ML20212G359

Conformance to Reg Guide 1.97,Grand Gulf Nuclear Station, Unit 1

ML20212G359
Person / Time
Site:	Grand Gulf
Issue date:	03/31/1986
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20212G336	List: ML20212G342 ML20212G359
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-51094, NUDOCS 8701200250
Download: ML20212G359 (23)

Text

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Attachment-i

• o CONFORMANCE TO REGULATORY GUIDE 1.97 GRAND GULF NUCLEAR. STATION, UNIT NO. 1

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A. C. Udy ,

Published March 1986 EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the

,- U.S. Nuclear Regulatory Consnission Washington, D.C. 20555 Under DOE' Contract No. DE-AC07-76ID01570

.' FIN No. A6483 8701200250 870112 PDR ADOCK 05000416 -

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ABSTRACT This EG&G Idaho, Inc., report reviews the submittal for Regulatory Guide 1.97, Revision 2, for the Grand Gulf Nuclear Station, Unit No. 1, and identifies areas of'nonconformance to the regulatory guide. Exceptions to

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Regulatory Guide 1.97 are evaluated.

Docket No. 50-416 .

TAC No. 51094 L_______________-._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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

Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc., NRR and I&E Support Branch.

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

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Docket No. 50-416

. TAC No. 51094 iii

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CONTENTS .

ABSTRACT .............................................................. 11 FOREWORD .............................................................. i ii

1. INTRODUCTION ..................................................... 1

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

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

4. CONCLUSIONS ...................................................... 17

5. REFE'RENCES ....'................................................... 18 4

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CONFORMANCE TO REGULATORY GUIDE 1.97

, GRAND GULF NUCLEAR STATION UNIT NO. l'

1. INTRODUCTION d

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. 1 to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).

Mississippi Power and Light Company, the licensee for the Grand Gulf N0 clear Station, Unit No. 1, provided a response to Section 6.2 of the gerieric letter on February 28, 1985 (Reference 4). Additional information was provided on February 14, 1986 (Reference 5).

This report provides an evaluation of this material.

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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 -

1 response facilities. The submittal should include documentation that  ;

provides the following information for each variable shown in the l applicable table of Regulatory Guide 1.97. )

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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 The submittal should identify deviations from the regulatory guide and provide supporting justification or alternatives.

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

At these meetings, it was noted that the NRC review would only address exceptions taken to Regulatory Guide 1.97. Where licensees or applicants ,

explicitly state that instrument systems conform to the regulatory guide it was noted that no further staff review would be necessary. Therefore, this -

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

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3. EVALUATION .

The licensee provided a response to Item 6.2 of NRC Generic Letter 82-33 on February 28, 1985. The response describes the licensee's position on post-accident monitoring instrumentation. Additional information was provided on February 14, 1986. This evaluation is based on that material.

3.1 Adherence to Regulatorv Guide 1.97 o The licensee has provided a review of their post-accident monitoring instrumentation that shows instrumentation that presently complies with Regulatory Guide 1.97, Revision 2, dis usses modifications to bring instrumentation into full compliance with the regulatory guide and discusses deviations that the licensee supports as appropriate to tne Grand Gulf Nuclear Station design. The Grand Gulf Nuclear Station, Unit No. 1, operating license ha's a licensing condition that requires all modification l

identified for Regulatory Guide 1.97 be complete prior to startup following the second refueling outage. The refueling outage is exoected to cccur in the first quarter of 1988 Therefore, we conclude that the l , ,

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.

l l 3.2 Type A Variables 1

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

The licensee classifies the following instrumentation as Type A.

1. Reactor pressure vessel (RPV) level

2. RPV pressure ,

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3. Drywell pressure e*

. 4. Drywell atmosphere temperature

5. Primary containment pressure

6. Primary containment temperature

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7. Suppression pool water temperature

8. Suppression pool water level

9. Containment hydrogen concentration

10. Drywell hyarogen concentration

11. Main steam isolation valve (Group 1)-position These variables, with exceptions as noted in Sect. ion 3.3, either meet or will meet the Category 1 recommendations, consistent with the requirements for Type A variables.

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

3.3.1 Reactor Coolant System (RCS) Soluble Boron Concentration Regulatory Guide 1.97 recommends *ns.trumentation for this variable with a range of 0 to 1000 parts per million. The licensee states that the range of this instrumentation is 250 to 10,000 parts per million. No

. justification was provided for the deviation in the lower limit of the range.

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l The licensee deviates from Regulatory Guide 1.97 with respect to the range of this post-acciderst sampling capability. This deviation goes beyond the scope of this review and sasi _ addressed by the NRC as part .

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of their review of NUREG-0737, Item II.B.3.

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3.3.2 Coolant level in Reactor Regulatory Guide 1.97 recommends redundant instrumentation for this C variable with a range from the bottom of the core support plate to the lesser of the top of the vessel or the centerline of the main steamline.

The licensee's instrumentation consists of redundant instruments that cover 3 zones with overlapping ranges.

The licensee's instrumentation meets the recommendations of Regulatory Guide 1.97 except for the shutdown range instrumentation, which measures the upper 58 inches of the 435 inch recommended range. It is not fully redundant. These channe,1s will share a reference leg, drywell sensing lines and drywell penetrations. This-avoids an additional penetration of .

the reactor pressure vessel head. The. licensee s.tates that only a break of the reference leg or sensing line would prevent both divisions from operating, and that only a marginal plant safety improvement would be made by costly-reactor pressure vessel and containment penetrations needed for full redundancy. Based on these considerations, we conclude that the

- shutdown range instrument channels are acceptable, and that the instrumentation provided for this variable is satisfactory.

I 3.3.3 Drywell Sumo level Drywell Drain Sumos Level .

Regulatory Guide 1.97 recommends Category 1 instrumentation for these variables. The licensee has supplied Category 3 instrumentation for these variables. The drywell sump systems are automatically isolated at the primary containment penetration should an accident signal occur. The .

' licensee also identifies alternate instrumentation that monitors leakage.

This instrumentation consists of fission product monitoring, air cooler -

j condensate monitoring, drywell air temperature, drywell pressure, i

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recirculation pump seal monitoring, reactor vessel head seal monitoring and safety relief valve exhaust temperature. .

We conclude that the instrumentation provided by the licensee will provide appropriate monitoring of the parameters of concern. This conclustod is based on (a) for small leaks, the instrumentation is-not expected to experience harsh environments during operation, (b) for larger leaks, the sumps fill promptly and the sump drain lines isol' ate due to the o increase in drywell pressure, thus negating the drywell sump level and drywell drain sumps level instrumentation, and (c) this instrumentation neither automatically initiates nor alerts the operator to initiate  ;

operation of a safety-related system in a post-accident situation.

Therefore, we find the Category 3 instrumentation provided acceptable.

3.3.4 Primary Containment Isolation Valve Position Regulatory Guide 1.97 recommends Category 1 position indication for these valves.

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 5 position indication). Since redundant isolation valvos are provided, we -

find that redundant indication per valve is not intended by the regulatory guide. Position indication of check valves is specifically excluded by Table 1 of Regulatory Guide 1.97. Therefore, we find that the instrumentation for this variable is acceptable in regards to redundancy.

The licensee is providing the recommended seismic qualification for those lamps located on seismically qualified panels. All-containment isolation valves will thus have Category 1 indication in the control room.

O Note 23 of Reference 4, attachment 2, lists 15 valves that do not have

.. position indication on the isolation valve status panel. The licensee, in Reference 5, verifed that indication for these 15 valves is in the control room.

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3.3.5 Radiation level in Circulating Primary Coolant .

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The licensee indicates that the key instrumentation to measure radiation level to indicate fuel cladding failure is provided by the post-accident sampling system. This. system was7 reviewed by the NRC as .

part of their review of NUREG-0737, Item II.B.3. Additional information is provided by the condenser off-gas and the main steamline radiation monitor before isolation occurs, and by the drywell and containment hydrogen and radiation monitors.

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

conclude that the instrumentation.provided by the licensee for this variable is adequate and, therefore, acceptable.

3.3.6 Suppression Pool Water Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the bottom of the emergency core cooling system (ECCS) .

suction to five feet above the normal level. The, instrumentation supplied has a range that exceeds the upper limit, but is lacking six inches from satisfying the recommended lower limit (103 feet 6 inches instead of 103 feet). The licensee's instrumentation measures to the centerline of the ECCS suction line rather than to the bottom. With the water level at

. eitner location (centerline or bottom of the suction line), the residual heat removal (RHR) pumps will lose suction. Lack of this six inches of range does not preclude any safety system from operating as designed, nor is this portion of the recommended range required for any operator i initiated safety action.

l Based on the licensee's justification, we find the range provided for this instrumentation acceptable.

i 3.3.7 Containment and Drvwell Hydrogen Concentration .

Regulatory Guide 1.97 recommends instrumentation for this variable -

with a range from 0 to 30 percent. The licensee's instrumentation has a 8

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range of 0 to 10 percent. The licensee stites that the hydrogen recombiners trip because of overtemperature when the hydr' ogen concentration

- -exceeds 4 percent. A hydrogen burn occurs at a hydrogen concentration of 6 percent because of the hydrogen igniters. Thus, hydrogen concentra. tion

is limited to less than 10 percent by operator action of redundant Class 1E hydrogen igniters. This operator action is part of the emergency operating procedures and is based on this Type A variable.

As the in.Trumentation will remain on scale because of the use of the I hydrogen ignitors, we find that this instrumentation is acceptable.

3.3.8 Effluent Radioactivity - Noble Gases and Vent Flow Rates Regulatory Guide.1.97 recommends Category 2 instrumentation for this variable. The power sources for Category 2 instrumentation should be high

. reliability, not necessarily standby power. The licensee addresses the power supply for this instrumentation for the following release points as a deviation: .

o Containment purge i o Fuel handling area -

o Turbine butiding o Radwaste building This was addressed as a deviation because at one time the licensee had proposed to provide onsite power to this instrument ~ation. This modification will not be done. Power to.this instrumentation is derived from the same non-Class 1E power source as the ventilation system. It is not backed up with onsite power. We find that the power sources for this

- instrumentation are in accordance with Regulatory Guide 1.97, and are acceptable.

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3.3.9 Radiation Exposure Rate ,

Regulatory Guide 1.97 recommands Category 2 instrumentation for this I variable with a range of 10 to 10 R/hr. The Category 3 instrumentation supplied by the licensee has location dependent ranges of ,

either 10 to 1.R/hr, 10- to 10 R/hr or 10" to 100 R/hr.

The licensee states that this instrumentation is used for an order-of-magnitude indication as the instrumentation will be affected by both the primary containment radiation and the radioactivity in the fluid flowing in the emergency core cooling system piping. The licensee states that because of the amount of this piping and the number of hatches and electrical penetrat, ions, ambiguous indications are expected for this instrumentation. Long term accessibility will be evaluated with portable radiation survey instruments and containment atmosphere sampling and analysis, Release assessment will be accomplished with noble gas effluent monitors. ,

r l Regulatory Guide 1.97, Revision 3 (Reference.6), specifies Category 3 instrumentation for this variable. Therefore, we find Category 3 '

l instrumentation adequate for this variable. From a radiological stand

! point, if the radiation levels reach or exceed the upper limits of the ranges provided, personnel would not be permitted into the areas without portable monitoring (except for life saving). We therefore find the proposed ranges for the radiation exposure rate monitors acceptable.

l 3.3.10 Condensate Storace Tank Level l

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l Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the top to the bottom. The licensee indicates that the -

tank top is at 31 feet and that the range of the instrumentation includes this. The lower limit of the range is not at the bottom of the tank, but is 6-1/2 inches below the emergency core coolant suction line. Water below -

this level would not be usable as core coolant.

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Based on the licensee's justification, we find this deviation acceptable.

4 . i 3.3.11 Orywell Atmosphere Temperature l

Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 40 to 440*F. The licensee has instrumentation for this i variable that has a range of 0 to 400*F. The licensec states that the ,

maximum calculated post-accident drywell temperature is 330*F. Based on

' the maximum expected temperature transient being 330*F, a range of 0 to 400*F is adequate for this variable.

3.3.12 Main Steamline Isolation Valves' Leakace Control System Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range of 0 to 15 inches of water and 0 to 5 psid. The licensee has l two sets of instrumentation for this variable with ranges of 0 to 50 psia I

' and 0 to 100 psig. . .

We find this instrumentation adequate to provide indication of pressure boundary maintenance as recommended by Regulatory Guide 1.97.

Therefore, this instrumentation is acceptable.

. 3.3.13 Core Soray System Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. As such, environmental'y qualified instrumentation is required

( in accordance with 10 CFR 50.49. The licensee states that this instrumentation.is exempt from the requirements of'NUREG-0588 and, because

. of this, environmental qualification to 10 CFR 50.49 is not required. In Reference 5, the licensee clarifies that the transmitters have been addressed per 10 CFR 50.49, and found to be located in a mild environment.

J Thus, this instrumentation is acceptable, y

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1 3.3.14 Standby Liquid Control System (SLCS) Flow Regulatory Guide 1.97 specifies Category 2 instrumentation with a I range of 0 to 110 percent of the SLCS design flow. The Grand Gulf Station l

does not measure this. flow directly.- The operator verifies pump operation ,

by use of the pump operating indicator lights and by a decrease in the SLCS ,

storage tank level. Other parameters that can be monitored to verify  !

system operation include squib valve position, SLCS tank outlet valve position and neutron flux.

We find the above instrumentation valid as an alternative indication of SLCS flow.

3.3.15 SLCS Storaae Tank Ievel i

Regulatory Guide 1.97 recommends Category 2 instrumentation for this i variable with a range from the bottom to the top. As such, environmentally qualified instrumentation is required in accordance with 10 CFR 50.49. The licensee states that the range will be recalibrated to be from 2-1/2 inches 1

above the tank outlet to the tank overflow. Ti.is is essentially the bottom and top of the tank. Based on the licensee's justification, the deviation l from the recommended range is acceptable.

1 The instrumentation is not environmentally qualified. The licensee states that this instrumer.tation will be operating in a mild environment for a anticipated transient without scram and that the design basis for the standby liquid control system, (SLCS) reorganizes that the SLCS is not required to mitigate a loss of coolant or high energy line break design

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basis event.

As the licensee has verified that the instrumentation is Category 2 and only required to operate in a mild environment, we find this instrumentation acceptable. -

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3.3.16 Coolina Water Flow to Er.aineered Safety Feature System Components

." Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. As such, environmentally qualified instrumentation is required in accordance with 10 CFR 50.49. Th'e licen'see, in the description of this instrumentation, states that environmental qualification is not necessary for this variable. In Reference 5 the licensee clarifies that this instrumentation has been addressed per 10 CFR 50.49, and found to be

• located in a mild environment. Thus, this instrumentation'is acceptable.

3.3.17 Hioh Radioactivity Liouid Tank Level Regulatory Guide 1.97 recommends instrumentation for this variable with a range from the top to the bottom of the tank. The licensee's instrumentation does not comply with this recommendation, but does measure to beyond the tank o'verflow. The low limit of the range is at 10-5/8

~ inches." The licensee states that this limit is satisfactory as interlocks are provided to prevent pcmpout of the tank contents when the level is below 14 inches.

The licensee has shown that the instrumentation will remain on scale at all times. Based on this, we find the range of this instrumentation acceptable. .

3.3.18 Status of Standby Power and Other Eneroy Sources Important to Safety The licensee has identified several deviations from the recommended Category 2 instrumentation. .

Startina Air Pressure for the Standby Diesel Generator

. The licensee has identified this as a backup variable and has used Category 3 instrumentation with local readout only. A local alarm of

,- abncrmal pressure is input to a diesel generator trouble alarm in the control room. We find this arrangement acceptable.

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Startino Air Pressure for the High Pressure Core Spray Diesel Generator The licensee has identified this as a backup variable and has .

redundant Category 3 pressure indication and pressure switches with l local readout only. The pressure switches control the air compressors .

I for this system. The licensee states, in Reference 5, that an input i to the common trouble alarm in the control room will be provided with

. Category 2 equipment. o i

High Pressure Core Spray Standby (HPCS) Power I

l The licensee has identified that Category 3 instrumentation for the

j. 4.16 KVAC bus, voltage and current are needed to monitor the status of the HPCS power supply. The licensee justifies Category 3-3 instrumentation because of the diversity provided by other Category 3 instrumentation: the diesel generator frequency, bus 17AC frequency, l

Division 3 de voltage (both in the control' room and at the bus), local

ammeters and the synchonizing circuits voltage. Based en this

! diversity, we find the instrumentation provided to determine the -

statJs of the HPCS power supply acceptable.

DC Power Voltace and Current

. The licensee has identified several deviations for the monitoring of DC power.

a. Battery current for Class 1E batteries--The licensee's alternate instrumentation for this parameter measures the balance of the cell voltages between the two halves of the battery. Should an imbalance exist an operator is. dispatched to investigate the situation. We find this an acceptable method for determining the condition of the battery.

b. Battery charger output current--This is a local instrument with no control room readout. The licensee states that this -

instrument is primarily for service and maintenance personnel.

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Undervoltage alarms are in the control room should a significant overcurrent condition exist. We find this combination of

, instrumentation acceptable for this parameter.

I c. Battery charger output voltage--The bus voltmeter is used to provide this information, along with bus over/undervoltage alarms. This instrumentation is located in the control room. We find this arrangement acceptable. -

d. Battery high discharge rate alarm--The licensee alarms bus undervoltage~and ground faults. For a high discharge rate to occur, either or both conditions will exist. We find this ,

instrumentation acceptable.

3.3.19 Standby Gas Treatment System - Noble Gas Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee's instrumentation for this variable consists of two sets of instrumentation. Category 3 instruments' cover a range of 10~ to 2 -#

10 pC1/cc and Category 2 instruments cover a range of 10 to 10 pCi/cc. The licensee has performed an analysis that shows that during accidents and during post-accident conditions, the Category 2 (upper range) instrumentation will be on scale. Therefore, we find the instrumentation supplied for this variable acceptable.

3.3.20 Wind Speed Regulatory Guide 1.97, Revision 2, recommends. instrumentation for this variable with an accuracy of 0.5 miles per hour. The licensee has identified a deviation in that this instrumentation has an accuracy of 1 percent of the wind speed over the entire range. Thus, over 50 miles per hour, the accurancy is greater than recommended by Revision 2 of the Regulatory Guide. Revision 3 of the Regulatory Guide (Reference 6) permits an accuracy of 10 percent when the wind speed is greater than 5 miles per hour.

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I Based on Revision 3 of the regulatory guide, we find the licensee's wind speed accuracy adequate for release assessment. Therefore, this instrumentation is acceptable. ,

3.3.21 AccidentSamplina(primarydoolant.ContainmentandSump) I The licensee's sample system can obtain samples and provide the analyses within the ranges reconsnended for this variable, with the following exceptions:

o Boron content - the minimum resolution is 250 ppm rather than 0 o Chloride content - the ainimum resolution is 100 ppb rather than 0 o Dissolved hydrogen - the minimum resolution is 0.5 percent rather than 0 o Dissolved oxygen - the range is 500 ppb to 19 ppm rather than 0 to 20 ppm -

o The suppression pool is sampled rather than the sumps The licensee deviates from Regulatory Guide 1.97 with respect to post-accident sampling capability. This deviation goes beyond the scope of this review and was addressed by the NRC as part of the review of j NUREG-0737, Item II.B.3 I 16 -

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4. CONCLUSIONS _

, Based on our review, we find that the licensee either conforms to or is justified in deviating from Regulatory Guide 1 97 . .

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. . q S. REFERENCES ,

1. NRC letter, D. G. Eisenhut to All Licensees of Operating Reactors, A* al'  ; for Operating Licenses, and Holders of Construction ,

. Pe.mit, ' Supplement No.1 to NUREG-0737--Requirements for Emergency l Response Capability (Generic Le,tter No. 82-33)," December 17, 1982. ,

2. Instrumentation for Liaht-Water-Cooled Nuclear Power Plants to Assess Plant and Enytrons Conditions Durino and Following an Accident,

Regulatory Guide 1.97, Revision 2, NRC, Office of Standards Development December 1980.

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

4. Mississippi Power and Light Company letter, L. F. Dale to NRC,

" Regulatory Guide 1.97 (Revision 2) Position Report on Accident Monitoring Instrumentation," February 28, 1985, File:

0260/15619/L-813.0, AECM-85/0059.

5. Mississippi Power and Light Company letter, L. F.. Dale to NRC,

" Response to NR.C Request for Additional Information (RAI) on MP&L's Position Report on Regulatory Guide 1.97 (Rev. 2)," February 14, 1986,

. AECM-86/0030. -

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6. Instrumentation for Licht-Water-Cooled. Nuclear Power Plants to Assess

, Plant and Environs Conditions During and Followina an Accident,

Regulatory Guide 1.97, Revision 3, NRC, Office of Nuclear Regulatory i Research, May 1983.

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