ML20071E667

Forwards Response to Generic Ltr 82-28 Re Inadequate Core Cooling Instrumentation Sys.Subcooling Monitor Fully Operational.No Mods Planned.Present & Upgraded Sys Capabilities Per NUREG-0737,Item II.F.2,discussed

ML20071E667
Person / Time
Site:	Mcguire, McGuire
Issue date:	03/09/1983
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM GL-82-28, NUDOCS 8303150317
Download: ML20071E667 (14)

Text

e 1 DUKE POWEIt Godmon-P.O. HOX 331150 CIIAHLOTTE, N.C. 215242 IIAL II. TUCKER TELEPIIONE

,, *",=,"=", March 9, 1983 (m)a m ma Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. 3. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Ma. E. G. Adensam Chief Licensing Branch No. 4 Re: 'mGgire Nuclear Station Docket. Nos, 50-369, 50-370 Lear Mr. Eisenhut:

Attached is Duke Power Company's response to NRC Generic Letter No. 82-28 concerning inadequate Core Coaling Instrumentation System for McGuire Nuclear Statioa Units 1 and 2. -

1 de.clare under penalty of perjury that the statements set forth herein are true sad correct. to the best of my kncwledge.

Very truly yours, W

Hal B. Tucker REH:jfw Attachment cc: Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303 Senior Resident Inspector McGuire Nuclear Station

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Response to Generic Letter Number 82-28 Attachment 1 - Subcooling Margin Monitor Attachment 2 - Reactor Vessel Level-Ins,trumentation Sy tem '

' Attachment ~3 - Incore Thermocouples P

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ATTAC10iENT 1 McGuire Nuclear Station i Response to Generic Letter No. 82-28 Subcooling Monitor A detailed description of.the subcooling_ monitor is included in'the

Duke Power Company, McGuire Nuclear Station, Response to TMI Concerns"

, . which was submitted to the NRC on May 23, 1980 and revised on July 18,.

1980, August 6, 1980, September 8, 1980, October 10, 1980, October 29, 1980, February 6, 1981, March 9, 1981, and June 18, 1982. NRC staff review and acceptance of the subcooling monitor is documented in the

. McGuire Safety Evaluation Report (SER), NUREG-0422, Supplement Nos,4 I' and 5. Please note that the SER includes comparisons of the McGuito

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subcooling monitor to the NUREG-0737 recommendations. ,

The subcooling monitor as described in the above references is fully '

operational and no modifications are planned.

ATTACHMENT 2.

MCGUIRE NUCLEAR STATION ,

RESPONSE TO GENERIC LETTER N0. 82-28 REACTOR VESSEL LEVEL INSTRUMENTATION SYSTEM REFERENCE DEVIATIONS a 1. Description of the proposed final system including:

a. a final design description of Items A,B Functionally, None additional instrumentation and displays;

b. ' detailed description of existing Items H,I Furctionally, None instrumentation syste:ns.

c. Description of completed or Sameas1(a) - - - - - - - - - - - - - -

planned modifications.

2. A design analysis and evaluation of Items f.,6,C, Functionally, None inventory trend instrumentation, and .D,E,F test data to support design in item 1.

3. Description of tests planned and Items C,D,E,F None results of tests completed for evaluation, ocalification, and calibration of Edditional instru-mentation.

4. Provide a table or description Items G,K None covering the evaluation of con-formance with NUREG-0737: II.F.2, Attachment 1, and Appendix B (to be reviewed on a plant specific basis)

- 5. . Describe computer, software and Items A,B None display functions associated with ICC monitoring in the plant.

6. Provide a proposed schedule for Items L,M None installation, testing, and cali-bration and implementation of any proposed new instrumentation or information displays.

7. Describe guidelines for use of Item J None reactor coolant inventory tracking system, and analyses used to develop procedures.

8. Operator instructions in emergency Items J,N None operating procedures for ICC and how these procedures will be modified when final monitoring system is implemented.

ATTACHMENT 2 (CONT.)

REFERENCE DEVIATIONS

9. Provide a schedule for additional N/A submittals required Explicit confirmation of conformance to the Appendix B (NUREG-0737) items listed below for the Reactor Vessel Level Instrumentation System.

CONFIRMATION DEVIATIONS

1. Environmental qualification Item K Nane

2. Single failure analysis Item G None

3. Class lE power source Yes None

4. Availability prior to an accident One channel (Per Techn. Spec.) None  :

5. . Quality Assurance Yes, as described in Duke None Power Company, Topical Report, Quality Assurance Program, Duke-1 A

6. Continuous ir.dications Yes None

7. Recording of instrument outputs Yes (Single train) None

8. Identification of instruments Item A Nor.e

9. Isolation Yes None For the Westinghouse Differential Pressure (dp) system a detailed response to the plant specific items stated below is provided.

RESPONSE

A. Westinghouse dp System

1. Describe the effect of instru- Item B ment uncertainties on the

measurement of level .

2. Are the differential pressure Yes transducers located outside containment?

l 3. Are hydraulic isolators and Yes j sensors included in the impulse l

lines?

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ATTACHMENT 2 (CONT.)

REFERENCE ITEMS FOR REPLY TO NRC GENERIC LETTER 82-28 REFERENCE ITEM A

SUMMARY

REPORT Westinghouse Reactor Vessel Level Instrumentation System for Monitoring Inadequate Core Cooling December,1980.

Submittal. Letter T. M. Anderson (W) to Darrell G.

Eisenhut (NRC)

NS-TMA-2358 of December 23, 1980 J

REFERENCE _ ITEM b 25 RESPONSES TO'NRC REQUEST FOR ADDITIONAL INFORMATION

! On the Westingilouse R.V.L.I.S. Sumciary Report REFERENCE TEM C SUPPLEMENTARY INFORMATION Submittal Letter E. P. Rahe (W) to L. E. Phillips (NRC)

NS-EPR-2579 of March 19, 1982 _

REFEPENCE ITEM D }j EVALUATION OF TESTS S-07-3, S-UT ~5, S-UT-7, S-NC-2, S-NC-3, S-NC-8 Submittal Letter E. P. Rahe {W) to L. E. Phillips (NRC)

NS-EPR-252C of December 9,1981 l REFERENCE ITEM E W EVALUATION OF TEST S-UT-8 Submittal Letter E. P. Rahe (W) to L. E. Phillips (NRC)

NS-EPR-2542 of January 13, 1982 REFERENCE ITEM F W EVALUATION OF TEST S-lB-1 AND FUNCTIONAL TEST Submittal Letter E. P. Rahe (W) to L. E. Phillips (NRC)

SED-SA-0081 of June 28, 1982 REFERENCE ITEM _G_ RESPONSE TO REQUEST TO WOG FOR ADDITIONAL INFORMATION Submittal Letter E. P. Rahe (W) to Dennis M. Crutchfield (NRC) NS-EPR-2597 of May 14, T982 REFERENCE ITEM H RCS WIDE RANGE PRESSURE INSTRUMENTATION Submittal Letter of E. P. Rahe (W) to R. C. Deyoung (NRC)

NS-DPR-2586 of April 21, 1982 REFERENCE ITEM I RELEVANT DRAWINGS OF EXISTING INSTRUMENTATION SYSTEMS 108D619 Revision 20 W Process Block Diagrams (See Sheet for W. R. RCS TH0T) 2326D48 Shts 1 to 5 Rev 5 RVLIS Process Block Diagram

ATTACHMENT 2 (CONT.)

ll3E306 Sat.1 Rev.13 W Flow Diagram (PAID) for RCS FSAR Fig. 5.1-1 RCS Flow Diagram Note that W Process Block Diagram which shows W. R. RCS Pressure is not recommended as suitable interfacing in-strumenta tion. Refer to Item H.

REFERENCE ITEM J Critical safety function status trees for core cooling and system inventory volumes 1, 2, and 3 Emergency Response Guidelint:s (ERG) Developed by Westinghouse Owner's Group (WOG) Sections FR-C.) and C.2, FR-I.3, FR-P.I Refer also E20.26 (which is a new section to be added, for natural circulation cooldown regarding depressuriza-tion in the upper head. Although this shows the use of thr RVLIS instrumentation, it is not scecifically for inadequate core coolirg (ICC) monitoring.

Volume 1 and 2 was under cover of 0G-64,11/30/81

0. Kingsley (WOG) to D. Eisehut (NRC)

Volume 3 was under cover of 0G-83,1/4/83, C. Kingsley (W93) to D. Eisenhut (NRC)

All r: ember utilities received copies under cover of l etters:

W0G-81-235,12/2/81 WOG-83-100,1/4/83 REFERENCE ITEM K ENVIRONMENTAL QUALIFICATION (Note Various Equipment Data Qualification Packages)-

i.e., EQDP - for RVLIS instrumentation are submittals as supplements to the Environmental Qualification topicals WCAP-8587, non-proprietary (which provides summary EQDP-s) and WCAP-8687, proprietary (which provides detailed EQDP's).

EDQP References are as follows:

1. ESE-4 D/P Transmitters Outside Containment - Previously submitted (Note, this EQDP does not specifically reference transmitters to RVLIS, but this will be done by Westinghouse July,1983)

2. ESE-13 7300 Process Electronics - Previously submitted (Note, this EQDP does not specifically reference to RVLIS, but this will be done by Westinghouse July,1983)

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. a. ATTACHMENT 2 (CONT.)

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- Reference Item L Facility Operating License NPF-9 McGuire Unit 1 OL.' Condition 2.C.ll.(f) as modified by Amendment Number 10 requires installation of a Reactor Vessel Level Instrumentation System be' fore startup following the first refueling cf the unit.

Reference Item M Facility Operating License NPF-17 McGuire Unit 2 OL Condition 2.C.10(c) requires installation of a Reacter Vessel Level Instrumentation  ;

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System before startup following the first refueling  ;

of the unit.

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, Reference Item N - ICC Operating Procedures Duke Power plans to upgrade the McGuire emergency operating procedures based upon the Emergency Re-sponse Guidelines (ERG) developed by the Westinghouse Owners Group. The RVLISfwill be incorporated into procedures according to these guidelines.

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ATTACHMENT 3 INCORE THERMOC0UPLE SYSTEM I. PRESENT DESIGN The present incore thermocouple system has 65 T/C's (thermocouples) positioned to sense exit flow temperature of selected fuel assemblies. See Figure 1 for these selected assemblies. The T/C's penetrate the reactor vessel head in 5 locations known as instrument ports. Each instrument port has 13 T/C's.

Electrical connection to the T/C's is made at the instrument ports by connectors.

The T/C's are cabled from the instrument ports to reference junction boxes to allow transition to copper for the remainder of the cabling. Reference junction temperature is monitored by the plant computer. After leaving the reference junction boxes, the cabling runs through containment electrical penetrations to the Auxiliary Building. Cabling then enters the Control Room terminating at the back up display. The back up display by use of push-to-read switches can display any desired T/C. All T/C's are input into the plant computer by running cables from the input side of the switches on the back up display to the computer input cabinets.

A. PRESENT SYSTEM CAPABILITIES (NUREG 0737 II.F.2 Attachment 1 format)

1. Core inlet temperature data is used with core exit temperature to give radial distribution of coolant enthalpy rise across the core.

This is available to the operator via CRT or hard copy.

2. The plant computer via CRT is the operator's primary display having the'following capabilities:

a. A spatially oriented core map is available on demand indicating temperature and enthalpy rise at each core exit thermocouple location.

b. The incore thermocouples are an input into the saturation monitor program to assist operator actions for inadequate core cooling procedures.

. ATTACHMENT 3 (CONT.)

c. ' Direct re.adout via CRT and hard copy print out capability ,

is provided for. all thermocouple temperatures. This readout range extends'from 200 decrees F.'to 2300 degrecs F.

d. Trending of selected,thermocouhles to show temperature - time historyisavailableondemanI.

e. Alann capabilities are provided thru ths' saturation monitor program. ,

f. To he addressed in the ongoing Control Room Debign Review.

3. A back up display is provided to" read any of the thbr.aoccuplcs.

With push-to-read switches, readings can,be taken well withir the six minute time guiriance. The range of this back up display extends' from- -

200 degrees F. to~2300 degrees F.

4. A human factors analysis will ed part of the ongoing Control Room Review'(A schedule firLthis review will be submitted in response toNUREG0737Supplemenk1LiyApril 15, 1983).

5. Notapplicabletot$epresentsystem.

6. The primary arid back up displays are electrically independent and

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are on separate. highly reliable power' systems. Isolation devices are not necessary in the present system >as the back up display is not in the circuit until a push-to-read switch is used.

7. Documentation is unavailable recarding the environmental capabil'ities of the present' system, but all readouts are located in a mild controlled environment.

8. Availability of the plant computer has been greater than 99%. Thi.s documentation has previously been submit'ted via NUREG 0578/TMI Action Plan response.

9. QA provisions cited in Appendix B do not apply to the present system.

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ATTACHMENT 3 (CONT.)

II. INCORE THERM 0 COUPLE UPGRADE An upgrade to the McGuire Incore Thermocouple System is planned in order to better meet the requirements of NUREG 0737 Item II.F.2 Attachment 1 and Appendix B. To ensure an expedient, orderly process, the system upgrade will be accomplished in two phases.

The first phase will consist of upgrading the in-containment connectors, cabling system, and penetrations to withstand harsh accident environments.

The second phase will consist of an upgrade of the outside containment portion of the system including backup display. This is integrated with the Control Room Revier effort.

A. PHASE 1 UPGRADING Please refer to the present design description to aid in understanding this upgrade.

Qualification of the existing thermocouples is assumed. At least 16 targeted T/C's will have their connectors at the instrument ports re-placed. Mineral insulated thermocouple extension cable will replace the existing softline cable. The mineral insulated cable will continue all the way to the Containment liner with appropriate disconnects for refueling provided. A separate route will be used from the non-target T/C's. Separation criteria as defined in Chapter 8 of the FSAR, cannot be totally met on the Vessel Head because of the physical configuration of the area. Separation as practical will begin as the cables leave the Upper Reactor Head and will be fully separated from the Refueling Canal Wall to the Containment liner. At the Containment liner a separate electrical penetration will be provided for the targeted T/C's.

B. PHASE 2 UPGRADE The Phase 2 upgrade will start at the Auxiliary Building side of the Containment Penetrations. The targeted T/C's cabling will be separated

ATTACHMENT 3 (CONT.)

from the other T/C's. An IE qualified back up display will be installed.

The targeted T/C's will then be input into the Plant Computer as the pri-mary display through a qualified isolation device. The display types and locations ( both primary and backup) will be selected as part of the Control Room Review.

C. SCHEDULE The Phase 1 Incore Thermocouple System upgrade will be accomplished during the first refueling shutdown of each of McGuire Unit I and 2. The Phase 2 Incore Thermocouple System upgrade will be an integrated part of the installation of changes from the Control Room Review. The schedule for this review will be submitted by April 15, 1983 in response to NUREG 0737 Supplement 1.

D.

UPGRADED SYSTEM CAPABILITIES (NUREG 0737 II.F.2 Attachment 1 fonnat)

Display capabilities will be the same as the present design description with exceptions listed below. . Exception numbers correspond to original design numbers.

2(f) & 4 The control Room review will be completed and all operator display devices will be human factor designed.

5. System design and qualification criteria are explained in the appropriate sections of this response.

6. The primary and back up display will be energized from independent battery backed power sources. The back-up display and associated hardware will be on 1E power. Separation as defined in Chapter 8 of FSAR will be met from the refueling canal to the isolation device.

7. The targeted T/C instrumentation (T/C qualification assumed) will be seismically and environmentally qualified up to and including the isolation device. Seismic qualification will be consistent with

ATTACHMENT 3 (CONT.)

the methodologies described in Section 3.10 of the McGuire FSAR. Instrumentation subject to a harsh environment will

, be environmentally qualified consistent with the Duke Power Company position on the Category II Guidelines of NUREG 0588 as detailed in the Duke submittal of June 30, 1982 Docket Nos 50-369, 50-370. The isolation device will be in an accessible area following an accident.

8. Quality Assurance provisions cited in Duke Power's QA program for nuclear safety related equipment will be met for all equipment installed except the primary display and hardware beyond the isolation device.

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