ML20094G433
| ML20094G433 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/08/1984 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Harold Denton, Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-4-118, NUDOCS 8408130312 | |
| Download: ML20094G433 (6) | |
Text
-
%r5 412 787 51 1 (412)923-1960 Nuclear Construction Division Te o 4 2)787-2629 Robi n aza. Buildin9 2. Suite 210 g
Mr. Harold R. Denton Of fice of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Mr. George W. Knighton, Chie f Licensing Branch 3 O fice of Nuclear Reactor Regulation f
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Do cke t No. 50-412 Draf t SER Open Items 150 and 151, Equipment Qualification Gentlemen:
This le tter fo rwards res ponses to the issues listed below.
The following items are enclosed: : Response to Open item 150 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report :
Response to Open Item 151 of the Beaver Valley Power Station Unit No. 2 Draft Safety Evaluation Report If there are any questions in this regard, please cont act C.
L.
Hill at (412) 787-5141.
DUQUESNE LIGHT COMPANY
\\
By E. Q1."Wooleve r Vice President CLH/wjs Enclosures jotif l
SUESCRIBED AND S RN TO BEFORE ME THIS
[ O DAY OF mf 1984.
N in C
/
Notary Public ELVA G. LESONDAM, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSl0N EXPIRES OCTOBER 20,1986 8408130312 840808 gDRADOCK05000gg
g:
.p p.
i-United Stct"Js Nuclecr Regulctory Conunicaicn Mr. Gestgi W. Knighten,.Chisf Page'2
' COMMONWEALTH OF PENNSYLVANIA )
)
ss:
COUNTY OF ALLEGHENY
)
On this.[
day of ad
///
, before me,
/
f a Notary-Public in and for - said - Commonwealth and County, personally
.. appeared E. J. Woolever, who 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 behalf of said Company, and (3) the.
statements set forth in the Submittal are true 'and correct to the best of his knowledge.
J.
yWeh Notary Public ELVA G. LESONDAK, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISS!ON EYT"""* OCTOBER 20,1o86
ENCLOSURE 1 Draf t SER Open Item No.150 (Section 3.10.1):
" Seismic and Dynamic Qualifi-cation" b
' 1.
The - applicant should identify the in plant dynamic loads which may be induced during the operation of Beaver Valley 2 plant, and address their effects on the seismic and dynamic qualification of safety-related equipment.
2.
The applicant. should commit to establish a maintenance and surveil-lance progra'n to maintain equipment in a qualified status throughout the life of the plant.
3.
The applicant should commit to establish a central filing system capable of retrieving qualification documentation, in an auditable manner, before the plant operation.
4.
The applicant should commit to update the equipment liets and perti-nent qualification information contained in the table s in FSAR Sections 3.9 and 3.10.
5.
For ' any BOP equipment, and NSSS equipment not covered under the Westinghouse generic qualification program as approved by the staff and for which ' single axis and/or single frequency testing methods were used, justification should be provided for the validity of the methodology in light of the current staff licensing criteria as specified in SRP 3.10.
Response
The following response to SER Open Item No. 150 was discussed with NRC Equipment Qualification Branch (EQB) reviewer, A. Lee, during a June 13, 1984, telecon.
1.
Vibrations from normal operating conditions and their af fects on aging will be considered. Loads occuring during faulted or abnormal conditions do not need to be addres sed.
A.
Lee provided these guide. lines during a June 13, 1984, telecon.
- 2.
A' maintenance and surveillance program. to maintain equipment in a qualified status throughout the life of the plant will' be presented at the pre-audit meeting.
3.
A central filing system containing qualification documen':ation in an auditable manner exists at SWEC's Boston of fice and at W's Monroe-ville office.
Copies of qualification documents of those items selected by the NRC for the audit will be available at the site at the time of the audit.
- 4. ;The equipment list and the pertinent qualification information will be updated concurrently with the summary SQRT listing submittal to i
i I'
b
r.-
.s the NRC as agreed to in a meeting on April 10, 1984, and subsequent telephone conversation with the NRC.
- 5. ' Examples comparing single-axis and single-frequency testing with multi-axis and multi-frequency testing will be provided during the pre-audit meeting.
l i
l i
l 6
{
I L
ENCLOSURE 2 Draft SER Open Item No.- 151 (Section 3.10.2):
" Pump and Valve Operability Assurance 1.
There should be a list of equipment types which clearly shows the methods used for qualification.
This list should also address which standards are met, in particular, those cited in SRP 3.10.
2.
Clarification of how aging was incorporated in the qualification process should be contained in the FSAR.
In addition, the applicant should commit to establish a maintenance and surveillance program to maintain equipment in a qualified status t.hroughout the life of the plant.
The criteria for the maintenance and surveillance program should be contained in the FSAR.
3.
SRP 3.10, Paragraph II.1.a(2) indicates that equipment should be tested in the operational condition, that is, normal plant loadings should be superimposed on seismic and dynamic loads, including thermal, flow induced loads and degraded flow conditions.
The FSAR should clearly indicte how this requirement is met.
In addition, the FSAR should clearly show the loads and conditions considered in the qualification of safety-related pumps and valves.
4.
The extent to which draf t standards ANSI /ASME QNPE-1 (N551.1), QNPE-2 (N551.2), QNPE-3 (N551.3), QNPE-4 (N555.4) and N41.6 and issued standard ANSI /ASME B.16.41 are used needs to be clearly stated in the FSAR.
In addition, the applicant's position with respect to Regla-tory Guide 1.148 must also be indicated in the FSAR and the extent to which the applicant' fo llows the requirements and recommendations of IEEE 344-1975.
5.
The FSAR should show the extent to which operational testing is being used to meet the requirements of SRP Section 3.10.
The extent to which operational testing is performed at full flow and temperature conditions should be shown.
Response
1.
The SQRT/PVORT master list of safety related equipment shall identify the ethods used for qualification and the codes and standards that are met.
2.
For an explanation of how aging is incorporated in the qualification program for electrical equipment, please refer to the Environmental Qualifcation of Class 1E Electrical Equipment Report submitted to the NRC on June 22, 1984, via letter 2NRC-4-087.
For the environmental qualification of mechanical equipment, the approach was to identify the non-me ta11ics susceptable to radiation and thermal degradation.
Documentation atesting to the non-metallics's qualified li fe is provided, and on that basis a determination is made as to whether to include it in the maintenance / surveillance program.
t v...:. M 3.
Section 3.9B.3.2 of the FSAR shows the loads and conditions consid-ered in the qualification of safety related pumps and valves.
4.
The implementation section of R. G.1.148 identifies.that the Reguia-tory Guide is applicable. to plants docketed af ter July 1,1981, and for replacement valves ordered after July - 1, 1981, on operating
- plants or for
- plants under construction.
The Reguictory Guide is therefore not applicable on BVPS-2.
The FSAR position on R. G.1.148 will be reviewed to reflect the above position.
The draf t standards identified have not been endorsed.by the NRC and are thus not appli-cable for BVPS-2.
BVPS-2 is complying with SRP 3.10 requirements for
. plants docketed before October 27, 1972, (i.e., as a minimum meeting 3
the requirements of IEEE 344-1971).
5.
The extent to which operational testing of pumps and valves is employed on BVPS-2 is reflected in Section 3.9B.3.2 of the FSAR.
1 I
I
. _..