ML17298B319
| ML17298B319 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/04/1984 |
| From: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8410100197 | |
| Download: ML17298B319 (6) | |
Text
MEMORANDUM FOR:
FROM:
D.
G. Eisenhut, Director, Division of Licensing, NRR T.
W. Bishop, Director Division of Reactor Safety and Projects
SUBJECT:
PVNGS COMPLIANCE WITH REGULATORY GUIDE 1.143 - TRANSFER OF LEAD RESPONSIBILITY (DOCKET NOS. 50-528, 50-529, 5O-53O)
During a special NRC inspection, on August - September, 1984, the inspection team found that a licensee audit (dated April 26, 1984) identified that the Bechtel Design Criteria was out of date relative to the requirements of Regulatory Guide 1.143.
Regulatory Guide 1.143, "Design Guidance for Radioactive Waste Management
- Systems, Structures and Components Installed in Light Water Cooled Nuclear Power Plants," requires that the Radwaste and Steam Generator Blowdown Systems comply with a number of technical and quality assurance requirements.
The preliminary Bechtel response to the audit finding (the audit finding is still open) has been to propose a
revision to the FSAR to include five technical exceptions to the Regulatory Guide (the five exceptions are included as Attachment No.
1 to this letter).
- However, due to the late stage of construction (for Unit No.
- 1) Region V is concerned whether the proposed Bechtel exceptions meet the intent of the Regulatory Guide and whether the systems are designed and constructed as originally committed by the licensee and intended by NBA II The licensee stated in Amendment No.
4 (dated
- May, 1981 to the FSAR, that they complied with the position of the Regulatory Guide, with no exceptions noted.
Additionally, it must be noted that the Regulatory Guide requires the establishment of a minimal quality assurance program for the Radwaste and STeam Generator Blowdown Systems, including a program of inspections and sufficient records to furnish evidence of the implementation of the Regulatory Guide's stated requirements.
The preliminary Bechtel audit response does not address the quality assurance requirements of the Regulatory Guide, though discussions with the licensee indicate they believe they are in compliance with the Regulatory, Guide in this aspect.
Further discussions and inspections determined that the licensee has designated the Radwaste Systems as Class "R" and the Steam Generator Blowdown System as Class "S".
Class R systems are discussed in the licensee's quality program and are under a minimal quality program with the exception that, Area and Welding Field Engineers perform and document inspections instead of quality control inspections.
These inspections are performed on a surveillance basis and not on each and every item (weld, as-built condition, etc.).
Class S systems are not discussed in the licensee's quality program, though licensee personnel state that they inspect these classes of systems.
84'10100197 841004.
PDR ADOCK 05000528 8
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D.
G. Eisenhut OCT4 88'dditionally, it was found that the licensee has no program for the protection, storage or turnover of Classes R and S system documents.
Therefore, based on the foregoing, the Region requests NRR assume lead responsibility for evaluating whether the licensee's technical exceptions and the lack of formalized quality control inspection and record retention comply with the commitment to the Regulatory Guide.
T.
W.
shop, Director Division of Reactor Safety and Projects CC:
G, Knighton, NRR E. Licitra, NRR R.
Zimmerman, SRI, Palo Verde G. Hernandez, SRI, Palo Verde L. Miller, RV bcc:
RSB/Document Control Desk (RIDS)
Mr. Martin, RV pink/green/docket file copies RV Bish dot 10/
/84
1 I
Attachment 1
Position C, paragraph 1.1.3 - The turbine building, which houses most, of the steam generator blowdown system, is a Seismic Category II braced steel and concrete structure with a design that has been shown not to collapse under SSE loads.
The turbine building has no means of containing the maximum liquid inventory contained in the potentially radioactive portions of the steam generator blowdown system.
This potential for liquid/gaseous release is less than that resulting from failure of the refueling water tank analyzed in FSAR section 15.7.3 where the radiological consequences have been determined to be less than 1/ of the 10 CFR 100 limits.
b.
Position C, paragraph 1.2.1 - High level alarms on tanks in the Radwaste Building alarm in the radwaste control room instead of the main control room.
A common radwaste alarm sounds in the main control room for any alarm that exists in the radwaste control room.
No tank has a local alarm as the tank overflows are hardpiped to to sumps avoiding local uncontrolled spillage.
c
~
Position C, paragraph 1.2.3 The blowdown flask tank, (SCN-XOl) in the turbine building, does not have an elevated threshold to catch potential leakage.
However, because this t'.ank operates at an elevated temperature and pressure, any leakage would be initiallyvisible as steam.
Liquid leaks would be collected by the Turbine Building Drain System, which can be routed to the I,iquid,Radwaste System.
d.
Position C, paragraph 4.3 - Pressure testing is conducted using the applicable ASME or ANSI code, but in no case less than 1.5 times the line design pressure for a minimum of 10 minutes as required by the above codes.
Testing per applicable code requirements results in a higher test pressure for a shorter period of time than is recommended by the regulatory guide and is considered acceptable.
e.
Position C, paragraph 5.1.2, 5.2.4 - The reinforced concrete design of these structures is in accordance with American Concrete Standard ACI-318 in lieu of ACI 349-76.
Structures containing radwaste systems are analytically verified to withstand SSE loads without collapse.
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