ML20140G453

Draft Conformance to Reg Guide 1.97 South Texas Project, Units 1 & 2

ML20140G453
Person / Time
Site:	South Texas
Issue date:	09/30/1985
From:	Stoffel J EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20140G458	List: ML20140G453
References
CON-FIN-A-6493, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8602140020
Download: ML20140G453 (23)

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CONFORNANCE TO REGULATORY GUIDE 1.97 SOUTH TEXAS PR05ECT, UNIT NOS. 1 AND 2 J. W. Stoffel Published September 1985 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Connission Washington 0.C. 20555 Under DOE Contract No. DE-AC07-761D01570 FIN No. A6493 23ff 1

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ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97, Revision 2, for Unit Nos. 1 and 2 of the South Texas Project and identifies areas of nonconformance to the regulatory guide. Exceptions 3

to Regulatory Guide 1.97 are evaluated and those areas where sufficient J 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 Regulatory Regulation, Division of Systems Integration, by EG&G Idaho, Inc., NRC Licensing Support Section.

The U.S. Nuclear Regulatory Comission funded the work under authorization B&R 20-19 40-41-3.

Docket Nos. 50-498 and 50-499 11 DRAFI 9 *

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DRAF, CONTENTS ABSTRACT .................................................. . - 11 FOREWORD ......................................... .- - - - 11 1

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

2. REVIEW REQUIREMENTS .............................................. 2 4

3. EVALUATION ............................................. ... -

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

4. CONCLUSIONS ...................................................... 16

5. REFERENCES ....................................................... 20 T

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. CONFORMANCE TO REGULATORY GUIDE 1.97 SOUTH TEXAS PROJECT, UNIT NOS.1 AND 2

1. INTRODUCTION On Decen.ber 17, 1983, 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 holoers of construction permits. This letter incluceo additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2) relating to the requirements for emergency response capability. These requirements have been published as Supplement No. I to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).

Houston Lighting and Power Company, the applicant for the South Texas Project, Unit Nos. I and 2, provided a response to Section 6.2 of the generic letter on September 25, 1984 (Reference 4).

This report provices en 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 NRC describing how the applicant 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.

1. Instrument range

2. Environmental qualification ,

3. Seismic qualification

4. Quality assurance -

5. Redundance and sensor location

6. Power supply

7. Location of display

8. Schedule of installation or upgrade 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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pg necessary. Therefore, this report only addresses exceptions to Regulatory -

Guide 1.97. The following evaluation is an audit of the applicant's submittals based on the review policy described in the NRC regional meetings.

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3. EVALUATION The applicant provided a response to Section 6.2 of NRC Generic Letter 82-33 on September 25, 1984. This evaluation is based on that submittal.

3.1 Adherence to Reaulatory Guide 1.97 The applicant states that their submittal provides a detailed account of the conformance of the South Texas Project, Unit Nos. 1 and 2, to the recommendations of Revision 2 of Regulatory Guide 1.97. The applicant further states that the information provided in their submittal meets the requirements of Supplement No. 1 to NUREG-0737, Section 6. Therefore, we conclude that the applicant has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3. ,

3.2 Type A Variables Regulatory Guide 1.97 does not specifically 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 applicant classifies the following instrumentation as Type A.

1. Reactor coolant system (RCS) pressure

2. RCS hot leg water temperature 1

3. RCS cold leg water temperature

4. Steam generator level (wide range)

5. Steam generator level (narrow range)

6. Pressurizer level DR!!i

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7. Containment pressure

8. Steamline pressure

9. Refueling water storage tank (RWST) level

10. Containment water level (wide range)

11. Containment water level (narrow range)

12. Auxiliary feedwater storage tank level

13. Auxiliary feedwater flow

14. Containment radiation level (high range)

15. RCS pressure

16. Steam generator blowdown radiation monitor

17. Steamline radiation monitor

18. Core exit temperature

19. RCS subcooling Except as noted in Section 3.3 the above variables meet the Category 1 recommendations consistent with the requirements for Type A variables.

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

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3.3.1 Rance Reautrement Deviation The applicant Indicates that the following variables conform to the range recommended by Regulatory Guide 1.97. However, the range provided for each variable is listed as 0 to 100 percent of span. Based on this information we are unable to determine that the range meets the regulatory guide recommendation.

1. Steam generator level (wide range)

(from tube sheet to separators)

2. Steam generator level (narrow range)

(no specific requirement)

3. Pressurizer level (bottom to top) - .

4. Refueling water storage tank (top to bottom)

5. Auxiliary water storage tank (top to bottom)

6. Auxiliary feedwater flow (0 to 110 design flow) 7< Volume control tank level (top to bottom)

8. Main feedwater flow (0 to 110 percent design flow)

9. Containment spray flow (0 to 110 percent design flow) l 6

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10. Component cooling water flow to emergency safety features t

(ESF) system corrponents i (0 to 110 percent design flow) 1 1' . Residual heat removal (RHR) system flow f

(0 to 110 percent design flow)

12. Unit vent flow (0 to' 110 percent design flow) l The applicant nas not provicea tne range information required by I Section 6.2 of Supplement No. I to huREG-0737. The applicant should l

' provide tne required information, toentify any deviation from Regulatory Guice 1.97 and justify those deviations identified.

3.3.2 RCS Soluble Boron Ccncentration Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to o000 ppm. The applicant has not provided the information required by Section J.2 of Supplement ho. I of NUREG-0737.

l The applicant should provide the required information, identify any l deviation from Regulatory Guide 1.97 and justify those deviations identifieo.

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( 3.3.3 Reactor toolant System Cola anu Hot leg Temperature Revision 2 of Regulatory buice 1.97 recommends Instrumentation for these variables with ranges of 50 to 750'F. The applicant has supplied instrumentation for these variaDies with ranges from 0 to 700*F. The applicant presented no justification for these deviations.

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DRAFT Revision 3 of Regulatory Guide 1.97 (Reference 5) reconsnends a range of 50 to 700*F for these variables. The instrumentation supplied by the applicant neets this range. Therefore, the range supplied by the applicant for these variables is acceptaole.

3.3.4 Core Exit Temperature Rt.gulatory Guiae 1.97 recommenos instrumentation for this variable with a range of 200*F to 2300'F. The applicant is installing instrumentation for this variable with a range of 100*F to 2200*F and has not identified this as a deviation.

This exception goes beyo,nd the scope of this review and is being _

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

3.3.5 Coolant Level in Reactor Regulatory Utide 1.97 recommends instrumentation for tnis variable with a range from the bottom of the core to the top of the vessel. The applicant is installing instrumentation for tnis variable with a range from the upper core support plate to the top of the vessel and has not icentified this as u ceviation.

This exception goes t,eycnu tne scope of this review and is being addressed by the hRC as part of their review of NUREG-0737, Item II.F.2.

3.3.6 Containment Isolation Valve Position Regulatory Guide 1.97 recomnends Category 1 instrumentation for this variable. The applicant does not consider this instrumentation to be a key I variable to indicate whether plant safety functions are being i accomplished. The applicant states that this variable is designated for monitoring gross breach of the containment and is qualified to Category 2 criteria.

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We are unable to determine from the applicants submittal just where*

tne provided instrumentation deviates from Category I criteria. The applicant should provide Category 1 instrumentation for this variable or identify and justify the specifit deviation.

3.3.7 Radiation Level in Circulating Primary Coolant The applicant uses the post-accident sample system to measure this parameter. Based on the alternate instrumentation provided by the applicant, we concluoe that the instrumentation supplied for this variable is adequate, and therefore, acceptable.

3.3.8 Analysis of Primary Coolant (Ganma Spectrum)

The applicant has riot provided the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable.

The applicant should provide the required information, identify any deviation from Regulatory Guide 1.97 and justify those deviations icentified.

3.3.9 Radiation Exposure Rate (Type C)

Regulatory Guide 1.97, Revision 2, recommends Category 2 instrumentation for this variable as an indication of breach. The applicant has provided Categocy 3 instrumentation.

Regulatory Guice 1.97, Revision 3, (Reference 5) eliminates this variable as an indicator of breach. Therefore, the existing instrumentation is acceptable.

3.3.10 Radiation Exposure Rate (Type E)

Regulatory Guide 1.97, Revision 2, recommends Category 2 instrumentation for this variable. Tna applicant has provided Category 3 instrumentation.

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Regulatory Guide 1.97, Revision 3, recommends Category 3 instrumentation for this variable. Therefore, the provided instrumentation is acceptable to monitor this variable.

3.3.11 Residual Heat Removal (RHR) Heat Exchanger Outlet Temperature The applicant has supplied instrumentation for this variable with a range of 50 to 400*F. Regulatory Guide 1.97, Revision 2, recommenos a range of 32 to 350*F and Revision 3 recommends a range of 40 to 350*F. The icw end of the range deviates from both revisions of the regulatory guide.

This deviation is less than 3 percent of the current maximum recomended range. Considering instrument accuracy and the overall range, we consider this deviation minor and, therefore, acceptable.

3.3.12 Accumulator Tank Level and Pressure The applicant indicates conformance for accumulator' tank pressure. ,

However, a range of 0 to 700 psig has been supplied while the regulatory guide recommends a range of 0 to 750. The applicant should provide i Justification for this oeviation.  ;

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Tne applicant inoicates that tnere is no level ino1 cation provided for this variable. Tne applicant states that accumulator pressure and valve l position inoication provide acequate status of the accumulators.

i This justification is unacceptable as the applicant has not shown an alternative methoo for oetermining the amount of water injected by the accumulators. The applicant should provide level indication in accordance with Regulatory Guide 1.97.

I l 3.3.13 Accumulator Isolation Valve Position The applicant has not provided the information required by Section 6.2 of Supplement No I to NUREG-0737.

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The applicant should provide the required information, identify any deviation from Regulatory Guide 1.97 and justify those deviations identified.

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3.3.14 Boric Acid Charoino Flow The applicant does not have instrumentation for this variable. The applicant states that the units do not have boric acid charging flow as a post-accident safety injection system. Refueling water storage tank (RWST) level, high head safety injection (HHSI) flow, low head safety injection (LHSI) flow, containment water level, and emergency core cooling system (ECCS) valve status are the safety injection variables monitored.

Because this is not a safety injection flow at this station, we find that this variable is not applicable.

3.3.15 Reactor Coolant Pump Status Regulatory Guide 1.97 recommends Category 2 motor current instrumentation to monitor this variable. The applicant has provided on/off Indication that except for environmental qualification meets Category 2 requirements. No justification for these deviations was submitted.

Dependent on the accident conditions, the reactor coolant pumps may or may not be operating. When they are operating, the motor current is a valuable aid to the operator in diagnosing approach to cavitation, pump seizure and shaft break conditions. As this information can be valuable in mitigating the consequence of an accident, we recommend that the applicant install the recommended instrumentation.

3.3.16 Pressurtrer Heater Status Regulatory Guide 1.97 recommends electric current indication to monitor this variable. The applicant has provided open/ closed indication s .

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.for the heater circuit breakers. The applicant states that heater circuit breaker position was selected for determining pressurizer heater status oue to hardware considerations.

Section II.E.3.1 of NUREG-0737 requires a number of the pressurizer heaters to have the capaDility 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.

The Stanoard Technical Specifications for hestinghouse reactors, Section 4.4.3.2, require that the emergency pressurizer heater current be measureo quarterly. These emergency power supplied heaters snould have the current instrumentation recommended by Regulatory Guide 1.97.

3.3.17 Quench Tank Level Quench Tank Temperature Quench Tank Pressure

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The applicant has not provided the information required by Section 6.2 of Supplement f.o. I to NOREG-0737. ,.

The applicant should provide the required information, identify any deviation from Regulatory Guide 1.97 and justify those deviations iuentified.

3.3.18 Containment Atmosphere Temperature Tne applicant has not provioeo the information required by Section 6.2 cf Supplement No. 1 to NUREG-0737. The applicant states that their.

emergency response guidelines do not require the operator to take actions 5 that would result in adverse consequences if the containment temperature was inoiCating an erroneous value, l.e assume by this that the instrumentation provioed for this variable does not satisfy the recontrendations of Regulatory Guide 1.97.

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This is insufficient justification for this deviation. The applicant should provide the required information, identify any deviations from Regulatory Guide 1.97 and justify those oeviations identified.

3.3.19 Containment Sump Water Temperature The applicant has not provided this instrumentation. The applicant states that other parameters were designated as Type D variables to demonstrate that the safety injection systems are operating properly when taking suction from the containment sump.

This justification is not adequate. The applicant should provide the recommended instrumentation for the functions outlined in Regulatory Guice 1.97 or ioentify other instruments that provide the same quantitive information and satisfy the regulatory guide.

3.3.20 Hign-Level Radioactive Liquid Tank Level Raoicactive Gas Holuuo Tank Pressure The applicant has nut provided the information required by Section o.2 of Supplement No. I to hUREG-0737 for these variables.

The applicant should provide the required information, identify any deviations from Regulatory Guide 1.97 and justify those deviations identified.

3.3.21 Energency Ventilation Darr.per Position Regulatory Guide 1.97 recommends Category 2 instrumentation that provides open-closed status of the emergency ventilation dampers. The applicant coes not provide this instrumentation. Instead, tne applicant monitors radiogas, radioparticulate, and radiohalogen concentrations at l

various locations in the plant. The applicant states that this instrumentation provides information concerning the status of the ventilation systems.

The applicant's justification for this deviation is unacceptable.

Emergency damper nosition is recommendeo by Regulatory Guide 1.97 in aodition to monitoring of the flow paths specified by the applicant. The 4

applicant shoulo commit to the installation of Category 2 open/ closed instrumentation for this variable.

3.3.22 Vent f rom Steam Generator Safety Relief Valves or Atmospheric Lumg Valves The applicant has not provided the information required by .ection 6.2 of Supplement No. I to NUREG-0737 for this variable.

The applicant should provide the required information, identily any

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} identified.

3.3.23 Radiation Exposure Meters The applicant has not provioed the information required by Section 6.2 i of Supplenent No. I to h0 REG-0737 for this variable.

Kevision 3 of Regulatory Guice 1.97 deletes this variable. Therefore, we find it acceptable that the applicant does not have this instrumentation.

3.3.24 Plant and Environs Radiation (Portable Instrumentation) l Regulatory Guide 1.97 recommends instrumentation for this variable

., with a range of 10-3 to 104 R/hr, photons and 10-3 to 104 rads /hr, beta radiation and low energy photons. The applicant has indicated that the range for this instrumentation is not applicable.

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The applicant should provide the range of this instrumentation, ,

identify any deviation from Regulatory Guide 1.97 and justify those c;eviations identified.

3.3.25 Plant and Environs Radioactivity (Portable Instrumentation) i The applicant has not provided the information required by Section 6.2 of Supplement No. I to NUREG-0737. The applicant should provide the I required information, identify any deviation from Regulatory Guide 1.97 and justify those deviations identified, l

i 3.3.26 Wind Direction

! Wind Speea Estimation of Atmospheric Stability The applicant states that the instrumentation for these variables meets tne requirements of Regulatory Guide 1.23.

The applicant has not provioed the information required by Section 6.2 cf Supplement No. I to NUREG-0737 for these variables. The applicant should provide tne required information, identify any deviation from Regulatory Guioe 1.9? a..d justify those deviations identified.

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

1. Range requirement deviation--the applicant should provide the range monitored for the twelve variables listed and justify any

deviation from the regulatory guide (Section 3.3.1).

2. RCS soluble boron concentration--the applicant should provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable, identify any deviation and justify tnose deviations identified (Section 3.3.2).

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3. Containment isolation valve position--the applicant shoulo provide Category 1 instrumentation for this variable or identify ~ '

and Justify any specific deviation (Section 3.3.6).

, 4 Analysis of primary coolant (gamma spectrum)--the applicant should provide the information required by Section 6.2 of i Supplement No. I to NUREG-0737 for this variable, identify any deviation and justify those deviations foenti fied (Section 3.3.8).

l 5. Accumulator tank level and pressure--the applicant should justify i the deviation in the pressure range; the applicant should install accumulator tank level instrumentation that meets the recommendations of Regulatory Guice 1.97 (Section 3.3.12).

! 6. Accumulator isolation valve position--the applicant shoula provice the information required by Section 6.2 of Supplement No. I to NUKEG-0737 for tnis variable, identify any deviation ana justify those deviations identified (Section 3.3.13).

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7. Reactor coolant pump status--the applicant should install the motor current instrumentaticn in accordance with Regulatory Guide 1.97 (Section 3.3.15).

8. Pressurizer heater status--the applicant should provide the recommenced instrumentation (Section 3.3.16).

9. Quench tank level--the applicant should provide the information required by Section 6.2 of Supplement No. I to hUREG-0737 for this variable, identify any deviation anc justify those a

deviations identified (Section 3.3.17).

10. Quench tank temperature--the applicant should provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable, identify any deviation and justify those oeviations iaentified (Section 3.3.17).

11. Quencn tank pressure--the applicant should provide the information required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable, identify 'any deviation and justify those deviations identifieo (Section 3.3.17).

12. Containment atmosphere temperature--the applicant should provice the information required oy Supplement No. I to Section 6.2 of NUREG-0737 for this variable (Section 3.3.18).

13. Containment sump water temperature--the applicant should provide the recommended instrumentation for this variable or ioentify other instrumentation that provides the same information (Section 3.3.19).

14. High-level radioactive liquid tank level--the applicant should j provide the information required by Section 6.2 of Supplement No. I to NukEG-0737 for this variable, identify any deviation and

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justify those oeviations identifieo (Section 3.3.20).

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15. Radioactive gas . .ldup tank pressure--the applicant should provide the infor: nation required by Section 6.2 of Supplement No. I to NUREG-0737 for this variable, identify any deviation and justify those deviations identified. (Section 3.3.20).

16. Emergency ventilation damper position--tne applicant should provide position indication for these dampers in accordance with the recommendations of Regulatory Guide 1.97 (Section 3.3.21).

17. Vent from steam generator safety relief valves or atmospheric dump valves--the applicant should provide the information required by Section 6.2 of Supplement No. I to NUREG--0737 for this variable, identify any deviation and justify those deviations icentified (Section 3.3.22).

18. Plant and environs radiation--the applicant shoula provide the range of the instrumentation proviaed for this variable, identify -

any aeviation and justify those deviations identified (Section 3.3.24).

19. Plant and environs radioactivity--the applicant should provide the information required by Section 6.2 cf Supplement No. I to NUREG-0737 for this variable, identify any deviation and justify those deviations identified (Section 3.3.25).

20. Wina direction--the applicant should provide the information required by Supplement No. I to NUREG-0737 for this variable, identify any ceviation anu justify tnose deviations identified (Section 3.3.26).

21. Wind speea--the applicant should provide the information required by Supplenent ho. I to NUREG-0737 for this variable, identify any deviation ana justify those deviations identified (Section 3.3.26).

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22. Estimation of atmospheric stability--the applicant should provide j the'information required by Supplement No. I to NUREG--0737 for

} this variable, ioentify any'ceviation and justify those deviation i

identified (Sectlon' 3.3.16).

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5. REFERENCES

1. NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors.

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

2. Instrumentation for Lic ht-Water-Cooled Nuc1Hr Power Plants to Assess Plant and Environs Conc itions Durina and Foowing an Accident, Regulato y Guide 1.97, Revision 2, NRC, Office of Standards Development, December 1980.

3. Clarification of TNI Action Plan Reautrements. Reautrements for Emeroency Response CaDabtitty, NUREG-0737, Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.

4. Houston Lighting and Power Company letter, J. H. Goldberg to H. Denton, NRC, " Final Safety Analysis Report Amendment 40" ,,

September 25, 1984, ST-HL-AE-1125.

5. Instrumentation for Licht-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Followina an Accident, Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory Research, Nay 1983. ,

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