ML20133B813
| ML20133B813 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/16/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM NUDOCS 8508060265 | |
| Download: ML20133B813 (5) | |
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PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. D ALTROFF
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February 16, 1984 Docket Nos. 50-277 50-278 Dr. Thomas E. Murley Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
SUBJECT:
Feach Bottom Atomic Power Station NRC Inspection of NUREG-0737 Items
Dear Dr. Murley:
This letter provides information requested by the NRC inspection team during an exit interview on December 2, 1983, at the Feach Bottom Atomic Power Station and the subsequent telephone conversations between J. R. White, NRC, and W. C.
Birely, D. R. Helwig, A. E. Hilsmeier, and J. Ballantine of PECo on December 8-9, 1983.
The information deals with the NRC inspection of modifications implemented to meet several NUREG-0737 requirements (TMI Action Plan Requirements) and supplements the information provided by correspondence dated December 30, 1983 (S. L. Daltrof f, PECo, to T. E. Murley, NRC).
Additionally, a revision in our plans for writing procedures for these NUREG-0737 systems is provided.
1.
NRC Request:
Provide a schedule for submitting a safety evaluation for the use of the Unit 1 facility as a laboratory for the analysis of post accident samples.
The safety evaluation is necessary
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-Dr. Thomas E. Murley Page 2 to assure that radioactive gas and liquid samples are able to be processed in the laboratory without the creation of an unreviewed safety question.
Response
We plan to perform an off-site dose evaluation of a worst case release from the Unit 1 laboratory.
Currently, we are obtaining the necessary input data required for the evaluation.
The results of the evaluation will be submitted on or before May 11, 1984.
2.
NRC Request:
The inspection team observed some difficulty in aligning the needles with the sample bottle when sampling reactor coolant using the Post Accident Sampling System.
The misalignment caused the needles to bend and necessitated needle replacement.
A schedule for corrective action is requested.
Response
As stated in the December 8,1983, telephone conversation, we have initiated action to acquire larger mouth sample bottles in an effort to eliminate this type of problem.
Recently, we acquired several sample bottles of this type and confirmed its application to the Peach Bottom Post Accident Sampling System (PASS) design.
Subsequently, requisition of the parts needed to modify the sample collection system and provide an adequate stock of large mouth sample bottles has been initiated.
While the delivery date for this equipment has not been confirmed by the vendor, we currently expect delivery in April 1984.
We propose an implementation date of 45 days after receipt of all necessary equipment for the PASS on both units.
In the event circumstances beyond our control delay implementation beyond October 15, 1984, we will provide a formal explanation to Region 1, along with a revised schedule.
3.
NRC Request:
Evaluate the representativeness of air samples collected from the PASS in view of long sample line lengths, low flow velocity and right-angle bends.
' analysis should be L
Dr. Thomas E. Murley Pcge 3 submitted that will substantiate that the system has the ability to provide representative samples.
Response
The inspection team expressed concern about the impact of the generally long horizontal sample line, numerous elbows, and low sample flow rate on plateout of iodine and particulates in the containment air samples.
We agreed to perform (1) an assessment regarding the representativeness of the sample, (2) an evaluation of the acceptability of the purge times for the gas sample, and (3) a demonstration test comparing PASS sample measurements with those of the non-emergency drywell radiation monitoring sample system (shorter sample line).
NUREG-0737, Item II.B.3, requires the capability to obtain and analyze containment atmosphere samples as an aid in the assessment of the degree of core damage.
The generic core damage estimate procedure submitted to the NRC by the BWR Owners' Group was approved by letter from J. A. Norris, NRC, to D. R. Helwig, BWROG, dated September 1, 1983 for use by BWR licensees in the development of plant specific procedures.
This procedure relies on the measurement of noble gas and hydrogen concentrations in the containment atmosphere, as well as primary coolant parameters for the assessment of core damage.
There is no known mechanism that would affect noble gas or hydrogen concentrations at the sample station in such a manner that they would not be representative of containment atmosphere conditions, after purging of the sample lines as discussed below.
Neither iodine nor particulate measurements are utilized in the core damage estimate procedure. Consequently, their measurement is not essential to meeting the requirements of NUREG-0737, Item II.B.3.
Gas sample line purge times have been established based on consideration of sample line size, length, and sample pump flow rate.
The measured sample flow rate of 0.5 cfm provides turbulent flow through the sample lines.
At this flow rate, the specified purge time of 5 minutes provides for several full volumetric changes thus assuring representative samples.
Iodine loss in the sample lines is further minimized by the use of heat tracing on the sample line to prevent condensation.
articulate measurement can only be regarded as a crude indicator of containment atmosphere conditions.
Dr. Th mns E. Murley Page 4 The results of the demonstration test were not conclusive due to the low activity levels in the containment atmosphere.
A seven-hour sample for iodine and particulates on both the Unit 3 PASS and the Unit 3 drywell radiation monitoring sample system measured no detectable levels.
At these background levels in the containment, longer sample times would also be non-conclusive.
4.
PASS Calibration and Testing Procedure Commitments In the December 30, 1983 letter previously referenced, we made a commitment to write five procedures by February 15, 1984.
The calibration procedure for the containment high-range radiation monitors has been implemented.
Three other procedures are in the process of being drafted; however, we will require another two weeks (until February 29, 1984) to refine and approve them for use.
These are the procedures associated with EP-316, analyzing an undiluted sample, and actuation of laboratory equipment.
Additionally, we wish to revise the commitment in the December 30, 1983 letter to write maintenance and calibration procedures for the PASS.
The words did not correctly reflect our intentions.
The NRC guidance in an August 24, 1982 letter (J. F. S tolz, NRC to E. G. Bauer, Jr., PECo) specifies the equipment to be calibrated or tested at a frequency which will ensure that the sampling system will be available if required.
Therefore, we propose the following program that meets the NRC guidance.
A semi-annual operability test will be performed on the PASS to ensure that the system is functional.
Maintenance or calibration of PASS components will be performed if indicated by the operability tests.
Calibrations will be performed in accordance with approved procedures, and equipment maintenance will be performed in accordance with Peach Bottom procedure A-26, Procedure for Corrective Maintenance.
It was our intention that the February 15, 1984 commitment apply to the operability test procedure, and to calibration procedures for the analytical equipment.
These procedures have been written and approved.
Additionally we will routinely calibrate at a frequency of every other refueling outage, the parameter measuring devices on the PASS (radiation, temperature, pressure, flow rate).
j.-
Dr. Thomas E. Murley Page 5 Procedures for calibrating these particular parameter measuring devices on the PASS will be written and approved' prior to calibration.of this equipment during the next refueling outage for each unit.
This program also complies with the NRC request in Inspection Report No. 83-35 and 83-33, dated February 1,-1984, to establish surveillance procedures for the PASS and associated analytical systems addressing instrument calibration and test on a scheduled frequency.
If you have have questions or require further information on this matter, please do not hesitate to contact us.
Very truly yours, l
/u cc:
'A.- R. Blough, Site Inspector t