ML17277B156
| ML17277B156 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/05/1983 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0892, RTR-NUREG-892, RTR-REGGD-01.097, RTR-REGGD-1.097 GO2-83-1115, NUDOCS 8312130387 | |
| Download: ML17277B156 (14) | |
Text
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REGULATORY ORNATION DISTRIBUTION SYA (RIBS)
ACCESSION NOR 08312130387 DOC ~ DATE! 83/12/05 NOTARIZED:
NO DOCKET FACIL:50 397 WPPSS Nuclear Projects Unit 2E Nashington Public Powe 05000397
'AUTH INANE AUTHOR AFFILIATION SORENSONiGBC, Washington Public Power Supply System RECIP ~ NAME RECIPIENT AFFILIATION SCHHENCERE~B Licensing Branch 2
SUBJECT:
Forwards response to Reg Guide 1,97 re environ qualification of safety"related equipment
~ Info provides Justification for SSER3
- concerns, DISTRIBUTION CODE:
AOASS COPIES RECEIYEDILTR j ENCL i SIZE TITLE: OR/Licensing Submittal:
Equipment Qua'lification NOTES:
RECIPIENT ID CODE/NAME NRA LB2 BC 12 INTERNALS ELD/HDS2 1?
IE F ILE 09 NRR/DE/EQB 07 NRR ORAB 06 F IL 04 COPIES LTTR ENCL 1
0 1
1 1
2 2
1 1
1 RECIPIENT ID CODE/NAME AULUCKER~
01 GC 13 NRR CALVOEJ NRR/DL DIR 14 NRR/DSI/AEB RGN5 COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 EXTERNAl; ACRS 15 NRC PDR 02 NTIS 31 8
8 1
1 1
1 LPDR NSIC 03 05 1
1 1
1 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 24
~
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Washington Public Power Supply System P.O. Box 968 3000 George Washington Way Richland, Washington 99352 (509) 372-5000 8312130387 831205 POR AOOCX 0@000397 E
PDR December 5, 1983 G02-83-1115 Docket No. 50-397 Director of Nuclear Reactor Regulation Attention:
Mr. A. Schwencer, Chief Licensing Branch No.
2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Schwencer:
Subject:
NUCLEAR PROJECT NO.
2 REGULATORY GUIDE 1.97 EQUIPMENT QUALIFICATION
References:
1)
Safety Evaluation Report Related to the Operation of Supply System Nuclear Project No. 2, Docket No. 50-397, NUREG-0892, Supplement No. 3, dated May,1983 2)
G02-83-842, G.
C. Sorensen to A. Schwencer, "Nuclear Project No. 2, Environmental Qualification Report f'r Safety Related Equipment, September 1983", dated September 16, 1983 The Supply System has provided its response to Regulatory Guide 1.97 in Section 7.5 of the FSAR.
That Section identifies Category 1 and 2
equipment that is available 'to perform the post-accident monitoring function.
Attachment I is a list of this post-accident monitoring equipment that can be potentially exposed to a harsh environment.
Except as discussed below, this equipment is environmentally qualified, justified by previous submittal, Reference 2,
on Table B of the JIO, or purchased qualified for installation prior to fuel load.
A recent review of the Category 2 monitoring equipment identified the need to develop environmental qualification documentation for radiation elements and their supporting equipment that monitor reactor building exhaust air.
A Justification for Interim Operation for these pieces of equipment is attached.
e~
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Mr. A. Schwencer Page Two FSAR Table 7.5-1 presently shows Radiation Exposure Rate design criteria, as would be applied to area radiation monitors, as Category 2.
As provided in Revision 3 to Regulatory Guide 1.97, we will revise the FSAR to make such instruments Category 3, and they are not included in the Tables attached.
We appreciate your review and consideration of this justification.
While we judge that this response addresses this SSER concern satis-factorily, we are available to assist your review if necessary.
Very truly yours,
~c G.
C. Sorensen, Manager Regulatory Programs KRW/sms cc:
R Auluck -
NRC WS Chin
- BPA A
Toth NRC Site
0 P
ATTACHtlENT I 1o22 REG.
GUIDE 1.97 CATEGORY 1
E UIPHENT LOCATED IN A HAZARDOUS ENVIRONMENT E UIPHENT NO.
SR'-DET-1A thru D
SRM-EAtlP-1A thru D
MS-LITS-26A, D
MS-LITS-44A, ~B HS-PT-.51A, B
CMS-PT-1,2,5,6,7,8 CMS-LS-1 thru 4 CSP-RLY-V/10/R1 CSP-RLY-V/10/R2 CSP-RLY-V/10/R4 CSP-RLY-V/10/R5 CSP-RLY-V/10/CR CSP-RLY-V/8/R1 CSP-RL'Y-V/8/R2 CSP-RLY-V/8/R4 CSP-RLY-V/8/R5 CSP-RLY-V/8/CR CSP-RLY-V/7/R1 CSP-RLY-V/7/R2 CSP-RLY-V/7/R4 CSP-RLY-V/7/CR CAC-RLY-4A/CR1 CAC-RLY-4A/CR2 CAC-RLY-4B/CRl CAC-RLY-4B/CR2 CHS-LE-3A, B
CtlS-LE-4A, B
E UIPMENT NO.
CMS-LE-5A, B
Ct<S,-A)-1 thru 4 SPTM-TE-1A, B
SPTM-TE-2A, B
SPTH-TE-3A, B
SPTM-TE-4A, B
SPTH-TE-SA, B
SPTH-TE-6A, B
SPTM-TE-7A, B
SPTt1-TE-8A, B
SPTM-TE-9 thru 16 CMS-TE-1 thru 14 CMS-TE-24 thru 31 HS-POE-1A thru 4A MS-POE-1B thru 5B HS-POE-1C thru 5C tlS-POE-1D thru 4D MS-POT-1A thru 4A MS-POT-1B thru 5B MS-POT-1C thru 5C MS-POT-1D thru 4D CMS-RE-27E, F
SW-FE-j.A, B
Slt-FT-8A, B
Position switches for containment isolation valves
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ATTACHMENT I REG.
GUIDE 1.97 CATEGORY 2 EQUIPMENT LOCATED IN A HAZARDOUS ENVIRONMENT E UIPMENT NO.
MSLC-PS-7A thru 7D MSLC-PS-8A thru 8D MSLC-PS-20 MSLC-PS-24 MSLC-PS-25 MSLC-PS-60 MSLC-PS-70A thru 70D MSLC-PT-6A thru 6D MSLC-PT-10A thru 10D MSLC-PT-11 MSLC-PT-12A thru 12D MSLC-PT-13 MSLC-PT-23 RCI C-FE-1 RC1C-FT-3 HPCS-FE-7 HPCS-FT-5 LPCS-FE-2 LPCS-FT-3 RHR-FE-14A thru 14C RHR-FT-15A thru 15C SLC-FT-1 SLC-FE-1 RHR-TE-27A, B
SW-TE-1A thru 1D SW-FE-1A, B
SW-FT-BA, B
REA-RE-19A REA-SR-27A REA-RE-19 REA-F IS-1 REA-P I-14 REA-SR-27 REA-JB-SR27 REA-SR-37 REA-RV-1 REA-FCV-2 E UIPMENT NO.
REA-FE-8 REA-V-55 REA-FCV-1 REA-BV-1 REA-FT-10 REA-FR-94 REA-P/I-2 REA-P/ I-1 REA-PI-13 REA-PI -12 REA-P I-11 REA-PI-10 REA-PI-9 REA-PI-8 REA-PI-7 REA-PI-6 REA-PI-5 REA-PI-4 REA-PI-3 REA-P/P-2 REA-P/P-1 REA-FC-2 REA-FC-1 REA-SgRT-3 REA-SgRT-2 REA-Sg RT-1 REA-'FT-9 REA-FT-8 REA-FT-7 REA-FI-8 REA-FI-7 REA-DPI-4 REA-DPI-3 REA-DPI-2 REA-DPI -1 REA-FN-94 Emergency ventilation damper position switches, RHR valve position switches
E UIPMENT J USTIFICATION "823
- 1. 0 COMPONENT IDENTIFICATION EPNs:
REA-SR-27, 27A, and 37 including all subcomponents.
==
Description:==
Reactor Building Exhaust Stack Air Sample Racks Component Type:
Composite Rack consisting of Air Sampling and Radionuclide Analysis Instrumentation Manufacturer/Model:
Kaman Sciences Corp. /Model 952312 Nuclear Measurement/Model Pt.
8285501 Air Monitor Corp. /Model AMC-79-128
- 2. 0 ACCIDENT CONDITIONS Tem erature Relative Humidit Accident Profile:
Use Code:
Operability Time:
Radiation Zone:
Zone Dose:
84 1
4320 Hours R606A 2.4 x 104 Rads 22X 3.0 COMPONENT SAFETY FUNCTION The reactor building exhaust stack air monitoring instrumentation provides the operator with continuous indication of the radio-activity level in the stack air being released.
If the activity levels of the stack air begin to increase, the control room indi-cation and associated alarm provide information necessary for the operator to take corrective action before the limits specified by 10CFR100 are exceeded.
As part of Regulatory Guide 1.97 instrumentation, this monitoring system must provide continuous long-term indication of post accident effluent releases.
4.0 UALIFICATION STATUS
- 4. 1 Summar of uglification Status The design was finalized and this instrumentation was purchased before TMI (Regulatory Guide 1.97) requirements were imposed.
Subsequently, qualification was required by Regulatory Guide 1.97 and 10CFR50.49.
Complete equipment qualification docu-mentation is not presently available.
This rack is in a relatively mild environment.
That is, it is exposed to moderate accident temperature and radiation environments.
- However, radiation qualification data is not presently available.
'In the interim, the following justification is provided.
4 f
4.2 Parameters Re uirin Justification Radiation.
5.0 JUSTIFICATION FOR INTERIM OPERATION These sample racks are not exposed to harsh temperature and relative humidity profiles for which operation must be demonstrated.
They are exposed to a moderate radiation environment.
For"the worst case LOCA, the total integrated dose (T. I.D.) would be approximately lxl0" Rads after eight days (1.0 x 104 Rads is the threshold at which radiation qualification would be required) and 1.8x104 Rads after six months.
The components comprising this equipment were reviewed for radiation sensitive materials.
No components were found that had radiation sensitive materials at these levels.
Therefore, operability is assured for at least eight days by which point the plant's decay heat removal operations have been initiated.
Monitoring of effluents is critical until the plant has been depressurized and long-term cooling has been established.
This is because the magnitude of the potential fission product releases which could occur are greater when the plant is pressurized.
If all of the reactor building exhaust stack ai~ monitoring instru-mentation failed when the T. I.D. reached 1.0x10
- Rads, the safety objective would still not be compromised.
The removal of contamin-ants is performed by the Standby Gas Treatment System (SGTS) and its effectiveness is measured by the stack monitors.
The SGT system is a fully qualified safety related, dual train system.
Each train-is designed to remove containment and reactor building airborne contamination associated with the worst case LOCA and ensure that the activity in the air discharged to the reactor building exhaust stack is below the 10CFR100 limi'ts.
As documented in the Equipment gualification Report, each train has a complete set of qualified flow, temperature, and relative humdity instru-mentation.
Therefore, operation of the SGTS system can be monitored.
Continued observation of these normal performance indicators provides a level. of confidence that the Standby Gas Treatment System is operating normally a'nd that it is performing as designed, to reduce exhaust stack air activity levels below the 10CFR100 limits.
Also, fai lure of the Reactor Building Exhaust Stack Air monitoring system after eight days does not imply that all effluent monitoring has been eliminated.
Portable instruments can and would be positioned to measure off-site releases following an accident.
Long-term monitoring is assured by alternate means.
6.0 CONCLUSION
Interim operation is justified on the following basis; 1.
This entire monitoring system was designed in accordance with Supply System Specifications.
These specifications require that the system be capable of operating for anticipated tempera-ture and humidity harsh service conditions.
It is, therefore, reasonable to assume that this system will survive the environ-ment for which it was designed.
2.
Should the system fail, releases in excess of 10CFR100 will not occur unless accompanied by failure of both SGTS trains.
3.
If both the Reactor Building Exhaust Stack Air monitoring and the two SGTS trains fail, then off-site releases can be monitored by mobilization of portable monitoring equipment.
Sufficient time is available to accomplish this, since a harsh environment (i.e, TID > 104 Rads) is not experienced by the equipment until eight days after the accident.
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