ML17328A146
| ML17328A146 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/11/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17328A145 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8909180372 | |
| Download: ML17328A146 (3) | |
Text
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO INDIANA MICHIGAN POWER COMPANY DONALD C.
COOK NUCLEAR PLANT UNITS NOS.
1 AND 2 DOCKETS NOS.
50-315 AND 50"316 CONFORMANCE TO REGULATORY GUIDE 1.97 1.0 INTfCE:UCTIOh Indiana Michigan Power Company was requested by Generic Letter 82-33 to provide a report to tlRC describing how the post-accident monitoring instrumentation meets the guioelirIes of Regulatory Guide (R.G.) 1.97 as appIied to emergency response facilities.
The licensee responded to Item 6.2 of the ceneric letter on February 28, 1985.
Adaitional information was providea by Ietters dated October 15, 1985, September 23, 1986, March 6, 1987,
~IIe 2g ig87
.'and October 5, 198B.
A detai led review ana technical evaluation of the licensee's submittals was performea by EGhG Idaho, Inc., under a contract to the NRC, with general supervision by the NRC staff.
This work was reported by EGSG in Technical Evaluation Report (TER), "Conformance to Regulatory Guide 1.97: Gook-1/-2,"
dated August 1989 (attached).
Ke have reviewed this report and concur with the conclusion that the licensee either conforms to, or has adequately justified deviations from, the guidance of R.G. 1.97 for each post-accident monitoring variable except for the variable wide range steam generator level.
2.0 EVALUATION CRITERIA Subsequent to the issuance of the generic letter, the MRC held regional meetings in February and Mar ch 1983 to answer licensee and applicant questions 89%'i80372 Sg09ii PDR ADOCK 0 0003i5 P
and concerns regarding the NRC policy or! P..G. 1.97.
At these nieetings, it was established that the NRC review wculo only address exceptions taken to the guidance of R.G. 1.97.
- Further, where licensees cr applican.s expl>citly
=tate that irstrument systems conform to provisscns of the regulatory guise, i,o further taff revie~ woula bt tecessarv fnr those items.
Therefore, the i~.view per i'.;t:c and reported by EGRC only addresses except ons to the guidance o; t..G. 1.97.
This safety evaluatior addresses the licensee's submittals based on the review pol'.cy oescrsbed in the NRC regional meetincs and the cerclusions o-
-.he review as reportec l,y EC4G.
3.G EVALUATlCV l'e have
~eviewed the ~evaluation performed L'y EGImG contairec in the attached
.ER and concur with, its bases ana fin@i)!gs.
The licensee e>ther conforms to, or has prov;oeo an acceptable justification for deviatiors from the guidance of R.G. 1.97 for each post-accident monitoring variable except tur the var>able wide rance steam generator level.
R.G.
1.97 recommends Category 1 w>de range steam generator level instrumentat>on, with a range from the tube sheet to the separators, to monitor the operation of the steam generators.
The instrumentation provided by the licensee does not meet the environmental qualification criteria for Category 1 instrumentation as recoomended in R.G. 1.97.
This instrumentation uses Class 1E power.
However, the same power source is used for each wide range channel.
The licensee states that Category 1 narrow range level instrumentation could be used to aooitor heat sink capability. If the water level is not within the range of this ihstrusentation, the licensee would use auxiliary feedwater flow to indicate the availability of the steam generators as a heat sink.
Ne find the licensee's justification for this deviation unacceptable.
The purpose of wide range steam generator level measurement is for the identification and mitigation of an accident and for determining the availability of the steam generators as heat sinks.
As such it is necessary that the operator have a positive indication of water level so that he is sure
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of the exact status of the steam generators at all times.
The loss of the single power source would cause the loss of a'i'ide range steam generator level channels.
Environmenta'. (ualification has beer: clarified by the Environmental Qualificatior kilo, 10 CFR 50.49.
The I>censee shoulo provide environmentally qualified wide range steam generator ievel instrumentation in accordance with the provisions of 10 CFR 50.49.
The licensee should also provide redundant Class 1E power sources; one source to two cf the steam generators ona the secona source to the ether two steam generators.
4.C CONCLUSInN Based on the staff's review of the enclosed TER ard the licensee's submittals, we find that the Donald C.
Cook Nuclear Plant Unit Nos.
1 and 2 design is acceptable with respect to corformance to R.G. 1.97, Revision 3, except for the Instrumentation associated with the variable wide range steam generator level.
It is the stafT's position that wide range steam generator level indication is needed by the operator in the evaluation of the availability of the steam generators as a heat sink. It is also the staff's position that the licensee should install wide range steam generator level monitoring instrumentation which fully complies with the Category 1 criteria of R.G. 1.97, which includes environmental qualification and redundant Class lE power supplies.
An appropriate implementation schedule will be developed by the project manager via discussion with the licensee.
Once the schedule is established, the licensee is required to inform the Ceanission, in writing, of any significant changes in the established completion schedule identified in the staff's safety evaluation and when the action has actually been completed.
Principal Contributor:
B. marcus Dated:
September 11, 1989