ML20114D604

Conformance to Reg Guide 1.97,Millstone Nuclear Power Station,Unit 3

ML20114D604
Person / Time
Site:	Millstone
Issue date:	01/31/1985
From:	Udy A EG&G, INC.
To:	NRC
Shared Package
ML20107B835	List: ML20114D604
References
CON-FIN-A-6493, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8501310481
Download: ML20114D604 (22)

Text

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s ENCLOSURE e- ,

CONFORMANCE TO REGULATORY GUIDE 1.97 MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3.

NORTHEAST NUCLEAR ENERGY COMPANY DOCKET NO. 50-423 9

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CONFORMANCE TO REGULATORY GUIDE 1.97 .

,- MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3 4

A. C. Udy i

. Published January 1985 m ..... _

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s EG&G Idaho, Inc. . ,

Idaho Falls Idaho 83415 i

l Prepared for the U.S. Nuclear Regulatory Commission i

l Washington, D.C. 20555 i , Under DOE Contract No.' DE-AC07-76ID01570 . .

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ABSTRACT

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r This EG&G Idaho, Inc., report reviews the submittals foriUnit No. 3 of the Millstone Nuclear Power Station and identifies areas of noan nformance to Regulatory Guide 1.97 Revision 2. Exceptions to these guidelines are evalu '

ated and those areas where. sufficient basis for acceptability is not provided

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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 Regu-latory Commission Office of Nuclear Reactor Regulation, Division of Systems Integration, by Ed&G Idaho, Inc., NRC Licensing Support Sectio'n.

The 1.5. Nuclear Regulatory Consission funded the work u xier authoriza'-

tion B&R 20-19-40-41-3. , ,

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Docket No. 50-423 ii ,

C.ONTENTS

.. ABSTRACT ...........................-..... 11 W. I

-FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

! 1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . I

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

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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 . . . . . . . . ... . . . . 6

4. CONCLUSIONS . . . . . . . . . .............'...... 16 .

5. REFERENCES . .,. . . . . . . . . . . . . . . . . . . . . . . . . . . - 18 W . , .

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CONFORMANCE TO REGULATORY GUIDE 1.97 MILLSTONE NUCLEAR POWER STATION. UNIT NO. 3

' INTRODUCTION On December 17,.1982, Generi.c Letter No. 82-33 (Reference 1) was issued

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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 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3). , ,

Northeast Utilities, the' applicant for Unit No. 3 of the'M111 stone Nuclear Power Station, provided a response to the generic letter on April 15,

, 1983 (Reference 4). The letter referred to a previous letter dated

. February 2,1983 (Reference 5). for a r.eviet of the instrumentation provided -

for Regulatory Guide 1.97. Additional information was provided in letters .

/ dated December 16, 1983 (Reference 6), and January 13,1984(Reference 7).

This interim report provides an evaluation ef these submittals.

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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 applicant meets the r guidance of Regulatory Guide 1.97 as applied to emergency response facili-tie's. The' submittal'should include documentation that provides the following

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information for each variable shown in the appMcable table of Regulatory Guide 1.97.

1. Instrument range

2. Environmental qualification

3. Seismic qualification'

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4. Quality a'ssurance -

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5. Redundance and sensor location

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7. Location of display i

8. Schedule of installation or upgrade .

Further, the submittal should identify deviations from the guidance in the regulatory guide and provide supporting k stification or alternatives.

Subsequent to the issuance of the generic letter, the NRC held regional meetings'in February and March 1983, to answer licensee and applicant ques-ti.'ns'and concerns regarding the NRC policy on this matter. At these meet-ings, it wa'., noted'that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97. Further, where licensees or applicants explicitly state that instrument systems conform or will' conform to the pro-visio~ns of the guide it was noted that no further staff review would be.

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necessary.- Therefore, this report only addresses exceptions to the guidance of Regulatory Guide 1.97. The following evalua' tion is an audit of the ap-plicant'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 the NRC Generic Letter 82-33 on IApril 15, 1983. This response referred to an earlier submittal of February 2 1983, which described the applicant's position on post-accident monitoring i ins'trumentation. Additional information was provided on December 16, 1983 and

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January 13, 1984. This evaluation is based on these submittals.

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- 3.1 Adherence to Regulatory Guide 1.97 l Table 420.6-1 of the applicant's response dated December 16, 1983, and January 13, 1984, identifies each variable and shows whether or not the in-strumentation provided complies with the recommendations of Regulatory ,,

Guide 1.97. 'Therefore, it is ' concluded that the applicant has provided an explicit commitment on conformance to the guidance of Regulat6ry Guide 1.97, ,

i' except for those exceptions that were justified as noted in Section 3.3 of

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3.2 Type A Variables

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RegulatoryGuide1.97doesnotspecifically{identifyTypeAvariables, i.e., those variables that provide information required to permit the control room operator to take specific manually controlled. safety actions. The ap-

!_ plicant classifies the following instrumentation as Type A variables.

l i 1. Reactor coo W : system (RCS) pressure (wide range)

2. RCS hot leg water temperature (wide range)

3. RCS cold leg water temperature (wide range)

4. Steam generator level (wide range)

5. Steamgeneratorlevel(narrowrange) -

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6. Pressurizer level- .

!'- 7. Primary reactor containment pressure i-

8. Steamline pressure.

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9. Refuelingwaterstoragytanklevel ,

10. -Containment high range internal radiation monitor 1

11. Core exit temperature

12. Auxiliary feedwater flow ,

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13. Containment sump water flow q

14. Fuel drop monitors (containment radiation)

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15. RCSpressure(extendedrange)

H 16. Containment hydrogen concentration

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, 17. RCS subcooling monitor i

. . ':p i ) All of the above variables are also included as Type 9, C, or 0 variables and i

meet-Category 1 requirements consistent with the requirements for Type A vari-ables ' except for RCS subcooling monitor and as noted in Section 3.3. The applicant. considers the RCS subcooling monitor a type A,-

Category 2 backup variable.

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

3.3.1 Reactor Coolant System Soluble Baron Concentration Regulatory Guide 1.97 recomends Category 3 instrumentation with a range ,

of 0 to 6000 parts per mi1 Tion for this variable. The applicant does not pro- .

pose to provide instrumentation for this variable, saying that Category i neutron flux monitoring will adequately perform this function.

The applicant takes exception to the guidance of Regulatory Guide 1.97 with respect to post-accident sampling capability. This excep, tion 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.

- 3.3.2 Reactor Coolant System Cold and Hot Leo Temperature Revision 2 of Regulatory Guide 1.97 recommends Category 1 instrumentation

! - fo'r these variables with a range of 50 to 750*F.! The applicant has instru- '

m'entationfort$1svariablewitharangeof0to700*F,andwhichiscon-

. sidered non-redundant by the applicant.

The applicant states.that the " saturation pressure corresponding to 700*F-l- in approximately 3100 psia. Obtaining RCS pressures above this range would .

l require a highly improbable event, far beyond the design basis of the l

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plant."

l We find that the supplied instrumentation range is adequate. Further, Revision 3 of Regulatory Guide 1.97 (Reference 8) lists the upper limit recom -

mendation as 700*F. This is met by the licensee.

The applicant indicates in Table 7.5-1 of the Final Safety Analysis Re.-

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. port -(FSAR, Reference 9) that there is 1 channel per loop for this 4 loop e

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unit. We consider this as redundant instrumhntation, however, the applicant should show these four channels are separate an'd have independent power supplies.

'3.3.3 Coolant Level.in Reactor .

r The applicant has committed to supply instrumentation for this variable. The proposed instrumentation is Category 2 with a range from the

.. top of the vessel to the top of the core. This range is consistent with the recommendation of Revision 3 of the regulatory guide (bottom of hot leg to top of vessel). We find this range acceptable.

The applicant takes exception to the guidance of the Regulatory .

Guide 1.97 with respect to the category of the instrumentation. This excep-tion goes beyond the scope of this review and will be addressed by the NRC as part of their revTew of NUREG-0737. Item II.F.2. The acceptarice criteria for Item II.F.2 is the'same.as Category 1.for Regulatory Guide 1.97. _

3.3.4 RCS Subcooling Monitor ,

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The applicant has identified this as a Type A variable. As such, Table 2 of R.egula' tory Guide 1.97 recommends Category 1 instrumentation. The applicant is providing Category 2 instrumentation. The justification is that the opera-tor would use the monitor to determine subcooling; however, RCS pressure and temperature, in conjunction with a steam table, provides the same information. The NRC is reviewing the acceptability of this variable as part-of their review of NUREG-0737. Item II.F.2.

3.3.5 Containment Isolation Valve position ,

From the information provided, we find the licensee deviates from a strict interpretation of the Category 1 redundancy recommendation. Only the active valves have position indication (i.e., check valves have no position indication). Since redundant isolation valves are provided, we find that re-

, dundant indication per valve is not intended by the regulatory guide.

i Position indicat' ion of check valves is specifically excluded by Table 2 of.

Regulatory Guide 1.97. Therefore, we find that the instrumentation for this

! variable is acceptable.

x 3.3.6 Radiation Level in Circulating Primary Coolant-Regulatory Guide 1.97 recommends Category 1, continuous reading in-

strumentation with a range from 1/2 the technical specification limit to

-- 100 times the technical spe~cification limit. ,

The applicant states that the post-accident sampling system can provide this information with an isolated nuclear steam supply system. Main steamline and letdown line monitors provide information when the system is not '

isolated.

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Based on the~ justification provided by the licensee, we conclude that the

._. instrumentation su'pplied for this variable is adequate, and therefore, ~

acceptable. -

3.3.7 Containment Hydrogen Concentration -

Regulatory' Guide 1.97 recommends instrumentation'for thisivariable with a sensor capable of operating down to 10 psia. The applicant's sensor is cap-able of operating down to.0.8 atmosphere (11.76 psia). -

Section 6.2.1.1.2 of the. FSAR identifies M111'stione 3 as having a sub-

-atmospheric type containment. Normal operation is with the atmospheric pres-sure between 9.0 and 12.5 psia. The internal minimum design pressure is 8.0 psia. The containment pressure is returned to subatmospheric within one hour of an accident.

The operability of the containment hydrogen concentration sensors has not been established in the post-accident situation. The applicant should show

< that these sensors will operate in any postulated containment' environment.

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3.3.8 Residual Heat Removal Heat Exchanaer Outlet Temoerature Revision 2 of Regulatory Guide 1.97 recommends a range of 32 to 350*F.

The applicant has supplied instrumentation with a range of 50 to 400*F. The

_ lower limit of the range supplied does not conform to,either revision of the regulatory guide.

The applicant did not provide justification for this. deviation. The ap-plican: should either provide a new instrumentation span so that the recom-

. mended range is covered, or provide justification for not providing the recommended range.

3.3.9 Accumulator Tank Level ,,

Regulatory Guide 1.97 recommends Category 2 instrumentatian for this variable with a range of 10 to 90 percent of the accumulator volume. The applicant states that the " accumulator pressure indication and valve position w indicatiqn for the accumulator discharge isolation and accumulator vent valves provide adequate status of the accumulators."

Section 6.3.5.4 of the FSAR indicates that there are two level instrumen-tation channels, with control room indication and high and low level alams, for each accumulator.

l The applicant has not provided the information required by Section 6.2 of NUREG-0737, Supplement No. 1 for the level instrumentation. Therefore, we are unable to conclude that the instrumentation provided for this variable is ac-ceptable. The applicant should provide the required information, identify any

' deviation from Regulatory Guide 1.97, and provide satisfactory justification

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for that deviation.

3.3.10 Accumulator Tank Pressure l

Regulatory Guide 1.97 recommends instrumentation for this variable with a range.of 0 to 750 psig. The applicant is providing instrumentation with a t

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range of 0 to 700 psig. 700 psig is the design pressure of the accumulators and the same pressure at which the accumulator safety relief valves operate, as identified in Table 6.3-1 of the FSAR. The applicant indicates that the j normal operating pressure of the accumulator is manual controlled at l

, 650 psig. -Thus, there is margin between the normal operating pressure and the set' point of the isafe'ty relief valves. Based on this, we find that the in- i strumentation supplied by the applicant for this variable is acceptable.

3.3.11 Boric Acid Charging-Flow Regulatory Guide 1.97 recommends instrumentation for this variable. The applicant does not supply instrumentation for this variable as "the ECCS (emergency core cooling system).does not normally take suction from the boric acid tank." Should the boric hcid tank be used for boration following an ac-cident, the applicant demonstrates boration of the reactor coolant system by normal charging flow and reactor coolant system sampling. -

The applicant does not have instrumentation for this variable. The ap

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plicant states that the units do not have boric acid charging flow as a safety

/ injection system. Centrifugal charging pump flow, safety. injection flow and residualheatremovalflowarethesafetyinject(onvariablesmonitored.

Therefore, we find that.this variable is not appl'icable at Millstone 3.

3.3.12 Reactor. Coolant Pump Status Regulatory Guide 1.97 recommends instrumentation to monitor the reactor

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coolant pump motor current. The applicant is not supplying instrumentation for this' variable stating that " Millstone 3 has not selected this variable as a post-accident variable."

Deper. dent on the accident conditions, the reactor coolant pumps may or may not be operatirig. When they are operating, the motor current is a valu-abl'e aid to the operator in diagnosing approach to cavitation, pump seizure and shaft break conditions. As this information can be valuable in

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mitigating the consequence of an accident, we recommend that the applicant in-stall the recommended instrumentation.

3.3.13 Pressurizer Heater Status Regulatory Guide 1.97 recomends Category 2 electric current instrumenta-l tion for this variable, to determine the operating status of the heaters. The I applicant has supplied circuit breaker position indication' for this variable, I indicating t' hat this deviat' ion is for " hardware corsiderations."

Section II.E.3.1 of NUREG-0737 requires a number of the~ pressurizer heat-ers 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 Standard

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Techn1 cal Specifications, Section 4.4.3.2, requires that the emergency pres-

, surizer heater cufrent be measured quarterly. These heaters,'as required by

& NUREG-0737,'should'have the current instrumentation recommended by Regulatory _

Guide 1.97. -

3.3.14 Steam Generator Pressure Regulatory' Guide 1.97 recommends instrumentation for this variable with a .

range from atmospheric pressure to 20 percent above the lowest safety valve

setting. The applicant has supplied instrumentation for this variable with a -

range of 0 to 1300 psia. The applicant indicates that this is an exception from the regulatory guide recommendations, stating that the shell design pres-sure of the steam generator is 1200 psia.

. We have not been able to determine what the settings of the steam genera- .

i tor safety valves are. Even though the supplied range covers to 108 percent j of the shell design pressure, the applicant should provide information on the lowest and the highest safety valve setpoints .

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3.3.15 Containment Spray Flow

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Regulatory Guide 1.97 recommends environmentally qualified Category 2 in-

.strumentation for this variable. The applicant has supplied Category 3 in-strumentation that, as far as we are able to determine, is not Category 2 in the' area of environriental qualification. -

The environmental qualification guidance of Regulatory Guide 1.97 has '

been superseded by the environmental qualification rule,10 CFR 50.49. There-fore, environmental qualification is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.

3.3.16 Heat Removal by the Containment Fan Heat Removal System ,,

Regulatory Guide 1.97 recommends plant specific instrumehtation for this variable. The applicant has not a supplied instrumentation.fer this vari-able. The applicant's justification for this deviation is:

"Other parameters were designated as Millstone 3 Type D variables to demonstrate that the containment heat removal systems are operating properly., These include the following. ,

- Containment spray system valve status.

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. 3 Containment pressure. i Containment water level." g As the containment spray system does not affect the containment fan. heat. .

removal systems, and containment pressure.and water level are affected by the containment fan heat removal system and the containment spray system and is a function of break size and location, we do not concur with the applicant's position. These variables do not show conclusively that the containment fan heat removal system is operating.. , ,

The applicant should provide the recommended instrumentation for this variable. -

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3.3.17 Containment Sumo Water Temperature -

Regulatory Guide 1.97 recommends instrumentation for this variable. The l applicant has not supplied this instrumentation, based on the following

_; justification: -

,- " Containment sump water temperature indication is not utilizcd by the i

operator to take corrective action. Other parameters were designated as Millstone 3 Type D variables to demonstrate that the safety injection

, system is operating properly when taking suction with the containment sump."

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We find that the justification presented by the applicant for this vari-able does not address the purpose of this variable. Therefore, the justifi-cation is not acceptable. The applicant should either provide the recommended

. instrumentation, or provide fu'rther justification for this deviation that ad-dresses the purpose of this variable.

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3.3.18 Makeup Flow-In .

Regulatory Guide 1.97 recommends Category 2 instrumentation for this ,

e . variable. The applicant does not have instrumentation that provides a direct measure of this variable, stating that they have not designated makeup flow as a post-accident' variable.

. Section 9.3.4.1 of the FSAR (Reference 9) indicates that the chemical _

volume and control system is used to. achieve a safety-grade shutdown. The

, makeup flow is composed of the charging flow and the reactor coolant pump seal injection flow. The applicant does monitor these flows, but has not indicated the category of the instrumentation used. -

Since the component flows that composi the makeup flow are monitored, we find this deviation acceptable, if the applicant verifies that the instrumen-tation is Category 2.

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3.3.19 Volume C'ontrol Tank Level Regulatory. Guide 1.97 recomends instrumentation for this variable with a range from top to bottom. The applicant has instrumentation for this variable ev with a range from " bend line to bend line". This refers to the transition l

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between the cylin'rical d portion of the tank and the hemispherical ends of the tank. Based on this, the range deviation is acceptable.

3.3.20 Component Cooling Vater Temperature to ESF System .

Regulatory Guide 1.97 recomends Category 2 instrumentation for this variable. The applicant has not provided instrumentation for this variable, stating that "other parameters were designated as Millstone 3 type D variables to demonstrate that the ESF components were being cooled. These include CCW pump status, CCW valves status and CCW header temperature." Table 7.5-1 of the FSAR (Referende 10) shows that the CCW header temperature'is of the recom-mended range and chtegory. However, Table 9.2-1 shows that there are many ESF components cooled by the service water system. We were unable to determine that this system has temperature instrumentation. Therefore, we find this deviation not acceptable. The applicant should show that-the temperature of th'ecoolingwatertoeachESFsystemcomponentid.knowntobewithindesign limits. \ T '

3.3.21 High Level Radioactive Liquid Tank Level .

Regulatory Guide 1.97 recommends instrumentation for this variable.. The ,

applicant does not have instrumentation for this variable, stating that they have "not designated High Level Radioactive Liquid Tank Level as'a Post Ac-cident Variable."

This justification does not address the purpose of the variable, there-fore the deviation is not acceptable. The licensee should either supply the recommended instrumentation or provide justification for not supplying it that addresses the purpose of the variable. ~

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3.3.22 Radioactive Gas Holdup Tank Pressure.

4 Regulatory Guide 1.97 recommends instrumentation for this variable.

Millstone 3 does not have radioactive gas holdup tanks, using a charcoal delay

. system instead. Thus, instrumentation for this variable is not needed.

3.3.23 Containment or Purge Effluent-Vent Flow Rate Regulatory Guide 1.97 recomends instrumentation for this variable with a range of 0 to 110 percent of design flow. The applicant has instrumentation-for this ventilation vent flow rate that is from 10,000 (4.3 percent of design flow) to 260,000 cubic feet per minute (113 percent of design flow). We find the deviation (measuring down to 4.3 percent of design flow instead of 0 per-cent) insignificant, as the ventilation vent flow would be higher than this for any one blower in operation. Therefore, we find this deviation acceptable. '.

3.3.24 All Othe.r Identified Release Points -

Hydrogen recombiner cubicle ventilation-noble gas--Regulatory Guide 1.97 -

recommends instrumentation for this variable with a range of 10-6 to 10+2 uCi/cc. The applicant has supplied instrumentation for this variable; how-ever, the range is 7.1 x 10-4 to 6 uC1/cc. The applicant did not provide justification for this deviation.

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Turbine driven auxiliary feedwater pump steam exhaust-noble gas- -

Regulatory Guide 1.97 recommends instrumentation for this variable. The ap-plicant 'has grouped it under "all other identified release points," which .

l recommends a range of 10-6 to 10+2 uC1/cc. This recomended range is for measuring releases from containment. For the steam exhaust the range for vent from steam generator safety relief valves, 10-1 to 10+3 uC1/cc would be ap-f ~

l propriate. This is the range supplied by the app 11 cant.

The applicant should provide justification for the deviation from the recommended range for the hydrogen recombiner cubicle ventilation noble gas.

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4 .' CONCLOSIONS Based on our review, we find that the licensee conforms to or is justi-fied in deviating from the guidance of Regulatory Guide 1.97 with the follow-ing exceptions:

1. Reactor coolant system cold and hot leg temperature--the~ applicant should

(~ show that the four hot leg and the four cold leg channels have appropri-ate separation and independent power supplies (Section 3.3.2).

j 2. Containment hydrogen concentration--the applicant should demonstrate that these detectors will operate as specified in any postulated post-accident-environment (Section 3.3.7).

3. RHR heat exchanger outlet temp'erature-the applicant should either pro-vide the instrument range recomended by Regulatory Guide 1.97 or justify

deviating fEom the recommended range (Section 3.3.8).

4. Accumulator tank level--the applicant should provide the information re-

, quired by Section 6.2 of NUREG-0737, Supplement No.1, note arty deviations from the recommendations of Regulatory Guide 1.97 and provide satisfac-

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tory justification for any deviation (Section 3.3.9). '

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5. Reactor coolant pump status--the applicant should install the recommended i

instrumentation (Section 3.3.12). - -

6. Pressurizer heater status--the applicant should provide the instrumenta- .

tion'recommendedbyRegulatoryGuide1.97(Section3.3.13).

7. Steam generator pressure--the applicant should provide additional infor-mationonsafetyreliefvalvesetpoints(Section3.3.14).

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8. Containment spray flow--Environmental qualification needs to be addressed in accordance with 10 CFR 50.49 (Section 3.3.15). . ,

, 9. Heat removal by the containment ~ fan heat removal system--the applicant should provide the recomended instrumentation for this variable-(Sec-tion 3.3.16). *

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10. Containment sump water temperature--the- applicant should either supply the recommended instrumentation or provide additional justification for not supplying it (Section 3.3.17).

y 11. Makeup f. low-in--the applicant should verify the alternate.' instrumentation used for this variable is. Category 2 (Section 3.3.18). .

12. Component cooling water temperature to ESF system--the applicant should show that the temperature of the cooling water to each.ESF system compo-nent is known to be within design limits (Section 3.3.20).

13. High level radioactive liquid tank level--the applicant should either supply the recommended instrumentation, or provide additional justi. fica-

' tion for not doing so (Se'ction 3.3.21).

14. All other identified release points--the applicant should provide justi-fication for the deviation from the recommended range for the hydrogen

(('~ recombinercubicleventilation--noblegas(Section3.3.24).

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5. REFERENCES

1. NRC letter, D. G. Eisenhut to all Licensees of Operating Reactors, Ap-plicants for Operating Licenses, and Holders of Construction. Permits,

" Supplement No. I to NUREG-0737~-Requirements for Emergency Response Capa-i ,: - ,

bility (Generic Letter No. 82-33)'," December 17.-1982.

I_ 2. Instrumentation for Light-Water-Cooled Nuclear Power Plant's to Assess 1 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.

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i 3. Clarification of'TMI Action Plan Requirements. Requirements for Emercency '

Response Capability, NUREG-0737 Supplement No.1, NRC, Office of Nuc' ear Reactor Regulation, January 1983.

4. Northeast Utilities letter, W. G. Counsil to D. G. Eisenhut, NRC, " Supple-ment 1 to NUREG-0737, Requirements for Emergency Response Capability (Generic Letter No. 82-33)" April 15, 1983. A02959.

, '5. Northeast Utilities letter, W. G. Counsil to H. R. Dento NRC, "Applica- .

tion for an Operating License", February 2, 1983, B10671

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6. Northeast NucTear Energy Company letter, W. G. Counsil to Director of -

4 Nuclear" Reactor Regulation, NRC, " Response to Question 420.06."

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December 16, 1983, A03541.

7. Northeast Nuclear Energy Company letter, W. G. Counsil to Director of 4

Nuclear Reactor Regulation, NRC, " Response to Question 420.6 " January 13, 1984, 811002. .

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8. Instrumentation for' Light-Water-Cooled Nuclear Po er Plahts to Assess * ~

Plants and Environs Conditions During and Following an Accident Regula-tory Guide.l.97, Revision 3. NRC, Office of Nuclear Regulatory Research, May.1983.

9. Millstone Nuclear Power Station Unit 3, Final. Safety Analysis Report.

Revision 0.

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n .

l , ,

i e

18

- . _ _ . - - _ _ _ _ _ _ . .