ML101130262
| ML101130262 | |
| Person / Time | |
|---|---|
| Site: | Boiling Water Reactor Owners Group |
| Issue date: | 05/14/2010 |
| From: | Huang T, Lavie S, Marcus B Division of Policy and Rulemaking |
| To: | BWR Owners Group, Exelon Generation Co |
| G. Bacuta | |
| References | |
| NEDO-33349, Rev 1, RG-1.097, Rev 4 | |
| Download: ML101130262 (62) | |
Text
ENCLOSURE 1
DRAFT SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2
3 TOPICAL REPORT NEDO-33349, REVISION 1 4
5 ABOILING WATER REACTOR APPLICATION TO REGULATORY GUIDE 1.97, REVISION 4" 6
7 BOILING WATER REACTOR OWNERS GROUP 8
9 PROJECT NO. 691 10 11 12
1.0 INTRODUCTION AND BACKGROUND
13 14 By letter dated August 31, 2007 (Reference 1), the Boiling Water Reactor Owners Group 15 (BWROG) submitted licensing topical report (LTR) NEDO-33349, Revision 1, ABoiling Water 16 Reactor (BWR) Application to Regulatory Guide 1.97, Revision 4,@ for Nuclear Regulatory 17 Commission (NRC) staff review. The LTR provides the technical justification for the use of 18 Regulatory Guide (RG) 1.97 Revision 4, Criteria for Accident Monitoring Instrumentation for 19 Nuclear Power Plants, issued June 2006 (Reference 2), for currently licensed boiling water 20 reactors (BWRs). By letters dated October 31, 2008 (Reference 3) and September 14, 2009 21 (Reference 4), the BWROG submitted supplemental material in response to the NRC staff=s 22 request for additional information.
23 24 Licensees of plants with operating licenses issued before June 2006 committed to follow either 25 Revision 2 or 3 of RG 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to 26 Assess Plant and Environs Conditions During and Following an Accident, (References 5 and 27 6). Both Revisions 2 and 3 of RG 1.97 prescribe a detailed list of variables to monitor and 28 specify comprehensive design and qualification criteria to be met by the instrumentation 29 monitoring variable. Revision 4 of RG 1.97 endorses with exceptions and clarifications, Institute 30 of Electrical and Electronics Engineers (IEEE) Std. 497-2002, IEEE Standard Criteria for 31 Accident Monitoring Instrumentation for Nuclear Power Generating Stations, (Reference 7).
32 IEEE Std. 497-2002 establishes flexible, performance-based criteria for the selection, 33 performance, design, qualification, display, and quality assurance of accident monitoring 34 variables. Licensees of plants with operating licenses issued before June 2006 may convert to 35 the criteria of RG 1.97, Revision 4, or use those criteria when performing modifications that do 36 not involve a conversion. The guidance in Regulatory Position 1 of RG 1.97, Revision 4, should 37 be followed in these cases.
38 39 Revisions 2 and 3 of RG 1.97 group the monitored variables into five types. Each type 40 separates the variables based on the general purpose (or function) of the variables. Individual 41 variables may be monitored for multiple functions and, therefore, belong to multiple types. Type 42 A variables supply the primary information required to permit the control room operators to take 43 specific manually controlled actions for which no automatic control is provided and that are 44 required for safety systems to accomplish their safety function for design basis events. Type B 45 variables indicate whether plant safety functions are being accomplished. Type C variables 46 provide information indicating the potential for being breached or the actual breach of the 1
barriers to fission product releases. Type D variables indicate the operation of individual safety 2
systems and other systems important to safety. Type E variables provide information for use in 3
determining the magnitude of a release of radioactive materials and continual assessment of 4
such releases.
5 6
Revisions 2 and 3 of RG 1.97 present design and qualification criteria separated into three 7
categories that provide a graded approach depending on the importance to safety of the 8
measurement of a specific variable. Category 1 provides for environmental and seismic 9
qualification, redundancy, continuous real-time display, and on-site Class 1E power sources.
10 11 Category 2 provides for environmental qualification but is less stringent in that it does not 12 include seismic qualification, redundancy, or continuous display, and only a highly-reliable 13 power source is needed. Category 3 provides for high-quality commercial-grade equipment and 14 recommends only offsite power.
15 16 This mixture of type and category results in the need for several instruments to meet the criteria 17 for multiple type and category combinations. In cases where a single variable monitors multiple 18 functions, some licensees have provided one set of instrumentation that meets the highest 19 category criteria of the multiple functions of that variable.
20 21 Since the criteria in Revisions 2 and 3 of RG 1.97 are similar, this document will refer to both 22 revisions as RG 1.97, Revision 3, unless differences in criteria between the two need to be 23 noted. In those cases, this document will refer specifically to Revision 2 or Revision 3.
24 25 RG 1.97, Revision 4, endorses with exceptions and clarifications, IEEE Std. 497-2002, which 26 classifies accident monitoring variables into Types A, B, C, D, or E. The selection criteria in 27 IEEE Std. 497-2002 are as follows:
28 29 Type A variables are those variables that provide the primary information required to permit 30 the control room operating staff to (a) take specific planned manually-controlled actions for 31 which no automatic control is provided and that are required for safety systems to perform 32 their safety-related functions as assumed in the plant accident analysis licensing basis, and 33 (b) take specific planned manually-controlled actions for which no automatic control is 34 provided and that are required to mitigate the consequences of an anticipated operational 35 occurrence.
36 37 Type B variables are those variables that provide primary information to the control room 38 operators to assess the plant safety functions.
39 40 Type C variables are those variables that provide primary information to the control room 41 operators to indicate the potential for breach or the actual breach of the fission product 42 barriers including extended ranges.
43 44 Type D variables are those variables that are required in procedures and licensing basis 45 documents to (a) indicate the performance of those safety systems and auxiliary supporting 46 features necessary for the mitigation of design basis events, (b) indicate the performance of 47 other systems necessary to achieve and maintain a safe shutdown condition, and (c) verify 48 safety system status.
49 Field Code Changed Type E variables are those variables required for use in determining the magnitude of the 1
release of radioactive materials and continually assessing such releases.
2 3
IEEE Std. 497-2002 does not use the RG 1.97, Revision 3, approach of establishing design and 4
qualification categories. Instead, the design and qualification of each variable are based on 5
functional need. The net result is essentially the same as the RG 1.97, Revision 3, 6
categorization, with minor exceptions as follows:
7 8
The design and qualification criteria for Type A in RG 1.97, Revision 4, is equivalent to 9
Category 1 in RG 1.97, Revision 3; however, (1) environmental qualification is not required if 10 the instrument performs its required accident monitoring function in an environment which is 11 not harsh for the design basis event the instrument is needed for and (2) seismic 12 qualification is not required if the instrument's accident monitoring function is not required 13 following a seismic event.
14 15 The design and qualification criteria for Types B and C in RG 1.97, Revision 4, are 16 equivalent to Category 1 in RG 1.97, Revision 3. Variables that are classified as Type B or 17 Type C, Category 2 or 3 do not need to meet the Type B or Type C design and qualification 18 criteria of RG 1.97, Revision 4.
19 20 The design and qualification criteria for Type D in RG 1.97, Revision 4, is equivalent to 21 Category 2 in RG 1.97, Revision 3; however, (1) environmental qualification is not required if 22 the instrument performs its required accident monitoring function in an environment which is 23 not harsh; (2) seismic qualification is not required if the instrument's accident monitoring 24 function is not required following a seismic event; and (3) if an interruption in power is 25 tolerable a continuously available source of power is not required. Variables that were 26 classified as Type D, Category 3 do not need to meet the Type D design and qualification 27 criteria of RG 1.97, Revision 4.
28 29 The design and qualification criteria for Type E instrumentation in RG 1.97, Revision 4, are 30 equivalent to Category 3 in RG 1.97, Revision 3. However, if an interruption of power is not 31 tolerable, a continuously available source of power is required.
32 33 Note: Instruments classified as more than one type should either meet the more limiting 34 criteria or separate instruments can be provided for each type.
35 36 Although not specifically stated in IEEE Std. 497-2002, the intent of the IEEE working group was 37 that RG 1.97, Revision 3, Type D, Category 1 variables would become IEEE Std. 497-2002 38 Type B variables (There are no RG 1.97, Revision 3, BWR Type D, Category 1 variables).
39 Additionally, RG 1.97, Revision 3, Type B and C backup and diagnostic variables would be 40 expected to become IEEE Std. 497-2002 Type D or E variables, respectively (i.e., RG 1.97, 41 Revision 3, Type B, Category 2 variables would become IEEE Std. 497-2002 Type D variables 42 and RG 1.97, Revision 3, Type C, Category 2 and 3 variables would become IEEE Std. 497-43 2002 Type E variables). Some RG 1.97, Revision 3, backup and diagnostic variables might not 44 warrant classification as IEEE Std. 497-2002 Type D or E variables, if they do not meet the 45 selection criteria for Type D or E variables.
46 47 48 49
2.0 REGULATORY EVALUATION
1 2
The primary purpose of accident monitoring instrumentation is to display plant variables that 3
provide information required by the control room operators during accident situations. This 4
information provides the necessary support for the operators to take manual actions to initiate 5
safety systems and other appropriate systems important to safety.
6 7
Criterion 13, Instrumentation and Control, of Appendix A, General Design Criteria for Nuclear 8
Power Plant, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic 9
Licensing of Production and Utilization Facilities (Reference 8) requires operating reactor 10 licensees to provide instrumentation to monitor variables and systems over their anticipated 11 ranges for accident conditions as appropriate to ensure adequate safety.
12 13 Criterion 19, Control Room, of Appendix A to 10 CFR Part 50 requires operating reactor 14 licensees to provide a control room from which actions can be taken to maintain the nuclear 15 power unit in a safe condition under accident conditions, including loss-of-coolant accidents 16 (LOCAs).
17 18 Criterion 64, Monitoring Radioactivity Releases, of Appendix A to 10 CFR Part 50 requires 19 operating reactor licensees to provide the means for monitoring the reactor containment 20 atmosphere, spaces containing components to recirculate LOCA fluids, effluent discharge 21 paths, and the plant environs for radioactivity that may be released as a result of postulated 22 accidents.
23 24 The regulation in 10 CFR 50.34(f), Additional TMI-related Requirements, requires certain 25 operating reactor licensees to provide additional instrumentation related to the findings from the 26 Three Mile Island (TMI) accident.
27 28 The regulation in 10 CFR 50.44, Combustible Gas Control for Nuclear Power Reactors, 29 requires operating reactors to meet requirements for combustible gas control and monitoring.
30 31 NUREG-0737, Clarification of TMI Action Plan Requirements, dated November 30, 1980 32 (Reference 9), provides TMI-related action items approved for implementation.
33 34 NUREG-0737, Supplement No. 1, ARequirements for Emergency Response Capability, 35 (Generic Letter No. 82-33),@ dated December 17, 1982 (Reference 10), provides additional 36 clarifications regarding NUREG-0737.
37 38 RG 1.97, Revisions 2, 3, 4, describes a method acceptable to the NRC staff for complying with 39 the Commission=s regulations to provide instrumentation for monitoring plant variables and 40 systems during and after an accident.
41 42
3.0 TECHNICAL EVALUATION
43 44 3.1 NEDO-33349 Recommendations 45 46 NEDO-33349 lists the variables that should be monitored during and after an accident in 47 accordance with RG 1.97, Revision 4. The BWROG performed an analysis to evaluate how 48 each accident monitoring function is currently being monitored. Based on the results of the 49 analysis, NEDO-33349 recommends key variables for checking the performance of each 1
accident monitoring function. This includes changes to some of the functions and function 2
changes for some variables. The recommendations also include what would be considered 3
changes in type under RG 1.97, Revision 3, for several variables. In some cases, variables are 4
recommended that differ from those recommended by RG 1.97, Revision 3. In other cases, 5
NEDO-33349 recommends that the variable recommended by RG 1.97, Revision 3, no longer 6
be considered an accident monitoring variable.
7 8
3.1.A Type A Variables 9
10 NEDO-33349 recommends that Reactor Pressure Vessel (RPV) Water Level, RPV Pressure, 11 Drywell Pressure, Suppression Pool Temperature, and Suppression Pool Water Level be 12 classified as RG 1.97, Revision 4, Type A variables for design basis events. The selection of 13 Type A variables is plant specific. Each licensee that uses NEDO-33349 should review its plant 14 design against NEDO-33349 in the selection of Type A variables. For some plants the 15 NEDO-33349 recommendation for Type A variables may not be applicable. Some plants may 16 have additional Type A variables. Other plants, may find it necessary to justify deviations for not 17 including individual Type A variables recommended by NEDO-33349.
18 19 The NRC staff accepts the NEDO-33349 recommendation that RPV Water Level, RPV 20 Pressure, Drywell Pressure, Suppression Pool Temperature, and Suppression Pool Water Level 21 to be classified as RG 1.97, Revision 4, Type A variables, with the caveat that each licensee 22 should review its plant design against NEDO-33349 in the selection of Type A variables.
23 24 3.1.B Type B Functions 25 26 RG 1.97, Revision 3, recommends that Reactivity Control, Core Cooling, Maintaining Reactor 27 Coolant System Integrity, and Maintaining Containment Integrity as the Type B plant safety 28 functions. NEDO-33349 recommends that (1) Reactivity Control, (2) Level Control, (3) Pressure 29 Control, and (4) Primary Containment Control as the Type B plant safety functions.
30 31 The change in terminology for the safety functions from RG 1.97, Revision 3, to that used in 32 NEDO-33349 is the result of naming conventions associated with the BWR Emergency 33 Procedures Guidelines (EPGs).
34 35 The RG1.97, Revision 3, Core Cooling function relates to fuel cladding barrier integrity where 36 the fuel remains intact when the water level in the reactor is maintained above a predetermined 37 level. The water level in the reactor ensures that core cooling is maintained. Therefore, the 38 NEDO-33349 Level Control function replaces the RG 1.97, Revision 3, Core Cooling function.
39 40 The reactor coolant pressure boundary provides a barrier to the release of primary coolant from 41 the reactor coolant system to the primary containment. The BWR EPG for RPV Control uses 42 pressure, level, and power control in an integrated manner to fulfill the RG 1.97, Revision 3, 43 Reactor Coolant System Integrity function. Along with other pressure instrumentation the 44 reactor coolant system pressure is maintained. Monitoring RPV pressure instrumentation 45 satisfies both the RG 1.97, Revision 3, Maintaining Reactor Coolant System Integrity function 46 and the NEDO-33349 Pressure Control function. Therefore, the NEDO-33349 Pressure Control 47 function replaces the RG 1.97, Revision 3, Maintaining Reactor Coolant System Integrity 48 function.
49 The primary containment includes isolation features that provide a barrier to the release of 1
radioactive material due to a postulated LOCA from the primary containment. RG 1.97, 2
Revision 3, refers to these features as fulfilling the Maintaining Containment Integrity function.
3 NEDO-33349 refers to these features as the Primary Containment Control function. Therefore, 4
the NEDO-33349 Primary Containment Control function replaces the RG 1.97, Revision 3, 5
Maintaining Containment Integrity function.
6 7
3.1.B.1 Type B Reactivity Control Variables 8
9 3.1.B.1.1 Neutron Flux 10 11 RG 1.97, Revision 3, recommends that Type B, Category 1 instrumentation be provided to 12 monitor Neutron Flux to provide function detection and accomplishment of mitigation of the 13 Reactivity Control function. NEDO-31558, Position on NRC Regulatory Guide 1.97, Revision 3, 14 Requirements for Post-Accident Neutron Monitoring System, issued April 1, 1988 (Reference 15 11), proposed alternate design and qualification criteria for Neutron Flux monitoring 16 instrumentation at BWR plants. In its safety evaluation dated January 13, 1993 (Reference 12),
17 the NRC staff accepted NEDO-31558 for BWR plants with applications submitted before 18 January 14, 1993. NEDO-31558 was reissued as NEDO-31558-A, March 1993 (Reference 13) 19 to incorporate the January 13, 1993 safety evaluation. NEDO-33349 recommends that Neutron 20 Flux remain an RG 1.97, Revision, 4 Type B variable with the NEDO-31558 alternate design 21 and qualification criteria. Neutron Flux also meets the criteria of an RG 1.97, Revision 4, Type 22 D variable, as it provides status information on the Reactor Protection System (RPS) and the 23 Control Rod Drive (CRD) System performance.
24 25 The NRC staff agrees with the classification of Neutron Flux as an RG 1.97, Revision 4, Type B 26 key variable, with the NEDO-31558 alternate design and qualification criteria, to provide 27 information about the accomplishment of the Reactivity Control function.
28 29 3.1.B.1.2 Control Rod Position 30 31 RG 1.97, Revision 3, recommends that Type B, Category 3 instrumentation be provided to 32 monitor Control Rod Position for verification of the Reactivity Control function. NEDO-33349 33 recommends that Control Rod Position need not be considered as an RG 1.97, Revision 4, 34 Type B variable. The justification given in NEDO-33349 is that Control Rod Position is not a key 35 variable for providing information about the accomplishment of the Reactivity Control function.
36 Control Rod Position does, however, meet the criteria of an RG 1.97, Revision 4, Type D 37 variable, as it provides status information on the RPS and the CRD System performance.
38 39 As an RG 1.97, Revision 3, Type B, Category 3 variable, Control Rod Position does not need to 40 meet the RG 1.97, Revision 4, Type B design and qualification criteria. The NRC staff agrees 41 that Control Rod Position is not a key variable for providing information about the 42 accomplishment of the Reactivity Control function and, therefore, may be reclassified as not 43 being an RG 1.97, Revision 4, Type B variable for the Reactivity Control function.
44 45 3.1.B.1.3 Reactor Coolant System Soluble Boron Concentration 46 47 RG 1.97, Revision 3, recommends that Type B, Category 3 instrumentation be provided to 48 monitor Reactor Coolant System (RCS) Soluble Boron Concentration (Grab Sample) to provide 49 verification of the Reactivity Control function. NEDO-33349 recommends that RCS Soluble 1
Boron Concentration (Grab Sample) need not be considered as an RG 1.97, Revision 4, Type B 2
variable. The justification given in NEDO-33349 is that RCS Soluble Boron Concentration (Grab 3
Sample) is not a key variable for providing information about the accomplishment of the 4
Reactivity Control function.
5 6
As an RG 1.97, Revision 3, Type B, Category 3 variable RCS Soluble Boron Concentration 7
(Grab Sample) does not need to meet the RG 1.97, Revision 4, Type B design and qualification 8
criteria. The NRC staff agrees that RCS Soluble Boron Concentration (Grab Sample) is not a 9
key variable for providing information on the accomplishment of the Reactivity Control function 10 and, therefore, may be reclassified as not being an RG 1.97, Revision 4, Type B variable for the 11 Reactivity Control function. However, this does not release licensees from meeting the 12 requirements of 10 CFR 50.34(f)(1)(viii) and NUREG-0737, Item II.B.3.
13 14 3.1.B.2 Type B Level Control Variables 15 16 3.1.B.2.1 Reactor Pressure Vessel Water Level 17 18 RG 1.97, Revision 3, recommends that Type B, Category 1 instrumentation be provided to 19 monitor RPV Water Level (Coolant Level in Reactor Vessel) to provide function detection, 20 accomplishment of mitigation, and verification of the Core Cooling function. NEDO-33349 21 recommends that RPV Water Level be classified as an RG 1.97, Revision 4, Type B variable for 22 the Level Control function. The justification given in NEDO-33349 is that RPV Water Level is 23 the same Type B variable as Coolant Level in the Reactor Vessel for monitoring the RG 1.97, 24 Revision 3, Core Cooling function. RPV Water Level is equivalent to Coolant Level in Reactor 25 Vessel and Level Control is equivalent to Core Cooling. The terminology difference is the result 26 of naming conventions associated with the BWR EPGs.
27 28 The NRC staff agrees with the classification of RPV Water Level as an RG 1.97, Revision 4, 29 Type B key variable to provide information about the accomplishment of the Level Control 30 function.
31 32 3.1.B.2.2 BWR Core Temperature 33 34 RG 1.97, Revision 3, recommends that Type B (without any category designation) 35 instrumentation be provided to monitor BWR Core Temperature (RG 1.97, Revision 3) or 36 Thermocouples (RG 1.97, Revision 2) to provide diverse indication of water level for the Core 37 Cooling function. NEDO-33349 recommends that BWR Core Temperature need not be 38 considered as an RG 1.97, Revision 4, Type B variable. The justification given in NEDO-33349 39 is that not monitoring BWR Core Temperature is a generically approved deviation.
40 41 NUREG-0737, Supplement 1, does not require the monitoring of BWR Core Temperature, 42 pending further developments and considerations. The RG 1.97, Revision 3, recommendation 43 for BWR Core Temperature monitoring has never been imposed and has not been reviewed as 44 part of compliance with RG 1.97. The NRC staff agrees that BWR Core Temperature is not a 45 key variable for providing information on the accomplishment of the Level Control function and, 46 therefore, may be reclassified as not being an RG 1.97, Revision 4, Type B variable for the 47 Level Control function.
48 49 3.1.B.3 Type B Pressure Control Variables 1
2 3.1.B.3.1 Reactor Pressure Vessel Pressure 3
4 RG 1.97, Revision 3, recommends that Type B, Category 1 instrumentation be provided to 5
monitor RPV Pressure (Reactor Coolant Pressure) to provide function detection, 6
accomplishment of mitigation, and verification of the Maintaining Reactor Coolant System 7
Integrity function. NEDO-33349 recommends that RPV Pressure remains as an RG 1.97, 8
Revision 4, Type B variable for the Pressure Control function. The justification given in 9
NEDO-33349 is that monitoring RPV Pressure satisfies both the RG 1.97, Revision 3, 10 Maintaining Reactor Coolant System Integrity function and the NEDO-33349 Pressure Control 11 function. Therefore, the NEDO-33349 Pressure Control function replaces the RG 1.97, 12 Revision 3, Maintaining Reactor Coolant System Integrity function.
13 14 The NRC staff agrees with the classification of RPV Pressure as an RG 1.97, Revision 4, 15 Type B key variable to provide information on the accomplishment of the Pressure Control 16 function.
17 18 3.1.B.3.2 Drywell Pressure 19 20 RG 1.97, Revision 3, recommends that Type B, Category 1 instrumentation be provided to 21 monitor Drywell Pressure to provide function detection, accomplishment of mitigation, and 22 verification of the Maintaining Reactor Coolant System Integrity function. NEDO-33349 23 recommends that Drywell Pressure need not be considered as an RG 1.97, Revision 4, Type B 24 variable for the Pressure Control function. The justification given in NEDO-33349 is that the 25 Reactor Control EPGs include RPV Pressure as the key variable for providing information on 26 the accomplishment of the Pressure Control function. Drywell Pressure serves as a key 27 variable for other RG 1.97, Revision 4, Type B functions.
28 29 The NRC staff agrees that Drywell Pressure is not a key variable for providing information on 30 the accomplishment of the Pressure Control function and, therefore, may be reclassified as not 31 being an RG 1.97, Revision 4, Type B variable for the Pressure Control function.
32 33 3.1.B.3.3 Drywell Sump Level 34 35 RG 1.97, Revision 3, recommends that Type B, Category 1 instrumentation be provided to 36 monitor Drywell Sump Level to provide function detection, accomplishment of mitigation, and 37 verification of the Maintaining Reactor Coolant System Integrity function. NEDO-33349 38 recommends that Drywell Sump Level need not be considered as an RG 1.97, Revision 4, 39 Type B variable. The justification given in NEDO-33349 is that Drywell Sump Level is not relied 40 on in the safety analysis or the EPGs for small or large leaks.
41 42 The NRC staff agrees that Drywell Sump Level is not a key variable for providing information on 43 the accomplishment of the Pressure Control function and, therefore, may be reclassified as not 44 being an RG 1.97, Revision 4, Type B variable for the Pressure Control function.
45 46 47 48 49 3.1.B.4 Type B Primary Containment Control Variables 1
2 3.1.B.4.1 Drywell Pressure/Containment Pressure 3
4 RG 1.97, Revision 3, recommends that Type B, Category 1 instrumentation be provided to 5
monitor Primary Containment Pressure to provide function detection, accomplishment of 6
mitigation, and verification of the Maintaining Containment Integrity function. NEDO-33349 7
recommends that Drywell Pressure/Containment Pressure be classified as an RG 1.97, 8
Revision 4, Type B variable for the Primary Containment Control function. The justification 9
given in NEDO-33349 is that Drywell Pressure and Containment Pressure are essentially the 10 same instruments for BWR Mark I and II containments, and the two terms are used 11 interchangeably. In Mark III containments, the Drywell Pressure and Containment Pressure 12 instruments have only minor differences in their readings. The EPGs use Drywell Pressure.
13 14 The NRC staff agrees with the classification of Drywell Pressure/Containment Pressure as an 15 RG 1.97, Revision 4, Type B key variable to provide information on the accomplishment of the 16 Primary Containment Control function.
17 18 3.1.B.4.2 Suppression Pool Temperature 19 20 NEDO-33349 recommends that Suppression Pool Temperature be classified as an RG 1.97, 21 Revision 4, Type B variable to provide information on the Primary Containment Control function.
22 The justification given in NEDO-33349 is that Suppression Pool Temperature is an EOP entry 23 condition for the Primary Containment Control function. Suppression Pool Temperature is 24 monitored and controlled to protect equipment in the primary containment and to ensure 25 containment integrity for the duration of an accident.
26 27 The NRC staff agrees with the classification of Suppression Pool Temperature as an RG 1.97, 28 Revision 4, Type B key variable to provide information on the accomplishment of the Primary 29 Containment Control function.
30 31 3.1.B.4.3 Suppression Pool Water Level 32 33 NEDO-33349 recommends that Suppression Pool Water Level be classified as an RG 1.97, 34 Revision 4, Type B variable to provide information on the Primary Containment Control function.
35 The justification given in NEDO-33349 is that Suppression Pool Water Level is an EOP entry 36 condition. Suppression Pool Water Level is monitored and controlled to ensure adequate 37 quench volume to absorb heat capacity associated with emergency depressurization, provide 38 reactor vessel makeup via Emergency Core Cooling Systems (ECCS), and minimize hydraulic-39 mechanical loading of equipment and structures located in the primary containment and/or the 40 suppression chamber.
41 42 The NRC staff agrees with the classification of Suppression Pool Water Level as an RG 1.97, 43 Revision 4, Type B key variable to provide information on the accomplishment of the Primary 44 Containment Control function.
45 46 47 48 49 3.1.B.4.4 Primary Containment Isolation Valve Position 1
2 RG 1.97, Revision 3, recommends that Type B, Category 1 instrumentation be provided to 3
monitor Primary Containment Isolation Valve (CIV) Position to provide information on the 4
accomplishment of mitigation of the Maintaining Containment Integrity function. NEDO-33349 5
recommends that CIV Position be reclassified as an RG 1.97, Revision 4, Type D variable. The 6
justification given in NEDO-33349 is that Type B variables provide information to plant operators 7
for assessing the execution of plant safety functions. The BWR Type B Primary Containment 8
Control function variables are Drywell Pressure, Suppression Pool Temperature, and 9
Suppression Pool Water Level. CIV Position is not relied on in the safety analysis or in BWR 10 EPGs. CIV Position does, however, meet the criteria of an RG 1.97, Revision 4, Type D 11 variable, as it provides information on the status of CIV system performance.
12 13 The NRC staff agrees that CIV Position is not a key variable for providing information on the 14 accomplishment of the Primary Containment Control function and, therefore, may be 15 reclassified as not being an RG 1.97, Revision 4, Type B variable for the Primary Containment 16 Control function.
17 18 3.1.C Type C Fission Product Barriers 19 20 RG 1.97, Revision 3, recommends that Fuel Cladding, Reactor Coolant Pressure Boundary, and 21 Containment are the Type C fission product barriers. NEDO-33349 recommends that (1) Fuel 22 Cladding, (2) Reactor Coolant Pressure Boundary, and (3) Primary Containment be the RG 23 1.97, Revision 4, Type C fission product barriers. These fission product barriers are the same, 24 as the terminology changed from Containment fission product barrier in RG 1.97, Revision 3, 25 to Primary Containment fission product barrier in NEDO-33349, as a result of the naming 26 conventions associated with the BWR EPGs.
27 28 3.1.C.1 Type C Fuel Cladding Variables 29 30 3.1.C.1.1 Reactor Pressure Vessel Water Level 31 32 NEDO-33349 recommends that RPV Water Level be classified as an RG 1.97, Revision 4, Type 33 C variable to provide information on the Fuel Cladding fission product barrier. The justification 34 given in NEDO-33349 is that RPV Water Level is the parameter that most directly indicates the 35 integrity of the fuel cladding fission product barrier. The integrity of the fuel cladding barrier is 36 maintained when the core remains adequately cooled by water in the reactor. A breach of the 37 fuel cladding barrier is assumed when adequate core cooling cannot be restored or has not 38 been maintained. RPV Water Level is the most directly indicative parameter in determining 39 adequate core cooling effectiveness. Other plant specific instrumentation is available to 40 determine if core damage has occurred and the magnitude of the damage. This other 41 instrumentation does not need to be classified as RG 1.97, Revision 4, Type C instrumentation.
42 43 The NRC staff agrees with the classification of RPV Water Level as an RG 1.97, Revision 4, 44 Type C key variable to provide information about the integrity of the Fuel Cladding fission 45 product barrier. However, since a decrease in RPV Water Level is only a precursor to fuel 46 damage, each licensee should identify plant specific backup instrumentation to provide 47 information to determine if core damage has occurred. This plant specific backup 48 instrumentation does not need to meet the RG 1.97, Revision 4, Type C design and qualification 1
criteria.
2 3
3.1.C.1.2 Radioactivity Concentration or Radiation Level in Circulating Primary Coolant 4
5 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 6
monitor Radioactivity Concentration or Radiation Level in Circulating Primary Coolant to detect 7
a breach in the Fuel Cladding fission product barrier. NEDO-33349 recommends that 8
Radioactivity Concentration or Radiation Level in Circulating Primary Coolant need not be 9
considered as an RG 1.97, Revision 4, Type C variable. The justification given in NEDO-33349 10 is that not monitoring Radioactivity Concentration or Radiation Level in Circulating Primary 11 Coolant is a generically approved deviation.
12 13 The RG 1.97, Revision 3, recommendation for Radioactivity Concentration or Radiation Level in 14 Circulating Primary Coolant has never been imposed and has not been reviewed as part of 15 compliance with RG 1.97. The NRC staff agrees that Radioactivity Concentration or Radiation 16 Level in Circulating Primary Coolant is not a key variable for providing information on the 17 integrity of the Fuel Cladding fission product barrier and, therefore, may be reclassified as not 18 being an RG 1.97, Revision 4, Type C variable for the Fuel Cladding fission product barrier.
19 20 3.1.C.1.3 Analysis of Primary Coolant 21 22 RG 1.97, Revision 3, recommends that Type C, Category 3 instrumentation be provided to 23 monitor Analysis of Primary Coolant to provide detailed analysis, accomplishment of mitigation, 24 verification, and long-term surveillance of the Fuel Cladding fission product barrier.
25 NEDO-33349 recommends that Analysis of Primary Coolant need not be considered as an 26 RG 1.97, Revision 4, Type C variable. The justification given in NEDO-33349 is that not 27 monitoring the Analysis of Primary Coolant is a generically approved deviation.
28 29 The RG 1.97, Revision 3, recommendation for the Analysis of Primary Coolant has not been 30 reviewed as part of compliance with RG 1.97. The NRC staff agrees that Analysis of Primary 31 Coolant is not a key variable for providing information on the integrity of the Fuel Cladding 32 fission product barrier and, therefore, may be reclassified as not being an RG 1.97, Revision 4, 33 Type C variable for the Fuel Cladding fission product barrier. However, this does not release 34 licensees from meeting the requirements of 10 CFR 50.34(f)(1)(viii) and NUREG-0737, Item 35 II.B.3.
36 37 3.1.C.1.4 BWR Core Temperature 38 39 RG 1.97, Revision 3, recommends that Type C (without any category designation) 40 instrumentation be provided to monitor BWR Core Temperature (Revision 3) or Thermocouples 41 (Revision 2) to provide diverse indication of water level for the Fuel Cladding fission product 42 barrier. NEDO-33349 recommends that BWR Core Temperature need not be considered as an 43 RG 1.97, Revision 4, Type C variable. The justification given in NEDO-33349 is that not 44 monitoring BWR Core Temperature is a generically approved deviation.
45 46 NUREG-0737, Supplement 1, does not require the monitoring of BWR Core Temperature, 47 pending further developments and considerations. The RG 1.97, Revision 3, recommendation 48 for BWR Core Temperature monitoring has never been imposed and has not been reviewed as 49 part of compliance with RG 1.97. The NRC staff agrees that BWR Core Temperature is not a 1
key variable for providing information on the integrity of the Fuel Cladding fission product barrier 2
and, therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C variable for the 3
Fuel Cladding fission product barrier.
4 5
3.1.C.2 Type C Reactor Coolant Pressure Boundary Variables 6
7 3.1.C.2.1 Reactor Pressure Vessel Water Level 8
9 NEDO-33349 recommends that RPV Water Level be classified as an RG 1.97, Revision 4, 10 Type C variable to provide information on the Reactor Coolant Pressure Boundary fission 11 product barrier. The justification given in NEDO-33349 is that RPV Water Level is the Type C 12 variable most directly associated with the Reactor Coolant Pressure Boundary fission product 13 barrier. The control of RPV Water Level is considered a key parameter for maintaining the 14 Reactor Pressure Boundary fission product barrier.
15 16 The NRC staff agrees with the classification of RPV Water Level as an RG 1.97, Revision 4, 17 Type C key variable to provide information on the integrity of the Reactor Coolant Pressure 18 Boundary fission product barrier.
19 20 3.1.C.2.2 Reactor Pressure Vessel Pressure 21 22 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 23 monitor RPV Pressure to detect the potential for a breach or actual breach, accomplishment of 24 mitigation, and long-term surveillance of the Reactor Coolant Pressure Boundary fission product 25 barrier. NEDO-33349 recommends that RPV Pressure remains as an RG 1.97, Revision 4, 26 Type C variable for the Reactor Coolant Pressure Boundary fission product barrier. The 27 justification given in NEDO-33349 is that RPV Pressure is one of several variables needed to 28 address all potential breaches of the reactor coolant pressure boundary.
29 30 The NRC staff agrees with the classification of RPV Pressure as an RG 1.97, Revision 4, 31 Type C key variable to provide information on the integrity of the Reactor Coolant Pressure 32 Boundary fission product barrier.
33 34 3.1.C.2.3 Drywell Pressure/Containment Pressure 35 36 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 37 monitor Drywell Pressure to detect a breach and to verify the integrity of the Reactor Coolant 38 Pressure Boundary fission product barrier. NEDO-33349 recommends that Drywell Pressure 39 remains as an RG 1.97, Revision 4, Type C variable for the Reactor Coolant Pressure Boundary 40 fission product barrier. The justification given in NEDO-33349 is that Drywell Pressure is one of 41 several variables needed to address all potential breaches of the reactor coolant pressure 42 boundary. NEDO-33349 also states that Drywell Pressure and Containment Pressure are 43 essentially the same instruments for BWR Mark I and II containments, and the two terms are 44 used interchangeably. In Mark III containments, the Drywell Pressure and Containment 45 Pressure instruments have only minor differences in their readings.
46 47 The NRC staff agrees with the classification of Drywell Pressure/Containment Pressure as an 1
RG 1.97, Revision 4, Type C key variable to provide information on the integrity of the Reactor 2
Coolant Pressure Boundary fission product barrier.
3 4
3.1.C.2.4 Suppression Pool Water Level 5
6 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 7
monitor Suppression Pool Water Level to detect a breach, accomplish mitigation, verification, 8
and long-term surveillance of the Reactor Coolant Pressure Boundary fission product barrier.
9 NEDO-33349 recommends that Suppression Pool Water Level remains as an RG 1.97, 10 Revision 4, Type C variable for the Reactor Coolant Pressure Boundary fission product barrier.
11 The justification given in NEDO-33349 is that Suppression Pool Water Level is one of several 12 variables needed to address all potential breaches of the reactor coolant pressure boundary.
13 14 The NRC staff agrees with the classification of Suppression Pool Water Level as an RG 1.97, 15 Revision 4, Type C key variable to provide information on the integrity of the Reactor Coolant 16 Pressure Boundary fission product barrier.
17 18 3.1.C.2.5 Suppression Pool Temperature 19 20 NEDO-33349 recommends that Suppression Pool Temperature be classified as an RG 1.97, 21 Revision 4, Type C variable for the Reactor Coolant Pressure Boundary fission product barrier.
22 The justification given in NEDO-33349 is that Suppression Pool Temperature is one of several 23 variables needed to address all potential breaches of the reactor coolant pressure boundary.
24 25 The NRC staff agrees with the classification of Suppression Pool Temperature as an RG 1.97, 26 Revision 4, Type C key variable to provide information on the integrity of the Reactor Coolant 27 Pressure Boundary fission product barrier.
28 29 3.1.C.2.6 Primary Containment Area Radiation 30 31 RG 1.97, Revision 3, recommends that Type C, Category 3 instrumentation be provided to 32 monitor Primary Containment Area Radiation to detect a breach and verify the integrity of the 33 Reactor Coolant Pressure Boundary fission product barrier. NEDO-33349 recommends that 34 Primary Containment Area Radiation need not be classified as an RG 1.97, Revision 4, Type C 35 variable. The justification given in NEDO-33349 is that Primary Containment Area Radiation 36 may indicate radiation release from fuel cladding failure and reactor coolant pressure boundary 37 breach, but it is not a direct indicator of the integrity of the Reactor Coolant Pressure Boundary 38 fission product barrier. The variables for the BWR Type C Reactor Coolant Pressure Boundary 39 fission product barrier are RPV Water Level, RPV Pressure, Drywell Pressure/Containment 40 Pressure, Suppression Pool Water Level, and Suppression Pool Temperature. Primary 41 Containment Area Radiation does, however, meet the criteria of an RG 1.97, Revision 4, Type E 42 variable, as it provides the magnitude of release for Containment Area Radiation.
43 44 As an RG 1.97, Revision 3, Type C, Category 3 variable Primary Containment Area Radiation 45 does not need to meet the RG 1.97, Revision 4, Type C design and qualification criteria. The 46 NRC staff agrees that Primary Containment Area Radiation is not a key variable for providing 47 information on the integrity of the Reactor Coolant Pressure Boundary fission product barrier 48 and, therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C variable for the 1
Reactor Coolant Pressure Boundary fission product barrier.
2 3
3.1.C.2.7 Drywell Drain Sump Level 4
5 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 6
monitor Drywell Drain Sump Level to detect a breach, accomplishment of mitigation, verification, 7
and long-term surveillance of the Reactor Coolant Pressure Boundary fission product barrier.
8 NEDO-33349 recommends that Drywell Drain Sump Level need not be considered as an RG 9
1.97, Revision 4, Type C variable. The justification given in NEDO-33349 is that Drywell Drain 10 Sump Level is isolated when a LOCA occurs. The drywell drain sump level is not used for other 11 than normal operation to determine the potential degradation in the reactor coolant pressure 12 boundary, so that repairs can be made before failure occurs.
13 14 The NRC staff agrees that Drywell Drain Sump Level is not a key variable for providing 15 information on the integrity of the Reactor Coolant Pressure Boundary fission product barrier 16 and, therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C variable for the 17 Reactor Coolant Pressure Boundary fission product barrier.
18 19 3.1.C.3 Type C Primary Containment Variables 20 21 3.1.C.3.1 Drywell Pressure/Containment Pressure 22 23 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 24 monitor Primary Containment Pressure to detect the potential for a breach and the 25 accomplishment of mitigation of the Containment function. NEDO-33349 recommends that 26 Drywell Pressure be classified as an RG 1.97, Revision 4, Type C variable for the Primary 27 Containment fission product barrier. The justification given in NEDO-33349 is that Drywell 28 Pressure and Containment Pressure are essentially the same instruments for BWR Mark I and 29 II containments, and the two terms are used interchangeably. In Mark III containments the 30 Drywell Pressure and Containment Pressure instruments have only minor difference in their 31 readings. Drywell Pressure indication is used as the EPG entry condition which supports plant 32 mitigation strategies related to Primary Containment Control functions. Drywell Pressure is 33 used for the determination of Primary Containment integrity.
34 35 The NRC staff agrees with the classification of Drywell Pressure/Containment Pressure as an 36 RG 1.97, Revision 4, Type C key variable to provide information on the integrity of the Primary 37 Containment fission product barrier.
38 39 3.1.C.3.2 Suppression Pool Temperature 40 41 NEDO-33349 recommends that Suppression Pool Temperature be classified as an RG 1.97, 42 Revision 4, Type C variable to provide information on the Primary Containment fission product 43 barrier. The justification given in NEDO-33349 is that Suppression Pool Temperature is 44 monitored to detect conditions leading to containment breach and to verify the effectiveness of 45 ECCS action in preventing containment breach. Maintaining Suppression Pool Temperature 46 within limits is an EPG action to ensure the maintenance of the containment pressure 47 suppression function during accident conditions.
48 49 The NRC staff agrees with the classification of Suppression Pool Temperature as an RG 1.97, 1
Revision 4, Type C key variable to provide information on the integrity of the Primary 2
Containment fission product barrier.
3 4
3.1.C.3.3 Suppression Pool Water Level 5
6 NEDO-33349 recommends that Suppression Pool Water Level be classified as an RG 1.97, 7
Revision 4, Type C variable to provide information on the Primary Containment fission product 8
barrier. The justification given in NEDO-33349 is that Suppression Pool Water Level is an EPG 9
entry condition for the Primary Containment function and is monitored and controlled below 10 limits to protect equipment in the primary containment. Suppression Pool Water Level is 11 monitored and controlled to maintain containment integrity for the duration of an accident.
12 13 The NRC staff agrees with the classification of Suppression Pool Water Level as an RG 1.97, 14 Revision 4, Type C key variable to provide information on the integrity of the Primary 15 Containment fission product barrier.
16 17 3.1.C.3.4 Reactor Pressure Vessel Pressure 18 19 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 20 monitor RPV Pressure to detect the potential for breach and accomplishment of mitigation of the 21 Containment fission product barrier. NEDO-33349 recommends that RPV Pressure need not 22 be classified as an RG 1.97, Revision 4, Type C variable for the Primary Containment function.
23 The justification given in NEDO-33349 is that RPV Pressure is not a direct or indirect indicator 24 of a breach in the primary containment barrier.
25 26 The NRC staff agrees that RPV Pressure is not a key variable for providing information on the 27 integrity of the Primary Containment fission product barrier and, therefore, may be reclassified 28 as not being an RG 1.97, Revision 4, Type C variable for the Primary Containment fission 29 product barrier.
30 31 3.1.C.3.5 Containment and Drywell Hydrogen 32 33 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 34 monitor Containment and Drywell Hydrogen to detect the potential for breach and the 35 accomplishment of mitigation for the Containment fission product barrier. The regulation in 36 10 CFR 50.44 accepts the use of RG 1.97, Type C, Category 3 instrumentation to monitor 37 Containment and Drywell Hydrogen. NEDO-33349 recommends that Containment and Drywell 38 Hydrogen need not be considered as an RG 1.97, Revision 4, Type C variable. The justification 39 given in NEDO-33349 is that Containment and Drywell Hydrogen concentration requirements 40 based on 10 CFR 50.44, which indicates that monitoring of Containment and Drywell Hydrogen 41 is not needed for design basis events but is needed for beyond design basis events, do not 42 meet the criteria for inclusion as an RG 1.97, Revision 4, Type C variable.
43 44 As an RG 1.97, Revision 3, Type C, Category 3 variable, as determined by 10 CFR 50.44, 45 Containment and Drywell Hydrogen does not need to meet the RG 1.97, Revision 4, Type C 46 design and qualification criteria. The NRC staff agrees that Containment and Drywell Hydrogen 47 is not a key variable for providing information on the integrity of the Primary Containment fission 48 product barrier and, therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C 49 variable for the Primary Containment fission product barrier. However, this does not release 1
licensees from meeting the requirements of 10 CFR 50.44.
2 3
3.1.C.3.6 Containment and Drywell Oxygen 4
5 RG 1.97, Revision 3, recommends that Type C, Category 1 instrumentation be provided to 6
monitor Containment and Drywell Oxygen to detect the potential for breach and 7
accomplishment of mitigation for the Containment fission product barrier. The regulation in 8
10 CFR 50.44 accepts the use of RG 1.97, Revision 3, Type C, Category 2 instrumentation to 9
monitor Containment and Drywell Oxygen. NEDO-33349 recommends that Containment and 10 Drywell Oxygen need not be considered as an RG 1.97, Revision 4, Type C variable. The 11 justification given in NEDO-33349 is that Containment and Drywell Oxygen concentration 12 requirements based on 10 CFR 50.44, which indicates that Containment and Drywell Oxygen is 13 not needed for design basis events but is needed for beyond design basis events, do not meet 14 the criteria for inclusion as an RG 1.97, Revision 4, Type C variable.
15 16 As an RG 1.97, Revision 3, Type C, Category 2 variable, as determined by 10 CFR 50.44, 17 Containment and Drywell Oxygen does not need to meet the RG 1.97, Revision 4, Type C 18 design and qualification criteria. The NRC staff agrees that Containment and Drywell Oxygen is 19 not a key variable for providing information on the integrity of the Primary Containment fission 20 product barrier and, therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C 21 variable for the Primary Containment fission product barrier. However, this does not release 22 licensees from meeting the requirements of 10 CFR 50.44.
23 24 3.1.C.3.7 Containment Effluent Radioactivity - Noble Gases 25 26 RG 1.97, Revision 3, recommends that Type C, Category 3 instrumentation be provided to 27 monitor Containment Effluent Radioactivity - Noble Gases (from identified release points 28 including Standby Gas Treatment) to detect an actual breach, accomplishment of mitigation, 29 and verify the integrity of the Containment fission product barrier. NEDO-33349 recommends 30 that Containment Effluent Radioactivity - Noble Gases need not be considered as an RG 1.97, 31 Revision 4, Type C variable. The justification given in NEDO-33349 is that Containment 32 Effluent Radioactivity - Noble Gases may be an indicator of radiation release, but it is not a 33 direct indicator of the integrity of the primary containment barrier. RPV Pressure, Drywell 34 Pressure/Containment Pressure, Suppression Pool Temperature, and Suppression Pool Water 35 Level provide information about the Primary Containment function. Containment Effluent 36 Radioactivity - Noble Gases does, however, meet the criteria of an RG 1.97, Revision 4, Type E 37 variable, as it provides the magnitude of release for Containment Effluent Radioactivity - Noble 38 Gases.
39 40 As an RG 1.97, Revision 3, Type C, Category 3 variable Containment Effluent Radioactivity -
41 Noble Gases does not need to meet the RG 1.97, Revision 4, Type C design and qualification 42 criteria. The NRC staff agrees that Containment Effluent Radioactivity - Noble Gases is not a 43 key variable for providing information on the integrity of the Primary Containment fission product 44 barrier and, therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C variable 45 for the Primary Containment fission product barrier.
46 47 48 49 3.1.C.3.8 Effluent Radioactivity - Noble Gases 1
2 RG 1.97, Revision 3, recommends that Type C, Category 2 instrumentation be provided to 3
monitor Effluent Radioactivity - Noble Gases (from buildings or areas where penetrations and 4
hatches are located, e.g., auxiliary building, fuel handling building, and secondary containment, 5
that are in direct contact with primary containment) to indicate a breach in the Containment 6
fission product barrier. NEDO-33349 recommends that Effluent Radioactivity - Noble Gases 7
need not be considered as an RG 1.97, Revision 4, Type C variable. The justification given in 8
NEDO-33349 is that Effluent Radioactivity - Noble Gases may be an indicator of radiation 9
release, but it is not a direct indicator of the integrity of the primary containment barrier. RPV 10 Pressure, Drywell Pressure/Containment Pressure, Suppression Pool Temperature, and 11 Suppression Pool Water Level provide information about the Primary Containment function.
12 Effluent Radioactivity - Noble Gases does, however, meet the criteria of an RG 1.97, Revision 4, 13 Type E variable, as it provides the magnitude of release for Effluent Radioactivity - Noble 14 Gases.
15 16 As an RG 1.97, Revision 3, Type C, Category 2 variable Containment Effluent Radioactivity -
17 Noble Gases does not need to meet the RG 1.97, Revision 4, Type C design and qualification 18 criteria. The NRC staff agrees that Effluent Radioactivity - Noble Gases is not a key variable for 19 providing information on the integrity of the Primary Containment fission product barrier and, 20 therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C variable for the 21 Primary Containment fission product barrier.
22 23 3.1.C.3.9 Radiation Exposure Rate 24 25 RG 1.97 Revision 2 recommends that Type C, Category 2 instrumentation be provided to 26 monitor Radiation Exposure Rate (inside buildings or areas, such as the auxiliary building, fuel 27 handling building, and secondary containment, that are in direct contact with the primary 28 containment where penetrations and hatches are located) to indicate a breach of the 29 Containment fission product barrier. NEDO-33349 recommends that Radiation Exposure Rate 30 need not be considered as an RG 1.97, Revision 4, Type C variable. The justification given in 31 NEDO-33349 is that Radiation Exposure Rate may be an indicator of radiation release, but it is 32 not a direct indicator of the integrity of the primary containment barrier. RPV Pressure, Drywell 33 Pressure/Containment Pressure, Suppression Pool Temperature, and Suppression Pool Water 34 Level provide information about the Primary Containment function. Radiation Exposure Rate 35 does, however, meet the criteria of an RG 1.97, Revision 4, Type E variable, as it provides the 36 magnitude of release for Radiation Exposure Rate.
37 38 RG 1.97, Revision 3, does not recommend Radiation Exposure Rate as a Type C variable. As 39 an RG 1.97, Revision 2 Type C, Category 2 variable Radiation Exposure Rate does not need to 40 meet the RG 1.97, Revision 4, Type C design and qualification criteria. The NRC staff agrees 41 that Radiation Exposure Rate is not a key variable for providing information on the integrity of 42 the Primary Containment fission product barrier and, therefore, may be reclassified as not being 43 an RG 1.97, Revision 4, Type C variable for the Primary Containment fission product barrier.
44 45 3.1.D Type D System Status 46 47 RG 1.97, Revision 3, recommends that the status of the following groups of systems be 48 monitored for information indicating the operation of individual systems or other systems 49 important to safety: Condensate and Feedwater System, Primary Containment Related 1
Systems, Main Steam System, Safety Systems, Residual Heat Removal (RHR) Systems, 2
Cooling Water System, Radwaste Systems, Ventilation Systems, and Power Supplies.
3 4
NEDO-33349 recommends that the performance status of the following groups of systems be 5
monitored: (1) Containment System, (2) Reactor Protection System and Control Rod Drive 6
System, (3) Safety Relief Valve (SRV) System, (4) Reactor Core Isolation Cooling (RCIC) 7 System, (5) High Pressure Coolant Injection (HPCI) or High Pressure Core Spray (HPCS) 8 System, (6) RHR System, (7) Low Pressure Core Spray (LPCS) System, (8) Cooling Water 9
System, (9) RHR Service Water System, (10) Essential Service Water System, (11) RPV 10 Isolation System, (12) Containment Isolation System, (13) Secondary Containment System, 11 (14) Control Room Environment System, (15) Standby Liquid Control System (SLCS),
12 (16) Power Systems, (17) Equipment Area Cooling Water System, (18) Essential Pneumatic 13 Gas Supply System, and (19) Isolation Condenser System. NEDO-33349 also recommends 14 that the status of variables in the following RG 1.97, Revision 3, systems need not be 15 monitored: (20) Condensate and Feedwater System, (21) Main Steam System, and 16 (22) Radwaste Systems.
17 18 3.1.D.1 Type D Containment System Variables 19 20 3.1.D.1.1 Drywell Pressure/Containment Pressure 21 22 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 23 monitor Drywell Pressure to check the operation of the Primary Containment Related Systems.
24 NEDO-33349 recommends that Drywell Pressure remains an RG 1.97, Revision 4, Type D 25 variable to provide information on the status of the Containment System performance.
26 NEDO-33349 also states that Drywell Pressure and Containment Pressure are essentially the 27 same instruments for BWR Mark I and II containments and the two terms are used 28 interchangeably. In Mark III containments the Drywell Pressure and Containment Pressure 29 instruments have only minor differences in their readings.
30 31 The NRC staff agrees with the classification of Drywell Pressure/Containment Pressure as an 32 RG 1.97, Revision 4, Type D variable to provide information on the status of the Containment 33 System performance.
34 35 3.1.D.1.2 Suppression Pool Temperature 36 37 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 38 monitor Suppression Pool Water Temperature to check the operation of the Primary 39 Containment Related Systems. NEDO-33349 recommends that Suppression Pool Temperature 40 remains an RG 1.97, Revision 4, Type D variable to provide information on the status of the 41 Containment System performance.
42 43 The NRC staff agrees with the classification of Suppression Pool Temperature as an RG 1.97, 44 Revision 4, Type D variable to provide information on the status of the Containment System 45 performance.
46 47 48 49 3.1.D.1.3 Suppression Pool Water Level 1
2 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 3
monitor Suppression Pool Water Level to check the operation of the Primary Containment 4
Related Systems. NEDO-33349 recommends that Suppression Pool Water Level remains an 5
RG 1.97, Revision 4, Type D variable to provide information on the status of the Containment 6
System performance.
7 8
The NRC staff agrees with the classification of Suppression Pool Water Level as an RG 1.97, 9
Revision 4, Type D variable to provide information on the status of the Containment System 10 performance.
11 12 3.1.D.1.4 Drywell Temperature 13 14 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 15 monitor Drywell Atmosphere Temperature to check the operation of Primary Containment 16 Related Systems. NEDO-33349 recommends that Drywell Temperature remains an RG 1.97, 17 Revision 4, Type D variable to provide information on the status of the Containment System 18 performance.
19 20 The NRC staff agrees with the classification of Drywell Temperature as an RG 1.97, Revision 4, 21 Type D variable to provide information on the status of the Containment System performance.
22 23 3.1.D.1.5 Suppression Chamber Spray Flow 24 25 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 26 monitor Suppression Chamber Spray Flow to check the operation of the Primary Containment 27 Related Systems. NEDO-33349 recommends that Suppression Chamber Spray Flow need not 28 be classified as an RG 1.97, Revision 4, Type D variable to provide information on the status of 29 the Containment System performance. The justification given in NEDO-33349 is that the 30 containment performance assessment does not rely upon Suppression Chamber Spray Flow.
31 Containment performance information is provided by Drywell Pressure/Containment Pressure, 32 Drywell Temperature, Suppression Pool Temperature, and Suppression Pool Water Level.
33 34 The NRC staff agrees with the reclassification of Suppression Chamber Spray Flow as not 35 being an RG 1.97, Revision 4, Type D variable to provide information on the status of the 36 Containment System performance.
37 38 3.1.D.1.6 Drywell Spray Flow 39 40 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 41 monitor Drywell Spray Flow to check the operation of the Primary Containment Related 42 Systems. NEDO-33349 recommends that Drywell Spray Flow need not be considered as an 43 RG 1.97, Revision 4, Type D variable to provide information on the status of the Containment 44 System performance. The justification given in NEDO-33349 is that the containment 45 performance assessment does not rely upon Drywell Spray Flow. Containment performance 46 information is provided by Drywell Pressure/Containment Pressure, Drywell Temperature, 47 Suppression Pool Temperature, and Suppression Pool Water Level.
48 49 The NRC staff agrees with the reclassification of Drywell Spray Flow as not being an RG 1.97, 1
Revision 4, Type D variable to provide information on the status of Containment System 2
performance.
3 4
3.1.D.2 Type D Reactor Protection System and Control Rod Drive System Variables 5
6 3.1.D.2.1 Neutron Flux 7
8 NEDO-33349 recommends that Neutron Flux be classified as an RG 1.97, Revision 4, Type D 9
variable to provide information on the status of the RPS and CRD System performance. The 10 justification given in NEDO-33349 is that Neutron Flux meets the criteria of a Type D variable 11 because it demonstrates the status of the RPS and CRD System performance. NEDO-31558 12 proposed alternate design and qualification criteria for Neutron Flux monitoring instrumentation 13 at BWR plants. The NRC staff accepted NEDO-31558 for BWR plants with applications 14 submitted before January 14, 1993.
15 16 The NRC staff agrees with the classification of Neutron Flux as an RG 1.97, Revision 4, Type D 17 variable with the NEDO-31558 alternate design and qualification criteria to provide information 18 on the status of the RPS and CRD System performance.
19 20 3.1.D.2.2 Control Rod Position 21 22 NEDO-33349 recommends that Control Rod Position be classified as an RG 1.97, Revision 4, 23 Type D variable to provide information on the status of the RPS and CRD System performance.
24 The justification given in NEDO-33349 is that Control Rod Position indication system is used to 25 determine that the RPS has performed its safety function by control rod insertion following an 26 accident. The Control Rod Position system confirms that the CRD System has performed its 27 safety function. The control rod position indication is a normal operating system that is not 28 required to be seismically designed. Its function is completed before experiencing a harsh 29 environment.
30 31 The NRC staff agrees with the classification of Control Rod Position as an RG 1.97, Revision 4, 32 Type D variable, without environmental or seismic qualification, to provide information on the 33 status of the RPS and the CRD System performance.
34 35 3.1.D.3 Type D Safety Relief Valve System Variables 36 37 3.1.D.3.1 Safety Relief Valve Position 38 39 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 40 monitor Primary System SRV Position for detection of accident and boundary integrity indication 41 of the Main Steam System. NEDO-33349 recommends that SRV Position be classified as an 42 RG 1.97, Revision 4, Type D variable to provide information on the SRV System performance.
43 The justification given in NEDO-33349 is that SRV Position is a backup instrument only and is 44 not required to be environmentally or seismically qualified. NEDO-33160, Regulatory 45 Relaxation for the Post Accident SRV Position Indication System, issued December 13, 2004 46 (Reference 14), changed the RG 1.97, Revision 3, classification of SRV Position from Category 47 2 to Category 3. With a safety evaluation dated September 25, 2006 (Reference 15), the NRC 48 staff accepted NEDO-33160. NEDO-33160 was reissued as NEDO-33160-A, October 2006 49 (Reference 16) to incorporate the September 25, 2006 safety evaluation. This change in 1
category does not relieve licensees from meeting the requirements of 10 CFR 50.34(f) or 2
NUREG-0737, Item II.D.3.
3 4
The NRC staff agrees with the classification of SRV Position as an RG 1.97, Revision 4, Type D 5
variable, without environmental or seismic qualification, to provide information on the status of 6
the SRV System performance. However, this does not relieve licensees from meeting the 7
requirements of 10 CFR 50.34(f) or NUREG-0737, Item II.D.3.
8 9
3.1.D.4 Type D Reactor Core Isolation Cooling System Variables 10 11 3.1.D.4.1 Reactor Core Isolation Cooling System Flow 12 13 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 14 monitor RCIC Flow to check the operation of Safety Systems. NEDO-33349 recommends that 15 RCIC System Flow remains classified as an RG 1.97, Revision 4, Type D variable to provide 16 information on the status of RCIC System performance. The justification given in NEDO-33349 17 is that RCIC is required only for anticipated operational occurrences. It is not associated with 18 any events requiring environmental or seismic qualification, and, therefore, is not required to be 19 environmentally or seismically qualified.
20 21 The NRC staff agrees with the classification of RCIC System Flow as an RG 1.97, Revision 4, 22 Type D variable, without environmental or seismic qualification, to provide information on the 23 status of RCIC System performance.
24 25 3.1.D.4.2 Condensate Storage Tank Water Level 26 27 RG 1.97, Revision 3, recommends that Type D, Category 3 instrumentation be provided to 28 monitor Condensate Storage Tank Level for indication of available water for cooling of the 29 Condensate and Feedwater System. NEDO-33349 recommends that Condensate Storage 30 Tank Water Level be reclassified as an RG 1.97, Revision 4, Type D variable to provide 31 information on the status of RCIC System performance. The justification given in NEDO-33349 32 is that Condensate Storage Tank Level provides information on the status of the RCIC System, 33 and, therefore, does not need to provide information on the Condensate and Feedwater 34 System. The condensate storage tank is required only for anticipated operational occurrences.
35 Condensate Storage Tank Level is not associated with any events requiring environmental or 36 seismic qualification.
37 38 The NRC staff agrees with the reclassification of Condensate Storage Tank Level as an 39 RG 1.97, Revision 4, Type D variable, without environmental or seismic qualification, to provide 40 information on the status of RCIC System performance.
41 42 3.1.D.5 Type D High Pressure Coolant Injection or High Pressure Core Spray 43 System Variables 44 45 3.1.D.5.1 High Pressure Coolant Injection or High Pressure Core Spray System Flow 46 47 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 48 monitor HPCI Flow to check the operation of Safety Systems. NEDO-33349 recommends that 49 HPCI or HPCS System Flow remains classified as an RG 1.97, Revision 4, Type D variable to 1
provide information on the status of HPCI or HPCS System performance.
2 3
The NRC staff agrees with the classification of HPCI or HPCS System Flow as an RG 1.97, 4
Revision 4, Type D variable to provide information on the status of HPCI or HPCS System 5
performance.
6 7
3.1.D.5.2 Condensate Storage Tank Water Level 8
9 RG 1.97, Revision 3, recommends that Type D, Category 3 instrumentation be provided to 10 monitor Condensate Storage Tank Level for indication of available water for cooling of the 11 Condensate and Feedwater System. NEDO-33349 recommends that Condensate Storage 12 Tank Water Level be reclassified as an RG 1.97, Revision 4, Type D variable to provide 13 information on the status of HPCI or HPCS System performance. The justification given in 14 NEDO-33349 is that Condensate Storage Tank Level provides information on the status of the 15 HPCI or HPCS System, and, therefore, does not need to provide information on the Condensate 16 and Feedwater System. The condensate storage tank is required only for anticipated 17 operational occurrences. Condensate Storage Tank Level is not associated with any events 18 requiring environmental or seismic qualification.
19 20 The NRC staff agrees with the reclassification of Condensate Storage Tank Level as an 21 RG 1.97, Revision 4, Type D variable, without environmental or seismic qualification, to provide 22 information on the status of the HPCI or HPCS System performance.
23 24 3.1.D.6 Type D Residual Heat Removal System Variables 25 26 3.1.D.6.1 Residual Heat Removal System Flow 27 28 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 29 monitor RHR System Flow to check the operation of RHR Systems. NEDO-33349 recommends 30 that RHR System Flow remains classified as an RG 1.97, Revision 4, Type D variable to provide 31 RHR System performance information.
32 33 The NRC staff agrees with the classification of RHR System Flow as an RG 1.97, Revision 4, 34 Type D variable to provide information on the status of RHR System performance.
35 36 3.1.D.6.2 Residual Heat Removal System Valve Position 37 38 NEDO-33349 recommends that RHR System Valve Position be classified as an RG 1.97, 39 Revision 4, Type D variable to provide information on RHR System performance. The 40 justification given in NEDO-33349 is that RHR System valve lineup can be used instead of flow 41 indication for individual RHR operating modes. The BWR RHR system provides multiple 42 operating modes including Low Pressure Coolant Injection (LPCI), suppression pool cooling, 43 shutdown cooling, and drywell spray. The system uses common pumps and piping for the 44 various systems that it feeds.
45 46 The NRC staff agrees with the classification of RHR System Valve Position as an RG 1.97, 47 Revision 4, Type D variable to provide information on the status of RHR System performance.
48 49 3.1.D.6.3 Suppression Chamber Spray Flow 1
2 NEDO-33349 recommends that Suppression Chamber Spray Flow be classified as an RG 1.97, 3
Revision 4, Type D variable to provide information on the status of RHR System performance.
4 The justification given in NEDO-33349 is that Suppression Chamber Spray Flow is one of the 5
modes considered in the EPGs.
6 7
Previously approved deviations from RG 1.97, Revision 3, have allowed the use of RHR Flow, 8
Suppression Chamber Temperature, and Suppression Chamber Pressure as acceptable 9
alternatives if it can be shown that (1) use of these variables can accurately and reliably 10 measure the effectiveness of the suppression chamber spray in a timely manner, and (2) the 11 position of the spray throttling valves can be monitored and the sprays adequately controlled 12 from the control room using the alternate variables. The use of these alternate variables is 13 acceptable under RG 1.97, Revision 4. The NRC staff agrees with the classification of 14 Suppression Chamber Spray Flow or alternate instrumentation as an RG 1.97, Revision 4, 15 Type D variable to provide information on the status of RHR System performance.
16 17 3.1.D.6.4 Drywell Spray Flow 18 19 NEDO-33349 recommends that Drywell Spray Flow be classified as an RG 1.97, Revision 4, 20 Type D variable to provide information on the status of RHR System performance. The 21 justification given in NEDO-33349 is that Drywell Spray Flow is one of the modes considered in 22 the EPGs.
23 24 Previously approved deviations from RG 1.97, Revision 3, have allowed the use of RHR Flow, 25 Drywell Temperature, and Drywell Pressure as acceptable alternatives if it can be shown that 26 (1) use of these variables can accurately and reliably measure the effectiveness of the drywell 27 spray in a timely manner, and (2) the position of the spray throttling valves can be monitored 28 and the sprays adequately controlled from the control room using the alternate variables. The 29 use of these alternate variables is acceptable under RG 1.97, Revision 4. The NRC staff 30 agrees with the classification of Drywell Spray Flow or alternate instrumentation as an RG 1.97, 31 Revision 4, Type D variable to provide information on the status of RHR System performance.
32 33 3.1.D.6.5 Residual Heat Removal System Heat Exchanger Outlet Temperature 34 35 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 36 monitor RHR System Heat Exchanger Outlet Temperature to check the operation of RHR 37 Systems. NEDO-33349 recommends that RHR System Heat Exchanger Outlet Temperature 38 remains classified as an RG 1.97, Revision 4, Type D variable. The justification given in 39 NEDO-33349 is that RHR System Heat Exchanger Outlet Temperature provides information on 40 the status of decay heat removal performance of the RHR System.
41 42 The NRC staff agrees with the classification of RHR System Heat Exchanger Outlet 43 Temperature as an RG 1.97, Revision 4, Type D variable to provide information on the status of 44 decay heat removal performance of the RHR System.
45 46 47 48 49 3.1.D.7 Type D Low Pressure Core Spray System Variables 1
2 3.1.D.7.1 Low Pressure Core Spray System Flow 3
4 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 5
monitor LPCI System Flow to monitor the operation of Safety Systems. NEDO-33349 6
recommends that LPCS System Flow remains classified as an RG 1.97, Revision 4, Type D 7
variable. The justification given in NEDO-33349 is that LPCS System Flow provides information 8
on the status of LPCS System performance and that LPCI and LPCS systems perform the same 9
functions. The differences in nomenclature are the result of BWR plant naming conventions.
10 11 The NRC staff agrees with the classification of LPCS System Flow as an RG 1.97, Revision 4, 12 Type D variable to provide information on the status of LPCS System performance.
13 14 3.1.D.7.2 Core Spray Flow 15 16 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 17 monitor Core Spray System Flow to check the operation of Safety Systems. NEDO-33349 18 recommends that Core Spray Flow be classified as an RG 1.97, Revision 4, Type D variable.
19 The justification given in NEDO-33349 is that Core Spray Flow provides information on the 20 status of LPCS System performance.
21 22 The NRC staff agrees with the classification of Core Spray Flow as an RG 1.97, Revision 4, 23 Type D variable to provide information on the status of LPCS System performance.
24 25 3.1.D.8 Type D Cooling Water System Variables 26 27 3.1.D.8.1 Cooling Water Temperature to Engineered Safety Feature System Components 28 29 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 30 monitor Cooling Water Temperature to Engineered Safety Feature (ESF) System Components 31 to check the operation of the Cooling Water System. NEDO-33349 recommends that Cooling 32 Water Temperature to ESF System Components be classified as an RG 1.97, Revision 4, 33 Type D variable to provide information on the status of Cooling Water System performance.
34 The justification given in NEDO-33349 is that various BWR plants use plant specific alternate 35 means to monitor Cooling Water System performance. Each licensee would need to document 36 plant specific deviations for providing information on the status of Cooling Water System 37 performance.
38 39 The NRC staff agrees with the classification of Cooling Water Temperature to ESF System 40 Components, or alternate instrumentation, as an RG 1.97, Revision 4, Type D variable to 41 provide information on the status of Cooling Water System performance.
42 43 3.1.D.9 Type D Residual Heat Removal Service Water System Variables 44 45 3.1.D.9.1 Residual Heat Removal Service Water System Flow 46 47 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 48 monitor Cooling Water Flow to ESF System Components to check the operation of the Cooling 49 Water System. NEDO-33349 recommends that RHR Service Water System Flow be classified 1
as an RG 1.97, Revision 4, Type D variable to provide information on the status of the RHR 2
Service Water System performance. The justification given in NEDO-33349 is that various 3
BWR use plant specific alternate means to monitor RHR Service Water System performance.
4 Each licensee would need to document plant specific deviations for providing information on the 5
status of RHR Service Water System performance.
6 7
The NRC staff agrees with the classification of RHR Service Water System Flow, or alternate 8
instrumentation, as an RG 1.97, Revision 4, Type D variable to provide information on the status 9
of RHR Service Water System performance.
10 11 3.1.D.10 Type D Essential Service Water System Variables 12 13 3.1.D.10.1 Essential Service Water System Flow 14 15 NEDO-33349 recommends that Essential Service Water System Flow be classified as an 16 RG 1.97, Revision 4, Type D variable to provide information on the status of the Essential 17 Service Water System performance. The justification given in NEDO-33349 is that various 18 BWR plants use plant specific alternate means to monitor Essential Service Water System 19 performance. Each licensee would need to document plant specific deviations for providing 20 information on the status of Essential Service Water System performance.
21 22 The NRC staff agrees with the classification of Essential Service Water System Flow, or 23 alternate instrumentation, as an RG 1.97, Revision 4, Type D variable to provide information on 24 the status of Essential Service Water System performance.
25 26 3.1.D.11 Type D Reactor Pressure Vessel Isolation System Variables 27 28 3.1.D.11.1 Main Steam Isolation Valve Position 29 30 NEDO-33349 recommends that Main Steam Isolation Valve (MSIV) Position be classified as an 31 RG 1.97, Revision 4, Type D variable to provide information on the status of the RPV Isolation 32 System performance. The justification given in NEDO-33349 is that MSIV Position provides 33 information on the status of the RPV Isolation System performance.
34 35 The NRC staff agrees with the classification of MSIV Position as an RG 1.97, Revision 4, 36 Type D variable to provide information on the status of RPV Isolation System performance.
37 38 3.1.D.11.2 Cleanup System Isolation Valve Position 39 40 NEDO-33349 recommends that Cleanup System Isolation Valve Position be classified as an 41 RG 1.97, Revision 4, Type D variable to provide information on the status of the RPV Isolation 42 System performance. The justification given in NEDO-33349 is that Cleanup System Isolation 43 Valve Position provides information on the status of the RPV Isolation System performance.
44 45 The NRC staff agrees with the classification of Cleanup System Isolation Valve Position as an 46 RG 1.97, Revision 4, Type D variable to provide information on the status of RPV Isolation 47 System performance.
48 49 3.1.D.11.3 Shutdown Cooling System Isolation Valve Position 1
2 NEDO-33349 recommends that Shutdown Cooling System Isolation Valve Position be classified 3
as an RG1.97 Revision 4 Type D variable to provide information on the status of the RPV 4
Isolation System performance. The justification given in NEDO-33349 is that the Shutdown 5
Cooling System Isolation Valve Position provides information on the status of the RPV Isolation 6
System Performance.
7 8
The NRC staff agrees with the classification of Shutdown Cooling System Isolation Valve 9
Position as an RG 1.97, Revision 4, Type D variable to provide information on the status of RPV 10 Isolation System performance.
11 12 3.1.D.11.4 Other Reactor Pressure Vessel Normally Open Isolation Valve Position Inside 13 Containment 14 15 NEDO-33349 recommends that Other RPV Normally Open Isolation Valve Position Inside 16 Containment be classified as an RG 1.97, Revision 4, Type D variable to provide information on 17 the status of the RPV Isolation System performance. The justification given in NEDO-33349 is 18 that this variable provides information on the status of the RPV Isolation System performance.
19 20 The NRC staff agrees with the classification of Other RPV Normally Open Isolation Valve 21 Position Inside Containment as an RG 1.97, Revision 4, Type D variable to provide information 22 on the status of RPV Isolation System performance.
23 24 3.1.D.11.5 Other Reactor Pressure Vessel Normally Closed Isolation Valve Position Inside 25 Containment That Require Opening for LOCA 26 27 NEDO-33349 recommends that Other RPV Normally Closed Isolation Valve Position Inside 28 Containment That Require Opening for LOCA be classified as an RG 1.97, Revision 4, Type D 29 variable. The justification given in NEDO-33349 is that this variable provides information on the 30 status of the RPV Isolation System performance.
31 32 The NRC staff agrees with the classification of Other RPV Normally Closed Isolation Valve 33 Position Inside Containment That Require Opening for LOCA as an RG 1.97, Revision 4, 34 Type D variable to provide information on the status of the RPV Isolation System performance.
35 36 3.1.D.11.6 Other Reactor Pressure Vessel Normally Open Isolation Valve Position Outside 37 Containment 38 39 NEDO-33349 recommends that Other RPV Normally Open Isolation Valve Position Outside 40 Containment be classified as an RG 1.97, Revision 4, Type D variable to provide information on 41 the status of the RPV Isolation System performance. The justification given in NEDO-33349 is 42 that Other RPV Normally Open Isolation Valve Position Outside Containment provides 43 information on the status of RPV Isolation System performance.
44 45 The NRC staff agrees with the classification of Other RPV Normally Open Isolation Valve 46 Position Outside Containment as an RG 1.97, Revision 4, Type D variable to provide 47 information on the status of the RPV Isolation System performance.
48 49 3.1.D.11.7 Other Reactor Pressure Vessel Normally Closed Isolation Valve Position Outside 1
Containment That Require Opening for Pipe Breaks Outside Containment 2
3 NEDO-33349 recommends that Other RPV Normally Closed Isolation Valve Position Outside 4
Containment That Require Opening for Pipe Breaks Outside Containment be classified as an 5
RG 1.97, Revision 4, Type D variable. The justification given in NEDO-33349 is that this 6
variable provides information on the status of the RPV Isolation System performance.
7 8
The NRC staff agrees with the classification of Other RPV Normally Closed Isolation Valve 9
Position Outside Containment That Require Opening for Pipe Breaks Outside Containment as 10 an RG 1.97, Revision 4, Type D variable to provide information on the status of the RPV 11 Isolation System performance.
12 13 3.1.D.11.8 Other Reactor Pressure Vessel Normally Closed Isolation Valve Position Outside 14 Containment That Do Not Require Opening for either LOCA or Pipe Breaks 15 Outside Containment 16 17 NEDO-33349 recommends that Other RPV Normally Closed Isolation Valve Position Outside 18 Containment That Do Not Require Opening for either LOCA or Pipe Breaks Outside 19 Containment be classified as an RG 1.97, Revision 4, Type D variable, without environmental or 20 seismic qualification, to provide information on the status of RPV Isolation System performance.
21 The justification given in NEDO-33349 is that for Other RPV Normally Closed Isolation Valve 22 Position Outside Containment That Do Not Require Opening for either LOCA or Pipe Breaks 23 Outside Containment, the position is known before an accident, and the valves are not required 24 to open for either LOCAs or pipe breaks outside containment and, therefore, do not need to be 25 environmentally or seismically qualified.
26 27 The NRC staff agrees with the classification of Other RPV Normally Closed Isolation Valve 28 Position Outside Containment That Do Not Require Opening for either LOCA or Pipe Breaks 29 Outside Containment as a RG1.97 Revision 4 Type D variable, without environmental or 30 seismic qualification, to provide information on the status of RPV Isolation System performance.
31 32 3.1.D.12 Type D Containment Isolation System Variables 33 34 3.1.D.12.1 Normally Open Containment Isolation Valve Position Inside Containment 35 36 NEDO-33349 recommends that Normally Open CIV Position Inside Containment be classified 37 as an RG 1.97, Revision 4, Type D variable. The justification given in NEDO-33349 is Normally 38 Open CIV Position Inside Containment provides information on the status of Containment 39 Isolation System performance.
40 41 The NRC staff agrees with the classification of Normally Open CIV Position Inside Containment 42 as an RG 1.97, Revision 4, Type D variable to provide information on the status of the 43 Containment Isolation System performance.
44 45 46 47 48 3.1.D.12.2 Normally Closed Containment Isolation Valve Position Inside Containment That 1
Require Opening for LOCA 2
3 NEDO-33349 recommends that Normally Closed CIV Position Inside Containment That Require 4
Opening for LOCA be classified as an RG 1.97, Revision 4, Type D variable. The justification 5
given in NEDO-33349 is that this variable provides information on the status of Containment 6
Isolation System performance.
7 8
The NRC staff agrees with the classification of Normally Closed CIV Position Inside 9
Containment That Require Opening for LOCA as an RG 1.97, Revision 4, Type D variable to 10 provide information on the status of Containment Isolation System performance.
11 12 3.1.D.12.3 Containment Isolation Valve Position Outside Containment That Require 13 Opening for LOCA 14 15 NEDO-33349 recommends that CIV Position Outside Containment That Require Opening for 16 LOCA be classified as an RG 1.97, Revision 4, Type D variable. The justification given in 17 NEDO-33349 is that this variable provides information on the status of the Containment 18 Isolation System performance.
19 20 The NRC staff agrees with the classification of CIV Position Outside Containment That Require 21 Opening for LOCA as an RG 1.97, Revision 4, Type D variable to provide information on the 22 status of the Containment Isolation System performance.
23 24 3.1.D.12.4 Normally Closed Containment Isolation Valve Position Inside or Outside 25 Containment That Do Not Require Opening for LOCA 26 27 NEDO-33349 recommends that Normally Closed CIV Position Inside or Outside Containment 28 That Do Not Require Opening for LOCA be classified as an RG 1.97, Revision 4, Type D 29 variable, without environmental or seismic qualification, to provide information on the status of 30 Containment Isolation System performance. The justification given in NEDO-33349 is that for 31 Normally Closed CIV Position Inside or Outside Containment That Do Not Require Opening for 32 LOCA the position is known before an accident, and the valves are not required to open for a 33 LOCA and, therefore, do not need to be environmentally qualified or seismically qualified.
34 35 The NRC staff agrees with the classification of Normally Closed CIV Position Inside or Outside 36 Containment That Do Not Require Opening for LOCA as an RG 1.97, Revision 4, Type D 37 variable, without environmental or seismic qualification, to provide information on the status of 38 Containment Isolation System performance.
39 40 3.1.D.13 Type D Secondary Containment System Variables 41 42 3.1.D.13.1 Secondary Containment Isolation Damper Position 43 44 NEDO-33349 recommends that Secondary Containment Isolation Damper Position be classified 45 as an RG 1.97, Revision 4, Type D variable. The justification given in NEDO-33349 is that 46 Secondary Containment Isolation Damper Position provides information on the status of the 47 Secondary Containment System performance.
48 49 The NRC staff agrees with the classification of Secondary Containment Isolation Damper 1
Position as an RG 1.97, Revision 4, Type D variable to provide information on the status of the 2
Secondary Containment System performance.
3 4
3.1.D.13.2 Standby Gas Treatment Flow 5
6 NEDO-33349 recommends that Standby Gas Treatment Flow be classified as an RG 1.97, 7
Revision 4, Type D variable. The justification given in NEDO-33349 is that Standby Gas 8
Treatment Flow provides information on the status of the Secondary Containment System 9
performance.
10 11 The NRC staff agrees with the classification of Standby Gas Treatment Flow as an RG 1.97, 12 Revision 4, Type D variable to provide Secondary Containment System performance.
13 14 3.1.D.14 Type D Control Room Environment System Variables 15 16 3.1.D.14.1 Control Room Isolation Damper Position 17 18 NEDO-33349 recommends that Control Room Isolation Damper Position be classified as an 19 RG 1.97, Revision 4, Type D variable. The justification given in NEDO-33349 is that Control 20 Room Isolation Damper Position provides information on the status of the Control Room 21 Environment System performance.
22 23 The NRC staff agrees with the classification of Control Room Isolation Damper Position as an 24 RG 1.97, Revision 4, Type D variable to provide Control Room Environment System 25 performance.
26 27 3.1.D.14.2 Emergency Ventilation Damper Position 28 29 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 30 monitor Emergency Ventilation Damper Position to check the operation of the Ventilation 31 Systems. NEDO-33349 recommends that Emergency Ventilation Damper Position remains 32 classified as an RG 1.97, Revision 4, Type D variable. The justification given in NEDO-33349 is 33 that Emergency Ventilation Damper Position provides information on the status of the Control 34 Room Environment System performance. Differential pressure can be used as an acceptable 35 alternative.
36 37 The NRC staff agrees with the classification of Emergency Ventilation Damper Position, or 38 alternate instrumentation, as an RG 1.97, Revision 4, Type D variable to provide information on 39 the status of the Control Room Environment System performance.
40 41 3.1.D.15 Type D Standby Liquid Control System Variables 42 43 3.1.D.15.1 Standby Liquid Control System Flow or Pumps Running 44 45 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 46 monitor Standby Liquid Control System (SLCS) Flow to monitor operation of Safety Systems.
47 NEDO-33349 recommends that SLCS Flow or Pumps Running remains classified as an 48 RG 1.97, Revision 4, Type D variable, without environmental or seismic qualification. The 49 justification given in NEDO-33349 is that SLCS Flow or Pumps Running provides information on 1
the status of SLCS performance. The SLCS is not associated with any events requiring 2
environmental or seismic qualification.
3 4
The NRC staff agrees with the classification of SLCS Flow or Pumps Running as an RG 1.97, 5
Revision 4, Type D variable, without environmental or seismic qualification, to provide 6
information on the status of SLCS performance.
7 8
3.1.D.15.2 Standby Liquid Control System Storage Tank Level 9
10 RG 1.97, Revision 3, recommends that Type D, Category 2 to monitor SLCS Storage Tank 11 Level to check the operation of Safety Systems. NEDO-33349 recommends that SLCS Storage 12 Tank Level be classified as an RG 1.97, Revision 4, Type D variable, without environmental or 13 seismic qualification. The justification given in NEDO-33349 is that SLCS Storage Tank Level 14 provides information on the status of the SLCS performance. The SLCS is not associated with 15 any events requiring environmental or seismic qualification.
16 17 The NRC staff agrees with the classification of SLCS Storage Tank Level as an RG 1.97, 18 Revision 4, Type D variable, without environmental or seismic qualification, to provide 19 information on the status of SLCS performance.
20 21 3.1.D.16 Type D Power Systems Variables 22 23 3.1.D.16.1 AC and DC Power Status 24 25 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 26 monitor Status of Standby Power to check the system status of Power Supplies. NEDO-33349 27 recommends that AC and DC Power Status be classified as an RG 1.97, Revision 4, Type D 28 variable. The justification given in NEDO-33349 is that AC and DC Power Status provides 29 information on the status of Power Systems performance.
30 31 The NRC staff agrees with the classification of AC and DC Power Status as an RG 1.97, 32 Revision 4, Type D variable to provide information on the status of Power Systems 33 performance.
34 35 3.1.D.17 Type D Equipment Area Cooling Water System Variables 36 37 3.1.D.17.1 Equipment Area Cooling System Cooling Water Temperature 38 39 NEDO-33349 recommends that Equipment Area Cooling System Cooling Water Temperature 40 be classified as an RG 1.97, Revision 4, Type D variable. The justification given in 41 NEDO-33349 is that Equipment Area Cooling System Cooling Water Temperature provides 42 information on the status of Equipment Area Cooling System performance.
43 44 The NRC staff agrees with the classification of Equipment Area Cooling System Cooling Water 45 Temperature as an RG 1.97, Revision 4, Type D variable to provide information on the status of 46 Equipment Area Cooling Water System performance.
47 48 49 3.1.D.18 Type D Essential Pneumatic Gas Supply System Variables 1
2 3.1.D.18.1 Essential Pneumatic Gas Supply Pressure 3
4 NEDO-33349 recommends that Essential Pneumatic Gas Supply Pressure be classified as 5
RG 1.97, Revision 4, Type D variable. The justification given in NEDO-33349 is that Essential 6
Pneumatic Gas Supply Pressure provides information on the status of the Essential Pneumatic 7
Gas Supply System performance.
8 9
The NRC staff agrees with the classification of Essential Pneumatic Gas Supply Pressure as a 10 RG1.97, Revision 4, Type D variable to provide information on the status of the Essential 11 Pneumatic Gas Supply System performance.
12 13 3.1.D.19 Type D Isolation Condenser System Variables 14 15 3.1.D.19.1 Isolation Condenser System Shell-Side Water Level 16 17 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 18 monitor Isolation Condenser System Shell-Side Water Level to check the operation of Safety 19 Systems. NEDO-33349 recommends that Isolation Condenser System Shell-Side Water Level 20 be classified as an RG 1.97, Revision 4, Type D variable for plants with isolation condensers.
21 The justification given in NEDO-33349 is that isolation condensers are associated with BWR/2 22 and BWR/3 plant designs. For BWR/2 and BWR/3 plants, the performance of the isolation 23 condenser is indicated by Type B instrumentation, and system status is indicated by Type D 24 Condensate Return Valve Position and Type D Isolation Condenser Shell Water Level.
25 26 The NRC staff agrees with the classification of Isolation Condenser System Shell-Side Water 27 Level as an RG 1.97, Revision 4, Type D variable to provide information on the status of 28 Isolation Condenser System performance, for plants with isolation condensers. Plants with 29 isolation condensers should review their plant design and propose plant specific Type B 30 variables to provide information on the accomplishment of the Isolation Condenser function and 31 Type D variables to provide information on the status of the Isolation Condenser System 32 performance.
33 34 3.1.D.19.2 Isolation Condenser System Valve Position 35 36 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 37 monitor Isolation Condenser System Valve Position to check the status of Safety Systems.
38 NEDO-33349 recommends that Isolation Condenser System Valve Position Level be classified 39 as an RG 1.97, Revision 4, Type D variable for plants with isolation condensers. The 40 justification given in NEDO-33349 is that isolation condensers are associated with BWR/2 and 41 BWR/3 plant designs. For BWR/2 and BWR/3 plants, the performance of the isolation 42 condenser is indicated by Type B instrumentation, and system status is indicated by Type D 43 Condensate Return Valve Position and Type D Isolation Condenser Shell Water Level.
44 45 The NRC staff agrees with the classification of Isolation Condenser System Valve Position as 46 an RG 1.97, Revision 4, Type D variable to provide information on the status of Isolation 47 Condenser System performance for plants with isolation condensers. Plants with isolation 48 condensers should review their plant design and propose plant specific Type B variables to 49 provide information on the accomplishment of the Isolation Condenser function and Type D 1
variables to provide information on the status of the Isolation Condenser System performance.
2 3
3.1.D.20 Type D Condensate and Feedwater System Variables 4
5 3.1.D.20.1 Main Feedwater Flow 6
7 RG 1.97, Revision 3, recommends that Type D, Category 3 instrumentation be provided to 8
monitor Main Feedwater Flow for detection of operation and analysis of cooling of the 9
Condensate and Feedwater System. NEDO-33349 recommends that Main Feedwater Flow 10 need not be considered as an RG1.97, Revision 4, Type D variable for the Condensate and 11 Feedwater System. The justification given in NEDO-33349 is that Main Feedwater Flow is a 12 normal operating system.
13 14 The NRC staff agrees with the reclassification of Main Feedwater Flow as not being a RG1.97, 15 Revision 4, Type D variable for the Condensate and Feedwater System.
16 17 3.1.D.21 Type D Main Steam System Variables 18 19 3.1.D.21.1 Main Steam Isolation Valve Leakage Control System Pressure 20 21 RG 1.97, Revision 3, recommends that Type D, Category 2 instrumentation be provided to 22 monitor MSIV Leakage Control System Pressure to indicate pressure boundary maintenance of 23 the Main Steam System. NEDO-33349 recommends that MSIV Leakage Control System 24 Pressure need not be considered as an RG 1.97, Revision 4, Type D variable for the Main 25 Steam System. The justification given in NEDO-33349 is that the NRC approved the elimination 26 of the MSIV leakage control system on a plant specific basis with the approval of 27 NEDC-31858P, Revision 2, BWROG Report for Increasing MSIV Leakage Limits and 28 Elimination of Leakage Control Systems, issued August 1993 (Reference 17), with a safety 29 evaluation issued March 3, 1999 (Reference 18). NEDC-31858P, Revision 2, was reissued, as 30 NEDC-31858P-A, issued August 1999 (Reference 19), to incorporate the March 3, 1999 safety 31 evaluation.
32 33 The NRC staff agrees with the reclassification of MSIV Leakage Control System Pressure as 34 not being an RG 1.97, Revision 4, Type D variable for the Main Steam System. Each licensee 35 should identify any previous approval of the elimination of MSIV leakage control system, justify 36 the elimination of the MSIV Leakage Control System, or provide instrumentation indicating the 37 MSIV Leakage Control System Pressure.
38 39 3.1.D.22 Type D Radwaste System Variables 40 41 3.1.D.22.1 High Radioactivity Liquid Tank Level 42 43 RG 1.97, Revision 3, recommends that Type D, Category 3 instrumentation be provided to 44 monitor High Radioactivity Liquid Tank Level to check the operation of the Radwaste Systems.
45 NEDO-33349 recommends that High Radioactivity Liquid Tank Level need not be considered as 46 an RG 1.97, Revision 4, Type D variable. The justification given in NEDO-33349 is that BWR 47 radwaste systems are normal operating systems. Liquid radwaste systems are not required for 48 mitigation of accidents.
49 The NRC staff agrees with the reclassification of High Radioactivity Liquid Tank Level as not 1
being an RG 1.97, Revision 4, Type D variable to provide information on the status of the 2
Radwaste System.
3 4
3.1.E Type E Functions 5
6 NEDO-33349 recommends that the following functions be monitored by Type E variables:
7 (1) Containment Radiation, (2) Area Radiation, (3) Airborne Radioactive Materials Released 8
from Plant - Noble Gas and Vent Flow Rate, (4) Particulates and Halogens, (5) Environs 9
Radiation and Radioactivity, (6) Meteorological, (7) Grab Samples, (8) Off-gas System 10 Radiation, and (9) Effluent Radioactivity.
11 12 3.1.E.1 Type E Containment Radiation Variables 13 14 3.1.E.1.1 Containment Area Radiation 15 16 RG 1.97, Revision 3, recommends that Type E, Category 1 instrumentation be provided to 17 monitor Containment Area Radiation - High Range for detection of significant releases, release 18 assessment, long-term surveillance, and emergency plan actuation for determining the 19 magnitude of Containment Radiation releases. NEDO-33349 recommends that Containment 20 Area Radiation - High Range instrumentation be classified as an RG 1.97, Revision 4, Type E 21 variable to Monitor Identified Pathway. NEDO-33349 also recommends that this 22 instrumentation should meet the plant specific licensing commitments to Item II.F.1 in 23 NUREG-0737 and RG 1.97, Revision 2 or 3, for Type E variables, instead of the RG 1.97, 24 Revision 4, Type E criteria.
25 26 The NRC staff agrees with the classification of Containment Area Radiation - High Range as an 27 RG 1.97, Revision 4, Type E variable to monitor identified pathways provided that the 28 instrumentation meets the plant specific licensing commitments to Item II.F.1 in NUREG-0737 29 and RG 1.97, Revision 2 or 3, Category 1 criteria, instead of the RG 1.97, Revision 4, Type E 30 criteria. The classification of Containment Area Radiation - High Range as an RG 1.97, 31 Revision 4, Type E variable does not release licensees from meeting the plant specific licensing 32 commitments related to the requirements of Item II.F.1 of NUREG-0737.
33 34 RG 1.97, Revision 3, also recommends that Type C, Category 3 instrumentation be provided to 35 monitor Primary Containment Area Radiation to detect a breach and verify the Reactor Coolant 36 Pressure Boundary function. NEDO-33349 recommends that Primary Containment Area 37 Radiation be reclassified as an RG 1.97, Revision 4, Type E variable. The justification given in 38 NEDO-33349 is that Primary Containment Area Radiation is an indicator of radiation release 39 from fuel cladding failure and reactor coolant pressure boundary breach and thus meets the 40 criteria of an RG 1.97, Revision 4, Type E variable, as it provides the magnitude of release for 41 Containment Area Radiation.
42 43 The NRC staff also agrees with the reclassification of RG 1.97, Revision 3, Type C Primary 44 Containment Area Radiation as an RG 1.97, Revision 4, Type E variable. The range of Primary 45 Containment Area Radiation is included in the range of Containment Area Radiation - High 46 Range; therefore, a single instrument could provide information for both Containment Area 47 Radiation - High Range and Primary Containment Area Radiation.
48 49 NEDO-33349 also implies that because the design criteria for Containment Area Radiation -
1 High Range instrumentation and the requirements for hydrogen monitoring instrumentation in 2
10 CFR 50.44 are similar, the requirements of 10 CFR 50.44 could be extended to 3
instrumentation for Containment Area Radiation - High Range. Any relaxations or downgrades 4
from previous design and qualification criteria for instrumentation covered by 10 CFR 50.44 are 5
applicable only to the instrumentation that is specified in the regulation and cannot be extended 6
to other instrumentation. Therefore, relaxations and downgrades in 10 CFR 50.44 cannot be 7
extended to instrumentation for Containment Area Radiation - High Range.
8 9
3.1.E.1.2 Reactor Building or Secondary Containment Area Radiation 10 11 RG 1.97, Revision 3, recommends that Type E, Category 2 instrumentation for Mark III 12 containments and Category 3 instrumentation for Mark I and II containments be provided to 13 monitor Reactor Building or Secondary Containment Area Radiation for detection of significant 14 releases, release assessment, and long-term surveillance to determine the magnitude of 15 Containment Radiation releases. NEDO-33349 recommends that Reactor Building or 16 Secondary Containment Area Radiation be classified as an RG 1.97, Revision 4, Type E 17 variable to Monitor Identified Pathway.
18 19 The NRC staff agrees with the classification of Reactor Building or Secondary Containment 20 Area Radiation as an RG 1.97, Revision 4, Type E variable to Monitor Identified Pathway for 21 determining the magnitude of Containment Radiation releases.
22 23 3.1.E.2 Type E Area Radiation Variables 24 25 3.1.E.2.1 Radiation Exposure Rate 26 27 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 28 monitor Radiation Exposure Rate for detection of significant releases, release assessment, and 29 long-term surveillance for determining the magnitude of Area Radiation releases; RG 1.97, 30 Revision 2, recommends that Type E, Category 2 instrumentation be used for these purposes.
31 NEDO-33349 recommends that Radiation Exposure Rate (inside buildings or areas where 32 access is required to service equipment important to safety) be classified as an RG 1.97, 33 Revision 4, Type E variable.
34 35 The NRC staff agrees with the classification of Radiation Exposure Rate (inside buildings or 36 areas where access is required to service equipment important to safety) as an RG 1.97, 37 Revision 4, Type E variable to Monitor Identified Pathway for determining the magnitude of Area 38 Radiation releases.
39 40 3.1.E.2.2 Control Room Area Radiation 41 42 NEDO-33349 recommends that Control Room Area Radiation be classified as RG1.97, 43 Revision 4, Type E variable to monitor radiation levels in the control room. The justification 44 given in NEDO-33349 is that Control Room Area Radiation is consistent with the plant recovery 45 access parameters in RG 1.97, Revision 4.
46 47 The NRC staff agrees with the classification of Control Room Area Radiation as an RG 1.97, 48 Revision 4, Type E variable to monitor control room radiation.
49 3.1.E.3 Type E Airborne Radioactive Materials Released From The Plant - Noble Gas 1
and Vent Flow Rate Variables 2
3 3.1.E.3.1 Drywell Purge, Standby Gas Treatment System Purge, and Secondary 4
Containment Purge 5
6 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 7
monitor Drywell Purge, Standby Gas Treatment System Purge (in Mark I and II plants), and 8
Secondary Containment Purge (in Mark III plants) - Noble Gases and Vent Flow Rate for 9
detection of significant releases and release assessment for determining the magnitude of 10 Airborne Radioactive Materials Released from the Plant. NEDO-33349 recommends that 11 Drywell Purge, Standby Gas Treatment System Purge (Mark I and II plants), and Secondary 12 Containment Purge (Mark III plants) - Noble Gases and Vent Flow Rate be classified as an 13 RG 1.97, Revision 4, Type E variable. The justification given in NEDO-33349 is that these 14 purges should be included as release points if they are included in a plant specific list of 15 potential release points.
16 17 The NRC staff agrees with the classification of Drywell Purge, Standby Gas Treatment System 18 Purge (in Mark I and II plants), and Secondary Containment Purge (in Mark III plants) - Noble 19 Gases and Vent Flow Rate as an RG 1.97, Revision 4, Type E variable for plants that include 20 these purges as release points in a plant specific list of potential release points.
21 22 3.1.E.3.2 Secondary Containment Purge 23 24 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 25 monitor Secondary Containment Purge (in Mark I, II, and III plants) - Noble Gases and Vent 26 Flow Rate for detection of significant releases and release assessment for determining the 27 magnitude of Airborne Radioactive Materials Released from the Plant. NEDO-33349 28 recommends that Secondary Containment Purge (in Mark I, II, and III plants) - Noble Gases and 29 Vent Flow Rate be classified as an RG 1.97, Revision 4, Type E variable. The justification given 30 in NEDO-33349 is that Secondary Containment Purge - Noble Gases and Vent Flow Rate 31 should be included as a release point if included in a plant specific list of potential release 32 points.
33 34 The NRC staff agrees with the classification of Secondary Containment Purge (in Mark I, II, and 35 III plants) - Noble Gases and Vent Flow Rate as an RG 1.97, Revision 4, Type E variable for 36 plants that include Secondary Containment Purge (in Mark I, II, and III plants) - Noble Gases 37 and Vent Flow Rate as a release point in a plant specific list of potential release points.
38 39 3.1.E.3.3 Secondary Containment 40 41 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 42 monitor Secondary Containment (reactor shield building annulus) - Noble Gases and Vent Flow 43 Rate for detection of significant releases and release assessment for determining the magnitude 44 of Airborne Radioactive Materials Released from the Plant, for plants with a reactor shield 45 building annulus. NEDO-33349 recommends that Secondary Containment (reactor shied 46 building annulus) - Noble Gases and Vent Flow Rate be classified as an RG 1.97, Revision 4, 47 Type E variable. The justification given in NEDO-33349 is that Secondary Containment (reactor 48 shield building annulus) - Noble Gases and Vent Flow Rate should be included as a release 49 point if included in a plant specific list of potential release points.
1 2
The NRC staff agrees with the classification of Secondary Containment (reactor shield building 3
annulus) - Noble Gases and Vent Flow Rate as an RG 1.97, Revision 4, Type E variable for 4
plants that include Secondary Containment (reactor shield building annulus) as a release point 5
in a plant specific list of potential release points.
6 7
3.1.E.3.4 Auxiliary Building 8
9 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 10 monitor Auxiliary Building (including any building containing primary system gases) - Noble 11 Gases and Vent Flow Rate for detection of significant releases, release assessment, and long-12 term surveillance for determining the magnitude of Airborne Radioactive Materials Released 13 from the Plant. NEDO-33349 recommends that Auxiliary Building (including any building 14 containing primary system gases) - Noble Gases and Vent Flow Rate be classified as an 15 RG 1.97, Revision 4, Type E variable. The justification given in NEDO-33349 is that Auxiliary 16 Building (including any building containing primary system gases) - Noble Gases and Vent Flow 17 Rate should be included as a release point if included in a plant specific list of potential release 18 points.
19 20 The NRC staff agrees with the classification of Auxiliary Building (including any building 21 containing primary system gases) - Noble Gases and Vent Flow Rate as an RG 1.97, 22 Revision 4, Type E variable for plants that include Auxiliary Building (including any building 23 containing primary gases) - Noble Gases and Vent Flow Rate as a release point in a plant 24 specific list of potential release points.
25 26 3.1.E.3.5 Common Plant Vent or Multipurpose Vent Discharge 27 28 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 29 monitor Common Plant Vent or Multipurpose Vent Discharge - Noble Gases and Vent Flow 30 Rate for detection of significant releases, release assessment, and long-term surveillance for 31 determining the magnitude of Airborne Radioactive Materials Released from the Plant.
32 NEDO-33349 recommends that Common Plant Vent or Multipurpose Vent Discharge - Noble 33 Gases and Vent Flow Rate be classified as an RG 1.97, Revision 4, Type E variable. The 34 justification given in NEDO-33349 is that Common Plant Vent or Multipurpose Vent Discharge -
35 Noble Gases and Vent Flow Rate should be included as a release point if included in a plant 36 specific list of potential release points.
37 38 The NRC staff agrees with the classification of Common Plant Vent or Multipurpose Vent 39 Discharge - Noble Gases and Vent Flow Rate as an RG 1.97, Revision 4, Type E variable for 40 plants that include Common Plant Vent or Multipurpose Vent Discharge - Noble Gases and Vent 41 Flow Rate as a release point in a plant specific list of potential release points.
42 43 3.1.E.3.6 All Other Identified Release Points 44 45 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 46 monitor All Other Identified Release Points - Noble Gases and Vent Flow Rate for detection of 47 significant releases, release assessment, and long-term surveillance for determining the 48 magnitude of Airborne Radioactive Materials Released from the Plant. NEDO-33349 49 recommends that All Other Identified Release Points - Noble Gases and Vent Flow Rate be 1
classified as an RG 1.97, Revision 4, Type E variable. The justification given in NEDO-33349 is 2
that All Other Identified Release Points - Noble Gases and Vent Flow Rate should be included 3
as a release point if included in a plant specific list of potential release points.
4 5
The NRC staff agrees with the classification of All Other Identified Release Points - Noble 6
Gases and Vent Flow Rate as an RG 1.97, Revision 4, Type E variable for plants that include 7
All Other Identified Release Points - Noble Gases and Vent Flow Rate as a release point in a 8
plant specific list of potential release points.
9 10 3.1.E.4 Type E Particulates and Halogens Variables 11 12 3.1.E.4.1 Particulates and Halogens - All Identified Plant Release Points Sampling with 13 Onsite Analysis Capability 14 15 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 16 monitor Particulates and Halogens - All Identified Plant Release Points Sampling with Onsite 17 Analysis Capability for detection of significant releases, release assessment, and long-term 18 surveillance for determining the magnitude of Airborne Radioactive Materials Released from the 19 Plant. NEDO-33349 recommends that Particulates and Halogens - All Identified Plant Release 20 Points Sampling with Onsite Analysis Capability remain classified as an RG 1.97, Revision 4, 21 Type E variable.
22 23 The NRC staff agrees with the classification of Particulates and Halogens - All Identified Plant 24 Release Points Sampling with Onsite Analysis Capability as an RG 1.97, Revision 4, Type E 25 variable for determining the magnitude of Particulates and Halogens releases.
26 27 3.1.E.5 Type E Environs Radiation and Radioactivity Variables 28 29 3.1.E.5.1 Airborne Radiohalogens and Particulates 30 31 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 32 monitor Airborne Radiohalogens and Particulates (portable sampling with onsite analysis 33 capability) for release assessment and analysis to determine the magnitude of Environs 34 Radiation and Radioactivity. NEDO-33349 recommends that Airborne Radiohalogens and 35 Particulates (portable sampling with onsite analysis capability) remains classified as an RG 36 1.97, Revision 4, Type E variable.
37 38 The NRC staff agrees with the classification of Airborne Radiohalogens and Particulates 39 (portable sampling with onsite analysis capability) as an RG 1.97, Revision 4, Type E variable 40 for determining the magnitude of Environs Radiation and Radioactivity.
41 42 3.1.E.5.2 Plant and Environs Radiation 43 44 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 45 monitor Plant and Environs Radiation (portable instrumentation) for release assessment and 46 analysis to determine the magnitude of Environs Radiation and Radioactivity. NEDO-33349 47 recommends that Plant and Environs Radiation (portable instrumentation) remains classified as 48 an RG 1.97, Revision 4, Type E variable to Monitor Plant Environs.
49 The NRC staff agrees with the classification of Plant and Environs Radiation (portable 1
instrumentation) as an RG 1.97, Revision 4, Type E variable for Monitoring Plant Environs.
2 3
3.1.E.5.3 Plant and Environs Radioactivity 4
5 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 6
monitor Plant and Environs Radioactivity (portable instrumentation) for release assessment and 7
analysis to determine the magnitude of Environs Radiation and Radioactivity. NEDO-33349 8
recommends that Plant and Environs Radioactivity (portable instrumentation) remains classified 9
as an RG 1.97, Revision 4, Type E variable.
10 11 The NRC staff agrees with the classification of Plant and Environs Radioactivity (portable 12 instrumentation) as an RG 1.97, Revision 4, Type E variable.
13 14 3.1.E.6 Type E Meteorological Variables 15 16 3.1.E.6.1 Wind Speed 17 18 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 19 monitor Wind Speed for release assessment for Meteorological assessment of releases.
20 NEDO-33349 recommends that Wind Speed remain classified as an RG 1.97, Revision 4, 21 Type E variable to Monitor Environmental Conditions.
22 23 The NRC staff agrees with the classification of Wind Speed as an RG 1.97, Revision 4, Type E 24 variable to Monitor Environmental Conditions.
25 26 3.1.E.6.2 Wind Direction 27 28 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 29 monitor Wind Direction for release assessment for Meteorological assessment of releases.
30 NEDO-33349 recommends that Wind Direction remain classified as an RG 1.97, Revision 4, 31 Type E variable to Monitor Environmental Conditions.
32 33 The NRC staff agrees with the classification of Wind Direction as an RG 1.97, Revision 4, 34 Type E variable to Monitor Environmental Conditions.
35 36 3.1.E.6.3 Estimation of Atmospheric Stability 37 38 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 39 monitor Estimation of Atmospheric Stability for release assessment for Meteorological 40 assessment of releases. NEDO-33349 recommends that Estimation of Atmospheric Stability 41 remain classified as an RG 1.97, Revision 4, Type E variable to Monitor Environmental 42 Conditions.
43 44 The NRC staff agrees with the classification of Estimation of Atmospheric Stability as an 45 RG 1.97, Revision 4, Type E variable to Monitor Environmental Conditions.
46 47 48 49 3.1.E.7 Type E Grab Sample Variables 1
2 3.1.E.7.1 Primary Coolant and Sump Grab Sample 3
4 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 5
monitor Primary Coolant and Sump Grab Sample for release assessment, verification, and 6
analysis for Accident Sampling Capability. NEDO-33349 recommends that Primary Coolant and 7
Sump Grab Sample remains classified as an RG 1.97, Revision 4, Type E variable within the 8
guidance of NEDO-32991, Regulatory Relaxation for BWR Post Accident Sampling Stations 9
(PASS), issued November 30, 2000 (Reference 20). With a safety evaluation dated 10 June 12, 2001 (Reference 21), the NRC staff accepted NEDO-32991. NEDO-32991 was 11 reissued as NEDO-32991-A, dated August 2001 (Reference 22), to incorporate the June 12, 12 2001 safety evaluation. NEDO-32991-A contains justification for the elimination of PASS, 13 including sampling associated with the primary coolant, suppression pool, and building sumps.
14 15 The NRC staff agrees with the classification of Primary Coolant and Sump Grab Sample as an 16 RG 1.97, Revision 4, Type E variable within the guidance of NEDO-32991-A.
17 18 3.1.E.7.2 Containment Air Grab Sample 19 20 RG 1.97, Revision 3, recommends that Type E, Category 3 instrumentation be provided to 21 monitor Containment Air Grab Sample for release assessment, verification, and analysis for 22 Accident Sampling Capability. NEDO-33349 recommends that Containment Air Grab Sample 23 remains classified as an RG 1.97, Revision 4, Type E variable within the guidance of 24 NEDO-32991. With a safety evaluation dated June 12, 2001, the NRC staff accepted NEDO-25 32991. NEDO-32991 was reissued as NEDO-32991-A to incorporate the June 12, 2001 safety 26 evaluation. NEDO-32991-A contains justification for elimination of PASS.
27 28 The NRC staff agrees with the classification of Containment Air Grab Sample as an RG 1.97, 29 Revision 4, Type E variable within the guidance of NEDO-32991-A.
30 31 3.1.E.8 Type E Off-gas System Radiation Variables 32 33 3.1.E.8.1 Off-gas System Release Point Radiation 34 35 NEDO-33349 recommends that Off-gas System Release Point Radiation be classified as an 36 RG 1.97, Revision 4, Type E variable to Monitor Identified Pathway. The justification given in 37 NEDO-33349 is that Off-gas System Release Point Radiation is consistent with the identified 38 pathways contained in RG 1.97, Revision 4.
39 40 The NRC staff agrees with the classification of Off-gas System Release Point Radiation as an 41 RG 1.97, Revision 4, Type E variable to Monitor Identified Pathway for the off-gas system.
42 43 3.1.E.9 Type E Effluent Radioactivity Variables 44 45 3.1.E.9.1 Containment Effluent Radioactivity - Noble Gases 46 47 NEDO-33349 recommends that Containment Effluent Radioactivity - Noble Gases (from 48 identified release points including Standby Gas Treatment) be classified as an RG 1.97, 49 Revision 4, Type E variable. The justification given in NEDO-33349 is that Containment Effluent 1
Radioactivity - Noble Gases (from identified release points including Standby Gas Treatment) 2 provides the magnitude of release for Containment Effluent Radioactivity - Noble Gases.
3 4
The NRC staff agrees with the classification of Containment Effluent Radioactivity - Noble 5
Gases (from identified release points including Standby Gas Treatment) as an RG 1.97, 6
Revision 4, Type E variable to monitor Containment Effluent Radioactivity.
7 8
3.1.E.9.2 Effluent Radioactivity - Noble Gases 9
10 NEDO-33349 recommends that Effluent Radioactivity - Noble Gases (from buildings or areas 11 where penetrations and hatches are located, e.g., auxiliary building, fuel handling building, and 12 secondary containment, that are in direct contact with the primary containment) be classified as 13 an RG 1.97, Revision 4, Type E variable. The justification given in NEDO-33349 is that this 14 variable provides the magnitude of release for Effluent Radioactivity - Noble Gases.
15 16 The NRC staff agrees with the classification of Effluent Radioactivity - Noble Gases (from 17 buildings or areas where penetrations and hatches are located, e.g., auxiliary building, fuel 18 handling building, and secondary containment, that are in direct contact with primary 19 containment) as an RG 1.97, Revision 4, Type E variable to monitor Effluent Radioactivity.
20 21 3.2 Codes and Standards 22 23 RG 1.97, Revision 4, endorses IEEE Std. 497-2002, which references the latest applicable 24 codes and standards at the time of its issue. Regulatory Position 6 of RG 1.97, Revision 4, 25 recommends that if the NRC staff has endorsed a referenced code or standard in a regulatory 26 guide, that code or standard constitutes an acceptable method for use in meeting the related 27 regulatory requirement as described in the regulatory guide(s). Revisions 2 and 3 of RG 1.97 28 include references to other regulatory guides that endorse codes and standards that are earlier 29 versions of the RG 1.97, Revision 4, codes and standards.
30 31 Currently operating BWRs made commitments to either Revision 2 or 3 of RG 1.97, including 32 agreements and deviations to the referenced codes and standards. These agreements and 33 deviations were accepted by the NRC staff and form the current licensing bases for the plants 34 accident monitoring instrumentation.
35 36 NEDO-33349 discusses the application to currently operating BWRs of IEEE Std. 308-1991, 37 IEEE Standard Criteria for Class 1E Power Systems for Nuclear Power Generation Stations, 38 (Reference 23); IEEE Std. 323-1983, IEEE Standard for Qualifying Class 1E Equipment for 39 Nuclear Power Generating Stations, (Reference 24); IEEE Std. 344-1987, IEEE 40 Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power 41 Generating Stations, (Reference 25); IEEE Std. 384-1992, IEEE Standard Criteria for 42 Independence of Class 1E Equipment and Circuits, (Reference 26); IEEE Std. 1023-1988, 43 IEEE Guide for Application of Human Factors Engineering to Systems, Equipment, and 44 Facilities of Nuclear Power Generating Stations, (Reference 27); IEEE Std. 1289-1998, IEEE 45 Standard Guide for the Application of Human Factors Engineering in the Design of Computer-46 Based Monitoring and Control Displays for Nuclear Power Generating Stations, (Reference 28);
47 International Organization for Standardization (ISO) 9241-3-1992, Visual Display Terminals 48 (VDTs) Used for Office Tasks Ergonomics Design-Part 3: Visual Display Requirements, 49 (Reference 29); and American Society of Mechanical Engineers (ASME) NQA-1-2001, Quality 1
Assurance Requirements for Nuclear Facility Applications, (Reference 30). NEDO-33349 2
details the codes and standards that currently operating BWRs meet in lieu of the codes and 3
standards referenced by RG 1.97, Revision 4.
4 5
The NRC staff recognizes that no currently operating BWR fully meets the codes and standards 6
that are referenced by RG 1.97, Revision 4. Licensees shall review their RG 1.97, Revision 2 or 7
3, commitments with respect to codes and standards and shall either comply with the codes and 8
standards referenced by RG 1.97, Revision 4, where practicable, or provide justification for 9
maintaining their existing commitments to the RG 1.97, Revision 2 or 3, referenced codes and 10 standards.
11 12 3.3 Summary 13 14 The NRC staff agrees with the NEDO-33349 recommendation that the following types, 15 functions, and variables should be monitored in accordance with RG 1.97, Revision 4:
16 17 18 Rev 4 Type Function Variable Safety Evaluation Section A
Design Basis Event RPV Water Level 3.1.A A
Design Basis Event RPV Pressure 3.1.A A
Design Basis Event Drywell Pressure 3.1.A A
Design Basis Event Suppression Pool Temperature 3.1.A A
Design Basis Event Suppression Pool Water Level 3.1.A B
Reactivity Control Neutron Flux 3.1.B.1.1 B
Level Control RPV Water Level 3.1.B.2.1 B
Pressure Control RPV Pressure 3.1.B.3.1 B
Primary Containment Control Drywell Pressure/
Containment Pressure 3.1.B.4.1 B
Primary Containment Control Suppression Pool Temperature 3.1.B.4.2 B
Primary Containment Control Suppression Pool Water Level 3.1.B.4.3 C
Fuel Cladding RPV Water Level 3.1.C.1.1 C
Reactor Coolant Pressure Boundary RPV Water Level 3.1.C.2.1 C
Reactor Coolant Pressure Boundary RPV Pressure 3.1.C.2.2 C
Reactor Coolant Pressure Boundary Drywell Pressure/
Containment Pressure 3.1.C.2.3 C
Reactor Coolant Pressure Boundary Suppression Pool Water Level 3.1.C.2.4 C
Reactor Coolant Pressure Boundary Suppression Pool Temperature 3.1.C.2.5 C
Primary Containment Drywell Pressure/
Containment Pressure 3.1.C.3.1 Rev 4 Type Function Variable Safety Evaluation Section C
Primary Containment Suppression Pool Temperature 3.1.C.3.2 C
Primary Containment Suppression Pool Water Level 3.1.C.3.3 D
Containment System Drywell Pressure/
Containment Pressure 3.1.D.1.1 D
Containment System Suppression Pool Temperature 3.1.D.1.2 D
Containment System Suppression Pool Water Level 3.1.D.1.3 D
Containment System Drywell Temperature 3.1.D.1.4 D
RPS and CRD System Neutron Flux 3.1.D.2.1 D
RPS and CRD System Control Rod Position 3.1.D.2.2 D
SRV System SRV Position 3.1.D.3.1 D
RCIC System RCIC System Flow 3.1.D.4.1 D
RCIC System Condensate Storage Tank Water Level 3.1.D.4.2 D
HPCI or HPCS System HPCI or HPCS System Flow 3.1.D.5.1 D
HPCI or HPCS System Condensate Storage Tank Water Level 3.1.D.5.2 D
RHR System RHR System Flow 3.1.D.6.1 D
RHR System RHR System Valve Position 3.1.D.6.2 D
RHR System Suppression Chamber Spray Flow 3.1.D.6.3 D
RHR System Drywell Spray Flow 3.1.D.6.4 D
RHR System RHR System Heat Exchanger Outlet Temperature 3.1.D.6.5 D
LPCS System LPCS System Flow 3.1.D.7.1 D
LPCS System Core Spray Flow 3.1.D.7.2 D
Cooling Water System Cooling Water Temperature to ESF System Components 3.1.D.8.1 D
RHR Service Water System RHR Service Water System Flow 3.1.D.9.1 D
Essential Service Water System Essential Service Water System Flow 3.1.D.10.1 D
RPV Isolation System MSIV Position 3.1.D.11.1 D
RPV Isolation System Cleanup System Isolation Valve Position 3.1.D.11.2 D
RPV Isolation System Shutdown Cooling System Isolation Valve Position 3.1.D.11.3 D
RPV Isolation System Other RPV Normally Open Isolation Valve Position Inside Containment 3.1.D.11.4 D
RPV Isolation System Other RPV Normally Closed Isolation Valve Position Inside Containment That Require Opening for LOCA 3.1.D.11.5 Rev 4 Type Function Variable Safety Evaluation Section D
RPV Isolation System Other RPV Normally Open Isolation Valve Position Outside Containment 3.1.D.11.6 D
RPV Isolation System Other RPV Normally Closed Isolation Valve Position Outside Containment That Require Opening for Pipe Breaks Outside Containment 3.1.D.11.7 D
RPV Isolation System Other RPV Normally Closed Isolation Valve Position Outside Containment Do Not That Require Opening for Either LOCA or Pipe Breaks Outside Containment 3.1.D.11.8 D
Containment Isolation System Normally Open CIV Position Inside Containment 3.1.D.12.1 D
Containment Isolation System Normally Closed CIV Position Inside Containment That Require Opening for LOCA 3.1.D.12.2 D
Containment Isolation System CIV Position Outside Containment Require Opening for LOCA 3.1.D.12.3 D
Containment Isolation System Normally Closed CIV Position Inside or Outside Containment That Do Not Require Opening for LOCA 3.1.D.12.4 D
Secondary Containment System Secondary Containment Isolation Damper Position 3.1.D.13.1 D
Secondary Containment System Standby Gas Treatment Flow 3.1.D.13.2 D
Control Room Environment System Control Room Isolation Damper Position 3.1.D.14.1 D
Control Room Environment System Emergency Ventilation Damper Position 3.1.D.14.2 D
SLCS SLCS Flow or Pumps Running 3.1.D.15.1 D
SLCS SLCS Storage Tank Level 3.1.D.15.2 D
Power System AC and DC Power Status 3.1.D.16.1 D
Equipment Area Cooling Water System Equipment Area Cooling System Cooling Water Temperature 3.1.D.17.1 D
Essential Pneumatic Gas Supply System Essential Pneumatic Gas Supply Pressure 3.1.D.18.1 D
Isolation Condenser System Isolation Condenser System Shell-Side Water Level 3.1.D.19.1 D
Isolation Condenser System Isolation Condenser System Valve Position 3.1.D.19.2 Rev 4 Type Function Variable Safety Evaluation Section E
Containment Radiation Containment Area Radiation 3.1.E.1.1 E
Containment Radiation Reactor Building or Secondary Containment Area Radiation 3.1.E.1.2 E
Area Radiation Radiation Exposure Rate 3.1.E.2.1 E
Area Radiation Control Room Area Radiation 3.1.E.2.2 E
Airborne Radioactive Materials Released From Plant - Noble Gas and Vent Flow Rate Drywell Purge, Standby Gas Treatment System Purge, and Secondary Containment Purge 3.1.E.3.1 E
Airborne Radioactive Materials Released From Plant - Noble Gas and Vent Flow Rate Secondary Containment Purge 3.1.E.3.2 E
Airborne Radioactive Materials Released From Plant - Noble Gas and Vent Flow Rate Secondary Containment 3.1.E.3.3 E
Airborne Radioactive Materials Released From Plant - Noble Gas and Vent Flow Rate Auxiliary Building 3.1.E.3.4 E
Airborne Radioactive Materials Released From Plant - Noble Gas and Vent Flow Rate Common Plant Vent or Multipurpose Vent Discharge 3.1.E.3.5 E
Airborne Radioactive Materials Released From Plant - Noble Gas and Vent Flow Rate All Other Identified Release Points 3.1.E.3.6 E
Particulates and Halogens Particulates and Halogens 3.1.E.4.1 E
Environs Radiation and Radioactivity Airborne Radiohalogens and Particulates 3.1.E.5.1 E
Environs Radiation and Radioactivity Plant and Environs Radiation 3.1.E.5.2 E
Environs Radiation and Radioactivity Plant and Environs Radioactivity 3.1.E.5.3 E
Meteorological Wind Speed 3.1.E.6.1 E
Meteorological Wind Direction 3.1.E.6.2 E
Meteorological Estimation of Atmospheric Stability 3.1.E.6.3 E
Grab Sample Primary Coolant and Sump Grab Sample 3.1.E.7.1 E
Grab Sample Containment Air Grab Sample 3.1.E.7.2 E
Off-gas System Radiation Off-gas System Release Point Radiation 3.1.E.8.1 E
Effluent Radioactivity Containment Effluent 3.1.E.9.1 Rev 4 Type Function Variable Safety Evaluation Section Radioactivity - Noble Gases E
Effluent Radioactivity Effluent Radioactivity - Noble Gases 3.1.E.9.2 1
2 The NRC staff agrees with the NEDO-33349 recommendation that the following RG 1.97, 3
Revision 3, variables do not need to be monitored under RG 1.97, Revision 4:
4 5
Rev 3 Type Rev 3 Category Revision 3 Function Variable Safety Evaluation Section B
3 Reactivity Control Control Rod Position 3.1.B.1.2 B
3 Reactivity Control RCS Soluble Boron Concentration 3.1.B.1.3 B
N/A Core Cooling BWR Core Temperature 3.1.B.2.2 B
1 Maintaining Reactor Coolant System Integrity Drywell Pressure 3.1.B.3.2 B
1 Maintaining Reactor Coolant System Integrity Drywell Sump Level 3.1.B.3.3 B
1 Maintaining Containment Integrity Primary Containment Isolation Valve Position 3.1.B.4.4 C
1 Fuel Cladding Radioactivity Concentration or Radiation Level in Circulating Primary Coolant 3.1.C.1.2 C
3 Fuel Cladding Analysis of Primary Coolant 3.1.C.1.3 C
N/A Fuel Cladding BWR Core Temperature 3.1.C.1.4 C
3 Reactor Coolant Pressure Boundary Primary Containment Area Radiation 3.1.C.2.6 C
1 Reactor Coolant Pressure Boundary Drywell Drain Sump Level 3.1.C.2.7 C
1 Primary Containment RPV Pressure 3.1.C.3.4 C
1 Primary Containment Containment and Drywell Hydrogen 3.1.C.3.5 C
1 Primary Containment Containment and Drywell Oxygen 3.1.C.3.6 C
3 Primary Containment Containment Effluent Radioactivity - Noble Gases 3.1.C.3.7 C
2 Primary Containment Effluent Radioactivity -
Noble Gases 3.1.C.3.8 C
2 (Rev. 2)
Primary Radiation Exposure Rate 3.1.C.3.9 Rev 3 Type Rev 3 Category Revision 3 Function Variable Safety Evaluation Section Containment D
2 Primary Containment Related systems Suppression Chamber Spray Flow 3.1.D.1.5 D
2 Primary Containment Related Systems Drywell Spray Flow 3.1.D.1.6 D
3 Condensate and Feedwater System Main Feedwater Flow 3.1.D.20.1 D
2 Main Steam System MSIV Leakage Control System Pressure 3.1.D.21.1 D
3 Radwaste System High Radioactivity Liquid Tank Level 3.1.D.22.1 1
4.0 LIMITATIONS AND CONDITIONS 2
3 4.1 Type A Variables 4
5 Each licensee that uses NEDO-33349 should review its plant design against NEDO-33349 for 6
the selection of Type A variables. For some plants, the NEDO-33349 recommendation for 7
Type A variables may not be applicable. Some plants may have additional Type A variables.
8 Other plants may need to justify not including individual Type A variables recommended by 9
10 11 4.2 Relaxations or Downgrades 12 13 Any relaxation or downgrade in design and qualification criteria for RG 1.97, Revision 4, 14 instrumentation from the recommendations in RG 1.97, Revision 3, does not affect the design 15 and qualification criteria for instrumentation required by 10 CFR 50.34, 10 CFR 50.44, or 16 NUREG-0737. The requirements of 10 CFR 50.34, 10 CFR 50.44, and NUREG-0737 take 17 precedence over RG 1.97. Even though RG 1.97, Revision 4, may allow relaxations or 18 downgrades from the recommendations of RG 1.97, Revision 3, the recommendations of 19 RG 1.97, Revision 4, cannot replace the requirements of 10 CFR 50.34, 10 CFR 50.44, and 20 NUREG-0737.
21 22 Any relaxations or downgrades from previous design and qualification criteria for 23 instrumentation covered by 10 CFR 50.44 are applicable only to the instrumentation that is 24 specified in that section, of the regulations, and cannot be extended to other instrumentation.
25 26 4.3 Reactor Coolant System Soluble Boron Concentration 27 28 The NRC staff agrees that RCS Soluble Boron Concentration (Grab Sample) is not a key 29 variable for providing information on the accomplishment of the Reactivity Control function, and, 30 therefore, may be reclassified as not being a RG1.97, Revision 4, Type B variable. However, 31 this does not release licensees from meeting the requirements of 10 CFR 50.34(f)(1)(viii) and 32 Item II.B.3 of NUREG-0737.
33 4.4 Reactor Pressure Vessel Water Level 1
2 The NRC agrees with the classification of RPV Water Level as an RG 1.97, Revision 4, Type C 3
key variable to provide information about the integrity of the Fuel Cladding fission product 4
barrier. However, since a decrease in RPV Water Level is only a precursor to fuel damage, 5
each licensee should identify plant specific backup instrumentation to provide information to 6
determine if core damage has occurred. This plant specific backup instrumentation does not 7
need to meet the RG 1.97, Revision 4, Type C design and qualification criteria.
8 9
4.5 Analysis of Primary Coolant 10 11 The NRC staff agrees that Analysis of Primary Coolant is not a key variable for providing 12 information on the integrity of the Fuel Cladding fission product barrier and, therefore, may be 13 reclassified as not being an RG 1.97, Revision 4, Type C variable for the Fuel Cladding fission 14 product barrier. However, this does not release licensees from meeting the requirements of 15 10 CFR 50.34(f)(1)(viii) and Item II.B.3 of NUREG-0737.
16 17 4.6 Containment and Drywell Hydrogen 18 19 The NRC staff agrees that Containment and Drywell Hydrogen is not a key variable for 20 providing information on the integrity of the Primary Containment fission product barrier and, 21 therefore, may be reclassified as not being an RG 1.97, Revision 4, Type C variable for the 22 Primary Containment fission product barrier. However, this does not release licensees from 23 meeting the requirements of 10 CFR 50.44.
24 25 4.7 Containment and Drywell Oxygen 26 27 The NRC staff agrees that Containment and Drywell Oxygen is not a key variable for providing 28 information on the integrity of the Primary Containment fission product barrier and, therefore, 29 may be reclassified as not being an RG 1.97, Revision 4, Type C variable for the Primary 30 Containment fission product barrier. However, this does not release licensees from meeting the 31 requirements of 10 CFR 50.44.
32 33 4.8 Safety Relief Valve Position 34 35 The NRC staff agrees with the classification of SRV Position as an RG 1.97, Revision 4, Type D 36 variable, without environmental or seismic qualification, to provide information on the SRV 37 System performance. However, this does not release licensees from meeting the requirements 38 of 10 CFR 50.34(f) or Item II.D.3 of NUREG-0737.
39 40 4.9 Isolation Condenser System Shell-Side Water Level and Isolation Condenser 41 System Valve Position 42 43 The NRC staff agrees with the classification of Isolation Condenser System Shell-Side Water 44 Level and Isolation Condenser System Valve Position as being RG 1.97, Revision 4, Type D 45 variables to provide information on the status of Isolation Condenser System performance, for 46 plants with isolation condensers. Plants with isolation condensers should review their plant 47 design and propose plant specific Type B variables to provide information on the 48 accomplishment of the Isolation Condenser function and Type D variables to provide 1
information on the status of the Isolation Condenser System performance.
2 3
4.10 Main Steam Isolation Valve Leakage Control System Pressure 4
5 The NRC staff agrees with the reclassification of MSIV Leakage Control System Pressure as 6
not being an RG 1.97, Revision 4, Type D variable for the Main Steam System. Each licensee 7
should identify previous approval of the elimination of MSIV leakage control system, justify the 8
elimination of the MSIV leakage control system, or provide instrumentation for MSIV Leakage 9
Control System Pressure.
10 11 4.11 Containment Area Radiation 12 13 The NRC staff agrees with the classification of Containment Area Radiation - High Range as an 14 RG 1.97, Revision 4, Type E variable to monitor identified pathways, provided that the 15 instrumentation meets the plant specific licensing commitments to Item II.F.1 of NUREG-0737 16 and RG 1.97, Revision 2 or 3, Category 1 criteria, instead of the RG 1.97, Revision 4, Type E 17 criteria. However, the classification of Containment Area Radiation - High Range as an 18 RG 1.97, Type E variable does not release licensees from meeting the plant specific licensing 19 commitments related to the requirements of Item II.F.1 of NUREG-0737. Relaxations and 20 downgrades in 10 CFR 50.44 cannot be extended to instrumentation for Containment Area 21 Radiation - High Range.
22 23 4.12 Codes and Standards 24 25 The NRC staff recognizes that no currently operating BWR fully meets the codes and standards 26 that are referenced by RG 1.97, Revision 4. Licensees should review their RG 1.97, Revision 2 27 or 3, commitments with respect to codes and standards and should either comply with the 28 codes and standards referenced by RG 1.97, Revision 4, where practicable, or provide 29 justification for maintaining their existing commitments to the RG 1.97, Revision 2 or 3, 30 referenced codes and standards.
31 32
5.0 CONCLUSION
33 34 Based on the above evaluation, the NRC staff concludes that the proposed application of 35 RG 1.97, Revision 4, to currently licensed BWR plants, as detailed in NEDO-33349 and 36 modified as stated above, is acceptable for currently licensed BWR plants. Licensees electing 37 to adopt NEDO-33349 should perform a plant specific review to determine its applicability.
38 Licensees should also address the limitations and conditions of this safety evaluation.
39 Licensees should submit a plant specific change to their commitments to RG 1.97 for NRC staff 40 review.
41 42 The licensees submittal should include a table that compares each RG 1.97, Revision 2 or 3, 43 variable and the resultant RG 1.97, Revision 4 variable. This information should also include, 44 for each Type A, B, C, D, or E variable under RG 1.97, Revision 4, in a table format: instrument 45 range, environmental qualification, seismic qualification, quality assurance, redundancy, location 46 of sensors, power supply, and location of display.
47 48 49 The attachment to this safety evaluation provides a detailed list of each RG 1.97, Revision 3, 1
variable and NEDO-33349 proposed changes that have been reviewed and accepted by the 2
NRC staff.
3 4
6.0 REFERENCES
5 6
- 1.
Letter from R. C. Bunt Boiling Water Reactor Owners Group (BWROG), submitting 7
Licensing Topical Report (LTR) NEDO-33349, Revision 1, ABWR Application to 8
Regulatory Guide 1.97, Revision 4,@ August 31, 2007 (Agencywide Documents Access 9
and Management System (ADAMS) Accession No. ML072470741).
10 11
- 2.
Regulatory Guide 1.97, Revision 4, Criteria for Accident Monitoring Instrumentation for 12 Nuclear Power Plants, NRC Office of Nuclear Regulatory Research, June 2006 (ADAMS 13 Accession No. ML061580448).
14 15
- 3.
Letter from D. W. Coleman, BWROG, Responses to Requests for Additional Information 16 (RAIs) Regarding the Submittal of BWROG LTR NEDO-33349, Revision 1, BWR 17 Application to Regulatory Guide 1.97, Revision 4, October 31, 2008 (ADAMS Accession 18 No. ML083090576).
19 20
- 4.
Letter from D. W. Coleman, BWROG, Responses to Supplemental Request for Additional 21 Information (RAIs) dated June 16, 2009, Regarding Boiling Water Reactor Owners Group 22 Licensing Topical Report (LTR) NEDO-33349, Revision 1, BWR Application to Regulatory 23 Guide 1.97, Revision 4, September 14, 2009 (ADAMS Accession No. ML092600272).
24 25
- 5.
Regulatory Guide 1.97, Revision 2, AInstrumentation for Light-Water-Cooled Nuclear 26 Power Plants to Assess Plant and Environs Conditions During and Following an Accident,@
27 NRC Office of Nuclear Regulatory Research, December 1980 (ADAMS Accession No.
28 ML060750525).
29 30
- 6.
Regulatory Guide 1.97, Revision 3, AInstrumentation for Light-Water-Cooled Nuclear 31 Power Plants to Assess Plant and Environs Conditions During and Following an Accident,@
32 NRC Office of Nuclear Regulatory Research, May 1983 (ADAMS Accession No.
33 ML003740282).
34 35
- 7.
IEEE Std. 497-2002, IEEE Standard Criteria for Accident Monitoring Instrumentation for 36 Nuclear Power Generating Stations, Institute of Electrical and Electronics Engineers.
37 38
- 8.
Title 10, of the Code of Federal Regulations, Part 50, Domestic Licensing of Production 39 and Utilization Facilities.
40 41
- 9.
NUREG-0737, Clarification of TMI Action Plan Requirements, NRC Office of Nuclear 42 Reactor Regulation, November 30, 1980 (ADAMS Accession No. ML051400209).
43 44
- 10. Supplement No. 1 to NUREG-0737, ARequirements for Emergency Response Capability 45 (Generic Letter No. 82-33), December 17, 1982 (ADAMS Accession No. ML031080548).
46 47
- 11. NEDO-31558, Position on NRC Regulatory Guide 1.97, Revision 3, Requirements for 48 Post-Accident Neutron Monitoring System, April 1, 1988.
49 Field Code Changed
- 12. Safety Evaluation Boiling Water Reactors, Regulatory Guide 1.97, Post-Accident Neutron 1
Flux Monitoring Instrumentation, NRC Office of Nuclear Reactor Regulation, January 13, 2
1993.
3 4
- 13. NEDO-31558-A, Position on NRC Regulatory Guide 1.97, Revision 3, Requirements for 5
Post-Accident Neutron Monitoring System, March 1993.
6 7
- 14. NEDO-33160, Regulatory Relaxation for the Post Accident SRV Position Indication 8
System, December 13, 2004 (ADAMS Accession No. ML043510165).
9 10
- 15. Safety Evaluation, Final Safety Evaluation for Boiling Water Reactor Owners Group 11 (BWROG) Topical Report (TR) NEDO-33160, Regulatory Relaxation for the Post Accident 12 SRV [Safety Relief Valve] Position Indication System, NRC Office of Nuclear Reactor 13 Regulation, September 25, 2006 (ADAMS Accession No. ML062210067).
14 15
- 16. NEDO-33160-A, Regulatory Relaxation for the Post Accident SRV Position Indication 16 System, October 2006 (ADAMS Accession No. ML062910165).
17 18
- 17. NEDC-31858P, Revision 2, BWROG Report for Increasing MSIV Leakage Limits and 19 Elimination of Leakage Control Systems, September 1993.
20 21
- 18. Safety Evaluation, Safety Evaluation of GE Topical Report NEDC-31858P, Revision 2, 22 BWROG Report for Increasing MSIV Leakage Limits and Elimination of Leakage Control 23 Systems, September 1993, NRC Office of Nuclear Reactor Regulation, March 3, 1999 24 (ADAMS Accession No. ML010640286).
25 26
- 19. NEDC-31858P-A, Revision 2, BWROG Report for Increasing MSIV Leakage Limits and 27 Elimination of Leakage Control Systems, August 1999.
28 29
- 20. NEDO-32991, Regulatory Relaxation for BWR Post Accident Sampling Stations (PASS),
30 November 30, 2000 (ADAMS Accession No. ML012260048).
31 32
- 21. Safety Evaluation, Safety Evaluation Related to Topical Report NEDO-32991, Regulatory 33 Relaxation for BWR Post Accident Sampling Stations (PASS), NRC Office of Nuclear 34 Reactor Regulation, June 12, 2001 (ADAMS Accession No. ML011630016).
35 36
- 22. NEDO-32991-A, Regulatory Relaxation for BWR Post Accident Sampling Stations 37 (PASS), August 2001 (ADAMS Accession No. ML012260048).
38 39
- 23. IEEE Std. 308-1991, IEEE Standard Criteria for Class 1E Power Systems for Nuclear 40 Power Generation Stations, Institute of Electrical and Electronics Engineers.
41 42
- 24. IEEE Std. 323-1983, IEEE Standard for Qualifying Class 1E Equipment for Nuclear 43 Power Generating Stations, Institute of Electrical and Electronics Engineers.
44 45
- 25. IEEE Std. 344-1987, IEEE Recommended Practice for Seismic Qualification of Class 1E 46 Equipment for Nuclear Power Generating Stations, Institute of Electrical and Electronics 47 Engineers.
48 49
- 26. IEEE Std. 384-1992, IEEE Standard Criteria for Independence of Class 1E Equipment 1
and Circuits, Institute of Electrical and Electronics Engineers.
2 3
- 27. IEEE Std. 1023-1988, IEEE Guide for Application of Human Factors Engineering to 4
Systems, Equipment, and Facilities of Nuclear Power Generating Stations, Institute of 5
Electrical and Electronics Engineers.
6 7
- 28. IEEE Std. 1289-1998, IEEE Standard Guide for the Application of Human Factors 8
Engineering in the Design of Computer-Based Monitoring and Control Displays for Nuclear 9
Power Generating Stations, Institute of Electrical and Electronics Engineers.
10 11
- 29. ISO 9241-3-1992, Visual Display Terminals (VDTs) Used for Office Tasks Ergonomics 12 Design-Part 3: Visual Display Requirements, International Organization for 13 Standardization.
14 15
- 30. ASME NQA-1-2001, Quality Assurance Requirements for Nuclear Facility Applications, 16 American Society of Mechanical Engineers.
17 18
Attachment:
NEDO-33349 Variables and RG 1.97, Revision 3, Variables 19 20 Principle Contributors:
Barry Marcus, NRR/DE/EICB 301-415-2823 21 Tai Huang, NRR/DSS/SRXB 301-415-2867 22 Steve LaVie, NSIR/DPR/IRIB 301-415-1081 23 24 Date:
25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Field Code Changed
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables ENCLOSURE NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable A
Design Basis Event RPV Water Level A
1 Design Basis Event Plant Specific 3.1.A List of Type A variables may vary for specific plants A
Design Basis Event RPV Pressure A
1 Design Basis Event Plant Specific 3.1.A List of Type A variables may vary for specific plants A
Design Basis Event Drywell Pressure A
1 Design Basis Event Plant Specific 3.1.A List of Type A variables may vary for specific plants A
Design Basis Event Suppression Pool Temperature A
1 Design Basis Event Plant Specific 3.1.A List of Type A variables may vary for specific plants A
Design Basis Event Suppression Pool Water Level A
1 Design Basis Event Plant Specific 3.1.A List of Type A variables may vary for specific plants B
Reactivity Control Neutron Flux B
1 Reactivity Control Neutron Flux 3.1.B.1.1 NEDO-31558 (see 3.1.D.2.1)
B 3
Reactivity Control Control Rod Position 3.1.B.1.2 Type D (see 3.1.D.2.2)
B 3
Reactivity Control RCS Soluble Boron Concentration 3.1.B.1.3 B
Level Control RPV Water Level B
1 Core Cooling Coolant Level in Reactor Vessel 3.1.B.2.1 B
N/A Core Cooling BWR Core 3.1.B.2.2
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable Temperature B
Pressure Control RPV Pressure B
1 Maintaining Reactor Coolant System Integrity RPV Pressure 3.1.B.3.1 B
1 Maintaining Reactor Coolant System Integrity Drywell Pressure 3.1.B.3.2 B
1 Maintaining Reactor Coolant System Integrity Drywell Sump Level 3.1.B.3.3 B
Primary Containment Control Drywell Pressure/Containment Pressure B
1 Maintaining Containment Integrity Primary Containment Pressure 3.1.B.4.1 B
Primary Containment Control Suppression Pool Temperature 3.1.B.4.2 B
Primary Containment Control Suppression Pool Water Level 3.1.B.4.3 B
1 Maintaining Containment Integrity Primary Containment Isolation Valve Position 3.1.B.4.4 Type D (see 3.1.D.12)
C Fuel Cladding RPV Water Level 3.1.C.1.1 C
1 Fuel Cladding Radioactivity Concentration or Radiation Level in Circulating Primary Coolant 3.1.C.1.2 C
3 Fuel Cladding Analysis of Primary Coolant 3.1.C.1.3 C
N/A Fuel Cladding BWR Core Temperature 3.1.C.1.4 C
Reactor Coolant RPV Water Level 3.1.C.2.1
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable Pressure Boundary C
Reactor Coolant Pressure Boundary RPV Pressure C
1 Reactor Coolant Pressure Boundary RPV Pressure 3.1.C.2.2 C
Reactor Coolant Pressure Boundary Drywell Pressure/Containment Pressure C
1 Reactor Coolant Pressure Boundary Drywell Pressure 3.1.C.2.3 C
Reactor Coolant Pressure Boundary Suppression Pool Water Level C
1 Reactor Coolant Pressure Boundary Suppression Pool Water Level 3.1.C.2.4 C
Reactor Coolant Pressure Boundary Suppression Pool Temperature 3.1.C.2.5 C
3 Reactor Coolant Pressure Boundary Primary Containment Area Radiation 3.1.C.2.6 Type E (see 3.1.E.1.1)
C 1
Reactor Coolant Pressure Boundary Drywell Drain Sump Level 3.1.C.2.7 C
Primary Containment Drywell Pressure/Containment Pressure 3.1.C.3.1 C
Primary Containment Suppression Pool Temperature 3.1.C.3.2 C
Primary Containment Suppression Pool Water Level 3.1.C.3.3 C
1 Containment RPV Pressure 3.1.C.3.4 C
1 Containment Containment and Drywell Hydrogen 3.1.C.3.5 10 CFR 50.44 C
1 Containment Containment and Drywell Oxygen 3.1.C.3.6 10 CFR 50.44 C
3 Containment Containment Effluent Radioactivity - Noble Gases 3.1.C.3.7 Type E (see 3.1.E.9.1)
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable C
2 Containment Effluent Radioactivity -
Noble Gases 3.1.C.3.8 Type E (see 3.1.E.9.2)
C 2 (Rev. 2)
Containment Radiation Exposure Rate 3.1.C.3.9 Type E (see 3.1.E.2.1)
D Containment System Drywell Pressure/Containment Pressure D
2 Primary Containment Related Systems Drywell Pressure 3.1.D.1.1 D
Containment System Suppression Pool Temperature D
2 Primary Containment Related Systems Suppression Pool Temperature 3.1.D.1.2 D
Containment System Suppression Pool Water Level D
2 Primary Containment Related Systems Suppression Pool Water Level 3.1.D.1.3 D
Containment System Drywell Temperature D
2 Primary Containment Related Systems Drywell Atmosphere Temperature 3.1.D.1.4 D
2 Primary Containment Related Systems Suppression Chamber Spray Flow 3.1.D.1.5 D
2 Primary Containment Related Systems Drywell Spray Flow 3.1.D.1.6 D
Reactor Protection System and Control Rod Drive System Neutron Flux B
1 Reactivity Control Neutron Flux 3.1.D.2.1 NEDO-31558 D
Reactor Protection System and Control Rod Drive System Control Rod Position B
3 Reactivity Control Control Rod Position 3.1.D.2.2 No EQ or Seismic D
2 Main Steam System Primary SRV Position 3.1.D.3.1 NEDO-33160 No EQ or Seismic D
RCIC System RCIC System Flow D
2 Safety System RCIC Flow 3.1.D.4.1 No EQ or Seismic D
RCIC System Condensate Storage D
3 Condensate and Condensate Storage 3.1.D.4.2
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable Tank Water Level Feedwater System Tank Level No EQ or Seismic D
HPCI or HPCS System HPCI or HPCS System Flow D
2 Safety System HPCI Flow 3.1.D.5.1 D
HPCI or HPCS System Condensate Storage Tank Water Level D
3 Condensate and Feedwater System Condensate Storage Tank Level 3.1.D.5.2 No EQ or Seismic D
2 Residual Heat Removal Systems RHR System Flow 3.1.D.6.1 D
RHR System RHR System Valve Position 3.1.D.6.2 D
RHR System Suppression Chamber Spray Flow D
2 Primary Containment Related Systems Suppression Chamber Spray Flow 3.1.D.6.3 Alternate Instrument D
RHR System Drywell Spray Flow D
2 Primary Containment Related Systems Drywell Spray Flow 3.1.D.6.4 Alternate Instrument D
RHR System RHR System Heat Exchanger Outlet Temperature D
2 Residual Heat Removal Systems RHR Heat Exchanger Outlet Temperature 3.1.D.6.5 D
LPCS System LPCS System Flow D
2 Safety Systems LPCI System Flow 3.1.D.7.1 D
LPCS System Core Spray Flow D
2 Safety System Core Spray System Flow 3.1.D.7.2 D
Cooling Water System Cooling Water Temperature to ESF System Components D
2 Cooling Water System Cooling Water Temperature to ESF System Components 3.1.D.8.1 Alternate instrument D
RHR Service Water System RHR Service Water System Flow D
2 Cooling Water System Cooling Water Flow to ESF System Components 3.1.D.9.1 Alternate instrument D
Essential Service Water System Essential Service Water System Flow 3.1.D.10.1 Alternate Instrument D
RPV Isolation System MSIV Position 3.1.D.11.1
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable D
RPV Isolation System Cleanup System Isolation Valve Position 3.1.D.11.2 D
RPV Isolation System Shutdown Cooling System Isolation Valve Position 3.1.D.11.3 D
RPV Isolation System Other RPV Normally Open Isolation Valve Position Inside Containment 3.1.D.11.4 D
RPV Isolation System Other RPV Normally Closed Isolation Valve Position Inside Containment Require Opening for LOCA 3.1.D.11.5 D
RPV Isolation System Other RPV Normally Open Isolation Valve Position Outside Containment 3.1.D.11.6 D
RPV Isolation System Other RPV Normally Closed Isolation Valve Position Outside Containment Require Opening for Pipe Breaks Outside Containment 3.1.D.11.7
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable D
RPV Isolation System Other RPV Normally Closed Isolation Valve Position Outside Containment Do Not Require Opening for either LOCA or Pipe Breaks Outside Containment 3.1.D.11.8 No EQ or Seismic D
Containment Isolation System Normally Open CIV Position Inside Containment B
1 Maintaining Containment Integrity Primary Containment Isolation Valve Position 3.1.D.12.1 D
Containment Isolation System Normally Closed CIV Position Inside Containment Require Opening for LOCA B
1 Maintaining Containment Integrity Primary Containment Isolation Valve Position 3.1.D.12.2 D
Containment Isolation System CIV Position Outside Containment Require Opening for LOCA B
1 Maintaining Containment Integrity Primary Containment Isolation Valve Position 3.1.D.12.3 D
Containment Isolation System Normally Closed CIV Position Inside or Outside Containment Do Not Require Opening for LOCA B
1 Maintaining Containment Integrity Primary Containment Isolation Valve Position 3.1.D.12.4 No EQ or Seismic D
Secondary Containment System Secondary Containment Isolation Damper Position 3.1.D.13.1 D
Secondary Containment System Standby Gas Treatment Flow 3.1.D.13.2 D
Control Room Environment System Control Room Isolation Damper Position 3.1.D.14.1
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable D
Control Room Environment System Emergency Ventilation Damper Position D
2 Ventilation Systems Emergency Ventilation Damper Position 3.1.D.14.2 Alternate Instrument D
SLCS System SLCS Flow or Pumps Running D
2 Safety Systems SLCS Flow 3.1.D.15.1 No EQ or Seismic D
SLCS System SLCS Storage Tank Level D
2 Safety Systems SLCS Storage Tank Level 3.1.D.15.2 No EQ or Seismic D
Power Systems AC and DC Power Status D
2 Power Supplies Status of Standby Power 3.1.D.16.1 D
Equipment Area Cooling Water System Equipment Area Cooling System Cooling Water Temperature 3.1.D.17.1 D
Essential Pneumatic Gas Supply System Essential Pneumatic Gas Supply Pressure 3.1.D.18.1 D
Isolation Condenser System Isolation Condenser System Shell-Side Water Level D
2 Isolation Condenser System Isolation Condenser System Shell-Side Water Level 3.1.D.19.1 D
Isolation Condenser System Isolation Condenser System Valve Position D
2 Isolation Condenser System Isolation Condenser System Valve Position 3.1.D.19.2 D
3 Condensate and Feedwater System Main Feedwater Flow 3.1.D.20.1 D
2 Main Steam System MSIV Leakage Control System Pressure 3.1.D.21.1 D
3 Radwaste System High Radioactivity Liquid Tank Level 3.1.D.22.1 E
Containment Radiation Containment Area Radiation E
1 Containment Radiation Primary Containment Area Radiation - High Range 3.1.E.1.1 NUREG-0737 & RG 1.97 Rev 2 or 3
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable E
Containment Radiation Reactor Building or Secondary Containment Area Radiation E
2 (Mark III) 3 (Mark 1
& 2)
Containment Radiation Reactor Building or Secondary Containment Area Radiation 3.1.E.1.2 E
Area Radiation Radiation Exposure Rate E
3 Area Radiation Radiation Exposure Rate 3.1.E.2.1 E
Area Radiation Control Room Area Radiation 3.1.E.2.2 E
Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Drywell Purge, Standby Gas Treatment System Purge, and Secondary Containment Purge E
3 Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Drywell Purge and Standby Gas Treatment System Purge 3.1.E.3.1 Plant Specific E
Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Secondary Containment Purge E
3 Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Secondary Containment Purge 3.1.E.3.2 Plant Specific E
Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Secondary Containment E
3 Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Secondary Containment 3.1.E.3.3 Plant Specific E
Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Auxiliary Building E
3 Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Auxiliary Building 3.1.E.3.4 Plant Specific
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable E
Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Common Plant Vent or Multipurpose Vent Discharge E
3 Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate Common Plant Vent or Multipurpose Vent Discharge 3.1.E.3.5 Plant Specific E
Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate All Other Identified Release Points E
3 Airborne Radioactive Materials Released From Plant - Noble Gases and Vent Flow Rate All Other Identified Release Points 3.1.E.3.6 Plant Specific E
Particulates and Halogens Particulates and Halogens - All Identified Plant Release Points Sampling With Onsite Analysis Capability E
3 Airborne Radioactive Materials Released From Plant -
Particulates and Halogens Particulates and Halogens - All Identified Plant Release Points Sampling With Onsite Analysis Capability 3.1.E.4.1 E
Environs Radiation and Radioactivity Airborne Radiohalogens and Particulates E
3 Environs Radiation and Radioactivity Airborne Radiohalogens and Particulates 3.1.E.5.1 Portable Instruments Acceptable E
Environs Radiation and Radioactivity Plant and Environs Radiation E
3 Environs Radiation and Radioactivity Plant and Environs Radiation 3.1.E.5.2 Portable Instruments Acceptable E
Environs Radiation and Radioactivity Plant and Environs Radioactivity E
3 Environs Radiation and Radioactivity Plant and Environs Radioactivity 3.1.E.5.3 Portable Instruments Acceptable E
Meteorological Wind Speed E
3 Meteorological Wind Speed 3.1.E.6.1 E
Meteorological Wind Direction E
3 Meteorological Wind Direction 3.1.E.6.2 E
Meteorological Estimation of Atmospheric Stability E
3 Meteorological Estimation of Atmospheric Stability 3.1.E.6.3
ATTACHMENT - NEDO-33349 Variables and RG 1.97, Revision 3, Variables NEDO-33349 RG 1.97, Revision 3 Safety Evaluation Section / Remarks Type Function Variable Type Category Function Variable E
Grab Sample Primary Containment Sump Grab Sample E
3 Accident Sampling Capability Primary Coolant and Sump Grab Sample 3.1.E.7.1 NEDO-32991 E
Grab Sample Containment Air Grab Sample E
3 Accident Sampling Capability Containment Air Grab Sample 3.1.E.7.2 NEDO-32991 E
Off-gas System Radiation Off-gas System Release Point Radiation 3.1.E.8.1 E
Effluent Radioactivity Containment Effluent Radioactivity - Noble Gases C
3 Containment Containment Effluent Radioactivity - Noble Gases 3.1.E.9.1 E
Effluent Radioactivity Effluent Radioactivity -
Noble Gases C
3 Containment Effluent Radioactivity -
Noble Gases 3.1.E.9.2 1