ML20128L879
| ML20128L879 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/01/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20127D449 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8507110480 | |
| Download: ML20128L879 (3) | |
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ENCLOSURE SAFETY EVALUATION REPORT COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NOS. 1 & 2 DOCKET N05. 50-445/446 CONFORMANCE TO REGULATORY GUIDE 1.97 INTRODUCTION AND
SUMMARY
Texas Utilities Generating Company (TUGC) was requested by Generic Letter 82-33 to provide a report to the NRC describing how the post-accident monitoring in-strumentation meets the guidance of Regulatory Guide 1.97 as applied to emer-gency response facilities. The applicant responded to the generic letter by letter dated April 15, 1983, which referred to the Final Safety Analysis Report for a review of the instrumentation provided for Regulatory Guide 1.97.
Addi-tional information was provided by letters dated October 24, 1983 and January 28, 1985, and in FSAR Amendments 47 and 50.
A detailed review and technical evaluation of the applicant's submittals was performed by EG&G Idaho, Inc., under contract to the NRC, with general super-vision by the NRC staff.
This work is reported by EG&G in their Technical Evaluation Report (TER), "Conformance to Regulatory Guide 1.97, Comanche Peak Steam Electric Station, Unit Nos. 1 & 2," dated March 1985 (attached).
We have reviewed this report and concur with the conclusion that the applicant either conforms to, or is justified in deviating from, the guidance of i
(
Regulatory Guide 1.97 for each post-accident monitoring variable except for neutron flux.
For this variable, TUGC has not identified the appropriate l
environmental cualification.
8507110480 850701 PDR ADOCK 05000445 F
2-f EVALUATION CRITERIA Subsequent to the issuance of the generic letter, the NRC held regional meet-ings in February and March 1983, to answer licensee and applicant questions and concerns regarding the NRC policy on Regulatory Guide 1.97. At these meetings, it was noted that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97.
Further, where licensees or appli-cants explicitly state that instrument systems conform to the provisions of the There-guide, it was noted that no further staff review would be necessary.
fore, the review performed and reported by EG&G only addresses exceptions to the guidance of Regulatory Guide 1.97.
This Safety Evaluation addresses the applicant's submittals based on the review policy described in the NRC regional meetings and the conclusions of the review as reported by EG8G.
EVALUATION We have reviewed the evaluation performed by our consultant contained in the enclosed TER and concur with its bases and findings.
The applicant either conforms to, or has provided an acceptable justification for deviations from i
the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable except for the environmental qualification of the variable identi-fied in Section 4 (conclusions) of the TER.
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10 CFR 50.49 requires that all Regulatory Guide 1.97, Category 1 and 2 instru-ments located in a harsh environment be included in the environmental qualifi-cation program unless adequate justification is provided.
The justification provided by the a~pplicant supporting the lack of environmental qualification for the neutron flux instrumentation is that the same information can be obtained by monitoring the reactor coolant system (RCS) hot leg and cold leg water temperatures, and as backup, the control rod position and RCS soluble baron concentration.
The staff has reviewed this justification and finds it not acceptable.
The alternate instrumentation cited by the applicant does not provide the necessary information required for post-accident monitoring in accordance with Regulatory Guide 1.97.
CONCLUSION Based on the staff's review of the enclosed Technical Evaluation Report, and the licensee's submittals, we find that the Comanche Peak Steam Electric Station, Unit Nos. 1 and 2 design, with the exception of the neutron flux i
j instrumentation, is acceptable with respect to conformance to the guidelines of Regulatory Guide 1.97, Rev. 2.
1 The applicant must provide Category 1 neutron flux instrumentation prior to fuel loading.
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