ML20215M329

From kanterella
Jump to navigation Jump to search
Forwards Supplemental Info to Reg Guide 1.97,Rev 2 Re Suppl to NUREG-0737,including Corrections to Instrument Ranges & Clarification of Scientific Notation
ML20215M329
Person / Time
Site: Beaver Valley
Issue date: 10/13/1986
From: Sieber J
DUQUESNE LIGHT CO.
To: Thompson H
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8610300168
Download: ML20215M329 (31)
v • d • e


Text

,______ _ _____ __ - __ . _ _. __ _ _ _ _ _ _ _ _ _ -_- . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

s 8Vs, M Telephone (412) 093-6000 i

Nuclear orcup L ,,%,do,,,pa ,3o77ono. October 13, 1986 l

/ Director of Nuclear Reactor Regulation

/ U. S. Nuclear Regulatory Commission Attn: Mr. Hugh L. Thompson, Director Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. I Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-33; Supplement to NUREG-0737, Regulatory-Guide 1.97, Revision 2, Supplemental Report Gentierten:

The attachment to this letter provides supplemental information to the Regulatory Guide 1.97, Revision 2, report transmitted by letter dated November 29, 1985. This transmittal is being provided in the interest of clarifying and amending the information in the report.

Following our November, 1985 submittal, this report received additional review and it was determined that a few corrections to instrument ranges were necessary and that there were inconsistencies in using scientific notation. It was also concluded that there was a need to clarify some of the information contained in the report for ease of understanding. We have therefore prepared this Supplemental Report to address these concerns. In order to facilitate your incorporation of these changes, we are resubmitting the entire report for your review rather than submitting a limited number of pages which would require insertion in our November 29, 1985 report. The sections of the report which are

, affected by this supplement are indicated by a line in the right-hand column of l the pages. Please find below a brief summary of the supplemental information.

! BVPS-1 R. G. 1.97 Variable Table (Summary of Supplement)

There are three general types of supplemental information provided for the Table:

1. Additional information on the availability of displays, particularly for the TSC and EOF,
2. Amended ranges for the control room instrumentation; the majority of which were made to provide consistent use of the exponential notation "E", and
3. Clarification for the Steam Generator Level Instrumentation by separately addressing the narrow and wide ranges, and clarification of the environmental qualification of containment hycjrogen concentration <

instrumentation by using terminology consistent with our environmental qualification documentation and with other parts of the table. M3 8610300168 861013 '

PDR ADOCK 05000334 P PDR s

.s-s oen er Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-33; Supplement to NUREG-0737, Regulatory Guide 1.97, Revision 2, Supplemental Report i, Page 2 -

We believe that the above supplemental information to the table should not affect the conformance status of the related instrumentation. It is noted here that in the contrcl room the radiation monitoring indications which are in units of cpm envelope the corresponding ranges in the units of pCi/cc. Also, for clarification, the intended meaning of the terms " indication" and " record" as used in the control room display column of the' table are, unless exception is taken, continuous meter indication and continuous chart recording, respectively.

Comment Notes to BVPS-1 R.G. 1.97 Variable Table (Summary of Supplement)

Some of the revisions to the Comment No s are in consequence of and correspond to the above revisions to the Table. Also, information was added or amended such as in Comment Notes 11, 12, 30, 35 and 36. Again, we do not believe that these revisions should affect the conformance status of the related instrumentations.

More extensive revisions to Comment Notes 29, 32 and 33 were considered appropriate to more clearly and accurately present the radiation and flow monitoring capability for effluent pathways. However, phase note that the results of a concurrent review has indicated the necessity to also revise some of the information in Comment Notes 29, 32 and 33 concerning the ranges of certain radiation monitors. A slight loss of sensitivity has resulted in the lower end of their ranges to be slightly above that recommended in R.G.1.97.

As built installation changes and shifts in calibration constants for the steam release monitors in Comment Notes 32 and 33 and a shift in calibration constants for the two, lower range, gaseous waste monitors in Comment Note 29 have resulted in the loss of sensitivity. We did not consider it necessary to revise the report for the radiation monitors where changes in range have occurred if the range still conforms to R.G. 1.97. We believe that the variation of the range as a function of periodic calibration which was mentioned in Comment Note 12 of the original report, adequately addressed these cases.

If you have any questions regarding this submittal, please contact myself or members of my staff.

Very truly yours, J. D. Sieber Vice-President Nuclear Operations

(

.s-s' ' Beavar Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 Generic Letter No. 82-33; Supplement to NUREG-0737, Regulatory Guide 1.97, Revision 2, Supplemental Report Page 3 Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission i Beaver Valley Power Station i Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 2

Director, Safety Evaluation & Control Virginia Electric & Power Company P. O. Box 26666 One James River Plaza Richmond, VA 23261 i

l I

J l

Beaver Valley Power Station Unit Number 1 Regulatory Guide 1,97, Revision 2 Supplemental Report October, 1986

,s-

/

O The accompanying table summarizes the status of conformance of the Beaver Valley Power Station Unit-1 (BVPS-1) to Regulatory Guide 1.97, Revision 2.

Provided below is additional information explanatory to the table.

Type A Variables The current BVPS-1 Emergency Operating Procedures (EOPs) have been used to identify those instrumets to be classified as Type A variables. These E0Ps are based on the Westinghouse Owner's Group Emergency Response Guidelines, Revision 1.

Environmental Qualification A "yes" in the table under environmental qualification indicates that the instrumentation complies with 10CFR50.49.

Seismic Qualification A "yes" in the table under seismic qualifications indicates that the instrumentation complies with the seismic qualification program which was the basis for plant licensing. An outline of the design philosophy for Seismic Class I systems and components is contained in the BVPS-1 UFSAR, Appendix B. ,

Quality Assurance Quality Assurance of the instrumentation is in accordance wijth the BVPS-1 Quality Assurance Program described in UFSAR, Appendix A.

Power Supply All safety-related instrumentation is fed from reliable and separate vital buses as described in Section 8.5.4 of the UFSAR to guarantee continuous monitoring and control of all instrument channels. Each bus receives power from a separate battery. The 1E designation as used in the table under Power Supply denotes that the instrumentation channel (s) is powered from a vital bus. The 120 volt AC vital bus system consists of four completely independent subsystems and is provided in accordance with IEEE Std. 308-1971, as also described in Section 8.5.4 of the UFSAR.

Electrically Separation The Category 1 instrumentation listed in the table, while not meeting the full requirements of R.G. 1.75, does possess adequate separation of channels. The plant design and installation complies with the AEC general design criteria 17 and 18 and the applicable BVPS specifications. This is consistent with separation requirements at the time the operating license for BVPS-1 was granted. The separation requirements are discussed in the UFSAR Sections 8.1, 8.5, 8.5.2.2, 1.29, Q7.1(3), Q8.5 and for Safety Guides 6 and 9.

Page 2 of 3

.s-a i

Redundancy Redundancy is indicated by the number of channels for a variable in the table. Deviations are identified in the notes for the table when appropriate.

Conformance to R.G. 1.97 ,

A "yes" in the column indicates conformance to R.G. 1.97 on the basis of the information provided above and in the table. A note is provided wherein the specific deviations are identified and in which additional information and/or supporting justification or alternatives are presented.

l l

l Page 3 of 3 t-

BVPS-1 R. C. 1.97 VARI ABLE TABLE ., [

, QUALIFICATION NUMBER OF RANCE/ DISPLAY LOCATION CONFORMANCE/ ,

VARIABLE TYPE /CATECORY ENVIRONMENTAL SE!SMIC CHANNELS STATUS POWER SUPPLY CONTROL ROOH TSC EOF (NOTE) e Containment Sump Level Al, Bl. C1, Yes Yes 2 Per 0-90 In. IE, Battery Indication Record One Yes Yes (1)

Plant Backed Channel B2, C2 -Yes Yes 1 Per 3-15 In. IE, Battery Indication Yes Yes Yes Plant Backed Containment Area Al, C), El Yes Yes 2 Per 1 1E7 IE, Battery Indication Both Channels Yes Yes Yes Radiation Plant R/Hr Backed Record Both Channels Primary Plant DWST A1, D1 Exempt, Hild Yes 2 Per 1-30 Ft. IE, Battery Indication Both Channels Yes Yes (2)

Level Environment Plant Backed Auxiliary Feedwater Al, D2 Yes Yes 1 Per 0-400 CPM IE, Battery Indication Each Channel Yes Yes Yes Flow Loop Backed RCS Pressure (WR) Al, Bl. Cl Yes Yes 2 Per 0-3000 1E, Battery Indication Both Channels Yes Yes Yes Plant PSIC Backed Record Both Channels RCS T Hot (VR) AI, BI Yes Yes 1 Per 0-700 'F IE, Battery Record Each Channel Yes Yes (3)

Loop Backed i RCS T Cold (WR) Al, Bl. B3 Yes Yes 1 Per 0-700 'F IE, Battery Record Each Channel Yes Yes (3)

Loop Backed Stecm Genera tor Level (NR) Al, Yes Yes 3 0-100% IE, Battery Indication Each Channel Yes Yes Yes pe r S .C. span Backed Record One Channel Per (see Note 4) Loop 1

Steam Cenerator Level (WR) D1 Yes 'Yes 1 per IE, Bat t ery Record Each Chanrel 0- 1 00 % Yes Yes (4)

S.C. span Backed (see Note 4)

Pressurizer Level Al, D1 Yes .Yes 3 per 0-I n0% Indication Each Chanrel IE, Battery Yen Yes (5)

Plant Backed Record Each Chanrel

==.w.-

E .

BVPS-1 R. C. 1.97 VARIABLE TABLE .. [

, QUALIFICATION NUMBER OF RANCE/ DISPLAY LOCATION CONFORMANCE/

VARIABLE TYPE /CATECORY ENVIRONMENTAL SEISMIC CRANNELS STATUS POWER SUPPLY CONTROL ROOM TSC EOF (NOTE)

Containment Pressure A1, 51, Cl Yes Yes 4 Per 10 55 IE, Battery Indication Each Channel Yes Yes Yes Plant PSIC Backed Record 1 Channel C1 Yes Yes 2 Per 0-200 1E, Battery Indication Each Channel Yes Yes Yes Plant PSIA Backed Record 1 Channel Containment Hydrogen A1, Cl, E3 Except Mild Yes 2 Per 0-10% IE, Battery Indication Each Channel Yes Yes Yes Concentration Enviro nme nt Plant Backed Record 1 Channel Steam Generator A1, D2 Yes Yes 3 Per 0-1400 1E, Battery Indication Each Channel Yes Yes Yes Pressure Steam PSIC Backed Record 1 Channel Per Generator Steam Generator RWST Level A1, D2 Exempt, Mild Yes 4 Per 0-55 Ft. 1E, Battery Indication Three Yes Yes (6)

Environment Plant Backed Channels Record 1 Channel Neutron Flux B1 No Yes 2 Per 1-lE6 IE, Battery Indication Each Channel y, , y,, (7)

Plant CPS Backed Record Each Channel No Yes 2 Per IE IE, Battery Indication Each Channel Yes Yes Plant IE-3 Backed Amps No Yes 4 Per 0-120% IE, Battery . Indication Each Channel Yes. Yes Plant Backed Record Each Channel Control Rod Position B3 NR NR 1 Per Full In/ Non IE 1 Status Light Per Rod Yes Yes Yes Rod Not Full 4

In RCS Soluble Boron 83 (See (See N/A 0-6000 N/A 4

Post Accident Sampling (8)

Concentration Note) Note) PPM Local Indication Core Exit Temperature B3/C1 (See (See 51 Per 0-1650*F Non IE 8 T/Cs Subcooling NWrgin Yes Yes (9)

Note) Note) Plant Display All T/Cs Plant Variable Computer Coolant Level In B1 (See (See 2 Per 0-100% IE, Battery Indication Each Channel Yes Yes (9) i Reactor Note) Note) Plant Span Backed Record Each Channel i

BVPS-1 R. C. l.97 VARIABLE TABLE ..'

QUALIFICATION NUMBER OF RANCE/ DISPLAY LOCATION CONFORMANCE/ , ;

V ARI AB LE TYPE /CATECORY ENVIRONMENTAL SEISMIC CHANNELS STATUS POWER SUPPLY CONTROL ROOM TSC EOF (NOTE)

Degrees Subcooling B2 (See (See 1 Per 200'F See Note Indication Yes Yes (9) i Note) Note) Plant Sub-

! cooled to ,

i 2000*F Superheat

, Containment Penetration B1 Yes Yes 1 Per Open/ IE, Battery 1 Fair Of Lights Per Yes Yes (10)

Isoletion V.stve Valve Closed Backed Valve Position (See Note For i

Exceptions) i l Radition Level in Cl Exempt, Mild (Bee 2 Per 10-lE6 IE, Battery Indication Each Channel Yes Yes (11)

Primary Coolant Environment Note) Plant CPM Backed Record Each Channel i

Analysis of Primary C3 N/A N/A N/A Up to Non IE Post Accident Sampling Yes j Coolant (Camma 10C1/g System - Sample Analysis t

] "S pec t rum) With Dilution ,

i j Condenser Air Ejector C3 Exempt, Hild NR 1 Per 10-1E6 IE. 3attery Indication Yes Yes (12)

Monitor Environment Plant CPM Backed Record i

Containment Purge C2 Exempt, Mild Category 2 Per 10-lE6 IE, Battery Indication Each Channel Yes Yes (29) j Exhaust Radioactivity Environment 3 Plant CPM Backed Record Each Channel Effluent released via identified release point.

I i

j RHR System Flow D2 No Yes 1 Per 0-8500 1E, Battery Indication Yes Yes (II)

Plant CPM Backed i

! RHR Heat Exchanger D2 No Yes 1 Per 50-400*F IE, Battery Record Yes Yes (13) i Outlet Temperature Plant Backed

)

i 1

l 1

y e

i l

N l

. . . - -. _ _ - . _ ~ _ - ~ .. - - - . ~ . _ . .- -- . --- - . _

BVPS-1 R. C. 1.97 VARIABLE TABLE -

QUALIPICATION NUMBER OP RANCE/ DISPLAY LOCATION CONFDIMANCE/ ,

VARIABLE TYPE /CATECORY ENVIRONMENTAL SEISMIC CHANNELS STATUS POWER SUPPLY CONTROL ROOM TSC EOF (NOTE) *

, Accumulator Tank Level D2 No NR 2 Per 0-100% IE, Battery . Indication Each Channel' Yes Yes (14) i And Pressure Accumula- Span Backed ,

tor

No NR 2 Per 0-800 IE, Battery Indication Each Channel Yes Yes Accumula- PSIG Backed tor Accumulator Isolation D2 Yes Yes  ! Per Open/ lE, Battery 1 Status Light Per Valve Yes Yes Yes

, Valve Position Accumula- Closed Backed tor i

Boric Acid Charging D2 No NR 1 Per 0-160 Non IE Record Yes Yes (15) l Flow Plant CPM Flow In LPI System D2 No Yes 1 Per 0-4000 lE, Battery Indication Each Channel Yes Yes (16)

- Train CPM Backed Reactor Coolant Pump D3 NR NR 1 Per 0-1200 Non IE Indication Each Channel Yes Yes Yes Status Pump ACI Primary System Safety D2 Yes Yes 1 Per Open/ IE, Battery Display Accoustic Yes Yes Yes

, Relief Valves Positions Valve Closed Backed Monitor (0-100%)

Yes Yes 1 Per Open/ IE, Battery 1 Status Light Per Valve Yes Yes Valve Closed Backed (PORVs) 1 1 Pressurizer Heater D2 Yes Yes 1 Per Closed / IE, Battery Control Switch Indication Yes Yes (17)

Power Availability Heater Trip Backed Group t

1 j Quench Tank Level D3 NR NR 1 Per 0-100% Non IE Indication Yes Yes (18) j Plant Span

! Quench Tank D3 NR NR 1 Per 50-350*F IE, Battery Indication Yes .Yes (19)

, Temperature Plant Backed 1

5 i

j i

I I 5 e I

_ m. .. _ .. . _ . .._ .

BVPS-1 R. C. 1.97 VARIA"LE TABLE ,,

QUALIFICATION NUMBER OF RANCE/ DISPLAY LOCATION CONFORMANCE/ .

VARIABLE TYPE /CATECORY ENVIRONMENTAL SEISMIC Chan* J' S STATUS POWER SUPPLY CONTROL ROOM TSC EOF (NOTE)

Quench Tank D3 NR NR 1 Per 0-120 lE, Battery Indication - Yes Yes Yes Pressure Plant PSIG Backed

! Main Feedwater Flow D3 NR NR 2 Per 0-4 . 6E6 IE, Battery Indication Each Channel Yes Yes Yes S.C. LB/HR Backed Record One Chan rel Per Long Containment Spray Flow D2 (20)

Containment Atmosphere D2 No NR 2 Per 0- 300* F IE, Battery Indication Each Channel Yes Yes (21) l Terparature Plant Backed 1

j containment Sump Water D2 Yes Yes 2 Per 0-300*F IE, Ba'ttery Indication Each Channel Yes Yes Yes Temperat ure Plant Backed

] RCS Makeup Flow-In D2 Exempt, Mild NR 1 Per 0-150 IE, Battery Indication Yes Yes Yes Environment Plant CPM Backed RCS Letdown Flow-Out D2 No NR 1 Per 0-150 IE, Battery Indication Yes Yes (22)

Plant CPM Backed volume Control Tank D2 No NR 2 Per 0-100% Non IE Indication Each Channel Yes Yes (23)

Level Plant Span i

Component Cooling Water D2 No NR 1 Per 0-200*F lE Battery Indication Yes' Yes (24)

Temperature to ESF Plant Backed

, System High Level Radioactive D3 NR NR 1 Per 0-132 IE, Battery Indication Yes Yes (25) l Liquid Tank Level Tank In Water Backed 3

Radioactive Cas Holdup D3 NR NR 1 Per 0-100 IE, Battery Record Each Channel Yes Yes (26)

Tank Pressure Tank PSIC Backed Emergency Ventilation D2 Yes Yes 1 Per Open/ IE , Battery 1 Status Light Per Yes Yes (27) j Damper Position (See Damper Closed Backed Damper j Note For Exceptions) i 1

1 i

I i

l 1

i i

4 i

i

BVPS-1 R. C.'t.97 VARIABLE TABLE .[

QUALIFICATION NUMBER OF RANCE/ DISPLAY IACATION CONFORMANCE// ',.

VARIABLE TYPE /CATECORT ENVIRONDENTAL SEISMIC CHANNELS STATUS POWER SUPPLY CONTROL ROOM TSC EOF. (NOTE) .

High Pressure SI Flow D2 Yes Yes 1 Per 0-1000 Non-lE Indication Record Yes Yes Yes Plant CPM Status of Standby Power D2 Exempt, Mild Yes I per Channel Non-lE Indication Each Channel Yes Yes Yes and Other Energy Sources Environment Voltage / . Specific Important to Safety Current Radiation Exposure Rate- C2 (See ( S" 1 Per Channel Non-lE with Indication Each Channel Yes Yes (28)

Inside Buildings or Areas Note) Note) Monitor Specific Backup Power Record Each Channel which are in Direct Contact (See Note) with Primary Containment Where Penetration and Hatches are Located Effluent Radioactivity C2 Exempt, Mild IS** 1 Per Channel Non-lE with Indication Each Channel Yes Yes (29)

Noble Cases From Area Environment Note) Monitor Specific Backup Power Record Each Channel Indicated for Previous (See Note)

Variable Secondary System Safety D2 No Yes 1 Per Open/ Closed Relief Valve Positions IE, Battery 1 Fair of Status Lights y, y, (30)

S.C. Backed Per Valve Radiation Esposure Rate - E2 (See (See 1 Per 0.1-lE4mR/ Non-lE Indication Each Channel Yes Yes (31)

Areas Where Access is Note) Note) Monitor HR. Record Each Channel Required to Service Equipment Important to Safety 5 .

BVPS-1 R. C. 1.97 VARIABLE TABLE .

QUALIFICATION NUMBER OF RANCE/ DISPLAY LOCATION CONFORMANCE/

VARIABLE TYPE / CATEGORY ENVIRONMENTAL SEISMIC CHANNELS STATUS POWER SUPPLY CONTROL ROOM TSC EOF (NOTE)

Noble Cas and Vent E2 Effluent released via identified release point.

Flow-Containment or Purge Effluent Noble Gas and Vent E2 Effluent released via identified release point. (29)

Flow-Raactor Shield Building Arinu lu s Noble Cas a,d Vent E2 Effluent released via identified release point.

F l ow- Aux i li ary (29)

Euilding Noble Cas aid Vent E2 Effluent released via identified release point. (29)

Flow- Connar Plant Vent

" Vent from S.C. Safety E2 Exempt. Mild (See  ! Per Indication Each Channel 10-lE 6C PM IE Batt ery y, y. (32)

Relief Valves or Environment Note) Loop Backed A t mos phe r ic Valves Noble Cas and Vent E2 Exempt. Mild (See Flow Rate-All Other I 10-lE 6C PM IE Battery Indication yes Yes (33)

Environment Note) Backed Idsntified Release Points Particulates and Halogens- E3 N/A N/A N/A N/A All Identified Release IE Laboratory Analysis N/A N/A Yes Points (except S.C. IE2dCi/cc of Filter Safety Reliefs or Atmospheric Dumps)

Sempting with On Site Analysis k

s

  • BVPS-1 R. C. 1.97 VARIABLE TABLE , .

QUALIFICATION NUMBER OF RANCE/ DISPLAY LOCATION CONFORMANCE/ .

VARIABLE TYPE /CATECORY ENVIRONMENTAL SEISMIC CHANNELS STATUS POWER SUPPLY CONTROL ROOM TSC EOF (NOTE)

Environs Ra. fiat ion and Radioact ivity Radiation Esposure Meter E3 (3'I Airborne Radiohalogens E3 NR NR N/A IE- 9uct /cc N/A N/A N/A N/A Yes and Particulates IE- 3uct / c c (Portable Sampling with On Site Analysis Capability)

Plant and Environs E3 NR NR N/A (See Note) N/A N/A N/A N/A (35)

Radiation (Portable Instrumentation)

Plant and Environs E3 NR NR N/A Camma-Ray N/A N/A WA N/A Yes Radiation (Portable Spectrometer

" Instrumentation)

Mateorlogic.it E3 NR NR 1 Parameter Non-!E Strip Chart Recorders Yes Yen (36)

Parameters S pec i fic Accident Sanpling E3 This capability exists via the PASS (see Note 8) Yes Capability-Primary Coolant and Sump and Containment Air-Analysis Capability On Site NA = Not Applicable NR = Not Required E .

Comment Notes to BVPS-1 R.G. 1.97 Variable Table

1. Containment Sump Level R.G. 1.97, Revision 2, recommends that the containment sump level indication, wide range, measure from the bottom of containment to 600,000 gallons level equivalent. The BVPS-1 indication is from 0-90 inches and is considered adequate based on plant specific requirements for operator monitoring as described in the symptom based E0Ps. It is also noted that Revision 3 of R.G.1.97 changed the gallonage criterion to plant specific.

Based on the above, we believe the instrumentation to be in conformance with R.G. 1.97.

2. Primary Plant DWST Level The BVPS-1 instrumentation for this variable does not conform completely to redundancy in that the instruments are powered from the same vital bus. The following describes the existing instrumentation for this tank and summarizes the related BVPS-1 procedural instructions to the operator.

Both level transmitters provide remote level indication in the Control Room, and there are two low-level alarms and two low-low level alarms. In addition to these transmitters, a local tank level indication is available. A loss of power to either transmitters will result in a full downscale indication and a low-level alarm. The local " float type" level indicator would provide indication should a power failure occur to both channels. The operator is instructed to monitor the PPDWST level as a criterion of auxiliary feedwater switchover. Upon reaching a low-level alarm at approximately 26 1/2 feet water level, the operator is instructed to take water makeup action to the PPDWST and first verifies the alarms by observing the remote level indication. If both level indications read low, the operator verifies low level using the local indication, if it is suspected that the power supply has lost power. Should the water level in the tank decrease to approximately four feet, a low-low level will alarm. This setpoint allows 30 minutes for the operator to take corrective action.

Based on the above and a review of this system, the following is provided in support of the existing instrumentation.

a. The instruments do not provide assistance in determining the nature of
any accidents addressed in the FSAR.
b. The instruments do not provide early indications necessary to protect the public or provide an estimate of the magnitude of an impending threat,
c. Performance of the AFWS is primarily evaluated by the operator through interpretation of auxiliary feedwater flow, steam generator level, and 4 RCS temperature and the level instrument indication does not, therefore, define proper operation of reactor trip ESF system 1 operation.

i

, Comment Motes to BUPS-1 R.C. 1.97 Variable Table (cont.)

d. The instrument power supply failure would not cause the operator to

, take actions that would aggravate the course of any accident. The instruments simultaneous failures would only result in conservative actions being taken earlier in an accident.

e. The instruments do not provide information related to determining the potential for breaching any fission product barriers.
f. The instruments are not subject to HELB and electrical failure can be readily identified through annunciation. Local " float type" level indication is utilized for a backup system.
3. RCS T hot and T cold The range of 0-700 F for RCS T hot and T cold is considered to be in conformance with R.G. 1.97 based on the Revision 3 recommended range of 50-700 F.
4. Steam Generator Level Narrow Range: The BVPS-1 narrow range level indication of 0-100% represents a span of approximately -5 to +7 feet from nominal full load water level.

During accident conditions, operator action (i.e. regulation of feedwater flow) is based on the 5% to 50% range of this span.

Wide Range: R.G. 1.97 recommends wide range level indication from the steam generator tube sheet to the separators. The BVPS-1 level range of 0-100%

represents a span twelve (12) inches above the tube sheet to a point above the separators or approximately -41 to +7 feet from nominal full load water level. During accident conditions, operator action (i.e. a determination of the effectiveness of secondary heat sink) is based on the 10% value of this span - values below 10% indicating approaching depletion of steam generator inventory. Since the 0% indicated level down to the tube sheet represents a small percentage of steam generator volume, the additional twelve inches of span capability would provide only marginal benefit.

5. Pressurizer Level R.G. 1.97 recommends level indication from the top to the bottom of the
pressurizer. The BVPS-1, 0-100% span is essentially for the cylindrical portion of the pressurizer and does not include the hemispherical ends. The currently installed span provides adequate indication to evaluate system conditions and to initiate manual operator actions for accident conditions.

J i

i Page 2 of 17 i

. . . . . _ . _ _ - _ . . _ - - . _ _ _ . _ _ , _ . . _ . _ , , _ _ _ _ . , . _ _ _ , . . - _ _ _ - . _ _ , . . . _ . . _ . _ - , - . _ ~_..-..,_. - _.___ -

q

, ' Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

6. Refueling Water Storage Tank (RWST) Level R.G. 1.97 recommends that the RWST level be measured from the top to the bottom of the tank. The BVPS-1, 0-1004 calibrated span is from twelve inches off the bottom to within approximately one foot off the top of the tank. This spans fifty-five (55) of the approximately fifty-seven (57) feet of tank height. The RWST level instrumentation adequately provides for all levels of indication required during emergency operating conditions such as switchover from the injection to recirculation mode.
7. Neutron Flux R.G. 1.97 recommends that the neutron flux indication be environmentally qualified. The description of the BVPS-1 installed Reactor Control System is provided in Section 7.7 of the UFSAR with response consideration of reectivity in Section 7.7.2.2. In general, overall reactivity control is achieved by the combination of soluble boron and rod cluster control assemblies. Long-term regulation of core reactivity is accomplished by adjusting the concentration of boric acid in the reactor coolant. Short-term reactivity control for power changes is accomplished by the rod control system, which moves the RCCAs. This system uses input signals including neutron flux, coolant temperature, and turbine load. Borating the primary system after an accident in accordance with the E0Ps ensures that adequate shutdown margin is maintain. In addition, a loss of shutdown margin would be reflected in a heatup of the RCS, which is monitored by qualified instruments.
8. RCS Soluble Boron Concentration R.G. 1.97 recommends that continuous indication for this variable be provided in the Control Room. BVPS-1 utilizes the Post Accident Sampling System (PASS) for this variable. The PASS lines and equipment are designed to conform to the classification of the system to which each sampling line is connected. In addition, PASS is designed to meet clarification Item II.B.3 in NUREG-0737 by promptly obtaining reactor coolant and containment atmosphere samples, which can be analyzed under accident conditions. In-line anlayzers are provided for direct measurement of dissolved Oxygen, dissolved Hydrogen, pH, Boron, Chloride, and conductivity from post accident samples. Additional information on PASS is contained in Section 9.6 of the UFSAR.
9. Core Exit Temperature, Coolant Level in Reactor and Degrees Subcooling The Core Exit Thermocouple (CETC) System, Coolant Level in reactor and degrees subcooling are elements of the Inadequate Core Cooling (ICC)

Instrumentation. The BVPS-1 proposed ICC System is presented in our letter to the NRC dated April 24, 1984, in response to the NRC request for additional information dated December 16, 1983, NUREG-0737, Item II.F.2; ICC Instrumentation System (Generic Letter 82-28).

page 3 of 17

,' Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

10. Containment Penetration Isolation Valve Position There are three general groupings of containment isolation valve position indications, which are not in strict conformance with the recommendations of R.G. 1.97. They are classified and identified below based on (A) electrical redundancy, (B) environmental qualification, or (C) Control Room indication availability,
a. Containment isolation valves in series which do not have electrically redundant position indication, within a single train of equipment.

This arrangement of valve position indication is for the two Hydrogen Analyzers, which are on separate trains and redundant to each other.

The valve position indications for one analyzer are, therefore, correspondingly on the same train, Train A, and those for the other analyzer are on Train B. This arrangement is necessary to maintain the redundancy of one anlayzer to the other and is, therefore, believed to be an acceptable deviation from R.G. 1.97.

b. Environmental Qualification: Within this classification there are four subgroupings of valve position indication.
1) Containment isolation valves in series wherein the position indication for the valve inside containment is environmentally qualified or is a check valve (CV) and the position indication for the valve outside containment is not environmentally qualified.

The number of outside valves is listed below generically.

Component Cooling Water System (12 valves)

RCS Letdown Line (1 valve)

Containment Sump Pump Discharge (1 valve)

Primary Drain Transfer Pump No. 1 Discharge (1 valve)

S.I. Accumulator Sample Line (1 valve)

Pressurizer Relief Tank Nitrogen Supply (1 valve, CV inside)

Primary Grade Water Supply to the Pressurizer Relief Tank (1 valve, CV inside)

Main Condenser Ejector for Containment (1 valve, CV inside)

Pressurizer Relief Tank Vent (1 valve)

2) Containment isolation valves in series where indication for the valves are not environmentally qualified.

Sampling System (9 pairs of valves, one inside and one outside containment)

Containment Activity Monitor Suction (1 pair of valves outside containment)

Containment Vacuum Pump 1B Suction (1 pair of valves outside containment)

Containment Open Pressure System (1 pair of valves outside containment, channel separation does not exist)

Page 4 of 17

, Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

3) Containment isolation valves in a closed or sealed system wherein the position indication is not environmentally qualified.

Containment Sealed Pressure System (2 valves inside containment, CV outside each line)

Main Steam Line Trip Valves (3 valves outside containment)

Main Steam Blowdown (Line Drain) (3 valves outside containment)

4) Containment 1:olation valve position indication, which is not environmentally qualified but may be opened or closed on an intermittent basis under administrative control.

Nitrogen supply lines to SI Accumulators (two valves in series, one inside and one outside containment).

SI Accumulator Testline (one valve inside containment, position indication environmentally qualified, in series with one valve outside containment).

For each of the above four groups of valve indications, the following E0P information on performance of containment isolation checklists is provided.

Dual or no valve indication (red green status lights) will be' indicated if a containment isolation valve fails for any reason.

In accordance with the EOPs, the operator notes the discrepancy

, when isolation valve status is checked.

If a discrepancy exists with a valve, the operator checks and notes that its redundant valve is closed and checks that the redundant valve is not subject to an adverse environment. If the redundant valve stays open, the E0P checklist identifies the solid state protection system slave relays to associated equipment and instructs the operator in taking the appropriate actions for maintaining containment integrity. Valves that have environmentally qualified components are identified on the checklist.

c. Containment Isolation Valves Which Have No Control Room Indication i

Thirty-three (33) cor,tenment isolation valves are identified for BVPS-1, which do not have Cuatrol Room indication. The main steam code safety valves are not included here as they are addressed elsewhere in the table. We believe that no Control Room indication is necessary for these valves based on the following results of our review.

Paga 5 of 17 i

-- - - - - , . - - . . - - - - - - . - , . ~ . - . . . - - - , , - . .- . . _ , . . - - - ~ , , - - - - . , - - - , - - - - - . . - -

/ Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

Thirty-one (31) of the valves are included either in an operation surveillance test or quarterly padlock log review. The normal system arrangement for all thrity-three (33) valves is " shut" with twenty-five (25) valves being locked shut and two valves having lead seals for administrative control. One of the locked shut valves may be opened or closed on an intermittent basis under administrative control.

One of the two remaining valves is a relief valve in the RCS letdown line. This line has remote temperature indication and alarms in the Control Room, which provides backup indication for the status of this valve. The other remaining valve is inside containment and is associated with the containment air lock. For personnel to exit containment, this valve must be closed in order to equalize the airlock pressure.

11. Radiation Level in Primary Coolant The BVPS-1 channels for this variable are not in strict conformance with R.G. 1.97 redundancy recommendation in that they are powered from the same IE source, battery backed. Also, these monitors are located in letdown which is isolated as a result of a safety injection signal (see Note 22).

However, evaluation of this variable can be backed up by the PASS in the event the common IE power source should be lost or upon isolation of letdown (See Note 8, PASS). Category 1 is not considered necessary since these monitors are backed up by the PASS.

12. Condenser Air Ejector Monitor The instrumentation for this C3 variable meets the guidance of R.G. 1.97, except the range is 2.85 E-5 pCi/cc to 2.85 pCi/cc Xe-133. It should be noted, however, that the Condenser Air Ejector Vent Monitor is not the final point effluent monitor and, therefore, it is not included as an E2 variable.

As a general note, the radiological instrumentation ranges as above are nominal values. Actual ranges vary as a function of periodic calibration.

13. RHR System Flow & RHR Heat Exchanger Outlet Temperature The instrumentation for the RHR System Flow and RHR Heat Exchanger Outlet Temperature deviate from R.G. 1.97 in environmental qualification and in the heat exchanger minimum indicated temperature.

With respect to the latter, R.G. 1.97, Revision 2, recommends a minimum temperature indication of 32 F. This minimum temperature has been changed to 40*F in Revision 3 to R.G. 1.97. The BVPS-1 minimum temperature indication of 50 F is, therefore, not considered a significant deviation.

In addition, during cold shutdown, the heat loads are transferred by the RHR Heat Exchangers to the component cooling water. The component cooling system with all components operating as designed will produce water at 70 F with the river water at 34 F. Therefore, the minimum indicated temperature of 50 F envelopes the lowest expected RHR Heat Exchanger Outlet temperature.

Page 6 of 17 l

l t

, Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

The environmental qualification of equipment that pertains to the RHR system should bot be considered deficient. BVPS-1 is licensed and designed for hot shutdown and is not required to have a Class 1E qualified path to cold shutdown. For this reason, the equipment listed in the R.G. 1.97 table for the RHR system is considered exempt from environmental qualification.

In our submittal pertaining to environmental qualification, we have also provided information for a primary and backup method to RHR, for each of several accident scenarios, which would preclude any problems with putting the plant in a cold shutdown condition.

14. S.I. Accumulator Tank Level and Pressure R.G. 1.97 categorizes accumulator tank level and pressure as a Category 2 variable and thus requiring environmental qualification. Category 2 is designated for instrumentation indicating system operating status after an accident. Based on the following, we believe that the BVPS-1 instrumentation for accumulator tank level and pressure should not be Category 2 but Category 3 variables.

The accumulators are a passive safety feature in that they will perform their design function in the total absence of an actuation signal or power source. The only moving parts in the accumulator injection train are in the two check valves. Information on the accumulator check valve tests and reliability and the administrative controls placed on the accumulator isolation valves are provided in Section 6.3.3.7 of the BVPS-1 UFSAR. The accumulator isolation valve position indications are qualified as presented in the table herein. To provide additional assurance that the isolation valves are open, they also receive an actuation signal to open on S.I.

The current BVPS-1 Emergency Operating Procedure (symptom based) do not require either the accumulator tank level or pressure to be monitored during or after an accident. During certain accidents, the accumlators are isolated by operator action to prevent discharge into the RCS when RCS subcooling or hot leg temperature criteria are satisfied. In these cases, either the contents of the accumulators are no longer required because of operator control actions or the contents are considered to be discharged and isolation prevents nitrogen injection to the RCS. Nitrogen injection into the RCS is prevented whenever the RCS pressure remains greater than 210 psig. The corresponding operator action to isolate the accumlators is based, therefore, either on RCS pressure or, if appropriate, on other system parameters which correlate to the RCS pressure (i.e. S.G. pressure).

The accumulator pressure and level indications are only required during normal operation to meet Technical Specifications. The accumulator pressure is required by the BVPS-1 Technical Specifications to have a nitrogen cover pressure of between 605 and 661 psig during normal operation. The analysis for LOCAs in Chapter 14 of the BVPS-1 UFSAR indicates that RCS pressure will decrease below 605 psig for LOCAs down to and including the three inch small break. It is, therefore, anticipated that the accumulators will passively discharge into the RCS for these accidents.

Page 7 of 17

-l Comment Notes to BVPS-2 R.G. 1.97 Variable Table (cont.)

The accumulator tank level indication (0-100% span) does not conform to the R.G. 1.97 recommended range of 10-90% volume. The BVPS-1 level span covers the equivalent tank volume of 7145 gallons minimum to 7981 gallons maximum which envelopes the BVPS-1 Technical Specification range of 7664 for 7816 gallons. The level instrumentation in conjunction with accumulator pressure indication enables the operator to establish the required water-nitrogen ratio for normal operation which provides assurance of the passive operation of the SI accumulator system in response to accident conditions. We believe, therefore, that the existing range for the accumulator level instrumentation is adequate.

15. Boric Acid Charging Flow The Westinghouse Owner's Group Emergeacy Response Guidelines, upon which the BVPS-1 current E0Ps are based, do not consider boric acid charging flow as a parameter to be used by operations during or following an accident. Under these conditions, borated water is pumped from the large volume RWST into the RCS. BVPS-1 has designated RWST level, HHSI flow, LHSI flow, containment water level, and emergency core cooling system (ECCS) valve status for monitoring the performance of the ECCS since the ECCS does not normally take suction from the boric acid tank. If boration is used following an accident, qualified charging flow indication and RCS sampling are used to demonstrate that the RCS is being adequately borated.
16. Flow in Low Pressure Injectier. (LPI) System R.G. 1.97 recommends that the flow indication in the low pressure injection system be environmentally qualified. We believe that the LPI flow indication does not need to be environmentally qualified based on the following.

The LPI System is part of the Emergency Core Cooling System. A single active failure analysis is presented in Table 6.3.1 of the UFSAR. Credible active system failures are considered. The analysis of the LOCA presented in Section 14 is consistent with the single failure analysis, based on a single failure in the ECCS.

The analysis shows that the failure of any single active component does not l prevent fulfilling the design function; also, operator action is not required to correct the malfunction.

In addition to the single active failure capability, an alternate flow path is available through the high head safety injection pumps should any part of the flow path from the low head pumps to the RCS cold legs become i unavailable. This feature ensures that core cooling would be monitored in the event of a piping failure in the ECCS. It also should be noted that the reactor cold legs are fed via a common header in the injection mode and it

is not possible to isolate the broken leg and prevent spilling under the present design.

Page 8 of 17 i

,' Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

Failure analysis of the emergency power supply under LOCA conditions are described in Section 8.5 of the UFSAR.

Both the charging and low head safety injection pumps are located outside the containment and are electric motor-driven. The pumps also ensure an adequate supply of borated water for an extended period of time by recirculation of the water from the containment sump to the reactor core through two separate flow paths.

Within the basis provided in Section 6.3.1.2 of the UFSAR on ECCS Single Failure Criterion Compliance, continued function of the ECCS will meet minimum core cooling requirements and offsite doses resulting from the leak will be within 10CFR100 limits.

There are two separate low pressure safety injection subsystems, which provide long-term reactor core decay heat removal. The redundant features of the ECCS recirculation loop include one pump in each of two separable and redundant trains with crossover capability at the discharge of each pump.

Each pump takes suction through separate cross-connected lines from the containment sump. The system design provides for one pump failing to start, with one LHSI being sufficient to meet the requirements of safety injection.

Based on the above and depending on the type of accident in progress (i.e.

small or large loss of primary or secondary coolant), the operator has adequate backup instrumentation from which the operational status of the LPI System can be derived and by which the operator can take the appropraite contingency actions. These system indications include, RCS pressure, charging /HHSI flow and pump ammeter indications, RCS subcooling, and pressurizer level. In addition, the operator has direct indication of pump operation via the LHSI pump switches and status lights and both LHSI pump ammeter indications on the main control boards.

17. Pressurizer Heater Power Availability R.G. 1.97 specifies that heater current is the preferred parameter for determining heater status. For BVPS-1 heater breaker position, not current indication, was selected for determining heater status. Breaker position provides adequate indication to the operator to ensure the pressurizer heaters are operable. In addition, the power consumption of each of the backup heater groups, A, B, D, and E, is tested on an 18-month interval basis pursuant to Technical Specification Surveillance Requirements.
18. Quench Tank Level R.G. 1.97 recommends level indication from the top to the bottom of the quench tank. The BVPS-1 level indication does not cover this full range.

The level instrumentation provides for annunciated alarm High/ Low of 78 2/66 1 2%. Upon receipt of the alarm, the operator is instructed to correct the level to approximately 72% of the span. Based on the control range and the design provisions for the tank, we believe that the existing level range is adequate.

Page 9 of 17 i

/ omaent Notes to BVPS-1 R.G. 1.97 Variable Table (cnnt.)

19. Quench Tank Temperature (Pressurizer Relief Tank)

R.G. 1.97 recommends a range of 50 - 750 F for temperature indication for the tank contents. The temperature indication range is from 50 - 350 F, the design temperature of the tank. The volume of water in the tank is capable of absorbing the heat from the design discharge from the pressurizer with an initial temperature of 120 F, increasing to a final temperature of 200*F. During accident conditions we do not anticipate the temperature to exceed 350 F due to the tank rupture disc relief pressure of 85 5 psig.

+

20. Containment Spray Flow R.G. 1.97 recommends instrumentation for this variable with a range of 0-110% of design flow. BVPS-1 does not have direct indication of spray flow.

However, we believe that adequate instrumentation is presently avaialble in the Control Room and that the addition of spray flow indication would not provide additional essential information. The instrumentation presently available in the Control Room is delineated below and includes both containment Quench Spray (QS) and Recirculation Spray (RS).

QS low flow alarm QS and RS pump motor breaker positions QS and RS pump motor currents QS and RS pump discharge pressures QS and RS valve position indications Containment pressure RWST level River water flow to RS heat exchangers It should be noted that both QS trains and all four of the RS subsystems are rated at 100% capacity. The effects of containment spray can be monitored by containment pressure. Any trouble in returning the containment pressure subatmospheric or maintaining the containment vacuum would result in timely operator action.

21. Containment Atmosphere Temperature R.G. 1.97 recommends that the Containment Atmosphere Temperature be a Category 2 variable. The Westinghouse Owner's Group Emergency Response Guidelines, on which the BVPS-1 E0Ps are based, do not require operator action based on containment temperature indication, but on the use of 0-300 F. Based on the above, the containment temperature indication should be considered a Category 3 variable and the existing range considered adequate.
22. RCS Letdown Flow R.G. 1.97 recommends that RCS Letdown Flow indication be a Category 2 variable, thus requiring environmental qualification. Based on the following, we believe that this flow indication should not require environmental qualification.

i Page 10 of 17

Commant Notes to BVPS-1 R.G, 1,97 Variable Table (cont.)

The RCS Letdown and the Volume Control Tank are part of the Chemical and Volume Control System (CVCS). Other than the charging /HHSI Pumps, the CVCS is not required to function during a LOCA, nor is it required to take action to prevent an emergency condition. During LOCA, this system is isolated at the containment boundary except for the charging pumps and the piping is the safety injection flow path.

The generation of a safety injection signal automatically closes the motor-operated valves in the outlet line of the volume control tank and in the normal charging line, thus isolating the CVCS from the safety injection path. The letdown line is isolated by valves, which automatically close as a result of a safety injection signal.

23. Volume Control Tank (VCT) Level (See also Note 22)

R.G. 1.97 recommends that the VCT Level instrumentation measure from the top to the bottom of the tank. The BVPS-1 level instrumentation is on the cylindrical section of the tank and does not include the hemispherical heads and a portion of the cylindrical section. However, the level instrumentation is designed to accommodate all normal design flow, providing for diverting the letdown flow and ensuring suction for the charging pumps for normal RCS makeup flow.

24. Component Cooling Water (CCW) Temperature to ESF System R.G. 1.97 recommends that the CCW Heat Exchanger Outlet Temperature to the ESF System be environmentally qualified. We believe that this upgrade is not necessary since, although the CCW Subsystem normally supplies water to some safety-related items (RHR heat exchangers and fuel pool heat exchangers), it is, however, not used for accident purposes and is not considered part of the Engineered Safety Features as discussed in Section 9.4 of the UFSAR.

However, in the event of a DBA, the river water system is designed to supply sufficient cooling water to the following ESF components; at least two recirculation spray heat exchangers (coolers) and at least one charging pump lube oil cooler.

With a minimum 100% backup capacity at the onset of an accident, the recirculation spray subsystem design is conservative. Within one day after the LOCA, the backup capacity exceeds 400%. The system is designed to satisfy a maximum 86 F inlet temperature of the cooling river water for the recirculation cooler. An annunciator alarm for intake river water temperature greater than 86 F is provided in the Control Room.

The following instrumentation is available in the Control Room for the operator to monitor the River Water System.

Page 11 of 17

ommsnt Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

a. Flow indication for the 1A and IB river water supply header to the four recirculation spray heat exchangers.
b. Flow indication for the river water discharge header from the four recirculation spray heat exchangers.

. c. Annunciator alarm for river water pump auto start-stop.

In addition, each recirculation spray cooler has outlet temperature indication in the Control Room for the recirculation spray flow.

25. High Level Radioactive Liquid Tank Level The BVPS-1 Level instrumentation does not completely measure the tank level from top to bottom as recommended in R.G. 1.97. However, the deviation is not considered significant since the tap for the level transmitter is eight inches above the hemispherical bottom of the tank.
26. Radioactive Gas Holdup Tank Pressure R.G. 1.97 recommends that the tank pressure indication is from 0 to 150's designed. The BVPS-1 design pressure is 100 psig for the tanks. Indication is also to 100 psig. However, over pressure protection is provided in the form of a pressure controller followed by a rupture disc in parallel with a restriction orifice and a rupture disc. When the pressure in the decay tank reaches .00 psig, the pressure controller will relieve gas for the release system. If the pressure controller fails to open at the required pressure, the rupture disc, in parallel with the pressure controller will relieve at 110 psig.
27. Emergency Ventilation Damper Position There are three Emergency Air Supply Fan Discharge Dampers for the Control Area, which do not have position indication in the Control Room. We believe that position indication for these dampers is not necessary due to the operational characteristics of this system as presented below.

The two Emergency Outdoor Air Supply Fans, when started, will open their own discharge dampers and will send a pneumatic opening signal to a selector relay to open the common air filter discharge damper. The selector relay is

.used to separate the individual damper control systems. The fans do not function during a chlorine leak for which a supply of compressed air is provided to the Control Room. One hour after initiation of Containment Isolation Phase B (CIB), two automatic timers will start the Emergency i Supply Fans. Fan control switches with indicating lights are provided to the operator in the Control Room. A Control Area Differential Pressure

+

Indicator (manometer) is located in the Control Room, which provides monitoring capability to the operator to assure a positive pressure is maintained in the Control Area. The Control Area positive pressure is indicative of the operating status of the Emergency Air Supply.

Page 12 of 17 l

,* Commgnt Notes to RVPS-1 R.G. 1.97 Variable Table (cont.)

28. Radiation Exposure Rate - (inside buildings or areas which are in direct contact with primary containment where penetrations and hatches are located.)

The following information is provided for the BVPS-1 instrumentation for this variable. We believe that this instrumentation meets the intent of the guidance of R.G. 1.97.

Ranges, Category and Purpose of Instrumentation.

a. Reactor Containment (High Range) Area Monitor (outside personnel hatch)

Range: 1.04-4 to 1.0E4 R/hr.

Category: 3

Purpose:

Personnel Exposure Control; Assess Containment Activity

b. Leak Collection Areas Gas Monitor Range: 2.86E-7 pCi/cc to 2.86E-2 pCi/cc, Xe 133 Category: 3

Purpose:

Detect Breach of Containment Penetrations.

c. Supplemtary Leak Collection Release System (SLCRS)

Effluent Monitors (2 Monitors)

Range: 1.84E-11 to 1.84E-6 pCi/cc, 1-131 2.86E-7 to 2.86E-2 pCi/cc, Xe 133 Category: 3, with backup power.

d. Reactor Building /SLCRS Effluent Monitor Range: 8E-8 to 1.0E5 pCi/cc Xe 133 Category: 3, with backup power
e. Reactor Building /SLCRS Effluent Monitor Range: 8E-8 to 1.0E5 pCi/cc Xe 133 Category: 3, with backup power NOTE: Monitors described in c, d, and e operate in parallel with each other, and in series with b.

The following information should be considered for the above instrumentation:

1) Area radiation monitors are not suitable for the intended purpose. Conditions that could result in an increase of containment pressure necessary to create leaks in penetrations will be accompanied by high radiation levels which would mask any radiation emitted by leaking containment gas. This is particularly the case with personnel and equipment access hatches.

Page 13 of 17

-[ Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

2) Even without this direct / scattered radiation, an area monitor would not be as sensitive a leak detector as would be a ventilation monitor on the exhaust of the area into which the penetration occurs. This is the purpose of Monitor b above, which monitors the ventialtion exhaust from the penetration / safeguards equipment areas (SLCRS).
3) Considerations with regard to penetrations.

a) .For miscellaneous piping systems, refer to Paragraph 2 above.

b) For ventilation penetrations refer to Effluent Radioactivity - Note (29).

c) Personnel Access Hatch monitor is described in Item "a" i above.

d) Equipment Hatch - unmonitored. This hatch would leak directly to the environment. No direct mnitoring is possible as described in Paragraph 1 above. Leakage via this pathway will be assessed by onsite monitoring terms using airborne activity samples.

29. Ef fluent Radioactivty - (noble gases from buildings identified for previous variable.)

Instrumentation for this variable is provided for the Auxiliary Building -

Ventilation vent (4 monitors), the SLCRS (4 monitors), and the Gaseous Waste System (4 monitors). These are considered to be Category 3. All twelve monitors have backup power. For each area a separate Noble Gas Monitor, whose range (Xe-133) envelopes that recommended in R.G. 1.97, was installed to meet NUREG-0737 requirements. In addition, the remaining monitors for each area have overlapping ranges (Xe-133), which span that recommended in R.G. 1.97, except for a slight calibration shift in the lower range of the two gaseous waste monitors which raised the lowest value of their monitoring capability to 1.1E-6 pCi/cc. The higher values for the upper range monitors typically exceed the R.G. 1.97 value by approximately a factor of IE2. We believe, therefore, that the redundancy, except for the slight deviation noted above, of the existing monitors provides a capability which meets the intent of R.G. 1.97.

The output from the SPING related monitors for each of the above areas is available in the 95C/ EOF via an interface to the BVPS Atmospheric Radioactive Effluent Release Assessment System (ARERAS). It is noted that i the control room indicated scale and units are 10-1E6 CPM which envelopes the range for each of the above twelve monitors.

i The capability for indicating / recording flow in the control room for the Auxiliary Building Vent, the Gaseous Waste Effluent and the SLCRS is

! described below. In each case the capability satisfies the 110% of design

! flow that is designated in R.G. 1.97, Footnote 10, as the maximum flow i anticipated in normal operations.

i 4

f Page 14 of 17

~-

.e Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)

A control terminal in the control room provides the capability for the operator to request pr'inted flow data, via the SPING system for each of the release points identified above. Computer storage of the SPING data provides flow data recording capability. ARERAS can obtain the signal from the same control terminal and display the flow data in the TSC/E0F.

In addition, the flow rate for the Auxiliary Building Vent can be obtained from its flow velocity chart recorder posted with conversion factors for flow rates. And, the flow rate for the Gaseous Waste Effluent Flow can be obtained directly from its flow rate chart recorder. Although there is no additional capability in the control room for obtaining the flow rate for the SLCRS, there is a local flow rate chart recorder located on the 768 foot level of the Auxiliary Building which also satisfies the 110%

indicating / recording capability.

30. Secondary System Safety / Relief Valve Positions The instrumentation described in the table is for the three atmospheric steam dump valves. The code safety valves have no position indication in the Control Room. We believe that the intent of R.G. 1.97 (i.e. to determine if valves are opened or closed) can be satisfied by the Main Steam
Line flow Indication in conjunction with Main Steam Line Pressure. This l instrumentation is environmentally qualified and displayed in the Control l Room. Each Main Steam Line has both Flow (2 channels) and Pressure

! Instrumentation (3 channels) are located upstream of the safety and relief l

valves, and the main steam isolation valves, respectively.

31. Radiation Exposure Rate - (areas where access is required to service equipment important to safety).

The BVPS-1 area radiation monitoring system contains gamma radiation monitors at thirteen locations throughout the controlled area of the plant.

Based on the change in R.G. 1.97, Revision 3, we believe Category 3 for this variable is acceptable.

Based on the following, we believe that the existing range of these monitors and area coverage is adequate.

a. The specified range of 0.1 to 10,000 R/hr is inappropriate at both ends of the range. One hundred (100) mR/hr is too high for many areas during normal operations, and would be too high for many accident conditions, also. Ten thousand (10,000) R/hr is many orders of magnitude higher than the level at which personnel would be allowed access. The stay time to receive an emergency exposure 100 R is less than 1 minute at this dose rate. The current installed monitor range is appropriate. Personnel would not be authorized access to any area on the basis of a radiation monitor alone, especially at dose rates higher than 10 R/hr.

Page 15 of 17

.__r.--- _ _ _ ._ _

,'
  • Comment Notes to BVPS-1 R.G. 1.97 Variable Table (cont.)
b. The critical areas in the plant where personnel go in the event of an emergency were required to be identified by NUREG-0737. In addition, affected areas are likely to be impacted by airborne activity, surface contamination, and beta radiation fields, all of which are inadequately monitored by an area radiation monitor. Thus, a health physics survey This administrative is required prior to entry into such an area.

4 requirement, documented in the Radiological Controls Manual and the Emergency Preparedness Plan, is a suitable, and perhaps more advantageous alternative to that specified in the guidance for this item.

32. Vent from S.G. Safety Relief Valves or Atmospheric Dump Valves It should be noted that this system is configured such that the monitors view dump valve and lowest setpoint safety simultaneously. The range of 0.15 to 1E4 pCi/cc is based on the fission product mix. These instruments were installed to meet NUREG-0737 requirements.

e The duration of the release is assessed for each, loop via the Steam Generator Atmospheric Dump Valves (SGADV) and the adjacent Main Steam Safety Valves (MSSV) which have the lowest lift pressure of the five MSSVs per loop. Release flow is assessed from flow transmitters on the main steamlines. Upon receipt of indication that one of the SGADVs or MSSVs are open, the ARERAS processor assigns release flow and concentration and calculates the integrated release quantity and provides a printout of the total radioactivity released.

33. Noble Gas and Vent Flow Rate - (all other identified release points).

It is noted that this monitor is for the Auxiliary Feedwater Turbine Exhaust. The range of 0.15 to 1E4 pCi/cc is based on the fission product release. This instrument was installed to meet NUREG-0737 requirements.

The processing and display of effluent release data for this effluent pathway is the same as that described above for the SGADV and MSSV monitors.

34. Radiation Exposure Meters .

This variable is not addressed herein since it is noted that R.G. 1.97, Revision 3, has deleted it.

a j 35. Plant and Environs Radiation (Portable Instrumentation) l The BVPS survey kits have E530 or similar. This instrument has a response of 0-200 mR/hr beta and photon response.

i Page 16 of 17

F

'f*

Comment Notts to BVPS-1 R.G. 1.97 Variable Tablo (cont.)

Available at the station are:

E530N 0 - 20 R/hr photon Teletector 0 - 1000 R/hr photon PIC-6A 0 - 1000 R/hr photon Cutie Pie 740F/740G 0 - 25 R/hr, 0 - 100 R/hr photon R0-2 0 - 5 R/hr - Beta / photon R0-2A 0 - 50 R/hr - Beta / photon CP-TP-10K 0 - 10,000 R/hr - Beta / photon The following is provided in consideration of range recommendation of R.G.

197.

a. The specified range of 10,000 R/hr photon or beta is far beyond what is reasonable exposure for a portable survey instrument. An individual using an instrument in such a field would receive unacceptable levels of exposure while performing the survey.
b. The 10,000 R/hr value is particularly unwarranted for environs measurements.
c. A beta field of 10,000 rads /hr is not a personnel exposure situation warranting a survey. The stay time at this dose rate to receive an exposure of 100 R is only 0.6 minutes. A photon survey on a hot piece of equipment may be warranted. This can be accomplished with the CP-TP-10K or with the Teletector. Dose-distance relationships could be used to obtain an on-scale reading which could be subsequently corrected.
36. Meteorological Parameters The meteorological parameters for BVPS conform to the guidance of R.G. 1.97 except as follows:

R.G. 1.97 recorr ends ranges for wind speed instrumentation of 0 to 67 mph and for estimation of atmospheric stability of -9 to +18 F. The BVPS instrument range for wind speed is 0 to 50 mph and estimation of atmospheric stability of -4 to +8 F (150 - 35 ft.) and -6 to +12 F (500 - 35 f t.). The instrumentation for wind speed meets the guidance of Regulatory Guide 1.23, Rev. 1. The vertical temperature ranges include the range of lapse rates (change of temperature with height) guidance of R.G. 1.23, Rev. 1, required to estimate the atmospheric stability class.

Page 17 of 17

Retrieved from "https://kanterella.com/w/index.php?title=ML20215M329&oldid=3233661"