ML20127D443

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Conformance to Reg Guide 1.97,Comanche Peak Steam Electric Station,Units 1 & 2
ML20127D443
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/31/1985
From: Udy A
EG&G, INC.
To:
NRC
Shared Package
ML20127D449 List:
References
CON-FIN-A-6493, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8504150261
Download: ML20127D443 (19)
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Text

{{#Wiki_filter:. 1 CONFORMANCE TO REGULATORY GUIDE 1.97 COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NOS. 1 AND 2 A. C. Udy s Published March 1985 C 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-AC07-76ID01570 FIN No. A6493 h ispa hb m pp.

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 !                                                       ABSTRACT i

This EG&G Idaho, Inc., report provides a review of the submittals for Regulatory Guide 1.97 for Unit Nos. I and 2 of the Comanche peak Steam i Electric Station, and identifies areas of non-conformance to the guide. ,! Any exceptions to these guidelines are evaluated. i 1 1 l FOREWORD i 4 j 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 j Section. .i . l The U.S. Nuclear Regulatory Commission funded the work under j authorization B&R 20-19-40-41-3. i I l 

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i i l Docket Nos. 50-445 and 50-446 l 1 4 l 

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] CONTENTS i ' ABSTRACT .............................................................. ii i FOREWORD .............................................................. 11 i { 1. INTRODUCTION ..................................................... 1 i

2. REVIEW REQUIREMENTS .............................................. 2  ;

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3. EVALUATION ....................................;.................. 4 .

i i i 3.1 Adherence to Regulatory Guide 1.97 ......................... 4 1

3.2 Type A Variables ........................................... 4 i'

3.3 Exceptions to Regulatory Guide 1.97 ........................ 5  ! i i 4. CONCLUSIONS ...................................................... 15

5. REFERENCES ....................................................... 16 J.

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CONFORMANCE TO REGULATORY GUIDE 1.97 COMANCHE PEAK STEAM ELECTRIC 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 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 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).

Texas Utilities Generating Company, the applicant for the Comanche Peak Steam Electric Station, responded to the generic letter with a letter dated April 15, 1983 (Reference 4). The letter referenced Section 7.5 of the Final Safety Analysis Report (FSAR) for a review of the instrumentation provided for Regulatory Guide 1.97. We reviewed material from the FSAR that was submitted in a letter dated June 30, 1982 (Reference 5) and material submitted in a letter dated October 24, 1983 (Reference 6). Amendments 47 and 50 of Table 032.110-1, submitted June 26, 1984 (Reference 7), were also reviewed. Additional information was submitted on January 28, 1985 (Reference 8). This report provides an evaluation of these submittals. i 1 l 1 i 

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2. REVIEW REQUIREMENTS  :

Section 6.2 of NUREG-0737, Supplement 1, sets forth the documentation to be submitted in a report to NRC describing how the applicant meets the guidance of Regulatory Guide 1.97 as applied to emergency response 

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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 l
2. Environmental qualification f
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 questions and concerns regarding the NRC policy on this matter. At these meetings, it was noted that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97. Furthermore, where licensees or applicants explicitly state that instrument systems 2 

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4 j conform to the provisions of the guide it was noted that no further staff 

 !.             review would be necessary. Therefore, this report only addresses i               exceptions'to the guidance of Regulatory Guide 1.97. The following                                                      i j               evaluation is an audit of the applicant's submittals based on the review                                                l 4

policy described in the NRC regional meetings. l i L 4 r i i i t. ! I t t i  ! 1 i , ! e $ l ! 6 i r I i 

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3. EVAWATION This evaluation is based on the following applicant's submittals: the applicant's response to generic letter 82-33 dated April 15, 1983,
!,        Section 7.5 of the applicant's FSAR as reported in a letter dated. June 30, 1982, and additional information submitted on October 24, 1983, June 26, j          1984 and January 28, 1985.                                                                ,

3.1 Adherence to Requiatory Guide 1.97 i j The applicant states in Section 7.5.3.6 of the FSAR that the Comanche f i Peak Station meets the intent of Regulatory Guide 1.97. This statement was l reaffirmed in Reference 6. Therefore, it is concluded that the applicant a t i has provided an explicit commitment on conformance to the guidance of l Regulatory Guide 1.97, with the exception of those deviations identified in I Section 3.3 of this report. 1 i

  • 3.2 Type A Variables i

[ t Regulatory Guide 1.97 does not specifically identify Type A variables, 1.e., those variables that provide information required to permit the I control room operator to take specific manually controlled safety actions, j The applicant classifies the following instrumentation as Type A variables  : I I in the FSAR, Table 7.2. l I . I

1. Reactor coolant system (RCS) pressure, wide range l
2. RCS cold leg water temperature f

I j 3. RCS hot leg water temperature r 4

4. Steam generator level, wide range
5. Steam generator level, narrow range j 6. Pressurizer level . . . . .

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7. Containment pressure, narrow range J

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8. Steam 11ne pressure .

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;                  9. Refueling water storage tank level j                   10. Containment water lavel, wide range i

l i 11. Condensate storage tank level L )' Auxiliary feedwater flow 

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13. Containment radiation level i 14 Core exit temperature. l l [
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f All of the above variables meet Category 1 requirements consistent with the ( i requirements for Type A variables. l j 3.3 Exceptions to Regulatory Guide 1.97 1 l The appitcant identified the following exceptions to the guidelines of l Regulatory Guide 1.97. 

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! 3.3.1 Neutron Flux i. Regulatory Guide 1.97 recommends environmental qualification for this j i

variable. The applicant states that the flux detectors are not qualified I for an accident environment inside containment. The justification giver is t

r that the same information can be had by monitoring the Reactor Coolant i l l System (RC$)hotandcoldlegtemperatures,orasbackup,thecontrolrod ( position and RC5 soluble baron concentration. Also, the power level will [ l be in the power range for a very short period of time during those design l basis accidents that result in a harsh environment inside containment. { 1 5 l 

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Environmental qualification has been clarified since Revision 2 of l Regulatory Guide 1.97 was issued. The clarification is in the i Environmental Qualification 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 l and should be addressed in accordance with 10 CFR 50.49. l l 3.3.2 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends instrumentation with a range from l 0 to 6000 parts per million for this variable. The applicant has provided l instrumentation with a range of 0 to 5000 parts per million. The applicant t states that the range covers the anticipated requirements for normal l operation, anticipated operational occurrences and accident conditions, j i The applicant takes exception to the guidance of Regulatory Guide 1.97 { with respect to post-accident sampling ct.pability. This exception goes  ! l beyond the scope of this review and is being addressed by the NRC as part . of their review of NUREG-0737, Item !!.B.3. f l 1 ! 3.3.3 RCS Hot and Cold Leo water Temperature I r Regulatory Guide 1.97 Revision 2 recommends instrumentation with a range from 50 to 750*F for these variables. The applicant has provided L instrumentation with a range from 0 to 700*F. The applicant states that l the range covers the anticipated requirements for normal operation,  ; anticipated operational occurrences and accident conditions. ( l l l Based on our evaluation of the applicant's justification, we find that ( this deviation is acceptacle. Furthermore, Revision 3 of Regulatory { Guide 1.97 (Reference 9) Itsts the range as 50 to 700'F; this range is met t by the applicant. I i > 

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3.3.4 Coolant Level in Reactor Revision 2 of Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable covering a range from the bottom of the core to the top of the vessel. The applicant has committed to supply instrumentation for this variable. The proposed instrumentation is Category 2 with a range from the top of the vessel to the top of the core. This range is consistent with the recommendation of Revision 3 of the regulatory guide. We find the deviation in the range acceptable. The applicant takes exception to the guidance of the Regulatory Guide 1.97 with respect to the category of the instrumentation. 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 Containment Sump Water Level _ Regulatory Guide 1.97 recommends Category 2 narrow range instruments to measure the fluid height in the sump and Category 1 wide range instruments to measure the fluid height in the containment to the equivalent of 600,000 gallons. The applicant is not supplying narrow range instruments. The Category 1 wide range instruments cover the height from 808 f t (the sump bottom) to 817 f t 6 in. The applicant states that this covers the entire range of expected water level in the containment for post-accident conditions. Based on this statemen*., we corclude that (a) the range is sufficient to monitor the sump r tration for any anticipated condition and (b) the sump level is adequately monitored by the wide range instrumentation to preclude the need for narrow range instrumentation. Therefore, we find that the instrumentation provided for this variable is acceptable. 3.3.6 Containment pressure The Comanche Peak Station has a reinforced concrete containment On this basis, Regulatory Guide 1.97 structure with a steel liner. recommends extended range containment pressure instrumentation with a range. ,, 7 .

of 10 psia to 3 times the design pressure. Table 6.2.1-1 of the Final Safety Analysis Report (FSAR, Reference 9) indicates that the design pressure is 50 psig. Thus the range should be from 10 psia to 150 psig. The applicant has supplied instrumentation for this variable.with a range from 0 to 150 psig. The justification supplied by the applicant for this deviation in range is that the range supplied covers the anticipated measurements for normal operation, anticipated operational occurrences and accident conditions. Additionally, the narrow range pressure instrumentation covers down to -5 psig which covers the recommended lower range of 10 psia. We find that the justification provided by the applicant is acceptable. , 3.3.7 Containment Isolation Valve Position Regulatory Guide 1.97 recommends indication for this variable that meets the recommendations for Category 1 instrumentation, including redundancy. The applicant indicates a deviation from the Category 1 recommendations. From the information provided, we find the applicant deviates from a strict interpretation of the Category 1 redundancy recommendation. Only the active valves have position indication (i.e.; check valves have no position indication). Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory guide. Position indication of check valves is specifically excluded by Table 2 of Regulatory Guide 1.97. Therefore, we find that the instrumentation for this variable is acceptable. 3.3.8 Radiation level in Circulating Primary Coolant Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable with a range from 1/2 to 100 times the technical specification limit. The applicant has supplied a Category 3 instrument with a range of 1 to 105 uCi/ce, stating that the range is within the limits of normal 8

operation, anticipated operational occurrences and accident conditions. Additionally, the post-accident sampling system provides this information i in the post-accident situation. Based on the justification provided by the applicant, we conclude that the instrumentation supplied for this variable is adequate, and therefore, acceptable. 3.3.9 Analysis of Primary Coolant (Gamma Soectrum) The applicant identifies a deviation in the display location in that this analysis is done in the chemical laboratory with no direct display in the control room. Regulatory Guide 1.97 implies that each variable should ' have a display; however, it states that the indications are to be monitored by the control room personnel. The applicant indicates that results of the l ! analysis are obtained from samples or portable monitors, making a direct control room display unreasonable. Section 6.2(g) of NUREG-0737 l Supplement 1 makes allowance for displays in locations other than control room panels. Therefore, we find this deviation acceptable. l 3.3.10 RHR Heat Exchanger Outlet Temeerature i Regulatory Guide 1.97, Revision 2, recommends a range of 32 to 350*F. Revision 3 changed the recommended range to 40 to 350*F. The applicant has supplied a range of 50 to 400'F. The instrumentation supplied has a range ~ ~ where the lower limit of the span does not conform to the regulatory guide. 1 The applicant states that the supplied range covers the anticipated requirements for normal operation, anticipated operational occurrences and accident conditions. Based on this, we find that the range is adequate. 3.3.11 Accumulator Tank level _and Pressure I Regulatory Guide 1.97 recommends Category 2 instrumentation for this l l } variable with a range of 10 to 90 percent volume (for level) and 0 to 1 I ~ 9 . 

,i              750 psig (pressure). The applicant is supplying Category 3 instrumentation f                for level and Category 2 instrumentation for pressure. Ranges are 0 to 100 percent of usable volume and 0 to 700 psig.

J t l The supplied level range is stated to be O to 100 percent of. usable ) volume. (The accumulator volume is 1350 cu ft, Table 6.3.1 of the FSAR). l 2 The level is manually controlled to have a minimum water volume of l i 850 cu ft before an accident. The applicant indicates that the range I covers all anticipated accident and abnormal conditions, and that the level } is backup instrumentation for the pressure instrumentation. ( l The supplied pressure range is 0 to 700 psig. This is equal to the design pressure of the accumulator vessels, the same pressure at which the j accumulator safety relief valves operate, i l i The accumulators are passive devices. Their discharge into the - reactor coolant system (RCS) is actuated solely by a decrease in RCS j pressure. We find that the ranges of the instrumentation suoplied for this { variable are adequate to determine that the accumulators have discharged. Therefore, we find this instrumentation acceptable for this variable. i 1 y > 3.3.12 Boric Acid Charging Flow { l The applicant does not have instrumentation for this variable. The L P l applicant states that the units do not have boric acid charging flow as a l l safety injection system. Centrifugal charging pump flow, safety injection l ! flow and residual heat removal flow are the safety injection variables  ! monitored. Therefore, we find that this variable is not applicable at the f I Comanche Peak Station.  ; 3.3.13 Quench Tank Temperature , I l Regulatory Guide 1.97 recommends a range of 50 to 750'F for this > 1

variable. The applicant has provided a range of 0 to 400*F. The j l justification presented by the applicant for this deviation is that the range cover, the anticipated reautrements for normai operation, anticipated .. ..

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    .. _ _-. ..          --    _ _ _ _ - ~         _ - __._ - - -_       -               .-. _- _ _   . _ _ . _ .

1 . . 1 4 operational occurrences and accident conditions. This is related to the 

!                 tank's rupture disk and the 100 psi tank design pressure that limits the
temperature to saturated conditions under 400 F. Thus, we find that this l i deviation from the recommendation of the regulatory guide is acceptable. t 1 3.3.14 Steam Generator pressure i ,

4 Regulatory Guide 1.97 recommends instrumentation for this variable with a range from atmospheric pressure to 20 percent above the lowest ! safety valve setting. The applicant has provided instrumentation for this I variable with a range from 0 to 1300 psig, less than the recommended i 1440 psig. The justification provided for this deviation is that the l highest setting of tne main steam safety valves is 1235 psig, and that even s i with setpoint accumulation, all safety valves would be fully open at a i pressure of less than 1285 psig. On this basis, we find the range of 0 to l 1300 psig acceptable. i 4 3.3.15 Containment Sump Water Temeerature j

Regulatory Guide 1.97 recommends Category 2 instrumentation for this

) variable, with a range from 50 to 250*F. The applicant has not provided instrumentation for the containment sump water temperature. f The applicant has performed an analysis that shows that the emergency i I core cooling system pumps will have adequate not positive suction head ,. i regardless of the sump water temperature. The applicant establishes that i containment cooling is taking place with a variety of instrumentation, j j including: RHR heat exchanger inlet (Category 3) and outlet (Category 2)  ! ! temperature, RHR system flow (Category 2), containment spray flow f r j (Category 2), containment atmosphere temperature (Category 2), RCS hot and cold leg water temperature (Category 1) and core exit temperature i ! (Category 1). r With adequate not positive suction head provided and suitable alternative instrumentation to show the effectiveness of containment cooling, we find this exception acceptable. - .. l j 

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3.3.16 High Level Radioactive Liouid Tank Level. Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the top to the bottom of the tank. The applicant has an alarm in the control room, and instrumentation covering the recommended range in the local waste processing panels. The applicant indicates that the control room alarm is to prevent the overfilling of the three tanks, and that a full scale display in the control room is not needed. Section 6.2(g) of NUREG-0737 Supplement 1 makes allowance for displays in locations other than control room control panels. Therefore, we find this deviation acceptable. 3.3.17 Radioactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range from 0 to 150 percent of the tank design pressure. The applicant has an alarm in the control room and Category 3 instrumentation covering 0 to 150 psig in the local waste processing panels. The applicant indicates that the control room alarm is to prevent the overfilling of these tanks, and that the display in the control room is not needed. Section 6.2(g) of NUREG-0737 Supplement 1 makes allowance for Thus, we displays in locations other than on control room control panels. find that the display location is acceptable. The applicant states that the range from 0 to 150 psig covers the anticipated requirements fer normal operation, anticipated operational occurrences and accident conditions. Tables 11.3-1 and 2 of the FSAR indicate that these tanks have a design pressure of 150 psig, and that the alarm is set at 100 psig. The design output pressure of the waste gas compressors is also 150 psig. Section 11.3.2.1.1 of the FSAR indicates that there are relief valves capable of relieving the full flow from both waste gas compressors and that they are set to relieve pressure somewhere below the design pressure of the system. Based on this, we find that the deviation from the recommended range is acceptable. . 12

3.3.18 Radiation Excesure Meters The applicant is not supplying instrumentation for this variable, citing errata dated July 1981 that postpones implementation of this variable. Revision 3 of Regulatory Guide 1.97 also deletes this variable. Therefore, we find that the applicant's justification for not providing instrumentation for this variable is acceptable. 3.3.19 Estimation of Atmospheric Stability Regulatory Guide 1.97 recommends instrumentation for this variable with a range of -9 to +18'F or an analogous range for alternative stability. analysis. The applicant has supplied instrumentation with a range of -5 to 

      +5'F. The applicant justifies this, indicating that the range is wider than the range specified in Regulatory Guide 1.23, Revision 1, Table 1,
      " Classification of Atmospheric Stability by Temperature Change with Height." The applicant states that this is equivalent to 25.56*C for an equivalent 100 meter span.

Table 1 of Regulatory Guide 1.23 provides seven atmospheric stability classifications based on the difference in temperature per 100 meters elevation range. These classifications range from extremely unstable to extremely stable. Any temoerature difference greater than +4 or less than 

      -2'C per 100 meter span does nothing to the stability classification.

Therefore, we find that the instrumentation is acceptable to determine the atmospheric stability. 3.3.20 Accident Samplino (primary Coolant, Containment Air and Sump) The applicant's post-accident sampling system provides sampling and analysis as recommended by the regulatory guide, except that it does not have a display in the control room and several parameter ranges do not start at zero (For example: baron content. 0,5 to 6000 ppm; chloride content, 0.5 to 20 pom; dissolved hydrogen or total gas, 0.5 to 2000 cc/kg, dissolved oxygen, 0.5 to 20 ppm; for containment air: hydrogen content. 0.1 to 10 percent, oxygen content, 0.1 to 30 percent), .- l 13

L 4 The applicant takes exception to the guidance of Regulatory Guide 1.97 1 i with respect to post-accident sampling capability. This exception goes j 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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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 exception:
1. Neutron flux--environmental qualification of the flux detectors should be addressed in accordance with 10 CFR 50.49 (Section 3.3.1).

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5. REFERENCES
1. NRC letter, 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 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 i

(NRC), Office of Standards Development, December 1980.

3. Clarification of TMI Action Plan Recuirements, Recuirements for Emergency Response Capability, NUREG-0737 Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4. Texas Utilities Generating Company letter, R. J. Gary to Director of 3'

Nuclear Reactor Regulation, NRC, " Response to NRC Generic Letter 82-33," April 15, 1983.

5. Texas Utilities Services Incorporated letter, H. C. Schmidt to S. Burwell, NRC, " Accident Monitoring Instrumentation," June 30, 1982.
6. Texas Utilities Services Incorporated letter, H. C. Schmidt to i'

Director of Nuclear Reactor Regulation, NRC, " Response to Request for Additional Information, Accident Monitoring Instrumentation," October 24, 1983, TXX-4068.

7. Texas Utilities Generating Company letter, H. C. Schmidt to Ofrector of Nuclear Reactor Regulation, NRC, " Accident Monitoring Instrumentation," June 26, 1984, TXX-4205.

. 8. Texas Utilities Generating Company letter, J. W. Beck to Director of Nuclear Reactor Regulation, NRC, " Response to NRC Staff Interim Evaluation on Accident '4enitoring," January 28, 1985, TXX-4382.

9. 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. ,
10. Final Safety Analysis Report, Comanche Peak Steam Electric Station, Texas Utilities Generating Company, Amendment 45.  !

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