ML20072P775
| ML20072P775 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/30/1990 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20072P778 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7047, TAC-51119, NUDOCS 9011020239 | |
| Download: ML20072P775 (35) | |
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June 1990 TECHNICAL EVALUATION REPORT
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Idaho-National omcE TO EWWORY WIDE 1.97: PILGRIM Eng/neering Laboratory Managed by the U.S.
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t NCrr!CE This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States .
Govetament nor any agency thereof. not any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any .
- Information apparatus, product or process disclosed in this report, or a represenu that its use by such third party would not infringe privately owned rishu.
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si EGG NTA 7047 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97: PILGRIM Docket No. 50 293 Alan C. Udy c.
Published June 1990 o
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-AC07-761D01570 FIN No. A6483 TAC No. 51119
SUttiARY This EG&G Idaho, Inc. report documents the review of the Regulatory Guide 1.97, Revision 3, submittals for the Pilgrim Nuclear Power Station and identifies areas of nonconformance to the regulatory gui,de. Exceptions to Regulatory Guide 1.97 are evaluated and areas where sufficient basis for acceptability is not provided are identified.
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FIN No. A6403
- B&R 20 19-10 11-3 Docket No. 50-293 .
TAC No. 51119 ii l
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PREFACE This report is supplied as part of the " Program for Evaluating Licensee / Applicant- Conformance to R31.37," 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 Tt nical Assistance Unit.
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1 CONTENTS i
I 1
SUMMARY
.............................................................. ii
- PREFACE .............................................................. iii
- 1. INTRODUCTION .................................................... I
- 2. REVIEW REQUIREMENTS ............................................. 2 4
- 3. EVALUATION ...................................................... 4 3.1 Adherence to Regulatory Guide 1.97 ......................... 4 3.2 Type A Variables ........................................... 4 3.3 Exceptions to Regulatory Guide 1.97 ........................ 5
- 4. CONCLUSIONS ..................................................... 27 5.- REFERENCES ...................................................... 28 iv
CONFORMANCE TO REGULATORY GUIDE 1.97:' plLGRIM
- l. 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 licensos, and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency response capability. These requirements have been published as Supplement No I to NUREG-0737, "THI Action Plan Requirements" (Reference 3).
The Boston Edison Company, the licensee for the Pilgrim Nuclear Power Station, provided a ' response to Section 6.2 of the generic letter on November, 1, 1984 (Reference 4). This submittal addresses Revision 3 of Regulatory Guide 1.97 (Reference 5). The licensee provided additional information on February 10, 1987 (Reference 6), April 11, 1989 (Reference 7), January ll, 1990 (Reference 8), and January 15, 1990 (Reference 9). On April 5, 1990, the licensee provided an updated response to the compliance issues related to Regulatory Guide 1.97 (Reference 10).
Reference 10 superseded the previous submittals.
This report, based on the recommendations of Regulatory Guide 1.97, Revision 3, compares the instrumentation proposed by the licensee's submittals with these recommendations.
1
- 2. _ REVIEW REQUIREMENTS .
Item 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. ,
,l. . instrument range
- 2. environmental qualification -
3._ seismic qualification '
- 4. quality assurance 5.. redundance and sensor location
- 6. power-supply
- 7. location of display
- 8. schedule of installation or upgrade The submittals should identify any deviations taken from the regulatery '
guide recommendations. 'They should also provide supporting justification or
' alternatives for the deviations identified.
After issuing the . generic letter, the NRC held regional meetings, in February and March 1983, to answer licensee and applicant _ questions and
- concerns regarding the NRC policy on this subject. _At these meetings, it was noted that the NRC review would- address only _the exceptions taken to Regulatory Guide 1.97. It was also noted that when licensees or applicants-
explicitly state that instrument systems conform to the regulatory guide, no _
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further staff. review would be necessary. Therefore, this report addresses only those exceptions to Regulatory Guide 1.97 identified by the licensee.
The following evaluation is an audit of the licensee's submittals based on the review policy described in the NRC regional meetings.
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- 3. EVALUAi10N The licensee provided responses to item 6.2 of NRC Generic Letter 82-83 on November 1, 198a, February' 10, 1987, April 11, 1989, January ll, 1990,
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and January 15.- 1990. -A superseding submittal was made on April-5, 1990.
The responses describe the licensee's position on post accident monitoring instrumentation. This evaluation' compares the Reference 10 material,- .
supplemented by the earlier submittals, to the recommendations of Revision 3 of Regulatory Guide 1.97.
3.1 Adherence to Reculatory Guide 1.97 The licensee documented their review of the Pilgrim Nuclear Power Station post-accident monitoring instrumentation. The licensee's review compares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 3 (Reference 5). The licensee's report has three divisions; (a) instrumentation that meets the recommendations of-the regulatory guide, (b) instrumentation that the licensee will modify to meet the recommendations of the regulatory guide, and (c) instrumentation that
- the licensee has determined appropriate. The licensee committed to the modifications noted in their report. Therefore, we conclude that the licensee provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide noted in Section 3.3.
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. drywell atmosphere temperature
- 2. containment and drywell hydrogen concentration -
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- 3. fcentainment 'and drywell oxygen conr.entration 14 '. - primary containment pressure dr/well'
- 5. : primary containment pressure suppression pool
- 6. reactor' coolant system pressure i
- 7. coolant level in reactor vessel ,
8.- suppression-pool water level 94 suppression pool water temperature LThese variables, with exceptions as noted in Section 3.3, either meet or will = be upgraded toimeet the-Category I recommendations, consistent with the 3 requirements-for Type A variables.
3.3 Exceotions to Reaulatory Guide 1.97 -
~The licensee identified deviations and exceptions from Regulatory
- Guide'l.97.- The following paragraphs discuss these deviations and exceptions.
-3.3.1 Seismic =Oualification Regulatory Guide 1.97 recommends seismic qualification .for Category 1
' instrumentation. -The licensee identified the-following' Category _1 variables -
that needed moreLinformation before they could document-them.as meeting the-requirements of Regulatory Guide 1.97. We note that seismic qualification' for Category 2 instrumentation is optional.
- 1. - neutron flux-
- 2. coolant level in reactor p 5-l '
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- 3. reactor coolant systeQ (RCS) pressure.
4.- :drywell pressure 5._ -primary containment pressure .
0, primary cantainment isolation valve position ,
7.- containment and drywell hydrogan concentration 8.- cont i t. nt and drywell oxygen concentration
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- 9. drywell atmosphere temperature I
In Reference-7, the licensee discusses the seismic design and qualification criteria from the time of original plant design up to the
.present requirement lof IEEE Std 344 1975. Based on the licensee's statement that the applicable seismic- specifications are applied to the Category 1 i
instrt'entation,_.we find the licensee's instrumentation acc"< table in
-meeting-the~ seismic qualification requirements as discussed in the NRC regional' meetings.
In References 9 and 10, the licensee-provides additional clarification 1 on seismic 1 qualification. The licensee reviewed all Categnry 1 instrumentation and any Category'2 instruments _that are part of a-
-safety related system. - The evaluation classified the instrumentation as acceptable .for seismic qualification if either of the' following conditions exists. The licensee considers the instrumentation seismically qualified if purchased ad installed under-IEEE Standard 344-1975 and auditable qualification documentation exists. The licensee also considers the
--instrumentation scismically;oualified if it meets the requirements of IEEE i Standard-344-1987, Sectior. 9,." Experience," and the " Seismic Qualification '
-Utility Group Generic Implementation Procedure," Revision _l, dated
( November,1988. . Seismically qualified equipment is.being installed for .
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Category 1 modifications. We find the licensee's description of their seismic qualification program acceptable.
3.3.2 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee's existing instrumentation is not Category'1. The licensee proposed, in Reference 7, to base their position on neutron flux monitoring on the BWR Owners Group Regulatory Guide 1.97 subcommittee topical report for neutron flux instrumentation.
Regulatory Guide 1.97 reccmmends Category 1 neutron flux monitering instrumentation to monitor reactivity control during post-accident situations. The regulatory guide specifies neutron flux as the key variable for determining ',he accomplishment of reactivity control, it is a key variable because it is a direct measurement and not an indirect or lagging indication. The regulatory guide specifically states that Category 1 instrumentation should meet the environmental qualification requirements of 10 CFR 50.49, 10 CFR 50.49 explicitly references Regulatory Guide 1.97, requiring environmental qualification of all Category 1 instrumentation.
Initiating and post-reactor shutdown everts could involve environmental conditions that are more extreme than the conditions considered for the existing neutron flux instrumentation. Neutron flux instrumentation supplied for monitoring post-accident conditions should, accordirg 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 (detectors) must be reliably in place immediately after initial shutdown, and be fully operable for an exter.ded period, i.e., in the order of sixty days. following an accident.
In Reference 10, the licensee states that they have started a project to install neutron flux instrumentation that complies with the recommendations of Regulatory Guide 1.97. We find this commitment acceptable. We also conclude that the existing instrumentation is acceptable for interim operation.
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3.3.3 Reactor Coolant System (RCS1 Soluble Boron Concentration Regulatory Guide 1.97 recomends-instrumentation for this variable with a range from zer3 to 1000 parts per million. The licensee states that they '
use the post accident sampling system for this variable. As the post accident sampling system has this capability, we find this deviation acceptable.
3.3.4 Coolant Level in Reactor Regulatory Guide 1.97 recomends instrumentation for this variable with a range from the bottom of the core support plate to the lesser of the top of the vessel or the centerline of the main steamline. The licensee states that this range recomendation is equivalent to 186 inches to 604 inches above vessel bottom.
The licensee utilizes twc sets of Category 1 instrumentation with overlapping ranges. They cover from 205-inchs to 505 inches and from 432 inches to 532 inches. The licensee states that this combined range encompasses all automatic and manual safety actions for accident and post accident conditions. Further, the licensee states that this range encompasses the active fuel and includes the high level trip setpoint of the emergency core cooling system.
Based on these considerationte-we find the level range provided acceptable. [
3.3.5 RCS Pressure ,
Regulatory Guide 1.97 recomends Category 1 instrumentation for this variable. Thus, the instrumentation should have at least two independent and redundant channels. Both redundant transmitters described in '
Reference 4 share'the same vital instrument bus, Y2, as their power source.
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Additionally, both channels share a two channel recorder.
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In Reference 6, the licensee outlined plans to provide redundant power sources from vital buses Y3 and Y4, and independent recordi-] and indication for the two channelt. Reference 10 indicates that these modifications are complete.
- 3.3.6 Drywell Sumo level Drywell Drains Sumo level Regulatory Guide 1.97 recommends Category 1 instrumentation for these variables. The licensee has supplied Category 3 instrumentation for these variables. The dryvell sump systems isolate automatically at the primary containment penetration should an accident signal octur.
We conclude that the instrumentation supplied by the licensee will provide the appropriate monitoring of the parameters of concern. This conclusion is based on the following.
- 1. For small leats, 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 drain liner isolate due to the increase in drywell pressure, thus negating the drywell sump level and drywell drains sump level instrumentation.
- 3. This instrumentation neither automatically starts nor alerts the operator to start operation of a safety rolated system in a o post accident situation.
Therefore, we find the urovided Category 3 instrumentation acceptable.
3.3.7 Primary Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category 1 position indication for these valves. The licensee's position indication for containment isolation valves meets these recommendations except as described below.
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The core spray to reactor lines, residual heat removal (RHR) to drywell spray lines, the RHR to suppression pool, spray lines, and low pressure coolant injection lines all have redundant isolation valves. The licensee provides redundant safety systems. The lines are redundant and train oriented. Therefore, each redundant line has two valves and associated ,
indication and controls powered from the same power source. The regulatory guide does not require redundant indicating channels within a division of a '
boiling water reactor safety system. Therefore, the indication for these valves is acceptable. Similarly, we find the indication for the valves in the post-accident sampling system acceptable.
CV 5046 is a normally closed remote operated manual value. It controls the air supply to the drywell to torus vacuum breakers, in Reference 10, the licensee discusses administrative controls that prevent this valve from opening inadvertently. With these administrative controls, the exclusion of this valve from this regulatory guide recommendation is acceptable.
Position switches ZS6000 and 258001 control the valves that isolate the torus makeup line from the condensate storage tank. These control switches and their position indication are locally mounted in the residual heat removal (RHR) and core spray pump room "B,' a potentially harsh environment. The power source and cabling for these two valves are not independent and redundant. The licensee states that these valves, indications, and controls are not safety related. These valves are norcally closed during power operation. A containment isolation signal does not close them. Because of the application of these valves and the administrative controls applied to these manually-operated valves, we determine that the deviations for these valves are acceptable.
The licensee does not consider the 580 control rod drive directional control valves part of this variable. These valves do not have position indication. These valves do not receive an automatic isolation signal. The valves are closed except when normal rod movement occurs. A scram does not ,
require the use of these valves. They are not used in the post accident situation. Based on this justificatien, we find the lack of position ~
indication for these valves acceptable.
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From the information provided, we find that the licensee deviates from a strict interpretation of the Category I redundancy recommendation. Only the active valves have position indication (i.e., check valves have no position indication or there is only a single isolation valve in a closed s
loop). Since the design uses redundant isolation valves, we find that the regulatory guide does not intend redundant indication per valve. Position indication of check valves is specifically excluded by Table 2 of Regulatory Guide 1.97. Therefore, we find the instrumentation for this variable acceptable. This applies to the following valves used with check valves: .
M0 1201 80, MD 1301 49, M0 2301 8, A0 5033A, A0 5033C. A0 5040A, A0 50408.
MO 1001 28A, MO 1001 28B, M0 1001 29A, .nd MO 1001 29B. It also applies to MO 4002, located on a closed cooling water line that penetrates the primary containment boundary.
Valves M0100160 and M010016S are shut and electrically incapacitated by administrative controls during operation. Since these valves cannot then change position, excluding them from having position indication is acceptable.
There are twelve valves that connect the torus to outside systems, the residual heat removal system, reactor core isolation cooling system, high pressure coolant injection system, and core spray system. The licensee states that these lines terminate below the suppression pool water level.
Because of this design. rn gaseous release path exists. Accident recovery ,
procedures require the use of these flow paths. Because of this, their exclusion fiom the regulatory guide recommendation is acceptable.
Residual heat removal system valves M0100121 and M0100132 receive primary containment isolation signals to assume their position. However, they are not containment isolation valves. Therefore, the exclusion of
. these valves from the regulatory guide recommendations is acceptable, The guide tube ball valves in the TIP system are normally closed, fail closed valves that are open only when the TIP system is in use. The position indication circuits for valves 736A, 736B, 736C, 736D, 737A, 7378, 7370, and 7370 are Category 3. The TIP system is nonsafety related, and 11
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p, M6 r.t iv de containment atmosphere or reactor coolant outside of f
-c m .t.:ints The operator, in atter. dance when these valves are open,
- f. U M El,ates the redundant squib actuated shear valve should the ball valve not indicate isolation when required. Based on this, we find this deviation ecceptable. -
In Table 2 of Reference 9, the licensee lists additional valves with .
environmental qualification as an open item. The environmental qualification rule,10 CFR 50.49, clarifies the requirements. The valve position indication limit switches and associated cables should be environmentally qualified in accordance with 10 CFR 50.49 and Regulatory Guide 1.97.
3.3.8 Radiation level in Circulatina Primary Coolant The licensee indicates that the post. accident sampling system provides
. radiation level measurements to indicate fuel cladding failure in the post accident condition. The post accident sampling system was reviewed and approved by the NRC as part of their review of NUREG 0737, item !!.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.
3.3.9 . Containment and Drvwell Hvdroaen Concentration Regulatory Guide 1.97 recommends instrumentation for this variable with a range from zero to 30 percent. The licensee's instrumentation has a range of zero to 10 percent. The licensee statcs that this range is sufficient because it meets the requirements of item !!.F.1.6 of NUREG 0737.
The NRC reviewed and approved this instrumentation as part of their review of NUREG 0737, item !!.F.1.6, finding it acceptable. We find this to be a good faith attempt-[as defined in NUREG 0737, Supplement No. 1.
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Section3.7(Reference 3))tomeetNRCrequirements. Therefore, this l instrumentation is acceptable, j 3.3.10 Containment and Drywell Oxvoen Concentration i
- Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. Category 1 criteria include Class 1E power sources for this instrumentation. The licensee indicates, in Reference 4, that this instrumentation does not comply with this requirement. .
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in Reference 6, the licensee states that independent, redundant Class 1Epowersources(bothonsiteandoffsitepower)supplytheredundant i channels of this instrumentation. Based on this re examination of the power !
sources for this instrumentation, we find the instrumentation provided for ;
- this variable acceptable.
3.3.11 Effluent Radioactivity Regulatory Guide 1.97 recommends Category 2 instrumentation for this 1
' i variable with a_ range of 10 6 pCi/cc to 103 pCi/cc.. Ti'e licensee indicates that the instrumentation does not satisfy the range and environmental f qualification recommendations. The ranges identified in Reference 6 are, i
Main Stack 1.2 x 10 5 pCi/cc to 9.9 x 10 pCi/cc 3
Reactor Building Vent .l.5 x 10 6 pCi/cc to 2.1 x 103'pCi/cc ^
Turbine Building Vent 1.7 x 10*3 pCi/cc to 1.7 x 102 pct /cc Reference '6 indicates that the turbine building vent has no normal effluents. thus .it does not have an overlapping low range monitor. Normally ;
used instrumentation monitors the other two release points. Thus, this t instrumentation is on scale for normal and accident situations. Based on
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. these discussions, we.-find the. ranges acceptable.
Reference 6 indicates that Class IE power supplies this instrumentation.
This satisfies the power supply requirements.
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6 In Reference 8, the licensee describes modifications made under a
.long-ters schedule for the completion of the Regulatnry Guide 1.97 q modifications. The main stack and reactor building vent stack effluent monitors will have shielding installed. This shielding keeps the monitors I in a mild environment. Cables that pass through potentially harsh -
environments will have those portions replaced with environmentally qualified cable. The turbine building effluent monitor will have ,
environmental qualification upgrades under the same schedule.
l Based on the licensee's description of instrumentation and commitments to upgrade this instrumentation, we find the provided instrumentation acceptable.
3.3.12 Condensate Storaae Tank level Regulatory Guide 1.97 recomends instrumentation for this variable with a range from the top to the bottom. The licensee, in Reference 4, indicated that this instrumentation does not meet the recommended range. The licensee did not . identify the actual range and the extent of the deviation.
in Reference 6, the licensee identifies the range as zero to 40 feet .
and states that corresponds to the bottom to the top of the tank range recommended. Therefore, the range provided is acceptable.
3,3.13 Drywell Atmosobere Temocrature The licensee identifies this as a Type A variable. Thus, Regulatory l Guide 1.97 recommends Category 1 instrumentation with a range of 40*F to I 440'F. Category I criteria include environmental qualification. The ,
- licensee indicates that the provided instrument range is zero to 400'F.
The Final Safety Analysis Report identifies a peak post-accident temperature of 340'F (as described in the emergency operating procedures). Because of' this temperature limit, we find the provided range acceptable.
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L l in Reference 7, the licentee states that this instrumentatico is ;
completely redundant and independent, including power sources, with full !
separation and isolation provided. Based on the licensee's description of the drywell' atmosphere temperature instrumentation, we find the described !
instrumentation characteristics acceptable in meeting the Category 1 l recommendations of Regulatory Guide 1.97. However, Reference 10 lists the environmental qualification of the instrumentation as an open item, with additional work identified to meet the environmental qualification rule (10 CFR 50.49) requirements. We conclude that the licensee has committed to provide the appropriate documentation that will verify the environmental qualification of this instrumentation.
3.3.14 Drywell Soray Flow Regulatory Guide 1.97 recommends: Category 2 instrumentation for this -
variable. The' regulatory guide recommends a range of zero to 110 percent of design flow'. The licensee does not provide a direct measure for this.
variable. The residual heat removal (RHR) flow elements monitor the drywell ,
spray flow. This e.lement is common to the drywell spray: flow, the -
suppression chamber spray flow, the low pressure coolant' injection system i flow, and the suppression chamber cooling lines. The' operator can determine that the drywell spray-is obtaining flow from the RHR system by observing the position of the RHR system valves. The operator operates these valves manually from the control room. The position of these valves is monitored in the control room on Category 1 position indication. -The operator can t verify the effectiveness of this spray with pressure.and temperature changes in the primt.ry containment. The pressure and temperature instrumentation for the drywell have Category 1 instrumentation in the control room.
We find that the instrumentation described above will provide adequate
- indication for this
- variabic. Therefore, this instrumentation is ,
- acceptable.
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3.3.15 Main Steamline Isolation Valves' Leakaae Control System Pressure .
Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee States that Pilgrim 1 has no leakage control system on the main steamline isolation valves. Therefore, no instrumentation for .
this variable is required.
3.3.16 Reactor Core Isolation Coolina (RCIC)_ tvstem Flow Coolina Water Flow to_Inainegred Saft.tv Feature System comoonents Regulatory Guide 1.97 recommends environmentally qualified instrumentation for these variables with ranges from zero to 110 percent of design flow. The licensee identifies a deviation from the environmental qualification recommendation and the range. Reference 4 did not. identify the extent of the deviation.
Reference 6 shows that the ranges provided exceed the recommended ranges. For RCIC flow, the range provided is zero to 500 gallons per minute. For cooling water flow, the range provided is zero to 3000 gallons per minute. The range satisfy the regulatory guide, in lieu of environmenta'ly qualified RCIC syst6m flow, the licensee has proposed the use of reactor pressure vessel (PRV) water level monitors. The RPV water level instrumentation is Category 1. In lieu of environmentally qualified cooling water flow to engineered safety features system components, the licensee has proposed the use of-primary containment pressure, RPV water level, and torus water temperature monitors. These variables have Category 1 instrume . ion. The licensee also states that the RPV water level monitors the performance of the low pressure coolant injection system.
The RPV water level- will not conclusively show that the RCIC system or the reactor building closed cooling water system are operating within each- .
system's design limits. Similarly, primary containment pressure and torus t 16
1 water temperature do not show conclusively that the reactor building closed l cooling water system is operating within its design limits. >
Reference 10 lists the environmental qualification of the RCIC flow and
, cooling water flow to engineered safety features system components as an '
- open item, with additional work-identified to meet the environmental qualification rule (10 CFR 50.49) requirements. We conclude that the licensee has committed to provide the appropriate documentation that will verify the environmental qualification of this instrumentation. .
3.5.17 Standbv Liouid Control System (SLCS) Flow ,
Regulatory Guide 1.97 recommends Category 2 flow instrumentation for this variable. _The licensee does not monitor flow, instead, there is i
Category 3 SLCS pump discharge header pressure indication. The pump discharge pressure indicator has a range of zero to 2000 psig. The ,
- instrumentation is used in a mild environment. The system design pressure is 1.500 psig. All SLCS valves, except check valves and the electrically I
detonate' squib valves, are open and locked in that position during reactor operation. The operator can also _ verify system operation by monitoring the decrease in _the SLCS storage tank level.
The_ licensee uses positive displacement pumps for the SLCS. Thus, high output pressure would indicate flow blockage and low or erratic pressure would indicate a line break. We find the above indications are a valid alternative indication of SLCS operation.
3.3.18 Standby Liouid Control System Storaae Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation- for this
. variable, in Reference 9, the licensee states that the range of the provided' Category 3. instrumentation is from zero-(essentially empty) to
. 4,750 gallons. The licensee states, in Reference 6, that the range covers the range recommended by General Electric (the nuclear steam supply system 17 1
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vendor). This recommended range is 9 inches to 121.25 inches. The proviued range also covers the technical specification required levels. Nine inches is essentially the bottom of the tank.
Based on the licensee's justification, we find the range provided acceptable. The licensee states that Category 3 instrumentation is appropriate because the SLCS has less importance to safety than the reactor -
protection system and the engineered safeguards system. We understand that when in use, this instrumentation is in a mild environment.
Also in Reference 6, the licensee identified the power source for this instrumentation. The power source is a highly reliable instrument bus that is appropriate for this variable. Based on the licensee's description, we find the provided instrumentation acceptable.
3.3.19 ((ich Radioactivity liauid Tank level Regulatory Guide 1.97 recommends instrumentation fo* this variable with a range from top to the bottom of the tank. The licensee, in Reference 4, identified a possible deviation from this recommendation. In Reference 6, the licensee identified the range as zero to 144 inches, which meets the recommendations for level measurement in the 12 foot high radwaste tank.
Thus, the provided instrumentation is acceptable.
3.3.20 Status of Standby Power Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable, with plant specific ranges. Category 2 criteria includes environmental qualification. The licensee identified the instrument ranges in Reference 7. Reference 8 states that the instrumentation is in both mild and potentially harsh post accident environments. The licensee states that
, upgrades to the instrumentation and supporting equipment will include '
environmental qualification for the post accident environment. The modifications are scheduled under the long term schedule for completion of the Regulatory Guide 1.97 project. We find this commitment acceptable. -
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3.3.21 Secondary Containment Area Radiation v
- The licensee states that they do not need the instrumentation for this variable. The licensee states that the plant noble gas effluent monitors .
are more useful and practical in detecting or assessing primary containment l leakage. The licensee reports that the use of local radiation exposure rate monitors to detect breach or leakage through primary containment
' penetrations results in ambiguous indications. This is due to the radioactivity in the primary containment, the radioactivity in the fluids flowing in emergency core coolant system piping, and the amount and the location of fluid and electrical penetrations. The licensee concludes that the use of the plant noble gas effluent monitors is the proper way to accomplish the purpose of this variable.
1 We concur with the licensee that the use of the noble gas effluent ,
monitors for this variable is acceptable.
1 3.3.22 Particulates and Halocens-- All Identified Release Points Airborne Radiohaloaens and Particulates Plant and Environs Radiation Plant and Environs Radioactivity Regulatory Guide 1.97 recc:'unends Category 3 instrumentation for these
-variables. The licensee had not provided the information required by Section 6.2 of Supplement No. I to NUREG 0737 for these variables in Reference 4. ,
in Reference 6, the licensee provided information on this instrumentation. The licensee stated that the provided instrumentation meets the intent of the regulatory guide. As described, we find that the release points have appropriate monitoring instrumentation for particulates and halogens,.wlth the possible exception of the range. In Reference 9 the-licensee described the use of a multi-channel analyzer, radiation survey meters, procedures and analytical tools, including nomograms, that, l
l L 19 l
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i together, measure particulates and halogens for airborne radionuclide concentrations. The measurement capability is from 10*I2 #Ci/cc to
. 3.5 x 10 4.pCi/cc. This encompasses the range recomended by the regulatory guide. Air sampling stations continutusly monitor the plant and environs.
I In Reference 7, the licensee identified the capability of their multichannel .
analyzer and portable instrumentation and sampling. In Reference 9, the licensee demonstrates that the capability of the analyzer is greater than ,
I the range recommended by the regulatory guide. However, the range is somewhat dependent on the radionuclides analyzed.
The licensee describes a deviation from the recommendations in that the j his range radiation survey instruments measure up to 103 R/hr rather than 4
the recommended 10 R/hr. Administrative restraints would prevent entry into areas where radiation levels could cause excessive personnel exposure.
. Therefore, we find the range for this portable instrumentation adequate and 4 acceptable. Based on-the licensee's description of these variables, and the noted devidtion, we find the instrumentation pro /ided for these variables acceptable.
1 3.3.23 -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 dissolved gas. For dissolved gas, the recommended range is zero to 2000 cc/kg. The range provided is zero to 400 cc/kg. .l The licensee deviates from the recommended Regulatory Guide 1.97 post accident sampling capability. The NRC has reviewed and approved the licensee's post-accident sampling facility as part of their review of NUREG 0737, Item II.B.3.
3.3.24' Instrumentation not Aeolicable at the pilarim Nuclear Station 4
Regulatory Guih 1.97 recommends instrumentation that is not applicable to the Pilgrim Nuclear Station. Section 6.lb of Supplement No. I to -
20
.NUREG 0737 excludes the variable BWR core temperature.- Therefore, no instrumentation is required for this variable.
The Pilgrim Nuclear Station does not have an isolation condenser.
Therefore, no instrumentation for the variables isolation condenser shell side water level and isolation condenser system valve position is required.
3.3.25 Sueoression Chamber Soray Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The regulatory guide recommends a range of zero to 110 percent of the design flow. The licensee does not provide a direct measure for-this variable. The residual heat removal (RHR) flow element monitors the suppression chamber spray flow. This element is common to the drywell spray flow, the suppression chamber spray flow, the low pressure coolant injection system flow, and the suppression chamber cogling lines. Ths spirator c%
determine that the suppression chamber spray is receiving tha iAlcat'ed flow by observing the position of the RHR system valves. The o p tior controls these valves manually from the control room. Category 1 position indication in the control room monitors the position of these valves. Temperature changes in the suppression chamber show the effectiveness of this flow. The pressure instrumentation for the suppression chamber meets Category 1 criteria.
\
We find that the instrumentation described above will provide adequate indication for this variable. Therefore, this instrumentation is acceptable.
3.3.26 Low pegssure Coolant Iniection System Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this l variable. The regulatory guide recommends a range of zero to 110 percent of
- the design flow. The low pressure coolant injection (LPCI) system is a subsystem of the RHR system. The RHR flow element is common to the drywell 21
spray flow, the suppression chamber spray flow, the LPCI system flow, and .
the suppression chamber cooling lines. The operator can determine that the JCI has flow by observing the positian of the LPCI injection valves. The operator monitors the posl tion of these valves in the control room by observing Category 1 position indication. The range of the flow .
instrumentation is zero to 20,000 gallons per ininute. This range exceeds the zero to 15,840 gallons per minute design flow by 26.3 percent. ,
We find that the instrumentation described above will provide adequate indication for this variable. Therefore, this instrumentation is acceptable.
3.3.27 Radiation Excesure Rate Regulatory Guide 1.97 recommends instrumentation with a range of 10*l R/hr to 104 R/hr for this variable. The licensee's instrumentation has a range of 10 5 R/hr to 10*I R/hr. The licensee states that they can supplement the permanently installed instrumentation with portable instrumentation. Personnel use the portable instrumentation to survey areas required for servicing equipment important to safety. Stated personnel exposure limits are 25 R for health, safety, and property protection, and 75 R for life saving. The licensee states that personnel observe these limits.
From a radiological standpoint, personnel would not enter the monitored areas without portable monitoring if the radiation levels reached or exceeded the upper limit of the provided instrumentation. Based on the alternative instrumentation used to supplement the instrumentation installed for this variable, we find the range for the radiation exposure rate monitors acceptable.
3.3.28 Redundancy and Seoaration Regulatory Guide 1.97 recommends protecting Category 1 instrument channels against potential single failures by applying the redundancy and ,
22
a .
i l
sepwation crdteria of Regulatory Guide 1.75 up to and including any ;
isolatior devices. The Pilgrim Nuclear Station was designed and constructed
. wfore the guidance of Regulatory Guide 1.75 was available, '
Tha licensee states that the redundancy and separation of Category 1 instrumentation meets or exceeds the definition established by Boston Edison j specification E 347, Section 5.4, Boston Edison specification E 347A, Sectiors 5.2.3 and S.2.4, and the final Safety Analysis Report, [
Section 8.9.3. The licensee describes minimum horizontal and vertical -
i separation.. Where the prescribed separation is not possible, the licensee
$pecifies barriers. The licensee describes the minimum separation distance for Class lE enclosed raceways. The licensee states they provide a barrier qutlified to IEEE Standard 384 1974 should wiring separation for redundant ,
circuits internal to a control panel be impossible. We find this to be a good faith attempt [as defined in NUREG 0737, Supplement No. 1 Section 3.7 (Reference 3)] to meet NRC requirements. Therefore, the redundancy and :
i separ6 tion is acceptable for those Category 1 variables not otherwise t
upgraded to meet Regulatory Guide 1.97 recommendations. This deviation does not. preclude the use of redundant (i.e., two or more) channels of instrumentation for Category 1 or Type A vsriables. [
The licensee has scheduled some modifications to bring Category 1 instrumentation into compliance with aspects of Regulatory Guide 1.97, in ,
these instances, the licensee should provide the redundancy and separation ~
recommended by the regulatory guide for those portions of the :
instrumentation upgraded.
3.3.29 Interfaces Section 9 of Table 1 of Regulatory Guide l.97 recommends the use of
. qualified isolation devices wherever Category I or Category 2 ,
instrumentation interface with instrumentation or control circuits that have [
less stringent design criteria. The licensee has no: described any isolation devices other than " coordinated Class IE fuses or breakers." The ;
licensee has not described any isolation amplifiers. ,
23
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m The Regulatory Guide 1.97 recommendation for isolation devices is 'the '
transmission of signals for other use should be through isolation devices that are designated as part of the monitoring instrumentation and that meet the provisions of this document."
The licensee has not identified which of the Category 1 and Category 2 instrument signals are diverted to "other use.' Therefore, we are not able -
to conclude that the licensee has met the regulatory guide provision for interfaces. The licensee should ensure that c;aalified isolation devices are used to protect Category I and Category 2 instrumentation. Documentation of isolation device usage for Category 1 and Category 2 instrumentation should be available for NRC audit during the Regulatory Guide 1.97 implementation inspection.
3.3.30 Environmental Dualification Regulatory Guide 1.97 recommends environmentally qualified instrumentation for Category 1 and Category 2 variables. Reference 9 lists variables for which the licensee has not addressed environmental qualification. The licensee listed the following Regulatory Guide 1.97 Category 1 and Category 2 variables open regarding environmental qualification, with additional work identified to meet the environmental qualification rule (10 CFR 50.49) requirements. The following variables are not discussed elsewhere in this report.
primary system safety relief valve position
. core spray system flow residual heat removal (RHR) system flow
. RHR heat exchanger' outlet temperature 4
24
+
. cooling water temper *e to engineered safety features system components
- emergency ventilation damper position
- . noble gases and vent flow rate for common plant vent de conclude that the licensee has committed to provide the appropriate documentation that will verify the environmental qualification of this instrumentation.
3.3.31 Recordina Table 1 of Revision 3 of Regulatory Guide 1.97 contkins specific criteria regarding recording. The licensee should record at least one ch.annel of Category I variables. The licensee should record the effluent ,
radioactivity monitort, area radiation monitors, and meteorological mor..cors. Recoroing may be by computer with display on demand if continuously updated. Likewise, data loggers and multipoint recorders are suitable if no significant transient response data would be lost by using them. If direct and immediate trend or transient information is essential for operator information or action, continuous, redundant, dedicated recorders shuuld be provided.
The licensee has not addressed this provision of Regulatory Guide 1.97. The licensee should ensure that recording is provided in accordance with Regulatory Guide 1.97 criteria. Documentation of recording capabilities should be available for NRC audit during the Regulatory 1.97 implementation inspection, 3.3.32 Channel Availabilliy Regulatory Guide 1.97 recommends, for Category 1 instrumentation, that the instrument channels be available before an accident except as provided 25
t' i
in paragraph 4.11, " Exception," of IEEE Standard 279 1971, or as specified in technical specifications. For Category 2 instrumentation, Regulatory Guide 1.91 recommends that the out of service intervals be based on normal f technical specification requirements on out of service intervals for the l system it services or as specified in other requirements.
r In Reference 10, the licensee lists this as an open item, yet to be .
addressed. The licensee should take steps to assure that their post accident monitoring instrumentation is available in accordance with the provisions of Regulatory Guide 1.97.
3.3.33 Ouality Assurance Regulatory Guide 1.97 recommends that the licensee's instrumentation be ,
' 4 part of a quality assurance program, with lesser requirements imposed on Category 2_ instruments, in Reference 10, the licensee lists this as an open item, yet to be addressed. The licensee should take steps to assure that their post accident monitoring instrumentation is part of a quality assurance program in accordance with the provisions of Regulatory Guide-1.97.
3.3.34 Servicina. Testina. and Calibration Regulatory Guide 1.97'contains specific recommendations for periodic <
checking, testing, calibration, and calibration verification that are based on the recommendations of Regulatory Guide 1.118.
In Reference 8. the-licensee lists this as an open item. yet to be addressed. The licensee should take :teps to assure that their post accident instrumentation is checked, tested, and calibrated under a
- surveillance program in accordance with Regulatory Guide 1.97 and Regulatory Guide 1.118.
l 26 l v
l' [
- 4. CONCLUSIONS r 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:
,' i
- 1. Redundancy and separation Any modifications to bring Category 1 or Type A instrumentation into compliance with Regulatory Guide 1.97 should include the redundancy and separation eecommended by the-regulatory guide for the modifications. See Section 3.3.28.- -
f
- 2. Interfaces The licensee should ens 9te that qualified isolation devices are used to protect Category 1 and Category 2 instrumentation. See Section 3.3.29.
- 3. Recording The licensee should ensure that recording is orovided in accordance with Regulatory Guide 1.97 criteria. See Section 3.3.31.
- 4. Channel availability -- The licensee should assure their instrumentation is available in accordance with the regulatory guide._ See Section 3.3.32.
- 5. Quality assurance -- The licensee should assure their instrumentation is part-of a quality assurance program in accordance with Regulatory Guide 1.97. - See Section 3.3.33.
- 6. Servicing, testing, and calibration - The licensee should assure their instrumentation is serviced, tested, and calibrated in accordance with Regulatory Guide 1.97 and Regulatory Guide 1.118.
See Section 3.3.34.
i.
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- 5. REFERENCES
- 1. Letter, NRC (D. G. Eisenhut) to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders o' Construction Permits, ,
"Supplerent 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 Durino and Followino an Accident, Regulatory G le 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
- 3. Clarification of TMl Action plan Reouirements. Reouirements for Emeroency Resoonse Caoability, NUREG 0737, Supplement No, 1, NRC, Office of Nuclear Reactor Regulation, J'auary 1983. .
- 4. Letter, Boston Edison Company (W. D. Harrington) to NRC (D. B. Vassalo), " Generic Letter 82 33: Regulatory Guide 1.97,*
November 1, 1984, letter #84 187.
- 5. Instrumentation for licht Water Cooled Nuclear Power Plant to Assess Plant and Environs Conditions Durino and Followino an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
- 6. Letter, Boston Edison Company (J. M. Lydon) to NRC, ' Additional Information Concerning Regulatory Guide 1.97," February 10, 1987, BEco 87 021. <
- 7. Letter, Boston Edison Compahy (R. G. Bird) to NRC, " Response to Request for Additional Information, Emergency Response Capability, Regulatory Guide 1.97, Revision 3, (TAC 51119)," April ll, 1989, BEco 89 053. .
28
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l I
Letter, Boston Edison Company (R. G. Bird) to NRC, ' Environmental !
B.
j Qualification of Instrumentation Monitoring Effluent Radioactivity and Status of Standby Power for Regulatory Guide 1.97, Revision 3 l (TAC 51119)," January 11, 1990, BEco 90 005. l t
9.- Letter.. Boston Edison Company (R. G. Bird) to NRC, " Summary of Compliance with Regulatory Guide 1.97, Revisiun 3, Concerning Emergency Response Capability (TAC 51119)," January 15, 1990, BECo 90 010.
- 10. Letter, Boston Edisor. Company (R.G. Bird) to NRC, ' Updated Summary of l Compliance with Regulatory Guide 1.97 Revision 3 (TAC 51119),"
April _5, 1990, BEco 90 049. ,
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- . tira . o nverita EGG-NTA.7047 CONFOIDENCE TO REGULATORY GUIDE 1.97: PILGRIM 3 o,n oi,o., v.us.io I
June 1990
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- 6. Ave,.onisi a tvet ce atoont Alan C. Ody Technical Evaluation Report- '
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Regulatory and Technical Assistance EGAG Idaho. Inc.
P.O. Box 1625 Idaho Falls. ID 83415
- e. ,spogago izatio . ..i a o mooains ..c. w. .,- -..c o . . 1 -
Division of Systems Technology Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comunission Washington, DC 20555 io.svara vai.taave.otis i t. A4&T m ACT <ser e w ==s This EG4G Idaho, Inc.. report documents the revie.# of the Regulatory Guide 1.97.
Revision 2, submittals for the Pilgrim Nuclear Power Station, and identifies areas of nonconformance to the regulatory guide. F,xceptica to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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