ML20116N695

Provides Supplemental Responses to Five Open Items Identified in 850227 SER in Response to Rev 2 to Reg Guide 1.97,including Addl Justification for Adequacy of Instrumentation Described in

ML20116N695
Person / Time
Site:	Hatch
Issue date:	04/29/1985
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NED-85-306, NUDOCS 8505070315
Download: ML20116N695 (5)

Text

Georgia Power Company -

333 P5dmont Avenue 1-

.. Attanta.Georg:a 30308 g

Telephone 404 S26-6526 Maing Address:

Post office Box 4545 Atlanta. Georgia 30302 Georgia Power Ma$a e x! ear Engineenng and Chief Nuclear Engineer NED-85J-306 1571N April 29, 1985 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.

20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 RESPONSE TO REGULATORY GUIDE 1.97 SER OPEN ITEMS Gentlemen:

The subject NRC Safety Evaluation Report (SER) dated February 27,-1985, concluded that, except for five exceptions, Georgia Power Company (GPC) has provided an acceptable response to NRC guidance contained in Regulatory Guide 1.97, Revision 2.

This letter provides supplemental GPC responses to the five open items, including additional justification for the adequacy of instrumentation described in our Regulatory. Guide 1.97 comparison dated February 21, 1984.

Exceptions from the SER are restated, followed by the GPC response.

Excention:

1.

" Neutron flux--the licensee's present instrumentation is acceptable' on an interim basis until Category 1 instrumentation is developed and installed (Section 3.3.1)."

Response

Section VI B of our comparison dated February 21, 1984 provided detailed justification for Category 3 classification of Variable B.1, Neutron

. Flux.

The SER Section 3.1.1, Neutron Flux.does not.. identify any objection to the GPC arguments, but concludes, with no apparent basis, that the licensee should "... install Category 1. instrumentation when it becomes available."

15505070315 850429

~~

gh PDR ADOCM 05000321

(

Q F.

PDR a

Georgia Power 1 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors-Branch No. 4 April 29, 1985 Page Two GPC continues to monitor industry development of improved neutron monitoring eoulpment.

We will evaluate installation of improved eoulpment when available, _but we cannot commit to replacement of existing reliable eoulpment with eoulpment' of unproven design._ As demonstrated in our February 21,'

1984 comparison of existing instrumentation to the Regulatory Guide, Category 3 instrumentation is provided for this variable, and is acceptable for its application at Plant Hatch.

I Exception:

2.

" Coolant level in the reactor-the licensee should justify the lack of redundant _-instrumentation above the normal operating range (Section 3.3.3)."

Response

Reactor Pressure Vessel (RPV) water level indication is recuired to assure that the reactor core -remains covered and. that the water level stays _below the bottom of the main steam lines to avoid water carry-over which could damage the turbines which drive-the high pressure make-up pumps.

Turbine protection is provided by redundant high water level trips which isolate the turbines at 58" in the RPV.

These high level trips terminate injection into the vessel and prevent the RPV level from exceeding 58" while pressurized.

Once the reactor is depressurized and make-up is provided by motor driven pumps, water level above the operating range is not considered. an emergency condition.

Post accident, the operator will maintain water level using the cualified and redundant-instrumentation provided for the operating _ range.

The non-redundant instrumentation for levels above 60" is intended for use only during refueling when water level is raised to flood the refueling cavity.

Therefore, OPC believes that the range of RPV level monitored by-redundant instrumentation meets the intent of the Regulatory Guide, and that provision of redundant level indication for the RPV level range' above 60" would not enhance the level of safety currently provided.

Based on the above it is our. position that the instrumentation provided meets both the regulatory reouirements that were the basis' for licensing, and the intent of Regulatory Guide 1.97.

Exception:

3.

" Radiation exposure rate-the licensee should. show that the-

. ~ -

m GeorgiaPower A -

Director.of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 April 29,- 1985 Page Three instrumentation. for this variable has ranges that encompass the expected radiation levels in its locations (Section 3.3.6)."

Response

The local area radiation monitors provided at Plant Hatch provide local area activity indication for personnel protection, release detection and assessment, and long-term release surveillance.

The ranges provided do not encompass the expected radiation levels following an accident involving severe core damage.

These instruments alarm in the main control room on a slight increase in local activity,.and provide local in' ication and alarm functions as well. Radiological control. procedures d

implemented in the plant recuire that the health physics department survey all areas alarmed, in addition to routine area surveys.

The plant health physics department controls personnel access into areas based on both routine and pre-access - surveys.. Need for access to any area of the secondary containment is not anticipated for at least 30.

days post-accident.

Prior to any post-accident-personnel access, portable radiation survey instruments and the results of secondary containment atmosphere sampling would be utilized to assess the potential-dose to personnel.-

In the event that the radiation levels exceed the ranges covered by this instrumentation, release detection and assessment, and long term release surveillance can be accomplished by portable survey instruments, atmosphere sampling and by monitors at the plant. release points (main stack and reactor building vents).

It is Georgia Power Company's position - that, based on the above, the existing radiation monitors, in conjunction' with plant radiological control procedures, meet the intent of i Regulatory Guide 'l.97.

No upgrade of this instrumentation is currently planned.

Exception:

4.

." Suppression pool water. temperature--environmental cualification, for the non-oualified channels, should be addressed.in accordance with 10 CFR 50.49; the ' licensee should provide an analysis that.

addressas the = seismic oualification programs that were the basis for. plant licensing, or provide a commitment-to upgrade the instrumentation (Section 3.3.8)."

Response

This ' instrumentation is ' included on the NRC-approved list of eoulpment 700775

.. ~.

.o

. '7 e

1 Georgia Pb ver

' : Director ofJNuclear Reactor Regulation.

" LAttentioni :Mr. John F. Stolz, Chief

~ Operating Reactors Branch No. 4-April 29,::1985 4

Page Four. _

y

. to -be L environmentally qualified in ' accordance with 10 tCFR 50.49.

In Jregard to seismic' qualification,' the' four temperature ' elements for Hatch J Unit -2 (2T48-N009A-D) were; qualified ' to the -seismic criterion of (IEEE i344-1971

.The. four temperature l elements for Hatch Unit.1 -(T48-N009A-D)

~

!were - also qualified ;to the seismic criterion of - IEEE - 344-1971,~.but

~

documentation ' to support 4 this. qualification-is not available in : our

= files. cThe-manufacturer has been contacted for the purpose of ebtaining replacement < documentation to substantiate the seismic qualification.

LThese qualifications comply with :the qualification program; used as' the

,. basis for PlanteHatch licensing.

, Based on' - the above,a it is our position.that currently installed

~

i equipment meets the intent of the guidance contained in Regulatory Guide-

[

1. 97.-

Exception:

l 5.

" Cooling water flow to ESF : system components--the! licensee.should upgrade thel alternate'- instrumentation, plant-service Jwater. output l

pressure, to.' Category 2, and provide the information required in Section 6.2 of NUREG-0737, Supplement 1.(Section 3.3.~12)".-

Response

4

~

Based on characteristics and use :of the; service _. water system parameters

-indicated --in.the ' main Econtrol room,1 it Lisf ouri position.that-the F

indication currently provided meets the11ntent of Regulatory Guide.1.97 as described below.

~

~

i I

The plant service water system is reldcd with remotefpump-running and

o temonstrate : that i the ? system.is

. multiple. system pre.ssure indicatrn ein operation and performing ea eA & Proper" system. operation: relies 1

Lonly on' passive components. wrt t.M m :eption of the ' service; water. pumps -

and remo_tely i operated 91 solation l valves.

Individual ' engineered. safety-

features 7(ESF) service waterf.. loads a are

provided1 with ? valve ' position, room temperature 1 indication,' Land local 1 temperature : indications. 11f _the 6:

~

Jservice water. pumps: are operating, Eand the. individualL ESF dcooling Lload :

1

isolation valves: are: open~, the ; cooling system will function?as designed -

and ? cani be : verified ninithe control. rooms by' pump t rurning Lindications,.

t ivalveiposition?indicationsFmultiple pressureaindicatiens,2 andiby' room j

? temperature L.: indications.s c A) ' system :leakn will? be J detected ? by l Lthe 1 equipment:( T nd: floorJdrainage. system instrumentation:: and,by ?roomi a

~ tenperature l indications.

Flow 4 indication is not?provided and Jw~ould Jnoti

.j be the preferred lmeans(of; verifying;systemLoperation as discussed inlthe eq

following'paragraphi

~

t-f

.r k

i.

?'

((

700h$( ^

• f

[4 -,

^

i/.

Ul, E,-

1 i J J, 4.

+

J a- - - - -

^

~..

j -

iGeorgihPowerb Director of Nuclear Reactor Regulation Attention:;;Mr. John F. Stolz, Chief 10perating Reactors Branch No. 4 iApril 29,-1985

Page Five Symptom-oriented emergency ; operating procedures. (EOPs) currently being ilmplemented at Plant Hatch provide.for t operator confirmation that the-service ~ water ' system is : operating ' properly,- and provide-specific instruction if proper : operation is not' confirmed.

The. operator. is f

directed to check isolation valve status and two pressure instruments:

'1) pump.-discharge pressure, Land '2) system pressure at the inlet to the'

. turbine.: building.

_The 11atter;-indication is downstream of ' the ESF cooling : loads,. and will -indicate both loss of flow ---(i.e.,

due l to pump failure -or' blockage upstream of tthat indication). or a - system break.

LPunp - running Jindications and valve - positions can" be-used to confirm L system' operation ^in the. event : of loss.of: pressure indications.. The actions called-- out in 1the < new E0 Psi provide an appropriate check of i

system operation.

- ' Adequacy. ofi control e room instrumentation will be addressed during' a detailed: control room' design review (DCRDR). described 7. in GPC submittal NED-84-556 Edated October ;23, fl984.

_ Adequacy of 'this Jinstrumentation

~

.will' receive speciali attention; during that review.

We will address the need to Jupgrade1 service water instrumentation during the.. assessment

phasel-;of the DCRDR.

In. the ; interim, we' will' continue to' rely on

Category - 3. pressure. instrumentation as '.. described 'in < our - comparison document dated February 21, 1984. 'Noiupgrades. based on the guidance of Regulatory Guide 1.97 are currently beingLconsidered.-

'Please contact this office if you have any questions or comments..

Very.truly'yours,'

$f4Lg L. T.'Gucwa-PLS/mb

(

xc:

H. C.; Nix, Jr. _.....

f LNRC Regional Administrator; I?

Senior. Resident Inspector I

r -

I3 7

j y

h.

' ~

n-r _ -(

1 roons [

a..

_ a.-

.