ML19338D639

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Confirms 800919 Telcon Re Clarification of Util Position W/Respect to NRC Questions Concerning 800628 Submittal on TMI Short-Term Lessons Learned Requirements
ML19338D639
Person / Time
Site: Beaver Valley
Issue date: 09/17/1980
From: Sieber J
DUQUESNE LIGHT CO.
To: Ross W
Office of Nuclear Reactor Regulation
References
BVPS-LC:JDS:398, TAC-44421, TAC-44901, NUDOCS 8009230593
Download: ML19338D639 (8)


Text

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==- 152 t9 DUQUESNE LIGHT COMPANY Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077 September 17, 1980 BVPS/LC:JDS:398 Memorandum of Telephone Conversation Compliance with NUREG 0578 Items 2.1.6 and 2.1.8 Mr. William J. Ross, Licensi 3 Project Manager United States Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Washington, D. C. 20555

Dear Mr. Ross:

This memorandum confims our telephone conversation on September 9, 1980 concerning clarification of the position of Beaver Valley Unit No.1 (DPR-66) with respect to certain questions raised by NRC staff reviewers on Duquesne Light Company's June 28, 1980 submittal on TMI-Short Term Lessons Learned Requirements. During that telephone conversation, I stated the following positions for Beaver Valley Unit 1. 2.1.6 (a) Systems Integrity 1. Q. Submit a summary description of the program. A. A study was conducted to identify systems with potential leakage paths outside containment which would or could contain highly radioactive fluids during a serious accident. The following systems were identified and evaluated as having potential leakage paths for highly radioactive fluids. I 8009230 $93

m7 .r.. . - r. - p 4 _ m. s>@._ ~ + L*) Mr um of TalcphonefConvhrsation ~ ' Compliance'with)NUREG 0578 Items:2.1.6 and 2.1.8: "I-

PageL2' fa)-
Safety Injection Systed :. Recirculatio'n = Phase -

I )I LContainment Depressurization System --Recirculation b Spray' Subsystem Lc)- Containment Vacuum and.Depressurization System - Containment. Pressure Sensing Subsystem - .d)L -Post DBA Hydrogen Control ~ System .The leakage reduction program includes visual. inspection of fluid. systems and measurement of existing-leak rates for both . fluid and gaseous systems... Test procedures-have been prepared for the conduct and documentation of leak tests and the tests-will be performed prior to entry into Mode 2. The results of tha. tests will be, evaluated by the'Onsite Safety Committee and plant leakage characteristics will be identified and work will-be initiated to repair all identified leakage paths where

feasible.'

2. Q. Physically redu'ce leakage as much.as practical. A. - Duquesne Light Company. commits to reduce identified leakage-in-systems within the scope of the program as much as.is practical. 3. 'Q. Ensure that inability to_use any excluded system would not preclude any option for cooling the core (including RC pump use and normal makeup) nor prevent'the use of any' safety system (including sampling).- A.- Attached as Table I is a " Summary of Systems" where each! system is tabulated as to whether it' or'some portion of it is excluded from the leaka'ge reduction' program and states the reasons for- ~ w' '. exclusion.' W point out that the current conceptual design for the permanent sampling system provides that:the system will be' automatically isolated if significant leakage occurs.- 4;. Q. -. include provisions to keep' leakage as low as practical or ' demonstrate that the proposed criteria are as low 'as practical. , A, Provisions have been-' included in the program to keep leakage: ~ .as-low as practical'.': - 5. ' Q.

Ensure _that proper: equipment and properly trained personnel

~ -will be used-for all helium leak testing.or'decument that -there will'be no; helium leak tests. A. No helium' leak tests'are planned for this program. ,>.3 y c% 7 g '5 i g t x ~ p ~ ~

[] 4 i ~- 1 Memorandum of Telephone Conversation'- Compliance with NUREG 0578 Items.2.1.6 and 2.1.8

Page-3;

~2.1.6'(b) Shieldina 1.

Q..

Ensure that. the evaluation of. electrical' equipment meets .the Lessons Learned requirements including use of the' NRC-specified source terms;and including all' safety related electrical equipment.. - A. The. evaluation of electrical equipment will be performed in accordance with the requirements of IE Bulletin 79-01B. - Electrical. equipment inside containment will'be-evaluated 1 before entry into Mode 2 from the current startup and electrical equipment outside. containment will be evaluated by November 1, 1980. NRC-specified source terms were~used~ for this evaluation. 2.' Q.- Complete evaluation of mechaniEal. equipment. A.. A study was conducted of radiation effects on mechanical components of safety related, systems outside containment r' under~ postulated. accident conditions including special attention being given to components containing radiosensitive materials. Conservative source terms were used'to calculate the-radiation effects of both; beta and gamma radiation during an accident and the 40 year normal' plant lifetime exposure. was added to the accident dose.- In all cases, the post-accident calculated : total integrated dose is less than the allowable - total integrated dose for each' component.within the scope ~ of the study.. 2.1.8-(a) Sampling 1. Q. ! Report whether the interim system permits RC analysis for chloride and pH.- A. .The interim system has no provisions for chloride and pH analysis. This was not a requirement of Mr. H. R. Denton's letter of October 30, 1979. -2.- Q. Provide interim alternate counting' facilities (even if analysis cannot be performed there within one hour).

A.

' Alternate counting fac' ilities exist at'Shippingport Atomic Station'(located'on-site, adjacent to' Beaver Valley Unit 1). Bettis Atomic Power Laboratory (a D.O.E.11aboratory) is =1ocated about 1. hour's' driving time:from the site. J i N 2-I

m . Memorandum'of Telepho:ne' Conversation Compliance with NUREG 0578 Items 2.1.6 and 2.1.8 Page 4. 3. Q. Include provisions in the post-accident sampling and analysis procedures to prevent overexposure. A. . Separate radiological control procedures are being written and will be approved before entry into hbde 2 from;the present shutdown which are designed -to prevent overexposure t during the operation of the.-interim chemical sampling facilities. . Train personne' in the use of the procedures. 4. Q. 1 A. Personnel will be trained in the use of the procedures before entry into Mode 2 from the current shutdown. 2.1.8 (b)' Radiation Monitors. 1. Q. Provide noble gas monitoring of the atmospheric steam ~ dump and safety' valves. A. Each of the three banks of atmospheric steam dump and safety valve headers is monitored by a high level gamma pressurized ion chamber (Eberline Model RD-17A). 'Each detector is enclosed in a nominal 4" thick collimated lead shield assembly. 'Each is located between a Steam Generator Atmos-pheric. Steam Relief Valve (PORV) riser and'the first, Steam Generator Code Safety. Valve riser. The collimation windows in each unit are focused on the PORV and safety valve riser. A fourth detector is located in the'same general area in a 1ead shield assembly.to measure ambient radiation contributions ~ from sources other than the steam dumps. This detector is used to differentiate between release via the cafety steam dumps and other contributors to radiation levels seen by the'other monitors. 4 Each detector is connected to a four decade logarithmic rate meter (Eberline Model RM-16) and a recorder. These readout devices are located in a Ventilation Systems Room at elevation 752' 6" of the Service Building. It is outside of any area where high radiation levels can normally be expected. It is directly accessible via the supervisor locker room adjacent ' to the' station administrative office. ~ Pro ~ edures have been draf ted for the use of these monitors c as well as other interim radiation monitorirg systems. -These procedurec address their use in both routine and emergency / accident conditions. =These monitors provide capability to l

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Memorandum of Telephone.. Conversation Compliance.with NUREG 0578 Items 2.1.6 and 2.1.8 Page 5-0 assess release rates up to 10 C1/sec. The detector. range exceeds the upper range of system requirements by more than an order of magnitude. Appropriate conversion factors from -~ meter and/or-recorder reading to. release activity (or -activity release rate)'are included along with methods of: applying this data to quantify releases.. 2. Q. Provide backup -power for radiation ' monitoring system. > A. Each.of the interim radiation monitoring systems is powered by'an emergency bus providing for continuous radiation monitoring in the event of loss of offsite power.

3..

Q. Provide training in the use of the interim post-accident monitoring system. A. Appr6priate training will be provided.to personnel expected to use the interim post-accident monitoring systems. Should further questions arise, please contact me. f Very truly yours, I ' J.'D. Sieber #[I3 Superintendent Licensing and Compliance JDSiba Attachment -l l ) - i u ' D' ~ f a- ?_ '5.. L _'i.

Memorandum of Telephone Conversation ' Compliance with NUREG 0578. Items.2.1.6 and 2.'1.8 . Page 6 ~ BLIND COPIES TO:. Messrs. C.-N. Dunn. G. W. Moore . J.' : J. - Carey. J.- A. Werling J. A. Kosmal .J..C. Allingham J. W.' Wenkhous L'.' G. Schad R. F. Burski . Central File (2) e 'f - i L'_

' TABLE I

SUMMARY

OF SYSTEMS' INCLUSION IN LEAKAGE SYSTEM PROGRAM COMMENTS Reactor Plant Vents & Drain 'No. Containment sump,2 primary drain transfer tank and gaseous releases are isolated by CIA Supplementary Leak Collection No System serves for collecting and Release System and exhausting leakage from other systems to the environ-ment; therefore, is not included in leakage reduction-program. Boron Recovery System (BR) No Provided'that Chemical and Volume Control System (CHS) is not used. Radiation Monitoring System (RM) No Containment Structure and No Personnel air lock and equip-Air Lock ment hatch'are closed and not. available for personnel access. Post LOCA Sampling System ~ No Not required to mitigate an accident. (Note: Currently scheduled f r installation by 1/1/81.) -Liquid Waste. System (LW) No Connected co vent and drain systems which have no flow-path from containment. Solid Waste / Decontamination (SW) No Connected to CHS, BR, LW, c.nd fuel pool Gaseous Waste (GW) No Connected to BF.. As long as CHS remains isclated GW should not be used. Area Ventilation' No Separate. air supply provided in control room if accident. occurs. S-c,. :_ ' b-{ a - ~ C. : -. 0

m-1 TABLE I-(Continued) INCLUSION IN. LEAKAGE-SYSTEM PROGRAM COMMENTS' ' Chemical and Volume Control' No Except charging pumps in' SIS- - (CHS) recirculating phase. Also, pump seal' injection water would be used if any RC-pumps are operable. Reactor Coolant System (RCS) No' Inside containment ~ Safety Injection System (SIS) -Yes -Recirculate containment' sump; water in recirculation phase Containment Depressurization, Yes Recirculate cont'ainment < sap Recirculation Spray water through spray (2 pumps outside containment) ' Containment Vacuum Leakage. Yes Pressure caps inside'contain-Monitoring System, Containment Pressure Sensing SuFsystem ment and sample line extending outside containment Residual Heat Removal System No Inside containment (RHR) Post-DBA Hydrogen Control Yes Draw contaiiunent air. for System-hydrogen monitoring and recombination of H and 0

  • 2 2

Containment Hydrogen Purge No System Use of-this system for purging containment of hydrogen results in purging of contaminated air through filtering system to the environment. Should be avoided, if possible.; Post-DBA Hydrogen Control System dedicated forf contain - ment hydrogen control. 4 = w .1D 4 E v '}}