ML20138F157

Forwards Responses to Requests for Addl Justification for Exceptions to Reg Guide 1.97,included in 850806 Draft Technical Evaluation rept.Narrow-range Containment Sump Level Has No Intended Accident Monitoring Function

ML20138F157
Person / Time
Site:	Catawba
Issue date:	10/22/1985
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8510250197
Download: ML20138F157 (8)

Text

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DUKE POWER GOMPANY P.O. Box 33189 CHARLOTTE, N.O. 28242 HALB. TUCKER Tzterssown vum r===mewe (704) 373-4 sat

. . - October 22, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Ms. E. G. Adensam, Chief Licensing Branch No. 4 Re: Catawba Nuclear Station Docket Nos. 50-413 and 50-414

Dear Mr. Denton:

Ms. E. G. Adensam's letter of August 6, 1985 transmitted the draft Technical Evaluation Report (TER) on Regulatory Guide 1.97, Rev. 2, for Catawba Units 1 and 2. The TER included eight (8) requests for additional justification for exceptions to Regulatory Guide 1.97. Attached is a response to each item identified in Section 4 of the TER.

Very truly yours, H.2. ~u ,j Hal B. Tucker ROS: sib Attachment cc: Dr. J. Nelson Grace Regional Administrator NRC Resident Inspector U. S. Nuclear Regulatory Commission Catawba Nuclear Station Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Jesse L. Riley Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207 Palmetto Alliance 213515 Devine Street Columbia, South Carolina- 29205 Robert Guild, Esq. ,

P. O. Box 12097 Charleston, South Carolina 29412 pd D lI l 13 PDR

Attachment Page 1 of 5 Catawba Nuclear Station Response to Request for Additional Information:

Emergency Response Capability - Regulatory Guide 1.97 NRC Letter Dated August 6,1985

1. Containment sump water level narrow rense--environmental qualification abould be addressed in accordance with 10 CN 50.49 (section 3.3.4).

Narrow Range Containment Sump Level, has no intended accident or post-accident monitoring function. It is used only for the detection of leakage during normal operation. The purposes listed in Reg. Guide 1.97 for this instrment would be accomplished by the environmentally qualified Wide Range Contaiment Sump Level instrmentation during a design basis event. During an accident, Narrow Range Sump Level serves only as backup indication for the Wide Range instrments.

Narrow Range Sep Level is not considered a key variable for Catawba and a classification of Category 3 is considered adequate. Therefore it is Duke's position that environmental qualification is not required in that this instrment provides no required monitoring function for design basis events that could expose the instrment to a harsh environment.

2. Accessulater tank level and pressure--environmental qualification abould be addressed in accordance with 10 CM 50.49 (section 3.3.7).

The primary function of this instrmentation is to monitor the pre-accident status of the accumulators to assure that this passive safety system is in a ready state to sert e its safety function. The only safety function of the accumulator tank is to empty upon rapid, uncontrolled depressurization of the primary system. No operator actions are based on Accumulator level ar.d pressure instrmentation. Accumulator Tank Level and Pressure are not referenced in any mergency procedure covering design basis events which may cause a harsh environment. De only operator action involving the Accumulator portion of the

. Safety Injection system is to isolate the Accumulator when the primary system pressure is below 1000 psig and primary system conditions indicate that the accumulator inventory is not needed to makeup lost RCS volume. That action is 3 based on system pressure for which fully qualified instrments are provided (see variable sheet A-1, from the original response to RG 1.97). Berefore, it is Duke's position that for Catawba Nuclear Station the Accumulator Tank Level and Pressure are not key variables for aror design basis events which result in a harsh environment. Providing environmental qualification for the post accident in-contalment harsh environment is not required in that the instrments have no post-accident safety function nor grovide any required post accident monitoring function.

Attachment Page 2 of 5 Catawba Nuclear Station Response to Roquest for Additional Information:

Emergency Response Capability - Regulatory Guide 1.97 NRC Letter Dated August 6,1985

3. steen generator pressure >--the licensee abould expand the existing range to meet the recoseendation of Regulatory Guide 1.97 (Section 3.3.12).

Improper pressure information was supplied in Duke's position concerning this variable. he maximte system pressure during the worst postulated lost of heat sink accident is no greater than 1221 psig. This pressure is derived from transient analyses which conservatively model safety valve opening at 1185 psig plus 35 accumulation. The Catawba safety valves are actually expected to begin opening at 1175 psig g 15. This provides s. significant margin ( 80 psig) between the highest steam line pressure and the upper range limit in a design basis event.

Three additional considerations were questioned regarding the sufficiency of the installed upper range limit. (1) Pressure drop across the flow restrictor, (2) pressure instrtmentation accuracy, and (3) tolerance on the safety valve lif t setpoints. he pressure drop across the flow restrictor is minor ( 3 psi).

he normal channel accuracy on the pressure instrunent is calculated to be 44 psi. he lif t tolerance on the safety valves is already accounted for in the 1221 psig figure given above. Duke Power maintains that the range of the installed instrtmentation is adequate for the Catawba design and considers this instrtmentation adequate for the intended monitoring function.

4. Containment sump water temperature--the licensee abould install the instrumentation recommended for this variable or provide information on antisfactory alternate instrimentation (Section 3.3.13).

Containment Sump Water Temperature instrtmentation is not currently installed at Catawba. It is neither recorded nor indicated as it is not required to mitigate the the consequences of a design basis event.

(1) The available NPSH for the Residual Heat Ranoval pumps is conservatively calculated with a sufficient safety margin such that an indication of sump temperature is not required in order to insure adequate NPSH.

(2) No automatic or manual actions are initiated based on this temperature.

(3) Fcr contaiment cooling, Contairment Pressure is the variable of primary importance (see variable sheet B-13) . Alternate indications of containment cooling status is provided by Contaiment Atmosphere Temperature (see variable sheet D-24) and Contairment Spray Flow (variable sheet D-22) .

(4) An alternate temperature indication for long term operation in cold leg recirculation is provided by Residual Heat removal heat exchanger inlet temperature.

Duke considers the existing instrtmentation to be adequate and therefore Contairment Sump Water Temperature instrtmentation need not be added.

Attachment Page 3 of 5 Catawba Nuclear Station Response to Request for Additional Information:

Emergency Response Capability - Regulatory Guide 1.97 NRC Letter Dated August 6,1985

5. Maheup flow-iar-environmental qualification abould be addressed in accordance with 10 CFR 50.49 (Section 3 3.14).

Bere are no design basis accidents that create a harsh environment for this instruentation for which it is required to operate per the plant emergency procedures. Further, the system containing this instrment is automatically bypassed upon an ESF actuation. Makeup Flow thus is not considered a key variable for Catawba and a classification of Category 3 is considered adequate.

Berefore it is Duke's position that environmental qualification is not required in that this instrument provides no required monitoring function for design basis events when the instraent is exposed to a harsh environment.

6. Letdown flow-out- . environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3 3 14).

Bere are no design be. sis accidents that create a harsh environment for this instruentation for which it is required to operate per the plant emergency procedures. Further, the system containing this instrument is automatically isolated upon an ESF actuation. Letdown Flow thus is not considered a key variable for Catawba and a classification of Category 3 is considered adequate.

Berefore it is Duke's position that environmental qualification is not required in that this instraent provides no required monitoring function for design basis events when the instrument is exposed to a harsh environment.

7. Area radiation (radiation exposure rate)-the lioonase abould expand the range to encompass the mari- espected radiation levels (Section 3 3.18).

he area radiation monitoring system at Catawba Nuclear Station is installed with the sole function of monitoring area radiation levels for personnel protection to indicate when normal background levels have been exceeded . Areas in the plant which require operator access following an accident (as listed in the Catawba FSAR Table Q440.441-1) have maximm dose rates which analysis shows are below the full scale reading of the fixed Area Radiation Monitor-ing System and Health Physica portable survey equipment.

Attachment Page 4 of 5 Catawba Nuclear Station Response to Request for Additional Information:

Emergency Response Capability - Regulatory Guide 1.97 NRC Letter Dated August 6,1985

7. (continued)

During accident situations, station Health Physica procedures take precedence and include the use of portable radiation monitoring equipnent. We pocedures require strict access control and have provisions for detailed radiation surveys and for HP personnel escorts for individuals or teams requiring or desiring plant access. These procedures are designed to keep personnel exposures as low as reasonably achievable and below legal limits. Doses above the normal legal limits may be authorized for volunteers if necessary to save lives and/or prevent extensive damage to goperty. Extensive damage to property is considered to result in loss of life or the inability to control or mitigate an accident with assurance that life can be protected. Portable equipment available fcx making radiation surveys is listed in the following section and includes instrtments with ranges to 10 3R/ hr.

It is Duke's position that the existing Area Radiation Monitoring System, the available portable radiation monitoring instrtmentation, and the required Health Physica gocedures are adequate for the intended monitoring function.

8. Plant airborno and area radiation (sampling with onsite analysis, portable instrumentation)-the licensee abould autunit the ranges for these four variables (Section 3.3.19).

The gincipal equipnent used for laboratory analysis of radioactive liquid and gaseous samples are listed below with the type of activity analysis each provides. The lower limit of detection for each type of activity analysis is listed in the Catawba Tech Specs, Tables 4.11-1 and 4.11-2 (attached). Upper measurment limits are not restricted to the range of the equipnent as various methods including dilution, shorter sampling pe.aiods, shorter counting periods and varying tne sample geometry can be used to measure the

r. ore highly radioactive samples.

TYPE OF HSM ACT N 1TI ANAL 13IS Multi-channel gamma analyzer Principal gamma anitters Iodine (131 & 133)

Dissolved and entrained gasses (gamma taitters)

Liquid scintillation counter 'n i tita Alpha-beta low background Cross alpha proportional counterscaler

Attachment Page 5 of 5 q Catawba Nuclear Station

~

Response to Request for Additional Information:

j Emergency Response capability - Regulatory Guide 1.97 NRC Letter Dated August 6,1985 l

8. (oostimmed)

J The primary portable equipment used for making radiation surveys and the nominal ranges for this equipment (from the Catawba FSAR, Section 12.5.2.1.2) are listed below. Also listed are the ranges of the equipment currently in use i at Catawba.

[

EtBEINAL ACTUAL IIS M RAMM8 Mu

Beta-gamma survey 0-100 mR/hr 0-200 mR/hr meters (0eiger counters) 0-2000 mR/hr 0-5 R/hr

~

0-50 R/hr 0-1000 R/hr 0.1-1000 R/hr 10-1000 R/hr 0-50,000 cpm 0-500,000 cpm

.; Beta-gamaa ionization 0 mR/hr-1000 R/hr 0-50 R/hr I chamber survey meters 0-1000 R/hr j Neutron rem dosimeter 0 mrea/hr-5 ree/hr o arma/hr-5rea/hr i

1 I

1 l

• - Nominal ranges are considered the basic range of interest for the intended survey function. At least one instrtment type in each catagory will meet or exceed the listed nominal .*ange.

H - Each instrtment has several selectable range settings. Only the highest range of each instriment is listed here.

t I

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- - , . . . , - - - - - - - - - - - , , - , --,,,_-.~n ~ ., +

l . .'.,,- e l /,

• tz -;

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TABLE 4.11-1 RADI0 ACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM I

LOWER LIMIT MINIMUM OF DETECTION LIQUID RELEASE SAMPLING ANALYSIS TYPE'0F ACTIVITY (LLO)( }

TYPE FREQUENCY FREQUENCY ANALYSIS (pCi/ml) ' ,

i

1. Batch Waste P P Release Each Batch Each Batch Principal Gamma 5x10 7 Tanks (2) Emitters I3) 1-131 1x10 6

. c

. Any tank which  !

discharges P M -

01ssolved and 1x10 6 liquid wastes One Batch /M ^

Entrained Gases i by the liquid - -

(Gamma Emitters)  !

effluent moni-  ;

tor, EMF-49 :P M H-3 1x10.6 Each Batch Composite (4)

Gross Alpha 1x10 7

'P, . Q Sr-89, Sr-90 5x10 8 Each Batch Composite (4)

r. .

Fe-55 , 1x10 8

~

2. Continuous W PrincipalGammal5x107  ;

Releases ( ) Continuous (6) Composite IO) Emitters ( ) -

i F  ; r I-131 1x10.n

a. Conventionall i Dissolved and M M WasteWaterj Treatment ; Grab Sample r EntrainedGasesl1x10-6 Line  ! r [ (Gamma Emitters) {

l N H-3 1x10 8 Continuous (6 Composite (6) e Gross Alpha 1x10 7 l N Sr-89, Sr-90 5x10 8 .

, Continu5us(6) Composite (6) I l

• Fe-55 1x10 8  !

l E l I

CATAWBA - UNIT 1 3/4 11-2 t _

'x. .

1 TABLE 4.11-2 RADI0 ACTIVE GASEOUS WASTE SAMPLING AND ANALYSIS PROGRAM k , ,

E tn HINIMUM LOWER LIMIT OF i

SAMPLING ANALYSIS TYPE OF DETECTION (LLD)( }

7 GASEOUS RELEASE TYPE FREQUENCY FREQUENCY ACTIVI1Y ANALYSIS (pCi/ml) c I 1. Waste Gas Storage P P Principal Gamma Emitters I) 1x10 4 Tank Each Tank .lEa'ch Tank

] Grab Sa'eple t

2. Containment Purge P II P

I3) 1 10

• Each PURGE Each PURGE jPrincipalGammaEmitters(2)

Grab Sample 1x10 6 M fH-3(oxide) i W I3)'I4)

Principal Gamma Emitters (2) 1x10 4

3. Unit Vent

' Grab Sample W( H-3 (oxide) I 1x10 6 PrincipalGammaEmitters(2)l D(3)(S) 1x10 4 w 4. Containment Afr D(3)(5)  ;

D Release and H-3 (oxide) 1x10 6 -

Additio:1, System Grab Sample M g ^

a I7I I-131 1x10 88 I

5. All Release Types Centinuous(6) D as listed in 3. Charcoal ' '

above. Samole I-133 1x10

• Continuous (6) D II Principal Gar.ma Emitters (2) 1x10 "' l r

. Particulate Sample l Gross Alpha Ix10

Continuous (6) H l Composite Par-ticulate Sample .

Sr-89. Sr-90 1x10 88 Continuous (6) Q Composite Par-ticulate Sample j

O Q _

_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _