ML20246B973
| ML20246B973 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 03/31/1989 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20246B978 | List: |
| References | |
| CON-FIN-A-6493, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7643, EGG-NTA-7643-01, EGG-NTA-7643-1, TAC-57192, TAC-63250, TAC-64029, TAC-64056, NUDOCS 8905090229 | |
| Download: ML20246B973 (24) | |
Text
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EilCLOSURE 2 EGG-NTA-7643 March 1989 L...
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TECHNICAL EVALUATION REPORT 1
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Idaho CONFORMANCE TO REGULATORY GUIDE 1.97:
- fi-National BYRON-1/-2 AND BRAIDWOOD-1/-2 Engineering
' Laboratory l
' Managed Alan C. Udy by the U.S.
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ofEnergy.
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Prepared for the H
U.S. NUCLEAR REGULATORY COMMISSION
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Work performed under DOE Contract -
No. DE-AC07-76tD01570 c_
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4 EGG-NTA-7643 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97:
BYRON-2/-2 AND BRAIDWOOD-1/-2 Docket Nos 50-454/50-455 and 50-456/50-457 Alan C. Udy Published March 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear f.sgulatory Commission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6493 TAC Nos. 57192, 63250, 64029, and 64056
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SUMMARY
This EG&G Idaho, Inc., report documents the review of the submittals-for Revision 3 of 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
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those areas where' sufficient basis for acceptability is not provided are identified.
FIN No. A6493 B&R No. 20-19-40-41-3 Docket Nos. 50-454/50-455 and 50-456/50-457 TAC Nos. 57198, 63250, 64029, and 64056 i
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L PREFACE This report is supplied as part of the " Program for Evaluating '
Licensee / Applicant Conformance to R.G. 1.97," being conducted for the U.S.
- Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering and System Technology, by EG&G Idaho, Inc.,
Electrical, Instrumentation, and Control Systems Evaluation Group.
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e-ja CONTENTS f
SUMMARY
11 PREFACE'...............................................................
iii 1.
INTRODUCTION.....................................................
I 2.
REVIEW REQUIREMENTS..............................................
2 3.
EVALUATION.......................................................
4 3.1 Adherence to Regulato ry Guide 1.97.........................
4 3.2' Type A Variables............................................
4 3.3 Exceptions to Regulatory Guide 1.97........................
5 3.3.1
. Neutron Flux.......................................
5 3.3.2 RCS Soluble Boron Concentration....................
6 3.3.3 RCS Cold Leg Water Temperature RCS Hot Leg Water Temperature......................
6 3.3.4 Radiation Level in Circulating Primary Coolant.....
7 3.3.5 Residual Heat' Removal (RHR) Flow...................
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3.3.6 RHR Heat Exchanger Outlet Temperature..............
8 3.3.7 Accumulator Tank Level and Pressure................
8 3.3.8 Bori c Acid Cha rgi ng Flow...........................
9 3.3.9 Flow in High Pressure Safety Injection (HPSI)
System.............................................
9 3.3.10 Flow in Low Pressure Safety Injection (LPSI)
System.............................................
10 3.3.11 Pressurizer Heater Status..........................
10 3.3.12 ' Quench Tank Temperature...........................
11 3.3.13 ' Steam Generator Level..............................
11 3.3.14 Steam Generator Pressure...........................
12 3.3.15 Safety Relief Valve Position or Main Steam Flow....
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-3.3.16 Aux il i a ry Feedwa te r Fl ow...........................
13 3.3.17 Condensate Storage Tank Water Level................
13 3.3.18 Containment Atmosphere Temperature.................
14 3.3.19 Containment Sump Water Temperature.................
14 3.3.20 Makeup Flow-In Letdown Flow-Out Volume Control Tank Level..........................
15 3.3.21 Component Cooling Water Temperature to Engineered Safety Features (ESF) System Component Cooling Water Flow to ESF System.........
15 3.3.22 Radiation Exposure Rate............................
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CONCLUSIONS......................................................
17 5.
REFERENCES.......................................................
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CONFORMANCE TO REGULATORY GUIDE 1.97:
BYRON-1/-2 AND BRAIDWOOD-1/-2 l
1.
INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Divisis. af 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.1 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 submittal provides a review'of the instrumentation provided by the Byron and Braidwood Stations for Revision 3 of Regulatory Guide 1.97 (Reference 5).
Additional information was submitted on September 1, 1987 (Reference 6),
December 28, 1987 (Reference 7), and July 27, 1988 (Reference 8).
This report is based on the recommendations of Regulatory Guide 1.97, Revision 3, and compares the instrumentation proposed by the licensee's submittals with these recommendations.
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REVIEW REQUIREMENTS 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 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
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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 instrument systems conform to the regulatory guide, 2
4 it was noted that no further staff review would be necessary. Therefore, this report addresses only deviations and exceptions taken from Regulatory Guide 1.97. The following evaluation is an audit of the licensee's submittals based on the review policy described in the NRC regional meetings.
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3.
EVALUATION This evaluation is based on the licensee's February 27, 1987; September 1, 1987; December 28, 1987; and July 27, 1988, responses to Generic Letter 82-33.
3.1 Adherence to Regulatory Guide 1.97 si The licensee's submittals for Unit Nos.1 and 2 of the Byron and Braidwood Stations compare their post-accident monitoring instrumentation with the instrumentation r3 commended by Regulatory Guide 1.97, Revision 3.
The licensee states that References 4 and 6, together, represent their
' final Regulatory Guide 1.97 report. Reference 6 also contains an implementation schedule for any identified modifications.
Reference 7 contains further amplification of commitments made and other available instrumentation. 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) pressure (wide range) 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) 4
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Pressurizer level (narrow range) y 7.
Containment pressure (narrow range) l 8.
Containment pressure (wide range) 9.
Main steam pressure
- 10. Refueling water storage tank level l
- 11. Containment water level (wide range)
- 12. Containment radiation level
- 13. Main steamline radiation level
- 14. Core exit temperature
- 15. Spray additive tank level These variables, with exceptions as noted in.Section 3.3, either meet or will meet the Category I recommendations, consistent with the requirements for Type A variables.
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 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation to monitor this variable. The licensee has provided instrumentation that meets the Category I requirements, with the exception of recording capability. The 5
licensee states that they are adding computer inputs to meet this requirement..This modification will be complete at the conclusion of the first refueling outage for each unit following the September 1, 1987 report. Once. complete, the instrumentation for this variable will be in compliance with Revision-3 of Regulatory Guide 1.97.
3.3.2 RCS Soluble Baron Concentration t
Regulatory Guide 1.97 recommends a -range of zero to 6000 parts per million for this variable. -The licensee has provided on-line monitoring for this variable, with a digital range of zero to 5000 parts per million.
The licensee considers this range adequate for the intended purpose of Regulatory Guide 1.97, because the borated water that is injected is kept at a concentration of 2000 parts per million boron. This is diluted to less.than 2000 parts per million when injected into the reactor coolant.
system.
Based on the refueling water storage tank boron concentration being 2000 parts per million, we find the zero to 5000 parts per million range acceptable.
3.3.3 RCS Cold Leg Water Temperature RCS Hot Leg Water Temperature Regulatory Guide 1.97 recommends redundant power supplies for these variables. The licensee supplies all four channels of the cold leg instrumentation from a Division I instrument bus and all four channels!of the hot leg instrumentation from a Division II instrument bus. The licensee considers this arrangement adequate, because these instrument buses are backed up by standby power sources (diesel and battery) and the core exit temperature indication provides an 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 6
instruments' tion is powered by a second UPS. Diverse instrumentation (core exit temperature and steamline pressure) are powered by additional UPS power sources. These power-sources were previously reviewed by the NRC and found to be acceptable. We find this to be a good faith attempt to meet NRC requirements, as defined in NUREG-0737, Supplement No. 1, Section 3.7 (Reference ?) and, therefore, acceptable.
3.3.4 Radiation Level in Circulating Primary Coolant The licensee uses the post-accident sampling system, wF.ich has been reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3, to measure this parameter.
Based on the alternate instrumentation provided by the lic W ee, 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 Category 2 instrumentatf or for this variable. The instrumentation installed to measure the RHR flow is classified Category 3, because it is not environmentally qualified. The licensee states that this instrumentation is backup instrumentation for the key variables that monitor the operation of the RHR system: engineered safety feature (ESF) system status monitoring lights, component status indications, and pump motor ammeters. This instrumentation is said to be Category 2.
In addition, the refueling water storage tank level and the reactor vessel level indicators supply information on the overall emergency core cooling system (ECCS) performance.
As the licensee has verified that these key variables are monitored by Category 2 instrumentation, we find the Category 3 flow instrumentation provided to be acceptable.
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3.3.6 RHR Heat Exchanger Outlet Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of 40 F to 350 F for this variable. The licensee states that the instrumentation is classified Category 3 because the sensors are not environmentally qualified. The licensee also states that the range of 50 F to 350*F is adequate for the intended monitoring functions, 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.
The instrumentation installed to measure the RHR heat exchanger outlet temperature is not environmentally qualified. The licensee states that this instrumentation-is backup instrumentation for the key variables that monitor the operation of the RHR system:
ESF system status monitoring lights, component status indication, and pump motor ammeters. This instrumentation is said to be Category 2.
In addition, the refueling water storage tank level and the reactor vessel level indicators supp")
information on the overall ECCS performance. However, none of tnis alternate instrumentation will provide tha temperature of the coolant being-recirculated to the reactor core.
The licensee should upgrade this instrumentation to include environmentally qualified temperature sensors.
3.3.7 Accumulator, Tank Level and Pressure Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The range of the pressure instruments should be from zero to 750 psig. The licensee has supplied instrumentation with no environmental qualification. The provided range of the pressure instrument is zero to 700 psig. The licensee states that the design pressure for the accumulator tank is 700 psig.
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The accumulators are passive devices. Their discharge into the reactor coolant system (RCS) is actuated sclely by a decrease in RCS pressure. Should three of the four accumulators discharge, the injection 4
is considered successful by the licensee. We find that the range of the pressure instrumentation supplied for this variable is adequate to determine that the accumulators have discharged. Therefore, the range of the instrumentation for this variable is acceptable.
4 The licensee states that no operator action is specified by the h
Emergency Operating Procedures based on post-accident accumulator level or pressure. This statement confirms that this instrumentation is not Type A, Category 1.
The licensee states (Reference 8) that they will evaluate the feasibility and cost of upgrading either level or pressure (as the key variable for monitoring accumulator operation) to Category-2 recommendations.
The existing nonenvironmentally qualified instrumentation is not acceptable for monitoring the discharge of the accumulators. The licensee should provide the NRC with their schedule for upgrading either the level or pressure instrumentation to meet the requirements of 10 CFR 50.49 and Regulatory Guide 1.97.
3.3.8 ~ Boric Acid Charging Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The instrumentation provided is classified Category 3, because it is not environmentally qualified. This path of injection is the normal charging flow path. This path of injection is isolat+j by a Phase A containment isolation signal.
As a safety injection results in the isolation of this flow, we find the instrumentation provided to be acceptable.
3.3.9 Flow in High Pressure Safety Injection (HPSI) System Regulatory Guide 1.97 recommends Category 2 instrumentation for this l
variable. The instrumentation installed to measure the HPSI flow is 9
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e classified Category 3, because it is not environmentally qualified. The licensee states that_this instrumentation is backup instrumentation for the Lkey variables to monitor the operation of the HPSI system:
ESF system status monitoring lights, component status indication, and pump motor
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ammeters. : This instrumentation is said to be Category 2.
In addition,.the refueling water storage tank level and the reactor vessel level indicators supply information on the overall ECCS performance.
As the licensee has verified that these key variables are monitored by Category 2 instrumentation, we find the Category 3 flow instrumentation provided to be acceptable.
3.3.10 Flow in Low Pressure Safety Injection (LPSI) System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The instrumentation installed to measure the LPSI flow is classified Category 3, because it is not environmentally qualified. The licensee states that this instrumentation is backup instrumentation for the key variables that monitor the operation of the LPSI system: ESF system status monitoring lights, component status indication, and pump. motor ammeters. This instrumentation is said to be Category 2.
In addition, the refueling water storage tank. level and_the reactor vessel level indicators supply information on the overall ECCS performance.
As the licensee has verified that these key variabl s are monitored by Category 2 instrumentation, we find the Category 3 flow instrumentation provided to be acceptable.
3.3.11 -Pressurizer Heater Status Regulatory Guide 1.97 recommends Category 2 electric current monitoring instrumentation for this variable. The licensee states that on-off indication and electric current indication are available, but the power supply is not safety-related. The licensee's technical specification surveillance of the heater group capacity and the operability of the 10 I
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1 cross-tie breaker (that accesses the diesel generator supplied power) assure that the heater will be operable. The licensee states that the controls are in compliance with NUREG-0737 Item II.E.3.1.
As the i
instrument power supply is dependent on the heater power supply, current (or circuit breaker position) is operable only when a power source is
' available. Because of this, we find the instrumentation provided to be acceptable.
3.3.12 Quench Tank Temperature Regulatory Guide 1.97 recommends a range of 50"F to 750 F for this variable. The licensee has.provided a range of 50 F to 300'F. The licensee considers this range adequate, because it covers the normal operating design conditions under which the tank is expected to maintain
.its integrity and '.he temperature of the tank contente, which has the potential to go above the 300 F limit of the scale, will only exceed the range by approximately six percent. The licensee states (Reference 8) that they will evaluate the feasibility and cost of upgrading the present instrumentation.
The regulatory guide is specific that instrumentation should remain on-scale.to eliminate the potential for the operator to misinterpret an off-scale instrument as a failed instrument.
Therefore, the licensee should rerange this instrumentation to include the maximum expected saturation temperature (338 F at the relief disc set pressure of 100 psig) during any accident that is expected to lift the pressurizer relief valves. The licensee should provide the NRC with a schedule for this i
modification.
3.3.13 Steam Generator Level Regulatory Guide 1.97 recommends Category 1 instrumentation for the wide-range steam generator level and for Type A variables. Regulatory Guide 1.97 specifically allows a single wide-range channel per steam generator for four-loop plants. This is met by the licensee.
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The licensee has determined that steam generator level (narrow range) is a Type A variable and that the strip chart recorder for this instrument is not seismically qualified. As the instrument signal is also recorded on the plant computer, we find this devfation to be acceptable.
3.3.14 Steam Generator Pressure Regulatory Guide 1.97 recommend: a range of zero to 20 percent above the lowest safety valve setting for this variable. The licensee has provided a range (zero to 1300 psig) that is only 12 percent above the lowest safety valve setting. The licensee considers this adequate because 1300 psig is above the highest relief pressure setting of the safety valves.
Based on the licensee's justification, we find the existing range l
adequate to monitor the steam generator pressure during all accident and post-accident conditions. Therefore, the range of zero to 1300 psig is an acceptable deviation from Regulatory Guide 1.97, 3.3.15 Safety Relief Valve Position or Main Steam Flow Regulatory Guide 1.97 recommends either Category 2 safety relief valve position indication or Category 2 main steam flow instrumentation for this variable. The licensee has provided main steam safety relief valve position indication. There is no equivalent indication for individual steam generators. The licensee also has main steam flow indication; however, it is not environmentally qualified. The licensee states that, under Emergency Operating Procedures, main steam pressure is used to determine a fault 6d steam generator. There are three Category 1 steamline pressure instruments on each of the four steamlines. The licensee uses the Category 3 steam flow (two instruments per steamline) as backup instrumentation.
The licensec states that the main steam isolation valves (MSIVs) must be closed to diagnose a faulted steam generator with either steam flow or l
pressure providing information to the operator. Core cooling would be monitored during an event that opened a safety relief valve by observing l
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RCS and core temperature indications. Additionally, the licensee states that steam flow is not used to diagnose any plant conditions, either by Critical Safety Function Status Trees or by Function Recovery Guidelines.
Based on the justification presented by the licensee and.on the procedural use of steamline pressure to diagnose an open safety relief valve, we find the Category 3 main steam flow instrumentation to be acceptable for this variable.
3.3.16 Auxiliary Feedwater Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. Originally, the licensee classified this as a Type A variable that would require recording of the flow signal.
Reference 8 re-evaluates this classification, and recants the Type A classification. As described, the instrumentation meets the requirements of Category 2 instrumentation.
The licensee has justified why the more stringent Category 1 requirements are not necessary for this variable. We find the instrumentation provided to be acceptable.
3.3.17 Condensate Storage Tank Water Level Regulatory Guide 1.97 recommends Category 1 instrumentation for the primary source of auxiliary feedwater. The licensee states that the essential service water system is the Category 1 source of auxiliary feedwater. The regulatory guide recognizes this possibility.
The licensee identified the following instrumentation for monitoring the redundant trains of the essential service water system:
supply header temperature (Category 1), return header temperature (Category 1), ESF equipment monitor lights (Category 2), component status lights (Category 2), essential service water pump ammeters (Category 2), and pump discharge pressure (Category 2). Additionally, the steam generator level (Category 1) instruments and the auxiliary feedwater flow (Category 2) instruments show the performance of the auxiliary feedwater system.
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We find the instrumentation provided to be acceptable for this variable.
I 3.3.18 Containment Atmosphere Temperature l
l Regulatory Guide 1.97 recommends Category 2 instrumentation for this l
l variable. The instrumentation installed is not environmentally qualified.
The licensee has acknowledged this. The licensee states that containment pressure initiates all ESF containment cooling functions and is the key variable for assessing containment conditions and the effectiveness of the containment cooling systems.
The containment atmosphere temperature is not used in any post-accident procedure, nor is it used for contingency actions, emergency
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procedures, or function recovery guidelines. Steam tables can be used to convert the saturated steam containment pressure to temperature if this information is needed for event analysis.
Based on the licensee's justification and on the use cf the containment pressure instrumentation (Category 1) to assess containment conditions and the effectiveness of the containment cooling systems, we I
find the Category 3 containment temperature instrumentation provided to be acceptable.
3.3.19 Containment Sump Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a range of 50 F to 250 F to monitor this varit.ble. The licensee has not j
provided instrumentation for this variable, stating that the containment j
sump water temperature is not required to be monitored to detect R4R or j
i containment spray pump cavitation when in the recirculation mode. This I
argument was previously accepted by the NRC for pump considerations only.
Reference 8 amplified the arguments for not needing this instrumentation for Net Positive Suction Head (NPSH) or cavitation considerations, i
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The licensee has not provided sufficient justification for this exception..The licensee should provide the recommended instrumentation for the functions outlined in Regulatory Guide 1.97 or identify other n
instruments that provide the same information (such as the residual heat removal. heat exchanger inlet temperature) and that satisfy the regulatory guide.
3.3.20 Makeup Flow-In Letdown Flow-Out Volume Control Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation to monitor these variables. The instrumentation inst.alled is Category 3.
The m Lume control system, including makeup flow,' letdown flow, and the volume control tank are isolated by a Phase A containment isolation system.
As a safety injection re:ults in the isolation of this system, we find the instrumentation providad to be acceptable.
3.3.21 Component Cooling Wattg e perature to Engineered Safety Features i
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{ESF) System Cpmponent Cooling Water Flow to ESF System Regulatory Guide 1.97 recommends Category 2 instrumentation to monitor these variables. The instrumentation installed is Category 3.
The licensee states that the essential service water and the component cooling water systems are not throttled down, but rather, as a result of the accident, are automatically operated at maximum flow. Monitor lights, equipment (valve) position, equipment status indication, and flow indication are provided. The electrical switchgear and, therefore, the pump running and pump motor current indications, are located in a mild environment. The water temperature is not controlled, but is essentially the temperature of the ultimate heatsink.
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water and the component cooling water, we find that the licensee's justification for pro
'ng Category 3 temperature indication is adequate.
The temperature of the.ooling water to the ESF system components will I
always be within the design range. Therefore, this deviation from Regulatory Guide 1.97'is acceptable.
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the'l'icensee to supplement the flow instrumentation, we find the
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instrumentation provided to be acceptable.
3.3.22 Radiation Exposure Rate 1
i Regulatory Guide 1.97 recommends radiation exposure rate instruments in areas where access is required to service equipment important to a
safety. The licensee states that area radiation monitors (range of 1
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0.1 mrem /hr to 10 mrem /hr and 1 mrem /hr to 10 mrem /hr) are used in combination with hand-held survey instruments and process radiation monitors when entry is required.
From a radiological standpoint, if the radiation levels reach or exceed the provided range, personnel would not be permitted into the areas I
without portable monitoring (except for life saving). Based on the alternate, supplemental instrumentation used by the licensee for this variable, we find the instrumentation proposed for this variable to be acceptable.
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CONCLUSIONS Based on our review, we find that ti licensee either conforms to or is justified in deviating from Regulator Guide 1.97, with the following exceptions:
1.
RHR heat exchanger outlet temperature ---The licensee should provide environmentally qualified temperature instrumentation for this variable. (Section 3.3.6) 2.
Accumulator tank level and pressure -- The licensee should provide envlronmentally qualified instrumentation for either the level or the pressure portion of this variable. The licensee should also provide the NRC with the schedule developed for upgrading this instrur.entation.
(Section3.3.7) i 3.
Quench tank temperature -- The licensee should expand the range to remain on scale during accident conditions. The licensee should also provide the NRC with the schedule developed for reranging this instrumentation.
(Section 3.3.12) 4.
Containment sump water tengerature -- The licensee should provide the recommended instrumentation or identify other instrumentation i
that satisfies the regulatory guide requirements. (Section 3.3.19) 1 I
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'4 REFERENCES-
@i 1.
Letter, NRC (D. G. Eisenhut) to All Licensees of Operating Rehetors, s
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 Plant and Environs Conditions During and Following an Accident,
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' Regulatory Glide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.
=3.
Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability, NUREb-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1953.
4.
Letter, Commonwealth Edison Ccapany (K. A. Ainger) to NRC (H. R.
Denton), " Regulatory Guide 1.97 Compliance Preliminary Report,"
February 27, 1987.
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 Research, May 1983.
6.
Letter, Commonwealth Edison (S. C. Hunsader) to NRC (T. E. Murley),
" Regulatory Guide 1.97 Compliance Final Report," September 1,1987.
7.
Letter, Commonwealth Edison (S. C. Hunsader) to NRC (T. E. Murley),
" Regulatory Gui6e 1.97 Compliance Final Report," December 28, 1987.
8.
Letter, Commonwealth Edison (S. C. Hunsader) to NRC (T. E. Murley),
" Regulatory Guide 1.97 Compliance," July 27, 1988.
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.A6493 w 5FoNSOMeNG ORGANi2 AfloN NAME ANo MAILe*Q Acont&8 fsa=*es te cases its TYPE C 7 At OAT Division of. Engineering and Systems Technology Technical Evaluation Report Office of. Nuclear Reactor Regulation U.S. Nuclear Regulatory Cownission Washington, DC 20555
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it sueektutNTAmy morts 13 A4STRACT d200 weres a west This EG&G Idaho, Inc., report reviews the submittals for the Byron-1/-2 and Braidwood-1/-2 Stations, and identifies areas of.nonconformance to Regulatory Guide 1.97.
Exceptiens to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.
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