ML20132C580

Forwards Supplemental Nh Wagner Auxiliary Sys Branch Affidavit Re Consequences of Cold Pulling Main Feedwater Pump Discharge Line & Consequent Misalignment When Line Mated to Pump.Position in 841120 Affidavit Maintained

ML20132C580
Person / Time
Site:	Harris
Issue date:	12/06/1984
From:	Rubenstein L Office of Nuclear Reactor Regulation
To:	Novak T Office of Nuclear Reactor Regulation
Shared Package
ML20132C567	List: IR 05000400/1983020 ML20132C562 ML20132C580 ML20134G063 ML20134G066 ML20134G069 ML20134G075 ML20134G079 ML20134G082 ML20134G086 ML20134G090 ML20134G095 ML20134G098 ML20134G101 ML20134G105 ML20134G106 ML20134G110 ML20134G117 ML20134G135 ML20134G143 ML20134G144 ML20134G149 ML20134G153 ML20134G157 ML20134G162 ML20134G165 ML20134G170 ML20134G174 ML20134G177 ML20134G182 ML20134G184 ML20134G188 ML20134G192 ML20134G196 ML20134G369
References
FOIA-85-173 NUDOCS 8412110084
Download: ML20132C580 (1)

Text

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EMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing, Division j of Licensing FROM: L. 5. Rubenstein, Assistant Director for Core and Plant Systems Integration

SUBJECT:

AUXILIARY SYSTEMS BRANCH AFFIDAVIT FOR SHEAR 0N HARRIS NUCLEAR PLANT, UNITS 1 AND 2 - MAIN FEEDWATER SYSTEM Attached is the affidavit prepared by the Auxiliary Systems Branch which deals with the consequences of cold pulling a main feedwater pump discharge line and the consequent misalignment when the discharge line is mated to the main feed-water pump. This issue was previously addressed in the affidavit dated November 7, 1984 which we sent to you on November 20, 1984. We continue to maintain the position we stated in the November 20, 1984 affidavit.

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e. bL L. S. P.ube tein, Assistant Director for Core and Plant Systems Division of Systems Integration

Enclosure:

As Stated cc w/ enclosure:

R. Bernero

0. Parr G. Knighton J. Wilson P. Hearn B. Buckley N. Wagner

Contact:

N. Wagner X29466 M(9Il#68+xA A\%

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ,

CAROLINA POWER AND LIGHT COMPANY AND )

NORTH CAROLINA EASTERN MUNICIPAL ) Docket Nos. 50-400 OL POWER AGENCY ) 50-401 OL (Shearon Harris Nuclear Power Plant, ,

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Units 1 and 2)

SUPPLEMENTAL AFFIDAVIT OF NORMAN H. WAGNER RESPONDING TO THE CHAN VAN VO DAVIS AFFIDAVIT DATED NOVEMBER 25, 1984 State of Maryland ) SS County of Montgomery )

Norman H. Wagner, have first been duly sworn, hereby states as follows: -

I am employed as an engineer in the Auxiliary Systems Branch of the Division of Systems Integration, Office of Nuclear Reactor Regulations and am the Staff reviewer of auxiliary systems for the Shearon Harris operating license appli-cation. My educational qualifications and professional experience are set forth imediately below.

' Education B.S. - Chemical Engineering - C.C.N.Y., 1948 M.S. - Chemical Engineering, University of Cincinnati,1952 c), , n r -- - I

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2 Experience I have been with the U.S. Nuclear Regulatory Commission from its inception in 1975, with a short period (from January 1975) with the U. S. Atomic Energy Commission. In my career with the Nuclear Regulatory Commission I have been assigned to the Reactor Systems Branch, to the Systems Interaction Branch and to the Auxiliary Syst' ems Branch at times and in the capacities shown below:

From January 1975 to approximately September 1980. I served as an engineer 1 in the Reactor Systems Branch, with the title of Reactor Engineer. In that capacity I performed licensing case reviews, checking adherence of reactor systems in nuclear power plants to the rules and regulations stipulated by the Nuclear Regulatory Commission. In September of 1980 I was transferred to the newly formed Systems Interaction Branch where I, with other members of the branch, attempted to develop a systematic methodology for reviewing nuclear f

power plants for adverse system interactions. I was transferred back to the Reactor Systems Branch in July 1981 when the Systems Interaction Branch was dissolved, and then to the Auxiliary Systems Branch in December 1981 where I am presently; in this capacity my main effort is reviewing plant systems and assuring compliance of these systems with the rules and regulations of the Nuclear Regulatory Commission.

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Response

I have reviewed the affidavit of Mr. Chan Van Vo Davis dated November 25, 1984 with regard to the main feedwater pumps and main feedwater piping within the turbine building and the effect of cold pulling a feedwater pump discharge line, and consequent misalignment when mated to the feedwater pump (1A-NNS).

After this review I continue to maintain the response contained in my affidavit of November 7, 1984 which states:

Response Of November 7, 1984 I have reviewed the Affidavit of Mr. Chan Van Vo Davis dated October 6, 1984. Mr. Davis alleges on pages 5 and 6 of his Affidavit that a 24 inch carbon steel pipe was " cold pulled" to fit the pipe to the discharge nozzle of steam generator feed-water pump 1A-NNS. This pump pumps water to the steam generators.

Figures 10.1.0-3 and 10.1.0-4 in the Shearon Harris Final Safety Analysis Report (Amendment 15) are flow diagrams which include the pump in issue. It does not appear that there is a 24" pipe attached to the pump's discharge nozzle. The pump appears to have an 18" discharge nozzle.

Pipes leading in and out of the steam generator feedwater pump 1A-NNS, 1

and the pump itself, do not perform a safety-related function. Failure of that pump or its piping will not prevent bringing the Harris facility to a cold shutdown mode.

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The concerns raised by Mr. Davis on pages 5 and 6 of his Affidavit relating to piping attached to steam generator feedwater pump 1A-NNS do not raise safety concerns for the facility. This is also evident from the pump's designation 1A-NNS. The NNS is the Applicants' nomenclature for non-nuclear safety equipment.

End Of November 7, 1984 Response It is the staff's position that the feedwater pumps, valves and piping within the turbine building do not perform any safety-related function.

Supplementing my ' previous affidavit I refer to the Shearon Harris Final Safety Analysis Report, pages 39 and 40 of Table 3.2.1, " Classification of Structures, Systems, and Components" in confirmation. As shown in Table 3.2.1 (in Amendment 3, dated June 30, 1982 or prior thereto) only the feedwater piping and valves from the steam generator up to and including the main feed isolation valve (MFIV) check valve within the auxiliary building and containment building are designed to the standards of safety class 2 (SC-2). This MFIV check valve, together with the pneumatic-hydraulically operated valve imediately downstream, also SC-2, serves to isolate the feedwater from the steam generators so that fluid from the feedwater pumps can not pass into containment nor can fluid pass out of contain-ment along the main feedwater piping (containment isolation) in the event'of an accident. The.feedwater pumps, remaining valves and piping are safety class NNS. The Shearon Harris safety classes 1, 2, and 3 correspond to NRC Quality Groups A,,B, and C. respectively~. NNS corresponds to Quality Group D. These b \N

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are defined in Regulatory Guide 1.26, " Quality Group Classifications and l

Standards for Water , Steam , and Radioactive Waste-Containing Components of Nuclear Power Plants." Quality Group B (corresponding to classification SC-2 in the Shearon Harris classification system) includes the portions of the feedwater systems of pressurized water reactors extending from the steam generators up to and including the 'outennost isolation valve which is, in this case, the MFIV check valve. Quality Group D applies to water containing components not included in Groups A, B or C but which may contain radioactive material. Only components in Gro'ups A, B and C (corresponding to safety classes 1, 2, and 3, respectively in the Shearon Harris classification scheme) have safety-related functions while components in Group D do not. l For further amplification I refer to Section 10.4.7.3, " Safety Evaluation" of the Shearon Harris FSAR (Amendment 0, dated prior to January 29,1982). The first ser.:ence below that heading states, "Operatfor, of the condensate and main feedwater pumps is not required for safe shutdown of the plant." The staff agrees with this statement. A similar statement which was written by me and which is consistent with the applicant's statement, appears in the NRC Safety Evaluation Report (SER), " Safety Evaluation Report Related to the Operation of Shearon Harris Nuclear Power Plant Units 1 and 2," dated November 1983 (NUREG-1038). The statement, on page 10-14 of the SER, under the heading 10.4.7,

" Condensate and Feedwater System" states "the sy' W v serves no safety function (with the exception of containment isolatirs 'rmr ty)".

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6 Therefore in my view, neither the affidavit of November 25, 1984 nor the attachments thereto support Mr. Davis' thesis that the feedwater pump and attached feedwater piping are safety-related components.

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NORMAN H. WAGNER Subscribed and sworn to before me this day of December 1984 NOTARY PUBLIC kkY

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peue 1 Ei.WJC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD EC ~7 P2:5f In the Matter of h'. I.'s;,g. Oa. -)WCi.

CAROLINA POWER AND LIGHT COMPANY AND NORTH CAROLINA EASTERN MUNICIPAL Docket Nos. 50-400 OL POWER AGENCY 50-401 OL (Shearon Harris Nucitar Power Plant.

Units 1 and 2)

SUPPLEMENTAL AFFIDAVIT OF NORMAN H. WAGNER RESPONDING TO THE CHAN VAN VO DAVIS AFFIDAVIT DATED NOVEMBER 25, 1984 State of Maryland' ) SS County of Montgomery )

Nonnan H. Wagner, have first been duly sworn, hereby states as follows:

I am employed as an engineer in the Auxiliary Systems Branch of the Division of Systems Integration, Office of Nuclear Reactor Regulations and am the Staff reviewer of auxtliary systems for the Shearon Harris operating license appli- -

cation. My educational qualifications and professional experience are set l forth innediately below.

Education .

B.S. - Chemical Engineering - C.C.N.Y., 1948 M.S. - Chemical Engineering University of Cincinr.ati, 1952 l

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I have been witt[the U.S. Nuclear Regulatory Comission from its inception in 1975, with a short period (from January 1975) with the U. S. Atomic Energy Commission. In my career with the Nuclear Regulatory Commission I have been assigned to the Reactor Systems Branch, to the Systems Interaction Branch and to the Auxiliary Systems Branch at times and in the capacities shown below:

From January 1975 to approximately September 1980. I served as an engineer

. in the Reactor Systems Branch, with the title of Reactor Engineer. In that capacity I performed licensing case reviews, checking adherence of reactor systems in nuclear power plants to the rules and regulations stipulated by the Nuclear Regulatory Comission. In September of 1980 I was transferred to the newly formed Systems Interaction Branch where I, with other members of the branch, attempted to develop a systematic methodology for reviewing nuclear power plants for adverse system interactions. I was transferred back to the Reactor Systems Branch in July 1981 when the Systems Interaction Branch was dissolved, and then to the Auxiliary Systems Branch in December 1981 where I am presently; in this capacity my main effort is reviewing plant _sy. stems and assuring compliance of these systems with the rules and regulations of the Nuclear Regulatory Comission.

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Response

I have reviewed the affidavit of Mr. Chan Van Vo Davis dated November 25, 1984 with regard to the main feedwater pumps and main feedwater piping within the turbine building and the effect of cold pulling a feedwater pump discharge line, and consequent misalignment when mated to the feedwater pump (IA-NNS).

After this review I continue to maintain the response contained in my affidavit of November 7, 1984 which states:

Response Of November 7, 1984 I have reviewed the Affidavit of Mr. Chan Van Vo Davis dated October 6 1984. Mr. Davis alleges on. Pages 5 and 6 of his Affidavit that a 24 inch carbon steel pipe was " cold pulled" to fit the pipe to the discharge nozzle of steam generator feedwater pump 1A-NNS. This pump pumps water to the steam

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generators.

Figures 10.1.0-3 and 10.1.0-4 in the Shearon Harris Final Safety Analysis Report (Amendment 15) are flow diagrams which include the pump in issue. It does not appear that there is a 24" pipe attached to the pump's-discharge nozzle. The pump appears to have an 18" discharge nozzle.

Pipes leading in and out of the steam generator feedwater pump 1A-NNS, and the pump itself, do not perform a safety-related function. Failure of that pump or its piping will not prevent bringing the Harris facility to a l l

cold shutdown mode.  !

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The concerns raised by Mr. Davis on pages 5 and 6 of his Affidavit relating to piping attached to steam generator feedwater pump 1A-NNS do not raise safety concerns for the facility. This is also evident from the pump's designation 1A-NNS. The NNS is the Applicants' nomenclature for non-nuclear safety equipment.

End Of November 7, 1984 Response It is the staff's position that the feedwater pumps, valves and piping within the turbine building do not perform any safety-related function.

Supplementing my previous affidavit I refer to the Shearon Harris Final Safety Analysis Report, pages 39 and 40 of Table 3.2.1, " Classification of Structures, Systems, and Components" in. confirmation. As shown in Table 3.2.1 (in Amendment 3, dated June 30, 1982 or prior thereto) only the feedwater piping and valves from the steam generator up to and including the main feed isolation valve (MFIV) check valve within the auxiliary building and containment building are designed to the standards of safety class 2 (SC-2). This MFIV check valve, together with the pneumatic-hydraulically operated valve imediately downstream, also SC-2,

.; serves to isolate the feedwater from the steam generators so that fJuid from the -

feedwater pumps can not pass into containment nor can fluid pass out of contain-ment along the main feedwater piping (containment isolation) in the event of an l accident. The feedwater pumps, remaining valves and piping are safety class i

t NNS. The Shearon Harris safety classes 1, 2, and 3 correspond to NRC Quality Groups A,'B, and C. respectively. NNS corresponds to Quality Group D. These O

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are defined in Regulatory Guide 1.26, " Quality Group Classifications and .

Standards for Water , Steam , and Radioactive Waste-Containing Components of Nuclear Power Plants." Quality Group B (corresponding to classification SC-2 in the Shearon Harris classification system) includes the portions of the feedwater l systems of pressurized water reacters extending from the steam generators up

. to and . including the outermost isolation valve which is, in this case, the MFIV check valve. Quality Group D applies to water containing components not included in Groups A, B or C but which may contain radioactive material. Only components in Groups A, 8 and C (corresponding to safety classes 1, 2, and 3, 2

respectively in the Shearon Harris classification scheme) have safety-related

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! functions while components in Group D do not. .

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.' For further amplification I refer to Section 10.4.7.3, " Safety Evaluation"

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of the Shearon Harris FSAR (Amendmant 0, dated prior to January 29,1982). The first sentence below that heading states, " Operation of the condensate and main .

feedwater pumps is not required for safe shutdown of the plant." The staff agrees with this statement. A similar statement which was written by me and which is consistent with the applicant's statement, appears in the NRC Safety Evaluation Report (SER), " Safety Evaluation Report Related to the Operation of 1

Shearon Harris Nuclear Power Plant Units 1 and 2," dated November 1983 (NUREG-1038). The statement, on page 10-14 of the SER, under the heading 10.4.7, "Conder. sate and Feedwater System" states "the system serves no safety function

(with the exception of containment isolation integrity)".

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6 Theref6re in my view, neither the affidavit of November 25, 1984 nor the ..

attachments thereto s'upport Mr. Davis' thesis that the feedwater pump and attached feedwater piping are safety-related components.

i blLtiu h. 4 k NORMAN H. WAGNER Subscribed and sworn to before me this (d" day of December 1984 .

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NOTARY PUBLIC ,

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of CAROLINA POWER AND LIGHT COMPANY AND NORTH CAROLINA EASTERN MUNICIPAL Docket Nos. 50-400 OL POWER AGENCY 50-401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 and 2) ) .

CERTIFICATE OF SERVICE -

I hereby certify that copies of " SUPPLEMENTAL AFFIDAVIT OF N0'RMAN H.

WAGNER RESPONDING TO THE CHAN VAN VO DAVIS AFFIDAVIT DATED NOVEMBER 25, 1984", in the above-captioned proceeding have been served pursuant to the telephone conference call among the Board and parties held on December 5, 1984, on the following by deposit in the United States mail, first class, or deposit in the Nuclear Regulatory Commission's internal mail system (*),

this 6th day of December 1984.

James L. Kelley, Chairman

• Richard D. Wilson, M.D.

Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn 0. Bright

• Travis Payne, Esq.

Administrative Judge 723 W. Johnson Street Atomic Safety and Licensing Board P.O. Box 12643 U.S. Nuclear Regulatory Commission Raleigh, NC 27605 Washington, DC 20555 Dr. James H. Carpenter

• Dr. Linda Little - - - -

l Administrative Judge Governor's Waste Management Building Atomic Safety and Licensing Board 513 Albermarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury Street Washington, DC 20555 Raleigh, NC 27611 Daniel F. Read John Runkle, Esq. Executive Coordinator CHANGE Conservation Counsel of North Carolina P.O. Box 2151 307 Granville Rd.

Raleigh, NC 27602 Chapel Hill, NC 27514

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J Steven Rochlis Spence W. Perry, Esq. i Regional Counsel Associate General Counsel  !

FEMA Office of General Counsel 1371 Peachtree Street, M.E. FEMA Atlanta, GA 30309 500 C Street, SW Rm 840 Washington, DC 20472 Atomic Safety and Licensing Appeal Bradley W. Jones Esq.

Board Panel Regional Counsel, USNRC, Region II U.S. Nuclear Regulatory Comission 101 Marietta St., N.W. Suite 2900 Washington, DC 20555 Atlanta, GA 30323 Robert P. Gruber George Trowbridge, Esq.

Executive Director Thomas A. Baxter, Esq.

Public Staff - NCUC John H. O'Neill, Jr., Esq.

P.O. Box 991 Shaw, Pittman, Potts & Trowbridg,e Raleigh, NC 27602 1800 M Street, N.W.

Washington, DC 20036 Wells Eddleman Atomic Safety and Licensing Board 718-A Iredell Street Panel

• Durham, NC 27701 U.S. Nuclear Regulatory Comission Washington, DC 20555 Richard E. Jones, Esq. Dr. Harry Foreman, Alternate Associate General Counsel Administrative Judge Carolina Power & Light Company P.O. Box 395 Mayo P.O. Box 1551 University of Minnesota Raleigh, NC 27602 Minneapolis, MN 55455 L -

V dd Charles A. Barth Counsel for NRC Staff

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