ML20138H132
| ML20138H132 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/31/1985 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20138E112 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-51094, NUDOCS 8510280262 | |
| Download: ML20138H132 (21) | |
Text
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Enclosure
" Interim Safety Evaluation" I
CONFORNANCE TO REGULATORY GUIDE 1.97 GRAND GULF NUCLEAR STATION, UNIT NO. 1 i
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A. C. Udy i
Published October 1985 i
EG6G Idaho, Inc.
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Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-761001570 FIN No. A6483 esi42evzezx6 Y
l ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97 Revision 2, for the Grand Gulf Nuclear Station, Unit No.'1, and identifies areas of nonconformance to the regulatory guide.
Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is nat 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 20-19-10-11-3.
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Docket No. 50-416
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CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
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1.
INTRODUCTION.....................................................
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2.
REVIEW REQUIREMENTS..............................................
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3.
EVALUATION.......................................................
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3.1 Adherence to Regulatory Guide 1.97.........................
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3.2 Type A Variables...........................................
4 3.3 Exceptions to Regulatory Guide 1.97........................
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CONCLUSIONS......................................................
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REFERENCES.......................................................
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CONFORMANCE TO REGULATORY GUIDE 1.97 GRAND GULF NUCLEAR STATION. UNIT NO. 1 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 i
operating licenses, and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97 Revision 2 (Reference 2), relating to the requirements for emergency response capability. These requirements have been published as Supplement No. 1 to NUREG-0737, 'TMI Action Plan Requirements" (Reference 3).
Mississippi Power and Light Company, the licensee for the Grand Gulf Nuclear Station Unit No. 1, provided a response to Section 6.2 of the l
generic letter on February 28, 1985 (Reference 4).
This report provides an evaluation of that material.
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2.
REVIEW REQUIREMENTS l
Section 6.2 of NUREG-0737, Supplement No. 1, sets forth the i
documentation to be submitted in a report to the NRC describing how the l
licensee complies with Regulatory Guide 1.97 as applied to emergency response facilities. The submittal shoult! include documentation that provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97.
I 1.
Instrument range 2.
Environmental qualification r
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3.
Seismic qualification 4.
Quality assurance 1
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5.
Redundance and sensor location j
6.
Power supply i
7.
Location of display l
l 8.
Schedule of installation or upgrade I
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 4
rcgional meetings in February and March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on this subject.
j At these meetings, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97.
Furthermore, where licensees or j
applicants esplicitly 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, this report only addresses exceptions to Regulatory Guide 1,97. The following evaluation is an audit of the licensee's submittal based on the review policy described in the NRC regional meetings, e
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3.
EVAL llATION The licensee provided a response to Item 6.2 of NRC Generic Letter.
82-33 on February 28, 1985. The response describes the licensee's position cn post-accident monitoring instrumentation.
This evaluation is based on that material.
3.1 Adherence to Reaulatory Guide 1.97 The licensee has provided a review of their post-accident monitoring instrumentation that shows instrumentation that presently complies with Regulatory Guide 1.97, Revision 2, discusses modifications to bring instrumentation into full compliance with the regulatory guide and discusses deviations that the licensee supports as appropriate to the Grand Gulf Nuclear Station design. The Grand Gulf Nuclear Station, Unit No. 1 Cperating license has a licensing condition that requires all modifications identified for Regulatory Guide 1.97 be complete prior to startup following the second refteling outage (~ August 1987).
Therefore, we conclude that the licensee has provided an explicit commitment on conformance to i
Exceptions to and deviations from the regulatory guide are noted in Section 3.3.
i 3.2 Tvoe A Variables Regulatory buide 1.97 does not specifically identify Type A variables, 4
i.e., those variables that provide information required to permit the control room. operator to take specific manually controlled safety actions.
The licensee classifies the following instrumentation as Type A.
1.
Reactor pressure vessel (RPV) level 2.
RPV pressure j
3.
Dryweli pressure 4.
Drywell atmosphere temperature i
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5.
Primary containment pressure 6.
Primary containment temperature 7.
Suppression pool water temperature 8.
Suppression pool water level 9.
Containment hydrogen concentration 2
- 10. Drywell hydrogen concentration i
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- 11. Main steam isolation valve (Group 1) position These variables, with exceptions as noted in Section 3.3, either meet or will meet the Category 1 reconnendations, consistent with the requirements for Type A variables.
3.3 Excentions to Reaulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97.
These are discussed in the following paragraphs.
3.3.1 Reactor Coolant System (RCS) Soluble Boron Concentration Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 1000 parts per million. The licensee states that the range of this instrumentation is 250 to 10,000 parts per million. No justification was provided for the deviation in the lower limit of the range.
The licensee deviates from Regulatory Guide 1.97 with respect to the l*
range of this post-accident sampling capability. This deviation goes beyond the scope of this review and is being addressed by the NRC as part of their review of NUREG.0737, Item !!.8.3.
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j 3.3.2 Coolant Level in Reactor I
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Regulatory Guide 1.97 recomends redundant instrumentation for this
- t variable with a range from the bottom of the core support plate to the l
1 esser of the ter of the vessel or the centerline of the main steamline.
l The licensee's instrumentation consists of redundant instruments that cover j
3 rones with overlapping ranges, j
l The licensee's instrumentation meets the recomendations of Regulatory 1
Guide 1.97 except for the shutdown range instrumentation, which measures jl the upper 58 inches of the 435 inch recomended range.
It is not fully l
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redundant. These channels will share a reference leg, drywell sensing l
j lines and drywell penetrations.
This avoids an additional penetration of j
the reactor pressure vessel head. The licensee states that only a break of l
l the reference leg or sensing line would prevent both divisions from l
eperating, and that only a marginal plant safety improvement would be made i
j by costly reactor pressure vessel and coatainment penetrations needed for i
full redundancy. Based on these considerations, we conclude that the
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shutdown range instrument channels are acceptable, and that the f
i lastrumentation provided for this variable is satisfactory.
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j 3.3.3 Drvwell Sumo Level Drvwell Orain Sumos Level l
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Regulatory Guide 1.97 recomends Category 1 instrumentation for these j
variables. The licensee has supplied Category 3 instrumentation for these 5 l
variables. The drywell sump systems are automatically isolated at the I
primary containment penetration should an accident signal occur. The i
licensee also identifies alternate instrumentation that monitors leakage.
j This instrumentation consists of fission product monitoring, air cooler l
condensate monitoring, drywell air temperature, drywell pressure, recirculation pump seal monitoring, reactor vessel head seal monitoring and j
safety relief valve exhaust temperature.
i lie conclude that the instrumentation provided by the licensee will l
provide appropriate monitoring of the parameters of concern. 'This l
conclusion is based on (a) for small leaks, the instrumentation is not 6
I expected to experience harsh environments during operation (b) for larger leaks, the sumps fill promptly 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) this instrumentatt'on neither automatically initiates nor alerts the operator to initiate operation of a safety-related system in a post-accident situation.
Therefore, w find the Category 3 instrumentation provided acceptable.
3.3.4 Primary Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category 1 position indication for these valves.
From the information provided, w find the licensee 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, w l
find that redundar.t indication per valve is not intended by the regulatory guide. Position indication of check valves is specifically excluded by 4
i Table 1 of Regulatory Guide 1.97.
Therefore, w find that the instrumentation for this variable is acceptable in regards to redundancy.
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t As noted during our review of the licensee's submittal, the indicating l
lamps are not seismically qualified. No justification was provided for l
this deviation. The licensee should provide the recommended seismic 4
qualification for this Category 1 variable in accordance with the plant's seismic design criteria.
Note 23 of the licensee's submittal, attachment 2 lists 15 valves that do not have position indication on the isolation valve status panel.
l The licensee should verify that indication for these 15 valves is in the r
control room.
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3.3.$ Radiation Level in Circulatina Primary Coolant The licensee indicates that the key instrumentation to measure radiation level to indicate fuel cladding failure is provided by the j
post-accident sampling system which is being reviewed by the NRC as part of
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their review of NUREG-0737. Item 11.8.3.
Additional information is provided by the condenser off-gas and the main steamline radiation monitor before isolation occurs, and by the drywell and containment hydrogen and j
radiation monitors.
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Based on the alternate instrumentation provided by the licensee, we I
cenclude that the instrumentation provided by the licensee for this i
variable is adequate and, therefore, acceptable.
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3.3.6 Sunoression Pool Water Level l
Regulatory Guide 1.97 recomends instrumentation for this variable t
eith a range from the bottem cf the wwrgency core cooling system (ECCS)
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suction to five feet above ti.e norn.a1 level. The instrumentation supplied has a range that exceeds the upper limit, but is lacking six incnes from
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satisfying the recomunended lower limit (103 feet 6 inches instead of
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103 feet). The licensee's instrumentation measures to the centerline of the ECCS suction line rather than to the bottom. With the water level at oither location (centerline or bottom of the suction line), the residual heat removal (RHR) pumps will lose suction. Lack of this six inches of
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range does not preclude any safety system from operating as designed, nor l
1s this portion of the recomunended range required for any operator j
initiated safety action.
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Based on the licensee's justification, we find the range provided for this instrumentation acceptable.
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I 3.3.7 Containment and Drvwell Hydronen Concentration I
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Regulatory Guide 1.97 recomends instrumentation for this variable l
t:ith a range from 0 to 30 percent. The Itcensee's instrumentation has a t
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range of 0 to 10 percent. The licensee states that the hydrogen recombiners trip because of overtemperature when the hydrogen concentration exceeds 4 percent. A hydrogen burn occurs at a hydrogen concentration of 6 percent because of the hydrogen igniters. Thus, hydrogen concentration is limited to less than 10 percent by operator action of redundant Class 1E hydrogen igniters. This operator action is part of the emergency operating procedures and is based on this Type A variable.
As the instrumentation will remain on scale because of the use of the hydrogen ignitors, we find that this instrumentation is acceptable.
3.3.8 Effluent Radioactivity - Noble Gases and Vent Flow Rates Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The power sources for Category 2 instrumentation should be high reliability, not necessarily standby power.
The licensee addresses the power supply for this instrumentation for the following release points as a deviation:
o Containment purge o
Fuel handling area o
Turbine building o
Radwaste building i
This was addressed as a deviation because at one time the licensee had proposed to provide onsite power to this instrumentation. This modification will not be done.
Power to this instrumentation is derived from the same non-Class IE power source as, the ventilation system.
It is not backed up with onsite power. We find that the power sources for this instrumentation are in accordance with Regulatory Guide 1.97, and are acceptable.
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i 3.? 9 iladiation Exposure Rate i
Regulatory Guide 1.97 recomends Category 2 instrumentation for this i
variable with a range of 10 to 10 R/hr. The Category 3
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instrumentation supplied by the licensee has location dependent ranges of either 10 to 1 R/hr, 10 to 10 R/hr or 10' to 100 R/hr.
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The licensee states that this instrumentation is used for an i
l order-of-magnitude indication as the instrumentation will be affected by both the primary containment radiation and the radioactivity in the fluid flowing in the emergency core cooling system piping. The licensee states that because of the amount of this piping and the number of hatches and l
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electrical penetrations, ambiguous indications are expected for this l
l Instrumentation.
Long term accessibility will be evaluated with portable i
radiation survey instruments and containment atmosphere sampling and j
I analysis. Release assessment will be accomplished with noble gas effluent I
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- nonitors, t
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i Regulatory Guide 1.97, Revision 3 (Reference 5), specifies Category 3 i
instrumentation for this variable. Therefore, we find Category 3 j
instrumentation adequate for this variable.
From a radiological stand i
j p21nt, if the radiation levels reach or exceed the upper limits of the ranges provided, personnel would not be permitted into the areas without p:rtable monitoring (except for life saving). We therefore find the
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proposed ranges for the radiation exposure rate monitors acceptable.
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3.3.10 condensate storaae Tank Level i
l Regulatory Guide 1.97 recommends instrumentation for this variable eith a range from the top to the bottom.
The licensee indicates that the j
tank top is at 31 feet and that the range of,the instrumentation includes 1
this. The lower limit of the range is not at the bottom of the tank, but f
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is 6-1/2 inches below the emergency core coolant suction line. Water below i
this level would not be usable as core coolant.
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Based on the licensee's justification, we find this deviation acceptable.
3.3.11 Orywell Atmosphere Temperature Regulatory Guide 1.97 recommends inctrumentation for this variable with a range of 40 to 440*F. The licensee has instrumentation for this variable that has a range of 0 to 400*F. The licensee states that the maximum calculated post-accident drywell temperature is 330*F. Based on the maximum expected temperature transient being 330*F, a range of 0 to 400*F is adequate for this variable.
3.3.12 Main Steamline Isolation Valves' leakaae Control System Pressure Regulatory Guide 1.97 recommends instrumentation for this var. table with a range of 0 to 15 inches of water and 0 to 5 psid. The licensee has two sets of instrumentation for this variable with ranges of 0 to 50 psia and 0 to 100 psig.
1 We find this instrumentation adequate to provide indication of pressure boundary maintenance as recommended by Regulatory Guide 1.97.
Therefore, this instrumentation is acceptable.
3.3.13 Core Soray System Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. As such, environmentally qualified instrumentation is required in accordance with 10 CFR 50.49. The licensee states that this instrumentation is exempt from the requirements of NUREG-0588 and, because of this, environmental qualification to 10 CFR 50.49 15 not required.
Environmental qualification has been' clarified by the Environmental Qualification Rule, 10 CFR 50.49.
10 CFR 50.49 (b) (3) includes post-accident monitoring instrumentation in its scope. We conclude that 1
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Regulatory Guide 1.97 has been superseded by a regulatory requirement. Any oxception to this rule is beyond the scope of this review and should be I
addressed in accordance with 10 CFR 50.49.
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3.3.14 Standby Liould Control System (SLCS) Flow Regulatory Guide 1.97 specifies Category 2 tr.strumentation with a range of 0 to 110 percent of the SLCS design flow. The Grand Gulf Station d:es not measure this flow directly. The operator verifies pump operation I
i by use of the pump operating indicator lights and by a decrease in the SLCS storage tank level. Other parameters that can be monitored to verify j
system operation include squib valve position, SLCS tank outlet valve position and neutron flux.
3 We find the above instrumentation valid as an alternative ind,1 cation of SLCS flow.
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3.3.15 SLCS Storace Tank Level I
Regulatory Guide 1.97 recommends Category 2 instrumentation for this l
variable with a range from the bottom to the top. As such, environmentally j
qualified instrumentation is required in accordance with 10 CFR 50.49.
The instrumentation provided by the licensee is not environmentally qualified.
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The licensee states that the range will be recalibrated to be from 2-1/2 inches above the tank outlet to the tank overflow. This is essentially the b3ttom and top of the tank.
Based on the licensee's justification, the i
j d;viation from the recommended range is acceptable.
Environmental qualification has been clarified by the Environmental l
Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guide 1.97 i
has been superseded by a regulatory requirement. Any exception to this rule is beyond the scope of this review and should be addressed in 1
accordance with 10 CFR 50.49.
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3.3.lb Coolina Water Flow to Enaineered Safety Feature System Components Regulatory Guide 1.97 recommends Category 2 instrumentation for this l
variable. As such, environmentally qualified instrumentation is required j-in accordance with 10 CFR 50.49. The licensee, in the description of this instrumentation, refers to Note 24. Note 24 states that environmental qualification is not necessary for this variable. This statement is based l
on the instrumentation being exempt from the present NUREG-0588 requirements.
Environmental qualification has been clartfled by the Environmental Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guide 1.97 i
has been superseded by a regulatory requirement. Any exception to this q
rule is beyond the scope of this review and should be addressed in j
accordance with 10 CFR 50.49.
l 3.3.17 Hiah Radioactivity Liouid Tank Level
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Regulatory Guide 1.97 reconnends instrumentation for this variable l
with a range from the top to the bottom of the tank. The licensee's j
instrumentation does not comply with this reconnendation, but does measure l
to beyond the tank overflow. The low limit of the range is at 10-5/8 inches. The licensee states that this limit is satisfactory as interlocks are provided to prevent pumpout of the tank contents when the level is below 14 inches.
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The licensee has shown that the instrumentation will remain on scale at all times. Based on this, we find the range of this instrumentation i
acceptable.
4 3.3.18 Status of Standby Power and Other Enerav Sources Imoortant to Safety e
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j The licensee has identified several deviations from the recommended
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Category 2 instrumentation.
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a Startina Air Pressure for the Standby Diesel Generator The licensee has identified this as a backup vari &ble and has used, Category 3 instrumentation with local readout only. A local alarm of abnormal pressure is input to a diesel generator trouble alarm in the j
control room. We find this arrangement acceptable.
Startina Air Pressure for the Hiah Pressure Core Spray Diesel Generator l
The licensee has identified this as a backup variable and has used redundant Category 3 pressure indication and pressure switches with l
local readout only. The pressure switches control the air compressors for this system. The licensee has not mentioned control room alarms associated with the parameter, and no alternative for control room indication is mentioned. The licensee should provide some indication 1
in the control room for this parameter.
Hiah Pressure Core Spray Standby (HPCS) Power The licensee has identified that Category 3 instrumentation for the 4.16 KVAC bus voltage and current are needed to monitor the status of the HPCS power supply. The licensee justifies Category 3 instrumentation because of the diversity provided by other Category 3 a
instrumentation:
the diesel generator frequency, bus 17AC frequency.
Division 3 de voltage (both in the control room and at the bus), local ammeters and the synchonizing circuits voltage.
Based on this diversity, we find the instrumentation provided to determine the status of the HPCS power supply acceptable.
DC Power Voltaae and Current 1
The licensee has identified several deviations for the monitoring of DC power.
a.
Rattery current for Class 1E batteries--The licensee's alternate instrumentation for this parameter measures the balance of the 14
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2 cell voltages between the two halves of the battery.
Should an imbalance exist an operator is dispatched to investigate the situation. We find this an acceptable method for determining the j-condition of the battery.
I b.
Battery charger output current--This is a local instrument with i
no control room readout. The licensee states that this instrument is primarily for service and maintenance personnel.
i Undervoltage alarms are in the control room should a significant overcurrent condition exist. We find this combination of Instrumentation acceptable for this parameter.
i c.
-Batery charger output voltage--The bus voltmeter is used to j
provide this information, along with bus over/undervoltage alarms. This instrumentation is located in the control-room. We 2
find this arrangement acceptable.
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l d.
Battery high discharge rate alarm--The licensee alarms bus l
undervoltage and ground faults.
For a high discharge rate to occur, either or both conditions will exist. We find this instrumentation acceptable.
3.3.19 Standby 6as Treatment System - Noble Gas l
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Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation for this variable consists of two
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sets of instrumentation.
Category 3 instruments cover a range of 10 to i
10 pC1/cc and Category 2 instruments cover a range of 10 to 10' 4
pC1/cc. The licensee has performed an analysis that shows that during accidents and during post-accident conditions, the Category 2 (upper range)
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instrumentation will be on scale. Therefore, we find the instrumentation supplied for this variable acceptable.
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J 3.3.20 Wind Speed Regulatory Guide 1.97, Revision 2, recommends instrumentation for this variable with an accuracy of 10.5 miles per hour. The licensee has identified a deviation in that this instrumentation has an accuracy of 1 percent of the wind speed over the entire range. Thus, over 50 miles per hour, the accuracy is greater than recommended by Revision 2 of the Regulatory Guide.
Revision 3 of the Regulatory Guide permits an accuracy of 10 percent when the wind speed is greater than 5 miles per hour.
Based on Revision 3 of the regulatory guide, we find the licensee's Dind speed accuracy adequate for release assessment.
Therefore, this instrumentation is acceptable.
3.3.21 Accident Samolina (Primary Ccolant. Containment and Sump)_
The licensee's sample system can obtain samples and provide the analyses within the ranges reconnwnded for this variable, with the following exceptions:
o Boron content - the minimum resolution is 250 ppm rather than 0 o
Chloride content - the minimum resolution is 100 ppb rather than 0 1
o Dissolved hydrogen - the minimum resolution is 0.5 percent rather than 0 i
o Dissolved oxygen - the range is 500 ppb to 19 ppm rather than 0
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to 20 ppm o
The suppression pool is sampled ra$her than the sumps The licensee deviates from Regulatory Guide 1.97 with respect to post-accident sampling capability. This deviation goes beyond the scope of this review and is being addressed by the NRC as part of the review of NUREG-0737, Item II.B.3 i
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4.
CONCLUSIONS Based on our review, we find that the licensee either conforms to or is justified in deviating from Regulatory Guide 1.97, with the follow'ing exceptions:
1.
Primary containment isolation valve position--the licensee should provide seismic oualification for the indicating lamps; the licensee should verify that the indication of the valves not located on the isolation valve status panel is located in the control room (Section 3.3.4).
2.
Core spray system flow--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.13).
3.
Standby liquid control system storage tank level--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.15).
4.
Cooling water flow to engineered safety feature system components--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.16),
t 5.
Status of standby power and other energy sources important to ~
safety--the licensee should provide control room indication for the parameter starting air pressure for the high pressure core spray diesel generator (Section 3.3.18).
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BIBLIOGRAPHIC DATA SHEET EGG-NTA-7053 Mt nest.uCteamt on t=4 gvs.sg 2 YsTLE.mo Sw.,sTLt 3 LB.WE96 4.
Confonnance to Regulatory Guide 1.97, Grand
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Gulf Nuclear Station, Unit No.1
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Washington, DC 20555 125 # 6448447
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13 057..c? sJap eem er us, This EG&G Idaho, Inc. report reviews the submittal for the Grand Gulf Nuclear Station, Unit No.1, and identifies areas of nonconfonnance to Regulatory Guide 1.97.
Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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RtFERENCES 1.
NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits, " Supplement No. 1 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 Durino and Followina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Reauirements. Reautrements for Emeraency Response Capability, NUREG-0737, Supplement No. 1. NRC, Office of. Nuclear Reactor Regulation, January 1983.
4.
Mississippi Power and Light Company letter, L. F. Dale to NRC,
" Regulatory Guide 1.97 (Revision 2) Position Report on Accident Monitoring Instrumentation," February 28, 1985, File:
0260/15619/L-813.0, AECM-85/0059.
5.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durino and Following an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
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