ML20116E022
| ML20116E022 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/04/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20116D885 | List:
|
| References | |
| FOIA-96-237 NUDOCS 9608050046 | |
| Download: ML20116E022 (4) | |
Text
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4 ENCLOSURE 1
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UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION
]
g
- j WASHINGTON,0. C. 20555
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SUPPLEMENTAL SAFETY EVALUATION REPORT 4
BALTIM0RE GAS AND ELECTRIC CALVERT CLIFFS NUCLEAR POWER PLANT UNIT NOS. 182 DOCKET NOS. 50-317/318 CONFORMANCE TO REGULATORY GUIDE 1.97 1
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1.0 INTRODUCTION
The staff completed its review of the licensee's conformance to Regulatory Guide (R.G.) 1.97, Revision 2, by providing the staff's safety evaluation to the licensee, on January 6,1987. The staff found that the licensee's design was acceptable with respect to conformance to R.G. 1.97 with the exception of the variables containment sump water level (narrow range), containment sump water temperature, safety injection tank level or pressure (accumulator tank level and pressure), and component cooling water flow to the ESF system. By letter dated March 10, 1987 the licensee requested that the staff reevaluate these issues.
A detailed review and technical evaluation of these four issues was performed by EG&G Idaho, Inc., under contract to NRC, with general supervision by the NRC staff. This work is reported by EG&G in their revised Technical Evaluation Report (TER), "Confonnance to Regulatory Guide 1.97, Calvert Cliffs -1 and -2, Revision 1," dated September 1987 (enclosed). We have reviewed this report and concur with the conclusions that the licensee either conforms to, or is justified in deviating from, the guidance of R.G.1.97 for the variables containment sump water level (narrow range) and component cooling water flow to the ESF system. We however do not concur with the conclusions for the variables accumulator tank level and pressure and containment sump water temperature.
9608050046 960731 PDR FOIA DINICOL96-237 PDR
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l 2.0 EVALUATION We have reviewed the evaluation perfonned by EG8G contained in the enclosed TER and concur with its basis and findings except for the findings contained in TER sections 3.3.7 and 3.3.14 concerning accumulator tank level and pressure l
and containment sump water temperature respectively. For the remaining items l
we agree with EG8G findings that the licensee either confonns to or has acceptably justified deviations from the guidance of R.G. 1.97.
In TER section 3.3.7 EG&G concluded that for the variable accumulator tank level and pressure, the licensee should designate either level or pressure as the key variable to directly indicate accumulator discharge and provide instrumentation for that variable that meets the requirements of 10 CFR 50.49.
The staff, however, is currently generically reviewing the need for environ.
mentally qualified Category 2 instruments to monitor accumulator tank level and pressure. We will, therefore, report on the acceptability of this item when the generic review process is complete.
In TER section 3.3.14 EG&G concluded that for the variable containment sump water temperature, the licensee should provide environmentally qualified instrumentation that will allow a quantitative look at the operation of the heat removal from the containment sump or identify suitable alternate instrumentauon that meets the Category 2 requirements. The staff, however, is currently generically reviewing the need for environmentally qualified Category 2 instruments to monitor containment sump water temperature. We will therefore report on the acceptability of this item when the generic review process is complete.
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3.0 CONCLUSION
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Dased on the staff's review of the enclosed TER and the licensee's submittals, we find that the Calvert Cliffs Nuclear Power Plant design for the containment j
sump water level (narrew range) instrumentation and the component cooling l
water flow to the ESF system is acceptable with respect to conformance to R.G.
l 1.97, Revision 3.
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The acceptability of instrumentation for accumulator tank level and pressure y
and containment sump water. temperature will remain open pending the outcome of j-the staff's generic review of the need for environmentally qualified Category j
2 instrumentation to monitor these variables. We will therefore report on the q
accept 6bility of these issues when the generic review process is complete.
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ENCLOSURE 2 I
c ICS8/ DEST SALP INPUT 4
i PLANT: Calvert Cliffs Nuclear Power Plant Unit Nos.1&2
)
LICENSEE: Baltimore Gas and Electric Company DOCKET NO: 50-317/318 SER
SUBJECT:
Emergency Response Capability - Conformance to R.G.1.97, J
Rev. 2 1
i PERFORMANCE PARAMETERS:
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Management Involvement in Assuring Quality I
Approach to Resolution of Technical Issues From a Safety Standpoint I
Response to NRC Initiatives I,,
Staffing (Including Management) 4 I; I Reporting and Analysis of Reportable Events Training and Qualification Effectiveness (I
Any Other SALP Functional Area i
PERFORMANCE NARRATIVE DESCRIPTION OF CATEGORY /
PARAMETER APPLICANT / LICENSEE'S PERFORMANCE RATING 1
No basis for assessment.
N/A 2
The licensee demonstrated an adequate 1
l understanding of the issues and provided technically sound justification supporting their positions.
I 3 thru 7 No basis for assessment.
N/A i
i OVERALL APPLICANT / LICENSEE PERFORMANCE RATING 1
a
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EGG-NTA-7071 Revision 1 TECHNICAL EVALUATION REPORT CONFORMANCh TO REGULATORY GUIDE 1.97:
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CALVERT CLIFFS-1 AND -2 Docket Nos. 50-317 and 50-318 J. W. Stpffel Published September 1987 Idaho National Engineering Laboratory 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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I ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97 for Unit Nos. I and 2 of the Calvert Cliffs Nuclear Power Plant and identifies areas of nonconformance to the regulatory guide.
Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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Docket Nos. 50-317 and 50-318
. TAC Nos. 51078 and 51079 11
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l FOREWORD This report is suppited 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 Engineering and System Technology, by EG&G Idaho, Inc.,
Electrical Instrumentation and Control Systems Evaluation Group.
The U.S. Nuclear Regulatory Commission funded the work under authorization B&R 20-19-10-11-3.
Docket Nos. 50-317 and 50-318 TAC Nos. 51078 and 51079 111 i
l CONTENTS l
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ABSTRACT..............................................................
11 FOREWORD..............................................................
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1.
INTRODUCTION.....................................................
1 2.
REVIEW REQUIREMENTS..............................................
2 3.
EVALUATION.......................................................
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l 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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1 4.
CONCLUSIONS......................................................
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5.
REFERENCES.......................................................
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e CONFORMANCE TO REGULATORY GUIDE 1.97:
CALVERT CLIFFS-1 and -2 1.
INTRODUCTION i
On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was.
4 1ssued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear
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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) relating to the requirements for emergency response capability. These requirements have been published as Supplement No. I to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Baltimore Gas and Electric Company, the licensee for the Calvert i
Cliffs Nuclear Power Plant, Unit Nos. I and 2, provided a response to the Regulatory Guide 1.97 portion of the generic letter on December 1,1984 (Reference 4). Additional information was provided on February 21, 1986 (Reference 5) and March 10, 1987 (Reference 6).
This report provides an evaluation of these submittals.
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2.
REVIEW REQUIREMENTS Section 6.2 of NUREG-0737, Supplement No. 1, sets forth the documentation to be submitted in a report to the NRC describing how the licensee complies with Regulatory Guide 1.97, as applied to emergency response facilities.
The 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 8.
Schedule of installation or upgrade The submittal should identify deviations from 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 March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on this subject.
At these meetings, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97. Where licensees or applicants explicitly state that instrument systems conform to the regulatory guide, 2
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it was noted that no further staff review would be necessary. Therefore, this report only addresses exceptions to Regulatory Guide 1.97.
The i
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 I
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The lice.nsee provided a response to NRC Generic Letter 82-33 on-December 1, 1984. Additional information was provided on February 21, 1986 4
and March 10, 1987.
The responses describe the' licensee's position on 4
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~ post-accident monitoring instrumentation. This evaluation is based on i
i these submittals.
i 3.1 Adherence to Regulatory Guide 1.97 i
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'The licensee provided an account of the conformance of the Calvert j
Cliffs Nuclear Power Plant, Unit Nos. I and 2, to Revision 3 of Regulatory
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Guide 1.97 (Reference 7). The licensee states that the information j
provided in their submittal meets the requirements of Supplement No.1 to NUREG-0737, Section 6. -The licensee will complete any modifications
. identified to provide compliance to Agulatory Guide 1.97 prior to the startup following the cycle 10 refueling outage (Unit 1 ~ Spring 1988), and the cycle 9 refueling outage (Unit 2 - Fall 1988) (Reference 8).
Therefore, we conclude that the lice,nsee has provided an explicit j
commitment on conformance to Regulatory Guide 1.97.
Exceptions to and l
deviations from the regulatory guide are noted in Section 3.3.
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3.2 Type A Variables i
j Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide the information required to permit the f
control room operator to take specific manually controlled safety actions.
l The licensee classifies the following instrumentation as Type A.
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Pressurizer level 2.
Pressurizer pressure 3.
Steam generator pressure 9
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Steam generato,r level 5.
Reactor coolant system (RCS) hot leg temperature 6.
RCS cold leg temperature
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7.
Degrees of subcooling 8.
Condensate tank No.12 level 9.
Containment hydrogen concentration
- 10. Containment pressure
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The above instrumentation meets the Category I recommendations consistent with the requirements for Type A variables.
3.3 Exceptions to Regulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97.
These are discussed in the following paragraphs.
3.3.1 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable.
In Reference 5, the licensee has committed to install environmentally qualified wide range instrumentation for this variable that will meet the guidelines of Regulatory Guide 1.97. We find this commitment acceptable.
3.3.2 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends a range of 0 to 6000 ppe for this variable. The licensee has instrumentation that covers a range of 5
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i O to 5000 pm. The lice'nsee's justification is that this boren meter is adequate for any anticipated boron concentration.
The licensee deviates from Regulatory Guide 1.97 with respect to the range of this post-accident sampling capability.
This deviation 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 Core Exit Temperature Regulatory Guide 1.97 recommends Category 1 instrumentation that is environmentally qualified and that has a range of 200 to 2300*F. The licensee has instrumentation with a range of 32 to 2000*F that is not environmentally qualified.
In Reference 5 the licensee has committed to environmentally qualify this instrumentation and install new indicators that will measure the recommended range. We find this commitment acceptable.
3.3.4 Degrees of Subcooling Regulatory Guide 1.97 recommends a range of 200*F subcooling to 35'F superheat for this variable. The licensee has instrumentation that calculates the subcooled margin over a range of 100 to 0*F of subcooling.
The licensee justifies this range deviation by stating that the provided range is adequate to meet the needs of the emergency operating procedures.
Manual calculation of the saturation margin over a greater range can be done using the RCS temperature and pressure.
The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737, Item II.F.2.
e 3.3.5 Containment Sump Water Level Regulatory Guide 1.97 recommends Category 2 instrumentation for the narrow range instrumentation associated with this variable. The licensee takes exception to the environmental qualification recommended for 6
Category 2 instrumentat, ton.
The licensee stated in Reference 4 that this equipment is used only during normal operation and that post-accident monitoring is accomplished by the wide range instrumentation.
In Reference 6, the licensee states that pressurizer level in conjunction with cycling of the charging pumps is the key method for early detection of a RCS break at CCNPP. The licensee considers narrow range containment sump
~~ water level to be backup or diagnostic instrumentation, for which environmental qualification is not required.
Based on the additional information provided in Reference 6, we conclude that the existing containment sump water level instrumentation is aCCeptabl e.
3.3.6 Radiation Level in Circulating Primary Coolant The licensee has provided one instrument loop to measure activity over a range of 0 to 10 counts per minute. This instrument is only used during normal operation to monitor gross activity changes. This instrument is isolated in the event of safety injection actuation. Post-accident l
monitoring is accomplished by grab sample analysis using the post-accident sampling system, which is being reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3.
Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.
3.3.7 Accumulator Tank Level and Pressure The licensee takes exception to the pressure range (0 to 750 psig) and environmental qualification recommended by Regulatory Guide 1.97 for this variable. The licensee stated in Reference 4 that the safety injection 1
tank (SIT) level and pressure is only used for pre-accident indication of the status of SITS to assure that the safety injection system is prepared to serve its safety function. The licensee further states that no outside f
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J power source, signal, or' operator action is required for their operation during a design basis accident.
In Reference 6, the licensee adds further justification for considering this instrumentation as backup or diagnostic instrumentation requiring a Category 3 classification. The licensee states that since this variable is not listed as a Type B variable (plant safety
-function) it is considered only as a measure of the system operating
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status. The licensee further states that knowing if the accumulator discharged or not, is not useful to the operator.
The accumulators discharge very early in the event of a large break LOCA.
Even if the operators were aware of accumulator failure, they could not take action soon enough to change the outcome of the event.
The existing instrumentation is not acceptable. An environmentally qualified instrument is necessary to monitor the status of these tanks.
The licensee should designate either level or pressure as the key variable to directly indicate accumulator discharge and provide instrumentation for that variable that is qualified to the requirements of 10 CFR 50.49.
The licensee states that the pressure instrumentation provided (0 to 250 psig) is adequate to monitor the status of these tanks,'and that the existing range will not be exceeded since relief valves on the tanks are set to relieve at 250 psig. We find that the ranges of the instrumentation supplied for this variable are adequate to determine that the accumulators have discharged.
3.3.8 Flow in High Pressure Injection System The range is not as recommended by Regulatory Guide 1.97 (0 to 110 percent of design flow). The instrumentation.provided covers a range of 0 to 300 gpm.
4 In Reference 5, the licensee states that based on accident analysis and flow calculations, the maximum flow is expected to be approximately 200 gpm. This is well within the O to 300 gpm range of the existing instrumentation and is, therefore, acceptable.
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3.3.9 Refueling Water Storage Tank Level Regulatory Guide 1.97 recommends a range of top to bottom for this variable. The licensee has provided instrumentation for this variable with a range that spans from 18 inches above the tank bottom to 12 inches below the tank top. The licensee states that the instrumentation meets the
_" guidelines for post-accident monitoring.
We find this deviation minor with respect to the overall size of the tank. The existing instrumentation is adequate to monitor the operation of the storage tank during all accident and post-accident conditions.
Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.10 pressurizer Heater Status 1
The licensee takes exception to using electric current to monitor all l
of the heater groups. Ammeters are provided for the two proportional heater banks only. All six heater banks have on-off indicating lights.
s In Reference 5, the license 2 states that after a safety injection actuation signal, the back-up heaters can only be added manually by an 4
operator. The current of the energized heaters can be monitored from the load center ammeters or the diesel kilowatt meter. Therefhre,wefindthat the existing instrumentation is adequate to monitor the pressurizer heater current and is acceptable.
3.3.11 Quench Tank Level Regulatory Guide 1.97 recommends a level range from the top to the bottom of this tank. The itcensee has provided instrumentation that i
i corresponds to 4 percent to 96 percent of the tank volume. The licensee states that while the range is less than required, the instrumentation provided is adequate and sufficient for the intended post-accident l
monitoring function.
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We find this deviation minor with respect to the overall size of the tank. The existing instrumentation is adequate to monitor the operation this tank during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
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~3 3 12 Steam. Generator Level Regulatory Guide 1.97 recommends instrumentation that reads from the tube sheet [445 inches below normal operating level (NOL)] to the separators (39 inches above NOL). The licensee has provided instrumentation that reads from 401 inches below NOL to 63.5 inches above NOL. The licensee states that while the range is slightly less than required by Regulatory Guide 1.97, it is adequate for post-accident monitoring.
The steam generator is, in effect, empty at -401 inches of water relative to the normal operating level.
Therefore, we find that this j
deviation is minor when compared to the overall range and instrument accuracy. The existing range is adequate for the intended monitoring function.
1 3.3.13 Containment Atmosphere Temperature l
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Regulatory Guide 1.97 recommends 400'F for the upper range limit. The licensee has provided instrumentation that reads to 300*F. The licensee states that the maximum temperature predicted inside the containment during a postulated accident is 274*F.
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Since the worst case postulated accident will not increase the containment atmosphere temperature above 274*F, we find the range of 0 to 300*F adequate to monitor this variable during all accident and post-accident conditions.
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3.3.14 Containment Sump Water Temperature j
The licensee does not have instrumentation for the containment sump l
water temperature.
In Reference 4, the licensee justifies this deviation l
by stating that this variable is not used in the management of a design basis accident and that it is not required for post-accident monitoring
~tecause the minimum net positive suction head (NPSH) requirements are not dependent on the sump water temperature.
In Reference 6 the licensee points out that the containment spray system is the method of containment cooling at CCNPP. Water from the containment sump passes through shutdown cooling (SDC) heat exchangers to the containment spray header nozzles. The flow and outlet temperature of the SDC heat exchangers.are monitored with Category 2 instrumentation.
Therefore, the licensee believes the basis given in Regulatory Guide 1.97 (monitor the operation of the containment cooling system) has been satisfied without providing instrumentation to monitor the containment sump temperature.
This is insufficient justification for this exception. The licensee should provide environmentally qualified instrumentation that will allow a quantitative look at the operation of the heat removal from the containment sump or identify suitable alternate instrumentation (such as RHR heat exchange inlet temperature) that meets the Category 2 requirements.
3.3.15 Makeup Flow-In Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of 0 to 110 percent design flow for this variable. The instrumentation provided monitors 0 to 94 percent of design flow and does not meet all Category 2 criteria. The licensee justifies this deviation by stating that this variable is not required for post-accident monitoring and is isolated in the event of a safety injection actuation.
As this variable is not utilized in conjunction with a safety system, we find that the instrumentation provided is acceptable.
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3.3.'16 Letdown Flow-Oui.
Volume Control Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables and a level range of top to bottom for the volume control tank.
-The provided instrumentation does not meet the Category 2 requirements for either of these variables and the range monitored for the volume control tank is 8 to 86 percent of the tank volume. The Itcensee states that the level indication of the volume control tank is used only during normal operation and the existing range is adequate for this use.
Furthermore, the letdown line and volume control tank make-up to the reactor coolant system is isolated in the event of a safety injection actuation.
As these variables are not utilized in conjunction with a safety system, we find the instrumentation provided is acceptable.
3.3.17 Component Cooling Water Temperature to Engineered Safety Features (ESF) System i
The licensee deviates from the range recommended by Regulatory Guide 1.97 (40 to 200*F) for this variable. The licensee has provided a range of 50 to 200*F and states that this range is adequate and sufficient for post-accident monitoring.
The deviation of 10*F out of the maximum span of 200*F is 5 percent.
We consider this deviation minor and acceptable.
3.3.18 Component Cooling Water Flow to ESF System In Reference 4, the licensee states that they do not have flow indicators for this variable. The licensee stated that an evaluation of the need for this instrumentation is being conducted.
If the review indicates the flow instrumentation is needed it will be provided.
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In Reference 6, the licensee has committed to upgrade the component i
cooling water header pressure and water temperature instrumentation to Category 2 requirements. The licensee states that these instruments will alert the operators of all system malfunction with the exception of system blockage or the inadvertent closing of an isolation valve. The isolation valves are locked open and checked monthly and the 3/4 inch minimum piping
~ with chemistry controlled water is unlikely to clog.
Based on the additional justification submitted by tt.? licensee we conclude that the instrumentation provided for this variable is acceptable.
l 3.3.19 High-Level Radioactive Liquid Tank Level Regulatory Guide 1.97 recommends instrumer.tation for this variable that reads from the top to the bottom of the tank.
The licensee has provided instrumentation that reads from 73 inches above the bottom to 60 inches below the top of the hemispherical ended tank. This corresponds to 93 percent of the tank volume. The licensee states that the instrumentation provided is adequate for post-accident monitoring.
We find this deviation minor with respect to the overall size of the tanks. The existing range is adequate to monitor the operation of these tanks during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.20 Radioactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends a range for this variable to cover 0
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to 150 percent of the design pressure. The instrumentation provided has a range of 0 to 150 psig which is 0 to 100 percent of design pressure. The justification given by the licensee is that the upper range limit of 100 percent of tank design pressure is adequate for post-accident monitoring and that above 150 psig, the holdup tanks relieve excess pressure to the surge tank.
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1 Based on the justification provided by the licensee, we conclude that the instrumentation provided for this variable is adequate to monitor the j
operation of these tanks and is, therefore, acceptable.
3.3.21 Radiation Exposure Rate
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Regulatory Guide 1.97 recommends a range of 10 R/hr to 10 R/hr for this variable.
The licensee has provided instrumentation with a range of 0.1 mR/hr to 10 R/hr. The licensee justifies this deviation by. stating that the intended function of.this instrumentation is personnel protection and the existing range is sufficient for that purpose. Detection of releases, release assessment and surveillance are performed through health l
physics procedures with supplemental information provided by the effluent l
monitors.
From a radiological standpoint, if the radiation levels reach or exceed the upper limit of the range, personnel would not be permitted into
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the areas without portable monitoring (except for life saving). Based on the alternate instrumentation used by the licensee for this variable, we i
find the proposed range for the radiation exposure rate monitors acceptable.
3.3.22 Vent from Steam Generator Safety Relief Valves or Atmospheric Dump Valves Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.
In Reference 5, the licensee has committed to provide Category 2 instrumentation for this variable. We find this commitment acceptable.
3.3.23 All Identified Plant Release Points
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Regulatory Guide 1.97 recommends a range of 10 to 10 pCi/cc for
-11 this variable. The range provided by the licensee is 10 pC1/cc to
~9 5 x 10 for particulates. Halogens are sampled and analyzed off-line.
In Reference 5, the licensee states that the identified plant release points are further monitored in the main plant vent. These main 14 s
plant vent monitors cover the recommended range. Therefore, because of the main plant vent monitors we find the instrumentation provided for this variable acceptable.
3.3.24 Estimation of Atmospheric Stability
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Regulatory Guide 1.97 recommends a range of -5 to 10*C for this variable. The licensee has provided a range of -3 to 7'C.
The justification provided by the licensee is that their instrumentation is adequate for the intended monitoring functicn.
Table 1 of Regulatory Guide 1.23 (Reference 9) provides seven atmospheric stability classifications based on the difference in j
temperature per 100 meters elevation change. These classifications range from extremely unstable to extremely stable. Any temperature difference greater than +4*C or less than -2*C does nothing to the stability classification. The licensee's instrumentation includes this range.
Therefore, we find that this instrumentation is acceptable to determine the l
atmospheric stability.
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CONCLUSIONS Based on our review, we find that the licensee either conforms to or I
is justified in deviating from Regulatory Guide 1.97, with the following exceptions:
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Accumulator tank level and pressure--environmental qualification l
should be provided in accordance with 10 CFR 50.49 for the parameter designated as the key variable (Section 3.3.7).
2.
Containment sump water temperature--the licensee should either j
supply the recommended instrumentation or identify suitable alternate instrumentation (Section 3.3.14).
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REFERENCES i
1.
NRC letter, D. G. Eisenhut to All Licensees of Operating Peactors, i
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Applicants for Operating L! censes, and Holders of Construction j
Pemits, " Supplement No. I to NUREG-0737--Requirements for Emergency i
Response Capability (Generic Letter No. 82-83)," December 17, 1982.
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2.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess I
Plant and Environs Conditions During and Following an Accident,
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j Regulatory Guide 1.97, Revision 2, NRC, Office of Standards l
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j Development, December 1980.
3.
Clarification of TMI Action Plan Requirements. Requirements for Emergency Response Capability, NUREG-0737, Supplement No. 1, NRC, j
Office of Nuclear Reactor Regulation, January 1983.
i 4.
Baltimore Gas and Electric Company letter, J. R. Lundvall to Director, Office of Nuclear Reactor Regulation, " Regulatory Guide 1.97 Review,"
l December 1, 1984.
i 5.
Baltimore Gas and Electric Company letter, Joseph A. Tiernan, to Office of Nuclear Reactor Regulation, NRC, " Regulatory Guide 1.97 l
Review," February 21, 1986.
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Baltimore Gas and Electric Company letter, Joseph A. Tiernan, to NRC, l
" Regulatory Guide 1.97 Review," March 10, 1987.
7.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess l
Plant and Environs Conditions During and Following an Accident, i
Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory i
Research, May 1983.
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NRC letter E. J. Butcher to A. E. Lundvall Jr., Baltimore Gas and j
Electric Company. " Order Modifying License Confiming Additional 1
l Licensee Commitments on Emergency Response Capability (Supplement No. I to NUREG-0737)," July 16,1985.
4 9.
Onsite Meteorological Pronrams, Regulatory Guide 1.23 (Safety Guide 23), NRC,
- ebruary L7, 1972 or Meteorological Programs in Support of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, September 1980.
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Idaho Falls, ID 83415 Technical Evaluation Report
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Division of Engineering and System Technology Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cosutission j
Washington, DC 20555 i
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l This EG&G Idaho, Inc., report reviews the substital for Unit Nos. I and 2 of the Calvert Cliffs Nuclear Power Plant, and identifies areas of nonconform-l ance to Regulatory Guide 1.97.
Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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