ML20092P320

Forwards Reg Guide 1.97, 'Instrumentation for Light-Water- Cooled Nuclear Power Plants to Assess Plant & Environs Conditions During & Following Accident,' Compliance Rept Per Suppl 1 to NUREG-0737

ML20092P320
Person / Time
Site:	Farley
Issue date:	06/29/1984
From:	Mcdonald R ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20092P321	List: ML20092P320 ML20092P323
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-51088, TAC-51089, NUDOCS 8407060166
Download: ML20092P320 (1)

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Alabama Power Company 600 North 18th Street l Post Office Box 264$ )

Telephone 205 783-6090 R. P. Mcdonald Senior Vice President-rW Alabama Power June 29, 1984 Docket No. 50-348 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D.C. 20555-Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Unit 1 Regulatory Guide 1.97 Compliance Gentlemen:

In letters dated September 22 and December 15, 1984, Alabama Power Company comitted to describe the compliance of Farley Nuclear Plant - Unit 1 with Regulatory Guide 1.97 (R.G.1.97) Compliance Report in June 1984.

Attachmer.ts 1 and 2 of this letter and the enclosed Unit 1 R.G.1.97 Compliance Report satisfy this comitment.

This commitment was made to satisfy the provisions of Supplement 1 to NUREG-0737 which address the Technical Support Center (TSC), the Emergency Operations Facility (E0F) and Control Room. The compliance of the Farley Nuclear Plant TSC and E0F to NUREG-0737, Supplement 1 is presented in Attachment 1. It is the opinion of Alabama Power Company that the E0F and TSC presently satisfy Supplement 1 to NUREG-0737 and that the Unit 1 Control Room will satisfy the provisions of R.G.1.97 upon the implementation of the modifications as described herein.

The enclosed Unit 1 R.G.1.97 Compliance Report presents the compliance of the Farley Nuclear Plant 'Jnit 1 Control Room with R.G.1.97. For each R.G.1.97 variable, a Compliance Review Checklist, which sumarizes the variable's compliance with the R.G.1.97 provisions, is provided.

Compliance , Ith a R.G.1.97 provistor is indicated on the checklist by "Yes" and deviations by "No". The basis for compliance to R.G. 1.97 and the interpretation of the R.G.1.97 provisions are presented in the R.G.1.97 Design and Qualification Review Criteria which is included in the R.G.1.97 Compliance Report. The format of the R.G.1.97 Compliance Report and the infomation requested by Supplement 1 to NUREG-0737 are discussed in the Introduction and User's Guide, which is contained in the enclosed R.G.1.97 Compliance Report.

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l_ Mr. S. A. Varga June 29, 1984 l U. S. Nuclear Regulatory Commission Page 2 l

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-The R.G.1.97 Compliance Report presents justifications and/or modifications that are provided as resolution for each deviation. The schedules for implementation of these modifications are presented in Attachment 2.

It should be noted that the provisions of NUREG-0737, Supplement 1, including the R.G.1.97 provisions, are to enhance the present emergency response capabilities and are not to provide the sole safety function. The present emergency response capability for accident monitoring (R.G.1.97) is currently provided by the Farley Plant computer and the main control board.

Based on the review performed to prepare the R.G.1.97 Compliance Report, Alabama Power Company believes that the present instrumentation provides an adequate emergency response capability during the implementation of n.odifications to satisfy R.G.1.97.

If there are any questions, please advise.

Yours very truly, R. P. Mcdonald RPM / JAR:ddb-D9 Attachments Enclosure cc: Mr. L. B. Long Mr. J. P. O' Reilly Mr. E. A. Reeves Mr. W. H. Bradford Dr. I. L. Myers i

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Attachment 1 Compliance of the Farley Nuclear Plant TSC and EOF with Supplement 1 to NUREG-0737 I. Technical Support Center (TSC)

A. NUREG-0737, Supplement 1 Provisions The Type A, B, C, D and E variables that are essential f~

performance of TSC functions shall be available in the TSC.

(1) BWR incore thermocouples and continuous offsite dose monitors are not required pending their further development and consideration as requirements.

(ii) The indicators and associated circuitry shall be of reliable design but need not meet Class 1E, single-failure or seismic

_ qualification requirements.

B. TSC Compliance Farley Nuclear P1 ant is a Westinghouse pressurized water reactor (PWR). NUREG-0737, Supplement 1 provision Item (1) above does not apply to Farley Nuclear Plant.

Alabama Power Company's philosophy of data monitoring is that a person would be located at the main control room computer console and would communicate with the TSC via sound-power phones. TSC personnel would request display of the desired data in the TSC.

Upon activation of the TSC, one of the two CRTs normally located in the main control room (one per unit) would be moved to the TSC for use by support personnel. A two-pen recorder located in the TSC has the capability to trend two parameters. Parameters can be trended on the line printers or recorders providing a hard copy of data for review. The system will address monitoring and display equipment between TSC and main control room. In addition, main control board displays can be read on the closed circuit TV system. The TSC is pr_ovided with all information essential for the performance of its designed functions. This inforr:ation includes the appropriate R.G.1.97 variables. The TSC also has the capability to monitor and display data regarding wind speed, wind direction and atmospheric stability. Reliable voice communication is available between the TSC and the National Weather Service. As an addition to the existing TSC indications, provisions have been made to incorporate the SPDS display into the TSC. This information will further enhance the TSC personnel capability for providing emergency response.

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Attachment 1 Page 2 II. Emergency Operations Facility (E0F)

A. NUREG-0737, Supplement 1 Provisions (i) Those primary indicators needed to monitor containment conditions and releases of radioactivity from the plant shall be available in the E0F.

(ii) The E0F data indications and associated circuitry shall be of reliable design but need not meet Class 1E, single-failure or seismic qualification requirements.

B. Emergency Operating Facility (EOF) Compliance Information regarding reactor coolant system, containment conditions, meteorological data, emergency core cooling and projected radiation dose rates would be transmitted via telephone from the TSC to the E0F and recorded on the post-accident status boards. The E0F is provided with all information essential for the performance of its designed functions. This information includes the appropriate R.G.1.97 variables. The EOF also has the ccpability to monitor and display data regarding wind speed, wind direction and atmospheric stability. Reliable voice communications is available between the TSC and the National Weather Service.

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' Attachment 2 Schedules to Complete R.G.1.97 Modifications NUREG-0737, Supplement i requires a schedule to be submitted with the R.G.1.97 Compliance Report for any modifications for resolution of any deviations. These modifications are presented in the R.G.1.97 Compliance Report. For scheduling purposes, the modifications may be categorized as follows:

f I. Main Control Board Modifications II. 10CFR50.49 Modifications

, III. All Other R.G.1.97 Modifications The schedule to complete these three categories of modifications will be consistent with previous APCo schedule commitments regarding R.G.1.97 and Control Room Design Review (CRDR). These schedules are discusied below:

I. MCB Modifications Scope: MCB modifications which include the addition of display devices for new instruments, replacement of existing display devices and the installation of supports and/or restraints of certain MCB display devices.

Completion Schedule: Unit i eight refueling outage (March 1988)

Basis: Schedule for completion of CRDR modifications (Reference APCo letter dated December 15, 1983)

Discussion: Certain MCB modifications, including the relocation of MCB display devices, nuy be performed to resolve human engineering discrepancies resulting from the CRDR. The MCB modifications resulting from R.G.1.97 and CRDR will be integrated to avoid overlapping and costly modifications. The CRDR modifications are committed to be completed by the end of the Unit 1 eight ref1eling outage (March 1988). The MCB modifications associated with R.G.1.97 will be implemented in accordance with the schedule for CRDR modifications.

II. 10CFR50.49 Modifications Scope: Environmental qualification of Category 1 and 2 instruments whose only deviation from R.G.1.97 is environmental qualification.

Completion Schedule: Unit 1 sixth refueling outage ( April 1985)

Basis: NRC granted extension to J JCFR50.49 for Unit 1 in letter dated April 16,1984

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Attachment 2 Page 2

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' Discussion: In letter dated February 22, 1984 APCo requested an extension to the schedule provided in 10CFR50.49 for upgrading the environmental qualification of R.G.1.97 equipment for Units 1 and 2. The NRC granted this extension request in letter dated April 16, 1984. The scope of the R.G. 1.97 equipment addressed by the 10CFR50.49 schedule was redefined based on additional clarifying criteria for Unit 1 in letter dated February 22, 1983. The clarifying criteria provides for the qualification of Category 1 and 2 equipment within the 10CFR50.49 schedule whose only deviation to R.G.1.97 is environmental qualification. The scope of Unit 1 R.G.

1.97 equipment addressed by the 10CFR50.49 schedule is as follows:

a) Containment spray flow transmitter (FT958 A,B) b) Charging line flow transmitter (FT122) c) Letdown flow transmitter (FT150)

-d) Volume control tank level transmitter (LT115) e) Reactor coolant pump seal injection flow transmitter (FT124, FT127 and 130) and local indications (FI1248, 127B and 130B) f) Containment high range radiaton monitor _ cable outside containment (2VA15011F, H and IVBIS009F,H)

III. Other R.G.1.97 Modifications Scope: These modifications,. other than those in the above categories, include replacing sensors, re-routing cables, changing power supplies, providing diesel power, etc.

Completion Schedule: Unit 1 eight refueling outage (March 1988)

Basis: Schedule for completion of R.G.1.97 modifications (Reference

' APCo letter dated December 15,1983) ,

Discussion: APCo connitted to complete the R.G.1.97 modifications by the end of the Unit-1 eight refueling outage (March 1988) in letter dated Decenber 15, 1983. The R.G. 1.97 i modifications'have been included in an integrated '

implementation schedule of all other NRC connitments and other design modifications and maintenance activities.

This integrated schedule includes implementation of  !

commitments related to IE Bulletins, Generic Letters, 10CFR50 provisions such as environmental qualification and Appendix R, as well as other NUREG-0737, Supplement 1 activities. Implementation of the licensing items'must  ;

be coordinated with ongoing plant activities including i refueling outages and other design modifications and-maintenance activities. Typical refueling outages at

Attachment 2 Page-3 Farley Nuclear Plant are six weeks in duration with the installation of all modifications on a pre-planned and packaged basis. A modification is pre-planned and packaged when all design reviews are completed, manpower requirements assessed, detailed work sequences identified, acceptance testing planned, field procurement identified and all material received onsite prior to the outage. It is the philosophy of Alabama Power Company that only refueling-related work will be performed on the outage critical path unless a safety issue is involved.

The R.G.1.97 modifications are to enhance the present emergency response capabilities and are not to provide the sole safety function. Consequently, the safe operation of Farley Nuclear Plant - Unit I will not be jeopardized during the interval required to implement the R.G.1.97 modifications.

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