ML19343A642
| ML19343A642 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/1980 |
| From: | Bender M, Plesset M Advisory Committee on Reactor Safeguards |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 ACRS-R-0902, ACRS-R-902, NUDOCS 8011190344 | |
| Download: ML19343A642 (2) | |
Text
.
![p erc,%,
e UNITED STATES
/d-Cd7cQ NUCLEAR REGULATORY COMMISSION
{ [Th [,(^.$
ADVISORY COMMITTEE OfJ REACTOn SAFEGUARDS o 1*y ijM}*' f y.4 WASWNGTON, D. C. 20555
%.'.A '.../
.::. m November 10, 1980
'D: W: ;3 H4M 4
t 0,TES.
? X-:
Mr. William J. Dircks Executive Director for Operations U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
REGULATORY GUIDE 1.97, REVISION 2, " INSTRUMENTATION FOR LIGHT-WATER-COOLED NUCLEAR POWER PLANTS TO ASSESS PLANT AND ENVIRONS CONDITIONS DURING AND FOLLOUING AN ACCIDENT"
Dear Mr. Dircks:
During its 247th meeting, November 6-8, 1980, the ACRS completed its review of Revision 2 to Regulatory Guide 1.97.
This Euide was reviewed by the Reg-ulatory Activities Subcommittee during its November 5,1980 meeting. We concur in the regulatory positions embodied in Modified Draft 3, dated November 6,1980, with the following exceptions and cornnts:
1.
Our concerns regarding the potential usefulness of core themoccuples in 3'dRs have been resolved to some extent in view of the limited re-suits of a study made by the General Electric Company and presented by the NRC Staff at the meeting.
In this regard, the Staff has indicated that the vertical location of these themoccuples in the core has not yet been decided on.
From the limited amcunt of information available to us, it appears that a lccation close to the top of the core may be desirable, but further detailed consideration of how the infomation frcm these instruments will be used will be required before the optimum location or locations can be detemined.
- 2. - The requirements for installed instruments to measure, transmit, and display radiation exposure rates in the environs of a plant are defi-cient in that they provide inadequate guidance. Until suitable guid-ance, in the form of objectives or performance criteria or in prescrip-tive terms can be provided, we recommend that these requirements be deleted from the Guide. Once such guidance is available, it can be provided to licensees and applicants in a supplement to the Regulatory Guide, in the Standard Review Plan, in a Branch Technical Position, or by other suitable means.
3.
The proposed implementation schedule appears to be barely adequate to permit the design, procurement, qualification, and installation of these instruments in a manner that will not degrade the safe operatio%
N b
'80111mo34f
._.~
4 Mr. William J. Dircks
-2 November 10, 1930 of the plants. Moreover, the design of these instruments is closely
~
linked to and may be influenced by the manner and extent to which they are utilized in the Safety Parameter Display System, Onsite Technical Support Center, Hearsite Emergency Operations Facility, and Nuclear Data Link.
For this reason, it is essential that the requiremefits for these systems, now only tentatively prescribed in NUREG-0696, be decided upcn and promulgated promptly.
If this cannot be done, the implementation schedule for the Regulatory Guide should be modified accordingly.
i Additional comments by Mr. Myer Bender, ACRS Member, are presented below.
Si ncerely, N
y Miiton C. Plesset Chairman i
Additional Coments by Mr. Myer Bender, ACRS Member While I agree in principle with the requirements of Regulatory Guide 1.97, Revision 2, the Guide has some serious weaknesses that will detract from its value.. Not enough thought has been given to the ranges needed for effective use of instruments.
In many cases, including the primary cool-ant system pressure, the ranges are beyond those of use in normal opera-tion and require a separate set of instruments whose reliability is hot assured by normal attention as a part of routine operation. The "quali-fication" requirements are especially of concern because they lead to demands for redundancy, safety system interconnection or isolation, and environmental testing for equipment that has little value for accident diagncsis purposes.
Recognizing that one of the lessons from TMI-2 was to avoid confusion due to an excessive number of unusable and confusing instrument displays that hide important diagnostic information, efforts should be made to.further reduce the number of instruments and their specialized charactaristics required by this Guide through more use of Improved capabil-operational instruments and displays already in place.
ity could be provided through emergency hookup provisions or by more dis-criminate selection of parameters of diagnostic value.
References:
1.
Regulatory Guide 1.97, Revision 2, Draft 3, dated November 6,1980,
" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Curing and Following an Acci-dent."
2.
"Functionci Criteria for Emergency Response Facilities," NUREG-0696 dated July 1980 prepared by the Office of Nuclear. Reactor Regula-tion, U. S. Nuclear Regulatory Co.uission.
r--
v-