ML20151N880

Forwards Comments on SER (NUREG-1057).Sys Will Be Implemented to Track Resolution of Comments & Future SER Changes.Statement on Page 2-46 Re Susceptibility of Soils Around Intake to Liquefaction Should Be Expanded

ML20151N880
Person / Time
Site:	Beaver Valley
Issue date:	12/24/1985
From:	Carey J DUQUESNE LIGHT CO.
To:	Rubenstein L Office of Nuclear Reactor Regulation
References
RTR-NUREG-1057 2NRC-5-157, TAC-62882, NUDOCS 8601030171
Download: ML20151N880 (21)

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N"dindn$Ee*IsUdIs .s"uite 21o December 24, 1985 Pittsburgh, PA 15205 United States Nuclear Regulatory Conmission Washington, DC 20555 ATTENTION: Mr. Lester S. Rubenstein, Director PWR Project Directorate No. 2 Office of Nuclear Reactor Regulation

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Duquesne Light Conpany Conments on the Safety Evaluation Report (NUREG-1057)

Gentlemen:

Attached are Duquesne Light Conpany's (DLC) conments on the Beaver Valley Power Station Unit No. 2 (BVPS-2) Safety Evaluation Report (SER) which was issued by the NRC as NUREG-1057, dated October 1985. DLC proposes to implenent a systen to track resolution of these conments and any future SER changes identified by DLC. The intent of this systen is to provide a mecha-nism to ensure that the conments or changes are transmitted to the NRC and resolved in a timely manner, and to ensure that all appropriate SER changes are made. The systen should be beneficial fran the standpoint of maintaining SER accuracy and pronoting a more coordinated approach to the issuance of SER suppionents. We will be discussing our plans with the Licensing Project Manager in the near future in order to jointly develop this system.

DUQUESNE LIGHT COMPANY By k (2(,

J. J. Carey f Vice President JD0/wjs Attachnent cc: Mr. B. K. Singh, Project Manager (w/a)

Mr. G. Walton, NRC Resident Inspector (w/a) 8'601030171 g51224 0

SUBSCRIBEDANDSWORNTQBEFOREMETH , 1985.

1. 6( DAY OF z hwc/av .

\ b W f{$vu) _ YlzN$7<

1. l ~ Notary Public ANITA ELAINE REITER, NOTARY PUBLIC 8'

$1 ,$ inIk Y" * ""'d ROBINSON TOWNSHIP, ALLEGHENY COUNTY Zj' g l, MY COMMISSION EXPIRES OCTOGER 20,198G O !"J" 0 n

i United States Nuclear Regulatory Consnission Mr. Lester S. Rubenstein. Director OLC Comments on the SER (NUREG-1057)

Page 2 COMMONWEALTH OF PENNSYLVANIA )

SS:

COUNTY OF ALLEGHENY -

The Manager, Regulatory Af fairs, R. E. Martin, being first duly sworn, deposes, and says: thatche is Manager, Regulatory Affairs, of Duquesne Light Company, with legal authority to sign official correspondence on behalf of the Vice President, Nuclear Division, J. J. Carey, in relation to licensing for Beaver Valley Power Station, Unit 2, and is therefore authorized to submit the foregoing on behalf of the applicant.

ken t<. 2 V / 91$

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$Manager, Regulatory Af f airs Sworn and subscribed before me this gyff day of .Thau4o , 1985.

KY UO)

Notary Public LibG ANITA ELAINE REITER, f40TARY PUBLIC ROBINSON TOWNSHIP, ALLEGHEf4Y COUNTY MY COMMISSION EXPlRES OCTOBER 20,1986

SAFETY EVALUATION REPORT DLC COMENTS .

PAGE 1 of 19 NO. PAGE SECTION COMENT t i

1. 1-9 1.7.2 The last sentence of tne resolution of issue (4) should be replaced with: "The applicant has also conmitted in a letter dated March 27, 1965, to revise the FSAR to correct an erroneous reference to the stean generator high level trip and thereby resolve the con-flict with 10CFR50.55a(h). This issue is therefore closed pending resolution of Generic t Issue A-47." l

2. 1-9 1.7.2 Tne last sentence of the resolution of issue (7) should be changed to: "To close this issue, the applicant provided justification in a letter dated October 8,1985, that a i hose strean .. ."

3. 1-17 Table 1.2 Open Item 4: Section 5.2.4.1 should be included with the other SER sections listed.

1-19 Taale 1.4 i Section 5.4.2.2 should De deleted fran the list in Table 1.2 since this is a confirmatory iten as stated on Page 5-20. It should be listed as a confinnatory iten in Table 1.4.

4. 1-18 Table 1.3 The status of issue (4) should be changed fron "A" to "C" to be consistent with the latest NRR monthly status report on plant-specific backfitting activities, dated Novenber 25, 1985. Tne SEli shows this iten open pending review of 10CFR50.55a(h). We assune the staff's oasis for closure is that they have reviewed our conmitment in a letter dated March 27, 1985, to revise the FSAR and that they have detennined that 10CFR50.55a(h) is therefore not applicable to this systen.

5. 1-18 Table 1.3 The status of issue (7) should be changed froa "A" to "C" to oe consistent with the latest NRR monthly status report on plant-specific backfitting activities, dated Novenber 25, 1985. The SER shows this iten open pending justification showing that a hose strean will reach the dense cable tray array in the northwest corner. We assune the staff's basis for closure is that in a letter dated Octouer 8, 1985, this justification was provided.

6. 1-19 Table 1.4 Confirmatory Issue 2: SER Section 2.5.4.3.3 should be listed in addition to Section 2.5.4.5.

7. 2-7 2.3.1 Second paragraph on Page 2-7: This paragraph should indicate that, with respect to the tornado pressure drop rate, BVPS-2 is consistent with RG 1.76 and WASH 1300 (as discussed in the response to NRC Question 451.2).

! SAFETY EVALUATION REPORT l DLC C0000ENTS .

PAGE 2 of 19 NO. PAGE SECTION C000ENT t

8. 2-11 2.3.4 Suggest adding to last sentence of Section 2.3.4: "... and has determined that the I relative concentrations at the EAS meet the requirements of 10CFR100.ll." i

9. 2-14 2.4.2.3.1 Last paragraph on Page 2-14 implies that mR 33 did not include the Smethport Storm. The differences between HMR 33 and HMas 51/52 are in the methods used to obtain the anount of i rainfall.

10. 2-17 2.4.3.1 No Standard Tech. Spec. nor BVPS-1 Tech. Spec. currently requires a plant flood alert be issued for a high river water level. This violates the criteria established by the NRC in t the G. Knignton to J. Carey letter issued by the NRC on September 18, 1984, and Chapter 16 of the SER. Therefore, this conmitnent for such a Tech. Spec. should be withdrawn by ,

the NRC. (BVPS-2 Tech. Specs, do require an increase in surveillance when the Ohio River  !

reaches 690 feet asl. However, they do not mention that a " flood alert" be issued.)

11. 2-30 2.5.1.1 First paragraph on Page 2-30: The 1926 earthquake was excluded fran DLC's interpretation l Of the ;PTP as stated, but its effect on the design earthquake was considered and dis-cussed in the February 1935 report.

As discussea in Section 2.5.2.4.1, this earthquake has been identified as a shallow earthquake and as such does not represent any greater selsnic hazard to the site than the design eartnquake selected. In fact, for the seisnic hazard analysis presented in the February 1935 report, this earthquake was conservatively incluoed within the APTP as a normal focal depth event. [

i Since the NRC staff concurs with DLC's position on shallow events, a brief discussion indicating this concurrence could De included in tnis paragraph. This could be done by referencing the discussions in Sections 2.5.2.4.1 and 2.5.2.5.1.

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12. 2-33 2.5.2.2 Second to last sentence in Section 2.5.2.2: Tne Cleveland area earthquakes have been  ;

included in the APTP, out it could be inferred froo this sentence that they were not. l (Refer to FSAR Figure 2.5.1-5.)  ;

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13. 2-36 2.5.2.6 First sentence of Section 2.5.2.6: The BVPS-2 response spectra hate the shape of the Newaark spectra but they are not truly Newnark spectra. With the exception of the value ,

of the acceleration anplification factor for 5 percent danping, the anplification factors I used to develop the BVPS-2 spectra were not those suggested by Newnark.

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SAFETY EVALUATION REPORT r DLC C0f0ENTS -l '

PAGE 3 of 19 r

20. PAGE SECTION C0f0ENT I

14. 2-45 2.5.4.1.2 First paragraph of Ites (2): Tne stiff clay lens was renoved fran within the containnent  !

area aro replaced with conpacted structural fill. Tnis could be indicated here by referencing the discussion in Section 2.5.4.2.1.

15. 2-4o 2.5.4.1.2 Last paragrapn of Iten (2): The Orief description of the soil profile near the main '

intake is not entirely correct. Refer, for exanple, to FSAR Figures 2.5.4-54 and 2.5.4-

58. Tne silty clays to tne soutn of the structure and -within the excavation for the i BVPS-1 and BVPS-2 SWS pipelines were renoved and replaced with coupacted fill. Similarly,  ;

east and west of the structure, within the limits of the wing walls and anchor walls, the l upper soils were also renoved at least to the level of the anchors and replaced. l i

The statenent concerning the susceptibility of soils around the intake to liquefaction should De expanced to denonstrate that the problen has been addressed and resolved. This  !

could be done by referencing the discussion in Section 2.5.4.3.4. I

16. 2-49 2.5.4.2.2 Last paragraph on Page 2-49: The properties of conpacted structural fill were not deter-mined by laboratory testing. Refer to FSAR 2.5.4.5.2 for cetails. j

17. 2-51 2.5.4.3.3 Last two paragraphs of Section 2.5.4.3.3: In response to Draft SER Open Iten 176 (cur-2-54 2.5.4.5 rently SER Confir.natory Iten 2), which was provided in DLC letter 2NRC-4-159, dated October 3,1934, DLC stated that an evaluation of the effect of differential settlenents -

on Duried pipelines at the soil-structure interface was being conducted. Differential movenents between aroitrary points along the pipeline away fron the constraint of the j structure penetration are not considered to be a problen. Buried steel pipelines are ,

considered to De flexible enough to inove witn the soil without causing undue stress in r the pipe.

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la. 3-3 3.2.2 First paragraph on Page 3-3: DLC has received approval fran the NRC Mechanical Engineer- t ing Branch in an NRC letter dated Septenber 9,1985, to implenent a proposed progran for Safety Class 2 and 3 instrurnent tubing. This progran takes alternatives to the ASME Code  ;

as described in DLC letter 2NRC-5-113, dated July 31, 1985. i

19. 3-4 3.3.2 First paragraph of Section 3.3.2: Witn respect to the tornado pressure drop rate, BVPS-2 l is consistent with RG 1.76 and WASH-1300 (as discussed in the response to NRC Question c 451.2). f l

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SAFETY EVALUATION REPORT DLC CO M NTS PAGE 4 of 19

20. PAGE SECTION CO M NT

20. 3-9 3.5.1.1 Tnird paragraph, first sentence: Add the following words after the word "systens":

" nave been evaluated and found not to affect the itens required for safe shutdown or".

The FSAR will be anended.

21. 3-9 3.5.1.1 Third paragraph, fourth sentence: Revise this sentence to clarify that it is past tense as follows: "The method of blade attachment has been investigated to ensure that the blade locknut torque and blade tip angle meet the manufacturer's specification."

22. 3-9 3.5.1.1 Tnird paragraph, fifth and sixth sentences: "The following sentence should be substi-tuted: "Either a stress analysis has determined that the safety factors against the f ailure of a fan is acceptable or analyses have been performed sich deaonstrate that the housing is adequate to rei.ain the fragments." Tne FSAR will be anended.

23. 3-10 3.5.1.1 First paragraph: A3d the following sentence after the first sentence: "In addition, the applicant has perfannea an analysis that deaonstrates that potential missiles froa the turbine-driven auxiliary feedwater ptsap would be contained by the concrete conpartnent."

The FSAR will be aaended. Refer to letter 2NRC-4-121, dated August 13, 1984.

24. 3-10 3.5.1.1 Fourth paragraph, second sentence: Change the words "will not cause a missile" to "will not occur, therefore, a missile will not be generated."

25. 3-12 3.5.1.2 First paragraph, second sentence: Change the words "will not cause a missile" to "will not occur, therefore, a missile will not be generated."

26. 3-12 3.5.1.2 Second paragraph, first sentence: Revise this sentence to clarify that it is past tense as follows: Tne method of blade attachnent has been investigated to ensure that the blade locknut torque and blade tip angle meet the manufacturer's specification."

27. 3-12 3.5.1.2 Second paragraph, second and third sentences: The following sentence should be substi-tuted: "Either a stress analysis has detennined that the safety f actors against the failure of a fan is acceptable or analyses have been perfonned which denonstrate that the housing is adequate to retain the fragnents." The FSAR will be anended.

SAFETY EVALUATION REPORT DLC C0f01ENTS PAGE 5 of 19 NO. PAGE SECTION C000ENT

28. 3-12 3.5.1.3 Confirmatory Itea 5: DLC intends to study the results of the probabilistic analysis to be performed using Westinghouse methodologies as recently approved by the NRC before

~ making a final decision on a maintenance progran. Refer to the response to Question 251.2 in Anendnent 3, dated October 1983.

29. 3-15 3.6.1 Second paragrapn: Revise first sentence to the following: "The main stean and feedwater lines and the high energy portion of their branch lines, including the isolation valves, located in the main steaa valve house have been classified as part of the break exclusion boundary." Cnange second sentence words " Jet impingenent and environnental effects of the postulated pipe break" to "environaental effects of a postulated 1 f t.2 nonnechanistic pipe break."

30. 3-15 3.6.1 A comnitment has not been made to provide an analysis that confinns that safety-related equpreent is properly qualified for the superheated stean condition that may result fran a postulated steaaline Dreak. DLC intends to utilize the results of the WOG/SBOC subgroup to review impact on environnental qualifications.

The results of the Hazards Analyses are scheduled for coupletion at the end of 1986 and docunentation in early 1937.

31. 3-16 3.6.2 Tne definition of Dreak exclusion zone and the design basis are sonewhat different than those outlined in SRP 3.6.2. Refer to T1.9-2, Pages 12 and 12a of 93 of A11end>nent 10, dated May 1985.

32. 3-17 3.6.2 The criteria for postulating intennediate creak locations is 3.0 (Sm) instead of 2.4 (52 ). Refer to T1.9-2, Pages 12 and 12a of 93 of Anendinent 10, dated May 1985. OLC Letter 2NRC-5-042, dated March 12, 1985, requested the elimination of arbitrary inter-mediate pipe breaks for certain piping systens. The NRC approved this request on May 21, 1985.

33. 3-18 3.7.1 Section paragraph on Page 3-18: In the first sentence, it would be more appropriate to state that the danping ratios used for BVPS-2 "conply with RG 1.61" rather than "conply with those in RG 1.61." As stated in FSAR Table 1.8-1, BVPS-2 uses sone danping values which are not the sane as those reconmended in Tah 1 of RG 1.61. However, these values do comply with the Regulatory Position delineated in Section C of RG 1.61.

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NO. PAGE SECTION C000ENT l

l 34. 3-24 3.8.4 Tne second paragrapn of Section 3.8.4 should read as follows: "The staff has reviewed l

the responses provided by the applicant and has detennined that all nine action itens 1 related to this SER section (see Section 3.8.6) are resolved. Teen 19 required the j

applicant to suomit ... and Itens 20 and 22 required the applicant to provide ..." ~

l 35. 3-33 3.9.3.1 Fourth paragraph, third sentence: Revise this sentence to read as follows: "The Code i also requires a stress report for ASME Cone Class 1 couponents and stress calculations

]I for ASME Cooe Class 2 and 3 components."  !

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36. 3-33 3.9.3.1 Confinnatory Iten 10: A telecon between the NRR staff and its consultants DLC and Stone j & Weoster on Septenber 13, 1985, resolved all questions. The questions were fonnally j issued by the staff on Novenber 26, 1985. DLC will be submitting fonnal responses,

} 37. 3-35 3.9.3.2 Confinnatory Iten 11: The BVPS-2 plant-specific response is covered in Section 5.4.13.4 i in Aaendment 4, dated Decenber 1983. This iten should be closed.

l 33. 3-36 3.9.3.3 Second paragraph, second sentence: Revise this sentence to read as follows: "The f primary loop conponent supports utilized ASME Code, Subsection NF, as a guide in the design."

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39. 3-36 3.9.3.3 Last complete sentence on Page 3-36 should end with tne following words (after the word .

"conbined"): "by tne square root of the sun of the squares (in accordance with NLREG-0484, Rev. 1)."

I 40. 3-39 3.9.6 The inservice testing progran applies to certain safety-related punps and valves. Refer to Sections 3.98.6.1 and 3.98.6.2.

41. 3-40 3.9.6 The criteria required for pressure isolation valve testing is still under discussion.

1 DLC does not agree with all criteria stated in the first two paragraphs on Page 3-40. .

This will be resolved through Open Itens 1 and 2 on Table 1.2.

. 42. 3-41 3.10.1 Tne SER states that DLC has conmitted to incorporating "the seismic and all other perti-3 nent dynanic loads, including accident loads, in the seisnic qualification prograns, which should include fatigue cycling effects." DLC has met with the staff on several l occasions and discussed the types of loads included in the seisnic progran. The FDSER 2

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SAFETY EVALUATION REPORT l DLC COMENTS

! PAGE 7 of 19 NO. PAGE SECTION COMENT

] 42. (continueo) was the first time DLC had been requested to address fatigue cycling effects. We disagree l

because we only consider f atigue on certain equipnent.

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43. 3-41 3.10.1 The SER states: "Tne applicant should submit FSAR anendments to document the resolution

! of the ioentified FSAR discrepencies." The SER refers to FSAR discrepencies but does not identify then.

44. 3-42 3.10.2 The staff has concluded that the applicant's qualification progran meets the requirenents 5

, of IEEE 323-1974. BVPS-2 is required to meet IEEE 323-1971.  ;

e i 45. 3-43 3.10.2 Tne staff identified a new concern relating to preoperational testing. Many of the systen l

preoperational tests are to be monitored visually rather than by calibrated instrumenta- ,

) tion. Because of this, the applicant should provide justification that preoperational

! test results will validate the qualification of the systen, conponent, and supports. The  !

concera is directly related to FSAR Open Iten 2 and will be addressed by the response to j this open item.

I 46. 3-44 3.11.3 10CFRSO.49(k) states that the applicant is not required to requalify electrical equipnent .

. to meet 10CFRSO.49 if the staff has previously required qualification to NUREG-0588.  !

Part (k) does state that repl acenent equipnent should be upgraded where possible to i l 10CFRSO.49. It appears that the staff in 3.11.3 is now requiring BVPS-2 to address the ,

requirenents of 10CFR50.49. In the previous section (3.11.2), the staff stated that BVPS-2 is to De qualifiec to NUREG-0588, Category II.

47. 3-44 3.11.3 The itens required in this section that DLC is expected to provide prior to the audit have all been. previously submitted or discussed with the staff. The infonnation being ,

requested is identical to FSAR Question 270.2, dated Septenber 22, 1983. DLC met with

! the NRC on Decenber 19, 1983, to present our response to Question 270.2 and to notify the staff that DLC would be preparing and submitting a separate submittal forEQ. During this Decenber n.eeting, DLC identified where the needed infonnation could be found in the  !

l; FSAR and in the subsequent separate EQ submittal. On June 26, 1984, DLC met with the staff to fermally submit the EQ report and to explain its contents. Except for Itens 2, S, and 6 (FDSER 3-44 through 3-46), the infonnation the NRC requested was included in the EQ report. On Novenber 1, 1984, DLC submitted the Mechanical EQ Report which fully i

satisfied Iten 6. The fact that the SER has not recognized any of this infonnation implies that no work has been done in the EQ area since September 22, 1983.

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SAFETY EVALUATION REPORT DLC COMENTS PAGE 8 of 19 NO. PAGE SECTION COMENT

48. 4-3 4.2.1 Confinnatory Iten 15: Tne peak pellet design-basis Durnup value was confinned by Letter 2NRC-5-132, dated Septenber 13, 1985.

49. 4-3 4.2.2 Confinnatory Iten 16: The corrected fuel values were submitted in Letter 2NRC-5-132, dated September 13, 1985.

50. 4-6 4.2.3.1 Confinnatory Iten 17 (Iten [6] on Page 4-6): Confinnation of the perfonnance of the rod bowing analysis was provided in Letter 2NRC-4-102, dated July 12, 1984, and FSAR Section 4.4.2.2.5, Anend;nent 8, dated Septenber 1984.

51. 4-/ 4.2.3.1 Confinnatory Iten 18 (Iten [8] on Page 4-7): Confinnation of the fuel rod internal pres-sure criterion was provided by Letter 2NRC-5-132, dated Septenber 13, 1985.

52. 4-8 4.2.3.2 Confinnatory Iten 19 (Iten [2] on Page 4-8): Confinnation of the calculated cladding collapse time was provided by Letter 2NRC-5-132, dated September 13, 1985.

53. 4-10 Confinnatory Iten 20 (Iten [4] on Pages 4-10 and 4-11): The SRSS methodology was con-

& 11 4.2.3.3 firmeo by Letter 2NRC-4-209, dated December 18, 1984.

54. 4-16 4.3.2.1 Last paragraph: BVPS-1 Tech. Specs, no longer require the use of APDMS. Tnerefore, in accordance with the G. Knighton to J. Carey letter issued by the NRC on Septenber 18, 1984, and Chapter 16 of the SER, BVPS-2 Tech. Specs. should also not require this.

55. 4-23 4.4.4 Last paragraph

In accordance with the G. Knighton to J. Carey letter issued by the NRC 1 4-25 4.4.8 on Septenber 18, 1984, and Chapter 16 of the SER, BVPS-2 Tech. Specs. should be modeled after the BVPS-1 Tech. Specs. (which do not include a requirenent for LPMS) and not like

the Standard Tech. Specs. BVPS-2 does not take any licensing credit for the LPMS and I therefore an LPMS Tech. Spec. is not ... derived fron the analyses and evaluations

! included in the safety analysis report," pursuant to 10CFR50.36(b). Therefore, DLC will i

not include the LPMS In the BVPS-2 Tech. Specs. If the staff insists on requiring the i

LPMS De addressed in the BVPS-2 Tech. Specs., DLC requests that the basis for this requirenent be identified and docunented in a response to DLC.

]' 56. 4-28 4.6 The CRDM ventilation systen fans are seisnically designed but are not seisnic Category I.

FSAR Section 9.4.8.1.3 will be updated to reflect this.

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SAFETY EVALUATION REPORT DLC COMENTS ,

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- PAGE 9 of 19 NO. 'PAGE' SECTION COMENT

57. 5-4 5.2.2.2 The PORV setpoint curve will be developed along with the appropriate Tech. Specs. This should be listed as a confirmatory item.

53. 5-5 5.2.2.2 The BVPS-2 Tech. Specs. will follow the BVPS-1 Tech. Specs. This area of the BVPS-1 Tech. Specs. is still under NRC review.

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59. 5-9 5.2.4.3 Open Iten 4: On January 31, 1985, DLC submitted an alternate plan for the preservice 6-32 6.6.1 exanination of ASME Class 2 piping welds. On May 20, 1985, the NRC approved the method-ology of the plan.

60. 5-9 5.2.4.3 Open Iten 4: NRC conments on the PSI progran were received in June 1985. The PSI 6-32 progran docunent is now scheduled for coupletion at the end of 1985.

thru 6-35 6.6

61. 5-10 5.2.5 Sixth paragraph, second sentence: This sentence is incorrect and should be deleted.

62. 5-10 5.2.5 Sixth paragraph, fourth sentence: This sentence should be revised to read as follows:

" Leakage collected in these tanks is punped to the boron recovery systen wi th the overheaa processed through the radioactive gaseous waste system."

63. 5-11 5.2.5 First paragraph, first and second sentences: Revise these sentences to the following:

" Unidentified leakage is also detected by a containnent airborne gas and particul ate radioactive monitor. This monitor responds to the increase in airborne radioactivity resulting fron leakage."

64. 5-11 5.2.5 Second paragraph, second sentence: Af ter the words " condenser air ejector vent line" add the words "and steam generator blowdown lines".

65. 5-19 5.4.2.2 Second paragraph: First sentence: Change " Specification NDS-0064 (Revision 0)" to

" Specification 10080-DMS-002 (Rev. 2)." Second sentence: Add "(Rev. 2)" af ter "Specifi-cation 10080-DMS-002." Third sentence: Change the words "after the field hydrostatic test and before" to the words " prior to."

SAFETY EVALUATION REPORT DLC COMENTS PAGE 10 of 19 NO. PAGE SECTION COMENT

66. 5-24 5.4.7.5 NRC still has not stated why the infonnation submitted by DLC on North Anna test results was not acceptable. DLC would like a reason docu,nented why North Anna infonnation does not meet BTP RSB 5-1 (which was accepted by NRC for North Anna) before DLC will address Diablo Canyon test results.

67. 5-26 5.4.11 Tnird paragraph, first sentence: Revise to the following: "Tne contents of the tank can be drained to the degasifiers in the boron recovery systen vi a the primary drains transfer pumps."

68. 5-27 5.4.12 Confinnatory Iten 23: As stated in Section 5.4.15.4, inservice inspection will be conducted in accordance with Section 6.6. Operating procedures will address this systen.

This iten should not be confinnatory. It should be either open or closed.

69. 5-27 5.4.12 The SER says that BVPS-2 Tech. Specs. must include Tech. Specs. on the vent systen as required by NUREG-0737, Iten II.B.1 (NUREG-0737 issued per D. G. Eisephut letter to all licensees of operating plants and NTOLs on October 31, 1980). However, this was super-seded by the H. Denton letter to all NRR enployees issued on July 23, 1984, regarding preparation of Tech. Specs. for second units at multi-unit sites. .Per that letter, "The only changes that are pennitted" (fron the first unit's Tech. Specs.) "are those which are absolutely necessary and justified, e.g., actual design difference or new regulatory requirenents applicable only to the unit being licensed." The BVPS-2 vent systen is not designed differently fran BVPS-1, nor is NUREG-0737 only applicable to BVPS-2 and not to BVPS-1. Thus, the BVPS-2 Tech. Specs, for this systen (or lack of Tech. Specs.) will be modeled after BVPS-1 Tech. Specs.

70. 6-3 6.1.2 Sixth paragraph, first sentence: Af ter the word "for" add the following words: "maj or surfaces in".

71. 6-5 6.2.1.1 Confinnatory Iten 24: As described in DLC letter 2NRC-4-132, dated August 22, 1984, 6-8 6.2.1.3 Westinghouse provided additional infonnation to the NRC in Letter NS-EPR-2948, dated August 14, 1984. DLC requests the schedule for completion of the NRC review.

72. 6-6 6.2.1.2 The following words in the last sentence of the seventh paragraph should be deleted:

" contingent on the acceptability of the mechanically constrained limit on the pipe break size (see Section 3.6)." The design basis for the reactor cavity will not be changed by the GDC-4 exemption.

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SAFETY EVALUATION REPORT DLC COMENTS PAGE 11 of 19 NO. PAGE SECTION COMENT

73. 6-6 6.2.1.2 As described in DLC Letter 2NRC-4-132, dated August 22, 1984, the SATAN-V Progran, which is described in WCAP-8312A, rather than the SATAN-VI Progran, was enployed in the sub-compartment analyses. Also, see FSAR Amendment 9, dated December 1984.

74. 6-7 6.2.1.2 Fifth paragraph, fourth sentence: Change 360 in.2 LDR to 320 in.2 LDR.  ;

75. 6-7 6.2.1.2 Sixth paragraph, third sentence: Change 12.9 psid to 15.08 psid.

76. 6-7 6.2.1.2 Seventh paragraph, first sentence: Change "three breaks" to "four breaks" and add the following words to the end of the sentence: "and a simultaneous rupture of three 6-in.

safety lines in the upper pressurizer cubicle (which is enveloped by the spray line DER)."

77. 6-8 6.2.1.2 First paragraph, first sentence: Change 18.07 psid to 5.38 psid.

78. 6-9 6.2.1.4 Second paragraph, fifth sentence: This sentence should be revised to indicate that credit has been taken for liquid entrainment in the mass and energy release analysis.

79. 6-10 6.2.2 Sixth paragraph, fifth sentence: Change "with" to "within".

80. 6-12 6.2.2 Confinnatory Iten 25: A more descriptive title of this iten is "Containnent Sump 50%

Blockage Assunption." As indicated in response to Question 480.26 in FSAR Anendment 6, dated April 1984, RG 1.82 indicates that an assuned 50% blockage is conservative. If the staff position is that 50% blockage assunption has to be justified as discussed in tne draft documents cited in the question response, this issue should be included on Table 1.3. Otherwise, this iten should be closed.

81. 6-32 6.6 The methodology for the preservice examination of ASME Class 2 piping as described in DLC Letter 2NRC-5-014, dated January 31, 1985, has been found acceptable by the NRC. NRC conments on the PSI Progran were received in June 1985 and the conpleted progran is scheduled for the end of 1985.

82. 7-7 7.2.2.l' Time constants are . required -by neither the Standard Tech. Specs. nor the BVPS-1 Tech.

i Specs. BVPS-2 Tech. Specs will follow the BVPS-1 Tech. Specs. as per the G. Knighton to '

J. Carey letter issued by the NRC on Septenber 18, 1984, and Chapter 16 of the SER.

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SAFETY EVALUATION REPORT '

DLC COMENTS PAGE 12 of 19 NO. PAGE SECTION COMMENT

83. 7-7 7.2.2.2 Periodic testing of the redundant circuits used to trip the turbine is required by neither the Standard Tech. Specs. nor the BVPS-1 Tech. Specs. Therefore, DLC does not agree that a Tech. Spec. to periodically test these circuits is required, as per the G.

Knighton to J. Carey letter issued by the NRC on Septenber 18, 1984, and Chapter 16 of the SER.

84. 7-9 7.2.2.5 DLC will use a value of 70% for P-9 in the BVPS-2 interlock. NRC has not justified why a lower value of 50% is required.

85. 7-12 7.3.1 Item (Sc): " Low Tave (2/3) coincident with Reactor Trip," is not an ESFAS as no credit is taken for this in FSAR Chapter 15.

86. 7-13 7.3.1 Iten (8): Service water isolation is from CI "A", not safety injection.

87. 7-21 7.3.3.10 Confinnatory Iten 27: FSAR Figure 9.2-4 was updated by FSAR Anendment 10 (May 1985) to correct the representation of automatic open signals for valves MOV 113B and C.

88. 7-24 7.3.3.14 This section should incorporate the infonnation included in Letter 2NRC-5-135, dated September 16, 1985.

89. 7-33 7.5.2.2 Confinnatory Item 29: FSAR Table 7.5-1 was revised in FSAR Anendment 9 (Decenber 1984) .

90. 7-36 7.6.l.2 Valve position indication for the accumulator isolation valves is provided fran both the valve motor operator limit switches and the valve sten limit switches.

91. 7-44 7.7.2.3 Confinnatory Iten 32: The documentation of the detailed plant review was submitted to the NRC in Letter 2NRC-5-141, dated October 15, 1985. DLC believes that this iteu should be closed.

92. 8-5 8.3.1.1 Tne third sentence in Iten (1) is misleading. It should state, "This condition postu-lates a hypothetical worst case event for analysis purposes, but is not credible as an actual event."

93. 8-6 8.3.1.3 The second sentence of the second paragraph is not accurate. It should state, ". . . using actual or simulated load .. ." '

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SAFETY EVALUATION REPORT DLC COMMENTS PAGE 13 of 19 NO. PAGE SECTION COMMENT

94. 8-12 8.3.3.1.2 Editorial: " lighting" should be " lightning".

95. 8-17 8.3.3.3.6 For consistency with the DLC submittal which is discussed:

" Configuration No. 2" should be " Configuration No. 3"

" Configuration No. 3" should De " Configuration No. 4"

" Configuration No. 4" should be " Configuration No. 6"

" Configuration No. 5" should be " Configuration No. 7"

96. 9-2' 9. l .1 No metal decking will be used in the new fuel area. The FSAR will be revised to reflect this.

97. 9-12 9. 2.1.1 Last paragraph, fifth sentence: Sentence should read: "A seisnic Category 11 restrict-ing orifice is provided in the SWS discharge line to the circulating water syiTem."

98. 9-24 9.3.2.2 Last paragraph on Page 9-24: This paragraph should be revised to indicate that the BVPS-2 core danage estimate procedure will ne provided before fuel load. The scheduled date for submittal of this procedure is Decenber 31,1986 (as indicated in Lett'er 2NRC 116, dated August 7, 1985).

99. 9-26 9.3.3 The first sentence of the last paragraph on Page 9-26 should be replaced with the follow-ing: "BVPS-2 is designed with a nonseisnic floor drainage systen and plant flood levels have been calculated without taking credit for drainage through the floor drains. For those areas where safety-related equipnent is located, backflow fron other areas through the drain lines is considered and all essential equipnent will be either qualified for submergence or located above the flood level." (See DLC response to NRC Question 410.24.)

100. 9-31 9.4.1 Second paragraph on Page 9-31: "RG 152" should be "RG 1.52".

101. 9-43 The staff is speaking of a need to evaluate the impact of flooding and the inadvertant

&44 9.5.1.1 operation of fire protection on safety-related equipnent. The evaluation has already been done and the results were submitted to the NRC in Letter 2NRC-5-054, dated March 27, 1985.

L

SAFETY EVALUATION REPORT DLC COMENTS PAGE 14 of 19 NO. PAGE SECTION COMENT 102. 9-44 9.5.1.3 Tne fire brigade is not shared between BVPS-1 and BVPS-2. However, three of the five dedicated menbers are conmon to both units with the renaining two being specific to either BVPS-1 or BVPS-2. The fire brigade roon and its equipnent is shared by both units.

103. 9-45 9.5.1.4 Fifth paragraph: Two 1.5-hour fire rated danpers were placed in series in conmon sleeves to provide the equivalent 3-hour rated danper. This deviation / justification was submit-ted to the NRC in Letter 2NRC-5-054, dated March 27, 1985, and preliminarily approved by the staff at the October 22, 1985, meeting.

Fifth paragraph: The fire danpers do not have UL labels. These aanpers were all pur-chased as UL-rated danpers. In most cases, tne UL ldbel was renoved due to the installed configurations, which were previously UL tested. The NRC was infonned of this deviation, and justification was provided by Letter 2NRC-5-054, dated March 27, 1985. During a meeting with the staff on October 22, 1985, preliminary approval was obtained on this issue.

104. 9-46 9.5.1.4 Fourth paragraph: Fourth sentence should be changed to read: "Tne turbine building south exterior wall adjacent to the transfonner is 2-hour rated."

105. 9-47 9.5.1.4 Under the topic " Electrical Cable Construction, Cable Trays, and Cable Penetrations," the second and third paragraphs are incorrect. First, all areas containing cable trays are provided with an early warning snoke detection systen. However, there are three fire areas where the requirenents of Section C.S.e of BTP CMEB 9.5-1 are exceeded and auto-matic fire suppression is not provided.

1. Reactor Contairunent (RC-1)

2. Auxiliary Building (PA-3)

3. Auxiliary Building (PA-4)

These areas have been laid out such that all trays can be effectively reached by a hose strean and contain early warning snoke detection. Safe shutdown analysis is provided for these areas and the rest in the FPER. (See Letter 2NRC-5-054, dated March 27,1985.)

SAFETY EVALUATION REPORT DLC COMMENTS PAGE 15 of 19 NO. PAGE SECTION COMMENT 106. 9-53 9.5.1.6 Seventh paragraph on Page 9-53: Tne NRC has conmitted DLC to implenent the reconmenda-tions of the DLC hunan f actors expert ( April 15, 1985, letter) . DLC is presently review-

i ng all of these reconmendations. However, sone of these reconmendations will not be impl enented . A letter will be sent to the N7r. discussing the hunan f actors improvenents and explaining why sone of the recommendations will not be implenented.

107. 9-53 9.5.1.6 Eighth paragraph on Page 9-53: The Director, DL, identified the northwest enener of the cable spreading roon as a deviation, in that a hose strean could not reach all parts of this area. DLC believes that this area (northwest corner) can be reached by a hose strean and is not a deviation. Letter 2NRC-5137, dated October 8,1985, was sent to the NRC stating DLC's position and identifying further steps DLC will take to inprove the fire fighting capabilities in this area.

108. 9-55 9.5.1.8 The cable spreading roon is a backfit, not an open item.

109. 9-67 9.5.3.3 The fourth sentence on the page should state: ".. . extended period of accunulated time (i.e., greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) ..."

110. 9-71 9.5.4.2 BVPS-2 Tech. Specs, will be modeled af ter the BVPS-1 Tech. Specs. as per Chapter 16 of 9-81 the SER and in accordance with the Standard Tech. Specs. Therefo re, the BVPS-2 Tech.

& 82 9.5.7 Specs. for energency diesel engine fuel oil and lubricating oil will be the sane as used in the BVPS-l Tech. Specs.

111. 9-72 9.5.4.2 The last sentence on the page should be deleted because the staff has received che infor-mation and closed the items.

112. 10-3 10.2 In FSAR Auendment 8, DLC did not conmit to follow the Standard Tech. Specs. for inservice inspection of the turbine valves. Iten 4 should be classified as the sane status as Itens 1-3. BVPS-2 Tech. Specs, will be written to be like BVPS-1 Tech. Specs. , not like the Standard Tech. Specs., as discussed in Ch apter 16 of this SER. A copy of the proposed BVPS-2 Tech. Specs. was provided to NRR in a letter issued Septenber 14, 1984.

113. 10-5 10.3 For _ clarity, the fifth sentence on the page should state, "... close on low pressure ..."

and a comma should be placed after "steamline".

SAFETY EVALUATION REPORT ~

DLC COMENTS PAGE 16 of 19 NO. PAGE SECTION COMMENT 114. 10-5 10.3 The thiro sentence of the third paragraph is not accurate and should be terminated after "s ig n al " . It should be followed by the following: "The valves are sized to inaintain hot standby for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, followed by a 26-hour cooldown, and have a required capacity of 26,200 lb/hr per valve with a 100 psia inlet pressure."

115. 10-16 10.4.9 The fourth sentence fron the end of the page should have " motor operated isolation valve" deleted to be accurate.

116. 10-17 10.4.9 The sixth sentence of the second full paragraph on the page should begin with "Pneunatic hydraulic operated."

117. 10-17 10.4.9 The eighth sentence of the second full paragraph on the page should be replaced with, "No nonsafety-rel ated piping is directly connected to the tank 'o elow the dedicated water level."

118. 10-17 10.4.9 The ninth sentence of the second full paragraph on the page should be supplenentd with,

... are seisnic Category I, except connection N4, which is associated with a nonsafety-rel ated tr ansni tter. This instrument and tubing and valves are designed as Seisnic Category II and will not f ail in a manner that will cause a loss of pressure boundary in the event of an SSE."

119. 10-17 10.4.9 The tenth sentence of the second full paragraph on the page should . state, "... Category H . . ." to be accurate.

120. 10-18 10.4.9 The third sentence of the third paragraph on the page describes an "open iten" which was closed based on a letter dated August 13, 1984. (Refer also to conment No. 23 on SER P age 3-10, Section 3.5.1.1) . This should state, " separate cubicle enclosure ... fran the turbine-driven pump. The applicant has provided ..."

121. 10-18 10.4.9 The seventh sentence of the fourth paragraph on the page should state, "... has solenoid operated valves that open .. ."

122. 10-18 10.4.9 The eighth sentence of the fourth paragraph on the page should be replaced with, "the solenoid valves are powered fron the energency busses and fail in the open position on loss of power to the valves."

SAFETY EVALUATION REPORT '

DLC C0l#4ENTS i

PAGE 17 of 19 NO. PAGE SECTION C0pO4ENT 123. 10-20 10.4.9 The third sentence of the third full paragraph on the page should end with, "... during hot standby or cold shutdown conditions."

124. 10-20 10.4.9 Fourth paragraph: The first four sentences should be revised to the following: "The 140,000 gallon PPDWST is maintained with at least 127,500 gallons of usable water by Technical Specification. This volume is adequate for maintaining hot standby for at least nine hours following a loss of nonnal feedwater. The PPDWST has connections to the 600,000 gallon denineralized water storage tank, which will contain approximately 543,000 gallons of usable volume that can be transferred to the PPDWST. The connection between the two tanks is above the 127,500 gallon level in the PPDWST." The FSAR will be anended.

i 125. 10-20 10.4.9 The BVPS-2 Tech. Spec. is being revised to require a lower value of gallons of water be stored in the PPDWST (e.g. , approximately 127,000 gallons) . A FSAR change is being developed to correct this information in the FSAR. Due to the tank instrumentation design limitations (e.g., minimun possible instrumentation error) the tank itself won't i

allow a Tech. Spec. requiring 140,000 gallons. Therefore, the statenent on PPDWST l

required volume should be altered to say "later." Upon final evaluation, the NRC will be notified of the final value for this Tech. Spec. criteria. The design basis is being changed for the PPDWST to be 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> at hot standby, rather than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in hot standby plus 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to cooldown, in order to be consistent with the BVPS-1 Tech. Specs. (in accordance with Chapter 16 of this SER).

126. 11-9 11.4.2 Second paragraph on Page 11-9: The confinnatory iten on the Solid Waste Process Control Progran will be addressed in a topical report which will be submitted directly to the NRC by the systen vendor (Stock Equipnent Company). This report will be submitted to the NRC before initial reactor heatup. The scheduled submi ttal date is March 31, 1986, as indicated in Letter 2NRC-5-ll6, dated August 7,1985.

127. 13-3 13.2.1.3 The " loss of cool ant" iten should be corrected as follows to be consistent with the Denton letter and to be correct:

loss of coolant including:

- significant PWR stean generator leaks

- inside primary containment '

- large and small, including leak-rate detennination

- saturated reactor coolant response

SAFETY EVALUATION REPORT ,

DLC COMMENTS PAGE 18 of 19 NO. PAGE SECTION COMMENT 128. 13-12 13.3.2.4 The SER deficient energency action levels have been reviewed by DLC. Where appropriate,

& 13 changes have been made in Issue 7, Rev. 6, of the BVPS-1 plan.

129. 13-18 13.3.2.12 The EPP (Issue 8, Rev.1) has been revised to state that the letters of agreenent will be certified to be current on an annual basis.

130. 13-22 13.3.3 Tne BVPS-2 EPP and inplenenting procedures addressing the SER open itens will be submit-ted to the NRC for review at least 180 days before fuel load.

131. 14-3 14 The sentence above Iten (1) should end with, "... initial test progran or its descrip-tion." Some of the changes did not affect the test, only the FSAR.

132. 14-3 14 Iten (1) should be deleted since nothing new was added to the FSAR or the table. The reviewer was merely referred to a table which already existed.

133. 14-3 14 Iten (4) should state, " Describing testing to ..." since the tests were not expanded, just their descriptions.

134. 15-4 15.1.4 First paragraph: BVPS-2 does not have a Baron Injection Tank. The third sentence should

, read : "The safety injection systen (SIS) irdects borated water (2,000 ppm) fran the refueling water storage tank into the primary coolant system ..."

135. 15-6 15.2.6 The statenent regarding sufficient water in the PPDWST to cool the plant to 350*F is not correct. DLC is planning to revise this statenent that the volume in the PPDWST is able to hold the plant at hot standby and safety grade backup water source fran the Service Water Systen is provided to cool the plant down.

136. 15-20 15.7.3 Last paragraph of Section 15.7.3: The fifth sentence indicates that in the case of an RWST rupture, the dilution factor at the Chester intake is 2,000. FSAR Table 15.7-4 indicates that this dilution factor is 476. The SER should be changed to read a dilution f actor of 476.

137. 15-2 2 15.9.2 Confinnatory Itens 41b and 41d: These itens should be closed based on DLC's conmitnent 15.9.3 to do this. Procedures do not need to be subnitted for this.

15-24 15.9.11

SAFETY EVALUATION REPORT .

DLC COMMENTS PAGE 19 of I9 NO. PAGE SECTION COMENT 138. 18-2 18.1 The SER states that the sunmary report "will be submitted on June 1, 1985." This is incorrect. The actual submittal date was Decenber 2,1985 (Letter 2NRC-5-147) . This date was negotiated with the NRC prior to the original scheduled submittal date.

139. 22-1 22.2 In accordance with 10CFR140.13, financial protection in the anount of $160,000,000 has been obtained from NELIA. Copies of the policies are on file with the NRC.