ML18155A271
| ML18155A271 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/20/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18052B360 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8710270434 | |
| Download: ML18155A271 (34) | |
Text
.-
-=*
1.0 INTRODUCTION
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION REPORT CONSUMERS POWER COMPANY PALSADES PLANT DOCKET NO. 50-255 CONFORMANCE TO REGULATORY GUIDE 1.97 ENCLOSURE 1 Consumers Power Company was requested by Generic Letter 82-33 to provide a report to the NRC describing how the post-accident monitoring instrumentation meets the guidelines of Regulatory Guide (R.G.) 1.97 as applied to emergency response facilities.
The licensee's response to R.G. 1.97 was provided by letters dated September 13, 1983, and April 30, 1986.
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 supervision by the NRC staff.
The work was reported by EG&G in the Technical Evaluation Report (TER), "Conformance to Regulatory Gui de 1. 97, Pali sades Plant" dated July 1986 (attached).
We have reviewed this report and concur with the conclusion that the licensee either conforms to, or is justified in deviating from the guidance of R.G. 1.97 for each post-accident monitoring variable except for the variables accumulator tank level and pressure, quench tank temperature, quench tank pressure, steam generator pressure and component cooling water flow to ESF system.
2.0 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 concerns regarding the NRC policy on R.G. 1.97.
At these meetings, it was established that the NRC review would only address exceptions taken to the
.a-710270434 971020 i
- PDR *ADOC~ 05000255 PDRI p..
1-l guidance of R.G. 1.97.
Further, where licensee or applicants explicitly state that instrument systems conform to the provisions of the regulatory guide, no staff review would be necessary for these items.
Therefore, the review performed and reported by EG&G only addresses exceptions to the guidance of R.G.
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 EG&G.
3.0 EVALUATION We have reviewed the evaluation performed by EG&G contained in the enclosed TER and concur with its bases and findings except for the findings contained in TER section 3.3.l and Appendix A item I concerning a) accumulator tank level and pressure.
For the remaining items we agree with EG&G's findings that the licensee either conforms to or has acceptably justified deviations from the guidance of R.G. 1.97 for each post-accident monitoring variable except for the variables b) quench tank temperature, c) quench tank pressure, d) steam generator pressure, and e) component cooling water flow to ESF system.
a)
In TER section 3.3.1 and Appendix A item I ~G&G concluded that for the variables accumulator tank level and pressure, the licensee should designate either level or pressure as the key variable to directly indicate accumulator discharge and provide instrumentation for that variable that meets the requirements of 10 CFR 50.49.
The staff, however, is currently generically reviewing the need for environmentally qualified Category 2 instruments to monitor accumulator tank level and pressure.
We will therefore report on the acceptability of this item when the generic review process is complete.
b)
R.G. 1.97 recommends instrumentation with a temperature range of 50 to 750°F to monitor the quench tank temperature.
The licensee has provided instrumentation for this variable with a range of 0 to 300°F.
The licensee states that the tank is* provided with a rupture disk to relieve an overpressure condition at the tank design pressure.
The licensee further states that the only event which could result in excessive temperatures would be a stuck open safety relief valve.
-* The staff finds this justification unacceptable.
The licensee should install instrumentation that will remain functional and on scale, i~clud ing the maximum expected saturation temperature, during any accident that lifts the pressurizer safety or relief valves.
c)
R.G. 1.97 recommends instrumentation with a pressure range of 0 to design pressure to monitor the quench tank pressure.
The licensee has provided instrumentation for this variable with a range of 0 to 25 psig.
The licensee has acknowledged that the tank's design pressure is 100 psig.
The licensee states that the tank is provided with a rupture disk to relieve an overpressure condition at the tank design pressure of 100 psig.
The staff finds this justification unacceptable.
The licensee should
_install instrumentation that will remain functional and on scale, during any accident that lifts the pressurizer safety or relief valves.
d)
R.G. 1.97 recommends instrumentation with a range of 0 to 20 percent above the lowest safety valve setting to monitor the steam generator pressure.
The licensee has provided instrumentation for this variable with a range of 0 to 1000 psig.
The upper value of this range is 1.5 percent above the lowest safety valve setting and less than the highest safety valve setting of 20 percent above the lowest safety valve setting as recommended by the regulatory guide.
The staff finds this justification unacceptable.
The licensee should increase the range of the instrumentation for this variable to 20 percent above the lowest safety valve setting._
e)
Regulatory Guide 1.97 recommends instrumentation be provided to monitor the cooling water flow to ESF system.
The licensee has not provided instrumentation to monitor this variable.
The licensee states that the proper operation of this system can be determined by monitoring component cooling water pump status and the status of the valves that are required to be open.
The staff finds this justification unacceptable.
The instrumentation proposed by the licensee will not determine proper system operation should flow blockage or pipe rupture occur.
The licensee should provide component cooling water flow to ESF system instrumentation as recommended by R.G.
0 1.97.
4.0 CONCLUSION
Based on the staff's review of the enclosed TER and the licensee's submittals, we find that the Palisades Plant design is acceptable with respect to conform-ance to R.G. 1.97, Revision 3 with the exception of the variables accumulator tank level and pressure, quench tank temperature, quench tank pressure, steam generator pressure and component cooling water flow to ESF system.
a)
The acceptability of instrumentation for accumulator tank level and pressure will remain open pending the outcome of the staff's generic review of the need for environmentally qualified Category 2 instrumen-tation to monitor this variable.
The staff's conclusion will be reported on when the generic review is complete.
b)
It is the staff's position that information on the quench tank temper-ature up to the maximum expected saturation temperature is valuable to an operator in the evaluation of proper primary coolant system operation. It is also the staff's position that the licensee shall provide instrumentation to monitor the quench tank temperature in accordance with R.G. 1.97.
c)
It is the staff's position that information on the quench tank pressure up to the design pressure of the tank is valuable to an operator in the evaluation of proper primary coolant system operation.
It is also the staff's position that the licensee shall provide instrumentation to monitor the quench tank pressure in accordance with R.G. 1.97.
d)
It is the staff's position that information on the steam generator pressure up to 20 percent above the lowest safety valve setting is valuable to an operator in the evaluation of proper steam generator operation.
It is also the staff's position that the licensee shall provide instrumentation to monitor the steam generator pressure up to 20 percent above the lowest safety valve setting.
e)
It is the staff's position that information on the component cooling water flow to ESF system is valuable to an operator in the evaluation of proper cooling water system operation.
It is also the staff's position that the licensee shall provide instrumentation to monitor the component cooling water flow to ESF system in accordance with R.G. 1.97.
An appropriate implementation schedule will be developed by the project manager via discussion with the licensee.
Once the schedule is established, the licensee is required to inform the Commission, in writing, of any significant changes in the estimated completion schedule identified in the staff's safety evaluation and when the action has actually been completed.
CONfORMANCE TO REGULATORY GUIDE 1.97 PALISADES PLANT J. W. Stoffe*l Publ\\shed July 1986 EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuc1ear Regulatory Conrnission Washington, D.C.
20555 Under DOE Contract No. OE-AC07-76ID01570 FIN No. A6483 EGG-EA-6926
ABSTRACT This EG&G Idaho, Inc., report rev1ews the subm1ttals for Regulatory Gu1de 1.97, Revis1on 3, for the Pal1sades Plant and.\\dent1f1es areas of*
nonconformance to the regulatory gu1de.
Exceptions *to Regulatory Gu1de 1.97 are evaluated and those areas where suff1c1ent bas1s for acceptab111ty 1s not prov~ded are 1dent1f1ed.
Docket No. 50-255 TAC No. 51116
\\1
FOREWORD Th\\s report 1s suppl1ed as *part of the *Program for EvaluaUng Ucensee/Appl\\cant Conformance to R.G. 1.97,a be\\l')g conducted for the U.S.
Nuclear Regulatory Comm\\ss\\on, Off1ce of Nuclear Reactor Regulat\\on, 01v1s1on of PWR L1cens1ng-A, by EG&G Idaho, Inc., NRR and I&E Support Branch.
The U.S. Nuclear Regulatory Comm1ss1on funded the work under author1zat1on 20-19-10-11-3.
Docket No. 50-255 TAC No. 511 1 6
CONTENTS ABSTRACT................
,............................................... 11 FOREWORD. * * *. *. * * *.. *...... *.. *..... * *. *... *.. * *. * * * *. * * * *. * * * * * *. *...
111
- 1.
INTRODUCTION * * *.. * *. *. * * * *. * * * * * * * * * * * * * * * *.* * * * * *... * * * * * * * * * * * *.
- 1
- 2.
REVIEW REQUIREMENTS 2
- 3.
EVALUATION * * * * * * * * * *.* * * * * * * * * * * * * * * * * * * * * * * * * * * *.. * * * * * * *. * * *. * * * *
- 4
- 4.
- 5.
3.1 Adherence to Regulatory Gu1de 1.97...............*........... 4
- 3.2 * 'fype A Var1ables............................................
4 3.3 Except1ons to Regulatory Gu1de 1.97................*........
5 CONCLUSIONS * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
- 16 REFERENCES 17 APPENDIX A * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *. * * *
- 18
CONFORMANCE TO_REGULATORY GUIDE 1.97 PALISADES PLANT
- 1.
INTRODUCTION On December 17. 1982. Gener1c Letter No. 82-33 (Reference 1) was issued by D. G. E\\senhut. Director of the D1v1sion of licensing. Nuclear Reactor Regulation. to all liceniees of operating reactors. applicants for operating licensees and holders of construction permits.
This letter included additional clarification regarding Regulatory Guide 1.97.
Revision 2 (Reference 2). relating to the requ1rements for emergency response*capab111ty.
The~e requirements have been publ1shed as Supplement No. l to NUREG-0737. *TMI Act1on Plan Requirements* (Reference 3).
Consumers Power Company. the licensee for the Palisades Plant.
provided a response to the generic letter on April 14. 1983 (Reference 4).
On September 13. 1983 (Reference 5), the licensee prov1ded the information required by Section 6.2 of the generic letter. Additional 1nformat1on was provided on April 30 *. 1986 (Reference 6).
This report provides an eva1uat1on of these submittals.
1
- 2.
REVIEW REQUIREMENTS Section 6~2 of NUREG-0737, Supplement No. 1, sets forth the documentation to be submitted in a report to the NRC describing how the licensee complies with Regulatory Guide 1.97 as applied to emergency resp-onse fac11ities.
The submittal should include documentation that provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97.
- 1.
Instrument range
- 2.
Environmental qualification
- 3.
Seismic qualification
- 4.
Quality asfurance
- 5.
Redundance and sensor location
- 6.
Power supply
- 7.
Location of display
- 8.
Schedule of installation or upgrade The submittal should identify any deviations from the reco111Tlendations of Regulatory Guide 1.97 and provide supporting justifica.Uon or alternatives for those deviations identified.
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 concerns regarding the NRC policy on this subject.
At these meetings, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97.
Where licensees or applicants explicitly state that their instrument systems conform to the regulatory 2
guide, it was noted that no further staff revie~ would be necessary.
Therefore, this report only addresses except1ons to Regulatory Gu1de 1.9).
The following evaluation 1s an audit of the licensee's submittals based on the review policy described in the NRC regional meetings~
3
,I.
- 3.
EVALUATION The 11censee prov1ded a response to Sect1on 6.2 of NRC Gener1c Letter 82-33 on September 13, 1983.
Add1t1onal 1nformat1on was prov1ded on Apr11 30; 1986.
Th1s evaluat1on 1s based on-these subm1ttals.
3.1 Adherence to Regulatory Gu1de 1.97 The 11censee subm1tted a schedule 1n thefr subm1ttal that 1nd1cates that they w111 conform w1th the reco111T1endat1ons of Regulatory Gu1de 1.97, Rev1s1on 3 (Reference 7). Therefore, we conclude that the 11censee has prov1ded an expl1cH co111T1itment on conformance to Regulatory Gu1de 1.97.
Except1ons to and dev1at1ons from the regulatory gu1de are noted 1n Sect1on 3.3.
3.2 Type A Var1ables Regulatory Guide 1.97 does not spec1f1cally 1dent1fy Type A var1ables, Le., those var1ables that prov1de the 1-nformat1on requ1red to permH the control room operator to take spec1f1c manually controlled safety act1ons.
The licensee c1ass1f1es the follow1ng 1nstrumentat1on as Type A.
- 1.
Degrees of sub~ool1ng
/
- 2.
Steam generator pressure
- 3.
Steam generator level
. 4.
Pressur1zer level This instrumentation meets the Category 1 recolTITlendations consistent
- w1th the requirements for Type A var1ables, except as noted 1n Section 3.3.
4
3.3 Except1ons to Regulatory Gu1de 1.97 The 11cens~e 1dent1f1ed dev1at1ons and exceptions to Regulatory Guide 1.97.
These are d1scussed 1n the follow1ng paragraphs.
3.3.l Env1ronmental Qua11f1cation R~guirement Deviation The licensee stated 1n Reference S that the current environmental
- qual1ficat1on requirement for the variables listed in Appendix A was not addressed when these systems were des1gn~d. In Reference 6,.the 11censee has addressed each of these 30 identified vaii~bles; We find, based on the modifications and justificat1ons, provided by the 11censee, that all but two variables are acceptable. These are accumulator level and pressure and containment*sump water temperature.
Env1ronmentally qualified. 1nstrumentation should be provided for these variables.
Dev1at1ons other than environmental qualif1cation are addressed elsewhere in th1s report.
3.3.2 Se1smic Qua11f1c~t1on Requirement Oeviat1on The licensee states that the current seismic qualif1cation requ1rement for the following variables was not addressed when these systems were des1gned.
In Reference 6, the licensee has addressed each of these variables.
. A.
Neutron flux--1n Reference 6, the licensee has conrnitted to upgrade the ex1st1ng nuclear 1nstrumentat1on dur1ng the second upconrn1ng refueling outage.
The upgraded 1nstrumentat1on will be env1ronmentally and seismically qualif1ed.
B.
Reactor coolant system (RCS) cold leg water temperature--the temperature elements (RTD's) were upgraded during the 1985 refue11ng outage and two loops of seismically qua11f1ed loops of 5
I.*
instrumentation will be 1nstalled dur1ng the refuel1ng outage scheduled for m1d-l987.
C.*
RCS hot leg water temperature--the temper*ature elements (RTO's) were upgraded dur1ng the 1985 refuel1ng outage and two loops of seism1cally qual1fied loops of 1nstrumentat1on w1ll be 1nstalled dur1ng the refuel1ng outage scheduled for m1d-1987.
D.
RCS pressure--1n Reference 6, the 11censee states that th1s variable was upgraded during the 1985 refuel1ng outage except for the recorders.
The recorders are scheduled for replacement ~1th se1sm1cally qualified components during the refueling outage scheduled for mid-1987.
Based on the justification and colllnitments made by the licensee 1n Reference 6, we conclude that the se1sm1c qualification recolllnendations of Regulatory Guide 1.97 have been met.
3.3.3 RCS Soluble Boron Concentration Regulatory Guide 1.91 recolllnends a range of 0 to 6000 ppm for this variable.
The 11censee has prov1ded 1nstrumentat1on w1th a range of 0 to 2050 ppm.
The 11censee states that the range is with1n the 11mits for
- normal operation.
For an acc1dent, all d1ssolved boron that can be pumped 1nto the RCS 1s injected, and the letdown s1de would be isolated to maintain flow into the primary system.
Since the boron meter 1s on the letdown line, the licensee ind1cates that it would not be measuring pr1mary
~ystem concentration at th1s t1me and, therefore, the range of the instrument 1s adequate for its 1ntended funct1on.
The licensee takes exception to Regu1atory Guide 1.97 with respect to post-accident sampling capability.
Th1s except1on goes beyond the scope of th1s review and is being addressed by the NRC as part of their review of NUREG-0737, Item II.B.3.
6
3.3.4 RCS Cold *Leg Temperature In Reference 5, the 11censee stated that the recorder for the RCS cold
. leg ~emperature 1nstrumentation \\s powered from a non-Class lE source.
In Reference 6, the 11censee convnitted to change the power supply for the temperature recorder to a Class 1E power source.
We f1nd th1s conrnitment acceptable.
3.3.5 RCS Pressure In Reference 5, the 11censee stated that the 1nstrumentat1on prov1ded
- for th1s var1able does not meet e1ther the redundancy or the power suppl~
reconrnendations of Regulatory Gu1de 1.97.
In Reference 6, the 11censee states that redundant se1sm1cally and env1ronmentally qualified pressure tra~sm1tters powered from separate Clas1 lE power sources were installed during the 1985 refueling outage.
In add1t1on, the licensee has conrn1tted to install recorders that meet the regulatory gu1de reconrnenaat1ons during the next refueling outage.
We f1nd these changes and th'1 s conrnitment acceptable.
3.3.6 Core Ex1t Temperature Regulatory Gu1de 1.97 reconrnends 1nstrumentat1on w1th a temperature range of 200 to 2300°F for th1s variable.
The 11censee acknowledges a range dev1at1on from the regulatory gu1de.
However, the ex1st1ng range has not been provided and no just1f1cat1on for dev1ating from Regulatory Guide 1.97 was subm1tted.
The licensee states that the core cooling 1nst_rumentaUon project w111 address any 1nadequac1es.
The NRC 1s rev1ew1ng the acceptab111ty of th1s var1able as part of the1r rev1ew of NUREG-0737, Item II.F.2.
3.3.7 Degrees of Subcool1ng Regulatory Guide L97 reconrnends 1nstrumentation with a temperature range of 200°F subcool1ng to 35°F superheat for th1s var1able.
The 1
11censee's subm1ttal acknowledges a range dev,at1on from the regulatory gu1de, however, the ex1st1ng range has not *been prov1ded.
The 11censee states that the e~1st1ng range 1s 11mited by current 1nputs and that the subcoo11ng margin mon1tor will be upgraded as part of core coo11ng 1nstrumentat1on project.
The NRC 1s rev1ew1ng the acceptab111ty of th1s var1able as part of the1r rev1ew of NUREG-0737, Item II.F.2.
3.3.8 Containment Isolat1on Valve Pos1t1on In Reference S, the l\\censee 1dent1fied a power source dev1at1on for this variable.
In Reference 6, the 11censee states that each conta1nment penetrat1on requ1r1ng 1solat1on has two valves \\n ser1es w1th control power prov1ded from d1fferent trains of Class lf power.
E1ther of these valves 1s capable of perform1ng the isolat1on funct1on.
Pos1t1on 1nd1cat1on for each valve 1s powered from the valve's Class 1E control power.
Fa1lure of a s1ngle power source results 1n the loss of posjt\\on 1nd1cat1on of one of the valves, but the posit1on 1nd1cat1on of the redundant valve performing the 1solation function r~mains powered.
From the 1nformat1on prov1ded, we f1nd that the 11censee dev1ates from a str1ct 1nterpretat1on of the Category 1 redundancy recorrrnendat1on.
S1nce redundant 1solat1on valves are prov1ded, we find that redundant 1nd1cation per valve is not 1ntended by the regulatory gu1de.
Therefore, we f 1nd that the. instrumentation for this var1able 1s acceptable.
3.3.9 Radioact1v1ty Concentrat1on Rad1ation Level. 1n C1rculating Pr1mary Coolant The 11censee has one Category 3 channel of pr1mary coolant rad1at1on level 1nstrumentat1on.
In add1t1on, th1s 1nformat1on can be provided by the post-accident sampling system, which is being reviewed by the NRC as part of their rev1ew of NUREG-0737, Item II:B.3.
8
Based on the alte~nate 1n~trumentat1on provided by the 11censee, we conclude that the 1nstrumentat1on supplied for th1s var1able 1s adequate and, *therefore, acceptable.
3.3.lO Accumulator Tank Pressure Regulatory Guide 1.97 reco111nends a pressure range of Oto 750 ps1g for th1s var1able.
The 1nstrumentat1on has a range of 0 to 300 psig.
The max1mum operat1ng pressure for th1s tank. 1s 250 ps1g and the rel1ef valve sett1ngs on the tanks are set for 250 ps1g.
- We f1nd that the existing range is adequate to monitor any expected pressure.
- Therefore, this 1s an acceptable dev1at1on from Regulatory Guide 1.97.
3.3.11 Pressurizer Level lri Reference 5, the licensee has identified dev1at1ons from the Category 1 reconrnendations for env1ronmental qualificat1on, se1smic qualif1cation and redund~ncy.
In Reference 6, the 11censee states that one pressurizer level 1nstrument loop was upgraded dur1ng the 1985 refuel\\ng outage and now complies w*Hh the Regulatory Gu1de 1.97 recolmlendat1ons.
An add1t1onal level loop wi 11 be upgraded to Category 1 requ1rements in late 1988.
We f1nd these changes and this conrn1tment acceptable.
3.3~12 Quench Tank Level The licensee has an ex1st1ng range for th1s variable of 24 1nches to 96 inches.
Regulatory Guide 1.97 reconrnends a range from the top to the bottom of the tank.
The licensee states that the tank is 114 1nches h1gh.
and that the effect1ve range 1s to 93.6 percent level at 96 inches.
The tank would not be used if the level was below 24 1nches.
(
9
The level that is ma1ntained 1n th1s tank 1s approx1mately 60 percent volume.
The existing low 1nd1cat1on of th1s 1nstrumentation 1s adeQuate t~
insure that the sparger 1s covered and suff1cient flu1d volume ex1sts to quench the des1gn bas1s steam release.
The h1gh ind1cat1on is adeQuate to 1nd1cate suff1cient gas volume to accept a pressurizer steam release w1thout becoming overpressurized and to 1nd1cate in-leakage from the relief discharge system.
Based on this information, we find the existing instrumentation adequate.
Therefore, this is an acceptable deviat1on from the. regulatory*guide.
3.3.13. Quench Tank Temperature
- Regulatory Guide 1.97 reconmends a temperature range of 50 to 750°F for this variable.
The licensee has provided a range of *o to 300°F.
The licensee states, in Reference 6, that the tank is provided with a rupture disk to rel~eve an overpressure cond1tion at the tank design pressur~ of 100 psig (347°F).
The licensee ~urther states that the only event wh1ch could result 1n excessive temper.atures on the quench tank would be a stuck open safety or rel1ef valve.
S1nce these valves have qualified pos1t1on indication, the quench tank temperature would only provide conf 1rmatory indication that the safety or relief valves are stuck open.
The licensee has not provided adequate just1f1cati~n for this deviation.
The licensee should provide temperature indicat1on that will remain funct1onal and on scale, including the maximum expected saturation temperature, during any accident that 11fts the pressurizer safety or rel1ef valves.
3.3.J4 Quench Tank Pr~ssure The licensee has provided instrumentation for this variable with a pressure range of 0 to 25 psig.
Regulatory Guide 1.97 reconrnends a pressure rahge of 0 to design pressure.
The licensee acknowle~ges that the tank design pressure is 100 psig.
The licensee states, in Reference 6, that the tank is provided with a rupture disk to relieve an overpressure 10
cond1t1on at the tank des1gn pressure of 100 ps1g.
The 11censee further states that the only event wh1ch could result 1n excessive pressures 1n th~-
. quench tank would be a stuck open safety or power operated relief valve.
S1nce these valves have qua11f1ed pos1t1on 1nd1cation, the quench tank pressure 1nd1cat1on would only prov1de conf1rmatory 1ndication that the safety or re11ef valves are stuck open.
The 11censee also itates that 1ncreas1ng the range of the quench tank pressure 1nd1cat1on wouldl decrease the sensitivity of the reading required during normal operation of the system.
The licensee has not provided adequate-justificatiQn for th1s deviat1on.
The 11censee. should prov1de pressure 1nd1cat1on that w111 rema1n funct1onal and on sc~le dur1ng any acc1dent that 11fts the pressur1~er safety or power-operated re11ef valves.
3.3.15 Steam Generator Level In Reference 5, the 11censee 1dent1f1ed a se1sm1c qua11f1cat1on deviation for this var1able.
In Reference 6, the 11censee states that changes were made to th1_s 1nstrumentat1on dur1ng the 1983 and 1985 refue11ng outages.
The w\\de and narrow ran~e steam generator level 1nstrumentat1on now meets the reconmendat1ons of Regulatory Gu1de 1.97~
3.3.16 Steam Generator Pressure In Reference 5, the 11censee 1dent1f1ed a Category 1 dev1at1on for th1s var1ab1e.
The range of the ex1st1ng \\nstrumentat\\on (0 to 1200 ps1g) was adequate to meet the reconmendat\\ons of Regulatory Gu1de 1.97.
The licensee states. \\n Reference 6, that the steam generator pressure
\\nstrumentation loops were upgraded dur1ng the 1985 refuel1ng outage and now meet Category l requirements.. However. the range of the upgraded instrumentation 1s 0 to 1000 psig.
Th1s upper range \\s 1.5 percent above the lowest safety valve setting and less than the highest safety valve setting instead of the 20 percent above the lowest safety valve setting as reconmended by the regulatory guide.
11
We f1nd th1s dev1at1on unacceptable.
The 11censee 1s prov1d1ng an 1nstrumentat1on range that w111 not rema1n on scale -during all accident cond1t1ons.
The 11censee should expand the range of this 1nstrumenat1on to cover any expected pressure that the steam generator might reach.
3.3.17 Ma1n Feedwater Flow Regulatory Guide 1.97 reconrnends a range of 0 to 110 percent of design flow for th1s variable.
In Reference 5,. the 11censee subm1tted an incorrect value for the feedwater flow.
In Reference 6, the 11censee 6
states that the flow range 1s 0 to 12 x 10 lbs/hr.
Th1s range is 6.7 percent greater than the 11.25 x 106 lbs/hr des1gn rate and adequate to mon1tor any potent1al overfeed occurences.
We find th1s dev1ation m1nor and, therefore, acceptable.
3.3.TB Condensate Storage Tank Water Level In R~ference 5, the l1censee 1dent1f 1ed a deviat1on from Regulatory Gu1de 1.97 for env1ronmental qual1f1cat1on and seism1c qua11f1cat1on of the power supply for th1s variable.
In Reference 6, the 11censee states that the power supply 1s located 1n a m11~ env1ronment and w111 be upgraded by the end of the nett refueling outage w1th seismically qual1f1ed components.
We f1nd this conm1tment acceptable.
3.3.19 Conta1nment Sump Water Temperature The 11censee has not prov1ded direct read1ng instrumentat1on for this var1able.
The justif1cat1on submitted by the 11censee for th1s dev1ation is that the containment temperature mon1tors would 1ndicate the same temperature as the sump water when the conta1nment atmosphere is at saturation.
In addition, after switchover to the rec1rculation mode, the sump water temperature can be monitored by reading ~he low pressure safety 1njection (LPSI) and conta~nment spray (CS) pump discharge temperature.
12
The conta1nment temperature monHors prov1de a 11m1t1ng value of sump temperature.
The d1verse methods of determ1n1ng containment sump water temperature are, however, adequate to monitor the operation of the containment sump.. Therefore, this is an acceptable deviation from.
Regulatory Guide l.97.
3.3.20 Volume Control Tank Level Regulatory Gu1de 1.97 reconrnends a top to. bottom range for the level of th1s tank.
The licensee has instrumentat1on with a range of 0 to 88 inches and considers this range adequate because 1t covers from 0 to 100 percent of the operating levels.
The tank would be 1solated by any safety injection system actuation.
As the range is adequate t~ monitor the operation of this.tank, th1s is an acceptable deviation from Regulatory Guide 1.97.
3.3.21 Component Cooling Water !CCW) Temperature to Enginered Safety Features !ESFl System The licensee takes exception to the temperature range reconrnended by the regulatory gu1de for this var1able (40 to 200°F).
The licensee provides a range of Oto 140°F.
The 11censee states that the d1scharge temperature of the component coo11ng water at the heat exchanger discharge w111 remain between 65 to 90°f.
The range of the exist1ng transmitter will cover this discharge temperature.
S\\nce the temperature at the heat exchanger discharge is maintained between 65 and 90°F, the existing temperature range will adequately cover any*expected component cooling temperature for jhe ESF system components.
Therefore, this *is an acceptable dev1at1on from Regulatory Guide 1.97.
3.3.22 Component Cooling Water Flow to ESF System The licensee has not provided instrume~tation for this variable.
The licensee states that proper operation of this system can be determined by 13
mon1tor1ng CCW pump status and the status of the valves that are required to be open.
The 11censee further states that flow control 1s not required as the CCW pump 1s either "on", with full flow, or "offu.
We f1nd th1s fustificat1on unacceptable.
The alternate 1nstrumentation w111 not determine proper system operat1on should flow blockage or pipe rupture occur.
The 11censee should prov1de the recolTITlended instrumentation.
3.3.23 Rad1oact1ve Gas Holdup Tank Pressure The licensee has provided instrumentation w1th a range of 0 to 120 ps1g for this variable.
Regulatory Gu1de 1.97 reconmends a range of O to 150 percent design pressure.
The licensee states that the design pressure 1s 120 psig.
In Reference 6, the licensee states that the tanks are isolated when 80 percent of desig~ pressure is reached and an alarm will initiate at 83 percent of des1gn pressure.
In addition, two rel1ef valves are set at the tank design pressure and have a relief capacity greater than the design capacity of the compressors that discharge into the tanks.
Based on the justification provided by the licensee, we find the existing instrument range adequate to monitor this variable.
3.3.24 Particulates and Halogens In Reference 5, the licensee took exception to providing instrumentat1on for th1s var1able as recolTITlended by Regulatory Gu1de 1.97.
ln R~ference 6, the licensee states that all aspects of the Regulatory Gu1de 1.97 recolTl1lendat1ons for this variable have been met.
We find th1s acceptable.
14
3.3.25 A1rborne Rad1ohalogens and Part1culates Plant and Environs Rad1at1on Plant and Environs Radioactivity In Reference 5, the 11censee took ~xception to prov1d1ng 1nstrumentat1on for these variables as recomnended by Regulatory Guide 1.97.
In Reference 6, the licensee states that all aspects of the Regulatory Gu1de 1.97 recomnendat1ons for these var1ables have been met.
We f1nd this acceptable.
15
- 4.
CONCLUSIONS Based on our rev1ew, we f1nd that the 11censee e1ther conforms to or 1s Just1f1ed 1n dev1at1ng from Regulatory Gu1de 1.97, w1th the follow1ng except1ons:
- 1.
Accumulator level and pressure--env1ronmentally qua11f1ed tnstrumentat1on should be prov1d~d (Sect1on 3.3.l and append1x A).
- 2.
Quench tank temperature--the 11censee should prov1de 1nstrumentation that covers the saturation temperature of the tank contents (Section 3.3.13).
- 3.
Quench tank pressure--the 11censee should prov1de the reconrnended 0 to 100 ps1g range (Sect1on 3.3.14).
- 4.
Steam generator pressure--the licensee should prov1de the range (0 ps1~ to 20 percant above the lowest safety valve sett1ng) recorrmended for this variable (Section 3.3. 16).
- 5.
Component cooling water flow to ESF system--the licensee should prov1de the recorrmended 1nstrumentat1on (Sect1on 3.3.22).
16
- 5.
REFERENCES
- 1.
NRC letter, 0.
G~ Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits, *supplement No. 1 to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33),".December 17, 1982.
- 2.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Cond1ttons Dur1ng and Following an Accident, Regulatory Guide 1.97, Rev1sion 2, NRC~ Office of Standards
_Development, December 1980. *
- 3.
Clarification of THI Action Plan Requirements, Regutrements for Emergency Response Capabtltty, NUREG-0737, Supplement No. 1, NRC, Off 1ce of Nuclear Reactor Regulat1on, January 1983.
- 4.
Consumjrs Power Company letter, David J. Vandewalle to 01rector, Office of Nuclear Reactor Regulation, April 14, 1983.
- 5.
Consumers Power Company letter, Kerry A. Toner to Director, Off\\ce of Nuclear Reactor Regulat1on, September 13, 1983.
- 6.
Consumers Power Company letter, Kenneth W. Barry to Director, Nuclear Reactor Regulation, NRC, Aprtl 30, 1986.
- 7.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Ourtng and Followina an Acctdent, Regulatary Gutde 1.97, Rev1sion 3, NRC, Off1ce of Nuclear Regulatory Research, May 1983.
- 8.
Clartftcatton of TMi Action Plan Requirements, NUREG-0737, NRC, Office of Nuclear Reactor Regulat1on, November 1980.
17
APPENDIX A ENVIRONMENTAL QUALIFICATION.
18
- e
APPENDIX A ENVIRONMENTAL QUALIFICATION The following variables were not identified as being environmentally qualified tn Reference 5.
- Reference 6 clartfies the status of the environmental qualification for the following instrumentation (See Section 3.3. 1).
A.
Neutron flux--the licensee has conm1tted* to replace the ex1st1ng nuclear 1nstrumentat1on late 1n 1988.
The new instrumentation will be environmentally qua1H1ed.
We find th1s conrn1tment acceptable.
- 8.
Reactor coolant system (RCS) cold leg water temperature--the res1st~nce temperature detectors were upgraded with e'nvtronmentally qualified components during the 1985 refueling outage.
C.
RCS hot leg water temperature--the resistance temperature detectors were upgraded w1th envtronemntally qual1f1ed components during the 1985 refueling outage~
D.
RCS pressure--the pressur1z~r pressure transmitters were upgraded w1~h environmentally qual1f1ed components dur1ng the 1985 refueling outage.
E.
Containment sump water level (narrow range)--the narrow range
- sump water level transm1tters were upgraded with environmentally qual1fied components during the 1983 refueling outage.
F.
Containment isolation valve position--the isolation valve posit1on switches were upgraded to meet 10 CFR 50.49 requirements dur1ng the 1985 refueling outage.
19
'1*
G.
Res1dual heat removal (RHR) system flow--the shutdown too11n~
system 1s used for th1s funct1on at Pal1sades and the components to mon1tor the flow are located 1n a m1ld environment.
H.
RHR heat exchanger outlet temperature--1n Reference 6, the 11censee states that the ex1st1ng temperature element for this var1able 1s located 1n an env1ronment that would see s11ghtly elevated temperatures and rad1a1ton levels dur1ng an acc1dent.
The 11censee 1s evaluat1ng the ex1st1ng temperature element to see 1f 1t w111 cont1nue to perform 1t's funct1on dut1ng post-acc1dent cond1t1ons.
The l1censee has conrn1tted to replace the element w1th one that 1s env1fonemntally qua11f1ed 1f the analys1s shows that the ex1st1ng temperature element cannot meet the necessary requ1rements.
We f1nd th1s acceptable.
I.
Accumulator tank level -and pressure--1n Reference 6, the 11censee states that the safety 1njection tanks are pass1ve devices and that the level *and pressure 1nstrumentat1on 1s prov1ded for normal operat1on monttor1ng.
The 11censee further states that an acc1dent that results 1n a rap1d RCS depressur1zat1on w111 cause the safety inject1on tanks to d1scharge, result1ng 1n no level and pressure 1nd1cat1on.
In add1t1on, the licensee states that there are no operator act1ons requ1red during post-acc1dent cond1t1ons that requ1re knowledge of the tank level and pressure.
The ex1sting 1nstrumentat1on 1s not acceptable.
An env1ronmentally qual1f1ed 1nstrument 1s necessary to mon1tor the*
status of these tanks.
The 11censee should des1gnate e1ther level or pressure as the key var1ab1e to d1rectJy 1nd1cate accumulator d1scharge and prov1de 1nstrumentat1on for that var1able that meets the requ1rements of 10 CFR 50.49.
J.
Accumulator 1solat1on valve pos1t1on--the 11censee states that power to the safety inject1on tank 1solation valves 1s locked out 20
dur1ng normal operat1on to prevent 1nadvertent 1solat1on of the tanks.
Therefore, Category 3 1nstrumentat1on 1s adequate to mon1tor this var1able.
Based on the licensee's just1f1cat1on that these valves are open and cannot change posit1on during or follow1ng an acc1dent, we consider the instrumentat1on for this variable acceptable.
K.
Boric acid charging f low--this 1nstrumentat1on 1s the same as the variable makeup f low-.1n, and 1s located 1n a m11d environment.
L.
flow 1n h1gh.pressure 1njection (HPI) system--the licensee has conmHted to *replace the ex1sting fl~w transmHters late 1n 1988.. The new transmitters will be environmentally qualified.
We find th1s.conmitment acceptable.
M.
flow in low pressure 1nject1on (LPI) system--the l1censee has conmitted to replace the ex1sting flow transmitters late in 1988.
The new transmHters will be env,ronmentally qualHied.
We f1nd th1s conmitment acceptable.
N.
Refueling water storage tank level--the safety injection and refueling water tank (SIRW) 1s used at Palisades for this function.
The level instrumentat1on for th1s *tank 1s located 1n a mild environment.
- 0.
Primary system safety relief valve positions--the acoustfc mon1tors for th1s variable were upgraded w1th environmentally qualif1ed components durin~ th~ 1985 refuel1ng outage.
P.
Pressurizer heater status--all components of the current measur1ng loop for this var1able are located in a m1ld environment.
21
, *~
~**
- o.
Steam generator level--the level 1nstrument loop and level transm1tters located 1ns1de conta1nment were upgraded to meet env1ronmental qua11f1cat1on requ1rements dur1ng the 1983 refue11ng outage.
R.
Steam generator pressure--the pressure transm1tters for th1s var1able were replaced dur1ng the 1985 refueling outage.
The new transm1tters are env1ronmentally qua11f1ed.
r S.
Safety/re11ef valve pos1t1ons or ma1n steam flow--1n Reference b the 11censee states that the purpose of th1s 1nd1cat1on 1s to mon1tor for potent1ally stuck open steam generator re11ef valves.
Palisades has main steam flow 1nst_rument loops with flow transm1tters located inside conta1nment that can be ut11ized to monitor for excess1ve steam flows that would result from stuck open steam generator relief valves.
The steam generator relief valves are located outs1de containment, and a ma1n steam 11ne break (MSLB) result1ng from a stuck ~pen re11ef. valve would not result 1n a harsh env1ronment 1nside of containment.
Based on the 11censee's ju.stHicat1on we conclude that the ma1n steam flow instrument loops are locate*d in a m1 ld environment for events during which 1t would be requ1red to function and, thus, are acc'eptable for post-accident monitoring.
T.
Aux111ary or emergency feedwater flow--the control and ind1cat1ng instrument loops and flow transm1tters for this variable were upgraded to meet environmental qualH1cat1on re.qu1rements dur1ng the 1983 refueling outage.
U.
Containment spray flow--all components of the flow instrument loop for this var1able are located 1n a m1ld environment.
22
~
- v.
Heat removal by the conta1nment fan heat removal system--the requ1red components of th1s system were upgr~ded to meet the env1ronmental qua11f1cat1on requ1rements dur1ng the 1985 refue11ng outage; W.
Conta1nment atmosphere temperature--the 11censee does not cons1der conta1nment atm6sphere t~mperature to be a key var1able~ The temperature 1nd1cat1on 1~ prov1ded as a back~p var1able and for rout1ne surve1llance dur1ng normal operat1ons.
Qual1fied containment pressure indicat1ng loops are provided and are util1zed as the key variable to assess containment cond1tions.
We find th1s acceptable.
X.
Conta1nment sump water temperature--1n Reference 6, the 11censee states that they cons1der that conta1nment pressure 1s an acceptable alternat\\ve for mon1tor1ng conta1ment sump water temperature.
The sump temperature w111 be equal to or less than the saturat1on temperature corresponding to conta1nment pressure.
In add1t1on, there are no operator act1ons requ1red, based Qn knowledge of the conta1nment sump water temperature, and alternate temperature 1nstrumentat1on is ava1lable.
We f1nd th1s dev1at1on acceptable.
See Sect1on 3.3.19.
Y.
Makeup flow-1n--al1 components of the makeup flow 1nstrument loop are located.1n a m11d env1ronment.
Z.
Letdown flow-out-~all components of the letdown flow 1nstrument loop are located 1n a mild env1ronment.
AA.
Volume control tank level--all components of the volume control tank level \\nstrument loop are located 1n a m\\ld env1ronment.
23
BB.
Component cool1ng water temperature to ESF system--1n Reference 6, the 11censee states that the ex1st1ng temperature element fo~
th1s var1able 1s located in an environment that would see sl1ghtly elevated temperatures and radiation levels dur1ng an accident.
The licensee 1s evaluat1ng the ex1st1ng temperature element to see 1f 1t w111 cont1nue to pe.rform H's funct1on dur1ng post-acc1dent cond1tions.
The 11censee has conmitted to replace the element w1th one that 1s env1ronmentally qual1fied if th~ analys1s shows that the ex1sting temperature element cannot meet the necessary requ1rements.
We find th1s acceptable.
CC.
Emergency ventilat1on damper pos1t1on--the vent1lation damper pos1t1on sw1tch~s were upgraded to meet 10 CfR 50.49 requ1rements dur1ng the 1985 refueling outage.
OD.. Statu1 of standby power and other energy sources 1mportant to safety--the components assoc1ated w1th prov1d1ng the necessary status 1nformat1on are located 1n mild env1ronments.
The licensee states that they are cont1nu1ng to evaluate th~ necess1ty of provid1ng env1ronmental)y qualif~ed instrumentation for the following var1ables even though a conmitment nas been made to make the necessary modHicat ions.
A.
Neutron flux H.
RHR heat exchanger outlet temperature L.
flow 1n h1gh pressure safety injection system M.
Flow in low pressure safety 1nject1on system BB-Component cool1ng water temperature to ESF system.
24
.. *:.)
.. -. ~*
If *the 11censee's evaluat1on shows that env1ronmentally qua11f1ed equ1pment 1s not requ1red for these var1ables, the 11censee states that they w111 not1fy the NRC and prov1de the appropr1ate Just1fica~1on.
25