ML20003G443

Forwards Info Schedule Re Facility Compliance W/Reg Guide 1.97,Revision 2,per Condition 5 of License NPF-9 for Fuel Loading & Zero Power Testing.Meeting W/Nrc to Discuss Areas in Need of Clarification Requested

ML20003G443
Person / Time
Site:	Mcguire, McGuire
Issue date:	04/23/1981
From:	Parker W DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8104290447
Download: ML20003G443 (16)

Text

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DUKE POWER COMPANY Powra Dust.otwo 422 Socin Cucacu Stazzi. CHARLOTTz, N. C. 26242 w s LLIA s4 O. Pa n s t a, J R.

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Steam Paoovctio= April 23. 1981 ^**'.e's*

273 a Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Ms. E. Adensam, Chief Licensing Branch No. 4

Subject:

McGuire Nuclear Station Docket Nos. 50-369 and 50-370

Dear Mr. Denton:

On January 23, 1981 the NRC issued License No. NPF-9 to Duke Power Company for fuel loading and zero power testing of McGuire Nuclear Station Unit 1. Con-dition 5 of this license requires that Duke provide a schedule for bringing McGuire in compliance with Regulatory Guide 1.97, Revision 2. The attached pages discuss those areas where the McGuire design meets this Regulatory Guide and provides a schedule for upgrading the remaining areas. Duke requests a meeting with the appropriate NRC personnel to discuss those areas identified in the attached as neading clarification.

Very truly yours, William O. Parker, Jr.

THH:pw Attachment

! cc: T. J. Donat Senior Resident Inspector McGuire Nuclear Station

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810.4290 N7

REG GUIDE 1.97 RESPONSE A detailed review of the McGuire Nuclear Station instrumentation has been performed per the guidance given in Regulatory Guide 1.97 (Rev. 2) and a Duke Power Company position established. The significant points of this position and the compliance of McGuire Nuclear Station are discussed in this document.

Variables All of the variable measurement channels required to assess plant and environment conditions during and following an ace? dent are presently in-stalled and operating at McGuire Nuclear Station (Refer to following table).

Certain variables tabulated in the 197 document are not measured by McGuire instrumentation. These particular variables either do not apply to the McGuire plant design or would not be utilized for operator action and accident analysis. An example of this type of variable is " heat removal by the con-tainment fan heat removal systed" as listed in Table 2 under Type D variables.

This variable does not apply to the McGuire station since the containment is of Ice condenser design and no credit is taken for ventilation system cooling during an accident.

Some new instrumentation (e.g. reactor vessel level) is being installed at McGuire as a result of new requirements stemming from the TMl-2 accident.

This Instrumentation has been or will be installed per the commitments and schedules provided previously in the document " Duke Power Company, McGuire Nuclear Station, Response to TMI Concerns."

Duke Power Company Positions on Regulatory Guide 1.97 Rev. 2 Type A Variables Regulatory Guide 1.97 Rev. 2 provides no new significant guidance concerning Type A variables.* The McGuire station Type A variables have been addressed previously in licensing documents submitted by Duke to the NRC.

Nuclear Safety Related Equipment The instrumentation installed at McGuire Nuclear Station as nuclear-safety related per the FSAR licensing basis meets the intent of the RG 1.97 Rev. 2 definition of Category 1 instrumentation.

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• As defined in RG 1.97 Section C.1.1 and including footnote 2 which defines primary information.

Qualification The environmental qualification of Category 1 Instrumentation located in .

a harsh environment has been addressed in the Duke response to NUREG-0588,

" Interim Staff Position of Environmental Qualification of Safety Related Electrical Equipment," dated October 14, 1980. Seismic qualifications are discussed in McGuire FSAR Chapter 3, " Design Criteria." Environmental qualification of Category 2 Instrumentation will require further discussion and clarification.

Quality Assurance information concerning the Quality Assurance program followed for McGuire Nuclear Station may be found in the McGuire FSAR, Chapter 17, " Quality Assurance." QA requirements for Category 2 instrumentation will require further discussion.

Ranges The Duke analysic has determined that more than 98% of the existing McGuire ranges for variables listed in Table 2 of RG 197 Rev. 2 are adequate for system operation under normal and accident conditions. (Refer to the attached table) However, these ranges do not always envelope the RG l.97 Rev. 2 ranges. Examples of this are the reactor coolant hot and cold leg temperatures, which are specified to be 50-750 F. .'n the RG 1 97 Table 2 listing. The Duke range of 0-700 0 F. is adequate since at 7000F, the saturation pressure is 3090 psia and system relief design pressure is well below that point.

For certain variables, plant accident procedures such as direct sampling of a variable are utilized to gather primary information where wide range instantaneous data is either unavailable or unnecessary. During accident conditions, these procedures are the preferred means of gathering this in-formation due to accuracy considerations. An example of this is the reactor coolant radioactivity monitor, which was not designed to quantify accident conditions and cou. . cot be assured of flow af ter RCP's are tripped. Direct sampling would then be a more accurate and appropriate means of measuring activity during and af ter an accident.

The instrument 6 tion (<2%) which Duke has determined requires recalibration of I the existing range for accident conditions will be modified by June, 1983 or by the end of the first refueling outage thereaf ter.

Diversity A diverse means of information verification has been provided at McGuire Nuclear Station for Category 1 instrumentation where failure of one channel could result in information ambiguity that could lead operators to defeat or fail to accomplish a required safety function.

Controls Layout Instrument grouping and identification will be addressed in the Duke response for Task 1.D.1 of NUREG-0660 and the yet-to-be issued NUREG-0700.

Neteorological Variables A discussion of the McGuire Meteorological System capabilities as they per-tain to NUREG-0654 is contained in an April 3,1981 letter from Mr. W. O.

Parker to Mr. Harold R. Denton. This letter deals with the McGuire Nuclear Station Emergency Plan.

Labora tory Capabili ties and Environs Moni toring The plant portable Instrumentation, sampling and laboratory analysis capabilities which now exist at McGuire Nuclear Station are adequate for normal and accident conditions and meet the intent of RG 1.97 Rev. 2. Further Information can be obtained in the McGuire FSAR Chapter 12, " Radiation Protection," and " Duke Power Company, McGuire Nuclear Station, Response to TMl Concerns."

Information concerning fixed radiation exposure meters at McGuire Nuclear Station will be provided as part of the Duke response for NUREG-0654 which is currently under development.

Processing Equipment Most of the variables specif'ed in RG 1.97 Rev. 2 are monitored by independent, dedicated instrument loops. Instrumentation to monitor the remaining variables is contained in the following McGuire systems: process instrumentation hard-ware, radiation monitoring hardware and Incore thermocouples.

Process Ins trumenta tion Hardware The Process Control System (PCS) is divided into Protection Cabinets and Control Cabinets.

The PCS Protection Cabinets were p ovided as nuclear safety related equip-ment and were seismically qualified. The instrumentation loops are sepa-rated into four redundant channels with each having its own independent, safety-related vital power source.

i Each instrument loop within a channel has an output isolation device which provides a signal for a control board Indicator and a second output iso-lation device which provides a signal for a strip chart recorder and the plant operator-aid computer.

The signal being provided to the computer is isolated such that an open circuit or short circuit will not affect the signal to the recorder or the control board indicator.

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Cable separat 8 on has been provided between the four instrumentation channels from the sensor up to and including the output isolation de-vice. in addition, instruments previously defined as post-accident-monitoring (PAM) devices have had one channel per variable separated from the other channels. This separation is from the output isolation device to the indicating device on the main control board.

Due to the above considerations, Duke concludes that the instrumentation in the Protection Cabinets meets the intent of the RG 1.97 Rev. 2 de-finition for Category 1 Ins t rumen ta t ion. Refer to the McGuire FSAR, Chapter 7. " Instrumentation and Control" for further discussion.

The PCS Control Cabinets were provided as high-quality instrumentat!on for use in non-safety related application. The power for these Control Cabinets is supplied from both a battery-backed auxiliary control power. <

bus and a reliable regulated AC bus. See the McGuire FSAR Chapter 8 for a description of the McGuire power systems. Output signals to Indication and/or recording equipment is provided through output isolation devices.

Due to the above-listed considerations, Duke concludes that the instru-mentation in the PCS control cabinets meets the intent of the RG 197 Rev. 2 definition of Category 2 Instrumentation.

Radiation Monitor Hardware Each instrument loop of the McGuire Radiation Monitoring System has an in-dividual power supply which is powered from a reliable battery-backed auxiliary control bus. All process radiation monitors are continuously indicated and recorded in the main control room, with additional hardware for trending capability. All area radiation monitors are continuously in-dicated in the main control room, with monitors pertinent to station operation providing inputs to the operator-aid computer.

Due to the above considerations, Duke concludes that the instrumentation in the Radiation Monitoring System meets the intent of the RG 1.97 Rev. 2 defini tion of Category 2 instrumentation. Refer to McGuire FSAR, Chapter 11, " Radioactive Waste Management, " Chapter 12 " Radiation Protection,"

and " Duke Power Company, McGuire Nuclear Station, Response to TMI Concerns" for further discussion of this system.

Incore Thermocouples Refer to Appendix 2.

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APPENDIX 1 Subcooling Monitor The McGuire Subcooling Monitor meets the requirements for Category 2 equipment, as called for in RG 1 97 Rev. 2. The subcooling margin is continuously monitored and is powered by a high reliability battery-backed power source (computer has a dedicated inverter). The display is a CRT in the main control room, with a " quick" call-up featJre as well as normal graphic display. The " quick" call-up utilizes one button for display access. The functional speci f ications for the Subcooling Monitor are given on page 11-9 of " Duke Power Company, McGuire Nuclear Station, Response to TMI Concerns."

This response is in answer to questions pertaining to NUREG-0737, item 11.F.2.

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AITINIllX 7

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- Incore Thermocouples 4 The following analysis is In response to NUREG-0737, i tem II .F.2 Attachment I,

" Design and quali fication Cri teria for Press,urized-Wa ter Reactor incore Thermocouples." Points are-addressed in the same order and format as -

followed in Attachment I of II .F.2:

(I) The McGuire incore Thermocouples are located at the core exit for cach quadrant, and in conjunction wi th core inlet RTD data, are sufficient to provide indication of radial distribution of the 1 coolant enthalpy rise across representative sections of the core. L There are a total of 65 core-exi t thermocouples. ,

(2) The primary operator display is on the operator-aid computer CRT. This system has the following capabilitics:

(a) A spatially oriented core map is available on demand which

indicates the temperature at each core exit thermocouple location. This map can be displayed or printed on demand.

(b) An example of the McGuire selective readings is an on-demand tabular listing of all instantaneous incore thermocouple values.

This listing can be displayed or printed on demand.

(c) Di rect readou t of average and instantaneous values, as well as hard-copy capabilities, are provided for all thermocouple I tempe ra tu re s . The range is 0-2300* F.

] (d) Trend capabili ty showing temperature-time histories is designed into the system. Strip chart recorder points are available .to assign to any incore thermocouples on demand. In addition, a point-value trend printout is available on the control room typer.

(e) Alarm capabili ty is provided in conjunction wi th the Subcooling Moni tor, which uses the average, of all valid thermocouple ,

readings in its calculations and alarms when the value drops '

below the setpoint.

(f) The CRT displays are designed for rapid operator access and ease of viewing da ta , in addition, the incore program has a i validi ty-check comparison which reduces the probabili ty of accessing false readings.

(3) A back-up analog readout is provided wi th **no capabili ty of selective

, reading of any thermocouples in the system. The range will be extended

! to 2300' F. as di scussed in a telephone conversation with the NRC -

on March 24, 1981 and described in a letter of March 25, 1981 by Mr.

W. O. Parker to Mr. H. R. Ocnton.

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(4) The displays for Incore thermocouples take the human-factors criteria listed into account. The same display is utilized for both normal and abnormal plant conditions. The validity-check feature only allows valid readings to be displayed. In addition the operators are trained in the use of tht; type of graphic display.

(5) Duke has reviewed the feasibility of upgrading the qualification of the existing McGuire incore thermocouples. This review has revealed that thermocauples which meet all of the NUREG 0737 requirements are not available at this time. However, Duke will continue to pursue the de-velopment of such incore thermocouples.

(6) Isolation between the primary and backup channels is implemented in the form of electrical switches.. The primary and back-up display channels are powered by a highly reliable battery-backed power source.

(7) (8) (9) Theexistingincorethermocoupleshstemisaverysimpleset of hardware which should, by virtue of its very simplicity, be a highly reliable and accessible system. The reliable and accessible normal CRT display and the existence of a backup display are additional factors which contribute to the overall system reliability.

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3 t VARIABLE RG 1 97 ' DUKE RG 1.97 'tiUMBER OF ' tt0TES rat 1GE rat!GE CATEGORY CHAtli:E'_ S Reactor Vessel Core bot tom to Core bottom 1 2 channels level RV top to RV top 2 indicated (1) i recorded (R) 2 compute r points (CP)

Containment Sump Level 0 to 600,000 0-1,000,000 1 2 channels gal, level gal. level 2 I IR 2 CP Containment Hydrogen 0 to 30'/. O to 307, 1 2 channels Concentration 2 I IR

' 2 CP 100 to 10 7R/hr 0 0 Containment High Range 10 to 10 R/hi 1 2 channels Radiation Monitor 2I I R 2 CP Containment isolation Closed-!!ot Closed-flot i 1 channel Switch lights, monitor lights Valve Position Closed Closed 1 I I CP Prese .ri ze r t. eve l Top to bottom 0-1007, 1 3 channels PCS Protection Cabine t 3I 3 CP Sel. Rec.

Steam Generator Wide Tube Sheets 0-1007, 1 1 channel per SG PCS Protect ior. Cabi ne t Range level to Separators 1 Rec.

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, VARIABLE RG 1 97 DUKE RG 1 97 nut 1BER OF NOTES RANGE RAf1G E CATEGORY CHANNELS Neutron Flux 10 107X 100 - 106 cps 1 2 Source Range Power 10-II 3 A 2 Intermediate 0- 12UX power la Power Range

Selectable Rec.

capability incore Instrumentation 200*F-2300*F 200*F-2300*F I Computer Display (core-Exit Thermocouples) and Printout.

i Backup is an analog indicator.

Auxi liary Feedwate r Guaran- Plant Speci fi c  ; Guaranteed so'u rce for Aux..ree -

teed Source water is provided by the '.uc ~ ea 4

Service Water Syster. See Mc3_:

o FSAR, Chapte r 9, " Aux iiia. y Systems" for furt* er i nfc ea:: c-NC Pressure O to 3000 psig. O to 3000 psig I 2 channels PCS Protect ion Ca':i ne:

21 iR I CP NC Hot Leg Temp. 50 to 750* F 0 to.700* F I I channel per loop FCS Protection Ca:ine:

IR I CP

NC Cold Leg Temp. 50 to 750* F 0 to 700* F 1 1 channel per loop PCS Protect ion Ca

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1R I CP NC Radioactivity 5x10-I -3x10 10-2 -103 uC i /m i 1 i channel uCi/gm t I ~

I CP l Selectable Rec.

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pat 4GE RG 1.97 't1 UMBER OF tt0TES RAtJG E CATEGORY C HANilELS Steam Release Rad. 10'I to 103 uci/c Monitoring 102 tol03R/hr 2 I channel per steamlIne Loca tion wil l determine range in uCi/cc.

I I Total steam release program is being developed.

RHR Heat Exchanger 32-350*F Outlet Tempe ra t u re 50 f00*F 4

2 2 channels (1 per PCS Control Cabinet heat exchanger) 2R fil Accumulator Tank Level 10-90X Z_ .

0-100% 2 2 channels per PCS Control Cabinet Y---==

(0- Ilt i tMD) Accumulator 2 I per Accum.

M Containmbnt Spray F 6 O 0-110Z of design 0 f00 gpm4 2

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2 channels (1 per PCS Cont rol Cab ine t M header)'

i 2I Q Volume Cont rol Tank Level Top to bottom

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Residual Heat Removal Floss 0 to 1107 Desigr. O'to 2500 gpm 2 O to 5000 gpm 2 channels (1 ea. Comauter point i s corron return (3000 gpm per heat exchanger) flow.

2 i design) PCS Control Cahiret I CP Boric Acid Charging Flow 0 to 1I0/ design 0 10 gpm4 2 1 channel PCS Cont rol Cab ir.i t (35 gpm design) l I

! I CP lR High Pressure inj. Flow ] to IIO7 design 0 to 1000 gpm 2 1 channel. *

(boron inj.,

i I PCS Cor t rol Cab i r.e t 550 gpm designi i CP O to 800 gpm 2 2 channels (I per (sa fe t y i nj . , header)

PCS Control Cabi..et 650 gpm designi 21 4

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VA R I ABLE RG 1.97 DU KE RG 1.97 i iluttBER OF tt0TES RAtlG E RAtlG E CATEGORY CHAtitlELS Containment Wide Range -5 to 60 psig -5 to 60 psig I 2 channels 1

Pressure 1I 1R 2 CP Accumulator Isol. Open-Closed Open-Closed 2 1 chan-,el per viv. Annunciator, Monitor light Valve Pos i t i on 2I 1 CP Pressurizer PORV's Open-Closed Open-Closed 2 1 channel per viv.

I 2 l 1 CP Pressurizer Code Relief Open-Closed Open-Closed 2 I channel per viv. Annunciator Valves

• 2 i Low Pressure inj . Flow 0 to 1107 design 0 to 2500 gpm 2 2 channels ( l ea . Computer Point is ccmmon return (RHR Fic.9) O to 5000 gpm per header) flow (3000 gpm desig i) 21 PCS Control Cabinet I CP Ma i n S t ean Fl ow 0 to 1107 design 0-1207 2 2 channels (per SG) PCS Control Cab inet 21 2 CP CVCS Hakep-up Flow 0 to 110/ design 0 to 200 gpm 2 Ichannel PCS Cont rol Cab ine t in (100 gpm i I design)

CVCS Letdown Flow Out 0 to 1107 design 0 to 200 gpm 2 1 channel PCS Control Cabinet (120 gpm design. I I Degree of Subcooling 200*F subcooled calculated 2. I channel Calculations done continuously b3 to 35' super- value I graphic OAC. Displayed on demand.

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VARlABLE RG 1.97 DUKE RG I.97 i ilVMBER OF  !!0TES RAtlGE rat 4G E CATEGORY CilAtlflELS Emergency Vent Damper Jpen-Closed (' pen-Closed 2 I channel per Switch indicator and/or Position damper (a t least) status light.

Active dampers and isolation valves which are ac:uated u-Yc accident conditions whoce failure could resul: in a radioactive release to atmos: :

are indicated. Also, Contro' Room isolati on is i-dicated.

Pressurizer Relief Tank lop to bottom 0-100% 2 I channel FCS Control Cabinet Level (0-100 INWD) 1 I I CP

-6 -2 Containment Release Gas 10 to 10 N/A 2 Moni tor is rot requ: red, ra'c_.

Rad. Monitor uCl/cc is through Unit Ver:.

til Accumulator Tank Pressure O to 750 psig 0 to 750 psig 2 2 channels per tank PCS Contro! Cabine: === I 8i <

Pressurizer lleater Status current Bkr. status 2 I channel per Z

contactor statu- device 13I!

1 I ea. gg 1 C P ea . Q SG Pressure O to 20'/ above 0 to 1300 psig 2 3 channels per loop PCS Protec: ion Ca: inet g=gwa low safety valve (0 to 10% 3 1/ loop g===g set point 3 CP/ loop above low safet) g= mag valve set point, gg Unit Vent Radiation 10-6to 10b uti/cc 10-6 to 103 2 Monitoring for 0 to 110/, 100 to uClfcc 10 R/br vent flow e

VARIABLE RG l.97 DUKE RG 1.97 t! UMBER OF NOTES PAtJGE PAtJG E CATEGORY C HAtitiELS Other Release Point 10-6 to 10 2 10-6 to 10-I 2 I channel per devica Radiation Monitoring uCl/cc uCi/cc I I/ device (Contaminated Materials Whse. and Interim Radwaste Faci l i t y)

Containment Heat Removal plant speci fic N/A 2 by AHU Containment Sump Wa ter 50 to 250' F none 2 Variable is nc: used for o: era::

Temperature action nor necessary for accide-analysis.

Area Radj at ion Moni tori ng 10-I to 10 bR/h IO-I to 10b mR 'h r 2 1 channel per device 1 1/ device i

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Auxiliary Feedwa te r Flow 0 to l107, design 0-400 gpn 2 4 channels ( l per SG) -

4i RWST Level top to bottom 0 to 160" WD 2 3 channels 3I 3 CP 160 to 500" WD 2 I channel i I I CP Component Cool ing Va te r 32 to 200* F So to 150' F 2 I channel (per Temperature to ESF header) 1 CP Component' Cooli ng Va te r 0 to l107 design 0 to 6000 gpm 2 1 channel ( per flow to ESF (5000 gpm desigi ) header)

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. VARIABLE RG l.97 DUKE RG l.97 '

NUMBER OF NOTES RANGE RANG E CATEGORY C HANNEL S i

Containment Atmosphere 40 to 400*F 0 to 300* F 2 8 channels (4 i n j Temperature upper Contai nment i and 4 in lower l con ta i nment )

8 CP l Sa f e t y Powe r S t a tus Current, voltage status and 2 All safety poaer systems are i

a l a rms alarmed in the control roon l tc indicate abnornal ooeration.

I Local indication is provided for analyzing sys tem t rouble.

High Level Radaaste Tank Top to bottom 0-100% 2 I channel Local indicator and High Leve; Level , 1 CP Ar.nunciator also available.

Boron Concentration 0-6000 ppm 0-5000 ppm 3 1 channel .

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Pressuri zer Relief 50 to 750* F 50 to 300* F 3 1 channel F S Control ebinet Tank Tempera ture  ! I i

l Condensate. Storage Tank Plant speci fi c 0 to 100% 3 1 channel A nunciator a 'arn when tar'< -

l Level (o to 12 f t .) 1I is not full.

Radioactive Gas Holdup 0 to 150Z design 0 to 150 psig 3 I channel Tank Press (100 psig desig n) 1 CP HC Pump Status Motor Current 0 to 800A 3 1 channel per pump 1 l l

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