ML20151N681

Forwards Response to Request to Clarify Confirmatory Item 44 & QA Branch Question 260.64.QA Classification for Fabricated Supports Same as Equipment Being Supported. Reactor Coolant Pump Seals Considered nonsafety-related

ML20151N681
Person / Time
Site:	Beaver Valley
Issue date:	12/20/1985
From:	Carey J DUQUESNE LIGHT CO.
To:	Knighton G Office of Nuclear Reactor Regulation
References
2NRC-5-152, TAC-62931, NUDOCS 8601030064
Download: ML20151N681 (4)

Text

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'Af 2 E721 Nuclear Construction Division Telecopy 8 9 Robinson Plaza. Building 2. Suite 210 Pittsburgh, PA IS205 December 20, 1985 United States Nuclear Regulatory Conunission 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 Assur ance Branch Question 260.64 and Confirmatory Item No. 44 Gentlemen:

Enclosed please find the response to NRC Request for Clarification on Beaver Valley Unit 2 Q-List. This response closes Confirmatory Item No. 44.

Should you have any questions concerning the enclosed response, please contact G. H. Oliver at 412/787-5141.

DUQUESNE LIGHT COMPANY l'

By

4. GV Carey (/ '

Vice President GH0/slm At tachment cc: Mr. B. K. Singh, Project Manager - w/ attachment Mr. G. Walton, NRC Resident Inspector - w/attachnent 5h10 P

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REQUEST FOR CLARIFICATION BEAVER VALLEY 2 Q-LIST The response to QA Branch question 260.64 supplied by Duquesne Light letter 2NRC-5-096 dated June 28, 1985 needs to be clarified as noted below before it is acceptable. Please respond to the itens shown, numbered as in the original question 260-64.

A.3 and A.4:

~ These itens include f abricated supports addressed in Regulatory Guide 1.29 and other itens within the scope of Regulatory Positions C.2 and

.' C.3 of Regul atory Guide 1.29. Regulatory Position 4 of the regulatory guide states that the pertinent requirenents of Appendix B to 10CFR50 should be applied to these itens. Provide such a canmitment for the operations phase or justify not doing 50

Response

A.3 - The Quality Assurance classification for f abricated supports is the sane as the equipment being supported.

A.4 - For BVPS-2 structures, systens, and conponents within the scope of Regul atory Guide 1.29, paragraphs C.2 and C.3 are designated non-safety-related Seismic Category II and are constructed to QA Category II or III requirenents.

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For itens within the scope of Regulatory Guide 1.29 paragraphs C.2 ana C.3, the pertinent requirenents of Appendix 8 to 10CFR50 will be applied to all activities affecting the safety-related func-tions of structures, systens, and conponents which prevent or mitigate the consequences of postul ated accidents which could

• cause undue risk to the health and safety of the public.

A.5:

Clarify that any repairs or modifications of liner will nave the sane or 4

equivalent quality assurance requirenents as the initial installation or justify not doing so. The response concerning the spent fuel pool is acceptable.

Response

SRP 9.1.2,Section III.3.b states:

" Stresses induced in the fuel pool liner plate welds due to an SSE will usually be well below the maximum allowable stress levels and, therefore, liner failure is not considered a likely event. Even if the liner plate failed, it would not y likely block the coolant outlet of the spent fuel assenblies conpletely and sufficient cooling of the stored spent fuel would be maintained. Therefore, the spent fuel liner plate

e seisnic design is not considered a significant safety issue dnd backfit is not regt.4ed."

The design of tne BVPS-2 spent fuel pool liner meets the criteria of Sections III.3.a and III.3.b of SRP 9.1.2. This confonnance has been achieved by designating, designing, and constructing the liner as a Seismic Category II iten. (Seisnic Catetory II is a classification specific to BVPS-2 and is defined in FSAR Section 3.2.1.2.)

However, as described by Section III.3.b of SRP 9.1.2, the BVPS-2 spent fuel pool liner will not affect the safety-related functions of struc-tures, systens, and conponents which prevent or mitigate the conse-quences of postulated accidents which could cause undue risk to the health and safety of the public. Repairs or modification of the spent fuel pool liner will be administratively controlled to assure a quality level and design equivalent conynensurate with its importance to safety.

A.13:

The reactor coolant punp seals perfonn a safety function and should be in Table 3.2-1. Provide such a conmitment for the operations phase or justify not doing so.

Response

The reactor coolant pump seals are considered non-s afety-rel ated .

However, special requirenents are included in the specifications by the NSSS supplier. This iten will be added to Table 3.2-1.

A.18(b) and (d):

The response to these itens indicates that BVPS-2 does not have separate foundations for service water piping and cooling water discharge piping.

BVPS-2 should have records showing the acceptability of the excavation /

backfill during the construction phase. Also, any maintenance /modifica-tion of the backfill for this piping during the operations phase should i be subject to the pertinent provisions of Appendix B to 10CFR50. Provide such a connitment or justify not doing so.

Re;ponse:

See DLC response to NRC question 241.5, Amendment 6.

For backfill -in areas designated Category I, the pertinent requirenents of Appendix B to 10CFR50 will be applied to maintenance / modifications affecting the safety-rel ated functions of structures, systens, and conponents which prevent or mitigate tne consequences of postulated accidents which could cause undue risk to the health and safety of the public.

A.19:

Site grading affects site drainage and potential flooding of safety-related iters at BVPS-2. Therefore, the pertinent provisions of Appendix B to 10CFR50 should be applied to modifications to site grading during the operations phase. Provide such a conmitment or justify not doing so.

Response

The pertinent requireaents of Appendix B to 10CFR50 will be applied for changes to site grading which affect the safety-related functions of structures, systens, and conponents which prevent or mitigate the conse-quences of postul ated accidents which could cause undue risk to the health and safety of the public.

A.26:

Meteorology equipnent at BVPS-2 will be used to mitigate the conse-quences of any accident which coulo affect the health and safety of the public. Therefore, it should be subject to the pertinent provisions of Appendix B to 10CFR50 during the operations phase.

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Provide a conmitment or justify not doing so.

Response

The BVPS-2. meteorological progran is considered non-s afety-rel ated.

However, the pertinent requirenents of Appendix B to 10CFR50 are applied to the BVPS meteorological equipnent.

C.19:

In-plant I2 radiation monitoring will be used to mitigate the conse-quences of any accident which could affect the healtn and safety of the public. Therefore, it should be subject to the pertinent provisions of Appendix B to 10CFR50-during the operations phase. Provide such a con-mitment or justify not doing so.

Response

Portable air sanples used at BVPS-2 for detennining in-plant airborne iodine concentrations are considered non-safety-related. However, the pertinent requirenents of Appendix B to 10CFR50 will be applied to these sanples.

Also, see response to NRC question 471.15, Anendment 3, for a descrip-tion of these sanplers.