ML20138L904
| ML20138L904 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/09/1985 |
| From: | Thadani A Office of Nuclear Reactor Regulation |
| To: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| Shared Package | |
| ML20138L910 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8512200101 | |
| Download: ML20138L904 (2) | |
Text
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3.
December 9, 1985 Docket Nos. 50-317
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and 50-210~
Lr a ot Mr. A. E. Lundvall, Jr.
Vice. President - Supply Baltimore Gas & Electric Company P. O. Box 1475 Raltimore, Maryland 21203
Dear Mr. Lundvall:
We are in the process of reviewing the manner in which Calvert Cliffs Units 1 and 2 conform to Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." The enclosed report, prepared by our consultant EG&G, provides the preliminary results of our review. We request that you provide comments on the enclosed report within sixty (60) days following receipt of this letter.
The information requested in this letter affects fewer than 10 respondents; therefore,' OMB clearance is not required under PL 96-511.
Sincerely, Ashok C. Thadani, Director PWR Project Directorate #8 Division of PWR Licensing-B
Enclosure:
As stated cc w/ enclosure:
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Mr. A. E. Lundvall, Jr.
Baltimore Gas & Electric Company Calvert Cliffs Nuclear Power Plant cc:
Mr. William T. Bowen, President Regional Administrator, Region I Calvert County Board of U.S. Nuclear Regulatory Comission Commissioners Office of Executive Director Prince Frederick, Maryland 20768 for Operations 631 Park Avenue D. A. Brune, Esq.
King of Prussia, Pennys1vania 19406 General Counsel Baltimore Gas and Electric Company Mr. Charles B. Brinkman P. O. Box 1475 Manager - Washington Nuclear Operations Baltimore, Maryland 21203 Combustion Engineering, Inc.
7910 Woodmont Avenue George F. Trowbridge, Esq.
Bethesda, Maryland 20814 Shaw, Pittman, Potts and Trowbridge 1800 M Street, NW Mr. J. A. Tiernan, Manager Washington, DC 20036 Nuclear Power Department Calvert Cliffs Nuclear Power Plant Mr. R. C. L. Olson, Principal Engineer Maryland Routes 2 and 4 Nuclear Licensing Analysis Unit Lusby, Maryland 20657 Baltimore Gas and Electric Company Room 720 - G&E Building Mr. R. E. Denton, General Supervisor P. O. Box 1478i Training and Technical Services Baltimore, Maryland 21203 Calvert Cliffs Nuclear Power Plant Maryland Routes 2 and 4 Lusby, Maryland 20657 Resident Inspector c/o U.S. Nuclear Regulatory Commission Combustion Engineering, Inc.
P. O. Box 437 ATTN: Mr. R. R. Mills, Manager Lusby, Maryland 20657 Engineering Services P. O. Box 500 Mr. Leon B. Russell Windsor, Connecticut 06095 Plant Superintendent Calvert Cliffs Nuclear Power Plant Department of Natural Resources Maryland Routes 2 and 4 Energy Administration, Power Plant Lusby, Maryland 20657 Siting Program ATTN: Mr. T. Magette Bechtel Power Corporation Tawes State Office Building ATTN: Mr. D. E. Stewart Annapolis, Maryland 21204 Calvert Cliffs Project Engineer 15740 Shady Grove Road Gaithersburg, Maryland 20760 Mr. R. M. Douglass, Manager Quality Assurance Department Baltimore Gas and Electric Company Fort Smallwood Road Complex P. O. Box 1475 Baltimore, Maryland 21203
CONFORMANCE TO REGULATORY GUIDE 1.97 CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 J. W. Stoffel Published October 1985 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-AC07-76IO01570 FIN No. A6483
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ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97 for Unit Nos. 1 and 2 of the Calvert Cliffs Nuclear Power Plant 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 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., NRR and I&E Support Branch.
The U.S. Nuclear Regulatory Commission funded the work under authorization B&R 20-19-10-11-3.
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Docket Nos. 50-317 and 50-318 TAC Nos. 51078 and 51079 J
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CONTENTS ABSTRACT...................................
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11 FOREWORD..............................................................
11 1.
I N TR 0 0 'J C T I ON.....................................................
1 2.
REVIEW REQUIRENENTS..............................................
2 3.
EVALUATION.......................................................
4 3.1 Adherence to Regulatory Guide 1.97.........................
4 3.2 Type A Variables...........................................
4 3.3 Exceptions to Regulatory Guide 1.97........................
5 4.
CONCLUSIONS......................................................
16 5.
REFERENCES.......................................................
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CONFORMANCE TO REGULATORY GUIDE 1.97 CALVERT CLIFFS NUCLEAR POWER PLANT. 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 No. 1 to NUREG-0737, 'TMI Action Plan Requirements" (Reference 3).
Baltimore Gas and Electric Company, the licensee for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, provided a response to the Regulatory Guide 1.97 portion of the generic letter on December 1, 1984 (Reference 4).
This report provides an evaluation of that submittal.
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REVIEW REQUIREMENTS Section 6.2 of NUREG-0737, Supple' ment No. 1, sets forth the documentation to be submitted in a report to the NRC describing how the licensee complies with 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 regioral 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
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Cxceptions taken to Regulatory Guide 1.97.
Furthermore, where licensee ~s 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, 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.
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3.
EVALUATION
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The licensee provided a response "to NRC-Generic Letter.82-33 on December 1, 1984. The response descr,1bes the licensee's position on post-accident monitoring instrumentation. This evaluation is based on that submittal.
3.1 Adherence to Reaulatory Guide 1.97 The licensee provided an account of the conformance of the Calvsrt Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, to Revision 3 of Regulatory Guide 1.97 (Reference 5). The licensee states that the information provided in their submittal meets the requirements of Supplement No. 1 to NUREG-0737, Section 6.
The licensee will complete any modification-identified to provide compliance to Regulatory Guide 1.97 prior to the startup following the cycle 10 refueling outage (Unit 1 - Spring 1988),
and the cycle 9 refueling outage (Unit 2 - Fall 1988) (Reference 6).
Therefore, we conclude that the licensee has.provided an explicit commitment on conformance to Regulatory Guide 1.97.
Exceptions to and d2viations from the regulatory guide are noted in Section 3.3.
s 3.2 Tvoe A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, 1.p., 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.
Pressurizer level 2.
Pressurizer pressure 3.
Steam generator pressure 4
4.
Steam generator level 5.
Reactor coolant system (RCS)' hot leg temperature.
6.
RCS cold leg temperature 7.
Degrees of subcooling 8.
Condensate tank No.12 level 9.
Containnent hydrogen concentration
- 10. Containment pressure The above instrumentation meets the Category 1 reconnendations consistent with the requirements for Type A variables.
3.3 Exceptions 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 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. As such, environmental qualification is recommended. The in-containment equipment is not qualified for a harsh environment. The licensee states that upgrading of the equipsent located in a harsh environment is being evaluated. Resolution is pending additional operating experience with the new ex-core detectors installed on the auxiliary i
shutdown panel.
Environmental qualification has been clarified by the Environmetal l
Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guide 1.97 has been superseded by a reguitory requirement. Any exception to this rule 5
is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
3.3.2 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends a range of 0 to 6000 ppm for this variable. The licensee has instrumentation that covers a range of 0 to 5000 pm. The licensee's justification is that this boron meter is adequate for any anticipated boron concentration.
The licensee deviates from Regulatory Guide 1.97 with respect to the 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 II.B.3.
3.3.3 Core Exit Temperature Regulatory Guide 1.97 recommends Category 1 instrumentation that is cnvironmentally qualified and has a range of 200 to 2300*F. The licensee has instrumentation with a range of 32 to 2000'F that is not
,snvironmentally qualified. The licensee states that an evaluation of the adequacy of the existing design and electrical installation is being ccnducted and that the instrumentation will be upgraded if necessary.
e The licensee should justify the deviation of 300*F in the upper range cr expand the range to that recommended by the regulatory guide.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guide 1.97 has been superseded by a regulatory requirement. Any exception to this rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
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3.3.4 Dearees of Subcoolina Regulatory Guide 1.97 recommends'a range of 200'F subcooling to 35'F superheat for this variable. The lic,ensee has instrumentation that calculates the subcooled nergin over a range of 100 to O'F of subcooling.
The licensee justifies this range deviation by stating that the provided range is adequate to meet the needs of the emergency operating procedures.
Manual calculation of the saturation margin over a greater range can be done using the RCS temperature and pressure.
The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737. Item II.F.2.
3.3.5 Containment Sump Water Level I
Regulatory Guide 1.97 recommends Category 2 instrumentation for the narrow range instrumentation associated with this variable. The licensee takes exception to the environmental qualification recmunended for Category 2 instrumentation. The licensee states that this equipment is used only during normal operation and that post-accident monitoring is accomplished by the wide range instrumentation.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guide 1.97 has been superseded by a regulatory requirement. Any exception to this rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
3.3'.6 Radiation Level in Circulatina Primary Coolant The licensee has provided one instrument loop to measure activity over a range of 0 to 10 counts per minute. This instrument is only used during normal operation to monitor gross activity changes. This instrument-is isolated in the event of safety injection actuation. Post-accident n monitoring is accomplished by grab sample analysis using the post-accident 7
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sampling system, which is being reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3.
Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.
3.3.7 Accumulator Tank level and Pressure The licensee takes exception to the pressure range (0 to 750 psig) and cnvironmental qualification recommended by Regulatory Guide 1.97 for this variable. The licensee states that the safety injection tank (SIT) level and pressure is only used for pre-accident indication of the status of SITS to assure that the safety injection system is prepared to serve its safety function.
The licensee states that the pressure instrumentation provided (0 to 250 psig) is adequate to monitor the status of these tanks, and that the existing range will not be exceeded since relief valves on the tanks are sat to to relieve at 250 psig.
We find that the ranges of the instrumentation supplied for this variable are adequate to determine that the accumulators have discharged.
However, the existing instrumentation is not acceptable.
Environmentally q5ilified instruments are necessary to monitor the status of these tanks in accident and post-accident conditions. The licensee should designate oither level or pressure as the key variable to determine accumulator discharge and provide instrumentation, for that variable, that meets the I
requirements of 10 CFR 50.49.
3.3.8 Flow in Hiah Pressure Injection System The range is not as recoamended by Regulatory Guide 1.97 (0 to 110 percent of design flow). The instrumentation provided covers #a range of 0 to 300 gpm. Table 6-1 of the Calvert Cliffs Final Safety Analysis Report (FSAR) lists pump design flow as 345 gpm.
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The licensee has not provided justification for this deviation. The licensee should submit the basis that shows that this instrumentation range will cover any expected flow, or provide the-range recommended by Regulatory Guide 1.97.
3.3.9 Refuelina Water Storace Tank Level Regulatory Guide 1.97 recommends a range of top to bottom for this variable. The licensee has provided instrumentation for this variable with a range that spans from 18 inches above the tank bottom to 12 inches below the tank top. The licensee states that the instrumentation meets the guidelines for post-accident monitoring.
We find this deviation minor with respect to the overall size of the tank. The existing instrumentation is adequate to monitor the operation of the storage tank during all accident and post-accident conditions.
i Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.10 Pressurizer Heater Status
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The licensee takes exception to using electric current to monitor all of the heater groups.
Ammeters are provided for the two proportional heater banks only. All six heater banks have on-off indicating lights.
The licensee justifies this deviation by stating that while electric surrent is not measured for all heater banks, the existing design provides sufficient and adequate information for post-accident monitoring.
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Section II.E.3.1 of NUREG-0737 requires'a number of pressurizer heaters to have the capability of being powered by the emergency power sources.
Instrumentation is to be provided to prevent overloading a diesel generator. Also, technical specifications are to be changed accordingly.
l The Standard Technical Specifications for Combustion Engineering l
Pressurized Water Reactors, Section 4.4.3.2, require that the emergenty pressurizer current be measured quarterly. These emergency power supp.11ed heaters should have the current instrumentation recommended by Regulatory Guide 1.97.
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3.3.11 Quench Tank Level Regulatory Guide 1.97 reconnends 'a leve4 range from the top to the bottom of this tank. The licensee has provided, instrumentation that ccrresponds to 4 percent to 96 percent of the tank volume. The licensee states that while the range is less than required, the' instrumentation provided is adequate and sufficient for the intended post-accident monitoring function.
We find this deviation minor with respect to the overall size of the tank. The existing instrumentation is adequate to monitor the operation this tank during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.12 Steam Generator Level Regulatory Guide 1.97 recommends instrumentation that reads from the tube sheet (445 inches below normal operating level (NOL)] to the scparators (39 inches above NOL). The licensee has provided instrumentation that reads from 401 inches below NOL to 63.5 inches above
, NOL. The licensee states that while the range is slightly less than rcquired by Regulatory Guide 1.97, it is adequate for post-accident monitoring.
The steam generator is, in effect, empty at -401 inches of water relative to the normal operating level; therefore, this deviation is minor when compared to the overall range and instrument accuracy. The existing range is adequate for the intended monitoring function.
3.3.13 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends 400*/ for the upper range limit. The licensee has provided instrumentation that reads to 300'F. The licensee states that the maximum temperature predicted inside the con +ainment during a postulated accident is 274'F.
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Since the worst case postulated accident will not in:rease the containment atmosphere temperature above 274*F, we find the range of 0 to 300',F adequate to monitor this variabTe during all accident.and post-accident conditions.
3.3.14 Containment Sumo Water Temperature The licensee does not have instrumentation for the containmen' sump water temperature. The licensee justifies this deviation by stating that this variable is not used in the management of a design basis accident and is not required for post-accident monitoring.
This is insufficient justification for this exception. The licensee should provide the reconnended instrumentation for the functions outlined in Regulatory Guide 1.97 or identify other instruments (i.e., residual heat removal (RHR) inlet tenperature] that provide the same information and satisfy the recommendations of the regulatory guide.
3.3.15 Makeuo Flow-In Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of 0 to 110 percent design flow for this variable. The instrumentation provided monitors 0 to 94 percent of design flow and does not meet all Category 2 criteria. The licensee justifies this deviation by stating that this variable is not r? quired for post-accident monitoring and is isolated in the event of a safety injection actuation.
As this variable is not utilized in conjunction with a safety system, 1
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we find that the instrumentation provided is acceptable.
3.3.16 Letdown Flow-Out Volume Control Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation for lhese variables and a level range of top to bottom for the volume control tank.
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The provided instrumentation does not meet the Category 2 requirements for either of these variables and the range monitored for the volume control tank is 8 to 86 percent of the tank volume. -The licensee states that the level indication of the volume control tank is used only during normal cperation and the existing range is adequate for this use.
Furthermore, the letdown line and volume control tank make-up to the reactor coolant system is isolated in the event of a safety injection actuation.
As these variables are not utilized in conjunction with a safety system, we find the instrumentation provided is acceptable.
3.3.17 Component Cooline Water Temperature to Enaineered Safety Features (ESF) System The licensee deviates from the range recommended by Regulatory Guide 1.97 (40 to 200'F) for this variable. The licensee has provided a range of 50 to 200'F and states that this range is adequate and sufficient fcr post-accident monitoring.
The deviation of 10*F out of the neximum span of 200*F is 5 percent.
We consider this deviation minor and acceptable.
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3.3.18 Component Coolina Water Flow to ESF System The licensee does not have flow indicators for this variable. The
-licensee states that an evaluation of the need for this instrumentation will be conducted.
If the review indicates the flow instrumentation is needed it will be provided.
The licensee should either commit to install the recommended flow instrumentation, or provide supporting justification or alternatives for this exception.
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3.3.19 Hiah-level Radioactive Liauid Tank Level Regulatory Guide 1.97 recommends' instrumentation for this variable that reads from the top to the bottom of the tank. The licensee has provided instrumentation that reads from 73 inches above the bottom to 60 inches below the top of the hemispherical ended tank. This corresponds to 93 percent of the tank volume. The licensee states that the instrumentation provided is adequate for post-accident monitoring.
We find this deviation minor with respect to the overall size of the tanks. The existing range is adequate to monitor the operation of these tanks during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.20 Radioactive Gas HolddD Tank Pressure Regulatory Guide 1.97 recomends a range for this variable to cover 0 to 150 percent of the design pressure. The instrumentation provided has a range of 0 to 150 psig which is 0 to 100 percent of design pressure. The justification given by the licensee is that the upper range limit of 3
100 percent of tank design pressure is adequate for post-accident monitoring and at 150 psig the holdup tanks relieve to the surge tank.
Based on the justification provided by the licensee, we conclude that othe instrumentation provided for this variable is adequate to monitor the operation of these tanks and is, therefore, acceptab1(
l 3.3.21 Radiation Exposure Rate Regulatory Guide 1.9) recommends a range of 10- R/hr to 10* R/hr for this variable. The licensee has provided instrumentation with a range of 0.1 mR/hr to 10 R/hr. The licensee jusitifies this deviation by stating l
that the intended function of this instrumentation is personnel protection and the existing range is sufficient for that purpose. Detection of -
releases, release assessment and surveillance are performed through health 13
physics procedures with supplemental information provided by the effluent monitors.
From a radiological standpoint, 1f the radiation levels reach or cxceed the upper limit of the range, personnel would not be permitted into the areas without portable monitoring (except for life saving).
Based on the alternate instrumentation used by the licensee for this variable, we find the proposed range for the radiation exposure rate monitors acceptable.
3.3.22 Vent from Steam Generator Safety Relief Valves or Atmospheric Dump Valves Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided Category 2 instrumentation with the oxception of environmental qualification. The licensee's justification for this deviation is that the only postulated event requiring this instrumentation is a steam generator tube rupture, and that environmental qualification is not required for steamline break or loss of coolant accident.
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Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guide 1.97 has been superseded by.a regulatory requirement. Any exception to this rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
3.3.23 All Identified Plant Release Points Regulatory Guide 1.97 reconsnends a range of 10 to 10 pCi/cc fer this variable. The range provided by the licensee is 10-" to 5 x 10-Inci/cc for particulates.
Halogens are sampled and analyzed off line. The licensee states that although the range does not meet Regulatory Guide 1.97 guidelines, it is sufficient for the purpose of monitoring giant releases.
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J The justification provided by the licensee for this range deviation is unacceptable. The licensee should either expand the range to that recommended by the regulatory guide or' subm14 analysis that. shows that the existing range will not be exceeded during accident and post-accident conditions.
3.3.24 Estimation of Atmosoheric Stability Regulatcry Guide 1.97 recommends a range of -5 to 10*C for this variable. The licensee has provided a range of -3 to 7'C.
The justification provided by the licensee is that their instrumentation is adequate for the intended monitoring function.
Table 1 of Regulatory Guide 1.23 (Reference 7) provides seven atmospheric stability classifications based on the difference in temperature per 100 meters elevation change. These classificiations range from extremely unstable to extremely stable. Any temperature difference greater than +4*C or less than -2'C does nothing to the stability classification. The licensee's instrumentation includes this range.
Therefore, we find that this instrumentation is acceptable to determine the atmospheric stability, s
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CONCLUSIONS Based on our review, we find that' the 14censee either conforms to or is justified in deviating from Regulatory Guide 1.97, with the following exceptions:
"l 1.
Neutron flux--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.1).
2.
Core exit temperature--the licensee should expand the range of the existing instrumentation; environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.3).
3.
Containment sump water level (narrow range)--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.5).
4.
Accumulator tank level and pressure--environmental qualification should be addressed in accordance with 10 CFR 50.49 for the parameter designated as the key variable (Section 3.3.7).
5.
Flow in high pressure injection system--the licensee should i
expand the existing range for this variable or justify the present range (Section 3.3.8).
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Containment sump water temperature--the licensee should either supply the recommended instrumentation or identify suitable alternate instrumentation (Section'3.3.14).
7.
Component cooling water flow to ESF system--the licensee should either supply the recommended instrumentation or justify this exception (Section 3.3.18).
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8.
Vent from steam generator safety relief valves or atmospheric dump valves--environmental qualification should be addressed in accordance with 10 CFR 50.47 (Sect 4on 3.3.22).
9.
All identified plant release points--the licensee should expand the existing range for this variable or justify the present range (Section 3.3.23).
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REFERENCES 1.
NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Bolders of Cons,truction Permits, " Supplement No. 1 to NUREG-0737--Requirements for Emergency R9sponse Capability (Generic Letter No. 82-83)," December 17, 1982.
2.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Requirements. Reauirements for Emeraency Response Capability, NUREG-0737, Supplement No.1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4.
Baltimore Gas and Electric Company Letter, A. E. Lundvall, Jr., to Director Office of Nuclear Reactor Regulation, " Regulatory Guide 1.97 Review " December 1, 1984.
5.
Instrumentation for Licht-Wa'ter-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followina an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
6.
NRC letter E. J. Butcher to A. E. Lundvall Jr., Baltimore Gas and Electric Company, " Order Modifying License Confirming Additional Licensee Commitments on Emergency Response Capability (Supplement No. 1 to NUREG-0737)," July 16, 1985.
_ 7.
Onsite Meteoroloaical Proarams, Regulatory Guide 1.23 (Safety Guide 23), NRC, february 17, 1972 or Meteoroloaical Procrams in
)
Suncort of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, September 1980.
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seaWOGRAPHIC DATA SHEET EGG-NTA-7071
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.w.96.a.a Conformance to Regulatory Guide 1.97, Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2
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Washington, DC 20555 i
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This EG8G Idaho, Inc. report reviews the submittal for Unit Nos. I and 2 of the Calvert Cliffs Nuclear Power Plant, and identifies areas of nonconform-ance 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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