ML20101K255
| ML20101K255 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 03/29/1996 |
| From: | Duffy J VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 BVY-96-33, NUDOCS 9604020310 | |
| Download: ML20101K255 (36) | |
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VERMONT YANKEE NUCLEAR POWER CORPORATION 3 Ferry Road, Brattleboro, VT 05301-7002 ENGINE IN OFFICE 580 MAIN STREET BOLTON, MA 01740 (508) 7794 711 March 29,1996 i BVY 96-33 l
l United States Nuclear Regulatory Commission ATTN: Document Control Desk l Washington,DC 20555 1
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) Letter, VYNPC to USNRC, BVY 89-80, dated September 1,1989 (c) Letter, VYNPC to USNRC, BVY 95-117, dated October 26,1995 l l
Attachments: Summary of Changes A. Regulatory Guide 1.97 Qualification Summary B. Regulatory Guide 1.97 Matrix C. Regulatory Guide 1.97 Design and Qualification Criteria for Instrumentation (Summary) i
Subject:
NUREG-0737, Supplement No.1 - Regulatory Guide 1.97 Program Update !
I In Reference (c) Vermont Yankee committed to perform a comprehensive review ofits current RG 1.97 program doedment [ Reference (b)]. Attached with this letter is an updated RG 1.97 program document revised to incorporate the results of that review. l We trust that the information provided is acceptable; however, should you have any questions, please contact this office.
Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION 1
/N$ L l 020C20 James >. Duffy ,
Licensing Engineer j
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- USNRC Region 1 Administrator i USNRC Resident Inspector- VYNPS USNRC Project Manager - VYNPS 00 I}
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9604020310 960329 PDR ADOCK 05000271 P PDR
. . Summary of Changes to the Vermont Yankee September 1989 RG 1.97 Submittal March 1996 Attachments Type of Change 50.59 Required item # AfTected Description of Change (Admin / Tech) (Impacts SER (NVY 90-215))
N/A A Moved some of the parameter interpretation to Administrative No Information relocated and Attachment 'C', Added some additional clarification, clarification provided for clarity.
N/A B RG 1.97 Attachment 'B' category column. Originally Administrative No Information added for only reflected RG 1.97 required category Revised to clarity include Vermont Yankee enmmitted category as stated in attachment 'A*.
N/A C Attachment 'C' added to provide clarification on how Administrative No - Information added for parameter requirements have been satislied. clarity.
AI, A2, B Recorder ID revised from LR/PR 2-347 & 68 to Administrative No The same recorders as C4,C9 LR/PR 2-348A&B originally committed to still being used.
BI A, B Neutron Flux deleted. Technical No SER (NVY 93-036 & NVY 94-28) concurred with the removal of neutron flux.
B10 A Added FCV 2 39 & 40 as requiring upgrade to satisfy Technical No - Valves to be upgraded to RG 1.97 PCIS valve position indication requirements. comply with SER. BMO addresses operability concerns.
BIO A, B Removed list of PCIS valves from Attachment 'A' and Administrative No - List of valves moved to a included them as part of Attachment B. Reference to more appropriate location; added l
"long term" & "short term" operability requirements redundancy class for j removed (not a RG l .97 issue). clarification. j B10 A,B Removed MOV 10-33 from list. Administrative No This valve was removed .
from service via PDCR 91-11. l As such,it no longer is required to provide PCIS valve position indication and therfore RO l.97 item B10 requirements no longer 3PPl y.
Cl A,B The description provided in Attachment 'B' relates to Technical No - The Category change from an instrument system which will not be effective after i to 3 reflects the functional the MSIVs are shut. It will not be relied on after that. description originally provided Therefore, a Category I status does not apply. Instead, in Attachment 'B'. The intended the description provided in Attschment 'B' more use and post-accident function I closely resembles a Category 3 requirement. has not changed D20,D21 B Regised recorder identification number: Administrative No - Corrective update to From TRS10-130 To TRS23-115 reficct actual recorder used.
Referenced recorder satisfies Category 3 requirements.
D21 B Revise temperature range of cooling water to ESF Technical No Revised range addresses components from O' F - 150
- F to O' F - 600
- F. outstanding SER comment.
Revised range addressed in NRC letter DVY 91/09 dated 1 17-91 and validated during RG 1.97 audit #50-271/91-08 dated 4 91.
D25 B Revise emergency power indicator ID numbers as Administrative / No - Although different follows: Technical indicators will be used, the RG From El-386F (CRP 9-8) To El-386D (CRP 9-8) 1.97 parameters will continue to From El-52 (CRP 9-8) To DC-I-VM (Local /Cbl Vit) be monitored to the same From El-53 (CRP 9-8) To DC-2-VM (Local / Chi Vit) requirements assumed in the SER. This variable is " Plant Specific" i
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, . Summary of Changes to the Vermont Yankee September 1989 RG 1.97 Submittal March 1996 Attachments Type of Change 50.59 Required Item # Affected Description of Change (Adminfrech) (Impacts SER(NVY 90-215))
D25 B Revisc emergency power indicator range as follows: Administrative No - Although different ranges will be used, the RG 1.97 D250,11, & I: From 150 to O to 150 To O to 150 parameters will continue to be D25L : Removed reference to 0 to 300 Vac and monitored to the same added note D20. requirements assumed in the SER. This variable is Plant Specific" E8 A,B Assigned the existing RG 1.97 catego y 2 to RD 17 Technied Yes SER based on both low 155. Assigned separate RG 1.97 category 3 for Stack range and high range being RG Gas 1 & !!. Parameter requirements revised to address 1.97 cat. gory 2.
Category 3 requirements in lieu of Category 2 for the low range plant stack radiation effluent monitoring function. (liigh range remains Category 2).
E8 B Note E7 Correct equivalent range; Administrative No - Range provided in notes From 2E-5 to IE-2uCi/cc To IE-7 to IE-l uCi/cc inadvertently u.ed. Bases for and revised range provided in VYI From 10E-4 to 10E+4 uCi/cc to IE-2 to IE+5 uCi/cc 33/90 and earlier RG 1.97 submittals. This range supports Changed installed low range span; position taken in Attachment B From 10 to 10E+6 CPM To 10 to 10E+7 CPM and envelopes the range required by RG 1.97.
Notes B Described sump level control requirements. Administrative No Information provided for Bil,CIO clarification. Reflects Attachment 'A' and SER description.
D15,D17 B Parameter requirements revised to address Category Administrative No Attachment 'A' details the D18,D22 3 requirements in lieu of Category 2. requirements for the different RG E2 1.97 Categories. The subject items were determined to be Category 3 monitoring functions in Attachment 'A'. The SER recognized these parameters as Category 3. RG 1.97 originally required these monitoring functions to be Category 2.
Attachment 'B' inadvertently listed the requirements associated with Category 2 instead of Category 3.
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1 ATTACHMENT A Reculatory Guide 1.97 1
1 Oualification Summarv I i
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l Attachment A Qualification Summary March 1996 He following is a list of Post-Accident Monitoring (Regulatory Guide 1.97) instrumentation. It is divided into four sections as follows:
o Section I lists the instrumentation which is in full compliance with the requirements as specified by Regulatory Guide 1.97 and as interpreted in Attachment C.
o Section 2 details equipment which has been evaluated on a plant-specific basis to provide the information required to support safe shutdown. This equipment may differ in range, environmental qualification, or other attributes frorn the guidance in Regulatory Guide 1.97. However, the analysis performed ensures that this equipment supports the required safety functions specified in the Vermont Yankee Environmental Qualification Program and conforms to the new Symptom-Based Emergency Operating Procedures.
o Section 3 details additional instrumentation needed. This additional instrumentation could consist of entirely new instrument channels or existing instrument channels which require some upgrading. All equipment being installed will be qualified in accordance with the appropriate Vermont Yankee specific Design and Qualification Criteria category. No items were listed at the time of the last NRC submittal. Since that time, one item has been added.
o Section 4 details the instrumentation which has been deleted from the Regulatory Guide 1.97, List of instrumentation. Vermont Yankee originally considered this equipment within the scope of Regulatory Guide 1.97. However, following further development of operating procedures and the Vermont Yankee Equipment Qualification Program, some equipment was no longer required to be operational. Consequently it has been removed from the Regulatory Guide 1.97 Instrumentation Matrix (Attachment B). Two items have been added to this Section since the last NRC submittal.
Environmental Qualification requirements are determined in the Vermont Yankee EQ Program. In determining environmental qualification requirements, all design basis events, as documented in Chapter 14 of the Vermont Yankee Final Safety Analysis Report (FSAR), have been addressed. Also addressed are High Energy Line Breaks (HELBs) outside containment and flooding. This is consistent with the intent of 10CFR50.49.
He method for identifying electrical equipment within the scope of Paragraphs (b)(1) and (b)(2) of 10CFR50.49 (i.e.,
safety-related, as well as non-safety-related electrical equipment relied upon to remain functional or whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions during and following design-basis accidents) is described and documented in the Vermont Yankee EQ Program. This included:
(a) Identification of general design criteria consistent with Vermont Yankee's plant-specific design and 10CFR50.49; (b) Defining required safe shutdown safety functions for design-basis accidents utilizing shutdown sequence diagrams based upon existing emergency operating procedures and the Vermont Yankee FSAR; (c) Identification of the major electrical components required for each postulated accident in potentially harsh environments which are relied upon to operate (or to not fail) for required safety functions. These components were identified by reviewing Plant Piping and Instrumentation Diagrams (P&lDs); and (d) Identification of the remaining chctrical components in potentially harsh environments (associated with the major required electrical components) that are relied upon to function, or whose failure could impact any required safety functions or mislead the operator such that required safety functions could be jeopardized.
These components were identified by reviewing plant electrict.1 Control Wiring Diagrams (CWDs). In addition, a field walkdown inspection of all major components and associated equipment was performed to ensure accuracy and completeness.
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Attachment A l Qualification Summary March 1996 l
l The method used for identifying electrical equipment within the scope of Paragraph (b)(3) of 10CFR50.49 (i.e., ;
j "certain post-accident monitoring equipment") included the review of Symptom-Based Emergency Operating Procedures to identify a complete list of associated display instrumentation. The instrumentation necessary to determine that a system is performing its safety function is included in the list of post-accident monitoring instrumentation.
A review for plant-specific Type A variables was conducted utilizing the Symptom-Based Emergency Procedures. l These procedures are living documents; as future revisions to the E0Ps modify display instrumentation requirements, ,
changes to the instrument list will be made accordingly. j i
Attachment B is the Regulatory Guide 1.97 Equipment Matrix. It is arranged in a manner which allows identification i of requirements and abilities. Where a requirement is not applicable, it is so noted with an N/A under the appropriate -l l column. An explanation of an N/A status is provided in Attachment A, Section 2. Where the regulatory guide does ]'
i not require specific documentation, N/R is inserted under the appropriate column. The basis for N/R status is l - provided by Table 1 of the Regulatory Guide. Vermont Yankee interprets the basic design and qualification
- requirements as follows:
l Category 1 Required' Required Required Required Category 2 Required' N/R Required 2 N/R l Category 3 N/R N/R N/R N/R Note 1. If located in harsh environment.
Note 2 Certain Category 2 variables are not as important as others and, based on evaluation (per the Vermont Yankee Safety Class Manual), an items safety classification (Safety Class or Non-Nuclear Safety) is determined. . An item determined to be Safety Class will ,
l' require QA; Other QA requirements (OQA) for Non-Nuclear Safety related items will i l be determined on a component specific basis (which could include no QA). ,
Under the appropriate columns, a Yes or No is indicated to reflect if the documentation or redundancy requirements l are adequately addressed. If a No is listed, justification for its acceptability is provided in Attachment A, Section 2.
Attaciunent C is the RG 1.97 Table 1 design and qualification requirements summary. A summary of how Vermont Yankee satisfies the Table 1 requirements is addressed here.
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Attachment A Qualification Summary March 1996
- 1. Instrumenentinn in Full Comotinnee With Reculatory Guide 1.97 1
The following instrumentationcurrently installed at Vermont Yanke- fully complies with Regulatory Guide J 1.97 requirements:
ltts Semce Egg j l
Al Reactor Pressure 1 A2 Reactor Vessel Level 1 A4 Drywell Pressure 1 )
A5 Drywell Temperature 1 A6 Torus Pressure 1 A7 Torus Water Temperature 1 A8 Torus Water level 1
.A9 Torus Airspace Temperature 1 i
B2 Control Rod Position 2 ,
B3 RCS Soluble Boron Concentration 2 i B6 RCS Pressure 2 i
B10 Primary Containment Isolation Valve Position Indication 2,3 C2 Primary Coolant Analysis (gamma spectrum) 2 ,
C4 RCS Pressure 2 i C5 Primary Containment Area Radiation 2 C7 Suppression Pool Wide-Range level 2 C9 RCS Pressure 2 C10 Drywell Pressure 2 Cll Containment /Drywell Hydrogen Concentration 2 i C12 Containment /Drywell Oxygen Concentration 2 I Di Main Feedwater Flow 2 I D3 Suppression Chamber Spray Flow 2 ,
D6 Suppression Pool Water Temperature 2 !
D8 Drywell Spray Flow 2 :
DIO Primary Safety Relief Valve Position - ADS 2 -
D16 LPCI Flow 2 D19 RHR System Flow 2 -
D23 Radwaste System 2 D25 Standby Power Status 2 El Primary Containment Area Radiation 2 E3 Radiation Exp9sure Rate (Safety Access Areas) 2 E10 Particulates/ Halogens 2 El1 Airborne Radio halogens 2 E13 Isotopic Analysis 2 l E14 Wind Direction 2 EIS Wind Speed 2 E17 Primary Coolant Sample (Except ph) 2 E18 Containment Air Sample 2 Page 3 of 13 J
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Attachment A Qualification Sununary March 1996 Notes
- 1. Fully satisfies the requirements for Type "A" variables as defined by Regulatory Guide 1.97. The Vermont Yankee Emergency Operating Procedures determined the need for the variable and the acceptance criteria.
- 2. Fully satisfies the requirements as defined by Regulatory Guide 1.97. This includes enveloping the stipulated range and category requirements. .
- 3. PCIS valve position indication satisfies RG 1.97 with the exception of FCV 2-39 & FCV 2-40. Refer to Section 3 of this Attachment.
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Attachment A Qualification Summary March 1996 l 2. Eauioment Determined to be Anorooriate on a Plant-Soecific Basis l This section details equipment currently existing at Vermont Yankee, how it deviates from the regulatory l guidance, and a justification for the existing equipment acceptability. This equipment is:
1[gm Service Results I l
B1 Neutron Flux This parameter has be:n remwed from the Vermont Yankee RG 1.97 submittal. Refer to Section 4 of this Attachment.
B4 Coolant level Regulatory Guide 1.97 requires a range from the bottom of the core ,
support plate to the lesser of the top of the vessel or the centerline
- of the main steam line. The top of active fuel is used as the 0" -j
! reference for level indication. Based on that, the bottom of the core support plate is at approximately -154 inches; centerline of the main i steam line is approximately +244 inches; approximately 500 inches l
to the vessel top. The monitored range is +200 inches. He lower ;
range requirement is enveloped. The increasing range is j approximately 44 inches less than the requirement. However, it is j the widest range which can reasonably be monitored. This is duc '
to the locations of the existing instrument tap locations. Should level exceed +200 inches and fill the vessel, the operator will have indication of increasing reactor pressure. The High Pressure injection Systems would have automatically shut down due to high water level long before reaching the main steam line. Based on the above discussion, and a review of the E0Ps, it is Vermont Yankee's position that the 200" range is acceptable.
B5,C3 Core Temperature in-core thermocouples do not presently exist at Vermont Yankee.
He intent of these instruments is to verify adequate water level / core ,
l cooling. Water level issues were addressed via Generic Letter 84- -[
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- 23. At that time, it was determined that in-core thermocouples were not required to ensure adequate water level / core cooling.
Furthermore, this parameter was determined to be not required at this time (SECY 82-11). Therefore, it is Vermont Yankee's position that this parameter will not be included at this time in the Regulatory Guide 1.97 submittal.
B7,B9 Drywell Narrow-C8,D4 Range Pressure Regulatory Guide 1.97 requires both drywell narrow- and wide-range pressure measurement. Drywell narrow-range pressure transmitter, IYT 16-19-28, is a single channel instrument. The wide range pressure transmitters, PT 16-19-29A/B, encompass both the narrow- and wide-range requirements. These transmitter loops meet the requirements for Category 1 variables. It is Vermont Yankee's position that narrow-range drywell pressure is not needed post-LOCA due to the fact that once the IACA has been controlled, the drywell will not repressurize. However, if that were to happen, any
, changes in pressure will be displayed in the Control Room via the
! wide-range instruments. Therefore, it is not necessary to provide
- Category 1 instrumentation for narrow-range pressure. it is
! Vermont Yankee's position that PT 16-19-29A/B instrument loops j satisfy the intent of these four post-LOCA variables.
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Attachment A Qualification Summary March 1996 B8,C6 Drywell Sump Level The drywell sump level uses level switches to start /stop pumps during normal operation. Regulatory Guide 1.97 requires continuous sump level indication from the bottom to the top. The existing configuration is designed to detect and measure leaks in the drywell by measuring both the sump pump running time and the time between pump initiation with external pump monitoring equipment. During a LOCA, drywell sump level is ineffective because the sump will fill and overflow into the torus. The torus is monitored by an environmentally qualified level measurement system. Additionally, drywell pressure is also monitored by environmentally qualified instrumentation which will indicate a line break in the drywell before the torus level indicates a rise.
Therefore, it is Vermont Yankee's position that drywell sump level indicatiori is not appropriate for Vermont Yankee. The existing system, viewed as a Category 3 parameter, is adequate.
Cl Radiation Level in Circulating Primary Coolant Radiation levels in the main steam line are continually monitored by the main steam line radiation monitors. A steam line isolation and scram are generated by these instruments if the steam radiation exceeds a preset level, indicating a failure of the fuel cladding.
Their intended function is to scram the reactor prior to the onset of harsh environmental conditions. In accordance with the methodology used in the Vermont Yankee EQ Program, these detectors, although utilized for fuel failure events, are not relied upon for LOCA or HELB events. Once the MSIVs have closed, there is no circulating primary coolant in the main steam lines.
Therefore, there is no longer a need to accurately monitor steam line radiation levels. In addition, the drywell high-range radiation monitors (which are environmentally qualified) will monitor radiation buildup within the drywell. Direct coolant radiation level assessments will be available from the chemical and health physics analysis via the Post-Accident Sampling System.
For the reasons stated above, it is Vermont Yankee's position that the existing instrumentation is acceptable and is viewed as a Category 3 parameter.
Cl3,Cl4 Noble Gases and E4,ES,E7 Vent Flow Rate E9 All anticipated post-accident plant effluents pass through the plant stack. Monitoring the common plant vent will provide indication of effluent radiation levels from these areas. The stack monitoring instruments cover the range required. Therefore, it is Vermont Yankee's position that separate monitoring of these parameters is not required. For Type E variables this is explicitly stated as acceptable.
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Attachment A Qualification Summary March 1996 D2 Condensate Storage Tank level Regulatory Guide 1.97 requires CST level indication from top to bottom. The existing range is 0 to 35'. 38*-3" is the overall height of the CST. It is Vermont Yankee's position that the existing range is adequate. This is based, in part, on the fact that the portion of the CST above 36'-9" is cone shaped. Level increases above the level do not relate to any significant additional volume.
Furthermore, by procedures, the operator will limit the level in the CST to less than 35' to ensure overflow does not occur through the tank's vent.
D5 Torus Level Variable D5 requires level be monitored from " top of vent to top of Weir Wall" The Vermont Yankee torus design does not utilize a Weir Wall. Therefore, this parameter is not applicable.
D7 Drywell Atmospheric Temperature Drywell atmospheric temperature displays 0*F to 350*F, which is less than the 40' F to 440' F range required. The accident analysis conducted to support Vermont Yankee's EQ Program indicates that the postulated drywell temperature will not exceed 350' F.
Therefore, a 0* F to 350' F range is appropriate for Vermont Yankee.
D9 MSIV Leak Control The Vermont Yankee design does not include an MSIV Leak Detection System. Therefore, this parameter is not applicable.
D11,D12 1 solation Condenser System Level & l Valve Position Variables D11 and D12 pertain to plants which utilize isolation condensers in their design. Vermont Yankee does not utilize an
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isolation condenser. Therefore, these variables are not applicable.
D13,Dl4 RCIC Flow i HPCI Flow Boih HPCI and RCIC flow indication is available to the Control Room. Regulatory Guide 1.97 requires these two variables to be environmentally qualified. Per the Vermont Yankee EQ Program, these two variables do not experience harsh environments during the l small break LOCA event in which they are relied upon. Once the vessel has been depressurize, both HPCI and RCIC become inoperative and their flow indication is not needed. Therefore, it is l Vermont Yankee's position that the existing equipment is ,
acceptable. l l
D15,D22 Core Spray Flow Cooling Water Flow to ESF System Components In the EQ Program, flow indication for these safety systems is not l l required. in lieu of various flows, the instrumentation that monitors the reactor and primary containment responses post-accident would I l
i be the ultimate indication of ECCS performance (i.e., reactor vessel level, pressure, drywell temperature, drywell pressure). In addition, ECCS valve position information, along with ECCS pump motor running current (amps) indicates the mode of operation and is far more valuable than monitoring flow. Therefore, additional qualification or ygrading is not warranted. Vermont Yankee considers these parameters Category 3.
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Attachment A Qualification Summary March 1996 D17,D18 SLCS Flow &
Storage Tank Level SLCS flow and storage tank level is required by Regulatory Guide "
1.97 to be environmentally qualified. Per the EQ Program and the Vermont Yankee FSAR (Section 3.8.4), this system provides a method to shut down the reactor from the full-power condition and maintain the reactor suberitical during cooldown, i=lepe= lent of the control rods. As such, it is not expected to be needed for plant ,
3 safety following a Design Basis Accident (DBA). Since this system ;
, is for independent backup of the control rods, it is not relied upon i for accidents in which harsh environments are created. Therefore, ;
environmental qualification of any SLC component is not warranted,
!- although specified in Regulatory Guide 1.97. These parameters are !
considered Category 3 by Vermont Yankee. !
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This parameter is adequate to inform the operator that the pump is !
i discharging fluid in a manner indicative of proper operation [
In addition, the Regulatory Guide requires the SLCS tank level be monitored from top to bottem. For Vermont Yankee, this would .i require a range of 0" to 132.5". The available range is 0" to ;
127.5". By procedures, the operator is to limit the level to 92%
(approximately 122"). Should level exceed the 92% full mark, the l
j operator would take appropriate action should level approach the l l 127.5" level. As such, monitoring level up to 132.5" is not )
4 necessary. Therefore, it is Vermont Yankee's position that the l l existing range is adequate. I D20,D21 RHR Heat Exchanger Outlet Temperature Cooling Water Regulatory Guide 1.97 requires environmentally qualified monitoring of these two variables. In the Vermont Yankee EQ Program Temperature to ESF, monitoring the RHR System Components heat exchanger shell and tube side outlet temperature is not relied upon. The function of the RHR heat exchangers post-accident is to remove stored and decay heat. In lieu of the RHR heat exchanger temperature variables, monitoring the reactor and primary containment responses (i.e., torus water temperature, drywell, and reactor pressure) will be the most important indicators of RHR heat exchanger performance. Therefore, additional qualification or upgrading is not warranted. Vermont Yankee considers these parameters Category 3.
D24 Emergency Ventilation 1 Damper Position The Regulatory Guide requires that this parameter be environmentally qualified. However, per the Vermont Yankee Environmental Program, environmental qualification of damper position is not required. This is because the dampers are located outside the Reactor Building. As such, they will not experience a harsh environment. Therefore, it is Vermont Yankee's position that emergency ventilation damper position is not required to be environmentally qualified to satisfy the intent of Regulatory Guide 1.97.
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Attachment A i Qualification Summary March 1996 D25 Status of Standby Power (A thru I,
~ L, & M) ne Regulatory Guide requires that this variable be environmentally qualified. Variables D25J, K. N, and O have been determined to satisfy this requirement. The remainder of the Variable D25 i
indicatiora do not require environmental qualification because none of the cables or components are located within a harsh environment.
Herefore, it is Vermont Yankee's position that the remaining D25 variables are acceptable without environmental qualification.
E2 Reactor Building or Secondary Area Radiation Containment . Post-accident secondary containment area ra r
well as radiation monitoring in other areas where personnel access -
l may be desirable, would be helpful to the Health Physics .
- Department in determining local radiological conditions prior to l
. entering these areas. His function is important from the standpoint of evaluating personnel habitability in the event of a severe core :
damage accident.
Areas outside the Reactor Building that do require personnel access post-accident have been analyzed using very conservative assumptions to show that habitability would be allowed. !
The EQ Program assumes that habitability in the Reactor Building ,
is not possible for at least three months post-accident. Equipment required for long-term post-accident operations has generally been environmentally qualified for one year. Therefore, any decisions on
, habitability inside the Reactor Building would not be necessary for i some time after the event. If the secondary containment area radiation monitors were not functioning at this time, alternate means to estimate secondary containment radiation levels would be possible (i.e., correlations based on drywell, vent stack, and site area radiation measurements). :
l Therefore, Vermont Yankee considers this parameter Category 3.
I E6 Noble Gases and i l !
Vent Flow (Reactor Shield Annulus) Variable E6 pertains to a Reactor Shield Building annulus. Vermont l Yankee does not utilize a Reactor Shield Building in their design. ;
Therefore, this is not applicable.
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Attachment A Qualification Summary March 1996' l i
! E8 Airborne Radioactive
- Material Releases - .i Common Plant i Ventilation These monitors are located in the stack. The only possible harsh j environment is due to radiation. This equipment is specifically -
designed and tested to measure radiation levels higher than those which will be encountered. Therefore, they are qualified for their intended service.
These instruments read out in CPM and millirem; however, a simple conversion to microcuries per cubic centimeter can be accomplished by Health Physics. The range of millirem, once 4
converted, envelopes the uCi/cc range specified by Regulatory Guide 1.97. Therefore, it is Vermont Yankee's position that the existing instruments satisfy the intent of the Regulatory Guide.
The low range instruments are only relied on to provide information while the stack effluent is still representative of normal plant I
- operation. The low range instruments are relied on during the e
j initial stages of an accident scenario. The high range instruments are relied on to follow the progress of post-accident releases up the
. stack. Therefore, the high range instruments are viewed as
- Category 2 instruments, while the low range instruments are considered to be acceptable as Category 3.
E12 Environments Radiation R2.dioactivity Plant I and Environments Radiation ' Presently, there is one portable survey instrument at Vermont Yankee that can measure up to 104 R/hr photons, but none that can measure the Regulatory Guide required 104 R/hr beta. The existing instrumentation can measure approximately 102 R/hr beta. These ranges are sufficient for portable plant use.
E16 Atmospheric Stability The existing delta temperature is ranged -50' F to +15' F.
Regulatory Guide 1.97 requires a range of-9* F to +18' F. This covers all seven stability classes, it is Vermont Yankee's position that the existing range is adequate. 'Ihis is based on the fact that the existing range has historically been adequate over the operation of the system. Expanding the range does not provide improved information.
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' Attachment A Qualification Summary March 1996 -
E17 Primary Coolant Sample )
(pH) Regulatory Guide 1.97 requires the on-site ability to perform several different analyses on the primary coolant sample, one of which has a pH concentration of 1 to 13. However, in a previous Vermont Yankee letter, dated September 21, 1984, concerning NUREG-0737, item II.B.3, " Post-Accident Sampling Capability," Criterion 10, that, "... pH measurements are not included because an i undiluted sample cannot be obtained from the post-accident sample I panel 9". The NRC issued a safety evaluation report on January 14, 1985 accepting this position. 'Ihe above exception is based on tests conducted at Vermont Yankee on actual reactor cooltnt samples. ,
This sample was obtained and diluted with demineralized water to a dilution of 1000:1, which is the minimum dilution appropriate to t maintain personnel radiation exposures ALARA for the expected j post-accident coolant activity levels. The resulting measurement ,
concluded that no meaningful information was obtained other than 5 the undiluted sample was acidic or alkaline. Additionally, Vermont ,
Yankee evaluated the need to measure coolant pH at a freshwater ;
BWR site and determined that pH is not particularly important since all metals which contact the coolant are compatible with liquids 8 having a wide range of pH. Thus, we conclude that relatively little j meaningful information would be gained from post-accident coolant 1 pH sampling. j Therefore, based on Vermont Yankee's prior notification to NRC ;
stating that undiluted pH samples cannot be obtained for the post-accident sample station; NRC's acceptance of Vermont Yankee's provisions to meet NUREG-0737, Item II.B.3, Criterion 10; and Vermont Yankee's evaluation of diluted pH samples discussed above, we have removed primary coolant pH from our post-accident <
monitoring instrumentation' list.
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Attachment A Qualification Summary March 1996 I
- 3. Instrumentation Reauirine Uncrade or Modification 1 This section details additional instrumentation needed for compliance to the Regulatory Guide. This additional instrumentation consists of any equipment which requires modifications to establish compliance. !
This could consist of entirely new instrument channels or existing instrument channels which require some j upgrade.
lica Service Results !
l B10 Primary Containment l Isolation Valve Position l Indication (FCV 2-39 & !
l FCV 2-40) These are recirculation sample line isolation line PCIS valves. Item ;
j B10 requires PCIS valve position indication. These valves presently l
- do not have a direct means of monitoring valve open-closed i i
position. A means of direct position indication will be added to l these valves during the 1998 refueling outage. Other PCIS valves i
l associated with B10 (valve position indication) have adequate direct ;
measurement. Refer to LER 95-18 dated October 26,1995 (NRC 1 notification BVY 95-117).
i There are no other instruments under this category.
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l Page 12 of 13 l
l Attachment A Qualification Summary March 1996
- 4. Instrument =tinn Deleted from the Submittal ,
1 i
This section details instrumentation which has been deleted from the original Regulatory Guide 1.97 i submittal. The equipment removed and the reasons for the removal are listed below:
lism Service Results A3 Reactor Vessel Reference leg Area l Thermocouple Originally, Vermont Yankee classified this variable as Type A, l
Category 1, based on the Vermont Yankee draft Emergency Operating Procedures (E0Ps). Vermont Yankee has further developed the E0Ps and concluded that these variables are not Type A variables. This is based on the fact that this variable does not provide primary indication of a plant parameter. The reference leg thermocouples provide the Control Room operators with information on the reliability of the reactor vessel level indication. As such, they provide indication of the confidence in a variable providing
(- primary indication of a plant parameter. Based on the above I discussion, Vermont Yankee has removed this item from the Regulatory Guide 1.97 submittal. However, reference leg
, thermocouples have been installed as a part of :he resolution of j- Generic Letter 84-23, " Reactor Vessel Water level Instmmentation j of BWRs.'
B1 Neutron Flux Monitoring Neutron Flux Monitoring was an open issue in the SER provided to. ,
i Vermont Yankee. Subsequent effort by Vermont Yankee and the j j BWROG determined that this variable was not required for RG q l.97. Supplemental SERs (NVY 93-036 & NVY 94-28) concurred with the removal of neutron flux from the Vermont Yankee RG 1.97 submittal.
f- B10 Primary Containment l Isolation Valve Position j Indication (V10-18) RHR shutdown cooling supply, Valve 10-18, has been removed l from the original Regulatory Guide 1.97 submittal and the Vermont l Yankee EQ Program. This valve is normally closed by a pressure l interlock during plant operation and opened only when the plant is l shut down. Following a LI)CA, this valve is not needed for accident l mitigation. Additionally, post-LOCA failure will not cause the valve
! to open. Consequently, removal of this valve from the Regulatory Guide PCIS valve position list is acceptable. j l
l BIO Primary Containment Isolation Valve Position Indication (V10-33) RHR Head Spray Isolation Valve 10-33, has been removed from the l original Regulatory Guide 1.97 submittal and the Vermont Yankee l
( EQ Program. This valve has been removed from service by a plant
- design change. It no longer receives a PCIS signal. Following a Il)CA, this valve is not needed for accident mitigation. ,
L Additionally, post-LOCA failure will not cause the valve to open. ]
l Consequently, removal of this valve from the Regulatory Guide 4 j PCIS valve position list is acceptable.
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Page 13 of 13 L_ _ __ _ . _ -
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l ATTACHMENT B REGULATORY GUIDE 1.97 MATRIX March 1996 1
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A MMEN Page 1 of13 -
REGULATORY GUIDE 1.97 MATRIX March 1996 RG 197 VARuBLE MATRfx TYPE 'A' VARIABLES DOCUMENTI.TIOlWQUALFCATION CATEGORY COMPUTER VARMBLE VARIABLE REQUIREDI REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR D RECORDER D NPUT-O DESCRIPTION CO M MTTED RANGE RANGE DANCY ID SUPPLY LOCATION LOCATION AVAILABLE ' EQ SEtSMC QA REMARKS A1 REACTOR VESSEL 1/1 PLANT SPECFIC 0to 1500 peg YES PT 2-3-56A&8 ECCS 24Vdc Pt 24 56A&8f LR/PR 2448A&BI YES YES YES YES NOTE At PRESSURE A&8 CRP F5 CRP S3 & 94 A2 REACTOR VESSEL 111 PLANT SPECFIC -200 to +200" H2O YES LT 2-3-T3A&8 ECCS 24Vdc U 2441A&BI LR/PR 2448AE8f YES YES YES YES . NOTE At WATER LEVEL A&B CRP94 CRP S3 & 94 j A3 DELETED - - - - - - - - - . - - NOTE A2 A4 DRYWELL 1/1 PLANT SPECFIC -15 to 260 peg YES PT 1&19-29A&B VITAL ac Ll/Pt1&1412A&8f NONE YES YES YES YES NOTE A1 PRESSURE INSTR ac CRP S3 AS DRYWELL 1/1 PLANT SPECFIC 0 to 350 F YES TE 1&19-30A&8 vlTALac T11&19-3081 TR1&1945I YES YES YES YES NOTE A1 ,
TEMPERATURE WSTR ac CRP S25 CRP S25 *
. AS TORUS PRESSURE ill PLANT SPECtFIC 15 to 65 psg YES PT 16-19-3GA&8 VITAL ac Pt1&1436A&BI NONE YES YES YES YES NOTE At MSTRac CRP S3 A7 TORUS WATER 1/1 PLANT SPECFIC O to 250 F YES TE 1&19-33A&C VITAL ac T11&1433ASCf NONE YES YES YES YES NOTE A1 TEMPERATURE WSTRac CRP S3 AS TORUS WATER 1/1 PLANT SPECFIC O to 25' H2O YES LT 16-1410A&B VITAL ac ufPI141412AE81 NONE YES YES YES YES NOTE At LEVEL MSTR at CRP E3 1 4
A9 TORUS AIRSPACE 111 PLANT SPECFIC 50 to 300 F & YES TE1&1434& VITAL ac Tl16-19411 - TR 16-19-451 YES YES YES YES NOTE A1 TEMPERATURE O TO 350 F TE 16-1941 MSTR ac CRP 9 3 CRP 9-25 j NOTES A1 THIS VARIABLE FULLY SATISFIES THE REQUIREMENTS FOR TYPE *A* VARIABLE. ACCEPTABILITY OF RANGE IS BASED ON A REVIEW OF THE PLANT SPECFIC EMERGENCY OPERATING PROCEDURES.
A2 THIS ITEM HAS SEEN DELETED AS A TYPE "A" VARIABLE. REFEst TO ATTACHMENT A'. TABLE 4 OF TEXT.
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- ---m. .u _s a __ __ _.-_.-_m.._m._.. _,--- .-_ma- _ . _ . _ - w e-m up - a +we--
ATT^cWENTC ' Page 2 of13 REGULATORY GUIDE 1.97 MATRtx March 1996 RG 197 VARIABLE MATRtX TYPE *Y VARIABLES DNaz.wrwGUALIFICATION .
CATEGORY COMPUTER VARMBLE VARIABLE REQUIREDr REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR IDF RECORDER Dr INPUT ,
ID DESCRIPTION COMMITTED RANGE RANGE DANCY ID SUPPLY LOCATION LOCATION AVAILAstE EQ SEISMIC QA REMARKS t
RE#TMTV CONTROL 81 DELETED - - - - - - - - - - - - NOTE 85 C2 CONTROL ROD 3f3 FULL M OR FULL IN to MR ROD POSITION INST ac ROD POSITIONI NONE YES MR MR MR NOTE 81 POSITION NOT FULL M FULL OUT CRP 94 83 RCS SOLUBLE 3/3 0 to 1000 ppm 0 to 1000 ppm MR GRA8 SAMPLE MA N/A MA MA MA MA MA NOTE B1.83 BORON CONCENTRATION ,
(GRAB SAMPLE) !
CORE COOLMG ,
84 COOLANT LEVEL M 1/1 BOTTOM OF CORE SUPPORT 400 to +200"H2O YES LT 2 3-73A&B ECCS 24Vdc LI 2-3-91 A&BI LRIPR 2448*&8f YES YES 7ES YES NOTE B2.87 REACTOR VESSEL PLATE TO LESSER OF TOP - A&B CRP 94 CRP S3 & 9-4 OF VESSEL OR CENTERLINE OF MAN STEAM LINE US BWR CORE (NONE) 200 F to 2300 F NONE N/A NIA N/A N/A N/A MA MA MA MA NOTE 84 TEM ERATuRE L
MANTAINNG REACTOR COOLANT SYSTEM NTEGRITY s
86 RCS PRESSURE 1/1 0 to 1500 (pag) O to 1500 peg YES PT 24-56A&B ECCS 24Vdc PI 24-56A&81 LR/PR 2448A&87 YES YES YES VES NOTEB1 A&8 CRP 9-5 CRP E3 & 94 4 87 ORYWELL 1/1 0 to DESIGN -15 to 260 peg YES PT 1&1429A&B VITAL ac Ll/PI 16-1412A&8f NONE YES YES YES YES NOTE 82.86 [
PRESSURE NSTR ac CRP S3 88 DRWELL SUMP 113 TOP to BOTTOM NONE NfA MA N/A MA MA MA MA N/A N/A NOTE 811 LEVEL L
MANTAfMNG CONTAINMENT NTEGRfTY [
89 PRIMARY 1/1 4 peg to DESIGN PRESSURE -15 to 290 peg YES PT 16-19-29A&B VITAL ac Ll/Pt 16-1412A&Bf NONE YES YES YES YES NOTE 82.86 f CONTAINMENT MSTRse CRPS3 i PRESSURE 810 PRIMARY 1/1 CLOSED- CLOSED- YES PER EACH VARIOUS LIGHTSI NONE NONE YES YES YES NOTE St. ,
CONTANMENT NOT CLOSED NOT CLOSED VALVE CRP 94 810,812 t ISOLATION VALVE POSITION (EXCLUDING CHECM VALVES) b t
F
. . _ . . _ __._m._-_.______.___.m._s
_ _ . _ _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . - . _ <- - - - - . . _ - -wvv %._ _2 _ , _ - - . , . . -
ATTACHMENT B Page 3 of13 '
REGULATORY GUIDE 1.97 MATRIX March 1996 .
NOTES.
B1- FULLY SATISFIES THE REOUIREMENTS SPECIFIED BY RG 197.
32 SATISFIES THE MTENT OF THE REOUIREMENTS SPECIFIED BY RG 197 ON A PLANT SPECIFIC BASIS REFER TO ATTACHMENT'A*. TABLE 2 OF TEXT. .
33 THERE IS NO MSTRUMENTATION DIRECTLY ASSOCIATED WITH THIS PARAMETER THE SAMPLE ANALYSIS IS PERFORMED BY THE CHEMISTRY & HEALTH PHYSICS DEPARTMENT.
54 NOT REQUIRED AT THIS TIME (REFER TO SECY 82-1111 WATER LEVEL tSSUES ADORESSED M VYs RESPONSE TO GENERIC LETTER B4-23. REFER TO ATTACHMENT W. TABLE 2 OF TEXT.
85 ITEM REMOVED REFER TO ATTACHMENT'A' TABLE 4 OF TEXT.
96 DESIGN PRESSURE IS 56 PSIG B7 THE FOLLOWING LEVELS ARE APPROXIMATEL BOTTOM OF CORE SUPPORT PLATE IS -154* TCP OF %ESSEL IS +$00 CENTERLINE OF MAIN STEAM LINE IS +244*. TOP OF ACTIVE FUEL IS 0" REFERENCE POWT.
98 DELETED REPLACED BY NOTE 12.
99 ITEM REMOVED REFER TO ATTACHMENT A' TABLE 4 OF TEXT.
B10 SOME VALVE POSITION MAY INPUT TO ERFIS HOWEVER. IT IS NOT NECESSARY TO INPUT ALL OF THEM B11 TORUS WATER LEVEL IS RELIED UPON TO PROVIDE INDICATION OF SUMP LEVEL OVERFLOW REFER TO ATTACHMENT W. TABLE 2 OF TEXT. CATEGORY 3 SUMP LEVEL CONTROLS ARE REUED ON.
E12 THE LIST OF PCIS VALVES WHOSE INDICATION IS INCLUDED tS AS FOLLOWS (REDUNDANCY CLASS DEFINED IN ATTACHMENT Cy val.VE TAG REDUND VALVE TAG SERVICE REDUND VALVE TAG SERVICE REDUND.
NUMBER SERVICE CLASS ' NUMBER CLASS NUMBER CLA35
~
AOV-2-80A.B.C.D Mam Seam Isolmsma (Inboard) I MOV-2-74. TF Man Saram Dram, hotation i NGil A. B CAD Pwge $gply Isolmes 2 AOV-24A.B.C.D Man Suse isoimme (Ombaard) l MOV-1413A.B.C.D RHR Peup Surnoe Fiem Torus lao. 4 NG12A, B CAD Pwge Supply hointma 2 (
i AOV-2482. 83 DW Floor Drain Isolatson I MOV-1416A. B RHR Mannum Recut. no Torus iso. 4 ngl 3A, B CAD Pwse Supply isoimma 2 AOV-2494,95 DW Equipmem Drais isoimma I MOV-1417 Shutdown Coolms Reactor holatma 4 VG9A. B CAD Vem holanon 2 i
, AOV-72-38A. B DW As Cornpressor Secten Isolaren i MOV-1425A B RHR LPCI so Reaceur Isolema 2 VG22A. B CAD Vem isolacen 2 l 1 ;
FCV-2-39. 40 Reacsor Sample Line holatma 3 MOV-1427A, B RHR LPCI es Reactor geolatum 2 VG23 Drywell Radinison Manner Supply 3 Isolmen Tir BY TIP Ball Vafws i MOV-1426A. B RHR so DW Spray Isolmen 2 VG24 Torus H242 Sample luolata,a 2 Tir SV TIP $ lear Valves 1 MOV-1431 A. B RHR e DW 5 pray Isolmsen 2 VG25 Torus im02 sample hotarme 2 VG 26 DW Radenom Monnor isdarma 3 t F34109-76A. B DW Radutme Monow to Torus 3 MOV-1434A. B RHR to Torus isolation 2 Vri-33 Torus H222 Sample holmsee 2 I lonV.mn
[
V142420; 22A.B N2 Maketg Isolanon I MOV 1438A. B RHR esTorus sprsy holmme 2 VG34 Torus H222 Sample holaima 2 ,
l
$8-9.10. II.12 RB HVAC laulatspe (see D24) i MOV-1439A. B RHR so Torus Spray Isolarme 2 FsG109 Torus H242 Sample Isohnen 2 75A1. A2 i
S&le 19M DW Vem e SBGT leolmen i MOV-1457,66 RHR to Radensee incianon i F50109 Torus H222 Sample Isolmen 2 75A3 A4 l 53161946A. 07A DW Vem hotatma 1 MOV-12-13.18 RWCU Supply Isaintson i F50109- Drywell H2/02 Saniple lealatma 3 75Bl. B2 58-1419468. 07B Torus vem lenianon i MOV-1248 RWCU Return Isolance 4 FSG109- Drywell H242 Sangle holation 2 75C1. C2 58 16 1947 DW Vem e Stack isolaten I MOV-1115.16 RCIC TurtHne $wam Supply Isolaten 1 F3G109- Drywell H2J02 Sample Isolauon 2 75DI D2 ,
58-16-1948 Pwge Supply so DW holmion I MOV-1445A. B O Mm. mum Rectrc. m Torus 4 holasma i CS Sucten holanne 4
~
SB-le 1949 Ar Purge $upply Fsom RB Isolanon MOV-1447A. B
, $B-161410 Fwge Supply so Torus isolaten i MOV-14-II A. B CS en Reecear holanos 2 SB-!619 II A. B DW Vacuum Retef Isolasma 4 MOV-14-12A, B CS to Reecour helation 2
$8-161423 N2 Pwge Sgply luolates ! MOV-23-15.16 HPCI Suura Supply Isaimme I
_ . , ._ . _ _ _ _ _ _ . - - - _ . - . - ~ ~ _ _ _ _ - - _ _ ~ . - . _ - _ _ . - - - _ _ - - - - _ __-
ATTACHMENT B Page 4 or13 REGULATORY GUIDE 117 MATRlx March 1996 RG 197 VARIABLE MATRIX TYPE T VARIABLES DOCUMENTATIOMOUALIFICATION CATEGORY COMPUTER '
VARIABLE VARIABLE REQUREDI REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR IDI RECORDERIDI MPUT ID OFSCRIPTION COMMITTED RANGE RANGE DANCY ID SUPPLY LOCATION LOCATION AVAILA8LE - EQ SEtSMIC QA REMARKS FUEL CLADDING C1 RADIOACTIVITY 1/3 1/2 to 100X TECHNICAL 0 to 1E+6 mR/Hr WR RD17 RPS BUS A&8 RM 17 RR 17-2521 YES NR WR WR NOTE CONCENTRATION SPECIFICATION LIMIT 230A8.C.D 251 A,8.C.&Dr CRP 9-2 C2C5.C9 OR RADIATION CRP S10 LEVEL M CIRCULATING PRIMARY COOLANT C2 ANALYSIS OF 3t3 10 uCdml to 10 CWml OR to uCWml to10 CWml N/R COO! ANT WA N/A WA WA WA WA N/A NOTE C1,C3 PRIMARY COOLANT TD 14844 SOURCE TERM M SAMPLE (GAMMA COOLANT VOLUME SPECTRUM)
C3 BWR CORE (NONE) 200 F to 2300 F NONE WA WA WA N/A WA WA WA WA WA NOTE C4 TEMPERATURE REACTOR COOLANT PRESSURE BOUNDARY C4 RCS PRESSURE 111 0 to 1500 (psg) 0 to 1500 psg YES PT 2-3-56A&B ECCS 24Vdc PI 2-3-56A&Bt LR/PR 2-348A&8f YES YES YES YES NOTE C1 A&B CRP 9-5 CRP 94 & 94 C5 PRIMARY 3/3 1 R#v to 1E+5 RMr 1 R/Hr to 1E+7 R/Hr NIR RD 16-19-1 A&8 VITAL ac RI151S1A&Bt NONE YES WR WR N/R NOTE C1 CONTAINMENT MSTRac CRP S3 AREA RADIATION C6 DRYWELL DRAM 1/3 TOP to BOTTOM NONE WA WA NA N/A WA WA WA WA WA NOTE C10 SUMPS LEVEL (IDENTIFIED AND UNIDENTIFED l
LEAKAGE)
- C7 SUPPRESSION 111 BOTTOM OF ECCS SUCTION O to 2F H2O YES LT 151S10AAB VITAL ac Ll/Pt 16-1912A&81 NONE YES YES YES YES NOTE C1.C7 POOL WATER LEVEL LINE to 5 FT ABOVE NORMAL INSTR ac CRP S3 ;
WATER LEVEL C8 DRYWELL III O to DESIGN PRESSURE (psg) -15 to 260 psg YES PT 1&19-29A&8 VITAL ec LitPl16-1412A&BI NONE YES YES YES YES NOTE C2.C5 PRESSURE INSTR ac CRP S3 ;
CONTAINMENT C9 RCS PRESSURE 1/1 0 to 1500 (psg) O to 1500 peg YES PT 2-3-56A&B . ECCS 24Vdc P12-3 56A&B/ LR!PR 2-3-68A&Bt YES YES YES YES NOTE C1 A&8 CRP 9-5 CRP 9-3 & 9-4 i
C10 PRSAARY 1/1 -5 pag PRESSURE to 3 TIMES -15 to 260 peg YES PT 1&1429A&8 VITAL ac LifPt 1&1412A&BI NONE YES YES YES YES NOTE C1.C5 CONTAINMENT DESIGN PRESSURE FOR INSTR ac CRP S3 PRESSURE CVNCRETE: 4 TIMES DESIGN h PRESSURE FOR STEEL C11 CONTAINMENT AND 1/1 0 to 30 VOL-WCAPABlWTY OF 0% to 10% to 30% YES SAH VG-5A&8 PP49 NONE SR VG4A&BI YES YES YES YES NOTE C1.C5 DRYWELL OPERATNG FROM -5 peg TO AC-DP-5 CAD PNL A&B HYDROGEN DESIGN PRESSURE)
CONCENTRATION
- _ . _ _ _ _ ..m_ _ _ _ _ _ _ - . _ _ _ - --__-_-___.m-_.--_-__--.__.___._.___m--_ _- _ _ _ _ . _ _ _ _ _ __ w-e.-e%*rd-,W-r ___: 4 eer---W W - - - - + .a. m. -__ _ m= -_ ___ A __ - -
ATTACHMMT B Page 5 of 13 -
REGUI.ATORY GUIDE 1.97 MATRIX . March 1996 RG 197 VARIABLE MATRIX TYPE T VARIABLES DOCUMENTATIOMOUALFICATON CATEGORY COMPUTER VARIABLE VARIABLE REQUIREDI REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR IDF RECORDERIDI INPUT C DESCRIPTION COMMITTED RANGE RANGE DANCY O SUPPLY LOCATON LOCATION AVAILA8LE EO SEISMIC QA REMARKS 2
C12 CONTAINMENT AND ' 1/1 0 In 10-VOL-%(CAPA83LITY OF 0% b 10% to 25% YES SAH VG4A&8 PP-89 INDICATOR (NO SR VG4A&BI YES YES TES YES NOTE C1.C5 DRYWELL OXYGEN OPERATNG FROM -5 ps'O TO AC-DP-5 0)tCAD PNL A&B CAD PNL A&B CONCENTRATION DESIGN PRESSURE)
(FOR INERTED CONTAINMENT PLANTS) i C13 CONTAINMENT 3I- 1E4 uCWce to 1E 2 uCitoc NONE MA WA WA WA WA WA N/A MA MA NOTE C8 EFFLUENT RADIOACTIVITY .
NOBLE GASES (FROM IDENTIFED RELEASE POINTS MCLUDING STAND 8Y GAS TREATMENT SYSTEM VENT)
C14 EFFLUENT 21- 1E4 uCaRm to 1E*3 uCatcc NONE WA WA MA MA MA MA WA MA MA NOTE C8 RADIOACTN ITY -
NOBLE GASES (FROM BUILDINGS OR AREAS WHERE PENETRATIONS AND HATCHES ARE LOCATED.eg.
SECONDARY CONTAINMENT AND AUXILLARY BUILDINGS AND FUEL HANDLMG BUILDINGS THAT ARE M DIRECT CONTACT WITH prs 9ARY CONTA#MNT)
NOTES, C1 FULLY SATISFES THE REQU18GMENTS SPECIFED BY RG 197.
C2 SATISFIES THE MTENT OF THE NMutREMENTS SPECIFIED BY RG 197 ON A PLAST SPECIFIC BASIS. REFER TO ATTACHMENT'A', TABLE 2 OF TEXT.
C3 THERE IS NO INSTRUMENTATION DINtOTLY ASSOCIATED WITH THIS PARAMETER. THE SAMPLE ANALYSIS IS PERFORMED BY THE CHEMtSTRY & HEALTH PHYSICS DEPARTMENT.
C4 NOT REOUIRED AT THIS TIME (REFER TO S*CY 82-111). WATER LEVEL ISSUES HAVE BEEN ADDRESSED M VYs RESPONSE TO GENERIC LETTER 84-23. REFER TO ATTACHMENT W, TABLE 2 OF TEXT.
C5 DESIGN PRESSURE IS $6 PSIG.
C3 TECH SPEC LMIT IS 3X BACKGROUND. TYPICALLf. BACKGROUND DOES NOT EXCEED 300 mR1HR.
C7 LEVELS ARE APPROXIMATE: BOTTOM OF ECCS SUCT AN IS 2' NORMAL LEVEL IS 12' CQ INDMOUAL MONETORING OF THIS PARAMETER IS NOT AFPLICABLE, INCLUDED IN ITEM EB. REFER TO ATTACHMENT 'A*, TABLE 2 OF TEXT.
C9 PER THE VERMONT YANKEE EQ MATRIX THESE DEVICES ARG CATEGORY 'C'. AS SUCH, THIS EQUIPMENT WILL EXPERENCE HARSH ENVIRONMENTAL CONDITONS WHICH IT NEED NOT FUNCTION FOR MITIGATION OF THE ACCOENT AND WHOSE FAILURE DURING THE ACCOENT IS NOT DETRIMEftTAL TO PLANT SAFETY OR ACCOENT MITIGATION THEREFORE, THIS EQUIPMENT NEED NOT BE QUALIFED FOR THE ACCOENT.
C10 TORUS WATER LEVEL IS RELIED UPON TO PROVIDE INDICATION OF SUMP LEVEL OVERFLOW REFER TO ATTACHMENT W. TA8LE 2 OF TEXT. CATEGORY 3 SUMP LEVEL CONTROLS ARE RELED ON-
- - - . _ . - . a--- - - - . - - - . - - - - - _ - , - - - - - . - - - - . - - - - - - - _ - - - -aetu -_a ___-,,---,.a _'----=w+ + wwwu----_m - +-- m. -- - - ~ - _ - - - - _ - ------. _----
ATTACHMENT B Page 6 Of13 i REGULATORY GUIDE 1.97 MATRIX March 1996 RG 197 VARIABLE MATRIX TYPE 7 VARIABLES DOCUMENTATIOMQUALIFICATION CATEGORY COMPUTER VARIABLE VARIA8tE REQUIREDr REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR IDI RECORDER Of INPUT U DESCRIPTION COMM!TTED RANGE RANGE DANCY ID SUPPLY LOCATION LOCATION AVAILABLE EO SEISemC QA REMARKS .j m
CONDENSATE AND FEEDWATER SYSTEM D1 MAIN FEEDWATER 3!3 0 m 110% DESIGN FLOW 0 to 4E*6 ltun/Hr MR FT 6-50A&8 VITAL ac FI 649A&Bf R 6-961 YES MR MR MR NOTE FLOW CRP 9-5 CRP 45 D1.D3.04 D2 CONDENSATE 3/3 BOTTOM to TOP O to 35" MR LT 107-5A&8 VITAL ac LI 107-5f LR 23-73I YES MR MR WR NOTE STORAGE TANK , CRP 94 CRP 9-3 02.D4_D5 LEVEL i
PRNARY CONTAWMENT - RELATED SYSTEMS D3 SUPPRESSION 2/2 0 to 110% DESIGN FLOW D to 17000 gpm MR FT 10111A&B NSTRac F410136A&BI NONE YES YES MR YES NOTE CHAMBER SPRAY CRP 9 3 D1.D4 D6 !
FtOW L
D4 DRYWELL 2f2 -5 pasg to 3 psg (NARROW -15 to 260 peg MR PT 1619-29AAB VITAL ac Ll/Pl1619-12A&BI NONE YES YES MR YES NOTE D2.D7 k PRESSURE RANGE) AND0 to110% INSTRac CRP E3 i
DESIGN PRESSURE (WIDE RANGE)
?
D5 SUPPRESSON 21- TOP OF VENT TO TOP OF NONE MA MA MA N/A MA MA NA N'A NA NOTE 09 ,
POOL WATER LEVEL WEIR WALL D6 SUPPRESSION 2s2 40 F to 230 F 0 to 250 F N/R TE 16-1433A&C VITAL ac Tl161S33ASCE TR 1&19-40f YES YES MR YES NOTE D1 I POOL WATER INSTRoc CRP 43 CRP 947 TEMPERATURE k f
D7 DRYWELL 2/2 40 F to 440 F 0 to 350 F WR TE 16-1S30A&8 VITAL ac Tl1&193087 TR 161945I YES YES MR YES NOTE D2 I ATMOSPHERIC MSTRac CRP 9-25 CRP 9-25 !
TEMPERATURE ,
D8 DRYWELL SPRAY 212 0 to 110% DESIGN 0 to 17000 gpm WR FT 14111A&B MSTRac FI 14136A&Bf NONE YES YES MR YES NOTE FLOW CRP S3 D1.D4.D6 ,
t MAN STEAM SYSTEM D9 MAN STEAMLME 2/- O to 15 OF WATER (NARROW NCNE MA N/A NA MA NA NA MA MA MA NOTE D9 - 6 ISOLATION VALVES
- RANGE) AND (WIDE RANGE)
LEAMAGE CONTROL ;
SYSTEM PRESSURE !
D10 PRIMARY SYSTEM 2/2 CLOSED-NOT CLOSED OR CLOSED- MR PS 2-71-1,2,&3 VITAL ac LIGHTSt NONE YES YES MR YES NOTE D1.D4 SAFETY RELIEF 0 to 50 peg NOT CLOSED (A.B.C.&D) CRP 9-3 VALVE POSITIONS, INCLUDMG ADS OR FLOWTHROUGH OR l PRESSURE N +
VALVE LINES k
SAFETY SYSTEMS D11 ISOLATION 21- TOP to BOTTOM NONE MA N/A MA N/A MA MA MA MA MA NOTE DB CONDENSER SYSTEM SHELL-SIDE WATER LEVEL
ATTACHMENTB Page 7 of13 g REGut.ATORY GUIDE 1.97 MATRIX Mdrch 1996 RG 197 VARIABLE MATRIX TYPE 7 VARABLES DOCUMENTA70MOUALIFICATION I l
CATEGORY '
COMPUTER )
t4ARIABLE VARIABLE REQUIREDI REQUF<ED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR Of RECORDER Of INPUT i O DESCRIPTION COtmelTTED RANGE ,
RANGE DANCY D SUPPLY LOCATION LOCATION AVAILABLE EO SEISMPC OA REMARKC -(
l !
D12 ISOLATION 2f- OPEN OR CLOSED NONE WA WA N/A NA N#A N/A N/A N/A WA NOTE D9 [
CONDENSER f SYSTEM VALVE POSITON l 013 RCIC FLOW 2/2 0 to 110% DESIGN FLOW 0 to 500 gpm MR FT 13-58 VITAL ac FI 13-91-11 NONE YES NO NdR YES NOTE [
CRP 94 D2.D10 [
[
L D14 HPCl FLOW 212 0 to 110% DEStGN FLOW 0 to 5000 gpm WR FT 2342 DC-1C FI 23-10811 NONE YES NO NR YES NOTE t CRP 9-3 D2.D11 D15 CORE SPRAY 2/3 0 to 110% DESIGN FLOW O to 5000 gpm NR FT 14-40AAB MSTRac F114-50A&BI NONE YES WR WR WR NOTE D2, SYSTEM FLOW CRP 9-3 D4.Dt2 l D16 LPCI SYSTEM FLOW 2/2 0 to 110% DESIGN FLOW 0 to 20000 gpm NR FT 14109AAB WSTRac Fi 10-139A&BI FR 14143f YES YES WR YES NOTED1, -
CRP 9-3 CRP 9-3 D4.D14 L D17 SLCS FLOW 2/3 0 to 110% DESIGN FLOW 0 to 2000 psig N/R PT 11-52 INSTRac P111451 NONE YES N44 NIR WR NOTE f CRP 45 D2.D15 i
D18 SLCS STORAGE 2/3 TOP to BOTTOM o to 127.5" WR LT 11-45 INSTR ac Li 1146I Notf YES NKS WR N44 NOTE TANK LEVEL CRP 9-5 D2.016 f i
I RESIDUAL HEAT REMOVAL (RHR; SYSTEMS D19 RHR SYSTEM FLOW 2r2 0 to 110% DESIGN FLOW 0 to 20000 gpm N4t FT 10-109A&B HSTRac F110-139A&BI FR 14143f YES WS NfR YES NOTE D1, 1 CRP 9-3 CRP 9-3 D4.D14
. i D20 RHR HEAT 2/3 40 F to 350 F 0 to 300 F MR TE 10-93A&B tTRac NONE TRS 23-1157 YES NO MR YES NOTE !
EXCHANGER TE 10-95A&B CRP 9-21 a D2,D17 OUTLET TEMPERATURE ,
COCllNG WATER SYSTEM D21 COOLING WATER 2/3 40 F to 200 F 0 to 600 F MR TE 10-94A&B INSTR ac NONE TRS 23-115f YES NO NIR YES NOTE TEMPERATURE TO CRP 9-21 D2,D17
. ESF SYSTEM COMPONENTS
[
D22 COOLING WATER 213 0 to 110% DESIGN FLOW 0 to 4000 gpm WH FT 10-97A&B INSTRac Fi14132A&BI NONE YES WR WR MR NOTE FLOWTO ESF CRP 9-3 D2.D18 SYSTEM COMPONENTS
, g
?
' RADWASTE SYSTEMS l I I i D23 HIGH RADIOACTIVITY LOUO TANK LEVEL f A WASTE 3I3 TOP to BOTTOM 0 to 140" N/R LT 24389 INSTRac NONE LRS 20-302f NONE MR WR i.? NOTE D1.De i COLLECTION TANK RACK 25-17 i 8 WASTE SURGE 3t3 TOP to BOTTOM 0 to 331r NfR LT 24395 INSTR ac NOME LRS 20 3921 NONE MR WR NIR NOTE D1.D8 TANK RACK 25-17
_..__...__...__.m_m_.. . __ _ _ ._ . _ . _ _ _ . _ _ _ _ _ _ 4 ___ __ _ _ _ - _ . ,.-__m_ re--+ -rw, + _ . v .- --.e-v 4-- 4s. _____.__..r-- _ _ _ _ __
ATTACHMENT B Page 8 of 13 !
REGULATORY GUIDE 1.97 MATRIX March 1996 ;
CG 197 VARIABLE MATRIX VYPE 1T VARIABLES NNTQTIOWOUALFCOTCDN CATEGORY COMPUTER VARIABLE VARIABLE REQUIREDr REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR IDF RECORDER Of INPUT C DESCRIPTION COMMITTED RANGE RANGE DANCY O SUPPLY LOCATON LOCATON AVAILABLE EO SEISMIC OA REMARKS I
C FLOOR DRAM 3/3 TOP to BOTTOM 0 to 140" MR LT 24420 MSTR u: NONE IRS 20-419f NONE MR WR WR NOTED1.08 COLLEC TON TANK RACK 2517 D FLOOR DRAM 3r3 TOP to BOTTOM 0 to 250" WR LT 20437 INSTR ac NONE LRS 244351 NONE WR MR WR NOTE D1.D8 !
SAMPLE TANK RACK 2517 k E WASTE SAMPLE 3/3 TOP to BOTTOM 0 to 215' WR LT 24388A INSTRac NONE LRS 2438GI NONE N/R WR WR NOTE DI.D8 TANK 16A RACK 2%17 F WASTE SAMPLE 3I3 TOP to BOTTOM 0 to 215' NiR LT 20-3888 INSTR ac NONE LRS 243861 NONE N!R WR MR NOTE D1,De TANK 169 RACK 25-17 ,
V2NTILATON SYSTEMS D24 EMERGENCY 2/2 OPENCLOSED STATUS OPENCLOSED WR S3-910.11.E12 AC-DP-5 LIGHTSI NONE YES NO MR YES NOTE ;
, VENTILATION PP-9A CRP 9-26 D2.013 DAMPER POSITION POWER SUPPLIES I I I i t
D25 STATUS OF STANDBY POWER AND OTHER ENERGY SOURCES IMPORTANT TO SAFETY (ELECTRIC,
- HYDRAbLIC, PNEUMATIC)(VOLTAGES, CURRENTS. PRESSURES) j A 4160 V EMERGENCY 212 PtANT SPECFC 0 to 5000V nc NR Eb20 SOURCE Eb20f NONE YES NO MR YES NOTE [
BUS 3 (VOLTAGE) CRP 48 D2,013 B 4160 V EMERGENCY 2/2 PLANT SPECFC 0 to 5000V ac N/R El-21 SOURCE EL211 NONE YES NO NR d NOTE '
BUS 4 O/OLTAGE) CRPE8 02.D13 C DG 1-1A (WATTS) 2 12 PLANT SPECFC O to S000 kW WR EM3 SOURCE El-43f NONE YES NO WR YES NOTE CRP 9 8 D2.013 _
D DG 1-1B (WATTS) 2/2 PLANT SPECFC 0 to 5000 kW N/R EM2 SOURCE EM2/ NONE YES NO MR YES NOTE CRPE8 D2.D13 E DG 1-1 A 212 PLANT SPECFC 56 to 65 Hz MR El-36 SOURCE El-36/ NONE YES NO WR YES NOTE (FREQUENCY) CRP E8 D2 D13 F DG 1-18 2/2 PLANT SPECFC 56 to 65 Hz WR El-35 SOURCE El-351 NONE YES NO WR YES NOTE (FREQUENCY) CRP 9-8 D2.D13 G 125V de DIST PNL 2/2 PLANT SPECFC 0 to 150V dc MR DC-1-VM SOURCE DC-1-VMf NONE YES NO NIR YES NOTE !
DC-1 (VOLTAGE) LOCAL 4BLE VLT D2.D13 H 125V dc DIST PNL 2/2 PLANT SPECFC 0 to 150V de NR DC-2-VM SOURCE DC-2-VMI NONE YES NO NIR YES NOTE i
DC-2 (VOLTAGE) LOCAL 4EIL VLT D2.Dt3 4 125V t: BATTERY 2/2 PLANT SPECFC O to 150V dc WR El-388D SOURCE El-368DI NONE YES NO MR YES NOTE BUS DO-2AS CRP 94 D2.D13, D19 (VOLTA GlE __,,
J MCC Su(VOLTAGE) 2/2 PLANT SPECFC 0 to 800V ac WR INDCATOR (NO SOURCE INDICATOR (NO NONE YES YES WR YES NOTED1 (UPS 1 A. O ASSIGNED) O)#CRP S3 i
_____m. - - . _ . _ _______- ___m__._____ _ _ ____.__m . _. _ _ _ _ i_* n - -- p . y r---w ww- wee- --- -T-w----W-- r '--e rarv--
ATTAMENTa prge 9 of13 REGULATORY GUIDE 1.97 MATRIX March 1996 RG 197 VARIABLE MATRIX TYPE v VARIABLES DOCUMENTAT10 Pef 0UALFICAT10N CATEGORY f. COMPUTER VARIABLE VARIABLE REQUIREDI REQUIRED AVAILASLE REDUN- LOOP SENSOR LOOP POWER . MDCATOR D RECORDER O MPUT O DESCRIPTON COMMITTED RANGE RANGE DANCY O SUPPLY LOCATION LOCATION AVAILABLE EO SEISMC QA REMARKS D25 (CONTINUED)
K MCC 598 (VOLTAGE) 212 PLANT SPECFC 0 to 600V ac NIR INDICATOR (NO SOURCE INDICATOR (NO NONE YES YES N/R YES NOTED1 (UPS 18) O AS$9GNED) 0)/CRP 9-3 L 120f240V UNINTER- 2/2 PLANT SPECIFIC O to 150V ac NfR E8-68 SOURCE El-681 NOME NONE NO NIR ' YES NOTE UPTABLE ac CRP 94 02.D13.020 (VOLTAGE) i M 1201240V 212 PLANT SPECYC 551o 65 Hz N/R El-67 SOURCE El471 NONE NONE NO NtR YES NOTE UNINTER4)PTABLE CRP 94 D2.D13 ac (FREQUENCY)
N ECCS 24V dc SUS A 212 PLANT SPECFC 0 to 50V dc NfR El2460A SOURCE El 2440AI NOME YES YES N#R YES NOTE D1 (VOLTAGE) CRP 9 4 O ECCS 24V de BUS 8 2/2 PLANT SPECFC 0 to 50V de N/R El 2-340B SOURCE El24408f NONE YES ' YES NIR YES NOTE D1 rVOLTAGE) CRP 94 NOTES D1 FULLY SATISFIES THE REQUIREMENTS SPECFIED BY RG 197.
D2 SATISFIES THE MTENT OF THE REQUIREMENTS SPECIFED 8Y RG 197 ON A PLANT SPECFIC BASIS. REFER TO ATTACHMENT W. TABLE 2 OF TEXT.
D3 DESIGN IS 6 4E+6 LBMMR FOR TWO PUMPS. OR 3.2E*6 LBMNR PER EACH FLOW LOOP.
D4 DL*PLICATE CHANNELS FOR MFORMATION. COMMON POWER SOURCE USED FOR BOTH CHANNELS D5 HEIGHT OF CONDENSATE STORAGE TANK IS FROM 0 to 31r-3".
C3 DESIGN IS 7000 GPM (TOTAL OF DRYWELL AND TORUS SPRAYS)
D7 DESIGN IS 56 PSIG D6 WIDE RANGE LEVEL MONITORepsG ESSENTIALLY COVERS THE REQUIRED RANGE OF TOP to BOTTOM D9 NOT APPLICABLE TO VERMONT YANKEE REFER TO ATTACHMENT W. TABLE 2 OF TEXT.
D10 DESIGN IS 400 GPM.
D11 DESGN IS 4250 GPM D12 DESIGN IS 3000 GPM .
D13 ENVIRONMENTAL QUALIFCATON DOES NOT APPLY. THESE DEVICES AND THEIR ASSOCIATED CABLES AND COMPONENTS ARE LOCATED IN A NON41ARSH ENVIRONMENT.
D14 DESIGN IS 14000 GPM D15 PUMP OUTLET PRESSURE IS USED M L9EU OF PUMP DISCHARGE FLOW D16 HEGHT OF SLCS TANK IS 11*4*(132 54 D17 ALTERNATE VARIABLES RELIED UPON FOR THIS PARAMETER REFER TO TABLE 2 OF TEXT.
013 DESGN IS 2700 GPM (RHRSW FLOW)
D19 EMI6110 IS LOCATED ON CRP 94 ON THE GROUND BUS DETECTION PANEL.
020 METER El46 MONtTORS ONE LINE TO NEUTRAL M A 240 Vac CIRCulT.
~
ATTACHMENTB Page 10 or13 REGULATORY GUIDE 1.97 MATRIX March 1996 RG 197 VARtABLE MATRIX TYPE T VARIABLES DOCUMENTATIOWQUALFICATION CATEGORY COMPUTER UARIABLE VARIABLE REQUIREDI REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR D RECORDER D INPUT ID DESCRIPTION COMMITTED RANGE RANGE DANCY O SUPPLY LOCATION LOCATION AVAILABLE EQ SEISMIC OA REMARKS CONTANMENT RADIATION E1 PRIMARY 1/1 1 Rhr to 1E+7 Rthr 1 Rhtr to 1E+7 R/Hr YES RD 16141A4B VliAL ac RI 16141A&Bt NONE YES YES YES VES NOTE E1 CONTAINMENT NSTRac CRP S3 AREA i RADIATION +ttGH RANGE E2 REACTOR BUILDING 2/3 1E-1 R#r to 1E+4 R4r FOR RM 17-452A&Bf RR 17-455f NOTE E2.E3 OR SECONDARY MARK l AND 11 0 to 1E+4 mRMr N/R RD 17-430A&B RPS ASB CRP S10 CRP 42 YES WR WR WR CONTAINMENT CONTAINMENTS.1 R/hr to RM 17-453A&Bt AREA RADIATION 1E+7 Rhr FOR MARK m 0 to 1E+4 mRMr NIR RD 17-431 A&B RPS A&B CRP S10 NONE YES WR WR WR CONTAINMENT RM 18-154A.B.&Ct
. 1 to 1E+4 R/Hr WR RD 18154A.B.&C NSTRac CRP 9-11 NONE YES WR WR WR AREQ RADIATION E3 RADIATION 3/3 1E-1 RAr to 1E+4 Rev 0 to 1E+4 mRetr WR NSTRoc RM 18-56 UNITS NONE YES WR WR WR NOTE E1 EXPOSURE RATE RD 1845 UNITS #1.4 thru 12.&14 (INSOE BUILDMGS 81.4 Oru 12.814 thru 16; OR AREASWHERE #wu if RM 18-51 UNITS ACCESSBS RD15 NITS s2&3/
REQUIRED TO s2&3 CRPSit SERVICE 1 to 1E+4 RMr WR RD 18154A.B.&C MSTRac RM 18-154A.B.&Cl NONE YES WR WR WR EQUIPMENT CRP 9-11 IMPORTANT TO SAFETY)
QlRBORNE RADIOACTIVE MATERIALS RELEASED FROM PLANT I I I I I I I I NOBLE GASES AND VENT FLOW RATE E4 DRYWELL 21- 1E4 uCptz:to 1E+5 uCdec, NONE N/A WA WA WA WA WA NA NA NA NOTE E3,E4 PURGE. STANDBY 01o 110% VENT DESIGN GAS TREATMENT FLOW (NOT NEEDED F SYSTEM PURCT EFFLUENT DISCHARGE (FOR MARK l AND 11 THROUGH COMMON PLANT PLANTS) AND VENT)
SECONDARY CONTAINMENT PUi1GE (FOR MARK m PLANTS) 4 E5 SECONDARY 28- 1E4 uC#cc to 1E+4 h NONE N/A N/A N/A NA WA WA WA WA WA NOTE E3,E4 CONTAINMENT 0 to 110% VENT DESIGN PURGE (FOR MARK FLOW (NOT NEEDED F
- 1. II, AND Ill PLANTS) EFFUlENT DISCHARGE THR'OUGH COMMON PLANT VENT)
E6 SECONDARY 21- 1E4 uC#cc to 1E+4 uCam NONE WA WA WA WA WA N/A WA WA NA NOTE ES CONTAINMENT 0 to 110% VENT DESIGN (REACTOR SHIELD FLOW (NOT NEEDED F BUILDING ANNULUS. EFFLUENT DISCHARGE IF IN DESIGN) THROUGH COMMON PLANT VENT) 1
-_.. . . . _ _ _._.__m _ . _ . . _ _ _ _ _ . _ , _ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ - < - _ . _ - _ - _ - _ - _ , - _.-wm __r.- -_+-,=.--.-~-ab - . - . - . _ = = - - - __ _ _ _ - _ _ . _ _ _ - - = __ _
ATTACWENT B Pege 11 of13 REGULATORY GUIDE 1.97 MATRIX March 1996 RG 197 VARIABLE MATRIX TYPE *E' VARIABLES DOCUMEN7ATIO400ALIFICATION CATEGORY COMPUTER VARIABLE VAR 4ABLE REQUIREDI REQUIRED AVAILABLE REDUN- LOOP SENSOR LOOP POWER INDICATOR Of RECORDERIDI INPUT C DESCRIPTION COnmalTTED RANGE RANGE DANCY ID BUPPLY LOCATION LOCATION AVARABLE EO SEISMIC OA REMARKS E7 AUX 1LIARY 21- 1E4 uCWee to 1E+3 uCWcc, NONE WA N/A N/A N/A WA NrA WA MA MA NOTE E4 BUILDMG 0 to 110% VENT DESIGN (INCLUDING ANY FLOW (NOT NEEDED F BUILDHG EFFLUENT DISCHARGE CONTANWG THROUGH COMMON PLANT PRBAARY SYSTEM VENT)
GASES e g . WASTE GAS DECAY TANK)
E8 COMMON PLANT 1E4 uCWce to 1E*3 uCah:. RM STACK GAS NOTE E2,E6, VENT OR 0 to 110% VENT DESIGN RD STACK CMi DG-1 ve t<I RR 108-1/ E7.E10 MULTIPURPOSE 2/3 FLOW to to 1E+7 CPM NIR t & It LP-1L&1AE CRP 9-2 CRP 9-2 YES N/R N44 WR VENT DISCHARGING ANY OF THE ABOVE 2/2 1 to 1E+7 mR/Hr N/R RD 17-155 DG-1 vs RM 17-155i NONE YES NO N/R YES RELEAshS LP-1L CRP 9-2 (IF DRYWELL OR 1E4 uCWce to 1E+au Cau:
SGTS PURGE IS NCLUDED)
E9 ALL OTHER 21- 1E4 uCWce to 1E*2 uCM NONE N/A MA N/A N/A N/A MA N/A N/A N/A NOTE E4 OENTIFIED 0 to 110% VENT DESIGN RELEASE POINTS FLOW (NOT NEEDED IF EFFLUENT DISCHARGE THROUGH COMMON PLANT VENT)
PARTICULATES ANDHALOGENS E10 ALL OENTIFIED 313 1E-3 uCWce to 1E+2 uCWec, 1E-3 to 1E+2 uCWcc WR STACK GRAB N/A N/A N/A N/A MA WA N/A NOTE E1.E8 PLANT RELEASE O to 110% VENT DESIGN SAMPLE POINTS. SAMPLING FLOW WITH ONS!TE ANALYSIS CAPABILITY EleflRONS RADtATION AND RADIOACTIVITY I
Ett AIRBORNE 3/3 1E-9 uCdoc to 1E-3 uCWec 1E-9 uCWee to 1E-3 WR PORTABLE I WA MA N/A N/A N/A MA NA NOTE E1.E8 RADIOHALOGENS uCWec SAMPLNG AND PARTICULATES (PORTABLE SAMPLING WITH ONSITE ANALYSIS CAPABILITY)
E12 PLANT ANO 1E-3 RMr to 1E+4 1E4 R/hr to 1E+4 NIR PORTABLE N/A N/A NIA MA N/A N/A NA NOTE E2.E8 ENVIRONS 3/3 RMr. PHOTONS RMr, PHOTONS SAMPLNG RADIATION 3r3 1E-3 reenMr to 1E+4 1E-3 raon#v to 1E+2 (PORTABLE radshr. BETA RADIATIONS redsMr, BETA INSTRUMENTATION) AND LOW 4NERGY PHOTONS E13 PLANT ANO 3/3 (ISOTOPIC ANALYSIS) MULTI-CHANNEL WR NONE N/A N/A N/A MA NA WA WA NOTE E1.E8 ENVIRONS GAMMA RAY RADIOACTMTV SPECTROMETER (PORTABLE NSTRUMENTATION)
ATTACHMENT B Page 12 of13 REGULATORY GUIDE 1.97 MATRIX March 1996 RG 197 VARIABLE MATRIX TYPE *E' VARIABLE 3 DNN7DTIOWOUARDICATC)N CATEGORY COMPUTER VARIABLE VARIABLE REQUIREDI REQUIRED AVARA8LE REDU4 LOOP SENSOR LOOP POWER INDICATOR IDI RECORDER IDI INPUT .
O DESCRIPTION COMMITTED RANGE RANGE DANCY O SUPPLY LOCATION LOCATION AVARA8tE EQ SEtSMIC QA REMARKS METEOROLOGY E14 WIND DIRECTION 313 0 to 360 (+A5 ACCURACY ACCURACY WR WIND JOHN DEERE NONE WSAND YES WR WR WR NOTE E1.E9 WITH A DEFLECTION OF DEFLECTION DIRECTION DG &DIST PNL RECORDERI 10 ). STARTING SPEED STARTING 15 mph,0 4 CRP9 4 RELAY HOUSE &
LESS THAN O 4 mee (10 DELAY DISTANCE LESS (BACK4JP) WS/WD mph). DAMPING RATIO THAN 1 METER RECORDER /
GREATER THAN OR CRP 948 EQUAL TO O 4 DELAY (BACKUP)
DISTANCE LESS THAN OR EQUAL TO 2 METERS I
E15 WIND SPEED 3I3 0 to 22 mps (50 mph) +t42 0 6 to 90 mph.0 6 WR WIND SPEED JOHN DEERF NONE WS/WD YES WR N/R N/R NOTE E1.E9 mps (0 $ mph) ACCURACY START, ACCURACY +A DG &DtST PNL RECORDERI 1 FOR SPEEDS LESS THAN 190 or 015 CRP 9 48 RELAY HOUSE & '
2 mps (5 mpht10% FOR mphGREATER OF (BACK4JP) WSAND SPEEDS IN EXCESS OF 2 START 0 6 mph RECORDEP!
mpe(5 mph)WITH A DISTANCE CONSTANT CRP948 i STARTING THRESHOLD 5 FEET. (BACKUP)
OF LESS THAN 0 4 mps l (10 mph) AND A DISTANCE CONSTANT NOT TO EXCEED 2 METERS E16 ESTNATION OF 3/3 BASED ON VERTICAL 4F to +15F. ACCURACY NR DELTA TEMP JOHN DEERE NONE TEMPERATURE YES N/R WR WR NOTE E2.E9 ATMOSPHERIC TEMPERATURE +A .1C/ TOP to BOTTOM DG &DtST PNL RECORDER /
STABILITY OlFFERENCE FROM CRP 946 RELAY HOUSE &
PRNARY (BACK4.lP) TEMPERATURE METEOROLIGICAL RECORDER /
SYSTEM 4C to 10C (-9F CRP948 TO 18F) AND +A 015C (BACKUP)
ACCURACY PER 504AETER INTERVALS (+6 0.3F ACCURACY PER 164f00T INTERVALS) OR ANALOGOUS RANGE FOR ALTERNATIVE STABILITY ESTMATES ACCIDENT SAMPtING CAPABILITY (ANALYSIS CAPA8UTY ON SITE)
E17 PRMARY COOLANT 3I3 GRA8 SAMPLE GRAB SAMPLE N/R GRAB SAMPLE N/A WA WA WA WA N/A WA NOTE E1 AND SUMP (EXCEPT
-GROSS ACTMTY -1 uComito to uCarmi - 1 uchi to 10 uC*nt pH).E8
-GAMMA -(ISOTOPIC ANALYSIS) -(ISOTOPIC ANALYSIS)
SPECTRtN
- BORON CONTENT -O to 1000 ppm -O to 1000 ppm
-CHLORCE -O to 20 pgra -O to 20 ppm CONTENT
- DISSOLVED -O to 2000 cc(STP)AG O to 2000 a:(STP)Ag HYDROGEN OR TOTAL GAS
- DISSOLVED -O to 20 ppm -O to 20 rpm OXYGEN
-pH - 1 to 13 - NONE - - - . - - - - - NOTE E11 E18 CONTAINMENT AIR 3I3 GRAB SAMPLE GRA8 SAMPLE WR GRAB SAMPLE WA N/A WA N/A NA WA WA NOTE E1.E8
-HYDROGEN -O to 10 vok% -O to 10 vok%
CONTENT 0 to 30 voF% FOR 0 to 30 vok% FOR INERTED INERTED CONTAINMENTS 0 to 30 CONTAINMENTS 0 to 30
- OXYGEN CONTENT vol-% vok%
-GAMMA -(ISOTOPIC ANALYSIS) -(ISOTOPIC ANALYSIS)
SPECTRtM
ATTACHMENT B Page 13 or13-REGIAATORY GUIDE 1.97 MATRIX March 1996 -
NOTES.
Et FULLY SATISFIES THE REQUIREMENTS SPECIFIED BY RG 197.
E3 SATISFES THE INTENT OF THE REQUIREMENTS SPECFIED BY RG 197 ON A PLANT SPECIFIC 8 ASIS. REFER TO ATTACHMENT'A', TABLE 2 OF TEXT.
- E3 VERMONT YANKEE HAS A 9 DARK I CONTABBAENT.
E4 THIS PARAMETER IS NOT APPLICABLE. EFFLUENT DISCHARGE IS THROUGH A COMMON VENT. REFER TO ATTACHMENT W, TABLE 2 OF TEXT.
EG ' THIS PARAMETER 18 NOT APPLICABLE. REACTOR SHIELD ANNULUS IS NOT PART OF THE VERidONT YANNEE DESIGN EQ DG.YWELL PURGE /STANSY GAS IS INCLUDED IN THE COamdON VENT DISCHARGE. REFER TO ATTACMAENT W. TABLE 2 OF TEXT.
EF A LOW RANGE OF to lo 10E+7 CPM IS PROVIDED OF THAT RANGE.101010E+6 CPM EQUATES TO 1E-7 to 1E-1 uCWte.A HIGH RANGE OF 1 to 10E+7 mr/Hr EQUATES TO 1E-2 to 1E+5 uCWcc.
E8 THERE IS NO INSTRUMENTATION DIRECTLY ASSOCIATED WITH THIS PARAMETER THE SAMPLE ANALYSIS BS PERFORMED BY THF CHEMISTRY & HEALTH PHYSICS DEPARTMENT.
E9 THERE IS A PRIMARY TOWER AND A BACK4.JP TOWER E10 ENVIRONMENTAL QUALFICATION DOES NOT APPLY. THESE DEVICES ARE LOCATED IN A NON4WtSH ENVIRONMENT (CONTROL ROOld)
Ett THt$ PARAMETER PREVIOUSLY DETERMINED TO PROVIDE INCONCLUSIVE RESULTS. REFER TO ATTACHMENT W. TABLE 2 OF TEXT.
t
)
. _ _ _ _ _ _ _ _ - _ _ _ _ _ , - - , _ . - . . . . ~ . - -. . - - , _ . . - . . - - - , _ . . _ - _ . .,-.._--,..-_..4 _ _ _ _ . _ _ _ _ -_ - _ _ _ _ _ _ _ _ . _
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l ATTACHMENT C l
REGULATORY GUIDE 1.97 DESIGN & QUALIFICATION ;
I l CRITERIA FOR INSTRUMENTATION (
SUMMARY
)
March 1996 I l
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Attachm:nt C RG 1.97 Design & Qualification Criteria For Instrumentation (Summary) March 1996 Design & qualification requirements are stipulated in RG 1.97 Revision 3 (Table 1). Vermont Yankee satisfies those requirements as summarized below. The description applies in accordance with the RG 1.97 Category Vermont Yankee has committed to. Programs and criteria discussed were in place and available for review during the Vermont Yankee RG 1.97 Audit No. 50-271/91-08 dated April 10,1991. Revisions which have taken place did not change the intent of what was audited. Approved exceptions to the RG 1.97 requirements are discussed in Attachment A.
11gm Reauirement Vermont Yankee Position
- 1. Equipment Qualification RG 1.97 Category 1 and selected Category 2 instrumentation are included in the Vermont Yankee Environmental Qualification Program. Not all RG 1.97 Category 2 instrumen'ation is Environmentally Qualified (see exceptions in Attachment A). Equipment located in a Post-accident harsh environment are environmentally qualified. Equipment located in a non-harsh environment do not require environmental qualification, but are qualified for the range of environments in which they will be exposed. The time required to be environmentally qualified is determined in this program.
RG 1.97 Category 3 instrumentation does not require environmental qualification.
- 2. Redundancy RG 1.97 Category 1 instrumentation is required to be redundant. This instrumentation has been evaluated to ensure that a single failure will not result in information ambiguities that could lead operators to defeat or fail to accomplish a required safety function. One or more of the following means is available to access plant status of the affected parameter:
. Cross checking with an independent channel that monitors a different variable bearing a known relationship to the failed monitoring channel.
Perturbing the measured variable to determine the failed channel by observing the response on each instrument.
. Operating procedures.
It should be noted that RG 1.97 Category 1 separation at Vermont Yankee is in accordance with the Vermont Yankee Seoaration Criteria for Reactor Protection. Enaineered Safety Feature and Auxiliary Sucoort Systems-Related Electrical Eauioment and Wirina This is the criteria utilized during the original design and construction of the plant and has been updated to include RG 1.97 considerations. Redundant instrument loops with separate and diverse power supplies are provided. Its use in this application is, therefore, acceptable.
RG 1.97 criteria for redundancy is focused toward classic two train j instrumentation loops. PCIS valves (and associated valve position indication) l have additional criteria to consider. Physical valve redundancy is a design l basis requirement for the Vermont Yankee PCIS. For the purposes of RG 1.97 PCIS valve position indication, four redundancy classes are described:
Page1of4
l Attachment C RG 1.97 Design & Qualification Criteria For Instrumentation (Summary) March 1996 i'
i a. Redundancy Class 1: Two isolation valves in series, each valve being l powered from a different power source. Isolation valves with motor l operators arranged with one in the drywell and one outside the drywell satisfy classic PCIS valve electrical redundancy (including position '
i indicabon). Selected Air Operated Valves (i.e., MSIVs) also satisfy this type of electrical redundancy.
l
- b. Redundancy Class 2: Two redundant process trains with each train
- powered from a different source than the other; each train containing l two isolation valves in series, both valves being powered from the _i same source. These PCIS valve isolation trains have an equally important function to remain operable. In these cases, the physical l redundancy is maintained but the electrical redundancy is satisfied by ;
an attemative means. The process lines involved are small (less than l 2-inches). In these cases: l
. The isolation valves are either normally closed and/or fail closed on loss of air or loss of electrical power. 1
. Redundant trains (parallel process paths supporting the same f i
function) are relied on where the need to maintain functional operability on a loss of one train of electrical power is needed f Each train has a power source redundant to the other, f Physical redundancy is still applied, but both PCIS valves are i powered from a common source.
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- c. Redundancy Class 3: A single process train with two (redundant) valve ;
[ isolation, both valves being powered from a common source. In cases where train redundancy is not required but reliability is desired, j physical redundancy is maintained but electrical redundancy is not. If !
electncal redundancv were applied in these cases, a loss of electrical ;
power in either power source would cause the associated PCIS valve '
to ' fait closed' and the process function would be lost. The process lines involved are small (less than 2-inches). In these cases: j
. The isolation valves are either normally closed and/or fail !
closed on loss of air or loss of electrical power.
. There is no redundant train to support the process function, but the function is not critical to immediate plant operation. ;
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- d. Redundancy Class 4: A single isolation valve in series with a check valve or a single isolation valve. The isolation valve receives motive l power from only one source, the check valve receives no motive power i and provides no position indication. ,
In all four redundancy classes, PCIS valve electrical control power is the same l as the position indication power. This is important to ensure that the operator is not provided ambiguous infomiation. On a loss of electrical power, the valve is either normally closed and/or will fail closed and position indication will be lost. This loss of position indication implies the valves have closed. Single failure criteria provides reasonable assurance that even if one of the PCIS valves failed to close, the second physically redundant valve would close.
- Category 3 instrumentation does not require redundancy.
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Attachm:nt C RG 1.97 Design & Qualification Criteria For Instrumentation (Summary) March 1996
- 3. Power Source Station standby power sources are applied to Category 1 instrumentation.
Standby power typically has battery or Emergency Diesel Generator back-up.
Vermont Yankee credits diverse power sources to meet the intent of battery back-up. This includes the Instrument ac (normally supplied from an Sll power source) and Vital ac (normally supplied from an Si power source) buses.
Vital ac is fed from an uninteruptible power supply (Vital MG-set). On a loss of normal ac supply, the MG-set continues to provide ac power to the Vital bus uninterrupted. On a loss of the Vital MG set, a bus transfer occurs, powering the Vital bus from an Sil source, the same power train as normal Instrument ac.
The momentary interruption in power will be tolerable to the operator.-
Instrument ac has an Si source as its back-up. On a loss of Instrument ac, the bus is automatically transferred to the SI source. The momentary interruption in power will be tolerable to the operator.
Category 2 power sources are highly reliable power sources. (See D25).
Instrumentation meeting this requirement will either be powered from sources equivalent to Category 1 or be diesel backed. Any momentary interruption in power will be tolerable to the operator. The power sources to these inf truments will not be load shed.
Category 3 instrumentation have no specific requirements. They will be provided with a power source commiserate with their importance.
- 4. Channel Availability Selected Category 1 & 2 instrumentation required to be available during normal operation are addressed in the Vermont Yankee Technical Specifications, Section 3.2.6. Time out of service is limited by surveillance requirements with appropriate LCO statements. Category 3 instrumentation have no specific requirements.
- 5. Quality Assurance Quality Assurance (QA) requirements are applied to safety related equipment and selected non-safety related equipment as determined in the Vermont Yankee Safety Classificabon Manual (SCM). For RG 1.g7 instrumentation, all instrumentation determined to be Safety Class requires QA. This would include all Category 1 instruments.
Certain Category 2 variables are not as important as others and, based on evaluation (per the SCM), an items safety classification (Safety Class or Non-Nuclear Safety) is determined. An item determined to be Safety Class will require QA; Other QA requirements (OQA) for Non-Nuclear Safety related items will be determined on a component specific basis (which could include no QA).
Category 3 instrumentation have no specific requirements.
Attachment 'B' indicates instrumentation requiring QA.
- 6. Display and Recording Continuous real time display for Category 1 parameters is provided by Control Room indication (indicators and/or recorders) and computer display. A review of plant-specific requirements indicates that the only pa ameters which require
] trend recording are reactor pressure and reactor water level. However, a variety of additional recording and plant computer inputs are available.
Category 2 and 3 instrumentation is either displayed or recorded continuously or on demand. Many of the signals are provided to the ERFIS computer system. Radioactive effluents and meteorological monitors are continuously recorded and/or provided to ERFIS.
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Att chmant C l RG 1.97 Design & Qualification Criteria l For Instrumentation (Summary) March 1996
- 7. Range The ranges committed to are accomplished using one or more instruments.
Overlapping of ranges is applied as deemed appropriate to monitor the variable.
Where multiple instruments are used to cover the entire range, the l requirements for each instrument can vary from each other. An instrument used to cover the low range might only be relied on for conditions representative of normal operating conditions, where the high range instrument might be required to provide its information during harsh environmental condiiions. In this situation, the requirements applied to the low range instrument would not be as stringent as those applied to the high range I instrument. This philosophy applies to RG 1.97 Categories 1,2, and 3.
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- 8. Equipment l Identification Selected Category 1 and Category 2 instrumentation have a
- red dot" applied in the vicinity of the readout device (in the Control Room). Category 3 instrumentation have no such means of equipment identification attributable to RG 1.97 requirements.
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- 9. Interfaces Electrical isolation (safety class circuits from non-safety class circuits) and cable separation / routing is provided in accordance with the Vermont Yankee Seoaration Criteria for Reactor Protection. Enaineered Safetv Feature and Auxiliary Sucoort Systems-Related Electrical Eauioment and Wirina in this application, circuits are isolated using safety class fuses, safety class circuit breakers (fuse & breaker coordination) and safety class isolators.
- 10. Servicing, Testing, and Calibration Category 1, 2, and 3 instrumentation is maintained commiserate with its importance.
Selected instrumentation is included in the Vermont Yankee Technical Specifications, Section 3.2.6. Surveillance requirements and out of service times are dehned. Other instrumentation is maintained by approved procedures or by other plant approved methods.
. Isolation devices are located in areas accessible post-accident.
. Control of calibration parameters is provided via the procedure change process.
- 11. Human Factors A human factors review and evaluation has been applied to the Control Room design, the panel layouts, and the instrumentation needs of the operator.
Modifications have been completed which incorporate upgrades to address deficiencies in this area.
In most cases, the instrumentation used during normal plant operation has been designated for use post-accident.
- 12. Direct Measurement To the extent practical, direct parameter measurement has been applied.
Indirect measurement is relied on where it is not practical or reasonable to use direct measurement. In those cases, Operator training and experience
~ supplements the use of indirect measurement.
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