ML20198S973
| ML20198S973 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/30/1986 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20198S974 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-EA-6771, TAC-51120, TAC-51121, NUDOCS 8606110136 | |
| Download: ML20198S973 (27) | |
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DJ i idaho CONFORMANCE TO REGULATORY GUIDE 1.97, ,
7 National P0 INT BEACH NUCLEAR PLANT, UNIT NOS.
1 AND 2 Engineering Laboratory i ,
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J. W. Stoffel
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DISCLAIMER This book was prepared as an account of work sponsored by an agency of ike United States Go ernment Nece> tre United States Gowernment nor any agency t* erect. nor any of their evr.plo,ees, m%es any narranty, e= press cr irnpbed, of assumes any legal liabihty or respons t4t, for the acc>acy. comc:eteress, or use'ainess of any information, apparatus. 0 o%ct or process disclosed. or represents that its , se would not intnnge pnvatelv caned r,gtts References tere.n to any specific cc-mercial product, process. or serwce Lv trade name, trademark. man u facture . or ot ewse. does not necessanly const t ute or irnp!v its endarsement. recom mendat.cn. o *a <gt,ng by the United States Go.e'nment or any agency t*e eof The views and co n,ons of authors empressed herein da not necessarJv state or re'iett those of the Un.tEJ States Government or any 4yet , therec.f l y . .;: l l l l l l l ,_._ l ( l
EGG-EA-6771 CONFORMANCE TO REGULATORY GUIDE 1.97 POINT BEACH NUCLEAR PLANT, UNIT N05.1 AND 2
'J. W. Stoffel Published February 1986 EG&G Idaho, Inc.
Idaho Falls, Idaho 83415
- n. w Prepared for the U.S. Nuclear Regulatory Commission Washington, C.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483 k
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ABSTRACT This EG&G Idaho, Inc., report reviews .the submittals'~for Regulatory
- Guide 1.97 for Unit Nos. I and 2 of the Point Beach Nuclear Plant 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.
FOREWCR0 This report is supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97," b+ing conducted for the U.S. Nuclear Regulatory Commisgion, Office of tiuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Ioaho, Inc., NRR and I&E Support Branch. ( The U.S. Nuclear Regulatory Commission funded the work under authorizat ion 20-19-10-11-3. h 1 i l l I .w- . t Docket Nos. 50-266 and 50-30; TAC Nos. 51120 anc 51121 T' ii i 1 2-t
i 1 CONTENTS A B S T R A C T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'I. . . . . . .ii. . . . . FOREWORD .............................................................. ii
- 1. INTRODUCTION ..................................................... I
- 2. REVIEW REQUIREMENTS .............................................. 2
- 3. EVALUATION ....................................................... 4 3.1 Adherence to Regulatory Gu ide 1.97 . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.2 Type A V a r ia b l e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.3 Except ions to Regulatory Gu ide 1.97 . . . . . . . . . . . . . . . . . . . . . . . . 5 l
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4 CONCLUSIONS ...................................................... 19
- 5. REFERENCES ....................................................... 20 ,
l i l l- . l i I t
. 111
. CONFORMANCE TO REGULATORY GUIDE 1.97 !
POINT BEACH NUCLEAR PLANT, UNIT'N05. 1 AND 2-i
- 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 i included additional clarification regarding Regulatory Guide 1.97, j Revision 2 (Reference 2), relating to the requirements for emergency '
! response capability. These requirements have been puolished as Supplement No. I to NUREG-0737, "TMI Action' Plan Requirements" (Reference 3) . The Wisconsin Electric Power Company, tne licensee for Point Beach Nuclear Plant, Unit Nos. I and 2, provided a response to the Regulatory Guide 1.97 portion of. the generic letter on September 1,1983 (Reference 4). Additional information was provided on August 30, 1985 (Reference 5) and November 27, 1985 (Reference 6). This report orovides an evaluation of these submittals. tu-1
1 3
': 2. REVIEW REQUIREMENTS 2
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 che following information for each variable shown in the applicable table of Regulatory Guide 1.97.
- 1. Instrument range I
- 2. Environmental qualifi, cation l
- 3. Seismic qualification
- 4. Quality assurance l 5. Redundance and sensor location -
- 6. Power supply !
- 7. Location of display 4
, 8. Schedule of installation or upgrade 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 ! .exc'eptions taken to Regulatory Guide 1.97. Where licensees or applicants exolicitly state that instrument systems conform to the regulatory guide, ! 2
it was noted that, no further staff review would be necessary. Therefore, this report only addresses exceptions to Regulatory Guide h97. The following evaluation is an audit of the licensee's submittals based on the review policy described in the NRC regional meetings. 1 - 9 l
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- 3. EVALUATION ed The licensee provided a response to NRC Generic Letter 82-33, on September 1, 1983. Additional information was provided on August 30, 1985 and November 27, 1985. This evaluation is based on these submittals.
3.1 Adherence to Reculatory Guice 1.97 The licensee states that their submittal provides a detailed account of the conformance of Wisconsin Electric Power Company's' Point Beach Nuclear Power . Plant, Unit Nos. ,1 and 2, to the recommendations of Revision 2 to Regulatory Guide 1.97. The licensee further states that the information provided in their submittal meets the requirements of Supplement No. I to NUREG-0737, Section 6. The licensee has committed to make the modifications they have identified by December 31, 1985 (Reference 7). Subsequent to this commitment the licensee agreed to modify the instrumentation for the variables neutron flux and pressurizer relief tank (quench tank) temperature by the end of their 1987 refueling outage (Reference 6). Therefore, we conclude that the licensee ha provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to anc deviations 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, w- -i'.e., those variaoles that provide the information required to permit the control room operator to take specific manually controlled safety' acttenrr - - - The licensee classifies the following instrumentation as Type A.
- 1. Refueling water storage tank level
- 2. Reactor coolaat system pressure
- 3. Containment pressure 7_
'1 4
- 4. Condensate storage tank level
- 5. Steam generator level
- 6. Auxiliary feedwater flow
- 7. Core exit temperature
- 8. Degrees of subcooling
- 9. Steam generator pressure 10 .' Pressurizer level This instrumentation meets Category I recommendations consistent with the requirements for Type A variables, except for 1 and 8 above. These are not environmentally qualified because they are located in a mild environment as defined by 10 CFR 50.49.
3.3 Exceptions to Regulatory Guide 1.97 The licensee identified the following deviations and exceptions frca Regulatory Guide 1.97. These are discussed in the following paragraphs. 3.3.1 Neutron Flux .u- : 1 Regulatory Guide 1.97 recommends Category 1 instrumentation to meaneer-- - this variable. The licensee has provided instrumentation that does not meet Category I requirements for environmental and seismic aualification. The licensee states that the source and intermediate range neutron flux monitors are not required for loss of coolant accident '(LOCA) or high energy line break (HELB) mitigation. Reactivity control is automatically achieved and maintained by reactor scram and injection of boric acid into j the Reactor Coolant System (RCS) by the safety injection system following a 7 5
postulated LOCA/HELB. They further state that control rod position indication and analysis of RCS samples for boron are considered adecuate to ensure reactor shutdown. The licensee maintains that neutron flux monitoring is a backup means of verifying automatic reactor shutdown' and, as such, should be classified as no higher than a Category 2 instrument. The licensee has committed, in Reference 5, to the installation of one channel of additional neutron flux monitoring per unit. This new channel is capable of monitoring the entire recommenaed range and will be environmentally and seismically qualified.' The following lists the available means of dete'rmining reactivity 4 control at this station.
- 1. A new neutron flux monitoring channel that is environmentally and seismically qualified and meets the regulatory guide range recommendat ion.
- 2. The 2 existing channels of source range and 2 existing channels of intermediate range neutron flux monitoring instrumentation that are redundant but, are not environmentally or seismically qual if ied.
- 3. Control rod position indication signals.
4 Safety injection system monitoring instrumentation. A
- 5. Monitoring of the RCS soluble boron content by analysis of gee 6 --
samples. Based on the availability of this neutron flux and alternate instrumentation, we conclude that the licensee nas crovided adeouate instrumentation to monitor this variable during post-accident conditions. 7_ 6
3.3.2 Reactor
Coolant System Soluble Boron Concentration Regulatory Guide 1.97 recommends instrumentation with a range of 0 to 6000 ppm for this variable. The licensee uses grab samples with analysis to monitor this variable and has identified the ability to analyze a range of 20 to 6000 ppm. The licensee states that a lower range limit of 0 ppm boron is not practicable to measure and that the difference in reactivity between a boron concentration of 0 and 20 ppm is negligible. The licensee deviates from Regulatory Guide 1.97 with respect to tne range of this 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. 4 3.3.3 Containment Isolation Valve Position The Iicensee deviates from the recomended environmental qualification and the single f ailure criteria for this variable, i The 1icensee's justification for the enyironmental qualification deviation is that, consistent with NRC Generic Letter 82-09 and 10 CFR 50.49, those valve position indicators associated with containment isolation valves located in a mild environment outside containment are not required to be environmentally qualified. The 1icensee's valve position indicators located in a potentially harsh accident environment are being
.- environmentally qualified in accordance with 10 CFR 50.49. We find this position acceptable. - - - - -
From the information provided, we find the licensee deviates from a strict interpretation of the Category I redundancy recommendation. Only the active valves have positicn 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 gu ide. Position indication of check valves is specifically excluded by Table 2 of Reggiatory Guide 1.97. Therefore, we find that the instrumentation for this variable is acceptable. 7
3.3.4 Radiation' Level in Circulating Primary Coolant The licensee uses the post-accident sample system, which is being reviewed by the NRC as part of their review of NUREG-0737, Item II.8.3, to measure this parameter. Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable. 3.3.5 Effluent Radioactivity--Noble Gas Effluent from Condenser Air Removal System Exhaust , Regulatory Guide 1.97 recommends instrumentation with a range of
-0 to 10-2 10 uCi/cc for this variable. In Reference 5, the licensee provided information on the new detectors that were mounted in pipe wells in April 1984. The range of the instrument for Unit No.1 is 1.1 x 10-7 to 3.8 x 10-3uCi/cc. This range nearly meets the regulatory guide recommendation. The range for Unit No. 2 does cover the recommended range. The licensee states that additional radioactivity monitoring of this variable is provided in the combined delay duct and the auxiliary building exhaust stack.
2 We conclude that the range deviation i ir this instrumentation is minor when compared to the overall range and instrument accuracy. Based on this and the availability of the alternate monitoring instrumentation, we find this instrumentation adequate to monitor this . variable during cost-accTEEEl-~~- c ond it ions. 7.. 8
3.3.6 Radiation Exposure Rate (inside buildings or areas, e.g., auxiliary building, reactor shield building annulus, fuel ha'n'dling building, which are in direct contact with primary containment where penetrations and hatches are located) The licensee takes exception to the environmental qualification recommended by Regulatory Guide 1.97 for this instrumentation. The licensee states that rad dation exposure rate is an ineffective means of detecting the breach of containment. Since other variables (e.g.,
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Auxiliary Building Exhaust Radioactivity) would be used for this purpose, the environmental qualification .of this instrument is not required, a We find the justification provided by the licensee for this deviation acceptable. In addition, Regulatory Guide 1.97, Revision 3, May 1983 (Reference 8) has deleted these expo'sure rate monitors from the guide. 3.3.7 RHR Heat Exchanger Outlet Temperature t Regulatory Guide 1.97, Revision 2 recommends an instrument range of 32 to 350*F for this variable. The provided range is 50 to 350*F. The licensee states- that this value (50*F) is the lowest possible temperature for this variable. Therefore, this range meets the intent of Regulatory Guide 1.97 and is adequate for monitoring system operation. Based on the licensee's statement that the instrumentation will remain on scale for any anticipated event, we find the range acceptable. w-3.3.8 Accumulator Tank Level and Pressure l Regulation Guide 1.97 recommends level instrumentation that is environmentally qualified and has a range of 10 to 90 percent volume. The licensee deviates from the range and environmental cualification . recommendations of Regulatory Guide 1.97 for the level instrumentation. The licensee provided the following justification for these deviations. The accumulator I Ievel instruments are not required for mitigation of l 5 9
LOCA/HELB s'inde' the safety injection accumulators are passive devices. The accumulator pressure instruments, which are qualified, ar'e used to' derive an equivalent accumulator water level. The existing instrumentation is acceptable. An environmentally
-l qualified instrument is necessary to monitor the status of these tanks. ;
The licensee has designated pressure as the key variable to directly indicate accumulator discharge and provided instrumentation for that variable that meets the requirements of 10 CFR 50.49. 3.3.9 Accumulator Isolation Valve Position i , l Regulatory Guide 1.97 reccmmends environmentally qualified instrumentation for this variable. The licensee has provided Category 3 instrumentation and states that this is acequate because this valve is normally open with power administratively removed (i.e., breaker locked open) from the motor. operator. Since the closing of this valve is not required for accident mitigation, enyironmental qualification of the valve position indicator is not required. l Based on the licensee's justification and the f act that this valve is open and does not change position daring or follcwing an accident, we consider Category 3 instrumentation adequate for tnis variable. 3.3.10 Boric Acid Charging Flow w- . . . . - Regulatory Guide 1.97 recommends Category 2 instrumentation to monitor this variable. The licensee states that Category 3 instrumentation is appropriate for this variable. The following justification was given by the licensee. The charging pumps are not used -for mitigation of design-bas is accidents. Therefore, environmental qualification of the charging line flow instrument is not required. Boric acid is injected into the RCS during LOCA/HELB accident conditions using tne safety injection system, wnich has qualified flow instruments. 10
As the charging pumps are not utilized at Point Beach as a safety system, we find.that the instrumentation provided for this-variable is acceptable. 3.3.11 Flow in High Pressure Injection (HPi) System Regulatory Guide 1.97 recommends a range of 0 to 110 percent of design flow for this variable. The instrumentation provided by the licensee has a range 0 to 1500 gpm (0 to 107 percent of design flow). The licensee's justification for this deviation is that the upper range of 107 percent of high pressure safety injection flow is adequate to monitor the expected range of flow conditions. The 1,07 percent of design flow is close to 110 percent of design flow and is adequate to determine pump runout flow rate in an accident.- The existing range is adequate to provide the necessary accident and post-accident information. Therefore, this is an acceptable deviation from Regulatory Guide 1.97, 3.3.12 Pressurizer Heater Status Regulatory Guide 1.97 recommends electric current monitoring to determine the operating status of the heaters. The 1icensee relies on , breaker. position indication lights in the control room to determine heater status. In addition to the indicating lights the licensee has ammeters in l'~ the control room for monitoring the 4160 volt and 430 volt supply transformers. Each heater group current can be readily seen on the l associated ammeters during cycling to verify operability. The licensee I further states that if pressure response indicates that a problem exists with the pressurizer heaters an operator can be sent to accessable local control panels located outside of the control room. The control group of heaters has ammeters as well as circuit breakers on these panels and the T 11
, other panci's have individual circuit breakers for each set of three heater elements. Troubleshooting and possible repair can be acc5Eplished, on J ~ individual heater groups or power sources, from these power panels. Based on the electrical bus ammeters in the control room and the availability of tne local power panels that can be checked if a malfunction is suspected, we conclude that the existing instrumentation.to monitor this variable is acceptable. 3.3.13 Quench Tank Temperature The licensee deviates frop the range recommended in Regulatory Guide 1.97 for this variable (50 to 750*F). The provided range is 0 to 300*F. The licensee's justificaticn for this deviation is that the upper range limit (300*F) is close to the saturation temperature (338*F) for the
. tank design pressure and rupture disk relief pressure of 100 psig. The licensee has committed, in Reference 5, to change the range of this i instrument to 50 to 350*F.
The new range will cover the anticipated requirements for normal operation, anticipated operational occurrences and accident conditions. ' This range relates to the tank's rupture disk and 100 psi tank design pressure that limits the temperature of the tank contents to saturated steam conditions under 350 F. Thus, we find this deviation from the regulatory guide acceptable. u-
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3.3.14 Heat Removal by the Containment Fan Heat Removal System Regulatory Guide 1.97 recommends Category 2 instrumentation to monitor this variable. The licensee's instrumentation is Category 2, except for environmental qualification. The licensee is not supplying environmentally qualified instrumentation, indicating that this variable is used as backto
; instrumentation that is not within the scope of 10 CFR 50.49. The licensee also states that the accomplishment of post-accident cooling is verified by 12
L monitoring the: redundant, qualified containment atmosphere and sump , temperatures and the containment pressure instrumentatione We find the application of backup instrumentation in conjunction with key variables to monitor the heat removal function acceptable. 3.3.15 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends a range of 40 to 400*F for this
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variable. The licensee has provided a range of 50 to 350*F. The licensee
' l states that the lower range 1imi,t of 50*F is adequat'e s inte the' containment
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temperature is always maintained above 50 F. The licensee states that the upper range limit is adequate b'ecause the design temperature of the containment from a large-break LOCA is 280 F. A peak temperature of 3a0 F is postulated to occur during a steamline break for a short ' duration. , . Since the worst case postulated accident will not increase the containment atmosphere temperature above 340*F and the containment ! atmosphere temperature is always maintained above 50 F, we find the range of 50 to 350 F adequate to monitor this variable during all post-accident conditions. 1 j 3.3.16 Makeuo Flow-in, Letdown Flow-out, and Volume Control Tank Level The 1icensee deviates from the environmental qualification, and
- v- seismic qualification recommendations' of Regulatory Guide 1.97 for these variables. The licensee states that the CVCS (Chemical and Volume ConM-System) except the BASTS (Boric Acid Storage Tanks) are not required for mitigation of design-basis LOCA/HELB accidents. RCS makeup and boric acid injection is performed by the separate safety injection system. Therefore, qualification of these instruments is not required.
Additionally, we note that the makeup and letdown lines are isolated by an accident signal. 13
7 As thesd variables are not utilized at Point Beach in conjunction with a safety system, we find that the instrumentation provided is acceptable. 3.3.17 Component Cooling Water Temperature to Engineered Safety Feature (ESF) System Regulatory Guide 1.97, Revision 2 recommends a range of 32 to 200*F for this variable. The provided instrumentation has a range of 50 to 200 F. The justification provided by the licensee is that this value (50 F) is the lowest possible value expected for this variable. Therefore, this range meets the intent of Regulatory Guide 1.97 and is adequate for monitoring system operation. , Based on the licensee's statement that the instrumentation will remain on scale for any anticipated event, we find that the range is acceptable. 3.3.18 Radioactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends a range for this variable to cover 0 to 150 percent of the design pressure. The instrumentation provided has a range of 0 to 100 percent of design pressure (0 to 150 psig). The licensee states that the tanks are designed for 150 psig. The tanks are never operated near this design rating as the system ~ switches to a standby tank at 95 psig and an alarm alerts the operator of overpressure
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at 112 psig.
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l The 1icensee states that the range of 0 to 150 psig covers the anticipated requirements for normal operation, anticipated operational occurrences and accident conditions. Based on this, we find the deviation-from the recommendec range acceptable. s* 14
a_ . . 3.3.19 Emergency Ventilation Damper Position Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable.- In Reference 5, the licensee states that envirormental qualification is not required for these position indicators because they are located in a mild environment and are not within the scope of 10 CFR 50.49. , Seismic qualification of these damper position indicators is planned to be addressed in accordance with the response to unresolved safety issue A-46, " Seismic Qualification of Equipment in Operating Reactors." Therefore, seismic qualification is ceyond the scope of this review, and will be reviewed by the NRC as'part of their review of unresolved safety issue A-46. 3.3.20 Radiation Exposure Rate (inside buildings or areas where access is required to service equipment important to safety) The licensee has provided area radiation instrumentation with various ranges. Some do not have the range recommended by Regulatory Guide 1.97 (10- to 10 R/hr). The licensee's justification for this deviation is that the existing ranges are based on expected post-accident radiation dose rates. Two overlapping detectors are used where required to cover the entire expected range. w- The ranges of the existing instrumentation are adequate. The areas where high radiation levels would be expected post-accident have both TPMPr-- - and low range instruments. These overlapping instruments cover the range recommended by Regulatory Guiae 1.97. Therefore, we consider this deviation from Regulatory Guide 1.97 acceptable. t Exception is also taken to the environmental qualification recommended by Regulatory Guide 1.97 for this instrumentation. The licensee's justification for this deviation is that portable survey meters are the 7_ l 15 l i
I primary means of measuring radiation levels for personnel access. Area
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radiation monitors are not appropriate for rad'ioactivity release detection and assessment. Revision 3 of Regulatory Guide 1.97 recommends Category 3 instrumentation for this variable. Environmental qualification is not required. Therefore, the instrumentation for this variable is acceptable. 3.3.21 Vent from Eteam Generator Safety Relief Valves or Atmospheric DumD Valves Regulatory Guide 1.97 recommends a range of .01 to 10 uCi/cc and Category 2 instrumentation for this variable. The licensee deviates from the range and has not provided environmental qualification for this instrumentat ion. The range of the provided instrument is 1 to 10" nR/hr wnich is stated to be equivalent to 0.15 uCi/cc to 1.5 x 10 3uC i/cc . The licensee's justification for this deviation is that the actuai lower range is judged to be adequate to monitor this variable. Considering instrument accuracy in this lower range we find that this range is Jequate to monitor this variable during post-accident conditions. In Reference 5, the licensee states that environmental qualification is not required for these monitors because they are located in a mild environment and are not within the scope of 10 CFR 50.49. We find this
'- instrumentation acceptable.
3.3.22 Plant and Environs Radiation (portable instrumentation) The licensee deviates from the range recommended by Regulatory Guide 1.97 for this variable (10- to 10 o/nr, gamma: 10-3 to 10 rads /hr, beta). The instrumentation provided does not meet the upper range (10 # to 103R/hr, gamma; 10-3 to 5 x 102 rad /hr, beta). The licensee states that the upper range limit is adequate since entrance 16
I l to any high radiation area (i.e., >100 mR/hr) would be under tight administrative controls to preclude overexposure except in-an emergency. This instrumentation is portable and .would not be used to assess levels of radiation greater than the range provided by the licensee. Therefore, this is an acceptable deviation from Regulatory Guide 1.97. 3.3.23 Estimation of Atmospheric Stability The licensee deviates from the temperature range (-9 to +18 F) that Regulatory Guide 1.97 recommends for this variable. The supplied range is
-10 to +10*F. The licensee states that this range is based on an autoconvective lapse rate of s7'F per 235 feet which is the maximum theoretical temperature gradient above which turbulent mixing occurs to equalize the temperatures.
Table 1 of Regulatory Guide 1.23 (Reference 9) provides 7 vertical atmospneric stability classifications based on the difference in temperature per 100 meter elevation change. These classifications cover from extremely unstable to extremely stable. Any temperature difference greater-than +4 C or less than -2 C does nothing to the stability class if icat ion. The licensee's instrument accuracy is as specified in Regulatory Guide 1.97, the temperature range and the vertical separation are both greater than that recommended in Regulatory Guide 1.23. Therefore, we find that this instrumentation is acceptable to determine the
,_ atmospheric stability.
3.3.24 Accident Sampling (primary coolant, containment air and sumo) The licensee deviates from the ranges recommended by Regulatory Guide 1.97 for the following variables:
- a. Boron content--0 to 6000 ppm recommended, 20 to 6000 ppm is prov ided.
Y 17
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- b. Chl5r^1de content--O to 20 ppm is recommended, 0.1 to 20 ppm is ,
provided. The licensee has no onsite analysis capability for
; this variable.
- c. Dissolved hydrogen--O to 2000 cc/kg is recommended,10 to greater i than 2000 cc/kg is provided.
1
- d. Dissolved oxygen and oxygen content--these two variables are not read at this station.
The licensee deviates fromI 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. I 1 i~o - M= i e L 3 { 18
- 4. CONCLUSIONS Based on our review, we find that the licensee either conforms to or is justified in deviating from the guidance of Regulatory Guide 1.97.
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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. 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 Piant ano t nvirons Londitions During and Following an Acc ident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
- 3. Clarification of TMI Action Plan Requirements, Reouirements for Emergency Response Capability, NUREG-0737, Supplement No. i, NRC, ottice of Nuclear Reactor Regulation, January 1983.
4 Wisconsin Electric Power Company (WE) letter, C. W. Fay to H. R. Denton, Director, Office of Nuclear Reactor Regulation, NRC, September 1, 1983.
- 5. Wisconsin Electric Power Company (WE) letter, C. W. Fay to H. R. Denton, Director, Nuclear Reactor Regulation, NRC, August 30, 1985, VPNPD-85-282 NRC-85-93.
- 6. Wisconson Electric Power Company (WE) letter, C. W. Fay to H. R. Denton, Director, Office of Nuclear Reactor Regulation, NRC,
" Confirmation of Schedule for Regul6 tory Guide 1.97 Commitments, Point Beach Nuclear Plant, Units 1 and 2, " November 27, 1985, VPNPD-85-537, NRC-85-126.
- 7. Letter, J. R. Miller, NRC to C. W. Fay, Wisconsin Electric Power Company (WE), July 3, 1984.
- 8. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess P lant and Environs Conditions During and Following an Accioent, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
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- 9. Onsite Meteorological Programs, Regulatory Guide 1.23 (Safety -- -
Guioe 23), NRC, February 17, 1972 or Meteorological Programs in Support of' Nuclear Power Plants, Proposed Revision 1 to Regulatory Guiae 1.23, NRC, Office of Standards Development, September 1980. 37877 I 20
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- 3. TITLE AND SwSTITLE 3 LIAvi SLANE Conformance to Regulatory Guide 1.97, Point Beach Nuclear Plant, Unit Nos.
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February l 1986 7 p t APORWe4G QR "4Ama2ATION Naut aNQ MasLsNG ACQatSS isaceweeld Cese, 8 PmCatcT Ta&E wCan WNet NwwetR EG8G Idaho, Inc. ,.,No G A,,,,,,,,,, Idaho Falls, ID 83415 A6483 10 SPONSQA.NG QMG ANel Af eGN Naut AND MasLa8eQ .OQat15 reassi,ee l.a Cases i t s ' vet C' At*Ca! Division of Systems Integration ' Technical Evaluation Report Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission > t a'a cm a n '~~~ ~~ Washington, DC 20555 12 SbPPLEVENf amv NOTES t3 LGSTRACT s20peeres or eess This EG&G Idaho, Inc., report reviews the submittals for the Point Beach Nuclear Plant, Unit Nos. I and 2, and identifies areas of nonennformance to Regulatory Guide 1.97. Exceptions to these guidelines are evaluated.
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