ML18143B351
| ML18143B351 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/02/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 85-123B, NUDOCS 8508080339 | |
| Download: ML18143B351 (5) | |
Text
.,
WILLL4M L STEWART Vice President Nuclear Operations
/\\ugust 2, 1985 e
Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation Attn:
Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:
VIRGINIA POWER SURRY POWER STATION, UNITS 1 AND 2 CONFORMANCE WITH REGULATORY GUIDE 1.97 e
Nuclear Operations Department Post Office Box 26666 One James River Plaza Richmond, Virginia 23261 VIRGINIA POWER Serial No. 85-123B E&C/BMc:acm Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Virginia Power letters, Serial No. 85-123A, dated May 10, 1985 and Serial No. 85-123AA, dated June 21, 1985, provided a partial response to your letter of February 19, 1985, which requested additional information concerning conformance with Regulatory Guide 1. 97, Revision 3.
The attachment to this letter provides responses for the remaining two items.
If you have any questions, or need additional information to complete your review, please contact us.
V Attachment cc:
Dr. J. Nelson Grace Regional Administrator Region II Mr. D. J. Burke NRC Resident Inspector Surry Power Station
e SURRY POWER STATION REGULATORY GUIDE 1.97 RESPONSE TO NRC LETTER DATED FEBRUARY 19, 1985 e
NRC letter, dated February 19, 1985, on conformance with Regulatory Guide 1.97 identified fifteen open items and requested a Virginia Power response to each item.
Responses to thirteen of these items were provided in Virginia Power letters Serial No. 85-123A, dated May 10, 1985, and Serial No. 85-123AA, dated June 21, 1985.
The remaining two items are addressed below.
Item 1 RCS flow -- the licensee should upgrade this instrumentation to Category 1 requirements (Section 3.2).
Virginia Power Response Upon reevaluation of planned manual actions taken in emergency procedures, RCS flow has been deleted as a Type A variable for Surry Power Station.
Originally RCS flow was intended to be used to provide a qualified means of verifying whether the Reactor Coolant Pumps were operating/not operating.
This function is also identified as variable D-10 in the Virginia P9wer January 31, 1984 submittal (Serial No. 053) as RCP status.
By definition a Type A variable provides primary information which is 11 ***
essential for the direct accomplishment of the specified safety functions; it does not include those variables that are associated with contingency actions that may also be identified in written procedures.
Primary information is needed to permit the Control Room operating personnel to take the specified manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for the design basis accident event.
11 (R. G.
1.97, Rev. 3).
RCP status is associated with contingency actions in the Emergency Operating Procedures, and as such, there is no basis for requiring either RCP status or RCS flow to be Type A variables.
Item 3 Radiation level in circulating primary coolant -- the licensee should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1 for this variable (Section 3.3).
Virginia Power Response Regulatory Guide 1.97 recommends monitoring this variable for the purpose of detecting fuel cladding failure.
The Containment High Range Radiation Monitoring System (CHRRMS; RM-RMS-127,-128,-227,-228) which is qualified per Reg. Guide 1.97 would be used for this purpose.
The CHRRMS has been identified by Westinghouse as a system that can be*used for determining
r e
the extent of fuel damage for any accident involving a breach of the reactor coolant system to the containment atmosphere.
Additionally, the Core Exit Thermocouples have been identified by Westinghouse as a system that can be used for detecting a fuel cladding failure.
This system will be upgraded to meet Reg Guide 1.97 qualifications.
The system can be used to monitor changes in temperature for any region of the reactor core.
Core exit temperature can be used as an indication of gross fuel cladding damage. These thermocouples will be able to detect high temperatures which would indicate possible fuel cladding damage during design basis accidents.
The two methods described above both meet the intent and qualifications required by Reg*Guide 1.97 and provide diverse techniques for identifying fuel cladding failure.
The backup method, which will be used to sample and obtain actual radioactivity concentration measurements, is the Post Accident Sampling System (PASS) which is qualified to NUREG-0737 requirements.
It has the capability to analyze the primary coolant, providing a trending capability for small amounts of fuel cladding failure as well as gross failure, and meets the range requirements specified in Reg. Guide 1.97.
Virginia Power believes that the combination of these systems meets the intent of Reg Guide 1.97 for the C-2 variable and is consistent with the Westinghouse Emergency Response Guidelines for this variable.
The information relative t; Section 6.2 of NUREG-0737, Supplement No.
1 for each system is provided on the following tables:
- 1. System
- 2. Instrument Range
- 3. Environmental Qualification
- 4. Seismic Qualification
- 5. Quality Assurance
- 6. Redundancy
- 7. Power Supply
- 8. Location Upgraded Core Exit Thermocouples (Two groups of 25 thermocouples monitor the 4 core quadrants) 200 to 2300 degrees F System will be install-ed to meet Reg. Guide
- 1. 97 Category 1 Requirements All equipment seismical-ly qualified Category 1 25 thermocouple inputs to two separate channels (A and B) which meet redundancy criterion lE e
Containment High Range Monitor System (CHRRMS)
(RM-RMS-127,-128,
-227,-228) 1 to 1E7 R/hr Monitors qualified to harsh environment.
Readout in Control Room All equipment seismical-ly qualified Category 1 Two widely separated monitors are provided for each unit lE Readouts in Control Room. Readouts in Control Room.
Thermocouples in RCS in Monitors in Containment Containment Building Building
- 1.
- 2.
- 3.
- 4.
- 5.
- 6.
- 7.
- 8.
System:
Instrument Range:
Environmental Qualification:
Seismic Qualification Quality Assurance:
Redundancy:
Power Supply:
Location:
e e
Post Accident Sampling System (Sentry) 1/2 times Tech Spec Limit to 100 times Tech Spec Limit The panel is environmentally qualified consistent with NUREG-0737 for conditions expected post-accident and is accessible during postulated events.
Partial.
Sample lines are seismic from sample point to outside containment isolation valves.
Category 3 None.
Non-lE Control Panel in Service Bldg. Elev.
_45'-3";1iquid sampler panel in Aux.
Bldg. Elev. 27 1 -6 11