ML20215M502

Safety Evaluation Accepting Util Response to Generic Ltr 82-33 Re Conformance to Rev 2 to Reg Guide 1.97,except for Instrumentation Associated W/Neutron Flux Variable

ML20215M502
Person / Time
Site:	Cooper
Issue date:	10/27/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20215M500	List: ML20215M499 ML20215M502 ML20215M504
References
RTR-REGGD-01.097, RTR-REGGD-1.097 GL-82-33, TAC-51082, NUDOCS 8610300287
Download: ML20215M502 (3)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION COOPER NUCLEAR STATION DOCKET N0. 50-298 CONFORMANCE TO REGULATORY GUIDE 1.97 INTRCDUCTION AND

SUMMARY

Nebraska Public Power District (NPPD) was requested by Generic Lette- 82-33 to provide e 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 the R.G. 1.97 portion of the generic letter en March 1, 1984. Additional information was providea by letters date.d April 16, 1984, March 6, 1985, May 24, 1985, May 29, 1985 and December 4,1985.

A detailed review and technical evaluation of the licensee's submittals was

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performed by EG&G Idaho, Inc., under contract to the NRC, with general supervision by the NRC staff. This work was reported by EG&G in their Technical Evaluation Report (TER), "Conformance to Regulatory Guide 1.97, Cooper Nuclear Station," dated January 1986 (attached). 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 R.G.1.97 for each

. post-accident monitoring variable except for neutron flux.

4 8610300287 DR 861027 ADOCK 05000298 PDR

2 EVALUATION CRITERIA Subsequent to the issuance of the generic letter, the NRC held regional meetings in Febt.ary and March 1983 to answer licensee and applicant questions and concerns regarding the NRC policy en 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 instrument systems conforr. to the provisions of the regulatory guide, it was noted that no further staff review would be necessary. Therefore, the review performed 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 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 our consultant contained in the enclosed TER and concur with its bases and findings. The licensee either conforms to, or has provided an acceptable justification for deviations from the guidance of R.G. 1.97, Revision 2 for each post-accident monitoring variable except for neutron flux. The licensee has provided neutron flux instrumentation which does not conform to the environmental cualification provision of R.G. 1.97, Revision 2, wt.ch recommends that all Category 1 instrumentation located in a harsh environment be environmentally qualified in accordance with 10 CFR 50.49 unless adequate justification is provided. The existing neutron flux instrumentation has not been snown to provide reliable data in a post-accident situation in accordance with R.G. 1.97, Revision 2.

It is the staff's understanding that a Category I neutron flux monitoring system that will meet all the criteria of R.G. 1.97, Revision 2 is an item currently under development by industry. The licensee has committed to follow

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industry development of this equipment, to evaluate newly developed equipment, and to install neutron flux monitoring instrumentation which fully complies _

with Category 1 criteria. It has been concluded by the staff that the existing neutron flux irstrumentation is acceptable for interim operation pending satisfactory implementation of a fully qualified indication system.

CONCLUS10f:

Basec on the staff's review of the attached Technical Evaluation Report and the licensee's submittals, we find that the Cooper Nuclear Station design is acceptable with respect to conformance to Regulatory Guide 1.97, Revision 2 except for the instrumentation associated with the neutron flux variable. It is the staff's position that the licensee shall install and have operational monitoring instrumentation for the subject variable which fully conforms to the recommendations of R.G. 1.97, Revision 2. The licensee shall develop.a schedule for this implementation through coordination with the NRC project manager.

Principal Contributor: R. Stevens Dated: October 27, 1986

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