ML20116B366

Conformance to Reg Guide 1.97,Arkansas Nuclear One,Unit 2

ML20116B366
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/28/1985
From:	Stoffel J EG&G, INC.
To:	NRC
Shared Package
ML20116B369	List: ML20116B366
References
CON-FIN-A-6483, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-2.B.3, TASK-2.F.2, TASK-TM GL-82-33, NUDOCS 8504250265
Download: ML20116B366 (19)

Text

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CONFORMANCE TO REGULATORY GUIDE 1.97 ARKANSAS NUCLEAR ONE, UNIT NO. 2 J. W. Stoffe1 Published February 1985 EG&G Idaho, Inc.

Idaho Falls Idaho 83415 l

l Prepared for the U.S. Nuclear Regulatory Comission

! Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761001570 FIN No. A6483 l

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i ABSTRACT This EG&G Idaho, Inc., report provides a review of the Arkansas Nuclear One, Unit No. 2, submittal for Regulatory Guide 1.97 and identifies areas of nonconformance to the guide. Any exceptions to the guidelines are evaluated and those areas where sufficient basis for acceptability is not pro-vided are identified.

FOREWORD 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 Sys-tems Integration by EG&G Idaho, Inc., NRC Licensing Support Section.

The U.S. Nuclear Regulatory Comission funded the work under authoriza-tion 20-19-10-11-3.

i Docket No. 50-368 TAC No. 51070 11

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CONTENTS ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. REVIEW REQUIREMENTS ........................ 2

3. EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.1 Adherence to Regulatory Guide 1.97 .............. 4 3.2 Type A Variables ....................... 4 3.3 Exceptions to Regulatory Guide 1.97 . . . . . . . . . . . . . . 5

4. CONCLUSIONS ............................ 15

5. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 111

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CONFORMANCE TO REGULATORY GUIDE 1.97 ARKANSAS NUCLEAR ONE. UNIT NO. 2

1. INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut Director of the Division of Licensing, Nuclear Reactor Regulation to all licensees of operating reactors, applicants for operating licenses and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2),

relating to the requirements for emergency response capability. These requirements have been published as Supplement No. I to NUREG-0737, "TMI ActionPlanRequirements"(Reference 3).

i Arkansas Power and Light Company, the licensee for Arkansas Nuclear One, provided a response on April 13, 1984 (Reference 4) containing the information required by Section 6.2 of the generic letter.

This report provides an evaluation of that submittal.

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2. 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 meets the guidance of 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.

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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 1

Furthermore, the submittal should identify deviations from the guidance in the regulatory guide and provide supporting justification or alternatives.

Subsequent to the issuance of the generic letter, the NRC held regional meetings in February ard March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on this matter. At these meetings, it was noted that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97. Furthermore, where licensees or applicants explicitly state that instrument systems conform to the provisions 2

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O of the guide it was noted that no further staff review would be necessary.

Therefore t'his report only addresses exceptions to the guidance of Regulatory Guide 1.97. The following evaluation is an audit of the licensee's submittal based on the review policy described in the NRC regional meetings.

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3. EVALUATION 1

1 The licensee provided a response to Section 6.2 of the generic letter on April 13, 1984. This evaluation is based on that submittal.

3.1 Adherence to Regulatory Guide 1.97 The licensee included a schedule in their submittal that indicates that they will conform with the recommendations of Regulatory Guide 1.97, Revision 3 (Reference 5). Therefore, it is concluded that the licensee has provided an explicit. commitment on conformance to the guidance of 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, 1.e., those variables that provide information required to permit the control room operator to take specific manually controlled safety actions. The licen-see classifies the following as Type A variables.

I l 1. Reactor coolant system (RCS) hot leg water temperature 4

2. RCS pressure

3. Containment hydrogen concentration 4

4. Steam generator level i

j 5. Steam generator pressure.

This instrumentation meets the Category 1 recommendations consistent with the l requirements for Type A variables.

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3.3 Exceptions to Regulatory Guide 1.97 l

The licensee identified the following exceptions to the requirements of Regulatory Guide 1.97.

3.3.1 RCS Soluble Boron Concentration The licensee has not provided this capability and states that during normal operation the boron concentration is measured by a boronometer in the letdown line or through radiochemistry analysis. Following an accident however, the letdown line is isolated and the radiochemistry lab may become inaccessible due to radiation levels. The post-accident sampling system provides boron concentration measurement capability. The range and design s criteria is consistent with guidance provided for Item II.B.3 of NUREG-0737.

i The licensee takes exception to the guidance of Regulatory Guide 1.97 with respect to post-accident sampling capability. This exception goes beyond the scope of this review is being and addressed by the NRC as part of their review of NUREG-0737. Item II.B.3.

3 3.2 RCS Cold Leo Water Temperature Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable with a range of 50 to 700*F. The licensee's Category 3 instrumentation has a display of 165 to 750*F. The licensee states that the primary reason for monitoring of the cold leg temperature is as a backup to steam generator pressure, which is utilized to assess the performance of heat removal. Thus, the licensee considers this a Category 3 backup variable. The licensee states that temperatures less than 200*F or greater than 600*F in the

. cold leg does not provide dependable information about the core conditions j such that the Category 1 core exit temperature instrumentation (0 to 2300*F) should be utilized.

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We find the existing temperature range adequate for the intended purpose, with the core exit temperature instruments used as a diverse method of deter-I mining RCS heat removal. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

i 3.3.3 RCS Hot Lee Water Temoerature 1

The range recomended by Regulatory Guide 1.97 for this variable is 50 to 700*F. The range available in the control room for continuous display is 125 to 675'F. The licensee states that the lower range of 125'F is sufficient

! because cooldown to below 200*F is accomplished by using the shutdown cooling i heat exchangers which have inlet and outlet temperature instrumentation  !

designed to monitor temperatures below 300*F.

i The licensee states that the upper limit of 675'F is sufficient because the RCS saturation temperature at the safety valve setpoint is less than 670*F. Should temperatures in the RCS Hot Leg exceed 670'F the RCS is in a superheat or overpressure condition such that the core exit temperature instrumentation (0to2300*F)shouldmonitorthecorecoolingstatus. Also, l

! there are four fully qualified hot leg RTDs which measure a range of 165 to j 750'F that use a computer display.

We find the existing instrumentation adequate. Additionally, the core exit temperature instruments and computer point readouts serve as diverse j methods of determining RCS heat removal. Therefore, this is an acceptable deviation. .

3.3.4 RCS Pressure l

1 The licensee deviates from the range recomended by Regulatory Guide 1.97 (0to4000psig). The range available is 0 to 3000 psig. This is in excess of 120 percent of the RCS safety valve setting and the RCS design pressure.

i The existing range of 0 to 3000 psig is adequate to monitor all expected l pressures based on the accident analyses presented in Chapter 15 of the plant  !

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FSAR. Therefore, we find this deviation acceptable, but require a commitment l from the licensee to install Category 1 instrumentation with a range in accordance with the resolution of the ATWS issue. if pressures are found to exceed those currently presented in the FSAR.

t 3.3.5 Degrees of Subcooling I

Regulatory Guide 1.97 recommends instrumentation with a range of 200*F subcooling to 35'F superheat for this variable. The licensee has i instrumentation with a range of 0 to 200*F subcooled. The licensee states that for situations that result in superheated conditions in the RCS. core exit thermocouples and hot leg RTDs will be monitored against RCS pressure to determine the degree of superheat or subcooling. The SPDS computers will plot on the display a curve of core exit temperature versus pressure or a grid with the saturation curve.

The NRC is reviewing the acceptability of this variable as part of their l review of NUREG-0737. Item II.F.2.

l 3.3.6 Radioactivity Concentration or Radiation Level in Circulating Primary Coolant 4

During normal plant operations the licensee measures RCS radiation levels by a radiation monitor in the letdown line and through radiochemistry analy-l sis. After an accident, the licensee will utilize the post-accident sampling system to obtain this information. l Based on the alternate instrumentation and the justification provided by the licensee, we conclude thVt the instrumentation supplied for this variable is adequate, and therefore, r.cceptable.

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, 3.3.7 Containment Effluent Radioactivity--Noble Gases from Identified Release Points l Effluent Radioactivity--Noble Gases from Buildings or Areas Where i Penetrations and Hatches are Located The licensee has not provided a high-reliability power source for these variables as recosuended by Regulatory Guide 1.97 for Category 2 variables.

7 The licensee states that the Gaseous Effluent Radiation Monitoring System was 1

designed to comply with the requirements of NUREG-0737. Item II.F.1, which had no requirements on the power supply.

The licensee has not stated that a highly reliable power supply cannot be provided, nor shown it to be unnecessary. The licensee should provide a high

! reliability power source for this instrumentation.

3.3.8 Safety In.iection (Accumulator) Tank Level and Pressure j The licensee has taken exception to the Category (2) and range (0 to 750 psig) recossended by Regulatory Guide 1.97 for the accumulator pressure.

l The licensee has classified accumulator tank pressure a Category 3 variable

) and provided a range of 0 to 700 psig. The licensee states that the safety l injection tank pressure is used for preaccident status to assure that this passive safety system is prepared for its safety function. The licensee states that this pressure indication provides no essential information for the operator during or following an accident. The licensee has classified the safety injection tank level as the key variable necessary to determine whether the safety injection tanks have fulfilled their safety function, with safety injection tank pressure as a backup type variable. The safety injection tank pressure is restricted by Technical Specifications to less than 624 psig.

The accumulators are passive devices. Their discharge into the reactor coolantsystem(RCS)isactuatedsolelybyadecreaseinRCSpressure. We find that the instrumentation supplied for this variable is adequate to 8

determine that the accumulators have discharged. Therefore, we find the instrumentation provided for this variable acceptable.

3.3.9 Quench Tank Temperature The licensee takes exception to the temperature range (50 to 750*F) recomended by Regulatory Guide 1.97 for this variable. The licensee states that the maximum expected quench tank temperature during design basis events is 280'F.

We find that the O to 300'F range is adequate to monitor the operation of this tank during accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

3.3.10 Steam Generator Level Regulatory Guide 1.97 recommends a level range for this variable that reads from the tube sheet to the separators. The licensee has instrumentation that reads from 19 1/8 in. above the tube sheet to the separators and states that the lower range of 19 1/8 in, above the tube sheet equates to zero, and that operator action would not change by monitoring levels lower that the 19 1/8 in. level.

The steam generator is, in effect, empty at 19 1/8 in above the tube sheet; therefore, this deviation is acceptable.

i 3.3.11 Steam Generator Pressure The licensee has provided instrumentation for this variable with a range of 0 to 1200 psia. This does not meet the regulatory guide reconenended range l of from atmospheric pressure to 20 percent above the lowest safety valve set- l ting. The following discussion and justification for this deviation was sub-mitted by the licensee.

The lowest safety valve is 1078 psig. The range would have to be O to 1295 psig to meet the NRC's recommendation. The FSAR accident analyses 9

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(Chapter 15)indicatethatforboththelossofexternalloadtransientand '

loss of all non-emergency AC power transient, the maximum steam pressure is l 1135 psig. The main steamlines have safety relief valves, atmospheric dump j valves and condenser dump valves to prevent overpressurization and to provide i pressure control. There is approximately 30 percent excess steam relief I capacity when the plant is operating at full power and all main steam safety valves are operable. Technical Specifications limit the maximum allowable plant power and its steam flow should any safety valves not be operable. This 1 l maintains excess relief capacity. The highest safety valve setting is j 1132 psig.  !

4 Based on the licensee's justification, we find the existing range

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

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3.3.12 Containment Atmosphere Temperature  ;

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! Regulatory Guide 1.97 recommends Category 2 instrumentation with a range

of 40 to 400'F for this variable. The licensee has provided Category 3 in- j strumentation with a range of 0 to 300*F. The licensee states that the key i variable for containment monitoring is containment pressure which is measured by Category 1 instrumentation. Containment atmospheric temperature is a j l backup for containment accident monitoring and as such is measured by j l Category 3 instrumentation. The range is based on the worst case peak l

! containment temperature of 288.5'F.

An analysis has been performed that demonstrates peak temperatures will l j remain on scale during worst case accidents. Therefore, this is an acceptable i deviation from Regulatory Guide 1.97.

j The justification for this category is unacceptable. Containment pres-sure is a key variable for maintaining containment integrity. Containment atmosphere temperature is for the containment cooling system. Therefore, 1 classifying this variable as Category 3 is not warranted. This instrumenta-tion should be upgraded to Category 2. l j {

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I 3.3.13 Containment Sumo Water Temperature

. The licensee does not have instrumentation for the sump water temperature. The licensee states that saturated conditions for the sump water  ;

during sump recirculation was assumed. Thus, adequate net positive suction head exists for containment spray and safety injection pumps.

This is insufficient justification for this exception. The licensee should provide the recommended instrumentation for the functions outlined in Regulatory Guide 1.97 or identify other instruments that provide the same l information and satisfies the recomendations of the regulatory guide.

3.3.14 Comoonent Coolina Water Temperature to ESF S.vstem The licensee has not provided instrumentation for this variable and sub-

' mitted the following as justification. The Service Water System inlet temperature, by design, is a maximum temperature of 129.5'F, from the i emergency cooling pond. The average temperature of the pond (June through September)is95'F. There is no control over the temperature of the service water.

l The temperature of the cooling water to the ESF components will always be ,

i within the design range. Therefore, this is an acceptable exception from Regulatory Guide 1.97.

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! 3.3.15 Component Coolina Water Flow to ESF S.vstem 1

Regulatory Guide 1.97 recomends instrumentation to monitor the cooling  ;

water flow to the ESF components. The licensee has a diverse method of l determining this flow. The following justification describes this method. l The ANO-2 system for cooling the ESF components is the Service Water System. ,

! The existing instrumentation for monitoring service water to the ESF l components includes the following: l I l

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1. Service water system pressure, with a range of 0 to 200 psig. l This instrumentation is Category 2. j 11 ,

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2. Service water system valve position indication in the control >

room and specific line-up procedures assure ESF component

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cooling. This indication is Category 2.

3. Individual ESF equipment cooling unit differential pressure alarms in the control room.

4. ESF heat exchanger local flow indicating switches on the con-tainment coolinfl units and shutdown cooling heat exchanger, with alarms on 'ow flow indication in the control room.

We find the licensee's justification acceptable. The pressure indication j

in conjunction with the valve position indication and differential pressure  !

alarus adequately monitor this system. Therefore, this is an acceptable de-viation from Regulatory Guide 1.97. {

l j 3.3.16 Radioactive Gas Holduo Tank Pressure l

l Regulatory Guide 1.97 recommends monitoring this variable with Category 3 i instrumentation with a range of 0 to 150 percent of design pressure to indi-  :

l cate storage capacity. The licensee does not have this instrumentation, saying that it is not a necessary control room variable for post-accident l monitoring. The licensee states that an accident which results in failed fuel l or radioactive gas release would preclude the manual transfer of radioactive j gases to the radioactive gas holdup tanks. The containment building would be  ;

4 utilized as the holdup tank. The licensee states that there are no automatic

) transfer operations involving the radioactive gas holdup tanks.

i l Since these tanks are not used for accident mitigation at this station and no automatic transfer operations take place, we find this an acceptable j exception from Regulatory Guide 1.97.

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I l 3.3.17 Radiation Exoosure Rate 4

l The licensee has not met the range recomended for this instrumentation I

(10-1 to 104 R/hr). The licensee has an Area Radiation Monitoring System consisting of 24 Area Monitors, four with a range of 10-2 to 103R/hr and 20 I

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with a range of 10-4 to 101 R/hr. These ranges are based on the background reading in the areas where they are located. Should entry be required in areas where these monitors indicate high radiation, health physics escorts l i would accompany personnel into these areas using portable instrumentation to

assess radiation levels. The high range for portable instrumentation is l 103 R/hr. i

] From a radiological standpoint, if the radiation levels reach or exceed the upper limit of the range provided, personnel would not be permitted to the l areas except for life saving. Therefore, we find the existing ranges for the

! radiation exposure rate monitors acceptable.

3.3.18 Condenser Air Removal S.vstem Exhaust l j Comon Plant Vent or Multipurpose Vent I

The licensee has not provided a high reliability power source for these l variables. The licensee states that the Gaseous Effluent Radiation Monitoring '

I System was designed to comply with the requirements of NUREG-0737,

, Item II.F.1, which had no requirements on the power supply.  ;

l The licensee has not stated that a high reliability power supply cannot I

be provided, nor shown it to be unnecessary. The licensee should provide a i high reliability power source for this instrumentation. -

3.3.19 Plant and Environs Radiation l  ?

l Regulatory Guide 1.97 recomends portable instrumentation with a range of

) 10-3 to 10 4 R/hr, photons; and 10-3 to 104 reds /hr, beta radiation and l low-energy photons.

j The licensee's portable instrumentation can detect gamma dose rates from ,

j 10-3 to 103 R/hr and beta dose rates from 10-3 to 50 rad /hr. They do not  !

l anticipate encountering radiation fields greater than those which can be l measured by current equipment except under severe accident conditions. Even i i i l

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I under accident conditions they do not anticipate sending individuals into 3

greater than 10 R/hr fields.

l Based on the licensee's justification, we find this deviation acceptable.

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3.3.20 Plant and Environs Radioactivity i

The licensee has not provided the recomended portable instrumentation.

! Gasmia spectroscopy can be performed, both t.t the site and at the Technical

} Analysis Laboratory in Little Rock. In addition, there is a NO-60 i spectrometer in the ANO Emergency Offsite Facility which can be used. The l

licensee states that this instrumentation should not be portable due to the rough handling it would encounter, and due to the limited amount of time field j teams have to assess a release.  !

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) The laboratory equipment at this station can provide isotopic analysis

and a timely assessment of radioactive releases. Therefore, this is an ac- ,

ceptable deviation from Regulatory Guide 1.97.

I 3.3.21 Estimation of Atmosoheric Stability i

i i Regulatory Guide 1.97 recomends instrumentation for this variable with a ,

I range of -5 to 10*C or an analogous range for alternative stability  !

l estimates. The licensee has existing instrumentation with a range of -3 to l l 5'C temperature differences and 0 to 40' wind direction sigma. i i

Table 1 of Regulatory Guide 1.23 (Reference 6) provides seven atmospheric i stability classifications based on the difference in temperature per j j 100 meters elevation change. These classifications range from extremely un-stable to extremely stable. Any temperature difference beyond -2'C or +4'C l

does nothing to the stability classification. Therefore, we find this an ac- l

) ceptable deviation from Regulatory Guide 1.97. i l  !

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4. CONCLUSIONS

. Based on our review, we find that the licensee either conforms to, or is justified in deviating from the guidance of Regulatory Guide 1.97, with the following exceptions:

1. Reactor coolant system pressure--the licensee should commit to d

install instrumentation with a range in accordance with the resolu-tion of the ATWS issue (Section 3.3.4).

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2. Containment effluent radioactivity-noble gases from identified release points--the licensee should provide a high reliability power supply for the gaseous effluent radiation monitoring system (GERMS)

(Section3.3.7).

3. Effluent radioactivity-noble gases from buildings or areas where penetrations and hatches are located--the licensee should provide a high reliability power supply for the GERMS (Section 3.3.7).

4. Containment atmosphere temperature--the licensee should upgrade this instrumentationtoCategory2(Section3.3.12).

5. Condenser air removal system exhaust--the licensee should provide a high reliability power supply for the GERMS (Section 3.3.18).

6. Conson plant or multipurpose vent--the licensee should provide a high reliabilitypowersupplyfortheGERMS(Section3.3.18).

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5.0 REFERENCES

1. MRC letter, D. G. Eisenhut to all licensees of operating reactors, ap-plicants for operating licenses, and holders of construction permits,

" Supplement No. 1 to NUREG-0737--Requirements for Emergency Response Capa-bility (Generic Letter No. 82-33)," December 17, 1983.

2. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regula-tory Guide 1.97, Revision 2. U.S. Nuclear Regulatory Commission (NRC),

Office of Standards Development, December 1980.

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

4. Arkansas Power and Light Company letter, John R. Marshall to Director, Office of Nuclear Reactor Regulation, April 13, 1984.

5. Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conc itions During and Following an Accident, Regulatory Guide 1.97, Revision 3 U.S. Nuclear Regulatory Connission (NRC), Office of Nuclear Regulatory Research, May 1983.

6. Onsite Meterological Programs, Regulatory Guide 1.23 (Safety Guide 23),

NRC, February 17, 1972, or Meterological Programs in Support of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, Office of Standards Development. September 1980. .

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