ML20126K893
| ML20126K893 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/31/1985 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20126K881 | List: |
| References | |
| CON-FIN-A-6493, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8507300509 | |
| Download: ML20126K893 (19) | |
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CONFORMANCE TO REGULATORY GUIDE 1.97 RIVER BEND STATION, UNIT N05. 1 AND 2 A. C. Udy Published March 1985 EG84 Idaho, Inc.
Idaho Falls 83415 Prepared for the U.S. Department of Energy Idaho Operations Office I
Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6493 B507300509 05071D PDR ADOCK 05000450 F
l ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97, Revision 2 for the River Bend Station Unit Nos. I and 2.
Any exception to the guidelines of Regulatory Guide 1.97 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 Regulatory Commission, Office of Nuclear Reactor Regulation. Division of Systems Integration, by EG&G Idaho, Inc., NRC Licensing Support Section.
The U.S. Nuclear Regulatory Commission funded the work under authorization B&R 20-19-40-41-3.
Docket Nos. 50-458 and 50-459 11
CONTENTS 11 ABSTRACT................................................................
11 FOREWORD................................................................
1 1.
INTR 000CT10N..................................................J....
2 2.
REVIEW REQUIREMENTS................................................
4 3.
EVALUATION.........................................................
1 4
3.1 Adherence to Regulatory Guide 1.97...........................
4 3.2 Type A Variables.............................................
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3.3 Except ions to Regul atory Guide 1.97..........................
14 4.
CONCLUSIONS........................................................
16 5.
REFERENCES.........................................................
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CONFORMANCE TO REGULATORY GUIDE 1.97 RIVER BEND STATION. UNIT NOS. 1 AND 2 1.
INTRODUCTION On December 17, 1982 Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut Director of the Division of Licensing, Nuclear Recctor 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),
relatir,g to the requirements for emergency response capability. These requirements have been published as Supplement No. I to NUREG-0737. "TMI ActionPlanRequirements"(Reference 3).
The Gulf States Utilities Company, applicant for the River Bend Station, provided a response to the generic letter on April 15,1983(Reference 4).
This report provides an evaluation of that material and the referenced FinalSafetyAnalysisReport(FSAR, Reference 5).
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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 complies to 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 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 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.g7. Furthermore, where licensees or applicants explicitly state that instrument, systems conform to the provisions of the guide, it was noted that no further staff, review h 1d be necessary.
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Theref
- a. this report only addresses exceptions to Regulatory Guide 1.97.
The : 11owing evaluation is an audit of the applicant's submittal based on the review policy des:ribed in the NRC regional meetings.
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EVALUATION The applicant provided s response to NRC generic letter 82-33 on April 15, 1983. This referred to Section 1.8 and Tables 7.5-1 and 7.5-2 of the FSAR, as describing the applicant's position on post-accident monitoring instrumentation. This evaluation is based on that material.
3.1 Adherence to Reaulatory Guide 1.97 The applicant states that they have incorporated the regulatory guide criteria by the indication of variables in th9 main control room to ensure that necessary information is available to the operator to help prevent and mitigate consequences of reactor accidents and transients. Therefore it is concluded that the applicant has provided an explicit couplitsent on conformance to Regulatory Guide 1.97, except for those deviations that were identified by the applicant as noted in Section 3.3.
All of the information required by Section 6.2 of the NRC generic letter 82-33 has not been supplied. The applicant states that a schedule and additional infomation concerning the envirormental and seismic qualification criteria, redundancy and sensor locations, type of power supply, and the location of display will be submitted prior to fuel load.
"3.2 Type A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide information required to pemit the control room operator to take specific manually controlled safety actions. The applicant classifies the following as Type A variables.
1.
Containment and drywell hydrogen concentration 2.
Reactor vessel pressure 3.
Suppression pool water tempera'ture 4
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The above varie'les meet th. Category 1 requirements consistent with the i
requirements for Type A variables.
3.3 Exceptions to Reaulatory Guide 1.97 The applicant 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, powered by station standby (Class IE) power sources. The applicant has identified that the instrumentation to be provided for this variable is Category 2. With powered derived from non-Class IE power sources.
The applicant presents a justification for this based on the importance to safety. They state that the number of detectors driven into the core after shutdown makes it likely that one or more of the existing detectors will be inserted. They also say that there is little probability of an accident envirorment in which the neutron flux instrumentation would be rendered inoperable concurrent with a need for the measurement for operator action.
The standby liquid control system can, they state, be actuated upon loss of instrumentation.
This deviation is similar to most SWRs. A Category 1 system that meets all the criteria of Regulatory Guide 1.97 is an industry development item.
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Based on our review, we conclude that the existing instrumentation is acceptable for interim operation. The applicant should follow industry development of this equipment, evaluate newly developed equipment, and install Category 1 instrumentation when it becomes available.
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3.3.2 Reactor Coolant Sr yes Soluble ron Concentration Regulatory Guide 1.g7 recommends instrumentation for this variable with a range of 0 to 1000 parts per million. The applicant is providing this capability as part of the post-accident sampling system. The proposed range is 8 to 1000 parts per million.
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 the review of NUREG-0737. Item !!.8.3.
3.3.3 Coolant level in Reactor Regulatory Guide 1.97 recomends Category 1 instrumentation for this variable with a range extending from the bottom of the core support plate to thecenterlineofthemainsteamlineorthetopofthevessel(whicheveris less). The applicant has Category 1 instrumentation from -160 to +60 in.
(referredtoinstrumentzero). They state tk.at this range covers from the top of the fuel to the high level trip. Categtry 2 instrumentation monitors the fuel zone levels.
The applicant has not justified using Cai,:;ory 2 instruments from the bottom of the core support plate to -160 in.. nor have they justified not providing Category 1 instrumentation from +60 in. (high level trip) to the centerline of the main steamline. The applicant should provide Category 1 instrumentation to cover the recommended range.
3.3.4 Dewell Sump Level Orwell Drains Sump Level Regulatory Guide 1.97 recommends Category 1 instrumentation for these variables. *The sumps at the River Bend Station have the following indication:
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level 2.
rate-of-rise 3.
high level alam 4.
high-high level alarm The two alarms start, individually, the two sump pumps for each sump. The sump drains are automatically isolated at the primary containment penetration should an accident signal occur.
We conclude that the instrumentation supplied by the applicant will 1
provide appropriate monitoring for the parameters of concern. Basedon(a) i for small leaks, the instrumentation is not expected to experience harsh l
environmentsduringoperation.(b)forlargerleaks,thesumpsfillpromptly and the sump drain lines isolate due to the increase in drywell pressure, thus negating the drywell sump level and drywell drain sumps level instrumentation, and(c)thisinstrumentationneitherautomaticallyinitiatesnoralertsthe operator to initiate operation of a safety.related system in a post-accident situation, we find the Category 3 instrumentation provided acceptable.
3.3.5 Radiation Level in Circulatina Primary Coolant The applicant states that their instrumentation is justified based on the critical actions to be taken to prevent and to mitigate a gross breach of fuel claddingbeing(a)shutdownthereactor,and(b)maintainthewaterlevel.
The applicant states that the post-accident sampling station provides a means of obtaining samples of reactor coolant and determining the status of fuel 4
cladding and that radiation monitors in the condenser off-gas and the main steamlines provide information on the status of fuel cladding when the plant is not isolated.
Based on the alternate instrumentation and the justification provided by the applicant, we conclude that the instrumentation supplied for this variable 7
is adequate, and therefore, acceptable.
3.3.6 Suporession Pool Water Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the bottom of the ECCS suction line to the top of the weir wall.
The applicant has instrumentation with a range from the safety relief valve discharge to the top of the liner. Our examination of the FSAR shows that the topofthelinerisabovethe91ft.3in.topoftheweirwell(thebasemat ofthesuppressionpoolisat70ft.). Thus, the upper limit of the range meets the recomendations of Regulatory Guide 1.97.
Thecenterlineoftheresidualheatremovalsuctionline(a20in.line) is at 73 ft. 4.75 in. The safety relief valves discharge through querchers, which are' located above the basemat of the pool. FSAR Figure A.6A.10-2 shows i
these discharge typically at 79 ft. 11.69 in.
Thus, compliance is not achieved for the lower limit of the range. No l
justification is given by the applicant. They should provide justification for this deviation.
t 3.3.7 Containment and Drywell Hyd'ronen Concentration Regulatory Guide 1.97 recomends instrumentation for this variable with a i
range from 0 to 30 percent. The applicant is supplying instrumentation with a l
range from 0 to 10 percent. They state that this is adequate since they do i
not use an inerted contalment and have alarms at 3.5 percent concentration.
f Section 6.2.5 of the F5AR describes the instrumentation, the hydrogen mixing i
system and hydrogen recombiners. Together, they are designed to limit the hydrogen concentration to 4 percent. Therefore, the range of 0 to 10 percent 1
is acceptable.
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3.3.8 Radiation Exposure Rate Revision 2 of Regulatory Guide 1.97, recomends Category 2 instrumentation i
for this variable. The licensee has provided Category 3 instrumentation. As i
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Revision 3ofRegulatoryGuide1.97(Reference 6)haschargedthe recommendation to Category 3 instrumentation, this deviation from the recommendation of Revision 2 is acceptable.
3.3.9 Suppression Pool Water Temperature Regulatory Guide 1.97 recommends instrumentation for this variable with a range from 30 to 230'F. The applicant is supplying instrumentation with a range of 0 to 200*F.
i The deviation is supported by the applicant s statement that the maximum design suppression pool temperature is 185'F. Based on this, the instrument range to 200'F is acceptable.
3.3.10 Orywell Atmosphere Temperature Regulatory Guide 1.97 recommends instrumentation for this variable with a range from 40 to 440'F. The applicant indicates, in Table 7.5-1 of the FSAR, We find a range of 40 to 440'F. and in Table 7.5 2, a range of 40 to 400'F.
the given information inconsistent; thus, we are unable to determine the adequacy of the instrument range.
If a deviation The applicant should clarify the instrument range.
exists, it should be justified.
3.3.11 Main Steamline Isolation Valves' Leasane Control System Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 15 in, water or 0 to 5 psid. The applicant has instrumentation with a range of 0 to 200 psig. This pressure, taken from redundant compressor and accumulator air systems, is put into the steam 11nes between the main steam 11ne isolation valves and between the outer main steam 11ne isolation valve and tem main steam shutof,f valves. This pressure provides a controlled leakage.
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3.3.12 primary System Safety Relief Valve Position Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The applicant is supplying a Category 3 acoustic monitoring system. They have not provided justification for this deviation from the category recommendation.
The applicant should justify why Category 2 instrumentation cannot be supplied for this variable.
3.3.13 Standby Liauid Control System Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from 0 to 110 percent of design flow. The applicant does not measure flow.
Instead, there is indication of the standby liquid controlsystem($LCS)pumpdischargeheaderpressure. Additionally, system operationcanbeverifiedby(a)thethangeinleveloftheSLCSstoragetank.
(b)thereactivitychangeasmeasuredbyneutronfluxandboronconcentration.
(c)thepumpmotorindicatinglightsand(d)thesquibvalveposition indicating lights.
The applicant uses positive displacement pumps for the SLC5. Th'us, high output pressure would indicate flow blockage and low or erratic pressure would indicate a line break. We find that the above indications are valid for an alternate SLCS flow indication.
3.3.14 SLCS Storace Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The applicant is supplying Category i instrumentation. The following jdstifications were given by the applicant.
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The design basis for the SLCS as'sames the need of an alternative method of reactivity control without a concurrent loss-of-coolant accident or high-energy line break. Therefore, the environment in which the SLCS instrumenta: ion must work is a mild environment.
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The design basis fer the SLCS recognizes that the system has less importance to safety than the reactor protection system o'r the engineered safeguards systems.
Iftheapplicantconformstoallthecr'teria(powersupply, quality assuranc.e etc.) identified under Category 2 instrumentation, avcept for equipment qualification, then this justification is acceptable. The applicant should provide a commitment of conformance to Category 2 criteria, except for equipment qualification.
s 3.3.15 Coolina Water Temperature to ESF System Components Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 32 to 200*F. The applicant is supplying irstrumentation,with a range of 0 to 125'F.
The applicant states the maximum temperature for the standby service water system is 95'F. Based on this, the range of 0 to 125'F is acceptable.
3.3.16 Emcreeney Ventilation Damper Position Regulatory Guide 1.97 reconnends Category 2 instrumentation for this variable. The applicant is supplying imtrumentation for this variable, some of which is Category 1 and acceptable, sed some of which is Category 3.
The, applicant has not identified which dampers have Category 3 instrumentation associated with them, nor jusilfied the use of Category 3 instrumentation in these instances.
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The applicant should identify where Category 3 emergency ventilation damper position indication is used, and show why Category 2 instrumentation cannot be used and justify the use of Category 3 instrumentation.
3.3.17 Airborne Radiohalogens and Particulates Regulatory Guide 1.97 recommiends portable sampling with onsite analysis capability for this variable with a range from 10-9 to 10-3 vC1/cc. The applicant identifies a portable air sampler with a range of 0 to 2 Nev. They did not state that the instrumentation supplied is equivalent to the instrumentation recommended.
We find that the instrumentation supplied gives a reading of energy level. We are not able to determine if the resolution is satisfactory such that its range is equivalent to the six decades of range recommended for this l
variable. Therefore, we conclude that the applicant should provide additional I
information describing the acceptability of this instrumentation.
l 3.3.18 Estimation of Atmospheric Stability Regulatory Guide 1.97 recommends instrumentation for this variable with a range of -9 to +18'F for an analogous range for alternative stability analysis. The applicant has supplied instrumentation with a range of -12 to
+12'F.
The applicant has not provided justification for the deviation from
+12 to +18'.
Table 1ofRegulatoryGuide1.23(Reference 7)providessevenatmospheric I
stability classifications based on the difference in temperature per 100 meters elevation change. These classifications cover from extremely unstable to extremely stable. Any temperature difference greater than +4*C or less than -2'C does nothing to the stability classification. Therefore, we
' find that this instrumentation is acceptable to detemine the atmospheric stability..
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3.3.19 Accident' Sampling (Primary Coolant. Containment Air and Sump)
I Regulatory Guide 1.97 recomends sampling and onsite analysis capability for the reactor coolant system, containment sump. ECCS pump room sumps and other similar auxiliary building sump liquids and containment air. The applicant's post-accident sampling system provides sampling and analysis as recomended by the regulatory guide, except for the following deviations.
1.
Dissolved hydrogen or total gas--the range has not been identified 2.
Dissolved oxygen--the range is 0.02 to 20 mg/l instead of 0 to 20 ppe.
The applicant takes exception to the guidance of Regulatory Guide 1.97 l
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.
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CONCLUSIONS Based on our review, we find that the applicant either conforms to, or is justified in deviating from Regulatory Guide 1.97, with the following exceptions:
1.
Neutron flux--the applicant's present instrumentation is acceptable on an interim basis, until Category 1 instrumentation is developed andinstalled(Section3.3.1).
2.
Coolant level in reactor--the applicant should cover the recommended range with Category 1 instrumentation (Section 3.3.3).
3.
Suppression pool water level--the applicant should justify the deviation in the lower limit of the instrumentation range (Section3.3.6).
4.
Drywell atmosphere temperature--the applicant should clarify what the instrument range is; any deviation should be justified (Section3.3.10).
5.
Primary system safety relief valve position--the applicant should justify why Category 2 instrumentation cannot be supplied for this l
variable (Section3.3.12).
6.
Standby liquid control system storage tank level--the applicant should confirm conformance to the Category 2 recomendations (except for environmental qualifications since the instrumentation is located in a mild environment (Section 3.3.14).
7.
Emergency ventilation damper position--the applicant should identify where Category 3 instrumentation is used, show why Category 2 instrumentation cannot be used and justify the use of Category 3
~ instrumentation (Section3.3.16).
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Airborne radiohalogens and particulates--the applicant should demonstrate the acceptability of the supplied instrumentation for this variable (Section 3.3.17).
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REFERENCES 1.
NRC 1 ester D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits,
" Supplement No. I to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33) " December 17, 1982.
2.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Concitions During and Following an Accident, Regulatory Guide 1.97, Revision 2. U.S. Nuclear Regulatory Commission (NRC), Office of Standards Development Decemoer 1980.
3.
Clarification of TMI Action Plan Reauirements. Requirements for Emergency Response Capability, NUREG-0737, Supplement No. 1. NRC, Office of Nuclear Reactor Regulation, January 1983.
4.
Gulf States Utilities Company letter, J. E. Booker to D. G. Eisenhut, NRC, April 15, 1983, RBG-14,819, File Code 69.33.4, G9.5.
5.
River Bend Station Final Safety Analysis Report, through Amendment 11.
6.
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.
7.
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 5tandards Development. September 1980.
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