ML20215N242

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Forwards Responses to Sqrt & Pump & Valve Operability Review Team 860930-1003 Audit Issues
ML20215N242
Person / Time
Site: Beaver Valley
Issue date: 10/27/1986
From: Carey J
DUQUESNE LIGHT CO.
To: Harold Denton, Tam P
Office of Nuclear Reactor Regulation
References
2NRC-6-113, TAC-62895, TAC-62896, NUDOCS 8611050090
Download: ML20215N242 (18)


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g 2NRC-6-113 Beaver Valley No. 2 Unit Project Organization Telecopy ( 12) 643- Ext.160 S.E.G. Building P.o. Box 328 Oct. 27, 1986 Shippingport, PA 15077 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Comission 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 BVPS-2 Seismic Qualification Review Team and Pump and Valve Operability Review Team Audit (SQRT/PV0RT)

Gentlemen:

The Beaver Valley Power Station Unit 2 SQRT and PVORT Audits were held from September 30 through October 3,1986. At the final exit meeting held on October 3,1986 the NRC SQRT and PV0RT tean leaders presented several issues that required DLC responses.

Please find enclosed one (1) copy of Duquesne Light Company's responses to these issues.

If you should have any questions, please contact E. T. Eilmann at (412) 393-7895.

DUQUESNE LIGHT COMPANY

~ By W s J. J. Carey Sr. Vice President 8611050090 86102 @k th\

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4 United States Nuclear Regulatory Commission Mr. ' Harold R. Denton, Director .

BVPS-2 Seismic Qualification Review Team. . . . Pump and Valve Operability (SQRT/PVORT)

Page 2 l

'TJZ/ijr NR/SQRT/PVORT Attachments AR/NAR l cc: G. Bagchi, NRC - w/ attachment S. Hoe, NRC - w/ attachment l A.'Masciontonio, NRC - w/ attachment  :

J. Singh (EG&G) - w/ attachment  !

C. Kido (EG&G) - w/ attachment l J. Beall (NRC Resident Inspector) - w/ attachment L. Prividy (NRC Resident Inspector) - w/ attachment NRC Document Control Desk - - w/o/ attachment INPO Records Center - w/ attachment i

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L SQRT Iss'ue 1: Nozzle Load Stress Reconciliation Program Provide schedule for completion and notification of results of the

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Nozzle Load Stress Reconciliation Progran.

Response

A stress reconciliation progran is presently in effect on BVPS-2. The Progran calls for Engineering completion of all piping calcul ations including resolution of nozzle loads on equipment by Decenber 31, 1986.-

Completion of hardware modifications is scheduled through the first quarter 1987 in parallel with ASME N-5 form completion and in support of an April 30,1987 fuel load . The results of the Nozzle Load Recon-cilation Progran will be made available to the NRC upon its completion.

Status:

Confirmatory l

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SQRT Issue 2: Seismic Interaction Walkdown Provide the schedule for completion and notification of results of the Seismic Interaction Walkdown.

Response

The " Engineering and Quality Control Survey of Component Spacing and Clearances by Area" as outlined in Beaver Valley Project Manual Procedure 2BVM 236 was initiated on September 29, 1986 with an estimated -

completion on November 13, 1986. The results of the above survey will be made available to the NRC upon its completion.

Status:

Confirmatory i

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SQRT-Issue 3: Alternate Shutdown Panel (PNL*ALTSHTDN) Qualification Analysis

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Provide verification of the vendor qualification analysis, by in-situ testing, of the Alternate Shutdown Panel (PNL*ALTSHTDN). . Also provide a schedule and the results of the testing.

Response

~In-situ impedence testing will be performed on the Alternate Shutdown Panel in October 1986. The measured mode shapes and frequencies will be

- compared to those computed by the vendor. The results will be utilized to verify the vendors analytical model for computing natural frequencies and for evaluating effects on Class 1E device qualification. The re-

, sults will be incorporated in the equipment qualification documentation

and will be made available to the NRC upon its completion.

Status:

Confirmatory i

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SQRT. Issue 4: Residual Heat Removal Heat Exchang r (2RHS*E21A)

Provide justification for use of the Bijlaard Technique for the . a) shell side' nozzles, b) lower supports and c) verification of the lower support welds.

Response

a) The discontinuity stresses developed at the shell flange, shell to head junction, and any other discontinuity in the vessel shell. are secondary stresses. The basic characteristic of the secondary stresses is that they are self limiting. Secondary stresses can produce local yielding or minor distortion resulting in a stress distribution in the structure which does not have the potential of causing gross collapse. The loads causing the secondary stresses in the case under consideration are self-limiting or limited by the boundary restraints. These stresses are important when a slightest structural defonnation cannot be tolerated as it might interfere in the operation of the equipment. A typical example would be any equipment containing rotating parts. The other area of concern would be when the structure is subjected to repetative loading such that the high local stresses can seriously limit its fatigue life.

Neither of these conditions exists with the shellside of the RHR heat exchanger.

The Bijlaard technique calculates pr.imary as well as secondary stresses.

The secondary stresses from discontinuity effects would increase the-total sum of these secondary stresses. However, as mentioned previously l

these stresses produced by these loads are self-limiting in nature and they are not expected to cause a gross collapse or failure.

b) This response relates to the use of the Bijlaard technique for the attachment which is really not a closed rectangle, square, or circle.

Also 'a concern was expressed.for the distance between the gussets of .the support and their ability to carry the load symetrically due to l flexibility of the support, l Analysis of the gusset demonstrates the stress level is sufficiently low to prevent buckling failure. The base plate is very rigid by having one.

edge welded to the shell, stiffened by gussets, and anchored at four locations. The support has been requalified for the nozzle loads which exceed the . design level. This analysis represents the support by a retangul ar attachment approximately one third in size of the actual dimensions of the support, and results indicate stresses well within the code limits.

The. question of stress concentration or discontinuity stresses at the corners of the gussets or the base plates are resolved in the response

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(a) to the Bijlaard techniques for the shell side nozzles.

c) The lower support is manuf actured with a single full penetration (45*

bevel) weld. A 1/4" fillet weld is provided on both sides of the gusset pl ates. A 3/8" fillet weld is provided on both the top and bottom sides of the base plate. The calculated total throat thickness at these welds exceeds the thickness of the plates they join. Since the plates are qualified and shown to be stressed within the allowables, the weld is also qualified.

Status:

Confirmatory, based on this submittal

PVORT Issue 1: Preservice Tests

'The applicant shall confirm that all pre-service tests for safety related . peps and valves that are required before fuel load have been completed. The applicant shall also provide a list of all preservice tests to be completed the schedule for .these tests, and the justification for any tests scheduled beyond fuel loads.

Response

The Initial Test Program for BVPS-2 is described in FSAR Section 14.2.

The Pre-operational Test Phase (FSAR Section 14.2.1.2) includes the tests required to demonstrate that structures, systems, and components perform satisf actorily and that they ~ are ready to support fuel . loading-and Initial Start-up Testing Phase. In-general, it is expected that the majority of pre-operational testing will be completed before fuel load-

< ing. However, in some cases it may be necessary to defer certain Pre-operational Testing until after fuel loading . In such cases, sufficient testing will be perfomed prior to fuel loading to ' provide reasonable assurance that the post-loading tests will be successful.

The schedule for the Initial Test Program for system operability l verification, pre-operational testing phase, and initial start-up test l

phase is shown on FSAR Figure 14.2-3. The schedule depicts _ certain milestones, at which time each test or portions of .the test will be completed. . The detailed schedules for testing will be prepared, reviewed and revised on' a continuing basis as pl ant construction progresses.

All appropriate pre-service tests will be completed prior to fuel load.

Status:

Confirmatory; based on this submittal

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PV0RT Issue 2: Installation Verificatio.n The applicant shall confirm that all safety related peps and valves are properly . qualified and installed prior to fuel load. In addition, the

- appl icant shall provide written confirmation that the . original loads used in tests or analyses to qualify safety-related peps and valves are not exceeded by any new loads, such as those imposed by a LOCA.

(hydrodynanic loads) or as-built conditions.

Response

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All safety related equipment will be qualified and properly installed prior to fuel load. Any equipment that cannot be qualified by fuel load e will be identified to the NRC as soon as it is identified by DLC. In addition, if any new loads are imposed that exceed those loads used in the ~ tests or analysis to qualify the safety related peps and valves, the NRC will be notified.

Status:

Confirmatory; based on this submittal w, [,

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/ Similarity analysis has not been included in the documentation which ~

/ addresses acceptabilty of the analysis (2CHS*MOV8130A, 2IAC*MOV130).

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9 7 k:  %' conplete review of all equipment qualification packages was g.-formed s'.? .c < daririj; the package assembly phase of the progran. Simil arit, ev al u-C ..I ations will be re-verified in conjunction with the finalization and .l

, turnover of the equipment qualification packages to ~0LC (2CHS*MOV8130A).

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~/ F.or motors operated valve 2IAC*MOV130, the vendors operability test e e' report Mas a prototype test encompassing all valves purchased under the

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subject / purchase order (2BVS-091). Stone and Webster review of the

. submitted report included a review of the applicabilty of the -prototype

' testing to all valves affected. This evaluation has been confinned with

, the vendor (via letter) and the equipment qualification package will be 3,

updsted in accordance with the aforementioned package finalization

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I PVORT Issue 4:' Equipm:nt Qualification Documentation

--2 Reevaluate documentation retrie','al system in order to improve its effectiveness.

Response

The equipment qualificatio'n documentation packages will be evaluated to improve the documentation retrieval system in conj unction with the finalization and turnover of the packages to DLC. Any improvements will be incorporated into the Final Equipnent Qualification Documentation  :

Package and will be completed prior to fuel load. i Status:

Confirmatory; based on this submittal e

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4 PV0RT Issue 5: Check valves on FSAR Drawings s The FSAR drawings do not identify check valves.

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Response

The FSAR- is a licensing document, and as such, all equipment items are s not required to be listed. Check valves .are identified on design and

'I operation drawings as required.

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1-Closed i

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PVORT Issue'6: FSAR listing 'of balance-of-plant-(B0P) active pumps and.

v alves.

The FSAR does not . list (Table) all balance-of-plant (B0P) active pumps and valves.

Response

All balance-of-plant (B0P) active pumps and valves will be listed in the FSAR in Anendment 13, scheduled for January,1987.

Status:

Confirmatory i

PV0RT Issue 7: Fuel Pool Cooling Pump (2FNC*P21A)

Notify the -NRC when the Fuel Pool Cooling Pump has been tested and meets its design criteria.

Response

The NRC will be notified when the Fuel Pool Cooling Pump (2FNC*P21A) has

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been tested and accepted for operation.

Status:

Confirmatory I

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. - PVORT Issue 8: Main Steam _Isolat' ion Valves (2 MSS'*HYV101 A, B, C) .

Notify the NRC when all problems associated with the Main . Steam' Isolation Valves (MISV) are corrected .and the . valves are fully qualified and . ready for service.

Response

DLC will' be utilizing the existing MSIVs. The NRC will be notified when .

all problems associated with the Main Steam Isolation Valves (2 MSS *HYV101A, B, C) have been corrected, fully qualified and ready for operation.

Status:-

Confirmatory; based on this submittal e

PVORT Issue 9: Terry Turbine (2FWE*P22)

The NRC is to be notified by DLC of any deviations from the vendor's recommended-5 year maintenance progran.

Response

DLC has contacted the vendor in regards to the recommended 5 - ye ar maintenance progran. Based on the aforenentioned discussion with the vendor, DLC. will follow the recommended 5 year maintenance progran.

Status:

Closed; based on this submittal i

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PV0RT Issue 11: -Check Valves (IE .Information Notice 86-01)

The NRC requested DLC to be aware of concerns. identified in I.E. Notice

~ 86-01 concerning check valves.

Response

.The NRC was presented the DLC position on IE Notice 86-01 and was

- assured that DLC is fully aware of the concerns that were identified.

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Closed 1

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PV0RT. Issue 10: Masonellan Air Operated Valves (2BDG*A0V100B1)

Provide justification for the lack of usage of the vertical seismic load (with any' anplification factor) in the bonnet stress analysis when -

developing an " equivalent pressure" (Peq) per ASME Boiler and Vessel Code Section 3.

Response

Inclusion of the vertical seismic load and anplification factor was not required due to the insignificance of the load compared to the torsional load which was applied due to the offset mass associated with the actu-ator. The load due to the vertical seismic load is a factor of 10 less than the torsional (bending) ~ load applied. The overall acceptance of the approach is justified by review of vendors stress results using Peq which shows an actual stress of 6000 psi against an allowable of 30,000 psi.-

Status:

NRC Review in Process

SQRT/PV0RT General Issue 1: Identification of Equipment The NRC SQRT/PVORT tean leaders and EG&G consultants were concerned with the traceability of Equipment Mark Number. to Vendor or Manufacturer Identification Number.

Response

A presentation was given during the audit to both SQRT/PV0RT tean leaders and EG&G consultants concerning the method of traceability of equipment- at BVPS-2. This presentation outlined the methods used by BVPS-2 to ensure that the equipment iten installed is identified by Mark Number in the Qualification Document. This approach, identification by Ma r k Number, has been used on other nuclear facilities including BVPS-1.

Therefore, DLC considers this issue satisfactorily resolved.

Status:

NRC Review in process