ML20107E382
| ML20107E382 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/30/1985 |
| From: | Vanderbeek R EG&G, INC. |
| To: | NRC |
| Shared Package | |
| ML20107E333 | List: |
| References | |
| CON-FIN-A-6493, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8502250550 | |
| Download: ML20107E382 (16) | |
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CONFORMANCE TO REGULATORY. GUIDE 1.97 V0GTLE ELECTRIC GENERATING PLANT, UNIT NOS. 1 AND 2 R. VanderBeek Published January 1985 EG&G Idaho, Inc.
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l Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6493 8502250 g gM$
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c ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97, Revision 2, for the Vogtle Electric Generating Plant, Unit Nos. I and 2.
Exceptions to these guidelines are evaluated and areas where suf-ficient basis for acceptability is not provided are identified.
FOREWORD This report is supplied as pe ' of the " Program for Evaluating Licensee /-
Applicant Conformance to RG 1.97 " being conducted for the U.S Nuclear Regula-tory Commission, Office of Nuclear Reactor Regulation, Division of Systems
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Integration, by EG&G Idaho, Inc., NRC Licensing Support Section.
The U.S. Nuclear Regulatory Commission funded the work under authoriza-tion B&R 20-19-40-41-3.
Docket Nos. 50-424 and 50-425 11 4
4 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.............
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- 4.
CONCLUSIONS 12
- 5. REFERENCES............................
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CONFORMANCE TO REGULATORY GUIDE 1.97 V0GTLE ELECTRIC GENERATING PLANT. UNIT NOS.1 AND 2 1.
INTRODUCTION
.On December 17, 1982 Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and holders of construction permits. This letter included additional
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clarification regarding Regulatory Guida 1.97, Revision 2 (Reference 2), re-
.lating to the requirements for emergency response capability. These require-ments have been published as Supplement 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Georgia Power Company, the applicant for the Vogtle Electric Generating Plant, provided a response to the generic letter on April 14, 1983 (Refer-ence 4). This submittal refers to the Vogtle Final Safety Analysis Report (FSAR) (Reference 5) for a review of the instrumentation provided for conform-ance to Regulatory Guide 1.97.
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.This report provides an evaluation of these submittals.
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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 applicant meets the guidance of Regulatory Guide 1.97 as applied to emergency response facilities. The submittal should include documentation that provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97.
1.
Instrument range 2.
Environmental qualification 3.-
Seismic qualification i
4.
Quality assurance 5.
Redundance and sensor location 6.
Power supply 7.
Location of display l
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Schedule of installation or upgrade l
Furthermore, the submittal should identify deviations from the guidance in the Regulatory Guide and provide supporting justification or alternatives.
I Subsequent to the issuance of the generic letter, the NRC held regional l
meetings in February and March 1983, to answer licensee and applicant ques l
tions and concerns regarding the NRC policy on this matter. At these meet l
ings, it was noted that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97.
Furthermore, where licensees er I
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 applicant's submittal based on the review policy described in the NRC regional meetings.
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EVALUATION In the applicant's response to NRC generic letter 82-33, Section 7.5 of the FSAR is identified as containing (a) the description of the Post-Accident Monitoring System (PAMS), (b) tables which identify the monitored parameters, and (c) compliance to or deviations from the guidance of Regulatory Guide 1.97 along with the supporting justification or alternatives. This evaluation is based on the information provided in Section 7.5 of the FSAR.
3.1 Adherence to Regulatory Guide 1.97 Within Table 7.5.2-1 of the FSAR, the applicant has identified where the post-accident monitoring instrumentation conforms to Regulatory Guide 1.97, Revision 2, and where deviations have been taken.
It is concluded that the
' applicant has made an explicit commitment to conform to the guidelines of Regulatory Guide 1.97 with the exception of the identified deviations noted in Section 3.3 of this report.
j 3.2 Type A Variables a
i Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide information required to permit the control room operator-to take specific manually controlled safety actions. The applicant classifies the following instrumentation as Type A variables.
'l. Reactor coolant pressure (wide range) 2.
Reactor. coolant system wide range THot
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3.
Reactor coolant system wide range TCold 4.
Wide range. steam generator water level 5.
Narrow range steam generator water level 4
6.
Pressurizer level 1
7.
Containme:t pressure 8.
Steamline pressure 9.
Refueling water storage tank level
- 10. Containment water level-narrow range Containmen' water level-wide tange 11.
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- 12. Condensate storage tank level
- 13. Auxiliary feedwater flow l-
- 14. Containment radiation level-wide range
- 15. Containment radiation level-narrow range t
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- 16. Steam 11ne radiation monitor
- 17. Core exit temperature 18.~
Degrees of subcooling 19._ Condenser air ejector radiation The above variables are also included as Type B, C, D or E variables. The ap-plicant has committed that were a variable is included in one or more of the five classifications, the equipment monitoring the variable is specified in l
accordance with the highest category identified. All of the above variables l-are identified as conforming to Regulatory Guide 1.97, Revision 2, and, with the exception.of degrees of subcooling and condenser air ejector radiation.
l are Category 1 as required for Type A variables. Variables 18 and 19 are specified as Category 2.
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3.3 Exceptions to Regulatory Guide 1.97 The following exceptions to the requirements of Regulatory Guide 1.97 have been identified by the applicant.
3.3.1 Reactor Vessel Water Level Exception has been taken by the applicant to the recommendations of Regu-latory Guide 1.97 for the reactor vessel water level variable. Category 2 instrumentation has been provided instead of the recommended Category 1 instrumentation. The applicant states that (a) the reactor vessel water level is not required for safety, but is provided for information purposes only, and (b) the reactor vessel water M al is not a key variable but is the preferred backup to the key variable--pressurizer water level.
The applicant takes er.ception to the guidance of Regulatory Guide 1.97 with respect to the category of the instrumentation. This exception goes be-j
-yond the scope of this review and is being addressed by the NRC as part of
.their review of NUREG-0737 Item II.F.2.
The acceptance criteria for l
Item II.F.2 is the same as Category 1 for Regulatory Guide'1.97.
l 3.3.2 -Containment Isolation Valve Status l
Category 2 instrumentation has been provided for this variable by the ap-l plicant instead of the recommended Category 1 instrumentation. The applicant states' that all variables which indicate actual breach, iracluding containment isolation valve status, have been designated as preferred backup information and are qualified to Category 2 criteria. The applicant designates contain-ment pressure and hydrogen concentration as the key variaales for containment boundary verification.
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.The applicant has not provided acceptable justification for the use of Category 2 1r.strumentation for this variable. The containment isolation valve l
status (closed-not closed) is the primary means to detect the actual position
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l of these safety-related valves. The applicant should commit to upgrade the containment isolation valve status instrumentation to the recommended Cate-gory 1 criteria.
l 3.3.3 Pressurizer Heater Status The applicant takes exception to the guidance of Regulatory Guide 1.97 with respect to monitoring of the current to the pressurizer heaters.
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The applicant states that indication of the pressurizer heater breaker pusition.'is adequate indication to the operator that the pressurizer heaters are operable..We find this justification unacceptable.
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Section II.E.3.1 of NUREG-0737 requires a number of the pressurizer heaters to have the capability of being powered by the emergency power j
sources.
Instrumentation is to be provided to prevent overloading a 4
diesel-generator. Also, technical specifications are to be changed accordingly. The 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.
3.3.4 Accumulator Tank Level and Pressure The applicant hat specified in Table 7.5.2-1 of the FSAR that their range is 0 to 700 psig, while Regulatory Guide 1.97 recommends 0 to 750 psig. The applicant has not provided justification for this deviation.
The applicant has not included as a monitoring variable the accumulator
-tank level, the justification being that accumulator pressure indication and valve position indication for the accumulator discharge isolation and accumu-lator vent valves provide adequate status of the accumulators. The applicant
-has not listed in Table 7.5.2-1 of the FSAR the accumulator discharge isola-tion valve nor the accumulator' vent valve as monitoring variables, or provided 3
the-information requirements of Section 6.2 of NUREG-0737, Supplement 1; I[
.therefore, this justification is unacceptable.
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9 The applicant should comply to Regulatory Guide 1.97 by providing Cate-gory 2 accumulator tank level instrumentation and provide justification for not complying with the Regulatory Guide 1.97 specified range cf 0 to 750 psig for the accumulator tank pressure.
3.3.5 Containment Atmosphere Temperature The applicant specifies Category 3 instrumentation for this variable instead of Category 2.
The applicant states that this is based on the fact that the plant emergency response guidelines do not require the operator to take action that would result in adverse consequences if the containment temperature were indicating an erroneous value.
The containment atmosphere temperature directly indicates the accomplish-I ment of a safety function (containment cooling), and is, therefore, a key variable. As such, Category 2 requirements should be met by the applicant.
3.3.6 Containment Sump Water Temperature The applicant indicates that this variable is not required, the justifi-cation being (a) the variable is not used by the operator to take corrective action, and (b) other parameters demonstrate that the safety injection system is operating properly when taking suction from the containment sump.
We. find this justification unacceptable. The applicant should provide the temperature instrumentation for the purpose outlined in the regulatory guide.
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3.3.7 Heat Removal by the Containment Fan Heat Removal System l
The applicant indicates that this variable is not required.
The appli-l cant states that (a) the containment spray flow indication, (b) the contain-ment spray system valve status indication, (c) the containment pressure indication, (d) the containment water level indication, (e) the containment spray sump status indication, (f) the containment fan cooler damper position indication, and (g) the containment fan cooler breaker position all provide indication to allow the operator to determine operability. These variables are identified by the applicant as Category 2.
Based on the above diversity, we find the alternate instrument acceptable.
I 3.3.8 Accident Sampling (Primary Coolant, Containment Air and Sump)
The applicant notes an exception for this variable. The justification provided by the applicant is that (a) these parameters are not used by the operator to take any manual action to mitigate the consequences of an accident, and (b) these parameters ere considered backup variables and are included as part of the post-accident sampling system.
The applicant takes exception to the guidance of Regulatory Guio i.97 with respect to post-accident sampling capability. This exception goes beyond i
the scope of this review and is being addressed by the NRC as part of their I
review of NUREG-0737, Item II.B.3.
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3.3.9 Boric Acid Charging Flow The applicant indicates that this variable is not required. The justi-fication is that (a) the refueling water storage tank level indication, (b) the high-head safety injection flow indication, (c) the low-head safety injection flow indication, (d) the containment water level indication, and (e) the Emergency Core Cooling System (ECCS) valve status monitor the per-formance of the emergency core cooling system. The normal charging flow and reactor coolant system (RCS) sampling is used to demonstrate that the RCS is being borated. The boric acid charging flow is not a safety injection system, nor is it used for emergency boration. Therefore, we find that this variable is not applicable at the Vogtle Station.
3.3.10 Degrees of Subcoolinq The applicant has identified this as a Type A variable. As such, Table 2 of Regulatory Guide 1.97 requires Category 1 instrumentation. The applicant is supplying Category 2 instrumentation. The NRC is re' viewing the accepta-bility of this variable as part of their review cf NUREG-0737, Item II.F.2.
3.3.11 Condenser Air Ejector Radiation The applicant has identified this as a Type A variable. As such, Table 2 of Regulatory Guide 1.97 requires Category 1 instrumentation. The applicant is supplying Category 2 instrumentat1on. No justificatien was given. The ap-
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plicant should provide Category 1 instrumentatio1.
3.3.12 -Areas of Additional Noncompliance t'
The following variables have not been addrersed or indicated in Table 7.5.2-1 by the applicant as complying to ti.a recommendations of Regula-i tory Guide 1.97, nor has the informatiod required by Section 6.2 of NUREG-0737, Supplement 1 been provided.
4 1.
Reactor Coolant System Soluble Baron Concentration 10
2.
Radioactivity Concentration or Radiation Level in Circulating Coolant 3.
Analysis of Primary Coolant (Gamma Spectrum) 4.
Containment Effluen' Radioactivity t
5.
Accumulator Isolation Valve Position 6.
Reactor Coolant Pump Status 7.
Quench Tank Level 8.
Quench Tank Temperature 9.
Quench Tank Pressure
- 10. High Level Radioactive Liquid Tank Level e
- 11. Radioactive Gas Holdup Tank Pressure
- 12. Emergency Ventilation Damper Position The applicant should provide the information required by-Section 6.2 of MUREG-0737 Supplement'1, identify any deviations from the requirements of
- Regulatory Guide 1.97 and provide justification for any non-compliance.
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CONCLUSIONS Based on our review, we find that the applicant conforms to or is justi-fied in deviating from the guidelines of Regulatory Guide 1.97 with the fol-lowing exceptions:
1.
Containment isolation valve status--the applicant should provide Category 1 instrumentation (Section 3.3.2).
2.
Pressurizer heater status--the applicant should provide the recom-
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mended instrumentation (Section 3.3.3).
3.
Accumulator tank level and pressure--the applicant should provide Category 2 accumulator tank level instrumentation; the applicant should provide justification for not complying with the recommended pressure range of C to 750 psig (Section 3.3.4).
4.
Containment atmosphere temperature--the appitcant should upgrade the instrumentation to Category 2 (Section 3.3.5).
5.
Containment sump water temperature--the applicant should provide the instrumentation recommended by the regulatory guide (Section 3.3.6).
- 6.. Condenser air ejector radiation--the applicant should upgrade this
-instrumentation to Category 1 as required for Type A variables (Sec-tion 3.3.11).
7.
Jhere are twelve variables for which the licensee should submit the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify' any deviation from the regulatory guide and justify these deviations (Section 3.3.12).
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REFERENCES 1.
D. G. Eisenhut, NRC letter to all licensees of operating reactors, ap-plicants for operating Ticenses, and holders of construction permits,
" Supplement No. I to NUREG-0737--Requirements for Emergency Response Capa-bility (Generic Letter No. 82-33)," December 17, 1982.
2.
Instrumentacion 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 of Standards Development, December 1980.
- 3.. Clarification of TMI Action Plan Requirements. Requirements for Emergency
' Response Capability, NUREG-0737 Supplement No. 1, NRC, Office of Nuclear Reactor Regulation January 1983.
4.
D. Outton to E. G. Adensam, Chief cf Licensing Branch #4, Division of Licensing, NRC, Georgia Power Company letter, "NRC Docket Numbers 50-424 and 50-425 Construction Permit Numbers CPPR-108 and CPPR-109 Vogtle Electric Generating Plar.t-U11ts 1 and 2 Supplement 1 to NUREG-0737 (Generic Letter No. 82-33)," April 14,1983.
5.
Final Safety Analysis Report (FSAR) for Vogtle Electric Generating Plant, Unit 1 and Unit 2.
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