ML20073P303
| ML20073P303 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/15/1983 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM TAC-44421, NUDOCS 8304250114 | |
| Download: ML20073P303 (6) | |
Text
,I
}Vg
'Af Telephone (412) 393-6000 Nuclear Division P.O. Box 4 Shippingport, PA 15077-0004 April 15, 1983 Director of Nuclear Reactor Regulation ynited States Nuclear Regulatory Commission
/At tn:
Mr. Steven A. Varga, Chief Operating Reactors Branch No.1 Division of Licensing Washington, DC 2055 Leference: Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 NUREC-0737 Request for Additional Information on the Post Accident Sampling System (Item II.B.3)
Centlemen:
Attached is our response to your request, dated March 7, 1983, for additional information on our Post Accident Sampling System (PASS).
Your draf t safety evaluation report (SER) has been reviewed by members of my staf f and it has been identified that some of the information presented in this draf t SER was not included in our submittal of August 31, 1982 which provided information to the staff for their post-implementation review of our PASS. Your letter of March 7 stated that our PASS meets eight of the eleven criteria in Item II.B.3.
The attachment to this letter provides the additional information being requested of the remaining three c rite ria. Gur review has revealed that six of the remaining eight criteria contained information different from that provided in our August 31 sub-mittal and we have included in the attachment corrections to the draf t SER.
Should you have any questions regarding this submittal, please con-tact members of my staf f for prompt resolution.
Sin er ly,
. J. Carey Vice President, Nuclear Attachment cc:
Mr. W. h. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission
[
c/o Document Management Branch Washington, DC 20555 8304250114 830415 PDR ADOCK 05000334 P
DUQUESNE LIGHT COMPANY BIcvsr V llcy Power Station, Unit No.1 l
Post Accident Sampling System Response to NRC letter dated March 7,1983 Attachment Criterion (1)
The draft SER states: "The PASS electrical power supply is not load shed upon loss of offsite power. However, a backup diesel generator supply is available".
The information provided in our August 31 response stated:
With regard to having provisions for sampling during a loss of offsite power, this provision is not a design require-ment and as such was not considered in the design of the PASS.
Additionally, the station laboratory counting room originally was not designed to have an alternate backup power source.
Sample collection and analysis will not be possible in the event of a loss of off-site power. However, the ERF will have a back-up power supply in the form of a diesel genera-tor.
As such the laboratory and counting room in the ERF would be operable in the event of a loss of off-site power.
Criterion (2)
The draft SER states:
"The PASS is capable of analyzing, by re-motely controlled in-line monitors, noble gases, iodines and cesiums, nonvolatile isotopes, boron, chloride, pH, and dissolved gases in the primary coolant. Hydrogen and gamma spectrum in the containment at-mosphere can also be analyzed by in-line monitors" The PASS does not have in-line monitors capable of analyzing noble gases, iodines and cesiums, non-volatile isotopes, hydrogen concentration or gamma spectrum in the containment atmosphere. The hydrogen concentration in the containment atmosphere is determined utilyzing equipment installed as a result of NUREG-0737 item II.F.1.6 as stated in our August 31 sub-mittal. The remaining above analyses are performed in the chemistry lab-oratory on a sample which may be obtained from the PASS. Our submittal of August 31 stated that isotopic analysis of grab samples is performed, in either the chemistry laboratory in the plant or the emergency response facility, utilizing a Germanium detector connected to a computer based multichannel analyzer. Additionally, installation of the boron and chloride analyzers has not been completed, however, this has been identi-fied in your confirmatory Order dated March 14, 1983.
Some difficulties have been experienced in attempting to complete this installation, but it remains our intent to place these in-line analyzers in service at our first opportunity.
Request for Additional Information Provide a core damage estimate procedure l
f' s
Pso heid;nt Sa:pling Syatsa Rrptd33 to NRC 19ttsr dat:d March 7,1983 Page 2
' Response l
i Our submittal of August 31 stated we had p;epared procedures to f
relate specific nuclides to core damage and that the Rogovin Report
,was used as a reference in their develnpment. The adequacy of this procedure is currently being re-evaluated based on utility inquiries and research to determine what level of detail is needed in the
>J-procedure to determine varying. degrees of core damage. We are part-icipating in the Westinghouse Owner's Group (WOG) procedures subcom-mittee, which has been coordinating activities with members of the g
NRC staff, for the development of an acceptable approach for assess-
/
' ng co're damage. Redent correspondence from the owner's group to i
/'
',N\\
the NRC, OG-95, has documented to the NRC how the WOG is going to 7
- 'I' continue working with' the NRC staff to resolve the procedure needs for NUREG-0737 item II.B.3.
We expect to develop improved plant specific procedures as a result of this owner's group activity.
Criterion (3)
The draf t SER states:
"The PASS provides the ability to obtain samples from each reactor coolant hot leg, each reactor coolant cold leg, the RHR system, the containment sump, and the containment atmos-phere without using an isolated auxiliary system."
Some clarification of our sampling ability is required.
In our August 31 submittal.in response to criterion 11, we stated that the normal PASS sample point for the reactor coolant system is on the B loop hot leg between the reactor vessel and the reactor coolant isolation valve. We also stated that sample points from the other loops and the cold legs may be valved into service if radiation fields at the normal sample panel permit. Operating manual figures 12-1, 14-1 and 14-4 were provided to permit review of our sampling capability.
The design of the PASS is to obtain a sample from the B loop hot leg, the containment sump and the containment atmosphere. Other samples may be collected in the PASS if radiation levels permit entry to the previously existing sample panel for the purpose of manually valving in other sample points. By reviewing operating manual figure OM 14-1, it is possible to collect a sample in the PASS from any hot leg or from the residual heat removal system heat exchanger inlet or outlet by manually valving in that sample location at the existing sample panel.
A cold leg sample cannot be collected in the PASS. Our submittal of August 31, which stated a sample from the cold legs could be collected, was based on collecting this sample at the existing sample panel, not in the PASS.
Criterion (4)
Your evaluation of our submittal as documented in the draf t SER is correct.
L
1.
Prat AccidInt S:cpling Systcm Rocponaa t2 NRC lsttsr dated March 7.11983 Page 3 Criterion (5)
The draf t SER states:
"An in-line ion chromatograph is provided which meets the 96-hour chloride limit for a fresh water plant."
Our submittal of August 31 states that the PASS is designed with an in-line chloride analyzer. Our design does not include an in-line ion chromatograph.
s Criterion (6)
Your evaluation of our submittal as documented in the draf t SER is correct.
Criterion (7)
The. draft SER states: " Boron analysis of the reactor coolant will be performed by in-line ion chromatograph with a measurement capability from 0 ppm to 6,000 ppm under accident conditions.
Prior to time when the.in-line ion chromatograph is operational, boron can also be analyzed using' diluted reactor coolant sample" Our submittal of August 31 states that the PASS is designed with an in-line boron analyzer. Our design does.not include an in-line ion chromatograph.
Criterion (8)
The draft SER' states:
"An in-line chemical analysis panel is pro-vided for_. rcactor coolant, pH, oxygen and hydrogen concentrations, as well as containment hydrogen concentrations".
As stated previously and in our August 31 submittal, the containment hydrogen concentration, is determined utilizing a hydrogen analyzer installed in response = to NUREG-0727 item II.F.1.6, Containment Hydrogen Monitor. The hydrogen analyzer designed for the PASS measures the amount of dissolved hydrogen after it has been stripped from a liquid sample.
The collection and measuring of' dissolved hydrogen is included in our August 31 submittal in response to item 2C.
Criterion (9)
The draft SER states: "The PASS can perform radioisotope analysis at the levels corresponding to the source term given in Regulatory Guide 1.4".
Our submittal of August 31 stated that a radioisotope analysis is performed in the chemistry laboratory in the station or in the ERF lab-o rato ry.
The sample to be analyzed can be collected at the PASS.
C T Prot Accidsst. Sarpling Systes
. R; ponas to NRC lattsr d tsd March 7,1983 Page-4
~
e Criterion (10)'
Request'for additional'information
- Provide information demonstrating applicability of procedures and instrumentation in the' post accident water chemistry and radiation; environment, and retraining of operators on semi-annual basis.
Response
Procedures will be written to demonstrate instrumentation accur-acies. The standard ' test matrix will be prepared and each instru-a ment in the PASS will be tested in the laboratory. This will demonstrate instrument operability in the post accident water chemistry. Additionally, each instrument will:be tested to_ verify instrument range and sensitivity over four points of its operating range (low,' high and intermediate) using laboratory standards.
- This will be accomplished during our third refueling outage, pre-sently scheduled for June 1983. _ With regard to' radiation env-ironment, the instruments were purchased with a certification that they_will function in a radiation field exceeding 10 E~4 RADS / gram.
~
of reactor coolant.
We have reviewed _the guidelines provided in attachment 2 of your letter, report on the evaluation of Sentry Equipment Corporation and General Electric Company analytical chemical procedures for post accident analysis, and have concluded that our test methods described above are consistent with that report.
'The draf t SER states that the PASS operators should receive initial and = refresher training in post accident sampling, analysis and tran-sport every six months.
We will provide this training to the PASS operators at this frequency.
The following instruments will be calibrated or tested on a six month -
frequency to ensure their availability; boron, chloride, and pH analyzer. The dissolved hydrogen and dissolved oxygen analyzers will be calibrated on an 18 month frequency.
Criterion (11)
Request for additional information Provide information on heat tracing of containment atmosphere sample line to limit iodine plateout.
E
y Post Accidsnt Sr.mpling Syetez Response to NRC letter dated March 7, 1983.
Page 5
Response
f'
. To prevent the plate out of iodine, the containment atmosphere sample line is heat. traced from the containment isolation valve to the PASS and on sample lines 'inside the PASS.
The heat' tracing operates'in-the range of 150*F to 160'F.
An alarm is provided to indicate failure of the heat tracing to operate.
s
- .n