ML20235M359

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Preliminary Conformance to Reg Guide 1.97:Byron Units 1 & 2 & Braidwood Units 1 & 2, Technical Evaluation Rept
ML20235M359
Person / Time
Site: Byron, Braidwood, 05000000
Issue date: 08/31/1987
From: Stoffel J
EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:
NRC
Shared Package
ML20235M361 List:
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7643, GL-82-33, TAC-57198, TAC-63250, TAC-64029, TAC-64056, NUDOCS 8710060162
Download: ML20235M359 (23)


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TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97:

BYRON-1 AND -2 AND BRAIDWOOD-1 AND -2 Docket Nos. 50-454/50-455 and 50-456/50-457 b

J. W. Stoffel Published August 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regula, tory Commission Wash'ngton, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483 l

PRELIMINARY  :

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ABSTRACT' i

'l This EG&G Idaho, Inc., report reviews the submittal for Revision 3 of 1 Regulatory Guide 1.97 for Unit Nos.-1 and 2 of the Byron'and Braidwood  !

Stations 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. '

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1 Docket Nos. 50-454/50-455 and 50-456/457 TAC Nos. 57198, 63250 and 64029, 64056 . I l

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' FOREWORD This report is supplied as part'of.the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97," being conducted for the U.S.

Nuclear Regulatory Commission, Office of Nuclear. Reactor Regulation, Division of Engineering and System Technology by EG&G Idaho, Inc.,

Electrical, . Instrumentation and Control Systems Evaluation Group.

The U.S.. Nuclear Regulatory Commission' funde'd the work under authorization B&R 20-19-40-41-3. H

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Docket Nos. 50-454/50-455 and 50-456/50-457 TAC Nos. 57198, 63250 and 64029,'64056 .l d

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CONTENTS AoSTRACT

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1. INTRODUCTION ..... ............................................... 1
2. REVIEW REQUIREMENTS .............................................. 2 1
3. EVALUATION .................................. .................... 4 3.1 Adherence to Regulatory Guide 1.97 ......................... 4 l

3.2 Type A Variables ........................................... 4 3.3 Exceptions to Regulatory Guide 1.97 . . . . . . . . . . 4 ............ 5 4 CONCLUSIONS ...................................................... 15

! s. REFERENCES ....................................................... 18 q l  !

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CONFORMANCE TO REGULATORY GUIDE.1.97: .,

BYRON-1 AND -2 AND' l BRAIDWOOD-1 AND -2: f

1. INTRODUCTION j i

On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was

'I issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear .

Reactor Regulation, to all licensees of operating reactors, applicants for.

operating licenses and holders of. construction' permits. This letter included additional clarification regarding Regulatory Guide.1.97, Revision 2 (Reference 2), relating to the requirements for emergency response capability. These requirements have been published as Supplement No. I to NUREG-0737, "TMI Action Plan Requirements".(Reference 3).

Commonwealth Edison Company, the licensee for Unit Nos.-I and 2 of the Byron and Braidwood Stations, responded to Item 6.2 of the generic letter with a letter dated February 27, 1987 (Reference 4). This letter provides a review of the instrumentation provided by the Byron and Braidwood Stations for Revision 3 of Regulatory Guide 1.97 (Reference 5)..

This report provides an evaluation of that submittal.

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2. REVIEW REQUIREMENTS 1

Section 6,2 of.NUREG-0737, Supplement No. 1, sets forth the j documentation to be submitted in a report to the NRC describing how the licensee complies with Regulatory Guide 1.97 as applied to emergency. 'l 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.

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1. Instrument range
2. Environmental qualification ~

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3. Seismic qualification j
4. Quality assurance I
5. Redundance and sensor location
6. Power supply i
7. Location of display
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- '

for the deviations identified.

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 i explicitly state that their instrument systems conform to the regulatory 2 -

cuide, 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 submittal based on the review policy described in the NRC regional meetings.

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3. EVALUATION This evaluation is based on the licensee's February 27, b87 response 4

to Generic Letter 82-33.

3.1 Adherence to'Reculatory Guide 1.97 )

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The licensee's submittal for Unit Nos. I and' 2 of the Byron and f Braidwood Staticns, compares their post-accident monitoring instrumentation -

with the instrumentation recommended by Regulatory Guide 1.97,. Revision 3.  ;

j The licensee states that a final Regulatory Guide 1.97 report and implementation schedule is scheduled to be submitted by September 1, 1987.

Therefore, we conclude that the licensee has.provided an explicit f commitment on conformance to Regulatory Guide 1.97. Exceptions to and i deviations from the regulatory guide are noted in Section 3.3. _

i 3.2 Tyoe A Variables Regulatory Guide 1.97 does not specifically identify Type A variables,- q 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. Reactor coolant system (RCS) pressure
2. RCS hot leg water temperature (wide range)  :
3. RCS cold leg water temperature (wide range)
4. Steam generator level (wide range)
5. Steam generator level (narrow range)- ,

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6. Pressurizer level i
7. Containment pressure (narrow range) {
8. Containment-pressure (wide range) q l
9. Main steam pressure
10. Refueling water storage tank level I
11. Containment water level (wide range) )
12. Auxiliary feedwater flow
13. Containment radiation level R
14. Main steamline radiation level -]
15. Core exit temperature l 1
16. Spray addithe ta.sk level This instrumentation meets the Category I recommendations consistent with

{ the requirements for Type A variables, except as noted.'in Section 3.3.

3.3 Exceptions to Regulatory Guide 1.97 l The licensee identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.

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. 1 3.3.1 Neutron Flux i Regulatory Guide 1.97 recommends Category 1 instrumentation to monitor l this variable. The licensee has provided instrumentation that meets 1 Category I requirements with the exception of recording capability. .The i

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licensee states that they are evaluat'ing the need to add computer inputs .to meet this requirement.

1 The measurement of neutron. flux is the. key variable, defined in Regulatory Guide 1.97, for detecting an u' uncontrolled approach to critically' and for determination that an accident has been successfully mitigated.

Therefore, the licensee should provide'a means of recording this variable.

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3.3.2 RCS Soluble Boron Concentrations i

Regulatory Guide 1.97 recommends a range of 0-6000 ppm for.this-variable. The licensee has provided a calibrated range of 0-5000 ppm on a .j digital indicator. The licensee considers the existing range to be adequate for the intended purpose of Regulatory Guide 1.97.

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 has been addressed by the NRC as part of their review of NUREG-0737, Item II.B.3.

3.3.3 RCS Cold Leg Water Temperature l RCS Hot Leg Water Temperature l 1

l Regulatory Guide 1.97 recommends redundant power supplies.for these variables. The licensee supplies all four channels of the cold leg i instrumentation from a division I instrument bus and all four channels of a the hot leg instrumentation from a division II instrument bus. The licensee considers this arrangement adequate since these instrument buses are backed up by standby power sources (diesel and battery) and the core exit temperature indication provides alternate temperature indication.

The power sources are uninterruptible power supplies (UPS) that are backed by battery and by standby power sources. 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 steamline pressure) are powered by additional UPS 6 ,

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 i requirements and is, therefore, acceptable.

3.3.4 Radiation Level in Circulating primary Coolant The licensee uses the post-accident sample system, which has been reviewed by the NRC as part of their review of NUREC-0737, Item II.B.3, to measure this parameter.

l Based on the alternate instrumentation provided by the licensee, we ,

conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.

3.3.5 Residual Heat Removal (RHR) Flow Regulatory Guide 1.97 recommends environmentally qualified

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instrumentation for this variable. The instrumentation installed is not environmentally qualified. The licensee has acknowledged this and is in the process of evaluating the need for an upgrade of this instrumentation.

No justification was given to support this deviation.

We conclude that the licensee should provide instrumentation for this i variable that is environmentally qualified to the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

3.3.6 RHR Heat Exchancer Outlet Temperature l

Regulatory Guide 1.97 recommends environmentally qualified

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instrumentation with a range of 40*F to 350 F for this variable. The l licensee states that the sensors are not environmentally qualified and that the range of 50*F to 350 F is adequate for the intended monitoring functions. The licensee is in the process of evaluating the need for an l

upgrade of this instrumentation.

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This range deviation is less than three percent of the maximum recommended range. Considering instrument accuracy, and overall range, we consider this deviation minor and, therefore, acceptable. However, the

. I licensee should provide instrumentation for this variable that is  !

environmentally qualified to the requirements of 10 CFR 50.49 and ')!

Regulatory Guide 1.97.

1 3.3.7 Accumulator Tank Level and Pressure l

Regulatory Guide 1.97 recommends environmentally qta tified instrumentation for this variable with a pressure range 0 to 750 psig. The licensee has supplied instrumentation with no environmental qualification.

The provided range of the pressure instrument is 0 to 700 psig. The licensee states that the design pressure for the accumulator tank is 700 psig.

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reactor coolant system (RCS) is actuated solely by a decrease in RCS pressure. We find that the range of the pressure instrumentation supplie'd for this variable is adequate to determine that the accumulators have discharged. Therefore, the range of the instrumentation for this variable is acceptable. I The existing non-qualified 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 accumulator discharge and provide instrumentation for that variable that meets the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

3.3.8 Boric Acid Charging Flow Regulatory Guide 1.97 recommends environmentally qualified instrumentation for this variable. The instrumentation provided is not 8

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environmentally qualified. The licensee has acknowledged this, and is in the process of evaluating the need for an upgrade of this instrumentation.

The licensee should provide instrumentation for this variable that is environmentally qualified to the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

3.3.9 Flow in High Pressure Injection (HPI) System Regulatory Guide 1.97 recommends environmentally qualified instrumentation for this variable. The licensee has instrumentation that is not environmentally qualified. The licensee has acknowledged this, and is in the process of evaluating the need for an upgrade of this instrumentation.

The licensee should provide instrumentation for this variable that is environmentally qualified to the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

3.3.10 Flow in Low Pressure Injection (LPI) System Regulatory Guide 1.97 recommends environmentally qualified instrumentation for this variable. The licensee has instrumentation that is not environmentally qualified. The licensee has acknowledged this, and is in the process of evaluating the need for an upgrade of this instrumentation.

The licensee should provide instrumentation for this variable that is environmentally qualified to the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

3.3.11 Pressurizer Heater Status Regulatory Guide 1.97 recommends environmentally qualified electric current monitoring instrumentation for this variable. The licensee states 9

that on-off indication and electrical current indication is.available, however neither is environmentally qualified. The licer.see.further states that their design of the pressurizer. heater system and. control,s is not safety-related and heater status is considered Category 3. The licensee.is however in the process of evaluating the need for'an upgrade of this ,

instrumentation.

I The licensee should provide' electric. current monitoring instrumentation ~

for this variable that is environmentally qualified to the requirements.of 10 CFR 50.49 and. Regulatory Guide 1.97.

3.3.12 gu.enchTankTemperature Regulatory Guide 1.97 recommends a range. of 50 to 750'F for this variable. The licensee has provided a range of .50 to 300 F. .The licensee considers this range adequate since it covers the normal operating'desig'n conditions under which the tank is expected to maintain its integrity.

The licensee has not provided adequate justification for this deviation. The licensee should show that the temperature indication'will remain on scale, including the maximum expected saturation temperature l (338 F at 100 psig), during any accident that lifts 'the pressurizer relief l

valves.

l 3.3.13 Steam Generator Level I i

Regulatory Guide 1.97 recommends Category 1 instrumentation for the wide range steam generator level and for Type A variables. The licensee has determined that steam generator level (narrow range) is a Type A variable and the recorder for this instrument is not seismically j qualified. The licensee is in the process of evaluating the qualification of this recorder by similarity analysis.

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We find this deviation unacceptable for Type A variables. Neither NUREG-0737, nor Regulatory Guide 1.97 require this instrumentation to be Type A. The licensee has determined that this instrumentation is Type A.

Therefore, the licensee should provide Category 1 recorders for'this variable.

3.3.14 Steam Generator Pressure Regulatory Guide 1.97 recommends a range of 0 to 20 percent above the lowest safety valve setti'] for this variable. The licensee has provided a range (0 to 1300 psig) that is only 12 percent above the lowest safety i valve setting. The licensee considers this adequate because 1300 psig is 3 above the highest setting of the. safety valves.

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adequate to monitor the steam generator pressure during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

1 3.3.15 Safety Relief Valve Position or Main Steam Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable, that can be either safety relief valve position or main steam i flow. The licensee has provided qualified valve position indication, but only for the power operated relief valves. The licensee also has main steam flow indication, however it is not environmartally qualified. The licensee is in the process of evaluating these discrepancies for compliance.

The licensee should either add Category 2 instrumentation to monitor the safety valves or upgrade the main steam flow indication to meet the l requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

3.3.16 Auxiliary Feedwater Flow l

Regulatory Guide 1.97 recommends instrumentation for this variable that meets Category 2 recommendations. Since the licensee has designated 11

this instrumentation as Type A, this instrumentation should be Category 1.

The licensee indicates that no recording or computer input is provided.

The licensee is presently evaluating a resolution.to this deviation.

1 We find the recording deviation unacceptable for Type A variables.

Neither NUREG-0737, nor Regulatory Guide 1.97 require this . instrumentation to be Type A. The licensee has determined that this instrumentation is Type A. Therefore, the licensee should provide Category 1 instrumentation for this variable, d

i 3.3.17 Condensate Storage Tank Water Level ,

Regulatory Guide 1.97 recommends Category 1 instrumentation for.the 1 primary source of auxiliary feedwater. The licensee states that the j essential service water system, not the condensate storage tank, is the  !

Category 1 source of auxiliary feedwater. i The licensee should provide information that shows that Category 1 instrumentation is available to show proper. operation of the essential j service water system, and show that water is available to the auxiliary-feedwater system for post-accident situations.

3.3.18 Containment Atmosphere Temperature 1

Regulatory Guide 1.97 recommends environmentally qualified instrumentation for this variable. The instrumentation installed is not environmentally qualified. The licensee has acknowledged this, and is in the process of evaluating the need for an upgrade of this instrumentation.

The licensee should provide instrumentation for this variable that is environmentally qualified to the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

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3.3.19 Containment Sump Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of 50 to 250'F to monitor this variable. The licensee ha's not ]

provided instrumentation for this variable, stating that the containment sump water temperature is not required to be monitored to detect RHR or' '

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containment spray pump cavitation when in the recirculation mode.

This is insufficient justification for this exception. The licensee-should provide the recommended instrumentation for the functions outlined in Regulatory Guide 1.97 or identify other instruments that provide the same information (such as the residual heat removal . heat exchanger-inlet temperature) and that satisfies the regulatory guide. I 3.3.20 Makeup Flow-In Letdown Flow-Out i Volume Control Tank Level i

Regulatory Guide 1.97 recommends environmentally qualified )

instrumentation to monitor these variables. The instrumentation installed is not environmentally qualified. The licensee has acknowledged this and is in the process of evaluating the need for an upgrade of this .

instrumentation.

The licensee should provide instrumentation for these variables that is environmentally qualified to the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

l 3.3.21 Component Cooling Water Temperature to Engineered Safety Features (ESF) System

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Component Cooling Water Flow to ESF System

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Regulatory Guide 1.97-recommends environmentally qualified instrumentation to monitor these variables. The instrumentation installed 13

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is not environmentally' qualified. The licensee acknowledges this, and is

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i in the process of evaluating the need for an upgrade of this instrumentation.

The licensee should provide instrur'entation for these variables that is environmentally qualified to the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.

3.3.22 Radiation Exposure Rate  !

i Regulatory Guide 197 ' recommends radiation exposure rate instruments in areas where access is' required to service equipment important to safety. The licensee states that all required areas may not'contain.these instruments at the present time. The licensee is in the process of

.l evaluating the need for additional instruments in some specific areas. j 1

l The licensee should. commit to the installation of additional radiation exposure rate instrumentation should the evaluation show that more are needed.

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4. CONCLUSIONS .i l

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. Neutron flux--the licensee should provide a means of recording this variable (Section 3.3.1). i l
2. RHR flow--the licensee should provide environmentally qualified instrumentation for this variableL(Section 3.3.5). 1 1

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3. RHR heat exchanger outlet temperature--the licensee should ]

provide environmentally qualified instrumentation for this I variable (Section 3.3.6).  ;

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4. Accumulator tank level and pressure--the licensee should provice- i environmentally qualified instrumentation for this variable j (Section 3.3.7). j i
5. Boric acid charging flow--the licensee should provide ]'

environmentally qualified instrumentation for this variable (Section 3.3.8).

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6. Flow in HPI system--the licensee should provide environmentally -l qualified instrumentation for this variable (Section 3.3.9).
7. Flow in LPI System--the. licensee should provide environmentally qualified instrumentation for this variable (Section 3.3.10).  ;

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8. Pressurizer heater status--the licensee should provide environmentally qualified electric current instrumentation for this variable (Section 3.3.11).

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9. Quench tank temperature--the ' licensee should provide analysis i that shows.the existing range will stay on scale.during accident conditions or provide a range that will-remain on scale }

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.(Section 3.3.12). 1

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10. Steam generator level ,-the licensee should provide Category 1L.

1 recorders for this. variable (Section.3.3.13).

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11. Safety relief valve position or. main steam flow--the licensee '1 should either add qualified position indication for the safety :j valves or upgrade the main steam' flow indication to Category 2-requirements (Section 3.3.15).
12. Auxiliary feedwater flow--the licensee should provide Category I recorders for this variable (Section 3.3.16).
13. Condensate storage tank water level--the licensee should show that Category 1 instrumentation is'available to show that water to the auxiliary feedwater system is available in post-accident situations (Section 3.3.17). I
14. Containment atmosphere temperature--the licensee should' provide

) environmentally qualified instrumentation for this variable (Section 3.3.18). J i

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15. Containment sump water temperature--the licensee should provide the recommended instrumentation .or identify other instrumentation l that satisfy the regulatory guide requirements (Section 3.3.19).  !
16. Makeup flow-in--the licensee should provide environmentally l qualified instrumentation for this variable (Section 3.3.20)'. 'l
17. Letdown flow-out--the licensee should provide environmentally' qualified instrumentation for this variable (Section 3.3.20).

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~18. Volume control tank level--the . licensee lshould provide j environmentally qualified instrumentation for this variable I (Section 3.3.20). .

19. Component cooling water temperature.to ESF system--the licensee.

should provide environmentally qualified. instrumentation for.this.  !

variable (Section 3.3.21). l 1

l. 20. Component. cooling water flow to ESF system--the licensee should~

provide environmentally qualified instrumentation for this g variable (Section 3.3.21).

21. Radiation exposure rate--the. licensee should commit to.the installation of additional radiation exposure rate instruments should their study show that~more are needed (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 .

Response Capability-(Generic Letter No. 82-33)," December 17, 1982. .,

2. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess l Plant and Environs Conditions During and Following an Accident, .j i

Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.

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3. Clarification of TMI Action Plan Requirements, Requirements'for Emergency Response Capability, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Peactor Regulation, January 1983.  ;

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4. Commonwealth Edison Company letter, K..A. Ainger to H. R..Denton,.

Director of Nuclear Reactor. Regulation, NRC, " Regulatory Guide 1.97 Ccmpliance Preliminary Report," February 27, 1987. ,

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5. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory L -)

Research, May 1983.

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