ML20138P780
| ML20138P780 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 10/31/1985 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20137W244 | List: |
| References | |
| CON-FIN-A-6483, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7079, TAC-51361, NUDOCS 8511110281 | |
| Download: ML20138P780 (21) | |
Text
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.e CONFORMANCE TO REGULATORY GUIDE 1.97 THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 1
.1. W. Stoffel Published October 1985 EG&G Idaho, Inc.
Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483
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ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97, Revision 3. for Unit No. 1 of the Three Mile Island Nuclear Station 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.
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' FOREWORD F
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 I.itegration, 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.
L Docket No. 50-289 j
o TAC No. 51361 i
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CONTENTS 11 ASSTRACT ..............................................................
p 11 FOREWORD ..............................................................
1
- 1. INTRODUCTION .....................................................
2
- 2. REVIEW REQUIREMENTS ..............................................
4
-3. EVALUATION .......................................................
Adherence to Regulatory Guide 1.97 ......................... 4-3.1 4
3.2 Type A Variables ...........................................
3.3 Exceptions to Regulatory Guide 1.97 ........................ 5 16
- 4. CONCLUSIONS ......................................................
18 u -5. REFERENCES .......................................................
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1 CONFORMANCE TO REGULATORY GUIDE 1.97
. THREE MILE ISLAND 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 operating licenses, and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision i
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).
General Public. Utilities Nuclear Corporation, the licensee for the Three Mile Island Nuclear Station, provided a response to'Section 6.2 of ,
the generic letter on October 1, 1984 (Reference 4). This response i
. provides a comparison of the licensee's instrumentation to the recommendations cf Revision 3 of Regulatory Guide 1.97 (Reference 5).
This report provides an evaluation of that material.
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- 2. REVIEW REQUIREMENTS Section 6.2 of NUREG-0737, Supplement No. 1, sets.for,th 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 4
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 f
c Furthermore, the submittal should identify deviations from the regulatory guide and provide. supporting justification or alternatives.
Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on this subject.
4 'At these meetings, it was noted that the NRC review would only address oxceptions 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 i
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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 The licensee provided a response to Item 6.2 of NRC G,eneric Letter ,
82-33 on October 1, 1984. The response describes the licensee's position i on 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 compares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 3. The review lists the regulatory guide variables, showing either full compliance, j noncompliance with justification, or noncompliance with a commitment and 1
schedule to upgrade. The licensee states that all upgrade modifications
- are scheduled for completion by the second refueling outage after restart, designated refueling outage 7. Therefore, we con:1ude that the licensee ;
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-has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3.
f 3.2 Tvoe A Variables k
Regulatory Guide 1.97 does not specifically identify Type A variables..
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1.e., those variables that provide information required to permit the n I{ control room operator to take specific mcnually controlled safety actions.
!- The-licensee classifies the following instrumentation as Type A.
- 1. -Reactor coolant system (RCS) cold leg water temperature
- 2. RCS pressure
! 3. Core exit temperature 1
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- 4. Degrees of subcooling
- 5. Containment hydrogen concen.tration '
- 6. Low pressure injection / decay heat removal system flow
- 7. Flow in high pressure injection system
- 8. Refueling water storage tank level
- 9. Steam generator level
- 10. Steam generator pressure I 11. Auxiliary or emergency feedwater flow
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- 12. Condensate storage tank water level The above variables either meet or will be modified to meet the Category 1 requirements c:nsistent with the requirements for Type A variables.
3.3 Exceotions to Reaulatory Guide 1.97 h .The licensee identified deviations and exceptions from Regulatory i Guide 1.97. These are discussed in the following paragraphs. .
i 3.3.1 Reactor Coolant System (RCS) Soluble Boron Concentration ,
' Regulatory Guide 1.97 recommends on-line instrumentation with a range of 0 to.6000 ppm. The licensee has not provided this on-line instrumentation, but can obtain the information by utilizing the post-accident sampling system and on-site laboratory analysis.
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. l 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 their review of NUREG-0737 Item II.B.3. - .
3.3.2 RCS Cold Leo Water Temperature Regulatory Guide 1.97 recommends instrumentation with a range of 50 to 700*F for this variable. The licensee has supplied instrumentation with a range of 50 to 650*f. The licensee considers the existing range adequate based on the maximum steam generator pressure of 1200 psig and corresponding saturation temperature of 600'f. Therefore, the cold leg temperature would always be at or below this value. c; Based on the licensee's statement that the instrumentation will remain on scale for any anticipated event, we find the range of this
' instrumentation acceptable.
3.3.3 RCS Hot Leo Water Temperature Regulatory Guide 1.97 recommends instrumentation with a range of 0 to 700*F for this variable. The licensee has supplied instrumentation with a range of 120 to 920*F. The licensee states that at temperatures less than 300*F, the plant will be in the decay heat removal mode, in cold shutdown.
- and this temperature is not then required. The decay heat removal system has additional temperature instrumentation to monitor the RCS in this temperature range. Category 1 core exit thermocouples also provide information below 120'F. ,
Based on the alternate instrumentation and the justification provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable. ,
3.3.4 RCS pressure .
Regulatory Guide 1.97 recommends instrumentation for this variable with a range from 0 to 3000 psig. The licensee has provided 6
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Instrumentation with a range from 0 to 2500 psig. The licensee states that no additional operator action would be taken or performed with an extended range from 2500 to 3000 psig, and tha.t the code safety valves on the pressurizer are set ta relieve pressure at 2500 psig.
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Regulatory Guide 1.97 states that it is essential that the range be sufficient to keep the instruments on scale. The licensee has not shown that the pressure will remain below 2500 psig for all design basis accident
- -. . scenarios. Therefore, we cannot agree with this deviation. The licensee should either show that the supplied range encompasses all anticipated RCS pressures or provide the recommended range.
3.3.5 Radiation Level in Circulatina Primary Coolant 4
, -The licensee indicates that radiation level measurements to indicate fuel cladding failure are provided by the following instruments:
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- 1. Letdown line radiation monitors (during normal operation)
- 2. Post-accident sampling system.
i The post-accident sampling system is available with the reactor isolated, j!
- and 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'11censee, we
-conclude that the instrumentation supplied for this variable is adequate, and therefore, acceptable. .
3.3.6 RHR Heat Exchanaer Outlet Temperature .
Regulatory Guide 1.97 recommends Category 2 instrumentation for this
. variable with a range of 40'F to 350*F. As such, environmentally qualified instrumentation is required in accordance with 10 CFR 50.49. The licensee
- has provided instrumentation that deviates from these recommendations. The licensee considers the existing range of 0 to 300*F sufficient to cover all 4
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Based on the licensee's justification, we find this r*ange adequate to -
monitor this variable during all accident and post-accident conditions, however, the licensee did not provide justification for the environmental qualification deviation.
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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.
3.3.7 Accumulator Tank level and Pressure i
Regulatory Guide 1.97 recommends Category 2 instrumentaticn for this
.e variable. The licensee has provided Category 3 instrumentation that. -
except for environmental qualification, is Category 2. The licensee justifies this deviation by stating inat these instruments provide the tperator information pertaining to tank status during normal operation, and l,
that since the core flooding system is totally passive, no monitoring of ,
[j these parameters is required for any manual actions to mitigate the consequences of an accident. .
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The existing instrumentation is not acceptable. An environmentally qualified instrument is necessary to monitor the status of these tanks.
The licensee should designate either level or pressure as the key var.iable <
to determine accumulator discharge and provide instrumentation, for that'
! variable, that meets the requirements of 10 CFR 50.49.
3.3.8 Accumulator Tank Isolation Valve Position !
Regulatory Guide 1.97 recommends Category 2 instrumentation for this I variable. The licensee states that these are motor operated valves. The ,
circuit breakers for these valves are open and de-energized when the 8
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reactor is critical. Therefore, the licensee recommends that this variable be reclassified as Category 3.
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Based on the licensee's justification and the fac't that these valves are open and do not change position.during or following an accident, we consider Category 3 instrumentation adequate for this variable.
3.3.9 Boric Acid Charaina Flow 4
'. The licensee does not have instrumentation for this variable. The licensee states that the charging system is not part of the emergency ccre cooling system (ECCS). High pressure injection and low pressure injection are the flow paths from the ECCS to the RCS that are monitored. Therefore, we find that this variable is not applicable at the Three Mile Island
- Station.
3.3.10 Pressurizer Level 1-
- 4 Regulatory Guide 1.97 recomends Category 1 instrumentation for this variable. The licensee considers pressurizer level instrumentation to be
- a Category 2 and has not met the environmental qualification requirement for the temperature compensation element. The licensee's design does not
- satisfy the single failure criteria.
l The justification provided by the licenses for these deviations is that pressurizer level is only used as an indicator to the ' operator that I throttling of the high pressure injection flow is allowed.
Pressurizer level is a key variable used to ensure proper operation'of 4 the pressurizer. The licensee has not provided sufficient justification 4
'for deviating from the regulatory guide requirements for this variable.
4 - The licensee should comit to installing redundant Category 1
, , instrumentation for this variable.
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l 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
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f rule 1:; beyond the scope of this review and should be addr*essed in accordance with 10 CFR 50.49. -
3.3.11~ pressurizer Heater Status Regulatory Guide 1.97 recommends instrumentation to monitor the current drawn by the pressurizer heaters. The licensee's instrumentation l consists of on/off indication of the pressurizer heaters. The licensee considers this to be sufficient indication when used in conjunction with
! RCS pressure.
l Section II.E.3.1 of NUREG-0737 requires a number of the pressurizer
.t heaters to have the capability of being powered by the emergency power sources. Instrumentation is to be provided to prevent overloading a diesel
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generator. Also, technical specifications are to be changed accordingly.
The Standard Technical Specifications, Section 4.4.3.2, require that the emergency pressurizer heater current be measured quarterly. These heaters.
as required by NUREG-0737, should have the current instrumentation ,
). recommended by Regulatory Guide 1.97 in the control room.
3.1.12 Ouench Tank Temperature
' Regulatory Guide 1.97 recomends instrumentation for this variable with a range from 50 to 750'F. The installed instrumentation has a range of 0 to 275'F. The licensee states that the tank is isolated with a reactor trip and that the existing temperature range is adequate to detect leakage into the tank.
The licensee has not provided adequate justification for this i deviation. The licensee should submit analysis shcwing that the ,
l tcmperature indication will remain on scale during any accident that lifts i the pressurizer relief valves. -
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l 3.3.13 Safety / Relief Valve Positions or Main Steam Flow Regulatory Guide 1.97 recommends, Category 2 instrumentation for this ,
variable. The licensee has provided Category 3 instrument ~ation. The licensee states that Category 3 instrumentation is acceptable for this variable because they consider the key variables to determine the steam generator (SG) safety / relief valve position or main steam flow to be SG level and SG pressure. Valve position indication is provided as backup
. Instrumentation.
4 The licensee considers the valve position indication to be a backup for the Category 1 steam generator level and pressure instrumentation. As
! the regulatory guide allows backup instrumentation to be Category 3, we i ,
find this deviation acceptable.
3.3.14 Containment Soray Flow .
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Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided instrumentation that, except for environmental qualification, is Category 2. The licensee did not cubmit
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justification for the environmental qualification deviation.
j 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 exceptio,n to.this rule is beyond the scope of this review and should be addressed in -
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! accordance with 10 CFR 50.49.
3.3.15 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from 40 to 400'F. The licensee has supplied i
, Category 3 instrumentation with a range of 0 to 300'F. Their justification for this deviation is that the primary variable required to show accident 4 - mitigation and containment integrity is reactor building pressure, a j
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Category 1 variable. The licensee considers the containment atmosphere temperature a Category 3 variable.
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The containment atmosphere temperature directly 1'dichtes n the -
accomplishment of a safety function.(containment cooling), and is, ,
therefore, a key variable. As such, Category 2 requirements should be met by the licensee.
The licensee states that the presently installed 0 to 300'F centainment temperature indicators provide sufficient range to monitor the sntire spectrum of containment temperature transients as analyzed in the FSAR.
Based on this justification, we find that the existing range is adequate to monitor this variable during all accident and post-accident conditions, however, the instrumentation should be upgraded to conform to the Category 2 criteria.
- e 3.3.16 Containment Sumo Water Temocrature Regulatory Guide 1.97 reconsnends Category 2 instrumentation for this variable. The licensee has supplied instrumentation that, except for environmental qualification .is the Category 2. The licensee states that the minimum available net positive suction head for the decay heat' removal pump is. independent of sump temperature and no automatic or manual actions
!- are initiated based on this temperature.
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.
J 3.3.17 Letdown Flow-Out Regulatory Guide 1.97 recommends Category 2 instrumentation for this i
variable. The licensee.does not consider this variable to be a '
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post-accident Category 2 instrument, and has supplied Category 3 instrumentation. .The licensee states that this variable is not required in the mitigation of an accident and that the letdown system is isolated by '
any accident requiring containment isolation.
As this variable is not utilized in conjunction with a safety system, we find that the instrumentation provided for this variable is acceptable.
3.3.18 Component Coolina Water Temocrature to Encineered Safety Feature (ESF) System Regulatory Guide 1.97 recommends Category 2 instrumentation for this .
variable. The licensee is supplying instrumentation that, except for .
environmental qualification, is Category 2. The licensee states that the
!' decay heat removal heat exchanger outlet temperature provides an adequate measure of the decay heat removal closed cooling water system heat removal capability.
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. The licensee has not met the environmental qualification, requirement for this instrumentation, nor have they met the environmental qualification requirement for decay heat removal heat exchanger outlet temperature (the alternate method mentioned to monitor this variable).
Environmental qualification has been clarified 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 i rule is t. yond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
3.3.19 Component Coolina Water Flow to ESF System Regulatory Guide 1.97 recommends Category 2 flow instrumentation for
, this variable. The licensee does not have instrumentation for this var iab1'e.. The licensee justifies this exception by stating that since all
- decay heat and nuclear services closed cycle cooling systems component 4
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cooling water valves are manually operated and are normally open, pump status and system temperature is sufficient indication for system operation.
The alternate instrumentation will not determine prop *er system eperation should flow blockage or a. pipe rupture occur. The licensee ,
should supply the recommended instrumentation.
3.3.20 Radioactive Gas Holduo Tank Pressure .
! Regulatory Guide 1.97 recommends control room instrumentation for this variable with a range of 0 to 150 percent of design pressure. The licensee has local indication only. The licensee states that the design pressure fer these tanks is 150 psig. When the pressure reaches 82 psig, it initiates a local high pressure alarm. Also, the pressure can be indicated en a local indicator oa demand. At 85 psig, the relief valve opens and discharges to the auxiliary building, where it will be detected and indicated by the auxiliary building radiation monitor. Also, when the , ,
relief valve opens, it will annunciate in the common problem panel in the control rocm.
The licensee does not state what the range of the local indicator is f nor state that the instrumentation is accessable post-accident. Therefore, I we are unable to determine its adequacy. The licensee should either submit f additional justification for this deviation or provide the recommended instrumentation.
s-3.3.21 Status of Standby power and Other Enercy Sources Important to Safety i .
Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided instrument air instrumentation that.,
except for environmental qualification, is Category 2.
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 I
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4 rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
- 3.3.22 Vent from Steam Generator Safety Relief Valves'or Atmosoheric Dumo Valves .
! The *nstrumentation provided for this variable has a range of
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3.96 x 10 to 980 pCi/cc. Regulatory Guide 1.97 recommends 10 to l 3
_. 10 pC1/cc. The existing range does not envelop the upper end of the recommended range. The existing range deviates from the recommended range by 20 pC1/cc, but is adequate to provide the necessary accident and post-accident information. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
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l 4 . 4. CONCLUSIONS I Based on our review, we find that the licensee either conforms to or ,
[ is justified in deviating from Regulatory Guide 1.97, with*the following j cxceptions: - ,
l 1. RCS pressure--the licensee should either show that the present j range is adequate or provide the recommended range
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(Section 3.3.4). ,
- 2. RHR heat exchanger outlet temperature--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 5.3.6).
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! 3. Accumulator tank level and pressure--the licensee should provide a level or pressure instrument for this variable that is environmentally qualified in accordance with 10 CFR 50.49 , ,
(Section 3.3.7). -
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- 4. Pressurizer level--the licensee should commit to installing
- redundant instrumentation for the variable;~ environmental l qualification should be addressed in accordance with 10 CFR 50.49 l# (Section 3.3.10). .
- 5. Pressurizer heater status--the licensee should provide the 7, ,
recommended instrumentation (Section 3.3.11).
- 6. Quench tank temperature--the licensee should provide analysis showing that this instrument will remain on scale during accident and post-accident conditions (Section 3.3.12).
"7 . Containment Spray Flow--environmental qualification should be
- addressed in accordance with 10 CFR 50.49 (Section 3.3.14).
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- 8. Containment atmosphere tevr.perature--the instrumentation should be
. upgraded to Category 2 (Section 3.3.15).
- 9. Containment sump water temperature--environm' ental qualification should be addressed in accordance with 10 CFR 50.49 0
(Section 3.3.16).
- 10. Component cooling water temperature to ESF system--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.18).
- 11. Component cooling water flow to ESF system--the licensee should supply the recommended instrumentation (Section 3.3.19).
- 12. Radioactive gas holdup tank pressure--the licensee should either l supply additional justification regarding the local pressure instrument or provide the recommended instrumentation e
4 .- (Section 3.3.20).
- 13. Status of standby power and other energy sources important to safety--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.21).
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- 5. REFERENCES 1
- 1. NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, !
Applicants for Operatino Licenses, and Holders of Construction ,
Permits, " Supplement No. 1 to NUREG-0737--Requirement; for Emergency *
- Response Capability (Generic Letter No. 82-33) " December 17, 1982. ;
- 2. Instrumentation for Licht-Water"-Cooled Nuclear Power Plants to Assess .
Plant and Envirens Conditions Durina and Fo' lowina an Accident,
- Regulatory Guide 1.97 Revision 2, NRC, Office of Standards l Development, December 1980.
- 3. Clarification of TMI Action Plan Recuirements. Reauirements for Emeroency Response CaDability, NUREG-0737 Supplement No.1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4 General Public Utilities Nuclear Corporation letter, H. D. Hukill to Office of Nuclear Reactor Regulation, NRC, October 1, 1984, Serial No. 5211-84-2252
- 5. Instrumentation for Licht-Water-Cooled Nucletr Power Plants to Assess Plant and Environs conc itions Durina and for owine an Accident, 4 -
Regulatory Guide 1.97, Revis*on 3. NRC, Office of Nuclear Regulatory l' Research, May 1983. ,
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