ML20069N203
| ML20069N203 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/31/1988 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20069N210 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7061, EGG-NTA-7061-R01, EGG-NTA-7061-R1, TAC-51099, NUDOCS 8909260358 | |
| Download: ML20069N203 (24) | |
Text
. _. _ _.
EGG-NTA-7061 Rev,ision 1 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97:
INDIAN POINT-3 Alan. C. Udy Pubitsbed October 1988 EG&G Idaho, Inc.
Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-761001570 FIN No. A6483 D
sqcw.o3591^
AB$ TRACT This EG&G Idaho, Inc.# report reviews the submittals for Regulatory Guide 1.97, Revision 3, for the Indian Po'.
- iree Nuclear, Power Plant.
Any exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
Docket No. 50-286 TAC No. 51099 11
h a
FOREWORD This report is supplied as part of the " Program 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 Engineering and System Technology, by EG&G Idaho, Inc.,
Electrical, Instrumentation, and Control Systems Evaluation Unit.
The U.S. Nuclear Regulatory Commission funded the work cnder authorization B&R 20-19-10-11-3.
Docket No. 50-286 TAC No. 51099 tii
CONTENTS
+
ABSTRACT.............................................................
11 FOREVORD..............................................................
iii 1.
INTRODUCTION.....................................................
1 2.
REVIEW REQUIREMENTS..............................................
2 3.
EVALVATION.......................................................
4 3.1 Adherence to Regulatory Guide 1.97.........................
4 3.2 Type A Variables...........................................
4 3.3 Exceptions to segulatory Guide 1.97........................
5 4
CONCLUSIONS..........'............................................
12 5.
REFERENCES.......................................................
13 APPENDIX A...........................................................
14 IV
CONFORMANCE TO REGULATORY GV!DE 1.97 IN0!AN POINT-3 1.
INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was issued by O. G. Eisenhut, Directer of the Division of Licensing, Nuclear 1
Reactor Regulation, to all licensees of operating reactors, applicants for l
eperating licenses and holders of construction permits.
This letter cluded additional clarification regarding Regulatory Guide 1.97, aeitsion 2 (Reference 2), relating to the requirements for emergency ispense capability.
These requiremunts have been published as Supplement No. I to NUREG-0737, "TM!, Action P1sn Requirements" (Reference 3).
The New York Power Authority, licensee for Indian Point-3, provided a response to Section 6.2 of the generic letter on June 29, 1984 (Reference 4), that addresses the requirements of Revision 3 of Regulatory Gvfde 1.97 (Reference 5). Additional information was provided on January 7,1986 (Reference 6) and December 1,1986 (Reference 7).
This report is based on the recommendations of Repulatory Guide 1.97, Revision 3, and compares the instrumentation identified in the licensee's submittals with these recommendations.
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2.
REV!EW REQUIREMENT $
Section 6.2 of NUREG-0737, Supplement No. 1, sets forth the documentation to be submitted to the NRC in a report describing how the licensee complies with Regulatory Guide 1.97 as applied to emergency response facilities. The submittal should include documentation that provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97, 1.
Instrument range 2.
Environmental qualification i
3.
Seismic qualification 4.
Quality assurance 6.
Redundance and senhar location 6.
Power supply 7.
Location of display 8.
$chedule of installation or upgrade The submittal should identify deviations from the recommendations o' Regulatory Guide 1.97 and should provide supporting justification alternativesforthediviationsidentified.
Subsequent to the issuance of Generic Letter 82-33, the NRC held regional meetings in February and March 1983, to answer licensee and applicent questions and concerns regarding the NRC policy on this subject.
At these meetings, it was noted that the NRC review would address only exceptions taken to Regulatory Guide 1.97.
It was also noted that, where licensees or applicants explicitly state that instrument systems conform to 2
th9 regulatory guide, no further staff review would be necessary.
Therefore, this report addresses only exceptions to Regulatory Guide 1.97.
Thefollowingevaluationofthelicensee'ssubmittalsisbasedonthi review policy described in the NRC's regional meetings.
1 3
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n 3.
EVALUATION The licensee provided a response to Item 6.2 of NhC Generic Letter 82-33 on June 29, 1984. The response describes the licensee's Additional position on post-accident monitoring instrumentation.
This information was provided on January 7, 1986, and on December 1, 1986.
evaluation is based on these submittals.
3.1 Adherence to Regulatory Guide 1.97 The licensee pror ced a review of their post-accident monitoring instrumentation that compares the instrumentation characteristics against The lirensee the recommendations of Regula; tory Guide 1.97, Revision 3.
identified where tha post-acciaert mor.ftoring instrer.antation conforms to A confirmatory order Regulatory Guide 1.97 and where devis>.t ans exist.
(issued by the NRC, Reft ~.'nce 8) requirit tF le needed modifications into full compliance identi+d by tF-licensee to bring tne instrumentlot with the regal guide to be completed during the cycle S/6 (198})
v, we conclude that the licensee has provided an
~
refueling.
4e conformance to Regulatory Guide 1.97.
Exciptions to expitett con
+nt ie regulatory guide are noted in Section 3.3.
and deviation- ? c se 3.2 Type A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., thosc variaoles that provide the information required to permit the control room _ operator to take specific, manually-controlled safety The' licensee classifies the following instrumentation as Type A.
actions.
1.
reactor coolant system cold leg water temperature 2.
reactor coolant system hot leg water temperature 3.
reactor coolant <Ystem pressure 4
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4 4,
- core exit temperature s
5.
degrees-of subcooling 6.
containmentsumpwaterlevel(widerange) 7..
containment pressure 8.
containment area radiation 9.
. refueling water storage tank level low level alarm 10, pressurizer 'leve1,-
11..steamgeneratorlevel(wide-range)
+
12.
steam generator level (narrow range) t
- 13. steam generator pressure
- 14. - secondary system radiation - main steam
-The above instrumentation meets the Category I recommendations consistent with the requirements for Type A variables, with those exceptions listed in Section 3.3.
(
3.3 Exceptions to Re
,ry Guide 1.97
. The licensee-identified deviations and exceptions from Regulatory l-Guide 1.97.
These are discussed in the following paragraphs.
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3.3.1 Initially Unresolved Variables In Reference 4, the licensee identified 25 variables (listed in Appendix A).that needed either additional analysis and assessment or plant modifications. Additional information was provided in References 6 and 7.
These variables are discussed in Appendix A.
The instrumentation either meets the recommendations of Regulatory Guide 1.97 or deviates from those recommendations. With the exception of the containment sump water temperature, the instrumentation is acceptable for use with Regulatory Guide 1.97.
3,3.2 Neutron Flux Regulatory Guide 1,97 recommends Category 1 instrumentation for this
-6 variable with a range from 10 percent to 100 percent of full power.
The licensee's then existing instrumentation had a range (identified in
-5 Reference 4) of 10 percent to 120 percent of full power.
Reference 6 states that the neutron flux instrumentation will be modified or upgraded to achieve full compliance with. Regulatory Guide 1.97.
Reference 7 describes the instrumentation as being displayed, recorded, and acceued'en the Qualified Safety Parameter Display System (QSPDS) and on the Critical Functions Monitoring System (CFMS). The QSPOS is Ifully qualified to display an'd record Category 1 -instrumentation as Lrecommended by Revision 3 of Regulatory Guide 1.97. We find the described instrumentation to be acceptable.
-3.3.3 Cor.tainment Isolation Valve Position.
The licensee identified an exception to Regulatory Guide.1.97 for this variable in-that the manually-operated containment isolation valves do not haveLthe recommended instrumentation. Those containment isolation valuet
-that are-operated automatically have the-recommended instrumentation.
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The licensee justifies this exception by stating that these manual valves are maintained in their closed position. When technical specifications permit their opening, it is done only with-the approvn) of the shift supervisor. An operator is specifically assigned to operate that valve, and only with communications established with the control room.
This dedicated operator's response, should an accident occur while the valve is open, is to close that valve. The operator has no other duties while that_ valve is open. We find this exception acceptable.
Regulatory Guide 1.97 recommends Class 1E power sources for this variable.
Reference 4 did not identify the power sources for this instrumentation. Based on the licensee's statement in Reference 6 that the recommendations of Regulatory Guide 1.97 are met, we conclude that Class 1E power sources are used for'this instrumentation.
s Additionally, from the information provided, we find that the licensee deviates from a strict interpretation o..he Category I recommendation for redundant instrumentation. There is'ene open/ closed 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 instrumentation provided for this variable is acceptable.
3.3.4 -Accumulator Tank level and Pressure Regulatory Guide 1.97 recom11 ends Category 2 instrumentation for this variable, with ranges of 10 percent to 90 percent volume for level and zero to:750 psig for pressure. The licensee has-provided Category 3-instrumentation,.with ranges of 84 percent to 92 percent volume for level and zero to 700 psig for pressur.e.
The : licensee did not provide justification for the deviations from the recommended ranges. The licensee has committed to upgrade either the level or the pressure instrumentation to Category 2.
If pressure is the key variable, the existing level range is acceptable; however, the pressure 7
E l_
range should be expanded.to zero to 750 psig.
If accumulator level is 3
considered the key variable, the level range should be expanded to meet the regulatory guide recommendation.
3.3.5 Pressurizer Heater Status Regulatory Guide 1.97 recommends monitoring the pressurizer heater electric current with Category 2 instrumentation. The licensee monitors the heater circuit breaker position.
The licensee states that this instrumentation is adequn e,'as-pressurizer temperature and pressure are
-used as backup.
Sectiot II.E.3.1 of NUREG-0737 requires a number of the pressurizer heaters to:have the capability of being powered by the emergency power.
sources.
Instrumentation is to be provided-to prevent overloading a diesel generator, and technical specifications are to be changed accordingly.- The Standard Technical Specifications for_ Westinghouse reactors, Section 4.4.3.2,; require that _the emergency pressurizer heater current be measured quarterly. The : licensee has diesel 1. ding information in-the control. room and has procedures to prevent overloading a diesel generator, In addition,'an accident signal strips these heaters from the bus.
They must then be-energized manually by procedure.
We find the. supplied-instrumentation, procedures-and bus stripping on
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an accident signal to be acceptable.
3.3.6-Quench Tank Temperature-Regulatory Guide 1.97. recommends' instrumentation for this variable with a range of_50*F to 750*F. The licensee has'providedlinstr'umentation with a range of 50*F to 300*F that will be re-ranged to _50*F to 350*F. The licensee's justification for this deviation is that the upper range
~
limit (350*F) enveleos the saturation temparature (327'F) corresponding to the rupture disk relief'presnre.that prevents the' vessel pressure from 8
m
excaeding the tank destgr pressure of 100 psig.
The licensee also states
.that no operator action is required for accident mitigation based on this parameter.
Because pressure relief limits the temperature of the tank contents to saturated steam conJisions under 350*F, we find this deviation from the regulatory guide and the 50*F to 350'F range to be acceptable.
3.3.7, Heat Removal by the Containment Fan Heat Removal System Regulatory Guide 1.97 recommends plant-specific Category 2 instrumentation for this variable.
In Reference 4, the licensee identified Category 3 service water flow instrumentation with a range of zero to 2500 gpm.
The increase in service water temperature across the containment fan heat removal heat exchangers was also identified by the licensee; however, no instrumentation was identified for this temperature dif ferential. ' This combination of instrumentation, if Category 2, would give a quantitative look at the operation of this system as recommended be the regulatory guide.
The licensee committed to implement changes to upgrade the flow and heat exchanger differential temperature instrurentation supplied for this variable to Category 2 (Reference 6). We find this commitment to be acceptable._
3.3.8 High Level Radioactive Liquid Tank level Regulatory Guide 1.97 recommends instrumentation with a range from the top to the bottom of.the tank for this variable, The licensee indicates that this range is equivalent to zero to 12 feet 11 inches.
The licensee's instrumentation has a range of zero to 12 feet 2 inches, and this is stated to represent more than 94 percent of the tank volume.
4
~This range is adequate to indicate the storage volume during all accident and post-accident conditions.
Therefore, we find-this deviation to be acceptable.-
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3.3.9 Radioactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends' instrumentation with a range from zero sto 150 percent of design pressure for this variable. The licensee states that this range is equivalent to zero to 165 psig. The range
-provided by the licensee is zero to 150 psig..The licensee sta:is that 150 psig is the tank pressure relief valve setpoint.
The tank pressure will not exceed this range. Also, high pressure alarms are-set at 110 psig.
Based on the justification provided by the licensee, we conclude that the instrumentation provided for this variable is adequate to monitor the operation of_these tanks and is, therefore, acceptable.
3.3.10 plant'agd Environs Radioactivity w
Regulatory Guide 1.97 recommends portable instrumentation for this variable for isotopic analysis. The licensee states (Reference 6) that.
l portable instrumentation for-isotopic analysis will be supplied. We find this commitment to be acceptable, s3.3.11~ Estimation of Atmospheric Stability-Regulatory Guide 1.97-recommends instrumentation for this variable to
.have either a range of -5'C to +10*C or ar. analogous range for alternative
' stability-analysis. The licensee has' supplied-instrumentation with a range of'-4.44*C to'+11*C, -The licensee has not provided justification,for the-l deviation:fromJ-5'C to -4.44'C..
Table 1 of' Regulatory Guide l.23_(Reference 9) provides seven atmospheric stabilityJclassifications based'on-the difference in I
temperature per 100 meters elevation'-change. These4 classifications cover
- from extremely unstable to extremely stable. A temperature differe'nce i
greater than +4*C_or less than -2"* has no impact on the stability-classification. The -licensee's instrumentation includes this range.
Therefore, +ni find that-this instrumentation is acceptable to determine i
atmosphericistability.
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I 3.3.12 Accident Sampling (Primary Coolant. Containment Air and Sump)
Thelicensee'spost-accidentsamplingsystemprovidessamplingind fanalysis as recommended by the regulatory guida except for the following deviations.
1.
Boron content--the minimum observable concentration is 10 ppm.
2.
Chloride content--the minimum observable concentration is 0.04 ppm.
3.
Dissolved hydrogen--the-maximum observable concentration is 200 cc/kg.
The licensee deviates from Regulatory Guide 1.97-with respect to
' post-accident sampling capability. This deviation goes beyond the scope of-this review and has been addressed by the NRC as part of their review of NUREG-0737,. Item !!,0.3.
11 4
4.
CONCLU$10NS Based on our review, we find that the licensee either conforms to or is justified in deviating from Regulatory Guide 1.97, with the following exceptions:
1.
Accumulator tank level and pressure -- The licensee should provide the recommended range for this variable.
(Section 3.3.4) 2.
Containment sump water temperature -- The licensee should provide instrumentation for a quantitative measure of heat removal.
(Appendix A) 12
.4 5.
REFERENCES
. 1.
Letter, NRC (D. G. Eisenhut) to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits, " Supplement No. 1 to NUREG 0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982, 2,
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Enytrons Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development December 1980.
3.
Clarification of THI Action Plan Requirements, Requirements for Emergency Response Capability, NUREG-0737, Supplement No.1, NRC, Of fice of-Nuclear Reactor Regulation, January 1983.
4.
Letter, New York Power Authority (J. P. Bayne) to NRC, " Regulatory Guide 1 Revision 2, Implementation Program," June 29, 1984, 10N-84-2v.
5.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 3. NR, Of fice of Nuclear llegulatory
- i Research, May 1983.
6.
Letter, New York Power Authority (J. C. Brons) to NRC, " Regulatory Guide 1.97-Implementation Program," January 7,1986, IPN-86-05.
7.
Letter, New York Power Authority (J. C. Brons) to NRC (S. A. Varga),
" Clarification of Regulatory Guide 1.97 Implementation Program,"
December 1, 1986, IPN-86-60.
8.
-Letter, NRC-(S. A. Varga) to New York Power Authority (J. C. Brons),
" Order Modifying Licensee Confirming Additional Licensee Commitments on Emergency Response' Capability (Supplement-No I to NUREG-0737),"
August 6, 1985.
9.
Onsite Meteorological Programs, Regulatory-Guide 1.23 (Safety
-Guide 23), NRC, February 17, 1972 or Meteorological Programs in Support
_of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, Sept' ember 1980.
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APPENDIX A INITIALLY UNRESOLVE0 VARIABLES I
14
APP [NUlX A INiil AL L V UNRE SOL Vf D VAR I ABL E S l
Resolution Variable Deviation (f rom Ref erence 6)
J 1.
Neutron flux Environmental Qualification The licensee has comunitted to provide or upgrade to Cat egery I instrumentation, covering the f es11 recormoended range. (Section 3.3.2) 2.
Reactor Ecolant
$ctsmic Qualificalton The licensee indicates that this is seissiCally System Pressure (Type A) qualified and that the range of the redundant instrumentation will be zero to 3000 psig.
3.
Core Exit Temperature Environmental Qualification The licensee states that this instrumentation (lype A)
Seismic Qualifica* ton will be modified to comply with Regulatory Guidt.l.97.
Inis includes display and recording on the 0$PDS and the CIMS. Ihis arrangement is an acceptable method to meet the rectmmendations of Revision 3 of Regulatory
'uide 1.91.
4 Degrees of Subcooling Range The licensee states that this instrumentation (Iype A)
Environmental Qualification now sat tsfies a*1 the regulatory guide Seismic Qualificatian rec ormnendat ions.
5.
Eontainment Sump Water Level Range The licensee indicates overlappino sump water (Wide Range) level instrumentation covering f rom 34*4* to 54'1".
6.
Radiation Level in Circulating Range The licensee states that the evivironmental Primary Coolant environmental Qualification and seismic qualif ication, redundancy, and Seismic Qualification range recorsmended by the regulatoey guide will be provided. R edundertt instrumentation will be provided, but only a single sampling line will be added to tap the redCtor (oolant systese. We find this arrangment acceptable.
7.
Containment Ef fluent Radioactivity-Range The lir.ensee states that R-12 is in a mild Noble Gas Environmental tauelification environment.
R.27, which is envirocamentally quailfied, has a range that overlaps R-12 and f entands beyond the recomumended range.
8.
Radiation Esposurr Rate Range The licensee states that new instrummevitation tack of Ponitors in Specific will oc provided that satisf ies the Areas regulatory guide.
9.
Ef fluent Radioactivity - Noble Gas Range As this discharges through the comumon Envirocaental Qualification plant vent, separate instrumentation is not necessary.
l
a Resolut ion Variable
!)eviat ion
( f rom Ref erence 6)
- 10. Boric Acid Charging F low Environmental Qualification This variable is monitored by the high pressure Seismic Qualification injection flow instrumentation.
i
- 11. Refueling Water Storage Tank-Level Redundanc y
( Type A) 1he Type A variable consists of alarms t%at will be upgraded to Category I. including redundancy.
The Type D variable has the recosamended instrumentation.
- 12. Containment Atmosphere Temperature Range the licensee states that this instrumentation l
will be upgraded to comply with Regulatory Guide 1.91.
I
- 13. Containment Sump Water Temperature Cst. 2. Instrumentation Not This variable is monitored by the RNt heat i
Provided exchanger outlet temperature, containment spray flow and containment temperature. The licensee states that this instrument 1 tion provides indication of containment heat removal capability. However, it does not shnw a I
quantitative measure of heat removed. The licensee should orovide instrumentation to acco m lish this.
14.14akeup Flow-in Environmental Qualif icat ion The licensee states that this is in a mild environment.
- 15. Letdown Flow-Out Range Administrative controls limit the letdown flow to 120 gpe.
Therefore the ranje of zero to 4
i 125 gpm is acceptable.
- 16. Volue e Control Tank t evel Range lhe liceesee states that expanding the range range beytmd 18 percent to 32 percent is not justified due to expos. ore and ost/ benefit.
The range covers the cylinderia al portion of the tank. Beyond this range in the hemispherical tank ends, the v^lume/ level ratio l
is not linear. Therefore, the provided range
[
is acceptable.
- 17. Component Cooling Water Ternperature Range The licensee has never experie-ced a temperature 4
to Engineered Safety feature System f omponents of <50*F for this variable. In an accident, the tegerature would increase. Therefore the s
range of 50*F to 200*F is acceptable.
- 18. Conconent Cooling Water Flow to Range (Low limit)
The licensee states that the minimum Engineered Safety Feature System Lomponents
~
indicated flow (2000 gpe) is acceptable because any post-accident flow mould be greater than this. Also, pump motor circuit breaker and low output pressure alarrs exist, we find this instrismentation acceptable.
j
- 19. (mergency Ventilation Dancer
.Rrnge
.This is indicated by red and green lights l
Posetion operated of f the same position switches. Low flow is also alarmed. We find this
4 I
Resolution variable Deviatton (from Reference 6)
- 20. Status of Standby Power t ack of DC Bus Current the licensee states that suf ficient parameters Instrumentation are monitored to assure the bus status.
4 includirv, charger out*,ut current and bus voltage. We find th,s acceptable for i
monitoring this plar t specific variable.
- 21. Condenser Air Renoval System Seismic Qualification The licensee shows this meeting the Type A.
bhaust-Moble Gas and Vent Flow Redundancy Category I requirements.. The f low indication Rate (Type A) 4 for the Type E ins'.ruments will be modified to comply with Regula tory Guide 1.97 The noble j
gas indication for the Type E variable is routed to ontainment for levels
>l.4 x 10-,Ci/cc to be monitored by the j
common plant vent. We find this acceptable.
- 22. Vent from Steam Generator Safety This is. no lenger considered a Type A variable.
Relief Valves.hoble Gas.
Duration of Release and Mass of It meets the Type E variable requirements.
4 Duration of release and mass flow rate are
]
5 team Per Unit Time recorded on the plant computer.
- 23. All Other Identified Release Points-Range Instrumentation for the radioactive machine Noble Gas and went flow Rate Lack of Monitors in Specific shop exhaust noble gas will be modified to Areas comply with the regulatory guide. Flow instrumentation that conforms to Regulatory l
Guide 1.97 will be added to the steam generator j
blowdown flash tank went. The flow rate instrumentation will be provided as recommended.
The 4th floor adelnistrative building exhaust is not part of the unit and does not <me under the regulatory guide.
s
- 24. Particulates and Halogens Range The instrumentation for this variable either t ack of Monitors in Specific meets or will be modified to meet the espected Areas levels of particulates and halogens. The flow j
rate instrumentation will be provided as recommended. The 4th floor administrative
}
building exhaust is not part of the unit and i
does not come under the regulatory guide.
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el8000RAPHic DATA SHEET EGG.NTA 7061, Rev. 1 CONFORMANCE TO KEGULATORY GUIDE 1.97:
INDIAN P0lNT-3
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October 1988 Alan C. Udy-
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October I
1988
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EG&G Idaho. Inc.
P.O. Sox 1625 Idaho Falls, ID 83415 A6483
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Division of Engineering and. System Technology Technical Evaluation Report Office of Nuclear Regulation U.S. Nuclear Regulatory Commission
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Washington, DC 20555
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o..c..c,,m This EG&G Idaho, Inc., report documents the review of the applicable submittals for the Indian Point-3 Nuclear Power Plant and identifies areas of nonconformance to Reaulatory Guide 1.97.
Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is
.vt orovided are identified.
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Mr, Ralph E. Beedle 2
April 3, 1991 This requirement affects one respondent and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
Sincerely, DRIGDMI SIGNED BYi Franc's J. Williams, Jr., for Joseph D. Neighbors, Senior Project Manager Project Directorate 1 1 Division of Reactor Projects. 1/11 Office of Nuclear Reactor Regulation
Enclosures:
1.
Safety Evaluation 2.
TER ECG.HTA.7061, Revision 1 cc w/ enclosures:
See next page Distribution:
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