ML20215E126
| ML20215E126 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 11/30/1986 |
| From: | Tawfik M, Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20215E104 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-EA-6866, EGG-EA-6866-R02, EGG-EA-6866-R2, TAC-51366, NUDOCS 8612170302 | |
| Download: ML20215E126 (34) | |
Text
EGG-EA-6866 November 1986 Revision 2 INFORMAL REPORT t
r-4 Idaho National c0NFORitANCE TO REGULATORY GUIDE 1.97 i
Engineering YANKEE R0WE GENERATING STATION Laboratory Managed by the U.S.
M. S. Tawf1k Department A C Udy
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Prepared for the 4
U. S. NUCLEAR REGULATORY COMMISSION w, - _,
DOE Cetract No. DE-AC07-MID0tS70
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EGG-EA-6866 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97 YANKEE R0WE SENERATING STATION Docket No. 50-29 M. S. Tawfik g
A. C. Udy e
Published November 1986 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483
1 ABSTRACT
,5
.This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97, Revision 3 for the Yankee Rowe 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.
G Docket No. 50-29 TAC No. 51366 11
FOREWORD This report is supplied as part of the " Program for Evaluating I
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 20-19-10-11-3.
F l
Docket No. 50-29 TAC No. 51366 111
CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
11 1.
INTRODUCTION....................................................
1 2.
REVIEW REQUIREMENTS..............................................
2 3.
EVALUATION.......................................................
4 3.1 Adherence to Regulatory Guide 1.97.........................
4 3.2 Type A Variables...........................................
4 3.3 Exceptions to Regulatory Guide 1.97........................
5 4.
CONCLUSIONS......................................................
18 ch 5.
REFERENCES.......................................................
19 APPENDIX A............................................................
20 APPENDIX 8............................................................
25 D
P iv
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CONFORMANCE TO REGULATORY GUIDE 1.97 YANKEE R0WE' GENERATING STATION 1.
INTRODUCTION 4
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 cperating 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 j
' No.'~1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
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Yankee Atomic Electric Company (YAEC), the licensee for the Yankee Rowe Generating Station, provided a response to Regulatory Guide 1.97, Revision 3 (Reference 4), on April 19,1983 (Reference 5), and on August 30, 1983 (Reference 6). Additional information was provided on January 19, 1984 (Reference 7), on October 22, 1985 (Reference 8), and on September 30, 1986 (Reference 9).
d This report provides an evaluation of these submittals, f
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f-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
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g 3.
Seismic qualification 4.
Quality assurance i
5.
Redundance and sensor. location 6.
Power supply 7.
Location of display 8.
Schedule of installation or upgrade 6
The submittal should identify deviations from the regulatory guide and provide supporting justification or alternatives.
Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on this 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, i
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 1s an audit of the licensee's submittals based on the
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review policy described in the NRC regional meetings.
t h
4 4
3
3.
EVALUATION The licensee provided a response to Section 6.2 of NRC Generic Letter 82-33 on August 30, 1983 (Reference 6).
This evaluation is based on that and subsequent submittals.
3.1 Adherence to Reaulatory Guide 1.97 The licensee has reviewed the recommendations of Regulatory Guide 1.97, Revision 3, and has submitted a report that describes the compliance of the instrumentation used for measurement and indication for the variables identified in the regulatory guide. The submittal lists instrumentation for which the licensee has proposed alternate means of
' g compliance with the intent of Regulatory Guide 1.97, Revision 3, along with the licensee's justification for the alternate means.
The licensee is j
committed to complete those modifications identified for compliance with Regulatory Guide 1.97 by the start of Cycle 18 operation (Reference 10).
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.
4 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 f
control room operator to take specific manually controlled safety actions.
The licensee classifies the following instrumentation as Type A.
1.
Reactor coolant system (RCS) pressure 2.
Pressurizer level 3.
Steam generator level 4.
Core exit temperature 4
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5.
Safety injection tank level The above instrumentation meets the Category I recommendations consistent with the requirements for Type A variables, with the exceptions as listed in Section 3.3.
3.3 Exceptions to Reaulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.
3.3.1 Environmental and Seismic Qualifications g
-Environmental The licensee originally identified deviations from the Regulatory Guide 1.97 environmental qualification recommendations for the systems shown in Appendix A.
The licensee states, in Reference 8, that the Environmental Qualification Program contains all of the equipment required to meet the requirements of 10 CFR 50.49, which includes applicable Regulatory Guide 1.97 instrumentation. The licensee's position on the environmental qualification of the instrumentation in question is listed in Appendix A.
f Seismic Regulatory Guide 1.97 recommends seismic qualification for all Category 1 instrumentation. The licensee states in Note #1 of Reference 7 that the instrumentation is not part of the hot shutdown system, and therefore, need not be seismically qualified. The licensee indicates, in Reference 8, that the only instrumentation identified to require seismic qualification at Yankee per the Integrated Plant Safety Assessment (Systematic Evaluation Program) is:
f 5
l
.o Pressurizer level o
Pressurizer pressure o
Cold leg temperature (one per loop) o Steam generator level (one per loop) o Steam generator pressure (one per loop)
This instrumentation will be installed as part of the seismic upgrade of
- h the plant.
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.
3.3.2 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee indicated in Reference 7 that the Vital Instrument Bus 1 (VB1) is the only power source for the neutron flux channels. The licensee states that two additional source range channels (range of 1 to 100,000 counts per second (CPS)) are available.
None of this instrumentation is environmentally qualified. These two additional channels have a separate power source.
The licensee states that the control rod position indication, RCS soluble boron concentration samples and RCS temperature will provide additional long-term information.
The two additional source range channels are powered separately from VB1, however, they do not cover the full range recommended by the regulatory guide.
They are only redundant for the two source range 6
= - _ - _ _ _ _ = _ = _ _ _ = - -
channels SR1 and SR2. Having VB1 as the single power source for all neutron flux channels that cover the recommended range does not comply with the single failure criteria.
The licensee's statement concerning control rod position indication, RCS soluble boron concentration samples and RCS temperature as alternate indication is not acceptable. The first two systems are Category 3.
Therefore, they are not an acceptable substitute for the neutron flux i
instrumentation.
The licensee repeated, in References 8 and 9, the above mentioned information. They state that because a scram will occur with the loss of VB-1, Category 1 instrumentation is not necessary. The licensee states that after a reactor scram occurs, the neutron flux decays to less than I
100,000 CPS. Thus, the licensee contends that the source range instrumentation can be used to detect an uncontrolled approach to criticality. Procedures call for emergency boration on any increases in i
flux level. Recorded flux levels will verify the initial shutdown.
Borated safety injection water prevents a return to criticality for loss of coolant accidents, and the licensee's safety analysis shows that a return to criticality is not a concern for steamline breaks as shutdown margin is i
maintained.
The neutron flux instrumentation is recommended for post-accident monitoring, after a scram has occurred for long term monitoring. The measurement of neutron flux is a key variable for detecting an uncontrolled g
approach to criticality, be it inadvertant boron dilution event or other l
reactivity addition situation resulting from accidents, and for the determination that an accident has been and is continuously successfully 7
l mitigated. Since key variables are classified Category 1, the licensee should commit to the installation of instrumentation for this variable that is in accordance with Regulatory Guide 1.97.
7 l
3.3.3-Reactor Coolant System (RCS) Soluble Boron Concentration Regulatory Guide 1.97 recommends continuous indicating instrumentation with a range from 0 to 6000 ppm for this variable. The licensee provides grab sampling only but did not indicate that they meet the recommended range.
The licensee deviates from Regulatory Guide 1.97 with respect to the range of this 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 11.8.3.
1 3.3.4 Core Exit Temperature
.h Regulatory Guide 1.97 classifies this variable as Category 1.
The licensee states that compliance with the design requirements specified in Item II.F.2 of NUREG-0737 is addressed in their letter RYR-83-69, dated July 28, 1983, to the NRC.
The NRC is reviewing the acceptability of this Eariable as part of i
their review of NUREG-0737, Item II.F.2.
i 3.3.5 Reactor Coolant Inventerv i
Regulatory Guide 1.97 classifies this variable as Category 1.
The Ii licensee states that this instrumentation has been addressed in their letter to the NRC dated March 10, 1983, the NRC letter to the Yankee Atomic Electric Company dated June 27, 1983, and by their letter to the NRC, dated July 28, 1983 on the subject of Inadequate Core Cooling Instrumentation.
l The NRC is reviewing the acceptability of this variable as part of
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their review of NUREG-0737, Item II.F.2.
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3.3.6 Dearees of Subcoolino
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l Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from 200*F subcooling to 35'F superheat. The licensee indicates that l
the provided range.is from 0 to 999'F. The licensee states that saturation margin is provided without the inclusion of superheat indication, that saturation margin can be determined by redundant pressure and temperature channels, and that the safety parameter display systems (SPDS)
Independently calculates the saturation margin.
l 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 Isolation Valve Position Regulatory Guide 1.97 classifies the containment isolation valve position indication system as Category 1.
The licensee indicates that they provide one channel for each valve and that 125 Vdc station battery 3 is the only' power source for this instrumentation.
1
.From the information provided, we find the Itcensee 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). 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.
1 9 The licensee states that the NRC reviewed and accepted the containment isolation provisions, including valve position instrumentation, as part of the Systematic Evaluation Program.
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.
9 i
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3.3.8 Radioactivity Concentration or Radiation Level in Circulatina Primary Coolant The licensee indicates that the post-accident sampling system is used to monitor reactor coolant radiation levels.
In addition, a local area radiation monitor also provides indication in the main control room.
i Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and is, therefore, acceptable.
3.3.9 Residual Heat Removal (RHR) Heat Exchanaer Outlet Temoarature g
Revision 3 of Regulatory Guide 1.97 recommends a range from 40 to 350*F.for this instrumentation. The licensee provides a range from 50 to 350*F. We find this deviation minor and, therefore, acceptable.
3.3.10 Boric Acid Chargino Flow The licensee does not have instrumentation for 'this variable. The i
Itcensee states that boric acid charging flow is not part of the i-safety-injection system; that boration is done with the high and low pressure safety-injection systems.
Therefore, we find that this variable is not applicable at the Yankee Rowe Station.
I i
3.3.11 Flow in Low Pressure Safety Injection (LPSI) System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from 0 to 110 percent design flow.
The licensee does not provide this instrumentation. Their justification is that this system has a short term function and system flow can be adequately derived by l
observing the safety injection tank level and the high pressure safety injection (HPSI) flow. They also indicate that the total injection flow (LPSI and HPSI) for each RCS loop is available on Category 3 instrumentation.
LPSI flow is the difference between the total injection flow and the HPSI header flow.
10
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This LPSI system does not have a long term recirculation function.
In recirculation, the LPSI pumps take water from the containment sump and pump it to the suction of the HPSI pumps. The HPSI header flow will be equal to
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the flow through the LPSI pumps.
Based on the justification provided by the licensee, we find this instrumentation acceptable.
3.3.12 Pressurizer Level Regulatory Guide 1.97 recommends instrumentation with a range from the top to the bottom (0 to 408 inches) of the pressurizer. The licensee has three instrument channels with ranges from 20 to 360 inches, from 20 to 360 inches and from 40 to 160 inches, respectively.
The instrumentation provided for this variable does not indicate the 5
volume in the hemispherical ends of the vessel. The level indication is provided for the cylindrical portion of the pressurizer (approximately 90 percent of the total volume). We find this deviation minor and acceptable.
3.3.13 Pressurizer Heater Status Regulatory Guide 1.97 recommends electric current instrumentation for this variable. The licensee provides kilowatt-hour meters and indicating lights associated with the controls for each of the 8 groups of heaters.
The disc speed of the kilowatt-hour meters has a relation to the heater g
current. Additionally, diesel generators that can be used for a source of pressurizer heater power are monitored for volts, amperes and kilowatts in the control room.
The kilowatts of power used by the pressurizer heaters has a direct relation to the heater current. Based on our review and judgement, we find o
this deviation of measuring pressurizer heater input power rather than current acceptable, since the heater power has a known relation to heater current. When emergency power is supplied to the pressurizer heaters the 11
increase in diesel generator current is directly observable in the control room. Therefore, we find the instrumentation provided for this variable acceptable.
3.3.14 Auxiliary or Emeroency Feedwater Flow Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from 0 to 110 percent of the design flow. The design flow, as stated in Reference 8, is 80 gallons per minute. Thus, the provided range of 0 to 150 gallons per minute is acceptable.
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3.3.15 Heat Removal by the Containment Fan Heat Removal System j.
Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee did not provide this instrumentation. Their
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justification is that the containment heat removal system does not depend on any active components.* It is a passive. system.
We find the justification provided by the licens,ee for not supplying instrumentation for this variable acceptable.
3.3.16 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from 40 to 400*F. The licensee provides 25 channels of Category 3 i
instrumentation, each with a range from 0 to 150*F and 10 channels of Category 3 instrumentation, each with a range from 0 to 120*F.
All post-accident heat inside the containment at Yankee Rowe is dissipated through the metal containment structure. There are no heat exchangers of air or fluid systems. The containment's primary indication of safety performance is core exit temperature and containment pressure.
Containment atmosphere temperature is a backup to these variables. As such, Category 3 instrumentation is acceptable.
12
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The licensee states that this instrumentation is not used 1
post-accident because the operator has no means available to change the containment atmosphere temperature due to the passive heat reject' ion design for containment cooling.
Based on this, we find the instrumentation provided for this variable acceptable.
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3.3.17 Containment Sumo Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from 50 to 250*f. The licensee does not provide the recommended instrumentation. Their justification is that the containment cooling is of the passive design, that adequate net positive suction heat is provided for emergency core cooling system (ECCS) pump operation and
- 'thar the number of ECCS pumps allowed to be in operation is based on the
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variable ' containment pressure. There is a correlation between containment pressure and sump water temperature at this station where there are no active cooling systems. Therefore, a quantitative measure of heat removal is not necessary. We conclude that the exception of this instrumentation at the Yankee Rowe station is acceptable.
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3.3.18 Volume Control Tank Level (Low Pressure Surce Tank) l Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from top to bottom (0 to 90 inches). The licensee provides a range l
cf 0 to 72. inches.
f The instrumentation provided for this variable does not indicate the volume in the hemispherical ends of the vessel. The level indication is provided for the cylindrical portion of the low pressure surge tank (approximately 90 percent of the total volume). We find this deviation minor and acceptable.
3.3.19 Coolina Water i
1.
Component cooling water temperature to engineered safety features (ESF) system l
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2.
Component cooling water flow to ESF system.
Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables.
The licensee states that the ESF systems are not cooled by component cooling water. The ESF system components are cooled by the
. pumped fluid, not by any auxiliary cooling water system.
Based on the cooling provisions of the ESF component design, we find this exception from the recomended component cooling water instrumentation acceptable.
3.3.20 Radioactive Gas Holduo Tank Pressure j
Regulatory Guide 1.97 reconsnends a range for this variable to cover from 0 to 150 percent of the design pressure. The instrumentation provided has a range from 0 to 100 psig. The design pressure is 100 psig. The licensee states the following justification for this deviation.
I'.
The tank, in 25 years, has never been pres,s.urized to greater than 50 percent of design pressure.
2.
A safety valve operates at 100 psig to prevent exceeding the tank design pressure.
3.
The waste gas compressors can only develop a discharge pressure I
of 84 psig.
4.
Accident analysis considers the release of the tank contents, resulting in a off-site release below the value allowed in 10 CFR 100.
Based on the licensee's justification, we find the range of 0 to 100 psig acceptable.
The readout for this instrumentation is local.
In the event of an accident that,would preclude access to this instrumentation, the system is 14
_ _ _ _.. __;._=__._.._.:__
isolated so that no additions to the tank contents can be made.
In addition, there are control room alarms should the pressure approach the tpper limit of the range.
We find the local 0 to 100 psig pressure indication in combination with control room alarms acceptable.
3.3.21 Emeroency Ventilation Damper Position Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee does not provide the instrumentation.
In their justification they state that the emergency ventilation systems are controlled locally. Damper position is changed manually, with no automatic functions.
6 Based on the licensee's description of this manually operated system and associated alarms, we find the lack of position indication in the control room for this variable acceptable.
3.3.22 Status of Standby Power Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee provides direct ir.dication in the main control room for part of the instrumentation and local indication with an alarm in the main control room for the other part with additional indirect indication in the main control room.
The licensee states that the switchgear room is g
immediately below the control room, and is readily accessible.
We find the control room indication and alarms in combination with the switchgear room indication acceptable.
3.3.23 Radiation Exposure Rate Regulatory Guide 1.97 recommends instrumentation for this variable 4
with a range from 10-I to 10 R/hr. The licensee provides 2
instrumentation with a range from 10-3 to 10 R/hr except in one 15 i
location that has _ range frma 10-# to 10 R/hr. The licensee states that the instrumentation complies with the intent of the regulatory guide and that access to equipment would not be permitted for radiation fields greater than 100 R/hr.
From a radiological standpoint, if the radiation levels reach or exceed the upper limit of the range (100 R/hr), personnel would not be permitted to the areas without portable monitoring (except for life saving). Therefore, we find the ranges for the radiation exposure rate monitors acceptable.
3.3.24 Common Plant or MultiDurDose Vent--Noble Gas and Vent Flow Rate
- I Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from 10 to 10 pC1/cc. The licensee has s
provided 2 overlapping channels of instrumentation that together cover from 3 x 10-6 to 10 pCi/cc. The licensee states that vent design flow is fixed and depends only on the number of fans operatipg (1 or 2).
We find that the instrumentation provided for this variable is adequate to monitor this variable during all accident and post-accident conditions.
3.3.25 All Identified Plant Release Points--Particulates and Halocens l
f Regulatory Guide 1.97 recommends Category 3 instrumentation for this variable with a range from 10 to 10 pC1/cc and 0 to 110 percent j
vent design flow.
The licensee monitors the operation of the fans and f
states that the vent design flow is fixed and depend: only on the number of fans operating-(1 or 2). Each fan is rated at 23,0':' CFM.
We find that the instrumentation provided for this variable is adequate to monitor this variable during all accident and post-accident conditions.
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3.3.26 Plant'and Environs Radiation (Portable Instrumentation) t Regulatory Guide 1.97 recommends instrumentation with a range from 10 to 10 R/hr photons f'or this variable. The licensee complies 3
except that the range is'11mit'ed to 10 R/hr. The licensee justifies the deviation by stating that higher ranges are not considered necessary since
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access to areas of extreme radiation would not be permitted.
We find this deviation acceptable, as the instrumentation is portable and would not be used to assess. levels of radiation greater than the range provided.
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3.3.27 Accident Samp11na (primary coolant containment air and sump)
The licensee deviates from the recommended sampling and analysis for dissolved oxygen and oxygen content.
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 l
NUREG-0737. Item II.B.3.
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4.
CONCLUSIONS Based on our review, we find that the licensee either con' forms to or is justified in deviating from Regulatory Guide 1.97, with the following exception:
1.
Neutron flux--the licensee should provide fully qualified Category 1 instrumentation with the recomended range for this variable.
(See Section 3.3.2 and Appendix A).
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5.
REFERENCES 1.
.NRC letter D. G. Eisenhut to All Licensees of Operating Reactors, l
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 Fo110wina an Accident, Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
3.
Clarification of TMI Action Plan Reauirements. Reauirements for Emeraency Response Capability, NUREG-737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4.
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 Standards j
Development, May 1983.
5.
Yankee Atomic Electric Company letter, J. A. Kay to Chief Operating Reactors Branch No. 5, Division of Licensing, April 19, 1983.
6.
Yankee Atomic Electric Company letter, L. H. Heider to Chief, Operating Reactors Branch No. 5, Division of Licensing, August 30, 1983.
7.
Yankee Atomic Electric Company letter, J. A. Kay to Chief, Operating Reactors Branch No. 5, Division of Licensing, " Additional Information for Response to Regulatory Guide 1.97," January 19, 1984.
8.
Yankee Atomic Electric Company letter, G. Papanic, Jr. to J. A. Zwolinski, NRC, " Response to Open Items-Regulatory Guide 1.97,"
October 22, 1985.
9.
Yankee Atomic Electric Company letter, G. Papanic, Jr. to i
E. M. McKenna, NRC, " Response to Request for Additional Information Regulatory Guide 1.97," September 30, 1986, FYR 86-091, DCC 86-147, 2.C2.1
- 10. NRC letter, D. M. Crutchfield to J. A. Kay, Yankee Atomic Electric i
Company, June 12, 1984.
e 19
APPENDIX A The licensee's original report states that these systems deviate from
.the regulatory guide environmental qualifications recomendations.
1.
Reactor coolant system (RCS) pressure sensors powered by vital bus 2--Reference 9 clarifies the instrumentation supplied for this variable. Those sensors powered by vital bus 2 are environmentally qualified. Should a steam generator tube rupture occur (which isolates'the qualified sensor on vital bus 2),
unqualified channels, in a mild containment environment will provide the needed information. We find that this instrumentation is acceptable.
2.
Neutron flux--the licensee states that there is no long term environmental qualification. The licensee states that alternate i
instrumentation for long term observation of the core conditions includes control rod position, boron concen,tration and RCS temperature.
The measurement of neutron flux is the key variable for detecting and directly observing an uncontrolled approach to criticality and for the determination that an accident has been successfully mitigated. Since key variables are Category 1, and includes I
environmental qualification, the licensee should commit to the installation of instrumentation for this variable that is in accordance with Regulatory Guide 1.97.
See Section 3.3.2.
i 3.
RCS hot leg water temperature--the licensee states that while this instrumentation is not qualified, the variable can also be monitored via the core exit temperature instrumentation. Also, since cooling occurs by way of the safety injection system, environmental qualification of this instrumentation fsr RCS hot leg water temperature is not necessary.
The licensee also has l
j 20
redundant qualified thermocouples that measure the coolant temperature in the reactor vessel head area.
The licensee's justification shows that the hot leg water temperature instrumentation is back-up instrumentation to the other supplied instrumentation. Therefore, we find the existing
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RCS hot leg water temperature indication acceptable.
O 4.
RCS cold leg water temperature--the licensee states that while this instrumentation is not qualified, the variable can also be monitored via the steam generator pressure instrumentation.
Also, since cooling occurs by way of the safety injection system, environmental qualification of the RCS cold leg water temperature instrumentation is not necessary. The core exit thermocouples I
monitor core cooling.
The licensee' justification rhows that the cold. leg water temperature instrumentation is back-up instrumentation to other supplied instrumentation. Therefore, we find the existing RCS cold leg water temperature indication acceptable.
5.
Degrees of subcooling--the licensee clarified, in Reference 9, that the RCS pressure inputs for this variable are environmentally qualified.
6.
Containment effluent radioactivity--noble gases from identified 6
release points--the licensee has committed to either replace, upgrade or to supply documentation to achieve environmental qualification for this instrumentation. We find this commitment acceptable.
7.
Effluent radioactivity--noble gases (from buildings as indicated)--the licensee has committed to either replace, upgrade or to supply documentation to achieve environmental qualification for this instrumentation. We find this committment acceptable.
21
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8.
Residual heat removal (RHR) system flow--the licensee states that the RHR functions are accomplished by the shutdown cooling system.
This system has the appropriate instrumenation located outside of containment in a mild environment.
We find the instrumentation supplied for this variable acceptable.
9.
RHR heat exchanger outlet temperature--the licensee states that the RHR functions are accomplished by the shutdown cooling system. This system has the appropriate instrumentation located outside of containment in a mild environment. We find the instrumentation supplied for this variable acceptable.
- 10. & 11. Accumulator tank level and pressure--the licensee states that there is one accumulator, located outside of containment in a
'I mild environment.
The accumulator is normally depressurized. An accident signal pressurizes the accumulator with nitrogen. The accumulator is isolated after discharge and the remaining nitrogen is vented automatically, due to low level switches.
The low pressure injection header, used for the accumulator injection, is isolated in establishing recirculation.
Based on the licensee's description of the accumulator design, we find the supplied instrumentation acceptable.
- 12. Accumulator isolation valve position--the licensee states that g
the position switch for the in-containment isolation valve (on the low pressure injection header) is environmentally qualified.
The other isolation valves concerned with the accumulator are located outside of the containment in a mild environment.
l Based on the licensee's description of the accumulator design, we find the supplied instrumentation acceptable.
- 13. Containment atmosphere temperature--the licensee states that since the containment is passively cooled, environmentally i
22
- 4 qualified instrumentation for this variable is not necessary (see Section 3.3.16).
Based on this justification, we find this deviation acceptable.
- 14. Makeup flow-in--the licensee states that because the charging system is automatically isolated and secured by an accident
~
signal, this instrumentation is not required to operate during or after a harsh environment. Additionally, this instrumentation is located outside of containment.
Based on the licensee's description of the charging system, we find the supplied instrumentation acceptable.
g
- 15. Letdown flow-out--the licensee states that because the charging i
system is automatically isolated and secured by an accident signal, this instrumentation is not required to operate during or after a harsh environment. The letdown line is automatically, and remains, isolated. Therefore, we find the provided instrumentation acceptable.
- 16. Volume control tank level--the licensee states that because the charging system is automatically secured by an accident signal, this instrumentation is not required to operate during or after a harsh environment. Additionally, this instrumentation is located outside of containment.
i Based on the licensee's description of the charging system, we find the supplied instrumentation acceptable.
- 17. Common plant vent or multipurpose vent--noble gases--the licensee has committed to either replace, upgrade or to supply 4
documentation to achieve environmental qualification for this instrumentation. We find this commitment acceptable.
4 i
23
.l
- 18. Vent from steam generator safety relief valves or atmospheric dump valves--the licensee states, in Reference 9, that this instrumentation is located outside of containment. The licensee
^
states that there are no high energy line breaks that could subject this instrumentation to a harsh environment.
Because of this, we find this instrumentation acceptable.
6
.5 0
24
APPENDIX 8 Category 1 systems affected by the licensee Note 1.
These systems were identified as not being seismically qualified in accordance with the seismic program of the time of licensing.
1.
Reactor coolant system (RCS) pressure 2.
Pressurizer level 3.
Steam generator level g-
4.
Core exit temperature 5.
Safety injection tank level 6.
Neutron flux 7.
RCS hot leg water temperature 8.
RCS cold leg water 9.
Containment sump water level, wide range f
- 10. Containment pressure 11.
Containment isolation valve position
- 12. Containment hydrogen concentration
- 13. Condensate storage tank water level A.
Primary water storage tank l
25 l
\\
l
~
B.
Demineralized water storage tank l
- 14. Containment area radiation O
O+
26
~
n 6
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BIBUOGRAPHIC DATA SHEET Revision 2 me eaverio= o e....n 3 La.w.
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fitL..see.u Tatg.
Conformance to Regulatory Guide 1.97, Yankee Rowe Generating Station e o.f....o.f co L.Teo oes t n
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. November 1986
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EGAG Idaho, Inc.
Idaho Falls, ID 83415
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... ev..o....o.1 Division of PWR Licensing A Technical Evaluation Report Office of Nuclear Reactor Regulation g
U. S. Nuclear, Regulatory Commission Washington, DC 20555 sg as.e.
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is T..cf samt news, er un, This EG8G Idaho, Inc. report reviews the submittals for the Yankee Roue Generating Station and identifies areas of nonconformance to Regulatory Guide 1.97.
Any exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability are not provided are identified.
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DEC09199g Distribution. Copies:
i I.kli Local PDR PAD #1 r/f PAD #1 p/f TNovak, Actg..DD NThompson, DHFT
'0GC-Bethesda EJordan BGrimes JPartlow GLear PShuttleworth EMcKenna ACRS 10)
LFMB TAC No. 51366) f t