ML17251A692
| ML17251A692 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/19/1986 |
| From: | Kober R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Lear G Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-2.B.3, TASK-2.F.2, TASK-TM GL-86-10, IEIN-84-09, IEIN-84-9, TAC-51093, NUDOCS 8606240176 | |
| Download: ML17251A692 (35) | |
Text
REQULATO INFORNATION DISTRIBUTION~STEN (R IDS)
ACCESSION NBR: 8606240176 DOC. DATE: 86/06/19 NOTARIZED: NO DOCNET 0 FACIL: 50-244 Robert Emmet Qinna Nuclear Plant> Unit 1> Rochester 0 05000244 AUTH. NANE AUTHOR AFFILIATION KOBER> R. W. Rochester Qas Sr Electric Corp.
RECIP. NAME REC I'P I ENT AFFILIATION LEAR> Q. E. PWR Prospect Directorate 1
SUBJECT:
Forwards response to N Fairtile 860414 ltr re aspects of Reg Quide 1. 97 identified in Section 6. 2 of Suppl 1 to NUREQ-0737. Concerns expressed in 860414 technical evaluation rept @ equipment qualification per Reg Quide 1. 97 addressed.
DISTRIBUTION CODE: AOOBD COPIEB RECEIVED: TR TITLE: OR/Licensing Submittal: Suppl 1 l ENCL JSIZE:
to NUREQ-0737(Qeneric Ltr 82-33) l NOTES: License Exp date in accordance with 10CFR2> 2. 109(9'/19/72). 05000244 RECIPIENT COP IES RECIPIENT COPIES ID CODE/NAl'1E LTTR ENCL ID CODE/NANE LTTR ENCL PWR-A ADTS 1 1 PWR-A EB 1 1 PWR-A EICSB 2 2 PWR-A FOB 1 1 PWR-A PD1 LA 1 1 PWR-A PD1 PD 7 7 FAIRTILE, N 1 1 PWR-A PSB 1 PWR-A RSB 1 1 INTERNAL:, ADN/LFl1B 1 0 IE/DEPER/EPB 3 3 NRR BWR ADTS 1 NRR PAULSON> W 1 NRR PWR-B ADTS 1 NRR/DHFT/NTB 1 NRR/DSRO ESPRIT 1 1 A)SR 1 1 NRR/DSRO/RSIB 1 1 1 1 RQNi EXTERNAL: LPDR 1 NRC PDR NSlC 1 1 TOTAL NUl'lBER OF COPIES REQUIRED: LTTR 32 ENCL 31
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~ r ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649.0001 ROGER W. KOBER vIce pResIDENT TELEPHONE eLCCTRIC Si STEAM PRODUCTION AREA CODE TIS 546-2700 June 16< 1986 Director of Nuclear Reactor Regulation Attention: Nr. George E. Lear> Chief PWR Project Directorate No. 1 U.S. Nuclear Regulatory Commission Washingtonr D.C. 20555
Subject:
Regulatory Guide 1.97 Review R. E. Ginna Nuclear Power Plant Docket No. 50-244 TAC No. 51093
Dear Hr. Lear:
This submittal is in response to the letter of April 14< 1986 from Norton Fairtile of the NRC to Roger Koberi and addresses those aspects of Regulatory Guide 1.97 identified in Section 6.2 of NUREG-0737I Supplement No. l. Attachment A to this letter responds to the concerns of the Technical Evaluation Report accompanying the NRC April 14 letter. Attachment A also addresses scheduling for modifications necessary to meet our commitments and addresses equipment qualification as Guide 1.97 equipment.
it may apply to Regulatory V y truly yoursi
~@4/
Roger W. Kober 860624017b 8b0619 PIID ADOCK 05000244 PDR P I(
ATTACHMENT A Regulatory Guide 1.97 Review June 16'986 The responses below are identified consistent with the paragraph numbers of the EGGG report< "Conformance to RG 1.97> R.
E. Ginna Nuclear Power Plant~" attached to the April 14i 1986 NRC letter.
3.1 Adherence to RG 1.97 RGGE has not provided a specific completion date for compliance with Section 6.2 of NUREG-0737< Supplement l.
Dates identified in the RGSE letter of February 28> 1985 were anticipated completion dates for known modifica-tions. Completion dates for additional known modifica-tions are identified later in this response. Modifica-tion completion dates for RG 1.97 modifications not previously committed to> or for which agreement has not been reached between RGGE and the NRC< will be negotiated< if necessary< with the NRC project manager.
It should be noted that RG 1.97 specifies that Category 2 items should be environmentally qualified to RG 1.89 and NUREG-0588. Since the issuance of the Regulatory Guide> 10CFR50.49i "Environmental Qualification of Electrical Equipment>" has been issued> and implemented at Ginna Station. This regulation defines the evaluation process required to define which equipment should be environmentally qualified. That equipment includes those items of electrical equipment required to ensure (i) the integrity of the reactor coolant pressure boundary< (ii) the capability to shut down the reactor and maintain it in a safe shutdown condition> and (iii) the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the 10CFR100 guidelines.
10CFR50.49 also specifies that non-safety-related equipment which could cause failure of the above equipment> and certain post-accident monitoring equip-menti should be environmentally qualified. RGKE agrees that the scope of 10CFR50.49 is appropriate for equipment ensuring the performance of the three critical safety functions. In terms of post-accident monitoring<
only Category 1 instruments and certain designated Category 2 instruments warrant inclusion under the rule.
Environmental qualification determinations are provided in RGGE's 10CFR50.49 compliance documentation> rather than in the submittals associated with Regulatory Guide 1.97.
3.2 T e A Variables RGGE has completed its review of Type A variables> and included them in the modified "USNRC Reg. Guide 1.97 Revision 3 Comparison Table" (Attachment B). All Type A variables are considered Category 1> unless specific exceptions are taken.
Instrumentation not previously shown on the table but categorized as Type A variables are standby auxiliary feedwater (SAFW) flow< SG Level (narrow range)~
pressurizer pressure> and NaOH tank level. All of these
'instruments meet Category 1 requirements, except NaOH tank level.
The purpose of NaOH tank level is to determine whether
~
or'ot sump recirculation should be performed with spray flow> or without (if NaOH tank level is greater than 40%i the CS system is to be actuated during recircula-tion). RGGE is presently evaluating sump pH calcula-tions> to ensure the necessity of this provision. If this provision is determined to be necessary< RGGE will plan to upgrade this instrumentation. Otherwise< RGGE will justify the elimination of this instrument as a Type A variable. This evaluation is scheduled to be completed by September 16< 1986.
3.3 Exce tions to RG 1.97 3.3.1 Neutron Flux For Ginna Station applications< source and intermediate range neutron flux instrumentation is not required to be Category 1. These instruments, are not used as a primary means of defining operator actions following a design basis event (therefore> they are not Type A variables);
they are not used to mitigate a design basis event< such that a safety function (as defined in 10CFR50.49 and Regulatory Guide 1.29) would be compromised; and they are not the only means available to ensure reactor subcriticality (boron concentration using the post-accident sampling system is available). Therefore< no specific safety need exists to justify the upgrade of source range and intermediate range neutron flux instruments to Category 1 requirements.
In addition< the NRC Staff has determined in other instances that neutron flux indication is not required to assure safe shutdown. 10CFR50> Appendix R> Section III.L.2.d states that "the process monitoring function shall be capable of providing direct readings of the process variables necessary to perform and control" the reactivity control function. ISE Information Notice 84-09 provided a listing of instrumentation preferred by the Staff to demonstrate compliance with the regulatory provision. Generic Letter 86-10 states that "while this y
tl
~i I I
b
3 guidance provides an acceptable method for compliance with the regulation> it does not exclude other alternative methods of compliance. Accordingly> a licensee may propose to the Staff alternative instrumentation to comply with the regulation (e.g.>
boron concentration indication)." Thus< proposals addressing the instrumentation guidance of Regulatory Guide 1.97 which are consistent with Staff interpreta-tions of the Appendix R rule should be found acceptable on technical merits. RGSE has previously evaluated the merits of sampling for boron concentration as explained in our RG 1.97 letter of February 28, 1985. In addition< an evaluation was provided for the implementation of item II.B.3 of NUREG-0737> (Post Accident Sampling System)> in the NRC's SER dated April 24'984.
It should be noted is that power range neutron flux environmentally qualified< per instrumentation not 10CFR50.49. This is not an exception to Regulatory Guide 1.97 or 50.49> however< since this instrumentation performs a required safety function only for design basis events not causing a harsh environment or has completed its safety function prior to exposure to the harsh environment< for events such as rod withdrawal or ejection or RCP seizure.
RCS Soluble Boron Concentration The NRC TER notes that resolution of items on this issue are addressed in NUREG-0737 reviews. Item II.B.3 of NUREG-0737 was resolved in the NRC's SER of April 24>
1984.
De rees of Subcoolin Item II.F.2 of NUREG-0737 was reviewed and approved by the NRC in the SER dated September 7, 1980. The Ginna Station Emergency Procedures provide for primary subcooling information to be generated by calculations based on core exit thermocouple temperature and RCS wide-range pressure. The effective range of this parameter calculation exceeds the recommendation of the regulatory guide. This information is also automatically calculated and displayed on the SAS. The subcooling meter which is based on RC temperature and RC wide-range pressure and ha's an indication of 0-100 0 F subcooled> is a backup information display. Thus>
considered that the present Ginna Station arrangement is it is acceptable based upon NRC approval in the September 7 i 1980 SER.
Containment Isolation Valve Position In RGSE's review of equipment required to meet 10CFR50.49> containment isolation valve position
indication was specifically considered. In our correspondence with the NRC relative to Environmental Qualification> it has been noted that failure of the valve position indication would have no adverse effect on the isolation capability of the valves> and would not result in any inappropriate operator action. Therefore>
valve position indication is a confirmatory type display only whose failure would not result in any safety consequences.
As noted in EGGG's TER< the issue of environmental qualification is best addressed in the resolution of 10CFR50.49, rather than in RG 1.97 discussions.
3.3.5 Radioactivit Concentration on Radiation Level in Circulatin Primar Coolant The EGGG TER found the instrumentation provided for this variable to be acceptable. No further response is required.
3.3.6 Radiation Ex osure Rate
-5 -4 to Area radiation monitors> with a range of 10 or 10 10 R/hr> have been installed. These are Category 2 instruments< and meet NRC requirements.
3.3.7 RHR Heat Exchan er Outlet Tem erature RGSE has calculated the maximum temperature out of the RHR heat exchangers> during post-LOCA sump recircula-tion. Assuming a worst-case single 0 failure and minimum flog rates> this temperature is 196 F. A margin of 114 F0 to the top of the installed instrument range (310 F) is considered sufficient to compensate for equipment or calculational uncertainties. Therefore<
modifications 0to conform with the generic guidance (top of range = 350 F) are not considered necessary.
3.3.8 Accumulator Tank Level and Pressure and Boric Acid 3.3.9 Char in Flow The EGGG TER found the instrumentation provided for this variable to be acceptable. No further response is required.
3.3.10 Low Pressure In'ection S stem Flow The TER notes that RGSE did not provide the information required by Section 6.2 of Supplement No. 1 to NUREG-0737. This information was provided in our February 28<
1985 letter under the title< "RHR System Flow". The RHR (LPI) flow meets the requirements of NUREG-0737>
Supplement 1, Section 6.2, as a Category 1 item, except that it Procedures<
is not redundant. According to the Emergency it is used only to decide whether to go to
low head sump recirculation> or to go to high head sump recirculation. The RHR flow is only one parameter which can be used for this purpose. Other parameters> such as safety inject'ion flow> and RCS pressure> will also provide the necessary information (e.g.I if RCS pressure is above the shutoff head of the RHR pumps when RWST level reaches 15%I high head recirculation would be required). Thus, it is not considered that lack of redundancy for this parameter would prevent proper operator action.
Pressurizer Heater Status The TER implies that pressurizer heater current instrumentation is required to ensure that the diesel generators will not be overloaded. Loading of the pressurizer heaters onto the diesel generators was previously discussed with the NRC> and the acceptability of RGGE's resolution was determined in the NRC's SER of July 7I 1980< "TNI Lessons Learned Category A." No reliance on or need for pressurizer heater current instrumentation was defined during this acceptance review. Based on that acceptance> it is not considered that pressurizer heater current instrumentation is required for RG 1.97.
Quench Tank Tem erature RGSE's range is 0-300 0 FI compared to the recommendation of 50-750 F. The tank rupture disk pressure is 100 psigI corresponding to a temperature of 328 F- Thusj a small portion of the possible temperature range which could be experienced in this tank would not be provided to the operator.
The purpose> presumably< of providing quench tank temperature is to determine if a reactor coolant leak from the pressurizer safety or relief valves exists. At Ginna Station Category 1 instrumentation is provided for the pressurizer relief valve and pressurizer safety valve position indication. Thus> RGSE considers that sufficient information is provided to the operator to inform him of events which could indicate adverse conditions in the reactor coolant pressure boundary.
The pressurizer relief tankI or quench tank> is provided only to prevent the spread of contamination within containment and is not required for accident mitigation>
indicationI or recovery. Furthermore> any tank temperature above normal (well below 300 F) would certainly provide the operator with indication of an unusual situationI which would be verified by other available instruments. ThereforeI RGSE does not consider that any safety reason exists for modifying the instrument range.
(I tl II 4 E
3.3.13 Steam Generator Level (Hide Ran e)
A review of the Ginna Station Emergency Procedures has shown that this parameter is not a primary parameter for providing necessary operator information. Safety actions are based on SG level (narrow range) AFH flow <
and main steam pressure. All of these instruments are Category 1 and thus are redundant> independent and satisfy the single failure criterion.
r,,
generator level> wide range< is used in the Ginna
'team Station Functional Restoration procedures. (The FR procedures describe contingency actions for situations beyond the station design basis.) It is used in combination with pressurizer pressure such that any one of the three signals (pressurizer pressure< SGlA level-wide> SG 1B level-wide) provide the same guidance to the operator. The wide range level instrumentation meets all Category 1 requirements< except that it is not SG redundant for each steam generator. Since the SG level wide range instrumentaton is not used in the Ginna Station Emergency procedures< and is used only in combination with other instrumentation in the FR procedures< it is considered only as a useful backup instrument. RGGE does not consider that any safety justification exists to install redundant wide range level instrumentation for each steam generator.
3.3.14 Containment S ra Flow During the initial injection phase following an SI exists.
signal> no containment spray flow indication Pump status is available> however. Since no control functions are dictated by the availability of this parameter< and the containment spray system itself is single failure proof> no need for CS flow indication exists. During the sump recirculation phase following a LOCA> CS flow can be determined by comparing RHR discharge flow to the CS and SI pumps (FT 931A<B) to the indicated SI flow (FT 924, 925). Both of these sets of instrumentation meet Category 1 requirements. In addition> containment pressure and sodium hydroxide tank level provide indication of proper spray system operation. Thus> sufficient information is provided to perform all required safety functions.
3.3.15 Containment Sum Hater Tem erature RGSE is providing> as part of the RVLIS> an RTD which monitors sump temperature. This instrument< being part of the RVLIS> is Class 1E. The implementation date for RVLIS is Narch 20'987's indicated in an RGGE letter of August 7> 1984. Indication of sump water temperature will have a range of 0-360 F>will will be displayed on the plant process computer, and be considered Category 2 instrumentationi as suggested in RG 1.97.,
E N
8 PI
Makeu Flow In The EGGG TER found the instrumentation provided for this variable to be acceptable. No further response is required.
CCN Tem erature to ESFs The EGGG TER found the instrumentation provided for this variable to be acceptable. No further response is required.
Com onent Coolin Nater Flow to ESF S stems RGGE provides redundant component cooling water pumpsi with pump status indication> as well as CCW surge tank level indication in the control room. Also< alarms are provided for the following: low surge tank level> low system flow, low system pressure> and low CCW flow from the RHR> CS and SI pumps. Thus> substantial information exists to verify operability of the CCW system.
The CCN system is aligned to provide cooling water flow to the required ESF components> with no required manipulations. The combination of redundancy and normal alignment ensure that< even assuming a worst-case single failure> no loss of required safety function can occur to more than one train. Thus> RGGE does not consider the upgrade of the present instrumentation from alarms to control room indication to be justified based on safety considerations.
Radioactive Gas Holdu Tank Pressure The tank pressure is normally maintained below a maximum pressure of 100-110 psig. The indicated range of 0-150 psig provides substantial margin over this range> and is equal to the relief valve setpoint and design pressure of the tank. RGGE considers that appropriate actions if possible< would be taken prior to the time that 150 psig were reached (or actions would be taken if off-scale).
the four pressure gauges indicated high It is not clear what the purpose would be of indicated pressures greater than 150 psig. Decay tank rupture analyses have been performed per Chapter 15 of the UFSAR, with radiological consequences well below Part 100 guidelines.
RGGEr therefore< does not consider that there is a safety reason to modify the tank pressure instru-mentation to provide the generic range suggested in RG 1.97.
JA H
N 1 '
3.3.20 Accident Sam lin The NRC TER noted a few minor deviations from the guidance of Regulatory Guide 1.97 regarding the range of sampled parameters and noted that these deviations would be addressed under the review of NUREG-0737 item II.B.3.
An NRC SER dated April 24i 1984 determined the acceptability of RGSE's resolution of item II.B.3 of NUREG-0737.
ATTACHMENT B USNRC Regulatory Guide 1.97, Revision 3 Instrumentation Comparison Table Rochester Gas and Electric Corporation R.E. Ginna Nuclear Power Plant Docket. No. 50-244 June 16, 1986
>j I pl h 4
June 16, 1986 ROCHESTER GAS 8 ELECTRIC USNRC REG. GUIDE 1.97 REVISION 3 COMPARISON TABLE Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate or Present Ginna Status for EOPs Existin Confi uration Neutron Flux 10 to Existing intermediate and source No See Attachment A, item 3.3.1 100$ power range not qualified to Category 1 Control Rod Full in or Existing No N/A Position not full in RCS Soluble 0-6000 ppm Available on PASS, No See Attachment A, Item 3.3.2 Boron Concent. System Range: 50-6000 ppm RCS Cold Ieg 50-'700 F Existing TE-409B-1 and TE-410B-1 Yes N/A Temperature (range 0-700 F)
(Type A)
RCS Hot Ieg 50-700oF Existing TE-409A-1 and TE-410A-1 Yes N/A Temperature (range 0-700 F).
(Type A)
RCS Pressure 0-3000 psig PT-420A feeds PR-429 (0-3000 Yes N/A (Type A) psig) and is Category 1; PT-420 feeds PR-420 (0-3000 psig) and is Category-I.
Core Exit 200-2300 F Category 1 thermocouple system Yes See Attachment A, item 3.3.3 Temperature has 0-2300 F range.
0 June 16, 1986 Schedule for Upgrade Required NRC Required or-Justification of Variable Ran e Cate o Present Ginna Status for EOPs Existin Confi uration Standby Auxiliary Plant Specific 1 Existing Yes N/A Feedwater Flow (Type A)
Pressurizer Plant Specific Existing Yes N/A Pressure (Type A)
Sodium Hydroxide Plant Specific 1 Existing Yes See Attachment A, item 3.2 Tank Level (Type A)
Coolant Ievel in Bottom of hot leg 1 Installed; in test phase No To be operable as of 3/20/87 Reactor to top of vessel as discussed in RGB letter of 8/7/84.
Degrees of Sub- 200~F sub- Existing, (range: 0-lOO~F Yes See Attachment A, item 3.3.3 cooling cooling to 35 F subcooling) superheat Containment Sump Plant specific 2 Existing, Sump A: LT-2039 and No N/A Narrow Range LT-2044 (range: 0-30 ft.)
Containment Sump Plant specific 1 Existing, Sump B: LC-942(A-E) Yes N/A Wide Range and LC-943(A-E) indication of 8, (Type A) 78,113, 180, 214 inches (214 inches = approx. 500,000 gal.
which was previously justified and accepted by NRC).
Containment 10 psia to Existing, PT-946 8 948 (10-200 Yes N/A Pressure 3 times design psia)
(Type A) pressure Containment Closed/not Existing, status lights No See Attachment A, item 3.3.4 Isolation Valve closed on MCB.
Position
0 1
June 16, 1986 Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate o Present Ginna Status for EOPs Existin Confi uration Radioactivity 1/2 to 100 Available with PASS system. No See Attachment A, item 3.3.5 Concentration times Tech.
or Radiation Spec. limit Level in R/hr Circulating Primary Coolant Analysis of 10 to 10 Existing capability No N/A Primary Coolant Ci/gm or TID-14844 source term in coolant volume 7
Containment 1 to 10 R/hr 1 Existing Yes N/A Area Radiation (Type A)
Radiation 10 to 10 Existing No See Attachment A, item 3.3.6 Exposure Rate R/hr (areas where access required to service equipment)
Effluent Radio-activity-Noble Gas:
-Condenser Air 10 to 10 Existing No N/A Ejector Exhaust uCi/cc
-Containment 10 to 10 Existing No N/A Purge Vent uCi/cc Exhaust
-Plant Bldg. 10 to 10 Existing No N/A Exhaust Vent uCi/cc
June 16, 1986
-Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate o Present Ginna Status for EOPs Existin Confi uration
-Vent from S/G 10 to 10 Existing Yes N/A Safety Relief uCi/cc 6 Atmospheric Dump Valves Effluent Radio-activity-Particulates and Halogens.
Sampling with Onsite Analysis Capability:
-Containment 10 to 10 Existing No N/A Purge Vent uCi/cc,.
Exhaust
-Aux. Bldg. 10 to 10 Existing No N/A Vent Exhaust uCi/cc Containment 0:.10$ Existing Yes N/A Hydrogen Concentration Radiation 10 to 10 Existing No See Attachment A, item 3.3.6 Exposure Rate R/hr in Areas Adjacent to Containment RHR System Flow 0-110/ design Existing, FT-626 (0-4000 gpm) Yes See Attachment A, item 3.3.10 (Type A) (Not redundant. SI flow or RCS pressure is used as backup indication)
tf iY
'll
June 16, 1986 Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate or Present Ginna Status for EOPs Existin Confi uration RHR Heat 0-350oP Existing, TE-627 to computer No See Attachment A, item 3.3.7 Exchanger Out- =(range: 0-310 F) let Temperature Accumulator 10-90$ volume 2 2larrow range instrument No N/A Tank Level 0-750 psig indicates +7 inches from and Pressure normal fill level for accurate Tech. Spec. compliance; 0-800 psig pressure Accumulator Closed or open 2 Existing, MOV 841 6 865 No N/A Isol. Valve position indicated on MCB Position Charging Plow 0-110'j, design 2 Existing ZT-128 (0-75 gpm, No N/A the maximum flow anticipated in normal operations)
SI Plow 0-110/ design 1 Existing FT-924 S 925 Yes N/A-(Type A) (0-1000 gpm)
RUST Level Top to bottom 1 Existing, LT-920 8 921 (0-100/) Yes N/A (Type A)
Reactor Coolant Electric Ammeter existing at 4KV Bus No N/A Pump Status current (0-1200A)
Primary System Closed/not Existing Yes N/A Safety Relief closed Valve Positions (PORV's 6 Code Safeties)
Pressurizer Bottom to top 1 Existing Yes N/A I,evel (Type A)
June 16, 1986 Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate or Present Ginna Status for EOPs Existin Confi uration Pressurizer Electric Por control group of heaters, No See Attachment A, item 3.3.11 Heater Status current ammeter existing in Aux. Bldg.
No ammeter for backup group, but have breaker position for both control and backup groups in Control Room.
Quench Tank Top to bottom 3 Existing, IT-442 (0-100/) No N/A Ievel Quench Tank 50-750~F 3 Existing, TE-439 (0-300oF) No See Attachment A, item 3.3.12 Temp.
Quench Tank 0 to design Existing, PT-440 (0-150 psig) No N/A Pressure pressure S/G I,evel Tubesheet to Existing, LT-460 6 470 input No See Attachment A, item 3.3.13 separators to LR-460 on MCB (0-518" H 2
0)
S/G Ievel Narrow Range Existing Yes See Attachment A, item 3.3.13 (Type A) 0-100$
S/G Pressure Prom atmos- Existing, PT-468, 469, 478, Yes N/A (Type A) pheric press. 479 (range: 0-1400 psig) to 20$ above lowest safety valve setting (13OO psig)
Safety/Relief Closed/not 1 Existing, main steam flow Yes N/A Valve Positions closed (flow only) PT-464, 46$ , 474, 475 (range:
or Main Steam 0-3.8 x 10 pph). Safety/
Plow relief valve positions only
. during high radiation in secondary sys.
0 June 16, 1986 Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate o Present Ginna Status for EOPs Existin Confi uration Main Feedwater 0-110$ design 3 Existing, FT-466, 4(7, 476, 477 No N/A Flow (range: 0-3.8 x 10 pph)
Aux. Feedwater 0-110$ design Existing Yes N/A Flow (Type A) flow Condensate Plant Specific 1 CST Transmitters LT-2022A Yes See Note 1 Storage Tank (Note 1) and LT-2022B are qualified; (Type A) read 0-24 ft.
Containment Spray 0-110/ design Containment spray flow itself No See Attachment A, item 3.3.14 Flow flow is not available, however, SI, RHR, and total flow are available - CS flow can be determined.
CV Fan Heat Plant Specific 2 CV fan 1A, 1B, 1C, 1D on/off No N/A Removal status at MCB, plenum exhaust temp.
CV Atmosphere 40-400 F 24 CV RTD's go to Ieak Rate No N/A TeIIlp ~ Test Panel; range 130 F Also, RTD's in plenum exhaust read 0-6000F n
Note 1: Condensate storage tank level is not redundant per tank; however the tanks are normally tied together and thus redundant indication is provided. Furthermore, the CST's are not located in a Seismic Category I building, although the instruments are Seismic Category I. (This is consistent with Section B (6th paragraph) of Regulatory Guide 1.97). However the Ginna Station arrangement is such that a completely qualified redundant Seismic Category I system, using the AFM pumps or the SAFE pumps, taking suction for the Service Mater pumps, which draw water from Lake Ontario, is available to provide an unlimited source of seismically qualified auxiliary feedwater to the steam generators.
this lack of redundancy or full seismic qualification is. of concern.
Thus, it is not considered that
I' W
June 16, 1986 Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate or Present Ginna Status for EOPs Existin Confi uration CV Sump Water 50-250 F To be installed as part of RVLIS No See Attachment A, item 3.3.15 Temp letdown Flow 0-110/ design 2 FT-134 (0-100 gpm) No M/A Volume Control top to bottom 2 IT-112 (0-100/) No N/A Tank Ievel Component Cooling 40-200 F TE-621 from CCW Hx goes to No N/A Water Temp. to computer (50-200 F)
ESF CCW Flow to ESF 0-110$ Design 2 Have low flow alarms .No See Attachment A, item 3.3.18
.Flow High Ievel top to bottom 3 L1001 (0-100/) No N/A Radioactive Tank 4 I,evel Radioactive Gas 0 to 150/ design 3 P1036, 1037, 1038, 1039 No See Attachment A, item 3.3.19 Holdup Tank Pressure (0-150 psig) design pressure 150 psig,-normal operation
.100-110 psig.
Emergency Vent Open/close Existing for containment vent No N/A Damper Position status on MCB
'ht June 16, 1986 Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate or Present Ginna Status for EOPs Existin Confi uration Status of Voltage, current 2 No N/A Standby Power pressure and Other Energy Sources Important to Safety (hydraulic, pneumatic):
-480 V Bus Existing diesel voltmeters 6 ammeters on MCB
-Instrument Bus Existing voltmeters on panels No N/A in control room; ammeters on inverters in battery rooms for bus lA 8 1C
-125 VDC Bus Existing voltmeters and No N/A ammeters in Control Room Radiation Expo- Range, location, 2 Existing procedures and equipment No N/A sure Meters and qualifi- are used to initiate emergency (continuous cation criteria measures in accordance with indication at to be developed Appendix I and II.H.5b and 6b fixed locations) to satisfy of NUREG 0654 and NRC approved NUREG-0654, plant Technical SpecificationsSection II.H.5b for compliance with 10 CFR 50 and 6b requirements Appendix I.
for emergency radiological monitors Airborne Radio- 10 to 10 Existing No N/A halogens and uCi/cc Particulates (portable sampling with onsite analysis capability)
June 16, 1986 t
Schedule for Upgrade Required NRC Required or Justification of Variable Ran e Cate or Present Ginna Status for EOPs Existin Confi uration Plant and 10 to 10 Existing No N/A Environs Radi- R/hg, photon ation (portable 10 to 10 instrumentation) rads/hr, beta radiations and low energy photons Plant and Multichannel Existing N/A Environs gamma ray Radioactivity spectrometer (portable instrumentation)
Wind Direction 0-360o Existing No N/A Wind Speed 0-67 mph Existing at 33, 150, 250 ft. No N/A elevations (range: 0-100 mph)
Estimation of Based on Existing, 2 RTD's at 33, 150, No N/A Atmospheric vertical 250 ft. elevations; delta T Stability temperatures between each elevation differences Primary Coolant Grab Sample Available with PASS system No See Attachment A, item 3.3.20 and Sump:
-Gross Activity 10 to 10 Ci/cc
-Gamma Spectrum Isotopic Existing No N/A Analysis
-Boron Content 0-6000 ppm (50-6000 ppm) with PASS No N/A
-Chloride 0-20 ppm 5 ppb 100 ppm lab analysis No N/A Content
June 16, 1986 Schedule for Upgrade Required NRC "-'equired or Justification of Variable Ran e Cate o Present Qiana Status for EOPs Existin Confi uration
-Dissolved 0-2000 (10-2000 cc/Kg) with PASS No N/A Hydrogen cc(STP)/Kg
-Dissolved 0-20 ppm (0.1 - 20 ppm) with PASS No N/A Oxygen
-pH 1-13 1-13 with PASS No N/A Containment Grab Sample Available with PASS No N/A Air:
-Hydrogen. 0-10$ Available with H2 monitors and PASS'o N/A Content
-Oxygen Content 0-30/ 0-30'/, with PASS No, N/A
-Gamma Spectrum Isotopic Existing No N/A Analysis