ML13323A458

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Rev 0 to San Onofre Nuclear Generating Station Unit 1,Reg Guide 1.97 Review
ML13323A458
Person / Time
Site: San Onofre 
Issue date: 12/13/1985
From: Cotton C, Hess R, Sellers C
CYGNA ENERGY SERVICES
To:
Shared Package
ML13323A459 List:
References
RTR-REGGD-01.097, RTR-REGGD-1.097 TR-85124-02, TR-85124-02-R00, TR-85124-2, TR-85124-2-R, NUDOCS 8601090487
Download: ML13323A458 (60)
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Text

0 San Onofre Nuclear Generating Station Unit 1 Regulatory Guide 1.97 Review Prepared for:

Southern California Edison Company Cygna Report Number:

TR-85124-02 Revision 0 December 1985 Prepared by:

6ZA I

L_

Date

/_//2/F Chris Cotton Reviewed hy:

1j. 141-Date /IZ/35 Robert W. Hess Approved by:

Date tzIhar Craig D. Sellers 8601090487 851216 PDR ADOCK 05000206 F

PDR Cygna Energy Services 101 California Street Suite 1000 T -

San Francisco, California 94111

Section TABLE OF CONTENTS Table of Contents.......................... ***************

1 List of Tables............................................ iii 1.0 Introduction..

....................................... 1-1 2.0 Method of Review......................................... 2-1 2.1 SONGS 1 Variables.................................... 2-2 2.2 SONGS 1 Instruments.................................. 2-2 2.3 Comparison with R.G. 1.97 Requirements............... 2-3 2.4 Justifications/Recommendations....................... 2-3 3.0 SONGS 1 Variables......................................... 3-1 3.1 Type I: Variables Monitored to Initiate Preplanned Manual Actions..........................

3-1 3.2 Type II: Variables Monitored to Ensure Accomplishment of Plant Safety Functions........... 3-2 3.3 Type III: Variables Monitoring Radioactive Releases.. 3-2 4.0 SONGS 1 Specific Instruments............................. 4-1 4.1 Equipment Qualification Status....................... 4-1 4.2 Instrument Redundancy and Separation................. 4-2 4.3 Instrument Loop Power Source......................... 4-2 4.4 Quality Assurance....................................

4-2 4.5 Display Type......................................... 4-3 4.6 Range of Instruments.................................

4-3 5.0 Comparison with Regulatory Guide 1.97 Requirements........ 5-1 5.1 SONGS 1 Specific Instruments.........................

5-2 6.0 Justification of Discrepancies and Recommendations........ 6-1 6.1 Suberiticality....................................... 6-2 6.2 Core Cooling......................................... 6-3 6.3 Secondary Heat Sink...................................

6-7 6.4 RCS Integrity........................................ 6-10 6.5 Containment Integrity................................6-14 Southern California Edison Company Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

TABLES OF CONTENTS, continued 6.6 RCS Inventory........********************************6-16 6.7 Effluent Radiation............**..........

6-17 7.0 References.......................

7-1 Southern California Edison Company Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

T etLIST OF TABLES Table Title Page 3-1 SONGS 1 Variables - Type I.........................

3-4 3-2 SONGS 1 Variables - Type II........................

3-7 3-3 SONGS 1 Variables -

Type III.......................

3-10 5-1 R.G. 1.97 Design and Qualification Criteria........ 5-3 5-2 Comparison of SONGS 1 Site Specific Variables and RG 1.97 Generic Variables..............

5-4 5-3 SONGS 1 Variables - Type I Design/Qualification Compliance with R.G. 1.97..........................

5-12 5-4 SONGS 1 Variables -

Type II Design/Qualification Compliance with R.G. 1.97........................ 0.....

5-15 5-5 SONGS 1 Variables -

Type III Design/Qualification Compliance with R.G. 1.97.............................

5-20 Southern California Edison Company 111 Regulatory Guide 1.97 Review SReport No.

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1.0 INTRODUCTION

This report describes the review performed to identify and evaluate the instrumentation necessary for San Onofre Nuclear Generating Station Unit 1 (SONGS 1) to assess plant and environs conditions during and following an accident. The SONGS 1 Emergency Operating Instructions (EOIs) [1], and SONGS Emergency Plan (EP) [2], were reviewed to determine the specific variables that provide operators with the information required to safely shut down the plant and monitor radioactive releases that may pose a threat to the public.

Plant design documents were used as the basis for selecting instrumentation installed at SONGS 1 that provides the means of monitoring the critical variables.

The degree of compliance of the available instrumentation that monitors the critical plant variables was evaluated against the design and qualification requirements of Regulatory Guide 1.97 Rev.

2 (RG 1.97)

[3].

Supporting justifications are provided for instrumentation that meets the intent of the Regulatory Guide but deviates from the specific design or qualification criteria. Modifications are proposed in cases where the available instrumentation does not meet the intent of the Regulatory Guide design and qualification requirements.

Southern California Edison Company 1-1 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

2.0 METHOD OF REVIEW In the event of an accident at a nuclear power plant, it is essential that operating personnel be provided information about the plant systems and releases that allow them to safely shut down the plant and take steps necessary to protect the public. RG 1.97 provides guidance on this subject in terms of a list of "variables" to be monitored during and following an accident. These "variables" are temperatures, pressures, levels, dose rates, etc., that the Regulatory Guide recommends monitoring on control room (or accessible) instruments during and following an accident. RG 1.97 specifies certain design and qualification requirements for these monitoring instruments based on their importance to safety.

It is recognized that full compliance with the guidance provided in RG 1.97 is not necessary for safe plant shutdown and monitoring following an accident. Consistent with this philosophy, this review was conducted on a "plant-specific" basis, wherein the variables specifically required for post-accident operations at SONGS 1 were identified and reviewed to determine design and qualification status.

Four separate tasks were performed in conducting the Regulatory Guide 1.97 Review:

Define the SONGS 1 Variables Identify the SONGS 1 Instruments Compare SONGS 1 Variables with RG 1.97 design and qualification requirements Justify Discrepancies/Provide Recommendations Southern California Edison Company 2-1

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2.1 SONGS 1 Variables The list of SONGS 1 variables specifically required for the operators to respond to an accident was developed based on review of the SONGS 1 Emergency Operating Instructions (EOIs) and the SONGS Emergency Plan (EP).

The EOIs are based primarily on the Westinghouse Owner's Group Emergency Response Guidelines [4] which identify the variables and systems that are used to bring the plant to a safe shutdown condition following an accident.

The variables were broken down into three types based on their role in accident monitoring and control of plant systems.

Type I variables are those that provide information needed by the operators to take preplanned manual actions in carrying out the applicable EOIs and bringing the plant to a safe shutdown condition.

Type II variables are those which provide the information needed to determine whether plant systems and/or operator actions are accomplishing the EOI specified "critical safety functions."

Type III variables are those monitoring release of radioactive materials and required for implementation of radiological dose assessment actions of the offsite emergency plan.

Further discussion of these variables and the basis for their selection is provided in Section 3.0.

2.2 SONGS 1 Instruments Once the SONGS 1 variables were selected, a review of the instrumentation presently installed in the plant was performed to determine the adequacy of this instrumentation to monitor the desired variables.

SONGS 1 design documents, including piping and instrumentation diagrams, electrical single lines, and control 0

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logics were used as a basis for identifying the SONGS 1 instruments. Detailed data was collected for each of the instruments to ensure that instrumentation was designed and qualified in a manner commensurate with the safety significance of the measured variable. Further discussion of the instruments is provided in Section 4.0.

2.3 Comparison with RG 1.97 Requirements RG 1.97 specifies design and qualification requirements for monitoring instruments based on the safety significance of the monitored variable. The current design and qualification data for the SONGS 1 instruments were reviewed against the criteria specified in RG 1.97 for instruments monitoring each corresponding variable.

Further discussion is provided in Section 5.0.

2.4 Justifications/Recommendations Some discrepancies were identified as a result of the review of variables and instruments against the design and qualification requirements of RG 1.97. In many cases, the available plant instrumentation can be expected to adequately and dependably provide the required information to plant operators, meeting the intent of the RG 1.97 design and qualification requirements, even though the instrumentation deviates from one or more of the specific requirements. In these cases, justification is provided for use of existing instruments to meet post-accident monitoring requirements for SONGS 1.

In cases where the existing instrumentation does not provide the capability to monitor a variable included in the SONGS 1 list, or design and qualification status does not ensure proper monitoring Southern California Edison Company 2-3

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capability will be available to the operators, appropriate recommendations are provided to upgrade monitoring capability.

The deviations between the design and qualification of instruments and RG 1.97 requirements for design and qualification, and associated justifications or recommended modifications, are discussed in Section 6.0.

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3.0 SONGS 1 VARIABLES The SONGS 1 variables are plant specific variables that must be monitored by the control room personnel during and following accident conditions.

These variables are used by the control room personnel to perform their role in the Emergency Operating Instructions in evaluating, assessing, monitoring, and executing control room functions. The variables identified for the list are those that provide information allowing the operators to (I) take the necessary preplanned actions to accomplish safe shutdown of the plant, (II) ensure accomplishment of critical plant safety functions, and (III) monitor release of radioactive materials and implement the radiological dose assessment actions of the offsite Emergency Plan. The selection of variables for each of these purposes is discussed in detail below.

3.1 TYPE I: Variables Monitored to Initiate Preplanned Manual Actions The variables included in the list as Type I are those providing information allowing the control room operator to take specific manually controlled actions for which no automatic control is provided and that are required for plant safety systems to accomplish their safety functions for design basis accident events. The SONGS 1 EOIs were used as the basis for the selection of variables providing this primary information. The EOI entry instruction identifies actions to be taken by the control room personnel to verify the proper response of the automatic protection systems following a reactor trip, safety injection, or loss of AC power (in certain operating modes). The entry instruction then leads the operator through a series of diagnostic checks and directs transition to an applicable Optimal Recovery Instruction (ORI) or Function Restoration Instruction (FRI).

Variables providing the Southern California Edison Company 3-1 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

information necessary for the operators to take specific manual actions to complete the ORIs and FRIs and bring the plant to a safe shutdown condition comprise the Type I list. The Type I variables and the required operator actions based on one or more of these variables are given in Table 3-1.

3.2 TYPE II: Variables Monitored to Ensure Accomplishment of Plant Safety Functions The variables included in the list as Type II are those given in the EOIs that provide information to indicate whether the plant "critical safety functions" are being accomplished. The EOIs define plant "critical safety functions" as the following:

Subcriticality Core Cooling Secondary Heat Sink RCS Integrity S-Containment Integrity RCS Inventory The variables providing the means of determining if the plant engineered-safety-features and/or operator actions are accomplishing these "safety functions" make up the Type II variable list. The Type II variables and the primary critical safety function that they monitor are given in Table 3-2.

3.3 TYPE III: Variables Monitoring Radioactive Releases The variables included in the list as Type III are those that allow implementation of the radiological dose assessment actions of the offsite Emergency Plan on the basis of in-plant direct radiation Southern California Edison Company 3-2 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

levels and release of radioactive materials from the plant.

The EP was reviewed to determine the plant radiation and release-related variables that must be monitored to direct implementation of the plan and allow estimates of the magnitude of any threat to the public from radioactivity releases.

The variables included as Type III are limited to SONGS 1 specific variables.

The remaining variables required to be monitored for implementation of the EP, including meteorological variables, have been previously evaluated

[5,6].

The Type III variables are listed in Table 3-3.

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TABLE 3-1 SONGS 1 Variables -

Type I VARIABLE REQUIRED OPERATOR ACTION REF ECI 501 o RCS Subcooling Initiate/Terminate SI 1.0-10, 1.0-12, 1.0-21, 1.0-31, 1.3-1, 1.4-1 Depressurize RCS 1.4-1.

o RCS Hot Leg Stop Uncontrolled Cooldown 1.1-1, 1.4-1 Temperature Initiate/Terminate SI 1.0-31, 1.2-1 Place RHR in Service 1.0-22, 1.0-31 Initiate RCS Feed/Bleed 1.3-1 o RCS Cold Leg Control RCS Cooldown Rate 1.0-30, 1.0-31, Temperature to Maintain Specified 1.0-32, 1.0-40, Pressure/Temp Limits 1.4-1, 1.4-2 o Refueling Water Manual Transfer of SI to 1.0-10, 1.0-11, Storage Tank Cold Leg Injection/

1.0-12, 1.0-20, Level Recirculation 1.0-22, 1.0-30, 1.0-32, 1.0-40, 1.2-1, 1.5-1 Manual Transfer to 1.0-31 Containment Spray Recirculation o Steam Generator Manually Adjust AFW Flow to 1.0-10, 1.0-11, Narrow Range Maintain Steam Generator 1.0-12, 1.0-20, Level Level 1.0-21, 1.0-30, 1.0-32, 1.0-40, 1.0-60, 1.2-1, 1.3-2, 1.3-3 Terminate SI 1.0-10, 1.0-21 Terminate Feed/Bleed 1.3-1 0

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TABLE 3-1 (continued)

SONGS 1 Variables - Type I VARIABLE REQUIRED OPERATOR ACTION REF EI S01 o Auxiliary Manual Transfer to 1.0-10, 1.0-11, Feedwater Tank Alternate AFW Supply 1.0-12, 1.0-20, Level 1.0-22, 1.0-30, 1.0-31, 1.0-40, 1.3-1 o RCS Pressure Initiate/Terminate SI 1.0-10, 1.0-11, 1.0-12, 1.0-21, 1.0-31, 1.0-40, 1.0-60 Place RHR in Service 1.0-22, 1.0-31, 1.0-40.

Depressurize RCS 1.4-1, 1.4-2 Select Feed Path to Steam 1.3-1 Generators or SI o Pressurizer Initiate/Terminate SI 1.0-10, 1.0-12, Level 1.0-21, 1.0-31, 1.3-1 Operate Charging 1.0-32, 1.0-40, 1.6-1 Stop Depressurization of 1.4-1 RCS o Containment Initiate/Terminate SI 1.0-11, 1.0-12, Pressure 1.0-60 Transfer to Containment 1.5-1 Spray Recirculation Mode o Containment Manual Transfer to Cold Leg 1.0-23, 1.0-32, Sphere Level Injection/Recirculation 1.2-1, 1.5-1 Southern California Edison Company 3-5 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

TABLE 3-1 (continued)

SONGS 1 Variables - Type I VARIABLE REQUIRED OPERATOR ACTION REF EOI S01 o Auxiliary Terminate SI 1.0-31 Feedwater Flow Establish Secondary Heat 1.0-11, 1.3-1 Sink; Initiate/Terminate Feed/Bleed Limit Flow to Prevent Water 1.3-3 Hammer o Main Steam Depressurize RCS/Place RHR 1.0-40 Pressure in Service Stop Steam Dump/Throttle FW 1.1-1 Flow to Prevent Uncontrolled Cooldown o Containment Manually start hydrogen 1.2-1, 1.5-1 Hydrogen recombiners Concentration Recirculation Manual transfer to cold leg 1.0-20, 1.0-23, 1.0-40, Flow injection 1.2-1, 1.2-2, 1.3-1, 1.4-1 Manual transfer to hot leg 1.0-24 injection Southern California Edison Company 3-6 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Table 3-2 SONGS 1 Variables -

Type II PRIMARY CRITICAL SAFETY FUNCTION VARIABLE MONITORED REF EQI S01 o RCS Hot Leg Core Cooling 1.0-1, 1.0-10, 1.0-11, Temperature 1.0-12, 1.0-20, 1.0-21, 1.0-22, 1.0-30, 1.0-31, 1.0-32, 1.0-60, 1.1-1, 1.2-1, 1.2-2, 1.2-3, 1.3-1, 1.4-1 o RCS Cold Leg RCS Integrity 1.0-1, 1.0-11, 1.0-12, Temperature 1.0-21, 1.0-22, 1.0-30, 1.0-31, 1.0-32, 1.0-40, 1.0-60, 1.4-1, 1.4-2 o Steam Generator Secondary Heat Sink 1.0-1, 1.0-10, 1.0-11, Narrow Range 1.0-12, 1.0-20, 1.0-21, Level 1.0-22, 1.0-30, 1.0-31, 1.0-40, 1.0-60, 1.2-1, 1.3-1, 1.3-2 1.3-3 RCS Pressure RCS Integrity 1.0-1, 1.0-10, 1.0-11, 1.0-12, 1.0-20, 1.0-21, 1.0-22, 1.0-30, 1.0-31, 1.0-32, 1.0-40, 1.0-60, 1.0-61, 1.1-1, 1.2-1, 1.2-2, 1.3-1, 1.4-1, 1.4-2, 1.6-1 o Pressurizer RCS Inventory 1.0-1, 1.0-10, 1.0-11, Level 1.0-12, 1.0-20, 1.0-21, 1.0-22, 1.0-30, 1.0-31, 1.0-32, 1.0-40, 1.0-61, 1.3-1, 1.4-1, 1.6-1, 1.6-2 Southern California Edison Company 3-7 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Table 3-2 (continued)

SONGS 1 Variables -

Type II PRIMARY CRITICAL REF EOI 501 SAFETY FUNCTION VARIABLE MONITORED o Containment Containment Integrity 1.0-1, 1.0-10, 1.0-12, Pressure RCS Integrity 1.0-20, 1.0-21, 1.0-22, 1.0-30, 1.0-31, 1.0-40, 1.0-60, 1.2-2, 1.5-1 o Containment RCS Integrity 1.0-1, 1.0-10, 1.0-20, Radiation 1.0-40, 1.2-2, 1.5-3 o Containment RCS Integrity 1.0-1, 1.0-23, 1.0-32, Sphere Level 1.2-1, 1.5-1, 1.5-2 o Containment RCS Integrity 1.0-10, 1.0-30, 1.0-40, Sump Level 1.2-2 o Auxiliary Secondary Heat Sink 1.0-1, 1.0-10, 1.0-11, Feedwater Flow 1.0-12, 1.0-20, 1.0-21, 1.0-30, 1.0-31, 1.0-32, 1.0-40, 1.0-60, 1.1-1, 1.2-1, 1.3-1, 1.3-2, 1.4-1, 1.4-2 o Main Steam Secondary Heat Sink 1.0-10, 1.0-11, 1.0-12, Pressure 1.0-21, 1.0-22, 1.0-30, 1.0-31, 1.0-32, 1.0-40, 1.0-60, 1.1-1, 1.3-1, 1.3-3, 1.3-4 o Neutron Flux Subcriticality 1.0-1, 1.0-10, 1.0-11, 1.0-12, 1.0-21, 1.0-31, 1.0-40, 1.1-1, 1.1-2 o Core Exit Core Cooling 1.0-1, 1.0-11, 1.0-12, Temperature 1.0-21, 1.0-22, 1.0-31, 1.0-60, 1.2-1, 1.2-2, 1.3-1 o

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Table 3-2 (continued)

SONGS 1 Variables -

Type II PRIMARY CRITICAL SAFETY FUNCTION VARIABLE MONITORED REF EOI SO o RCS Subcooling Core Cooling 1.0-1, 1.0-10, 1.0-11, 1.0-12, 1.0-20, 1.0-21, 1.0-22, 1.0-30, 1.0-31, 1.0-32, 1.0-60, 1.1-1, 1.2-1, 1.2-2, 1.2-3, 1.3-1, 1.4-1 o Containment Containment Integrity 1.0-10, 1.5-1, 1.5-3 Isolation Valve Status o Control Rod Subcriticality 1.0-10, 1.0-11 Position Southern California Edison Company 3-9 Regulatory Guide 1.97 Review II Report No. TR-85124-02, Rev. 0

TABLE 3-3 SONGS 1 Variables -

Type III VARIABLE

RESPONSE

o Steam Relief/Dump Implement dose assessment actions of Vent Radioactivity the offsite emergency plan at the appropriate emergency action level o Vent Stack Effluent based on magnitude of radiological Release Rate release and corresponding dose estimate at the exclusion area o Vent Stack Effluent boundary Radioactivity o Meteorological (Wind direction, wind speed, atmospheric stability)

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4.0 SONGS 1 SPECIFIC INSTRUMENTS The SONGS 1 specific instruments are plant instruments available to monitor the variables discussed in Section 3.0.

The available instruments were identified by a review of the E0Is, EP, system P&IDs, electrical drawings, and the control room instrument list.

Detailed design and qualification data for each of the SONGS 1 instruments was assembled and reviewed. The information provided for the SONGS 1 variables includes the following:

4.1 Equipment Qualification Status The SONGS 1 Environmental Qualification (EQ) program documentation was used as the basis for determining the environmental qualification status of the instruments.

The environmental equipment qualification status for instruments exposed to post-accident harsh environments was obtained from the SONGS 1 Equipment Qualification Master List

[7].

Designation of the seismic qualification status of instruments that are part of safety-related systems was based on a review of the SONGS 1 Q-List [8].

Seismic qualification of these instruments will be reevaluated as part of the resolution of Unresolved Safety Issue A-46, "Seismic Qualification of Equipment in Operating Plants."

Appropriate action will be taken in the event of any change in the seismic qualification status of an instrument due to this reevaluation.

Report No. TR-85124-02, Rev. 0

4.2 Instrument Redundancy and Separation Plant design documents were reviewed to determine if adequate redundant instrumentation exists to allow monitoring each of the specific variables requiring redundancy. Adequate redundancy exists when a single failure within either the accident monitoring instrumentation or its power source or supporting features, concurrent with an accident event, does not prevent the presentation of information necessary for the operating personnel to determine plant status and achieve a safe plant condition. Redundant means of recording variables is not required.

The cabling associated with a given instrument circuit was evaluated for separation and independence from its redundant instrument's circuit to determine if any credible single failure concurrent with event associated failures could compromise the availability of at least one variable monitoring channel.

4.3 Instrument Loop Power Source Instrument loop power sources were determined by a review of the SONGS 1 electrical design drawings.

These drawings included electrical single-line drawings, schematic diagrams and instrument loop diagrams.

4.4 Quality Assurance The quality assurance requirements applied to instrumentation was determined by a review of the SONGS 1 Q-List [8].

The requirements of the quality assurance program given in 10 CFR 50, Appendix 8, are implemented in accordance with the SONGS 1 Topical Quality Assurance Manual for safety-related components.

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4.5 Display Type The type of display provided for each of the variables was determined by a review of the SONGS 1 process and instrumentation diagrams, instrumentation loop diagrams and control panel layout drawings.

These information sources were supplemented by control room inspections.

4.6 Range of Instruments The calibrated range of all instruments was determined by review of instrument calibration sheets, design documents, and control room walkdowns.

The design and qualification status of the variables is discussed in Section 5.0.

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5.0 COMPARISON WITH REG.

GUIDE 1.97 REQUIREMENTS Regulatory Guide 1.97 specifies five general types of variables that should be measured and monitored following an accident situation at a PWR.

Each of the variables is assigned a design and qualification category (1, 2 or 3) that depends upon the importance of the variable in monitoring plant conditions. Category 1 provides the most stringent requirements and is intended for key variables.

Category 2 has lesser requirements and generally applies to variables indicating system operating status. Category 3 variables may be monitored by high-quality commercial instruments and applies to backup and diagnostic instrumentation. A summary of the Regulatory Guide requirements is given in Table 5-1.

RG 1.97 also presents a generic list of PWR variables to be monitored during and following an accident. A comparison between the SONGS 1 site specific variables and the RG 1.97 variables was performed and is given in Table 5-2. The SONGS 1 site-specific variables provide the essential information to the operators to accomplish and maintain a safe plant shutdown while minimizing risk to the health and safety of the public.

This comparison is not intended to justify the omission of RG 1.97 recommended variables from the SONGS 1 list of variables.

However, brief statements are provided to explain exclusion of variables based on the information which that variable provides (e.g., the information not within the variable "Type" definitions provided in Section 3.0).

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5.1 SONGS 1 Specific Instruments The design and qualification data applicable to the instruments discussed in Section 4.0 were compared against the design and qualification requirements identified for corresponding instruments given in RG 1.97.

In cases where RG 1.97 identified the same variable for more than one purpose with different assigned categories, the instrumentation was reviewed against the requirements of the category specified for the safety function monitored by the SONGS 1 variable.

Comparisons between the design and qualification of SONGS 1 instruments and RG 1.97 design and qualification requirements is presented in Tables 5-3, 5-4 and 5-5.

Deviations between Regulatory Guide requirements and the qualification and design of the SONGS 1 instrumentation are noted, with further discussion and justification or recommendation provided in Section 6.0.

Table 5-1 Regulatory Guide 1.97 Design and Qualification Criteria CRITERIA CATEGORY 1 CATEGORY 2 CATEGORY 3 Environmental Qualification Yes Yes Not Specified Seismic Qualification Yes If part of Not Specified Safety-related System Redundancy and Separation Yes Not Specified Not Specified Electrical Power Supply Class 1E High-Not Specified with reliability battery source with backup some battery backup Quality Assurance Yes Reduced Not Specified Require ments Display Type Continuous On-Demand On-Demand Indication with con-with con and Record-tinuous tinuous ing update update Southern California Edison Company 5-3 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Table 5-2 Comparison of SONGS 1 Site-Specific Variables and RG 1.97 Generic Variables RG 1.97 Variable SONGS 1 Variable Comment TYPE A VARIABLES Plant Specific Included Type I variables TYPE B VARIABLES Reactivity Control Neutron Flux Included Type II Control Rod Position Included Type II RCS Soluble Boron Not Included Can be verified through Concentration PASS. See Section 6.1(1).

RCS Cold Leg Water Included Type I and II Temperature Core Cooling RCS Hot Leg Water Included Type I and II Temperature RCS Pressure Included Type I and II Core Exit Temperature Included Type II Coolant Level in Not Included ICC addressed as Reactor separate issue.

See Section 6.2(1).

Degrees of Subcooling Included Type I and II Southern California Edison Company 5-4 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Table 5-2 (continued)

RG 1.97 Variable SONGS 1 Variable Comment TYPE B VARIABLES (continued)

Maintaining Reactor System Integrity RCS Pressure Included Type I and II Containment Sump Water Included Type I and II Level Containment Pressure Included Type I and II Maintaining Containment Integrity Containment Isolation Included Type II Valve Position Containment Pressure Included Type I and II TYPE C VARIABLES Fuel Cladding Core Exit Temperature Included Type II Radioactivity Concentration Not Included Can be verified through or Radiation Level in PASS. See Section 6.1(1).

Circulating Primary Coolant Analysis of Primary Coolant Not Included Can be verified through PASS.

See Section 6.1(1).

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Table 5-2 (continued)

RG 1.97 Variable SONGS 1 Variable Comment TYPE C VARIABLES (continued)

Reactor Coolant Pressure Boundary RCS Pressure Included Type I and II Containment Pressure Included Type I and II Containment Sump Water Included Type I and II Level Containment Area Radiation Included Type II Effluent Radioactivity-Included Type III Noble Gas Effluent from Condenser Air Removal System Exhaust Containment RCS Pressure Included Type I and II Containment Hydrogen Included Type I Concentration Containment Pressure Included Type I and II Containment Effluent Included Type III Radioactivity Noble Gases from Identified Release Points Radiation Exposure Rate Not Included Not a critical safety function (Reference 11).

Effluent Radioactivity Included Type III Southern California Edison Company 5-6

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Table 5-2 (continued)

RG 1.97 Variable SONGS 1 Variable Comment TYPE D VARIABLES Residual Heat Removal or Decay Heat Removal System RHR System Flow Not Included Required for Cold Shutdown.

Not required in response to accident conditions.

RHR Heat Exchanger Not Included Required for Cold Shutdown.

Outlet Temperature Not required in response to accident conditions.

Safety Injection System Accumulator Tank Level Not Included Not applicable (NA) to SONGS and Pressure

1.

Accumulator Isolation Not Included NA to SONGS 1.

Valve Position Boric Acid Charging Flow Not Included NA to SONGS 1. Boron injection included as part of SI flow from RWST.

Flow in HPI System Not Included NA to SONGS 1.

Flow in LPI System Not Included Not required for verifying system operation (i.e., valve alignment, pump operation).

Refueling Water Storage Included Type I Tank Level Primary Coolant System Reactor Coolant Pump Status Not Included Not a critical safety function.

Primary System Safety Not Included Not required in response Relief Valve Positions to accident conditions.

Pressurizer Level Included Type I and a

r So~uth rn California Edison Company 5-7 Regulatory Guide 1.97 Review RepNot reqire for5242 verifyin

Table 5-2 (continued)

RG 1.97 Variable SONGS 1 Variable Comment TYPE D VARIABLES (continued)

Primary Coolant System (continued)

Pressurizer Heater Status Not Included Not required in response to accident conditions.

Quench Tank Level Not Included Not required in response to accident conditions.

Quench Tank Temperature Not Included Not required in response to accident conditions.

Quench Tank Pressure Not Included Not required in response to accident conditions.

Secondary System (Steam Generator)

Steam Generator Level Included Narrow range included and wide range included as part of Auxiliary Feedwater Flow redundant channel.

Type I and II.

Steam Generator Pressure Included Type I and II Safety/Relief Valve Not Included Not required in response Positions or Main Steam accident conditions.

Flow Main Feedwater Flow Not Included Not required in response to accident conditions.

Table 5-2 (continued)

RG 1.97 Variable SONGS 1 Variable Comment TYPE D VARIABLES (continued)

Auxiliary Feedwater or Emergency Feedwater System Auxiliary or Emergency Included Type I and II Feedwater Flow Condensate Storage Included Type I Tank Water Level Containment Cooling Systems Containment Spray Flow Not Included Not required for verifying system operation (i.e., valve alignment, pump operation).

Heat Removal by the Not Included NA for SONGS 1.

Containment Fan Heat Removal System Containment Atmosphere Not Included Instrumentation does not Temperature exist. Not required in response to accident conditions.

Containment Sump Water Not Included Instumentation does not Temperature exist.

Not required in response to accident conditions.

Chemical and Volume Control Systems Makeup Flow-In Not Included Not required in response to accident conditions.

Letdown Flow-Out Not Included Not required in response to accident conditions.

Volume Control Tank Level Not Included Not required in response to accident conditions.

Southern California Edison Company 5-9 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Table 5-2 (continued)

RG 1.97 Variable SONGS 1 Variable Comment TYPE D VARIABLES (continued)

Cooling Water System Component Cooling Water Not Included Not required in response to Temperature to ESF System accident conditions.

Component Cooling Water Not Included Not required in response to Flow to ESF System accident conditions.

Radwaste Systems High-Level Radioactive Not Included Not required in response to Liquid Tank Level accident conditions.

Radioactive Gas Holdup Not Included Not required in response to Tank Pressure accident conditions.

Ventilation Systems Emergency Ventilation Not Included Indication is not provided.

Damper Position Power Supplies Status Standby Power Not Included Not required in response to and Other Energy Sources accident conditions.

SSouthern California Edison Company 5-10 Eegn Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Table 5-2 (continued)

RG 1.97 Variable SONGS 1 Variable Comment TYPE E VARIABLES Containment Radiation Containment Area Radiation Included Type II High Range Area Radiation Radiation Exposure Rate Not Included Not a critical function (Ref 11).

Airborne Radioactive Materials Released from Plant Noble Gas and Vent Flow Included Type III Rate Particulates and Halogens Included Type III Environs Radiation and Not Included Not required to assess offsite Radioactivity doses.

Meteorology Included Type III Accident Sampling Capability (Analysis Capability On Site)

Primary Coolant and Sump Not Included Can be verified through PASS. See Section 6.1(1).

Containment Air Not Included Hydrogen monitors available.

Southern California Edison Company 5-11 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

0'*

Table 5-3 SONGS 1 Variables -

Type I Design/Qualiflcation CoAIliance with IG 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1

REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS RCS Hot Leg 1

Yes Yes Yes 100-700*F Yes Yes Yes No See Section 6.2 Water Temperature Justification 50-750*F RCS Subcooling 1

Yes Yes Yes 50*F Superheat-Yes Yes Yes No See Section 6.2 150*F Subcool Just If Icat Ion 35*F Superheat-200*F Subcool Refueling Water I

Yes Yes Yes 0-100%

Yes Yes Yes No See Section 6.2 Storage Tank Level Justification 0-100%

Reclrculation Flow 1

No Yes Yes 0-300 GPM No Yes NA No See Section 6.2 Justification and Plant Specific Recommendation Main Steam Pressure 1

No Yes Yes 0-1000 Psig No No NA No See Section 6.3 Justification and 0-1182 Psig Recommendation Southern California Edison Company 5-12 Regulatory Guide 1.97 Review

- -A Report No. TR-85124-02, Rev. 0

Table 5-3 (continued)

SONGS 1 VarIables -

Type I Design/Qualification Compliance with RG 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1 REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS Auxiliary Feedwater 1

Yes Yes Yes 0-100%

Yes Yes No No See Section 6.3 Tn L l Justification and Tank Level Plant Specific Recommendation Steam Generator Yes Yes Yes 0-85%

Yes Yes Yes No See Section 6.3 Narrow Range Level 236-274 In Justification Plant Specific Auxiliary 1

No Yes Yes 0-100% Design Flow Yes Yes Yes No See Section 6.3 Feedwater Flow Justification and 0-100 % Design Flow Recommendation Containment Pressure 1

Yes Yes Yes 0-60 Psig Yes Yes Yes No See Section 6.4 Justification 0-51 Psig Containment Sphere 1

Yes Yes Yes

-9.5 to +12.0 Ft Yes Yes Yes No See Section 6.4 Level

- - - -Justification Plant Specific Southern California Edison Company 5-13 Regulatory Guide 1.97 Review

-E -

Report No. TR-85124-02, Rev. 0

Table 5-3 (continued)

SONGS 1 Variables -

Type I Design/Qualification Compliance with RG 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1 REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS RCS Cold Leg 1

Yes Yes Yes 100-600*F Yes Yes No Yes See Section 6.4

.Justification and Water Temperature 50-750*F Recommendation RCS Pressure 1

Yes Yes Yes 1600-2400 &

Yes Yes No Yes See Section 6.4 0-3000 PsIg Justification and Recommendation 0-3000 PsIg Containment 1

Yes Yes Yes 0-10% By volume Yes Yes Yes No See Section 6.5 Hydrogen Justification Concentration 0-10% By Volume Pressurizer Level 1

Yes Yes Yes 0-100%

Yes Yes No Yes See Section 6.6 Justification and 0-100%

Recommendation Southern California Edison Company 5-14 S-Regulatory Guide 1.97 Review IlllIII Report No. TR-85124-02, Rev. 0

TdIe 5-4 SONGS 1 Variables -

Type 11 Design/Qualification Compliance with RG 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1 REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS VARIABLES MONITORING SUBCRITICALITY Neutron Flux 1

No Yes Yes 0-120%

Yes Yes No Yes See Section 6.1 Full Power Justification and Recommend at Ion IE-6-100%

Full Power Control Rod Position 3

NA NA NA Full In/

NA NA NA Yes Not Full In Full In/

Not Full In VARIABLES MONITORING CORE COOLING RCS Hot Leg 1

Yes Yes Yes 100-700*F Yes Yes Yes No See Section 6.2 Water Temperature Justification 50-750*F Southern California Edison Company 5-15 Regulatory Guide 1.97 Review Report No.

TR-85124-02, Rev.

0

Table 5-4 (contInued)

SONGS I Variables -

Type II Design/Qualification Compliance with RG 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1 REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS Core Exit 1

No Yes Yes 100-22000F Yes Yes Yes Yes See Section 6.2 Temperature Justification 200-1650*F RCS StbcooIinq 1

Yes Yes Yes 50*F Superheat--

Yes Yes Yes No See Section 6.2 150*F Subcool Justification 35*F Superheat-200*F Subcool as VARIABLES MONITORING SECONDARY HEAT SINK Main Steam Pressure 1

No Yes Yes 0-1000 Psig No Yes NA No See Section 6.3

- - - - - - - -Justification and 0-1182 Psig Recommendation Steam Generator 1

Yes Yes Yes 0-85%

Yes Yes Yes No See Section 6.3 Narrow Range Level 236-274 In Justification Plant Specific Southern California Edison Company 5-16 Regulatory Guide 1.97 Review IIIIllIIIIIl Report No. TR-85124-02, Rev. 0

Table 5-4 (contInued)

SONGS 1 VarIables -

Type II Design/Qual fIcatilon Compliance with RB 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1 REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS Auxiliary 1

No Yes Yes 0-100% Design Flow Yes Yes Yes No See Section 6.3 Feedwater Flow Justification and 0-100% Design Flow Recommendation w VARIABLES MONITORING RCS INTEGRITY Containment Pressure 1

Yes Yes Yes 0-60 Psig Yes Yes Yes No See Section 6.4 Justification 0-51 PsIg Containment 1

Yes Yes Yes

-9.5 to +12.0 Ft.

Yes Yes Yes No See Section 6.4 Sphere Level Justification Plant Specific Containment 2

Yes Yes Yes

-15.5 to -9.5 Ft NA Yes NA Yes Sump Level Plant Specific Southern California Edison Company 5-17 Regulatory Guide 1.97 Review 1

Report No. TR-85124-02, Rev. 0

Tdble 5-4 (continued)

SONGS 1 VarIables -

Type II Design/Qualification Compliance with RG 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1 REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS RCS Cold Leg 1

Yes Yes Yes 100-600*F Yes Yes No Yes See Section 6.4 Water Temperature Justification and 50-750*F Recommendation RCS Pressure 1

Yes Yes Yes 1600-2400 &

Yes Yes No Yes See Section 6.4 0-3000 PsIg Justification and

-- - - - - - - -Recommendation 0-3000 Psig Containment 1

Yes Yes Yes 1-1E8 R/HR Yes Yes Yes Yes Radiation 1-1E7 R/HR

  • VARIABLES MONITORING CONTAINMENT INTEGRITY Containment 1

No Yes Yes Closed/Not Yes Yes Yes Yes See Section 6.5 Isolation Valve Recommendation Position Closed/Not Southern California Edison Company 5-18 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Se Table 5-4 (continued)

SONGS 1 VarIbIes -

Type II Design/Qualification Compliance with RB 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS I REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS Containment 1

Yes Yes Yes 0-60 Psig Yes Yes Yes No See Section 6.5 Pressure 245 Psig Justification 0-51 Psig 204 Psig VARIABLES MONITORING RCS INVENTORY Pressurizer 1

Yes Yes Yes 0-100%

Yes Yes No Yes See Section 6.6 Level Justification and 0-100%

Recommendation Southern California Edison Company 5-19 F

"/:

Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Tab le 5-5 SONGS I Variebles -

Type III Design/Qualificaton Compliance with RG 1.97 INSTRUMENT RANGE CATEGORY QUALIFICATION SONGS 1 REDUN-POWER PHYS DISPLAY VARIABLE ENV SEIS QA REQ RG 1.97 DANCY SUPPLY SEPAR TYPE COMMENTS Steam Relief/Dump 2

Yes Yes Yes 1E 1E4 R/HR NA NA NA Yes See Section 6.7 Valve Vent Justification Radioactivity 1E 1E3 uCI/CC Effluent 2

Yes Yes Yes 1 -

1E13 uCI/SEC NA NA NA Yes Release Rate 0-100% Vent Flow Effluent Release 2

Yes Yes Yes 1E 1E5 uCI/CC NA NA NA Yes Radioactivity 1E 1E4 uCI/CC Meteorological 3

NA NA NA See Comments NA NA NA Yes Meteorological Instruments Variables for the SONGS 1, 2, 3 site (Wind direction, have been previously shown wind speed, atmos pheric stability) ments.

15, 61 Southern California Edison Company 5-20

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Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

6.0 JUSTIFICATION OF DISCREPANCIES AND RECOMMENDATIONS A discussion of each of the variables for which design or qualification discrepancies have been identified is presented below. Justifications for use and acceptance of the available instrumentation are provided in cases where the intent of the Regulatory Guide is met even though the specific design and qualification criteria are not met.

Recommendations are provided in cases where the existing instrumentation does not meet the intent of RG 1.97.

It should be noted that the Technical Support Center (TSC) Fox 3 computer (Fox 3) has been identified to provide trend information for several of the SONGS 1 variables. The Fox 3 has no continuous on-line hardcopy readout devices, but stores large amounts of data that can be readily obtained in hardcopy form, as required by the operators.

The SONGS 1 TSC is located adjacent to the control room and provided with doorways, windows, and a pass-through box connecting the two facilities.

Any data available in the TSC is nearly as accessible to control room personnel as it would be if the readouts were in the control room. Use of the Fox 3 in satisfying requirements to monitor trends in essential variables has been previously addressed by Edison and the NRC. [9, 10]

Southern California Edison Company 6-1 Regulatory Guide 1.97 Review INHHIHII~dliniii i

Report No.

TR-85124-02, Rev.

0

6.1 SUBCRITICALITY (1) NEUTRON FLUX Deviation:

(a) Environmental qualification of the neutron flux detectors cannot be verified.

(b) Physical separation of control cables to the neutron monitoring instrumentation does not meet separation requirements.

Justification/Recommendation (a) Following a design basis accident the reactor can be assumed to be subcritical which could be verified by the difference between the RCS hot-leg and cold-leg temperatures, and by means of the control rod position lights. In the longer term, RCS grab sampling is adequate for confirming proper boron concentration to ensure that the reactor remains shut down. This sampling can be performed using the Post Accident Sampling System (PASS) installed in response to NUREG 0737 item II.B.3.

(b) Upgrade of the cabling to provide adequate.separation is recommended.

Southern California Edison Company 6-2 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

6.2 CORE COOLING (1) CORE EXIT TEMPERATURE Deviation:

Environmental qualification of core exit thermocouples has not been verified.

Just ification:

SONGS 1 core exit thermocouple system is being reviewed and will be addressed as part of Edison's response to the requirements of NUREG 0737, item II.F.2, "Inadequate Core Cooling."

Further discussion of the qualification of CET's is deferred to this evaluation.

(2) RCS HOT LEG TEMPERATURE Deviations:

(a) The existing indicator scale ranges are 100 700 0 F. The RG 1.97 recommended range is 50 750 0F.

(b) No recording capability is provided.

Justification:

(a) The existing range of 100-700 0 F meets the upper range limit of RG 1.97, Rev. 3 [11]. Monitoring RCS temperature down to 50F is not necessary.

E01 specified actions are based on whether or Southern California Edison Company 6-3 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

not the hot leg temperature has exceeded 680'F, and the existing range is adequate for this determination.

(b) Adequate hot leg trend information may be obtained from the Fox 3. The cold leg temperature recorder and the average temperature recorder provide additional backup for following reactor coolant temperature trends.

(3) RCS SUBCOOLING Deviation:

(a) The existing indicator scale ranges are 50aF superheat to 150 0F subcool.

The RG 1.97 specified range is 350F superheat to 200'F subcool.

(b) No recording capability is provided.

Justifi cation:

(a) The monitor range of 150aF subcool provides adequate indication for the operators to take all necessary preplanned actions and to monitor core cooling.

(b) Adequate subcooling trend information may be determined using RCS hot leg temperature and pressurizer pressure trend information maintained by the Fox 3.

Southern California Edison Company 6-4 Regulatory Guide 1.97 Review IIIIIIIiiiiiiiiiiiiiii Report No.

TR-85124-02, Rev. 0

(4) REFUELING WATER STORAGE TANK LEVEL Deviations:

(a) Continuous indication of tank level is provided by only one of the redundant instrument loops (LT/LI-950).

(b) No recording capability is provided.

Justifications:

(a) The operator action (manual transfer to containment recirculation) associated with this variable takes place when the water level in the RWST reaches a specified low level.

The operators receive indication of tank level from LI-950, are alerted to a low level (21%)

condition by control room annunicator A-7, and may also obtain level information from the Fox

3. Separate qualified instruments provide input to LI-950, annunciator A-7 and the Fox 3. The single continuous indicator and related annunciator, with the additional level information available from the Fox 3, is adequate.

(b) Adequate RWST trend information may be obtained from the Fox 3.

Southern California Edison Company 6-5 Regulatory Guide 1.97 Review I

I l

Report No.

TR-85124-02, Rev. 0

(5) RECIRCULATION FLOW Deviations:

(a) Environmental qualification of flow transmitters FT-2114B, 2114C, 3114A has not been verified.

(b) Redundant channels of control room indication for each injection line are not provided.

(c) No recording capability is provided.

Justification/Recommendations:

(a,b)Upgrade of flow instrumentation to provide redundant, environmentally qualified indication is recommended.

(c) Trending of recirculation flow rate is not required to assure appropriate operator response.

Southern California Edison Company 6-6 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

6.3 SECONDARY HEAT SINK (1) AUXILIARY FEEDWATER TANK LEVEL Deviations:

(a) Physical separation of the instrument loop power supply cables do not meet separation requirements.

(b) No recording capability is provided.

Justification/Recommendation:

(a) The power supply circuits to the instrument loop are routed in common cable trays from the DC Switchgear Room to the Control Room. Upgrade of the power supply installation is recommended.

(b) Adequate auxiliary feedwater tank level trend information may be obtained from the Fox 3.

(2) AUXILIARY FEEDWATER FLOW Deviations:

(a) Redundant auxiliary feedwater flow indication for each steam generator is provided by means of one channel of steam generator level (wide range) and one channel of auxiliary feedwater flow rate. Auxiliary feedwater flow.

instrumentation (flow transmitters FT-3453, 3454, 3455) are qualified, however, qualification of steam generator wide range level transmitters LT-450, 451, 452 has not been verified.

Southern California Edison Company 6-7 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

(b) No recording capability is provided.

Justification/Recommendation:

(a) Upgrade of level transmitters LT-450, 451 and 452 to qualified status is recommended.

(b) Adequate auxiliary feedwater flow trend information may be obtained from the Fox 3, which maintains data for both feedwater flow and steam generator wide range level.

(3) MAIN STEAM PRESSURE Deviations:

(a) Qualification of pressure transmitter PT-459 has not been verified.

(b) The range of the existing control room indicator is 0-1000 psig. The RG 1.97 specified range is 0-20% above the lowest safety valve setting of 985 psig, or approximately 0-1182 psig.

(c) Redundant channels of control room indication are not provided.

(d) No qualified recording capability is provided.

(e) The power supply to the instrument loop is not battery backed.

Southern California Edison Company 6-8 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

Justification/Recommendations:

(a,b,c) Upgrade of pressure instrumentation to provide redundant, qualified indication with adequate range is recommended.

(d) Main steam pressure is recorded on non-safety related control room recorder R-8, and adequate trend information is available from the Fox 3.

However, trending of main steam pressure is not required.

(e) It is recommended that the instrument loop be powered from an uninterruptable power supply.

(4) STEAM GENERATOR NARROW RANGE LEVEL Deviation:

No qualified recording capability is provided.

Justification:

Adequate steam generator level trend information may be obtained from the Fox 3.

Southern California Edison Company 6-9 S- -

Regulatory Guide 1.97 Review Report No.

TR-85124-02, Rev. 0

6.4 RCS INTEGRITY (1) RCS COLD LEG TEMPERATURE Redundant cold leg temperature indication for RCS loops is provided by one channel of RCS cold leg temperature and one channel of RCS loop temperature differential.

The temperature differential instruments provide a diverse means of determining cold leg temperature by referencing hot leg temperature readings.

Deviations:

(a) The existing recorder scale range is 100 600 0F. The RG 1.97 specified range is 50 750 0F.

(b) Physical separation of control and power cables to cold leg temperature and differential temperature instrumentation does not meet separation requirements.

Justifications/Recommendation:

(a) The primary function of this variable is to monitor the RCS cooldown rate based on downcomer coolant temperature. The existing instrument/recorder range is adequate for this purpose.

(b) The instrument loop cables are routed in common cable trays. These cable trays contain only low voltage instrument circuits and do not have Southern California Edison Company 6-10

-?Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

sufficient energy to cause common mode failures and are adequately separated from all other cable trays. Common mode failures due to high energy line break interactions will be evaluated as part of the high energy line break analysis.

The power supply circuits to the instrument loops are routed in common cable trays and are subject to common mode failures.

Upgrade of the power supply circuits to provide adequate separation is recommended.

(2) CONTAINMENT PRESSURE Deviation:

No recording capability is provided.

Justification:

Adequate wide range containment pressure trend information may be obtained from the Fox 3.

(3) CONTAINMENT SPHERE LEVEL Deviation:

No recording capability is provided.

Justification:

Adequate sphere level trend information may be obtained from the Fox 3.

Use of the Fox 3 in monitoring trend information for this variable has been previously addressed and found acceptable by the NRC [9].

Southern California Edison Company 6-11

-f Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

(4) RCS PRESSURE Deviation:

(a) The scale range for indicators PI-430, 431, 432 and recorder PR-430 are 1600-2400 psig.

The RG 1.97 specified range is 0-3000 psig.

(b) Physical separation of control and power cables to the four RCS pressure transmitters PT-425, 430, 431, 432 does not meet separation requirements.

Justifications/Recommendation:

(a) The scale range of redundant recorder PR-425 meets the RG 1.97 specified range of 0-3000 psig. In addition, the Fox 3 monitors RCS pressure and provides adequate trend information for the range of 0-3000 psig.

(b) The instrument loop cables are routed in common raceways. These raceways contain only low voltage instrument circuits and do not have sufficient energy to cause common mode failures and are adequately separated from all other raceways. Common mode failures due to high energy line break interactions will be evaluated as part of the high energy line break analysis.

Southern California Edison Company 6-12

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Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

The power supply circuits to the instrument loops are routed in common cable trays and are subject to common mode failures. Upgrade of the power supply circuits to provide adequate separation is recommended.

Southern California Edison Company 6-13 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

6.5 CONTAINMENT INTEGRITY (1) CONTAINMENT HYDROGEN CONCENTRATION Deviation:

No recording capability provided.

Justification:

Adequate containment hydrogen trend information may be obtained from the Fox 3. Use of the Fox 3 in monitoring trend information for this variable has been previously addressed and found acceptable by the NRC [9].

(2) CONTAINMENT PRESSURE (WIDE RANGE)

Deviation:

No recording capability provided.

Justification:

Adequate containment pressure trend information may be obtained from the Fox 3. Use of the Fox 3 in monitoring trend information for this variable has been previously addressed and found acceptable by the NRC [9,10].

Southern California Edison Company 6-14 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0 IIIIIIIIIIIIIIIIII

(3) CONTAINMENT ISOLATION VALVE POSITION Deviation:

Qualification of position switches for CI valves CV 949, CV-951, CV-953, CV-955, CV-956, CV-957, CV-962 and CV-992 has not been verified.

Recommendation:

Upgrade of position switches to qualified status is recommended.

Southern California Edison Company 6-15 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

6.6 RCS INVENTORY (1) PRESSURIZER LEVEL Deviation:

Physical separation of control and power cables to the three pressurizer level transmitters does not meet separation requirements.

Justification/Recommendation The instrument loop cables are routed in common cable trays. These cable trays contain only low voltage instrument circuits and do not have sufficient energy to cause common mode failures and are adequately separated from all other cable trays. Common mode failures due to high energy line break interactions will be evaluated as part of the high energy line break analysis.

The power supply circuits to the instrument loops are routed in common cable trays and are subject to common mode failures. Upgrade of the power supply circuits to provide adequate separation is recommended.

Southern California Edison Company 6-16

Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

6.7 EFFLUENT RADIATION (1) STEAM DUMP VALVES/SAFETY VALVES EFFLUENT MONITORS Deviation:

Dose rate is provided in lieu of RG 1.97 specified specific activity, flow rate, and duration.

Justification:

The dose rate measurement provided by the steam dump valves/safety valve radiation monitors, in conjunction with AFW flow (or steam flow as backup) provides for adequate determination of release magnitude.

0 Southern California Edison Company 6-17 Regulatory Guide 1.97 Review Report No. TR-85124-02, Rev. 0

7.0 REFERENCES

1. SONGS 1 Emergency Operating Instructions.
2. Emergency Plan for San Onofre Nuclear Generating Station Units 1, 2, and 3, Rev. 1, Dated 12/21/84.
3. "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," USNRC Regulatory Guide 1.97, Rev. 2, dated December 1980.
4.

Westinghouse Owners Group Emergency Response Guidelines.

5.

Letter, K.P. Baskin (Edison) to F. Miraglia (NRC), dated May 13, 1982, re: Edison RG 1.97 review for SONGS 2 and 3.

6. Letter, M.O. Medford (Edison) to G. W. Knighton (NRC), dated July 26, 1984, re: Edison RG 1.97 review for SONGS 2 and 3.
7. SONGS 1 Equipment Qualification Master List, CDM 'M' No. M85003, dated 7/31/85.
8. SONGS 1 Q-List Report M-37560, Rev. 1, dated August 1985.
9. Letter, D.M. Crutchfield (NRC) to K.P. Baskin (Edison), dated April 16, 1984, re: NUREG 0737 items II.F.1.4, 5 and 6.
10. Letter, W.A. Paulson (NRC) to K.P. Baskin (Edison), dated August 3, 1984, re: NUREG 0737 item II.F.1.4.
11.

"Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," USNRC Regulatory Guide 1.97, Rev. 3, dated May 1983.

Southern California Edison Company 7-1 Regulatory Guide 1.97 Review uuuu Report No. TR-85124-02, Rev. 0

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