ML20117B584
| ML20117B584 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/13/1985 |
| From: | Knighton G Office of Nuclear Reactor Regulation |
| To: | Carey J DUQUESNE LIGHT CO. |
| Shared Package | |
| ML20117B588 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-62938, NUDOCS 8505090157 | |
| Download: ML20117B584 (4) | |
Text
-
D k-((.
'g UNITED STATES p,
NUCLEAR REGULATORY COMMISSION p
WASHINGTON, D. C. 20555
%.....,/
APR 131985 Docket No. 50-412 Mr. John J. Carey Vice President, Nuclear Duquesne Light Company Robinson Plaza Building, No. 2, Suite 110 PA' Route 60 Pittsburgh, Pennsylvania 15205
Dear Mr. Carey:
SUBJECT:
BEAVER VALLEY UNIT 2 RE0UESTS FOR ADDITIONAL INFORMATION -
CONFORMANCE TO R.G.I.97
References:
- 1) Duquesne Light Company letter, E. J. Woolever to USNRC,
" Generic Letter 87-33, Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability,"
April 15, 1983, 2NRC-3-017.
- 2) Duquesne Light Company letter, E. J. Woolever to H. R. Denton, NRC, " Regulatory Guide 1.97 Implementation Report," September 12, 1983, 2NRC-3-072.
- 3) NRC Generic Letter No. 82-33 (Supplement No. I to NUREG-0737-Reouirements for Emergency Response Capability, December U,1982.
References 1 & 2, in response to Reference 3, provided detailed descriptions of conformance to Pegulatory Guide 1.97, Rev. 2.
The enclosed interim report was prepared by INEL under a technical assistance procram for the review of these responses on conformance to R.G. 1.97.
The staff has reviewed References 1 and 2 and concluded that DLC has provided an explicit commitment on conformance to R.G. 1.97 with the exception of those items that were identified by you.
Further, it is concluded that the DLC's justification for exceptions to R.G. 1.97 for some items are acceptable. However, there are some items for which INEL could not conclude that adequate justification was provided and has identified those as unjustified exceptions.
The report prepared by INEL is forwarded to you to provide a response to the open items.
If the enclosed report includes any incorrect assumptions or reflects a commitment which you believe is beyond the intent of your previous response, please identify so.
To maintain a workable review schedule, your response to these requests should be submitted to the NRC within 60 days of the receipt of this letter.
D 2
F i
n
~.
-Should you have_any questions concerning the enclosed requests please contact the Project Manager, B. K. Singh at 301-492-8423.
Sincerely,
./
I George W Knighton, ef Licensiiig Branch No). 3 Division of Licensing
Enclosure:
-As Stated cc: See next.page DISTRIBUTION
-iDocket;fUe;50912i NRC PDR-LPDR NSIC PRC System LBf3 Reading BKSingh-JPartlow BGrimes EJordan-Attorney, OELD
-ACRS(16)
JLee 4
A 4
w D
3 BKSingh/yt swKri'igh' ton L4/Il/85 4//zJ85
G Beaver Valley
. Mr. John J. Carey Vice President, Nuclear Duquesne Light Company Robinson Plaza Building, No. 2, Suite 110 PA Route 60 Pittsburgh, Pennsylvania 15205 Gerald Charnoff, Esq.
Jay E. Silberg, Esq.
Mr. R. E. Martin, Manager Engineering Beaver Valley Two Project Shaw, Pittman, Potts & Trowbridge Duquesne Light Company 1800 M Street, N.W.
Robinson Plaza Building No. 2, Suite 110 Washington, DC 20036 PA Route 60 Pittsburgh, Pennsylvania 15?05 Mr. C. W. Ewing, Quality Assurance Zori Ferkin Manager Assistant Counsel Quality Assurance Department Governor Energy Council Duquense Light Company 1625 N. Front Street P. O. Box 186 Harrisburg, PA 15105 Shippingport, Pennsylvania 15077 Mr. John J. Carey Vice President, Nuclear Duquense Light Company Director, Pennsylvania Emergency P. O. Box 4 Management Agency Pittsburgh, Pennsylvania 15205 Room B-151 Transportation & Safety Building Harrisburg, Pennsylvania 17120 Mr. T. J. Lex Westinghouse Electric Corporation Mr. Thomas Gerusky Power Systems Bureau of Radiation Protection P. O. Box 255 PA Department of Environnental Pesources Pittsburgh, Pennsylvania 15230 P. O. Box 2063 Mr. P. RaySircar Harrisburg, Pennsylvania 17120 Stone & Webster Engineering Corporation BVPS-2 Records Management Supervisor P. O. Box 2325 Duquesne Light Company Boston, Massachusetts 02107 Post Office Box 4 Mr. Glenn Walton Shippingport, Pennsylvania 15077 U. S. NRC P. O. 181 John A. Lee, Esq.
Duquesne Light Company Shippingport, Pennsylvania 15077 1 0xford Centre 301 Grant Street Mr. Thomas E. Murley, Regional Admin.
Pittsburgh, Pennsylvania 15279 U. S. NRC, Region I.
631 Park Avenue King of Prussia, Pennsylvania 15229
a,
-?-
e Mr. E. - F.. Kurtz, Jr., Manager Regulatory Affairs
' Beaver Valley Two Project Duquense Light Company Robinson Plaza Buidling No. 2
-Suite #210
.PA Route 60 Pittsburgh, Pennsylvania 15205 N
---.,J.---------
Enciosura CONFORMANCE TO REGULATORY GUIDE 1.97 BEAVER VALLEY 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 Comission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6493 7-4*'Q9
ABSTRACT This EG&G Idaho, Inc., report provides a review of the submittals for Regulatory Guide 1.97 for Unit No. 2 of the Beaver Valley Power Station and identifies areas of nonconformance to the guide. Any exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are 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 Reg-ulatory Comission, 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 20-19-40-41-3.
Docket No. 50-412 11
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 16
- 5. REFERENCES.............................
20 iii
CONFORMANCE TO REGULATORY GUIDE 1.97 BEAVER VALLEY POWER STATION, UNIT NO. 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 Reg-ulation, 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 NUREG-0737, "TMI Action Plan Requirements"(Reference 3).
Duquesne Light, the applicant for Unit 2 of the Beaver Valley Power Sta-tion, responded to the generic letter with a letter dated April 15, 1983 (Ref-erence 4). A letter dated September 12, 1983 (Reference 5), provides a review of the instrumentation provided for Regulatory Guide 1.97.
This report provides an evaluation of these submittals.
1
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 applicant meets the guidance of Regulatory Guide 1.97 as applied to emergency response facili-1 ties.
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 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 of 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 ques-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 ap-plicants explicitly state that instrument systems conform to the provisions of 4-the guide, it was noted that no further staff review would be necessary.
Therefore, this report only addresses exceptions to the guidance of Regulatory
.2
Guide 1.97.
The following evaluation is an audit of the applicant's submit-stals based on the review policy described in the NRC regional meetings.
4 i
a I
e 2
i I
d t
E T
4 3
3.
EVALUATION This evaluation is based on the following applicant submittals:
the ap-plicant's response to Generic Letter 82-33 dated April 15, 1983, the appli-cant's response to Section 6.2 of the generic letter dated September 12, 1983, and the Final Safety Analysis Report (FSAR-Reference 6).
3.1 Adherence to Regulatory Guide 1.97 The applicant states in Table 1.8-1 of the FSAR that Unit 2 of the Beaver Valley Power Station meets the intent of Regulatory Guide 1.97.
This statement was reaffirmed in Reference 5.
Therefore, it is concluded that the applicant has provided an explicit comitment on conformance to the guidance of Regulatory Guide 1.97, with the exception of those deviations identified in Section 3.3 of this report.
32 Type A Variables 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 ap-plicant classifies the following as Type A variables.
1.
Reactor coolant system (RCS) cold leg water temperature 2.
RCS hot leg water temperature 3.
RCS pressure 4.
Core exit temperature 5.
Degrees of subcooling 6.
Containment sump water level-wide range 7.
Containment sump water level-narrow range 4
e
8.
Containment pressure 9.
Containment area radiation level-high range
- 10. Pressurizer level
- 11. Steam generator level, wide range
- 12. Steam generator level, narrow range
- 13. Steamline pressure
- 14. Auxiliary feedwater flow
- 15. Primary plant demineralized water storage tank level
- 16. Secondary system radiation.
All of the above variables, except degrees of subcooling, meet Category 1 requirements consistent with the requirements for Type A variables. The deviation for degrees of subcooling is addressed in Section 3.3.5.
3.3 Exceptions to Regulatory Guide 1.97 The applicant identified the following exception to the guidelines of Regulatory Guide 1.97.
3 3.1 Neutron Flux Regulatory Guide 1.97 specifies environmentally ~ qualified instrumentation for this variable. The instrumentation provided for this variable includes detectors that are not environmentally qualified. The applicant states that there are no commercially available sensors with post-accident environmental qualifications.
l l
+
Environmental qualification has been clarified since Revision 2 of Reg-ulatory Guide 1.97 was issued. The clarification is the environmental quali-fication 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 accordance with 10 CFR 50.49.
3.3.2 Reactor Coolant System Soluble Boron Concentration Regulatory Guide 1.97 recommends instrumentation for this variable with a range of from 0 to 6000 parts per million. The applicant has supplied instru-mentation for this variable with a range of 50 to 6000 parts per million. The applicant has not provided justification for this deviation.
The applicant 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 Reactor Coolant System Cold and Hot Leg Temperature Revision 2 of Regulatory Guide 1.97 recommends instrumentation for these variables with ranges of 50 to 750*F. The applicant has supplied instrumenta-tion for these variables with ranges from 0 to 700*F. The applicant presented no justification for this deviation.
Revision 3 of Regulatory Guide 1.97 (Reference 7) recomends a range of 4
50 to 700*F for these variables. The instrumentation supplied by the appli-5 car.t meets this range. Therefore, the range supplied by the applicant is acceptable.
3.3.4 Coolant level in Reactor I
Regulatory Guide 1.97 recomends instrumentation for this variable with a
[
range from the bottom of the core to the top of the vessel. The applicant is i
6
installing instrumentation for this variable with a range of 0 to 100 percent of the plenum and core height. The applicant has identified this as a devia-tion.
However, the applicant continues, the instrumentation being installed for this variable was approved for this purpose by NRC Generic Letter No. 82-28 (Reference 8).
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.F.2.
3.3.5 Degrees of Subcooling The applicant has identified this as a Type A variable. As such, Table 2 of Regulatory Guide 1.97 recommends Category 1 instrumentation. The applicant is providing Category 2 instrumentation. The NRC is reviewing the accepta-bility of this variable as part of their review of NUREG-0737. Item II.F.2.
3.3.6 Radiation Level in Circulating Primary Coolant The applicant uses the post-accident sample system to measure this parameter. Based on the alternate instrumentation and the justification provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate, and therefore, acceptable.
3 3.7 Containment Area Radiation Regulatory Guide 1.97 recommends extended range instrumentation for this variable with a range of 1 to 107 R/hr. The applicant has committed to in-stall instrumentation for this variable. The range is to be determined and supplied at a later date. The applicant should provide the recommended i
range.
r 4
7
-.-..._m..._,..-----,_____..m.-,,
.m.,,_.,,...,
~
3.3.8 Effluent Radioactivity-Noble Gases and Vent Flow Rate Regulatory Guide 1.97 recommends Type C and Type E instrumentation for various locations where gaseous radioactive materials can be released to the atmosphere. The applicant has identified the location--plant vent radiation level--with the range to be supplied later, with a vent flow rate of 0 to 75,000 standard cubic feet per minate.
The FSAR, Tables 11.3-7 through 10, identify the following release points:
(a) Process vent (Unit Nos. I and 2), (b) ventilation vent, (c) ele-vated release and (d) turbine building vent. Thus, we conclude that the ap-plicant has not provided sufficient information for these variables. The licensee should provide a correlated statement on instrumentation provided for the station release points, showing conformance to Regulatory Guide 1.97, and the information requirements of Section 6.2 of Supplement No. I to NUREG-0737.
3.3.9 Radiation Exposure Rate (Inside building or areas...)
Regulatory Guide 1.97 reconnends permanently installed Category 2 instru-mentation for this variable. The applicant has proposed portable Category 3 instrumentation for this variable with the range as yet unidentified.
No justification was presented for these deviations.
The applicant should provide the recommended instrumentation.
3.3.10 RHR Heat Exchanger Outlet Temperature Revision 2 of Regulatory Guide 1.97 recommends a range of 32 to 350*F for this variable. Revision 3 changed the reconnended range to 40 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 regula-tory guide.
We find that this deviation is minor with respect to the overall range and system accuracy. Therefore, this deviation is acceptable.
8
~
3.3.11 Accumulator Tank Level and Pressure and Isolation Valve Position Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables. The applicant has not provided the information required in Section 6 2 of NUREG-0737, Supplement No. 1 for these variables, stating nonconformance for level and pressure and conformance for the isolation valve status. The justification provided for nonconformance is that these variables are not necessary to monitor the status of the plant while proceeding to a cold shutdown condition.
We conclude that the applicant should provide the information required in Section 6.2 of NUREG-0737, Supplement No. 1 for the accumulator tank level, accumulator tank pressure and accumulator isolation valve position variables.
We further conclude that the applicant should provide Category 2 instru-mentation, with the recommended ranges, for these variables.
3.3.12 Boric Acid Charging Flow Regulatory Guide 1.97 recommends instrumentation for this variable.
The applicant does not have instrumentation for this variable, as it is not a part of the emergency core cooling system, and the boric acid tank is not used as a source of water for safety injection.
The applicant does not have instrumentation for this variable. The ap-plicant states that the units do not use boric acid charging flow as a safety injection system. Centrifugal charging pump flow, safety injection flow and residual heat removal flow are the safety injection variables monitored.
Therefore, we find that this variable is'not applicable at the Beaver Valley Station, Unit No. 2.
i 9
~
3.3.13 Reactor Coolant Pump Status s
Regulatory Guide 1.97 recommends instrumentation for this variable that measures the motor current.
The applicant has not provided the information required in Section 6.2 of NUREG-0737, Supplement No.1 for this variable.
We conclude that the applicant should provide the recommended instru-mentation and the required information, identify any deviation from the recommendations of the regulatory guide, and provide justification for any
' deviation.
3.3.14 Pressurizer Heater Status Regulatory Guide 1.97 recommends Category 2 electric current instrumenta-tion for this variable. The applicant has supplied circuit breaker position indication for this variable.
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 Instrumentation is to be provided to prevent overloading a diesel-sources.
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.
l 3.3.15 Quench Tank Level. Temperature and Pressure Regulatory Guide 1.97 recommends instrumentation for these variables.
The applicant has not provided the information required in Section.6.2 of NUREG-0737, Supplement No. 1 for these variables. They have not indicated compliance with the regulatory guide. Section 5.4.11.4 of the FSAR indicates that this instrumentation is installed.
10
The applicant should provide the required information, identify any de-viation from the regulatory guide recommendations and provide satisfactory justification for any deviation.
+
3.3.16 Steam Generator Level e
Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable, with a range from the tube sheet to the separator. The applicant has provided both narrow range instrumentation and wide range instrumenta-tion.
Both the narrow range and the wide range instruments are identified as conforming to the recommendations of Regulatory Guide 1.97 with a range of 0 to 100 percent of span.
-The applicant should identify the range limits for both the narrow and wide range instruments in relation to vessel height. Furthermore, the appli-cant should show compliance with the required range of tube sheet to the separator.
3.3.17 Heat Removal by the Containment Fan Heat Removal System Regulatory Guide 1.97 recommends plant specific instrumentation for this variable.
The applicant, in his submittal, does not address this variable.
Our examination of Section 6.2.2 of the FSAR indicates that Unit 2 of the Beaver Valley Power Station does not have a containment fan heat removal system. This being the case, this variable is not needed at this unit.
3.3.18 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of 40 to 400*F for this variable The applicant has supplied Category 3 instru-mentation with a range of 0 to 200*F. The justification provided for these deviations is that there is no operator action based on the containment temperature and the range is adequate for normal operation.
11
~
We find this justification unacceptable. The regulatory guide recommends that the instrumentation remain on scale for any anticipated condition.
We conclude that the applicant should supply Category 2 instrumentation with a range of 40 to 400*F for this variable.
3.3.19 Containment Sump Water Temperature Regulatory Guide 1.97 recomends instrumentation for this variable with a l
5 range of 50 to 250*F.
The applicant has not provided the information required in Section 6.2 of NUREG-0737, Supplement No. 1, for this variable. The justi-
~
fication for this deviation is that no operator action is based on the con-tainment sump water temperature. We find this justification unacceptable.
We conclude that the applicant should provide the required information, identify any deviation from the recommendations of the regulatory guide, and provide justification for any deviation.
3.3.20 High Level Radioactive Liquid Tank Level Regulatory Guide 1.97 recommends instrumentation for this variable.
The applicant has not provided the information required in Section 6.2 of NUREG-0737, Supplement No. I for this variable.
We conclude that the applicant should provide the required information, identify any deviation from the recommendations of the regulatory guide, and provide justification for any deviation.
3.3.21 Radioactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends instrumentation for this variable.
The applicant has not provided the information required in Section 6.2 of NUREG-0737, Supplement No. 1, for this variable.
We conclude that the applicant should provide the recommended instru-mentation and the required information, identify any deviation from the 12
__ ~.
3.
recommendations of the regulatory guide, and provide justification for any de-viation.
3.3.22 Condenser Air Removal System Exhaust Noble-Gases and Vent Flow Rate Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 10-6 to 105 uCi/ce, and 0 to 110 percent of the vent design flow. The applicant is providing a set of instrumentation for the air ejector discharge and a set of instrumentation for the air ejector delay bed exhaust. Both of these are Category 3 with the range to be supplied later.
The applicant has not provided justification for the deviation in cate-gory. We conclude that the applicant should provide the ranges of measurement for these variables, showing that the recommended range is satisfied, and a
justify the deviation from the recommended category of instrumentation.
3.3.23 Vent From Steam Generator Atmospheric Dump Valves Regulatory Guide 1.97 recommends measuring noble gas, duration of release and mass of steam per unit time for this variable. The applicant has not pro-vided the information required in Section 6.2 of NUREG-0737, Supplement No. 1, for this variable.
We conclude that the applicant should provide the recommended instru-mentation and the required information, identify any deviation from the recom-mendations of the regulatory guide, and provide satisfactory justification for any deviation.
3.3.24 Information Not Supplied. Type E Variables Regulatory Guide 1.97 recommends instrumentation for the following Type E variables.
Particulates and Halogens--all identified plant release points i
Airborne radiohalogens and particulates 13
Plant and environs radioactivity Wind direction The applicant has not provided the information required by Section 6.2 of NUREG-0737, Supplement No. 1, for these variables.
We conclude that the applicant should provide the recommended instru-mentation, identify any deviation from the recommendations of the regulatory guide and provide satisfactory justification for any deviation.
3.3.25 Plant and Environs Radiation Regulatory Guide 1.97 recomends portable instrumentation with ranges of 10-3 to 104 R/hr (photons) and 10-3 to 104 rads /hr (beta and low energy photons). The applicant indicates conformance and has identified that the range will be supplied later.
We conclude that the applicant will verify that the instrument ranges supplied are in conformance with the recomendations of the regulatory guide.
3.3.26 Wind Speed Revision 2 of Regulatory Guide 1.97 recomends a range of 0 to 67 miles per hour (mph) for this variable. Revision 3 changes the recommendation to O to 50 mph. The applicant has identified a deviation from the Revision 2 recommendation in that the range provided is 0 to 50 mph. They state that
.this is acceptable because it meets the guidance of Regulatory Guide 1.23.
We find that the range provided is satisfactory. Furthermore, it meets the recommendation of Revision 3 of Regulatory Guide 1.97.
4 3.3.27 Estimation of Atmospheric Stability Regulatory Guide 1.97 recomends instrumentation for this variable with a 1
14
~.
l range -9 to +18'F for 164 ft intervals or an analogous range for alternative h
I i
i l
15 J
stability analysis. The applicant has provided instrumentation with a range of -4 to +8'F for a 115 ft interval and -6 to +12*F for a 465 ft interval.
The licensee justifies this deviation by saying that "the vertical temperature ranges cover the range of lapse rate guidance of Regulatory Guide 1.23 (Refer-ence 9) required to estimate the atmospheric stability class."
Table 1 of Regulatory Guide 1.23 provides 7 vertical atmospheric sta-bility classifications based on the difference in temperature per 100 meters elevation change. These classifications cover from extremely unstable to ex-tremely stable. Any temperature difference greater than +4*C or less than
-2*C does nothing to the stability classification. The applicant's instrument accuracy is as specified in Regulatory Guide 1.97, the temperature range and the vertical separation are both greater than that recommended in Regulatory Guide 1.23.
Therefore, we find that this instrumentation is acceptable to determine the atmospheric stability.
16
~
4.
CONCLUSIONS Based on our review we find that the applicant either conforms to, or is justified in deviating from, the guidance of Regulatory Guide 1.97, with the following exceptions:
1.
Neutron flux--environmental qualification of the detectors should be addressed in accordance with 10 CFR 50.49 (Section 3.3.1).
2.
Containment area radiation--the applicant should provide the recom-mended range (Section 3.3.7).
3.
Effluent radioactivity--noble gases and vent flow rates--for four release locations identified in the FSAR, the applicant should show conformance to Regulatory Guide 1.97 and provide the information re-quired by Section 6.2 of NUREG-0737, Supplement No. 1 (Sec-tion 3.3.8).
4.
Radiation exposure rate--the applicant should provide instrumenta-tion as reconenended by Regulatory Guide 1.97 (Section 3.3.9).
5.
Accumulator tank level and pressure--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, showing that Category 2 instrumentation of the recommended ranges are provided (Section 3.3.11).
'6.
Accumulator isolation valve position--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, showing that Category 2 instrumentation is provided (Sec-tion 3.3.11).
7.
Reactor coolant pump status--the applicant should provide the infor-mation required by Section 6.2 of Reference 3, identify any devia-tion from the recommendations of Regulatory 3uide 1.97, and provide satisfactory justification for any deviation (Section 3.3.13).
17
~
8.
Pressurizer heater status--the applicant should provide the instru-mentation recommended by Regulatory Guide 1.97 (Section 3.3.14).
9.
Quench tank level--the applicant should provide the information re-quired by Section 6.2 of NUREG-0737, Supplement No. 1, showing com-pliance to Regulatory Guide 1.97 (Section 3.3.15).
10.
Quench tank temperature--the applicant should provide the informa-tion required by Section 6.2 of NUREG-0737, Supplement No. 1, showing compliance to Regulatory Guide 1.97 (Section 3.3.15).
11.
Quench tank pressure--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, showing compliancetoRegulatoryGuide1.97(Section3.3.15).
12.
Steam generator level--the applicant should identify the instrument ranges in terms of vessel height, showing compliance with the recommended wide range of from tube sheet to separator (Sec-tion 3.3.16).
13.
Containment atmosphere temperature--the applicant should supply Category 2 instrumentation with a range of 40 to 400*F for this variable (Section 3.3.18).
14.
Containment sump water temperature--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the recommendations of Regulatory Guide 1.97 and provide justification for any deviation (Sec-tion 3.3.19).
15.
High level radioactive liquid tank level--the applicant should pro-j vide the information required by Section 6.2 of NUREG-0737, Supple-ment No. 1, identify any deviation from the recommendations of Regulatory Guide 1.97 and provide justification for any deviation (Section3.3.20).
18
- 16. Radioactive gas holdup tank pressure--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the recommendations of. Regulatory Guide 1.07 and provide justification for any deviation (Sec-tion 3.3.21).
- 17. Condenser air removal system exhaust--the applicant should provide the range of the instrumentation supplied, showing conformance to Regulatory Guide 1.97; the applicant should provide justification for using Category 3 instrumentation instead of Category 2 (Sec-tion 3.3.2).
- 18. Vent from steam generator atmospheric dump valves--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the recommendations of Regulatory Guide 1.97, and provide justification for any deviation (Section 3.3.23).
- 19. Particulates and Halogens--all identified plant release points--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the recommendations of Regulatory Guide 1.97, and provide justification foranydeviation(Section3.3.24).
- 20. Airborne radiohalogens and particulates--the applicant should pro-vide the information required by Section 6.2 of NUREG-0737, Supple-ment No. 1, identify any deviation from the recommendations of Regulatory Guide 1.97, and provide satisfactory justification for anydeviation(Section3.3.24).
- 21. Plant and environs radioactivity--the applicant should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the recommendations of Regulatory Guide 1.97, and provide satisfactory justification for any deviation (Section 3.3.24).
19 1
I
~
22.
Wind direction--the applicant should provide the information re-quired by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the reconmendations of Regulatory Guide 1.97, and provide satisfactory justification for any deviation (Sec-tion 3.3.24).
)
23.
Plant and environs radiation--the applicant should identify the range of this instrumentation (Section 3.3.25).
i 4
t i
i 20 L
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. 1 to NUREG-0737--Requirements for Emergency Response Capa-bility (Generic letter No. 82-33)," December 17, 1982.
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 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.
Duquesne Light Company letter, E. J. Woolever to U.S. NRC, " Generic Let-ter 82-33, Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability," April 15, 1983, 2NRC-3-017, 5.
Duquesne Light Company letter, E. J. Woolever to H. R. Denton, NRC, " Reg-ulatory Guide 1.97 Implementation Report," September 2NRC-3-072.
12, 1983, 6.
Beaver Valley Power Station Unit 2. Final Safety Analysis Report, Duquesne Light Company, Amendment 4, December 1983.
7.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
8.
HRC Letter, D. G. Eisenhut to all Licensees of Operating Westinghouse and CW PWRs, " Inadequate Core Cooling Instrumentation System (Generic Letter No. 82-28)," December 10, 1982.
9.
Onsite Meteorological Programs, Regulatory Guide 1.23 (Safety Guide 23),
NRC, February 17, 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.
/. -
k 21 k