ML20215M926
| ML20215M926 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/31/1986 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8611030476 | |
| Download: ML20215M926 (8) | |
Text
th Carolina Electric & Gas Company n.Nauan Co m a 29218 Nuclear Operations SCE8G
~,
October 31,1986 Mr. IIarold It. Denton, Director Office of Nuclear Iteactor Itegulation U.S. Nuclear llegulatory Commission Washington, DC 20555
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Itegulatory Guide 1.97 Itequest for Additional Information
Dear Mr. Denton:
Ily a letter from Mr. D. A. Nauman to Mr. II.11. Dent <m dated August 15,1986, South Carolina Electric & Gas Company (SCE&G) provided a partial response to an NltC request for additional information on Itegulatory Guide 1.97 (ItG 1.97). The purpose of this submittal is to provide the remaining information requested by the NItC that was not transmitted in the August 15,1986, letter.
Ifyou should have any further questions please advise.
ry tru yot hg i
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.,A. Nau nan AMM: DAN:bjh l
Attachments c:
O. W. Dixon, Jr./l'. C. Nichols, Jr.
K. E. NodIand E. II. Crews, J r.
- 11. A.Stough E. C. Itoberts G. O. Percival J. G. Con nelly, J r.
It. L. Prevatte W. A. Williams,Jr.
J.11. K notts, Jr.
J. Nelson Grace NPCF J
8 Grou i Managers File 00) 0.S. Iradham ph C. A. Price C.1,.1,igon ( NSitC)
- 11. M. Campbell 0611030476 061031 PDR ADOCK 05000395 P
F A'ITACHMENT PAGE10F7 3.0 RCS Soluble Boron Concentration Range 0-3000 ppm Environmental Qualification None Seismic No
- of Channels One Control RoomIndication Device Digital Meter Pcwer Supply Non IE EOFffSC Indication No SCE&G takes exception to the range requirement for RCS soluble boron concentration. The range ofour existing instrumentation envelopes the RCS/ Boron Injection System design parameters for all design basis events.
Back-up indication can be provided by RCS Sample Analysis utilizing the Post Accident Sampling System.
5.0 Condenser Air Removal System Exhaust SCE&G takes the "not required" position for this variable as allowed in RG 1.97 Rev 3. The design at Virgil C. Summer Nuclear Station discharges the effluent from the Condenser Air Removal System to the common plant vent.
However, the Station does maintain a radiation monitor on the Condenser Air Removal System Exhaust.
G.0 Effluent Radioactivity - Noble Gases I,ow/ Narrow Range - RMA-3 4.0 x 10 6 uCi/cc to 2.0 x 10 2 uCi/cc High/ Wide Range - RMA 13 - 8.0 x 10-3 uCi/cc to.86 x 103 uCi/cc Vent Design Flow 228 kCFM Instrument Range 35 - 350 kCFM Environmental Qualification No Seismic No
- of Channels One per Instrument Control Room Indication Device Analo g Meter, Chart Recorder Power Supply Non 13, Diesel Backed EOF /fSC Indication Yes / Yes SCE&G takes exception to the following requirements for this variable.
I.
Radioactivity Ha,1ge The present instruments cover 86% of the required range and exceed anticipated levels of all Design Basis Events, thus the intent of RG 1.97 !s met.
II. Vent Flow Rate The installed instrument covers 15 - 150% of Design flow and meets the intent of RG 1.07.
l III. Qualification -Instrument qualification upgrade is not required based on the following:
i a) The Plant Vent System is non safety non seismic. Category 2 instrumentation does not require seismic qualification unless it is safety.related.
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A'ITACHMENT PAGE2OF7 b) The instruments are located in a mild environment and are not subject to a HELB.
c)
Portable instruments and on site analysis serve as adequate back-up.
8.0 AccumulatorIsolation Valve Position Range Open/Not Open, Closed / Not Closed Indication Environmental Qualification Yes Seismic Yes
- ofChannels One perIndication Control RoomIndication Device Monitorlight(Closed /Not Closed)
Alarm - Not Full Open Power Supply 1E EOF /I'SC Indication Yes/ Yes 9.0 Boric Acid Charging Flow SCE&G takes exception to this variable. The Virgil C. Summer Nuclear Station does not utilize " Boric Acid Charqing" as part of the Safety Injection System design. The principal mechanica. components of the Emergency 1
Core Coolin System (Safety Injection Flow) which provide core cooling t
immediatel following a loss of coolant accident are the accumulators, the centrifugal harging pumps (see Note), and the residual heat removal pumps (RIIR).
NOTE: The centrifugal chargingpumps (or Safety, Injection Pumps) are i
commonly referred to as high head pumps and the RIIR pumps as
" low head pumps".
10.0 Flow in High Pressure Injection System - SI Flow Range 01000 gpm or 0 400% of Normal Operation Max Flow (Normal flow 250 g 0150% Max Operation (hm),
ump runout 650 gpm)
Environmental Qualification Yes Seismic Yes
- ofChannels 2 (1 per line]
Control Room Indication Device 2 analog meters Power Suppiv Non IE EOF /fSC Inilcation Yes/ Yes 11.0 Reactor Coolant Pump Status - Motor Current Ranze 0 800 amps Eny ronmental Qualification None l
Seismic Indicator Only
- ofChannels One per pump Control Room Indication Device Analo t Meter Power Supply Non 13
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l A'ITACHMENT PAGE3OF7 EOF /TSC Indication No 12.0 Pressurizer Heater Status - SCE&G takes exception to the environmental qualification requirement for this variable be--d on the following:
s, A. All associated instruments for this variable are located in mild environments and would not experience harsh environments during accident or post accident periods. Since present equipment has a long history of reliability under normal environmental conditions, replacement with environmentally qualified instruments (tested and documented) would not provide a significantly higher level of reliability over the presentinstruments.
B.
Diverse indication of Pressurizer limater Status can be provided using a combination of Pressurizer Heater Breaker position and Pressurizer Pressure.
13.0 Quench Tank Level (Pressurizer Relief Tank Level)
Range 4-104" Represents 97% ofTank Volume Env. ronmental Qualification None Seismic No
- ofChannels One Control RoomIndication Device Meter Power Supply Non 1E EOF /TSC Indication Yes/ Yes 14.0 Quench Tank Temperature Range 50 - 350*F Environmental Qualification None Seismic No
- of Channels One Control Room Indication Device Meter Power Supply Non IE EOF /TSC Indication Yes/ Yes SCE&G takes exception to the range requirement based on the following.
The quench tank design pressure is 100 psi at which point the ru sture discs will activate and provide relief to the containment atmosphere. Cherefore, an relief from the pressurizer safety valves will be maintained below 100 ps g. The saturation temperature at 100 psigis approximately 275'F and the ex sting 50 350'F range is adequate to monitor any expected conditions in the tank.
15.0 Quench Tank Pressure Range 0120 psig Environmental Qualification None Seismic No
- of Channels One Control Room Indication Device Meter Power Supply Non IE EOF /TSC Indication Yes / Yes Tank Design Pressure 100 psig
ATTACHMENT PAGE4OF7 17.0 Heat Removal by Containment Fan Heat Removal System SCE&G provided part of the requested information in our submittal dated, April 15,1985. Please reference Table 1-1, page 1 11 under variable " Fan Cooler Motor Specd". Please note the following correction. The " Power Supply" for this indication is 1E power.
In addition the following instruments are available to quantify the heat removal rate.
Service Water Booster Pump FT 4466 & FT4496 Discharge Flow Range 0 - 120% Flow Environmental Qualification Yes Seismic Yes
- ofChannels One per train Control RoomIndication Device Analog meter Power Supply 1E, Diesel Backed EOFfrSC Indication Yes/ Yes Reactor Building Cooling Unit AT (Differential Temperatures)
Instrument # ITE 4497,4467(DischargeTemp)
ITE 4480,4510 (Intake Temp)
Range 50 - 350*F Environmental Qualification Yes Seismic Yes
- ofChannels One per train Control Room Indication Device Computer Power Supply 1E, Diesel Backed EOFfrSC Indication Yes/ Yes 18.0 Containment Atmosphere Temperature Range 50 - 350*F Environmental Qualification Yes Seismic Yes
- of Channels 2 Channels in Control Room,1 of 2 Channels on CREP Control Room Indication Device 2 Meters,1 Chart Recorder Power Supply 1E EOFfrSC Indication Yes / Yes 19.0 Containment Sump WaterTemperature Range 50-350 F Environmental Qualification No Seismic No
- of Channels 2
Control Room Indication Device TSC Computer, Indicator Power Supply 1E EOFfrSC Indication Yes / Yes
ATTACHMENT PAGE5OF7 SCE&G takes exce ation to the g ualification requirements. Suitable back-up indication is provi(ed by the RElR Pump Suction Temperature monitors.
These instruments are not subject to harsh environments.
20.0 High Level Radioactive Liquid Tank Level Range 29"- 169"in we Environmental Qualification No Seismic Yes
- ofChannels 1
Control RoomIndication TSC Computer Power Supply Non IE EOF /fSC Indication Yes/ Yes SCE&G takes exception to the range requirement of RG 1.97 for this variable. The present instrumentation measures the upper 88% of the tank and is sufficient to provide the operator with the necessary information for accident monitoring and meets the intent of RG-1.97.
21.0 Radioactive Gas Holdup Tank Pressure Tank Design Pressure 100 psig Instrument Range 0 - 150 psig Environmental Qualification None Seismic No
- of Channels One per tank Location of Display Remote Panel 22.0 Emergency Ventilation Damper Position Range Open/Not Open, Closed /Not Closed Indication Environmental Qualification Yes Seismic Yes
- ofChannels One per valve position Location of Display Control Room l
Type of Display Indication Lights Power Supply 1E EOF /fSC Yes / Yes l
23.0 Vent from Steam Generator Safety Relief Valves or Atmospheric Dump Valves Virgil C. Summer Nuclear Station will use the following instrumentation to meet this requirement:
i
- 1) Steamline Radiation Monitors (see original submittal dated 4/15/85, page 1-6)
- 2) Narrow Range and Wide Range Steam Flow Instrumentation
- 3) Steamline Isolation Valve position indiction
ATTACHMENT PAGE6OF7 SCE&G takes exception to the qualification requirements for the Steamline Radiation Monitors. Steam Generator Blowdown sample analysis serves as a suitable backup and verification to the steamline monitors.
NOTE: An error has been identified in the April 15,1985, submittal on Table 1-1, page 1-6 under the variable "Steamline Radiation". The qualification categories should be corrected to read.
Environmental Qualification No Seismic No(Detactor andIndicator are seismically mounted) 24.0 Airborne Radiohalogens and Particulates Required 10-9 uCi/cc to 10-3 uCi/cc (Portable Air Sompling Equipment) i Range Gross levels of 10-9 uCi/cc with sufTicient air sample volume. For smaller air sample volume 10-3 uCi/cc is obtainable.
i 25.0 Plant and Environs Radiation (Portable Instrumentation)
Requirement 10-3 to 10 +4 Rad /hr for beta & low energy photons Range 0-200 R/hr 0-20,000 R/hr for photons and beta radiation The existing range is adequate for Virgil C. Summer Nuclear Station plant and environs radiation monitoring. These instruments meet the intent of RG 1.97.
26.0 Plant and Environs Radioactivity (Portable Instrumentation)
Isotopic Analysis Required Position - SCE&G does not have the capability to send a multi-channel gamma ray spectrometer into the field and perform Isotopic analysis. IIowever,several non portable multi-channel analyzers (MCA) equipped with (Ge(Li)) detectors are located in the station counting room and at the Radiological Environmental Monitoring Laboratory located within the two mile radius of the Virgil C. Summer Nuclear Station. SCE&G does not believe portable multi-channel gamma-ray spectrometers would enhance the existing monitoring program due to the inherent problems in a portable system of decreased sensitivity, increased noi; e and interference, and reduced reliability. This departure from RG 1.97 recommendations is considered to be acceptable.
31.0 Containment Air Sampling Capability (Grab Sample)
IIydrogen Content 010% by Volume Oxygen Content No Capability Gamma Spectrum Isotopic Analysis i
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ATTACHMENT PAGE7OF7 SCE&G takes exception to the Oxygen content analysis requirement based on the following:
a) " Oxygen Concentration" does not serve a safety related function and quantification would not serve a useful purpose for accident analysis, mitigation or recovery.
l b) The Design Basis for Combustible Gas Control in the Reactor Building shall maintain safe hydrogen concentrations. Use of the Electric Hydrogen Recombiners is such that the Reactor Building hydrogen concentration will not exceed (4) four volume percent based on t2e NRC TID-14844 release model as indicated in RG 1.7. Since an uncontrolled hydrogen burn is not postulated as a post accident event, oxygen concentration can be determined from pre-accident levels plus known hydrogen concentration levels.
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