ML20236L020

Forwards Request for Addl Info & Clarification Re 870413 Request for Changes in Tech Specs Related to Monitors for Waste Gas Decay Tank.Response Expected within 45 Days of Ltr Receipt

ML20236L020
Person / Time
Site:	Beaver Valley
Issue date:	11/04/1987
From:	Tam P Office of Nuclear Reactor Regulation
To:	Sieber J DUQUESNE LIGHT CO.
References
TAC-65106, NUDOCS 8711100065
Download: ML20236L020 (4)

Text

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'Novemiser 4,.1987: , ,

Docket'No. 50 f334 '

Mr. J.-D. Sieber, Vice President' ,

, Nuclear Operatio,,

Duquesne Light:Companyc Post: Office: Box'41' LShippingport, PA 15077 . 4

SUBJECT:

BEAVER' VALLEY UNIT 1 --' WASTE-GAS DECAY TANK MONITOR:-

c (TAC #65106)-

We'have. reviewed your.submittalfdated April:13, 1987, requesting chan'ges-in '

s the Technical Specifications regarding; monitors;for the waste gas decay, tank.

The proposed changes would delete the radiation monitor'and the sampler flow rate. measuring device from..the Technical Specifications, and allow the physical removal of.these monitors from the plant.' In orderLfor us to find this request acceptable,'we will need clarification from you onithe: submittal'and provide additional information to justify the proposed changes. 4Please~

respondtotheenclosedlquestionsz within 45. days'of receipt of?this letter.

The reporting and/or recordkeeping requirements' cont'ained in'this letter ..

affect fewer than ten respondents; therefore,'OMB clearance is not required- '

under P.L.96-511.

S'incerely,'

/s/-

Peter S..~ Tam,~' Project Manager Project: Directorate'I-4' Division of Rea'ctor Projects.I/II.-

~0ffice of Nuclear' Reactor-Regulation:

Enclosure:

As stated cc: ,

See next page DISTRIBUTION DecketJUe4%

'NRC & Local PDRs PDI-4 Reading S. Varg'a-B. Boger S. Norris P. Tam

'0GC-Bethesda E. Jordan J. Partlow 8711100065 s?1104 '

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ACRS (10) P PDR Grey Files E. Branagan-( .

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l Mr. J. D, Sieber Beaver Valley 1 Power Station Duquesne Light Company j

I cc:

Mr. W. S. Lacey Pennsylvania Power Company Station Superintendent James R. Edgerly: :4i Duquesne Light Company Post Office Box 891 Beaver Valley Power Station New Castle, Pennsylvania '16103

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Post Office Box 4 Shippingport, Pennsylvania 15007 .

Mr. W. F. Camichael, Connissioner State of West Virginia Department . .j Mr. Kenneth Grada, Manager R of Labor Safety and Licensing 1800 Washington Street, East Duquesne Light Compary Charleston, West Virginia 75300.

Post Office Box 4 shippingport, Pennsylvania 15077 David K. Heydinger, M.D.

State Director of Health Mr. John A. Levin State Department of Health' Public Utility Comnission 1800 Washington Street, East Post Office Box 3265 Charleston, West Virginia 25305 Harrisburg, Pennsylvania 17120 Gerald Charnoff, Esquire Regional Administrator, Region 1 U.S. Nuclear Regulatory Connission Jay E. Silberg Esquire 631 Park Avereue i

Shaw, Pittman, Potts and Trowbridge i 2300 N Street, N.W. King of Prussia, Pennsylvania 19406 l Washington, DC 20037 Mr. R. Janati Charles E. Thomas. Esquire Bureau of Radiation Protection Pennys1vania Department of ~

Thomas and Thomas 1 212 Locust Street . Environmental Resources l Box 999 P.O. Box 2063 Harrisburg, Pennsylvania 17108 Harrisburg, Pennsylvania 17120 John D. Burrows, P.E.

Marvin Fein o Utility Counsel Director of Utilities  !

State of Ohio City of Pittsburgh Public Utilities Comnit,sion >

313 City-County Building 180 East Broad Street Pittsburg, Pennsylvania 15219 Columbus, Ohio 43266-0573 Resident Inspector Pennsylvania Office of Consumer U.S. Nuclear Regulatory Comnission Advocate Post Office Box 298 ATTN: Michael Bardee Shippingport, Pennsylvania 15077 1425 Strawberry Square Harrisburg, Pennsylvania 17120 e

1 BEAVER VALLEY UNIT 1 TECHNICAL SPECIFICATION CHANGE REGARDING WASTE  !

GAS DECAY TANK MONITOR: REQUEST FOR ADDITIONAL INFORMATION

1. In Ref. 1 (Attachment B, p. 1) it is stated that an evaluation of the quantity of radioactive material in the gas surge tank leads to the conclusion that a monitor is not needed for the Waste Gas Decay Tank.

(WGDT). However, the text does net provide enough information for us to verify Duquesne Light's conclusion. Describe the relationship between the gas surge tank, the WGDT, the monitor for the WGDT, and the radioactive l' effluent release points. For example, a simple diagram (as~ opposed to the highly detailed FSAR Fig. 11.2-2) would be useful. In particular, state  !

whether there are any radiation monitors that are downstream of the WGDTs .;

and whether these monitors provide alarm and automatic termination of l releases from the WGDTs. l

2. In Ref.1 (Attachment B, p. 2, first paragraph), it is stated that:

"This action will ensure the accident analysis value will not be exceeded and in NUREG-0472, Revision 2 Tables 3.3-13 and 4.3-13 do not list a radiation monitor or a sampler flow rate measuring device on the waste gas holdup system."

However, NUREG-0472, Revision 3 (p. 3/4 3-79) and Revision 5 (p. 3/4 3-78) list the following instruments for the Waste Gas Holdup System: noble gas activity monitor; iodine sampler; particulate sampler; effluent system flow rate measuring device; sampler flow rate measuring device; hydrogen monitor; and in some cases an oxygen monitor. In summary, the staff's position is that the preceding instruments are required for the Waste Gas Holdup System, and that Duquesne Light will need to clarify its request and provide supplemental information to justify the proposed changes.

3. In Ref. 1 (Attachment B, p. 2, first paragraph), Duquesne Light stated that:

"With RM-GW-101 in operation, no additional information and no increase in the level of safety is provided, therefore, deleting this monitor from the technical specifications will not affect the proba-bility of occurrence or the consequences of an accident previously evaluated."

The rationale that the dose criteria of 10 CFR 100 are met without the monitors is not a sufficient reason for removing the monitors. Other regulations such as 10 CFR 20, Appendix I of 10 CFR 50, and General Design Criteria 60 and 64 of Appendix A of 10 CFR 50 are also applicable, but ere not addressed in the submittal.

a. Provide the basis for Duquesne Light's assertion that "no additional information and no increase in the level of safety is provided ..."

by RM-GW-101.

a D

b. Describe' the reasons (i.e. , benefits) for removing the radiation <

monitor and the sampler flow rate measuring device,' as opposed to retaining these instruments. Presumably there was a reason for initially installing these instruments. Has additional equipment, or-changes in procedures made these instruments obsolete or unnecessary?

What alternatives have been considered?

c. Address all applicable regulations in the revised rationale.

4. In proposed TS 4.11.2.5.1 it is stated that:

"The quantity of radioactive material contained in each gas storage .'

tank shall be determined to be within the above limit at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when radioactive materials are being added to the tank.

Performance of this surveillance is required when the gross concen-tration of the primary coolant is > 100 pCi/ml."

a .- Briefly describe how the quantity shall be determined.

l b. State why it is not necessary to determine the quantity of radioac -

! tive material.in the WGDTs prior to releasing this activity from the WGOTs.

c. Provide the basis for using a value of 100 microcuries/ml, rather than some other value, for determining when surveillance will be I required,

d. Further define the quantity 100 microcuries/ml in terms of activity-of a group (s) of radionuclides with half-lives greater than a speci-fied value.  :

I

5. In Ref. 1 (Attachment B, p. 1, last paragraph), it is stated that: "We j have calculated a Xe-133 maximum expected concentration of 375 y

microcuries/ml." Identify the component or system in which the preceding l concentration is expected. j l

References

1. Letter from J. D. Sieber, Duquesne Light, to USNRC, dated April 13, 1987.

1 Principal Contributor  !

l E. Branagan, reviewer i l,

1 l

l 1

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