ML20136G142

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Conformance to Reg Guide 1.97,Crystal River,Unit 3
ML20136G142
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 05/31/1985
From: Stoffel J
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML20136G144 List:
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-51083, NUDOCS 8507080402
Download: ML20136G142 (21)
v • d • e


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9 CONFORMANCE TO REGULATORY GUIDE 1.97 CRYSTAL RIVER, UNIT NO. 3 -

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J. W. Stoffel Published May 1985 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 '

Prepared for the U.S.. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761001570 FIN No. A6483 y(g~ .

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ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97 for Unit No. 3 of the Crystal River Station and identifies areas of nonconformance to the regulatory guide. Exceptions to Regulatory I

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

FOREWORD This report is supplied as part of the " Program for Evaluating Licensee / Applicant Conformance to R.G.1.97," being conducted for the U.S.

Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Systems Integration, by EG&G Idaho, Inc., NRC Licensing Support Section.

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

I Docket No. 50-302 TAC No. 51083 __

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CONTENTS l ABSTRACT .............................................................. 11-FOREWORD .............................................................. 11 l

1. INTRODUCTION ..................................................... 1 REVIEW REQUIREMENTS ..............................................
2. 2
3. EVALUATION ....................................................... 4 3.1 Adherence to Regulatory Guide 1.97 ...........:............. 4 ,

3.2 Type A Variables ........................................... 4 1

3:3 Exceptions to Regulatory Guide 1.97 ........................ 5

4. CONCLUSIONS ..................................................... 18 s
5. REFERENCES ...................................................... 19

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CONFORMANCE TO REGULATORY GUIDE 1.97 CRYSTAL RIVER, UNIT NO. 3

1. INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was -

issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and holders of construction permits. "This letter included additional clarification regarding Regulatory Guide 1.97, s, Revision 2 (Reference 2), relating to the requirements for emergency response capability. These requirements have been published as Supplement No. 1 to NUREG-0737, "TMI Action Plan Requirements" (Ref'erence 3).

Florida Power Corporation, the licensee for Crystal River, Unit No. 3, ,

provided a response on August 21, 1984 (Reference 4) containing the information required by Section 6.2 of the generic letter.

This report provides an evaluation of that submittal.

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

applicable table of Regulatory Guide 1.97.

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1. Instrument range
2. Environmental qualification
3. Seismic qualification
4. Quality assu'rance
5. Redundance and sensor location
6. Power supply
7. Location of display
8. Schedule of installation or upgrade Furthermore, 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. Furthermore, where licensees or applicants explicitly state that instrument systems conform to the regulatory guide, it was noted that no further staff review would be 2

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necessary. Therefore, this report only addresses exceptions to Regulatory Guide 1.97. The following evaluation is an audit of the licensee's submittal based on the review policy described in the NRC regional meetings.

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3. EVALUATION The licensee provided a response to Section 6.2 of the generic 1etter on August 21, 1984. This evaluation is based on that submittal.

3.1 Adherence to Regulatory Guide 1.97 The licensee included a schedule in their submittal that indicates that they will conform with the recommendations of Regulatory Guide 1.97, Revision 3 (Reference 5). Therefore, it is concluded that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97.

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Exceptfons to and deviations from the regulatory guide are'noted in Section 3.3.

3.2 Type A Variables Regulatory Guide 1.97 does not specifically identify Type A variables, i.e., those variables that provide information required to permit the control room operator to take specific manually controlled safety actions.

The licensee cl&ssifies the following instrumentation as Type A.

1. Reactor coolant system (RCS) hot leg water temperature
2. RCS pressure
3. Borated water storage tank level
4. Steam generator level
5. Steam generator pressure l

The above instrumentation meets Category 1 requirements consistent,with the requirements for Type A variables.

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

3.3.1 RCS Soluble Boron Concentration The licensee does not provide continuous control room monitoring for this variable. They state that manual sampling and laboratory analysis is sufficient based on the fact that the loss of negative r'eactivity due to xenon decay is sufficiently slow that the control room operator need not

%, know the boron concentration instantaneously or continuously.

The licensee takes exception to Regulatory Guide 1.97 with respect to this variable. This exception goes beyond the scope of this

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review and is being addressed by the NRC as part of their review of j NUREG-0737, Item II.B.3.

3.3.2 RCS Hot Leg Water Temoerature Regulatory Guide 1.97 recommends instrumentation with a range of 0 to 700*F for this variable. The licensee has supplied instrumentation with a range of 120 to 920*F. The licensee submitted the following justification for this deviation; (1) at temperatures less than 280*F, the ' plant will be .

in the decay heat removal mode and this temperature is not required, (2) cold shutdown is defined in the technical specification as less than 200*F, and.(3) RCS cold leg temperature range will indicate down to 50*F.

Ba:ed on the licensee's justification we find that the range of 120 to l .

920*F is acceptable.

3.3.3 RCS Cold Leg Water Temperature ,

Regulatory Guide 1.97 recommends Category 1 instrumentation with a range of 50 to 700*F for this variable. The licensee has supplied-Category 3 instrumentation with a range of 50 to 650*F. There are deviations in both range and category.

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The licensee's justification for Category 3 instrumentation is that the cold leg temperature may not provide valid information on the status of core cooling. It is located in the RCS loops and not the reactor vessel, so there must be either forced or natural circulation flow through the steam generators for the indication to be representative of actual core conditions. Also, the licensee states that due to the proximity of the cold leg RTOs to the high pressure injection (HPI) nozzles, HPI flow may -

significantly affect the cold leg temperature indication particularly in the absence of forced RCS flow. Incore temperature monitors provide a direct indication of core cooling independent of whether'or not there exists coolant ficw through the loops. For these reasons, the licensee has 1, designated the cold leg water temperature instrumentation backup instrumentation.

The licensee states that the key variables for monitoring the core cooling function are RCS hot leg water temperature, core exit temperature, and steam generat.or pressure. As the licensee has supplied Category 1 instrumentation for these variables, we find the Category 3 RCS cold leg water temocrature instrumentation acceptable.

The licensee's justification for the range deviation is based on providing the capability of the RCS cold water temperature instrumentation to measure a value greater than the saturation temperature for the steam generators, which is approximately 500*F (based on 1050 psig design pressure). 650*F for the high end of the range provides excess measurement capability and is approximately 110 percent of the design temperature of 600*F. Based on this justification, we find this deviation acceptable .

.3.3.4 Containment Isolation Valve Position

.From the information provided, we find the licensee deviates from a strict interpretation of the Category 1 redundancy recommendation. ,Only the active valves have position indication (i.e., check valves have no position indication). Since redundant isolation valves are provided, we find that redundant indication per valve is not intended by the regulatory 6

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f guide. Position indication of the check valves is specifically excluded by Table 3 of Regulatory Guide 1.97. Therefore, we find that the instrumentation for this variable is acceptable. , [

3.3.5 Radioactivity Concentration or Radiation Level in Circulating j Primary Coolant I

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The licensee states that the letdown line radiation monitors are used to provide indication of fuel failure during normal operation. The letdown i line is isolated during serious accidents requiring containment isolation, j

The primary means of monitoring this variable after containment isolation .

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t is by ,the post-accident sampling system.

) Based on the alternate instrumentation provided by the licensee, we l conclude that the instrumentation supplied for this variable is adequate.

l and therefore, acceptable. ,

3.3.6 Residual Heat Removal (RHR) Heat Exchanger Outlet Temoerature

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) The licensee has not ccmplied with the range recommended by the regulatory guide for this variable (40 to 350*F). The existing range is 0 to 300*F. The licensee states that the design temperature of the decay

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heat system and heat exchanger is 300*F.

i The licensee states that the RHR design temperature covers the i anticipated requirements for normal operation, anticipated operational  !

j occurrences and accident conditions. Based on this, we find that the range l l

1s adequate and that this deviation is acceptable. j l

3.3.7 Accumulator (Core Flood) Tank level and Pressure

The licensee has taken exception to providing Category 2 ,

! instrumentation for the accumulator tank pressure instrumentation and states that the key variable to determine whether the core flood tanks have fulfilled their safety function is core flood tank level. Therefore, core

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I flood tank pressure is designated a backup variable by the licensee and has 1

been classified as Category 3.

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, 1 The accumulators are passive devices. Their discharge into the  :

reactor coolant system (RCS) is actuated solely by a decrease in RCS j pressure. We find that the instrumentation provided for this variable is

, l adequate to determine that the accumulators have discharged. Therefore, j this instrumentation is acceptable for this variable.

3.3.8 - Boric Acid Charging Flow -

The licensee does not have instrumentation for this variable. The '

licensee states that the unit does not have boric acid charging flow as a safety injection system. High pressure injection flow, low pressure 5 injection flow and core flood tank level are the safety injection variables I monitored. Therefore, we find that this variable is not applicable at the [

Crystal River Station, f I

3.3.9 Refueling Water' Storage Tank level. l A range of 0 to 600 inches has been provided instead of the top to I bottom range recommended by the regulatory guide.

F At Crystal River 3, the tank level is monitored from 0 to 50 feet I (maximum fili). A low alarm is provided at 4 feet and switchover is required at 2.5 feet. Thus, the operator is provided with level indication f at all times.  !

l This deviation is minor with respect to the total volume of the tank.

The existing instrumentation is adequate to monitor the operation of the tank during all accident and post-accident conditions. Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

3.3.10 Pressurizer Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the top to the bottom of the pressurizer vessel. The licensee states that the reactor coolant system can experience a reactor '

trip from full power without uncovering the level sensors in the lower ,

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shell while maintaining system pressure above the HPI system actuation setpoint. The steam volume is such that the reactor coolant system can experience a turbine trip without covering the level sensors in the upper shell. The licensee states that the range of 0-320 inches was based on this criteria and setpoints for automatic or manual actions are based on this range.

The pressurizer is 512 inches tall. The zero reference for the range is 96 inches from the bottom, 16 inches below the upper set of heaters, and approximately at the level of the second set of heaters.' The upper pressurizer level is 92 inches from the top (approximately 37 inches from

( the spray head).

The licensee's analysis covers normal operation of the pressurizer (reactor trip or turbine trip). The licensee does not show that the range is adequate for all ani.icipated transient or accident conditions. The .

licensee should supply additional analyses to support this deviation.

3.3.11 Pressurizer Heater Status Regulatory Guide 1.97 recommends instrumentation to monitor the current drawn by the pressurizer heaters. The licensee's instrumentation

. consists of on/off indication of the redundant pressurizer heaters. The licensee indicates that the control of these heater banks is either on or off, and therefore, the instrumentation is appropriate.

Section II.E.3.1 of NUREG-0737 requires a number of the pressurizer heaters to have the capability of being powered by the emergency power sources. Instrumentation is to be provided to prevent overloading a diesel generator. Also, technical specifications are to be changed accordingly.

Th'e Standard Technical Specifications, Section 4.4.3.'2, require that the emergency pressurizer heater current be measured quarterly. These. heaters, as required by NUREG-0737, should have the current instrumentation recommended by Regulatory Guide 1.97.

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e 3.3.12 Quench Tank Temoerature Regulatory Guide 1.97 recommends instrumentation for this variable with a range.from 50 to 750*F. The instrumentation will have a range of 0 to 400F. The licensee states that quench tank is equipped with a rupture disc which blows at 110 psig. The corresponding saturation temperature is 345*F.

Since the rupture disc will preclude the tank temperature from exceeding 345'F, we find the licensee's range of 0 to 400*F acceptable.

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1, 3.3.13 Steam Generator pressure

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Regulatcry Guide 1.97 recommends instrumentation for this variable with a range from 0 to 20 percent above the lowest safety valve setting.

The lowest safety valve' setting is 1050 psig; therefore, the range should be from 0 to 1260 psig. The instrumentation for this variable has a range of 0 to 1200 psig, 9 percent above the highest safety valve setting of 1100 psig. The licensee states that the steam relief capacity is 20 to 25 percent above the expected steam flow rate and that excess relief capacity is maintained when safety valves are inoperable, and that the FSAR analysis indicates a maximum steam pressure of about 1100 psig.

Based on the licensee's justification listed above, the range of 0 to 1200 psig is acceptable for this variable.

3.3.14 Safety / Relief Valve positions or Main Steam Flow Regulatory Guide 1.97 recommends Category 2 instrumentation to monitor this variable. The licensee's submittal indicates that no instrumentation is installed to' read either valve position or main steam flow. The licensee evaluated their current practices for operating without th,is instrumentation under both anticipated transients and accident conditicns.

The conclusion was reached, by the licensee, that their current practices are adequate to meet NRC requirements for system monitoring and release asses: ment.

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We have reviewed the licensee's justification for this deviation and find it inadequate and conclude that the licensee should install Category 2 instrumentation that will monitor these valves or the main steam flow. ,

3.3.15 Containment Sump Water Temoerature Regulatory Guide 1.97 recommends Category 2 instrumentation for this-variable with a range of 50 to 250*F. The licensee does not have instrumentation for this variable. Their justification is that monitoring the sump temperature is not needed to assure that net positive suction head (NPSH) exists for the decay heat removal pumps and no automatic or manual

% actions are required to protect safety equipment, based on this temperature. Further, the licensee states that containment atmosphere temperature instrumentation provides the most direct indication of containment cooling system operation. In addition, other instrumentation is provided by the licensee to monitor the reactor building spray system ,

and reactor building emergency cooling system. The sump water temperature can be determined by the use of the icw pressure injection system in the recirculation mode.

We find this alternative instrumentation acceptable and adequate to monitor the containment cooling system operation.

3.3.16 Makeup Flow-In Letdown Flow-Out ,

Regulatory Guide 1.97 recommends Category 2 instrumentation for these variables. The licensee has classified this instrumentation as Category 3 for the following reasons:

1. During design basis events, the makeup and purification system l (MU&PS) is isolated. ,
2. During normal operation and certain design basis accidents where the MU&PS is still operable, the Category 2 makeup tank level is the key variable used to provide indication of proper MUtPS operation.

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3. Since the makeup tank is a surge volume for the RCS, makeup tank level and pressurizer level indications can be used to qualitatively assess makeup flow into the RCS and letdown flow from the RCS. .

Since pressurizer level instrumentation is Category 1 and makeup tank level instrumentation is Category 2, high quality instrumentation is -

available to provide information on the status and operation of the MU&PS.

The Category 3 makeup flow-in and letdown flow-out are considered as backup information. Therefore, this is an acceptable deviation' from Regulatory Guide 1.97. -

s 3.3.1/ Component Cooling Water Flow to ESF System The licensee has not provided Category 2 flow instrumentation in the control room for this variable. Local flow indication for these systems is available. Indicated flow measurements in the control room are not deemed necessary by the licensee because the Decay Heat Closed Cycle Cooling (DC) and Nuclear Services Closed Cycle Cooling (SW) systems surge tank levels provide system information to the operator. The wide range of design flows

. to various ESF components would not necessarily be representative of overall system performance according to the licensee. Service water header pressures and remote actuated valve positions are available to the operator along with the levels of the surge tanks. The licensee indicates that this provides better overall indication of system status.

We find the alternate instrumentation acceptable, provided the licensee verifies that it is Category 2 instrumentation.

3.3.18 Radioactive Gas Holdup Tank pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 150 percent of design pressure. The tank design pressure is 150 psig and the instrumentation range is 150 psig. The l

licensee states that the radioactive gas hold-up tanks are equipped-with relief valves which are set at 125 psig, and the range of the pressure

! indication is 120 percent above the relief valve setting.

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l The justification for the existing instrumentation for this variable i

is acceptable, as the pressure will not exceed the provided range. l 1 l

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i t 3.3.19 Emergency Ventilation Dameer position Regulatory Guide 1.97 recommends monitoring the open-closed status of i these dampers. The licensee states that emergency ventilation system -

,l dampers are controlled from the fan start circuitry and do not have 1 individual control switches. Redundant systems are provided so that a single failure will not defeat.their safety function. P'anel lights show l l

when the fan circuitry is operating. Back-up operational data are provided l

t g to operators by high quality commercial grade low flow and'high temperature (

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alarms.

Based on the licensee's alternate instrumentation and justification, i we find that the provii: led instrumentation is adequate to determine that the ,

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. ventilation system is operational. Therefore, this is an acceptable '.

deviation from Regulatory Guide 1.97.

j 3.3.20 Radiation Exposure Rate I

The licensee takes exception to the instrument range recommended by i

, Regulatory Guide 1.97 (10 -1 to 10 R/hr). Currently installed area 4

j radiation monitors cover the range of 0.01 to 10 R/hr. The licensee states f that detection of significant releases by area radiation exposure rate is

! secondary to that provided by the release path monitoring. Area radiation i levels inside the plant are monitored, to verify compliance with 10 CFR 20, i

by instruments that are considerably more sensitive (1000x) than required l by R.G.1.97 and are sufficient for supporting, as backup instrumentation, j

the detection of significant releases.

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{ Determination of accessibility of equipment for service or lor,ig term I surveillance is the function of health physics personnel, mostly using l portable instrumentation. Exposure rate instrumentation in areas outside l containment have an upper range of 10 R/hr, which the licensee states is

! adequate for initial assessments of accessibility.

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These ranges are based on background readings in the areas in which they are located. Should personnel entry be required in areas where these monitors have gone off scale or indicate a high radiation area, a health physics escort would accompany personnel into these areas using portable instrumentation to assess radiation levels. The licensee does not anticipate, even under emergency conditions, sending personnel into' radiation fields beyond the limits of this portable instrumentation.

From a radiological standpoint, if the radiation levels reach or exceed the upper limits of the range (10 R/hr), personnel would not be permitted access to the areas except for life saving. We therefore find the proposed range (0.01 to 10 R/hr) for the radiation exposure rate monitors acceptable.

3.3.21 Condenser Air Removal System Exhaust

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Regulatory Guide 1.97 recommends a range of 10 to 10 9C1/cc for this variable. The licensee has provided instrumentation with a range l of 2 x 10 -6 to 10 -2 uCi/ce. No justification was submitted for this range deviation.

The licensee should change the present range to that recommended by

. the regulatory guide or justify the existing range.

3.3.22 Noble Gas Vent from Steam Generator Safety Relief Valves or Atmosoheric Dump Valves Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The recommended parameters to be monitored for this variable are noble gas, duration of release in seconds and mass of steam per unit time.

In regard to this variable, the licensee states the following:.

1. The four 24 in, main steam headers each contain four relief valves. Additionally, there are 2 atmospheric dump valver. Each header is monitored for radiation by on-line monitors witn 14

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7 readouts in tne control room. The system range is 0.1 to 10 I

i mR/hr. There are plans to recalibrate the system for other source terms in uCi/cc in order to comply with NUREG-0737. . l

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! 2. There are no flow meters to determine the quantity of steam i venting to the atmosphere from the relief valves or the .

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  • l atmospheric dump valves and there are no position detectors to

! provide a status (open/ closed) indication of these valves.

1 i 3. This variable is only for a S.G. tube rupture accident. A harsh i environment does not result. Therefore, the sensors are 1

i l'- environmental qualified for their purpose. Also, these monitors  ;

I 4 are stated to be needed only very early in the event.  !

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i, We find this arrangement unacceptable for this variable. First, the (

licensee should verify that the range is adequate and that the instrumentation is Category 2. Second, the licensee should indicate how the duration of the release and the mass of steam per unit time is determined. Third, the licensee should show that the results derived from this method are within an acceptable tolerance from the actual release, 3.3.23 plant and Environs Radiation (Portable Instrumentation) t' The licensee takes exception to the range recommended by Regulatory .

~3 4 l Guide 1.97 for this variable (10 to 10 R/hr, photons). The range of the provided instrumentation is 10 ~3 to 10 R/hr. The licensee does 3

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not anticipate encountering radiation fields greater than those which can  !

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be measured yb' their equipment except under severe accident conditions.

I Even under accident conditions they do not anticipate sending individuals l 3

into greater than 10 R/hr fields, i l

This instrumentation is portable and would not be used to assess  ;

j levels of radiation greater than the range provided by the licensee. l Therefore, this is an acceptable deviation from Regulatory Guide 1.97.

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r 3.3.24 Estimation of Atmospheric Stability Regulatory Guide 1.97 recommends instrumentation for this variab,le with a range of -5 to +10'C or an analogous range for alternative stability analysis. The licensee has supplied instrumentation with a range of -5 to

+5'C. The licensee states that this i: acceptable based on its meeting the

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recommendations of Regulatory Guide 1.22.

Table 1 of Regulatory Guide 1.23 (Reference 6) provides seven atmospheric stability classifications based on the difference in temperature per 100 meters elevation change. These classifications range 6 from extremely unstable to extremely stable. Any temperature differences greater than +4 or less than -2*C does nothing to the stability classification. The range supplied by the licensee encompasses this range. Therefore, we find that the instrumentation is acceptable to determine the atmospheric stability. .

3.3.25 Accident Sampling (Primary Coolant. Containment Air and Sumo)

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

1. Regulatory Guide 1.97 recommends a range of 1 pC1/ml to 10-Cf /ml for gross activity. The licensee has provided a range of 10 pct /ml to 10 C1/ml.
2. It does not have the capability to analyze for dissolved oxygen.
3. It does not have containment air oxygen content analysis on-site.

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 is being addressed by the NRC as part of their review of NUREG-0737, Item II.B.3.

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

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1. Pressurizer level--the licensee should supply additional analys4s to support the deviation from the recommended range (Section 3.3.10).
2. Pressurizer heater status--the licensee should provide the instrumentation recommended by Regulatory Guide 1.97

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(Section 3.3.11).

3 .' Safety / relief valve positions or main steam flow--the licensee should instail instrumentation to monitor safety / relief valve l

position or main steam flow (Section 3.3.14).

4. Component cooling water flow to ESF system--the licensee should verify that the alternate instrumentation is Category 2

[ (Section 3.3.17).

i . 5. Condenser air removal system exhaust--the licensee should change the existing range to conform with the regulatory guide or justify the deviation (Section 3.3.21).

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6. Noble gas from steam generator safety relief valves or j atmospheric dump valves--the licensee should provide additional justification for this deviation (Section 3.3.22).

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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, 1983.

2. Instrumentation for Light-Water-Cooled Nuclear Power Plants to'Asse'ss Plant and Environs Conditions During and Following an Accident, .

Regulatory Guide 1.97, Revision 2, U.S. Nuclear Regulatory Commission (NRC), Office of Standards Development, December 1980.

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

( 4. Florida Power Corporation Letter, P. Y. Baynard to Director Office of Nuclear Reactor Regulation, August 21, 1984.

5. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 3, U.S. Nuclear Regulatory Commission (NRC), Office of luclear Regulatory Research, May 1983. .
6. Regulatory Guide 1.23 (Safety Guide 23), Onsite Meteorological Programs, NRC, February 17, 1972, or Proposed Revision 1 to Regulatory Guide 1.23, Meteorological Programs in Support of Nuclear Power Plants, NRC, Office of Standards Development, September 1980.

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