ML20244E419
| ML20244E419 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 07/31/1988 |
| From: | Stoffel J, Udy A IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20244E400 | List: |
| References | |
| CON-FIN-A-6483, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7368, GL-82-33, TAC-51367, TAC-51368, NUDOCS 8904240473 | |
| Download: ML20244E419 (25) | |
Text
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ATTACHMENT EGG-NTA-7368 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97: ZION-1/-2 Docket Nos. 50-295/50-304 J. W. Stoffe1 Alan C. Udy Published July 1988 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comtss ton Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6483 kh P
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ABSTRACT This EG&G Idaho, Inc., report documents the review of the submittals for Revision 2 of Regulatory Guide 1.97 for Unit Nos. 1 and 2 of the Zion Nuclear Power Station and identifies areas of nonconformance to the l regulatory guide. Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are
. . identified.
Docket Nos. 50-295/50-304 TAC Nos. 51367/51368 ii
l FOREWORD This report is supplied as part of the " Program for Evaluating Licensee /Applict. Lonformance 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 Systams Evaluation Unit.
The U.S. Nuclear Regulatory Commission Funded the work under authorization B&R 20-19-10-11-3.
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f Docket Nos. 50-295/50-304 TAC Nos. 51367/51368 111 a_______-___ . _ _ _ _ _ _ _
CONTENTS 3
ABSTRACT .............................................................. 11 FOREWORD .............................................................. iii
- 1. INTRODUCTION ..................................................... 1
- 2. REVIEW REQUIREMENTS .............................................. 2
- 3. EVALUATION ....................................................... 4 3.1 Adherence to Regulatory Guide 1.97 ......................... 4 3.2 Type A Variables ........................................... 4 3.3 Exceptions to Regulatory Guide 1.97 ........................ 5
- 4. CONCLUSIONS ...................................................... 19
- 5. REFERENCES ....................................................... 20 iv
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CONFORMANCE TO REGULATORY GUIDE 1.97: ZION-1/-2 )
- 1. INTRODUCTION 1
l 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 operating licenses and holders of construction permits. This letter. 3 included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency l
response capability. These requirements have been published as Supplement l No. 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).
Commonwealth Edison Company, the licensee for Unit Nos.1 and 2 of the Zion Nuclear. Power Station, responded to Section 6.2 of the generic letter with a letter dated August 1, 1986 (Reference 4). This provides a review of the instrumentation provided for Revision 2 of Regulatory Guide 1.97.
Additional information was provided on August 24, 1987 (Reference 5).
This report is based on the recommendations of Regulatory Guide 1.97, Revision'2, and compares the instrumentation proposed by the licensee's submittals with these recommendations.
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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 with Regulatory Guide 1.97 as applied to emergency response facilities. The submittal should include documentation that provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97.
- 1. Instrument range
- 2. Environmental qualification
- 3. Seismic qualification
- 4. Quality assurance
- 5. Redundance and sensor location
- 6. Power supply
- 7. Location of display
- 8. Schedule of installation or upgrade The submittal should identify any deviations taken from the Regulatory Guide 1.97 recommendations 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 address only exceptions taken to Regulatory Guide 1.97. Where licensees or applicants explicitly state that their instrument systems conform to the regulatory 2
guide, it was noted that no further staff review would be necessary.
Therefore, this report addresses only 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 August 1, 1986 and l August 24, 1987 submittals for Generic Letter 82-33 and on Revision 2 of Regulatory Guide 1.97.
3.1 Adherence to Regulatory Guide 1.97 The licensee's submittals for Unit Nos. 1 and 2 of the Zion Nuclear Power Station compares the provided post-accident monitoring instrumentation with the instrumentation recommended by Regulatory Guide 1.97, Revision 2. The licensee states, in Reference 4 that a final Regulatory Guide 1.97 report and implementation schedule will be submitted. The licensee states, in Reference 5, that modifications will be scheduled. Therefore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3.
3.2 Type 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. Reactor coolant system (RCS) hot leg water temperature (wide range)
- 2. RCS cold leg water temperature (wide range)
- 3. RCS pressure
- 4. Steam generator level (wide rJnge)
- 5. Steam generator level (narrow range) 4
- 6. Pressurizer level
- 7. Steam line pressure
- 8. Containment pressure
- 9. Refueling water storage tank level
- 10. Containment water level (wide range)
- 11. Auxiliary feedwater flow
- 12. Containment radiation level
- 13. Core exit temperature
- 14. RCS subcooling
- 15. Condensate storage tank level These variables, with exceptions as noted in Section 3.3, either meet or will meet the Category 1 recommendations, consistent with the requirements for Type A variables.
3.3 Exceptions to Reg'ulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.
3.3.1 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation to monitor this variable. The licensee has provided instrumentation that does not meet Category 1 requirements for environment', and seismic qualification.
The licensee states that they have reclassified this instrumentation to 5
. i Category 3 since the indication of reactivity control and reactor shutdown that they use is provided by the control rod position (short term) and by the post-accident sampling system for boron concentration (long term).
The licensee states that a reactor trip automatically activates the release of the control rods at the onset of accident symptoms, before harsh environmental conditions occur. Thus, the neutron flux source and intermediate range instrumentation is expected to operate for a period long enough to verify that the nuclear reaction is shut down. Further, the operator is required to initiate emergency boration should the rod bottom lights and neutron flux fail to indicate reactor shutdown. In addition, the reactor trip circuit breakers are accessible for visual indication of operation.
The measurement of neutron flux is the key variable, defined in Regulatory Guide 1.97, for detecting an uncontrolled approach to criticality and for determination that an accident has been and continues to be successfully mitigated. Control rod position and RCS soluble boron concentration are the backup variables (Category 3) as defined in 2 Regulatory Guide 1.97 and the alternative instrumentation discussed in
. Generic Letter 86-10. Because of this, the licensee's justification is not acceptable. Also, the licensee has not provided justification for the lack of seismic qualification.
The licensee should therefore provide instrumentation for this variable that is environmentally qualified in accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97 and seismically qualified in accordance with the provisions of Regulatory Guide 1.100.
3.3.2 RCS Cold Leo Water Temperature I
RCS Hot Lea Water Temperature l
Regulatory Guide 1.97, Revision 2, recommends instrumentation with a '
range of 50*F to 750*F for these variables. The licensee has provided a range of zero to 700*F. The licensee states that the existing range is 6
I adequate to monitor RCS design temperatures and pressure and in addition the core exit thermocouple indication piovides an alternate temperature indication. l l
The Itcensee indicates that the range supplied exceeds all expected l
design basis conditions. Based on this statement, we find this deviation acceptable. Further, Revision 3 of Regulatory Guide 1.97 (Reference 6) recommends a range of 50*f to 700*F. This range is met by the itcensee.
3.3.3 Core Exit Temperature The licensee has identified this variable as Type A which requires Category 1 instrumentation. The licensee is upgrading this instrumentation. The NRC has reviewed the acceptability of this variable as part of their review of NUREG-0737 Item II.F.2.
3.3.4 Decrees of Subcoolina Regulatory Guide 1.97 recommends environmentally qualified
- instrumentation for this variable. The licensee states that modifications are being made on this instrumentation. The NRC has reviewed the acceptability of this variable as part of their review of NUREG-0737, Itam II.F.2.
3.3.5 Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category,1 valve position indication for the purpose of verifying containment isolation. The licensee has provided a list of containment isolation valves and justification for exceptions from the regulatory guide recommendations.
Based on the information provided, we are unable to determine that the recommendations for redundancy, the single-failure criterion, and environmental qualification have been met. Thus, we conclude that the licensee's justification is inadequate to support the following exceptions, 7
- a. The licensee has listed a group of valves that do not have position indication for series pairs. The licensee states that backup indication is provided by various plant system variables.
The licensee should provide additional information for the valves listed, i.e., why is there no indication of individual valves of the series pair? Why is a plant system variable adequate to determine the proper valve position?
- b. The licensee states that all air operated and solenoid operated valves fail in the safe (closed) direction on loss of power, thus, position status for these valves need only meet Category 3 criteria.
The fact that these valves fail shut is not sufficient justification for not qualifying this position indication. A control circuit failure could cause a valve to be open. The operator should be able to positively ascertain that the valves are shut.
- c. We are unable to determine from the licensee's submittals which valve position switches are located in a mild environment and which ones are not. The licensee should provide information that verifies that all valve position switches requiring environmental qualification have environmentally qualified limit switches.
3.3.6 Radioactivity Concentration or Radiation level in Circulating Primary Coolant Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has provided Category 3 instrumentation stating that containment radiation and containment hydrogen concentration are the primary short-term indications of fuel-cladding integrity. The licensee further states that the post-accident sampling system provides additional, long term indication.
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Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.
3.3.7 Containment Effluent Radioactivity - Noble Gasses (from Identified Release Points)
Regulatory Guide 1.97 recommends Category 2 instrumentation with a
-6 range of 10 pCi/cc to 10- pC1/cc for this variable. The licensee, in Reference 4, indicated that an instrument is installed to monitor this variable that has a range of 10 cpm to 10 cpm. The licensee stated that this effluent path is not required for post-accident service and, because of this, meeting the regulatory guide recommendations for this variable is not applicable. In Reference 5, the licensee expanded this justification by stating that the main vent stack is a common plant vent and that this source discharges into the main vent stack in post-accident situations. Therefore, no specific instrumentation is required for this source by the regulatory guide.
3.3.8 Effluent Radioactivity-Noble Gases (from buildings--)
Regulatory Guide 1.97 recommends Category 2 instrumentation with a 3
range of 10-6 C1/cc to 10 : Ci/cc for this variable. The licensee, in Reference 4, indicated that an instrument is installed to 6
monitor this variable that has a range of 10 cpm to 10 e m. The licensee stated that this effluent path is not required for post-accident service and, because of this, meeting the regulatory guide recommendations for this variable is not applicable. In Reference 5, the licensee expanded this justification by stating that the main vent stack is a common plant vent and that this source discharges into the main vent stack in post-accident situations. Therefore, no specific instrumentation is required for this source by the regulatory guide.
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3.3.9 Residual Heat Removal (RHR) Flow 1
Regulatory Guide 1.97 recommends environmentally qualified instrumentation with a range of zero to 110 percent of design flow for this variable. The licensee states that the sensors are located in a mild environment and that the transmitter range is zero to 59.5 inches of water and zero to 300 inches of water. The range of the narrow range indicators is equivalent to zero to 1500 gallons per minute, and the range of the wide range indicators is equivalent to zero to 3300 gallons per minute. The wide range instruments read to 110 percent of the 3000 gallon per minute design flow rate.
Non-environmentally qualified instrumentation is acceptable since the instrumentation is located in a mild environment.
3.3.10 RHR Heat Exchanger Outlet Temperature Regulatory Guide 1.97 recommends environmentally qualified instrumentation with a range of 32*F to 350*F for this variable. The licensee states that the sensors are located in a mild environment and that the range of 50*F to 350*F is adequate for the intended monitoring functions.
Non-environmentally qualified instrumentation is acceptable since the instrumentation is located in a mild environment. The range recommended for this variable in Regulatory Guide 1.97, Revision 2, is 40*F to 350*F.
This deviation is less than 3 percent of the maximum recommended range.
Considering instrument accuracy and overall r'ange, we consider this deviation minor. Therefore, we find this deviation acceptable.
3.3.11 Accumulator Tank Level and Pressure Regulatory Guide 1.97 recommends environmentally qualified instrumentation for this variable with a range of 10 percent to 90 percent volume (for level) and zero to 750 psig (pressure). The licensee has 10
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supplied instrumentation with no environmental qualification. The provided ranges are approximately 20 percent to 95 percent of the tank volume and zero to 700 psig.
The licensee states that the primary function of both level and pressure instrumentation is to monitor the pre-accident status'of the accumulator tanks to assure that this passive safety system is prepared to serve its safety function.
The accumulators are passive aevices. Their discharge inte the reactor coolant system (RCS) is actuated solely by a decrease in RCS pressure. We find that the ranges of the instrumentation supplied for this variable are adequate to determine that the accumulators have discharged.
Therefore', the ranges of this instrumentation are acceptable for this variable.
The existing non-qualified instrumentation 1: not acceptable. An environmentally qualified instrument is necessary to monitor the status of these tanks. The licensee should designate either *evel 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.
3.3.12 Accumulator Isolation Valve Position I
-Regulatory Guide 1.97 recommends Category 2 instrumentation for this ;
variable. The licensee states that this requirement is not applicable at this station since these valves are de-energized in the open position.
Based on the licensee's justification that these valves are open and can not change position during or following an accident, we consider the instrumentation provided fcr this variable acceptable.
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f 3.3.13 Boric Acid Charaina Flow ;
Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. In Reference 5, the licensee states that environmental qualification is not required because the instrumentation is located in a mild environment. Therefore, we find the instrumentation provided l acceptable for post accident monitoring.
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3.3.14 Flow in Hiah Pressure Inlection (HPI) System Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of zero to 110 percent of design flow for this variable. Reference 4 told of instrumentation that is not environmentally qualified and with a range of zero to 3200 inches of water and zero to 25 psi. The licensee corrected this in Reference 5. The range is zero to 800 gallons per minute (zero to 600 inches of water), which is 200 percent of the design flow and is acceptable. The licensee also verified in Reference 5 that the instrumentation is located in a mild environment, and that the cables used are environmentally qualified. Based on the information provided, we find the licensee's instrumentation acceptable for this variable.
3.3.15 Flow in low Pressure Inlection (LPI) System ~
Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of zero to 110 percent of design flow for this variable. Reference 4 told of instrumentation that is not environmentally qualified and has a range of zero to 59.5 inches of water and zero to 300 inches of water. The licensee, in Reference 5, correlates this to z'ero to 1500 and zero to 3300 gallons per minute. The wide range instrument is 110 percent of the design flow rate (3000 gallons per minute). The licensee also verified in Reference 5 that the instrumentation is located in a mild environment, and that the cables are environmentally qualified. Based on the information provided, we find the licensee's instrumentation acceptable for this variable.
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l 3.3.16 Refuelina Water Storage Tank Level I
Regulatory Guide 1.97 recommends environmentally qualified l instrumentation for this variable. The licensee has instrumentation that l 1
is not environmentally qualified. Reference 4 states that a modification l is required. )
I The licensee comitted, in Reference 5 to upgrade this instrumentation in accordance with the Environmental Qualification Rule, 10 CFR 50.49, and Regulatory Guide 1.97. We find this comitment acceptable. ,
3.3.17 Primary System Safety-Relief Valve Position Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. In Reference 5, the licensee describes previous and future modifications to this instrumentation. When all modifications are complete, each of the two power operated relief valves will have Category 2 limit switch position indication and Category 2 temperature monitoring of
,, the valve discharge line. Each of three code safety valves will have Category 2 temperature monitoring of the valve discharge line and Category 3 acoustic monitoring. We find this instrumentation acceptable in complying with Regulatory Guide 1.97.
3.3.18 Quench Tank (Pressurizer Relief Tank) Temperature Regulatory Guide 1.97 recomends a temperature range of 50*F to 750*F for this variable. The licensee has provided a range of 50*F to 400*F and states that the instruments are adequate for the intended use. The licensee's temperature indication will remain on scale during any accident that lifts the pressurizer relief valves because the rupture disc is set at 100 psig. The saturation temperature corresponding to this pressure is 340*F. As this will not exceed the 400*F range, we find the provided range acceptable.
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3.3.19 Safety / Relief Valve Position or Main Steam Flow Regulatory Guide 1.97 recommends closed-not closed indication or steam flow indication to monitor this variable. The licensee indicates that the range is -20 inches to 400 inches of water. This corresponds to zero to 6
4.2 x 10 ounds mass per hour. The information provided by the licensee shows that adequate instrumentation is provided for this variable. We find the instrumentation acceptable for this variable.
3.3.20 Main Feedwater Flow Regulatory Guide 1.97 recommends instrumentation with a range of zero to 110 percent of design flow to monitor this variable. The licensee indicates that the range monitored is zero to 330 inches of water. This 6
corresponds to zero to 4.2 x 10 pounds mass per hour, which exceeds the 6
design flow of 3.5 x 10 pounds mass per hour by 20 percent. Thus, we find the instrumentation meets the recommendations of Regulatory Guide 1.97.
i 3.3.21 Auxiliary Feedwater Flow Regulatory Guide 1.97 recommends instrumentation for this variable with a range of zero to 110 percent of design flow. Since the licensee has designated this instrumentation as Type A, this instrumentation should be Category 1. The licensee states that the range is zero to 200 inches of water (zero to 300 gallons per minute) and that this exceeds the design flow of 225 gallons per minute per channel. There is one channel per steam generator.
The licensee states that only two of the four channels are required to achieve a safe shutdown. The instrument channels have redundant instrument power supplies and redundant auxiliary feedwater pumps are used. Further, the licensee has the ability to isolate flow through a damaged steam generator line. The licensee also states that each steam generator has narrow range level instrumentation that is available as backup indication.
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The-licensee states that the variable is Type A because the operator must verify a minimum total auxiliary feedwater flow of 340 gallons per minute, and a steam generator level of greater than 4 percent on the narrow range instruments of those steam generators with auxiliary feedwater flow j in order to terminate a safety injection. It is not required to initiate any manual action other than this. Because of this requirement, safety injection will not be terminated prematurely should a channel of auxiliary feedwater flow instrumentation fail to show flow. We note that this exemption is similar to the Regulatory Guide 1.97 allowance for a single j Category 1 wide range steam generator level channel per steam generator for !
3 or 4 1000 plants. The viability of each steam generator as a heat sink is shown by the combination of level and auxiliary feedwater flow. Thus, we find that one channel of auxiliary feedwater flow indication per steam generator is acceptable. Therefore, the instrumentation provided to meet the recommendations of Regulatory Guide 1.97 is acceptable.
3.3.22 Condensate Storace Tank Water Level Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has instrumentation that is not Category 1.
Reference 4 states that a modification is required.
The itcensee committed, in Reference 5, to upgrade this instrumentation to meet Category 1 requirements. We find this connitment acceptable.
3.3.23 Containment Atmosphere Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a l range of 40 to 400*f for this variable. The licensee has supplied 2 channels of Category 3 instrumentation with a range of zero to 150*f and a single Category 3 channel with a range of zero to 300*F. The licensee states that the containment atmosphere temperature is not a key variable for accident monitoring; that the key variable for monitoring containment cooling is containment pressure indication, which is monitored by 15
Category 1 instrumentation; and that the containment atmosphere temperature is a backup. variable for reactor building accident monitoring.
We find that the licensee's application of Category 3 backup instrumentation is in accordance with the regulatory guide. The licensee states that the maximum containment temperature is 271*F. As this is within the capacity of the zero to 300*F instrumentation, we find that the range of instrumentation provided for this variable acceptable.
3.3.24 Component Coolina Water Flow to Enaineered Safety Features (ESF)
System Regulatory Guide 1.97 recommends a flow range from 0 to 110 percent of de :n flow for this variable. The licensee has provided a range of 1500 gpm te 7000 gpm. The licensee states that the instruments are adequate for the intended purpose. ,
Br.hed on the licensee's justification and statement of compliance, we conc 7ude that 1500 gpm is the minimum flow that would be seen with the system in operation. Therefore, we find this deviation acceptable.
3.3.25 Emeroency Ventilation Damper Position Regulatory Guide 1.97 recommends Category 2 open-closed status instrumentation for this variable. The licensee states that the alternate indication provided is all located in a mild environment.
The licensee states that these dampers are automatically positioned in their accident position as a result of either a high radiation signal or a safety injection signal. The licensee's alternate instrumentation consists of the running status of the charcoal filter booster fans, the charcoal filter differential pressure ano control room radiation monitors. The licensee indicates that the dampers fail in the appropriate post-accident position, and that damper position can be verified locally. Further, system operation is verified monthly by observing the same differential 6
pressure to show that flow exists. The licensee states that if flow exists, the dampers can be assumed to be correctly positioned.
Based on the licensee's justification, we find the alternate instrumentation provided acceptable for this variable.
3.3.26 Noble Gases and Vent Flow Rate Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10-6 pC1/cc to 10* pCi/cc and flow monitored from zero to 110 percent of design flow. The licensee provides Category 2 instrumentation that is located in a mild environment. Reference 5 shows that this instrumentation exceeds the reconnended range. Therefore, the common plant vent instrumentation provided is acceptable for this variable.
3.3.27 Particulate and Halocens '
Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10-3 Ci/cc to 10 2 Ci/cc and flow monitored from zero to 110 percent of design flow. The licensee's instrumentation is capable, according to Reference 5 of measuring releases over this range.
Therefore, we find this instrumentation acceptable for triis variable.
3.3.28 Airborne Radiohalogens and Particulate Regulatory Guide 1.97 recommends that the instrumentation to monitor i airborne radiohalogens and particulate have a range of 10-' pCi/cc to l '
10~3 pC1/cc. The licensee states, in Reference 5, that the range provided is 10"" pC1/cc to 10 pC1/cc. As this exceeds the recommended range, we find that this instrumentation is acceptable.
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3.3.29 Plant and Environs Radiation Regulatory Guide 1.97 recommends that the plant and environs radiation monitors have a range of 10' R/hr to 10 R/hr. The licensee states that the existing range is zero to 10 R/hr.
We find this deviation acceptable as the instrumentation is portable and would not be used to assess levels of radiation greater than the range provided.
3.3.30 Estimation of Atmospheric Stability ,
1 Regulatory Guide 1.97 recomends a range of -9'f to +18'F over a l l
50 meter elevation differential. In Reference 5, the licensee describes '
their instrumentation for this variable. Differential temperatures of
-20*F to +40*f for elevation differences of 90 feet (which is less than recommended) and 215 feet (which is greater than recommended) can be measured. We find the instrumentation described acceptable for this variable.
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- 4. 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. Neutron Flux--Environmental qualification should be provided in accordance with 10 CFR 50.49 and Regulatory Guide 1.97 and seismic qualification should be provided in accordance with Regulatory Guide 1.100. (Section 3.3.1) 1
- 2. Containment Isolation Valve Position--The licensee should provide additional information and commitments to resolve the questions on redundancy, the single failure criterion, and environmental qualification for this indication. (Section 3.3.5)
- 3. Accumulator Tank Level and Pressure--Environmentally qualified instrumentation should be provided for this variable.
(Section 3.3.11) w l
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, 5. REFERENCES j
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- 1. NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Pertaits, " Supplement No. 1 to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.
- 2. Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Following an Accident, Regulatory Guide 1.97, Revision 2 NRC, Office of Standards Development, December 1980.
- 3. Clarification of TMI Action Plan Requirements. Requirements for Emergency Response Capability, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
- 4. Letter, Commonwealth Edison Company (P. C. LeBlond) to NRC (H. R. Denton), "NUREG-0737, Supplement 1 - Confirmatory Order - Regulatory Guide 1.97," August 1, 1986.
- 5. Letter, Commonwealth Edison Company (P. C. LeBlond) to NRC, "NUREG-0737, Supplement 1 - Confirmatory Order Regulatory Guide 1.97,"
August 24, 1987.
- 6. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Fo110wina an Accident, Regulatory Guide 1.97, Revision 3 NRC, Office of Nuclear Regulatory Research, May 1983.
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