ML20137F898
| ML20137F898 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/30/1985 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML18019A536 | List: |
| References | |
| CON-FIN-A-6493, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8601170593 | |
| Download: ML20137F898 (15) | |
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(Attachment to Enclosure)
E C0hFORMANCE TO REGULATCRY GUIDE 1.97 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NOS.1 AND 2 J. W. Stoffel Published September 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-AC07-761001570 FIN No. A6493 oII70593 pg
1 ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97, Revision 3, for Unit Nos. I and 2 of the Shearon Harris Nuclear Power Plant and ioentifies areas of nonconformance to the regulatory guice. Exceptions to Regulatory Guide 1.97 are evaluated anc those areas where sufficient Dasis for acceptability is not provided are icentified.
FOREWORD Tnis report is supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97," being conducted for tne 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.
4 Docket Nos. 50-400 and 50-401 ii
CONTENTS A B ST RA C T..............................................................
i i FOREWORD..............................................................
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INTRODUCTION.....................................................
I 2.
REVIEW REQUIREMENTS..............................................
2 3.
EVALUATION.......................................................
4 3.1 Adherence to Regulatory Guide 1.97.........................
4 3."2 Ty p e A V a r i a b l e s...........................................
4 3.3 Exceptions to Regulatory Guide 1.97........................
5 4.
CONCLUSIONS......................................................
10 5.
REFERENCES.......................................................
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C0hFORMANCE TO REGULATORY GUIDE 1.97 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT N05.1 AND 2 1.
INTRODUCTION o
On December 17, 1983, 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 aoditional 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.1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Carolina Power ano Light Company, the applicant for the Snearon Harris Nuclear Power Plant, Unit Nos. I and 2, provioed a response to the generic letter on April 15,1983 (Reference 4). The letter with their position with respect to Regulatory Guide 1.97 was submitted on September 6,1983 (Reference 5). Adoitional information was submitted on June 3,1985 (Reference 6).
This report provides an evaluation of these submittals.
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REVIEW REQUIREMENTS Section b.2 of NUREG-0737, Supplement No.1, sets forth the documentation to be submitted in a report to NRC describing how the applicant comp' lies with Regulatory Guide 1.97 as applied to erergency 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.
Recundance ano sensor location 6.
Power supply 7.
Location of display 8.
Schedule of installation or upgrade Furthermore, the submittal should identify deviations from the regulatory guioe and provioe 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. Furthermore, where licensees or applicants explicitly state that instrument systems conform to the regulatory guide it was noted that no further staff review would be 2
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necessary. Therefore, tnis report only adoresses exceptions to Regulatory Gulae 1.97. The following evaluation is an audit of the applicant's submittals baseo on the review policy cescribed in the hRC regional e
meet ings,
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EVALUATION Tha applicant provided a response to Section 6.2 of NRC Generic Letter 82-33 on Septemoer 6, 1983 and additional information on June 3,1985. - This evaluation is based on these submittals.
3.1 Adherence to Regulatory Guide 1.97 ine applicant states that their submittal provides a detailed account of the conformance of tne Shearon Harris Nuclear Power Plant, Unit Nos. I ano 2, to tne recomenoations of Revision 3 of Regulatory Guide 1.97 (Reference 7). The applicant further states that the information provided in their subn.ittal meets the requirements of Supplement No. I to NUREG-0737, Section 6.
Therefore, we conclude that the applicant has provioed an explicit concitment on conformance to Regulatory Guioe 1.ti7.
Exceptions to anc deviations from the regulatory guide are noted in Section 3.3.
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 permit the control room operator to take specific manually controlled safety actions.
The applicant classifies the following instrumentation as Type A.
,f 1.
Reactor coolant system (RCS) hot leg water temperature 2.
RCS cold leg water temperature 3.
RCS pressure
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Core exit temperature 5.
Neutron flux l
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Containment water level 7.
Containment hydrogen concentration
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Containment pressure 9.
Refueling water storage tank (RkST) level
- 10. Pressurizer level
- 11. Steam generator level (narrow range)
- 12. Steamline pressure
- 13. Auxiliary feedwater flow
- 14. Condensate storage tank (CST) level
- 15. Containment spray additive tank level The above variables meet the Category I recommendations consistent with the requirements for Type A variables, except as noted in Section 3.3.
3.3 Exceptions to Regulatory Guide 1.97 1.
The applicant identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.
3.3.1 Neutron Flux In Reference 5, the applicant indicated that their source and intermediate range neutron flux monitors that do not meet Category 1 requirements as recommended by Regulatory Guice 1.97. The applicant stated that this variable was still under investigation.
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In Reference 6, the applicant committeo to the installation of Category 1 instrumentation for this variable in accordance with Regulatory Guide 1.97.
3.3.2 kCS Soluble Boron Concentration Regulatory Guide 1.97 recommends a range of 0 to 6000 ppm for this variable. The applicant has instrumentation that covers a range of 0 to 5000 ppm. Tne applicant's justification is that this boron meter is adequate for any anticipated baron concentration.
The applicant oeviates from Regulatory Guide 1.97 with respect to post-accident sampling capability. This deviation goes beyond the scope of this review and is being adoressed by the NRC as part of their review of NUREG-0737, Item 11.8.3.
3.3.3 RCS Hot ano Cold Leg Water Tenperature The Shearon Harris reactors are three loop reactors. Each reactor loop has an inoication of temperature for both the hot leg and the cold leg; however, in Reference 5, the applicant states that only temperatures of two loops are continuously displayed while the temperatures of the third loop is displayed on demand at the Emergency Response Facilities Information System (ERFIS) computer.
In Reference 6, the applicant has committed to provide continuous inoication of the temperature of the third loop on the main control board for these variables.
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Primary Coolant The applicant has a Category 3 gross failed fuel detector that monitors delayea neutron precursors. The applicant states that if the detector is not available, grab samples may be taken via the post-accident sampling system (PASS) for laboratory analysis.
Based on the alternate instrumentation provided by the applicant, we ccnclude tnat the instrur.entation supplied for this variable is adequate ano, tnerefore, acceptable.
i 3.3.5 Accumulator Tank Level and Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation for these variaoles with a level range that monitors 10 to 90 percent of volume. The applicant has provided instrumentation that, except for environmental qualification, is Category 2.
The level range monitored is between 64.1 and 71.2 percent of the accumulator volume. The applicant states that the tank level and pressure are monitored in accordance with technical specifications during normal operation. The applicant does not expect any i
post-accident operator action based on these variables and states that the tank status can be inferred from the RCS pressure.
The existing instrumentation is not acceptable. An environmentally qualified instrument is necessary to monitor the status of these tanks. If pressure is the key variable, and is environmentally qualified, the i
i existing level range is acceptable. If accumulator level is considered the i
key variable then the range should be expanded to meet the regulatory guide recommenaation in addition to being environmentally qualified.
3.3.6 Quench Tank Temperature Regulatory Guide 1.97 recommends a temperature range of 50 to 750"F for this variable. The applicant has provided a range of 50 to 250*F. The 7
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applicant states, in Reference 5, that the tank design pressure and rupture oisk relief pressure are 100 psig. This corresponds to a saturation temperature of approximately 338'F. In Reference 6, the applicant states that this tank is non-safety and only provides a reservoir for several radioactive fl'uids. Direct position indication of the pressurizer safety and relief valves is provided, along with temperature indication on the discharge header from the pressurizer relief and safety valve discharge lines.
Baseo on the justificaticn and alternate instrumentation provided by the applicant, we conclude that the instrumentation supplied for this variable is adequate ano, therefore, acceptable, 3.3.7 Steam Generator Level In Reference 5, the applicant lists 0 to 100 percent for the range of both narrow ana wide range level instrumentation. No reference is made as to what part of the steam generator these instruments are monitoring. The applicant states that the wide-range transmitters rey be supplemented by the redundant narrow range transmitters on each steam generator. The applicant also states that diversity is provided by use of steamline pressure and auxiliary feedwater flow. In Reference 6, the applicant states that their wide range steam generator level instrumentation meets the range recommended by Regulatory Guide 1.97 3.3.8 Makeup Flow-In Letdown Flow-Out Volune Control Tank Level The applicant takes exception to the environmental qualification,
recommendation of Regulatory Guide 1.97 for these variables. The justification provided by the applicant for this deviation is that these variables are not required for safe plant shutdown and the system is isolated by plant protection signals.
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As these variables are not utilized in conjunction with a safety system, we find that the instrumentation provided is acceptable.
3.3.9 Component Cooling Water (CCW) Flow to Engineered Safety Features (ESF) System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. Category 3 instrumentation is provided. The applicant considers CCW flow to be a backup variable to the exiting Category 2 key variables which demonstrate CCW flow. These key variables are CCW heat exchanger outlet temperature and pressure, CCW pung status and CCW flow leaving the containment from the reactor coolant pumps. These variables are monitored on the main control board.
We fino the applicant's justification acceptable. The temperature and pressure inoication in conjunction with the CCW pumps status and the reactor coolant pump cooling water flow status adequately monitor this system.
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CONCLUSIONS Basad on.our review, we find that the applicant either conforms to or is justified in deviating from Regulatory Guide 1.97, with the following exception:
1.
Accumulator tank level and pressure--environmental qualification should be addressed in accordance with 10 CFR 50.49. If accumulator level is determined to be the key variable the range should be expanded (Section 3.3.5).
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REFERENCES 1.
NRC litter, 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 ano Environs Conditions During ano Following an Accident, Regulatory Guice 1.97, Revision 2, u.S. Nuclear Regulatory Comission (hRC), Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Requirements, Requirements for Emergency desponse capacility, huREG-0/37 dupplement No. I, h R t.,
Office of Nuclear Reactor Regulation, January 1983.
4.
Carolina Power and Light Company Letter, E. E. Utley to Director, Office of Nuclear Reactor Regulation, April 15, 1983.
5.
Carolina Power and Light Company Letter, M. A. McDuffie to Director, Office of Nuclear Reactor Regulation, September 6,1983.
6.
Carolina Power and Light Company Letter, S. R. Zimmerman to H. Denton, Office of Nuclear Reactor Regulation, NRC, " Compliance with Regulatory Guide 1.97," June 3,1985, Serial No. NLS-85-109.
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Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Concitions During and Following an Accident, Regulatory Guide 1.97, Revision 3, U.S. Nuclear Regulatory Comission (NRC), Office of Nuclear Regulatory Research, May 1983.
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This EG&G Idaho, Inc. report provides a review of tb Shearon Harris Nuclear Power Plant, Unit Nos. I and 2, submittal for Regulatory Guide 1.97 and identifies areas of nonconformance to the guide. Any exception to the guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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