3F0386-11, Forwards Addl Info to Support Util Justification for Six Exceptions to Reg Guide 1.97 Items,Including Pressurizer Level,Pressurizer Heater Status & Safety/Relief Valve Positions,Per 851115 Commitment
| ML20140F858 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/27/1986 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 3F0386-11, 3F386-11, NUDOCS 8604010195 | |
| Download: ML20140F858 (8) | |
Text
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ge Florida Power C O R PO R AT TON March 27, 1986 3F0386-11 Director of Nuclear Reactor Regulation Attention:
Mr. John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NUREG-0737, Supplement 1 Regulatory Guide 1.97
Dear Sir:
Nuclear Regulatory Commission (NRC) letter dated October 24, 1985 (3N1085-12) requested additional information to support Florida Power Corporation's (FPC) justification for six (6) exceptions to Regulatory Guide 1.97 items p reviously submitted.
FPC provided partial responses to the six (6) items in letter dated November 15, 1985 (3F1185-17), and stated additional responses would be submitted by April 1,
1986.
This letter provides the additional responses stated in FPC letter dated November 15, 1985 (3F118E-17).
Item 1 Pressurizer Level - the licensee should provide additional analyses to support the deviation from the recommended range (Section 3.3.10).
Response 1 The B&W Owners Group (BWOG) response has been received, and FPC has reviewed the BWOG response and concurs.
Compliance Table, page 26, has been revised in accordance with the BWOG response, and a copy (Attachment 1) is attached.
the licensee should provide the Item 2 Pressurizer heater status instrumentation recommended by Regulatory Guide 1.97 (Section 3.3.11).
nd 8604010195 860327 l
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GENERAL OFFICE 3201 Thirty fourth Street South.P.O. Box 14042, St. Petersburg, Florida 33733 813-866-5151
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3 March 27, 1986 3F0386-11 Page 2 Response 2 The BWOG response has been received.
FPC has reviewed the BWOG response and concurs.
Compliance Table, page 27, has been revised in accordance with the BW0G response, and a copy (Attachment 2) is attached.
Item 3 Safety / relief valve positions or main steam flow - the licensee should install instrumentation to nonitor safety / relief valve position or main steam flow (3.3.14).
Response 3 On re-examining our position on " Main Steam Safety / Relief Valve Position", FPC plans to install monitcring instrumentation to comply with the requirements of Regulatory Guide 1.97, Rev. 3.
A revised copy of page 33 ( Attachment 3) is attached.
Please note that the schedule for installation of this instrumentation is Refuel 7 outage, December 1989.
Item 4 No further response required.
Item 5 No-further response required.
Item 6 Noble gas from the steam generator safety / relief valves for atmospheric dump valves - the licensee should provide additional justification for this deviation (Section 3.,s.22).
Response 6 Two of the four main steam line monitors, namely RM-C25 and RM-G28, are presently being relocated to monitor dischsrge of the atmospheric dump valves.
A revised copy of page 47
( Attachment 4) is attached.
In FPC letter dated Novembe 19, 1985 (3F1185-22), we stated that the completion schedule was March 31, 1986. Due to the recent late delivery of the required calibration cables, the completion date for installation and calibration is June 1,1986.
Sincerely, a
G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management 1
i EMG/feb I
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i ATTACHMENT 1 Paga 26 (Sh:et 1 of 2)
R2 vision 1 Date: 3/24/86 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Pressurizer Level TYPE & CATEGORY:
D1 RANGE:
.CR-3 0-320 inches, see position NRC Top to bottom ENVIRONMENTAL QUALIFICATION:
No, will comply I
SEISMIC QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUNDACY:
No, will comply 2 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & E0F SCHEDULE:
New transmitter will be installed by end of Refuel V.
Other upgrades to be complete by end of Refuel VI.
POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
The pressurizer level was sized based on the following.
The water volume is chosen such that the reactor coolant system can experience a reactor trip from full power without uncovering the level sensors in the lower shell and to maintain system pressure above the HPI system actuation set-point. The steam volume is chosen such that the reactor coolant system can experience a turbine trip without covering the level sensors in the upper The range of 0-320" H O was based on this criteria and setpoints shell.
2 for automatic or manual actions are based on this range.
The pressurizer is approximately 512 inches tall. The 0 inch reference for the p(ressurizer level instrument range is 43 inches above the lower datum line. approx. 96 inches from the bottom),16 inches below the upper set of heaters, and approximately at the level of the second set of heaters. The upper pressurizer level top (320 inches above the 0 inch reference) is 43 inches below the upper datum (approx. 92 inches from the top), and approxi-mately 37 inches from the spray head.
Bitler(R01)C4-2
Page 26A ATTACHMENT 1 Revision 1 (Sheet 2 of 2)
Date: 3/24/86 The Accident Analysis chapters of several B&W Owners Group Utility Final Safety Analysis Reports (SAR), as well as Part II, Volume 2 of the B&W Own-ers Group Abnormal Transient Operating Guidelines ( AT0G) were reviewed to obtain pressurizer level responses to anticipated transients and accidents.
For anticipated transients such as decreasing feedwater temperature, exces-sive main feedwater flow, loss of main feedwater flow, decreasing steam flow, small steam leaks, loss of external load, loss of off-site power, loss of condenser vacuum and small steam generator tube leaks, the existing ranges for the pressurizer level are sufficient such that indicated level should remain on-scale.
For severe transients (accidents) such as steam line break, steam generator tube rupture and many small break LOCAs, the pressurizer voids.
Following SFAS actuation of the HPI system, actions can be taken as necessary to stabilize the plant.
Those actions are based on subcooling margin and RCS p ressu re, not pressurizer level.
For the case of a total loss of feed-water, the pressurizer will go solid unless either main or emergency feed-water is restored to the steam generators within about 15 minutes. Actions taken are dependent on when feedwater is restored, subcooling margin and RCS pressure, not pressurizer level.
In general, for severe transients or accidents, the pressurizer will either void or go solid.
A voided pressurizer will cause indicated level to go off-scale low followed by a rapid decrease in RCS pressure to saturation.
A solid pressu rizer will cause indicated level to go off-scale high accompanied by high RCS pressure, possible large and rapid changes in RCS pressure, PORV and pressurizer safety valve actuation.
All of these indi-cations are available in the control room.
Based on this information, the existing ranges of pressurizer level indica-tion are sufficient for anticipated transients.
For severe transients or accidents, indicated pressurizer level will go off-scale high or low due to the pressurizer going solid or voiding and, as a result, top to bottom instruments would provide no significant additional information.
In these cases, subcooling margin, RCS pressure, PORV status and pressurizer safety valve status are monitored to determine actions to be taken.
Bitler(R01)C4-2
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ATTACHMENT 2 Pag 2 27 (Sheet 1 of 2)
R3 vision 1 Date: 3/24/86 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Pressurizer Heater Status TYPE & CATEGORY:
D2 RANGE:
CR-3 On-off lights, see Position NRC Electric Current ENVIRONMENTAL QUALIFICATION:
No, will comply SEISNIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, not required POWER SOURCE:
No, not required DISPLAY:
On-off heater lights in CR, will comply SCR failure alarm in CR Group overcurrent alarms in CR Breaker open alarms in CR SCHEDULE:
Upgrades will be complete by end of Refuel VI POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
Pressurizer heater control utilizes several banks of heaters including redundant, 126 kW ba-ks of emergency pressurizer heaters which are con-trolled in an on-off mode and one bank of heaters which is modulated to produce a proportional output that increases as pressure decreases from setpoint.
Since the control of the two emergency pressurizer heater banks is either "on" or "off" and not by modulating the current to them, an on-off indication of the heater status is appropriate.
RCS pressure can be monitored to determine the effectiveness of the heaters to maintain system pressure.
Bitler(R01)C4-2
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age 27A ATTACHMENT 2 Revision 1 (Sheet 2 of 2)
Date: 3/24/86 Regarding Diesel Loading For loading the emergency heaters onto the diesels, the operator has indi-cation of existing loads on the diesels in order to determine whether,he can load the heaters without overloading the diesels.
Once he has loaded the heaters onto the diesels, then the operator has indications including heater overcurrent alarms, breaker status and breaker alarms in addition to or in lieu of heater current indication for information to prevent contin-
'ued overloading of the diesels.
Regarding Technical Specifications Technical specifications applicable to B&W-designed plants do not in gen-eral require the measurement of pressuri zer heater current.
The CR-3 Standard Technical Specification 3.4.4.C requires that at least 126 kW of pressurizer heaters be available in order that the pressurizer be oper-able.
Surveillance Specification 4.4.4.2 states that the emergency power supply for pressurizer heaters shall be demonstrated operable at least once per 18 months by manually transferring power from the normal to the emergency power supply and energizing the heaters. There is no requirement that emergency pressurizer heater current be measured quarterly.
Should measurements be performed by the utility as part of its surveillance pro-cedure on the pressurizer heaters, there is no requirement that the current flow be measured using instrumentation in the control room available to the operator for post-accident monitoring. Many other types of instrumentation are available for such measurement.
i 1
r Bitler(R01)C4-2
Pagn 33 ATTACHMENT 3 Revision 1 Date: 3/25/86:
CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Main Steam Safety Relief Valve Position TYPE & CATEGORY:
D2
' RANGE:
CR-3 Closed - not closed NRC Closed - not closed ENVIRONMENTAL QUALIFICATION:
Yes, will comply SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, will comply REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in Control Room SCHEDULE:
Refuel 7, December 1989 POSITION:
Equipment will be installed to indicate Main Steam Safety Relief Valve Position.
The installation will include equipment to establish the magnitude of release of radioactive material from the secondary coolant system during accident conditions.
Bitler(R01)C4-2 i
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ATTACHMENT 4 Pagn 57 Ravision 2 Date: 3/25/86 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Vent from Safety Valves or Atmospheric Dump Valves (Main Steam Line Radiation Monitor) - See position.
TYPE & CATEGORY:
E2 3
RANGE:
CR-3 10-2 to 10 gci/cc Xe-133 NRC 10-1 to 103 ci/cc (and duration of release in second mass of steam per unit time).
ENVIRONMENTAL QUALIFICATION:
Yes, see position.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
Yes, see position.
REDUNDANCY:
No, not required.
1 each atmospheric dump valve POWER SOURCE:
1E/ Battery Backed DISPLAY:
Indicated in CR, recorded on demand SCHEDULE:
Completed by June 1, 1986 POSITION:
The four 24" main steam headers contain a total of 16 relief valves and 2 atmospheric dump valves.
Each atmospheric dump valve discharge will be monitored for radiation by monitors with readouts in the Control Room. The system will be calibrated in terms if ci/cc Xe-133 in order to comply with NUREG-0737.
Refer to the position on item 33 (page 33) for an evaluation of duration of release and mass of steam per unit time.
This variable is only used during a S.G. tube rupture type accident.
The results of this accident do not create a harsh environment, therefore they meet the environmental qualifications for the normal environment.
Bitler(R01)C4-2