ML20058C858
| ML20058C858 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/30/1990 |
| From: | Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML17262A227 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-9195, TAC-51093, NUDOCS 9011050161 | |
| Download: ML20058C858 (31) | |
Text
. -
%l. i f.f
~
\\
joy..c 4 ;-Q
[
f
' EGG-NTA-9195
/.
September 1990-A t,
s y
?
o TECHNICAL EVALUATION RdPORT
+
c0NFORMANCE TO REGULATORY GUIDE 1.97: GINNA l
" National f F" Engineering l.aboratory y'
- l Managed--
. Alan C. Udy vby the U.S.
- .bepartment
,;u ofEnergy.
w.
.. i 1
\\'
au
}
E h
'3i
- 1 j
1 1
l t
'a 4" g.fEBsG,e Prepared for the j
U.S. NUCLEAR REGULATORY COMMISSION a.
Y Work performed under DOE Contract No. OE AC07 MID01570 t
t i
-M ;g
&Y
- t EGG-NTA-9195 i.
- n i
P 4
TECHNICAL: EVALUATION REPORT t
~
~CONFORMANCE TO REGULATORY GUIDE 1.97:
GINNA s.
- i l-Docket No. 50-244 t
a Alan C. Udy J
t
,tv <
+
i svm
-i
}":
(
Published September 1990 y
o
.y LIdaho' National EngineeringLLaboratory
. EG&G Idaho, Inc.;
t-1 i
Prepared for the U.S.. Nuclear. Regulatory Commission
. Washington, D.C.
20555-Under DOE Contract No.'DE-AC07-761D01570 FIN No. A6483 TAC No. 51093 s
l..
p
SUMMARY
This EG&G Idaho,- Inc., report documents the review of the Regulatory Guide l.97, Revision 3, submittals for the R. E. Ginna Nuclear Power Plant.
This report, as part of this review, identifies areas of nonconformai, e to the regulatory guide.
Exceptions to Regulatory Guide 1.97 are evaluated and those-areas where sufficient basis for acceptability is not provided are identified.
i FIN No. A6403 B&R 20-19 10-11-3 Docket No. 50 244 TAC No. 51093 11 i
Q :-
8 p
e L
PREFACE This report is supplied as part of the "Pr- ; ram for Evaluating Licensee / Applicant Conformance to RG 1.97 " being conducted for the U.S.
Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Systems Technology, by EG&G Idaho, Inc., Regulatory and Technical Assistance Unit.
.i.
i E-t iii 1
i r
k CONTENTS i
SUMMARY
11 PREFACE...............................................................
iii 1.
INTRODUCTION.....................................................
I 2.
REVIEW REQUIREMENTS..............................................
2 3.
EVALVATION.......................................................
4 3.1 Adherence to Regulatory Guide 1.97.........................
4 i
3.2 Ty p e A V a r i a b l e s...........................................
4 3.3 Exceptions to Regul atory Guide 1.97........................
6 4.
CONCLUSIONS......................................................
24 5.
REFERENCES.......................................................
25 f
t t
iv e
t i
j
CONFORMANCE TO REGULATORY GUIDE 1.97:
GINNA 1.
INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses, and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.91, Revision 2 (Reference 2), relating to the requirements for emergency response capability These requirements have been published as Supplement No. I to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Rochester Gas and Electric Corporation, the licensee for the R. E. Ginna Nuclear Power Plant, responded to Section 6.2 of the generic letter with letters dated January 31, 1984 (Reference 4) and February 28, 1985 (Reference 5).
The licensee submitted additional information and commitments on June 16, 1986 (Reference 6) and July 13, 1990 (Reference 7).
This report, based on the recommendations of Re"ulatory Guide 1.97, Revision 3 (Reference 8), compares the instrumentati:n proposed by the licensee's submittals with these recommendations.
i i
w I
.. $ i.
2.
REVIEW REQUIREMENTS Section 6.2 of NUREG 0737, Supplement No.1, sets forth the documentation to be submitted in a report to the NRC describing how the licensee complies with Regulatory Guide 1.97 as applied to emergency response facilities.
The documentation should provide the following information for each variable shown in the applicable table of Regulatory Guide 1.97, 1.
instrument range 1
2.
environmental qualification 3.
seismic qualification 4.
quality assurance 9
5.
redundance and sensor location 6.
power supply 0
7.
location of display 8.
schedule of installation or upgrade The submittals should identify any deviations taken from the regulatory guide recommendations and provide supporting justification or alternatives for the deviations identified.
After issuing the generic letter, the NRC held regional meetings, in Ftbruary and March 1983, to answer licensee and applicant questions and c'>ncerns regarding the NRC policy on this subject. At these meetings, it was' noted that the NRC review would address only exceptions taken to
]
It was also noted that when licensees or applicants j
explicitly state that instrument systems conform to the regulatory guide, no.
1; '
further staff review would be necessary. Therefore, this report addresses 1
\\
t I
e only those *xceptions to Regulatory Guide 1.97 that have been identified by 1
the licensee.
The following evaluation is an audit of the licensee's submittals based in the review policy described in the NRC regional meetings.
I
(
3 L
3.
EVALUATION The licensee responded to item 6.2 of NRC Generic Letter 82 33 on January 31, 1984, February 28, 1985. June 16, 1986, and July 13, 1990.
The responses describe the licensee's position on post-accident monitoring instrumentation. This evaluation compares the material provided by the licensee to the recommendations of Revision 3 of Regulatory Guide 1.97.
3.1 Adherence to Reaulatory Guide 1.97 The licensee's submittals for the R. E. Ginna Nuclear Power Plant compares the Ginna post-accident monitoring instrumentation with the instrumentation recommended by Regulatory Guide 1.97, Revision 3.
The licensee states their intent to comply with Revision 3 of the regulatory guide except where justification and evaluation shows that exacting implementation is not necessary.
Therefore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97.
Section 3.3 discusses exceptions and deviations from the regulatory guide.
3.2 Tvoe A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide the information required to permit the control room operator to take specific, manually-controlled safety actions.
The licensee classifies the following instrumentation as Type A.
1.
reactor coolant system (RCS) cold leg water temperature 2.
RCS hot leg water _ temperature 3.
RCS' pressure (zero to 3000 psig) 4
.p
.o 4.
RCS pressurizer pressure (1700 psig to 2500 psig) 5.
core exit temperature 6.
coolant level in reactor 7.
degrees of subcooling 8.
containment sump water level -- wide-range 9.
containment pressure 10, containment hydrogen concentration ll, residual heat removal system flow (low pressure injection) 12.
safety (high pressure) injection flow 13.
refueling water storage tank level 14.
primary system safety relief valve position p
15.
pressurizer level
- 16.. steam generator level
-wide-range (when installed)
--narrow-range (deleted as Type A when wide-range is installed) 17.
steam generator pressure
- 18. main steam flow 19.
auxiliary feedwater flow l
20.
standby auxiliary feedwater flow 5
l
n; 21.
condensate storage tank level 22.
containment area radiation -- high-range These variables, with exceptions as noted in Section 3.3, either meet or will be upgraded to meet the Category I recommendations, consistent with the requirements for Type A variables.
3.3 Excentions to Reaulatory Guide 1.97 The licensee identified deviations and exceptions to Regulatory Guide 1.97.
The following paragraphs discuss these deviations and exceptions.
3.3.1 Neutron Flux l
Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable.
Category I criteria include environmental qualification. The licensee's instrumentation is the original plant equipment and is not environmentally qualified.
The'11censee reviewed their Updated Final Safety Analysis Report (UFSAR), Chapter 15, " Accident Analyses", and their Emergency Operating Procedures (EOPs). The review determined that no automatic or manual operator actions for accident mitigation are based on this instrumentation.
These E0Ps and functional restoration procedures cover events that go beyond design basis events.
Therefore -this instrumentation was not designated Type A-instrumentation.
The licensee proposes to use alternate instrumentation, such as the core exit thermocouples, the reactor vessel. level indicating system, and soluble boron concentration analysis to assure the core is shut down and-remains subcritical.
6 1
8 p
.a Regulatory Guide 1.97 recommends Category I neutron flux monitoring instrumentation to monitor reactivity control during post-accident situations. The regulatory guide specifies neutron flux as the key variable for determining the accomplishment of reactivity control.
It is a key i
variable because it is a direct measurement, not an indirect or lagging indication.
The regulatory guide specifically states that Category 1 instrumentation should meet the environmental qualification requirements of l
This has been superceded by 10 CFR 50.49, the environmental qualification rule.
10 CFR 50.49 explicitly references Regulatory Guide 1.97, requiring the environmental qualification of all Category 1 instrumentation.
Initiating and post reactor shutdown events could involve environmental conditions that are more extreme than the conditiens considered for the existing neutron flux instrumentation.
Neutron flux instrumentation supplied for monitoring post accident conditions must, according to the regulatory guide, be capable of monitoring down to 10-6 percent of full reactor power.
This instrumentation must satisfactorily operate in these extreme environmental conditions.
The instrumentation should be fully operable for an extended period, i.e., in the order of sixty days, following an accident.
The licensee bases the use of neutron flux and alternate
)
instrumentation on anticipated conditions resulting from standard design basis analysis conditions. These events are normally considered reasonably
]
comprehensive.
However, the instrumentation recommendations of Regulatory Guide 1.97 intends ~ to cover a wide range.of possibilities, including j
. conditions not necessarily anticipated following standard event ~ analysis defined' event paths. The intent of the 10-6 percent lower limit of the recommended range was to provide, with maximum forewarning' time, operator j
information (via evaluations of deviations from normal post shutdown flux 1evels) and warning of possible post-event ~ approaches or a return to a critical state.
This micht be under circuinstances that would involve reactor states and evolving events and conditions not anticipated from analyses following normally considered event scenarios.
It would thus be virtually-impossible'to either predict or demonstrate the implausibility of such event paths and resulting conditions.
7
.. s We conclude that the licensee's position does not address the conceptual basis that set the recommendations of Regulatory Guide 1.97.
The expected flux levels exist for some extended period after rapid shutdown from power operation.
These expected flux levels set the required power levei that this instrumentation must measure.
For the reactivity status to be verifiable, the source, intermediate, and power range detectors must be operational following this rapid shutdown from power operation.
The normal, non power flux levels serve as a base for observable deviations of reactivity state in the anomalous and undefined events indicated above.
10 CFR 50.49 requires environmental qualification for Category 1 and Category 2 post-accident monitoring equipment.
Therefore, based on the above, we conclude that the Category 1 designation is appropriate.
We also conclude that the licensee should environmentally qualify the r.e +ron flux monitoring instrumentation to comply with 10 CFR 50.49.
The licensee should evaluate available neutron flux instrumentation that meets the Category I criteria.
Then the licensee should install neutron flux monitoring instrumentation that fully complies with the Category 1 and range criteria of Regulatory Guide 1.97.
3.3.2 Reactor Coolant System (RCS) Soluble Boron Coicentration Regulatory Guide 1.97_ recommends instrumentation for this variable with a range of zero to 6,000 parts per million. The licensee's instrumentation has a span of 50 1 50 parts per million to 6,000 300 parts per million.
The licensee states-that the accuracy is maintained at 20 parts per million.
If outside this accuracy, the analyzer is recalibrated.
The licensee deviates from Regulatory Guide 1.97 with respect to the range of this post-accident sampling capability.
This deviation goes beyond the scope of this review.
The NRC addressed this capability as part of their review of NUREG-0737, Item 11 B.3, and found it acceptable.
P 8
.'. t..
3.3.3 Dearees of Subcoolino Regulatory Guide 1.97 recommends instrumentation for this variable.
It recommends a range from 200'F subcooled to 35'F superheat.
The licensee has instrumentation for the variable, however, the range is zero to 100'F subcooled. The licensee normally calculates the amount of subcooling, using this instrumentation as a back-up to the calculated value.
The licensee deviates from Regulatory Guide 1.97 with re vect to the range of this variable.
This deviation goes beyond the scope of this review. The NRC addressed this capability as part of their review of NUREG 0737, item II.F.2, and found it acceptable.
3.3.4 Containment Isolation Valve position Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable.. Category I criteria include the environmental qualification of those iristruments and circuit components that can be exposed to a harsh environment._ The licensee reviewed their Updated Final Safety Analysis Report (UFSAR),. Subsection 6.2, " Containment Systems," to identify containment isolation valves. The licensee states that containment isolation will occur even with a single failure of position indication instrumentation.
The licensee notes that the valve stem position switches mounted on air-operated valves are used for indication only.
They are not environmentally qualifibd. These position switches are not part of control logic circuits.
Therefore, failure of these switches does not affect the isolation capability. of air operated valves. All motor operated valves are included in the licensee's valve refurbishment and upgrade efforts. The
' internal torque and position sensing elements and wiring either h a been or
- will be replaced as. part of this upgrade program.
Environmentally qualified l
conductors are part of the upgrade. We infer that the position switches for the motor-operated valves will also be environment,11y qualified.
l 9
1
.3 l.
The licensee states that the systematic evaluation program (SEP), topic VI-4, shows that the containment will be properly isolated even with a single failure.
The licensee states that failure of the position indication will not cause the loss of any safety function, or incorrect or unsafe operator actions.
The operator is directed to close the valve if it indicates open.
It can be closed electrically or manually (if not in a harsh environment). Of greater concern is an open valve that indicates j
closed. The operator will not attempt to close a valve that indicates closed. SRP Topic IV-4, " Electrical, Instrumentation, and Control Aspects of the Override of Containment Purge Valve Isolation," does not address the position indication of the containment isolation valves.
That topic was restricted to.certain valves, and the override of certain automatic isolation functions.
From the information provided, we find that the license deviates from a strict interpretation of the Category I recommendation for redundant instrumentation. There is one open/close indication per valve.
Since redundant isolation valves are provided, we find that redundant indication per valve -is not intended by the regulatory guide. There is redundant indication of the isolation function.
Therefore, we find that the redundancy.provided.for this variable is acceptable.
The instrumentation recommended.by Regulatory Guide 1.97 is to provide the plant operators with a complete picture of what it taking place in the plant post-accident.
If the indication for containment isolation valve position erratically indicates closed when a valve is opin, the operator is not assured that the containment atmosphere is isolated. We conclude that the licensee should provide environmentally qualified position-indic.ation for any containment isolation valves that can be exposed to a harsh post-accident environment.- This conclusion agrees with the requirements of
'10 CFR_50.49 (b)(3).
10
.I i
3.3.5 Radiation level in Circulatina Primary Coolant The licensee states that radiation level measurements to indicate fuel cladding failure are provided by the post-accident sampling system.
This capability was reviewed and approved by the NRC as part of their review of NUREG-0737, Item II.B.3.
Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable, i
3.3.6 Radiation Exoosure Rate Regulatory Guide 1.97 recommends Category 3 instrumentation for this variable.
It recommends a 10*l R/ hour to 10 R/ hour range.
Reference 7 4
identifies the licensee's microprocessor-based instrumentation.
Each 7 mR/ hour (10-4 R/ hour to 10 4
monitor has a range of 0.1 mR/ hour to 10 5
R/ hour). Monitor R-2 'is identified with a range of 0.01 R/ hour to 10 q
R/ hour. As the instrumentation identified in Reference 7 meets the j
recommendations of Regulatory Guide 1.97, it is acceptable.
3.3.7 Residual Heat Removal (RHR) Heat Exchance Outlet Temocrature Regulatory Guide 1.97 recommends Category 2' instrumentation for this variable.
It recommends a range of 40'F to 350'F.
Category 2 criteria include environmental qualificatiun. The licensee's instrumentation, as described in Reference 5, has a range of zero to 310'F.
The upper limit of the span originally identified is 40' below the recommended limit.
Reference 7 updates the information.
The range is 50*F to 400*F. : As an accident tends_ to increase fluid temperatures, and normal building temperatures are above 50*F, we find the provided range acceptable.
L 11 1
.i
t, In Reference 7, the licensee states that the resistance temperature detectors (RTD's) for this variable are not included in their environmental qualification program for 10 CFR 50.49.
The licensee states that the instruments do not perform a safety-related function.
Further, the licensee states that this instrumentation is not required by the emergency operating procedures.
Operator response is not based on this display.
We conclude that the licensee's position does not address the conceptual basis that set the recommendations of Regulatory Guide 1.97.
The purpose stated for this variable is to monitor system operation and analysis or event reconstruction.
This system, also used for low pressure injection, is used for an extended period of time after rapid shutdown from power operation.
For accurate RHR heat exchanger outlet temperature information, the RTD's, instrumentation, and interconnecting cables must be operational for both defined and anonymous undefined events.
10 CFR 50.49 requires environmental qualification for Category 1 and Category 2 post-accident monitoring equipment.
Therefore, based on the above, we conclude the Category 2 designation is appropriate.
We also conclude that the licensee should environmentally qualify the RTD's and cables involved to comply with 10 CFR 50.49.
3.3.8 Accu.nulator Tank Level and Pressere Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.
Category 2 criteria include environmental qualification.
The range recommended for the level instrumentation is 10 percent to 90 percent of the tank volume.
The range recommended for the pressure instrumentation is zero to 750 psig. The licensee's level-instrumentation has a range of s
i 7 inches from the normal fill level.
Thus, the level instrumentation deviates from the recommendations of the regulatory guide.
The licensee's pressureinstrumentationhaia-rangeofzeroto800psig.
This exceeds the recommended range for the pressure instrumentation.
Therefore, the range of the pressure' instrumentation is acceptable. Neither the level or pressure instrumentation is environmentally qualified as reported in Reference 7.
12
- - ~,,
-e
The licensee reports that the narrow level range is required to meet technical specification accuracy requirements that assure an adequate fill of borated water. The tank fill verification is part of normal surveillance requirements.
The accumulators are passive devices that discharge for reactor coolant system breaks with no operator intervention. The instrumentation is not required to protect the integrity of the reactor coolant system pressure boundary, to shut down the reactor, to maintain the reactor in a safe shutdown condition, or to prevent or mitigate the consequences of an accident that could result in potential exposures.
Using the pressure instrumentation as the key instrumentation in determining accumulator discharge, we find the level instrumentation supplied for the accumulator adequate and acceptable.
Regardless of procedural requirements for the operator, environmentally qualified pressure instrumentation should be available to the operators to.
monitor the status of the accumulators through the course of an acchent.
Properly qualified instrumentation would conclusively show that the accumulators, a safety-related system, have discharged. Therefore, the licensee should provide instrumentation for the accumulator pressure that meets the requirements and criteria of Regulatory Guide 1.97 and 10 CTR 50.49.
3.3.9 Boric Acid Charaina Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of zero to 110 percent of design flow.
The licensee's instrumentation, located in a mild environment, has a range of zero to 75 gallons per minute. The licensee states that 75 gallons ner minute is
.the maximum anticipated flow rate. The licensee states that the s
instrumentation will: remain on scale during accident conditions because the flow willlbe less than 75 gallons per minute. Therefore, we find this deviation-acceptable.
Because of the mild environment, no specific qualification requirements are needed.
l 13 l
.. > i-3.3.10 Low Pressure in.iection System Flow e
Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.
It recommends a range from zero to 100 percent of design flow.
The licensee did not identify instrumentation for this variable in References 4 and 5.
In References 6 and 7, licensee states that low pressure injection is a function of the RHR system.
The licensee is l
upgrading this instrumentation because it is Type A instrumentation.
As discussed in Reference 7, the licensee is scheduled to add a redundant instrument loop during the 1993 refueling outage. This upgrade will provide fully redundant Category 1 instrumentation monitoring the common containment penetration.
The common flow orifice has separate instrument taps for the two transmitters. We find this acceptable, 3.3.11 Pressurizer Heater Status l
I Regulatory Guide 1.97 recommends electric current instrumentation in
~ the control room for this variable. The licensee has two 400-kilowatt pressurizer heater groups.
Each group has control switch position and status = lights.
The buses that supply power to the pressurizer heater groups have kilowatt meters.
The control group of heaters has local current monitoring on the proportional controller cabinets in the auxiliary building. The backup heater group is not proportionally controlled.
It is strictly either on or off.
The kilowatts used by the heaters have a known, z
direct relation to the current used by the heaters.
Based on this relation between current and power, we find the instrumentation provided for this l
variable acceptable.
l 3.3.12 Ouench Tank Temeerature Regulatory Guide 1.97 recommands instrumentation for this variable with a range from 50'F to 750*F._ The licensee's instrumentation had a range of zero to 300'F.
Reference 7 documents a change in instrument
~
scaling. The new range will be 50'F to 400'F.
14
~-
-d The quench (pressurizer relief) tank has a rupture disk that operates at 100 psig. With this rupture disk, the tank contents are limited to i
saturated steam conditions at 100 psig.
This corresponds with 338'F.
The proposed range is adequate to monitor any expected conditions in the l
tank.
We find the licensee's commitment to res: ale this instrumentation acceptable.
3.3.13 Steam Generator level -- Wide Range Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. Thus, the licensee should provide independent and redundant environmentally and seismically qualified instrumentation channels for each of the two Ginna steam generators.
Reference 5 identified two level transmitters (LT-460 and LT-470) and a shared 2 channel recorder.
This configuration does not satisfy the single failure criteria for Category 1 instrumentation.
The licensee is replacing the feedwater control system with an Advanced Digital Feedwater Control System (ADFCS) during the 1991 refueling outage.
As part of-this design change, the wide range steam generator level instrumentation, with a range of zero to 520 inches, will be upgrad.ed.
After the modification, the wide-range instrumentation will fully comply with the Category 1 criteria. Two wide range channels will monitor each steam generator. The narrow range channels are not being changed; they will y
remain as Category 1 instrumentation. The regulatory guide does not require narrow-range instrumentation. Therefore, after the new wide-range channels are operational, the narrow-range instrumentation will no longer be considered part of Regulatory Guide 1.97. We find the licensee's-proposed modifications for this instrumentation acceptable.
3.3.14. Containment Sorav Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.
It recommends a range of zero to 110 percent of design flow. - The licensee does not monitor this flow. The licensee monitors the containment spray system operation by the pump control switch position and the pump status lights.
15
i; Containment spray starts on a signal from the Category I containment pressure instrumentation.
This instrumentation is also observed to determine if the containment spray is effective.
The operator is directed by the emergency operating procedures to use the containment pressure instrumentation to base containment spray system decisions.
These decisions include continued operation, restarting the pumps after suction switchover to the containment sump, or to stop the pumps.
Containment temperature also indicates the effectiveness of the containment spray.
s The licensee can also determine the containment spray flow in the
. recirculation (from the sump) mode by subtracting the total (high pressure) safety injection flow from the total residual heat removal (RHR) flow.
Once high pressure safety injection is terminated, the RHR flows only to the containment spray until RHR is established.
'The alternate instrumentation provided by the licensee is adequate to monitor this variable.. Therefore, this exception is acceptable.
3.3.15 Containment Sumo Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 50'F to 250*F.
References 4 and 5 did not identify instrumentation for this variable.
However, References 6 and 7 describe added instrumentation that satisfy the criteria of Regulatory Guide 1.97 for the containment sump water temperature.
It has a range from zero to 360*F. We find the describet instrumentation acceptable.
3.3.'16 Makeun Flow In Regulatory Guide 1.97 recommends instrumentation for this variable with a range of zero to 110 percent of design flow. The liransee's rotameter instrumentation has a range of 5 to 75 gallons per minute.
The licensee states that 75 gallons per minute is the maximum anticipated flowrate.
The
-licensee states that the.instrun.entation will remain on' scale during accident conditions because the flow will be less than 75 gallons per 16 n
~
., o..
minute A rotameter requires a minimum flow before rotation starts.
Any pump operation will cause flow indiction.
Therefore, we find this deviation acceptable.
3.3.17 Comoonent Coolina Water Temperature to Enaineered Safety Features (ESF) SysteJD Regulatory Guide 1.97 recommends instrumentation for this variable with a range from 40'F to 200*F. The licensee's instrument span for this variable, as stated in Reference 5, was 50'F to 200'F.
Reference 7 indicates the range is zero to 225'F.
This encompasses the recommended range. We find this acceptable.
This instrumentation does not have control room indication.
The readout is local, in a mild environment, in the auxiliary building.
There are alarms in the control room. The system is prealigned procedurally.
Emergency operating procedures do not require any changes to the component cooling water system for accident recovery.
As Item 6.2 (g) of Supplement No. I to NUREG-0737 specifically allows readout locations that are not in the control room, we find this instrumentation acceptable.
3.3.18 Comoonent Coolina Water Flow to ESF System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.
It recommends a range of zero to 110 percent of design flow.
References 4 and 5 did not identify instrumentation for the variable.
In.
Reference 7, the licensee. identified the instrument span of zero to
-7,000 gallons per minute. This range satisfies the recommended instrument q
span and is, therefore, acceptable.-
l 3.3.19 ~ Radioactive Gas Holduo Tank Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range of zero to 150 percent of design pressure.
The Ginna instrumentation has a range'of zero to 150 psig (design pressure).
The 17
.. s s.
licensee states that the normal operating pressure of these tanks is less than 100 psig.
The rad gas pump is administrative 1y limited to 100 psig.
Each radioactive gas decay holdup tank has a pressure relief valve that operates at 150 psig.
As the licensee shows that it is reasonable to expect this instrumentation to remain onscale, we find the provided range acceptable.
3.3.20 Accident Samolina (Primary Coolant. Containment Air and Sumo)
The licensee's sampling system can sample and provide the analysis within the ranges recommended for this variable, except for boron content, chloride content, dissolved hydrogen, and dissolved oxygen.
For boron content, the capability is 50 50 parts per million to 6,000 300 parts per million rather than the recommended zero to 6,000 parts per million.
1 For chloride content, the capability is 5 parts per billion to 100 parts per million rather than the recommended zero to 20 parts per million.
For dissolved hydrogen,.the capability is 10 cc/kg to 2,000 cc/kg rather than the recommended zero to 2,000 cc/kg.
For dissolved oxygen, the capability is 0.1 parts per million to 20 parts per million rather than the recommended zero to 20 parts per million. These lower limit resolution deviations are
- small, i
The licensee deviates from the recommended Regula.,ry Guide 1.97 post-accident sampling capability.
The NRC has reviewed and approved the i
licensee's post accident sampling system as part of their review of NUREG 0737, Item II.B.3.
L 3.3.21 Containment Sumo Water Level Regulatory Guide 1.97 recommends Category I wide-range and Category 2 narrow-range instrumentation for this variable.
The licensee's wide range instrumentation is Category 1 and has a plant specific range as recommended.
The licensee's narrow-range instrumentation is Category 3.
The licensee states that the narrow-range instruments serve as an adjunct to the wide-range instruments.
18
I The licensee states that the narrow range instrumentation is not, by itself, the basis for any operator action.
The narrow-range instruments are used to check if the reactor coolant system is intact.
The wide-range instruments are used for any operator decisions.
Indeed, the wide-range instruments are Type A.
The licensee states that the narrow-range instruments are used early in a teactor trip or safety injection recovery.
The narrow range instruments do not generate a trip or an injection signal.
We conclude that the instrumentation supplied by the licensee will provide the appropriate monitoring of the parametric of concern.
We base this evaluation on the following.
1.
For small leaks, the instrumentation will not experience a harsh environment during operation and will show response to the leak.
2.
For larger leaks, the sumps fill promptly and the sump recirculation and drain lines isolate due to the containment isolation signal, thus negating the narrow range instrumentation.
3.
The instrumentation neither automatically starts nor alerts the operator to start operation of a safety related system in a i
post-accident situation.
4.
The wide-range Category 1 instrumentation covers up to an equivalent of 500,000 gallons in containment, overlapping a good portion of the narrow-range instruments.
Therefore, we find the provided Category 3 narrow-range instrumentation acceptable.
3.3.22 Effluent Radioactivity - Noble Gases i
Regulatory Guide 1.97 recommends instrumentation for this variable with' 3
a range of 10-6 pCi/cc to 10 #Ci/cc. The licensee identifies monitor R-ll for this variable.
Monitor R ll has a range of I count per I
19 L
l e-
..
- i.
minute to 107 counts per minute. The licensee states for the containment purge vent exhaust that this range exceeds 10 pCi/cc.
For the auxiliary building vent exhaust, this range exceeds 50 gCi/cc.
The regulatory guide assumes a common plant vent for this variable.
Based on the licensee's instrument description, this assumption does not hold.
The regulatory guide footnote states that a single device is'not likely to have the capability to cover the entire recommended range, that multiple components or systems will be needed. The licensee states that the post-accident sampling system is backup instrumentation for this variable.
The post-accident sampling system can analyze an undiluted or a diluted exhaust stream.
If the R-ll monitor goes off scale, the licensee would still be able to identify a breach of containment, which is the purpose of this variable. Therefore, we find the instrumentation provided for this variable acceptable *.
3.3.23 Accumulator Isolation Valve Position Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.
Category 2 criteria include environmental qualification.
In Reference 7, the' licensee states that the accumulator isolation valves are not included in the environmental qualification program.. The licensee states that-these valves are maintained open during reactor operation by
- administrative controls.
The administrative controls include removing the fuses from the control circuits.
This disables the valves in the open positions.
Because these valves are open and cannot change position during or following an accident without deliberate operator action, we consider the
-instrumentation for this variable acceptable.
3.3.24 - Hioh Pressure injection (Safety injection) Flow l
Regulatory Guide-1.97 recommends Category 2 instrumentation for this-variable; hewever, the licensee has classified this as a Type A variable.
Therefore, the licensee should provide Category 1 instrumentation for this
'ariable.
Category I criteria include redundancy. The-licensee has v
redundant safety injection piping.
Each of the two redundant safety injection legs has a single flow or_lfice and one transmitter.
20
y*.*-
Table 1 of Regulatory Guide 1.97, Revision 3, clarifies this situation.
It reads "within each redundant division of a safety system, redundant monitoring channels are not needed except for steam generator level instrumentation in two-loop plants." Therefore, the licensee's instrumentation for this variable is acceptable.
l 3.3.25 Condensate Storaae Tank Level Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee meets the Category 1 criteria except for redundancy. The licensee has two condensate storage tanks.
Each tank has one level measurement instrument system.
I The two condensate storage tanks are connected together with ten inch piping.
The valves on this line are administrative 1y controlled and locked open. Thus, the two tanks function as a single tank.
We also note that
^
where redundant safety systems are employed, redundant instrumentation is not required by the regulatory guide (except for wide-range steam generators in two-loop plants).
Based on the two tank design, we find the instrumentation provided for this variable acceptable.
3.3.26 Heat Removal by the Containment Fan Heat Removal System o
Regulatory Guide 1.97 recommends plant-specific Category 2 I
instrumentation for this variable.
The licensee states that the fan operation is monitored by Category 2 indicating lights.
The containment air fan cooler is cooled by service water.
Category 3 flow (local) and
-temperature indication and alarms monitor the cooling water.
This i
instrumentation is located in a mi'id environment.
Containment pressure, containment temperature, and containment sump water temperature are observed to verify the effectiveness of the heat removal.
We note that this is effective only when containment spray is not operating.
We find the licensee's described instrumentation acceptable for the l
l variable heat removal by the containment fan beat removal system.
21 l
l l
..
- s 3.3.27 Containment Atmosphere Temoerature
(
Regulatory Guide 1.97 recommends Category 2 instrumentation for this i
variable with a range of 40*F to 400*F.
The licensee is upgrading six resistance temperature detectors (RTDs) to meet the Category 2 criteria. However, the range is zero to 300'F.
l The licensee's Updated Final Safety Analysis Report, Table 3.11-1 and Figure 6.12, show that the design peak containment temperature is j
286'F.
Based on this limit, in-containment equipment was qualified to a maximum temperature of 300*F.
Based on this justification, we find the range supplied by the licensee for post-accident monitoring acceptable.
3.3.28 Emeroency Ventilation Damper Position Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.
It does not suggest what equipm< it is to be monitored.
The licensee states that the main purge valves, A0V-5869 and 5879, are blind flanged and not normally operated. The licensee identifies the 6-inch mini-purge valves, both supply and exhaust, as subject to the recommendations for this variable. These valves, 7970, 7971, 7445, and 7478 are not identified as air-operated or motor operated valves. The licensee indicates that they are included under the scope of containment isolation valves.
See Section 3.3.4.
The licensee does not indicate if these valves are in a mild environment, or if the position switches installed in 1987 are environmentally qualified. Any containment isolation valve that can be
- exposed to a harsh post accident environment should have environmentally qualified position indication.
This conclusion agrees with the requirements l
of'10 CFR.50.49 (b)(3). The licensee should assure.that this instrumentation,-including position switches and cables, is environmentally qualified.
i l
i t
l 22~
L s
e
m
.,yt s
3.3.29 Plant and Environs Radiation Regulatory Guide 1.97 recommends portable instrumentation for this 4
variable.
It recommends a range of 10-3 R/ hour to 10 R/ hour photons and 10*3 rads / hour to 10 rads / hour beta radiation and low energy 4
photons.
In Reference 7, the licensee lists the instrument capabilities.
3 For photons, the instrument span is 10-6 R/ hour to 10 R/ hour.
For beta 4
type radiation the instrument span is 10-3 R/ hour to ' M R/ hour.
The scaling in R/ hour instead of in rads / hour can ia converted, and is thus acceptable. The deviation in the upper limit of the range is acceptable because the instrumentation is portable. Because of the potential for personnel exposure,-the licensee would not use portable instrumentation to assess radiation levels greater than the provided ranges.
3.3.30 Estimation of Atmosoheric Stability Regulatory Guide 1.97 recommends instrumentation for this variable with a range of -9'F to +18'F or an analogous range for alternative stability analysis.
The licensee's instrument span covers between -8'F to +20*F.
Table 1 of Regulatory Guide 1.23 (Reference 9) provides seven j
atmospheric-stability classifications based on the difference in temperature per 100 meter elevation change.
These classifications cover from extremely unstable to extremely stable. A temperature difference greater than 4'C o*
1ess than -2'C has no impact on the stability classification.
The licensee's instrumentation is inclusive of this span.- Therefore, we find the' instrumentation acceptable for determining the atmospheric stability, i
1 23
)
4.
CONCLUSIONS Based on'our retiew, we find that the licensee either conforms to or is justified in deviating from Regulatory Guide 1.97, with the following exceptions:
1.
Neutren flux - The licensee should provide neutron flux instrumentation that meats the Category 1 and range criteria of 9egulatory Guide 1.97.
See Section 3.3.1.
2.
Containment isolation valve position -- The licensee should provide position indication instrumentation that is environmentally qualified in accordance with 10 CFR 50.49 for any containment isolation valve that can be exposed to a harsh post-accident environment.
See Section 3.3.4.
3.
RHR hea't exchanger outlet temperature -- The licensee should environmentally qualify the RTDs and cables, in accordance with 10 CFR 50.49, that are associated with.this variable.
See Section 3.3.7.
4.
Accumulator tank pressure -- The licensee should environmentally qualify.this instrumentati..) in accordance with 10 CFR 50.49.
See j
Section 3.3.8.
5.
Emergency ventilation damper position - The licensee should l
assure that the instrumentation is environmentally qualified -in accordance with 10 CFR 50.49.
See Sections 3.3.4 and 3.3.28.
l 1:
l 24 1
I
- < ]
o REFERENCES 1.
Letter, NRC (D. G. Eisenhut) to All licensees of Operating Reactors, Applicants for Operating licenses, and Holders of Construction Permits,
" Supplement No. I to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
2.
Instrumentation for licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Reauirements. Reauirements for Emeroency Response Canability, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4.
Letter, Rochester Gas and Electric Corporation (J. E. Maier) to NRC, "NUREG 0737, Supplement 1," January 31, 1984.
5.
Letter, Rochester Gas and Electric Corporation (R. W. Kober) to NRC, "USNRC Regulatory Guide 1.97," February 28,1985.
6.
Letter, Rochester Gas and Electric Corporation (R. W. Koben) to KRC (G.
E. Lean), " Regulatory Guide 1.97 Review," June 16, 1986.
7.
Letter, Rochester Gas and Electric Corporation (R. C. Mecredy) to NRC (A. R. Johnson), " Regulatory Guide 1.97 Conformance Emergency Response Capability, TAC.No. 51093," July 13, 1990.
8.
Instrumentation for licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followino an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
9.
Onsite Meteoroloaical Proarams, Regulatory Guide 1.23, NRC, February 17, 1972, or Meteorolooical Procrams in Sucoort of Nuclear Power Plants, Proposed Revision I to Regulatory Guide 1.23, NRC, Office of Standards Development, September 1980.
I 25
9 eons ass u;UEcks Aa cecuLatuar commnission agtyya i
EuE BIBLIDGRAPHIC DATA SHEET
~
o
.,,,,w,,,,,,.,,.,,,
l.GG-flTA-9195
- 2. Taf LE ANo Sveinf LE C0flFORnAllCE TO REGULATORY GUIDE 1.97:
GIttflA J
o ATE agpont eve 615=to uom itaa September 1990
-1
. ein on canst svueen A6483
- 6. AUTHORIll 6 TYPE of Ripont
_ Alan C. Udy Technical Evaluation Report
- 7. Pt RIoo Cov & A Eo,me e one.
e Pswgaggnizatio - =A=
ano aoanass,,...c.
o o - - u.a
% c -
J Reculatory and T4c,hnical Assistance EG&G Idaho, Inc. (
P. O.-Box 1625 Idaho Falls, ID 83415 e.,seoggoamzatio mame ano aooanss e,,=ac.,,
i.
..c o o,
. va a-1, Division of. Systems Technology Office of fluclear Reactor Regulation _
. U.S., Nuclear Regulatory Commission Washington,.DC 20555
- 10. $UPPLOWENT ARY NOTI 5 1l. As$f A ACT Geo.wes., o.s.
e
'This EG&G Idaho, Inc., repopt documents the review of the Regulatory Guide'1.97, Revision 3, submittals for the R. E. Ginna fluclear Power Plant, and identifies areas c
.of 'nonconformance; to the-regulatory guide. - Exceptions to Regulatory Guide 1.97 are evaluated and those areas where-sufficient basis for acceptability is not provided are identified.
s
/
O
+
- i.
- 12. EE Y mS05/DESCRIPTOR5 tw eem esais.e en w a.se. _
. m aer.s-v ene suse.s.
- u. ava,4eaurv sTarsus=T Unlim<ted Distr' bution y
- i. secuni", cussie cario%
mus Ausse Unclassified a r n.,-.,
Unclassified t 5. NUMG4R OF PAGE&
le. PRICE J'
- =ac eaa. m ami -
~l
.