ML20148B100

Safety Evaluation Accepting Util Justification for Deviations from Reg Guide 1.97 for post-accident Monitoring Variables

ML20148B100
Person / Time
Site:	FitzPatrick
Issue date:	03/14/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20148B037	List: ML20148B033 ML20148B100 ML20148C044
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, NUDOCS 8803210346
Download: ML20148B100 (2)

Text

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SAFETY EVALUATION RY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO CONFOPMANCE TO REGULATORY GUIDE 1.97 JAMES A FIT 7. PATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 INTRODUCTION The Power Authority of the State of New York was requested by Generic Letter 82-33 to provide a report to NRC describing how the post-accident instrumentation meets the guidelines of Regulatory Guide (R.G.) 1.97 as applied to emergency response facilities. The licensee's response to R.G. 1.97 was provided by letters dated November 30, 1984, June PR, 1985, December 24, 1985, February 25, 1986, June 9, 1987, and November 11, 1987.

A detailed review and technical evaluation of the licensee's submittals was performed by EG&G Idaho, Inc., under contract to the NRC, with general supervision by the NRC staff. This work was reported by EGAG in Technical Evaluation Report (TER), Conformance to Pegulatory Guide 1.97 -- FitzPatrick," dated November 1987 (attached). Note that reference to the licensee's submittal dated November 11, 1987 was inadvertently omitted from the TER. This submittal, however, has been reviewed by EG&G.

We have reviewed the TER and concur with the conclusion that the licensee either conforms to, or has adecuately justified deviations from, the cuidance of R.G.1.97 for each post-accident monitoring variable except for the variable neutron flux.

EVAll!ATION CRITERIA Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983 to answer 1;censee and applicant questions and concerns regarding the NRC policy on R.G. 1.97. At these meetings. it was established that the NRC review would only address exceptions taken to the cuidance of R.G. 1.97. Furthar, where licensees or applicants explicitly state that instrument systems confom to provisions of the regulatory guide, no further staff review would be necessary for those items. Therefore, the review performed and reported by EG5G only addresses exceptions to the guidance of R.G. 1.97. This safety evaluation addresses the licensee's submittals based on the review policy described in the NRC regional meetings and the conclusions of the review as reported by EG&G.

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EVALUATION We have reviewed the eval"ation performed by EG&G as contained in the enclosed TEP and concur with its basts and findings. The licensee either conforms to, or has providad acceptab'e justification for deviations from, the guidance of R.G.1.97 for each post-ac.cident monitoring variable with 'he exception of neutron flux.

The licensee has provideJ neutron flux monitoring instrumentation which complies with Category 1 design criteria except for environmental qualification. R.G.

1.97 equires all Category 1 and ? instruments located in a harsh environment to be environmentally cualified in accordance with 10 CFR 50.49 unless adequate justification is provided. The justification provided by the licensee far not fully cualifying the neutron flux instrumentation is that the variable is only needed for long term use in the event of an anticipated transient without scram (ATWS), which does not result in cn environment that is more severe than a normal operating environment. However, it is the staff's position that neutron flux instrurentation is required for monitoring purposes as related to the mitigation of any inadvertent boren dilution event or other reactivity addition situation resulting from accidents. Thus, the staff finds the licensee's justification unacceptable.

The staff has been informed that industry has developed a wide range neutron flux monitorina system that satisfies the criteria of R.G. 1.97. Therefore, it is the str.ff's position that the licensee should evaluate these newly

. developed systems and install neutron flux monitoring instrumentation which complies with the Category I criteria, including environmental cualification.

It has been concluded by the staff that the existino neutron flux instrumentction is acceptable for interim use pending satisfactory implementation of a fully ,

nualified indicating system.

CONCUISION Based on the staff's review of the enclosed TER and the licensee's submittals, we find that the James A. FitzPatrick Nuclear Power Plant design is acceptable 1 with respect to conformance to R.G.1.97, Revision 2, except for the instrumentation associated with the variable neutron flux.

The staff niso finds acceptable the existing neutron flux instrumentation for interim operation. It is the staff's position that the licensee shall install and havo operational neutron flux monitoring instrumentation which fully conforms to the recommendations of R.G. 1.97, Revision 2.

1 The licensee, in coordination with the NRC projtet manager, shall develop a schedule for the installatien of Category i neutron flux monitoring instrumentation.

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