ML20235N479

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Amend 1a to RESAR-SP/90 Pda Module 7, Structural/Equipment Design
ML20235N479
Person / Time
Site: 05000601
Issue date: 01/31/1989
From:
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML20011C562 List:
References
RESAR-SP-90, NUDOCS 8903010238
Download: ML20235N479 (5)


Text

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': : ' WESTINGHOUSE CLASS 3 w

L AMENDMENT la TO RESAR-SP/90 PDA MODULE 7 STRUCTURAL / EQUIPMENT DESIGN O

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O WEC P.O. Box 355 l Pittsburgh, PA 15230 l-I 1

WAPWR-S/E AMENDMENT la 1858e:1d JANUARY, 1989 8903010238 890214 DR ADOCK 0500 1


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, AMENDMENT la'TO RESAR-SP/90 PDA MODULE 7 STRUCTURAL / EQUIPMENT DESIGN-INSTRUCTION SHEET O

Replace current pages' 210-9 through 210-10 with revised pages 210-9~through 210-10.

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WAPWR-S/E AMENDMENT la 4858e:1d JANUARY,1989

RESPONSE

Regulatory Guide 1.151- generally endorses ISA-S67.02 and was developed to provide guidance for the design' and ~ installation lof instrument sensing lines. In endorsing this standard, the NRC has presented several additional regulatory positions addressing common sensing. lines, mechanical ; design, and environmental considerations.

7T Industry standard ISA-S67.02 reiterates and clarifies the Westinghouse practice as expressed in .the controlling ' documents, i.e.. interface requirements and regulations. Westinghouse utilizes q the Engineering Flow Diagram as the approved document to designate b the safety classification system boundaries for' use by the-B0P/ Architect-Engineer. Instrument lines that are. attached to the safety class process piping in NPB systems show a continuation of safety class from the process piping to the instrument lines and instruments. Where there is a transition between the safety class, this information is also reflected accordingly. The following represents the Westinghouse position relative .to the additional regulatory positions listed in Part C of the guide:

Positions 1, 4, and 5: Westinghouse agrees and follows these regulatory positions.

Position 2(a): Westinghouse agrees with this position and includes the appropriate information on the related engineering diagrams.

Position 2(b): Westinghouse agrees with this regulatory position, and provides the following clarification regarding implementation:

In general for instrumentation channels used to actuate or monitor la safety related functions or systems, the " sensing line" between the instrument sensor and the Safety Class 1 or 2 (ASME Class 1 or 2) l

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process piping or vessel consists of two sections:

O WAPWR-5/E 210-9 AMENDMENT la 4858e:1d JANUARY, 1989

.1. A " piping" section, consisting of . a short length of.3/4 inch

.g Schedule 160 pipe meeting ASME Class 2 and Seismic Category 1

() requirements. Connection of this pipe to the process piping'or vessel is made through a passive flow restrictor, which limits flow to within the capacity of the normal makeup system in the event of line rupture. 'The pipe terminates in a normally open isolation valve.

2. A " tubing" section, consisting of instrument or capillary tubing-p of small inside diameter, between. the isolation valve and

(,) sensor. The rules of Section III of the ASME Code (see NCA-1130) do not apply to instruments, or to permanently sealed fluid filled tubing systems furnished with instruments. Therefore this section is . designed and specified to the level of detail la necessary to meet 'its functional requirements and for compatibility with the instrument sensor. In addition, seismic supports for this section adequate to meet Seismic' Category 1 requirements are specified.

These a' arrangements assure proper operation and provide protection against both single failure and common mode failure. In the event of a single random failure of any portion of the installation, up to and including complete rupture in the piping section, tubing section or sensor, the resulting outflow of reactor coolant will be limited to within the capacity of the normal makeup system either by the flow restrictor in the piping section or by the inherent high flow resistance of the tubing section. The sensing line seismic supports protect against a common mode failure of all sensing lines that might O otherwise result from a seismic event.

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O WAPWR-S/E 210-9a AMENDMENT la 4858e:1d JANUARY, 1989 1

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Position (3): Westinghouse agrees with this licensing position. Any.

gs -instrument sensing.line between the Safety Class 3 (ASME Class 3) process piping or vessel and an instrument sensor used to actuate or monitor safety related functions or systems will be fabricated in the 33-same manner as indicated above for compliance with position 2(b).

The only difference is that'the " piping" sections of.the sensing line would 'be fabricated to ASME Class 3 requirements'instead of to Class I 2 requirements; also Seismic Category 1 requirements would apply.

Position 6: Agreement or disagreement with this regulatory position is moot. Applicable codes and code addenda are clearly established by other documents.

210.20 A number of ASME Code Cases are identified in Regulatory Guides 1.84, 1.85, and 1.147 as conditionally acceptable. That is, Regulatory Position C.1 of each guide identifies additional conditions that should be imposed in addition to those conditions specified in each Code Case.

Provide a commitment that when conditionally approved Code Cases are used in the construction of ASME.Section III, Class 1, 2, 3, MC, NF, and NG components that'you will be in compliance with .the additional conditions applicable to each of the conditionally approved Code Cases that are identified in Regulatory Guides 1.84, 1.85, and 1.147.

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O WAPWR-S/E 210-10 AMENDMENT la 4858e:1d JANUARY, 1989