ML19290C654
| ML19290C654 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 01/15/1980 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19290C655 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-OS, TASK-RS-917-4 NUDOCS 8001220481 | |
| Download: ML19290C654 (5) | |
Text
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@ One First National Plaza. Chicago. Ulinoi Commonwealth Edison f o: Post Office Box 767 Adcress Rep!
t Chicago. 'mnois 60690 January 15, 1979 Mr. S.A. Varga, Acting Assistant Director for Light Water Reactors Division of Pro' ject Management United States Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
LaSalle County Station - Units 1 and 2 Comments on Proposed Revision 2 to Regulatory Guide 1.97 " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following An Accident", per your Letter to Mr. D. Louis Peoples, Commonwealth Edison Company, Dated November 23, 1979.
Docket Nos:
50-373/374
Dear Mr. Varga:
The topic of accident monitoring instrumentation has been the sub'ect of a great deal of concern and controversy since the first iss ance of Regulatory Guide 1.97.
We are encouraged to see that the NRC has taken steps toward the elimination of the apparent confusion and subs Muent concern regarding minimum requirements for and qualification leve' of various accident parameters.
Further, we are pleased to provide our comments in response to your letter and the Revision 2* draft which was distributed in December, 1979.
We have expended a considerable effort in preparing these comme"ts, in order to provide a timely response so that our input would be be'eficial to you in preparing the final Revision 2 version, and in decid ng the licensing impact on near-term OL reactors such as LaSalle Count Station.
To aid you in you review of our comments, we have rganized them in t',e f orm of Attachments to this letter.
The attachments contain the following:
Attachment A:
Mark-up of draft a Revision 2* containing line for line text changes we feel are necessary in order to implement this revision.
Attachment B:
General comments regarding the Design Criteria presented in Revision 2's Table 1, and their applicability to BWR 5 Mark II Containments.
Attachment C:
A detailed discussion of each var able presented i
in Table 3 of Revision 2, a discussion of LaSalle County Station's current licensing position, and a presentation of cost and scheduling impact estimates for LaSalle to fully comply with all the Revision 2 requirements.
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- Attachment 0:
Further notes on the overall cost impact for LaSalle to obtain full compliance with Revision 2 requirements, and a guide for using the cost estimates given in Attachment C.
It is important for the NRC staff to r.":lize that LaSalle has participated in nearly four years of operating license review and is nearing completion of that review.
In all issues of safety, Commonwealth Edison has had an attitude of compliance with regulatory guides, or presenting alternatives acceptable to the NRC staff.
The subject of accident monitoring has been no exception.
Licensing commitments were changed recently in Chapter 7.5 of the FSAR concerning accident instrumentation, to more closely comply with NRC standards and to aid the staff review of this Section, even though we had no prior commitment to do so.
The changing licensing requirements for Lasalle at this point in time has serious consequences.
Our country is currently in a time of potentially severe economic loss, due to the nature of our energy situation.
We are confident that we have satisfactorily addressed all safety issues concerning the licensing of LaSalle County Station, and the NRC staff must acknowledge the potential consequences of delay and increase in cost to the nuclear 'ndustry that this revision has.
Preliminary estimates of the cost impact to this revision due to additional hardware purchases, engineering / design, and installation costs alone (see Attachment 0) amount to approximately $11 million.
This figure does not take into account the adverse impact to Edison or to our customers due to a loss of energy production.
The staff should consider the marginal safety being purchased with the implementation of this revision, and whether that additional investment is a recognizable safety benefit for which the consumer is willing to pay.
This decision in this context is the key to implementing a responsible Reg. Guide.
Among the specific comments we have concerning the revision, the following are foremost:
1)
Qualification period for environmental transients:
The staff has put an arbitrary additional 100 days (to total 200 days) on the requirement depicted in Draft 4 of the ANS 4.5 standard.
Current industry practice is to use 100 days of LOCA environment.
NRC assertions that 200 days be used has the consequence of negating most qualification programs which are either completed or currently underway.
These programs are the basis for qualification of components in new plants as well as near term 0L's and operating reactor backfits.
All this work would have to be redone, at considerable expense to the utility and to the public, and for an extremely questionable additional safety value.
2)
Emergency power versus critical bus:
The requirements for each of these terms are unclear.
Plwase describe more fully what is the intent of differentiation, and which 1786 144
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type of emergency power (e.g. diesel generator, M-G set, battery) is required.
It was difficult to assign, a cost estimate due to this requirement, without knowing the design requirements or technical differences assignable to this terminology.
3)
Requirement for QA to be in accordance with 10CFR50-Appendix B for all variables - even non-safety:
We feel that the NRC is asking for much more than they really desire.
Your assumption is that those non-safety parameters which provide information to the operator for ascertaining the status of accident condition should be qualified to a level consistent with those that are relied upon for accident mitigation.
This level of qualification was extended to operation under abnormal environmental transients! It should not be extended to documentation regarding the design of the components themselves.
For example, QA procedures could be followed in the design of the system which uses a particular instrument / component, but they should not be extended to the design of the component, norits production, nor its installation.
Parochial over kill via QA of non-safety equipment cheapens the genuine QA program.
4)
Use of proposed ANS 4.5 as a basis for this revision, without regard to other proposed standards:
For example, IEEE p.497 has a useful portion pertaining to the classification of equipment in the post accident monitoring system that is considered " Class 1E".
Such acknowledgement is necessary in order to appropriately use those IEEE standards that are referenced by other Regulatory Guides.
For instance, RG. 1.89 demands the use of IEEE 323-1974, but IEEE 323-1974 first requires that the systems or components which are required to follow its qualification criteria be classified as " Class lE".
The NRC staff should constrain the Class 1E definition to its applicable IEEE 308 definition.
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The use of arbitrary ranges assumed to cover accident conditions in excess of those for which the system is designed:
Good engineering practice demands that there be nothing arbitrary in the design of safety systems.
The industry currently uses calculations and reasonable assumptions based on technical data in formulating expected transients that a system is able to produce.
Generally accepted margin factors are used to develop instrument design requirements, not arbitrary and unreasonable demands that have no real world basis.
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We hope that these comments are useful to you in preparation of the final form of this revision, and that NRC will be able to make reasoned technical decisions regarding the ultimate impact on our society regarding its cost and safety aspects.
If we can be of any further assistance to you or your staff, in formulating a responsible post-accident Reg. Guide, please let us know..
Yours very truly,
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