ML19332B582

Conformance to Reg Guide 1.97:Millstone-2, Technical Evaluation Rept

ML19332B582
Person / Time
Site:	Millstone
Issue date:	09/30/1989
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML19332B583	List: ML19332B582
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-EA-6857, TAC-51107, NUDOCS 8909260388
Download: ML19332B582 (27)

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_ EGG-EA-6857 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97: MILLSTONE-2 Docket No. 50-336 Alan C. Udy Published September 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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SUMMARY

This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97, Revision 2, for Unit No. 2 of the Millstone Nuclear Power Station. Exceptions to and deviations from Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not i provided are identified.

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B&R No. 20-19-10-11 3 FIN No. A6483 Docket No. 50 336 TAC No. 51107 l

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PREFACE 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 Systems Technology, by EG&G Idaho, Inc., Regulatory and

-Technical Assistance Unit. ,

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CONTENTS  :,

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SUMMARY

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PREFACE ............................................................... iii

1. INTRODUCTION ..................................................... 1-

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- 2. REvlEw REoVIREnENTs .............................................. 2  :

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i 3.. EVALUATION ....................................................... 4 L 3.1 Adherence to Regul atory Guide 1.97 . . . . . . . . . . . . . . . . . . . . . . . . . 4

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3.2 Type A Variables ........................................... 4 3.3 Exceptions to Regul atory Guide 1.97 . . . . . . . . . . . . . . . . . . . . . . . . 5

4. CONCLUSIONS ...................................................... 20  ;

5. REFERENCES ....................................................... 22 i

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CONFORMANCE TO REGULATORY GUIDE 1.97: MILLSTONE-2

1. INTRODUCTION I >

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, "TM1 Action Plan Requirements" (Reference 3).

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Northeast Utilities, the licensee for Unit 2 of the Millstone Nuclear -

Power Station, provided a response to the generic letter on April 15, 1983 (Reference 4). The response to Section 6.2 of the generic letter was submitted on February 29, 1984 (Reference 5), and revised on April 9, 1984

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(Reference 6). Additional information was provided on August 7, 1986 (Reference 7), June 15, 1987 (Reference 8), and June 20, 1988 (Reference 9). ,

This report is based on the recommendations of Regulatory Guide 1.97, Revision 2, and compares the instrumentation proposed by the licensee's submittals with these recommendations, i

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1. REVIEW REQUIREMENTS ,

Section 6.2 of NUREG-0737, Supplement No. 1, sets forth the documentation to be submitted in a report to the NRC describing how the ,

licensee complies with Regulatory Guide 1.97 as applied to emergency i response facilities. The submittals should i;,' de documentation that-provides the following information for each variable shown in the applicable table of Regulatory Guide 1.97.

1. instrument range

2. environmental qualification i

3. seismic qualification

4. quality assurance

5. redundance and sensor location

6. power supply l 7. location of display 1'

l 8. schedule of installation or upgrade l- The submittals should identify any deviations from the recommendations of Regulatory Guide 1.97 and should provide supporting justification or alternatives for the deviations identified.

Subsequent to the issuance of Generic Letter 82-33, the NRC held regional meetings in February and March, 1983, to answer licensee and I l applicant questions and concerns regarding the NRC policy on this subject.

l At these meetings, it was noted that the NRC review would address only exceptions taken to Regulatory Guide 1.97. It was also noted that, when licensees or applicants explicitly state that instrument systems conform to l

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the regulatory guide, no further staff review wculd be necessary.  ;

Therefore, this report addresses only those exceptions to Regulatory  ;

i Guide 1.97 that have been identified by the licensee. The following i'- evaluation of. the licensee's submittals is based on the review policy !

described in the NRC regional meetings.

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3. EVALUATION

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The licensee provided a response to item 6.2 of NRC Generic Letter 82-33 on February 29, 1984. This was revised on April 9, 1984. The I response describes the licensee's position on post accident monitoring instrumentation. This evaluation is based on the April 9,1984 submittal, en Revision 2 of Regulatory Guide 1.97 and on the additional information provided on August 7,1986, June 15,1987, and June 20, 1988.

3.1 Adherence to Reoulatory Guide 1.97 The licensee has provided a review of their post-accident nionitoring -

instrumentation that compares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 2. The licensee states that in several instances, satisfactory instruinentation already -

exists and also that additional instrumentation will be installed to comply with the provisions of Regulatory Guide 1.97, except for those instances where deviations are justified. In Reference 7, the licensee states that <

all those identified modifications were completed by December 31, 1985.

Therefore, we conclude th6t the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3.

3.2 Tvoe 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. pressurizer level

2. pressurizer pressure

3. reactor coolant system (RCS) hot leg water temperature 4

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5. steam generator pressure l l

6.. steam generator level I l

7. auxiliary feedwater flow ]

8. containment pressure i

9. degrees of subcooling I i

l 10, containment hydrogen concentration ll, containment radiation The above instrumentation meets the Category I recommendations consistent j

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with the requirements for Type A variables, with those exceptions listed in Section 3.3.

3.3 Exceotions to Rfoulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.

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3.3.1 Environmental Oualification In the licensee's submittals, the following Category 2 variables were listed as not having environmentally qualified instrumentation. The justification listed below is taken from References 7, 8, and 9.

c. Containment sump water level -- Narrow range - The licensee states that this instrumentation is used only for normal operation. The sump is small (approximately 1000 gallons), and I would fill quickly following an accident. The sump contents would l- 5 L

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not be transferred outside containment. This is to prevent the transferring of contaminated water outside of the containment.

The environmentally qualified wice range instrumentation is r recorded and is used post accident. Based on this, we find the provided instrumentation acceptable.

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b. Residual heat removal (RHR) system flow - The licensee states

/ that the failure of this instrumentation does not cause non-operability of the system. All system valves are

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prepositioned. The licensee uses the pump motor current (located in a mild environment) as backup instrumentation. Surveillance testing assures system availability prior to an accident. Normal RHR system operation would indicate 20 amperes on a 100 ampere scale. This is not acceptable, because current is not a direct indication of flow (pipe rupture or flow blockage could occur).

The licensee has not shown evidence of a correlation between pump motor current and pump flow under adverse conditions.

Environmentally qualified flow instrumentation should be provided.

4 y c. RHR heat exchanger outlet temperature -- The licensee states that environmental qualification for this instrumentation is not needed because this temperature can also be trended by the reactor coolant temperature. The licensee states that surveillance testing and valve lineup checks assure operation of the RHR system prior to an accident. We find this justification inadequate, since sources of coolant other than the RHR could also be cooling the core, and the reactor coolant temperature would not necessarily be usable in determining the quantity of heat removed by the RHR heat exchanger. This instrumentation should be-environmentally qualified,

d. Accumulator tank level and pressure -- The licensee states that

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this instrumentation is less important after an accident than L during normal operation. The licensee states that 20 seconds after a large break accident, the accumulators would be empty. I 1

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The licensee states that this instrumentation is for readout only, '

i.e., the system is passive and functions automatically early in the accident sequence. The licensee states that no automatic functions or operator actions are based on this instrumentation.

We find this'~ justification unacceptable. An environmentally  !

qualified ir.strument is necessary to monitor the status of these ,

tanks, to determine whether discharge has occurred, and to help evaluate the extent of the accident. The licensee should designate'either level or pressure as the key variable to directly indicate accumulator discharge and provide instrumentation for ,

that variable that meets the requirements of 10 CFR 50.49.

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e. High pressure injection system flow - The licensee states that the failure of this instrumentation does not cause non-operability

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of the systera. All system valves are prepositioned. The licensee uses the pump motor current (located in a mild environment) as backup instrumentation. Surveillance testing assures system

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availability prior to an accident. Normal system operation is '

said to indicate 20 amperes on a 100 ampere scale. This is not acceptable, because current is not a direct indication of flow (pipe rupture or flow blockage could occur). The licensee has not shown evidence of a correlation between pump motor current and pump flow under adverse conditions. Environmentally qualified flow instrumentation should be provided,

f. Low pressure injection system flow -- The licensee states that the y failure of this instrumentation does not cause non-operability of the system. All system valves are prepositioned. The licensee uses the pump motor current (located in a mild environment) as backup instrumentation. Surveillance testing assures system availability prior to an accident. Normal system operation is said to indicate 20 amperes on a 100 ampere scale. This is not acceptable, becaust current is not a direct indication of flow (pipe rupture or flow blockage could occur). The licensee 7

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' has not shown evidence of a correlation between pump motor current and pump flow under adverse conditions. Environmentally qualified flow instrumentation should be provided.

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g. Containment spray flow -- The licensee states that the failure of this instrumentation does not cause non-operability of the l system. All system valves are prepositioned. The licensee uses 3

, the pump motor current (located in a mild environment) as backup instrumentation. Surveillance testing assures system availability r

. prior to an accident. Normal system operation is said to indicate

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20 amperes on a 100 ampere scale. This is not acceptable, because current is not a direct indication of flow (pipe rupture or flow blockags could occur). The' licensee has not shown evidence of a ,

correlation between pump motor current and pump flow under adverse conditions. Environmentally qualified flow instrumentation should be provided. [

h. Containment atmosphere temperature -- The licensee states that this instrumentation is used only for diagnostic purposes, and that the key variable for monitoring containment conditions is containment pressure, which is measured by Category 1

• instrumentation. Containment atmosphere temperature is a backup for containment accident monitoring. Based on the licensee's justification, we find the application of Category 3 backup instrumentation is in accordance with the regulatory guide.

i. Makeup flow in -- The licensee states that the Category 3 charging system pressure instrumentation can be used to supplement the l makeup flow instrumentation. Additionally, the charging pumps are positive displacement. Each pump motor has operation indicated.

When operating, each pump pumps 44 gallons per minute. We find

this instrumentation in conjunction with positive displacement pumps acceptable for post-accident monitoring instrumentation.

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J. Letdown flow-out -- The licensee states that the pressurizer level

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or the differential pressure across the letdown filter can be used

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s to backup this instrumentation. No details on this instrumentation (i.e., qualification, power source, range, or how it is used) was provided. We find the justification provided fcr this deviation unacceptable. Environmentally qualified instrumentation should be provided for this variable.

k. Volume control tank level -- The licensee states that this tank is isolated by a safety injection actuation signal. As this tank is not utilized in conjunction with a safety-system, we find the I

instrumentation provided acceptable.

1. Component cooling water (CCW) temperature to ESF system -- The licensee states that the reactor building component cooling water (RBCCW) temperature instrumentation has no safety function. The licensee states that surveillance testing assures system I availability prior to an accident. We find this justification' inadequate and unacceptable. The licensee should provide environmentally qualified instrumentation to verify the proper operation of the RBCCW system (see also Section 3.3.17).  :

m. Component cooling water flow to ESF system -- The licensee states that failure of this instrumentation does not cause non-operability of the system. All system valves are prepositioned. The licensee uses the pump motor current (located

.- in a mild environment) as backup instrumentation. Surveillance testing assures system availability prior to an accident. Normal system operation is said to indicate 40 amperes on a 100 ampere scale. This is not acceptable, because current is not a direct l_ indication of flow (pipe rupture or flow blockage could occur).

The licensee has not shown evidence of a correlation between pump l

motor current and pump flow under adverse conditions.

l Environmentally qualified flow instrumentation should be provided.

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e n. Status of standby power -- The licensee states that this instrumentation is located in a mild environment. We find this instrumentation acceptable.

1 p o. Containment isolation valve position - The licensee stotes I (Reference 8) that seven containment isolation valves (each located outside containment) will be qualified to a more severe  !

environment than originally required. These valves, 2CH 198, j 2AC 47, 12 and 15, 2EB-92 and 99 and 2 SSP-16.2, will be upgradd during the January-March 1988 refueling outage. This change will bring full compliance with this variable. i

( Environmental qualification is clarified by the Environmental l Qualification Rule, 10 CFR 50.49. The licensee should provide 3 l instrumentation that is environmentally qualified in accordance with the l provisions of 10 CFR 50.49 and Regulatory Guide 1.97 for the variables RHR  ;

system flow, RHR heat exchanger outlet temperature, accumulator tank level l or pressure, high pressure injection system flow, low pressure injection  ;

system flow, containment spray flow, ietdown flow-out, CCW temperature to j i

ESF system and CCW flow to ESF system, i 3.3.2 Reactor Coolant System (RCS) Soluble Boron Concentration

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i The range of the instrumentation supplied by the licensee for this variable'is zero to 2050 parts per million. The range recommended in the regulatory guide is zero to 6000 parts per million. The licensee's

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justification for this deviation from the recommended range is that the ,

boron concentration is not expected to exceed the technical specification limit of 1720 parts per million, and that if a higher range is needed, the post-accident sampling system can be used.

The licensee takes exception to Regulatory Guide 1.97 with respect to post-accident sampling capability. This exception goes 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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, l l3.3.31 RCS Cold Leo Water Temoertture t.

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Regulatory Guide l'.97. recommends redundant instrumentation for this- l

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variable with _ a range .from 50'F to 750'F. The licensee has supplied-one wide range channel for each cold leg, with a range from zero to 600*F.

1 The licensee'ident'ifies one wide range temperature instrument in each of the hot legs and' cold legs. Millstone Unit 2 is a two loop unit. Thus, there is redundancy in that the coolant temperature delivered to the core and-leaving.the reactor is measured by independent instruments. The ,

' licensee verified (Reference 7) that each channel of instrumentation,

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including power supplies, is independent and redundant.

The licensee states.the for all design basis accident scenarios, the ,,

range of zero to 600'F i; & luate to monitor the cold leg fluid

-temperature. Based on ti <tatement, we find the existing range  !

acceptable.

3 . .'. 4 RCS Hot Lea Wa: femoerature Regulatory Guide 1.97 recommends redundant instrumentation for this variable with a range from 50*F to 750*F. The licensee has supplied one wide range channel for each hot leg, with a range from 150'F to

-750'F.

The licensee identifies one wide range temperature instrument in each of the hot legs and cold legs. Millstone Unit 2 is a two loop unit. Thus there is redundancy in that the coolant temperature delivered to the core and leaving the reactor is measured by independent instruments. The licensee verified (Reference 7) that each channel of instrumentation, l

including power supplies, is independent and redundant.

The licensee states that 212*F is the saturation temperature at atmospheric pressure, and therefore the 150*F lower range provides

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situation in'the event-of a loss of shutdown cooling. In addition, the RCS cold;1eg water temperature and the residual heat removal (RHR) heat exchanger outlet temperature are measured down to zero. Therefore, this deviation in'the lower limit of the range for this variable is-acceptable.

3.3.5 RCS Pressure Regulatory Guide 1.97 recommends Category 1 instrumentation with a range from zero to 4000 psig for this Combustion Engineering unit. The licensee has supplied instrumentation for this unit as follows:

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. Redundant, Category 1, zero to 1600 psig channels

. Redundant, Category 1, 1500 to 2500 psig channels  !

. 0ne zero to 3000 psig channel that is not Category 1 1

The redundant ranges overlap such that redundancy is provided from j zero to 2500 psig. . The licensee states that the upper range of 3000 psig is adequate for all. design basis events. The primary safety relief valves .!

limit the RCS pressure to 2500 psig following the initial pressure j increase. The licensee states that any pressure excursions above 2500 psig would be short.

The pressure range of zero to 3000 psig is adequate to monitor all expected pressures based on the iicensee's design basis event analysis. The licensee commits (Reference 7) to upgrade these instrument channels in accordance with the resolution of the anticipated transient without scram L (ATWS) issue. We find this commitment acceptable.

3.3.6 [oolant level in Reactor Revision 2 of Regulatory Guide 1.97 recommends instrumentation for this I variable with a range from the bottom of the core to the top of the vessel.

The licensee is supplying instrumentation with a range from the top of the l

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core to the top of the vessel and notes that it deviates from the recommendation of Revision 2 of the regulatory guide. This is acceptable, i

-as it exceeds the range-recommended by Revision 3 (Reference 10) of the regulatory guide (bottom of the hot leg to the top of the vessel),

m 3.3.7 Containment Sumo Water level

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Regulatory Guide 1.97 recommends. measuring the sump level with wide range instruments up to the height equivalent to 600,000 gallons. The

. licensee has' instrumentation for this variable that measures from -22 feet 6 inches to -15 feet 5 inches. This is equivalent to.565,000 gallons.

I The licensee refers to a previous letter (Reference 11) where it was

.shown that the maximum post-accident containment water volume will not exceed 563,800 gallons. As the range exceeds the maximum expected water 1 volume, we find this. deviation acceptable.

3.3.8 Radiation Level in Circulatina Primary Coolant The licensee states that the post-accident sampling system, which has been reviewed by the NRC as part of their review of NUREG-0737, Item II.B.3, can provide this information with an isolated nuclear steam supply system.

Based on the alternate instrumentation provided by the licensee, we L

l conclude that the instrumentation. supplied for this variable is adequate and acceptable.

3.3.9 Containment Hydroaen Concentration I

Regulatory Guide 1.97 recommends that this instrumentation remain l

functional for containment pressures from 5 psig to the maximum design L" pressure. The licensee states that the hydrogen analyzers are designed for l operation with a positive containment pressure up to 10 psig. Furthermore, they state that the containment will not see a negative pressure under any Final Safety Analysis Report (FSAR) analyzed accident condition.

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Reference 12 provides additional information. The containment ,

structure'is not of.subatmospheric design. Therefore, the atmospheric pressure will'be positive when the hydrogen monitoring instrumentation is used~in a post-accident situation.- The limit of 10 psig is because of the i particulate radiation' monitors that share the same sample lines. This I operational limit has been shown, by the licensee, to be acceptable because the hydrogen concentration instrumentation is not necessary until after the containment pressure has decayed to less than.10 psig, f

We find'this justification sound. Therefore, we find the provided instrumentation acceptable.

[ 3.3.10 Radiation Exoosure Rate The: licensee takes exception to the instrument range recommended by Regulatory Guide 1.97 (10-1 R/hr to 10 4 R/hr). Currently installed area radiation monitors cover a lesser range up'to 10 R/hr or 103 R/hr. The licensee's justification for this deviation is that the existing area radiation monitors provide for adequate employee protection, that these monitors can be augmented by portable monitors, and that these monitors do warn of changing or unusually high radiological conditions.

From a radiological standpoint, if the radiation levels reach or exceed the upper limit of the range, personnel would not be permitted to the areas except of life saving. We therefore find the proposed ranges for the radiation exposure rate monitors acceptable.

3.3.11 ' Accumulator Tank Pressure Regulatory Guide 1.97 recommends instrumentation with a range of zero to 750 psig for this variable. The range provided is zero to 250 psig. On the basis that the design pressure of the accumulaters is 250 psig, we find this deviation acceptable.

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-3~.3.12 Refuelina Water Storace Tank level

Regulatory Guide 1,97 recommends'instramentation with a range from the f

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top'to the bottom:for this-ver f.,le. The range of the instrumentation! a supplied by the licensee is from 4.3 percent to 100" percent. At 4.3 percent,'the tank is. essentially empty. Therefore, this is an acceptable deviation from Regulatory Guide 1.97. l

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-3.3.13 Pressurizer Heater Status Y Regulatory Guide 1.97 recommends Category 2 electric current

-instrumentation for this variable. The licensee has identified circuit' 7

• breaker position indication for this variable. The licensee states (Reference 7) that the lack of this-instrumentation will be addressed as part-of the human engineering discrepancy program, with final resolution

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. .information to be submitted'by October, 1986. The licensee states

'(Reference 8) the: intent to . instal'l' current meters for the proportionally [

controlled < heaters. The licensee states (Reference 9) that this  ;

modification has been scheduled as'part of the control room design review d corrections. We find the added instrumentation acceptable for this i variable.

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3.3.14 Ouench Tank level L

L Regulatory Guide 1.97 recommends instrumentation for this vr.riable with

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a range from the top to the bottom of the tank. The tank is a horizontal cylindrical tank with an outside diameter of 60 inches. The licensee's instrumentation measures the level for 20 inches on each side of the centerline of the tank. We calculate that this range covers approximately 9

74 percent of the tank volume.

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The licensee states that the existing range will adequately cover any

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anticipated event except for an uncontrolled or continuous safety / relief l valve discharge. Such a discharge will cause the tank rupture disk to l rupture, venting the tank contents to containment. Based on this, we find 1

this instrumentation adequate. Therefore, this deviation is acceptable.

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.3.3.15 .0uench Tank Temoerature Regulatory Guide 1.97 recommends instrumentation for this variable with

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m a range from 50*F to 750*F. The licensee has provided

\.y instrumentation-for this variable with a range of zero to 300*F.

h .The licensee states that the range of zero to 300'F is sufficient 2 to monitor normal and design basis accident scenarios. Based on this

' justification, we find this deviation acceptable. i 3.3.16 SteamGeneratorliyd Regulatory Guide 1.97 recommends instrumentation with a range from the  ;

.! tube sheet to the separators for this variable. The licensee has provided

-instrumentation with a range from the top of the tube bundles to the y separi. tor: . Thus, the length of the tube bundles is not measured. The-

,~ licensee (Reference 7) i_ndicates that this deviation will be addressed as part of the human engineering discrepancy (HEO) program, with final <

resol'ution information to be submitted by October,' 1986. .in Reference 8, the licensee defers resolution of this variable to the end of the 1991

-refueling outage. The licensee repeats this stand.in Reference 9. The licensee'is anticipating a decision on replacing the steam generators,  !

Should the steam generators be replaced, the licensee will include wide range:1evel indication. Should the licensee decide not to replace the steam generators, there is no commitment to provide the wide range level indication.

The licensee states that there are no instrument taps to allow a direct wide range steam generator level measurement. The auxiliary feedwater (system is automatically initiated on a low level signal and is of sufficient capacity to restore the level to normal conditions even with a single failure. The main feedwater pumps can be manually ramped back to 5 percent flow to accomplish this also. Primary side temperature and pressure and main and auxiliary feedwater flow rates are available to verify the secondary side availability as a heat sink. Additionally, the 16

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E 9, -licensee states that there is sufficient inventory to maintain an adequate heat sink with no feedwater flow for 22 minutes. Based on this alternate-instrumentation and the low probability of -an accident at Millstone 2, we find that continued operation until wide range channels are installed is

-acceptable. However,- not having an installation schedule is not acceptable.

Deferring a decision committing to install this instrumentation to 1991 is unacceptable. 'The licensee should commit to install. the recommended instrumentation and taps should tha decision be not to replace the steam

, generators in the_near term.

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3.3.17 Heat' Removal by the Containment Fan Heat Removal System .

.i Regulatory Guide 1.97 recommends plant specific Category 2 instrumentation for this variable. The. licensee (Reference 9) describes the  ;

instrumentation available to monitor the containment air recirculation and cooling system (CARCS). Temperature (zero to 200'F) is monitored at the  !

/ inlet and the outlet of the cooling water (reactor buildup closed cooling water system) heat exchangers that are part of the CARCS. The flow from the fan blowers _is also monitored. We find that the instrumentation provided would provide satisfactory indication for this variable if it was environmentally qualified. Environmental qualification is the only

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Cate W y 2 recommendation not met by this instrumentation.

The licensee states that redundancy in design (only 3 out of 4 units are needed following a LOCA), surveillance testing, valve position verification, and th'e Category I containment pressure instrumentation are adequate to assure system operation.

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L However, the containment pressure instrumentation cannot distinguish between the containment spray system operation and CARCS operation. The l system testing and verification will assure a state of system readiness, but cannot show proper system operation under accident conditions. Therefore, the instrumentation for this variable should be environmentally qualified in accordance with 10 CFR 50.49 and Regulatory Guide 1.97.

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3.3.18 Containment Atmosohere Temoerature i

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Regulatory Guide 1.97 recommends instrumentation for this variable with' a range from 40*F to 400'F. The licensee has instrumentation for j this variable with a range of zero .to 350'F. ,

The licensee's justification for this deviation is that the maximum

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predicted containment temperature is less than 300'F. Based on this justification, we find the range supplied by the licensee for post-accident monitoring acceptable.

3.3.19 Containment Sumo Water Temoerature Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range from 50*F to 250*F. The licensee has no f . instrumentation for this variable saying it is not considered a part of the

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post-accident monitoring system, that it serves no safety function, and that an adequate net positive suction head exists for the high pressure safety injection pumps in the recirculation mode.

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 (such as the residual heat removal heat exchanger inlet temperature) that satisfy the regulatory guide.

3.3.20 Radioactive Gas Holduo Tank Pressure l Regulatory Guide 1.97 recommends instrumentation for this variable with I- .a range from zero to 150 percent of design pressure. The licensee has local instrumentation for this variable as the system is operated locally. There are no controls in the control room, only a common alarm. A surge tank (de:ign pressure of 20 psig) has instrumentation that reads from zero to 25 psig.

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The surge tank contents are compressed and stored in one of six waste-decay tanks when the surge tank reaches 3 psig. The waste decay tanks have-a design pressure of 165 psig; they are monitored by instrumentation with a range of zero to'200 psig. The tank pressure is limited by the capability l of the' compressor.. While the instrumentation range is to only 121 percent of design pressure, we find the overrange. sufficient for this application.

.We find this instrumentation acceptable, ,

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2 6 3.3.21 Accident Samolino (Primary Coolant. Containment Air and Sumo)

The licensee's post-accident sampling system provides sampling and -

analysis as recommended by the regulatory guide, except.that it does not have'the capability to analyze for dissolved oxygen.

The licensee takes exception to Regulatory Guide 1.97 with respect to  ;

post-accident sampling. capability. This exception goes 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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1. 4. CONCLUSIONS

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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: '

l. RHR system flow -- The licensee should provide instrumentation for this variable that is environmentally. qualified.in accordance l with 10.CFR 50.49 and with Regulatory Guide 1.97.

('Section3.3.lb) 2.- RHR heat exchanger. outlet. temperature -- The licensee should provide instrumentation for this variable that is environmentally qualified in accordance with 10 CFR 50.49 and with Regulatory Guide l.97. (Section 3.3.lc)~ <

.3. Accumulator' tank level and pressure -- The licensee should provide instrumentation for either level or pressure that is environmentally qualified in accordance with 10 CFR 50.49 and with-

.

Regulatory Guide 1.97. (Section 3.3.ld)

4. . High pressure injection system flow -- The licensee should provide instrumentation for this variable that is environmentally qualified in accordance with 10 CFR 50.49 and with Regulatory Guide 1.97. (Section 3.3.le)

5. Low pressure injection system flow -- The licensee should provide

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instrumentation for this variable that is environmentally qualified in accordance with 10 CFR 50.49 and with Regulatory Guide 1.97. (Section 3.3.lf)

6. Contaminant spray flow -- The licensee should provide instrumentation for this variable that is environmentally  :

qualified in accordance with 10 CFR 50.49 and with Regulatory Guide 1.97. (Section3.3.lg) 20 l w

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7. Letdown flow out - The li_censee should provide instrumentation

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for this variable that is environmentally qualified in accordance with 10 CFR 50.49 and with Regulatory Guide 1.97.

.(Section3.3.lj) ,

8. Component cooling water temperature to ESF system -- The licensee should provide instrumentation for this variable that is environmentally qualified in accordance with 10 CFR 50.49 and with.

Regulatory Guide 1.97. (Section 3.3.11)

9. Component cooling water flow to ESF syste:n -- The licensee should provide instrumentation for this variable that is environmentally q qualified in accordance with 10 CFR 50.49 and with Regulatory Guide 1.97.-(Section3.3.1m): I

10. - Steam generator level -- The licensee should commit to provide the ,

reconnended instrumentation regardless of steam generator '

replacement.: (Section 3.3.16)

11. Heat removal by the containment fan heat removal system -- The

-licensee should provide instrumentation for thi: variable that is environmentally qualified in accordance with 10 CFR 50.49 and with 4 Regulatory Guide 1.97. (Section 3.3.17) )

12. Containment sump water temperature -- The licensee should either provide instrumentation for this variable or identify appropriate l alternative instrumentation. (Section 3.3.19)

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5. REFERENCES i>

L 1.

!

Letter,.NRC (D. G. Eisenhut) to All Licensees of Operating Reactors, j l

Applicants for Operating Licenses, ano Holders of Construction Permits,  !

L

" Supplement No.~1 to NUREG-0737--Requiroments for Emergency Response  !

l Capability (Generic Letter No. 82-33)," Decembcr 17, 1982.

! 2.

!

Instrumentation for Licht-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durino and Followino an Accident, Regulatory Guide 1.97, Revision 2 NRC, Office of Standards- i

,

Development, December 1980. I i

3. I

! Clarification of TMI Action Plan Recuirements. _ Recuirements for Emeroency Resoonse Canability, NUREG 0737, Supplement No. 1, NRC, j

Office of Nuclear Reactor Regulation, January 1983. )

i- l 4.

Letter, Northeast Utilities (W..G. Counsel) to NRC (D. G. Eisenhut),

" Requirements for Emergency Response Capability (Generic Letter L

.

No. 82-33)," April 15, 1983, A02959. i 5.

i Letter, Northeast Utilities (W. G. Counsel) to NRC, " Supplement I to i NUREG-0737, Revision 2 to Regulatory Guide 1.97," February 29, 1984, l

A02959.

t

6. )

j Letter, Northeast Utilities (W. G. Counsel) to NRC, " Supplement 1 to NUREG-0737, Revision 2 to Regulatory Guide 1.97," April 9,1984, A02959.

7. Letter, Northeast Utilities (J. F. Opeka) to NRC, " Supplement I to

HUREG-0737,- Revision 2 to Regulatory Guide 1.97," August 7, 1986,

,

A04770/A02959. ,

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8. Letter, Northeast Utilities (E. J. Mroczka) to NRC, " Supplement 1 to NUREG-0737, Revision 2 to Regulatory Guide 1.97," June 15,1987, A04770, A02959.

9.

Letter, Northeast titilities (E. J. Mrotzka) to NRC, " Supplement 1 to

.

NUREG-0737," June 20, 1988, A04770, A02959.

10.

Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess l Plant and Environs Conditions Durino and Followino an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.

11. 1 Letter, Northeast Utilities (W G. Counsel) to NRC (R. A. Clark),

"NUREG-0737 1983, B10717. Item II.F.1.5, Containment Water level Monitor," March 8,

!

l 12.

Letter, Northeast Utilities (W. G. Counsel) to NRC, "TMI Action Item II.F.1.6, Containment Hydrogen Monitor," March 27, 1984, B11073.

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NRC #0pt JW ' U.S. NUCLEAR REGULATOQY COtabel8810N l. WEPORY NUMBEQ

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. beg L*"!ll1l1l*.Sl2,%T""-

voi.no i SIBUOGRAPHIC DATA SHEET 1

rsn i=r,ver .a ra , EGG-EA-6857 2.VITLE AND SV6 TITLE

'CONFORMANCE TO-REGULATORY GUIDE 1.97: MILLSTONE-2 y o,7ERE,oR,,0 tis,Eo

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woe ...a 4

l g September 1989

4. FIN OR GR ANT NurtE R A6483

• _ 6. AUTHORI$) 6. TYPE OF REPORT a Alan C. Udy Technical Evaluation J

! Report I

7. PE RICO COVERED esace.w 0. s

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. .,1 l s.gp3R gNIZ AT TON - N AME AND ADD R ES$ t,, sac p,,ve Ommoa. O,,.se e, A.pma. u.& murmer Aapes.e,y Commessa, and mas,.ay asemesc s, seawarm,. prove L Regulatory and Technical Assistance L EGAG-Idaho, Inc.

P. O. Box 1625 Idaho Falls ID 83415 rse "seme a asen". ,# esarserm,. a, ewer mac 0.vessa, ormi.Yassen, va av.ms, monumway commessa

9. .amm S. PONS.ORI.NG .ma OR G ant 2 ATION - N AME AND ADDRESS ts, **c.

Division of Systems Technology Office of Nuclear Reactor Regulation .l U.S. Nuclear Regulatory Commission '

Washington, DC 20555 lo. 5UPPLEMENT ARY NOTES

11. A8STR ACT tmo neen e,esas J This EG&G Idaho, Inc., report documents the review of the Regulatory Guide 1.97, Revision 2, submittals for the Unit 2 of the Millstone Nuclear 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 I not provided are identified. I i

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15. NvwSER OF PAGES

16. PRICli i

teNC POmu 333 (2496

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