ML17261B088

Provides Update to Util 860616 Ltr Re Implementation of NUREG-0737,Item 6.2,Suppl 1, Emergency Response Capability.

ML17261B088
Person / Time
Site:	Ginna
Issue date:	07/13/1990
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 9007170242
Download: ML17261B088 (61)

Text

AC( ELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9007170242 DOC.DATE: 90/07/13 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MECREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.R. Project Directorate I-3

SUBJECT:

Provides update to util 860616 ltr re implementation of NUREG-0737,Item 6.2,Suppl 1, "ERC."

DISTRIBUTION CODE: A003D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR/Licensing Submittal: Suppl 1 to NUREG-0737(Ge eric Ltr 82-33)

NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-3 LA 1 1 PD1-3 PD 7 7 JOHNSON,A 1 1 INTERNAL: NRR/DLPQ/AHFB11 1 1 OC/LFMB 1 0

~REGS-I LE=~OgP 1 1 RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 Ptl~n R vi;E NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 16 ENCL 15

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• SZt II Zuzzcim ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649.0001 ZZ TELEPHONE AREA CODE 7ld 546-2700 July 13, 1990 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Allen R. Johnson Project Directorate I-3 Washington, D.C. 20555

Subject:

Regulatory Guide 1.97 Conformance Emergency Response Capability TAC No. 51093 R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Johnson:

The purpose of this submittal is to provide an update to RG&E's June 16, 1986 submittal concerning RG&E's implementation of NUREG-0737 item 6.2 Supplement 1, Emergency Response Capability, concerning Reg. Guide 1.97 documentation. It update of information, and a response to the nine issues listed in includes both an the NRC's February 20, 1990 correspondence. Rochester Gas and Electric has prepared a technical response for each of the nine topics and has retained the report format used in our previous correspondence. Attachment A provides the additional information pertaining to the NRC's requests on the open issues. Attachment B provides a completed tabulation matrix concerning RG&E's Reg. Guide 1.97 position.

RG&E technical responses to the identified issues provides data to resolve the issue directly for most open items. However, in some identified instances, exception is taken to the subject guidance topics based upon technical justification. The major issues which involve exception statements include neutron flux monitoring, containment isolati'on valve position indication, radioactivity concentration or radiation level in circulating primary coolant, and containment spray flow monitoring. RG&E is actively pursuing the neutron flux topic in cooperation with two other nuclear utilities (Westinghouse PWRs) to review and document the use of other existing qualified plant instrumentation and emergency operations procedural approaches to ascertain and maintain reactor subcriticality status during harsh containment environment circumstances.

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RG&E will support engineering discussions leading to the resolution of any open issues.

Very truly yours, Robert C. Mecredy Division Manager Nuclear Production'KMK103 Attachments xc: Allen R. Johnson (Mail Stop 14D1)

Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

ATTACHMENT A REGULATORY -GUIDE 1. 97 REVIEW The responses below are ordered to be consistent with the USNRC correspondence concerning emergency response capabilities, dated February 20, 1990. Previously assigned paragraph numbers contained in the EGGG report, "Conformance to Regulatory Guide 1.97, R.E.

Ginna Nuclear Power Plant", attached to the April 14, 1986 NRC letter have been referenced in this Attachment A. Attachment B has been organized, expanded and annotated.

1 3.1 ADHERENCE TO REGULATORY GUIDE 1.97 RGGE has previously provided specific completion and exception status for compliance with Section 6.2 of NUREG-0737, Supplement 1 concerning emergency response capability. The RGGE letters of February 28, 1985 and June 16, 1986 furnished Reg. Guide 1.97 equipment qualification status information data. Completion dates for near-term future modifications are identified later in this response. Completion dates for Regulatory Guide 1.97 modifications not previously committed to, or for which agreement has not been reached between RG&E and the NRC, will be established, as necessary, with the NRC Project Manager.

Table 1 of Regulatory Guide 1.97 specifies that Category 1 and 2 items should be environmentally qualified to Regulatory Guide 1..89 and NUREG-0588. Subsequent to that time, 10CFR50.49 requirements involving "Environmental Qualification of Electrical Equipment...", was implemented at Ginna Station with an effective date of November 30, 1985. This 10CFR50.49 regulation defines the evaluation process required to identify post-accident monitoring equipment which should be environmentally qualified. Equipment which performs critical safety functions includes those items of electrical equipment required to ensure (i) the integrity of the reactor coolant pressure boundary, (ii) the capability to shut down the reactor and maintain it in a safe shutdown condition, and (iii) the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the'10CFR100 guidelines. 10CFR50.49 also specifies that non safety-related equipment which could cause failure of the above equipment, and certain post-accident monitoring equipment, should be environmentally qualified. RGGE considers that 10CFR50.49 is the appropriate vehicle for defining the scope of instrumentation which meets these three categories. Environmental qualification program determinations are provided in RGGE's 10CFR50.49 compliance documentation, rather than in the submittals associated with NUREG-0737 and Regulatory Guide 1.97.RGGE has reviewed the Ginna Station Emergency Operating Procedures and UFSAR Chapter 15 concerning plant design basis events-to determine which instrumentation is used to provide information to the operator which may affect

his ac ns. Any installed instr ntation required to perform a safety-related function and that is required to operate during and following an accident resulting in a harsh environment, has been included in the scope of RG&E 10CFR50.49 Environmental Qualification Program.

Instrumentation not meeting this criteria, although designated in Regulatory Guide 1.97 Table 3 to require environmental qualification (by virtue of being classified as Category 2) may not be so designated for RG&E's 10CFR50.49 program. The rationale for Regulatory Guide 1.97 Category 2 instrumentation assignments is explicitly provided in Section 3.3 of this Attachment and in the Attachment B tables.

'2 3.2 TYPE A -VARIABLES RG&E has completed its review of Type A variables, and.

included them in the modified. "USNRC Reg. Guide 1.97 Revision 3 Comparison Table" (Attachment B). All type A variables are considered Category 1, unless specific exceptions are taken.

The sodium hydroxide tank level instrumentation was

,evaluated with regard to Emergency Operating Procedures and use of the Containment Spray System during harsh environment conditions. RG&E has concluded that the sodium hydroxide (NaOH) level transmitters do not require upgrading to a Category 1 Type A variable based on Safety Evaluation NSL 0000 009 October 25, 1989, which provided an evaluation of spray chemistry requirements, possible boron dilution phenomena, and sump pH requirements during postulated sump recirculation modes. The Emergency Operating Procedures (EOPs) do not require any operator attention or response related to NaOH tank level conditions in the revised procedural documents issued July 21, 1989, (these were reviewed by the NRC EOP

~ inspection (89-80) with no open issues identified).

This evaluation response completes the June 16, 1986 letter (Topic 3. 2) commitment to determine if NaOH tank level transmitters should be replaced with 10CFR50.49 qualified transmitters.

Based on recent RG&E review, additional instrumentation will be categorized as Type A measurement variables.

These include two redundant sets of Steam Generator wide range level transmitters. The future transmitter installations will become operational when the new Advanced Digital Feedwater Control System (ADFCS) is operational (1991 tentative schedule). These instruments will meet Category 1 requirements. RG&E is planning to upgrade the Containment Temperature Monitors to Category

2. RG&E plans to provide one additional Category 1 Residual Heat Removal System Flow Transmitter to provide redundancy for FT-626.

0 I

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Neutron Flux Detection Existing RG&E excore Nuclear Instrument System (NIS) neutron flux detection equipment that monitors source range (SRM), intermediate range (IRM) and power range (PRM) reactor flux conditions, is Westinghouse furnished original plant electrical equipment whose specifications predate the Emergency Response Capability regulatory activities. Regulatory Guide 1.97 Table 3 guidance notes the neutron flux detection equipment as Type B measurement variables with Category 1 attributes.

RG&E review of neutron flux monitor functions presents no reasons for these devices to be Category 1 at Ginna Station, and intends to take exception to the Regulatory Guide 1.97 guidance since the existing Category 3 equipment is suitable to perform all its necessary functions.

RG&E has reviewed the Ginna Station UFSAR Chapter 15 accident analyses, as well as the Emergency Operating Procedures (EOPs), to determine the requirements for use of the NIS PRM, SRM, and/or IRM instrumentation during environmentally harsh design basis accident scenarios.

No automatic or manual operator actions required for accident mitigation are described for any Chapter 15 events which require excore NIS operation during or after the onset of a "harsh" environment per 10CFR50.49.

The Ginna Station EOP series E (Emergency), ES (Emergency Supplement), and ECA (Emergency Contingency Action) do not take credit for the source, intermediate'r power range neutron, flux monitors to peiform any required safety functions, and are thus not considered a Type A variable. These instruments do not meet RG&E's criteria for inclusion in our 10CFR50.49 Equipment Qualification Program.

RG&E's FR (Functional Restoration) procedures, as well as the Critical Safety Function Status Tree (CSFST Red Path) do utilize the excore NIS displays as an indication of reactivity conditions. The FR 'and ECA procedures are beyond design basis events, where all potentially available equipment is used to mitigate events and sets of events beyond the licensed capability of Ginna Station (e.g., dual steam line breaks, Steam Generator Tube Rupture with Steam Line Break, etc.). It is not RG&E's intent to replace equipment considered potentially useful for beyond-design-basis-event situations, unless this is considered warranted as a part of RG&E's Severe Accident Management strategy. The Severe Accident Management strategy will be developed within the context of our current Probabilistic Risk Assessment/Individual Plant Examination (PRA/IPE) process.

The excore NIS is also used in attachments to the Emergency Procedures as the Red Path CSFST F-01 reactor subcriticality determination devices. No discrete

action ther than reactivity moni 'ng are accomplished by the instruments. The underlying accident scenarios already make use of all potential sources of reactivity control (drop control rods, inject boric acid) and no actions within the Ginna Station design basis are necessary ,for more reactivity control than already provided by automatically actuated systems. 'gain, the comments above regarding Severe Accident Management apply.

RG&E does agree that some potential operator confusion could arise over the use of the CSFST Red Path, SRMs failed high-scale due to the harsh environment.

if the Although automatic safety systems 'would maintain all required safety functions, operator concern could arise.

RG&E therefore proposes to modify the CSFST Red Path, to make use of instrumentation which is already Class 1E and incorporated into RG&E's 10CFR50.49 Equipment Qualifica-tion Program to provide a better indication of beyond design basis conditions than the excore NIS. This requires the use of the core exit thermocouples (CETs),

in combination with the Reactor Vessel Level Indicating System (RVLIS). This would be supplemented with additional Boron analysis requirements by use of the Post Accident Sampling System (PASS) to determine shutdown margin.

EOP instructions presently require Operators to observe Core Exit Thermocouples (CETs). Because of the multiplicity (39) and the reactor locations of the CETs Operators may (in a situation clearly beyond the licensing requirements'for Ginna Station) locate core hot spots which. could. be indicative of added: heat flux. due, for example, to a loss of subcriticality at a specific location(s) in the reactor core. Such operator CET observations after emergency reactor shutdown would result in procedurally required borated water additions to add negative reactivity thus assuring shutdown margin (SDM) adequacy as well as assuring core cooling. During design basis accidents, while core conditions are being evaluated and while Safety Injection Pump(s) are being operated, the CET temperature displays will be consulted by the operators to determine the interval periods when SI pumps may be turned off based upon stable core temperature indications.

The EOPs require SDM determinations which involve PASS Boron analysis techniques. Excess Boron concentration above the conservative minimum requirement (in ppm) provides the objective measurement basis that the core is shut down and remains subcritical.

The RG&E Ginna Tech. Specs. require a minimum of four active CETs per reactor core quadrant during plant operations.

The p ding excore NIS discuss linked with other core criticality/SDM measurement techniques is being further investigated by RGGE and two other Westinghouse PWR nuclear utilities. Assessment of the use of CETs and RVLIS as alternative measurement means, and EOP procedural upgrades, are underway.

~

Containment Isolation Valve Position~ =Indication A detailed RG&E review of the UFSAR Chapter 6 (Engineered Safety Features; Subsection 6.2 Containment Systems) discloses that the containment mechanical boundaries are protected by piping and valve configuration designs which provide defense-in-depth. System design considerations include redundancy provisions (valving or closed IST and Appendix J piping systems), functional operability testing, and seismic and missile protection.

In RG&E's correspondence with the NRC relative to Environmental Qualification and USNRC IE Bulletin 78-04, it has been noted that failure of any externally valve position indication switch would have no adverse mounted effect on the isolation capability of any containment valve based on the control circuit design. The valve stem position switches mounted on air operated valves are utilized only for indication purposes and are not incorporated in any control logic schemes.

Motor Operated Valves (MOVs) have integral limit/torque switch compartments adjacent to the motor and gearing attached to the process valve. The valve open or close cycle is operated from a remote location and relies upon control commands while providing valve position indication at the plant operators control location. The motor operated valves do require wiring intraconnections within the integral switch compartment torque and position sensing devices. The control logic cross-connected wiring within the Limitorque compartment has been replaced with environmentally qualified conductors.

during specific surveillance and valve refurbishment and upgrade efforts associated with the MOVATS program.

MOVATS testing and surveillance programmatic maintenance is scheduled for motor operated valves whether or not they are included in the 10CFR50.49 environmental qualification program (safety-related and in a harsh environment), or if the valve has been identified as being located in a mild environment, or not required to operate during a DBA.

Isolation boundaries IJ Motor Operated Valves at Containment (and other MOV locations) identified in the Plant Technical Specifications Table 3.6-1 provide closed/not-closed indicator light displays in the control room. The MOVATs testing and valve rework efforts assure that the valves function correctly, and that limit switch operated displays are correct. Containment Isolation MOVs remain in a committed long term surveillance program.

Regulatory Guide 1.97 Table 3, Type B variables, notes that a Category 1 assignment exists for Containment Isolation Valve position indication (closed/not-closed).

Rochester Gas and Electric requests that an exemption be granted. from guidance on environmental 'qualification topics associated with the individual valve position switches located in potentially harsh locations. RG&E

has ve+ied (as documented in SEIepic VI-4) that, in accordance with the licensing requirements for Ginna Station, proper containment isolation will occur even assuming a worst-case single failure.

Emergency Operating Procedures do not require Operations personnel to take any immediate actions based solely on the open or closed valve position indication during a design basis accident. Although EOPs do specify that the operator verify containment isolation valve position, failure of position indication will not cause loss of any safety function, or incorrect and unsafe operator actions.

In the EOPs, if a valve indicates open (whether open or closed) the operator is directed to close the valve.

Failure .of the valve position indication does not prevent motion of the valve itself. It is not expected that the operator would manually attempt to position a valve located in a "harsh" environment. If a valve indicates closed (whether it is open or closed) the operator will not attempt to manipulate the valve (and certainly, not to open it). Thus, adequate containment isolation is ensured by the defense-in-depth provision built into the system, rather than by valve position indication.

Therefore, RGGE has chosen not to designate valve position indication for containment isolation valves as a Type A, Category 1 variable.

Pressurizer Heater Status (Electric Current Indication)

Pressurizer (PZR) heater electric current draw status is a Regulatory Guide 1.97 Category 2, Type D variable. At Ginna there are two diverse PZR heater groups operated.

from the main control room benchboard location. A handswitch and illuminated status lights are provided for each of the two heater groups. The Plant Operations Group presently relies upon and observes either the Bus 14 kilowatt (KW) power draw meter readouts or the Bus 16

~

kilowatt (KW) meter readouts in the control room to determine that either of the PZR heater banks are drawing power whenever control bank handswitch or backup bank handswitch is operated. An electrical load as large as either 400 KW PZR heater bank is readily quantified and observed whenever the bank is on (or off). If the 400 KW backup bank is required to be on, the incremental load increase is noted on the Bus KW meter. Operator decisions concerning emergency diesel generator loading conditions may be made upon KW,display information.

The control bank heater group provides modulating proportional heater control from its Silicon Controlled Rectifier (SCR) control cabinet in the Auxiliary Building. The SCR panel at the intermediate level (East) is internally equipped with current transformers (CTs) and provides local panel ammeter monitoring each of three incoming 480 Volt Bus 14 phase lines.

RG&E has evaluated the Category 2, Type D Regulatory Guide 1.97 recommendation to monitor electric current draw. The control bank equipped with diverse at the remote panel location, plus a controlammeters'ndications room status light display with its associated handswitch and its analog controller on the benchboard is judged to be in compliance with the intent of the Guide.'he Bus 14 KW meter is also available in the control room to indicate power draw conditions imposed by the control bank of PZR heaters. Since these heater controls and motor control center are located in environmentally mild plant locations, they are not included in Ginna's 10CFR50.49 program.

The second heater group is identified as the backup heater bank which draws its power from 480 Volt Bus 16 and performs as an on/off group. This backup bank can be handswitch operated from the control room or a remote shutdown panel location. No local CTs or ammeters are provided for the backup heater circuitry.

The backup heater bank equipped with a control room status light display with its benchboard handswitch, plus the remote location handswitch and its status light display, working in conjunction with the Bus 16 KW metering MCR display is judged to also be in compliance with the intent of Regulatory Guide 1.97. The Category

2 con ls and motor control c er are located in environmentally mild locations so the equipment is not included in Ginna's 10CFR50.49 Program.

The key measurement variables which monitor the pressure/temperature effect produced by the pressurizer heater bank actuation(s) are the pressurizer and RCS pressure transmitters which monitor primary coolant pressure, and the pressurizer level transmitters which monitor water level. These environmentally qualified Category 1, Type A transmitters are incorporated into the 10CFR50.49 program.

10

Pressurizer Relief ( ench) Tank (PRT) Tem erature The quench tank temperature is monitored by the TE-439 loop and is presently scaled to indicate 0 to 300 F The Regulatory Guide 1.97 recommendation notes a temperature range of 50 to 750 F. The physical configuration of the tank includes a rupture disk with a 100 psig setpoint. For saturated steam conditions, the corresponding maximum temperature expected within the tank would be 338 F. The rupture disk is designed. to burst open if Pressurizer Safety Valves or Power Relief Valves (PSV or PORV) discharge fluids > 100 psig Operated into the quench tank.

PORV and block valve position status and pressurizer safety valve position indications are available on the control room panelboard to detect whether RCS fluids are establishing a flow path to the PRT. These are environmentally qualified position sensing instrumentation devices provided to detect safety or relief actuations.

RG&E has evaluated the PRT tank parameters and consequently proposes to rescale the TE-439 loop to the recommended 50 to 400 F range which conservatively envelops the postulated ,338 setpoint. RG&E has initiated an Engineering Work Request to complete this instrument rescaling effort.

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Steam Generator Wide Ran e Level

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Transmitter Ginna Station is presently equipped with one wide range level plus three n'arrow range level transmitters for each steam generator. The wide range transmitters monitor steam generator level from tubesheet to separators (0" to 520" H 0), and provide data to the Safety Assessment System (SAS) computer and to a permanent recorder/display on the'ain control panel. Existing Ginna Emergency Operating Procedures (EOPs) do not require any Operator action or decisions during design basis accidents involving containment harsh atmosphere conditions, based on SG wide range level instrumentation. Existing wide range level transmitters LT-460 and LT-470 ~ have been regarded to be as Category 2, Type D measurement variables. This decision to base EOP Operator actions on-other level transmitter displays results from original Westinghouse design philosophy which involves qualified Category 1, Type A narrow range steam generator level transmitters which provide Class 1E control and display functions. The steam generator narrow range level transmitters interact with reactor protection and control systems, provide main control board level indication and provide data to the SAS.

Rochester Gas and Electric plans to replace the existing analog feedwater control syst'm with an Advanced Digital Feedwater Control System (ADFCS) currently'scheduled for installation during the 1991 Refueling Outage.

Environmentally qualified steam generator wide range level transmitters conforming with 10CFR50.49 and the guidance language stated in Regulatory Guide 1.97 will be installed at that time. Two redundant transmitters monitoring level between tubesheet up to separators will be furnished for each steam generator. The wide range transmitters will be treated as Category 1, Type A equipment upon completion of that modification. When redundant wide range level for each SG is incorporated on a Type A variable, the fully qualified, redundant Class 1E transmitters, LT-461, LT-462, LT-463< and LT-471, LT-472, LT-473< ~ > will be considered for deletion as a Type A variable. No changes in form or function for these six level transmitters will be undertaken.

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8 3.3.14

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Containment S ra Flow ~

(Providing a Flow Indication Capability)

There are no Containment Spray (CS) flow indications or transmitters provided for the two CS pumps'. There are no required Operator actions or decisions based upon CS pump flow parameters dictated by the Emergency Operating

-Procedures. CS pump operating status during normal plant operations or following a safety injection signal can be determined from the main control board switch position and illuminated displays. The containment spray pumping system components and Class 1E electrical systems are single failure proof.

The Emergency Operating Procedures requirements make no mention of CS flowrate measurements. CS pump operation is dependent upon environmentally qualified containment pressure transmitter signals which provide containment isolation signals and pump actuation commands containment conditions above setpoint are detected.

if adverse Containment pressure is the selected Category 1, Type A measurement variable to determine the containment spray pump operation and containment environments pressure reduction effectiveness. EOPs require the Operator to make decisions'ased upon Containment pressure to maintain pumping, restart pump(s) after sump recirculation switchover or to secure pump operations during design basis accident conditions.

Although there is no requirement to do so, indirect determinations of Containment spray flowrate can be calculated after the containment spray system pump suction switchover from the Refueling Water Storage Tank (RWST) to the containment sump recirculation water source has been initiated. The determination may be made from Category 1, Type A flowrate instrumentation which is monitoring the Residual Heat Removal (RHR) recirculation pumping operation (FT-626). A portion of the available RHR flow (monitored by Category 1, Type A transmitters FT-931A, FT-931B) is split between the containment spray pumps (no flow metering) and the Safety Injection (SI) pumps (monitored by Category 1, Type A transmitters FT-

~ in flowrate 924, FT-925). The subtracted difference split between the RHR and the SI pumps is the net flow directed to the CS pumps. Sufficient indirect CS flowrate information is, therefore available to the Operations staff if the data is requested. There is no EOP requirement to monitor Sodium Hydroxide tank level during a DBA which involves a containment spray pumping occurrence (see Topic 2).

NOTE 1: [FT-931A + FT-931B] [FT-924 + FT-925]

Containment Spray Pump(s) Flow in gallons per minute 13

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Com 0

onent Coolin Water to En ineered Safe ards Features (Flow Measurement)

RG&E provides redundant single failure proof Component Cooling Water (CCW) pumps. CCW pump on-auto-off control and illuminated status indication is provided on the main control board. Category 2, Type D pump pressure control and alarm as well as CCW surge tank level control room alarm and monitoring instruments are installed to monitor system operation. CCW system flow and temperature are locally monitored and are alarmed in the main control room. The CCW instrumentation is located in environmentally mild locations in the Auxiliary Building.

The CCW Category 2, Type D measurement instrumentation has not been included in the Ginna EQ program for that reason.

Local rotameter indicating switch flow instrumentation to bearing and/or pump seal coolers (with main control room flow alarm provisions) is located near each of the combined CCW discharge outlets from the two RHR, the two CS and the three Sl Emergency Safety Features (ESF) pumps. The local rotameter indicating switches facilitate system coolant flowrate adjustments for administratively controlled CCW to ESF pumps. Thus, substantial process information exists to monitor and verify operability of the prealigned and adjusted CCW system.

The CCW system is administratively controlled and process flow destinations procedurally aligned during all plant operating conditions to provide cooling water flow to the ESF pumps. The Emergency Operating Procedures do not require process valve manipulations, instrument realignments or system monitoring during a design basis accident. The combination of the CCW system single failure proof design and administrative control over cooling syst: em valving alignments ensure that, even assuming a worst-case single failure, no loss of required safety function can occur to more than one train.

Therefore, RG&E considers that the existing Category 2, Type D instrumentation presently installed in the process area and control room that provides indication or alarm instrumentation to be justified as configured.

it is presently 14

ATTACHMENT B USNRC REGULATORY GUIDE 1.97, REVISION 3 INSTRUMENTATION COMPARISON TABLE WITH NOTE/SECTION Rochester Gas and Electric Corporation R. E. Ginna Nuclear Power Plant Docket No. 50-244 ISSUE: DATES Original February 25, 1985 Second June 16, 1986 Third July 12, 1990

C, SI APj:RYURE Page 1 of 19.

CARD ROCHESTER GAS AND ELECTRIC CORPORATION USNRC REGULATORy GUIDE 1.97 REVISION 3 COMPARISON TABLE NOTE 1 Also Available On Aperture Card REACTIVITY CONTROL Neutron Flux 10 'o 100% power Source, Intermediate and Power Range Are Not Environmentally Qualified to Category See Attachment Item 3.3.1 A

1

~ 1.0E-l

~ 1.0E-11 to 1.0E06 cps/n/cm'RM to 1.0E-3 Amps/n/cmo/sec IRM PWR Owners Group Formulated to Evaluate Plant

~ 1.7E-6 to 4.25 Amps/section PRM Equipment Control Rod Position Full In oz Not Full In (Microprocessor N/A MRPI Rod Position Indicator) System Replaced Original Plant Equipment. Category 3 MRPI Digital System was Placed In-Service During 1987 RCS Soluble Boron Concentration 0-6000 ppm Available on PASS Boron Analyzer 15 Former Item 3.3.2 (Range: 50150 to 6000~300 ppm)

RCS Cold Leg Water Temperatuze 50 700oF TE-409B-1 and TE-410B-1 (one per loop) N/A (Type A) (Range: 0-700'F) 17

[EQ Program]

CORE COOLXNG RCS Hot Leg Water Temperature 50 700oF 1 TE-409A-1 and TE-410A-1 (one pez loop) 18 N/A (Type A)

(

(Range: 0-700'F)

[EQ Program)

RCS Pressuze 0-3000 psig PT-420A, PT-420 N/A (Type A) (Range: 0-3000 psig)

[EQ Program)

RCS Pressurizer Pressure Plant-Specific PT-429, PT-430, PT-431, PT-449 N/A (Type A) (Range: 1700 to 2500 psig)

[EQ Program)

Core Exit Temperature 200 2300oF Incore Core Exit Thezmocouples [CET) with 19 Former Item 3.3.3 (Type A) Connectors and Regulatory (Range: 0 to 2300'F) Guide 1.97 Rev. 3

[EQ Program) Table 3, Note 3 yoo7]7o~<> ~I

I L

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t Page 2 of 1R Coolant Inventory Level in Reactor Bottom of Hot Leg to Top Reactor Vessel Level Indicating System (RVLIS) -16 N/A (Type A) of Vessel Calculations Involve Combinations of Differential Pressure (Flow, Level) plus CET and RCS Loop Temperature Transmitter Signals that Monitor Bottom of Vessel to Top of Vessel

[EQ Program]

Degrees of Subcooling 200'F Subcooling to 35'F 2 19 Former Item 3.3.3 (Type A) Superheat EOP Requirement Utilizes Category 1 Core Exit Thermocouples and RCS Pressure Instrumentation Displays Linked with a Subcooled/Superheat Nomogram to Ascertain Wide Range Primary Coolant Fluid Conditions Greater Than 200'F Subcooled Through 35'F Superheat

[EQ Program)

Hot Leg RTD Plus RCS Pressure Analog Signal 18 Computation Produces Redundant 0 to 100 F 19 Subcooled Category 1 Data and Diverse Information Displays

[EQ Program) 5 Core Exit Thermocouples Plus RCS Pressure; Diverse Isolated Analog/Digital Data in the Plant Process Computer System Generates >200'F Subcooled Through >35'F Superheat Demand Display Data for Safety Assessment [Category

3) System Displays MAINTAININGREACTOR COOLANT SYSTEM ZNTEGRZTY Containment Sump: Wide Range Water Level PLant-Specific Sump B: LC-942 (A-E) and LC-943 (A-E) N/A (Type A) Indication of 8, 78, 113, 180, 214 inches (214 inches ~500,000 gallons which was previously accepted by NRC) (EQ Program) 2 Containment Sump: Narrow Range Water Level Plant-Specific Sump A: LT-2039 and LT-2044 2 (Range: 0-30 ft H,O) 33 N/A pc o 7/ popO>-PW APERTURE CARD A]50 Ava)fable Or)

Aperture Card

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Page 4 of 11 Effluent Radioactivity Noble Gas From Condenser 10 'o 10 pCi/cc Electronic Microprocessor Gas Radiation Process Unit (Eberline SPING units) 3 14 N/A Air Removal System Exhaust (Ranges: NOBLE GAS 10~ pCi/cc to 1.0EOSpCi/cc; Monitor R-15 Xe 133 Equiv. 8 600 SCFM Condenser'ir Effector Exhaust mixed with Gland Seal Steam CONTAINMENT Containment Hydrogen Concentration 0-10% Redundant Category 1 COMSIP Containment H, N/A (Type A) Monitors 0 to 10% Concentration

[EQ Program); A Train, B Train Containment Effluent Radioactivity: Monitor R-12 SPING Electronic Microprocessor Air Noble Gases at Release Points: Particulate and Radioactive Gas Process Monitors With an Active Range of 1.0EO through 1.0E07 cpm (counts per minute or as indicated below>:

~ Containment Purge Vent Exhaust 10 ~

to 10~ pCi/cc 1.0E-Ski/cc to 1.0EOSpCi/cc Range 3 N/A Xe 133 Equiv. 8 11,000 SCFM 14

~ Plant Building Exhaust Vent 10 ~

to 103 pCi/cc 1.0E-Ski/cc to 1.0EOSpCi/cc Range 3 N/A Xe 133 Equiv. 8 76,000 SCFM 14

~ Vent from S/G Safety Relief and Atmospheric 10 i to 10~ pCi/cc 1.0E-1)LCi/cc to 1.0E03 Ci/cc Range with time 3 N/A Dump Valves compensation calculation 14 Effluent Radioactivity Monitor R-11 SPING Electronic Microprocessor Air Particulates and Halogens Particulate and Radioactive Gas Processor Sampling with Onsite Analysis Capability: -Monitors with an Active Range of 1.0EO through 1.0E07 cpm (counts per minute) a Containment Purge Vent Exhaust 10 3 to 10'Ci/cc Halogens > 1.0E-5 to 10 pCi Range 3 N/A Particulates 1.0E-6 to 1.0 pCi Range 14 8 11,000 SCFM as Cs 137

~ Auxiliary Building Vent Exhaust 10 ~

to 10'Ci/cc 3 Halogens > 5.0E-5 to 50pCi Range 3 N/A Particulates 2.5E-5 to 25 )ICi Range 14 8 76,000 SCFM as Cs 137 SI APERTURE WoD7~ 7D>>e N

CAR9 Also Available On Aperture Card

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Page 5 of 19..

RESIDUAL HEAT OR DECAY HEAT REMOVAL RHR System Flow (LPI) 0-110% Design FT-626 (Range: 0-4000 gpm) Former Item 3.3.10 (Type A) FT-931A, FT-931B (0-2200 gpm) 25 (EQ Program)

RHR Heat Exchanger Outlet Temperature 40-350oF 2 TE-627 to Computer 22 Former Item 3.3.7 (Range: 50 to 400 F)

SAFETY IMECTION SYSTEMS Accumulator Tank Level 10-90% Volume Accumulator SI Tank(s) Former Item 3.3.8 Narrow Level Range Instruments Indicate ~ 7 Inches from Administratively Controlled Nominal Setpoint IT 934 LT 938 LT 935 LT 939 Accumulator Tank Pressure 0-750 psig Accumulator SI Tank(s) 12 Former Item 3.3.8 (Range: 0-800 psig Pressure) 23 PT 936 PT 940 PT 937 PT 941 Accumulator Isolation Valve Position Closed or Open MOV-841 and MOV-865 (Limitorque) 13 Former Item 3.3.4.

Position Indicated on MCB Safety Injection (SI) 0-110% Design FT-924 and FT-925 Flow (HPI) (Range: 0-1000 gpm) 31 (Type A) [EQ Program)

Boric Acid Charging Pump Flow 0-110% Design FT-128 (Range: 0-75 gpm) Former Item 3.3.9 Refueling Water Storage Tank (RWST) Level Top to Bottom 2 LT-920 and LT-921 N/A (Type A) (Range: 0-1000" H~O, ~ 0 to 100%)

PRIMARY COOLANT SYSTEM Reactor Coolant Pump Status Electric Current Main Control Room Ammeters on 4 KV Bus (0- N/A 1200A) Along with Handswitches and Status Iights on Control Room Panelboards SI O'Oc 7/7ogyp. '0+

APERTURE CARD Also AvailaMe On Aperture Card

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bi APERTURE CARD Page 6 of 19-Also Available on primary System Safety Relief Valve Positions (PORVs Closed/Not Closed Class lE Valve Position Monitors: See Attachment A and Code Safeties) Item 3.3.12 (Type A) ~ The Pressurizer Safety Reliefs are Equipped with LVDT Analog Valve Stem Motion/Position N/A Detectors. [EQ Program] ZT-434 and ZT-435

~ The PORVs are Equipped with Snap Action N/A Position Switches [EQ Program) ZS-430 and ZS-431C Pressurizer Level Bottom to Top LT-426, LT-427, LT-428 N/A (Type A) (Range: 202" to 100" H~O)

[EQ Program]

Pressurizer Heater Electric Current 2 Main Control Room Handswitch Controls for Each 10 See Attachment A Control or Backup Bank Breaker w/Status Light Item 3.3.11 Display; MCC Supply Voltage and MCC Bus KW Demand Meters for Control or Backup Groups Exist in Control Room Pressurizer Relief (Quench) Tank. Level Top to Bottom LT-442 (0-100%) N/A (Range: 0 to 84" H,O ~ 0 to 100%)

Pressurizer Relief (Quench) Tank Temperature 0 750oF TE-439 (Existing Range: 0-300'F) See Attachment A Item 3.3.12 Scale Change Pl'armed: 50 to 400oF Pressurizer Relief (Quench) Tank Pressure 0 to Design Pressure 3 PT-440 (Range: 0-150 psig) N/A

'I (Tank Rupture Disc Setpoint 5 100 psig)

SECONDARY SYSTEM STEAM G)2KRATOR S/G Level Tubesheet to Separators Wide Range LT-460 and LT-470 See Attachment A (Type A Proposed) Wide Range Level (Range: 0-520" H~O) Item 3.3.13

[EQ Program)

S/G Level Narrow Range: 0-100% LT-461, LT-462, LT-463 See Attachment A (Type A) LT-471'T-472'T-473 Item 3.3.13 (Range: 138" to 33.6" H,O)

[EQ Program]

S/G Pressure Prom Atmospheric Pressure PT-468, PT-469, PT-478, PT-479 N/A (Type A) to 20% Above Lowest Safety PT-482, PT-483 Valve Setting (Range: 0-1400 psig)

[EQ Program] goo pa PYP-dC

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SI APERYURZ CARK) Page 7 of 19-11cn Ave(lnhln A~

Main Steam Flow Plow Range Main Steam Flow FT-464, FT-465, N/A (Type A) OR 0-110% FT-474, FT-475 Safety/Relief Valve Position (Range: 0-3.8 x 10'ph)

[EQ Program]

Main Feedwater Flow 0-110% Design Flow 3 PT-466, FT-467, FT-476, FT-477 N/A (Range: 0-3.8 x 10'ph)

AUXILIARYFEEDWATER OR EMERGENCY FEEDWATER SYSTEM Auxiliary Feedwater Flow 0-110% Design Flow FT-2001, FT-2013; FT-2002, FT-2014 6 N/A (Type A) (Range: 0 to 275 gpm) MDAFW, or FT-2015, FT-2006, FT-2007 (Range: 0 to 500 gpm) TDAFW Standby Auxiliary Feedwater Plow Plant-Specific 2 FT-4084, FT-4085 6 N/A (Type A) (Range: 0 to 250 gpm) SBAFW Condensate Storage Tanks Plant-Specific CST Seismically Qualified Transmitters LT- 5 N/A (Type A) 2022A and LT-2022B (Range: 0-24 ft.)

CONTAINMENT COOLING SYSTEMS Containment Spray Flow 0-100% Design Plow Containment Spray Flow Determinations are See Attachment A Indirectly Available. EQ Qualified SI and RHR Item 3.3.14 Flow Sensor Indications are Available. CS Plowrate can be Calculated from Indicated SI and RHR Flowrate Difference When in Recirculation Mode from Containment Sump B (EQ Program Transmitters] SI and RHR Flow Rate Difference CV Fan Heat Removal Plant-Specific 2 CV Pan 1A, 1B, 1C, 1D On/Off Status Lights and 7 N/A Handswitches at MCB 8 CV Atmosphere Temperature 40 400oF Six of 24 RTDs are R.G. 1.97 objects. See Note 22 Existing RTDs are Recorded and Indicated at the Containment Leak Rate Test Panel and the 32 PPCS computer monitors the six RTDs.

(Range: 0-300 F)

CV Sump Water Temperature 50 250oF 2 RTDs Installed as Part of RVLIS; TE-490A/B or 16 Former Item 3.3.15 Sump B (RHR Suction Source) TE-491A/B (Range: 0 to 360'F) 26

[EQ Program]

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CHEMICAL AND VOLUME CONTROL SYSTEM (CVCS)

Reactor Water Makeup Flow 0-110% Design Flow FI-144 (Range: 5-75 gpm Rotameter) 9 Former Item 3.3.16 27 Letdown Flow 0-110% Design Flow FT-134 (Range: 0-100 gpm) N/A Volume Control Tank Level Top to Bottom LT-112 (Range: 0 to 76" H,O ~ 0-100%) 9 N/A COOLING WATER SYSTEM (CCW)

Component Cooling Water Pump Temperature to ESF 40 200oF 2 CCW System Conditions: 9 Former Item 3.3.17 28

~ Heat Exchanger Temperature TE-621 (Range: 0 to 225~F)

~ Pump(s) Pressure Monitor PIC-617 (Range: 0 to 150 psig) ~

~ CCW Surge Tank Level LT-618 (Range: 0 to 46" H,O ~ 0 to 100%)

CCW Flow to ESF 0-110% Design Flow FT-619 (Range: 0 to 7000 gpm with Low Flow See Attachment A Alarm 8 1800 gpm) Item 3.3.18 High Level Radioactive Tank Levels

~ Waste Drain (Holdup) Tank Top to Bottom LT-1001 (Range: 0 to-128" H,O) N/A

~ 0 to 100%

~ Reactor Coolant Drain Tank Top to Bottom 3 LT-1003 (Range: 0 to 28" H,O)

~ 0 to 100%

Radioactive Gas Holdup Tank Pressure 0 to 150% Design PT-1036, PT-1037, PT-1038, PT-1039 29 Former Item 3.3.19 (Gas Decay) (Range: 0-150 psig) Design Pressure of Each Tank and its Safety Valve Setpoint is 150 psig. Normal Radgas Pump Operating Condition is ( 100 psig SI Pd'd 7/ 7D~QP -dg

~IERYURE CARD A1so Avai1ab1e On Aperture Card

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Page 9 of 19.-

VENTILATION SYSTEMS Emergency Vent Damper Position Open/Close Status Existing Valve Status Indication See Attachment A (Containment Mini-Purge Valves) Provisions for Containment Air Supply or Purge Item 3.3.4 Vent Valve is Located on MCB. Snap-Action Position Switches Installed on 6" Purge Supply and Exhaust Valves during the 1987 outage.

Mini-Purge Valves: 7970, 7971; 7445, 7478.

Main Purge Valves AOV-5869 and AOV-5879 are blind flanged, and accessed only when the reactor is secured off-line POl(ER SUPPLY SOURCES Status of Standby Power and Other Energy Sources Voltage/Current Diesel Generator Voltmeters, Wattmeters (KW) 10 N/A Important to Safety and Ammetezs on the Main Control Board (MCB)

(Hydraulic, Pneumatic):

480V Bus Instrument Bus Voltage/Current Voltmeters on Panels in Control Rooms Ammetezs 10 N/A on Invezters in Battery Rooms for Bus 1A and lc 125 VDC Bus Voltage/Current Voltmeters and Ammeters in Control Room 10 N/A Air or Nitrogen; Instrument Actuation Pressure Instrument Air PT-2023 (0 to 160 psig) 11 N/A Nitrogen Gas PT-1066 (0 to 150 psig)

Nitrogen PT-455 and PT-456 12 (0 to 1000 psig) PORV and SI Accumulator Motive Gas

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SI APERTURE CARD Page 10 of 19-

~ ~ rt CONTAINMENT RADZATZON Containment Area Radiation, High Range 1 to 10'/Hr R29, R30 1.0 R/Hr to 1 ~ OE07 R/Hr N/A (Type A) (EQ Program]

AREA RADIATION Radiation Exposure Rate Meters Range, Location, and Existing Microprocessor-Based Area Monitoring Former Item 3.3.6 (Continuous Indication at Fixed Locations) Qualification Criteria Equipment Displays. Area Monitor Active Range Have Been Developed to is 0.1 through 1.0E07mR/hour 21 Satisfy NUREG-0654, Requirements for Emergency Radiological Monitors Radiation Exposure Rate in Areas Ad)acent to 10-'o 10'/Hr Range: 0.1 through 1.0E07mR/hour Former Item 3.3.6 Containment 21 AZRBORNE RADIOACTIVE MAT%2UALS RELEASED FROM PLANT NOTE: Noble Gases, Particulates, Halogens and Vent Flowrate Information is Presented Elsewhere in This Comparison Table ENVZRONS RADZATZON AND RADIOACTIVITY Airborne Radiohalogens and Particulates 10 ~

to 10 ~

pCi/cc Fixed or Portable Samplers N/A (Portable Sampling with Onsite Analysis Capability) 1.0E-12 pCl/cc to 1.0E-3 pCi/cc PASS Sampling Technique Varies Aliquot or Diluted Sample Plant and Environments Radiation 10 ~

to 10'/Hr, 1.0E-6 R/Hr to 1.0E03 R/Hr Gamma Photon N/A (Portable Instrumentation)

'o 10'ads/Hr, Gamma 10 Photon Radiations and Beta Low Energy 1.0E-3 R/Hr to 1.0E03 R/Hr Beta Photons Plant and Environments Radioactivity Multichannel Gamma Ray 1.0E-8 pCi to 10 pCi (or Higher Based Upon N/A (Portable Instrumentation) Spectrometer Sampling Dilution Techniques)

METEOROLOGY Wind Direction 0-360o 0 to 360O N/A Wind Speed 0-67 mph Monitored at 33, 150, 250 ft Elevations N/A (Range: 0-100 mph)

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Page ll of 19-Estimation of Atmospheric Stability Based on Vertical Temperature Differences RTDs Delta at 33, 150, 250 T Between Each ft Elevations; Elevation N/A Range: So to +20oF ACCZDENT SAMPLZNG CAPABZLZTY (ANALYSZS CAPABZLZTY ON-SZTE)

Primary Coolant and Sump 3 (all) Available with PASS (Post Accident Sampling System)

~ Gross Activity per ml Grab Sample Dilution Means is Provided Within the PASS 20 Former Item 3.3.20 1.0 )LCi to 10.0 Ci Liquid and Gas Sample Panel (LGSP), Then the 30 prepared sample is brought to the counting facility.

~ Gamma Spectrum isotopic Analysis Lab Analysis Spectrometer with a Multichannel Gamma 20 30

'/A 1.0E-8 pCi to 10 pCi or Higher Based Upon Sampling Dilution Techniques

~ Boron Content 0-6000 ppm 50'o 6000~

Titration Analysis ppm) with PASS Mannitol Auto- N/A Methodology

~ Chloride Content 0-20 ppm 5 ppb to 100 ppm Separate Lab Analysis After N/A LGSP Grab Sample

~ Dissolved Hydrogen 0-2000 cc(STP) /Kg (10-2000 cc/Kg) with PASS Gas Chromatagraph N/A Dissolved Oxygen 0-20 ppm (0.1-20 ppm) with PASS Probe Measurement N/A

~ pH 1-13 1-13 pH with PASS Boron Measurement Equipment N/A

~ Conductivity N/A 0. 1-500 pmho/cd N/A Containment Air: Grab Sample 3 (all) Available with PASS N/A

~ Hydrogen Content 0-10% Available with Either the EQ Qualified COMSIP N/A Hydrogen Monitors or PASS non-EQ Gas Chromatagraph 0 to 10%, 0 to 20% (or up to 100% concentration)

~ Oxygen Content 0-30% 0-30% with PASS Gas Chromatagraph N/A wpERTURE goo7/'>Dugs-yt'ARD Also Available On Aperture Card

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Page 12 of 1R-

a. Gamma Spectrum Isotopic Analysis Existing; Separate Ge(Li) Lab Analysis 20 N/A Multi-Channel Gamma Spectrometer After PASS 30 LGSP Grab Sample 1.0E-8 pCi to 10 pCl SI APIYURE CARD A~so Available On Aperture Card

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SI APERTURE Page 13 of 19 CARD ATTACHMENT B NOTES Also Available On Apertur Card Items in this RG&E Regulatory Guide 1.97 comparison table are listed in the order of appearance in Table 3 PWR VARIABLES, with exceptions. The exceptions concern Table 3 individual items that, are included under more than one Type of previously stated variables. For brevity, repeated items do not appear more than once (e.g., RCS Cold Leg Temperature, Containment Pressure, Noble Gas Effluents, etc.). If a Table 3 measurement variable it is assigned more than one Type, the highest stated Category or Ra'nge zeceives a response in this attachment wherever first appears (e.g., Core Exit Thermocouple Category 3, Type B variable or, [response prepared for] Category 1, Type C variable).

The two narrow range Sump A Category 2 Type B level transmitters are noted here as an adjunct measurement. The wide range level Category 1 redundant measurements in Sump B satisfy the Regulatory Guide 1.97 concerns.

The Category 2 radiation monitoring equipment is located in mild environments prior to any event that would actuate a protective interlock or alarm based on a radiation condition above the setpoint. Radiation monitors deal with area, liquid process, gas and particulate conditions. Most of these applications at Ginna result in a control room alarm with administrative control procedures imposed on the operators response to clear the alarm condition. Five designated alarm conditions also provide an electrical interlock to secure possible particulate, gas, or liquid release paths well below any Tech Spec allowable limits (containment air particulate or gas, Auxiliary Building air particulate or gas, and steam generator blowdown drain) . The Ginna P-9 procedure deals with radiation monitor setp'oint backgrounds and conservatively establishes setpoints. Procedure PC-23.5 details the radioactive release SPING-4 effluent monitoring equipment. Parameters measuzed deal with noble gas, gamma background, area monitoring, particulate and halogen gas concentrations. During Design Basis Accident conditions involving a safety injection or containment isolation signal, the radiation monitors act rapidly to perform their design alarm, recording and/or interlock functions. The Emergency Operating Procedures do not require the further deployment of these monitoring devices.

Air particulate, radgas and liquid monitors are generally located in mild environments during normal plant operations. Post Accident Sampling System (PASS) provisions are designed to access potentially hot samples from isolated systems which would be monitored by online rad monitoring equipment.

The defense-in-depth strategy involving the use of Category 3, Type B PASS limits the degradation of many radiation monitors due to harsh environs while also providing alternative measurement means. Some area monitors may, be exposed to design basis concentrations of radioactive and thermal accident harsh environments. Again, defense-in-depth provisions'for hand-held radiation survey and contaminated fluid assay metering devices or PASS (which is not single failure-proof) provides the capability to procedurally follow plant recovery opezations. For these reasons, Environmental Qualification of radiation monitoring devices is not required.

The RWST level monitoring redundant transmitters are located in an environmentally mild location during normal and accident (DBA) conditions. Manual and automatic instrumentation actions occur during Safety Injection and Switchover to Sump B RHR suction. Operator actions rely on RWST level instrumentation indications. Since the level transmitters are located in a mild environment, Equipment Qualification is not required for these Class lE Foxboro N-E11DM transmitters.

Condensate Storage Tank (CST) level transmitter provisions are not redundant per tank. However, each of the two tanks with a single transmitter is piped together with administratively controlled locked open 10" valves and thus redundant indication is provided. Furthermore, the CSTs are not located in a Seismic Category 1 building, although the installed Foxboro Model N-E13DM level instruments are Seismic Category 1 devices. (This is consistent with Section B, .6th paragraph and Table 1, Topic 3 of Regulatory Guide 1.97.) Level transmitter redundancy or building seismic qualification is analyzed not to be a concern based upon tank crosstie configuration and the Regulatory Guide 1.97 cited reference. The level transmitters are in an environmentally mild location therefore they have not been included in the Equipment Qualification Program.

The Ginna Station auxiliary feedwater arrangements located in mild environment locations provide a qualified redundant Seismic Category 1 system.

If for any reason AFW supply sources have to be augmented with another diverse supply source, a piped cross-connect exists which allows the AFW pumps or the SBAFW pumps to take suction from the Service Water pumps, (that draw water from Lake Ontario). The seismically qualified AFW to SW system piping crosstie is available to provide an unlimited source of auxiliary feedwater to the steam generators.

The service water Category 3 local flow and temperature indicator/switch sensors downstream of each containment air fan cooler water side heat exchanger provide evidence that heat is being removed when compared with the temperature of the service water supply to each of the coolers. Theze are high temperature alarms provided in the control room for each fan's service water discharge line. The local service water flow indicator/switch and temperature indicator/switch sensors are in an environmentally 'mild location and therefore not in the EQ Program. Main Control Room panelboard handswitch and status lights provide the Operator with fan operation data.

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Sl ISO XVmIabie GII APKR7URK ~,-~~<: ca.a Page 14 of 19 GARB The determination that containment heat removal is occurring after an accident (DBA) involves the use of Category 1, Type A instrumentation.

Environmentally Qualified containment pressure and containment sump water temperature provide the required post DBA temperature decrease data.

Containment Air Temperature monitoring devices are also being considered for upgrade.

The Category 2, Type D CVCS flow and level, and CCW temperature a flow measurement instrumentation is located in a non-harsh environment in the auxiliazy building. The Emergency Operation Procedures do not stipulate that these Class lE sensor systems have to be deployed during an accident (DBA), nor do operators have to form decisions based on display data. For these reasons, the foregoing instrumentation is regarded to be non-EQ.

The Category 2, Type.D electrical voltage and current instrumentation sensors are located within switchgear in a mild environment. They are not subject to a hazsh environment during a Design Basis accident (DBA). The Emergency Operation Procedures (EOPs) do not specifically require any subsequent operator actions or decisions based on output data. The remote switchgear located electrical sensors are therefore not included in the EQ Program.

The pressure transmitters that monitor instrument air and nitrogen are located in mild environments at all times. The EOPs do not require any operator observations nor safety significant decision-making based upon pressure indications at the MCB. The pressure transmitters aze not included in the EQ Program for these reasons.

r The two N, high pressure accumulator pressure transmitters monitor a backup motive gas source to operate PORVs and safety injection charged accumulators. Solenoid operated valves, check valve configurations and pressure control valves direct the 'gas to various administratively controlled destinations prior to any accident scenario. Since the pressure transmitters perform their service in mild environment conditions and are not subject to DBA harsh environs, they are not included in the EQ Program.

The accumulator motorized valves have been placed in the open position by administrative contzol, then electrically locked in that open condition by removal of fuses to prevent inadvertent safety injection accumulator isolation. The MOV-841 and MOV-865 valves remain in the open configuration isolated from RCS fluids by the passive check valves 842A and 842B. Since the administratively controlled accumulator Limitorque valves achieve the safety-related process alignment without actuation prior to harsh environs, they'e not included in the Equipment Qualification Program.

The new, replacement microprocessor-based Eberline SPING-4 process radiation monitoring system equipment digitally measures noble gas, particulates and halogen activity. Plant-specific administrative procedures provide calculation sealer coefficients for conversion from cpm readout notations to ion-specific results (pCi/cc or mR/hr) . The administrative procedures of interest include P-9 (ranges, tech spec limits and setpoints), EPIP 2-4 conversion methods and scalar constants, PC-23.5 concerned with Eberline SPING-4 effluent monitor ranges with data conversion multipliers/setpoint limits, and computer alarm and time based trend values are found in the PPCS (Plant Process Computer System) index.

RCS Soluble Boron Concentration Former Topic 3.3.2 The USNRC SER dated April 14, 1986 deals with Boron analysis range topics. NUREG-0737 Item II.B.3 approval for Boron analysis range and accuracy statements was deferred for RGaE in the USNRC correspondence dated April 14, 1986. The Boron analysis inaccuracy allowances were published* June 30, 1982 as NUREG-0737 supplementary information. In the NRC document dated June 30, 1982, it is stated: "In general this analysis should be accurate within a5% of the measured value (i.e., at 6000 ppm Boron, the tolerance is + 300 ppm while at 1000 ppm boron the tolerance is F50 ppm). For t

concentrations below 1000 ppm boron the tolerance band should remain at 50 ppm." Ginna plant administrative controls over analyzer standard solution checks during computerized calibration runs are more restrictivj (in the order of + 20 ppm, or recalibrate and standardize again). The documented a5% accuracy band remains the governing Boron measurement allowance.

• June 30, 1982 correspondence between S.A. Varga (USNRC ORB to J. Dolan, Docket 50-315 D.CD Cook IMEC; Criterion 10).

The Category 1, Type A Reactor Vessel Level Indicating System (RVLIS) was placed in service during March 1987. The design basis and equipment features concerning the RVLIS were evaluated by the USNRC TAC 445137 Amendment No. 30 to RGaE's Operating License. The determination by the USNRC in its correspondence dated September 23, 1988 was that the safety basis and performance was acceptable.

RCS Cold Leg RTDs have been stipulated to be Type A measurement variables. The Cold Leg RTDs do not provide any signal input data into Engineered Safety Feature control system apparatus. However, they directly provide the Operator with decision-making display data. EOP (Emezgency Operating

'rocedures) requirements are imposed upon the Operator to observe Cold Leg RTDs and perform a contingent action based on TE-409 B-l/TE-410 B-l signal information. Operators observe either of the cold leg RTD temperatures to maintain an overall cooldown rate < 100'F per hour to minimige metal thezmal stress on RCS components. The cold leg RTDs also are utilized in the Analog Reactor .Vessel Level Indicating System (RVLIS). Each cold leg RTD is environmentally qualified and documented in RG&E's 10CFR50.49 program. The RVLIS RTD input signal in either analog signal process rack converts its

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Also AvaiIable On

~ERYURE Aperture Card Page 15 of 19 CARD resistance signal into diverse instrument signals suitable to drive each of two main control board cold leg temperature indicators (0 to 700'F) . RVLIS is a Category 1, Type A analog indicating system for operator assessment duties during all plant operating conditions. RVLIS does not provide any permissive or stop logic control signal outputs to electrical equipment.

RCS hot leg RTDs have been stipulated as Type A measurement variables. The hot leg RTDs TE-409 A-1 and TE-410 A-1 do not provide any signal input data into Engineered Safeguards Feature control system apparatus; However, they directly provide the Operator with decision-making display data.

EOP (Emergency Operating Procedure) requirements are imposed upon the Operator to observe the two diverse hot leg RTDs in the eventuality that CETs aren't available and perform a contingent backup action based on RCS temperatures <3254F. The primary action steps involve possible securing of one or more SI pumps based on Core Exit Thermocouple/RCS Pressuze Subcooling determinations, and RHR pumping system availability. Another use for hot leg RTDs include the Subcooling Margin Monitors (SMM) that utilize single hot leg RTD analog data inputs and links RCS pressure data to produce two different 0 to 100'F subcooled margin indications in the main control room. No SMM Operator decision or observation requirements exist, since the EOPs rely on other qualified system components to provide SMM information (Core Exit Thermocouples/RCS pressure) . The hot leg RTDs are environmentally qualified and aze documented in RGaE's 10CFR50.49 program. The signals from each hot leg RTD are routed to the main control board indicators.

De rees of Subcoolin (RCS Circulating Fluid)

Former Item 3.3.3 Item II.F.2 of NUREG-0737 which deals with circulating primary fluid subcooled margin parameters was reviewed and approved by the NRC in the SER dated September 7, 1980. The Ginna Station Emergency Operating Procedures (EOPs) require that primary Reactor Coolant System (RCS) loop circulating fluid subcooling information be generated by means of Operator observations and calculations. The EOP provides a graphic minimum Subcooled Margin Monitor (SMM) nomogram format based on Category 1, Type A variable measurements involving main control room display instrumentation and Operator prepared data plots of core exit thermocouple temperature and RCS pressure. Regulatory Guide 1.97 Category 2 Type C measurement variable guidance applies to this SMM topic. EOPs involved with a harsh containment condition requires that the Operations team prepare a minimum SMM Ginna nomograph which displays subcooled region margin conditions (or inadequate subcooling margin) under normal or adverse containment conditions. The SMM nomograph conservatively accounts for any instrumentation inaccuracies. The effective range of this nomograph exceeds the 200 F subcooled/35'F superheat range recommendation of Regulatory Guide 1.97. Subcooled margin monitoring information derived from core exit thermocouple and RCS pressure is also automatically calculated and displayed on the non safety-related Safety Assessment System (SAS). The effective range of the SAS also exceeds the 200'F subcooled/35~F superheat Regulatory Guide 1.97 guidance.

The redundant existing Class 1E subcooled margin monitor analog panel meters that are based upon qualified analog signal inputs from reactor outlet hot leg temperature RTDs and RCS wide-range pressure have an indgcation range of 0-100 F subcooled. The SMM meters are not required to be observed by EOPs but provide a diverse backup information display and will therefore be left as-is. The present Ginna Station subcooled margin display arrangement utilizing Category 1, Type A variable measurements was acceptable based upon NRC approval in the September 7, 1980 SER.

Radioactivit Concentration or Radiation Level in Circulatin Primar Coolant (Isotopic Analysis)

Former Topic 3.3.5 II The NRC SER, dated April 14, 198t) found the instrumentation provided for this measurement variable to be acceptable. The original design basis for implementation of NUREG-0737 Topic II.B.3, involves sampling requirements to perform a radiological analysis within a three hour time period for "certain radionuclides in the reactor coolant...". The NUREG-0737 Clarification, dated October 31, 1980, (2)(d), states "Alternatively, have inline monitoring capabilities to perform'll or part of the above anaw.ysis". Ginna's response involved the selection of semi-automated manual dilution techniques involving sample withdrawal and preparation of the sample aliquot by the Post-Accident Sampling System, not an inline monitoring capability.

The remote-manual sampling and dilution capabilities of the existing installed equipment are equivalent to Category 3, Type C attributes.

The Ginna Post-Accident Sampling System (PASS) is equipped wit) remote-manual abilities to acquire a Reactor Coolant System (RCS) sample, then manipulate the sample by diluting it approximately 1000:1. The dilutant may then be manually delivered to either of two diverse counting facilities at Ginna Station for multichannel spectrometer isotopic analyses',. The PASS panel is utili,zed by Health Physics technicians at least once pez week to produce routine pzoceduralized analyses when the unit is on-lj.ne.

Regulatory Guide 1.97 guidance for radiation concentration determinations states that Category 1, Type C attributes apply to this measurement variable with the purpose stated to be detection of breach (Fuel Cladding~topic). Fuel cladding breach detection is not within the Ginna licensing basis but is acknowledged to be a concern during Functional Restoration activities. Functional Restoration activity is beyond the Ginna licensing basis. No EOP activity involved with design basis DBA occurrences requires'that the radiation concentration=determinations in RCS be performed, and there's no consequent operator action requirement. Safety In)ection boration will have been performed to shut down the reactor and maintain it in a subcritical 5'oo7/7o ~Q 4 -(S

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Page 16 of 19 state. Other Environmentally Qualified 10CFR50.49 equipment has been chosen and dedicated to track the course of the DBA. For these reasons, RG&E requests that an exception be granted to retain the existing PASS Category 3, Type C measurement methodology.

Radiation Exposure Rate (Area Monitoring)

Former Topic 3.3.6 Area radiation monitors are Category 2, Type E instruments, and meet NRC Regulatory Guide 1.97 range guidance language. The monitozs are detailed in the Attachment B chart data under the heading "Area Radiation". ("Environs Radiation and Radioactivity", "Containment Radiation", and "Containment" topics aze somewhat related to this issue.) The EOPs do not require operator response to any area radiation monitor alert during a DBA. The main control room or computerized area monitor displays serve as a human warning function, not as an automatic protective system. The area radiation monitoring system has been upgraded to include microprocessor based local and remote readout displays. Dedicated main control panelboard recorders post area monitor radiation data. The microprocessor-based field remote and control board area monitor signal handling apparatus has an ovezall span range of 0.1 through 1.0E07 mR/hour. Specifics concerning these monitors, their setpoint data and calculation scalar constants are administratively controlled within the P-9 procedures for all radiation monitors at fixed locations in the Ginna Plant. Computer outputs dealing with alarm and time based trends aze processed by the Plant Process Computer System (PPCS) . Alarm setpoints and trend information are maintained within the PPCS computer index.

RHR Heat Exchan ez Outlet Temperature Former Item 3.3.7 RG&E has determined the maximum RCS fluid approach temperature Upstream from the RHR heat exchangers, before temperature reduction during post-LOCA sump recirculation. This reactor coolant fluid temperature is, approximately 264 F. The installed instrument range of 50'F to 400'F is considered sufficient to compensate for equipment or operating uncertainties and provides a wide margin when RHR heat exchangers attemperate the recirculating fluids.

The temperature is derived from one Resistance Temperature Device which monitors RCS fluid conditions. The RTD is located in potentially harsh environs and its temperature data is dizected to the Plant Process Computer System and also to the Safety Assessment System computer displays.

This measurement variable is characterized as a Category 2, Type D instrumentation pez Regulatory Guide 1.97. It does not perform a safety-related function at Ginna. There are no EOP requirements for this Category 2, Type D temperature measurement, nor is there any required Operator response based on its display. For these reasons, the RHR heat exchanger outlet temperature instrumentation is not included in the 10CFR50.49 Program.

Accumulator Tank Level and Pressure Former Topic 3.3.8 The April 14, 1986 NRC SER correspondence found the Category 2, Type D instrumentation provided for this variable to be acceptable. No further response was required at that time.

The SI accumulators are administratively maintained in a pzessure charged and filled status under normal plant operating circumstances. No Operator action is required other than the routine surveillance of the accumulators'evel fill and pressurized ready state during normal plant operation.

During DBA conditions which result in subsequent harsh environment in containment there are no EOP dizected safety-related Operator requirements which rely upon level or pressure accumulator display data.

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Page 17 of 19 e rea y- o- red in each of two vessels. Two electronic displacement type narrow band level prov e or e ovided for each accumulator vesse a

1. Ma in t 1 lb d i di dditio al informatio relative to the safety function of the accumulat ozs d 1 1 t ti 1 readiness prior to any, eventt which tor o erational variable transmitters are not included in RG&E's 10CFR50.49 E i Q lifiwould zesu 1 t in a h ars h en i o tio P o t I th C t o y 2 T D Boric Acid Charain Flow Former Topic 3.3.9 The NRC SER, dated April 14, 1986 found that Category 2, Type D instrumentation prov rovided or this e for is va variable to be acceptable. No further response was determined to be necessary at that time.

lizes a differential pressure electronic pressure transmitter annd its associated orifice at an Auxiliary Building basement location which is generally locateed in mild environments. Normal e Tank temperature is approximately 80'F,(50'-104 variation) the transmitter location (1.0E04 Rads during a DBA) .

i tio ) an d b ac kgroun ou d a di tio i o 11 le 'ha 20 R t e peza o owrate indication and control setpoints at the main control panelboard. The charging pumps basis accident. The Safety ln)ection System is designa e istin of or a p p Si i th p i t desi nated design bas s equ pmen whi h th 1 i i t d to miti t th i d o of d are located i

in an environmentally mild location, the electrical environmental qualifications ave no een g go y 2 TyP e D measurement variable. The CVCS pumping system line flow differential pressure n an environmentally mild location is not required by the the 10CFR50.49 EQ Program.

EOPs during the course off a DBA . F or h es fl j FT 128 i 1 d d f Low Pressure In ection S stem Flow (Residual Heat Removal [RHR])

Former Topic 3.3.10 Th e RHR with a S ys t em flow transmitter meets the requirements of NUREG-,,0737 Su redundant flow transmitter loop. The existing FT-626 is an environmentally qua i lifi lement 1 Sect on 6 . 2 with an exception. . FT-626 RHR flow is not configureed e d nuc 1 e ar service Foxboro N-E13DM series transmitt e r erforming Category 1, Type A measurement and indication service. This flow transmitter low transm tter may bee exexposed to a radiation harsh environment during a DBA (less th an 5E04 Rads a s aat 10 foot distance from a pump radiation source).

n nd install a redun ant flow redundant ow transmitter ransm to monitor flow with the existing n p ipeed p rimar y ifi flow or ce FE- 2 . The E R installation is currently scheduled for the 1993 R f i

be environmentally qualified and incorporate d n thee 10CFR50.49 program. The redundant RHR f ow s gna w li g 0 t g Th i RHR t 1 tdf t d ti ill display and also be directed to the RVLIS system.

Containment Sumo Water Temperature Former Item 3.3.15 ed with environmentally qualified Class 1E RTDs (Resistance Temperature Detectors) on the eve ransm he two RTD electrical termination provisions are located above the potent a pos 1

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i i1 o id li TE-490 A~B id d i o io ment imatel 4.3 feet above 1 t d d the conta nmen b i aseme id t Th o d of th ot ti ll desi n ran e for the compensat on system has been operational since 1987 and is d esi g ned to P rovide'n isolated computer ze d RTD th erm 1 d i RTD 1 o o t di 0 o 360 F. Th 1 o th Pl

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Page 18 of 19 The RVLIS temperature detection equipment is qualified for the postulated harsh environment process conditions and all sensors, wiring and connections are in the Ginna EQ (Equipment Qualification) program. The containment water temperature measurement method comp)ies with Regulatory Guide 1.97 recommendations for a Category 2 Type D measurement.

(Reactor Water Makeup)

Former Topic 3.3.16 The NRC SER dated April 14, 1986 found that Category 2, Type D instrumentation provided for this variable to be acceptable. No further response is required.

Component Coolin Water to En ineered Safe ards Features (Temperature Measurement)

Former Topic 3.3.17 The NRC SER dated April 14, 1986 found that Category 2, Type D instrumentation provided for this variable to be acceptable. No further response is required.

Radioactive Gas Holdu Tank Pressure Former Item 3.3.19 Each of the four Category 3, Type D gas decay tank pressure conditions are normally maintained below a maximum operating pressure of < 100 psig. The normal operating pressure of 80 to 100 psig is limited by the design of the liquid ring rotary compressor which pressurizes the gas delivered to any of the decay tanks. The pressure transmitter range of 0-150 psig provides substantial margin over this operating range. Each of the gas decay holdup tanks is equipped with a pressure safety relief valve set at 150 psig and also equipped with a series connected rupture disc. 150 psig is equal to the pressure safety relief valve setpoint and is also the design p"essuze of the tank. RGaE considers that appropziate Operator action, would be taken as pressures approach 80 psig, but prior to the time that the full scale 150 psig reading was zeached.

No Emergency Operating Procedures require any Operator action or decision as a consequence of the four main control room pressure displays. It is apparent that pressures greater than the relief valve setpoint pressure of 150 psig are not possible. Guidance in Regulatory Guide 1,97 suggests that 225 psig pressure indication (150% of design pressure) be available. Since tank overpressure relief takes place at 150 psig and the liquid-ring compressors are administratively controlled to pressure outputs in the range of 80 to < 100 psig, RGaE elects to retain the transmitter/indication ranges at the existing range of 0 to 150 psig. Decay tank rupture analyses have been performed per Chapter 15 of the UFSAR, with radiological consequences well below Part 100 guidelines.

RGaE, therefore, does not consider that there is a safety reason to modify the radgas decay tank pressure instrumentation.

Accident Sam lin Former Topic 3.3.20 The NRC TER noted a few minor deviations from the guidance of Regulatory Guide 1.97 regarding the range of Category 3, Type E sampled parameters and noted that these deviations would be addressed under the review of,,NUREG-0737 Item II.B.3. An NRC SER dated April 14, 1984 determined the acceptability of RG6E' resolution of Item II.B.3 of NUREG-0737.

Safety Infection Flow (SI)

(New HPI Topic)

The SI System flow transmitters meet the requirements of NUREG-0737 Supplement 1, Section 6.2 with an exception. FT-924 and FT-925 are not configured as redundant flow transmitter loops within each train. The SI piping system splits into a parallel piping arrangement. Each of two legs is equipped with one flow orifice and one transmitter. The symmetry of a flow transmitter in each of two redundant piped flowpaths provides SI flow measurement redundancy. The two piped flowpaths are designed to be single failure-proof. The existing flow transmitters are environmentally qualified nuclear service Foxboro N-E13DM series transmitters performing Category 1, Type A measurement and indication service. The flow transmitters in containment may be subject to the DBA harsh environment profiles (spray, humidity, temperature and pressure) .

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Page 19 of 19 Containment Air Temperature (New Topic) 24 Containment Air Temperature RTDs are being replaced throughout containment. Six designated Category 2, Type D RTDs which are presently entered into the PPCS computerized display (1 operating deck, 4 intermediate, 1 basement), will receive data from the replacement RTDs. The PPCS provides the Containment Air Temperature display upon demand from the Operator (Regulatory Guide 1.97, Table 1, Topic 6 covers this Category 2 display topic).

The Containment Air RTDs are being environmental qualification tested in accordance with 10CFR50.49 Program requirements. The tentative completion date and dedication of the environmentally tested RTDs for EQ service is the 1991 Refueling Outage.

Two Containment Sump A level transmitters LT-2039 and LT-2044 have been installed to monitor water level off-normal increase. These transmitters are maintained as Category 3, Type C devices not the Reg. Guide Category 2, Type C guidance for this measurement variable. The EOP E-O, Step 26 directs the operators to check if the RCS is intact and uses sump A level as one of several sources of the information to base that decision. There are no specified operator requirements during a sump level increase indication other than entering EOP *E-0 to determine if there's any leakage source if the RCS is not intact. EOP *E-1 uses committed Category 1 Type A measurement apparatus to follow the DBA and pinpoint the source of leakage. LT-2039 and LT-2044 are used in concert with other RCS breach detection-instrumentation including radiation monitoring, containment pressure and Sump B level detection equipment for RCS breach determinations. Technical Specification Section 3.1.5 deals with RCS leakage limitations and plant responses whenever leak parametezs are determined.

LT-2039 and LT-2044 operate at an early part of a reactor trip or safety injection occurzence and play no active role in the generation of trip or SI signals. Sump A level measurements are diagnostic aids used in concert with other environmentally qualified apparatus (radiation, pressure and sump B level) . These two transmitters can fail, but they will not misdirect the operator nor can they interfere with SI or reactor trip sequences which preceded step 26.

RGaE requests an exemption from the Category 2 Guidance and seeks to retain the redundant LT-2039 and LT-2044 transmitters as Category 3, Type C measurement equipment.

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