ML17262B095

Summary of 920916 Meeting W/Util Re Emergency Response Capability

ML17262B095
Person / Time
Site:	Ginna
Issue date:	11/24/1992
From:	Andrea Johnson Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
TAC-M80439, NUDOCS 9212070069
Download: ML17262B095 (32)

Text

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November 24, 1992 Docket No. 50-244 LICENSEE:

Rochester Gas and Electric Corporation UTILITY:

R.E.

Ginna Nuclear Power Plant

SUMMARY

OF MEETING WITH ROCHESTER GAS AND ELECTRIC CORPORATION ON EMERGENCY RESPONSE CAPABILITY SEPTEMBER 16, 1992 (TAC NO. M80439)

Rochester Gas and'lectric Corporation (RG&E), in an NRC meeting on September 16, 1992, at NRC Headquarters, discussed the Request for Additional Information (RAI) dated July 7,

1992, (Enclosure 2) on Ginna Station's conformance with provisions of Regulatory Guide 1.97, Revision 3.

RGIIE's 90-day response to the RAI was provided to the NRC staff on October 14, 1992.

A copy of a list of meeting attendees is included in Enclosure l.

Enclosure 3

is a meeting summary.'nclosures:

1.

List of Attendees 2.

Request for Additional Information 3.

Meeting Summary cc w/enclsoure:

See next page Original signed by Allen R. Johnson, Project Manager Project Directorate I-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation DISTRIBUTION W ENCLOSURES:

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 November 24, 1992 Docket No. 50-244 LICENSEE:

Rochester Gas and Electric Corporation UTILITY:

R.E.

Ginna Nuclear Power Plant SUBJECT'UMMARY OF MEETING WITH ROCHESTER GAS AND ELECTRIC CORPORATION ON EMERGENCY RESPONSE CAPABILITY SEPTEMBER 16, 1992 (TAC NO. H80439)

Rochester Gas and Electric Corporation (RG&E), in an NRC meeting on September 16, 1992, at NRC Headquarters, discussed the Request for Additional Information (RAI) dated July 7,

1992, (Enclosure 2) on Ginna Station's conformance with provisions of Regulatory Guide 1.97, Revision 3.

RG&E s 90-day response to the RAI was provided to the NRC s'..aff on October 14, 1992.

A copy of a list of meeting attenc's is included in Enclosure l.

is a meeting summary.

Enclosures:

1.

List of Attendees 2.

Request for Additional Information (RAI) 3.

Meeting Summary cc w/enclosure:

See next page Alle R. Johns n, Project Manager Proj ct Oirec rate I-3 Divis eactor Projects I/II Office of Nuclear Reactor Regulation

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R.E. Ginna Nuclear Power Plant CC:

Thomas A. Moslak Senior Resident Inspector R.E. Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road

Ontario, New York 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Hs.

Donna Ross Division of Policy Analysis 5 Planning New York State Energy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Charlie Donaldson, Esq.

Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Nicholas S.

Reynolds Winston 8 Strawn 1400 L St.

N.W.

Washington, DC 20005-3502 Hs. Thelma Wideman

Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7370 Route 31

Lyons, New York, 14489

~0 Ms. Mary Louise Meisenzahl Administrator:,, Monroe County Office of Emergency Preparedness ill West Fall'oad, Room 11 Rochester, New York 14620 Dr. Robert C. Hecredy Vice President, Nuclear Production Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649 Hr. George Wrobel Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649 Hr. Brian Flynn Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649

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ENCLOSURE 1

LIST OF MEETING ATTENDEES G

NNA EME GENCY RESPONSE CAPABILITY MEETING SEPTEMBER 16 1992 NAME Allen Hansen George Wrobel Brian Flynn R. J. Paolino Barry Marcus Angelo Marinos William Lazarus Scott Newberry-Al Johnson Tom Moslak ORGANIZATION NRR/DRP RG&E RG&E NRC:RI NRR/S ICB NRR/SICB NRC:RI NRR/SIC B NRR/DRP NRC SRI TELEPHONE NO.

301-504-1390 716-724-8070 716-546-2700 x4805 215-337-5285 301-504-2823 301-504-2911 215-337-5231 301-504-2821 301-504-1497 315-524-6935

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R U ST FOR AOO TIONAL INFORMAT ON RA B

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F CE OF NUC AR REACTOR R GULATIO CONFORMANCE TO R GULATORY GUIDE 1.97 ROCHEST R

GAS AND E CTR C

COMPANY

~ll.. GINIIA OCK T NO. 50- 44 RCS Cold e

Water Tem erature 2.

Regulatory Guide (R.G.) 1.97 recommends Category 1 instrumentation to monitor RCS cold leg water temperature.

Category 1 criteria include recording the signal from at least one channel of instrumentation.

Rochester Gas and Electric (RG&E) has two channels of instrumentation to monitor this variable,

however, they do not record this variable.

RG&E should record at least one channel of RCS cold leg water temperature information.

This recording can be via dedicated

recorder, computer, or data logger.

Containment Sum Water Level - Narrow Ran e

3.

R.G.

1.97 recommends that narrow range containment sump water level be monitored by instrumentation with a range of top to bottom of the sump.

RG&E lists the range of this instrumentation as zero to 30 feet.

RG&E also lists the range of the wide range containment sump water level instrument up to 214 inches.

The narrow range appears to be wider than the wide range.

RG&E should resolve this apparent discrepancy.

Containment Isolation Valve Posit on R.G.

1.97 recommends Category 1 instrumentation to monitor the position of containment isolation valves.

Category 1 criteria include environmental qualification of those instruments and circuit components that can be exposed to a harsh environment.

Since there are redundant containment isolation valves, redundant indication for each isolation valve is not required.

RG&E states that the containment isolation valves located outside of containment do not encounter a harsh environment until after the automatic containment isolation signal has been bypassed.

This harsh environment con~ists of radiation shine from recirculating fluids, in the order of 10 Rads.

RG&E has not provided data that validates the assumption that the valve position switches will survive this environment.

This environment occurs late in the recovery phase of an accident.

The operator has time to verify valve position before a harsh radiation environment occurs, but RG&E has not addressed procedures that direct the operator to do this.

RG&E should show how the recovery procedures verify the position of the containment isolation valves.

J

Category 1 criteria also include seismic qualification.

RG&E states that, while the containment isolation valve position indication lamp holders are seismically qualified, the lamps themselves are not.

The lamps are identified only as "commercially rugged."

RG&E should provide additional information about the seismic testing and capabilities of the lamps and the assemblies.

The information should show that these lamps are similar to other lamps that have been seismically qualified.

4.

RHR Heat Exchan er Outlet Tem erature 5.

R.G.

1.97 recommends Category 2 instrumentation to monitor residual heat removal (RHR) heat exchanger outlet temperature.

Category 2 criteria include environmental qualification.

RG8E indicates that this instrumentation loop is not environmentally qualified.

RG8E stated that performance of decay heat removal is sufficiently monitored by Category 1

RCS hot leg temperature, RCS cold leg temperature, core exit temperature, and sump temperature.

RG&E has not provided.information detailing how these instruments provide the status of the RHR system oper ation.

RG&E should either describe how this alternate instrumentation provides RHR system operation and decay heat removal information or provide environmentally qualified RHR heat exchanger outlet temperature instruments.

Refuelin Water Stora e Tank eve R.G.

1.97 recommends Category 1 instrumentation to monitor the refueling water storage tank level.

Category 1 criteria include independent, separate power sources for the redundant instrument channels.

RG8E states that the instrument loop for transmitter LT-920 is powered from instrument bus 1C and the instrument loop for transmitter LT-921 is powered from instrument bus 1A.

Computer indication for LT-920 also receives power from instrument bus 1A.

RG&E should address the potential loss of instrument bus 1A affecting both channels and ensure that the loss of any one power source will not cause the loss of both redundant instrument channels.

6.

Prim te Powe 0 e ated Relief give Positio RG&E has identified the power operated relief valve (PORV) position indication as a Type A variable.

Type A variables must meet the Category 1 criteria which include independent Class 1E power sources.

RG8E states that there are two PORVs, each with its own block valve.

The position indication for PORVs are powered from safety-related battery bus B.

Loss of safety-related battery bus B would cause the loss of the position indication for both valves.

RG&E should provide an independent power supply for each of the two PORVs.

Category 1 criteria also include seismic, qualification.

RG8E states that, while the PORV position indication lamp holders are seismically

qualified, the lamps themselves are not.

The lamps are identified only as "commercially rugged."

RG&E should provide additional information about the seismic testing and capabilities of the lamps and the assemblies.

RG&E should show that these lamps are similar to other lamps that have been seismically qualified.

7.

Hain Steam Flow RG&E classifies main steam flow as a Type A variable.

Type A variables must meet the Category 1 criteria.

Category 1 criteria include independent, redundant Class 1E power sources.

RG&E lists three power sources for the main steam flow instruments for steam generator A.

These are instrument buses lA, 1B, and 1A/1C.

For steam generator B,

the main steam flow instrumentation power sources are instrument buses 1C, 1D, and 1A/1C.

Instrument bus 1D is not Class lE.

The nomenclature for instrument bus 1A/1C is not clear.

The staff assumes that there is an auctioneering circuit between instrument buses 1A and 1C.

However, RG&E's submittals do not show that the power circuits remain independent and redundant.

RG&E should clearly show that the power sources for this instrumentation are independent and redundant.

Using instrument bus 1D to power one instrument loop would be acceptable if the other two instrument loops have independent Class.

1E power sources.

8.

Letdown Outlet Flow R.G.

1.97 recommends instrumentation to monitor letdown outlet flow with a range of zero to 110 percent.

The instrumentation provided by RG&E has a range of zero to 100 gallons per minute.

The upper limit of the span is equal to 100 percent.

RG&E has not provided justification for this deviation.

RG&E should either justify this deviation or provide letdown outlet flow instrumentation with a range of zero to 110 percent.

9.

Hi h-Level Radioactive i

id Tank Level R.G.

1.97 recommends instrumentation to monitor high radioactive liquid tank level.

RG&E identifies waste drain tank level (LT-1001) and reactor coolant drain tank level (LT-1003) for this variable.

The instrumentation provided for loop LT-1003 is acceptable.

However, RG&E has no display, readout, or recording for loop LT-1001.

RG&E has not provided justification for this deviation.

RG&E should either justify this deviation or provide display, readout, and/or recording of the loop LT-1001 information.

10.

Status of Standb Power R.G.

1.97 recommends plant specific Category 2 instrumentation to monitor the status of standby power.

RG&E has identified the parameters to be monitored for this variable.

However, RG&E has no display,

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readout, or recording for loop PT-1066 (nitrogen gas pressure).

RGEE should either justify this deviation or provide display,

readout, and/or recording of the loop PT-1066 information.

11.

Particulates and Halo ens R.G.

1.97 recommends an instrument span of 10 pCi/cc to 10 pCi/cc for monitoring particulates and halogens.

The instrumentation provided by RG8E satisfies this recommendation for the lower end of the instrument span.

The upper end of the span deviates as follows:

R-12A, containment vent particulates 10 pCi/cc halogens 1 pCi/cc R-14A, plant exhaust vent particulates 50 pCi/cc halogens 25 pCi/cc RGEE has not provided justification for these deviations.

RG8E should either justify these deviations or provide particulates and halogens instrumentation with ranges in accordance with R.G. 1.97.

12.

Plant and nvirons Radiatio R.G.

1.97 recommends portable sampling with onsite analysis capability to monitor plant and environs rqdi ation.

R.G.

1.97 recommends an analysis span of 10 R/hr to 10 R/hr for photons, and 10 rads/hr to 10'ads/hr for beta radiation and low-energy photons.

The instrumentation provided by RG&E satisfies the recommendation for the lower end of the analys s span.

The upper end of the span deviates, with capabilities to 10 R/hr and 10 rads/hr respectively.

RG&E has not provided justification for these deviations.

RGEE should either justify these deviations or provide plant and environs radiation instrumentation with ranges in accordance with R.G. 1.97.

13.

Redundanc and Se grat on R.G. 1.97 recommends redundant channels for Category 1 instrumentation that are electrically independent and physically separated.

Physical separation applies to safety-related redundant channels and separation from other equipment not classified important to safety, up to and including isolation devices.

RGIIE states that physical separation between channels is according to the design criteria in effect at the time of installation.

As RG&E's design predates the R.G. 1.75 separation criteria, not all Category 1 channels have complete physical separation.

RGIIE states that the control room does not necessarily have physical separation between channels.

The staff finds this to be a good faith attempt (as defined in NUREG-0737, Supplement No. 1, Section 3.7) to meet NRC requirements.

Therefore, the redundancy and separation is acceptable for those Category 1 variables where instrumentation is not otherwise upgraded to

meet the R.G.

1.97 recommendations.

This deviation does not preclude the use of redundant (that is, two or more) channels of instrumentation for Category 1 or Type A variables.

Where RG&E modifies Category 1

instrumentation, redundancy and separation should be provided for those portions of the instrumentation modified.

Since RGKE's design predates the R.G.

1.75 separation criteria, not all modifications can fully comply with the redundancy and separation criteria of R.G. 1.97.

RGSE should describe constraints on separation that the licensee will adhere to for future modifications of R.G.

1.97 instrumentation.

RGEE should detail plans for a commitment to R.G.

1.97 addressing redundancy and separation, as they apply to future design changes.

ui ment Identification R.G.

1.97 recommends that Type A, B, and C instruments designated as Category 1 or 2 should be specifically identified with a common designation on the control panels so that the operator can easily discern that these instruments are intended for use under accident conditions.

RGKE has not provided any control room identification of this instrumentation.

RG8E states that a

common designator would only be appropriate where several redundant instrument channels are provided of which only a few are post-accident qualified.

However, RGKE has not shown this to be the predominant case.

Without identification the Category 1 and 2

instrumentation are indiscriminate from Category 3 and non-post-accident instrumentation.

The intent of identifying the R.G.

1.97 instrumentation is to provide the operator with identification of a minimum set of instruments to monitor during post-accident situations.

This identification would not restrict the operator to use only those instruments identified.

The operator may supplement the R.G.

1.97 instrumentation with other instrumentation.

The staff has reviewed the R.G.

1.97 recommendations on the identification of R.G.

1.97 instrumentation and has determined that the Type A and the Category 1 instrumentation need control room identification.

RG8E should develop a methodology for identifying post-accident monitoring instrumentation in the control room.

The control room Type A and the Category 1 R.G.

1.97 instruments should be identified by the developed methodology.

The operators should be trained in the use of the common designator.

15.

Interfaces R.G. 1.97 recommends the use of qualified isolation devices whenever Category 1 and Category 2 instruments interface with instrumentation or control circuits that have less stringent design criteria.

The isolation devices should be considered part of the monitoring

instrumentation circuits.

The isolation devices should meet the same design criteria as the instrument loop being isolated.

RG&E states that there may be no isolation between post-accident instrumentation and other uses, such as controllers and alarms.

RG&E has not provided

details, described the circuits without isolation devices, or given justification for not providing the isolation recommended by the regulatory guide.

RG&E should identify and provide justification for any Category 1 or Category 2 instruments that interface with instrumentation or control circuits that have less stringent design criteria.

16, Commitment to R.G.

.97 Generic Letter No. 82-33 (NUREG-0737, Supplement No.

1) recommends that licensees and applicants document how they meet the recommendations of R.G. 1.97.

The generic letter also recommends that licensees and applicants explicitly show deviations from the guidance in R.G.

1.97 and to present supporting justification or alternatives.

In lieu of a commitment to R.G. 1.97, RG&E has provided a comparison of existing instrumentation attributes with the criteria provided in R.G. 1.97.

RG&E has made no commitments concerning the R.G.

1.97 criteria for future post-accident instrumentation modifications.

RG&E's design predates the R.G.

1.75 separation criteria, thus not all modifications can fully comply with the redundancy and separation criteria of R.G. 1.97.

RG8E should describe constraints on separation that the licensee will adhere to for future modifications of R.G.

1.97 instrumentation.

RG&E should detail plans for a commitment to R.G.

1.97 addressing redundancy, separation, and any other criteria not in full conformance with R.G. 1.97, as they apply to future design changes.

A

Enclosure 3

~R.E.

GINN EMERGENCY RESPONSE CAPABI ITY M ETING

SUMMARY

SEPTEMBER 16 1992 The NRC staff followed the Request for Additional Information (RAI) dated July 7, 1992 (Enclosure

2) as an outline for discussions with Rochester Gas and Electric Corporation (RG&E) with the following commitments and conclusions:

RAI I - Reactor Coolant S stem Cold Le Water Tem er ture The licensee's submittals indicated that Reactor Coolant System (RCS) cold leg water temperature information is not recorded.

During the meeting the licensee stated that they plan to record RCS cold leg water temperature from a Category I source.

The licensee has not determined what type of recording this will be or when it will be implemented.

The licensee will provide this information in a future submittal.

RAI 2 Containment Sum Water Level Narrow Ran e

The licensee's submittals listed the range of narrow range containment sump water level instrumentation as zero to 30 feet and the range of the wide range containment sump water level instrumentation as up to 214 inches.

The narrow range appeared to be wider than the wide range.

During the meeting the licensee explained the relationship between the narrow range and wide range containment sump instrumentation.

The narrow range monitors up to 45,000 gallons in the instrument sump and the wide range monitors up to 500,000 gallons in the recirculation sump.

RAI 3

Containment Isolatio Valve Position The licensee's submittals described seven containment isolation valves, located outside containment, that encounter a harsh environment after the automatic containment isolation signal has been bypassed.

The submittals described the harsh environment but did not provide data that validates the assumption that these position switches will survive this environment or how the operator verifies valve position.

The submittals also stated that, while the containment isolation valve position indication lamp holders are seismically qualified, the lamps themselves are not.

The lamps are identified only as "commercially rugged."

The submittals did not provide additional information about the seismic testing and capabilities of the lamps and the assemblies

I that show that these lamps are similar to other lamps that have been seismically qualified.

During the meeting the licensee stated that the position switches of the seven outboard valves described above are in a mild environment for 30 minutes after accident.

The position of the valves are verified during this mild environment.

The valves will not change position without specific operator action, which is controlled by procedures.

The licensee noted that indicating lamps would be qualified as part of their participation in a seismic qualification utility owners group (SHRUG) for resolution of unresolved safety issue (USI) A46, in response to Generic Letter (GL) 87-02, Supplement l.

RAI 4 Residual Heat Removal Heat Exchan e

Outlet Tem erature The licensee's submittals indicated that instrumentation to monitor Residual Meat Removal (RHR) heat exchanger outlet temperature is not environmentally qualified.

The submittals identified alternate instrumentation that would be used to monitor performance of decay heat removal.

However, the submittals did not provide information detailing how this alternate instrumentation would provide the status of the RHR system operation.

During the meeting the licensee stated that a harsh environment only exists during recirculation when significant fuel failure has occurred during a large break loss of coolant accident (LOCA).

The heat exchanger would be lined up manually for recirculation.

The reactor vessel level instrumentation system (RVLIS), core exit temperature, containment

pressure, RCS pressure, RHR flow, and containment sump water temperature can be used to determine RHR heat exchanger operation.

RAI 5 Ref elin ater Sto a

e Ta Level The licensee's submittals identified portions of redundant refueling water storage tank (RWST) level instrument channels that are powered from the same power source.

The submittals did not address the effect of a potential loss of the single instrument bus the feeds both channels.

During the meeting. the licensee stated that isolation is provided between. the. redundant RWST instrument loops.

The loss of the single instrument bus would not cause the loss of both channels of indication.

RAI 6 Primar S stem Safet Valve osit'o The licensee's submittals identified power operated relief valve (PORV) position as a Type A variable.

The submittals stated that the position indication for the PORVs are powered from the same power source.

The

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submittals did not provide any information concerning the block valves, block valve position indication, or block valve position indication power supplies.

The submittals also stated that, while the PORV position indication lamp holders are seismically qualified, the lamps themselves are not.

The lamps are identified only as "commercially rugged."

The submittals did not provide additional information about the seismic testing and capabilities of the lamps and the assemblies showing that these lamps are similar to other lamps that have been seismically qualified.

During the meeting the licensee stated that PORV position was misclassified as a Type A variable.

The correct classification is Type D, Category 2.

RGLE will document this change in classification by a letter to NRC.

RAI 7 - Hain Steam Flow The licensee's submittals identified main steam flow as a Type A variable.

The submittal listed both Class 1E and non-Class lE power sources for this instrumentation.

During the meeting the licensee stated that main steam flow was misclassified as a Type A variable.

The correct classification is Type D, Category 2.

RG8,E will document this change in classification by a letter to NRC.

RAI 8 Letdown Flow-Out The licensee's submittals listed letdown flow-out instrumentation with a range of zero to 100 gallons per minute (gpm).

This is a deviation from the recommended range of zero to 110 percent.

The submittals did not provide justification for this deviation.

During the meeting the licensee stated that the maximum letdown flow is 60 gpm, and not 100 gpm as previously noted.

Therefore the 100 gpm upper limit of the range is 167X of design flow.

RAI 9 Hi

- evel Radio ctive i uid Tank Level The licensee's submittals did not identify any control room instrumentation to monitor high-level radioactive liquid tank level.

During the meeting the licensee stated that instrumentation monitoring high-level radioactive liquid tank level is located at the Waste Disposal Panel in the Auxiliary building and in the Technical Support Center, with an alarm in the control room.

An operator would be dispatched to the Waste Disposal Panel or the Technical Support Center if needed.

RAI 10

Status of Standb Power The licensee's submittals identified nitrogen gas pressure as a status of standby power variable.

However, the submittals did not identify any control room instrumentation to monitor nitrogen gas pressure.

During the meeting the licensee stated that nitrogen gas pressure is not an energy source.

Therefore it will removed from the list of Regulatory Guide (R.G.) 1.97 instrumentation.

RAI 11 - Particulates and Halo ens The licensee's submittals identified deviations in the ranges for instrumentation to monitor particulates and halogens.

\\

During the meeting the licensee stated that these range deviations were previously accepted in the staff's December 4,

1990, Safety Evaluation Report (SER).

RAI 12

Plant and Environs Radiation The licensee's submittals identified deviations in the ranges for instrumentation to monitor plant and environs radiation.

During the meeting the licensee stated that these range deviations were previously accepted in the staff's December 4,

1990, SER.

RAI 13

Redundanc and Se aration The licensee's submittals stated that physical separation between channels is in accordance with the design criteria in effect at the time of installation.

The design predates the R.G.

1.75 separation criteria.

Therefore, not all Category 1 channels have complete physical separation.

The submittals also stated that the control room does not have physical separation between channels.

However, the submittals did not address separation for any future modifications.

During the meeting. the licensee stated that modifications to the control room will be in accordance with the existing design of the control room.

When modifying safety related electrical circuits, outside of the control room, including post-accident Category 1

instruments, the licensee will attempt to comply with IEEE Standard 384-1981, Section

6. 1 separation criteria, if practicable.

Deviations from this criteria will be addressed in the modification specific safety analysis.

The licensee does not consider that separation of individual redundant circuits in the control room would provide any significant benefit, given the overall existing design.

A

RAI 14

E i

e t Identification The licensee's submittals stated that identification of post-accident monitoring instrumentation is not provided in the control room.

During the meeting the licensee stated that a common designator would only be appropriate where several redundant instrument channels are provided of which only a few are post-accident qualified.

In almost all cases, all control room instruments are equally qualified.

The licensee will investigate further those instances where multiple instrument channels have different qualifications.

The licensee will document a method that will ensure that operators are aware that these channels may not provide correct indication in post-accident situations.

RAI 15

Interfaces The licensee's submittals stated that there may be no isolation between post-accident instrumentation and nonpost-accident instrumentation, such as controllers and alarms.

The subm'ittals did provide details,-

describing the circuits without isolation devices, or give justification for not providing the isolation recommended by the regulatory guide.

During the meeting the licensee stated that isolation has been provided between the protection circuits and the control circuits.

However isolation has not been provided between original control grade indicators that provide Category 1 indication and other control grade instrumentation.

When it can be accommodated during a major modification, efforts are made to isolate and upgrade Category 1

indicators in accordance with current standards.

The licensee considers this to be a good faith effort to meet the intent of R.G. 1.97.

The licensee will investigate performing an analysis of a typical circuit to show. that isolation is not needed between original control grade indicators that provide Category 1 indication and other control grade instrumentation.

However, the licensee stated that the results of such an investigation may not be available when the licensee responds to the RAI.

RAI 16 Commitment to R.G.

1.97 The licensee's submittals did not include a commitment to R.G. 1.97.

In lieu of a commitment to R.G.

1.97 the submittals provided a

comparison of existing instrumentation attributes with the criteria provided in R.G. 1.97.

The licensee has made no commitments concerning the R.G.

1.97 criteria for future post-accident.instrumentation modifications.

During the meeting the licensee stated that post-accident instrumentation is identified in the plants Final Safety Analysis Report.

As such, any modifications to the equipment must have a safety evaluation performed in accordance with 10 CFR 50.59.

This assures that future modifications to the post-accident instrumentation will not degrade its performance.

The licensee stated that they attempt to comply with current standards for separation, redundancy, and isolation.

Modification specific safety evaluations document acceptability if the standards cannot be met.-

The following items, although not included in the RAI, were discussed in the meeting:

Neutron Flux The licensee's submittals included a detailed proposal that included deviations from R.G.

1.97 for neutron flux monitoring instrumentation.

The staff has focused on neutron flux monitoring in BWRs and has not performed technical review of the licensee's position.

2.

Containment Resista ce Tem eratu e Detecto s

The licensee stated that containment resistance temperature detector (RTD) qualification testing would not be completed until the first quarter of 1993, and not the third quarter of 1992, as previously indicated.

This date is consistent with their intended use during the 1993 integrated leak rate testing (ILRT).

Based on the discussions at the meeting the licensee agreed to address the issues in the RAI, in a letter to be issued by October 14, 1992.

f 4