ML20076D995

Forwards Response to 830307 Request for Clarifications & Addl Info Re FSAR Table 3.2-1.Suppl 3 to SER Issued in Apr Referenced Same Questions as Outstending Issue 23.Info Should Resolve Outstanding Issue 23 in Next SER Suppl

ML20076D995
Person / Time
Site:	Perry
Issue date:	05/19/1983
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8305260267
Download: ML20076D995 (11)

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P.o BOX 5000 - CLEVELAND, oHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMit' NG BLOG - 55 PUBUC SoUARE Serviorg he Best Location in the Nation MURRAY R. EDELMAN VICE PRE 51 DENT May 19, 1983 NUCLE A R PY-CEI/NRR-0044 L Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Question Nos. 260.14 - 260.18 Outstanding Issue No. 23

Dear Mr. Youngblood:

This letter and its attachments are provided in response to Question Nos. 260.14 - 260.18 addressed by the NRC Ouality Assurance Staff in your letter dated March 7, 1983. In your letter you requested clarifications and additional information pertaining to Table 3.2-1 in the Perry FSAR.

In April 1983, the NRC staff issued Supplement No. 3 to the Perry Safety Evaluation Report (SER). In Supplement No. 3, the NRC staff added the previously mentioned questions on the Perry FSAR Table 3.2-1, as Outstand-ing Issue No. 23.

We believe that this letter and its attachments should clarify and provide the pertinent information for the Quality Assurance Staff, to resolve Out-standing Issue No. 23 in the next supplement of the Perry SER.

Very truly yours, Murray R. E elman Vice President Nuclear Group MRE:kh cc: Jay Silberg, Esq.  !

John Stefano Max Gildner Attachments 0305260267 830519 PDR ADOCK 05000440 E PDR i

260.14 The response to the following questions are acceptable. They need to be incor-porated into Table 3.2-1 as committed to by CEI in each response.

Response Table 3.2-1 Item to Question Location (Comment) 260.10 XXIX.12 Diesel generator jacket water cooling.

(Safety Class column is blank per Amendment 8. Needs to show Safety Class 3 per response.)

260.10 XXXIV.15 Spent fuel pool and liner. (Safety Class column is blank per Amendment 8. Needs to show Safety Class 2 per response.)

260.10 XXXIV.17 Foundation for Seismic Category I electrical duct banks and manholes. (Same comment as for XXXIV 15.)

260.11 Note 1 Clarification that valve operators are implicit in the entry for valves. (Note 1 of Table 3.2-1 needs to be revised per the response.

260.12 I.6 Reactor internal structures, other. (The response indicates an acceptable note regarding QA will be added to the table, and this needs to be done. Also, FSAR Amend-ment 8 changed the seismic category from I to N/A. This change is contrary to Regulatory Guide 1.29 and is unacceptable to the staff.)

260.12 III.6 Pump motors. (The response states: "A note will be added to Table 3.2-1 stating that the pump motors are subject to General Electric's QA Program requirements during design, fabrication and installation.

Pump motors will be subject to the perti-nent provisions of 10CFR50, Appendix B during the operations phase." We will require that the second sentence be included in the note.)

260.12 XXXII.9 AC control power inverters. (Safety Class column shows NSC per Amendment 8. Needs to show Safety Class 2 per response.)

260.12 XXXII.11 Fire stops. (New note needs to be added per the response and referenced at Item XXXII.11.)

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Response Table 3.2-1 Item to Question Location (Comment) 260.12 XXXV.1.f Fire control dampers. (New note needs to be added per the response and referenced at Item XXXV 1.f.)

260.13 XXXVI Other components (Items need to be returned to Table 3.2-1.)

RESPONSE

260.10 XXIX.12 Diesel generator jacket water cooling:

Safety Class 3 will be indicated in Amendment 12 of Table 3.2-1.

260.10 XXXIV.15 Spent fuel pool and liner: Safety Clacs 2 will be indicated in Amendment 12 of Table 3.2-1.

260.10 XXXIV.17 Foundation for Seismic Category I clectrical duct banks and manholes: Safety Class 2 will be indicated in Amendment 12 of Table 3.2-1.

260.11 Note 1 Clarification that valve operators are implicit in the entry for valves: (Additional clarification of our previous response is required to completely address this item.)

Specific valves in Perry's design are designated Safety Class 1 solely on their application in maintaining the Reactor Coolant Pressure Boundary. These valves serve no other safety function in Perry's plant design tu prevent or mitigate the consequences of an accident. Associated operators with these valves do not affect the Reactor Coolant Pressure Boundary and are therefore classified nonsafety.

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l An additional sentence will be added to the end of Note 1 of Tabic 3.2-1 (in Amend-ment 12) stating that all valve operators are implicit in the entry of valves, except in those applications where the valve's sole function is maintaining a Reactor Coolant j Pressure Boundary.

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Response Table 3.2-1 Item to Question Location (Comment) 260,12 I.6 Reactor internal structures, other: A note will be added to Table 3.2-1 (Amend-ment 12) stating that other reactor internal structures will be subject to the pertinent provision of 10CFR50, App ( dix B during the operations phase.

The change (in Amendment 8) in the seismic category of reactor vessel internals from I to N/A is considered correct based on GE's design program for the reactor vessel.

Other reactor vessel internals referred to in Table 3.2-1 includes:

(1) Shroud head and steam separators assembly.

(2) Dryer assembly.

(3) Containers for vessel surveillance samples.

(4) Guide rods.

The structures described above are classified as " passive" and have no function or contri-bution to move or cause another component to accomplish a safety function during normal operation, shutdown, or an accident.

These assemblies / components are constructed to assure operational integrity only.

General Electric's program to verify structural integrity is accomplished via stress analysis and/or periodic inspection as required by codes ASME III and XI during the design and construction phase.

260.12 III.6 Pump motors: (A revised response is required to completely address this item.) Recircula-tion pump motors are nonsafety class and are therefore not subject to the provisions of 10CFR50, Appendix B during the operations phase.

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Response Table 3.2-1 Item to Question Location (Comment) l Recirculation pumps as utilized I'n the Perry Nuclear Power Plant's design are specified Seismic Category I since they form part of

- the Reactor Coolant Pressure Boundary.

Operation of these pumps is not required to mitigate or prevent the effects of an accident. Associated motors with these pumps are not classified Seismic Category I, i however, they have been evaluated for Seismic Category I' requirements and will not threaten the pressure boundary function of the pumps or any other safety-related system's functions.

260.12 XXXII.9 AC control power inverters: Table 3.2-1 (in Amendment 12) will be revised to reficct; "AC control power inverters with safety functions as the principal component with a Safety Class 2 designation. Based on this classification, these components are j subject to the provisions of 10CFR50,

Appendix B during the operations phase."

i l 260,12 XXXII.11 Fire stops: A note will be added to Table 3.2-1 (in Amendment 12) stating that fire stops are subject to the pertinent provisions of 10CFR50, Appendix B as dis-cussed in the Perry Fire Protection Evalua-tion Report.

I 260.12 XXXV.1.f Fire control dampers: A note will be added to Table 3.2-1 (in Amendment 12) stating that fire control dampers are subject to pertinent provisions of 10CFR50, Appendix B as dis-cussed in the Perry Fire Protection Evaluation Report.

260.13 XXXVI Other components: Item XXXVI will be I

reinserted into Table 3.2-1 as part of

Amendment 12 to the FSAR.

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260.15 The response to the following questions need clarification or correction as

-noted.

Response Tabic 3.2-1 Item to Question Location (Comment) 260,11.c.1 XXI.3 Safety parameter display system - SPDS.

(The staff requires a commitment that the SPDS will be subject to the pertinent pro-visions of CEI's 10CFR50, Appendix B QA Program during the operations phase.)

260.11.c.8 Noted Additional accident monitoring instrumenta-tion. (The response needs clarification in that Safety Class Category "2 (electrical)"

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is not defined and the response to 6 items appears to fall into 7 references. Also, the references made in the response should show all items as being subject to the per-tinent provisions of CEI's 10CFR50, Appendix B QA Program during the operations-phase.)

260.12 XXXII.6 & Conduits, etc. (The response to both items XXXIII.4 omitted cable trays and should be revised to include cable trays. New note needs to be added per the response and referenced at both Table 3.2-1 locations.)

RESPONSE

260.11.c.1 XXI.3 Safety parameter display system (SPDS): The SPDS at Perry is not subject to the pertinent provisions of 10CFR50, Appendix B during

, the operations phase.

The SPDS as described in Section 4.1 of NUREG 0737 Supplement 1 states:

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i The SPDS should provide a concise display

of critical plant variables to the control room operators to aid them in rapidly and reliably determining the safety status of the plant.

In describing the design implementation criteria, Section 4.1.c of this document imposes no safety requirements (i.e.,

Class 1E or Seismic Category I on hardware for the systems, i

Response Table 3.2-1 Item to Question Location (Comment)

Using the guidance of this document, CEI has committed to install a SPDS system at Perry with a nonsafety classification. The SPDS will be used as an aid to operators for determining the safety status of the plant. All parameters which are displayed on the SPDS and which are safety-related, are also displayed on safety-related instruments in the control room; and, the pertinent pro-visions of 10CFR50, Appendix B have been applied to these. Therefore, due to its non-safety classification, the provisions of 10CFR50, Appendix B do not pertain to the SPDS during the operations phase.

260.11.c.8 Noted Additional accident monitoring instru-mentation: The safety class category of Items XLII, XLIII, and XLIV in Table 3.2-1 should be "2" in lieu of "2' (electrical).

This correction will be added in FSAR Amendment 12.

Items XXI, XXII, and Note 8e are applicable to containment pressure monitor instrumenta-tion. Complete clarification to our pre-vious response is as follows: Additional accident monitoring instrumentation as designated in NUREG-0737 Section II.F.1 through 6 includes: (1) Noble gas effluent radiological monitor (is covered in Table 3.2-1 Sections XLIV and XLV).

(2) Continuous sampling of plant effluents (is covered in Table 3.2-1 Section XLVI).

(3) Containment high-range radiation monitor (is covered in Table 3.2-1 Sections XLII and XLIII). (4) Containment pressure monitor (is covered in Table 3.2-1 Sections XXI, XXII, l Note 8e). (5) Suppression pool level monitor l (is covered in Table 3.2-1 Section XXXVII).

(6) Containment hydrogen concentration monitor (is covered in Table 3.2-1 Section XXXV.30.g).

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Response Table 3.2-1 Item to Question Location (Comment)

Instrumentation and controls for items in our previous response are safety class except for Items XLV and XLVI and are subject to the provisions of 10CFR50, Appendix B during the operations phase. Instrumenta-tion snd controls for Items XLV and XLVI in Table 3.2-1 are designated nonsafety class.

A note applicable for these items will be added to Table 3.2-1 as follows:

"Nonsafety class instrumentation and con-trols specified for radiation or radio-activity monitoring will be subject to the portinent provisions of 10CFR50, Appendix B during the operations phase."

260.12 XXXII.6 & Conduits, etc.: A paragraph will be added XXXIII.4 to the end of FSAR Section 3.2.1 (in Amend-ment 12) to reficct the following:

"During construction, all nonsafety struc-tures systems or components which fall under Regulatory Guide 1.29 Paragraph c.2 are identified through a seismic clearance and anti-fall down inspection program.

Such structures or components are then analyzed for the seisaic loads and when necessary, additional supports are added or existing supports are modified to ensure structural integrity during a seismic event."

A note will be added to Tabic 3.2-1 (in Amendment 12) to state that conduit, cable trays, and supports containing Non-1E cables in safety-related structures are subject to the pertinent provisions of 10CFR50, Appendix B during the operations phase.

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260.16 FSAR Table 3.2-1 Items XIII, Fuel Service Equipment; XIV, Reactor Vessel Service Equipment; and XVI.3, Fuel Transfer System were revised in Amendment 8 to now reference FSAR Tables 9.1-3, 9.1-5, and 9.1.4, respectively. These tables do not explicitly show which items are subject to CEI's 10CFR50 Appendix B QA Program during the operations phase. These tables should explicitly show this information or the information should be included in Table 3.2-1 where it originally was. The following items were shown to be subject to CEI's 10CFR50, Appendix B QA Program during the operations phase, and the staff position is that they should continue to be shown in this manner:

Fuel preparation machine General purpose grapple Dryer and separator sling and head strongback Fuel transfer system

RESPONSE

Tables 9.1.3 and 9.1.5 will be revised to reflect a Passive Essential Classifica-tion and Seismic I Classification for the fuel preparation machine, general purpose grapple, dryer and separator strongback, and head strongback carousel.

A note will be added to Tables 9.1-3, 9.1-4 and 9.1-5 (in Amendment 12) stating that equipment will be subject to the pertinent provisions of 10CFR50, Appendix B during the operations phase.

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, 260.17 The response to 260.a.6 Indicates that the diesel generator intake air filter and exhaust silencer will not be subject to the pertinent requirements of CEI's 10CFR50, Appendix B QA Program during the operations phase. This is reflected in Class NSC per FSAR Amendment 8. The staff position is that these

! items should be subject to the pertinent requirements of CEI's 10CFR50 i Appendix B QA Program during the operations phase. (Our original review of

) these items did not catch this shortcoming and CEI has not been informed of our objection to the 260.a.6 response.)

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RESPONSE

The dicsol generator intake air filter is Safety Class 3. The pertinent require-ments of 10CFR50, Appendix B will thus be applied to this item during the

operations phase. FSAR Table 3.2-1 will be revised in Amendment 12 to reficct 1

the intake air filter included in Item XXIX.10 and deleted from Item XXIX.11.

l The exhaust silencer is not subject to the pertinent requirements of 10CFR50, Appendix B.during the operations phase based on its nonsafety classification.

As described in Section 9.5.8.1 of the Perry FSAR, the silencer is nonsafety-related since any blockage of the exhaust silencer would be automatically bypassed through the blowoff hatch.

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r 260.18 FSAR Table 3.2-1 was revised by Amendment 8 to include the items listed below.

The staff position is that these items should be subject to the portinent requirements of CEI's 10CFR50, Appendix B QA Program during the operations phase. The table should be so revised.

XL.6 Drywell atmospheric radiation monitors XL.7 Containment atmospheric radiation monitors XL.8-12 Portable radiation monitors XL.13 Control room airborne radiation monitors XLI.All Area radiation monitors XLVII.All Portable radiation monitoring equipment XLVIII TSC & EOF airborne and area monitors We note that Page Q&R 17.2-14 of FSAR Amendment 9 addressed these items by stating: "These items are covered by plant operating procedures and administra-tive controls and are not included in Table 3.2-1 (see Note 1)." Note 1 states (Page Q&R 17.2-13) that "These procedures and controls ... are ... con-trolled ... by the pertinent requirements of the operational quality assurance program (Chapter 17)." Tabic 3.2-1 should reflect this commitment for these items.

RESPONSE

A note will be added to Tabic 3.2-1 (in Amendment 12) stating that nonsafety class instrumentation and controls specified for radiation or radioactivity I monitoring will be subject to the pertinent provisions of 10CFR50, Appendix B during the operations phase.