ML20236R411
| ML20236R411 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/13/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236R408 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8711230262 | |
| Download: ML20236R411 (4) | |
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- g ,/ ENCLOSURE li
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) SAFETY EVALUATION REPORT 4-SOUTH CAROLINA ELECTRIC AND GAS COMPANY s
] 'N VIRGIL C. SUMMER NUCLEAR STATION 4
s DOCKET NO. 50-395 j ,
\ CONFORMANCE'TO REGULATORY GUIDE 1.97- "I ,
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1.0 INTRODUCTION
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l The South Caro 1*,na, Electric wn.' Goa ,Cpmpany was requested by Generic Letter 82-33 to provide a report' te the KP'Miscribing h'ow the post-accident Ponitoring instrumentation meets the @\fdelines of Regulatory Guide (R.G.) 1.97 as applied to emergency response facilit%s. The licensee responded to,Atem 6 of the' I
generic letter on Apy11 15,-1985: Additional infonnation wasp provided by letters j dated August 18, 1986 and October 31, 1986, i
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Aodettiledc r.diew ind technical evaluation of the licensee's submittals t was s
' jedormee ll.t EG&G Idaho, Inc.., under contract to t>r MC, W1Weenera1' supervision 3
j bythehRC'skST). This work is documented by EG&G in the Technical Evaluation l Repo[t UER), Confamance }o R.G.1.97: Sunener, dated September 1987
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(attachg1)V We halve revirrEd Ahis report and concur with the cont.'iusion that. j j 'the licepse either confonas h[,,N 'Is juNified in devi.6 3 ting froIn the guidance .
I of R.G. i.97 for each post-accident monitoring variable Meepb for,the variables a
Q accumulator tank level and pressure, bl pntainment styspf ere' temperature, l
d.id c) ven't from steam generator safety vA ves or atmospheric y4.,, 4p valves.
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{s d.B EVAll"LTION ' - -
CRITERIA '
I g Subsequent to hhe hsuance of'the generic letter,.the NfC held regional meetings i in February an,d March 1983 to answer licensee and applicant questions and I' concerns regarding the NRC yoll Icy on R.G.1.97. At these meetings, it was .noted I a i. .
( t(y, the NRC. review woulA tng address exceptions taken to the guidance of R.G. '
r 107. Further, where licenseep;or appiscar.ts expiscitiy stated that instrument .
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systems conform to the provisions of the regulatory guide, it was noted that no+
further staff review would be necessary. Therefore, the review perfohned and reported by EG&G only addresses exceptions to the guidance of R.G. 1.97. This safety evaluation addresses the licensee's submittals based on the review policy described in the NRC regional meetings and the conclusions of the review as reported by EG&G.
v 3.0 EVALUATION
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We have reviewed the evaluatiot performed by EG&G contained in the enclosed TER and concur with its bases and findirigs except for the fincings contained in TER section 3.3.1 concerning a) accumulator tank level and pressure. For the remaining items we agree with EG&G's findings that 'the licensee either conforms to or has acceptably justified deviations from the guidance of R.G.1.37 for each post ~ accident monitoring variable except for the variables b) containment atmosphere temperature, and c) vent f rom steam generator safety valves or atmospheric dump valves.
a) In TER section 3.3.1 EG&G concluded that for the variable accumulator tank level and pressure, 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. The staff, however, is currently generically reviewing the need for environmentally qualified Category 2 instruments to monitor accumulator tank levei and pressure. We will, therefore, report on the acceptability of this item when the generic review process is complete.
b) R.G.1.97 recommends instrumentation with a range of 40 to 400*F to monitor the containment atmosphere temperature. The licensee has not providec instrumentation that will monitor this range. The range provided is 50 to 350'F and no analysis was submitted showing that this instrumentation 1
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would remain on scale during post-accident conditions. The staff believes * -
that it is necessary to monitor any expected containment atmosph~e~re temper-ature with this instrumentation. In this regard, we find the licensee's proposed exception to the guidelines of R.G. 1.97 unacceptable. , 1 f R.G.1.97 recocraends Category 2 instrumentation be provided to monitor a )
, c) release from the steam generator safety relief valves or atmospheric dump valves. The licensee has provided steamline radiation monitors whlch conform to the criteria for Type E, Category 2, variables with the 3 .
exception of environmental qualification. The use of this instrumentation to monitor this. variable has been accepted at other stations if it is !
environmentally qualified or locatea in a mild environment. In this regard, we find the licensee's proposed exception from the guidelines of R.G.1.97 acceptable, except in the area of environmental qualification.
4.0 CONCLUSION
Based on the staff's review of the attached TER and the licensee's submittals, we find that the Virgil C. Summer Nuclear Station design is acceptable with respect to conformance to R.G. 1.97, Revision 3, except for the instrumentation associated with the variables accumulator tank level and pressure, containment !
atmosphere temperature, and vent from steam generator safety valves or atmospheric dump valves.
a) The acceptability of instrumentation for accumulator tank level and pressure will remain open pending the outcome of the staff's generic !
review of the need for environmentally qualified Category 2 instrumen-
, tation to nonitor'this variable. The staff's conclusion will be reported on when the generic review is complete, b) It is the staff's position that the information provided by monitoring the containment atmosphere temperature is useful to an operator in the evaluation of some accident conditions. Instrumentation that meets the
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range recommended by the regulatory guide,or analysis that shows the ,
provided range is adequate,is needed from the licensee. A commitment to install instrumentation with a range that is in conformance with the.
recommendations of R.G.1.97 or an analysis that shows the provided range is adequate shall be submitted within 90 days from the receipt of this report.
3 c) It is the staf f's position that instrumentation that meets the environ-mental qualification requirements of 10 CFR 50.49 for harsh environments should be supplied to monitor"a release from the steam generator safety relief valvesor atmospheric dump valves, if, applicable. It is also the staff's position that the licensee shall install, and have operational, qualification steamline radiation monitoring instrumentation at the first scheduled outage of sufficient duration, but no later than startup following the second refueling outage after receipt of this report.
An appropriate implementation schedule will be developed by the project manager via discussion with the licensee. Once the schedule is established, l the licensee is required to inform the Commission, in writing, of any-significant changes in the estimated completion schedule identified in the staff's safety evaluation and when the action has actually been completed.
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... ENCLOSURE 2
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TECHNICAL EVALUATION REPORT
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CONFORMANCE TO REGULATORY GUIDE 1.97: SUMMER
Docket No. 50-395 3
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J. W. Stoffel Published September 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.
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Prepared for the i U.S. Nuclear Regulatory Commission {
Washington, D.C. 20555 ;
Under DOE Contract No.-.DE-AC07-761001570 '.
FIN No. A6483 i 1
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a' ABSTRACT
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This EG&G Idaho, Inc., report reviews the submittals for Regulatory
' Guide 1.97 for the Virgil C; Summer Nuclear Station and identifies areas of nonconformance to the' regulatory guide. Except' ions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis.for.
acceptability is not provided are identified.
I Docket'No. 50-395 TAC No. 51137 ii
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.- FOREWORD This report is supplied as part of the " Program for Evaluating Licensee / Ape'icant Conformance to R.G. 1.97," being conducted for the U.5. j Nuclear Regulatory Commissien, Office of Nuclear Reactor Regulation,
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DivisionofEngineeringandSysyemTechnology,byEG&GIdaho,Inc.,
Electrical, Instrumentation and Control Systems Evaluation Group. i The U.S. Nuclear Regulatory Commission funded the work under authorization B&R 20-19-10-11-3.
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Docket No. 50-395 TAC No. 51137 iii
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CONTENTS 1
.: 1 AB S T RAC T . . . . . . . . .................................................. ii V.
FOREWORD ............... ... . ........................................ iii ,J7
- 1. INTRODUCTION ............. .......................,........7.. 1 )
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- 2. REVIEW REQUIREMENTS ......... ..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
- 3. EVALUATION .. ............................................. ...... '4 '.
3.1 Adherence to Regulatory Guide 1.97 ...... ............ ..... 4 3.2 Type A Variables ... .... . . . . . . . . . . . . . . . . . . . . . . . . 4 l 3.3 Exceptions to Regulatory Guide 1.97 ................ .. .... 5
- 4. CONCLUSIONS ............ ..v.. ..... . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
- 5. REFERENCES ................. ........... ............ .......... 21 l
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. q SUMMER CONFORMANCE TO REGULATORY GUIDE 1.97:
- 1. INTRODUCTION 9: ;
On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was >
issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear j 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 reovirements have been published as Supplement ]
No.1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3). -
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South Carolina Electric and, Gas Company, the licensee for the
~ Virgil C. Summer Nuclear Station, provided a response to the Regulatory {
Guide 1.97 portion of the generic letter on April 15, 1985 (Reference 4).
Additional information was submitted on August 18, 1986 (Reference 5) and j October 31, 1986 (Reference 6). f f i This report provides an evaluation of those submittals.
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- 2. REVIEW REQUIREMENTS )
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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 to Regulatory Guide 1.97 as applied to emergency' response facilities. The submittal should include documentation that provides the :
following informati.on for each variable shown in the applicable table of i. '
Regulatory Guide 1.97:
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- 1. Instrument range e l
- 2. Environmental qualification T i' j
- 3. Seismic qualification
- 4. Quality assurance
- 5. Redundan e and sensor location l
- 6. Power supply )
- 7. Location of display {
- 8. Schedule of installation or upgrade The submittal should identify deviations from Regulatory Guide 1.97 and provide supporting justification or alternatives.
Subsequent to the issuance of the generic letter, the NRC held regiorial meetings in February and March 1983, to answer' licensee and I
applicant questions and concerns regarding the NRC policy on this subject. l At these meetings, it was noted that the NRC review would only address- _ ,
exceptions taken to Regulatory Guide 1.97. Where licensees or applicants j explicitly state that instrument systems conform to the regulatory guide, it was noted that no further staff review would be necessary. Therefore, i
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this report only addresses exceptions to Regulatory Guide 1.97. The -1 following evaluation is an audit of the licensee's submittals based on the review policy described in the NRC regional meetings. .gy,.
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- 3. EVALUATION
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The licensee provided a response to NRC Generic Letter 82-33 on ; ;
April 15, 1985. Additional information was submitted on August 18, 1986 and October 31, 1986. This evaluation is based on these submittals. -
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3.1 Adherence to Regulatory Guide 1.97 4*
i The licensee stated that compliance with Regulatory Guide 1.97 is indicated on Table 1-1 of their submittal (Reference 4), which summarizes
the compliance of each variable with the provisions of Regulatory Guide 1.97, Revision 3 (Reference 7). That compliance report presents I l
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~ justification, modifications or ohgoing evaluations that are provided as j
- resolution for any identified deviations. There. fore, 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.
3.2 Type A Variables Regulatory Guide 1.97 does not specifically icentify Type A variables, p i.e., those variables that provide the information required to permit the l control room operator to take specific manually controlled safety actions.
The licensee classifies the following instrumentation as Type Ai
- 1. Reactor coolant system (RCS) pressure (wide range)
- 2. RCS hot leg temperature (wide range)
- 3. RCS cold leg temperature (wide range) l
- 4. Steam generator level (wide range)
- 5. Steam generator level (narrow range) 4
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- 6. Pressurizer level
- 7. Containment pressure (normal range) ,
Containment pressure (extended range) .,::S 8.
. 9. Main steamline pressure
.- 10. Refueling water storage tank level
- 11. Containment water level
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- 12. Emergency feedwater flow \. ,
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- 13. primary containment radiation level J
- 14. Core exit temperature 1
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- 15. RCS subcooling monitor The above variab'les meet Category I recommendations consistent with the requirements for Type A variables, except as noted in Section 3.3. !
l 3.3 Exceptions to Regulatory Guide 1.97 The licensee identified deviations and exceptions.from Regulatory !
Guide 1.97. These are discussed in the following paragraphs.
3.3.1 Range Requirement Deviations The licensee indicates that.the following variables. conform to the
. range recommended by Regulatory Guide 1.97. However, in Reference 4, the range provided for each variable is listed as 0 to 100 percent of span.
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- 1. Steam generator level (wide range)'
(from tube sheet to. separators) ii4
- 2. Steam generator level (narrow range) 7 (no specific requirement)
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- 3. Pressurizer level- 1 (bottom to top) i-I I
- 4. Refueling water storage tank level J (top to bottom) .
, 4 In Reference 5, the licensee provided the ranges monitored by this I g l - instrumentation. We find the ranhes provided acceptable.
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3.3.2 Control Rod position i 1
Regulatory Guide 1.97 recommends Category 3 instrumentation with a range of full in or not full in for this variable.
In Reference 4, the licensee did not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 -for this variable.
In Reference 5, the licensee provided the required information. We l l
find the existing instrumentation acceptable.
3.3.3 RCS Soluble Boron Concentration Regulatory Guide 1.97 recommends instrumentation with a range of 0 to 6000 ppm for this variable.
The licensee deviates from Regulatory Guide 1.97 with respect to the range of this post-accident sampling capability. This deviation'goes - .'
- l. beyond the scope of this review and is being addressed by the NRC as part of their review of NUREG-0737, Item II..B.3.
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/' 3.3.4 Core Exit Temperature The licensee has identified core exit temperature as a Type A variable. As such, it should meet Category 1 requirements. The licensee N' indicates that this instrumentation is Category 1 with the exception of ,1 ~
recording. _ _ _
The NRC has reviewed the acceptability of-this variable' as part of
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e their review of NUREG-0737, Item II.F.2.
1 3.3.5 Coolant Inventory .]
. j Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has provided instrumentation that, except for I redundancy, is Category 1.
The NRC has reviewed the acceptability of this variable as part of their review of NUREG-0737, Item II.F.2.
3.3.6 Degrees of Subcooling The licensee has identified degrees of subcooling as a Type A variable. As such, it should meet Category I requirements. The licensee indicates that this instrumentation is Category 1 with the exception'of redundancy.
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i The NRC has reviewed the acceptability of this variable as part of' their review of NUREG-0737, Item II~.F.2.
i 3.3.7 Containment pressure
. Regulatory Cuide 1.97 recommends instrumentation with a range of
-5 psig to 3 times design pressure for this variable. The licensee stated, in Reference 4, that the instrumentation provided covers a range of 0 psig to 3 times design pressure. This range does not cover the subatniospheric-pressure recommended by the regulatory gJide.
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In Reference 5, the licensee states that the' range monitored by the existing instrumentation is -5 to 175 psig. We find this range acceptable.
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3.3.8 Containment Isolation Valve Position From the information provided, we find that the licensee deviates from a strict interpretation of the Category I redundancy recommendation. Only 1 4* 4 the active valves have position indication (i.e., check valves have no position indication). Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory guide. Position indication of check valves is specifically excluded by Table 3 of Regulatory Guide 1.97. Therefore, we find that the instrumentation for this variable is acceptable. I 3.3.9 Radiation Level in Circulating Primary Cc61 ant The licensee indicates that radiation level measurements to indicate fuel cladding failure are provided by the post-accident sampling system, which has been reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3.
Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate I
and, therefore, acceptable.
3.3.10 Condenser Air Removal System Exhaust--Noble Gas and Vent Flow Rate l
In Reference 4, the licensee did not provide the information required ;
by Section 6.2 of Supplement No. I to NUREG-0737 for this variable. !2 In Reference 6, the licensee states that this instrumentation is not required since the condenser air removal system effluent at this station ;
i discharges to the common plant vent. We find this acceptable. i 8
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3.3.11 Effluent Radioactivity--Noble Gases (from buildings or areas. .)
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In Reference 4, the licensee did not provide the information required
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by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
Reference 6.provided the equired information.
Regulatory Guide 1.97 rscommends a range of 10-6 to 103pC1/cc for this variable. The licensee has instrumentation with a range of 4 x 10-6 to 0.86 x 103 pCi/cc.
The licensee states-th'at this range is 86 percent of the recommended range and exceeds the anticipated levels of all normal f
. operation and design basis events. ~
The licensee further states that
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adequate back-up is provided with portable instruments and on site analysis. I i
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Based on the justification provided by the licensee, we find this
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instrumentation adequate to monitor this variable during all accident and post-accident conditions.
3.3.12 Resicaal Heat Removal (RHR) Heat Exchanger Outlet Temperature Regulatory Guide 1.97, Revision 3, recommends a range of 40 to 350*F for this variable.
The licensee has provided a range of 50 to 400*F.
This 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.
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3.3.13 Accumulator Tank Level and Pressure 1
in Reference 4, the licensee did not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for these variables.
In Reference 5, the licensee provided information for the accumulator t tank pressure. !
Based on this information, we conclude that the pressure !
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instrumentation is not fully environmentally qualified. The licensee stated that accumulator tank level will be addressed in a future submittal. As of July 1, 1987, we have not received this submittal. 'U. ,
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 !
I to directly indicate accumulator discharge and provide instrumentation for . j that variable that meets the requirements of 10 CFR 50.49. If the level is used as the key variable, then the range should satisfy the recommendations i
of Regulatory Guide 1.97. -
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l 3.3.14 Accumulator Isolation Valve Position T In P.eference 4, the licensee did not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable. .
I In Reference 6, the licensee provided the required information. We find the provided instrumentation acceptable to meet Regulatory Guide 1.97. ,
l 3.3.15 Boric Acid Charging Flow s
1 In Reference 4, the licensee did not provide the information required i by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
11 In Reference 6, the licensee states that they do not utilize boric ;
l acid charging as part of the injection system design. Accumulators, the ;
I centrifugal changing pumps and the RHR pumps are the safety injection flow paths.
Because this is not a safety injection flow at this station, we find .
that this variable is not applicable.
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flow for this variable. In Reference 4, the licensee states that a range g' of 0 to 100 percent of design flow is provided.
, The licensee has provided data, in Reference 6, that shows that the instrument range is to 150 percent of the maximum pump flow. Therefore, -
.- this instrumentation is acceptable.
3.3.17 Reactor Coolant Pumo Status ,
In Reference 4, the licensee did not provide the.information requibed.
by Section 6.2 of Supplement No'! 1 to NUREG-0737 for this variable.
In Reference 6, the licensee provided the required information. We i find the provided instrumentation acceptable for this variable.
3.3.18 Pressurizer Heater Status Regulatory Guide 1.97 recommends monitoring the pressurizer heater electric current with Category 2 instrumentation. The licensee has provided electric current instrumentation that, except for environmental qualification, is Category 2.
In Reference 6, the licensee states that the instrumentation for this variable is located in a mild environment. Therefore, we find the existing instrumentation acceptable.
3.3.19 Ouench Tank Level In Reference 4, the licensee did not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
In Reference 6, the licensee provided the required'information. We find the provided instrumentation acceptable for this variable. '
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3.3.20 _uench Q Tank Temperature
.. 1 In Reference 4, the licensee did not provide the information required W by Section 6.2 of Supplement No. I to NUREG-0737 for this variable. The .I -
information was submitted in Reference 6. . . .
Regulatory Guide 1.97 recommends a range of 50 to 750 F for this variable. The licensee has provided a range of 50 to 350 F. The licensee states that the quench tank design pressure is 100 psig and that a rupture disk on the tank is set to activate at 100 psig. Since.the saturation 1
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temperature at 100 psig is less than 350 F, the existing range is adequate I l to monitor any expected conditions in the tank.
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Based on the licensee's ju'stification that the existing range covers the anticipated requirements for normal operation, anticipated operational occurrences and accident conditions, we find this deviation from the regulatory guide acceptable.
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3.3.21 Quench Tank pressure In Reference 4, the licensee did not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
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In Reference 6, the licensee provided the required information. We )
find the provided instrumentation acceptable.
3.3.22 Steam Generator Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range from atmospheric pressure to 20 percent'above the lowest safety valve setting. In Reference 5, the licensee states that the lowest safety valve setting is 1176 psig with thh highest safety valve setting at 1235 psig and that the range provided is 0 to 1300 psig (0 to 110.5 percent);
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Based on the lowest safety valve setting.of 1176 psig and the highest j
safety valve setting of.1235 psig, which is well below'the instrument #
range, we conclude that the existing; range is adequate to monitor the steam G
generator pressure during all accident and post-accident conditions. '
Therefore, this is an acceptable deviation from Regulatory Guide l.97.
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3.3.23 Heat Removal by the Containment Fan Heat Removal System l
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In Reference 4, the licensee provided only part of the'information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
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'In Reference 6, the licensee provided'the additional information' -
required.
Wefindtheprovidedinstrumentationacceptableinmeeting'khe recommendations of Reg'ulatory G'uide 1.97. '
3.3.24 Cont'ainment Atmosphere Temperature
' In Reference 4, the licensee did not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variab'le.
In Reference 6, the licensee provided the required information-for this variable. However, the recommended range of 40 to 400*F is not met.
The licensee has instrumentation with a range of 50 to 350*F and provided no justification for this deviation. A temperature range, other than the range recommended, has been found acceptable at other stations when adequate justification was provided. The licensee should provide the f
recommended range or justify the existing range. '!
3.3.25 Containment Sump Water Temperature i In Reference 4, the licensee did .not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable. )
Reference 6 provided the required information.
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Regulatory Guide 1.97- recommends environmentally qualified j instrumentation for this variable. The instrumentation provided is not 1
environmentally qualified; however, a backup method of monitoring this .g i
variable is provided by the RHR suction temperature monitors. ,
q Based on the availability of an alternate method of monitoring ~this parameter, with instruments that are not subject. to harsh environments, we ]
find the existing instrumentation acceptable. '
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3.3.26 High-Level Radioactive Liouid Tank Level !
In Reference 4, the licensee did not provide'the information required j l
by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
t , Reference 6 provided the required:information.
l Regulatory Guide 1.97 recommends a range of top to bottom for this
( tank. The licensee has provided a range of 29 to 169 inch water column. i l The licensee states that this range measures the upper 88 percent of the j q tank and is sufficient to provide the operator with the necessary information for accident monitoring.
We find the existing range adeauate to monitor this variable during all accident and post-accident conditions and, therefore, acceptable.
3.3.27 Radioactive Gas Holdup Tank pressure-In Reference 4, the licensee did not provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
In Reference 6, the licensee provided the required information. We find the provided instrumentation acceptable in meeting the recommendations of Regulatory Guide 1.97.
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3.3.28 Emergency Ventilation Damper Position l
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In Reference 4, the licensee did not provide the information required
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by Section 6.2 of Supplement No I to NUREG-0737 for this variable.
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In Reference 6, the licensee provided the required information. We find the provided instrumentation acceptable-in meeting the recommendations I of Regulatory Guide 1.97.
- 3.3.29 Radiation Exposure Rate v {
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Regulatory Guide 1.97 recommends instrumentation with a range of J
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10 to 10 R/hr for this variable. The licensee has provided instrumentation with ranges from 10 -4 to 10 R/hr. The' licensee states that the existing area monitors must be augmented by.high range portable survey instrumentation to meet the range requi*ements.
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)
exceed the upper limit of the range, personnel would not be permitted into i the areas without additional monitoring with portable monitors. Based on the alternate instrumentation used by the licensee for this variable, we find the proposed ranges for the radiation exposure rate monitors acceptable.
3.3.30 Containment or Purge Effluent--Noble Gases Regulatory Guide 1.97 recommends a range of 10-6 5 to 10 uCi/cc for this variable. The licensee has provided a range that does not meet the recommended minimum sensitivity. The licensee provided a minimum range of 2 x 10 -6 pCi/cc.
We find this small deviation from the range recommencat-ion to be acceptable for this variable. The range provided will adequately monitor the operation of this system during accident and post-accident conditions.
Therefore, this is an acceptable deviation from Regulatory Guide l.'97.
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3.3.31 Vent From Steam Generator Relief Valves or Atmospheric Dump Valves It appeared in Reference 4 that the' licensee had not provided the @ l l
I information required by Section 6.2 of Supplement No. I to NUREG-0737 for p l
this variable. ,_
I In Reference 6, the licensee states that steamline radiation monitors are used along with steam flow instrumentation, and steamline isolation .
valve position indication, to monitor this variable. However the steamline radiation monitors are not environmentally qualified as recommended by
~
Regulatory Guide 1~.97 and adequate justification for this. exception has not been provided. This instrumentation has been found acceptable for this -j variable at other stations. However, the licensee should either'provideT i environmental qualification for the steamline radiation monitors or show j they are located in a mild environment. -
3.3.32 Airborne Radiohalogens and Particulate 1 1
In Reference 4, the licensee'did not provide the information required j by Section 6.2 of Supplement No. 1 to NUREG-0737 for this variable. )
i In Reference 6, the licensee provided the required information. We {
find the provided instrumentation acceptable in meeting the recommendations of Regulatory Guide 1.97, i
3.3.33 Plant and Environs Radiation (portable instrumentation)
In Reference 4, the licensee indicated that the range recommended for this instrumentation was not met. In Reference 6, the licensee has provided information that shows the range e.f the instrumentation is acceptable in meeting the recommended range.
16
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3.3.34 plant and Environs Radioactivity'(portable instrumentation) si.
In Reference 4, the licensee did not provide the information required
i by Section 6.2 of. Supplement No. I to NUREG-0737 for this variable. The information was provided in Reference 6.
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' The licensee does not have the capability to send a multi-channel l gamma ray spectrometer into the field and perform isotopic analysis. '
However, several non portable multi-channel analyzers (MCA) equipped with Ge(Li) detectors are located in the station counting room and at the RadiologicalEnvironmentalMonitoringLaboratorylocatedwithinatwomiYe distance from the station. The licensee states that portable multi-channel !!
T gamma ray spectrometers would not enhance the existing monitoring program l due to the inherent problems in'a portable system of decreased sensitivity, increased noise and interference, and reduced. reliability.
1 The laboratory equipment at this station can provide isotopic analysis and a timely assessment of radioactive releases. Therefore, this is ari acceptable deviation from Regulatory Guide 1.97.
3.3.35 Wind Direction In Reference 4, the licensee did not provide the instrument range information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.
In Reference 5, the licensee provided the required information. The instrumentation provided meets the regulatory guide recommendations.
3.3.36 Wind Speed In Reference 4, the licensee did not provide the instrument range ir. formation required by Section 6.2 of Supplement No. I to NUREG-0737 for
's this variable. '
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.. 1 In Reference 5, the licensee provided the required information. The j instrumentation provided meets the regulatory guide recommendations. f c: \s 3.3.37 Estimation of Atmospheric Stability ,.
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In Reference 4, the licensee did not provide the instrument rangi information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable. ..
In Reference 5, the-licensee provided the required information. The instrumentation provided meets the regulatory guide recommendations. ,
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3.3.38 primary Coolant and Sump Sampling Cacability 3 i
In Reference 4, the licensee did not. provide the instrument' range information required by Section 6.2 of Supplement No. 1 to NUREG-0737 for-this variable.
In Reference 5, the licensee provided the required information for all .
l parameters except for chloride content and dissolved oxygen.
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 has been addressed by the NRC as part of.their review of' NUREG-0737, Item II.B.3.
3.3.39 Containment Air Sampling Capability In Reference 4, the licensee did not provide the instrument range information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable. ,..
In Reference 6, the licensee provided the required information for all. ,
. parameters except for oxygen content. They have no capability to r.ead oxygen content.
18
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 has been addressed by the NRC as part of their review of NUREG-0737, Item II.B.3.
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' Based on our review,:we find that.the licensee either conforms to' or- 'd f a .
i is' justified in deviating from Reg 91atory Guide 1.97, .with the following ; f .\.pt( t,
- exceptions:
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1,- AccumulatorstanV.pf d and pressun--the(11iensee should p'for.ie , . _ - b, ' / j '
^
. Category 2 instrumentation for either ac umulator tank lertl NE N'
..prestgre and provide the inform'ation required by Section 6/ ' 's. u I
Supplement- No.. I- to NUREG-0737 for' the accumulator [ank level, e' s , .
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Gstrumentatidy (Section 3.3.13). ce ,. .,
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- 2. .Containmentatmospherecegrature--thelicensee-shouldpr$ vide '
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therangerecommended-byre [1dr;oryGuide.1.97orsubmit"analhsis M' ai .> .3 that shows the provided' range ?!1') envelop all ekpedce.d _
post-accident kmperakures (Section 3.3.24). b q cr .. 1 3^.
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- 3. Vent from steam geInerator iafety relief valves'or$tmospheric o i dump valves--the licens e,should provide environmentally: ,. q
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.y' qualified steanhe rad ation monitors or show that the( >exi' sting i ;
monitors are Mcv.ed in a mild environment (Section 3.3.31)lJ ' ,,i 1
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. 5. REFFhiENCES
- 1. Y tm Qpt'er, D. G. Eisenhut to A1) 1.icensees of' Operating Reactors, Appi rart.s for Operating Licensh. and Holders of Construction
,Pgrn, t$, "Suzolement No I to NUREG-0737--Requirements for Emergency Of
, Response Capa0ility (Generic Letter No. 82-33)," December 17,1983. -
1 1
//. N- "
'InstrumentatM for Light-Water-Cooled Nuclear Power Plants to Assess ]
(2.
l (; '
t f'11 ant and Environs ConditionsJaring and Following an Accicenti Pygvlatory Guide 1.97, Revision P'g NRC,'3ffice of Standards L , Dev'Mppment, December 1980. l '
t, D '
?, .,1 i. ~
i' 4 6 [ 3. C').pi l ation of TN.'.. Action p d Ar.ouirements. Requirements for
~
' - Ee'r~ Jcy Response Cac'ibility, ATREG-0737, Supplement No.1, NRC, .,
.Eifff:eefNuclear, Reactor *Regulabon, January 1983. {'
1 i, 1
. h 4 hxMarolina Electric and Gas Company letter, O. W. Dixon, Jr. to.-
- l bi r
, 3 e
lH.' pens, NRC, April 15, 1985.
j;
- 5. Sou*.h f :arolina Electric anci>1as Company letter, D. A. Nauman to T l H. Denton, NRC, "Regulato;. Guide 1.97 Request for Additional Infor ation," August 18,G 86.
p ]
- 6. Sout),brolinaElectricandGasCompany1'etter,D.A.Naumanto H.R.genton,NRC,"RegulatoryGuide1.97'RequestforAdditional L Informaion," October 31, 1986. ..
I 'if t ,
- 7. Instru:rentation for Light-Water-Coolid Nuclear Power Plants to Assess Plant and EnviroEs_ Conditions Dur,,i,n,3.,and Following an Accident, Regulatory Guide 1.97, Revision 3, MC, Offige of Nuclear Regulatory I Research, May 1983.
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- %',"3$' 818UOGRAPtHC DATA SHEET EGG-NTA.7231 S.. atif'4WC, toms os .. es,g egg
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Conformance to Regulatory Guide 1.97: -_
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NRC Technical Assistance EG8G Idaho, Inc. ' ,
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a.. c. o. .. .. ., ,o .. t .~o ... ..<, .oo... . n . <. c , f Division of Engineering and Systems; Technology Technical Evaluation Report Office of Nuclear Reactor Regulation , ,..,oo oo,... ,g,;;;;----
U.S. Nuclear Regulatory Commission Washington, DC 20555
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, , .. , . . e , .m . 1 This EG&G Idaho Inc., report reviews the submittals for the Summer )
Nuclear Station, and %ntifies areas of nonconformance to Regulatory .
i Guide 1.97. Exceptions to these guidelines are evaluated and those J areas where sufficient basis for acceptability is not provided are :
identified. ;
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