ML20215G113

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SER Re Util 830414,850315,0620,0906 & 860121 Responses to Reg Guide 1.97.Design Acceptable W/Respect to Conformance to Reg Guide 1.97,Rev 2,w/exception of Containment Sump Water Temp
ML20215G113
Person / Time
Site: Vogtle, 05000000
Issue date: 04/11/1986
From:
NRC
To:
Shared Package
ML20213F414 List:
References
FOIA-87-213, RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8706230129
Download: ML20215G113 (5)
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-l SAFETY EVALUATION REPORT .

V0GTLE ELECTR!C GENERATING PLANT, UNITS 1 AND 2  ;

DOCKET NOS. 50-424/425  ;

CONFORMANCE TO REGULATORY GUIDE 1.97 j

INTRODUCTION AND

SUMMARY

Georgia Power 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 facili-ties. The appli m t's response to Regulatory Guide 1.97 was provided by letters dated April 14, 1983, March 15, 1985, June 20, 1985, September 6, 1985 and January 21, 1986.

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 supervi-sion by the NRC staff. This work was reported by EG&G in' the Technical Evalua-tion Report (TER), "Conformance to Regulatory Guide 1.97, Yogtle Electric Gen-erating Plant, Unit Nos. I and 2." dated April 1986 (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 Regulatory Guide 1.97 for each post-accident monitoring variable except for containment sump water temperature.

EVALUATION CRITERIA Subsequent to the issuance of the gener'ic letter, the NRC held regional meetings in February and March 1983'to answer licensee and applicant questions and con-cerns regarding the NRC poficy 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. Furthercuhere licensees or applicants

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i explicitly state'that instrument systems conform to the provisions of the regulatory guide, no staff review would be necessary for these items. There-fore, tne 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

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meetings and the conclusions of the review as reported by EG&G.

q EVAL.UATION 1 We have reviewed the evaluation performed by EG&G contained in the enclosed TER 1

and concur with its bases and findings. The applicant either conforms to, or has acceptably justified deviations from. the guidance of Regulatory Guide 1.97 for each post-accident monitoring variable except for containment sump water temperature.

i Regulatory Guide 1.97 recommends that instrumentation be provided to monitor the containment sump water temperature. The applicant has provided this in-strumentation which conforms to the R.G.1.97 criteria for Type D, Category 2 variables with the exception that the electrical connections at the instru-ments and at the penetrations are not qualified for a steam environment. RHR heat exchanger inlet temperature is an alternate variable which can be used to -

-l obtain a measure of the sump water temperature during the recirculation phase of an accident. The applicant however states that the RHR inlet temperature instruments are 'not qualified for. the high radiation levels that may. be present --

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in the heat exchanger rooms. Thus, there is no assurance that either the con-

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i tainment sump water temperature instrumentation or the RHR heat exchanger in- 4 let temperature instrumentation will be available during the course of an accident.

-i The applicant indicates that the determination of containment emergency sump water temperature is not required on the' basis that this indication is not used by the operator to take any type of corrective action, and because the sump ' i temperature would not rise to the point where the RHR pump net positive suction head would be inadequate. While the staff agrees with the applicant that emer-gency operating procedures do not rely upon measured values of sump water temperature, we believe that this instrumentation 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.- I Therefore, because there is no assurance that either the' containment sump water temperature instrumentation or the RHR heat exchanger inlet temperature instru-mentation will be available during the course of an accident,~ we find the appli-cant's proposed exemption to the guidelines of Regulatory Guide 1.97 to be unacceptable.

CONCLUSION Based on the staff's review of the enclosed Technical Evaluation Report' and the applicant's submittals, we find that the Vogtle Electric Generating Plant, Unit

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Nos. 1.and 2, desion is acceptable with respect to conformance to Regulatory Guide 1.97, Revision 2 with the exception of the containment sump water 3 temperature.

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'It is the staff's position that instrumentation be provided for the containment-1 sump water temperature variable that is entirely environmentally qualified in I accordance with the provisions of 10 CFR 50.49 and Regulatory Guide 1.97.and 'l that it be operational prior to receiving a full power license.

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