ML17342A442
| ML17342A442 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/20/1986 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML17342A438 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8604080148 | |
| Download: ML17342A442 (20) | |
Text
.. SAFETY EVALUATXON TURKEY 3
AND 4 UL R
INTRODUCTION AND
SUMMARY
The Florida Pawer and Light Company was requested by Generic Letter 82-33 to provide a report to the NRC describing how the post-accident monitoring instru-mentation meets the guidelines of Regulatory Guide 1.97 as applied to emergency response facilities.
The licensee responded to Section 6.2 of the generic letter on January 26, 1984.
Additional information was provided by letter dated May 10, 1985.
A detailed review and technical evaluation of the licensee's submittals was performed by EG&G Idaho, Inc., under contract to the NRC, with general super-vision by the NRC staff.
This work was reported by EG&G in the Technical Evaluation Report {TER), "Conformance to Regulatory Guide 1.97, Turkey Point Plant, Unit Nos.
3 and,4," dated June 1985 {attached).
Me have reviewed this I
report and concur with the conclusion that the licensee either conforms to, or is justified in deviating from, the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable except for the variable plant and environs radiation.
EVALUATION CRITERIA Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983 to answer licensee and applicant questions and con-cerns regarding the NRC policy on Regulatory Guide 1.97.
At these meetings, it was noted that the NRC review would only address exceptions taken to the 8604080148 85000250 pop AQOCK 0 pop P
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guidance of Regulatory Guide 1.97.
- Further, where licensees or applicants ex-plicitly state that instrument systems conform to the provisions of the regu-latory guide, it was noted that no further staff review would be necessary.
Therefore, the review performed and reported by EGKG only addresses exceptions to the guidance of Regulatory Guide 1.97.
This Safety Evaluation addresses the licensee's submittals based on the review policy described in the NRC regional meetings and the conclusions of the review as reported by EGKG.
EVALUATION We have reviewed the evaluation performed by our consultant contained in the enclosed TER and concur with its bases and findings.
The licensee either con-forms to, or has provided an acceptable iustification for any deviations from the guidance of Regulatory Guide 1.97 for each post-accident monitor ing variable except for the variable plant and environs radiation.
Regulator/'uide 1.97 recommends that the instrumentation provided for the variable plant and environs radiation have a range of 10 to 10 R/hr photons and 10 to 10 rads/hr beta radiation and low energy photons.
The licensee
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identified in their May 10, 1985 submittal instrumentation with a range of 0 to 50 R/hr for this variable.
On February 27, 1986 the licensee submitted new information identifying the EBERLINE TELETECTUR (Models 6112R and 6112D) instruments with a range of 10 R/hr to 10 R/hr and EBERLINE (Model RO-2A) with a ranqe of 10 rads/
hr to 150 rads/hr.
The licensee considers this instrumentation tn be adequate to meet R.G.
1.97 purpose of determining the magnitude of release of radio-active materials and in assessing such releases.
They also stated that their operators would'not be placed in a position that would require higher ranges than those available.
The staff has reviewed this information and finds the additional instrumentation in conformance with the guidelines of R.G.
1.97.
CONCLUSION Based on the staff's review of the enclosed Technical Evaluation Report, and the licensee's submitta'Is, we find that the Turkey Point Plant, Unit Nos.
3 and 4, design is acceptable with respect to conformance to the guidelines of I
Regulatory Guide 1.97, Revision 3.
CONFORMANCE TO REGULATORY GUIDE 1.97 TURKEY POINT PLANT, UNIT NOS, 3 AND 4 J.
W. Stoffel Published June 1985 EGEG Idaho, Inc.
Idaho Fal l's', Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483
ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97 for Unit Nos.
3 and 4 of the Turkey Point Plant and identifies areas of nonconformance to the regulatory guide.
Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
FOREWORD This report is supplied as part of the "Program for Evaluating Licensee/Applicant Conformance to R.G. 1.97," being conducted for the U.S.
Nuclear Regulatory Commission, Office of Nuclear Reactor Regula.ion, Division of Systems Integration,. by EG&G Idaho, Inc.,
NRC Licensing Support Section.
The U.S. Nuclear Regulatory Commission funded the work under
'I authorization 20-19-10-11-3.
Docket Nos.
50-250 'and 50-251 TAC Nos.
51363 and 51364
CONFORMANCE TO REGULATORY GUIDE 1.97 TURKEY POINT PLANT UNIT NOS.
3 AND 4 1.
INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference
- 1) was issued by D.
G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and holders of cons'truction permits.
This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency response capability.
These requirements have been published as Supplement No.
1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Florida Power and Light Company, the licensee for the Turkey Point Plant, Unit Nos.
3 and 4, provided a response to the Regulatory Guide 1.97 portion of the generic letter on January 26, 1984 (Reference 4).
Additional information was provided on May 10, 1985 (Reference 5).
This report provides an evaluation of these submittals.
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necessary.
Therefore, this report only addresses exceptions to Regulatory Guide 1.97.
The following evaluation is an audit of the licensee's submittals based on the review policy described in the NRC regional meetings.
3.3 Exce tions to Re ulator Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97.
These are discussed in the following paragraphs.
3.3. 1 Containment Isolation Valve Position From the information provided, we find the licensee deviates from a strict interpretation of the Category 1 redundancy recommendations.
Only the active valves have position indication (i.e., check valves have no position indication).
Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory guide.
Position indication of check valves is specifically excluded by Table 3 of Regulatory Guide 1.97.
Therefore, we find that the instrumentation for this variable is acceptable.
3.3.2 Radioactivit Concentration or Radiation Level in Circulatin Primar Coolant The licensee will utilize the analysis of grab samples from the reactor coolant system for this variable.
Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation"'supplied for this variable is adequate, and therefore, acceptable.
3.3.3 Residual Heat Removal RHR Heat Exchan er Outlet Tem erature Regulatory Guide 1.97 recommends an instrument range of 40 to 350'F for this variable.
The range provided is 50 to 400'F.
The licensee states that intake cooling water (sea water) cools the component cooling water (CCW) which cools the residual heat removal (RHR) heat exchanger.
Since the licensee's historical data shows that the intake canal water 4emperture has never fallen below 57'F, the RHR heat exchanger outlet temperature is not expected to fall below 57'F.
The range covers the anticipated requirements for normal operation,
.anticipa.ed operational occurrences and accident conditions.
This range relates to the tank's rupture disk and the 100 psi tank design pressure that limits the temperature of the tank. contents to saturated steam conditions under 350'F.
- Thus, we find that this deviation from the recommendation of the regulatory guide is acceptable.
3.3.6 Containment S ra Flow The licensee has not provided instrumentation to directly monitor this variable.
The justification submitted by the licensee for this exception is that 1) there is another independent system that performs the same function and 2) the system operation is monitored by the containment spray actuation signal, the indication of pump starting and by valve position indication.
Operation of the emergency containment coolers, is monitored by temperature elements at the inlet and outlet of the containment coolers.
The licensee states that the containment spray system and the emergency containment coolers are redundant and that either system can independently maintain containment pressure and temperature below design limits during a
large break loss of coolant. accident with a single failure.
The alternate instrumentation provided by the licensee is adequate to monitor this variable.
Therefore, we find this deviation acceptable.
3.3.7 Containment Atmos here Tem erature Regulatory Guide 1.97 recommends a range of.40 to 400'F for this variable.
The licensee has provided instrumentation with a range of 0 to 300'F.
The justification submitted by the licensee for this deviation is that the maximum containment temperature is 275'F.
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3.3. 10 Plant and Environs Radiation ortable instrumentation Regulatory Guide 1.97 recommends a range for this variable of 10 to 10 R/hr, photons and 10 to 10 rads/hr, beta radiation and "3
4 low-energy photons.
The licensee has provided a range of 0 to 50 R/hr and submitted no jus.ification for the deviation.
The licensee should justify the existing range or provide instruments that will read the range recommended by the regulatory guide.
3.3. 11 Estimation of Atmos heric Stabi lit Regulatory Guide 1.97 recommends a temperature range of -9 to +18'F for this variable.
The licensee has provided instrumentation with a range of -5 to +5'F.
The licensee states that temperatures for determining atmospheric stability are taken at elevations of 10 and 60 meters.
Atmospheric stability classifications are normally categorized by the
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.temperature change per 100 meters of elevation.
With a 50 meter'hange in elevation for the Turkey Point meteorological
- tower, an adequate instrument range for determining atmospheric stability would be -1.71 to 3.6~F.
Table 1 of Regulatory Guide 1.23 (Reference
- 7) provides seven atmospheric stability classifications based on the difference in temperature per 100 meters elevation change.
These classifications range from extremely unstable to extremely stable.
Any temperature difference l
greater than +4 C or less than -2 C does nothing to the stability classification.
The licensee's instrumentation includes this range based on an elevation change of 50 meters.
Therefore, we find that this instrumentation is acceptable to determine the atmospheric stability.
3.3. 12 Accident Sam lin Primar Coolant Containment Air and Sum The licensee takes exception to the recommendation for sampling and analysis of the following parameters:
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CONCLUSIONS Based on our review, we find that the licensee either conforms to or is justified in deviating from Regulatory Guide 1.97, with the following excep.ion:
1.
Plant and environs radiation (portable instrumentation) the licensee should provide instruments with the recommended range for this variable or justify use of the existing range (Section 3.3.10).
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NRC FORM SSS IZ Sol NACM 110T, SSOI.ST09 US. NUCLEAR REGULATORYCOMMISSION I AEPOA BIBLIOGRAPHICDATA SHEET EA IAFJ!Poo>>OY TIDC, oOO Vol Ho., tlO>>VJ SEE IHS'TAUCTIOHS OH THE AEVEASE TITLE AND SVSTITLE Conformance to Regulatory Guide 1.97, Turkey Point Plant, Unit Nos.
3
& 4 EGG-EA-6814 J LEAVE SLAHK
~ DATE REPORT COMPL'ETED 9 AVTHORISI MONTH June YEAR 1985 0 OATS REPORT JSSVED J.
W. Stoffel I,PEAFORMIHG ORGANIZATION NAME AND MAILINGADDRESS llr!oJvooZ!P Co>>Pl MONTH June S. PROJECT/TASKJWOAK UNIT NUMSEA YEAR 1985 EG&G Idaho, Inc.
Idaho Falls, ID 83415
- 10. SPONSOR JAG ORGANIZATIONAIAMEAHDMAILINGADDRESS JI>>OJ~Z~ COOOJ Division of Systems Integration Office,of Nuclear Reactor Regulation U.S. Nu'clear Regulatory Commission Washington, DC 20555 Ilo. TYPE OF REPORT Technical Evaluation Report
- 0. PERIOD COVERED IIOCJVJ>>>>JHIOJJ Il. SUPPLEMENTARY NOTES IS. ASSTA*CTIJ00>>>>Jror or Joul This EG&G Idaho, Inc., report reviews the submittals for the Turkey Point Plant, Unit Nos.
3 and '4, and identifies areas of nonconformance to Regulatory Guide 1.97., Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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