ML20082T166

Documents Plans to Resolve NRC Concerns Re NUREG-0737,Item II.B.3, Post-Accident Sampling Sys, as Discussed During 831109 Telcon W/Nrc

ML20082T166
Person / Time
Site:	Peach Bottom
Issue date:	12/12/1983
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Stolz J Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM NUDOCS 8312150191
Download: ML20082T166 (4)

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PHILADELPHIA ELECTRIC COMPANY 230! MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. DALTROS- /

utsc'in1c rnUEnon December 12, 1983 Docket Nos. 50-277 50-278 Mr. John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

SUBJECT:

Peach Bottom Atomic Power Station Post-Accident Sampling System (NUREG-0737, Item II.B.3)

Dear Mr. Stolz:

This letter was requested by the NRC staff in a telephone conversation on November 9, 1983, and describes our plans to resolve the staff's concerns pertaini.ng to the Post-Accident Sampling System (NUREG-0737, Item II.B.3). Philadelphia Electric Company's plans for meeting the criteria of NUREG-0737, Item II.B.3, were identified in a January 31, 1983, submittal (S.

L. Daltroff, PECo, to J. F. Stolz, NRC). By correspondence dated October 6, 1983, the staff accepted our proposal for meeting eight of the eleven criteria regarding Item II.B.3. The staff concluded that three criteria were not fully satisfied. A telephone conference was requested within thirty days to discuss the resolution of these issue. The unresolved issues as presented in the staff's October 6, 1983, letter and our plans for resolution as prosented during the November 9, 1983, telephone _ conference are as follows:

8312150191 831212 PDR ADOCK 05000277 P PDR O

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~Mr. John lF.I Stolz Paga 2

'I; 'NRC' Concern:

.We:findLthat the licensee. partially meets Criterion-(2) by

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t establist ing an on-site radiological and che7ical analysis -

capability. The BWR Owners Group core damage-estimate procedure,. dated. June 17, 1983, is acceptable.ns a generic procedure. -The licensee.should develop'this procedure into

one that'is' plant specific.-

PECo. Response:

LA controlled-Nuclear Generation Division' procedure (FM-19 Procedures for Estimating Core Damage During- Accident Conditions) provides for a determination of the extent of damage-on :the Peach Bottom core during accident conditions.

The procedure is based on the BWR Owners-Group core damage estimate procedure dated June 17,.1983. It is the responsibility.of'the Core Physics Coordinator to determine the extent of-damage utilizing this procedure. As requested, a copy of.the procedure is attached for your Treview.

II.. NRC Concern:

Chloride analysis is performed within the 4-day time

. requirement by the turbidimetric method which has a sensitivity of lO' ppm in a diluted sample. More sensitive analyses may be made at an off-site facility that has been

' arranged-for. An. undiluted sample can also be collected in

-a shielded cask and retained for' chloride analysis for_30

. days.- We' determined that-these provisions partially meet

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Criterion (5). The turbidimetric method is unacceptable

,- for chloride analysis because of_ interference with iodine L in'the post-accident sample. Dependence on an off-site

[_ facility for chloride analysis requires a licensed shipping j container. The licensee should' provide a chloride

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! procedure sensitive to 0.l ppm levels in.the presence of L the standard test matrix given in Criterion (10) or confirm L the availability of.a licensed shipping container and *

!, discuss arrangements for off-site analysis.

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PECo Response:

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L Jus' stated in the January 31, 1983 submittal, the turbidimetric method of chloride analysis will only be Lutilized for on-site " scoping" analyses. Contractual ,

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arrangements have been made with an off-site laboratory L (Babcock &-Wilcox, Lynchburg, VA) for more precise L

-measurements. The off-site laboratory has the capability

.of analyzing chlorides using an ion chromatograph. This f

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. 6 'I Mr.'JohnLF.1Stolz Pcga 3

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-technique'is accurate within +/- 10%.of the measured value for concentrations between.O.5'and 20.0' ppm chloride, and -

1+/-.O.05 ppm for_. concentrations below 0.5 ppm, and is .

.therefore in'conformance with the NRC's recommendations (J.

F.1Stolz, NRC,,to_E. G. Bauer, PECo,. August 24,-1982).

Two licensed shipping casks are presently being procured by i the Pooled Inventory Management System -(PIMS) program for .

-use by the participating utilities. The casks are expected to be delivered to:thelPIMS facility in Memphis, Tennessee,

-by February 1984 Land will be available for use to transport samples to the B&W' laboratory. Procedures have been

' generated for the acquisition of the cask in an emergency sand' shipping samples to the B&W laboratory.

III.- :NRC Concern:

We find that the licensee partically meets Criterion (10).

The licensee should provide additional information

-consistent with the guidelines in our letter dated August

-24,:1981,- on operator training to ensure proficient operation and_ performance of analyses for post-accident sampling. A minimum frequency for the above efforts is considered to be every'six months if indicated by testing.

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PECo Response:

L. By correspondence dated August 24, 1981, the staff

' oupplemented the criteria provided in NUREG-0737, Item L II.B.3. Clarifi. cation to Criterion (10) addressed the j; training' of personnel-in post-accident sampling, analysis, and transport.' A training frequency of every six months was recommended. The number of personnel required to be

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. trained in the use of this system was not identified in the staff's clarification.

-Our. response'in the January 31, 1983, letter went beyond the--staff's clarification, in that we committed to having 4 at least five members of the on-site organization trained in the sampling, analysis, and transport of samples.

Considering'the number of personnel committed to this effort, variation in work schedules, and other demands of L the job,~it would be impossible to assemble at least five personnel-for a common training session. Therefore, at least two training sessions every six months (four per

-year)-.would'be necessary to accommodate at least five personnel. The operation of the PASS is performed by the techniciansLin the-Health Physics and Chemistry group.

.Considering the growth of training requirements applicable to plant-technicians, we believe at least four training l

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Mr.-John F.-Stolz Paga 4 sessions a year in the performance of one activity to be an unnecessary burden.

As discussed during the November 9, 1983, telephone conference, we are modifying our commitment as follows: A training session will'be conducted approximately every six months in post-accident sampling, analysis, and transport. i At least five' members of the on-site organization shall receive the training at least annually (at least every 1 other training session). This proposal would permit the training of at least five personnel utilizing two sessions a year-(one every six months),.while at the same time ensuring that at least some of the five have received the training within the past six months. It should be noted that additional on-the-job experience in the use of the l sampling and analytical equipment is acquired during the i periodic emergency drills and. practice exercises. The l

. staff indicated, during the telephone conference, that they would give this proposal serious' consideration.

1 Should you have additional questions regarding this matter, please do not hesitate to contact us.

Very truly yours, y u -~

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Attachment cc: A. R. Blough, Site Inspector l

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