View source for RBG-19-385, Forwards Revised Response to NRC 840123 Position Re Drywell/Containment Purge Sys, LOCA & Seismic Analysis & Revised Text of Fsar.Encls Respond to SER Confirmatory Item 18 Re Containment Purge Valves

{{Adams
| number = ML20100E814
| issue date = 11/08/1984
| title = Forwards Revised Response to NRC 840123 Position Re Drywell/Containment Purge Sys, LOCA & Seismic Analysis & Revised Text of Fsar.Encls Respond to SER Confirmatory Item 18 Re Containment Purge Valves
| author name = Booker J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000458
| license number = 
| contact person = 
| document report number = RBG-19-385, NUDOCS 8412060379
| package number = ML20100E823
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 21
}}

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GULF STATES                   UTILITIES COMPANY P O S T O F FIC E B O X 2951 . BEAUMONT. TEXAS ?7704 AREA CODE 713 838-6631 November 8, 1984 RBG- 19,385 File No. G9.5, G9.8.2.6, G9.19.2 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

==Dear Mr. Denton:==

River Bend Station - Unit 1 Docket No. 50-458 Attached is Gulf States Utilitics Company's (GSU) revised response (Attachment 1) to the Staff Position regarding the River Bend Station (RBS) Drywell/ Containment Purge System transmitted to Mr. W. J. Cahill       ,l from Mr. A Schwencer on January 23, 1984. This transmittal supersedes GSU's letter from Mr. J. E. Booker to Mr. H. R. Denton dated March 13, 1984 and reflects discussions held with the Staff on April 3, 1984.
In addition, GSU's position as stated herein represents the response to the Safety Evaluation Report (SER) Confirmatory Item #18 -
Containment Purge Valves (SER Section 6.2.4.3, pg. 6-29).
Attachment 2 contains revised text of the Final Safety Analysis Report (FSAR) to support statements in Attachment 1 and in combination with Attachments 3 and 4 address the Staff's Request for Additional Information on Purge and Vent Valve Operability transmitted to Mr. W.J.
Cahill from Mr. A. Schwencer on March 15, 1982. The revisions contained in Attachment 2 will be included in a future FSAR Amendment.
Sincerely, e   h J. E. Booker Manager-Engineering, Nuclear Fuels & Licensing River Bend Nuclear Group OlOV                          6y JEB/WJR/JWL/j e
                                    '                          l Attachments (4)                M'f \                  '     '
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8412060379 84110s q
E PDR ADOCK 05000458 PDR A

r Attachment 1
: 1. STAFF POSITION Continuous containment purging through large diameter valves will not be allowed. We will require the applicant to develop appropriate interim guidelines that will establish provisions for a reduction in the use of the containment purge system. These guidelines will consider limitations on airborne activity levels to satisfy the as low as reasonably achievable (ALARA) levels and overall containment air quality in determining when use of the purge system is not needed. The interim guidelines shall be furnished to the NRC staff six months before the initial fuel load data.

===RESPONSE===
GSU has performed an analysis to estimate the number of hours per year that containment purge will be required for containment radiation purposes. This analysis is based on GE Document No.
22A5718, Revision 1, " Mark III Containment Dose Reduction Study",
dated March 11, 1980, using design basis main steam and coolant source terms. The buildup of airborne activity in the containment is assumed to be interrupted every 18 months for a refueling cutage.      {
The basic criteria used in this analysis was to maintain airborne activities below 25 percent maximum permissible concentration (MPC) during normal operation. Using the normal containment purge rate of 7,000 cfm, the results of the analysis indicated that a normal containment purge usage of 7,300 hours per year is required to limit the airborne setivity to 23 percent MPC. This analysis has been reflected in the proposed RBS Technical Specifications submitted July 17, 1984 (RBG-18,233).
: 2. STAFF POSITION The app.'.icant shall commit to implement a data collection effort to justify the need for containment purging. Before startup after the first regtlarly scheduled refueling outage, the applicant shall use the results from the above program (based on containment purge system (CPS) operating experience information) to evaluate the plant's need for purging. A summary of the evaluation shall be provided to the NRC staff before the plant returns to operation.

===RESPONSE===
GSU will implement a data collection program, during the first fuel cycle, to collect and evaluate RBS containment purge operating experience information. An evaluation of this information will be made to determine if personnel exposure can be reduced, if airborne concentrations were maintained less than 25% of the maximum permissible concentration as specified in 10CFR20, and if changes to the interim purge guidelines are warranted.
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4 GSU is aware that data gathered during the first fuel cycle may not necessarily be indicative of dynamic plant conditions and will consider future plant usage in evaluation of the interin guidelines.
Evaluation of the interim guidelines will include any applicable Mark III purge experience.
: 3. STAFF POSITION The applicant shall commit to develop a containment access management program so that access time requirements will be minimized as appropriate. Considerations of the total spectrum of activities to be performed, as well as when and how those activities can be accomplished, will be included. A description of this program shall be furnished to the NRC staff six months prior to the initial fuel load date.

===RESPONSE===
GSU has developed a containment access management program (CAMP) to minimize personnel access and residence time in containment.
The primary objective of the CAMP for River Bend  Station is to control and evaluate containment access based on  plant specific operational  experience. In order to control and  evaluate containment eccess, the CAMP will consist of the  following activities:
: 1. Procedures to control containment access
: 2. Collection of access data during first fuel cycle
: 3. Evaluation of access data
: 4. Recommendations based on data evaluation Control of containment access will be by procedure which establishes criteria to be met prior to entry, coordinates the entry among the various site groups (i.e. Operations, Security, Maintenance) and directs the collection of access data:
: 1. When entries are made
: 2. Purpose of each entry
: 3. Duration of each entry
: 4. Number of personnel required for each entry Access data vill  be evaluated at the end of the first fuel cycle to determine if  regularly scheduled containment entries are being consolidated to  the greatest extent possible and if equipment performance indicates  that the frequency of operational checks and routine surveillances  can be reduced based on the data evaluation.
Recommendations will be made by the ALARA Committee to Operations and Maintenance with regard to frequency and scheduling of operational checks and routine surveillances.
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( 1'                     a         4. -STAFF POSITION
                                             , P' urging (of; the ~ containment shall' be secomplished lby.'use of a       ._
         -                                        low-volume; purge l system, i.e'.,ipurge valve. size'shall not exceed-8" for Operattug : Modes' l', 2,. and.3 (i.e. , l power- operation, start up and hot. shutdown). LHowever, to' avoid delaysiin critical. path testing of:
                                                                                                           ~
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                                             -the-purge. system'and-the_ resultant l impact on fuel load schedules, it (E,            .
                                            'is. proposed that,the existing system betused until it is-determined, c
6                                          ~ based onJItems 1-3 above,1when: purging..isineeded;and the-line size
             -=                                   to' accomplish this'. The applicant:shall:also commit-to submit forn staff l review all available data and proposed programs that (demonstrat'eLthe reliability of the:36Linch diameter. valve utilized cat River Bend Station six months prior,to fuel load.                                            .
                                      .s

===RESPONSE===
Based on'GSU's stated position on Items 1-3 above, GSU is using the p ..                                      : existing system equipment'for limited purge'in accordance with the interim guidelines. Based on the.results and evaluation of'.the.
icontainment purge operational data gathering program in Item 2, the purge 1 guidelines for the first. fuel cycle will'be evaluated and a-
 !                                                report submitted:to the-NRC.
                          ~
Enclose'd'a'e     r      the Posi-Seal International, Inc..-report (see Attachment 4) supplemental technical justification (see Attachment
                                             -3) and an evaluation of NRC Branch Technical Position (BTP).CSB 6-4,.
                                             . outlined-in table form:(see Attachment 2). . In conjunction with the -
enclosed documentation, which outlines the considerations developed for. showing valve reliability, GSU will add actuator limit stops restricting the valves to.a 65-deg. opening and change the bolting Laaterial on valve 1HVR*A0V123 to SA354GRBD. The restriction was
                                              'developedLin the LOCA and seismic analysis (Attachment 4) based on flow rates developed-with a conservative 9-psi pressure drop.across the antives. GSU is implementing the Poti-Seal recommendations for all-valves, even though our estimated dP will be 3' psi with
                                              'significantly lower. aerodynamic torques. This is addressed in the
         -                                        technical justification. The bolts'are being changed to ensure that c                        ' valve 1HVR*A0V123 is not overstressed during seismic and LOCA:
                                              . events.
: 5.         STAFF POSITION
: Purge / vent valves that are to be used during Operating Modes 1 through 3 shall meet all staff requirements set forth in Branch Technical Position 6-4.
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===RESPONSE===
V. .
3, CSU will comply with the intent of BTP 6-4 with the following clarifications:
: 1. (a).      Comply 1.(b)'       The current number of primary containment /drywell purge supply and exhaust lines are limited to one supply and one exhaust line.
1.(c)        The current design utilizes 36 inch containment isolation valves and 24 inch drywell isolation valves for the primary containment /drywell purge supply and exhaust lines.
1.(d-g)      Comply
: 2.           Comply
: 3.           Recirculation of containment atmosphere is accomplished through an external purge filter.
: 4.           Comply 5.(a-d)      Comply
: 6. STAFF POSITION The drywell supply and exhaust isolation valves shall be normally
                                                                                   \
closed during Modes 1 through 3 except:
: a.      To accommodate drywell pressure control or reduce drywell activity levels in Operating Mode 3, the applicant shall limit use of the drywell purge system to 90 hours per year (cumulative) for Operating Mode 3.
: b.      To accommodate the need for drywell pressure control during Operating Modes 1 and 2.
(1) Either the exhaust or supply lines of the drywell purge system may be opened, but both lines shall not be opened at the same time, (2) While venting the drywell, the containment shall not be vented or purged, and j
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c                 ;x C                        . "'..                s (3) DThe total _. time of ventingsthe drywell shall'be limited to
                                                                   .five: hours per.~ year (cumulative) for Operating. Modes 1'and' y'
                                                                   -2. JThis restriction will.be withdrawn ~upon: receipt and
                                                                  '_NRC approval:of' analyses to demonstrate acceptable (consequences on_the containment structure!and'the enclosed equipment following~ onset of4the most~1imiting primary::
                                                                  , system break during use of the drywell' purge system.
RESPONSE-
                                         ;GSU.is currently _ studying'the nee'd,' availability and design of the idrywellipurge system in light.of'the' Staff's recommendations-and
                                         ;will respond 'ay December. 14, 1984.
                                   "7.      STAFF POSITION
           ^
If purging:(either-drywell or containment) is'through the SGTS, requirements-Sb of Branch-Technical Position 6-4 should be met,
                                            -otherwise, the following restrictions should be implemented.
: a.           Whenever the purge system is in use during Operating 1 Modes 1, 2, and 3, only-one of the two SGTS trains shall be_used, and b ~. -       Both-SGTS trains are determined to be operable whenever1the
                         ,                               purge system is in use.
RESPONSE.
Norma 1' primary containment purging (7000 cfa) in Operating Modes 1,,
2 and 3 will be.through the containment purge exhaust filter;
                                         ~however one standby gas treatment system (SGTS) subsystem may.be'in the purge flow path provided that both SGTS subsystems are operable.
The two=SGTS, trains will not be used in the fast purge mode (25,000
                                         -cfm)-in Operating Modes 1, 2 or.3..
: 8. STAFF POSITION The hydrogen mixing system shall not be opened during Operating Modes 1 through 3 for drywell pressure control or airborne activity level reduction- since the valves on this system receive ru) LOCA isolation. signal.
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===RESPONSE===
The hydrogen' mixing system valves for the drywell close on a LOCA signal. This signal can be overridden by the operator upon verifying that an actual LOCA does not exist (see-revised FSAR Section 6.2.5.2.1 contained in Attachment 2.) In addition, the hydrogen mixing system valves are environmentally qualified; therefore, one inlet line or one exhaust line may be opened for drywell pressure control provided that the primary containment /drywell purge valves are closed. The potential for drywell bypass with the 6 inch hydrogen mixing system inlet valve open is 0.20 sq.ft which is bounded by the analyzed allowable bypass for the entire spectrum of breaks for RBS. Based on acceptable containment pressurization consequences under all break conditions with one hydrogen mixing line path open, GSU may elect to utilize this path for drywell pressure control with no limitations on total time for venting in a year. While venting the drywell using the hydrogen mixing system in Modes 1, 2 or 3, the primary containment /drywell purge system will not be operated.
: 9. STAFF POSITION The purging system (drywell and/or containment) shall not be utilized for temperature / humidity control during Operating Modes 1, 2 and 3.

===RESPONSE===
The primary containment /drywell purge system will not be utilized for temperature / humidity control during Operating Modes 1, 2 and 3.
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                                                                                'FSAR REVISIONS-INCLUDING A-4                                       .                    

==SUMMARY==
EVALUATION OF CONTAINMENT - "
FURCE VALVES AGAINST NRC
_ BRANCH. TECHNICAL POSITION CSB'6-4 e         . I Note: These revisions will be included in the FSAR.in a future amendment.
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as RBS-FSAR
             ;.;7.I.                                                          intent         yof       the      technical
        ? f?'                                                                 position           requirement                  for 1eakage         rate        testing.           The j                                                                           system.        complies       :with this technical position for testing the availability of the valve isolation           function.                -Leak tightness          and       testing                in accordance             with        10CER50,
                                         ..                                   Appendix J,.are considered to satisfy         the      intent of the branch          technical          position
  .c                                                                          requirement for leakage rate I                                                                         testing.
(4)    BTP      CSB 6-4 Position B.S.c:
The       ECCS         back        pressure requirement is not applicable INSERT                                      y                          to BWR containment.
: 6. Containment Hydrogen Purge The Containment Hydrogen Purge System complies with all       applicable                portions          of          NUREG-0737, Item II.E.4.2, except:                                                                        11 A'                              a.           Positions 1 and 3:
    .                                                           Manually operated containment isolation '
valves in the nonessential penetrations listed below are closed during. normal, shutdown, and postaccident operation.
Penetration                Title                                Valve No.
1KJB*Z31                   Containment Hydrogen                 1CPP*SOV140 l                                                           . Purge Supply Line 1KJB*Z33                 . Containment Hydrogen                 ICPP*MOV104 Purge Return Line                    1CPP*MOV105
                                                   ~
;                                                                For         these           motor-operated                     and solenoid-operated valves, administrative control includes mechanical devices to seal or lock the valve- closed or to prevent power from being supplied to the valve operator.             Valve        position               and locking devices are. checked each time the
              -                                                  containment is secured.              In addition, the seal or lock is verified intact.at'least
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B Demonstration.of the operability of the containment purge valves and their ability._to'close during a design basis accident is sununarized in    ,
HTable-6.2-52.    .1 detailed report'has been submitted to'NRC under         i f,
separate cover.(Ref. 27) The report verifies.that the valve actuator's torque capability has sufficient margin to overcome the torques and forces that resist closure when stroking from the initial open position to full seated in the time limit specified'following a design basis LOCA..
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,                 ,          3.5 volume percent. Thus, the hydrogen mixing system                               is
:. n capable of removing -hydrogen at generation rate.                               a rate of 2.2 times                the Initiation     of the hydrogen mixing system                    requires an operator first to. energize an inlet valve in the line connecting the drywell and containment.                       Opening of the valve equalizes drywell and containment pressures if they are different.- An interlock is provided to prevent opening of the outlet valves before the inlet valves are fully                                    '
opened.      The operator then manually opens the outlet valves and, the with  the valves in their fully opened position, starts hydrogen     mixing       fan    (Fig. 7.3-8).          There is no limitation to on pressure the  initiation   of  hydrogen     mixing         system due differentials         between      the       drywell          and containment.
Using extremely conservative system initiation is not required         assumptions, hydrogen mixing until at least 3 hr following the LOCA.
An alarm is sounded in the main control
                           -rocm when hydrogen concentration at any of the four drywell sample points is determined by the analyzer to be greater-
                           .than or equal to 3.5 volume percent. This alarr signals the                                   -
operator INSERT 1                           to manually        initiate the hydrocen mixina system.<w T,1e requirement for manual operation ensures that spurious signals     dc    not      prematurely      actuate      the     system          and,                 ms, therefore,   do not result in inadvertent steam bypass leakage from the drywell to   the     primary containment. The valve interlock     previously     described      ensures that            a        single operator mixing fans.
error does not result in initiation cf the hydrogen Although a single operator error could result in   the   opening of one 6 in hydrogen mixing system inlet
* path, the allowable steam hypass leakage capacity for the River Bend Station drywell                    -
bypass leakac e capacity of this leakaae (A//k = 1.0 f t2) exceeds the INSERT 2                                                                 oathias discussed in Section 6.2.1.1.3.4.
Drywell and containment conditions of pressure, temperature, and hydrogen concentration are             continuously      monitored             and are available to the main control rocm operator,s.
6.2.5.2.2     Hydrogen Recombiner System The    long-term centrol         of    hydrogen below the '4 percent by volume flammable limit         is    achieved    by    means       of      thermal hydrogen recombiners located in the primary containment.
The hydrogen recombiner system is fully redundant. and consists of two 100 percent capacity hydrogen recombiners.
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The hydrogen mixingl. system valves c.1ose'on a.LOCA signal whichican be
                                                         ' overridden by the operator-upon verifying that.an actual.LOCA does not 1 exist.
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                                                        - Insert 2 far Page. 6.2-80.
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RBS ESAR
: 24. Regulatory Guide 1.141, Containment Isolation Provisions
                   .                     for Fluid Systems, April 1978.
: 25. Regulatory          Guide 1.11,      Instrument Lines     Penetra. ting Primary    Containment,         March 10, 1971;      supplement,       33 February 17, 1972.
: 26. BWR Owners' Group, NUREG 0578, Implementation Analyses and Positions. for Plan-Unique Submittals NEDO-24782, BONED 006 Class I, August 1980.
: 27. Transmittal letter from J.E. Booker to H.R. Denton dated November 8, 1984 (RBG-19,385); Docket No. 50-458.
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==SUMMARY==
OF CONTAINMENT PURGE VALVE OPERABILITY DEMONSTRATION Consideration                            RBS Analysis
: 1. Valve closure rate vs time          Valve closure is within 3 seconds. This is ensured in Reference 1. The 3-second closure ensures worst-case differential pressure of 3 psi or less (see Item 2).
: 2. Flow direction through valve        Flow direction evaluation in and dP across the valve             Reference 1. 1HVR*A0V165 and r                                           166 are in preferred direction for closure, and 1HVR*A0V123 and 128 are in nonpreferred direction.
The maximum differential pressure is less than 3 psi based on various accidents outlined on FSAR Figures 6.2-4 through 6.2-7. Isolation occurs based on drywell pressure.
See Logic Description, FSAR Figure 7.3-9, sheet 14.
: 3. Single valve closure vs              In performing the LOCA analysis, simultaneous valve closure          it was assumed that the valves close individually. This assump-t                                            tion is considered more conserva-tive because if both valves closed simultaneously, the resistance in the system would be greater, and consequently, the flow and the aerodynamic torque would be less.
: 4. Containment backpressure             The backpressure effect on venting effect on closing torque            pilot air to the containment is margins of the air-operated          conservatively addressed in Reference valves, which vent pilot air         1 (i.e., assumed 9 psi containment inside containment                  backpressure).
: 5. Adequacy of accumulator              Accumulator not required. Valves close by spring force on release of air from operator.
: 6. Adequacy of torque-limiting          No terque-limiting devices are devices                              required because of the valve design.
: 7. Effect of upstream and down-         The effect of the piping system stream piping system                was addressed in Reference 1.
Only one valve, lHVR*A0V123, R

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                                                                                     . required that the; effects =of an
                                                                                     -elbow be addressed. An investi =
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gation by Posi-Seal could.not.
develop conclusive results'about
                                                                                      'the effects of elbows on the U                                                                                     flow stream. For this reason                 L Posi-Seal made estimates:about
    ~                                            '
effects on'the flow. stream
                                                                                     -through.the bend and added:this to the LOCA-developed torques through a . straight run of pipe.
Posi-Seal's analysis, outlined; in Referenced 1,. indicated that.
the valve actuator would develop
                                                                                                             ~
                                                                                     -enough torque to close the valve.
After. reviewing the effects'of'a
!'                                                                                    3 psi pressure differential across the valve, the-LOCA-developed torque was doubled through a-straight run of pipe in accordance-
                                                                                     -with the NRC concern outlined in-Enclosure 4 of Reference 3.
Doubling of this torque'did not
                                                                                     . exceed.the available actuator closing torque th'us indicating-that the valves would close.
: 8. Effects of butterfly valve                           The effect of the valves' disc ~
disc and shaft orientation               and shaft orientations was ad-on valve operation                       dressed in Reference 1. The analysis, assuming a.9 psi pressure drop across the valves.
                                                                                     -indicated that valve 1HVR*A0V123' be restricted at 65 deg open. To be conservative, all four valves will be restricted to 65 deg open. When restricted to this size opening, and considering the valve disign, flow will tend to close the valve.
: 9. Seismic and stress loading                           Valves were seismically analyzed and analyzed for stress-conditions developed by a'LOCA in
                                                                                                                 ~
the Reference 1 report. The report, in combination with the Post-Seal seismic report (Reference 2) and SWEC supplemental ~ calculation No. SQE 2005, qualifies the valve for all seismic and dynamic loading conditions. The NAMCO EA-740 Qualification Report No. QTR111 l
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                                                                                                            ..(Reference 4) and SWEC           .
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                                                                                                          ! supplemental. calculation No.;SQE;
                                                                       ~
                                                                                                      ,~    '2008 address 'the dynamic loading::
            "<                                                                                           --  conditions for thel limit.
                                                                                                          = switches. The ASCO HV206-832-6F
            ,'                                                                                              . solenoids are qualified'for; ,
                                      ~
4 (seismic'and dynamic!1oading conditions by Raport. No.:AQR 67368 (Reference 3).and SWEC' supplemental Calculation No. SQE:
12042.
10.' Effects of environmental                                 The environmenta1' qualification conditions on valves (i.e.,                        ; program will qualify the valves .
                                                       - radiation temperatures, contain-                    and.their limit switch and. sole-
                                                  ' ' ment sprays, etc)-                                 -lnoid attachments to a qualified life. Preliminary analysis in-dicates-that each valve assembly 1                    -;
(including attachments)-is qualified for a maximum of 1.76 years. This analysis indicates that the solenoids must be changed every 1.76 years. , Valves.
1HVR*A0V165 and 166.have a=
qualified life-of 17.9 years'and.
valves 1HVR*A0V123'and 128 a-qualified life of 26.9 years.
: 11. Seal integrity after closure                             Valves were pressure leak-tested
                                                       ; of valves, including                              .by the vendor-to a minimum of environmental effects                                75.psig using the halogen diode detector method outlined in-accordance with ASM Section V, Article 10. Paragraph-T-1040..                '
During plant operation. the
                    ,                                                                                      ' valves will be subject .to the integrated leak rate test in accordance with 10CTR50, Appen .
dix J. At least once every 92 days, the seals will be tested to demonstrate their integrity in accordance with Technical Specifications Section 4.6.1.8.2.
The seals were evaluated under the environmental mechanical equipment qualification program,.
resulting in 40-year qualified                          ,
i                                                                                                            life.
: 12. Debris screens                                           Debris screens have been instal-i led in accordance with NRC requests in Branch Technical Position CSB 6-4 (see FSAR 7,                                                                                                           Section 9.4.6.2.5).
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13.TScope of operational andileak.            . Valves have.been.hydrostatically eJ                                   tests. performed on valves.              . tested by the seller for adher-L,,                                             -
ence to requirements of Paragraph' y
NC 6000, Code' Class 2 ASME III.
The valves have been' leak tested to requirements outlined in. Item jf-                                       11 of this table.-
The valv'es have been cycled by..
the seller to indicate that they' open against a maximum differential pressure of 15 psi.'
      ^
Valve 1HVR*A0V128 has been' tested for operability with a' simulated static load.of 3.0 g placed on-the. valve. The test was outlined                                                   .
in the Posi-Seal Static Operability Report (Reference'5),
                                                                                 . qualifying valves 1HVR*A0V123, 128, 165, and 166..
                                                                                 .During plant operation,-the valves seals-will be demonstrated operable every 92 days in
                     .                                                             accordance with Technical Specification Section 4.6.1.8.2.~
In accordance with Reference 1                                                      ,.
hydrodynamic testing was.
performed by Posi-Seal on valves-
                                                                                 .up to 14 inches. The
                                                                                 ' hydrodynamic testing, in
                                                                           ''t    ' combination with the analysis outlined'in Reference 1,
        +
developed aerodynamic torque coefficients for the subject valves. The results of this combination of testing and analysis was applied to RBS's design conditions to verify.that valves 1HVR*A0V123, 128, 165, and                                                   i 166 will isolate the containment during the postulated LOCA.
                                                                                                          ~
i t .                             _                                    .-.            _ _ . . _ _ _ . . _ _ _ _ _ _ _ _ . - - _ _ . _ . _ _ - _ - - _ - . .

7 h
ry                                                                              .
F-               - References
: 1. Posi-Seal International, Inc., Seismic and LOCA. Report No.
g 10837SL-001 (SWEC-File No. 4228.241-092-016)
: 2. Posi-Seal-Seismic Report _(SWEC-File No.- 4228.241-092-004)
: 3. ASCO Qualification Report No. AQR67368 (SWEC File No.
6228.241-092-010B).
J
                 , 4. NAMCO Qualification Report for EA740' Limit Switches No.-QTR111 (SWEC
                         -File No. 6228.241-092-008)
                                       ~
   .                 5. Posi-Seal Static Operability Qualification Report No. 10837ST-001
                         '(SWEC File No. 4228.241-092-011)                                       >
f 6
9 Y'
t________.

7---
Attachment 3 SUPPLEMENTAL TECHNICAL JUSTIFICATION

p;; ,                                           ,
1 if'
't t
1 4
                                                    -Estimate of' Required Torque for g                                                    Closure of Posi-Seal Actuators
                                                   . With a 3 psi. Differential Pressure
: 1.      Assumptions:-
i a .'  Bearing, packing end' seal torques will remain the same as
                                       ' calculated-for the 9 psi pressure differential b.-   Compressibility. effects at 'dP of 3 psi ~are smail:
ac . LNonsyme'tric approach flow due to bends and elbows will double the flow torque (reference a).
: 2.       Method:
                                       . Torque due to flow is a function of valve construction, disk
                                 . angle.. fluid density and velocity-and Mach number for compressible.
                                                                           ~
flow. Considering a dP. of 3 psi the compressibility effects will be small thus flow torque will be a function of density and velocity for the same disk angle. Assuming the densities are approximately the same for the 9 psid and'3 psid conditions, then torque is proportional to velocity squared which in turn is proportional to
                                . the pressure drop access the duct.       For conservatism, the flow torque at 3 psid will be multiplied by 2 to account for'non-symetric flow approach and the seal torque which occurs at the no flow condition will be added to the bearing, packing and flow torques for calculating required actuator torque for closure.-
From Appendix B of reference b (values in IN-LBf)                               s Valve          Flow torque       Bearing     Packing;    Seal  . LTorque Required 9 paid 3 paid       torque      torque    torque  for closure at 3 paid A0V 123         3548     2400        1766       1663     10,452          16,281 A0V 128         3419     2300        1766       1663     10,452          16,181 A0V 165         3415-    2300        1766       1663     17,420          23,149 A0V 166         3415     2300        1766       1663     17,420          23,149

==Reference:==
a) Attachment #4 to NRC letter 12/21/82 b) Posi-Seal Report 10837SL-001

  ^,
Attachment 4 PURGE VALVE QUALIFICATION REPORT 4
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