ML20128F285

Forwards Response to QA Branch Question 260.64 Re Applying QA Requirements to Listed safety-related Structures,Sys & Components.Response Will Be Included in Future FSAR Amend

ML20128F285
Person / Time
Site:	Beaver Valley
Issue date:	06/28/1985
From:	Carey J DUQUESNE LIGHT CO.
To:	Knighton G Office of Nuclear Reactor Regulation
References
NUDOCS 8507080195
Download: ML20128F285 (9)

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'Af 2NRC-5-096 (412) 787-5141 Nuclear Construction Division (412) 923-1960 Robinson Plata Buildin9 2, Suite 210 Telecopy (412) 787-2629 Pittsburgh, PA 15205 June 28, 1985 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 Response to Quality Assurance Branch Question 260.64 Gentlemen:

This letter forwards res ponse to Quality Assurance Branch Question 260.64.

Upon your concurrence, this res pons e will be included in a future FSAR amendment.

DUQUESNE LIGilT COMPANY By J.pgCarey /

Vice President GH0/wjs Attachment cc: Mr. B. K. Singh, Project Manager (w/a)

Mr. G. Walten. NRC Resident inspector (w/a)

SUBSCRIBED AND y WORN Tg BEFORE ME THIS 48/ DAY OF(_../cco f / , 1985.

3 Y lk.~ W W Notary Public 12 A pm g \

United States Nuclear Regulatory Commission ,

Mr. George W. Knighton, Chief (

Response to Quality Assurance Branch Question 260.64 i Page 2

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i COMMONWEALTH OF PENNSYLVANIA )

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COUNTY OF BEAVER )

i On this (( day of ,64p ,

/ [ [4 , before me, a Notary Public in and for said Comdnwealth and County, personally appeared J. J. Carey, 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.

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260.0 Quality Assurance Branch 260.64 Section 17.1.2.2 of the s t andard format (Regulatory Guide 1.70) requires the identification of safety-related structures, systems, and components controlled by the QA program. You are requested to I supplement and clarify the Beaver Valley 2 FSAR in accordance with the following:

Add the A. The following items do not appear on Table 3.2-1.

appropriate items to the table and commit to apply the pertinent QA program requirements to the remaining items during the opera-tions phase or justify not doing so.

Response

A.l. Biological Shielding Biological shielding and post-accident shielding are integral parts of the applicable structures listed in Table 3.2-2.

A.2. Missile Barriers Missile barriers are constructed integrally with, and are considered part of, the applicable structures listed in Table 3.2-2.

A.3. Fabricated Supports The classification for fabricated suppo rt s is consistent with the classification of the system or equipment being supported.

A.4. Items Within the Scope of Regulatory Positions C.2 and C.3 of Regu-latory Guide 1,29 Structures, systems, and component s designed in accordance with paragraphs C.2 and C.3 of Regulat ry Guide 1.29 are designated non-nuclear safety, Seismic Category II, and either QA Category 11 or 111 based on their function as defined in Section 3.2.2.3. St anda rd industry quality control practices will be applied during the opera-tions phase.

A.S. Spent Fuel Pool and Liner The s pe nt fuel pool is constructed integrally with, and considered part of, the saf e ty-related fuel building listed in Table 3.2-2.

The spent fuel pool liner is designated non-nuc le ar safety, QA Category 11 based on its funct ion as defined in Sect ion 3.2.2.3. l Sect ion 9.1.2.3 has been revised to indicate that the s pe nt fuel pool liner is classified Seismic Category 11. Standard indus try quality control practices will be applied during the ope rations i phase, j A.6. Fuel Assemblies Table 3.2-1 will be revised to include fuel assemblies.

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A.7. Core Support Structure See Table 3.2-1, page 22.

A.8. Fuel Transfer System See Table 3.2-1, page 21.

A.9. Steam Generator Steam Flow Restrictors Steam generator steam flow restrictors are fabricated integrally with, and considered part of, the steam generator outlet nozzles as listed in Table 3.2-1, page 1.

A.10. Station Stack Not applicable to BVPS-2.

A.ll. Plant Sampling System See Table 3.2-1, page 9.

A.12. QSS Chemical injection Pumps See Table 3.2-1, page 13.

A .13 . Reactor Coolant Pump Seals The BVPS-2 Reactor Coolant Pumps Seals are designated non-nuc le ar safety. Standard industry quality control practices will be applied during the operations phase.

A.14. Service Building See Table 3.2-2, page 1.

A.15. Auxiliary Building See Table 3.2-2, page 1.

A.16. Cable Vault See Table 3.2-2, page 1.

A.17. Pipe Tunnels See Table 3.2-2, page 1 (note 2), and page 2 (note 7).

A.18. Foundations For (a) Electrical Conduit Ducts (including manholes)

Foundations for electrical conduit ducts ( including manholes)

! are an integral part of the Class IE cable suppo rt s listed in l

Table 3.2-1, page 24. Also, see response to A.27.c.

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(b) Service Water Pipes BVPC-2 does not have separate foundations for the service water piping.

(c) Sheetpile Retaining Walls Adjacent to Primary intake Structure The primary intake structure and sheetpile retaining walls adjacent to the primary intake structure were licensed as part of BVPS-l.

(d) Cooling Water Discharge Pipe BVPS-2 does not have separate foundations for the cooling water discharge piping.

A.19. Modifications to Site Grading Any modifications to Site Grading will be des ignat ed non-nuc le ar safety, QA Category 111 based on its function as defined in Section 3.2.2.3. Standard industry quality control practices will be applied during the operations phase.

A.20. Containment Sump The Containment Sump is an integral part of the containment struc-ture listed in Table 3.2-2.

A.21. Containment Penetrations, Air Locks, and Access Hatches See Table 3.2-1, page 24 for containment electrical penetrations.

Table 3.2-1 will be revised to include cont ainme nt piping pe ne t r a-tions, air locks, and access hatches.

A.22. Control Building Radiation Monitor (Outside Air intake)

Thu BVPS-2 design does not include an outside air intake control building radiation monitor. The BVPS-2 design utilizes QA Category I control room area radiation monitors. Table 3.2-1 will be revised to include control building area radiation monitors.

f A.23. Control Building Chlorine Monitor (Outside Air intake)

Table 3.2-1 will be revised to include control building chlorine monitor (outside air intake).

A.24. Fuel Building Radiation Monitor The fuel building radiation monitor is designat ed non-nuc le ar safety, QA Category II, based on its function as defined in Section 3.2.2.3. Standard industry quality control practices will be applied during the operations phase.

A.25. Expendable and Consumable items When utilized in safety-related systems, the consumable items listed below shall be subject to the pe rt inent QA program req ui rune nt s during the operations phase.

(a) emergency generator diesel fuel (b) hydraulic anubber fluids (c) reagents (d) resins (e) boric acid A.26. Accident Related Meteorological Data Collection Equipment BVPS does not utilize safety-related meteorological data collection equipment. Meteorological equipment used at BVPS shall be subject to s tandard industry quality control practices during the operations phase.

A.27. Standby AC Auxiliary Power Systems (Class IE)

(a) See Table 3.2-1, pages 9 through 12 and 23. The governor, voltage regulator, and excitation system are an integral part of the Diesel Generator.

(b) Instrumentation, control and powe r cables, unde rground crhie splices, connectors, and terminal blocks are considered part of the Class 1E cable listed in Table 3.2-1, page 24.

(c) Class 1E cable supports are ident ified in Table 3.2-1, page 24.

Table 3.2-1 will be revised to include Class 1E c onduit and cable trays.

(d) Valve operators that are required to pe rfo rm a safety funct ion are qualified to Class 1E requirements and are included in Table 3.2-1 under ins t rume nt at ion and controls required to pe rfo rm a safety function.

(e) Electrical pe net rat ions of containment are listed in Table 3.2-1, page 24.

Safety-related protect ive devices used fo r safety-related circuits passing through containment penetrations will be added to Table 3.2-1. No n-nuc le ar safety circuits passing through contalment penet r at ions have non-nuc le ar safety primary and backup protective devices, t (f) BVPS-2 does not have Class 1E AC lighting batteries.

A.28. DC Power Systems (Class 1E)

(a) See response to A.27.c.

(b) Table 3.2-1 will be revised to include battery racks.

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' 260.64 B. Provide'a commitment that al ai'ety-related instrumentation and

. y7 controls (I&C) described in Sections 7.1 through 7.6 of the FSAR and other safety-related 1&C fo r , safety-related fluid sys tans a' '

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will be' subject to the pertinent requirements of the FSAR Appen-

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' dix B QA program. This can be-done by a footnote to FSAR Table 3.2-1. s

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., B. Instrumentation and controla > (I&C) required to perfo rm a safety

, function are listed in' Table 3.2-1. Consequently, all safety-related I&C described in Sections 7.1 through 7.6 and other safety-related I&C for, srfety-telated'systematwill be subject to the pertinent QA program requiremen'ts durisg the' operations phase.

/ .j 260.64 C. Enclosure 2 of ' NUREG-0737, " Clarification of TML Action Plan Requirements" (November 1980) identified numerous itens that are a safety-related and appropriate for OL application and therefore should be on Table 3.2-1. These items are listed below. Add the ajpropriate items to Table 3.2-1 and provide a commitment

, that the ., remaining items are subject to the pe rt inent require-ments hf 'the ,FSAR operational QA program or justify not doing so. j 5 h

/^ Respons e': -

,6~ C.L. Reactor Coolant System Pents f'>h  :._

The PORVs and the reactor vessel head letdown isolation and throt-tling valves which provide a safety grade me ans of venting the s

' reactor coolant system /are listed in Table 3.2-1, page 2.

C.2. ' Plant Shielding ,

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g e response to Item A.L.

S'e 7 C.3. Vak've Position Indication See, response to Part B.

C.4. 4?uxilsary3Feedwater System  %

( h, , s' See Tebie 3l2-1, pages 7 and 8.

7- C.5. Auriliary Feedwater initiation anf Flow p ,

See Table 3.2-1, pages 7 and 8'. Also, see response to Part B.

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C.6. 'Em9rgency Power for Pressurizer Neaters

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The. pressurizer heater panely de listed in Table 3.2-1, page 23.

4 ,. The'480V load centers that supply power to these panels are listed in Table 3.2-1, page 23. The .unergency power supply for the pres-i s uriz'e r heaters is described in Sect ion 8.3.1 and 8.3.2. Table

., 3.2-1 will be revi<cd to include pressurizer heaters.

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C.7. Dedicated Hydrogen Penetrations See response to A.21.

C.8. Containment Isolation Dependability See Table 3.2-1, page 15, and Section 6.2.4.

C.9. Accident Monitoring Instrumentation See Table 3.2-1, page 20, and response to Part B.

C.10. Instrumentation for Detection of inadequate Core Cooling Instrumentation for detection of inadequate core cooling includes core exit thermocouples, RVLIS, and core subcooling margin monitoring equipment. This equipment is safety-related and will be added to FSAR Table 3.2-1.

C.ll. Power Supplies fo r Pressurizer Relief Valves, Block Valves, and Level Indicators The powe r supplies for these items are safety-related as described in Section 8.3.1. The pressurizer relief and block valves are listed in Table 3.2-1, page 2. The pressurizer level indicator is part of the instrumentation and controls required to perform a safety func-tion listed in Table 3.2-1, page 3.

C.12. Automatic PORV Isolation As indicated in Table 1.10-1, an automatic pressurizer powe r-operated relief valve isolation system is not required for BVPS-2.

C.13. Automatic Trip of Reactor Coolant Pumps As discussed in Table 1.10-1, automatic trip of reactor coolant pumps is not utilized in the BVPS-2 design.

C.14. PID Controller As discussed in Table 1.10-1, this item is not applicable to BVPS-2.

'C.15. Anticipatory Reactor Trip on Turbine Trip Instrumentation and controls for anticipatory reactor trip on

, turbine trip are designated non-nuclear safety and QA Category 11 or til based on their funct ion as de fined in Sect ion 3.2.2.3. This reactor trip is desc ribed in Section 7.2.1. St anda rd industry quality control pract ices will be applied during the ope rat ions phase.

C.16. Power on Pump Seals The emergency diesel generators are st art ed automatic ally due to j loss of offsite powe r , thus restoring both seal inject ion and j component ecoling water flows within seconds. 1

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C.17. Emergency Plans (and Related Equipment)

St andard industry quality control practices will be applied during the operations phase.

C.18. Equipment and Other items Associated with Emergency Suppo rt Facilities St andard industry quality control pr act ices will be applied during the operations phase.

C.19. Inplant 12 Radiation Monitoring Standard industry quality control practices will be applied during the operations phase.

C.20. Control Room Habitability Habitability systems are listed in Table 3.2-1, pages 16 through 20 and are descirbed in Section 6.4.

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