ML20235L511
| ML20235L511 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/31/1986 |
| From: | Stoffel J EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML18052B360 | List: |
| References | |
| CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-EA-6926, TAC-51116, NUDOCS 8710050495 | |
| Download: ML20235L511 (29) | |
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EGG-EA-6926-1 I
l CONFORMANCE TO REGULATORY GUIDE 1.97 PALISADES PLANT J. W. Stoffel
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Pubitsbed July 1986 I
EG&G Idaho Inc.
I Prepared for the U.S. Nuclaar Regulatory Comission i
Washington, D.C.
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Under 00E Contract No. OE-AC07-76IO01570 FIN No. A6483 k
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ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory 4
Guide 1.97,. Revision 3, for the Palisades Plant and identifies areas of j
'I nonconformance to the regulatory. guide.
Exceptions.to,Regulat'ory i
Guide 1.97 are evaluated and those areas.where sufficient basis for acceptability is not provided_are identified.
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Docket No. 50-255 TAC No. 51116 j
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l FOREWORD
.s This~ report is supplied as part'of the " Program for Evaluating Licensee / Applicant 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..
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i The U.S. Nuclear Regulatory Commission funded the work under 1
.i authorization 20 10-l'l -3.
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Docket No. 50-255 TAC No. 51116-111 1
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CONTENTS k
ABSTRACT..............................................................
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.FOREWOR0..............................................................
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INTR 000CTION......................................................
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REVIEW REQUIREMENTS 3.
EVALUATION........................................................
4 3.1 Adherence to Regulatory Guide 1.97..........................
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, 3. 2 Type A Variables............................................
4 3.3 Exceptions t'o Regulatory Guide 1.97..........................
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CONCLUSIONS.......................................................
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1 5.
REFERENCES........................................................
17 APPENDIX A.............................................................
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s-i CONFORMANCE TO REGULATORY GUIDE 1.97 PALISADES PLANT
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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
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operating licensees 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 i
No. 1.to'NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Consumers Power Company, the licensee for the Palisades Plant, j
provided a response to the generic letter on April 14, 1983 (Reference 4).
On September 13, 1983 (Reference 5), the licensee provided the information required by Section 6.2 of the generic letter.
Additional information was provided on April 30, 1986-(Reference 6).
1 This report provides an evaluation of these submittals.
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REVIEW REQUIREMENTS
'Section 6.2 of NUREG-0737, Supplement No. 1, sets forth the g
documentation to be submitted in & report to the NRC describing how the licensee complies with Regulatory Guide 1.97'as applied to emergency j
resp'onse facilities.
The submittal should include documentation that j
provides the following information for each variable shown in the j
applicable table of Regulatory Guide 1.97.
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Instrument range 2.
Environmental qualification o
3.
Seismic qualification 4.
Quality assurance 5.
Redundance and sensor location 6.
Power supply 7.
Location of display I
8.
Schedule of installation or upgrade I
The submittal should identify any deviations from the recommendations of Regulatory Guide 1.97 and provide supporting justification or alternatives j
for those deviations identified.
Subsequent to the issuance of the generic letter, tne C0C held s
regional meetings in February and March 1983, to answer licensee and I
1 applicant questions and concerns regarding the NRC policy on this subject.
At these meeti.igs, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97.
Where licensees or applicants explicitly state that their instrument systems conform to the regulatory l
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guide, it was noted that no further staff review would be necessary.
Therefore..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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EVALUATION The licensee provided a response to Section 6.2 of NRC Generic Letter 82-33 on September 13. 1983. ' Additional information was provided on April 30, 1966.
This evaluation is based on these submittals.
3.1 Adherence to Regulatory Guide 1.97 i
The licensee submitted a schedule in their submittal that indicates that they will conform with the recommendations of Regulatory Guide 1.97, Revision 3 (Reference 7).
Therefore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97.
l Exceptions to and deviations from the regulatory guide are 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 the information required to permit the control room operator to take specific manually controlled safety actions.
The licensee classifies the following instrumentation as Type A.
1.
Degrees of subcooling 2.
Steam generator pressure 3.
Steam generator level
.4.
Pressurizer level This instrumentation meets the Category 1 recommendations consistent with the requirements for Type A variables, except as noted in Section 3.3.
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3.3 Exceptions to Reculatory Guide 1.97
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The licensee identified deviations and exceptions to Regulatory
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L Guide 1.97.
These are discussed in the following paragraphs.
3.3.1 Environment.1 Qualification Requirement Deviation
'The licensee stated in Reference 5 that the current environmental qualification requirement for the variables listed in Appendix A was not addressed when these systems were design'ed.
In Reference 6, the. licensee has addressed each of these 30 identified variables.
i We find, based on the modifications and justifications, provided by-the licensee, that all but two variables are acceptable. 'These are accumulator level and pressure and containment' sump water temperature.
a Environmentally qualified instrumentation should be provided for these variables.
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Deviations other than environmental qualification are addressed elsewhere in this report..
3.3.2 Seismic Qualification Requirement Deviation The licensee states that the current seismic qualification requirement for the following variables was not addressed when these systems were designed.
In Reference 6 the licensee has addressed each of these variables.
.A.
Neutron flux--in Reference 6, the licensee has committed to upgrade the existing nuclear instrumentation during the second upcomming refueling outage.
The upgraded instrumentation will be environmentally and seismically qualified.
B.
Reactor coolant system (RCS) cold leg water temperature--the temperature elements (RTO's) were upgraded during the 1985 refueling outage and two loops of seismically qualified loops of 5
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instrumentation will be installed during the refueling outage scheduled for. mid-1987.
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RCS hot leg water temperature--the temperature elements.(RTO's)-
were upgraded during the 1985 refueling outage and two' loops of-seismically qualified loops of instrumentation will be installe'd during the refueling outage scheduled for mid-1987.
D.
RCS pressure--in Reference 6 the licensee states that this variable was upgraded during the 1985 refueling-outage except'for the recorders.
The recorders are scheduled for. replacement with 1
seismically qualified components during the refueling _ outage-1 i
scheduled for mid-1987.
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Based on the justification and comitments made by the licensee in i
k Reference 6, we conclude that the seismic qualification recommendations of i
Regulatory Guide 1.97 have been met.
3.3.3 RCS Soluble Boron Concentration i
a Regulatory Guide 1.97 recomends a range of 0 to 6000 ppm for this
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variable.
The licensee has provided instrumentation with a range of 0 to-2050 ppm.
The licensee states that the range is within the limits for
. normal operation.
For an accident, all dissolved boron that can be pumped-into the RCS is injected, and the letdown side would be isolated to j
i maintain ~ flow into the primary system.
Since the boron meter is on the q
1etdown line, the licensee indicates that it would not be measuring primary system concentration at this tirne and, therefore, the range of the instrument is adequate for its intended function, i
The licensee takes exception to Regulatory Guide 1.97 with respect to l
post-accident sampling capability.
This exception goes beyond the scope of
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this review and is being addressed by the NRC as part of their review of NUREG-0737, Item 11.8.3.
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3.3.4 RCS Cold Lea Temperature i
In Reference 5, the licensee stated that the recorder for the RCS cold leg temperature instrumentation is powered from a non-Class 1E source.
In Reference.6, the licensee committed to change the, power supply for the temperature recorder to a Class 1E power source.
We find this commitment acceptable.
- 3.3.5 RCS pressure i
In Reference 5, the licensee stated that the instrumentation provided for this variable does not meet either the redundancy or the power supply, j
recommendations of Regulatory Guide 1.97.
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In Reference 6, the licensee states that redundant seismically and environmentally qualified pressure transmitters powered from separate Class 1E power sources were installed during the 1985 refueling outage.
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addition, the licensee has committed to install recorders that meet the
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regulatory guide recomen'dations during the next refueling outage. We find these changes and this comitment acceptable.
t 3.3.6 Core Exit Temperature Regulatory Guide 1.97 recommends instrumentation with a temperature range of 200 to 2300*F for this variable.
The licensee acknowledges a range deviation from the regulatory guide.
However, the existing range has not been provided and no justification for deviating from Regulatory
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Guide 1.97 was submitted.
The licensee states that the core cooling inst,rumentation project will address any inadequacies.
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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Regulatory Guide 1.97 recommends instrumentation with a temperature l
range of 200*F subcooling to 35'F superheat for this variable.
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o licensee's submittal acknowledges a range deviation from the regulatory guide, however, the existing range has not been provided.
The licensee states that the existing range is limited by current inputs and that the
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subcooling margin monitor will be upgraded as part of core cooling instrumentation project.
1 The NRC is reviewing the acceptability of this variable as part of their review of NUREG-0737 Item II.F.2.
3.3.8 Containment Isolation valve Position In Reference 5, the licensee identified a power source deviation for this variable.
In Reference 6, the licensee states that each containment penetration requiring isolation has two valves in series with control power provided from different trains of Class lE power.
Either of these valves is capable of performing the isolation function.
Position indication for each valve is powered from the valve's Class 1E control power.
Failure of a single power source results in the loss of position indication of one of the valves, but the position indication of the redundant valve performing the isolation function rpmains powered.
From the information provided, we find that the licensee deviates from a strict interpretation of the Category 1 redundancy recommendation.
Since redundant isolation valves are provided, we find that redundant indication
.per valve is not intended by the regulatory guide.
Therefore, we find that the instrumentation for this variable is acceptable.
3.3.9 Radioactivity Concentration Radiation Level in Circulating f
Primary Cooiant The licensee has one Category 3 channel of primary coolant radiation level instrumentation.
In addition, this information can be provided by the post-accident sampling system, wnich is being reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3.
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Based on the-alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is' adequate
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and, therefore, acceptable.
3.3.10 Accumulator Tank Pressure Regulatory Guide 1.97 recommends'a pressure range of 0 to 750 psig for this variable.
The instrumentation has a range of 0 to 300 psig.
The maximum operating pressure for this tank.is 250 psig and the relief valve settings on the tanks are set for 250 psig.
We find that the existing range is adequate to monitor any expected pressure.
Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
3.3.11 Pressurizer level In Reference 5, the licensee has identified deviations from the Category 1 recommendations for environmental qualification, seismic qualification and redundancy.
In Reference 6, the licensee states that one pressurizer level instrument loop was upgraded during the 1985 refueling outage and now complies with the Regulatory Guide 1.97 recommendations.
An additional level loop will be upgraded to Category 1 requirements in late 1988.
We find these changes and this commitment acceptable.
3.3.12 Ouench Tank Level The licensee has an existing range for this variable of 24 inches to 96 inches.
Regulatory Guide 1.97 recommends a range from the top to the bottom of the tank.
The licensee states that the tank is 114 inches high.
and that the effective range is to 93.6 percent level at 96 inches.
The tank would not be used if the level was below 24 inches.
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'O The level that is maintained in this tank is approximately 60 percent volume.
The existing low indication of this instrumentation is adequate to l
insure that the sparger is covered and sufficient fluid volume exists to quench the design, basis steam release.
The high indication is adequate to indicate sufficient gas volume to accept a pressurizer steam release j
without.becoming overpressurized and to indicate in-leakage from the relief discharge system.
Based on this information, we find the existing instrumentation adequate.
Therefore, this is an acceptable deviation from the regulatory' guide.
3.3.13 Ouench Tank Temperature Regulatory Guide 1.97 recommends a temperature range of 50 to 750*F for this variable.
The licensee has provided a range of 0 to 300'F.
The licensee states, in Reference 6, that.the tank is provided with a rupture disk to relieve an overpressure condition at the tank design pressure of 100 psig (347'F).
The licensee further states that the only event which could result in excessive temperatures on the quench tank would be a stuck open safety or relief valve.
Since these valves have qualified position indication, the quench tank temperature would only provide'cunfirnatory indication that the safely cr relief valves are stuck open.
The licensee has not provided adequate justification for this deviation.
The licensee should provide temperature indication that will i
remain functional and on scale, including the maximum expected saturation temperature, during any accident that lifts the pressurizer safety or relief valves.
3.3.14 Ouench Tank pressure The licensee has provided instrumentation for this variable with a pressure range of 0 to 25 psig.
Regulatory Guide 1.97 recommends a l
pressure range of 0 to design pressure.
The licensee acknowledges that the tank design pressure is 100 psig. The licensee' states, in Reference 6, that the tank is proviced with a rupture disk to relieve an overpressure 10
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condition at the tank design pressure of 100 psig.
The licensee further states that the only event which could resul't in excessive pressures in the'.
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quench tank would be a stuck open safety or power operated relief valve.
j Since these valves have qualified position indication, the quench tank pressure. indication would only provide confirmatory indication that the-safety or relief valves are stuck open.
The licensee also states that increasing the range of the quench tank pressure indication would decrease the sensitivity of the reading required during normal operation of the system.
The itcensee has not provided adequate justification for this deviation.
The licensee should provide pressure indication that will remain functional and on scale during any accident that lifts the pressurizer safety or power-operated relief valves.
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3.3.15 Steam Generator level
'In Reference 5, the licensee identified a seismic qualification deviation for this variable.
In Reference 6, the licensee states that changes were made to this instrumentation during the 1983 and 1985 refueling outages.
The wide-and narrow range steam generator. level I
instrumentation now meets the recommendations of Regulatory Guide 1.97.
3.3.16 Steam Generator Pressure In Reference 5, the licensee identified a Category 1 deviation for this variable.
The range of the existing instrumentation (0 to 1200 psig) was adequate to meet the recommendations of Regulatory Guide 1.97.
The licensee states, in Reference 6, that the steam generator pressure instrumentation loops were upgraded during the 1985 refueling outage and nos meet Category 1 requirements.
However, the range of the upgraded instrumentation is 0 to 1000 psig.
This upper range is 1.5 percent above the lowest safety valve setting and less than the highest safety valve l
l setting instead of the 20 percent above the lowest safety valve setting as reconsnended by the regulatory guide.
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We find this deviation unacceptable.
instrumentation range that will not remain-on scale during 411' accident.
conditions. -The licensee should' expand the range of this instruntnation'to coveranyexpectedpressurethatthesteamgeneratormidhtreach.
- 3. 3.1' 7 Main Feedwater Flow v.
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s Regulatory Guide 1.97 recommends a range of 0 to 110 percent of3 design 4
flow for this variable.
In Reference 5, the licensee submitted an l
incorrect value for the feedwater flow.
In Reference 6, the licensee ll
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states that the flow range is 0 to 12 x 10 lbs/hr.
This. range is 6.7 6
percent greater than the 11.25 x 10 lbs/hr design rate and adequate to monitor any potential overfeed occurences.
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We find this deviation minor and.,;therefore, acceptable.
3.3.18 Condensate Storace Tank Water' Level In Reference 5, the licensee identified a deviation from Regulatory Guide 1.97 for environmental qualification and seismic qualif) cation of the power supply for this variable.
In Reference 6, the licensee s tates that the power supply is located in a mild environment and will be upgraded by the end of the next refueling outage with seismically qualified j
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components. We find this comitment acceptable.
3.3.19 Containment Sump Water Temoeratura
, The licensee has not provided direct _ reading' instrumentation for this variable.
The justification submitted by'the licensee for. thie, deviat un iJ that the containment temperature monito75 would indicate the same temperature as the amo water when the containment atmosphere is at saturation.
In addition, after switchover to the recirculation mode, the sump water temperature can be monitored by reading the low pressure safety injection (LPSI) and containment spray (CS) pumo (,ischarge temperature.
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t'emperature.
The diverse'metho'ds of determining containment sump water temperature are, however, adequate to monitor the operation of the
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containment sump.
Therefore, this is an acceptable deviation from
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3.3.20 Volume control Tank level Regulatory Guide 1.97 recomends a top to bottom range for the level of this tank.
The licensee has instrumentation with a range of 0 to l
88 inches and considers this range adequate because it covers from 0 to 100 percent of the operating levels.
The tank would be isolated by any safety injection system actuation.
As the range is adequate to monitor the operation of this tank, this
-is an acceptable deviation from Regulatory Guide 1.97.
I i3.3.21 Component Coolina Water (CCW) Temperature to Enoinered Safety f
features (ESF) System The licensee takes exception to the temperature range recomended by the regulatory guide for this variable (40 to 200*F).
The licensee provides a range of 0 to 140*F.
The licensee states that t'ie discharge temperature of the component cooling water at the heat ex'. hanger discharge will remain between 65 to 90*F.
The range of the existing transmitter will
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cover this discharge temperature.
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Since the temperature at the heat exchanger discharge is maintained between 65 and 90*F, the existing temperature range will adequately cover any expected component cooling temperature for.the ESF system components.
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Therefore, this is an acceptable deviation from Regulatory Guide 1.97.
i 3.3.22 Component Coolina Water Flow to ESF System The licensee has not provided instrumentation for this variable.
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licensee states that proper operation of this system can be determined by j
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- monitohng CCW pump status and the' status of the vanes that arti; skuired I
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~. ' d, to be open. ' The licer see further staMs' that flow cc.n.trel is nc< vacuired '
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as the ;CCW ' pump" h either "on", with full flow, or "of
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' find this justification unacceptable.
The alternate 1
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3.3.23 Radioct'tive Gas Holdup Tank pressure m
y radeof0to Thelicenseehasprovided;instrumenjationwithps 120 psig for this. variable.
Regulatory uuide 1.97 reconsnends a range of 0 j
to 150 percent design pressure.
The licensee states that the design j
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pressure is 120 psig.
In Reference 6, the licensee states that the tanks
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are nolated when 80 percent of' design pressure is reached and an alarm
+ill initiatt 'st 83 percent of design pressure. l In addition, two relief 7.
valvesarese06tthetankdesignpresfureandhaveareliefcapacity greater than the design capacity of t-le compressors that discharge into the
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tanks.
J, Based on the justification provided4 by the' licensee, we find the i
existing instrument range adequate to m,onitor this variable.
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3.3.24 particulate and Halogens InReference5,thelicenseetochexceptiontoMoviding instrumentation for this variable as recommended by Regulatory Guide 1.97.
I In Rhference 6, the' licensee states that all aspects Nf the Regulatory i
Guide 1.97 reconrnendations for this variable have been' met.
We find this acceptable.
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3.3.25. Airborne Radiohalocens and Particulate
't-Plant and Envirens Radiation Plant and Environs Radioactivity In Reference 5, the licensee took exception to providing j
instrumentation for these variables as recommended by Regulatory Guide 1.97.
In Refert-nce 6, the licensee states that all aspects of the Regulatory Guide 1.97 recommendations for these variables have been met.
We find this, acceptable.
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CONCLUSIONS Based on our review, we find that the licensee either conforms-to or is justified.in deviating from Regulatory Guide 1.97, with the following exceptions:
1.
Accumulator level and pressure--environmentally qualified instrumentation should be provided (Section 3.3.1 and appendix A).
2.
Quench tank temperature--the licensee should provide I
instrumentation that covers the saturation temperature of the tank contents (Section 3.3.13).
3.
Quench _ tank pressure--the licensee should provide the recommended 0 to 100 psig range (Section-3.3.14).
4..
Steam generator pressure--the licensee should provide the range (0 psig to 20 percent above the lowest safety valve setting) recommended for this variable (Section 3.3.16).
5..
Component cooling water flow to ESF system--the licensee should provide the recommended instrumentation (Section 3.3.22).
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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 I to NUREG-0737--Requirements for Emergency 1
Response Capability (Generic Letter No. 82-33)," December 17, 1982.
2.
Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conoitions Durina and Followiin an Accident, Regulatory Guide 1.97, Revision 2. NRC, Office of Standards 1
. Development, December 1980.
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Clarification of TMI Action Plan Requirements. Reautrements for Emeraency ResDonse Capability, NUREG-0737, Supplement No.~1. NRC, Office of Nuclear Reactur Regulation, January 1983.
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4.
Consumers Power Company letter, David J. Vandewalle to Director, Office of Nuclear Reactor Regulation, April 14, 1983.
5.
Consumers power Company letter, Kerry A. Toner to Director, Office of Nuclear Reactor Regulation, September 13, 1983.
6.
Consumers Power Company letter, Kenneth W. Barry to Director, Nuclear Reactor Regulation, NRC, April 30, 1986.
7.
Instrumentation for Licht-Water-Cooled Nuclear-Power Plants to Assess plant and Environs Conditions Durina and Followine an Accident, Regulatory Guide 1.97,-Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
8.
Clarification'of TMI Action plan Requirements, NUREG-0737, NRC, Office of Nuclear Reactor Regulation, NovemDer 1980.
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APPENDIX A ENVIRONMENTAL QUALIFICATION O
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J APPENDIX ~A ENVIRONMENTAL QUALIFICATION l'e The following variables were not. identified as.being environmentally qualified in Reference 5. :2eference 6. clarifies the status of the environmental qualification for the following instrumentation (See Section 3.3.1).
A.-
Neutron flux--the licensee has connitted to replace the existing nuclear instrumentation late in 1988.
The new instrumentation will be environmentally qualified. We find this commitment acceptable.
8.
Reactor coolant system (RCS) cold' leg water temperature--the resistance temperature detectors were upgrtded with environmentally qualified components during the 1985 refueling outage.
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RCS hot leg water temperature--the resistance temperature detectors were upgraded with environemntally qualified components during the 1985 refueling outage.
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RCS pressure--the pressurizer pressure transmitters were upgraded.
with environmentally qualified components during the 1985 refueling outage.
E.
Containment sump water level (narrow range)--the narrow range q
sump water level transmitters were upgraded with environmentally
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qualified components during the 1983 refueling outage.
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' Containment isolation valve position--the isolation valve
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position switches were upgraded to meet 10 CFR 50.49 requirements during the 1985 refueling cutage.
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Residua'l heat removal (RHR) system flow--the shutdown cooling system is used for this function at Palisades and.the components' to monitor the flow-are located in a mild environment.
H.
RHR heat exchanger outlet temperature--in Reference.6, the licensee states that the existing temperature element for this variable is located in an environment that would see slightly.
elevated temperatures and radiaiton levels during an accident.
~The licensee is evaluating-the existing' temperature element to see if it will continue to perform it's function during
. post-accident conditions.
The licensee has comitted to replace the element with one that is environemntally qualified if the analysis shows that the existing temperature element cannot meet the necessary requirements.
We find this acceptable.
I.
Accumulator tank level and pressure--in: Reference 6, the licensee states that the safety injection tanks are passive devices and that the level and pressure instrumentation is provided for normal operation mon'itoring.
The licensee further states that an
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accident that results in a rapid RCS depressurization will cause the safety injection tanks to discharge, resulting in no level and pressure indication.
In addition, the licensee states that there are no operator actions required during post-accident conditions that require knowledge of the tank level and pressure.
i The existing instrumentation is not acceptable.
An environmentally qualified instrument is necessary to monitor the' status of these tanks.
The licensee should designate either level or pressure as the key variable to directly indicate i
accumulator discharge and provide instrumentation for that variable that meets the requirements of 10 CFR 50.49.
J.
Accumulator isolation valve position--the licensee states that power to the safety injection tank isolation valves is incked out a
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E during normal operation'to prevent' inadvertent isolation of the tanks.
Therefore, Category 3 instrumentation is adequate to monitor this variable.
.i Based on the licensee's justification that these valves are open and cannot change position during or following an accident, we consider the instrumentation for this variable acceptable.
X.
Boric acid charging flow--this instrumentation is the same as the variable makeup flow-in, and is located in a mild environment.
L.
Flow in high pressure injection (HPI) system--the licensee has
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comitted to replace the existing flow transmitters late in 1988.
The new transmitters will be environmentally qualified. We find this commitment acceptable.
M.
Flow'in low pressure injection (LPI) system--the licensee taz comitted to replace the existing flow transmitters late in 1988.
The new transmitters will be environmentally qualified.
We find this commitment acceptable.
N.
Refueling water storage tank level--the safety injection and refueling water tank (SIRW) is used at Palisades for this function.
The level instrumentation for this tank is located in a mild environment.
O.
Primary system safety relief valve positions--the acoustic monitors for this variable were upgraded with environmentally qualified components during the 1985 refueling outage.
P.
Pressurizer heater status--all components of the current measuring loop for this variable are located in a mild environment.
21
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0.
' Steam generator level--the level instrument loop and level transmitters located inside containment were upgraded to meet l
environmental qualification requirements during the 1983 refueling outage.
R.
- Steam generator pressur.e--the pressure transmitters for this variable were replaced during the 1985 refueling outage.
The new transmitters are environmentally qualified.
-S.
Safety / relief valve positions or main steam flow--in Reference 6-the licensee states'that the purpose of this; indication is to l'
monitor.for potentially. stuck open steam generator relief valves.
Palisades has main steam flow instrument loops with flow transmitters located inside containment that can be utilized to monitor for. excessive steam flows that.would result from stuck open steam generator relief valves.
The steam generator relief valves are located outside re w inment, and a main steam line break (MSLB) resulting from a stuck open relief valve would not result in a harsh environment inside of containment.
Based on the licensee's justification we conclude that the main steam flow instrument loops are locate ~d in a mild environment for events during which it would be required to function and, thus, are acceptable for post-accident monitoring.
T.
Auxiliary or emergency feedwater flow--the control and indicating instrument loops and flow transmitters for this variable were upgraded to meet environmental qualification requirements during the 1983 refueling outage.
l U.
Containment spray flow--all components of the flow instrument loop for this variable are located in a mild environment.
i 22
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e V.
Heat removal by the containment fan heat removal system--the required components of this system were upgraded to meet the e'
environmental qualification requirements during the 1985 refueling outage.
W.
Containment atmosphere temperature--the licensee does not consider containment atmdsphere temperature to be a key variable.
The temperature indication is provided as a backup variable and for routine surveillance during normal operations.
Qualified containment pressure indicating loops are provided and are utilized as the key variable to assess containment conditions. We find this acceptable.
X.
Containment sump water temperature--in Reference 6, the licensee states that they consider that containment pressure is an acceptable alternative for monitoring contaiment sump water temperature.
The sump temperature will be equal to or less than the saturetion icmperature corresponding to containment pressure.
In addition, there are no operator actions required, based on knowledge of the containment sump water temperature, and alternate temperature instrumentation is available.
We find this deviation acceptable.
See Section 3.3.19.
Y.
Makeup flow-in--all components of the makeup flow instrument loop are located in a mild enviror. ment.
Z.
Letdown flow-out--all components of the letdown flow instrument loop are located in a mild environment.
AA.
Volume control tank level--all components of the volume contro1 j
tank level instrument loop are located in a mild environment.
l 23 1
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.ol 88.
Component cooling water temperature to ESF system.-in Reference
{
t 6, the licensee states that the existing temperature element for a
this variable :s located in an environment that would see slightly elevated temperatures and radiation levels during an accident.
The licensee is evaluatirig the existing temperature
. element.to see if it will continue to perform it's function
{
during post-accident conditions.
The licensee has. committed to replace the element with one that is environmentally qualified if 1
the analysis shows'that the existing temperature element cannot meet the necessary requirements.
We find this acceptable.
CC.- Emergency ventilation damper position--the ventilation damper position switches were upgraded to meet 10 CFR 50.49 requirements' during the 1985 refueling outage.
00.
Status of standby power and other energy sources important to safety--the components' associated with providing the necessary status information are located in mild environments.
The licensee states that they are continuing to evaluate the necessity of providing environmental'ly qualified instrumentation for the following variables ever tnough a comitment has been made to make the necessary modifications.
A.
Neutron Flux H.
RHR heat exchanger outlet temperature
'L.
Flow in high pressure safety injection system M.
Flow in low pressure safety injection system BB.
Component cooling water temperature to ESF system.
l 24
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6:
If.the licensee's evaluation shows'that environmentally qualified equipment a
is.not required for these variables, the licensee states that they will
's-notify the NRC and provide ~the appropriate justification.
.-Q-
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