ML20058L698

Advises Category 3 Instrumentation May Be Replaced in Lieu of Category 2 Instrumentation to Monitor Accumulator Level & Pressure Re Section 6.2 of GL 82-33 Request to Provide Rept on Implementation of RG 1.97.Safety Evaluation Encl

ML20058L698
Person / Time
Site:	Callaway
Issue date:	12/10/1993
From:	Wharton L Office of Nuclear Reactor Regulation
To:	Schnell D UNION ELECTRIC CO.
Shared Package
ML20058L702	List: ML20058L698 ML20058L703
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 9312170151
Download: ML20058L698 (4)

Text

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l December 10, 1993 Docket No. 50-483 DISTRIBUTION IDockettFile> , NRC & Local PDRs JRoe PDill-3 Reading  ;

Mr. Donald F. Schnell JZwolinski IAhmed l Senior Vice President - Nuclear JHannon EGreenman, Rlli j Union Electric Company MRushbrook LRWharton 1 Post Office Box 149 ACRS(10) AHansen St. Louis, Missouri 63166 OGC BMarcus

Dear Mr. Schnell:

SUBJECl: CALLAWAY NUCLEAR PLANT - INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT (REGULATORY GUIDE 1.97)

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 PWR licensees asking that the environmental qualification requirement for accumulator level and pressure monitoring instrumentation be relaxed from C# cgory 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 item 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 instrumentation 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.

We understand. that you have installed Category 2 instrumentation to monitor accumulator level and pressure. You are encouraged to continue using this instrumentation, however, you may replace this instrumentation with Category 3  ;

instrumentation at your discretion. Please notify me of the actions you plan to take and the schedule for implementation.

If you have any questions regarding this issue, please do not hesitate to contact me at (301) 504-1396. ORIGINAL SIGNED Irt:

L. Raynard Wharton, Project Manager Project Directorate 111-3 Division of Reactor Projects - Ill/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation  !

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.... December 10, 1993 Docket No. 50-483 Mr. Donald F. Schnell Senior Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166

SUBJECT:

CALLAWAY NUCLEAR PLANT - INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT (REGULATORY GUIDE 1.97)

Section 6.2 of Generic Letter 82-33 requestsc licensees to provide a report on their implementation of Regulatory Guide 1.9? (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 PWR licensees asking that the environmental qualification requirement for accumulator 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 item 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 instrumentation and t 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.

We understand that you have installed Category 2 instrumentation to monitor accumulator level and pressure. You are encouraged to continue using this instrumentation, however, you may replace this instrumentation with Category 3 instrumentation ct your discretion. Please notify me of the actions you plan to take and the schedule for implementation.

If you have any questions regarding this issue, please do not hesitate to contact me at (301) 504-1396.

f( l0 &

L. Raynard Wharton, Project Manager Project Directorate III-3 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation cc: See next page

Mr. D. F. Schnell Callaway Plant Union Electric Company . Unit No. I cc:

Cermak Fletcher Associates Mr. Bart D. Withers 18225 Flower Hill Way #A President and Chief Gaithersburg, Maryland 20879-5334 Executive Officer Wolf Creek Nuclear Operating Corporation -

Gerald Charnoff, Esq. P.O. Box 411 Thomas A. Baxter, Esq. Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge  ;

2300 N. Street, N.W. Mr. Dan I. Bolef, President Washington, D.C. 20037 Kay Drey, Representative Board of Directors Coalition  ;

Mr. S. E. Sampson for the Environment Supervising Engineer, 6267 Delmar Boulevard -

Site Licensing University City, Missouri 65130 Union Electric Company Post Office Box 620 Fulton, Missouri 65251 U.S. Nuclear Regulatory Commission Resident Inspectors Office RR#1 Steedman, Missouri 65077 Mr. Alan C. Passwater, Manager Licensing and Fuels Union Electric Company Post Office Box 149 ,

St. Louis, Missouri 63166 Manager - Electric Department Missouri Public Service Commission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator U.S. NRC, Region III 799 Roosevelt Road ,

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Glen Ellyn, Illinois 60137 Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102

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