ML20148E630

SER Accepting Util 840116,0927 & 850805 Responses to Generic Ltr 82-33,Item 6 Re Compliance w/post-accident Monitoring Instrumentation Guidelines of Reg Guide 1.97 Concerning Emergency Response Facilities

ML20148E630
Person / Time
Site:	Peach Bottom
Issue date:	01/15/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20148E609	List: ML20148E606 ML20148E630
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8801260074
Download: ML20148E630 (3)

Text

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ENCLOSURE 1

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l SAFETY EVALUATION REPORT l l

PEACH BOTTOM ATOMIC POWER STATION, UNIT NOS. 2 AND 3 '

CONFORMANCE TO REGULATORY GUIDE 1.97 DOCKET NOS. 50-227/278 INTRODUCTION AND

SUMMARY

The PhiladelpMa Electric Company was requested by Generic Letter 82-33 to )

provide a report to the NRC describing how the post-accident monitoring instrumentation meets the guidelines of Regulatory Guide (R.G.) 1.97 as applied -

to emergency response facilities. The licensee responded to item 6 of the generic letter on January 16, 1984 Additional infomation was provided by  !

letters dated September 27, 1984 and August 5, 1985.

A detailed review and technical evaluation of the licensee's submittals was i perfomed by EG&G Idaho, Inc., under contract to the NRC, with general supervision by the NRC staff. This work is documented by EG8G in their Technical Evaluation Report (TER), "Confomance to R.G.1.97, Peach Bottom Atomic Power Station, Unit Nos. 2 and 3," dated February 1986 (attached). We 4 have reviewed this report anf concur with the conclusion that the licensee either conforms to, or is justified in deviating from, the guidance of R.G.

1.97 for each post-accident monitoring variable except for the variables i neutron flux and containment isolation valve position.

EVALUATION CRITERIA l Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983 to answer licensee and applicant questions and concerns regarding the NRC policy on R.G.1.97. At these meetings, it was noted that the NRC review would only address exceptions taken to the guidance of R.G. 1.97. Further, where licensees or applicants explicitly state that l instrument systems confom to the provisions of the regulatory guide, it was l noted that no further staff review would be necessary. Therefore, the review perfomed and reported by EG&G only addresses exceptions to the guidance of R.G. 1.97. This safety evaluation addresses the licensee's submittals based on i the review policy described in the NRC regional meetings and the conclusions of the review as reported by EG&G.

EVALUATION We have reviewed the evaluation perfomed by our consultant containet in the attached TER and concur with its bases and findings. The licensee either confoms to, or has provided an acceptable justification for deviations from the guidance of R.G. 1.97, Revision 3 for each post-accident monitoring O74 880215 fjj!2gOCK05000277 F

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2 variable except for (a) neutron flux and (b) containment isolation valve position. '

l (a) The licensee has provided neutron flux monitoring instrumentation which complies with Category I design criteria except for environmental ,

qualification. Regulatory Guide 1.97, Revision 3 requires all Category I l and 2 instruments located in a harsh environment to be environmentally i qualified in accordance with 10 CFR 50.49 unless adequate justification is provided. The justification provided by the licensee for not fully l qualifying the neutron flux instrumentation is that the variable is only j needed for long term use in the event of an anticipated transient without scram (ATWS), which does not result in an environment that is more severe than a normal operating environment. However, it is the staff's position that neutron flux instrumentation is required for monitoring purposes as related to the mitigation of any reactivity addition situation resulting fro-accidents. Thus, the staff finds the licensee's justification unacceptable. .

The existing instrumentation has not been shown to provide reliable neutron flux data in a post-accident situation in accordance with R.G. .l 1.97, Revision 3. However, it is the staff's understanding that a l

Category I neutron flux monitoring system that meets all the criteria of l R.G. 1.97, Revision 3 is an item currently under development by industry, i The licensee should monitor industry progress related to the development {

of this equipment, evaluate the newly developed systems, and install l neutron flur monitoring instrumentation which fully complies with the Category I criteria including environmental qualification. It has been concluded by the staff that the existing neutron flux instrumentation is  ;

acceptable for interim operation pending satisfactory implementation of a fully qualified indication system.

(b) R.G.1.97, Revision 3 recomends that Category 1 instrumentation be provided to monitor containment isolation valve position. The licensee i has provided instrumentation which conforTns with the criteria of Category i I variables with the exception of seismic qualification of the indicating lamps. The licensee has Ttated that the operator would be expected to l l

replace damaged indicator lamps following a seismic event. The staff does l not c,onsider this to be a feasible approach since the staff believes that -

l under actual circumstances, operators would not have adequate time to replace damaged indicator bulbs in an effective manner due to other ,

priority demands on their responses associated with the mitigation of the i event itself. Therefore, the licensee should either qualify the existing indicator lamps for the worst-case postulated seismic event or install new ,

lamps that are seismically qualified.

CONCLUSION Based on the staff's review of the attached technical evaluation report and the ~

licensee's submittals, we find that the Peach Bottom Atomic Power Station, Units 2 and 3, design is acceptable with respect to conformance to Regulatory Guide 1.97, Revision 3 except for the instrumentation associated with variables

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pertaining to neutron flux and containment isolation valve position. It is the i staff's position that the licensee shall install and have operational instrumentation to moniter the subject variables as described in items (a) and (b) above which meets tne recommendations for R.G. 1.97 Revision 3. The licensee should develop a schedule for implementation through coordination with the NRC project manager.

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