ML19290C657

Draft Reg Guide 1.97,Revision 2, Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant & Environs Conditions During & Following Accident

ML19290C657
Person / Time
Site:	LaSalle
Issue date:	12/31/1979
From:	NRC OFFICE OF STANDARDS DEVELOPMENT
To:
Shared Package
ML19290C655	List: ML19290C654 ML19290C657
References
TASK-OS, TASK-RS-917-4 REGGD-01.097, REGGD-1.097, NUDOCS 8001220491
Download: ML19290C657 (70)

Text

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.. f o,.g*e U.S. NUCLEAR REGULATORY C01'tf!SS!CN i1 e OFFICE OF STANCARDS DEVELOP:!ENT c

December 1979 I\\

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CRAFT REGULATORY GUICE AND VALUE/I" PACT STATEMENT Division 1

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Task RS 917-4 t*e n t a ct -

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5. Wint-a. n011 aa2,,10U3 PROPOSED REVISICN 2" 70 RECULATORY GUICE 1.97 INSTRUMENTATICN FOR LIGHT-WATER-CCOLED NUCLEAR PCWER PLbTS TO ASSESS PLANT AND ENVIRCNS CCNOITICNS CURING AND FOLLCWING AN ACCICENT A.

INTRCOUCTION Criterion 13. " Instrumentation and Control,".of Appendix A, " General Design Criteria for Nuclear Pcwer Plants," to 10 CFR Part 50, "Comestic Licensing of Production and Utilization Facilities," includes a requirement that instrumen-tatica be provided to monitor variantes and systems for accident conditions as appropriate to ensure adequate safety.

Criterion 19, " Control.Roem,* of Appendix A to 10 CFR Part 50 includes a requirement that a centrol roem te'provided frem wnica actions can be taken to maintain the nuclear pcwer unit in a safe condition under accident c:nditions, including loss-of-coolant accidents, and that equipment, includfrg the necessary instrumentation, at appropriate locations outside the control rocm te provided i

with a design capability for prompt het shutecwn of the reactor.

Criterion 64, "Menitoring Radioactivity Releases," of Appendix A to 10 CFR j

Part 50 includes a requirement that means te provided for monitoring the reactor containcent at=eschere, scaces containing c:mecnents for recirculat:en of loss-of-coolant accident fluid, effluent discharge paths, and the plant environs for radioactivity that may be released from postulated accidents.

This guide describes a tethod acceotacle to the NRC staff for c:mplying with the Ccomission's regulations to provide instrumentation to menitor plant variables and systems during and following an accident in a light water-cooled nuclear power plant.

"The suestantial numoer of enanges in this crecosed revision has made it imorac-tical to indicata ine enanges with lives in the margin.

nfs nslatory ;uice ans es associateo vat.e/'.-cact sute ent are :ei g issues in crert for to involve tae suotic f a tre early sta;es or u. :evei e ent or a re;uisterv :esistan in nts area. wey save est recete.e comoiete surf revin. ave os :eea e, vie-ee ny t. e oc sequieury secuire-enu 2e. w Gas tue, ans as not represent an errictai *R: surf :esition.

a Puelic coments are seing soiteites en sota crar'.a. t e guide (tec i.etag ary trotenentatisn icne rute) and fR the value/ impact suteeent. "ments on tr.e sale.es t cact state **nt s*culd :e ecc: :apies sy turoorting data. Coasents an tota crafts sMuld se sent to 13e !+c.-*tary of the S-mssion U.S. 'tuc!eer te;utatsry Commission. Wasningtan. 3.0.

• 3!5, attentf on: :ociettsg anc ferv'ce tranca, sy Iseuests ter single castee of draf* guices (.nicas ey 'ne rosaseuce<J) er r r stace*ent on an automatic o

ef stribution 11st fce sfegle c:sies of fut re :raf t ;uices 's scecif'c sivesions poule te

• ace in writing to the U. s. Muc t e e r z ;u t a to ry Gew i s s en. 'assington, 3.0. *:335, attention? 31 re c *.se, e

3feisten of Tec3nicel !ntsmation and "ocw.* eat "antrit.

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B.

O!SCUSSION Indications of plant variaoles and status of systems imoottant to safety are required by the plant operator (licensee) during accident situations to (1) provide information required to permit the operator to take preplanned

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manual actions to accomplish safe plant shutdown; (2) determine whether the reactor trip, engineered-safety-feature systems, and manually initiated systems are performing their intended functions (i.e., reactivity control, core cooling, maintaining reactor coolant system integrity, and maintaining containment integrity);

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-*J thsa.. b. :iis ocun Greacr;eu; (3) furnisn data for ceciding on the need to take unplanned action if an automatic or manually initiated safety system is not functioning properly or the plant is not resconding properly to the safety systems in operation; and.M_ ': ury J..

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..w. m..n a W W t e t'2 s M ::.; % an u....;. J :: ??+ 4 t h r %,,.~ ;r. p h-^r At the start of an accident, it may be difficult for the operator to detor-mine immediately what accident has occurred or is occurrir.g and, therefore, to determine the appropriate response. For this reason, reactor trip and certain other safety actions (e.g., emergency core cooling actuation, containment isola-tion, or depressurization) have been designed to be performed automatically during the initial stages of an accident. Instrumentation is also provided to indicate information accut plant parameters required to enaole the operation of manually initiated safety systems anc other accrocriate operator actions involv-ing systems imoortant to safety.

Instrumentation is also needed to provide information about some plant parameters that will alert the coerator to conditions that have degraced beyond those postulated in the accident analysis. In particular, it is important that the operator be informed regarding that t atus of coolant level in tr.e reactorvesselortheexistenceofcorevoidingjthatwoulfr**4t.

Jarre appec indicata degraced core cooling. Direct indication of coolant level in the reactor vessel is not i

currently availacle in pressuri:ed water reactors. However, it is imoerstive f

that this capacility te caveicoed within a reasonable time in order to provide l

the operator with tnis vital information in a ;ositive, unamaigucus manner. ::

is essential tnat degraded conditions de icentifisc so that the coerator can taxe 2 - AtlaCbir>erstl A 1785 149

4 actions that are available to mitigate the consequences.

It is not intended that the operator be encouraged to prematurely circumvent systems important to safety but that he be adequately informed in order that unplanned actions can be taken when necessary.

Examples of serious events that could threaten safety if conditions degrade beyond those assumed in the Final Safety Analysis Report are loss-of-coolant accidents (LCCAs), overpressure transients, anticipated transients without scram (ATVS), reactivity excursions, and releases of radioactive materials.

Such events require that the operator understand, within a short time period, the ability of the barriers to limit radioactivity release, f.e.,_the F.ter.t %

Nb d a Wi..,,. an actual breach of a barrier by an accident in progress.

It is essential that the required instrumentation be capable of surviving the accident envirenment in which it is located for tne length of time its fune-tion is required as defined by Section 3.0 of Oraft Standard ANS-4.5,* " Functional Requirements for Accident !ionitoring in a Nuclear Pcwer Generating Station,"

Draft 4 dated November 1979.

It could therefore either be designed to withstand the accident environment or be protected by a local protected environment.

If the environment surrounding an instrument component is the same for accident and normal operating conditions (e.g., some instrumentation components outside of containment or those in the main control room powered by a Class 1E source),

the instrumentation components need no special envirmnmental qualification.

It is important that accident-manitorinc instrumantation comoonents and

.their counts that cannot be located in N5eismic Category I build-ings be conservatively designed for the intended service.

Parameters selected for accident monitoring can be selected so as to permit relatively few instruments to provide the essential information needed by the operator for postaccident monitoring. Further, it is prudent that a ifmited

• Copies may oe obtained from tne American Nuclear Scciety, 555 North Kensington Avenue, La Grange Park, Illinois 50525. Althougn tais standard has been balloted by the resconsible subcommittee and reviewed by the resoonsible con-sensus body, Oraft 4 does not reflect the resoluties of all comments. A suo-sequent draft is intendec to ac::ress tne comments coat formed the basis of the negative succommittee ballota.

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b number of those parameters (e.g., containment pressure, primary system pressure) be sonitored by instruments qualified to rese4MHgsMr environmental recuire-

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sents and with ranges tha. extend Ashbdeyent that which the selected parameters can attain uncer ifmiting conditions) It is essential that the range selections

,not be arbitrary but sufficiently hig's that the instruments will always be on scal, for examole, a range for tt'e containment pressure monitor extending to the pressure of the containment in orcer that the operator will not be blind as to the level of containment pressure. Provisions of suca instruments are important so that respenses to corrective actions can be cbserved and the need for, and.magnituce of, further actions determined. On the other hand, it is also necessar/ to make sure that when a range is extended, the sensitivity and accuracy of the instrument are within acceptable limits.

Normal power plant instrumentation remaining functional for all accident conditions can provide indication, records, and (with certain types of instru-ments) time-history rescenses for many parameters important to felicwing the course of the accident. Therefore, it is prudent to select the required accident-monitoring instrumentation frem the normal power plant instrumentation to enacle the operator to use, during accident situations, instruments with which he is most familiar. Since some accidents impose severe operating requirements en instrumen-tation components, it may te necessary to upgra'ce those instrumentation ::mpenents to withstand t3e more severe c;erating c:nditions and to measure greater variati:ns of monitored variables that may be associated with the accident if tney are to be used for both accident and normal operatien. Mcwever, it is essential tnat instrumentation so u graced does not ccm remise the ac:uracy and sensitivity required for normal coeration. In seme cases, this will necessitata use of tverlapping ranges of instruments to monitor the required r nge of the parameter to be monitored.

Oraft Standard ANS-4.5, Draft 4 dated Novemoer 1979, delineates criteria for determining the variaDies to be meniMred by the c ntrei rocm Operat0r, as required for safety, during the ::urse of an ;::icent and during tne long-term stable shutdown phase followng an accident. Oraft Standard ANS-4.5 was prepared by Working Group 4.5 of subc:xiittee ANS-4 with two primary cojectives: (1) to address that instrumentation that permits the : erator to.tenitor ex:ected parameter :hanges in an ac:icent period and (2) to accress extenced range instrumentation deemec acor oriate for the oossibility of encountering =reviousiy h

Orb.1'i.lEEE P 497, ddeci Voy M7,for ace 64 m has been klp Mnt Aou P** M oM Nfawd r-Atfachryn6 A dad & gua.Akrofim deemed apprepnch k %. use of b l@rumm4cch e br' post - a ccMen 4 Mr..

1785 151

The standard defines four classifications of variable types for the purpose of aiding the designer in his selection of accident-monitoring instrumentation and applicable criteria.

thi, -tn;w&a-hn N The types are:

(1) Type A - those variables that provide informa-tion needed for preplanned operator actions, (2) Type B - those variables that provide i formation to indicate whether plant safety functions are being accom-plished, (

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Type A variables have not been gd included in the listings of variables to be measured because they are plant specific and will depend on the operations that the designer chooses for pre-I planned manual action. Efe two-ci e.. i T. 4r. ions are uv...a. t.;; ;,

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The time phases (Phases I, II, and III) delineated in ANS-4.5 are not specified for each variable in this regulator-; guide. These considerations are plant specific. It is important that the aquired instrumentation survive the accident environment and ' unction as long as the information it provides is needed'by the plant coerator.

C.

REGULATORY POSITION The criteria, requirements, and recommendations (identified as important to safety) contained in Draft Standard ANS-4.5, " Functional Requirements for Accident Monitoring in a Nuclear Power Generating Station, Oraft 4 dated November 1979,$areconsideredbytheNRCstafftobegenerallyacceptable Ifor providing instrumentation to monitor variabl'es and systems for accident conditions and 'or :enitoring the reactor containment, scaces containin comoc-nents for recirculation of loss-of-coolant accident fluids, effluent discharge

""dmd clrdt 64anMy cl IE P47 dedt 1,defed VoV E77 5-%chmenf A 1785 152

a paths, and the plant environs for radioactivity that may be released during and follow'ing an accident from a nuclear power plant subject to the following:

1.

Section 2.0 of ANS-4.5 defines the scope of the standard as contain-

. ing criteria for deter.Mning the variables to be =enitored by the control room operator during and following an accident that will need so=e operator action.

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d In Section 3.0 of ANS-4.5, the definition of " Type C" includes tw nd (2). Item (1) includes those instruments that ind

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items, i,

extent to whic.

amaters that indicate the pote'ntial #

breach in the containment have exces the design basis val In conjunction with the parameters th't indicate the

'entia a breach in the containment, the a

causing a breach in the fuel cladding parameters that have tne pot (e.g., core exit tem ure) and the reac.. -aolant pressure boundary (e.g.,

reactor cool ressure) should also be included.

ei ces to Type C instru-ments c associated parameters to te measured, in Draf t Stanca. " S-4.5 (e.g.,

etions _4.2, 5.0, 5.1.3, 5.2, S.1, 5.3) should include this expanced defin. Q 3. Section 3.0 of ANS-4.5 defines design basis accicent events.

In conjunction with the design basis accident evants delineated in the standard, those events that are expectad to occur one or : ore times during the life of a nuclear power unit and include but are not limited to loss of power to all recirculating pumos, tripoing of the turoine generator set, isolation of the main condenser, and loss of all offsita power should be included.

3. Section 4.2 of ANS-4.5 discusses the various types of variables.

With regard to the discussion of Type 0 variables, Ty;e 0 varisbles and instru-ments are within the scope of Accident Monitoring Instrumentation althougn they are not addressed in Orsft Standard ANS-4.5.

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4. Section 5.1 of ANS-4.5 pertains to General ::esign Critaria for instru-mentation monitoring Types A, B, anc C variaales. In conjunction with Section 5.*.,

s - Asche,ed A 1785 153

instrumentation monitoring Types 0 amh5 variables should also be included.

Noted applicable design criteria are identified in Table 1 of this regulatory guide.

6.

Section 6.1.2 of ANS-4.5 pertains to the duration that instrumentation is qualified to function. In conjunction with Section 6.1.2, Phase II instru=en-tation should be qualified to function for myhn h 00 O' "Ma +ine penod, cew4tg ceupta 6te. -to Wt.184,%

rs: : 90-0.7 tmlcs c. shorter.twMe. based on nece or component accessability for replacement or repair, can f

4 be justified.

y 7.

Sections 6.2.2, 6.2.3, 6.2.4, 6.2.5, 6.2.6, 6.3.2, 6.3.3, 6.3.4, and

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6.3.5 of ANS-4.5 pertain to variables and variaole ranges for monitoring. In li O

conjunction with the above sections, Tables 1, 2, and 3 of this regulatory guide o.

9 (which include those parameters mentioned in the above sections) should be c4 used in developing the minimum set of instruments and their respective ranges for accident-monitoring instrumentation for each nuclear power plant.

8.

Section 6.4 of ANS-4.5 pertains to specific design criteria for accident-monitoring instrumentation. In conjunction with Section 6.4, the provisions as indicated in Table 1 of this regulatory guide should be used.

9. lEEEp,@7 para roph 4.5 rego res one h define onJ document %e psthcw of Me atoden4 monj4erinj Ms rumenigh g 13 Es IE n der 4a qppheA.

This proposed revision has been released to encourage public participa-tion in its development. Except in those cases in whf en an aaplicant proposes an acceptable alternative method for comolying with s:ecified ;ortions of the Commission's regulations, the =ethod to be cescribed in the active guide reflecting puolic ccm=ents will be 'Jsed in the evaluation of the following applications that are dockated after the isolementation date to be s ecified in the guide:

1.

Preliminary Design Approval (PCA) applications and

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Preliminary Duplicate Design Accroval (PCOA) acplications.

2.

Final Design Approval, Type 2 (FOA-2), applications and Final Duolicate Design Ap;roval, Type 2 (F00A-2), a:clications.

3.

Manufacturing License (ML) a:plications.

4.

Construction Permit (CP) acclications except for those portions of CP applications that reference stancard designs (i.e.. PCA, FOA-1, FOA-2, PCCA, F00A-1, F00A-2, or ML) or *.nat reference

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qualified base plant designs uncer the rectication oc.fon.

7 - Af/<dhtnerb A 1785 154

p anons In addition, the NRC staff intends to implement Fact >cryd41 of this guide for all operating plants, plants under construction, all PDAs and FOAs, all P00A's and all F00As that may involve additions, elimination, or modification of structures, systems, or components of the facility after the construction permit or design approval has been issued. All backfitting decisions in accordance with the positions stated in this guice will be determined by the staff on a case-by-case basis.

The implementation date of this guide will in no case be ear 11er than April 15,1980.

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Table 1 M DESIGN CRITERIA 1 CRITERIA INSTRUMENTATICN TYPES 3 A

B 4

0

/

1.

Seismic qualification yes yes s

no 3

per Regulator / Guide 1.100 2.

Single failure criteria yes yes no o

per Regulator / Guide 1.53 3.

Environmental qualification yes yes yes per Regulator / Guide 1.89 4

Power source Emra 37 Emr8 e rs 5.

Out-of-service interval a

e t

before accident 6.

Portable no no l'

noll n 11 7.

Quality assurance level 12 12 12 8.

Display type 13 Con 14 Con + Cn*

C0ts is 1

1 9.

Display method Rects geet; e;

Indts I ts,ts t

10. Unique identification yes yes y

no n

11. Periodic testing :er yes yes y

yes Regulator / Guide 1.113 Unless cifferen: specifications are given in ents regulatorf guice, ne specifications in ANSI N320-1979. Performance Soecifications for Reactor Emergency Raciolegical wonitoring Instrumentation," acoly to tne hign-range containment area monitors, area ex;osure rate onitors in otner buildings, effluent and envirormental monitors, and po.cle instruments for measuring radiation or radioactivity.

2 Type A - Those instruments tnat provida information required to take preplanned manual actions.

Type B - Those instruments that provide information to monitor the process of accomplishing critical safety functions.

Type 0 - Those instruments that incicata tne performance of incivicual safety systems.

Ses in tru.. nt th ; ;r vice inf reatdon for use in data in'pg t.

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"ei ise f f r c ica iv tat a

pr :c. nu Ty as s.ng aca rel as, fo/ de nst /n. ::

r ag sf.

3 Radiation monitors snould meet tne ricuirements of ANSI N320-1979, Sec-icn 5.'4 anc/or Section 9.1.*5, as accroariata.

• See paragraon 5.3.5 of Graft Stancard ANS-4.5.

(Footnotes continuec) 9-AWdrnen-f A h See. A+f4Ch men 4

-fo r-spectM C.

etrid de4aile.d co%s,rk en %g

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Footnotes continued for Table 1 I

8 Qualified to tne conditions of its operation and, for radiation monitors, ANSI N320-1979.

• Emergency power source.

7 Critical Instrument Sus - Class 1E Power.

^

Paragraph 4.11. "Exemotion," of IEEE Standard 279-1971.

8Sased on normal Technical Specification requirements on out-of-service for s

the safety system it serves.

10Not necessary to include in the Tecnnical Specifications unless specified by other requirements.

11 Radiation monitoring outside containment may be portable if so designated in Tables 2 and 3.

12 Level of quality assurance per Appendix 9 to 10 CFR Part 50.

18 Continuous indication or recording displays a given variable at all times; intermittent indication or recording displays a given variable periodically; on-demand indication or recording displays a given variaole only wnen requested.

14 Continuous display.

18 Indication on demand.

18Where trend or transient infor=ation is essential to planned operator actions.

17 Recording.

asDial or digital indication.

1' Effluent release monitors require recording, including effluent radioactivity monitors, environs exposure rate monitors, and meteorology monitors.

20 Radiation monitors snould te eriodically tested in accorcance with the recuirements of ANSI N320-1979.

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Measured Yariaale tange Type Purpeet JCit Care Emit Tescerature 150*F to 220C*F 8,C 25 4.5. Section f.2.3.

To provice Incar-e ta=cerature ocasurements ta icentiff localized hot areas. (Accrosisataly $3 sessuresents)

Control tod Positten Full fa er not 3

To provide positive faafcation tnat full in the control ecos are fully inserted.

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(Minfaus 5 days af ter accicent)

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Neutron Flus 1 c/s to :*. power E

MS a.5. Section 6.2.2.

(at least one For indication of accroacn ta i

ffssten counter) criticality.

RIACTCt CCOLANT $YSTDt

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RCS Hot Leg Tescer-15C*F to 750*F B

05-4.5. Section 5.2.3.

ature To af d in detamtv g reactar systas l

subcaoling anc is srevice volcation ef natural circulat? n.

3 RC$ Cold Leg fe car-130*F to 750*F B-2 5-a.5. Section 6.2.3.

sture To provice indication of satural circulation; to 3rovice ' rout f ar heat talance calculations: *a provide alrect teotcatten of i:03 fnjection.

1 RCS Pressure 15 psia to 4C00 8.C 25-a.5. Sections 6.2.3 ano i.2.4 I

pstg For fnetcation af an accicaat ano to inoicate inat actfoes ust :e taken to sittgate an event.

I.

Pressuciter Level lettom tangent ta 4.2 05-a.5. Section 6.2.3.

top tangent To assure scoser : eastion of tne pressurfter and to assure safe coerstion af 9 eaters. It ts also used in conjueet :s etin c anges in reactor sressure to :starstne lett and veto sizes.

Gegree of $d coolfeg 200'8 s%3csoling to E

For indication af aargin 4 :sre 3S'F supernest cooltag and *.no aees 'se eeer emey coolant aest t*:ns se recuttions as toe margin enan;es ano ts :nviate the necessity ta consult steam taales.

4 11 178(

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Taale 3 SWR vat!A8tts Measured Vartaale R&nge Type Pvrpose C0tt Care Exit Tesoerature 150*F to 23Co*F B.C To provies fecore tamoerature seasurements to f centify tocatf red het, areas. (Accreateately 50 eessurements)

Control tod Position Full in er not D

To provt::a position f naf cation 19at the full in control ro'es are fully insertad.

(Minfeue of 2 nours af*er accicent)

Neutron Fluz 1 C/s to I% pcwer 8

AN5-4.5. Section 6.2.2.

(at least one For Indication of accroach to fission counter) criticality.

t!ACTCt COOLANT SYSTEM ACS Pressure 15 osia to 8.C AMS-a.$. Sections 6.2.3. 6.2.4 2000 psig 6.3.3. and 6.3.5.

For incication of an acc? cent and to indicate taat actions sust se taken to aftigata en event.

Coolant Level in the Bottom of care B

ANS-4.5. Section 6.2.3.

Raactor succort stata For indication of f ael sucrer.ency to acove tse of for a LOCA event.

disenarge plenus Main Staanitne Flow 0 to 120% cesign 8

Te provide an f netcation of tre flout integrity of the pressure councary.

Mafn Staasline !sels-3 to 15" of water 3

To provfde an facication of tse tion valves' Leenage 3 to 5 pate pressure councary and centatnment Caetrol Systes Pressure Primary System Safety 01osee not closed 9.3 By tfiese sessurements, ine oce* star telfer valve sost-or knows if trere ts a :ata seen far tions, fncluetag 0 to 50 psig less of coolant anc tf an event A05 or Flow Th mugs asy te in progress, er Pressure in valve Lines f785 159 6Cesign flow - tse samfeum '1cw ant?cf=4teo 'n 9er-al aceratte ;

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$ %fer so h41schinen+ C, Ear de% \\ed commh an eae h Varia bk-.

Applicability of Proposed Regulatory Guide 1.97 Rev. 2 to BWR 5 Reactors with Mark II Containment Section Pace I General Coments on Applicability 1

of Design Criteria for each Category of Instrument II Comments on the Applicability of 5

other Regulatory Guides III Coments on Specific Design Criteria 7

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Attachment B Apolicability of Proposed Rev. 2 to R.G.1.97 to BWR 5 Mark II's I.

General comments on applicability of design criteria for each category of i nstrument.

A.

Type A instrunents: Those instruments that provide information required to achieve preplanned manual actions.

Design Criteria Specified 1.

Seismic Qualification R.G.1.100 Agree that it should be provided.

2.

Single Failure Criteria R.G.1.53 Agree that it should be met, where appropriate.

3.

Environmental Qualif. R.G.1.89*

Agree that some level of testing should demonstrate that instr.

will survive expected environmental transients. Do not agree that R.G.1.89 be followed.

4.

Power source **

Do not understand difference between " emergency" and Class IE

" Critical" buses. Assume it means one which can be backed up by Class IE.

If so, agree.

If not, see further comments in Section III.

5.

Out of service interval Since this 's not considered protection system i.e.,

it includes the operator taking action based on a mental decision process, note 8 is an error referencing IEEE 279-1971, pgh 4.11.

Instead, Tech Spec limits on the operability of the system in which it is installed should adequately cover the allowable out of service interval.

6.

Portable Agree with Draf t Rev.

7.

Q.A. Level **

10CFR50 App.BshouldonlyYtothe extent of designs at the level of combining cormiercia' grade equip., and dedicating it for nuclear service. For example, Q.A. on the design process of the system is required, but not of each component in,the system unless it is now commercially$h kb available, and recognized by the manuf acturer that QA is important to safety.

Attachrent 8 I. Discussion of General Categories of Instruments (Cont'd)

10. Unique identification If specific operator action is planned, identification should be different from those parameters for which possible operator intervention is unplanned.

11. Periodic testing R.G.I.118 Provisions should be made.

• • See discussion of specific design requirements.

(Section III) See discussion of applic'.bility or other Reg. Guides. (Section II) 8. Type B instrunents: Those instruments which provide information to monitor the process of accomplishing critical safety functions. e.g. reactivity control, core cooling, RCS integrity, containment integrity, and reactivity effluent control. 1. Seismic Qual. (R.G.1.00) Agree 2. Single failure criteria (R..G.1.53) Agree 3. Env. Qual * (R.G.1.89) Some level of testing reg'd - See Section II 4, Power Source ** (Crit. Bus) Agree, if this refers to Class 1E Bus. 5. Out of service Interval Tech. specs should specify. 6. Portable Agree 7. Q A. Level ** Same coment as " Type A". 8. Display type Continous - agree 9. Display method Since for this type of parameter, the important information is what's happening now (current process parameter) either indicating or recording should be allowed.

10. Unique Identification Should be different than those for which preplanned operator action is required.

11. Periodic testing (R.G.I.118)

Should have provisions for periodic testing. 1785 162

Attachment B I. Discussion of General Categories of Instruments (Cont'd) C. Type C instruments: Those instruments which indicate potential for breaching or the actual breaching of the fission product barriers. " Potential" is defined in ANS4.5 as the extent to which parameters have exceeded the design basis values. (In the case of containment systems, this is same as type B instruments). 1. Seismic Qual. (R.G.1.100) Agree 2. Single Fail Crit. (R.G.l.53) Agree 3. Equip. Qual * (R.G.1.89) Some level of testing - See Section II. 4. Power Source **(Crit. Bus) Agree, if this refers to Class lE Bus. 5. Out of service interval Should be Tech Spec. - same as "B" type. 6. Portable No except where indicated. 7. Q.A. level ** Same comment as Type A 8. Display type Same coment as Type B - agree it is continuous. 9. Display method Should be either recordino _o_r indicating.

10. Unique identification Should be different than Tyoe A.

11. Periodic testing (R.G. 1.118) Should have provisions. In general, Type "C" instruments meet all the same qualification requirements as Type "B" instruments. In addition, specifically for BWR 5 Mark II containments, those parameters (except for reactor coolant radiation) listed as being Type "C" were also listed as being Type "B". T he difference given in ANS 4.5 between "B" and "C" instruments are the extended " arbitrary" ranges for the Type "C" instruments, and qualification to a level consistent with their given arbitrary range. Specifically, for reactor coolant radiation, indicative of breach of fuel element barrier, it is impossible given present state of the art teghnology to calibrate on-line as requested in Draft note 8 to a level of 104 curies /cc. Type "C" should be lumped together with Type "B" because it is only one kind of protective safety function. A note should instead'be added to depict the fact that they have extended arbitrary ranges. 1 1786 163

Attachment B I. Discussion of General Categories of Instruments (Cont'd) D. Type "D" instruments: Those that indicate that the perfonnance of cafety systems is as designed. 1. Seismic Qual. (R.G.1.100) Disagree with Draft - passive qualification should be required. 2. Single Fail Crit.(R.G. 1.53) Not reg'd. 3. Environ. Qual.(R.G.1.89) Should be to the extent of measurement of its parameter, and to maintain pressure boundary in event of seismic. 4. Power Source See Section III. 5. Out of Service interval Tech Spec. limits ok. (agree) 6. Portable A, gree. 7. Q.A. level Not important here (disagree). 8. Display type On demand (agree). 9. Display method Indication ok. (agree).

10. Unique identification Not reg'd (agree).

11. Periodic testing (R.G. 1.118)

Agree some should be provided to demonstrate indication actually works. Table 1 (Design Criteria) lists for Type "D" instruments that Reg. Guide 1.100 (seismic qualification) does not have to be met but, it does list Reg. Guide 1.89 as having to be met. Reg. Guide 1.89 (see section II) requires that IEEE 323-1974 be met, and this in turn requires that IEEE 344-1975 (Seismic Qualification) be met as part of the environmental qualification. We assume that Table 1, criteria 3 should be interpreted to mean that Reg. Guide 1.89 must be met, with 9 exception of seismic qualification. E. Type E instruments: Those which provide info for use in determining magnitude of actual release of radioactive materials, and for continuously assessing such releases. 1. Seismic Qual (R.G.1.100) Agree with Draf t --qual. not necessary. 2. Single Fail Criteria (R.G.1.53) Agree with Draft --qual. not necessary. 1786 164

Attachment B I. Discussion of General Categories of Instruments (Cont'd) E. Type "E" Instruments: (Cont'd) 3. Environ. Qual (R.G.1.89) Agree with Draf t 3--qual. not necessary. 4. Power Source Should be non-essential plant power. 5. Out-of-Service int. (See notes below) 6. Portable Can be, if necessary, but requirements should be changed for power supplies. 7. Q.A. level No special Q. A.-necessary. 8. Display type On demand (agree) 9. Display method Indication or Recordings 5,e

10. Unique identification (See below) notes

11. Periodic testing (R.G. 1.118)

Should have some b el.o2 requirements, but documentation not required. The Type "E" category created by the NR2 staff over and above the ANS 4.5 requirements has no justification. The types A, 8, C, & D instruments described adequately can determine the nature and extent of the accident condition.T pe's"should not be covered in regulatory guide 1.97. 9 Further, the staff has made some wrong assumptions. Many instruments in the general category of instrumentation they chose to call Type "E" are not used to determine the magnitude of the release, for defense in depth, or for diagnostics. Instead the individual plants have formulated plans for emergency preparedness, and it is up to other agencies to carry out these plans. Generally these plans are based on information from comercial grade equipment, for which there is no reason to upgrade the qualification of this equipment to Table 1 requirements. II. Coments on the Applicability of other Reg. Guides A. Environmental Oualification per Reg. Guide 1.89 Reg. guide 1.89 endorses the use of IEEE 323-1974, Qualification of Class 1E equipment for Nuclear Power Generat'ng Stations. This IEEE Standard assumes that anything which must be qualified using its criteria has already been categorized as Class "1E". .._4785 165

II. Coments on the Applicability of other Reg. Guides (Cont'd) A. Environmental Qualification per Reg. Guide 1.89 (Cont'd) The definition of Class "1E" is: The safety classification of the electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling, and containment and reactor heat removal, or are otherwise essential in preventing significant release of radioactive material to the environment. Note that the definition does not say: "those systems essential to monitoring emergency reactor shutdown, (etc.)". In addition, it specifically singles out those systems essential in preventino release of radioactive material. The main point of the above is to point out that with the exception of Type "A" instruments (those instruments providing information for the operators to take pre-planned action) none of the instruments required by Draf t 2 are classified as Class 1E, and hence a reference to Reg. Guide 1.89 for Types B,C,0, and E instrument is inaoprooriate. We feel however, that some level of qualification to adverse environmental conditions should be done. We suggest qualification in accordance with a level consistent with the expected abnormal transients for temperaturc, pressure, humidity, and seismic conditions, as well as variations in electrical power supply. We do not advocate performing aging testing because the periodic inspection and testing together with the relatively short instrument life typical of current technology will assure that a working instrument is always installed. In addition, the types of aging testing usually performed for those Class 1E reactor protection system instruments have not proven to be appropriately applied or conducted, as the testing criteria originally came from cable testing or other mechanically-oriented, passive devices. Specifically, the LaSalle County licensing position is to comply with IEEE 323-1971, not IEEE 323-1974 as required by Reg. Guide 1.89. This is true of both the 80P and the NSSS portions of the equipment. Because commercial grade equipment qualified to IEEE 323-1974 is not now currently available, we would not be in a position to comply with this standard until manuf actures have products which meet this standard. B. Periodic Testing Reg. Guide 1.118 endorses the use of IEEE 338-1975, which is ancillary to IEEE 279-1971 and IEEE 380-1974 The NSSS design complies with this guideline to enable response time testing baseql on relay contact intervals, but not sensor responses to stimulating media. 1786 166

Attachment B II. Coments on the Applicability of other Reg. Guides (Cont'd) 8. Periodic Testing (Cont'd) Otherwise, LaSalle meets the intent of regulatory positions C.1 through C.7. (No specific design features were included in the BOP systems to facilitate response time testing). III. Coments on Specific Design Criteria A. Power Source Draft 2 indicates two types of power sources " Emergency power source", and " Critical Instrument Bus-Class 1E Power". We are not sure as to what is the difference between these two source descriptions. It would seem to us that if a component which is not required to be seismically, or environmentally qualified (such as the Type "D" and "E" instruments), is put on a Class 1E power supply, there is a chance of degrading that bus; therefore there must be some difference intended. However, we do not know of any nuclear power station which uses the term " Emergency power source" in a context different from " Class 1E" power source. On the surface it appears that the NRC staff has created a requirement for a new power supply: one which has an alternate generator back-up that is different from the Class 1E buses backed up by in-plant diesel generators. B. 0.A. Level In general, we favor system design to be required to meet all of 10CFR50 App. B and ANSI N45.2 requirements, but component design consisting of off-the-shelf hardware be exempted from this requirement. 1785 167

Attachment B III. Comments on Specific Design Criteria (Cont'd) C. Display Method We assume that the following hardware falls into these categories: Continuous display types: Recording Pen Recorders (Hard-wired to transmitters) Multi-Point Recorders (even though there is a small but finite time gap between successive printing of each channel) Computer-driven trend recorders Dial or Digital Indication Analog meters Displays Driven by Computer Light Bulbs Lit by Hard-wired contacts Digital window displays or seven-seguent BCD displays. D. Unique Identification The method of unique identificaticn can be based on applying different colored borders to the instruments that are essential for safety, to highlight these readouts. It is recommended that type "A" instrument readouts have a different color border than the "B" or "C" instruments. It is njtil assumed that unique identification means that a dedicated " accident" CRT be added to the computer system. V 1785 168

? Attachment C Post-Accident Variable Data Sheets This attachment contains an itemized breakdown of Table 3 of the proposed Revision 2 to Regulatory Guide id7, as it pertains to LaSalle County Station. For each variable, the requirements are listed, together with a presentation of the current LaSalle design, general comments or clarifications, and cost and scheduling impact notes. For a discussion of how to use the information presented in the cost and impact statements, refer to Attachment D. Table of Contents Pace V ariable 1 Core Exit Temperature 2 Control Rod Position 3 Neutron Flux 4 RCS Pressure 5 Coolant Level in the Reactor 6 Main Steamline Flow Main Steamline Isolation Valves' Leakage Control 7 System Pressure Primary System Safety Relief Valve Positions, including ADS of Flow Through or Pressure 8 in Valve Lines 9 Radiation Level in Coolant 10 Primary Containment Pressure Containment and Drywell Hydrogen Concentration 11 Containment and Drywell Oxygen Concentration for those plant with inerted containments) 12 13 Primry Containment Isolation Valve Position 14 Suppression Pool Water Level 15 Suppression Pool Water Temperature 16 Drywell Pressure Drywell Drain Sumps Level (Identified and Unidentified 17 Leakage) 18 High-Range Containment Area Radiation 19 Main Feedwater Flow 20 Condensate Storage Tank Level 21 Containment Spray Flow 22 Steam Flow to RCIC 23 RCIC Flow 24 RHR System Flow 2f RHR Heat Exchanger Outlet Temperature 26 Service Cooling Water Temperature 27 Service Cooling Water Flow 27A Flow in Ultimate Heat Sink Loop 28 Temperature in Ultimate heat Sink Loop 29 Ultimate Heat Sink Level 30 SLCS Storage Tank Level Sump Level in Spaces of Equipment Required for 31 Safety s. 1785 169

Attachment C l_,at-AccidentVariableDataSheets Table of Contents (Cont.) Page Variable 32 High Radioactivity Liquid Tank Level Charcoal Delay Gas System Gas Flow or Radioactivity 33 Level 34 Emergency Ventilation Damper Position Temoerature of Space in Vicinity of Equipment 35 Required for Safety 36 5tatus of Class lE Power Supplies and Systems 37 Status of Non-Class lE Power Supplies and Systems 38 Radiation Exposure Rates 39 Effluent Radioactivity-Noble Gases Effluent Radioactifity-High-Range Radiohalogens 40 and Particulates 41 Environs Radioactivity-Exposure Rate 42 Environs Radioactifity-Radiohalogens and Particulates Plant and Environs Radioactivity (portable instruments) 43 Primary Coolant, Suppression Pool, Containment 44 Air, Standby Gas 45 Post Accident Analysis Capability (On-site) Meteorology: Wind Ofrection, Wind Speed, Temperature, 46 Vertical Temp. Difference, and Precipitation 47 SCHEDULE IMPACT NOTES 1785 170

'. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Core Exit Temperature Range - 1500F to 23000F Type - B,C Purpose - To provide incore temperature measurements to identify localized hot areas. (Approximately 50 measurements) LaSalle Design: Recuired Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes 2. Sing. failure /RG 1.53 Yes (This 3. Env. qual./1.89 Yes (Parameter 4. Power Source Class 1E (Currently 5. Out of Service Int. 279-1971 (Does Not 6. Portable No (Exist 7 Qual. Assur. ',evel 10CFR50 App. B (On LaSalle 8. Display Type Continuous 9. Display Method Recording

10. Unique Ident.

Yes

11. Per. Test./RG 1.118 Yes Discussion:

See A nc.ch e'd ente op Cost and Schedulina Impact to Uparade: Design, procurement, and installation of a $600,000 50 channel core temperature measurement system (NSSS vendor estimation) up to 32 month completion. 5600,000 Schedule Imoact Notes See Notes 1, 2, 3, 4, 5 and 6 1785 171

Attachment C Core Exit Temperatures in BWR Core exit temperature indication will not improve the safety of BWR's. The apparent utility of post accident core exit temperature indication would be location of fuel blockage caused by a postulated accident which produced significant structural damage to the fuel. There is no other apparent use. As described in the following paragraphs for normal operation or accident mitigation core exit temperature indication is useless. The capability to locate fuel blockage in a significantly degraded fuel has no safety benefit. A postulated accident which causes significant fuel degradation, will be identified by various radiation indications. These indications are totally adequate to estimate the extent of core damage, to initiate emergency procedures, and to develop recovery plans. Since the proposed core exit temperature indication system has no safety benefit, it shoulf not be an NRC requirement for BWR's. What the NRC is really asking for is a fuel cladding temperature monitor. The most logical and certain status indicator for a change in fuel state would derive from " temperature state" measurements from solid-state fusible links distributed throughout the core. The insertion of fusible links for three temperatures (2000, 2200, 24000F) into the power on monitoring circuit of the LPRM's provides a method by which post accident fuel melting can be determined. These LPRM strings provide axial core separation vertically such that a structured distribution of fusible links can be planned to cover the geometry with temperature state monitors whose fusion can be monitored with time in the post accident situation. An operational advantage accrues in the subordination of this post accident indicator to a status light that is routinely monitored for continuity. Also, a major thermal calibration problem is avoided by not using thermocouples or RTD's. Another useful feature is that LPRM strings are changed out from time to time, and the expense should, therefore, be minimal if this requirement is mandated by NRC. Thermocouples are purposefully not used in the BWR to indicate fuel bundle perf ormance nor operational safety margin (status). The thermal performance of the core is designed on the basis of an extremely conservative linear heat generation rate (MAPLHGR) on the fuel element which takes into account the fuel temperature and the heat removal rate by the coolant. This basis is empirically derived from heat transfer correlations from actual fuel elements in reactor conditions for millions of fuel-element-years of experience. For reactor operation, the safety margin inherent in the BWR operating regime is controlled by a minimum critical power ratio (MCPR) based upon the convective heat transfer condition experienced by the fuel element. This operational safety margin is consistent with the design (MAPLHGR) performance curves previously cited. 1785 172

Attachment C Core Exit Temperatures in BWR (Continued) With this design and control approach, detailed temperature profiles of the core, either radial or axial, provide no useful information on which to adjust power or flow once the reactor performance verification has been authenticated during start-up tests. Indeed, there is no design capability to control performance as a function of temperatures in the core region. Power regime control of the reactor is exercised on a bulk-coolant pressure property (state values of pressure and enthalpy versus flow), whereas f uel perf ormance, i.e. burnup, parameters are measured by neutron flux and time. The bulk state values are mean values within the design approved power-flow domain (map). For particular state valves, a corresponding temperature parameter can be computed but its magnitude is not meaningful in a systems control sense with a Rankine cycle turbine that uses pressure as the dominant (practical) variable. The reactor feedback variable for control is also pressure because pressure in the core determines coolant density and density directly affects reactor flux. Thus pressure is the dominant variable with the largest gradient with respect to core flux and with the largest range for control of BWR systems. Temperature devices are not needed to knowledgeably and safely operate the BWR in its control regime. Pre sure is the most practical and useful operating variable for BWR's. Tempura.ure information is of secondary importance in the normal operation of BWR's. For transaccident determination of core status in an abnormal situation, the most significant parameter is the presence or absence of coolant in the core. Operating experience dictates that plant shutdown occur immediately upon confirmation of loss of coolant. Such confirmation can come from high radiation monitors on the main steam , lines or from anomalous APRM indications that the core is not covered. The primary indications would of course come from the multiple, redundant level instrumentation (28 channels in BWR-5 and 42 channels in BWR-6) to indicate improper vessel water level. All essential safety actions for this situation are designed to assure that adequate coolant is injected into the core region for both accident and transient situations. Several automatic ECCS actuations occur in the BWR to assure coolant availability for core coverage. The normal operator response is to isolate the reactor to conserve cool ant inventory whenever water level adequacy is uncertain, thus permitting the normal inputs (feedwater) to surpass the outputs (steam to the turbine) and thus increase the water level in the vessel. Local temperature information from the core based on convective heat transfer to tha coolant medium (part steam, part water for the partial coverage situation) at such a time as this would require significant additional inf ormation with regard to local pressures, leakage paths, refluxing loops, blocked channels, stagnant conditions, etc. before an intelligent response action could be made. As an indicator of core status during the transaccident period, the only useful status to know in the BWR is whether or not coolant is present in the core and is more coolant needed. The level instruments provide the former and the ECCS actuation switches provide the latter. Confirmation of proper operation is available to the operator as stated above via the APRM's to verify the continuity of core coverage. 1785 173

Attachment C Given that the reactor is shutdown, the post accident determination of core status and fuel clad status for the retention of fission products is the primary concern. (Containment integrity is justifiably presumed). Indication of clad status correlates back to the radiation readings on the main stear lines just prior to isolation, but post accident determination is available from reactor water samples and containment air samples for the case of a break of the primary pressure boundary. Other lead-in information on the possibility of fuel melt is indicated from abnormalities in the APRM readings compared to normal core APRM readings. Indications of core status via temperature profiles from in-core thermocouples would again be fraught with the same uncertainties of local pressure, stagnation, refluxing, etc. enumerated for the transaccident case plus the uncertainty of geometric distortion in melt zones. Absolute determination of core status is probably not attainable via data requiring correlation of state values of pressure, temperature, etc. because of postulated internal exothermic reactions, uncertainty in geometry, and unrestrained hypothesizing by instant experts. Responsive actions do not range sufficiently to overcome that level of uncertainty anyway. Certainly, a range of 0-23000F for core exit temperatures is inappropriate. The water in the core exit will never be as high as 2300uF. In a BWR, there are safety relief valves which lift at pressures in the 1000 psig to 1150 psig range. At this pressure actuation level and any temperature exceeding the normal 5500F the water flashes immediately to steam and is replaced by emergency core cooling water. The inventory of water in the vessel can never be heated more than the pressure actuation of the safety relief valves allow. If the NRC is assuming a complete failure of all 18 safety relief valves so that the water can be heated, they must also assume that the vessel can be pressurized to 4380 psig in this condition, because that is what it would take thermodynamically to achieve a core exit temperature of 23000F. 1408A 1785 174

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Control Rod Position Range - Full in or not full in Type - D Purpose - To provide position indication that the control rods are fully inserted. (Minimum of 2 hours after accident) LaSalle Design: Required Desian Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. f ailure/RG 1.53 No Yes 3. Env. qual./1.89 Yes No 4. Power Source EMR Bus. No 5. Out of Service Int. Tech Spec Rqmt. Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No No

11. Per. Test./RG 1.118 Yes See Comments p.6 Att.B LaSalle's design consist of a non-quality grade system of indication The sending designed to function in the non loss of off-site power condition.

hardware (multiplexing electronics) is designed to function under normal reactor operating conditions prior to the environmental transient effect The system is not required to function 2 or more hours caused by LOCA's. af ter the accident because the operator ascertains trip has safely occurred by 10 minutes after the accident: Cost and Scheduling Impact to Upgrade: Design, procurement, and Installation of a $300,000 quality grade RPIS, with emergency power provisi ons. Qualification of hardware to function minimum 2 hrs into accident (NSSS vendor estimates) Schedule impact: See noptes 1, 2, 3, 4, 5, and 6 i785175

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Neutron Flux Range - 1 c/s to 1% power (at least one fission counter) Type - B Purpose - ANS-4.5 Section 6.2.2 for indication of approach to criticality. LaSalle Design: Required Design Criteria g LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes No 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No 4. Power Source Class 1E No-MG Set Only 5. Out of Service Int. 279-1971 Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type Continuous Yes 9. Display Method Recording No-Indication

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes Yes-See Comments LaSalle's design consists of non-quality grade components designed to function during the normal start-up and operation modes of the reactor.

Environmental qualification is not required because the Zero Plux Level occurs on reactor trip. It is not designed for the loss of off-site power condition for indication purposes. The required range cannot be covered by a sing l monitor, and it is anticipated that a series of three detectors are required. Cost and Scheduling Imoact to Upgrade: Design, purchase, and install a quality-grade, $360,000 seismically-and environmentally-qualified Neutron Flux indication system. (NSSS vendor anticipates up to 24 months completion) Scheduling Impact: See notes 1, 2, 3, 4, 5 and 6 1786 176

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - RCS Pressure Range - 15 psia to 2000 psig Type - 8, C Purpose - ANS-4.5, Sections 6.2.3, 6.2.4, 6.3.3, and 6.3.5. For indication of an accident and to indicate that actions must be taken to mitigate an event. LaSalle Design: Required Design Criteria B_ v, LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No-Meets 1EEE 323-1971 only 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec Limit 6. Portable No No 7. Qual. Assur. Level 10CFR5e pp. 8 No 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Cormlents, Pg. 6 of Att.B Currently LaSalle does not meet the 0-2000 psig range.

Instead we have 0-1500 psig. The current range covers 110% of the highest ATWS transient. Cost and Schedulina Impact to Uparade: 10CFR50 App.B and 1EEE-1974 Transmitter upgrade: $700.00 X 2 = $1400 (not currently available, expect 32 week delivery when available) Unique identification 25.00 X 2 = 50. Range change of recorder 300. Piping upgrade to 2000 psig (Rehydro) 84,000. (Same piping new documen- $85,750. tation and rehydro) 25 men 9 4 days @ 8 hrs / day = 16,000 25 men @ 4 days @24 hr/ day = 48,000 Total =$S4,000 Scheduling Impact: See Notes 1, 2, 3, 4, and 5 1785 177

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Coolant Level in the Reactor Range - Bottom of core support plate to above top of discharge plenum Type - B Purpose - ANS-4.5, Section 6.2.3. For indication of fuel submergency for a LOCA event. LaSalle Desian: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No-meets 1EEE323-1971 only 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec Limit 6. Portable No No 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Comments, Pg. 6 Att.B support plate to above top of discharge plenum. quirement bottom of core Currently LaSalle does not meet the range re LaSalle can measure -150" to

+60" where 0 is " normal" feedwater control system design level. The -150 corresponds to 17" above top of active fuel (wide range). Additionally, LaSalle has a fuel zone (single instrument loop) level indicator which covers -150" to 0" to +50", where 0 corresponds to top of active fuel. Cost and Scheduling Impact to Upgrade: 10CFRApp. B and 323-1974 transmitter upgrade for wide range $700_X 2 = $1400 transmitter Unique identification 50 X 2 = 100 323-1974 upgrade of fuel zone transmitter loop 700 X 2 = 1400 Addition of second fuel zone channel (transmitter, recorder, power supply cables, piping, QA, maintenance, etc.) $42,400 Total $45,300 Schedule Impact: See Note 1, 3, 4, and 5 l'785 178

4 Attachment C Req. Guide 1.97 - Table 3 Variables Variable - Main Steamline Flow Range - 0 to 120% design flow Type - 8 P.rpose - To provide an indication of the integrity of the pressure boundary LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes No 2. Sing. failure /RG 1.53 Yes No 3. Env. qual./1.89 Yes No 4. Power Source Class 1E Plant Normal Instr. Power 5. Out of Service Int. 279-1971 Not Redundant 6. Portable No No 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. 1?nique Ident.

Yes No

11. rer. Test./RG 1.118 Yes Yes-See Comments V. Atv.b LaSalle does not have redundant flow measurement, and cannot comp y with We see no need to even measure flow in main team-RG 1.53, 1.89, or 1.100.

lines at all. The NRC assumes that if a main steamline does not isol te that the existing flow elements will be sensitive enough to measure leakage flow. Instead, we have a leakage control system which is This is not the case. designed to detect the presence of leakage through MSIV's and process that leakage before release to the environment. Flow measurement is not necessary because flow restrictors regulate maximum LOCA outflow prior to isolation by MSIV's. Their leakage is processed by the MSIV-Leakage Control System. Cost and Schedulino Imoact to Upgrade: Additional instr. loops for flow monitoring 4 X $42,399.03 = 169,596.12 Increase capacity of Safety-related power supplies 20,000.00 = 20,000.00 1,000.00 Add documentation for out-of-service interval 1,000.00 = 50.00 50.00 = Unique identification 4,000.00 Isolators for Feedwater Control System (Class 1E) 4,000.00 = 194,646.12 20,000.00 Cost of upgrading old hardware to IEEE stds. $214,646.12 Schedule Impact: See Note 1, 3, 5 and 6 1786 179

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Main Steamline Isolation Valves' Leakage Control System Pressure Range - O to 15" of water 0 to 5 psid Type - B Purpose - To provide an indication of the pressure boundary and containment LaSalle Design: Required Design Criteria By LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes No-1 XMTTR for each 3. Env. qual./1.89 Yes No-323-1971 only 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 No 8. Display Type Continuous Yes 9. Display Method Recording No

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes Yes-See Comments P.6 Att.B This system should take this place of requirement for main steam line flow monitoring. The required range is 0-15" WC. or 0-5Psid. LaSalle range is 30" Hg to 10 Psia.

Cost and Schedulina Imoact to Upgrade: $2400.00 Upgrade to 323-1974: $600.00 X 4 = $1200.00 Change Scale Range: $300.00 x 4 = Add Redundant Inst. Loops: $42,400.00 x 4 = $169,600.00 $100.00 Add Unique Identification: $25.00 x 4 = $6,000.00 Replace Ind. With Recorders: $1,500.00 x 4 = $179,300.00 Schedule Impact: See Notes 1, 3 and 5 1785 180

8-Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Primary System Safety Relief Valve Positions, including ADS or Flow Through or Pressure in Valve Lines Range - Closed-not closed or 0 to 50 psig Type -B,0 Purpose - By these measurements, the operator knows if there is a path open for loss of coolant and if an event may be in progress LaSalle Design: Required Desian Criteria By LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 Yes No 2. Sing. failure /RG 1.53 Yes No 3. Env. qual./1.89 Yes No 4. Power Source Class IE Yes 5. Out of Service Int. 279-1971 Tech Spec. 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type Continuous Yes 9. Display Method Recording No-Ligiit Bulbs Only

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Comments Pg. 6 Att. B Method of indication is not conducive to being recorded without the aid of a process computer. LaSalle's computer is non safety-related.

Cost and Scheduling Imoact to Upgrade: Add Redundant SWS. and Lights: $10,000 x 18 $180,000 = Upgrade to Seismic and: $ 3,000 x 18 = $ 54,000 Environmental 323-1974 Add Saf. Rel. Recording Sys. Add Unique Identification: $25 x 18 $450. = $234,450 It is estimated that a dedicated safety related processor can be added for approximately $300,000. Definite Scheduling Impact. Scheduling Impact: See Notes 1, 3, 4 and 5 178:5 181

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Radiation Level in Coolant Range - 10 uCi/cc to 10Ci/cc Type - C Purpose - ANS-4.5, Section 6.3.2. For early indication of fuel cladding failure and estimate of extent of damage. LaSalle Design: Required Design Criteria By, LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes No 2. Sing. failure /RG 1.53 Yes No 3. Env. qual./1.89 Yes No 4. Power Source Class 1E None 5. Out of Service Int. 279-1971 Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B None 8. Display Type Continuous None 9. Display Method Recording None

10. Unique Ident.

Yes None

11. Per. Test./RG 1.118 Yes Not Documented Presently LaSalle's menthod of determing the level of radiation in the reactor coolant is via manual sampling.

Cost and Scheduling Impact to Upgrade: If LaSalle had to implement and automatic grab sampling system to accomodate this requirement we estimate the following hardware and engineering costs: $400,000 Automatic Grab Sampling Sta.: $200,000 x 2 = Shielding for Sampling Sta. $ 40,000 and Sample Line: $ 20,000 x 2 = $ 16,000 Engineering & Design: $ 16,000 = Add Second Sampling Line & $ 30,000 Containment Isolation Valves: $ 30,000 = $ 40,000 Estimated Cabling Requirements: $ 20,000 x 2 = S 3,000 Control Room Recording: $ 1,500 x 2 = $529,000 Scheduling Impact: See Notes 1, 2, 3 4, and 5 9 1785 182

. Attachment C Req. Guide 1.97 - Table 3 Variables Variable - Primary Contaimnent Pressure 2 for Range - 10 psia pressure to 3 times design pressure concrete; 4 times design pressure for steel Type -B,C Purpose - ANS-4.5, Sections 6.2.5, 6.3.3, 6.3.4, and 6.3.5. For indication of the integrity of the primary containment pressure boundary; to indicate the potential for leakage from the containment. LaSalle Design: Required Design Criteria Bjc LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No-323-1971 only 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 Yes 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Comments on Pg. 6 Att. B LaSalle's range is 0 to 60 Psig which corresponds to 133% containment design pressure.

Cost and Scheduling Impact to Ucgrade: $6,000 Upgrade to 323-1974: $3,000 x 2 = 50. Add Unique Identification: 25.x 2 = $ 600. Change Recorder Scale Range: $ 300.x 2 = 56,650 Scheduling Impact: See Note 1 and 5 f 9

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Containment and Drywell Hydrogen Concentration Range - 0 to 10% (capabjlity of operating from 12 psia to maximum design pressure ). Type - B,C Purpose - ANS-4.5, Sections 6.2.5 and 6.3.5. For indication of the need for and a measurement of the performance of the containment hydrogen recombiner and to verify the operation of the mixing system. LaSalle Design: Required Design Criteria By LaSalle Comoliance GUde 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No* 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 Yes 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes Yes-See Comm. on Pg. 6 Att.B LaSalle's Range is from 12.7 Psia to 60 Psig, whereas the required range is from 12 Psia to 45 Psig.

Testing is currently in progress for IEEE 323-1974 Requirements Testing is expected to be completed by fuel load. Cost and Scheduling Imoact to Vograde: Add Unique Identification: $25. x 2 550. Schedule Impact: None $50. 1785 184

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Containment and Drywell Oxygen Concentration (for those plants with inerted containments) Range - O to 10% (capability of operating from 12 psia to design 2 pressure ) Type - B,C Purpose - For indication of the need for a measurement of the performance of the containment oxygen elimination system. LaSalle Design: Required Design Criteria g LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No* 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 Yes 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Comments Pg. 6 Att. B LaSalle's range is from 12.7 Psia to 60 Psig, shereas the required range is from 12.0 Psia to 45 Psig.

In addition oxygen measurement capability is a range of 0 to 20% as opposed to 0-10% required. Testing is currently in progress for IEEE323-1974 requirements. Testing is expected to be completed by fuel load. Cost and Schedulina Imoact to Uograde: Add Unique Identification: $25. x 2 $50. = Schedule Impact: None .~ 1785 185

A Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Primary Containment Isolation Valve Position Range - Closed-not closed Type - 8,C Purpose - ANS-4.5, Section 6.2.5. To indicate the status of containment isolation and to provide information on the status of valves in process lines that could carry radioactive materials out of containment. LaSalle Design: Required Desian Criteria Bj( LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes No* 3. Env. qual./1.89 Yes No-323-1971 only 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 Yes 8. Display Type Continuous Yes 9. Display Method Recording No-Light Bulbs Only

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Comments on Pg. 6 Att.B Each valve has full-cpen and full-closed indication.

There are 2 valves on each line penetrating the primary containment. Cost and Schedulina Imoact to Uparade: Addition of Redundant Indication Provisions for Each Valve: $20,000 x 400 = **$8,000 000. 3 Addition of Recording System: See Comments for Safety Relief Valve Indication. Upgrade to 323-1974: $20,000 x 8 $160,000 = Adding Unique Identification: $10. x 400 4,000 = It is assumed that this requirement will not be mandatory and that redundant valves each with single power sources is all that is necessary. Then the total would be $164,000. Scheduling Impact: See Notes 1, 3, 4 and 5 l7185 186

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Suppression Pool Water Level Range - Top of vent to top of weir well Type - B Purpose - ANS-4.5, Section 6.3.3. LaSalle Design: Required Design Criteria By LaSalle Comoliance Guide 1. Seis. Qual./RG.I.100 Yes Yes 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No-323-1971 Only 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 Yes 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Comments on Pg. 6 Att.B LaSalle's range is

-l' to O to +1' where 0 corresponds to normal water level. There is no postulated scenario where measurement below normal water level is indicative of reactor coolant pressure boundary leakage. Further, it is assumed that the required range is for SWR 6 Mk III Containments, and top of weir well refers to top of weir wall (which does not exist on LaSalle). It was further assumed that the NRC desires MarkII's to meet NUREG 0578, which demands measurement to 5 feet above normal water level. Cost and Scheduling Imoact to Uograde: Upgrade to 323-1974: $3,000 x 2 $6,000 = Change Piping to Measure +5': $5,000 x 2 $10,000 = Change Recorder Scale Range: $ 300. x 2 = $ 600. Replace Transmitters: $ 600. x 2 = $1,200. Add Unique Identification:

25. x 2 =

50. $17,850. Scheduling Impact: See Notes 1, 3, 4, and 5 1785 187

. Attachment C Rea. Guide 1.97 - Table 3 Variables Variable - Suppression Pool Water Temperature Range - 500F to 2500F Type - B Purpose - To ensure proper temperature for NPSH of ECCS. To verify the operation of the makeup system. LaSalle Design: Required Design Criteria BJ LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. f ailure/RG 1.53 Yes Yes 3. Env. qual./1.89 Yes Yes 4. Power Source Class IE Yes 5. Out of Service Int. 279-1971 Tech Spec 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B Yes 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Connents on Pg. 6 Att.B LaSalle Range is 00F to2500F Cost and Scheduling Impact to Upgrade:

Adding Unique Identification: $25. x 2 = $50. 3T07 Scheduling Impact: None 1786 188

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Drywell Drain Sumps Level (Identified and Unidentified Leakage) Range - Bottom to top Type -B, C Purpose - ANS-4.5, Section 6.3.3 LaSalle Design: Required Design Criteria LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 Yes No 2. Sing. failure /RG 1.53 Yes No 3. Env. qual./1.89 Yes No 4. Power Source Class 1E No 5. Out of Service Int. 279-1971 Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B None 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes Not Documented LaSalle's sump continuous analog level measurement is based on the minimum requirement for leakage rate testing, specifically, it does not measure from bottom to top of sump but instead measures from bottom to top of an elevated weir section; in addition the equipment drain sump measures level only discreetly, and not a continuous analog signal.

Cost and Scheduling Impact to Uparade: Siesmic Qualification of Readout Equip.: $1,200 x 4 =$ 4,800 Upgrade to 323-1974: $1,000 x 4 =$ 4,000 Add Redundant Instrument Loops: $42,400 x 4 = $ 169,600 Add Class 1E Power: $10,000 x 4 =$ 40,000 Increase Capacity of Class 1E Instrument Power Supply: $20,000 =$ 20,000 Documentation For Periodic Testing and Out of Service Interval: $ 2,000 =$ 2,000 Add Unique Identification: $25. x 2 =$ 50. 5 240,450 Scheduling Impact: 1851M See Notes 1, 3, 4 and 5

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - High-Range Contginment Area Radiation Range - 1 to 10' R/hr (60 kev to 3 MeV photons wi h + 20% accuracy for photons of 0.1 to 3 MeV) (10 R7hr for photons is approximately equivalent to 10 rads /hr for betas and photon) Type - 8,C Purpose - To help identify if an accident has degraded beyond calculated values and to indicate its magnitude in order to determine action to protect the public. LaSalle Design: Required Design Criteria By LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 Yes Yes 2. Sing. failure /RG 1.53 Yes Yes 3. Env. qual./1.89 Yes No* 4. Power Source Class 1E Yes 5. Out of Service Int. 279-1971 Tech Spec 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 Yes 8. Display Type Continuous Yes 9. Display Method Recording Yes

10. Unique Ident.

Yes No

11. Per. Test./RG 1.118 Yes See Comments on Pg. 6 Att. B LaSalle's range is 1 to 108 R/HR.

It is not capable of detecting beta energy levels. Testing is currently in progress for IEEE-323-1974 requirements Cost and Scheduling Imoact to Upgrade: Add Unique Identification: $25. x 2 S50. = S50. Scheduling Impact: None \\186 190

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Main Feedwater Flow Range-O to 110% design flow Type - E Purpose - To indicate an adequate source of water to the reactor LaSalle Design: Required Design Criteria LaSalle Comoliance 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source See Comm. P.5 No 5. Out of Service Int. Not reg'd. Yes 6. Portable No Yes 7. Qua!. Assur. Level 10CFR50 App. B No 8. Display Type Ind. on demand Yes 9. Display Method Dial or digital Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes LaSalle meets the required measurement range for accident conditions.

Indication of adequate cooling water to the reactor is provided by ECCS Systems. These systems are designed in accordance with safety requirements. There is no justification for upgrading the indication of a non-safety related system flow to safety requirements. Cost and Scheduling Impact to Upgrade: Upgrade to 10CFR50-App. B: This cannot be done without replacing existing hardware at an estimated cost of $200,000. Add Power That is Non-Interruptable: $200,000. $400.000. Scheduling Impact: See Notes 1, 3, 4, 5 and 6 1786 191

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Condensate Storage Tank Level Range-Bottom to top Type - E Purpose - To indicate available water for core cooling LaSalle Design: Required Desian Criteria g LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not reg'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes LaSalle's range is from lowest suction point to overflow line instead of bottom to top of tank. For accident conditions the volume of water in the cycled condensate storage tank is ensured by Tech Spec requirements for the HPCS System.

In addition the remaining ECCS Systems take suction from the Suppression Pool which has a safety grade level indication. There is no justification for providing quality grade level measurement when acceptable alternatives are provided. Cost and Scheduling Imoact to Upgrade: Upgrade to 10CFR50-App. B: This cannot be done without replacing existing hardware at an estimated cost of $80,000. Add Power That is Non-Interruptable: $200,000. 5280,000. Scheduling Impact: See Notes 1, and 5 1785 192

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Steam Flow to RCIC Range- 0 to 110% design flowl Type - E Purpose - To verify that adequate steam is available for the system to perform its function LaSalle Design: Required Design Criteria By LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4 Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Not req'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFRS0 App. B No 8. Display Type On demand Yes 9. Display Mathod Indication Yes

10. Unique Ident.

No Yes

1. Per. Test./RG 1.118 No Yes LaSalle meets the required measurement range.

Steam flow to RCIC turbine is not an adequate measurement of establishment of ECCS flow. A more direct measurement of RCIC flow is more appropriate. (See next item). For example it would not detect the presence of a small RCIC line break. Cost and Schedulina Imoact to Upgrade: Add power that is non-interruptible: S200,000. 5200,000. 1785 193

, Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - RCIC Flow l kange-O to 110% design flow Type - D Purpose - For indication of system operation LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No-323-1971 Only 4. Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Tech Spec Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes See Comments on Pg. 6 Att. B LaSalle meets the required measurement range. LaSalle's liscensing position is such that the RCIC system is not considered to be one of the safety grade ECCS systems. Therefore there is no justification for upgrading a flow measurement system to quality grade requirements.

Cost and Schedulina Impact to Upgrade: Upgrade to 323-1974: $ 2,100. Add Power That is Non-Interruptable: $200,000. Documentation for out of Service Interval: $ 5,000. 5207,100. Scheduling Impact: See Notes 1, 2, 3, 4 and 5. 1786 194

Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - RHR System Flow Range-O to 110% design flow Type - D Purpose - For indication of system operation LaSalle Design: Required Design Criteria h LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No-323-1971 Only 4. Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Tech Spec Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes See Comments on Pg. 6 Att. 8 LaSalle meets the required measurement range.

Cost and Scheduling Impact to Upgrade: Upgrade to 323-1974: $ 2,100. Add Power That is Non-Interruptable: $200,000. $202,100. Scheduling Impact: See Notes 1, 3, 4 and 5. 1786 195

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - RHR Heat Exchanger Outlet Temperature Range-320F to 3500F Type - D Purpose - For indication of system operation LaSalle Design: Required Desian Criteria LaSalle Compliance 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No-323-1971-Only 4. Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Tech Spec No 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 No 8. Display Type On Demand es-Recorder v 9. Display Method Indication Yes-Recorder

10. Unique Ident.

No Yes

11. Per. Te"./RG 1.118 Yes See Comments on Pg. 6 Att.B LaSalle meets the required measurement range.

Cost and Schedulina Impact to Upgrade: Upgrade to 323-1974: $ 2,000. Documentation For Out of Service Interval: $5,000. Add Power That is Non-Interruptable: S200,000. 5207,100. Scheduling Impact: See Notes 1, 3 and 5. 1786 196'

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Service Cooling Water Temperature Range-320F to 2000F Type - D Purpose - For indication of system operation LaSalle Design: Required Desfon Criteria g LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No 4. Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Tech Spec No 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes See Coments on Pg. 6 Att. B LaSalle meets the required measurement range.

Cost and Scheduling Impact to Upg.adc: Upgrade to 323-1974: $ 2,100. Documentation for out of Service Interval: $ 5,000. Add Power that is Nor.- Interruptable: S200,000. S207,100. Scheduling Impact: See Notes 1 and 5. 1786 197

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Service Cooling Water Flow l Range- 0 to 110% design flow Type - 0 Purpose - For indication of system operation LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No 4. Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Tech Spec Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes See Cormients on Pg. 6 Att.B LaSalle's range does not meet the 0 to 110% design flow requirement.

LaSa11e's range is presently 0 to 108% design flow. Cost and Scheduling Impact to Upgrade: Upgrade to 323-1974: $ 2,100. Documentation for out of Service Interval: $ 5,000. Change the Range of Trans-mitter and Indicator: (Included in Above) Add Power That is Non-Interruptable: $200,000. $207,000. Scheduling Impact: See Notes 1 and 5 1786 198

-27A-Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Flow in Ultimate Heat Sink Logp Range-O to 110% design flow Type - D Purpose - For indication of system operation LaSalle Design: Required Design Criteria g LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. f ailure/RG 1.53 No Yes 3. Env. qual./1.89 Yes No 4. Power Source EMR Buss. No-Class lE Only 5. Out of Service Int. T.S. Regmts Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 No 8. Display Type On demand Yes 9. Display Method Indication Yes

10. Unique Id9nt.

No Yes

11. Per. Test./RG 1.118 Yes See comments on P.6 Att.B LaSalle's design for service cooling water is an open-loop, once-through Suction is taken from the same pond that functions as tha cooling system.

ultimate heat sink. Therefore this measurement is the same as service cooling water flow, and it is assumed that a second measurement is not required. Cost ana Scheduling Impact to Upgrade See Service Water Cooling Flow Scheduling Impact: See Service Water Cooling Flow 1785 199

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Temperature in Ultimate Heat Sink loop R ange-300F to 1500F Type - D Purpose - For indication of system operation LaSalle Design: Required Design Criteria g LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No 4. Power Source EMR Bus. No-Class 1E Only 5. Out of Service Int. Tech Spec No 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 No 8. Display Type On Demand Yes 9. D:: play *iethod Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes See Comments on Pg. 5 LaSalle's design for service cooling w4ter is an open-loop, once through cooling system.

Suction is taken from the same pond that functions as the Ultimate Heat Sink. Therefore this measurcment is the same as service cooling water temperature, and it is assumed that a second measurement is not required. Cost and Scheduling Impact to Vograde: See Service Water Cooling Temperature Scheduling Impact See Service Water Cooling Temperature 1785 200

.. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Ultimate Heat Sink Level Range-Plant specific Type - 0 Purpose - To ensure adequate source of cooling water. LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No 4. Power Source EMR. Bus No 5. Out of Service Int. Tech Spec Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 8 No 8. Display Type On Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes No The LaSalle Cooling Lake is so designed that it is impossible to empty the ultimate heat sink cooling pond even with a major breach of the cooling lake dike. Upgrade to safety quality levels is not warranted.

Cost and Scheduling Impact to Upgrade: Upgrade to 323-1974: $ 2,000. Add Power that is Non-Interruptable: $200,000. Increase Capacity of Class 1E Instrument Power Supply: (Included in Above) Documentation for Periodic Testing and Out of Service Interval: $ 5,000. Upgrade to 10CFR50-App.B (Included in Above) $207,000. Scheduling Impact: See Notes 1 and 5 1786 201

. Attachment C Req. Guide 1.97 - Table 3 Variables Variable - SLCS Storage Tank Level Range-Bottom to top Type - E Purpose - To provide indication of inventory for boron injection for shutdown. LaSalle Design: Reouired Design Criteria Q LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Tech. Spec Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50-App.B No 8. Display Type On-Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes LaSalle's range is from lowest suction point to overflow line instead of bottom to top of tank.

Minimum required level for baron injection is ensured via Tech. Spec. requirements for surveillance of the tank. The storage tank is so designed that a seismic event would not impair it s capability of maintaining the minimum required boron solution. Cost and Scheduling Impact to Upgrade: Documentation For Out of Service Interval: $ 5,000. Add Power that is Non-Interruptable: $200,000. $205,000. Scheduling Impact: See Notes 1, 3, 4, 5 and 6 1786 202

. Attachment C Reg. Guide 1.97 - T3ble 3 Variables Variable - Sump Level in Spaces of Equipment Required for Safety R ange-To corresponding level of safety equipment failure Type - D Purpose - To monitor potential for failure of equipment in closed spaces due to flooding LaSalle Design: Required Design Criteria h LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No No 4. Power Source EMR. Bus No 5. Out of Service Int. Tech Spec. Not Documented 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B Not Documented 8. Display Type On demand No 9. Display Method Indication No

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes No LaSalle's reactor building is so designed that flooding of any one ECCS equipment cubicle will have no effect on any of the other ECCS cubicles.

Measurement of potential flood level is not an indication of loss of ECCS protection function, because of the redundancy built into the ECCS room layout. Cost and Scheduling Impact to Upgrade: Add Power that is Non-Interruptable: $200,000. Documentation for Periodic Testing and Out of Service Interval $ 10,000. Add Analog Instrumentation loops Which Meet 323-1974 and 10CFR50 App. 8 2 Loops x 6 Sumps x $42,400= $508,300. 5718,800. Scheduling Impact: See Notes 1, 5 and 6 1786 203

32-Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - High Radioactivity Liquid Tank Level R ange-Top to bottom Type - E Purpose - Available volume to store primary coolant. LaSalle Design: Rec uired Design Criteria h LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not req'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand No 9. Display Method Indication No

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No yes LaSalle's design provides for a non-quality grade installation which indicates in a separate radwaste control room - not the main control room.

This information can be received by the control room operator by calling the operator in the radwaste control room. In the event of a major LOCA it is intended that the radioactive primary coolant be stored and maintained in the isolated primary containment. Cost and Scheduling Impact to Upgrade: Add Power that is Non-Interruptable: $200,000. Add Instrument Loop to Monitor Radwaste Tank Level Which Meets 10CFR50-App. B: $ 42,400. 5242,400. Scheduling Impact: See Notes 1 and 5. 1785 204

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Charcoal Delay Gas System Gas Flow or Radioactivity Level R ange-As required Type - E Purpose - To monitor performance of system. LaSalle Design: Required Design Criteria g LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4 Power Source See Com. P.5 No 5. Out of Service Int. Not reg'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type Ind. on demand Yes 9. Display Method Dial or digital Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes It was assumed that this variable description refers to normal off-gas processing system.

On receipt of reactor trip signals this system is isolated and in this condition flow or radioactivity monitoring for post accident conditions is not warranted. Cost and Scheduling Imoact to Upgrade: Add Power That is Non-Interruptable: $200,000. Design New Flow Monitoring System That Will Meet 10CFR50 App. 8: (A) Engineering $ 40,000. (B) Hardware Purchasing $ 42,400. & Installation: $282,400 Scheduling Impact: See Notes 1, 3 and 5. 1785 305

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Emergency Ventilation Damper Position R ange-Open-closed status Type - D Purpose - To ensure proper ventilation under accident conditions. LaSalle Design: Required J LaSalle Comoliance B Design Criteria Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No-323-1971 Only 4. Power Source EMR. Bus No-Class 1E Only 5. Out of Service Int. Tech Spec Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. 3 Yes 8. Display Type On Demand Yes 9. Display Method Indication Yes-Light Bulb Only

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes See Comments on Pg. 6 Att.B It was assumed that this variable refers to LaSalle's reactor building ventilation system isolation dampers and main control room ventilation system isolation dampers.

Cost and Scheduling Imoact to Upgrade: Upgrade to 323-1974: $ 4,300. Add Power That is Non-Interruptible: $200,000. $204,300. Scheduling Impact: See Notes 1 and 5 1785 206-

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Temperature of Space in Vicinity of Equipment Required for Safety R ange-300F to 1300F Type - B Purpose - To monitor environmental conditions of equipment in closed spaces. LaSalle Design: Required Design Criteria By LaSalle Comoliance Guide System 1 System 2 1. Seis. Qual./RG.1.100 Yes No Yes 2. Sing. failure /RG 1.53 Yes No No 3. Env. qual./1.89 Yes No No-323-1971 Only 4. Power Source Class 1E Yes Yes 5. Out of Service Int. 279-1971 Yes Not Documented 6. Portable No Yes No 7. Qual. Assur. Level 10CFR50 App. B No Yes 8. Display Type Continuous No Yes 9. Display Method Recording No No

10. Unique Ident.

Yes No No

11. Per. Test./RG 1.118 Yes See Com-Not Documented ments Pg.6 Att. B LaSalle's design consists of two systems:

1) Temperature monitoring in ECCS equipment cubicles for the purpose of leak detection and 2) Temperature monitoring in safety related equipment rooms to monitor the performance of the safety related HVAC System which cools those rooms. System 1: LaSalle's 0

range is 500F to 350 F, and system has on demand indication only system 0 2: LaSa11e's range is 500F and 250 F, and is indicated only,not recorded. Cost and Scheduling Impact to Uograde: System 1 and System 2: Provide redundante instrument loops $35,200. which meet 323-1974 requirements: Provide recorders and seismic $2150. x 6 = $12,900. qualification Add Unique Identification: $ 25. x 6 = $ 150. System 1 Add Seismic Qualification: $ 1,600. Upgrade to 10CFR50-App.B $16,200. System 2: Document Periodic Testing: S 5,000. Scheduling Impact: See Notes 1 and 5

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Status of Class 1E Power Supplies and Systems R ange-Voltages and Currents Type - D Purpose - To ensure an adequate source of electric power for safety systems. LaSalle Design: Recuired J, LaSalle Compliance Design Criteria E Gu1de 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 Yes No 4. Power Source EMR. Bus No-Class 1E Only S. Out of Service Int. Tech Spec Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On Demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 Yes Not Documented LaSalle's design provides for one channel of measurement per each Class 1E power division.

Cost and Scheduling Imoact to Upgrade: Add Power that is Non-Inrerruptable: = $200,000. Upgrade to 10CFR50-App.B = $ 64,800. Document Periodic Testing Requirements: = S 10,000. 5274,800 Scheduling Impact: See Notes 1, 3 and 5. 1785 208

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Status of Non-Class 1E Power Supplies and Systems R ange-Voltages and Currents Type - E Purpose - To indicate an adequate source of electric power. LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not reg'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes It is not practical to monitor non-Class 1E power system busses with instrumentation powered from emergency busses.

In addition if the emergency bus is required to meet Class 1E criteria, this measurement would be in violation of Reg. Guide 1.75. Cost and Scheduling Impact to Upgrade: Add Power that is non-Inter,ruptable: $200,000. Upgrade to 10CFR5-App. B: S 90,000 5290,000. Scheduling Impact: See Notes 1 and 5 1785 209

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Radiation Egposure Rates Range to 104 R/hr for photons Type - E Purpose - For measurement of high-range radiation exposure rates at various locations. LaSalle Design: Required Design Criteria By LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not reg'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand Yes 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes LaSalle's area radiation design and selected locations for monitoring was geared for the detection of abnormal transients which could possibly be expected to occur during normal operating conditions for the protection of monitorsthereforefallinthecategoryof10gt. ThgrangeofLaSalle's those plant personal who must maintain equipme to 10 Mr/ hour.

If LaSalle's area radiation monitors were required to function during post accident conditions, a major design effort would be required. Cost and Scheduling Impact to Upgrade: Add Power that is non-Interruptable: $200,000. Engineering Cost to Design New Monitors: $ 10,000. Purchase and Installation of 20 New Channels (High Range): $416,000. 5626,000. Scheduling Impact: See Notes 1, 5 and 6. 1785 210

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Effluent Radioactivity-Noble Gases R ange- (Nonnal plus accident range for noble gas) Type - E Purpose - ANS-4.5, Section 6.2.6. To provide operator with information regarding release of radioactive noble gas on a continuous basis. Variable - Containment Exhaust Vent and Other Release Points (including Standby Gas Treatment System fuel handling building, auxiliary Vent bu iding,2and turbine building) Range 107 to 105 uCi/cc 10 to 10 uCi/cc Xe-133 Xe-133 calibration calibration (permanently installed monitors)

Purpose:

Provisions should be made to monitor all potential pathways for release of gaseous radioactive materials to the environs in conformance with General Design Criterion 54. Note: Monitoring of individual effluent streams only is required where such streams are released directly to the environment. If two or more streams are combined prior to release from a common discharge point, monitoring of the combined stream is considered to meet the intent of this guide provided such monitoring has a LaSalle Design: Required Design Criteria g LaSalle Compliance Guide Main Stack Standby Gas Effluent Treatment Effluent 1. Seis. Qual./RG.1.100 No Yes No 2. Sing. failure /RG 1.53 No Yes Yes 3. Env. qual./1.89 No Yes Yes 4. Power Source EMR. Bus No No-Class 1E Only 5. Out of Service Int. Not reg'd. Yes No 6. Portable No Yes Yes 7 Qual. Assur. Level 10CFR50 App. B No Yes 8. Display Type On demand Yes Yes 9. Display Method Indication Yes Yes

10. Unique Ident.

No Yes Yes

11. Per. Test./RG 1.118 No Yes Yes LaSalle's standby gas treatment is 10 g is 4 x 10-10 to 4 x 10-3 uC/cc.

LaSa11e's main stack effluent rang to 102 uCI/cc, whereas the required range extends down to 10-7 and up to 10 uC/cc. 3 For both of these ranges a major design effort is required. LaSalle design provides for on-line monitoring of every release point. There are not release points other than main stack effluent and there are no release points other than main stack effluent and standby gas treatment stack effluent which can contain noble gasses. Cost and Schedulino Impact to Upgrade: 7gg 2}} Estimated Hardware & Engineering costs to provide $350,000 wide range monitoring for both Stack Effluents: Add Power that is Non-Interruptable: S200,000. 5550,000.

Attachmen+ C -39A-Scheduling Impact: See Notes 1, 5 and 6. 1785 212

. Attachment C Req. Guide 1.97 - Table 3 Variables EffluentRagioactigity-High-RangeRadiohalogensandParticulates Variable - 10- to 10 uCi/cc (permanently installed monitors) Range-Type - E Purpose - To provide the operator with information regarding release of radioactive halogens and particulates. Continuous collection of representative samples followed by monitoring (measurements) of samples for radiohalogens and for particulates. LaSalle Design: Recuired Design Criteria h LaSalle Compliance Guide Main Stack Standby Gas Effluent Treatment Effl. 1. Seis. Qual./RG.1.100 No Yes Yes 2. Sing. failure /RG 1.53 No Yes Yes 3. Env. qual./1.89 No Yes Yes 4. Power Source EMR. Bus No No-Class 1E Only 5. Out of Service Int. Not reg'd. Yes Yes 6. Portable No Yes Yes 7. Qual. Assur. Level 10CFR50 App. B No Yes 8. Display Type On demand No Yes 9. Display Method Indication No Yes

10. Unique Ident.

No Yes Yes

11. Per. Test./RG 1.118 No Yes Yes LaSalle's main stack is not equipped with on line radiohalogen and particulate monitoring - grab sample analysis only.

LaSalle's standby gas treatment {ack mongtoring measures radiohalogens rangeis10gtesoverarangeof10-and particul to 10- uC/cc whereas the required 2 to 10 uC/cc. Cost and Schedulina Impact to Uporade: Add Power that is Non-Interruptable: $200,000. Main Stack Effluent: Add Particulate and Iodine Monitoring Caoability Which Meets 10CFR50-App.B Regmts.: Add Control Room Indication for Particulate and Iodine Monitoring: Engineering and Installation for Wide Range $350,000. Monitors (Similar to Previous Item). $550,000. Scheduling Impact: See Notes 1, 5 and 6. 1785 213

. Attachment C Req. Guide 1.97 - Table 3 Variables EnvironsRagioactigity-ExposureRate Variable - 10- to 10' R/hr (60 kev to 3 MeV) permanently Range-installed monitors) E Type - Purpose - For estimating release rates of radioactive materials released during an accident from unidentified release paths (not covered by effluent monitors) - continuous readout capability. Approximately 16 to 20 locations - site dependent.) LaSalle Design: Reauired Design Criteria By LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not reg'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand No 9. Display Method Indication No

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes LaSalle does not have on-line environs radioactivity monitnring which is outside the building but inside the plant boundary. LaSalle is provided with a secondary containment and safety related ver.tilation systems which are designed to contain post accident radioactivity, process it thru the standby gas treatment system and discharge it thru the standby gas treatment stack which in turn is monitored continuously for noble gas particulate and iodine.

(plant environs monitoring is not required). Cost and Scheduling Impact to Uograde: Add Power that is Non-Interruptable: $ 200,000. Add a System that is Designed to Monitor Plant Environs Using 20 Channels of Ganma Monitors Which Meets 10CFR50-App.B Reqmts. S 850,000. S1,050,000. Scheduling Impact: See Notes 1, 5 and 6 1785 214

. Attachment C Reg. Guide 1.97 - Table 3 Variables Environs Ragioactivjty-Radiohalogens and Particulates Variable - 10- to 10- uCi/cc for both radiohalogens and R ange-particulates (permanently installed monitors) E Type - Purpose - For estimating release rates of radioactive materials released during an accident from unidentified release paths (not covered by effluent monitors). Continuous collection of representative samples followed by monitoring (measurements) of the samples. (Approximately 16 to 20 locations). LaSalle Design: Required Design Criteria h LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not reg'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand No 9. Display Method Indication No

10. Unique Ident.

No Yes

11. Per Test./RG 1.118 No Yes LaSalle does not have on-line radiohalogen and particulate monitoring which is outside the buildings and inside the site boundary.

Instead LaSalle is equipped with a non-safety grade air particulate monitoring system within the secondary containment which automatically samples the air in various cubicles for the purpose of leak detection. Because of the secondary containment design (see previous item) plant environ monitoring is not required. There are no unidentified release paths which are not covered by effluent monitoring systems. Cost and Scheduling Impact to Upgrade: Add Power that is Non-Interruptable: $ 200,000. Add a System that is Designed to Monitor Plant Environs using 20 Channels of Particulate and Iodine Monitors which Meet 10CFR50-App.B $1,600,000. Requirements: S1,200,000. Scheduling Impact: See Notes 1, 5 and 6. 1785 215

. Attachment C Req. Guide 1.97 - Table 3 Variables Plant and Environs Radioactigity (portable instrumengs) Variable - R ange-High Range 0.1 to 10 R/hr photons 0.1 to 10 rads /hr betas and low-energy photons 100-channel gama-ray spectrometer Type - E Purpose - During and following an accident, to monitor radiation and airborne radioactivity concentrations in many areas throughout the facility where is is impractical to install stationary monitors capable of covering both normal and accident levels. During and following an accident to rapidly scope the composition of gamma-emitting sources. LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not req'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand No 9. Display Method Indication No

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes As the present time there are no portable instruments capable of this In addition LaSalle does not currently have a program for portable range.

measurement. For accident conditions plant effluent monitors are relied There is no justification for taking this kind of measurement. upon. Cost and Schedulina Impact to Upgrade: Design, develop and purchase instrumentation: $350,000. Add Power that is Non-Interruptible: $200,000. 5550,000. Scheduling Impact: See Notes 1, 5 and 6. 1785 216

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Primary Coolant, Suppression Pool, Containment Air, Standby Gas Treatment System (upstream of each area served) R ange-As required based on Regulatory Guide 1.3 guidelines Type - E Purpose - ANS-4.5, Section 6.3.2. To provide means for safe and convenient sampling. These provisions should include: LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes H,0,& 2 Mon-Class 1E Only 4. Power Source EMR. Bus 2 2 All Others - None 5. Out of Service Int. Not req'd. Yes 6. Portable No Yes H,02 & 2 Only-None 7. Qual. Assur. Level 10CFR50 App.B 2 for PC or RXWTR, er Supp. Pool H,02 & 2 Only 8. Display Type On demand 2 H,02 & 2 Only 9. Display Method Indication 2

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes LaSalle is provided with capability to monitor each of the variables for normal operating conditions only. For accident conditions, LaSalle is equipped with primary containment oxygen and hydrogen sampling capability, and gross gamma monitoring. We see no useful ness of Ph monitoring. Further, provisions for manual sampling assuming Reg. Guide 1.3 source terms are present, requires a major design effort.

Cost and Scheduling Impact to Vograde: Design of Sampling Provisions for pH monitoring of Supp. Pool & Primary Coolant, and Air Sampling of Primary Containment: $ 950,000. Provisions of Taking Manual Grab Sample for Oxygen and Hydrogen Monitoring: $ 450,000. Grab Sampling Station for Primary Coolant: SSee Variable for Radiation Level In Coolant $1,400,000. Scheduling Impact: See Notes 1, 2, 3, 4, 5 and 6. 1786 217

. Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Post Accident Analysis Capability (On site) Range-1. Gama-ray spectrum 2. pH 3 Hydrogen 4. Oxygen Type - E Purpose - 1. Shielding to maintain radiation doses ALARA. 2. Sample containers with container sampling part-connector compatibility. 3. Capability of sampling under primary system pressure and negative pressure. 4. Handling and transport capability, and 5. Pre-arrangement for analysis and interpretation. LaSalle Design: Required Design Criteria JB LaSalle Comoliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. failure /RG 1.53 No Yes 3. Env. qual./1.89 No Yes & 2 Mon.-Class 1E H,02 4. Power Source EMR. Bus 2 OnlyJA11Others-None 5. Out of Service Int. Not req'd. Yes 6. Portable No Yes & 2 Only;None H,02 7. Qual. Assur. Level 10CFR50 App. B 2 For PC, RXWTR, or Supp. Pool H,02 & 2 Only 8. Display Type On demand 2 H,02 & 2 Only 9. Display Method Indication 2

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes LaSalle is provided with capability to monitor each of the variables for normal operating conditions only. For accident conditions, LaSalle is equipped with primary containment oxygen and hydrogen sampling capability, and gross gamma monitoring. We see no useful ness of pH monitoring.

Further, provisions for manual sampling assuming Reg. Guide 1.3 source terms are present, requires a major design effort.

Cost and Scheduling Impact to Upgrade: Design of Sampling Provisions for Ph Monitoring of Supp. Pool & Primary Coolant, and Air Sampling of Primary $ 950,000. Containment: Provisiens of Taking Manual Grab Sample for Oxygen and Hydrogen Monitoring: $ 450.000. Grab Sampling Station for Primary Coolant: $See Variable for Radiation Level In Coolant 51',400,00,2.}O }}$ Scheduling Impact: See Notes 1,2,3,4,5 and 6.

.- Attachment C Reg. Guide 1.97 - Table 3 Variables Variable - Wind Direction Range- 0 to 3600 (+ 50 accuracy with a deflection of 150 Starting speed 0.45 mps (1 mph)) Type - E Purpose - For determing effluent transport direction for emergency planning, dose assessment, and source estimates. V ari able-Vertical Temperature Difference Range- -90F to + 90F (+ 0.30F accuracy per 164-foot i ntervals). Type - E Purpose - For determining effluent diffusion rates for emergency planning, dose assessments, and source estimates. Variable-Wind Speed Range-0 to 30 mps (57 mph) 10.22 mps (0.5 mph) accuracy for wind speeds less than 11 mps (25 mpg), with a starting threshold of less than 0.45 mps (1 mph)) Type - E Purpose - For determining effluent travel speed and dilution for emergency planning, dose assessments, and source estimates. Variable - Precipitation Recording rain gage with range sufficient to ensure Range - accuracy of total accumulation within 107. of recorded value -0,01" resolution Type - E Purpose - For determining effluent transport and ground deposition for emergency planning. Variable - Temperature Range - -600F to 1200F (1 0.90F accuracy) Type-E Purpose - For determining nature of precipitation and ground deposition for emergency planning. LaSalle Design: Required Design Criteria By LaSalle Compliance Guide 1. Seis. Qual./RG.1.100 No Yes 2. Sing. f ailure/RG 1.53 No Yes 3. Env. qual./1.89 No Yes 4. Power Source EMR. Bus No 5. Out of Service Int. Not req'd. Yes 6. Portable No Yes 7. Qual. Assur. Level 10CFR50 App. B No 8. Display Type On demand Yes 7gg }}g 9. Display Method Indication Yes

10. Unique Ident.

No Yes

11. Per. Test./RG 1.118 No Yes

.~ (Con't) Attachment C Reg. Guide 1.97 - Table 3 Variables LaSalle is equipped with non-safety grade meteorological monitoring. It's primary purpose is for tracking abnormal transient dose dispersions. For accident conditions a formulated plan for evacuation is put into effect which is independent of the information provided by LaSalle's on-line meteorological monitoring system. This plan is carried out by agencies other than the utility and the control room operator takes no action based upon the receipt of this information for accident conditions. Upgrading to quality grade components is not justified. Cost and Scheduling Impact to Upgrade: Add a New Quality Grade Meteorological Monitoring System: $450,000. Add Power that is Non-Interruptable: $200,000. $650,000. Scheduling Impact: See Notes 1, 5 and 6. 1785 220

_ SCHEDULE IMPACT NOTES (for use with Attachment C Data Sheets) Note 1) Schedule of completion is dependent upon equipment delivery Note 2) Equipment must be physically installed without fuel in the reactor vessel Note 3) Equipment cannot be installed while reactor is operating in any mode Note 4) Equipment cannot be installed while reactor is in hot standby Note 5) Equipment cannot be installed and preoperationally tested before scheduled fuel loading (June 1980) Note 6) Equipment cannot be installed and preoperationally tested before December 31, 1981 (785221

Cost Impact Attachment B contains general comments on the Regulatory Guide 1.97 Rev. 2 Design Criteria, as they pertain to BWR 5 Mark II containments in general. Attachment C contains a listing of each variable required in Table 3 of the Reg. Guide revision, and a description of what it would take for laSalle County Station to be modified or upgraded to obtain full compliance with each requirement. A price tag was estimated for each variable, using reasonable assumptions and interpretations of unclear regulatory requirements. It should be noted that due to the enormity of the task of performing a cost impact statement of such a radical change to so many here-to-fore non-safety variables, given such a short time allowance in which to work, that the price estimates are only "best engineering judgements," and that further time for reasoning can produce a refinement of results - either in the form of lower estimates for performing a combination of engineering and purchasing efforts on many variables simultaneously, or higher estimates which allow for some of the " hidden" costs not obvious on a first pass judgement. As an example of some of the " hidden" costs, consider the example of Reactor Coolant System pressure in Attachment C. Here, the staff required a range of 0-2000 psig for BWR's. LaSalle has a system currently capable of measuring 1500 psig. On the surface it would appear that a simple range change for a transmitter is all that is required for LaSalle to upgrade. But this is not the case. The piping system to which LaSalle is designed is only a 1500 psig system, ANSI standards require that if a piping system is dasigned for pressure vessel service, there should be documentation to the fact that this system be hydrostatically tested to 1.25 times the peak expected perf ormance.Th: wer.d require LaSalle to re-hydro its instrument lines and document the change from 1563 psig hydro to 2500 psig. When estimating individual variable upgrading costs, the following was taken into account: purchasing & procurement manhours, engineering and design manhours, installatio1 manhours, installation hardware costs, computer time for design of safety-related piping and conduit systems, R & D time for designing those systems which are not currently available on the market, hardware costs of non-engineered items, cost of qualification documentation (allocated over many units), maintenance costs of new channels of instrumentation over a 40 year plant life (present valved at 7%), cost of processing and storing QA/QC documentation, and cost of those hidden tasks to be performed concurrent with the actual installation of the new equipment, if it was immediately obvious. What this study did not take into account was the cost of reactor down time. The last page of Attachment C indicates an explanation of the notes used for each variable to describe schedule impact. Some of the variables can be immediately implemented because LaSalle already is committed to installing components qualified to the level desired by the NRC, (as we too, agreed that it was a necessity). However, there are many other variables where the additional safety Q 4, itwouldbediffig/44 gained by upgrading is of questionable value, and Jgg at best, for LaSalle to fully comply with the requirements.

. For example, note 2 states that equipment cannot be installed with fuel in place in the reactor vessel. The cost impact for core exit thermocouples, for example, can be calculated as follows: LaSalle is scheduled for fuel load in June, 1980. The NSSS vendor has estimated that it will take approximately 32 months to design and deliver a system for installation. Portions of the system (display devices, calculation hardware, etc.) can be installed with the reactor operating.

However, when the time comes for actual installation of the sensors, the reactor must be brought to cold shutdown, fuel removed, core support structures pulled out, and installation may begin.

This may possibly be timed to coincide with a scheduled fuel outage. The installation time is estimated to take 4 to 6 weeks, on a 24 hour per day per basis. During this time no fuel can be re-shuffled. The replacement power costs for an 1100MWe nuclear station are extimated at $1.03 million/ day.. It is easy to see how this one item alone can cost five to six times as much as the total estimated hardware, engineering, and installation costs. In order to come up with a figure for total hardware, engineering and installation costs, the following is provided: First, sum up the costs of the individual variables: S15,566,000.00 per unH-Next, Subtract the cost of the addition of uninterruptable power supply for 23 of the 24 items, because it can be assumed that the power supply is sized to handle many instrument loads and the same power supply can be used for all loops requiring non-interruptable power: -(23 x $200,000) = -$4,600,000.00 Then you get a remainder of $10,966,000.00 for hardware, purchasing, engineering, design and installation. This can be safely rounded to $11 million. We feel that because LaSalle already meets many of the NRC desired qualifications, this figure may appear low when compared with other BWR's Mark II's. This is because LaSalle has already made licensing commitments to upgrade certain systems during the normal OL review process. It can be anticipated, however, that estimates for as much as $15 million may come in for other plants in the near-term OL category. 1785 223}}