ML19263D979
| ML19263D979 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1979 |
| From: | Deyoung R Office of Nuclear Reactor Regulation |
| To: | Julie Ward ATOMIC INDUSTRIAL FORUM |
| References | |
| REF-GTECI-A-34, REF-GTECI-IP, TASK-A-34, TASK-OR NUDOCS 7904170136 | |
| Download: ML19263D979 (4) | |
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O*4 TJUcLEAR REGULATORY COMMisslON j } /2, j
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S JAN 311979 V +..../
Generic Activity: A-34 Atomic Industrial Forum, Inc.
ATTN: Mr. John E. Ward, Chairman Committee on Reactor Licensing and Safety 7101 Wisconsin Avenue Washington, D. C.
20014
Dear Mr. Ward:
This letter is in response to your June 13, 1978 letter to Edson Case con-cerning the philosophical and technical aspects of implementation of Regulatory Guide 1.97, Revision I, " Instrumentation for Light Water Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident".
On November 9,1978, members of my staff met with the members of the ad hoc committee on Post Accident Monitoring Instrumentation that has been established by your organization to address the issue of implementation of Regulatory Guide 1.97.
At that meeting many of the philosophical and technical issues raised in your June 13, 1978 letter were discussed and we agreed that we would respond to the specific issues in your let cer to the extent possible at this time. *0ur responses to your comments are enclosed.
The staff is currently considering a major revision to Task Action Plan
'(TAP) A-34 " Instruments for Monitoring Radiation and Process Variables During Accidents." This revision would climinate the current lead plant approach described in the TAP. We will provide you with the details of the proposed revision after it has been reviewed by our management and discussed with ACRS.
- In addition, we plan to work closely with your ad hoc conmittee on Post Accident Monitoring Systems in order to gain industry input into the resolution of various issues associated with implementation of Regulatory 790417013G D
!!r. John E. Mard 2-JAN 311979 Guide 1.97.
As a first step in this process, we thank you for your coments concerning Regulatory Guide 1.97 and hope that the informatic..
provided in this letter will begin to resolve your concerns about l'sle-mentation of this Regulatory Guide.
Sincerely yours, m; gin.a sim.ct uy R. C. DeE#8 Richard C. DeYoung, Director Division of Site Safety and Environmental Analysis
Enclosure:
Responses to Comnents f
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RESPONSES TO CO:@iENTS I.
Philosophy _
A.
We agree with your position that the operator should have sufficent information available to determine the effects of an accident to the extent required to make intelligent decisions for taking manual action and to assist in determining what actions, if any, are needed to execute the plant emergency plan.
You have expressed considerab e concern over the instruments l
B.
described in Postion C.3 of Regulatory Guide 1.97.
This position is not intended to monitor Class 9 accidents in the sense indicated in your letter.
Position C.3 is intended to provide assurance that even under conditions that degrade far beyond those that we assume in our accident analyses, the operator will have usable instrumentation that will provide a basis for decisionmaking.
The operator must not be placed in a position where all his relevent instru..ientation is off-scale.
The ranges of the instruments described in Position C.3 are not based directly on accident scenarios but are based on engineering judgments of the admittedly extreme points beyon which catastropic failure of important fission product barriers (e.'g.
containment burst) would make the need for instrumentation a moot point.
II.
Technjcal Comments The responses provided below are numbered consistently with the technical problems described in your June 13, 1978 letter.
For brm;ity, your comments are not repeated here.
Regulatory Position C.1 1.
It is the staff's present position that with respect to Position C.1 that except in those cases in which the applicant or licensee proposes an acceptable alternative method for complying with the specified portions of the Commission's regulations, the methods
- described in Position C.1 will be implemented only for the evaluation of sub-mittals for construction permit applications docketed af ter September 30, 1977.
2.
We agree that operator actions should be restricted to those types of activities which are designed or planned manual action (s).
It is not the intent of this Regulatory Guide that operators be encouraged to circumvent automtic featurer prematurely, but rather that they be adequately informed in order that they can take necessary planned and unplanned actions
- The staff is currently in the process of developing a list of parameters
~ _l that, if monitored, would satisfy the guidance _in _ Position C.l.
. Pegulatory Position _C.3, l.-2.
The basis for the selection of the ranges of the instru-mentation described in Position C.3 is discussed above.
3.
We believe that radiation monitors located outside containment can be properly calibrated. We will require that applicants and licensees prepare calibration criteria, in addition we will work with your ad hoc committee to resolve problems associated with calibration of the radiation level instrument described in Position C.3.b.
liowever, we feel that with the cooperation of applicants, licensees, and your ad hoc committee we will resolve your concerns in this area in a timely manner that will not impede implementation of Position C.3.
4.
We disagree with your conclusion that the maximum value of a parameter, based on reasonable and suf ficient initiating events and technical conditions, must be the basis for establishing the range of an instrument.
As we have des-cribed above, for the instn.nentation described in Position C.3, we believe that it is appropriate to base the range of an instrument on the value of the parameter beyond which neasurement of the parameter is no longer useful.
This basis is appropriate even if we do not postulate a scenario that would produce a value for the parameter equal to the maximum range of the instrument.
5.i.
Currently installed instruments provide coverage in lower ranges.
Therefore, it is not necessary that radiation instruments described in Position C.3.b be particularly accurate at the lower ranges.
ii.
In our March 1978 guidance to the lead plant ap)licants we provided additional information concerning t1e charactc.-
istics of effluent release monitors described in Position C.3.d.
In addition, we plan to initiate a study of the current state-of-the-art release rate nunitors.
We will use the results of this study to further define tne characteristics of the instruments described in Position C.3.d.
Until these efforts are complete, Position C.3.d will not be implemented.
iii.
We believe that instruments described in Position C.3 can be located and shielded such that qualification will not be a major problem.
We will provide additional guidance concerning the qualification of instruments described in Position C.3.