ML20023D224
| ML20023D224 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/06/1983 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8305200229 | |
| Download: ML20023D224 (5) | |
Text
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7w8 iMsconsm Electnc romcome 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI $3201 May 6, 1983 Mr.
J. G. Keppler, Regional Administrator Office of Inspection and Enforcement, Region III U. S. NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
DOCKET NOS. 50-266 AND 50-301 RESPONSE TO IE INSPECTION REPORT NOS. 50-266/83-03 (DRMS) AND 50-301/83-03 (DRMS)
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 This is in response to certain items noted in NRC IE Inspection Report Nos. 50-266/83-03 and 50-301/83-03 dated February 16, 1983.
Although a response is not required since there was no noncompliance identified in the subject inspection reports, we wish to clarify our position regarding the maintenance and testing program for HVAC filter units not controlled by the Technical Specifications and for the respirator fitting program.
HVAC filter units which are not governed by the Technical Specifications are tested annually (particulate or adsorption, as applicable) to establish current operational filter efficiencies and to check for overall system deterioration.
It should be noted that these filter units are not required from a safety standpoint but are provided for an ALARA function.
There is no requirement for the minimum acceptable operating efficiency of filter units not regulated by the Technical Specifications.
Following testing, the operating condition of a filter unit is analyzed on a case-by-case basis to determine if maintenance is necessary.
The following factors are considered in determining if a filter's performance level is acceptable:
1.
Standard industry practices, NRC Regulatory Guide 1.140, and ANS N510-1980.
2.
The intended function of the unit.
3.
The unit's design capabilities. 0305200229 830506 MAY 12 M PDR ADOCK 05000266 G
PDR 22:07
1 Mr.
J.
G.
Keppler May 6, 1983 4.
Anticipated future operating conditions.
5.
ALARA considerations.
6.
Radwaste considerations.
7.
Financial considerations.
This approach provides an effective means of obtaining the basic operational design objective of a particular filter unit, while also integrating other significant factors of an overall operating management standpoint.
We believe the application of sound equipment management practices is preferable to the arbitrary assignment of efficiency acceptance criteria.
The subject filter units do receive attention.
The specific items from the inspection report are discussed below and are numbered to correspond with the inspection document.
3.
The concern identified in this item relates to the practice of not retesting a filter unit following replacement of HEPA filters.
In general, retesting of filter units following minor maintenance activities is not necessary.
Maintenance activities, many of which are corrective in nature resulting from testing, include filter module replace-ment (HEPA and charcoal), localized seal repair, clamping device repair, etc.
We have not experienced any sub-sequent annual test failures due to previous minor maintenance activities in 21 reactor-years of operation.
This approach has been successful because of factory testing of filter modules, design and consistency of seals and filter modules, design of clamping devices, and the ability of the testing program to determine the particular problem.
In view of the fact that there is no requirement for filter retesting, and in consideration of the above, we have elected to omit filter retesting following the performance of routine minor maintenance activities.
In the event of major nonroutine maintenance that could adversely affect the performance of a filter unit, follow-up filter testing would also be performed.
Mr. J.
G. Keppler May 6, 1983 5.
In this item, the concerns relate to the practice of allowing a filter unit to remain in operation with parameters less than the recommendations of NRC Regulatory Guide 1.140 and to the practice of not retesting filter units following minor mainte-nance activities.
The latter is discussed in our response to Item 3 above.
In particular, the DOP test of filters F23 and F25 indicated a removal efficiency of 98% and 93%,
respectively.
These units serve to filter the effluent from portions of the primary auxiliary building.
We do not consider the leakage by F23 to be excessive (98% vs. 99%).
Considering the overall size of the filter bank and intended service, it was decided that maintenance action was not necessary.
The design of the HVAC system serviced by F S included some inputs of extremely high humidity air.
This occasionally lead to water accumulation within the filter unit, resulting in reduced efficiencies.
This was the cause of the low filter efficiency noted in the subject inspection report.
Since that test, the system has been modified to prevent the introduction of water into the system.
It should be noted that the subject filter unit was recently tested (03/30/83) and found to have a removal efficiency of greater than 99%.
In addition, filters 1F32 and 2F32 were noted to be below the recommended guidelines for the methyl iodide adsorption test.
The concern indicated was that immediate filter replacement was not undertaken.
The methyl iodide test is performed off site, thus, the results are not immediately available.
When the results of the test were obtained, both of the units were in power operation.
1F32 and 2F32 are located inside their respective reactor containment buildings.
These units function primarily to purify the containment atmosphere during times of personnel access which, during power operation, is limited both in frequency and length.
Considering the location of these units and their intene.ed service, it was decided that immediate filter replacement was not in the best interests of the ALARA program.
The charcoal filters in the Unit 2 containment have recently been replaced (03/25/83) and the Unit 1 charcoal filters will be replaced during Unit l's upcoming outage.
Mr. J. G. Keppler May 6, 1983 8.
Two items of concern were noted regarding health physics procedure HP 12.1.
These items related to respirator fit testing and allowable respirator protection factors.
The first item noted that, contrary to our procedure, an irritant smoke test could not be used in lieu of booth fit testing for rebreathing type respirators.
The procedure has been revised to preclude the use of irritant smoke testing with rebreathing devices.
The second item identified that the allowable protection factor for supplied air respirators is 2000, per the Code of Federal Regulations, instead of 3000 as noted in the procedure.
This inconsistency was due to a typographical error during a procedural revision.
In practice, we have not excceded 2000 in the application of protection factors for supplied air respirators.
The procedure has been corrected.
11.
The concerns identified in this item relate to the general respirator fit testing program.
In particular, the practice of fit testing only the face mask versus the entire device and that respirator fit tests above a protection factor of 2000 cannot be verified.
The fit testing program is designed to verify the seal of a particular mask to an individual's face.
Obviously, this particular_ seal of the respirator protection system varies from person to person.
The program is not intended to check the operability of the system (seals, efficiency, etc.) every time a face-to-face mask seal is verified, We believe that this is not necessary since the equipment is of a proven design.
The equipment used in the protection program receives regular cleaning, inspection, and maintenance to assure that it performs as expected.
We see no reason to implement a testing program of this nature, considering that the additional information to be gained is of questionable value and that the existing program is highly effective as evidenced by the results from the whole body counting program.
The system currently used to test the face-to-face mask seal is capable of testing up to a protection factor of 2000.
Although credit is taken for protection factors greater than 2000 (with certain types of respiratory devices), we are not able to verify these high protection factors due to equipment and process limitations.
~_.
Mr. J. G. Keppler May 6, 1983 We believe that this approach is adequate as the respiratory devices which are allocated a protection factor greater than the verification capability provide a positive face mask pressure with respect to the atmospheric pressure.
Thus, any leakage past the face-to-face mask seal is in the outward direction.
Presently, we intend to replace the existing respiratory fit testing equipment with state-of-the-art equipment capable of verifying the higher protection factors.
This system change is scheduled to occur in 1985.
We trust this clarifies our position regarding the concerns identified in the subject NRC IE Inspection Reports.
Very truly your,
f h
'h Vice President-Nuclear Power C. W. Fay Copy to NRC Resident Inspector