ML20235B071

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Conformance to Reg Guide 1.97:Comanche Peak -1/-2, Technical Evaluation Rept
ML20235B071
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 12/31/1988
From: Udy A
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML20235B074 List:
References
CON-FIN-A-6493, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-8287, TAC-R00405, TAC-R405, NUDOCS 8902090324
Download: ML20235B071 (25)
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l 1. . . ATTACHMENT i.

EGG-NTA-8287-i

' TECHNICAL EVALUATION' REPORT CONFORMANCE TO' REGULATORY GUIDE 1.97: . COMANCHE PEAK-1/-2 i

Alan C. Udy Published December 1988 EG&G Idaho, Inc.

Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 Under 00E Contract No. DE-AC07-761001570 FIN No. A6493 i

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o ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97, Revision' 2, for Unit Nos.1 and 2 of the Comanche Peak Steani Electric Station. Any exceptions to Regulatory Guide 1.97.are eviiuated

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- and those areas where suffi-ient basis for acceptability is not provided are identified.

l Occket Nos. 50-445/50-446 TAC No. R00405 ii

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b FOREWORD.

This' report is supplied as.part of the'" program for Evaluating Licensee / Applicant.Confo'rmance to RG 1.97," being conducted for the.V.S.

~ Nuclear Regulatory Commission, 0ffice of Nuclear Reactor Regulation,

. Division of-Engineeringfand System Technology, by EG&G. Idaho, Inc.,

Regulatory and' Technical Assistance Unit.

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

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r Docket Nos. 50-445/50-446 TAC No. R00405 1 iii  ;

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. 3 CONTENTS

~ii ABSTRACT ..........^....................................................

iii FOREWORD ..... .... .................-..................... ............

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

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27 REVIEW REQUIREMENTS ......... ....................................

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3. EVALUATION ..... .................................................

4 3.1 Adherence to Regulatory Guide 1.97 .........................

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

5 3.3 Exceptions'to Regulatory Guide 1.97 ........................

CONCLUSIONS ....................... ... . ' '*************** ~

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- 5. ' REFERENCES .......................................................

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CONFORMANCE TO REGULATORY GUIDE 1.97: 1 I

COMANCHE PEAK-1/-2 I

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

The Texas Utilities Generating Company (licensee for Comanche Peak-1/-2) response to Section 6.2 of the generic letter is contained in Section 7.5 of the " Comanche Peak Steam Electric Station Final Safety Analysis Report" (FSAR). Other documents identified in Section 5 of this report provide additional information used in preparing this report.

This report is based on the recommendations of Regulatory Guide 1.97, Revision 2, and compares the instrumentation identified in Section 7.5 of the FSAR with these recommendations.

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2. REVIEW REQUIREMENTS Section 6.2 of NUREG-0737, Supplement No. 1, sets forth the documentation to be submitted to the NRC in a report 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.
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 rec 0 emendations of Regulatory Guide 1.97 and should provide supporting justification r alternatives for the deviations identified.

I Subsequent to the issuance of Generic Letter 32-33, the NRC held l regional meetings in February and Marce, 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 address only exceptions taken to Regulatory Guide 1.97. It was also noted that, where licensees or applicants explicitly state that instrument systems conform to 2

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-th'e regulatory. guide,: no further. staff review would be n'ecessary.

.Therefore, this report addresses only those exceptions'to RegO ttery'-

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! Guide 1.97 that have been identified by:the licensee. The following evaluation of. the.' licensee's'submittals is based on .the review pol. icy.

-described in~the NRC's' regional meetings.

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3. EVALUATION The licensee's response to_ Item 6.2 of NRC Generic Letter 82-33, Section 7.5 of the Comanche Peak FSAR, describes the licensee's position on post-accidentmonitoringl instrumentation. Amendment 69 of this section was reviewed against the recommendations of Regulatory Guide 1.97, Revision 2.

3.1 Adherence to Regulatory Guide 1.97 The licensee provided a review of their post-accident monitoring instrumentation that compares the instrumentation characteristics against the recommendations of Regulatory Guide 1.97, Revision 2. The licensee states, in Section 7.5.3.6, that Comanche Peak meets the intent of Revision 2 of Regulatory Guide 1.97. Therafore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guide are noted in Section 3.3.

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

' actions. The licensee classifies-the following instrumentation as Type A.

1. reactor coolant system (RCS) cold leg water temperature
2. RCS hot leg water temperature
3. RCS pressure
4. core exit temperature
5. degrees of subcooling V

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containment . sump water level (wide' range)

7. containment pressure (narrow range).
8. refueling water storage tank level.-
9. pressu-izer level
10. steam generator level-(narrow range)
11. steam generator pressure
12. auxiliary feedwater flow ,

13, condensate storage tank water level The above-instrumentation meets the Category 1 recommendations consistent with the requirements for Type A variables, with those exceptions listed in Section 3.3.

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 Soluble Boron Concentration Regulatory Guide 1.97 recommends a control room display of zero to 6000 parts'per mi11 ion (ppm) for the instrumentation supplied for this variable. The licensee has not provided on-line instrumentation for this variable and states that this variable is monitored by the post-accident samplirg system using laboratory analysis. The available range is 500 ppm to 6000 ppm.

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The licensee deviates from Regulatory Guide 1.97.with respect to post-accident sampling capabilitye This deviation 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.

3.3.2 Reactor Coolant System Cold Leo Water Temperature Revision 2 of Regulatory Guide 1.97 recommends a control room display with a range of 50 F to 750 F for this variable. The licensee's instrumentation has a range of 50*F to 700*F.

Revision 3 of Regulatory Guide 1.97 (Reference 5) recommends a range of 50 F to 700'F for this instrumentation. The instrumentation supplied by the licensee meets this range. Therefore, the range supplied by the licensee for this instrumentation is acceptable.

3.3.3 Reactor Coolant System Hot Leg Water Temperature Revision 2 of Regulatory Guide 1.97 recommends a control room display with a range of 50*F to 750 F for this variable. The licensee's 4

instrumentation has a range of 50*F to 700*F.

Revision 3 of Regulatory Guide 1.97 (Reference 5) recommends a range of 50 F to 750*F for this instrumentation. The instrumentation supplied by the licensee meets this range. Therefore, the range supplied by the licensee for this instrumentation is acceptable.

3.3.4 Coolant Level in Reactor Revision 2 of Regulatory Guide 1.97 recommends reactor coolant level instrumentation with a range from the bottom of the core to the top of the reactor vessel. The licensee's instrumentation has a range covering f rom  ;

the upper core plate to the top of the reactor vessel.

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Revision 3 of Regulatory Guide 1.97 (Reference 5) recommends a range from the bottom of the hot leg to the top of the reactor vessel for this -

instrumentation. The instrumentation supplied by the licensee meets this.

range. Therefore, the range supplied by the licensee for this instrumentation is acceptable.

3.3.5 Containment Sump Water Level Regulatory Guide 1.97 recommends both narrow range containment sump level instrumentation and wide range (up to 600,000 gallons) instrumentation for this variable. The licensee has wide range instrumentation that has indication from 808 feet to 817 feet 6 inches.

There is no. separate narrow range instrumentation.

The licensee states that the wide range instrumentation displays the entire-range of expected post-accident levels in the containment. 'This is said to include the information that the recommended narrow range

- instruments would display. Because the wide range instruments are inclusive of the narrow range, we find the instrumentation supplied for this variable acceptable.

3.3.6 Containment-Isolation Valve Position The licensee identified an exception to Regulatory Guide 1.97 for this variable in that the manually-operated containment isolation valves do not have the recommended instrumentation. Those containment isolation valves that are operated automatically have the recommended instrumentation.

We could find no justification for not providing indication of the status of manual contai' ment isolation valves. The licensee should either provide suitable justification for not providing position indication for these manually-operated valves or, alternatively, provide position indication for these valves as recommended by Regulatory Guide 1.97.

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l' automatic valve. Since redundant isolation valves are provided, we find

- that. redundant indication per valve is not intended by the regulatory guide. There is redundant indication of the isolation function.

Therefore, we find that the instrumentation provided for this variable is acceptable.

3.3.7 Residual Heat Remo'al v Heat Exchanger Outlet Temperature Regulatory Guide 1.97 recommends instrumentation with a range of 32 F to 350 F for this variable. The licensee's instrumentation has a range of 50*F to 400*F. There is a deviation of 18 F in the lower limit of the range.

Reference 6 states that the 50*F to 400 F range covers the anticipated requirements for normal operation, anticipated operational occurrences, and-accident conditions, Based on this statement, we find the provided range acceptable.

3.3.8 Accumulator Tank Level and Pressure Regulatory Guide 1.97 recommends instrumentation with ranges of 10 percent to 90 percent of the accumulator volume for level and zero to 750 psig for the accumulator pressure. The licensee has designated pressure as the key instrumentation for this variable and has supplied Category 2 pressure instrumentation. Category 3 level instrumentation is acceptable as backup instrumentation to the Category 2 pressure instrumentation.

l The supplied instrumentation has ranges of zero to 100 percent (level) and zero to 700 psig (pressure). Reference 6 states that both ranges cover the anticipated requirements for normal operation, anticipated operational occurrences, ahd accident conditions. Based on this statement, we find the provided ranges acceptable.

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g-I a 3.3.9 Flow in Low Pressure Injection System Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. Section 7.5 of the FSAR does not address this variable; however, from previously submitted material (Reference 6), we understand that in the Comanche Peak Design, low pressure injection is a residual heat removal system function. The residual heat removal flow is monitored by Category 2 instrumentation in accordance with Regulatory Guide 1.97. Therefore, we find the instrumentation provided for this safety-injection function acceptable.

3.3.10 Boric Acid Charging Flow Regulatory Guide 1.97 recommends Category 2 instrumentation for this i

variable to inonitor safety injection flow. Section 7.5 of the FSAR states that in the Comanche Peak design, this safety injection flow is accomplished with the centrifugal charging pump. The centrifugal charging pump flow is monitored by Category 2 instrumentation in accordance with Regulatory Guide 1.97. Therefore, we find the instrumentation provided for this safety-injection function acceptable.

3.3.11 Quench Tank Temperature Regulatory Guide 1.97 recommends instrumentation with a range of 50 F to 750 F for this variable. The licensee's instrumentation has a range of 50*F to 350 F.

Reference 6 states that the 50 F to 350 F range covers the anticipated requirements for normal operation, anticipated operational occurrences, and accident conditions. This is related to the design pressure (100 psig) of the tank and the corresponding saturated steam temperature at this pressure. Based on this statement, we find the provided range acceptable.

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, j 3.3.12 $_ team' Generator Level-Wide Range Regulatory' Guide 1.97 recommends that this instrumentation-be Category 1. The-licensee has identified this instrumentation as Category 2 backup instrumentation; however, no deviations from Category 1 requirements were identified.

The licensee should verify that this instrumentation is Category 1.

3.3.13 Steam Generator pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range from atmospheric pressure to 20 percent above the lowes' safety vilve sctting. Section 10.3.2.1 of the Comanche Peak FSAR states that the sarety valve with the lowest setpoint is set at 1200 psig; therefore, the upper limit of the range sh.21d be 1440 psig. .The range provided by the licensee is zero to 1300 psig.

In Reference 8, the licensee describes the tap location in justifying the range provided. The tap is located oetween the steam flow restrictors and the main steam isolation valves. Because the tap is located close to the main steam safety relief valves, they experience essentially the same pressure. The safety relief valve with the highest setpoint is set at 1235 psig il percent. The licensee states that oecause of the flow restrictors and the setpoint, tolerance, and accumulation, all safety-relief valves will be wide open at 1285 psig. inus, the pressure seen by the transmitter would be within the range supplied. Because the pressure is thus limited, we find the zero to 1300 psig range acceptable.

3.3.14 Heat Removal by the Containment Fan Heat Removal System i

Regulatory Guide 1.97 recommends plant specific instrumentation for this variable. Section 7.5 of the FSAR does not discuss this variable.

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-Reference 6 states that there is no containment fan heat' removal ident-situation.

csystem at Comanche Peak designed to operate in a post-acc Based on this statement, we find this exemption from Regulatory Guide 1.97 acceptable.

3.3.15 Containment Sump Water Temperature Regulatory Guide 1.97 recommends Category 2 instrumentation with a range from 50*F to 250*F for this variable. Section 7.5 of the FSAR does not discuss this variable.

Reference'7 reports on an analysis that shows that the emergency core

_i cooling system pumps will have adequate net positive suction head regardless of.-the sump water temperature. The licensee establishes that alternate instrumentation can be used to confirm that containment cooling is 'taking place. This alternate instrumentation includes Category 3 RHR heat exchanger inlet temperature, Category 2 RHR heat exchanger outlet temperature, Category 2 RHR flow, Category 2 containment spray flow, Category 2 containment atmosphere temperature, Category 1_RCS hot leg water temperature, Category 1 RCS cold leg water temperature, and Category 1 core exit-temperature instrumentation.

With adequate net positive suction head provided and suitable alternative instrumentation to slow the effectiveness of containment cooling, we find this exemption for Regulatory Guide 1.97 acceptable.

3.3.16 Makeup Flow-In i

Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided Category 3 instrumentation, stating that while this instrumentation is used for a normal safe shutdown, it is  ;

not required during or following an accident. The licensee states that these instruments are located such that a mild environment is present when procedures require the use of the instrumentation. Based on these statements, we find this deviation from Regulatory Guide 1.97 acceptable.

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3.3.17 Letdown Flow-Out Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided Category 3 instrumentation, stating that while this instrumentation is used #or a normal safe shutdown, it is not required during or following an accident. The licensee states that j

these instruments are located such that a mild environment is present when I procedures require the use of the instrumentation. Based on these statements, we find this deviation from Regulatory Guide 1.97 acceptable.

l 3.3.18 Volume Control Tank Level Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable. The licensee has provided Category 3 instrumentation, stating that while this instrumentation is used for a normal safe shutdown, it is not required during or following an accident. The licensee states that these instruments are located such that a mild environment is present when procedures require the use of the instrumentation. Based on these statements, we find this deviation from Regulatory Guide 1.97 acceptable.

3.3.19 High Level Radioactive 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 has a high level alarm in the control room, and instrumentation that covers the recommended range in the local waste processing panels.

In Refe ence 7, the licensee states that the control room alarm is an aid in preve.aing the overfilling of the three tanks, and that a display in the control room is not needed. Section 6.2(g) of NUREG-0737, Supplement No. 1 (Reference 3), allows displays in locations other than the control room control panels. Because of this allowance, we find tne provided instrumentation ccceptable.

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v 3.3.20 Radioactive Gas Holdup Tank Pressure Regulatory Guide 1.97 recommends instrumentation for this variable with a range of zero to 150 percent of the tank design pressure. The licensee has a high pressure alarm in the control room and instrumentation with a range of zero to 150 psig in the local waste processing panels.

In Reference 7, the licensee states that the control room alarm is an aid in preventing the overfilling of these tanks, and that a display in the control room is not needed. Section 6.2(g) of NUREG-0737, Supplement No. 1 (Reference 3), allows displays in locations other than the control room control panels. Because of this allowance, we find the provided instrumentation location acceptable.

Tables 11.3-1 and -2 of the FSAR state that these tanks have a design pressure of 150 psig, and that the high pressure alarm is set at 100 psig.

The design output (maximum) pressure of the waste gas compressors is 150 psig. Section 11.3.2.1.1 of the FSAR states that there are relief valves that relieve the full flow from both waste gas compressors. These relief valves are set to relieve pressure at less than the system design pressure. Because of the pressure relief capacity of the system, we find the zero to 150 psig range acceptable.

3.3.21 Vent from Steam Generator Safety-Relief Valves Regulatory Guide 1.97 recommends Category 2, env:ronmentally qualified instrumentation for this variable to monitor noble gases, the duration of the release, and the mass of steam per unit of time. Section 7.5 of the FSAR states that this instrumentation is qualified for the period of time needed to detect a tube rupture event. The regulatory guide recommends this instrumentati n for the purpose of the detection of significant The instrumentation is not qualified releases and for release assessment.

for the long term release assessment recommended by the regulatory guide, l

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The licensee gives no justification for this deviation. The ]

regulatory guide makes allowance for a common plant vent that monitors this discharge. .If this is-the case,'the licensee should identify this instrumentation and verify that it.is Category'2. If this is not the case, then theLlicensee;should environmentally qualify this instrumentation in accordance with Regulatory Guide'1.97 and 10 CFR-50.49.

- 3.3.22. Condenser Air Removal System Exhaust-Noble Gas 'and Vent Flow

. Regulatory Guide 1.'37 recommends a display with a range of

-6 pC1/cc to 10 5 uCi/cc. The i strumentation identified-in 10

-5 ~1 Section 7.5 of the FSAR has a range of 10 uCi/cc to 10 uCI/cc.

The regulatory guide makes allowance for a common plant vent that monitors this discharge. Reference 7 states that this system discharges through a common plant vent. Because of this flow. routing, the instrumentation. supplied for this variable is acceptable.

. 3.3.23 All Other Identified Release Points-Noble Gas and Vent Flow Regulatory Guide J.97 recommends Category 2 instrumentation for this

-6 2 variable with a display with a range of 10 uCi/cc to'10 Ci/cc.

Section 7.5 of the FSAR does not discuss this variable.

The licensee should either verify that all identified release points are monitored in accordance with the regulatory guide or provide any additional instrumentation needed to bring about full compliance.

l 3.3.24 Particulate and Halogens Regulatory Guide 1.97 recommends sampling with onsite analysis with a 2

capability of 10 ~3 uCi/cc to 10 uCi/cc. Section 7.5 of the FSAR The states that a grab sample is used with an "as required" capability.

licensee should verify that the range supplied meets or exceeds the recommended range.

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j Regulatory Guide 1.97 recommends portable sampling with onsite

~9 -3 pCi/cc for this analysis with a capability of 10 uCi/cc to 10 variable. Section 7.5 of the FSAR does not discuss this variable.

The licensee should identify the instrumentation provided for this l

variable and verify that it meets the' recommendations of Regulatory Guide 1.97.

3.3.26 plant and Environs Radiation Regulatory Guide 1.97 recommends portable instrumentation for this

-3 R/hr to variable for isotopic analysis. The range recommended is 10

~3 4 104 R/hr for photons and 10 rads /hr to 10 rads /hr for beta and lower energy photons. Section 7.5 of the FSAR states that the instruments used has an "as required" capability. The licensee should verify that the range supplied meets or exceeds the recommended range.

3.3.27 plant and Environs Radioactivity i Regulatory Guide 1.97 recommends a portable multichannel gamma-ray spectrometer for this variable. Section 7.5 of the FSAR does not discuss this variable.

The licensee should identify the instrumentation provided for this variable and verify that it meets the recommendation of Regulatory l Guide 1.97.

3.3.28 Estimation of Atmospheric Stability i

Regulatory Gu'de 1.97 recommends instrumentation for this variable to l have either a range of -5'C to +10 C or an analogous range for alternative stability analysis. The licensee's instrumentation has a range of -5*F to

+5'F. The licensee justifies this range in Reference 6, stating that the range is wider than the range specified in Regulatory Guide 1.23, 15 I

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Revision 1, Table 1, " Classification of Atmospheric Stability by Temperature Change with Height." The licensee states that the -5'F to +5 F range is equivalent to -5.56*C to +5.56*C for an equivalent of 100 meter span.

Table 1 of Regulatory Guide 1.23 (Reference 8) provides 7 atmospheric stability classifications based on the difference in . temperature per 100 meter elevation change. These classifications cover from extremely unstable to extremely stable. A temperature difference greater than +4*C or less than -2*C has no impact on the stability classification. The licensee's instrumentation includes this range. Therefore, we find that this instrumentation is acceptable for determining atmospheric stability.

3.3.29 Accident Sampling (primary Coolant, Containment Air and Sump)

The licensee's post-accident sampling system provides sampling and analysis as recommended by the regulatory guide except for the following deviations.

1. Boron Content -- The minimum observable concentration is 500 ppm.
2. Chloride Content -- The minimum observable concentration is 25 ppb.

The maximum observable concentrations is 5 ppm.

3. Dissolved Hydrogen -- The minimum observable concentration is 0.5 ppm.

4 Dissolved Oxygen -- The minimum observable concentration is 0.1 ppm.

5. Hydrogen Content -- The minimum observable concentration is 0.1 ppm.
6. Oxygen Content -- The minimum observable concentration is 0.1 ppm.

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 has been addressed by the NRC as a part of their review of NUREG-0737 Item II.B.3.

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3.3.30 Information Not Complete Table 7.5-1 of the FSAR states that environmental qualification will be provided "as appropriate". This statement does not convey that the 10 CFR 50.49 requirement that instrumentation supplied for Category 2 variables is to be environmentally qualified.- The licensee should state specifically that each Category 2 variable has environmentally qualified 3 instrumentation. Where environmental qualification is not provided, the licensee should provide suitable justification for each separate deviation.

Table 7.5-1 of the FSAR also states that the indication for Category 1 variables is "immediately accessible". Imme$iately accessible is not defined by the licensee. Regulatory Guide 1.97 recommends continuous indication for Category 1 variables. The licensee should state specifically, for each Category 1 variable, what the means of display are.

Where the methods of indication are not in compli'ance with Revision 2 of Regulatory Guide 1.97, the licensee should provide appropriate justification for each deviation.

s Table 7.5-1 and Section 7.5.1.3.1.4 of the FSAR state that the emergency response facility (ERF) computer is the device used for recording the Category 1 variables. The licensee has not described this capability; i.e., is instrumentation / computer isolation provided by qualified isolation devices, or is the ERF computer installed and maintained in accordance with Category 1 requirements (including maintaining redundancy and independence, and Class 1E power sources). The licensee should describe this recording capability, including the qualification of the instrumentation / computer interface devices, and verify that this capability meets the recommendations of Revision 2 of Regulatory Guide 1.97.

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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, with the following exceptions:
1. Containment isolation valve position -- The licensee should either provide Category 1 position indication for the manually operated containment isolation valves or supply suitable justification for not providing this instrumentation. (Section 3.3.6)
2. Steam generator level-wide range -- The licensee should verify that this instrumentation is Category 1. (Section 3.3.12)
3. Vent from steam generator safety-relief valves -- The licensee should environmentally qualify this instrumentation in accordance with Reg'ulatory Guide 1.97 and 10 CFR 50.49, or alternatively, identify the common plant vent innrumentation and verify that it is Category 2.

(Section 3.3.21)

4. All other identified release points-noble gas and vent flow -- The licensee should either verify that all identified release points are monitored in accordance with Regulatory Guide 1.97 or provide .

I additional instrumentation to bring about full compliance.

(Section 3.3.23) _

5. Particulate and halogens -- The licensee should vi:rify that the range supplied meets or exceeds the recommended range. (Section-3.3.24)
6. Airborne radichalogens and particulate -- The licensee should describe the instrumentation supplied for this variable and verify that it meets the recommendation of Regulatory Guide 1.97.

(Section 3.3.25)

7. Plant and environs radiation -- The licensee should verify that the range supplied meets or exceeds the range recommended by Regulatory Guide 1.97. (Section 3.3.26) 18

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8.. . Plant and environs radioactivity -- The licensee should describe the-

-instrumentation. supplied for this variable ~and verifyzthat it meets the recommendations of Regulatory Guide 1.97. (Section-3.3.27) 1

9. Environmental _ qualification -- The. licensee should verify'the environmental qualification of the Category 2 instrumentation.

(Section 3.3;30)

10. Indication -- The licensee should describe the means of used to display Category 1 variables. (Section 3.3.30)- l 1
11. Recording -- The licensee should describe the ERF computer, including interface and isolation devices, and ar.y other instrumentation used in recording Cc'.egory 1 variables. (Section.3.3.30) i l

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5. REFERENCES
1. Letter, NRC (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 Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, Regulatory Guide 1.97, Revision 2, 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, Of fice of Nuclear Reactor Regulation, January 1983.
4. " Comanche Peak Steam Electric Station Final Safety Analysis Report,"

Amendment 69, March 14, 1988.

5. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident, l Regulatory Guide 1.97,. Revision 3, NRC, Office of Nuclear Regulatory Research, May 1983.
6. Letter, Texas Utilities Services, Inc. (H. C. Schmidt) to NRC (B. J. Youngblood), " Response to Request for Additional Information:

Accident Monitoring Instrumentation," October 24, 1983, Log #TXX-4068, File #907.5.

7. Letter, Texas Utilities Generating Company (J. W. Beck) to NRC (B. J. Youngblood), " Response to NRC Staff Interim Evaluation on

' Accident Monitoring," January 28, 1985, Log #TXX-4382, File # 10010,907.5.

8. Onsite Meteorological Programs, Regulatory Guide 1.23 (Safety Guide 23), NRC, February 17, 1972 or Meteorological Programs in Suoport of Nuclear Power Plants, Proposed Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, September 1980. l i

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