ML20211G120

Safety Evaluation Re Util 840413 & 850701 Responses to Reg Guide 1.97, Emergency Response Capability. Responses Acceptable.Licensee Should Provide Qualified Instrumentation for Stated Variable

ML20211G120
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/23/1986
From:	NRC
To:
Shared Package
ML20211G114	List: ML20211G109 ML20211G120
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8611030211
Download: ML20211G120 (3)

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SAFETY EVALUATION ARKANSAS NUCLEAR ONE, UNIT N0. 2 DOCKET N0. 50-368 CONFORMANCE TO REGULATORY GUIDE 1.97 INTRODUCTION AND

SUMMARY

Arkansas Power and Light 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 1.97 as applied to emergency response facilities. The licensee's response to Regulatory Guide 1.97 was provided by letters dated April 13, 1984 and July 1, 1985.

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 super-vision by the NRC staff. This work was reported by EG&G in the Technical Evaluation Report (TER), "Conformance to Regulatory Guide 1.97, Arkansas Nuclear One, Unit No. 2," dated May 1986 (enclosed). We have reviewed this report and concur with the conclusion that the licensee either conforms to, or is justified in deviating from the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable except for the RCS pressure and contain-ment sump water temperature.

EVALUATION CRITERIA 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 Regulatory Guide 1.97. At these meetings, it was established that the NRC review would only address exceptions taken to the guidance of Regulatory Guide 1.97. Further, where licensees or applicants explicitly state that instrument systems conform to the provisions of the regulatory guide, no staff review would be necessary for these items.

Therefore, the review performed and reported by EG&G only addresses exceptions to the guidance of Regulatory Guide 1.97. This safety evaluation addresses the 8611030211 861023 PDR ADOCK 05000389 P PDR

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• 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.

EVALUATION We have reviewed the evaluation performed by,EG&G contained in the enclosed TER and concur with its bases and findings. ' The licensee either conforms to, or has acceptably justified deviations from, the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable except for the following:

1. Regulatory Guide (RG) 1.97 recommends that Category 1 instrumentation be provided to monitor the RCS pressure. The licensee has provided instru-mentation which conforms to the criteria for Category 1 variables, except for the instrument range. RG 1.97 recommends a range of 0-4,000 psig for the RC'S pressure. The existing range 0-3,000 psig is adequate to monitor all expected pressures based on the accident analyses presented in the FSAR. However, the licensee has not substantiated its statement that the maximum pressure that could be reached as a result of an ATWS is within the recommended band from the upper range of the instrument. The licensee should provide the bases and results of an analysis that shows the maximum expected pressure for an ATWS event at AN0-2 to be at least 300 psi belcy the upper range of the existing RCS pressure instrument, or provide a qualified instrument with a range of 0-4,000 psig.

2. Regulatory Guide 1.97 recommends that Category 2 instrumentation be provided to monitor containment sump temperature. The purpose of this variable as defined by RG 1.97 is to monitor operation of containment cooling systems. The licensee does not have instrumentation to monitor the sump water temperature. The licensee states that the key variables for monitoring operation of the containment cooling systems are containment pressure and spray flow. While staff agrees with the licensee that the instrumentation identified by the licensee can be used to monitor some aspects of containment cooling systems, the staff notes that the

containment sump water temperature is necessary to provide a quantitative measure of heat removal by way of the containment sump and permit monitoring of the containment heat removal system operation and effectiveness. Hence, the licensee should provide qualified instrumentation for this variable.

CONCLUSION Based on the staff's review of the enclosed Technical Evaluation Report and the licensee's submittals, we find that Arkansas Nuclear One, Unit No. 2 design is acceptable with respect to conformance to Regulatory Guide 1.97, i Revision 3, except for the variables pertaining to the RCS pressure and containment sump water tenperature. It is the staff's position that the licensee install instrumentation which meet the positions set forth in Regulatory Guide 1.97, Revision 3, for the sump water temperature. With regard to the RCS pressure, it is the staff's position that the licensee demonstrate the adequacy of the existing instrument range for an ATWS event, or install instrumentation which meet the positions set forth in Regulatory Guide 1.97, Revision 3 for this variable.

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