ML18059A548
| ML18059A548 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/29/1993 |
| From: | Hsia A Office of Nuclear Reactor Regulation |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18059A549 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, TAC-M84063, TAC-M84973, NUDOCS 9312090129 | |
| Download: ML18059A548 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20655-0001 Docket No. 50-255 Mr. Gerald B. *slade Plant General*Manager Palisades Plant Consumers Power Company 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
November 29, 1993*.
SUBJECT:
PALISADES PLANT - INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT (REGULATORY GUIDE 1.97}(TAC NO. M84063, M84973}
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 pressurized water reactor licensees asking that the environmental qualification requirem~nt for safety injection tank (SIT} 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 exceptions have been considered as an open i tern until a generic resolution can 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 instrument~tion and that it does not perform a safety function. 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.
- You have not finalized your commitment regarding installation of instrumentation to monitor SIT level and pressure.
You may now utilize Category 3 instrumentation for SIT level and pressure. Please notify me.of the actions you plan to take and the ~chedule for implementation.
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Mr. Gerald November 29, 1993 This request for information was approved by the Offic'e of Management and Budget under clearance number 3150-0011 which expires June 30, 1994.
Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management Room 3208, New Executive Office Building, Washington, D.C.
20503.
If you have any questions regarding this issue, please do not hesitate to contact me on {301) 504-3028.
Enclosure:
Safety Evaluation cc: w/enclosure See next page DISTRIBUTION
[po_c_~et FiJ e_
NRC & *1oca l PDRs PD31 Reading JRoe JZwol in.ski
BJorgensen, RIII A. Hansen B. Marcus/HICB OFFICE LA:PD31 NAME OFFICIAL RECORD COPY Sincerely, Original signed by Anthony H.
Hsi~, Project Mahager Project Directorate 111-1 Division.of Reactor Projects - 111/IV/V Office of Nuclear Reactor Regulation A D:PD31 FILENAME: G:\\WPDOCS\\PALISADE\\PALRG197.LTR
Mr. Gerald B. Slade.
Cpn~~~~rs Power Company cc:
M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, fsquire Consumers.Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn; Illinois 60137 Jerry Sarno
-Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room l. - Capitol Buildin'g Lans1ng, Michigan 48913 Mr. David W. Rogers Safety and Licensing Director Palisades Plant 27780 Blue Star Memorial Highway
. Covert, Michigan 49043 U.S. Nuclear.Regulatory Commission Resident Inspector Office Palisades Plant 27782 Blue Star Memorial Highway Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3423 N. Logan Street P. 0. Box 30195 Lansing, Michigan 48909:
Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington DC 20037 Alora Davis Commitment Tracking System Coordinator Palisades Plant
- Consumers Power Company 27780 Blue Star Memo*ri a 1 Hwy.
Covert, Michigan 49043-9530 July 1993
.e UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20656-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PRESSURIZED WATER REACTORS SAFETY INJECTION TANK PRESSURE AND VOLUME INSTRUMENTATION RELAXATION OF REGULATORY GUIDE 1.97 ENVIRONMENTAL QUALIFICATION REQUIREMENTS
- 1. 0 INTRODUCTION *..
Section 6.2 of the Generic Letter 82-33 requested licensees to provide a report on their implementation of Regulatory Guide (R.G.) 1.97 (Rev.2),
"Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," and methods for complying with the Commission's regulations including a supporting technical justification of any proposed alternatives or deviations. A review of the licensees' submittals was performed by the staff and a safety evaluation (SE) was issued for each plant. These SEs concluded that the licensees either conformed to, or adequately justified deviations from, the guidance of the Regulatory Guide for each post-accident monitoring variable except for the variables identified i~
the SE.
Ex~eptions were identified for th~ safety injection tank (SIT) level and pressure monitoring. A large number of the exception requests were for relaxing the equipment qualification (EQ) requirement from Category 2 to Category 3 qualification that allows commercial grade instruments to be used in certain applications. However, none of the submitt*ls requesting the exceptions provided sufficient justification for granting the exception. These requests were denied for the licensees and applicants whose R.G. 1.97 compliance SEs were issued by the staff before 1987. Since 1987, exceptions for the SIT instrumentation were considered by the staff as an open item until a generic resolution could be found.
Thirty-two plants requested relaxation of EQ requirements from Category 2 to Category 3 for the SIT level and pressure instrumentation.
. 2.0 EVALUATION The Code of Federal Regulations 10 CFR 50.49 requires licensees to establish a program for qualifying certain post-accident monitoring equipment for which specific guidance concerning the types of variables to be monitored is provided in revision 2 of R.G. 1.97. This guide identifie~ the SIT instrumentation as a type D variable that provides information to indicate the operation of individual safety systems and other systems important to safety, to help the operator in selecting appropriate mitigating actions. The guide lists Category 2 qualification for this instrumentation. The Category 2 qualification criteria require the instrumentation to be qualified in accordance with R.G. 1.89, "Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants," and the methodology described in NUREG-0588, "Interim Staf(
Position on Environmental Qualification of Safety-Related Electrical Equipment."
Additionally, the instrumentation with Ca.tegory 2 qualification should be 9312090131 *93.!;1'29* !..
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energized-from a high-reliability power source, not necessarily standby power.
In contrast to this, the Category 3 qualification criteria require only an offsite power source and the instrumentation to be only of high-quality commercial grade to withstand the specified service environment (mild environment as defined in 10 CFR 50.49, paragraph c).
Qualification criteria for instrumentation are established based on the safety function of the system whose variables are being monitored.
The selection criteria for R.G._ 1.97 variables qualification category is based upon whether monitoring of system parameters is needed during and following an accident and whether subsequent operator actions in the operating procedures are dependent on the information provided by this instrumentation.
The SITs* are pressure vessels. filled with borated water and pressurized with nitrogen gas.
Being a passive system, it provides a fast acting, high flow rate, cold leg injection during the injection phase of an emergency core cooling system operation.
Both volume and pressure are monitored to assure the SIT's
- function in accordance with the Final Safety Analysis Report safety analysis.
During normal operation, the SIT is isolated from the reactor coolant system (RCS) by two check valves in series. To prevent inad.v.ertent closing, each SIT'S motbr-operated isolation valve (MOV) is normally open with its power removed, and the status of the MOV is assured by the Technical SpeCification surveillance requirements. Should the RCS pressure decrease below SIT pressure (as during a loss of coolant ~ccident), the check valves open and the nitrogen gas pressure.
will force the borated water into the RCS. :Thus, a mechanical operation of.the swing-check valves is the only action required to open the injection path from the SIT to the reactor ~ore. No external powe~ source or initiating signal is needed. for the SIT to perform its safety function.
The operator can only.
control the operation of the MOV which is used to isolate the SIT from the RCS.
Isolation from the RCS is not a safety function of the SIT. Additionally, the SIT is not designed to perform any post-accident safety function.
- t The ~bove discussion es~ablishes that the'SIT instrumentation does not ~erform*a" safety function during or in a post-accident environment and operator actions to.
. mitigate the effects of an accident do not depend on the information provided by the SIT instrumentation. Additionally, successful performance of cbre*cooling systems can be inferred from environmentally qualified instrumentation.*
3.0 CONCLUSION
Based on -0ur review, we conclude that the post~accident monitoring of the SIT*
volume and pressure does not perform a safety function and no operator action is based on the information that will require Category 2 qualification of the instrumentation.
In lieu of Category 2 qualification,. Category 3 qualification of this instrumentation is acceptable.
Principal Contributor:
I. Ahmed Date: November 29, 1993