ML20155G020
| ML20155G020 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 05/31/1986 |
| From: | Stoffel J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20155F979 | List: |
| References | |
| CON-FIN-A-6493, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7067, NUDOCS 8806170141 | |
| Download: ML20155G020 (13) | |
Text
e EGG-NTA-7067 4
May 1986 INFORMAL REPORT
/daho c0NFORMANCE TO REGULATORY GUIDE 1.97, WASHINGTON PUBLIC POWER SUPPLY SYSTEM, National NUCLEAR PROJECT NO. 1 Engineering Laboratory Afanaged by the U.S.
. J. W. Stoffel j
Depanment ofEnergy
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Prepared for the U. S. NUCLEAR REGULATORY COMMISSION Wort performed uncler DOE Contract No. DE AC07 76/D01S?0 8806170141 880601 PDR ADOCK 05000460 P
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e OfSCLAIMER The book was preoered as en account of work sponsored by en egency of the Urvted States Gowmment. Nether the Uruted States Gowrnment nor any agency thereof, nor any of ther emo6oyees, rnates any worrenty, express or vnplied, or eseumes any logel hedhty or resoorebety for the accuracy, compoeteness, or usefulness of any enformeDon, spooretus, product or process doscsooed, or represents that rts use would not entnnge Drivately owned nghts. References heren to any tocofic RT ieM
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product, process, or sorwee by trece name, trademort, manufacturer, or otherwise, does not necessenN constitute or vnpiy its endorsement, iKcT.Te.decon, or favonng by the Urwted States Gowrnrnent or any agency thereof. The wows and opinions of authors expressed herein do not tw aunty sute or reflect those of the Urvted States Governtnent or any agency thereof.
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CONFORMANCE TO REGULATORY GUIDE 1.97 WASHINGTON PUBLIC POWER SUPPLY SYSTEM, NUCLEAR PROJECT NO. 1 J. W. Stoffel Published May 1986 EG&G Idaho, Inc.
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Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under 00E Contract No. DE-AC07-76ID01570 FIN No. A6493 4
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ABSTRACT This EG&G Idaho, Inc.,, report reviews the submittals for Regulatory Guide 1.97, Revision 3, for the Washington Public Power Supply System, Nuclear Project No. 1 and identifies areas of nonconformance to the regulatory guide. Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
4 Docket No. 50-460 11 0
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FOREWORD 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 Comission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc., NRR and I&E Support Branch.
The U.S. Nuclear Regulatory Comission funded the work under authorization B&R 20-19-40-41-3.
Docket No. 50-460 iii i
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CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
iii 1.
INTRODUCTION.....................................................
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........................
S 4.
CONCLUSIONS......................................................
12 5.
REFERENCES.......................................................
13 iv
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l CONFORMANCE TO REGULATORY GUIDE 1.97 WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO. 1 1
1 1.
INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and holders of construction permits.
This letter included additional clarification regarding Regulatory Guide 1.97, Revision 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).
The Washington Public Power Supply System, the applicant for Nuclear Project No. 1, provided a response to the Regulatory Guide 1.97 portion of the generic letter on April 15, 1983 (Reference 4). Additional information was provided on February 6, 1986 (Reference 5).
Reference 5 addresses conformance to Revision 3, of Regulatory Guide 1.97 (Reference 6).
This report provides an evaluation of these submittals, l
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1 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 applicant complies with Regulatory Guide 1.97 as applied to emergency response facilities.
The submittal should include documentation that provide: 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
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4.
Quality assurance 5.
Redundance and sensor location 6.
Power supply l
7.
Location of display i
8.
Schedule of installation or upgrade i
The submittal should identify deviations from the regulatory guide and provide supporting justification or alternatives.
Subsequent to the issuance of the generic letter, the NRC held
)
regional meetings in February and March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on this subject.
At these meetings, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97.
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, a
2
I this report only addresses exceptions to Regulatory G'.,ide 1.97.
The following evaluation is an audit of the applicant's submittal based on the review policy described in the NRC regional meetingt.
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3.
EVALUATION The applicant provided a report addressing the Regulatory Guide 1.97 portion of NRC Generic Letter 82-33 on April 15, 1983.
Additional information was provided on February 6, 1986.
This evaluation is based on those submittals.
3.1 Adherence to Reoulatory Guide 1.97 The applicant states that their instrumentation does not provide full compliance with Regulatory Guide 1.97.
The applicant plans to provide full coicolianc e.
Table 7.5-4 was included in the submittal to litt the parameters applicable to th'is unit.
When the design details are completed, the table will be modified by the applicant to provide the supporting information. Therefore, we conclude that the applicant has provided an explicit commitment on conformance to Regulatory Guide 1.97.
Exceptions to and Jeviations from the regulatory guide are noted in Section 3.3.
3.2 Type A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide the information required to permit the control room operator to take specific manually controlled safety actions.
The applicant classifies the following instrumentation as Type A.
1.
Borated water storage tank level 2.
High pressure injection flow 3.
Reactor coolant system (RCS) hot leg water temperature 4.
RCS pressure 5.
Steam pressure 4
6.
Steam generator level 7.
Pressurizer level 8.
Demineralized water storage tank level This instrumentation meets the Category 1 recommendations consisteat with the requirements for Type A variables, except as noted in Section 3.3 3.3 Exceptions to Reaulatory Guide 1.97 l
The applicant identified the following deviations and exceptions from RegLlatory Guide 1.97.
The~se are discussed in the following paragraphs.
1 3.3.1 Information Provided in Reference 5 1
Listed below are instruments from Table 7.5-4 of the applicant's submittal (Reference 4), where the applicant stated that the indicator range and design category would be provided later. Additional information was provided by Reference 5.
This information is evaluated below.
1.
Steamline radiation--the applicant deleted this as a Type A variaole, Reference 5 lists it as a Type E variable that meets the recommendations of Regulatory Guide 1.97.
2.
Neutron flux--in Reference 5, the applicant states that this instrumentation is Category 1 and meets the range recommendations of Regulatory Guide 1.97.
3.
Coolant level in reactor--in Reference 5, the applicant states that this instrumentation is Category 1 and meets the range recommendation of Regulatory Guide 1.97.
4.
Radioactivity concentration or radiation level in circulating primary coolan'.--In FSAR fable 7.5-4, note 4, the applicant states that cross failed fuel detectors are located in the j
5 i
letdown line.
This is used to provide indication of fuel failure during normal operations, however, the letdown line is isolated for serious accidents requiring containment isolation.
For post-accident monitoring, the applicant uses the post-accident sampling system, which is being reviewed by the NRC as part of l
their reivew of NUREG-0737 Item II.8-3, to monitor this variable.
Based on the alterr. ate instrumentation provided by the applicant, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.
5.
pressurizer heater status--in Reference 5, the applicant states that the range of'the instrumentation is 0-220 amperes.
This is acceptable; however, the category of the instrumentation is not provided. The applicant should provide Category 2 l
instrumentation for this variable.
l 6.
Quench tank temperature--In FSAR Table 7.5-4, note 8, as provided in Reference 5, the applicant states that the range of this instrument is 50 to 400'F.
Regu'4 tory Guide 1.97 recommends a range of 50 to 750'F for this variable.
The licensee states that the design temperature of the tank is 340'F and the design pressure is 100 psig.
The range covers thre anticipated requirements for normal operation, anticipated operational occurrences and accident conditions.
The pressure relief limits the temperature of the tank contents to saturated conditions under 400*F. Thus, we find this deviation acceptable.
7.
Emargsacy ventilation damper position--ell information concerning this variable remains to be provided.
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8.
Status of standby power and other energy sources important to safety--Reference 5 states that this variable conforms to the guidance of Regulatory Guide 1.97, 9.
Vent from steam generator safety relief valves or atmospheric dump valves--Reference 5 states that this variable conforms to the guidance of Regulatory Guide 1.97.
10.
Radiation exposure meters--Regulatory Guide 1.97, Revision 3 deletes this variable. Since the applicant is addressing Revision 3 of the regulatory guide this variable is not aop11 cable.
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- 11. Airborne radiohalogens and particulates--Reference 5 states that i
this variable conforms to the guidance of Regulatory Guide 1.97.
12.
Plant and environs radiation--Reference 5 states that this variable conforms to the guidance of Regulatory Guide 1.97.
13.
Plant and environs radioactivity--Reference 5 states that this variable conforms to the guidarca of Regulatory Guide 1.97.
The applicant provided the necessary information in Reference 5 for all of these variables except pressurizer heater status and emergency ventilation damper position.
The applicant should provide the recommended instrumentation and the information for these two variables.
i 3.3.2 Radiation Monitorina Instrumentation i
The applicant, in Reference 4, took exception to the design category (Category 2) recommended by Regulatory Guide 1.97 for two Type C and four Type E radiation monitoring instruments.
In Reference 4, the applicant identified instrumentation that, except for environmental qualification, meets this recommendation.
They are:
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Radiation exposure rate (Type C)--this variable is excluded as a Type C in Regulatory Guide 1.97, Revision 3.
Since the applicant is addressing Revision 3, this variable is not applicable.
2.
Effluent radioactivity-noble gases (Type C)--Reference 5 states that this variable is monitored by the common plant vent instrumentation at this station.
Therefore, it is acceptable.
3.
Radiation exposurr rato (Type E)--Regulatory Guide 1.97, Revision 3, recommead Category 3 instrumentation for this variable. The applicant has complied.
4.
Condenser air renioval system exhaust (Type E)--conformance for this variable remains to be provided.
5.
Common plant vent (Type E)--Reference 5 states that the effluent gaseous monitor provided by the applicant for this variable conforms to the guidance of Regulatory Guide 1.97.
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6.
All other identified release points (Type E)--conformance for this variable remains to be provided..
The applicant resolved the environmental qualification exception for i
these variables in Reference 5, with the exception of condenser air removal f
t system exhaust and gland steam exhaust.
The applicant states that these two exceptions will be addressed later.
3.3.3 Accumulator Tank Level and Pressure t
The range of the level instrumentation is not as recomended by Regulatory Guide 1.97 (10 to 90 percent volume).
The provided level i
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instrumentation covers a range of 0 to 80 percent of tank volume.
The pressure instrumentation meets the recommendations of the regulatory guide.
The accumulators are passive devices.
Their discharge into the reactor coolant system (RCS) is actuated solely by a decrease in RCS pressure. We find the instrumentation supplied for this variable adequate to determine that the accumulators have discharged.
Therefore, this instrumentation is acceptable.
3.3.4 Main Feedwater Flow The range of this instrumentation is not as recommended by Regulatory Guide 1.97 (0 to 110 percent of design flow).
The provided instrumentation covers a range of 0 to 9 x 10 lb/hr which is 0 to 109 percent of design flow.
Considering instrumentation accuracy and scaling factors, we find that this deviation is minor and, therefore, acceptable.
3.3.5 Heat Removal by the Containment Fan Heat Removal System No instrumentation is listed on Table 7.5-4 of Reference 4 for this variable.
In Reference 5 the applicant states that containment heat removal for loss of coolant and main steam line break accidents is by the j
operation of the containment spray and decay heat removal systems.
The applicant refers to Section 6.2.2 of the FSAR, which establishes that adequate heat removal is provided without reliance on the containment fan heat removal system.
The design at Nuclear Project No. 1 does not include the containment fan heat removal system in their accident analysis.
Thus, this variable is not applicable at this station.
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3.3.6 Makeup Flow-In Regulatory Guide 1.97 reconnends Categcry 2 instrumentation for this
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variable. As such, it should be environmentally qualified.
The applicant's instrumentation is not environmentally qualified.
The applicant justifies this deviation, stating that this variable is not required for the mitigation of an accident, and during design basis events the make-up system is isolated.
As this variable is not utilized in conjunction with a safety system, we find that the instrumentation provided is acceptable.
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3.3.7 Letdown Flow-Out Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. As such, it should be environmentally qualified. The applicant has provided instrumentation that is not environmentally qualified.
The applicant justifies this deviation, in Reference 5, by stating that this variable is not required for the mitigation of an accident, and that during l
design basis events, the letoown line is isolated.
As this variable is not utilized in conjunction with a safety system, we find that he instrumentation provided is acceptable.
3.3.8 Volume Control Tank Level 1
Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from the top to the bottom of this tank. As such, it should be environmentally qualified. The applicant has supplied instrumentation which monitors tank level from the top to the bottom of the cylindrical section of the tank, approximately 80 percent of the tank volume.
This range is considered adequate by the applicant.
This range does not cover the hemispherical tank ends where the volume to level ratio is not linear.
Where this ratio is linear, it is monitored.
Therefore, this range is an acceptable deviation from Regulatory Guide 1.97.
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i The applicant has stated that the volume control tank level i
instrumentation is not environmentally qualified.
The applicaret justifies this deviation in Reference 5, by stating that this variable is not l
required for the mitigation of an accident, and that during design basis
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events the tank outlet is isolated.
As this variable is not utilized in conjunction with a safety system we fino that the instrumentation provided is acceptable, j
3.3.9 Component Coolina Water Flow to Encineered Safety Features (ESF)
System i
The range of this instrumentation is not as reconsnended by Regulatory Guide 1.97 (0 to 110 percent of design flow).
The provided instrumentatioa
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covers a range of 0 to 107 percent of design flow.
I Considering instrumentation accuracy and scaling factors, we find that j
this deviation is minor and, therefore, acceptable.
3.3.10 Radiation Exoosure Rate The applicant takes exception to the range recommended by Regulatory j
Guide 1.97 (10 to 10 R/hr).
The provided instrumentation covers a f
range from 10' to 10 R/hr.
Portable instrumentation supplements l
this fixed location instrumentation.
The applicant's justification for this deviation is that should the radiation levels reach or exceed the j
upper limit of the range, personnel would be denied access to those areas i
except for life saving, From a radiological standpoint, if the radiation levels react or i
exceed the upper limit of the range, personnel would not be permitted into the areas without portable monitoring, except for life saving.
Based on j
the supplemental portable instrumentation used by the applicant for this variable, we find the proposed range for the radiation exposure rate monitors acceptable.
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CONCLUSIONS Based on our review, we find that the applicant either conforms to or is justified in deviating from Regulatory Guide 1.97, with the following f
exceptions:
I 1.
Information te be provided later--the applicant should provide the recommended instrumentation for the variables pressurizer heater status, and emergency ventilation damper position (Section 3.3.1).
2.
Radiation monitoring instrumentation--environmental qualification
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should be addressed in accordance with 10 CFR 50.49 for the variables condenser air removal system exhaust and gland steam i
exhaust (Section 3.3.2).
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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 for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
2.
Instrumentation for Liaht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Reauirements. Reauirements for Emeraency Response Capability, NUREG-0737, Supplement No.1
- NRC, Office of Nuclear Reactor Regulation, January 1983.
4.
Washington Public Power Supply System letter, G. D. Bouchey to Director of Nuclear Reactor Regulation, NRC, ' Nuclear Project No. 1, Response to NUREG-0737, Supplement No. 1," April 15, 1983, G01-83-0149.
5.
Washington Public Power Supply System letter, G. C. Sorensen to Director of Nuclear Reactor Regulation, NRC, ' Nuclear Project No. 1, Response to Requests for information Regarding Regulatory Guide 1.97,'
February 6, 1986, G01-86-0035.
6.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Ourina and Followina an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
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Technical Evaluat 4n Report Office of Nuclear Reactor Regulation
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This EG&G Idaho, Inc. report reviews the submittals for the Washington Public Power Supply System, Nuclear Project No.1, and identifies areas of nonconformance to Regulatory Guide 1.97.
Exceptions to these guidelines i
are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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