ML18029A530

Forwards Response to Items Identified by Eg&G as Insufficient Re Conformance to Rev 2 to Reg Guide 1.97. Corrections to Original Response Will Be Submitted by 850508

ML18029A530
Person / Time
Site:	Browns Ferry
Issue date:	05/07/1985
From:	Domer J TENNESSEE VALLEY AUTHORITY
To:	Vassallo D Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8505140241
Download: ML18029A530 (24)

Text

REGULATORY ORMATION DISTRIBUTION SYSWR (RIDS)

ACCESSION NBRe8505100241 DOC ~ DATE! 85/05/07 NOTARIZED: YES DOCKET" 0 FACIL:50,. 259 Browns Ferry Nuclear Power Stations Unit li Tennessee 05000259=

50. 260 Browns Feiry Nuclear Power Stat)one'ni.t 2i Tennessee 05000260 50 296 Browns Ferry Nuclear, Power Stations Unit 3i Tennessee 05000296 AUTH',NAflE AUTHOR AF F ILIAT'ION DOMERiJ ~ Ai Tennessee Valley Authority RECIP ~ NAME~

RECIPIENT AFFILIATION VASSALLO'iDi B ~

Operating Reactors Branch,2

SUBJECT:

Forwards, response to items identified by EGLG as insufficient conformance. to Rev 2'o Reg Guide 1'7.

Corrections to original"response will be submitted by 850508

~

DISTRIBUTION CODE.:

A003D COPIES RECFIVED:LTR i" ENCL: J 'IZE'!

TITLE'. OR/Licensing Submittal:

Suppl 1 to NUREG 0737(Generic Ltr 82 33)

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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II May 7, 1985 Director of Nuclear Reactor Regulation Attention:

Mr. Domenic B. Vassallo, Chief Oper ating Reactor Branch No.

2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Vassallo:

In the Matter of the Tennessee Valley Authority Docket Nos.

50-259 50-260 50-296 We have reviewed your let;ter to H. G. Parris dated January 23, 1985 regarding the conformance to Regulatory Guide 1.97, Revision 2 for Browns Ferry Nuclear Plant.

Enclosed is our response to that letter regarding items EG8G, Idaho found insufficient.

We have also included corrections to our original response to Regulatory Guide 1.97.

Ron Roger s of my staff and Dick Clark of your staff on April 17, 1985 discussed an extension to May 8, 1985 for submitting this response.

If you have any questions regarding this matter, please get in touch with us through the Browns Ferry Project Manager.

Very truly yours, r

Subscrib d~d sworn to efore me t

~

day of TENNESSE VALLEY AUTHORITY J.

A. Domer, Chief Nuclear Licensing Branch 1985.

Notary Public My Commission Expires Enclosure cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II ATTN:

Dr. J. Nelson Grace, Regional, Administrator, 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. R. J. Clark Browns Ferry Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue

Bethesda, Maryland 20814 850S>eo~ei 8505O7 PDR AOQCK OM00259 F

PDR

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Enclosure

RESPONSE

TO NRC INTERIM REPORT ON CONFORMANCE TO REGULATORY GUIDE 1.97 FOR BROGANS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3

This enclosure provides information needed by EGKG Idaho, Inc. in order to complete review of Browns Ferry conformance to R.G. 1.97. It is being submitted in response to an NRC request dated January 22, 1985 (reference

1) which contained the NRC Interim Report on Conformance to Regulatory Guide 1.97 for Browns Ferry 1, 2, and 3.

Items are numbered so as to correspond to the item numbers in that report.

The Interim Report is based upon information provided by TVA to NRC in our letter dated April 30, 1984 (reference

2) in response to NUREG'737, Supplement 1.

Additionally, this enclosure contains some corrections to the original TVA response concerning R.G.

1.97 (reference 2).

Responses to EG&G Interim Report 3,3,1 s

C te o c

'on Several variables have been identified as Category 2 by R.G.

1.97 and submitted as Category 3 by Reference 2.

The following identifies and justifies the exceptions from Category 2

recommendations on a case-by-case basis for each of the variables involved.

(a) u ad'

'v't o

s s nd V

ow a

The instrument designed to perform these functions, RR-90-322A, was chosen to meet the requirements of NUREG 0737, Items II.F.1-1 and II.F.1-2, which are essentially the same as Category 3 recommendations.

This instrument is used to assess plant releases and no automatic or manual actions are required during a DBA that are based on its indication.

Therefore, a Category 3 instrument is justified for monitoring these variables.

(b) s fe a

e Pos t'n Reference 2, this variable was defined as Category 3

instead of the Category 2 required by R.G. 1.97.

This variable is monitored by the following systems:

coust'c n

o These instruments meet all Category 1 qualifications with the exception of single failure criteria and data recording.

These instruments have a

continuous real-time display by open-closed indicators.

Therefore, these instruments meet Category 2

requirements.

ocou These serve as a backup to the acoustic monitors and meet Category 3 requirements.

These instruments are displayed in the control room by multipoint recorder.

Since the acoustic monitor meets Category 2 criteria, R.G.

1.97 recommendations are met.

(c) c o C

s t'oo C

o RCIC flow indication is not classified as Class 1E

'instrumentation and therefore cannot meet Category 2

requirements.

The Browns Ferry FSAR does not classify RCIC as an ECCS system for mitigating design basis accidents nor is any credit taken for it in the accident analyses.

The RCIC system as a whole is not qualified as Class 1E, and, therefore, Class 1E qualification of the flow instrument is not required and a Category 3

instrument is sufficient to monitor this variable.

Responses to EGKG Interim Report (Continued) 3.3.1 e

0 c

(Continued)

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'-c-""-'-This Variab3.'eius'=monitored-'"by'a Class 1E=-instrument loop rccc-.:..-that.meets=all Category-1-'requirements:.except for v "."'.-iecorN,ng'".and redundancy.

Therefore, this instrument meets Category 2 requirements.

It was classified as Category~ in. reference 2'ecause we believe. that this meets the minimum post accident monitoring requirements.

I (e)

C CP P

The instr uments, used to monitor this variable are not environmentally qualified and,* therefore, cannot be classified. as Category 2.

No operator action is required based'on their indication. to mitigate a DBA.

Therefore, environmental qualification is not required and Category 3 instruments are sufficient for post-accident monitoJ ing.,

su Co CI w

s'du Both of these variables are monitored by the same instruments for each loop.

They do not meet the environmental qualification for Category 2.

No operator action is required based on their indication to mitigate a DBA.

Therefore, environmental qualification is not

required, and a Category 3 instrument is sufficient for post-accident monitoring.

Co o

LC s

e k

ev SLC storage tank level is monitored daily by LI-63-1A.

The SLC volume and concentrations are verified monthly.

For monthly surveillance, the level is verified manually at the SLC tank using a gage stick.

This ensures that level is maintained and does not rely entirely on a single level indicator. If SLC injection is initiated, procedures require continued operation until the SLC storage tank is empty, and therefore, no operator action is based on this level indicator for DBA.

Based on the

above, Category 3 is appropriate for this variable.

Responses to EG&G Interim Report (Continued) 3.3.1 e

n Cat o

c ons (Continued)

(h)

H a xc a

ut e em a u Coo 'a m

t

. o C

w s

Co Co These variables would be used for the operator to improve system operation over the minimum required for design basis behavior or to diagnose problems in the system.

No operator action is based on these variables in DBA or to ensure design basis behavior.

These instruments do not meet R.G.

1.97 Category 1 and 2 requirements for 1E or environmental qualification.

Category 3 is justified for these variables based on the above.

(i) e c

t' m

Pos No operator action is based on these variables in a DBA.

Each pathway has redundant dampers and thus no operator action is required to ensure isolation.

On this basis, they are not designated for environmental qualification and therefore, do not meet Category 2 requirements.

Dampers designated as having 1E power in Reference 2 meet Category 2 requirements other than environmental qualifications.

Those designated as having station power meet Category 3 only.

(j) t s

ow In the control room for units 1 and 2, instrument readings of current, voltage, frequency, and real and reactive power are available on each diesel generator.

There are indicating lights to indicate the status of the mode control and whether or not the diesel generator is operating.

A light is also provided for each diesel generator to indicate when the machine has been manually stopped in the presence of an accident signal.

Alarms are provided on each machine to indicate overload on the

machine, high field current, and a ground on the system.

Trip-out of the machine by any of the protective relays is also annunciated.

The unit 3 diesel generators are controlled similarly from a panel in the unit 3 main control room.

The indications which are used by the operator to control the diesel generators after DBA meet R.G.

1.97 requirements for monitoring Category 2

variables.

Responses to EG&G Interim Report (Continued) 3o'3 +2 ut n '

u t

vncw~~nec:

f ~ ~~or ~;w~l No addi:t'iona]; ~'r)formatiqj'"equqsged" ~-"",

3.3.3 Coo t L act,o I

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The range of reactor water level-, instrumentation 'does'ot.-

extend. below 1/3 core height,.

All automatic actions. occur with the 'reactor coolant, level above the Top. of Active Fuel (TAF) and. all manual operator actions to, mantain,adequate

.core cooling in a DBA are the same anywhere below 2/3 core height.

Therefore, the ability to monitor the lower 1/3 of core height would not enhance the operators abilty to ensure adequate core cooling in a DBA.

The range given in reference 2 is justified on this basis.

3.3.4 c o oo t

ssu No additional information requested.

3.3.5 D

u

- D w

u L

No additional information requested.

3.3.6 Co t ss No additional information requested.

3.3 7 Con a' Iso

'o os The three valves identified as needing surveillances or administrative controls which verify them closed (HCV-2-1383, HCV-33-1070, and HCV-74-722) are verified closed by their respective system operating instructions as are all other manual valves forming a containment boundary.

The two valve pairs in the sampling and water quality system (SCV-43-28AB and SCV-43-29 AB) are solenoid controlled valves that automatically return to the closed position, solenoids deenergized, when the control button is released.

They are operated at least monthly per sampling procedures and position verified at this time.

These valves are also situated such that flow out of the sample line would be obvious to operations personnel if a pair of valves remained open.

There is no operator action possible from the control rocm to close these valves in post-accident conditions.

Therefore, these valves are under local administrative control, and control room indi-cation is of no safety benefit.

Responses to EG&G Interim Report (Continued) 303 07 o

a' s

t'o o

(Continued)

The H 0 monitoring system was designed without position indi-catiok Fn individual valves.

These valves are proved operable quarterly by alternate

means, pulling and holding a vacuum on each line.

The status of the isolation signal to these valves is indicated in the control room.

This indication, along with the operability surveillance, provides adequate verification of valve position.

In addition, the H20 system is a closed qualified system that is designed to function under post LOCA conditions as part of the containment boundary and these valves are not required to preserve containment integrity.

3.3.8 d'a n

C c

m Co No additional information requested.

3.3.9 Co do The instrumentation scheduled for installation to monitor this variable meets Category 1 requirements with the exception of the environmental qualification for the drywell electrical penetrations.

These will be replaced according to the Browns Ferry Integrated Schedule.

All range,

accuracy, display and instrument locations will be in accordance with R.G. 1.97.

The following is information to supplement reference 2.

Range:

1 to 10 R/Hr Accuracy:

+365 of input radiation

Response

to Gamma Radiation:

60 KeV to 3 MeV Instrument Location:

2 detectors on opposite sides of the drywell 3.3.10 C

Co c n No additional information requested

Responses

.to.EG&G Interim Report (Continued)

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The in'formation required in Sect'ion '6.2 of. NUREG 0737-Supple-iaent 1 that wa's hot prov'ided"by referehce 2-is as*follows 'for the abov'e listed-variable's.-

Instrument Number':

RR-90-322 '

5 Instrument Range:

Noble Gas 10 to 10 uCi/cc Iodines 10 to 10 uCi/cc

"-12 2

Particulates.

10.

. to'0 uCi/cc Power Supply:

Not yet assigned Location of Display:

Displayed on recorder in control room This instrument meets R.G. 1.97 requirements for containment effluent radioactivity.

For effluent radioactivity, which R.G.

1.97 classifies Category 2, this instrument meets all Category 2 requirements with the exception of Class 1E and environmental qualifications.

This instrument. does not perform any safety functions and no operator action is based on this variable in a DBA.

Therefore, 1E qualification is not required.

Also, this instrument is located such that it would not be exposed to harsh environment conditions following a DBA so environmental qualification is not required.

3.3.12

'a Regardless of the upper range of the existing instrumentation

( 10 mR/hr), the potential exists for much higher exposure rates in local unmonitored areas due to spacial dependence of the measurements.

Any entry into the secondary containment area under post accident conditions would require close health physics monitoring in specific areas where inspections or maintenance would be performed>

Portable gonitors are available with ranges from 10 R/Hr to 10 R/Hr.

This will be adequate for health physics to support entry to secondary containment during post accident conditions, as well as long term surveillance and release rate assessment.

This satisfies R.G.

1.97 requirements.

Responses to EGEST Interim Report (Continued) 3313 e s'o C

b a

o F o The LPCI flow instrument used to monitor these variables is not environmentally qualified and therefore are not classified as Category 2.

No operator action in a DBA is based on their indication.

Therefore, environmental qualification is not required.

These variables are also indirectly monitored by observing containment pressure response.

Per issue 9 of reference 2, primary containment pressure is monitored indi-rectly by the drywell pressure instrumentation which is classified as a Category 1 variable.

The drywell and torus pressure may not be equal at all times;

however, the contain-ment design results in the drywell and torus pressures to be within 2 psi of each other during static conditions.

3.3.14 tmos m

u No additional information requested.

3.3.15 s

m a

The following is the information required in Table 6.2 of NUREG 0737 Supplement 1 not supplied by reference 2.

Seismic, environmental, a quality assurance qualifications are in accordance with R.G.

1.97 for Category 2 or 3 as applicable.

cous c

n c u Category:

Instrument Range:

Close-not Closed 0-600 F Power Supply:

1E Non 1E battery backed The acoustic monitors alone meet R.G.

1.97 requirements.

The tailpipe temperature monitors are utilized as a backup and can detect low level MSRV leakage which would not be seen by acoustic monitors.

This meets R.G.

1.97 requirements.

3.3.16 b 'dc LC No additional information requested.

3 3 17 d'o ctd k

No additional information requested.

Responses to EGEG Interim Report (Continued) 3.3.18 ac u'

co da Cont n

d This variable is similar in nature to TVA variable E3 (radiation,ExposureRate)

Age 4o;ggqibgjl4igg.=configgration. ;

Implementation. of,=-variable.-.$ 3 j.s.,:discuqsed inreference 2 and is mainly. for'he purpose,.of. personnel"access;,':

Detection of

releases, release, assessment-,

and."3.gag-Cyan'purveillapcq is performed by the vent stack monitor and cannot be adequately satisfied by area radiation measurement as!'discussed"in=Issue 13 of reference 2.

For this reason, this 'particular variable will not be implemented separately.

The range requirement of. R.G.

1.97 has;been met for the stack

monitor, and since-this is the only-adequate measurement= of radiation release,. it meets the purpose-stated for reactor building or secondary containment area radiation.

3.3.19 o

s d

n 0

-C on The information required in Section 6.2 of NUREG 0737 Supplement 1 that was not, provided by reference 2 is specified in our response to item.3.3.11..

The, same instrument is used for both variables.

3.3.20 c

s The information required in Section 6.2 of NUREG 0737 Supplement 1 that was not provided by reference 2 is specified in our response to item 3.3.11.

The same instrument is used for both variables.

3.3.21 d'o o

s a d

P

'cu Portable radiation monitoring istrumentation is available to monitor Airborne Radiohalogens and Particulates and Plant and Environs Radiation and Radioactivity as follows:

Variable:

Plant and Environs Radiation and Radioactivity Type:

E Category:

3 Instrument Number:

N/A Instrument Range:

10 m Ci/cc to 10 uCi/cc 10 R/Hr to 10 R/Hr photons 10 Rads/hr to 10 Rads/hr beta radiation and low energy photons isotopic analysis

Responses to EG8Q Interim Report (Continued) 3.3.21 bo a

o s

d tcu (Continued)

Redundancy:

N/A Power Supply:

N/A Location of Display:

N/A Schedule:

Use as is Remarks:

Release assessment and analysis e

The isotopic analysis is performed by multichannel analyzer with hyper-pure germanium detector.

This equipment meets all R.G.

1.97 recommendations.

3322 a

d.

0 s d a Same as 3.3.21.

'~:-;;.; Co. ect'o s".

ns e c Durde"our.3".G"..-..1.".97'i>viewMrCprhpaMtion"..for"our'.'respose to reference 1, errors in our original response (reference

2) were discb0ered:whi.ch are corrected below.

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--This has been-defined by R.G.

1.97 and reference 2 as a Category 1 variable.

However, all of the limit switches

-'-. which=provide-this'.indication'.are;.not environmentally qualified.

For motor operated

valves, the limit switches

.'.used for control room position, indication're part of the same assemblies used for control'unctions.

These assemblies are environmentally qualified for environments associated with accidents in which the valves must close in order to mitigate those accidents.

While not speci-

,.fically.:qualified, the indications should be considered as reliable as the control functions of the respective valve.

Primary containment isolation valves which fail closed in post-accident conditions do not have qualified limit switches for position indication.

However, little operator action could be taken to close such a valve should it fail to automatically close in a harsh environ-ment.

Because no operator action in a DBA is based on this indication, environmental qualification is not required.

(2)

Coolant Level in Reactor Our response to this variable in Reference 2 should be revised as follows:

Identifier:

B4 Variable:

Coolant level in reactor Type:

B Category:

1, 3 (3)

Instrument Number:

LI-3-52, LI-3-62A, LI-=3-58A, LI-3-58B, L-3-55 Instrument Range:

-100 to +200 inches with zero at TAF (LI-3-52, LI-3-62A)

-155 to +60 inches with zero at instrument zero (LI-3-58A, LI-3-58B) 0 to 400 inches with zero at instrument zero (LI-3-55)

Co c

s 0 (2)

Coolant Level in Reactor (Continued)

Redundancy:

2 separate channels (except LI-3-55)

Power Supply:

Class 1E (except LI-3-55)

Location of Display:

Control Room Schedule:

Use as is Remarks:

Purpose:

Core Cooling (1)

Total range is 1/3 core height to 228 inches above the top of active fuel (TAF)

(2)

See Issue 2A and 2B (revised)

(3)

LI-3-55 is Category 3; all other level indicators are Category 1

e

Issue 2A and='2B={Revised) '

':. Variable-'B4. -'-'-'. -'--'--.---'--'".-'--'-.

Coolant Level in Reactor rove,nr I oiiai q ~ pn~c~~

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Regulatory Guide t".97-'eqo'ires'eduMariY'Ntilments.for Categor y 1

variables.

For reactor coolant level, redundant instruments would be available with a range-'-from -1/'-3 ~ore height"Q 228"inches above the top of active fuel (TAF)."::Contrary '.to that, Category 1 instruments are not provided for the full..range.

CUSS The instrument ranges are being-used. to cover-the-total range:

post-accident flooding (-100 to +200 -inches with zero at TAF), emergency system flooding (-155 to +60 inches'ith zer'o at instr'ument zero),

and shutdown vessel flooding (0 to 400 inches with zero at instrument zero).

Redundancy is provided for the postaccident flooding and the emergency system flooding ranges.

Only one category 3 instrument is provided for the shutdown vessel flooding range.

No manual or automatic functions are initiated from the shutdown flooding range in a DBA. It is for operation only and not intended for post accident monitoring.

Providing a Category 1

instrument would not result in any improvement in plant safety.

Conc s o The redundancy provided for two of the three instrument ranges satisfies the intent of the guide and a Category 1 instrument will not be provided for the shutdown vessel flooding range.

n'on Regulatory Guide 1.97 states that recording of instrumentation readout information be provided for at least one redundant channel.

Contrary to

that, no recorder from a qualified instrument channel will be provided.

SCUSS Two independent qualified channels for indication are. provided in the control room for the postaccident flooding range and the emergency system flooding range.

They will not,

however, have a recording device in the control room.

This information is not essential for the operator's

direct, and imediate trend or transient information.

However, a level recorder from a nonqualified instrument loop is provided for the postaccident flooding range and the narrow range (0-60" from instrument zero).

The emergency system flooding range will be included in the data base for the safety parameter display system (SPDS).

issue 2A and 28 (Revised)

Variable B4 Coolant Level in Reactor Cocu o

Two independent control room indicators from qualified instrument loops for the postaccident flooding range and the emergency system flooding range is sufficient for operators use during accident conditions.

lfI'1)

NRC letter, Domenic B. Vassallo to Hugh G. Parris, TVA "Emergency

Response

Capability Conformance to R.G.

1.97 REV 2," January 23, 1985 (2)

TVA letter, L. M. Mills to Harold R. Denton, NRC, April 30, 1984

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