ML20080Q658

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Forwards Response to Request for Addl Justification for Proposed Completion Schedule Re NUREG-0737,Item II.B.3, Post-Accident Sampling Capability. Site Verification Tests Will Be Completed by 840501
ML20080Q658
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 02/20/1984
From: Gucwa L
GEORGIA POWER CO.
To: Stolz J
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM NED-84-077, NED-84-77, TAC-53478, TAC-53479, NUDOCS 8402240145
Download: ML20080Q658 (5)


Text

Georgia Power Company 333 P;edmont Avenue Attanta Georgia 30308 Telephone 404 526-6526 Mailing Address:

Post office Box 4545 Atlanta. Georgia 30302 h

Georgia Power L T. Guewa trv southem electnc system Manager Nuclear Engineenrig and chief Nuclear Engineer NED-84-077 February 20, 1984 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Ccunission Washington, D. C.

20555 NRC DOCITTS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HA'ICH NUCLEAR l'IANT UNITS 1, 2 NUREX;-0737 ITEM II.B.3, POST-ACCIDENI' SAMPLING CAPABILITY Gentimen:

Our subnittal dated January 26, 1984 provided information demonstrating the extent of cmpliance of Plant Hatch with the criteria of the subject ite. A cmpletion schedule was proposed for the criteria which were not yet satisfied.

Mr. George Rivenbark, Hatch Licensing Project Manager, has requested additional justification for the proposed cmpletion schedule.

In response to that request, Enclosure 1 is subnitted.

Please contact this office if there are any questions.

Very truly yours,

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L. T. Gucwa JH/m Enclosure xc: J. T. Beckhm, Jr.

H. C. Nix, Jr.

P. D. Rice J. P. O'Reilly (NRC-Region II)

Senior Resident Inspector 1

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I.

INIPODUCTION In our letter of January 26, 1984 we indicated four items reained outstanding concerning full cmpletion of NUREG-0737 Its II.B.3.

%ese itms are discussed further below. Each of these four itms can be characterized as relatively current probles.

Initial comitments were based on the assumption operability of the Post-Accident Saple Systs (PASS) was all that was needed to satisfy the NUREG-0737 comitment.

Other utility experience, site inspections, and the proposed technical specifications and formal progra referenced by your Generic Letter 83-36 indicated a good deal more would be expected in the administrative aspects of this systs. 'Iwo of the outstanding itms relate specifically to these administrative aspects.

The other two items concern questions on probles that did not fully develop until Dec eber, 1983.

II.

SCHEDULE JUSTIFICATION A.

PROPOSED SCHEDUIE - SHIPPING CASK Criterion 8 of Item II.B.3 requires the capability to obtain and analyze (not necessarily on-site) grab saples as a backup if in-line monitoring is used for any analysis.

Plant Hatch is in partial empliance with this criterion in that the PASS provides the capability to obtain grab smples to back up its in-line monitors and arrangenents have been made for analysis at an off-site facility.

The shipping cask which is to be used for transportation of the saples, however, will not be available until May 1, 1984.

This date was proposed by GPC for completion of Criterion 8.

JUSTIFICATION

%e cask in question was developed for the Pooled Inventory Managenent (PIM) progra for use by numerous BWR utilities.

GPC has therefore had minimal control over the schedule for design, construction, licensing, and delivery of the casks to the PIM facility.

At the time the December 1,1983 cmpletion date for Item II.B.3 was proposed by GPC, the PIM casks were scheduled for delivery in late 1983.

As late as Novenber 21, 1983, GPC was informed that this schedule would be met.

We discovered on January 24, 1984, however, that delivery had not been made and had been re-scheduled for May 1,1984.. - - -

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t Had shipping cask availability been the only incmplete aspect of

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Its II.B.3, it is expected that alternate shipping arrangements could have been made. Furthermore, the probability of an accident

- requiring use of the PASS is extreely low, grab smple analysis would only be used as a backup to in-line monitoring, and limited grab smple analysis capability would be available on-site.

B.

PROPOSED SCHEDULE - VALIDATION 'IESTING Criterion 10 of Its II.B.3. specifies that the accuracy range, and 4

j sensitivity -of the required isotopic and chemical analyses be adequate to provide pertinent data on the condition of the reactor

- coolant.

Clarification 10 of the August 24, 1982 NRC letter provided specific accuracies - which were to be achieved while performing the analyses in the presence of certain interferences (NRC test matrix).

Plant Hatch partially satisfies Criterion 10 in that factory tests, performed using the NRC test matrix, resulted in accuracies which substantially emplied with the recomendations of Clarification 10.

However, a full systs integrated test was not possible until site installation and initial operability were cepleted. To assure that the caponents and integrated syste perform as designed a series of verification /

validation tests are being carried out. GPC proposed May 1, 1984 as the completion date for this testing.

~

JUSTIFICATION

%e integrated systs tests could not be initiated until all system functions were established.

Reliable pressure control and flow throughout the system were not available until the latter part of January 1984.

Site verification tests and any necessary syste refinments are in progress and will be empleted by May 1, o

.1984.

C.

PROPOSED SCHEDULE - AININISTRATIVE PROGRAM Clarification 10 of the August 24, 1982 NRC letter specifies that equipnent testing, procedures :for sapling and analysis, and personnel training be adequate to ensure the availability of post-accident sapling and analysis capability.

It was noted that fortheming model Technical Specifications would provide guidance on the incorporation of these provisions. % e referenced guidance was provided in Generic Letter 83-36, dated Novmeber 1, 1983.

%is letter transmitted a model Technical Specification which required an administrative progra covering personnel training, maintenance of sapling and analysis equipnent, and procedures for sampling and analysis.

GPC proposed to implement such a progra by June 1, 1984... ~.

l JUSTIFICATION Based on Generic Letter 83-36 it was apparent that a formal administrative progran would be required.

'Ihis adninistrative program needs to address surveillance, calibration, procedures training, retraining, operability criteria, staffing (i.e. who is trained), etc.

While initial training, calibration, procedural developnent, and related functions have been acceplished, the establishment of a formal ongoing progran is not yet emplete.

Technical Specification and Program developnent will be cmpleted p

by June 1, 1984.

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D.

PROPOSED SCHEDULE - HEAT TRACING criterion 11 of Item II.B.3 requires that consideration be given to various aspects of equipnent design related.to representative sampling.

Clarification 11 of the August 24, 1982 NRC letter specifically mentions heat tracing as an item to be addressed.

l Plant Hatch partially cmplies with Criterion 11 in that the PASS design includes. all of the required considerations with the exception of heat tracing on the contairunent atmosphere sample

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lines. GPC proposed to install the heat tracing by August 1,1984.

JUSTIFICATION Heat tracing was not a specific design criterion in the initial discussion of this iten. ' It was recognized that the contairunent atmosphere sanple must be respresentative for noble gases and radioiodines.

Initial engineering analyses indicated heat tracing was not. needed to assure sanple validity.

While subssjuent analyses do not clearly indicate heat tracing is either needed or l

not needed, it was decided that installation would be necessary to renove any doubt about sample validity.

Heat tracing has been

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designed and is in the procurenent process.

The current schedule calls for installation by August 1, 1984.

III. CONCLUDING S& MARY As stated in our January 26, 1984 subnittal, the PASS systen is fully functional. All esponents are operating. 'Ihe four outstanding itens discussed need to be cmpleted, however, before GPC can state that Plant Hatch is in full-cmpliance with NUREG-0737 criteria for Post-Accident Sanpliag Capability.

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