L-82-332, Conformance to Reg Guide 1.97,Fort St Vrain Nuclear Generating Station
| ML20141M890 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/30/1985 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20141M891 | List: |
| References | |
| CON-FIN-A-6483, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, GL-82-332, TAC-51092, NUDOCS 8603030011 | |
| Download: ML20141M890 (10) | |
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CONFORMANCE TO REGULATORY GUIDE 1.97 FORT ST. VRAIN NUCLEAR GENERATING STATION l
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A. C. Udy i
i Published November 1985 l
1 E646 Idaho, Inc.
Prepared for the U.S. Nuclear Regulatory Commission l
Washington. 0.C.
20655 Under 00t Contract No. Ot-AC07-761001570 r
FIN No. A6403 f
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ABSTRACT This EG&G Idaho, Inc., repor t reviews the submittal for Regulatory Guide 1.97 for the f ort St. Vrain Nuclear Generating Station and identifies areas of nonconformance to the vegulatory guide.
Exceptions to Pegulatory Guide 1.97 are evaluated and those areac where sufficient basis for acceptability is not provided are identified.
FOREWORD This report is supplied as part of the ' program for Evaluating Licensee /Appilcant Conformance to R.G. 1.97,* being conducted for the U.S.
Nuclear Regulatory Commission Office of Nuclear Reactor Regulation.
Division of Systems Integration, by EG6G Idaho, Inc., NRR and 16E Support tranch.
The U.S. Nuclear Regulat ry Commission funded the work under authorization 20-19-10-11 3.
Docket No. 50-267 TAC No. 51092 11
CONTENTS AR$ TRACT..............................................................
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FOREMORD................................................... *...
11 1.
INTRODUCTION....................................................
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REVIEW REQUIREMENTS..............................................
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........................
4 4.
CONCLUSIONS..........................................
10 5.
REFERENCES.......................................................
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i CONFORMANCE TO REGULATORY GUIDE 1.97 FORT ST. VRAIN NUCLEAR GENERATING STATION i
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INTRODUCTION
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f 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.
i 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).
l The Public Service Company of Colorado, the licensee for the Fort St. Vrain Nuclear Generating Station, provided a response to the l
l Regulatory Guide 1.97 portion of the generic letter on February 28, 1985 (Reference 4).
This report provides an evaluation of this submittal.
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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 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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Fort St. Vrain station. The licensee has utilized the concept of key and backup variables as described in Regulatory Guide 1.97 in determining the category of the instrumentation to be supplied.
3.3.1 Tvoe O Variables The licensee has identified instrumentation to be utilized for the following plant safety functions.
o Reactivity control o
Core cooling o
Reactor coolant system integrity o
Reactor containment integrity These plant safety functions,and their key and backup instrumentation are used to monitor twenty-six Type 8 variables. These functions correspond to those in Regulatory Guide 1.97.
Each function has a key variable identified and several backup variables. We find the instrumentation supplied for the Type 8 variables consistent with the purpose of Regulatory Guide 1.97 and, therefore, acceptable.
3.3.2 Tvoe C Variables The licensee has identified instrumentation to be utilized to indicate the poten tal for being breached or the actual breach of the barriers to fission product releases. This instrumentation is grouped as follows.
o fuel particle coating integrity a
o Reactor coolant system pressure boundary o
Rehter containment integrity 5
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o Ventilation systems o
Power supplies a
This instrumentation is used to monitor thirty-seven Type D variables.
These groups of instrumentation correspond to the groups identified in l
Three groups of instrumentation identified in Regulatory Guide 1.97 for Type D variables are not mentioned by the licensee. These are auxiliary feedwater system, containment cooling system and radwaste system. There is no auxiliary feedwater system at Fort St.
i Vrain. Feedwater is provided by the feedwater system at all times, using either a steam turbine or a pelton wheel water turbine, which are on the same shaft as the feed pump, as motive power. Thus, instrumentation for auxiliary feedwater is not needed.
There is no containment building at Fort St. Vrain. The containment function is provided by the prestressed concrete reactor vessel which is cooled by the reactor plant cooling system. This system is provided with appropriate monitoring instrumentation.
The licensee has not identified instrumentation for radweste systems.
The instrumentation for the helium purificaton system may provide some post-accident information in this area. The licensee should verify that all their radweste systems have appropriate instrumentation.
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Regulatory Guide 1.97 recommends Category 2 instrumentation for the ventilation systems and power supplies. The instrumentation provided for these groups of instrumentation is Category 3.
The licensee did not I
justify this deviation. The licensee should provide Category 2
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instrumentation for these variables.
t For the instrumentation groups reserve shutdown system, reactor plant cooling system, purification cooling water system, helium purification i
system and nitrogen system, the Itcensee has not identified the key l
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1 Guide 1.97 for Type E variables are not mentioned by the licensee. These
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are containment radiation and area radiation. As containment is provided by the prestressed concrete reactor vessel, instrumentation for containment radiation is not needed. Area radiation monitors should be provided in the reactor building as recomended by Regulatory Guide 1.97.
For environs radiation and radioactivity, the licensee's response lists portable radiation instrumentation and sensors. This is not responsive to the requirements of NUREG-0737, Supplement No. 1 Section 6.2.
The regulatory guide lists four variables under this heading. The licensee should provide additional information on the instrumentation provided for these variables.
For the variable estimation of atmospheric stability, Regulatory Guide 1.97 recommends a range of -9 to +18'F for this variable. The licensee's instrumentation has a range of -5 to +5'F.
No justification for this deviation was provided.
The licensee should either expand the range of this instrumentation to conform with the regulatory guide or show that the instrumentation system provides resolution of delta temperatures for the determir,ation of atmospheric stability categories as defined in Regulatory Guide 1.23 (Reference 5).
For the variable accident sampling (primary coolant, containment air and sump), Regulatory Guide 1.97 recomends sampling the following parameters: gross activity, game spectrum, boron content, chloride content, hydrogen content, oxygen content and pH. The licensee lists the parameters gross activity and game spectrum.
Some of these parameters may not be necessary because the Fort St. Vrain design does not have a containment building and sump.
The licensee deviates from Regulatory Guide 1.97 with respect to post-accident sampling capability. This deviation goes beyond the scope of this review and is being addressed by the NRC as part of the review of NuttG-0737, Item 11.5.3.
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Nitrogen system--the licensee should identify the key variable for this instrumentation group and upgrade the instrumentation for this variable to Category 2 (Section 3.3.3)
- 10. Steam generator pressure--the licenses should provide Category 2 instrumentation for this variable (Section 3.3.3)
- 11. Area radiation--the licensee should provide the recommended instrumentation for the reactor building (Section 3.3.4)
- 12. Environs radiation and radioactivity--the licensee should provide additional information on the instrumentation supplied for these variables (Section 3.3.4)
- 13. Estimation of atmospheric stability--the licensee should install instrumentation with the recommended range or justify the use of the existing instrumentation (Section 3.3.4) t 9
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Conformance to Regulatory Guide 1.97. Fort St. Vrain Nuclear Generating Station
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EG&G Idaho Inc.
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Idaho Falls. ID 83415 A6483 Division of Systems Integration Preliminary Technical Office of Nuclear Reactor Regulation Evaluation Report
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U.S. Nuclear Regulatory Comission Washington, DC 20555 This EG&G Idaho Inc. report reviews the submittal for the Fort St. Vrain Nuclear Generating 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.
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