ML20141M851
| ML20141M851 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 11/30/1985 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20140C173 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-51103, NUDOCS 8602280438 | |
| Download: ML20141M851 (27) | |
Text
..
CONFORMANCE TO REGULATORY GUIDE 1.97 MAINE YANXEE ATOMIC POWER STATION A. C. Udy Published November 1985 EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483 M3h,j
$7, N
38
T l
\\
4 ABSTRACT 4
This EG&G Idaho, Inc., report reviews the submittal for Regulatory 3
Guide 1.97, Revision 3, for the Maine Yankee Atomic Power Station and i
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 provioed are identified.
I FOREWORD 1
1 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 Nuc1' ear Reactor Regulation, Division of Systems Integration, by EG&G Idaho, Inc., NRR ano I&E Support Branch.
i The U.S. Nuclear Regulatory Commission funded the work under authorization B&R 20-19-10-11-3.
1, j
Docket No. 50-309 j
l ii
CONTENTS 4
A B S TR A C T...............................................................
ii FOREWORD..............................................................
ii 1.
INTRODUCTION.....................................................
1 2.
REVIEW REQUIREMENTS..............................................
2 1
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......................................................
20 5.
REFERENCES.......................................................
23 I
I O I
O e
iii
CONFORMANCE TO REGULATORY GUIDE 1.97 MAINE YANKEE ATOMIC POWER STATION 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. I to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Maine Yankee Atomic Power Company, the licensee for the Maine Yankee Atomic Power Station, provided a response to Section 6.2 of the generic letter on February 28, 1985 (Reference 4). This submittal addresses the recommendations of Regulatory Guide 1.97, Revision 3 (Reference 5).
Tnis report provides an evaluation of that material.
0 4
a f
1 i
i.
1
e 2.
REVIEW REQUIREMENTS Section 6.2 of NUREG-0737, Supplement 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 rssponse 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 l
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 regional meetings in February and March 1983, to answer licensee and applicant questions ano concerns regarding the NRC policy on this suoject.
At these meetings, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97. Furthermore, where licensees or applicants explicitly state that instrument systems conform to the regulatory guide it was noted that no further staff review would be 2
necessary. Therefore, this report only addresses exceptions to Regulatory i
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 1
W I
4 4
I i
a O
i 3
i
- -, -. - - ~
3.
EVALUATION 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 on post-accident monitoring instrumentation. This evaluation is based on that material.
3.1 Adherence to Regulatory Guide 1.97-4 The licensee has provided a review of their post-accident monitoring instrumentation that' compares th.e instrumentation characteristics against the recomendations of Regulatory Guide 1.97, Revision 3.
The licensee shows that in several instances, satisfactory instrumentation already exists and states that adoitional instrumentation will De installed to comply with the provisions of Regulatory Guide 1.97, except for those instances where deviations are justified. The licensee states in their report that the identified modifications will be completed during the 1985 refueling outage. Therefore, we conclude that the licensee has provided' an explicit,comitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3.
3.2 Type A Variables Regulatory Guide 1.97 coes not specifically identify Type A variables, i.e., those variables that provide information required to permit the control room operator to take specific manually controlled safety actions.
The licensee classifies the following instrumentation as Type A.
1.
Reactor coolant system (RCS) cold leg water temperature 2.
RCS hot leg water temperature i
i 3.
RCS pressure 4.
Wide range containment sump water level 2
I 1
4 i
1 _
~,.. _,.-_ _ -.____ __ _ _._ _._ _. _ _ - _ __ ~.-
i
.t 5.
High range containment pressure 6.
Containment area radiation 7.
Pressurizer level o
8.
Steam generator level 9.
Steam generator pressure.
This instrumentation meets the Category I recommendations consistent with j
the requirements for Type A variables, with the exceptions as listed in Section 3.3.
~
3.3 Exceptions to Regulatory Guide 1.97 i
j The licensee identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.
l 3.3.1 Reactor Coolant System Pressure t
Regulatory Guide 1.97 recommends instrumentation with a range fr..a i
i O to 4000 psig for this variable for Maine Yankee's Combustion Engireering j
supplied nuclear steam supply system. The licensee's instrumentation for this variable has a range of 0 to 3250 psig, i
The licensee states that, as part of the final resolution of the anticipateo transient without scram (ATWS) issue, they are 1nstalling an l
ATWS mitigation system that curtails reactor coolant system pressures in l
excess of 3250 psig. As the pressure is limited to the O to 3250 psig range of the instrumentation, we find the range acceptable.
I e
3 i
\\
l 5
i i
- -. _ _.. _ ______,___,,___. _ _ ~ ~_ _
3.3.2 Coolant Level in Reactor Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has identified the following deviations for the instrumentation provided; l) there is no reoundant instrumentation, 2) one recorder indicates the level for all three instrument loops, and 3) all three instrument loops are powered by the same power source, VB-1.
The licensee states that the core exit thermocouples, the subcooled margin monitors and the safety parameter display system and the plant computer displays provide alternate and backup indication for this variable.
1 This exception goes beyond the scope of this' review and is being addressed by the NRC as part of their review of NUREG-0737, Item II.F.2, 3.3.3 Degrees of Subcooling 4
Regulatory Guide 1.97 recorrends instrumentation for this variable l
with a range of 200*F subcooling to 35'F superheat. The instrumentation supplied by the licensee has a range of 0 to 200*F subcooling. Superheat is I
not monitored. No justification for this deviation was given by the licensee.
The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737, Item II.F.2.
3.3.4 Containment Sumo Water Level 1
Regulatory Guide 1.97 recommends narrow range instrumentation for this variable. The licensee does not include narrow range intrumentation. They state that the wide range instruments have resolution sufficient for measurement of the range in question. The licensee states that the sumps isolate below 6 inches water level, and that the wide range instruments are adequate for all usable (above 6 inches) sump levels.
f 6
l-Because the wide range instrumentation covers the entire range of i
i expected water levels for post-accident conditions, we conclude that (a) the range is sufficient to monitor the sump operation for any anticipated condition and (b) the sump level is adequately monitored by the i
l.
wide range instrumentation to preclude the need for narrow range instrumentation. Therefore, we find that the instrumentation provided for p
this variable is acceptable.
3.3.5 Containment Pressure l
Regulatory Guide 1.97 recommends instrumentation for this variable with a range of -5 psig to three times design pressure. The licensee has instrumentation for this variable with a range of 0 to 200 psig. The
]
licensee did not provide justification showing that monitoring j
subatmospheric pressures is unnecessary.
1 i
The licensee should either provide instrumentation capable of monitoring subatmospheric containment pressures or provide justification for this deviation.
i 3.3.6 Radiation Level in Circulating Primary Coolant l
The licensee nas instrumentaten that monitors the radiaton level in the letdown line during normal operaiton. This line is isolated with an accident signal. Thus, this instrumentation is not available I
post-accident, and the post-accident sampling system, which is being revieweo oy the hRC as part of their review of NUREG-0737, Item II.B.3, is used to verify fuel cladding integrity.
Based on the alternate instrumentation provided by the licensee, we I
conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.
1 i
7 l
3.3.7 Radiation Exposure Rate Regulatory Guide 1.97 recmunends ' instrumentation for this variable with a range of 10-I to 10 R/hr. The licensee has instrumentation for
~
4 this variable with a range of 10-# to 10 R/hr. The licensee states tnat this instrumentation is used to determine area accessibility. Portable instrumentation is used to survey the area prior to and during any work i
being done in the areas monitored.
The licensee has not shown an analysis of radiation levels expected for the monitor locations. The licensee should show that the existing radiation exposure rate monitors have ranges that encompass the expected radiation levels in their locations.
J 3.3.8 Residual Heat Removal (RHR) System Flow l
Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The instrumentation supplied by the licensee meets Category 2 requirements except in environmental qualification. Tne licensee states that the Category 2 low pressure safety injection flow instrumentation can be used for tnis variable should qualified instrumentation be needed. That instrumentation does not have a range that covers the design flow for the I
RHR system. The licensee also states that instrumentation for this variable is not required to function for any of the accidents analyzed in the Maine Yankee Final Safety Analysis Report (FSAR).
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 l
rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
i 0
8 m -,.. - - -,,,, - - -. -,,, - -
,--w-7 e.-
e.--.
...,ym-,,
.,-.-,,,,.y--g,.-..,,
-...,.-..---,-.----.----,-,+-3
-+.
3.3.9 RHR Heat Exchanger Outlet Temperature Regulatory Guide 1.97 recomends Category 2 instrumentation for this variable. The licensee's instrumentation for this variable meets the Category 2 requirements except for environmental qualification. The licensee states that for large break loss-of-coolant accidents (LOCA) the RHR system is isolated, and that this instrument would not be used. For a small break LOCA, the licensee states that this instrumentation may be used during recirculation. The licensee states that the containment sump contents would not exceed 191*F and that no net positive section head pump problems would result for the high pressure safety injection pumps, even if the heat exchanger is not functioning. The licensee states tnat heat removal can be monitored by the rise in primary and secondary component cooling water (PCCW and SCCW) temperatures.
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.
3.3.10 Accumulator Tank Level and Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation for this variable meets the Category 2 requirements except in environmental qualification. The range of the pressure instrumentation is not as recomended. The regulatory guide recommenos a range of 0 to 750 psig. The licensee's instrumentation has a range of 0 to 300 psig.
The licensee states that the accumulators are a passive system ano that they are not accessible during an accident. Because the level and pressure are verified and recorded by the operator on each shift, the i
licensee does not supply environmentally qualified instrumentastion for
~
this variable. Environmental qualification has been clarified by the i
9
~
1
~
Environmental Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guide 1.97 has been superseded by a regulatory requirenent. Any exception to this rule is beyond the scope of this review and should be adoressed in accordance witn 10 CFR 50.49.
The licensee states that the accumulator safety relief valves are set for 250 psig. Because of these safety relief valves, the pressure in the accumulators will not exceed the range of 0 to 300 psig. Therefore, we find the range acceptable.
3.3.11 Accumulator Isolation Valve Position Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation for this variable meets the Category 2 requirements except for environnental qualification. The licensee states that there is no need to monitor the position of these valves ouring or after an accident because these valves are opened in the startup procedure and electrically disabled in the open position.
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.
3.3.12 Boric Acid Charging Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation for this variable meets the Category 2 requirements except for environmental qualification. The licensee states that the flow transmitter is not required to operate in a harsh environment, because the flow is not through the transmitter during emergency boration. For emergency boration, the flow from the boric acid 1
10
storage tank to the reactor coolant system is via the boric acid transfer pumps and the charging pumps, in series. The flow is calculated by the rated pump flow rate and the duration of the pump operation.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49. !!e 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.
3.3.13 Low Pressure Injection System Flow Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 110 percent of design flow. The~ licensee identifies this requirement as 0 to 2100 gallons per minute, and the range of the instrumentation as 0 to 300 gallon per minute. No justification was given for this deviation.
The licensee should verify that the provided range encompasses the recommended range.
~
3.3.14 Pressurizer Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the top to the bottom. The licensee's instrumentation measures from 146 to 321 inches. This deviation has not been justified by the licensee.
The licensee should identify the range of the instrumentation in relation to the height of the vessel, justify the deviation or expand the range of tne instrumentation to that recommended by Regulatory Guide 1.97.
e 11
-- ~ = = -.
3.3.15 Pressurizer Heater Status Regulatory Guide 1.97 recomends monitoring the pressurizer heater olectric current with Category 2 instrumentation. The licensee monitors the heater circuit breaker position. This deviation has not'been justified by the licensee.
Section II.E.3.1 of NUREG-0737 requires a number of the pressurizer heaters to have the capaDility 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.
The Standard Technical Specifications for Combustion Engineering reactors, Section 4.4.3.2, require that the emergency pressurizer heater current be measured quarterly. These emergency power supplied heaters should have the cwent instrumentation recomended by Regi iatory Guide 1.97.
3.3.16 Quench Tank Temperature Regulatory Guide 1.97 recommends instrumentation for this variable e:ith a range from 0 to 750*F. The licensee's instrumentation has a range of 0 to 350*F. The licensee states that the normal tank temperature is 104*F, and that the maximum temperature that can be reached by the tank contents is 350*F.
The range covers the anticipated requirements for normal operation, anticipated operational occurences and accident conditions. Because the temperature of the tank contents will not exceed the 0 to 350*F range of the instrumentation, we find this deviation from the regulatory guide acceptable.
3.3.17 Steam Generator Level Regulatory Guide 1.97 recommends Category 1 instrumentation for this j
variable with a range from the tube sheet to the separators. The j
licensee's Category 1 instrumentation has a 140 inch range of 42 to 182 inches. This 12 l
v,-
-y-
does not indicate level from the tube sheet to the separators. This deviation from the regulacory guide was not justified by the licensee.
From the information provided by the licensee, we cannot conclude that the recomendations of Regulatory Guide 1.97 have been met for this variable. The licensee should provide instrumentation with the range recomended by Regulatory Guide 1.97 for this variable.
3.3.18 Steam Generator Pressure Regulatory Guide 1.97 recomends instrumeittation for this variable with a range of 0 to 20 percent above the lowest safety valve setting. The licensee nas identified the lowest safety valve setting as 985 psig (1000 psia). Thus, the recomended range is 0 to 1200 psia. The licensee's instrumentation has a range of 0 to 1000 psia. The licensee states that this range is sufficient, however, there are five additional safety valves with settings above 1000 psia.
As there are Setpoint tolerances and instrument accuracies to consioer, we find the range provided for this variable not acceptable. The steam generator pressure can exceed the capabili'.ies of the instrumentation. The licensee should provide the overrange capability recomended by the regulatory guide.
3.3.19 Condensate Storage Tank Water Level i
Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee's instrumentation is Category I except for satisfying tne single f ailure criteria. The licensee indicates that the diverse low level alarm is sufficient for the redundancy of this variable.
Concerning this alarm, the licensee states that it is independent ano powered separately from the level instrumentation channel; however, the licensee has not shown it to be a Category 1 channel. Therefore, we cannot 13
find this diversity acceptable. The licensee should provide a redundant channel of instrumentation for this variable that is qualified to Category 1.
3.3.20 Containment Spray Flow-Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 0 to 110 percent of design flow. The licensee's instrumentation for this variable is the containment spray header pressure (which is Category 1) and spray valve position (the category of this indication is not mentioned). The licensee has not shown that this instrumentation is adequate under all containment spray system conditions.
.The licensee should show that the spray valve position indication is Category 2, and address flow blockage and pipe rupture.
3.3.21 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 40 to 400*F.- As Category 2 instrumentation, it snould be enviromentally qualified and isolated. The licensee's instrumentation deviates from these reconnendations. The licensee states tnat environmental qualification is not needed because this instrumentation is used only for containment leakage tests, and not for normal or post-accident operation.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49. We conclude that Regulatory Guioe 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 witn'10 CFR 50.49.
l The licenses states that isolation from the plant computer is not needed because this instrumentation is not required for normal or post-accident use. They are used for containment leakage tests only. Tne 14
range of the instrumentation is 30 to 150*F, rather than the recommended 40 to 400*F. No justification was given by the licensee for this deviation.
The licensee has not addressed the purpose of this variable as outlined in Regulatory Guide 1.97. Therefore, we find these deviations not acceptable. The licensee should provide the reconnended instrumentation for this variable.
3.3.22 containment Sump Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 50 to 250*F. The licensee has not provided this instrumentation, stating that an analysis has determined that the required safety equipment will not be adversly affected by the sump water temperature.
This is insufficient justification for tnis exception. The licensee should provide the recommenced instrumentation for the' functions outlined in Regulatory Guide 1.97 or identify other instruments that provide the same information and satisfy the regulatory guide.
3.3.23 Makeuo Flow-In Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. Thus, environmentally qualified instrumentation should be utilized. The iitstrumentation provided for this variable is not environmentally qualified. The licensee states that charging can be performed using the high pressure injection system, using its qualified flow instrumentation, should the makeup flow instrumentation fail due to a harsh environment.
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 15 I
i rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
3.3.24 Letdown Flow-Out Regulatory Guide 1.97 recommends Category 2 instrumentation for this variaole. Thus, environmentally qualified instrumentation should be utilized. The instrumentation provided for this variable is not environmentally qualified. The licensee states that the high pressure drain line can be used for letdown should the letdown flow instrumentation fail due to a harsh environment. The high pressure drain line flow is measured by instrumentation located in a mild post-accident environment.
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.
3.3.25 Component Cooling Water Flow to Engineered Safety Features System Components Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 0 to 110 percent of design flow. The licensee does not nave instrumentation for this variable. The licensee states that this exception is justified because a break in the ccaponent cooling water (CCW) system can be identified by a loss of level in the CCW surge tanks.
This alternate instrumentation has not been shown to be Category 2.
Its aoility to monitor the CCW System operation for all post-accident conditions has not be demonstrated.
The licensee should provide the recommended instrumentation for the functions outlined in Regulatory Guide 1.97 or identify other instruments that provide the same information and satisfy the regulatory guide.
16
3.3.26 Radioactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a readout in the control room. The licensee's instrumentation for
~
this variable has local indication only. No justification was provided by,
the licensee for this deviation.
The licensee has not shown that this instrumentation is accessable post-accident. Therefore, we are unable to determine its adequacy. The licensee should either submit additional justification for this deviaiton or provide the recommended instrumentation.
3.3.27 Containment or Purge Effluent-Noble Gases and Vent Flow Rate Regulatory Guide 1.97 recommends instrumentation for this variable with ranges of 10-6 to 10 uCi/cc and 0 to 110 percent of design 5
0 flow. The licensee provides a range of 10 to 10 cpm.
The equivalence to the recommended range is not stated.
Instrumentation for the vent flow rate is not mentioned. Therefore, we are unable to determine the adequacy of the licensee's instrumentation for this variable. The licensee should submit additional information and justification concerning the instrumentation for this variable or provide the recommended instrumentation.
3.3.28 Common plant Vent-Noble Gases and Vent Flow Rate i
Regulatory Guide 1.97 recommends instrumentation for this variable with ranges of 10-6 to 10 uCi/cc ana 0 to 110 percent of design flow. The 3
6 6
licensee provides ranges of 10 to 10 cpm, 100 to 10 cpm and 0.1 to 7
10 mR/hr.
The licensee states that the flow rate is known based on the number of fans operating. The flow rate for each individual fan is a known quantity.
The licensee also states that calculations have been made that snow the e
17
equivalence between the recommended range and the supplied range and units.
The licensee has this information available for review should an audit need this information.
Based on this equivalence, we find that the instrumentation provided is adequate to monitor this variable during all accident and post-accident conditions.
3.3.29 Vent from Steam Generator Safety Relief Valves-Noble Gases, Duration and Mass of Steam per Unit Time Regulatory Guide 1.97 recommends instrumentation for this variable with ranges to 10~I to 10 vC1/cc, seconds and mass of steam per unit time.
3 The licensee provides a range of 10-I to 10 mR/hr.
7 The equivilance to the recommended range not stated.
Instrumentation for the duration of the release and the mass of steam per unit time is not mentioned. Therefore, we are unable to determine the adequacy of the
- licensee's instrumentation for this variable. The licensee should submit additional information and justification concerning the instrumentation for this variable or provide the recommended instrumentation.
3.3.30 Estimation of Atmospheric Stability Regulatory Guide 1.97 recommends instrumentation for this variable with a range of -9 to +18'F.
The licensee has provided instrumentation for this variable with a range of -8 to 20*F.
Table 1 of Regulatory Guide 1.23 (Reference 6) provides seven atmospheric stability classifications based on the difference in temperature per 100 meters elevation change. These classifications range from extremely unstable to extremely stable. Any temperature difference greater than +4*C or less tnan -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.
18 a
i
3.3.31 Accident Sampling (Primary Coolant, Containment Air and Sump)
The licensee's post-accident sampling system provides sampling and analysis as recommended by the regulatory guide, except that:
~
1.
the primary coolant and sump are not analyzed for dissolved oxygen,
- and, 2.
the containment air is not analyzed for oxygen content.
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.
O h
o I
H O
19 c-
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 following exceptions:
1.
Containment pressure--the licensee 'should either provide instrumentation capable of monitoring subatmospheric containment pressures or provide justification for tnis deviation (Section 3.3.5).
1.
Radiation exposure rate monitors--the licensee should show that the instrument range is greater than the expected radiation levels at their locations (Section 3.3.7).
3.
RHR system flow--environmental qualification should be addressed in accordance witn 10 CFR 50.49 (Section 3.3.8).
4.
RHR heat exchanger outlet temperature--environmental
~
qualification should addressed in accordance with 10 CFR 50.49 (Section 3.3.9).
5.
Accumulator level and pressure-environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.10).
6.
Accumulator isolation valve position--environmental-qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.11).
7.
Boric acid changing flow--environmental qualificaton should be addressed in accordance with 10 CFR 50.49 (Section 3.3.12).
8.
Low pressure injection system flow--the licensee should verify that the provided range encompasses the recommended range (Section3.3.13).
20
9.
Pressurizer level--The licensee should provide justification for the deviation from the reconsnended range or provide the range recomended by the regulatory guioe (Section 3.3.14).
- 10. Pressurizer heater status--the licensee should provide the recomended current instrumentation (Section 3.3.15).
- 11. Steam generator level--the licensee should provide the recomended instrumentation for this variable (Section 3.3.17).
- 12. Steam generator pressure--the licensee should provide the recomended overrange capabilities (Section 3.3.18).
- 13. Condensate storage tank water level--the licensee should provide a second Category 1 channel of instrumentation for this variable (Section 3.3.19).
- 14. Containment spray flow--the licensee should show that the spray l
valve position indication is Category 2 and adoress flow blockage and pipe rupture (Section 3.3.20).
- 15. Containment atmosphere temperature--the licensee should provide the reconsnended instrumentation for this variable (Section 3.3.21).
- 16. Containment sump water. temperature--the licensee shoulo provide the recomended instrumentation or identify alternate instrumentation that provides the same information.and satisfies the regulatory guide (Section 3.3.22).
- 17. Makeup flow-in--environmental ~ qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.23).
l 21
~
1
~...
- 18. Letdown flow-out--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.24).
- 19. Component cooling water flow to engineered safety features system components--the licensee should provide the recanmended instrumentation or identify alternate instrumentation that provides the same information and satisfies the regulatory guide (Section 3.3.25).
- 20. Radioactive gas holdup tank pressure--The licensee should either submit additional justification for local readout only, or provide the recommended instrumentation (Section 3.3.26).
- 21. Containment or purge effluent--the licensee should submit adcitional information and justification conc'erning the instrumentation for this variable or provide the recommended instrumentation (Section 3.3.27).
- 22. Vent from steam generator safety relief valves--the licensee should submit additional information and justification concerning the instrumentation for this variable or provide the recommended instrumentation (Section 3.3.29).
22
e 5.
REFERENCES 1.
hRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits
~
" Supplement No. I to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
2.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards.
Development, December 1980.
3.
Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability, NUREG-0737, Supplement No. 1, NRC, OfficeofNuclearReactorRegulation,danuary1983.
4.
Maine ' ankee Atomic Power Company letter, G. D. Whittier to Director of Nuclear Reactor Regulation, NRC, " Regulatory Guide 1.97 Report".
February 28, 1985, MN-8-43, GDW-85-71.
5.
Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assass Plant ano Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
6.
Onsite Meteorological Programs, Regulatory Guide 1.23 (Safety Guide 23), NRC, February 17, 1972 or Meteorological Programs in Support of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, September 1980.
c e
23
4 m _,,
i c 7;'";;"
sisWOGRAPHIC DATA SHEET EGG-NTA-7083
,w, J 68 *'t #4*
s 3,e,6.
we,.,6a Conformance to Regulatory Guide 1.97, Maine Yankee Atomic Power Station l
November 1985 A. C. Udy g
November 1985
~ n..u,
.- s. -
.- ne - *,- ~
EG&G Idaho, Inc.
Idaho Falls, ID 83415 A6483
...,,. or.o =,
s u, -
..- a. -
Preliminary-Technical Division of Systems Integration Evaluation Pannet Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, DC 20555
..c, a This EG8G Idaho, Inc. report reviews the submittal for the Maine Yankee Atomic Power Station and identifies areas of nonconformance to Regulatory Guide 1.97.
Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
.. ;.,.gg.
..-..........c.-.
Limited Distribution
-.v. a..c..
- ,be UncTassified
..,,.. = =
, v.
a Unclassified 5
G.
,-__.--