ML18150A376
| ML18150A376 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/11/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Rubenstein L Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 86-273, NUDOCS 8606170015 | |
| Download: ML18150A376 (4) | |
Text
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e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWABT VICE PRESIDENT NUCLEAR OPERATIONS June 11, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation Attn:
Mr. Lester S. Rubenstein, Director PWR Project Directorate No. 2 Division of PWR Licensing-A U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT NOS. 1 AND 2 CONFORMANCE WITH REGULATORY GUIDE 1.97 Serial No.
NO/ETS/amg Docket Nos.
License Nos.
CATEGORY RECLASSIFICATION OF BORIC ACID CHARGING FLOW 86-273 50-280 50-281 DPR-32 DPR-37 On January 31, 1984 we submitted a letter (Serial No. 053) identifying modifications to comply with Regulatory Guide (RG) 1.97.
One of these modifications was Variable D-6, Boric Acid Charging Flow, for which we committed to replace the existing flow transmitter with an environmentally qualified flow transmitter.
Subsequently, on February 21, 1984 (Serial No.
088) we committed to implement the previously identified modifications for 20 variables, including D-6, by the first refueling after July 1985.
After further investigation and discussion with our Architect Engineer, we have determined that Variable Item D-6 should be reclassified from Category 2 to Category 3.
Correspondingly, no modification of the boric acid charging flow transmitters is currently planned.
The basis for our
. reclassification is provided in the attachment.
Two other R.G. 1.97 variables also identified in our February 21, 1984 letter have recently been the subject of a schedular extension request dated April 26, 1986 (Serial No.86-191).
Reclassification of Variable Item D-6 does not impact that extension request.
However, it does modify our commitment associated with our Confirmatory Order on Emergency Response capabilities, dated June 12, 1984.
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PDR ADOCK 05000280 p
e VIRGINIA. ELECTRIC AND POWER COMPANY TO If you have any questions or need additional information, please contact us.
Very truly yours, W. L. Stewart Attachment cc:
Dr. J. Nelson Grace Regional Administrator NRC Region II NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A
e REG. GUIDE 1.97 VARIABLE D6 BORIC ACID CHARGING FLOW INDICATION RECLASSIFICATION TO CATEGORY 3 SURRY POWER STATION UNITS 1 & 2 We have reassessed our position on Boric Acid Charging Flow Transmitters and now consider that the present transmitters, although not environmentally qualified, are adequate given their function.
Consistent with the definition of Category 2 and 3 variables, we have reclassified this item to Category 3 based on the following:
- 1. Boric acid can be supplied directly to the charging pump suction in order to compensate for reactivity changes.
The associated flow transmitters are not required by the operator to initiate planned manual actions or to mitigate the consequences of a design basis accident.
The flow transmitter is used in normal and abnormal operations to estimate boric acid addition to the core.
Verification of accomplishment of the safety function (i.e. reactivity control) and hence the performance of boration is more directly monitored by measurement of neutron flux which is to be upgraded to a Category 1 instrument.
- 2.
The boric acid flow transmitters are not used to detect high energy line breaks (HELE).
The temperature effects of a HELE in the Auxiliary Building are discussed in the FSAR in Appendix 14B.
Sources of high temperture conditions are identified and methods of mitigation are discussed.
Protection from a break in the Chemical and Volume Control Systems includes the use of existing instrumentation to detect the break.
However, the boric acid bypass is not identified as a high energy line.
Therefore, the flow transmitters will not be used to detect the source of a HELE.
- 3.
The boric acid flow transmitters are located in the auxiliary building el. 13 ft in an area which is considered to have a harsh environment (EZD zone AB-13A) during accidents.
However, the flow transmitters are not required to mitigate the consequences of design basis events, therefore, they are not required to operate in the harsh environment conditions.
- 4.
Preventive maintenance and calibration is performed on the flow transmitters (FT-1110/2110) each refueling cycle (18 month cycle) to ensure proper operation and availability.
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- 5.
To date, we have not identified a qualified transmitter which could be used in our specific application for this variable.
The available transmitters are either suitable for use in boric acid and not qualified for harsh environments or qualified for radiation harsh environments and not suitable for use in boric acid solutions.
Our current instrument was chosen for its compatability in boric acid solutions.