ML20090H700

Conformance to Reg Guide 1.97,Salem Nuclear Generating Station Units 1 & 2

ML20090H700
Person / Time
Site:	Salem
Issue date:	03/31/1983
From:	Udy A EG&G, INC.
To:	NRC
Shared Package
ML18092A179	List: ML20090H700
References
CON-FIN-A-6483, RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8404230353
Download: ML20090H700 (19)

Text

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CONFORMANCE TO REGULATORY GUIDE 1.97 SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2

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A. C. Udy Published March 1983~

EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Ccamission Washington, D.C. 20555 Under-DOE Contract No. DE-AC07-76ID01570 FIN No. A6483 i

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I CONFORMANCE-TO REGULATORY GUIDE 1.97

. SALEM NUCLEAR GENERATING STATICN. UNIT "g3. 1 AND ?

1. INTROCUCTION

_ .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, appitcants for

. .  ; P8F"tIU9, licenses and} holders of con,struction pe.rmy , Q his 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 pubitshed as Supplement 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).

The Public Service Electric and Gas Company, the licensee for the Salem Nuclear Generating Station, proviced a response to the generic letter-on April 15, 1983 (Reference 4). The ietter referred to a previous latter dated April 2, 1981-(Reference 5) for a review of the instrumentation-provided for-Regulatory Guide 1.97. The licensee provided additional information for this review in a letter dated -September. 21, 1983

-(Reference 6).

This report provides an evaluation of these submittals.

2. REVIEW REQUIREMENTS-

.Section 6.2 of NUREG-0737, Supplement '1, sets forthithe d,ocumentation

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to be-submitted infa. report to the N'RC describing'how the licensee meets'~ j the guidance of Regulatory Guide 1.97 asiapplied to emergency response facilities. The.suomittal should include documentation that provides the

'following information for each variable shown in.the applicable table of-Regulatory Guide 1.97.

I '. Instrurientirange a-

-2. ' Environmental?quali fication F

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3. Seismic cualification

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Quality assurahec

. 5 '. Redundance and sensor location

26. pcwer supply-

7. _ Location of display- .

3. Schedule of installation or ucgrade.

C acther, the submittal should identify deviations from the guidance in the Regulatory Guide and provide supporting justification or alternatives.

Subsequent to the issuan:e of the Genenic Letter, the NRC held

. ..f onal meetings in February and March 1933 to answer licensee and .

. acplicant questions and concerns regarding the NRC policy.on-this matter. -

1At these meetings, it was noted-that the NRC review would only address excectionsitaken to the guidance of Regulatory Guide .l.97. .Further, where licensees or applicants explicitly state that instrument systems' conform'to the provisions.of the Guide it was nated that no further staff review would be . nece s sa ry. :Therefore, this report only addresses exceptions to the.

uidance of Regulatory Guide 1.97. The following evaluation-is an audit of

ne licensee's submittals based on the review policy described in the NRC regional meetings.

3. EVALUATION The. licensee previded a response to the NRC Generic. Letter-82-33 on

. -i.1,15, 1983'. -This'respense referred'to an earlier' submittal of

.,;ef1 ~ 2,1931,; which described -the licensee's. position on post-accident.

monitoring' instrumentation. Additional information was providedDon.

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' itetember 21,1 1983. This evaluation is based on these'submittals.

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t 3.1 -Adherence to Regulatory Guide 1497,- A y m p p g .g The licensee stated that the guidance of Regulatory Guide 1.97 has -

been implemented as follows. Conformance includes instrumentation that meets the guidarice, and ins;rumentation that was added or modified to meet i the guidance. Exceptions on those items where a generic (to Westinghouse) issue remains to be resolved, instrumentation thn is not tully in compliance, but where the lic.ensee views it as appropriate hw the s ,, ,. . variable,.and items which,are not part of. the station., design wer,e noted.,

Therefore, it is concluded that the licensee has provided an explicit commitment on conformance to the guidance of Regulatory Guide 1.97, except for those exceptions that were justified as noted in Section 3.3.

3.2 Tyoe A Variables In that Regulatory Guide 1.97 does not specifically identify Type A variables i.e. , t':ose variables that provirie inform.ttien required for operator controlled safety actions, the licensee classified the following instrumentation channels as Type A variables.

1. Reactor coolant system hot leg water temperature

2. Reactor coolant system pressure ,

3. Degrees of subcooling 4 Containment pressure

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5. Effluent radioactivity--noble gas effluent from condenser air removal system exhaust

6. Refueling water storage tank level

7. Pressurizer level

8. Steam generator pressure ~ - ,

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10. Condensate storage tank water level

11. Steam generator blowdown radiation 3 All of the above variables, except number 11, are also included as Type B, C or D variables. All meet Category I requirements consistent with the

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3.3 Exceptions to-Regulatory Guide 1.97 The licensee identified the following exceptions to the requirements of Regulatory Guide 1.97.

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3.3.1 Neutron Flux The licensee has provided instrumentation for this variable that meets the Category 1 recommendations except that the detectors are not environmentally or seismically qualified as specified in the regulatory j

guide.

1 Environmental qualification has been clarified since Revision 2 of Regulatory Guide 1.97 was issued. The clarification is in the environmental qualification rule, 10 CFR 50.49. It is concluded that the l

guidance of Regulatory Guide 1.97 has been superseded by a regulatory

, requirement. Any exception to this rule is beyond the scope o,f this review ,,

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and should be addressed in accordance with 10 CFR 50.49.

The licensee has indicated that the detectors are not seismically qualified and that this item is an issue that is generic to Westinghouse neutron flux instrumentation. We find the licensee's justification'for -

this deviation unacceptable.

During the regional meetings;in February and March, 1983, the NRC

. indicated that the. seismic portion of, instrumentation qualificationFfor M 4

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Loperating reacters, should comply with-the seismic-qualification program which was the basis for planticensing. This requirnent is plant specific for cperating reactors and is not generic.

The ' licensee shculd. provide justificatica for this deviation -in tha form'of an analysis that shows the detectors conform to the seismic

qualification program, cr.previde a commitment to upgrade the detectors.

3i3.2' Reactor Coolant' System Cold Leo Water Temeerature ,

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The licensee has provided instrumentation for this variable that satisfies the recommendations of Regulatory' Guide 1.97 except the the range is 0* to 700*F rather than the 50* to 750*F recommended by Revision 2 of the' regulatory guide.

The licensee indicates that the ra.nge, supplied covers ~all accidents except where.the reactor coolant becomes superheated. Revision 3 of Regulatory Guide 1.97-(Reference ~7) reccmmends a range of 50* to 700 F, .

which is met by the supplied instrumentation.~ Therefore, there is no deviation from the current revision of.the regulatory guide.

3.3.3 -Reactor Coolant System Het Leo Water Temaerature >

The licensee.has provided' instrumentation for.this variable that satisfies the recommendations of Regulatory Guide .1.97. except .that the range is 0* to 700*F rather than the 50 ~to 750*F recommended by Revision 2 .

of the regulatory guide. _

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The licensee indicates that the range supplied-covers all accidents except where .the reactor coolant--becomes- superheated. ' Revision 3 of, the regulatory guide recommends a range.of 50' to 700*F,-which is. met by the -

supplied-instrumentation. Therefore, there is no deviation from the current revision of the' regulatory guide, c

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[ -3.3.4- Radiation Level in Circulatine primary Coolant i

. Regulatory Guica 1.97 rtcc. mends instrumentatien for thic <a ".ible i the detection of a breach. The licensee has not prcvided instrumencatien for snis variaole. There is, however, radiation monitoring en the letcown' ,

f' line. The letdown line is isolated with an accident and the monitor is '

then ineffective.

The licensee's post-accident sampling system can provide some ,  ;

information to compliment this variabie, hcwevar, it is not can;i9uous

cn-line instrumentation.

. Instrumentation that is suitable for this variable has been under t

! research and development. We find that use of the post-accident samoling I- system is acceptable on an interim basis, on the conditions that the

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licensee (a) commit to evaluate systems for.,the variable as they become ivailable and (b) commit to installation of a-satisfactory system within a reasonable time frame.

3.3.5 Radiation Excesure Rate i i The regulatory guide specifies a range of 10 -1 to 104 R/hr for this t

variable. The licensee has supplied instrumentation for this variable in

. ' lait 2 that has a range of 1 to 107 R/hr. 'While the upper. limit'ef the-i supplied range is inclusive of the reccmmended range, the lower. limit is -

not, i~ =

l The licensee has not justified this deviation. Further, they state f'

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nattnis.instrumentatienwill.netbeinstailedin ni t' 1=. We f.ind beth of these positions unacceptable. The . licensee should provide justification showing'why these deviations are acceptable, or commit to ccmplying to the .

Regulatory Guide recer.mendations for the variable within a reasonable time frame.

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i 3.3.6 Effluent Radicactivity-Nobie Gases From s.iac.rical ud Mechanical i pre t-a .t on arais ind F"*1 Ho dline %ildir',q  !

i Tha l'censee has not provided instrumentation for thi. variable, nor

. provided .he ju.itif ten.lon for not sus,1yha thia i n s t.'umernat ion . The  :

licensee chould provide satisfactory justification showing why this exceptian i ac:optable, or commit to complying to the Regultury Guide recommendations for this variable within a reasonablo ties feso.

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3.3.7 Residual Heat Removal Heat Exch'ancer Outl'et Temoer'ature The licensee f adicates that the instrumentation for this variable has no seismic or environmental qualification test data available. Our review of the requirements of Regulatory Guide 1.97 for Category 2 instrumentatien shows that seismic qualification is not required.

Environmental qualification has be n subsequently clarified by the environmental qualification rule, 10 CFR 50.49. It is concluded that the ,

1 guidance of Regulatory Guide 1.97 has been superseded by a regulatory f requirement. Any exception'to this rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.

3.3.8 Accumulator Tank Level i

4 i Regulatory Guide 1.97 reccmmends a range for this variable of 10 to 90!; of volume. The licensee has supplied instrumentation for this variable ,

j that covers a range of 52.65 to 70.29*; of volume. The licensee's ,

justification for this deviation is that the present range is needed to *

• meet the instrument accurccies required by technical specifications. We find the licenne's justificatio.n for this deviation unacceptable.

The tecanical specifications provide the limiting conditiens for operation and; surveillance requirements for system variables (volumes, '

pressures, levels, temperatures and etc.) that are required te,be ,

operational and available for pre-accident conditions,. The technical specificatt'ons do-not' identify specific instrumentation ranges;that must be 7

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I available in : cst-accicent c:nditi:ns. The licensee shculd crovice an analys*s that shows his ex' sting 1::umulater 'a.e: instrumer:stien will I adecuately c:ver the maximum expe:ted rarge,. Or previce instrumentation I with the range rec:mmenced by Regulat:ry Guide 1.!7.

1 3.3.9 Refueline Water Stocace Tank Level i

The licensee has supplied instrumentation for this variable that covers a range of 2.5 to 45.24 ft of the 48 ft tank height. The regulatory

. guide s:eci'ies a scan of ::1 to bett::. The licensee indicates that the tank overflew is at 45.24 ft. Therefore, the u;per limit of the span is the affective tcp of tne tank. We were unable to determine where 2.5 ft is in relation to the tank discharge to the emergency ccre ecoling pump -

, suction. The licensee states that the range "adecuttely ccvers" the technical specification requirement. We find the licensee justification for this deviation unacceptable. .

l The technical specifications provide the limiting conditions for cperation and surveillance requirements fer system variables (volumes,

pressures, levels, temperatures and etc.) that are required to be cperational anc availacle for pre-accident conditiens. The technical '

4 specifications do not identify specific instrumentation ranges that must be available in post-accident condittens. The licensee should provide an analysis that shows his existing refueling water storage tank level h instrumentation will adequately cover the maximum expected range, or provide instrumentation with the range recommended by Regulatory Guide 1.97. -

3.3.10 Pressuri:er level l

4 The licensee has supplied instrumentation for this variable with a ungt of 3 ft 4 in, tc 47 ft. 2 in. Regulatory Guide 1.97 specifies a 4

range of top to bottem. The Itcensee justifies the deviation in the range requirerents by saying it is needed to meet the technical scocification recuire ents. Cur review cf the FSAR (Ref taence 7) shcws that if the water were at tne 3 ft. 4 in. level, the pressurt:er heaters would to partially i uncovered. If the water Itvel is much abcve 47 ft. 2 in, the safety and I 8

- > i relief valve no::les could have water in them. Neither c:ndition is desirable, but could cccur during an accident. The lic1nsee nts not demonstrated tht the range aderately covers these levels in the pressurf:er. Therefore, we find that the justification suoplisc by the licensee is inadequate and unacceptable.

The technical specifications provide ue limit!ng c:nditions for operation and surveillance requirnents for system variables (volumes,

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... temperatures

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operational and availab1'e for pre-accident c:ndittens. The technical

! specifications do not identify specific instrumentation ranges that must be available in post-accident conditions. The licensee should provide an analysis that shows his existing pressurizer level instrumentation will adequately cover the maximum expacted range, or provide instrumentation with the range rec:mmended by Regulatory Guide 1.97.

3.3.11 pressurizer _Hester Status .

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The licensee has supplied inttrumentation for this variable that satisfactorily complies with the recommendations of the regulatory guide except the instrumentation is not environmentally qualified. Environmental qualification has been subsequently clarified by the environ.tental qualification rule, 10 CFR 50.49. It is concluded that the guidsnce of Regulatory Guide 1.97 has been superseded by a regulatory requirement. Any exception to this rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.

3.3.12 Quench Tank Level The licensee has provided instrumentation for this variable with a range of 7 in, to 8 ft.11 in, out of a total height of 9 ft. 6 in.

Regulatory Guido 1.97 recommends that the full height be covered by the instrument range. The licensee indicates that the range adequately covers the technical specification requirements.. We find the licensee's justification for this deviation unacceptable.

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The technical s:ecifications provice the limittre concitica: for

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n and tu vsfilanca requi-2:ents for sys : .a r t les , is,

ss :res, levels, tem:eritu as and etc.) that tr' requir;d to

o;araticnal and available for pre-accident conditions. The technical soccifications co not icentify specific instrumentation ranges tnat must be available in post-accident ccnditions. The licensee should provide an analysis tnat shows his existing puench tank level instrumentatien will adequately cover the maximum expected range, or provide instrumantation

'<tth the . range recommended.by Regulatory Guide 1.97. e

?.13 Cuecen Tank Temeerature The licensee has supplied instrumentation for this variable that has a

-1rge of 50 to 350*F instead of the reccmmended 50 to 750*F. The licensee states tnat the tank rupture disk has a design pressure of 85 psig, and that this restricts the temperature of the saturated steam to 323*F. The

- ":sure would have to reach 134 psig for the temperature to exceed the range of 350*F. We concur with the licensee's analysis and find that this deviation is acceptable.

3.3.14 Steam Generator Level The licensee has supplied non-redundant instrumentation for this elftable tnat measures frem 0 to 500 in, cut of a total height of 812 in.

Thare is redundance for a portion of this range provided by redundant narrow range instrumentation. Regulatory Guide 1.97 recommends redundant instrumentation with a range from the tube sheet to the separaters.

The licenses has not shewn the correlation between the O to 500 in, range supplied and the reccmmended range from the tube sheet to the

• sesrators. The licensee has stated that the auxiliary'feedwater flow cans

a used as a backup indication of level. Hewever, they have not shewn a positive correlation between the two variables. For a given flew of iaxiliary feec ater, the steam generatcr level will vary depending en _the type and severity of the accident. Thus, we cannet ccnclude that the-auxiliary fetcwater ficw is incicative of the steam generater level uncer all accident ccnditions. Therefore, we find that the justification 10

supplied by the licensee for deviations in range and redunda.1cy for this variable tre faadec'nte T licensee shon1' rovide (a) tbc cor elst t-between :ne steam generatcr eval and the a'niliary feedwiter flow, (S) -Se correlation between the 0 to 500 incl. range supplied and the etnge from tube sheet to separators recommended, and (c, either pro <ide recundancy for the entire recommended range or provice satisfactory justification for not having thi; redundancy.

3.3.15 Containment Soray Flow Regulatory Guide 1.97 recommends instrumentation for this variable to monitor operation of the containment spray. It recommends Category 2 instrumentation with a range from 0 to 110% of design flow. The licensee has not provided a direct measurement of coatainment spray flow. Instead they use a measurement of the spray additive flow. The licensee has not provided information on this instrumentation to show that it is qualified to Category 2 recommendations, nor shown that the additive flow is proportional to the containment spray flow. Further the licensee has not shown that this alternative is viable after the additive is used up.

Therefore, we cannot conclude that this deviation is acceptable. The licensee should shew the relation between the spray additive flow rate and the containment spray. The licensee should also show that the instrumentation is Category 2 and address the impact of when the spray additive flow is gone.

3.3.16 Heat Removal by the Containment Fan Heat Removal System

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Regulatory Guide 1.97 recommends plant specific Category 2 ~

instrumentation for this variable to monitor operation of this system. The licensee senses the flow of cooling water (0 to 3000 gallons per minute) threugh the containment fan cooling coils with Category 2 instrumentation.

This by itself does not show that the fans are operating or that heat is actually being removed by the containment fan heat removal system. It assumes that flow alore is indicative of heat removal. The licensee has not provided justification for not monitoring the cifference in temperature across the cooling coils or the operation of the fans by Category 2 instrumentation. Either of these in combination with the cooling water 11 L

-flow conclusively.shows whether heat is being removed. The licensee shoulc

-snow how either the tarperature difference a:ros: the f;n c:fi Or the fr

'coeration is monitored by Category 2' instrumentation to conclusively demonstrate heat removal.

3.3.17- Containment Sumo Water Temoerature Regulatory Guide 1.97 recommends instrumentation for this variable to

. monitor operation. of the containment cooling. systems. ,The licensee.i.s not suc'clying instrumentation for tnis variable. The licensee justifies not monitoring this variable by stating that " emergency core coclin;-and containment heat removal system pumos, specifically the residual heat removal pumps which take suction from the containment sump when the refueling water storage tank is empty, were-designed to meet the criteria in Safety Guide 1." Safety Guide 1 (Regulatory Guide 1.1), when followed, provides adequate net positive suction head.to the pumps that draw suction-from the containment sump, assuming maximum expected temoerature of the sump contents with normal (i.e., minimum), ambient containment pressure. We find this justification unacceptable. The licensee's justification does not adcress the purpose of this instrumentation as stated in the regulatory guide (monitoring the operation of the containment cooling. systems with a range from 50 to 250 F). The licensee should provide specific information

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showing why compliance cannot be accomplished, or provide instrumentation with the~ range specified by the. regulatory guide.

~3.3.18 Volume Control Tank Level Regulatory Guide 1.~97 recommends instrumentation for this variable to monitor operation of the chemical volume and control system.- The licensee-

.provides instrumentation for this. variable that measures from 16.5% to 85%

of total volume instead of the regulatory guide recommended top to-bottom.

. The tank overflow line is at a level equivalent.to 85% of total volume.

Thus the u::per 1imit.of the. range is at full volume. ' The licensee states

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that the range is' adequate.for the-requirements of their technical- ,

soecifications, and. that this instrumentation is not required for an

accident. LSection' O.2.3.1 of the FSAR (Reference 8) confirms. this--the r i

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volume control t:nk is autcmatically vaivac off with an accident signal.

Eased on this, we concur that the licensee: S justification for this deviation is acceptacle.

3.3.19 Cerconent Cooline '4a ter .: low to ES: ysten Regulatory Guide 1.97 recommends instr. :entatien for this variable to insure that the ESF equipment is su:: plied with adequate cooling water.

Category 2 instrumentation with a range of 32* to 2'00*F is recommended.

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The licensee'171dic'ates that thIsinstrumentatica satisfies thJ specifications of Regulatory Guide 1.97 except that it provides useful information only "during periods of recirculation." The component cooling water system is an intermediate system between the reactor ecolaat and the engineered safety feature (ESF) systems and the service water system. It is operated in a closed loop mode. It is manually aligned ta the ESF ecuipment. Therefore, we find that the licensee's instrumentation is suitaole for post-accident monitoring o.'f this variable.

3.3.20 Radioactive Gas Holdur Tank Pressure The licensee indicates that this variable is directly measured by Category 3 instrumentation. They did not show that the instrument range is 0 to 15C's of design pressure as recommended by Regulatory Guide 1.97.

Since the range of the-instrumentation was not indicated in the licensee's submittals (Reference 6), a judgement cannot be made on the adequacy of the instrumentation under a post-accident condition. The licensee should provide the range as recommended in the regulatory guide or provide justification that the existing range is adequate for pnst-accident -

conditions.

3.3.21 Emeroency Ventilation Dameer' Position The emergency ventilation damper position -is monitored by Category 2 instrumentation as specified in Regulatory Guide 1.97, except for the dampers in the auxiliary cuilding ard tne tael. handling butiding. These 13 1

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dameers co not have :osition indication in tne :cytr:1 -c: 3. ~5s licensee j not indicata in his si.:Ht:als - '

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~Tua have no bas!! 11 which t0 cetermi" tne a::sp -O deviation. The licensee should identify where tna dampe Ocii'.ico indicators are located and justify not having tnis indicaefcn la tne Controi room.

.3.22 Commen olen: Vent Fisw Rate C.egulatory Guide 1.97 re: mends instrumentatica for this variable fo-a detectice of significant releases, assessment of any releas: and icng term surveillance. The licensee has not shewn :nat this variable is

. instrumented frem 0 to 110% of design ficw as re mmenced in the regulatory guide. The licensee should provice information that verifies the instrument range is as re:0mmended or justify any deviatien fr m the recommended range. ,

3.3.23 No'le c Gas Vent Frem Steam Generater Safety Relief Valves or Atmescheric Cum: Valves

! Regulatory Guide 1.97 reccmmends instrumentation for this variable for tha dete:: ten of significant releases, assessment of any release and long tarm surveillance. Besides the radiation level, the curation of the

. ease and mass of steam :er unit of time are reccemended as parameters to 1 measured. The licensee does not have instrumentation for this l

l variable. However, alternate instrumentatien is installed to measure the main steamline radiation. The monitors are located between the steam generators.and the corresponding safety relief and atmospheric dump

< lives. Thus, any release through the safety relief er at:0 spheric dump valves will pass through a main steamline monitor.

l The licensee has stated that this instrunentation meets the Category 1 requirements. The licensee did not supply information to show the

ivalence ta the range specified by Regulatory Guide 1.97 (10 ~1 to 14 c

t 103 pC1/cc and duration of the release in seconds and the mass of steam per unit time). The 1 Mensee should supoly thit. Infirmati m to it can ba 1 determined ;P N ie alternite instrumentatfor 1r. V que n

4. CONCLUSIONS l

Basea un our review we find that the liceinvu alther uniu as to ur is

justified in deviating from the guidance oi Regulacory f. ou .17 with tha

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Efollowing.exceptionsty ,, ,, . . . ,

, 1. Neutron flux--the issue of seistaic qualification of the neutron detectors is not a generic issue. The licensee should provide justification for this deviation ir the for.n of an analysis that addresses the qualification of the detectors (in accordance with the qualification program which was the basis for plant licensing) or provide a commitment to upgrade the detectors; environmental qualification

• qld be addrea.<ed in accordance with 10 CFR 50.49 (Section 3.3.1).

4 i 2. Radiation level in circulating primary. coolant--the licensee ,

should commit to install instrumentation for this variable as it

becomes available (Section 3.3.4). [

3. Radiation exposure rate--the licensee should adequately justify not covering the lowest decade of the range recommended by the regulatory guide for this variable; the licensee should also justify not providing instrumentation for this variable in Unit 1

(Section 3.3.5).

4 Effluent radioactivity--noble gases from electrical and mechanical penetration areas and fuel handling buildings--the licansee should provide the appropriate instrumentation for this variable or provide justification for this deviation (Section 3.3.6).

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5. RHR heat exchanger outlet temperature--environmental qualificationshouldbeappliedinaccordancewithSection(g)to 10CFR50.49(Section3.3.7). ,

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6. 'A:c uulator tank level--the instrumentation for this variable  !

does not ctver' the range recommended by the regulatory guide. l j

, The license shod'd' provide an analysis that shows his existing '

monito' ring instN.tentation will adequately cover the maximum '

a. , e.tpactedrangef.ororovideinstrumentation.,withthe.rangeas ,

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recommended by Regulatory 'luide 1.97 (Section 3.3.8).

7 Refueling' iator storage tank level- the licensee should provide en analysis that shows his existipg monitoring instrumentation ,

will AJequately cover the made m trapected range, or provide

• • tstrumentation w';tt d.he range fi recommended by Regulatory Guide 1.9/ (Section 3.3.9).

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8. Pressurigerlievei-thelicenseeshouldprovideananalysisthat sf.ows'hYsexstingmonitoring1.istrumentationwilladequately cover the medmam expecteo range, or provide instrumentation with the. range as Aecom6nded by Regulatory Guide 1.97  !

Sehtion3.3.10). , l l

9, l fressur/Tephairj datus--envirinmentalqualificationshouldbe applied in acccedance ;with, Section +1), tu 10 CFR 50.49

( (Section'3.3.11). ,

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10. Quench tani.r'svel- the license's shou'Id provide additional informat' ion 1.1 sd; port of the deviation from the recommended range (Section3.3.12). -

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11. Ste.v.s generator Itvel--the licenseeEthculd provide redundant .

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instrumer.t channels for this variablq,o, r provide natisfactory justification for not providing this reduntancy;.the licensee

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should show that the supplied range satisfies the regulatory

. guide recommendation for a range from the tube sheet to the separators (Section 3. ? 14).

12. Coistainment spray flev -the licensee shvuld provide accitional triformation to justify use of the spray additive flow in lieu of l this variable (Section 3.3.15).

13. Heat removal by the containment fan heat' removal system--the

. . .. - .. . , . . . ~ . f, .... s .. . .

l. .

' licensee sho'uld provide additional'information on the al' ternate instrumentation proposed for use with this variable, showing that Category 2 requirements are met (Section 3.3.16).  :

l .

14. Containment sump water temperature--the licensee should provide specific information showing why compliance cannot be ,

accomplished, or provide the range specified in the regulatory  !

guide (Section 3.3.17), f l

15. Radioactive gas holdup tank pressure--the licensee should show l l tr.e instrument range meets the O to 150% of design pressure recommended by Pogulatory Guide 1.97 or provide justification showing that the existing range is adequate for post-accident conditions (Section 3.3.20).

16. Emergency ventilation damper position--the Itcenset should j justify not having control room indication for this variable for the auxiliary butiding and the fuel handling buildin,g dampers (Section3.3.21).

17. Common plant vent flow--the licensee should show the instrument range meets the 0 to 110% of design flow recommended by  :

Regulatory Guide 1.97 ($ection 3.3.22).

18. Noble gas-vent from steam generator safety relief valves or atmospheric dump valves--the licensee should show that the main 1

17

+

4 La _

4 f .

steamline radiation monitors used for this variable meet the rangerecommendationsofRegulatoryGuide1.57(Section3.3.23).

5. REFcRENCES

1. NRC letter, 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 ll, 1982.

-2 . Instrumentation for Light-Water-Cooled Nuclear Power Pla~nts to Assess, Plant and Environs' Conditions During and Fo11cwine an Accident, Regulatory Guice 1.97, Revision 2, U.S. Nuclear Regulatory Commission (NRC), Office of Standards Development, December 1980.

3. . Clarification of TMI Action Plan Reouirements, Requirements for Emergency Response Cacability, NUREG-0737 Supolement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.

4. Public Service Electric and Gas Company letter, E. A. Liden to Director of Nuclear Reactor Regulation, NRC, " Requirements for Emergency Response Capability, Supplement 1 to NUREG 0737, Preliminary Status Report and Schedule," April 15, 1983.

5. Public Service Electric and Gas Company letter, R. L. Mitti to

Director of Nuclear R6 actor Regulation, NRC, " Compliance with Regulatory Guide 1.97, No. 2 Unit," April 2,1981.

6. Public Service Electric and Gas Company letter, E. A. Liden to Director of Nuclear Reactor Regulation, NRC, " Compliance with Regulatory Guide 1.97, NRC' Request for Additional Information,"

September 21, 1983.

7. 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, NRC, Office of Nuclear Regulatory Research,-May 1983.'

8. Salem Nuclear Generating Station, Units 1 and 2, Final Safety Analysis

' Report, Public Service Electric .and Gas Company, Newark, NJ, - -

August 27, 1971, Amendment 10.

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= 18 w

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