ML20236G624
| ML20236G624 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/14/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM NUDOCS 8711030161 | |
| Download: ML20236G624 (7) | |
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Duquestie Lidit (412) 643-5200 Beever Valley No. 2 Unit Project Organization Telecopy (412) 643-5200 Ext.160 S.E.G. Building P.O. Box 328 Shippingport, PA 15077 October 14, 1987 United States Nuclear Regulatory Commission
/ egion I R
631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Thomas T. Martin, Director Di' Vision of Radiation Safety and Safeguards
SUBJECT:
Beaver Valley Power Station Unit No. 2 Docket No. 50-412 Inspection Report 50-412/87-50 Response i
REFERENCE:
Letter dated September 14, 1987 (T. T. Martin to J. J. Carey)
Gentlemen:
The above referenced letter transmitted Inspection Report 50-412/87-50 covering the Beaver Valley Power Station Unit No. 2 implementation of certain TMI Action Plan Requirements (NUREG 0737).
The letter requested Duquesne Light Company (DLC) to review some improvement and unresolved items discussed in the report and to respond on actions planned or taken in regard to these items.
The attachment to this letter provides DLC's response to these items.
i DUQUESNE LIGHT COMPANY BY J. JMarey v'
Sr. Vice President Attachment Mr. P. Tam, Project Manager (v/a) cc:
Mr. J. Beall, NRC Sr. Resident Inspector (w/a)
INP0 Records Center (w/a)
NRC Document Control Desk (w/a) 8711030161h[0 12 PDR ADOCK ppg l'(I O
te e, t.
ATTACHMENT l
Response to Inspection Report 50-412/87-50 i
Inspection Report 50-412/87-50 listed ahree (3) areas which vere considered to require inspector follow-up, and two (2) unresolved items. These items from the Inspection Report are listed here, followed by the Duquesne Light Company response.
1.
Pass Sampling and Analysis Items for Improvement (NUREG 0737, Item II.B.3)
The report states, in part:
The licensee indicated the following matters vill be reviewed and j
clarification / improvements vill be considered, as appropriate:
(50-l 412/87-50-01) l (A)
The procedures for performance of Reactor Coolant and Containment Atmosphere Sampling Operations have yet to be finalized and implemented, including revisions to the sequence for collecting samples, verification of the gas dilution factor and reference to appropriate procedures for handling high activity samples.
(B)
Document that the PASS Piping and Valving Systems are capable of functioning as designed at. applicable reactor coolant temperatures and pressures.
(C)
Perform a comparison of the routine Reactor Coolant System and PASS sample analyses results when sufficient' activity is present in reactor coolant.
(D)
Ensure that the In-Lina Boron Analyzer and Gas Chromatograph are operational.
(E)
Develop and implement a procedure for Gamma Isotopic Detector l
Calibration.
Response
(A) The PASS procedure has been rewritten and reissued using guidance provided by the NRC during the inspection. The Gas Dilution Ratio has been experimentally verified to be 160.
(B) The PASS was tested after the Reactor Coolant System reached operating temperature and pressure conditions. Automatic valves were verified to operate properly.
All temperatures, flows and pressures throughout the system, vere verified to be within design, and no valve leakage was noted. l
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(C) This is not yet complete due to insufficient activity in the Reactor Coolant. When the activity is sufficient, the comparison vill-be performed and the results made available to Mr. V. Thomas of the NRC.
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(D) The Gas Chromatograph used in the PASS to determine hydrogen concentrations has been recalibrates and new Quality control Charts have been generated.
The problem with the Gas Chromatograph experienced during the inspection has been corrected.
The in-line boron analyzer is not yet in operation. The BV-2 Instrumentation and Control Section is working to make it operational as soon as possible.
(E) A calibration procedure for the Gamma Spectroscopy System, used in measuring PASS samples, has been generated using guidance from the NRC and has been issued.
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2.
Noble Gas Effluent Monitor (NUREG 0737, Item II.F.1-1)
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The Report states,:
"The licensee indicated.the following matters will be reviewed and clarification / improvements will be considered, as appropriate:
(50-412/87-05-02)
Approve Preoperational Procedure P.O.
2.43.01, Sections N and 0, ' Radiation Monitoring System'."
Response
The referenced procedure, P.O.
2.43.01, Sections N and 0 and its associated test results, have been approved.
3.
Sampling and Analyses of Plant Effluents (NUREG 0737, Item II.F.1-2) l The reports states, in part:
l The licensee indicated the following matters vill 'be reviewed and I'
clarifier. tion / improvements vill be considered, as appropriates (50-412/87-50-03) 4 l
(A)
Determine conservative correction factors for line loss or line j
deposition for particulate and radioiodines in the High Activity /Lov Volume Flow Rate (HA/LVFR) Effluent Sampling Path.
l (B)
Evaluate need to change the Isokinetic Control Ratio for the HA/LVFR Effluent Sampling Path and document assumptions and i
resultant dose to sample collection personnel from the source l
term in the Elevated Release Duct above the Monitoring Skid; i
have approved procedures for manual operation of the Gamma i
l Spectrometer in the Unit 2 Radiochemical Laboratory and i
l Radiochemical personnel trained in those procedures.
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(C)
Provide calibration and records for counting silver zeolite cartridges on the Gamma Spectrometer.
Response
(A) Through the General Atomics Digital Radiation Monitor System User's Group, a request for Vide Range Gas Monitor (VRGM) lov flovrate, sample line loss studies has been made. A number of utilities have responded to date.
The study results are being collated to identify any similarities / correlations.
One study was performed on a system very similar to BV-2 and a correction factor is being developed for our installation based on this study.
l (B) An Engineering Memorandum (EM) No. 62433, dated July 17, 1987, has
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I been issued to address whether the Isokinetic Control Ratio for j
l the HA/LVFR Effluent Sampling Path requires any change.
Engineering is continuing to investigate this matter with the vendor, GA Technologies.
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SVEC Calculation 12241-UR(B)-441-1, dated August 17, 1987, documents the assumptions used and the total dose calculated to i
sample collection personnel from all sources, including from the l
source term in the Elevated Release Duct above the Monitoring l
Skid. The dose contribution from this duct is 0.03 Rem, assuming l
the data collection person is at the Monitoring Skid for ten (10)
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minutes.
Approved procedures for the automatic operation of the Gamma Spectrometer in the BV-2 Radiochemistry Laboratory, were added to I
the BVPS Chemistry Manual in Chapter 5.
These procedures contain l
detailed instructions and the Radiochemistry personnel have been familiarized with these procedures.
i (C) The Gamma Spectrometer in the BV-1 Radiochemistry 1.aboratory was calibrated on July 16,
- 1987, for counting silver-zeolite cartridges.
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4.
Power Sources to the PASS System The report states, in part:
I "All of the above power supplies are considered to be capable of prcviding reliable power to the segment / portion of the PASS System they feed.
- However, the inspector identified the large number of power supplies which are required to be operable in order for the PASS System to operate add to the complexity of the system.
As an example, in order to take any sample, all of the five (5) power feeders must provide power to a position of the system - a single failure in any of tne feeders disables the entire PASS sampling capability.
DLCo committed to review their Station Operating Procedures in order to assure that a power feeder failure can be easily detected / traced and overcome to permit PASS sampling within the three (3) hour PASS System sampling time design requirement. This matter is considered unresolved (50-412/87-50-04)."
Response
The applicable BV-2 Operating Manual (OH) Chapters, Chapter 14A,
" Reactor Plant Sample System" and Chapter 14C, " Post-Accident Sampling System," describe the specific power sources for the various components involved in the PASS function.
This information is contained in Section 3 of the chapters in the " Power Supply and Control Switch List." The format is standard for each BV-2 OM Chapter and the operators are thoroughly familiar with this format.
Recovery from loss of power source conditions is adequately addressed in the BV-2 OM vhen automatic transfer to an alternate source does not occur or is not available.
Appropriate alarms and computer points are available in the Control Room.
The use of two position indication lights at the control switch (es) for various PASS valves also provides a simple method of verifying power source availability.
Lack of illumination of both position indicating lights of these normally energized circuits is a sign of possible power loss. Operator response is expected to be timely so that the PASS process is not significantly delayed.
Regulatory Guide 1.97, Rev. 2 (RG 1.97) lists variables associated with the PASS function as Type E, which are defined as backup variables and as Category 3 for purposes of Design and Qualification CI Deria.
RG 1.97 requires no specific provision for instrumentation po.re" sources and no specific provision for redundancy. Regulatory Guide 1.97, Rev. 3, retains these same positions.
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+8 5.
PASS Environmental Qualification (E0)
The report states, in part:
The licensee indicated the folloihg matters will be reviewed and clarification / improvements vill be ' considered, as appropriate:
(5Q-412/87-50-05). This item is considefqd unresolvedt, Verify acceptability of PASS in-containment ' valves which are currently not considered by the licensee to require Environmental Qualification but may be required to operate under accident conditions for purposes of sample collection.
Response
.i The subject valves are Reactor Plant Sampling System (RPSS) valves, g
also utilized by the Post-Accident Sampldag System (PASS). Namely, i
Primary Coolant Hot Leg Samples 7SSR*S0V121A, B, C and D RHR Heat Exchanger Outlet Samples 2SSR*S0V123A and B
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These in-line solenoid operated valvesi vere procured under Purchase Specification 2BVS-719 as OA Category. I valves, specified to withstand BV-2 in-containment accident conditions and were supplied with all necessary documentation to qualify for Class 1E use.
Likewise, the associated field installed connecting cabling for these valves was procured under QA Category I purchase specifications for electrical cable and is qualified for Class 1E, in-containment accident condition use.
Based on the actual application of these valves and associated cabling however, BV-2 has not included this equipment in th4 BV-2 Equipment Qualification of Electrical Equipment (EO): Program.
There are no specific Equipment Qualification provisions' for PASS capability, a Category 3 variable, in Regulatory Guide 1.97, Rev. 2.
These valves do not perform any safety related function and in accordance with the current BVPS-2 E0 position are not within the scope of 10CFR Part 50.49 (E0 Rule).
In accordance with the Regulatory Requirements of NUREG 0737, Item II.B.3 and RG 1.97, these valves are of high quality commercial grade and are selected to withstand the specified sqrvice environment.
All of the above is consistent with the BV-K FSAR Sections 9.3.2.3.1, 9.3.2.3.2 and 9.3.2.3.3 and the BV-2 RG 1.97 position in the BV-2 FSAR, Table 1.8-1.
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