ML20206A023

Preliminary Conformance to Reg Guide 1.97,Fort Calhoun Station, Informal Rept

ML20206A023
Person / Time
Site:	Fort Calhoun
Issue date:	04/30/1986
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20206A028	List: ML20206A023 ML20206E342
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7157, EGG-NTA-7157-DRFT, TAC-51091, NUDOCS 8606160328
Download: ML20206A023 (20)

Text

. .

. TiqT}l' ' -

i

.. e x.. -(.

.. ~ .~ . . .

. - .: ..

EGG-NTA-7157 e

.. April 1986

. .~

s; .

.1

- - INFORMAL REPORT kigho

". h tfongl c0NFORMANCE TO REGULATORY GUIDE 1.97 EnI Ineer/nE FORT CALHOUN STATION 4,aboratory l Managed by the U.S.

- Depenment A. c. udy ofEnergy

• a .

a

.: 4

. i u

s .

t

?. . - . .

y

. :/ ; _ .

~

N;-

7. ., . -

4 - ;;y gi .z y#'_

.= -

..;yp. ,

n .,

MWY.m..O., .. a Prepared for the

- g.

watsummantener , *1.. j{[.[in.: '

U. S. NUCLEAR REGULATORY COMMISSION c.

, 40FW 4 I s' p ,

7ff_i.- '

v : ski.4.*

PREl.lMENARI

'. EGG-NTA-7157 CONFORMANCE TO REGULATORY GUIDE 1.37 FORT CALHOUN STATION A. C. Udy Published April 1986 EE&G Idaho, Inc.

Idahc Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission biashington, D.C. 20555 under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483 M

9

..-m

. 1

\

l l

l l

ABSTRACT  !

l This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97, Revision 2, for the Fort Calhoun Station 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.

l l

l l

i Docket No. 50-285 TAC No. 51091 11 -.

• 1 1

} f

9 l

s l

F6 REWORD l

This report is supplied as part of the " Program for Evaluating l I

Licensee / Applicant Conformance to RG 1.97," being conducted for the U.S.

Nuclear Regulatory Commission 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 Commission funded the work under authorization B&R 20-19-10-11-3.

e l

1 I

i I

I Docket No. 50-285 TAC No. 51091 111 ,

l

= e *w

1 t

CONTENTS i i

i 11 l

! A8STRACT ...............................................................

. I FOREWORD .............................................................. iii i

l

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 ........................ 5

4. CONCLUSIONS ...................................................... 13

5. REFERENCES ....................................................... 14 m

iv .

CONFORMANCE TO REGULATORY GUIDE 1.97 FORT CALHOUN STATION

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 Omaha Public Power District, licensee for the Fort Calhoun Station, provided a response to Section 6.2 of the generic letter on April 1, 1985 (Reference 4).

This report provides an evaluation of that material.

4 9

1 M

i l

l l

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 th'e

• 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. Environmental qualification

3. Seismic qualification

4. Quality assurance

5. Redundance and sensor location

6. Power supply

7. ' Location of display

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 Parch 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. Theref ore, 7

~

2 a

this report only addresses exceptions to Regulatory Guide 1.97. The following evaluation is an audit of the licensee's submittal based on the I'Vi'W Policy described in the NRC regional meetings.

O r

J I,

e 1

9 8

l I

3 5

3. EVALUATION The licensee provided a response to Item 6.2 of NRC Generic ,-

Letter 82-33 on April 1, 1985. The response describes the licensee's '

position on post-accident monitoring instrumentation. This evaluation is based on that material.

3.1 Adherence to Reaulatory Guide 1.97 The licensee has provided a review of their post-accident monitoring instrumentation that compares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 2. The licensee states that they have determined whether instrumentation complies with the regulatory guide or complies with the regulatory guide with exceptions or with modifications. In those instances where compliance of existing instrumentation was not established the licensee either justified the exception or deviation or committed to upgrade the instrumentation in '

question. For that instrumentation to be modified, the licensee has scheduled all modifications to be completed during or before the 1987 .

refueling outage. Therefore, we conclude that the licensee has provided an explicit' commitment on conformance to Regulatory Guide 1.97, except for those deviations that were justified by the licensee as noted in Section 3.3.

' 3.2 Tvoe A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, I i.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.

1. Neutron flux

2. Reactor coolant system (RCS) hot leg water temperature

. .E

3. RCS cold leg water temperature 4

- 4. Degrees of subcooling

5. Core exit temperature

6. Coolant level in reactor

7. Pressurizer level

8. Pressurizer pressure

9. Steam generator level

10. Steam generator pressure

11. Containment hydrogen concentration

12. Containment radiation monitor (high range)

These variables meet the Category 1 recommendations consistent with the requirements for Type A variables, except as noted in Section 3.3.

[ 3.3 Exceptions to Reculatory Guide 1.97 The licensee identified the following deviations and exceptions to Regulatory Guide 1.97. These are discussed in the following paragraphs.

3.3.1 Reactor Coolant System (RCS) Pressure Regulatory Guide 1.97 recommends instrumentation for a Combustion Engineering nuclear steam supply system with a range of 0 to 4000 psig for this variable. The licensee utilizes the pressurizer pressure instrumentation for this variable. The RCS and the pressurizer pressure are essentially the same. This is acceptable except that the range is 0 to 2500 psig. The licensee states that the existing range of 0 to 2500 psig is adequate to monitor all expected pressures based on.the

?

5

^

accident analyses presented in the updated Safety Analysis Report (USAR) and is acceptable pending resolution of the anticipated transient without

, scram (ATWS) issue. ,,

The licensee has committed to install Category 1 instrumentation with a range in accordance with the resolution of the ATWS issue if pressures are found to exceed those currently presented in the USAR. Therefore, this is an acceptable deviation.

3.3.2 Core Exit Temperature The licensee has identified this as a Type A variable. As such, Category 1 recommendations must be met by the instrumentation. In this, the licensee has identified a deviation that there is no continuous display of this information in the control room, but it is available on demand on the safety parameter display system (SPDS).

The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737, Item II.F.2.

i 3.3.3 Coolant level in Reactor Regulatory Guide 1.97 recommends continuous indication of this variable with a range from the bottom of the core to the top of the vessel. The licensee is installing a heated junction thermocouple level measurement system for this variable. The range is from the top of the core to the top of the vessel, and there is no continuous display of this information in the control room, but it is available on demand on the SPDS.

The licensee deviates from Regulatory Guide 1.97 with respect to the instrumentation for the variable coolant level in reactor. 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.F.2. .

6

. _ - 2 =~

. 3.3.4 Containment isolation Valve Position .

From the information provided, we find that the licensee deviates from a strict interpretation of the Category 1 redundancy recommendation. 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 guide. Position indication of check valves is specifically excluded by Table 2 of Regulatory Guide 1.97. Therefore, we find that the instrumentation for this variable is acceptable.

3.3.5 Radiation Level in Circulatino Primary Coolant Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has a radiation monitor on the letdown line (which is isolated from the RCS in an accident) and on-line gross gamma detectors that are part of the post-accident sampling system. The post-accident sampling system is being reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3.

Based on the alternate instrumentation provided by the licensee, we conclude, that the instrumentation supplied for this variable is adequate -

and, therefore, acceptable.

- 3.3.6 Containment Effluent Radioactivity Effluent Radioactivity Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables. The licensee states that this instrumentation is not in full compliance with the Category 2 recommendations, but that it was installed to and meets the requirements of NUREG-0737.

We find this to be a good faith attempt, as defined in NUREG-0737 Supplement No.1. Section 3.7 (Reference 3), to meet NRC requirements and is, therefore, acceptable.

7

l  !

1 l

3.3.7 Radiation Exposure Rate  !

I i

Revision 2 of Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has Category 3 t instrumentation for this variable. As Revision 3 of the regulatory guide l has changed the reconnendation for this variable to Category 3 f instrumentation, we find the instrumentation supplied for this variable l acceptable, f

i f

3.3.8 Accumulator Tank level and Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with ranges of 10 to 90 percent of volume and 0 to 750 psig. The i licensee's instrumentation meets the reconnendation for Category 2 instrumentation except for environmental qualification. The licensee I states that this instrumentation is not used post-accident, and that the I reactor vessel level is used to determine the performance of the emergency core cooling system. l I

The licensee states that the ranges provided art . to 100 percent, which is not stated to be in compliance (the licensee has not indicated l whether' the range is in percent of tank volume or in percent of instrument f i

tap height) and 0 to 300 psig, which is not.in compliance. The licensee did not justify this non-compliance. The licensee should provide justification in support of the O to 300 psig range. l 1

The existing instrumentation is not acceptable. An environmentally qualified instrument is necessary to monitor the status of tnese tanks.

The licensee should designate either level or pressure as the key variable to directly indicate accumulator discharge and provide instrumentation for that variable that meets the requirements of 10 CFR 50.49. If level is '

used as the key variable, then the range should be expanded to satisfy the recommendations of Regulatory Guide 1.97. .

[

8

3.3.9 Reactor Coolant Pumo Status '

Pressurizer Heater Status Regulatory Guide 1.97 recommends instrumentation for these variabl,es that measures the current drawn by this equipment. The instrumentation provided by the licensee for these variabler measures power (kilowatts). l The kilowatts of power used is a direct relation to the current.

Based on our review and judgment, we find the deviation of measuring power rather than current acceptable, as power has a known relation to current.

3.3.10 Containment Sump Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 50 to 250*F. The licensee does not have instrumentation for this variable, stating that the net positive suction I

head is adequate for the safety injection and containment spray pumps when operating in the recirculation mode, regardless of the sump water

~

temperature. The licensee also states that core cooling measurements infer containment cooling.

l This is insufficient justification for this exception. The licensee -

should provide the recommended instrumentation for the functions outlined in Regulatory Guide 1.97 or identify other instruments that provide the same quantitative information and satisfy the reconnendations of the regulatory guide.

3.3.11 Letdown Flow-Out Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation is Category 3. The licensee states that the letdown system is isolated during accident conditions.

9

As this variable is not used in conjunction with a safety system, we find that the instrumentation provided is acceptable.

3.3.12 Volume Control Tank Level -

Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation is Categnry 3. The licensee states that the volume control tank is automatically bypassed during accident conditions; that the volume control tank is not a source of borated water for safety injection and that this instrument loop is not required to achieve a safe shutdown.

As this variable is not used in conjunction with a safety system, we find that the instrumentation provided is acceptable.

3.3.13 Component Coolina Water Temperature to Encineered Safety Feature (ESF) System Comoonent Coolina Water Flow to ESF System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable.. The licensee's instrumentation is Category 2, except in the area of environmental qualification. The licensee states that the instrumentation is in a mild environment immediately post-accident, but that, in the long term, the instrumentation will be subject to a harsh environment. No justification was provided to determine the adequacy of this non-environmentally qualified instrumentation.

i Environmental qualification has been clarified by the Environmental l Qualification Rule,10 "'R 50.49. The licensee should therefore provide 1 the required justification for this deviation from Regulatory Guide 1.97 or s

provide instrumentation that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97.

10 l

.. 3.3.14 Containment or Purae Ef fluent--Noble Gases and Vent Flow Rate Auxiliary Buildina--Noble Gases and Vent Flow Rate ,

Common Plant Vent--Noble Gases and Vent Flow Rate Vent from Steam Generator Safety Relief Valves--Noble Gases.

Duration of Release and Mass of Steam per Unit Time Regulatory Guide 1.97 reconnends Category 2 instrumentation for these variables. The licensee states that this instrumentation is not in full compliance with the Category 2 recommendations, but that it was installed to and meets the requirements of NUREG-0737.

We find this to be a good faith attempt, as defined in NUREG-0737, Supplement No. 1 Section 3.7 (Reference 3), to meet NRC requirements and is, therefore, acceptable.

3.3.15 Wind Direction Regulatory Guide 1.97 recommends instrumentation for this variable with an accuracy of 15*. The instrumentation provided by the licensee has  :

an accuracy of 1 5 4*. No justification was provided for this deviation.

The licensee should provide justification showing why this deviation is acceptable.

3.3.16 Accident Samplino (Primary Coolant. Containment Air and Sume)

The licensee's post-accident sampling system provides sampling and analysis as recommended.by the regulatory guide, except it does not have I

the recommended capability for dissolved oxygen or oxygen content. The licensee states that this was not a requirement of NUREG-0737, but that the dissolved oxygen and oxygen content parameters can be determined using chemistry procedures. -

I.

p 11

The licensee deviates from Regulatory Guide 1.97 with respect to post-accident sampling capability. This deviation goes beyond the scope of this review and is being addressed by the NRC as part of their review of NUREG-0737. Item II.B.3. .

S.

l l

Sp i

12

_ _ , . _ _ _ _ _ . _ _ . . _ _ . . . _ . .N. _ . . _ ' .

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:

1. Accumulator tank level and pressure--environmentally qualified instruments should be provided; the licensee should verify the compliance of the level range; the licensee should justify the range of 0 to 300 psig (Section 3.3.8).

2. Containment sump water temperature--the licensee should provide the r'ecommended instrumentation or identify other instruments that provide the same quantitative information and satisfy the recommendations of the regulatory guide (Section 3.3.10).

3. Component cooling water temperature to engineered safety feature system components--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.13).

4. Component cooling water flow to engineered safety feature system

,' components--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.13).

5. Wind direction--the licensee should show that the accuracy of the instrumentation is acceptable (Section 3.3.15).

I 13

l S. 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 '

ResponseCapability(GenericLetterNo.82-33)," December 17j1982.

2. Mnstrumentation for Licht-Water-Cooled Nuclear Power Plants to assess Plant and Environs Conditions (lurina and Followina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.

3. Clarification of TMI Action Plan Reauirements. Reautrements for daeraency Response Capabi' ity, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.

4. Omaha Public Power District letter, R. L. Andrews to H. R. Denton, NRC, " Fort Calhoun Station Compliance with Regulatory Guide 1.97, Revision 2," April 1, 1985, LIC-85-117.

5. Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followina an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.

4 4

s e

37651 P

14 1

. . n .--. -r , - . ...o. < o - - r,oc ... ,

h,'# BISUOGRAPHIC DATA SMHT EGG-NTA-7157 set e.sT9uCTso.no o.e ^t .tvt.64 3 La.weeLA a

& Yif L4. .w. tat 64 Conformance to Regulatory Guide 1.97, -

Fort Calhoun Station e .ftas.o.1Coe 6tteo eso.e f.e vi..

April 1986 t .or o....

• • • """"* l A. C. Udy r.

g April 1986 ,

<. c , . ct v =.. ..$ ..  ;

, n o .a o.s . .r.o. ...w. ,

EG&G Idaho, Inc. ,,,,,,,,,,,,,,,,,,,

Idaho Falls, ID 83415 A6483 evn o. .. , .

,. o.c . .r.o ... .... .- e. c ... Preliminary Technical i Division of PWR Licensing - A Evaluation Report l Office of Nuclear Reactor Regulation '""'"'*' **" l U. S. Nuclear Regulatory Comission Washington, DC 20555 l 1 aw .g t.T v -QTES

. .. r..cra ..

This EG&G Idaho, Inc. report reviews the submittal for Fort Calhoun i

)

and identifies areas of nonconformance to Regulatory Guide 1.97. Exceptions l to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.

1

- ...........c.oi,o.sc...c..

. :c:. . 1 .v.vi ., -

Limited G itribution

't stC..i tw :. Ass,s. cat g I

'ITnUassified

. .oe v...... em ..:.o -i.

r.-,

Unclassified o .. . c. ..cn it ..+0E

., - , _ , - . _ _ _ . . , - - , _ . _ . . - - - _ , - , - _ , _ . , . - - - , . - . ,---,-----.,,.w---