ML20207D678

Safety Evaluation Accepting Util Responses to Generic Ltr 82-33 Re post-accident Monitoring Instrumentation Compliance W/Guidelines of Reg Guide 1.97,Rev 2,subj to Listed Condition.Portions of Rev 1 to EGG-EA-6771 Encl

ML20207D678
Person / Time
Site:	Point Beach
Issue date:	07/11/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20198S974	List: ML20198S973 ML20203D917 ML20207D620 ML20207D678
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, TAC-51120, TAC-51121, NUDOCS 8607220159
Download: ML20207D678 (16)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR THE F0 INT BEACH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET N05. 50-266 AND 50-301 CONFORMANCE TO REGULATORY GUIDE 1.97 INTRODUCTION AND

SUMMARY

Wisconsin Electric Power Company (WE) was requested by Generic Letter 82-33 to provide a report to the NRC describing how the post-accident monitoring instru-mentation meets the guidelines of Regulatory Guide 1.97 as applied to emergency response facilities. Response specific to Regulatory Guide 1.97 was provided on September 1, 1983. Additional information was provided by letters dated August 30, 1985 and November 27, 1985.

A detailed review and technical evaluation of the licensee's submittals was performed by EG&G Idaho, Inc., under contract to the NRC, with general super-vision by the NRC staff. This work was reported by EG&G in their Technical Evaluation Report (TER), "Conformance to Regulatory Guide 1.97, Point Beach Nuclear Plant, Unit Nos. 1 and 2," dated February 1986 (attached). We have reviewed this report and concur with the conclusion that the licensee either conforms to, or is justified in deviating from, the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable.

EVALUATION CRITERIA Subsequent to the issuance of the generic letter, the NRC held regional meet-ings in February and March 1983 to answer licensee and applicant questions and concerns regarding the NRC policy on Regulatory Guide 1.97. At these meetings, it was noted that the NRC review would only address exceptions taken to the P

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guidance of Regulatory Guide 1.97. Further, where licensees or applicants ex-plicitly state that instrument systems conform to the provisions of the regu-latory guide, it was noted that no further staff review would be necessary.

Therefore, the review performed and reported by EG&G only addresses exceptions to the guidance of Regulatory Guide 1.97. This Safety Evaluation addresses the licensee's submittals based on the review policy described in the NRC regional meetings and the conclusions of the review as reported by EG&G.

EVALUATION .

We have reviewed the evaluation performed by our consultant contained in the enclosed TER and concur with its bases and findings. The licensee either con-forms to, or has provided an acceptable justification for deviating from, the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable.

However, because the neutron flux instrumentation will have only one channel of instrumentation which is environmentally and seismically qualified, the staff will require that it have more frequent surveillance intervals than a qualified two channel system when this equipment is required to be incorporated into the plant Technical Specifications in the future.

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3-It is also noted that in section 3.3.19 of the enclosed TER it is incorrectly stated that Regulatory Guide 1.97 recommends Category 1 instrumentation for emergency ventilation. The Regulatory Guide actually recommends Category 2 instrumentation. Seismic qualification is therefore not necessarily required.

CONCLUSION Based on the staff's review of the enclosed Technical Evaluation Report, and the licensee's submittals, we find that the Point Beach Nuclear Plant, Unit .

Nos. 1 and 2, design is acceptable with respect to conformance to Regulatory Guide 1.97, Revision 2. However, the staff will require more frequent surveillance intervals for the neutron flux instrumentation when this equipment is required to be put into future plant technical specifications.

Date:

Principal Contributors:

A. Toalston J. Lazevnick T. Colburn

Attachment:

Technical Evaluation Report l

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ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97 for Unit Nos. I and 2 of the Point Beach Nuclear Plant 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.

FOREWORD This report is supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to RG 1.97," being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc., NRR and I&E Support Branch.

The U.S. Nuclear Regulatory Commission funded the work under .

authorization 20-19-10-11-3.

ll Decket Nos. 50-266 and 50-301 TAC Nos. 51120 and 51121 ,

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CONTENTS A B S T RA C T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 Except ions to Regul atory Gu ide 1.97 . . . . . . . . . . . . . . . . . . . . . . . . 5

4. CONCLUSIONS ...................................................... 19

5. REFERENCES .......................................................

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2. REVIEW REQUIREMENTS Section 6.2 of NOREG-0737, Supplement No.1, sets forth the documentation to be submitted in a report to the NRC describing how the licensee complies with Regulatory Guide 1.97 as applied to emergency response facilities. The submittal should include documentation that provides the following information for each variable shown in the upplicable table of Regulatory Guide 1.97.

1. Instrument range

2. Environmental qualification

3. Seismic coalification

4. Quality assurance

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5. Redundance and sensor location

6. Power supply

7. Location of display

8. Schedule of installation or upgrade The submittal should identify deviations from the regulatory guide and provide supporting justification or alternatives.

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

At these meetings, it was noted that the NRC review would only address ,

exceptions taken to Regulatory Guide 1.97. Where 1 fcensees or applicants explicitly state that instrument systems conform to the regulatory guide, ,

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3. EVALUATION i The licensee provided a response to NRC Generic Letter 82-33, on September 1,1983. Additional information was provided on August 30, 1985 and November 27, 1985. This evaluation is based on these submittals.

3.1 Adherence to Regulatory Guide 1.97 The licensee states that their submi'ttal provides a detailed account of the conformance of Wisconsin Electric Power Company's Point Beach ,

Nuclear Power Plant, Unit Nos.1 and 2, to the re' commendations of Revision 2 to Regulatory Guide 1.97. The licensee further states that the information provided in their submittal meets the requirements of Supplement No. I to NUREG-0737, Section 6. The licensee has committed to make the modifications they have identified by December 31, 1985 (Reference 7). Subsequent to this commitment the licensee agreed to modify the instrumentation for the variables neutron flux and pressurizer relief, tank (quench tank) temperature by the end of their 1987 refueling outage (Reference 6). Therefore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3.

s 3.2 Type A Variables Regulatory Guide 1.97 does not specifically identify Type A variables,

i.e., those variables that provide the information required to permit the control room operator to take specific manually controlled safety actions.

The licensee classifies the following instrumentation as Type A.

1. Refueling water storage tank level

2. Reactor coolant system pressure

3. Containment pressure 4 .

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postulated LOCA/HELB. They further state that control rod position indication and analysis of RCS sampies for boron are considered adequate to ensure reactor shutdown. The licensee maintains that neutron flux monitoring is a backup means of verifying automatic reactor shutdown and, as such, should be classified as no higher than a Category 2 instrument.

The licensee has committed, in Reference 5, to the installation of one channel of additional neutron flux monitoring per unit. This new channel is capable of monitoring the entire recommended range and will be environmentally and seismically qualified.'

The following lists the available means of determining reactivity control at this station.

1. A new neutron flux monitoring channel that is environmentally anc seismically qualified and meets the regulatory guide range recommendat ion.

2. The 2 existing channels of source range and 2 existing channels of intermediate range neutron flux monitoring instrumentat fon that are redundant but, are not environmentally or seismically qualif ied.

3. Control rod position indication signals.

4. Safety injection. system monitoring instrumentation.

5. Monitoring of the RCS soluble boron content by analysis of grab samples.

Based on the availability of this neutron flux and alternate instrumentation, we conclude that the licensee has provided adequate

instrumentation to monitor this variable during post-accident ecnditions. ,

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3.3.4 Radiation Level in Circulating Primary Coolant The licensee uses the post-accident sample system, which is being reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3, to measure this parameter.

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

3.3.5 Effluent Radioactivity--Noble Gas Effluent from Condenser Air Removal System Exhaust Regulatory Guide 1.97 recommends instrumentation with a range of 10-6 to 10-2 uCi/cc for this variable. In Reference 5, the licensee provided information on the new detectors that were mounted in pipe wells in April 1984. The range of the instrument for Unit No.1 is 1.1 x 10~7 .

to 3.8 x 10~3uCi/cc. This range nectly meets the regulatory guide .

recommendation. The range for Unit No. 2 does cover the recommended .

range. The licensee states that additional radioactivity monitoring of '

this variable is provided in the combined delay duct and the auxiliary building exhaust stack.

We conclude that the range deviation for this instrumentation is minor when compared to the overall range and instrument accuracy. Based on this and the availability of tne alternate monitoring instrumentation, we find

- this instrumentation adequate to monitor this variable during post-accident conditions.

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LOCA/HELB since the safety injection accumulators are passive devices. The accumulator pressure instruments, which are qualified, are used to derive an equivalent accumulator water level.

The existing instrumentation is acceptable. An environmentally qualified instrument is necessary to monitor the status of these tanks.

• The licensee has designated pressure as the key variable to directly '

indicate accumulator discharge and provided instrumentation for that variable that meets the requirements of 10 CFR 50.49.

3 3,9 Accumulator Isolation Valve Position '

Regulatory Guide 1.97 recomends environmentally qualified instrumentation for this variable. The licensee has provided Category 3 instrumentation and states that this is adequate bect.use this valve is normally open with power administrativelj removed (i.e., breaker locked open) from the motor operator. Since the closing of this valve is not ,

required for accident mitigation, environmental qualification of the valve position indicator is not required. .

Based on the licensee's justification and the f act that this valve is open and does not change position during or followino an accident, we consider Category 3 instrumentation adequate for this variable.

3.3.10 Boric Acid Charging Flow Regulatory Guide 1.97 recomends Category 2 instrumentation to monitor this variable. The licensee states that Category 3 instrumentation is appropriate for tnis variable. The following justification was given by the licensee. The charging pumps are not used for mitigation of design-basis accidents. Therefore, environtnental qualification of the charging line flow instrument is not required. Boric acid is injected into ,

the RCS during LOCA/HELB accident conditions using the safety injection system, whicn has qualified flow instruments. l 10 ,

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i other panels have individual circuit breakers for each set of three heater elements. Troubleshooting and possible repair can be accomplished, on individual heater groups or power sources, from these power panels.

Based on the electrical bus anneters in the control room and the

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availability of the local power panels that can be checked if a malfunction is suspected, we conclude that the existing instrumentation to monitor this

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variable is acceptable. i 3.3.13 Quench Tank Temperature The licensee deviates from the range reconnended in Regulatory Guide 1.97 for this variable (50 to 750*F). The provided range is 0 to 300'F. The licensee's justification for this deviation is that the upper  :

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range limit (300*F) is close to the saturation temperature (338'F) for the tank design pressure and rupture disk relief pressure of 100 psig. The  !

licensee has connitted, in Reference 5, to change the range of this .

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instrument to 50 to 350*F.

The new range will cover the anticipated requirements for normal operation, anticipated operational occurrences and accident conditions.

This range relates to the tank's rupture disk and 100 psi tank design pressure that limits the temperature of the tank contents to saturated l steam conditions under 350*F. Thus, we find this deviation from the regulatory guide acceptable. l 3.3.14 Heat Removal by the Containment Fan Heat Removal System Regulatory Guide 1.97 recomends Category 2 instrumentation to monitor  !

this variable. The licensee's instrumentation is Category 2, except for environmental qualification. The licensee is not supplying environmentally ,

qualified instrumentatfon, indicating that this varfabic is used as backup .

instrumentation that is not within the scope of 10 CFR 50.49. The licensee ,

j also states that the arcomplishment of post-accident cooling is serified by .

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As these variables are not utilized at Point Beach in conjunction with a safety system, we find that the instrumentation provided is acceptable.

3.3.17 Component Cooling Water Temperature to Engineered Safety Feature (ESF) System Regulatory Guide 1.97, Revision 2 recommends a range of 32 to 200*F for this variable. The provided instrumentation has a range of 50 to 200*F. The justification provided by the licensee is that this value (50*F) is the lowest possible value expected for this variable. Therefore, this range meets the intent of Regulatory Guide 1.97 and is adequate for monitoring system operation.

Based on the licensee's statement that the instrumentation will remain on scale for any anticipated event, we find that the range is acceptable.

3.3.18 Radioactive Gas Holdup Tank Pressure .

Regulatory Guide 1.97 recommends a range for this variable to cover 0 to 150 percent of the design pressure. The instrumentation provided has a range of 0 to 100 percent of design pressure (0 to 150 psig).

The licensee states that the tanks are designed for 150 psig. The.

tanks are never operated near this design rating as the system switches to a standby tank at 95 psig and an alarm alerts the operator of overpressure at 112 psig.

The licensee states that the range of 0 to 150 psig covers the anticipated requirements for normal operation, anticipated operational occurrences and accident conditions. Based on this, we find the deviation from the recommended range acceptable.

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3.3.19 Emergincy Ventilation Damper Position Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. In Reference 5, the licensee states that environmental

. qualification is not requi.ed for these position indicators because they are located in a mild environment and are not within the scope of 10 CFR 50.49.

. Seismic qualification of these damper position indicators is planned to be addressed in accordance with the response to unresolved safety issue A-46, " Seismic Qualification of Equipment in Operating Reactors."

Therefore, seismic qualification is beyond the scope of this review, and J

will be reviewed by the NRC as part of their review of unresolved safety issue A-46. .

3.3.20 Radiation Exposure Rate (inside buildings or areas where access is required to service equipment important to safety)

The licensee has provided area radiation instrumentation with various ranges. Some do not have the range recomended by Regulatory Guide 1.97 (10'I to 104 R/hr). The licensee's justification for this deviation is that the existing ranges are based on expected post-accident radiation dose rates. Two overlapping detectors are used where required to cover the entire expected range.

The ranges of the existing instrumentation are adequate. The areas where high radiation levels would be expected post-accident have both high and low range instruments. These overlapping instruments cover the range recomended by Regulatory Guide 1.97. Therefore, we consider this deviation from Regulatory Guide 1.97 acceptable.

, Exception is also taken to the environmental qualification recommended by Regulatory Guide 1.97 for this instrumentation. The licensee's

, , justification for this deviation is that portable survey meters are the 15 l

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to any high radiation area (i.e., >100 mR/hr) would be under tight administrative controls to preclude overexposure except in an emergency.

This instrumentation is portable and would not be used to assess levels of radiation greater than the range provided by the licensee.

Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

3.3.23 Estimation of Atmospheric Stability The licensee deviates from the temperature range (-9 to +18'F) that Regulatory Guide 1.97 recommends for this variable. The supplied range is

-10' to +10*F. The licensee states that this range is based on an autoconvective lapse rate of $7'F per 235 feet which is the maximum theoretical temperature gradient above which turbulent mixing occurs to equalize the temperatures.

. Table 1 of Regulatory Guide 1.23 (Reference 9) provides 7 vertical

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atmospheric stability classifications based on the difference in tenperature per 100 meter elevation change. These classifications cover from extremely unstable to extremely stable. Any temperature difference greater than +4*C or less than -2*C does nothing to the stability classification. The licensee's instrument accuracy is as specified in Regulatory Guide 1.97, the temperature range and the vertical separation are both greater than that recommended in Regulatory Guide 1.23.

Therefore, we find that this instrumentation is acceptable to determine the l atmospheric stability.

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3.3.24 Accident Sampling (primary coolant, containment air and sump)

The licensee deviates from the ranges recommended by Regulatory Guide 1.97 for the following variables:

a. Boron content--0 to 6000 ppm recommended, 20 to 6000 ppm is provided.

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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.

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This EG&G Idaho, Inc., report reviews the submittals for the Point Beach Nuclear Plant, Unit Nos. I and 2, and identifies areas of nonconformance to Regulatory Guide 1.97. Exceptions to these guidelines are evaluated.

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