ML20212J543
| ML20212J543 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/04/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Harold Denton, Tam P Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-7-036, 2NRC-7-36, TAC-62897, NUDOCS 8703090047 | |
| Download: ML20212J543 (8) | |
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2NRC-7-036 Beaver Valley No. 2 Unit Project Organization Telecopy (4 21643 2 Ext.160 S.E.G. Building P.O. Box 328 March 4, 1987 Shippingport, PA 15077 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. Peter Tam, Project Manager Division of PWR Licensing - A Office of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 NRC/NRR Enviromiental Qualification Audit held November 18-20, 1986 OLC Response to NRC Audit Comments Gentlemen:
As the result of the NRC/NRR Environmental Qualification Audit of BVPS-2, three (3) specific and one (1) generic comment were to be addressed by Ouquesne Light Company.
The attachment to this letter provides six (6) copies of the DLC response to these items indicating the action taken to date. This infonnation indicates that action has been completed to address the three (3) specific comments and that actions are underway to address the generic comment prior to BVPS-2 fuel load.
The NRR is requested to review the attached information in preparation of the final EQ SER for BVPS-2.
DLC intends to submit a final letter when the BVPS-2 EQ program equipment is completely qualified in support of the existing fuel load schedule.
If there are any questions regarding this matter, please contact Mr. E. T. Eilmann at 412/393-7895.
DUQUESNEtjGHTCOMPANY By A
Sr./JUJ. Caregl( Vice PresMent KEW/ bib MCE/KEW/50412 AR/NAR Attachment cc: Mr. P. Tam, Project Manager
- w/o/ attachment Mr. J. Beall, NRC Sr. Resident Inspector - w/ attachment INP0 Records Center
- w/o/ attachment NRC Docunent Control Desk
- w/o/ attachment 8703090047 870304 ho PDR ADOCK 05000412 II A
PDR D
United Stat:s Nuclear R:gulatory Commission
- Mr. Harold R. Denton, Director DLC Response to NRC Audit Comments Page 2 COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF-BEAVER
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, before me, a Notary Public in and for said Commonwealth and County, personally appeared J. J. Carey, who being duly sworn, deposed and said that (1) he is Senior
-Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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ATTACHMENT DLC Response to NRC/NRR Comments on BVPS-2 Environmental Qualification Audit NRC Specific Comnent:
Barton Pressure Transmitter, File No. 001/ESE-01A Cable to transmitter is not qualified for superheat.
However, alternate indication will be used for the superheat event. Applicant committed to update the R.G.1.97 submittal to reflect thir, condition.
DLC Response:
The revision, Attachment A, to BVPS-2 FSAR Table 7.5-1 (Amendment 15 March 1987) describes the Reg. Guide 1.97 update which identifies the alternate indication and engineering justification for its use during superheat conditions. The mainsteam pressure transmitter and cable runs remain qualified for all other postulated events in the MSVH.
NRC Specific Comnent:
ASCO Solenoid Valve File No. 001/HE-02/5 Maintenance procedure does not include a replacement schedule for gaskets and seals. While this is not a reconmendation by the Westinghouse test report, the applicant agreed to incorporate an inspection schedule that will determine if a replacement schedule should be developed. The applicant suggested that it may also be appropriate to adapt the Unit 1 maintenance procedures to the Unit 2 ASCO solenoid valves. The staff finds this approach acceptable.
OLC Response:
The Maintenance Assessment Package (MAP Engineering Review of Requirenents for Maintenance of Environmental Qualification) for BVPS-2 ASCO Solenoid Valves is presently in the final review phase.
This assessment has incorporated several aspects from the corresponding BVPS-1 assessment including a reduction in qualified life for 40 to 20 years and the incorporation of scheduled surveillance at 18-month interv als.
This represents a solid, conservative approach to maintain environmental qualification on BVPS-2 ASCO Solenoid Valves including gasket and seal materials.
NRC Specific Comment:
Borg Warner Valve Actuator, File No. 2BV-92 This file did not adequately address the specified spray requirenent.
OLC Response:
This spray requirenent for the feedwater isolation valves has been elimi-nated through engineering analysis and plant survey as detailed in Attachment B.
The EQ package is being updated to reflect this change and, therefore, adequately documents the environmental qualification of the feedwater isolation.
valves for their BVPS-2 application.
(Also see DLC response to the following generic comment.)
NRC Generic Comment:
As a result of the audit, it was discovered that qualification of equip-ment for submergence inside containment and qualification of equipment for spray and submergence outside containment was not always clearly demonstrated (e.g., files 2BV-24, 2BV-92, 001/ESE-42A, 2BV-312 and 2BV-635.
Therefore, the entire program should be reviewed to identify all instances where qualification for submergence and spray is required, and all files should be updated as necessary to clearly denonstrate qualification for submergence and spray.
DLC Response:
Regarding ~ spray qualification for BVPS-2 equipment located outside con-tainment, the NRC has not accepted the BVPS-2 argument that testing at 100%
htmidity at elevated tenperature/ pressure is an acceptable water spray qualifi-cation method.
The NRC position is that spray of sufficient quantity must be denonstrated to have been directed on the equipment item during test. OLC nas, therefore, reviewed each applicable EQ package to determine the spray qualifi-cation methodology enployed. This review has resulted in the identification of several EQ packages for BVPS-2 equipment located outside containment in which OLC had taken credit for spray qualification by other then direct water spray test. Each of these EQ packages is being reviewed to assess the most efficient and cost-beneficial means to adequately denonstrate qualification to BVPS-2 requirements in regards to the NRC position. The BVPS-2 Environnental Qualifi-cation program has used an area worst case approach for the establishment of environmental conditions (including spray).
The elimination / reduction of these conditions has been a viable option when equipment cannot be shown to meet the worst case.
All such cases have been adequately documented within the respev.ive EQ packages and/or project environmental conditions document 2BVM-119.
This option will be utilized by DLL where applicable to eliminate water spray requirenents outside containment.
Where this is not possible, OLC will provide justification through additional vendor information/ engineering evaluation. Each affected EQ package will be anended to include this revision /
justification.
Regarding submergence of EQ progran equipment, OLC has conducted a similar review of EQ packages and is taking action to provide additional justi-fication/ clarification within affected rackages to assure adequate qualification for applicable submergence conditions.
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- Smi, Confo-an:e C ;ressure C4) 0-3,0C0 psig A1, 31, C; 12 Yes Yes
- par plant 2 uters hel.3*4 1E Yes C, 02 1 chaar.el a plasma dir; lay 1 recorder 31 ha: ('a; 0-700*F M, 32 Yes Yes 1 per loop 3 =e:ers bei had IE Yes 3 recorders C T.14 ('4) 0-700*7 M, 32 Yes Yes 1 per loop 3 meters fcel laed 1E Yes c
3 recorders steam generator 0-100% of spaa M, 31, 32, 22 Yes Yes 1 per steam 3 meters complete IE Yes level (n) generator 3 recorders steam generator 0-10C2 of spaa M, 31, 32 Yes Yes 3 per steaa 9 meters fuel load IE Yes 1*'*1 CA) generator 3 racerders y
-4 Pressuriser level 0-10C: of spaa M, 31, C2 Yes Yes 3 per plant 3 meters complete 1E Tes y
3 recorders n
Centainment pressure
-5 ta $5 psig M, 31, 32. C2, Yes Yes 4 per plant 4 meters complete IE Yes
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32 2 recorders Q
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5:eas11ae pressure O ta 1,2:X3 M, 31, 22 Yes(14)
Yes 3 per loop 9 meters complete IE Yes pstg 3 recorders D
Caetainment water 0-225 in M, 31, 32. C.
Yes Yes 2 per plant 2 meters complete EE Yes le**1 P4) 32 1 recorder Caet ai% water 0-12 La M, 31, 32, C2, Yes Yes 2 per plant 2 meters fuel load IE Yes level (LE) 02 1 recorder Refuel 1=g wster 0-700 La D2 Yes Yes 2 per plant 2 meters complete IE Yes eterage tar.a level I recorder l
Amendment 13 1 of 11 March 1987 BMI-12241-5 8 U
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4 BVPS-2 FSAR I
Page 2 of 2 ATTACHMENT A NOTES 70* TABLE 7.5-1 (Cont) s temperature can be inferred from containment pressure.
Containment spray system valve status and containment spray flow indications are used to demonstrate that the Emergency Core Cooling System is operating properly when taking suction from the containment sump.
12.
Note that although these valves are classified as Category 2, the associated instrumentation meets the qualification requirements for Category 1 instrumentation as discussed in FSAR Section 7.5.2.1.3.1, with the exception of 2CHS*FCV160 and 2CHS*HCV142 (See Table 6.2-60).
These valves are closed during normal plant operation and post-accident conditions, and are powered from non-Class 1E sources.
A 13.
Under Implementation Date,
" complete" means that this instrumentation already exists in the current design.
All instrumentation will be installed by fuel load unless otherwise noted.
14.
The main steam pressure transmitters are environmentally qualified for all events with the exception of the arbitrary 1.0 ft2 MSLB in the main steam valve house imposed by NRC-BTP-ASB 3-1.
The resultant environment produced by the 1.0 ft2 break exceeds the qualified temperature of the transmitters' instrument cable. Failure of the cable has no adverse effect on RPS or SLI signal generation as the cables perform these functions prior to exceeding their qualified temperature.
For the purposes of monitoring heat removal during plant cooldown following this specific event alternative Class 1E-powered instrumentation is available in the form of steam generator level, auxiliary feedwater flow, ai.d RCS temperature.
These variables provide sufficient indication that the steam generators have been isolated, that level is being maintained, and that primary system heat removal is in progress.
HR = Wide range.
NR = Narrow range.
- = Range / Status information for radiation monitors is not firial.
- = Sufficient to monitor anticipated rates (refer to Section 12.5.2.2.3).
Amendment 15 11 of 11 March 1987 fp
I, ATTACHMENT B A compilation of all potential water spray sources is available from a review of the RP-116 drawing series for the main stean valve area (MSVA) eleva-tion 773'-6", for the BVPS-2 feedwater isolation valves.
The fluid systen piping within this area is tabulated as follows:
1.
Steam Generator Blowdown (BDG) 2.
Component Cooling Water (CCP) 3.
Valve Steam Leakoff (DGV) 4.
Feedwater(FWS) 5.
Gaseous Nitrogen (GNS) 6.
Leakage Monitoring (LMS) 7.
Main Steam (MSS) 8.
Steam Drains (SDS) 9.
SteamVents(SVS) 10.
- 11. Demineralized Water (WTD)
All high energy piping (as defined by Appendix B BTP-ASB 3-1, Section 1) within this area is designated to the break exclusion requirenents of BTP-MEB 3-1 attached to SRP 3.6.2 as implenented by Project Procedure, 2BVM-85,
" Criteria for Postulating Pipe Breaks and Cracks and Analyzing the Dynanic and Environmental Effects Inside and Outside Containment", Sections 2.3, " Break /
Crack Postulation" and 3.1,
" Postulation of Breaks in High Energy Lines",
except as indicated in Iten B below.
Based on the proceeding criteria and the tabulation of high energy piping systens outside containment as provided by FSAR Table 3.68-1, items 1 through 9 of the preceeding tabulation are eliminated from consideration as spray sources.
The only high energy line break which need be postulated in this area is a non-mechanistic 1.0 square foot main strean line crack.
In accordance with the requirenents of ASB 3-1, this crack is abitrarily postulated for the evalu-ation of the consequential temperature and pressure affects for equipment environmental qualification purposes only.
Based on the above spray wetting for high energy sources is precluded for the MSVH Elevation 773'-6" area.
Moderate energy piping in the MSVH elevation 773'-6" is limited to Items 10 and 11 of the piping tabulation.
Specifically four (4) 4-inch noninal pipe size (NPS)
Service Water System (SWS) lines and one (1) 2-inch NPS Demineralized Water Systen (WTD) line.
A visual inspection of the routing of
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.I ATTACHMENT B
'these lines tias been performed in accor' dance with the evaluation requirements of SRP 3.6.1,Section III.1 and to identify targeted spray-sensitive, safety-related components and to -establish the area of influence of the wetting-effects associated with the postulated piping cracks.
The results of this inspection indicate that by virtue of the. plant arrangement and in accordance with ASB 3-1, Part B.1, the subject service water and demineralized water piping is remotely located relative to the safety-related equipment question.
Specifically, the fluid piping is separated from the FWS valves by a minimum of 20 feet in both the vertical and horizontal directions.
Additionally, water from the postulated cracks will be directed away from the FWS valves by other intervening structures as 'shown on plant arrangement draaings RM-2A, Piping Drawings RP-178,19G and 99E, and Building Ventilation Drawing RB-160.