IR 05000277/1990002
| ML20006E493 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/31/1990 |
| From: | Anderson C, Cheung L, Greca A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20006E492 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 50-277-90-02, 50-277-90-2, 50-278-90-02, 50-278-90-2, GL-82-33, NUDOCS 9002230346 | |
| Download: ML20006E493 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
REGION I
L Report Nos.
50-277/90-02
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50-278/90-02 L
Docket Nos.
50-277 50-278 License Nos. DPR-44 DPR-56 Licensee:
Philadelphia Electric Company
). O. Box 7520 Philadelphia, Pennsylvania 19101
Facility Name:
Peach Bottom Atomic Power Station, Units 2&3 Inspection At:
Delta, Pennsylvania Inspection Conducted. January 8-12, 1990 Inspectors:
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Leon'ard Cheung, Senior R tor Engineer
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A.1De~la eAg','%eactor Engineer
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Approved by:
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C. J. Anderson, Chief Plant System date Section, EB/DRS Inspection Summary:
Inspection of January 8-12, 1990 (Combined Inspection Report Nos. 50-277/90-02 & 50-278/90-02)
i Areas Inspected: Special, ennounced inspection to review the licensee's implementation of Regulatory Guidance 1.97, Revision 3 which relates to post' accident monitoring instrumentation.
Results: Based on this inspection, the inspectors determined that the licensee had implemented a program to meet the recommendations of R.G. 1.97.
One unresolved item was identified - calibration information missing for a drywell pressure channel (see paragraph 4.3).
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DETAILS 1.0 Persons Contacted
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See Attachment 2.0 Background The purpose of this inspection was to review instrumentation systems for
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assessing plant conditions during and following.the course of an accident
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based on the criteria specified in Regulatory Guide (RG) 1.97, Revision 3.
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These systems were inspected to determine if they were installed in ac-
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cordance with Generic Letter number 82-33 " Requirements for Emergency Response Capability" (Supplement I to NUREG-0737).
This letter specifies those requirements regarding emergency response capabilities that have been approved by the NRC for implementation. This supplement also dis-cusses, in part, the application of RG 1.97 to the emergency response facilities, including the control room, the technical support center (TSC)
and the emergency response facility.
Regulatory Guide 1.97 identifies the plant variables to be measured and the instrumentation criteria for assur-ing acceptable emergency response capability during and following the course of an accident.
Regulatory Guide 1.97 divides Post Accident Instrumentation into three categories and five types.
The three design categories are noted as 1, 2 and 3.
Category I has the most stringent design requirements and category 3 has the least stringent. The five types of instrumentation identified in the Regulatory Guide are types A, B, C, D, and E.
Type A variables are plant specific and classified by the licensee.
Type B variables provide information to indicate that plant safety functions are being accomplished. Type C variables provide information regarding the
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breach of barriers for fission product release. Type D variables indicate the operation of individual safety systems.
Type E variables
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are those that indicate and determine the magnitude of the release of radioactive materials.
Each variable type can be any design category.
However, Type A variables must meet Category 1 design requirements.
3.0 Scope The NRC inspection scope included:
equipment qualification (Seismic and Environmental), redundancy of power supplies, measured variables, display and recording methods used, independence and separation of electrical circuits, range and overlapping features of multiple instrument indicators,
equipment identification for RG 1.97 instruments, service, test and surveil-L lance frequency, and direct and indirect measurement of parameters of l
interest.
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The safety related (Q) and EQ master equipment lists were reviewed for the instruments selected to ascertain whether they had been evaluated and tested to the appropriate environmental, quality assurance (QA) and i
l seismic qualification requirements.
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l 4.0 Inspection Details
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i The' inspectors held discussions with various members of the licensee's staff, reviewed drawings and procedures, and selected variables for a system walkdown. Walkdowns were performed for the sensing instruments (transmitters and 0 and H analyzers) at various locations of the
2 reactor building and the display instruments in the control room to assess the implementation of RG 1.97, Rev. 3.
e Instrument variables reviewed included reactor coolant level, reactor pressure, drywell pressure, containment hydrogen / oxygen concentration, torus water level and drywell sump water level.
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Characteristics examined for each variable include identity, location, function, separation (physical / electrical), isolation, seismic, power source, environmental qualification status and instrument ranges.
The following instrumentation was examined:
4.1 Reactor Water Level (Unit 3)
The licensee determined the reactor water level to be a Type A variable. The licensee has provided the following instruments for post accident monitoring of this variable:
Power Transmitter Division'
Recorder P_EN Range
LT-3-2-3-72C I
LR-3-2-3-110A Green-165" to +60" f
(wide range)
LT-3-2-3-73C I
LR-3-2-3-110A Blue-325" to +60" (fuel zone range)
PT-3-2-3-404C I
(for water density compensation only)
LT-3-2-3-72D II LR-3-2-3-110B Green-165" to +60" LT-3-2-3-73D II LR-3-2-3-110B Blue-325" to +60" PT-2-2-3-404D II (for water density compensation only)
The licensee has taken exception to RG 1.97 for the reactor water level neasurement range.
RG 1.97 specifies that the range should be from the bottom of the core support plate (-331") to the lesser of the top of the vessel or the centerline of the main steam lines (+114").
The range, provided by the licensee, deviates by 6" on the lower end of the recommended span and by 54" on the upper end. This deviation was justified by the licensee and was reviewed by the NRC as documented in the Peach Bottom Safety Evaluation Report (SER).
In addition, the control room instrumentation includes a refueling range indicator, LI-3-2-3-86, which receives its signal from LT-3-2-3-61 and which measures the reactor water level from -21" to +371".
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refueling range instruments are not Category 1 instruments. The inspector determined that the combined ranges provide adequate
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coverage for this variable.
The Category 1 display instruments (recorders) are located on the main control board, and are specifically marked with yellow trans-parent mylar strips for easy identification af ter an accident.
All of the above instrument loops were found to be in calibration as evidenced by the calibration records. The inspector reviewed the associated drawings and procedures and did not identify any deficien.cies.
4.2 Reactor Coolant Pressure (Unit 2)
The licensee determined reactor coolant pressure to be a Type A variable. The following two instrument channels were provided to monitor this variable after an accident:
Power-Transmitter Division Recorder PEN Range PT-2-2-3-404A I
PR/LR-2-2-3-404A Green 0 to 1500 psig PT-2-2-3-404B II PR/LR-2-2-3-404B " Green 0 to 1500 psig The Division I instrument channel shares the recorder with another fuel zone reactor water level measurement. The recorders are two pen recorders located on the main control board and are specifically marked with yellow mylar strips for easy identification after an accident.
The transmitters are on the EQ master list.
All instruments in these two instrument channels are on the seismic qualification list..
The instrument loops were found to be in cali-bration, as evidenced by the calibration records. The inspector reviewed the associated drawings and procedures and observed no deficiencies.
4.3 Drywell Pressure (Unit 2)
The licensee determined drywell pressure to be a Type A variable.
The following instrument channels were provided to monitor this variable after an accident:
Sensing Power Elements Division Recorder Indicator Range PT-8 102A I
PR8102A Blue 0 to 225 psig PT-8 102C I
PR8102A Green-5 to 25 psia PT-8 1028 II PR8102B Blue 0 to 225 psig PT-8 102D II PR81028 Green-5 to 25 psia
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RG 1.97 recommends measurement of this from -5 psig to 4 times
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the dryv. ell design pressure. The licensee satisfied the RG 1.97 guidance using two instrument loops with overlapping ranges.
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The recorders are located on the main control board and are marked with yellow mylar strips for easy identification after an accident.
All four transmitters are included on the Peach Bottom EQ Master List. All of the instruments for these two instrument channels are..
currently in calibration.
However, while checking the records of the calibration history, the inspector observed that the calibration records for PT-8102B was missing for the period from November 19, 1983 to November 15, 1988 (probably for only one calibration considering the 18-month calibration frequency and the long shutdown period from 1987 to 1989). The calibration indicates minimum instrument drift.
l At the conclusion of this inspection, the licensee was unable to l'
provide other evidence to prove that this instrument was in calibra-
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tion for the period from 1985 to 1987 when the plant was in operation.
This item is unresolved pending NRC's review of the licensee's l
further evaluation and justification (50-277/90-02-01).
4.4 Drywell H LO Concentration (Unit 2)
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The licensee determined that drywell hydrogen and oxygen concentration are Type A variables. Accordingly, the licensee
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furnished category 1 sampling, process and display instrumentation.
The monitoring of these variables is performed by the following l-redundant instrument channels-
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a.
Hydrogen Concentration L
Sensing Power I
l Elements Division Recorder Indicator Range I
H2R-4965A H21-4965A 0 - 20%
H2R-4965C H21-4965C 0 - 20%
l H2E-4965B II H2R-4965B H2I-4965B 0 - 20%
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H2E-49650 II H2R-4965D H21-49650 0 - 20%
For hydrogen concentration RG 1.97 recommends instrumentation with a 0 to 30% range.
The licensee has supplied instrumentation for this variable with a 0 - 20% range.
It justified a " deviation" l
as discussed in the Peach Bottom Safety Evaluation Report. The use j
of a lower range for an inert drywell atmosphere is acceptable.
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Oxygen Concentration Sensing Power Elements Division Recorder Indicator Range
R 02E-4963A I
02R-4963A 021-4963A 0 - 10%
02R-4963C 021-4563C 0 - 10%
02E-4963B II 02R-4963B 021-4963B 0 - 10%
02E-4963D II 02R-4963D 021-4963D 0 - 10%
i The hydrogen and oxygen concentration instruments are located on the main control board and are marked with yellow mylar strips for distinction and ease of recognition as post-accident monitoring l
instrumentation.
All instrument loops were found to be properly j
calibrated as evidenced by the calibration records. Within the j
scope of this review, no deficiencies were identified.
4.5 Torus Water Level (Unit 2)
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The licensee classified torus water level as a Type A variable.
The-L monitoring of this variable after an accident is accomplished by the
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following two instrument channels:
Power i
Transmitter Division Recorder Q
Range i
LT8123A I
LR/TR8123A Green 1 - 21 FT
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LT8123B II LR/TR8123B Green 1 - 21 FT The instrument range meets the recommended range of RG 1.97 (bottom f
of ECCS suction line to 5 ft. above normal water level).
The two instrument channels share the display instruments (recorders) with the torus water temperature monitoring channels. The recorders are
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. located on the main control board and are marked with yellow mylar strips for ease of recognition as post-accident instrumentation.
The above instrument loops were found to be properly calibrated as
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evidenced by the calibration records. The inspector reviewed the associated documents and observed no deficiencies.
4.6~ Drywell Drain Sump Level (Unit 3)
There are two drain sumps in the drywell, the floor drain sump (for unidentified leakage) and the equipment drain sump (for identi-fied leakage).
For each drain sump, the licensee provides a Category 1 level switch (no redundant channels), LS-351 for the floor drain sump and LS-350 for the equipment drain sump. A high-high level alarm is provided in the control room for each sump.
For this variable RG 1.97 specifies category 1 instrumentation with continuous
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l indication from the bottom to the top of the sump. The RG 1.97 recom-mendations were evaluated by the BWR owners group which, upon due l
consideration of safety function, availability of other instrumenta-
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tion and system operation, concluded the instrumentation for drywell j
drain sump level could be classified as Category 3 and that continuous indication is not required. This categorization was addressed in the i
Peach Bottom SER and was found acceptable.
4.7 Drywell Atmosphere Temperature (Unit 3)
Regulatory Guide 1.97 considers the drywell atmosphere temperature
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to be a Type D, Category 2 variable and recommends monitoring instru-mentation for the range 40'F to 440*F. At the time the SER was issued, the licensee had provided instrumentation for the range-150'F to 300'F. However, it comrnitted to a modification to pro-vide the instrument range in accordance with the Regulatory Guide recommendations.
i The new temperature recorders with correct range were observed to have been installed in the control room of both Units 2 & 3.
For Unit 3, the replacement of the recorder was performed via MRF
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- 8709742 dated October 24, 1989.
4.8 Isolation Devices Where a Category 1 signal is used as input to a non-Category 1 L
system, Regulatory Guide 1.97 specifies the use of isolation devices which are fully qualified for use in Category 1 circuits. The-inspector examined the circuits involved and found that the isolation
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as well as the separation criteria had been properly implemented.
In-particular, the inspection determined that:
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a.
Digital and analog inputs to the plant computer were routed through a Class 1E multiplexer interconnected to the computer via Fiber Optic cables.
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Except as discussed in paragraph c., below, inputs to the l-non-safety related annunciator, for the variables evaluated, use Class IE, environmentally qualified, Foxboro contact output isolators, Model No. 2AO-L2C-R, Foxboro contact output isolators are acceptable isolating devices, c.
Digital inputs from the hydrogen / oxygen analyzers to the
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non-safety-related annunciator use circuit board type, Class IE relays with isolation performed by coil to contact separation.
The circuit board type relays supplied by Delphi are considered to be acceptable devices for signal isolation.
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5.0 Physical Inspection The inspector performed a physical inspection of display instruments
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located in the control room, and local instruments located in various areas of the Reactor Building.
For the display instrumer.ts (indicators and recorders). the inspector verified instrument function, instrument range and the yellow marker identification.
For the local mounted instruments, the inspector verified instrument mounting and supports, separation of cable routing and instrument tubing for redundant instrument channels. Within the scope of this inspection no deficiencies were observed.
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6.0 Surveillance, Testing and Calibration The surveillance tests and calibrations of all RG 1.97 Category 1 Instruments are perf ormed by the I&C maintenance department. The licensee employs a computerized data base for scheduling and tracking instrument calibration. The inspectors reviewed the data base-for the instruments inspected, the frequency of calibration, and the calibration expiration date.
The inspector conducted a review to determine that procedures are in place for the performance of the cali-bration. The inspector identified a calibration record deficiency as described in paragraph 4.3 of this report.
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7.0 Unresolved items Unresolved items are matters about which more information is required in order to oetermine if they are acceptable items or violations. An unresolved item identified during this inspection is discussed in Details, Paragraph 4.3 of this report.
8.0 Exit Meetina The inspectors met with licensee representatives (denoted in Details, Section 1.0) at the conclusion of the inspection on January 12, 1990.
The inspectors summarized the scope of the inspection, the inspection findings and confirmed with the licensee that the documents reviewed by
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the team did not contain any proprietary information. The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information.
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Attachment
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1.1 Philadelphia Electric Company
- J. W. Cornell, Nuclear Engineering, EEI
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- T. E. Cribbe, Regulatory Engineer
- K. Cutler, I&C Engineer
- D. Foss, Licensing
- J. F. Franz, Plant Manager i
- S. Kincaid, Nuclear Engineering, EEI Brancit
- R. S. Ogitis, Engineer J. O'Hara, Senior Engineer J. R. Rainet, Maintenance Superintendent
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- J. C. Rovansek, Nuclear Quality Assurance J. J. Stanley, Engineer-Maintenance Services G. Termine, Engineer 1.2 U.S. Nuclear Regulatory Commission
J. J. Lyash, Senior Resident Inspector
- R. J. Urgan, Resident Inspector
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- Denotes those present at the exit meeting on January 12, 1990.
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