ML20079R596

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Forwards FSAR Page Changes Modifying Response to NRC Request for Addl Info 271.2 Re Equipment Qualification Branch SER Open Item 6.FSAR Changes Will Be Incorporated in Rev Scheduled for Feb 1984
ML20079R596
Person / Time
Site: Limerick  
Issue date: 01/30/1984
From: Bradley E
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Schwencer A
Office of Nuclear Reactor Regulation
References
NUDOCS 8402020300
Download: ML20079R596 (4)


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6 PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. 90X 8699 PHILADELPHIA. PA.19101 U $," " ",, [,'," ^ ",' "' ' "-

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OUGENE J. BR ADLEY AssoceAtm emmena6 covessm6 DON ALD BLANM EN RUDOLPN A. CHILLEMI E. C. MI R K H A LL T. H. M A;4ER CORNELL January 30, 1984 PAUL AUERSACH assesTANT SEMEteAL SOU4sEL ODW ARD J. CULLEN, J R.

THOM AS H. MILLER. J R.

SRENE A McKENNA assistant coumssk Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Limerick Generating Station, Units 1 and 2 Equipment Qualification Branch Open Item (SER Open Item #6)

Reference:

1)

Letter from E. J. Bradley (PECO) to A. Schwencer dated 12/23/83 transmitting revised response to NRC RAI 271.2 2)

Telecon between L. Kintner, G. Bagchi and D. Reiff (NRC) and C. W. Wiedersum and J. T. Robb (PECO) on 1/10/84 File:

GOVT 1-1 (NRC)

Dear Mr. Schwencer:

The attached FSAR page changes modify the response to NRC RAI 271.2 as discussed in the reference 2 telecon. These page changes close out the portion of the referenced open item dealing with ADS accumulators.

The information contained on these draft FSAR page changes will be incorporated into the FSAR, exactly as it appears on the attachment, in the revision scheduled for February 1984.

c' cerel 8402020300 840130 PDR ADOCK 05000352 E

PDR Euger. J.

radley JTR/gra/012484250 Attachment f1f cc: See Attached Service List i

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Judga Lawrence Brenner (w/o enclosure)

Judge Peter A. Morris (w/o enclosure)

Judge Richard F. Cole.

(w/o enclosure)

Troy B. Conner, Jr., Esq.

(w/o enclosure)

Ann.P. Hodgden, Esq.

(w/o enclosure)

Mr. Frank R. Romano (w/o enclesure)

Mr. Robert L. Anthony (w/o enclosure)

- Mr. Marvin I. Lewis (w/o enclosure)

Charles W.

Elliot, Esq.

(w/o enclosure)

Zori G. Ferkin, Esq.

(w/o enclosure)

Mr. Thomas Gerusky (w/o enclosure)

Director, Penna. Emergency

- (w/o enclosure)

Management Agency Mr. Steven P.

Hershey (w/o enclosure)

Angus Love, Esq.

(w/o enclosure)

Mr. Joseph H. White, III (w/o enclosure)

David Wersen, Esq.

(w/o enclosure)

Robert J.

Sugarman, Esq.

(w/o enclosure)

Spence W. Ferry, Esq.

(w/o enclosure)

Jay M.-Gutierrez, Esq.

(w/o enclosure)

Atomic Safety & Licensing (w/o enclosure)

Appeal Board Atomic Safety & Licensing (w/o enclosure)

Board Panel Docket & Service Section (w/o enclosure)

Martha W.

Bush, Esq.

(w/o enclosure)

James Wiggins (w/o enclosure) 1 5

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c g rC"u-mg p'ha Mhb D E nd M nd f kd LGS FSAR The pneumatic system solenoid valves have been qualified under the qualification program for electrical equipment to remain functional under conditions simulating the environment following a postulated design basis LOCA. The pneumatic system spring-loaded, soft-seated valves have been qualified to remain leaktight after a seismic event. A materials and design review was performed to ensure that the check valves would not experience a significant increase in leakage due to post-LOCA environmental conditions. The functional capability of the check valves will be further reviewed as part of the mechanical equipment qualification program. In any event, the backup safety grade pneumatic supply will provide the motive force for ADS valve operability. A surveillance test will be conducted every refueling cycle 4. under the local leak rata test (LLRT) program. Although the accumulator system is not considered to be a part of the primary containment boundary, this test under the LLRT program ensures completion of the surveillance test. Two tests will be performed at 90 psig. For the first test, the isolation boundaries will be the normal supply check valve, the seismic supply check valve, and the de-energized actuation solenoid. Vents are provided on the upstream side of the isolation check valves to meet the single isolation valve criteria. For the second test, the solenoid will be energized so that the SRV actuator and the solenoid valve vent port become part of the boundaries. In both tests, the leakage criteria will be 78 scc / min. TDe acct.pGWA, Cden'r$v4 cf 78 SCr min. h (4% 6 -%e, expeded lenMcgg 5. The backup system is safety-related, seismic Category I, and designed to meet the overall requirements for long-term operation of the ADS system. l 6. The condition of low instrument gas system receiver tank pressure is alarmed in the control room. The alarm is unspecific with respect to individual ADS accumulators. When low pressure is sensed in the instrument gas receiver tank, the station instrument air system can be manually placed into service as a backup. Low pressure in the normal instrument gas supply header automatically connects the backup safety-grade instrument gas system to the seismic Category I ADS valve supply header. The alarms and instrumentation i associated wit.h the backup, safety-grede pneumatic supply are described below: a. Pressure instrumentation is installed in each of the two supply piping branches outside containment to provide pressure indication in the control room. High or low supply pressure in the backup safety-grade gas supply l header is alarmed in the control room. bm n in 2. olrxNe Gom the,17,3 scc /nA, allouhbL'. Itzkzg M i he. Rev.2R, OLlo4 271.2-3 Rc;. 29, O L'S 4 l

4 [ LGS FSAR Q t, ..; i. p i~ S h ['d.. O U QJ[] PG Actions to be taken, in a specified time frame, should the allowable leakage rate be exceeded.

11. Provide a statement that confirms that the complete ADS accumulator system and associated equipment and control circuitry are a part of the Limerick Environmental Qualification Program and will be qualified to accommodate the affects of and are compatible with the environmental condition associated with normal operation, maintenance, testing, and postulated accidents as stated in General Design Criteria 2 and 4 of Appendix A of 10 CFR 50.
12. Provide a P&ID of the ADS Accumulator System including the gas bottle supply.

RESPONSE

1. The basis for the allowable leakage criteria applies only to the short-term ADS SRV operations because provision is made for an infinite long-term supply through the use of external I connections. An allowable leakage criteria of 173 sec/ min was established to ensure that there would be sufficient pneumatic pressure to depressurize the reactor pressure vessel from the HPCI/RCIC operating pressure to the RHR shutdown cooling operating pressure range using two ADS SRV actuations over a period of 6 hours. Calculations indicate that this leakage criteria will ensure ADS operability for periods in excess of 6 hours for a range of containment conditions that might accompany the need for ADS operation. This duration is sufficient to ensure that the ADS valves can perform their functions. '2. A 46 sec/ min margin is provided in the allowable leakage rate criteria described above to account for any possible increase in laakage due to a harsh environment and/or seismic event. l This. margin is obtained by oversizing the accumulators by 35jf, The pneumatic components that make up the ADS accumulator system were designed for low leakage in a harsh environment and seismic event. A safety grade pneumatic supply of nitrogen cylinders is available to provide a backup supply if the ADS accumulator system leakage rate should exceed its allowable limit. 3. As described below, testing and/or analysis has been performed to verify that a harsh environment and/or seismic event would not increase the leakage rate of the ADS pneumatic supply system. 29 oys Rev. g n ':: 27i.2-2 1}}