ML20236X516
| ML20236X516 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/05/1998 |
| From: | Repka D NORTHEAST NUCLEAR ENERGY CO., WINSTON & STRAWN |
| To: | Cole R, Kelber C, Moore T Atomic Safety and Licensing Board Panel |
| References | |
| CON-#398-19396 LA-2, NUDOCS 9808100063 | |
| Download: ML20236X516 (15) | |
Text
'
/93 %
o
~
l WINSTON & STRAWN I
USNiiC 3S WEST WACKER DRIVE 1400 L STREET, N W.
- 6. RUE DU CIRQQE CHICAGO. ILLtNots 60 sot-9703 75006 PARIS. FRANCE.
WASHINGTON D.C.20005;$.$* AU,u -7 P 1 :58 200 PARK AVENUE (202) 371 5700 suLAYMANIYAH CENTER NEW YORK, NY 10166,4193 HIYADM 11495. SAUDI ARABIA FACSIMILE (202) 37GGlid 7
DAVID A. REPKA m,
1204 GENEVA. SWITZERLAND August 5, l@'l ?
"~
(202337i.572e Thomas S. Moore Dr. Richard F. Cole Chairm:m Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Dr. Charles N. Kelber Administrative Judge l
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Subj: Northeast Nuclear Energy Company l
(Millstone Nuclear Power Station, l'
IInit 31 Docket 50-423.LA-2
. Gentlemen:
On July 23,1998, in response to a Licensing Board Order, Northeast Nuclear Energy Company (NNECO) provided the Licensing Board and parties with a copy of the license amendment application (dated April 1,1998) at issue in this proceeding. Prior to that date, by letter dated July 9,1998, NNECO had provided the Licensing Board and parties with a copy of a submittal made by NNECO to the NRC Staff on June 26,1998, providing certain additional information on the April 1,1998 application.
l In reviewing the matter, it has come to our attention that NNECO had made an additional submittal on this matter on M. 29,1998, responding to an NRC request for additional information on the application. Although this is a public document available in the NRC's Public g
1 9000100063 990005
~
PDR ADOCK 05000423 0
PDR 303
WINSTON & STILiWN i
Thomas S. Moore -
Dr. Charles N. Kelber Dr. Richard F. Cole August 5,1998 Page 2 Document Room, to ensure completeness attached hereto is a copy of the May 29,1998 NNECO submittal. The submittal provides additional information on the sump pump subsystem discussed l
in the April 1,1998 application.
I Sincerely, h;dA.
L-David A. Repka Counsel for Northeast Nuclear Energy Company t
Enclosure cc:
Service List i.
l l
Document Number: 98996.1 8-5-98/10:37am i
,). Northeast
""er r,ny n,ian-ni, in woierror.i. cr 063as Nuclear Energy n,ii,,oo, s,. i,,, i,...., s,,in, N.rilien. N.clent IG,rrgy Onenpany P O llos 128 Waarrfor.l. Gl' 06:UtF. 012n i
n'.s.0) 4 4 ? C's t I
i
,m...n..
ir-n.. s... a...., i,,i..... s.....
MAY ? 9 m:
Docket No 50-423
~
B17220 I
Re: 10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station Unit No. 3 Proposed License Amendment Request (TAC NO. MA1379)
ESF Building Sump Pumping Subsystem (PLAR 3-98-2) j l
Response to Reouest for Additional Information I
i in a letter dated April 1,1998, Northeast Nuclear Energy Company (NNECO) requested
. a license amendment to revise the Millstone Unit No. 3 licensing basis by adding a new j
sump pump subsystem to address groundwater inleakage through the containment l
basemat. The NRC Staff in a letter dated April 30,1998 requested NNECO to provide l
additional information to support our proposed license amendment.
i provides a list of commitments regarding this submittal, Attachment 2 provides specific responses to NRC questions,.and Attachment 3 provides information regarding the substantial time available to initiate the ground water removal system. This time frame exceeds 40 days.
l 1
if you have any additional questions, please contact Mr. D. Smith at (860) 437-5840.
NORTHEAST NUCLEAR ENERGY COMPANY l
l l
Martin L Bowling, Jr.
V Recovery Officer - Technical Services cc:
H. J.
Miller, Region i Administrator W.D. Travers. Ph.D., Director, Special Projects Office J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3 Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection l
79 Elm Street Hartford, CT 06106-5127 J, u l'"MlM '-
~ w v y vi,,
L-___________-______--_____--_____-_______________.
l, Docket No. 50-423 817220 Millstone Nuclear Power Station Unit No. 3 Proposed License Amendment Request (TAC NO. MA1379)
ESF Building Sump Pumping Subsystem (PLAR 3-98 2)
Response to Request for Additional Information NNECO's Commitments I
May 1998
U.S. Nuclear Regulatory Commission B17220\\ Attachment 1\\Page1 l
Enclosure List of Regulatory Commitments The following table identifies those actions committed to by NNECO in this document.
Please notify the Manager - Regulatory Compliance at the Millstone Nuclear Power Station Unit No. 3 of any questions regarding this document or any associated regulatory commitments.
Number Commitment Due None I
I 1
l w___________________-_________
l Docket No. 50-423 B1722]
Millstone Nuclear Power Station Unit No. 3 Proposed License Amendment Request (TAC NO. MA1379)
ESF Building Sump Pumping Subsystem (PLAR 3-98-2)
Response to Request for Additional information i
l I
May 1998 I
l U.S. Nuclear Regulatory Commission I~
B17220\\ Attachment 2tPage 1 l
l Question 1 in the submittal dated April 1,.1998l NNECO states that in the proposed revision
. to the Final Safety Analysis Report Table 3 2-1, the containment recirculation sump piping is listed as ANS Class 3; however, the Code Class is denoted as N/A (not applicable). Also the table does not contain the other components in the engineered safety features (ESF) building sump pumping subsystem, which is necessary to assure operation of the recirculation spray system following a loss-of-coolant-accident (LOCA). This is inconsistent with Regulatory Guide l
1.26 guidance, which states that such systems having an important safety function for post-accident containment heat removal should be categorized Quality Group C, which should be designed to American Society of Mechanical Engineers (ASME) Code Class 3 requirements.
Provide justification for not designating these safety-related components as ASME Code Class 3.
Resoonse Final Safety Analysis Report (FSAR) Table 3.2-1 provides a list of QA category 1 and seismic category 1 structures, systems, and components. This new sump pumping subsystem consists of both QA category 1 and non-QA category 1 components. The code class is listed as N/A because this piping is considered to be ANS Safety Class 3, non-ASME (See Design Philosophy below).
The Design Philosophy used was as follows:
i a) Quality Group D was selected using Regulatory Guide 1.26 for the new subsystem because this subsystem did not fall specifically into any of the Quality Groups A, B or C.
b) However, the subsystem, does perform a safety function and according to i'
RG 1.26 "should be designed, fabricated, erected and tested to quality standards commensurate with the safety function to be performeo."
i c) The safety function to be performed for this subsystem is the long-term removal of groundwater, post accident, to preclude flooding the RSS cubicles which could ultimately jeopardize the integrity of the containment steel liner and the operability of the RSS pumps.
This function, pre-accident, is handled by a nonsafety-related sump pump subsystem. The system can be nonsafety-related because the cubicles.are accessible during normal plant operation and any malfunction can be rectified or temporary pumping means I
can be employed before any harm to the containment liner or RSS equipment can occur. However, post accident, radiation levels in tne cubicle make it inaccessible and therefore the subsystem, inside the ESF Building, is required to be QA category I and seismic category I to provide added
l U.S. Nuclear Regulatory Commission B17220\\ Attachment 2\\Page 2 assurance that the inaccessible portion of the subsystem will operate without requiring maintenance for one year post accidentN The pump and the piping system from the pump to the outside isolation valve d) is required to be ANS Safety Class 3 and will be designed, fabricated, j
erected and tested to quality standards commensurate with the safety function to be performed. These standards are:
I
\\
Pump manufacturer's standards
.1 I
Piping & components ANSI B31.1, seismically supported, QA Cat i materials with traceability and fabrication controls without "N" stamp ANI inspection required.
e) The air supply components outside of the building are not required to be QA Category I because they are outside of the areas affected by accidents mitigated by RSS and are thus accessible. Attachment 3 serves to demonstrate that there is an ample amount of time available to operators / mechanics to fix any malfunctions to the equipment outside of the building (i.e. compressors & hoses). It should also be noted that either train is capable of removing the daily groundwater inleakage. Therefore, any malfunction resulting in loss of air supply can be rectified or other compressed air sources can be employed before RSS or containment operability are challenged.
These classifications, codes and standards were chosen because they are commensurate with the functions to be performed by the new subsystem given the following factors:
The removal of groundwater by the new subsystem following a LOCA is not required to be performed until weeks after the event (see Attachment 3).
The attributes associated with the implementation of the sump subsystem design modification are essentially equivalent to Quality Group C, for piping, pumps, and associated supports. A comparison between the existing system requirements and the ASME code for Materials, Design, Fabrication, Examination, and Testing is provided in Attachment 4.
The subsystem, by design, does not transport liquid radioactive fluids.
W MNPS-3 Final Safety Analysis Report, Volume 16, Questions and Responses - NRC Letter:
i l
May 31,1983 Question Q440.67 (Section 6.3) 1
U.S. Nuclear Regulatory Commission B17220\\ Attachment 2\\Page 3 Question 2 Because the ESF building sump pumping subsystem pumps and valves are used to mitigate the consequences of a LOCA, they should be included in the plant inservice testing (IST) program and periodically tested in accordance with the applicable edition of the ASME Code.
Provide the justification for not including these safety-related components in the IST program.
Response
The Millstone Unit No. 3 IST program includes certain ASME lit, Class 1, 2 and 3 pumps and valves. For reasons stated previously, the new subsystem is not required to be ASME 111 and therefore not included in the IST program. However the Millstone Unit 3 Technical Requirements Manual has been revised to provide periodic testing of both trains of compressors / sump pumps. In addition the pumps will be operated every quarter per the preventive maintenance program.
Question 3 Two designated air compressors are to be used for motive power for the ESF building sump pumps and should be included in the Quality Assurance (QA) program in order to assure proper operation to accomplish their safety-related function. Describe the QA requirements for these air compressors.
Response
As discussed above (see response to Question 1) the compressors are not required to be QA category 1 to perform their intended safety function.
Given the long term requirement for their use, any malfunction of this equipment can be overcome without compromising the integrity of the steel liner or RSS operation (see Attachment 3). In addition, the added benefits (namely material traceability) of commercially dedicating the compressors to be classified as QA category I does not ensure that they are substantially more reliable. The non-QA category I compressors however will have periodic maintenance performed on them as recommended by the vendor and will be used to perform the tests described in the response to Question 2.
This will give reasonable assurance that the compressors will operate as required if called upon.
l l
U.S. Nuclear Regulatory Commission 817220\\ Attachment 2tPage 4 0.uestion 4 to NNECO's license amendment request (List of Regulatory Commitments) states that two air compressors are staged in designated locatio periodically tested to ensure their availability.
also indicate how their safety against tornado rissiles are ensured. Identify th
Response
v.-
The proposed storage location is the railroad canopy of the Fuel Building.
The compressors and associated equipment would be stored together.
This structure is seismic but not entirely tornado proof since there is a large roll up door on the east e where the compressors would be stored.
However, with regard to a Design Basis Tornado (DBT), Regulatory Guide 1.117 - Tornado Design Classification states tha
"...the selection of structures, systems and components to be protected against th effects of a DBT is based on not allowing offsite exposures to exceed an appro fraction of the 10 CFR Part 100 guidelines." The safety function performed by th compressors is to remove groundwater, which left unchecked, would eventually (see ) exert hydrostatic loads on the containment steel liner and later flood ou the RSS pump motors and render them unusable.
The long term threat will be corrected (see response to Question 1 and Attachment 3) after a tornado before a threat to the containment or RSS. Therefore, these compressors are not required to b protected against tornado missiles.
Question 5 Provide information regarding the method and the ground motion input used in the seismic qualification of the sump pumps.
Response
NNECO has performed a seismic qualification of pumps 3DAS*P15A/B using biaxial dynamic test results from an outside vendor. The test response spectra conservativ enveloped the required response spectra (ESF building, el. (-)34'-4"] at all frequencies from 0.0 to 40.0 bz. The testing met MP3 Design Basis requirements. The pump support attaches directly to the building structure, consistent with the test configuration.
Therefore, no additional seismic interaction effects apply.
i 4
i
Docket No. 50-423 817220 Millstone Nuclear Power Station Unit No. 3 Proposed License Amendment Request (TAC NO. MA1379)
ESF Building Sump Pumping Subsystem (PLAR 3-98-2)
Response to Request for Additional Information Flood Height Analysis i
l
)
I l
I I
May 1998 l
U.S. Nuclear Regulatory Commission B17220\\ Attachment 3\\Page1 Elood Height Analysis The new sump pump subsyse., is required to remove groundwater, post ac protect the integrity of the containment steel liner and to protect RSS from inoperable. The allowable flood height (Het) within the RSS cubicles before h pressure starts to be exerted on the containment steel liner is determined as follows:
Het= Elevation of the bottom of the steelliner-RSS cubicle floor elev Het = (-) 27'- 3"
- (-) 34'-9" Het=
7'- 6" = 90" The flood height (Hass) within the RSS cubicles before flooding out of the RSS m can occur is determined as follows:
Hass = Elevation of the bottom of the RSS motor - RSS cubicle floor Hass = (-) 19'- 31/2" - (-) 34'-9" Hass =
15'- 51/2" = 186.6" Since Het < Hass, the flood height within the RSS cubicles before hydrostatic pre starts to be exerted on the containment steel liner is the most limiting and therefore the governing case. By previous analysis, the cubicles were calculated to fill to a height o 6.6 inches given a Limited Passive Failure of 1500 gallons.
Therefore each RSS cubicle holds approximately 227 gallons per inch of flood (1500 gall 6.6in). If the cubicle was allowed to flood to 90 inches, then 20430 gallons would have accumulated (90in*227gallir ). Assuming the current average inflow of 500 gallons per day to each!
cubicle, the maximum time which can elapse without pumping before the liner can be challenged is 40.9 days (20430 galls 00gpd). This time does not include the rough 600 gallon capacity in each sump (with 3 foot extension) which would have to overflow before cubicle flooding could begin. Accounting for this would add an extra day to the total and therefore 42 days could elapse before adverse effects could jeopardize the 1
integrity of the containment steel liner.
l 4
It should be noted that this 42 day time frame is discussed to demonstrate the amount of time available to equipment operators / mechanics te fix any malfunctions to the nonsafety-related equipment outside of the building (i.<f. compressors & hoses).
In practicality, the pumps would be operated more frequently to ensure that the sump contents do not mix with any radioactive water alter.dy spilled on the floor due to a limited passive failure.
l
Docket No. 50-423 817220 Millstone' Nuclear Power Station Unit No. 3 Proposed License Amendment Request (TAC NO. MA1379)
ESF Building Sump Pumping Subsystem (PLAR 3-98-2)
Response to Request for Additional Information Design Compaison i
May 1998
U.S. Nuclear Regulatory Commission B17220%ttachment 4\\Page 1 Desian Comparison The following comparison is provided to demonstrate r aw.he quality standards chosen for QA Category I portions of the subsystem compare with ASME lit, Class 3. This list is not intended to be all inclusive.
Attribute Requirements Requirements of ASME Notes imposed in DCR M3-Boiler & Pressure 97079 Vessel Code, Section lit, Subsection ND and MP3 Design Basis Materials Pipina: SA material Pipina: SA material with Materials purchased QA with traceability traceability including Cat I have the same Pump: manufacturer's prescribed material chemical compositions standards tes. ting but may not have all Suppor: SP-ME-Pumo: ND-2000 and ND-prescribed material 570*
3410 (Manufacturer's testing. Also the pump standards) purchased is non-ASME.
Sucoorts: same Design Supports installed per Same NETM 24" to ensure piping compliance I
with ASME BPVC, Section lit, NC/ND 3600 Support design per NETM 45")
Fabrication Pipina: All welding per Same NU Welding Manual 4
Supports: Allwelding per NU Welding i
Manual and AWS D1.1 Examination Piping - All socket Same Acceptance criteria for welds, VT, acceptance VT are equivalent.
1 m SP-ME-570 Design Specification for Field Fabrication and Erection of Piping and Suppoits-Northeast Utilities Service Company Millstone Nuclear Power Station - Design and Installation of Small Bore Piping
")
Pipe Support and Duct Support DesQn Criteria Document - Millstone Nuclear Power 1
Station - Unit 3
O.
U.S. Nuclear Regulatory Commission B17220\\ Attachment 4\\Page 2 criteria per B31.1 Supports - All fillet welds, VT acceptance criteria per AWS D1.1 Testing Hydrostatic (1.5x des)
Hydrostatic (1.25x des)
Hydro performed at and inservice leak test higher pressure than for pump and piping required by Sect.111 or
[
not hydrotested.
Sect. XI.
l