ML20209E022

Forwards EGG-NTA-7157, Conformance to Reg Guide 1.97,Fort Calhoun Station, Informal Rept

ML20209E022
Person / Time
Site:	Fort Calhoun
Issue date:	12/01/1986
From:	Roberts E EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	Carrington M Office of Nuclear Reactor Regulation
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EWR-137-86, NUDOCS 8704290414
Download: ML20209E022 (1)

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/NE Idaho NationalEngle,eerksg Laboratory December 1, 1986

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i Mr. M. Carrington, Program Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 TRANSMITTAL OF FINAL REPORT, "CONFORMANCE TO REGULATORY GUIDE 1.97, FORT CALHOUN STATION," EGG-NTA-7157, NOVEMBER 1986 - EWR-137-86 Ref: NRC Form 189, " Program for Evaluating Licensee Conformance to R.G. 1.97, Rev. 2, and SPDS Implementation" (FIN A6483),

October 1983

Dear Mr. Carrington:

Transmitted herewith is the above subject report which was completed under FIN A6483. This report documents the EGSG Idaho evaluation of the Fort Calhoun Station's conformance to Regulatory Guide (RG) 1.97,

" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plants and Environs Conditions During and Following an Accident."

Based on our evaluation it is concluded that, with the exception of the accumulator tank level and pressure variables, the licensee either conforms to or is justified in deviating from the variables in RG 1.97.

The exceptions are reviewed in Section 3.3.8 of the report.

Very truly yours 3 n/3 s E. W. Roberts, Manager NRC Headquarters Support

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Enclosure:

As Stated )

cc: I Ahmed, NRR-PBPE J. J. Lazevnick, NRR-PAEI G. L. Jones, DOE-ID P. Shemanski, NRR-PBPE J. O. Zane, EG&G Idaho,Inc. (w/o Encl.)

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EGG-NTA-7157 November 1986 INFORMAL REPORT idaho Nationa/ CONFORMANCE TO REGULATORY GUIDE 1.97, Engineering FORT CALHOUN STATION Laboratury Managed I by the U.S.

Depanment ofEnergy A. C. Udy  ;

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Prepared for the w ea - o, mea unae, U. S. NUCLEAR REGULATORY COMMISSION l DOE Contract No. DE-AC07-76lD01570 i

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DISCLAIMER J This book was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any l

legal liabiity or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disciosed, or reprewnts that its use would not intnnge pnvately owne3 rights. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessanly constitute or imply its endorsement, recommendation, or favonng by the United States Government or any agency thereof. The views and opinions of authors excressed herein do not recessanly sta's or reflect these of the United States /

Government or any agency thereof i

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,, TECHNICAL EVALUATION REPORT I- J.'

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CONF 0RFANCE TO REGULATORY GUIDE 1.97 FORT CALHOUN STATION Docket No. 50-285 ,

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i' Published November 1986 i .

Idaho National Engineering Laboratory .

EG6G Idaho, Inc.

Idaho Falls, Idaho 83415 i

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U.S. ik. clear Regulatory Comission i Washingtori, D.C. 20555 /

Under 001 Contract No. DE-AC07-76ID01570 i FIN No. A6483 4

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ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97, Revision 2, for the Fort Calhoun Station and identifies areas of nonconformance to the regulatory guide. Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are identified.

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

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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 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 8&R 20-19-10-11-3.

u Docket No. 50-285 TAC No. 51091 111

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CONTENTS 4

ABSTRACT .............................................................. 11 FOREWORD .............................................................. 111 i  !

! 1. INTRODUCTION ..................................................... 1 ,

2. REVIEW REQUIREMENTS .............................................. 2 i

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 l 4. CONCLUSIONS ...................................................... 13 S. REFERENCES ....................................................... 14 l

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-CONFORMANCE TO REGULATORY GUIDE 1.97 FORT CALHOUN STATION

1. INTRODUCTION

. On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was 4

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).

l The Omaha Public Power District, licensee for the Fort Calhoun Station, provided a response to Section 6.2 of the generic letter on l April 1, 1985 (Reference 4). Additional information was provided on October 21, 1986 (Reference 5).

This report provides an evaluation of that material.

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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

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response facilities. The submittal should include documentation that provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97.

1. Instrument range

2. Environmental qualification

3. Seismic qualification

4. Quality assurance

5. Redundance and sensor location

6. Power supply

7. Location of display

8. Schedule of installation or upgrade The submittal should identify deviations from the regulatory guide and provide supporting justification or alternatives.

Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983, to answer licensee and

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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 I

explicitly state that instrument systems conform to the regulatory guide, it was noted that no further staff review would be necessary. Therefore, 1

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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 4

review policy described in the NRC regional meetings.

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3. EVALUATION The licensee provided a response to Item 6.2 of NRC Generic Letter 82-33 on April 1, 1985. Additional information was provided on October 21, 1986. The responses describe the licensee's position on post-accident monitoring instrumentation. This evaluation is based on that material. ,

3.1 Adherence to Regulatory Guide 1.97 The licensee has provided a review of their post-accident monitoring instrumentation that compares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 2. The licensee states that they have determined whether instrumentation complies with the regulatory guide or complies with the regulatory guide with exceptions or with modifications. In those instances where compliance of existing instrumentation was not established the licensee either justified the exception or deviation or committed to upgrade the instrumentation in question. For that instrumentation to be modified, the licensee has scheduled all modifications to be completed during or before the 1987 refueling outage, except for the variable containment sump water temperature, which will be installed during the 1988 refueling outage.

Therefore, we conclude that the licensee has provided an explicit I 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 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. Neutron flux

2. Reactor coolant system (RCS) hot leg water temperature 4

3. RCS cold leg water temperature

4. Degrees of subcooling

5. Core exit temperature

6. Coolant level in reactor

7. Pressurizer level

8. Pressurizer pressure

9. Steam generator level

10. Steam generator pressure

11. Containment hydrogen concentration

12. Containment radiation monitor (high range)

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

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

3.3.1 Reactor Coolant System (RCS) Pressure Regulatory Guide 1.97 recommends instrumentation for a Combustion Engineering nuclear steam supply system with a range of 0 to 4000 psig for

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this variable. The licensee utilizes the pressurizer pressure instrumentation for this variable. The RCS and the pressurizer pressure are essentially the same. This is acceptable except that the range is 0 to 2500 psig. The licensee states that the existing range of 5

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0 to 2500 psig is adequate to monitor all expected pressures based on the accident analyses presented in the updated Safety Analysis Report (USAR) and is acceptable pending resolution of the anticipated transient without scram ( ATWS) issue.

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In Reference 6, the licensee has committed to install additional Category 1 instrumentation with a range from 1900 to 2900 psia. This is in ,

accordance with the resolution of the ATWS issue, where a peak pressure of 2600 psia is expected based on analysis. Therefore, this is an acceptable deviation.

3.3.2 Core Exit Temperature The licensee has identified this as a Type A variable. As such, Category 1 recommendations must be met by the instrumentation. In this, the licensee has identified a deviatio1 that there is no continuous display of this information in the control room, but it is available on demand on the safety parameter display system (SPDS).

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

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

The licensee deviates from Regulatory Guide 1.97 with respect to the ,

instrumentation for the variable coolant level in reactor. This deviation goes beyond the scope of this review and is being addressed by the NRC as part of their review of NUREG-0737, Item II.F.2.

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3.3.4 Containment Isolation Valve Position From the information provided, we find that the licensee deviates from a strict interpretation of the Category 1 redundancy recommendation. Only the active valves have position indication (i.e., check valves have no

. position indication). Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory guide. Position indication of check valves is specifically excluded by Table 2 of Regulatory Guide 1.97. Therefore, we find that the instrumentation for this variable is acceptable.

3.3.5 Radiation Level in Circulatina primary Coolant Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has a radiation monitor on the letdown line (which is isolated from the RCS in an accident) and on-line gross gamma detectors that are part of the post-accident sampling system. The post-accident sampling system is being reviewed by the NRC as part of their review of NUREG-0737, Item II.8.3.

Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.

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

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

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3.3.7 Radiation Exposure Rate Revision 2 of Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has Category 3 instrumentation for this variable. As Revision 3 of :he regulatory guide has changed the recommendation for this variable to Category 3 instrumentation, we find the instrumentation supplied for this variable ,

acceptable.

3.3.8 Accumulator Tank Level and Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with ranges of 10 to 90 percent of volume and 0 to 750 psig. The licensee's instrumentation meet; the recommendations for Category 2 instrumentation except for environmental qualification. The licensee states that the accumulators discharge their contents into the cold legs of the reactor coolant system automatically for either loss of coolant accidents (LOCA) or uncontrolled heat extraction events (steamline breaks).

The licensee supports using the present instrumentation with the following discussions:

1. Operator action for the accumulators is not assumed or possible

2. It is not possible to overpressurize the accumulators after an event

3. The accumulators do not provide a long term core cooling function

4. Environmentally qualified instrumeatation will not increase the reliability or availability of the accumulators.

The licensee states that the ranges provided are O to 100 percent level, but did not state this to be in compliance (the licensee has not indicated whether the range is in percent of tank volume or in percent of instrument tap height) and 0 to 300 psig, which is not in compliance. The 8

licensee states that the pressure is a minimum of 240 psig, and relief valves are set at 275 psig. On this basis, the range of 0 to 300 psig is acceptable. The licensee should provide justification in support of and clarify the level range.

. The existing instrumentation is not acceptable. An environmentally qualified instrument is necessary to monitor the status of these tanks to show that the accumulators have performed their safety functions. The licensee should designate either level or pressure as the key variable to directly indicate accumulator discharge and provide instrumentation for that variable that meets the requirements of 10 CFR 50.49 and Regulatory Guide 1.97. If level is used as the key variable, then the range should be expanded to satisfy the recommendations of Regulatory Guide 1.97.

3.3.9 Reactor Coolant pump Status Pressurizer Heater Status Regulatory Guide 1.97 recommends instrumentation for these variables that measures the current drawn by this equipment. The instrumentation provided by the licensee for these variables measures power (kilowatts).

The kilowatts of power used is a direct relation to the current.

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

3.3.10 Containment 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 presently have

. instrumentation for this variable, stating that the net positive suction head is adequate for the safety injection and containment spray pumps when operating in the recirculation mode, regardless of the sump water temperature. The licensee also states that core cooling measurements infer containment cooling.

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In Reference 5, the licensee commits to installing instrumentation for this variaDie that is in accordance with Regulatory Guide 1.97. We find this committment acceptable.

3.3.11 Letdown Flow-Out Regulatory Guide 1.97 recommends Category 2 instrumentation for this .

variable. The licensee's instrumentation is Category 3. The licensee states that the letdown system is isolated during accident conditions.

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

3.3.12 Volume Control Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation is Category 3. The licensee states that the volume control tank is automatically bypassed during accident conditions; that the volume control tank is not a source of borated water for safety injection and that this instrument loop is not required to achieve a safe shutdown, s this variable is not used in conjunction with a safety system, we fino at the instrumentation provided is acceptable.

3.3.13 Component Coolina Water (CCW) Temperature to Engineered Safety Feature (ESF) System Component Cooling Water Flow to ESF System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation is Category 2, except in the area of environmental qualification. The licensee states, in Reference 5, that the instrumentation for temperature is in a mild environment. Therefore, this instrumentation is acceptable.

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In addition to the flow instrumentation, the licensee has Category 2 instrumentation to monitor the CCW pump motor current and Category 2 low flow alarms on the CCW flow outlet for each of the containment air cooling units. We find this combination of instrumentation acceptable for this variable.

3.3.14 Containment or Purge Effluent--Noble Gases and Vent Flow Rate Auxiliary Building--Noble Gases and Vent Flow Rate Common Plant Vent--Noble Gases and Vent Flow Rate Vent from Steam Generator Safety Relief Valves--Noble Gases.

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

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

3.3.15 Wind Direction Regulatory Guide 1.97 recommends instrumentation for this variable with an accuracy of 5*. In Reference 5, the licensee commits to provide calibration of this instrumentation that will provide this accuracy. We find this commitment acceptable.

3.3.16 Accident Sampling (Primary Coolant, Containment Air and Sump)

The licensee's post-accident sampling system provides sampling and analysis as recommended by the regulatory guide, except it does not have the recommended capability for dissolved oxygen or oxygen content. The 11

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

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

NUREG-0737, Item II.B.3.

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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. Accumulator tank level and pressure--environmentally qualified instruments should be provided to show that the accumulators have performed their safety function; if level is the key variable to accomplish this, the licensee should verify the compliance of the level range (Section 3.3.8).

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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. 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 During and Following an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of ~

Standards Development, December 1980.

3. Clarification of TMI Action Plan Requirements. Requirements for Emergency Response Capability, NUREG-0737, Supplement No. 1 NRC, Office of Nuclear Reactor Regulation, January 1983.

4. Omaha Public Power District letter, R. L. Andrews to H. R. Denton, NRC, " Fort Calhoun Station Compliance with Regulatory Guide 1.97, Revision 2," April 1, 1985, LIC-85-ll7.

5. Omaha Public Power District letter, R. L. Andrews to D. E. Sells, NRC, "Conformance to Regulatory Guide 1.97, Revision 2",

October 21, 1986, LIC-86-532.

6. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.

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