IR 05000400/1987025
| ML18004B918 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/26/1987 |
| From: | Kahle J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004B917 | List: |
| References | |
| TASK-2.B.3, TASK-TM 50-400-87-25, NUDOCS 8709040492 | |
| Download: ML18004B918 (24) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
<<JI82 8 i937 Report No.:
50-400/87-25 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 facility Name:
Harris
Inspection Conduc July 7-31, 1987 Inspector:
P.
G. Sto rt License No.:
NPF-53 r/~/I Date Slg e
Approved by:
J.
B. K, Sectso ief Division of Radiation Safety and Safeguards a
e Soigne SUMMARY Scope:
This special, announced inspection was in the areas of post-accident sampling systems, radiological effluent sampling and monitoring, and investigation of allegations.
Results:
No violations or deviations were identified.
870'p'040492 870828 PDR ADQCK 05000400 G
REPORT DETAILS Persons Contacted Licensee Employees
"J.
L. Harness, Assistant Plant General Manager
"H. W. Bowles, Director, Onsite Nuclear Safety
"G. Campbell, Manager, Maintenance
- G. L. Forehand, Director, equality Assurance
"0.
N. Hudson, Senior Engineer, Regulatory Compliance
"H. Lipa, Supervisor, Environmental and Chemistry
- C. L. McKenzie, Principal gA Engineer
- G. Nathan, Project Specialist, Environmental and Chemistry
"A. Poland, Project Engineer, Radiological Control
- C. E.
Ross, Jr., guality Assurance Supervisor
"F. L, Smith, Senior Engineer, Maintenance
"D. L. Tibbetts, Director, Regulatory Compliance J. Sipp, Manager, Environmental and Radiation Control Other licensee employees contac ed included engineers and technicians.
NRC Resident Inspectors
~G. Maxwell, Senior Resident Inspector
~Attended exit interview Exit Interview The inspection scope and findings were summarized on July 31, 1987, with those persons indicated in Paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The post-accident sampling system was evaluated against 14 criteria set forth in NUREG 0737,Section II.B.3.
For two of the 14 criteria, the licensee could not adequately demonstrate the capability to quantify dissolved gases in primary coolant and was not able to analyze accurately for chloride in primary coolant.
On all other criteria, the PASS was evaluated as satisfactory (Paragraph 4).
Four inspector followup items and one unresolved item from previous inspections were closed during this inspection.
An investigation into an allegation to the effect that a computer data tape recording mechanism was not functioning properly revealed that the allegation was substantiated; however, the licensee, prior to this inspection, had initiated appropriate corrective action (Paragraph 6).
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
Licensee Action on Previous Enforcement Matters (Closed)
Unresolved Item (UNR) 50-400/87-13-02, was concerned with an excessive moisture condensation condition in the turbine building gaseous effluent release point radioactivity monitor.
Actions taken by the licensee to correct this problem using heat-traced sampling lines and a
moisture reduction system appeared to be successful in correcting the condition.
This matter is considered closed.
Evaluation of the Post-Accident Sampling System (PASS)
(NUREG 0737, Item II.B.3)
The post-accident sampling system (PASS) installed at Shearon Harris was ori gina 1 ly designed and was partially fabricated by the Mi 1 ton Roy Division of the Hayes-Republic Company.
At some point in time during the procurement process, the Milton Roy operation responsible for the PASS was sold to the Bull and Roberts Company, under which most of the principal components were fabricated and assembled.
Subsequently, the Bull and Roberts division responsible for the PASS was sold to the Maltron Corporation, where final fabrication, assembly, and factory-testing were completed.
The PASS liquid sampling section had the capability of sampling primary coolant from the hot leg and for sampling of liquid from the containment sump utilizing the lower section of the RHR discharge piping.
The gas'ampling section of the PASS had the capability of sampling primary containment atmosphere for airborne radioactivity content and for hydrogen.
No isolated auxiliary systems were required to be operated in order to obtain samples of primary coolant and of containment atmosphere.
The PASS was evaluated against the criteria in NUREG 0737, Item II.B.3, Post-Accident Sampling Capability, and in the attachments to the Generic Letters to all operating nuclear power plants, dated September 13, and October 30, 1979, and to all power reactor applicants and licensees dated March 28, 1980.
The referenced criteria were consolidated into 14 criteria for inspection and evaluation purposes.
The results of the individual criterion evaluations are presented in Attachment 1 to this inspection report.
In the evaluation, it was determined that the licensee did not fully meet two of the fourteen criteria.
The two criteria which were not met were Number 6, (}uantification of Dissolved Gases in'eactor Coolant, and Number 7, Chemical Analysis Capability to guantify Chloride in Reactor Coolant.
The sampling mechani,sms of the PASS functioned adequately and samples were collected without difficult The required analyses, with exceptions of dissolved gases in primary coolant and chloride in primary coolant, were performed readily and within time and accuracy limits as prescribed in NUREG 0737.
Three separate reactor coolant system (RCS) liquid samples were collected and analyzed within the prescribed time period of three hours to demonstrate the operability, accuracy, and repeatability of the dilute (920: 1)
sampling method.
Gamma spectrum analyses, correlated to the analysis of the normal RCS sample for the same time period, were within
+16%
on total activity and individual radionuclides were within a factor of two for such nuclides as were detectable at the dilute concentrations present in the PASS diluted samples.
The criterion specified a factor of two as being acceptable.
Analyses of the RCS liquid samples for boron were performed in duplicate on each of three samples.
Results of the six analyses were then correlated to the results of the current undiluted RCS coolant boron analysis.
As was discussed in NRC Inspection Report No. 50-400/87-13, the current NRR position holds that an accuracy of
+12% for highly dilute samples is adequate.
Of the six analyses of dilute samples performed for this evaluation, five were within 12% of the value determined for the undiluted sample obtained through the normal sampling system.
The sixth value was within 15% of the normal sample value.
On the basis that the licensee results were within the specified accuracy limits in five out of six analyses, the licensee'
sampling and analysis methods and pr actices were considered adequate.
The criterion was considered to have been met.
The Harris PASS was designed and installed with provision for in-line determination of dissolved gases (e.g.,
in primary coolant.
In the event of unavailability of the in-line system, provi sion was also made for the obtaining of a grab sample and a procedure was established for backup measurement of grab samples for dissolved gases.
The preoperational tests of the in-line measurement system and of the grab sample procedure were both satisfactory.
However, at the first quarterly test, the in-line measurement system was found to be non-functional and the grab sample results were found to be questionable.
A work order was issued to examine the system for leaks but none were found or identified.
At the second quarterly test, similar results were obtained and efforts were initiated for repair or replacement of the dissolved gas measurement device (Plant Change Request PCR-1570)
and to resolve the inaccuracy of the grab sample method.
As of the end date of this inspection, the problems had not been resolved.
The grab sample measurement observed by the inspector was 4.97 cc/kg.
Normal RCS dissolved gas measurements for the same time period were 26 to 29 cc/kg.
The observed result was not within the limits of +5 cc/kg (at concentrations below 50 cc/kg)
as specified in the criterion.
The licensee acknowledged that such inaccuracies had been observed earlier and pointed out that a program was already in progress to resolve the problem.
The inspector informed the licensee that the inability to accurately measure dissolved gases in primary coolant would be listed as an inspector'ollowup item pending a
review of proposed licensee remedial actions in a subsequent inspection.
The inspector concluded that the licensee did not meet Criterion 6.
Under Criterion 7, the licensee was required to establish chemical analysis capability to quantify chloride in reactor coolant within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
The analysis was not required to be performed onsite.
The
,licensee demonstrated the capability to obtain a
PASS RCS sample for chloride analysis but was not able to provide an analysis which could be correlated to the normal RCS sample result.
Analyses of three RCS PASS liquid samples showed chloride present at an average concentration of 48 ppb in samples diluted 920: 1.
The undiluted RCS normal sample showed less than 5 ppb.
At the end of the inspection, the licensee had not been able to resolve the discrepancy, which,licensee representatives stated had not been present in the preoperational tests or in the two quarterly tests which had been run since plant startup.
It was noted that in a reanalysis of the remaining portions of the three samples, all three showed significant values of chloride, fluoride and sulfate, which could indicate sample contamination by pipe sealing compound or a similar substance.
The licensee was notified that this matter would be considered an inspector followup item pending a review of licensee resolution of the cause or source of the apparent contamination of the RCS PASS samples.
It was noted that the licensee had a contract with Babcock and Milcox to provide post-accident analysis services such as chloride analysis of primary coolant and that the 96-hour requirement for performance of the chloride test could be accomplished through that contract.
Due to the presence of the contaminant described above, the licensee was not able to demonstrate the capability to meet Criterion 7, Chloride Analysis.
The reactor coolant and containment atmosphere post-accident sampling systems were designed with sufficient shielding and sample dilution systems to permit samples to be obtained and analyzed without exceeding radiation exposures of S rem whole body and 7S rem to the extremities.
Documentation of dose calculations appeared in licensee document TLR-RC-006, Rev.
0, dated May 7, 1987.
The PASS appeared to have been installed in accordance with the design and there appeared to be no unresolved safety issues.
The licensee employed a
grab sampling method and onsite laboratory analysis capability to quantify hydrogen levels in the containment atmosphere.
Samples were observed during collection and analysis, with results of the PASS and normal sample station s'amples showing less than 0. 1% hydrogen.
The analysis method was demonstrated to be capable of measuring from less than 0. 1% to in excess of 10%,
by volume, of hydrogen in air during preoperational testing.
Provision was made for grab sampling and analysis of reactor coolant for dissolved oxygen.
On-line analysis was provided for pH.
Dissolved oxygen
in the normal RCS liquid sample was <0.05 ppm, while the PASS measurement was 29 ppb, or 0.029 ppm.
The correlation between the two measurements was within the prescribed
+0.05 ppm criterion.
The pH measurements were 6.42 for the normal RCS value and 6.55 for the PASS determination.
The differential of 0.13 pH unit was within the bounds of +0.3 pH unit for readings between pH 5 and pH 9.
Provisions were incorporated in the PASS for purging sample lines to assure representative sampling and for clearing radioactive material from sampling lines after sampling'lateout in liquid sample lines was minimized by employing high velocity flows and by employing heat tracing as necessary to minimize temperature differentials.
Filters and strainers were employed at sample intake points and samples were taken from zones of turbulent mixing rather than from quiescent areas to minimize the possibility of drawing debris into sample intakes.
RCS fluids and containment gases employed in flushing or purging sample lines will be returned to containment under accident conditions.
During system tests and checks under normal operating conditions, purge and flush liquids will be drained to a
radwaste retention tank, while purge and flush gases will be returned to containment.
Sampled materials will be disposed of after analysis under health physics surveillance.
Flow restriction to limit coolant loss in the event of a
line rupture was incorporated in design by utilizing small diameter lines and flow restriction devices.
Ventilation exhaust of equipment and sampling panel rooms associated with the PASS was ducted to exhaust gas/air treatment systems incorporating HEPA filtration and charcoal adsorption prior to discharge through the plant vent.'he licensee had a formalized training program incorporating written lesson plans and hands-on training in operation of the system.
Vendor
'nstruction was also used in the training program.
All training was adequately documented and refresher training was being conducted on a
quarterly basis at the time of the inspection.
The licensee had performed a formal acceptance test during preoperational PASS testing and had initiated a quarterly test program, beginning in March 1987, as specified in Procedure CRC-830,
"PASS quarterly Testing".
All laboratory chemical analyses were also being tested quarterly.
Procedure CRC-830, referenced above, and Procedure CRC-821,
"Post-Accident RCS/RHR Sampling,"
appeared to adequately address necessary requirements for quar'terly performance tests for the PASS.
~Summa r The PASS installed at Shearon Harris was evaluated against 14 criteria of NUREG 0737 and follow-on instructions.
The evaluation showed that the
PASS fully met 12 of the 14 criteria, did not meet the criterion for analysis of chloride in RCS coolant, and did not meet the criterion for measurement of dissolved gases in RCS coolant.
In the case of the latter two criteria, it was apparent that the licensee had previously recognized the problems and had undertaken appropriate timely remedial action.
The inspector concluded that the Shearon Harris PASS was demonstrated to be an operational system (subject to the two items noted above),
that system operators and chemistry analysts were adequately trained and qualified to perform their assigned tasks, and that adequate programs were in place for training, retraining, and qualification of personnel and for the maintenance and calibration of the PASS and related analytical functions.
(Opened)
Inspector Followup Item 87-25-01, Review licensee actions to replace monitor for in-line detection of dissolved gas in RCS samples and to resolve inaccuracies of grab sample analysis.
(Opened)
Inspector Followup Item 87-25-02, Review licensee resolution of contamination of. PASS RCS samples with chloride.
No violations or deviations were identified.
Review of Environmental Surveillance Report for the Period January-December 1986 (80721)
The inspector reviewed the licensee's environmental surveillance report for calendar year 1986, received Nay 26, 1987.
The report covered the period immediately preceding the fuel loading, startup, and ascent to power of the Shealon Harris plant.
The environmental monitoring report appeared to be adequate to meet reporting requirements.
It was noted that Iodine-131 activity was observed for approximately six weeks following the Chernobyl accident of April 26, 1986.
Beta activity, as Cesium-134 and Cesium-137, was also detected; however, the Cesium-137 activity was consistent with prior observations of Cesium-137 resulting from atmospheric weapons test of prior years.
No other significant anomalies were observed or reported.
No violations or deviations were identified'llegation Followup (99014)
The material presented in the following paragraphs was transmitted to appropriate investigative organizations by copy of this inspection report.
The inspector conducted a review of circumstances surrounding Allegation RII-87-0080 on July 28-29, 1987, during this inspections
An allegation was received from an during the week of June 1,
1987, and inspector on June 1,
1987.
The al Region II Allegations Coordinator on individual by a Resident Inspector also from the same individual by this leger was also contacted by the June 9,1987.
The essence of the allegation was a
concern that the RM-21 computer associated with the Process and Effluent Radiological Monitoring and Sampling System (PERMSS)
was malfunctioning in that the tape drive mechanism used to "back-up" the hard disk computer memory system would not make an error-free copy of the accumulated data on the hard disks.
If the backup tape recording were not made or were to be made with errors, there was a potential that in the event of power loss or disk memory "crash,"
three to six months of data data which Technical Specifications require to be in permanent storage -- could be lost or irretrievable and that certain reports required by Technical Specifications could not be prepared in the absence of that data.
In discussions with licensee personnel, it was determined that the licensee was aware of the principal points of the allegation and that a
program to correct the problem had been active since March 1987.
The problem had not been resolved to the satisfaction of licensee personnel as of the end date of the inspection; however, significant progress had been made and two error-free copies were made during the period of the inspection.
What had not been determined as of the end date of the inspection was whether or not the problem had been fully resolved and if error-free copies could be made consistently.
The inspector also contacted the alleger; however, no additional information was obtained.
On the basis of the above, the inspector concluded'hat the allegation was substantiated, that the licensee was apparently taking appropriate action to correct the situation, that the licensee actions had succeeded in minimizing the problem, but that the final licensee action had not been completed as of the end date of the inspection.
No violations or deviations were identified.
Process and Effluent Radiological Monitoring and Sampling Systems (84723, 84724)
The inspector reviewed the status of the process and effluent radiological monitoring and sampling systems with licensee representatives.
As noted in a
previous inspection (IFI 50-400/87-13-06),
the licensee had experienced a
number of problems with the RM-11 computers which control the various components of the radiation monitoring system and which generate records of radiation conditions, determine alarm status, and provide computer graphic indications of plant radiological conditions.
Modified software, for establishing RM-ll computer programs, was obtained from the vendor and tested.
While the general operating condition of the
system was improved, system malfunctions continued to occur, apparently as a result of overloading the system with data messages.
The licensee was continuing efforts to resolve the problem.
Vendor proposals on resolving the problem were stated by licensee representatives to be unacceptable.
The inspector concluded, on the basis of discussions with licensee representatives and on review of plant records and correspondence, that IFI 50-400/87-13-06 should remain open pending resolution of the problem.
No violations or deviations were identified.
8.
Followup on Inspector Identified Problems (92701)
a.
b.
(Closed)
Inspector Followup Item (IFI) 86-79-05 - Evaluate post-accident sampling system (PASS) after reactor has operated at full power for at least
days immediately prior to evaluation.
See paragraph 4 of this report.
This matter is considered closed.
(Closed)
IFI 87-13-01 - Review and evaluate alpha activity trends in primary coolant radioactivity analyses.
The indication of the presence of alpha activity in primary coolant samples was evaluated by the licensee and was found to be attributable to a
vendor-recommended counting procedure, This counting procedure employed TENNELEC alpha-beta proportional counters in a simultaneous alpha-beta counting mode, in which the detector high voltage.was pre-set at a point in the limited proportional voltage region to produce detectable pulses from both beta particles and alpha particles.
A pulse-height discriminator was used to categorize the resultant pulses as originating from either alpha particle ionization or from beta particle ionization, Occasionally beta-produced ionizing events initiate voltage pulses which may be larger than the pulse height discriminator setting and may be recorded as alpha ionizing events.
This characteristic is referred to as "cross-talk".
The vendor's specifications clearly state that
"cross-talk" is limited to less than 1%,
which only means that less than 1% of beta-particle-initiated ionizing events will be recorded in the alpha channel.
In analyses of primary coolant samples, the presence of small quantities of short-lived nucl ides with high speci fic activi ties apparently resulted in unusually high cross-talk, resulting in the recording of what were considered to be alpha activity concentrations of sufficient magnitude to be of concern.
Such concentrations, if valid, could indicate the presence of defective or damaged fuel.
The licensee determined that when the counting system was operated at a lower detection voltage such that only alpha particles resulted in pulses large enough to be detected, analysis of primary coolant samples no longer indicated the presence of alpha activity, which confirmed the premise that alpha activity was not actually presen Licensee representatives stated that the operating mode of simultaneous counting of both alpha and beta particle activity would be discontinued and that in the future, each sample would be counted separately for alpha activity at the lower voltage setting and for beta activity at the higher voltage setting and that any alpha activity apparently detected at the higher voltage would be discounted unless it were also detected at the lower voltage setting.
The inspector considered the licensee's evaluation to be adequate and that the corrective measures were acceptable.
This matter is considered closed.
(Closed)
IFI 87-13-03 - Review corrective actions initiated by the licensee to achieve representative sampling by the turbine building drain monitor.
A plant change request on this matter was closed approximately July 15, 1987.
The original piping was laid out in such a manner as to permit the liquid in the sampling system to drain out; -without liquid present in the sampling line, the pump was not always able to promptly re-establish flow while liquid radwaste was being discharged, resulting in non-representative sampling.
The piping was re-routed to correct the drainage problem and the sampling pump was re-programmed to run only when the discharge pumps run.
The discharge pumps were wired so as to prevent starting if the sampling pump was not running.
The corrective measures appeared to be adequate to resolve the question of non-representative sampling.
This matter is considered closed.
(Closed)
IFI 87-13-04 Review delayed preoperational testing of evaporators in the secondary liquid radwaste system.
The inspector reviewed preoperational test results for the two 15 gpm evaporators in the secondary coolant radwaste processing system.
Initial tests had revealed excessive vibration during operation.
The vibration was remedied by installing retaining braces on the upper structure of the evaporator vapor body and installing a baffle plate in the lower section of the evaporator to reduce an excessive vortexing condition which was apparently causing the available recirculating pump head to drop to a point at which the pump started cavitating.
The preoperational tests on one evaporator were completed on May 6, 1987, and on the second evaporator on May 28, 1987.
The.
preoperational tests appeared to have been completed in accordance with the established procedures and had been reviewed and approved by plant management.
This matter is considered closed.
(Open)
IFI 87-13-05 Review delayed preop'erational testing of the radwaste solidification system.
This matter was in a "hold" status pending a licensee decision which was to be based on results of tests being conducted by another licensee.
This matter remains open pending licensee actio f.
(Open)
EFI 87-13-06 Review installation and testing of modified computer software in the radiation monitoring computer of the radiation monitoring system.
This item remains open pending completion of licensee action.
See Paragraph 7 of this report for additional details.
g.
(Closed)
LER 50-400/87-15, Turbine Building Vent Stack Radiation Monitor - Missed Sample.
The cause of this event was personnel error resulting from an incorrect log entry which caused operators to
,believe sampling was not required, On March 23, 1987, the Turbine Building vent stack radioactive gaseous effluent monitor was declared inoperable as the result of a
moisture problem.
Technical Specifications covering this condition required the collection and analysis of a
grab sample of the stack effluent every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Personnel concerned were counseled as to the need for correct log entries.
The under lying root cause of the need for special sampling was moi sture condensation in the continuous monitor serving the Turbine Building.
The moisture problem appeared to have been resolved, as discussed in Paragraph 3 of this inspection report.
h.
(Closed)
LER 50-400/87-16, Turbine Building Vent Stack Radiation Monitor (84724)
The conditions which led to this LER were associated with excessive moisture accumulation within the detector and sampling components of the monitor.
The licensee's resolution of the excessive moisture problem was discussed in Paragraph 3 of this inspection report.
This matter is considered close ATTACHMENT 1 EVALUATION,OF THE SHEARON HARRIS POST-ACCIDENT SAMPLING SYSTEM (PASS)
BY REGION II, USNRC Inspection 50-400/87-25 July 27-31, 1987 Principal Inspector:
P.
G. Stoddart Senior Radiation Specialist Radiological Effluents and. Chemistry Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards Region II U.
S. Nuclear Regulatory Commission
Criterion (1) The licensee shall have the capability to promptly obtain reactor coolant samples and containment atmosphere samples, The combined time allotted for sampling and analysis should be 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or less from the time a decision is made to take a sample.
(NUREG 0737 Criterion (1)).
The licensee demonstrated the ability to obtain a reactor coolant sample, transport the sample to an onsite laboratory facility, and complete the required analyses within the prescribed three hour period.
The licensee also demonstrated the abil'ity to obtain, transport, and analyse a
containment atmosphere sample within the three hour period.
The licensee meets this criterion.
Criterion (2) Reactor coolant and containment atmosphere sampling during post accident conditions shall not require an isolated auxiliary system such as the Residual Heat Removal (RHR)
System to be placed in operation in order to use the sampling system.
(NUREG 0737 Criterion (3)).
The reactor coolant sampling system and the containment atmosphere sampling system for post-accident conditions are both totally independent systems which do not require an auxiliary system to be placed into operation in order to use the sampling system.
The licensee meets this criterion.
Criterion (3)
The design basis for plant equipment for reactor coolant and containment atmosphere sampling and analysis must assume that it is possible to obtain and analyze a
sample without radiation exposures to any individual exceeding 5 rem whole body and 75 rem extremities.
The system is installed as per the design and the system installation has not resulted in an unreviewed safety question (NUREG 0737, Criterion (6)).
The reactor coolant and containment atmosphere post-accident sampling systems were designed with sufficient shielding and sample dilution systems to permit samples to be obtained and analysed without exceeding the specified exposure limits.
Documentation of dose calculation appears in licensee document TLR-RC-006, Rev.
0, dated May 7, 1987.
The systems were installed in accordance with the design and there, appeared to be no unresolved safety issues.
The licensee meets this criterion.
Criterion (4)
The licensee shall establish an onsite radiological analysis capability to provide quantification of noble gases, iodines and non volatile radionuclides in the reactor coolant and containment atmosphere, which may provide an indication of the degree of core damage.
(NUREG 0737 Criterion (2)
-(a)).
The range of activity that the equipment must be capable of measuring for a reactor coolant sample is from lpCi/ml to 10 Ci/ml total activity.
(NUREG 0737 Criterion (9)).
The results of the gamma spectral measurements should be accurate within a factor of 2 across the entire range.
(NUREG 0737 Criterion (10) and Attachment No.
1 to Generic Letter).
Samples of the reactor coolant and containment atmosphere were taken with the post-accident sampling systems and with the normal sampling system.
Analysis results are shown below:
LI UID de assed uCi/ml Radionuclide PASS Sample Corrected for 920: 1 dilution RCS Liquid Undiluted Na-24 Co-58 Nb-95 I-131 I-132 I-133 I-134 I-135 Cs-138 Ba-139 3.11 E-3 6.71 E-3 4.71 E-3 1.49 E-2 1.03 E-2 4.16 E"3 1.31 E-3 6.59 E"5 1.92 E-4 4.05 E-3 2.66 E-3 8.77 E-3 5.40 E-3 1.35 E-2
~ 84 E-3 Total 3.97 E-2 4.20 E"2
"Activity below detection limit Containment Atmos here Analysis of samples from containment taken by the normal sampling path and by the PASS showed radioactivity concentrations in both samples to be below detection limits.
The results of the PASS and normal sample RCS analyses showed the correlation to be well within the factor of two specified for this criterion.
The reactor containment samples taken with the PASS and with the normal containment sampling device did not contain sufficient activity to provide for correlation.
The licensee meets this criterion.
Criterion (5)
The licensee shall establish an onsite chemical analysis capability to provide quantification of hydrogen levels in the containment atmosphere (NUREG 0737 Criterion (2) (b)).
Accuracy, range, and sensitivity shall be adequate to'rovide pertinent data to describe the chemical status of the reactor coolant system (NUREG 0737 Criterion (10).
Range:
0-10 volume
% (Reg.
Guide 1.97, rev 3)
The licensee used a grab sample method, with onsite laboratory analysis, to quantify hydrogen levels in the containment atmosphere.
Sampling of containment atmosphere using the post accident gas sampling system was done on July 28, 1987.
A sample of containment atmosphere was taken on the same date using the normal sample system.
Analyses of both samples showed less than 0. 1% Hz.
The analysis method is capable of measuring in excess of
volume
% of Hz, as verified by preoperational test records.
The licensee meets this criterio Criterion (6)
The licensee shall establish an onsite chemical analysis capability to provide quantification of dissolved gases (e.g.
Hz) in reactor coolant.
Pressurized reactor coolant samples are not required if the licensee can quantify the amount, of dissolved gases with unpressurized samples.
Measuring total dissolved gases or hydrogen is adequate.
(NUREG 0737 Criterion (2)
(c) and (4)).
The recommended range for this analysis is 0-2000 cc (STP)/kg (Reg.
Guide 1.97, Rev. 3).
The recommended accuracy within this range is
+10%
between
and 2000 cc/kg but
+20%
between
and 2000 cc/kg is acceptable.
Below
cc/kg, the acceptable accuracy is
+
5.0 cc/kg.
(Attachment No.
1 to Generic Letter).
The licensee's in-line hydrogen monitor was not operational at the time of the inspection.
Repair parts needed were not available from the manufacturer.
A licensee representative stated that the original manufacturer was no longer operational in this equipment area and that no spare parts or technical support could be expected in the future.
The licensee had a grab sample capability which could be utilized to measure total dissolved gases pending re-establishment of on-line monitoring capability.
A PASS grab sample observed by the inspector indicated total gas at 4.97 cc/kg (STP).
The current value for normal sampling
.of reactor coolant was 26 cc/kg to 29.9 cc/kg.
The analytical results were not satisfactory.
The licensee does not meet this criterion.
Criterion (7)
The licensee shall establish chemical analysis capability to provide quantification of chloride in reactor coolant.
Plants have 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to perform the chloride analysis.
The chloride analysis does not have to be done onsite.
(NUREG 0737 Criterion (2)
and (5)).
The range of the analysis is 0-20 ppm (Reg.
Guide 1.97, Rev. 3).
The accuracy
+
10% for ppm Cl
+ 0.05 ppm for C1
<0.5 ppm.
(Attachment No.
1 to Generic Letter)
The licensee demonstrated the capability to obtain a
sample for chloride ion analysis.
However, the results of the analyses were not satisfactory, with results indicating the presence of chloride contamination of the samples.
Three diluted PASS RCS samples showed an average of 48 ppb of chloride.
The undiluted RCS sample was less than 5 ppb.
The licensee was not able to resolve the discrepancy prior to the end of this inspection.
The licensee does not meet this criterion.
Criterion (8)
The licensee shall establish an onsite chemical analysis capability to provide quantification of boron in reactor coolant.
(NUREG 0737 Criterion (2)
(c) and (7)).
Range:
PWRs 0-6000 ppm (Reg.
Guide 1.97 Rev 3)
Accuracy: '12% for Boron.
- NRR Position reference Inspection Report '50-400/87-13 The licensee measured the boron concentration of reactor coolant PASS samples with the following results.
Two analyses of each of three samples were made to
demonstrate the consi stency of the dilute boron analysi s procedure.
A fluoroborate method was used in the analysis.
Boron PASS 800 ppm 870 ppm 830 ppm 700 ppm 820 ppm 825 ppm RCS 825 ppm The NRR position on boron analysis accuracy, discussed in 50-400/87-13, is that an accuracy of +12% for diluted boron analysis is satisfactory.
If it is assumed that the RCS sample value of 825 ppm is precise, then the allowable deviation is 825+100 ppm.
Five of the six values above fall within the established limits.
The sixth value was 15. 1% below the RCS value.
With five out of six analyses meeting the accuracy limits, it is considered that the licensee meets this criterions Criterion (9) The following analysis are recommended but not required:
Dissolved Oxygen in reactor coolant (NUREG-0737 Criterion (4));
pH of the reactor coolant (Reg Guide 1.97, Rev. 3).
Range:
oxygen 0-20 ppm pH 1-13 (Regs Guide 1.97, Rev.
3)
Accuracy:
dissolved oxygen
+10% for 0.5 to 20 ppm
+0.05 ppm for <0.5 ppm pH
+0.3 pH units for 5 to
+0
~ 5 pH units for 1-5 and 9-13 (Attachment No.
1 to Generic Letter)
The licensee's analyses of primary coolant for dissolved oxygen and pH were as follows:-
pH PASS 0.029 ppm (29 ppb)
6.55 RCS
<0.5 ppm 6.42 The analyses were within the specified limits.
The licensee meets this criterion.
Criterion ( 10) If inline monitoring is used for any sampling and analytical capability specified in (4)
through (9)
above, the licensee shall provide backup sampling through grab samples and shall demonstrate the capability of analyzing the samples'stablished planning for analysis at offsite facilities is acceptable.
(NUREG 0737 Criterion (8)).
0'
The licensee demonstrated the capability to take and analyze both a diluted and undiluted reactor coolant sample.
The licensee, in addition, has a
standing contract with Babcock and Milcox to provide such analyses of grab samples as might be required under accident conditions, including both diluted and undiluted reactor coolant system samples and containment atmosphere samples.
The licensee meets this criterion.
Criterion (11) Provisions for purging sample lines, for reducing plateout in sample lines, for minimizing sample loss or distortion, for preve'nting blockage of sample lines by loose materials in the reactor coolant system or containment, for appropriate disposal of samples and fot flow restriction to limit the coolant loss from a rupture of the sample line should be made.
The ventilation exhaust from the sample station should be filtered at some point through charcoal absorbers and high efficiency particulate air (HEPA) filters.
(NUREG 0737 Criterion (11)).
The reactor coolant sample lines can be recirculated to assure representative sampling and can also be flushed with demineralized water to reduce radiation levels.
The containment air sample lines were re-worked to minimize the number of sharp bends and isolation valves and to provide a
more representative sample (See Inspection Report Nos. 50-400/85-44, 86-54, and 86-79).
The small diameter of the sampling lines functions to limit loss of coolant in the event of sample line rupture.
Ventilation exhaust from the PASS sampling cubicles is filtered through charcoal adsorbers and HEPA filters prior to release to the atmosphere.
The licensee meets this criterion.
Criterion (12)
The licensee shall have a formalized training program, written lesson plans, and documented hands-on training.
An adequate number of staff members are qualified to provide operation of the equipment under a protracted accident.
The licensee had an adequate training program featuring written lesson plans, training aid visuals, and hands-on training'raining was required on a
semi-annual basis for all individuals having job responsibilities or assignments involving the PASS.
Training was scheduled on a quarterly basis to assure conformance with training requirements and plant schedules.
All training was scheduled in advance, and attendance was documented in personnel training files and in plant training records.
At the time of the inspection, a
licensee representative stated that twelve chemistry technicians, foremen and supervisors were qualified in the operation of the PASS.
The licensee meets this criterion.
Criterion (13)
The licensee has operating procedures'hat have been prepared, reviewed and approved in accordance with station requirements.
The inspector reviewed PASS operating procedures and chemistry analytical procedures for PASS liquid and gaseous samples.
The procedures were adequate and were verified to be current versions as approved in accordance with Technical Specification requirements.
The licensee meets this criterio Criterion (14)
The licensee has a formal acceptance test for the equipment, appropriate calibration and recalibration requirements and a
periodic performance test for each analytical test required from the equipment.
The licensee performed formal acceptance tests for the PASS equipment.
Appropriate calibration and recalibration requirements appear in plant chemistry procedures and periodic performance tests were performed on a
quarterly basis in accordance with procedure (CRC-830, PASS quarterly Testing).
The licensee is committed by license condition to train PASS operating personnel semi-annually.
Training at the time of the inspection was being performed quarterly.
The licensee meets this criterion.