ML20080P660
| ML20080P660 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/09/1983 |
| From: | Brown W, Wasenko M CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20080P657 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8310070293 | |
| Download: ML20080P660 (33) | |
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CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT POSITION PAPER ON REGULATORY GUIDE 1.97 DATE:
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SUBMITTED BY:
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RECOMMENDED BY: ((
w APPROVED BY:
0310070293 e3093o PDR ADOCK 05000324 F
TABIE OF COT 3NPS SECTION TITLE PAGE 1.0 Introduction 1
2.0 General Position Statenent 1
3.0 Brunswick's Position Statement on 101.97 Positions 1
4.0 Plant Specific Position on Each variable 7
5.0 Abbreviations 30 f
6.0 References 31 Page i 1
1.0 INrBCEUCTION i
This docunent states Brunswick's position on Regulatory Guide 1.97, I
Revision 2, "Instrinnentation for Light Water Cooled Nuclear Power Plants to M aaaa Plant and Environs Conditions During and Following an Accident" (referred to in this doctanent as BG 1.97). In aaaaaaing aG 1.97, Brunswick used infonnaticx1 contained in ANS 4.5, NROG Emergency Procedure Guidelines, Brunswick's FSAR, and assessment of BG 1.97 done by the BWBOG. Secticn 2.0 provides Brunswick's general position statenent. Section 3.0 provides Brunswick's position statements on the generic BG 1.97 criteria.
Section 4.0 details our position on each of the variables listed in Table 1 of BG 1.97.
" Agreement" or " Concurrence" means Brunswick will provide /has provided the reccanended range and category stated in RG 1.97 unless noted.
2.0 GENERAL POSITION STATEMENT Brunswick concurs with the intent of aG 1.97, which is to ensure that naaaa y and sufficient instrinnentation exists in a nuclear power station for amaa==ing plant and envia.u ai.a1 conditicn during and following an accident as required by 10CFR Part 50, Appendix A and General Design Criteria 13,19 and 64.
3.0 BRWSWICK'S POSITICN STATDENT ON RG 1.97 REGUIATORY POSITIONS The position statements given below correspond to the referenced paragraphs in Section C, "REGUIATORY POSITICE" of BG 1.97.
Paragraph 1.1: Brunswick concurs with this definition.
Page 1
3.0 BRONSWICK'S POSITION STATDENT CN RG 1.97 REGUIA'IORY POSITIONS (Cont'd)
Parap.@ 1.2:
Brunswick concurs with this definition.
Paragraph 1.3.la:
Brunswick is an operating plant licensed prior to aG 1.89, " Qualification of Class 1E Equipnent for Nuclear Power Plants". Brunswick will ccanit to ensuring envimmaitdl qualifica-tion as required by NUREG-0588 where applicable and Memorandun and order CLI-80-21. Additionally, Brunswick will mly qualify agiir-mt located in a harsh environnent to these.Qements. Thus gi4:=mt forming part of an instranentation loop which is located in a mild environnent may not be qualified by testing.
94-ia qualification of existing egiiyt will be in accordance with Brunswick's FSAR for the original plant design. New agii =mt will be maiamically qualified in acmrdance with IEEE-344-75. An isolation device will be pccvided between IE and Non-IE porticm of loops.
Paragraph 1.3.;Lb:
A third channel of instrumentation for a Category 1 variable will be provided if a failure of coe accident monitoring channel results in information ambiguity that would lead operators to defeat or fail to a m lish a required safety function, and if one of the following measures cannot M done:
1.
Cross 1: ding with an hviapandent channel that mcnitors a different variable bearing a known relationship to the failed monitoring channel.
2.
Perturbing the measured variable to determine the failed channel by observing the response on each instrument.
3.
Using portable instrunentation to validate correct channel.
Page 2
3.0 BRINSWICK'S POSITION STATENENT ON BG.1.97 REGUIRIORY POSITIONS (Cont'd)
Paragraph 1.3.lb:
(Continued)
Category 1 instrtmentation channels shall be electrically division-alized and handled in accordance with Brunswick's ESAR design requirements for divisionalized channels and circuits. Generally, Brunswick is designed to IEEE-279-1971.
Paragraph 1.3.lc:
All Category 1 instrument channels shall be powered frcri plant energency power sources designed in accordance with Brunswick's FSAR criteria and ccumitments.
Paragraph 1.3.ld:
Brunswick concurs.
Paragraph 1.3.le:
The quality assurance requirements invoked for the currently installed agnimant were the Corporate Quality Assurance Program in effect at the time of purchase. As part of the implementation of this Regulatory Guide, Brunswick will ensure that the equipnent associated trith Category 1 in.L w=it. channels are on the plant's Q-List such that the current Brunswick Quality Assurance P W iam requia.= -ii.= will be invoked for future procure-ment, maintenance, and design change activities. Adherence to the requirements of the regulatory gnidaa listed in this pa m i da will be done if they are in the Brunswick QA program ccmmitments.
Refer to letter OQA-81-026 addraaaad to Mr. Eisenhut for details cri the Brunswick QA program.
Parzkg di 1.3.lf:
Brunswick concurs with this position.
Paragraph 1.3.1g:
Brunswick concurs with this position.
Page 3 I
l 1
3.0 BRUNSWICK'S POSITICN STATDENT CN RG 1.97 REGUIATORY POSrrIONS TCont'd)
Paragraph 1.3.2a:
Brunswick's position on these criteria for Category 2 instnnents are the same as given for par i@ 1.3.la w
above. Instruments that are not part of a safety-related systen will not be aai-ically qualified unless Brunswick's ESAR invokes aaimic requirements for the associated systen.
Paragraph 1.3.2b:
Brunswick concurs with this position.
Parg sapu 1.3.2c:
Brunswick concurs with this position.
Paragraph 1.3.2d:
Brunswick's positicn on quality assurance requirements for category 2 safety-related instrtments is the same as stated for paragraph 1.3.le above. For non-safety related category 2 instrtments quality assurance requirements will be invoked consistent with the importance to safety of the instrtment.
Paragraph 1.3.2e:
Brunswick concurs with this position.
Paragraph 1.3.2f:
Brunswick concurs with this position.
Paragraph 1.3.3a:
Brunswick concurs with this position with the understanding that envirornental qualification testing is not nacaaaary in selecting egiimant for the service envirement.
Paragraph 1.3.3b:
Brunswick concurs with this position.
Paragraph 1.4.a:
Isolation devices will be provided between mcnitoring i h.t channel and other user circuit only if the other circuit is designed to less strirgent requirements.
Page 4
3.0 BRUNSWICK'S POSITION STATEMENT ON RG 1.97 REGULATORY POSITIONS (Cont'd)
Paragraph 1.4.b:
Brunswick believes the identification of instruments for post-accident monitoring falls into the realm of human factors engineering and must take into consideration all current activities such as control board review, new emergency guidelines and procedures.
By incorporating these activities and RG 1.97 into an integrated project (SECY 82-111) the NRC has ensured that human factors engineering and integration is achieved.
Brunswick will not commit to labeling the instruments but will develop a philosophy regarding instrument channel identification as part of the SECY-82-111 project. We believe this meets the intent of the guideline position.
Paragraph 1.5.a:
Servicing, testing, and calibration procedures will be established and performed on a frequency necessary to maintain instrumentation capability.
This frequency should be equal to or less than the interval between refuelings.
If the frequency is longer than refueling intervals, a justification will be provided.
Paragraph 1.5.b:
Brunswick concurs with this position.
Paragraph 1.5.c:
The utilization of design features such as locked cabinets and seals to allow establishment of controlled access to equipment setpoint, calibration and other adjustments is not feasible at Brunswick. Brunswick does not usually endorse such design considerations, but relies on procedure controls and personnel training.
Page 5
3.0 BRUNSWICK'S POSITICN STATEMENT CN BG 1.97 REGOTAIORY POSITICNS (Cont'd)
Parc.g.d4 1.5.d:
Brunswick concurs with this position.
Paragraph 1.5.e:
Brunswick concurs with this position.
Paragraph 1.5.f:
Brunswick generally concurs with this position.
However, several exceptions are specified in Section 4.0.
Paragraph 1.5.g:
Brunswick concurs with this position.
Paragraph 1.5.h:
Periodic checking, testire, calibration and calibration verification for g.ci.ection instrunentation is in accordance with IEEE-338-1971, " Trial - Use criteria for the PaMic Testing of Nuclear Power Generating Stations Protective Systans."
Paragraph 1.6:
Brunswick's specific position cn each variable is given in Section 4.0.
i Regulatory Guide Section C.2 Paragraphs 2.1, 2.2, 2.3 and 2.4: Brunswick concurs with these positions.
Paragraph 2.5: Brunswick's position is outlined in our positions stated for paragraphs 1.3.la through 1.3.3b, 1.4a, 1.4b and 1.6.
Page 6
4.0 PIRC-SPECIFIC POSITICN CN EACH VARIABLE 4.1 Plant-Specific variables Considered by Brunswick to be Tvpe A BG 1.97 M h a Type A variables as "those variables to be monitored that provide the prinary infomation required to pemit the control rom operator to take specific manually controlled actions for which no autmatic control is provided and that are required for safety systens to accmplish their safety functions for design basis accident events". Primary infomation is defined by RG 1.97 as "infomation that is essential for the direct amlistrent of the specified safety functions."
(variables associated with contingency actions that may be identified in written g. Mares are excluded frca this definition of primary information.)
The following paragraphs discuss each Type A variable by designating the safety function (s), operator action (s),
and giving a measurenent range for the variable. All type A variables are category one and have been er will be provided at Brunswick.
4.1.1 variable Al - RPV Pressure The RPV Pressure gives the information needed for the operater to maintain core cooling and reactor coolant systen integrity. Operator action calls for depressurizing the RPV to maintain a safe cooldown rate by any of several systems, such as HPCI, PCIC, ADS, and RWCU.
'Ihe operator can also manually open one SRV to reduce pressure to below the SRV setpoint if any SRV is cycling. 'Ihe range rez----Med for this variable is 0 to 1500 psig in accor-dance with FSAR Section 5.2.2.2 and FSAR Table 7.5.1-1.
Page 7
4.0 PLANT-SPECIFIC POSITION CN FXR VARIABLE (Cont'd) 4.1 Plant-Specific Vanables Considered by Brunswick to be Type A 4.1.2 Variable A2-RPV Water Level Be RPV Water Level gives the infounation needed by the operator to restore and maintain RPV water level. Me range ra,- erded for this variable is -180 to +295 inches of water. The installed 1
l range will meet or aM the r+ >- Med range.
l 4.1.3 Variable A3 - Suppression Pool Water T m perdture i
Suppression Pool Water FP nture gives the information needed by the operator to maintain con
- air-mt integrity and reactor coolant system integrity. Operator acticms are: Oper-ate available suppression pool cooling systen i
when the suppression pool tanparature exceeds the normal operating limit, maintain RPV pressure at a rainM pressure if the suppression i
pool temperature cannot be main
- aired below the j
heat capacity tanpanture limit, and at+M to close any stuck open relief valve. We r+ x ----ded range for this variable is 30' to 230'F. S e installed range will neet or exceed the r h -creed range.
Page 8
4.0 PLANT-SPECIFIC POSI" ION ON EACH VARIABLE (Cont'd) 4.1 Plant-Specific Variables Considered by Brunswick to be Type A 4.1.4 Variable A4 - suopression Pool Water Level Suppression pool eter level provides infomation necessary for the operator to maintain contalment integrity. Operator action calls for nalntaining suppression pool water level within nomal operat-ing limits. If the suppression pool water level cannot be main +ained below the suppression pool load limit, the operator is to maintain the RPV pressure below its cou.---px iing limit. The range will be wealmately minus ten feet, which is the mid-plane of the lowest ECCS suction line to a position six feet above normal water level. This range follows frm NUREG-0737 Its II.F.1, At+a 4 e11t 5.
4.1.5 Variable A5 - Drywell Pressure Drywell gas ure provides information necessary for the operator to maintain contaiment and reactor coolant syst s integrities. Operation action is to wub.Ol primary containment pressure by contaiment pressure control systems. A range of minus 5 to plus 245 psig is provided and is in accordance with NUREG-0578. See PM 80-025, 026.
Page 9
4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.1 Plant-Specific Variables Considered by Brunswick to be Type A 4.1.6 Variable A6 - Drywell Temperature Drywell temperature provides information necessary for the operator to maintain containment and reactor coolant system integrities.
Operator action is to operate the drywell cooling system and those systems necessary to compensate reactor water level.
The range recommended for this variable is 40 to 440 F.
See Brunswick's FSAR section 6.2.1.1.1, page 6.2.1-4.
4.1.7 Variable A7 - Suppression Pool Pressure The Suppression Pool Pressure gives the information needed by the operator to maintain containment and reactor coolant system integrities.
The operator uses this information along with drywell temperature and suppression pool temperature to determine when to initiate the suppression pool and drywell sprays. A suitable range for this variable is minus 5 to plus 245 psig.
4.1.8 Variable A8 - Drywell and Suppression Pool Hydrogen, Oxygen Concentration Containment Hydrogen and Oxygen concentrations provide information necessary for the operator to maintain containment integrity.
Operator action is to initiate the combustible gas control system in the Containment Atmosphere Dilution (CAD) system La the l
f Brunswick design.
The ranges for these variables will l
meet or exceed the requirements of RG 1.97.
Page 10 l
1
4.0 PLANT-SPECIFIC NSITICN ON EACH VARIABIE 4.2 Brunswick's Pesition on 101.97 Tvoe B Variables 101.97 defines Type B variables as those that provide "informatim about the mlimbr=rt of plant safety functions". Key variables under type B are those variables which most directly indicate the amlistunent of a safety functim.
Each variable is discussed in the following paragraphs and where this variable is covs ai under another variable type, it is indicated.
4.2.1 Variable B1 - Neutron Flux Brunswick agrees with the regulatory guide.
4.2.2 Variable B2 - Control Rod Position Brunswick is in agreement with BG 1.97 and indicaticn is provided to monitor this variable.
4.2.3 variable B3 - BCS Soluble Baron Cbr e ib.& tion Brunswick concurs with the ability to obtain a sample of reactor core coolant. Sampling will be dme through the Post-Accident Sampling System. Analysis will be per-formed in acmrdance with NUREG-0737, Iten II.B.3.
4.2.4 Variable B4 - Coolant Level in Reactor 1
Refer to variable A2, paragraph 4.1.2.
Page 11
4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.2 Brunswick's Position on RG 1.97 Type B Variables 4.2.5 Variable B5 - BWR Core Thermocouples Not required at this time per Supplement 1 to NUREG-0737.
4.2.6 Variable B6 - RCS Pressure Refer to variable Al paragraph 4.1.1.
4.2.7 Variable B7 - Drywell Pressura Refer to variable A5, paragraph 4.1.5.
4.2.8 Variables B8 - Drywell Sump Level The Brunswick plant design does not require continuous measurement of drywell sump level.
A LOCA signal will prevent operation of the sump pumps and will close con-tainment isolation valves to eliminate the possibility of radioactive caterials leaking outside the primary containment. During and after a LOCA, the drywell sumps overflow to the suppression pool. Measuring sump level after an accident would not accomplish anything.
4.2.9 Variable B9 - Primary Containment Pressure l
I Total primary containment pressure is monitored by the combination of drywell pressure and suppression pool l
pressure. Refer to variable AS, paragraph 4.1.5 and variable A7, paragraph 4.1.7.
Page 12 i
4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.2 Brunswick's Position on RG 1.97 Type B Variables 4.2.10 Variable B10 - Primary Containment Isolation Valve Position Brunswick provides position indication for all isolation and containment boundary valves except check valves and manually operated valves.
4.3 Brunswick's Position on RG 1.97 Type C Variables RG 1.97 defines Type C variables as "those variables that provide information to indicate the potential for being breached or the actual breaching of the barriers to fission product releases.
The barriers are (1) fuel cladding, (2) primary coolant pressure boundary, and (3) containment." Key variables under Type C are "those variables which most directly indicate the accomplishment of a safety function." Each variable is discussed in the follow-ing paragraphs and where this variable is covered under another variable type, it is indicated.
4.3.1 C1 - Radioactivity Concentration or Radiation Level in Circulating Primary Coolant.
Brunswick does not intend to continuously monitor the radioactivity level of the primary coolant. During normal operation the Radiation Monitoring System pro-vides indication of breach.
During accident conditions the Post-Accident Sampling System will provide local indication of radioactivity concentration in the reactor coolant while samples are being taken for analysis.
Page 13
i 4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.3 Brunswick's Position on PG 1.97 Tyee C variables 4.3.2 Variable C2 - Analysis of Primary Coolant Brunswick concurs and will provide a system that meets the requirements of NUREG-0737 It s II.B.3.
4.3.3 Variable C3 - MfR Themoccuple See variable B5, paragraph 4.2.5.
4.3.4 Variable C4 - PCS Pressure The requim=Rs for the variable are met by vanable Al, paragraph 4.1.1.
4.3.5 Variable C5 - Primary Contaiment Area Radiation See Variable El, paragraph 4.5.1.
4.3.6 Variable C6 - Drywell Drain Sumps Level l
see discussion for variable B8, parwatii 4.2.8.
4.3.7 Variable C7 - Suparession Pool Water Level Refer to vanable A4, paragraph 4.1.4.
4.3.8 Variable C8 - Drywell Pressure i
Refer to variable A5, paragraph 4.1.5.
Page 14
4.0 PIAVf-SPECIFIC POSITION CN EAG VARIABLE (Cont'd) 4.3 Brunswick's Position on 101.97 Type C Variables 4.3.9 Variable C9 - RCS Pressure (0 to 1500 osig)
Refer to variable A1, paragraph 4.1.1.
4.3.10 Variable C10 - Primary Contairznent Pressure Refer to variable AS, paragraph 4.1.5 and variable A7, paragraph 4.1.7.
4.3.11 variable Cll - Contalment & Drywell Hydrogen Concen-tration Refer to variable A8, pa::agraph 4.1.8.
4.3.12 Variable C12 - ContairInent & Drywell Oxygen Concentration Refer to variable A8, paragraph 4.1.8.
4.3.13 Variable Cl3 - Contaiment Effluent Radioactivity -
Noble Gases Refer to variables E4 and E5, paragraph 4.5.4 and 4.5.5.
4.3.14 Variable C14 - Radiaticn Exposure Rate Not required at this time per Supplanent 1 to NUREG-0737.
Page 15
M 4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.3 Brunswick's Position on RG 1.97 Tvoe C Variablas 4.3.15 Variable C15 - Ef fluent Radioactivity a -Noble Gases Refer to variables E4 and E5, paragraph 4.5.4.
4.4 Brunswick's Position on RG 1.97 Tvpe D Variabics Type D variables as stated in the RG are, "those variables that provide information to indicate the operation of individual safety systems and other systems important to safety.
These variables are to help the operator make appropriate decisions in using the individual systems important to safety in mitigating the consequences of an accident." Key variables that are type D are defined as "those variables that most directly indicate the operation of a safety system." These variables are discussed in the following paragraphs and where the variable has been covered und'er another variable type, it is indicated.
4.4.1 Variable D1 - Main Feedwater Flow Brunswick is in agreement with RG 1.97 concerning this variable.
At the Brunswick plant there is a minor range deficiency on the high end of 0.212%.
This is a negligible value.
The "110% of design value" stated in the RG is considered a guideline.
Brunswick will use the current value of 12,000,000 #/hr, for high end monitoring.
4.4.2 Variable D2 - Condensate Storage Tank Level Brunswick concurs with RG 1.97.
Page 16
4.0 PLANT-SPECIFIC POSITICN CN EACH VARIABLE (Cont'd) 4.4 Brunswick's Position on PG 1.97 Tvoe D Variables (Cont'd) 4.4.3 variable D3 - Su p sion Spray Flow Brunswick does not concur with BG 1.97 cn this variable. For the Brunswick design BHR flow can be used to monitor the operation of primary con-taiment related systems. ' Also, the followmg parameters give indication *that the safety system is a m lishing its task:
Drywell Pressure - A5, B7, C8, D4, B9, C10 Drywell Temperature - A6, D7 Suppression Pool Pressure - A7 Suppression Pool Tacw=mture - A3, D6.
IER flow and the above 1ist of variables provide Magm.e information to nonitor operaticn of primary contalisnent related systems.
4.4.4 Variable D4'- Drvwell Pressure Brunswick concurs with TG 1.97 on this variable.
4.4.5 variable D3 - hooressicn Pool Water Level Refer to variable A4, paragraph 4.1.4.
l' 4.4.6 Variable D6 - Sucaression Pool Water Te"cerature Re.fer to variable A3, paragraph 4.1.3.
4 Page 17
4.0 PIRFT-SPECIFIC POSITICN CN EAG VARIABLE (Cont'd) 4.4 Brunswick's Positics on BG 1.97 Type D Variables (Cont'd) 4.4.7 Variable D7 - Drwell Atmosphere Temperature amfer to variable A6, paragraph 4.1.6.
4.4.8 variable D8 - Drywell Spray Flow Brunswick's position on thlm variable is the same as that discussed under D3, paragraph 4.4.3.
4.4.9 Variables D9 - PEIV Leakage Control Systen Pressure These systens are not included in the Brunswick plant design. Brunswick does not intend to add these systems.
4.4.10 Variable D10 - Primary Systen Safety Relief Valve Positions Incimi%g ADS or Flow Through or Pressure in Valve Lines Brunswick is in agreenent with BG 1.97 on this variable, and provides instrmentation for this variable.
Dll - Isolation Cordera Systen Shell-Side Water Invel D12 - Isolation Condenser System Valve Position These systens are not included in the Brunswick plant design. Brunswick does not intend to add these systans, 4.4.11 variable D13 - PCIC Flow Brunswick agrees with the intent of BG 1.97 concerning this variable. Current design has indication as part of the flow wuaclier and therefore indication is not isolated frcm the control loop. Brunswick does not plan to provide isolation bot n i indication and cwiLol. If controller and/or flow indicator fail, PCIC performance can be mcnitored by monitoring the response of the reactor water level.
Page 18
4.0 PIRT!-SPECIFIC PCSITIm CN EACH VARIABLE (Cont'd) 4.4 Brunswick's Position on M 1.97 Type D Variables (Cont'd) 4.4.12 Variables - D14 - HPCI ? low D15 - Core Spray Syste Flow D16 - LPCI Systm Flow The HPCI and CS syst es each have one branch line - -
the test line - - downstream of the flow - measuring element. The test line is provided with a motor operated valve that is normally closed (two valves in series in the case of the HPCI). Further, the valve in the test line closes autcmatically when the mergency system is activated, thereby ensuring that indicated flow is not being diverted by the test line. Proper valve position can be verified by a direct indication of valve position.
(Although LPCI has several branch lines located downstream of each flow neasuring element, each of those lines is normally closed.) For all of these systes, there are valid primary inM m tors other than flow measurement to verify the performance of the mergency systs; for example, vessel water level.
The existing flomarxuii. schemes for the HPCI, CS and LPCI are all adequate in that they meet the intent of M 1.97.
4.4.13 variable D17 - SICS Flow
'Ihe SIC syste is -manually initiated. Flow measuring l
devices were not provided for this systs. The pmp dis-charge header pressure, which is indicated in the control rocm, will indicate SIC pump operation. Besides the dis-charge header pressure obseriation, the operator can verify the proper functicntng of the SICS by nonitoring the following:
Page 19 l
4.0 PIRTf-SPECIFIC POSITICN CN EACH VARIABLE (Cont'd) 4.4 Brunswick's Position on IC 1.97 Type D Variables (Cont'd) 4.4.13 Variable D17 - SICS Flow (Cont'd) 1.
Decrease in the level of the boric acid storage tank.
2.
Reactivity change in the reactor as measured by neutron flux.
3.
Squib valve cxmtinuity indicating lights.
The use of these indications is believed to be a valid alternative to SICS flow indication.
4.4.14 Variable D18 - SICS Storage Tank Level Brunswick is in ap a. eat with the regulatory guide range of bottcra to top level monitoring. At the Brunswick Plant, this level is given in pete.
Br;unswick is in disagreement with the category 2 desig-nation for this varir.ble. The curreu. Jaeign b ain for the SICS assumes a need for an alternative met!xx1 of reactivity control without a concurrent loss-of-coolant accident or high-energy line break.
The envirtment in which the SICS instrumentaticn must work is therefore a " mild" envirorment for qualification purposes.
Page 20
j 4.0 PLANT-SPECIFIC IOSITION ON FJOI VARIABLE (Cont'd) 1 4.4 Brunswick's Position on PG 1.97 Type D Variables (Cont'd) 4.4.14 Variable D18 - SICS Storage Tank Invel (Cont'd)
The current design basis for the SIIS recognizes the systen has an importance to safety less than the ine-portance to safety of the reactor protection systen and agrees with the graded approach to quality assurance specified in M 1.97.
It is unna,a=== q to apply a full quality assurance program to this instrumentation. Brunswick will classify this variable category 3.
A category 3 requirement is consistent with the 79-01B stand on the SIIS, diich is that the systen is non-safety related and does not require envi m. M.a1 qualification.
i 4.4.15 variable D19 - BHR Systen Flow Brunswick concurs with BG 1.97 on this variable.
4.4.16 Variable D20 - NHR Heat Exchanger Outlet Tertperature Brunswick concurs with BG 1.97 cut this variable.
4.4.17 Variable D21 - Cooling mter Temperature to ESF l
Cuurawsnts S e engineered safety feature u u g ents in the Bruns-wick design include the BHR heat exchangers, core spray pep race fan cooling units, the BHR pmp rom coolers and the BHR pump seal cx3oling exchangers. The service water system provides cooling water to these ccagx>nents..
Brunswick interprets this variable as meaning main systen tam =mture. In the Brunswick design, there are two main service water lines, the nuclear and conventional Naiar lines. Since there are no heat sources between Page 21
4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) i 4.4 Brunswick's Position on RG 1.97 Type D Variables (Cont'd) 4.4.17 Variable D21 - Cooling Water Temperature to ESF Components (Cont'd) these lines and the ESF components there will be no significant temperature change in cooling water temperature.
Brunswick will comply with the 0
RG 1.97 range recommendation of 32 to 200CF, and will implement instrumentation for these lines.
4.4.18 Variable D22 - Cooling Water Flow to ESF System Components Brunswick concurs with RG 1.97 on this variable and will provide flow measurement and indication of main i
service water flow in the conventional and nuclear service water headers.
4.4.19 Variable D23 - Righ Radioactivity Liquid Tank Level Brunswick concurs with RG 1.97 on this variable.
4.4.20 variable D24 - Emergency Ventilation Damper Position 1
Brunswick concurs with RG 1.97 on this variable.
Brunswick interprets this variable to be dampers which could release radiation to the surrounding plant environment or expose control room personnel to radiation.
Page 22
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l 4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.4 Brunswick's Position on BG 1.97 "M:e D Variables (Cont'd) 4.4.21 Variable D25 - Status of Standbv Power & Other Energy Sources Important to Safety (Electric, Hydraulic, Pneranatic)
At Brunswick the standby AC power supply and distribu-ticm system for the two units consists of four diesel generators and four 4.16 kv Class IE buses.
The 4 kv energency Ma*= are El, E2, E3 and E4.
'Ihe voltage is stepped down to the 480V emergency buses ES, E6, E7, and E8. The 480V emergency bus feeds the 120V AC emergency bus.
The DC standby power is supplied by batteries.
The instrument air pressure is supplied by the standby air compressors.
Diesel generator terminal voltage, feeder breaker indication, and feeder breaker trip annunciation are provided in the control rom and provide ade-quate information on bus voltage. Also, g ec=ss cmpater points E039, E040, E041 and E042 give El, E2, E3, and E4 feeder bus voltage Isog,. tively.
Feeder breaker trip annunciation is available in the control rom for both the 480V and *h 120V AC emer-gency buses. Feeder breaker indicaticm and feeder aqd=arit malfunction annunciation are available for the 480V emergency bus.
Brutureick believes that its treatment of this variable is adequate in that it provides information which is consistent with the definition of *h Type D variable.
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4.0 PLANT-SPECIFIC POSITION N EAG VARIABLE (Cont'd) 4 4.1 Brunswick's Position on M 1.97 Type D Variables (Cont'd) 4.4.22 Plant Designer Selected Variables In accordance with m 1.97's statment, "The plant designer should select variables and infor-mation display channels required by his design to enable the control rom personnel to ascertain the operating status of each individual safety systs and other syste s important to safety to the extent &ry to detamine if each syste is i
operating or can be placed in operation...", Bruna-wick has selected four additional type D, category 3 variables to mcmitor. The basis for choosing these variables is the capability of using the main condenser as a heat sink for main steam frm the reactor. This involves bypassing the main turbine provided the hotwell level is low enough to acco-modate additional condensate, and that there is i
sufficient vacum for operation. Verification of the neber of c.or'=aate pumps running is also re -.= Ned.
'Ihe four variables are:
D26 - Turbine Bypass Valve Position D27 - Cor'= -r Hotwell Level l
D28 - Condenser Vacum t
l D29 - Condensate Pump & Booster Pump Status 1
l l
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I
4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.5 Brunswick's Position on RG 1.97 Type E Variables The RG 1.97 definition for type E variables is: "those variables to be monitored as required for use in determining the magnitude of the release of radioactive materials and for continually assessing such releases." Key variables that are type E are defined as variables that most directly indicate the release of radioactive material.
Each variable is discussed in the following paragraphs and Brunswick's position on the variable is given. Where a variable has already been discussed under another type, it is indicated.
4.5.1 Variable E1 - Primary Containment Area Radiation -
High Range Brunswick concurs with the RG 1.97 recommendation on this variable and the requirements of NUREG 0737 (Table II.F.1-3). Brunswick is currently installing equipment to measure this variable.
Refer to TMI plant modifications80-030 and 80-031.
4.5.2 Variable E2 - Reactor Building or Secondary Contain-ment Area Radiation See Variable C14, paragraph 4.3.14.
4.5.3 variable E3 - Radiation Exposure Rate The stated purpose for this variable is to monitor buildings or areas where access is required to service safety equipment.
The Brunswick plant is not designed for servicing equipment in the reactor building during or after an accident.
Redundancy of system design mitigates the requirement for servicing a safety system after an accident.
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4.0 PIAVf-SPECTFIC POSITION CN EACH VARIABLE (Cont'd) 4.5 Brunswick's Position on PG 1.97 Type E Variables 4.5.4 variables E4 - Noble Gases and Vent Flow Rate E5 - Particulates and Halocens In the Brunswick design there are five identifiable release points: the stack, two turbine building vents, and two reactor bi41 ding vents. The instnanentation on the reactor building vents is not required because the reactor biilding isolates upon the receipt of a high radiation signal to the mcnitoring instrtunentation.
CP&L has NRC approval for this position provided in a letter frm the NRC dated May 5,1982, concerning NOREG-0737 Action Iterns II.F.1.1 (Noble Gas Monitor) and II.F.1.2 (Iodine / Particulate Sampling).
Under variable E4 in RG 1.97, there are six sub-headings.
For convenience and clarity of discussion, the six are listed below and their applicability to Brunswick stmmarized:
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4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.5 Brunswick's Position on RG 1.97 Type E Variables 4.5.4 Variables E4 - Noble Cases and Vent Flow Rate ES - Particulates and Halogens (Cont'd)
RG 1.97 Brunswick
- 1. Drywell Purge, SGTS Stack
- 2. Secondary Containment Purge Reactor Building
- 3. Secondary Containment (RX Shield Bldg. Annulus)
N/A
- 4. Auxiliary Building N/A
- 5. Common Plant Vent Stack
- 6. All other Release Points Turbina Vents Instrumentation for the stack and turbine building vents will be provided through 1MI plant modifica-tions80-034, 35 and 36.
These plant modifications meet the requirements of NUREG-0737 and applicable standards and regulatory guides including RG 1.97.
4.5.5 Variable E6 - Radiation Exposure Meters On hold due to lack of requirements from NRC.
Refer to NRC ERRATA dated July 1981.
4.5.6 Variable E7 - Airborne Radiohalogens and Particulates (Portable Sampling with On-Site Analysis Capability)
Brunswick concurs with RG 1.97.
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4.0 PLANT-SPECIFIC POSITION ON EACH VARIABLE (Cont'd) 4.5 Brunswick's Position on RC 1.97 Type E Variables J
4.5.7 Variable E8 - Plant & Environs Radiation (Portable Instrumentation)
Brunswick concurs with RG 1.97.
4.5.8 Variable E9 - Plant & Environs Radioactivity (Portable Instrumentation)
Brunswick concurs with RG 1.97.
4.5.9 Variables E10 - Wind Direction Ell - Wind Speed E12 - Estimation of Atmosphere Stability Brunswick will install new equipment which will meet the recommendations of RG 1.97.
4.5.10 Variable E13 - Primary Coolant & Sump Accident Sampling of primary coolant will be done at two points in the jet pump pressure instrument system and from a single sample line connected to both loops in the RHR system.
Refer to Plant Modification 80-28 and 80-29.
Sampling of t'ae containment sumps is not necessary at the Brunswick plant because accident conditions will close isolation valves G16-F003, F004, F019 and F020, which prevents release of radioactive materials from primary containment.
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4.0 PLW"-SPECIFIED POSITICN CN EAG VARIABLE (Ccat'd) 4.5 Brunswick's Position on IC 1.97 Type E Variables 4.5.11 variable E14 - Contairrient Air Containment air===1ing will be taken frca the drywell and suppression pool atmosphere. Refer to Plant Modification 80-028 and 80-029.
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-3y
_-.,~-,.,,,----,,#.
_ _, -,. ~ -
5.0 ABBREVI ATI ONS ADS Automatic Depressurization System BWR Boiling Water Reactor BWROG -
Bolling Water Reactor Owners Group CAD Containment Atmospheric Dilution CS Core Spray ECCS -
Emergency Core Cooling System ESF Engineered Safety Features FS A A -
Final Safety Analysis Report HPCI -
High Pressure Coolant inj ection LPCI -
Low Pressure Coolant i nj ection NA Not Applicable QA Quality Assurance RCS Reactivity Control System RC I C -
Reactor Core Isolation Cooling Regulatory Guide RG RHR Residual Heat Removal RPV Reactor Pressure Vessel RWCU -
Reactor Water Clean Up RX Reactor R/h r -
Standby Gas Treatment System SLCS -
Standby Liquid Control System SRV Sa fety Rel ie f Valve TMI Three Mile Islar.d Page 30
6.0 REFERENCES
1.
ANS 4.5 2.
Brunswick FSAR 3.
Brunswick System Descriptions 4.
BWROG Emergency Procedure Guidelines, Rev. 3 (Prepublication Draft) 5.
BWROG Position Paper on RG 1.97, Rev. 2 6.
NUREG-0578 8.
NUREG-0737 and Supplement 1 9.
Plant Modifications:
77-268, Pressure Switch Analog Replacement U1 77-269, Pressure Switch Analog Replacement U2 77-303, CST & MVD Level Indicator Addition & Range Change 80-137, TSC Computer Input Points U1 80-138, TSC Computer Input Points U2 80-180, Nuclear Boiler Instrumentation U1 80-181, Nuclear Boiler Instrumentation U2 81-251, Suppression Pool Instrumentation U1 81-252, Suppression Pool Instrumentation U2 82-049, Drywell RTD Replacement 10.
RG 1.97, Rev. 2, Rev. 3 11.
TMI Action Item Plant Modifications:
80-025, Drywell Pressure Instrumentation U1 80-026, Drywell Pressure Instrumentation U2 80-028 Improved Post Accident Sampling U1 80-029, Improved Post Accident Sampling U2 80-030, Containment Rad Monitoring Ul
.80-031, Containment Rad Monitoring U2 80-032, Containmert H2 Monitoring U1 80-033, Containment H2 Monitoring U2 80-034, TB Vent High Range Rad Monitor U1 80-035, TB Vent High Range Rad Monitor U2 80-036, Stack Radiation Monitors80-078, Wide Range Torus Level U1 80-079, Wide Range Torus Level U2 12.
10CFR50 Appendix A and General Design Criteria 13, 19, and 64.
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