ML20072H548

Forwards Response to 821210 Generic Ltr 82-28, Inadequate Core Cooling Instrumentation Sys, Consisting of Upgraded Subcooling Margin monitors,core-exit Thermocouples & Reactor Coolant Inventory Tracking Sys Info

ML20072H548
Person / Time
Site:	Beaver Valley
Issue date:	03/25/1983
From:	Carey J DUQUESNE LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
GL-82-28, TAC-45114, NUDOCS 8303290473
Download: ML20072H548 (9)

Text

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'Af Telephone (412) 393-6000 Nuclear Division P.O. Box 4 Shippingport, PA 15077-0004 March 25, 1983 Director of Nuclear Reac+or Regulation United States Nuclear Regelatory Commission Attn: Mr. Darrell G. Eisenhut, Director Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-28; Inadequate Core Cooling Instrumentation System Gentlemen:

' lour letter ef December 10, 1982, requested additional informa-tion pertaining to an Inadequate Core Cooling Instrumentation System consisting of upgraded subcooling margin monitors, core-exit thermo-couples and a reactor coolant inventory tracking system. This infor-ma tion has been included with this letter as an attachment for your review. Additionally, you have requested that we identify the design for the reactor coolant inventory system we have selected and submit schedules for engineering, procurement and installation. We have selected the Westinghouse Differential Pressure System and have provided informa-tion regarding its design and installation in previous submittals.

These submittals are further referenced in the attachment.

The current schedule is to complete installction of the Reactor Vessel Level Indication System (RVLIS) hardware during our third refueling outage scheduled to begin in June of 1983. System calibration is planned af ter refueling during Cold Operations and system testing is planned during Hot Operations. If the work associated with making the system operable, including final system calibration and testing, cannot be accomplished within our existing 14 week scheduled outage, we will not delay the return of the unit to service solely for the completion of these activites.

We believe this action to be reasonable since the RVLIS cannot be used for its intended purpose until the plant specific design and instal-lation has been approved by the NRC staff, until we have completed that portion of the control room design review where the operator must evaluate RVLIS indications and until instructions for the use of RVLIS have been incorporated into our emergency operating procedures. Until such time as these actions are completc, this instrument cannot be used by the operatore for the purpose of taking mitigating actions during an emergency condition.

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• Docket No.~50-334, License No. DPR-66 Generic Letter No. 82-28; Inadequate Core Cooling Instrumentation System Page 2 The reactor vessel level instrument is an aid, but not a necessity l in the detection of the onset of inadquate core cooling. It is our position that resuming operation without RVLIS will not decrease our margin of safety.

As indicated in the attachment, additional information will be provided by April 21, 1983 to complete our reiponse to this generic letter.

We have been in contact with our NRC Project Manager with respect to providing this submittal beyond the requested response date and have discussed the scope of your request for additional' information with members of your stuf f. Based on a March 21 conference call for obtaining clarification with a staff reviewer, we have re-evaluated and expanded upon our response and have determined additional time would be required to provide a complete response wi.ich satisfies the scope of your request.

Specific areas requiring additional review are indicated in the attachment.

If you have any questions regarding this response, please contact myself or members of my staff.

Very truly yours,

. J. Carey Vice President, Nuclear cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555

O COMMONWEALTH OF PENNSYLVANIA) sS:

COUNTY Of BEAVER this ed6;d[dayof MAb ,

/ 9 b , before me, A//7. 7/WInh, a Notary Public in and for said Commonwealth and~ County, personally appeared J. J. Carey, who being duly sworn, deposed, and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge, information and belief.

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w. ATTACHMENT.

. Response to Generic Letter 82-28 Inade'quate Core Cooling Instrumentation System

~

dated December 10,'1982 thecklist for Plant, Specific Review of Inadequate Core Cooling (ICC) Instrumentation System For: Beaver Valley Power Station, Unit No.1 Docket No. 50-334

_ Operated by: Duquesne Light Company

.Theffoll'owing items for review are taken from NUREG-0737, pp II.F.2 .

3, and 4. Responses should be made to full requirements in NUREG-0737, not abbreviated forms below. Applicants'should provide reference to either the applicant's submittal or the generic description under the column'labled " Reference." :These items are required to be reviewed on_a-plant specific basis by NUREG-0737 for all plants. ' Differences from the genetic descriptions provided by Westinghouse, :the Westinghouse Owner's

- Group,' Combustion Engineering, or Combustion Engineering Owner's Group must be indicated'by "yes or.no" in the columnLlabled deviations and rust be justified. Under the Column labeled schedule, either ' indicate that your documentation of the item is complete gor provide a proposed schedule for your euhmittal.

s Reference Deviations Schedule 1.- Description of the proposed final system including:

a.. a final design- description of additional-instrumenta-tion and displays; 1, 4 No Complete

b. detailed description of existing instrumentation systems 1, 6 Yes Complete Description of Core Exit'Thermocouples The thermocouple incore temperature measuring system consists of 51 chromel-alumel thermocouples installed within selected guide tubes which penetrate the reactor vessel head and termin-ate at the' exit flow end. (top) of selected fue1' assemblies.

The thermocouple extension ~ wires (chromel-alumel) which are external of the core are terminated in two reference ' junction boxes within the containment. The reference junctions, which are maintained within a controlled temperature range, permit the use of conventional isolated copper wiring from the junction boxes through the containment penetrations to the thermocouple readout devices. These thermocouple signals pass through ref-erence junctions, through penetrations in the containment and

At tachment '

. , Gintric Lattar 82-28 Rmaponsa Page 2 then to terminal strips in the flux mapping consol'e.

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From l.

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there,; they branch into twc signals, one ~ connecting to the -

computer and the other to a. precision indicator with manual selector switches.- Primary readout of the incore thermocouples is by _the plant computer, with backup readout. provided by the precision indicator in the~ Incore Flux Mapping Control Console (FTEC): which is intended for use .in the' event the computer is inoperable.

Each thermocouple is' 1/8' inch (nominal) diameter, stainless steel sheathed, aluminum oxide- insulated, with the : trailing end terminated in a male thermocouple connector. The thermoelectric characteristics conform to the K calibration curve within t 2F from zero to 530F and ~

within 3/8 percent of any point from-530 to 700F, Ea ch thermo-couple is supplied to the specific length requirmt for its assigned location. .

The two thermocouple reference junction boxes (Dynasciences Corp.

Model BRJW14S-36TT) provide a controlled 160F temperature refer-ence for the incore thermocouples. Each reference junction box contains three platinum _ resistance temperature detectors (RTD) .

Two of'the RTD's from each unit are. connected directly to the l- -plant computer for monitoring of ' reference junction temperature; the third RTD in each unit is an installed spare.

- The Honeywell~ Precision Temperature Indicator (Model Y156188) is, I mounted in the Flux Mapping Control-Console. This_ instrument is supplied with a double ' range measuring circuit which permits measurement'within the ranges 100 to 400F or 400 to 700F.

Selection of the single thermocouple to be indicated is made

- by the nonlocking key switches on_the front of the indicator.

The switch must be manually held in position (lef t or right)

' ~

to monitor the desired thermocouple. . The switch is spring returned to L the neutral . (center) position. Since the thermo-couple input signal to the indicator is in parallel with the

$ ant computer, a contact closure signal is provided to inform the computer.when any thermocouple is being monitored by the indicator.

Design and/or Operating Data Incore Thermocouples Number 51 Type Chromel-Alumel Nominal 0.D., In. 1/8 Range, F 0-700 Accuracy, F (0-530F) 12

% (530-700F) t 3/8

r- .a L ' Attachment -

- Gantric Lstter 82-281 Rsapsure -

'. Page 3:

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Deviation: A deviation is indicated' based on the final system design with. respect-to environmental qualifications since-this equipment does 'not satisfy all NRC final. design criteria.- This will be further discussedLwhen addressing the qualification of the ICC Instrumentation System. Justificativa vill be provided as part of the submittal' on environmental qualifixation of electrical equipment.

-Note: The NRC Staff has completed'un evaluation of our subcooling:

margin monitor. This is-documented in reference 7 which was an evaluation of our action taken ,to satiafy the TMI Lesson Learned Category "A" items.? The long term action on the subcooling mon-itor.as identified in the NRC clarification letters, reference 8, and reference 9 (enclosure 1), states the instrumentation qualifica-tions must be upgraded to meet 1the requirements of Regulatory Guide 1.97. An evaluation of Regulatory Guide 1.97, Rev. 2, will be completed:in accordance with our response to Supplement I of NUREG-0737.

Reference Deviations Schedule-

'c.- description of completed or planned modifications 1,.6 Yes Complete 1 Deviation: A deviation'is indicated based on the completed modification which installed the subcooling margin monitor which has inputs that do not satisfy all NRC final design criteria with-respect

<tu environmental qualification.1This will be further discussed when addressing the qualification of the ICC Instrumentation System. Justification will belprovided as part of the. submittal on environmental qualification of electrical equipment.

Note: A schedule providlug a description of planned modifications, .

if any, to instrumentation- systems described in 1b above' will be addressed within'the implementation plan developed in response to Generic Letter 82-33, Supplement I to NUREG-0737 or in sub-sequent submittals relating to ' environmental qualification. It is therefore considered that additional submittals for the purpose of addressing.NUREG-0737, II.F.2; item IC of Documentation Required or item IC of Generic Letter 82-28 will-not be necessary.

Reference Deviations Schedule

2. A design analysis'and evaluation l

of inventory trend instrumentation,

! and test data to support design in~ Item 1 1 No Complete

3. Description of tests planned and results of tests completed for

-evaluation, qualification, and calibration of additional instru-mentation. 1, 4 No Complete I

t

At tachment Ginnric Lotter 82-28 Respanza

'Page 4-R_eference Deviations Schedule

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-4. Provide a table or description

- covering the evaluation of con .

formance with NUREG-0737: II.F.2, Attachment I, and Appendix B -(to .

be reviewed on a plant specific basis)

• 1, 3, 5 Yes 4/21/83 5.: Describe computer, software and display functions associated with ICC monitoring in the plant. 1 -

4/21/83

6. Provide a proposed schedule for installation, testing and cali-bration and implementation of any proposed new instrumentation or information displays. 1, 2 No Complete NOTE: This submittal provides our current schedule

7. Describe guidelines for use of reactor coolant inventory tracking system, and analyses used to develop procedures. 1 No- Complete

8. Operator instructions in emergency operating procedures for ICC and how these procedures will be modified whea final monitoring sys tem is implemented. 1 - No ' Complete Note: New emergency operating procedures are currently being developed

, based on the Westinghouse Owner's Group Emergency Response Guide-lines (ERG's). These ERGS have been submitted by the Owner's Group to ' the NRC for review. Additional submittals on this i

subject will be provided as part of Supplement I to NUREG-0737.

(

9. Provide a schedule for additional

submittals required ** 4/21/83 Schedule

Additional information covering the evaluation of con-formance with NUREG-0737 Item II.F.2 Attachment 1 and Appendix B as requested in Item 4 above and additional information describing computer sof tware and display functions associated with ICC monitoring as requested in Item 5 above will be provided by the above date.

• II.F.2 Attachment 1 -(for Core Exit Thermocouples)

In response to item 4 in the above checklist, the following materials should be included to show that the proposed system meets the design and qualification criteria for the core exit thermocouple system.

1 i

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. , ,. - . , - . . - - - . . _ . . - - , , ~ . , , . - , . - . - . - . _ . , .. -,-- .

A'ttachment' Generic Letter 82-28 Response

'Page.5' Response: _This information requested will be provided in response:

to item 4 in the above checklist consistent with the above schedule.

' Appendix B (of NUREG-0737, II.F.2)

Confirm explicitly the conformance to the Appendix B items listed below for the ICC1 instrumentation, i.e,. the SMM, the reactor coolant inventory tracking system, the core exit thermocouples and the display systems.

Reactor Coolant Inventory Tracking System Reference Deviations

1. Environmental qualification 3. No

2. Single failure analysis 3 No

3. Class IE power source 3 No

4.  : Availability prior to an accident . 3 No

5. Quality Assurance 3 Designed to meet 10 CFR 50, App. B

6. -Continuous indications 3 No 7.- Recording of instrument outputs 3 No

8. Identification of instruments' 3 No

9. Isolation 3 No Note: Additional information will be provided on the subcooling margin monitor and the core exit thermocouples and display systems by 4/21/83.

• • For the users of either Combustion Engineering Heated Junction Thermocouple (HJTC) System or Westinghouse Differential Pressure (dp) system a detailed response to the plant specific items stated below should be provided:

Reference Deviations A. Westinghouse dp System

1. Describe the effect of instrument uncertainties on the measurement of level. 4 No 12 . Are the differential pressure transducers located outside containment? 1 No

3. Are hydraulic isolators and

- sensors included in the impulse lines? 1 No l

r:

.- At tr.chment a

Generic. Letter 82-28 Response

,Page'6 Reference Deviations B. CE HJTC System

1. Discuss the spacing of the sensors from the core- align-ment plats to the top of the reactor vessel-head. How would the decreese in resolution due to~the loss of a' single sensor affect the ability of the system to detect an approach to ICC? N/A References

1. Letter, C. N. Dunn to D. G. Eisenhut, dated 12/30/80

2. Letter, J. J. Carey to D. G. Eisenhut, dated 4/28/82

3. Letter, J. J. Carey to S. A. Varga, dated 4/15/81

4. Letter, J. J. Carey to S. A. Varga, dated 9/2/81

5. . Letter, J. J. Carey to S. A. Varga, dated 12/30/81

6. Letter, C. N. Dunn 'to D. G. Eisenhut, dated 6/26/80 7.. Letter, S. A. Varga to C. N. Dunn, dated;10/9/80

8. Letter, H. R. Denton to All Operating Nuclear Power Plants, dated 10/30/79

9. Letter, D. G. Eisenhut to All Licensees, dated 10/31/80; NUREG-0737 I

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