ML20213F853

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Provides Updated Summary of Description of Compliance W/ Reg Guide 1.97.Util in Compliance W/Reg Guide Re Category 3 Instrumentation Located in Mild Environ for Events for Which Reactor Bldg Emergency Cooling Sys Required
ML20213F853
Person / Time
Site: Crane Constellation icon.png
Issue date: 05/07/1987
From: Hukill H
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 5211-87-2087, NUDOCS 8705180016
Download: ML20213F853 (2)


Text

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GPU Nuclear Corporation

- 1 Nuclear

=,ome,c Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Olal Number:

May 7, 1987 5211-87-2087 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:

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 GPUN letter 5211-86-2097, dated June 5,1986, provided an updated summary of the description of TMI-1 compliance with Regulatory Guide 1.97.

This letter provides additional updated information concerning the following R.G.1.97 variables:

1.

Heat Removal by the Containment Fan Heat Removal System In Table 28, Item 9 of the above referenced submittal, GPUN indicated

)

that this variable would be Category 2, as specified in R.G.1.97.

The purpose of this variable is to provide indication that the Reactor Building Cooling System is performing its design objective to cool the Reactor Building atmosphere and to maintain it below its designed pressure limit following a design basis accident. This objective is primarily confirmed by observation of the Category 1 Containment Pressure variable. Accordingly, indications of the subject variable provide a backup to the pressure indicators.

Therefore, GPUN considers the subject variable Category 3 for TMI-1.

This position has been found acceptable by the NRC on other B&W plants.

L Category 3 instrumentation at TMI-l includes indication of River Water Pump motor breaker status, Reactor Building fan motor contactor status, indication of each Reactor Building Emergency Cooling Coil outlet pressure, and annunciation of leak detection for each Reactor Building Emergency Cooling Coil.

This instrumentation (from sensor to display) is located in a mild environment for events for which the Reactor Building Emergency Cooling System is required. Therefore, we consider TMI-l to be in compliance with the intent of R.G.1.97 for this variable.

8705180016 870507P PDR ADCJK 05000289 P

PDR3 3

GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation geP

r 5211-87-2087 May 7, 1987 2.

Steam Generator Level Regulatory Guide 1.97 instrument range requirement for this variable is from tube sheet to separators. THI-l OTSGs do not have separators. There are redundant Category 1 qualified OTSG full range-level indicators on each OTSG with a range of 0-640 inches which satisfies the level indication requirements of R.G.1.97.

For TMI-1, zero inches equals six inches above the lower tube sheet, and ihe lower surface of the upper tube sheet is located at 625 inches. This range is useful for normal heatups and cooldowns, and would be utilized by the operator should the start-up range level indication go off-scale high; however, this information need not be trended.

During design basis accidents, the range of interest is up to the aspirating port (376 inches above. lower tube sheet). This is a B&W Owners Group position for 177FA lowered loop plants such as TMI-1 (Reference B&W Document No. 47-1150378-01, March 1984).

To satisfy R.G.1.97 recording requirements for steam generator level, TMI-1 will utilize recorder (LR1046/LR1054) installed in the control room during outage 6R. This recorder records the " start-up" range level of each OTSG (0-388 inches) which covers the range.of interest for design basis accidents.

Therefore, we consider TMI-l to be in compliance with the intent of R.G.1.97 for this variable.

GPUN requests that the above clarifications be addressed in the revised NRC-SER on TMI-l compliance to R.G.1.97.

If any additional information is required, please contact us.

Sincerely,

. D. H kill Vice President and Director, TMI-l HDH:DJD/0871 A cc:

J. Stolz, USNRC G. Edison, USNRC W. T. Russell, USNRC Region I R. Conte, USNRC TMI-l Site