ML20137U724
| ML20137U724 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 02/06/1986 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 GO1-86-0035, GO1-86-35, NUDOCS 8602190302 | |
| Download: ML20137U724 (13) | |
Text
{{#Wiki_filter:9 Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000 February 6, 1986 G01-86-0035 Docket No. 50-460 Director of Nuclear Reactor Regulation Attention: Mr. J. F. Stolz, Project Director PWR Project Directorate No. 6 Division of PWR Licensing-B U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
NUCLEAR PROJECT NO. 1 RESPONSE TO REQUESTS FOR INFORMATION REGARDING REGULATORY GUIDE 1.97
Reference:
Letter, dated November 19, 1985, E.G. Adensam to D.W.
- Mazur, same subject The reference incit:ded requests for information regarding the implementation of Regulatory Guid= 1.97 for WNP-1.
Our response is provided in the attach-ment to this letter. The reference also invited comments on any misinterpretation of our previous responses. It has become apparent to us that your consultant did not have available the latest information we had submitted at the time of their review. It appears that the consultant reviewed the FSAR material (i.e., Table 7.5-4) as it was initially submitted. This material was significantly changed in Amendment No. I which was docketed on October 29, 1982. The consultant's report is dated May 1985. Additional changes to this material have been made in subsequent amendments to the FSAR. Our response is based upon the FSAR as it exists today;- that is revised through Amendment No. 4. As indicated in the attachment, many of the re-quests for information are resolved by the additional commitments made by the FSAR amendm nts submitted. ( ru&r-G. C. So ensen, Manager Requlatory Programs (280) p0+ t GCS:GLW: AGH:pd 8602190302 860206 PDR ADOCK 05000460 A Attachment cc: Mr. G. Dicks, NRC l Mr. J.R. Lewis, BPA (399) Mr. N.S. Reynolds, BLCPR Mr. H. Kwan, UE&C NRC Doctnent Control Desk d6 2 FDCC 'li
e ATTACHMENT 1.0 Introduction This attachment provides the response to requests for information. regarding the WNP-1 design to implement the guidance of RG 1.97. Based on the comments and requests in the Interim Technical Evaluation Report it is concluded that the NRC Consultant reviewed the initial submittal of FSAR Table 7.5-4. Since the time of that initial submittal there have been four amendments to the FSAR which provided changes to the table that supply most of the information requested. Our response in this attachment is organized as follows: o Additional information and justification (2.0) - Items are addressed in the same order as they are addressed in the Consultant's evaluation report. e Sunrnary of inform'ation to be provided later (3.0) - Based on FSAR Table 7.5-4, Amendment 4, this is a list of information that remains to be provided later, e Summary of deviation from RG 1.97, Rev. 3 - The initial submittal of FSAR Table 7.5-4 was based on Revision 2 of the Regulatory Guide, but the current Table 7.5-4 -( Amendment 4) is based on Revision 3. This is a listing of deviations noted in the current table. Justification for these deviations is addressed by the notes which accompany the table. Any further reviews of the WNP-1 design should be based on the information provided by FSAR Amendment 4. There are some minor changes to be made to the table that will be included in Amendment 5 which is scheduled for submittal in May, 1986. Draft pages to be changed have been included at the end of this attachment to support' reviews that may be scheduled before May 1986. 2.0 Additional Information and Justification This section addresses the request for additional information and justification in the Interim Technical Evaluation Report and the letter.of November 19, 1985 to the Supply System. Items are addressed in the same order as they are addressed in the Consultant's evaluat. ion report. 2.1 _ Type of Variables (3.2) The listing of Type A variables reviewed ',y the Consultant ' differs from the current list in FSAR Table 7.5-4, Amendmert 4. Two variables, steam line radiation and RCS cold leg temper.at >re, have been deleted from the list. The remaining (8) variables are the same as those reviewed, and each is in compliance with category (1) requirements as recommended by RG 1.97, Rev. 3. _1
2.2 Information to be provided later - Washington Public Power Supply System is to provide range and category information for the thirteen listed variables, identify any deviation and justify those identified deviations. (Section 3.3.1)
Response
The thirteen variables are addressed in the order listed in the evaluation report. 1. Steam line radiation - this variable has been deleted as a Type A, and is now listed in FSAR Table 7.5-4 as a Type E: Vent from Steam Generator Safety Relief Valves agd Atmosgheric Dump Valves. It is category (2) and the range provided is 10 to 10 mR/hr. which conforms to the guidance of RG 1.97, Rev. 3. ~9 2. Neutron Flux - Th'is variable is category (1) and the range provided is 10 % to 200% Full Power which exceeds the guidance of RG 1.97, Rev. 3 for range. 3. Coolant level in reactor - RG 1.97, Rev. 3 lists this as " coolant inventory", and the WNP-1 design provides three measurements which meet category (1) requirements: o Reactor vessel head level 15 ft. H O 2 o RC hot leg level - full range 75 ft. H O 2 o RC hot leg level - Narrow range 10ft. H O 2 This conforms to the guidance of RG 1.97, Rev. 3. Refer to FSAR Subsection 1.10.1, response to Item II.F.2 for discussion. 4. Radioacti vity concentration or radiation level in circulating primary coolagt - This variable is category (3 ) and the range provided is 1 mR/hr. to 10 mR/hr. The justification for deviation of category is addressed in FSAR Table 7.5-4, Note 4. 5. Pressurizer heater status - The category remains to be provided later. The range is 0-220 Amp. 6. Quench tank temperature (RC Drain Tank for WNP-1) - This variable is category (3) and the range provided is 50 to 400F. The justification for deviation of range is addressed in FSAR Table 7.5-4, Note 8. 7. Emergency ventilation damper position - All information remains to be provided later. 8. Status of standby power and other energy sources important to safety - Four variables are monitored and all measurements meet category (2) requirements. The ranges and devices monitored are listed in FLAR Tab?a 7.5-4. All conform to the guidance of RG 1.97, Rev. 3. 9. Vent from steam generator safety relief valves or atmospheric dump valves - The variable monitored is steag lin? radiation, and it is category (2) and g the range provided is 10 to 10 mR/hr. which conforms to the guidance of RG 1.97, Rev. 3.
- 10. Radiation exposure rate - FSAR Table 12.3-4 is a tabulation of Area Radiation Monitors provided for WNP-1, and includes the ranges for each.
The justification for deviation of range is provided in FSAR Table 7.5-4, Note 15. This same justification has been reviewed by the NRC Consultant and found to be acceptable. All monitors meet category (3) which conforms to the guidance of RG 1.97, Rev. 3.
- 11. Airborne radiohalogens and particulates - see item (13) below.
- 12. Plant and environs radiation - see item (13) below.
- 13. Plant and environs radioactivity -
Items 11,12 and 13 are monitored by sampling and/or portable instrumenta-ti on provided by the Plant Health Physics / Chemistry Department. The equipment to be utilized will have adequate ranges and analysis capability. All equipment of this type satisfies the requirements for category (3) which conforms to the guidance of RG 1.97, Rev. 3. 2.3 Radiation monitoring instrumentation - environmental qualification should be addressed in accordance with 10CFR50T49. (Section 3.3.2) Response: These items are addressed in the same order as listed in Section 3.3.2 of the evaluation report. 1. Radiation exposure rate (Type C) - The current submittal is based on RG 1.97, Rev. 3 which no longer includes this as 'a Type C variable. See response to item (3) below. 2. Effluent radioactivity - noble gases (Type C) - These measurements are not applicable to WNP-1 because WNP-1 utilizes a common plant vent. These are monitored by the Type E variable at that location - see item (5) below. 3. Radiation exposure rate (Type E) - RG 1.97, Rev. 3 lists these measurements as category (3), and therefore there are no requirements for environmental qualification. The monitors provided by WNP-1 conform to the guidance for category (3). 4. Condenser air removal system exhaust (Type E) - RG 1.97, Rev. 3 lists this measurement as category (2) which includes requirements for environmental qualification. Conformance remains to be addressed later, i l 5. Common plant vent (Type E) - RG 1.97, Rev. 3 lists this measurement as category (2) which includes requirements for environmental qualification. The effluent gaseous monitor (EGM-3) provided by WNP-1 to monitor this l location conforms to the guidance for category (2) including qualification. i 6. All other identified release points (Type E) - RG 1.97, Rev. 3 lists this measurement as category (2) wiiich includes requirements for environmental qualification. For the WNP-1 design there is one other release point: Gland Steam Exhaust that is monitored by an effluent gaseous monitor (EGM-5). Conformance remains to be addressed later. [ c t 1.
2.4 Heat removal by containment fan heat removal system - Washington Public Power Supply System should identify the method of monitor.ing heat removal by the containment fan heat removal system or justify why it is not required. (Section 3.3.5) Response: As discussed in FSAR Section 6.2, containment heat removal for loss of coolant and main steam line break accidents is by operation of the Containment Spray System and the Decay Heat Removal System. The design analysis in Section 6.2.2 establishes that adequate heat removal is provided without reliance on the containment fan heat removal system. 2.5 Make up flow-in - environment qualification should be addressed in accordance with 10CFR50 49 (section 3.3.6)- Response: The measurement provided meets the requirements for category (3) which do not require environmental qualification. The justification for this deviation of category is ad. dressed in FSAR Table 7.5-4, Note 12. This variable is not required for the mitigation of an accident, and during design basis events the Make-up System is isolated. 2.6 Letdown flow-out - environmental qualification should be addrested in accordance with 100FR50 49- (Section 3.3.7) Response: The measurement provided meets the requirements for category (3) which do not require environmental qualification. The justification for this deviation of category is addressed in FSAR Table 7.5-4, Note 13. This variable is not required for the mitigation of an accident, and during design basis events the letdown line is isolated. 2.7 Volume control tank level - environmental qualification should be addressed in accordance with 10CFR5'C 49~. (Section 3.3.8)
Response
The volume control tank is the Make-up tank in the WNP-1 design. The measurement provided meets the requirements for category (3) which do not require environmental qualification. The justification for this deviation of category is addressed in FSAR Table 7.5-4, Note 14. - This varii. Die is not required for th~e mitigation of an accident, and during design basis events the Make-up tank outlet is isolated. ~ 9 .~ t 3.0 Summary of Information To Be Provided Later This section provides a list of information which will be provided later. This information.is not yet available because of circumstances associated with the construction delay of WNP-1. Variable Information To Be Provided Later e Pressurizer Category. Design includes indication of Heater Status heater current, but the category to be provided is not resolved. e Emergency Venti 1ation All Information. Damper Position e Condenser Air Category and power supply Removal System Exhaust i e Vent from Steam Power Supply Generator Safety Relief Valves or Atmos. Dump Valves e Gland Steam Category and power supply Exhaust e Safety / Relief All information for Code Safety Valves. Valve Positions 4 J k ? e,, - - +- m
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l 1 4.0 Summary of Deviation From RG 1.97, Rev. 3 This section provides a list of deviation in the design of WNP-1 instrumentation as compared with the guidance of RG 1.97, Rev. 3. Although the WNP-1 design exceeds the recommendations for range, power supply and/or indication for many of the variables, the following list is limited to those which are less than the recommendations. The basis for each deviation is addressed in the notes which follow Table 7.5-4, Amendment 4 of the FSAR. Variable Deviation e Pressurizer Level Range. e RCS Soluable Boron Range for on-line display only. concentration Grab sample facility conforms to guidance. e Radioactivity Concentration Category. or Radiation Level in Circulating ?rimary Coolant e Accumulator Tank Range. This deviatica has been addressed Level by the NRC Consultant and found to be acceptable. e RC Drain Tank Range. Temperature o Main Feedwater ' Flow Range. This deviation has been addressed by the _ NRC Consultant and found to be acceptable. e Containment Sump Category. Water Temperature o Make-up Flow-In
- Category, e Letdown Flow-Out Category e Make-up Tank Level Category and range.
e Radiation Exposure Rate Range. This deviation has been addressed by the NRC Consultant and found to be acceptable. - - -
= p 9 g TABLE 7.5-4 (Sheet 3 of 43) CONFORMANCE TO REGULATORY CUIDE 1.97, REV. 3 WNP-1 INSTRUMENTATION PROVIDED Variable Recommended Sensor Power Indicator Recorder Per RG 1.97, Rev. 3 Category Range Tag No. Supply Panel / Tag No. Panel / Tag No. Comments Type A (Plant Specific) - RC Hot Leg 1 50-750 F RCS-TE-3A4 IE SCI-1 SCI-3 Conforms to Water Temp. (Hot Leg A) VPN A RCS-TI-3A3 RCS-TR-3A3-guidance. 50-700 F RCS-TE-3B4 lE SCI-l SCI-3 (Hot Leg B) VPN B RCS-TI-3B3 RCS-TR-3B3 RCS-TE-3A2 IE CRT CRT (Hot Leg A) VPN B 7 w -RCS-TE-3B2 lE CRT CRT (Hot Leg B) VPN A - RCS Pressure 1 0-3000 psig RCS-PT-16-1 lE SCI-l CRT Conforms to 0-3000 psig VPN'A RCS-PI-16-3 guidance. RCS-PT-16-2 lE SCI-l SCI-3' r VPN B RCS-PI-16-4 RCS-PR-16 Conforms to E - Pressurizer 1 0-400 in. RCS-LT-14-5 lE SCI-l CRT Level VFN A RCS-LI-14-3 guidance,H[ [ MN- . R. Bottom to Top RCS-LT-14-6 IE SCI-l SCI-3 See Note 1 mg VPN B RCS-LI-14-4 RCS-LR-14-2 g ie 1 't
w TABLE 7.5-4 (Sheet 10 of 43) WNP-1 INSTRUMENTATION PROVIDED Variable Recommended Sensor Power Indicator Recorder Per RG 1.97. Rev. 3 Category Range Tag No. Supply Panel / Tag No. Panel / Tag No. Comments Type B (Continued) - Core Exit Temp. 1E CRT SCI-3 Quadrant 3 (Cont'd) VPN-B IMS-TR-3B2 (continued) lE CRT SCI-3 Quadrant 4 VPN A IMS-TR-4A1 lE CRT SCI-3 Conforms to VPN A IMS-TR-4A2 guidance. e $4 IE CRT SCI-3 VPN B IMS-TR-4B1 ~ IE CRT SCI-3 VPN B IMS-TR-4B2 - Coolant Inventory 1 Reactor Vessel RCS-LT-24A lE SCI-l C2I SCZ-3 Conforms to Head Level (Hot Leg A) VPN A RCS-LI-24A RC S -LR A guidance, o Bottom of hot 0-15 ft. H90 leg to top of RCS-LT-24B IE SCI-1 CRT Refer to Sub-vessel. (Hot Leg B) VPN B RCS-LI-24B section 1.10.1. response to Item z{g o Category 1 RC Hot Leg RCS-LT-22A lE SCI-l CRT II.F.2 for dis-Level-Full (Hot Leg A) VPN A RCS-LI-22A
- cussion, gg Range o c.
0-75 ft. H;0 RCS-LT-22B lE SCI-l CRT (Hot Leg B) VPN B RCS-LI-22B C5 $v RC Hot Leg RCS-LT-26A lE PCC-LW CRT Level-(Hot Leg A) VPN A RCS-LI-26A Narrow Range HO RCS-LT-26B 1E. PCC-LW CRT 0-10 ft. 2 (Hot Leg B) VPN B RCS-LI-26B i G G G
-.- -. -. _ -_.=. -. O O O~ TABLE 7.5-4 (Sheet 17 of 43) WNP-1 INSTRUMENTATION PROVIDED Variable Recommended Sensor Power Indicator Recorder Per RG 1.97,' Rev. 3 Category Range Tag No. Supply Panel / Tag No. Panel / Tag No. Comments Type D - DHR System Flow 2 0 to 7000 GPM DHR-FT-2A 1E SCI-l None Conforms to VPN A DHR-FI-2A guidance. o O to 110% design flow (Design flow DHR-FT-2B IE SCI-1 None is 5000 GPM) VPN B DHR-FI-2B o Category 2 - DHR Heat Exchanger 2 40 F to 400 F DHR-TE-4A 1E SCI-I None Conforms to Outlet Temperature VPN A DHR-TI-4A gtidance. W _ o 40 F to 350 F DDR-TE-4B IE SCI-l None VPN B DHR-TI-4B o Category 2 - Core Flood Tank 2 0 to 21 ft. CFS-LT-3Al IE SCI-l' None' Conforms to (Accumulator) (Tank 1A) VPN A CFS-LI-3Al guidance, M Level e r==. eNotek CFS-LT-3A2 IE SCI-l None o 10% to 90% Volume (Tank 1A) VPN B CFS-LI-3A2 5 o Category 2 CFS-LT-3B1 lE SCI-l None $7 (Tank 2B) VPN A CFS-LI-3B1 e a& CFS-LT-3B2 1E SCI-1' None (Tank 2B) VPN B CFS-LI-3B2 +c 4 O
.( TABLE 7.5-4 (Sheet 22 of 43) WNP-1 INSTRUMENTATION PROVIDED Variable Recommended Sensor Power Indicator Recorder Per RG 1.97, Rev. 3 Category Range Tag No. Supply Panel / Tag No. Panel / Tag No. -Comments Type D (Continued) - RC Drain Tank 3 0 to 100% DFR-LT-2605 APN X PCC-RS None Conforms to Level (Quench DFR-LI-2605 guidance. Tank) o Bottom to Top o Category 3 - RC Drain Tank 3 50 to 400 F DFR-TE-2046 APN X PCC-RS None Conforms to N' Temperature DFR-TI-2046 guidance,J e *# g o 50 F to 750 F b 8. o Category 3 - RC Drain Tant 3 0 to 100 psig DFR-PT-2616 APN X PCC-RS None Conforms to Pressure DFR-PI-2616 guidance. o O to Design Pressure y o Category 3 g.g $s 2- - Steam Generator 1 0-600 in. See previous list-g" Level ing for Type A
- variable, o Category 1 4
G G G
l 't e e S. k,_ TABLE 7.5-4 (Sheet 33 of 43) WNP-1 INSTRUMENTATION PROVIDEC Variable Recommended Sensor Power Indicator Recorder Per RG 1.97, Rev. 3 Category Range Tag No. Supply Panel / Tag No. Panel / Tag No. Comments Type E - Containment Area 1 10-2 R/hr See previous list-Radiation - High to ing for Type C Range 107 R/hr
- variable, o 1 R/hr to 107 R/hr o Category 1 m5 m4
- Radiation Exposure 3 Refer to Refer to APN X CRT CRT Conforms to y8 Rate Table 12.3-4 Table 12.3-4 guidance f #sAI ~ y o 10-1 R/hr to 15 104 R/hr o Category 3 - Containment or WNP-1 design has Purge Effluent common plant vent. z - Reactor Shield Not in design. O g Building Annulus Om $ E. - Auxiliary Building WNP-1 design has S common plant vent. 5 Er $k 4
r TABLE 7.5-4 (Sheet 24 of 43) WNP-1 INSTRUMENTATION PROVIDED Variable Recommended Sensor Power Indicator Recorder Per RG 1.97, Rev. 3 Category Range Tag No. Supply Panel / Tag No. Panel / Tag No. Comments Type D (Continued) - Main Feedwater Flow 3 0 to 9 x lb6 FWS-FT-2Al APN X NSP PCC-CS Con fo rms to lb /' e x (Loop A) Fb'S-FI-2 A FWS-FR-19A guidance) o O to 110% Design ( Inp'u t (Input ~ d'**1I
- Flow Selectable)
S e lec
- tab le)
Category 3 (0 to 109% FWS-FT-2A2 APN X o design flow) (Loop A) c FWS-FT-2B1 APN X NSP PCC-CS (Loop B) FWS-FI-2B FWS-FR-19B y8 (Input (Input Selectable) Selectable) FWS-FT-2B2 APN X (Loop B) - Auxiliary Feedwater 1 0-1600 CPM FWA-FT-4010 lE PCC-LS SCI-3 Conforms to Flow (To SG-1) VPN A FWA-FI-4010 FWA-FR-4010
- guidance, o 0 to 110% Design FWA-FT-6793 lE PCC-LS CRT Flow (To SG-2)
VPN A FWA-FI-6793 p $W o Category 1 FWA-FT-4008 lE PCC-LS SCI-3 mg g.g (To SG-2) VPN B FWA-FI-4008 FWA-FR-4008 h FWA-FT-6794 lE PCC-LS CRT (To SG-1) VPN B FWA-FI-6794 c c-4 I h bd =}}