ML17306A727

Forwards Safety Evaluation Accepting post-accident Instrumentation as Category 3 Qualification Since No Operator Action Based on Instrumentation & Does Not Perform Safety Function

ML17306A727
Person / Time
Site:	Palo Verde
Issue date:	05/05/1992
From:	Trammell C Office of Nuclear Reactor Regulation
To:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML17306A728	List: ML17306A727 ML17306A729
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 9205190231
Download: ML17306A727 (6)

Text

~p,S REGS~

s P

p~

~Cy C

I pp lA P

r

/p

~O

+a*++

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 May 5, 1992 Docket Nos. 50-528, 50-529 and 50-530 Mr. William F.

Conway Executive Vice President, Nuclear Arizona Public Service Company P.O.

Box 53999

Phoenix, Arizona 85072-3999

SUBJECT:

INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT (REGULATORY GUIDE 1.97)

Section 6.2 of Generic Letter 82-33 requested licensees to provide a report on their implementation of Regulatory Guide 1.97 (Revision 2), including methods for complying with the Commission's regulations and supporting technical justification for any proposed alternatives or deviations.

A large number of exception requests were received from PWR licensees asking that the environmental qualification requirement for accumulator (safety injection tank) level and pressure monitoring instrumentation be relaxed from Category 2

to Category 3, which would allow commercial grade instruments to be used.

Prior to 1987, these requests were denied by the staff.

Since then, these exception'requests have been considered as open items until a generic resolution could be found.

The staff has now reviewed the bases for these exceptions and has concluded that no operator action is based on this post-accident instrumentation and that it does not perform a safety function.

In addition, successful performance of core cooling systems can be inferred from other environmentally qualified instrumentation.

Since this instrumentation does not perform any post-accident safety function, its qualification requirements can be reduced to Category 3.

A copy of the Safety Evaluation is enclosed.

ago f~ ~3

+Q~QPP0528~

P

r

'1 E

N 1

~(

V

Mr. William F.

Conway You have installed Category 2 instrumentation to monitor accumulator level and pressure.

You are no longer bound by this commitment, and may, at your discretion, replace this instrumentation with Category 3 instrumentation.

You are requested to notify us of the actions you plan to take and the schedule for implementation.

Please contact us if you have any questions regarding this matter.

Sincerely, C

Charles M. Trammell, Senior Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Projects

Enclosure:

Safety Evaluation cc w/enclosure:

See next page

~ 1

Mr. William F.

Conway Arizona Public Service Company Palo Verde CC:

Nancy C. Loftin, Esq.

Corporate Secretary

& Counsel Arizona Public Service Company P. 0.

Box 53999, Mail Station 9068

Phoenix, Arizona 85072-3999 James A. Beoletto, Esq.

Southern California Edison Company P. 0.

Box 800

Rosemead, California 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission HC-03 Box 293-NR Buckeye, Arizona 85326 Regional Administrator, Region V

U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. William A. Wright, Acting Director Arizona Radiation Regulatory Agency 4814 South 40 Street

Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors ill South Third Avenue

Phoenix, Arizona 85003 Jack R.

Newman, Esq.

Newman 8 Holtzinger, P.C.

1615 L Street, N.W., Suite 1000 Washington, D.C.

20036 Curtis Hoskins Executive Vice President and Chief Operating Officer Palo Verde Services 2025 N. 3rd Street, Suite 220

Phoenix, Arizona 85004 Roy P.

Lessey, Jr.,

Esq.

Bradley W. Jones, Esq.

Arkin, Gump, Strauss, Hauer and Feld El Paso Electric Company 1333 New Hampshire Ave., Suite 400 Washington, D.C.

20036

\\

t