ML20206T135
| ML20206T135 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/31/1986 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20206T139 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7076, TAC-51362, NUDOCS 8609240175 | |
| Download: ML20206T135 (26) | |
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Enclosure
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EGG-NTA-7076 O
CONFORMANCE TO REGULATORY GUIDE 1.97 TROJAN NUCLEAR PLANT J. W. Stoffel Published July 1986 s
EG6G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483 A
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T ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97 for the Trojan 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 .
l acceptability is not provided are identified.
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Docket No. 50-344 l
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FOREWORD This report is supplied as part of the " Program for Evaluating Licensee / App 11'can' t "Conformance to R.G.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 20-19-10-11-3.
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Docket No. 50-344 TAC No. 51362 iii
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CONTENTS .
ABSTRACT .............................................................. 11 FOREWORD .............................................................. iii i
- 1. INTRODUCTION ..................................................... 1
- 2. REVIEW REoulREnENTS .............................................. 2
- 3. EVALUATION ....................................................... 4 j l
3.1 Adherence to Regulatory Guide 1.97 ........................ 4 !
3.2 Type A Variables ........................................... 4 )
3.3 Exceptions to Regulatory Guide 1.97 ........................ 5-
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- 4. CONCLUSIONS......................................................... 18 l
- 5. REFERENCES ....................................................... 19 ;
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. CONFORMANCE TO REGULATORY GUIDE 1.97 TROJAN NUCLEAR PLANT
- 1. INTRODUCTION On December 17, 1982 Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, 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 capabil.i.ty.. These requirements have been published as Supplement No. 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Portland General Electric Company, the licensee for the Trojan Nuclear Plant, provided a response to the Regulatory Guide 1.97 portion of the generic letter in December 1984 (Reference 4). Additional information was provided on May 13, 1986 (Reference 5).
, This report provides an evaluation of these submittals.
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- 2. REVIEW REQUIREMENTS Section 6.2 of NUREG-0737 Supplement No. 1, sets forth the documentation to be submitted in a report to the NRC describing how the licensee complies with Regulatory Guide 1.97 as applied to emergency ,
response facilities. The submittal should include documentation that provides the following information for each variable shown in the .
applicable table of Regulatory Guide 1.97.
- 1. Instrument range
- 2. Environmental qualification
- 3. Seismic qualification l 4. Quality assurance
- 5. Redundance and sensor location
- 6. Power supply s
- 7. Location of display
- 8. Schedule of installation or upgrade The submittal should identify deviations from Regulatory Guide 1.97 and provide supporting justification or alternatives.
Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983, to answer licensee and ,
applicant questions and concerns regarding the NRC policy on this 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, 2
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- 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 NRC regional meetings.
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- 3. EVALUATION .
The licensee provided a report addressing the Regulatory Guide 1.97 portion of NRC Generic Letter 82-33 in December 1984. Additional information was submitted on May 13, 1986. This evaluation is based on ,
these submittals.
3.1 Adherence to Reculatory Guide 1.97 The licensee stated that compliance with Regulatory Guide 1.97, Revision 3 (Reference 6), is indicated in their accident monitoring 4 instrumentation review, which summarizes each variable's compliance with the Regulatory. Guide 1.97 provisions. That compliance review presents justification, modifications or ongoing evaluations that are provided as resolutions for any identified deviations. The licensee states in Appendix 7C of their report on conformance to Regulatory Guide 1.97 that all upgrade modifications are scheduled for completion by the end of the 1987 refueling outage. Therefore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97.
Exceptions to and deviations from the regulatory guide are noted in s Section 3.3.
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3.2 Tvoe A variables l
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 spec'ific manually controlled safety actions.
The licensee classifies the following instrumentation as Type A.
- 1. Reactor coolant system (RCS) hot leg water temperature
- 2. RCS cold leg water temperature -
- 3. RCS pressure (wide range) 4
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. 4. Core exit temperature
- 5. Containment pressure f l
- 6. Refueling water storage tank level
- 7. Pressurizer level
- 8. Steam generator level
- 9. Steam generator pressure
- 10. Condensate storage tank level This instrumentation meets Category 1 recommendations consistent with the requirements for Type A variables, except as noted in Section 3.3.
3.3 Exceptions to Reaulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory s 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. The licensee has committed to the installation of a single new neutron flux channel that will meet the Category 1 requirements; however, a fully qualified redundant channel will not exist. Category 1 requirements include full redundancy to satisfy the single failure criteria. The licensee states, in Referente 4, that one Category 1 channel is sufficient since control rod position and RCS soluble boron concentration can be used as diverse methods of monitoring this variable during all types of accidents.
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In Reference 5, the licensee reiterated the justification previously ,
submitted. This justified for a single channel of qualified neutron flux instrumentation is not acceptable. The single failure criteria sh'ould be complied with. We conclude that the licensee should provide a fully qualified redundant channel of neutron flux instrumentation to satisfy the ,
single failure criteria.
3.3.2 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends Category 3 instrumentation, with a range of 0 to 6000 ppm, for this variable. The licensee does not provide a separate instrument for this variable. To conform to the regulatory guide, the licensee is .tak,ing credit for the post-accident sampling system for this variable.
The licensee takes exception to Regulatory Guide 1.97 with respect to
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post-accident sampling capability. This exception 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.
, 3.3.3 Core Exit Temperature Regulatory Guide 1.97 recommends Category 1 instrumentation with a i
range of 200*F to 2300*F. The licensee has provided a continuous display of 0 to 700*F. The monitoring system is not environmentally or seismically qualified and the power source is non-Class 1E.
The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737 Item II.F.2.
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1 3.3.4 Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee identified the following areas in which they deviate from the Category 1 criteria:
- 1. Recording has not been provided.
- 2. Redundancy of indication generally has been met on a per line basis rather than on a per valve basis.
- 3. Indication is not continuous for certain valves that are required to be de-energized with power removed to ensure that the correct position is maintained.
- 4. Indication is not provided for manually operated valves, safety relief valves, or check valves used as containment isolation valves.
From the information provided, we find that the licensee deviates from
' a strict interpretation of the Category 1 criteria. We view recording of
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the position of these valves as unnecessary. Only the ac'tive valves have i 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. Loss of indication due to the removal of power from the valve power control circuit is acceptable. Position indicati5n of check valves is specifically l excluded by Table 3 of Regulatory Guide 1.97. Therefore, we find that the
! instrumentation provided for this variable is acceptable.
l 3.3.5 Radioactivity Concentration or Radiation Level in Circulatina Primary Coolant The licensee has a gross failed-fuel monitor that continuously measures the concentration of gamne emitting fission products in the primary coolant during normal operation. Post-accident, this monitor is t
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1solated and the post-accident sampling system, which is being reviewed by ,
the NRC as part of their review of NUREG-0737. Item II.B.3, is used to verify fuel cladding integrity.
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 Condenser Air Removal System Exhaust-Noble Gases Containment Effluent Radioactivity-Noble Gases Effluent Radioactivity-Noble Gases In Reference.5, the licensee provided the required information for these variables. Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables and a range up to 10 pC1/cc for the auxiliary building exhaust. The licensee has provided Category 3 instrumentation that is equivalent to the NUREG-0737 criteria under which this equipment was installed. The upper limit of 300 pCi/cc for the auxiliary building exhaust monitors and the Category 3 instrumentation was previously reviewed and accepted by the NRC as part of their review of s NUREG-0737.
i 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.
3.3.7 Residual Heat Removal (RHR) Heat Exchanaer Outlet Temperature l
Regulatory Guide 1.97 recommends a range for this variable of 40 to 350*F. The licensee has supplied a range of 50 to 400*F. The instrumentation supplied has a range where the lower limit of the range -
does not conform to the regulatory guide.
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. The licensee statis that operators are required by written procedures to maintain the reactor coolant temperature above 100*F when using the RHR system. In addition, the minimum temperature that the reactor vessel may be at with the head bolts tensioned, is 60*F. Finally, the licensee states that all Updated Final Safety Analysis Report, Chapter 15, condition III
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and IV, accidents will cause the RHR outlet temperature to rise, showing that the temperature range is adequate.
Based on the justification provided by the licensee, we conclude that the existing range is adequate to monitor the RHR system operation.
3.3.8 Accumulator Tank level and Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee takes exception to the recommended pressure range (0 to 750 psig) and level range (10 to 90 percent volume) and the level instrumentation, except for environmental qualification, is Category 2.
The licensee has supplied pressure instrumentation with a range of 0 to 700 psig. The licensee states that the operators are required by the plant technical specifications to manually control the accumulator pressure between 600 and 673 psig. The tank design pressure is 700 psig and relief valves limit the pressure to this value.
The licensee has supplied level instrumentation with a range of 53 to 70.9 percent volume. The licensee states that level indication is useful during normal operation to ensure that adequate water is available for injection. The operators are required by technical specifications to manually control the accumulator level to between 64 and 69 percent volume.
The accumulator pressure is the key variable used to determine the status of the accumulators. The accumulators are passive devices. Their discharge into the reactor coolant system (RCS) is actuated solely by a decrease in the RCS pressure. We find that the instrumentation supplied for this variable is adequate to determine that the accumulators have 9
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discharged. Therefore, the instrumentation provided for this variable is
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acceptable. .
l 3.3.9 Refuelina Water Storaae Tank Level Regulatory Guide 1.97 recommends a range from the top to the bottom of the tank. The licensee does not meet this range and states that the
- existing range is adequate. The usable volume of the tank is from 37 feet 1 inch (in the overflow line) to 2 feet 4 inches (the tank outlet). The installed instrument taps are at a point 37 feet 7 inches (in the overflow line) to 2 feet 4 inches from the tank bottom. This span covers more than the usable volume of the tank. .
Based on the ustification provided by the licensee, we find the ,
instrumentation for this variable adequate to monitor the level of this tank.
1 3.3.10 Pressurizer Level Regulatory Guide 1.97 recommends a range from the bottom to the top for this variable. The instrumentation provided by the licensee does not read this full range. The licensee states that the volume measured .
represents approximately 92 percent of the pressurizer volume and that this
- is sufficient for the operator to take the required manual actions and to ensure the proper operation of the pressurizer.
i The volume of the pressurizer where level is not indicated (approximately 8 percent volume) is the upper and lower hemispherical head region, where the volume to level ratio is not linear. We find this deviation minor and acceptable. The existing range is adequate to monitor this variable during all accident and post-accident conditions.
3.3.11 Quench Tank Level The range of the existing instrumentation for this variable does not meet the range recommended by Regulatory Guide 1.97 (top to bottom). The 10
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