ML20207J439

Conformance to Reg Guide 1.97:Maine Yankee, Technical Evaluation Rept

ML20207J439
Person / Time
Site:	Maine Yankee
Issue date:	06/30/1988
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20206F670	List: ML20206F667 ML20207J439
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7083, TAC-51103, NUDOCS 8809150117
Download: ML20207J439 (21)

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EGG-NTA-7083

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TECHNICAL EVALVATION REPORT CONFORMNCE TO REGULATORY GUIDE 1.97: PAINE YANKEE Occket No. 50-309 Alan C. Udy Published June 1988 Idaho National Engineering Laboratory EC&G Idaho, Inc. '

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under CCE Contrac; No. DE-AC07-761001570 FIN No. A6483 grio m 6 o N 7 cuao #

n-ABSTRACT This EC1G Idaho, Inc., report documents the review of the submittals for Regulatory Guide 1.97, Revision 3, for the Maine Yankee Atomic Power Station and identifies areas of nonconformance,to the regulatory guide.

Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability'is not provided are identified.

Occket No. 50-309 TAC No. 51103 11

FOREWORD This report is supplied as part of the "Program for Svaluating Licensee / Applicant Conformance to RG 1.97 " being conducted for the U,$.

Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering and System Technology, by EG&G Ioaho, Inc.,

Electrical, Instrumentation and Control System Evaluation Unit.

The U.S. Nuclear Regulatory Commission funded the work under authorization B&R 20-19-10-11-3.

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Occket No. 50-309 [

TAC No. 51103 l l

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CONTENTS ABSTRACT ............................................................. 11 FOREWORD .............................................................. 111 l 1. INTRODUCTION ..................................................... 1 ,

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

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3. EVALUATION ................................................ ...... 4 1

3.1 Adherence to Regulatory Guide 1.97 .......................... 4 i 3.2 Type A Variabits ............................................ 4 l

3.3 Exceptions to Regulatory Guide 1.97 ......................... 5 4 CONCLUSIONS ...................................................... 19 l

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5. REFERENCES ....................................................... 20 i

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CONFORMANCE TO REGULATORY GUIDE 1.97: MAINE YANKEE

1. INiRODUCTICN On December 17,1982. G=. 3.ric Letter No. 82-33 (Reference 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regu16 tion, to all Itcensees of operating reactors, s.pplicants for operating licenses and holders of construution permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency re ?onse capability. These requirements have been published as Supplement No.1 to NUREG-0737, "TMI Action Plan Rsquirements" (Referenct 1).

Maine Yankee Atemic Power Company, the licensee for the Maine Yankee Atomic Power Station, provided a response to Section 6.2 of the generic letter on February 28, 1985 (Reference 4). Th,is submittal addresses the reco-aendations of Regulatory Guide 1.97, Revision 3 (Reference 5).

t Additional information was provided on June 17, 1986 (Reference 6),

September 5,1986 (Reference 7), April 8,1958 (Reference 8), and April 29, 1938 (Reference 9). ,

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T5is report is Lassd on the recommendations of Regulatory Guide 1.97, l

Revision 3, and ccmpares the instrumentation proposed by the licensee's  ;

submittals with these reccomendations.

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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 describirg how the licensee complies with Regulatory Guide 1.97 as applied to emergency response facilities. The submittal should include documentation that provides the following info:mation for each variable shown in the applicable table of Regulatory Guide 1.9 '.

1. 'nstrument range

2. Environmental qualification

3. Seismic qualification

4. Quality assurance -

5. Reduidance and sensor location

6. Power supply

7. Location of di; play

8. Schedule of installation or trgrade The sobmittal should identify deviations f rcs the regulatory guide and pre /.ide supporting justification or alter 9atives.

Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983, to answer liceasee and applicant questions and concerns regarding the NRC policy on this subject.

At these meetir.js, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97. Where licensees or applicants explicitiv state that instrumen' systems conform to the regolatory guide it was n; td that no further staff review would be necessary. Therefore, this 2

,' report only addresses exceptions to Regulatory Guide 1.97. The folloting evaluation is an audit of the licensee's submittals, based on the review policy cescribed in the NRC regional meetings.

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3. EVALUATION The licensee provided a response to Item 6.2 of NRC Generic Letter 82-33 on Feb*uary 28, 1985. The respunse describes the licensee's position on post-accident monitoring instrumentation. Additional information was provided on June 17, 1986, September 6, 1996. April 8, 1988, and April 29, 1988. This eviluation is based on the submitted material.

3.1 Adherence to Regulatory Guide 1.97 The licensee has provided a review of their post-accident monitoring instrumentation that compares the instrumentation characteristics against the recommendations of Reguiatory Guide 1.97, Revision 3. The licensee shows that in several instances, satisfactory instrumentation already exists and states that additio9al instrumentation will be installed to comply with the provisions of Regulatory Gu'de 1.97, except for those instances where deviations are justified. The licensee states in their report that the identified mocifications will be completed during the 1935 refueling outage. Later submittals that commit to modifications also provide schedules. Therefore, we conclude that the licenseo has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3.

3.2 Type A variables Regulatory Guide 1.97 does not specifically 1;entify Type A variables, i.e., those variables that provide the in'

• ion required to permit the control room operator to take specific ' controlled safety actions.

The licensee classifies the following it. . entation as Type A.

1. Reactor coolant system (RCS) colo leg w<ter temperature

2. ROS het leg watsr temperature 4

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3. RCS pressure .f 4

4. Wide range containment sump water level I

5. High range containment pressure l l

6. Containment area radiation  ;

7. Pressurizer level  ;

8. Steam generator level  !

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9. Steam generater pressure, s  :

. I I inis instrumentation meets the Category 1 recommendations consistent with l the requirements for Type A variables, with the exceptions as listed in

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Section 3.3. l I

i 3.3 Exceptions to Regulatory Guide 1.97 [

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i The licensee identified deviations and exceptions from Regulatory {

Guide 1.97. These are discussed in the following paragraphs. I i i i 3.3.1 bactor Coolant System Pressure l l

Regulatory Guide 1.97 recomends instrumentation with a rango from l 0 to 4000 psig for this variable for Maine Yankee's Cor.bustion Engineering f supplied nuclear steam supply system. l'he licensee's instrumentation for l this variable his a range of 0 to 3250 psig. l l

s The licensee states that, as part of the final resolution of ths l i anticipated transient without scram (ATWS) issue, they are installing an i

. ATVS mitigation system that curtails reactor coolant system pressures in l excess of 3250 psig. As the pressure is limited to the 0 to 3250 psig  !

j range of tha instrumentation, we find the range acceptable. f 1

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4 3.3.2 Coolant level in Reactor i

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Regulatory Guide 1.97 recommends Category 1 instrumentation for this i variable. The licensee has identified the following deviations for the.  !

l ' instrumentation provided; 1) there is no redundant instrumentation, 2) one ,

recorder indicates the level for all three instrument loops, and 3) all f three instrument loops are powered by the same power source, IB-1.

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f i The licensee states that the core exit thermocouples, the subccoled l 4 margin monitors and the safety parameter display system and the plant f computer displays provide alternate and backup indication for this variable. t l

This exception goes beyond the scope of this review and has been t 4

addressed by the NRC as part of their review of NUREG-0737, Item II.F.2.  :

i 3.3.3 Degrees of Subcooling ,

I Regulatory Guide 1.97 reccmmends instrumentation for this variable ,

with a range of 200*F subcooling to 35'F superheat. The instrumentation I supplied by the licensee has a range of 0 to 200'F subcooling. Superheat is f not monitored. No justification for this deviation was given by the l l licensee in their !ubmittals regarding Regulatory Guide 1.97. I 1 i

! The NRC has reviewed the acceptability of this variable as part of L their review vf NUREG-0737. Item II.F.2. l i I 1  !

3.3.4 Containment Sump Water level i i l Regulatory Guide 1.97 recommends narrow renge instrumentation for this l l variable. The iteensee does not include narrow rasse intrumentation. They l state that the wide range instruments have resolution sufficient for f

! measurement of the range in question. The licensee states that the sumps i isolate below 6 inches water level, and that the wide range instruments are adequate fer all usable (above 6 inches) sump levels, p

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r Because the wide range instrumentaticn covers the entire range of expected water levels for post-accident conditions, we conclude tnat (a) the range is su'ficient to monitor the sump operation for any anticipated condition and (b) the samp level is adequately monitored by*the wide range instrumentation to preclude the need for na row range instrumentation. Therefore, we find that the instrueta.tation provided for this variable is acceptable.

3.3.5 Containment Pressure Regulatory Guide 1.97 rec 6e. mends instrumentation for this variab,le with a range of -5 psig to three times design pressure. The licensee has instrumentation for this variable with a range of 0 to 200 psig. The licensee (Reference 6) verifies that this instrumentation is capable of monitoring subatmospheric pressure. With this clarification, we find this instrumentation acceptable. .

3.3.6 Radiation Level in Circulating Primary Coolant The licensee has instrumentaton that monitors the radiaton level in the letdown line during normal operaiton. This line is isolated with an accident signal. Thus, tnis instrumentation is not available post-accident, and the post-accident sa.mpling system, which has been reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3, is used to verify fuel cladding integrity.

Based on the alternate instrumentation provided by the licensee, we conclude that the instrumentation supplied for this variable is adequate and, therefore, acceptable.

3.3.7 Radiation Excesure Rate Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 10"I te 10' R/hr. The licersee has irstrumentation for this variable with a range of 10 to 10 R/hr. The li:ensee states that 7

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6 this instrumentation is used to determine area accessibility. Portable instrumentation is used to survey the area prior to and during any work being done in the areas monitored.

From a radiological standpoint, if '.ne radiation levels reach or exceed the upper limit of the range, personnel would not be permitted into the areas without portable monitoring (except for lifS saving). 9ased on the alternate supplemental instrumentation used by the licensee for this variable, we find the provided ranges for the radiation exposure rate monitors acceptable.

3.3.8 Residual Heat Removal (RHR) System Flow '

Regulatory Guide 1.97 recommends Cctegory 2 instrumentation for this variable. The instrumentatici supplied by the licensee meets Category 2 requirements except in environmental qualifica, tion. The licensee states that the Category 2 low pressure safety injection (LPSI) flow instrumentation can be used for this variable, because it is the LPSI system that provides long term decay heat removal in post-accident conditions. The licensee also states that the RHR system flow instrumentation has been addressed in accordance with the Environmental Qualification Rule 10 CFR 50.49, and it was found that environmental qualification was not necessary. Based on this, we find the provided instrumentation acceptable.

3.3.9 RHR Heat Exenanger Outlet Tet;erature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation for this variable meets the Category 2 requirements except for environmental qualification. The Itcensee states that for large break loss-of-coolant accidents (LCCA) the RHR system is isolated, and that this instrument would not be used. For a small break LOCA, the licensee states that this instrumentation may be used during recirculation. The licensee states that the containment sump contents would not exceed 191*F and that no net positive section head ; ump 8

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probleas would result for 9.he high pressure safeBy injection pemps, even if the heat exchanger is not functioning. The licensee states that heat removal can be monitored by the rise in primary and se:ondary component cooling water (PCCW and SCCW) temperatures. The licensee (Reference 6) states that this instrumentation has been addresses in accordance with the Environmental Qualification Rule,10 CFR 50.49, and it was found that environmental qualification was not necessary because the long term cecay heat imoval capacity following an accident is perfor ed by the LPSI 1ptem Based on this, we find the provided instrumentation acceptable.

C ,10 lccumulatorTankLevelandpressure

' ilatory C.ide 1.97 recom. mends Category 2 instrumentation for this var W ,s. The licensee's instrumentation for this variable meets the Catwory 2 requirements except in environmental qualification. The range of the pressure instrumentation is not as recommended. The regulatcry cuide reccamends a range of 0 to 750 psig. Thc licensee's instrueentation has a range of 0 to 300 psig.

The licensee states that the accumulators are a passive system and that they are not accessible during an accident. Because the leve' and pressure are verified ar.d racorded by the operator (to maintain the readiness of the accumulators to function) on each shift, the licensee d0es not supply environmentally qualified instrumentation for this variable.

The licensee states that the accumulator safety relief valves are set for 250 psig. Because of these safety reif ef valves, the pressure in the accumulators will not exceed the range of 0 to 300 psig. Therefore, we find thc rsnge acceptable.

The existing instrumentation is not acceptable. An environmentally qualified instrument is necessary to monitor tne status of these tanks.

The licensee should designate either level or pressure as the key variable to directly indicate accumulator discharge and provice instrumentation for that variable that is environmentally qualified in ac:ordance with 10 CFR 50.49 and Regulatory Guide 1.97, 9

6 3.3.11 Accumulator Isolation Valve Position ,

Regulatory Guide 1.97 recommends Category 2 instrumentation for this >

variable. The itcensee's instrumentation for this variable meets the l Category 2 requirements except for environmental qualification. The f '

licensee states that there is no need to monitor tne position of these valves during or after an accident because these valves are opened in the startup procedure and electrically disabled and verified to be in the open position. This is accomplished by the licensee's tagging procedures.  !

/ Additionally, the valves are operated by keylock switches, providing  ;

additional administrativo controls on the valve position.

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Based on the licensee's justific.ation that these valves are open and ,

j cannot change position during c= following an accident, we consider the {

1 instrumentation for this variable acceptable ,

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t 3.3.12 Peric Acid Charoino Flow 1

j Regulatory Guide 1.97 recommends Category 2 instrumentation for this I

variab'e. The licensee'

instrumentation for this variable meets thi j Category 2 requirements except for environmental qualification. The f licensee states that the flow transmitter is not required to operate in a j harsh environment, because the flow is not through the transmitter during l.

emergency boration. For emergency boration, tne flow from the boric acid  ;

storage tark to the reactor coolant system is via the boric acid transfer i pumps and the charging pumps, in series. The flow is calculated by the {'

rated pump flow rate and the duration of the pump operation. The licensee

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l states (Reference 6) that this instrumentation has been addressed in accordance with the Environmental Qualification Rule, 10 CFR 50.49. This determined that environmental qutlification of this instrumentation is not j necessary. Based on this, we find the provided instrumentation acceptable.  !

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3.3.13 LowPressureInlect,ionSystemFlow i Regulatory Guide 1.97 'ecommends instrumentation for this variable with a range of 0 to 110 percent of design flow. The licenste identifies this requirement as 0 to 2100 gallons per minute. The licensat states (Reference 6) that the range of the instrumentation is 0 to 3000 gallons per minute. This meets the recommendations of the regulatory guide and is acceptable.

l 3.3.14 pressurizer Level  !

i Regulatory Guide 1.97 recommends instrumentation for this variable  !

with a range from the top to the bottom. The licensee's instrumentation, I measures from the bottom to the top of the pres.urizer (Reference 6).

Based on this statement, we find the instrutentation Acceptable.

J.3.15 pressuri:er Heater Status -

i Regulatory Guide 1.97 recommends monitoring the pressurizer heater l

electric current with Category 2 instrut.entation. The licensee monitors l the heater circuit breaker position.  !

t Section II.E.3.1 of NUREG-0737 requires a number of the pressurizer heaters to have the capability of being powered by the es rgency s power sources. Instrumentation is to be provided to prevent overloading a diesel gsnerator.

The licensee maintaines the position that an on-off mede of indic: tion is adequate to monitor this variable (Reference 6). The licensee bases i-l this on the fact that the heater banks are either "on" or "off". The t licensee further states that the heater current can be monitored with the l diesel kilowatt meters when the heaters are loaced onto the diesels, i 1

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6 While this would provide an indication of the operability of the pressurizer heaters when powered by the diesel generators, it does not provide an operability indication when the power source is offsite power.

We find the justification provided by the licensee unacceptable. A means of monitoring pressurizer heater current in the control room should be provided.

3.3.16 Quench Tank Temperature Regulatory Guide 1.97 recommends instrumentation for t51s variable with a range from 0 to 750*F. The licensee's instrum.entation has a range of 0 to 350*F. The licensee states that the normal tank temperature is 104*F, and that the maximum temperature that can be reached by the tank contents is 350*F.

The range covers the anticipated requirem,ents for normal operation, anticipated operational occurences and accident conditions. Because the temperature of the tank contents will not exceed the O to 350*F range of the instrumentation, we find this deviation from the regulatory guide acceptable.

3.3.17 Steam Generator Level Regulatory Guide 1.97 recom. mends Category 1 instrumentation for this variable with a range from the tube sheet to the separators. The licensee commited to install Category 1 instrumentation that has the full range recommended by the regulatory guide (Reference 6). The installation is to be accomplished during the 1988 refueling outage or the refueling outage 6 months following the NRC Sa'ety Evaluation Report, whichever is later. We find this committment acceptable.

3.3.18 Steam Generator Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 20 percent above the lowest safety valve setting. The 12 I

licensee has identified the lowest safety valve setting as 935 psig  !

(1000 psia). Thus, the recommended range is 0 to 1200 psia. The

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licensee's present instrumentation has a range of 0 to 1000 psia. The i licensee commits (Reference 7) to provide upgraded instrumentation, f t

scheduled for the 1988 refueling outage, with a range to 1200 psig. We  !

find this commitment acceptable.  !

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3.3.19 condensate Storage Tank. Water Level f

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Regulatory Guide 1.97 recommends Category 1 instramentation for this l variable. The licensee's instrumentation is a single Category 1 channel j with readout in the control room. A self powered pressure guage is mounted i j on the tank and is assessible following an accident. The licensee i

{ indicates that the diverse and separately powered low level and low-low f

) levtl alarms are sufficient to backup this instrumentation. Based on this  !

i diversity, we find the instrumentation provide,d for this instrumentation acceptable. ,

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I 3.3.20 Containment Spray Flow I i l Regulatory Guide 1.97 recommeds Category 2 instrumentation for this j j variable with a range of 0 to 110 percent of design flew. The licensee i l commits (Reference 7) to provide the recommended Category 2 instrumentation. Ihe upgrade is scheduled fo* the 1953 refueling outage, f

.l j We find this commitment acceptable. I l  !

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j Regulatory Guide 1.97 recommends Category 2 instramentation for this j j variable with a range of 40 to 400*F. As Category 2 instrumentation, it i t '

should be envirementally qualified and isolated. The licensee's l l instrumentation deviates from these recommendations. The licensee states l l that environmental qualification and isolation from the plant computer is  !

! not needed because this instrumentation is used only for centsinment  !

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leaksge tests, and not for normal or post-accident operation. The licensee sta es that containment pressure is the variable used to monitor the post-accident containment integrity.

Based on the licensee's justification, we find that the application of Category 3 backup instrumentation is in accordance with the regulatory guide.

The range of the instrumentation is 30 to 150'F rather than tne recommended 40 to 400*F. No justification was given oy the licensee for this deviation. Thererere, we find the deviation in range not acceptable.

The licensee should provide instrumentation with tne recommended range for this variable.

3.3 22 Containment Sump Water Teeperature Regulatory Guide 1.97 *ecemeends Category 2 instrumentstion for this variable with a range of 50 to 250*F. The licensee has not provided this instrumentation, stating that an analysis has determined that the required safety equipment will not be adversly affected by the sump water temperature. Reference 6 indicates that tFis variable is not required to appraise the operation of the containment spray system (which provides containment pressuto suppression).

This is intuf ficient justificution for this exception. The licensee thould provide the recot. mended instrueentation to allow a quantative evaluation of the heat removed from the containment. Otherwise, the licensee should identify other instruments (such as the RHR heat exchanger inlet temperatura) that provides the same information and satisfies the reyulatory guide.

3.3.23 Makeup Fiow-in, Regulatory Guide 1.97 recommends Categoey 2 instrumentation for snis variable. Thus, environmentally qualified instrumentation should be 14

utilized. The instrumentation provided for this variatie is not environmentally qualified. The licensee states'that charging can be performed using the high pressure safety injection system, using itt qualified flow instrumentation, should long term coolic; be required. The licensee states that this instrumentation has been evaluated in accordance with the Environmental Qualification Rule,16 OcR 50.49, and environmental cualification was found to be unnecessary. Based on t91s statement, we find the provided instrumentation acceptable.

3.3.24 Letdown Flew-Out Regulatory Guide 1.97 recommends Category 2 instra entation for this variable. Thus, environmentally qual.'fied instrumentation should be utilized. The instrumentation provided for this vari 4 Die is not environmentally qualified. The licensee states that the high pressure drain line can be used for letdcwn should the letdown flow instrutentation fail due to a harsh environment.

The high pressure drain line flow is measured by instra entation located in a mild post-accident environment. The licensee states that this instrumentation has been evaluated in accordance with the Environmental Qualification Rule, 10 CFR 50.49, and environmental qualification was found to be unnecessary. Based on this statetent, we fine tre provided instrumentation acceptable.

3.3.25 Component Cooling Water Flew to Ergineered Safety Features (ESF)

System Ccmponents Regulatory Guide 1.97 recommends Category 2 instr. entation for this variable with a range of 0 to 110 percent of design flew. The licensee is upgrading alternate instrumentation to Category 2 it;uirements. The alternate instrumentation consists of the follcwing fce each of the two co penent cooling water subsystems.

Surge tank level 15

pu.mp motor current temperature alarms for each individual cooling load.

A decrease in the surge tank level (displayed on demand) would indicate leakage or a break in the cooling water subsystem. A pump flow curve shows that the pump motor current would decrease if system blockage occurred on the discharge side of the pump or if pump suction was lost. A high temperature alarm on any compenent would indicate the possiblity of tradequate system c eration.

We find the upgraded alternate instrumentation to be a viable and acceptable approach to meeting the objectives of Regulatory Guide 1.97, 3.3.26 Radioactive Gas Holdup Tank (Orum) Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a readout in the control room. The licensee's instrumentation for this variable has local indication only. The licensee states (Reference 7) that this local readout is accessible in the post-accident situation.

Considering the operation of this equipment, that no automatic or manual transfer of radioactive gases would occur in the post-accident situation, we find the accessible local readout acceptable.

3.3.27 Containment or purge Eft:uent-Neble Gases and Vent Flow Rate Regulatory Guide 1.97 recommends instrumentation for this variable with ranges of 10 -6 to 105uC1/cc and a to 110 percent of design flow.

The licensee provides a range of 10 to 10 6 ep,,

The licensee states (Reference 7) that the containment purge effluent is directed to the primary vent stack for exhaust (see Section 3.3.23). We find the provided instrumentation, as described, to be in conformance with Regulatory Guide 1.97, which allows no instru entation for this variable if tne purge effluent is routed through a cetmon plant vant.

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3.3.28 Common plant Vent-Noble Gases and Vent Flow Rate .

I Regulatory Guide 1.97 recommends instrumentation for this variable with ranges of 10 -6 to 103 uti/cc and 0 to 110 percent of derign flow. The licensee provides ranges of 10 to 610 cpm,100to1depmand0.1to 7

10 mR/hr.

The licensee states that tre flow rate is known based on the numbcr of fans operating. The flow rate fer each individual fan is a known quantity.

The licensee also states that calculations have been made that show the ,

equivalence between the recommended range and the supplied range and units.

The licensee has this information available for review should an audit need t this information.

Based on this equivalence, we find that the instrumentation provided is adequate to monitor this variable during all accident and post-accident

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conditions. L 3.3.29 Vent frem Steam Generator Safety Relief Valves-Noble Gases. l Duration and Mass of Steam per Unit Time i

Regulatory Guide 1.97 recommends instrumentation for this variable with ranges to 10 -1 to 10 3uCi/ce, seconds and mass of steam per unit time.

The licensee provides a range of 10'I to 107 eR/hr. The equivalence to the reccmmended range not stated. Instr mentation a is provided for main steam I flow, and the duration of the release can be determined from this.

Additionally, the licensee states that, since the safety relief valves l

l discharge to the atmosphere, various personnel will be aware of the lifted safety relief valves.

l The licensee's response did not address the equivalence of the provided range to the reccerended range. Therefore, we can only conclude that the range is not acceptable. The licensee should provide the reccmmended instrutentation with a range of 10 ~1 to 103 uti/cc.

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a 3.3.30 Estimation of Atmospheric Stability Regulatory Guide 1.97 recommends instrumentation for this variable with a range of -9'F to +18'F. The licensee has pro ided instrumentation for this variable with a range of -8'F to 20*F.

Table 1 of Regulatory Guide 1.23 (Reference 10) provides seven atmospheric stability classifications based on the difference in temperature per 100 meters elevation change. These classifications range from extremely unstable to extremely stable. Any temperature difference greater than +4*C o.*

1ess than -2'C does nothing to the stability classification. The licensee's instrumentation inclusts this range. Therefore, we find that this instrumentation is acceptable to determine the atmospheric stability.

3.3.31 Acciden; Sampling (primary Coolant. Containment Air and Sump)

The licensee's post-accident sampling system provides sampling and analysis as recommended by the regulatory guide, except that:

1. the primary coolant and sump are not analyzed for dissolved oxygen, and,

2. the containment air is not analy:ed for oxygen concent.

The licensee deviates from Regulatory Guide 1.97 with respect to post-accident sampling capability. This deviation gces beyond the scope of this review and has been addressed by the NRC as part of their review of NUREG-0737 Item II.B.3.

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

1. Accumulator level and pressure-the licensee should designate either level or pressure as the key variable and provide environmentally qualified instrumentation for that variable (Section 3.3.10).

2. Pressurizer heater status--the licensee should provide the recommended current instrumentation (Section 3.3.15).

3. Containment atmosphere temperature- ,the licensee should prcvide the recommended range for this instrumentation (Section 3.3.21).

4. Containment su p water temperature--the licensee should provide the recommended instrumentation or identify alternate '

instrumentatien that provides the same infarration and satisfies the regulatory guide (Section 3.3.22).

5. Vent from steam generator safety relief valves--the licensee should provide the reconmended instrumentation for this variable

- to monitor any radioactive releases from this point (Section 3.3.29).

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5. REFERENCES

1. NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction Permits "Supplement No. 1 to NUREG-0737--Requirements for Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982.

2. Instrumentation for Light-Water-Coeled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guice 1.97, Revision 2, NRC, Office of Stancards Development, December 1980.

3. Clarification of TMI Action Plan Reguirements, Requirements for Emergency Resoonse Capacility, NJKtG-0737, Supplement No.1, NRC, Office of Nuclear Reictor Regulation, January 1933.

4 Letter, Maine Yankee Atomic Power Cempany (G. O. Whittier) to NRC, "Regulatory Guide 1.97 Report", February 28, 1985, MN-S-43, GOW-SS 71.

5. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant anc Environs Concitions During and Follewing an Accicent, Regulatory Guice 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1933.

6. Letter, Maine Yankee Atemic Power Company (G. D. Whittier) to NRC, "Additional Information on Exceptions to Regulatory Guide 1.97,"

June 17, 1936, MN-86-31.

7. Letter, Maine Yankee Atomic Power Company (G. O. Whittier) to NRC, "Additional Information on Exceptions to Regulatory Guide 1.97,"

Septetter 5, 1936, MN-56-111.

8. Letter, Maine Yankee (G. D. Whittier) to NRC (R. H. Wessman),

"Regulatory Guide 1.97, Rev. 3," April 8, 1983, MN-88-41, GCW-88-36.

9. Letter, Maine Yankee (G. O. Whittier) to NRC (R. H. Wessman),

"Regulatory Guide 1.97, Rev. 3," April 29, 1988, MN-SS-49, GCW-33-95.

10. Onsite Meteorological Programs, Regulatory Guide 1.23 (Safety Guice 23), NRC, February 1771972 or Meteorological Programs in Support cf Nuclear Pewer Plants, Proposed Revision 1 to $egulatory Guice 1.23, NRC, Office of Stancares Devel:pment, September 1950.

20

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'#"65'- Sl8UOGRAPHIC DATA SHEET EGG-NTA-7083

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CONFORMANCE TO REGULATORY GUIDE 1.97: MAINE YANKEE

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....,i, July 1988

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• Alan C. Udy -

July I 1988

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EG4G Idaho, Inc. n . ..u w, P.O. Box 1625 Idaho Falls 10 83415 A6483

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Division of Engineering and System Technology Preliminary Technical Office of Nuclear Reculation Evaluation Report U.S. Nuclear Regulatory Corenission ,

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Washington, DC 20555

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This EG&G Idaho, Inc., report documents the review of the applicable submittals for the Maine Yankee Atomic Power Station and identifies areas of nonconformance to Regulatory Guide 1.97. Exceptions to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.

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