ML20099D455

Conformance to Reg Guide 1.97,Millstone Nuclear Power Station,Unit 2

ML20099D455
Person / Time
Site:	Millstone
Issue date:	02/28/1985
From:	Udy A EG&G, INC.
To:	NRC
Shared Package
ML20099D458	List: ML20099D455
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-51107, NUDOCS 8503130353
Download: ML20099D455 (21)

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CONFORMANCE TO REGULATORY GUIDE 1.97 l MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 A. C. Udy Published February 1985 EG&G Idaho, Inc.

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

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ABSTRACT This EG&G Idaho, Inc., report provides a review of the submittals for Regulatory Guide 1.97 Revision 2, for Unit No. 2 of the Millstone Nuclear Power Station. Any exception to the guidelines of Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not pro-vided are also identified.

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 Systems Integration, by EG&G Idaho, Inc., NRC Licensing Support Section.

The U.S. Nuclear Regulatory Commission funded the work under authoriza-tion B&R 20-19-10-11-3.

1 Pocket No. 50-336 1 TAC No. 51107 l

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CONTENTS ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. REVIEW REQUIREMENTS ........................ 2

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 ............................ 14 4

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5. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4

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CONFORMANCE TO REGULATORY GUIDE 1.97 MILLSTONE NUCLEAR POWER STATION. UNIT NO. 2 l

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1. INTRODUCTION l

On December 17, 1982 Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut. Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating ,

licenses and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97 Revision 2 (Reference 2), re-lating to the requirements for emergency response capability. These require-ments have been published as Supplement No. I to MUREG-0737, "TMI Action Plan Requirements"(Reference 3).

Northeast Utilities, the licensee for the Millstone Nuclear Power Station, provided a response to the generic letter on April 15,1983(Refer-ence4). The response to Section 6.2 of the generic letter was submitted on February 29,1984(Reference 5),andrevisedonApril9,1984(Reference 6).

This report provides an evaluation of this material. .

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2. REVIEW REQUIREMENTS Section'6.2 of NUREG-0737, Supplement 1, sets forth the documentation to be submitted in a report to the NRC describing how the licensee meets the guidance of Regulatory Guide 1.97 as applied to emergercy response facilities. The submittal should include documentation that provides the fol-lowing information for each variable shown in the applicable table of Regula-tory Guide 1.97.

1. Instrument range i .

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.

Furthermore, the submittal should identify deviations from the guidance in the regulatory guide and provide supporting justification or alternatives.

Subsequent to the issuance of the generic letter, the NRC held regional

> ' meetings *in February and Mardh 1983, to answer licensee and applicant ques-l tions and concerns regarding the NRC policy on this matter. At these meet-

) ings, it was noted that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97. Furthermore, where licensees or

! applicants explicitly state that instrument systems conform to the provisions of the guide it was noted that no further staff review would be necessary.

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Therefore, this report only addresses exceptions to the guidance of Regulatory Guide 1.97. 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. EVALUATION The licensee provided a response to Item 6.2 of the NRC generic letter 82-33 on February 29, 1984. This was revised on April 9, 1984. The response describes the licensee's position on post-accident monitoring in-strumentation. This evaluation is based on this material.

3.1 Adherence to Regulatory Guide 1.97 The licensee has provided a review of their post-accident monitoring in-strumentation that compares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 2.

The licensee states that in several instances, satisfactory instrumenta-tion already exists and that additional instrumentation will be installed to comply with the provisions of Regulatory Guide 1.97, except for those in-stances where deviations are justified.

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

3.2 Type A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide information required td permit the control room operator to take specific manually controlled safety actions. The licen-see classifies the following instrumentation as Type A.

1. Pressurizer level .

2. Pressurizer pressure i

3. Reactor coolant system (RCS) hot leg water temperature

4. RCS cold leg water temperature t

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5. Steam generator pressure

6. Steam generator level

7. Auxiliary feedwater flow

8. Containment pressure

9. Degrees of subcooling

10. Containment hydrogen concentration

11. Containment radiation.

All of the above instrumentation meets the Category 1 requirements consistent with the requirements for Type A variables, with the exceptions as listed in Section 3.3.

3.3 Exceptions to Regulatory Guide 1.97 The licensee identified the following deviations from the recommendations of Regulatory Guide 1.97. '

l 3.3.1 Environmental Qualification  ;

i The following Category 2 variables do not have environmentally qualified

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instrumentation, and no upgrading has been proposed.

Containment sump water level--narrow range

• 2 RIsidua1 I I heat h val (RHR) system flow * '

• RHR heat exchanger outlet temperature l

• Accumulator tank pressure 5

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• Flow in high pressure injection system

- Flow in low pressure injection system

• Containment spray flow

• Containment atmosphere temperature

• Makeup flow-in Letdown flow-out Volume control tank level

• Component cooling water temperature to ESF system

• Component cooling water flow to ESF system

• Status of standby power Environmental qualification has been clarified since Revision 2 of Regulatory Guide 1.97 was issued. The clarification is in the environmental qualifica-tion rule, 10 CFR 50.49. It is concluded that the guidance 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 ac-  !

cordance with 10 CFR 50.49. I 3.3.2 Reactor Coolant System (RCS) Soluble Boron Concentration l The range of the instrumentation supplied by the licensee for'this vari-able is 0 to 2050 parts per million. The range recommended in the regulatory guide is 0 to 6000 parts per million. The licensee's justification for this deviation from the recommended range is that the boron concentration is not expected to exceed the technical specification limit of 1720 parts per 6

million, and that if a higher range is needed, the post-accident sampling i system can be used.

The licensee takes exception to the guidance of Regulatory Guide 1.97 with respect to post-accident sampling capability. This exception goes beyond the scope of this review and is being addressed by the NRC as part of their review of NUREG-0737. Item II.B.3.

3.3.3 RCS Cold Leg Water Temperature Regulatory Guide 1.97 recommends redundant instrumentation for this variable with a range from 50 to 750*F. The licensee has supplied one wide range channel for each cold leg, with a range from 0 to 600*F.

The licensee identifies one wide range temperature instrument in each of the hot legs and cold legs. Millstone Unit 2 is a two loop unit. Thus, there i is redundancy in that the coolant temperature delivered to the core and leaving the reactor is measured by independent instruments. However, the licensee should verify that each channel of instrumentation, including power supplies, is independent and redundant.

l The licensee states that the range of 0 to 600*F is adequate to monitor-cold leg fluid temperature following all design basis accident scenarios.

This is based on the safety analysis of the plant. Based on this statement, we find the existing range acceptable.

3.3.4 RCS Hot Leg Water Temperature Regulatory Guide 1.97 recommends redundant instrumentation for this vari-l able with a range from 50 to 750*F. The licensee has supplied one wide range channel for each hot leg, with a range from 150 to 750*F. t I

j The licensee identifies one wide range temperature instrument in each of j the hot legs and cold legs. Millstone Unit 2 is a two loop unit. Thus there l 1s redundancy in that the coolant temperature delivered to the core and 7 i 1

l leaving the reactor is measured by independent instruments. However, the licensee should verify that each channel of instrumentation, including power supplies, is independent and redundant.

The licensee states that 212*F is the saturation temperature at atmospheric pressure, and therefore the 150*F lower range provides sufficient margin to monitor the approach to saturation in a cold shutdown situation in the event of a loss of shutdown cooling. In addition, the RCS cold leg water i

temperature and the residual heat removal (RHR) heat exchanger outlet temperature are measured down to 0*F. Therefore, this deviation in the lower limit of the range for this variable is acceptable.

3.3.6 RCS Pressure i Regulatory Guide 1.97 recommends redundant Category 1 instrumentation with a range from 0 to 4000 psig for this Combustion Engineering unit. The licensee has supplied instrumentation for this unit as follows:

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Redundant 0 to 1600 psig channels Category 1 Redundant 1500 to 2500 psig channels. Category 1 One O to 3000 psig channel, not Category 1.

The redundant ranges overlap such that redundancy is provided from 0 to 2500 psig. The licensee " considers the upper range of 3000 psig adequate for all design basis events."

Redundancy is needed for pressures above 2500 psig. The pressure range of 0 to 3000 psig is adequate to monitor all expected pressures based on the licensee's design basis event analysis. The licensee should commit to install i

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redundant Category 1 instrumentation in accordance with the resolution of the anticipated transient without scram (ATWS) issue.

3.3.6 Coolant Level in Reactor Revision 2 of Regulatory.4uide 1.97 recommends instrumentation for this variable with a range from the bottom of the core to the top of the vessel.

The licensee is supplying instrumentation with a range from the top of the core to the top of the vessel and notes that it deviates from the recommenda-tion of Revision 2 of the regulatory guide. This is acceptable, as it exceeds

.s the range recommended by Revision 3 of the regulatory guide (bottom of the hot leg to the top of the vessel).

3.3.7 Containment Sump Water Level Regulatory Guide 1.97 recommends measuring the sump level with wide range instruments up to the height equivalent to 600,000 gallons. The licensee has instrumentation for this variable that measures from -22 ft. 6 in. to -15 ft.

5 in. This is equivalent to 565,000 gallons.

The licensee refers to a previous letter where it was shown that the .

maximum post-accident containment water volume will not exceed 563,800 gallons. As the range exceeds the maximum expected water volume, we find this deviation acceptable.

3.3.8 Radiation Level in Circulating Primary Coolant l

The licensee states that the post-accident sampling system can provide this information with an isolated nuclear steam supply system.

1 Based on the justification provided by the licensee, we conclude that the l instrumentation supplied for this variable is adequate, and therefore, acceptable.

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t l' 3.3.9 Containment H.ydrogen Concentration Regulatory Guide 1.97 recommends that this instrumentation remain functional for containment pressures from -5 psig to the maximum design pressure. The licensee states that the hydrogen analyzers are designed for operation with a positive containment pressure up to 10 psig. Further, they state that the " containment will not see a negative pressure under any FSAR analyzed accident conditions."

The licensee states that the pressure range is being addressed under Item II.F.1 of NUREG-0737. This does not require an operating pressure envelope. Therefore, the licensee should provide a complete justification for

! this deviation, including the basis for the statement of not having a negative containment pressure, or they should provide instrumentation capable of func-tioning over the reconmended pressure range.

. 3.3.10 Radiation Exposure Rate The licensee takes exception to the instrument range recommended by 1 4 RegulatoryGuide1.97(10 R/hr to 10 R/hr). Currently installed area radi-3 ation monitors cover a lesser range up to 10 or 10 R/hr. The licensee's justification for this deviation is that the existing area rad 14 tion monitors provide for adeq" ate employee protection, that these monitors can be augmented by portable monitors, and that these monitors do warn of changing or unusually high radiological conditions. .

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From a radiological standpoint, if the radiation levels reach or exceed l l

the upper limit of the range, personnel would not be permitted to the areas except of life saving. We therefore find the proposed ranges for the radia-l tion exposure rate monitors acceptable.

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3.3.11 Accumulator Tank Pressure ,

Regulatory Guide 1.97 recommends instrumentation with a range of 0 to 750 psig for this variable. The range provided is 0 to 250 psig. On the 10

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basis that the design pressure of the accumulators is 250 psig, we find this deviation acceptable.

3.3.12 Refueling Water Storage Tank Level i Regulatory Guide 1.97 recomends instrumentation with a range from top to bottom for this variable. The range of the instrumentation supplied by the licensee is 4.3 to 100 percent. At 4.3 percent, the tank is essentially empty. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

l 3.3.13 Pressurizer Heater Status Regulatory Guide 1.97 recommends Category 2 electric current instrumenta-

) tion for this variable. The licensee has supplied circuit breaker position i indication for this variable.

Section II.E.3.1 of MUREG-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. Also, technical specifications are to be changed accordingly. The i

Standard Technical Specifications, Section 4.4.3.2, requires that the emergency pressurizer heater current be measured quarterly. These heaters, as required by NUREG-0737, should have the current instrumentation recommended by Regulatory Guide 1.97.

3.3.14 Quench Tank Level i

Regulatory Guide 1.97 recomends instrumentation for this variable with a

! range from the top to th4 bottom of the tank. The tank is a horizontal cylindrical tank with an outside diameter of 60 in. The licensee's instru-l mentation measures the level for 20 in. on each side of the centerline of the l

tank. We calculate that this range covers 74 percent of the tank volume.

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The licensee did not relate the existing range to the range that needs to be available in a post-accident condition. The licensee should show that the )

existing quench tank level instrumentation will adequately cover the maximum l

expected range, or provide instrumentation with the range recommended by l Regulatory Guide 1.97. l j

3.3.15 Quench Tank Temperature Regulatory Guide 1.97 recomends instrumentation for this variable with a range from 50 to 750*F. The licensee has provided instrumentation for this l

! variable with a range of 0 to 300*F.

l The licensee states that "the range of 0 to 300'F is sufficient to monitor normal as well as design basis accident scenarios." Based on this i statement, we find this deviation acceptable.

3.3.16 Steam Generator Level Regulatory Guide 1.97 recomends instrumentation with a range from the tube sheet to the separators for this variable. The licensee has provided instrumentation with a range from the top of the tube bundles to the separators. Thus, the length of the tube bundles is not measured.

I The licensee states that "there are no instrument taps in the steam generator to allow direct wide range level measurement." They also say that i there are "other methods of determining the level below the lower instrument tap using analytical methods."

! The licensee has not provided justification showing why compliance cannot j be accomplished. They have not stated what criteria are being applied to the )

analytical method. Therefore, we conclude that the licensee should provide .

the recommended. instrumentation.

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j 3.3.17 Heat Removal by the Containment Fan Heat Removal System  !

Regulatory Guide 1.97 recommends plant specific Category 2 instrumenta-tion for this variable. The licensee has no instrumentation for this, variable l saying that it is not considered a part of the post-accident monitoring ]

system.

The licensee should either provide instrumentation for this variable or provide additional justification showing why compliance is not needed. l l

3.3.18 Containment Atmosphere Temperature l

l Regulatory Guide 1.97 reconmends instrumentation for this variable with a  !

range from 40 to 400*F. The licensee has instrumentation for this variable I with a range of 0 to 350*F.

The licensee states thst "the maximum predicted containment temperature l 1s less than 300*F." Based on this statement, we find the range supplied by I the licensee for post-accident monitoring acceptable.

3.3.19 Containment Sump Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from 50 to 250*F. The licensee has no instrumentation for this variable saying it is not considered a part of the post-accident monitoring system.

The licensee should either provide instrumentation for this variable or

] provide justification showing why compliance cannot be accomplished.

4 3.3.20 Radioactive Gas Holdup Tank Pressure 1

Regulatory Guide 1.97 recommends instrumentation for this variable with a range from 0 to 150 percent of design pressure. The licensee has instrumentation for this variable that reads from 0 to 25 psig. We were 4

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f unable to determine what the design pressure of the tank is. However, Section 11.1.3.3.1 of the Final Safety Analysis Report (Reference 8), states that in normal operation, the tank is subjected to 140 psig maximum. This is beyond the range of the instrumentation. The licensee has not provided justification for this deviation, as they do not consider it part of the post-accident monitoring system.

The licensee should either provide the recommended range for this instrumentation or provide justification for not doing so.

3.3.21 Accident Sampling (Pr.imary Coolant. Containment Air and Sump)

The licensee's post-accident sampling system provides sampling and analysis as recommended by the regulatory guide, except that it does not have the capability to analyze for dissolved oxygen.

The licensee takes exception to the guidance of Regulatory Guide 1.97 with respect to post-accident sampling capability. This exception goes beyond the scope of this review and is being addressed by the NRC as part of their review of MUREG-0737. Item II.B.3.

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4. CONCLUSIONS Based on our review, we find that the licensee either conforms to, or is justified in deviating from, the guidance of Regulatory Guide 1.97 with the following exceptions:

1. Environmental qualification--there are 14 Category 2 variables for which environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.1).

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2. RCS cold leg water temperature--the licensee should verify that these channelsareredundant(Section3.3.3).

3. RCS hot leg water temperature--the licensee should verify that these channels are redundant (Section 3.3.4).

4. RCS pressure--the licensee should commit to install redundant Cate-gory 1 instrumentation with a range to coincide with the resolution of the ATWS issue (Section 3.3.5).

5. Containment hydrogen concentration--the licensee should provide addi-tional justification for not complying with the recomended operating pressure envelope, or they should provide instrumentation capable of functioning over the recomended pressure range (Section 3.3.9).

6. Pressurizer heater status--the licensee should provide the recom-mendedcurrentmeasuringinstrumentation(Section3.3.13).

7. Quench tank level--the licensee should show that the existing range isadequateorprovidetherecommendedrange(Section3.3.14).

8. Steam generator level--the licensee should provide the recommended instrumentation (Section3.3.16).

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9. Heat removal by the containment fan heat removal system--the licensee

, should either provide instrumentation for this variable or provide further justification showing why compliance is not needed (Sec-tion 3.3.17).

10. Containment sump water temperature--the licensee should either pro-vide instrumentation for this variable or provide further justifica-tion showing why compliance cannot be accomplished (Section3.3.19).

11. Radioactive gas holdup tank pressure--the licensee should either pro-vide instrumentation with the recommended range for this variable or provide justification showing why compliance cannot be accomplished (Section3.3.20).

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- 5. REFERENCES .

1. NRC' letter. D. G. Eisenhut to All Licensees of Operating Reactors, Appli-cants for Operating Licenses, and Holders of Construction Permits " Supple- )

ment No. I to NUREG-0737--Requirements for Emergency Response Capability 1 (GenericLetterNo.82-33)." December 17, 1982. i

2. Instrumentation for Light-Water-Cooled Nuclear Power plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 2. U.S. Nuclear Regulatory Commission (NRC). Office l l of Standards Development. December 1980.

3. Clarification of TMI Action Plan Requirements. Requirements for Emerciency Response Capability, NUREG-0737 Supplement No. 1. NRC, Office of Nuc' ear Reactor Regulation January 1983.

4. Northeast Utilities letter, W. G. Counsel to D. G. Eisenhut NRC, "Re-quirements for Emergency Response Capability (Generic Letter No. 82-33),"

April 15, 1983, A02959.

5. Northeast Utilities letter, W. G. Counsel to Director of Nuclear Reactor Regulation, NRC, " Supplement I to NUREG-0737. Revision 2 to Regulatory Guide 1.97." February 29, 1984, A02959.

6. Northeast Utilities letter, W. G. Counsel to Director of Nuclear Reactor Regulation, NRC, ". Supplement 1 to NUREG-0737. Revision 2 to Regulatory Guide 1.97 " April 9, 1984, A02959.

7. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Environs Conditions During and Following an Accident, Regulatory

Guide 1.97 Revision 3 NRC, Office of Nuclear Regulatory Research, May 1983. -

8. Final Safety Analysis Report, Millstone Nuclear Power Station, Unit No. 2.

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Millstone Ge'rald Garfield, Esc. Arthur Heubner, Director l Day, Berry & Howard Radiation Control Unit I Counselors at Law Department of Environmental l City Place Protection Hartford, Connecticut 06103-3499 State Office Building Hartford, Connecticut 06116 Regional Administrator USNRC, Region I Mr. John Shedolsky l Office of Executive Director for Operations Resident Inspector / Millstone 631 Park Avenue Box 811 King of Prussia, Pennsylvania 19406 Niantic, CT 06357 Mr. Charles Brinkman, Manager Office of Policy & Management Washington Nuclear.0perations ATTN: Under Secretary Energy C-E Power Systems Division Combustion Engineering, Inc. 80 Washington Street 7910 Woodmont Avenue Hartford, Connecticut 06115 Bethesda, Maryland 20814 Superintendent Millstone Plant Mr. Lawrence Bettencourt, First Selectman P. O. Box 128 Town of Waterford Waterford, Connecticut 06385 Hall of Records - 200 Boston Post Road Waterford, Connecticut 06385 Vice President-Nuclear Operations Northeast Utilities Service Co.

Northeast Utilities Service Company P. O. Box 270 ATTN: Mr. Richard R.'Laudenat, Manager Hartford, Connecticut 06101 Generation Facilities Licensing Post Office Box 270 Hartford, Connecticut 06101 l

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