam Une. PECo and EQE have verified the "As-Built" configuration and determin6d that the current configuration, which is seismic category 1, is acceptable. .

As described before, a ' Margins Assessment

of the Umerick Unit 2 piping was performed. The assessment demonstrates that the Main Steam Drain Une design provides adequate margins when subject to dead weight and seismic loads to provide a reasonable assurance that position retention of the line will be maintained. In performing this assessment two of Umerick's drain lines were chosen (4 inch EBD-208 and 2 inch EBD-214). These lines were chosen to provide a representative sample of the non-seismic piping in the MSIV Leakage Attemate Drain Pathway which are both limiting in that the portion of the lines chosen have the greatest distance between supports, and are ;

representative in that they evaluate the two types of supports ut!!! zed in designated piping systems.

The methodology utilized to demonstrate the margins inherent in the piping support designs is the Conservative Deterministic Failure Margin (CDFM)

Selsmic Margins. This methodology le described in detail in reference 2 and utillzes a deterministic approach to margins assessment with the following basic steps: 1) The Earthquake Response Spectrum is Conservatively Defined as 84% Non-Exceedance,2) The Estimated Structural and Piping Response is Median Centered.,3) The Component Support Capacity is Conservatively i Estimated. This combination of conservatively defined seismic demand, median centered response to seismic demand and conservative estimate of capacity is considerod to result in a High Confidence of Low Probabl!!!y of .

Fa!!ure (HCLPF) which provides the reasonable assurance of performance desired.

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l Attachment 3 l Page 9 i The evaluation found that the lowest HCLPF was above 0.4g, which is greater than the 0.15g Design Basis Earthquake peak ground acceleration for the plant.- This provides a reasonable assurance that position retention of the line will be maintained. It should be noted that the calculation was performed assuming the applicable modifications identified in section V.A. have been performed.

Once the identified modifications are performed, the margins assessment in ,

conjunction with the "Selsmic Walkdown" provide reasonable assurance that supports will behave in a ductile manner, that the lines are free of known .

seismic hazards, and has demonstrated that the Limerick design will perform in a manner similar to piping and support which have observed good seismic '

performance in past strong ground motion earthquakes.

2. TURBINE BUILDING EVALUATION: ,

in the LGS Updated Final Safety Analysis Report (UFSAR) section 3.7.2.8 is a description of the analysis performed for the Turbine Building as part of the original !

licensing of LGS. This evaluation identifies the following in support of the adequacy of the Turbine Building to withstand an SSE:

"In addition, the turbine enclosure was dynamically analyzed to ensure the capacity to withstand a SSE without collapsing on or impairing the integrity of the adjacent reactor and control structures."

Also in section 3.2 of the UFSAR table 3.2-1 note (28) the following is identified:

"The main steam system supporting structures (those portions of the turbine enclosure) are such that the main steam system and its supports can maintain their integrity."

The piping systems identified in section til of this evaluation are located in the lower elevations of the Turbine Enclosure, further protecting the systems from any potential damage from the structure.

In addition to the UFSAR analysis of the Turbine Building and structure, the Seismic Walkdown also evaluated the adequacy of the civil and architectural plant features surrounding the piping identified in appendix 1. One discrepancy was noted as follows. -

a. The block wall adjacent to the main steam pressure transmitters should be reviewed to ensure the wall w!!! not fall during an SSE.

PECo has performed an evaluation of the Block Wall structure and determined ;

that the current structure is acceptable "as-is."

Based on the above information and analysis, it is the conclusion of this portion of the analysis that the Turbine Building structure wl!! not fall in such a way during or following an SSE such that it would cause damage to or prevent the "MSIV Leakage ,

A!!ernate Drain Pathway" from performing its design function. !

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3. INTERCONNECTED SYSTEM EVALUATION:

As shown in appendix 1, the Altemate Drain Pathway will rely on systems which are )

connected to the piping. Also as shown in appendix 1, with the exception of the !

MTSVs and the MTBVs, all boundary valves credited for operation are Selsmic 1 Category I and will be maintained Seismic Category 1, therefore, they meet or exceed .l the design requirements specified in reference 1. The MTSVs and the MTBVs although not Selsmic Category I have been previously evaluated and documented in the LGS UFSAR to be capable of functioning during and following an SSE. Section 3.2 Table 3.2-1 Note (29) and (30) specifies the following.

"(29) The following qualification has been met with respect to the certification requirements:

A. The manufacturer of the turbine stop valves, turbine control valves, turbine bypass valves, and main s'eam leads from 1 turbine control valve to turbine casing has used quality control procedures equivalent to those defined in GE Publication GEZ-4982A, " General Electric Large Steam Turbine-Generator Quality Control Program."

B. The manufacturer of these valves and steam leads has certified that the quality control program so defined has been accomplished.

(30) This section of the steam piping (note (30) is applicable to MTSV and MTBV) was seismically analyzed to ensure that it w!!! not fall under loading normally associated with an SSE.*

Based on the fact that the interconnected systems are either currently Selsmic Category 1, have been evaluated in the Selsmic Walkdown, or have been previously evaluated and accepted by the NRC as not fal!!ng during an SSE, it can be concluded that the interconnected systems identified in Section til are capable of functioning to support the operation of the "MSIV Leakage Altemate Drain Pathway" during and following an SSE.

4. MAIN CONDENSER EVALUATION:

a. Methodology To ensure the Main Condenser falls within the scope of the " Experience Database," PECo has performed an evaluation. This evaluation performed the fo!!owing: 1) Condenser capacity and demand parameters were compared to the " Experience Database" contained in reference 1,2) A simple static anchorage review was performed to estimate the anchorage capacity for seismic loads, and 3) Seismic capacity is compared to seismic demand to estimate the HCLPF capacity using seismic margin methods provided in reference 2.

Attachment 3 Page 11

b. Evaluation The Umerick Condenser has been demonstrated to fall well within the bounds of the " Experience Database." Second, the Umorick Condensers anchorage provides significantly greater

Resistance to Seismic Demand" than those in the

Experience Database," and the condenser anchorage has a HCLPF greater than 0.25g which exceeds the 0.15g design basis SSE.

Based on the evaluations discussed in this section and considering that the identified changes are implomonted, it is the conclusion of this portion of the analysis that the "MSIV Leakage Altemate Drain System" provides a reasonable assurancc of functioning per the design requirements of reference 1 during and following an SSE.

V. EVALUATION OF ADMINISTRATIVE CONTROLS / TESTING REQUIRED:

As specified in reference 1, the *MSIV Leakage Alternate Drain Pathway" will require testing under the In-Service Testing (IST) program. Therefore the following testing will be required:

1. Valve HV-041-2F021, will require to be stroked every quarter (see section VI.B.1). For valve HVC041-2F020, it is determined that no periodic valve stroking is required since its normal operating and safety position is open and therefore, should not need to be repositioned during an accident.

2. Valves HV-208, HV-209, HV-211, and HV-250 will require to be stroked on a cold shutdown frequency. These valves will only require cold shutdown testing based on the fact that when stroked the valves will cause a significant change to the plant during power operation (i.e., cycling the HV-208 would result in the loss of all Reactor Feed Pumps) (see section VI.B.1).

VI.

SUMMARY

OF IMPLEMENTATION ACTIONS REQUIRED:

A. PLANT MODIFICATIONS:

1. Currently, valve HV-041-2F021 is not supplied by class 1E power. A modification will be required to supply class 1E power and control power to this valve.

2. The H.P. Operating Drain line (1 inch EBD-214), MTSV Above Seat Drain Une (2 inch EBD-215), and the Start-up Drain Une (2 inch EBD-214) will be rerouted from elevation 239 feet penetration into the Main Condenser to at or below elevation 211 feet penetration to the Main Condenser.

3. The intemals of valve HV-C-041-2F020 w!!I be changed to increase the size of the opening.

4. Piping supports for 4 inch EBD-208 will all be modified with restraints which will prevent potential damage to the piping from lateral movement.

i Attachment 3 I Page 12 B. PLANT SOFTWARE CHANGES:

1

1. Tests will be written for stroke testing both the boundary valves and the single flow l pathway valve.

2. Plant Emergency Operating Procedures will be revised to specify that the actions required to establish the *MSIV Leakage Altemate Drain Pathway." The changes will ensure that the system is lined up within 20 minutes of a Design Basis LOCA. This will - ,

also include an evaluation by the dose assessment personnel.

Vil. CONCLUSIONS:

P Based on the above analysis, once all modifications and procedure changes have been performed it is the conclusion of this evaluation that the Limerick Unit 2 "MSIV Leakage Altemate Drain Pathway,"

identified in appendix 1, meets the design requirements (i.e., Functional Adequacy, Radiologically, Seismically, and Operational) as established in reference 1 and meets the intent for seismic ;

qualification as specified in 10CFR100 Appendix A.

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t-APPENDIX 1 LIMERICK GENERATING STATION UNITS I and 2 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 93-18-0

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'i APPENDIX 2 LIMERICK GENERATING STATION UNITS 1 and 2 Docket Nos. 50-352 50-353 License Nos. NPF-39 6 NPF-85 i

TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 93-18-0

" Contribution to the LOCA Dose Exposures for a MSIV Leak Rate of 100 per Steam Line with Total Leakage of 200 scfh"- 4 pages a

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e - m - - - - - - - - - - _ - - . - - - - . - - - - - -

4 TABLE 1 l

CONTRIBUTION TO THE IDCA DOSE EXPOSURES FOR A MSIV LEAK RATE'0F 100 scfh PER STEAM LINE WITH TOTAL LEAKAGE OF 200 SCFH LIMERICK 1 GENERATING STATION ,.

Whole 't Body Thyroid Beta

~

(rem) (rem) (tem) l Exclusion Area A) 10CFR 100 Limit 25 300 * ,

Boundary (2-Hour) B) Previous Calculated 0.67 0.15 -

Doses **

C) Previous Calculated 0.67 0.15 ' ****

Doses w/o MSIV Leakage i D) Contribution From 0.001 0.02 MSIVs at 200 scfh l E) New Calculated Doses 0.67 0.17 Low Population A) 10CFR100 Limit 25 300

I Zone (30-Day) '

B) Previous Calculated 1.7- 0.04 Doses **

C) Previous Calculated- 1.7 0.04 **** ;

Doses w/o MSIV Leakage 1

D) Contribution From 0.14 36.37 MSIV at 200 scfh - (

E) New Calculated-Doses 1.84 36.41 Control Room A) GDC-19 5 30 30/75*** l (30-Day) ;

B) Previous Calculated 0.38 0.004 7.6 ;

Doses **

C) Previous Calculated 0.38 0.004 7.6**** ,

Doses w/o MSIV Leakage D) Contribution From 0.05 6.27 0.60 MSIVs at 200 scfh q E) New Calculated Doses 0.43 6.27 8.2 .

No-limit specified. :

- UFSAR Section 15.6, Tabic '5.6 20, and Table 15.6-22

- - 75 if prior commitment has been made to use protective clothing.

- - - Contribution of MSIV leakage to FSAk doses are unknown; and, therefore,. .

are conservatively assumed to Le zero. !

TAG 33/964-09

. . - , . . ~ -

- l

n. i TABLE'2-CONTRIBUTION TO THE LOCA DOSE' EXPOSURES FOR A MSIV ;

< LEAK RATE OF 100 scfh PER STEAM LINE WITH TOTAL LEAKACE OF 200 SCFH LIMERICK 2 CENERATING STATION ,

Whole f Body Thyroid Beta ,

(rem) (rem) (rem)

Exclusion Area A) 10CFR 100 Limit 25 300 *

. Boundary (2-Hour) B) Previous Calculated 0.67. 0.15 :

Doses ** .q C) Previous Calculated 0.67 0.15 ****

Doses w/o MSIV Leakage i D) Contribution From 0.001 0.02 MSIVs at 200 scfh i E) New Calculated Doses 0.67 0.17 Low Population A) 10CFR100 Limit 25 300

Zone (30-Day) 1 B) Previous Calculated 1.7 0.04 .j Doses **

i C) Previous Calculated 1.7 0.04 ****

Doses w/o MSIV Leakage .;

5 D) Contribution From 0.14' 36.44' MSIV at-200 sefh -

. E) New Calculated Doses 1.84 36.48 Control Room A) GDC-19 5 30 30/75*** ,

(30-Day)

B) Previous Calculated 0.38 0.004' 7.6 ;

Doses **

C) Previous Calculated 0.38 0.004 7.6**** .

Doses w/o MSIV Leakage .

D) Contribution From 0.05 6.29 0.60 MSIVs at 200 scfh !

E) New Calculated Doses 0.43 6.29 8.2

'* No limit specified.

- UFSAR Section'15.6, Table 15.6-20, and Table 15.6-22 -

- - 75 if prior commitment has been_ made to use protective clothing. ,

- - - Contribution of MSIV leakage to FSAR doses are unknown; and, therefore, are conservatively ~ assumed to be zero. ,

TAC 33/964-09 ,

, . . . . . . . ..-; . . . . ~

l TABLE'3 BWROG MSIV . LIMERICK.1 DOSE CALCULATION Contributions of MSIV Leakage to Offsite and Control Room Radiological Doses I

CONTROL ROOM OFF-SITE (LPZ)

MSIV Leakage at Whole Whole 100 sefh per line Body Thyroid BETA Body Thyroid ;

(Total of 200 scfh) (5) (30) (30-75) (25) (300) '

Noble Gas (DL) 0.05 0.00 0.60 0.12 0.00 W Irsrganic I (DL) 0.00 0.03 0.00 0.00 0.17 Organic I (DL) 0.00 3.70 0.00 0.01 20.90 Noble Gas (HPT) 0.00 0.00 0.00 0.00 0.00 Inorganic I (HPT) 0.00 0.00 0.00 0.00 0.00 Organic I (HPT) 0.00 0.01 0.00 0.00 0.06 ,

Organic I via 0.00 2.53 0.00 0.01 15.24

]

Re-suspension / l

[

Conversion (DL)

TOTAL 0.05 6.27 0.60 0.14 36.37 EAB Doses are: 0.001 0.02 l

1 - Iodine, DL Drain Line Path, HPT - High-Pressure Turbine Path I

i L

i TAG 33/964-09 .

. ._ . . _ _ _ --_ ~ . _ . . . ~ . . . . _ _

TABLE 4 i

BWROG MSIV - LIMERICK 2 DOSE CALCULATION (FINAL)

Contributions of MSIV Leakage to Offsite i and Control' Room Radiological-Doses ;

j i

CONTROL ROOM OFF-SITE (LPZ)- :

MSIV Leakage at Whole Whole ;

100 scfh per line Body Thyroid BETA Body Thyroid (Total of 200 scfh) (5) (30) (30-75) (25) (300)

Noble Gas (DL) 0.05 0.00 0.60 0.12 0.00 ;

Inorganic I (DL) 0.00 0.03 -0.00 0.00 0.16 Organic I (DL) 0.00 3.70 0.00 0.01 20.90 l Noble Gas (HPT) 0.00 0.00 0.00 0.00 0.00 Inorganic I (HPT) 0.00 0.00 0.00 0.00 0.00 ;

Organic I (HPT) 0.00 0.01 0.00 0.00 0.06

]

i Organic I via 0.00 2.55 0.00 0.01 15.32 Re-suspension /

Conversion (DL)

TOTAL 0.05 6.29 0.60 0.14 36.44 .;

g i EAB Doses are: 0.001 0.02 .

I -' Iodine, DL - Drain Line Path, HPT - High-Pressure Turbine Path ,

' i I

TAG 33/964-09 !

+ ;

F" 1

APPENDIX 3 LIMERICK GENERATING STATION UNITS I and 2 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST' No. 93-18-0

" Limerick Generating Station Unit 2 MSIV Seismic Verification Walkdown Report" - 15 Pages

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. CONSULTANTS -

1 k .< LIM 5 RICK STATION .

b . '- MSIV SEISMIC VERIFICATION

~ WALKDOWN REPORT 7 -

6

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August 6,1993

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Prepared for:

1 PHILADELPHIA ELECTRIC COMPANY l

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e EQE ENGINEERING CONSULTANTS

A Ditision of EQE. international -

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j 50106-R-001 Revision O Page 1 of 15 h

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l LIMERICK STATION N1 L' MSIV SEISMIC VERIFICATION g

I WALKDOWN REPORT '

August 6,1993 1 l

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Prepared for:

PHILADELPHIA ELECTRIC COMPANY Chesterbrook Corporate Center 965 Chesterbrook Boulevard

t. , Wayne, Pennsylvania 19087-5691 l

d EQE Project Number: 50106.01 l

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Revision 0 Page 2 of 15 l APPROVAL COVER SHEET 4 ENGINEERING Umerick Station MSIV Seismic Verification Walkdown Report Report Number:

Philadelphia Electric Company Client:

MSIV Leakage issue Project:

W REVISION RECORD Revision Approval Number Date Prepared Reviewed Approved 0 08/06/93 pgr7 h

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3 50106-R-001 Revision O Page 3 of 15 El M4

- TABLE OF REVISIONS ina,sa:a: e :Sawwwse _

ts : .

O initial issue August 6,1993 E

E E

E N

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50106-R-001 Revision O l- Page 4 of 15 TABLE OF CONTENTS

[

Paae Background.................................................................................. 5 Scope ....... ...... ...... ................................. ................................. 5 Waikdown.................................................................................. 6 DrainPath......................................................................... 7 M a i n S t e a m Li n e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1O m

Mai n St e a m Bypa s s Li n e s . . . . ... . . . . . . . . .. .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Openitems.............................................................................. 12

~

FIGURES E..

1. Line 4 EBD-208 has several supports that have no provisions for 4 latera1 motion............................................................................. 14

2. Line 2" EBD-214 has a questionable support detail for seismic loads ... 14

3. The motor operator for valve HV-204 in close proximity to a I a r g e s t e a m li n e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4. Main steam pressure transmitters and associated instrument lines are located near a block wall enclosed battery room ........................ . 15 K

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50106-R-001 Revision 0 1 Page 5 of 15 t

BACKGROUND This report describes the work performed for supplemental plant specific Main Steam Piping Seismic Verification. This walkdown was performed in accordance with the recommendation of the General Electric BWR Owners Group Report for increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems.

i !

SCOPE l The walkdown scope included the drain path that will be established to convey any leakage past the outboard Main Steam isolation Valves (MSIV) to the condenser; including piping, instrumentation, valves and equipment that would be required to maintain the seismic verification boundaries. The drain path and seismic verification boundaries were defined by Philadelphia Electric Company engineers to capture the

. following portions of the main steam system beyond the outboard MSIVs:

1. The candidate drain paths to the condenser for any lcakage past the outboard MSIVs, including the main steam starwp

! drain, operating drain and steam tunnel drain.

2. Main steam piping from the outboard MSIV to the Main Stop Valves (MSV).

3. Main steam bypass piping from the main steam lines to the bypass valve chest.

4. Additional piping and instrumentation within the above seismic verification boundaries, such as HPCI and RCIC drain lines, and MSV above seat drains.

Several of the seismic verification boundaries were defined by valves that were assumed to be capable of isolation following an SSE, either by fail safe design, automatic operation by e reliable power source (such as 1E power), or manual valves operated by a reliable source with hand switches in the control room. Design documents and operating procedures should be reviewed to confirm that the automatic or manual actuations required to position the valves to establish the seismic verification boundary will be accomplished following an SSE.

The scope of the seismic adequacy walkdown included design conditions which could result in induced pressure boundary failure and inventory release and include 8 50106 01/Umenck 3p rp Ed d C

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Revision 0

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i support failure, falling of non-seismically designed plant features (ll/l), proximity

] impact, and differential seismic anchor motion of structures, piping or equipment.

The scope and extent of these conditions are described in GE NEDC-31858P.

'I J WALKDOWN 3

A field walkdown of the drain path, main steam lines and associated appendages 1 within the seismic verification boundary was conducted during the week of March 8, 1993 by Steven Harris and Thomas Roche. Plant specific guidance and technical support were provided by Kenneth Hudson and Douglas Keene from Philadelphia J

Electric Company. The piping systems reviewed were designated as Seismic Category 1, llA or 11 requirements, as depicted by class breaks on the P&lDs.

1 l Category i piping was considered to be designed and constructed in accordance with programmatic design controls in order to meet the requirements of Regulatory Guide 1.29.

Category I motor operated valves and associated power and controls were also considered as satisfactory insofar as Regulatory Guide 1.29.

l h

K llA Seismic Category llA piping greater than 2 inches in diameter was considered to be designed and constructed in accordance with the same design criteria as category I piping, however, not necessarily functional after SSE design loading accelerations 1

(Non-Safety-Related). Seismic Category llA piping 2 inches in diameter and under were reviewed to verify they will not affect plant safety features.

l-ll Seismic Categcry 11 piping is Non-Safety-Related; not normally

] designed for seismic accelerations. Seismic Category 11 components and structures are not normally designed for

seismic accelerations other than those specified in the Uniform

,j Building Code.

I 1 The objective of the walkdowns was to review the main steam system drain path J from the outboard MSIVs to the condenser to identify piping system anomalies that may lead to loss of the system pressure boundary during an SSE. As part of the review, potential seismic interaction issues that could lead to damage of the system l - were identified.

l b

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50106-01/umerick h ==

1 50106-R-001 7 Revision 0 Page 7 of 15 E Major structures and components such as the turbine building and condensers should be reviewed in order to ensure the integrity of the drain path, as well as ]

piping and equipment within the seismic verification boundaries, are not !

k compromised Structures and major components were not reviewed during the f l

walkdown since the activities are better suited for structural review based on design documents, rather than field reviews.

The field review was performed by walking down the in-scope systems using P&lDs, piping isometrics and layout drawings; as well as a brief review of pertinent

[ programs such as seismic interaction reviews. The walkdowns focussed on Seismic

]

} Category 11 lines, however, Seismic Category I and liA lines were walked by to identify any anomalies that may have gone undetected during previous design, construction and operations.

Walkdown observations are summarized below for the drain paths, main steam lines, main steam bypass lines, and additional lines within the seismic verification boundaries. Issues that should be further investigated are designated PS-X and SI-X for Piping and Support issues and Systems interaction issues, respectively. The identifier X is a sequential number beginning with 1.

Drain Path Two candidate drain paths were under consideration by Philadelphia Electric when the walkdowns were performed. The two candidate paths, hereafter identified as path 208 and path 214, are intended to convey any MSIV leakage to the condenser.

Path 208 Path 208 originates in the steam tunnel just downstream of the outboard MSIVs and terminates at the high pressure condenser. Lines

~

within the steam tunnel are Seismic Category I up to valve HV-C-2F020, and Seismic Category llA up to the Turbine Building, Piping whhin the Turbine Building is Seismic Category 11. Path 208 is outlined below:

= Drain lines 2" EBB-205 and 3" EBB-205 from the main steam headers downstream of the outboard MSIVs to common drain header 3" EBD-208.

E 4 50106 o1/Umeri:k

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50106-R-001 Revision O Page 8 of 15

= Line 3" EBD-208 from the above lines and line 4" EBD-l 1 208 (in series) to high pressure condenser penetration 88.

The Seismic Category I and ilA portions of path 208 are, as expected for seismically engineered lines, well supported with no anomalies I

3 were observed. Line 4" EBD-208, however, requires further review j since many of the deadweight supports rely on friction for resistance to lateral loads.

PS-1 Line 4" EBD-208 located in the turbine building has l several cantilever bracket or stanchion supports near the I

i condensers. Several supports in series are designed for I dead weight only, and have no provisions to preclude the pipe from sliding off the supports. Seismic Category 11 portions on line 208 are shown on isometric drawings EBD-208-2 and EBD-208-3 from support number EBD-3 208-H901 to condenser penetration 88. Of the 15 supports between 901 and the condenser; 2 supports are designed to provide lateral restraint; 4 supports are

.i flexible (rods and/or springs with positive clevis l attachment); and 9 supports, including 6 in series, are designed such that pipes may slide and fall off due to l, lateral displacement. At support HBD-208-H15 it appears that the pipe has slipped off the support,

. however, insulation prevented a detailed inspection (Figure 1). The line should be reviewed in detail to determine if thermal and seismic movements if it is to g be relied on as a drain path. Modifications may be El required to restrain lateral movement.

g The path 208 drain line runs through areas that are congested with mill , numerous other lines of varying sizes and flexibility, thus, seismic interactions such as pipes swinging into stationary appurtenances (such as handrails) and into each other may occur during an SSE. The l.

impacts would be minor resulting in only superficial damage (such as

1. . denting of insulation) and the interactions were judged not to compromise the integrity of the system.

I

}

i,

,E M. E a

l 50'i O 6-R-001 Revision O Page 9 of 15 Path 214 Path 214 originates from the main steam lines in the turbine building l just upstream of the Main Stop Valves (MSV), and terminates at the high pressure condenser. The path is seismic category 11 downstream

? of the main steam lines and serves as the startup and operating drains to the condenser. Path 214 includes the following lines:

= Lines 1" EBB-201,1" EBB-202,1" EBB-203 and 1" EBB-204 from their respective 26" main steam lines to main steam drain line 2* EBD-214.

= Main steam drain line 2" EBD-214 from the above lines

,' to high pressure condenser penetration 36 (startup drain to HP condenser).

= Drain line 1" EBD-214 from line 2" EBD-214 to high .

pressure condenser penetration 37 (operating drain to HP condenser).

One piping anomaly and one potential seismic interaction issue were observed during the path 214 walkdown.

.. PS-2 Line 2" EBD-214 has a support detail which relies on friction for seismic load resistance (Figure 2). A support is attached to the structure with a beam clamp, 4 however, the beam clamp support appears to be redundant since all supports included on the isometric drawing are installed. A review of piping and support design drawings should be reviewed to determine the purpose of the support, and if required, positive connection should be provided.

Sl-1 A potential seismic interaction issue was observed near the startup and operating drain condenser penetrations.

At the 2" EBD-214 branch to 1" EBD-214, the 1" line passes over the top of a large steam line and the 2" line runs just below the steam line, with the motor operator for valve HV-204 in close proximity to the steam line (Figure 3). Displacement of the steam line, which terminates at a suspended moisture separator, could impact va!ve HV-204 and/or the 214 drain line and t

50100 01/Umenck g l W$${

1

50103-R-OO1

Revision O Page 10 of 15 f impose high nozzle loads at the condenser penetrations.

The interaction may be credible if significant displacements of the attached moisture separator are ,

' , possible, if the lines penetrate the condenser at the 7 flexible diaphragm (many condenser shells have a relatively thin steel diaphragm to account for thermal expansion of the tubes), or if valve HV-204 is required to operate in order to establish the drain path.

Main Steam Lines

- Main steam lines were reviewed from the outboard Main Steam isolation Valves (MSIV) to the MSVs; including associated instruments and test connections. The main steam line review included the following lines:

= Lines 26" EBB-201,202,203 and 204 from the MSIVs to the MSVs.

= Line 6" EBB-201 from line 26" EBB-201 to valve HV-208.

Line 4" EBB-204 from line 26" EBB-204 to valve HV-250.

= Line 6" EBB-204 from line 26" EBB-204 to valve HV-211.

= Pressure averaging manifold 4" EBB-239, including lines 1" EBB-239 from each of the four 26" steam lines to the manifold.

= Several supports beyond the seismic verification boundaries were also included in the review to identify any issues that

. could affect the pressure boundary.

The above main steam lines are Seismic Category 1, excluding the pressure averaging

. manifold which is designated Seismic Category llA. No piping system or support concerns were observed during the field review, however, a support detail for the pressure averaging manifold was considered unique, and connection details could not be verified in the field due to insulation. Verification of positive connection is

, listed below for follow-up review.

"~

PS-3 A support detail for the pressure averaging manifold includes a member between the main steam line and the manifold.

N--e 4 5010641/Umenck S

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50106-R-001 j, Revision O Page 11 of 15

[, Positive connection (such as welds) to the main steam llne should be verified to ensure the support can resist lateral loads.

l System interaction observations noted during the main steam line review included the potential for impact of the pressure averaging manifold on an adjacent member, a flexible cable tray located within a few inches of stainless steel tubing and 4

pressure transmitters located adjacent to a block wall. The pressure averaging manifold was not considered significant since the postulated minor impact would only dent insulation. The cable tray is located several inches from the tubing such 1 that impact, if any, would not compromise the pressure boundary. The battery room

! concrete wall may, however, be a significant issue and should be further evaluated.

SI-2 Pressure transmitters PT-201 A, PT-201 B, PT-203A, PT-203B, je and PT-B21 and/or associated instrument lines are located near a block wall enclosed battery room (Figure 4). Failure of the block wall could impact the transmitters and/or instrument lines and compromise the pressure boundary of the system. A 3

review of the block wall construction and/or restraint details j should be performed to determine if the wallis capable of withstanding seismic loads.

al9' Main S_Leam Bvoass Lines Main r a bypass lines 14" EBB-206,18" EBB-206,14" EBB-207, and 18" EBB-4 207 were reviewed from the main steam lines to the main steam bypass valves, l

including branch line 6" EBB-207 to valve HV-209. Several supports beyond the

! h, bypass valves and valve HV-209 were also included in the review to identify any I issues that could affect the pressure boundary.

The piping system is Seismic Category I and, based on field observations, supported accordingly. One potential systems interaction issue was observed:

SI-3 A valve located in the hydraulic fluid supply line between the check valve and the accumulators is located within about 1/4" of a handrail support. Displacement of the bypass valve chest

in the direction towards the condenser could result in impact, and potentialloss of hydraulic fluid pressure. The system i should be investigated to determine if loss of hydraulic pressure in the accumulators would prevent the valves from closing. If pressure is required, trimming of the handrail members may be j required to resolve the issue.

h 50106 01/Umerick m 0: . ' .

N

J 50106-R-001 f Revision 0 Page 12 of 15 Additional Lines Within the Seismic Verification Boundaries Additional lines within the seismic verification boundaries includes the HPCI and RCIC drain lines, and MSV above seat drains.

~

= Line 2" EBD-215 from the MSVs to high pressure condenser penetration 21 (MSV above seat drains).

= Line 1" EBD-205 from valve HV-2F026 to line 4" EBD-208.

= Line 1" EBD-206 from valve HV-2F029 to line 4" EBD-208.

Additional piping reviewed includes Seismic Category I and Seismic Category llA portions located within the rea: tor enclosure (including the steam tunnel), and Seismic Category 11 piping located within the turbine building. The additional piping located outside of the reactor enclosure is Seismic Category 11 and supported in accordance with ANSI B31.1. No significant piping and support, or systems interaction issues were observed for the additional lines.

1 OPEN ITEMS The Limerick Generating Station Unit 2 main steam and associated piping within the seismic verification boundaries were observed to be generally well supported and, f, with a few exceptions, free of credible seismic interaction issues. The following issues should be investigated and resolved in order to complete the walkdown phase j of the review.

l ,

j a. The drain path and seismic verification boundaries should be j established and compared to the walkdown scopa that was based on preliminary information.

b. Line 4" EBD-208 should be reviewed and upgraded (as gl' required) to ensure the pipe will not fall off of it's deadweight 3, supports during an SSE (PS-1).

i:

1I c. The " beam clamp" support on line 2" EBD-214 should be

further investigated to determine if it is required (PS-2).

d. The main steam line adjacent to valve HV-204 should be p- investigated to determine if postulated movements during an fI SSE would adversely affect the EBD 214 pathway valve and ,

nearby condenser penetrations (SI-1). l i

l 1 .

I 50106-01/bme ick -2 a h%

c

i sm L1 --

J

50106-R-001 Revision O Page 13 of 15

e. Pressure averaging manifold supports should be reviewed to identify positive attachment to the main steam lines (PS-3).

~

f. The block wall adjacent to the main steam pressure transmitters should be reviewed to ensure the wall will not fall durirng an SSE (Si-2).

g. Control logic should be investigated to determine if the main It steam bypass valves require hydraulic fluid to close following

- an SSE. If fluid is required to operate, interaction of a hydraulic valve and handrails shot:M be investigated (SI-3). _

h. The MSV control logic should be reviewed to ensure the valves l, will automatically close following a turbine trip without supporting systems (such as external hydraulic fluid).

i. Motor operated valves that establish the seismic verification boundary should be reviewed to verify that reliable power (such as 1E) and controls would be avaliable following an SSE.

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L 50106 4 001 Revision 0

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Page 14 of 15 p.g y

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Figure 1 ,

Line 4" EBD-208 has several ;. .

M supports that have no provisions for . c. ,

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lateral motion. The line may fall off a s . af,,d.a it's supports during an SSE yg ;

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Figure 2:

Line 2" EBD-214 has 3 cuestionable support detail for seismic loads. A supocrt is attached to the structure with a beam clamp.

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50106-R-001 Revision 0 Page 15 of 15 4' ]

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3 a 0 3 ,.,. .

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t Rgure 3: The motor operator for va:ve i HV-204 in close proximity to e large steam line,

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"" Figure 4: Main Steam pressure transmitters and associated instrument

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lines are located near a block well enclosed battery rocm. --

8 5 310 6 01.'Leme >:: k

lI 50106-R-001 l7 Revision O i

Page 14 of 15

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I; 1 Lua 4" EED 205 has severa ) l *

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- g g %Mfar 6t suppcris that have no provis.ons for . q p;'7+- <

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lateral rnation The Une rnay f a:! cf f Mo 2 M:.'iWW it's supports dunng an SSE i,ySC~b

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AWy, kg ; ' % o,,1.s ,WM = -1 M , - r W&& dis =2%a.2k. .

I F:gure 2- Line 2* ESD-214 has 3 otestionable support detail for seismic loads. A supocri is attached 'O the s+ructure with a beam clamp.

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l' 50106-R-001 l Revision O l Page 15 of 15 j$hj(.y.Q'O I n:'[ .:QhyT?'\S j

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HV-204 in c!csc pr ' ::c" t , "f 2 y J+ M@ Y ..- ..

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Figu< 4- f.1a:n Steam pressure transmitters and associated instrument i nes are loca+cd nor a Uock ./,11 enclosed t:attery recm.

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ML20059K583

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