ML20207H331

Forwards Addl Info Re Containment Isolation Design/Chemical & Vol Control Sys,Per NRC 861016,1105 & 10 Requests & Unresolved Items Noted in Insp Repts 50-327/86-20 & 50-328/86-20

ML20207H331
Person / Time
Site:	Sequoyah
Issue date:	01/02/1987
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8701070508
Download: ML20207H331 (75)

Text

ef y o. TENNESSEE VALLEY AUTHORITY KNOXVILLE. TENNESSEE 379o2 SN 157B Lookout Place BAN 02887 Director of Nuclear Reactor Regulation Attention: Mr. B. Youngblood, Project Director PWR Project Directorate No. 4 Division of Pressurized Water Reactors (PWR)

Licensing A U.S. Nuclear Regulatory Conunission Washington, D.C. 20555

Dear Mr. Youngblood:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 j SEQUOYAH NUCLEAR PLANT - CONTAINMENT ISOLATION DESIGN PERTAINING TO THE CHEMICAL AND VOLUME CONTROL SYSTEN IE Inspection Report Nos. 50-327/86-20 and 50-328/86-20, transmitted from

-J. A. 01shinski to S. A. White by letter dated April 23, 1986, identified unresolved items 50-327/86-20-09 and 50-328/86-20-09, Containment Isolation Design Pertaining to the Chemical and Volume Control System. During a telephone conference between NRC and TVA held af ter our receipt of the subject inspection report, NRC requested additional information on Sequoyah's I

containment isolation systems. On May 30, 1986 we provided a submittal to NRC in response to both the inspection report and verbal request for information.

Upon review of our initial submittal, NRC advised us of additional questions they had on Sequoyah's containment isolation system. A meeting was held

between NRC project management and staff and TVA on August 13, 1986, for the t-purpose of addressing and resolving all areas of concern then expressed by NRC. A supplement'to our May 30, 1986 submittal was provided to NRC by my letter to you dated September 24, 1986. This later submittal reflected i understandings and agreements reached in the August meeting as documented in meeting minutes issued by NRC on August 15, 1986. After reviewing our

! September 24, 1986 submittal, NRC conveyed additional questions to TVA by 1

means of telephone conferences held on October 16, 1986; November 5,1986; and l November 10, 1986.

! Enclosure 1 addresses all NRC questions concerning Sequoyah's containment

!- isolation system design currently known to TVA. The purpose of the submittal

is to close out this issue with NRC. Enclosure 2 contains a listing of connaitments made in this submittal.

8701070508 870102 0 PDR ADOCK 05000327 0 PDR [

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An Equal Opportunity Employer

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Director of Nuclear Reactor Regulation liAN02se7 Please direct any additional questions you may have concerning the Sequoyah containment isolation design to Timothy S. Andteychek at (615) 870-7470.

Also, please provide TVA with written confirmation of the closeout of this issue upon completion of the staff's review.

Very truly yours, TENNESSEE VALLEY AUTHORITY

.d.

. Gridley, Director Nuclear Safety and Licensing Enclosures cc (Enclosures):

U.S. Nuclear Regulatory Commission Region II Attn: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW Suite 2900 Atlanta, Georgia 30323 Mr. Carl Stahle, Sequoyah Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. G. G. Zech Director, TVA Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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ENCLOSURE 1 REVISED RESPONSE - NRC INSPECTION REPORT NOS. 50-327/86-20 AND 50-328/86-20 l JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE I DATED APRIL 23, 1986 l 1

Unresolvid Item 50-327/86-20-09 and 50-328/86-20-09 BACKGROUND NRC Inspection Report Nos. 50-327/86-20 and 50-328/86-20 identified an unresolved item (URI) concerning five (5) chemical and volume control system-(CVCS) containment penetrations. The penetrations involved are X-16, the normal charging supply, and penetrations X-43A, -43B, -43C, and -43D, the four reactor coolant pump (RCP) seal injection lines. The URI, identified during an Operational Readiness inspection, identifies the apparent nonconformance of the five penetrations cited to the explicit requirements of 10 CFR 50 Appendix A General Design Criteria (GDC) for containment isolation.

As a result of several telephone conferences between NRC and TVA pertaining to this issue, NRC requested that TVA prepare a submittal to provide full information for all containment penetrations which have isolation schemes differing from those explicitly allowed in GDC 55, 56, and 57; i.e., for those penetrations employing alternate isolation schemes found acceptable on other defined bases. A discussion of the Sequoyah Nuclear Plant (SQN) containment isolation system design basis was also to be provided, as well as a clarification of TVA's position on the SQN containment isolation design relative to the 10 CFR 50 GDCs at the time SQN was licensed. Such a submittal was prepared by TVA and transmitted to NRC for their review on May 30, 1986.

A meeting was held in Bethesda, Maryland, on August 13, 1986, between TVA and NRC to discuss the results of the NRC review pertaining to both the five

, subject CVCS penetrations and the SQN containment isolation design in general. The May 30, 1986 submittal was discussed at length with initial and new NRC issues addressed. The principal issues involved the containment isolation design for the five CVCS lines, the designated isolation design for the Emergency Core Cooling System (ECCS) lines, and NRC concern over interpretation of submittal statements concerning the " applicable design criteria" for SQN. It was agreed that a revised submittal would be prepared by TVA to differentiate between the design and licensing basis for the containment isolation system (CIS) for SQN, to provide additional technical l basis for the alternate isolation scheme employed at SQN for the RCP seal c injection lines, and to redesignate certain remote manual and automatic valves as containment isolation valves.

Each redesignated containment isolation valve was to be evaluated for leak testing requirements in accordance with

! 10 CFR 50 Appendix J. A subsequent telephone conference was initiated by NRC

! on August 21, 1986, in which several additional NRC concerns were identified for TVA investigation and response in the revised submittal.

! A revised submittal was made to NRC on September 24, 1986. Upon review of the

, submittal, NRC advised TVA in telephone conversations on October 16, 1986;

, November 5,1986; and November 10, 1986, of the need for both clarification of t

several issues and further detail of several concerns.

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TVA RESPONSE The three attachments to this submittal provide the containment isolation design information requested by NRC. Attachment 1 provides clarification of the design and licensing bases for the CIS for SQN and discussion of all penetrations identified by NRC for specific evaluation and response. This includes, but is not limited to, the five subject CVCS penetrations.

Attachment 2 provides a revised tabulated listing of pertinent information for SQN containment penetrations, segregating those penetrations for which their design meets the CDCs explicitly (as defined in GDCs 55, 56, and 57) from those for which their design employs alternate isolation schemes which are found acceptable on- other defined bases. The two tables providing this information have been resubmitted in entirety from the initial submittal, not just the changes, to provide for continuity in the review process. Attachment 3 provides estimates of the minimum schedule, cost, and radiation exposure that would be incurred by a work crew due to installing remote manual containment isolation valves in the RCP seal water injection lines. These estimates were generated at the request of NRC and are not a commitment on the part of TVA to perform such modifications to the RCP seal water injection lines at SQN. Information provided in the three attachments reflects understandings and agreements reached between TVA and NRC to provide information in the August 13, 1986 meeting unless otherwise stated.

S.yMMARY The CIS for SQN has employed designs which either meet the requirements of GDC 55, 56, and 57 explicitly or which are found acceptable on other defined bases. In all cases, the designs provide redundant isolation barriers such that any single failure would not result in release of containment atmosphere to the environment. Clarification of the design as presented in this submittal will be incorporated into section 6.2.4 and table 6.2.4-1 of the SQN Final Safety Analysis Report (FSAR) during the next annual update, contingent upon NRC approval.

The five subject CVCS penetrations have been evaluated as follows. The normal charging line, after redesignation of an automatic isolation valve as the outboard isolation barrier, meets the explicit requirements of CDC 55. The design of the seal injection lines, with local manual valves and a closed system designated as providing the outboard isolation barrier, meets the requirements of GDC 55 by employing a design found acceptable on other defined bases.

All valves now designated as containment isolation valves and all associated piping have been purchased to TVA Class B requirements. TVA Class B

! designation means the valves and piping are ASME Section III Class 2 Seismic Category I or equivalent. Valves and piping procurred before April 1973 are designed in accordance with ANSI standard B 16.5 and B 31.1, respectively, as I

opposed to Section III of the ASME Code.

All valves now designated as containment isolation valves are protected from both internal and external missiles, pipe whip, or jet impingment that may result from a postulated Loss-of-Coolant Accident (LOCA).

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All newly designated remote manual containment isolation valves have position indication in the main control. The local manual valves in the RCP seal injection lines that are now designated containment isolation valves do not have position indication in the main control room; these valves are open for normal plant operation and their closing would be recorded in the plant configuration log.

This submittal was prepared so as to provide for closure, upon review and approval by NRC, of URIs 50-327/86-20-09 and 50-328/86-20-09.

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ATTACHMENT 1 CLARIFICATION OF RESPONSE TO NRC QUESTIONS CONCERNING THE DESIGN AND LICENSING BASIS FOR THE CONTAINMENT ISOLATION SYSTEM FOR THE SEQUOYAH NUCLEAR PLANT As a result of NRC review of TVA's submittal of May 30, 1986, on the CIS design of the SQN, NRC requested clarification of the design and licensing basis for the CIS for SQN and additional information regarding the design basis for specific penetrations of concern to NRC. The following discussion will address both issues, with reference to the May 30, 1986 submittal and subsequent NRC/TVA discussions regarding designs for specific penetrations.

As stated in the previous submittal, the initial design criteria of the CIS for SQN was provided by Westinghouse using their " Systems Standard Design Criteria Nuclear Steam Supply System Containment Isolation," 1.14 Revisions 0 and 1. These documents reflected the requirements of criterion 53 of the Atomic Energy Commission's (AEC's) " Proposed General Design Criteria for Nuclear Power Plant Construction Permits" dated July 1967, which was the applicable regulatory requirement at the time. The AEC GDC 55, 56 and 57 were issued in 1971 and provided more explicit isolation requirements. Revision 2 to the Westinghouse design standard was issued in 1973 to reflect these requirements; however, Westinghouse did not recommend backfit of the design for SQN, as the initial design was considered technically adequate. Both the previous two and more recent design standards provided for redundant isolation such that no single failure would cause release of the conteinment atmosphere to the environment. The difference in isolation provisions between the earlier two and more recent Westinghouse standards, as is germane to this issue, involves the use of a closed system alone outside containment as an isolation barrier. It was believed by TVA that this use of closed systems in the SQN design met the GDCs as an isolation scheme acceptable on other defined basis. Thus, when SQN was licensed in 1980, the licensing basis for the SQN CIS was the 10 CFR 50 CDCs.

The following provides specific discussion of the original design provisions and bases, indicated NRC concerns, and TVA's reevaluation of the isolation provisions for the five subject CVCS penetrations and for additional specific penetrations or classes of penetrations for which NRC questions have been raised. Specific details for each penetration may be found in tables 2.1 and 2.2 of attachment 2 to this submittal.

A. Reactor Coolant Pump Seal Water Injection Line Penetrations X-43A. -43B -43C. and -43D The provisions for containment isolation relating to these four lines consist of a check valve inside containment to provide the inboard isolation barrier and a closed seismically qualified, TVA Class B system outside containment

, which is continuously pressurized postaccident by the high head safety injection pumps. It is desirable for certain transients and accidents that these lines remain in service to protect the RCP seals. Therefore, these lines are not automatically isolated by an isolation signal.

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b The system design provides for the following features. A second check valve, which is not missile protected, is provided in series on each line inside containment. Each line has also been provided with a locally operated manual needle valve outside containment. A single supply line feeds the four injection lines.

There are two seal water injection filters in parallel in the seal water injection supply line, as well as a filter bypass line. The valves to isolate the seal water injection filters and bypass line may be operated by reach bars extending from the concrete cubicle housing the valves. (Reference FSAR figure 9.3.4-1 for TVA flow diagram.)

System Operating Instructions require the valve in the bypass line to be isolated during normal operation, thereby isolating the bypass line from the supply line. Flow is passed through only one of the filters at a time, with the unused filter being isolated from the flow path by closing valves both upstream and downstream of the subject filter. When the pressure drop across the active filter exceeds 20 psid, or the radioactivity level on the filter exceeds 5 rem, the system is realigned to utilize the previously isolated filter and isolate the used filter. The valve realignment is recorded by the operators in the plant configuration log.

The initial concern of the NRC inspector regarding the design of these lines was the lack of conformance to the explicit requirements of GDC 55, i.e., no automatic isolation valve is provided outside containment. As previously stated, it is desirable to maintain injection flow to the RCPs following certain transients and accidents to protect the RCP seals. Therefore, these lines are not automatically isolated by an accident isolation signal. GDC 55 allows that certain classes of lines may employ alternate isolation schemes (from those explicitly delineated) if found acceptable on some other defined bases. TVA has previously taken credit for the closed system outside containment as providing the outboard isolation barrier. This originated from the initial design philosophy which considered a closed system alone to be an acceptable isolation barrier inside or outside containment. Following review of TVA's May 30, 1986 submittal, NRC indicated use of the closed system alone outside containment did not constitute an acceptable isolation scheme for these penetrations. The available local manual isolation valves were discussed as additional isolation provisions. NRC requested evaluation of the alternate isolation method proposed--check valve inside containment and closed system with local manual valves outside containment--be discussed in detail to ensure adequate provisions exist for isolation of these lines should the need arise postaccident.

Postaccident, these lines will be left in service and will be supplied by the high head safety injection pumps (centrifugal charging pumps) which also provide seal flow and normal charging flow in nonaccident conditions. Under normal, transient, and accident conditions, at least one of the centrifugal charging pumps (CCPs) will remain in operation providing ECCS/ charging flow / seal flow as required. Therefore, a water seal will be continuously provided on the subject penetrations at a pressure greater than 1.1 Pa to preclude air leakage outside containment through these lines. The closed system piping outside containment meets the requirements for a closed system outsido containment as provided in the SQN FSAR section 6.2.4 and, therefore, A-2 I

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provides a reliable barrier. This piping is leak tested (visual inspection) in accordance with NUREG-0737, position III.D.l.1, and is included in the ASME Section XI inservice pressure test program for SQN. If for some unexpected

reason it becomes necessary or desirable to isolate these lines postaccident,

the locally operated manual valves are available. NRC requested use of these j valves be evaluated, and either the needle valves or seal injection filter valves be redesignated as outboard containment isolation valves. The results

of this evaluation follow.

'The seal water injection filter valve (filter outlet) is the preferred method

of isolation. The seal injection filter outlet valve is located in a concrete block cubicle on elevation 690, approximately 100 feet from the l-containment wall, and may be operated with a reach bar from outside the

cubicle in the auxiliary building general spaces. This valve allows isolation of all lines quickly with a single valve operation (the alternate filter and filter bypass line are normally isolated), and would be accessible l postaccident from a dose consideration. The needle valves on the individual injection lines are located in the elevation 690 pipe chase at SQN, '

! approximately two feet from the containment (shield building) wall, in close j proximity to many ECCS injection lines, CVCS lines, and the boron injection tank (BIT). For the design basis accident and when in the recirculation mode, this area would be inaccessible from a dose standpoint. Based upon these j considerations, the seal injection filter outlet valves and the filter bypass l valve will be redesignated as outboard containment isolation valves. +

In the unlikely event that a leak should occur in the RCP seal water injection

{ filter valve packing, drains in the floors of the cubicles are provided to j duct any potential spillage to the Tritiated Drain Collector Tank, which has a capacity of 24,700 gallons. The drains are sized to accommodate a maximum leak rate of 50 spm that would be expected from a Residual Heat Removal (RHR) pump shaft seal (see Section H). Leakage due to failure of valve packing '

would be substantially less than the 50 spm design value. Thus, the cubicle

drains would provide for the effective removal of any leakage due to valve packing failure and not hinder access to the RCP seal injection line Jilter valves in the unlikely event that it should become necessary or desicable to i isolate the RCP seal injection line.

l The seal injection line flow is provided by the CCPs. Leakage detection for l

the CCP rooms is discussed in Section H. A leak in either pump room can be l' associated with the particular pump involved, and appropriate action taken to isolate the affected equipment. From the CCP room, the seal injection line is generally rcuted through pipe chases that contain a number of other pipes.

Local leak detection for the lines running through a common pipe chase is not provided for by the leakage detection system at SQN. In the unlikely event that leakage due to a valve packing failure would occur, identification of the i

affected line by the leakage detection system without operator action is not possible. The operator, however, can sequentially isolate the lines passing

! through the common pipe chase until the affected line is found. Furthermore, l t any leakage resulting from valve packing failure, should it occur, would be l expected to be considerably smaller than the 50 spm design valve resulting l from a postulated RHR pump shaf t seal failure (see Section H). Thus, it is L expected that any unexpected leakage that may occur due to valve packing l failure in the RCP seal injection lines can be identified and isolated before the loss of a significant amount of water.

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These redundant isolation provisions--the inboard check valves, the closed system, the water seal, and the seal injection filter isolation valve--provide assurance that no single failure could result in release of containment atmosphere to the environment. Therefore, protection of the health and safety of the public is ensured and this isolation design is considered acceptable on other defined bases as presented above.

The seal water injection filter outlet and bypass valves have been evaluated with respect to testing requirements for containment isolation barriers in accordance with 10 CFR 50 Appendix J. SQN Emergency Operating Instructions (E0Is) call for continuous operation of the CCPs postaccident and thereby ensure a guaranteed 30-day water supply and injection pressure greater than 1.1 Pa, even with consideration of a single active failure. Thus, these valves are not subject to Type C leak testing. This seal system satisfies the provisions of Standard Review Plan (SRP) section 6.2.6.

TVA understands that its position is technically acceptable but that NRC may require an exemption to 10 CFR 50 to fully resolve this issue. TVA is prepared to file an exemption for these penetrations by January 15, 1987.

B. Normal Charging Line Penetration X-16 The provisions for containment isolation relating to this line consist of a check valve inside containment to provide the inboard isolation barrier and a closed seismically qualified, TVA Class B system which is pressurized continuously postaccident by the CCPs to provide the outboard barrier.

Additionally, two automatic isolation valves are provided outside containment which isolate on the safety injection signal.

The initial concern of the NRC inspector regarding the design of this line was that per the SQN FSAR table 6.2.4-1. TVA did not identify an outboard containment isolation valve as required by CDC 55. TVA has previously taken credit for the closed system outside containment as providing the outboard isolation barrier. This originated from the initial design philosophy which considered a closed system alone to be an acceptable isolation barrier inside or outside containment. The two automatic accident isolation valves were recognized as system isolation valves necessary for ECCS purposes, not for containment isolation purposes. While differing from the explicit requirements of GDC 55, the scheme was considered acceptable on another defined basis, in that redundant isolation capability was provided such that any single failure would not result in release of containment atmosphere to the environment. Following review of TVA's May 30, 1986 submittal, NRC indicated use of the closed system alone outside containment did not constitute an acceptable isolation scheme for this penetration. Use of the available automatic isolation valves was discussed.

As requested by NRC. TVA has redesignated one of the outboard automatic isolation valves (the valve closest to containment) as the outboard containment isolation barrier. This designation will bring the containment isolation design for this penetration into explicit compliance with GDC 55.

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The redesignated outboard isolation valve has been evaluated with reference to l testing requirements for containment isolation barriers in accordance with 10 CFR 50 Appendix J. This valve is not subject to Type C testing, as a water

seal is provided on this penetration postaccident with a guaranteed 30-day water supply and injection pressure greater than 1.1 Pa as a result of the i

continuous operation of the CCPs as required by the SQN E0Is, even with i consideration of a single active failure. This seal system satisfies the

} provisions of SRP section 6.2.6.

l C. Emergency Core Cooling System Lines - Penetrations X-22 -33, -32, -21,

-20A. -20B -17. -108. -109 a

l The basic provisions for containment isolation relating to this class of lines i

consist of missile protected check valves inside containment on each branch (a

! small test line branches off each main line inside containment isolated with a

normally closed globe valve) and a closed seismically qualified, TVA class B

! system outside containment. These essential lines must be available I postaccident to supply ECCS flow as required and, therefore, cannot be automatically isolated by an isolation signal. Additional design features are 4 provided for these lines. With one exception, each line has been provided with a remote manual valve outside containment which can be operated from the control room to isolate the line should the need arise postaccident.

j Additionally, there are other check valves located inside containment in each

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branch line which are not missile protected.

Following NRC review of the TVA May 30, 1986 submittal, it was noted that TVA j did not identify in the submittal table 2.2 or in the FSAR table 6.2.4-1 an

outboard isolation valve on these lines as required by GDC 55. It was i acknowledged that the explicit requirements of GDC 55 could not be met for these lines in that automatic isolation could not be provided; however, NRC

! stated that the alternate isolation scheme for these lines considered l acceptable by NRC on other defined bases was the use of remote manual valves l on the seismically qualified ECCS systems. This scheme was identified as the acceptable alternative in the SRP section 6.2.4. TVA has previously taken credit for the closed systems outside containment as providing the outboard j'

isolation barriers. This originated from initial design philosophy which considered a closed system alone to be an acceptable isolation barrier inside j or outside containment. TVA had, therefore, considered this scheme acceptable on other defined bases in that redundant isolation was provided such that any j single failure would not result in release of containment atmosphere to the j environment.

As requested by NRC. TVA has redesignated the remote manual valves available i

on the ECCS lines as outboard containment isolation valves. This designation I will bring the isolation design for these penetrations into compliance with

, GDC 55 on the other defined bases designated in SRP section 6.2.4. The one

! exception to the above provisions was discussed with NRC and basis for

! acceptability provided as follows.

I The design features for penetration X-17 at SQN, the RHR pump supply to the loop 1 and 3 hot legs, consist of primary and secondary (missile protected) check valves on the two primary branch lines inside containment, a remote i

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o manual motor-operated valve on the single supply line to the branches inside containment, and a closed seismically qualified, TVA Class B system outside containment. (Additionally, inside containment there is a normally closed remote-manual valve on a small test line branch off the single supply line and a relief valve on a second branch off the single supply line.) This design deviates from the previously discussed isolation scheme for ECCS lines in that the remote-manual valve is located inside containment with the outboard barrier provided by the closed system alone. It is TVA's position that this design is acceptable in that redundant isolation barriers are provided in the form of the check valves, the closed safety system grade piping, and capability for remote-manual isolation postaccident if the need should arise.

No single failure would result in release of containment atmosphere to the environment. As requested by NRC, TVA has, therefore, redesignated the inboard remote-manual valve as an additional containment isolation valve and believes the design for this penetration meets GDC 55 on other defined bases.

The redesignated remote manual valves for the ECCS lines have been evaluated with reference to testing requirements for containment isolation barriers in accordance with 10 CFR 50 Appendix J. For the injection line penetrations from the CCPs and intermediate head safety injection pumps (SIPS), a water seal is provided on these penetrations postaccident with a guaranteed 30-day water supply and injection pressure greater than 1.1 pa as a result of the continuous operation of the pumps as required by the SQN EOIs, even with consideration of a single active failure. Therefore, these lines are not subject to Type C leak testing.

For the injection line penetrations from the low head safety injection pumps (RHR pumps), a water seal is provided postaccident by operation of both RHR pumps with a guaranteed 30-day water supply and an injection pressure greater than 1.1 Pa.

With a single active failure of an RHR pump, the water seal will not be maintained on the associated penetration (s) during the recirculation mode.

However, any leakage past the primary and secondary check valves and the renote manual valve would be into a seismically qualified closed system of safety system grade piping. (Both the primary and secondary check valves are leak tested with water as pressure isolation valves to a requirement of less than or equal to 1 spm at a nominal Reactor Coolant System (RCS) pressure of l

2235 psig.)

The piping outside containment meets the requirements for a closed system outside containment as presented in section 6.2.4 of the FSAR. There is testing performed which verifies integrity of this piping. This testing includes annual inspections in accordance with NUREG-0737, position III.D.1.1, inservice pressure testing in accordance with ASME Section XI, and quarterly ASME Section XI pump tests. As the RHR system is a dual purpose system used during normal operation, an additional opportunity is provided to verify

system integrity.

l Most importantly, these RHR ECCS injection lines must be available to provide l water to the core postaccident to prevent fuel damage. The addition of in-line block valves to permit leak rate testing in accordance with 10 CFR 50, Appendix J would reduce the reliability of these lines to perform their primary safety function following a LOCA.

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O The combination of a water seal system, a qualified closed system, inspection and testing to verify system integrity, and the need for reliable operation of the ECCS system provides the bases upon which TVA will request an exemption from Type C leak rate testing for the RHR penetrations that supply the cold legs.

The redesignated remote manual valves for the Upper Head Injection (UHI) lines have been evaluated with reference to testing requirements for containment isolation valves in accordance with 10 CFR 50, Appendix J. The UNI system is normally filled with water from the accumulator up to the primary check valves going into the reactor head. The differential pressure between the RCS and the UHI system keeps the check valves closed during normal operation. Valves 87-21 and 87-23, as well as 87-22 and 87-24, are open during normal reactor operation, providing for immediate availability of the UHI system fluid when it is needed under accident conditions. When the RCS pressure falls below approximately 1,200 psig, the UHI system begins to discharge into the reactor, and when the accumulator reaches low level, valves 87-21 and 87-23 (as well as valves 87-22 and 87-24) close, retaining a water seal with pressure much greater than 1.1 Pa on the outboard side of these valves. This water seal and pressure is maintained by the remaining water level in the UNI water accumulator and the pressure acting upon this water head from the UHI gas accumulator (nitrogen blanket). If for some unexpected reason residual pressure in the UHI system decreases, the pressure would, at worst, equalize with pressure inside containment. Any leakage or interaction between containment atmosphere and the UHI system volume would be contained by the closed, seismically qualified, TVA Class B system outside containment.

Valves 87-10 and 87-11, identified as containment isolation valves in the SQN technical specifications, are located in a test line outside containment.

These valves are closed during normal reactor operation and receive a phase A Containm'nt Isolation signal. It is possible to postulate a leak path of containment atmosphere to the floor drain collector tank through valves 87-10 and 87-11 in the ex-containment vent line. There are no manual or remote-manual block valves currently installed within the UHI system that will allow for a Type C test of these valves using air. However, TVA proposes to perform Type C leak testing of these valves with the pressure in the opposite direction of the containment pressure that would be experienced as a result of a postulated event that would actuate the UHI system. This test would provide assurance that valves 87-10 and 87-11 provide a seal, The above discussion provides the basis upon which TVA will request an exemption from Type C leak rate testing for the UHI penetrations.

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• Contstament Spray and Residual Heat Removal Spray - Penetrations X-48A.

i -48B. -49A. -49B i The basic provisions for containment isolation relating to these lines consist i of missile protected check valves inside containment and a closed seismically i qualified, TVA Class B system outside containment. These essential lines must

! be available postaccident to provide containment depressurization and, 4 therefore, are not automatically isolated by an isolation signal. As an

additional design feature, each line has been provided with a remote-manual l valve outside containment which can be operated from the control room to isolate the line should the need arise postaccident.

l 1 Following NRC review of the TVA May 30, 1986 submittal, it was noted that TVA did not identify in the submittal table 2.2 or in the FSAR table 6.2.4-1 an outboard isolation valve on these lines as required by GDC 56. It was acknowledged that the explicit requirements of GDC 56 could not be ret for

these lines in that automatic isolation could not be provided; however, NRC stated that the alternate isolation scheme for these lines considered

acceptable by NRC on other defined bases was the use of remote-manual valves l on the seismically qualified systems outside containment. This scheme was identified as the acceptable alternative in the SRP section 6.2.4. TVA has j previously taken credit for this closed system outside containment as j providing the outboard isolation barrier. This originated from initial design j philosophy which considered a closed system alone to be an acceptable j

isolation barrier inside or outside containment. TVA had, therefore, considered this scheme acceptable on other defined bases in that redundant isolation was provided such that any single failure would not result in i

release of containment atmosphere to the environment.

As requested by NRC, TVA has redesignated the available remote-manual valves on these containment spray (CS) lines as outboard containment isolation

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valves. This designation will bring the isolation design for these i

penetrations into compliance with GDC 56 on other defined bases as endorsed in l SRP section 6.2.4.

! The redesignated remote-manual valves for the two CS lines have been evaluated j with reference to leak testing requirements for containment isolation barriers in accordance with 10 CFR 50 Appendix.J. A water leg is maintained in the riser between the closed remote-manual valve and the CS ring header under normal operation. The motor-operated gate valves in the CS lines are t Presently leak tested (with water) to verify there is sufficient inventory in i the risers to maintain a water seal on the gate valves for 30 days even after i shutoff of the CS pumps. The water seal ensures there will be no leakage of

containment atmosphere to the environment. These provisions are described in l FSAR section 6.2.4.2.1. Additionally, any throughline leakage would be i contained within the closed seismically qualified, TVA Class B system outside containment.

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1 A-8 1._.-_ - _. . _ , _ . . _ . _ _ . _ _ _ _ _ _ _ . - . - - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . - _ _ _ . _ .

o i o The redesignated remote-manual valves for the two RHR spray lines have also been evaluated with reference to leak testing requirements for containment isolation barriers in accordance with 10 CFR 50, Appendix J. A water leg is also maintained in the risers for the RHR spray lines under normal operation.

1 It is intended that the RHR pumps operate continuously postaccident, thereby maintaining pressure on the system and a water seal on the backside of the remote manual valves and preventing loss of the water les in the riser. If, for some unforeseen reason, one of the RHR pumps should be taken out of service, the water seal on the back side of the remote-manual valves cannot be guaranteed. Thus, the motor-operated remote manual valves will be leak tested (with water) to verify there is sufficient fluid inventory in the risers to

maintain a water seal on the valves for 30 days even af ter shutoff of an RHR pump, thereby ensuring there will be no leakage of containment atmosphere to the environment. This test is identical to that performed for the CS lines.

The provisions of the test are described in FSAR section 6.2.4.2.1.

, Additionally, any throughline leakage that may occur would be contained within the closed seismically qualified, TVA Class B system outside containment.

l E. Relief Valve Discharge to Pressurizer Relief Tank Penetration K-24 The provisions for containment isolation relating to this penetration consist of a check valve inside containment to provide the inboard isolation barrier and closed seismically qualified, TVA Class B systems--ECCS, CVCS, and CS--outside containment to provide the outboard barrier. Relief valves which provide overpressurization protection for the respective systems are located

, on these systems outside containment and relieve into a discharge header back j into containment through the penetration to the pressurizer Relief Tank.

, Questions were raised in the August 21, 1986 conference call held between NRC j and TVA concerning the containment isolation design for this penetration. NRC l requested the relief valves be redesignated as the outboard containment isolation barrier (s) in addition to the closed systems as opposed to the

closed systems alone outside containment. Additionally, the question was

, raised regarding the different provisions for this line as delineated in the Westinghouse Revision 1 standard and the Revision 2 standard.

As requested by NRC, TVA has redesignated the relief valves as outboard containment isolation barriers in addition to the closed systems. The SQN design for this penetration meets the GDCs on other defined bases. Review of

the two Westinghouse design standards and discussions with Westinghouse

indicate the Revision 1 design is as reflected in the SQN design described j above. The use of the relief valves as containment isolation valves in this '

application is acceptable as containment pressure is applied in the opposite I

direction that the valves relieve. The Westinghouse revision 2 standard does not depict this penetration. Westinghouse has explained that as an effort to

~

minimize the number of containment penetrations, the Revision 2 design assumes the relief discharge is not routed back into containment but instead into the

CVCS holdup tanks in the auxiliary building.

I i

i

! A-9 i

i

e For the pressure relief valves in lines running from SI lines, a water seal is provided with a guaranteed 30-day water supply at an injection pressure greater than 1.1 Pa as a result of the continuous operation of the CCPs as l required by the SQN E0Is. Thus, these pressure relief valves are not subject to Type C testing.

In general, however, Type C leak rate testing cannot presently be performed for the valves in the line associated with penetration X-24. There are no manual or remote-manual block valves in the line that would allow such testing of those valves. Furthermore, ASME Section III, Class 2, NC-3677.3, states that there shall be no intervening stop valves between pressure relief valves and their relief points to ensure those lines cannot be inadvertently isolated. However, any throughline leakage that may occur through the

! pressure relief valves would be contained within the closed seismically qualified TVA Class B system outside containment. Also, the containment pressure would tend to operate to further ensure the check valve and pressure relief valves would seat tightly. Based on the preceding discussion. TVA will

! request an exemption from the requirement to perform Type C leak rate testing on the check valve and all nine relief valves associated with the X-24 penetration.

F. Hydrogen Purge Penetration X-40D Containment isolation for the hydrogen (H2 ) purge penetration is provided by a blind flange equipped with double 0-ring seals. The flange is located outside containment in the auxiliary building.

In the August 21, 1986 NRC/TVA conference call, NRC stated that while the isolation scheme is acceptable (from a containment isolation standpoint) for a line that is not used at power or postaccident, use of a blind flange would not be acceptable for a line that would have to be opened to mitigate the consequences of an accident. NRC expressed concern that the provisions of this line for containment isolation could be in conflict with necessary provisions for the H2 purge system, i.e., meeting the requirements of 10 CFR 50.44. In response, TVA has reviewed both the isolation provisions for this penetration and the system design requirements per 10 CFR 50.44. The findings of this review are presented as follows.

Containment H2 Purge capability was initially required by 10 CFR 50.44(e) to s provide a backup to the redundant safety-related hydrogen recombiners which

, were designed to provide H2 control following design basis accidents such as a large break LOCA. The design for SQN was reflected in the prelicensing FSAR section 6.2.5 and system approval granted by NRC in section 6.2.5 of the original SER for SQN. As a result of TMI-2 (NUREG-0737), SQN was required to t

A-10

1 w

install an H2 mitigation system to provide hydrogen control capability for a 4

postulated degraded core event which would result in generation of substantially larger amounts of hydrogen than produced in the design basis LOCA. This system at SQN is composed of igniters that are designed to burn H2 near the lower flammability limit.

A conflict resulted between the function and operation of the H2 purge system and the igniter system. The operation of the purge system (preigniters) was based on an assumption of a maximum five-percent metal-water reaction which would not produce the much larger volumetric quantities of hydrogen that a degraded core event would produce. Emergency procedures required the line to be opened if the hydrogen concentration inside containment exceeded three percent by volume. The igniters are designed to

handle the hydrogen produced by metal-water reaction involving up to 75 percent of the fuel cladding. Emergency procedures require early initiation of igniter operation in the event of a LOCA, high containment pressure, or j degraded core event. The conflict arose where the procedures would have unnecessarily required and resulted in the containment being vented to the environment, albeit through filters, during a degraded core event coincident with igniter operation. As such, TVA concluded that the requirement for operation of the purge system postaccident should be deleted, and the emergency procedures requiring its operation be revised. A description of these changes to the procedures was provided in Appendix R of TVA's Report of the Safety Evaluation of the Interim Distribution of Ignition System for SQN Unit 1. This report was submitted to NRC in a TVA letter from L. M. Mills to A. Schwencer dated September 2, 1980.

j In summary, a H2 purge system was included in the H2 control system provided for SQN in accordance with the requirements of 10 CFR 50.44. Use of I this system was initially intended as a backup to the fully redundant hydrogen i recombiners to be used for control of hydrogen gas produced following a postulated LOCA. As a result of THI-2 and the potential for a degraded core

event, hydrogen igniters were later installed to handle the much larger volume

! of hydrogen produced by such an event. While the hardware still remains to j provide capability for controlled purging, it is not intended to be used at l SQN for postaccident hydrogen control. Purging and venting containment to the l environment, especially during a degraded core event, is undesirable and l unwarranted. The system was never required to be safety grade (beyond

containment isolation provisions) and the air supply is nonqualified. Use of

! this system would unnecessarily result in additional release of containment l atmosphere (filtered) to the environment. Therefore. *Se hydrogen purge l system is not intended to be used at SQN under postaccident conditions.

In consideration of the above, the design for penetration X-40D meets the requirements of CDC 56 on other defined basis designated in SRP section 6.2.4 l and does not degrade the hydrogen control system for SQN.

r A general question was expressed by NRC in the August 21, 1986 conference call concerning other containment penetrations employing blind flanges as the isolation scheme and whether they might be removed with the unit at power or i postaccident. Penetrations at SQN which employ blind flanges as the

{ containment isolation barrier are not intended to be opened postaccident.

Additionally, these blind flanges are not removed when containment integrity is required, i.e., are only opened in Modes 5 or 6.

A-11 t

v l .

G. Containment Vacuum Relief Penetrations X-111. X-112. K-113 The provision for containment isolation for each of these penetrations consists of two outboard isolation valves in series attached to penetration sleeves extending from the containment shell. The valve closest to containment is an air-power-operated isolation valve which is actuated by a set of redundant pressure sensors independent of those for other containment isolation valves, and the outer valve is a spring-loaded check valve .

In the NRC/TVA conference call held August 21, 1986, NRC expressed concern over the isolation provisions for these penetrations. The apparent concern was the lack of an isolation valve inside containment and consequences of a break in the " piping" outside containment between the isolation valve and containment shell. It was suggested that a demonstration of this " piping" as "superpipe" as designated in SRP section 3.6.2 . auld serve to resolve their concerns. A discussion of the design and response to NRC concerns is provided as follows.

The three vacuum relief lines are required to relieve pressure from the annulus into primary containment in the event of an inadvertent CS or air return fan actuation to prevent unacceptable pressure differentials from existing across the containment shell (see FSAR section 6.2.6). Both valves are located outside containment to allow the valves to be located as close to containment as possible yet provide reasonable access for maintenance, inspection, and testing.

The first isolation valve outside containment in each line is bolted directly to the containment penetration sleeve. This sleeve is designed and fabricated per thc ASME Boiler and pressure Vessel Code,Section III, Winter 1971 Addenda, subsection NE, and falls under the jurisdictional boundaries of Class MC according to NE-1142. The penetration sleeve between primary containment and the first outer isolation valve is part of the containment vessel. The stress in the penetration sleeve has been evaluated against the ASME section III Class MC allowables and against the stress given in section B.2.b of Branch Technical Position MEB 3-1. The results are provided in table 1.1, and clearly show that the stresses in the vacuum relief penetration sleeves are well below allowable values.

The butterfly valves in the vacuum relief lines are normally open valves that are designed to fail-open. This design feature was chosen because the valve-open position has been evaluated as providing for the greatest safety for the plant. In the event of an inadvertant actuation of CS or air return fan operation, a failure of the vacuum relief system could result in the collapse of the containment. Since the valves are normally open, each of the three butterfly valves in the vacuum relief system is provided by two solenoid actuators powered from redundant air supplies. Thus, the valves are single failure proof to closing when required except for a mechanical failure in the butterfly valvn itself. Both the butterfly valve and the check valve have position indication in the main control room.

For the above reasons, TVA believes that the present design of the vacuum relief lines is acceptable on other defined bases and provides redundant isolation capability to ensure protection of the health and safety of the public.

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9 H. Leakage Detection Components in Safeguards Systems With respect to piping and mechanical equipment outside the containment, considering the provisions for visual inspection and leak detection, leaks will be detected before they propagate to major proportions. A Westinghouse review of the equipment in the system indicates that the largest sudden leak potential would result from the sudden failure of an RHR or CS pump shaft seal. Evaluation of seal leakage assuming only the presence of a seal retention ring around the pump shaft showed flows less than 50 gpm would result, piping Icaks, valve packing leaks, or flange gasket leaks have been of a nature to build up slowly with time and are considered less severe than the pump seal failure.

1. The piping is classified in accordance with ANS safety Class 2 and receives the ASME Class 2 quality assurance program associated with this safety class.

2. The piping, equipment, and supports are designed to ensure no loss of function for the safe shutdown earthquake.

3. The system piping is located within a controlled area on the plant site.

4. The piping system receives periodic pressure tests and is accessible for periodic visual inspection.

5. The piping is austenitic stainless steel which, due to its ductility, can withstand severe distortion without failure.

Based on this review, design of the auxiliary building and related equipment is based upon handling of ECCS leaks up to a maximum of 50 gpm. To ensure adequate core cooling, design features are provided to prevent this limiting passive failure from causing any loss of function in the other train of the ECCS equipment due to flooding of redundant components or loss of section head to the ECCS pumps. Three independent means are available to provide information to the operator for use in identifying ECCS leakage into certain locations in the auxiliary building. These means include the auxiliary building flood detection system, the instrumentation and alarms associated with the drainage, and waste processing systems which normally handle drainage into these areas.

A flood detection system utilizing conductivity type water level detector devices is used to monitor and actuate alarms for ECCS and other leakage at locations throughout the auxiliary building. Individual detectors are located j in each ECCS pump compartment, in the ECCS heat exchanger rooms, in the pipe gallery for each unit, and in the pipe chase. A common alarm in the main control room will alert the operator indicator panel, located immediately outside the control room, then identifies the exact location of the tripped detector. The detector panel is provided with a test switch which can be used I

to verify the availability of power to each individual detector. These flood detectors are to be tested to verify initial operability and will be periodically tested as a part of the plant instrument surveillance and l maintenance program.

A-13

O Sines each ECCS pump heat exchanger compartment is monitored by a level detection device, the operator may immediately identify leakage into one of these rooms and determine which subsystem must be shut down and secured to terminate the leak. The operator can readily accomplish this action from the main control room by stopping the appropriate subsystem pump and by closing the corresponding sump isolation valves and individual pump discharge valves.

The time necessary for the operator to detect leakage into one of these compartments is dependent on the leakage rate. A limiting 50 gpm leak in the largest ECCS pump compartment can be detected within 30 minutes. Slower leaks will require proportionally longer detection times.

Leakage into the SIP or CCP compartments, the pipe chase, or the pipe gallery (all at elevation 669) is piped through the tritiated water drain header to the tritiated drain collector tank at elevation 651. ECCS leakage into the RHR or CS pump compartments or the pipe chase (all at elevation 653) is piped to the auxiliary building floor and equipment drain sump. The floor drain in each of these areas is provided with a standpipe which ensures that the setpoint for the water level detector is reached before draining the leakage from the room. However, the standpipes each have two 1/8-inch drilled holes to allow minor normal leakage to drain from the room.

The floor and equipment drain sump is provided with redundant 50 gpm pumps which automatically discharge on high level to the tritiated drain collector tank. Operation of these pumps is indicated in the main control room. Both the floor and equipment drain sump and the tritiated drain collector tank have high level alarms which indicate in the main control room. If the waste disposal system is available, the operator can manually initiate processing of the contents of the tritiated drain collector tank through the waste disposal

system. If the waste disposal system is not available the tritiated drain collector tank will fill and discharge through overflow piping to the auxiliary building passive sump.

Leakage into an ECCS pump or heat exchanger compartment can be detected by the flood detection system as described above. Leakage into areas other than these compartments can be detected by the flood detectors, by indication of sump pump operation, or by a high level alarm from the sump or the tritiated drain collector tank. However, the exact location of the leak, if from other than an ECCS pump or heat exchanger compartment, may not be immediately identified. Since ECCS leaks other than a pump seal failure are of a nature to develop very slowly and are less severe than a seal failure, the operator has an extended time period to detect and isolate the leak. Isolation of these minor leaks will be acomplished by arbitrarily selecting and isolating an ECCS subsystem and evaluating the response of the flood detector system. A factor which minimizes the probability of leakage into these areas is that the piping and valves in the RHR and CVCS systems are normally operated at temperatures and pressures which are greater than the postaccident conditions. Additionally, the entire ECCS is periodically inspected as a part of the inservice inspection program.

A-14

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l The flood detection system described above is not designed to meet the requirements of IEEE 279. The detectors, indicator panel, and control room alarm are single track and are powere t from nondivisional boards. However, j the system is designed such that a loss of power to any individual detector will be indicated on the indicator panel and will actuage the control room common alarm. Additionally, the nondivisional boards which supply the flood

' detection system are powered from a Class IE power board which is automatically loaded on the diesel generators. This ensures continued operability of the flood detection system following an accident.

In addition to the flood detection and normal drainage processing systems described above, water level sensor is provided in the auxiliary building passive sump (elevation 643). This sensor is designed to alarm in the main control room at three separate sump levels.

t i

e A determination of the time available for corrective operator action before

functioning of the redundant train of ECCS equipment would be impaired was d

made based on the assumed continuous leakage rate of 50 spm. An evaluation

} was made of the minimum time required to fill the passive sump (volume =

209,000 gallons) due to overflow of the tritiated drain collector tank.

l The calculated time of 2.9 days is conservative because no credit was taken j for processing of leakage through the waste disposal system. An additional evaluation was made of the time available before the required section head for the redundant ECCS pumps would be lost due to decreasing water level in the t reactor building sump. The calculated time of 5.0 days is conservative because no credit was taken for the volume of water which will be available due to melting of the ice condenser system ice (approximately 380,000 i gallons). These time periods are much longer than the time necessary for the i operator to detect and isolate the limiting 50 gpm leakage into an ECCS pump compartment.

With these design ground rules, continued function of the ECCS will meet

minimum core cooling requirements. A single passive failure evaluation is

presented in Table 1.2. It demonstrates that the ECCS can sustain a single passive failure during the long-term phase and still retain an intact flow path to the core to supply sufficient flow to maintain the core covered and affect the removal of decay heat. The procedure followed to establish the alternate flow path also isolates the component which failed.

I. POSITION INDICATION FOR CONTAINMENT ISOLATION VALVES All of the newly designated power operated containment isolation valves have position indication in the control room. The manually operated isolation valves in the RCP seal injection lines do not have position indication in the main control room (MCR). However, t~nese valves are open during normal plant

' operation, and any deviation from this position would be recorded in the plant configuration log.

( All other containment isolation valves, with the exception of the 22 listed in i

table 1.3, have position indication in the MCR. As noted in the table, position indication for these valves are located either in the auxiliary building or in the hot cample room. The installation of position indication for these valves in the MCR as per Reg Guide 1.97 is planned for the cycle 4 refueling outage at SQN. l A-15

ATTACHMENT 2 REVISED RESPONSE TO NRC QUESTION REGARDING SPECIFIC DESIGN OF CONTAINMENT PENETRATIONS FOR SEQUOYAH NUCLEAR PLANT 4

As a result of NRC review of TVA's previous submittal on this issue of May 30, 1986, TVA is resubmitting a sumary of the isolation provisions for all containment penetrations to reflect the results of that NRC review (presented by NRC in a subsequent NRC/TVA meeting and NRC/TVA conference call) as generally discussed in Attachment 1 of this submittal. The design of the containment isolation system for SQN is again being presented in the form of two tables following consideration of the 10 CFR 50 Appendix A GDC 55, 56, and 57 on a penetration-by-penetration basis. Based on these GDCs and the 10 CFR 50.2 definition (v) for reactor coolant pressure boundary, we have identified for each penetration: (1) penetration classification (CDC 55, 56, or 57); (2) physical configuration (barrier inside, barrier outside); (3) the applicable FSAR figure (if available); and (4) the other defined bases for acceptability if the isolation scheme does not explicitly meet the GDCs.

Supporting description, notes, and/or references are provided as appropriate.

The above information is provided in the form of two tables. Table 2.1 lists the penetrations for which the design correlates with the explicit GDC designated isolation schemes. Table 2.2 lists penetrations for which their design employs alternate isolation schemes which are found acceptable on other defined bases. Only principal process line isolation barriers are identified; penetration branch takeoffs such as vent, drain, and test lines and instrumentation sensing taps are not addressed within the scope of this presentation.

4 1

, , .__.c_-__ . _ - . - , - _ ,,_~-.__.__.,-w...r.-. . , _ . _ __y . . . - _

t ATTACHMENT 3 COST AND SCHEDULE IMPACT OF INSTALLING REMOTE-MANUAL CONTAINMENT ISOLATION VALVES IN THE REACTOR COOLANT PUMP SEAL WATER INJECTION LINES During the August 13, 1986 meeting between NRC and TVA on containment isolation issues held in Bethesda, Maryland, NRC expressed strong interest in having TVA perform a cost / benefit evaluation of installing remote-manual containment isolation valves outside containment for penetrations X-43A, -438,

-43C, and -43D. This cost / benefit study was to incorporate a probabilistic risk assessment of the likelihood of the need to isolate the subject lines and the consequences of the inability to isolate, should the need arise. It is TVA's position that such a study should be performed on a generic basis for the industry, not on a plant-specific basis.

During a telephone conversation on October 16, 1986 with NRC project j

management and technical staff. TVA suggested that, given current resource availability, it would be possible to identify the tasks associated with L installation of the remote manual valves in the seal water injection line.

NRC indicated that such information would be of value to them. Thus, TVA undertook an effort to identify the tasks and estimate their cost and schedule impacts, i The tasks that would be required to install remote-manual containment isolation valves in the seal water injection lines with provisions for leak testing for each unit at SQN are as follows:

i

l. Valve Requirements l a. Four motor-operated valves with associated conduit, cabling, and MCR i

indicators. Note: Valves must satisfy ASME Section III, Class 2, requirements and be equipped with IE operators; all equipment must satisfy applicable environmental qualification (EQ) requirements,

b. Four each of manual block valves and 1/2-inch vent valves to allow for Appendix J leak rate testing of isolation valves.

l 2. Division of Nuclear Engineering (DNE) activities

s. Author and issue an Engineering Change Notice (ECN).

l b. Procure all required materials.

I c. Perform a seismic analysis of the planned rerouting of piping.

( Note: Present configuration would require rerouting of piping to i install required valves.

l d. Perform electrical design; routing of conduit and cabling, i modification of control room panel to allow for MCR indicator of

! valve position, i e. Cenerate documentation for preceding activities, including drawing l changes and associated calculations to demonstrate flow requirements l to RCP seals is not impeded by piping rerouting and valve

! installation.

I i

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I l

9

3. Modification Activities

a. Generate mechanical workplan.

b. Generate electrical workplan,

c. Review and approve workplans through quality assurance (QA) procedure.

d. Execute workplans with required craft personnel; reroute piping, install hangers and valves, run cabling and conduit.

4. Postmodification Activities

a. Hydrostatic test of seal water injection lines to demonstrate integrity of new piping and valves.

b. Funetlonal test electrical hardware,

c. Appendix J 1eak rate test motor-operated valves; perform maintenance as required,

d. Change procedures EQ binder, operator training, technical specifications FSAR, and Surveillance Instructions.

e. Perform a flow balance test to RCP seals to ensure equal distribution of seal injection flow.

To accomplish the preceding tasks for each unit would require approximately two years, assuming the motor-operated valves must be procured from a vendor (18 months delivery time for the valves) at an approximate minimum cost of about $1,500,000. If appropriate valves could be located either in stock or warehoused, the preceding tasks may be accomplished in as few as about nine months at about the same minimum cost of approximately $1,500,000. A total exposure to the work crew used to implement the modification using estimated work crew sizes, times required to do similar tasks, and radiological surveys of the area of the plant in which the modification would be implemented is estimated to be about 47 man-rem.

9 Table 1.1 CONTAINMENT VACUUM RELIEF PENETRATIONS COMPARISON OF MAXIMUM AND ALf4WABLE STRESS LEVELS LOAD MAX. ALLOWABLE BTP MEB 3-1 SERVICE COMBINATION STRESS STRESS STRESS LEVEL (ksi) ASME CLASS MC (ksi)

(ksi)

P+DBE 1.65 15 16.2 B DBA+DBE 7.54 32 16.2 C P - Containment Design Pressure DBE - Design Basis Earthquake DBA - Dynamic effects due to the Design Basis LOCA I

Table 1.2 EMERGENCY CORE-COOLING SYSTEM RECIRCULATION PIPING PASSIVE FAILURE EVALUATION Long-Term Phase Flow Path Indication of Loss of Flow Path Alternate Flow Path Low Head Recirculation l

From containment sump to low head Accumulation of water in a residual Via the independent, identical injection header via the residual heat removal pump compartment or low head flow path utilizing the heat removal pumps and the residual Auxiliary Building sump second residual heat exchanger heat exchangers

. High Head Recirculation

! From containment sump to the high Accumulation of water in a residual From containment sump to the high head injection header via residual heat removal pump compartments or the head injection headers via heat removal pump, residual heat Auxiliary Building sump alternate residual heat removal exchanger and the high head pump, residual heat exchanger injection and the alternate high head charging pump.

4

9 Table 1.3 CONTAINMENT ISOLATION VALVES WITH POSITION INDICATORS OUTSIDE MAIN CONTROL ROOM Valve Penetration Location of Indication 1-FCV-32-102 U-l X-26 Elev 714 Aux Bldg.

2-FCV-32-103 U-2 X-26 Elev 714 Aux Bldg.

1-FCV-32-80

~

X-90 Elev 714 Aux Bldg.

2-FCV-32-81 X-90 Elev 714 Aux Bldg.

1-PCV-32-110 X-34 Elev 714 Aux Bldg.

2-FCV-32-111 X-34 Elev 714 Aux Bldg.

FCV-43-ll X-25D Hot Sample Room FCV-43-12 X-25D Hot Sample Room FCV-43-2 X-25A Hot Sample Room FCV-43-3 X-25A Hot Sample Room FCV-43-22 X-96C Hot Sample Room FCV-43-23 X-96C Hot Sample Room FCV-43-34 X-93 Hot Sample Room FC' 43-35 X-93 Hot Sample Room FC 75 X-85A Hot Sample Room FCV-43-77 X-8S Hot Sample Room l FCV-26-243 X-78 Elev 669 Aux Bldg.

FCV-26-240 X-51 l Elev 690 Aux Bldg.

(Pipe Chase)

FCV-43-58 X-14A Hot Sample Room i

} FCV-43-55 X-14B Hot Sample Room i

i FCV-43-61 X-14C Hot Sample Room FCV-43-64 X-14D Hot Sample Room

a.

TEbis 2.1 .

Pige 3 af 24 i -

Desier.CorrelatestoNxplicit +

1 10CFRs0 CDC Deauiraments .

Penetration Inside Outside FSAR Penetration Descriotion Classification' Barrierfs) Barrierfs) Finure Ref./ Notes i

a .

X-011 Instr. Rm. Purge Supply 56 30-20 30-19 9.4.7-1 X-012A Feedwater (FW)/ Aux. 57 Closed System 3-33, 3-164, 10.4.7-2 The FW valve, 3-33, isolates Feedwater (AFW) 3-164A, 3-174 and on an SI signal. The AFW 10.4.7-12 valves open to control S/G i 1evel on pump start. Remote manual operation available. Do not receive containment isolation signal.

t X-012B Feedwater (FW) 57 Closed System 3-47

• 10.4.7-2 Valve automatically

' and isolates on an SI signal.

10.4.7-12 Does not receive a contain-ment isolation signal.

1

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X-012C Feedwater (FW) 57 Closed System 3-87 10.4.7-2 See X-0128 and

, 10.4.7-12

'GDC 55. 56, 57 NOTE-- Autonette Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve 1

(RM) Remote Manual' Valve (CV) Check Valve 1

4

-em w -

' 4 **

Ttbla 2.1 .' P;ge 1 ef 24 ,

i Design Correlates to E plicit ~

1 10CFR50 CDC Reautrenwnts Penetration Inside Outside FSAR i Penetration Descriotion Classification 1 Barrierfs) Barrierfs) Fleure Ref./ Notes s

1 4 .,

I j X-004 Lower Comp. Purge Exh. 56 30-56 '

i 30-57 9.4.7-1 l

l X-005 Instr. Rm. Purge Exh. 56 30-58 i

30-59 9.4.7-1

. X-006 Upper Comp. Purge Exh. 56 30-50 30-51 i 9.4.7-1 X-007 Upper Comp. Purge Exh. 56 30-52 30-53 9.4.7 1 4

' GOC SS. 56, 57 i

riOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual valve (RM) Remote Manual' Valve j (CV) Check Valve J

l l 9

TEbis 2.1 ...'a Page 2 ef 24 .

Design Ccrrelates to E'xplicit . -

1 10CFR50 CDC Reauirements .

Penetration Inside Outside FSAR Penetration Descriotion classificationi Barrierfs) Barrierfs) Fiaure Ref./ Notes i

f X-009A Upper Comp. Purge Supply 56 30-08 30-07 9.4.7-1 X-0098 Upper Comp. Purge Supply 56 30-10 30-09 9.4.7-1 X-010A Lower Comp. Purge Supply 56 30-15 30-14 9.4.7-1 X-0108 Lower Comp. Purge Supply 56 30-17 30-16 9.4.7-1

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual valve (RM) Remote Manual' Valve (CV) Check Valve

Tabla 2.1 .- P:ge 4 Cf 24 .

Design Correlates to E plicit ~*

1 10CFR50 CDC Reautrements .

Penetration Inside Outside FSAR Penetration DescriR11RD Classification 8 Barrierfs) Barrier (s) Finure Ref./ Notes 8

i X-0120 Feedwater (FW)/ 57 Closed System 3-100, 10.4.7-2 . The FW valve, 3-100 Aux. Feedwater (FW) 3-171, and isolates on an SI 3-171A, 10.4.7-12 signal. The AFW valves 3-175 open to control S/G 1evel on pump start. Remote manual operation available. Do not receive containment isolation signal.

X-014A Stm. Gen. Blwdn. 57

• Closed System 1-14, 10.4.8-1 " Valve 1-182 is available.

43-58 X-014B Stm. Gen. B1wdn. 57

• Closed System 1-32, 10.4.8-1

• Valve 1-184 is available.

43-64 X-014C Stm. Gen. B1wdn. 57

• Closed System 1-25, 10.4.8-1

• Valve 1-183 is available.

43-61 l 'GDC 55. 56, 57 i' NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual' Valve (CV) Check Valve 2

4 .,

Ttbl2 2.1 .s Page 5 ef 24 .

Design Correlates to E plicit +

1 10CFR50 CDC Reautrements .

Penetration Inside Outside FSAR Penetration Dgserintion Classification' Barrier (s) Barrierfs) Floure Ref./ Notes i

a X-014D Stm. Gen. 81wdn 57

• Closed system 1-07, 10.4.8-1 'V'alve 1-181 is available.

43-55 X-016 Normal Charging 55 62-543 (CV) 62-90 9.3.4-1 Valve 62-90 is an auto-62-709 (LC) matic containment iso-and Closed lation valve in that it System closes on a Safety Injection signal which generates a i Phase A containment isolation

' signal. Therefore this penetration fully meets GDC 55. See additional discussion for this penetration in Attachment 1 of this document.

X-023 PASF Hot Leg 3 - 55 43-310 (RM)43-309 (RH) Valves are closed with power Train 8 removed during normal operation.

X-025A Przr. Stm. Sample 55 43-11 43-12 X-025D Przr. Liquid Sample 55 43-02 43-03

'GDC 55, 56, 57 I NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

i (LC) Locked Closed Manual Valve (RM) Remote Manual' Valve (CV) Check Valve 1

, *a

• 4 Trbia 2.1 .* P!ge 6 ef 24 i DesignCorrelatestodplicit '

1 10CFRSO CDC Reauirements .

Penetration Inside Outside FSAR Penetration Descriotion Classification 3 Barrierfs) Barrierfs) Einufg Ref./ Notes i

X-026B Control Air - Train B 56 Unit 1 32-102 9.3.1-6 32-297 (CV)32-295 (LC)

X-0268 Control Air - Train B 56 Unit 2 32-103 9.3.1-6 32-348 (CV)32-341 (LC)

X-027C ILRT 56 52-504 (LC)52-505 (LC)

X-029 CCS from RCP Coolers 56 70-89 70-92 UI 9.2.1-2 70-698 (CV) U2 9.2.1-3 J

i

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RH) Remote Manual' Valve (CV) Check Valve I

f i

i

_ _ _ _ -. . _ _ . . _ _ _.__ _ - - . . . _ . ._ . _ . . . .m ._. _ .

, , d -

Tib13 2.1 ri P;ge 7 af 24 $

Design Correlates to E plicit #

1 10CFR50 GDC Renutrements ,

l i

4 1

Penetration Inside Outside FSAR Penetration Description Classification 1 Barrierfs) Barrierfs) Fiaure Ref./gq1gs I

I X-030 Accum. to HU Tank 56 63-71 63-84 6.3.2-1

63-23 X-034 Control Air - 56 Unit 1 32-110 9.3.1-6 Nonessential 32-377 (CV)32-375 (LC) i i

X-034 Control Air - 56 Unit 2 32-111 9.3.1-6 i Nonessential 32-387 (CV)32-385 (LC)

X-039A N2 to Accumulators 56 77-868 (CV) 63-64 11.2.2-5 i

'GDC 55, 56, 57 NOTE-- Automatic Power Operated valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual' Valve (CV) Check Valve l

l

}

~

, ,g 8

Tab 12 2.1 ,' . P;ee 8 cf 24 ,

I

' Design Correlates to E'xplicit 1

.+

10CFRSO GDC Reouirements t

Penetration Inside Outside FSAR Penetration Descriotion Classification 1 Barrierfs) Barrierfs) Fleure Ref./ Notes a

d 1

X-0398 N2 to PRT 56 77-849 (CV)68-305 11.2.2-5 X-040A Aux. Feedwater 57 Closed System 3-156 10.4.7-12 Valves open to 3-156A control S/G 1evel 3-173 on pump start. Remote penual i

operation available. Do not receive containment isolation signal, i

l

] X-040B Aux. Feedwater 57 Closed System 3-148 10.4.7-12 See X-040A 3-148A 3-172 I

4 X-041 Floor Sump Pump Disch. 56 77-127 77-128 9.3.3-1 i

1 I

1

'GDC 55, 56, 57 NOTE-- Automat.ic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve

( RM) Remote Manual' Valve j (CV) Check Valve t I

I 1

i t ,

es Ttb12 2.1 s i

P ge 9 af 24 .

Design Correlates to E plicit

' 1 10CFR50 CDC Recuirements .

Penetration Inside Outside FSAR Penetration Description Classification 1 Barrierfs) Barrierfs) Fiaure Ref./ Notes 6

X-042 Primary Water 56 81-502 (CV) 81-12 X-044 Seal Water Return 55 62-61 62-63 9.3.4-1 62-639 (CV)

X-045 RCDT & PRT to Vent Hdr. 56 77-18 77-19 11.2.2-1 a 77-20 X-046 RCDT Pump Discharge 56 77-09 77-10 9.3.6-1 84-511 (LC)

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Re. note Manual' Valve (CV) Check Valve i

3

. _ . . - _ - ~ - ~ .

s

' . 4 .

Table 2.1 .

P!se 10 (f 24 .

Design Correlates to E plicit +

1 10CFR50 CDC Reauirmnents +

l

• l 1

i Penetration Inside Outside- FSAR Penetration Descriotion Classification' Barrierfs) Barrierfs) Fiaure Ref./ Notes 8

X-047A Glycol In 56 61-192 61-191 61-533 (CV)

, i X-0478 Glycol Out 56 61-194 61-193 l 61-680 (CV)

X-050A RCP Therm. Barr. Return 56 70-87 70-90 9.2.1-2 70-687 (CV)

X-050B RCP Therm. Barr. Supply 56 70-679 (CV)70-134 9.2.1-2

'GDC 55, 56, 57 NOTE-- Automatic Power Operated valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual' Valve (CV) Check Valve i

._ , __ - . ._. . ~ . - - -

4 ,

4 Tabl9 2.1 '

P!ee 11 af 24 . .

i Design Correlates to Explicit .

• 1 1 ,

J __ 10CFR50 GDC Renuirements Penetration Inside Outside FSAR I

Penetration Descriotion Classification 3 Barrierfs) Barriertsi Fiaure Ref./ Notes a

J .

a

• 1 X-051 Fire Protection 56 26-1260 (CV)26-240 9.5.1-10

}

X-052 CCS to RCP Oil Coolers 56 70-692 (CV)70-140 9.2.1-2 i

l X-056 ERCW Supply to Lower 56 67-562D (CV)67-107 9.2.2-3 Comp.

,1 j X-057 ERCW Return from Lower 56 67-111 67-112 9.2.2-3 Comp. 67-5750 (CV) 1

]

'GDC 55, 56, 57 f

i NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

? (LC) Locked Closed Manual Valve i (RM) Remote Manual' Valve '

I (CV) Check Valve t

j t

f i

• l

i. - -

Ttbla 2.1 .' P ge 12 ef 24 i j

4 Design Correlates to E'xplicit

• 1 10CFR50 CDC Reautrements .

]

Penetration Inside Outside FSAR Penetration Descrintion ClassificallAD 1 Barrierfs) Barrierfs) Fiaure Ref./ Notes s

X-058 ERCW Supply to Lower 56 67-562A (CV) 67-83 9.2.2-3 Comp.

• X-059 ERCW Return from Lower 56 67-87 67-88 9.2.2-3 Comp. 67-575A (CV)

X-060 ERCW Supply to Lower 56 67-5628 (CV) 67-99 9.2.2-3 Comp.

X-061 ERCW Return from Lower 56 67-103 67-104 9.2.2-3 Comp. 67-575B (CV) i 4

i

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

l (LC) Locked Closed Manual Valve (RM) Remote Manual' Valve

! (CV) Check Valve i

i l

4 Ttbla 2.1 ,,e PIge 13 cf 24 , -

Design Correlates to Ekplicit -

1 10CFR50 CDC Reauirements ,

Penetration Inside Outside FSAR Penetration Descrintion Classification 1 Barrierfs) Barrierfs) Fiaure Ref./ Notes i

l i

X-062 ERCW Supply to Lower 56 67-562C (CV) 67-91 9.2.2-3 Comp.

X-063 ERCW Return from Lower 56 67-95 67-96 9.2.2-3 Comp. 67-575C (CV) 0 X-064 Instr. Rm. Chill Water 56 31C-223 31C-222 Return 31C-752 (CV) 4 X-065 Instr. Rs. Chill Water 56 31C-225 a1C-224 Supply 31C-734 (CV)

'GDC 55, 56, 57 1

i NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Hanual Valve (RH) Remote Manual' Valve (CV) Check Valve l

d

)

Tabla 2.1. P!s9 14 ef 24 .

Design Correlates to E'xplicit #

1 10CFR50 GDC Reauirements

• Penetration Inside Outside FSAR Penetration Descrintion Classification' Barri.er(s) Barrierfs) Fiaure Ref./ Notes 6

X-066 Instr. Rm. Chill Water 56 31C-230 31C-229 Return 31C-715 (CV)

X-067 Instr. Rm. Chill Water 56 31C-232 31C-231 Supply 31C-697 (CV) 4 J

X-068 Upper ERCW Supply to 56 67-5800 (CV)67-141 9.2.2-3

Cooler l

1 1

X-069 Upper ERCW Supply to 56 67-580A (CV)67-130 9.2.2-3 Cooler j 'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

, (LC) Locked Closed Manual Valve

. (RH) Remote Manual' Valve

! (CV) Check Valve I

t i

. . - _ - - - = - -

, , , 4 TIble 2.1 i P;ge 15 g.f 24 Design Correlates to E plicit '

I

• 10CFR50 GDC Recuirements Penetration Inside Outside FSAR Penetration Description Classification 1 Barrierfs) Barrierfs) F1aure Ref./ Notes i

X-070 Upper ERCW Return from 56 67-297 67-139 9.2.2-3 Cooler 67-585B (CV) f X-071 Upper ERCW Return from 56 67-296 67-134 9.2.2-3 Cooler 67-585C (CV)

X-072 Upper ERCW Return 56 67-298 67-142 9.2.2-3 from Cooler 67-5850 (CV)

X-073 Upper ERCW Return from 56 67-295 67-131 9.2.2-3 Cooler 67-585A (CV) i d

'CSC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Hanual Valve (RH) Remote Manual' Valve (CV) Check Valve i

1

!'d Ttble 2.1 .

P ge 16 Af 24 .

Design Correlates to Explicit

1 10CFRSO CDC Reautrements ,

1 Penetration Inside Outside FSAR Penetration Descrintion Classification 1 Barrier (s) Barrierfs) Fioure Ref./ Notes 4

X-074 Upper ERCW Supply 56 67-580B (CV)67-138 9.2.2-3 4

b

, X-075 Upper ERCW Supply 56 67-580C (CV)67-133 9.2.2-3 X-076 Service Air 56 UI 33-704 (LC) UI 33-740 (LC)

U2 33-722 (LC) U2 33-739 (LC) i- X-077 Demin. H 2O 56 59-633 (CV)59-522 (LC) 9.2.3-2 59-529 (LC) l

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve

! (RH) Resote Hanual' Valve i

(CV) Check Valve t

l I

..- - --. - . .. . . . . ~ . . - .

1 Ttblo 2.1 ,

.- Piee 17 (f 24 DesignCorrelatestodxplicit 1

10CFR50 CDC Reauirements ,

i j Penetration Inside Outside FSAR i

Penetration Descrintion Classification 1 parrier(s) Barrierfs) Fleure Ref./ Notes I 8 I '..

^

1 j X-078 Fire Protection 56 26-1296 (CV)26-243 9.5.1-10 I

i X-080 Lower Comp. Press. Relief 56 30-40 30-37

9.4.7-1 l

1 5

i X-081 RCDT to Gas Analyzer 56 77-16 77-17

11.2.2-1 3

l

! X-082 Refueling Cavity Pump 56 78-560 (LC)78-561 (LC) 9.1.3-1 Suction 4

k 4

i i

1 I

l'

'GDC 55. 56. 57 I

NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RH) Remote Manual' Valve (CV) Check Valve a

1 l

! - 4 ,

+

TEbla 2.1 ,

. Pzge 18 Ef 24 s Design Correlates to E'xplicit '

1 10CFR50 CDC Reautrements i

l i

l l

Penetration Inside Outside FSAR l Penetration Descriotion Classification' Barrierfs) Barrierfs) Fiaure Ref./ Notes a

J l

. X-083 Refueling Cavity Pump. 56 78-558 (LC)78-557 (LC) 9.1.3-1 Discharge 1

i

! X-084A PRT to Gas Analyzer 56 68-308 68-307

}

i X-085A Excess Ltdn. HX to 55 43-75 43-77 Boron Analyzer l X-087B ILRT P-TAPS 56 52-502 (LC)52-503 (LC) i

'GDC 55, 56, 57 i

NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve i

(RM) Remote Manusl' Valve ,

(CV) Check Valve I

. . - _ . _ . . . . . . _ . ..__m.. . ._ _ _ . . ._.

t 4

Table 2.1 PIse 19 af 24 .

i 5 Design Correlates to Explicit -

1 10CFR50 GDC Reautrements ,

b Penetration Inside Outside- FSAR Penetration Descrintion Classificationi Barrierfs) Barrierfs) Fiaure Rgf./ Notes i

X-087D ILRT P-TAPS 56 52-500 (LC)52-501 (LC) i t.

X-090 Control Air - Train A 56 Unit 1 32-80 9.3.1-6 32-287 (CV)32-285 (LC)

J 4

X-090 Control Air - Train A 56 Unit 2 32-81 9.3.1-6 l- 32-358 (CV)32-353 (LC) i l

X-091 PASF Hot Leg 1 - 55 43-251 (RH)43-250 (RM) See X-023 Train A l

},

d

'GDC 55, 56. 57

NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

l (LC) Locked Closed Manual Valve

! (RM) Remote Manual' Valve (CV) Check Valve

(

4 i

i 1

r

. _ . . . . - _ - . . - ~. ---

t .'.

2 T bla 2.1 ,i Pc_ge 20 Cf 24 .,

Design Correlates to E plicit "

l 1

10CFR50 CDC Reoutrements ,

Penetration Inside Outside FSAR Penetration Description Classification' Barrierfs1 Barrierfs) Fiaure Ref./ Notes 6

X-093 Accumulator Sample 56 43-34 43-35 .

X-094A Upper Rad. Hon. - 56 90-109 90-107

, Intake l

l X-094B Upper Rad. Hon. - 56 90-108 90-107 j Intake i

l X-094C Upper Rad. Hon. - 56 90-110 90-111 I

Return i

i i

l

! 'GDC 55, 56, 57 i

! NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

i (LC) Locked Closed Manual Valve (RN) Remote Manual' Valve l (CV) Check Valve l

t

- ~= _

=

.__ . _ . ~

e Table 2.1 ,a Page 21 ef 24 . .

Design Correlates to xE'plicit

• 1 10CFRSO CDC Reauirements .

Penetration Inside Outside .FSAR Penetration Descriotion Classification' Barrierfs) Barrierfs) Fiaure Ref./N:tes a

X-095A Lower Rad. Hon. - 56 90-115 90-113 Intake i

X-0958 Lower Rad. Hon. - 56 90-114 90-113 Intake X-095C Lower Rad. Hon. - 56 90-116 90-117 Return 2

i X-096C Hot Leg Sample-Loops 55 43-22 43-23

, 2 and 3

?

1

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual' Valve j (CV) Check Valve l

l l

i 1

g 4 8 e ,

• TIbl9 2.1 .

P ge 22 af 24 .

Design Correlates to E plicit '

g '

, 10CFR50 GDC Reautrements ,

Penetration Inside Outside FSAR Penetration Descriotion Classification 1 Barrierfs) Barrierfs) Fiaure Ref./ Notes S

X-098 1LRT P-TAPS 56 52-506 (LC)52-507 (LC)

X-101 PASF Containment Air 56 43-319 (RH)43-318 (RM) See X-023 Intake - Train B X-102 AFW Test Line 57 Closed System 3-351C (LC)

X-103 PASF Liquid Discharge 56 43-461 (CV)43-317 (RH) to Containment See X-023 Note - Applies to 43-341 (RM) outboard valves only.

i l 'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Hanual Valve j (RM) Remote Manual

• Valve (CV) Check Valve i

i , '*

Table 2.1 .. Page 23 of 24 Design Correlates to E plicit '

1

. 10CFR50 GDC Recuirements l

l Penetration Inside Outside FSAR Penetration Descriotion Classification' Barrier (s) Barrierfs) Fiqure Ref./Notgi 6

9 X-104 AFW Test Line 57 Closed System 3-352C (LC)

X-106 PASF Air Discharge to 56 43-460 (CV)43-325 (RM) See X-023 Note - Applies to Containment 43-307 (RM) outboard valves only.

X-110 UHI Valve Test Line 55 87-7 87-9 6.3.2-15 87-8 X-114 Glycol Floor Cooling 56 61-122 61-110 6.5.6-2 61-745 (CV)

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual' Valve (CV) Check Valve

s a **

8 Ttbla 2.1 ,

, P!ge 24 (f 24 ,

Design Correlates to Explicit

• 1 10CFR50 GDC Renuirements ,

Penetration Inside Outside FSAR '

Penetration Description Classification 1 Barrierts) Barrierfs) Fiaure Ref./ Notes 6

'e X-115 Glycol Floor Cooling 56 61-97 61-96 6.5.6-2 61-692 (CV) '

l X-116A PASF Containment Air 56 43-288 (RM)43-287 (RM) See X-023 Intake - Train A l

t i

i 1

'GDC 55, 56, 57 NOTE-- Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve l (RM) Remote Manual' Valve (CV) Check Valve t

Tabla 2.2 .

P se 1 af 24.

Design Cirrolttss t2 1 +

toCFR50 CDC on Dther Defined Basis Penetration Inside Outside FSAR e...r'ritton Qt%CElDilDD Classificationi Barrier (s) Barrierfs) Fiaurc Dther Defined Basis Ref./ Notes i 005 Equipment Hatch 56

' Hatch ---

6.2.4-12 Double 0-Ring provides redundancy for hatch seal.

s 002A Personnel Airlock 56 Atriock Door Atriock Door 6.2.4-13 Two doors, both with double resilient seals and mechanical inter-locks.

0028 Personnel Airlock 56 Airlock Door Airlock Door 6.2.4-13 Two doors, both with i

double resilient seals and mechanical inter-

locks.

• I a 003 Fuel Transfer Tube 56 Blind Flange ---

6.2.4-14 Double resilient seals i provide redundant a

flange seal.

I, X 008 Spare 56 --- ---

Penetration is a seal-welded spare and,is a single passiGe barrier as is' primary containment.

3 4 GDC 55. 56, 57 i

NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve

(CV) Check Valve (RV) Relief Valve i

4

Tablo 2.2

• P!ge 2 af 24 Design CarrG1Et:s t2 1- ,

10CFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR PsoctCAL1QO Qgitr1Dtion Classification 1 Barrierfs) Barrierfs) Fleure other Defined nasis Ref./ Motes e Ot3A Main Steam 57 Closed System 1-04, 1-147 10.3.2-1 1-15, 1-05 &

The safety relief valves outside containment Safeties (5) required tc ensure transient and accident condition secondary side heat removal mechanism are acceptable as contain-ment isolation valves.

They have setpoints 4

greater than 1.5 Pa as allowed by Standard Review Plan 6.2.4 Section II.g.

> o'3B Main Steam 57 Closed System 1-11, 1-148, 10.3.2-1 See X-013A 1-12 and Safeties (5)

= 013L Main Steam 57 Closed System 1-22, 1-149, 10.3.2-1

., See X-013A 1-23, and Safeties (5) 4

'GDC 55, 56, 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manua' valve (CV) Check Vaive

) (RV) Relief Va*ve i

)

i

Tabla 2.2 Page 3 (f 24 DIsign CIrralttis ts 1

• 10CFR50 GDC on Other Defined Basis Penetration Inside Outside FSAR Penetration Descriotion Classification 3 Barrierfs) Barrierts) Fiaure Other Defined natis Ref./ Motes x-0130 Hain Steam 57 Closed System 1-29, 1-150, 10.3.2-1 See X-013A 1-16, and 1-30 and Safeties (5) l x 015 CVCS tetdown 55 62-72 62-77 9.3.4-1 One of the inboard 62-73 62-74 isolation valves is a pressure relief 62-662 (RV) valve,62-662, which relieves to the PRT. The relief valve is acceptable because containment pressure is acting opposite the direction that the valve relieves, thereby aiding the valve l to seat.

A 017 RHR Return 55 63-172 (RM) Closed System 5.5.7-1 63-640 (CV) Remote mancal valve 63-172 See additional 63-643 (CV) is located inside contain- discussion of ment in series with check this penetra-63-158 (RH) valves63-640 and 63-643.61-637 (RV) . tion in Attach-Remote manual valve 63-158 ment 1 of this is used for Section XI document.

'GDC 55, 56, 57 i NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve

) (RM) Remote Manual Valve l (CV) Check Valve i

(RV) Relief Valve i

i 1

4

Table 2.2 ~~

Pige 4 Cf 24 Design C rralitis t2 1 ,

10CFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR PcDCtraliOO QCitrifliDD Classification 1 Barrierfs) Barrierfs) Fiaure Other Defined Basis Ref./ Notes pressure boundary testing and is administrative 1y controlled. Reitef valve 63-637 is acceptable because containment pressure is acting opposite the direction that the valve relieves, thereby aiding the valve to seat.

. ole Spare 56 ---

See X-008 a oi9A RHR Sump 56

• 63-72 (RH) 6.3.2-1 " Containment Isolation and Closed for the RHR sump line System penetrations consists of: (1) a closed system outside containment, (2) a containment isolation valve (63-72) outside contajnment ':a'the auxiliary building which is a controlled leakage structure.

This valve is remotely controlled from the main control room.

'GDC 55, 56, 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check Valve (RV) Relief valve

_ _ _ ~

- - =

Tabla 2.2 P;ge 5 gf 24

• Design CIrralstis to I .

10CFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR PCncLraling QgicriotinD Classifications Barrierfs) Barrierfs) Eleurg Other Defined Basis Ref./ Notes This same discussion is given in the FSAR. This isolation scheme is acceptable per SRP 6.2.4 Section II.e and resolu-tion to NCR SQN NEB 8203.

e 0198 RHR Sump 56

• 63-73 (RH) 6.3.2-1

• Containment isolation for

. and Closed for the RHR sump line System penetration consists of:

(1) a closed system outside containment, (2) a containment isolation valve (63-73) outside

containment in the auxiliary 4

building which is a controlled leakage structure. This valve,is r6motely controlled from the main control room.

This same discussion is given in the FSAR. This isolation scheme is accep-table per SRP 6.2.4 Section II.e and resolution to NCR SQN NEB 8203.

'GDC 55, 56. 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manuat valve (RM) Remote Manual Valve (CV) Check Valve (RV) Relief Valve 4

_ _m

Tibl3 2.2 P!ge 6 C;f 24 Design CIrr31st:s ts 1 e 10CFR50 GDC on Dther Defined Basis Penetration Inside Outside FSAR Psocktation Qgscriolino Classification 1 Barrierts) Barrierts) Fiaure Other Defined Basis Ref./ Notes

1. o/UA SIS - RHR Pump 55 63-633 (CV) 63-94 (RH) 6.3.2-1 Discharge - Train B 63-635 (CV) and Closed See SRP 6.2.4 Section II.b 63-112 (RH) System for acceptability of out-board remote penual valve.

A test line adjoins this line inside containment between the check valves and primary containment. The isolation valve,63-112 In the test line is remote manually actuated from the main control room. This valve is open for short periods of time during normal operation for the performance of SIS and RHR system venting as described in Technical Specificatjon 4:5.2.

Thus,,this valve does not automatically close when the containment isolation or safety injection signal is initiated during the venting of the SIS and RHR system. This is accep-table because administrative

'GDC 55. 56, 57 NOTE--Autanatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Hanual Valve (RM) Remote Manual Valve (CV) Check Valve (RV) Relief Valve

T bla 2.2 P ge 7 Rf 24

• Design Cirralttss to 1 ,

loCFR50 GDC on Other Defined Basis Penetration Inside Outside FSAR PenetrAttga Qgscriotion Classification' Barrier (s) Barrierfs) Fiaure Other Defined Basis Ref./ Notes controls exist in the test documents to assure valve closure after testing and containment integrity is not compromised during testing since flow is being maintained.into containment by pump operation.

s U208 SIS - RHR Pump 55 Discharge - Train A 63-632 (CV) 63-93 (RM) 6.3.2-1 See SRP 6.2.4 Section II.b 63-634 (CV) and Closed for acceptability of out-63-111 (RM) System board remote' man 6al valve.

For discussion of remote manual valve 63-111. see same discussion under X-020A for valve 63-112.

> ott SI Pump Discharge to 55 63-547 (CV)

Hot Legs - Train B 63-157 (RM) 6.3.2-1 See SRP 6.2.4 Section II.b 63-549 (CV) and Closed for acceptability of out-63-167 (RM) System board remote manual valve.

For discussion of remote manual valve 63-167, see discussion under X-020A for valve 63-112.

'GDC 55, 56, 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve (Cv) Check Valve (RV) Relief Valve

Ttbl3 2.2 Pige 8 sf 24

• Design Carrelatss to 1 +

10CFR50 GDC on Other Defined Basis Penetration Inside Outside FSAR Puncitation Descriotion Classification' Barrierts) Barrierfs) finure Other Defined Basis Ref./ Notes a d22 BIT Charging Pump 55 63-581 (CV) 63-25 (RM) 6.3.2-1 See SRP 6.2.4 Section II.b Discharge 63-174 (RM) 63-26 (RM) for acceptability of out-63-697 (LC) board remote manual valves, and Closed For discussion of remote System - manual valve 63-174, see discussion under X-020A for valve 63-112. .

A 024 SI Relief Valve 56 68-559 (CV)62-505 (RV) 5.1-1

, Discharge Relief valves are See discussion 4 72-512 (RV) acceptable because in Attachment 1 72-513 (RV) containment prespure is of this63-511 (RV) acting opposite'the document for 63-536 (RV) direction that the valve further infor-I 63-535 (RV) relieves, thereby aiding nation on this63-534 (RV) the valve to seat. penetration.63-626 (RV)63-627 (RV) and Closed System I

' GOC 55, 56, 57 i

NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:-

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check Valve (RV) Relief Valve

T:bla 2.2 P2ge 9 Cf 24 Design Ctrroittas to 1

10CFR50 GDC on Other Defined B4111 Penetration Inside Outside FSAR Punctralian Descriotion Classification' Barrierts) Barrietts1 Einurn other Defined masts aer./ Notes a o25B dP Sensor 56 --- *

• The containment pressure sensors are located out-side of and as close as practical to the contain-ment. The lines and pressure sensors are missile protected and designed to safe shutdown event requirements. These sensors employ redundant bellows as isolapton barriers. D6 sign required to permit actuation of equipment necessary to mitigate the consequences of an accident, a alm Rx Vessel Level 55 * *

• The reactor vessel level indication system (RVLIS) is required postaccident for continual indication of the water level in the reactor vessel. The capillary sensing lines which transmit pressure from the reactor vessel to instruments in the Auxiliary Building are annored and designed to withstand DBE conditions.

Any containment isolation

' GOC 55, 56, 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manua) Valve (RM) Remote Manual valve (CV) Check Valve (RV) Relief va ' <i-se

Ttbla 2.2

• Page 10 af 24 Design Cirralttis to 10CFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR Ecncttat3go OcSCr1DLian Classification 1 Barrierfsi Barrierfs) Floure Other Defined Basis Ref./ Motes valves installed in the RVtIS capillary lines will jeopardize the performance of the system. For this reason, isolation of these capillary lines is accom-plished by a sealed sensor located inside containment and an isola $or Jocated outside containment. These devices utilize a type of bellows which transmits pressure while preventing mixing of the fluids on either side of the isola-tion devices. The captl-lary line is armored 3/16 inches 0.D. stainless steel tubing and is filled with demineralized water and sealed. A postulated shear of this capillary line on either side of the containment would not allow a leak to develop through the containment boundary. This design is i

described in FSAR 1

Section 6.2.4.3.

i

'(M)C 55. 56. 57 NOTE--Automatic power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check Valve (RV) Relief Valve

~,,

i

l Ttbl2 2.2 -

Pige'll af 24 Design Carrolttis to 1 "

_ 10CFR50 CSC on Other Defined Basis-Penetration Inside Outside FSAR PwctCittfgo Qescriotion Classificationi Barrierfs) Barrierfs) Finure Other Defined Basis Bef./ Notes

• utbA dP Sensor 56 --- * ,

"See X-0258 h ol6C R4 Vessel Level 55 *

• i "See X-025C

? '-

_ , ,o X 027A dP Sensor 56 --- *

"See'i-0258 m 0278 dP Sensor 56 --- *

"See X-0258

, a n270 Rx Vessel Level 55 * *

"See X-025C 4

a een Spare 56 --- --- ---

See X-008 e u31 Spare 56 --- ---

See X-008 J

t 1

1 i

'GDC 55, 50, 57 rdOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

, (LC) Locked Closed Manual Valve

.j (RM) Remote Manual Valve (CV) Check Valve (RV) Relief Valve 1

I E

i

Tchie 2.2

• P;ee 12 af 24 Design Carrs1ct:s ts 1 <

10CFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR Penetratico DestrjnLira Classification' Barrier (si sarrierts) Fleure Other Defined Basis Ref./ Notes X-03? SI Pump Discharge 55 63-545 (CV)63-156 (RM) 6.3.2-1 to Hot Legs - Train A 63-543 (CV) and Closed See SRP 6.2.4 Section II.h 63-21 (RM) System for acceptability of out-board remote manual valve.

For discussion of remote manual valve,63-21, see discussion'under X-020A for valve 63-112.

s 033 SI Pump Discharge 55 63-553 (CV) 63-22 (RM) 6.3.2-1 See SRP 6.2.4 Section II,b 63-555 (CV) and Closed for acceptability of out-63-551 (CV) System 63-557 (CV) board remote manual valve.63-121 (RM) For discussion of remote senual valve 63-121, see discussion under X-020A for valve 63-112.

x 03S CCS from Excess 57 Closed 70-85 9.2.1-2 Ltdn. HX System See X-053 X 036 Spare 56 ---

See X-008

'CDC 55. 56, 57 tDTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(tC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check Valve (RV) Relief Valve

Tabla 2.2 Pase 13 af 24 e-Design Cgrr31stras 10 -

I ,

10CFR50 GDC on Other Defined Basis Penetration Inside Outside FSAR Penetration Ogsstiption Classification' Barrierfs) Barrierft1 Floure other Defined Basis Ref./untes e 437 Spare 56 --- --- ---

See X-008

. usn Spare 56 --- --- ---

See X'-008 x 039L Spare 56 --- ---

See X-008 a 0390 Spare 56 --- --- ---

See X-008

> u40C Spare 56 --- --- ---

See X-008 s 0400 H: Purge Supply 56 ---

Blind ---

See X-003 See discussion Flange of this pene-tration in Attachment 1 of this document.

6.DC 55, 50, 57 hof E--Autanatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check Valve (RV) Relief Valve a

de

Tabl2 2.2 e Pree 14 Cf 24 Design Ctrr21ttcs to 10CFRs0 GDC on Other Defined Basis Penetration Inside Outside FSAR EcutLCAliQD' Q11ErlDL100 Classificationi Barrierfs) Barrierfs) Fiaure Other Defined Basis Ref./untes

~

a-041A To RCP Seals 55 62-563 (CV)62-546 9.3.4-1 62-549 Local manual *valkes Furt ** discus-62-550 62-546 and 62-549 are stor .garding normally closed valves. is. tion and and Closed Valve 62-550 can be System meeting the GDC isolated when the need on other defined to isolate is deter- basis is mined, provided in Attachment 1 of this document.

= u43B To RCP Seals 55 62-561 (CV) See X-043A 9.3.4-1 See X-043A a

sa P. To RCP Seals 55 62-562 (CV) See X-043A 9.3.4-1 See X-043A a 043L To RCP Seals 55 62-560 (CV) See X-043A 9.3.4-1 See X-043A

'CDC 55. 56. 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual valve (RM) Remote Manua' valve

, (CV) Cneck valve ,

j (RV) Relief Va've i

g

TIbl3 2.2 .-

P;ge 15 ef 24 Design Carroltt;s to 1 ,

10CFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR PencLEAtiQn 025CE19L100 Classification' Barrierf s t Barrierfs) Fiaure Other Defined Basis Ref./ Notes

> 048A Containment Spray 56 72-547 (CV) 72-39 (RM) 6.2.2-2 and Closed See SRP 6.2.4 Section for acceptability of II.b See further System discussion of remote manual valve this penetration outside containment, in Attachment 1 of this document.

4 u4a3 Containment Spray 56 72-548 (CV) 72-2 (RM) 6.2.2-2 See X-048A and Closed See X-048A System a 449* RHR Spray 56 72-556 (CV) 72-40 (RM) 6.2.2-2 See X-048A See X-048A and Closed System a 0498 RHR Spray 56 72-555 (CV) 72-41 (RM) 6.2.2-2 See X-048A and Closed See X-048A System

'GDC 55, 56. 57 h0TE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve . , ,

(PM) Remote Manual Valve (Cv) Check Valve (RV) Reitef Valve e

. = - - .- . . . . . - .- . - _ . ~ . .-__

Tib13 2.2

• p!se 16 ef 24 Design Carr31st;s to 1 ,

10CFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR Proctration , p, QtstcIntina Classification 1 Barrierfs) Barrierfs) Fiaure

.r Other' Defined Basis Ref./ Notes 4 '.

• CCS to Excess 57 Closed 70-143 Ltdn. HX System 9.2.1-2 This penetration directly meets GDC 57 except there is a relief valve.70-703 ,

on the closed system inside containment. The relief valve is acceptable because containment pressure is acting opposite the direction that the valve relieves thereby aiding the valve to seat.

Penetrations X-053 and X-035 are part of the same loop.

954 Thimble Renewal 56 ---

Blind 6.2.4-15 See X-003 Bitnd flange Flange is never re-moved except in i Mode 5 or 6.

. uS5 Spare 56 --- --- ---

See X-008

'GDC 55. 56, 57 ..

' F40TE--Autanatic Power Operated Valve unless otherwise indicated as follows:

i (LC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check valve (RV) Relief Valve r.

1 T

Tible 2.2 - *~

Paea 17 (f 24 Design CarralEtis ta 1 <-

10CFR50 CDC on Other Defined Basis Penetration

, g. J //

Inside Outside FSAR *"

Es:tdr_Alino Descriotion Classification' aarrierfs) Barrierfs) Finure Other Defined Basis Raf./ Notes a 0/9A Ice Blowing 56 Blind 6.2.4-16 See X-003 See X-oS4 Flange A 079B Negative Return 56 ---

Blind 6.2.4-16 See X-003 Flange See X-054 t u848 Spare 56 --- --- ---

See X-008 e un4 Spare 56 --- --- ---

See X-008

= 084D Spare 56 --- --- ---

See X-008 s 0858 dP Sensor 56 --- *

"See X-0258 x os5C Spare 56 --- --- ---

See X-oo8

'CDC 55, 56, 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual valve (RM) Remote Manual Valve (CV) Check valve (RV) Relief Va'<e 9*

es

Ttbla 2.2 Pape la er 24

• Design Ctrroittcs to 1 ,

, *sp 1DCFRs0 GDC on Other Defined Basis ,

ef

Penetration Inside Outside FSAR PE!!vtratigo QgittiDtion Classification 1 Barrierfs) Barrierfs) Fieure Other Defined Rasis Ref./ mates

' d .0 Spare 56 --- --- ---

See X-008

. h.soA Rm Vessel Level 55 * *

"See X-025C a wa68 Rn Vessel Level 55 * *

• See X-025C unoC R= Vessel Level 55 * *

"See X-025C

• udou Spare 56 --- --- ---

See X-002 e un sa Spare 56 --- --- ---

See X-008

. Ju7C Spare 56 --- --- ---

See X-008 e

'GCC 55, 56, 57 NOTE--Autanatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check valve (RV) Relief Valve ,,

Tchl2 2.2 Page 19 sf 24

r , ?f Desi;n C;rrolat;s to ,

1 *

• 1DCFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR PupstrlLIDD Descriotino Classification' Barrierfst Barrier (s) Fiaure other Defined Basis Ref./ Notes e can Shutdown Maint. 56 Access Blind ---

See X-003 Flange See X-054 e un9 Spare 56 --- --- ---

See X-008 a 49?A Hj Analy2er 56 43-207 (Auto Closed ---

Closed system outside open on pump System containment provides start) outer barrier. This line is required postaccident for H2 monitoring.

Penetrations X-092A and X-092B are part of the same closed loop. Valves43-207 and 43-208 are both located inside containment.

H2 Analyzers discussed in Supplement 2 to SQN's SER.

, u928 H2 Analyzer 56 43-208 (Auto Closed ---

See X-092A open on pump System start)

X-096A Spare 56 --- --- ---

See X-008

'CDC 55. 56. 57 .

NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(tC) tocked Closed Manual valve (RM) Remote Manua' valve (CV) Check va'.e .

(RV) Relief valve

Tcb12 2.2 ,-

d '

Pase 20 cf 24 -'

Design CarrGir.tts to 1 ,

loCFR50 CDC on Other Defined Basis Penetration Inside Outside FSAR Pc!!CLEAllQa Descripti20 Classification' Barrierfs) Barrierfs) Fiaure Other Defined Basis Ref./ Motes.

s 0968 Spare 56 --- --- ---

See X-008 X 099 Hg Analyzer 56 43-202 (Auto Closed ---

Closed system outside open on pump System containment provides outer start) barrier. This line is required postaccident for H2 monitoring. Penetra-tions X-099 and X-100 are part of the same closed system. Valves43-202 and 43-201 are both located inside containment.

. 100 H Analyzer 56 43-201 (Auto Closed ---

See X-099 open on pump System start) s 105 Spare 56 --- --- ---

See X-008

'GDC 55. 56, 57 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

ItC) tocked Closed Manual Valve (RM) Remote Manual Valve (CV) Check Valve

( RV ) Relief Valve

Ttbla 2.2 Page 21 Ef 24

• Design Cirr31stis to 1

• 10CFR50 GDC on Other Defined Basis Penetration Inside Outside FSAR Puestralian QcitIlatlQg Classificationi Barrierf s) Barrierfs) Fiaure other Defined Basjs Ref./ Notes 607 RMR Supply 55 74-2 (RM) Closed 5.5.7-1 Closed system outside 74-505 (RV) System containment provides outer barrier. Valve 74-1 is available in series with containment isolation valve 74-2 and both are normally closed with interlocks to prevent inadvertent opening.

The relief valve is acceptable because containment pressure is acting opposite the direction that the valve relieves, thereby aiding the valve to seat.

> 10a UNI 55 87-562 (CV) 87-10 (RM) 6.3.2-15 See SRP 6.2.4 Section II.b 87-11 (RM) for acceptability of remote 87-21 (RM) manual valve outside contain-and Closed ment.

System a 80* UNI 55 87-563 (CV) 87-10 (RM) 6.3.2-15 See X-108, 87-11 (RM) 87-23 (RM) and Closed System 3

CDC 55. 56. 57 .'.

NOTE--Automatte Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Eemote Manual Valve (CV) Check Valve 4RV) Reine' Valve

Tchio 2.2

• PJee 22 sf 24 Design Carr31ates to 1

• loCFR50 GDC on Other Defined Basis Penetration Inside Outside FSAR PsnsttaLino Descriotion Classification 8 Barrierfs) Barrierfs) Fleure Other Defined Basis

! Ref./ Motes _

m III Vacuum Relief 56 30-46 9.4.7-1 The containment vacuum See Attachment 30-571 (CV) and relief system isolation 1 of this 6.2.4-17 valve is located in document for series with a vacuum futher discus-reiter (check) valve sion, botta outside of con-tainment. The closing of the isolation valves are.

actuated by a set of redun-dant pressure sensors independent of those for other containment isolation valves. The closing is powered by redundant air i supplies. The spring-loaded vacuum relief valves are normally closed and have 2 position indicators in the

} Main Control Room to indi-cate the open or closed positions, These valves are not considered as simple check valves, fa 682 Vacuum Relief 56 ---

30-47 9.4.7-1 See X-111 30-572 (CV) and 6.2.4-17 l x-113 Vacuum Relief 56 ---

30-48 9.4.7-1 See X-111 l ...30-573 (CV) and 6.2.4-17 i 'CDC 55, 56. 57 NOTE--Automatic Power Operated valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve (RM) Remote Manual Valve (CV) Check valve (RV) Relief Valve i

1 g

._ _ . . _ __ _ _ _ . _ _ _ _ . . _ . . _ . . - _ . - . _ _ _ . . . . _ . . _ . - . , _ . . _ . . _ . . . . _ _ . , . . - . . . . . - . _ ___m.. . . . - . . ..

, Tchla 2.2 Page 23 af 24 '2 3

Design Carralttis to i I )

1 1DCFR50 GDC on Other Defined Basis 1

4 J

s Penetration Inside Dutside FSAR t PenettaLinn Descrintion classificatinni Barrierts) Barrier (s) 1 Fiaure other Defined Rasis Ref./ mates l

l Iles Spare 56 ---

See X-008 '

d 1 a libC Spare 56 --- ---

1 i

See X-008

s 1160 Spare 56 --- --- ---

See X-008 I

1 a its Shutcown Maint 56 Access Blind ---

See X-003 Flange See X-054

> t

. *< Layup Water 56 j

Treatment Blind ---

See X-003 See X-054 Flange s,

j l

i' Spare 56 --- --- ---

See X-008 i

i l

ia 120 Spare 56 ---

t ---

I See X-008 l <

j . l i

i .

j l

] 'CDC 55, 56, 57 i1 NOTE--Automatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual valve l (RM) Remote Manua' Valve

{ (CV) Check Va'<e

(RV) Relief Va'se 1

l .

t l

t 1

1 4

. . _ . . . . . . . - . . . - .. . - ... . . . . . - . - - . . . .~

Ttbla 2.2 Page 24 6f 24

• 1 Design C;rr31stes tg 1

• 10CFR50 GDC on Dther Defined Basis i

Penetration Inside Outside FSAR

• Psistration Descrintion classification . marrierts) 5 i

narrier(s) Fleure other Defined Basis Ref./ Notes a 4 *1t e c Liectrical 56 Epoxy Epoxy l > 8 7ut Penetrations Seal Standard dual passive

' Seal epoxy barrier electrical penetration assembly

, design - pressurized j between the seals with N-2 -

4

. *tSE Spare 56 --- --- ---

See X-008

* *1or Spare 56 --- ---

l See X-008 s .st Spare 56 --- ---

1 See X-008 ,

i -

.e Spare 56 --- ---

t See X-008 4

i 1'

'GDC 55. 56. 57 ji F40TE--Autanatic Power Operated Valve unless otherwise indicated as follows:

(LC) Locked Closed Manual Valve I (RM. Remote Manual Valve (CV) Check Valve 1

i (RV) Re16ef Valve l

i i

f v

a ENCLOSURE 2 COMMITMENTS MADE REGARDING CONTAINMENT ISOLATION CAPABILITY

1. TVA will revise the FSAR in the next annual update to reflect resolution of the containment isolation system questions.

2. TVA will test the RHR spray valves by the methods described in FSAR section 6.2.4.2.1.

3. TVA will request an exemption to 10 CFR 50, Appendix J leak test requirements for penetrations X-20A, X-20B, X-24, K-108 and X-109.

4. TVA will request an exemption to 10 CFR 50 for penetrations X-43A, X-43B, X-43C and X-43D.

5. TVA will install position indication in the MCR for all containment isolation valves that do not currently have it by the unit 2 cycle 4 refueling outage, in accordance with the requirements and schedule of Regulatory Cuide 1.97.

i i

I

!