ML20151B072

Forwards Rev 6 to Util Position on Reg Guide 1.97 Re Display of Category 1 Variables on Spds,In Response to Generic Ltr 82-33.Changes Incorporated in Position Rev Based on NUREG-0737 & NUREG-1286 Documentation

ML20151B072
Person / Time
Site:	Rancho Seco
Issue date:	03/31/1988
From:	Andognini G SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Miraglia F Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-1286, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-2.B.3, TASK-TM GCA-88-106, GL-82-33, NUDOCS 8804080045
Download: ML20151B072 (22)

Text

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kSMUD SACRAMENTO MUNICIPAL UTIUTY DISTRICT O P. O. Box 15830, Sacramento CA 95852-1830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALtFORNIA MAR 31 1888 GCA 88-106 U. S. Nuclear Regulatory Commission Attn: Frank J. Miraglia, Jr.

Associate Director for Projects 11555 Rockville Pike Rockville, MD 20852 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 REGULATORY GUIDE 1.97 POSITION, REVISION 6

Dear Mr. Miraglia:

In response to Generic Letter 82-33, the District submitted by letters dated July 13 and September 14, 1984; October 31, 1985; and March 30 and December 20, 1987, its response to Regulatory Guide 1.97. As part of the District's Expanded Augmented System Review and Test Prcgram (EASRTP), a review of the District's Regulatory Guide 1.97 position revealed seieral areas requiring clarification with regara to the display of Category 1 variables on the SPDS. Additional detail and changes to the report are provided as Attachment I to clarify the District's position.

Clarification for the physical separation for Category 1 variables was deemed necessary based on our review of the NRC's Safety Evaluation Report en Rancho Seco Restart NUREG-1206, the District's submittal of Engineering Peport ERPT-E0220 "Report on Confomance of Nuclear Service Electrical Building (NSEB) and DG Building Electrical Installation to Regulatory Guide 1.75" that is referenced in NUREG-1286, and the Rancho Seco Appendix R Fire Protection Program (see Attachment I).

Recent changes to the Post Accident 3ampling System (PASS) which were submitted to the NRC on May 4,1987, have affected the range of some of the PASS analyses. These changes deviate from the ranges recommended in Regulatory Guide 1.97, Revision 3, but were found to be acceptable by the NRC for meeting the requirements of Iten II.B.3 of NUREG-0737. These changes are incorporated in this Regulatory Guide 1.97 Position revision based on the NRC staff acceptance documented in NUREG-1286.

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~8804090045 880331 PDR ADOCK 05000312 RANCHO SECU NUL.,Lt n au.nn..dG STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935

5 GCA 88-106 Frank J. Miraglia, Jr. MAR 311989 In addition to the items discussed above, some miscellaneous changes have been incorporated to correct instrument tag numbers and to delete the implementation schedule which is provided by seperate correspondence.

i Attachment I describes the changes that have been made by Revision 6 to the Rancho Seco Generating Station Unit No.1, Regulatory Guide 1.97 Position.

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Attachment II contains replacement pages for incorporating Revision 6 into the Rancho Seco Generating Station Unit No.1, Regulatory Guide 1.97 Position.

Please contact me if you htye any qu, e stions. Members of your staff with questions requiring additional information or clarification may contact Mr. Jerry Delezenski at (209) 333-2935 extension 4914.

Sincerely,

) ),) Axu

'G. Carl Andognini Chief Executive Officer, Nuclear Attachments cc: G. Kalman, NRC, Rockville A. D'Angelo, NRC, Rancho Seco J. B. Hartin, NRC, Walnut Creek l

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, AttachmInt I

. . P2g3 1 of 6 REGULATORY GUIDE 1.97 POSITION CUMMARY OF REVISION 6 CHANGES Pace 10, ParacraDh III.A.8.

Old:

The Category 1 variables will be displayed in the SPDS in the Control Room and will be uniquely identified.

Changed to:

The SPDS CRTs provide the primary display of Category 1 variables for use under accident conditions.

Reason for change: a Reg. Guide 1.97 requires instruments designated as Category 1 to be specifically identified so that the operator can easily tell that they are intended for use under accident conditions. This identification has been accomplished at Rancho Seco by displaying these variables on the SPDS CRTs which are intended for use under accident conditions. No additional identification of Category 1 variables has been provided within the SPDS displays.

P_agg_Ja,Section IV, 3 riable No. 19, _under.JE_UD Tau Nost Old:

See Table 5.2-2 in USAR Changed to:

See Tech spec Tabla 3,6-1 Added footnote to SMUD Cat. and Computer Display:

i

• • See Note 19 Reason for Change:

EASRTP review of the District's Reg. Guide 1.97 Position i revealed the necessity for clarifying the position with l regard to Variable No. 19. The raference to USAR Table 5.2-2 is not an accurate reference to the list of containment isolation valves displayed on the SPDS. The list of Category 1 variables on the SPDS was contained in the l

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. Attachmsnt I Pags 2 of 6 District's November 20, 1986, response to NRC request for information. The containment isolation valves in this list ,

are based on Technical Specification Table 3.6-1 which lists '

the containment isolation valves that must be operable to assure containment integrity during startup and operation. ,

only the automatically (SFAS) actuated va' ves in Table 3.6-1 '

were determined to fall within the definition of Type B variables in Reg. Guide 1.97.

The manually initiated containment isolation valves listed in Technical Specification Table 3.6-1 fall within the definition of Type D variables and are displayed in the Control Room via Class 1 back-lit push-buttons or other Class 1 displays.

Steam generator isolation valves are not includsd since the steam generators and secondary system piping are extensions of the containment liner. Integrated containment leakage testing verifies the integr ,y of the secondary side of the steam generators. Steam generator isolation valves do not receive SFAS closure signals and therefore, fall within the definition of Type D or E variables. Valve position is indicated in the Control Room via Class 2 back-lit push-buttons.

Pace 32, Note 19 Added:

Valve positions for automatically (SFAS) actuated containment isolation valves listed in Technical Specification Table 3.6-1 are displayed on the Class 1 SPDS in the Control Room. The SPDS displays also centain an '

alert for failure of safety features containment isolation valves to recpond to the SFAS command.

Reason for Change:

See Variable No. 19 above.

Additional information is provided with regard to the alert feature in SPDS for the SFAS actuated containment isolation valves.

Paces 6 & 6a, Added heading before sub-paragraph III.A.2.a.l.i.:

a) Rancho Seco Appendix R Program Safe Shutdown Circuits meet the following separation criteria except where specific exemptions have been granted by the NRC in letters dated May 19, 1986 and November 6, 1987.

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Attachm nt I

. Paga 3 of 6 Added sub-Paragraph III.A.2.a.1.b):

b) Non-Appendix R Circuits

1. For the Category 1 circuits in the NSEB that are not required for Appendix R safe shutdown capability, separation of cables and equipment comply with the criteria contained in Engineering Report ERPT-E0220 "Report on Conformanc3 of NSEB and DG Building Electrical Installation to Regulatory Guide 1.75." This report was reviewed and accepted in NUREG-1286, the NRC Staff Safety Evaluation Report relating to restart of Rancho Seco, isnued October 1987.

ii. For the Category 1 circuits in the Auxiliary Building that are not required for Appendix R safe shutdown capability, the separation of cableo and equipment comply with the original plant criteria contained in USAR Section 8.2.2.11.

Deleted from the end of paragraph III.A.2.a.2:

"--- or one of the criteria identified above:"

Deleted sub-paragraphs i and 11 under paragraph III.A.2.a.2.

Replaced with sub-paragraph III.A.2.a.2.a):

a) Rancho Seco Appendix R Program Safe Shutdown Circuits inside the Containment meet the separation criteria as stated in the exemptions granted by the NRC in a lettar dated Novocher 6, 1987.

Added sub-Paragraph III.A.2.a.2.b):

b) Non-Appendix R Circuits

1. For the Category 1 circuits in the Containment that are not required for Appendix R saio shutdown capability, the separation of cables and equipment comply with the original plant criteria contained in USAR Section 8.2.2.11.

Reason for Change:

The separation criteria originally provided for the NSEB, Auxiliary Building, and Containment are separation requirements for the Rancho Seco Appendix R program. This l

criteria applies to the safe shutdown circuits required for Appendix R that are also used to provide Reg. Guide 1.97 Category 1 information. At the time that the Reg. Guide 1.97 position was developed, all the Category 1 variables were thought to fall into the Appendix R safe shutdown list.

Evolution of both programs has r9sulted in a list of

. . Attach 3snt I Osgo 4 of 6 variable that is different for each program. Not all of the Category 1 variables are also Appendix R circuits, therefore, non-Appendix R circuits were not evaluated to the Rancho Seco Appendix R separation criteria.

In the NSEB, the non-Appendix R, Category 1 variables meet the separation requirements stated in ERPT-E0220, "Report on Conformance of NSEB and DG Building Electrical Installation to Regulatory Guide 1.75." submitted June 26, 1987 and revised December 8, 1987 and February 22, 1988. The initial report was evaluated and accepted in the NRC Safety Evaluation Report relating to restart of Rancho seco (NUREG-1286 issued October 1987).

In the Auxiliary Building (excluding the Computer / Control Room) and the Containment, all Class 1 circuits conform to the original plant separation criteria stated in USAR Section 8.2.2.11. Credit was taken for existing Class 1 instrumentation since Generic Letter 82-33 (Supplement 1 to NUREG-0737) allows the use of installed instrumentation to satisfy Reg. Guide 1.97 requirements. Therefore, non-Appendix R Category 1 circuits in these buildings were not reviewed against Appendix R separation criteria but do meet the or'ainal plant separation criteria stated in USAR Section 8.2.2.11.

In addition, various exemptions from Appendix R requirements have been granted since the development of the District's Reg. Guide 1.97 position. These exemptions are documented in letters from the NRC dated May 19, 1986 and November 6, 1907. Some of these exempt 1ons modify the separation criteria for Appendix R safe shutdown circuits in specific areas of the Auxiliary Building and containment. A general

, reference to the granted exemptions for these buildings has beon incorporated for clarity.

Pace 30, Variable 84 under SMUD Rangq Old:

Comply See Note 84 I changed to:

See Note 84 Reason for Change:

The ranges of the PASS analyses deviate from the recommended ranges but have been accepted by the NRC in NUREG-1286. See note 84 below for additional discussion.

. Attschm:nt I Paga 5 of 6 Pace 42, Note 84 Old:

While total dissolved gas content is measurable by the Post Accident Saupling System (PASS) no specific measurement of oxygen content is available on site. The reactor coolant PASS was designed per NUREG 0737,Section II.B.3 which does not require measurement of oxygen (accepted by the NRC in the letter dated 2/15/83, Stolz to Mattimoe). All other ranges meet or exceed those listed in Reg. Guide 1.97.

Add just before the last sentence:

The boron concentration upper limit is 3800 ppm by in-line analysis. Since the boron concentration under accident conditions is not expected to exceed 2000 ppm, the upper limit of 3800 ppm was accepted by the NRC (reference NUREG-1286 issued October 1987).

Reason for Change:

Update the District's Reg. Guide 1.97 position with respect to the PASS that is accepted by the NRC for compliance with Item II.B.3 of NUREG-0737.

Pace 15. Variable 5 under SMUD Tag Nos.

Old:

PT-20544 A,B Change to:

PT-20B46 A,B Pane 23. Var bfl.s 50 uDd91 SMUD Taa Nos.

Old:

PT-20544 A,B Change to:

PT-20546 A,B Reason for Change:

Correct the instrument tag numbers for Steam Generator Pressure.

Attachmsnt I Pags 6 of 6 Paaes 1, 43, and 44.

Change:

Deleted Section VI, "Detailed Implementation Schedule."

Reason for Change:

Update of the Reg. Guide 1.97 Implementation Status was provided by separate correspondence dated March 30, 1987.

Future updates of the implementation of the remaining Reg.

Guide 1.97 items w'211 be submitted separately.

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Attachment II to GCA 88-106 Regulatory Guide 1.97 position Revision 6 Corrected pages only

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6 B SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SEC0 GENERATING STATION UNIT NO. 1 REGULATORY GUIDE 1.97 POSITION REVISION 6 (CORRECTED PAGES ONLY)

MARCH 1988 4

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TABLE OF CONTENTS Page I. Overview and Organization 1  !

A. Introduction 1 B. Methodology 2 C. Report Structure 2 .

II. Instrument Systems Description 2

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A. SPDS 3 B. IDADS 3 ,

c. DRMS 4 -

1 III. General Position on Reg. Guide 1.97 Design {

and Qualification 5  !

A. Category 1 5 B. Category 2 11 C. Category 3 12 IV. Reg. Guide 1.97 Position Tabulation 14 l

Y. Tabulation Notes 31 VI. Deleted 43 1

i Rev. 6 l

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2. Redundancy

a. Separation Physical separation is provided as described below. Figure 1 is a block diagram illustrating the major physical components and circuits of the SPDS which the District oroposes for Category 1 variable display. The system is considered to consist of three separate portions for evaluation of separation:

- NSEB and Auxiliary Building (excluding the Computer / Control Room)

- The Containment ,

- The Computer / Control Room t

1. NSEB/ Auxiliary Building For the circuits in the Nuclear Service Electrical Building (HSEB) or Auxiliary Building (excluding the Computer / Control Room), separation shall comply with one of the following criteria:

a) Rancho Seco Appendix R Program Safe Shutdown Circuits meet the following separation criteria except where specific exemptions have been granted by the NRC in letters dated May 19, 1986 and November 6, 1987.

i. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 0-hour rating.

11. Separation of cables and equipment and associated '

non-safety circuits of redundant trains by a horizontal distance of more than 20 feet; or ,

iii. Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire  :

barrier having a 1-hour rating.

b) Non-Appendix R Circuits

i. For the Category 1 circuits in the NSEB that are not required for Appendix R se.fe shutdown capability, separation of cables and equipment comply with the criteria contained in Engineering Report ERPT-E0220 "Report on conformance of NSEB and DG Building Electrical Installation to Regulatory Guide 1.75."

This report was reviewed and accepted in NUREG-1286, the NRC Staff Safety Evaluation Report relating to restart of Rancho Seco, issued October 1987.

ii. For the Category 1 circuits in the Auxiliary Building that are not required for Appendix R safe shutdown capability, the separation of cables and equipment comply with the original plant criteria contained in USAR Section 8.2.2.11.

6 Rev. 6 1

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, _ _.. -,._.______._________._..__m__. _ , _

2 Containment Inside the containment, ',eparation will comply with one of the following criteria:

a) Rancho Seco Appendix R Program Safe Shutdown Circuits inside the containment meet the separation criteria as stated in the exemptions granted by the NRC in a letter dated November 7,1987.

b) Non-Appendix R Circuits

1. For the Category 1 circuits in the Containment that are not required for Appendix R safe shutdown capability, the separation of cables and equipment comply with the original plant criteria contained in USAR Section 8.2.2.11.

3. Computer / Control Room Reg. Guide 1.75 "Physical Independence of Electrical Systems" and IEEE standard 384-1974 "Separation of Class IE Equipment and Circuits" identify the criteria for review of Class IE circuits for "exposure to potential hazards such as high pressure piping, missiles, flammable material, flooding, and wiring that is not flame retardant".

6a Rev. 6

7. Range Where two or more instruments are needed to cover a particular range, overlapping of instrument span is provided. Where the required range of monitoring instrumentation results_in a significant loss of sensitivity in the normal operating range, separate instruments are used.

8. Equipment Identification The SPDS CRT's provide the primary display of Category I variables for use under accident conditions.

9. Interfaces Qualified instrument channels are electrically isolated from non-qualified portions of the instrument loop up to and including the isolation device.

10. Servicing, Testing, and Calibration Category 1 instrumentation is part of the planned maintenance program. Testing is performed on instrument strings on a regular basis. The testpoints for the instrument strings are under administrative control (technical specification, maintenance procedure, administrative procedure, or surveillance procedure) to prevent unannounced testing. The isolators for the instrument strings are accessible during and following a design basis event. Normal calibration of instrumentation located inside containment is on a refueling cycle basis.

11. Human Factors The Control Room Design Review process will include a Human Factors Evaluation of Category 1 variables. Human factors analysis recommendations will be part of the CRDR submittal.

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12. Direct Measurement Except where noted, monitoring instrumentation inputs are from sensors

, that directly measure the desired variables.

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10 Rev. 6

Var. Variable Per SMUD SMUD Computer NRC SMUD No. R.G. 1.97 Rev. 3 Tag Nos. Cat. Display Range Range- Comments ,

TYPE A VARIABLES 1 Hot Leg Water TE-21030 1 SPDS Plant 120-9200F Living Schedule Temperature TE-21033 IDADS Specific (Category 1) 2 RCS Pressure PT-21050 1 SPDS Plant 0-3000 (Category 1) PT-21051 IDADS Specific psig 3 Containment Sump LE-20509 A,B 1 SPDS Plant 0 to 10' Water Level LE-20510 A,0 IDADS Specific (Category 1) 4 Steam Generator LT-20507 A,8 1 SPDS Plant 6-619" Living Schedule Level LT-20508 A,B IDADS Specific (Category 1) 5 Steam Generator PT-20546 A,B 1 SPDS Plant 0-1200 Living Schedule. , l Pressure PT-20545 A,B IDADS Specific psig (Category 1) 15 Rev. 6

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Var. Variabic Per SMUD SMUD Computer NRC SMUD Mo. R.G. 1.97 Rev. 3 Tag Nos. Cat. Display Range Range ~ Comments ,

TYPE S VARIABLES cont'd 16 RCS Pressure PT-?1050 i SPDS 0-3000 psig Comply Same as Variable 2 (Category I) PT-21051 IDADS 1 17 Containment LE-26112C,0 2 SPDS Top to Bottom Comply See Variable 3 Sump Water Level IDADS Plant See Note.

(Category 2) Now LE-20509A,B 1 Specific 17 (Category 1) Wide LE-20510A,8 18 Containment PT-53621 1 SPDS 0-design Comply Pressure PT-53622 IDADS Pressure (Category 1) (59 psig) 19 Cont. Iso. Valve See Tech 1 SPDS Closed / Open/

Spec Table ** Not Closed Pos (excl. IDADS Closed Check Valves) 3.6-1 ** See Note (Category 1) 19 .

20 Containment PT-53621 1 SPDS -5 psig Comply Same as Yariable 18 Pressure PT-53622 IDADS to design (Category 1) pressure (59 psig) o* See Note 19 18 Rev. 6 e

w.a b- 4.4.e 6.-Ass *- 4 L 4- a- E 4 C sm J .h - --  % l ' :D G. 4 A Var. Variable Per SMUD SMUD Computer NRC SMUD No. R.G. 1.97 Rev. 3 Tag Nos. Cat. Display Range Range Comments .

TYPE D VARIABLES Cont'd.

45 Pressurizer MCC S2A2 2 IDADS Electric Comply Living Scheduele ,

Heater Status MCC S282 Current (Category 2) 46 Quench Tank LT-219CS 3 -

Top to 0-10 ft.

Level Bottom Upper Half (Category 3) (0-23'5") See Note 46 47 Quench Tank TE-21801 3 500 to 500F to Living Schedule Temperature 7500F 6000F See (Category 3) Note 47 48 Quench Tank PT-21920 3 0 to 0-200 psig Pressure design See (Category 3) pressure Note 48 (235 psig) 49 Steam Generator LT-20507 A,B 1 SPDS From tube 6-619" Living Schedule Level LT-20508 A,B IDADS Sheet to See Same as Variable 4 (Category 1) Separaters -Note 49 50 Steam Generator PT-20546 A,B 1 SPDS From ATM 0-1200 Living Schedule l Pressure PT-20545 A,B IDADS pressure to psig Same as Variable 5 (Category 2) 20% above See lowest Note 50 safety '

valve setting 51 Safety Relief XE-20533 N/A IDADS Closed / Open/Not.

Valve Position XE-20534 See Not Closed Open See (Category 2) XE-20544 Note Note 51 to 20559 51 4

XE-20571 A.B,C 1

XE-20562 A,8,0

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9 Var. Variable Per SMUD SftUD Computer NRC SMUD No. R.G. 1.97 Rev. 3 Tag Nos. Cat. Display Range Ringe Comments TYPE E VARIABLES Coat'd.

84 Primary Coolant PASS 3 10-6-10C1/ml; See See Variable 23 l and Sump Isotopic Note (Grab Sample) Analysis 84 (Category 3) B:0-6000 ppm; C1:0-20 ppm; H 2 :0-2000cc; 02:0-20 ppm; pH:1-13 pH 85 Containment PASS S H2:0-10% r emply See Variable 23 Air 02:0-30% ace (Grab Sample) Isotropic Note (Category 3) Analysis 85 30 Rev. 6

Variable Explanation 15 The Rancho Seco Reactor Coolant System subcooling margin monitor was designed and installed per NUREG 0578, 2.1.3.b (accepted by the NRC in the. letter dated 5/1/80, Reid to Mattimoe). The control room indication is a digital readout which has a range of 0 to 2000F of subcooling. Indication of superheat is not provided on the digital display because of potential confusion of superheat versus subcooled degrees by the operator. The emergency procedures which rely upon this variable only require indication of whether or not adequate subcooling margin is apparent.

Subcooling or superheat is also available graphically on the Safety Parameter Display System (SPDS) CRT based control room display.

17 The Narrow Range Reactor Building sump water level is monitored by a magnetic float with reed-switches and indicating lights in the control room for 1, 2, 3, 4, and 5 feet. These lights provide positive indication of rising water level in the sump, thus alerting the operator to an unusual condition.

< The wide range RB sump water level uses a magnetic float with reed i switches every 1/8 inch. These wide range indicators are Class 1 and were installed for NUREG 0737, Clarification II.F.1, Attachment 5 and are displayed on the SPDS and IDADS (accepted by the NRC in the letter dated 1/28/82, Stolz to Mattimoe).

19 The Rancho Seco Reactor Building (RB) Isolation System is presented in the USAR, Section 5.2.4. A listing of the valves involved in the RB isolation system is shown in Table 5.2-2 of the USAR. A schematic repre.,entation of the valve arrangements are shown in Figure 5.2-21 of the USAR.

The Rancho Seco RB isolatien system described in the USAR, addresses 10CFR50 Appendix A, Criterion 54, 55, 56, and 57.

Additionally, Reg. Guida 1.141, "Containment Isolation Provisions for Fluid Systems" and ANSI Standard N?71-1976 provide guidance on

various combinations and numbers of automated and manual valves.

Reg. Guide 1.141, C-2, requires no indication on sealed closed manual and remote valves.

l Yalve positions for automatically (SFAS) actuated containment isolation valves listed in Technical Specification Table 3.6-1 are

displayed on the Class 1 SPDS in the Control Room. The SPDS displays also contain an alert for failure of safety features i containment isolation valves to respond to the SFAS command.

Reg. Guide 1.97 suggests a range of closed /not closed. Except for the sealed closed manual and remote valves, Rencho Seco has indication of valve position in the fom of open/mid travel / closed, open/ closed, open/not open, or closed /not closed.

The indication in any presentation format satisfies the District's understanding of the Reg. Guide 1.97 position.

1 32 Rev. 6

Variable Explanation -

83 Atmospheric stability at Rancho Seco is derived from the differential temperature indicated between 33 and 200 feet.

The -10 to +100F temperature range covers the seven Pasquill stability classes versus Delta-T as derived from Proposed Revision 1 to Reg. Guide 1.23, Table 1. Expansion of the existing range would provide no additional useful infomation.

In addition to temperature differential, atmospheric stability can also be calculated for all seven classes using wind direction sigma. Therefore, the differential temperature range is adequate.

84 While total dissolved gas content is measurable by the Post Accident Sampling System (PASS) no speciffe measurement of oxygen content is available on site. The reactor coolant PASS was designed per NUREG 0737,Section II.B.3 which does not require measurement of oxygen (accepted by the NRC in the letter dated 2/15/83, Stolz to Mattimoe). The boron concentration upper limit is 3800 ppm by in-line analysis. Since the boron concentration under accident conditions is not expected to exceed 2000 ppm, the upper limit of 3800 ppm was accepted by the NRC (reference NUREG-1286 dated October 1987). All other ranges meet or exceed those listed in Reg. Guide 1.97.

85 The containment air Post Accident Sampling System (PASS) has full capability to measure hydrogen from 0 to 10 volume % and to do an isotopic analysis utilizing gama spectroscopy. No on-site measurement of oxygen content in the containment atmosphere is provided. Oxygen analysis is not required because no action would be taken as a consequence of this ineasurement. All other ranges meet or exceed those listed in i<eg. Guide 1.97. The reactor coolant PASS was designed per NUREG 0737,Section II.B.3 which does not require measurement of oxygen (accepted by the NRC in the letter dated 2/15/83, Stoltz to Mattimoe).

42 Rev. 6

VI Detailed Implementation Schedule Deleted l

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44 Rev. 6