ML20148D650
| ML20148D650 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/21/1988 |
| From: | Ken Wilson FLORIDA POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 3FO388-18, TAC-51083, NUDOCS 8803240132 | |
| Download: ML20148D650 (85) | |
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gen ;,e seee Florida Power C 0 R P o R AT IO N March 21,1988 3F0388-18 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NUREG 0737, Supplement 1 Regulatory Guide 1.97 (TAC 51083)
Dear Sir:
Florida Power Corporation (FPC) is submitting a revised set of R.G.
1.97 variable sheets, which were originally sent to you with our August 21, 1984 transmittal. Revisions include equipment modifications that were made in Refuel VI which ended January 10, 1988.
The status that is shown on the attached variable sheets is considered complete with the exception of the following items which are scheduled to be complated by the end of Refuel VII presently scheduled to begin in Fall 1989, or as otherwise stated.
1.
FPC will install environmentally qualified current measurement instrumentation to monitor the status of the pressurizec heaters during an emergency.
2.
I'P C will install valve position indication for the Main Steam Safety / Relief Valves and the Atmospheric Dump Valves.
3.
FPC is still planning to complete the "on demand" displays for the Reactor Building High Range Radiation Monitors and the sump level variables into Recall by September 1988.
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Otk (813) 866-5151 St. Petersburg, Florida 33733 P.O. Box 14042 GENERAL OFFICE mi Tnirtv.inurth street south s
i S803240132 680321 A Florida Prog,ress Company PDR ADOCK 05000302 o
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' March 21,1988 3F0388-18 Page 2 Sincerely, b
K. R. Wilson, ' Manager Nuclear Licensing Enclosure KRW/ EMG/sde xc: Dr. J. Nelson Grace Regional Administrator, Region II Mr. T. F. Stetka Senior Resident Inspector I
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01 Date:
2/10/88 TABy?. OF CONTENTS VARIABLE PAGE Neutron Flux 01 Rev. 01 Control Rod Position 02 Rev. 01 RCS Soluble Boron Content 03 RCS Hot ieg Water Temperature 04 Rev. 01 RCS Cold '.e: Water Temperature 05 RCS Presst.cs 06 Rev. 01 Reacter Vessel Level 07 Rev. 01 Degrees of Subcooling 08 Rev. 01 Containment Sump Water Level (Narrow Range) 09 Containment Water Level (Flood Range) 10 Rev. 01 Containment Isolation Valve Position (Manual Valves) llA Containment Isolation Valve Position (Automatic Valves) llB Rev. 01 Core Exit Temperature 12 Rev. 01 RCS Radioactivity Concentration 13 Containment Hydrogen Concentration 14 Containment Pressure 15 Rev. 01 RHR System Flow (Decay Heat) 16 RHR Heat Exchanger Outlet Temperature (Decay Heat) 17 Rev. 01 Accumulator Tank Level (Core Flood Tank) 18A Rev. 01 Accumulator Tank Pressure (Core Flood Tank) 18B Rev. 01 Accumulator Isolation Valve Position (Core Flood Tank) 19 Rev. 01 Boric Acid Charging Flow 20 Flow in HPI System 21 Flow in LPI System 22 Refueling Water Storage Tank Level (Borated Water Storage Tank) 23 Rev. 02 Reactor Coolant Pump Status 24 Rev. 01 Primary System Safety Relief Valve Position or Flow Through 25 or Pressure in Relief Lines Pressuriter Level 26 Rev. 02 Pressurizer Heater Status 27 Rev. 02 Quench Tank Level (Reactor Coolant Drain Tank) 28 Quench Tank Temperature (Reactor Coolant Drain Tank) 29 Rev. 01 Quench Tank Pressure (Reactor Coolant Drain Tank) 30 Steam Generator Level 31 Rev. 01 Steam Generator Pressure 32 Rev. 01 Main Steam Safety Relief Valve Position 33 Rev. 02 Main Feedwater Flow 34 Auxiliary Feedwater Flow 35 Rev. 01 Condensate Storage Tank Water Level (Emergency Feedwater Tank) 36 Rev. 01 37 Rev. 01 Containment Spray Flow Heat Removal by the Containment Fan Heat Removal System 38 Rev. 01 39 Rev. 01 Containment Atmosphere Temperature 40 Rev. 01 Containment Sump Water Temperature Make-up Flow - In 41 Rev. 01 Letdown Flow - Out 42 Rev. 01 Volume Control Tank Level (Makeup Tank) 43 Rev. 01 44 Rev. 01 Component Cooling Water Temperature to ESF Systems Peck (TblCont)DN104-2 i
Rev: 01 Date:
2/10/88 TABLE OF CONTENTS (Cont'd)
VARIABLE PAGE Component Cooling Water Flow to ESF_ Systems (Level) 45 Rev.101 High-Level Radioactive Liquid Tank Level 46 Rev. 01 Radioactive Gas Hold-up Tank Pressure (Waste Decay Tanks) 47 Rev. 01 Emergency Ventilation Damper Position-48 Rev. 01 Status of Standby Power 49 Rev. 01 Containment Area Radiation - High Range 50 Rev. 01 Radiation Exposure Rate-Inside Buildings or Areas Where 51 Rev. 01 Access is Required to Service Equipment Important to Safety or which are in Direct Conta'ct with Primary Containment where Penetrations and Hatches are Locates Containment or Purge Effluent, Noble Gas 52 Rev. 01 Reactor Shield Building Annulus 53 Auxiliary Building, Noble Gas 54 Rev. 01 Condenser Air Removal System Exhaust 55 Rev. 01 Common Plant Vent 56 Vent from Safety Valves or Atmospheric Dump Valves 57 Rev. 03 All Other Identified Release Points 58 All Identified Plant Release Points Particulates and Halogens 59 Airborne Radio Halogens and Particulates 60 Rev. 01 Plant and Environs Radiation, Portable' Instrumentation 61 Rev. 01 Plant and Environs Radioactivity 62 Wind Direction 63 Wind Speed 64 Estimation of Atmospheric Stability 65 Rev. 01 Primary Coolant and Sump (Grab Sample) - Gross Activity 66 Rev. 01 Primary Coolant and Sump (Grab Sample) - Gamma Spectrum 67 Primary Coolant and Sump (Grab Sample) - Boron Content 68 Primary Coolant and Sump (Grab Sample) - Chloride Content 69 i
Primary Coolant and Sump (Grab Sample) - Dissolved Hydrogen 70 Total Gas Primary Coolant and Sump (Grab Sample) - Dissolved Oxygen 71 Primary Coolant and Sump (Grab Sample) - pH 72 Primary Coolant and Sump (Grab Sample)
Hydrogen Content 73
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Containment Air (Grab Sample) - Oxygen Content 74 Primary Coolant and Sump (Grab Sample) - Gamma Spectrum 75 l
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U CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 POSITION DOCUMENT I.
INTRODUCTION Supplement 1 to NUREG 0737, Requirements for Emergency Response Capability (Generic Letter No. 82-33), dated December 17, 1982 required Florida Power Corporation (FPC) to submit a report describing how it meets the requirements of Regulatory Guide 1.97 (Rev. 2) including supporting technical justification or alterna-K tives for any proposed deviations.
As stated in the cover letter to, and sections 6.1.B and 6.2 of Supplement 1 to NUREG 0737, FPC is using the referenced document as guidance.
This allows FPC the flexibility to tailor the guidance given to the specific requirements of Crystal River 3 and to take exception to some of the requirements as long as deviations are shown and supporting justification or alternatives are provided.
This document provides the requested information and is organized to be consistent with Table 3 (PWR Variables) of R.C.
1.97, (Rev.
3).
Revision 3 of the Regulatory Guide was used as opposed to Revision 2 to more accurately reflect the current NRC guidance on post accident monitoring.
II.
FORMAT Each page of the Compliance Table is devoted to a single R.G.
1.97 variable and a comparison of its present status at CR3 to the guidance given in R.G. 1.97, Rev. 3.
On the Compliance Table, where certain requirements are not applic-able to a particular variable due to its assigned category and therefore those requirements are not met, a response of "No, not required" will be found for that requirement.
If CR3 meets the a
requirement, regardless of whether or not it's required by its assigned category, a response of "Yes, Complies" will be found.
For each variable, the following heading and contained information will be found on the Compliance Table.
A.
VARIABLE This is the name of the variable as found in R.C.
1.97.
If a different nomenclature is utilized at CR 3, it will be contained in parenthesis.
RegGuide(Pos. Doc.)ND48-3 1
B.
TYPE AND CATEGORY The variables identified are divided into 5 types in actor-dance with Regulatory Guide 1.97.
The definition of each type is as follows:
1.
Type A Those variables which provide the primary information required to permit the control room operators to take specific manual actions for which no automatic control is provided, and that are required for a safety system to accomplish its safety function for design basis accident scenarios.
Type A variables are not specified in Regulatory Guide 1.97.
They are plant specific and must be selected based on a review of Emergency Operating Procedures to identify information essential for the direct accomplishment of specified safety functions.
As a result of a review of the CR2 Emergency Operating Procedures, the following variables were identified as Type A:
RCS Hot Leg Temperature RCS Pressure Borated Water Storage Tank Level Steam Generator Level Steam Generator Pressure 2.
Type B - These variables provide information to indicate whether plant safety functions are being accomplished.
Plant safety functions are defined as:
reactivity control, core cooling, maintaining reactor coolant system integrity, and maintaining containment integrity.
3.
Type C - These variables provide information to indicate the potential for breach or the actual breach of barriers to fission product release.
The barriers are defined as:
fuel cladding, primary coolant pressure boundary, and containment.
4.
Type D - These variables provide information to indicate the operation of individual safety systems and other a
important systems.
These variables help the operator l
make appropriate decisions in using the individual l
systems in mitigating the consequences of an accident.
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5.
Type E-These variables provide information for use in determining the magnitude of the release of radioactive materials and for use in assessing the consequences of such releases.
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l RegGuide(Pos. Doc.)ND48-3 l
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The variable type listed on the Compliance Table is in accor-dance with Table 3 of Regulatory Guide 1.97.
In accordance with Regulatory Guide 1.97 each variable is assigned to one of three separate categories that provide a graded approach to the ' requirements depending on the safety importance of the measurement of a specific variable.
Category 1 provides the most stringent requirements and is intended for key variables.
Category 2 provides less strin-gent requirements and generally applies to instrumentation designated for indicating system operating status.
Category 3 is intended to provide requirements that will ensure that high-quality off-the shelf instrumentation is obtained and appliss to backup and diagnostic instrumenta-tion.
It is also used where the state of the art will not support requirements for higher qualified instrumentation.
The category listed for each variable in the Compliance Table is the catagory assigned by FPC.
Generally, this is the same category as listed in Regulatory Guide 1.97.
If however FPC has determined that a particular variable is not a key vari-able or other less stringent requirements better apply, then a note is added referencing to the FPC position, where justi-fication is supplied for the category change.
C.
RANGE The ranges listed in the Compliance Table are the actual measurement range of the variable at CR3 and the range recom.
mended by the Regulatory Guide.
If the range varies from that stated in the Regulatory Guide, a note is added referencing to FPC's position where justification is supplied for the exist-ing range.
In those cases where the existing range varies from the Regulatory Guide and FPC intends to upgrade to the regulatory guidance, a note is added stating that the range will comply.
In some instances, the Regulatory Guide states the range in terms of a percentage of the design.
In these cases, the design basis is listed next to the range in.
parenthesis.
D.
ENVIRONMENTAL QUALIFICATION A response of "Yes, Complies" on the Compliance Table indi-cates that the currently installed equipment meets the requirements of IE Bulletin 79-OlB and 10 CFR 50.49.
This determination was based on either having actual environmental qualification documentation available or documentation on similar equipment available.
RegGuide(Pos. Doc.)ND48-3,
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For Category 2 variables. FPC considers existing installed instrumentation located in a mild environment to be adequate for Regulatory Guide 1.97 Category 2 variables.
FPC also con-siders portions of the Non nuclear Instrumentation (NNI) adequate for Category 2 variables and has the following position:
For strings which include hardware located in a harsh environ-ment, portions in the harsh environment (sensors, cabling, terminations) should be qualified for the accident tempera-ture, pressure, humidity, radiation and chemical environment.
Hardware located in a mild environment (cabling, terminations, processing modules, power supplies, indicators and recorders) is adequate as currently installed.
The basis for this position is as follows:
The Category 2 qualification requirements of Regulatory Guide 1.97, Rev. 3, include no specific provision for seismic qualification. We interpret this to mean that environmental qualification only is required.
Since 10CFR50.49 does not require environmental qualification for equipment located in a mild environment, only those components listed in a harsh environment need be qualified.
The currently installed NNI equipment was not supplied as safety related equipment but is comparable in quality and reliability to existins safety related equipment.
In fact, some of the NNI electronic modules are identical to those qualified and supplied for these safety related systems.
Operatin5 experience with the NNI indicates that this instrumentation can reasonably be expected to be operable for accident monitoring.
Category 2 instrumentation is not required to be seismically qualified, redundant, physically and electrically separated nor powered from a lE source.
The existing NNI hardware located in a mild environment is consistent with the Cate-gory 2 criteria and no substantial improvement in reliability or safety would be expected if this equipment were replaced with new, qualified hardware.
For those instruments which are not now installed or for which proper documentation does not currently exist but is required for compliance, either documentation will be generated or the equipment will be replaced. This is indicated on the Compli-ance Table by a response of "No, Will Comply".
Other responses are self explanatory.
RegGuide(Pos. Doc.)ND48-3 1
f E.
~ SEISMIC QUALIFICATION A response of "Yes, Complies" on the Compliance Table indi-cates that the entire instrument string is seismically quali-fied in accordance with Regulatory Guide 1.100.
For equipment which is not presently installed or where only a portion of the instrument string is seismically qualified and must be upgraded, a response of "No, Will Comply" will appear on the Compliance Table. Other responses are self explanatory.
F.
QUALITY ASSURANCE A response of "Yes, Complies" on the Compliance Table indi-cates that Quality assurance requirements meeting CR3's licensing commitments as documented in the FSAR Section 1.6 were applied to at least the safety-related portions of the instrument string.
In instances where new equipment is being installed or existing equipment upgraded to the above require-ment, a response of "No, Will Comply" will appear.
All other responses are self explanatory.
G.
REDUNDANCY A response of "Yes, Complies" indicates that redundant chan-nels are available up to and incluling any isolation device and that the channels are both electrically independent and physically separate from each other, in accordance with IEEE Standard 279 1971, and meet single failure criteria.
A response of "No",
indicates that even though more than one channel may be available as shown, they do not meet the above requirements.
"Will Comply" indicates that the existing channels will be i
upgraded to comply with the above requirements, or new equip-ment will be installed to those requirements.
H.
POWER SOURCE The power source for the instrument string listed on the Compliance Table is in compliance with the Regulatory Guide requirements unless otherwise noted.
I.
DISPLAY l
Under this heading on the Compliance Table is how the variable i
is indicated and/or recorded in the Control Room (CR).
This l
is in compliance with the regulatory guidance unless otherwise indicated that it "Will Comply".
RegGuide(Pos. Doc.)ND48 3 5-
Rev: ^01 Date: 2/10/88 If the variable is available on demand in the Technical Suppore. Center (TSC) or the Emergency Operating Facility (EOF) it will be so stated.
J.
SCHEDULE This area of the Compliance Table indicates when the upgrades (if required) will be complete. Refuel V was completed August 1985 and Refuel VI in January 1988.
1 K.
POSITION In this area of the Compliance Table will be Florida Power Corporation's position on a particular variable which will include any justifications which are required along with any comments or clarifying remarks which may be needed.
If the justification presented is justification developed by the Babcock & Wilcox Owners Group (BWOG) Regulatory Guide 1.97 Task Force, it will be so stated.
RegGuide(Pos. Doc.)ND48-3 6-
Pegs 01 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Neutron Flux TYPE 6 CATEGORY:
B1
-8 RANGE:
CR-3 10 to 100%
NRC 10'0 to 100%
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC
^
QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
lE, complies DISPLAY:
Indicated and recorded in CR, on demand in TSC and EOF SCHEDULE:
Installed POSITION:
Complies The installation of a two channel Gamma Metric System was completed during Refuel VI which meets all the requirements cf Reg. Guide 1.97.
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Pego 02 Rsv:
01 Date:
2/10/88-CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Control Rod Position TYPE & CATEGORY:
B3 RANGE:
CR-3 0-100%, Full-in/ Full-out, Avg group Lights Position NRC Full-in or not Full-in ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
.No, not required REDUNDANCY:
No, not required 2 channels POWER SOURCE:
Regulated instrument BUS VBDP-1 and VBDP-2 DISPLAY:
Indicated in CR Avg group position, on demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies l
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L Pags 03-CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RCS Soluble Boron Content TYPE & CATEGORY:
B3 RANGE:
CR 3 0-6000 ppm NRC 0 6000 ppm ENVIRONMENTAL QUALIFICATION:
No not required SEISMIC s
QUALIFICATION:
No not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
lE/DG DISPLAY:
In laboratory only, need not comply SCHEDULE:
Installed POSITION:
Complies The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
The manual sampling and laboratory analysis is sufficient to meet the intent of Regulatory Guide 1.97, Rev. 03.
This is based on the fact that the loss of negative reactivity due to xenon decay is sufficiently slow that the control room operator need not know instantaneously or continu-ously what the boron concentration is in the RCS. Also,Section II.B.3-of NUREG 0737 requires that capability exists to sample and analyze the reactor coolant in a post-accident environment.
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'Pego 04 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
-RCS Hot Leg Water Temperature TYPE & CATEGORY:
A,B 1 RANGE:
CR-3 120* to 920'F, see Position NRC-50' to 700*F C
ENVIRONMENTAL
' QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies
. QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF i
' SCHEDULE:
Installed POSITION:
Complies l
RCS Hot Leg Water Temperature is a key variable for monitoring the core cooling safety function.
It is used with RCS pressure to monitor the I
status of the RCS with respect to saturation and subcooled margin limits.
l It is used with Core Exit Temperature to verify natural circulation and to
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identify loss of natural circulation.
It enn also be used with Steam Gen-L erator Pressure to verify coupling between the RCS and the Secondary System.
l The RCS hot leg temperature range does not envelope the lower end of the l
Reg. Guide 1.97 recommended range, however the existing range is acceptable based on the following:
1.
At temperatures less than 280'F, the plant will be in the Decay Heat Removal mode and this temperature is not required.
2.
Cold Shutdown is defined in the Technical Specification as less than 200*F.
3.
RCS cold leg temperature range will indicate down to 50*F.
Peck (Comp)DN104-2 I
Pego 04A Rsv: 01 Date:
2/10/88 Instrument upgrades to meet requirements of Reg. Guide 1.97 were completed during Refuel VI.
Peck (Comp)DN104 2
Pags 05 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RCS Cold Leg Water Temperature TYPE & CATEGORY:
B 3, see Position RANGE:
CR-3 50' to 650*F, see Position NRC 50' to 700*F ENVIRONMENTAL QUALIFICATION:
No, need not comply A
SEISMIC QUALIFICATION:
No, need not comply QUALITY ASSURANCE:
No, need not comply REDUNDANCY:
No, need not comply 2 channels POWER SOURCE:
lE/DG DISPIAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
Reg. Guide 1.97 lists cold leg water temperature as a Category 1 (key) variable and core exit temperature as a Category 3 (backup) variable for the core cooling function.
Cold leg temperature indication may not in all cases provide valid information on the status of core cooling.
Since it is located in the RCS loops and not the reactor vessel, there must be either forced or natural circulation flow through the steam generators for indi-cations to be representative of actual core conditions.
Also, due to the proximity of the cold leg RTD's to the HPI nozzles, HPI flow may signifi-cantly affect the cold leg temperature indication particularly in the i
i absence of forced RCS flow.
Incore temperature monitors provide a more
[
direct indication of core cooling independent of whether or not there exists coolant flow through the loops.
l The key variables for monitoring the core cooling plant safety function arc RCS Hot Leg Water Temperature, Core Exit Temperature, and Steam Generator Pressure (see Discussion section for RCS Hot Leg Water Temperature).
RCS l
Cold Leg Water Temperature is a backup temperature monitor to the RCS Hot Leg Water Temperature and Core Exit Temperature.
Peck (Comp)DN104 2 I
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Page 05A For these reasons, core exit temperature and RCS Hot Leg are the key vari-ables for monitoring core cooling and are qualified to Category 1 require-ments while RCS cold leg temperature serves as a backup variable and is qualified to Category 3 requirements accordingly.
The CR 3 range of 50 to 650'F is based on providing the capability of the RCS Cold Lag Water Temperature instrumentation to measure a value greater than the ocuration temperature for the steam generators, which is approxi-mately 500'F (based on 1050 psig design pressure).
650'F for the high end of the range provides 15% excess measurement capability and is approximate-ly 110% of the design temperature of 600*F.
The low end of the range, 50'F, allows for measurement of the variable during conditions where the DHRS or LPI system is not in use or available and the steam generators are removing decay heat.
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Pego 06 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RCS Pressure TYPE & CATEGORY:
A,B,C 1 RANGE:
CR-3 0 3000 psig NRC 0 3000 psig ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded in CR
'On demand in EOF & TSC SCHEDULE:
Installed POSITION:
Complies Portion of the instrument loop from the ES test cabinet to the control board were upgraded to C'*
lE requirements during Refuel VI.
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RCS pressure transmitters were replaced during Refuel V.
New transmitters meet RG 1.89 requirements (lE and environmental qualification).
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Peck (Comp)DN104 2
Pcgo 07 Rov:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Coolant Inventory (Reactor Vessel Level)
TYPE & CATEGORY:
B1 RANCE:
CR-3 Bottom of hot leg to top of hot leg Bottom of hot leg to top of vessel NRC Bottom of hot leg to top of vessel I
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUAIITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
1-E DISPLAY:
Indicated and recorded in CR SCHEDULE:
Installed POSITION:
Complies Ref: The NRC's evaluation of CR 3's response to NUREG 0737, Item II.F.2, Docket No. 50 302, dated 9/6/83.
e Reactor vessel level and hot leg level, including reactor coolant pump monitors to detect voids in coolant was implemented duriag Refuel V to satisfy NUREC-0737, Item II.F.2.
I Reactor Coolant Inventory Tracking System -- (RCITS) provides a continuous indication of reactor vessel inventory trending when the pumps are tripped.
l When the pumps are running, the void fraction indicators provide inventory
(
level trend measurement.
t Peck (Comp)DN104-2
Pigo 08 Rov:
01 Date:
2/10/88 CRYSTAL RIVER 3 RECULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Degrees of Subcooling TYPE & CATECORY:
B2 RANCE:
CR-3 658*F NRC 200*F subcool to 35'F superheat ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required (1 channel per loop)
POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies Two subcooling margin monitors are located on the PSA section of the main control board.
These instruments continuously display saturation tempera-ture for each loop.
In addition to displaying saturation temperature, each instrument can display RC pressure and core exit temperature on demand.
Two separate groups of 6 CET's each have been selected to provide represent-ative temperatures from each core quadrant and the control region. The temperature displayed on demand is the highest of the six CET's in each group and displays over a range of 0 F to 1,023 F, well above saturation temperature s.
Peck (Comp)DN104 2
Pcgs 09 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARI ABLE:
Containment Sump Water Level (Narrow Range)
TYPE & CATEGORY:
B,C 2 RANCE:
CR-3 0-10 ft.
NRC Sump ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, com.tes QUALITY ASSURANCE:
- Yes, omplies REDUNDANCY:
Yes complies 2 c'annels POWER SOURCE:
UPS/DC with IE standby DISPLAY:
Indicated and recorded in EFIC room On demand in TSC 6 EOF SCHEDULE:
Installed POSITION:
Complies Ref:
Safety Evaluation Report, Docket No. 50-302 dated January 13, 1984 Due to lack of space in the Control Room, the indicators and recorder are l
located in the Emergency Feedwater Initiation and Control (EFIC) Room. The NRC in the above referenced SER found that this location adequately l
satisfies the requirements of NUREC-0737, Item II.F.1.5.
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Pcgs 10 Rov:
01 Date:
2/10/88
+
CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Sump Water Level (Flood Level)
TYPE & CATECORY:
B,C 1 RANGE:
CR-3 0-10 ft. above sump NRC Plant specific.
EWIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC
('
QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
lE DISPLAY:
Indicated and recorded in EFIC room (On demand in EOF & TSC) (Later See Schedule)
SCHEDULE:
Installation of "0N DEMAND" display will be complete by September 30, 1988.
POSITION:
l l
Ref: Safety Evaluation Report, Docket No. 50 302 dated January 13, 1984 i'
Due to lack of space in the Control Room, the indicators and recorder are located in the Emergency Feedwater Initiation and Control (EFIC) Room. The NRC in the above referenced SER found that this location adequately i.
satisfies the requirements of NUREG 0737, Item II.F.1.5.
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Pags llA CRYSTAL RIVER 3
' REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Isolation Valve Position
[
(Manual Valves)
TYPE & CATEGORY:
B1 RANCE:
No indication, need not comply ENVIRONMENTAL QUALIFICATION:
N/A
~
SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A l
DISPLAY:
N/A SCHEDULE:
N/A POSITION:
Locked / closed valves or blind flanges may be used in lieu of automatic valves.
Ref. SRP-6.2.4 6F and NUREG 0737 Pg. 3-91.
Automatic valves are only mentioned for position indication. Ref.
SRP-6.2.4 6J.
Therefore, indication not required for locked / closed manual valves.
Peck (Comp)DN104 2 b
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Pcgo llB Rav: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Isolation Valve Position (Automatic Valves)
TYPE & CATEGORY:
B1 RANCE:
CR-3 Open-closed lights NRC Closed not closed ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, need not comply, see Position POWER SOURCE:
IE/UPS DISPLAY:
Indicated in CR, see Position SCHEDULE:
Installed POSITION:
Complies Redundancy is not necessary on a per valve basis since redundant barriers are provided for all fluid penetrations.
Areas of noncompliance were upgraded to comply during Refuel VI.
Position indication is provided in the Control Room via a light matrix.
This method should be acceptable for monitoring valve positions rather than recording.
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Peck (Comp)DN104 2 l
Pcgs 12 Rav: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Core Exic Temperature TYPE & CATECORY:
B,C 1 RANCE:
CR 3 0 2500'F NRC 200* to 2300*F ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, see position POWER SOURCE:
UPS/DC DISPLAY:
16 CETS - Recorded in CR 52 CETS Indicated and recorded on demand in CR 12 CETS - On demand in TSC & EOF at range 0 2000 F SCHEDULE:
Installed POSITION:
Complies Ref: The NRC's evaluation of CR-3 is response to NUREG-0737, Item II.F.2, Docket No. 50 302, dated 9/6/83.
i Core Exit Temperature measurement dispin incluce a primary and backup display arrangement.
The primary display consists of $2 Core Exit Thermocouples (CET's) recorded on demand in the Control Room over a range of 0 2500 F.
(Twelvef12)are also recorded on demand in the TSC and EOF over a range of 0 2000 F.)
The back up display consists of 16 separate temperature measurements from 16 CET's - 4 from each core quadrant.
The system is part of the ICC detection system and is Class 1-E.
Each of the 16 Core Exit Temperature measurements is continuously recorded in the CR on three separate recorders j
over a range of 0 2500 F.
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Peck (Comp)DN104 2 l
l L -
Page 12A Rsv: 01 Date:
2/10/88 Primary and backup displays are electrically independent, energized from independent power sources, and physically separated, up to and including the isolators.
The primary display is not Class 1 E but is energized from a battery backed, high reliability uninterruptible power supply, which is backed up by the deisel generator.
The upgrade of this variable was completed in accordance with NUREG 0737, Item II.F.2 during Refuel V and complies with the requirements of RGl.97 j
Rev. 3.
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Peck (Comp)DN104 2
Pass 13 CRYSTAL RIVER 3 REGUIATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RCS Radioac.4vity Concenttation TYPE & CATEGORY:
C 3, see position RANGE:
CR-3 10'2 to 10 3
,gjg, t
NRC 1/2 tech spec limit to 100 times tech spec limit ENVIRONMENTAL QUALIFICATION:
Need not comply, see position SEISMIC QUALIFICATION:
Need not comply, see position QUALITY ASSURANCE:
Need not comply, see position REDUNDANCY:
Need not comply, see position POWER SOURCE:
lE DISPLAY:
Indicated and recorded in lab only i
SCHEDULE:
Installed POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
Currently, no instrumentation exists to adequately measure this variable on line.
Existing instrumentation, letdown line radiation monitors, can be used to provide indication of fuel failure during normal operation. How-ever, since the letdown line is isolated during serious accidents requiring I
containment isolation, it will not be available for long term measurement,Section II.B.3 of NUREG 0737 requires that capability exist at each plant to sample the RCS to assess the magnitude of fuel failures during post-accident conditions. As such, this measurement should be the primary determinant of fuel failure during normal operatien and post-accident. The letdown line radiation monitor should be used as the initiator for sampling during normal operation because state of-the art equipment is unavailable and the primary means of monitoring this variable must therefore be by sampling and analysis.
It is recommended that it be downgraded to Category 3.
1 t
f 2
l Peck (Comp)DN104-2 i
s s Pags 14 CRYSTAL RIVER 3 REGULATORY. GUIDE 1.97 COMFLIANCE TABLE VARIABLE:
Containment Hydrogen Concentration TYPE & CATEGORY:
C1 RANGE:
CR-3 0-10%
NRC 0 10%
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes,-complies 2 channels POWER SOURCE:
1E DISFLAY:
Indicated and recorded in EFIC room SCHEDULE:
Installed POSITION:
Complies Ref:
Safety Evaluation Report, Docket No. 50-302 dated January 13, 1984 Due to lack of space in the Control Room, the Containment Hydrogen Honitor-ing System (CHMS) indicators and recorder are located in the Emergency Feedwater Initiation and Control (EFIC) Room.
The NRC in the above referenced SER found that this location adequately satisfies the require-ments of NUREG-0737, Item I~.F.1.6.
s Peck (Comp)DN104-2
Pass 15 Rcv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Pressure TYPE & CATEGORY:
B,C 1 RANGE:
CR 3
-10 to 200 PSIG NRC 10 psia to 3 times design ENVIRONMENTAL
~
QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
lE DISPIAY:
Indicated in CR and recorded in EFIC room On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies Ref:. Safety Evaluation Re;. ort, Docket No. 50-302 dated January 13, 1984 l
l l
Due to lack of space in the Control Room, the recorder is located in the i"
Emergency Feedwater Initiation and Control (EFIC) Room.
The NRC in the above referenced SER found that this location adequately satisfies the requirements of NUREG-0737,-Item II.F.1.4.
L The installation of qualified transmitters was completed during Refuel VI.
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l Peck (Comp)DN104 2 l
l l
Pcgs 16 CRYSTAL RIVER 3 RF'ULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RHR System Flow (Decay Heat)
TYPE & CATEGORY:
D2 RANGE.
CR-3 0-5000 GPM (Design - 3000 GPM).
NRC 0 to 110% Design ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS/DG with lE standby DISPLAY:
Indicated in CR l
On demand in TSC & EOF SCHEDUL.
Installed POSITION:
Complies QA requirements meeting CR-3 licensing commitments were applied to safety
.related portions of this instrument string.
L.-
1.
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Peck (Comp)DN104-2 l
l l_
Pags 17 Rov: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
RHR Heat Exchanger Outlet Temperature (Decay Heat)
TYPE & CATEGORY:
D2 RANGE:
CR-3 0-300*F NRC 40' to 350'F ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Not required 2 channels POWER SOURCE:
UPS with lE standby DISPIAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies Equipment environmental qualification were upgraded to meet requirements of Reg. Guide 1.97 during Refuel VI.
QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
Design temperature of the Decay Heat system and heat exchanger for CR-3 is 300*F.
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Peck (Comp)DN104-2 i
l~
L
Pcgs 18A R:v: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Accumulator Tank Level (Core _ Flood Tank)
TYPE & CATEGORY:
D2 RANGE:
CR 3 0-14 ft. above datum
.NRC 10 to 90% Vol.
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies Range covers 100% of required liquid level. Voluae not covered is for nitrogen blanket.
Meets intent of RG 1.97.
QA requirements meeting CR-3 licensing commitments were applied to safety
~
related portions of this instrument string.
i i
i Peck (Comp)DN104-2 f
Page 18B Rav:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE
-VARIABLE:
Accumulator Tank Pressure (Core Flood Tank)
TYPE & CATEGORY:
D 3, see position RANGE:
CR 3 0 800 PSIG NRC 0-750 PSIG ENVIRONMENTAL QUALIFICATION:
.do, need not comply SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
The following position is a justi.fication developed by the BWOG Reg. Guide 1.97 Task Force.
Core Flood Tank Pressure is a key variable for pre-accident status to assure that this passive safety system is prepared to serve its function.
This pressure indication provides no essential information for operator action during or following an accident.
The key variable necessary to determine whether the Core Flood Tanks have fulfilled their safety function is Core Flood Tank Level. Therefore, Core Flood Tank Pressure is a backup type variable and has been classified as a Category 3 instrument according-ly.
i l
l Peck (Comp)DN104-2 L
)
Pogs 19 Rsv: 01 Date: 2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Accumulator Isolation Valve Position (Cere Flood Tank)
TYPE & CATECORY:
D2 RANGE:
CR 3 Closed open lights NRC Closed or open ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
l'.st required 2 channels POWER SOURCE:
UPS/DG DISPIAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
Areas of noncompliance were upgraded to comply during Refuel VI.
f Peck (Comp)DN104-2 i
Pags 20 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE
ARI ABLE :
Boric Acid Charging Flow TYPE & CATECORY:
D2 RANGE:
N/A ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
The following position is a justification developed by 'the BWOG Reg. Guide 1.97 Task Force.
The B&W - designed NSSS does not include a charging system as part of the Emergency Core Cooling System (ECCS).
Flow paths from the ECCS to the RCS l
include high pressure injection (HPI) and low pressure injection (LPI) with the BWST or the RB Sump as the suction source, and the Core Flood Tank inj ection. HPI and LPI-flow rates are monitored, and BWST, RB sump, and Core Flood Tank levels are monitored by RG 1.97 variables. Therefore, Boric Acid Charging Flow does not need to be monitored as a Type D variable to monitor the operation of the ECCS.
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l Peck (Comp)DN104-2 l
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Page 21 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Flow in HPI System TYPE & CATEGORY:
D2 RANGE:
CR-3 0-500 GPM (Design - 300 GPM)
NRC 0 to 110% Design ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 chmusels POWER SOURCE:
UPS/DG DISPIAY:
Indicated in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
Peck (Comp)DN104 2
Pags 22 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Flow in LPI System TYPE & CATEGORY:
D2 RANGE:
N/A ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
Same instrument as RHR system flow, see page 16.
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Pego 23 Rov: 02 Date:
2/10/88 CRYSTAL RIVER 3 RECULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Refueling Water Storage Tank Level (Borated Water Storage Tank)
TYPE & CATECORY:
A,D 1 RANGE:
CR-3 0 50 feet NRC Top to bottom
~.
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies
. QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
1E/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
The variable is indicated on redundant, qualified, indicators, located on a seismically qualified panel board and one of the redundant channels is recorded.
Due to a lack of seismically qualified panel space the recorder is mounted I
on panel not seismically qualified.
The recorder itself is environmentally qualified and electrically isolated from the rest of the qualified instrument loop.
Upgrades were completed during Refuel VI.
Peck (Comp)DN104 2
Paga 23A Rev:
02 2-10 88 B&W's Criteria for BWST sets three criteria which must be met by the BVST.
The first criterion is related to fuel handling and transfer operations and is not applicable for accident events.
The second criterion requires thac sufficient volume be contained in the BWST to provide sufficient time for injection operation prior to switchover to an alternate source.
This is a criterion which must be satisfied during normal plant operation to ensure availability of the BWST during an accident.
This volume is less than that required to meet the first criterion.
The third criterion is the important one for use during and after an accident.
This criterion requires that the BWST level be such that adequate NPSH for all ECCS pumps be available.
To meet the desired intent of the regulatory guide that accident monitoring instrumentation also be used, to the extent practicable, during normal
~
operations, the existing BWST level instrumentation has sufficiently wide range to monitor the level required in the BWST. At Crystal River 3, the tank level is monitored from 0 to 50 feet. A low alarm is provided a 4 feet and switchover is required at 2.5 feet.
Thus, the operator is provided with adequate level indication at all times.
I i
Peck (Comp)DN104 2
Pag 24 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Reactor Coolant Pump Status TYPE & CATEGORY:
D3 RANGE:
CR-3 0-125% load NRC Motor current ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required 1 per pump POWER SOURCE:
OP, complies DISPLAY:
Pump running lights in CR 0-125% load indicted for each pump in CR Indicator for total circuit amps is on switchgear On demand in TSC & EOF POSITION:
Complies Peck (Comp)DN104 2
Pega 25 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Primary System Safety Relief Valve Position or Flow Through or Pressure.in Relief Lines TYPE & CATEGORY:
D2 RANGE:
CR-3 Acoustic system NRC Closed not closed ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS/DC DISPLAY:
Indicated in CR On demand in TSC & EOF SCHEDULE:
Installed l
POSITION:
Complies 1
Accelerameters are seismically mounted.
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l Peck (Comp)DN104 2
Pags 26
'Rev: 02 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Pressurizer Lovel TYPE & CATEGORY:
D1 RANGE:
CR 3 0 320 inches, see position NRC Top to bottom ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDACY:
Yes, complies 2 channels POWER SOURCE:
lE/DC DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
L The pressurizer level was sized based on the following.
The water volume i
is chosen such that the reactor coolant system can experience a reactor l
trip from full power.without uncovering the level sensors in the lower l
shell and to maintain system pressure above the HPI system actuation set-P point.
The steam volume is chosen such that the reactor coolant system can experience a turbine trip without covering the level sensors in the upper l
shell.
The range of 0-320" H O was based on this criteria and setpoints 2
l for automatic or manual actions are based on this range.
l l
The pressurizer is approximately 512 inches call.
The 0 inch reference for j
the pressurizer level instrument range is 43 inches above the lower datum l
line (approx. 96 inches from the bottom), 16 inches below the upper set of heaters, and approximately at the level of the second set of heaters.
The upper pressurizer level top (320 inches above the 0 inch reference) is 43 I
inches below the upper datum (approx. 92 inches from the top), and approxi-l mately 37 inches from the spray head.
i l
Peck (Comp)DN104-2 1
I t
I
Page 26A Rav: 02 Date:
2/10/88 The Accident Analysis chapters of several B&W Owners Group Utility Final Safety Analysis Reports (SAR), as well as Part II, Volume 2 of the B&W Owners Group Abnormal Transient Operating Guidelines (ATOG) were reviewed to obtain pressurizer level responses to anticipated transients and accidents.
For anticipated transients such as decreasing feedwater temperature, excessive main feedwater flow, loss of main feedwater flow, decreasing steam flow, small steam leaks, loss of external load, loss of off-site power, loss of condenser vacuum and small steam generator tube leaks, the existing ranges for the pressurizer level are sufficient such that indicated level should remain on scale.
For severe transients (accidents) such as steam line break, steam generator tube rupture and mady small break LOCA's, the pressurizer will void.
Following ESFAS actuation of the HPI system, actions can be taken as necessary to stabilize the plant.
Those actions are based on subcooling margin and RCS pressure, not pressurizer level.
For the case of a total loss of feedwater, the pressurizer will go solid unless either main or emergency feed water is restored to the steam ' generators within about 15 minutes.
Actions taken are dependent on when feedwater is restored, subcooling margin and RCS pressure, not pressuri::er level.
In general, for severe transients or accidents, the pressurizer will either void or go solid.
A voided pressurizer will cause indicated level to go off-scale low followed by a rapid decrease in RCS pressure to saturation.
A solid pressurizer will cause indicated level to go off-scale high accompanied by high RCS pressure, possible large and rapid changes in RCS pressure, PORV and pressurizer safety valve actuation.
All of these indications are available in the control room.
Based on this information, the existing ranges of pressurizer level indication are sufficient for anticipated transientc.
For severe l
transients or accidents, indicated pressurizer level vill go off-scale high or low due to the pressurizer going solid or voiding and, as a. result, top to bottom instruments would provide no significant additional information.
l In these
- cases, subcooling margin, RCS
- pressure, PORV status and pressurizer safety valve status are monitored to determine actions to be I
taken.
The installation of upgrade to comply with the requirements of Reg. Guide l
1.97 were completed during Refuel VI.
I Peck (Comp)DN104-1 l
l l
E.
Pago 27 Rev: 02 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Pressurizer Heater Status TYPE & CATEGORY:
D2 RANGE:
CR-3 Electric Current, see Position NRC Electric Current ENVIRONMENTAL QUALIFICATION:
No, will comply SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, will comply REDUNDANCY:
No, not required POWER SOURCE:
No, will comply DISPLAY:
Indicate in CR, will comply SCHEDULE:
Upgrades will be complete by end of Refuel VII POSITION:
Will comply FPC will install environmentally qualified electric current flow instrumentation to monitor the status of the pressurizer heaters by end of Refuel VII, beginning in the Fall of 1989.
l Peck (Comp)DN104-2
Pags 23 CRYSTAL RIVER 3 REGULATORY CUIDE-1.97 COMPLIANCE TABLE VARIABLE:
Quench Tank Level (Reactor Coolant Drain Tank)
TYPE & CATEGORY:
D3 RANGE:
CR-3 6 inches from bottom to top NRC Top to bottom ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies Peck (Comp)DN104-2
Psgs 29 Rsv:
01 Date:- 2/10/88 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TASLE VARIABLE:
Quench Tank Temperature (Reactor Coolant Drain Tank)
TYPE & CATEGORY:
D3 RANGE:
CR-3 0 to 400 F NRC 50 to 750 F ENVIRONMENTAL 4-QUALIFICATICN:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies l
The following position is a justification developed by the BWOG Reg. Guide i
1.97 Task Force.
The Quench Tank, known as the Reactor Coolant Drain Tank (RCDT) is equipped L
with a rupture disc which blows at 110 psig (saturation temperature -
l-345'F).
1 A range change to 0-400 F and the installation of an indicator in the Control Room was completed during Refuel VI.
Peck (Comp)DN104-2
Page 30 CRYSTAL RIVER 3 RECULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Quench Tank Pressure (Reactor Coolant Drain Tank)
TYPE & CATECORY:
D3 RANCE:
CR-3 0-100 PSIG (Design - 100 PSIG)
NRC 0 to design ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC-QLALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR On demand in TSC & EOF SCHEDULE:
Installed
- POSITION:
Complies m
Peck (Comp)DN104 2
Pags 31 Rav:
01
-Date:
2/10/88 f
CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Steam Generator Level
-TYPE & CATECORY:
A,D 1 RANGE:
CR-3 0 to 150 and 100 to 394 inches, see Position NRC Tube sheet to separators ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 4 channels POWER SOURCE:
lE/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies CR-3, having a B&W NSSS, utilizes Once Through Steam Generators (OTSC) which produce superheated steam and therefore are not equipped with moisture separtors in the steam generator. CR-3 installed the Emergency Feedwater Initiation & Control (EFIC) system, which was completed in Refuel V.
This system provides Class lE, redundant, level indication in the CR.
The lower range (start-up) measures 0 to 150 inches and the upper range (operating) measures 100 to 394 inches.
The lower level sensing tap (o inches) is approximately 6 inches above the lower tube sheet and the upper level sensing tap (394 inches) is at approx-imately the level of the aspirating ports.
Areas of noncompliance were upgraded to comply and installation was completed during Refuel VI.
Peck (Comp)DN104 2
Pegs 32-Rsv:
01 Data:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARI ABLE:
Steam Generator Pressure TYPE & CATEGORY:
A,D 1 RANGE:
CR 3 0-1200 PSIC, see Position NRC Atmosphere to 20% > Lowest Safety Viv Setting (1260 PSIG)
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 4 channels POWER SOURCE:
lE/DG DISPLAY:
Indicated and recordad in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies see Position The steam generator pressure range of 0-1200 psf.g is acceptable because the safety valve setpoints range froc a low of 1050 psig 10 psig to 1100 psig 10 psig, which are close to 20% above the lov setpoint recommendation.
The high safety valve setpoint is a*uout 100 psig below the high end of the instrument scale.
The highest safety valve setting is typically 1100 psig.
The steam relief capacity is 20-25% above the expected steam flow rate.
Excess relief capacity is maintained when safety valves are inoperable.
The FSAR analysis indicates c. maximum steam pressure of about 1100 psig for operating plants.
Based on these facts, it is FPC's position that the existing range of 0-1200 psig is sufficient.
(
Other areas of nonecmpliance were upgraded to comply during Refuel VI, l
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Peck (Comp)DN104 2 l
l l
Pegs 33 Rsv:
02 Date:
2/10/88 r.
CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Main Steam Safety Relief Valve Position TYPE & CATEGORY:
D2 RANGE:
CR-3 Closed - not closed NRC Closed - not closed ENVIRONMENTAL QUALIFICATION:
Yes, will comply y
SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
Yes, will comply REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in Control Room SCHEDULE:
Upgrade will be completed by end of Refuel VII POSITION:
Will comply Equipment will be installed to indicate Main Steam Safety Relief Valve Position.
Installation is scheduled for completion by the end of Refuel VII, beginning in the Fall of 1989.
The installation will include equipment to establish the duration and magnitude of steam releases from the secondary coolant system l
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Peck (Comp)DN104-2
Pags 34 CRYSTAL RIVER 3 9
RECUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Main Feedwater Flow TYPE 6 CATECORY:
D3 6
6 RANGE:
CR 3 0 to 6 x 10 lbs/hr. (Design - 5.3 x 10 lbs/hr)
NRC 0 to 110% design ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required 3 channels POWER SOURCE:
UPS/DG DISPLAY:
Indicated and recorded in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies
~
is' ps;.
Peck (Comp)DN104-2
Pago 35 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIARLE:
Auxiliary Feedwater Flow f
TYPE 6 CATEGORY:
D1 RANGE:
CR-3 0 1000 GPM (Design - 740 GPM)
NRC 0 to 110% design ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes,' complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 4 channels POWER SOURCE:
lE DISPLAY:
Indicated and recorded on demand in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
Complies A redundant 4 channel system with all safety parts seismically qualified, and transmitters environmentally qualified were installed in conjunction l
with the EFIC modifications.
Installation was completed during Refuel V.
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l Peck (Comp)DN104-2 l
l
Paga 36 Rev:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Condensate Storage Tank Water Level (Emergency Faedwater Tank) - see Position TYPE & CATEGORY:
D1 RANGE:
CR-3 0-38 ft.
NRC Plant Specific ENVIRONMINTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANC'::
Yes, complies REDUNDANCY:
Yes, complies POWER SOURCE:
1E DISPIAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies A new tank called the Dedicated Emergency Feedwater Tank was installed during Refuel VI.
The level instrumentation installed with the tank complies with RG 1.97 requirements.
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Pago 37 Rev:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Spray Flow TYPE & CATECORY:
D2 RANGE:
CR 3 0-1800 CPM (Design - 1500 GPM)
NRC 0 to 110% Design
~
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Yes, complies 2 channels POWER SOURCE:
UPS/DG DISPIAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies Areas of nonconformance were upgraded to comply during Refuel V.
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Peck (Comp)DN104-2
Page 38 Rsv: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Heat Removal by the Containment Fan Heat demoval System TYPE-& CATEGORY:
D2 RANGE:
See posi: ion ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required POWER SOURCE:
Regulated instrument BUS VBDP-2 DISPLAY:
"RB Fans Running".
Indicated in CR; RBCU SW Flow -
Recorded on demand in CR.
SCHEDULE:
Installed POSITION:
Complies The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
The plant has a design air flow rate from the Reactor Building fans during normal and accident or emergency conditions. The design flow rates are achieved by reducing the normal running speeds of the fan motors by about one-half during accidents where the heavier steam air mixture might over-load the motors at full speed.
The fan cooling units are cooled by cooling water from the Nuclear Services Closed Cycle Cooling System (SW)
For the following reasons, the status of the fan breakers and cooling water flow rate are the measured variables.
The primary indication that the Reactor Building is being cooled is the Reactor Building temperature. A first indication that the Reactor Building fans are performing their func-tion is an indication of the status of the fan breakers to ensure that the fans are on and the delivery of cooling water flow to the cooling units.
The flow variable was upgraded to comply with P.G 1.97 Requirements during Refuel VI.
As backup information to ensure coupling between the fan and motor, each fan is equipped with vibration detectors which annunciate in the control room.
Calibrated percent load meters for the motors are also located in the control room.
Peck (Comp)DN104 2 g
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Pega 39 Rsv: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Atmosphere Temperature TYPE & CATECORY:
D2 RANGE:
CR-3 0-400*F NRC 40*F to 400*F ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATIGN:
Yes, complies QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
Not required 4 measurements POWER SOURCE:
UPS/DG DISPIAY:
Recorded in CR On demand in TSC & EOF SCHEEULE:
Installed POSITION:
Complies Areas of noncompliance were upgraded to comply during Refuel VI.
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Pegs 40 R v:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Sump Water Temperatue TYPE & CATEGORY:
D2 RANGE:
CR-3 Not measured, see position.
NRC 50 to 250'F ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPIAY:
N/A SCHEDULE:
N/A POSITION:
The NRC R.G. 1.97 requires containment sump water temperature indication as a Type D variable for the purpose of monitoring the operation of contain-ment coolin5 systems. No additional justification is provided.
It is expected that this information would be used following high energy line breaks in containment. While containment sump temperature trends may be indicative of high energy fluid leakages and containment cooling, it would be difficult to conceive of any correlation from monitored values to any useful measure of success.
Containment sump temperatures impact containment cooling only when the Reactor Building spray system is in operation with suction being taken from the sump.
This would be expected to be used only af ter depletion of avail-able supplies from the BWST.
a.
Containment Cooling System Monitoring Containment atmospheric temperature instrumentation provides the most direct indication of containment cooling system success.
Contaminment atmospheric temperature instrumentation was upgraded during Refuel VI to meet RG 1.97 requirements.
Peck (Comp)DN104 2
Pags 40A Rsv:
01 Date:
2/10/88 The next most valuable indication of containment cooling is provided by instrumentation which monitors the operation of systems with a con-tainment cooling function.
This function ic provided by the Reactor Building Spray System (BS) and the Reactor Building Air Handling System (AH).
The Reactor Building Containment Fan Heat Removal Cooling Water Flow Instrumentation (SW) was upgraded to provide heat removal indication meeting the requiremencs of R.G.
1.97 during Refuel VI (see position Page 38).
Containment atmospheric temperature is recorded in the control room.
The Reactor Building air handling fan motor breaker positions, indi-cating lights and percent full load ammeter indicators representative of air flow loading are monitored on the control board.
Fan cooling water flow leakage is also monitored and alarmed.
Containment sump water temperature provides only a crude indication of containment cooling system success.
Because of this and the avail-ability of the instrumentation described above, sump water temperature instrumentation is not necessary for containment cooling system monitoring.
Nevertheless, containment sump temperature can be deter-mined when the LPI is in the recirculation mode, using temperature indicators meeting all other R.C. 1.97 requirements.
b.
Equipment Temperature Limits Protection of DH and BS from Excessive Sump Temperatures:
These systems are designed for fluid temperatures in excess of the R.G. 1.97 required range for sump water temperature instrumentation (Ref. FSAR Table 6 3).
No operator action is required in response to sump water temperature.
Actual options available with excessive sump water temperatures would be limited to the reactor coolant system and containment cooldown prior to transferring to the recirculation mode of containment spray.
This traasfer is not required for over an hour after a LOCA, in which time the sump temperature is below 205'F.
L c.
NPSH Requirements l
l The minimum availsble NPSH for the Decay Heat Removal pumps is con-l servatively calculated with sufficient safety margin such that indica-l tion of sump temperature is not required in order to insure adequate l
NPSH and no automatic or manual actions are initiated based on this temperature.
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. Pegs 41 Ra,v :
01 Date:
2/10/88 r.
CRYSTAL RIVER 3 REGUIATORY CUIDE 1.97 -
COMPLIANCE TABLE VARIABLE:
Make up Flow - In TYPE & CATECORY:
D 3, see Position RANGE:
CR-3 0-200 GPM (Design - 115 GPM)
NRC 0 to 110% Design ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPIAY:
Indicated in CR SCHEDULE:
Installed POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
During design basis events such as LOCAs, the Makeup and Purification System (MU) is isolated.
Makeup flow is a backup variable to the makeup l
line isolation valve position.
During normal operation and certain design basis events cuch as small break IDCA, the MU System is used to supply l
borated makeup vater into the RCS to balance letdown flow out of the RCS.
It also adds makeup water in order to c.aintain pressurizer level at its setpoint.
Thus, makeup flow is an important variable for monitoring the operation of the MU System.
For the reasons provided in the Position l
section for the variable, Makeup Tank level (page 43), it is suggested that this variable can be a backup to Makeup Tank Level.
As a backup Type D variable, it is appropriate that Makeup Flow be classified Category 3.
Peck (Cornp)DN104-2
Pags 42 Rev:
01-Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Letdem Flow - Out TYPE 6' CATEGORY:
-D 3, see position.
RANGE:
CR-3.
0-160 GPM (Design - 140 GPM)
NRC 0 to 110% Design ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required i
QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG-DISPLAY:
Indicated in CR On demand in TSC & EOF SCHEDULE:
Installed POSITION:
The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
During design basis events such as LOCAs, the MU System is isolated.
l Letdown flow is a backup variable to the letdown 1.v;ation valve position.
During normal operation and certain design basis events such as small break LOCAs, the MU System is used to supply borated makeup water into the RCS to l
balance letdown flot out of the RCS.
Thus, letdown flow is an important l
variable for monitoring the operation of the MU System.
For the reasons provided in the Position section for the variable Makeap Tank level (page 43), it is suigested that this variable can be a backup to Makeup Tank level. As a leckup Type D variable, it is appropriate that letdown flow be classified Category 3.
For Crystal River 3, normal letdown flow rate through the block orifics is 45 gpm with a uaximum flow rate of 140 gpm with both letdown coolers in operation.
Having this maximum flow rate of 140 gpm the range of letdown flow indicator is 0 to 160 gpm which adequately meets the regulatory guide recommendation of 0 to 110% design flow.
Peck (Comp)DN104-2
P gs 43 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Volume Control Tank Level (Makeup Tank)
TYPE & CATEGORY:
D2 RANGE:
CR-3 0-120 inches, meets intent, see position NRC Top.co bottom ENVIRONMENTAL QUALIFICATION:
Tes, complies SEISMIC QUALIFICATION:
Yes, complies QUALITY ASSURANCE:
Yes, ccmplies REDUNDANCY:
No, not required 2 channels POWER SOURCE:
UPS DISPLAY:
Recorded in CR On demand in TSC & EOF l
SCHEDULI:
Installed POSITION:
l The following position is a justification developed by the L'J0G Re5. Guide l.97 Task Force.
L During normal operation and certain design basis accidents where the MU l
System is still operable, the Makeup Tank Level is the key variable used to provide indication that the MU System is operating properly. Makeup Tank l
Level information provides the first indication that a suction source for the Makeup pumps
'3 available.
Since che Makeup Tank is a surge volume for the RCS, Makeup Tank Level and Pressurizer Level indications can be used to qualitatively assess Makeup Flow into the RCS and Letdown Flow from the l
RCS.
Quantitative indication of Makeup Flow and Letdown Flow can be provided by flow instrumentation for these variables. However, in most instances, it is more important to know that Makeup and/or Lutdown is established (quali-tative) and not necessarily what thos3 flow rates are (quantitative) in order to determine the operation of the MU System. Since Pressurizer Level instrumentation is Category 1 and the suggested Makeup Tank Level instru-mentation be Category 2, then high quality instrumentation is available to l
Peck (Comp)DN104-2 l
Page 43A Rav:
01 Date:
2/10/88 provide information on the status and operation of the MU System.
Flow rate indication provided for Makeup Flow and Letdown Flow can be used as confirmatory, backup information to Makeup Tank Level and Pressurizer La' vel.
Meets intent of RG 1.97, 2 1/2" from bottom to 4" from top of vessel.
Parts of safety system are seismic with QA. QA requirements meeting CR
.'l licensing commitments were applied to safety related portions of this instrument string.
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Peck (Comp)DN104 2 l
Pcg3 44 Rsv: 01 Date:
2/10/88 CRYSTAL RIVER REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Component Cooling Water Temperature to ESF Systems TYPE & CATEGORY:
D2 RANGE:
CR-3 0-200*F and 0-250*F, see Position NRC 40' to 200*F ENVIRONMENTAL QUALIFICATION:
No, not required (mild environment)
SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, see Position REDUNDANCY:
No, not required POWER SOURCE:
UPS/DG DISPLAY:
Indicated in CR SCHEDULE:
Installed POSITION:
Complies The 0-200*F range is for the Decay Heat Closed Cycle Cooling Systems (DC) and the 0 to 250*F range is for the Nuclear Services Closed Cycle Cooling Systems (SW).
This equipment was originally purchased without Quality Assurance documen-tation.
Future equipment will be purchased with the requirement to specify the applicable Quality Assurance practices.
Peck (Comp)DN104-2
Pcg3 45 Rev:
01 D:ts:
2/10/88
(,
CRYSTAL RIVER 3 REGULATORY CUIDE 1.97-COMPL.!ANCE TABLE VARIABLE:
Component Cooling Water Flow to ESF Systems (Level) see Position TYPE & CATEGORY:
D2 RANCE:
CR-3 (See Position)
Surge Tank Levels: SW - 10 ft below to 4 ft above Normal WL.
DC From 11'3" below to 4 ft above Normal WL.
System Pressures:
SW 200 PSIG DC - 0 60 PSIG NRC 0 to 1101 Desipt Flow ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required
{
QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required POWER SOURCE:
Regulated Instrument BUS VBDP-2 DISPIAY:
Recorded on demand in CR SCHEDULE:
Installed POSITION:
Complies There are presently no flow indications on the main control board for Decay Heat Closed Cycle Cooling (DC) and Nuclear Services Closed Cycle Cooling 9
(SV) systems. Local flow indication for these systems is available.
Indi-cated flow measurements in the control room are not deemed necessary because the DC and SW systems surge tank levels provide better information to the operator. The wide range of design flows to various ESF components would not necessarily be representative of overall system performance.
Service water header pressures and remote actuated valve positions are available to the operator and along with the sur5e tanks levels, which pro-vide a better overall indication of system status.
QA requirements meeting CR-3 licensing commitments were applied to safety related portions of this instrument string.
(
Compliance upgrades were completed during Refuel VI.
Peck (Comp)DN104-2
Psgo 46 Rsv: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
High-Level Radioactive Liquid Tank Level TYPE & CATEGORY:
D3 RANGE:
CR 3 0 to 100%
NRC Top to bottom ENVIRONMLNTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, net required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
Instrument Air DISPLAY:
Indication at local panel only, see Position SCHEDULE:
Installed POSITION:
Complies Tanks covered by this variable are:
Concentrated Waste Tcnks (2)
Concentrated Boric Acid Tanks (2)
Spent Resin Holdup Tank The level indication for the concentrated waste tanks, concentrated boric acid tanks and the spent resin hold-up. tank are indicated on the radio-active waste disposal control panel located in the Auxiliary Building.
High level alarms at this panel will cause a common alarm to actuate on the main control board. The controls for the liquid waste disposal system are all located at the local panel; therefore indication on the main control board would not enhance operator control from the control room.
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Peck (Comp)DN104 2 l
l L
Pegs 47' Rev: 01 Date: 2/10/88 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Radioactive Gas Hold up Tank Pressure (Waste Decay Tanks)
TYPE & CATEGORY:
D3 RANGE:
CR-3 0-150 PSIG (Design - 150 PSIG), see position NRG 0 to 150% Design ENVIRONMENTAL QUALIFICATION:
No, not required SEISMIC QUALIFICATION:
No, not required QUALITY ASSURANCE:
No, not required REDUNDANCY:
No, not required POWER SOURCE:
Instrument air DISPLAY:
Indication at local panel only, see Position SCHEDULE:
Installed POSITION:
Complies The control and indications for the waste disposal system aie located on the radioactive vaste disposal panel in the Auxiliary Building.
Indication of radioactive gas hold-up tank pressure is not a necessary control room variable for the post accident monitoring.
In the event of an accident which results in significant failed fuel or significant radioactive gas release, the manual transfer of radioactive gases to the radioactive gas hold-up tanks would not be attempted since the Reactor Building would be utilized as the hold-up tank.
There are no automatic transfer operations involving the radioactive gas hold-up tanks.
Therefore, the monitoring in the control room of the radioactive gas hold-up tanks during post accident conditions is not necessary since these tanks are not utilized for accident mitigation.
The radioactive gas hold-up tanks are equipped with relief valves which are set at 125 poig.
The range of the pressure indication is 120% above the l
relieu alve setting.
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Peck (Comp)DN104-2 i
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. ~. - _
Pego 48 Rsv:
01 Date:
2/10/88 L
CRYSTAL RIVER 3 REGULATORY CUIDE 1.97-COMPLIANCE TABLE VARIABLE:
Emergency Ventilation Damper Position Indication (See Position)
TYPE & CATEGORY:
D 2
RANCE:
CR-3 See position NRC Open Closed Status ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
Yes, complies REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DISPLAY:
See position.
SCHEDULE:
Installed POSITION:
Complies Dampers covered under this category are those used in ventilation systems for the following:
Emergency Diesel Generator Control Complex Decay Heat Pump Area Spent Fuel Cooling Pump Area The dampers in these systems are controlled from the fan start circuitry and do not have individual control switches.
Redundant systems are provided so that a single failure will not defeat their safety function.
Panel lights show when the fan circuitry is operating.
Back-up operational data is provided to operators by high quality commercial grade low flov and high temperature alarms.
The control complex dampers also have open position lights.
The _above data should be adequate to determine if an HV system is opera-tional.
Individual damper position would only be beneficial if isolation were required.
(cont. on Page 48A)
L
Page 48A Rev: 01 Date: 2/10/88 For those dampers in the control complex which are closed on either high radiation or engineered safeguards systems actuation, qualified closed position-indication was added during Refuel VI.
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Peck (Comp)ND75-1 I
Peg 2 49 Rev:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Status of Standby Power TYPE & CATEGORY:
D2 RANGE:
CR-3 Inverter 250/125V DC DG 3A to 3D 4160V 480V 3A, 3B 3A',3B Pwr Avail-3A,3B 3A,3B Pwr Avail.
Volts; Amps able Volts Volts able 4
Ind. Lt -
Ind. Lts -
R/G R/G NRC Plant Specific ENVIRONMENTAL QUALIFICATION:
Yes Yes No SEISMIC QUALIFICATION:
No not required.
QUALITY ASSURANCE:
No No No REDUNDANCY:
Redundancy based on dual buses.
POWER SOURCE:
Indicated Indicated Indicated Indicated Indicated SCHEDULE:
Installed POSITION:
Complies Areas of non-compliance were upgraded to comply during Refuel VI.
Peck (Comp)ND75-1
Pagt 50
. Rov: 01 Date: 2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Area Radiation - High Range TYPE ~& CATEGORY:
C, E 1
RANGE:
CR-3 1 to 10 R/Hr l
8 NRC 1 to 10 R/Hr ENVIRONMENTAL QUALIFICATION:
Yes, complies.
SEISMIC QUALIFICATION:
Yes, complies.
QUALITY ASSURANCE:
Yes, complies.
REDUNDANCY:
Yes, complies.
2 channels POWER SOURCE:
lE DISPLAY:
Indicated and recorded in CR.
(On demand in TSC & EOF) (Later See Schedule)
SCHEDULE:
Installation of "0N DEMAND" display will be complete by September 30, 1988 POSITION:
Complies - except "0N DEMAND" display l
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Pcgo 51 Rev: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY CUIDE 1.97 COMPLI/.NCE TABLE VARIABLE:
Radiacion Exposure Rate inside buildin5s or areas where access is required to service equipment important to safety or which are in direct contact with primary containment where penetrations and hatches are located.
TYPE & CATEGORY:
E 3
RANGE:
CR-3
.01 to 10R/Hr, complies with position.
NRC
.1 to 10,000 R/Hr ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
lE DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
Complies The following position is a justification developed by the BWOG Reg. Guide 1.97 Task Force.
i NRC R.G.
1.97 Rev. 3 requires area radiation monitors inside buildings or areas where access is required to service equipment important to safety.
The NRC identified purposes for this instrumentation are:
"Detection of significant releasec, release assessments, and lon5 term surveillance."
This is a Type E variable with the overall purpose of being monitored as required in determining the magnitude of the release of radioactive materials and continually assessing such releases.
The required range for these monitors is 0.1 to 10" R/Hr.
R.G.
1.97 describes areas of concern as those where access is required to service safety related equipment.
This implies that this instrumentation may be used for purposes other than those described above, i.e. for health physics purposes.
For purposes of determining the magnitude of releases, the area radiation exposure rate monitors are clearly of very minor importance.
Determination l
Peck (Comp)ND75-1
Pags 51A of release magnitude is done by other Type E variables associated with release paths.
There is no useable correlation between area exposure rate monitors and amount of release.
Detection of significant releases by area radiation exposure rate monitor-ing is secondary to that provided by the release path monitoring.
Nonethe-less, area radiation levels inside the plant are monitored to verify compliance with 10CFR20. These instruments are considerably more sensitive
( 1000x) than required by R.G. l.97 and are sufficient for supporting the detection of significant releases.
Datarminations of accessibility of equipment for service or long term surveillance is the function of health physics personnel, generally-using portable instrumentation. M'nitoring of recordings of area radiation exposure rates from the Contcol Room is not a substitute-for this health physics function.
However, exposure rate monitoring equipment in areas outside containment have an upper range of 10 R/Hr., which is adequate for initial assessments of accessibility.
These ranges are based on background reading in the areas in which they are located.
Should personnel entry be required in areas where these monitors have gone off scale or indicate a high radiation area a health physics escort would accompany personnel into these areas using portable instrumen-tationtoassessradjacionlevels.
The high range for portable instrumen-tation at CR-3 is 10 R/Hr. We do not anticipate, even under emergency conditions, sending personnel into radiation fields of this magnitude. We believe that this meets the intent of Regulatory Guide 1.97.
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Pegs 52 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment or Purge Effluent, Noble Gas TYPE & CATECORY:
E, C, 2 RANGE:
CR-3 2x10 6 to 4.5 x 10 uci/cc Xe133, O to 65,000 CFM (Degign-50 000 cm) 5 NRC 10 to 10 uci/cc, O to 110% Design ENVIRONMENTAL QUALIFICATION:
Yes, complies.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, see position.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DISPIAY:
Indicated and Recorded in CR.
SCHEDULE:
Installed POSITION:
Complies The radiation monitoring equipment was originally purchased without Quality Assurance documentation.
Future radiation monitoring equipment will be purchased with the requirement to specify the applicable Quality Assurance practices.
The range was corrected to comply with the requirements of NUREG 0737, Item II.F.1.1.
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Pago 53 CRYSTAL RIVER 3 i
REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Reactor Shield Building Annulus TYPE & CATEGORY:
E 2
RANCE:
N/A ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
Not in CR3 design.
[ '..
l Peck (Comp)ND75-1 l-l
Pago 54 R v:
01 Date: 2/10/88 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Auxiliary Building, Noble Gas TYPE & CATEGORY:
C,E 2
RANGE:
CR 3 2 x10 6 to 4.5 x 10 uci/cc Xe133, 0-200,000 CFM 7
(Degign-15g,680CFM)
NRC 10 to 10 uci/ce, O to 110% Design t
ENVIRONMENTAL QUALIFICATION:
Yes, complies SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, see position.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DISPLAY:
Indicated and recorded in CR.
Concentration available on demand in TSC & EOF.
SCHEDULE:
Installed.
POSITION:
Complies.
The radiation monitoring equipment was originally purchased without Quality Assurance documentation.
Future radiation monitoring equipment will be purchased with the requirement to specify the applicable Quality Assurance practices.
The range was corrected to comply with the requirements of NUREG 0737, Item II.F.1.1.
Peck (Comp)ND75-1
Pago 55 R9v: 01 Date:
2/10/88 CRYSTAL RIVER 3 RECULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Condenser Air Removal System Exhause TYPE & CATECORY:
C,E 2
0 10~0 to10[2 uci/cc Kr(85), see Position RANGE:
CR-3 NRC 10' to 10" uci/cc, O to 110% Design Flow ENVIRONMENTAL QUALIFICATION:
Yes, complies.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, see position.
REDUNDANCY:
No, not required.
PO'JER SOURCE:
lE DISPLAY:
Indicated and recorded in CR.
On demand in TSC & EOF, SCHEDULE:
Installed POSITION:
The condenser air removal system exhausts through the Auxiliary Building (see page 54) in which the flow ig monitored. 7 The range of the monitor in the Auxiliary Building is 2 x 10 to 4.5 x 10 uci/cc Xel33.
The radiation monitoring equipment was originally purchased without Quality I_
Assurance documentation.
Future radiation monitoring equipment will be purchased with the requirement to specify the applicable Quality Assurance l
practices.
The range was corrected to conform to the requirements of NUREG 0737, Item II.F.1.1.
a Peck (Comp)ND75 1
4 Pegs 56 CRYSTAL RIVER 3 s.
REGULATORY CUIDE 1.97 COMPLIANCE TABLE
- VARIABLE:
Common Plant Vent TYPE & CATEGORY:
E-2 RANCE:
NA ENVIRONMENTAL QUALIFICATION:
-NA SEISMIC d
QUALIFICATION:
NA QUALITY ASSURANCE:
NA REDUNDANCY:
NA POWER SOURCE:
NA i
DISPLAY:
NA SCHEDULE:
NA POSITION:
Common plant vent from Auxiliary Building, see page 54.
i l.'
l'3.
l l
Peck (Comp)ND75-1
Pcg3 57 R:v:
03 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Vent from Safety Valves or Atmospheric Dump Valves (Main Steam Line Radiation Monitor) - See position.
TYPE & CATEGORY:
E 2
RANGE:
CR-3 8.7 x 10'3 go 2.5 x 10 uci/cc Xe-133 1
NRC 10 to 10 uci/cc (and duration of releases in seconds and mass of steam per unit time).
ENVIRONMENTAL
~
QUALIFICATION:
Yes, see position, SEISMIC QUALIFICAT'^N:
No, not required.
QUALITY ASSURANCE:
Yes, see position.
REDUNDANCY:
No, not required.
1 each atmospheric dump valve POWER SOURCE:
1E/ Battery Backed DISPLAY:
Indicated in CR, recorded on demand SCHEDULE:
Installed POSITION:
Complies The four 24" main steam headers contain a total of 16 relief valves and 2 atmospheric dump valves.
Each atmospheric dump valve discharge is l
monitored for radiation by monitors with readouts in the Control Room. The I
system was calibrated in terms of uci/cc Xe-133 in order to comply with NREG-0737.
The calibration change was completed mid 1986.
Refer to the position on item 33 (page 33) for a measure of steam release per unit time.
Radioactise releases are manually calculated.
This variable is only used during a S.G.
tube rup ture type accident.
The results of this accident do not create a harsh environment, therefore they meet the environmental qualifications for the normal environment, t
i i
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Peck (Comp)ND75-1 f
Pego 58 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
All Other Identified Release Points
-TYPE & CATEGORY:
E 2
RANGE:
N/A ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPIAY:
N/A SCHEDULE:
N/A PO,11 TION:
No other release points, see pages 52 and 54.
Peck (Comp)ND75 1
1 Pego 59 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
All Identified Plant Release Points Particulates and Hologens TYPE & CATEGORY:
E 3
RANGE:
CR-3 Reactor Building 10'11 to 10*7 uci/ce, 0-65,000Cm (Design-50,000 cm)
CR 3 Aux. Building 10 to 10'I uci/ce, 0-200,000C m (Design-156,680 CFM)
~11
~
2 NRC 10' to 10 uci/ce, O to 1101 Design ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE: UPS/DC DISPLAY:
Indicated and recorded in CR, SCHEDULE:
Installed.
(
POSITION:
Complies 2
NF.C required range of 10' to 10 uci/cc can be covered by grab sample capability.
Peck (Comp)ND75-1
\\t Page 60 Rsv: 01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 l
COMPLIAN';E TABLE
'L VARIABLt:
Airborne Radio Halogens and Particulates TYPE & CATECORY:
E 3 a
10
uci/cc 10 to 10to 10' uci/cc RANCE:
CR-3 NRC ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
Vital Bus DISPIAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies Various portable air samplers can be used to obtain the sample which is then taken to the Lab for counting.
(Such as the Radeveo H809 high volume air sampler.)
Also have portable particulate monitors Eberline AMS 2 and AMS 3 on hand.
(5) and 13 mini scalers (Eberline) MS-2.
Scaler up to 500K CPM, AMS 2 up i
to 50K CPM AMS-3 up to 100K CPM.
Once the sample is at the Lab, we have multi-channel gamma ray spectrometer systems to provide the capability of onsite analysis.
l l
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i l
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t Peck (Comp)ND75 1 a
Pags 61 Rev: 01
.'y e Date:
2/10/88 QN:-
e.
,]7 CRYSTAL RIVER 3 5 \\ i' REGULATORY GUIDE 1.97 COMPLIANCE TABLE pL
.v i
,Q VARIABLE:
Plant and Environs Radiation, Portable Instrumenta-ev s
tion x
e TYPE & CATEGORY:
E 3
3 10,3 to 10 R/Hr, complies with position.
RANGE:
CR-3 NRC 10 to 10 R/hr ENVIRONMENTAL QUALIFICATION:
No, not required.
i SEISMIC
. QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWEX SOURCE:
Batteries LISPIAY:
No, not required in CR.
SCHEDULE:
Installed POSITION:
Exjsting portable instrumentation can dotect dose rates from 10" R/Hr to l
10 R/Hr.
In the plant we do not anticipate encountering radiation fields greater than those which can be measured by our current equipment except under severe accident conditions.
Even under accident conditions we do not anticipate sending individuals into greater than 10 R/Hr fields.
There-fore, we meet the intent of Regulatory Guide 1.97 with our current equip-ment.
I Existing instruments Xetex Model 302A - GM Tube 999 R/Hr or equivalent Eberline Teletector - GM Turbe 1000 R/Hr 1 mr/Hr to 1000 Ion Chamber replacements:
Eberline PIC-6A l
R/Hr Radector III - Ion Chamber
.1 mr/Hr to 1K R/Hr i
Peck (Comp)ND75-1
Pego 62 CRYSTAL RIVER 3 RECUIATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Plant and Environs Radioactivity TYPE & CATEGORY:
E 3
)
RANCE:
CR 3 Multi-channel Gamma Ray Spectrometer NRC Isotopic Analysis.
ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALI~i ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPIAY:
No, not required in CR.
SCHEDULE:
Insralled.
POSITION:
Complies.
Additionally, 2-two channel gamma ray spectrometers, which are portable, are available (Eberline SAM 2), as is a multi-channel analyzer with computer which is contracted for with the Deps.rtment of Health and Rehabilitation Services.
This unit is on a truck, and mobile.
I i
Peck (Comp)ND75-1
Pago 63 Rsv:
01 Date:
2/10/88 CRYSTAL RIVER 3 REGUIATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Wind Direction TYPE & CATEGORY:
E 3
RANGE:
CR-3 0-360' NRC 0-360' ENVIRONMENTAL QUALIFICATION:
, No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DC DISPIAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
A Peck (Comp)ND75-1 d
Pags 64 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Wind Speed TYPE & CATEGORY:
E 3
RANGE:
CR-3 0-50 M/Sec.
NRC 0-22 M/Sec.
ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC
'^
QUALIFICATION:
No, not require 7.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DG DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITICN:
Complies.
Peck (Comp)ND75-1
Fage 65 Rsvision 1 CRYSTAL RIVER 3 DATE:
8/4/87 RECULATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Estimation of Atmospheric Stability TYPE & CATECORY:
E 3
RANGE:
CR 3
-5'F to +10*F, see Position NRC
-5'C to +10*C ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
UPS/DC DISPLAY:
Indicated and recorded in CR.
SCHEDULE:
Installed.
POSITION:
In accordance with Regulatory Guide 1.23, Table 1,
the measurement of temperature difference for estimating atmospheric stability requires a range from -1.9'c to +4.0*C for the 100 meter height.
The height distance between temperature measuring points at CR-3 is 142 f t.
At this distance the RGl.23 equivalent range of required temperature to estimate stability in degrees farenheit is -1.48 F to 3.12 F.
Since the actual CR-3 range of
-5 F to +10 F completely bounds the 1.48 F to 3.12 F range, it is totally sufficient for providing an estimate of atmospheric stability.
l Peck (Comp)N75-1 l
l l
l
Pcgs 66 Rsv 01 3/6/87 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Primary Coolant and Sump (Grab S eple)
Gross Activity TYPE & CATEGORY:
E 3
RANGE:
CR-3 1 uci/mi to 10 ci/ml NRC 1 uci/ml to 10 ci/ml ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPIAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
t' Peck (Comp)ND75-7
./
Page 67 CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCC TABLE VARI ABLE:
Primary Coolant and Sump (Grab Sample)
Gamma Spectrum TYPE & CATEGORY:
C, E 3
RANGE:
CR-3 Isotopic Analysis NRC Isotopic Analysis ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
l Peck (Comp)ND75 1
Page 68 CRYSTAL RIVER 3 REGUIATORY CUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Primary Coolant and Sump (Crab Sample) - Boron
. Content TYPE-& CATEGORY:
E 3
RANGE:
CR-3 0 6000 ppm NRC 0 6000 ppm ENVIRONMENTAL QUALIFICATION:
No, not required.
. SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
1:
l l
l l
Peck (Comp)ND75-1
-. -,... _. =, _. -.. _ -... -.. _.... - -.
Paga 69
-CRYSTAL RIVER 3 REGULATORY CUIDE 1.97 COMPLIANCE TABLE
. VARIABLE:
Primary Coolant and Sump (Grab Sample)
Chloride Content TYPE & CATEGORY:
E 3
RANGE:
CR-3 0 2'O ppm NRC 0 20 ppm ENVIRONMENTAL QUALIFICATION:
No, not required.
l:
SEISMIC QUALIFICATION:
-No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
9 l
l-1 Peck (Comp)ND75-1 i
l
Pags 70 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Primary Coolant and Sump (Grab Sample)
Dissolved llydrogen or Total Gas TYPE & CATEGORY:
E 3
RANGE:
CR-3 0-2000 CC (STP)/kg NRC 0-2000 CC (STP)/kg ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
4 Peck (Comp)ND75-1
Pags 71 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Primary Coolant and Sump (Grab Sample) - Dissolved Oxygen TYPE & CATEGORY:
E 3
RANGE:
CR-3
.Not measured, see position.
NRC 0-20 ppm ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
Ref: NRC criteria guidelines on NUREG-0737, Item II.B.3, Post Accident Sampling System, dated July 12, 1982 Criterion 4 of the reference stated that the measurement of oxygen is l
recommended but is not mandatory.
l l
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t 1
I Peck (Comp)ND75-1
Pags 72 CRYSTAL RIVER 3
.)
RECULATORY GUIDE 1.97 COMPLIANCE TABLE VARIAPLE:
Primary Coolant and Sump (Grab Sample) - pH TYPE & CATEGORY:
E 3
RANGE:
CR-3 1 to 13
.NRC 1 to 13 ENVIRONMENTAL QUALIFICATION:
No, not required.
.3 SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
Complies.
se-t I
i l
Peck (Comp)ND75 1 l
t l
Pags 73 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Air (Grab Sample) - Hydrogen Content TYPE & CATEGORY:
E 3
RANGE:
CR-3 0 - 10%
NRC 0 - 10%
ENVIRONMENTAL QUALIFICATION:
No, not required.
SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
- Complies, s
Peck (Co=p)ND75 1
Pags 74 CRYSTAL RIVER 3 REGULATORY GUIDE 1.97 COMPLIANCE TABLE VARIABLE:
Containment Air (Grab Sample) - Oxygen Content TYPE & CATECORY:
E 3
RANGE:
CR 3 Not measured, see position.
NRC 0 - 30%
ENVIRONMENTAL QUALIFICATION:
N/A SEISMIC QUALIFICATION:
N/A QUALITY ASSURANCE:
N/A REDUNDANCY:
N/A POWER SOURCE:
N/A DISPLAY:
N/A SCHEDULE:
N/A POSITION:
The NRC R.G. 1.97 required that Containment Oxygen be measured from 0 to 30% by volume. The category of the variable is 3 and the type is E.
A Type E variable is one that is "monitored as required for use in determin-ing the magnitude of the release of radioactive materials, and for contin-uously assessing such releases." For a Type E variable, Category 3 items are considered as backup variables.
l In discussions with the NRC, it was determined that the NRC expects the operator to compare the oxygen percentage with the hydrogen percentage to determine if the hydrogen formed is being caused by radiolysis or by metal-water reaction, which would be indicative of core damage.
l l
Percentage of oxygen in the containment atmosphere is classified as a Type l
E variable.
The definition of a Type E variable is that it is to be "moni-l tored as required for use in determining the ma6nitude of the release of radioactive materials, and for continuously assessing such releases. How-ever, the percentage of oxygen in the containment atmosphere does not pro-vide the necessary information to determine the magnitude of releases of radioactive materials. At best, it provides a very indirect means of arriving at an order of magnitude estimate.
There are other systems in place that can be used for this purpose. Some of these would be Contain-ment Area Radiation, Radioactivity Concentration or Radiation Level in the Peck (Comp)ND75-1
Page 74A Primary Coolant, Analysis of the Primary Coolant, Gross Activity and Gamma Spectrum of the Primary Coolant and Containment Sump, and Gamma Spectrum of the Containment atmosphere. All of these systems provide a more direct means of determining the magnitude of the release and in addition most are Category 1 variables which means they are qualified to the same extent as a safety-related system.
The only other purpose of this variable then would be to allow the operator to determine what physical process is occurring that is forming the hydro-gen in the Containment.
Radiolysis occurs at all times, and is a slow process.
It causes oxygen and hydrogen to be formed from water, so the percentages of both would increase providing no other processes were happening.
However, during a LOCA, a large amount of steam would be generated along with various other gases and the percentage of both hydrogen and oxygen would tend to be in a very dynamic state, rendering a reasonable decision based on that information virtually impossible.
A decrease in the percentage of oxygen along with an increase in hydrogen would be indicative of a metal-water reaction which in turn indicates core damage. Again, however, much better qualified instrumentation is available that provides a direct indication of cora damage, rather than an indirect indication of core damage.
Some of these systems are: Hot and Cold Leg Water temperatures, Core Exit temperature, Coolant inventory, Degrees of Subcooling, and the systems mentioned for determining the magnitude of the release. Additionally, the problems with a dynamic situation in the con-tainment would also hold true in this case.
The requirement for providing the means of measuring Containment Oxygen content is necessary because existing instrumentation provides more direct indication and are better qualified to perform the function of the required variable.
Peck (Comp)ND75-1 l
r Pega 75 CRYSTAL RIVER 3 REGUIATORY GUIDE 1.97 l
COMPLIANCE TABLE VARIABLE:
Containment Air (Grab Sample) - Gamma Spectrum TYPE & CATEGORY:
E 3
RANGE:
CR-3 Isotopic Analysis NRC Isotopic Analysis ENVIRONMENTAL QUALIFICATION:
No, not required.
F SEISMIC QUALIFICATION:
No, not required.
QUALITY ASSURANCE:
No, not required.
REDUNDANCY:
No, not required.
POWER SOURCE:
N/A DISPLAY:
No, not required in CR.
SCHEDULE:
Installed.
POSITION:
- Complies, i.
l Peck (Comp)ND75-1 i
1
.. -