IR 05000412/1987050
| ML20236S766 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/25/1987 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Carey J DUQUESNE LIGHT CO. |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8711300082 | |
| Download: ML20236S766 (2) | |
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- l ' Docket No:;50-412 ' ! Duquesne Light Company l ATTN: Mr. J. J. Carey__.
l Senior Vice President ." . Nuclear Group Post Office Box 4 l Shippingport, Pennsylvania 15077 i E Gentlemen: L Subject: ' Inspection 50-412/87-50 'This refers to your' letter dated October 14, 1987, in_ response to our - letter dated September 14, 1987.
I l Thank you for informing us of the status of your planned actions to address the improvement and unresolved items identified in the referenced.NRC Inspection Report, regarding the implementation of certain:TMI Action Plan requirements (NUREG0737). These actions' vill be examined during a future inspection of your licensed program.
! l ( Your cooperation with us is appreciated.
Sincerely, Ori;;inal Signed By: Ronald R. Bellamy Thomas T. Martin, Director Division of Radiation Safety and Safeguards cc w/ encl: J. D. Sieber, Vice President, Nuclear J. Crockett, Senior Manager, Nuclear Operations J. P. Thomas, Manager, Engineering R.'J. Swiderski, Manager, Startup Group E. Ewing, Quality Assurance Manager R. E. Martin, Manager, Regulatory Affairs C. O. Richardson, Stone and-Webster Engineering Corporation Public. Document-Room (PDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector Commonwealth of Pennsylvania 8711300082 871125y PDR ADOCK 0 % 4 2 ![ % "USl RE0i!D ]DPY"
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0FFICIAL RECORD C0Pf r1 87-50 11/18/87 _-__________a
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\\ Duquesm@ Beever Valley No. 2 Unit Project Organization (412) 643-5200 S.E.G. Building Telecopy (412) 643-5200 Ext.160 P.O. Box 328 Shippingport, PA 15077 October 14, 1987 United States Nuclear Regulatory Commission / Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards SUBJECT: Beaver Valley Power Station Unit No. 2 Docket No. 50-412 Inspection Report 50-412/87-50 Response REFERENCE: Letter dated September 14, 1987 (T. T. Martin to J. J. Carey) Gentlemen: The above referenced letter transmitted Inspection Report 50-412/87-50 covering the Beaver Valley Power Station Unit No. 2 implementation of certain THI Action Plan Requirements (NUREG 0737).
The letter requested Duquesne Light Company (DLC) to review some improvement and unresolved items discussed in the report and to respond on actions planned or taken in regard to these items.
The attachment to this letter provides DLC's response to these items.
DUQUESNE LIGHT COMPANY . - BY Z J.M arey / Sr. Vice President Attachment Mr. P. Tam, Project Manager (v/a) cc: Mr. J. Beall, NRC Sr. Resident Inspector (w/a) INPO Records Center (w/a) i ' NRC Document Control Desk (v/a) n m e fpp.
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_ >' (,, ., , , h ' ' ATTACHMENT l Response to Inspection Report 50-412/87-50 ' Inspection Report 50-412/87-50 listed three (3) areas which vere considered to require inspector follow-up, and two (2) unresolved items. These items from the
Inspection Report are listed here, followed by the Duquesne Li,sht Company response.
, 1.
Pass Sampling and Analysis Items for Improvement (NUREG 0737, Item II.B.3) f
L The report states, in part: \\ w The licensee indicated the following matters vill be re(ieved and ! clarification / improvements will be considered, as appropriates C50-412/87-50-01)
? y (A)
- The procedures for performance of Reactor Coolant' h d Containment Atmosphere Sampling Operations have -yet to be finalized and implemented, including revisions to the sequence for collecting samples, verification of the gas dilu't)m factor and reference to appropriate procedures for handling high activity samples.
(B) Document that the PASS Piping and Valving Systems are capable
of functioning as designed at applicable reactor coolant temperatures and pressures.
, (C) Perform a comparison of the routine Reactor Coolant Sp;, tem and
PASS sample analyses results when sufficient activity is present in reactor coolant.
t i (D) Ensure that the In-Line Boron Analyzer and Gas Chromatograph
are operational.
(E) Develop and implement a procedure for Gamma Isotop c Detector
Calibration.
- I Response: ) y i J t' (A) The PASS procedure has been rewritten and reissued using guidance l provided by the NRC during the inspection. The Gas Dilution Ratio { has been experimentally verified to be 160.
(B) The PASS vas tested after the Reactor Coolant System reached operating temperature and pressure conditions. Automatic valves were verified to operate properly.
All tempsratitres, flows and pressures throughout the system, vere verifie'd to be within design, and no valve leakage was noted.
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(C) Thidf 6 n64 yet complete due' -to ' insufficient-activity in the !) Reactor Coolant.- WhenLthe actTvTty is sufficient, the compa;ison a vill be performed and the results made,available to Mr. V. Thomas of the NRC.
, j['. y'il ' (D). The Gas Chromatograph used. in the. PASS to determine hydrogen-concentrations has been recalibrates and neu! Quality Control l- ~ f Charts have been.
generated.
The.
problem with,the Gas
j Chromatograph experienced during the-inspection has. been corrected.
The in-line. boron analyzer. is not yet in operation. The BV-2 In.s trumenta tion - and Control' Section is working to make.it operational as soon as possible.
(E) A calibration procedure for-the Gamma Spectroscopy System, used in measuring PASS samples, has been g2nerzted using guidance from the NRC and has been issued.
.1 r 'l i 2.. Noble Gas Effluent Monitor (NUREG 0737,2Uem II.F.1-1) N (
The Report untes,: "The licemee indfgated the following matters vill be' reviewed,d, as appropr..'te:idlarification/improvoyents vil bes ! and
considen " 9" - (50-412h7-05-02)
Approve Preoperational P30cedure P.O.
2.43.01, y - Sections N and 0, ' Radiation'Nonitoring System'." c Response: The referenced procedure, P.O..2.43.01, Sections N and 0 and its associated test results, have been approved.
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3.
amplingAtryi Analyses of Plant Effluents (NUREG 0737, Item II.F.1-2) r , , f ' Td re.p2Rs states, in part: p , " fne licensee indicated the following marrars will be reviewed and - ! clarification / improvements vill' oe considered, as appropriates (50- - - f-F 412/87-50-03) , p ,- ' (A)
Determine conservative correction factors for line loss or line I deposition for particubtes and radioiodines in the High , j Activity /Loy Tolume Flev Rau (HA/LVFR) Effl6ent Sampling: Path.
' j,.s , (B) Evaluate need to change the Isokindic Control Ratio for the
HA/LVFR EfflVsnt SamplingtPath and document assumptions and resultant dose to sample collectipn personnel from the source term in the Dhvated Helease / Duct above the Monitoring Skid; have approved procedures for manual operation of the Gamma Spectrometer in the Unit 2 Radiochemical Laboratory and Radiochemical parsonnel trained in those procedures.
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Provide calibration,andDrecord,s for counting silver zeolite j
'- cartridges on the Gamma Spectrometer.
' Respons d .s ? ' (A) 'Through khenGeneral Atomica Digital Radistion, Monitor System g
User's Group, Y request for Wide Range gas Monitor (VRGM) low I flowrate, sample line loss studies has7 been made. A number of utilities have responded to date.
The ': study results are being q collated to.ieientify asy similarities / correlations. One study was performed on a system very similar to BV-2 and n correction factor-is being developed.for our installation based.on;this study.
(B) An Engineering M'emorandum (EM)'No. 62433, dated July 17, 1987, has sbeen issued to address whether the Isokinetic Control Ratio for-the llA/LVFR Effluent Sampling Path requires. any change.- j . Engineering is ' continuing to investigate this. matter with the ' ' ' vendor, GA Technologies.
Q SVEC Calculation 12241-UR(B)-441-1, dated August 17,.1987,. documents the assumptions uskd,and tlye total dose calculated to sample collection perg.onnel from alll1 sources, including from the source term in the Elevated' Rbleast Duct above the Monitoring
3 Skid. The dose contribution from this duct.is 0.03 Rem, assuming j' the data collection person is at the Monitoring Skid for ten.(10) minutes.
\\ i a !'l Approved procedures for! the automatic operation of the Gamma " s Spectrometer in the BV-2 Radiochemistry Laboratory, were added to the BVPS Chemistry Manual in Chapter 5.
These procedures contain [,; detailed instructions and the asdiochemistry personnel have been
familiarized with these procedures.
l O (C)' The Gamma Spectrometer in the 'BV-1 Radiochemistry Laboratory was ) ,, ' calibrated 'on July 16, - 1987, for counting silver-zeolite cartridges.
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n: , s . 4.. Power Sources to the PASS System The report states, in part: "All of the above power supplies are considered to be capable of providing reliable power to the segment / portion of the PASS System they feed.
However, the inspector identified the large number of power; supplies which are required to be operable in order for.the PASS System 1 to operate add to the complexity of the' system.
As an example, in' order to take 'any sample,. all' of the five.(5) power feeders must provide power to a position of the system a ' single failure in any of~ the feeders.~ disables the entire PASS ~ sampling capability,:DLCo committed to review. their Station Operating Procedures in order to assure that a power feeder failure can be easily detected / traced and overcome to permit PASS sampling within-the three (3) hour PASS System sampling time design requirement. This matter is considered unresolved (50-412/87-50-04)."
Response i The. applicable BV-2 Operating Manual (OH) Chapters, Chapter 14A, " Reactor Plant Sample System" and Chapter 14C,." Post-Accident Sampling System," describe the specific power sources for the various components involved in-the PASS function.
This information,is contained in L Section 3 of the chapters in the " Power Supply and Control Switch.
L List." The format is standard for each BV-'2 OM ' Chapter and the operators are thoroughly familiar with this format.
Recovery from loss of power source conditions is adequately addressed in the BV-2 OM'when automatic transfer to an alternate source does not l occur or is not available.
Appropriate alarms and computer points are available in the Control Room.
The use of two position indication lights at the control switch (es) for various PASS valves also provides a simple method of verifying power. source availability.
Lack of illumination of both position indicating lights of these normally ! l energized circuits is a sign of possible power loss.
Operator response I ' is expected to be timely so that the PASS process is not significantly . l delayed.
Regulatory Guide 1.97, Rev. 2 (RG 1.97) lists variables associated with j < [ the PASS function as Type E, which are defined as backup variables and as Category 3 for purposes of Design and Qualification Criteria.
RG 1.97 requires no specific provision for instrumentation power sources and no specific provision for redundancy. Regulatory Guide 1.97, Rev. 3, retains these same positions.
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PASS Environmental Qualification (EO) The report states, in part: The licensee indicated the following matters-vill be reviewed and clarification / improvements vill be considered, as appropriate: (50-412/87-50-05). This item is considered unresolved: Verify acceptability of PASS in-containment valves which are ' currently not considered by the licensee to require Environmental , Qualification but may be required to operate under accident conditions for purposes of sample collection.
Response: The subject valves are Reactor Plant Sampling System (RPSS) valves, also utilized by the Post-Accident Sampling System (PASS). Namely, Primary Coolant Hot Leg Samples 2SSR*SOV121A, B, C and D RHR Heat Exchanger Outlet Samples 2SSR*S0V123A and B i These in-line solenoid operated valves were procured under Purchase Specification 2BVS-719 as OA Category I valves, specified to withstand BV-2 in-containment accident conditions and were supplied with all necessary documentation to qualify for Class IE use. Likewise, the associated field installed connecting cabling for these valves was procured under QA Category I purchase specifications for electrical cable and is qualified for Class 1E, in-containment accident condition use.
Based on the actual application of these valves and associated cabling however, BV-2 has not included this equipment in the BV-2 Equipment j Qualification of Electrical Equipment (EO) Program.
There are no i specific Equipment Qualification provisions for PASS capability, a Category 3 variable, in Regulatory Guide 1.97, Rev. 2.
These valves do not perform any safety related function and in accordance with the j current BVPS-2 E0 position are not within the scope of 10CFR Part 50.49 i (E0 Rule).
In accordance with the Regulatory Requirements of NUREG 0737, Item II.B.3 and RG 1.97, these valves are of high quality . commercial grade and are selected to withstand the specified service ! environment.
All of the above is consistent with the BV-2 FSAR l Sections 9.3.2.3.1, 9.3.2.3.2 and 9.3.2.3.3 and the BV-2 RG 1.97 position in the BV-2 FSAR, Table 1.8-1,
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