ML20214H060
| ML20214H060 | |
| Person / Time | |
|---|---|
| Site: | Seabrook, 05000000 |
| Issue date: | 05/31/1986 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20213F414 | List:
|
| References | |
| CON-FIN-A-6493, FOIA-87-213, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7256, NUDOCS 8606160036 | |
| Download: ML20214H060 (22) | |
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EGG-NTA-7256 CONFORMANCE TO REGULATORY GUIDE 1.97 SEABROOK STATION, UNIT NOS. 1 AND 2 A. C. Udy l
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I Published May 1986 i
EG&G Idaho, Inc.
Idaho Falls. Idaho 83415 Prepared for the.
U.S. Nuclear Regulatory Commission Washington, D C.
20555 Under 00E Contract No.' DE-AC07-76ID1570' FIN No. A6493
1 ABSTRACT This EG&G Idaho, Inc., report reviews the' submittal.for Regulatory Guide 1.97, Revision 3, for the Seabrook Station, Unit Nos. 1 and 2, and identifies areas of nonconformance to-the regulatory guide. Exceptions to.
~ Regulatory Guide 1.97.are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
FOREWORD This report is. supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97." being conducted for-the d.S.
i Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG6G Idaho, Inc., NRR and I&E Support Branch.
The U.S. Nuclear Regulatory Commission funded the work under authorization S&R 20-19-40-41-3.
Docket Nos. 50-443 and 50-444 11
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i CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
11 1.-
INTRODUCTION.....................................................
1 2.
REVIEW REQUIREMENTS..............................................
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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......................................................
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REFERENCES.......................................................
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4 CONFORMANCE TO REGULATORY GUIDE 1.97 SEABROOK STATION. UNIT NOS. 1 AND 2 l
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INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was f
issued by D. G. Eisenhut Director of the Division of Licensing, Nuclear.
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Reactor Regulation, to all licensees of operating reactors, applicants for W
operating licenses and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97,
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- Revision 2 (Reference 2), relating to the requirements for emergency i
response capability. These requirements have been published as Supplement No. I to NUREG-0737, 'TMI Action Plan Requirements" (Reference 3).
1 Public Service of New Hampshire, the applicant for the Seabrook
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Station, provided a response to Section 6.2 of the generic letter on
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August 30, 1985 (Reference 4). This response addresses Revision 3 of
.I Regulatory Guide 1.97 (Reference 5).
This report provides an evaluation of that material.
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REVIEW REQUIREMENTS Section 6.2 of NUREG-0737, Supplement No. 1, sets forth the documentation to be submitted in a report to the NRC describing how the applicant 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 j
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Environmental qualification 3.
Seismic qualification 4.
Quality assurance
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Redundance and sensor location I
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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 hRt neld regional meetings in February and March 1983, to answer licenst e-and applicant questions and concerns regarding the NRC policy on this matter..
At these meetings, it was noted that the NRC review would only _ address exceptions taken to Regulatory Guide 1.97.
Where licensees or applicants
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explicitly state that instrument systems conform to the regulatory guide, it was'noted that no further staff review would be necessary. 'Therefore, 2
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.. this report only addresses exceptions to Regulatory Guide 1.97.
The following' evaluation is an audit oft the applicant's submittal based on the review policy described in the NRC regional meetings.
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EVALUATION The applicant provided a response to Item 6.2 of NRC Generic Letter 82-33 on August 30, 1985. The response describes the applicant's position on post-accident monitoring instrumentation. This evaluation is
'l based on that material.
3.1 Adherence to Reaulatory Guide 1.97 The applicant has provided a review of their post-accident monitoring instrumentation that compares the instrumentation characteristics against the recomendations of Regulatory Guide 1.97, Revision 3.
The applicant states that in several instances, satisfactory instrumentation exists and.
that additional-instrumentation will be installed to comply with Regulatory Guide 1.97, except for those instances where deviations are technically justified. The applicant states that those modifications identified will be completed prior to fuel load. Therefore, we conclude that the applicant has provided an explicit commitment on conformance to Regulatory Guide 1.97, except for those deviations that were justified by the applicant as noted in Section 3.3.
3.2 Tvoe A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide information required to permit the control room operator to take specific manually controlled safety actions.
The applicant classifies the following instrumentation as Type A.
1.
Degrees of subcooling 2.
Steam generator pressure 3.
Core exit temperature 4.
Steam generator level 4
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Pressurizer level 6.
Refueling water storage tank level 7.
Reactor coolant system pressure 8.
Containment hydrogen concentration j
These variables meet the Category 1 requirements consistent with the requirements for Type A variables, except as noted in Section 3.3.
3.3 Exceptions to Reaulatory Guide 1.97
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i The applicant identified the following deviations and exceptions to Regulatory Guide 1.97.
These are discussed in the following paragraphs.
3.3.1 RCS Cold Leo Water Temperature RCS Hot Leo Water Temperature l
Regulatory Guide 1.97 recommends Category 1 instrumentation for these variables. As such, channels should be independent and redundant. The applicant's instrumentation is redundant; however, the channels for the cold leg water temperature are powered by one power _ source, and the channels for the hot leg water temperature are powered by another power source.
The power sources are uninterruptable power supplies (UPS) that'are backed by battery and by diesel generator. The hot leg. temperature instrumentation is powered by one UPS, the cold leg temperature instrumentation is powered by a second UPS. ' Diverse instrumentation (core exit temperature and steam generator pressure) are powered by additional UPS power sources. These power sources were previously reviewed by the NRC and found acceptable. 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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s 3.3.2 Containment Sumo Water Level The applicant is not supplying narrow range instruments specifically
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for this variable. The narrow range instrumentation is stated to meet the guidance of Regulatory Guide 1.45 and NUREG-0737, Item II.F.1.
The applicant states that abnormal leakage is detected with this instrumentation when'the leakage is insufficient to actuate the engineered safety features system and it is not monitored by accident procedures.
The Category 1 wide range instruments cover the entire range of expected water levels for-post-accident conditions. Based on this, we conclude that (a) the range is' sufficient to monitor the sump operation for l
any anticipated condition.and (b) the sump level is adequately monitored by the existing instrumentation-Therefore, we find that the instrumentation i
provided for this' variable is acceptable.
3.3.3 Containment Isolation Valve position From the information provided, we find that the applicant 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 3 of Regulatory Guide 1.97.
Therefore, we find that the instrumentation for this variable is acceptable.
3.3.4 Radiation level in Circulatina Primary Coolant The applicant indicates that radiation level measurements to indicate fuel cladding failure are provided by the post-accident sampling system, that is being reviewed by the NRC as part of.their review of WUREG-0737, Item 11.8.3.
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Based on the alternate instrumentation provided by the applicant, we conclude that the instrumentation' supplied for this variable is adequate and, therefore, acceptable.
3.3.5 Effluent Radioactivity - Noble Gases Regulatory Guide 1.97 recomends instrumentation for this variable with a range of 10~ to 10 pC1/cc..The applicant notes a deviation from'the recommended range'in that the first instrument that the effluent.
cps'(or'6 x 10
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is monitored by has a range of 10 to 10 10 pC1/cc). The effluent is then routed to the main plant vent-stack, where it is monitored over the range of 10~ 'to 10 pCi/cc prior _to discharge into the atmosphere. We find the provided instrumentation acceptable for the post-accident' effluent flow path.
3.3.6 Residual Heat Removal Heat Exchancer Outlet Temperature Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 40 to 350*F. The applicant's instrumentation has a range of 50 to 400'F. The deviation in the lower limit of the range 15 10or 2.5 percent of the upper limit of the range.
The applicant states that the residual. heat removal: system is. Cooled i
by the component cooling water, which.is automatically held at.85'f, and~
J alarmed if the temperature drops to 75'F.
The applicant states that this gives the operator sufficient time to correct any defect prior to the temperature falling to 60*F.
1;j Based on the applicant's justification, we find this range adequata to, b
a monitor this variable during post-accident conditions, j
1 3.3.7 Accumulator Level and Pressure-
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Regulatory Guide 1.97 recomends Category 21Astfumentation to monitor.
the status of the accumulators. A range of 10 to_90 percent:1evel and 0 to 750 psig is recommended. The applicant has not. identified' instrumentation for this variable.
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The applicant states that if the accumulators do not perform their intended safety function, there is nothing the operator can do to correct the situation, assuming the accumulator isolation valves are open (these valves are monitored in accordance with the regulatory guide). The only operator action relative to the accumulators in an accident situation is to isolate them. Isolation, regardless of accumulator discharge, is determined by the reactor coolant system (RCS) subcooling being greater than 80*F,.and RCS hot leg temperature being less than 400*F.
If an isolation valve fails to shut, the operator then opens an accumulator vent valve. The position of these valves'is monitored by Category 2 instrumentation.
The applicant has not provided the information required by Section 6.2-of Supplement No. 1 of NUREG-0737 for this variable. An environmentally qualified instrument is necessary to moniior the status of these tanks.
The applicant should designate either level or pressure as the key variable-to directly indicate accumulator discharge and provide Category 2 instrumentation that meets the recommended range for.that variable.
The applicant should provide the required information, identify any deviation from Regulatory Guide 1.97 and provide supporting justification for those deviations.
l 3.3.6 Refuelina Water Storace Tank Level Regulatory Guide 1.97 recommends instrumentation for this variable l
with a range from top to bottom. The applicant's instrumentation has a
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range of 22,000 to 485,500 gallons.. The applicant states that this range
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covers the usable volume of the tank. The deviation in 22,000 gallons from f
the bottom of the tank is 4.5 percent of the total tank volume, fi i
We find this deviation minor with respect to the overall size of the-tank. The instrumentation is adequate to monitor. the operation of the
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t y-storage tank during all accident and post-accident conditions,. 1herefore, this is an acceptable deviation from Regulatory Guide 1.97.
l 3.3.9' Pressurizer Level 1
Regulatory Guide 1.97 recommends instrumentation for this variable with a range from top to bottom. The applicant's instrumentation for this l,
' 94 percent of the pressurizer volume). It does not indicate the volume in variable has a range of 61.75 to 581.25 incf.es (approximately 10 to i.a l
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t the hestsptdrical ends of the vessel.
1 Outside of the supplied tratrument range, in the hemispherical vessel ends, the volume 4 to level ratio is Act linear (approximately 16 percent of C
the total vol we). We find this deviation minor und.,therefore, acceptable.
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s 3.3.1C Pressurizer Heater Stat!.i Regulatory Guide 1.97 recommends Categrry 2 instrumentat On for this.
I viriable that measures electric current. The applicant's instrumentation J
. is Category 2 except for environmental qualification and measures kilowatts
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of power instead of current.
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Thekilowattsofpowerusedbythepressurizerfjeatershasadirect 4
relation to the heater current. Base 6 on our review)and judgement, we find
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1 this deviation of measuring pressurizar heatsb input power rather than
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3 current acceptab'ie, since the heater power h@a known relation to the c.
heater current.
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The applicant states that the instrumentation is acceptable because the pressurizer heaters are not requirM for the mitigation of a' design 1
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basis accident, and they are not considered safety-related.-
Environmental qualification has Men clarified by the Environmental Qualification Rule, 10 CFR 50.49. Thetcyplicant should therefore provide
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the required justification for this deviation from Regulatory Guide 1.97 or provide instrumentation that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97.
3.3.11 Quench Tarik Temperature Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 50 to 750*F. The applicant's instrumentation has a. range of 50 to 250*F. The applicant states that the operators will be aware of this limitation in the temperature measurement, that enveloping any J
expected temperature is not necessary and that the range is adequate to indicate off normal conditions.
The applicant has not provided adequate justification for this deviation. The applicant should show that the temperature indication will remain functional and on-scale, including the maximum expected saturation temperature, during any accident that lifts the pressurizer relief valves.
3.3.12 Steam Generator Level i
1 Regulatory Guide 1.97 recommends instrumentation for this variable l
with a range from the tube sheet to the separators.- The applicant's instrumentation has a range from 22 inches above the tube sheet to above the separators.
The steam generator is essentially empty when the water is at j
22 inches above the tube sheet. Therefore, this deviation is minor with respect to the overall range and system accuracy. The existing range is adequate to nonitor this variable.during all accident and post-accident conditions.
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.1 3.3.13 Steam Generator Pressure
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Regulatory Guide 1.97.recomends instrumentation for this variable I
with a range from 0 to 20 percent above the lowest safety valve setpoint (0 to 1425 psig). The applicant's instrumentation has a range of 0 to I
1300 psig.
The applicant states that the setpoint of the lowest setting safety valve is 1185 psig, and that the setpoint of the highest setting. safety valve is 1255 psig. Thus, there is a margin of 3.6 percent above the f
setpoint of the highest setting safety valve before the range would be exceeded. The safety valves together can handle the entire steam flow at full reactor power.
Based on the applicant's justification, we find the existing range adequate to monitor the steam generator pressure during all accident and
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In addition, each steam generator has a Category 3 l
channel of instrumentation w'ith a range of 0 to 1500 psig.
3.3.14 Containment Spray Flow
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i Regulatory Guide 1.97 recommends instrumentation for this variable j
with a range of 0 to 110 percent of design flow. The applicant has i
instrumentation to monitor the operation of the containment spray system that consists of pump suction pressure (0 to 60 psig) and pump discharge pressure (0 to 500 psig). These indicators are located next to each other on the main control board. The applicant states that actual flow measurement is not needed in support of the emergency response procedures, and that the operators will be trained in the use of this instrumentation j
to verify operation of the containment spray.
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The applicant has alternate instrumentation, consisting of pump suction pressure and pump discharge pressure. Additionally, the effectiveness of the containment spray can be shown by the containment temperature and pressure trends.
The alternate instrumentation provided by the applicant is adequate to J
monitor this variable. Therefore, we find this deviation acceptable.
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3.3.15 Heat Removal by the Containment Fan Heat Removal System Regulatory Guide 1.97 recommends Category 2 instrumentation for this l
variable. The applicant states that this.is not considered accident i
monitoring instrumentation because the containment fan coolers are not required to mitigate design basis events, nor do the emergency response procedures require the' operator to monitor their operation.
The applicant states that the containment air coolers are not used in accident and post-accident conditions. Therefore, post-accident monitoring.
1s not provided. We find that this position is acceptable for this variable.
3.3.16 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends instrumentation for 'this variable l
t with a range of 40'to 400'F. The applicant's instrumentation has a range of 50 to 420*F. The applicant states that.the containment air temperature.
will be greater than 50*F during or after any accident.
As the temperature will remain on scale for any accident or post-accident condition, we find the range of 50 to 420*F adequate to-monitor this variable.
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e 3.3.17 Containment Sumo Water Temoerature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 50 to 250*f. The' applicant states that the emergency response procedures do not require the operator to observe this j
variable.
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This is insufficient justification for this exception. The applicant should provide the recom wnded instrumentation for the functions outlined in Regulatory Guide 1.97 or identify other instruments-(i.e., residual heat
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removal (RHR) heat exchanger inlet temperature).that provide the same information and satisfy the reconnendations of the regulatory guide, i
3.3.18 Makeuo Flow-In
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l Letdown Flow-Out Regulatory Guide 1.97 recommends Category 2 instrumentation for these-variables. The applicant has Category 3 instrumentation, stating that this-l instrumentation is not part of a s'afety system, and not required in the mitigation of a design basis accident.
i As these variables are not utilized in conjunction with a safety system, we find that the instrumentation provided is acceptable.
3.3.19 Volume Control Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from top to bottom. The applicant has Category 3 i
instrumentation that covers the 80 inch straight shell height, not including the hemispherical ends of the tank.
The. applicant states that this variable would only be used if letdown and makeup are reestablished following the containment isolation and:that the volume control system is not a safety system. The level is not monitored in the hemispherical ends of the tank because the volume to level-
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ratio is non-linear.
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' i As this variable is not utilized in conjunction with a safety system, we find that the Category 3 instrumentation is acceptable. Outside of'the j
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supplied instrument range, the volume to level ratio is not linear. We find this deviation minor and, therefore, acceptable.
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3.3.20 component Coolina Water Temperature to Enoineered Safety Feature System Regulatory Guide 1.97 recommends instrumentation for this variable with a range from 40 to 200*F. The applicant's instrumentation has a rang,*
of 0 to 175'F. The applicant justifies thi: deviation by stating that the maximum design component cooling water temperature under accident conditions is 120*F.
We find this deviation acceptable. The existing range is capable of indicating any expected accident or post-accident temperature for this variable.
3.3.21 Hiah Level Radioactive Liouid Tank Level l
Regulatory Guide 1.97 recommends instrumentation for this' variable j
with a range from'the top to the bottom of the tank. The applicant's instrumentation covers a range of the top fourteen feet of the tank rather q
than the eighteen foot tank height. The applicant states that the bottom.
j 4 feet of the tank is a hemispherical bottom section, where the volume to 1evel ratio is not linear.
This range is adequate to indicate the storage volume of the tank during all accident and post-accident conditions. Therefore, this deviation is acceptable.
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3.3.22 Radioactive Gas Holdup Tank pressure j
Regulatory Guide 1.9i reconnends instrumentation for this variable.
The Seabrook Station does not have radioactive gas holdup tanks, using
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carbon delay beds instead. Thus, instrumentation for this variable is not needed.
3.3.23 vent From Steam Generator Safety Relief Valves - Nob'e Gas i
Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10'I to 10 pCi/cc._ The applicant's instrumentation reads out a range of 1 to 10 mR/hr. An offsite dose assessment procedure converts this readout to the equivalent pCi/cc. The safety relief valve position is used to determine the duration of the release for
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use in this same procedure.
l We find the instrumentation provided for this variable acceptable to provide release assessment.
3.3.24 Accident Samplino (Primary Coolant. Containment Air and Sump)
The applicant's post-accident sampling system provides sampling and analysis as reconnended by the regulatory guide, except for the dissolved oxygen content of the primary' coolant and sump contents.. The applicant 6
states that Criterion 4 of NUREG-0737. Item 11.B.3 recommends this parameter, but does not make it mandatory.
The applicant 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 th'etr review of NUREG-0737. Item II.B.3.
3.3.25 Boric Acid Charoino Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. In Amendment 57 to the final Safety Analysis keport (tsar), ine 15
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. applicant identifies Category 3 instrumentation. No justification was'
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l The applicant should either upgrade this instrumentation to Category 2.
or justify the use of the existing instrumentation.
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CONCLUSIONS Based on our review, we find that the applicant either conforms to or.
is justified in deviating from Regulatory Guide.1.97, with the following exceptions:
.1.
Accumulator level and pressure--the applicant should designate either level or pressure as the key variable, provide Category 2 instrumentation for that variable, provide the information-required by Section 6.2 of Supplement No. 1 of NURE6-0737, identify any deviations and justify those deviations.
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(Section 3.3.7).
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Pressurizer heater status--the applicant should verify that this.
instrumentation has been addressed in accordance with 10 CFR 50.49 (Section 3.3.10).
3.
Quench tank temperature--the applicant should show that the indication will remain functional and on scale during any.
accident that' lifts the pressurizer' relief valves
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.(Section.3.3.11).
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Containment sump water temperature--the applicant should provide
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the recommended instrumentation or identify alternate I
instrumentation that provides the same information and satisfies.
g the regulatory guide (Section 3.3.17).
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Bor,1c acid charging flow--the applicant should either. provide Cat'egory 2 instrumentation for this variable.or justify the use of the present instrumentation (Section 3.3.25).
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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 Followino an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TN! Action Plan Reauirements. Requirements for Emeroency Response Capability, NUREG-0737, Supplement No.1 NRC, Office of Nuclear Reactor Regulation, January 1983.
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Public Service of New Hampshire, New Hampshire Yankee Division letter, J. DeVincentis to G. W. Knighton, NRC, " Accident Nonitoring Instrumentation Review and Compliance with Regulatory Guide 1.97."
August 30,1985, SBN-864 T. F. 87.1.2.
5.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conc itions Durina and Followino an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
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BISUOGRAPHIC DATA SHEET EGG-NTA-7256
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Conformance to Regulatory Guide 1.97, Seabrook Station Unit Nos. I and 2 4 D.f.. 90.,Coaseg.Teo
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May 1986:
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ii.vvn oe.e.o.1 Division of PWR, Licensing-A.
Preliminary Technical-Office of Nuclear Reactor Regulation Evaluation Report,
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U. S. Nuclear Regulatory Commission Washington, DC 20555 it Suppt,Gn ser v o784
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This EG&G Idaho, Inc. report reviews' the submittal for Unit Nos.1' and 2 of the Seabrook Station, and identifies areas of nonconfomance to.
Exceptions to these guidelines are evaluated and-those areas where sufficient basis for acceptability is not provided are identified.
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