ML20234D522

Safety Evaluation Re Conformance to Reg Guide 1.97

ML20234D522
Person / Time
Site:	Crystal River
Issue date:	06/16/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20234D495	List: ML20234D522 ML20234D548
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8707070244
Download: ML20234D522 (6)

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ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FLORIDA POWER CORPORATION ET. AL.

CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302 )

CONFORMANrE TO REGULATORY GUIDE 1.97

1.0 INTRODUCTION

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SUMMARY

The licensee, Florida Power Corporation, was requested by Generic letter 82-33 to provide a report to the NRC describing how the post-accident monitoring instrumentation neets the guidelines of Regulatory Guide -

l (RG) 1.97 as applied to emergency response facilities. The licensee's  !

'I response to RG 1.97 was provided by letters dated August 21, 1984, i j

November 15, 1985 and March 27, 1986.

A detailed review and technical evaluation of the licensee's submittals was performed by EG&G Idaho, Inc. under contract to the NRC, with general supervision by the NRC staff. This work was' reported by EGAG in the __

Technical Evaluation Report (TER), "Conformance to RG 1.97, Crystal River j Unit 3" dated May 1986 (attached). We have reviewed this report and concur with its conclusion that the licensee either conforms to, or has justified deviations from, the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable except for the pressurizer heater status.

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- 2 2.0 EVALUATION CRITERIA Subsequent to the issuance of the generic letter, NRC held regional meet-ings in February and March 1983 to answer the licensees' questions and concerns regarding NRC policy on RG 1.97. At these meetings, it was es- -

tab 11shed that NRC review would address only exceptions taken to the guidance of RG 1.97. Further, where the licensee explicitly stated that instrument systems conform to the provisions of the Regulatory Guide, no staff review would be necessary. Therefore, the review performed and re-ported by EG&G addresses only exceptions to the guidance of the Regulatory Guide. This safety evaluation addresses the licensee's submittals based on the review policy described in the NRC regional meetings and the con-clusions of the review as reported by EG&G.

3.0 EVALUATION 1

We have reviewed the evaluation performed by EG&G contained in the attached TER and concur with its bases and findings. In the TER, the licensee was found either to conform to the RG 1.97 recommendations or to have provided acceptable justification for deviating from those recommendations for each post-accident monitoring variable, except for the pressurizer heater status, ,

i Reactor Coolant System (RCS) soluble boron concentration, radiation level l

in circulating primary coolant, and post-accident sampling system. I 1

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RG 1.97 recommends the provision of Category 2 instrumentation to tronitor electric current flow to the pressurizer heaters. NUREG-0737, Item II.E.3.1 requires that some of these heaters be capable of being energized from emergency power sources and that instrumentation be provided to -

prevent overloading a diesel generator. The licensee. states that two of the pressurizer heater banks can be energized from emergency power (diesel generators). These two heater banks have only "on-off" control and are equipped with "en-off" lights to indicate' status. These lights indicate only that electric power is available to the heater bank but do not provide a direct and unambiguous indication of heater operation by indica-ting electric current flow through the heaters. While, as the licensee states, the diesel generator ammeters could be used to determine if over-loading has occurred, their sensitivity may not be sufficient to indicate proper operation of the heater banks. We therefore find the licensees's proposed exception not acceptable and require that instrumentation meeting 1

the requirement of RG 1.97 be provided to monitor pressurizer heater current in each pressurizer heater bank that is used to satisfy the reauire- ~ i ment of NUREG-0737, Item II.E.3.1.

The RCS soluble boron concentration, radiation level of circulating primary coolant, and the post-accident sampling system (PASS) were all reviewed as part of the resolution of NUREG-0737, Item II.B.3. In Reference 1 the staff found the RCS soluble boron concentration to be monitored through sampling

by in-line automatic titration equipment which meets the guidelines of both NUREG-0737. Items II.B.3 and PG 1.97. Therefore, this concern is resolved.

In References 1 and 2, the staff also found that the radiation level of

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the circulating primary coolant, which is an indication of fuel failure, can be determined from measured radionuclide concentrations provided by the PASS. The staff determined this was acceptable. In its review of the PASS, which provides capability for analyzing the activity and chemical content of the primary coolant, containment sump liquid and containment air, the staff found acceptable a sensitivity of 10 C1/ml. During their later review of the RG 1.97 submittals, the staff apparently found contra-dicting radiochemical measurement sensitivities of I and 10 C1/ml for the PASS. In a telecon with the staff, the licensee clarified the status and -

use of the radiochemical measurement capabilities of the PASS and stated that while the Automatic Isotopic Measurement System (AIMS) had a sensitivity of 1 Ci/ml and is part of the PASS, it is not used to meet the RG 1.97 Revision 3 guideline for Primary Coolant and Sump (Grab Sample) Gross Activity Monitoring. This guideline is met by grab sampling with the samples being sent offsite to ORNL for radiochemical analysis. Originally, the analytical sensitivity was specified to be 10 C1/ml which met the then current RG 1.97, Revision 2 guideline. The licensee stated their intent to meet the RG 1.97, Revision 3 guideline of luci/ml and will revise Page 66 of their RG 1.97 Compliance Table to state that samples are sent to s

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i ORNL for analysis and will obtain confirmation of ORNL's capability to meet the A1 Cf/ml sensitivity. On the basis of this additional clarifying information and the licensee's commitment to revise the RG 1.97 Compliance Table to meet the Revision 3 guidelines, the staff considers this concern j resolved. In addf eion, the staff did not require the PASS to have the -

capability for measuring dissolved oxygen and there was no need to measure I

containment air oxygen concentration since the containment is not purged and inerted. On this basis, the licensee's action of not providing

, instrumentation to monitor these latter two variables is found acceptable.

4.0 CONCLUSION

Based on the staff's review of the attached Technical Evaluation Report and the licensee's submittals, we find that the Crystal River Unit 3 design is acceptable with respect to conformance to RG 1.97, Revision 3, with the exception of the pressurizer heater status indication.

The staff concludes that instrumentation to monitor the status of the pressurizer heaters which is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and RG 1.97, Revision 3, shall be providad.

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I The licensee has stated that all modifications required to conform with RG 1.97 will be completed by December 31, 1987. The licensee is required ,

to inform the Commission, in writing, of any changes to that schedule, of-any significant changes to the implemented system from that approved in -

the staff's safety evaluation, and of the actual implementation completion dates.

5.0 REFERENCES

1. Letter, John F. Stolz, USNRC, to W. S. Wilgus, FPC, dated August 26, 1985.

2. Letter, John F. Stolz, USNRC, to W. S. Wilgus, FPC, dated November 12, 1985. j

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