IR 05000029/1985005

Insp Rept 50-029/85-05 on 850304-08.No Violation Noted.Major Areas Inspected:Implementation & Status of NUREG-0737 Task Actions,Including post-accident Sampling of Reactor Coolant & Containment Atmosphere & Effluent Monitoring

ML20127M061
Person / Time
Site:	Yankee Rowe
Issue date:	05/02/1985
From:	Cheung L, Dionne B, Dragoun T, Knox W, Shanbaky M, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127M022	List: IR 05000029/1985005 ML20127M018
References
RTR-NUREG-0737, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-029-85-05, NUDOCS 8505230171
Download: ML20127M061 (21)

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U.S. NbCLEAR REGULATORY COMMISS10H-

REGION I

Report'No.. 50-29/85-05 Docket No.

50-29 License No. OPR-3 Priority Category C

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Licensee: 1 Yankee Atomte Electric Company 1671 Worcester Road

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Framinoham, MA 01701 Facility Name: Yankee Rowe Inspection At: MonroeBridge,Massachusep

Inspection Conduct

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Inspectors:

-(t'e! Sedior%adfa' tion Specialist

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L. Chep6,

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M. M. Shanbily,'Chiet PWR Radiation Safety Seftion inspection Sumrr.ary:

Inspection on March 4-8, 1985 (Report No. 50-29/85-05)

~ Areas Inspected: Special, announced safety inspection of the licensee's imple-mentation and status of the_following task actions identified in NUREG-0737:

Post-accident sampling of reactcr coolant and containment atmosphere; increased range of radiation _ monitors; post-accident effluent monitoring; containment-radiation monitoring; and in plant radiofodine measurements. The inspection involved 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> by three region-based ir.spectors and two contractors from

Brookhaven National Laboratory.

Results: No violations were noted, but several areas requiring improvements were identified.

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DETAILS 1. 0 Persons Contacted 1.1 During the course of the inspection, the following licensee personnel were contacted or interviewed:

• l. Heider Vica' President, Nuclear Operations l

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'*N.- N. St. Laurent Plant Superintendent

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. *J. C.-Trejo -

Radiation Protection Manager

• R. L. Boutwell Technical Services Supervisor-0. Brown Operatcr

• B. L. Drawbridge Assistant Plant Supervisor

• S, P.'Fournier Lead Systers Engineer

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• J. S. Credutts Senior Chemist

• J. D. Ha.seltine Project Manager

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• T. Henderson Technical Directo-A. iiodgdon Senior' Engine.er

• W. G. Jones Engineer Manager

• J.

Kay-Licensing Engineer

• R. Mellor Chemistry

• N. M. Panzarino Radiation Protection Group

• L. A. Rice-Preparedness Coordinator

• L. Richardson Instrument and Control M. Thisell Chenii st

~* Denotes attendance at the Exit Interview conducted March 8, 1935.

Other members of!the licensee's staff were also contacted and/or participated in exercises of. post-accident and effluent monitoring systems during the-inspection.

2.0 Purpose The purpose of this inspection was to verify and validate'the adequacy of the licensee's implementation of tLe following task actions identified in NUREG-0737, Clarificaticn,of TMI Action Plan I:equirements:

. Task ~No.

Title II.B.3 Post Accident Sampling Capability II.F.1-1 Noble Gas Effluent Monitors L

II. F.1-2 San.pling and Analysis of Plant Effluents II.F.1-3 Containment High-Range Radiation Monitor.

III.D.3.3 Improved Inpl&nt Iodine Instrumentation under Accident Conditions

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W I 3.0 'TMI' Action Plan Generic -Criteria and Commitments

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The licensee's ' implementation of-the task actions specified in Section 2.0 were reviewed against criteria and commitments contained-in the

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following documents:

NUREG-0578, TMI-2 Less ons Learned Task Force Status Report and 3hort-_

Term Recommendations, dated July 1979.

• Letter:from Darrel G. Eisenhut, Acting Director, Division of Operating Reactors, NRC,.to all Operating Power Plants, dated October 30, 1979.

e NUREG-0737,-Clarification of TMI Action Plan Requirements, d4ted November,- 1980.

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Generic Letter 82-05, letter from Darrell G. Eisenhut, Dir(ctor, Division of Licensing (DOL), NRC, to all Licensees of Operatirig Power Reactors, dated March 14, 1982.

• Letter:from Darrell G. Eisenhut, Director, Division of Licensing, NRR to Regional Admin 1strato.s " Proposed Guidelines for Calibration and Surveillance-Requirements for Equipment Provided to Meet Item II F.1.,

Attachments 1, 2, and 3, NUREG-0737", dated August 16, 1982.

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Order " Confirming License Commitments on Post-TMI Related Issues",

dated March 14, 1983.

• Regulatory Guide'1.4, " Assumptions Used for Evaluating Radiological-Consequences of a Loss of Coolant Accident for Pressurized Water Reactors".

• Regulatory Guide 1.97, Rev. 2, " Instrumentation for Light-#ater-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident".

• Regulatory Guide 8.8, Rev. 3, "Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Station will be As Low As Reasonably Achievable.

4.0 Post Accident Sampling System, Item II.B.3 l

4.1~ Position

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NilREG-0737, Item II.G.3, specifies that licensee shall have the ca,nability-to promptly collect, handle and analyze post-accident samples which are representative ~ of conditions existing in the reactor coolant and containment atmosphere. Specific cri;eria are denoted in commitments to the NRC relative to the specifications contained in NUREG-073 _

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- Documents 'Rev'iewe'd The implementation, adequacy and status of the licensee's post-accident sampling and monitoring systems were reviewed against the criteria identified in Section 3.0 of.this' report and in regard to licensee

' letters,- memoranda,' drawings and station procedures as listed in Attachment I.A.

~ 4.2 System Description The Yankee Rowe Post Accident Sampling System (PASS) was designed to provide reactor coolant and containment atmosphere grab samples for laboratory analysis.

- The PASS sample station -is located outside of the Primary Auxiliary Building (PAB). The Hot Lab is located in.the Service Building.

Liquid grab samples from the sample station are transported to the Hot Lab for

- analysis using lead pigs.

The. PASS has the capability to sample the following t teams involving the Reactor Coolant System (RCS). and Containment Atmosphere (CA):

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f.eactor Coolant System Pressurizer

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Each of the four cold leg loops

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'The types of liquid RCS samples which can be obtained include:

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diluted (up to 1000) liquid samples from the reactor coolant; and,

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undiluted : tripped gas from the pressurized reactor coolant liquid

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sample.

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Containment Atmosphere

-~ The containment atmosphere sample'is obtained from the sump line

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used by one of the Hydrogen Analyzers.

The PASS has' the capability for the' purge of lines before sampling. The

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sample line for the RCS can be flushed after the sampling operations are

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completed to reduce residual' radioactivity.

'The following laboratory and counting room analyses capabilities are available:

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Boron - Boron analysis is conducted by a titration method using

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mannitol.

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' Dissolved Hydrogen-and Containment Hydrogen - Hydrogen analysis is-conducted using a. Fisher / hamilton.model 29 Gas Partitioner.

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. Isotopic'- Isotopic analysis is conducted using a Canberra 8100 multichannel analyzer, which is interfaced to a PDP 11/05 mini-computer. The -vendor supplied CLASS program is utilized for.

spectral-interpretation.

The -licensee has developed a procedure for the characterization of core damage in terms of clad failure, fuel overheat or fuel melt, using the data acquired from post-accident sampling, as well as other plant indicators. The procedure is derived from the Westinghouse Owner's Group c

nethodology.

14 dose rate of 25 R/ hour was used as the habita'oility design basis for the PASS sample station. According to the design base accident assessment, the dose rate in the containment may exceed 10,000 R/ hour.

Due to the

. proximity of the sample station to the unshielded vapor container, the

' dose rate at the station may exceed 25 R/ hour. The July 10, 1981 letter

'from NRC-DOL to YAPC specified 25 R/ hour as the design criterion for

' unshielded containments. Subsequently, the licensee has included a prceaution in simpling procedures which preclude use of the system if the dose rate exceeds 25 R/ hour.

4.3 PASS Performance Test A test of the PASS was conducted on March 6, 1985 in order to determine if the licensee's sample acquisition and analytical capabilities were in

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conformance with the specifications of NUREG-0737 and the licensee's connitments.

The licensee was able ta demonstrate that system hardware, procedures and personnel were sufficient to obtain and analyze post-accident samples within the three hcur time constraint of NUREG-0737. The licensee was also able to demonstrate an acceptable boron analytical capability by the successful determination of a calibrated boron test solution which was prepared by Brookhaven National. Laboratory.

The results of the licensee's performance in this area are detailed in Attachment II of this report.

4.4 Findings, Personnel and Procedures The licensee was able to demonstrate a satssfactory analytical capability. The personnel involved were knowledgeable of the system's operating characteristics and were familiar with the procedures used for sample acquisition-and analysis.

However, the following technical deficiencies were noted in the procedures used to detail PASS operation:

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Procedure OP-9450, " Post' Accident Sampling and Analyses" contains

'no provisions for the: performance of pH and chloride analysis. The

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. licensee's position and actions relative to these type of analyses is currently being_ reviewed by NRR.

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2.

The coreLdamage assessment proccdure requires the use of-several radionuclides which were not listed in the multichannel analyzer

. l ibra ry.' 'The' licensee has initiated action to replace the present system with a Cancerra Series-90 MCA. The new system will have expanded gamma analytical capability.

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.The ' licensee has_ not specifically stated the range, sensitivity and taccuracy cf several analytical.capaoilities, i.e. lower limit on dissolved.ga'ses, hydrogen concentration, and boron.

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4.4.1. Recommendations for Improvement

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Relative'to these items, it-is recommended that the licensee consider the following-improvements:

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Make provisions'to' conduct analysis of reactor coolant pH and chloride.

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Provida. assurances that the data required by the core damage

' assessment procedure can be provided by the available analytical y

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capabilities.

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. State the range, sensitivity and accuracy of all analytical

. methods.

These items will be reviewed in a subsequent inspection.

(50-29/85-05-01)

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4.5-Findings, Hardware Based ~en an evaluation cf PASS System and equipment, the following items

,s were noted:

The RCS post-accident sampling systems incorporates existing sampling lines for acquisition of coolant samples. One sample point is provided

. at each of four reactor coolant cold legs, located between the steam generator outlet and the reactor coolant pump suction. One additioinal-sample point is located in the pressurizer surge line.

-NUREG-0737 Section II.B.3 requires the licensee to have capability to promptly collect and handle post accident samples which are representative of conditions existing in the reactor coolant.

Regulatory

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- Guide '1'.97 specifies grab samples capability be provided for the reactor-coolant at high pressure and negative (lowest possible) presture, and for theEcontainment sump.

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The Yankee Rowe PASS does not haves a sample point at the containment sump, and cannot draw samples from the reactor coolant when the primary system is depressurized after a postulated line break accident.

In addition, even with the primary system fully pressurized, the sample obtained may not be representative and timely (for the core condition)

when the reactor coolant pumps are not running, since reactor coolant flow relies entirely on natural circulation, from the core through the hot ~1eg, through the steam generator tube, and to the cold leg before reaching the sample point.

In summary, the ability of the system to collect a representative liquid sample under all emergency cooling modes and RCS pressures is questionable due to the following considerations:

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-There is no pump in-the RCS sample lines.

Instead, the system relies on RCS pressure to create flow through the PASS. The system has not been tested below a primary system pressure 90 psi. The licensee plans to make low pressure tests during the next outage, b.

The coolant sample is taken from each of the four cold leg loops.

In order to obtain a representative sample, coolant must be circulating in the loop from which the sample is.being obtained.

Under certain accident conditions, natural circulaticn in a loop may not be adequate to assure that the sample provides information representative of core conditions.

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It has not been demonstrated that samples can be obtainea frum all four cold leg sample points.

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The system is not' designed to collect a sump sample.

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The system purge time has not been verified on the basis of an analysis using line volume and flow rate. The' system does not contain a flow rate meter, but relies on the initial system pressure and the drop in pressure during flow as an indicator that proper system flow is being maintained.

This item is unresolved pending review of the licensee's justification that the system as designed provides adequate assurance that representative post accident sampling can reasonably be accomplished.

(50-E9/85-05-02).

In addition, the following items were also noted:

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As installed, the containment air sampling system discharges to the e

i environment. The licensee currently plans to modify the system so that it utilizes the pump for the hydrogen analyzer and that the

discharges from the sampling position is routed back to i

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40~cc sample bottle in the PASS panel'is used to collect the reactor

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coolant sample. The bottle is rated for 1800 psig while the reactor coolant pressure can be more than 2000 psig. The licensee agreed to replace the sample bottle with one of sufficient pressure rating by-May 8, 1985.

These~ items '. vill be reviewed in a subsequent inspection (50-29/85-05-01).

-5.0' Noble Gas Effluent Monitor, Item II.F.1-1 5.1 -Position NUREG-0737, Item.II.F.1-1 requires the installation of noble gas monitors

.with an extended range designed to function during normal operation and accident conditions. The criteria, including the design basis range of monitors for individual release pathways, power supply, calibration and other design considerations are set forth in Table II.F.1-1 of NUREG-0737.

Documents Reviewed The implementation, adequacy, and status of the licensees monitoring systems were reviewed against the criteria identified _in Section 3.0 and in regard to licensee letters, memoranda, drawings and station procedures as listed in Appendix I.B.

The licensee's performance relative to these criteria was determined by

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interviews with the principal persoas associated with the. design, testing, installation and surveillance of the high range noble gas monitoring-systems, a review of the associated procedures and documentation, an examination of personnel qualifications, and direct observation of the systems.

5.2 Findings Within the scope of this review, the following was identified:

5.2.-1 Description and Capability

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To meet NUREG-0737 requirements for the monitoring of noble gases in plant effluents, the licensee has modified existing sampling arrangements

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with additional equipment installed specifically to meet the requirements of NUREG-0737, Item II.F.1 Attachment 1.

The noble. gas effluent monitoring systems consist of four isokinetic sampling _ probes which are installed in the primary vent stack, a low range primary vent stack gas monitor, a high range primary vent stack

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noble gas monitor, and four main steam line monitors.

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j L0f.thefour/isokineticprobeswhichareinstalledin.theprimaryvent 9-stack,1two are designed for the flow rate during normal-operation.(23,000

CFM) and.two'are designed for the flow rate during purge operations

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'(46,0_00 CFM). The probesLare connectec for four 1" stainless steel

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jipes',3which have been heat' traced'and insulated. The pipe runs.between

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2-or 4 large radius: bends-(SR bends)..Two of-the lines are connected to

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'the Fixed Partiolate, -Iodine and Gas Primary Vent Stack Monitor and the

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other two lines are connected to the Moving Particulate and Gas Monitor.

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nThellow range primary vent-stack; gas monitor _Ts preceded by a fixed

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< - E particulate filter and an iodine' charcoal cartridge.

The filtered gas

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then counted by.a beta: scintillation detector. The gas is then returned

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to;the primary vent stack. The gas detector is connected to a rate meter

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t,having decade ranges from 10 to 10' CPM. Meter indication and tiarms J

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.appearflocally at the instrument caninet. Remote readout is available in

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control room, via a chart recorder and panel alarm. sThis system is a

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capable'of measuring noble gas. concentrations from 3 x 10 ' uC1/cc_to_2 x y

c10 8 uC1/cc for Xe-133.

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moving particulate filter and/or the fixed particulate iodine cartridge.

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The filtered gas.is-pas' sed through the high range noble ga: monitor l and a

.is then re. turned.to the primary vent stack.

The high range detector is

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.an ion chamber which.is placed in the well of an 18" diameter x 0.1" l

thick' steel marinelli beaker..The detector and gas volume are surrounded

' by an 8" thick lead thield assembly. The detector is connected to a

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-preamplifier assembly and a local' readout module.

Remote: readout via_a

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chart recorder and a panel ' alarm is provided in the control room.

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System processor for display on the CRT monitors in the Technical. Support

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n Center and Euergency Operations Facility. The monitor readouts cover

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- leight decades from 0.1 to 107 mR/ hour.

The licensee's procedure calls

for the manual conversion of meter, chart recorder or. digital monitor.

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readings to_ concentration, release rate and off-site whole body dose

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i un equiv'alent rate 'at 1/2 mile by the use of momograms. These conversian

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' curves were developed by YAEC's radiation shielding code (DIDOS ~IV) for

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several fission product noble gas mixtures. This system is capable of

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N measuring noble gas mixtures and gas concentraticns from 1.74 x 10 8

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'uCi/cc.to 1.74'x 10' uC1/cc for Xe-133.

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' releases from the main steam line safety valvas. The monitors consist of

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lion chambers externally mounted over.each main steam line, upstream of

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L the-safety valves. The monitor readouts are located on the area

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radiation monitor panel in the Control Room. The readout is via an eight decade strip chart recorder which ranges from 0.1 to 107 mR/hr.

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readings-ate converted to concentrations, releases rate and off-site

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. whole body. dose aquivalent rate at 1/2 mile by the use of nomograms.

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108JuC1/cc for-Xe,-133.

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5.2.2 Acceptability'

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The-instal?ed system' meets the requirements-for-high. range noble gas

monitoring as(contained in NUREG-0737, Attachment II.F.1, Attachment 1.

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5.2.3' Observations

1During the-review'the following was observed:

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1 Noble gas: effluent monitoring could not be accomplished for normal

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conditions (i.e., BKG to:1.74:x 10 8 uCi/cc). The low range primary.

vent -stack gas monitor RAK-331-F. is presently out of service for.

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modification.

The -system has recently been upgraded to rectify

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moisture problems.

It will be placed in service following testing and calibration which.is awaiting resolution of technical issues-relating to calibration at elevated temperatures.

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the licensee is maintaining surveillance of noble gas ~ effluent ~

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releases in. accord with technical specifications.

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Main steam line' monitoring of main steam line safety valve

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discharges cannot adequately monitor a design basis release involving

'a fission product release in the: vapor contair.er and subsequent primary to secondary leakage with safety valves opened. ' Since the

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main steam line monitors are located directly under the unshielded

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vapor < container they would be rendered ineffective at quantifying.

. releases from this potential release path'due to the direct radiation from the vapor container. The NRC has recognized this

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limitation and realizes that'the unshielded containment. design

-precludes a reasonable resolution to this problem.

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"6.0 Sampling and Analysis of Plant Effluents, Item II.F.1-2 16.1 Position ~

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S NUREG-0737, Item II.F.1.2, requires the provision of a capability for the -

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collection, transpur t, and measu*ement of representativo. sa nples of

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"radioactiveLiodines and;particulater.that may accompany gaseous effluents

following an accident.

It must be performable within specified dose

~1imits to the individuals ~1nvolved.

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The criteria. including the design basis shielding envelope, sampling m.

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media, sampling considerations, and~ analysis considerations that are set

.forth in Table II.F.1,~Attachaent 2.

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Documents Reviewed-The implementation, adequacy and status of the-licensee's sampling and analysis. system and procedures were reviewed against the criteria identified in Section 3.0 and in regard to licensee letters, memoranda, drawings and station procedures as listed in Appendix.I.B.

lThe licensee's performance relative to these criteria was determined by interviews with-the principal persons associated with the design, testing

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installation, and surveillar.ce of the systems-for sampling-and analysis of high. activity.radiciodine and particulate efflents, by a review of the associated procedures and documentation, by an examination of personnel qualifications, and by direct observation of the systems.

6.21 Findings -

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Within the scope of this review, the following items were identified:

6.2.1 Description and Capability For the monitoring of particulates and iodines in plant effluents, the licensee has modified' existing sampling systems with additional equipment installed to meet the requirements of NUREG-0737, Item II.F.1, Attachment 2.

The pre-existing primary vent stack fixed particulate and iodine monitor draws a continLous sample stream from the isokinetic probes mounted in

.the stack. ine isokinetic nozzle assembly for this monitor was described previously (see section 5.2.1).

The sample stream is passed through a fixed filter which is monitored by a beta-scintillation detector to measure routine low-level particulate concentrations. Next, the sample stream is passed through a charcoal cartridge which is monitored by a sodium iodine detector to measure low-level Iodine-131 concentrations.

The filter paper and charcoal cartridge can be removed for subsequent

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laboratory analysis.

The supplemental high range primary vent stack iodine and particulate sampler consisted of a bubbler followed by a silver zeolite vial.

The sampler draws.a suction from the isokinetic nozzles inside the stack through 1" heated and insulated stainless steel pipe. A 1/4" stainless steel line is connected via a 90* "T" to the top of the 1" primary vent stack sampling line. This tap is not provided with a.iozzle directed at the stack sampling stream and it does not provide adequate flow to establish isokinetic sampling. The sample then impacts on a 90* "T", one leg of which is for backup sampling of particulates and iodines during routine operation (being utilized during this inspection) and the other

. leg is for'the accident sampler. The entrained sample encounters 2 more 90* bends, then proceeds through three Swagelok reducers into a teflon petcock valve and into teflon micro tubing. This micro tubing extends

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lapproximately 2-1/2 feetiinto a glass impinger apparatus. The sample is i,

bubbled through a chemical solution containing 200 ml of 0.01 m'

Na:S Os and 0.01 m KI with a KH P0( buffer.

The exhaust from the' bubbler bottle goescinto a 4cc vial which contains about'3cc of silver zeolite.

-.The exhaust from the silver zeolite is drawn via a low flow air sample pump;(5-8 cc/ min) which is connected to an elapsed timer. This system

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was mounted on a~ plexiglass board which was hung on the wall of the

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primary vent-stack monitoring equipment building. A 2 m1 sample is drawn

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from the bubbler via.a syringe and =is analyzed with a multi-channel

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'6 2~2~ Acceptability

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The system does not~ meet NRC guidance given in NUREG-0737 II.F.1

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Attachment 2 for the following reasons:

Continuous Sampling

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Continuous particulate and iodine sampling.is required whenever-exhaust flow occurs.

Continuous sampling utilizing the bubbler 1 system is doubtful due to~ saturation of solution, depletion of chemical volume and the lack of provision for the analysis of

, differential samples.

' Isokinetic Sampling

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Isokinetic sampling of particulates and iodines is required to assure that a representative sample is drawing from the stack into the sampling line. This requires that the' sample nozzle entry velocities have approximately.the same velocities as the in-duct-or i

in-stack air velocities.

Isokinetic sampling cannot be verified, since no~ isokinetic nozzles existed inside the 1" sampling line and insufficient flow existed to achieve the required velocities with the existing pump.

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Representative Sampling

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Representative sampling per the criteria of ANSI N13.1-1969 and-Regulatory. Guide 1.97'cannot be verified and does not appear to be~

possible with'the existing design of the sampling system.

-Documentation of test results of representativeness of the

' particulate and iodine sample or data to support correction for line losses were not available.

Additional system design characteristics Lwhich preclude representative sampling include:

dead space, sharp

90* bends, lack of-laminar flow, valves upstream of the filters, c

drastic reduction ~in sampling line I.D., and no heat trace

.

provisions on sampling lines.

<-

,

e

,

I-c-A--e, n

a e-+--..-r--reer*,w-w-r--m-*n-+--.,w,-c-

-

.=-tw-+

w wwer-w em ww -r--,w rwm ' -- ww.s, + w--v g et ww w e,-t-e m - m-t-w, v- " w w--s r

-

.w-v-

+

Wm

-

'

.

r

,g

.

..s

g

.

.g,

-

w

.

' Analysis' Considerations

-On-site laboratory capabilities to analyze or measure the H

particulate and iodine samples did not make provisions for a backup

"

. analysis capability._ In the' event of a loss.of the laboratory, ibecause' of high background radiation, laboratory contamination and

yanalyzer failure,.the particulate and iodine samples _could not.be analyzed.

,m

As of October 1984,-_the licensee had concluJed that the system lacked

"

sufficient suitability relative to the requirements of NUREG-0737, and

-

subsequently initiated action to resolve these deficiencies _by~the

< installation of a completely redesigned system. The licensee expects the system will be installed by August 1985; and tested and verified as

'

representative'by December 1985.

16.2.3-Recommendations for the Particulate and Iodine Sampling and Analysis,

'

- Based.on the.above findings, the' licensee should:_.

-1 Acquire a b6ckup. multi-channel analyzer (presently on order) that-

'

.can be directed to sample analysis or obtain written confirmation of an outside agreement to provide backup analysis. This item will be reviewed in a subsequent inspection (50-29/85-05-04).

g 6.3._

Conclusion

-

DThe licensee's current installation does not' technically meet the requ' ire-

,

~

ments of NUREG-0737. However,-the licensee has already self-identified the~ deficiencies and initiated action to resolve the'. technical inadequa-cies by the installation of a completely. redesigned system. This item will

-

be considered unresolved pending timely completion-of the licensee's

' corrective measures as indicated.

(50-29/85-05-05).

.

-

7.0 Containment High Range Radiation Monitor, Item II.F.1-3'.

Position o

NUREG-0737 item II.F.1-3 requires the installation of high range radiatior.

monitors-capable of' detecting and measuring radiation levels within the-

'--

reactor.. containment during and following an accident.

Specific require--

.ments are' set forth in Table'II.F.1, Attachment 3.

,

Observations The: licensee has installed two Victoreen Model'875 High Range Containment-

-Monitors with readouts mounted in the control room. The location and

_

p.

.

h

,

L arrangement of the two detectors in containment were verified by the inspector during a routine containment entry at power.

Victoreen has issued a report.of the generic systers testing indicating that the range and response of this equipment are ac9quate.

The system was installed in accordance with the licensees Engineering Design Change No. 79-19. Work began in 1980 and was completed in early 1982.

Initial system calibrations were performed using on-site calibrated radiation sources. The licensee has purchased a Victoreen High Range Field Calibrator Model No. 878-10 for future use.

-Conclusion With the exception of equipment environmental qualification discussed in Section 12 of this' report, licensee implementation of item II.F.1-3 is satisfactory.

8.0 Improved In-plant Iodine Instrumentation Under Accident Conditions, Item III.D.3.3 Position NUREG-0737, Item III.D.3.3 requires the licensee to provide equipment and

associated training and procedure for accurately determining the airborne iodine concentration in areas within the facility where plant personnel may be present during an accident.

Observations The licensee's airborne iodine montt'oring equipment consists of a portable cart-mounted Eber11ne SAM-2 analyzer, TEDA impregnated charcoal

,

cartridges, silver impregnated silca gel cartridges and low volume air sampling pumps. The SAM-2 analyzer is used daily for routine air sampling which ensures its operability and maintains HP technician proficiency in its use.

It is calibrated to respond to'the 365 kev gamma of iodine - 131 as recommended by NUREG 0737. The cartridges and pumps are stored in locked emergency cabinets in the control room. The control room and adjacent Technical Support Center and the Operations Support

' Center on the turbine deck will be the only occupied areas in an emergency..The emergency equipment is easily accessible from these areas.

The following licensee procedures for post accident iodine monitoring were reviewed:

CP 8700, " Accident Radiation Survey Procedure for Control Room, TSC,

-

OSC" OP 8701, " Operation and Source Check of the Eberline SAM 2/RD 22 for

-

Determination of Radioiodine Airborne Concentrations"

.

-. -..

-

.

-

.

.

-

-

p

..

'

.

DP 8580, " Calibration and Source Check of the Eberline SAM 2/RD 22 for

-

Analysis of Radioiodine.

All HP technicians are qualified in these procedures.

To ensure the accuracy of the iodine analysis, the licensee purges the charcoal cartridge with clean. nitrogen gas to remove interference from

radioactive noble gases. However, the licensee plans to remove the purge apparatus and will specify the use of silica gel cartridges to selectively measure iodine. A procedure incorporating this change has been drafted and-is under review.

Conclusions Licensee. implementation of Item III.D.3.3 is satisfactory.

'

9.0 Quality Assurance and Design Review As part of the inspection effort, a review was performed to verify and validate the adequacy of the licensee's design and quality assurance program for the installation of the Post Accident Sampling System (PASS).

9.1 Documents Reviewed The inspector reviewed pertinent work and quality assurance records for the design, construction and installation of the Post Accident Sampling System to ascertain whether the records reflect work accomplishments consistent with NRC requirements in the areas of equipment qualification, installation and inspection.

Documents reviewed for this determination include:

A)

Stone and Webster Documents Drawing No. 9699-FM-6A, " Flow Diagram - Main Coolant, SV Blow,

-

Drain and Vent Lines", Revision 37 dated October 25, 1984.

Drawing NO. 9699-FM-9A, " Flow Diagram - Main Coolant Component,

-

Shutdown, Fuel Pit Cooling lines", Revision 34, dated September 4, 1984.

l Drawing No. 9699-FM-8A, " Flow Diagram - Charging, Bleed and

-

Chemical Shutdown Systems", Revision 43, dated September 6, 1984.

C

. _ -

- _

__ _ _- _ _

_ _ _ _ _ _ _ _ _ _

.

'

.

k

'

...

,

i e

.16

_

^

B)

Yankee Atomic Electric Company Documents

'

Drawing No. YM-H-8,." Flow Diagram Sampling System", Revision 8,

-

~ dated February 23, 1984.

,

i

'

Drawing No. 9699-FM-260, " Primary Air Disposal, Primary Vent

--

Stack and Hydrogen Monitoring'with Miscellaneous Sections",

'

Revision 2,. dated July 9, 1984.

'

Post Accident Sampling System - Bill. of Materials.

-

L

'C)

Oth'er Documents

,

l

. Whitey Catalog for Sample Cylinders.

-

Acceptable performance was evident. No violations were identified..

.

~

10.0 Alternate Power Supplies-

.To comply with the requirement of criterion 1 of NUREG-0737, Item II.B.3,

!

!

~

the licensee committed that-alternate power source would be available to

operate the PASS during loss of off-site power to meet the three-hour

'

Esampling and analysis time limit.

,

-

,

The inspector reviewed pertinent documents to ascertain:whether provision

of:this alternate power.. supply has been established.

Items reviewed in this. determination. included:

-1)-

Stone and Webster Drawing 9699-RE-IF, "480V One Line Diagram",

sheet 2, Revision 24, dated October 30, 1984.

2)

Stone and Webster Drawing'.9699-FE-1J, "480V one Line Diagram",

.

' sheet 4, Revision 23, ' dated December 3,1984.

Acceptable performance was evident. No violations were identified.

11.0 Environmental Qualification of Inaccessible Valves To comply with the requirement of criterion 3 of NUREG-0737, Item II.B.3, the licensee ' stated in their letter dated October. 3,1983 that they had verified that valves.which are not accessible after an accident are g,

environmentallyLquali,fied for the conditions in which they must operate.

,

1The following valves, all located in containment, are required to be

-

.

operable' for post accident sample collection and are inaccessible after an accident: HU-SOV-1 and HU-50V-2 (Valcor Solenoid Valves) VD-MOV-505

.

'through - 509, VD-MOV-511 (Motor Operated Valves with Limitorque SMA-00

'

'

and SMA-000 operators.)

,

I

.

- - - -.. -.

. - -

.

, - - - _ - -.. _ -. _ - - - - - ~ _ _ _.. _ _. _ _.. - - - - - - - - - _ _ -

. <. -

g

.

.o

At the end of the inspection period, the inspector was provided with the qualification documents for the above valves for review. This item re-mains open pending NRC review of the qualification data for these in-containmentvalves(50-29/85-05-06).

12.0 Environmental Qualification (EQ) of Containment High Range Radiation Detectors Attachment 3 to Item II.F.1 NUREG 0737 requires the containment high range radiation monitors be qualified to function in an accident environment. The inspector reviewed pertinent documents to determine whether the EQ data for these monitors has been established.

Documents reviewed for this determination include:

Licensee letters to NRC dated May 20, 1983, August 30, 1983 and

-

May 5, 1984.

Documentation Package Summary to YAEC Package No. QDR-5435-104-2450,

-

ECO TECH # YR-2001-8.6. Revision 2 page Al through A6.

ECO TECH Document # YR-2001-8.6, Revision 2 dated January 11, 1985,

-

" Operating Time Qualification pages 01 through D20", " Pressure Qualification pages D32 through 034", " Relative Humidity Qualification pages D35 through D37", " Radiation Qualification -

pages D38 through D40," " Aging Qualification, pages D41 through D43".

The adequacy of the Environment Qualification data is currently being evaluated by the NRC and the results will be documented in the associated Safety Evaluation Report.

No violations were identified.

13.0 Exit Interview The inspector met with the licensee management representatives (denoted in Section 1.0) at the conclusion of this inspection on March 8, 1985, to discuss the scope and findings of the inspection as detailed in this report.

At no time during this inspection effort was written material provided to the licensee by the NRC inspectors.

__

.

7 -.

.

'4

Attachment I.A Documentation for NUREG-0737 II.B.3 Licensee Correspondence D. M. Crutchfield, Chief, ORB #5-00L to J. S. Kay, Sen. Eng. YAPC, dated

-

July-10, 1981.

L. H. Gelder, V.P. YAEC to D. G. Eisenhut, Dir. DOL, dated

-

December 15, 1981.

J. A. Kay, Sen.~ Eng. YAEC to D. M. Crutchfield, Chief, ORB #5, dated

-

May 1, 1980.

D. M. Crutchfield, Chief, ORB #5-DOL to J. S. Kay, Sen. Eng. YAEC, dated

-

October 8, 1982.

J. A. Kay, Sen. Eng., Lic. YAEC, to D. M. Crutchfield, Chief ORB #5-DOL,

-

dated February 14, 1983.

D. M. Crutchfield, Chief, ORB #5-00L to J. A. Kay, Sen. Eng. Lic. YAEC,

-

dated. December 21, 1983.

J. Gedutis, YA-R to unspecified, dated January 25, 1985.

-

M. J. Smith, YA-R to file, dated March 7, 1985.

-

Licensee Procedures DP-9201, Titrimetic Analysis for Chloride, Boron, Chromate, Hardness,

-

P and Alkalinity," Rev 7.

DP-9451, Inventory of Post Accident Sampling Materials and Equipment,

-

original.

OP-4216 " Testing of the Post Accident Hydrogen Venting System," Rev. 15.

-

OP-9450, " Post Accident Sampling and Analyses," Rev. 4.

-

" Yankee Nuclear. Power Station Core Damage Assessment Methodology,"

-

undated.

Drawings YM-H-8, " Flow Diagram - Sampling System

-

9699-FM-6A, " Flow Diagram - Main Coolant, S.V. Blow, Drain and Vent Lines"

-

9699-FM-8A, " Flow Diagram - Charging, Bleed and Chem Shutdown Systems"

-

9699-FM-9A, " Flow Diagram - Main Coolant Component Shutdown Fuel Pit

-

Cooling Lines" 9699-FM-83A, " Flow Diagram - Low Press and High Press Safety Injection"

-

9699-FM-260, " Primary Air Disposal, Primary Vent Stack and Hydrogen

-

Monitoring with Miscellaneous Sections" L.

-.

-.. -

--

---

..

---

.-.. -. --w

• a

19

.

Attachment I.B Documentation for NUREG-0737 II.F.1 Licensee Correspondence D.M. Crutchfield, Chief, 0.R.B. #5 - DOL to J.A. Kay, Sen. Eng., YAPC,

-

dated July 10, 1981.

D.M.~Crutchfield,-Chief, 0.R.B. #5 - DOL to J.A. Kay, Sen. Eng., YAPC,

-dated October 20, 1981.

J.A. Kay, Sen. Eng., YAPC, to Dennis Crutchfield, Chief, 0.R.B. #5 -

-

00L, dated December 31, 1981.

D.M. Crutchfield, Chief, 0.R.B. #5 - DOL to J.A. Kay, Sen. Eng., YAPC,

-

dated February 26, 1982.

D.E. Moody, YAEC to D.M. Crutchfield, Chief ORB #5 - 00L, dated

-

May 14, 1982.

D.B. Eisenhut, Dir. DOL to L.H. Heider, V.P., YAEC, dated

-

March 14, 1983.

J.A. Kay, Sen. Eng., YAPC to J.A. Zwolinski, Chief ORB #5 - DOL, dated

-

November 19, 1984.

Licensee Procedures OP-3310 " Evaluation of Radiological Data", Rev. 4.

-

OP-4669.4 " Calibration of Main Steam Line, Primary Vent Stack Area

-

Radiation Monitoring Devices".

Drawings NMC-A-400060, "YAE-Duct Holing Reg.", Rev. B.

-

- -NMC-A-400061, "YAE-Nozzle.196 dia.", Rev. A.

NMC-A-400062, "YAE-Nozzle.277 dia.", Rev. A.

-

~SWEC-9699-RE-1F, ""80 V One Line Diagram - Sh-2", Rev. 24.

-

SWEC-9699-FE-1J, "480 V One Line Diagram - Sh-4", Rev. 20.

-

m

r-

.,

S

Attachment II t

'

Comparison of Analytical Results A.

Chemical Analyses 1.

Boron 1.1 Confirmatory Test Calibrated Acceptance Solution In-Line Acceptance Tolerance Analysis Laboratory Error Tolerance 2981 ppm 2995 ppm

+0.5%

i 5%

-

998 ppm 999 ppm +

+1 ppm i 50 ppm

-

1.2 PASS Test of Reactor Coolant Sink Analysis

.

PASS Acceptance Analysis Error Tolerance 485 ppp 516 ppm 31 ppm i 50 ppm g

2.. Chloride in Reactor Coolant

,

No provision for chloride analyses.

3.

pH of Reactor Coolant No provisions for pH analyses.

4.

Dissolved Hydrogen in Reactor Coolant Below analytical capability.

5.

Dissolved Oxygen in Reactor Coolant (Optional)

No commitment.

6.

Conductivity of Reactor Coolant (Not Requiredl No commitment.

7.

Hydrogen /0xygen in Containment Atmosphere Below analytica1' capability.

u

.--

,

,

...,;

..v

-

?--- g g

.

i

~

21:

B.

Isotopic Analyses'

,

i

,

f A

1. 2 Containment Atmosphere

>

Expected Observed.

.

. Grab Sample-Grab Sample'

_

Acceptance Isotope

- (uCi/cc)

(uC1/cc)

Factor Factor Xe-133 1.05E-3

- 1.175-3 1.1 0.5 to 2.0

' Xe-135 4.95E-6 3.09E-6:

0.6'

O.5 to 2.0

-

.2.

Reactor Coolant

.

Expected-Sink Observed

~

Isotope.L (uC1/cc)

(uCi/cc)

Factor Acceptance

,

-CoS8 1.63E-2 1.48E-2 0.9 0.5 to 2.0

'

Csl38 9.37E-1-

.5.68E-1 0.6 0.5 to 2.0

- I131 4.87c-2

'

. 5.05E-2 1.0 0.5 to 2.0 I132 3.34E-1 3.31E-1 1.0 0.5 to 2.0

'

I133'

1.01E-1 1.30E-1 1.3 0.5 to 2.0 I134,

6.77E-1 7.32E-1 1.1 0.5 to 2.0

- I135

- 2.25E-l'-

2.71E-1 1.2 0.5 to'2.0

' Kr85m

- 8.12E-2 1.53E-1 1.9 0.5 to 2.0 l

' Kr87 9.63E-2 2.25E-1 2.3 0.5 to 2.0

~

' Xe135 1.45E+0 2.23E+0 1.5 0.5 to 2.0 Xe135

. 5.48E-1

- 9.44E-1 1.7 0.5 to 2.0 t

i W

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%

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-

%

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sewg e-w

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