3F0884-07, Forwards Description of How Rev 3 to Reg Guide 1.97, Instrumentation for LWR Nuclear Power Plants to Assess Plant & Environs Condition During & Following Accident, Per Suppl 1 to NUREG-0737.Mods Will Be Implemented by 871231
| ML20095E294 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/21/1984 |
| From: | Baynard P FLORIDA POWER CORP. |
| To: | Rivenbark G Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 3F0884-07, 3F884-7, NUDOCS 8408240155 | |
| Download: ML20095E294 (85) | |
Text
-.
Power COAPOAAYBON August 21,1984 3F0884-07 Director of Nuclear Reactor Regulation
' Attention: Mr. George W. Rivenbark, Acting Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NUREG-0737, Supplement i Regulatory Guide 1.97
Dear Sir:
In accordance with the NRC order dated February 21, 1984 confirming Florida Power Corporation's (FPC's) commitment to Supplement I of NUREG-0737,
" Requirements For Emergency Response Capability", FPC is submitting the report required by item 3 of the implementation schedule describing how the Regulatory Guide 1.97 (RG 1.97), " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following An Accident" Rev. 3, dated May 1983. Requirements have been or will be met. Deviations from or alternatives to RG 1.97 have supporting justification.
The details of this report have been compiled in accordance with Section 6.2 of Supplement 1 of NUREG-0737 and are based on the events for which Crystal River Unit 3 was licensed.
The responses contained in this report represent FPC's evaluation and interpretation of RG 1.97 variables as they apply to our existing current design basis criteria. Assistance for the justifications for some variables was provided by participation in the "B&W Owners Group RG 1.97 Task Fc.ce" and from outside consultants.
B408240155 840821 PDR ADOCK 05000302 F
PDR i
General Office 3201 Thrty fourin street soutn. P.O. Box 14042, St. Petersburg. Florda 33733 e 81%-866-5151 e
August 21,1984 3F0884-07 Page 2 This comprehensive report includes schedules and proposed modifications. The estimated cost for the implementation of these proposed modifications is in excess of $5 million dollars.
These modifications are scheduled to be completed by December 31, 1987. We will advise you of any significant schedule delays as they occur for implementation of the modifications as identified in this report. An update of this schedule will be included in the annual April schedule updates for the NUREG-0737, Supplement 1 items.
Sincerely, A
at*T' P. Y. Baynard Assistant to Vice President Nuclear Operations EMG/ddl Attachments
_ _ _A
J F
CRYSTAL ~ RIVER 3 r
REGULATORY GUIDE 1.97 POSITION DOClMENT M-4
' I.
INTRODUCTION I
Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability (Generic Letter No. 82-33), dated December 17, 1982 required Florida Power ' Corporation (FPC) to submit a report describing how' it meets the requirements of Regulatory Guide 1.97 (Rev. 2) including supporting technical justification or alterna-4 tives for any proposed deviations.
As stated in the cover letter to, and sections 6.1.B 'and' 6.2 of Supplement 1 to NUREG 0737, FPC is -using the referenced document as guidance.
This allows FPC the flexibility tt tailor the guidance given to the specific requirements of Crystal River 3 and.to take exception to some -of the requirements as long as deviations are shown and supporting justification or alternatives are provided.
This document provides the requested information and is organized 4
to be consistent with Table 3 (PWR Variables) of R.G.1.97, (Rev.
=
3).
Revision 3 of the Regulatory Guide was used as opposed to Revision 2; to more accurately reflect the current NRC guidance on post-accident monitoring.
1 i
II. FORMAT l
Each page of the Compliance Table is devoted to a single R.G.1.97
)
variable and a comparison of its present status at CR3 to the guidance given in R.G.1.97, Rev.1.
i On the Compliance Table, where certsin requirements are not applic-able to a particular variable due to its assigned category and therefore those requirements are not met, a response of "No, not required" will be found for that requirement.
If CR3 meets the requirement, regardless of whether or not it's required by its assigned category, a response of "Yes, Complies" will be found.
4 For each variable, the following heading and contained information i
j will be found on the Compliance Table.
A.
VARIABLE This is the name of the variable as found in R.G.1.97.
If a l
di fferent nomenclature is utilized ' at CR-3, it will be contained in parenthesis.
RegGuide(Pos. Doc.)ND48-3 '
7 4
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...,._,_%,m m,, -,%,-w..n w..-~m.-g,
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1 B.
TYPE AND CATEGORY The _ variables : identified are divided -into 5 types in accor-L dance with Regulatory Guide 1.97.' The definition of each type is as follows:
l-1.
Type A.-- Those variables which provide the primary Information required to permit the control room operators j
to take specific manual actions for which no automatic i
control is provided, and that are required for a safety system to accomplish its safety function for design basis accidant scenarios.
Type A variables are not specified in Regulatory Guide 1.97.
They are plant specific and must be selected based on a review of Emergency Operating Procedures to identify information essential for the direct accomplishment of specified safety functions.
As a result of a review of the CR3 Emergency Operating Procedures, the following variables were identified as Type A:
RCS Hot Leg Temperature RCS Pressure Borated Water Storage Tank Level
{
Steam Generator Level Steam Generator Pressure 2.
Type B - These variables provide information to indicate wnetner plant safety functions are being accomplished.
Plant safety functions are defined as:
reactivity control, core cooling, maintaining reactor coolant system integrity, and maintaining containment integrity.
3.
Type C - These variables provide information to indicate the potential for breach or the actual breach of barriers to fission product release.. The barriers are defined as:
fuel cladding, primary coolant pressure bounda ry, and containment.
4.
Type D - These variables provide information to indicate the operation of individual safety systems and other important systems.
These variables help the operator make appropriate decisions in using the individual systems in mitigating the consequences of an accident.
5.
Type E - These variables provide infomation for use in detemining the magnitude of the release of radioactive materials and for use in assessing the consequences of such releases.
I RegGuide(Pos. Doc.)ND48-3 1
(
The -variable type ~ 1isted on the Compliance Table is in accor-dance with Table 3 of Regulatory Guide 1.97.
In accordance with Regulatory Guide '1.97 'each variable is
. assigned to one of three separate categories that provide a graded approach to the requirements depending on the safety importance of the measurement of a specific variable.
! Category 1 provides the most stringent requirements and is intended for key variables.
Category. 2 provides less strin-gent requirements and generally applies to instrumentation designated for indicating system operating status.
U Category 3 is intended to provide requirements that will ensure that high-quali ty off-the-shelf instrumentation -is obtained and applies to backup and diagnostic instrumenta-tion.
It is also used where the state of the art will not support requirements for higher qualified instrumentation.
1 The category listed for each variable in the Compliance Table is the category assigned by FPC.
Generally, this is the same category as listed in Regulatory Guide 1.97.
If however FPC has determined that a particular variable is not a key vari-able or other less stringent requirements better apply, then a note is added referencing to the FPC position, where justi-fication is supplied for the category change.
C.-
RANGE The ranges listed in the Compliance Table are the actual measurement range of the variable at CR3 and the range recom-mended by the Regulatory Guide.
If the range varies from that i
stated in the Regulatory Guide, a note is added referencing to
}-
FPC's position where justification is supplied for the exist-
)
ing range.
In those cases where the existing range varies j
from the Regulatory Guide and FPC intends to upgrade to the l
regulatory guidance, a note is added stating that the range will comply.
In some instances, the Regulatory Guide states i
the range in tenns of a percentage of the design.
In these cases, the design basis is listed next to the range in parenthesis.
D.
ENVIRONENTAL QUALIFICATION A response of "Yes, Complies" on the Compliance Table indi-cates that the currently installed equipment meets the requirements of IE Bulletin 79-01B and 10 CFR 50.49.
Thi s determination was based on either having actual environmental 4
qualification documentation available or documentation on similar equipment available.
f RegGuide(Pas. Doc.)ND48-3 3 i
. _..,.. -, -,. ~,,. -.,
w
For Category 2 variables, FPC considers existing installed instrumentation located in a mild environment to be adequate for Regulatory Guide 1.97 Category 2 variables. FPC also con-siders' portions of the Non-nuclear. Instrumentation (NNI) adequate for Category 2 variables and has the following position:
For strings which include hardware located in a harsh environ-ment, portions in the harsh environment (sensors, cabling,
' terminations) should be qualified for the accident tempera-ture, pressure, humidity, radiation and chemical environment..
Hardware' located in a mild environment (cabling, terminations, processing modules, power supplies, indicators and recorders) is adequate as currently installed.
The basis for this position is as follows:
The Category 2 qualification requirements of Regulatory Guide 1.97, Rev.
3, include no specific provision for seismic qualification.
We interpret this to mean that environmental qualification only is required.
Since 10CFR50.49 does not require environmental qualification for equipment located in a mild environment, only those components listed in a harsh environment need be qualified.
The currently installed NNI equi pment was not supplied as safety related equipment but is comparable in quality and reliability to existing safety related equipment.
In fact, some of the NNI electronic modules are identical to those qualified and supplied for these safety related systems.
Operating experience with the NNI indicates that this instrumentation can reasonably be expected to be operable for accident monitoring.
Category 2 instrumentation is not required to be seismically qualified, redundant, physically and electrically separated nor powered from a 1E source.
The existing NNI hardware located in a mild environment is consistent with the Cate-gory 2 criteria and no substantial improvement in reliability or safety would be expected if this equipment were replaced with new, qualified hardware.
For those instruments which are not now installed or for which proper documentation does not currently exist but is required for compliance, either documentation will be generated or the equipment will be replaced.
This is indicated on the Coupli-ance Table by a response of "No, Will Comply".
Other responses are self explanatory.
l RegGuide(Pos. Doc.)ND48-3 I
)
s E.
SEISMIC QUALIFICATION A response of "Yes, Complies" on the Compliance Table indi-cates that the entire instrument string is seismically quali-fled in accordance with Regulatory Guide 1.100. For equipment which 'is not presently installed or where only a portion of the instrtment string is seismically qualified and must be l
upgraded, a response of "No, Will Comply" will appear on the Compliance Table. Other responses are self-explanatory.
F.
QUALITY ASSURANCE A response of "Yes, Complies" on the Compliance Table indi-cates that Quality assurance requirements meeting CR3's licensing commitments as documented in the FSAR Section 1.6 i
were applied to at least the safety-related portions of the instrinent string.
In instances where new equipment is being installed or existing equipment upgraded to the above require-ment, a response of "No, Will Comply" will appear.
All other responses are self-explanatory.
G.
REDUNDANCY A response of "Yes, Complies" indicates that redundant chan-nels are available up to and including any isolation device and that the channels are both electrically independent and physically separate from each other, in accordance with IEEE Standard 279-1971, and meet single failure criteria.
A response of "No", indicates that even though more than one channel may be available as shown, they do not meet the above requirements.
"Will Comply" indicates that the existing channels will be
',/
upgraded to comply with the above requirements, or new equip-ment will be installed to those requirements.
H.
POWER SOURCE The power source for the instrument string listed on the
/
Compliance Table is in compliance with the Regulatory Guide
/
requirements unless otherwise noted.
/
I.
DISPLAY Under this heading on the Compliance Table is how the variable is indicated and/or recorded in the Control Room (CR).
This is in compliance with the regulatory guidance unless otherwise l
indicated that it "Will Comply".
RegGuide(Pos. Doc.)ND48-3 If the variable is available on-demand in the Technical Support Center (TSC) or the Emergency Operating Facility (E0F)
'it will be so stated.
J.
SCllEDULE This area of the Compliance Table indicates when the upgrades (if required) will be complete.
Refuel V is scheduled to be complete by August 1985 and Refuel VI in 1987.
K.
POSITION In this area of the Compliance Table will be Florida Power Corporation's position on a particular variable which will include any justifications which are required along with any comments or clarifying remarks which may be needed.
If the justification presented is justification developed by the Babcock & Wilcox Owners Group (BWOG) Regulatory Guide 1.97 Task Force, it will be so stated.
4 5
4 RegGuide(Pos. Doc.)ND48-3 -__
TABLE OF CONTENTS VARIABLE PAGE Neutron Flux 01 Control Rod Position 02 RCS Soluble Boron Content 03 RCS Hot Leg Water Temperature 04 RCS Cold Leg Water Temperature 05 RCS Pressure 06 Reactor Vessel Level 07 Degrees of Subcooling 08 Containment Sump Water Level (Narrow Range) 09 Containment Water Level (Flood Range) 10 Containment Isolation Valve Position (Manual Valves) 11A Containment Isolation Valve Position (Automatic Valves) 11B Core Exit Temperature 12 RCS Radioactivity Concentration 13 Containment Hydrogen Concentration 14 Containment Pressure 15 RHR System Flow (Decay Heat) 16 RHR Heat Exchanger Outlet Temperature (Decay Heat) 17 Accumulator Tank Level (Core Flood Tank) 18A Accumulator Tank Pressure (Core Flood Tank) 18B Accumulator Isolation Valve Position (Core Flood Tank) 19 Boric Acid Charging Flow 20 Flow in HPI System 21 F1ow in LPI System 22 Refueling Water Storage Tank Level (Borated Water Storage Tank) 23 Reactor Coolant Pump Status 24 Primary System Safety Relief Valve Position or Flow Through 25 or Pressure in Relief Lines Pressurizer Level 26 Pressurizer Heater Status 27 Quench Tank Level (Reactor Coolant Drain Tank) 28 Quench Tank Temperature (Reactor Coolant Drain Tank) 29 Quench Tank Pressure (Reactor Coolant Drain Tank) 30 Steam Generator Level 31 Steam Generator Pressure 32 Main Steam Safety Relief Valve Position 33 Main Feedwater Flow 34 Auxiliary Feedwater Flow 35 Condensate Storage Tank Water Level (Emergency Feedwater Tank) 36 Containment Spray Flow 37 Heat Removal by the Containment Fan Heat Removal System 38 Contair; ment Atmosphere Temperature 39 Contaiament Sump Water Temperature 40 Make-up F1ow - In 41 Letdown Flow - Out 42 Volume Control Tank Level (Makeup Tank) 43 Component Cooling Water Temperature to ESF Systems 44 Peck (TblCont)DN104-2
TABLE OF CONTEllTS (Cont'd)
VARIABLE' PAGE' Component Cooling Water Flow to ESF Systems (Level) 45 High-Level Radioactive Liquid Tank Level 46 Radioactive Gas Hold-up Tank Pressure (Waste Decay Tanks) 47 Emergency Ventilation Damper Position 48 Status of Standby Power 49 Containment Area Radiation - High Range 50 Radiation Exposure Rate Inside Buildings or Areas Where 51 Access is Required to Service Equipment Important to Safety or which are in Direct Contact with Primary Containment where Penetrations and Hatches are Locates Containment or Purge Effluent, Noble Gas 52 Reactor Shield Building Annulus 53 Auxiliary Building, Noble Gas 54 Condenser Air Removal System Exhaust 55 g
Common Plant Vent 56 Vent from Safety Valves or Atmospheric Dump Valves 57 All Other Identified Release Points 58 All Identified Plant Release Points Particulates and Halogens 59 Airborne Radio Halogens and Particulates 60 Plant and Environs Radiation, Portable Instrumentation 61 Plant and Environs Radioactivity 62 Wind Direction 63 Wind Speed 64 Estimation of Atmospheric Stability 65 Primary Coolant and Sump (Grab Sample) - Gross Activity 66 Primary Coolant and Sump (Grab Sample) - Gansna Spectrum 67 Primary Coolant and Sump (Grab Sample) - Boron Content 68 Primary Coolant and Sump (Grab Sample) - Chloride Content 69 Primary Coolant and Sump (Grab Sample) - Dissolved Hydrogen 70 Total Gas Primary Coolant and Sump (Grab Sample) - Dissolved Oxygen 71 Primary Coolant and Sump (Grab Sample) - pH 72 Primary Coolant and Sump (Grab Sample) - Hydrogen Content 73 Containment Air (Grab Sample) - 0xygen Content 74 Primary Coolant and Sump (Grab Sample) - Gamma Spectrum 75 Peck (TblCont)DN104-2
Pagn 01 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Neutron Flux TYPE & CATEGORY:
B1 RANGE:
CR-3 Source Int Power 10-8 to 10-2 10-4 to 10 1 to 125%
NRC-10-6 to 100%
ENVIRONMENTAL QUALIFICATION:
Power range only, will comply SEISMIC QU ALIFICATION:
No, will comply QUALITY ASSURANCE:
Yes, comnlies
-REDUND ANCY :
No, wi'll comply 2 channels POWER SOURCE:
1E, complies DISPLAY:
Indicated and recorded in CR, will comply On demand in TSC & E0F SCHEDULE:
Upgrades complete by end of Refuel VI, see position.
POSITION:
Power range detectors environmentally qualified per B&W Report 10003.
Further ' qualification not required per Section A12, Suppl. No. 2 of Bulletin 79-01B.
System 1E from detectors up to and including NI&P cabinets. Wiring to con-trol panel, and control panel ICS section not seismically qualified with QA.
QA Requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
By the end of Refuel V, one channel of a Gamma-Metric system will be installed for Remote Shutdown.
By the end of Refuel VI a second channel will be installed, with both channels indicated in the control room and meeting all the requirements of Reg. Guide 1.97.
l Peck (Comp)DN104-2
I t
Pagg 02 l
CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COWLIANCE TABLE t
VARIABLE:
Control Rod Position i.
l TYPE & CATES 0RY:
B3
}-
RANGE:
'CR-3 0-100%, Full-in/ Full-out, Avg group L
Lights Position NRC Full-in or not Full-in ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QU ALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS DISPLAY:
Indicated in CR Avg group position, on demand in TSC & E0F SCHEDULE:
Installed POSITION:
Complies t
Peck (Comp)DN104-2 l
Page 03 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COPFLIANCE TABLE VARIABLE:
RCS Soluble Boron Content TYPE & CATEGORY:
B3 RANGE:
.CR-3 0-6000 ppm NRC 0-6000 ppm ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QU ALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
1E/DG DISPLAY:
In laboratory only, need not comply SCHEDULE:
Installed POSITION:
Complies The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
The manual sampling and laboratory analysis is sufficient to meet the intent of Regulatory Guide 1.97, Rev. 03.
This is based on the fact that the loss of negative reactivity due to xenon decay is sufficiently slow that the control room operator need not know instantaneously or continu-ously what the boron conctntration is in the RCS.
Also,Section II.B.3 of NUREG-0737 requires that capability exists to sample and analyze the reactor coolant in a post-accident environment.
Peck (Comp)0N104-2 L.
Page 04 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RCS Hot Leg Water Temperature TYPE & CATEGORY:
A,B 1 RANGE:
CR-3 120* to 920*F, see Position NRC 50* to 700*F ENVIRONMENTAL QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, will comply 2 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Upgrades will be completed by end of Refuel VI POSITION:
RCS Hot Leg Water Temperature is a key variable for monitoring the core cooling safety function.
It is used with RCS pressure to nonitor the status of the RCS with respect to saturation and subcooled margin limits.
It is used with Core Exit Temperature to verify natural circulation and to identify loss of natural circulation.
It can also be used with Steam Gen-erator Pressure to veri fy coupling between the RCS and the Secondary System.
The RCS hot leg temperature range does not envelope the lower end of the Reg. Guide 1.97 recommended range, however the existing range is acceptable based on the following:
1.
At temperatures less than 280*F, the plant will be in the Decay Heat Removal mode and this temperature is not required.
2.
Cold Shutdown is defined in the Technical Specification as less than 200*F.
3.
RCS cold leg temperature range will indicate down to 50'F.
Peck (Comp)0N104-2
f; Pag 2-04A RTD's will be replaced.if necessary to meet EQ requirements. Cable used 'in
~
containment is qualified pending resolution of some outstanding questions.
'Only RTD's and indicators are safety related, seismically mounted, and redundant.
Instrument string will be upgraded to meet requirements.
.i I
i l
Peck (Comp)DN104-2
Page 05 CRYSTAL RIVER 3' REGULATORY GUIDE 1.97-
-COMPLIANCE ~ TABLE-l VARIABLE:
RCS Cold Leg Water Temperature
- TYPE A CATEGORY:
B 3,.see Position RANGE:'
CR-3 50' to L650'F, see Position NRC 50' to 700*F ENVIRONMENTAL' QUALIFICATION:
No, need not comply SEISMIC QUALIFICATION:~
No, need not comply QUALITY' ASSURANCE:
No, need not comply REDUNDANCY:
No, need not comply 2 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
The following position is a justification' developed by the BWOG Reg. Guide 1.97 Task Force.
Reg. Guide 1.97 lists cold leg water temperature as a Category 1 (key) variable and core exit temperature as a Category 3 (backup) variable for the core cooling function.
Cold leg temperature indication may not in all cases provide valid information on the status of core cooling. Since. it is located in the RCS loops and not. the reactor vessel, there must be either forced or natural circulation flow through the steam generators for indi-cations to be representative of actual core conditions.
Also, due to the proximity of the cold leg RTD's to the HPI nozzles, HPI flow may signifi-cantly affect the cold leg temperature indication particularly in the absence of forced RCS flow.
Incore temperature monitors provide a more direct' indication of core cooling independent of whether ~ or not there exists coolant flow through the loops.
The key variables for monitoring the core cooling plant safety function.are RCS Hot Leg Water Temperature, Core Exit Temperature, and Steam Generator Presure (see Discussion section for RCS Hot Leg Water Temperature).
RCS Cou Leg Water Temperature is a backup-temperature monitor to _the RCS Hot Leg Water Temperature and Core Exit Temperature.
Peck (Comp)DH104-2 s-
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,_.-m,
Page 05A 1
For-these reasons, core exit temperature and RCS Hot Leg are the key vari-ables for monitoring core cooling and are qualified to Category I require-ments while RCS cold leg temperature serves as a backup variable and is qualified to Category 3 requirements accordingly.
The CR-3 ~ range of 50 to 650 F is based on providing the capability of the RCS Cold Leg Water Temperature instrumentation to measure a value greater than the saturation temperature for the steam generators, which is approxi-mately 500*F (based on 1050 psig design pressure).
650*F for the high end of the range provides 15% excess measurement capability and is approximate-ly 110% of the design temperature of 600*F.
The low end of the range, 50*F, allows for measurement of the variable during conditions where the DHRS or LPI system is not in use or available and the steam generators are removing decay heat.
L l
Peck (Comp)DN104-2
l Page 06 CRYSTAL RIVER 3 t
REGULATORY GUIDE 1.97 COMPLIANCE TABLE f
VARIABLE:
RCS Pressure TYPE & CATEGORY:
A,B,C 1 RANGE:
CR-3 0-2500 psig, will comply NRC 0-3000 psig ENVIRONMENTAL QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
1E/DG i
DISPLAY:
Indicated and recorded in CR l
On demand in E0F & TSC SCHEDULE:
Equipment. Qualification upgrades complete by end of Refuel V, other upgrades complete by end of Refuel VI.
l POSITION:
Portion of the instrument loop from the ES test cabinet to the control board were not installed to Class 1E requirements.
These portions will be upgraded.
RCS pressure transmitters being replaced during Refuel V.
New transmitters meet RG 1.89 requirements (IE and environmental qualification).
l Peck (Comp)DN104-2
Page 07 CRYSTAL RIVER 3 REGULATORY GUIDE'1.97 COMPLIANCE TABLE.
L VARIABLE:
Coolant Inventory (Reactoa Vessel Level) l l
TYPE & CATEGORY:
B1 l
I:
RANGE:
CR-3 Bottom of. hot leg to top of hot leg Bottom of hot leg to top of vessel NRC Bottom of hot leg to top of vessel l
ENVIR0 MENTAL QUALIFICATION:
No, wi11 comply _
SEISMIC QUALIFICATION:
No, wi_ll comply QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, will comply 2 channels POWER SOURCE:
No, will comply DISPLAY:
No, will comply SCHEDULE:
To be completed by end of Refuel V l
l POSITION:
Ref:
The NRC's evaluation of CR-3's response to NUREG-0737. Item II.F.2, Docket No. 50-302, dated 9/6/83.
Reactor vessel and hot leg level, including reactor coolant pump monitors to detect voids in coolant is being implemented to satisfy NUREG-0737, Item II.F.2.
l l
Peck (Comp)DN104-2
r Pag 2 08 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 C0WLIANCE TABLE VARIABLE:
Degrees of Subcooling
- TYPE & CATEGORY:
B2 RANGE:
CR-3
+ 658*F NRC.
YOO*F subcool to 35*F superheat ENVIRONMENTAL QUALIFICATION:
Yes, temperature transmitter being evaluated to 79-01B SEISMIC QU ALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies 1E power supply, but wiring not safety related from vital bus.
l QA requirements meeting CR-3 licensing comitments were applied to the safety-related portions of this instrument string.
l l
l l
Peck (Comp)DN104-2
_Page 09 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 L COMPLI ANCE TABLE.
- V ARI ABLE:
-Containment Sump Water Level (Narrow Range)'
TYPE & CATEGORY:
B,C 2 lANGEi CR-3.
.0-10 ft.
R NRC Sump I
ENVIRONMENTAL j
QUALIFICATION:
.Yes, complies i-SEISMIC i
QUALIFICATION:
-Yes, complies QUALITY ASSURANCE:
Yes, complies
.t REmjND ANCYi Yes, complies i
2 channels POWER SOURCE:
UPS/DG with 1E standby DISPLAY:
Indicated and recorded in EFIC room On demand in TSC & EOF i
SCHEDULE:
Installed 1
POSITION:
Complies I
j Ref: Safety Evaluation Report, Docket No. 50-302. dated January 13, 1984 t
Due to lack of space in the Control Room, the indicators and recorder are y
located in the Emergency Feodwater Initiation and Control -(EFIC) Room.. The NRC 'in the above referenced SER found that this location adequately l
]
satisfies the requirements of NUREG-0737, Item II.F.1.5.
i l
i i
i Peck (Comp)DN104-2 i
J
Page 10 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Sump Water Level (Flood Level)
-TYPE & CATEGORY:
B,C 1 RANGE:
CR-3 0-10 ft. above sump NRC Plant specific.
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies
-REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
1E DISPLAY:
Indicated and recorded in EFIC room On demand in EOF & TSC SCHEDULE:
Installed POSITION:
Complies Ref:
Safety Evaluation Report, Docket No. 50-302 dated January 13, 1984 Due to lack of space in the Control Rcom, the indicators and recorder are located in the Emergency Feedwater Initiation and Control (EFIC) Room. The NRC in the above referenced SER found that this location adequately satisfies the requirements of NUREG-0737, Item II.F.1.5.
i Peck (Comp)DN104-2 l
Page 11A CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Isolation Valve Position (Manual Valves)
TYPE & CATEGORY:
B1 RANGE:
No indication, need not comply ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A l
POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
Locked / closed valves or blind flanges may be used in lieu of automatic valves. Ref. SRP-6.2.4-6F and NUREG-0737 Pg. 3-91.
Automatic valves are only mentioned for position indication.
Ref.
SRP-6.2.4-6J.
Therefore, indication not required for locked / closed manual valves.
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Peck (Comp)DN104-2
Page llB CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE j
VARIABLE:
Containment Isolation Valve Position (AutomaticValves)
TYPE & CATEGORY:
B1 RANGE:
CR-3 Open-closed lights NRC Closed-not closed ENVIRONMENTAL QU ALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, need not comply, see position POWER SOURCE:
No, will comply DISPLAY:
Indicated in CR, see Position SCHEDULE:
Upgrades will be completed by end of Refuel VI POSITION:
Redundancy is not necessary on a per valve basis since redundant barriers are provided for all fluid penetrations.
Areas of noncompliance will be upgraded to comply.
Position indication is provided in the Control Room via a light matrix.
This method should be acceptable for monitoring valve positions rather than recording.
Peck (Comp)DN104-2
Page 12 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE
-VARIABLE:
Core Exit Temperature TYPE & CATEGORY:
B,C 1 RANGE:
CR-3 0-900*F, will comply NRC 200* to 2300*F ENVIRONMENTAL
. QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, need not comply, see position POWER SOURCE:
UPS/0G DISPLAY:
Indicated and recorded on demand in CR On demand in TSC & EOF SCHEDULE:
See position.
POSITION:
Ref:
The NRC's evaluation of CR-3 is response to NUREG-0737 Item II.F.2, Docket No. 50-302, dated 9/6/83.
The Core Exit Thermocouples (CETs) are self-powered devices and are con-sidered a single channel.
CETs connected to both safety and nonsafety systens will be isolated prior to the connection with nonsafety systems.
There have been no problems with the existing in-core probe assemblies.
One-half of them have been replaced during the 1983 refueling outage with similar units.
During the next refueling outage, all of the existing in-containment cable for the in-core probe assemblies will be replaced with qualified cable. Also, during future outages, the in-core probe assemblies will be replaced with qualified units.
The primary and backup display channels will be electrically independent, energized from independent power sources, and physically separated in accordance with Regulatory Guide 1.75 up to and including the isolators.
The primary display and computers are not Class 1E, but are energized from a battery backed high-reliability uninterruptible power supply.
The backup display (16 CETs, 4 per Quadrant) and its power sources will be Class 1E.
Peck (Comp)DN104-2
y Page 12A CETs connected only to the plant computer will not be isolated, since they are unpowered.
This variable is being upgraded in accordance with NOREG-0737. Item II.F.2.
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s Peck (Comp)0N104-2 l
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Page 13 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RCS Radioactivity Concentration TYPE & CATEGORY:
C 3 see position RANGE:
CR-3 10-2 to 10-3 ci/gm NRC 1/2 tech spec limit to 100 times tech spec limit ENVIRONMENTAL QUALIFICATION:
Need not comply, see position SEISMIC QUALIFICATION:
Need not comply, see position QUALITY ASSURANCE:
Need not comply, see position i
REDUNDANCY:
Need not comply, see position POWER SOURCE:
1E DISPLAY:
Indicated and recorded in lab only SCHEDULE:
Installed l
l POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
Currently, no instrumentation exists to adequately measure this variable on line.
Existing instrumentation, letdown line radiation monitors, can be used to provide indication of fuel failure during normal operation.
How-ever, since the letdown line is isolated durir.g serious accidents requiring containment isolation, it will not be available for long term neasurement.
Section !!.B.3 of NUREG-0737 requires that capability exist at each plant to san.ple the RCS to assess the nagnitude of fuel failures during post-accident Conditions.
As such, this measurement should be the primary determinant of fuel failure during normal operation ard post-accident.
The letdown line radiation monitor should be used as the initiator for sampling during normal operation because state-of-the-art equipment is unavailable and the primary means of monitoring this variable must therefore be by sampling and analysis.
It is recommended that it be downgraded to Category 3.
Peck (Comp)DN104-2
Page 14 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE V ARI ABLE:
Containment Hydrogen Concentration TYPE & CATEGORY:
C1 RANGE:
CR-3 0-10%
NRC 0-10%
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUND ANCY:
Yes, complies 2 channels POWER SOURCE:
1E DISPLAY:
Indicated and recorded in EFIC room SCHEDULE:
Installed POSIIl0N:
Complies Ref: Safety Evaluation Report, Docket No. 50-302 dated January 13, 1984 Due to lack of space in the Control Room, the Containment Hydrogen Monitor-ing System (CHMS) indicators and recorder are located in the Emergency Feedwater Initiation and Control (EFIC) Room.
The NRC in the above referenced SER found that this location adequately satisfie: the require-ments of NUREG-0737, item II.F.1.6.
Peck (Comp)DN104-2
Page 15 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE V ARI ABLE:
Containment Pressure
~ TYPE & CATEGORY:
B,C 1 RANGE:
CR-3 0-280 PSIA (Design - 55 PSIG)
NRC 10 psia to 3 times design ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QU ALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes,. complies RED'JND ANCY:
Yes, complies 2 channels POWER SOURCE:
1E DISPLAY:
Indicated CR and recorded in EFIC room On demand in TSC & EOF SCHEDULE:
Qualified transmitters with 1E power to be installed by end of Refuel-V POSITION:
Cosp5ies i
l' Ref: Safety Evaluation-Report, Docket No. 50-302 dated January 13, 1984 Due to ' lack of space in the-Control Room, the recorder,, is located in the Emergency Feedwater Initiation and Control (EFIC) ' Room.
The NRC in the above referenced SER found that this location adequately satisfies the requirements of NUREG-0737, Item II.F.1.4.
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Pag 2 16-CRYSTAL RIVER 3
'l REGULATORY GUIDE 1.97
~
COMPLI ANCE TABLE -
'V ARI ABLE:
RHR System' Flow (Decay Heat)
TYPE'& CATEGORY:
D2 RANGE:
CR-3 0-5000 GPM (Design = 3000 GPM)
NRC 0 to 110% Design ENVIRONMENTAL QU ALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS/DG with IE standby DISPL AY:
Indicated in CR On demand in TSC & E0F SCHEDULE:
Installed POSITION:
Complies QA requirements meeting _ CR-3 licensing commitments were applied to safety related portloc.s of this instrument string.
l Peck (Comp)DN104-2 a
Page 17 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RHR Heat Exchanger Outlet Temperature (Decay Heat)
TYPE & CATEGORY:
D2 RANGE:
CR-3 0-300*F NRC 40" to 350*F
- ENVIRONMENTA'_
QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
Indicated in CR SCHEDULE:
Upgrades will be complete by end of Refuel VI POSITION:
Equipment environmental qualification-will be upgraded to meet requirements.
Transmitter with mounting is seismic since pressure boundary to safety system.
QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
Design temperature of the Decay Heat system and heat exchanger for CR-3 is 300*F.
l Peck (Comp)DN104-2
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Pag 18A CRYSTAL RIVER 3
. REGULATORY ~ GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Accumulator Tank Level (Core Flood Tank)
TYPE & CATEGORY:
D2 RANGE:
CR-3 0-14 ft. above datum NRC 10 to 90% Vol.
ENVIRONMENTAL QU ALIFICAYION:
'Yes, complies SEISMIC QUALIFICATION:
No, not rei,uired QUALITY ASSURANCE:
Yes, complies REDUND ANCY:
No, not required 2 channels POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies Range covers 100% of required liquid level.
Volume not covered is for N2 blanket. Meets intent of RG 1.97.
QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
Peck (Comp)DN104-2
Pagn 188 CRYSTAL RIVER 31 REGULATORY GUIDE 1.97 C0WLIANCE TABLE V'ARI ABLE:
- Accumulator Tank Pressure (CoreFloodTank)
I
. TYPE & CATEGORY:
D 3, see position RANGE:
CR-3 0-800 PSIG NRC 0-750 PSIG~
ENVIRONMENTAL
. QU ALIFICATION:
No, need not comply
. SEISMIC
. QUALIFICATION:'
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:-
.No, not required 2 channels POWER SOURCE:
UPS/DG 3
DISPLAY:
Indicated in CR SCHEDULE:
Installed i
POSITION:
Complies The following positio'n is a justification -developed by the BWOG Reg. Guide L
1.97 Task Force.
i QA requirements meeting CR-3 licensing commitments were applied to safety _
related portions of this instrument string.
Core Flood Tank Pressure is a key variable for pre-accident status to assure that this passive safety system is prepared to serve its function.
This-pressure indication provides no essential information for ' operator action during or following an accident.
The key variable necessary to determine whether-the Core Flood Tanks have fulfilled their safety function is Core Flood Tank Level.
Therefore, Core Flood. Tank Pressure is a backup i
- type variable and has been classified as a Category 3 instrument according-ly.
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Peck (Comp)DN104-2 7-
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Page 19 CRYSTAL RIVER 3
/
,/.'
REGULATORY GUIDE 1.97 /
COMPLIANCE TABLE
/
j VARIABLE:
Accumulator Isolation Vi ve Position (Core Flood Tank) p/
TYPE & CATEGORY:
D2
/
RANGE:
CR-3 Closed-open 110' s NRC Closed or ope #
ENVIRONMENTAL
/
QUALIFICATION:
No, will.domply SEISMIC-
/
QUALIFICATION:
Yes,/ complies QUALITY ASSURANCE:
YIs, complies
,! o, not required REDUNDANCY:
N
/
2 channels POWER SOURCE,'
UPS/DG DISPLAY:
/
Indicated in CR SCHEDULE:
Upgrades will be complet y the end of Refuel VI POSITION:
QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
Instrument cable is presently not environmentally qualified.
Areas of noncompliance will be upgraded to comply.
i Peck (Comp)DN104-2
Page 20 CRYSTAL RIVER 3 REGULAT JRY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Boric Acid Charging Flow TYPE & CATEGORY:
D2 RANGE:
N/A ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
The B&W - designed NSSS does not include a charging system as part of the Emergency Core Cooling System (ECCS).
Flow paths from the ECCS to the RCS include high pressure injection (HPI) and low pressure injection (LPI) with the BWST or the RB Sump as the suction source, and the Core Flood Tank injection.
HPI and LPI flow rates are monitored, and BWST, RB sump, and Core Flood Tank levels are monitored by RG 1.97 ~ variables.
Therefore, Boric Acid Charging Flow does not need to be monitored as a Type D variable to monitor the operation of the ECCS.
1 Peck (Comp)DN104-2
Page 21
. CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Flow in HPI System TYPE & CATEGORY:
D2 RANGE:
CR 0-500 GPM (Design = 300 GPM)
NRC 0 to 110% Design ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QU ALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels 3
- POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR On demand in TSC & E0F SCHEDULE:
Installed POSITION:
Complies QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
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Peck (Comp)DN104-2
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Pag: 22 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Flow in LPI System TYPE & CATEGORY:
D2 RANGE:
N/A
-ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A
. QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A' POSITION:
Same instrument as RHR system flow, see page 16.
Peck (Comp)DN104-2
~
Pags 23 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Refueling Water Storage Tank Level (Bor ced Water Storage Tank)
TYPE & CATEGORY:
A,0 1 P.ANGE:
CR-3 0-600 inches NRC Top to bottom ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUND ANCY:
Yes, complies 2 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded on demand in CR, will comply On demand in TSC & E0F SCHEDULE:
Upgrades will be completed by end of Refuel VI POSITION:
QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this in:trument string.
The recorder will be upgraded to comply.
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
B&W's Criteria for BWST (36-3364-02) sets three criteria which must be met by the BWST.
The first criterion is related to fuel handling and transfer operations and is not applicable for accident events. The second criterion requires that sufficient volume be contained in the BWST to provide 20 minutes of injection operation prior to switchover to an alternate source.
This is a criterion which must be satisfied during normal plant operation to ensure availability of the BWST during an accident. This volume is less than that-required to meet the first criterion. The third criterion is the important one for use during and after an accident.
This criterion requires that the BWST level be such that adequate NPSH for all ECCS pumps be available.
Peck (Comp)DN104-2
Pag 2 23A To meet the desired intent of the regulatory guide that accident monitoring instrumentation also be used, to the extent practicable, during normal operations, the existing BWST level -instrumentation has sufficiently wide range to monitor the level required in the BWST by the first criterion. At Crystal River 3, the tank level is monitored from 0 to 50 feet for the first criterion.
A low alarm is provided a 4 feet and switchover is required at 2.5 feet.. Thus, the operator is provided with adequate level indication at-all times.
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1 Peck (Comp)DN104-2 i
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Pags 24 CRYSTAL RIVER 3 -
REGULATORY GUIDE 1.97 COMPLIANCE TABLE
-VARIABLE:
Reactor Coolant Pump Status TYPE & CATEGORY:
D3 RANGE:
CR-3 0-125% load NRC Motor current ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required 1 per pump POWER SOURCE:
OP, complies DISPLAY:
Pump running lights in CR 0-125% load indicted for each pump in CR Indicator for total circuit amps in CR Recorder for total circuit amps in CR On demand in TSC & EOF POSITION:
Complies Peck (Comp)DN104-2
Pag 2 25 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Primary System Safety Relief ' Valve Position or Flow Through or Pressure in Relief Lines
-TYPE & CATEGORY:
D2 RANGE:
CR-3 Acoustic system NRC Closed - not closed ENVIRONMENTAL QU ALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required
_ QUALITY ASSURANCE:
Yes, compiies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR On demand in TSC & E0F SCHEDULE:
Installed POSITION:
Complies Accelerameters are seismically mounted.
Peck (Comp)DN104-2
Pag 2 26 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 SEISMIC QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUNDACY:
No, will comply 2 channels POWER SOURCE:
1E/0G 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 pressurizer 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.
Peck (Comp)DN104-2
Pag) 27 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 SEISMIC
-QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, will comply POWER SOURCE:
No, will comply 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 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 these two 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.
Peck (Comp)DN104-2
Page 28-CRYSTAL ' RIVER 3 REGULATORY GUIDE 1.97-COMPLI ANCE TABLE.
VARIABLE:
Quench Tank Level
-(Reactor' Coolant Drain Tank)
TYPE & CATEGORY:
D3 p
RANGE:
.CR-3 6 inches from bottom to top NRC Top to bottom ENVIRONMENTAL L
QUALIFICATION:
No, not required.
SEISMIC
' QUALIFICATION:
No, not required i
QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
_UPS/DG DISPLAY:
Indicated in CR On demand in TSC & E0F j
SCHEDULE:
Installed I-POSITION:
Co.aplies i
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L Pagm 29 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Quench Tank Temperature (Reactor Coolant Drain Tank)
TYPE & CATEGORY:
D3 RANGE:
CR-3 0 to 150*F, will comply with Position NRC 50* to 750 F ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, 'not required QUALITY ASSURANCE:
No, not required
' REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
On local radwaste panel only, will comply On demand in TSC & E0F 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.
The Quench Tank, known as the Reactor Coolant Drain Tank (RCDT) is equipped with 0 rupture disc which blows at 110 psig (saturation-temperature =
345F). Will change range to O to 400*F.
Indication will be added to the Control Room.
Peck (Comp)DN104-2
i Page 30 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE-VARIABLE:
Quench Tank Pressure-(ReactorCoolantDrainTank)
TYPE & CATEGORY:
D3 RANGE:
CR-3 0-100 PSIG (Design = 100 PSIG)
NRC 0 to design ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR On demand in TSC & E0F SCHEDULE:
Installed l
POSITION:
Complies Peck (Comp)DN104-2
Pags 31 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Steam Generator Level' TYPE & CATEGORY:
A,0 1 RANGE:
CR-3 0 to 150 and 100 to 394 inches, see Position NRC Tube sheet to separators ENVIRONMENTAL QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUND ANCY:
Yes, complies 4 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Upgrades will be complete by end of Refuel V POSITION:
CR-3, having a B&W NSSS, utilizes Once Through Steam Generators (OTSG) which produce superheated steam and therefore are not equipped with moisture separtors in the steam generator.
CR-3 is in the process of installing the Emergency Feedwater Initiation & Control (EFIC) systems, which will be completed by the end of Refuel V.
This system provides Class 1E, redundant, level indication in the CR.
The lower range (start-up) measures 0 to 150 inches and the upper range (operating) measures 100 to 394 inches.
The lower level sensing tap (0 inches) is approximately 6 inches above the lower tube sheet and the upper level sensing tap (394 inches) is at approx-imately the level of the aspirating ports.
Areas of noncompliance will be upgraded to comply.
Peck (Comp)DN104-2
Pagm 32 CRYSTAL RIVER 3 R
l REGULATORY ~ GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Steam Generator Pressure TYPE & CATEGORY:
A,D 1 RANGE:
CR-3 0-1200 PSIG, see Position NRC Atmosphere to 20% > Lowest Safety Viv Setting (1260 PSIG)
ENVIRONMENTAL QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 4 channels POWER SOURCE:
1E/DG DISPLAY :
Indicated in CR On demand in TSC & E0F SCHEDULE:
Upgrades will be complete by end of Refuel V POSIlION:
The steam generator pressure range of 0-1200 psig is acceptable because the safety valve setpoints range from a low of 1050 psig + 10 psig to 1100 psig
+ 10 psig, which are close to 20% above the low setpoint recommendation.
The high safety valve setpoint is about 100 psig below the high end of the instrument scale.
Therefore, based on the facts that the highest safety valve setting is typically 1100 psig, the. steam relief capacity is 20-25% above the expected steam flow rate and that excess relief capacity is maintainea when safety valves are inoperable, and the FSAR analysis indicates a maximum steam pressure of about 1100 psig for operating plants, it is recommended that the existing range of 0-1200 psig is sufficient.
Other areas of noncompliance will be upgraded to comply.
Peck (Comp)DN104-2
Pags 33.
~ CRYSTAL RIVER 3-REGULATORY GUIDE 1.97 L
C0f9LIANCE TABLE V ARI ABLE:
Main Steam Safety Relief Valve Position TYPE & CATEGORY:
D2-RANGE:
CR-3 Not' measured, see position NRC Closed - not closed i
ENVIRONMENTAL-QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A-QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
?
R.G. 1.97 identifies two uses for MSSRV/ADV position indications.
The i
first is to provide information to monitor the operation of the secondary system. This is expected, by the NRC, to help the operator make appropri-ate decisions in using available systems to mitigate consequences of an accident.
i '
An additional use is for establishing the magnitude of release of radio-active material from the secondary coolant system during accident condi-tions.
In order to justify not implementing the R.G.1.97 requirement-for. main steam safety / relief valve (MSSRV/ADV) position monitoring.. it is necessary to'either demonstrate that the information supplied by such instrumentation is not necessary for the stated functions, or that. the information can be obtained from other available instrumentation.
The following provides an assessment of the benefits of a MSSRV position monitoring system relative to current practice; and evaluates the accept-ability of not installing such a system.
Issues which are addressed are:
1.
Aid to operator in preventing overcooling sufficient to lead to pres-l surized thermal shock.
Peck (Comp)DN104-2
~Paga 33A 2.
' Assessment of. radioactive l material-releases through the MSSRV/ADV's during anticipated transients.
3.
Regulatory Guide 1.97 requirements for MSSRV. (including'ADV's) position indication.
For this evaluation, current practice for. operating without this instrumen-tation' under both anticipated transients ; and accident conditions at CR-3 were reviewed.
Conclusions are based upon judgements of the adequacy of current practices to meet NRC requirements for system monitoring and release assessments, and the benefits of additional instrumentation weighed against its monetary costs.
EVALUATION OF CURRENT CR-3 PRACTICE Anticipated Transients The - anticipated transients which result in.MSSRV/ADV operation are usually those which result in decreases in heat removal by the secondary ' system.
Examples are loss of load, turbine trip, and loss of condenser. vacuum. During any. full power turbine trip, a portion of
.the MSSRV/ADV's will open since -the turbine bypass valves are only designed for 15% for full steam flow.
Spurious MSSRV/ADV action is also possible.
In the event of spurious MSSRV/ADV lifting or failure of valves to resent, excessive secondary system heat removal may result.
Plant operating history illustrates that a fully stuck open MSSRV is
~
unlikely.
Excessive discharge flow is attributed to - shifting of spring set points, leaking seats or. inadequate blowdown -margin.
In all cases, a lowering of steam header pressure results in proper reseating, sometimes manual popping is required to generate the extra forces to eliminate leaks.
Ora manufacturer of relief valves with similar design features to the Consolidated series 3700 MSSRV's indicates that stuck valve flows of up to 25% capacity can be expected during the first blowdown stage.
Consolidated acknowledged that this maximum sinsner feature applies to their design.
Required Operator Action and Supporting Instrumentation Current emergency operating procedures require the operator to:
i (1) Verify reactivity control; (2) Maintain or achieve adequate subcooling; (3) Verify proper steam generator levels and feedwater flow; (4) Verify or establish natura1' circulation, if RCP's are not oper-ating; (5) Verify RC temperature > 500*F, or respond with actions designed to prevent pressurized thermal shock; Peck (Comp)DN104-2
+
... _ ~. _,.,. _.. _ ~
I w
Pags 33B I
(6) LConfirm that a; steam generator tube rupture has not occurred; (7):. Assess radioactive inventory control.
i N'one of these verifications,-or associated operator responses, require j
~
~.
specific ' measurements of steam flow or MSSRV/ADV position indication.-
- However, -ity is of _value to know the path of heat transferred from the
- secondary system to a heat ' sink,' for purposes of terminating the over--
-cooling transient.
Excessive secondary - system cooling _ cari.. result in excessive reactor coolant _ system cooldown, with theoretical technical specification i
violation. ' The excessive cooldown is monitored on the primary.
system. _ Unexpected. heat transfer : from the secondary system is observed, ~ first, by losses in secondary system pressure.
Diagnosis of MSSRV/ADV-Failure to Reseat Current practice for diagnosing the existing of an MSSRV/ADV which has failed to reseat is by its' distinct impact on secondary pressure (see 3 ).
Other transients can result 'in similar reductions in 4
secondary system pressure, however, a stuck MSSRV/ADV is the most 4-likely cause, and is checked first. Currently, a turbine plant oper-ator is dispatched to visually check and identify stuck relief l
valves. This does serve as a limited distraction from other duties.-
History of Secondary System and Operator -Response and Pressurized Thermal Shock Considerations A qualitative review of turbine / reactor trip events for the 1981 to 1984 time frame was conducted to note the frequency and character-istics of stuck MSSRV/ADV events.
A number of events have ' occurred i
over _ this period.
The attachment shows a sample event where the action of the MSSRV/ADV and the operator is fairly distinct.
The stuck valve did not, by itself, cause a significant secondary system s
pressure reduction.
The valve may have been partially open.
The majority of the pressure drop is associated with the operator action
'=
to establish a firm reseating by lowering the turbine bypass setpoint.-
In all of the observed events, reseating has been achieved - with p
secondary system pressures above 880 psig.
Reactor coolant tempera-tures have not been reduced below 500*F during these events.
i-These events of limited valve sticking do not appear to be precursors to an event resulting in a valve sticking down to a low pressure.
Extended stuck MSSRV/ADV events are, of course, readily recognizable by direct visual observation of the valve exhaust.
- Nevertheless, the importance of a stuck MSSRV/ADV event, where the j-valve does not reseat at.all, was reviewed based upon the B&W Owners Group - Probabilistic Evaluation of ' Pressurized Thermal Shock-Phase 1 report (PTS-P1), and transient assessments provided in the B&W Abnorm-
+-
al Transient Operating Guidelines (ATOG).
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1 Page 33C' The analysis providEd in the AT0G discussion.of small steam leaks uses
--the. event. of all-turbine bypass : valves failing open. - This would be equivalent to an event of two stuck MSSRV's, one on each steam gen-erator.
This event results in SLBIS. actuation within about 5 minutes of reactor L trip,. isolating all - feedwater to both ' steam generators.
For.a stuck MSSRV event, the cooldown would continue somewhat ' longer until the steam generators dry out...since the " break" is not i-isolated.
It is-important.to nate that the SLBIS actuation occurs at 600 psig, far.below that which.has been required to reseat MSSRV's in
~
the-: past.. In the case of a single, stuck fully open.MSSRV, the.
depressurization would be less. severe due to heat transfer from the unaffected loop and the fact that the heat - rejection capacity of a single valve is more comparable to reactor coolant pump and decay heat L
input.
In either case, the-RCS temperature would not be expected to go below 500*F.
Another analysis from.the AT0G shows the primary and secondary systgm response to a still more severe small steam line. break of 0.5 ft,
which. is equivalent to 4.5 fully open MSSRV's.
Again, the proper functioning of the SLBIS terminates the transient' prior to excessive cooldown of the RCS.
Conclusion 4
. A MSSRV/ADV position indication system' is not necessary for proper response to stuck relief valve events, or to prevent overcooling from these events.
The present procedure for checking for discharging valves after a trip should continue and be adequately documented.
Assessment of Radioactivity Releases Through MSSRV/ADV's During Transients i
A very small amount of ' radioactivity is released through - the MSSRV/
ADV/s during transients that result in secondary system undercooling.
- The amount is dependent on the -level of radioactivity in the secondary system.and the amount of steam released to the atmosphere.
It is important-to note that radioactive noncondensible gases -in the secondary system are normally released with the off-gas from the con-denser vacuum pumps, on a continuous basis.
The only impact on releases caused by the release through the MSSRV/ADV's 'is a minor i
reduction in the time delay and a somewhat reduced decontamination j
factor- (DF) for volatile fission products.
Since these releases are L'
of such a short duration, the contribution to overall site releases from MSSRV/ADV openings have always been minimal.
i Because MSSRV/ADV position indication is not now available at CR-3, the amount ~ of steam released through the MSSRV/ADV's when they are open, is conservatively estimated based upon secondary system condi-tions. Full power steam flow is assumed for the duration of time that i-steam pressure is above any valve set point and also for the estimated duration of any MSSRV/ADV sticking open.
This may result in an order Peck (Comp)DN104-2 1
1 v
~:.
w-
,a.
Pags 33D of magnitude or more over-estimate of steam release.
The duration of valve sticking is estimated based upon secondary system pressure response and discussion with operators who observed the event.
Conclusion Because the estimated releases are still minimal, the refinement pro-vided by actual position indication has essentially no value.
Having actual valve position data is not likely to simplify the estimation procedure.-
Some benefit may result from eliminating the need for a turbine plant operator to go and visually determine whether a stuck relief valve is the cause of loss of secondary pressure.
Such an operator would still probably be requested to confirm visually that the valve had reseated.
Accidents (and Transients using Accident Assuraptions)
The accidents discussed in the FSAR Chapter 14 which are relevant to assessing the benefits of a MSSRV/ADV position indication system are:
a.
Loss-of-load (14.1.2.8.3) 5 Complete Loss of All Unit AC Power (14.1.2.8.4) c.
Steam Generator Tube Failure (14.2.2.2) d.
Maximum Hypothetical Accident (14.2.2.7)
Monitoring of Secondary System Operation During Accidents l
As describeo above, the CR-3 appropriate response to transients and accidents does not require knowledge of the position of the MSSRV/
ADV's. For certain design basis accidents, the visual confirmation of MSSRV/ADV ststus may not be possible, however, as time and priorities permit, the operator can still respond to indications of secondary system pressure as appropriate.
Assessment of Radioactivity Releases Through MSSRV/ADV's During Accidents and Transients Evaluated with Accident Assumptions
. The loss of load and loss of AC power accidents assume reactor coolant activity associated with 1% defective fuel and the secondary systems activity associated with a1 gpm primary to secondary tube leak.
These values are also the Technical Specification operating limits and are conservative relative to what is typically observed.
Accident atmospheric dispersion factors are used.
The steam generator tube rupture accident assumes a 435 gpm initial primary to secondary leak, with the majority of the activity released through the condenser vacuum pump exhaust.
The typical results of these analyses are from 4 to 90 mrem to the thyroid, and 4 mrem or less to the whole body.
Steam released during a.
and b.
accidents is identified as about 200,000 lb.
It is likely that the steam release calculated by the conservative method of assuming full steam flow for the duration of i
Peck (Comp)DN104-2 I
e
~. __ -_
.Page 33E relieftoatmospherecould.be\\10ormoretimes[this'value. The calcu-
' lated dose rates would.still be small' relative to any emergency action
- criteria. :In addition, the aboveLoffsite: dose rates will usually be less because of the -actual meteorological conditions. at ' the time ' of -
~
b
. the event and because the typical - defective fuel-fraction and. steam i
generator '. tube'. leakage 'is : well below the -Technical Specification limits.
~
' During a. steam generatorr tube rupture, a. similar' over-estimation of
'offsite dose rates-could result.
It-iss important to note that the
~
benefit' of MSSRV/ADV position indication in eliminating the overesti-
- mations is_ by allowing the. number of _ valves open and their. capacity to
-be used 'in determining steam released.
A significant amount of the I
present over-estimation could he avoided by providing, in the estimat-t ing. procedure, actual.. integrated steam flow as a function of time
- after trip 1which could be used to estimate steam released..
i Non-mechanistic accidents such as the Maximum Hypothetical Accident (PtiA) 'provides the-principal basis on.which the NRC hasi promulgated e
the R.G.1.97 requirement for MSSRV/ADV ' position indication.
The MHA ; as described ~ in the FSAR assumes release of a substantial t-fraction of the core fission products to the containment.
It.is
[
possible that this activity could also be in the reactor coolant, cir-i' culating' through the ' steam generators.
The ratio of-resulting RCS j
activity to that associated with the 1% defective fuel design basis is from 200 to 500,000, depending on the isotope of interest. The poten-tial doses resulting from one gpm primary to secondary leak can become i
very significant-and whatever contributes to an. accurate estimate of j
the -release would be considered of snme value 1
3 i' provided an estimate of offsite exposure potential which 1
. was used to gauge the rela *.ive importance of accurate estimates for releases through steam venting. While this analysis is very conserva--
tive, it indicates that over-estimation on the order ' described above could result in unnecessary offsite emergency efforts.
Conclusions l
l Over-estimation of releases during an MHA is significant.
A more t
realistic model for steam released for use in procedure EM-304 Rev. 8
. is warranted.
Losses after initial full load rejection should be i
i based on reactor coolant loads and decay heat effects.
If turbine i
J bypass valves are functioning, losses from a simering/ leaking MSSRV f
can be assumed 25% capacity maximum.
Further consideration can be given to steam.headcr pressure during simering.
Steam flow is pro-
. portional to the absolute steam header pressure.
Steam at 975 PSIG i
j
. would discharge 15% less capacity then at the MSSRV accumulated design l'
~
pressure of 1144 PSIG.
i i
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"CRYSTALsRIVER 3 REGOCATORY. GUIDE-1.97
^-
COMPLIANCE TABLE
~3 u
,7^
. VARIABLE:
MainFeedwaterFlok
^
.gr TYPE & CATEGORY:
D3
',s
[
RANGE:
CR-3 0-6 x 10 '1bs/hr. (Design = 5.3 x 106 lbs/hr) 6 NRC 0 to 110% design m
ENVIRONMENTAL QUALIFICATION:
No, not.. required "N
m SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required-4
-REDUNDANCY:
No, not required 3 channels POWER SOURCE:
UPS/DG
.g*
DISPLAY:
Indicated and recorded in'CR On demand in TSC & E0F
- s
.s.
Installed SCHEDULE:
POSITION:
Complies s
~
x
-.g
>s i
,f
\\.
j I
Peck (Comp)DN104-2
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C, '
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- b
Page 35 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97.
COMPLIANCE TABLE VARIABLE:
Auxiliary Feedwater Flow
. TYPE & CATEGORY:
02
. R ANGE:
CR-3 0-500,000 _lbs/hr. (Design = -370,000 lbs/hr)
NRC 0 to 110% design ENVIRONMENTAL QUALIFICATION:
No, will comply-SEISMIC QU ALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies 4
REDUND ANCY:
Yes, complies 4 channels POWER SOURCE:
1E DISPLAY:
Indicated and recorded on demand in CR On demand in TSC & EOF SCHEDULE:
Upgrades will be complete by end of Refuel V i
POSITION:
A redundant 4 channel system, with all safety parts seismically qualified, and transmitters environmentally qualified, will be installed in conjunc-tion with the EFIC modifications.
4 i
Peck (Comp)DN104-2
Pagm 36' CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Condensate Storage Tank Water Level
~
. (Emergency Feedwater Tank) - see Position TYPE & CATEGORY:
01 RANGE:
CR-3 0-35 ft.
NRC Plant Specific ENVIRONMENTAL
_ QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, will comply QUALITY ASSURANCE:
No, will comply REDUND ANCY:
No, will comply POWER SOURCE:
1E DISPLAY:
Indicated in CR SCHEDULE:
Upgrades will be complete by end of Refuel VI POSITION:
A new tank called the Emergency Feedwater Tank will be installed to comply with these requirements, a
Peck (Comp)DN104-2
.,e-e,,
F.
Page 37 CRYSTAL RIVER 3-REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Spray Flow TYPE & CATEGORY:
D2 RANGE:
_CR-3 0-1800 GPM (Design = 1500 GPM)
NRC 0 to 110% Design ENVIRONMENTAL
-QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes,-complies 2 channels-
- POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Upgrades will be complete by end of Refuel V POSITION:
Areas of nonconformance will be upgraded to comply.
Peck (Comp)DN104-2
Paga 38 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Heat Removal by the Containment Fan Heat Removal System TYPE & CATEGORY:
D2 RANGE:
Not measured, will comply, see position ENVIRONMENTAL QUALIFICATION:
No, will comply SEISMIC QU ALIFICATION:
No, not required QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, not required POWER SOURCE:
No, will comply DISPLAY:
No, will comply SCHEDULE:
Upgrades will be complete by end of Refuel VI POSITION:
The following position is a justification developed by the BUOG Reg. Guide 1.97 Task Force.
The plant has a design air flow rate from the Reactor Building fans during normal and accident or emergency conditions.
.The design flow rates are achieved by reducing the normal running speeds of the fan motors by about one-half during accidents where the heavier steam-air mixture might over-load the motors at full speed. The fan cooling units are cooled by cooling water from the Nuclear Services Closed Cycle Cooling System (NSCCS).
For the following reasons, the status of the fan breakers and cooling water flow rate are the measured variables.
The primary indication that the Reactor Building is being cooled is the Reactor Building temperature.
A first indication that the Reactor Building fans are performing their func-tion is an indication of the status of the fan breakers to ensure that the fans are on and the delivery of cooling water flow to the cooling units.
The flow variable will be upgraded to comply.
As backup information to ensure coupling between the fan and motor, each fan is equipped with vibration detectors which annunciate in the control room.
Calibrated percent load meters for the motors are also located in the control room.
Peck (Comp)0N104-2
Paga 39 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Atmosphere Temperature TYPE & CATEGORY:
D 2' RANGE:
CR-3 0-200 F, will comply NRC 40*F to 400 F ENVIRONMENTAL QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No,.will comply REDUNDANCY:
No, not required 4 channels POWER SOURCE:
UPS/DG DISPLAY:
Local indicator, recorded on demand in CR On demand in TSC & E0F l
SCHEDULE:
Upgrades will be complete by end of Refuel VI POSITION:
Areas of noncompliance will be upgraded to comply.
4 l
Peck (Comp)DN104-2
Paga 40 CRYSTAL RIVER 3 REQJLATORY GUIDE 1.97 COMPLIANCE TABLE
- V ARI ABLE:
Containment Sump Water Temperatue TYPE & CATEGORY:
D2 RANGE:
CR-3 Not measured, see position.
NRC' 50 to 250*F
-ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
The NRC R.G.1.97 requires containment sump water temperature indication as a Type D variable for the purpose of monitoring the operation of contain-ment cooling systems. No additional justification is provided.
It is expected that this information would be used following high energy line breaks in containment.
While containment sump temperature trends nay be indicative of high energy fluid leakages and containment cooling, it would be difficult to conceive of any correlation from monitored values to any useful measure of success.
Containment sump temperatures impact containment cooling only when the Reactor Building spray system is in operation with suction being taken from the sump. This would be expected to be used only after depletion of avail-able supplies from the BWST.
a.
Containment Cooling System Monitoring Containment atmospheric temperature instrumentation provides the most direct indication of containment cooling system success. The existing system is expected to be upgraded to meet R.G.1.97 requirements.
Peck (Comp)0N104-2
Pags 40A The next most valuable indication of containment cooling is provided by instrumentation which monitors the operation of systems with a con-tainment cooling function.
This function is provided by the Reactor Building Spray System (RBSS) and the Reactor Building Emergency Cool-ing System (RBECS).
The RBECS instrumentation will be upgraded to provide heat removal indication meeting the requirements of R.G.1.97.
Containment atmospheric temperature is recorded in the control room.
The Reactor Building air handling fan motor breaker positions, indi-cating lights and percent full load ammeter indicators representative of air flow loading are monitored on the control board.
Fan cooling water flow leakage is also monitored and alarmed.
Containment sump water temperature provides only a crude indication of containment cooling system success.
Because of this and the avail-ability of the instrumentation described above, sump water temperature instrumentation is not necessary for containment cooling system monitoring.
Nevertheless, containment sump temperature can be deter-mined when the LPI is in the recirculation mode, using temperature indicators meeting all other R.G.1.97 requirements.
b.
Equipment Temperature Limits Protection of DHR/LPI and RBSS from Excessive Sump Temperatures:
These systems are designed for fluid temperatures in excess of the R.G.1.97 required range for sump water temperature instrumentation (Ref. FSAR Table 6-3).
No operator action is required in response to sump water temperature.
Actual options available with excessive sump water temperatures would be limited to the reactor coolant system and containment cooldown prior to transferring to the recirculation mode of containment spray.
This transfer is not required for over an hour after a LOCA, in which time the sump temperature is below 205 F.
c.
NPSH Requirements The minimum available NPSH for the Decay Heat Removal pumps is con-servatively calculated with sufficient safety margin such that indica-tion of sump temperature is not required in order to insure adequate NPSH and no automatic or maaual actions are initiated based on this temperature.
l Peck (Comp)DN104-2
Pagm 41 CRYSTAL RIVER 3 REGULATORY GUILE 1.97 COMPLIANCE TABLE VARIABLE:
Make-up Flow - In TYPE-& CATEGORY:
D 3, see Position RANGE:
CR-3 0-200 GPM (Design = 115 GPM)
NRC 0 to 110% Design-ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QU ALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Installed POSITION:
The following positica is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
During design basis events such as LOCAs, the Makeup and Purification System (MU&PS) is isolated. Makeup flow is a backup variable to the makeup line isolation valve position. During normal operation and certain design basis events such as small break LOCA, the Mu&PS is used to supply' borated makeup water into the RCS to balance letdown flow out of the RCS.
It also adds makeup water in order to maintain pressurizer level at its setpoint.
Thus, makeup flow is an important variable for monitoring the operation of the MJ&PS.
For the reasons provided in the Position section for the vari-able, Makeup Tank leiel (page 43), it is suggested that this variable can be a backup to Makeup Tank Level.
As a backup Type D variable, it is appropriate that Makeup Flow be classified Category 3.
Peck (Comp)DN104-2
.1 Page 42'
^
CRYSTAL RIVER 3' REGULATORY GUIDE 1.97
'C0W LIANCE TABLE t
iVARIABLE:
. Letdown F1ow - Out JTYPE &' CATEGORY:'
D 3, see position.
0-160 GPM -(Design = 140 GPM)
RANGE:
CR-3 NRC 0 to 110% Design ENVIRONMENTAL-
-QUALIFICATION:
No, not required SEISNIC
.QU ALIFICATION:
No, not required -
QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, nrt required POWER SOURCE:
UPS/0G DISPLAY:
Indicated in CR On demand in TSC & E0F SCHEDULE:
Installed POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
1 During design basis events such as LOCAs, the W&PS is isolated.
Letdown flow is a backup variable to the letdown isolation valve position. During normal operation and certain design basis events such as small break LOCAs, the N&PS is used to supply borated makeup water into the RCS to balance letdown flow out-of the RCS.
Thus, letdown flow is an important variable for monitoring the operation of the W8PS. For the reasons provided in the Position section for the ' variable Makeup Tank level (page 43), it is
. suggested that this variable can be a backup to Makeup Tank level.
As a backup Type D variable, it is appropriate that letdown flow be classified Category 3.
For Crystal River 3, normal letdown flow rate through the block orifice is 45 gpm with a maximum flow rate of 140 gpm with both letdown coolers in
. operation.
Having this maximum flow rate of 140 gpm the range of letdown flow indicator is 0 to 160 gpm which adequately meets the regulatory guide recommendation of 0 to 110% design flow.
Peck (Comp)DN104-2 r
1
r 6
'Pagni43
- CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COW LIANCE TABLE ~
VARIABLE:
Volume Control Tank Level j.
(Makeup Tank) l
.~ TYPE & CATEGORY:
.D2 RANGE:
CR-3
'0-120 inches, meets intent, see position f
NRC Top to bottom ENVIRONMENTAL QUALIFICATION:
Yes, complies i~
SEISMIC L
QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
.No, not required 2 channels POWER SOURCE:
UPS DISPLAY:
Recorded in CR On demand in TSC & E0F SCHEDULE:
Installed POSITION:
The following position is a justification developed by the BWOG ~ Reg. Guide 1.97 Task Force.
During normal operation and certain design basis accidents where the Mu&PS is still operable, the Makeup Tank Level is the key variable used to pro-vide indication that the MU&PS is operating properly.
Makeup Tank Level information provides the first indication that a suction source for. the l
Makeup pumps is available. Since the Makeup Tank is a surge volume.for the l
RCS, Makeup Tank Level and Pressurizer Level indications can be used to qualitatively assess Makeup. Flow into the RCS and Letdown Flow from the RCS.
Quantitative indication of Makeup Flow and Letdown Flow can be provided by flow instrumentation for these variables.
However, in most instances, it
~
is more important to know that Makeup and/or Letdown is established (quali-tative) and not necessarily' what those flow rates are (quantitative) in order to determine the operation of the MuaPS.
Since Pressurizer ' Level instrumentation is Category 1 and the suggested Makeup Tank Level instru-mentation be Category 2, then high quality instrumentation is available to L
Peck (Comp)DN104-2 L
i
Page 43A provide information on the'. status and operation of the til&PS.
Flow rate indication provided 'for Makeup Flow and Letdown Flow can be used as con-firmatory, backup information to Makeup Tank Level and Pressurizer Level.
Meets intent _ of RG 1.97, 2-1/2" from bottom to 4" from top of vessel. -
Parts of safety system are seismic with -QA.
QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
Peck (Comp)DN104-2
Paga 44
-CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Component Cooling Water Temperature to ESF Systems TYPE & CATEGORY:
D2 RANGE:
CR-3 0-200'F and 40-250 F, see Position NRC 40' to 200*F ENVIRONMENTAL QUALIFICATION:
No, not required (mild environment)
SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, see Position REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
. Installed POSITION:
Complies The 0-200*F range is for the Decay Heat Closed Cycle Cooling Systems (DC) and the 40 to 250'F range is for the Nuclear Services Closed Cycle Cooling Systems.
This equipment was originally purchased without-Quality Assurance documen-tation. Future equipment will be purchased with the requirement to specify the applicable Quality Assurance practices.
Peck (Comp)DN104-2 1
Page 45 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE
-VARIABLE:
. Component Cooling Water Flow to ESF Systems (Level) see Position TYPE & CATEGORY:
D2 RANGE:
CR-3 (SeePosition)
Surge Tank Levels: SW - 2" above BL to-2' above Normal WL DC - 7" above BL to l' labove Normal ~WL System Pressures:
SW 200 PSIG DC 60 PSIG NRC 0 to 110% Design Flow ENVIRONMENTAL
-QU ALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies
+
REDUNDANCY:
No, not required POWER SOURCE:
None, will comply DISPLAY:
Local indication only, will comply with position SCHEDULE:
Upgrades will be' complete by the end of Refuel VI POSITION:
r There are presently no flow indications on the main control board for Decay Heat Closed Cycle Cooling (DC) and Nuclear Services Closed Cycle Cooling (SW) systems. Local flow indication for these systems is available.
Indi-j.
cated flow measurements in the control room are not deemed necessary because the DC and SW systems surge tank levels provide better information to.the operator. The wide range of design flows to various ESF components would not necessarily be representative of overall system performance.
Service water header pressures and remote actuated valve positions are available to the operator and along with the surge tanks levels, which pro-vide a better overall indication of system status.
4 QA requirements meeting CR-3 licensing connitments were applied to safety related portions of this instrument string.
Area of non-compliance will be upgraded to comply with position.
Peck (Comp)DN104-2
r,-
Pag 46-m CRYSTAL RIVER 3 REGULATORY GUIDE -1.97 COPFLIANCE TABLE VARIABLE:
High-Level. Radioactive Liquid Tank Level 1 TYPE-8 CATEGORY:
D3 RANGEi CR-3 0 to 100%
NRC Top to bottom ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QU ALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
Instrument Air-DISPLAY:
Indication at local panel only, see Position SCHEDULE:
Upgrades will be complete by the end of Refuel VI POSITION:
Tanks covered by this variable are:
Concentrated Waste Tanks (2) l Concentrated Boric Acid Tanks (2)
Spent Resin Holdup Tank The level indication for the concentrated waste tanks, concentrated boric-acid tanks and the spent resin hold-up tank are indicated on the radio-active waste disposal control panel located in the' Auxiliary Building.
High level alarms at-this panel will cause a comon alara to actuate on the main control board.
The controls for the liquid waste disposal system are all located at the local panel; therefore' indication on the main control board would not enhance operator control from the control room.
Peck (Comp)0N104-2
Paga 47
' CRYSTAL RIVER 3 ll REGULATORY GUIDE - 1.97 '
COMPLIANCE TABLE VARIABLE:
Radioactive Gas Hold-up Tank Pressure
-(Waste Decay. Tanks)
TYPE &~ CATEGORY:
D.3 RANGE:
CR-3 0-150 PSIG'(Design = 150 PSIG), see position NRC 0 to 150% Design ENVIRONMENTAL QU ALIFICATION: -
No, not required SEISMIC-QUALIFICATION:
No, not required QUALITY' ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
Instrument air DISPLAY:
Indication at-local panel only, see Position SCHEDULE:
Upgrades will be complete by the end of Refuel VI t
POSITION:
The control and indications for the waste disposal system are located on 1
the radioactive waste disposal panel in the Auxiliary Building.
Indication of radioactive gas hold-up tank pressure is not a necessary control ' room variable for the post accident monitoring.
In the event of an accident which results in significant failed fuel or significant radioactive gas release, the manual transfer of radioactive gases to the radioactive gas hold-up tanks would not be attempted since the Reactor Building would be i
utilized as the hold-up tank.
There are no automatic transfer operations involving the radioactive gas hold-up tanks.
Therefore, the monitoring in the control room of the radioactive gas hold-up tanks during post accident conditions is not necessary since these tanks are not utilized for accident mitigation.
The radioactive gas hold-up tanks are equipped with relief valves which are set at 125 psig.
The range of the pressure indication' is 120% above the relief valve setting.
Peck (Comp)DN104-2 u
Page 48 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 CONLI ANCE TABLE VARI ABLE:
Emergency Ventilation Damper Position Indication (SeePosition)
TYPE & CATEGORY:
0 2
RANGE:
CR-3 See position NRC Open-Closed Status l
ENVIRONMENTAL I
QUALI FICATION:
No, will comply.
i SEISMIC l
QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, will comply.
REDUNDANCY:
No, not required.
2 channels i
POWER SOURCE:
UPS/DG DI SPLAY:
See position.
l SCHEDULE:
Upgrades will be complete by the end of Refuel VI.
POSITION:
i Dampers cove ed under this category are those used in ventilation systems for the follawing:
l Emergency Diesel Generator l
Control Complex l
Decay Heat Pump Area Spent Fuel Cooling Pump Area The dampers in these systems are controlled from the fan start circuitry and do not have individual control switches.
Redundant systems are provided so that a single failure will not defeat their safety function.
Panel lights show when the fan circuitry is operating.
Back-up operational data is provided to operators by high quality commercial grade low flow and high temperature alarms. The control complex dampers also have open position lights.
The above data should be adequate to determine if an HV system is opera-tional.
Individual damper position would only be beneficial if isolation were required.
Pagn 48A~
'For those dampers in the control complex which are closed on either high radiation or engineered safeguards systems actuation, qualified closed position indication will be added.
I l
l l
Peck (Comp)ND75-1
t.
J 1
+
li L
Paga 49 h'
CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE I
VARI ABLE:
Status of Standby Power I-s TYPE & CATEGORY:
D2 R ANGE: -
CR-3 Inverter 250/125V DC -
DG 3A to 30 4160V 480V 3A, 38 i
3A,3B Not 3A,3B
-3A,3B Not l-Volts; Amps Measured Volts-Volts; Amps Neasured NRC Plant Specific 4
l 5
l ENVI RONMENTAL QUALIFICATION:
Yes Yes No SEI SMIC QUALI FICATION:
No not required.
QUALITY ASSURANCE:
.No No No REDUNDANCY:
Redundancy based on dual buses.
l POWER SOURCE:
Indicated Will Indicated Indicated Will Comply Comply l
SCHEDULE:
Upgrades will be completed by end of Refuel VI.
3 POSITION:
Areas of non-compliance will be upgraded to comply.
e t
i i
l l
f i
I Peck (Comp)ND75-1 L-
Page 50 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Area Radiation - High Range TYPE & CATEGORY:
C, E 1
RANGE:
CR-3 1 to 107 R/Hr NRC 1 to 10 R/Hr ENVIRONMENTAL QUALIFICATION :
Yes, complies.
SEISMIC QU ALIFICATION:
Yes, complies.
QUALITY ASSURANCE:
Yes, complies.
REDUND ANCY:
Yes, complies.
2 channels POWER SOURCE:
1E DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed POSITION:
Complies Peck (Comp)ND75-1
Page 51 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Radiation Exposure Rate inside buildings or areas where access is required to service equipment important to safety or which are in direct contact with primary containment where penetrations and hatches are located.
' TYPE & CATEGORY:
E 3
RANGE:
CR-3
.01 to 10R/Hr, complies with position.
NRC
.1 to 10,000 R/Hr-ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
l QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
1E DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
Complies The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
NRC R.G.1.97 Rev. 3 requires area radiation monitors inside buildings or areas where access is required to service equipment important to safety.
l The NRC identified purposes for this instrumentation are:
" Detection of l
significant releases, release assessments, and long term surveillance."
This is a Type E variable with the overall purpose of being monitored as required in determining the magnitude of the release of radioactive l
materials and continually apsessing such releases.
The required range for these monitors is 0.1 to 109 R/Hr.
R.G.1.97 describes areas of concern as those where access is required to service equipment important to safety. This implies that this instrumenta-tion may be used for purposes other than those described above, i.e. for health physics purposes.
For purposes of determining the magnitude of releases, the area radiation exposure rate monitors are clearly of very minor importance. Determination Peck (Comp)ND75-1
Pag 2 51A i
of release magnitude is done by other Type E variables associated with release paths. There is no useable correlation between area exposure rate monitors and amount of release.
Detection of significant releases by area radiation exposure rate monitor-
'ing is secondary to that provided by the release path monitoring. Nonethe-less, area radiation levels inside the plant are monitored to verify compliance with 10CFR20. These instruments are considerably more sensitive
( 1000x) than required by R.G.1.97 and are sufficient for supporting the detection of significant releases.
Determinations of accessibility of equipment for ' service or long term surveillance is the function of health physics personnel, generally using portable instrumentation.
Monitoring of recordings of area radiation exposure rates from the Control Room is not a substitute for this health physics function.
However, exposure rate monitoring equipment in areas outside containment have an upper range of 10 R/Hr., which is adequate for initial assessments of accessibility.
These ranges are based on background reading in the areas in which they are located.
Should personnel entry be required in areas where these monitors have gone off scale or indicate a high radiation area a health physics escort would' accompany personnel into these areas using portable instrumen-tation to assess radiation levels.
The high range for portable instrumen-tation at CR-3 is 103 R/Hr.
We do not anticipate, even under emergency conditions, sending personnel into radiation fields of this magnitude.
We believe that this meets the intent of Regulatory Guide 1.97.
i Peck (Comp)ND75-1
Paga 52 p
CRYSTAL' RIVER 3 REGULATORY _ GUIDE 1.97 COWLI ANCE TABLE
[
- VARI ABLE:
Containment or Purge Effluent, Noble Gas l'
TYPE &' CATEGORY:
E,C,2 RANGE:-
'CR-3 2x10-6 tog 05 uci/cc, 0 to 65,000 CFM (Design =50,000 CFM)
NRC 10-6 to 10 -uci/cc, 0 to 1107. Design L
ENVI RONMENTAL.
i QUALIFICATION:
Yes, complies.
SEI SMIC QUALI FICATION:
.No, not required.
-QUALITV ASSURANCE:
No, see position.
REDUNDANCY:
No,- not required.
POWER SOURCE:
UPS/DG DI SPLAY:
Indicated and Recorded in CR.
SCHEDULE:
Installed POSITION:
Compiies l
The radiation monitoring equipment was originally purchased without Quality Assurance documentation.
Future radiation monitoring equipment will be purchased with the requirement to specify-the -applicable Quality Assurance practices.
l l
I i-l l
i I
l Peck (Comp)N075-1 l
i I
!'u
1 Page 53
' CRYSTAL RIVER 3 L
, REGULATORY GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Reactor Shield Building Annulus TYPE & CATEGORY:
E 2
RANGE:
N/A ENVIRONMENTAL QU ALIFICATION:
N/A 4
SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A D ISPLAY:
N/A SCHEDULE:
N/A POSITION:
Not in CR3 design.
Peck (Comp)ND75-1
Page 54 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLI ANCE TABLE VARI ABLE:
Auxiliary Building, Noble Gas TYPE & CATEGORY:
CE 2
R ANGE:
CR-3 10-6 to 103 uci/cc, 0-200,000 CFM (Design =156,680 CFM)
NRC 10-6 to 103 uci/cc, 0 to 110% Design ENVI RONMENTAL QUALI FICATION:
Yes, complies i
SEI SMIC QUALI FICATION:
No, not required.
QUALITY ASSURANCE:
No, see position.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DI SPLAY:
Indicated and recorded in CR.
Concentration available on demand in TSC & E0F.
SCHEDULE:
Installed.
POSITION:
Complies.
The radiation monitoring equipment was originally purchased without Quality Assurance documentation.
Future radiation monitoring equipment.will be purchased with the requirement to specify the applicable Quality Assurance practices.
Peck (Comp)N075-1
n-Page 55 CRYSTAL' RIVER 3 REGULATORY. GUIDE 1.97 COMPLIANCE TA8LE
+
. Condenser Air Removal System Exhaust.
. VARIABLE:
j TYPE & CATEGORY:.
' C,E -
2 2x1f6to 10)0-2 uci/cc Kr(85), see Position
. RANGE:
CR-3 to l
NRC 3 uci/cc, O to 1105 Design Flow
,10-ENVIRONMENTAL f-QUALIFICATION:
Yes, complies.
SEISMIC l
QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, see position.
l REDUNDANCY:
No, not required.
POWER SOURCE:
1E DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed l
POSITION:.
The condenser air removal system exhausts through the Auxiliary Building (see page 54) in which the flgw is monitored.
The range of the monitor in the Auxiliary Building is 10-0 to 103 uci/cc The radiation monitoring equipment was originally purchased without Quality Assurance documentation.
Future radiation monitoring equipment will be purchased with the requirement to specify the applicable Quality Assurance practices.
l i
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Peck (Comp)N075-1
Page 56 CRYSTAL RIVER 3 l
f REGULATORY GUIDE 1.97 C0f9LIANCE TABLE y
- ~
F'a VARIA8LE:
. Common Plant Vent
- TYPE a CATEGORY
E 2
y.,-
' ~.
NA RANGE:
o l
e
' ' ~ '
l
'ENV18t0NMENTAL..
QU ALIFICATION,; /
NA n
i SEISMIC O
s QUALIFICATION:'
NA n
i /
QUALITY ASSURANCE:
NAr i 4,5 REDUNDANCY:
NA l
POWER SOURCE:
NA l
DISPLAY:
N A,,,
~~
~
/
SCHEDULE:
NA
'e-POSITION:
/
+.
/
a 1
Connon plant vent from Auxiliary, Building, see page 54.
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Page 57 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 C0WLI ANCE TABLE VARI ABLE:
Vent from Safety Valves or Atmospheric Dump Valves (Main Steam Lina Radiation Monitor) - See position.
TYPE & CATEGORY:
E 2
RANGE:
CR-3 Not measured see position.
NRC 10-1 to 10I uci/cc (and duration of release in second mass of steam per unit time).
ENVI RONMENTAL QUALIFICATION:
Yes, see position.
SEI SMI C QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
Yes, see position.
REDUNDANCY:
No, not required.
1 each header POWER SOURCE:
1E/ Battery Backed DISPLAY:
Indicated in CR, recorded on demand SCHEDULE:
Installed.
POSITION:
The four 24" main steam headers contain a total of 16 relief valves and 2 atmospheric dump valves.
Each header is presently monitored for radiation by on-line monitors with readouts in the Control Room.
The system 11 calibrated in terms of area monitoring, i.e. mR/HR (range =.1 to 10/
mR/HR).
There are plans underway to recalibrate the entire system for various sources and in terms of uci/CC in order to comply with NUREG-0737.
There are no flow monitors to meter the quantity of steam venting to the atmosphere from the relief valves or the manual dump valves and there are no position detectors to provide a status (open/ closed) indication of the valves.
Refer to the position on item 33 (page 33) for an evaluation of this position.
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 although the sensors are not qualified to a harsh environment, and they are in containment, they still meet the environmental qualifications for the normal environment. Also, these monitors are only needed very early in the event.
Peck (Comp)ND75-1
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Paga 58
- t,
+
r.
. CRYSTAL RIVER 3
.- - " REGULATORY GUIDE 1.97 C0ifLIANCE TABLE s
~.
s..
k-.
%g a -
VARIABLE:
All-Other Ident!fied Release Points TYPE & CATEGORY:
E 2
.g
~
- s.
RANGE:
-N/A ENVIRONMENTAL
~
QU ALIFICATION:
N/A
~
'A SEISMIC QUALIFICATION:1 N/A "
s --
QUALITF A5SURANCE:
N/A- ~
~
REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
-L' ~
No other release points, see pages 52 and 54.
+
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Pagt 59 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
All Identified Plant Release Points Particulates and Halogens TYPE & CATEGORY:
E 3
RANGE:
CR-3 Reactor Building 10-11 to 10-7 uci/cc, 0-65,000CFM (Design =50,000 CFM)
CR-3 Aux. Building 10-11 to 10-' uci/cc, 0-200,000CFM (Design =156,680 CFM)
NRC 10-3 to 102 uci/cc, O to 110% Design ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QU ALIFICATION:
No, not requi red.
QUALITY ASSURANCE:
No, not requi red.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DISPL AY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
Complies l
NRC required range of 10-3 to 102 uci/cc can be covered by grab sample capability.
Peck (Comp)ND75-1
Page 60 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Airborne Radio Halogens and Particulates
. TYPE & CATEGORY:
E 3 RANGE:
CR-3 10-9 to 10-3 uci/cc NRC 10-9 to 10-3 uci/cc ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
- POWER SOURCE:
Vital Bus DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies Various portable air samplers can be used -to obtain the sample which is a
1 then taken to the Lab for counting.
(Such as the Radevco H809 high volume air sampler.)
Also have portable particulate monitors Eberline AMS-2 and. AMS-3 on hand.
(5) and 13 mini-scalers (Eberline) MS-2.
Scaler up to 500K CPM, AMS-2 up
.i to 50K. CPM AMS-3 up to 100K CPM.
- Once~ the sample is at the Lab, will have Automated Isotopic & Chemical Measurement System installed with associated hardware and software to provide the capability of onsite analysis.
1 4
Peck (Comp)ND75-1 6
rv-
~
me w,w-a+-n,
,,w m
y v
vr w-,
e-o, e
,,9--
e-m ~ p -~w m,p----m, e-
--o-w- m n g - w wm---yw,w,,
- -w---ene--e v
e
Pagg 61 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Plant and Environs Radiation, Portable Instrumenta-tion TYPE & CATEGORY:
E 3
RANGE:
CR-3 10-3 to 103 R/Hr, complies with position.
NRC 10-3 to 104 R/Hr ENVIRONMENTAL QU ALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
Batteries DISPLAY:
No, not required in CR.
SCHEDULE:
Installed POSITION:
Existing portable instrumentation can detect dose rates from 10-3 R/Hr to 103 R/Hr.
In the plant we do not anticipate encountering radiation fields greater than those which can be measured by our current equipment except under severe accident conditions. Even under accident conditions we do not anticipate sending individuals into greater than 103 R/Hr fields.
There-fore, we meet the intent of Regulatory Guide 1.97 with our current equip-ment.
Available instruments:
Xetex Model 302A - GM Tube 999 R/Hr Eberline Teletector - GM Turbe 1000 R/Hr Eberline PIC-6A - Ion Chamber - 1 mr/Hr to 1000 R/Hr Radector III - Ion Chamber
.1 mr/Hr to 1K R/Hr 1
l Peck (Comp)ND75-1
Page 62 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Plant and Environs Radioactivity TYPE & CATEGORY:
E 3
RANGE:
CR Multi-channel Gamma-Ray Spectrometer NRC Isotopic Analysis.
ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
' POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
Additionally, 2-two channel gamma ray spectrometers, which are portable, are available (Eberline SAM-2), as is a multi-channel analyzer with computer which is contracted for with the Department of Health and Rehabilitation Services.
This unit is on a truck, and mobile.
4 Peck (Comp)ND75-1
Pag) 63 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Wind Direction TYPE & CATEGORY:
E 3
- RANGE:
CR-3 540' NRC 0-360 ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC.
QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
Peck (Comp)ND75-1 i
a
.O v.
m
-,-r awe--
-1 meu 9-
, yp P-g t
c
--w te T77 7?= r m
w F4 ye9 --
y-4+
y+w g-
'-- -~'
Paga 64 CRYSTAL RIVER 3 REGULATORY. GUIDE 1.97 COMPLIANCE TABLE.
VARIABLE:
Wind Speed TYPE & CATEGORY:
E 3~
RANGE:
CR-3 0-50 M/Sec.
NRC 0-22 M/Sec.
ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
I Peck (Comp)ND75-1 e
Page 65 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Estimation of Atmospheric Stability TYPE & CATEGORY:
E 3
RANGE:
CR-3
-5'C to +5'C,'see Position NRC
-5'C to +10*C ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/0G DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
In accordance with Regulatory Guide 1.23, the measurement of temperature difference for estimating atmospheric stability only requires a range from
-1.9 C to +4.0*C for the 50 meter interval.
Any temperature difference that is outside this range does not impact the stability category.
The range of -1.9 to +4.0"C corresponds to -3.42 to 7.2*F.
CR-3's range envelops that range and is sufficient for providing an estimate of atmo-spheric stability.
l l
I I
Peck (Comp)ND75-1
Pagg 66 ORYSTAL RIVER 3-REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Primary Coolant and Sump (Grab Sampl'e)
Gross Activity TYPE & CATEGORY:
E 3
RANGE:
CR-3 10 uci/ml.to 10 ci/ml NRC 1 uci/ml to 10 ci/ml ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
t REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
s Peck (Comp)ND75-1
Page 67 CRYSTAL' RIVER 3
. REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Primary Coolant and Sump (Grab Sample) - Gamma Spectrum TYPE & CATEGORY:
C, E 3
RANGE:
CR-3 Isotopic Analysis NRC Isotopic Analysis ENVIRONMENTAL QU ALIFICATICN:
No, not required.
. SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
I 4
Peck (Comp)ND75-1
Page 68 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97
' COMPLI ANCE TABLE VARIABLE:
Primary Coolant and Sump. (Grab Sample)
Boron Content
-TYPE & CATEGORY:
E
'3 RANGE:
CR-3 0-6000 ppm NRC 0-6000 ppm ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
- QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
I t
Peck (Comp)ND75-1 k
P-w
- w 9-c--
wvt t
-+W--T t
towe %w q
-*-W g* t T
-9'$ P#
9e M :
- v-M e - -lum--eW=+
+we---
TJP-F TT W '-
Ft='ay 'T7t-*'
4
Pag 2 69' CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 '
COMPLI ANCE TABLE VARIABLE:
Primary Coolant and Sump (Grab Sample) - Chloride Content TYPE & CATEGORY:
E 3
RANGE:
CR-3 0-20 ppm-NRC-0-20 ppm ENVIRONMENTAL QU ALIFICATION:
No, not required.
SEISMIC
-QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
i Peck (Comp)ND75-1
Paga 70 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 -
COMPLIANCE TAPLE VARIABLE:
Pri. nary Coolant and Sump (Grab Sample) - Dissolved Hydrogen or Total Gas TYPE & CATEGORY:
E 3
RANGE:
CR-3 0-2000 CC STP /kg NRC 0-2000 CC STP /kg ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
Peck (Comp)ND75-1
Page 71
. CRYSTAL RIVER 3
' REGULATORY GUIDE 1.97 COMPLI ANCE TABLE VARIABLE:
Primary Coolant and Sump (Grab Sample) - Dissolved Oxygen TYPE.8 CATEGORY:
E 3
RANGE:
CR-3 Not measured, see position.
'NRC~
0-20 ppm ENVIRONMENTAL.
QU ALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
Ref: NRC criteria guidelines on NUREG-0737, Item II.B.3, Post Accident Sampling System, dated July 12, 1982 Criterion 4 of the reference stated that the measurement of oxygen is recommended but is not mandatory.
I Peck (Comp, ID75-1
Page 72 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
. Primary Coolant and Sump (Grab Sample) - pH TYPE & CATEGORY:
E 3
RANGE:
CR-3 1 to 13 NRC 1 to 13 ENVIRONMENTAL QUALIFICATION:
No, not required.
' SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUND ANCY:
No, not requi red.
POWER SOURCE:
-N/A DISPL AY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
-Peck (Comp)ND75-1
- Page 73 CRYSTAL' RIVER 3 RE' ULATORY GUIDE 1.97 G
COMPLIANCE TABLE VARIABLE:
Containment Air (Grab Sample) - Hydrogen Content
- TYPE & CATEGORY
E 3
RANGE:
CR-3 0
10%
NRC 0 - 10%
ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
1 J
Peck (Comp)ND75-1 y-
+ - + - -,, -
e um
-+y,e
+-m,-~
p
,- =
p-e
,+-yy
--,yae.-*
-e ye-y y
Paga 74 CRYSTAL RIVER 3
' REGULATORY GUIDE 1.97 COMPLI ANCE TABLE V ARI ABLE:
Containment Air (Grab Sample) - Oxygen Content
- TYPE & CATEGORY:
E 3
RANGE:
CR-3 Not measured, see position.
NRC 0 - 30%.
ENVIRONMENTAL QUALIFICATION:
N/A
. SEISMIC QU ALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUND ANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
The NRC R.G.1.97 required that Containment Oxygen be measured from 0 to 30% by volume.
The category of the variable is 3 and the type is E.
A Type E variable is one that is " monitored as required for use in determin-ing the magnitude of the release of radioactive materials, and for contin-uously assessing such releases."
For a Type E variable, Category 3 items are considered as backup variables.
In discussions with the NRC, it was determined that the NRC expects the operator to compare the oxygen percentage with the hydrogen percentage to determine if the hydrogen formed is being caused by radiolysis or by metal-water reaction, which would be indicative of core damage.
Percentage of oxygen in the containment atmosphere is classified as a Type E variable. The definition of a Type E variable is that it is to be "moni-tored as required for use in determining the magnitude of the release of radioactive materials, and for continuously assessing such releases.
How-ever, the percentage of oxygen in the containment atmosphere does not pro-vide the necessary information to determine the magnitude of releases of radioactive materials.
At best, it provides a very indirect means of j
arriving at an order of magnitude estimate.
There are other systems in place that can be used for this purpose.
Some of these would be Contain-ment Area Radiation, Radioactivity Concentration or Radiation Level in the
]
-Peck (Comp)ND75-1 j
i
_ - - ~,
-. ~
Pagm 74A I
. Primary Coolant Analysis of the, Primary Coolant, Gross Activity and G'amma LSpectrum 'of the Primary Coolant and Containment. Sump, and Gamma Spectrum of 7the Containment j atmosphere.
All of these systems provide a more. direct
'means' of determining the ' magnitude of the release _ and in addition most are.
? Category 1_ variables.which means'they are qualified to the same extent as a.
safety-related. system.-
The only other purpose.af..this variable then would be to allow the operator z to determine' what physical process is occurring that 'is forming the hydro-gen in the Containment.
.Radiolysis ' occurs at' all times, and is a slow process.
It causes. Oxygen and hydrogen to be formed from water, so the percentages' of both would increase providing _ no other processes - were happening.
However, during a LOCA, a large amount of steam would be generated along a
with various other_ gases and the ' percentage of both _ hydrogen and oxygen would tend to be in a very dynamic state, rendering a reasonable decision based on that information virtually impossible.
4 A decrease' in the percentage of oxygen along with an increase. in hydrogen would be indicative of ~a metal-water reaction which in turn indicates core damage. Again,'however, much better qualified instrumentation is available that provides a direct ' indication of core damage, rather than an indirect-indication of core damage.
Some of these systems -are: Hot and Cold _ Leg Water temperatures, Core Exit temperature, Coolant inventory, Degrees of Subcooling, and-the systems mentioned for determining the magnitude of the j
L release.
Additionally, the' problems with a dynamic situation in the con-
'tainment would also hold true in this case.
i The requirement for providing the means of measuring Containment Oxygen content is necessary because existing instrumentation provides more direct indication and are better qualified to perform the function of the required 1
L variable.
i t
J i
i.
Peck (Comp)ND75-1
+
l I
a.
Pag 2 75-CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE
-VARIABLE:
ContainmentAir(GrabSample)-GammaSpectrum TYPE & CATEGORY:
E 3
RANGE:
CR-3 Isotopic Analysis NRC Isotopic Analysis ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
4 1
l I
r 4
Peck (Comp)ND75-1
_.. _, - _ _ ___