IR 05000413/1987027

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Insp Repts 50-413/87-27 & 50-414/87-27 on 870810-14.No Violations or Deviations Noted.Major Areas Inspected: Evaluation of post-accident Sampling sys(NUREG-0737,Item II.B.3) & Liquid & Gaseous Effluent Processing
ML20238A899
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 08/28/1987
From: Kahle J, Stoddart P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20238A861 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-413-87-27, 50-414-87-27, NUDOCS 8709090467
Download: ML20238A899 (14)


Text

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NUCLEAR REGULATORY COMM!SSION

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AEGION 11

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,101 M ARIFTTA STREET, N.W.

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SEP 0 2.1987,

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Report Nos.:

50-413/87-27 and 50-414/87-27 Licensee:

Duke' Power Company

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.4EP South Church Street e

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Charlotte, NC 28242 Docket Nos..

50-413 and 50-414 License Nos,:

NPF-35 and NPF-48 Facility Name:

Catawba 1 and 2 Inspection Conducted: August 10-14, 1987 Inspector r5 -

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7 7//f7 Approved by:

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Date/ Sign (d J. B( <ahle., Section' Chief Div on of Radiation Safety and Safeguards SUMMARY Scope:

This routine, announced inspection was. conducted in the areas of evaluation of post-accident sampling systems (NUREG-0737, Item II.B.3), liquid and gaseous effluent processing, treatment, and monitoring, and environmental monitoring.

Results: No violations or deviations were identified.

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • W. F. Beaver, Supervisor, Performance
  • R. Casier, Supervisor, Operations
  • R. H. Charest, Station Chemist R. Clemmens, Staff Health Physicist M. A. Cote, Licensing Engineer G. Courtney, Health Physics Supervisor

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R. DeShazo, Shift Supervisor, Health Physics J. Isaacson, Staff Health Physicist D. S. Lee, Staff Health Physicist P. N. McNamara, Staff Health Physicist 8. McNeill, Staff Chemist G. T. Mode, Staff Health Physicist M. Ruhe, Staff llealth Physicist

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0ther licensee employees contacted included engineers and technicians.

NRC Resident Inspector

"M.

Lesser

  • Attended exit interview 2.

Exit Interview (30703)

The inspection scope and findings were summarized on August 14, 1987, with those persons indicated in Paragraph I above.

The inspector described the areas inspected and discussed in detail the inspection findings listed below.

No dissenting comments were received from the licensee.

The evaluation of the post-accident liquid sampling system (PALSS) showed that the PALSS appeared to meet all applicable criteria of NUREG-0737.

The post-accident gaseous sampling system (PAGSS) was not operable primarily due to water contamination of the plant nitrogen system and could not be evaluated during this inspection.

The licensee did not identify as proprietary any. of the materici provided to or reviewed by the inspector during this inspection.

3.

Licensee Action on Previous Enforcement Matters (92701)

a.

(Closed) 50-413/85-55-08 (Unresolved Item) Clarification of Technical

Speci fication 3.3.3.6 and Table 3.3-10, Item 17.

This matter was l

identified by the resident inspector and was referred to this l

inspect.or for resolution.

Item 17 of Table 3.3-10 states, in effect,

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that only one of four steam line radiation monitors need be operable.

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The generic standard technical specification for this set of nonitors requires that all four monitors be operable; in the event one (or more) monitor (s) becomes inoperable, licensee would have to initiate an alternate method for monitoring within 72 hourc, and either restore the monitor (s) to operable status within 7 days or to subnit a special report to NRC within 14 days.

l At the time the Technical Specifications (TS) for Unit 1 were being prepared, the licensee took exception to the need for operability of all four steam if ne monitors (EMF-26, 27, 28, 29) and listed the

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I total number of channels as

"N. A." or "Not Applicable" and the minimum channels operable as "1", or only 1 out of 4 or,erable at any given time.

Only after all 4 monitors for a given unit were

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out-of-service would the action statement be applied.

The licensee's l

rationale for requesting the depar.ure from the standard technical I

specification was that other monitoring was available, e.g., the condenser air ejector monitor and the Steam Generator Water Sample Monitor (EMF-34).

NRR approved the licensee's version of this TS.

i Since the licensee was in conformance with the Technical l

Specification as issued, the inspector, after consultation with his supervisors, determined that no enforcement action should be taken at this time relative to the specifics of the TS 3.3.3.6 and Table 3.3-10, Item 17.

This unresolved item, UNR 85-55-08, is considered closed.

b.

(0 pen) Unresolved Item (UNR/URI) 50-413, 414/86-01-02, Sampling of radiciodine aerosols has been identified as being subject to substantial but unquantified losses in long sampling lines generic item applicable to all power reactors.

The licensee had initiated action to make sampling line iodine loss tests, including species determinations.

Procedures were prepared and testing materials and equipment were on hand.

A specific date for completion of testing had not been established as a result of other priority work Licensee indicated testing might be started in September (1987) but could not commit to a date.

This item remains open pending licensee action.

c.

(Closed) UNR/URI 50-413, 414/87-09-01, Review status of licensee commitment to complete modifica r wns necessary to return EMF-50 to operability status not later t July 31, 1987.

EMF-50 was the process radiation monitor on the gasecus radwaste treatment system and also functioned as the sampling point for sampling and analysis of waste gas decay tank contents.

A number of problems identified in Inspection Report Nos. 50-413, 414/87-09 were satisfactorily resolved.

Valve leakage frc., waste occay tanks into the common sampling header was corrected.

The sampling system was revised to bypass the common header and take samples from separate lines to each waste gas decay tank.

Pressure surges resulting from opening gaseous radwaste system discharge valves were corrected; however, a pressure

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r regulating valve, which had the function of holding pressure constant j.

in the detector operating chamber was found to not be maintaining a l

constant pressure, which resulted in negative swings of as much as l

10 psig from the desired value of 15 psig.

Since the detector was a l

beta-sensitive plastic scintillator inside the gas sample chamber, detector response was a function of chamber pressure and gas density.

The licensee identified the regulating valve (WG-159) causing the constant pressure problem and had instituted appropriate corrective measures.

As of the end date of the inspection, a completion date had not been established.

On the basis of discussion's with licensee representatives and review of supporting data, the inspector considered the subject matter of UNR/URI 87-09-01 to have been resolved satisfactorily and determined that the matter should be considered closed.

The question concerning the pressure regulating valve was considered

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to be a new and separate development and will be followed-up by the inspector at a later date.

(0pened) IFI 50-413, 414/87-27-02, Review licensee action to correct pressure swing problem associated with valve WG-159 in gaseous radwaste treatment system monitor EMF 50.

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4.

Post Accident Liquid Sampling System (PALSS) (84723)

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The Post Accident Liquid Sampling Systems (PALSS) installed at Catawba Nuclear Station, Units 1 and 2, was designed and fabricated by Duke Power Company to meet the criteria specified in NUREG-0737, Item II.B.3, and in follow-on directives of the NRC.

A separate but identical PALSS was

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installed for each reactor unit.

The Catawba version of the Duke PALSS L

was designed for the following analyses:

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I a.

Gross gamma activity in the reactor coolant system (RCS), as determined by gamma spectrum analysis of diluted RCS samples.

Such analyses should be accurate within a factor of two over the expected

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accident range for coolant radioactivity (1 uCi/gm to 10 Ci/gm).

b.

Boron in the reactor coolant system, as determined by analysis of diluted RCS sartples.

Accuracy of analysis was designed for i 10% of the RCS boron concentration as measured by normal sampling and analysis.

For boron concentration in the RCS below 500 ppm, the accuracy or tolerance band should remain at i 50 ppm.

(Note:

NRR now accepts i 12% for diluted sampling and analysis procedures.)

c.

Chlorides in the RCS, as measured in dilute samples.

For concentrations between 0.5 ppm and 20.0 ppm of chloride, the analysis should be accurate within i 10% of the measured value.

At concentrations below 0.5 ppm, the accuracy should remain at 1 0.c5 ppm.

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Dissolved gases or hydrogen, as measured in undiluted RCS samples.

For concentrations less than or equal to 50 cc/kg (at STP), the analysis should be accurate within i 10 cc/kg.

For concentrations between 50 cc/kg and 2,000 cc/kg, the analysis should be accurate within i 20L e.

Dissolved oxygen, as measured in undiluted RCS samples.

Analysis for dissolved oxygen is recommended by NUREG-0737 but is not a requirement.

The Duke design does not provide for dissolved oxygen measurement.

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pH, as measured in undiluted RCS samples.

For a pH between 5 and 9, the reading should be accurate within 10.3 pH units.

For all other ranges, the reading should be accurate within i 0.5 pH units.

The PALSS is maintained and operated under the Catawba Nuclear Station plant chemistry group.

The PALSS was evaluated against the eleven criteria set forth in NUREG-0737, Item II.B.3.

For clarity, certain of the e4ven criteria were re-organized into fourteen criteria for evaluatian purposes.

The inspector's evaluations of each of the fourteen criteria appear in the Attachment of this inspection report.

The PALSS for Unit I was evaluated on August 11-13, 1987.

Since Unit 2 was in an unscheduled shutdown at the time of the inspection, the licensee requested that the Unit 2 PALSS not be operated.

Since the PALSS installations were essentially identical, the inspector agreed.

Samples of reactor coolant were collected from Unit 1 using the Unit 1 PALSS; readings on in-line instrumentation for pH were obtained during the procedural steps leading to tne collection of the sample.

The sample was delivered to the chemistry laboratory for analysis in slightly under one hour.

The required analyses were completed within two hours, providing verification that sampling and analysis could be completed in under three hours elapsed time.

Analytical results, shown below, were correlated to current analyses of primary coolant obtained through the normal RCS sampling and analytical procedures.

Normal RCS Allowable Analysis PALSS Sample Difference Difference Acceptable?

pH 6. 4 6. 4

10.3 Yes Dissolved Hydrogen, cc/kg 15.6

6.4 i 10 Yes Boron, ppm 240 217

1 29 (12%)

Yes Chloride, ppb

<10 ppb

<10 ppb

1 50 ppb Yes Gross Gas Radioactivity, uCi/ml 0.593 0.896 0.303 0.483 Yes

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The PALSS had the capability of sampling primary coolant from "A" and "C" hot legs and for sampling of liquid from the containment sump.

No isolated auxiliary systems were required to be operated in order to obtain samples of primary coolant.

The PALSS 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 pcwer 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 the Attachment to this inspection report.

In the evaluation of the PALSS it was determined that two of the criteria were not applicable.

The licensee met all of the remaining 12 criteria.

The required analyses were performed readily and within the time and accuracy limits prescribed in NUREG-0737.

The gamma spectrum analysis of the primary coolant sample, correlated to the analysis of the normal RCS sample for the same time period, pas within 34% on total activity and individual radionuclides were within a factor of two for such nuclides as were detectable at the dilute concentrations presant in the PALSS diluted sample.

The criterion specified a factor of two as being acceptable.

Analysis of the RCS liquid sample for boron and chloride was performed in the station chemistry laboratory.

Results of the analyses were correlated to the results of the current RCS normal sample analyses for boron and chloride.

The. baron concentration in the PALSS sample was 240 ppm, as normalized to an undiluted sample.

The RCS normal sample for the period was 217 ppm.

The difference of 23 ppm (or 10.6%) was within the criterion limit of i 12% for dilute samples.

The chloride concentration in the PALSS sample was less than 10 ppb, as was the chloride concentration in the RCS normal sample.

A sample of the gas stripped from the liquid sample in the PALSS sampling process was analyzed for hydrogen as a measure of total dissolved gas.

The analysis result, by a gas chromatography process, was 15.6 cc/kg.

The RCS normal sample for the same period showed 22 cc/kg.

The PALSS value was within the acceptance limit of i 10 cc/kg at concentrations below 50 cc/kg.

The PALSS was designed with sufficient shielding and sample dilution systems to permit samples to be obtained and analyzed without exceeding

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radiation exposures of 5 rem whole body and 75 rem to the extremities.

The PALSS appeared to have been installed in accordance with the plant design and there appeared to be no unresolved safety issues.

On-line analysis was provided for pH.

Under Criterion 9, analysis of primary coolant for dissolved oxygen is recommended but is not required.

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Based on the licensee's experience at Oconee and McGuire with measurement of dissolved oxygen, the licensee elected not to provide for dissolved oxygen determination for the Catawb; PALSS.

The licensee's design as installed provided for liquid sampling wastes to be sent to a closed liquid radwaste collection system, in accordance with NUREG-0737 guidance.

In response to concerns that under accident conditions such wastes might preclude processing of collected wastes and might results in high radiation backgrounds within the auxiliary building, the licensee had initiated a plant change request to divert such waste to the containment sump, with modifications scheduled for the next refueling outage.

This matter was being tracked under IFI 86-01-01.

The licensee demonstrated the capability to take and analyze both a diluted and an undiluted RCS sample.

The licensee, in addition, had standing arrangements with the Duke Power Company's Applied Science Center to provide alternative post-accident analysis se.rvices.

Provisions were incorporated in the PALSS for purging sample lines to assure representative samp. ling and for clearing radioactive material from sampling if nes after sampling.

Plateout 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 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 closed radwaste retention tank.

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 te discharge through the plant vent.

The licensee had performed formal preoperational tests of the PALSS prior to startup of each reactor unit.

Tests involving simulated and/or artificial samples were conducted as part of the preoperational test programs.

Principal tests were performed as recorded in File Numbers CN-208.58, Validation Report for Catawba Nuclear Station Unit 1 PALSS, dated April 25, 1985, and under the same file number and title for Unit 2 PALSS, dated July 2, 1986.

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Summary The PALSS installed at Cutawba Nuclear Station was evaluated against the

l criteria of NUREG-0737, Item II.B.3, Post Accident Sampling, and of l

follow-on instructions.

The evaluation showed that the PALSS met 12 out of 12 applicable criteria.

Operational aspects of the licensee's PAGSS were not evaluated during this inspection.

A design review of the PAGSS is discussed in Paragraph 5 of this inspection report.

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(Closed) Inspector Followup Item 87-09-02, Evaluate post accident liquid sample system with reactor at full power.

5.

Post Accident Gaseous Sampling System (PAGSS) (84724)

The Post Accident Gaseous Sampling System installed at Catawba, Units 1 and 2, was. designed and fabricated by Duke Power Company to meet the criteria specifieu in NUREG-0737, Item 11.B.3, and in follow-on directives of the NRC.

A separate but identical PAGSS was installed for each reactor unit.

The Catawba version of the Duke PAGSS was designed for the following analyses:

a.

Radioactive gases in containment atmosphere.

b.

Radioactive particulate and iodine aerosols in containment atmosphere.

c.

Hydrogen in containment atmosphere.

The PAGSS was designed with sufficient shielding and sample dilution systems to permit gas samples to be obtained and analyzed without exceeding radiation exposures of 5 rem whole body and 75 rem to the extremities.

The PAGSS appeared to have been installed in accordance with the design and there appeared to be no unresolved safety issues.

The licensee had performed formal preoperational tests of the PAGSS prior to startup of each reactor unit.

Tests involving non-radioactive gases and hydrogen were conducted as part of the preoperational test programs.

A problem identified in the quarterly system tests conducted in March 1987 (Station Problem Report (SPR) dated 3/19/87) identified substantial quantities of water in the station bulk nitrogen system.

The water contamination made the PAGSS essentially inoperable because hydrogen could no longer be accurately sampled and ccatainment atmosphere particulate and iodine aerosol samples were similarly affected.

Plant Variation Notices (VNs) have been prepared to correct the water problem by modifying the gas supplied to the PAGSS.

The necessary modifications require new fittings and vacuum gauges.

New fittings are scheduled for delivery in January 1988 and vacuum gauges in February 1988.

An addition system modification involving a thiosulfate supply system has been completed.

Licensee representatives stated that in the event of an emergency, a bottled nitrogen supply system could be temporarily installed in a short (but

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unspecified) time.

To maintain training and qualification status of PAGSS operators, the PAGSS was operated for training purposes but samples were not analyzed because of excess water content.

The licensee was notified that the matter would be followed as an inspector followup item and that the PAGSS would be separately evaluated-at a later date.

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(0pened)~ Inspector Followup ltem (IFI) 50-413, 414/87-27-01, Evaluate Post Accident Gaseous Sampling System (PAGSS) following correction of water-contaminated nitrogen supply.

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Status of Inspector Followup Items (92701)

a.

(Closed) T2500/22, IFI, Collection of collocated -TLD measurement results.

Results of licensee environmental TLD measurement results for calendar year 1986 were obtained from the licensee during i

inspection 87-09.

The inspector obtained TLD measurement results from the licensee for the first 6 months of 1987.

Both sets of data will be forwarded to Region I under separate cover.

This matter is considered closed.

b.

(0 pen) IFI 86-01-01, Review modification to PALSS routing undiluted i

sample residues to containment sump.

Licensee plant change requests were issued to make the necessary changes at the next. refueling outage for each unit.

Closure of this. item awaits licensee action, c.

(Closed) IFI 86-23-02, Improved procedure detail regarding background and sensitivity limits of effluent monitors.

This matter.was

. reviewed during inspection 50-413, 414/87-09 (April 1987) and licensee action was found at that time to be complete except for formal issue of an ap Procedure HP/0/B/1004/ proved procedure on gaseous effluent monitoring.

05, dated August 6,1987, was reviewed by the inspector and was determined to be adequate.

The procedure had been reviewed and approved in accordance with plant requirements.

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matter is considered closed.

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d.

(Closed) IFI 87-09-02, Evaluate Post-Accident Liquid Sample System

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with reactor at full power.

This matter was discussed in detail i

under Paragraph 4 of thi. report.

This matter is considered closed.

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ATTACHMENT

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))

Licensee declined to demonstrate PAGSS, (Post-Accident Gaseous Sampling System) due to the presence of large quantities of water in plant nitrogen systems and also to the need to replace vacuum gauge now sized at -25" Hg with one going to -30" Hg.

Licensee does not meet this criterion for containment atmosphere samples.

The evaluation of the post accident liquid sampling system (PALSS) showed that the PALSS met this criterion for reactor coolant samples.

  • Criterion (2) - Reactor coolant and containment atmosphere sampling during post accident conditions shall not require an isolated auxiliary system to be placed in operation in order to use the sampling system (NUREG-0737, Criterion (3))

The RCS sampling system did not require the use of an isolated auxiliary system to be place in operation in order to use the tampling system.

The design of the containment atmosphere sampling system did not require the use of an isolated auxiliary system to be placed in operation in order to use the sampling system.

While this system was not demonstrated during this evaluation, a review of the design showed that the system 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 (NUREG-0737, Criterion (6)).

The system is installed as per the design and the system installation has not resulted in an unreviewed safety question.

The licensee meets this criterion.

Criterion (4) - The licensee shall establish an onsite radiological analysis capability to provide quantification of noble gases, iodines and

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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 i

must be capable of measuring for a reactor coolant sample is from 1 uCi/g L

to 10 Ci/g total activity (NUREG-0737, Criterion (9)).

The results of the

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gamma spectral measurements should be accurate within a factor of 2 across I

the entire range (NUREG-0737, Criterion (10) and Attachment No. I to

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Generic Letter).

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The licensee demonstrated the capability to meet this criterion for reactor coolant sampling.

The licensee declined to demonstrate the capability to meet this criterion for containment atmosphere sampling.

  • 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 provide pertinent data to describe the chemical status of the reactor coolant system (NUREG-0737,

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Criterion (10)).

Range 0-10 volume %

(Reg. Guide 1.97, Rev. 3)

The licensee did not demonstrate that the containment atmosphere could be sampled for hydrogen.

This was attributed to water contamination of the plant nitrogen system which is essential to the sampling process.

The licensee is working toward correction of the problem.

The licensee does not meet this criteria.

  • Criterion (6) - The licensee shall establish an on..

chemical analysis capability to provide quantification of dissolved gases (e.g., H ) in reactor coolant.

Pressurized reactor coolant samples are not requ$ red 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 i

analysis is 0-2000 cc (STP) (Reg. Guide 1.97, Rev. 3).

The accuracy within this range is f20% between 50 and 2000 cc/kg below 50 cc/kg the

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tolerance is i 10.0 cc/kg.

(Attachment No. I to Generic Letter).

The licensee demonstrated the capability to meet this criterion by sampling and analysis of reactor coolant and by demonstrating the capability to analyze calibrated samples.

The licensee meets this criterion.

  • Criterion (7) - The licensee shall establish chemical analysis capability to provide quantification of chloride in reactor coolant.

BWRs on sea or brackish water sites, and plants which use sea or brackish water in essential heat exchangers that have only single barrier protection between

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the reactor coolant are required to analyze chloride within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

All other 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 of 0-20 ppm (Reg. Guide 1.97, Rev. 3).

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The accuracy i 10% for 0.5 - 20 ppm Cl 1 0.05 ppm for C1 less than 0.5 ppm (Attachment No. I to Generic Letter)

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The licensee meets this criterion.

  • Criterion (8) - The licensee shall establish an onsite chemical analysis capability to provide quantification of boron in reactor coolant.

BWRs are to have the capability to perform boron analysis but they do not have

~to' do so unless boron was injected (NUREG-0737, Criterion (2)(c) and (7)).

r Range:

BWRs 0-1000 ppm PWRs 0-6000 ppm (Reg. Guide 1.97, Rev. 3)

Accuracy: t 12% for B greater than 1000 ppm i 120 ppm for B less than 1000 ppm

.(NRR Position)

The licensee meets this criterion.

' Criterion (9) - The following analyses are recommended but not required:

Dissolved oxygen in reactor coolant (NUREG-0737, Criterion (4)) reactor coolant (Reg. Guide 1.97, Rev. 3).

Range:

oxygen 0-20 ppm pH 1-13 (Reg. Guide 1.97, Rev. 3)

Accuracy:

dissolved oxygen i 10% for 0.5 to 20 ppm dissolved oxygen * 0.05. ppm for less than 0.5 ppm pH i 0.3 pH units for 5 to 9 pH i 0.5 pH units for 1-5 and 9-13 (Attachment No.- 1 to' Generic Letter)

The licensee does not choose to sample and analyze for dissolved oxygen.

The licensee meets the criterion for pH measurement.

  • Criterion (10) - If in-line monitoring is used for any sampling and analytical capability specified in (4) above, the licensee shall provide backup sampling through grab samples and shall demonstrate the capability of analyzing the samples.

Established planning for analysis at offsite

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facilities is acceptable (NUREG-0737, Criterion (8)).

The licensee does not provide in-line monitoring for any analysis required under 4.. above.

Not applicable.

(The only on-line analysis performed in reactor coolant sampling 'is pH, which is not a requirement and is not considered to require backup analysis.)

Criterion (11)

Provisions for purging sample lines, for reducing

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plateout 'in sample lines, for minimizing sample loss or distortion, for preventing blockage of sample lines by loose material in the reactor coolant system or containment, for appropriate disposal of samples and for flow restriction to limit the coolant loss from a rupture of the sample line should be made.

The ventilation exhaust from the sample station

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should be filtered at some point through charcoal absorbers and high efficiency particulate air (HEPA) filters (NUREG-0737, Criterion (11)).

The licensee has made provisions for the above conditions.

In addition, the licensee has committed to return sample flush material and liquid residues to the containment sump in the. event of an accident.

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.

At the time of _the evaluation, two chemistry staff personnel and six chemistry technicians were qualified on the PALSS system.

The PAGSS was not evaluated against the criterion.

  • Criterion (13) - The licensee has operating procedures that have been prepared, reviewed, and approved in accordance with station requirements.

.The licensee has provided prepared, reviewed, and approved appropriate operating procedures.

-The licensee meets this criterion.

  • 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 meets this criterion.

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