ML20154A335
| ML20154A335 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/30/1985 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20154A340 | List: |
| References | |
| CON-FIN-A-6483, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, TAC-51362, NUDOCS 8603030379 | |
| Download: ML20154A335 (23) | |
Text
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- ENCLOSURE 9
CONFORMANCE TO REGULATORY GUIDE 1.97 TROJAN NUCLEAR PLANT e
J. W. Stoffel Published November 1985 EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington. 0.C. 20555 under DOE Contract No. DE-AC07-761001570 FIN No. A6483 I
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ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97 for the Trojan Nuclear Plant and identifies areas of nonconforma.nce 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.
a FOREWORD This report is supplied as part of the ' Program for Evaluating Licensee / Applicant Conformance to R.G. 1.97,* being conducted for the U.S. Nuclear Regula' tory Commission, Office of Nuclear Reactor Regulation, ,
Division of Systems Integration, by EG66 Idaho, Inc., NRR and I&E Support Branch. ' ,
> The U.S. Nuclear Regulatory Consission funded the work under authorization 20-19-10-11-3.
Oocket No. 50-344 TAC No. 51362 t
CONTENTS -
A8STRACT .............................................................. 11 FOREWORD .............................................................. 11 .
- 1. INTRODUCTION .............J....................................... 1
- 2. 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 ........................ 5
- 4. CONCLUSIONS ...................................................... 17
- 5. REFERENCES ....................................................... 19 e
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CONFORMANCE TO REGULATORY GUIDE 1.97 TROJAN NUCLEAR PLANT
- 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, appitcants for operating licenses and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency response capability. These requirements have been published as supplement No.1 to NUREG-0737, 'TMI Action Plan Requirements" (Reference 3).
Portland General Electric Company, the Itcensee for the Trojan Nuclear Plant, provided a response to the Regulatory Guide 1.97 portion of the generic letter in December 1984 (Reference 4). ,
This report provides an evaluation of that submittal.
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- 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 response facilities. The submittal should include documentation that .
provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97.
- 1. Instrument range ,
- 2. Env1ronmental qua11ficatton
- 3. Selsmic qualification
- 4. Quality assurance ,
. 5. Redundance and sensor location .
- 6. Power supply
- 7. Location of display
- 8. ScheduIe of Mstallation or upgrade .
Ftrthermore, the submittal should identify deviations from Regulatory Sulde 1.97 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 sebject. ,
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 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'=
sutwntttal based on the review policy desertbed in the NRC regional meetings.
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- 3. EVALUATION -
c The licensee provided a report addressing the Regulatory Guide 1.97 portion of NRC Generic Letter 82-33 in December 1984. This evaluation is ,,
based on that report.
3.1 Adherence to Reaula' tory Guide 1.17 i
The licensee stated that compliance with Regulatory Guide 1.97,
) Revisten 3 (Reference 5), is indicated in their accident monitoring -
l instrumentation review which sununartres each variable's compliance with the
! Regulatory Guide 1.97 previstons. That compliance revtow presents j tstification, modifications or ongoing evaluattens that are provided as l resolutions for any identified deviations. The licenses states in Appendix 7C of their report on conformance to Regulatory Guide 1.97 that'
) all upgrade modifications are scheduled for completion by the end of the 1987 refueling outage. Therefore, we conclude that the licensee has
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provided an esplicit commitment on conformance to Regulatory Guide 1.97.
! Exceptions to and deviattens from the regulatory guide are noted in j Section 3.3.
l 3.2 Tvne A Variables i
j Regulatory Guide 1.9 oes not specifically identify Type A variables, i 1.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.
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- 1. Reactor coolant system (RCS) hot leg water temperature
- 2. RCS cold leg water temperature ,
- 3. RCS pressure (wide range) ,
- 4. Core salt temperature 4
- 5. Containment pressure 1
- 6. Refueling water storage tank level 4
- 7. Pressurtzer level '
- 8. Steam generator level
- 9. Steam generator pressure
- 10. Condensate storage tank level -
This instrumentation meets Category I recommendations consistent with
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the requirements for Type A variables, except as noted in Section 3.3.
s 3'3 Excentions to Reaulatory Guide 1.97 The licensee identified deviations and exceptions fron Regulatory Guide 1.97. These are discussed in th's following paragraphs.
3.3.1 Neutron Flux ,
Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has committed to the installation of a new neutron flux channel that will meet Category I requirmoents; however, a fully qualtfled redundant channel w111 not exist. Category I requirements include full redundancy to satisfy the single failure criteria. The licensee states that one Category 1 channel is sufficient since control rod position and RCS soluble boron concentration can be used as diverse methods of monitoring this variable during all types of accidents.
I The licensee's justification for this deviation is unacceptable, since control rod position indication and RCS boron concentration are Category 3 variables. The licensee should modify their instrumentation, so that.the Category 1 instrumentation (neutron flux) will satisfy the single failure criteria.
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3.3.2 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends Category 3 instrumentation, with a range of 0 to 6000 ppe, for this variable. The licensee does not provide a ,
separate instrument for this variable. To conform to the regulatory guide, i i
the licensee is taking credit for the post-accident sampling system for .,
this variable.
I The licensee takes exception to Regulatory Guide 1.97 with respect to post-accident sampling capability. This exception goes beyond the scope of this review and is being addressed by the NRC as pa'rt.of their review of NUREG-0737. Item II.B.3.
3.3.3 Core init Temnerature Regulatory Guide 1.97 recommends Category 1 instrumentation with a range of 200*F to 2300'f.. The licensee has provided a continuous display ,
of 0 to 700'f. The monitoring system is not environmentally or seismically qualtfled and the power source is non-Class it.
The NRC is reviewing the acceptability of this variable as part of their review of NURE'-0737,G Item II.F.2.
3.3.4 Containment Isolation Valve 70sition Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The 11censee identified the following areas in which they deviate from the Category 1 criteria Recording has not been provided.
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- 2. Redundancy of indication generally has been. net on a per line -
basis rather than on a per valve basis. ,
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- 3. Indication is not continuous for certain valves that are required -
to be de-energized with power removed to ensure that the correct position is maintained.
4 Indication is not provided for manually operated valves, safety relief valves, or check valves used as containment isolation valves.
From the information provided, we find that the licensee deviates from a strict interpretatten of the Category 1 criteria. We view recording of the, position of these valves as unnecessary. Only the active valves have position indication (i.e., check valves have no position indication).
Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory gulde. Loss of indication due to the removal of power from the valve control circuit is t acceptable. Position indication of check valves is specifically escluded
.. by Table 3 of Regulatory Guide 1.97. Therefore, we find that the instrumentation provided for this variable is a,cceptable. .
l 3.3.5 Radioactivity Concentration or Radiation Level in Circulatina
- primary Coolant The 11censee has a gross failed-fuel monitor that continuously measures the concentration of gansna emitting fission products in the primary coolant during normal operation. Post-accident, this monitor is isolated and the post-accident sampling system, which is being reviewed by the NRC as part of their review of 40 REG-0737, Item !!.B.3, is used to l
verify fuel t,1 adding integrity.
l taned on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate p and, therefore, acceptable, , , , . . . . . . ,
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3.3.6 ggndenser Air Removal Exhaust-Noble Gases .
Containment Effluent Radioactivity-Noble Gases Effluent Radioactivity-Noble Gases The licensee has not provided the information required by Section 6.2 of NUREG-0737, Supplement No. I for these variables. Therefore, we are .,
unable to conclude that the instrumentation provided for these variables is acceptable.
The licensee should provide the required information, identify any deviations from Regulatory Guide 1.g7, and provide supporting justification er alternatives for those deviations.
3.3.7 Residual Heat Removal (RNA) Heat tachanner Outlet Temnerature Regulatory Guide 1.g7 recommends a range for this variable of 40 to ;
350'F. The licensee has supplied a range of 50 to 400*F. The ,
1:strumentatten supplied has a range where the lower limit of the range does not conform to the regulatory guide.
The licensee states that operators are req'utred by written procedu,res to maintain the reactor coolant temperature above 100*F when using the RNR system. In addition, the minimum temperature that the reactor vessel may be at with the head bolts tensioned is 60'F. Finally, the licensee states that all Updated Final Safety Analysis Report, Chapter 15, condition !!!
and IV, accidents will cause the RHR outlet temperature to rise, showing that the temperature range is adequate.
Sased en the justification provided by the licensee, we conclude that the existing range is adequate to monitor the RHR system operation. ,
3.3.8 Ace --1ater Tank Level and pressult ,
Regulatory Suide 1.g7 recommends Category 2 Instrumentation for this variable. The licensee takes exception to the recommended pressure range 8
,(0 to 750 psig) and level range (10 to 90 percent volume). The level instrumentation, except for environmental qualification, is Category 2.
The Itcensee has supplied pressure instrumentation with a range of 0 to 700 psig. The licensee states that the operators are required by the
, plant technical specificattuns to manually control the accumulator pressure between 600 and 673 psig. Tank design pressure is 700 psig and relief valves limit the pressure to this value.
The licensee has supplied level instrumentation with a range of 53 to 70.9 percent volume. The licensee states that level indication is useful during normal operation to ensure that adequate water is available for injection. Operators are required by technical spectftcations to manually control each accumulator level between 64 and 69 percent volume.
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e The accumulator pressure .is the key variable used to determine the status of the accumulators. The accumulators are passive devices. Their -
- discharge into the reactor coolant system (RCS) is , actuated solely by a decrease in the RCS pressure. We find that the instrumentation supplied for this variable is adequate to determine that the accumulators have
- -discharged. Therefore, the instrumentation provided for.this variable is ,
acceptable.
F s.2 3.3.9 Re/$elinoWaterStoraceTanklevel Regulatory Guide 1.97 recommends a range from the top to the bottom of the tank. The licensee does not meet this range and states that the entsting range is adequate. The usable volume of the tank is from a point 37 feet 1 inch (in the overflow line) to 2 fett 4 inches (the tank outlet). The installed instrument taps are at a point 37 feet 7 inches (in the overflow line) to 2 feet 4 inches from the tank bottom. This span .
. covers more than the usable volume of the tank.
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Based on the justification provided by the licensee. we find the-instrumentation for this variable adequate to monitor the level of this ta:k.
3.3.10 Pressurifer level Regulatory Guide 1.97 recommends a range from the bottom to the top for this variable. The instrumentation provided by the licensee does not read this full range.* The licensee states that the voli.me measured represents approximately 92 percent of the pressuriser volume and that this is sufficient for'the operator to take the required manual actions and to ensure the proper operation of the pressurizer.
The volume of the pressuriser where level is not indicated (approximately 8 percent volume) 15 the upper and lower hemispherical head region', where the volume to level ratio is not linear. We find this ,
deviation minor and acceptable. The existing range is adequate to monitor .
.this variable during all accident and post-accident.cenditions.
3.3.11 QuenchTankLevel The range of the existing instrumentation for this variable does not meet the range recommended by Regulatory Guide 1.97 (top to bottom). The 4(l'censee's instrumentation covers a range of approximately 6 to 94 percent level. The licensee states that this meets the intent of the regulatory guide. ,
We find this deviation to be minor. The existing level range is adequate to monitor the operation of this tank during accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97. ,
3.3.12 Quench Tank Temocrature ,
Regulatory Guide 1.97 reconnendt a temperature range of 50 to 750*F for this variable. The licensee's instrumentation has a range of 0 10
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5 to 300'F. The licensee considers this to be adequate. The tank pressure is limited to 100 psig by rupture disks. If saturation conditions exist at the design pressure, the maximum temperature would be about 338'F. The licensee states that, per the design basis of this relief tank as described s in the plant Final Safety Analysis Report (FSAR), the maximum expected (
r temperature for the design discharge is only 200*F. Furthermore, quench i tank temperature is considered by the l'icensee to be a backup variable to
< tank level and pressure. ;
We agr u with the justification provided by the Itcensee for not , l tacreasing the range to 750*F. However, the existing range should be l adequate to read the saturation temperature for the tank design pressure and rupture disk release pressure. The licensee should expand the existing instrumentation to cover a range of 50 to 338'F.
t 3.3.13 Steam Generator Level l L
- . Regulatory Guide 1.g7 recensends Category ) instrumentation with a ,
range from the tube sheet to the separators for this variable. The l
. licensee has instrumentation that reads from 14 inches above the tube sheet to the separa, tors, but this instrumentation is not Category 1. The j
, licensee states that the wide range instrumentation will be epgraded to l Category I requirements and that the existing level range is adequate. l The steam generator is,- in qffect, empty at 14 inches above the tube sheet; therefore, this deviation is minor with respect to the overall range and system accuracy. The entsting range is adequate to monitor this ;
variable during all accident and post-accident conditions. The Itcensee !
l has committed to upgrade the wide range instrumentation to Cattgery 1. ;
, 3.3.14 Steam Generator Pressure i
, Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from atmospheric pressure to 20 percent above the lowest safety valve ;
setting (1125 pstg) for this variable. That means the upper range on this l Indicator should read 1350 psig. The Itcensee has provided Category 1 f i
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1 l instrumentation with a range of 0 to 1200 pstg (107 percent above the '
lowest safety valve setting), and an unqua11fted instrument with an j
.: acceptable range of 0 to 1500 psig. The Itcensee considers the entsting .
! range adequate for post-accident monitoring of this variable. -
1 i tie conclude that the existing instrumentation for this variable is ., j
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l tnacceptable, since 4 of the 5 safety valves are set to relieve at l 1200 psig or greater and no credtt can be taken for the high range j 4
instrumentation in a post-accident situation. The licensee should expand j the range of the Category 1 instrumentation er qualify the instrumentation j
{ t:ith the O to 1500 pstg range to Category 1. !
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r i 3.3.15 Condensate Storaes Tank (CST) j I
The licensee has not provided instrumentation for this variable that l meets the Category 1 seismic qualtftcation requirements. The licensee .
states that the CST ttself 1s not seismically qualtfled, therefore, the ,
3 cseismic qualificatten of the level instrumentation y111 not be upgraded.
1 i The licensee's justification is not acceptable. Regulatory Guide 1.97 (
recommends seismic qualtftcation for all Category 1 instrumentation. In j
- additten, the licensee has designated this variable as Type A, which is a !
l variable required to permit the control room operator to take manually (
controlled safety actions. The Itcensee should provide the recommended setssic qualtftcations for this vertable in accordance with the plant's
! seismic design criteria. ;
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3.3.16 Cantainment Sarav flow ;
l I l l Regulatory Sulde 1.97 reconmends Category 2 Instrumentation with a , l
{ range of 0 to 110 percent of design flow for this variable. The Itcensee ,
l l has not provided a direct measurement of containment spray flow. Instead. .
j they use qualtfled pressure transmitters en the discharge line of each pump ,
f j to indicate proper operatten of the spray system. In addition, j l apprestostely 5 percent of each containment spray pump discnarge is
! bypassed through a spray additive eductor, where it is used as the motivu k l I j 1 l 12 1
flow to draw sodium hydroxide solution from the sodium hydroxide tank. The normal operation of the containment spray system can be inferred from the decreasing level of this tank.
The alternate instrumentation provided by the licensee sourds 11ke a
> reasonable approach; however, the licensee should provide the NRC with the relationship between the pump discharge pressure and the pump flow rate as a basis for this deviation.
3.3.17 Containment Atmosehere Tomoerature Regulatory Guide 1.97 recommends a range of 40 to 400*F for this variable. The licensee has existing instrumentation with a range of 0
'te 300*F. The Itcensee justiftes this exception by stating that the design basis accident maximum containment temperature is 288'f, which is
- < consistent with the existing range.
a i Since the worst case postulated accident w111 not increase the ,
containment atmosphere above 288'f, we find the range of 0 to 300*F adequate to monitor this variable during all accident and post-accident conditions. -
1.3.18 Containment Sumo Water Temoerature a
The licensee does not have.this instrumentation and states that this parameter is unnecessary and would not provide useful indication if available. The accomplishment of containment cooling can be directly evaluated by monitoring of containment atmosphere temperature indication.
The licensee has determined that the residual heat removal (RHR) pumps and the containment spray pumps that take suction from the sump, are capable of operation under all expected temperature conditions. The licensee also
- monitors the discharge temperature of each RNA pump and the residual heat
, removal heat enchanger evtlet temperature. These temperatures would be indicative of the sump water temperature ence recirculation of the sump
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Based on the licensee's justificatten and this alternate .
1:strumentation, we conclude that this deviation is acceptable.
i 3.3.19 Volume Control Tank Level ..
l The licensee takes exception to the range recomended by Regulatory .,
Guide 1.97 for this variable (top to bottom). The transmitters measure the l
full range between the instrument taps and display 0 to 100 percent level; l however, these taps are not at the top and bottom of the tank. The span of the taps are about 70 inches or 18 to 82 percent volume. The licensee considers this range adequate to monitor the operation of the volume control tank. Also, the existing range of the volume control tank level envelops all automatic actions of the level control system.
l We find that the existing level indication is adequate to monitor the l operation of this tank. Therefore, this is an acceptable deviation from Regulatory Guide 1.97. ,
l 3.3.20 C - enent Cooline Water (CCW) Flow to tnaineered Safety Features (ESF1 System Components Regulatory Guide 1.97 recc mends Catego*y 2 instrume.tattor, with a range of 0 to 110 percent design flow for this variable. The licensee has not provided this instrumentation. The licensee does not consider this '** ,;-
instrumentation necessary based on the fallowing plant-specific design !
features.
- 1. The CCW system is os,erating during normal operations with one CCW pump and heat exchanger in continuous operation. The other train j is in a standby condition. Annunciation in the control room ,
indicates a low flow condition. ,
- 2. CCW pump and heat onchanger performance is' indicated by means of ,;
pressure transmitters and resistance temperature detectori (RTO's) for each train in the main control room. Vertf1 cation of i
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. i flow in each CCW pump discharge line is also confirmed by ;
comparing CCW heat exchanger inlet and outlet temperatures .in the ,
i main control room. l
- 3. Local flow indicators are installed in the CCW lines going to
> components in containment and to the RHR heat exchangers. l
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, The alternate instrumentation provided by the Itcensee will adequately menttor flow to the ESF components. However, we are unable to determine from the Itcensee's submittal that the alternate instrumentation is ;
Category 2. The Itcensee should werify that this alternate instrumentatten f meets the Category 2 requiroments. !
3.3.21 Nish Level Radioactive Lieutd Tank Level i Regulatory Sulde 1.97 reconnends a range of top to bottom for this E
> ; variable. The transmitters for these tanks measure the full range between [
the instrument taps and the indication is 0 te ,100 percent; however, the ,l lower tap is not at the betten of the tank. The actual range monttered is l
. 13.6 to 100 percent level. The licensee states that the esisting range I
-' meets the intent of confirming storage capacity. Upper level indicatten is f considered more significant than the lower level and the entsting range I does entend to the le g .
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%V, Q' I We find that the entsting range is adequate to monttor the operation ;
of this tank during all accident and post-accident condittens. Therefore, ,
l this is an acceptable deviation from Regulatory Guide 1.97. i 3.3.22 behle Gases and Vent Flow Rate !
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The Itcensee has not provided the information regelred by Section 6.2 ;
- of NURt4-0737, Supplement No. I for the seven lecettens under this I heading. Therefore,weareunabletoconcludet$attheinstrumentation provided for these variables is acceptable. (
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The licensee should provide the required information. Identify any deviations from Regulatory Guide 1.97. and provide supporting justification or alternatives for those deviations.
3.3.23 particulates and Malocens The licensee has not provided the information required by Section 6.2 of NUREG-0737. Supplement No. 1 for this yartable. Therefore. we are unable to conclude that the instrumentation provided for this variable is acceptable. ,
The licensee should provide the required information, identify any deviations from Regulatory Guide 1.97, and provide supporting justification or alternatives for those deviations.
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-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: .
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- 1. Neutro.1 flux--the licensee should install a redundant channel of Category 1 instrumentation for this variable (Section 3.3.1). ;
2., Condenser air removal exhaust-not:1e gas--the licensee should l provide the information required by Section 6.2 of NUREG-0737 l Supplement No. 1 for this variable and identify and justify any l' deviations (Section 3.3.6).
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- 3. Containment effluent radioactivity-noble gas--the licensee should i provide the information requir'ee by Section 6.2 of NOREG-0737
) Supplement No. 1 for this variable and identify and justify any deviattens (Section 3.3.6). -
- 4. Effluent radioactivity-noble gas--the licensee should provide the l Information required by Section 6.2 of NUREG-0737.. Supplement l No. I for this variable and identify and justify any deviations l (Section 3.3.6). l l
- 5. Quench tank temperature.-since the tank design pressure and !
rupture disk release pressure is 100 psig Instrumentation with a range up te and including 338*f should be previded (Seetton 3.3.12). l t
- 6. Steam generator level--the licensee should upgrade the wide range instrumentation to Category I requirements (Section 3.3.13).
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- 7. Steam generator pressure.-the 11censee'should either upgrade the esisting 0 to 1500 psig instrumentation to meet Category 1 requirements er espond the range of the Category 1 ,
instrumentation (Section 3.3.14).
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- 8. Condensate storage tank--the licensee should provide seismically qualified instrumentation for this Type A variable (Section 3.3.15).
- 9. Containfrant spray flow--the licensee should provide additional information for the alternate irstrumentation for this variable .,
(Section 3.3.16).
- 10. Component cooling water flow to engineered safety feature system components--the licensee should verify that the alternate instrumentation is Category 2 (Section 3.3.20).
- 11. Nable gases and vent flow rates--the licensee should provide the information required by Section 6.2 of NUREG-0737. Supplement No. 1 for these variables and identify and justify any deviations (Section 3.3.22).
- 12. Particulates and halogens--the licensee should provide the information required by Section 6.2 of NUREG-0737, Supplement No. I for this variable and identify and justify any deviations (Section 3.3.23).
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- 5. REFERENCES ,,
- 1. NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits, " Supplement No. 1 to NUREG-0737--Requirements 'or Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
2 2. Instrumentation for licht-Water-Cooled Nuclear Power P13nts to Assess Plant and Environs Conditions Durina and Followina an Accuej.,
Regulatory Guide 1.97 Revision 2. NRC, Office of Standar,.
Development, December 1980.
- 3. Clarificatio'n of TMI Action Plan Reauirements. Reaviremento for Emeroency Response Canabi' ity, NUREG-0737 Supplement No. . NRC, Office of Nuclear Reactor Regulation, January 1983.
- 4. Accident Monitorina In1trumentation Review for the Trojan Nuclear El10.1, Portland Genera Electric Company, December 1984. PGE 1043.
- 5. Instrumentation for Liaht-Water-cooled Nuc1mr Power Plants to Assess Plant and Environs Conditions Durina and Fo' Lowina an Accident,
) Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
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Conformance to Regulatory Guide 1.97. T.rojan Nuclear Plant . .... - , - .... ,.
November 1985 J. W. Stoffel a
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EGSG Idaho, Inc. a==='==
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Division of Systems Integration Preliminary Technical Office of Nuclear Reactor 9egulation Evaluation Reco d U.S. Nuclear Regulatory Commission Washinoton. DC 20555
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This EGtG Idaho, Inc. report reviews the submittal for the Trojan Nuclear Plant 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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