ML18153C383
| ML18153C383 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/28/1990 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 90-568A, NUDOCS 9010110252 | |
| Download: ML18153C383 (7) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 28, 1990 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 RESPONSE TO NRC REG. GUIDE 1.97 AUDIT RECORDERS FOR CATEGORY 1 VARIABLES Serial No.
PES/TRA:vlh Docket Nos.
License Nos 90-568A R1 50-280 50-281 DPR-32 DPR-37 During the period of July 9-19, 1990, a NRC inspection of Regulatory Guide 1.97 compliance was performed at Surry Power Station as documented in NRG Inspection Report Nos. 50-280/90-22 and 50-281/90-22. During this inspection, a question was raised regarding recording requirements for Category 1 variables. The inspector requested that trend and transient information requirements be reviewed for four variables (viz., steam generator pressure, RCS wide range pressure, AFW flow, and neutron flux) to determine whether recording requirements were being appropriately addressed for these variables. We were requested to document our ~valuation of these four items by submitting our positions to the NRC.
The Company had previously submitted a letter (Serial No. 053) on January 31, 1984, that specified which variables were equipped with dedicated recorders. The purpose of this letter is to document our position and justification on providing trend or transient.
information for individual RG 1.97 Category 1 variables. The attachment to this letter identifies Category 1 variables, provides the method of trending, if applicable, and defines the basis for trending.
In accordance with the guidance of R.G. 1.97, an assessment was performed to determine which Category 1 variables should have trend or transient information available for operator information or action.
These variables are provided with dedicated recorders or an alternate method of trending. This assessment was based on a review of the existing Emergency Operating Procedures. As identified in IR 90-22 and reconfirmed during this assessment Variable A-2, Steam Generator Pressure, requires trending based on the existing Emergency Operating Procedures. Therefore, a recorder will be provided for Variable A-2 in accordance with the schedule provided in the attachment.
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e It should be noted that the variables listed in the attachment also provide input into the Emergency Response Facility (ERF) Computer.
The ERF Computer meets the Category 2 requirements of RG 1.97 and provides additional capability for historical trending.
If you have any questions concerning this matter, please do not hesitate to contact us.
W. L.
te Senior Vi e President - Nuclear Attachment cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station
Variable #
A-1 A-2 D-18 Surry Category 1 Variables - Units 1 & 2 Variable Name Narrow Range Steam Generator Level Steam Generator Pressure Page 1 of 5 Remarks Narrow range steam generator level is used to control and maintain steam generator level for normal and emergency operations.
Steam Generator Narrow range level is used in the Emergency Procedures to provide primary information to the operator to ensure that SG level is maintained within a specified range (typically 9% to 50% of the narrow range band). In addition, Emergency Procedure, "Steam Generator Tube Rupture," uses this variable as one method to identify the faulted steam generator by checking for an "unexpected rise in any steam generator narrow range level." This unexpected rise would be a sudden increase in steam generator level associated with a large rupture.*
Wide Range Steam Generator level (Variable D-17, Category 1) is used to trend the variable of steam generator level.
Steam Generator Pressure is used in the EOPs to provide information to the operator to ensure that the faulted steam generator is isolated. The faulted steam generator is identified by an uncontrolled decrease in steam generator pressure or a completely depressurized steam generator. Operators are pre-sently trained to note trends by the continuous display. Consistent with the requirements of RG 1.97 and EOP usage, a dedicated recorder will be added by end of
A-2 (continued)
A-3 C-1 A-4 8-6 A-5 8-5 A-6 Core Exit Temperature RCS Cold Leg Temperature RCS Hot Leg Temperature RCS Flow Page 2 of 5 e
the Cycle 11 refueling outages for Surry Units 1 and 2, presently scheduled for February 1992 and 1993,respectively.
Core Exit Temperature is used in the Emergency Procedures to provide primary information to the operator so that action may be taken if Core Exit Temperature is increasing or above a specified value.
The Inadequate Core Cooling Monitor (ICCM) System displays are used to trend this variable.
This system was designed specifically to address accident monitoring requirements for detection of inadequate core cooling specified by NUREG 0737, Item II. F.2, as well as the then specified RG 1.97 by integrating accident variables into one system display to facilitate operator response.
Core Exit Temperature is trended via the "Highest CETs Tempera-ture Trending Page" of the ICCM.
The average of the highest five (5) thermocouples is trended.
Dedicated Recorders:
OX-RC-TR-X410 OX-RC-TR-X420 OX-RC-TR-X430 Dedicated Recorders:
OX-RC-TR-X413 OX-RC-TR-X423 OX-RC-TR-X433 RCS flow deleted as an "A" variable (Reference August 12, 1987 letter Serial No.87-323).
A-7 RCS Wide Range Pressure The Inadequate Core Cooling 8-7 Monitor (ICCM) System Displays 8-11 are used to trend this variable.
C-4 Wide Range Pressure is trended C-9 via the "Pressure/Temperature Curve" page of the ICCM. The current coolant condition is shown with a square figure on the graph.
Trending of the coolant condition is on the Pressure/Temperature Curve at 5 minute increments for the previous 30 minutes.
A-8 HPSI Flow (Total)
HPSI Flow deleted as an "A" variable (Reference August 12, 1987 letter Serial No.87-323).
A-9 Condensate Storage Dedicated Recorder:
D-22 Tank Level OX-CN-LR-XOO A-10 Refueling Water Dedicated Recorder:
D-9 Storage Tank Level OX-CS-LR-XOOD A-11 Pressurizer PORV Position No dedicated recorder required.
Variable only provides position indication (i.e., open/closed).
A-12 Pressurizer Liquid Pressurizer Liquid Temperature Temperature deleted as an "A" variable (Reference August 12, 1987 letter Serial No.87-323).
A-13 Pressurizer Level Dedicated Recorder:
D-12 OX-RC-LR-X459 A-14 Containment Hydrogen Containment Hydrogen Concen-C-10 Co nee ntratio n tration deleted as an "A" variable (Reference August 12, 1987 letter Serial No.87-323). However, addressed as a "C" variable (C-10).
A-15 Intermediate Range Intermediate Range Containment 8-13 Containment Pressure Pressure is used for operator con-8-15 trol activities. Wide Range Con-C-5 tainment Pressure recorder (Variable C-11) is used to trend containment pressure.
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e A-15 (continued)
A-18 A-19 B-12B C-6B A-20 E-1 A-21 B-1 Degrees of Subcooling Containment Sump Water Level - Wide Range Containment Area Radiation Auxiliary or Emergency Feedwater Flow Neutron Flux Page 4 of 5 Intermediate Range Containment Pressure is used in the Emergency procedures to provide primary information to the operator so that action may be taken if pressure exceeds a specified value. This variable is not trended per Emergency Procedures.
The Inadequate Core Cooling Monitor (ICCM) system displays are used to trend this variable.
Degrees of Subcooling is trended via the "Pressure/Temperature Curve" page of the ICCM. The current coolant condition is shown with a square figure on the graph.
A trending representation of the coolant condition is provided at 5 minute increments for the previous 30 minutes.
Dedicated Recorder:
OX-RS-LR-X51 A Dedicated Recorders:
OX-RR-RMS-X27 OX-RR-RMS-X28 No dedicated recorder required.
Auxiliary Feedwater Flow is used in the Emergency Procedures to provide primary information to the operator to ensure that auxiliary feedwater flow is greater than a specified flow rate. This information is provide by observing the continuous display.
This variable is not trended per Emergency Procedures.
No dedicated recorder required.
Neutron flux is used in the Emergency Procedures to provide information to the operator to indicate that Reactor Power is
B-1 (continued) above or below a specified level, or decreasing following a reactor trip. Confirmation of decreasing neutron flux following a reactor trip is by direct observation of the continuous indicators.
B-9 Coolant Inventory (RVLIS)
Dedicated Recorder:
01-RC-LR-131 OA 02-RC-LR-2310 B-14 Containment Isolation
- No dedicated recorder required.
Valve Position Variable only provides position only indication (i.e., open/closed).
C-2 Radiation Concentration This item is addressed by use of Primary Coolant the variables Core Exit Tempera-ture and Containment Area Radiation (Variables C-1 and E-1, respectively). Reference letter Serial No. 85-123B.
C-10 Containment Hydrogen Dedicated Recorder:
Concentration OX-H2R-GW-X04 C-11 Containment Pressure Dedicated Recorder:
Wide Range OX-LM-PR-X01 A D-17 Steam Generator Dedicated Recorder:
Level - Wide Range OX-FW-LR-X477, -X487, -X497 Note: The instruments are applicable to both units and have an "X" in their identification number in place of a unit number.
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