ML20237J319

Conformance to Reg Guide 1.97:Quad Cities-1 & -2, Interim Technical Evaluation Rept

ML20237J319
Person / Time
Site:	Quad Cities
Issue date:	08/31/1987
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20237J323	List: ML20237J319 ML20238D264
References
CON-FIN-A-6483, RTR-REGGD-01.097, RTR-REGGD-1.097 EGG-NTA-7761, GL-82-33, TAC-51124, TAC-51125, NUDOCS 8708260112
Download: ML20237J319 (24)

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EG3-NTA-7761 TECHNICAL EVALUATION REPORT CONFORMANCE TO REGULATORY GUIDE 1.97: QUAD CITIES-1 AND -2 l

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Docket Nos 50-254/50-265 i

Alan C. Udy l

Published August 1987 Idaho National Engineering Laboratory EG&G Idano, Inc.

Idaho Falls, Idaho 83415 Drepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Uncer DOE Contract No. DE-AC07-761D01570 FIN No. A6483 1

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ABSTRACT This EG&G Idaho, Inc., report reviews the submittals for Regulatory Guide 1.97 for the Quad Cities Station, Unit Nos. I and 2 and identifies areas of nonconformance to the regulatory gu-ide. Exceptions to Regulatory Guide 1.97 are evaluated and those areas where sufficient basis for acceptability is not provided are icentified.

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l Docket Nos. 50-254 and 50-265 TAC Nos. 51124 and 51125 ii l

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

Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering and System Technology, by EG&G Idaho, Inc.,

Electrical, Instrumentation and Control Systems Evaluation Unit.

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

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Docket Nos. 50-254 and 50-265 TAC Nos. 51124 and 51125 iii 1

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CONTENTS A:"<

" T RA* r .. . . .. . ... ........ .. , , ,, , ,, ,,,, , jj FOREWORD .... . .. .... ..

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1. INTRODUCTION ... ... ............... ....... . ......, ,,,, , ,,, 3

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

3. EVALUATION .... .... .... .............. g 3.1 Adherence to Regulato ry Guide 1.97 . . . . . . . . . . . . . . . . , , , , , , , 4 3.2 Type A Variables .. ...... . ...... ..... .......,,..... . 4 3.3 Exceptions to Regulatory Guide 1.97 .. .................. 5 4 CONCLUSIONS ...

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5. REFERENCES . .. .. .... ... . .. ... ... .... ........., 19 l

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o CCNFORMANCE TO REGULATORY GUIDE 1.97: QUAD CITIES-1 AND -2

1. INTRODUCTION l I

i On December 17, 1982, Generic Letter No. 82-33 (Reference 1) was i issued oy D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors,. applicants for operating licenses, and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency response capability. These requirements have been published as Supplement  !

No. I to NUREG-0737, "TMI Action Plan Requirements" (Reference 3).

Commonwealth Edison, the licensee for the Quad Cities Station, provided a response to Item 6.2 of the generic letter on August 1, 1985 (Reference 4). Schecular information was provided in letters dated l January 31,1986 (Reference 5), October 6,1986 (Reference 6), May 28,1987 (Reference 7) and May 29, 1987 (Reference 8). A letter dated Novemoer 4, 1985 (Reference 9) addressed instrumentation readouts for the emergency response facilities.

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This report provides an evaluation of that material.

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2. REVIEW REQUIREMENTS

! tem 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.

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 l The submittal should identify any deviations taken from the reguli ory guide recommendations and provide supporting justification or alternatives for the deviations icentified.

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 Guice 1.97. Where licensees or applicants  !

explicitly state that instrument systems conform to the regulatory guide i* }

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was noted that no further staff review would be necessary. Therefore, this report only acdresses 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 E2-33 on August 1, 1985. The response describes the licensee's position on post-accicent monitoring instrumentation. This evaluation is based on that material. Other schedular information submitted is listed in the l l References Section of this report.

1 3.1 Adherence to Reculatory Guide 1.97.

l The licensee has provided a review of their post-accident monitoring instrumentation that shows instrumentation that presently complies with the recommendations of Regulatory Guide 1.97, discusses modifications to bring instrumentation into full compliance with the regulatory guide and  !

f discusses deviations that the licensee supports as appropriate to the Quad l Cities Station design. The licensee has committed to complete all the modifications required to bring the presently identified deviations into compliance with Regulatory Guide 1.97 by the completion of the Unit 2 ,

Spring 1988 outage. One possible exception to this exists, in that rescaling the drywell pressure recorder cannot be completed until the corresponding technical specification change has been approved by the NRC.

The change is scheduled for submittal to the NRC in July 1987. Therefore, we conclude that the licensee has provided an explicit commitment on conformance to Regulatory Guide 1.97. Exceptions to and deviations from the regulatory guice are noted in Section 3.3.

3.2 Tyoe 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. Coolant level in reactor 4

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2. Reactor coolant system pressure

3. Crywell pressure 4 Suppression chamcer pressure

5. Suppression pool water level

6. Suppression pool water temperature These variables, with exceptions as noted in Section 3.3, either meet or will meet the Category 1 recommendations, consistent with the requirements  ;

for Type A variables. l 3.3 Exceotions to Reaulatory Guide 1.97 The licensee identified deviations and exceptions from Regulatory Guide 1.97. These are discussed in the following paragraphs.

3.3.1 Neutron Flux Regulatory Guide 1.97 recommends Category 1 instrumentation for this t

variable. The licensee's instrumentation is stated to be Category 1 except for environmental and seismic qualification of the cables, detectors and the detector drives that are inside the primary containment. These are not qualified for a loss of coolant accident.

The licensee states that there is a known relation between the source range reading when fully withdrawn and the actual power level. This is

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based on the attenuation f actor of the materials in the vicinity of the detectors and the neutron leakage factor that are known for this design of boiling water reactor. The source range period meter also shows increases or decreases in power level, even with the detectors withdrawn. There are j l 6 l

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four source range channels per unit. There are also eight intermediate range monitors that measure down to 5 x 10'# percent of full power when fully inserteo.

1 Additionally, tne licensee states that a scram can be verified by these diverse parameters:

1. Scram relay position indication,

2. Scram valve position indication,

3. Control rod drive scram accumulator low pressure indication,

4. Scram discharge volume high level alarm, and i

5. Indication of responses such as makeup flow, pressure decay, and ,

torus pressure increase.

In the process of our review of neutron flux instrumentation for boiling water reactors, we note that the detectors and their cables have not satisfied the environmental qualification requirement of Regulatory Guide 1.97. A Category 1 system that meets all the criteria of Regulatory Guide 1.97 is an industry development item. Based on our review, we conclude that the existing instrumentation is acceptable for interim operation. The if censee should follow industry development of this equipment, evaluate newly developed equipment and install Category 1 instrumentation when it becomes available.

3.3.2 Drywell Pressure Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. As such, the information should be continuously recorded. The licensee indicates that this is not recorded, but is available in the control room on an inoicator only. No justification was presented for this deviation.

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The licensee,should provide recording of the drywell pressure as recommenced by the regulatory guide.

3.3.3 Sucoression Pool Pressure The licensee classifies this as a Type A variable,.even though it is not a variable defined in the regulatory guide. The licensee states that the instrumentation for. the variable drywell pressure will be used for this variable as well, because there are twelve vacuum breakers that keep the suppression pool (or torus) pressure within 20.5 psi of the drywell. This is within one-half percent of the instrument range, and within the accuracy of the instruments. We find this acceptable, contingent on the recorder as concluded in Section 3.3.2.

3.3.4 Drywell Sumo Level Drywell Drain Sumos Level l

l Regulatory Guide 1.97 recommends Category 1 instrumentation for these variables. The licensee indicates that leakage rate, not sump level, is l the parameter of concern. This is monitored by Category 3 flow rate recorders. The leakage rate is determined every four hours when the sumps are required to be pumped out. A high sump level alarm is caused if the l sumps fill in less than four hours. Large leaks isolate the sumps.

We conclude that appropriate monitoring of the parameters of concern is crovided. This 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 isolate due l to the increase in drywell pressure, thus negating the drywell sump level and drywell drain sumps level instrumentation, and (c) this instrumentation

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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.

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3.3.5' Primary Containment Pressure Regulatory Guide 1.97 recommends. instrumentation for this variable with a range of -5 psig to 4 times the design containment pressure of 63 psig (252 psig).

The licensee's -instrumentation has a range of -5 psig to 250 psig.

The licensee has chosen this range because the scale is less awkward than the recommended range and because it meets the intent of the regulatory guide.

We find this deviation of 2 psig out of 250 psig' to be minor (less t

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.han 0.8 percent of the recommended range). Therefore, the range is acceptable.

3.3.6 Primary Containment Isolation Valve Position l From the information provided, we find that the licensee deviates from I 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 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.

3.3.7 Radiation Level in Circulating Primary Coolant The licensee states that their instrumentation is justified based on the critical actions to be taken to prevent and to mitigate a gross breach of " fuel cladding being (a) shut down the reactor, and (b) maintain the water level.

The licensee states that the post-accident sampling system provides a means of obtaining samples of reactor coolant and determining the status of fuel cladding and that the primary containment radiation monitors and the containment hydrogen monitors also provide information on the status of fuel cladding.

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l c ased on the alternate instrumentation and the justification provided by tne licensee, we conclude that the instrumentation supplied for this j variaDie is adecuate ana, therefore, acceptable.  ;

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3.3.3 Primary Containment Area Radiation )

i Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable with a range of 1 to 107 R/hr. The licensee's instrumentation j is Category 1, except for seismic qualification, and has a range of 10 to 108 R/hr in the drywell and Category 3 instrumentation with a range of 1 to 106 R/hr in the torus. The licensee's identification of the l

instrumentation says that seismic qualification is not required for this Lategory 1 instrumentation; no basis for this statement was given. The licensee should show that the installed instrumentation complies with the original station seitmic criteria. l l

The licensee states that the detectors will be recalibrates and j rescaled to meet the range of 1 to 107 R/hr.

1 3.3.9 Containment and Drywell Hydrocen Concentration j Regulatory Guide 1.97 recommends instrumentation for this variable l with a range of 0 to 30 percent. The range of the licensee's j instrumentation is 0 to 10 percent. A remote display that is accessible has a range of 0 to 20 percent, however, this remote display is not l Category 1 as recommended by the regulatory guide. The licensee states l

l that the O to 10 percent range monitors the hydrogen concentration well  !

1 into the explosive range and that there are no additional required operator actions for concentrations greater than 10 percent. j

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The NRC has reviewed the acceptability of this variable as part of their review of NUREG-0737, item II.F.1.6.

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D 3.3.10 Radiaticn Excesure Rate Revision 2 of Regulatory Guice 1.97 recommends Category 2 instrumentation for this variable with a range of 10 ~1 to 10 R/hr.

The licensee's instrumentation is Category 3. As Revision 3 of the regulatory guice (Reference 10) changes the recommendation to Category 3 instrumentation, we find the category of instrumentation acceptable.

The licensee states that the range is 10 ~1 to 103mR/hr

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(10 to 1 R/hr) and that this is adequate for normal operation and for use in determining local accessibility. Entry into an area is controlled by portable meters and by emergency plant procedures. The licensee states that this variable is a function of primary containment and emergency core cooling system fluid radioactivity, and that the use of effluent radioactivity monitors provides a positive indication of a break or of leakage.

The licensee has not shown any analysis of post-accident radiation l

levels expected for the monitor locations. The licensee should show that the existing radiation exposure rate monitors have ranges that encompass the expectea post-accident radiation levels in their locations.

i 3.3.11 Suppression Chamber Soray Flow 1

The suppression chamoer spray is derived from the residual heat removal (RHR) system, and as such uses the same flow detector that the variable low pressure coolant injection flow uses. The range of this instrumentation is 0 to 20,000 gpm, while the recommenced range for the l

variable suppression chamber spray flow is 0 to 110 percent of design flow (this is identified by the licensee as 275 gpm). The licensee acknowledges j that the instrumentation accuracy is not adequate for measuring 275 gpm.

The licensee states that the piping is sized to limit the rate of the suppression chamber spray flow. The licensee also indicates that other instrumentation is available including system valve position indication, l l

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9 The licensee does not provide instrumentation that is a direct incication for this variable for the diesel generator cooling water system, relying insteac on component temperature and an accessible readout of the cumo distnarge pressure.

We find the basis for this deviation unacceptable. The pump output pressure is an early indication of loss of flow, but it is not sufficient to replace flow. Flow blockage cannot be detected by pressure alone. The pressure indication is not in the control room. The component temperature is a lagging indication of loss of flow and thus is not acceptable to )

replace flow. The licensee should provide Category 2 instrumentation for the diesel generator cooling water system flow and provide the information required by Section 6.2 of NUREG-0737, Supplement No. 1.

3.3.14 Emeraency Ventilation Damper Position Regulatory Guide 1.97 recommends Category 2 indication in the control rcom for this variable. The licensee identifies the following deviations:

The diesel generator room ventilation dampers do not have position indication. Room high temperature alarms are used instead.

The main control room damper position indicators are located just outside the main control room in an accessible area. The main control room fan indication is in the control room and,.being interlocked with the dampers, provide information on the damper i status.

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! We find the alternate indications acceptable for this variable,  !

i however, the licensee should verify that the indication is Category 2. l l

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3.3.15 Secondary Containment Area Radiation Regulatory Guide 1.97 recommends Category 2 instrumentation for this variable with a range of 0.1 to 10'R/hr for the Mark I containment. The licensee's Category 3 instrumentation has a range of 0.1 to 103mR/hr.

The instrumentation deviates in both category and in the upper four decades of the recommended range.

The licensee states that the range is adequate for normal operation and for use in determining local accessibility. Entry into an area is controlled by portable meters and by emergency plant procedures. The licensee states that this variable is a function of primary containment and emergency core cooling system fluid radioactivity, and that the use of effluent radioactivity monitors provides a positive indication of a break or of leakage.

The licensee has not shown any analysis of post-accident radiation levels expected for the monitor locations. The licensee should show that the existing instrumentation for the variable secondary containment area radiation have ranges that encompass the expected post-accident radiation levels in their locations.

The licensee concludes that Category 3 instrumentation is acceptable for this variable because the use of these monitors to detect breach or leakage through primary containment penetration results in ambiguous indications.

We find that Category 3 instrumentation in concert with the noble gas effluent monitors is acceptable for this variable; however, the licensee snould verify the acequacy of the range of this instrumentation.

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3.3.16 Particulate anc Halooens Regulatory Guice 1.97 recommends instrumentation for this variable

.with a range of 10 -3 tg yg2 uCi/cc. The range of the licensee's instrumentation is stated to be 1 pCi/gm to 10 Ci/gm.

The licensee has stated that this instrumentation complies with the

-regulatory guide, yet has not shown correlation between the recommended and ]

the provided ranges. The licensee should demonstrate that the provided range encompasses'the recommended range. J 3.3.17 Plant and Environs Radiation q l

Regulatory Guide 1.97 recommends instrumentation for this variable )

-3 to 10 # rads /hr, wita ranges of 10 -3 to 10 R/hr, photons, and 10

' 4 beta and low energy photons. The licensee's survey meter for this variable i 3

has a range of 0 to 10 R/hr, and is stated to comply with the regulatory

(. guide. I From the information given for this variable, we conclude that a deviation exists; however, no justification was given for the different ranges. The licensee should provide instrumentation that covers'the  ;

s recommended range. .;

3.3.18 Plant and Environs Radioactivity Regulatory Guide 1.97 recommends portable instrumentation (i.e.,

instrumentation that is not in fixed locations) for this variable. The licensee is developing procedures which will utilize an analyzer that is in a fixed location, that uses samples that are taken as required in the plant and from the environs areas. The licensee states that portable equipment should not be used because of the rough handling it would receive in the' field.

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i t j f j The laboratory equ";mset at this station can provide isotopic analysis '

i s ,f anc a timbly assessmeri': of yidioactive releases. Therefore, this is an acceptable deviation fnm Regulatory Guide 1.97.

3.3.19 Estimation of Atmospheric Stability s e .

I Regplatory Guide 1.97 recommends instrumentation for this variable with a range of -3 to +18 F or an analogous' n;sge 'for alternate stabilitys analysi s[.. The licensee has supplied instrumentation with< a range of -10 t'o l

+10 F, b,dsed on a elevation differential of either 115 or 265 feet. i i Tath 1 of Regulatory Guide 1.23 ()kference 11) provides seven; atmospheric stability classifica.tions based on the difference in temperat? arf per 100 meters elevation chang (. These classifications range  ;

from extremely unstable to extremely stable. Any temperat et diffeAence  !

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greater tnan +4 C or less than -2 C does nothing to the stabfiity '

J clas pf*ication.

The licensee's instrumentation includes this range Therefore, we find that this instrumentation is acceptable to determine the i atmospheric stacility. l

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3.3.20 Accident Samoling (primary coolant', containment air and sumo)

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) The M ensee's sample system can obtain samples and provide the analys'se within the ranges recommended for t'is variable with the following exceptions-

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Containment air hydrogen content - the range is 0 to 10 percent Containment air oxygen content - tSe range is 0 to 10 percent 5

The licensee considers this adequato since the maifmO;.1 range covers into the explosive mixture region.

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- r The licensee ceviates fh,ec ' ,egulatory Guide 1.97 with respect to ,

post-accident samoling .cpebC]ity, g This deviation goes beyond the scope of thisreviewandhasbyt>iaddressedb3theNRCaspartofthereviewof NUREG-0737, Lten II.S',7,

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4 CONCLUSIONS Basec on our review, we finc that the licensee either conforms to or is justified in ceviating from Regulatory Guide 1.97, with the following exceptions:

1. Neutron flux--tne existing instrumentation is acceptable until Category 1 instrumentation is developed and installed (Section 3.3.1).

2. Drywell pressure--the 1icensee should record this variable (Section 3.3.2).

3. Primary containment area radiation--the licensee should show that this instrumentation meets the original station seismic criteria (Section 3.3.8).

4 Radiation exposure rate--the licensee should show that the ranges supplied for this variable encompass the radiatios, levels expected at the instrument locations (Section 3.3.10).

5. Diesel generator cooling water system flow--the licensee should provide Category 2 flow instrumentation for this system (Section 3.3.13).

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6. Emergency ventilation damper position--the licensee should verify that tne alternate instrumentation is Category 2 (Sectier. 3.3.14).

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that the ranges supplied for this variable encompass the

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radiation levels expected at the instrument locations (Section 3.3.15). )

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8. Particulate and. halogens--the licensee should show that the proviced range encompasses the recommenced range (Section 3.3.16).

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. ,nstrumentani?r dut covers tne recommended range (Section 3.3.17).

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5. REFERENCES

1. NRC letter, D. G. Eisenhut co All Licensees of Operating Reactors, Applicants for Operating Licenses, and Holders of Construction permits, " Supplement No. I to NUREG-0737--Requirements fo- Emergency Response Capability (Generic Letter No. 82-33)," December 17, 1982. l Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess

2. j Plant and Environs Conditions During and Following an Accident, j Regulatory Guice 1.97, Revision 2, NRC, Of fice of Standards i Development, December 1980.

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... Clarification of TMI Action Plan _ Requirements, Requirements for Emergency Response Caoability, MJREG-0737, Supplement No.1, NRC, Office of Nuclear Reactor Regulation, January 1983.

4. Letter, Commonwealth Edison Company (J. R. Wojnarowski) to NRC 1 (D. B. Vassallo), " Compliance with Regulatory Guide 1.97,"

August 1, 1985.

5. Letter, Commonwealth Edison Company (J. R. Wojnarowski) to NRC l (H. R. Denton), " Implementation Schedule for Regulatory Guide 1.97 Modifications," January 31, 1986. )

6. Letter, Commonwealth Edison Company (J. R. Wojnarowski) to NRC (H. R. Denton), " Regulatory Guide 1.97 Modification Schedule,"

i October 6, 1986.

7 Letter, Commonwealth Edison Company (I. M. Johnson) to NRC  !

(T. E. Murley), "Drywell Pressure Instrumentation Regulatory Guide 1.97 Commitment," May 28, 1987. l I

S. Letter, Commonwealth Edison Company (I. M. Johnson) to NRC )

(T. E. Murley), " Reg. Guide 1.97 Commitments Regarding Acoustic Monitoring and Containment Hydrogen Analyzers," May 29, 1987.

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9. Letter, Commonwealth Edison Comapny (J. R. Wojnarowski) to NRC (H. R. Denton), " Emergency Response Facility Regulatory Guide 1.97 Review," Novemoer 4, 1985.

10. Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess I Plant anc Environs Conditions During and Following an Accident, Regulatory Guice 1.97, Revision 3, NRC, Of fice of Nuclear Regulatory Research, May 1983.

11. Onsite Meteorolicical Programs, Regulatory Guide 1.23, NRC 1 Feorua ry 17, 1972 or Meteorological Programs in Support of Nuclear

. Power Plants, Proposeo Revision 1 to Regulatory Guide 1.23, NRC, Office of Standards Development, September, 1980.

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CONFORMANCE TO REGULATORY GUIDE 1.97: QUAD CITIES-1  !

i AND ~2 e o.ra na ont CoweLetto j v a~ r .s.a j l

s . , .o. ,, , August 1987 i Alan C. Udy

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EG&G Idaho, Inc.

P. O. Box 1625 e8.~oaar. t=w=na I Idaho Falls, 10 83415 )

'O S*C Soni G omo.~ig.T so. ~.wt .~o w.e,i o .Dont&& ##ser,v.s to C#esus iia TvetopmePont Division of Engineering and System Technology i Office of Nuclear Reactor Regulation '

i U.S. Nuclear Regulatory Commission e naioo Conaio - --->

Washir.gton, DC 20555 l l

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This EG&G Idaho, Inc. report reviews the submittals from Quad Cities for Regulatory Guide 1.97 and identifies areas of nonconformance to the regulatory guide. Exceptions  ;

to these guidelines are evaluated and those areas where sufficient basis for acceptability is not provided are identified.

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