ML17298B587
| ML17298B587 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/05/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM ANPP-31333-EEVB, NUDOCS 8412070164 | |
| Download: ML17298B587 (24) | |
Text
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REGULATORY'TAFORMATION DISTRIBUTION SYMEM (RIOS)
ACCESSION NBR'8012070160 DOC ~ DATE: 84/12/05 NOTARIZED:, YES, DOCKET FACIL:STN 50 528 Palo Verde-Nuclear. Station~
Uni,t i~ Ar)zona Publi 05000528
'STN, SO 529 Pa]o Verde Nuclear St:ationi Unit "2~ Ar3zona Publ i 05000S29
-STN 50 530 Palo Verde Nuclear. Stations Unit >>3i Arizona Publi OS000530 AUTH;NAME',
AUTHOR AFFILIATION VAN BRUNTiE;E>>,"
Arizona: Public,Ser vice Co".
'RFCIP ~ NAME" RECIPIENT, AFFILIATION KNIGHTON g G ~ ItI ~
Licensing Branch "3 SUBJECT!: Requests;.sch'edular exemption from 840927 commitment to use backup samplin'g to meet -requirements of'UREG 0737'tep II'~3>> be grantedzprior to'xceeding 5$ peweridue'o mods required on post accident'sampling sys Action plan encl'I'STRIBUT'ION CODE: B001D>>COPIES -RECEIVED:LTR~
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TITI.E: Licensing Submittal:
PSAR/FSAR Amdts -L Related Carr espondence NOTES:Standardized plant ~
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Arizona Public Service Company ANPP-31333-EEVB/t&Q/HAJ December 5, 1984 Director of Nuclear Reactor Regulation Attention:
Mr. George W. Knighton, Chief Licensing Branch No.
3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.
C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Docket Nos.
STN 50-528/529/530 Post Accident Sampling System (PASS)
Pile:
84-056-026; G.1.01.10
References:
(1)
Letter to G.W. Knighton, NRC, from E.E.
Van Brunt, Jr.,
ANPP dated September 27, 1984 (ANPP-30593).
Subject:
Response
to Post Accident Sampling System (PASS)
License Conditions.
Dear Mr. Knighton:
Reference (1) submitted our response to the five (5) stated license con-ditions contained in the PVNGS Safety Evaluation
- Report, NUREG-0857; (Item II.B.3) dated
- November, 1981.
In response to License Condition 2; ANPP provided Tables 1 and 2 (see pages 3 and 4 of Reference (1)) which describes the PVNGS Post Accident Sampling System (PASS) Inline and Back-up Grab Sample analyses.
We had committed to use backup sampling to meet the requirements of NUREG-0737, Item II.B.3 and Regulatory Guide 1.97, Revision 2,
during the interim period prior to achieving operational status of the PASS.
Since the submittal of Reference (1),
we have completed additional demon-stration testing on PASS.
The results of the site demonstration testing program have disclosed that further modifications to PASS are required to provide the backup sampling capability meeting the requirements as men-tioned above.
These modifications are expected to be complete by April 15, 1985 or prior to exceeding 5% power.
We request that a
schedular exemption from our previous commitment, Reference (1), be granted
- since, prior to exceeding 5% power, only small quantities of radioactive inventory will exist in the reactor coolant system and therefore the health and safety of the public will not be affected.
The modifications to PASS for backup sampling capability and subsequent testing is expected to be completed by April 15,
- 1985, or prior to exceeding 5%
- power, thus providing backup sampling capability meeting the requirements of NUREG-0737, Item II.B.3 and Regulatory Guide 1.97, Revision 2.
8412070164 841205 j
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Hr. George W. Knighton Post Accident Sampling System Pane 2
ANPP-31333 A description of the history, problems encountered and the modifications necessary to provide the backup sampling capability for the PVNGS PASS is provided in Attachment A.
Attached also are Tables A
and B.
Table A,
previously Table 2
of Reference (1), describes the PASS inl1ne instruments.
The PASS inline instruments have been tested functional but will not be calibrated until the completion of modifications to the equipment (as described in Attachment A) and subsequent
- testing, expected to be completed prior to restart following the first refueling outage of Unit
- f31, currently scheduled for October 1987.
Table B,
previously Table 1 of Reference (1),
describes the "Backup" sample capabil1ty which will be available after PASS is modified for backup sampling and retested; thi,s 1s expected to be completed by April 15,
- 1985, or prior to exceeding 5% power.
Prior to having the inline system
- operable, the primary method for performing Post Accident Sampling activities will be remote grab sampling.
Additionally, per the request of the PVNGS NRC regional inspector, Table B provides a clarificat1on to better describe the PVNGS capability to obtain and analyze the "Backup" samples listed previously in Table 1 of Reference (1).
If you have any questions or require additional information, please contact me.
Very truly yours, XXV ~/~~
E. E.
Van Brunt, Jr.
APS Vice President Nuclear Production ANPP Project Director EEVB/NLH/MAJ/JBC/RLJ/jle Attachment cc:
A. C. Gehr
'with E. A. Licitra (with R.
P.
Zimmerman (with J. [Gng (with attachments) attachments) attachments) attachments)
0 l
ANPP-31333 STATE OP ARIZONA
)
) ss.
COUNTY OP kfARICOPA)
I, Donald B. Karner, represent that I am Assistant Vice President, Nuclear Production of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its
- contents, and that to the best of my knowledge and belief, the statements made therein are true.
Donald B. Karner Sworn to before me this~I.
day o
I n
My Comm%'ssion:Expires:
F M
Commlsslon "IresA rll6 1987 1984.
Notary Public
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Mr. George W. Knighton Post Accident Sampling System Page 3
ANPP-31333 bcc:
Woods Karner Bynum Kirby Zeringue Allen Houchen Helman Rogers Page Cederquist Frost Ferguson Jenkins Quinn Quan Jones Rowland Winsor Canady Gross Smith Cole Scott
- Warren, Johnson Egebrecht G.
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25 4053 4056 6010 6080 4080 6425 6238 4057 4057 4057 4053 6254 6177 6088 6080 6080 6281
. 6431 6544 6238
- 4057, BPC/Downey BPC/Downey BPC/Downey BgS/Dotpey, (all with attachments) 0069K/0004K
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ANPP-31333 Attachment A
Page 1 of 3 PASS ACTION PLAN I.
GOAL The current Post Accident Sampling System (PASS) was designed as an automated in-line sampling and monitoring system to satisfy the requirements established in NUREG-0737 and Regulatory Guide 1.97, with additional capability for augmentation of the plant nuclear sampl'ing system.
The basic design provided for in-line monitoring and the, capability of extracting grab samples for backup analyses as required in NUREG-0737.
II.
FACTORY DEMONSTRATION TESTING During the summer of 1982, at the Vendor's facilities, the PASS was demonstrated satisfactorily for the given system operating para-meters (i.e.
low pressure and demineralized water).
The system was operated at 30 psia with clean water and air.
Only 50% of the chemical parameters were response checked because of the lack of analytical equipment and/or standards.
This testing, while not indicative of actual system conditions, did establish that the system components were functional.
Upon completion of the Factory Demonstration
- Test, the system was shipped to the PVNGS site.
During shipment of the PASS components, a
major component was damaged during off loading at the PVNGS site and was returned to the Vendor for repair.
Because the repair and reshipment required approximately four months, it was determined that sufficient time was not available to complete installation and complete component prerequisite testing prior to the Unit 81 Hot Functional Test.
Installation of PASS began in December 1982 and was completed in August 1983.
III.
SITE ACCEPTANCE TESTING (SAT)
Following installation of
- PASS, the entire system was to be fully tested under actual system operating conditions with the reactor coolant system at normal operating temperatures and pressures during the Unit //1 Reactor Coolant Pump Demonstration Test in July 1984.
The initial testing phase indicated conclusively that the system would not perform in the area of sample conditioning.
ANPP was prepared to extend the Reactor Coolant Pump Demonstration Test to accomplish the necessary modification and retesting. 'he valve module was modified to provide adequate temperature reduction and proper regulation of high pressure liquid samples in order to
Attachment A
Page 2 of 3 continue testing.
Additionally, the remote grab samples that the system provided were of inadequate size to perform the "Backup" analyses as required by NUREG-0737.
The sample size problem was addressed by the Vendor onsite during the SAT, but the system still did not supply sufficient sample quantity.
Extensive modifications were deemed to be necessary prior to a successful completion of the SAT.
This testing was restarted in September 1984.
Continued testing of the PASS resulted in the discovery of addi-tional failures and deviations in the 1) gas sampling
- system, 2) gaseous dilution
- system, 3) liquid dilution and recirculhtion system and 4) gas and liquid flushing and sump return system.
Many of the problems which occurred with the hardware portion of the system had been previously identified as potential problems as early as September 1983 by the CRACS/PASS Task Force, but were not verified until testing at normal system operating ~temperature and pressure.'V.
SUBSEQUENT ACTIONS
>Je are continuing to repair the aforementioned failures. 'e have reviewed the progress, found Vendor progress to be unsatisfactory and developed a plan for satisfying the requirements established in NUREG-0737 and Regulatory Guide 1.97.
This plan was implemented in mid November 1984
- and, when complete, will provide full PASS capa-bilities.
As NUREG"0737 requires backup sampling and analyses for installed in-line analysis equipment, we are currently reviewing, revising and generating the Chemistry procedures necessary for obtaining, transporting
.and analyzing the samples that will be available.
These procedures incorporate provisions for handling undiluted samples while maintaining dose commitments within the requirements of,, GDC-19, and are expected to be,'in place (approved),
personnel trained and qualified by April 15,
- 1985, or prior to exceeding 5%
power.
I Phile defining the scope and schedules for these modifications, schedule dates have been determined for the completion of design, fabrication, installation and testing of the modified PASS to pro-vide backup sampling capability by April 15,
- 1985, or prior to exceeding 5% power.
V.
ACTION PLAN The planned action is to proceed with an integrated method to modify PASS to provide manual capability of sampling and analysis to meet the requirements of NUREG-0737 and Regulatory Guide 1.97.
1'l I
l1 I
Attachment,A Page 3 of 3
By April 15,
- 1985, or prior to exceeding 5% power PASS is expected to be available to demonstrate the capability to promptly obtain reactor coolant and containment atmosphere samples in an accident chemistry and radiation environment.
The PASS will utilize grab sample methodology of depressurized reactor coolant for the para-meters except dissolved
- gases, and will provide dissolved gases capability with a modified remote grab sampler.
The plan also includes modification of the PASS to allow more accurate gaseous and liquid sampling with system maintenance capa-bility.
These enhancements will be incorporated into the inline portion of PASS during the first Unit 81 refueling outage expected in October 1987.
When these ienhancements are completed, the pri-mary method of sample capture and analysis will include the PASS inline instrumentation, with the secondary method to include remote grab samples.
0 Et ll
ION SPECIES LIQUID SAMPLE TABLE A NOR%6 PASS INLINE INSTRUMENTS SENSITIVITY ACCURACY
"'ALIBRATION Page 1 of 1
POST MODIFICATION CAPABILITY 1-13 Conductivity 0-10~ mhos/cm 7
Chlor ide Ion 0-20 ppm Dissolved Oxygen 0-20 ppm 2,
12 1000~ mhos/cm
~2 ppm
~ 1 ppm
+.5pH Note 1
+2X10~mhos/cm 4'o4 ppm
++05 ppm P Zlppm; +55 of Reading Q)l ppm 74CH-9ZZ90 Rev.1 74CH-9ZZ90 Rev.
1 74CH-9ZZ90 Rev.
1 74CH-9ZZ90 Rev.
1 Note 1
Note 3 Note 2 Note 3 Note 12 Note 12 Note 12 Note 12 Total Dissolved Gas (and Dissolved Hydrogen)
Radio-Isotope (liquid) 100-2000 cc/kg 100 cc/kg 0-6000 ppm 100 ppm
+5>> of Reading
+5p 10 QCi/cc 10 W Ci/cc Factor of 2 to 10 Ci/cc 74CH9ZZ90 Rev.
1 7401-9ZZ90 Rev.
1 74CH-9ZZ90 Rev.
1 Note 2 Note 4 Note 2 Note 12 Note 12 Note 12 Gaseous Hydrogen (also used for off-gas analysis) 1$ H (in 52) 1502
+.75$ H2 Tin N2)
+.75$ 02 74CH-9ZZ90 Rev.
1 74CH-9ZZ90 Rev.
1 Note 3 Note 3 Note 12 Note 12 Radio-Isotope (Gaseous) 10 3~ ((i/cc to 10 Ci/cc 10 ~Ci/cc Factor of 2 74CH-9ZZ90 Rev.
1 Note 4 Note 12 NOTE - The above mentioned instruments comply with R.G. 1.97 Rev. 2
0
Page 1 of 2 TABLE B PASS BAG(UP GRAB SAMPLE (HIGH RADIATION FIELD)
IOiV SPECIES SENSITIVITY CURREt1T PROCEDURE CALIBRATION CAPABILITY LIQUID SAMPLE 1-13
+0.3 pH 74%-9ZZ35 Rev. 2 EPIP-27 N/A
+104 of Reading 74CH-9ZZ65 cc/kg EPIP-27 N/A
+105 of Reading 74CH-9ZZ65 EPIP-27 N/A
.02-20 ppm Autotitra-2 ppm
~ metric 2 - 6000ppm
+0.05 ppm 6(
.5< p Rev.
1
+104 6 ) 0.5ppm EPIP-27
+5/ of Reading 74CH-9ZZ06 Rev.2 74%-9ZZ72 EPIP-27 Note 3 Note 3
- Complete, System Operable Note 8
- Canplete, System Operable Note 10 Total Dissolved Gas 50 to 2000 50 cc/kg
+ 20$
cc/kg Note 22 74CH-9XC34:
N/A Rev. 0 EPIP-27 Complete System Operable Note 6, 11
0 0
C, 1
Page 2 of 2 TABLE B PASS BACKUP GRAB $&PLE, (HIGH RADIATION FIELD)
(Continuation)
ION SPECIES Radio-Isotope Liquid)
RANGE 3 decades above MDA SENSITIVITY ACCURACY Note 5, 7
+5)
CURRENT PROCEDURE 74CH-9ZZ63 Rev.
1 74CH-9ZZ48 Rev.
1 CALIBRATION Note 4 CAPABILITY
+255 of Reading 74CH-9ZZ65 Note 3 Rev.
1
+255 of Reading 74CH-9ZZ65 Note 3 graph 1000 Rev.
1 ppm to 10$
EPIP-27
- Ccmplete, System Operable Note 2,6, 11 Radio-Isotope 3 Decades Note 5
+5)
(Gaseous) above MDA 74CH-9ZZ63 Note 4 Rev.
1 74CH-9ZZ48 Rev.
1
- Complete, System Operable Note 2,5,7
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NOTES FOR TABLES A AND B Note 1 PASS Performance Test Procedure 74HF-1SS03, Revision 0,
requires an accuracy specification for the PASS pH meters of
+
.2 pH units within the range of 4
10 pH units.
Calibration is performed monthly or prior to use.
Note 2
Calibration check will be accomplished by a
comparison with the Nuclear Sampling System analysis.
Note 3
Calibration check will be accomplished by comparison to a
calibration standard.
Note 4
Calibration checks will be accomplished by comparison to NBS traceable calibration check sources.
Note 5
Note 6
Note 7
The current capability indicates a
range of 10 " to 10 1 Ci/cc.
Procedures 74CH-9ZZ48 "Operation and Calibration of the Stand-alone MCA" and 75CH-9ZZ63 "Operation and Calibration of the PASS/PHA" are used to provide instruction for analyzing the grab samples.
Undiluted Sample Only.
Sample concentration reduced by large attenuation to provide counting capability to bracket the PASS in-line ranges.
Procedure 74CH-9ZZ33 describes use of an attenuator to provide proper range sensitivity and procedure 74CH-9ZZ34 provides operation instructions.
Note 8
Use of EPIP-27 describes the sample
- transfer, and 74CH-9ZZ72 describes the analytical methodology for use of the ion chromatograph for the specific sample.
Note 9
Use of EPIP-27 describes the sample transfer and 74CH-9ZZ35
'escribes the specific methodology.
Note 10-Boron samples will be analyzed by use of an autotitrametric method as described in 74CH-9ZZ06.
Note ll Samples analyzed by a
gas chromatograph per 74CH-9ZZ65 for the specific sample.
Note 12 The System will be usable after completion of PASS performance testing scheduled to be completed prior to the plant restart after the first refueling.
Note 13 Values to be verified during testing following modifications.
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