ML19341D678
| ML19341D678 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/31/1981 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-1.C.1, TASK-2.E.4.2, TASK-2.F.1, TASK-2.K.3, TASK-2.K.3.30, TASK-TM GR-Q381-12, NUDOCS 8104080398 | |
| Download: ML19341D678 (5) | |
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ARKANSAS POWER & LIGHT COMPANY POST OFFICE box 551 LITTLE ROCK. ARKANSAS 72203 (501)371-4000 March 31, 1981 e
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Mr. Darrel G. Eisenhut, Director M
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Division of Licensing (v?7 e
N Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Subject:
Arkansas Nuclear One-Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR051 and NPF-6 NUREG-0737 (File: 1510.3, 2-1510.3)
Gentlemen:
By letters dated February 27, 1981 and March 11, 1981, AP&L committed to provide, by March 31, 1981, additional information relative to certain items in NUREG-0737. The required information is provided below.
I.A.l.3 SHIFT MANNING AP&L's commitments regarding this f tam were provided in our letter of October 31, 1980.
We feel that these comitments indicate our intent to comply with the requirements of NUREG-0737 - Item I.A.l.3.
Per our commitments in letters dated February 27, 1981 and Marcy 11, 1981, following is a discussion of the status cf our efforts.
AP&L's recruiting effort for operating personnel to meet our July,1982 shif t staffing goal remains active. Operations staffing level, including trainees, now stands at 77, compared with a minimum staffing level re-quired for July 1982 of 70 people, and a preferred level of 88 operations personnel.
It is expected that the total number of operations assigned personnel will exceed the preferred level (>88) sometime in September of this year.
It is not meant to imply, however, that these persons will be trained to assume specific shift duties on that date. Our greatest constraints in reaching our 1982 staffing goal are our ability to conduct operator licensing programs for the required number of R0's and SR0's within the existing time frame, and achievement of a high success rate in licensing exams.
f 810.40803D MEMBEA MOOLE SOUTH #1UTIES SYSTEM
l Mr. D. G. Eisenhut, Director March 31,1981 Our failure rate for the last unit one and unit two SR0 & R0 classes was near 80% for operator applicants.
(Had the old scoring criteria been applied to the exams, our failure rate would have been nearer 20%.)
The SR0 & R0 license training program for the current and future classes is being upgraded in an effort to improve the passing rate on license examinations. This action included expanding certain lectures, dedicating l
ANO personnel to specific class lectures, providing more timely audit exam feedback and course adjustments, and placing additional emphasis in weak areas.
Defining generic weak license examination arer has been a concern; no feedback relative to specific weak areas has been forwarded to us from the OLB following our January:12-16 unit one examination.
(All communication
. relative to that exam has been informally over the phone.) The unit two SR0 & R0 exam results were made known to us and were used to set criteria for license class upgrade.
Specific examination scoring feedback in a timely fashion following exams is crucial if effective training upgrades are to occur. With rapidly changing criteria, and little overall scoping criteria available to us which is also used by OLB, it becomes difficult to determine where our priorities lie in adjusting our license training efforts.
If a very high success rate cannot be achieved during all future exams between now and July 1982, it becomes evident that the 1982 goal cannot be met.
It therefore becomes imperative that rapid feedback from the license examiners occur, such that adjustments can be made prior to commencing future classes.
i II.E.4.2(5) CONTAIPNENT ISOLATION SETPOINT We have reviewed 'the operating history of containment pressure for both ANO-1 and ANO-2.
(These units have similar containment volumes i
and thermal power ratings.) Our review indicates that pressure increases l
of up to 2 psi can be expected to occur from time to time during plant operation.
Re setpoints for each unit are discussed below.
ANO-2: We do not agree that a margin of 1 psi is adequate to account for instrument error. By letter dated February 28, 1979, AP&L submitt:d l
a report entitled " Determination of Plant Protection System Setpoint l
. Values." This report was submitted as proprietary information per 10 CFR 2.790.
As ind:cated by Tables 1, 2 and 4 of the report, the loop error for. high containment pressure, excluding that due to an accident environment, is 1.63 psi. When added to an expected 2 psi incmase this gives a minimum setpoint of 3.63 psig or 18.33 psia.
This setpoint is currently required by Technical Specification 3.3.2.1 l
to be set 5 18.4 psia. We feel a margin 0.07 psi is already uncomfortably l
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Mr. Darrel G. Eisenhut, Director March 31, 1981 small and certainly no further reduction is desirable. Therefore, we conclude that no modification of the current setpoint is needed.
AN0-1: Here again we do not agree that a margin of 1 psi is adequate to account for loop inaccuracies. Although a detailed error analysis such as that referenced for AN0-2 is not available at this time, we have perfonned a simplified analysis based on component data. The results of this analysis shows a loop error of 1.1 psi.
This analysis did not include setpoint variances, effects of line voltage fluctuations or temperature effects and therefore somewhat underestimates the actual error. Wnen added to an expected increase of 2 psi this results in a minimum setpoint of 3.1 psig or 17.8 psia.
This signal not only initiates containment isolation but also initiates other safety features including High Pressure Injection. We feel that inadvertent actuation of this signal is highly undersirable.
Since the present setpoir,t has proven to be adequate to prevent inadvertent actuation and has shown acceptable results in all accident analysis we conclude that no modification of the current setpoint is needed or desirable. The additional margin of 0.9 psi accounts for errors not included in our analysis and provides a buffer to prevent inadvertent challenges to the engineered safeguard features.
II.F.1 SAMPLING AND ANALYSIS Or PLANT EFFLUENTS Upon publication of NUREG-0578 in July of 1979, Arkansas Power & Light began a concerted efforted to comply with the requirements as set forth at that time, including Item 2.1.8.B " Increased Range of Effluent Monitors."
The pertinent requirements were listed on pages A-39 and A-40 of NUREG-0578.
At the time the requirement dealt mainly with noble gas monitoring. With regard to iodine the following guidance was provided.
"Since iodine gaseous effluent monitors for the accident condition are not considered to be practical at this time, capability for effluent monitoring of radioiodines for the accident condition shall be provided with sampling conducted by adsorption on charcoal cr other media, followed by onsite laboratory analysis."
No mention of particulate monitoring was included.
Based on this guidance AP&L proceeded with procurement of an effluent monitoring system to meet the subject requirement.
In September of 1980 we received a draft clarification letter (later issued as NUREG-0737). By that time the effluent monitoring system purchased by AP&L was in final factory acceptance testing. This system was delivered in January of 1981, and is to be installed prior to January 1,1982 as required.
A description of the system is attached (See Attachment I).
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Mr. Darrel G. Eisenhut, Director March 31, 1981 Although this system fully meets the requirements set forth in NUREG-0578, it does not fully conform to the requirements of NUREG-0737. The system meets all requirements for noble gas monitoring and provides for monitoring of radiciodines and particulates by removable filters and onsite laboratory analysis. However a review of our current design shows that it cannot operate at the design basis concentration of 104 uCi/cc of radiciodine and particulate required by table II.F.1-2 of NUREG-0737. At this concentration shine from the filters interferes with the noble gas monitor portion of the system. We have concluded that, because of its design, modification of the system to accomodate this extreme concentration is not practical.
We feel that we have acted in good faith in the resolution of this matter.
We expect the current system to entail a total cost of 3.6 million dollars.
As provided by your statements at the September 1980 regional meeting in Las Vegas and your letter of October 31, 1980, we request that we be granted relief from this portion (Table II.F.1 Design Basis Shielding) of NUREG-0737 and that you approve our present design. Failure to grant the requested relief will require procurement and installation of an additional radiation monitoring system (the present system will still be needed for low range noble gas monitoring) at a cost of several million dollars and in our opinion is not cost beneficial. We feel that the specified concentration in NUREG-0737 is unrealistic and that our present design will provide adequate monitoring capability in the unlikely event of an accident.
II.K.3.30 REVISED SMALL BREAK LOCA METHODS (ANO-2 ONLY)
Per conversations with representatives of Combustion Engineering (CE),
we expect a proposal for the subject work to be presented to the CE Owners Group at their meeting on April 2,1981. We understand the proposed time to complete the work is consistent with the requirements of NUREG-0737.
Per our letter of February 27, 1981 we committed to provide a scope and schedule for the corresponding work for ANO-1 by April 28, 1981. We comit to provide similar information for ANO-2 by that date also.
Very truly yours,
& (. h David C. Trimble Manager, Licensing DCT:DRH:1p M3 Attachment
ATTACHMENT I AN0 EFFLUENT MONITORING SYSTEM The ten gaseous effluent release paths at the ANO site are to be monitored by Eberline SPING-4 monitors.
Each SPING-4 has on-line monitoring of particulates, iodines and noble gases in the effluent. The noble gas is monitored by thrge detectors pf different ranges providing an overall range of 1 x 10 ' to 1 x 10 +3 pCI/cc for Xe133-The readings taken by the SPING-4 are corrected for background radiation levels by the use of an area monitor which is integral to the SPING-4.
Removable filters are provided along with sample ports upstream of the filters permitting plant personnel to obtain representative grab samples of the effluent being released.
Sample stream concentrations of up to 10-4 pCi/cc of gaseous radioiodine and particulate can be monitored by use of filters and grab samples.
The SPING-4 has the capability to remotely purge the monitor assembly as _ well as remotely actuating a check source.
Readouts of each detector channel and the status of each monitor are available in both control rooms.
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