ML20198R333
| ML20198R333 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/05/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 5211-86-2097, NUDOCS 8606100036 | |
| Download: ML20198R333 (53) | |
Text
_ _ _ _ _ _ _
GPU Nuclear Corporation Nuclear
- =,omg:,r8o Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84-2386 Writer's Direct Dial Nurnber:
June 5, 1986 5211-86-2097 Office of Nuclear Reactor Regulation Attn:
J. F. Stolz, Director PWR Projects Directorate No. 6 U.S. Nuclear Regu'latory Commission Washington, DC 20555
Dear Mr. Stolz:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Emergency Response Capability -
Conformance to Regulatory Guide 1.97 In Reference 1, the USNRC transmitted an evaluation of Three Mile Island Unit 1 conformance with Regulatory Guide 1.97.
GPU Nuclear Corporation (GPUN)
I has completed our review of this document, and' our comments and responses to open items are provided in Attachment 1.
In Reference 1, the NRC states that in several instances GPUN has provided inadequate justification for not environmentally qualifying equipment. We would like to provide clarification on this point. All instrumentation which is operational at TMI-1 and defined as Category 1 or 2 instrumentation either was included on the Environmental Qualification Master List at the time of the Reference 2 submittal, or was included in the subsequent update to the Master List in December 1984 (Reference 3) if required to function in a harsh environcnent.
Regulatory Guide 1.97 does not specify environmental qualification for Category 3 variables.
Our methodology in determining the extent of compliance with Regulatory Guide 1.97 was to identify whether a given TMI-l parameter should be classified as Category 1, 2 or 3, and then to evaluate compliance with requirements associated with that category.
For those parameters for which the TMI-l categorization differed from Regulatory Guide 1.97, GPUN provided the rationale for the deviation.
At this time, we also would like to supplement and update our Reference 2 and Reference 4 submittals regarding Regulatory Guide 1.97. is a newly formatted table identifying, for each parameter, the category appropriate for TMI-1, and the schedule for any modifications to ensure 8606100036 860605 h
PDR ADOCK 05000289 1hD F
PDR l
I i
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation L_.______
5211-86-2097 June 5, 1986 compliance. All Regulatory Guide 1.97 modifications described in Attachment 2 are scheduled for completion during the Cycle 7 refueling outage, or earlier.
Justification is provided for any exceptions taken to the Regulatory Guide 1.97 provisions. All changes from the information provided in References 2 and 4 are highlighted with bar lines. summarizes the changes from previous submittals.
Sincerely, r'JoA.g H. D. Hukill Vice President and Director, TMI-l HDH:jh:2769f/0593A Attachments
References:
(1) USNRC Letter, John F. Stolz to Henry D. Hukill, " Emergency Response Capabilities - Conformance to Regulatory Guide 1.97," November 25, 1985 (2) GPUN letter, 5211-84-2252, H. D. Hukill to J. F. Stolz, "NUREG-0737, Supplement 1 - Regulatory Guide 1.97 (Revision 3)," October 1,1984 (3) GPUN letter, 5211-84-2292, R. F. Wilson to J. F. Stolz, " Environmental Qualification of Electrical Equipment," December 11, 1984.
(4) GPUN letter, 5211-84-2279, H. D. Hukill to J. F. Stolz, "NUREG-737, Supplement 1-Regulatory Guide 1.97 Revision 3," November 9,1984.
L GPUN COMMENTS ON USNRC INTERIM REPORT ON TMI-l COMPLIANCE WITH REGULATORY GUIDE 1.97 AND RESPONSE TO OPEN ITEMS The following paragraphs address NRC comments and open items presented in the NRC assessment of the adequacy of TMI-l compliance with Regulatory Guide 1.97,
" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident", Rev. 3:
1.
The NRC report identified that the TMI-l evaluation identifies deviations with respect to environmental qualification for the following parameters:
RHR Heat Exchanger Outlet Temperature Accumulator Tank Level and Pressure Containment Spray Flow Containment Sump Water Temperature Component Cooling Water Temperature to Engineered Safety Feature (ESF)
System Status of Standby Power and Other Energy Sources Important to Safety Each of these parameters is discussed below:
a.
RHR Heat Exchanger Outlet Temperature - Instrumentation has been incorporated on TMI-l E.Q. Master List (GPUN Letter 5211-84-2292, December 11, 1984).
b.
Accumulator Tank Level and Pressure - GPUN considers these variables Category 3 for TMI-1, for reasons as discussed in item 3 below.
On this basis, the requirement for environmental qualification in accordance with 10 CFR 50.49 does not apply.
c.
Containment Spray Flow - Instrumentation has been incorporated on TMI-l E.Q. Master List (GPUN Letter 5211-84-2292, December 11, 1984).
d.
Containment Sump Water Temperature - GPUN considers this variable Category 3, for reasons as discussed in item 8 below.
On this basis, the requirement for environmental qualification in accordance with 10 CFR 50.49 does not apply.
e.
Component Cooling Water Temperature to Engineered Safety Feature (ESF) System - Instrumentation is not located in a harsh environment; therefore, environmental qualification to harsh environmental conditions is not appropriate and is not required in accordance with 10 CFR 50.49.
f.
Status of Standby Power and Other Energy Sources Important to Safety -
Instrumentation is not located in a harsh environment; therefore, environmental qualification to harsh environmental conditions is not appropriate and is not required in accordance with 10 CFR 50.49.
i
2.
RCS Pressure - Range - Reg. Guide 1.97 recommends instrumentation to measure this variable with a range from 0 to 3000 psig.
GPUN will be in compliance with this requirement by Refueling Outage 7R.
3.
Accumulator Tank (Core Flood Tank) Level and Pressure - The NRC report specifies that GPUN should designate either level or pressure as the key variable to determine accumulator discharge, and provide instrumentation for that variable that meets the requirements of 10 CFR 50.49.
The primary purpose of Core Flood Tank Pressure is to be able to monitor and thus maintain tank pressure during normal operation at a minimum required operating pressure to ensure its availability to perform its intended function during an accident such as a design basis LOCA event.
During accident events, this variable is not monitored.
The Core Flooding System is totally passive, and hence no operator actions are needed to mitigate the consequences of an accident based on core flood tank pressure indication. Thus Core Flood Tank Pressure cannot be considered a key variable, and categorization as a Category 3 variable is appropriate.
The TMI-l Core Flood Tank Pressure indication is in accordance with the Reg. Guide 1.97 requirements for a Category 3 variable.
Similarly, the primary purpose of Core Flood Tank Level indication is to provide information to monitor and maintain tank inventory of borated water during normal operation. Monitoring of this variable is required to assure that an inventory greater than the minimum assumed volume is available for injection into the RCS during accident conditions such as design basis LOCA events. Thus, Core Flood Tank Level indication cannot be considered a key variable, and categorization as Category 3 is appropriate. The TMI-l Core Flood Tank Level indication is in accordance with the Reg. Guide 1.97 requirements for a Category 3 variable.
4.
Pressurizer Level - The NRC report specifies that GPUN has not provided sufficient justification for deviating from the recommendations for this variable with respect to categorization as Category 2.
Also, the NRC report contends that GPUN has not met the single failure criterion by not providing an environmentally qualified temperature compensation element.
Regulatory Guide 1.97 specifies that categorization as Category 1 applies to key variables, and that categorization as Category 2 generally applies to indication for designating system operating status.
It is GPUN's position that the pressurizer level is an indication of system operating status but not a key variable.
Pressurizer level is used as an indication that HPI throttling is allowed. The operator throttles HPI if he has adequate subcooling margin and pressurizer level is on scale; however, failure to throttle under these conditions does not result in inadequate core cooling.
In addition, HPI is throttled upon reading 100F' subcooling, regardless of pressurizer level.
In this latter case, RCS pressure and temperature indicate whether PTS or NDT limits are violated.
Therefore, for TMI-1, pressurizer level indication cannot be considered a key variable and categorization as Category 2 is appropriate. L
1 4.
Pressurizer Level (Cont'd. )
The TMI-l pressurizer level indication is in accordance with the Regulatory Guide 1.97 requirements for Category 2 instrumentation, with the exception of environmental qualification for the temperature compensation element. The pressurizer level is normally temperature compensated by RC-2-TE 1/2.
An assessment of the effects of RC-2-TE 1/2 failure is presented in the following table. Three environmentally qualified pressurizer differential pressure instruments are available from the plant computer (these instruments meet the R.G.1.97 requirements for a Category 2 instrument).
In addition, the pressurizer temperature can be compared to the saturation temperature.
If the two do not agree, then pressurizer level can be manually compensated using the saturation temperature. The operator training program currently includes instruction on the use of instrumentation under degraded containment conditions. This training will be augmented to clarify the use of pressurizer level indication with a degraded containment environment.
Thus, although the temperature compensation element is not environmentally qualified, the pressurizer level indication is in accordance with 10 CFR 50.49. t
m._._.._
._m j
l EFFECTS OF POTENTIAL PRESSURIZER LEVEL INDICATION TEMPERATURE COMPENSATION ELEMENT (RC-2-TE 1/2) FAILURE EFFECT DN EFFECT ON EFFECT DN RC-2-TE 1/2 l PRESSURIZER LEVEL PTS /NDT LINITS l CORE COOLING l
C(M4ENT I
I I
Fails closed l Below 530*F, maximum errorl Pressurizer will not be I No effect. Core cooling is not l
shorted I is less than 100 inches. I water solid when i dependent on pressurizer level.
l l Largest error approaches I indicated pressurizer l Core cooling is maintained l
I minus 200 inches and I level is below 300 l since subcooling margin asst l
l occurs at highest actual I inches and temperature i be maintained regardless of I
l pressurizer temperatures. I is below 530*F. Above l indicated pressurizer level.
I I Above 100*F pressurizer 1 500*F, PTS /NDT limits l
l 8
I could be water solid and I are not in effect.
l l
T l indicate on scale.
l l
l l
l l
l c Plant computer providks three l
l l
l channels of pressurizer l
l l
l differential pressure that l
l l
l would be unaffected by the l
I l
l RC-2-TE 1/2 failure.
I I
I I
l l
l l
o Any small break LOCA large l
l l
l enough to cause a seriously l
l l
l degraded environment will l
l l
l provide sufficient pressure l
l l
l relief to prevent an NDT Fails open l At low pressurizer l No effect l No effect. Core cooling is not I
violation.
I levels, level will l
l dependent on pressurizer level.
l l indicate offscale low.
l l Core cooling is maintained since 1 I At high levels, indication!
I subcooling margin must be l
I will be offscale high l
l maintained regardless of I
l before the pressurizer is l l indicated pressurizer level.
l l actually water solid.
l l
l l
l l
1 1
I i
l 1
I l
l I
I I
I l
1
5.
Pressurizer Heater Status - The NRC report identifies that Regulatory Guide 1.97 recommends instrumentation to monitor the current drawn by the pressurizer heaters.
In addition, the NRC report identifies that (a)
NUREG-0737 Section II.E.3.1 requires a number of the pressurizer heaters to have the capability of being powered by emergency power sources, with technical specifications changed accordingly; and (b) the Standard Technical Specifications, Section 4.4.3.2, require that the emergency pressurizer heater current be measured quarterly.
With respect to the Regulatory Guide 1.97 recommendation for monitoring current drawn by the pressurizer heaters, the most appropriate means for determining availability of power to the heaters is the existing status indication, since the TMI-l emergency pressurizer heaters are controlled in an on-off manner.
The most direct and effective measure of heater performance is the response of the reactor coolant system pressure.
Current indication would not provide a direct measurement of heater performance.
At TMI-1, the operator has indication of the existing load on the diesel, which enables him to determine (based upon the known maximum power consumption of the heaters) whether he can load the heaters without overloading the diesels.
Should the operator err in adding the heaters, he would have indications (including overload alarm) that the diesel had been overloaded.
This parameter, and not heater current, is the indication of concern.
With respect to the NUREG-0737 requirement that a number of pressurizer heaters have the capability of being powered by emergency power sources, THI-l Technical Specification 4.6 " Emergency Power System Periodic Tests" specifies that the periodic tests include transfer of pressurizer heater groups 8 and 9 from the normal power bus to the emergency power bus at least once each refueling outage, and this is performed using TMI-l Surveillance Procedure 1303-11.55, " Pressurizer Heaters Emergency Power Functional Test."
In addition, the TMI-l Preventive Maintenance Program requires that a resistance check of the pressurizer heaters be performed in accordance with TMI-l Maintenance Procedure E-8 " Pressurizer Heaters -
Resistance Check."
With respect to the Standard Technical Specifications, NUREG-0103,
" Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors", Rev. 4, which is the current revision, does not include a requirement for measuring emergency pressurizer heater current.
In addition, it should be noted that the Standard Technical Specifications provide guidelines for plants preparing Technical Specifications while undergoing Operating License review. The Standard Technical
, Specifications are not in themselves requirements for new plants.
Implementation of revisions to the Standard Technical Specifications is not required for Operating facilities, nor are associated modifications to design..
I
6.
Quench Tank Temperature - Regulatory Guide 1.97 specifies a Category 3 Type D indication of Quench Tank temperature, with a range of 50 F to 750*F, to monitor operation. At TMI-1, instrumentation currently is provided with a range of 50*F to 275'F.
During normal operation, the Reactor Coolant Drain Tank (Quench Tank) temperature would not approach the upper bound of the existing TMI-l range (275'F).
Upon reactor trip, the RCDT is isolated.
An RCDT temperature approaching the maximum indicated temperature of 275'F woul<1 be indicative of inleakage into the tank.
The RCDT has a relief valve set at 40 psig so that the tank temperature normally would not go above 287*F.
The RCDT has a rupture disc set at 55 + 6 psig. Therefore, the tank bulk fluid temperature can never go i
above 308 F.
In order for the tank pressure to increase above 40 psig, the PORV or safety valve would have to open, in which case the pressure would increase above 55 psig rapidly. The RCDT temperature would be between 287'F and 308*F for a very short period of time only.
RCDT pressure is indicated and has a range of 0 to 100 psig.
Capability to monitor the complete range of postulated RCDT temperatures will be provided by Refueling Outage 7R.
7.
Containment Atmosphere Temperature - Regulatory Guide 1.97 recommends Category 2 indication of Containment Atmosphere Temperature to indicate accomplishment of cooling.
In Reference 1, GPUN provided a discussion that the purpose of the Containment Atmosphere Temperature indication is to provide indication that the Reactor Building Cooling and/or spray system is accomplishing its design objective, i.e., to cool the Reactor Building atmosphere and to maintain it below its designed temperature limit following any postulated design basis accident.
This objective is primarily confirmed by observation that the Category 1 qualified Containment Pressure indications are decreasing. Accordingly, Containment Atmosphere Temperature indications provide a backup to the pressure indicators. Therefore, GPUN considers this parameter Category 3 for TMI-1.
I GPUN maintains that the key variable for reactor building monitoring is reactor building pressure which is measured by Category 1 l
i nstrumentation. This is a B&W Owners Group position which has been found acceptable by NRC on other plants.
8.
Containment Sump Water Temperature - Regulatory Guide 1.97 recommends a Category 2 indication for containment sump water temperature, for the purpose of monitoring operation. '
l
i 8.
Containment Sump Water Temperature (Cont'd.)
At TMI-1, no automatic or manual actions are based on containment sump water temperature. The system and pump design assures that adequate NPSH is available for the range of temperatures specified in Regulatory Guide 1.97.
For these reasons, GPUN considers containment sump water temperature a Category 3 variable.
The TMI-1 containment sump water temperature indication is in compliance with the Regulatory Guide 1.97 requirements for Category 3 variables, j
9.
Component Cooling Water Flow to ESF System - Regulatory Guide 1.97 recommends Category 2 indication for component cooling water flow to the ESF system in order to monitor system operation.
The NRC report indicates 1
that the alternate indications proposed by GPUN (pump status and system temperature) would not determine proper system operation should flow l
blockage or a pipe rupture occur.
Since all decay heat and nuclear services closed cycle cooling water valves are either manual valves, which are normally open, or motor operated valves, controlled from and having position indication in the control room, GPUN considers that indications of pump status and system temperature provide adequate capability for monitoring system operation.
l Pump status is provided by indication of pump discharge pressure.
NSCCW pump discharge pressure indication is available in the control room.
DHCCW pump low flow condition is alarmed in the control room.
Based on these indications, the operator would be fully aware of a flow blockage situation.
With respect to pipe rupture occurrences in the DHCCW and NSCCW systems:
)
1.
The DHCCW system piping is not subject to pipe rupture considerations based on its location in the Auxiliary Building and the fact that it is itself not a high energy piping system.
2.
The NSCCW system likewise is not subject to pipe rupture considerations except for that portion located inside containment to provide reactor coolant pump motor cooling.
Pipe rupture in this portion of the system would cause an abnormal (low) surge tank level alarm in the control room. The affected portion of the piping would be isolated automatically on low surge tank level with 1600 psig RCS HPI signal.
- 10. Radioactive Gas Holdup Tank Pressure - Regulatory Guide 1.97 recommends radioactive gas holdup tank pressure indication to indicate storage capacity.
At TMI-1, indication is not available in the Control Room.
Local indication is available on demand, which is located on the radioactive waste control panel and is accessible af ter an accident. The range of the local indication is 0-100 psig. - - -.
?
Attache.ent 2 Regulatory Guide 1.97 Rev. 3 Recommendations TMI-l m,
PWR Variables - R.G. 1.97 Type B Variables Evaluation of Reactivity Control TMI-l Compliance Neutron Flux Table 18 Item 1 Control Rod Position Table 3B, Item 1 RCS Soluble Boron Concentration Table 4. Item 1 RCS Cold Leg Water Temperature Table IB, Item 2 Core Cooling RCS Hot Leg Hater Temperature Table IB, Item 3 RCS Cold Leg Water Temperature Table IB, Item 2 RCS Pressure Table IB, Item 4 Core Exit Temperature Table IB, Item 5 Coolant Inventory Table 18, Item 6 Degrees of Subcooling Table IB, Item 7 Maintaining Reactor Coolant System Integrity RCS Pressure Table IB, Item 4 Containment Sump Hater Level Narrow Range Table 2B, Item 1 Hide Range Table IB, Item 8 Containment Pressure Table 18, Item 9 Maintaining Containment Integrity Containment Isolation Valve Position Table 18, Item 10 Containment Pressure Table IB, Item 9 Type C Variables Fuel Cladding Core Exit Temperature Table 18, Item 5 Radioactivity Concentration or Table 38, Item 2 Radiation Level in Circulatory Primary Coolant Analysis of Primary Coolant (Gamma Spectrum)
Table 4, Item 2 Reactor Coolant Pressure Boundary RCS Pressure Table IB, Item 4 Containment Pressure Table IB, Item 9 Containment Sump Hater level Narrow Range Table 28, Item 1 Hide Range Table 18, Item 8 Containment Area Radiation Table IB, Item 11 Effluent Radioactivity - Noble Table 28, Item 2 Cas Effluent from Condenser Air Removal System Exhaust 3308/l
Containment RCS Pressure Table IB, Item 4 Containment Hydrogen Concentration Table 18, Item 12 Containment Pressure Table IB, Item 9 Containment Effluent Table 28, Item 3 Radioactivity - Noble Gases from Identified Release Points Effluent Radioactivity - Noble Table 2B, Item 4 Gases from Auxillary Building Type D Variables Residual Heat Removal (RHR) or Decay Heat Removal System i
l RHR System Flow Table 18, Item 13 i
RHR Heat Exchange Outlet Table 28 Item 5 Temperature Safety Injection Systems Accumulator Tank Level Table 38, Item 3 Accumulator Tank Pressure Table 3B, Item 4 Accumulator Isolation Valve Position Table 3B, Item 5 Boric Acid Charging Flow Table 4, Item 3 Flow in HPI System Table 18 Item 14 Flow In LPI System Table 18, Item 13 Refueling Water Storage Tank Level Table IB, Item 15 Primary Coolant System Reactor Coolant Pump Status Table 3B, Item 6 Primary System Safety Relief Valve Table 28 Item 6 Positions or Flow through or Pressure in Relief Valve Lines Pressurizer Level Table 28. Item 7 Pressurizer Heater Status Table 38 Item 7 Quench Tank Level Table 38 Ittm 8 Quench Tank Temperature Table 38, Item 9 Quench Tank Pressure Table 3B, Item 10 Secondary System (Steam Generator)
Steam Generator Level Table IB, Item 16 Steam Generator Pressure Table 18, Item 17 Safety / Relief Valve Positions or Table 3B, Item 11 Main Steam Flow Main Feedwater Flow Table 38, Item 12 Auxillary Feedwater or Emergency Feedwater System Auxiliary or Emergency Feedwater Flow Table IB, Item 18 Condensate Storage Tank Hater Level Table 18, Item 19 I
i 3308/2 1
1
...---,..-----,,--.,.__._--v
_____,--.__.--,_-.,--_.,,_,---_.-,_,---.._-n---
Containment Cooling Systems Containment Spray Flow Table 28. Item 8 Heat Removal by the Containment Table 2B, Item 9 Fan Heat Removal System Containment Atmosphere Temperature Table 38. Item 13 Containment Sump Water Temperature Table 3B, Item 14 Chemical and Volume Control System Makeup Flow-In Table 2B, Item 10 Letdown Flow-Out Table 3B, Item 15 Volume Control Tank Level Table 2B, Item 11 Cooling Water System Component Cooling Water Temperature Table 2B, Item 12 to ESF System Component Cooling Water Flow Table 4, Item 4 to ESF System Radwaste Systems High Level Radioactive Liquid Tank Level Table 3B, Item 16 Radioactive Gas Holdup Tank Pressure Table 4, Item 5 Ventilation Systems Emergency Ventilation Damper Position Table 28. Item 13 Power Supplies Status of Standby Power and Other Energy Table 2B, Item 14 Sources Important to Safety Type E Variables Containment Radiation Containment Area Radiation - High Range Table 18, Item 11 Area Radiation Radiation Exposure Rate Table 3B, Item 17 Airborne Radioactive Materials Released from Plant Containment or Purge Effluent-Noble Gases Table 28, Item 3 and Vent Flow Rate Reactor Shleid Building Annulus-Noble Gases Table 4, Item 7 and Vent Flow Rate Aux 111ary Building - Noble Gases Table 28 Item 4 and Vent Flow Rate Condenser Air Removal System Exhaust-Table 28, Item 2 Noble Gases and Vent flow Rate Common Plant Vent or Multipurpose Vent-Table 4, Item 8 Noble Cases and Vent flow Rate 3308/3
Airborne Radioactive Materials Released from Plant (Continued)
Vent from Steam Generator Safety Relief Valves Table 28, Item IS or Atmospheric Dump Valves-Noble Gases and Vent Flow Rate All Identified Plant Release Points-Table 3B, Item 18 Particulates and Halogens Airborne Radlobalogens and Particulates Table 3B, Item 19 Plant and Environs Radiation Table 38, Item 20 Plant and Environs Radioactivity Table 38 Item 21 Meteorology Hind Direction Table 38, Item 22 Hind Speed Table 3B, Item 23 Estimation of Atmospheric Stability Table 3B, Item 24 Accident Samplina Capability (Analysis Capability Onsite)
Table 3B, Item 25 Primary Coolant and Sump Gross Activity (Grab Sample)
Primary Coolant and Sump Gamma Table 3B, Item 26 Spectrum (Grab Sample)
Primary Coolant and Sump Boron Table 3B, Item 27 Content (Grab Sample)
Primary Coolant and Sump Chloride Table 38, Item 28 Content (Grab Sample)
Primary Coolant and Sump Olssolved Hydrogen Table 38, Item 29 or Total Gas (Grab Sample)
Primary Coolant and Sump Dissolved Oxygen Table 38, Item 30 (Grab Sample)
Primary Coolant and Sump pH Table 38, Item 31 (Grab Sample)
Containment Air Hydrogen Content (Grab Sample)
Table 3B, Item 32 Containment Air Oxygen Content (Grab Sample)
Table 3B, Item 33
~
Containment Air Gamma Spectrum (Grab Sample)
Table 38 Item 34 3308/4 x
Table lA Cateoorv 1 f'arameters R.C. 1.97 Reauirseents Notes an THI-l Cameliance 1.
Eauinment Oualification The instrumentation should be qualified in ac-Field sensors (i.e. transmitters) are located in various plant areas, whereas the cordance with Regulatory Guide 1.89, "Qualifica-secondary loop such as indicators and recorders and located in the control room.
i tion of Class IE Equipment for Nuclear Power In the column on Table IB which identifies the environment, the term " Marsh" indi-Plants." and the methodology described in cates that part of the loop, such as field sensors, are located in a harsh environ-NUREG-0588. " Interim Staf f Position on Environ-mert, and
- Mild" indicates that all components within the loop are located in a mild mental Qualification of Safety-aelated Electrical environment. Equipment installed in the plant prior to 2/22/83 was qualified to 00R Equipmeat."
Gi.idelines and equipment installed after 2/22/83 was qualified to NUREG 0588 l
Category 1.
Instrumentation whose ranges are required to en-tend beyond those ranges calculated in the most Cospliance with the enviromental qualification requirement for Category 1 parameters I
severe design basis accident event for a given in an environment identified as harsh signifies that equipment has been included in
(
wariable should be qualified using the guidance the TMI-I EQ Master t.ist (GPUN Letter 5211-84-2292 December 11, 1984), which provided in paragrapm 6.3.6 of ANS-4.5.
documents compliance with 10CFR50.49. If the instrument loop components including I
l field sensors are located in a mild area, they are not subject to the environmental Qualification applies to the complete instrumen-qualification requirement.
tation channel f rom sensor to display where the display is a direct-indicating meter or recording The qualification of all the control room devices, i.e. indicators, recorders, etc.,
device. If the instrumentation channel signal is are considered to be satisfactory since they are high grade industrial equipment, to be used in a computer-based display, record-designed procurred and installed in accordance with quality assurance requirements ing, or diagnostic program, qualification applies of 10CFR50 Appendia B.
f rom the sensor up to and including the channel l
isolation device.
l 2.
Seismic Oualification l
The seismic portion of qualification should be in Sensors and their related accessories which are mounted locally are seismically i
accardance with Regulatory Guide 1.100, " Seismic qualified to the appropriate response spectra. The displayed devices, such as I
Qualification of Electric Equipment for Nuclear indicators, recorders, etc. which are located on panels in the Control Room have Power Plants." Instrumentation should continue been previously qualified to generic envelope spectra.
to read within the required accuracy following, but not necessarily during, a safe shutdown Control panels in the Control Room are being evaluated to verif y seismic adequacy.
earthqua e.
This evaluation and any corrective actions necessary, are scheduled for completion by the Cycle 7 refueling outage.
l 3.
Redandancv No single failure within either the accident-mon-Separation requirements of TMI-1 are in accordance with the design requirements of itoring instrumentation, its ausiliary supporting the TMI-l FSAR as described in internal procedures.
'eatures, or its power sources concurrent with the f ailures that are a condition or result of a specific accident should prevent the operators i
I trom being presented the information necessary for them to determine the safety status of the plant and to bring the plant to and maintain it in a safe condition following that accident.
'G08/5
T Tabla IA Cateanrv 1 Parameters R G. 1.97 Genuirements hates on TMI-I ro liance 3.
Redundance (Continued) idhere f ailure of one accident-monitoring channel results in information ambiguity (that is, the redundant displays disagree) that could lead operators to defeat or f ail to accomplish a re-guered safety function additional information should be provided to allow the operators to deduce the actual conditions in the plant. This may be accomplished by providing additional inde-pendent channels of information of the same vari-able (.ddition of an identical channel) or by providing an independent channel to monitor a different variable that bears a known relation-ship to the multiple channels (addition of a diveru channel). Redundant or diverse channels should be electrically independent and physically separated from each other and from equipment not classified important to safety in accordance with Cegulatory Guide 1.75. " Physical Independence of Electric Systems.* up to and including any isola-tion device. Within each redundant division of a safety system, redundant monitoring channels are not needed emcept for steam generator level instrumentation in two-loop plants.
4 Pa=er Source The instrumentation should be energized from station standby power sources as provided in Re platory Guide 1.12. -Criteria for Safety-Re-leted Electric Power Systems f or Nuclear Po.er plants." and should be backed up by batteries where momentary interruption is not tolerable.
5.
Channel Availability The instrumentation channel should be available prior to an accid +nt estept as provided in l
paragraph 4.11
- ception." as defined in IEEE Std 279-1971. -Cri..ia ter Protection Systees f or Nuclear Power Generating Stations." or as specified in the technical specifications.
6.
Qualitw Assurance The recommendations of the follo.ing regulatory TPI-I equipment is cu sidered in compliance if the equipment is classified as IE quides pertaining to quality assurance should be and therefore has been designed, procurred, installed and maintained in accordance followed:
with the TMI-I QA Program at the time of installation. See GPUN 004 Plan Appendia C for current positions.
D08/6
Table 1A Catacorv 1 Parameters R_G. 1.97 Gem rements psotes on TMI-I Conoliance ts. Ot alitw Assurance (Contiu)
Regulatory bide 1.28
- Quality Assurance Progree Requireeents (Design and Construc-tion)"
l Regulatory Lice 1.30
" Quality Assurance (Safety 6ide 30)
Regairements for the l
Installation. Inspe<-
tion and Testing o' l
l Instrumentation and l
Electric Equipment" l
Regulatory kide 1.38
- 0uality Assurance l
Requirements for l
Packaging. Shipping, Eeceiving. Storage, i
and Handling of Items for Water-Cooled Eclear Power Plants" Rtgulatory Guice 1.58
" Qualification of Eclear Power Plant Inspection. Enamina-tion, and Testing Personnel" Regulatory hide 1.64
" Quality Assurance Requirements for the Design of E clear Power Plants" Regulatory Gide 1.74
" Quality Assurance Terms and Definitions" Regulatory bide 1.88
" Collection. Storage, and Maintenance of Eclear Power Plant Quality Assurance Records
- Eegulatory bide 1.123
" Quality Assurance Requirements for Con-trol of Procurement of Items and Services f or Aclear Po.er Plants" Cegulatory b ide 1.161
" Auditing of Quality Assurance Programs for A clear Power Plants" 33C8/7
Table 1A Catecorv 1 Parameters R.G. 1.97 Recai reet s hotes en TMI-1 Comoliance f,. Qualit Assura=ce - (continued)
Regulatory Lice 1.146
- Qualification of Q ality Assurance Program Audit Per-sonnel for tWear Power Plants" Deference to the above regulatory guides (except Regulatory hides 1.30 and 1.38) is being made pending issance of a revision to Regulatory Guide 1.28 that is ucder development (Task RS 002-5) and that will endorse ANSI /ASME M A-t-1979, " Quality Assurance Program Require-ments for % clear Po.er Plants.
F. Diselar aad Geterdiec Continuous real-t'me display should be provided.
4 The indication may be on a dial, digital display, CRT, or stripchart recorder.
CL; cording of instrumentation readout inf ormation sr.ould be prowiced for at least one redundant (hannel.
If direct and immediate trend or transicit infor-nation is essential for operator information or action, the recording should be continuously available on redundant dedicated recorders.
Otherwise, it may be continuously updated. Stored in computer memory, a d displayed on demand.
n Intermittent displays such as data loggers and scanning recorders may be used if no significant transient response information is likely to be lest by such devices.
- 8. Paage If t.o or more instruments are needed to cover a particular range, overlapping of instrument span should be provided. If the reqaired range of monitoring instrumentation results in a loss of instrumentation sensitivity in the normal operat-ing range, separate instruments should be used.
3108/8
I Table 1A Catecorv 1 Parameters R.G. 1.97 Retireeeats Notes on TMI-l Comoliance
- 9. Eeuinmeat Yeectification Types A. B. and C instrwents designated as A hs, man factors review has been performed with respect to control panel l
Categories I and 2 should be specifically identi-identification of Types A. B and C vsriables designated as Categories 1 and 2.
I f eed with a common designation on the ccatrol l
panels so that tne operator can easily discern As a folicw-up to findings in the 1%0 TMI-1 Control Room Design Review, the entire j
that they are intended f or use under accident IMI-l control room was relabeled; this labeling involw d setting up an uncluttered a
l (onditions.
hierarchical label ccior ano size scheme similar to those recommended in l
NUREG-0 700. GPLH feels that if large tags were added for Reg. Guide 1.37 wariables, they would add to panel clutter, obscure more important labels, and I
cause confusion with esisting ESAS panel label colors and reduce meaning, or would upset the main CR label color hierarchy. Smaller tags would be overlooked or confused with the six-symbol ICS/NNI power code labeling, therefore, GPUN has concluded that the potential benefits to identifying Category 1. Type A, B, and C conditions on the centrol panels are outweighed by the detriments such an addition to the control room would cause.
l l
?0. Interfaces The transmission of signals for other use should Category 1 instrument channels are electrically isolated f rom nonqualified portions be throug% isolation devices that are designated of the loop up to and including the isolation device.
as part of the monitoring instrumentation and that meet the provisions of this document.
1 II. Serviciso. Testine_ and Calibration Servicing, testing, and calit ration programs Category 1 instrumentation is part of the planned maintenance program. As should be specified to maintain the capability of desc ribed in Chapter 13 of the FSAR and Technical Specifications testing is per-the monitoring instrumentation. If the required formed on instrument strings on a regular basis. The testpoints for the instrument interval between testing is less than the normal strings are under administrative control to prevent unplanned testing. The time interval between plant shutdowns, a capabil-isolators f or the instrument strings are accessible during and following a design ity for testing during power operation shoulo be basis event (considering posted radiation fields). Normal calibration of provided.
instrumentation located inside containment is on a refueling cycle basis.
hAenever means for removing cher.nels from service are included in the design, the design should facilitate administrative control of the access to such removal means.
The design should facilitate administrative con-trol of the access to all setpoint adjustments, module calibration adjustments, and test points.
Periodic checking, testing, calibration, and cal-ibration werification should be in accordance with the applicable portions of Regulatory Guide 1.118. " Periodic Testing of Electric Power ar.d Protection Systems.* pertaining to testing of icstrument channels. (Mote: Response time test-ing not usually needed.)
3308/9
I l
l
{
Table IA Cateaorv 1 Parameters l
R.C. 1.97 Geeui rewats hotes on TMI-l Comoliance II. Serviciac. Testine. and Calibration (Continued)
The location of the isolation device should be such that it would be accessible for maintenance Curing accident concitions.
- 12. Nean Factors The instrumentation should be designed to facili-Compliance with this requirement means that for a given display device, the Human tate the recognition, location, replacement, re-Factors Evaluation has been completed as part of the Control Room Design Review pair, or adjustment of malfunctioning components Process Human factors analysis recommendations were part of the CRDR submittal (per or modales.
Letter No. 5211-84-2153, dated 6/29/84).
The ocnitoring instrumentation design should mini-mize the development of conditions that would cause meters, annunciators, recorders, alarms, etc., to give anomalous indications potentially confusing to the operator. Human f actors analysis l
should be used in determining type and locations of d uplays.
l The the entent practicable, the same instruments should be used for accident monitoring as are used for the eormal operations of the plant to enable the operators to use, during accident situations, instruments with which they are ecst familiar.
- 13. Direct weasurew et To the entent practicable, monitoring instrumen-tation inputs should be from sensors that direct-l ly measure the desired variables. An indirect measurement should be made only when it can be shown by analysis to provide unamoiguous informa-tion.
3308/10
Table IB Evaluation of TMI-I Compliance with R.G. 1.97 Requirements (Category 1 Parametsrs) veriable R.G. 1.97 TMI-l R.G. 1.97 Environment Areas of Non-Comments Schedule Classi f.
Classif.
Ranae c anal iance 1.
heutron Flum 1
1 10-61 to Harsh Capability Capability will be installed 100% full not provided during refueling outage 7R power 1
l l
2.
RCS Cold Leg 1
1 SS*F-700*F Harsh Range TMI-l range is 50*F Water Temperature (TE-959, 961) to 650*F. GPUN con-TE-959. 901 siders this suf ficient TI-959A, 961A based on the fact that at maximum steam gener-ator pressure of 1200 psig, saturation temp-erature is 600*F.
Thus, T-cold would at all times be less than or equal to this value.
i This is a B&W Owners Group generic position.
Recording Recording is f rom orig-Computer input will be inal plant installation moved to qualified instruments (Non-loop by refueling Nuclear Instrumentation) outage 7R.
which is not the same as a qualified loop.
3.
CCS Hot Leg Water 1
1 50*F-700*F Harsh Range TMI-I range is 120*F to Temperature (TE-958, 960) 920*F. At temperatures TE-958. 960 less than 300*F the TI-958A, 960A plant will be in the decay heat removal mode at cold shutdown, and tot leg water tempera-ture indication is not required. Therefore, GPON considers the existing range suffi-
- cient, Recording Recording is from orig-Computer input will be inal plant installa-moved to a qualified tion instruments (Non-loop by refueling out-Nuclear Instrumentation) age 7R.
which is not the same as a qualified loop.
3308/11
Table 18 Evaluation of TMI-1 Complitnce with R.G. 1.97 Requirements (Category 1 Parameters) variable R.G. 1.97 TMI-1 R.G. 1.97 Environment Areas of Non-Comments Schedule Classif.
Classif.
Ranoe canaliance 4.
RCS Pressure 1
1 0-3000 psig Harsh Redundancy.
Redundancy is provided PT-949, 963 (PT-949, 963)
Control Room except for Control Room PI-949A, 949 Display (Indi-Display, for which one cation and Re-channel only provides cording)
IE continuous indication.
Qualified redundant display is provided on the remote shutdown panel.
Recording is from original Computer input will be plant installation (Non-moved to a qualified loop Nuclear Instrumentation) by refueling outage 7R, which is not the same as providing recording and a qualified loop.
on-demand control room display.
Range IMI-1 range currently is GPUN will be in compliance 0-2500 psig.
by Refueling Outage 7R.
5.
Core Emit Temp-1 1
200*F-2300*F Hars%
None crature (Cables and AP 149A to 199A Connectors) 6.
Coolant Inventory 1
1 Bottom of Hars4 Indication Reactor Coolant Inventory Hot teg to Tracking System (RCITS)
Top of Vessel will be operational following Refueling Outage 6R.
RCITS will comply with all requirements of Reg. Guide 1.97, emcept Control Room indication. On-demand capability will be provided by computer based display.
3308/12
?*
Table 18 Evaluation of TMI-1 Compliance with R.G. 1.97 Requirements (C&tegory 1 Parametsrs)
Variable R.G. 1.97 TMI-1 R.G. 1.97 Environment Areas of Non-Comments Schedule Classif.
Classif_
n =a=
canaliance 7.
Degrees of Sub-1 1
200*F subcool-Harsi None cooling ing to 35*F (TE-M8, 960 TE-958, 960 suPerheat PT-949, %3)
TI-977, 978 PT-949, %3
- 8. Containment Sump 1
1 Plant Harsh None Recording Capability Water Level Specific (LT-906, 807) shared with narrow (Wide Range) range instruments.
LT-806. 807 LI-806, 807
- 9. Containment 1
1
-5 psig to 3 Harsh None
- Pressure times design (PT-981A, 9313, PT-981A, 9818 pressure 982A, 9828) 982A, 9828 PR-%), 982
- 10. Containment 1
1 Closed /Not Harsh None Isolation valve Closeo Position 7
1-10 R/hr Harsh None
- 11. Containment Area 1
1 Radiation-High (RtS-G22. G23) l Range RM-G22. G23 l
l
- 12. Containment Hydro-1 1
0-10 vol 7.
Mild None gen Concentration AE-42A, 428 l
- 13. LPI/ Decay Heat 1
1 0-100%
Harsh Seismic Qual-System will be in full l
Removal System design (DH-1DPT1, 2) ification, compliance by refueling Flow flow Redundancy, outage 7R.
DH-IDPT1, 2 Quality DH-l F I-1 Assurance, Recording j
l l
l l
l 3308/13
Ttble IB Evaluation af TMI-1 Complitnce with R.G.1.97 Rrquirements (Category 1 Parameters)
Variable R.G. 1.97 TMI-1 R.G. 1.97 Environment Areas of Non-Comments Schedule Classif.
Classif_
Rance comoliance
- 14. Flow in HPI System 1
1 0-1101 Harss Seismic Qual-System will be in full (Maheup Flow-in) design flow (MU23-DPT1, 2, ification, compliance by Refueling MU23-OPT 1, 2, 3,4 3, 4)
Redunoency.
Outage 7R.
MU23-FE1, 2, 3, 4 Quality MU23-FII, 2
.s. 4 Assurance, Recording
- 15. Refueling Water 1
1 Tcp to Botton Mild Seismic Qual-System will be in full com-Storage Tank ification pliance by Refueling Out-Level iBorated Redundancy age 7R.
heater Storage Tant)
DH3-LT1, 2 DH3-LII, 2
- 16. Steam Generator 1
1 from tube Harsh Recording Recording is from original Computer input will be Level sheet to (LT-775, 776 plant installation instru-moved to a qualified loop LT-775, 776, 788, separators 788, 789) ments (Non-Nuclear Instru-by Refueling Outage 7R.
789 mentation) which is not the same as a qualified loop.
- 17. Steam Generator 1
I From atmos-Harsh Recording Recording is from original Computer input will be Pressure pheric press.
(PT-950.951)
Redundancy plant installation instru-moved to qualified loop PT-950, 951 to 20% above ments (Non-Nuclear Instru-by refueling outage 7R.
PI-950, 950A the lowest mentation) which is not Redundant instrumentation 951, 951A safety valve the same as a qualified will be provided by setting loop.
Refueling Outage 6R.
- 18. Ausiliary or 1
1 0-110%
Harsh Recording On-demand recording capa-Emergency feedwater design flow (FT-782, 788, bility will be provided by Flow 791, 779)
Refueling Outage 7R.
FI-799, 782, 788, 791 FT-782, 788, 791, 779
- 19. Cor.d sate Storage 1
1 Plant Mild Seismic Qual-Instrumentation to be up-Tank Water Level Specific ification graded by Refueling Out-LT-43, 44 Redundancy age 6R.
1.5-43, 44 Quality LI-43, 44, 44A Assurance.
"t303/14
- - - _ -.. -. - - - - - - = _ _.
- - - ~ _ - - - - - -
Table 2A (gganrv 2 Parameters R.C. 1.97 Genuiraments Notes an TMI-l Connliance 1.
Enuinment Oualification The instrument should be qualified in accordance Field sensors (i.e. transmitters) are located in various plant areas, whereas the
~
with Regulatory Guide 1.89, " Qualification of secondary loop components, such as indicators and recorders, are located in the Class IE Equipment for Nuclear Power Plants," and Control Room. In the column on Table 2B which identifies the environment, the term the methodology described in NUREG-0588, " Interim
" Harsh" indicates that part of the loop, such as field sensors, are located in a StaffPositiononEnvironmentalQualificationof harsh environment, and " Mild" indicates that all components within the loop are Saf ety-aelated Electrical Equipment."
located in a mild environment. Equipment installed in the plant prior to 2/22/83 was qualified to DOR Guidelines and af ter 2/22/83 was qualified to NUREG-0588
]
Instrumentation whose ranges are required to ex-Category 1.
tend beyond those ranges calculated in the most
)'
severe design basis accident event for a given Compliance with the environmental qualification requirement f or Category 2 variable should be qualified using the guidance parameters in an environa.ent identified as harsh equipment has been included in the provided in paragraph 6.3.6 of ANS-4.5.
TMI-l EQ Master List (GPUN Letter 5:11-84-2292, December 11, 1984). If the 4
instrument loop components including field sensors are located in a Mild area, they i
Qualification applies to the complete instrumen-are not subject to the environmental qualification requirement.
tation channel f rom sensor to display where the
- j display is a direct-indicating meter or record-The qualification of all the control room devices, i.e.,
indicators, recorders, i
ing device. If the instrumentation channel sig-etc., are considered to be satisfactory since they are high grade industrial equip-nel is to be used in a computer-based display, ment, designed, procurred and installed in accordance with quality assurance re-recording, or diagnostic program, qualification quirements of 10CFR50 Appendia 8.
applies f rom the sensor up to and including the channel isolation device.
4 I
2.
Seismic Oualification No specific provision.
3.
Reduadancy No specific provision.
U 4
Power Source J
The instrumentation should be energized from a high-reliability power source, not necessarily j
l standby power, and should be backed up by batter-j ies where momentary interruption is not tolerable.
i 5.
@ nnel Availabilitu The out-of-service interval should be based on The out-of-service interval is based on normal technical specification requirements normal technical specification requirements on for the system it serves, where applicable, or by other requirements. This i
out of service for the system it serves where complies with the requirements. This complies with the requirements of Reg. Guide applicable or where specified by other require-1.97.
ments.
1 I
3'103/15 i
Table 2A Catemorv 2 Parameters R.G. 1.97 Reauirements Notes on TMI-l Cannliance 6.
Qualitv Assurance Same as Category I as modified by the following:
TMI-l equipment is considered in compliance if the equipment is classified as IE and therefore has been designed, procured, installed and maintained in accordance Since same instrumentation is less important to with the TMI-l QA Program at the time of installation. See GPUN 00A Plan safety than other instrumentation, it may not be Appendix C for current positions, necenary to apply the same quality assurance measures to all instrumentation. The quality assurance requirements that are implemented should provide control over activities affecting quality to an extent consistent with the importance to safety of the instrumentation.
These requirements should be determined and docu-mested by personnel knowledgeable in the end use of the instrumentation.
Category 2 requirements are as follows:
The recommendations of the following regulatory guides pertaining to quality assurance should be fol1 owed:
Degulatory Guide 1.28
" Quality Assurance Program kequirements (Design and Construc-tion)"
" Quality Assurance (Safety Guide 30)
Requirements for the Installation. Inspec-tion, and Testing of Instrumentation and Electric Equipment" Regulatory Guide 1.38
" Quality Assurance Requirements for Packaging, Shipping, Receiving. Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" Dagulatory Guide 1.58
" Qualification of Nuclear Power Plant Inspection Examina-tion, and Testing Personnel" 3308/16
Table 2 Catsaarv 2 Parameters R.G. 1.97 Reauirements Notes an TMI-1 Cameliance -
6.
Quality Assurance - (Continued)
" Quality Assurance Requirements for the Design of Nuclear Power Plants" R:9ulatory Guide 1.74
" Quality Assurance Terms and Definitions" Rigulatory Guide 1.88
" Collection. Storage, and Maintenance of l
Nuclear Power Plant j
Quality Assurance Records
" Quality Assurance Requirements for Con-l I
trol of Procurement of Items and Services l
for Nuclear Power l
Plants" l
" Auditing of Quality l
Assurance Programs for Nuclear Power Plants"
(
" Qualification of Quality Assurance l
Program Audit Person-nel for Nuclear Power Plants" l
Rsference to the above regulatory guides (except l
Regulatory Guides 1.30 and 1.38) is being made pending issuance of a revision to Regulatory l
Guide 1.28 that is under development (Task RS l
002-5) and that will endorse ANSI /ASME NGA-1-1979
" Quality Assurance Program Requirements for Nuclear Power Plants".)
Since some instrumentation is less important to j
safety than other. instrumentation, it may not be l
necessary to apply the same quality assurance measures to all instrumentation. The quality assurance requirements that are implemented
(
should provide control over activities af fecting I
quality to an entent consistent with the importance to safety of the instrumentation.
These requirements should be determined and documented by personnel knowledgeable in the end use of the instrumentation.
?%8/17 l
I l
Table 2A Cateoorv 2 Parameters R.G. 1.97 Reauirements Notes on TMI-l Comoliance
- 7. Disolav and Recordina The instrumentation signal may be displayed on an individual instrument or it may be processed for display on demand.
Signals from effluent radioactivity monitors and l
crea monitors shou d be recorded.
If direct and immediate trend or transient in-fsraation is essential for operator information er action, the recording should be continuously i
I available on redundant dedicated recorders.
l Otherwise, it may be continuously updated, stored in computer memory, and displayed on demand.
Intermittent displays such as data loggers and scanning recorders may be used if no significant trcnsient response information is likely to be lest by such devices.
- 8. Range If two or more instruments are needed to cover a particular range, overlapping of instrument span l
Should be provided. If the required range of monitoring instrumentation results in a loss of instrumentation sensitivity in the normal operat-ing range, separate instruments should be used.
- 9. Eauipment Identification Types A, B, and C instruments designated as A human factors review has been performed with respect to control panel Categories 1 and 2 should be specifically identi-identification of Types A, 3 and C variables designated as Categories 1 and 2.
fied with a connon designation on the control panels so that the operator can easily discern As a follow-up to findings in the 1980 THI-l Control Room Design Review, the entire I
that they are intended for use under accident TNI-l control room was relabeled; this labeling involved setting up an uncluttered I
conditions.
hierarchical label color and size scheme similar to those recommended in NUREG-0700. GPUN feels that if large tags were added for Reg. Guide 1.97 1
variables, they would add to panel clutter, obscure more important labels and cause glare. Any color label material would cause contusion with existing ESAS panel label colors and reduce meaning, or would upset the main CR label color hierarchy.
Smaller tags would be overlooked or would be confused with the six-symbol ICS/NNI power code labeling. Therefore, GPUN has concluded that the potential benefits to identifying Category 2 Type A B and C conditions on the panels are outweighed by i
l the detriments such an addition to the control room would cause.
l l
- 10. Interfaces j
l The transmission of signals for other use should IE Qualified instrument channels are electrically isolated f rom non-qualified por-be through isolation devices that are designated tio1s of the instrument loops up to and including the isolation device.
as oart of the monitoring instrumentation and that meet the provisions of this document.
'008/18 l
1
Table 2A Catsoorv 2 Parameters R.G. 1.97 Reaci rements.
Notes on TMI-1 Comoliance y.
e
- 11. $grvicina. Testina. ;md Ca?ibratian
,f s
o
$4rvicing, testing, and calibration programs Category 2 instrumentation is part of the planned maintenance program. As des '
sh uld be specified to maintain the capability of cribed in Chapter 13 of the FSAR and Technical Specifications, testing is performed the monitoring instrumentation. If the required.
on instrument strings on a regular basis. The test points for the instrument interval between testing is less than the normal strings are under administrative control to prevent unplanned testing. The isola-time interval between plant shutdowns, a capabil-tors for the instrument strings are accessible during and following a design basis ity for testing during power operation,should be event (considering posted radiation fields). Normal calibration of equipment in-side containment is on a refueling cycle basis.
previded.
Wh2never means for removing channels f rom service are included in the design, the design should facilitate administrative control of the access to such removal means.
Tha design should facilitate administrative con-( ! trol of the access to all setpoint adjustments,
-1 4 module calibration adjustments, and test points.
Periodic ctecking, testing, calibration, and cal-ibration verification should be in accordance with the applicable portions of Regulatory Guide 1.118 " Periodic Testing of Electric Power and Protection Systems," pertaining to testing of es instrument channels. (Note: Response time test-ing not usually needed.)
The location of the isolation device should be such that it would be accessible for maintenance during accident conditions.
- 12. Human Factors The instrumentation should be designed to facili-Compliance with this requirement means that for a given display device, the Human tate the recognition, location, replacement, re-Factors Evaluation has been completed as part of the Control Room Design Review.
pair, or adjustment of malfunctioning components Process, Human factors analysis recommendations were part of the CRDR submittal or modules.
(per Letter No. 5211-84-2153, dat.1d 6/29/84).
The monitoring instrumentation design should minimize the development of conditions that would cause meters, annunciators, recorders, alarms, etc. to give anomalous indications potentially confusing to the operator. Human factors analysis should be used in determining type and location of displays.
3308/19
~_.
. ~ - - -. -.
Table 2A Catenarv 2 Parameters R.G. 1.97 Reauirements Notes on TMI-I Conoliance
- 12. H"=an Factors - (Continued)
To ti e extent practicable, the same instruments shtuld be used for accident monitoring as are used for the normal operations of the plant to enable the operators to use, during accident sit-uJtions, instruments with which they are most f r. mil i a r.
- 13. Direct Haasurement i
To the extent practicable, monitoring instrumen-To the extent practicable, monitoring instrumentation inputs are f rom sensors that tation inputs should be from sensors that direct-directly measure the desired variables. This complies with the requirements of ly measure the desired variables. An indirect Regulatory Guide 1.97.
measurement should be made only when it can be j'
shcwn by analysis to provide unambiguous informa-
- tion, t
4 1
] 3308/20 i
Table 2B Evalustien of TMI-l Complitnce with R.G. 1.97 R2quirements (Category 2 Parameters)
Variable R.G. 1.97 THI-l R.G. 1.97 Environment Areas of Non-Comments Schedule Classif.
Classif.
Ranae conoliance 1
Centainment Sump 2
2 Plant Specific Harsh Hone Water Level (LT-804, 805)
(N3rrow R. ge)
LT-804, 805 LI-804, 805 1
6-Mild Quality Temporary flow indication Permanent indication meeting 2.
Effluent Radio-2 2
106 ac tivi t y-Nobl e 10 uCi/cc Assurance is provided in the Control QA requirements will be pro-Gas Effluent 0-110% vent Room. Range is achieved by vided by Refueling Outage 6R.
from Condenser design flow overlapping RM-A5 hi and Air Removal lo and RM-G25.
RM-A5 to and Hi RM-G25 3.
Containment 2
2 10 Hild None Range is achieved by over-Effluent Radio-10-2 uCi/cc lapping RM-A9 hi and lo.
Activity - Noble 0-110% vent Gases from Identi-design flow fied Release Points RM-A9 Lo and Hi 6-Hild None Range is achieved by over-4.
Effluent Radio-2 2
103 Activity - Noble 10 uCi/cc lapping RM-A8 lo and RM-A8 Gases from Auxiliary 0-110% went hi.
Building design flow RM-A8 Lo and Hi 5.
Dicay Heat Exchanger 2
2 40*F-350'F Harsh Quality This instrument is part Outlet Temperature (DH2-TEl, 2)
Assurance of the original plant installation. It was DH2-TEl, 2 DH2-TI1, 2 procured and installed as high quality commer-cial grade equipment.
Over the years of opera-tion it has demonstrated reliability and minimal maintenance. All future activities relative to this component will be subject to applicable QA requirements.
J 3308/21
1
,s' Table 28 Evaluatien of TMI-I Complitnce with R.G. 1,97 RIquirements (Catsgory 2 Parameters)
Varitble R.G. 1.97 TMI-l R.G. 1.97 Environment Areas of Non-Comments Schedule Classif.
Classif.
Ranae comoliance Range TMI-I range is 0-300*F.
Decay heat removal opera-tion is initiated when the RCS temperature is less than 300*F (see FSAR Table 9.5-1).
Therefore, GPUN considers the plant specific range of 0-300*F sufficient to cover all post accident conditions.
6.
Primary System Safety 2 2
Closed /
Harsh None Relief Valve Posi-Not Closed (DPT-921, tions or Flow through 922, 923) or Pressure in Relief valve VMS-ACC1, 2 RC-DPT-921, 922, 923 7.
Pressurizer Level 1
2 Top to Harsh None Pressurizer level is kcl-LTI, 2, 3 Bottom (RCl-LT, 1,2,3 used as an indication RCl-LR LT-777) that HPI throttling is LT-777 allowed. The operater LI-777, 777A throttles HPI if he has adequate SCH and pressurizer is on scale.
However, failure to throttle under these conditions does not result in the violation of anv safety limits (e.g. HPI is throttled upon reading 100*F subcooling, regard-less of pressurizer level.)
Therefore, GPUN considers pressurizer level a Category 2 variable.
3308/22
Ttble 2B Evaluttien cf TMI-I Compliance with R.G. 1.97 Requirements (Category 2 Parameters)
Varitble R.G. 1.97 TMI-l R.G. 1.97 Environment Areas of N0n-Comments Schedule Classif.
Classif.
Ranae enanliance The pressurizer level is normally temperature compensated by RC-2-TE 1/2, which are not environ-mentally qualified. However, the instrumentation is in accordance with '1CFR50.49, as discussed in TDR 598 Rev. 1 which served as a basis f or NRC's evaluation of GPUN's Environmental Qualification Program. This position has been endorsed by NRC in their evaluation of THI-l compliance with 10CFR50.49.
I
- 8. Containment 2
2 0-110%
Harsh Quality Equipment which was part Spray flow design (BSl-DPT1, 2)
Assu rance of the original plant l
BSI-FEl, 2 fl ow installation was BSl-DPT1, 2 procured and installed BS1-FI), 2 as high quality commer-cial grade equipment.
Over the years of opera-tion it has demonstrated reliability and minimal maintenance. Recent activities relative to this component have been subject to applicable QA requirements, as will all future activities.
- 9. Heat Removal by 2
2 Plant Harsh All Capability will be provided Indication will be the Containment specific which will be in total provided by refueling fan Heat Removal compliance.
outage 7R.
System 3308/23
Ttble 2B Evaluatien of TMI-1 Complitnce with R.G. 1.97 Rtquirements (Catsgory 2 Parametarst Varitble R.G. 1.97 TMI-1 R.G. 1.97 Envi ranment Areas of Non-Comments Schedule Classif.
Classif.
Ranoe comoliance
- 10. Make-up Flow-in 2
2 0-110%
Mild Quality This is the emergency boration MU24-F I design Assurance path for reactivity transients flow and is not needed for events producing harsh environments.
This indication was provided as part of the original plant instrumentation, with portions replaced during the THI-1 shut-down following the TMI-2 acci-dent. It was procurred and installed originally as high quality commercial grade equipment.
More recent activities relative to this indication have been subject to applicable QA requirements, as will all future activities.
)
- 11. Volume Control 2
2 Top to Harsh None Tank Level (Make-bottom (LT-778 t
up Tank Level)
MU-146T)
LT-778 LI-778 LI-778A MU-14LT
- 12. Component Cooling 2
2 40*F-200*F Mild Quality This instrument is part Water Temperature (Nuclear Assurance of the original plant in-3' to ESF System Service +
stallation. It was pro-i TE-229, 250, 251 Decay Heat curred and installed as l
TI-330, 108, 109 Closed Cool-high quality commercial ing Portions) grade equipment. Over the years of operation it has demonstrated reliability and minimal maintenance.
All future activities rela-tive to this component will be subject to applicable QA requirements.
l 1
3308/24
Ttble 28 Evalu: tion of THI-1 Complitnce with R.G. 1.97 RIquirements (Catsgory 2 Parametsrs)
Varichle R.G. 1.97 TMI-I R.G. 1.97 Environment Areas of Non-Comments Schedule Classif.
Cl as si f.
Ranae conoliance
- 13. Emergency Ventil-2 2
Open/ Closed Mild None Demand signal is provided ation Damper in the control room for Position (Control additional dampers.
Room)
D28, D36, 037, D39
- 14. Status of Standby 2
2 Plant Mild None Power and Other Specific Ensrgy Sources (I&V Meters, Backup Inst.
Air)
- 15. Vint from Steam 2
2 103 Mild Range TMI-I range is 3.96x10-2 I-Generator Safety 10 uCi/cc; to 980/947 uCi/cc. The RV or Atmospheric (Duration of range of existing radia-Dump Valves - Noble Release in tion monitors for vent Gases and Vent Flow Seconds and fromatmospheEcdumpvalves i
Rate Mass of Steam is 3.96 x 10- to 980 uCi/cc, RH-G26. G27 per Unit Time) which is taken from a test result conducted by Battelle.
This does not envelope the rec y-10gded range of 10-uCi/cc. GPUN considers the upper range of 980 uCi/cc sufficient.
These monitors were procurred, installed and maintained in accordance with the GPUN QA program, and represented the state-of-the-art for this type of equipment at the time of purchase.
3308/25
Table 1A Catenarv 3 Parameters R.G. 1.97 Reauirements Notes on TMI-1 Comoliance 1.
[auinment Oualification No specific provision.
2.
Seismic Qualification No specific provision.
3.
Redundancy N3 specific provision.
4.
Power Source N3 specific provision.
5.
Channel Availability No specific provision.
6.
Quality Assurance The instrumentation should be of high-quality The instrumentation is of high-quality commercial grade and is selected to with-commercial grade and should be selected to with-stand normal plant service environment.
stand the specified service environment.
7.
Disolav and Recordina The instrumentation signal may be displayed on an individual instrument or it may be processed for display on demand.
Signals from effluent radioactivity monitors, area monitors, and meteorology monitors should be recorded.
If direct and immediate trend or transient inf or-mation is essential for operator information or 4
action, the recording should be continuously available on redundant dedicated recorders.
Otherwise, it may be continuously updated, stored in computer memory, and displayed on demand.
Intermittent displays such as data loggers and scanning recorders may be used if no significant transient response information is likely to be last by such devices.
3308/26
Table 3A Categorv 3 Parameters R.G. 1.97 Reauirements Notes on TMI-1 Comoliance
- 8. Range If two or more instrements are needed to cover a psrticular range, overlapping of instrument span shculd be provided. If the required range of monitoring instrumentation results in a loss of instrumentation sensitivity in the normal operat-ing range, separate instruments should be used.
- 9. Eauioment Identification No specific provision.
- 10. Interf aces No specific provision.
II. Servicing. Testino and Calibration Servicing, testing and calibration programs Instrumentation is part of the planned maintenance program. As described in should be specified to maintain the capability of Chapter 13 of the FSAR and Technical Specification, testing is perf ormed on instru-the monitoring inst rumentation. If the required ment strings on a regular basis. The test points for the instrument strings are interval between testing is less than the normal under administrative control to prevent unplanned testing.
time interval betw?en plant shutdowns, a capabil-ity for testing during power operation should be provided.
Whenever means for removing channels f rom service dre included in the design, the design should facilitate administrative control of the access to such removal means. The design should facili-tate administrative control of the access to all setpoint adjustments, module calibration adjust-ments, and test points.
Periodic checking, testing, calibration and cali-bration verification should be in accordance with the applicable portions of Regulatory Guide 1.118. " Periodic Testing of Electric Power and Protection Systems," pertaining to testing of instrument channels. (Note: Response time test-ing not usually needed).
1308/27
Table 3A Catenarv 3 Parameters R.G. 1.97 Reauirements Notes on TMI-1 Connliance t
- 12. Human Factors l
I The instrumentation should be designed to facili-Compliance with this requirement means that for a given dispisy device, the Human j
tate the recognition, location, replacement, re-Factors Evaluation has been completed as part of the Cer. trol Room Design Review.
i l
pair, or adjustment of malfunctioning components Process, Human factors analysis recommendations were part of the CRDR submittal or modules the monitoring instrumentation design (per Letter No. 5211-84-2153, dated 6/29/84).
should minimize the development of conditions i
j that would cause meters, annunciators, recorders, alarms, etc. to give anomalous indications poten-tielly confusing to the operator. Human factors 1
analysis should be used in determining type and location of displays.
1 i
To the extent practicable, the same instruments should be used for accident monitoring as are i
used for the normal operations of the plant to enable the operators to use, curing accident sit-u2tions, instruments with which they are most
- familiar, j
- 13. Direct Measurement l
To the extent practicable, monitoring instrumen-To the extent practicable, monitoring instrumentation inputs are f rom sensors that tation inputs should be f rom sensors that direct-directly measure the desired variables. This complies with the requirements of ly measure the desired variables. An indirect Reg. Guide 1.97.
j measurement should be made only when it can be i
shown by analysis to provide unambiguous informa-1 tion.
I i
I i
i i
i i
w L
i i
I 3308/28 1
i
-_ ~..
l Tcble 38 Evalustien of THI-l Compliance with R.G.1.97 Riquirements (C&tsgory 3 Parametsrs)
Variable R.G. 1.97 THI-l R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif.
Ranae c omolianc e 1.
3 Full in/
None Continuous rod position Pcsition Not full indication, as well as in full-in or full-out in-dication are provided for each control rod drive.
Alarm lamps on the CRD panel alert the operator to the system's status at all times.
2.
Rrdioactivity Con-1 3
1/2 Tech.
See Comments Currently, no state of the centration or Spec.
art instrumentation exists Rtdiation Level Limit to to adequately measure this in Circulating 100 times variable on line. The dis-4 Primary Coolant TSL cussion of this variable is in the EGG report EE-6154,
" Assessment of Generic In-strumentation System Used 1
to Meet the Provisions of Regulatory Guide 1.97."
This provides an excellent e
overview of the problem related to this measurement.
J Existing letdown line radiation monitors can be used to provide indi-cation of fuel failure during normal operation.
However, since the letdow1 j
line is isolated at reactor trip, it will nnt be avail-able for long term measure-i ment.Section II.B.3 of NUREG-0737 requires that capability exist at each plant to sample the RCS i
i 3308/29 r
l
Ttble 3B Evalustien of TMI-l Complicace with R.G. 1.97 Requirements (Cctsgory 3 Parameters)
Vari tble R.G. 1.97 TMI-1 R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif_
Ranoe comoliance to assess the magnitude of fuel failure during normal operation and post-accident.
The letdown line radiation monitor is used as the in-itiator for sampling during normal operation and as a backup indication. There-fore, GPUN considers this a Category 3 parameter. This is a B&W Owners Group generic-position.
3.
Accumulator Tank 2
3 10-90%
None Core flood tank level indica-Level (Core Flood Vol ume tion is provided in the Control fank Level)
Room. This instrument provides CF2-LT1, 2, 3, 4 the operator information per-CF2-LII, 2, 3, 4 taining to tank status during normal operation. However, since the core flooding system is totally passive, no monitor-ing of this parameter is required for any manual actions to miti-gate the consequences of an ac-cident. Therefore, GPUN con-siders this a Category 3 para-meter. This is a B&W Owners Group generic position.
4.
Accumulator Tank 2
3 0-750 psig None Core flood tank pressure indica-Press are (Core tion is provided in the Control flood Tank Pressure)
Room with a range of 0-800 psig.
CF1-PT 1, 2, 3, 4 This instrument provides the CF1-FI 1, 2, 3, 4 operator information pertaining to tank status during normal operation. However, since the core flooding system is totally passive, no monitoring of this parameter is required f or any manual actions to mitigate the consequences of an accident.
Therefore, GPUN considers this a Category 3 parameter. This is a B&W Owners Group generic position.
3308/30
itble 38 Evaluttien of TMI-l Complicace with R.G.1.97 R:quirements (Catsgory 3 Parameters)
Varizble R.G. 1.97 TMI-l R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif.
Ranoe cameliance 5.
Acc umulator 2
3 Closed or Open None These are motor operated Isolation Valve valves whose circuit breakers Position are opened (de-energized)
CF-VIA, B when the reactor is critical.
6.
3 Motor Current None The CF system is designed Pump Status to inject borated water into RC-P-1A, B, C. O the reactor core during a LOCA. Such an injection, if CF-V-1 could not isolate and CF-V-3 could not vent the CF tank, would result in some time delay in the ability to depressurize the RCS below 600 psig and 275*f. CF in-jection will not result in nitrogen injection into the RCS. Therefore, GPUN con-siders this a Category 3 parameter.
7.
Pressurizer Heater 2
3 Elect. current Range Pressurizer heater status Status is provided at THI-1 by on-off indication only. This is considered sufficient in-dication at TMI-1 when used in conjunction with RCS pressure. Therefore, GPUN considers this a Category 3 parameter.
8.
Quinch Tank Level 3
3 Top to Bottom None (RC Drain Tank Level)
LT-115 LS-ll5, LR-115 3308/31
~. - --
Tchle 3B Evalustien of TMI-l Compliance with R.G. 1.97 Rrquirements (Catsgory 3 Pcrameters)
Variable R.G. 1.97 TMI-!
R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif.
Ranoe c omoli ance
- 9. Ournch Tank 3
3 50*F-750*F Range The RC drain tank is isolated Capability to monitor the Temperature (RC upon reactor trip. RC drain complete range of postulated Drain Tank tank temperature approaching RCDT temperatures will be Temperature) the temperature of the provided by Refueling Outage TE-605, TT-605, existing 275'r maximum 7R.
TI-605A/B indicated temperature is indicative of leakage into the tank. The RCDT has a relief valve set at 40 psig so that the tank temperature normally would not go above 287'F.
The RCDT has a rupture disk set at 55 2 6 psig.
Therefore, the bulk temperature can never go above 308*F.
In order for the tank pressure to increase above 40 psig, the PORV or safety valve would have to open, in which case the pressure would increase above 55 psig rapidly. The RCDT would be between 287'F and 308'F for a very short period of time only.
RCDT pressure is indicated and has a range of 0 to 100 psig.
- 10. Quench Tank 3
3 0-design None Pressure (RC Pressure Drain Tank Pressure)
PT-323 PS-323 PI-323
- 11. SG Safety / Relief 2
3 Closed /Not None The key variable to determine the Valve Position or Closed SG Safety / Relief valve position or main steam flow are SG level Main Steam flow and SG pressure. Valve position indication is provided as backup.
Therefore, GPUN considers this a Category 3 parameter. This is a B&W C<ners Group generic position.
i
- 12. Main feedwater Flow 3
3 0-110% Design None a
i FE-7A, 78, BA, 8B Flow FT-7, 8 J
F1-7A, 78, 8A, BB SP9A-FR SP98-FR i
i 3308/32 r
m
Table 3B Evaluatica of TMI-l Compliance with R.G.1.97 Rtquirements (Category 3 Parameters)
Variable R.G. 1.97 TMI-l R.G. 1.97 Areas of Non-Comments Schedule Classif.
Cl ass i f.
Ranoe comoliance
- 11. Containment Atmos-2 3
40*F-400*F Range The purpose of the Containment phere Temperature Atmosphere Temperature indica-l (TE-655 A, I, K. & W) tion as defined in R.G. 1.97 is to provide indication that the Reactor Building Cooling and/or Spray System is accomplishing its design objective, i.e. to cool the Reactor Building at-mosphere and maintain it below its designated temperature limit following any postu-lated design basis accident.
This objective is primarily confirmed by observation that the Category I qualified Con-tainment Pressure indications are decreasing. These have a range to three times design pressure which will cover the complete spectrum of postulated accidents that challenge these systems. Accordingly, Contain-ment Atmosphere Temperature indications provide a backup to the pressure indicators.
Therefore, GPUN considers this a Category 3 parameter. This is a B&W Owners Group generic position.
The TMI-l design basis accident containment analyses are pro-vided in the updated FSAR Chapter 6.
The presently in-stalled 0-297'F containment temperature indication pro-vides sufficient range to mon-itor the entire spectrum of containment temperature trans-ients as analyzed in the FSAR.
Recording capability is pro-vided f or 50*F-150*F. The containment temperature will be the saturation temp-erature for indicated con-tainment pressure during loss of coolant accidents and for l
any event in which building spray has been initiated.
Based on these considerations GPUN considers the existing IMI-l range sufficient.
3308/33
Table 38 Evaluztien of TMI-l Compliance with R.G. 1.97 Requirements (Category 3 Parameters)
Variable R.G. 1.97 TMI-l R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif_
Ranae c omoli ance
- 14. Containment Sump 2
3 50*F-250*F None The minimum available NPSH for uater Temperature the decay heat removal pump is DH6-TEI, 2 independent of sump temperature, and no automatic or manual ac-tions are initiated based on 4
this temperature. Therefore GPUN considers this a Category 3 parameter.
l
. 15. Letdown Flow-Gut 2
3 0-110%
None During design basis events Design Flow such as LOCA's the Make-Up d
and Purification System is isolated. Letdown flow indication is a backup vari-able to the makeup tank i
level for certain accidents.
Letdown flow rate can be es-timated, if necessary, based pressurizer level. Therefore, GPUN considers this a Category a
3 parameter.
i i
4
- 16. High-level Radio-3 3
Top to Bottom None j
active Liquid l,
Tank Level LT-11BA, 118B j
LI-18. WDL-LR j
- 17. Radiation Exposure 3
3 10-I-None Rate 104 R/hr 1
I 3-None Sample collected on silver l
- 18. All Identified Plant 3
3 102 Release Points -
10 uCi/cc zeolite and carbon. Onsite Sampling Particulates 0-110% Vent analysis via Canberra Jupi-7 and Halogens Design Flow ter Radionuclide Identifica-tion and Quantitative Measure-RM-AS, A8, A9 ment System. Systems are isokinetic (except RM-AS),
thus matching vent flow, 4
=
i 1
i 3308/34 i
[
l
.. ~ -
)
Table 38 Evaluaticn of TMI-1 Compliance with R.G. 1.97 Rrqairements (Category 3 Parameters)
Variable R.G. 1.97 TMI-I R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif.
Ranae c anal i ance
- 19. Airborne Radio-3 3
10 None halo w ns and Par-10-3 uCi/cc ticulates from Various locations (Portable)
- 20. Plant and Environs 3
3 10-3_
- gon, Radiation (Portable 104 R/hr Instrumentation)
(phgtons) 10-t E-140, R0-2A, RO-7 4
3 10 rad /hr (beta)
- 21. Plant and Environs 3
3 Isotopic None Portable sampling capability; onsite Radioactivity Analysis laboratory analysis (Canberra Series 10)
(Portable)
- 22. Wind Direction 3
3 0-360* ( 5* ac-None KT78 curacy with a deflection of 10*)
Starting speed g
less than 0.4 mps (1.0 mph)
Damping ratio greater than or equal to 0.4, de-lay distance less than or equal to 2 meters 3308/35
Tcle 3B Evaluatien cf THI-I Complicnce with 2.G. 1.97 R quirements (Cetsgory 3 Perameters)
Varicble R.G. l.97 TMI-I R.G. 1.97 Areas of Non-Comunents Schedule Classif.
Classif_
Rance coroliance 23 uind Speed 3
3 0-22 mps None ST-79 (50 mph),
SR79A 20.2 mps SR798 (0.5 mph) accuracy f or speeds less than 2 mps (5 mph),
10% for speeds in excess of 2 mps (5 mph),
with a start-ing threshold of less than 0.4 mps (1.0 mph) and a distance constant not to exceed 2 meters
- 24. Estimation of 3
3 Based on None Atmospheric vertical stability temperature difference f rom prim-ary meteor-ological system
-5'C to 10*C, (-90F to 18*F),
and 20.15'C accuracy per 50 meter in-terval s (10.3*F accuracy per 164-foot in-tervals) or anal ogous range for alternate stability estimates 3308/36
Table 3B Evaluatien of TMI-I Compliance with '
R.G. 1.97 Requirements (Category 3 Parameters)
Variable R.G. 1.97 TMI-I R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif.
Ranae cameliance
- 25. Primary Coolant 3
3 luCi/ml Mcne Onsite analysis capability and Sump Gross to 10Ci/ml exists Activity (Grab Sample)
- 26. Primary Coolant 3
3 Isotopic None Onsite analysis capability and Sump Gamma Analysis exists Spectr m (Grab Sample)
- 27. Primary Coolant 3
3 0-600 ppe None Onsite analysis capability exists and Sump Boron Centent (Grab Sampie)
- 28. Primary Coolant 3
3 0-20 ppe None Onsite analysis capability and Sump Chloride exists Content (Grab Sample)
- 29. Primary Coolant 3
3 0-2000 cc None Onsite analysis capability and Sump Dis-(STP)/kg exists solved Hydrogen or Total Gas (Grab Sample)
- 30. Primary Coolant 3
3 0-20 ppe None Onsite analysis capability exists and Sump Dissolved Oxygen (Grab Sample)
- 31. P:; mary Coolant 3
3 1-13 None Onsite analysis capability exists and Sump pH (Grab Sample)
- 32. Cantainment Air 3
3 0-10 vol. %
None Onsite analysis capability exists Hydrogen Content (Grab Sample)
- 33. Centainment Air 3
3 0-30 vol. %
None Onsite analysis capability exists Oxygen Content (Grab Sample) 1308/37
Tchle 33 Evaluatien of TMI-l Cooplicnce with R.G. 1.97 Rrquirements (Cctegory 3 Parameters)
Viritble R.G. 1.97 TMI-I R.G. 1.97 Areas of Non-Comments Schedule Classif.
Classif.
Range comoliance
- 34. Centainment Air 3
3
!sotopic None Onsite analysis capability Gasma Spectrum Analysis exists (Grab Sample) 3308/38
Table 4 R.G.1.97 Parameters Not Applicable to THI-I Variable R.G. 1.97 Comments Classif.
1.
No on-line facility exists to measure RCS soluble boron content (boron-meter).
Concentration Off-line facility is utilized.
For TMI-I the determination of Reactor Coolant Baron Concentration is by normal or post accident sampling RCS boron need not be constantly monitored because the loss of negative reactivity due to menon decay is suf ficiently slow that the con-trol room operator need not know instantaneously or constantly the boren concen-tration in the RCS. Therefore, GPUN considers IMI sampling sufficient for this parameter.
See item 27 of Table 38 2.
Analysis of Primary 3
Post accident sampling system covers this requirement. See items 26 and 25 of Coolant (Gamma Spectra)
Table 38 3.
Boric Acid Charging Flow 2
Boric acid charging pump flow is "not applicable" to B&W plants. 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 include high pressure injec-tion (HPI) and low pressure injection (LPI) with the BWST or the RB sump as the suction source, and the core flood tank injection. HPI and LPI flow rates and BWST, RB Sump, and Core Flood Tank levels are monitored (see items 8, 13 14 and 15 of Table 18, item 1 of Table 28, and item 3 of Table 3B). Therefore, Boric Acid Charging Flow does not need to be monitored as a Type D variable to monitor the operation of the ECCS. This is a B&W Owners Group generic position.
4.
Component Cooling Water Flow 2
Flow display is not provided in the TMI-l Control Room. Local display (DHCCW) capability is provided and is accessible post accident.
to ESF System Since all decay heat and nuclear services closed cycle cooling systems component cooling water valves are manual valves which are normally open, pump status and system temperature provide suf ficient indication f or system operation (except NSV j
52 and 53, where valve position indication is provided). These indications are considered to meet the requirements of Reg. Guide 1.97.
5.
Radioactive Gas Holdup 3
The design pressure f or these tanks is 150 psig. When the pressure reaches 82 psig, it initiates a local high pressure alarm. Also, this can be indicated Tank Pressure on a local indicator or demand. At 85 psig, the relief valve opens and dis-charges to the Auxiliary Building, where it will be detected and indicated by the Auxiliary Building radiation monitor. Moreover, when the relief valve opens, it will annunciate in the common problem panel in the Control Room. Based on these
{
considerations, GPUN considers the existing indications and alarms sufficient.
Measurement is not available in the Control Room. Local indication only is available on demand with a range of 0 to 100 psig. This readout is accessible post-accident.
6.
Common Plant Vent or Multi-2 TMI does not have a common plant vent.
purpose Vent - Noble Gases and Vent flow Rate f
7.
Reactor Shield Building 2
Not applicable, not in design for TMI Annulus (if in design) -
Noble Gases and Vent Flow Rate 3308/39
r CHANGES FROM REFERENCE 1 EVALUATION OF TMI-l COMPLIANCE WITH REGULATORY GUIDE 1.97 1.
RCS Pressure Reg. Guide 1.97 specifies a range of 0-3000 psig. The TMI-l range is 0-2500 psig. TMI-1 will be in compliance by Refueling Outage 7R. Qualified redundant display is provided on the remote shutdown panel.
2.
Core Exit Temperature Reference 1 identified that the digital indicator did not meet seismic qualification requirements.
Seismically qualified digital indicator has been installed.
3.
Coolant Inventory Reference 1 identified that the Reactor Coolant Inventory Tracking System (RCITS) would be installed and testing completed by March 1985.
The RCITS will be operational following Refueling Outage 6R.
4.
Degrees of Subcooling Reference 1 identified that the digital indicator did not meet seismic qualification requirements.
Seismically qualified digital indicator has been installed.
5.
Containment Hydrogen Reference 1 identified that recorded Concentration information would be placed on the computer by Refueling Outage 6R.
This has been completed.
6.
Containment Hydrogen Instrumentation is located in a mild Concentration environment post-accident. Thus, qualificatio: for harsh environmental conditions is not appropriate.
7.
LPI/ Decay Heat Removal Reference 1 identified that system upgrade was required for environmental qualification. This has been accomplished.
8.
Flow in HPI System Reference 1 identified that system upgrade (Makeup Flow-in) was required for environmental qualification. This has been accomplished.
9.
Steam Generator Reference 1 incorrectly identified Pressure compliance with the redundancy requirement.
Redundant Class 1E indication will be provided by Refueling Outage 6R.
I
- 10. Auxiliary or Emergency In Reference 1 Inventory and Compliance Feedwater Flow Table for this parameter, GPUN incorrectly identified that on demand recording capability would be provided by Refueling Outage 6R. The Reference 1 " Highlights of Deviations from R.G.1.97 Specific Recommendations" correctly identified the upgrade schedule as Refueling Outage 7R.
- 11. Decay Heat Exchanger Reference 1 identified that environmental Outlet Temperature qualification was required. This has been accomplished.
.i 2769f
r
- 12. Primary System Safety Reference 1 identified that environmental Relief Valve Positions qualification was required. This has been or Flow Through or accompli shed.
Pressure in Relief Valve.
- 13. Pressurizer Level Reference 1 identified noncompliance with respect to environmental qualification of the temperature compensation element.
The discussion has been clarified to explain that a qualified temperature compensation element is not required for compliance with 10CFR50.49.
- 14. Containment Spray Flow Reference 1 identified noncompliance with respect to environmental qJalification.
This has been accomplished.
- 15. Heat Removal by the Reference 1 committed to upgrading an Containment Fan Heat existing loor,. New indication is being Removal System, provided via a new separate loop.
- 16. Volume Control Tank Reference 1 identified noncompliance Level (Makeup Tank Level) with respect to environmental qualification. This has been accomplished.
- 17. Component Cooling Water Reference 1 erroneously identified non-Temperature to ESF System compliance with respect to environmental qualification. All components with safety related post accident functions are located in a mild environment.
- 18. Status of Standby Reference 1 identified noncompliance with Power and Other Energy respect to environmental qualification of Sources.
the instrument air system. Further review as part of the environmental qualification program has der.onstrated that active components of the instrument sir system required to perfonn safety related post accident functions are located in mild envi ronments.
- 19. Quench Tank Capability to monitor the complete range Temperature of postulated RCDT temperatures will be (RC Drain Tank provided by Refueling Outage 7R.
Temperature).
2769f I
- 20. Containment Atmosphere Range of TMI-1 instrumentation is 0-297'F Temperature rather than 0-300*F as reported in Reference 1.
Recording capability is provided for a range of 50-150*F.
- 21. Primary Coolant and Reference 1 identified capability being Sump Gross Activity installed to draw sump sample.
This has been accomplished.
- 22. Primary Coolant and Reference 1 identified capability being Sump Gamma Spectrum installed to draw sump sample. This has been accomplished.
- 23. Primary Coolant and Reference 1 identified capability being Sump Boron Content installed to draw sump sample. This has been accomplished.
- 24. Primary Coolant and Reference 1 identified capability being Sump Chloride Content installed to draw sump sample. This has been accomplished.
- 25. Primary Coolant and Reference 1 identified capability being Sump Dissolved Hydrogen installed to draw sump sample. This has and Total Gas been accomplished.
- 26. Primary Coolant and Reference 1 identified capability being Sump Dissolved Oxygen installed to draw sumo ProlS This has been accomplished.
- 23. Primary Coolant and Reference 1 identified capability being Sump pH installed to draw sump sample. This has been accomplished.
Reference:
(1)
GPUN Letter 5211-84-2252, "NUREG-0737, Supplement 1 -
Regulatory Guide 1.97 (Revision 3)", October 1,1984.
2769f )