ML18019A538

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Safety Evaluation Concurring W/Conclusion That Applicant Conforms to or Is Justified in Deviating from Reg Guide 1.97 for Each post-accident Monitoring Variable,Except for Variables Re Accumulator Tank Level & Pressure
ML18019A538
Person / Time
Site: Harris 
Issue date: 01/21/1986
From:
NRC
To:
Shared Package
ML18019A536 List:
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8601270401
Download: ML18019A538 (5)


Text

Encl osure SAFETY EVALUATION REPORT SHEARON HARR S UC E

P WER PL N

UNIT NO.

1 R

R UL Cl INTRODUCTION AND SUMh1ARY Carolina Power and Light Company (CPSL) was requested by Generic Letter 83-33 tc provide a report to the NRC describing how the post-accident monitoring instrumentation meets the guidelines of Regulatory Guide 1.97 as applied to emergency response facilities.

The applicant responded to the generic letter

'n April 15, 1983.

Response

specific to Regulatory Guide 1.97 was provided on September 6, 1983.

Additional information was provided by letter dated i)une 3, 1985.

A detailed review and technical evaluation of the applicant's submittals was performed by EG&G Idaho, Inc., under contract to the NRC, with general super-vision by the NRC staff.

This work is reported by EGSG in their Technical Evaluation Report (TER), "Conformance to Regulatory Guide 1.97, Shearon Harris Nuclear Power Plant, Unit Nos.

1 5 2," dated September 1985 (attached).

We have reviewed this report and concur with the conclusion that the applicant either conforms to, or is justified in deviating from, the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable except for the variables accumulator tank level and pressure.

860127040k 860i2i PDR ADOCN, 05000400 F

PDR I

EVALUATION CRITERIA 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 con-cerns regarding the NRC policy on Regulatory Guide 1.97.

At these meetings, it was noted that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97.

Further, wher e licensees or applicants explicitly state that instrument systems conform to the provisions of the regulatory guide, it was noted that no further staff review would be necessary.

Therefore, the review performed and reported by EGSG only addresses exceptions to the guidance of Regulatory Guide 1.97.

This Safety Evaluation addresses the applicant's submittals based on the review policy described in the NRC regional meetings and the conclusions of the review as reported by EGSG.

EVALUATION We have reviewed the evaluation performed by our consultant contained in the enclosed TER and concur with its bases and findings.

The applicant either conforms to, or has provided an acceptable justification for deviations from the guidance of Regulatory Guide 1.97 for each post-accident monitoring vari-able except for the variables accumulator tank level and pressure.

Regulatory Guide 1.97 recommends that instrumentation be provided to monitor the accumulator tank level and pressure.

The applicant has provided this instru-mentation which conforms to the criteria for Type 0, Category 2 variables with the exception of environmental qualification.

The applicant states that the accumulators are a passive system and action takes place within one minute of

the accident or well after safety injection depending upon the leak size.

In either case operator action is not required to mitigate the consequences of the postulated accident.

Also the signals from accumulator tank level and pressure instrumentation are not used as inputs to any automatic safety function.

While the staff agrees with the applicant that this is a passive system and the variables are not used for automatic initiation of a safety function, we believe that this instrument should be provided to permit the operator to determine if the plant safety functions (accumulator discharge) are being performed.

In this regard, we find the applicant's proposed exception to the guidelines of Regulatory Guide 1.97 to be unacceptable.

CONCLUSION Based on the staff's review of the enclosed Technical Evaluation Report, and the applicant's submittals, we find that the Shearon Harris Nuclear Power Plant, Unit No. 1, design is acceptable except as noted below with respect to conformance to Regulatory Guide 1.97, Revision 2.

The staff recognizes that the operator can infer from either level or pressure that the accumulator has injected borated water into the reactor coolant system.

Therefore, it is the staff's position that CPSL designate either level or pressure as the key variable to determine accumulator discharge and provide instrumentation, for that variable that meets the requirements of 10 CFR 50.49.

If accumulator level is selected as the key variable, then the range should be expanded to meet the regulatory guide recommendations.

It is also the staff's

position that CP8L shall install and have operational qualified accumulator tank level or pressure instrumentation at the first scheduled outage of sufficient

duration, but no later than start up following the first refueling outage.