ML20211E097

Forwards Complete Conformance to Reg Guide 1.97,Trojan Nuclear Plant, Technical Evaluation Rept.Technical Evaluation Rept Forwarded w/860929 Ltr Incomplete

ML20211E097
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/17/1986
From:	Chan T Office of Nuclear Reactor Regulation
To:	Withers B PORTLAND GENERAL ELECTRIC CO.
References
RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-51362, NUDOCS 8610220350
Download: ML20211E097 (2)

Text

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October 17, 1986 Docket No. 50-344 . DISTRIBUTION (Docket F.11e,

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T. Chan NRC PDR' C. Vogan Mr. Bart D. Withers Local PDR ACRS(10)

Vice President Nuclear PD#3 Rdg. PAEI Portland General Electric Company T. Novak OGC 121 S.W. Salmon Street E. Jordan B. Grimes Portland, Oregon 97204 J. Partlow N. Thompson

SUBJECT:

EMERGENCY RESPONSE CAPABILITY - CONFORMANCE TO REGULATORY GUIDE 1.97 REV. 2

Dear Mr. Withers:

By letter dated September 29, 1986 the staff issued its Safety Evaluation (SE) regarding PGE's conformance to Regulatory Guide 1.97 Rev. 2. Attached to the SE was EG&G's Technical Evaluation Report (TER).

It has come to our attention that the TER was missing several pages. Enclosed herein is the complete TER.

Sincerely, Terence L. Chan, Project Manager Project Directorate #3 Division of PWR Licensing-A

Enclosure:

As stated cc: See next page PD#3 PD#3 -

CVogan O TChan.' N'>

10/g786 10/p/86 8610220350 861017 hDR ADOCK 05000344PDR

Mr. Bart D. Withers Portland General Eletric Company Trojan Nuclear Plant cc:

Senior Resident inspector U.S. Nuclear Reculatory Commission Trojan Nuclear Plant Post Office Box 0 Rainier, Oregon 97048 Robert M. Hunt, Chairman Board of County Commissioners Columbia County St. Helens, Oregon .97501 William T. Dixon Oregon Department of Energy Labor and Industries Building Room 111 Salem, Oregon 97310 Regional Administrator, Region V U.S. Nuclear Regulatory Commission Office of Executive Director for_ Operations 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

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.. Enclosure EGG-NTA-7076

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CONFORMANCE TO REGULATORY GUIDE 1.97 TROJAN NUCLEAR PLANT .

J. W. Stoffel Published July'1986 s

EG&G Idaho, Inc.

Idaho falls. Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555

, Under DOE Contract No. SE-AC07-16ID01570 FIN No. A6483 I 1

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ABSTRACT This E6&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97 for the Trojan Nuclear Plant and identifies areas of nonconformance to the regulatory guide. Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for '

acceptability is not provided are identified.

l Docket No. 50-344 .

. TAC No. 51362 1

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FOREWORD This report is supplied as part of the " Program for Evaluating t

Licensee / App 11'can' "Conformance to R.G.1.97 " being conducted for the '

U.S. Nuclear Regulatory Commission. Office of Nuclear Reactor Regulation, Division of PWR Licensing A, by EG&G Idaho, Inc., NRR and I&E Support Branch.

The U.S. Nuclear Regulatory Crimission funded the work under authorization 20-19-10-11-3.

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. Docket No. 50-344 TAC No. 51362

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CONTENTS ABSTRACT .............................................................. 11 FOREWORD .............................................................. 111

1. INTRODUCTION ..................................................... 1

2. REVIEW REQUIREMEATS .............................................. 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. CONCLUSIQNS ..................................................... 18 '

5. REFERENCES ....................................................... 19 t .

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le CONFORMANCE TO REGULATORY GUIDE 1.97 TROJAN NUCLEAR PLANT

1. INTRODUCTION

, On December 17.-1982, Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency response capabil.ity.. These requirements have been published as Supplement ,

No. I to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).

Portland General Electric Company, the'11censee for the Trojan Nuclear Plant, provided a response to the Regulatory Guide 1.97 portion of the generic letter in December 1984 (Reference 4). Additional information was provided on May 13,1986 (Reference 5).

s 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 t' hat provides the following information for each variable shown in the .

applicable table of Regulatory Guide 1.97.

1. Instrument range

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2. Environmental qualification

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3. Seismic qualification

4. Quality assurance

5. Redundance and sensor location

6. Power supply

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l 7. Location of display

8. Schedule of installation or upgrade

! The submittal should identify deviations from Regulatory Guide 1.97 and l provide supporting justification or alternatives.

Subsequent to the issuance of the generic letter, the NRC held

( regional meetings in February and March 1983, to answer licensee and .

applicant questions and concerns regarding the NRC policy on this subject.

l At these meetings, it was noted that the NRC review would only address -

exceptions taken to Regulatory Guide 1.97. Where licensees or applicants j 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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l 3. EVALUATION l

The licensee provided a report addressing the Regulatory Guide 1.97 l portion of NRC Generic Letter 82-33 in December 1984. Additional information was submitted on May 13, 1986. This evaluation is based on ,

I these submittals.

( 3.1 Adherence to Regulatory Guide 1.97

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The licensee stated that compliance with Regulatory Guide 1.97, Revision 3 (Reference 6), is indicated in their accident monitoring instrumentation review, which sunrnarizes each variable's compliance with the Regulatory. Guide 1.97 provisions. That compliance review presents justification. modifications or ongoing evaluations that are provided as resolutions for any identified deviations. The licensee states in Appendix 7C of their report on conformance to Regulatory Guide 1.97 that all upgrade modifications are scheduled for completion by the end of the 1987 refueling outage. Therefore, we conclude that the licensee has provided an explicit consnitment on conformance to Regulatory Guide 1.97.

Exceptions to and deviations from the regulatory guide are noted in s 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 spec'ific manually controlled safety actions.

The licensee classifies the following instrumentation as Type A.

1. Reactor coolant system (RCS) hot leg water temperature

2. RCS cold leg water temperature c

3. RCS pressure (wide range) 4

4. Core exit temperature

5. Containment pressure

6. Refueling water storage tank level

, 7. Pressurizer level

8. Steam generator level

9. Steam generator pressure

10. Condensate. storage tank level L

This instrumentation meets Category 1 recommendations consistent with the requirements for Type A variables, except as noted in Section 3.3.

3.3 Exceptions to Reoulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory

, Guide 1.97. These are discussed in the following paragraphs.

3.3.1 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has committed to the installation of a single new j neutron flux channel that will meet the Category 1 requirements; however, a-fully qualified redundant channel will not exist. Category 1 requirements include _ full redundancy to satisfy the single failure criteria. The l licensee states, in Reference 4, that one Category 1 channel is sufficient since control rod position and RCS soluble boron concentration can be.used as diverse methods of monitoring this variable during all types of accidents.

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In Reference 5, the licensee reiterated the justification previously -

submitted. This justified for a single channel of qualified neutron flux instrumentation is not acceptable. The single failure criteria should be

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complied with. We conclude that the licensee should provide a fully qualified redunctnt channel of neutron flux instrumentation to satisfy the single failure criteria. .

3.3.2 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends Category 3 instrumentation, with a range of 0 to 6000 ppm, for this variable. The licensee does not provide a separate instrument for this variable. To conform to the regulatory guide, '

the licensee is .tak.ing credit for the post-accident sampling system for -

this variable.

The licensee takes exception to Regulatory Guide 1.97 with respect to post-accident sampling capability. This exception goes beyond the scope of this review and is being addressed by the NRC as part of their review of NUREG-0737 Item I1.8.3.

, 3.3.3 Core Exit Temocrature Regulatory Guide 1.97 recommends Category 1 instrumentation with a range of 200*F to 2300*F. The licensee has provided a continuous display of 0 to 700*f. The monitoring system is not environmentally or seismically qualified and the power source is non-Class 1E.

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

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3.3.4 Containment Isolation Valve Position -

Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee identified the following areas in which they deviate from the Category 1 criteria: .

, 1. Recording has not been provided.

2. Redundancy of indication generally has been met on a per line basis rather than on a per valve basis.

3. Indication is not continuous for certain valves that are required to be de-energized with power removed to ensure that the correct -

position is maintained.

4. Indication is not provided for manually operated valves, safety relief valves, or check valves used as containment isolation valves.

From the information provided, we find that the licensee deviates from a strict interpretation of the Category 1 criteria. We view recording of the position of these valves as unnecessary. Only the ac'tive valves have '

position indication (i.e., check valves have no position indicat'on).

Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory guide. Loss of indication due to the removal of power from the valve power control circuit is acceptable. Position indicati5n of check valves is specifically excluded by Table 3 of Regulatory Guide 1.97. Therefore, we find that the j instrumentation provided for this variabl,e is acceptable.

l 3.3.5 Radioactivity Concentration or Radiation Level in Circulatina l Primary Coolant The licensee has a gross failed-fuel monitor that continuously measures the concentration of ganna emitting fission products in the primary coolant during normal operation. Post-accident, this monitor is 7

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isolated and the post-accident sampling system, which is being reviewed by ,.

the NRC as part of their review of NUREG-0737. Item II.B.3, is used to verify fuel cladding integrity.

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

3.3.6 Condenser Air Removal System Exhaust-Noble Gases Containment Effluent Radioactivity-Noble Gases Ef fluent Radioactivity-Noble Gases In Reference.5 the licensee provided the required information for .

l these variables. Regulatory Guide 1.97 reconnends Categ ry 2 instrumentation for these variables and a range up to 10 pC1/cc for the auxiliary building exhaust. The licensee has provided Category 3 i instrumentation that is equivalent to the NUREG-0737 criteria under which this equipment was installed. The upper limit of 300 vC1/cc for the aux 111ary building exhaust monitors and the Category 3 instrumentation was previously reviewed and accepted by the NRC as part of their review of s NUREG-0737.

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 Residual Heat Removal (RHR)_ Heat Exchancer Outlet Temperature t

Regulatory Guide 1.97 recommends a range for this variable of 40 to 350*F. The licensee has supplied a range of 50 to 400*F. The instrumentation supplied has a range where the lower limit of the range -

l does not conform to the regulatory guide.

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1 The licensee states that operators are r to maintain the reactor coolant temperatu system. equired by written procedures be at with the head bolts , is 60*F.

tensionedIn addition, the m e reactor vessel may that all Updated Final Safety Analysis R Finally, the licensee states

, and IV, accidents will cause the RHR outlet teeport Chapter 15, cond that the temperature range is adequatemperature to rise, showing Based on the justification provided by th the existing range is adequate to monito e licensee, we conclude that r the RHR system operation.

3.3.8 Accumulator Tank Level and pressure Regulatory variable. Guide 1.97 recommends Catego (0 to 750 psig) and level range ended(10 torange pressure 90The licens instrumentation, except for environmental qpercent volume} and the ualification, is Category 2.

to 700The psig.licensee has su; plied pressure instru plant technical specifications torequired manually by the contThe between 600 and 673 psig. rol the accumulator pressure valves limit the pressure to this valueThe tank design

. e ef pressure is 70 The licensee has supplied levela instrument ti to 70.9 percent volume. on with a range of 53 useful for inje: tion.during normal operation to ensure that adThe licen s manually control the accumulator level ,

c cationstoto betThe ope ween 64 and 69 percent volume.

, The accumulatcr pressure is the key variabl status of the accumulators. e used to determine the discharge into the reactor coolant systThe accumulators .

Their are passive decrease in the RCS pressure . em (RCS) is actuated solely by a for this vartable is adequate to d tWe find that the instrumentation ed suppli e ermine that the accumulatprs have 9

discharged. Therefore, the instrumentation provided for this variable is '

acceptable.

3.3.9 Refuelina Water Storace Tank Level l

Regulatory Guide 1.97 recommends a range from the top to the bottom of the tank. The licensee does not meet this range and states that the l existing range is adequate. The usable volume of the tank is from 37 feet 1 inch (in the overflow line) to 2 feet 4 inches (the tank outlet). The installed instrument taps are at a point 37 feet 7 inches (in the overflow line) to 2 feet 4 inches from the tank bottom. This span covers more than the usable volume of the tank. .

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Sased on the justification provided by the licensee, we find the instrumentation for this variable adequate to monitor the level of this tank.

3.3.10 Pressurizer Level Regulatory Guide 1.97 recommends a range from the bottom to the top

, for this variable. The instrumentation provided by the licensee does not read this full range. The licensee states that the volume measured .

represents approximately 92 percent of the pressurizer volume and that this is sufficient for the operator to take the required manual actions and to ensure the proper operation of the pressurizer.

The volume of the pressurizer where level is not indicated (approximately 8 percent volume) is the upper and lower hemispherical head region, where the volume to level ratio it not linear. We find this deviation minor and acceptable. The existing range is adequate to monitor this variable during all accident and post-accident conditions.

3.3.11 Quench Tank Level The range of the existing instrumentation for this variable does not meet the range recommended by Regulatory Guide 1.97 (top to bottom). The 10

, licensee's instrumentation covers a range of approximately 6 to 94 percent. The licensee states that this meets the intent of the.

regulatory guide.

I We find this deviation minor. The existing level range is adequate to monitor the operation of this tank during accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

3.3.12 Quench Tank Temperature Regulatory Guide 1.97 recommends a temperature range of 50 to 750*F for this variable. The licensee's instrumentation has a range of 0 to 300*F. The licensee considers this range adequate. The tank pressure is limited to 100-psig by rupture disks. If saturation conditions exist at the design pressure, the maximum temperature would be about 338'F. The licensee states, in Reference 5, that this temperature indication is used during normal operation to determine if cooling is required to maintain the tank temperature below 200*F. A temperature near 300*F would indicate abnormal conditions that, the licensee states, would be assessed and acted I on by the operator.

We find this justification unacceptable. The range should be wide ..

enough to read the saturation temperature corresponding to the tank design pressure and rupture disk relief pressure (100 psig). The licensee should expand the existing instrumentation range to cover a minimum of 50 to 338*F.

3.3.13 Steam Generator Level Regulatory Guide 1.97 recommends Category 1 instrumentation with a range from the tube sheet.to the separators for this variable. The licensee has instrumentation that reads from 14 inches above the tube sneet to the separators, but this instrumentation is not Category 1. The 11

licensee states.that th'e wide range instrumentation will be upgraded to Category 1 requirements and that the existing level range is adequate.

The steam generator is, in effect, empty at 14 inches above the tube l

sheet. Therefore, we find this deviation 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

! has committed to upgrade the wide range instrumentation to Category 1.

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3.3.14 Steam Generator Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from atmospheric pressure to 20 percent above the lowest safety valve setting (1125 psig) for this variable. That means the upper range on this indicator should read 1350 psig. The. licensee has provided Category 1 instrumentation with a range of 0 to 1200 psig (107 percent above the lowest safety valve setting), and an unqualified instrument with an acceptable range of 0 to 1500 psig. The licensee considers the existing range adequate for post-accident monitoring of this variable.

In Reference 5, the licensee states that the O to 1500 psig range instrumentation is powered by a high reliability, diesel generator backed power bus and that the instrumentation is located in the turbine building.

The turbine building is considered a mild environment except for a main I steam or feed line break (MSLB or FWB) in the turbine building.

Based on the licensee having Category 1 instrumentation that will monitor the steam pressure to 1200 psig for wither the MSLB or FWB (when the pressure would decrease) and instrumentation located in a mild environment that will monitor the pressure to 1500 psig, we find this l instrumentation acceptable.

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3.3.15 Condensate Storace Tank (CST) Level In Reference 4, the licensee had not provided instrumentation for this variable that met the Category i seismic qualification requirements.

In Reference 5, the-licensee has committed to provide redundant, Class 1E, seismically qualified instrumentation for this variable by the end of the 1986 refueling outage. We find inis commitment acceptable.

3.3.16 Containment Spray Flow Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of 0 to 110 percent of design flow for this variable. The licensee has not provided a direct measurement of containment spray flow. Instead, they use qualified pressure transmitters on the discharge line of each pump to indicate proper operation of the spray system. In addition, approximately 5 percent of each containment spray pump discharge is bypassed through a spray additive eductor, where it is used as the motive flow to draw sodium hydroxide solution from the sodium hydroxide tank. The normal operation of the containment spray system can be inferred from the decreasing level of this tank.

In Reference 5, the licensee provided the additional information requested. Proper system flow is indicated by a spray pump discharge pressure of approximately 215 psig along with the containment spray isolation valve open indication and a sodium hydroxide flow indication of 35-40 gpm until isolated. We find this instrumentatica acceptable.

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3.3.17 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends a range of 40 to 400*F for this variable. The licensee has existing instrumentation with a range.of 0 to 300*F. The licensee justifies this exception by stating that the design basis accident maximum containment temperature is 288'F wnich is consistent with the existing range.

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Since the worst case postulated accident will not increase the containment atmosphere above 288'F, we find the range of 0 to 300*f '

adequate to monitor this variable during all accident and post-accident conditions. .

3.3.18 Containment Sumo Water Temperature The licensee does not have this instrumentation and states that this parameter is unnecessary and would not provide useful indication if The accomplishment of containment cooling can be directly a va ilable ~.

evaluated by monitoring of containment atmosphere temperature indication.

The licensee has determined that the residual heat removal 'RHR) pumps and the containment spray pumps that take suction from the sump, are capable of The licensee also operation under all expected temperature conditions.

monitors the discharge temperature of each RHR pump and the residual heat These temperatures would be

-removal heat exchanger outlet temperature.

indicative of the sump water temperature once recirculation of the sump contents begins.

Based on the licensee's justification and this alternate instrumentation, we conclude that this deviation is acceptable.

I 3.3.19 Volume Control Tank level The licensee takes exception to the range recommended by Regulatory The transmitters measure the Guide 1.97 for this variable (top to bottom).

full range between the instrument taps and , display 0 to 100 percent level; The span of however, these taps are not at the top and bottom of the tank.

The licensee the taps are about 70 inches or 18 to 82 percent volume.

considers this range adequate to monitor the operation of the volume level control tank. Also, the existing range of the volume control tank -

envelops all automatic actions of the level control system.

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We find that the existing level indication is adequate to monitor the operation of this tank. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

3.3.20 Component Coolina Water (CCW) Flow to Engineered Safety Features (ESF) System Components

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Regulatory Guide 1.97 recommends Category 2 instrumentation uith a range of 0 to 110 percent design flow for this variable. The licensee has not provided this instrumentation. The licensee does not consider this instrumentation necessary based on the following plant-specific design features.

1. The CCW system is operating during nornal operations with one CCW pump and heat exchanger in continuous operation. The other train is in a standby condition. Annunciation in the control room indicates a low flow condition.

2. CCW pump and heat exchanger performance is indicated by means of pressure transmitters and resistance temperature detectors (RTD's) for each train in the main control room. Verification of flow in each CCW pump discharge line is also confirmed by comparing CCW heat exchanger inlet and outlet temperatures in the main controi room.

3. Local flow indicators are installed in the CCW lines going to components in containment and to the RHR heat exchangers.

The alternate instrumentation provided by the licensee will adequately monitor flow to the ESF components. In Reference 5, the licensee verifiec that the CCW pump discharge pressure transmitters and CCW heat exchanger inlet and outlet temperature indicators meet Category 2 requirements. We find tnis alternate instrumentation acceptable.

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3.3.21 High Level Radioactive liauid Tank Level ,

Regulatory Guide 1.97 recommends a range of top to bottom for this variable. The transmitters for these tanks measure the full range between the instrument taps and the indication is 0 to 100 percent; however, the lower tap is not at the bottom of the tank. The actual range monitored is 13.6 to 100 percent level. The licensee states that the existing range meets the intent of confirming storage capacity. Upper level indication is considered more significant than the lower level and the existing range does extend to the top.

We find that the existing range is adequate to monitor the operation of this tank during all accident and post-accident conditions. Therefore, this is an acceptable deviation from-Regulatory Guide 1.97.

3.3.22 Noble Gases and Vent Flow Rate In. Reference 4, the licensee did not provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1 for the seven locations under this heading. In Reference 5, the licensee provided the required information for these variables. Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables, a range of up to 10 vC1/cc for the auxiliary building exhaust, and flow rate instrumentation f or the auxiliar y building ef fluent release. The licensee has provided instrumentation that is equivalent to the NUREG-0737 criteria under which this equipment was installed. The upper limit of 300 uCi/cc for the auxiliary building exhaust monitor and the Category 3 instrumentation was reviewed and accepted by the NRC as part of their review of NUREG-0737. For the auxiliary building accident effluent release flow rate the licensee monitors the operation of the exhaust fans. The licensee states that the vent design flow is fixed and depends only on the number of fans operating. Each fan is rated at 26.000 cubic feet per minute with local flow meters available for each fan. We find this acceptaole.

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We find this 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.

3.3.23 Particulates and Halogens In Reference 4, the licensee did not provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1 for this variable. In Reference 5, the licensee provided the required information for this variable noting a flow rate deviation. This flow rate deviation.is the same as that discussed and accepted in paragraph 3.3.22 of this report. We find the provided instrumentation adequate and, therefore, acceptable.

3.3.24 Accumulator Isolation Valve Position In Reference 4, the licensee committed to provide Category 2 isolation valve position indication. In Reference 5, the licensee stated that, after further review, a decision was made that environmentally qualified instrumentation is not required for this variable. The licensee states that these valves are acministratively controlled'and maintained open with power removed during operations. These valves are not required to change position during an accident for the accumulators to fulfill their safety function. Based on the licensee's justification that these valves are open and can not change position during or following an accident, we consider the instrumentation for this variable acceptable.

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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 ,

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1. Neutron flux--the licensee should provide a redundant channel of  ;

Category 1 instrumentation for this variable (3.3.1).

2. Quench tank temperature--the licensee should provide instrumentation that covers the tank contents saturation temperature (Section 3.3.12).

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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 Durina and Following 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,

.0ffice of Nuclear Reactor Regulation, January 1983.

4. Accident Monitorina Instrumentation Review for the Trojan Nuclear Plant, Portland General Electric Company, December 1984, PGE 1043.

5. Portland General Electric Company letter, Bart D. Withers to Director of Nuclear Reactor Regulation, NRC, " Regulatory Guide 1.97 Review,"

May 13, 1986.

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 Research, May 1983.

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