ML20092P564
| ML20092P564 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/02/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-4-099, 2NRC-4-99, NUDOCS 8407090104 | |
| Download: ML20092P564 (20) | |
Text
$VL 2NRC-4-099 Telecopy 4 2
July 02, 1984 Nuclear Construction Division Robinson a, Bu ding 2 Suite 210 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. George W. Knighton, Chief Licensing Branch 3 Office of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Gentlemen:
This letter forwards responses to twenty-four of the twenty-eight draft SER open items provided by the Auxiliary Systems Branch.
This draft SER material, thich was officially transmitted from the NRC to Duquesne Light Company on May -14,1984, contains open items 122 through 149.
All of the attached responses except for those for open items 138 and 145 were transmitted informally to you during the weeks of June lith and June 18th.
It should also be noted that a few of the formal responses include changes which provide additional information or clarifications.
The draft SER open items not addressed in the attachment are 125, 135, 139 and 148. Responses for these four items will be submitted shortly.
DUQUESNE LIGHT COMPANY
(
By j[
ETJ hWb61ever Vice President JJS/ms Attachment cc: Ms. M. Ley, Project Manager
- w/ attachment Mr. E. A. Licitra, Project Manager
- w/ attachment Mr. G. Walton, NRC Resident Inspector - w/ attachment SUBSrRIBED AtQ'ORN TO BEFORE E THIS g M AY OF L 4 d / -
, 1984.
A kis lW
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Notary Publ1C ELVA G. LESONDAK, N0'. ARY PUBLIC k
ROBINSON TOWNSHIP, ALLEGHENY COUNTY 709g4 j
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MY COMMISSION EXPIRiiS OCTOBER 20,1986 E
g
t United States Nuclear Regulatory Commission Mr. George W. Knighton, Chief l
Page 2 COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF ALLEGHENY
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On thisJ M day of hf,,
/ / f /, before me, a Notary Public in and for s$id Cdnonwealth and
- County, personally appeared E. J. Woolever, to being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behal f of said Company, and (3) the statements set forth in the Submittal are true and cor-ect to the best of his knowledge.
/
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Notary Public ELVA G. LESONDAK, NOTARY PUBUC ROBINSON TOWNSHIP, ALLEGHENY COUNTY' MY COMMISSION EXPIRES OCTOBER 20,1986
ATTACHMENT 01 122 THE APPLICANT SHOULD ADDRESS THE POSSIBILITY OF WATER ENTERING THE INDIVIDUAL INTAKE STRUCTURE CUBICLES HOUSING THE SAFETY-RELATED PUMPS AHD ASSOCIATED EQUIP-MENT DUE TO INADEQUATE WATERPROOF SEALS AT THE FOLLOWING LOCATIONS:
- 1. THE ENTRY OF WATER THROUGH ALL PUMP SHAFTS (INCLUDING NON SAFETY-RELATED PUMPS WITHIN THE CUBICLES)
- 2. THE ENTRY OF WATER THROUGH THE FOUR OUTSIDE CUBICLE SLIDING FLOOD D0 ORS AND THE TWO SLIDING FLOOD D0 ORS INTERCONNECTING THE CUBICLES.
- 3. ENTRY OF WATER THROUGH THE EQUIPMENT HATCHES (CONCRETE PLUGS) LOCATED IN THE 4
CEILING OF EACH OF THE CUBICLES AT ELEVATION 730
- 4. THE ENTRY OF WATER THROUGH ALL OTHER FLOOR, WALL AND CEILING PENETRATIONS IN EACH OF THE CUBICLES HOUSING UNIT 1 AND OR UNIT 2 SAFETY-RELATED EQUIPENT (INCLUDING THE JUNCTION OF THE VENTILATION AIR INTAKE STRUCTURE WITH THE INTAKE STRUCTURE AT ELEVATION 730.
RESPONSE
THE INTAKE STRUCTURE CUBICLES ARE DESIGNED TO PREVENT IN-LEAKAGE FOR THE PMF LEVEL OF 730FT. PLUS COINCIDENT WAVE ACTION.
THE CUBICLE FLOOD D0 ORS HAVE INFLATABLE SEALS WHICH ARE PERIODICALLY TESTED TO VERIFY FUNCTIONAL CAPABILITY AS DESCRIBED IN THE RESPONSE TO DRAFT SER OPEN ITEM 123. FLOOD PROTECTION PRO-CEDURES WHEN _THE FLOOD REACHES 695 FT. INCLUDE SEALING THE WATERPROOF D0 ORS, BOLTING VENTILATION DUCTS TO THE COMPARTMENT AIR EXHAUST PORTS AT ELEVATION 730FT. AND GASKETING THE EQUIPMENT HATCHES.
THE VENTILATION AIR INTAKES ARE LOCATED AT ELEVATION 737 FT. TO ALLOW FOR THE 6.7 FT. RUN-UP AB0VE THE STANDING WATER LEVEL OF 730 FT. LEAKAGE RATE THROUGH A PUMP SHAFT IS ESTIMATED TO BE ONLY A SMALL FRACTION OF A GALLON PER MINUTE.
ASSUMING SUCH A LEAKAGE RATE INTO THE CUBICLE, THE WATER LEVEL WOULD ONLY RISE AT A SMALL FRACTION OF AN INCH PER HOUR. IT IS ALSO NOTED THAT THE WATER LEVEL RISE TO 730 FT. WOULD TAKE PLACE OVER DAYS. ACCORDINGLY THERE WOULD BE TIME TO TAKE OTHER ACTIONS TO REDUCE OR STOP THE LEAKAGE. IN ADDITION, THE SUMP PUMPS LOCATED IN EACH CUBICLE ARE RATED AT 65 GPM.
AS NOTED IN THE RESPONSE TO Q410.4, AMENDMENT 5, THE INTAKE STRUCTURE CUBICLES ARE ISOLATED FROM EACH OTHER AND ARE REDUNDANT; ACCORDINGLY THERE IS AN ALLOW-ANCE FOR FAILURE DUE TO LEAKAGE.
OI 123 A DISCUSSION SHOULD BE PROVIDED TO DEMONSTRATE THAT THE RESPECTIVE WATERTIGHT SEALS ARE CAPABLE OF AND WILL BE PERIODICALLY TESTED TO VERIFY THEIR FUNCTIONAL CAPABILTY. WITH RESPECT TO INFLATABLE SEALS, THE DISCUSSION 3HOULD INCLUDE A)
THE POSSIBILITY OF THEIR RUPTURE DUE TO OVER INFLATION AND (B) LOSS OF SEAL DUE TO ITS LEAKAGES AND INADEQUATE PRESSURIZING GAS INVENTORY OVER THE TIME OF THE PMF.
i t
RESPONSE
i THE CUBICLE FLOOD D0 ORS ARE ANNUALLY AIR PRESSURE TESTED TO VERIFY THEIR FUNC-TIONAL CAPABILITY. THE SEALS ARE INFLATED TO 50 PSIG THEN ISOLATED FROM THE FILL VESSEL.
THE SEAL PRESSURE IS CHECKED OVER A PERIOD 0F 100 HOURS (DURATION OF PMF) FOR PRESSURE LOSS. IF AFTER 100 HOURS PRESSURE DOES NOT FALL BELOW 40 PSIG THE SEAL IS CONSIDERED TO BE IN GOOD CONDITION.
A LOSS OF PRESSURE FROM 50 TO 40 PSIG WITHIN 100 HOURS SATISFIES THE RECOMMENDATIONS OF THE t%NUFACTURER FOR MAXIMUM ACCEPTABLE AIR LOSS.
IF THE SEAL DOES NOT !%INTAIN AT LEAST 40 PSIG AT THE END OF 100 HOURS OR IF IT SHOWS MARKED WEAR OR SURFACE PEELING AND CRACKING, THE SEAL IS REPLACED. RELIEF PROTECTION, SET AT 75 PSIG, IS PROVIDED TO PROTECT AGAINST OVER-PRESSURIZATION OF THE SEALS, WHOSE t%XIMUM ALLOWABLE PRESSURE IS 100 PSIG.
THE AIR VESSEL PROVIDED, ONE FOR EACH D0OR SEAL, ARE CHARGED TO 200 PSIG AND ARE CAPABLE OF INFLATING THE SEALS AND MAINTAINING THE SEAL PRESSURE OF 50 PSIG FOR 100 HOURS WITH TEN TIMES THE t%XIMUM ANTICIPATED LOSS OF AIR.
THE AIR VESSEL WILL BE REPLACED WHEN, DUE TO LEAKAGE OR AS A RESULT OF TESTING DUR-ING NORMAL PLANT OPERATION, THE AIR PRESSURE FALLS TO 100 PSIG.
AT A PRESSURE OF 100 PSIG THE AIR VESSEL CAN STILL INFLATE THE SEAL IT SERVES AND CAN !%INTAIN 50 PSIG FOR 100 HOURS WITH THE t%XIMUM ANTICIPATED AIR LEAKAGE.
AN ADDITIONAL SAFETY MARGIN IS BUILT IN SINCE THE SEALS CAN MAINTAIN SPECIFICATION REQUIRE-MENTS WITH AN INTERNAL PRESSURE OF 40 PSIG. THE 10 PSI t%RGIN ALLOWS FOR AN ADDITIONAL 5 DAYS OF SEAL PRESSURIZATION AB0VE THE MINIMUM 0F 40 PSIG SEAL PRESSURE. THEREFORE, CONSIDERING THE DESIGN OF THE SEALING SYSTEM AND THE DESIGN MARGINS INCORPORATED INTO THE SYSTEM, IT IS NOT ANTICIPATED THAT ANY BOTTLE REPLACEMENT WOULD BE NECESSARY DURING THE PROBABLE MAXIMUM FL000.
OI 124 ACCESS TO SAFETY-RELATED EQUIPMENT AT THE INTAKE STRUCTURE IS BY MEANS OF A FOOT BRIDGE LOCATED AT ELEVATION 705'-0 OR A STAIRWAY LEADING TO A GRADE AT ELEVA-TION 675'-0. CONSEQUENTLY THE SAFEY-RELATED INTAKE STRUCTURE IS NOT ACCESSIBLE DURING THE PMF. (THEREFORE, THE APPLICANT SHOULD PROVIDE A DISCUSSION THAT DEM-ONSTRATES FOR ALL CREDIBLE EVENTS WITHIN THE CUBICLES OR RELATED TO THE INTAKE STRUCTURE, idAT ACCESS TO THE INTAKE STRUCTURE IS NOT REQUIRED TO BRING AND MAINTAIN UNIT 2 TO A SAFE SHUTDOWN CONDITION.)
RESPONSE
THE SYSTEMS IN THE INTAKE STRUCTURE ARE DESIGNED TO !%INTAIN SAFE SHUTDOWN ASSUMING A SINGLE FAILURE AND LOSS OF 0FFSIE POWER. NO OTHER EVENTS ARE POSTU-LATED CONCURRENT WITH THE PROBABLE MAXIMUM FLOOD. THE TECHNICAL SPECIFICATIONS WILL REQUIRE THAT BVPS-2 BE SHUTDOWN WHEN THE RIVER WATER LEVEL EXEEDS 695 FEET MSL.
THE ACTION REQUIRED TO SEAL THE SERVICE WATER PUMP CUBICLES IS DESCRIBED IN SECTION 2.4.14 AND IN THE RESPONSE TO Q210.4. AS STATED IN THE RESPONSE TO Q210.16 0F THE BVPS-2 PSAR, IT TAKES APPR0XIMATELY TWO DAYS BEFORE THE FLOOD LEVEL REACHES ELEVATION 705 FT. AFTER THE INCEPTION OF THE STORM.
IN ADDITION, SYSTEM ALIGNMENT AND THE MODE OF OPERATION OF THE EQUIPENT IN THE SERVICE WATER PUMP CUBICLES REQUIRED DURING THE PROBABLE MAXIMUM FLOOD IS NO DIFERENT FROM THE ALIGNMENT AND OPERATION REQUIRED DURING NORMAL OPERATING CON-DITIONS PRECEEDING THE FLOOD. THEREFORE, N0 OPERATOR ACTION IN THE INTAKE
l WILL BE REQUIRED DURING THE PERIOD THAT THE RIVER WATER LEVEL EXCEEDS 705 FEET MSL.
OI 126 THE APPLICANT HAS NOT ADEQUATELY ADDRESSED FLOODING DUE TO THE FAILURES OF NON-SEISMIC CATEGORY 1 TANK, PIPING AND VESSEL INSIDE SAFETY-RELATED STRUCTURES PER SRP SECTION 3.4.
RESPONSE
REFER TO SECTION 3.68.1.3.4.
THE EFFECT OF P0TENTIAL FLOODING DUE TO PIPING FAILURES OR RUPTURES OF LARGE TANKS IN AREAS WHICH CONTAIN SAFETY-RELATED EQUIP-MENT ARE DISCUSSED. SECTION 3.4 REFERS TO SECTION 3.68.1.3.4.
01 127
RESPONSE
THESE OPEN ITEMS ARE ALL CONCERNED WITH POTENTIAL HAZARDS FROM MISSILES OR PIPE BREAKS.
EVALUATIONS OF SUCH HAZARDS ARE CURRENTLY IN PROGRESS ON A PLANT AREA-T0-AREA BASIS.
RESULTS OF THOSE CACULATIONS WILL BE COMPLETED THROUGH 1985 AND FINAL DOCUMENTATION WILL BE COMPLETED BY THE END OF 1985.
(IT IS NOTE THAT OPEN ITEN 26 FROM MEB IS ALSO IN THIS CATEGORY).
THESE OPEN ITEMS SHOULD ' ALL BE GROUPED AS A SINGLE CONFIRMATORY ITEM BECAUSE THEY ARE ALL BEING ADDRESSED BY A SINGLE COMPREHENSIVE HAZARDS EVALUATION AND THE ETHODOLOGY THAT IS EMPLOYED IN THESE EVALUATIONS IS DESCRIBED IN THE FSAR.
01 128
RESPONSE
REFER TO THE RESPONSE TO 01 127 01 129
RESPONSE
REFER TO THE RESPONSE TO OI 127 01 130
RESPONSE
REFER TO THE RESPONSE TO OI 127.
__ -_ - ___ ____ OI 131 IN RESPONSE TO OUR CONCERN REGARDING THE ADEQUACY OF THE TORNADO DESIGN PROTEC-TION PROVIDED FOR THE AUXILIARY BUILDING AB0VE ELEVATION 773'-6 THE APPLICANT STATES THAT THE RESPONSE WILL BE PROVIDED AT A LATER DATE.
RESPONSE
REFER TO THE RESPONSE TO QUESTION 220.12 WHICH WAS PROVIDED IN A,MENDMENT 6.
01 132 IN RESPONSE TO THE STAFF'S CONCERN OVER MISSILE PROTECTION PROVIDED BY THE MAIN STEAM VENT PANELS, THE APPLICANT STATES FIGURE 3.11-2 " MAIN STEAM VALVE HOUSE FRESSURE/ TEMPERATURE TRANSIENTS" WILL BE REVISED IN A LATER AMENDENT TO SHOW THEIR DESIGN CAPABILITY.
RESP 0 HSE FIGURE 3.8-6 WAS REVISED IN AMENDfENT 6 TO SHOW THE ARRANGEMENT OF THE MAIN STEAM VALVE HOUSE VENT PANELS. THE FIGURE WAS CHANGED TO SHOW THAT THE MAIN STEAM HOUSE VENT PANELS ARE LOCATED IN A STRUCTURE ON THE ROOF NOT IN THE WALLS AS PREVIOUSLY STATED IN THE FSAR TEXT. THE RESPONSE TO Q410.9 IN AMENDfENT 5 WAS NOT REFERING TO FIGURE 3.11-2.
01 133
RESPONSE
REFER TO RESPONSE TO 01 127 OI 134 THE APPLICANT STATED THAT THE FUEL P00L HEAT LOADS HAVE BEEN CALCULATED IN ACCORDANCE WITH BRANCH TECHNICAL POSITION ASB 9-2. THE APPLICANT STATES THAT UNDER NORMAL HEAT LOAD (DEFINED BELOW), THE P00L TEMPERATURE WOULD BE MAINTAINED BELOW 140 DEGREES FAHRENHEIT ASSUMING THE FAILURE OF ONE COOLING TRAIN.
THIS HEAT LOAD HAS BEEN DEFINED AS ONE THIRD CORE AFTER 150 HOURS OF DECAY, ONE-THIRD CORE WITH ONE YEAR OF DECAY PLUS ONE-THIRD CORE WITH 400 DAYS DECAY. WE CONSIDER THE MAXIMUM NORMAL HEAT LOAD TO BE THAT WHICH WOULD EXIST WHEN THE P0OL IS COM-PLETELY FIl' rD WITH SUCCESSIVE NORMAL REFUELING BATCH DISCHARGES.
. WE WILL REQUIRE THE APPLICANT TO DEMONSTRATE THAT THE SPENT FUEL POOL COOLING SYSTEM IS CAPABLE OF MAINTAIdING THE P0OL WATER TEMPERATURE AT OR BELOW 140 DEGREES F WHEN THE STORAGE P00L IS COMPLETELY FILLED WITH NORMAL DISCHARGES ASSUMING THAT ONE COOLING TRAIN HAS FAILED.
THE MAXIMUM ABNORMAL HEAT-LOAD IS DEFINED BY THE APPLICANT AS ONE FULL CORE DISCHARGE WITH 150 HOURS OF DECAY PLUS ONE THIRD CORE DISCHARGE WITH 36 DAYS DECAY AND ONE THIRD CORE WITH 400 DAYS DECAY. WITH THIS HEAT LOAD, THE APPLI-CANT STATED THAT THE POOL TEMPERATURE IS MAINTAINED AT OR BELOW 165 DEGREES F.
WE CONSIDER THE MAXIMUM ABNORMAL HEAT LOAD AS ONE FULL CORE DISCHARGE PLUS ALL OTHER FUEL STORAGE CELLS IN THE STORAGE P00L FILLED WITH SUCCESIVE NORMAL REFUELING BATCH DISCHARGES.
WE WILL REQUIRE THE APPLICANT TO DEMONSTRATE THAT THE SPENT FUEL P0OL COOLING SYSTEM IS CAPABLE OF MAINTAINING THE POOL WATER TEMPERATURE BELOW BOILING WHEN THE P0OL CONTAINS A FULL CORE DISCHARGE AND ALL OTHER STORAGE SPACES ARE FILLED WITH NORMAL DISCHARGES.
RESPONSE
BVPS-2 HAS DESIGNED AND EVALUATED THE FUEL P00L COOLING SYSTEM IN ACCORDANCE WITH NUREG-0800 REV.1, SRP 9.1.3 AND NRC BTP ASB 9-2.
SECTIONS III.1.D AND III.1.H 0F SRP 9.1.3 SPECIFICALLY ADDRESS THE DECAY TIMES AND HEAT LOADS TO BE CONSIDERED, THE TEMPERATURFS TO BE MAINTAINED AND UNDER WHICH CONDITIONS SINGLE FAILURES MUST BE ADDRESSED. THE HEAT LOAD CASES, SINGLE FAILURE ASSUMPTIONS AND FUEL P0OL TEMPERATURES DESCRIBED IN FSAR SECTION 9.1.3 MEET THE ACCEPTANCE CRI-TERIA 0F SRP 9.1.3 (INCLUDING ASB 9-2). THE TWO ADDITIONAL CASES IDENTIFIED IN SER OPEN ITEM 134 ARE BEYOND THE ACCEPTANCE CRITERIA 0F SRP 9.1.3.
THE REVIEWER SHOULD CITE THE BASIS FOR STATING THAT THESE ARE REQUIREMENTS.
01 136 THE PHASE II PORTION OF THE REVIEW RELATES TO THOSE HEAVY LOADS HANDLING SYSTEMS C0VERED IN THE PHASE I REVIEW.
THIS REVIEW CONFIRMS THAT EITHER THE HANDLING SYSTEM, DESIGN IS IN COMPLIANCE WITH NUREG-0554 " SINGLE-FAILURE-PR0OF CRANES FOR NUCLEAR POWER PLANTS" OR THE CONSEQUENCES OF A LOAD DROP ACCIDENT WILL NOT EXCEED THE RECOMMENDED GUIDELINES PRESENTED IN SECTION 5.1 0F NUREG-0612.
WE WILL REPORT ON THE RESOLUTIONS TO BOTH PHASE I AND PHASE II 0F NUREG-0612 IN SUPPLEMENTS TO THE SER.
RESPONSE
THE PHASE I REVIEW WAS DISCUSSED IN A JUNE 15, 1984 MEETING WITH Mt. SINGH OF THE NRC STAFF AND AGREEMENTS WERE REACHED.
DOCUMENTATION OF THIS EETING WILL BE TRANSMITTED UNDER SEPARATE COVER.
. 01 137 WE CANNOT CONCLUDE THAT THE SSWS ADEQUATELY ENSURES A SUFFICIENT SUPPLY OF SERV-ICE WATER TO ACCOMPLISH UNIT SHUTDOWN AND SUBSEQUENT C00LDOWN IN THE EVENT THE SWS SEISMIC CATEGORY I INTAKE STRUCTURE IS LOST DUE TO A GAS 0LINE BARGE IMPACT /
EXPLOSION SINCE WE CANNOT CONFIRM THAT THE REQUIREMENTS OF GENERAL DESIGN CRI-TERI A 45 AND 46 ARE MET.
THE APPLICANT HAS NOT ADDRESSED THE MEASURES (E.G DESIGN AND PROCEDURES) THAT WILL BE TAKEN TO PREVENT F0ULING AND DEGRFn~ ION OF THE SSWS AS A RESULT OF MARINE GROWTH NOR HAS THE APPLICANT CONFIRMEL ! HAT THE PERIODIC SSWS TESTING AND INSPECTION WILL BE ASSURED BY TECHNICAL SPECIFICATIONS.
RESPONSE
THE SWS AND SSWS PUMPS AND PIPING ARE BOTH PROVIDED TO SUPPLY WATER TO THE SERV-ICE WATER HEADERS LOCATED IN THE SWS VALVE PIT.
FROM THIS TIE IN CONNECTION, THE WATER LINES OF THESE SYSTEMS ARE C011 MON.
THE INJECTION OF CHLORINATED WATER, AS DESCRIBED IN THE RESPONSE TO OUESTION 410.7, AMENDfENT 5, OCCURS DOWN-STREAM 0F THIS CONNECTION POINT.
01 138 THE APPLICANT HAS NOT COMMITTED TO PERFORM PERIODIC TESTS TO VERIFY THAT THE INSTRUMENT AIR QUALITY IS BEING MAINTAINED. THE APPLICANT SHALL PROPOSE SUCH A PROGRAM.
RESPONSE
IN ORDER TO ENSURE ADEQUATE OPERATING PERFORMANCE, INSTRUMENT AIR QUALITY AT THE FILTER DISCHARGE WILL BE TESTED FOR DEWPOINT AND PARTICULATE CONTAMINATION ANNU-ALLY.
01 140 THE APPLICANT HAS INDICATED COMPLIANCE WITH REGULATORY GUIDE 1.95 " PROTECTION OF NUCLEAR POWER PLANT CONTROL ROOM OPERATORS AGAINST AN ACCIDENTAL CHLORINE RELEASE" POSITION C.4.D.4, THE OTHER POSITIONS C.4.0 (1), (2), (3), (5) AND (6)
HAVE NOT BEEN ADDRESSED.
RESPONSE
THE REQUESTED INFORMATION HAS BEEN PROVIDED IN SECTIONS 6.4, 0.3, 1.8 AND 1.6.
OI 141 IN REFERENCE TO POSITIONS C.3, C.7 AND C.14 0F REGULATORY GUIDE 1.78 "ASSUMP-TIONS FOR EVALUATING THE IMBITABILITY OF A NUCLEAR POWER PLANT CONTROL ROOM.
DURING A POSTULATED HAZARD 0US CHEMICAL RELEASE," WE FIND THAT THE APPLICANT HAS IDENTIFIED VARIOUS HAZARD 0US CHEMICALS STORED ON SITE AND BEING TRANSPORTED 1
~
n l ON THE CONRAIL LINE ADJACENT TO THE BVPS-2 SITE.
HOWEVER THE REVIEW 0F THIS MATERIAL AND THE APPLICANTS EVALUATION OF THE POTENTIAL HAZARD TO THE HABITA-BILITY OF THE CONTROL ROOM IS NOT SUFFICIENT. THE APPLICANT SHALL ADDRESS THE AB0VE REGULATORY GUIDE POSITIONS. THERFORE, COMPLIANCE WITH THE GUIDELINES OF REGULATORY GUIDE 1.78 IS AN OPEN ITEM AT THIS TIME.
RESPONSE
THE REQUESTED INFORMATION IS PROVIDED IN SECTIONS 6.4, 2.2, 2.3, 1.8, AND 1.6.
OI 142 THE APPLICANT HAS FAILED TO INDICATE THAT THE BVPS-2 COMPRESSED AIR SYSTEM SHARED WITH BVPS-1, WHICH IS UTILIZED DURING THE FIRST HOUR AFTER A RADI0 ACTIVE RELEASE, IS DESIGNED TO SEISMIC CATEGORY I REQUIREMENTS. THIS SYSTEM SHOULD BE DESIGNED TO SEISMIC CATEGORY I REQUIREMENTS PER THE CONTROL ROOM HABITABILITY ANALYSIS.
RESPONSE
THE BOTTLED COMPRESSED AIR SYSTEM SHARED WITH BVPS-1 IS DESIGNED TO SEISMIC CATEGORY I REQUIREMENTS.
OI 143 THE APPLICANT'S RESPONSE TO OUR CONCERN REGARDING COOLING FOR SAFETY RELATED EQUIPMENT ASSOCIATED WITH SYSTEMS SUCH AS THE SERVICE WATER SYSTEM, PRIMARY PLANT COMPONENT COOLING WATER SYSTEM ANJ CONTAINMENT ISOLATON SYSTEM LOCATED IN THE FUEL BUILDING IS NOT SUFFICIENT. SINCE THE FUEL AND DECONTAMINATION BUILDING VENTILATION SYSTEM IS A NONSAFETY-RELATED SYSTEM, WE WILL REQUIRE THAT THE APPLICANT DEMONSTRATE THAT THE ESSENTIAL EQUIPMENT HOUSED IN THE FUEL BUILDING, IS BOTH ACCESSIBLE TO PERSONNEL AS NEEDED AND THAT IT IS ENVIRONMENTALLY QUALI-FIED FOR THE CONDITIONS WHICH COULD EXIST WHEN THE FUEL BUILDING VENTILATION SYSTEM IS UNAVAILARLE DURING EMERGENCY CONDITIONS.
RESPONSE
NO ACCESS TO THE FUEL BUILDING IS REQUIRED DURING EMERGENCY CONDITIONS. THE FUEL P0OL COOLING PUMPS CAN BE OPERATED FROM THE CONTROL R00M. THE FUEL P0OL LEVEL AND TEMPERATURE ARE INDICATED IN THE CONTROL R00M. SERVICE WATER CAN BE USED FOR EMERGENCY MAKE-UP BY INSERTING A SP0OL PIECE AND OPENING A VALVE IN THE SERVICE WATER VALVE PIT IN THE YARD (FIGURE 9.2-1). ISOLATION VALVES FOR PRIMARY PLANT COMPONENT COOLING WATER ARE LOCATED IN THE AUXILIARY BUILDING (FIGURE 9.2-13).
THE ONLY PART OF THE CONTAINMENT ISOLATION SYSTEM IN THE FUEL BUILDING IS THE GATE VALVE ISOLATING THE FUEL TRANSFER TUBE (ITEM 6 ON FIGURES 9.1-1 AND 9.1-2).
THIS VALVE IS OPEN ONLY DURING REFUELING OPERATIONS, AND NO EVENT REQUIRING CONTAINMENT ISOLATION IS POSTULATED DURING REFUELING.
SAFETY-RELATED EQUIPMENT IN THE FUEL BUILDING IS QUALIFIED FOR THE ENVIRONMENTAL CONDITIONS LISTED IN TABLE 3.11-2.
THE FUEL BUILDING ENVIRONMENTS FOR l
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ANTICIPATED OPERATIONAL OCCURRENCES AND ACCIDENTAL CONDITIONS INCLUDE THE EFFECTS OF LOSS OF THE FUEL BUILDING VENTILATION SYSTEM.
j-OI 144
.WE CANNOT. DETERMINE WHETHER THE MCC'S (MCC 2-E03 AND MCC 2-E04) ARE SAFETY
- RELATED. IF. THEY ARE, WE WILL REQUIRE THE APPLICANT TO DEMONSTRATE THAT THE TWO j
RECIRCULATION TRAINS EET THE APPROPRIATE REQUIREMENT FOR A SAFETY RELATED SYS-TEM SUCH AS PROTECTION AGAINST NATURAL PHENOMENA AND ESSENTIAL POWER SUPPLIES.
[
RESPONSE.
i MCC 2-E03 AND MCC 2-E04 ARE SAFETY RELATED, REFER TO TABLE 3.2-1.
L THE VENTILATION EQUIPMENT FOR THESE CUBICLES IS SAFETY RELATED, REFER TO TABLE
[
3.2-1. THE EQUIPENT IS POWERED FROM CLASS 1E BUSES AND IS HOUSED IN A QA CATE-GORY II STRUCTURE.
1' 01 145 d
ALL AIR EXHAUSTED FROM THE AUXILIARY BUILDING AND RADWASTE AREA PASSES THROUGH THE SAFETY-RELATED (SEISMIC CATEGORY I), REDUNDANT FILTERS OF THE SLCRS.
AIR-BORNE PARTICULATE AND NDBLE' GASES ARE CONTINUALLY SAMPLED AND ANALYZED BY A RADIATION MDNITORING SYSTEM.- HOWEVER, WE WILL REQUIRE THAT.THE' APPLICANT DEMON-1 STRATE THAT THE PRESENT AIRBORNE PARTICULATE AND NOBLE -GASES MDNITORING SYSTEM SUFFICIENTLY COVERS THE SPECTRUM OF POTENTIAL RADIOLOGICAL RELEASES (INCLUDING IODINE).
RESPONSE
AS INDICATED. IN SECTION 11.5.2.4.2, AMENDENT 4, THE OFF-LINE GAS AND PARTICU-LATE MONITOR FOR THE ELEVATED RELEASE POINT PROVIDES THE SAMPLING CAPABILITY AND.
l JTHE NECESSARY RANGE TO EET THE ' INTENT OF NUREG-0737, ACTION ITEM II.F.1,-
t ATTACHMENTS 1 AND 2.- THE DETECTABLE RANGE FOR THE PARTICULATE DETECTOR IS 10 E -
i 10 TO 10 E-5 MICRO-CURIES /CC. THE DETECTABLE RANGE FOR THE THREE GAS DETECTORS I
ARE 10 E-7 T0.10 E-1,10 E-4 TO 10 E+2 AND 10 E-1 TO 10 E+5 MICRO-CURIES /CC.
I OI 14'6 THE APPLICANT HAS NOT INDICATED WHETHER THE EMERGENCY SWITCHGEAR RD0M VENTIL-ATION SYSTEM.IS-LOCATED IN AN AREA WITHIN THE - SERVICE BUILDING WHICH IS ' PRO-TECTED FROM NATURAL PHEN 0ENA. WE NOTE THAT THE TOP STORY OF THE SERVICE. BUILD-i.
. ING. IS STEEL FRAMED,- NONSEISMIC STRUCTURE WHICH IS NOT. DESIGNED TO WITHSTAND NATURAL-PHENDENA INCLUDING TORNADOS AND TORNADO MISSILES.
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. RESPONSE THE ENTIRE EMERGENCY SWITCHGEAR ROOM VENTILATION SYSTEM, INCLUDING DISTRIBUTION DUCTWORK, IS LOCATED WITHIN THE SEISMICALLY AND TORNADO MISSILE DESIGN STRUC-TURES. THE SYSTEM IS DESIGNED TO SEISMIC QA CATEGORY I REQUIREMENTS. NO PORTION OF THE EMERGENCY SWITCHGEAR ROOM VENTILATION SYSTEM IS LOCATED IN THE NONSEIS-MIC/ TORNADO PROTECTED PORTION OF THE SERVICE BUILDING.
01 147 THE APPLICANT STATES THAT THE SLCRS IS LOCATED IN THE SLCRS VENTILATION EQUIP-MENT ROOM ON THE TOP 0F THE AUXILIARY SUILDING AND IS NOT PROTECTED FROM TORNA-DOES, HURRICANES OR MISSILES GENERATED BY NATURAL PHENOMENA. THIS AREA IS SEIS-MIC CATEGORY I. THE BASIS GIVEN FOR THIS IS THAT IT HAS BEEN ASSUMED THAT THOSE EVENTS REQUIRING SLCRS FUNCTION (SUCH AS A LOCA) WILL NOT OCCUR CONCURRENT WITH THESE NATURAL PHENOMENA.
FROM OUR REVIEW, WE CONCLUDE THAT THE SLCRS DESIGN AND THE APPLICANT'S EXPLANA-TION IS ACCEPTABLE PROVIDED IT CAN BE SHOWN THAT THE SLCRS SERVES NO EMERGENCY SHUTDOWN FUNCTION. WE WILL REQUIRE THE APPLICANT TO VERIFY AND DEMONSTRATE THAT THE SLCRS IS NOT REQUIRED FOR A SAFE SHUTDOWN (INCLUDING H0T STANDBY).
I
RESPONSE
THE SLCRS IS NOT REQUIRED FOR SAFE SHUTDOWN.
THE DESIGN CALCULATIONS FOR COOL-ING AVAILABLE SAFETY-RELATED EQUIPMENT TAKE NO CREDIT FOR THE SLCRS.
01 149 THE APPLICANT HAS NOT PROVIDED A RESPONSE TO OUR MARCH 10, 1980 GENERIC LETTER CONCERNING THE AUXILIARY FEEDWATER SYSTEM (AFWS) DESIGN INCLUDING THE CRITERIA 0F TMI TASK ACTION PLAN, NUREG 0737, ITEM II.E.1.1. THIS RESPONSE SHOULD INCLUDE THE FOLLOWING:
A.
A DETAILED POINT BY P0 INT REVIEW 0F THE AFWS DESIGN AGAINST THE CRITERIA 0F THE SRP SECTION 10.4.9 M10 BRANCH TECHNICAL POSITION ASB 10-1.
B.
A POINT-BY-POINT REVIEW 0F THE AFWS DESIGN, TECHNICAL SPECIFICATIONS, AND OPERATING PROCEDURES AGAINST THE GENERIC SHORT-TERM AND LONG-TERM RECOMENDA-TIONS DISCUSSED IN THE MARCH 10, 1980 LETTER AND NUREG-0611.
C.
M4 EVALUATION OF THE DESIGN BASIS FOR THE AFWS FLOW REQUIREMENTS, AND VERI-FICATION THE THE AFWS WILL MEET THESE REQUIREMENTS (REFER TO ENCLOSURE 2 0F THE MARCH 10, 1980 LETTER).
D.
A CURSORY REVIEW 0F THE AFWS SIMPLIFIED RELIABILITY ANALYSIS AS DESCRIBED IN THE FSAR APPENDIX 10A TO SECTION 10.4.9 HAS SHOWN THAT THE INFORMATION PRO-VIDED IS INADEQUATE IN THAT THE QUANTIFICATION OF THE ANALYSIS CANNOT BE r
- - - - - i - --
-ami--
ii l
VERIFIED.
THEREFORE, THE APPLICANT SHOULD PROVIDE AN AFWS RELIABILITY ANALYSIS CONSISTENT WITH THAT DESCRIBED IN THE t%RCH 10, 1980 LETTER AND NUREG-0611, OR PROVIDE A COMPARIS0N OF THE DATE BASES, METHODOLOGY, ASSUMPTIONS, AND NUMERICAL RESULTS USED IN AFWS SIMPLIFIED RELIABILITY ANALYSIS DISCUSSED IN APPENDIX 10A AGAINST THAT CONTAINED IN NUREG-0611.
INCLUDE A VERIFICATION OF COMPLIANCE WITH THE 10 TO THE MINUS 4 POWER TO 10 TO THE MINUS 5 POWER DEMAND NUiERICAL RELIA-BILITY ACCEPTANCE CRITERIA FOR THE LOSS OF t%IN FEEDWATER AND LOSS OF 0FFSITE POWER (LOOP) CASES.
RESPONSE
A.
AS STATED IN TABLE 1.9-1, THE BVPS-2 AUXILIARY FEEDWATER SYSTEM IS IN CON-FORMANCE WITH THE ACCEPTANCE CRITERIA 0F STANDARD REVIEW PLAN SECTION 10.4.9 AND BRANCH TECHNICAL POSITION ASB 10-1.
REFER TO TABLE Q410.52-1, WHICH PROVIDES A CROSS REFERENCE BETWEEN THE SRP, GDC/ SUBJECT AND BTP.
B.
REFER TO TABLE Q410.52-2, WHICH ADDRESSES NUREG-0611 RECOMMENDATIONS TO IMPROVE THE RELIABILITY OF THE AFWS.
C.
REFER TO TABLE Q410.52-3, WHICH PROVIDES THE BASIS FOR THE AFWS FLOW REQUIREMENTS.
D.
THE RELIABILITY ANALYSIS PROVIDED IN APPENDIX 10A IS CONSISTENT WITH THE RELIABILITY ANALYSIS GIVEN IN NUREG-0611.
THE DATA BASES, ETHODOLOGY,
ASSUMPTIONS, AND NUMERICAL RESULTS OF APPENDIX 10A COMPARE WITH NUREG-0611 AS FOLLOWS:
THE DATA BASES USED TO DETERMINE THE AFWS UNAVAILABILITY YALUES GIVEN IN APPENDIX 10A WAS OBTAINED FROM A NUMBER OF DOCUMENTED SOURCES. THE UNAVAIL-ABILITY VALUES FOR CERTAIN COMPONENTS AND SOURCES ARE PRESENTED IN TABLE Q410.52-4.
OTHER UNAVAILABILITY VALUES AND THEIR SOURCES ARE GIVEN IN APPENDIX 10A.
THE ETHODOLOGY AND ASSUMPTIONS USED IN APPENDIX 10A ARE DESCRIBED IN SEC-TION 10A.3. THE RELIABILITY APPROACH PRESENTED IN NUREG-0611, APPENDIX III, SECTION 4, WAS FOLLOWED IN THE PERFORMANCE OF THIS RELIABILITY ANALYSIS.
THE GENERIC EVENT TREE DESCRIBED IN NUREG-0611, APPENDIX III, SECTION 4.3, DEPICTS THE IMPORTANCE OF THE AFWS DURING A LOSS OF MAIN FEEDWATER EVENT.
THE BVPS-2 ANALYSIS USES EVENT SEQUENCE DIAGRAMS TO SHOW IN MORE DETAIL THE P0TENTIAL FAILURES THAT COULD DOMINATE THE UNAVAILABILITY OF THE AFWS. THIS DETERMINISTIC APPR0ACH PROVIDES THE BASIS FOR THE UNAVAILABILITY CALCU-LATIONS PRESENTED IN APPENDIX 10A.
THE FAULT TREE LOGIC APPROACH FROM NUREG-0611, APPENDIX III, SECTION 4.4, WAS USED TO DEVELOP THE LOGIC FOR THE UNAVAILABILITY CALCULATIONS PRESENTED IN APPENDIX 10A.
THE NUMERICAL RESULTS OF THE ANALYSIS ARE GIVEN IN FIGURES 10A-1 AND 10A-2 0F APPENDIX 10A.
THE UNAVAILABILITY OF THE AFWS FOR A LOSS OF MAIN FEED-WATER EVENT WIH OFFSITE POWER AVAILABLE WAS CALCULATED TO BE 8.7 TIMES 10 TO THE MINUS 6 POWER.
THE FOLLOWING TABULATION PROVIDES A COMPARISON OF THE RESULTS OF THE UNAVAILABILITY CALCULATIONS FOR BVPS-2 WITH THE RELIABILITY STUDIES OF OTHER UNITS OF SIMILIAR DESIGN.
r-l 0,
UNIT UNAVAILABILTY/ DEMAND SOURCE
- WASH 1400 (SURRY)
.000037 USNRC 1975a SAN 0N0FRE 2&3
.000022 USNRC 1981b ZION 182
.0000042 USNRC 1981c
. BVPS-2
.0000087 BVPS-2 FSAR L
APPENDIX 10A
-IN GENERAL, DATA VARIATION IS DOMINATED BY COMMON CAUSE FAILURES, OPERATING ERRORS, AND TEST AND MAINTENACE ERRORS.
TABLES Q410.52-1 THROUGH Q410.52-4 FOLLOW.
l 1
l
TABLE Q410.52-1 Conformance Review of Standard Review Plan Section 10.4.9 and Branch Technical Position ASB 10-1 SRP Section Subject FSAR Sections 10.4.9.11.1 General Design Criterion (GDC) 2 3.4; 3.7; 3.8; 10.4.9.1 10.4.9.II.2 GDC 4 3.5; 3.6; 3.11; 10.4.9.1 10.4.9.11.3 GDC 5 10.4.9.1 10.4.9.11.4 GDC 19 10.4.9.1; Appendix 5A 10.4.9.11.5 GDC 34/44 10.4.9.1; 10.4.9.3 10.4.9.11.6 GDC 45 6.6.2; 10.4.9.1 10.4.9.II.7 GDC 46 3.9B.6; 3
10.4.9.1 FSAR Reference BTP ASB Section Subject (Section) 10-1.B.1 System Arrangement and Power Sources 10.4.9.2 10-1.B.2 Separate and Multiple Sources of 10.4.9.2; Motive Energy 10.4.9.3 10-1.B.3 Feedwater Supply to any Combination of 10.4.9.2; Stean Generators 10.4.9.3 10-1.B.4 Redundancy 10.4.9.3 10-1.B.5 High Energy Line Break 10.4.9.3
~
' TABLE Q410.52-2 Review of NUREG-0611 Recommendations to Improve Reliability of Auxiliary Feedwater Systems Short-Term Recommendations GS-1 Te_chnical Specification Time Limits The outage time limit and subsequent action time limit for an inoperable auxiliary. feedwater pump and associated train are as required by the Standard Technical Specifications.
The limits will be given in the BVPS-2 Technical Specifications (Chapter 16 of the FSAR).
GS-2 Administrative Controls on Manual Valves Not applicable to BVPS-2.
BVPS-2 does not have common suction piping between the primary water source (*TK 210) and the auxiliary feedwater pump suction (Figure 10.4-24).
there are no single valves or multiple valves in series which coiild interrupt all auxiliary i
feedwater flow if inadvertently left closed.
GS-3 Throttling of auxiliary Feedwater Flow Not applicable to BVPS-2.
The auxiliary feedwat er flow control valves are normally in an open position in read ines s for system ope: ration.
GS-4 Emergency Procedure for Initiaging Backup Water Supply Procedures.will be written and made available to plant operators which will describe the proper operator actions necessary under the two cases of the recommendation.
GS-5 Initiation of Auxiliary Feedwater Following a Loss of AC Power Not applicable to EVPS-2.
Follow ~-
i loss of a.c.
power, the turbine-driven auxiliary feedwater pump is capable of providing the required flow for. at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without any operator action.
CS-6 Flow Path Verification Plant procedures to verify that valves are properly aligned follow-ing testing or maintenance shall be implement ed.
BVPS-2 will fol-low, where possible, the Standard Technical Specification, Rev. 4.
-GS-7 Non_-Safety Grade, Non-Redundant, Automatic Initiation Signals Not applicable to BVPS-2. ~The automatic start signals and associ-ated circuitry are safety grade..
~
. CS-8 Automatic Initiation of Auxiliary Feedwater System I
Not applicable to BVPS-2.
The auxiliary feedwater system is auto-matically. initiated.
Additional Short-Term Recommendations t
' 5.3.1 Primary Water Source Low Level Alarm Redundant safety grade level indication for the primary plant demineralized water storage tank (PPDWST) is provided in the main control room.
A low level alarm is provided to indicate if the PPDWST inventory has decreased to a level sufficient to supply auxiliary feedwater for at least 20 minutes.
l-5.3.2 Pump Endurance Test j
As stated in the response to Question 640.23(a) Amendment 7, the
-auxiliary feedwater pumps will undergo 48-hour endurance tests in accordance with SRP Section 10.4.9.
(Reference Sections
- 14. 2.12.3 2.1 and 14. 2.12.3 2. 2) 5.3.3 Indication of Flow to Steam Generators i
Safety grade, redundant flow transmitters located upstream of the cavitating venturis provide main control room indication of the flow to each steam generator.
These transmitters meet the power diversity requirements of Branch Technical Position ASB 10-1.
5.3.4 System Availability During feriodic Surveill_ance Testing Not applicable to BVPS-2.
The limiting condition of operation requires all three steam generator auxiliary feedwater pumps to be j
operable during modes 1, 2, and 3.
Long-Term Recomumendations GL-1 Automatic Initiation of Auxiliary Feedwater System l
See recommendations GS-7 and GS-8.
l GL-2 Single Valv_es in Flow Path See reconumendation GS-2.
GL-3 Elimination of System Dependency on AC _ Power Followig a Complete
+
Loss of AC Power-See recomunendation GS-5.
i
.m-m m.
m
. GL-4 Prevention of Multiple Pump Damage due to Loss of Suction Resulting from Natural Phenomena Not applicable to BVPS-2.
The PPDWST and all interconnected piping is protected from earthquakes and tornadoes.
GL-5 Non-Safety Grade, Non-Redundant Initiation Signals See recommendation GS-7.
s t
t i
6-
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. k, s
i T
y i.
TABLE Q410.52-3 Basis for Auxiliary Feedwater System Flow Requirements FSAR Reference (Table-T)
Item
- Subject (Section-S)
I l
1.a Plant transients and accident conditions S-10.4.9.1 l
-1.b Maximum RCS pressure T-5.4-13 Fuel temperature or damage limits S-4.4 RCS cooling rate S-5.3.2.1 Minimum steam generator level S-5.4.2 2.a Maximum reactor power T-15.0-3 S-15.0.3.1 2.b Time delay from initiating event to reactor trip I-15.0-4 2.c Plant parameters which indicate AFWS flow S-10.4.9.5 Time delay before introduction of AFWS flow to steam generators S-10.4.9.2 2.d Minimum steam generator water level when initi-ating event occurs T-15.0-4 2.e Initial steam generator water' inventory and T-15.1-3 depletion cates T-15.2-2 T-15.3-3 T-15.4-3 T-15.6-5 Reactor decay heat rate S-15.0.10-2.f Maximum pressure in steam generators S-15.1.4.1 S-15.1.5.1 S-15.2.2.1 S-15.2.3.1 S-15.2.6.1 S-15.2.7.1 S-15.6.3.1; S-15.6.5.2 2.g-Minimum number of' steam generators that must receive AFWS flow' S-10.4.9.1 2.h RC flow condition - RC pump operation or natural.
.T-15.0-2 circulation T-15.0-3 1
b-l-ri.
._m
-u_...
. FSAR Reference (Table-T)
Item
- Subject' (Section-S) 2.i Maximum AFWS inlet temperature S-10.4.9.2 2.j Time delay to direct AFWS flow to intact steam generators af ter postulated steam or feedwater line break S-10.4.9.3 l
2.k Volume and maximum temperature of water in main S-15.0.11 feedwater lines T-15.0-3
'2.1 Operating condition of steam generator blowdown following initiating event S-10.4.8.5 2.m Primary and secondary water and metal sensible heat S-15.0.11 2.n Time at hot standby and time to cooldown RCS to RHR system cut in temperature S-10.4.9.2 3.
Verify AFWS pumps will supply necessary flow to the steam generators considering a single failure S-10.4.9.3 4
Note:
- Refer ' to Enclosure 2 'in NRC letter of March 10, 1980, to near-team operating license applicants concerning auxiliary feedwater system design.
i TABLE Q410.52-4 Basic Component Probability of Failure on Demand Failure Component Probability (Q)
Reference Pump (Motor)
.00581 UFNRC 1981c Pump (Turbine)
.0116 USNRC 1981c Valves (MOV, HCV)
.000201 USNRC 1981c Valves (SOV)
.001 USNRC 1975a Valves (Manual)
Operator Error
.003 USNRC 1975b Valves (Manual)
Mechanical Failure
.0000193 USNRC 1981c Tank Failure
.00000031 USNRC 1981c Service Water
.00000372 USNRC 1981c Steam Generator
.000133 SWEC 1975 Emergency Diesel Generator Failure
.053 USNRC 1975a Pipe Length
.00000014 Melvin and Maxwell 1974