ML18086A225
| ML18086A225 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/02/1981 |
| From: | Mittl R Public Service Enterprise Group |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8104070200 | |
| Download: ML18086A225 (16) | |
Text
CPS~G Public Service Electric and Gas Company 80 Park Plaza, T160 Newark, N.J. 07101 201/430-8217 Robert L. Mittl General Manager - Licensing and Environment April 2, 1981 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. c.
20555 Attention:
Gentlemen:
Mr. F. J. Miraglia, Chief Licensing Branch 3 Division of Licensing COMPLIANCE WITH REGULATORY GUIDE 1.97 NO. 2 UNIT SALEM NUCLEAR GENERATING STATION DOCKET NO. 50-311 Public Service Electric and Gas hereby submits, in the enclosure to this letter, its initial evaluation of Salem 2 to determine the degree of compliance with Regulatory Guide 1.97, along with a schedule for bringing the unit into compliance.
Should you have any questions, do not hesitate to contact us.
Very truly yours, Enclosure
{)
The Energy People 8 1 o 4 n " o ")..C)O
4 SALEM NUCLEAR GENERATING STATION UNIT #2 COMPLIANCE WITH USNRC REGULATORY GUIDE 1.97 "INSTRUMENTATION FOR LIGHT WATER-COOLED NUCLEAR POWER PLANTS TO ASSESS PLANT AND ENVIRONS CONDITIONS DURING AND FOLLOWING AN ACCIDENT" INTRODUCTION PSE&G has completed an initial evaluation of the Salem Unit #2 instrumentation systems to determine its degree of compliance with Reg. Guide 1.97.
Since the Salem design bases for instrument systems were developed and approved by the NRC significantly prior to the issuance of this guide, the evaluation was based on compliance with the overall intent of the guide.
Demonstration of compliance with the intent of the Reg. Guide required that any specific differences between the Salem design bases and those of the Reg. Guide be identified.
The identification of these differences are specified in Section I.
The key elements of the overall evaluation can be summarized as follows:
o Compliance of existing systems and instrumentation is based upon meeting the intent of the Reg.
Guide.
o Compliance of new equipment is based upon appli-cation of the Reg. Guide to the extent that exist-ing design can accommodate the change without com-promising the existing system.
o Previous commitments to modify existing equipment or to add new equipment were considered (e.g.
NUREG-0588 and NUREG-0737) in the context of those commitments which pre-date Reg. Guide 1.97.
The results of this evaluation have been classified into five basic types of "compliance levels".
These com-pliance levels have been selected to illustrate the resolu-tion actions planned for the equipment to demonstrate the overall plant compliance with Reg. Guide 1.97.
This infor-mation is included in Sections II and III.
MP 81 101 03/l
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- I.
Identification of Design Basis Differences From Reg.
Guide 1.97.
To establish a baseline set of criteria for this eval-uation, the Reg. Guide 1.97 recommendations have been reviewed for similarity to the Salem plant design bases.
In those instances where the Salem bases agree with the Reg. Guide 1.97, no differences are listed below.
For those cases which involve differences, a comparison is provided below to demonstrate that the intent of the guide is adequately achieved.
- 1.
The Salem plant design bases were effectively established prior to issuance of the Regulatory Guides referenced in Reg. Guide 1.97.
Although the Salem plant conforms to the intent of the Reg-ulatory Guides, as stated in the Salem FSAR, strict compliance has not been required.
In many cases, the Guides have been revised to incorporate subsequent revisions of referenced standards; and in some cases, the Guides are not applicable to the previously approved design (e.g., Reg. Guide
- 1. 75).
For the purpose of compliance with Reg. Guide 1.97, the Salem design will conform with the in-tent of the referenced Guides and Standards to the same extent as specified in previous responses to the NRC on the subject documents.
- 2.
"Qualification of Class IE Equipment for Nuclear Power Plant".
The Salem plant review basis is NUREG-0588, Category II for existing instrumentation and NUREG-0588, Category I (i.e., IEEE 323-74) for new equipment.
Evalua-tions for equipment in harsh environments have been completed.
Evaluations for noncontrolled be-nign environments _w_ill _b_e_c_ompleted_per NRC estab-lished schedules.
Recorders, indicators, and other instrumentation located in controlled benign environments such as the control room, have been considered as meeting M P81 101 03/2
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the intent of Reg. Guide 1.97, pending the comple-tion of the NUREG 0588 benign environment review.
- 3.
"Seismic Qualification of Elec-tric Equipment for Nuclear Power Plants".
The Salem plant review basis is IEEE 344-71, for exis-ting equipment and IEEE 344-74, for new equipment.
- 4.
Reg. Guide 1.75- "Physical Independence of Elec-tric Systems".
The Salem plant electric systems do not conform to the recommendations in Reg.
Guide 1.75, since this was not an original design criterion.
New equipment will be integrated into our existing separation provisions.
The Salem separation criteria has been approved by the NRC staff as described in Safety Evaluation Report, Supplement No. 4, Section 8.4.5.
- 5.
Reg. Guide 1.32- "Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants.
The Salem plant review basis is IEEE 308-71, "Class IE Electric Systems for Nuclear Power Gene-rating Stations".
- 6.
Quality Assurance: Regulatory Guides
- a.
Reg. Guide 1.28, "Quality Assurance Program Requirements (Design and Construction)" Revi-sion 2, dated February, 1979.
The Salem plant review basis is Safety Guide 28, which en-dorses ANSI 45.2.1 of 1971.
- b.
Reg. Guide 1.38, Revision 2, dated May, 1977, "Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants".
The Salem plant review basis is Reg. Guide 1.38, Revision 1, dated October, 1976.
- c.
Reg. Guide 1.64, dated June, 1976, "Quality Assurance Requirements for the Design of Nu-clear Power Plants".
The Salem plant review basis is Reg. Guide 1.64, Revision O, dated October, 1973.
M P81 101 03/3
- d.
Reg. Guide 1.123, dated July 7, 1977, "Quality Assurance Requirements for Control of Procure-ment of Items and Services for Nuclear Power Plants".
The Salem plant review basis is ANSI 45.2.13, of 1976.
- e.
Reg. Guide 1.144, Revision 1, dated September, 1980 "Auditing of Quality Assurance Programs for Nuclear Power Plants".
The Salem plant review basis is ANSI 45.2.12, Draft 4, Revision 2.
- f.
Reg. Guide 1.146, dated August 1980, "Qualifi-cation of Quality Assurance Program Audit Per-sonnel for Nuclear Power Plants".
The Salem plant review basis does not include a commit-ment to Reg. Guide 1.146.
- 7.
Unique Identification: The instruments are not specifically identified on the control panels as those intended for use under accident conditions.
The instrumentation on the control panels in the Salem Control Room is presently grouped on a functional basis.
Additional markings could add confusion to a control panel layout that was favorably reviewed during the NRC "Human Factors Review of the Salem No. 2 Unit Control Room" in March of 1980.
- 8.
Reg. Guide 1.11$- "Periodic Testing of Electric Power and Protection Systems".
The Regulatory Guide invokes the requirements of IEEE 338-1975, which is applicable to protection systems.
The display information provided for Reg. Guide 1.97, is not considered to be part of the protection system and does not require all of the testing specified in IEEE-338.
The plant equipment being used for compliance with Reg. Guide 1.97 has been designed to incorporate testing capabilities as discussed in the Salem FSAR, Chapter 7.2.
Testing frequencies will be in accordance with the appli-cable Technical Specifications.
M P81 101 03/4
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- 9.
TYPE "A" VARIABLES (PLANT SPECIFIC)
The definition of Type "A" Variables given by Reg. Guide 1.97, Paragraph 1.1 is:
"Those variables to be monitored that provide the primary information required to permit the control room operators to take the specified manually con-trolled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis events."
The Salem Emergency Operating Procedures were re-viewed to determine which Reg. Guide 1.97, Type "A" parameters are required using the following baseline interpretation of Reg. Guide 1.97, Paragraph 1.1
- The operating procedures specify certain operator verification of automatic actions, and if the automatic actions have not been performed (presum-ably due to system failure), the operator is re-quired to manually perform those actions" The parameter selection does not include either the.
verification step or the manual backup action.
The parameter selection includes those required for operator actions needed for system functioning where no automatic signal/system exists.
Where important, the manual Type "A" operator ac-tions must be monitored to assure that the action has been performed.
This monitoring of Type "A" operation is performed by "Type B" Variables as defined by Reg. Guide 1.97.
In reviewing the Emergency Operating Procedures, the event "end point" for parameter selection is a stable hot condition for all events except LOCA's (large or small) that cannot be isolated.
The end point for LOCA's that cannot be isolated is a cold depressurized condition.
See Table I.l for an index of Class "A" Variables.
M P81 101 03/5
- II.
REG. GUIDE 1.97 COMPLIANCE LEVELS The evaluation revealed varying degrees of compliance with Reg. Guide 1.97 which were classified into five "com-pliance levels".
These classifications evolved from con-sideration of the design bases, existing NRC commitments and specific new changes, where possible, to meet the Reg.
Guide.
The overall results of this effort are summarized in Table II.l.
The description of each "compliance level" is provided below:
- 1.
Items in Compliance The items categorized under this heading meet the PSE&G bases as outlined in Section I.
- 2.
Items Where Design Precludes Compliance The items categorized under this heading are pres-ently installed, but by nature of the present de-sign, may not meet the recommendations in the Guide such as environmental and seismic qualif ica-tions.
These items are generic to Westinghouse plants.
- 3.
Items Which Are Being Replaced/Added The items categorized under this heading deviate from one or more recommendations in the Guide.
These items will be replaced with devices modified to meet the appropriate recommendations.
Re-placement/Installation/Modification for each item will be made to:
- a.
Meet requirements imposed by other documents such as NUREG-0588 and NUREG-0737.
- b.
Meet the recommendations of Regulatory Guide 1.97.
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- 4.
Items Which Are Not Being Replaced The items categorized under this heading are pres-ently installed, but deviate from one or more rec-ommendations of the Guide.
This is based on:
- a.
Devices located in non-harsh environment, that require qualification review in accordance with NUREG-0588 for benign environments which will be completed by June 30, 1982.
- b.
Devices located in a harsh environment that are not utilized in accident emergency in-structions for operators to maintain plant safety.
- c.
Devices currently meeting Tech. Spec. require-ments but the specified ranges do not meet the recommendations in Reg. Guide 1.97.
- 5.
Items Not Part of Salem Design The items categorized under this heading are not part of the Salem design and are not being instal-led.
Alternate capabilities are available which meet or will meet our requirements and provide ad-equate information for maintenance of plant safety.
III. PLANNED ACTIONS Compliance Level 1 No action planned.
The instrumentation in this com-pliance level meets the intent of Reg. Guide 1.97 in accordance with the criteria specified in Section I.
Compliance Level 2 No equipment replacement planned at this time pending resolution of generic problems.
M P81 101 03/7 Compliance Level 3a Instruments are being replaced or upgraded as a result of prior commitments related to NUREG-0588 and NUREG 0737.
These devices will comply, with Reg. Guide 1.97 in accordance with the criteria specified in Section I by the dates specified in previous correspondence to the NRC staff.
Compliance Level 3b Instruments will be upgraded to meet Reg. Guide 1.97 in accordance with the criteria specified in Section I by 6/1/83.
Compliance Level 4a The equipment will be evaluated in accordance with the requirements of the NUREG-0588 benign environment review, and appropriate actions will be taken where required.
Compliance Level 4b No action planned.
The importance of the device is deemed to be relatively low or insignificant.
Compliance Level 4c The existing devices comply with Tech. Spec. require-ments and should not be modified.
Compliance Level 5 No action planned.
Other provisions exist which ne-gate the need for the instrumentation.
All items currently planned to remain unchanged have been evaluated for potential effects on plant safety.
This evaluation concludes that plant safety is not af-fected by the lack of compliance to Reg. Guide 1.97.
M P81 101 03/8 TABLE I.l INDEX TYPE "A" VARIABLES Variable Description Variable Reference No.
Reactor Coolant System Hot Leg Water Temperature Reactor Coolant Pressure Degrees of Subcooling Containment Pressure Effluent Radioactivity Noble Gas Effluent from Condenser Air Removal System Exhaust Refueling Water Storage Tank Level Pressurizer Level Steam Generator Pressure Auxiliary Feedwater Flow Auxiliary Feedwater Storage Tank Level (Condensate Storage Tank)
Steam Generator Radiation M P81 101 03/9 5
6 9
11 16 27 30 36 39 40 73
-1
Variable Ref. No.
1 2
3 4
5 6
7 8
9 10 11 12 13
- Table II.l Summary of Instrumentation Compliance with Reg. Guide 1.97.
Variable Description Neutron Flux (Source Range, Intermediate range, Power range) - Monitors Control Rod Position RCS* Soluble Boron Concentration RCS Cold Leg Water Temperature RTD's Indication RCS Hot Leg Water Temperature RTD's Indication RCS Pressure -
Transmitters Core Exit Temperature -
Thermocouples Coolant Level in Reactor Degrees of Subcooling -
Display (inpu~s -
See variable Ref. No. 6&7)
Containment Sump Water Level -
Transmitters Containment Pressure (narrow and wide range) -
Transmitters Containment Isolation Valve Position (excluding check valves) -
Limit Switches Radioactivity Concentration or Radiation Level in Circulating Primary Coolant M P81 101 03/10 Compliance Level 2
1 1
3a 3b 3a 3b 3a 2
1 1
3a 3a 3a 5
Variable Ref. No.
14 15 16 17 18 19 19A 20 21 22 23 24 25 26 Table II.l (Cont'd)
Variable Description Analysis of Primary Coolant (Gamma Spectrum)
Containment Area Radiation -
Monitors Effluent Radioactivity -
Noble Gas Effluent from Condenser Air Removal System Exhaust -
Monitors Containment Hydrogen Concentration -
Analyzers Containment Effluent Radioactivity Nobles Gases from Identified Release Points -
Monitors Radiation Exposure Rate (Electrical Penetration Area) -
Monitor Radiation Exposure Rate (Fuel Handling Building & Penetration Area) - Monitors RHR System Flow -
Transmitters RHR Heat Exchanger Outlet Temperature -
Thermocouples Accumulator Tank Level and Pressure -
Transmitters Transmitter Range Accumulator Isolation Valve Position Boric Acid Charging Flow -
Transmitters Flow in HPI System -
Transmitters Flow in LPI System -
Transmitters M P81 101 03/11 Compliance Level 5
3a 3a 3a 3b 3b 4a 3a 4b 3b 4c 1
3a 3a 3a
Variable Ref. No.
27 28 29 30 31 32 33 34 35 36 37 38 39 Table II.l (Cont'd)
Variable Description Refueling Water Storage Tank Level and Low Level Alarm - Transmitters -
Transmitter Range Reactor Coolant Pump Status Primary System Safety Relief Valve Positions (including PORV and code valves) or Flow through or Pressure in Relief Valve Lines Pressurizer Level -
Transmitters Transmitter Range Pressurizer Heater Status (Current) -
Heaters Quench Tank Level (Pressurizer Relief Tank) -
Transmiter Range Quench Tank Temperature (Pressurizer Relief Tank) -
Transmitter Range Quench Tank Pressure (Pressurizer Relief Tank) -
Steam Generator Level -
Transmitters Steam Generator Pressure -
Transmitters Safety/Relief Valve Positions or Main Steam Flow -
Transmitters Main Feedwater Flow Auxiliary Feedwater Flow -
Transmitters M P81 101 03/12 Compliance Level 3a 4c 1
1 3a 4c 2
4c 3b 1
3a 3a 3a 1
3a
Variable Ref. No.
40 41 41A 42 43 44 45 46 47 48 49 50 51 52 52A Table II.l (Cont'd)
Variable Description Condensate Storage Tank Water Level (Auxiliary Feedwater Storage Tank)
Transmitters Containment Spray Flow Containment Spray Flow Additive Rate Transmitters Heat Removal by the Containment Fan Heat Removal System -
Transmitters Containment Atmosphere Temperature Containment Sump Water Temperature CVCS Makeup Flow-in -
Transmitters Letdown Flow -
Transmitters Volume Control Tank Level -
Transmitters Component Cooling Water Temperature to ESF System -
Transmitters Component Cooling Water Flow to ESF System - Transmitters High-Level Radioactive Liquid Tank Level -
Indication Radioactive Gas Holdup Tank Pressure-Indication Emergency Ventilation Damper Position -
Control Room Damper Limit Switches Emergency Ventilation Damper Position -
Ausiliary Bldg. Damper Limit Switches M P81 101 03/13 Compliance Level 3a 5
3a 3a 4b 5
3a 3b 4a 4a 4a 3b 3b 4a 4a
Variable Ref. No.
52B 53 53A 54 55 56 57 58 59 60A 60B 61 62 63 Table II.l (Cont 1 d)
Variable Description
- Emergency Ventilation Damper Position -
Fuel Handling Bldg.
Status of Standby Power Status of Control Air Containment ¢;}::Purge Effluent Reactor Shield Building Annulus Effluent Auxiliary Building Effluent Condenser Air Removal System Exhaust Common Plant Vent or Multi-Purpose Vent Discharging any of above releases Monitor Vent from Steam Generator Saftey Relief Valves or Atmospheric Dump Valves -
Monitors All other identified Release Points (Decontamination Bldg.) -
Monitor All other identified Release Points (Auxiliary Feed Pump Turbine Exhaust) -
Monitor All Identified Plant Release Points -
Monitor (Particulates and *~alogens Radiation Exposure Meters Airborne ;i[adiohalogens -_and p_q.rticulates (portable sampling with onsite analysis capability) -
M P81 101 03/14 Compliance Level 4a 1
5 N/A N/A N/A N/A 3a 3a 3b 3a 3a 5
1
Variable Ref. No.
64 65 66 67 68 69 70 71 72 73 Table II.l (Cont'd)
Variable Description Plant and Environs Raidation -
Instrument Range Plant and Environs Radioactivity Wind Direction Wind Speed Estimation of Atmospheric Stability Primary Coolant (Grab sample)
Containment Air (Grab sample)
Containment Sump (Grab sample)
Effluent Radioactivity -
Noble Gases -
Monitor Steam Generator Blow-down Radiation -
Monitor M P81 101 03/15 Compliance Level 4c 1
1 1
1 1
1 1
3a 3a