ML18017A042
| ML18017A042 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/14/1992 |
| From: | Lochbaum D, Prevatte D AFFILIATION NOT ASSIGNED |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| REF-PT21-92, RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.003, RTR-REGGD-1.003, TASK-2.F.1, TASK-TM NUDOCS 9301050046 | |
| Download: ML18017A042 (6) | |
Text
ACCEI ERAT DOCUMENT DIST VTION SYSTEM REGULAT INFORMATION DISTRIBUTIO YSTEM (RIDS) 2g ACCESSION NBR:9301050046 DOC.DATE: 92/12/14 NOTARIZED: NO DOCKET FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH.NAME AUTHOR AFFILIATION LOCHBAUM,D.A.
AffiliationNot Assigned PREVATTE,D.C.
AffiliationNot Assigned RECIP.NAME RECIPIENT AFFILIATION MARTIN,T.T.
Region 1 (Post 820201)
SUBJECT:
Suppl to 921127 Part 21 rept re high air concentration in reactor bldg making area uninhabitable for retrieving air filters,per NUREG-0737,?tern II.F.l.Util current position re fuel pool cooling issues contrary to Reg Guide 1.3.
DISTRIBUTION CODE:
IE19D COPIES RECEIVED:LTR
(
ENCL 0 SIZE: 5 TITLE: Part 21 Rept (50 DKT)
D S
NOTES: Maxwell,G Maxwell,G 05000387 05000388 D
RECIPIENT ID CODE/NAME PD1-2 LA RALEIGH'.
INTERNAL:
QDJJDSP/
OAB REG FILR Ol GM'GN3 RGN5 EXTERNAL: INPO RECORD CTR NSIC SILVERgE NOTES:
COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD1-2 PD NRR/DRIS/RVIB9D RES/DSIR/EIB RGN2 RGN4 SECY VANDERMEL NRC PDR COPIES LTTR ENCL D
D A
D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTETH CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
ll TOTAL NUMBER OF COPIES REQUIRED:
LTTR 17 ENCL
December 14, 1992 Mr. Thomas T. Martin Regional Administrator, Region I United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION DOCKET NO.
50-387 LICENSE NO. NPF-14 SUPPLEMENT TO 10CFR21 REPORT OF SUBSTANTIAL SAFETY HAZARD
Dear Mr. Martin:
On November 27,
- 1992, pursuant to the requirements of
- 10CFR21, Reporting of Defects and Noncompliance, the undersigned submitted to the NRC a report of a "substantial safety hazard" that exists in the design of the Susquehanna Steam Electric Station (SSES) with regard to cooling of the spent fuel pool.
During the past
- week, one of the undersigned, Mr. Prevatte, in the course of performing his assigned duties in the licensee's engineering offices in Allentown, Pennsylvania, discovered documents which are pertinent to the condition that was reported.
This letter is to bring these documents to your attention so that they may be considered in your evaluation of this condition.
One'of the main points of contention between Pennsylvania Power a I ight Company (PPaL)
(the licensee)
Nuclear Department managers and ourselves regarding this condition has been the accessibility of the reactor building post-LOCA.
We have contended that the radiation levels in the reactor building must be considered per the requirements of Regulatory Guide 1.3 and NUREG-0737, and that if they are so considered, the reactor building is inaccessible for at least the first several days of a design basis LOCA event, as stated in the SSES FSAR, Chapter 18.
PP&L has taken the position that they do not have to consider accessibility per these requirements, and that the reactor building is accessible, and therefore, the operators can enter the building to take the actions required to provide makeup water to the fuel pool upon loss of normal fuel pool cooling and to mitigate the effects of the boiling spent fuel pool on the safety-related equipment in the reactor building.
They have also taken the position that the airborne contributor of post-LOCA reactor building dose does not have to be considered since it was not included in their FSAR submittal.
The documents discovered this week directly relate to these points of contention.
In an NRC letter to the licensee dated April 23, 1984 transmitting inspection reports numbered 50-387/84-10 and
"'i AAO8 930105004b
'F21214 PDR ADOCK 05000387 S
50-388/84-11, in Section 6.0, Sampling and Analysis of Plant Effluent, Item II.F.1-2, pages 12 and 14, the NRC position with regard to accessibility for post-LOCA sampling was stated as follows:
"NUREG-0737, Item II.F.1-2, requires the provision of a capability for the collection, transport, and measurement of representative samples of radioactive iodines and particulates that may accompany gaseous effluents following an accident.
It must be performable without exceeding specified dose limits to the individuals involved.
"The sampling units are presently located in the fuel handing area in the 818'evel of the reactor buildings.
In an accident situation, high air contamination levels could make the area uninhabitable for retrieving the filters.
The shielding study by Bechtel did not consider air contamination from an accident...
"Samplers should be located in an assured habitable area so that necessary procedures can be conducted within the dose limits established in NUREG-0737."
PPSL acknowledged these requirements and committed to change their design accordingly in their letter PLA-2219 of June 4,
1984.
In a one page discussion, PPaL stated that "...under a
post-LOCA environment the high radiation levels on the reactor building refueling floor (elevation 818'/SPING monitor location) would not permit personnel access...",
that the peak airborne dose rates on the refueling floor were 600 rem/hr and would remain above 100 rem/hr for the first 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> post-LOCA, that the exposure rate would prevent meaningful access, and that as a result of their reevaluation new sampling equipment would be installed in'a low radiation area.
Regulatory Guide 1.3 and NUREG-0737 assumptions were used as required in their reevaluation of accessibility, These documents clearly convey the NRC's position with regard to the standards which must be followed in performing post accident accessibility evaluations and whetner airborne contamination must be considered.
They also clearly convey PPEL's understanding of those requirements, their commitment to conform with those requirements, and their understanding that in applying those requirements, the reactor building is inaccessible for considerable time post-LOCA; PPSL's current position regarding accessibility relative to the fuel pool cooling issues is contrary to these requirements, understandings, and commitments.
We appreciate your consideration of these
- concerns, and we trust that this additional information will be useful in your
eg "
evaluations..
Should you require any additional information/
please do not hesitate to contact us.
Yours very truly, David A. I ochbaum Donald C. Prevatte CC:
Mr. G.
S. Barber Senior
- Resident, Inspector US Nuclear Regulatory Commission P.
O.
Box 35
- Bervick, PA 18603-0035 US Nuclear Regulatory Commission Attention:
Document Control Clerk Mail Station Pl-137 Washington, DC 20555 Director, Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 The Honorable Ivan Selin Chairman US Nuclear Regulatory Commission Washington, DC 20555 The Honorable Kenneth Commissioner US Nuclear Regulatory Washington, DC 20555 C. Rogers Commission The Honorable James R.
Commissioner US Nuclear Regulatory Washington, DC 20555 Curtiss Commission The Honorable Forrest Commissioner US Nuclear Regulatory Washington, DC 20555 J.
Remick Commission The Honorable Gail De Commissioner US Nuclear Regulatory Washington, DC 20555 Planque Commission
4%