ML20207B660
| ML20207B660 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/30/1986 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20207B665 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7150, TAC-51071, NUDOCS 8612170085 | |
| Download: ML20207B660 (31) | |
Text
EGG-NTA -7150 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97 BEAVER VALLEY POWER STATION, UNIT NO. 1 Docket No. 50-334 J. W. Stoffel Published November 1986 Idaho National Engineering Laboratory 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-AC07-761001570 FIN No. A6483 84tanaD86M
ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Revision 2 of Regulatory Guide 1.97 for Unit No. 1 of the 8eaver Valley Power Station and identifies areas of nonconformance to the regulatory guide. Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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1 Docket No. 50-334 TAC No. $1071 11
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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 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 No. 50-334 TAC No. 51071 i
CONTENTS A8STRACT .............................................................. 11 FOREWORD .............................................................. 111
- 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 ...................................................... 23
- 5. REFERENCES ....................................................... 25 iv
O CONFORMANCE TO REGULATORY GUIDE 1.97 BEAVER VALLEY POWER STATION. UNIT NO. 1
- k. INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency response capability. These requirements have been published as Supplement No. 1 to NUREG-0737, "TMI Action Plan Requirements" (Raference 3).
Duquesne Light, the licensee for Unit No. 1 of the Beaver Valley Power Station, responded to Section 6.2 of the generic letter with a letter dated November 29, 1985 (Reference 4). Additional information was submitted on October 13, 1986 (Reference 5). These provide a review of the instrumentation provided for Regulatory Guide 1.97.
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
- 4. Quality assurance
- 5. Redundance and sensor location
- 6. Power supply
- 7. Location of display
- 8. Scheoule of installation or upgrade.
The submittal should identify any deviations for the recommendations of Regulatory Guide 1.97 and provide supporting justification or alternatives for the deviations identified.
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, this report l
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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 Generic Letter 82-33 dated November 29, 1985. Additional information was submitted on October 13, 1986. This evaluation is based on these submittals.
3.1 Adherence to Reaulatory Guide 1.97 .
The licensee states that Unit No. 1 of the Beaver Valley Power Station meets the intent of Regulatory Guide 1.97 with their presently installed instrumentation. For the instrumentation that is not in strict conformance, the licensee provided details and justification for deviating. 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 Type 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. Reactor coolant system (RCS) cold leg water temperature
- 2. RCS hot leg water temperature
- 3. RCS pressure
- 4. Containment sump water level -
- 5. Containment pressure
- 6. Containment hydrogen concentration
- 7. Containment area radiation 4
- 8. Pressurizer level
- 9. Refueling water storage tank level
- 10. Steam generator level
- 11. Steam generator pressure
- 12. Auxiliary feedwater flow
- 13. Primary plant demineralized water storage tank level.
This instrumentation meets the Category 1 recommendations consistent with the requirements for Type A variables, except as noted in Section 3.3.
3.3 Exceptions to Regulatory 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 specifies environmentally qualified instrumentation for this variable. The instrumentation provided for this variable includes detectors that are not environmentally qualified. The licensee states that borating the primary system after ar. accident in accordance with the emergency operating procedures ensures that adequate shutdown margin is maintained. In addition, a loss of shutdown margin would be reflected in a heatup of the RCS, which is monitored by qualified instruments. However, these alternates are not a direct measure of reactor power.
This is insufficient justification for this exception. Environmental qualification has been clarified by the Environmental Qualification Rule, 5
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.
3.3.2 Reactor Coolant System (RCS) Soluble Baron Concentration Regulatory Guide 1.97 recommends that continuous indication for this ,
variable be provided in the control room. The licensee uses the post-accident sampling system to monitor this variable. The licensee states that in-line analyzers are provided for direct measurement of boron from the post-accident RCS sample flow.
The licensee takes exception to Regulatory Guide 1.97 and states that post-accident sampling capability is designed to meet Item II.B.3 in NUREG-0737. 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 Reactor Coolant System Cold and Hot Leo Water Temperature Revision 2 of Regulatory Guide 1.97 recommends instrumentation for these variables with ranges of 50 to 750*F. The licensee has supplied instrumentation for these variables with ranges for 0 to 700*F.
Revision 3 of Regulatory Guide 1.97 (Reference 6) recommends a range of 50 to 700*F for these variables. The instrumentation supplied by the licensee meets this range. Therefore, the range supplied by the licensee
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l for these variables is acceptable.
3.3.4 Core Exit Temperature -
Regulatory Guide 1.97 recommends instrumentation for this variable that is environmentally and seismically qualified and that has a Class 1E power supply. The licensee has deviated from these recommendations and states l that this variable is one of the elements of the inadequate core 6
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cooling (ICC) instrumentation system. The licensee refers to Item II.F.2 of NUREG-0737 and states that their proposed ICC system was presented to the NRC on April- 24, 1984.
The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737, Item II.F.2.
3.3.5 Coolant Level in Reactor Regulatory Guide 1.97 recommends instrumentation for this variable that is environmentally and seismically qualified and that monitors from the bottom of the core to the top of the vessel. The licensee has deviated from these recomnendations and states that this variable is one of the elements of the inadequate core cooling (ICC) instrumentation system. The licensee's proposed IEE system was presented to the NRC on April 24, 1984.
l The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737, Item II.F.2.
3.3.6 Dearees of Subcoolina Regulatory Guide.1.97 recommends instrumentation for this variable that is environmentally qualified and that has a highly reliable power supply.
The licensee has deviated from these recommendations and states that this variable is one of the elements of the inadequate core cooling (ICC) instrumentation system. The licensee's proposed ICC system was presented to the NRC on April 24, 1984.
The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737 Item II.F.2.
3.3.7 Containment Sump Water Level Regulatory Guide 1.97, Revision 2, recommends wide range instrumentation for this variable that monitors from the bottom of containment to 600,000 gallon level equivalent. The licensee has 7
indication from 0 to 90 inches (wide range) and considers this to be adequate based on plant specific requirements for operator monitoring as described in their emergency operating procedures.
Regulatory Guide 1.97, Revision 3, recommends a plant specific range .
.for this variable. The instrumentation supplied by the licensee meets their plant specific requirements and is, therefore, acceptable. ,
3.3.8 Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has identified some areas that are not in strict conformance with the regulatory guide.
A. Electrical redundancy--the containment isolation valves in series which do not have electrically redundant position indication, within a single train of equipment.
The licensee states that this arrangement of valve position indication is for the two hydrogen analyzers, which are on separate trains and redundant to each other. The valve position indications for one analyzer are, therefore, correspondingly on the same train, Train A, and those for the other analyzer are on Train B. This arrangement is necessary to maintain the redundancy of one analyzer to the other.
Based on the justification provided, we find that the licensee deviates from a strict interpretation of the Category 1, redundancy recommendation.
Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory guide. Therefore, we find that the instrumentation provided is acceptable. .
B. Position indication not environmentally qualified
- l. Valves outside containment i
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The licensee lists 43 containment isolation valves outside containment which do not have environmentally qualified position indication. The licensee should certify that the position indication instrumentation is in a mild environment as defined in 10 CFR 50.49, or upgrade the instrumentation in conformance with 10 CFR 50.49. (See Note 1)
- 2. Valves inside containment The licensee lists 12 containnent isolation valves inside containment which do not have environmentally qualified position indication. The licensee should upgrade this instrumentation in c,onformance with 10 CFR 50.49 (See Note 1)
NOTE 1. The licensee has indicated that 6 of the containment isolation valves outside containment, and 2 inside containment are in a closed or sealed system. The licensee should confirm the validity and significance of this. If the valves are in a " closed system" as defined in General Design Criteria 57 (Appendix A of 10 CFR 50) the licensee should descrine how the " system" satisfies the definition.
C. Containment isolation valves which have no control room indication--the licensee identifies thirty-three containment isolation valves that do not have control room indication. The licensee states that the normal arrangenent for all the valves is shut, and surveillance procedures verify the valve position on a routine basis.
Since the containment isolation valves are shut and a change of position does not occur for an accident condition we conclude that the
. existing configuration is acceptable.
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3.3.9 Radiation Level in Circulatina Primary Coolant The licensee has instrumentation to monitor this variable, however it is not Category 1. The licensee considers this deviation acceptable since the post-accident sampling system, which is being reviewed by the NRC as
,part of their review of NUREG-0737, Item II.B. is used as back-up instrumentation. ,
Based on the justification .and the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this i variable is adequate and, therefore, acceptable.
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3.3.10 Effluent Radioactivity--Noble Gas from the Condenser Air Removal System Exhaust to 10- pCi/cc
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Regulatory Guide 1.97 recommends a range of 10 for this variable. The licensee has provided instrumentation with a range of 2.85 x 10' to 2.85 pCi/cc. The licensee considers this range l
adequate and states that the condenser air ejector vent monitor is not the final point of discharge.
We conclude that the range provided for this variable is adequate because the discharge is directed to a common plant vent.
3.3.11 Rjtdiation Exposure Rate (inside buildinas or areas-->
Regulatory Guide 1.97, Revision 2, recommends instrumentation for this variable as a Type C variable. Regulainry Guide 1.97, Revision 3, has eliminated this Type C variable.
The licensee has described the instrumentation available for this variable. Since instrumentation for this variable, for indication of breach, has been deleted in Regulatory Guide 1.97, Revision 3, we find the provided instrumentation acceptable.
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. 3.3.12 Residual Heat Removal (RHR) System Flow Regulatory Guide 1.97 recommends environmentally qualified instrumentation for this variable. The licensee has provided instrumentation that is not environmentally qualified and justifies this deviation by stating that they are Itcensed for and designed for hot shutdown. Therefore, the licensee states that a safety-related path to obtain cold shutdown is not required.
The existing instrumentation is not acceptable. The Environmental Qualification Rule 10 CFR 50.49 is not limited to Class 1E or to safe-shutdown equipment. The environmental qualification rule specifically refers to post-accident monitoring. The licensee should therefore provide instrumentation for this variable that is environmentally qualified in accordance with 10 CFR 50.49 and Regulatory Guide 1.97.
3.3.13 RHR Heat Exchanaer Outlet Temperature Regulatory Guide 1.97, Revision 2, recommends environmentally qualified instrumentation with a range of 32 to 350*F to monitor this variable. The licensee has provided instrumentation with a range of 50 to 400*F that is not environmentally qualified. The licensee's justification for the range deviation is that Regulatory Guide 1.97, Revision 3, increased the minimum
! indicated temperature to 40*F. The 50*F that is provided envelopes the lowest expected RHR heat exchanger outlet temperature and is not significantly different from.the 40*F recommended.
This deviation is less than three percent of the maximum recommended range. Considering instrumentation accuracy, and overall range, we consider this deviation minor and, therefore, acceptable.
The licensee's justification for the environmental qualification deviation is that they are licensed for and designed for hot shutdown.
Therefore, the licensee states that a safety-relatad path to obtain cold shutdown is not required.
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The existing instrumentation is not acceptable. The Environmental Qualification Rule 10 CFR 50.49 is not limited to Class IE or to safe-shutdown equipment. The environmental qualification rule specifically refers to post-accident monitoring. The licensee should upgrade the instrumentation for this variable in accordance with 10 CFR 50.49 and Requlatory Guide 1.97.
3.3.14 Accumulator Tank Level and Pressure Regulatory Guide 1.97 recommends environmental qualification for the tank level and pressure indication and a level range of 10 to 90 percent.
The licensee has level instrumentation for this variable that covers the equivalent tank volume of 7145 to 7981 gallons that envelopes the range required by the technical specifications. Neither instrument, however is environmentally qualified. The licensee states that the accumulators are a passive safety feature that will perform their design function in the total absence of an actuation signal or power source. The licensee further states that the emergency operating procedures do not require either the accumulator tank level or pressure to be monitored during or after an accident.
The existing pressure and level instrumentation is not acceptable. An environmentally qualified instrument is necessary to monitor the status of these tanks. The licensee should designate either level or pressure as the key variable to determine accumulator discharge and provide instrumentation, for that variable, that meets the requirements of 10 CFR 50.49. If accumulator level is selected as the key variable, then the range shculd be expanded to meet the regulatory guide recommendation.
3.3.15 Boric Acid Chancing Flow ,
Regulatory Guide 1.97 recommends Category 2 instrumentation for this .
variable. The licensee's instrumentation is Category 3. The licensee states that boric acid changing flow is not used as a post-accident safety 12
l system at this station. The licensee has designated high head safety injection flow and low head safety injection flow as'the safety injection variables monitored.
Because this is not a safety injection flow at this station, we find that this instrumentation is acceptable.
3.3.16 Flow in Low Pressure Iniettion System Regulatory Guide 1.97 recommends that the flow indication in the low pressure injection system be environmentally qualified. The licensee has provided instrumentation for this variable that is not environmentally qualified and submitted the following justification for this deviation.
There are two separate low pressure safety injection subsystems, which provide long-term reactor core decay heat removal. In addition to these redundant trains the licensee identifies RCS pressure, changing /high head safety injection flow and pump ammeter indications, RCS subcooling, and pressurizer level indication as backup instrumentation that the operator can use to determine the operating status of the low pressure injection system. We find this justification unacceptable. Category 2 instrumentation is necessary to directly indicate this flow.
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.
3.3.17 Refuelina Water Storace Tank (RWST) level Regulatory Guide 1.97 recommends instrumer.tation with a range from the top to the bottom of this tank. The licensee has provided a range that monitors from twelve inches off the bottom to the top of the cylindrical portion of the tank (51 of the approximately 57 feet). The licensee states that the RWST level instrumentation provides the indication needed during emergency conditions and switchover from the injection to recirculation mode.
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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.
3.3.18 Pressurizer Level Regulatory Guide 1.97 recommends level indication from the top to the bottom of the pressurizer. The licensee has provided instrumentation that monitors the height of the cylindrical portion of the pressurizer and does not include the hemispherical ends. The licensee states that the existing range is adequate to evaluate system conditions and to initiate manual operator actions for accident conditions.
1 Outside of the supplied instrument range, in the hemispherical vessel ends, the volume to level ratio is not linear (approximately 10 percent of the total volume). We find this deviation minor and, therefore, acceptable.
3.3.19 Pressurizer Heater Status Regulatory Guide 1.97 recommends monitoring the pressurizer heater electric. current with Category 2 instrumentation. The licensee monitors the heater circuit breaker position. The licensee states that this instrumentation is adequate.
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. These emergency power supplied heaters should have the current instrumentation recommended by Regulatory Guide 1.97 or an
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alternate means of determining the current being drawn by the pressurizer heaters.
3.3.20 Quench Tank Level Regulatory Guide 1.97 recommends instrumentation with a range from the l
l top to the bottom of this tank for this variable. The licensee has l 14
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instrumentation that reads 0 to 100 percent but does not cover the full
. recommended range. The licensee states that annunciation is provided when the level reaches a high level of 78 percent span or a low level of 66 percent span, Upon receipt of either alarm the level is adjusted to 72 percent of span. The licensee considers the existing range adequate i
based on this control range and the design provisions for the tank.
The licensee did not relate the existing range to the range that needs to be available in a post-accident condition. The licensee should show that the existing quench tank instrumentation will adequately cover the maximum expected range, or provide instrumentation with the range recommended by Regulatory Guide 1.97.
3.3.21 Quench Tank Temperature Regulatory Guide 1.97 recommends a range of 50 to 750*F for this variable. The licensee has provided temperature indication from -
50 to 350*F. The licensee states that 350*F is the design temperature of
, the tank and would not be exceeded during accident conditions due to the tank rupture disk relief pressure of 85
- 5 psig.
The range supplied by the licensee covers the anticipated requirements
! for normal operation, anticipated operational occurrences and accident conditions. This range relates to the tank's rupture disk and the 85 psig tank design pressure that limits the temperature of the tank contents to
, saturated steam conditions under 350*F. Thus, we find this deviation from i the regulatory guide acceptable.
3.3.22 Steam Generator Level 4
Regulatory Guide 1.97 recommends instrumentation for this variable, with a range from the tube sheet to the separator. The licensee has provided instrumentation with a range from 12 inches above the top of the tube sheet to a point above the separators. The licensee states that during accident conditions, operator action is based on the region from 5 to 50 percent of provided range.
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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.
3.3.23 Condensate Storaae Tank Water Level 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 Primary Plant Demineralized Water Storace Tank (DWST) Level Regulatory Guide 1.97 states that if the condensate storage tank is not the primary source of auxiliary feedwater (AFW) then whatever is should be listed and be Category 1. From the licensee's submittal we assume that the primary plant DWST is the primary source of AFW. The licensee has not met the redundancy requirement for the primary plant DWST in that the instruments are powered from the same vital ac bus.
We find this deviation unacceptable for Type A variables. The licensee has determined that this instrumentation is Type A. Therefore, the licensee should provide Category 1 instrumentation channels for this variable.
3.3.25 Containment Soray Flow Regulatory Guide 1.97 recommends instrumentation to monitor this variable. The licensee does not have direct indication of spray flow.
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However, alternate instrumentation is available in the control room to provide the essential information.
- 1. Quench spray (QS) low flow alarm
- 2. QS and recirculation spray (RS) pump motor circuit breaker positions.
- 3. QS and RS pump motor current
- 4. QS anc i pump discharge pressure
- 5. QS and RS valve position indication
- 6. Containment pressure
- 7. Refueling water storage tank level
- 8. River water flow to RS heat exchangers.
The alternate instrumentation provided by the licensee is adequate to monitor this variable. Therefore, we find this deviation acceptable.
3.3.26 Heat Removal by the Containment Fan Heat Removal System The licensee has not provided the information required by Section 6.2 l of Supplement No.1 of NUREG-0737 for this variable.
l The licensee should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification or alternatives for those deviations.
3.3.27 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a '
range of 40 to 400*F for this variable. The licensee has supplied
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I Category 3 instrumentation with a range of 0 to 300*F. The licensee states that the containment atmosphere temperature is not a key variable for accident monitoring; that the key variable for monitoring containment
, cooling is containment pressure indication, which is monitored by Category 1 instrumentation; and that the containment atmosphere temperature is a backup variable for reactor building accident monitoring.
l We find that the licensee's application of Category 3 backup instrumentation is in accordance with the regulatory guide. However, the licensee should justify the range and show that it will remain on scale for post-accident conditions, or provide the recommended range.
- 3.3.28 Letdown Flow-Out ,
- Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided Category 3 instrumentation. The licensee states that the letdown line is isolated as a result of a safety injection signal and is not required to function during an accident.
I As this variable is not utilized in conjunction with a safety system,
( we find that the instrumentation provided is acceptable.
3.3.29 Volume Control Tank (VCT) Level Regulatory Guide 1.97 recompends that the VCT level instrumentation j measure from the top to the bottom of the tank. The licensee has provided instrumentation that monitors the cylindrical section of the tank and not the hemispherical heads. The licensee states that this range will accommodate all normal design flow. In additions, the tank is isolated as a
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result of a safety injection signal. .
Outside of the supplied instrument range, in the hemispherical vessel ends, the volume to level ratio is not linear. We find this deviation minor and, therefore, acceptable.
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3.3.30 Component Coolina Water (CCW) Temperature to Engineered Safety i Features (ESF) System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided instrumentation that, except for environmental qualification, is Category 2. The licensee states that
'although the CCW subsystem normally supplies water to the RHR heat exchangers and fuel pool heat exchangers, it is not used for accident purposes and is not considered part of the ESF as discussed in Section 9.4 of the Updated Final Safety Analysis Report.
4 This is insufficient justification for this exception. 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.
> The licensee has not provided the information required by Section 6.2 i 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.
3.3.32 Hich Level Radioactive Liouid Tank Level i
Regulatory Guide 1.97 recommends instrumentation that monitors from the top to the bottom of the tank. The licensee has instrumentation with the .
j level transmitter top eight inches above the hemispherical bottom of the
. tank. The licensee does not consider this deviation significant.
This range is adequate to indicate the storage volume during all i accident and post-accident conditions. Therefore, this deviation is -
acceptable.
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l l 3.3.33 Radioactive Gas Holdup Tank Pressure l
l Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 150 percent of design pressure. The instrumentation provided has a range of 0 to 100 psig (design pressure). The licensee
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states that if 100 psig is reached in the tank, a pressure controller will relieve the gas to the release system. The pressure controller is backed up by a rupture disk that will relieve at 110 psig.
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l The licensee indicates that these tanks have a design pressure of l
100 psig. A pressure controller and rupture disks are provided to keep the pressure from exceeding 110 psig. Based on this, we find that the licensee should re-range the instrumentation to O to 110 psig.
3.3.34 Emeroency Ventilation Damper Position Regulatory Guide 1.97 recommends control room position indication for the emergency ventilation damper position. The licensee states that there are three emergency air supply fan discharge dampers for the control areas, l
that do not have position indication in the control room. The licensee states that when these fans are started they open their own discharge
- dampers. Fan control switches with indicating lights are in the control room along with a manometer that provides the operator with positive indication of the operating status of the supply dampers and the air supply.
Based on the licensee's description of this emergency control room air supply system with the alternate instrumentation in the control room to determine proper operation, we conclude that the purpose of this variable is met. Therefore, we find this instrumentation acceptable.
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l 3.3.35 Radiation Exposure Rate l
- Regulatory Guide 1.97 recommends instrumentation with a range of 10 to 10 R/hr for this variable. The licensee states that the range specified by the regulatory guide is inappropriate at both ends of the range. The licensee has evaluated the range (10 to 10 R/hr) of their 20
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thirteen installed instruments and considers them appropriate for the intended purpose. The licensee further states that access to any high .
l radiation area, based on an area radiation monitor alone, would not be authorized, especially at dose rates higher than 10 R/hr. .
From a radiological standpoint, if the radiation levels reach or exceed
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the upper limit of the ranges provided, 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 ranges for the radiation exposure rate monitors acceptable.
3.3.36 Noble Gases and Vent Flow Rate-(All Other Identified Release Points)
Regulatory Guide 1.97 recommends a range of 10' to 10 pC1/cc ,
for this variable. The licensee has identified this monitor as auxiliary feedwater terbine exhaust with a range of .1 to 1000 pC1/cc. The licensee states that this instrument was installed to meet NUREG-0737 requirements and is based on fission product release.
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.
3.3.37 Plant and Environs Radiation (Portable Instrumentation) i Regulatory Guide 1.97 recommends a range of 10 to 10* R/hr photons and 10" to 10 rads /hr beta for this variable. The licensee submitted a list of available instrumentation and associated ranges for their existing instrumentation. The existing ranges are less than recommended by the regulatory guide. The licensee states that the
- - specified range of 10,000 R/hr photon or beta is far beyond what is reasonable exposure for a portable survey instrument. An individual using an instrument in such a field would receive unacceptable levels of exposure while performing the survey.
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8 After an evaluation of the available instrumentation at this station, we conclude that radiation fields greater than those which can be measured by this equipment would not be measured with portable instrumentation.
Therefore, we find the existing instrumentation adequate for the intended monitoring function.
'3.3.38 Wind Speed Regulatory Guide 1.97 Revision 2 recommends wind speed instrumentation with a range of 0 to 67 mph. The licensee has wind speed instrumentation that reads 0 to 50 mph. The licensee states that the existing range meets the guidance of Regulatory Guide 1.23.
We find that the range provided is satisfactory. Furthermore, it meets the recommendation of Revision 3 of Regulatory Guide 1.97.
3.3.39 Estimation of Atmospheric Stability Regulatory Guide 1.97 recommends instrumentation for this variable with a range -9 to +18*F for 164 feet intervals or an analogous range for alternative stability analysis. The applicant has provided instrumentation with a range of -4 to +8*F for a 115 feet interval and -6 to +12*F for a 465 feet interval. The licensee justifies this deviation by saying that the vertical temperature range covers the range of lapse rate guidance of Regulatory Guide 1.23 (Peference 7) required to estimate the atmospheric stability class.
Table 1 of Regulatory Guide 1.23 provides 7 vertical atmospheric stability classifications based on the difference in temperature per 100 meters elevation change. These classifications cover from extremely ,
unstable to extremely stable. Any temperature difference greater than +4*C or less than -2*C does nothing to the stability classification. The -
licensee's instrument range is greater than that recommended in Regulatory Guide 1.23. Therefore, we find that this instrumentation is acceptable to determire the atmospheric stability.
22
- 4. CONCLUSIONS Based on our review, we find that the licensee either conforms to or is l justified in deviating from Regulatory Guide 1.97, with the following exceptions:
I
- 1. Neutron flux--the licensee should show that environmental qualification
^
has been addressed in accordance with 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.1).
- 2. Containment isolation valve position--the licensee should provide certification that the isolation valves that are located outside of containment are in a mild environment as defined in 10 CFR 50.49 or upgrade the instrumentation. The licensee should upgrade the isolation valves inside containment in conformance with 10 CFR 50.49. The licensee should describe how the isolation valves, that they indicate are in a closed or sealed system, satisfy the definition of " closed system" in General Design Criteria 57 (Section 3.3.8).
- 3. RHR flow--the licensee should show that environmental qualification has been addressed in accordance with 10 CFR 50.49 and Regulatory l Guide 1.97 (Section 3.3.12).
- 4. RHR heat exchanger outlet temperature--environmental qualification should be upgraded in conformance with 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.13).
- 5. Accumulator tank ~1evel and pressure--environmentally qualified instrumentation should be provided for this variable. If level is
! chosen as the key variable, the range should be expanded to 10 to 90 percent of the tank volume (Section 3.3.14).
- 6. Low pressure safety injection system flow--the licensee should show that environmental qualification has beer, addressed in accordance with 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.16).
l 23
- 7. Pressurizer heater current--the licensee should provide the recommended instrumentation (Section 3.3.19).
- 8. Quench tank level--the licensee should provide additional justification in support of the deviation in range (Section 3.3.20). .
- 9. Condensate storage tank water level--the licensee should provide information on the instrumentation for this variable, identify any i
deviations and justify any deviations identified (Section 3.3.23).
- 10. Primary plant demineralized water storage tank level--the licensee should provide independent power sources for the redundant instrument channels (Section 3.3.24).
- 11. Heat removal by the containment fan heat removal system--the licensee should provide information on the instrumentation for this variable, identify any deviations and justify any deviations identified (Section 3.3.26).
- 12. Containment atmosphere temperature--the licensee should either justify the existing range or provide the recommended range (Section 3.3.27).
! 13. CCW temperature to ESF system--the licensee should show that environmental qualification has been addressed in accordance with l 10 CFR 50.49 and Regulatory Guide 1.97 (Section 3.3.30).
- 14. CCW flow to ESF system--the licensee should provide information on the instrumentation for this variable, identify any deviations and justify ,
! any deviations identified (Section 3.3.31).
- 15. Radioactive gas holdup tank pressure--the licensee should re-range this j instrumentation (Section 3.3.34).
i i
i 24
- 5. REFERENCES
- 1. NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits,
" Supplement No. I to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
- 2. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and following an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
- 3. Clarification of TMI Action Plan Reautrements. Reauirements for Emergency Response Capability, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
- 4. Duquesne Light Company letter, J. J. Carey to Director of Nuclear Reactor Regulation, " Generic Letter No. 82-33; Supplement to NUREG-0737, Regulatory Guide 1.97, Revision 2, Report,"
November 29, 1985.
- 5. Duquesne Light Company letter, J. D. Sieber to Director of Nuclear Reactor Regulation, " Generic Letter No. 82-33; Supplement to NUREG-0737, Regulatory Guide 1.97, Revision 2, Supplemental Report,"
October 13, 1986.
- 6. Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durino and Following an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
- 7. Onsite Meteoroloaical Programs, Regulatory Guide 1.23 (Safety Guide 23), NRC, February 17, 1972 or Meteorological Proarams in Support of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, September 1980.
25
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- a. mta .=o swe riria Conformance to Regulatory Guide 1.97, Beaver Valley Power Stations, Unit No.1 , ,,,,,,,,,,,,,,, ,,,,
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- 10. 5PomSome=G ORG.Nid.Tsom m..t .mo ..skahG .congsg auw,,,,, J, cese, s ia r,pg op pgPome Division of Systems Integration Preliminary Technical Office of fluclear Reactor Regulation Evaluation Report U. S. Nuclear Regulatory Commission Washington, DC 20555 i3 SWP'LE tNr.av mot 85
'3 . 8Tm.;T sJ00 es,es er .ss, This EG&G Idaho, Inc. report reviews the submittal for the Beaver Valley Power Station, Unit flo.1, and identifies areas of nonconformance 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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