ML17298A937
| ML17298A937 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/21/1984 |
| From: | Knighton G Office of Nuclear Reactor Regulation |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8404120022 | |
| Download: ML17298A937 (9) | |
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Docket Nos 50 528 50 52g PAP 2 1 1984 and 50-530 Mr. E.
E.
Van Brunt, Jr.
Vice President - Nuclear Projects Arizona Public Service Company Post Office Box 21666 Phoenix, Arizona 85036 Dear h1r.
Van Brunt:
Subject:
Kaman Instrumentation for Palo Verde DISTRIBUTION A'Docket-File-50=528/529/530 NRC PDR Local PDR PRC System NSIC LB¹3 Reading JLee EALicitra OELD, Attorney ACRS (16)
EJordan NGrace As a result of the staff's further review of the high range noble gas monitors (Kaman Instrumentation) for Palo Verde, we have determined that the instrumen-tation installed at Palo Verde does not meet the requirements of Item II.F.l of NUREG-0737.
The staff's evaluation is provided as Enclosure 1.
We request that you reassess your design for the high range noble gas monitors and that you inform us of how you will correct the deficiency noted in the enclosed evaluation.
In addition, we ask that you advise us within two weeks of receipt of this letter as to when you plan to respond to this request.
If you have any questions regarding this request, you should contact Manny Licitra, the Licensing Project Manager.
Sincerely,
Enclosure:
As stated QngIMl affined bIt:
Qgr>BIO VLt(n)aha George W. Knighton, Chief Licensing Branch No.
3 Division of Licensing cc:
See next page EALicitva/yt 8
ghton 3//f/84
/P/84 84O43~OO88 84O82t PDR ADOCK 05000528 PDR
Palo Verde Mr. E.
E.
Van Brunt, Jr.
Vice President - Nuclear Projects Arizona Public Service Company P. 0.
Box 21666
- Phoenix, Arizona 85036 Arthur C. Gehr, Esq.
Snell 5 Wilmer 3100 Valley Center
- Phoenix, Arizona 85073 Mr. James H. Flenner, Chief Counsel Arizona Corporation Commission 1200 West Washington Phoenix, Arizona 85007 Charles R. Kocher, Esq. Assistant Counsel James A. Boeletto, Esq.
Southern California Edison Company P. 0.
Box 800
- Rosemead, California 91770 Ms. Margaret Walker Deputy Director of Energy Programs Economic Planning and Development Office 1700 West Washington Phoenix, Arizona 85007 Kenneth Berlin, Esq.
Winston
& Strawn Suite 500 2550 H Street, NW Washington, DC 20037 Ms. Lynne Bernabei Government Accountabilitv Project of the Institute ~or Policy Studies 1901 gue Street, NW Washington, DC 20009 Mr. Rand L. Greenfield Assistant Attorney General Bataan Memorial Building Santa Fe, New Mexico 87503 Resident Inspector Palo Verde/NPS U.S. Nuclear Regulatory Commission P.
O.
Box 21324
- Phoenix, Arizona 85001 Ms. Patricia Lee Hourihan 6413 S. 26th Street
- Phoenix, Arizona 85040 Regional Administrator - Region V
U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596
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POST-IMPLEMENTATION REVIEW OF NOBLE GAS EFFLUENT MONITORS Tb'NSTALLED AT PALO VERDE NUCLEAR GENERATING STATION; UNIT NO.
1 INTRODUCTION Subsequent to the TMI-2 incident, the need was recognized for high range noble gas effluent monitors to detect and measure concentrations of noble gas fission products in plant gaseous effluents during and following an accident.
Criteria for an acceptable monitoring system design are set out in NUREG-0737, Item II.F.1, Attachment 1,
and Regulatory Guide 1.97, Revision 2.
To meet these requirements, the applicant installed high range noble gas effluent monitors furnished by Kaman Instrumentation Company (Model KDGM-ER detector in model KSG-HRH sampler) in potential gaseous release points at Palo Verde, Unit No.
1 (plant vent, main condenser/gland seal
- exhaust, and fuel building vent).
These high range noble gas monitors are described in detail in Section 11.5 of Palo Verde FSAR and in 4
Section II.F.1 of Palo Verde Lessons Learned Implementation Report, dated May 24, 1982.
The applicant stated in these sections that high range noble gas monitors meet the requirements set out in NUREG-0737, Item II.F.l, Attachment 1,
and Regulatory Guide 1.97, Revision 2.
Meanwhile, the vendor (Kaman Instrumentation Company) learned that his monitors have an extreme photon energy dependence which makes them unable to detect or measure noble gas concentrations of 10 uCi/cc for photon energy 5
above 80 Kev.
The Kaman monitors are designed to meet the required 10 uCi/cc noble gas concentration based on Xe-133 photon energy of 80 Kev.
5 Consequently, the vendor notified all their customers, including Palo Verde,
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through Bechtel Power Corporation, of the extreme photon energy dependence characteristics of the monitors and proposed the monitor design modifications to extend the range of detectable and measurable noble gas concentrations above 80 Kev photon energy.
During the course of preoperational inspection by Region V at Palo Verde, Unit No.
1, it was learned that the applicant is using the Kaman instrumenta-tion to meet the requirements of II.F.1-1 of NUREG-0737.
It was confirmed that (1) the applicant has not incorporated the design change proposed by the vendor, and (2) the vendor's calibration data has shown the high range of the effluent monitors to be extremely energy dependent.
Therefore, pursuant to the provisons of H.
R. Denton's March 15, 1982 memorandum on technical assistance to the Regions, Region V requested that NRR review the technical adequacy of the high range noble gas effluent monitors installed at Palo Verde, Unit No. 1, to meet the requirements specified in NUREG-0737, Item II.F.1, Attachment 1, for acceptance.
EVALUATION The design basis maximum ranges for high range noble gas effluent monitors stated in the Palo Verde FSAR (10 uCi/cc) are based on isotopic calibration using high concentrations of low energy emitting (80 Kev) Xe-133 gas.
During our licensing review, the detailed calibration procedures were not questioned or reviewed si nce the applicant stated i n the FSAR that the monitors meet the requi rements set out in NUREG-0737 and Regulatory Guide 1.97, Revision 2.
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3 However, Regulatory Guide 1.97, Revision 2, clearly states that noble gas effluent concentrations may be expressed in terms of Xe-133 equivalents or in terms of any noble gas nuclide(s) but the monitors should be capable of detecting and measuring effluent concentrations with compositions ranging from fresh equilibrium noble gas fiss'ion product mixtures to 10-day-old mixtures, with overall system accuracies within a factor of 2.
The staff position and purpose of the high range effluent noble gas monitors are to detect and measure concentrations of noble gas fission products in plant gaseous effluents during and following an accident, and NUREG-0737, Item II.F.1, Table II.F.1-1, further stated that the decay of noble gases after an accident, as well as the distribution of noble gase
- changes, should be taken into account in the design of the monitors.
The staff obtained from the vendor the gamma energy response characteristic curves for the high range noble gas effluent monitor installed at Palo Verde, Unit No.
1 (Attachment 1),
and that of the modified and proposed by the vendor (Attachment 2).
The installed monitor energy response characteristics reveal an extreme energy dependency of approximately four decades (40 to 1.3 x 10 cpm per uCi/cc) over the 80 Kev to 3 Mev gamma 5
energy range.
The fresh equilibrium noble gas fission product mixtures with higher energy gamma emissions would saturate the detector during the initial hours following an accident'ausing no indication on instrument readouts.
The maximu~ noble gas concentrations that the installed monitor could detect and measure without the possibility of monitor saturation at various photon
energy levels can be obtained by multiplying the ratios of two detector (installed and modified) efficiencies at a given photon energy with the maximum design noble gas concentration of 10 uCi/cc.
For example, at a
5 photon energy of 0.7 Mev per disintegration, the maximum noble gas concentration detectable and measurable is only 800 uCi/cc.
Therefore, contrary to the statements in the FSAR, the monitors do not meet the requirements set out in NUREG-0737, Item II.F.1, Attachment 1 or range specification in Regulatory Guide 1.97, Revision 2.
On the other hand, the modified detector described and proposed by the vendor (Attachment
- 2) has the energy response characteristics of a nearly linear 1.5 decade (35 to 650 cpm per uCi/cc) energy dependency over the same gamma energy range and meets the above requirements, and therefore would be acceptable.
CONCLUSION Based on the foregoing evaluation, we find that the high range noble gas effluent monitors, as built and installed at Palo Verde, Unit No.
1, are not capable of detecting and measuring higher concentrations of all noble gas fission products in plant gaseous effluents during and following an
- accident, as specified in NUREG-0737, Item II.F.1, Attachment 1,
and Regulatory Guide 1.97, Revision 2.
Therefore, the monitors are not acceptable.
- Also, we find that the monitors with modified detector and sampler design by the vendor, as described and proposed in a letter to D. Gibson of Bechtel Power Corporation (Palo Verde Project) from D. Piraino
of Kaman Instrumentation, dated November 9, 1983, are capable of meeting the requirements set out in NUREG-0737, Item II.F.l, Attachment 1,
and Regulatory Guide 1.97, Revision 2, specifications.
Therefore, the modified monitors woul d be acceptable.
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