ML20205L125

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Forwards Response to 860303 Request for Addl Info Re Util 851031 Request for Revised Safety Evaluation Concerning NUREG-0737,Item II.B.3, Post-Accident Sampling
ML20205L125
Person / Time
Site: Calvert Cliffs  
Issue date: 04/01/1986
From: Tiernan J
BALTIMORE GAS & ELECTRIC CO.
To: Thadani A
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM NUDOCS 8604030184
Download: ML20205L125 (8)


Text

,

BALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TBERNAN Vice PntslOENT -

NUCLEAR ENEROY April 1,1986 U. S. Nuclear Regulatory Commission Offi:e of Nuclear Reactor Regulation Washington, D. C. 20555 ATTENTION:

Mr. Ashok C. Thadani. Director PWR Project Directorate #8 Division of PWR Licensing-B

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318

- NUREG-0737, item II.B.3, Post Accident Sampling l

REFERENCES:

(a)

Letter from Mr. A. E. Lundvall, Jr., to Mr. A. C. Thadani, dated October 31,1985, same subject (b)

Conference call between NRC Staff and BG&E Staff on February 25, 1986, concerning Post Accident Sampling at Calvert Cliffs (c)

Telecopy from Mr. D.

H. Jaffe,. to M r.

M. T. Finley, on March 3,1986, Request for AdditionalInformation Gentlemen:

The Baltimore Gas and Electric Company transmitted a request for a revised NRC safety evaluation concerning post accident sampling in Reference (a).

Reference (b) was convened to permit initial discussions concerning NRC Staf f review of Reference (a). Reference (c) forwarded a series of questions and concerns for which the NRC Staff has requested additional information. The attachments to this letter forward our response to Reference (c).

0604030184 860401 PDR ADOCK 05000317 jg p

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Mr.*Ashok C. Thadani

-April 1,1986 Page 2 Should you have any further questions regarding these matters, we would be pleased to discuss them with you.

Very truly yours, 3AT/LES/ dim Attachments (2) cc:

D. A. Brune, Esquire

3. E. Silberg, Esquire D. H. 3affe, NRC T. Foley, NRC
3. White, NRC

Mr. Ashok C. Thadani April 1,1986 Page 3 s

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ATTACHMENTI ITEM NO.

NRC REQUEST

SUMMARY

BGWkE RESPONSE

... it continues to be our position that the All non-manually operated control valves needed to 1.

modified PASS be capable of operating dur-obtain a sample following a loss of offsite power receive ing a loss of offsite power. The licensee DC power to the rotenoids which energize to direct shall commit to provide that capability."

instrument. air to oys rate the valves.

The normal instrument air supply to these valves is backed up by safety-related and seismic pressurized air receivers and by the saltwater air system, a safety-related air system with two air compresso s, each powered from a Class IE emergency bus. Therefore, a sample can be obtained following a loss of offsite power, if necessary. Regarding sample analysis, the mobile laboratory onsite can be powered by either of two commercial grade, gasoline powered, electric generators. The fuel tanks provided for these generators is sized for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run time. Due to instrument warm up times, the coolant hydrogen analysis is not available until four hours after i

the mcbile laboratory is activated.

For reasons delineated in Reference (b), it continues to be our position that PASS need not be operable following a loss of offsite power.

2.

" Describe the methods used in analysis of A slightly modified version of the ASTM D3082 is used boron concentration."

for boron analysis.

The method basically involves complete ionization of boric acid with Manitol followed I

by pH titration with standardized sodium hydroxide solution.

3.

"Will the valves not accessible after an The only inaccessible valves in the modified PASS are the accident and needed for taking post-remotely-operated control valves. In addition, see the accident samples operate during a loss of respanse to Item 1 above.

offsite power event? It is our position that 4

this capability is provided."

ATTACHMENT 1 ITEM Nb.

NRC REQUEST

SUMMARY

BG&E RESPONSE 4.

"Does the licensee intend to measure No.

If the hydrogen inventory is lost, the oxygen oxygen when the concentration of chloride concent.ation can be calculated by one of two methods, exceeds 15 ppm? This capability should be as follows:

provided if less than 10 cc of hydrogen per kg of water is present."

a. If RCS is partially depressurized, the final oxygen concentration in the RCS would be limited by the oxygen concentration in the refueling water tank.

The limiting concentration would be approximately 6 ppm; however, it would vary with RWT temperature; or

b. If the RCS is fully depressurized the oxygen concentration could be calculated using containment pressure and the law of partial pressures.

5.

"Will the equipment used for analysing grab The proposed Post Accident Sampling system equipment samples be able to provide at least one is currently used for routine analysis. Adequate equip-sample per day for seven days following the ment exists to ensure this capability.

beginning of the accident and at least one sample per week thereafter?

This capability should be provided."

6.

"How can the accuracy and linearity of In order to permit analysis of low levels of boron, the boron concentration be determined in the matrix boric acid concentration was varied.

matrix containing a constant amount (2000 ppm) of boric acid?"

ATTACHMENT 1 ITEM NO.

NRC REQUEST

SUMMARY

BG&E RESPONSE 4.

"Does the licensee intend to measure No.

If the hydrogen inventory is lost, the oxygen oxygen when the concentration of chloride concentration can be calculated by one of two methods, exceeds.15 ppm? This capability should be as follows:

provided if less than 10 cc of hydrogen per kg of water is present."

a. If RCS is partially depressurized, the final oxygen concentration in the RCS would be limited by the oxygen concentration in the refueling water tank.

The limiting concentration would be approximately 6 ppm; however, it would vary with RWT temperature; or

b. If the RCS is fully depressurized the oxygen concentration could be calculated using containment pressure and the law of partlat pressures.

5.

"Will the equipment used for analyzing grab The proposed Post Accident Sampling system equipment samples be able to provide at least one is currently used for routine analysis. Adequate equip-sample per day for seven days following the ment exists to ensure this capability.

beginning of the accident and at least one sample per week thereafter?

This capability should be provided."

6.

"How can the accuracy and linearity of In order to permit analysis of low levels of boron, the boron concentration be determined in the matrix boric acid concentration was varied.

matrix containing a constant amount' (2000 ppm) of boric acid?"

ATTACHMENT 1 ITEM NO.

NRC REQUEST

SUMMARY

BG&E RESPONSE 7.

"Although NUREG-0737 does not specif-Over a pH range of four to ten, ferrous alloys exhibit a ically request pH measurement, this very low corrosion rate (see Attachment 2).* Due to the measurement is recommended when a crisodium phosphate buffer used, the RCS has been significant primary coolant corrosion calculated to' not exceed these levels. Therefore, pH.

potential is expected. This condition would measurement is unnecessary. To require such an analysis occur when the primary coolant is acidic would only cause unnecessary radiation exposure for post (pH

< 7) since at 925 ppm trisodium accident sample analysis.

phosphate, the pH will drop below seven at approximately 2300 ppm of boron concen-tration, justify why pH should not be measured when boron concentration exceeds this value."

8.

"Do the lines used for taking containment Heat tracing is not installed on the containment atmosphere gas samples possess heat atmosphere sample lines. The containment atmosphere tracing in order to prevent iodine samples are analyzed for hydrogen and noble gas activity plateout? If not, what methods are used for using a spectrum analyzer. The purpose of this analysis is preventing iodine plateout?"

to provide an indication of the extent of core damage.

Iodine measurement is unnecessary. Iodine plateout is therefore not a consideration. This design was previously reviewed and approved by NRC, and has not been modified.

  • Attachment 2 comes from " Corrosion and Corrosion Control," by H. H. Uhlig, second edition.

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