ML20207A704
| ML20207A704 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/30/1986 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML17334A985 | List: |
| References | |
| CON-FIN-A-6483, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7282, GL-82-33, TAC-51080, TAC-51081, NUDOCS 8607160221 | |
| Download: ML20207A704 (49) | |
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EGG-NTA-7282 CONFORMANCE TO REGULATORY GUIDE 1.97 DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 A. C. Udy Published June 1986 EG&G 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
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FIN No. A6483
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e A8STRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97, Revision 3, for the Donald C. Cook Nuclear Plant, Unit Nos. I and 2, 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.
FOREWORD This report is supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97," being conducted for the U.S.
Nuclear Regulatory 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.
Docket Nos. 50-315 and 50-316 TAC Nos. 51080 and 51081 11
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e CONTENTS ABSTRACT..............................................................
ii FOREWORD..............................................................
11 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......................................................
17 5.
REFERENCES.......................................................
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CONFORMANCE TO REGULATORY GUIDE 1.97 DONALD C. COOK NUCLEAR PLANT. UNIT NOS. 1 AND 2 1.
INTRODUCTION
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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).
Indiana and Michigan Electric Company, the licensee for the Donald C.
Cook Nuclear Plant, provided a response to Section 6.2 of the generic letter on February 28, 1985 (Reference 4).
This was revised on October 15, 1985 (Reference 5).
These submittals address Revision 3 of Regulatory Guide 1.97 (Reference 6).
This report provides an evaluation of the material submitted by the
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licensee.
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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 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 r
l 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 matter.
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
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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EVALUATION The licensee provided a response to Item 6.2 of NRC Generic Letter 82-33 on February 28, 1985.
This was revised on October 15, 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 agtinst the recommendations of Regulatory Guide 1.97, Revision 3.
The licensee states that in several instances, satisfactory instrumentation exists and that additional instrumentation will be installed to comply with Regulatory Guide 1.97, except for those instances where deviations are technically justified. The licensee has stated that all planned modifications to bring about compliance with Regulatory Guide 1.97 will be complete by the end of the Unit No. 2 refueling outage in 1989. 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.e., those variables 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.
I 1.
Centrifugal charging pump flow 2.
Reactor coolant system (RCS) pressure 3.
Steam generator pressure 1
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4.
Containment sump level 5.
Steam generator level - narrow range 6.
Pressurizer level 7.
Containment area radiation monitor - high range 8.
Containment pressure - narrow range 9.
Auxiliary feedwater flow 10.
Refueling water storage tank level 11.
Degrees of subcooling 12.
Reactor coolant pump breaker status
- 14. Safety injection pump breaker status 15.
Safety injection pump flow 16.
Steam generator blowdown radiation s
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
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The licensee identified the following deviations and exceptions to Regulatory Guide 1.97.
These are discussed in the following paragraphs.
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e 3.3.1 Neutron Flux Regulatory Gude 1.97 recommends Category 1 instrumentation to monitor this variable in post-accident conditions. Thus, this instrumentation should be environmentally qualified.
The licensee's instrumentation is not environmentally qualified. The licensee states that this instrumentation is not needed for mitigation of loss of coolant accidents or high energy line breaks. The reactor shutdown is accomplished by the reactor SCRAM and by boric acid injection, and is verified by Category 3. instrumentation for control rod position and analysis of reactor coolant system grab samples.
We find this position unacceptable. The neutron flux instrumentation is necessary to observe inadvertant reactivity additions and in monitoring anticipated transients without scram (ATWS) events.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49.
The licensee should therefore provide instrumentation that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97.
3.3.2 Reactor Coolant System Soluble Baron Concentration Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 6000 parts per million.
The licensee identifies the post-accident sampling system as fulfilling this recommendation.
The licensee did not provide the range of the instrumentation as required by Section 6.2 of NUREG-0737, Supplement No. 1.
The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for those deviations.
3.3.3 Decrees nf Subcoolina The licensee has identified this as a Type A variable; as such, Category 1 recommendations are required. The licensee's instrumentation does not have the seismic qualification recommended nor does it meet the 6
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single failure criteria. The licensee states that this is acceptable because these recommendations are not required by NUREG-0737.
We find these deviations unacceptable for Type A variables.
NUREG-0737 does not require this instrumentation to be Type A.
The licensee has determined that this instrumentation is Type A.
Therefore, the licensee should provide Category 1 channels of instrumentation for this variable.
3.3.4 Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. Thus, this instrumentation should be environmentally qualified.
The licensee identifies valves VCR-11, VCR-21, and QCM-250 as being inside containment and not qualified for a design basis event. The licensee states that the position indication for the redundant valves (VCR-10 VCR-20 and QCM-350 respectively) can be used to verify the isolation function as these are located in an accessible mild environment.
An operator can verify the valve position of any of these three redundant valves (VCR-10, VCR-20 and QCM-350); however, QCM-350 does have the appropriate indication in the control room. We find this unacceptable.
Should a single failure occur, the operator could not verify containment isolation.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49.
The licensee should therefore provide instrumentation for this variable that is environmentally qualified in l
accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97.
3.3.5 Radiation Level in Circulatino Primary Coolant i
The licensee indicates that radiation level measurements to indicate fuel cladding failure are provided by the post-accident sampling system, which is being reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3.
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The licensee has not identified the ringe of this alternate instrumentation as required b*y Section 6.2 of Supplement No. 1 of, NUREG-0737.
The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for that deviation.
3.3.6 Analysis of Primary Coolant Regulatory Guide 1.97 recommends instrumentation for this variable capable of a gamma spectrum analysis with a range of 10-6 to 10 C1/ml.
The licensee has not identified the range of this instrumenta, tion as required by Section 6.2 of Supplement No. 1 of NUREG-0737.
The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for that deviation.
3.3.7 Containment Area Radiation - Hich Ranoe Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable.
In addition, the licensee has determined that this is a Type A variable; thus Category 1 instrumentation is required.
Category 1 instrumentation is to be seismically qualified.
The licensee's instrumentation is not seismically qualified. The licensee justifies this deviation by stating that seismic qualification is not a NUREG-0737 requirement for this instrumentation.
The licensee's justification for this deviation is not acceptable.
The licensee should provide seismic qualification for this Type A instrumentation in accordance with the plant's seismic design criteria.
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3.3.8 Containment Hydroaen Concentration e Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 30 percent for Cook's ice condenser containment.
The licensee has not identified the range of the instrumentation provided for this variable.
The NRC reviewed the acceptability of this variable as part of their review of NUREG-0737. Item II.F.1.6 and found it acceptable; however, the licensee should identify the range of this instrumentation as required by Section 6.2 of Supplement No. 1 of NUREG-0737.
3.3.9 Radiation Exposure Rate Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10 to 10* R/hr. The licensee's instrumentation for I
4 this variable has a range of 10 to 10 mR/hr. The licensee states that this range is adequate to monitor plant operation.
The licensee has not shown ar. analysis of radiation levels expected for the monitor locations. The lictnsee should show that the radiation exposure rate monitors have ranges that encompass the expected radiation levels in their locations.
3.3.10 Residual Heat Removal Heat Exchanaer Outlet Temoerature Regulatory Guide 1.97 recomends instrumertation for this variable with a range of 40 to 350*F. The instrumentation provided by the licensee has a range of 50 to 400*F. Thus, the range does not meet the recomended lower limit.
This deviation is 2.5 percent of the maximum range.
Considering instrument accuracy and overall range, we consider this deviation minor and, therefore, acceptable.
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l 3.3.11 Accumulator Tank Level and Press'ure l
Regulatory Guide 1.97 recomends level instrumentation for this variable with a range from 10 to 90 percent of the tank volume.
The licensee has both narrow range (105.8 to 121.7 inches) and wide range (0 to 133 inches) instrumentation.
The wide range instruments, which will be environmentally qualified, cover 52 percent of the tank volume.
The licensee states that this is adequate to monitor the accumulator j
operation. The water level is maintained within the range of the narrow range instruments and additional reactor coolant is excluded from the accumulators by check valves.
Because the wide range instrumentation covers the entire range of water level from 0 through the normally maintained level, we find that the range of the instrumentation supplied for this variable is adequate to determine that the accumulators have discharged.
Therefore, this instrumentation is acceptable for this variable.
3.3.12 Accumulator Isolation Valve Position Regulatory Guide 1.97 recomends Category 2 instrumentation for this variable. The licensee's instrumentation is Category 3.
The licensee states that these motor-operated valves are normally left in the open position. The circuit breakers are racked out and the valves cannot change position.
Based on the licensee's justification that these valves are open and cannot change position during or following an accident, we consider the instrumentation for this variable acceptable.
3.3.13 Pressurizer Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range of top to bottom.
The licensee's instrumentation measures 10
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over 96 percent of the total pressurizer volume, not indicating the volume in the hemispherical ends of the vessel.
The level indication covers the entire cylindrical portion of the pressurizer.
Outside of the supplied instrument range, in the hemispherical vessel ends, the volume to level ratio is not linear (approximately 4 percent of the total volume). We find this deviation minor and, therefore, acceptable.
3.3.14 Pressurizer Heater Status Regulatory Guide 1.97 recommends monitoring the pressurizer heater current with Category 2 instrumentation.
The licensee monitors the heater circuit breaker position.
Section II.E.3.1 of NDREG-0737 requires a number of the pressurizer heaters to have the capability of being powered by the emergency power sources.
Instrumentation is to be provided to prevent overloading an emergency power source. Also, technical specifications are to be changed accordingly.
The Standard Technical Specifications for Westinghouse reactors, Section 4.4.3.2, require that the emergency pressurizer heater current be measured quarterly.
These emergency power supplied heaters should have the current instrumentation recommended by Regulatory Guide 1.97 or an alternate means of determining the current being drawn by the pressurizer heaters.
3.3.15 Quench Tank Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the top to the bottom of the tank.
The licensee's instrumentation covers 74 percent of the total tank volume, stating that this is adequate to safety monitor the operation of this tank.
The licensee did not relate the existing range to the range that needs to be available in the post-accident condition.
The range should be adequate to (1) ensure that the sparger is covered and that sufficient fluid volume exists to quench a design basis pressurizer release, (2) to 11
x show that sufficient gas volume exists to accept a pressurizer release without becoming overpressurized, and (3) to indicate in-leakage from th'e relief discharge system. The licensee should show that the existing quench tank level instrumentation will adequately cover the maximum expected range, or provide instrumentation with the range recommended by Regulatory Guide 1.97.
3.3.16 Steam Generator Level Regulatory Guide 1.97 recommends Category 1 wide range instrumentation for this variable with a range from the tube sheet to the separators.
Category 1 instrumentation requires Class 1E power and environmental qualification. The licensee's instrumentation has a range from 12 inches above the tube sheet to the separators.
Non-Class 1E power is used.
Environmental qualification is not provided.
At 12 inches above the tube sheet, the steam generator is essentially empty. Therefore, this deviation is minor with respect to the overall range and system accuracy. The existing range is adequate to monitor this variable during all accident and post-accident conditions.
The licensee states that this instrumentation was addressed in a NRC Safety Evaluation Report (SER) dated June 16, 1981 (Reference 7).
This SER evaluation concludes that steam generator level instrumentation must be supplied and implemented in accordance with Regulatory Guide 1.97.
The Technical Evaluation Report attached to the SER indicates that Class 1E power is used for the wide range channels.
The licensee should verify that Class 1E power is used.
Environmental qualification has been clarified by the Environmental Qualification Rule,10 CFR 50.49.
The licensee should therefore provide instrumentation for this variable that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97, and verify that Class 1E power is used in accordance with the recommendationsofhegulatoryGuide1.97.
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l 3.3.17 Containment Soray Flow
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Regulatory Guide 1.97 recomends instrumentation for this variable with a range of 0 to 110 percent of design flow.
The Cook station has upper containment spray flow instrumentation, however, the licensee monitors the spray pump discharge pressure and the containment pressure, stating that with this instrumentation, the operator will be able to determine adverse containment conditions.
The alternate instrumentation provided by the licensee sounds like a reasonable approach; however, the licensee should provide the NRC with the relationship between the pump discharge pressure and the pump flow rate as a basis for this deviation.
3.3.18 Containment Sumo Water Temperature Regulatory Guide 1.97 reconmends Category 2 instrumentation for this variable with a range of 50 to 250*F. The licensee does not have instrumentation for this variable, saying it would give no information relative to mitigating or determining the consequences of an accident.
Containment sump level, containment atmosphere temperature and containment pressure are used by the operator to determine containment conditions.
However, these will not provide a qui s'.tative measure of heat removal from containment.
This is insufficient justification for this exception.
The licensee should provide the recommended instrumentation for the functions outlined in the Regulatory Guide 1.97 or identify other instruments that provide the same information (such as the residual heat removal heat exchanger inlet temperature) and satisfy the regulatory guide.
3.3.19 Volume Control Tank Level Regulatory Guide 1.97 recomends instrumentation for this variable with a range of top to bottom.
The licensee's instrumentation has a range 13
m of 0 to 70 inches, which is stated to cover approximately 65 percent of the total tank volume.
The licensee states that this range is adequate to safely monitor the operation of this tank.
The licensee has not indicated that this instrumentation will remain on scale for all accident and post-accident conditions.
Therefore, the deviation in range is not acceptable. The licensee should either expand i
the range to that recommended by Regulatory Guide 1.97 or provide additional justification for this deviation.
3.3.20 Hiah Level Radioactive Licuid Tank Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range of top to bottom. The licensee states the range covers 84 percent of the total tank volume and that this range is sufficient to monitor the operation of this tank.
The range does not include the volume in the hemispherical ends of the vessel.
Outside of the supplied instrument range, in the hemisperical ends, the volume to level ratio is not linear (16 percent of the total volume). We find this deviation minor and, therefore, acceptable.
3.3.21 Condenser Air Removal System Exhaust--Noble Gases Regulatory Guide 1.97 recampends instrumentation for this variable with a range of 10-6 to 10 pC1/cc. The licensee's instrumentation
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has a range of 10 to 10 pC1/cc.
The licensee states that this range is adequate to monitor this exhaust stream. The licensee provided no basis for this statement.
The justification provided by the licensee for this range deviation of 2 decades is not acceptable.
The licensee should either expand the range to that recommended by the regulatory guide or show that the existing range will not be exceeded during accident and post-accident conditions.
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3.3.22 Vent from Steam Generator Safety Relief Valves Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10- to 10 pCi/cc. The licensee's instrumentation has a range of 3 to 20 x 10 pCi/cc.
The lower limit of the recommended range, 10-I to 3 pC1/cc, is not detected by the instrumentation.
The licensee provided no justification for this deviation from the recommended release assessment capabilities.
The licensee should either expand the range to that recommended by the regulatory guide or show that the existing range is adequate during all accident and post-accident conditions.
3.3.23 Plant and Environs Radioactivity 4
Regulatory Guide 1.97 recommends portable instrumentation for isotopic analysis for this variable. The licensee has not provided the information required by Section 6.2 of Supplement No. 1 of NUREG-0737.
The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for those deviations.
3.3.24 Accident Samplina (Primary Coolant. Containment Air and Sumo)
Regulatory Guide 1.97 recommends sampling and on-site analysis capability for the reactor coolant system, containment sump, emergency core cooling system pump room sumps, and other similar auxiliary building sump liquids and containment air.
The licensee's post-accident sampling system provides sampling and analyses as recommended by the regulatory guide, except for the following deviations.
o Gross activity - the range is not identified o
Gamma spectrum - the range is nct identified 15
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Baron content - the range is not identified i
o Chloride content - capacity is not provided o
pH - the range is 5 to 8 instead of 1 to 13 o
Containment air hydrogen content - capacity is not provided o
Containment air oxygen content--capacity is not provided o
Containment air gamma spectrum--capacity is not provided 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.8.3.
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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.
Neutron flux--the licensee should provide instrumentation for this variable that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.1).
2.
Reactor coolant system soluble boron concentration--the licensee should identify the range as required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the regulatory guide and justify that deviation (Section 3.3.2).
3.
Drgrees of subcooling--the licensee should provide Category 1 instrumentation for this variable (Section 3.3.3).
4.
Containment isolation valve position--the licensee should provide instrumentation for 3 remaining penetration lines that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.4).
5.
Radiation level in circulating primary coolant--the licensee should identify the range of the alternative instrumentation as required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the regulatory guide and justify that deviation (Section 3.3.5).
6.
Analysis of primary coolant--the licensee should identify the range of this instrumentation as required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the regulatory guide and justify that deviation (Section 3.3.6).
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Containment area radiation - high range--the licensee should provide seismic qualification for this instrumentation (Section 3.3.7).
8.
Containment hydrogen concentration--the licensee should identify
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the range of this instrumentation (Section 3.3.8).
9.
Radiation exposure rate--the licensee should show that the ranges of this instrumentation encompass the expected radiation levels at their locations (Section 3.3.9).
10.
Pressurizer heater status--the licensee should supply the recommended instrumentation (Section 3.3.14).
11.
Quench tank level--the licensee should either show that the existing range is adequate or provide the recommended range (Section 3.3.15).
12.
Steam generator level--the licensee should provide instrumentation for this variable that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97; the licensee shoul'd ver.ify that this
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instrumentation is supplied with Class 1E power (Section 3.3.16).
13.
Containment spray flow (lower)--the licensee should provide additional justification to support their alternate instrumentation for this variable (Section 3.3.17).
14.
Containment sump water temperature--the licensee should provide the recommended instrumentation or identify alternate instrumentation that fulfills the function of thir variable as outlined in Regulatory Guide 1.97 (Section 3.3.18).
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15.
Volume control tank level--the 1.icensee should either provide the recommended range or provide additional justification for the range deviation (Section 3.3.19).
- 16. Condenser air removal system exhaust - noble gases--the licensee
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should supply the recommended range or provide additional justification in support of the existing range (Section 3.3.21).
- 17. Vent from steam generator safety relief valves--the licensee should supply the recommended range or provide additional justification in support of the existing range (Section 3.3.22).
18.
Plant and environs radioactivity--the licensee should provide.the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation and justify any deviation identified (Section 3.3.23).
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5.
REFERENCES
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1.
NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses and Holders of Construction Permits,
" Supplement No. 1 to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
2.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durino and Followina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Reauirements. Reauirements for Emeraency Response Capability, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4.-
Indiana and Michigan Electric Company letter, M. P. Alexich to H. R. Denton, NRC, " June 12, 1984 Confirmatory Order - Status Report 28, 1985, AEP:NRC:07733.
on Regulatory Guide 1.97 Compliance," February.
5.
Indiana and Michigan Electric Company letter, M. P. Alexich to H. R. Denton, NRC, " June 12, 1984 Confirmatory Order - Final Status Report on Regulatory Guide 1.97 Compliance," October 15, 1985, AEP:NRC:07730.
6.
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 Rosearch, May 1983.
7.
NRC letter, S. A. Varga to J. Dolan, Indiana and Michigan Electric Company, June 16, 1981.
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BISUOGRAPHIC DATA SHEET EGG-NTA-7282
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Confomance to Regulatory Guide 1.97, Donald C. Cook Nuclear Plant,
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oar Division of PWR Licensing - A Preliminary Technical Office of Nuclear Reactor Regulation Evaluation Report U. S. Nuclear Regulatory Comission m amoo cava.o a--
Washington, D.C.
20555 il Suf94.
r v.or.S c1 fra.d 1 (JN emum er em This EG8G Idaho, Inc. report reviews the submittals for Unit Nos.
1 and 2 of the Donald C. Cook Nuclear Plant and identifies areas of non-conformance to Regulatory Guide 1.97.
Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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4 EGG-NTA-7282 CONFORMANCE TO REGULATORY GUIDE 1.97 DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 A. C. Udy Published June 1986 l
EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483
v ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97, Revision 3, for the Donald C. Cook Nuclear Plant, Unit Nos. I and 2 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.
FOREWORD This report is supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97," being conducted for the U.S.
Nuclear Regulatory 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.
Docket Nos. 50-315 and 50-316 TAC Nos. 51080 and 51081 li i
e CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
11 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......................................................
17 5.
REFERENCES.......................................................
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CONFORMANCE TO REGULATORY GUIDE 1.97 DONALD C. COOK NUCLEAR PLANT UNIT NOS. 1 AND 2 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 energency response capability.
These requirements have been published as Supplement No. 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Indiana and Michigan Electric Company, the licensee for the Donald C.
Cook Nuclear Plant, provided a response to Section 6.2 of the generic letter on February 28, 1985 (Reference 4). This was revised on October 15, 1985 (Reference 5). These submittals address Revision 3 of Regulatory Guide 1.97 (Reference 6).
This report provides an evaluation of the material submitted by the licensee.
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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 facijities. 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.
Redund.ance 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 matter.
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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EVALUATION The licensee provided a response to Item 6.2 of NRC Generic Letter 82-33 on February 28, 1985.
This was revised on October 15, 1985.
The response describes the licensee's position on post-accident monitoring l
instrumentation. This evaluation is based on that material.
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O.1 Adherence to Reaulatory Guide 1.97 s
l The licensee has provided a review of their post-accident monitoring instrumentation that etipares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 3.
The licensee states that in several instances, satisfactory instrumentation exists and that additional instrumentation will be installed to comply with Regulatory j
Guide 1.97, except for those instances where deviations are technically justified. The licansee has stated that all planned modifications to bring about compliance with Regulatory Guide 1.97 will be complete by the end of the Unit No. 2 refueling outage in 1989.
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.e., those variables 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.
Centrifugal charging pump flow 2.
Reactor coolant system (RCS) pressure 3.
Steam generator pressure 4
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4.
Containment sump level 5.
Steam generator level - narrow range 1
6.
Pressurizer level 7.
Containment area radiation monitor - high range 8.
Containment pressure - narrow range 9.
Auxiliary feedwater flow 10.
Refueling water storage tank level
- 11. Degrees of subcooling 1
- 12. Core exit thermocouples 13.
Reactor coolant pump breaker status 14.
Safety injection pump breaker status 15.
Safety injection pump flow 16.
Steara generator blowdown radiation l-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 TO The itcensee identified the following deviations and exceptions to Regulatory Guide 1.97.
These are discussed in the following paragraphs.
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e 3.3.1 Neutron Flux Regulatory Gude 1.97 recommends Category 1 instrumentation to monitor this variable in post-accident conditions.
Thus, this instrumentation should be environmentally qualified.
The licensee's instrumentation is not environmentally qualified.
The licensee states that this instrumentation is not needed for mitigation of loss of coolant accidents or high energy line breaks. The reactor shutdown is accomplished by the reactor SCRAM and by boric acid injection, and is verified by Category 3 instrumentation for control rod position and analysis of reactor coolant system grab samples.
i We find this position unacceptable.
The neutron flux instrumentation is necessary to observe inadvertant reactivity additions and in monitoring anticipated transients without scram (ATWS) events.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49. The licensee should therefore provide instrumentaticn that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97.
l 3.3.2 Reactor Coolant System Soluble Boron Concentration Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 6000 parts per million.
The licensee identifies the post-accident sampling system as fulfilling this recommendation.
The licensee did not provide the range of the instrumentation as required by Section 6.2 of NUREG-0737, Supplement No. 1.
The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for those deviations.
3.3.3 Decrees of Subcoolina The licensee has identified this as a Type A variable; as such, Category 1 recommendations are required.
The licensee's instrumentation does not have the seismic qualification recommended nor does it meet the 6
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single failure criteria. The licensee sta.tes that this is acceptable because these recommendations are not required by NUKEG-0737.
he find these deviations unacceptable for Type A variables.
NUREG-O37 does not require this instrumentation to be Type A.
The licensee has determined that this instrumentation is Type A.
Therefore, the licensee should provide Category 1 channels of instrumentation for this variable.
3.3.4 Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category 1 instrumentation for this I
variable.
Thus, this instrumentation should be environmentally qualified.
The licensee identifies valves VCR-11, VCR-21, and QCM-250 as being inside containment and not qualified for a design basis event.
The licensee states that the position indication for the redundant valves (VCR-10, VCR-20 and QCM-350 respectively) can be used to verify the isolation function as these are located in an accessible mild environment.
An operator can verify the valve position of any of these three redundant valves (VCR-10, VCR-20 and QCM-350); however, QCM-350 does have the appropriate indication in the control room. We find this unacceptable.
Should a single failure occur, the operator could not verify containment isolation.
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Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49.
The licensee should therefore provide instrumentation for this variable that is environmentally qualified in l-accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97.
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3.3.5 Radiation Level in Circulatina Primary Coolant The licensee indicates that radiation level measurements to indicate fuel cladding failure are provided by the post-accident sampling system, which is being reviewed by the NRC as part of their review of NUREG-0737, Item 1I.8.3.
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s The licensee has not identified the ringe of this alternate instrumentation as required by Section 6.2 of Supplement No. 1 of, NUREG-0737.
The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for that deviation.
3.3.6 Analysis of Primary Coolant Regulatory Cuide 1.97 reccamends instrumentation for this variable capable of a gamma spectrum analysis with a range of 10-6 to 10 Ci/ml.
The licensee has not identified the range of this instrumentation as required by Section 6.2 of Supplement No. 1 of NUREG-0737.
The licensee should provide the required information, identify any 1
deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for that deviation.
3.3.7 Containment Area Radiation - Hioh Rance Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable.
In addition, the licensee has determined that this is a Type A variable; thus Category 1 instrumentation is required.
Category 1 instrumentation is to be seismically qualified.
The licensee's instrumentation is not seismically qualified.
The licensee justifies this deviation by stating that seismic qualification is not a NUREG-0737 requirement for this instrumentation.
The licensee's justification for this deviation is not acceptable.
The licensee should provide seismic qualification for this Type A instrumentation in accordance with the plant's seismic design criteria.
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3.3.8 Containment Hydrocen Concentration e
Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 30 percent for Cook's ice condenser containment. The licensee has not identified the range of the instrumentation provided for this varia*1e.
The NRC reviewed the acceptability of this variable as part of their review of NUREG-0737, Item II.F.1.6 and found it acceptable; however, the licensee should identify the range of this instrumentation as required by Section 6.2 of Supplement No. 1 of NUREG-0737.
3.3.9 Radiation Exoosure Rate Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10~ to 10* R/hr.
The licensee's instrumentation for j
this variable has a range of 10 to 10* mR/hr.
The licensee states i
that this range is adequate to monitor plant operation.
The licensee has not shown an analysis of radiation levels expected l
for the monitor locations.
The licensee should show that the radiation i
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exposure rate monitors have ranges that encompass the expected radiation l
1evels in their locations.
3.3.10 Residual Heat Removal Heat Exchanaer Outlet Temperature Regulatory Guide 1.97 reconsnends instrumentation for this variable with a range of 40 to 350*F. The instrumentation provided by the licensee l
has a range of 50 to 400*F.
Thus, the range does not meet the reconsnended l
lower limit.
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This deviation is 2.5 percent of the maximum range.
Considering instrument accuracy and overall range, we consider this deviation minor and, therefore, acceptable.
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3.3.11 Accumulator Tank Level and Press'ure Regulatory Guide 1.97 recommends level instrumentation for this variaole with a range from 10 to 90 percent of the tank volume. The licensee has both narrow range (105.8 to 121.7 inches) and wide range (0 to 133 inches) instrumentation. The wide range instruments, which will be environmentally qualified, cover 52 percent of the tank vnlume.
The licensee states that this is adequate to monitor the accumulator operation. The water level is maintained within the range of the narrow range instruments and additional reactor coolant is excluded from the accumulators by check valves.
Because the wide range instrumentation covers the entire range of water level from 0 through the normally maintained level, we find that the range of the instrumentation supplied for this variable is adequate to determine that the accumulators have discharged.
Therefore, this:
instrumentation is acceptable for this variable.
l 3.3.12 Accumulator Isolation Valve Position l
l Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation is Category 3.
The licensee states that these motor-operated valves are normally left in the open position. The circuit breakers are racked out and the valves cannot char.ge position.
Based on the licensee's justification that these valves are open and cannot change position during or following an accident, we consider the i
instrumentation for this variable acceptable.
3.3.13 Pressurizer Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range of top,to bottom.
The licensee's instrumentation measures 10
i over 96 percent of the total pressurizer volume, not indicating the volume in the hemispherical ends of the vessel.
The level indication covers the entire cylindrical portion of the pressurizer.
Outside of the supplied instrument range, in the hemispherical vessel ends, the volume to level ratio is not linear (approximately 4 percent of the total voluss). We find this deviation minor and, therefore, acceptable.
3.3.14 Pressurizer Heater Status Regulatory Guide 1.97 recommends monitoring the pressurizer heater I
, current with Category 2 instrumentation.
The licensee monitors the heater circuit breaker position.
Section II.E.3.1 of NUREG-0737 requires a number of the pressurizer heaters to have the capability of being powered by the emergency power sources.
Instrumentation is to be provided to prevent overloading an emergency power source. Also, technical specifications are to be changed accordingly. The Standard Technical Specifications for Westinghouse reactors Section 4.4.3.2, require that the emergency pressurizer heater current be measured quarterly.
These emergency power supplied heaters l
should have the current instrumentation recommended by Regulatory Guide 1.97 or an alternate means of determining the current being drawn by the pressurizer heaters.
3.3.15 Quench Tank Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the top to the bottom of the tank.
The licensee's instrumentation covers 74 percent of the total tank volume, stating that this is adequate to safety monitor the operation of this tank.
The licensee did not relate the existing range to the range that needs to be available in the post-accident condition.
The range should be adequate to (1) ensure that the sparger is covered and that sufficient fluid volume exists to quench a design basis pressurizer release. (2) to 11
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show that sufficient gas volume exists to a~ccept a pressurizer release without becoming overpressurized, and (3) to indicate in-leakage from the relief discharge system. The licensee should show that the existing quench tank level instrumentation will adeq:Jately cover the maximum expected range, or provide instrumentation with the range recommended by Regulatory Guide 1.97.
3.3.16 Steam Generator Level 1
Regulatory Guide 1.97 recommends Category 1 wide range instrumentation for this variable with a range from the tube sheet to the separators.
Category 1 instrumentation requires Class 1E power and environmental qualification. The licensee's instrumentation has a range from 12 inches above the tube sheet to the separators. Non-Class 1E power is used.
Environmental qualification is not provided.
At 12 inches above the tube sheet, the steam generator is essentially empty. Therefore, this deviation is minor with respect to the overall range and system accuracy. The existing range is adequate to monitor this variable during all accident and post-accident conditions.
The licensee states that this instrumentation was addressed in a NRC Safety Evaluation Report (SER) dated June 16, 1981 (Reference 7).
This SER l
evaluation concludes that steam generator level instrumentation must be supplied and implemented in accordance with Regulatory Guide 1.97.
The Technical Evaluation Report attached to the SER indicates that Class 1E power is used for the wide range channels.
The licensee should verify that Class 1E power is used.
Environmental qualification has been clarified by the Environmental Qualification Rule, 10 CFR 50.49. The licensee should therefore provide instrumentation for this variable that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97, and verify that Class 1E power is used in accordance with the reconsnendations oflegulatory Guide 1.97.
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3.3.17 Containment Sorav Flow y
Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 110 percent of design flow.
The Cook station has l
upper containment spray flow instrumentation, however, the licensee monitors the spray pump discharge pressure and the containment pressure.
stating that with this instrumentation, the operator will be able to determine adverse containment conditions.
The alternate instrumentation provided by the licensee sounds like a reasonable approach; however, the licensee should provide the NRC with the relationship between the pump discharge pressure and the pump flow rate as a basis for this deviation.
3.3.18 Containment Sumo 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, saying it would give no information relative to mitigating or determining the consequences of an accident.
Containment sump level, containment atmosphere temperature and containment pressure are used by the operator to determine conta! ament conditions.
However, these will not provide a quantitative measure of heat removal from containment.
This is insufficient justification for this exception.
The licensee should provide the recommended instrumentation for the functions outlined in the Regulatory Guide 1.97 or identify other instruments that provice the same information (such as the residual heat removal heat exchanger inlet temperature) and satisfy the regulatory guide.
3.3.19 Volume Control Tank Level i
Regulatory Guide 1.97 recommends instrumentation for this variable with a range of top to bottom.
The licensee's instrumentation has a range 13
of 0 to 70 inches, which is stated to cover approximately 65 percent of the total tank volume.
The licensee states that this range is adequate to safely monitor the operation of this tank.
The licensee has not indicated that this instrumentation will remain on scale for all accident and post-accident conditions.
Therefore, the l
deviation in range is not acceptable. The licensee should either expand the range to that recommended by Regulatory Guide 1.97 or provide additional justification for this deviation.
3.3.20 Hiah Level Radioactive Liould Tank Level Regulatory Guide 1.97 reconnends instrumentation for this variable with a range of top to bottom. The licensee states the range covers 84 percent of the total tank volume and that this range is sufficient to monitor the operation of this tank.
The range does not include the volume in the hemispherical ends of the vessel.
Outside of the supplied instrument range, in the hemisperical ends, the volume to level ratio is not linear (16 percent of the total volume). We find this deviation minor and, therefore, acceptable.
3.3.21 Condenser Air Removal System Exhaust--Noble Gases Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10-6 to 10 pCi/cc.
The licensee's instrumentation 5
has a range of 10~ to 10 pC1/cc.
The licensee states that this range is adequate to monitor this exhaust stream.
The licensee provided no basis for this statement.
The justification provided by the licensee for this range deviation of 2 decades is not acceptable. The licensee should either expand the range to that recommended by the regulatory guide or show that the existing range will not be exceeded during accident and post-accident conditions.
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3.3.22 Vent from Steam Generator Safety Relief Valves Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10-I to 10 pC1/cc. The licensee's instrumentation 3
has a range of 3 to 20 x 10' pC1/cc. The lower limit of the recommended range, 10~ to 3 pC1/ce, is not detected by the instrumentation. The licensee provided no justification for this deviation from the recommended release assessment capabilities.
The licensee should either expand the range to that recommended by the regulatory guide or show that the existing range is adequate during all accident and post-accident conditions.
3.3.23 Plant and Environs Radioactivity Regulatory Guide 1.97 recommends portable instrumentation for isotopic analysis for this variable. The licensee has not provided the information required by Section 6.2 of Supplement No. 1 of NUREG-0737.
The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for those de'viations, t
l 3.3.24 Accident Samplina (Primary Coolant. Containment Air and Sumo)
Regulatory Guide 1.97 recommends sampling and on-site analysis capability for the reactor coolant system, containment sump, emergency core cooling system pump room sumps, and other similar auxiliary building sump liquids and containment air.
The licensee's post-accident sampling system provides sampling and analyses as recommended by the regulatory guide, except for the following deviations.
o Gross activity - the range is not identified o
Gamma spectrum - the range is not identified 15
o Boron content - the range is not identified o
Chloride content - capacity is not provided o
pH - the range is 5 to 8 instead of 1 to 13 o
Containment air hydrogen content - capacity is not provided o
Containment air oxygen content--capacity is not provided o
Containment air gamma spectrum--capacity is not provided 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.8.3.
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4.
CONCL.USIONS 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 1
exceptions:
1.
Neutron flux--the licensee should provide instrumentation for this variable that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.1).
2.
Reactor coolant system soluble boron concentration--the licensee should identify the range as required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the regulatory guide and justify that deviation (Section 3.3.2).
3.
Degrees of subcooling--the licensee should provide Category 1 instrumentation for this variable (Section 3.3.3).
4.
Containment isolation valve position--the licensee should provide
. instrumentation for 3 remaining penetration lines that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.4).
5.
Radiation level in circulating primary coolant--the licensee should identify the range of the alternative instrumentation as required by Section 6.2 of NUREG-0737, Supplement No.1, identify any deviation from the regulatory guide and justify that a
deviation (Section 3.3.5).
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Analysis of primary coolant--the licensee should identify the range of this instrumentation as required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation from the regulatory guide and justify that deviation (Section 3.3.6).
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7.
Containment area radiation - high range--the licensee should provide seismic qualification for this instrumentation (Section 3.3.7).
8.
Containment hydrogen concentration--the licensee should identify
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the range of this instrumentation (Section 3.3.8).
9.
Radiation exposure rate--the licensee should show that the ranges of this instrumentation encompass the expected radiation levels at their locations (Section 3.3.9).
10.
Pressurizer heater status--the licensee should supply the recommended instrumentation (Section 3.3.14).
11.
Quench tank level--the licensee should either show that the existing range is adequate or provide the recommended range (Section 3.3.15).
12.
Steam generator level--the licensee should provide instrumentation for this variable that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97; the licensee should verify that this
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instrumentation is supplied with Class 1E power (Section 3.3.16).
13.
Containment spray flow (lower)--the licensee should provide additional justification to support their alternate j
instrumentation for this variable (Section 3.3.17).
14.
Containment sump water temperature--the licensee should provide the reconnended instrumentation or identify alternate instrumentation that fulfills the function of this variable as outlined in Regulatory Guide 1.97 (Section 3.3.18).
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15.
Volume control tank level--the licensee should either provide the recommended range or provide additional justification for the range deviation (Section 3.3.19).
- 16. Condenser air removal system exhaust - noble gases--the licensee should supply the recommended range or provide additional justification in support of the existing range (Section 3.3.21).
- 17. Vent fram steam generator safety relief valves--the licensee should supply the recommended range or provide additional justification in support of the existing range (Section 3.3.22).
18.
Plant and environs radioactivity--the licensee should provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1, identify any deviation and justify any deviation identified (Section 3.3.23).
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5.
REFERENCES 1.
NRC letter, O. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses and Holders of Construction Permits,
" Supplement No. 1 to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
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2.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Reauirements. Reauirements for Emeroency Response Capability, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4.
Indiana and Michigan Electric Company letter, M. P. Alexich to H. R. Denton, NRC, " June 12, 1984 Confirmatory Order - Status Report on Regulatory Guide 1.97 Compliance," February 28, 1985, AEP:NRC:0773J.
5.
Indiana and Michigan Electric Company letter, M. P. Alexich to H. R. Denton, NRC, " June 12, 1984 Confirmatory Order - Final Status Report on Regulatory Guide 1.97 Compliance," October 15, 1985, AEP:NRC:07730.
6.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Ourina and Followina an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory i
l Research, May 1983.
7.
NRC letter, S. A. Varga to J. Dolan, Indiana and Michigan Electric Company, June 16, 1981.
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Confomance to Regulatory Guide 1.97,
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Donald C. Cook Nuclear Plant, Unit Nos. I and 2 June 1986
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- 10..fo.a.oneaso on et2.Teose ss.as..sec as.au.so.oom is.ammed.Casse staTvPeorm pont Division of PWR Licensing - A Preliminary Technical l
Office of Nuclear Reactor Regulation Evaluation Rcport U. S. Nuclear Regulatory Commission
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I&.Sarm.CT,J umuser e This EG8G Idaho, Inc. report reviews the submittals for Unit Nos.
1 and 2 of the Donald C. Cook Nuclear Plant and identifies areas of non-confomance to Regulatory Guide 1.97.
Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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