View source for 2CAN948404, Forwards Comprehensive Rept & Schedules for Proposed Instrument Upgrades,Per Suppl 1 to NUREG-0737 & Reg Guide 1.97.Progress of Implementation & Upgrades Will Be Reported Biannually

{{Adams
| number = ML20083R892
| issue date = 04/13/1984
| title = Forwards Comprehensive Rept & Schedules for Proposed Instrument Upgrades,Per Suppl 1 to NUREG-0737 & Reg Guide 1.97.Progress of Implementation & Upgrades Will Be Reported Biannually
| author name = Marshall J
| author affiliation = ARKANSAS POWER &amp; LIGHT CO.
| addressee name = Eisenhut D
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000368
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0737, RTR-NUREG-737
| document report number = 2CAN948404, NUDOCS 8404240350
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 35
}}

=Text=
{{#Wiki_filter:ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 371-4000 April 13, 1984 2CAN948404 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

==SUBJECT:==
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License ho. NPF-6 NUREG 0737 Supplement 1 -
Regulatory Guide 1.97 Gentlemen:
Section 6 of Supplement 1 to NUREG 0737, pertaining to Regulatory Guide 1.97, requires each licensee to submit a report describing how it meets the specific recommendations of Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Environs Conditions During and Following an Accident." In our response to Supplement I dated April 15, 1983, AP&L cocriitted to submit the AN0-2 Regulatory Guide 1.97 position document by April 15, 1984. The attached document contains this comprehensive report and includes the schedules for proposed instrument upgrades. In the development of this position document AP&L has expended in excess of $400,000. We expect the cost associated with implementing the proposed modifications identified in this position document'to be in excess of $1.2 million. Assuming no extraordinary delays, all modifications should be implemented during the next three refueling outages.
It was the NRC's intent, as stated in the cover letter transmitting Supplement 1 to NUREG 0737, that Regulatory Guide 1.97 be used as a source of guidance as opposed to being interpreted as a strict regulation, for both the NRC and the licensee. AP&L supports this position, for it allows the needed flexibility for each licensee to comply with this plant specific issue.
8404240350 840413 PDR ADOCK 05000368 F                    PDR                                        400 h
I Sl MEMBER MIDOLE SOUTH UTIUTIES SYSTEM La

Mr. Darrell G. Eisenhut                                 April 13,1984 We  believe the attached document fully addresses Section 6 to NUREG 0737 Supplement 1 for AN0-2.
lie will keep you informed of our progress in the implementations of our upgrades committed herein through the biannual updates on NUREG 0737 Supplement 1.
Very truly yours,
( ,         If <~~
ohn R. Marshall Manager, Licensing JRM:DEJ:dr Enclosures

l ARKANSAS NUCLEAR ONE UNIT 2 REGULATORY GUIDE 1.97 POSITION DOCUMENT INTRODUCTION Supplement 1 to NUREG-0737 was transmitted with Mr. D. G. Eisenhut's Generic Letter 82-33 dated December 17, 1982 (OCNA128226). This document required AP&L to develop a position regarding compliance with Regulatory Guide 1.97 and to submit this position to the NRC on a schedule consistent with that of an overall integrated program to meet all NUREG-0737 Supplement 1 require-ments. Section 6.2 of' Supplement 1 to NUREG-0737 recommended that the submittal include documentation, which could be in the form of a table, which addresses the following for each Type A, B, C, D and E variable shown in Regulatory Guide 1.97:
(a) instrument range (b) environmental qualification (c) seismic qualification (d) quality assurance (e) redundance and sensor (s) location (s)
(f) power supply (g) location of display (h) schedule for any new installation or upgrade This document provides the requested information and is consistent in organization with Table 3 (PWR Variables) of Regulatory Guide 1.97, Revision 3, dated May 1983. Revision 3 was used as opposed to Revision 2 because it more accurately reflects the current NRC guidance on post-accident monitoring.
TABLE FORMAT                                                   -
Table 1 (attached) lists the variables recommended by Regulatory Guide 1.97, Revision Flux,   10  _g,to100%F.P., Cat.1).and       identifies The          thecolumns subsequent   recommended     range provide the    and category AP&L response to the Regulatory Guide 1,97 recommendations including the AP&L assigned category, range, redundancy, power supply, type of control room display, availability on SPDS, schedule for upgrading if applicable, and comments. The comments provided include current instrumentation capabil-ities as well as planned upgraded capability.
The power supply column specifies the type of available power as follon:
1E - instrument is powered from a qualified IE power source.
UPS - instrument is powered from a battery backed uninterruptable power source.
DG - instrument is powered from a source that is backed by the emergency diesel generators.
OP - instrument is powered from the normal offsite power source.
i i
l 1                                                 l I

l l
The SPDS column specifies whether the variable is available on the SPDS display. The SPDS display is located in both the Unit 1 and Unit 2 Control Rooms, the Technical Support Center and the Emergency Offsite Facility.
Another type of Control Room Display is the Gaseous Effluent Radiation Monitoring System (GERMS). The GERMS is a computerized dose projection system which combines effluent release data with real time meteorological data. GERMS terminals are located in the same facilities as the SPDS.
The schedule column specifies the expected latest date for completion of any planned upgrades. All equipment modified'. ions necessary will be performed during refueling outages to allow safe installation. The schedules given identify the refueling outage when the work is planned to be completed. A schedule of 2R4 implies the upgrade will be completed by the end of the ANO-2 fourth refueling outage. The current schedule for the ANO-2 fourth refueling outage is June, 1985, for the fifth refueling outage is December, 1986 and the Unit 2 sixth refueling outage is August, 1988. These dates are approximations since the actual refueling outages are dependent on plant availability. The specified schedules are based on an integrated consider-ation of currently planned major plant modifications.
The comment column specifies the status of compliance (i.e., complies, will comply, complies with justification) and gives the reference for further information including justification of deviations and explanation of planned modifications.
DEFINITION GF VARIABLES i~
The variables identified in Table 1 are divided into five. types in accordance with the Regulatory Guide 1.97. The definition for each type of
 ! variable is as follows:
Type A - Those variables vhich provide the primary information required to permit the control room operators to take specific manual actions for which no automatic control is provided, and that are required for a safety system to accomplish its safety function for design basis accident scenarios. Type A variables are not specified in Regulatory Guide 1.97. They are plant specific and must be selected based on a review of Emergency Operating Procedures to identify information essential for the direct accomplishment of specified safety functions.
As a result of a review of the ANO-2 Emergency Operating Procedures, the following variables were identified as Type A:
RCS Hot Leg Water Temperature RCS Pressure Containment Hydrogen Concentration Steam Generator Level Steam Generator Pressure l
2

Type B - These variables provide information to indicate whether plant safety functions are being accomplished. Plant safety functions are defined as:     reactivity control, core cooling, maintaining reactor coolant system integrity, and maintaining containment integrity.
Type C - These variables provide information to indicate the potential for breach or the actual breach of barriers to fission product release.
The barriers are defined as: fuel cladding, primary coolant pressure boundary, and containment.
Type D - These variables provide information to indicate the operation        ,
of individual _ safety systems and other systems important to safety.
These variables help the operator make appropriate decisions in using the. individual systems important to safety in mitigating the consequences of an accident.
Type E.- These variables provide information for use in determining the magnitude of_the release of radioactive materials and for use in assessing the consequences of such releases.
EVALUATION CRITERIA As recommended by Regulatory Guide 1.97, each variable type was evaluated based on the importance to-safety of the measurement of the specific variable. The criteria are therefore separated into three categories for a graded approach as follows:
Category 1:     provides the most stringent requirements and'is intended for key variables. Type A, B-&nd C key variables fall into this-category.
Category 2:     provides less stringent' requirements and applies to instrumentation designated for indicating system operating       ;
status. Type D and E key variables fall into this category.
Category 3:     provides requirements that will~ ensure that high quality off-the-shelf instrumentation is obtained and applies to backup and diagnostic instrumentation. This category is also used when the. state-of-the-art will not support requirements for higher qualified instrumentation. All backup variables, fall into this category.
The specific design and qualification criteria used to evaluate each variable, based on the category classification, are presented below:
3-

CATEGORY 1:
Environmental Qualification - Currently installed instrumentation was evaluated to determine if, as a minimum, the equipment meets the requirements of IE Bulletin 79-01B and 10CFR50.49. This determination was based on either having actual environmental qualification documenta-tion available or documentation on similar equipment available. For those instruments for which proper documentation does not currently exist, either documentation will be generated or the equipment will be replaced. If proper qualification cannot be documented or if new equipment is purchased to meet other Category 1 or 2 requirements, this equipment will be qualified in accordance with 10CFR50.49. Instrumentation whose qualification can not be documented will be reolaced by 2R6. Documentation pertaining to environmental qualification will be maintained on file.
Seismic Qualification - Currently installed instrumentation was evaluated against the seismic qualification criteria used as a basis for the plant operating license. These criteria are described in the AN0-2 FSAR, Section 3.10. The ANO-2 seismic criteria are synonymous with the requirements for Class 1 equipment as defined in IEEE Standard 344-1971. Exceptions to the standard are noted in FSAR Section 3.10. New instrumentation will be installed in accordance with the criteria specified in the FSAR.
Redundancy and Sensor Location - A response of "Yes" in the redundancy column indicates that redundant channels are available up to and including any isolation device and that the channels are both electrically independent and physically separate from each other and from non-safety equipment in 1
accordance with IEEE Standard 279-1971. This standard was used as the basis for the AN0-2 operating license and meets the intent but not all the strict requirements for physical separation of recundant channels as defined in Regulatory Guide 1.75. Where applicable, the general sensor location is listed.
Power Supply - All Category 1 instruments are supplied with power from a Class 1E power supply. The ANO-2 Class 1E power system is designed to meet the requirements of IEEE 279-1971, IEEE 308-1971, 10CFR50 including Appen-dices A and B, and Regulatory Guide 1.6.
Quality Assurance - All instrumentation was, and will continue to be purchased and installed in accordance with the provisions of the NRC approved AP&L Quality Assurance Program described in the AN0-2 FSAR, Chapter 17.
Control Room Display'and ' Recording - Continuous real-time display of at least one channel is provided in the Control Room. Recording of the instrument readout infomation is provided for at least one of the redundant channels, although this recording may be "Non-Q". Variables which input to the SPDS may be displayed and/or trended on demand. Where it has been determined that direct and imediate trend or transient information is essential for operator information or action, a continuous dedicated recorder is provided with redun-dant backup recording and trending available on SPDS and redundant dedicated indicators in the control room that can be utilized for trend information if necessary.
4

i CATEGORY 2:
e             Environmental Qualification - Same as Category 1 4
!            Seismic Qualification - No specific provision f
Redundancy - Not required 1
Power Supply - Powered by DG or UPS, both considered to be highly reliable 1            Quality Assurance       Same as Category 1 Control Room Display      "On-demand" or continuous display is provided in the control room. No direct or immediate trend or transient information was determined to be essential for operator information or action.
CATEGORY 3:
Environmental Qualification - Not required J.           Seismic Qualification - Not required i
;           . Redundancy - Not requi red                       f f            Power Supply - Powered by any available source of power
,            Quality Assurance - Same as Category 1 Coptrol Room Displa,y, - Same as Category 2' 1
1 i
4 1
                                                      .5               _

TABIE 1 AP&L PERMiB 10 101.97 PAGE     1 AND-2 VARIAIEE REINENtED PER                                             POWER             Ot RG1.97 (IEEV. 3)    CMTUORY      RANGE       REEINnWCY        SUPPLY         DISPIAY                   SPDS SOEARE          CO9fNrS TYPE "A" VARIAIEES IES Hot Img Water Tesp      1    1250 -6250 F     Yes               1E         2 Indicators                 Yes      -
Compliest see Table 2, Note 1.
(2 O winels)                                           (1 channel) 1650 -750PF      Yes               IE         CRP (SPDS)                   Yes      -
(4 Omnnels-2/hotleg) 5250 -6750F      Yes               IE         2 Indicators                 Yes      -
(4 Our.nels-                  (Each selectable to 2/het leg)                   1 of 2 hot legs) 525 -6250F       Yes               1E         1 Dual Pen Recorder          No       -
(2 O mnnels)
IES Pr-we                   1    0-3000 psia      Yes               JE         2 Indicators                 Yes      -
Ccapliest see Table 2, !!ote 2.
(2 O mnnels)                  1 Recorder Cantairment Hydroger        1    0-10% Vol        Yes               IE         2 Indicators                 Yes      -   Complies cancentration                                     (2 O mnnels)                  1 Recorder Steam Generator Level      1-    19-1/8" atxne Yes                  'E         2 Dual Indicators            Yes      2R5 Will complyr see Table 2, Note 3.
ttbe sheet to    (2 O mnnels/sG)               (19G O mnnel/ Indicator) separators                                    1 Dml Pen has (JSG O mnnel/ Pen)
Steam Generator Pressure    1    0-1200 psia      Yes               18         4 Indicators                 Yes      -   Compliest see Table 2, Note 4.
(-15-1185 poig) (2 Omnnels/SG)                 (1/Omnnel/SG)

TARIE 1 Ar%L RESFORE 'IU 101.97 PAGE    2
                                       .                                 FM)-2 VARIAILE RR330eMED PER                                        POWER                G IGl.97 (IIEV. 3)    CMTDDRY      RAIM    REDlNDANCY     CUPPIX            DISPIAY       SPDS SOEDUIE         CCD99 WIs TrPE '1B" VNtIAIEEB Fitst              1     10N to      Yes              IE           2 Irulicators 1 Gannel  -     Complies 1      to 1000 F.P.                1004 F.P.    (2 Oumnels)                  1 Recorder (Ott. 1)
Control Itod Position        3    Full In or  N/A               UPS         CRT               Yes    -     Couplies Full In or Not Full In            Not Full In                                 (SPDS)
(Cht. 3)
IICS Soltble Baron cone. 3     -
N/A              N/A          N/A               N/A    -
Complies; see Table 2, Note 5.
04iOOO PIM (Cht. 3)
IICS Cold Img Water Temp    3     1650 -7500F 4 Omnels          IE/UPS      CRT (SPDS)        Yes    -     Coupliest see Table 2, Note 6.
5dD to 700PF                                   (1/ Cold Img)
(Cat. 1) 50P to 40CPF (Ott. 3)
IG Hot        Water Temp    J     ~           -                -            -                 -      -
See previous listing on Page 1.
50P to (Cat. 1)
IU Pressure                 -     -           -                -            -                 -      -
See previous listing en Page 1.
4000 psig (for CE Plants)
(Cat. 1)

TNEE 1 Al%I, RESIUCP: 'IO 101.97 PNE       3 N2 MutIANE HB3Mansun PER                                            POWER              CR REDtNWCf       SUPPLY          DISPIAY   SPDS SCH!lDUIE          QP9fNPS Nil.97 (IEV. 3)      CNN00RY      RANGE Core Exit         .            1     ---          ---             --         ---           ---    ---     will comply; see Table 2, Note 7.
20(PF to (Cht. 3) th1-st Irwentory Bottomi       1     -            ---             ---        ---           ---    ---     Will comply; see Table 2, Note 8.
of Ibt Img to Top of Vessel (cat. 1)
Degrees of **=mling:           2     0-2000F      Yes             lE         2 Irdicators  Yes     -        Ocuplies: see Table 2, Note 9.
20dDF submoling to                                (2 O mnnels)              1 Recorder 350 F =q=rheat (Ont. 2)
                                                     -     -            -               -          -              -      -        See previous listing on Page 1.
In Pressure 4000 poig (for CE Plants)
(Qat. 1) contairusunt amp Water level 2      0-56"        N/A              lE         1 Irdicator   Yes    -        Ccuplies Itarrow Itange (sump)
(Ont. 2)                                                                                  Yes             Complies wide Itange (Plant Specific)   1    0-144"       Yes              IE         2 Irdicators          -
(Ont. 1)                        .                (2 O mnnels)               1 flecorder

TABIE 1 APTL RESPCHi:: 10 301.97 PAGE    4 AK)-2 M N PER                                                          IUCt                   CR M1.97 ( W . 3)       OrfREMtY      HMm        IEEl[1MPKN   PJpFLY              DISlYAY    SPDS SOWITNF         (INENTS Omutalsment hwe               1     0-210 pela      Yes             1E             2 Irdicators Yes    -
Complies O to Desigra Proomure               (-15-195 poig) (2 Chanrels)                    1 Remrder (Ont. 1)                            Desi M 9 psia
-5 poig to Design Pressire          (54 poig)
(Gt. 1) n=*mim Isolation              1     Ciceedhiot      Yes             IE             Li@ts        No     2R4   Will comply; see Table 2, Note 10.
Dinige Positicra                    Cicoed                                         (2/ Valve) ria==4/Iht Clamed
( S t. 1)
                                                                 --    ~-'                               -

TAhtE 1 APG RESKfEE 10 101.97 PAGE     S AND-2 MRIAIEE IWX30EMED PER                                              IDER                CR M31.97 (IELV. 3)        CM1HERY      RAICE    RFTUNPreCY     SUPPLY           DISPLAY                SPOS Scenum         crygergs TVFE "C" VRRIAEE2S Core Exit M                     -     -             -               -            -                         -     -     See previous listing on page 3.
20(P to 230d F (Cht.1)
Radioactivity Otmeentratics'     3     10-4uCi/gm N/A               OP          CRT                        No     -    Compliest see Table 2, Note 11.
or Itu11ation Invel in                to 10 Ci/gm                                 (GEles Computer)
Circulating Primary Coolant 1/2 Tech stioc Limit to 100 Times Tucs Spec Limit (Ont. 1)
Analysis of Primary Coolant      3    104uCi/m1     N/A             OP          CRT                        No     -
Complies (Gamma !gioctrum)                     to 10Ci/m1                                  (GEIDE N ter) 10uci/m1 to 10 Ci/mi or TID-14844 Sourm Term in Marit vbliane (Cat. 3)
ECS Pressure                    -     -             -               -            -                         -      -    See previous listing cs Page 1.
4000 poig (for M Plants)
(Cat. 1)
Containment Pressure            -     -             -               -            -                         -      -
See previous listing can Page 4.
-5 poig to Design Pressure (Cat. 1)                                                                                                       .

TAIEZ l APEL RESF0NSE M 101.97 PAGE    6 ANO-2 MRIAEEE IWO30EINDED PER                                            POWER              CR El.97 (IEV. 3)        CM1DG0fW       RAEE         RENNP.NLY  SUPPI,Y         DISPIAY      SPDS SOE!FUE         CarterrS Omtainment map                  -     -                -             -          -               -      -
See previous listirg on Page 3.
meer Invel Marrw Range (Simp)
(Cat. 2) wide Range (Plant Egecific)
(Ont. 1)
Omtainment Area Radiation       1          r to        Yes           IE         2 Indicators   Yes     2R4   Will maply; see Table 2, Note 12.
m nitors                              1Rp/hr 10 R                                      1 Recx)rder IR/hr to 10Mr                        C-(Ont. 3)
Effluent h dioactivity-Mcble 3        10     1/cc to N/A            DG          1 Indicator    Yes    -
Couplies; see Table 2, Note 13.
. Gas Effluent frta Omdenser             10-     /cc                               I Recorder Air Ramowel Syst Ibhatat              bened on KR-85 10M/cc to 10~        /cc (Qit. 3)
RCS Pressure                   -      -                -             -          -               -      -
See previous listirq on Page 1.
4000 poig (for CE Plants)
(Ont. 1)
Cantainment Hydrogen           -      -                -             -          -
See previous listing cm Page 1.
Concentration 0-108 Voline Capable of                                                                             ,
f1perating from -5 psig ngs to maiman Desip Pressure (Cat. 1)

                                                          ,__            . _ . ._ _          . _ _ . . _ . .                 _   .      . _ . . _    . _ _ ~ _
TAKE 1 APEL HESFmSE 10 RGl.97 PME      7 MO-2 MRIAIEE IIRIDOEBEED PER                                                              POWER             G M31.97 (IEV. 3)       CA11KORY       RAEE             RfRPRWRX                 S'JPl4X        DISITAY              SPDG SGPHER               03DENPS contairannt Pressure            -     -                     -                         -          -                       -      -
See previous listing on Page 4.
                        -5 psig to 3 Times Desip Pr-re (m t. 1)
Otmtainment Effluent            3           7 1.10 uQi/cc           N/A                       OF         Cac                    No      -          Ccuplies; see Table 2, Note 14.
Radicactivity-41oblec a -             to 1.3E'uci/cc                                              ( N Ctzpiter) fr a Identified Release               0-110% Vent 1/cc to 10-2uci/cc (mt. 2)
Effluent medicactivity-tiable 3       1.lf    1/cc          N/A                       OP         CRP                    No      -
Ocupliest see Table 2, Note 14.
from nury=                     to 1. uCi/cc                                             (GD Mi % ter) g0uCi/cc 1          to 10-2uci/cc              O-110% vent (mt. 2)                               Design Flow

TABTE 1 APEL RESPCNSE 'IO R31.97 PNE      8 AN>-2 VARIANE NKIMSEED PER                                           POWER              CR RGl.97 (NLV. 3)     CMTDORY      RAIG        RE[1NDANCY  SUPPLY          DISPLAY      SPDS 90 EIRE          CXMENIS TitPE "D" UUtIAMES IHL Systemi Flow             2    0-8000 GIH       N/A          DG          1 Irdicator     Yes    -
Ccuplies 0-110% Design Flow                (Design =
(Cat. 2)                          3100 GR4)
IHL Heat Enthanger Outlet    2    0-4000F          N/A          DG         2 Irdicators     Yes    -
Complies Tuop                                                                        (1/Qmtainment 0    0 32 -350 F                                                                  Spray Line)
(Cat. 2)
Safety Injection Tank        2    8.758-91.25%     N/A          DG         4 Irdicators     Yes    2RS (W-lator) Invol                   (Bottaa to Top)                                                        Will Comply;see Table 2, Note 15.
(1/ Tank)
Bott a to Tty (Cat. 2)
Safety Injection Tank         3    0-700 poig       N/A          DG         4 Irdicatern     Yes    -
Complies; see Table 2, Note 16.
. Pressure 0-750 poig                                                         (1/ Tank)
(Cat. 2)
Safety Injection Tank        2     Cleoed/          N/A          1E         8 Lights         No     -
Ctuplies (Accumlater) Isol. Valve          Not Clemed                               (2/ Valve)
Position Ciceed/Not Cinami (Cat. 2) 5 6

TABIE 1 APEL RESENSE '[O RG1.97 PNE                            9 ANO-2 WRIANE RB0(MGH!lD PER                                                IndER               Qt RG1.97 (REV. 3)       CATEGORY       RANGE     RE21NDANCY      SUPPLY           DISPIAY            SPDS SCM11AE          CnteeNTS Boric Acid Omrging Fim         2     0-150 GIH       N/A              DG            1 India tor          Yes 0-1101 Design Flow                   Design =132 GIN C W 11es (Cat. 2)
Flow in HPI System             2     0-875 GIM       N/A              D3 0-110% Design Flow 2 Irdicators         Yes       -
Casplies (Design =                                     (1/HPI locp)
(Cat. 2)                            320 GIN)
Flow in IPI System             2     0-0000 GIM      N/A              DG           1 Indicator          Yes       -
Complies 0-110% Design Flow                    (Design =
(Cat. 2)                             5100 GIN)
Refueling Water Storage        1     5.25-94.75%     Yes              lE           4 Indicators         Yes      -
Ccaplies Tank Imwel                           (Bottcnn to     (4 mannels)                   1 Recorder
      'Ibp to Bottom                       Tcp)
(Cat. 2)
DCP Status                     3     0-600 amps      N/A              OP          4 Meters              Yes Motor errent Ccaplies U/ Pump)          (Planned)
(Cat. 1)
Primary System Safety Relief'2       Closed /        N/A              DG          2 Indicators          Yes      -
Complies W lve Itsitions (Including           Not m w                                       (1/ Safety Valve)
    ' POWS and Cods Wlves) or Flow Throups or Pressure in
* Relief Valve Lines Cicssd/Ibt Mn==d                                                                                               *
(Cht. 2) d

TAME 1 AP.      N 10 10,1.97 PAGE     10 Aro-2 VARIAILE RIKD9BEED PER                                               TOWER              CR RGl.97 (REV. 3)     CN!15001W       RANGE       REDLNP#aCY     SLAPLY          DISPIAY   SPDS SOEIKKE         COMENTS Pressurizer Invel            1       3%-95%          Yes              IE         2 Irdicators Yes      2R6 Will comply; see Table 2, Note 17 1bp to Bottom                         (Top to Bottom) (2 curmels)                  (Redundant)
(mt. 1)
Pressurizer Heater Status     2      Electric        N/A               T1G       CRP (SPDS)    Yes     2R5  Will cxuply; see Table 2, Note 18.
Electric Oarrent                     Qarrent (Cat. 2)
Quandi Tank Level             3      5-958           N/A              DG          1 Indicator  Yes     -
C % lies 1bp to Bottom                        (Top to (Qat. 3)                           Botton)
Quench                              0-300 F O Tank M 3                      N/A              DG         1 Irdicator   Yes     2R4  Complies; see Table 2, Nota 19.
50-75d F (O t. 3)
Quench Tank Pressure         3      0-100 peig       N/A              Tfs        1 Irdicator   Yes     -    Ocuplies O to Design Pressure                Design =100 poig
; (Cat. 3)
Steam Generator Imvel        -      -                -                -          -             -       -
See previous listing on Page 1.
from Rbe theet to separators (Qat. 1)
Steam Generator Pressure     -      -                -                -          -             -       -
See previous listing on Page 1.
from At=naphoric Pressure ts 20% Above the Inwoot Safety Valve Setting (Cat. 2)

TABIE 1 AP&L hESIINSE 10 RGl.97 PAGE    I1 APO -?
MRIAIEE REKXM90ED PER                                            POER              CR RG1.97 (REV. 3)      CNITJGORY       RANGE    REDLM F W I  M LY           DISPIAY             SPOS SOIEIIJLE          COPM NPS Safety / Relief Valve          2      Closed /      N/A           DG          2 Lights /
Ibsitions or Main Steam                                                                            Yes      2R5    Will emplyt see Table 2, Note 20.
Not Closed                              Valve Flow Closed / biot Closed (Cat. 2)
Mkin Feedwater Flow            3      0-7.2 X 106   N/A            DG         1 Dual Pen Recorder O-110% Design Flow Yes      2RS    Will amply; see Table 2, Note 21 lb/hr (0-110%                           (1 I%n/ff Pump)
(Cat. 3)                             Design)
Auxiliary I W ter Flow         1      0-750 GIN     Yes            3E        4 Indicators           Yes      -      Complies 0-1101 Design Flow                     (Design =     (4 Ourmele)              (1/mannel)
(Ot. 2)                              575 GIM)      (1/ Leg) condensate Storage Tank        3      0-1004        N/A           DG         1 Dual Pen Recorder
-   Imvel No      -       Caplies; see Table 2, Note 22 f1 Pen / Tank)
Plant 15ecific (O t. 1)
    & ntainment Spray Flow         2      0-3500 GIN    N/A           DC         2 Irdicators           Yes    -        Caplies 0-1104 Design Flow                    (Design =                              (1/@ntainment (Cat. 2)                              2200 GIM)                              Spray Line)
Heat asumoval by the Ocmtain- 2       On-off        N/A           lE         Lights unnt Fan raat Removal System No     -        Coupliest see Table 2, Note 23.
(1/ Fan Breaker)
* Plant !Decific (Cat. 2)
* TABIE 1 AP&L PISKNSE 10 101.97 PAGE   12 APD-2 MRIAILE RBOONDEED PER                                 POWER              CR RG1.97 (REV. 3)   CMEGORY       RANGE   REDMWEY  SUPPLY          DISlu Y   SPDS SOEHRE          00peerrS 0
Contairment At==there      3     0 -300 F    N/A         OP/UPS     CRP (SPDS)  Yes     -
Compliest see Table 2, Note 24 Temp 40-40dDF (Ont. 2) contairment Sump hter      -     -           -                      -           -      -     See Table 2, Note 25.
Temp 50-25cPF (Ont. 2)
Makety Flow-In             2     0-150 GIN   N/A         DG         1 Indicator Yes    -
Ccaplies 0-110% Design Flow               Design =
(Cat. 2)                        132 GiH Imedown Fleneout           2    0-150 GIM   N/A          DG         1 Indicator Yes    -     Complies 0-110% Design Flow               (Design =
(Ont. 2)                        132 GlH)
Volums control Tank       2     'Ibp to     N/A         IX3         1 Indicator Yes    -     Complies (VCP) Imvel                     Bottomi Top to Bottcus (Qat. 2)
Component Cooling e ter   -     -           -           -          -            -
                                                                                         -     See Table 2, Note 26.
Temp to ESP Systemt 40-200 F (Ont. 2) l

                                                                                                                                       '! AIRE 1 AP&I. rpm 0NSE '!D 101.97 PAGE                             13 ANr>-2 VNtIAIEE ItBOOMBND PER                                             !Y1HEk                CR ngl.97 (HEV. 3)    CNITIGORY       RAEE   RFILMMiCY      !ARVLY            DISPIAY         SPDS SO1EttRE         CONrNN Cbsponent cooling Mater          2     0-200 peig   N/A              1E            2 Indicators      No     -
Couplieor see Table 2, Note 27.
Flow to ESF Systeel                   Closed /                                    2 Lights / Valve 0-110% Design Flow                    Not Closed (Ont. 2)
Hipt Imvel hidioactive          3      13.3-86.7%   N/A             DG            4 Indicators       No     -
Ocuplies Liquid 'fhnk Invel                    ('Ibp to                                    (1/ Tank)
Top to Bottom                          Botton)                                                                                                                             '
(Cht. 3)
Radioactive ens Holdup           ..    ---          ---              ---          -                  ---    -      See Table 2, Note 28
                                                            'thnk Pressure 0-150% Design Pressure (Ont. 3)
Buergency Ventilation           2      Closed /     N/A             DG            2 Lights           No     -      Couplies Desper Pcottien                        Not Closed                                  (1/Both CR Closedhtot Closed                                                                  Isol. Redundant (Cat. 2)                                                                        Diuper)
Status of Stanrtyy Power and    2.~'
Voltages;    N/A             Various      CRT                 Yes    2RS    Will comply; see Table 2, Note 29.
Other Ehergy Sources Impor-             k eaker                                     (SPDS) tant to Safety (Electric,              Positions:
Hydraulic, Phetuatic)                  etc.
voltages, currents, pressurest Plant Specific (cit. 2)

TAPlE 1 AP&L RESF0l@E TO R31.97 PNE      14 AIO -2 NMt1AIER RB000EREED PER                                               IOER                 CR RG1.97 (IEV. 3)       O MEDRY       RMEE '   RFDNmMCY  SUPPLY          DISPIAY       SPDS SO1EEUIE         CO9fNrS TYPE "If' %NtDst2S 1
Contairment Area Radiation                -    -            -            -           -               -      -
See previous listing on Page 6.
   -Hi@ Range 7
IR/hr to 10 W (Cat. 1) 2 Radiation Pure Itate                      3 103          N/A          DG          24 Indicators   Yes    -
Compliest eae Table 2, Note 30.
(inside b1dge or areas                        10 R/hrr to                           1 Recorder toure - is required                            1      r to to service equigment impor-                    1      ;
to safet                       I        to g
10 R/hr to 10                                  10 (Ont. 3)
Mcble Geses & Vent Float Rate
  --Omtairment or purge                    -    -            -            -           --               -      -
See previous listing on Page 7.
ofjf uutt 10 tCi/cc to 105uci/cc O-1104 Verit Design Flcat (omt. 2)
                                              ~
  -Reactor Sileid Bldg                    ~     -            -            -           -                -      -
Not in design.
Annulus (if in design)

TAf1LE 1 AP&L RIN0tCE 10 M1.97 PNE     15 APD-2 VARIAIEE RBOOMBEED PER                                                    POWER              CR IIGl.97 (IIEV. 3)        CA11!OOl&      RAME       REI1M MNCY  SUPPLY          DISPLAY       SPDS SOsnr2          COPMNIS
                     -Auxiliary Bldg (including -                  -               -            -          -                 -      -
see previous listing on Page 7.
any b1dg containing primary system ga        , e.g.4, waste gas d p y tank) 10 uci/cc to 10'uci/cc O.-1104 Vet Desip Flow (O t. 2)
                     -condenser              Air 91         3      1.1EIugi/cc     N/A          OP         CRP               No     -
Coupliest see Table 2, Note 14.
Syst       Euhaust 10 uCi/cc             to 1.3E'uCi/cx:                          (CEIDE Computer) to 1        1/cc                         O-110% Vent 0-110% Vent Design Flow                  Design Flow (m t. 2)
                     % Plant Vent Dis-                      3      1.1E-7u i/cc    N/A          OP         CRT               No    -
C g lies; see Table 2, Note 14.
charging Any of the                      to 1.3E uCi/cc                           (GE3DE Ctaputer)
Above Relaa=== (if                        0-110% Vent cantairument purge is                    Desi p Flow inchaled)
IONi/cc 3
to IO uci/cc O-110% Vent Desi p Flow (Ont. 2)
                     -Vet frtan Steam Generator 2                  .066uci/        N/A          lE         2 Irdicators      Yes   -
O g liest see Table 2, Note 31.
Safety Relief Valves or                  to 6.55 uCi/cx:
At= nag *istic Dump Valves                (Xe-133 D.E.)
I 10~3 tci/cc to 10 uci/cc ( & t. 2)

TARE 1 AP&L RESI0 LEE 'IU 101.97 PAGE     16 AND-2 VARIAIE2 RB000eOED PER                                          MJWER             CR RGl.97 (REV. 3)       CMTEDRY      RANGE     REIINDANCY  SINTLY        DISPIAY             SPDS SOIEDUM          COGENrs
    -All other identified          -      -
rol       points No other identified release points, 1       1/cc to 1 ci/cc (Cat. 2)
Particulates and Ihlegens
    -All identified plant          3      10-3 1/cc     N/A           OP        CRT                   No      -    Compliest see Table 2, Note 32.
     ' release points (awy                to 10 uCi/cc                          (GEIDE Computer) steam generator safety            0-110% Vent relief valves or atmo-            Design Flow e5heric steam dLap valves and condenser air removal system enhaust). Sampling
. with on-site analysis I
      <=g=hilityr for particulates and halogans 10-3tci/cc to 102uci/cc 0-110% Vent Design Flow (Cat. 3)
Airborne Radichalogans and     3     10-9uC         N/A          N/A       N/A                    N/A    -
Complies Particulates (Portable               to 10 g/cx:
uCi/cc Sampling with OrHilte is Capability) 10-     i/cc to 10-     i/cc                                                                                       *                                               *
(Cat. 3) 9

A TM'.E 1 APLL ItESR]p6E M PGl.97 PAGE    17          '
Ah2 M N MR                                                                                 fYWPR             CR
_        Mn.M l WV. 3)           (MEK3tY              RAltF    ItED.BerAfCr            ST5tLY         DISPIAY           SPDS SOEUXE          tWfr5_
3 DJ        avet lawi      M iations 3         10C Itptr         N/A                       N/A       N/A                  N/A    -
Otglies; r% Table ?, Note 33.
10~                  .sr,                   to ItY.'Tn/hr
                    /hr to 1.Tg sm:2-At to
         . Phgtens:
Itr WI4 het,r m shdi-y:
                                                      ,10.~ AArs/hr ations and 14mHhery PhcMr2 .                 to 50 ItME/hr (strtable Instrumentation) i Fl%tand P>virens Ilhdio-            3        Isotopic          N/A                      N/A        N/A                  N/A   -
Omplies see Table 2, Nota 34    .
actadty (ptstable temv,                      Analysis s   s h ! a? (Isotopic                                                                                                                                                '
Jhnipio) (Ont. 3) p-         kNiDirection                        3        0-360D + %! Fuli N/A                       OF         1 e xrder            No    -
O g ifes
   ,       0-3EdP(+ 5* ar - racy                        Scale;"3tartino                                       CRT (ceRS Cbsputer) with a 3er1.ctim of IcP). ,                  speed ~ .75 mph;
'I         D:arting myosd < 1 agti A--ing               dasc{rtg ratio -
ratio >0.4 distance constant i ;'                                                    .6; distance less tEnn or egami to 2 arters.           ' ctristrat - I m.
(Cat. 3)                                                                                                                                                              ,
wind speed                          3        0-100 mph         N/A                      OP         1 Itecorder          No    -
Couplies 0-50 $ (+ .5 ages accuracy                   a m wacy                                              CRT (CE396 Computer) for wind siiser3s < 5 usti,           -
greater of + lt lot for opmods > 5 p ,                       or+0.15uS:
with a startirug threshold                   starting threshold -
           < 1 sph and a distance                       0.6 mph distance canistant not to ==n==9 2                    anstant - 5 ft.
notars (m t. 3)

                                          . - _ _ ~-         . -.              _        _- _.           __. _ _ .   . _ - _   .      _ -__ -
l                                                                                TABU 1 1
APEL RESIOEE 10 RG1.07 l
PAm: 18 ANC)-2 imRIA52 Igapeamsun R3t                                              P0MER                    CR M31.97 (155f. 3)     CAT 3KORY            RABE    RE!DDOMCY  SUITLY                DISPEAY       SPOS SO EIIXE             COGE3r!S Batisation of At=n=re ieric
                                            -30      to 5%
Stability                       3                        N/A         OP            1 Dual Pen Recorder  No         -      Coglies; see Table 2, Note 35.
M on iAertial Temp                      M Difference                               CRT (GE356 %4er)
Difference fecun Primary                0-4P- Wind System -90F to la F and                 Direction Sicpia
    +0.3"F =<vuracy per 164' T=*arvels or analawr== range for alternative etability entientes.
(cat. 3)
Primary M=n and !kup           3        -
N/A         N/A           N/A                  N/A        -      Complieer ese Table 2, Note 36, (e ah ameple) (Ont. 3)
    -4 rome Activity I uCi/ml to 10 Ci/mi
    -emumme W (isotgic analysia)
    -toren ccuimntraticut 0-4000 PfM
    --Onloride content 0-20 PRt
    --Manolved hydrogen or Total Gee 0-2000 cc/kg
    --Diamolved Onygen 0-20 PIM y 1-13

    . - _ _ __.-                  ._ . _ . _ .         _         . _    __    _  _=        .                 _ . - . _ -_ _ _ _ _           _ . - -   .- - . - -                      -
TABIE 1 APEL RESIONSE '!D 101.97 PAGE          10 AIO-2 UWtIAILE RETD 995CED PER                                            POER                CR RG1.97 (IEV. 3)      CA'!BOORY       RANGE    RE21NDANCY    SUPPLY           DISPLAY                      SPOS SOEDUIJ:                  C G 9EStrS Contaitument Air Grab Sample 3             -
N/A             N/A          N/A                             N/A     -         Compliest see Table 2, Note 36 (Ont. 3)
::,ay. Content 0-10% Vol.
                    -Oxygen Omtent 0-30% Nbl.
                    --Gammun apoetrums (laotopic Analysis) <
4 6
                                                             .c w
w e

TABLE 2 AP&L RESPONSE TO REGULATORY GUIDE 1.97 ANO-2 NOTE 1: The range recommended by Reg. Guide 1.97 for RCS Hot Leg Water                                              l Temperature is 50* to 700 F. The existing range available in the control room for continuous display from Category 1 instrumentation is 125* to 675 F. The lower range of 125*F is sufficient for operator information since the cooldown of the RCS while using the steam generators is limited to approximately 300 F. At that point, further cooldown to below 200 F is accomplished by utilizing the shutdown cooling heat exchangers which have inlet and outlet tem-perature instrumentation designed specifically for monitoring temperatures below 300 F. Therefore, the lower range of 125 F for                                           i RCS Hot Leg Water Temperature meots the intent of Reg. Guide 1.97.
                                                                                                                    ]
The upper limit of 675 F is sufficient for operator information since the RCS saturation temperature at the safety valve setpoint is less than 670 F. If temperatures in the RCS Hot Leg exceed 670 F, the RCS has reached a superheat or overpressure condition such that the Category 1 Core Exit Temperature instrumentation (0*to 2300 F) should be utilized to monitor core cooling status, not the hot leg temperature instrumentation.                                        Also, as a backup, ANO-2 has four fully qualified hot leg RTD's which measure a range of 165 to 750 F that can be read out in the control room by use of computer points.
Therefore, the upper range of 675 F (continuous display) and 750 F (computer display) for RCS Hot Leg Water Temperature meets the intent of Reg. Guide 1.97.                                                                                  ,
i l
NOTE 2: The range recommended by Reg. Guide 1.97 for RCS pressure is 0 to                                         -
4000 psig. The existing range available in the control room is 0 to 3000 psig based on operator infornation needs to monitor normal and accident conditions. The value of 3000 psig is in excess of 120% of                                         1 the RCS safety valve setting and the RCS design pressure. The apparent basis for the Reg. Guide 1.97 range of 0 to 4000 psig is for monitoring ATWS scenarios that are postulated based on highly improbable failures that could result in pressures greater than 3000 psig. The operator information needs for accident situations including ATWS do not necessitate monitoring pressures greater than 2500 psig. Additionally, the probability of experiencing,an ATWS transient that results in pressures greater than 3000 psig is~so low that new instrumentation or modification of existing instrumentation solely for post-transient diagnosis is r.ot appropriate or justified.
Therefore, no modifications to the existing RCS pressure instrumen-tation are necessary to comply with the intent of Reg. Guide 1.97.'
1

i i
i i~
NOTE 3:                In addition to the 4 channel narrow range steam generator level instrumentation, ANO-2 currently has 1 non qualified wide range
,                              level loop per steam generator. These loops will be replaced to
;                             provide 2 fully qualified wide range instrument loops per steam                    i generator with a range of.19 1/8" above the tube sheet to separators, qualified indications (1/ channel /SG), one channel from each SG recorded on a non qualified dual recorder and all input to the SPDS computers. The lower range of 19 1/8" above the tube sheet              l
                             . meets the intent of Reg. Guide 1.97-since this level essentially j                             equates to zero and operator action would not be affected by monitoring levels lower than the 19 1/8" level.
NOTE 4:               ANO-2 has control room indication of main steam pressure at the turbine as well as at the steam generators. The steam generator
 ,                            outlet pressures are measured over the range from 0-1200 psia
( 1185 psig). The NRC recommendation is for the range to be 20% above the lowest safety valve setting. Since the lowest' safety valve.is 1078 psig, the range would have to be in the order of 1295 psig to meet the NRC's recommendation. The following discussion is provided to justify that the existing range of 0-1200 psia ( 1185 psig) is sufficient.
The accident analyses results presented in Chapter.15.of the ANO-2 FSAR. indicate that for both the loss of external load transient and, loss of all non-emergency AC power transient, the maximum steam-pressure is 1135 psig (See FSAR Table 15.1.7-2 and Fig 15.1.9-3).
 ;                            The main steam lines are provided with safety relief valves, atmospheric dump valves and condenser dump valves to prevent over-
   .                          pressurization of the' lines as well as pressure control. ANO-2 has
:                            ~30% excess steam relief capacity when the plant is operating at 100% power and all main steam safety valves are operable. ANO-2 also has a technical specification which limits the maximum allow-1                             able plant power and its steam flow in the event not-all safety-l                             valves are operable in order to maintain excess relief capacity.
Therefore, based on the facts that the highest safety valve setting is 1132 psig, the steam relief capacity is ~30% above.the expected
,                             steam flow rate, excess relief capacity is maintained when safety valves are inoperable, and the FSAR analysis indicates a maximum
^;                            steam ' pressure of 1135 psig, the existing range of -15 '1185 psig (0-1200 psia) is sufficient to meet'the intent of R.G. 1.97.
NOTE 5:               During normal operation-boron concentration is measured by a boronometer in the letdown line .or through radiochemistry analysis.
i                             Followingf a ' serious accident, however, the letdown' line will b'e
,                             isolated (either procedurally to conserve reactor coolant and limit exposure to personnel .in the auxiliary. building or via 'a containment.
.                             isolation ~ signal) and.the radiochemistry-lab may;become finaccessible
                             - due to radiation levels..
f 2
p
        - - - - - ~e,          -      ..-w,        - -* +e--m.-          w     v v     v       y  4

Therefore, in accordance with NUREG-0737, Item II.B.3, t'e   h Post Accident Sampling System (PASS) for ANO-2 was designed to provide boron concentration measurement capability. The range and design criteria for the PASS is consistent with guidance provided for Item II.B.3 which has been addressed by AP&L in previous submittals and discussions with the NRC.
NOTE 6: The range recommended by Reg. Guide 1.97 for RCS Cold Leg Water Temperature is 50* to 700*F. The existing range available in the control room for display is 165 to 750 F.       The primary basis for monitoring cold leg temperature is as a backup to steam generator pressure which is utilized to assess the performance of RCS heat removal. As a result, the RCS Cold Leg Water Temperature is a Category 3 backup variable. The actual range of value to the operator is approximately 200 to 600 F based on steam generator saturation temperatures at the lower and higher pressure limits of the secondary system. Measurement of temperatures less than 200 F or higher than 600 F in the RCS cold leg does not provide dependable information about the core conditions (i.e., RCS heat removal) such that the Category 1 Core Exit Temperature instrumentation (0 to 2300 F) should be utilized. Since the range of available instrumen-tation more than satisfies the intent of Reg. Guide 1.97, no modifi-cations to the cold leg temperature instrumentation are necesary to comply with the intent of Reg. Guide 1.97.
NOTE 7: ANO-2 will meet the requirements for measurement of Core Exit Temperature and Coolant Inventory as detailed in our response (2CAN048306) to the Inadequate Core Cooling Order for modification of Licenses. In sunmary, ANO-2 presently has 44 radially distrib-uted core exit thermocouples-(22 input to the plant computer and 22 input to the SPDS computer) with a range of 0-2300 F, and qualified up to the penetrations. The proposed modifications to the CET Monitoring System include:
(A) Transfer of the 22 inputs from the plant computer to the SPDS (primary display);
(B) Upgrading the qualification of the CET's connectors and cables to class 1E up to and including the isolation devices; (C) Addition of CET signal processing equipment and isolators in -
the loop between sensors (IE) and SPDS (non-1E), and (D) Addition of a qualified backup display in the control room for at least 16 of the CET's.
NOTE 8: Coolant Inventory will be monitored using a RADCAL Gamma thermometer. Two sensors will be axially located to provide optimum  l resolution in the areas of most concern. These will be 2 Class-1E        i channels up to and including the isolation devices.       Both channels are input to a common display, the SPDS computers. Recording will be performed using the trending capabilities'of the SPDS computers.
3' I
a

1 NOTE 9:        During situations that may result in superheated conditions in the RCS, core exit thermocouples and hot leg RTD's will be monitored-
,                               against RCS pressure to determine the degree of superheat or                      :
subcooling. Although not directly input to SPDS, the SPDS computers
;                               will plot on the CRT's core exit temperature versus pressure on a grid with the~ saturation curve so that the operator can tell at a                !
l'                              glance the thermodynamic status of the reactor coolant. Therefore, a range of 0 F-200 F -subcooled on .the subcooled margin monitor is' adequate to meet the intent of Reg. Guide 1.97.
NOTE 10:       Containment isolation valves listed in Table 6.2-26 of ANO-2's FSAR were evaluated. This evaluation excluded check valves and
,                               locked closed manual valves which are part of a passive boundary.
:                              Redundancy is satisfied by GDC 55, 56, or 57. With the exception of seven (7), all position switches are class 1E with "open-closed" indicating lights in the control room. These seven (7) switches will be upgraded to comply with Reg. Guide 1.97.
i                NOTE 11:       During normal plant operations RCS radiation levels are measured by a radiation monitor in the letdown line and through radiochemistry i-analysis. These two techniques are used to quantify the activity in the primary coolant and to determine Technical Specification compli-l                               ance.      Following a serious accident, however, the letdown line will l                               be isolated (either procedurally to conserve reactor coolant, and
:                               limit exposure to personnel in the auxiliary building or via a
                               - containment isolation signal) and the radiochemistry lab may become inaccessible due'to radiation-levels. Therefore, these normal 1                              methods are not suitable for post accident analysis. Section II.B.3' of NUREG-0737' requires that the capability exist at each nuclear
!                               plant to sample the RCS to assess the magnitude of fuel failures during post-accident _ conditions. As'such, this method should be the primary means of determining clad breach.
1 The Post Accident Sampling System for ANO-2 was designed to comply with the requirements of NUREG 0737' item II.B.3. These requirements l                               did not require that the system be safety grade. Therefore, PASS i                               does not comply with the strict requirements specified for Category-3                               1 equipment. Since PASS is designed.in accordance with the requirements of NUREG-0737, Item II.B.3,'and those requirements are-1-                              consistent with-the criteria of Reg. Guide.1.97 Category 3, the i
PASS variables have been specified as Category '3 by AP&L.       The range covered by PASS is consistent.with guidance provided for Item II.B.3 of NUREG 0737.
;                NOTE 12:       The existing'High Range Radiat. ion Mo'nitoring System' meets all
;                               requirements'of a Category 1 instrument loop, with the exception of having'at'least 1 channel recorded. . Difficulties were encountered with the acquisition of a qualified isolator / amplifier for the signal range. Testing has recently been completed ~successfully.
The isolator / amplifier, recorder, and input to SPDS.-will be installed by 2R4.'
                                                                         ~
J 4 -
4                                                                      4 9 ,. _ . . . e -.g -     _
9, g.,  y+        y   ,p. --
                                                                 ,-pi9 ,
n     4e            _y p

i NOTE 13: AH0-2 currently has a radiation monitor that will meet the specified concentration range if the detector response is attributed to Kr-85, as allowed for in Footnote 9 of Reg. Guide 1.97.
Footnote 9 also specifies that the monitor response (output in uci/cc) should not vary more than a factor of bio as the isotopic mixture of the measured gas varies from typical fresh to 10-day-old fission gas mixtures. The stated purpose of detecting steam generator tube rupture is adequately fulfilled by periodically observing the indicated gross activity in the condenser exhaust and watching for a step change. The baseline reading and the magnitude of the step change are not critical so long as the monitor has sufficient dynamic range. For this reason the isotopic mixture accuracy specification is not necessary. Since the average gamma energy of fission gases decreases by nearly a factor of two in ten days, it is unlikely that the monitor resporse would vary by less than a factor of two. However, the AN0-2 monitor meets the intent of Reg. Guide 1.97.
NOTE 14: The Gaseous Effluent Radiation Monitoring System (GERits) for AN0-2 was designed to comply with the requirements of NUREG-0737, Item II.F.1. These requirements did not include providing a " highly reliable" power supply. Therefore, GERMS does not comply with the strict requirements specified for Category 2 variables of Reg. Guide 1.97. Since GERMS is designed in accordance with the requirements of NUREG-0737, Item II.F.1, and those requirements are consistent with the criteria of Reg. Guide 1.97 Category 3, the GERf1S variables have been specified as Category 3 by AP&L. The range covered by GERMS is consistent with Reg. Guide 1.97 recommendations.
NOTE 15: ANO-2 presently has one wide range and two narrow range level measuring loops per tank. The wide range instrument loops will be upgraded to meet Category 2 requirements.
NOTE 16: Safety Injection Tank pressure is a key variable for pre-accident status to assure that this passive safety system is prepared to serve its safety function as dictated by the AN0-2 Technical Speci-fications. This pressure indication provides no essential informa-tion for operator action durina or following an accident. The key variable necessary to determine whether the Safety Injection Tanks have fulfilled their safety function is Safety Injection Tank level.
Therefore, Safety Injection Tank pressure is a backup type variable and has been classified as a Category 3 instrument accordingly.
Furthermore, since the Safety Injection Tank pressure is restricted by Technical Specifications to less than 624 psig, the existing range of 0-700 psig is more than' sufficient for this indication.
5

NOTE 17:   ANO-2 currently has 2 class IE channels of pressurizer level with indication in the control room; however, this is not a temperature compensated sevel. An existing pressurizer temperature RTO will be replaced with a qualified dual element RTD. Each element, after isolation, will feed the individual level loops. The level will then be compensated before going to the control room indication.
NOTE 18:   The pressurizer heater banks do not currently have electric current indication in the control room. Transducers will be added to the proportional heater circuits and input to SPOS. This will allow "on-demand" indication of pressurizer heater current.
NOTE 19:   Quench tank level and pressure are available for monitoring quench tank performance. The maxfmum expected quench tank temperature during desigg basis events is 280 F. As a result, the existing range of 00 to 300 F is in excess of that required fgr accidgnt monitoring.
Therefore, the existing temperature range of 0 to 300 F is adequate to meet the intent of Reg. Guide 1.97.
NOTE 20:   Presently ANO-2 does not have a Safety Relief Valve position indi-cation (SRVPI) system. Main steam flow is being monitored at the outlet of each steam generator. A new SRVPI system will be provided in compliance with R.G.1.97 to monitor valve open and closed posi-tions.
NOTE 21:   ANO-2 currently has m0'in feedwater flow transmitters that indicate
 ;            a range of 0-6.5 x 10 lb./hr which is equal to 0-100% of design flow. The range will be modified to provide 0-110% of design flow or 0-7.2 x 106 lb./hr.
NOTE 22:   The condensate storage tank level indication has been. specified as Category 3 in accordance with Reg. Guide 1.97 since it is not the essertial source of auxiliary feedwater. The essential source is the service water system which is considered an " infinite" source of feedwater. As a result, level indication for the service water system is not provided since indication of the quantity of service water available (from the Dardanelle Reservoir and the Emergency Cooling Pond) is not dependent on level and is essentially infinite.
NOTE 23:   ANO-2 currently has a Class IE indication of the containment cooling fan motor breaker status. The key variable for monitoring contain-ment cooler performance is containment pressure instrumentation
,             which is a Category 1 vaMable. Utilizing containment pressure 6
t

instrumentation and cooling fan motor breaker status, the operator can determine the performance of the safety related containment cooling system. Additionally, as a backup variable, a local flow switch is provided that includes an annunciator in the control room which alarms when service water flow thru the cooler is low. Therefore, the existing instrumentation satisfies the intent of Reg. Guide 1.97 with no modifications necessary.
NOTE 24: Containment atmospheric temperature is not a key variable for accident monitoring. The key variable for containment monitoring is containment pressure which is measured by Category 1 instrumen-tation. Containment atmospheric temperature is a backup variable for containment accident monitoring and as sgch is mgasured by Category 3 instrumentation with a range of 0 to 300 F. This range is justified based on ANO-2 safety analysis which demonstrates that 0
the worst case peak containment tegperaturg would be 288.5 F.
Therefore, the existing range of 0 to 300 F is in excess of that required for accident monitoring. Since the key variable for containment accident monitoring (i.e., containment pressure) is currently Category 1, the backup variable of containment temperature for ANO-2 is appropriately listed as Category 3 and meets the intent of Reg. Guide 1.97.
NOTE 25: AN0-2 FSAR accident analysis assumes saturated conditions for sump water during sump recirculation. With this conservative assumption, adequate NPSH exists for containment spray and safety injection pumps at all feasible sump water temperatures. Therefore, there is no need to monitor sump temperature to verify adequate NPSH for ECCS pumps or for any other accident monitoring requirements.
NOTE 26: The AN0-2 system for cooling the ESF components is the Service Water System. The inlet temperature of the servige water by design is based on a maximum temperature of 129.5 F from the .
emergency cooling pond, fhe average temperature of the pond (June through September) is 85 F; furthermore, there is no control over the temperature of the service water. Therefore, there is no need to indicate the service water temperature in the control room since, by design, no useful information would be provided to the operator by such instrumentation.
NOTE 27: The ANO-2 system for cooling the ESF components is the Service Water System. The existing instrumentation for monitoring service water to the ESF components includes the following:
: 1) Service water system supply pressure with a range of 0-200 psig. This instrumentation confirms service water pump operation as well as system flow to ESF components and is Category 2. The curve depicting the relationship between pressure and flow will be available to the operator for determining total service water flow during accident conditions.                                                      ,
l
: 2) Service water system valve position indication in the control      i room and specific line-up procedures to assure ESF cooling during all modes of plant operation. The valve position indication is Category 2.
7
: 3) ESF equipment cooling unit differential pressure alarms in the control room. This instrumentation is installed on ESF pump coolers to alert the operator of loss of service water to specific components.
: 4) ESF heat exchanger local flow indicating switches on select components (E.g., containment cooling units and shutdown cooling heat exchanger) with alarms on low flow indication in the control room.
NOTE 28: Indication of radioactive gas holdup tank pressure is not a necessary control room variable for post accident monitoring.      In the event of an accident which results in significant failed fuel or significant radioactive gas release, the manual transfer of
,           radioactive gases to the radioactive gas holdup tanks would not be attempted since the containment building would be utilized as the holdup tank. There are no automatic transfer operations involving the radioactive gas holdup tanks. Therefore, the monitoring in the control room of the radioactive gas holdup tanks during post accident conditions is not necessary since these i
tanks are not utilized for accident mitigation.
NOTE 29: Ap&L is in the process of defining the necessary parameters needed to assess the status of standby power. These required buss voltages, breaker status information, etc. will be added as inputs to the 4           SPDS computers. A specific graphic display for the SPDS is being developed to give the operator the' status of standby power at a glance.
NOTE 30: ANO-2 currently has an Area Radiation Monigoring Systgm consisting of 24 Area Monitors 4 with a with a range of 10~4 R/hr to 10{ange      of 10 ranges R/hr. These   R/hr toare 10based R/hr and on 20 background reading in the areas in which they are located. Should personnel entry be required in areas where these monitors have gone off scale or indicate a high radiation area,a health physics escort would accompany personnel into these areas using portable instru-levels. The high range for portable mentation    to assess instrumentation         radiatiog at AN0 is 10 R /hr. We do not anticipate, even under emergency conditions, sending personnel into radiation fields of this magnitude. We believe that this meets the intent of
-           Regulatory Guide 1.97.
NOTE 31: As detailed in Note 17, a system is being considered for safety relief valve position indication. The range of the existing radiation monitor is insufficient to cover the specified range as Kr-85; however, when a calculated method is applied as suggested in footnote 13 ~of RG 1.97 (Rev. 3), the Xe-133 dose equivalent concentration of fission gases from 1% failed fuel which can be measured by the monitor does meet the RG 1.97 recommendation for minimum sensitivity.11he emergency response of the current monitor (Eberline RMS-II/DAl-6) has not been tested above 1.25 MEV. It is, however, specified to be flat within + 15% from 40 KEV to 1.25 MEV.
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NOTE 32: Eacp Super Particulate Iodine Noble Gas (SPING) monitor which inputs to the Gaseous Effluent Radiation Monitoring System has the capability to measure halogen and particulate acitivity as it is accumulated on a sample media. The SPING microcomputer then cal-culates the gross radiohalogen and particulate sample concentration based on the rate of increase of activity on the filter media. If necessary, to further define the analysis or to extend the range, an isotopic analysis of the filter media can be performed by plant radiochemistry personnel . This technique provides a range at least equivalent to that which is recommended by the Regulatory Guide.
NOTE 33: Exigting portable instrumentation can detect gamga dose rates from 10 R/hr to 103R/hr and beta dose rates from 10 Rad /hr to 50 Rad /hr.
In the plant we do not anticipate encountering radiation fields greater than those which can be measured by our current equipment except under severe accident conditions. Even under accident conditigns we do not anticipate sending individuals into greater than 10 R/hr fields. Therefore, we meet the intent of Regulatory Guide 1.97 with our current equipment.
NOTE 34: Gamma spectroscopy can be performed using equipment in the HP department and the radiochemistry department at ANO, and in the Technical Analysis Laboratory in Little Rock. In addition, we have an ND-60 spectrometer in the AN0 Emergency Offsite Facility which can be used for less defined analysis. It is not appropriate that this instrumentation be portable due to rough handling it would encounter in the field and the limited amount of time field teams have to assess the release. Therefore, we comply with the intent of RG 1.97.
NOTE 35: Atmospheric stability at ANO is derived from the temperature differential indicated between 34 and 180 feet. The -3 to 5 C temperature range covers the seven Pasquill stability classes vs Delta-T as' derived from Regulatory Guide 1.23 and specified in the AN0-2 FSAR. Expansion of the range would provide no additional useful information. In addition to temperature differential, atmospheric stability can also be calculated for all seven classes using wind direction sigma. Therefore, we meet the intent of Regulatory Guide 1.97.
NOTE 36: Post accident sampling of the RCS and the containment air will be accomplished utilizing the Post Accident Sampling System (PASS).
The PASS was installed to meet the requirements of NUREG-0737 item II.B.3. The range and accuracy capability of.the PASS is being resolved at this time through further acceptance testing of the Orion equipment. AP&L is in contact with the NRC Division of Licensing to assure compliance with item II.B.3. Based on the fact that we are in compliance with item II.B.3 of NUREG-0737, we meet the intent of Regulatory Guide 1s97.
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