ML20206H535
| ML20206H535 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/30/1986 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20206H539 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7071, TAC-51078, TAC-51079, NUDOCS 8606260177 | |
| Download: ML20206H535 (22) | |
Text
EGG-NTA-7071 April 1986
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INFORMAL REPORT 4
/daho CONFORMANCE TO REGULATORY GUIDE 1.97 National CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT N05.1 AND 2 y,,yg,,,,,,
Laboratory M.
?d by the U.S.
J. W. Stoffe1 Department ofEnergy i
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Prepared for the pg U. S. NUCLEAR REGilLATORY COMMISSION Work perf r
No. DE-AC07.?ti/D015?O
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CONFORMANCE TO REGdLATORY GUIDE 1.97 CALVERT CLIFFS NUCLEAR POWER PL4NT, UNIT NOS. 1 AND 2 J. W. Stoffel 4
Published April 1986 4
f EG&G Idaho, Inc.
i Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-761001570 FIN No. A6483 4
c ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97 for Unit Nos. I and 2 of the Calvert Cliffs Nuclear Power 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.
l Docket Nos. 50-317 and 50-318 TAC Nos. 51078 and 51079 11
FOREWORD This report is supplied as part of the " Program for Evaluating Licensee /Ap')11 cant Conformance to RG. 1.97," being conducted for the U.S.
Nuclear Regulatory Conunission Office of Nuclear Reactor Regulation, Division of PWR Licensing A, by EG4G Idaho, Inc., NRR and I&E Support Branch.
l The U.S. Nuclear Regulatory Commission funded the work under authorization 8&R 20-19-10-11-3.
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Docket Nos. 50-317 and 50-318 TAC Nos. 51078 and 51079 111
CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
iii 1.
INTRODUCTION.....................................................
I 2.
REVIEW REQUIREMENTS..............................................
2 3.
EVALUATION.......................................................
4 1
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......................................................
15 5.
REFERENCES.......................................................
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CONFORMANCE TO REGULATORY GUIDE 1.97 CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS. 1 and 2 1.
INTRODUCTION I
On Decem'>er 17, 1982 Generic Letter No. 82-33 (Reference 1) was 1ssued t,y D. h. 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, 4
Revision 2 (Reference 2) relating to the requirements for emergency response capability. These requirements have been published as Supplement No. I to NUREG-0737, 'TMI Action Plan Requirements" (Reference 3).
t Baltimore Gas and Electric Company, the licensee for the Calvert C11tfs Nuclear Power plant, Unit Nos. 1 and 2, provided a response to the i
Regulatory Guide 1.97 portion of the generic letter on December 1, 1984 (Reference 4). Additional information was provided on February 21, 1986 (Reference 5).
I This report provides an evaluation of these submittals.
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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 documentat'lon 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 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.
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it was noted that no further staff review would be necessary. Therefore, this report only addresses exceptions to Regulatory Guide 1.97. The following evaluation is an audit of the licensee's submittals based on the review policy described in the hRC regional meetings.
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3.
EVALUATION The licensee provided a response to NRC Generic Letter 82-33 on December 1, 1984. Additional information was provided on February 21, 1986. The responses describe the licensee's position on post-accident monitoring instrumentation. This evaluation is based on these submittals.
3.1 Adherence to Reaulatorv Guide 1.97 The licensee provided an account of the conformance of the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, to Revision 3'of Regulatory Guide 1.97 (Reference 6). The licensee states that the information provided in their submittal meets the requirements of Supplement No. 1 to NUREG 0737, Section 6.
The licensee will complete any modifications identified to provide compliance to Regulatory Guide 1.97 prior to the startup following the cycle 10 refueling outage (Unit 1 ~ Spring 1988),
and the cycle 9 refueling outage (Unit 2 - Fall 1988) (Reference 7).
Therefore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97.
Exceptions to and deviations from the regulatory guide are noted in Section 3.3.
3.2 Twoe A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those var' ables that provide the 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.
Pressuriser level 2.
Pressuriser pressure 3.
Steam generator pressure 4
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Steam generator level 5.
Reactor coolant system (RCS) hot leg temperature 6.
RCS cold leg temperature 7.
Degrees of subcooling 8.
Condensate tank No. 12 level 9.
Containment hydrogen concentration
- 10. Containment pressure The above instrumentation meets the Category I recommendations consistent with the requirements for Type A variables.
3.3 Excentions to Reaulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.
3.3.1 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. In Reference 5 the licensee has committed to install environmentally qualified wide range instrumentation for this variable that will meet the guidelines of Regulatory Guide 1.97. We find this commitment acceptable.
3.3.2 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends a range of 0 to 6000 ppm for this variable. The licensee has instrumentation that covers a range of 5
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0 to 5000 pm. The licensee's justification is that this boron meter is adequate for any anticipated boron concentration.
The licensee deviates from Regulatory Guide 1.97 with respect to the l
range of this post-accident sampling capability. This deviation goes j
beyond the scope of this review and is being addressed by the NRC as part of their review of NUREG-0737, Ites !!.B.3.
3.3.3 Core Exit Tennerature 1
0 Regulatory Guide 1.97 recommends Category 1 instrumentation that is j
environmentally qualified and that has a range of 200 to 2300*F. The licensee has instrumentation with a range of 32 to 2000*F that is not environmentally qualified. In Reference 5 the licensee has connitted to environmentally qualify this instrumentation and install new indicators j
that will measure the recommended range. We find this commitment i
acceptable.
l 3.3.4 Deareas of Subcoolina l
j Regulatory Guide 1.97 reconnends a range of 200*F subcooling to 35'F i
superheat for this variable. The licensee has instrumentation that j
calculates the subcooled margin over a range of 100 to O'T of subcooling.
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The licensee justifies this range deviation by stating that the provided l
range is adequate to meet the needs of the emergency operating procedures.
l Manual calculation of the saturation margin over a greater range can be
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done using the RCS temperature and pressure.
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The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737. Item !!.F.2.
l 3.3.5 Containment s - Water Level 1
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Regulatory Guide 1.97 reconnends Category 2 instrumentation for the
- l narrow range instrumentation associated with this variable. The licensee tak'es enception to the environmental qualification reconnended for l
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Category 2 instrumentation. The licensee states that this equipment is j.
used only during normal operation and that post-accident monitoring is accomplished by the wide range instrumentation.
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Regulatory Guide 1.97 has listed this variable as one that is i
necessary for post-accident monitoring. The range of the wide range
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instrumentation does not start untti the water level is 9 inches above the i
containment floor, thus the sump level information cannot be obtained from j
l' the wide range instruments.
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We conclude that the licensee should provide instrumentation for this I
j variable that is environmentally qualified in accordance with the i
provisions of 10 CFR 50.49 and Regulatory Guide 1.97.
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3.3.6 Radiation Level in Circulatina Primary Coolant j
The licensee has provided one instrument loop to measure activity over l
a range of 0 to 10 counts per minute. This instrument is only used during 1
i normal operation to monitor gross activity changes. This instrument is l
isolated in the event of safety injection actuation. Post-accident '
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monitoring is accompitshed by grab sample analysis using the post-accident i
sampling system, which is being reviewed by the NRC as part of their review i
of NUREG-0737, Item II.B.3.
l Sased on the alternate instrumentation provided by the licensee, we j
conclude that the instrumentation supplied for this variable is adequate l
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and, therefore, acceptable.
3.3.7 Accumulator Tank Level and Pressure l
The licensee takes exception to the pressure range (0 to 750 psig) and
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environmental qualification recomended by Regulatory Guide 1.g7 for this l
vartable. The licensee states that the safety injection tank ($1T) level I
and pressure is only used for pre-accident indication of the status of $1Ts to assure that the safety injection system is prepared to serve its safety I
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f un'c tion. The Itcensee further states that no outside power source, j
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signal, or operator action is required for their operation during a design basis accident.
The licensee states that the pressure instrumentation provided (0 to 250 psig) is adequate to monitor the status of these tanks, and that the existing range will not be exceeded since relief valves on the tanks are set to relieve at 250 psig.
We find that the ranges of the instrumentation supplied for this variable are adequate to determine that the accumulators have discharged.
4 However, the existing instrumentation is not acceptable. An i
environmentally qualifted instrument is necessary to monitor the status of these tanks. The licensee should designate either level or pressure as the 4
t key variable to directly indicate accumulator discharge and provide l
instrumentation for that variable that is qualified to the requirements of I
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3.3.8 Flow in Hiah Pressure Injection System i
The range is not as recomended by Regulatory Guide 1.97 (0 to 110 f.orcent of design flow). The instrumentation provided covers a range of 0 to 300 gpm.
i In Reference 5, the licensee states that based on accident analysis and flow calculations, the maximum flow is expected to be approximately l
200 gpm. This is well within the 0 to 300 gpm range of the existing instrumentation and is, therefore, acceptable.
1 3.3.9 Refuelina Water Storane Tank Level Regulatory Guide 1.g7 recomends a range of top to bottom for this i
variable. The licensee has provided instrumentation for this variable with a range that spans from 18 inches above the tank bottom to 12 inches below l
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the tank top. The Itcensee states that the instrumentation meets the
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guidelines for post-accident monitoring.
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We find this deviation minor with respect to the overall size of the tank. The existing instrumentation is adequate to monitor the operation of the storage tank during all accident and post-accident conditions.
Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.10 Pressurizer Heater Status The licensee takes exception to using electric current to monitor all of the heater groups. Ammeters are provided for the two proportional heater banks only. All six heater banks have on-off indicating lights.
In Reference 5, the licensee states that after a safety injection actuation signal, the back-up heaters can only be added manually by an operator. The current of the energized heaters can be monitored from the load center anneters or the diesel kilowatt meter. Therefore, we find that the existing instrumentation is adequate to monitor the pressurizer heater current and is acceptable.
3.3.11 Quench Tank Level Regulatory Guide 1.97 recommends a level range from the top to the bottom of this tank. The licensee has provided instrumentation that corresponds to 4 percent to 96 percent of the tank volume. The licensee states that while the range is less than required, the instrumentation provided is adequate and sufficient for the intended post-accident monitoring function.
We find this deviation minor with respect to the overall size of the tank. The existing instrumentation is adequate to monitor the operation
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this tank during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.12 Steam Generator Level l
l Regulatory Guide 1.97 reconnends instrumentation that reads from the tube sheet (445 inches below normal operating level (NOL)] to the 1
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separators (39 inches above NOL). The licensee has provided instrumentation that reads from 401 inches below NOL to 63.5 inches above N0L. The licensee states that while the range is slightly less than required by Regulatory Guide 1.97, it is adequate for post-accident monitoring.
The steam generator is, la effect, empty at -401 inches of water relative to the normal operating level. Therefore, we find that this
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daviation is minor when compared to the overall range and instrument accuracy. The existing range is adequate for the intended monitoring function.
3.3.13 Containment Atasschere Temperature Regulatory Guide 1.97 recommends a00'F for the upper range limit. The licensee has provided instrumentation that reads to 300*F. The licensee l
states that the maximum temperature predicted inside the containment during a postulated accidentJs 274*F.
Since the worst case postulated accident will not increase the I
containment atmosphere temperature above 274*F,'we find the range of 0 to 300*F adequate to monitor this variable during all accident and i
post-accident conditions.
3.3.14 Con t11 men t_ Sumo _Wa t e r Temper a t ur e i
The licensee does nat have instrumentation for the containment sump water temperature. The licensee justifies this deviation by stating that this variable is not ustd in the management of a design basis accident and that it is not required for post-accident monitoring because the minimum net positive suction head (NPSH) requirements are not dependent on the sump i
water temperature.
This is insufficient justification for this exception. The licensee should provide environmentally qualifled instrumentation that will allow a j
qua'ntitative look at the operation of the heat removal from the containment i
sump or identify suitable alternate instrumentation (such as RHR heat exchange inlet temperature) that meets the Cateogry 2 requirements, w
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3.3.15 'Makeue Flow-In Regulatory Guide 1.97 recommends Category 2 instrumentation with a
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range of 0 to 110 percent design flow for this variable. The instrumentation provided monitors 0 to 94 percent of design flow and does not meet all Category 2 criteria. The licensee justifies this deviation by stating that this variable is not required for post-accident monitoring and I
is isolated in the event of a safety injection actuation.
j As this variable is not utilized in conjunction with a safety system, 1
we find that the instrumentation provided is acceptable.
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3.3.16 Letdown Flow-Out l
Volume Control Tank Level I
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Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables and a level range of top to bottom for the volume control tank.
j The provided instrumentation does not meet the Category 2 requirements for either of these variables and the range monitored for the volume control l
tank is 8 to 86 percent of the tank volume. The licensee states that the i
level indication of the volume control tank is used only during normal l
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operation and the existing range is adequate for this use. Furthermore, the letdown line and volume control tank make-up to the reactor coolant i
system is isolated in the event of a safety injection actuation.
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As these variables are not utilized in conjunction with a safety system, we find the instrumentation provided is acceptable.
i 3.3.17 C - onent Coolina Water Taaerature to Enaineered Safetv j
features (ESF) Systes The licensee deviates from the range recomended by Regulatory l
Guide 1.97 (40 to 200'F) for this variable. The licensee has provided a I
range of 50 to 200*F and states that this range is adequate and sufficient for post-accident monitoring, t
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The deviation of 10*F out of the maximum span of 200'F is 5 percent.
We consider this deviation minor and acceptable.
3.3.18 Component Coolina Water Flow to ESF System The licensee does not have flow indicators for this variable. The licensee states that an evaluation of the need for this instrumentation is
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being conducted.
If the review indicates the flow instrumentation is needed it will be provided.
The licensee should either comit to install the recommended flow instrumentation, or provide supporting justification or alternatives for this exception.
3.3.19 Hiah-level Radioactive Liould Tank Level Regulatory Guide 1.97 recomends instrumentation for this variable that reads from the top to the bottom of the tank. The licensee has provided instrumentation that reads from 73 inches above the bottom to 60 inches below the top of the hemispherical ended tank. This corresponds to 93 percent of the tank volume. The licensee states that the instrumentation provided is adequate for post-accident monitoring.
We find this dev';. tion minor with respect to the overall size of the tanks. The existing range is adequate to monitor the operation of these tanks during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.20 Radioactive Gas Holduo Tank Pressure Regulatory Guide 1.97 recomands a range for this variable to cover 0 to 150 percent of the design pressure. The instrumentation provided has a range of 0 to 150 psig which is 0 to 100 percent of design pressure. The justification given by the licensee is that the upper range limit of 12
100 percent of tank design pressure is adequate for post-accident monitoring and that above 150 psig, the holdup tanks relieve excess pressure to the surge tank.
Based on the justification provided by the licensee, we conclude that 4
the inst umentation provided for this variable is adequate to monitcr the operation of these tanks and 15, therefore, acceptable.
3.3.21 Radiation Exoosure Rate Regulatory Guide 1.97 recommends a range of 10~ R/hr to 10 R/hr for this variable. The licensee has provided instrumentation with a range l
of 0.1 mR/hr to 10 R/hr. The licensee justifies this deviation by stating that the inte'nded function of this instrumentation is personnel protection and the existing range is sufficient for that purpose. Detection of releases, release assessment and surveillance are performed through health physics procedures with supplemental information provided by the effluent monitors.
From a radiological standpoint, if the radiation levels reach or exceed the upper limit of the range, personnel would not be permitted into the areas without portable monitoring (except for life saving). Based on the alternate instrumentation used by the licensee for this variable, we find the proposed range for the radiation exposure rate monitors acceptable.
3.3.22 Vent from Steam Generator Safety Relief Valves or Atmospheric Dumo Ill.111 i
i Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. In Reference 5, the licensee has committed to provide Category 2 instrumentation for this variable. We find this commitment acceptable.
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i 3.3.23 All Identified Pla7t Release Points i;
Regulatory Guide 1.97 reconmends a range of 10-3 Therangeprovidedbythelicenseeis10'fi/cc to 10 pCi/cc for this variable.
to 5 x 10 ' for particulates. Halogens are sampled and analyzed
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off-line. In Reference 5, the licensee states that the identified plant release points are further monitc, red in the main plant vent. These main l
plant vent monitors cover the reconenended range. Therefore, because of the main plant vent monitors we find the instrumer.tation provided for this variable acceptable.
3.3.24 Estimation of Atmosoheric Stability i
Regulatory Guide 1.97 reconnends a range of -5 to 10*C for this variable. The licensee has provided a range of -3 to 7'C.
The justification provided by the licensee is that their instrumentation is adequate for the intended monitoring function, i
Table 1 of Regulatory Guide 1.23 (Reference 8) provides seven j
ateospheric stability classifications based on the difference in temperature per 100 meters elevation change. These classificattors range i
j from extremely unstable to extremely stable. Any temperature difference l
greater than +4*C or less than -2*C does nothing to the stability classification. The licensee's instrumentation includes this range.
l Therefore, we find that this instrumentation is acceptable to determine the i
atmospheric stability, i
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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.
Containment sump water level (narrow range)--environmental qualification should be addressed in accordance with 10 CFR 50.49 (Section 3.3.5).
2.
Accumulator tank level and pressure--environmental qualification should be provided in accordance with 10 CFR 50.49 for the parameter designated as the key variable (Section 3.3.7).
3.
Containment sump water temperature--the licensee should either supply the recommended instrumentation or identify suitable alternate instrumentation (Section 3.3.14).
4.
Component cooling water flow to ESF system--the licensee should either supply the recommended instrumentation or justify this exception (Section 3.3.18).
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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. 82-83)," December 17, 1982.
2.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Jollowina an Accident, Regulatory Guide 1.97 Revision 2, NRC, Office of Standards
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Development -December 1980.
3.
Clarification of TNI Action Plan Reauirements. Reauirements for Emeraency Response Canabi'ity, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear. Reactor Regulation, January 1983.
4.
Baltimore Gas and Electric Company Letter, J. R. Lundvall to Director, Office of Nuclear Reactor Regulation, " Regulatory Guide 1.97 Review."
December 1, 1984.
5.
Saltimore Gas and Electric Company Letter, Joseph A. Tiernan, to Office of Nuclear Reactor Regulation, NRC, " Regulatory Guide 1.97 Review," February 21, 1986.
l 6.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina ar. 8ollowina an Accident, i
Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory i
Research, May 1983.
7.
NRC letter E. J. Butcher to A. E. Lundvall Jr., Baltimore Gas and Electric Company, " Order Modifying License Confirming Additional Licensee Commitments on Emergency Response Capability (Supplement No. I to NUREG-0737)," July 16, 1985.
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8.
Onsite Meteoroloaical Proaraan, Regulatory Guide 1.23 (Safety Guide 23), NRC, february li,'972 or Meteoroloaical Proarams in Suncort of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, September 1980.
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,1 Sweet.tstent vseQT.8 sv..C,.m This EG&G Idaho, Inc. report reviews the submittal for Unit Nos. I and 2 of the Calvert Cliffs Nuclear Power Plant, and identifies areas of nonconform-ance to Regulatory Gute 1.97.
Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided l
are identified.
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