ML18018B970
| ML18018B970 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/03/1985 |
| From: | Zimmerman S CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-2.F.1, TASK-TM NLS-85-109, NUDOCS 8506060463 | |
| Download: ML18018B970 (11) | |
Text
REGUI A Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)
I ACCESSION NBR;8506060063 DOC ~ DATE 85/06/03 NOTARIZED:
NO FACIL:50-400 Shearon Harris Nuclear Power Planti Unit 1i Carolina AUTH'AME AUTHOR AFFILIAT'ION ZIMMERMANiS,R.
Carolina Power 8 Light Co.
RECIP ~ NAME RECIPIENT AFFILIATION DENTONgH ~ Ro Office of Nuclear Reactor Regulationg Director DOCKET 05000000
SUBJECT:
Forwr ds addi info re compliance w/Reg Guide 1,97~Rev 3<per NRC 850124 request, Info addresses util exceptions to reg guide 8 notifies of two addi deviations due to design finalization (ref NUREG-0737'tem II', 1).
DISTRIBUTION CODE:
A003D COPIES RECEIVED:LTR ENCL 'IZE:
TITLE: OR/Licensing Submittal j Suppl 1 to NUREG 0737(Generic Ltr 82"33)
NOTES:
RECIPIENT ID CODE/NAME, NRR LB3 BC INTERNALS ADM/LFMB NRR PAULSONgN NRR/DHFS/PSRB NRR/DL/ORB5 NRR/DSI/ICSB AB REG F IL EXTERNAL; ?LlX NRC PDR COPIES LTTR ENCL.
7 7
1 0
1
?
2 5
5 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME IE/DEPER/EPB NRR/DHFS/HFEB NRR/DL/DRAB NRR/DSI/CPB NRR/DS I/METB NRR/DSI/RSB RGN2 LPDR NSIC COPIES LTTR ENCL 3
5 5
1 1
1 1
1.
1 1
1 1
1 1-1 1
TOTAL NUMBER OF COPIEP REQUIRED:
LTTR 36 ENCL 35
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Mr. B. C. Buckley (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC-RII)
Mr. 3oe 3oyce (NRC-ICSB)
Mr. Travis Payne (KUDZU)
Mr. Daniel F. Read (CHANGE/ELP)
Wake County Public Library Mr. Wells Eddleman Mr. John D. Runkle Dr. Richard D. Wilson Mr. G. O. Bright (ASLB)
Dr. 3. H. Carpenter (ASLB)
Mr. J. L. Kelley (ASLB) 8506060463 850603 i
PDR ADOCH 05000400 F
PDR 411 Fayettevilte Street o P. O. Box 1551 o Raleigh, N. C. 27602
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ATTACHMENT 1 RESPONSE TO NRC'S REQUEST FOR ADDITIONALINFORMATIONON REGULATORY GUIDE 1.97
RESPONSE
In response to your recent request for additional information pertaining to Regulatory Guide (RG) 1.97, Carolina Power R Light Company (CPRL) hereby submits the following for your consideration:
Section 3.3 of your request for additional information addresses the exceptions CPRL has taken to the guidance of RG 1.97.
Based upon a meeting with the NRC staff in Bethesda, Maryland on March 22, 1985 and the clarifications provided at that time, we therefore submit the following to address each of the items.
Item 3.3.1 - Neutron Flux CPRL hereby commits to provide instrumentation for this variable in accordance with RG 1.97.
Item 3.3.2 - Reactor Coolant System (RCS) Soluble Boron Concentration Being addressed as TMI Item II.B.3.
Item 3.3.3 - RCS Hot and Cold Leg Water Temperature CPRL hereby commits to provide indication for the third loop on the Main Control Board (MCB) for both RCS Hot and Cold Leg Water Temperature.
Item 3.3.0 - Radioactivity Concentration or Radiation Level in Circulating Primary Coolant The NRC staff has concluded that the instrumentation supplied for this variable is
- adequate, and therefore acceptable.
Item 3.3.5 Accumulator Tank Level and Pressure Neither the instrumentation provided for accumulator level or pressure indication are environmentally qualified to a harsh environment.
These variables are monitored as required by the Technical Specifications (TS) during normal plant operation to maintain the accumulator in an "as-ready" condition.
As stated previously, safety grade isolation valve indication is provided, and since the system is passive, power to the valve is locked out at the circuit breaker.
Therefore, no immediate operator action is required or possible until power is restored at the circuit breaker.
We agree that the instrumentation is part of a safety-related system, but it is important to remember that this is a passive system and it is not needed post-accident.
The accumulator is provided for cold leg injection for a major loss of coolant accident.
The pre-accident (Technical Specification) limits on accumulator volume and pressure ensure the assumptions used for accumulator injection in the safety analysis are met.
The instrumentation is no longer required following accumulator injection.
( I3350CM/ccc )
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The injection lines are isolated during post-accident recovery by procedure on RCS pressure.
Thus, RCS pressure is the key variable and this instrumentation is qualified for post-accident conditions and is Class IE. At best, accumulator level and pressure would be considered back-up variables, which the Regulatory Guide states should be high quality commercial grade. These variables are not relied upon post-accident, therefore, we request an exception to the Category 2 requirements for post-accident environmental qualification of the accumulator tank level and pressure instrumentation.
Additionally, RG 1.97 requires that accumulator level be monitored between 10 and 90 percent of volume.
The SHNPP monitored volume corresponds to between 71.2 and 60.1 percent of volume.
Appropriate values have been addressed in the SHNPP TS.
Therefore, for the same reasons cited above, the monitored span for SHNPP is adequate.
Item 3.3.6 Quench Tank Temperature The Pressurizer Relief Tank at SHNPP is non-nuclear safety and simply provides a
'eservoir for several radioactive fluid flow sources.'vailability or non-availability of the Pressurizer Relief Tank has no impact on the ability to safely mitigate an accident condition.
If the desire for this instrumentation is to provide indirect indication of flow from the pressurizer safety or relief valves, then we submit that we already have direct position indication for the pressurizer safety and relief valves which are qualified.
As a back-up to this position indication, non-qualified temperature indication is provided on the discharge header from the pressurizer power operated relief valves and in each safety relief valve discharge line.
The range for these temperature indicators is 0-000'F and they are continuously displayed on the MCB.
Item 3.3.7 - Steam Generator Level SHNPP does meet the range requirements as stipulated in RG 1.97 for wide range level indication.
Since SHNPP is a 3-loop plant, our interpretation of the guidance is that only single channels are necessary for wide range indication.
However, the operator does have sufficient information diverse from the wide range steam generator level to monitor the operation of secondary heat sinks.
Each steam generator is equipped with four narrow range'evel protection channels.
Additional diversity is provided by Auxiliary Feedwater (AFW) flow, steam generator
- pressure, and RCS pressure indication.
By comparing the AFW flows and steam pressure of each steam generator in conjunction with the narrow or wide range indication, the operator can determine that a particular steam generator is operating~differently from the other steam generators.
Additionally, by monitoring the narrow range indicators, the operator can react to decreasing level situations.
In light of the above and the fact that SHNPP has automatic AFW initiation via narrow range indication, the existing indication is sufficient and meets the intent of RG 1.97.
Item 3.3.8 Make-Up Flow-In, Letdown Flow-Out, Volume Control Tank Level These portions of the chemical and volume control system are not part of the Engineered Safety Features System.
As such, they are isolated on an accident signal and are neither required for accident mitigation or safe plant shutdown.
Therefore, CPRL requests an exception to the equipment qualification requirements of RG 1.97 for these variables.
(1335DCM/ccc)
Item 3.3.9 - Component Cooling Water Flow to ESF System Component Cooling Water (CCW) flow indication is considered to be a back-up variable to the existing Category 2 key variables which demonstrate CCW flow.
The key variables used to monitor system performance are component cooling water heat exchanger outlet temperature and pressure.
These variables are
- Category 2 and monitored on the main control board.
CCW pump status is also available on the main control board.
Additionally, CCW flow leaving the containment from the reactor coolant pumps is monitored by Class lE flow switches to indicate loss of flow. Therefore, the existing indication meets the intent of RG 1.97.
(13350CM/ccc )
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ATTACHMENT2 SUPPLEMENTAL INFORMATION:
(1)
Item D.l.2, RHR Heat Exchanger Outlet Temperature - The existing range for SHNPP is 50'F to 000'F.
Regulatory Guide 1.97 calls for 00'F to 350'F.
The existing range is sufficient and meets the intent of RG 1.97.
(2)
Item E.3.2, Particulates and Iodines - Available sampler flow devices do not have the capability to maintain isokinetic conditions per RG 1.97, (i.e., 096 to 11096 of design flow).
- However, in accordance with NUREG-0737, Item II.F.1,, clarification 3, the sampler will have the capability to maintain isokinetic conditions with a variation of stack or duct design flow of +2096.
Existing flow transmitters willmeasure the effluent flow of gases between 096 and 11096 of design flow. Therefore, the system design meets the intent of RG 1.97.
(1335DCH/ccc)
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